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7. On or about August 16, 1993, Parent and Defendant David Ring entered Into an
Educational Goods and Services Retail Installment Contract ("Second Contract") for expenses incurred
for goods and services to be provided and rendered to Student by Dickinson during the 1993-1994
academic year. A true and correct copy of the Second Contract is incorporated by reference and
attached as Exhibit B.
6, On or about August 16, 1993, Student executed the Second Contract as co-signer,
thereby agreeing to repay all amounts due on the loan if Parent or Defendant David Ring defaulted in
accordance with the terms of the note, See Exhibit B,
COUNT I
DICKINSON COLLEGE v. JUDITH D. RING
BREACH OF CONTRACT
9, Paragraphs 1 through 6 are incorporated herein by reference as if set forth in full
below,
10, Under the terms of the First Contract, Parent, as "Buyer," agreed to pay Dickinson Six
Thousand Two Hundred Dollars ($6,200.00) with interest at the initial rate of seven point five percent
(7.5%) per annum, in one hundred thirty-six (136) equal monthly installments of Sixty-Seven Dollars
and Eighty-One Cents ($67.61), commencing on or about February 23,1993.
11, Section II of the First Contract provides that "[i]f a payment is more than 15 days late,
a sum equivalent to 5% of the late payment (but no more than $2,50 and not less than $1,00) may be
charged, "
12, Section VI, Paragraphs 3(a) and (b), of the First Contract provides that "Buyer shall be
deemed to have committed an 'Event of Default' of the Contract upon the occurrence of... failure to
make a payment on or before the date it is due, [or] .., failure to make a payment on any other
contract outstanding with [DickinsonJ, [orJ ... failure to perform any other provision of the Contract ...."
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13, Section VI, Paragraph 4, of the First Contract provides that if an Event of Default of the
Contract occurs, and is not cured by the Buyer pursuant to the Notice of Default, Dickinson has "the
right to declare all sums due on the Contract to be Immediately due and payable,"
14. Section VI, Paragraph 4, of the First Contract further provides that the Buyers "agree
to pay all attorneys' fees and other reasonable collection costs and charges necessary for the
collection of any amount not paid when due,"
15. Parent defaulted on the First Contract by failing to make the required monthly
payments on the Contracts due and owing to Dickinson since May 15. 1995,
16, Notices were forwarded to Parent informing Parent of her defaults and her right to cure
such defaults,
17, Parent failed to cure such defaults,
18, Therefore. Dickinson has exercised its right to declare all sums due on the Contract to
be immediately due and payable,
19, The total amount which has become immediately due and payable to Dickinson by
Parent pursuant to the First Contract is Six Thousand Two Hundred Six Dollars and Sixty-Three Cents
($6,206,63), which includes principal in the amount of Five Thousand Three Hundred Eighty-Nine
Dollars and Thirteen Cents ($5.389.13), interest in the amount of Six Thousand Sixty-Seven Dollars
and Seventy-Two Cents ($667,72), late fees in the amount of One Hundred Forty-Nine Dollars and
Seventy-Eight Cents ($149,78). plus attorneys' fees and collection costs,
WHEREFORE, Plaintiff demands judgment against Defendant Against Defendant Judith D.
Ring in the sum of Six Thousand Two Hundred Six Dollars and Sixty-Three Cents ($6,206,63); plus
interest at the rate of nine and one-quarter percent (9.25%) ($1.36 per diem) from August 22, 1996,
late fees, attorneys' fees, collection costs and costs of suit.
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COUNT II
DICKINSON COLLEGE v. JUDITH D. RING and DAVID A. RING
BREACH OF CONTRACT
20, Paragraphs 1 through 19 are incorporated herein by reference as if set forth in full,
21. Under the terms of the Second Contract, Parent and Defendant David A. Ring agreed
to pay Dickinson Ten Thousand Dollars ($10,000,00), with interest at the initial rate of seven percent
(7%) per annum, in one hundred twenly-eight (128) equal monthly installments of One Hundred Eleven
Dollars and Eleven Cents ($111,11), commencing on or about September 28, 1993,
22, Section II of the Second Contract provides that "[i]f a payment is more than 15 days
late, a sum equivalent to 5% of the late payment (but no more than $2,50 and not less than $1.00)
may be charged,"
23, Section VI, Paragraphs 3(a) and (b), of the Second Contract provides that "Buyer shall
be deemed to have committed an 'Event of Default' of the Contract upon the occurrence of...failure to
make a payment on or before the date it is due, [or] .., failure to make a payment on any other
Contract outstanding with [Dickinson] [or} .., failure to perform any other provision of the Contract ...."
24, Section VI, Paragraph 4, of the Second Contract provides that if an Event of Default of
the Contract occurs and is not cured by Parents pursuant to the Notice of Default, Dickinson has "the
right to declare all sums due on the Contract to be immediately due and payable,"
25. Section VI, Paragraph 4, of the Second Contract further provides that the Buyers
"agree to pay all attomey's fees and other reasonable collection costs and charges necessary for the
collection of any amount not paid when due."
26, Parent and Defendant David A. Ring defaulted on the Second Contract by failing to
make the required monthly payments on the Contract due and owing to Dickinson since May 15, 1995,
27. Notices were forwarded to Parent and Defendant David A, Ring informing them of their
defaults and their right to cure such defaults.
28. Parent and Defendant David A. Ring failed to cure such defaults.
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WHEREFORE, Plaintiff Dickinson College demands judgment against Defendant Michelle E. Ring
in the sum of Sixteen Thousand Seven Hundred Fifty-Three Dollars and Twenty-Five Cents ($16,753,25),
plus Interest at Three Dollars and Slxty.Nlne Cents ($3,69) per diem from August 22, 1996, until Student's
obligation Is paid In full, plus costs of suit.
McNEES, WALLACE & NURICK
By
. Stephenson Mat es
Attorney 1.0, No, 67408
100 Pine Street
P. 0, Box 1166
Harrisburg, Pennsylvania 17108.1166
(717) 232-8000
Attorneys for Plaintiff Dickinson College
Dated: June 20, 1997
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EXHIBIT A
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DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - PLAN B
EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT
Date February 15, 1993
1.
Seller.
Buyer(B)'
Dickinson College, Carlisle, Pennsylvania 17013-2896
Judith 0, Ring
16 White Pine Road
Needham, MA 02192
If there is more than one Buyer, each of you will be obligated, jointly and severally,
for all su~s due and for the performance of all agreements ae provided in thie Contract.
Under the terms of this Educational Goode and Services Retail Installment Contract,
you have agreed to pa~the expenses incurred tor goods and services to be provided
and rendered, as the case may be, to Michelle E. Rino
(hereinafter "Student") during his/her enrollment at Dickinson College during the 10Q?_ql
academic year, including tuition, room and board, books and supplies as herein stateo
(hereinafter the "Goods and Services").
The Goods and Services shall include only tuition, room and board.
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUAL PERCENTAGE FINANCE CHARGE: AMOUNT FINANCED: TOTAL OF PAYMENTS: TOTAL SALE
RATE:' Dollar amount Amount of credit Amount paid by PRICE:
Cost of credit as credit will provided by Buyer as total of Total cost of
yearly rats cost Buyer Dickinson Collsge all scheduled purchase on
payments credit, in-
cluding down
payment of
S 15,160.00
7.50 \ s 3,022,16 s 6,200.00 s 9,222.16 s 21,366.00
Rev 2/92
Number of Payments
136
-Variable Rate:
Late Charge:
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Buyer's payment schedule will be as follows:
Amount of Payments
When Payments are Due
$67.81
Monthly conunencing 2/28/93
until 5/28/04
The ANNUAL PERCENTAGE RATE disclosed above is a variable rats and may
change. The ANNUAL PERCENTAGE RATE may increase during the term of
this transact lOr I f the pr Ime I at.a 01 interest announced in ths Wall
Street Journal !lB cf t neo to.' ('lee of b'JEtinrBB Ola J\lIU:' .30 .~,t ~ach calendar
year increases, al1d \o.'iJ 1 h.: i.'.....rpasad tc t~,e rrime rate plus J\. The
ANNUAL PERCF.NTAGE RPTP \oJ!.! 1 r:.e,.t. J nCrf-:b3C rn:)re than ()n~e a year, .1.nd
the new interost rhi'". ",i 11 DP~~lJ:lII~ af fer-t,i.v(' em July 1 tollowing the
increase, if any, j j'I t ne Jd im<..' n.~te ')f lnt~reBt. Arty increase will
be in the form of hign".. payment amounl;B. Tf your cos~ of the Goods
and Servicee Rold ~er"undC<I' were $.Ii.lllll..!lll.- at 7 50 \ per annum
for 136 months, ana the prime rate plus 1\ were increased to 8.~0 \,
your regular monthly payments would increase to S 71.17 . Furt er,
the ANNUAL PERCENTAGE RATE will not increase to more than 1B\ or such
other rate as may be permitted under the Pennsylvania Goods and Services'
Installment Sales Act,
If a payment is more than 15 days late, a sum equivalent to 5\ of the
late paymsnt (but no more than $2.50 and not less than $1.00) may be
charged.
Buyer may prepay the unpaid balance of the Amount Financed and any
FINANCE CHARGE due through the date of early payment, in full or in
part, without penalty.
SEE SECTION VI OF THE CONTRACT BELOW FOR ANY ADDITIONAL INFORMATION ABOUT NON-PAYMENT, DEFAULT
AND REQUIRED REPAYMENT BEFORE THE SCHEDULED DATE FOR REPAYMENT OF THE AMOUNT FINANCED.
Prspayment:
III. ITEMIZATION OF AMOUNT FINANCED
l. Cash price of Goods and Services: $ 21,360.00
2. Total down payment: 15,160.00
3. Unpaid balance of cash price (1 - 2). 6,200.00
Amount paid to others on Buyer's behalf: 0
4.
5. Amount Financed (3 + 4): $ 6,200.00
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IV. CREDIT INSURANCE
Credit life inBurance for the term of thiB Contract iB not required.
V. NO WARRANTIES
THERE ARE NO WARRANTIES, EITHER EXPRESSED OR IMPLIED, GIVEN BY SELLER IN CONNECTION
WITH SALE or THE GOODS AND SERVICES COVERED BY THIS CONTRACT UNLESS BUYER HAS BEEN GIVEN
A SEPARATE WRITTEN WARRANTY.
VI. ADDITIONAL PROVISIONS
1. Buyer agreeB to pay Seller the Total Sale Price by making the total down payment
and paying Seller the Total of Payments in ths numbsr and amount of monthly
payments shown in ths Paymsnt Schedule. Payments ars due on or before ths same
date of each month as the firot payment date. Payments must be made to First
Wachovia, Inc. at the following addreos,
First Wachovia, Inc.
P.O. Box 70095
Charlotte, NC 2B272-D095
2. Buyer's legal rights include tl.e right to pay all or part of the amountB due on
this Contract in advance of their due dates, to obtain a refund or credit of
unearned Finance Charge whenever the amount is paid in full in advance, and
(with Seller's consent) to reinBtate the Contract if Buyer timely cures any
default.
3. Buyer shall be deemed to have committed an "Event of Default" of the contract
upon the occurrence of any of the following'
(a) failure to make any payment on or before the date it is due,
(b) failure to make a payment on any other Contract outstanding with Seller,
lc) failure to perform any other provision of the Contract,
(d) providing Seller with false information or signatures,
(e) death, incompetence, or conviction of any Buyer of crime involving fraud
or dishonesty,
(f) insolvency or bankruptcy of any Buyer.
4. Upon or after the occurrence of any Event of Default, Seller will provide Buyer
with notice, by certified mail as required by law, addreBsed to Buyer's last
known address as shown on Seller's records, advising Buyer of the default and of
Buyer's right to cure ths default. The notice will provide the tims, amount and
performance necessary to cure the default. If Buyer does not cure the default as
providsd in the notics, Seller's rights shall include ths right to declare all
sums due on ths Contract to be immediately due and payable. The Buyer agrees to
pay all attorney's feee and other reasonable collection costs and charges
necessary for the collection of any amount not paid when due.
5. waiver by Seller of any Event of Default shall not be binding upon Seller if
Seller should thereafter choose to exerciBe that or any other right or a similar
Event of Default occurs later. All Seller'B rights and remedies shall be
cumulative. Seller's exercise of one or more rights shall not cause Seller to
lose any other rights.
6. This contract is freely assignable by Seller. Buyer agrees that upon receiving
notice of the assignment Buyer shall be obligated to the Assignee of this
Contract, which Assignee shall have all of Seller's right and remedies.
7. If any part of thiu Contract is held to be illegal, void or unenforceable, that
provision shall be deemed not to have been a part of this Contract, which shall
otherwiss remain fully effective.
8. APPLICABLE LAW' Thie Agreement, whenever called upon to be construed, shall bs
governed by the domestic internal laws of ths Commonwealth of Pennsylvania except
to the sxtent supplemented, euperseded or preempted by fsderal law.
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9. CONSENT TO JURISDICTION. VENUE AND SERVICE: The parties to this Agreement
consent and agree that all legal proceedings relating to the subject matter
hereof shall be maintained in the Court of Common Pleas of Cumberland County,
Pennsylvania, or, if applicable, the United States District Court of the Middle
District of psnnsylvania, and all partics hereto consent and agree that
jurisdiction and venue for such proceedinge shall lie exclusively within eaid
court. Service of process in any such proceeding may be made by certified mail,
return receipt requested, directed to the respective party at the addrese set
forth above.
10. This contract shall be binding upon the parties hereto, their heirs, successors,
assigns and legal representativee.
11. TIME IS OF THE ESSENC~ Of T~TS CONTRACT.
NOTICE. AN~ HOLDER OF THIS CONSUHER CREUIT CONTRACT IS SUBJECT TO ALL CLAIMS AND
DEFENSES WHICH THE DEBTOR ';OULD A~SERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED
PURSUANT HERETO OR WITH THE PROCEEDS HEREOf, RECOVER~ HEREUNDER B~ THE DEBTOR SHJ\LL
NOT EXCEED ll,HOUNTS PAID BV THE I>.:BTUR IIF.REUNUER.
NOTICE TO BU~ER. (1) DO NOT SIGN THIS AGREEMENT BEFORE ~OU READ IT OR IF IT CONTAINS
AN~ BLANK SPACE. (2) ~OU ARE ENTITLED TO A COMPLETEL~ FILLED-IN COP~ OF THIS
AGREEMENT. (3) UNDER THE LAW, ~OU HAVE THE RIGHT TO PA~ OFF IN ADVANCE THE FULL
AMOUNT DUE AND UNDER CERTAIN CONDITIONS TO OBTAIN A PARTIAL REFUND OF THE FINANCE
CHARGE.
BU~ER(S) ACKNOWLEDGE (5) RECEIVING A COMPLETED COPY OF THIS CONTRACT AND INTEND(S)
TO BE LEGALL~ BOUND B~ ITS TERMS
BU~ER(S)' ~D< Je,;(J
I AGREE TO REPA~ ALL AMOUNTS DUE ON THIS LOAN IF THE BORROWER(S)/BU~ER(S) FAILS
TO DO SO IN ACCORDANCE WITH THE TERMS OF THE NOTE:
STUDENT COSIGNER
-A1lt r/ /h 7 7A LdL Z~' q
TRANSCRIPT OF A STllDEN'r~ RECORD WILL (O'r BE RELEASED
IF LOAN PAYMENTS 'rO THE COLLEGE ARE IN AIlREARS OR
DEFAULT.
DATE.
DICKINSON COLLEGE
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DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - PLAN B
EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT
Date
AU9ust 18, 1993
I.
seller.
Dickinson College, Carlisle, Pennsylvania 17013-2896
Buyer (s) ,
I\WI!.:>~,..a
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Judith D. Ring
llj'White Pine' Road'
Needham, MA.02-192--
David A. Ring
406 S. R?val St.
Alexandria, VA 22314
If there is more than one Buyer, each of you will be obligated, jointly and severally,
for all sums due and for the performance of all agreements as provided in this contract.
Under the terms of this Educational Goods and Services Retail Installment contract,
you have agreed to pay the expenses incurred for goods and services to be provided
and rendered, as the case may be, to Michell~ E. ~/~~
(hereinafter "Student") during his/her enrollment at Dickinson 'Cobege during the lQ9~_Q4
academic year, including tuition, room and board, books and supplies as herein stateQ
(hereinafter the "Goods and Services").
The Goods and Services shall include only tuition, room and board.
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUAL PERCENTAGE FINANCE CIlARGE: AMOUNT FINANCED' TOTAL OF PAYMENTS. TOTAL SALE
RATE'. Dollar amount Amount of credit Amount paid by PRICE,
Cost of credit as credit will provided by Buyer as total of Total coot of
yearly rate coot Buyer Dickinson College all scheduled purchase on
payments credit, in-
cluding down
payment of
$ 12,590.00
7.00 , $ 4,222.08 $ 10,000.00 $ 14,222.08 $ 22.590.00
Rev 2/92
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Number of Payments
128
.Variable Rate.
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Buyer'o payment ochedule will be ao followo.
Amount of Payment 0
When Payments are DUB
$111.11
Monthly commencing
until 5/28/04
9/28/93
The ANNUAL PERCENTAGE RATE disclosed above is a variab~ rate and may
change. The AKNUAL PERCENTAGE RATE may increase during tho term of
this tranoaction a t,he pri me rate of into real dnnounced In the Wall
Street Journa.l ,IlF 1.\1 thr. C"'.L.('BC 01 huetnes9 on ",l'urp 30 of each cAlendar
year incressen. and \0.]".) he l.nC:leasA1 t.c thf: rl.jmt:. 't'r.'!".e pllJB \\. The
ANNUAL PERCENTAGE it/\tT:: '.<14.1: n'Jt ~ nCrt~aBe mnrr ..hd.l' f"..nce a ',ear, dnd
the new interest :u.t I:! ,.,111 t;".,:onlu effect i ve em uul.i' " f.allowln9 the
increase, if an'.'. J.n thE" I.rime rate af 11ltereot. Al\;r lncrease will
be in the form ot high..r pdymenl amounto. If your coot of the Goods
and Service 0 Rold It"reund.." were $ 10.000.00 at 7.00 \ psr annum
for 128 montlta, and the prime rate pluo 1\ were increaoed to 8.0 \,
your regul~r mon~hly payments would increaoe to $ 116.~9 . Further,
the ANNUAL PEnCENTAGE RATE will not increase to more t an lB\ or such
other rate ao may be permitted under the Pennoylvania Goodo and Services
Installment SaleD Act.
If a payment is more than 15 days late, a sum equivalent to 5\ of the
late payment (but no more than $2.50 and not less than $1.00) may be
charged.
Buyer may prepay the unpaid balance of the Amount Financed and any
FINANCE CHARGE due through the date of early payment, in full or in
part, without penalty.
SEE SECTION VI OF THE CONTRACT BELOW FOR ANY ADDITIONAL INFORMATION ABOUT NON-PAYHENT, DEFAULT
AND REQUIRED REPAYMENT BEFORE THE SCHEDULED DATE FOR REPAYMENT OF THE AMOUNT FINANCED.
Late Charge:
Prepayment:
III. ITEMIZATION OF AMOUNT FINANCED
l- Cash price of Goods and Services: $ 22,590.00
2. Total down payment. 12.590.00
3. Unpaid balance of cash price (1 - 2): 10,000.00
4. Amount paid to others on Buyer's behalf. 0
5. Amount Financed (3 + 4). $ 10,000.00
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IV. CREDIT INSURANCE
Credit life inourance for the term of thio Contract io not required.
V. NO WARRANTIES
THERE ARE NO WARRANTIES, EITHER EXPRESSED OR IMPLIED, GIVEN BY SELLER IN CONNECTION
WITH SALE OF THE GOODS AND SERVICES COVERED BY THIS CONTRACT UNLESS BUYER HAS BEEN GIVEN
A SEPARATE WRITTEN WARRANTY.
VI. ADDITIONAL PROVISIONS
1. Buyer agreee to pay Seller the Total Sale Price by making the total down payment
and paying Seller the Total at paymente in tho number and amount of monthly
paymento .hown in the Payment Schedule, Payment. are due on or before the .ame
date of each month DB tho firet. payment date. Payment. mu.t be made to Fir.t
Wachovia, Inc. at the following addreoo:
First Wachovia, Inc.
P.O. Box 70095
Charlotte, NC 2B272-0095
2. Buyer'. legal right. include the right to pay all or part of the amount. due on
thi. Contract in advance of their due date., to obtain a refund or credit of
unearned Finance Charge whenever the amount i. paid in full in advance, and
(with Seller's consent) to reinstate the Contract if Buyer timely cure. any
default.
J. Buyer ehall be deemed to have committed an "Event of Default" of the Contract
upon the occurrence of any of the following:
(a) failure to make any payment on or before the date it i. due,
(b) failure to make a payment on any other Contract outstanding with Seller,
(c) failure to perform any other provision of the Contract,
(d) providing Seller with false information or signature.,
(e) death, incompetence, or conviction of any Buyer of crims involving fraud
or di.honesty,
(f) insolvency or bankruptcy of any Buyer.
4. Upon or after the occurrence of any Event of Default, Seller will provide Buyer
with notice, by certified mail a. required by law, addre..ed to Buyer'. last
known address as shown on Seller's records, advising Buyer of the default and of
Buyer's right to cure the default. The notice will provide the time, amount and
performance necessary to cure the default. If Buyer does not cure the default a.
provided in the notice, Seller's rights shall include the right to dsclare all
sums due on the Contract to be immediately due and payable. The Buyer agree. to
pay all attorney's fees and other reasonable collection co.ts and charge.
necessary for the collectlon of any amount not paid when due.
5. Waiver by Seller of any Event of Default shall not be binding upon Seller if
Seller should thereafter choose to exercise that or any other right or a similar
Event of Default occurs later. All Seller's rights and remedies shall be
cumulative. Seller's pxercise of one or more rights shall not cause Seller to
lose any other rights.
6. This contract ie freely assignable by Seller. Buyer agree. that upon receiving
notice of the aesignment Buyer shall be obligated to the A..ignee of thi.
Contract, which A.signee shall have all of Seller's right and remedies.
7. If any part of thie Contract is held to be illegal, void or unsnforceable, that
proviaion ahall be deemed not to have been a part of thia contract, which ahall
otherwiae remain fully effective.
8, APPLICABLE LAW' Thi. Agreement, whenever called upon to be conatrued, ahall be
governad by the domeltic internal lawl of the Commonwealth of pennlylvania except
to the extent .upplemented, super.eded or preempted by federal law.
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11 3. Md. Addre.sed to:
.i Judith D. Ring
~ 1111 Wessex Rd.
BNewton Centre, MA
-CompIet. ~ 1 ancVOf 2 tot.o:ltlonll MMoet.
'Compile tlemo 3..... and "b.
ePtlnl yow rwne Ind add,.... on Ihe mwM of IhIt form 10 lhat we can r.cum thlt
esnfl.~,
. Abch tNt form 10 !hi ftoft of the maIIpIeoe, or trI1h1 bldt tllpaCe doeI not
.e;::!RItum R<<*pl &q/JINttdo en the maJlr:*I below the artlcIt ~
'The RICLI'n RlCtllpt wlllhoW' 10 whom lhIlItld, wu deIYertd and the d&t~
.........
5. RllC8lved By: (Print NlJInIJ)
I .Iso wish to ,oeolve tI10
following ..rvtco. (for on
.xtro foo):
1. Cl Addr.....'. Add,... ~
2. Cl R.S1t\c\ed Delivery .i
Consult postmast.r fa, too. 11.
48, Artld. Number J
P 433 107 351 E
/.." ~b, rvlco Typo e
'. It 0, 13D'glst.red 15 Certlned oX
q ~ 're.. Moll 0 Insured E
, J:t m RocoIpl for Men:hard58 0 COO !I
"./;'3 j.i~: 'b t.'bO.!i;: i
S, Add,......s Addr... (OnlY II requested 'i
and /S.1s paid) (:
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102595.".B-o,,, Domestic Return Receipt
... END :
:f lCompI1t1 tterm 1 and/or 2 for additional MrVict'.
. leornp..ltlmt 3. 4a, and 4b.
I tprtnt your naml and address on the revers. olthislorm 10 thai we can return lhi.
eanfl. l'lu.
IAnach1hla form 10 tht Iron! 01 the maitpieca. 01 on the back if 'PIce does noli
_.
'Wrll,"R.wm R..,.;pt ReqUftf9d"on lhe mailpiece below thl arlicle number.
5 IThI Return Rectipt willhOw 10 whom the artidl was delrvered and lhe dall
C dellvwred.
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i 3. ArtIde Addressed 10:
.i Michelle E. Ring
~ c/o Philipp G. Grefe, Esq.
II Ring & Grefe PC
Two Center Plaza
Mezzanine Suite 130
Boston, MA 02108-1908
I 0150 wish to recelv. the
loIIowIng servlc.s (for on
Bxtra IBB): i
1, Cl AddrB...... Addre..
2, Cl RBstric1ed Delivery
Consult postmaster lor IBe, i'
48. Article Number I:
P 433 107 350 ~
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5, RllC8lved By: (Print NlJInIJ)
4b. SBrvlce Type
o RBgistBred ~ Certified
o Expre.. Moll 0 In.ured
o RBtum Racaipt lor Men:hard58 0 COD
7. Date 01 Delivery
1l~"1 n 00: 10.:1'1
\J~l. tJ. JJI
s. Addr...ee's AddrB" (Only II requeSll>d
and I.el. paid)
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v,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DICKINSON COLLEGE,
Plaintiff
JUDITH D. RING, DAVID A, RING and
MICHELLE E. RING,
Defendants
NO. 9' 7 .
3371
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NOTICE TO DEFEND
You have been sued in court, If you wish to defend against the claims set forth In the following
pages, you must take action within twenty (20) days after this Complaint and Notice are seNed, by
entering a written appearance personally or by attorney and filing in writing with the Court your defenses
or objections to the claims set forth against you, You are warned that if you fail to do so, the case may
proceed without you and a judgment may be entered against you by the Court without further notice for
any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff, You may
lose money or property or other rights important to you,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP,
Court Administrator
Fourth Floor
Cumberland County Courthouse
One Courthouse Square
Carlisle, Pennsylvania 17013-3387
(717) 240-6200
McNEES. WALLACE & NURICK
TRUE COPY FROM RECORD
In Testimony whereof. I here unto set my hand
and the seal 01 said CSF a~~Cartisle, Pa.
Th! ).;... day l C t9 (/ -,
6.... l L' .,
By t)~~
F ,stephenson Matthes, Esquire
Attorney 1.0, No. 67408
100 Pine Street
p, O. Box 1166
Harrisburg, Pennsylvania 17108-1166
(717) 232-8000
Attorneys for Dickinson College
Dated: June 20, 1997
'.
13, Section VI, Paragraph 4, of the First Contract provides that if an Event of Default of the
Contract occurs, and is not cured by the Buyer pursuant to the Notice of Default, Dickinson has "the
right to declare all sums due on the Contract to be Immediately due and payable,"
14, Section VI, Paragraph 4, of the First Contract further provides that the Buyers "agree
to pay all attomeys' fees and other reasonable collection costs and charges necessary for the
collection of any amount not paid when due."
15, Parent defaulted on the First Contract by failing to make the required monthly
payments on the Contracts due and owing to Dickinson since May 15, 1995.
16, Nolices were forwarded to Parent informing Parent of her defaults and her right to cure
such defaults,
17. Parent failed to cure such defaults,
18, Therefore, Dickinson has exercised its right to declare all sums due on the Contract to
be Immediately due and payable.
19. The total amount which has become Immediately due and payable to Dickinson by
Parent pursuant to the First Contract Is Six Thousand Two Hundred Six Dollars and Sixty-Three Cents
($6,206.63), which Includes principal in the amount of Five Thousand Three Hundred Eighty-Nine
Dollars and Thirteen Cents ($5,389.13), Interest In the amount of Six Thousand Sixty-Seven Dollars
and Seventy-Two Cents ($667,72), late fees In the amount ot One Hundred Forty-Nine Dollars and
Seventy-Eight Cents ($149,78), plus attorneys' fees and collection costs,
WHEREFORE, Plaintiff demands judgment against Defendant Against Defendant Judith D.
Ring In the sum of Six Thousand Two Hundred Six Dollars and Sixty-Three Cents ($6,206,63); plus
interest at the rate of nine and one-quarter percent (9.25%) ($1.36 per diem) from August 22, 1996,
late fees, attorneys' fees, collection costs and costs of suit.
- 4-
COUNT II
DICKINSON COLLEGE v. JUDITH D. RING and DAVID A. RING
BREACH OF CONTRACT
20. Paragraphs 1 through 19 are Incorporated herein by reference as If set forth In full.
21, Under the terms of the Second Contract, Parent and Defendant David A. Ring agreed
to pay Dickinson TEln Thousand Dollars ($10,000,00), with Interest at the Initial rate of seven percent
(7%) per annum, in one hundred twenly-eight (128) equal monthly installments of One Hundred Eleven
Dollars and Eleven Cents ($111,11), commencing on or about September 28,1993.
22, Section " of the Second Contract provides tllat "(i]f a payment Is more than 15 days
late, a sum equivalent to 5% of the late payment (but no more than $2.50 and not less than $1.00)
may be charged."
23, Section VI, Paragraphs 3(a) and (b), of the Second Contract provides that "Buyer shall
be deemed to have committed an 'Event of Default' of the Contract upon the occurrence oLfailure to
make a payment on or before the date it is due. [or] .., failure to make a payment on any other
Contract outstanding with [Dickinson] [or] ... failure to perform any other provision of the Contract .....
24, Section VI, Paragraph 4, of the Second Contract provides that if an Event of Default of
the Contract occurs and is not cured by Parents pursuant to the Notice of Default, Dickinson has "the
right to declare all sums due on the Contract to be immediately due and payable."
25. Section VI, Paragraph 4, of the Second Contract further provides that the Buyers
.agree to pay all attomey's fees and other reasonable collection costs and charges necessary for the
collection of any amount not paid when due,"
26, Parent and Defendant David A, Ring defaulted on the Second Contract by failing to
make the required monthly payments on the Contract due and owing to Dickinson since May 15, 1995.
27. Notices were forwarded to Parent and Defendant David A. Ring informing them of their
defaults and their right to cure such defaults.
28. Parent and Defendant David A. Ring failed to cure such defaults.
- 5-
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DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEK - PLAN B
EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLKENT CONTRACT
Date
February 15, 1993
Buyer(e).
Dickinson College, Carlisle, Penneylvania 17013-2896
Judith D. Ring
16 White Pine Road
1.
Seller.
Needham, MA 02192
If there is more than one Buyer, each of you will be obligated, jointly and severally,
for all sums due and for the performance of all agreements as provided in this Contract.
Under the terms of this Educational Goods and Services Retail Installment Contract,
you have agreed to pa~the expenses incurred for goods and services to be provided
and rendered, as the case may be, to Michelle E. RinQ
(hereinafter "Student") during his/her enrollment at Dickinson College during the 1QQ?-ql
academic year, including tuition, room and board, books and supplies as herein statea
(hereinafter the "Goods and Services").
The Goods and Services shall include only tuition, room and board.
II. TEAMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUAL PERCENTAGE FINANCE CHARGE: AMOUNT FINANCED: TOTAL OF PAYMENTS: TOTAL SALE
RATE:. Dollar amount Amount of credit Amount paid by PRICE:
Cost of credit as credit will provided by Buyer as total of Total COllt of
yearly rate cost Buyer Dickinson College all scheduled purchase on
payments credit, in-
cluding down
payment of
$ 15,160.00
7.50 , $ 3,022.16 $ 6,200.00 $ 9,222.16 $ 21,366.00
Rev 2/92
Number of Payments
136
-Vsrisble Ratel
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Buyer's payment schedule will be ae follows:
Amount of Payments
When Payments are Due
$67.81
Monthly commencing 2/28/93
until 5/28/04
The ANNUAL PERCENTAGE RATE disclosed above is a variable rate and may
change. The ANNUAL PERCENTAGE RATE may increase during the term of
this transacti.or I f the prime <at,e of. interest announced in ths Wall
Street Journal ~e c.r the l'J.ose of b". ineee or. June 30 of each calendar
year increaBes, and will. h~ i,,"rpaeed tc the prime rate plue l\, The
ANNUAL PERCRNTAGE RJlT\' wU I nc,t. ,"cr~b30 m.,re than on~.. a year, .:lnd
the new intereet rb'-" "Ul t>e.:o:..,' etfer.t.ivl' nn July 1 toll:lwing the
increase, if any, ir the prime ,'.;.te .,t inttireot. A1"Y increase will
be in the form of higher payment amount.e. If your COB~ of the Goode
and Services Bold her~under were $6.200~ at 7 50 \ per annum
for ~ months, ana the prime ra~uB l' were increased to R.~O \,
your regular monthly paymente WDuld increaee to S 71.17 . Furt er,
the ANNUAL PERCENTAGE RATE will not increase to more than lB\ or such
other rate as may be permitted under the Pennsylvania Goods and ServicBs'
Installment Sales Act.
If a payment ie more than 15 days late, a sum equivalent to 5\ of the
late payment (but no more than $2.50 and not lees than $1.00) may be
charged.
Buyer may prepay the unpaid balance of the Amount Financed and any
FINANCE CHARGE due through the date of early payment, in full or in
part, without penalty.
SEE SECTION VI or THE CONTRACT BELOW FOR ANY ADDITIONAL INFORMATION ABOUT NON-PAYMENT, DEFAULT
AND REQUIRED REPAYMENT BEFORE THE SCHEDULED DATE FOR REPAYMENT OF THE AMOUNT FINANCED.
Late Charge:
Prepayment I
III. ITEMIZATION OF AMOUNT FINANCED
l. Cash price of Goode and Servicee: $ 21,360.00
2. Total down payment: 15,160.00
3. Unpaid balance of caeh price (1 - 2): 6,200.00
othere on Buyer' e beha If: 0
4. Amount paid to
5. Amount Financed (3 + 4): $ 6,200.00
2
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V. NO WARRANTIES
THERE ARE NO WARRANTIES, EITHER EXPRESSED OR IHPLIED, GIVEN Br SELLER IN CONNECTION
WITH SALE or THE GOODS AND SERVICES COVERED Br THIS CONTRACT UNLESS BUrER HAS BEEN GIVEN
A SEPARATE WRITTEN WARRANTr.
(
IV, CREDIT INSURANCE
Credit life insurance for the term of this Contract is not required.
VI. ADDITIONAL PROVISIONS
1. Buyer agreee to pay Seller the Total Sale Price by making the total down payment
and paying Seller ths Total of paymente in the number and amount of monthly
paymente ehown in ths Payment Schedule. paymente are due on or before the .ame
date of each month as the first payment date. Payments must be made to Fir.t
Wachovia, Inc. at the following address:
First Wachovia, Inc.
P.O. Box 70095
Charlotte, NC 2B272-0095
2. Buyer's legal rights include the right to pay all or part of the amounts dus on
this contract in advance of their due dates, to obtain a rofund or credit of
unearned Finance Chargo whenever the amount 1s paid in full in advance, and
(with Seller's consent) to reinstate the Contract if Buyer timely cures any
default.
J. Buyer shall be deemsd to have committed an "Event of Default" of the Contract
upon the occurrence of any of the following:
(a) failure to make any payment on or before the date it is due,
(b) failure to make a payment on any other Contract outstanding with Seller,
(c) failure to perform any other provision of the Contract,
(d) providing Seller with false information or signatures,
(e) death, incompetence, or conviction of any Buyer of crime involving fraud
or dishonesty,
(f) insolvency or bankruptcy of any Buyer.
upon or after the occurrence of any Event of Default, Seller will provide Buyer
with notice, by certified mail as required by law, addressed to Buyer'D laDt
known addresD ae ehown on Seller'e recorde, advising Buyer of the default and of
Buyer'S right to cure the default. The notice will provide the time, amount and
performance neceseary to cure the default. If Buyer does not cure the default aD
provided in the notice, Seller's rights shall include the right to declars all
sums due on the Contract to be immediately due and payable_ The Buyer agreeD to
pay all attorney's fees and other reasonable collection costs and chargsD
necessary for the collection of any amount not paid when due.
4.
5.
Waiver by Seller of any Event of Default shall not be binding upon Seller if
Seller should thereafter choQue to exercise that or any other right or a similar
Event of Default occurs later. All Seller's rights and remedies .hall be
cumulative. Seller's exercise of one or more rights shall not cause seller to
lose any other rights.
Thi. contract is freely assignable by Seller. Buyer agrees that upon rscsiving
notice of the assignment Buyer shall be obligated to the Assignse of thie
Contract, which Assignee shall have all of Seller's right and remedies.
If any part of this contract is held to be illegal, void or unenforceable, that
provieion ehall be deemed not to have been a part of thi. contract, which .hall
otherwiee remain fully effective.
APPLICABLE LAW' This Agreement, whenever called upon to be con.trued, .hall be
governed by the domestic internal laws of the Commonwealth of pennsylvania except
to the extent supplemented, superseded or preempted by federal law.
6.
7.
8.
3
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9. CONSENT TO JURISDICTION, VENUE AND SERVICE. The partieD to thio Agreement
conoent and agree that all legal proceedingo relating to the oubject matter
hereof ohall be maintained in the Court of Common PleaD of Cumberland County,
Pennoylvania, or, if applicable, the United StateD Diotrict Court of the Hiddle
Diotrict of Penneylvania, and all partieD hereto coneent and agree that
juriodiction and venue for ouch proceedingo .hall lie excluoively within oaid
court. Service of proceee in any euch proceeding may be made by certified mail,
return receipt requeoted, directed to the re.pective party at the addreee Bet
forth above.
10. Thio Contract ehall be binding upon the partie. hereto, their heire, eucceeeoro,
aooigno and legal repre.entativeo.
II, TIME IS OF THE ESSENCE OF T~TS CONTRACT.
NOTICE. ANY HOLDER OF THIS CONSUMER CREUIT CONTRACT IS SUBJECT TO ALL CLAIMS AND
DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED
PURSUANT HERE'l'O OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL
NOT EXCEED AMOUNTS PAID BY THE DV-BTOR HF.REUNDER.
NOTICE TO BUYER. (1) DO NOT SICN THIS AGREEMENT BEFORE YOU READ IT OR IF IT CONTAINS
ANY BLANK SPACE. (2) YOU ARE ENTITLED TO A COHPLETELY FILLED-IN COPY OF THIS
AGREEMENT. (3) UNDER THE LAW, YOU HAVE THE RIGHT TO PAY OFF IN ADVANCE THE FULL
AMOUNT DUE AND UNDER CERTAIN CONDITIONS TO OBTAIN A PARTIAL REFUND OF THE FINANCE
CHARGE.
BUYER(S) ACKNOWLEDGE(S) RECEIVING A COHPLETED COPY OF THIS CONTRACT AND INTEND(S)
TO BE ::::::) :OUND B~ iJ. e;O
I ACREE TO REPAY ALL AMOUNTS DUE ON THIS LOAN IF THE BORROWER(S)/BUYER(S) FAILS
TO DO SO IN ACCORDANCE WITH THE TERMS OF THE NOTE.
STUDENT COSIGNER --A1/t r/ IL ? 7~~ I.L ~'Q
TRANSCRIPT OF A STUDENT'S RECORD WILLiiOT BE RELEASED
IF LOAN PAYMENTS TO THE COLLEGE ARE IN ARREARS OR
DEFAULT.
DATE. DICKINSON COLLEGE
2--15'-'13
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Number of PaymentB
128
.Variable Rate.
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BUYBr'B payment Bchedule will be aB followB'
Amount of PaymentB
When PaymentB are Due
$111.11
Monthly commencing
until 5/28/04
9/28/93
ThB ANNUAL PERCENTAGE RATE diBcloBBd above iB a variable rate and may
changB. The ANNUAL PERCENTAGE RATE may increaBe during the term of
this tranBaction ~f t,hB prime rate of intereBt dnnounced 1.n tha Wall
Street Journa~ ~~ 0t thn r.l~su ot husinesB on Ju~P. 30 of each CAlendar
year increases, and .....ill ht~ incr:eased t;c thE/. r.tj-m..:- '('r.te plus 1\. The
ANNUAL PERCENTAGE AAl'E toI: 1~. n~Jt ~. ncreaSG f11l')rE\ '.har r..nee a :iear, and
the new interest rate .llt Lo',,:ome sffectlve 071 .il1t:; :' (0110wl.n9 the
increaee, if an,/. in the prime rllte of llltereBt. An~ increllBe will
be in the f(')rn\ at hiqhk!I" pdyment amounto. I f your cost of the Goods
and SBrviceB ..old hE'reund.." were $ 10.000.00 at 7.00 \ per annum
for ~ months. and.the prime rate plus 1\ were increased to 8.0 \,
your regular monthly payments would increase to $ 116.~9 . FurthBr,
the ANNUAL PER~ENTAGE RATE will not increaBe to more t an lB\ or such
other rate as may be permitted under the pennsylvania Goods and Services
InBtallment Saleo Act.
If a payment is more than 15 days late, a sum equivalent to 5\ of the
late payment (but no more than $2.50 and not leBs than $1.00) may be
charged.
Buyer may prepay the unpaid balance of the Amount Financed and any
FINANCE CHARGE due through the date of early payment, in full or in
part, without penalty.
SEE SECTION VI OF THE CONTRACT BELOW FOR ANY ADDITIONAL INFORMATION ABOUT NON-PAYHENT, DEFAULT
AND REQUIRED REPAYMENT BEFORE THE SCHEDULED DATE FOR REPAYMENT OF THE AMOUNT FINANCED.
Late Charge.
prepayment.
III. ITEMIZATION OF AMOUNT FINANCED
l- Cash prics of Goods and Services. $ 22,590.00
2. Total down payment. 12.590.00
3. Unpaid balancs of cash price (1 - 2). 10,000.00
4. Amount paid to otherB on Buyer'S behalf. 0
5. Amount Financed (3 + 4). $ 10,000.00
. .
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IV. CREDIT INSURANCE
Credit life ineuranc9 for the term of thio Contract io not required.
V. NO WARRANTIES
THERE ARE NO WARRANTIES, EITHER EXPRESSED OR IHPLIED, GIVEN BY SELLER IN CONNECTION
WITH SALE OF THE GOODS AND SERVICES COVERED BY THIS CONTRACT UNLESS BUYER HAS BEEN GIVEN
A SEPARATE WRITTEN WARRANTY.
VI. ADDITIONAL PROVISIONS
1. Buyer agrees to pay Seller the Total Sale Price by making the total down payment
and paying Seller the Total of Payments in the number and amount of monthly
payments shown in the Payment Schedule. Payments ars due on or before the same
date of each month as the first payment date. Payments must bs made to First
Wachovia, Inc. at the following address,
First Wachovia, Inc.
P.O. Box 70095
Charlotte, NC 2B272-DD95
2. Buyer's legal rights include the right to pay all or part of ths amounts due on
this Contract in advance of their due dates, to obtain a refund or crsdit of
unearned Finance Charge whenever the amount is paid in full in advance, and
(with Seller's consent) to reinstate the Contract if Buyer timely cures any
default.
3. Buyer shall be deemed to have committed an "Event of Default" of the Contract
upon the occurrsnce of any of the following'
(a) failure to make any payment on or befors the date it is due,
(b) failure to make a payment on any other Contract outstanding with Seller,
(c) failure to perform any other provision of the Contract,
(d) providing Seller with false information or signatures,
(e) death, incompetence, or conviction of any Buyer of crime involving fraud
or dishonesty,
(f) insolvency or bankruptcy of any Buyer.
4. upon or after the occurrence of any Event of Default, Seller will provide Buyer
with notice, by certified mail as required by law, addressed to Buyer's last
known address as shown on Seller's records, advising Buyer of the default and of
Buyer'e right to cure the default. The notice will provide the time, amount and
performance necessary to cure the default. If Buyer does not cure the default as
provided in the notice, Seller's rights shall include thn right to declare all
sums due on the Contract to be immediately due and payable. The Buyer agrees to
pay all attorney's fees and other reasonable collection costs and charges
necessary for the collection of any amount not paid when due.
5. Waiver by Seller of any Event of Default shall not be binding upon Seller if
Seller should thereafter choose to exercise that or any other right or a similar
Event of Default occurs later. All Seller's rights and remedies shall be
cumulative. Seller's exercise of one or more rights shall not cause Seller to
lose any other rights.
6. This Contract ie freely assignable by Seller. Buyer agrees that upon receiving
notice of the assignment Buyer shall be obligated to the Assignee of this
Contract, which Assignee shall have all of Seller'S right and remedies.
7. If any part of thie Contract is held to be illegal, void or unenforceable, that
provision shall be deemed not to have been a part of this Contract, which Ihlll
otherwile remain fully effective.
B. APPLICABLE LAW: This Agreement, whenever called upon to be conltrued, shall be
governed by the domestic internal laws of ths Commonwealth of Pennsylvania except
to the extent supplemented, superseded or preempted by federal law.
3
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DICKINSON COLLEGE,
Plaintiff
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,PENNSYLV ANIA
v.
: CIVIL ACTION - LAW
JUDITH D. RING, DAVID A. RING, and
MICHELLE E. RING,
Defendants
: NO. 97-3371
PRAECIPE
TO TIlE PROTHONOTARY OF CUMBERLAND COUNTY:
Counsel moves the Court to reinstate the Complaint in the ahol'e-captloned mutter which was
filed on June 23, 1997, to be able to obtain service of the Complainlupon Ilmd A. Ilmg, Ilefendunl.
McNEES, W ALLAt 'E & NlIllI('I\
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Charles T. Yuung, Jr., Esquire,
Attorney I.D. No, NO(,XIl
100 Pine Street
1', O. Box 1166
Harrishurg, I' A 171UX-116h
(717) 232-XIlIlO
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Attorneys lilr PI:tinllff
Dickinson College
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AFFIDAVIT OF SERVICE
q7- 337t CiQt'(7fi2flJ
STATE OF CONNECTlClJT)
) ss: MADISON
COlJNTY OF NEW IIA VEN )
MAY 30, 2000
T, Jerry Juliano, being duly sworn, says:
I. I am over the age of21 and not a party to this action.
2. I am a person authorized to make service of process by the laws ofthe State of
Connecticut, to wit:
3. On May 30, 2000 I served a copy of this Praecipe To Reinstate Complaint and
Complaint upon the defendant DAVID A, RING by leaving with and in the hands of DA VID A.
RING at 37 Dorset Lane, Madison, County of New Haven. State of Connecticut.
A TrEST:
Sworn to before me this ~%
, day 0'r1>>~ . 2000
\-----r ~3~~~~
~ibello~
Notary Public
My Commission Expires: 2-28-02
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DICKINSON COLLEGE,
PlailllilT
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY.PENNSYLV ANIA
v,
CIVIL ACTION - LAW
JUDITII D. RING, DA VII) A, RING IIl1d
MICIIELLE E. RING,
Defendants
NO. 97-3371 CIVIL
PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT
TO TilE PROTIIONOTARY OF CUMBERLAND COUNTY:
Pursuant to Pa. R. Civ. 1', No. 103 7(b), enter judgment ill favor of Dickillson College, PI:tintiff,
in the ahove-eaptioncd :tclion. :tnd :tg:tinst D:tvid A. Ring. Defendant. in the :tbove-c:tptiollcd :tclion, for
f:tilurc to tilc all Answcr to Plaintiff's Compl:tint withintwent)' (20) days from Ihe datc of scrvice of said
Complaint, and :tsscss PI:tintill's dam:tges in the total sum of$16.753.25:ts principal, plus intercst from
August 22, 1996:tt the mte of $3.69 per diem. laIc fees. collcction costs and attorncys' fees, until
Defendant's obligation is p:tid in full. I herchy certify that a written Noticc of Intentiontu File this
Pmecipc for Entry of Defaull Judgmcnt was givcn in accordance with Pa, R, Civ. P. No. 237,1: a true :tnd
correct copy ofthc :tforcsaid Notice is :ttt:tched hcrclo. I herehy certify that the l:tst known addrcsscs of
thc Defcndant is:
David A Ring
37 Dorset L:tne
Madison, CT 06443
McNEES. WALLACE & NlIRICK
" ,
By.
Charles T. Youllg. Jr.. Esquirc
Attorney LD, No. 806NO
100 Pinc Strcet
1',O,llox 1166
lIarrishurg. PA 171ll8-1166
(717) 232-80ll0
Dated: (j" I),~: f,. {{ ( (
Attorneys li,r Plaintiff
Ilickinson t'llllq:e
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I hcrcby ccrtify thatthc Imme and addrcss of the proper pcrsonCs) to rcccive this noticc under Pa.
R. Civ. P. 236 is:
David A. Ring
37 Dorsct Lanc
Madison, CT 06443
McNEES, W ALbACE & NURICK
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By \ I .....\" ,. .-,.- I l /L-
Charlcs T. Young, Jr., ~squirc I
/
Attorneys for Plaintiff
Dickinson College
DICKINSON COLLEGE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
v,
: NO. 97-3371
: CIVIL ACTION-LAW
JUDITH D, RING, DAVID A,
RING and MICHELLE E, RING, : JURY TRIAL OF TWELVE
Defendants : DEMANDED
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Kindly withdraw the appearance of McNEES WALLACE & NURICK LLC on
behalf of Plaintiff in the above mailer.
MeNECI!1S' L! CE & NURICK LLC
V)
By
Charles T. Young, J r squ e
Attorney 1.0. No. 80
P.O. Box 1166
100 Pine Street
Harrisburg, PA 17108-1166
(717) 237-5397
{/7/
Dated: Augus(~, 2004
Attorneys for Plaintiff
Kindly enter (he appearance of MARTS ON DEARDORFF WILLIAMS & OTTO
on behalfofPlaintiffin the above matter.
MARTSON DEARDO F WILLIAMS &
OTTO
By
Davl R. Ga oway, Esquire
Attorney 1.0. No, 87326
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: August 9 ,2004
Attorneys for Plaintiff