HomeMy WebLinkAbout03-0941F:~FILESXDATAFILEXDickinson Collect doc\43.coml/drg/$js
Created: 1/7/03 0:37:15 PM
Revised: 2/28/03 0:13:25 PM
DICKINSON COLLEGE, :
Plaintiff :
V. :
CATHY L. COSTA, :
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION-LAW
JURY TRIAL OF TWELVE DEMANDED
NOTICE
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 served, 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 Plaintiffs. 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:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
Date:
MARTSON DEARDORRF 3VILLIAMS
BYDav~R. Galloway,~sq'~lr; -
I.D. Number 87326 ~
Ten East High Street
Carlisle, PA 17013 ~
(717) 243-3341
& OTTO
Attorneys for Plaintiff
DICKINSON COLLEGE, :
Plaintiff :
V. .'
CATHY L. COSTA, :
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 0
CIVIL ACTION-LAW
JURY TRIAL OF TWELVE DEMANDED
COMPLAINT
AND NOW, comes Plaintiff Dickinson College by and through its attorneys, MARTSON
DEARDORFF WILLIAMS & OTTO, and hereby avers as follows:
1. Plaintiff Dickinson College is a Pennsylvania educational institution and
nonprofit corporation with its principle place of business at West Street, Post Office Box 1773,
Carlisle, Cumberland County, Pennsylvania 17013.
2. Defendant Cathy L. Costa is an adult individual with a last known residence at
111 West Centre Street, #1402, Baltimore, Baltimore County, Maryland, 21201.
3. On or about September 30, 1992, Defendant entered into a Promissory Note -
Federal Perkins Loan Program ("Note #1") with Plaintiff. A copy of Note #1 is attached hereto
as Exhibit "A."
4. Note #1 provided for the financing of $1,100.00 plus interest and costs by
Defendant on her own behalf for educational services and benefits at Plaintiff's institution.
5. On or about October 7, 1993, Defendant entered into an additional Promissory
Note - Federal Perkins Loan Program ("Note #2") with Plaintiff. A copy of Note #2 is attached
hereto as Exhibit "B."
6. Note #2 provided for the financing of $1,100.00 plus interest and costs by
Defendant on her own behalf for educational services and benefits at Plaintiff's institution.
7. Note #1 and Note #2 are funds created under Part E of Title IV of the Higher
Education Act of 1965 as amended, (hereinafter the "Act") and are subject to the Act and the
Federal Regulations issued under the Act.
8. As provided in the Act, Plaintiff acts in a fiduciary capacity in the handling,
disbursing and collecting of funds associated with the programs under the Act.
9. The total collective outstanding principal balance for Note #1 and Note #2 is
$1,884.58.
10. Note #1 and Note #2 grant Plaintiff reasonable attomey's fees which Plaintiff has
calculated to be $500.00.
11. As of January 31, 2003, the principal and interest due and payable by Defendant
to Plaintiff was $2,441.08, plus interest of $0.26 per day, attorney's fees in the amount of
$500.00 and costs accruing subsequent to January 31, 2003.
12. The outstanding balance of $2,441.08 represents the total and actual overdue
value of the financing provided to Defendant under Note #1 and Note #2 for which Defendant
has yet to pay.
COUNT I
BREACH OF CONTRACT
13. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 12 of this Complaint.
14. Plaintiff has fulfilled, performed and complied with all obligations and conditions
of Note #1 and Note #2.
15. Defendant breached the expressed and implied obligations, conditions and terms
of agreement of Note #1 and Note #2 by failing to pay thc amounts financed therein.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
$2,441.08, plus interest of $0.26 per day, attorney's fees in the amount of $500.00 and costs
accruing subsequent to January 31, 2003; said amount is within the limits set forth for
compulsory arbitration in Cumberland County, Pennsylvania.
COUNT II
QUANTUM MERUIT
16. Plaintiff hereby incorporates by reference the averments contained in Paragraphs
1 through 15 of this Complaint.
17. Defendant is liable to Plaintiff and/or has been unjustly enriched in the amount of
$2,441.08, plus interest of $0.26 per day, attorney fees in the amount of $500.00 and costs
accruing subsequent to January 31, 2003.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of
$2,441.08, plus interest of $0.26 per day, attorney's fees in the amount of $500.00 and costs
accruing subsequent to January 31, 2003; said amount is within the limits set forth for
compulsory arbitration in Cumberland County, Pennsylvania.
David R. Galloway, Esqu~e
I.D. Number 87326 ~
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
& OTTO
Attorneys for Plaintiff
In making this communication, we are advising you this firm is a debt collector
attempting to collect a debt for Dickinson College. Any information gained from this
communication will be used for that purpose.
rowe[
-"r is a minor and this note
*wet ia a minor and this note
· records.
Perkins Loan
_Promissory Note ~ Perkins Loai,
Cathy L. Costa
na 4 .... , Promise lo pay to D c tnson Cnllao.~ r~.._: ........
cj'r~ j s le, rfl f/ul ~ , the sum of the amo~ls Ihat
u m me acn~ule of Advm~ s~ ;oflh ~low. ! promise
to pay gl ~onable collmtion ~se, including attorney fees and O~er chugs, ~s~ for t~ mllmtion of ~ ~ou~ not p~d when due.
1 fu~h: un~md a~ agree Ihal:
L ~en~
(I) A~lic~le Law. All sums ~vmc~ un~r thb ~te ~ ~awn ~m a ru~ :ea~d und~ Pa~ E ~ ~tle ~ of t~ Higher Education Act
196~, ~.am~d~ ~e~inaRer c~led Ihe Ac0, a~ ~e sub, ct ~ Iht A~ and ~ ~ Regulations iss~ U~r I~ A~. ~e te~s o[ this note
sh~l ~ mle~t~ in ~a~ wi~ I~ Act a~ Fe~ral Regulal~ns ~ i~ o[ w '.
or c~llafion h ~ting ~m the lnsli~ti~, ~ - -~ .a~ m ~c~ a ~f~t ~ c~cellafi~, ! must r~est the defertnent
must su~it b Iht ~dtulbn ~y ~mentation r~ by ~e lmfi~t~n ~ ~ve that ~ qualify
for the def~t or c~ellation. ] Fuflh~ un~rst~ Ihal ~ l am eligible for ~f~ent or C~eHation u~ ~i~ VI ~gh X][. l am
r~nsib~ for su~itting the a~riate r~u~ ~ time. [ fur~ u~t~d th~ ~ may lose my ~Ferm~t ~ ~n~Uation ~n~ts iF [ fail to
Fde my r~t on time.
~te~t shah a~e ~m the ~ginfling oF t~ ~p~nt ~od ~d sh~l ~ ~ t~ ANNUAL PERCENTAGE RATE O~ ~E I'ERCENT
(5~) on ~e unp~d b~ce, ex.pt ~ ~ in.rest sh~l ~me dwhg any deFe~nt ~ d~c~d in p~agr~ VI(i).
IH- ~ep~ment
(1) l ~mise ~ rely t~ ~incip~ and the inte~ that ~ on it to ~e lnsti~tion over a ~ ~ginn~ng n~e (9) monks aHet the dale
cede to ~ M I~t a half-t~e regul~ s~d~t at m insti~t~n of high~ ~at~n, ~ ~ a ~mp~le ~sti~l~n ou~ide t~ U~ Slal~ ar~(tved
F~ th~ ~M ~ the Unit~ ~tal~ Sec~t~ of Eduction ~a~ cd~d t~ S~t~), ~ e~ing ~n (IO) y~s later, unl~ that ~rlod is
Isho~ un~r p~ag~h IH(5), orl ex tend~ ~ p~pb. IH(4), IH(7) (~s~m), or Vl(I ) (defe~).
~) U~n my ~een ~uesL t~ ~pa~ent ~d may s~ on a da~ e~lier ~ ~e one ~d~al~ ~ pa~gra~ HI(I).
(3XA) ~ ~om~e ~ ~y t~ ~ipal and int~t ov~ t~ ~u~e of ~e ~nyment ~ h ~ mon~ly, b~onlMy, or qu~terly
imminent, u del~i~ by the lnsliluti~. I un~t~ Ihat ~ my ~s~t ~t for all the Io~s m~ ~ me ~ ~e ~sti~tion is not a
mul~ple of $5. ~ Imitation may round that ~yment to the ~xt high~ ~O~ a~unt that b a mulliple of
(B) Notwith~g p~gra~ ~I(3XA), U~n my ~ ~est. ~t may ~ m~e in g~unted ins~U~nts h ~mdnce with n
(4) N~wit~nding p~apaph I~(I), if l quaU~ m a ~w-i~me i~Mual ~g the re~nt
r~u~, m~ ex~ I~ r~ay~nt ~r~ for up ~ an a~iti~ ~n (~ ~s ~ ma ' the [nsti~tion, u~n my ~itten'
. (wh~h ~1~ ~th ~ipd and ~l~l). -r-~ -,- ~,,~s a~ mte~t ~ ~ts loan at ~e rate of $30 ~r mo~II
(5~B) If I have t~eiv~ P~ns Loans ~om other insfitut~ns n~ t~ ~t~ mon~ly mpa~enl ~te on t~se loa~ b ]~s ~an $30. the
monthly payment es~blish~ under SU~graph ~I(5)(A) inclu~s t~ ~oun~ [ o~ on nil my oulstanding Pe~s ~ns, ~l~ing Ihose received
from ~h~ i~fitutio~. ~e ~fl~n of the $30 monthly ~ent thai w~l ~ a~ to ~is ~an wal ~ me diffe~n~ ~een $30 ~d the total of
t~ ~un~ owed at a monthly rate off my other P~kim ~ns.
(6) ~e ~nsli~l~fl may ~it me to pay I~s than ~e r~e of $30 ~r month f~ a ~od of not more th~ one (!) ye~ where ~cess~
avoid h~ip Io me units that ~tion would exte~ ~e Mpny~nt ~ h ~ngmph IH(l).] to
(7) ~ lnstilut~n may. u~n my w~lten r~u~L r~uce ~ sc~ul~ ~paymen~ or exte~ the ~payment ~ indicaled h p~agrnph
if, ~ i~ o~on, cbcumstanc~ s~h ~ prolong~ Ulne~ or ~empl~mem ~ent
cont~ to ~e. ~ from m~ng the s~eduled pay~s.. Howler, interest shall
IV. ~a~t
(1) Z may, at my o~ion and without penal~, pr~ay ~1 or ~y p~ of ~e pdn~l, plus any accrued ht~t thegn, at ny time.
(2) A~un~ I te~y in ~e academic ~ in which the Io~ w~ m~ ~d ~e initi~ grace ~d h~ ~t ended wiU be u~d
a~unt of the loan and will not ~ conside~d a pr~a~t, to reduce the
(3) ]f I repay ~oun~ du~ng the aC~emic ye~ in which the Io~ wu m~e n~ the initial grace ~r~d ended, on~ ~ose amounl~ in exce~s of
I~ ~nt d~ f~ any repaint ~d sh~l ~ coasted a ~aymenl.
(4) If, in an ncad~ic ye~ o~er thru the awed ye~ in which the loan w~ made, ! r~ay more thru the amount due lot an installment, the
excess will ~ us~ to repay p~ipal units I designate it ~ an advance ~yment of the next regul~ ~nstallment.
V. Defaul~
(Il ~e Institution may, at its oplion, ~clare my loan to ~ h default ~ may demand immediate payment of the enli~ un~id balmtce of Iht
loan, including p~ipal, interest, lain charges, and collection costs, if ~
(Al [ do not make a sche~l~ payment when d~ ~d~ the ~payment ~h~ule establish~ by the Institution. ~d
(B) ! do ~t submit to the ~nstilulion, on or ~[ore ~e date on which payment is due. d~umentation thai I qualify for a ~F~ent or
ca.clinton descend in ~icles VL VH, VIII, ~, X, ~I, ~ X]I of this agreem~l.
(2) I U~ersta~ thai if I ~fault on my loan, I~ lfl~itution may disc~se Ihal ] have defaultS, along with other ~lev~l ~formflfinn. to c~edll
bu~au orgnni~qtions.
(3) Further, I undersland that if [ default on my ~an a~ the loan is ~sig~d to the Secretn~ lot ~llection, the S~ta~ may disclose th:ti
have ~fault~, along with other relevant infoTmafion, to cr~il bureau organi~tions.
(4) [ understand that if I default on my loan, I I~n will lose my right to defer repayment,
I of 4
Per kin.~
(5) I Understand that if the Institution accelerales the lOan under paragraph V(I), I then will lose my right to receive a caucellatiou or a porlion
of my loan for any teaching, Head Start, military, volunteer, law enforcemenl, or cmreclions service described in Arllcles VII. VIII. IX, X, and
performed alter the date the Inatitulion accelerated the loan.
(6) [ understand that failure to pay this obligation under the terms agreed upon will prevent my
authorized under Title IV of the Higher Education Act of 1965, as amended, until I have made an'angementa that are satisfactory to the Institution or
obtaining additional studenl financial aid
the Secretary regarding the repayment of the loan.
VI. _Defermen~
(I) I understand that upon making a properly documented wrilton request to the Institution. I may defer making schedhled installment payments,
and will not he liable for any interest that might otherwise accrue, during the following periods: '
(A) While I am enrolled and in attendance as at least a half-time regular student at an institution of higher education or at a comparable
institution outside the United Slates approved for this purpose
(B) For any period not to exceed three (3) by the Secrotmy. .
years during which ! am --
ti) On full-time active duty as a member of the Armed Forces of the United States (Army, Navy, Air Force, Marine Corps, or Coast Guard) or
the National Oceanic and Atmospheric Administration Corps or as an officer on full-time active duty in the Commissioned Corps .of the United
Stales Public Health Service, '
(ii) In service as a volunteer under the Peace Cospa Act,
(iii) A volunteer under the Domestic Volunteer Service Act of 1973 (ACTION programs),
(iv) A full-time volunteer in a tax-exempt organization performing service Comparabin to the service patfmmed in the Peace Crops or under the
Domestic Volunteer Service Act of 1973 (AC"I'ION progrmns), or
tv) Temporarily totally disabled as established by an affidavit of a qualiF~,.d physician, or unable to secure employment because I am providing
care required by my dependent who is so disabled.
(CT) For a Feriod not in excess of two (2) years --
ti) After I receive a I~:~.aleureatu or lm)fessional ckegr~e during which time I am serving in an internship that is required in order that I may
receive professional reCognition required to begin my professional practice or service, or
(ii) Serving in an internship or residency program leading to a degren or certificate awarded by an institution of higher education, a hospital, or a
health-care facility that offers pOStgraduate trsining.
(D) For a period oo~ in excess of one (I) year during which, if ! am a mother o~f___ .p~.chool age chiklren, I have entered or ' '
force, and am being paid at a rate that does not exceed $l more than the minimum rout'ay Wage established by section 6 of the reentered the work
Act of 1938.
(E) For a period not in excess of si'x (6) months ~ Fair Labor Standards
ti) Thai follOws by six (6) months or less a period during which ! was cinched as at least a half-time regular student at an eligible institution;
and
(ii) During which I am pregnant, caring for my eewboro baby, or carla8 for a child immediately after he or she was placed with me through
adoption and I em neither attending an eligible institution of higher education nor gainfully employed..
(F) During a six (6) month period immediately following the expiration of any deferment provided in paragraphs VI(I)(A) through VI(I)(E)..
(2) The Institurion may. upon my written request, defer my scheduled repayments if it determines that the deferment is necessary to avoid a
financial hardship for me. Interest, however, will continue to accrue.
VII. Cnucellation for Teuchin~
(1) I understand that Upon making a properly documented written request to the Institution, ! am entitled to have up to 1(30 percent of the
amount of this loan plus the interest thereon canceled if I perform service --
(A) As a full-rime teacher in a public or other nonprot~t elementary or secondary school in the school district of a local educational agency that
is eligible in such year of service for funds under Chapter ! of the Education Conselidstinn and Improvement Act of 1981, as amended, and which
has been designated by the Secretary (after consultation with each State Department of Education) in accordance with the provisions of section
465(aX2) of the Act as a school with a high concentration of students fl'om Iow-lnCome families. An official Directory of designated Iow-inCome
schools is published annually by the Secretary.
(B) As a full-time leacher of handicapped children (including those who ate mentally retarded, hard-of-hearing, deaf, speech, and language-
impaired, visually handicapped, seriously emotionally disturbed, orthopedieally impaired, have specific learning disabilities, or
impaired children, who by reason thereof require special education and related services); in a public or other nonprofit elementary or secondary
school system, are otherwise health-
(2) A portion of this loan will be canceled for each completed year of teaching service at the following rates:
(A) I5 percent of the total principal amount of the loan plus interest on the Unpaid balance accruing dor~ng ghat year will be canceled for each of
the ia'st and second Complete academic years of that teaching service,
(13) 20 percent of the total principal amount plus interest on the unpaid balance accruing during that year for each of the third and fourth
complete academic years of that leaching service, and
(C) 30 percent of the total principal amount plus interest on the unpaid balance accruing during that year for the fifth complete academic year of
that teaching service.
VIII. Head Start Cancellation
(I) I understand that Upon making a properly documented written request to the Institution, I am entitled to have up to !00 percent of the
amount of this loan plus the ~terest thereon canceled if I p~rform so, ice as a full-time staff member in a Head Start program if ~
(A) That Head Start program is operated for a period that is comparable to a full school year tn the locality, and
(B) .My salary is not more than the salary of a comparable employee of the local educational agency.
(2) This loan will be canceled at the rate of 15 percent of the total principal amount plus interest on the unpaid balance accruing during that year
for each complete school year or equivalent period of service in a Head Start program.
(3) Head Start is a preschool program carried out under the I-lead Start Act.
2 of 4
Perkins Loan
:ire a canccllalion or a I~rlinn
cles ¥11, ¥111, IX, X, and XI
,nal student financial aid
salisfactory to Ihe Inatltution or
mchedbled installment payments,
~tion or at a comparable
rise Corps, or Coast Guard) or
tinned Corps .of the United
n Ihe Peace Corps or under the
~yment because I am providing
required in order that ! may
higher education, a hospital, or a
mtered or reentered the work
n 6 of the Fair Labor Standards
dent at an eligible institution;
was placed with me through
; VI(])(A) Ihrough VI(1)(E).
rmnt is necuscaty to avoid a
up to i{30 percent of the
a local educational agency that
1981, as amended, and which
the provisions of section
ry of designated Iow-income
teal. speech- and lan8uage.
tittles, or are otherwise health-
~t elementary ot secondary .
year will be canceled for each of
h of the third and fourth
fifth complete academic year of
up to 100 percent of the
program if-
balance accruing during that year
Perkins Loan
IX. Military Cancellation
(1) I undersland Ihat upon making a properly documenled wrillen requesl In the instilulion, I am enlilled Io have up Io 50 percent ,f the
principal amounl of this loan plus the inlerest Ibereon canceled if I serve as a member of lhe Armed Forces of the United Slates in an area of
hostilities that qualifies for special pay under section 310 of Tille 37 of the Untied States Code.
(2) This loan will he canceled at the rate of 12 I/2 percent of the total principal amount plus interest on the unpaid balance accruing during that
yea~ for each complete year of such service.
X..Voluntees Service Cancellation
(1) I understand that upon making a properly documented written request to Ihe Institution, I am enlilled to have up to 70 percent of the amnunl
of this loan plus the iolerest thereon canceled if i perform service --
(A) As an volunleer under the Peace Corps Act; or
(B) As a volunteer under the Domeslic Volunteer Service Acl of 1973 (ACTION programs).
(2) This loan will be canceled al the following tales:
(A) 15 percent of the total principal amounl of the loan plus interest on the unpaid balance accruing during that year will he canceled for each of
the Fu'at and second Iwelve (12) month periods of volunteer service completed:
(R) 20 percent of the total principal amounl of the loan plus interesl on Ihe unpaid balance accruing during that yeas will he cancele( for each
the Ihird and fourth Iwelve (12) month periods of volunteer service completed. -.
XI. L. aw Enforcement or Corrections Officer Cancellation
(1) I understand that upon making a properly documented written request to the Institution, [ am en(itled Io have up to 100 percent of the
amount of this loan plus the interest thereon canceled if [ perform qualifying service after the period for which ! ~ceived the loan --
(A) As a full-time law enforcement officer for an eligible local, State. or Federnl law enforcement agency; or -
(B) As a full-time corrections offices for an eligible local, State, or Federal corrections agency.
(2) A portion of this loan will be canceled for each completed year of law enforcement or conections service at the fo[lowing rates:
(A) 15 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for each of thc first anti
second complete years of that service,
(B) 20 percent of the total principal amount plus interest on the unpaid balnnce accruing during that year for each of the third and fourth
complete yeats of that service, and
(C) 30 percent of the total principal amount plus interest on the unpaid balance accruing during the year for the fifth complete year of
service.
XII..Death and Disability Cancellation
(1) In the event of my death, the total amount owed on this loan will he canceled.
(2) If I become permanently and totally disabled after I receive this loan, the Institution will cancel the total amount of this loan.
XIII. ,Change in Name~ Address~ Telephone Number, or Social Se~usily
1 am ~-~.~l~,,~b~;, and any endorser is responsible, for inlom~ing Ihe Instiluti~n of any change o~ changes in name. address, telephone numbet.'or
Social Secusily number.
XIV. Late Charge
(!) The Institution will impose a late charge if-
(A) 1 do not make a scheduled payment when it is'due, and
(B) I do not submit Io the Inslitotinn, on or before the date on which payment is due, documentation that ! qualify for a deferment or cancellnlion
described in ,aa'ticles VI, VI], V~I, IX, X, XI. and XI] of Ibis agreement.
(2) No charge may exceed 20 percent of my monlhly, bimonthly, or qUmerly payment.
(3XA) T~e Institution may --
ti) Add the Isle charge to the i~ncipal the day after the scheduled repayment was due; or
(ii) Include it with the next scheduled repayment after ! have received nolice of Ihe late charge.
(B) If the ]ustitution elects to add the late charge to the oulstanding principal of the loan. it must so inform me before the due date ~f the next
installment.
XV. Assignment
(1) This note may be assigned by the Instilution only to ~
(A) The United States:
(fl) Another institution upon my transfer to that iostilution if that inatitotion is participating in this program; or
(C) Another institution approved by the ~ecretaty.
(2) The provisions of this note that relate to the Institution shall, where appropriate, relate to an assignee.
XVI. Prior Loans
I hereby certify that I have listed below all of the Perkins Loans I have obtained at other institutions. (If no prior loans have been re~.'ei¥~.,d, ~tate
"None.")
PERKINS LOANS AT OTHER INSTITUTIONS
Amount
I~ate
Institution
3 n f4
Perk{,~ l.,,:m
XVII. Schedule of Advances
The following amounts wet~e advanced Io me under this loan agreement on Ihe dates indicated:
Aii~,mi Dale
~gn~um of Borrower
, $550.00 o/ /92 Oo. - u
4
NO1 'ER: DO NOT SION THIS NOTE BEFORE YOU READ IT.
I UNDER~-'i'AND AND AOREE TO ALL OF THE FOREOOINO TERMS AND CONDITIONS.
[This note is signed as a sealed inslrument.]
~el~ae, anl Address (.~lreel ot Bol N~kr. City, Stale. ~ [i~ ~)
would no~ u~er ~ law of t ..... '~ "' '~' ~ un~s the ~w~ is a mi~ a~ t~s n~e
~ State m ~h ~ [nMOutmn ts ~ted, ~e a bmd~g obit[ntis. ~ ~e ~,o~ is a mi~r a~ ~is note
~uld not t~fow ~ legally ~ng. t~ ~slit~ sh~l ~ a ~g~ ~ ~is ~.
I ag~ to r~ay ~11 ~un~ due on this loan if t~ ~w~ fails ~ ~ ~ in ~ with t~ t~s of the note.
- Signat~ of ~sign~ J(se~)]
O~e , 19
Permanent Address (Street or Box Number. City, Stale, and Zip Code)
Social Security Number (cosigner must pro~ide,
The Institution shall provide n copy of this note lo you and any cosigner and you should retain the copy for your records.
(Authority: 20 U.S.C. 1087dd)
4 of 4
Perkins Loan
-09
Promissory_ Note-Federal Perkins Loan Pro~ral'~,
[Any bracketed clause or paragraph may be included at option of institution.]
I,. £af_hv Easts , promise to pay to Dickinson C011e e
Imtitution),locate~at Carlisle. PA 1701q :~ne~ ':. _. q (hereinafter ealled the
· - ,--,-,.,au , me sum ct the amounts that are advanced to me and endorsed in the
Schedule of Advances set forth below. I promise to pay all reasonable collection costs, including attorney fees and other charges, nec~ for
the collection of any amount not paid when due.
I further understand and agree that:
I. General
(1) ~llPJi.~.illL~gt~. All sums advanced under this note are drown from a fund created under Part 1~. of Title IV of the Higher Education Act
of 1965, as amended (hereinafter called the Act), and ate subject to the Act and the Federal regulations is.sued under the Act. The terms of this
note shall be interpreted in accordance with the Act and Federal regulations, copies of which are to be kept by the Institution~
(2) Procedures for Receivine Deferment, Cancellation, or Forbearanc-... I understand that, to receive a deferment, cancellation, or
forbearance, I must request the deferment, cancellation, or forbearance in writing from the Institution and must submit to the In.~titufian any
documentation required by the Institution to prove that I qualify for the deferment, cancellation, or forbearance. I further understand that, if I
am eligible for deferment, cancellation, or forbearance under Articles VI through XIV, I am responsible for submitting the appropriate requests
on time. I further understand that I may lose my deferment, cancellation, and forbearance benefits if I fail to f-de my request on time.
II. Interest
Interest shall accrue from the beginning of the repayment period and shall be at the ANNUAL PERCIi:NTAGIg RATE OF FIVE PERCENT
(5%) on the unpaid balance, except that no interest shall accrue during any deferment period described in Article VII.
(1) I promise to repay the principal and the interest that accrues on it to the Institution over a period beginning nine (9) months after the date
I cease to be at legist a half-time regular student at an institution of higher education, or at a comparable institution outside the United 5tares
approved for this purpose by the United States Secretary of Education (hereinafter called the Secretary), and ending ten (I0) yeats later, unless
that period is [shottencd under paragraph IR(b), or] extended under paragraphs III(4), IIT(7) (extensions), VII(l), or VII(3) (deferments). (2) Upon my written request, the repayment period may start on a date earlier than the one indicated in para&raph IR(l).
0)(A) I promise to repay the principal and interest over the course of the repayment period in equal monthly, bimonthly, or quarterly
installments, as determined by the Institution. I understand that, if my installment payment for all the loans made to me by the ln-~titution is not
a multiple of $5, the Institution may round that payment to the next highest dollar amount that is a multiple of $5. .
(B) Notwithstanding paragraph FIT(3)(A), upon my written request, repayment may be made in graduated installments in accordance with a
schedule approved by the Secretary.
(4) Notwithstanding paragraph IR(l), if I qualify as a low-income individual during the repayment period, the Institution, upon my written
request, may extend the repayment period for up to an additional ten (I0) years and may adjust any repayment schedule to reflect my income.
[(b)(A) If the monthly rate that would be established under paragraph ITt(1), or the total monthly repayment rate of principal and inter6st on
all my Federal Perkins Loans, including this loan, is less than . $40.00 per month, I shall repay the principal and i'nterest on
this loan at the rate of $40.00 per month (which includes both principal and interns0.
(5)(tl) If I have received Federal Perkins Loans from other institutions and the total monthly repayment rate on those loans is less than
$40.00 the $40'. 00 monthly payment established under subparagraph IR(b)(A) includes the amounts I owe
on all my outstanding Federal Perl~inn Loans, including those received from other institutions. The portion of'the $40.00
monthly payment that will be applied to this loan will be the difference between ' $40.O0 and the total of the amounts owed at a
monthly rate on my other Federal Perkins Loans.
(6) The.Institution may permit me to pay less than the rate of $40 o 00
· per month for a period of not more than one (1) year
where necessary to avoid hardship to me unless that action would extend the repayment period in paragraph IR(l).]
(7) The Institution may, upon my written request, reduce any scheduled repayments or extend the repayment period indicated in paragraph
IR(l), if, in its opinion, circumstances such as prolonged illness or unemployment prevent me from making the scheduled repayments.
However, interest shall continue to accrue.
(I) I may, at my option and without penalty, prepay all or any pan of the principal, plus any accrued interest thereon, at any time.
(2) Amounts I repay in the academic year in which the loan was made and the initial grace period has not ended will be used to reduce the
amount of the loan and will not be considered a prepayment.
(3) If I repay amounts during the academic year in which the loan was made and the initial grace period ended, only those amounts in excess
of the amount due for any repayment period shall be considered a prepayment.
(4) If, in an academic year other than the award year in which the loan was made, I repay more than the amount due for an installment, the
excess will be used to repay principal unless I designate it as an advance payment of the next regular installment.
V. Defaul_t
(I) The Institution may, at its option, declare my loan to be in default and may demand immediate payment of the entire unpaid balance of
the loan, including principal, interest, late charges, and collection costs, if--
(A) I do not make a scheduled payment when due under the repayment schedule established by the Institution; and
(B) I do not submit to the Institution, on or before the date on which payment is due, documentation that I qualify for a deferment,
cancellation, or forbearance as described in Articles VI, VII, VIII, IX, X, XI, XII, XIII, or XIV of this agreement.
(2) I understand that the Institution may disclose to credit bureau organizations the amount of loans made to me, along with other relevant
Page 1 of 4 Federal Perkins/July 1993
EXHIBIT "B"
information.
(3) I understand that, if I default on my loan, the Institution may disclose that I have defaulted, along with other relevant information, to
credit bureau organizations.
(4) Further, I understand that, if I default on my loan and tile loan is assigned to the Secretary for collection, the Secretary may disclose that
I have defaulted, along with other relevant information, to credit bureau organizations. ($) I understand that, if I default on my loan, I will lose my fight to forbearance.
(6) I understand that, if I default on my loan, I will lose my right to defer repayments.
(7) I understand that, if the Institution ae. celerates the loan under paragraph V(I), I will lose my fight to receive a cancellation cfa portion of
my loan for any service desgribe, d in Articles Vll[, IX, X, XI, XlI, XllI, or XI'V performed after the date the Institution accelerated the loan.
(8) I understand that failure to pay this obligation under the terms agreed upon will prevent my obtaining additional student financial aid
authorized under Title IV of the Higher Education Act of 1965, as amended, until I have made arrangements that are satisfactory to the
Institution or the Secretary regarding the repayment of the loan.
VI. Forbearance
(1) I understand that, upon making a properly documented written request to the Institution, I am entitled to be granted forbe, araRce of
principal and interest or principal only, renewable at 12-month intervals, for a period not to exceed three years, if-
(A) My debt burden equals or exceeds 20 percent of my gross income; or
(B) The Institution determines that I qualify for other reasons.
VII..Deferment
(1) I understand that, upon making a properly documented written request to the Institution, I may defer making scheduled installment
payments and will not be liable for any interest that might otherwise accrue during the following periods:
(A) For any period that I am-
(i) Enrolled and in attendance as a regular student in at least a half-time course of study at an eligible institution;
(ii) Enrolled and in attendance ns a regular student in a course of study that is part of a graduate fellowship program approved by the
Secretary;
(iii) Engaged in graduate or post-graduate fellowship-supported study (such as a Fulbright gran0 outside the United States; or
(iv) Enrolled and in attendance in a course of study that is part of a rehabilitation training program for disabled individuals approved by the
Secretary.
(B) For any period that I am engaged in service described in Articles VIII, IX, X, XI, XII, XIII, or XIV of this agreement.
(C) For a period not to exceed three (3) years during which-
(i) I am seeking and unable to find full-time employment; or
(ii) For any renzon that my Institution determines has caused or will cause me to have an economic hardship. ,
(2) I understand that I am not eligible for a deferment under paragraph (VII)O)(^) while I am~serving in a medical internship or residency
program. ·
(3) I understand that I may continue to defer making scheduled installment payments and will not be liable for any interest that might
otherwise accrue for a six (6) month period immediately following tho expiration of any deferment provided in paragraph VII(l).
VI~I. Teachin~ Cancellatioq
(1) I understand that, upon making a properly documented written request to the Itmitution, I am entitled to have up to I00 perceat of the
amount of this loan plus the interest thereon canceled if I perform qualifying service after the period for which I received the loan- .
(A) As a full-time teacher in a public or other nonprofit elementaxy or secondary school in the school district of a local educational agency
that is eligible in such year of service for funds under Chapter I of the Education Consolidation and Improvement Act of 1981, as amended, and
which has been designated by the Secretary (after consultation with each State Department of Education) in accordance with the provisions of
section 465(a)(2) of the Act as a school with a high ¢oacantration of students from Iow-income families. An official Directory of d~signated
low-income schools is published annually by the Secretary; '
(B) As a full-time special education teacher (including teachers of infants, toddlers, children, or youth with disabilities) in a public or other
nonprofit elementary or secondary school system, or as a full-time qualified professional provider of early intervention services in a public or
other nonprofit program under public supervision by the lead agency as authorized in section 6760})(9) of the Individuals With Disabilities
Education Act; or
(C) As a full-time teacher of mathematics, science, foreign languages, bilingual education, or any other field of expertise that is determined
by the State Department of Education to have a shortage of qualified teachers.
(2) A portion of this loan will be canceled for each completed year of teaching service at the following rates:
(A) 15 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for each of the first and
second complete academic years of that teaching service;
(B) 20 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for each of the third and
fourth complete academic years of that teaching service; and ·
(C) 30 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for the fifth complete
academic year of that teaching service.
IX. Head Start Cancellation
(1) I understand that, upon making a properly documented written request to the Institution, I am entitled to have up to 100 percent of the
amount of this loan plus the interest thereon canceled if ! perform qualifying service after the period for which I received the loan ns a full-time
staff member in a Head Start program if-
(A) That Head Start program is operated for a period that is comparable to a full school year in the locality; and
Page 2 of 4 Federal Perkins/July 1993
(B) My salary is not more than the salary of a comparable employee of the local educational agency.
(2) This loan will be canceled at the rate of 15 percent of the total principal amount of the loan plus interest on the unpaid balance accruing
during that year for each complete school year or equivalent period of service in a Head Start program.
(3) Head Start is a preschool program carried out under the Head Start Act.
X.~
(I) I understand that, upon making a p~'operly documented written request to the Institution, I am entitled to have up to 50 percent of the
principal amount of this loan plus the interest thereon canceled if I serve as a member of the Armed Forces of the United States in an area of
hostilities that qualifies for special pay under section 3 I0 of Title 37 of the United States Code.
(2) This loan will be canceled at the rate of 12 1/2 percent of the total principal' amount of the loan plus interest on the unpaid balance
accruing during that year for each complete year of such qualifying service after the period for which [ received the loan.
XI. Volunteer Service Cancellatioq
(I) I understand that, upon making a properly documented written request to the Institution, I am entitled to have up to 70 percent of the
amount of this loan plus the interest thereon canceled if I perform qualifying service after the period for which ! received the loan- - (A) As a volunteer under the Peace Corps Act; or
(B) As a volunteer under the Domestic Volunteer Service Act of 1973 (ACTION programs).
(2) This loan will be canceled at the following rates:
(A) 15 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for each of the first and
second twelve (12) month periods of volunteer service completed; and
(B) 20 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for each of the third and
fourth twelve (12) month periods of volunteer service completed.
XII. Law Enforcetuent or Corrections Office~- Cancellst!¢.,
(l) ! understand that, upon making a properly documented written request to the Institution, I am entitled to have up to 100 percent of the
amount of this loan plus the interest thereon canceled if I perform qualifying service after the period for which I received the loan- (A) As a full-time law enforcement officer for service to an eligible local, State, or Federal law enforcement agency; or
(B) As a full-time corrections officer for service to an eligible local, State, or Federal corrections agency. ,
(2) A portion of this loan will be canceled for each completed year of law enforcement or corrections service at the following rates:
(A) 15 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for each of the first and
second complete years of that service;
(B) 20 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for each of the 'third and
fourth complete years of that service; and
(C) 30 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for the fifth complete
year of that service.
X[II. Nurse or 1%/edical Technician Cancellatior,
(1) I understand that, upon making a properly documented written request to the Institution, I am entitled to have up to 100 percent of the
amount of this loan plus the interest thereon canceled if I perform qualifying service after the period for which I received the loan as a full-time
nurse or medical technician providing health care services.
(2) A portion of this loan will be canceled for each completed year of service at the following rates:
(A) 15 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during.that year for each of the first and
second complete years of that service;
(B) 20 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for each of the third and
fourth complete years of that service; and
(C) 30 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for the fifth complete
year of that service.
XIV. Child or Family Service A~enc¥ Cancellatic...
(1) I understand that, upon making a properly documented written request to the Institution, I am entitled to have up to 100 percent of the
amount of this loan plus interest thereon canceled if I perform qualifying service after the period for which I received the loan as a full-time
employee of an eligible public or private nonprofit child or family service agency who is providing, or supervising the provision of, services to
high-risk children who are from low-income communities and the families of such children.'
(2) A portion of this loan will be canceled for each completed year of service at the following rates:
(A) 15 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for each of the first and
second complete years of that service;
(B) 20 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for each of the third and
fourth complete years of that service; and
(C) 30 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for the fifth complete
year of that service.
XV. Death and Disability Cancellation
(1) In the event of my death, the total amount owed on this loan will be canceled.
(2) If I become permanently and totally disabled after I receive this loan, the Institution will cancel the total amount of this loan.
X'V'[. ChanEe in Name, Address, Telephone Number, or Social Security Numbs_..
I am responsible for informing the Institution of any change or changes ia name, address, telephone number, or Social Security number.
Page 3 of 4 Federal Perkins/July 1993
XVII. Late Charge
(1) The Institution will impose a' late charge if-
(A) I do not make a scheduled payment when it is due; and
(B) I do not submit m ~e In~itution, on or before the date on which payment is due, documentation that I quell'fy for a deferment,
cancellation, or forbearance ns described in Articles VI, VIZ, VIII, IX, X, XI, XII, XIII, or XIV of this agreement.
(2) No charge may exceed 20 percent of my monthly, bimonthly, or quarterly payment.
O)(A) Th~ Institution may-
(i) Add the late charge to the principal the day after the scheduled repayment was due; or
(ii) Include it with the next scheduled repayment aRer I have received notice of the late charge.
(B) If the Institution elects to add the late charge to the outstanding principal of the loan, it must so inform me before the due ant, of the
next installment.
XV]H. Assitnment
(1) This note may be assigned by the Xnstitution only to--
(A) The United States;
(B) Another institution upon my transfer to that institution if that institution is participating in this program; or
(C) Another institution approved by the Secretary.
(2) The provisions of this note that relate to the Institution shall, where appropriate, relate to an assignee.
(3) Any holder of this loan is subject to all claims and defenses that ! could a.xsert against the Institution that made this loan; my recovery is
limited to the amount ! repaid on this loan.
I hereby certify that ! have listed below all of the Federal Perkins Loans I have obtained at other institutions. (If no prior loans have been
received, state "None.
FEDERAL PERKINS LOANS AT OTH~R iNSTITUTIONS
Amount Date Institution
!
2
3
4
XX. Schedule of Advances
The following amounts were advanced to me under this loan agreement on the dates indicated:
Amount Date Sigo~mre of Borrower
$550.00 8/11/93 ~.~. ~
$550.00 1/12/94 (?,~cC/_c~ ~, ~
'
NOTICE TO BORROWER: DO NOT SIGN THIS NOTE BEFORE YOU READ lT.
I UNDERSTAND AND AGREE TO ALL OF THE FOREGOING TERMS AND CONDITIONS.
[This note is signed az a sealed instrument.]
Signature ~'~~ ~, ~ [(seal)]
Date, / O { ,
Permanent Address (Street or Box Number, City, State, and Zip Code)
Social Security Number (borrower must provide) / '7 0 -- -7~:~ -- / ~ ~ ~
The borrower and Institutioa shall execute this note without security and without endorsement.
The Institution shall provide a copy of this note to you and you should retain the copy for your records.
(Authority: 20 U.S.C.1087dd)
Page 4 of 4 Federal Perkims//uly 1993
VERIFICATION
I, THOMAS MEYER, Assistant Treasurer of Dickinson College, acknowledge that I
have the authority to execute this Verification on behalf of Dickinson College and certify that the
foregoing Complaint is based upon information which has been gathered by my counsel in the
preparation of this lawsuit. The language of this Complaint is that of counsel and not my own. I
have read the document and to the extent that this Complaint is based upon information which I
have given to my counsel, it is true and correct and to the best of my knowledge, information
and belief. To the extent that the content of this Complaint is that of counsel, I have relied upon
counsel in making this Verification.
This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904
relating to unsworn falsification to authorities, which provides that if I knowingly make false
averments, I may be subject to criminal penalties.
Dated:
Dickinson College
Tho~'-~'
Assistant Treasurer of Dickinson College
F:\FI LES\DATAFILE\Dickinson Collect.doc\43-com. I
F:~qLES~DATAFILEXDickinson College 7619~DickinsonCollegeC o11¢ ctions7619C~Documents\43 .pra2/cny
Created: 5/29/03 11:19:59 AM
Revised: 5/29/03 11:24:14 AM
7619C.43
DICKINSON COLLEGE, :
Plaintiff :
V. :
CATHY L. COSTA, :
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-941
CIVIL ACTION-LAW
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE TO DOCUMENT SERVICE PURSUANT TO THE
PENNSYLVANIA LONG ARM STATUTE
I hereby certify that a copy of the Complaint was personally served upon Cathy L. Costa on
Tuesday, May 20, 2003, at 5:18 p.m.
Attached is the certified Affidavit of Service.
MARTSON DEARDORFF WILLIAMS & OTTO
By
I.D. No. 87326 X,
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Date: May 29, 2003 Attorneys for Plaintiff
DICKINSON COLLEGE,
Plaintiff
V.
CATHY L. COSTA,
Defendant
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 03-941
· CIVIL ACTION-LAW
· JURY TRIAL OF TWELVE DEMANDED
AFFIDAVIT OF SERVICE
I, Adrian M. Clarke, being duly sworn according to law, depose and state that a copy of the attached
Complaint was served on the following Defendant, Cathy L. Costa, 31 Acorn Circle, Apt. 301, Towson,
Maryland 21286 by personal service at ~"[$W" onthe ~ov~ dayof ~ ,2003.
SAFE AND SECURE ENTERPRISES, INC.
Adrian M. Clarke
Swom to and subscribed before me
This a2 .L_ day of W]~/
,2003
CERTIFICATE OF SERVICE
I, Christina N. Yost, an authorized agent for Martson Deardorff Williams & Otto, hereby
certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post
Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Ms. Cathy L. Costa
31 Acorn Circle, Apt. 301
Towson, MD 21286
MARTSON DEARDORFF WILLIAMS & OTTO
By ~
Christina N. Yost //
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: May 29, 2003
DICKINSON COLLEGE,
Plaintiff
CATHY L. COSTA,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-941
CWIL ACTION - LAW
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE TO DOCUMENT COSTS ASSOCIATED WITH SERVICE
PURSUANT TO THE PENNSYLVANIA LONG ARM STATUTE
I hereby certify that Plaintiff incurred costs of $100.00 to serve the Complaint upon Cathy
L. Costa at 31 Acorn Circle, Apt. 301, Towson, Maryland 21286. A copy of the invoice is attached
hereto.
MARTSON DEARD~_Q~RFI~ WI~,~I~IAMS & OTTO
David R. Galloway, Esquire
I. D. Number 87326
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Date: June 13, 2003 Attorneys for Plaintiff
Safe and Secure Enterprises, Inc.
Phone: 877-379-6166
Fax: 877-8'13-3587
David R. Galloway, Esquire
Martson Deardorff Williams & Otto
Ten East High Street
Carlisle, PA 17013
INVOICE
www.ssenterprisesinc.com
DATE: 5/21/2003
Invoice No.: 1025-01 ~ment Terms: immediate
DESCRIPTION HOURS/MILES RATE T AMOUNT
Process Service-Flat Fee- Costa N/A $100.00 $ 100.00
EIN: 01-0571756 SUBTOTAL $ 100.00
Please Submit Payment to: TAX RATE 5.00%
Safe and Secure Enteprises, Inc. SALES TAX
1290 Bay Dale Drive, PMB 1'11 OTHER
Arnold, Maryland 21012 TOTAL $
THANK YOU FOR YOUR PROMPT PAYMENT! ~.~'~' ~',~/~3
CERTIFICATE OF SERVICE
I, Christina N. Yost, an authorized agent for Martson Deardorff Williams & Otto, hereby
certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post
Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Ms. Cathy L. Costa
31 Acorn Circle, Apt. 301
Towson, MD 21286
MARTSON DEARDORFF WILLIAMS & OTTO
,df
Christina N. Yost
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated:
DICKINSON COLLEGE,
Plaintiff
CATHY L. COSTA, :
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-941
CIVIL ACTION - LAW
JURy TRIAL OF TWELVE DEMANDED
PRAECIPE TO DISCONTINU.E_
Plaintiff requests the above-captioned matter be discontinued without prejudice.
I. D. Number 87326
Ten East High Street
Carlisle, PA 17C~13
(717) 243-3341
Date: August 19, 2003 Attorneys for Plaintiff
CERTIFICATE OF SERVICE
I, Martha-Anne lben, an authorized agent for Martson Deardorff Williams & Otto, hereby
certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post
Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Ms. Cathy L. Costa
31 Acorn Circle, Apt. 301
Towson, MD 21286
MARTSON DEAP,,,DORFF WILLIAMS & OTTO
Martha-Anne Iben
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: August 19, 2003