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II. Scction VI. Pamgraph 4 ofthc Contmct(s) providcs that ifan Evcnt of Dclintll ofthc
contmct occurs. and is not cnrcd hy thc Buycr pursuant to lhc Noticc of DclilUlt. Dickinson has "thc right
to dcclarc all sluns duc on thc contmctto bc immcdiatcly duc and payablc."
12. Lcstcr H. Poris. Parcnt has dcfaullcd on thc Contract(s) by Iililing 10 makc thc rcquircd
monthly paymcuts on the Contract(s) due and owing to Dickinson since Septcmher 12,1994.
13. Noticcs wcrc forwardcd to Parcnt informing him of his dclimlt and right to curc such
dcfault.
14. Parcnt has failcd to curc such dclimlts.
15. Thcrcforc Dickinson has cxcrciscd its right to dcclarc all slnns duc on thc Contract(s) to
bc immcdiatcly duc and payablc.
16. Thc total amount which has bccomc immcdiatcly duc and payablc to Dickinson by
Parcnt, Lcster H. Poris pursuant to thc Contract(s) is Six Thousand Two Hundred Nincty Eight Dollars
and Sixty-two Ccnts ($6,298.62), which includcs principal in thc amount ofFivc Thousand Ninc Dollars
and Scvcnty-eight Cents ($5,009.78), intcrcst inthc amount ofOnc Thousand Onc Hundrcd Fifty Eight
Dollars and Two Ccnts ($1,158.02), latc fccs in thc amount ofOnc Hundrcd Thirty Dollars and Eighty-
two Ccnts ($130.02), plus rcasonablc attorney's Ices and collcction costs.
WHEREFORE, PlaintifrDickinson Collcgc dcmandsjudgment against Parcnt Lcstcr H. Poris in
the sum of Six Thousand Two Hundrcd Nincty Eight Dollars and Sixty-two Ccnts ($6,298.62), plus
intcrcst at thc ratc indicated on thc individual Contract(s), latc fecs, costs of suit, attorncys' fees and
collcction costs.
VERIFICATION
Suhjcct to thc penallics of 18 Pa. C.S. ~4904rclating to unsworn Ihlsilication to authorities. I hcrcby
ccrtify that I am Thomas 13. Meyer, Assistant TrcasurcrofDickinson College, and am authorized to verify
this Complainl on its bchalf: and furthcr, thatthc f.1cts sct forth inthc foregoing Complainl arc truc and
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eorrcct to thc bcst of my information and belie!:
Datcd: fll fi I "i /:'
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DICKINSON COLLEGE FLEXIBLE FINANCING SYST~I - 2500 P~~
EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLNENT CONTRACT
Date March 1, 1985
I. Seller: Dickinson College, Carlisle, Pennsylvania 17013
Buyer(s):
Lester Poris
11329 Little Patuxent Pkwy., Columbia, MD 21044
If there is more than one Buyer, each of you will be obligated, jointly
and severally, for all Sums due ann 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 Ellen
(hereinafter "Student") during his/her enrollment at Dickinson College during
the 1984-85 academic year, including tuition, room and board,
books and supplies as herein stated (hereinafter the "Goods and Services").
The Goods and Services shall include only the following: Tuition and
room and board.
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
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ANNUAL FINANCE AMOUNT FINANCED: TOTAL OF TOTAL SALE
PERCENTAGE CHARGE: Amount of credit PAYMENTS: PRICE:
RATE: Dollar Amount provided by Amount paid Total cost of
Cost of credit credit will Dickinson College by Buyer as pu rchas e .on
as yearly rate cost Buyer total of all credit, in-
scheduled eluding down
Prior to repay- payments payment of
ment: 11. 000% $ 8.640.00
During repay-
ment: 10.999% $ 960.96 $ 2,400.00 $3,360.96
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IV. CREDIT INSURANCE
Credit life insurance ror the term of this Contract is 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 lIAS 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 are due on or
before the same date of each month as the first payment date. Payments must
be made to Industrial Valley Bank at the following address:
Industrial Valley Bank
P.O. Box 433
Upper Darby, Pennsylvania 19082
2. Buyer's legal rights include the right to pay all or part of the amounts
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 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 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 or the Contract,
(d) providing Seller with false information or signatures,
(e) death, incompetence, or conviction of any Buyer of crime in-
volving fraud or dishonesty,
(f) insolvency or bankruptcy of any Buyer.
4. Upon or after the occurrence or any Event of Default, Seller will
provide Buyer with notice, by certiried mail as required by law, addressed to
Buyer's last known address as shown on Seller's records, advising Buyer of the
default and or Buyer's right to cure the derault. The notice will provide the
time, amount and perrormance necessary to cure the default. If Buyer does not
cure the default as provided in the notice, Seller's rights shall include the
right to declare all sums due on the Contract to be immediately due and payable.
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aCT 2 3 19S5
DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - 2500 PLAN
EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT
/:
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Date Au!\ust 1, 1985
I. Seller: Dickinson College, Carlisle, Pennsylvania 17013
Buyer(s):
Lester and Barbara Paris
11329 Little Patuxent Pkwy., Columbia, HD 21044
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 Ellen
(hereinafter "Student") during his/her enrollment at Dickinson College during
the 1985-86 academic year, including tuition, room and board,
books and supplies as herein stated (hereinafter the "Goods and Services").
The Goods and Services shall include only the following:
Tuition and room and board
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUAL FINANCE AMOUNT FINANCED: TOTAL OF TOTAL SALE
PERCENTAGE CHARGE: Amount of credit PAYMENTS: PRICE:
RATE: Dollar Amount provided by Amount paid Total cost of
Cost of credit credit will Dickinson College by Buyer as purchase on
as yearly rate cost Buyer total of all credit, in-
scheduled eluding down
Prior to re~ay- payments pa~ment of
ment: 11.0 0 % $ ,630.00
During repact;- 1,459.16 2,500.00 3,959.16
ment: 10.9 6 % $ $ $ $ 12,130.00
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Buyer's payment schedule will be as follows:
Number of Pa ments
Amount of Pa ents
When Pa ments Are Due
20
22.92
monthly commencing October 1, 1985,
and continuing until May 1, 1987
or such time as Student is no long-
er enrolled at Dickinson (or in an
approved full-time off-campus pro-
gram of studies), whichever is
earlier.
72
47.58
monthly commencing June I, 1987
or such time as Student is no longer
enrolled at Dickinson (or in an
approved full-time off-campus program
of studies),. whichever is earlier.
Late charge: 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.
Prepayment: 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. Payments greater than the payoff
amount but less than $3.00 will not be refunded.
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.
III. ITEMIZATION OF AMOUNT FINANCED
1. Cash price of Goods and Services: $ 12,130.00
2. Total down payment: 9,630.00
3. Unpaid balance of cash price (1 - 2): 2,500.00
4. Amount paid to others on Buyer's behalf: .00
5. Amount Financed (3 + 4): $ 2,500.00
-2-
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IV. CREDIT INSURANCE
Credit life insurance for the term of this Contract is 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 agrees to pay SeUer 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 are due on or
before the same date of each month as the first payment date. Payments must
be made to Industrial Valley Bank at the following address:
Industrial Valley Bank
P.O. Box 433
Upper Darby, Pennsylvania 19082
2. Buyer's legal rights include the right to pay all or part of the amounts
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 reinstate the Contract if Buyer timely cures any
default.
3. Buyer shall be deemed to have counnitted 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 in-
volving 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, addres~ed to
Buyer's 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 as provided in the notice, Seller's rights shall include the
right to declare all sums due on the Contract to be immediately due and payable;
-3-
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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 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 rights and remedies.
7. If any part of this 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 otherwise remain fully effective.
8. The laws of the Commonwealth of Pennsylvania shall apply to this Con-
tract except to the extent supplemented, superseded or pre-empted by federal
law.
9. This Contract shall be binding upon the parties hereto, their heirs,
successors, assigns and legal representatives.
10. TIME IS OF THE ESSENCE OF THIS CONTRACT.
NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS
AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR
SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY
HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER.
NOTICE TO BUYER: (1) DO NOT SIGN THIS AGREEMENT BEFORE YOU READ IT OR IF IT
CONTAINS ANY BLANK SPACE. (2) YOU ARE ENTITLED TO A COMPLETELY 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 COMPLETED COPY OF THIS
CONTRACT AND INTEND(S) TO B i'r:.EGALL BjUND BY ITS TERMS.
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BUYER(S) :
DATE:
DICKINSON COLLEGE
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DICKINSON COLLEGE,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION. LAW
LESTER H, PORIS and
BARBARA PORIS, h/w and
ELLEN PORIS,
Defcndants
NO.
COMPLAINT
1. Plaintiff Dickinson College ("Dickinson") is a Pcnnsylvania cducational institution with
its principal offices located in Carlisle, Pennsylvania 17013.
2. Defendants Lester H. Poris and Barbara Poris, h/w ("Parents") arc adult individuals
whose last known address is 11329 Little Patuxent Parkway #315, Columbia, Maryland 21044.
3. Defendant Ellen Poris ("Student") is an adult individual whose last known address
is 178 I 3 Crickett Hill Drive, Germantown, Maryland 20874.
4. ' On or about February 5, 1985, Parent, Lester H. Poris entered into an Educational
Goods and Services Rctail Installment Contract ("First Contract") for expenses incurred for goods and
services to be provided and rendered to his daughter Ellen Poris by Dickinson during the 1984-85
academic year. A true and correct copy of the contract is incorporated by reference and attached as
Exhibit "A".
5. On or about October 7, 1985, Parents, Lester H. Poris and Barbara Poris entered into an
Educational Goods and Services Retail Installment Contract ("Second Contract") for expenses incurred
for goods and services to be provided and rcndered to their daughter Ellen Poris by Dickinson during the
1985-86 academic year. A true and correct copy of the contract is incorporated by reference and
attached as Exhibit "B".
I,
II. Scction VI, Parugraph 4 of the Contract(s) provides that ifan Evcnt of Dcfault ofthc
contract occurs, and is not cured by thc Buyer pursuant to the Notiec of Dcfault, Dickinson has "thc right
to dcclare all sums due on thc contract to be immcdiatcly due and payablc,"
12. Lester H. Paris, Parent has defaultcd on the Contract(s) by failing to makc the rcquired
monthly paymcnts on the Contract(s) due and owing to Dickinson sincc Scptcmbcr 12, 1994.
13. Notices were forwarded to Parent informing him of his dcfault and right to curc such
default.
14. Parent has failed to cure such defaults,
15. Therefore Dickinson has exercised its right to dcclare all sums due on the Contract(s) to
be immediately due and payable.
16. Thc total amount which has become immediately due and payable to Diekiason by
Parent, Lester H. Poris pursuant to the Contract(s) is Six Thousand Two Hundred Ninety Eight Dollars
and Sixty-two Cents ($6,298.62), which includes principal in the amount of Five Thousand Nine Dollars
ancl Seventy-eight Cents ($5,009.78), interest in the amount of One Thousand One Hundred Fifty Eight
Dollars and Two Cents ($1,158.02), late fees in the amount of One Hundred Thirty Dollars and Eighty-
two Cents ($130.02), plus reasonable attorney's fees and collection costs,
WHEREFORE, Plaintiff Dickinson College demands judgment against Parent Lester H. Poris in
the sum of Six Thousand Two Hundred Ninety Eight Dollars and Sixty-two Cents ($6,298,62), plus
intcrest at the rate indicated on the individual Contract(s), late fees, costs of suit, attorneys' fees and
collection costs.
. a "0
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DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - 2500 P~~
EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT
Date March 1, 1985
1. Seller: Dickinson College, Carlisle, Pennsylvania 17013
Buyer (5): Lester Poris
11329 Little Patuxent Pkwy., Columbia, MD 21044
If there is more than one Buyer, each of you will be obligated, jointly
and severally, for all sums due ann 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 Ellen
(hereinafter "Student") during his/her enrollment at Dickinson College during
the 1984-85 academic year, including tuition, room and board,
books and supplies as herein stated (hereinafter the "Goods and Services").
The Goods and Services shall include only the following: Tuition and
room and board.
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUAL FINANCE AMOUNT FINANCED: TOTAL OF TOTAL SALE
PERCENTAGE CHARGE: Amount 0 f credit PAYMENTS: PRICE:
RATE: Dollar Amount provided by Amount paid Total cost of
Cost of credit credit will Dickinson College by Buyer as purchase on
I as yearly rate cost Buyer total of all credit, in-
, scheduled eluding down
! Prior
to repay- payments payment of
,
I ment: 11.000% $ 8 .640.00
I During repay-
ment: 10.999% $ 960.96 $ 2,400.00 $ 3,360.96 $ 11 ,040.00
..'
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Buyer's payment schedule will be as follows:
Number of Pa ments Amount of Pa ments
When Pa ments Are Due
25 22.00
monthly commencing April 1, 1985,
and continuing until May 1, 1987
or such time as Student is no long-
er enrolled at Dickinson (or in an
approved full-time off-campus pro-
gram of studies). whichever is
earlier.
72 45.68
monthly commencing June 1, 1987
or such time as Student is no longer
enrolled at Dickinson (or in an
approved full-time off-campus program
of studies), whichever is earlier.
Late charge: 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.
Prepayment: 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.
III. ITEMIZATION OF AMOUNT FINANCED
1.
Cash price of Goods and Services:
$11.040.00
8,640.00
2,400.00
.00
$ 2,400.00
2.
Total down payment:
3.
Unpaid balance of cash price (1 - 2):
4.
Amount paid to others on Buyer's behalf:
5.
Amount Financed (3 + 4):
-2-
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IV. CREDIT INSURANCE
Credit life insurance for the term of this Contract is not required.
V. NO WARRANTIES
THER~ 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 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 are due on or
before the same date of each month as the first payment date. Payments must
be made to Industrial Valley Bank at the following 'address:
Industrial Valley Bank
P.O. Box 433
Upper Darby, Pennsylvania 19082
2. Buyer's legal rights include the right to pay all or part of the amounts
due on this Contract in advance of their due dates, to obtain a refund or credit
of ul!earned 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 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 in-
volving 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'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 as provided in the notice, Seller's rights shall include the
right to declare all sums due on the Contract to be immediately due and payable.
-3-
.' .
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r
c.
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 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 rights and remedies.
7. If any part of this 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 otherwise remain fully effective.
8. The laws of the Commonwealth of Pennsylvania shall apply to this Con-
tract except to the extent supplemented, superseded or pre-empted by federal
law.
9. This Contract shall be binding upon the parties hereto, their heirs,
successors, assigns and legal representatives.
10. TIME IS OF THE ESSENCE OF THIS CONTRACT.
NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS
AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR
SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY
HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER.
NOTICE TO BUYER: (1) DO NOT SIGN THIS AGREEMENT BEFORE YOU READ IT OR IF IT
CONTAINS ANY BLANK SPACE. (2) YOU ARE ENTITLED TO A COMPLETELY 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
CONTRACT AND INTEND(S) TO BE L GA
COpy OF THIS
ITS TERMS.
BUYER(S) :
DATE:
DICKINSON COLLEGE
2 !.s./I, s:-
f .
~~Jj 'JiL
By
-4-
c
f
OCT ~ 3 1m
DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - 2500 PLAN
EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT
Date Augus t 1, 1985
I. Seller: Dickinson College, Carlisle, Pennsylvania 17013
Buyer (s): Lester and Barbara Poris
11329 Little Patuxent Pkwy., Columbia, HD 21044
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 Ellen
(hereinafter "Student") during his/her enrollment at Dickinson College during
the 1985-86 academic year, including tuition, room and board,
books and supplies as herein stated (hereinafter the "Goods and Services").
The Goods and Services shall include only the following:
Tuition and room and board
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUAL FINANCE AMOUNT FINANCED: TOTAL OF TOTAL SALE
PERCENTAGE CHARGE: Amount of credit PAYMENTS: PRICE:
RATE: Dollar Amount provided by Amount paid Total cost of
Cost of credit credit will Dickinson College by Buyer as purchase on
as yearly rate cost Buyer total of all credit, in-
scheduled cluding down
Prior to re&ay- payments pa~ment of
ment: 11.0 0 % $ ,630.00
During repa?t 1,459.16
ment: 10.9 6 % $ $ 2,500.00 $_3,959.16 $ 12,130.00
('
~
\....
:
Buyer's payment schedule will be as follows:
Number of Pa ments Amount of Pa ments
When Pa ments Are Due
20 22.92
monthly commencing October 1, 1985,
and continuing until Hay L, L967
or such time as Student is no long-
er enrolled at Dickinson (or in an
approved full-time off-campus pro-
gram of studies), whichever is
earlier.
72 47.58
monthly commencing June I, 1987
or such time as Student is no longer
enrolled at Dickinson (or in an
approved full-time off-campus program
of studies) " whichever is earlier.
Late charge: 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.
Prepayment: 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. Payments greater than the payoff
amount but less than $3.00 will not be refunded.
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.
III. ITEMIZATION OF AMOUNT FINANCED
1. Cash price of Goods and Services: $ 12,130.00
2. Total down payment: 9,630.00
3. Unpaid balance of cash price (1 - 2): 2,500.00
4. Amount paid to others on Buyer's behalf: .00
5. Amount Financed (3 + 4): $ 2,500.00
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IV. CREDIT INSURANCE
Credit life insurance for the term of this Contract is not required.
V. NO WARRANTIES
THERE ARE NO W~IES. 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 WRITIEN 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 are due on or
before the same date of each month as the first payment date. Payments must
be made to Industrial Valley Bank at the following address:
Industrial Valley Bank
P.O. Box 433
Upper Darby, Pennsylvania 19082
2. Buyer's legal rights include the right to pay all or part of the amounts
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 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 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 in-
volving 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'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 as provided in the notice, Seller's rights shall include the
right to declare all sums due on the Contract to be immediately due and payable.
-3-
USTED DEI3E LLEVAR ESTE DOCUMENTO A SU MlODAOO IMMEDIATAMENTE. SI
USTED NO TIENE UN ABOOADO 0 NO PUEDE PAGARLE A UNO, LLAME 0 VAYA A LA
SIGUIENTE OFICINA PARA A VERIOUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL.
CUII/ber/alll/ Coullty Bar ASSllc;atioll
2 Liberty A,'elllle
Car/isle, PA 17013-3387
Telep/lOlIe: (717) 249-3/66
MCNdE~',W~LL, ACE & N~!~K
ro.. \ '--...... "
By '" ",-__ '\.,~,,~
F: Stephenson Matthes
Attorney I.D, No.67408
100 Pine Street
P. O. Box 1166
Harrisburg, P A 17108-1166
(717) 232-8000
Atlol'l1eys for Plaintiff
Dickinson College
11. Scction VI, Pam graph 4 ofthc Contract(s) provides that if an Event of Dcfault ofthc
contract occurs, and is not clll'ed by thc l3uycr pursuant to the Notice of Default, Dickinson has "thc right
to dcclare all SlltllS duc on the contract to be immediatcly duc and payable."
12. Lestcr H. Paris, Parent has dcfaulted on the Contract(s) by failing to makc the requircd
monthly payments on the Contract(s) due and owing to Dickinson sincc September 12, 1994.
13. Notices werc forward cd to Parent informing him of his dcfault and right to curc such
dcfault.
14. Parent has failcd to curc such defaults.
15. Therefore Dickinson has cxcrcised its right to declare all sums duc on the Contract(s) to
be immediately due and payable.
16. The total amount which has becomc immediatcly due and payable to Dickinson by
Parent, Lester H. Poris plll'suant to the Contract(s) is Six Thousand Two Hundred Ninety Eight Dollars
and Sixty-two Cents ($6,298,62), which includes principal in the amount of Fivc Thousand Nine Dollars
and Seventy-eight Cents ($5,009.78), interest in the amount of One Thousand One Hundred Fifty Eight
Dollars and Two Cents ($1,158.02), late fces in the amount of One Hundred Thirty Dollars and Eighty-
two Cents ($130.02), plus reasonable attorney's fees and collection costs.
WHEREFORE, Plaintiff Dickinson College demands judgment against Parent Lcster H. Poris in
the sum of Six Thousand Two Hundred Ninety Eight Dollars and Sixty-two Cents ($6,298.62), plus
interest at the ratc indicated on the individual Contract(s), late fces, costs of suit, attorneys' fees and
collection costs.
23. Notices wcrc forwardcd to Parcnt informing her ofhcr default and right to curc such
dcfault.
24. Parcnt has failed to cure such defaults.
25. Thereforc Dickinson has cxcrciscd its right to declarc all silins due on thc Contract(s) to
26. Thc total amount which has beeomc immcdiately due and payable to Dickinson by
,
,I
,!
i
,
bc immediately duc and payable.
COUNT III
DICKINSON COLLEGE V. ELLEN PORIS
IN OUANTUM MER VlT
Parcnt, Barbara Poris pursuant to thc Contraet(s) is Five Thousand Six Hundrcd Threc Dollars and
Eighty-two Ccnts ($5,603.82), which includes principal in thc amount of Two Thousand Fivc Hundred
Dollars ($2,500.00), intcrcst in the amount of Two Thousand Nine Hundred Seventy Thrce Dollars
($2,973.00), latc fecs in thc amount ofOnc Hundred Thirty Dollars and Eighty-two Cents ($130.82), plus
reasonable attorncy's fees and collcction costs.
WHEREFORE, Plaintiff Dickinson Collegc demands judgment against Parent Barbara Poris in
the sum of Five Thousand Six Hundred Thrce Dollars and Eighty-two Cents ($5,603,82), plus interest at
the ratc indicated on thc individual Contract(s),late fecs, costs of suit, attorneys' fees and collection
costs.
f
r
In the alternative, if this Honorable Court should dctermine that an express contract between
Dickinson and Student does not exist, which is denied, Dickinson pleads the following Court In Quantum
Meruit,
f
.
, 't,
(
r
'.
DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - 2500 P~~
EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT
Date March 1, 1985
I. Seller: Dickinson College, Carlisle, Pennsylvania 17013
Buyer (s): Lester Poris
11329 Little Patuxent Pkwy., Columbia, MD 21044
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 Ellen
(hereinafter "Student") during his/her enrollment at Dickinson College during
the 1984-85 academic year, including tuition, room and board,
books and supplies as herein stated (hereinafter the "Goods and Services").
The Goods and Services shall include only the following: Tui tion and
room and board.
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUAL FINANCE AMOU1lT FINANCED: TOTAL OF TOTAL SALE
PERCENTAGE CHARGE: Amount of credit PAYMENTS: PRICE:
RATE: Dollar Amount provided by Amount paid Total cost of
Cost of credit credit will Dickinson College by Buyer as purchase on
as yearly rate cost Buyer total of all credit, in-
scheduled cluding down
Prior to repay- payments payment of
ment: 11.000% $ 8.640.00
,During repay-
ment: 10.999% $ 960.96 $ 2,400.00 $3,360.96 $ 11,040.00
'.
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r
IV. CREDIT INSURANCE
Credit life insurance for the term of this Contract is 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 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 are due on or
before the same date of each month as the first payment date. Payments must
be made to Industrial Valley Bank at the following 'address:
Industrial Valley Bank
P.O. Box 433
Upper Darby, Pennsylvania 19082
2. Buyer's legal rights include the right to pay all or part of the amounts
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 reinstate the Contract if Buyer timely cures any
default.
3. Buyer shall be deemed to have cormnitted 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 in-
volving 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'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 as provided in the notice, Seller's rights shall include the
right to declare all sums due on the Contract to be immediately due and payable.
-3-
(
f
OCT 2. 3 93S
DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - 2500 PLAN
EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT
Date AURuS t I, 1985
I. Seller: Dickinson College, Carlisle, Pennsylvania 17013
Buyer (5) :
Lester and Barbara Poris
11329 Little Patuxent Pkwy., Columbia, ND 21044
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 Ellen
(hereinafter "Student") during his/her enrollment at Dickinson College during
the 1985-86 academic year, including tuition, room and board,
books and supplies as herein stated (hereinafter the "Goods and Services").
The Goods and Services shall include only the following:
Tuition and room and board
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUAL FINANCE AMOUNT FINANCED: TOTAL OF TOTAL SALE
PERCENTAGE CHARGE: Amount of credit PAYMENTS: PRICE:
RATE: Dollar Amount provided by Arnoun t paid Total cost of
Cost of credit credit will Dickinson College by Buyer as purchase on
as yearly rate cost Buyer total of all credit, in-
scheduled eluding down
Prior to recliay- payments pa~ment of
ment: 11.00% $ ,630.00
During repa?;- 1,459.16 2,500.00
ment: 10.9 6 % $ $ $ 3,959.16 $ 12,130.00
("
r.
\".
Buyer's payment schedule will be as follows:
Number of Pa ments Amount of Pa ents
When Pa ments Are Due
20
22.92
monthly commencing October I, 1985,
and continuing until Hay 1, 19t11
or such time as Student is no long-
er enrolled at Dickinson (or in an
approved full-time off-campus pro-
gram of studies), whichever is
earlier.
72
47.58
monthly commencing June I, 1987
or such time as Student is no longer
enrolled at Dickinson (or in an
approved full-time off-campus program
of studies),. whichever is earlier.
Late charge: If a payment is more than 15 days late, a sum equivalent to 57-
of the late payment (but no more than $2.50 and not less than
$1.00) may be charged.
Prepayment: 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. Payments greater than the payoff
amount but less than $3.00 will not be refunded.
SEE SECTION VI OF THE CONTRACT BELOW FOR ANY ADDITIONAL INFORMATION ABOUT NON-
PAYMENT, DEFAULT AND REQUIRED REPAYMENT BEFORE THE SCHEDULED DATE FOR REPAYMEN1:
OF THE AMOUNT FINANCED.
III. ITEMIZATION OF AMOUNT FINANCED
1. Cash price of Goods and Services: $ 12,130.00
2. Total down payment: 9,630.00
3. Unpaid balance of cash price (1 - 2): 2,500.00
4. Amount paid to others on Buyer's behalf: .00
5. Amount Financed (3 + 4): $ 2,500.00
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c
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IV. CREDIT INSURANCE
Credit life insurance for the term of this Contract is 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 lIAS 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 are due on or
before the same date of each month as the first payment date. Payments must
be made to Industrial Valley Bank at the following address:
Industrial Valley Bank
P.O. Box 433
Upper Darby, Pennsylvania 19082
2. Buyer's legal rights include the right to pay all or part of the amounts
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 reinstate the Contract if Buyer timely cures any
default.
3. Buyer shall be deemed to have cOllllIlitted 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 in-
volving 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'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 as provided in the notice, Seller's rights shall include the
right to declare all sums due on the Contract to be immediately due and payable.
-3-
.
c
c
5. Waiver by Seller of any event of default shall not be binding upon
Seller if Seller should thereafter choose to excrcise 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 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 rights and remedies.
7. If any part of this 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 otherwise remain fully effective.
8. The laws of the Commonwealth of Pennsylvania shall apply to this Con-
tract except to the extent supplemented. superseded or pre-empted by federal
law.
9. This Contract shall be binding upon the parties hereto. their heirs.
successors, assigns and legal representatives.
10. TIME IS OF THE ESSENCE OF THIS CONTRACT.
NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS
AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR
SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY
HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER.
NOTICE TO BUYER: (1) DO NOT SIGN THIS AGREEMENT BEFORE YOU READ IT OR IF IT
CONTAINS ANY BLANK SPACE. (2) YOU ARE ENTITLED TO A COMPLETELY FILLED-IN COPY
OF THIS AGREEMENT. '(3)' UNDER THE LAW. YOU HAVE THE, RIGHT TO PAY OFF IN ADVANCE
TRE FULL AMOUNT DUE AND UNDER CERTAIN CONDITIONS TO OBTAIN A PARTIAL REFUND
OF THE FINANCE CHARGE.
BUYER(S) ACKNOWLEDGE (S) RECEIVING A ~OMPLETED COPY OF THIS
CONTRACT AND INTEND(S) TO BE ,~EGALL BjUND BY ITS TERMS.
BU'lER (S): ~'U- ~J.f..1..;
~ \'.
I. '.,-)
~ ,;_1..J.1~ \ ~..~
DATE:
DICKINSON COLLEGE
IV 1-] I~S'
By /~~J:J Y;i'.
-4-
DICKINSON COLLEGE,
PllIintilT
: IN TIlE COUf('/' OF COMMON PI.EAS
: CUMBERLAND COUNTY. PENNSYI.V ANIA
v.
CIVIL ACTION -I.A W
LESTER II. PORIS and
BARBARA PORIS, h/wand
ELLEN PORIS,
DcJcndilllls
NO. 98-4186
PRAECII'E
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Counsclmovcs thc Court to rcinstatc thc Complaint in thc above-captioned mattcr which was
filcd on or about July 22, 1998, to bc ablc to obtain servicc ofthc Complaint upon Lcstcr H. I'oris and
Barbara Poris, h/w, Dcfcndants.
By
'. Stcphenson Malt les
Attorncy I.D. No.67408
100 Pinc Strcet
P. O.l3ox 1166
Harrisburg, P A 17108-1166
(717) 232-8000
Attorneys for Plaintiff
Dickinson Collegc