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Home My WebLink About03-2327F:\FILES~DATAFILEXDickinson College 7619~DickinsonCollegeCollections7619C~Documents\166.coml/cny Created: 4/24/03 10:49:05 AM Revised: 5/14/03 2:52:37 PM 7619C. 166 DICKINSON COLLEGE, Plaintiff Vo MEGHAN LILJEDAHL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 MARTSON DEARD~RE~~IAMS David R. Galloway, Esquire I~ eDn' ENa sU?Hb:;hS;¢z2e~t Carlisle, PA 17013 (717) 243-3341 & OTTO Dated: May 14, 2003 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff Vo MEGHAN LILJEDAHL, Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION-LAW · JURY TRIAL OF TWELVE DEMANDED COMPLAINT 1. PlaintiffDickinson College ("Dickinson") is a Pennsylvania educational institution with its principal offices located in Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant Meghan Liljedahl ("Defendant") is an adult individual whose last known address is 706 Blacksmith, Hartford County, Windsor, Connecticut 06095. below. COUNT I DICKINSON COLLEGE V. MEGHAN LILJEDAHL BREACH OF CONTRACT Paragraphs 1 through 2 are incorporated herein by reference as if set forth in full 4. Defendant opened a Student Receivables Account ("Account") with Plaintiff to pay tuition, dining service fees and other educational expenses provided and rendered to Defendant by Plaintiff. A true and correct copy of that Account is incorporated by reference and attached as Exhibit "A." 5. Defendant, by opening the Account and using the goods and services provided by Plaintiff, agreed to pay Plaintiff for all charges made to the Account. 6. Defendant received and accepted all goods and services provided by Plaintiff and thereby agreed to payment for said goods and services. 7. The terms of repayment required Defendant to pay all balances 14 (fourteen) days before the beginning of each semester. 8. Defendant defaulted on the repayment of the Account by not paying the balance when due. such default. 10. 11. Notices were forwarded to Defendant informing her of her default and right to cure Defendant failed to cure such defaults. The total amount which is immediately due and payable to Plaintiff by Defendant on the Account is Three Thousand One Hundred Dollars and Eighty-Three Cents ($3,100.83). WHEREFORE, Plaintiff Dickinson College demands judgment against Defendant Meghan Liljedahl in the sum of Three Thousand One Hundred Dollars and Eight-Three Cents ($3,100.83), plus late fees, costs of suit, attorneys' fees and collection costs, and interest fi.om date of judgment. COUNT II DICKINSON COLLEGE V. MEGHAN LILJEDAHL IN QUANTUM MER UIT In the alternative, if this Honorable Court should determine that an express contract between Dickinson and Meghan Liljedahl does not exist, which is denied, Dickinson pleads the following: 12. Paragraphs 1 through 11 are incorporated herein by reference as if set forth in full. 13. Because Plaintiff loaned money to Defendant, to the benefit of Defendant, Defendant became liable to Plaintiff for said money. 14. Defendant was unjustly enriched by accepting said money without paying Plaintiff reasonable compensation therefor. 15. The total amount by which Defendant has become enriched is Three Thousand One Hundred Dollars and Eighty-Three Cents ($3,100.83). 16. Plaintiff demanded payment of the above sums but Defendant failed and refused to do so. WHEREFORE, Plaintiff Dickinson College demands judgment against Defendant Meghan Liljedahl in the sum of Three Thousand One Hundred Dollars and Eighty-Three Cents ($3,100.83), until Meghan Liljedahl's obligation is paid in full, plus late fees, costs of suit, attorneys' fees and collection costs, and interest from date of judgment. Date: May 14, 2003 ~~c~ ~3i~s ~ o~o avid R. Galloway, Esquird''~ I. D. Number 87326 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Exhibit A ~0 t~ to to ~o o o o o ~ o o o ~ o 0 0 ~o 0 ~ U fl) 0 (1' o o o ~ o o o EXHIBIT "A" VERIFICATION The foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the .document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document 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. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Thomas B. Meyer F:\FILES\DATAFILE\Dickinson College 7619\DickinsonCollegeCollection~7619C\Documents\166.coml DICKINSON COLLEGE, Plaintiff MEGHAN LILJEDAHL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2327 CWIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED STIPULATION AND AGREEMENT FOR ENTRY OF JUDGMENT AND NOW, comes Plaintiff, DICKINSON COLLEGE, by and through its attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and Defendant Meghan Liljedahl who stipulate and agree as follows: 1. Pa. R.C.P. 1037 (c) provides that in all cases, the Court, on motion ora party, may enter an appropriate judgment against a party upon admission. 2. Defendant agrees and admits that Judgment should be entered against her in fav°r °f Plaintiffin the amount of $3,100.83, plus costs of suit and interest accruing at 6% per annum from Meghan Lilj edahlt 706 Blacksmith Windsor, CT 06095 date of judgment. 3. The parties agree that the Court, upon motion of Plaintiff, may enter Judgment pursuant to this Stipulation without issuance of a Rule to Show Cause, and without further proceedings or notice. By~.~~~_ (717) 243-3341 Defendant Date: Q ~' 1~ ~ 0'~ Attorney for Plaintiff Date: DICKINSON COLLEGE, Plaintiff MEGHAN LILJEDAHL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2327 CIViL ACTIOiN-LAW JURY TRIAL OF TWELVE DEMANDED ACCEPTANCE OF SERVICE I, Meghan Liljedahl, accept service of the Complaint. Dated: 7~ I(~ 2003 Megh~ Lfljedahl ' CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Acceptance of Service was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Meghan Liljedahl 706 Blacksmith Windsor, CT 06095 MARTSON DEARDORFF WILLIAMS & OTTO By ~/~/~' C/~ /~/~ Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: July 25, 2003 DICKINSON COLLEGE, Plaintiff MEGHAN LILJEDAHL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2327 CIVIL ACTION-LAW jURY TRIAL OF TWELVE DEMANDED STIPULATION AND AGREEMENT FOR ENTRY OF JUDGMENT Meghan Lilj edahY 706 Blacksmith Windsor, CT 06095 AND NOW, comes Plaintiff, DICKINSON COLLEGE, by and through its attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and Defendant Meghan Liljedahl who stipulate and agree as follows: 1. Pa. R.C.P. 1037 (c) provides that in all cases, the Court, on motion of a party, may enter an appropriate judgment against a party upon admission. 2. Defendant agrees and admits that Judgment should be entered against her in favor of Plaintiffin the amount of$3,100.83, plus costs of suit and interest accruing at 6% per annum from date of judgment. 3. The parties agree that the Court, upon motion of Plaintiff, may enter Judgment pursuant to this Stipulation without issuance of a Rule to Show Cause, and without further proceedings or notice. Martson Deardorff Willia~(s & {~to Carlisle, PA 17013-3093 (717) 243-3341 Defendant Date: "7 Attorney for Plaintiff Date: 7 '~,~ ~"-0_~ DICKINSON COLLEGE, Plaintiff MEGHAN LILJEDAHL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2327 CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED ORDER OF COURT [~ , 0 upo c n~dr AND NOW, this 2~_ day of ,/~'~ [ ~ 2 03, n o s' eation of the attached Stipulation, judgment is hereby entered in favor of Plaintiff, Dickinson College, against Defendant, Meghan Liljedahl, in the amount of $3,100.83 plus costs of suit with interest accruing at 6% per annum from date of judgment. Prothonotary is directed to enter and index this judgment accordingly. BY THE COURT, ~a Plaintiff: vid R. Galloway, Esquire Ten East High Street Carlisle, PA 17013 for Defendant: ~tleghan Liljedahl 706 Blacksmith Windsor, CT 06095 07' 0- DICKINSON COLLEGE, Plaintiff MEGHAN LILJEDAHL, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2327 CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED _PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark the judgment in the above-captioned case satisfied and issue a certificate reflecting the same. Date: July 22, 2004 MARTSON DEAR~D~)RFF WILLIAMS & OTTO BY-David R. Galloway~squire I I.D. Number 873:!6 ~ Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, 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. Meghan Liljedahl 706 Blacksmith Windsor, CT 06095 MARTSON DEARDORFF WiLLIAMS & OTTO TriLia D. Eckenroad I Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: July 22, 2004