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Home My WebLink About03-2920DICKINSON COLLEGE, Plaintiff QUAS A. GANDOLFO, 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 thc 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 thc 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 fights 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 I.D. Number 87326 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff & OTTO DICKINSON COLLEGE, Plaintiff V. QUAS A. GANDOLFO, Defendant IN THE COURT OF COMMON PLEAS OF CU ERL , COUNTY, P ,rNSYLV , NO. 03- 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 Quas A. Gandolfo is an adult individual with a last known address of 1333 Shore Road, Atlantic County, Linwood, NJ 08221-2345. 3. On or about March 14, 1978, Defendant entered into a PromissoryNote - 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 $800.00, plus interest and costs by Defendant on his own behalf, for educational services and benefits at Plaintiff's institution. 5. On or about April 19, 1979, 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 6. Note #2 provided for the financing orS 1,200.00, plus interest and costs by Defendant on his own behalf, for educational services and benefits at Plaimiff's institution. 7. On or about April 24, 1980, Defendant entered into an additional Promissory Note - Federal Perkins Loan Program (Note #3) with Plaintiff. A copy of Note #3 is attached hereto as Exhibit 8. Note #3 provided for the financing of $1,200.00 plus interest and costs by Defendant on his own behalf for educational services and benefits at Plaintiff's institution. 9. On or about October 21, 1980, Defendant entered into an additional Promissory Note - Federal Perkins Loan Program (Note//4) with Plaintiff. A copy of Note//4 is attached hereto as Exhibit Exhiibit A Exhibit "A" DEFAULT Exhibit "B" Exhibit C i F ' ~J':J 9 DEFERMi~T Exhibit "C" Exhibit 3 5 6 Exhibit "D" 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 tree and correct and to the best of my knowledge, information and beliefi 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 unswom falsification to authorities, which provides that ifI knowingly make false averments, I may be subject to criminal penalties. Dickinson College Thom~ Mey~~~ ~ Assistant Treasurer of Dickinson College Dated: DICKINSON COLLEGE, Plaintiff QUAS A. GANDOLFO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2920 CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED pRAECIPE TO DOCUMENT SERVICE AND COST OF SERVICE -PURSUANT TO THE PENNSYLVANIA LONG ARM STATUTE I hereby certify that a copy of the Complaint was mailed to Quas A. Gandolfo on June 20, 2003, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed and dated July 17, 2003, and a copy of the receipt showing the cost of service was $8.61. Ten East High Street Carlisle, PA 17013-3093 (717) 243-3347L Date: July 28, 2003 Attorneys for Plaintiff · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. A~lcle Addressed to: 2, N~icle Number 7001 2510 ] Addre~ Date of Dellv~y O. is belive~y address ,Siffem~t fT~m item 1 ? F1 Yes if YES, enter delivery address below: i'9 No 0006 5862 9541 Postage Certified Fee Return Receipt Fee (Endomement Required) Restricted Delivery Fee (Endomement Required) 0?/22/2003 11:41 ?1724359~0 POSTOFFIGE PAGE 01 07/22/2003 11:41 7172435998 POSTOFFICE P~GE 02 CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent of 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: Mr. Quas A. Gandolfo 1333 Shore Road Linwood, NJ 08221-2345 MARTSON DE./LRDORFF WILLIAMS & OTTO Nichole L. Myers Ten East High Street Carlisle, PA ! 7013 (717) 243-3341 Dated: July 28, 2003 DICKINSON COLLEGE, Plaintiff QUAS A. GANDOLFO, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2920 CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED PRAECIPE Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant Quas A. Gandolfo in the amount of $3,855.75, plus interest from May 7, 2003 in the amount of $29.61, collection and attorneys' fees in the amount of $705.00 for a total of $4,590.36 plus interest accruing at $0.21per day and costs of suit for Defendant's failure to file an answer to the Complaint. I do hereby certify that a written notice of intention to file this Praecipe (in the form attached hereto) was mailed to the Defendant at the address indicated thereon, on September 3, 2003, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. M~F~LIAMS & OTTO David R. Galloway, EsqU~ I. D. Number 87326 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Dated: September 25, 2003 DICKINSON COLLEGE, Plaintiff QUAS A. GANDOLFO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2920 CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED TO: Quas A. Gandoifo, Defendant NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on , the following Judgment was entered against you in the above-captioned case: In favor of Plaintiff and against Defendant Quas A. Gandolfo in the mount of $3,855.75, plus interest from May 7, 2003 in the amount of $29.61, collection and attorneys' fees in the amount of $705.00 for a total of $4,590.36 plus interest accruing at $0.21per day and costs &suit for Defendant's failure to file an answer to the Complaint. Date: Prothonotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Mr. Quas A. Gandolfo 1333 Shore Road Linwood, NJ 08221 ~2345 DICKINSON COLLEGE, Plaintiff V. QUAS A. GANDOLFO, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2920 CIVIL ACTION-LAW : JURY TRIAL OF TWELVE DEMANDED NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT YOU ARE 1N DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Date: September 2, 2003 M TSON OE 0 F wiLmus & OTTO C~lisle, PA 17013 (717) 243-3341 Attorneys for Pl~ntiff CERTIFICATE OF SERVICE I, Marti Iben, an authorized agent ofMartson DeardorffWilliams & Otto, hereby certify that a copy of the foregoing Notice of Intention to File Praeeipe for Entry of Default Judgment was served this date by depositing same in the Post Office at Carlisle, PA, Certified Mail/Restricted Delivery, postage prepaid, addressed as follows: Mr. Quas A. Gandolfo 1333 Shore Road Linwood, NJ 08221-2345 MARTSO ,I~ DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: September 2, 2003 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL Mf'}L, DQES NOT PROVIDE F~)R INSURANCE--POSTMASTER PS Form 3817, Mar. 1989 DICKINSON COLLEGE, Plaintiff QUAS A. GANDOLFO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2920 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. ~~F WILLIAMS & OTTO BYD~~u~ire~ I.D. Number 872;26 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff Date: CERTIFICATE OF SERVICE I, Ashlee N. Davis ,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: Benjamin Podolnick, Esquire LAW OFFICES OF BENJAMIN PODOLNICK 1001 Tilton Road, Suite 204 Northfield, NJ 08225 Kristina G. Murtha, Esquire GOLDBECK, MCCAFFERTY & MCKEEVER Suite 5000 Mellon Independence Center 701 Market Street Philadelphia, PA 19106 MARTSON DE,td~-DORFF WILLIAMS & OTTO Ashlee N. Davis Ten East High Street Carlisle, PA 17013 (717) 24:3-3341 Dated: September 17, 2004