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DICKINSON COLLEGE,
Plaintiff
V.
ANDRE D. BLACKNALL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ,0.3 - -3 14 3
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
Ry C
David R. Gallo y,1
I.D. Number 87326
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
WILLIAMS & OTTO
Date: 71,/03
DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 3 3 ( 3
CIVIL ACTION-LAW
ANDRE D. BLACKNALL,
Defendant 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 Andre D. Blacknall is an adult individual with a last known address of 172
Merline Avenue, Trenton, NJ 08648-3865.
3. On or about October 11, 1993, Defendant entered into a Promissory Note - Federal
Perkins Loan Program (Note #1) with Plaintiff. A copy ofNote #I is attached hereto as Exhibit "A."
4. Note # 1 provided for the financing of $2,000.00 plus interest and costs by Defendant
on his own behalf, for educational services and benefits at Plaintiff s institution.
5. On or about September 2, 1994, 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 $2,000.00 plus interest and costs by Defendant
on his 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 principal for Note #1 and Note #2 is $4,000.00.
10, Note #1 and Note #2 grant Plaintiff reasonable collection and attorney's fees which
Plaintiff has calculated to be $600.00.
11. As of May 28, 2003, the principal and interest due and payable by Defendant to
Plaintiff was $4,166.13, plus interest accruing thereafter at $.49 per day.
12. The outstanding balance of $4,166.13 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.
13. Plaintiff has fulfilled, performed and complied with all obligations and conditions of
Note #1 and Note #2.
COUNTI
BREACH OF CONTRACT
14. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 13 of this Complaint.
15. Defendant breached the expressed and implied obligations, conditions and terms of
agreement of Note #1 and Note #2 by failing to pay the amounts financed therein.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $4,166.13,
plus interest accruing at $.49 per day from May 28, 2003, collection and attorneys' fees in the
amount of 600.00 and costs of suit.
COUNT II
IN OUANTUMMERUIT
16. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 15 of this Complaint.
17. Having requested Plaintiff to loan money, and doing so to the benefit of Defendant,
Defendant became liable to Plaintiff for said money.
18. Defendant has been unjustly enriched by accepting said money without paying
Plaintiff reasonable compensation therefor.
19. The total amount by which Defendant has become enriched is $4,166.13, plus interest
accruing at $.49 per day from May 28, 2003.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $4,166.13,
plus interest accruing at $.49 per day from May 28, 2003, collection and attorneys' fees in the
amount of $600.00 and costs of suit.
Date:
MARTSON DEARDOITMILLIAMS & OTTO
David R. Galloway
I.D. Number 87326
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Plaintiff
Exhibit A
PERKINS (NDSL) TRUTH-IN-LENDING STATEMENT
DICKINSON COLLEGE
a
0
Account Number 00273-000-00-1738-09
Name of Borrower Andre D. Blacknall
Address 315 Avon Drive
Carlisle PA 17013
ANNUAL PERCENTAGE
RATE
The cost of your
credit as a yearly
rate.
Prior to During
repayment repayment
0 % 5 % $ 2,000.00
Itemization of the Amount Financed: $ 2.000.00 Amount given directly to you
Late Charge: If a payment is late, you may be charged: $1.00 for the first
late payment, and $2.00 for each subsequent late payment if
this loan is payable monthly, $3.00 for each late payment if
this loan is payable bimonthly, $6.00 for each late payment
if this loan is payable quarterly.
Prepayment: If you pay off early, you will not have to pay a penalty.
See your promissory note for any additional information about nonpayment, de-
fault, any required repayment in full before the scheduled date, and pre-
payment.
THE BORROWER ACKNOWLEDGES RECEIPT OF AN EXACT COPY OF THIS STATEMENT.
STUDENT ;??nn /J INSTITUTIONAL
BORROWER,j? may/„d',u" Q? REPRESENTATIVE I?CJI?L?e ¢
DATE //I/6//43 DATE 16111153
AMOUNT FINANCED
The amount of
credit provided
to you.
EXHIBIT "A"
-09
Promissory Note-Federal Perkins Loan Program
[Any bracketed clause or paragraph may be included at option of institution.]
I, Andre 0. Rlarknlisle, 1l promise to pay to Dickinson Colleqe (hereinafter called the
Institution), located at dr PA 17013-2896 , the sum of 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, necessary for
the collection of any amount not paid when due.
I further understand and agree that.
I. Gene
(1) Applicable Law. All sums advanced under this note are drawn from a fund created under Part E of Title IV of the Higher Education Act
of 1965, as amended (hereinafter called the Act), and are subject to the Act and the Federal regulations issued 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.
C2) Procedures for Receivin¢ Deferment, Cancellation, or Forbearance. 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 Institution 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 file my request on time.
It. Interest
Interest shall accrue from the beginning of the repayment period and shall be at the ANNUAL PERCENTAGE RATE OF FIVE PERCENT
(5%) on the unpaid balance, except that no interest shall accrue during any deferment period described in Article VII.
III. Repayment
(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 least a half-time regular student at an institution of higher education, or at a comparable institution outside. the United States
approved for this purpose by the United States Secretary of Education (hereinafter called the Secretary), and ending ten (10) years later, unless
that period is [shortened under paragraph M(5), or] extended under paragraphs M(4), III(7) (extensions), VII(I), or VII(3) (deferments).
(2) Upon my written request, the repayment period may start on a date earlier than the one indicated in paragraph M(l).
(3)(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 Institution 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 III(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 III(1), 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 (10) years and may adjust any repayment schedule to reflect my income.
[(5)(A) If the monthly rate that would be established under paragraph III(1), or the total monthly repayment rate of principal and interest on
all my Federal Perkins Loans, including this loan, is less than $40.00 per month, I shall repay the principal and interest on
this loan at the rate of $40.00 per month (which includes both principal and interest).
(5)(B) If I have received Federal Perkins Loans from other institutions and the total monthly repayment rate on those loans is lea than
$40.00 the $40.00 monthly payment established under subparagraph III(5)(A) includes the amounts I owe
on all my outstanding Federal Perkins 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 $40.00 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 $40.00 - 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 III(1).]
C7) The Institution may, upon my written request, reduce any scheduled repayments or extend the repayment period indicated in paragraph
M(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.
M Prepayment
(1) I may, at my option and without penalty, prepay all or any part 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. efault
(1) 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, DC, X, XI, XII, XIII, or XIV of this agreement.
(2) I understand that the Institution may disclose to credit bureau organimtions the amount of loans made to me, along with other relevant
Page 1 of 4 Federal Perkins/July 1993
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 the 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.
(5) I understand that, if I default on my loan, I will lose my right to forbearance.
(6) 1 understand that, if I default on my loan, I will lose my right to defer repayments.
(1) 1 understand that, if the Institution accelerates the loan under paragraph V(1), I will lose my right to receive a cancellation of a portion of
my loan for any service described in Articles VIH, DC, X, XI, X11, XIII, or XIV performed after the date the Institution accelerated the loan.
(8) 1 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) 1 understand that, upon making a properly documented written request to the Institution, I am entitled to be granted forbearance of
principal and interest or principal only, renewable at 12-mouth 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 as 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 grant) 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, Dr, X, Xr, X11, X111, 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 nay reason 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 (V11)(1)(A) while I am'serving in a medical internship or residency
program.
(3) 1 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 the expiration of any deferment provided in paragraph VII(I).
VIII. Teachine 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 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 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 1 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 concentration of students from low-income families. An official Directory of designated
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 676(b)(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 I perform qualifying service after the period for which I received the loan 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 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. Military Cancellation
(1) I understand that, upon making a properly 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 310 of Title 37 of the United States Code.
(2) This loan will be canceled at the rate of 12 112 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 I received the loan.
XI. Volunteer Service Cancellation
(1) 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 I 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 Enforcement or Corrections Officer 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 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.
XIII. Nurse or Medical Technician 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 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 Agency 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 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 servicq; 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.
XVI. Change in Name. Address, Telephone Number. or Social Security Number
I am responsible for informing the Institution of any change or changes in name, address, telephone number, or Social Security number.
Page 3 of 4 Federal Perkins/July 1993
XVII, Late Charea
(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 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) No charge may exceed 20 percent of my monthly, bimonthly, or quarterly payment.
(3)(A) The 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 after 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 date of the
next installment.
XVM. Assienment
(1) This note may be assigned by the Institution 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 I could assert against the Institution that made this loan; my recovery is
limited to the amount I repaid on this loan.
XIX Prior Loans
I hereby certify that I have listed below all of the Federal Perkins Loans I have obtained at other institutions. (If no prior loans have been
received, state "Noce.')
FEDERAL PERKINS LOANS AT OTHER INSTITUTIONS
Amount
Date
Institution
XX. Schedule of Advances
The following amounts were advanced to me under this loan agreement on the dates indicated:
Amount Date Signature of Borrower
1 $1,000.00 8/11/93 /.u?, ?t?/yy' ylf?a?.li?--/?
2 $1.000.00 1/12/94 All" ?O.QN?r?Pf
3
NOTICE TO BORROWER: DO NOT SIGN THIS NOTE BEFORE YOU READ IT.
I UNDERSTAND AND AGREE TO ALL OF THE FOREGOING TERMS AND CONDITIONS.
[This note is signed as a sealed instrument.]
Signature GAO f Ar(seal)]
Date /%/f3 19
Permanent Address (Street or Box Number, City, State, and Zip Code)
P?. 'SA- "A
Social Security Number (borrower must provide) /g/.17
The borrower and Institution 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 Perkins/July 1993
Dickinson College
Perkins Pre-Loan information sheet
PLEASE PRINT
Name: No&rP. t?iQf `(11iu (l Date At o
College Address: r
HUB # 1f39 Telephone Number Z.vO-3365
Street ('incl. Apt. No.) Ipti_!ul Srn r9aliQ.
Permanent Address:
Street (incl. Apt. No.) AVon.-Dr.Oztrlisle-
City, state and Zip Code '•> no o
Telephone Number 2W-"2Pl5_9
7 3 ?;Zf 381
Exp. Graduation Date 5. 71
Social Security No/yZ-?2
Drivers License No ?9SId
Birthdate J'1,9• j7j
State ?A .
Parent or Guardian:
Name: AJ rD 1 U)AC k1.A I /
Street (incl. Apt. No.) ?kpe_
City, State and Zip Code ?Q4?f.t,Ckli%l f_ ?/. c'???q??
Telephone Number h'00 ?1?e^02 3.?
+ ,?{{ J
Parent or Guardian Employer's Name /,??/?{
Employer's Address:
Three references: (Individuals who will always know your address)
Name: l)Od kf .
Street (incl. Apt. No.)
City, State and Zip Code
Telephone Number Cn,9,}7 ys/•-7?jr. q
Name : /_?G ?O l ?? C?k ttX
Street (incl. Apt. No.) Lcturp»['?!,'h?e•
City, State and Zip Code ?gUre NC?. ??P
Telephone Number?aiS ?`lj -CL?Z
• D?5 ?vs?
Street (incl. Apt. No.) ? ? ? .+T19?1:?1ar1 y1'i'l/e ?
Name: ?<.i, f, C_.C !v[ 'lG 4 !!?!r ?
City, State ahd Zip Code
Telephone Number ?j//i G
Exhibit B
PERKINS (NDSL) TRUTH-IN-LENDING STATEMENT
DICKINSON COLLEGE
a
O
V
Account Number 00273-000-00-1738-09
Name of Borrower Andre D. Blacknall
Address 315 Avon Drive
Carlisle, PA 17013
ANNUAL PERCENTAGE
RATE
The cost of your
credit as a yearly
rate.
Prior to During
repayment repayment
0 % 5 2 $ 2,000.00
Itemization of the Amount Financed: $ 2.000.00 Amount given directly to you
Late Charge: If a payment is late, you may be charged: $1.00 for the first
late payment, and $2.00 for each subsequent late payment if
this loan is payable monthly, $3.00 for each late payment if
this loan is payable bimonthly, $6.00 for each late payment
if this loan is payable quarterly.
Prepayment: If you pay off early, you will not have to pay a penalty.
See your promissory note for any additional information about nonpayment, de-
fault, any, required repayment in full before the scheduled date, and pre-
payment.
THE BORROWER ACKNOWLEDGES RECEIPT OF AN EXACT COPY OF THIS STATEMENT.
AMOUNT FINANCED
The amount of
credit provided
to you.
STUDENT `.' altars INSTITUTIONAL
REEPRESPRESENNTATIVTATIVBORROWER E
DATE DATE l - Z c) /
EXHIBIT "B"
-09
Promissory Note-Federal Perkins Loan Program
[Any bracketed clause or paragraph may be included at option of institution.]
1, Andre D. Blacknall promise to pay to Dickinson College (hereinafter called the
Institution), located at Carlisle. PA 17013-2896 , the sum of 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, necessary for
the collection of any amount not paid when due.
I further understand and agree that.
1. Gene
(1) Applicable Law. All sums advanced under this note are drawn from a fund created under Part E of Title IV of the Higher Education Act
of 1965, as amended (hereinafter called the Act), and are subject to the Act and the Federal regulations issued 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 Forbearance. 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 Institution 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 file my request on time.
II. merest
Interest shall accrue from the beginning of the repayment period and shall be at the ANNUAL PERCENTAGE RATE OF FIVE PERCENT
(5%) on the unpaid balance, except that no interest shall accrue during any deferment period described in Article VII.
M. Repayment
(1) 1 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 least a half-time regular student at an institution of higher education, or at a comparable institution outside the United States
approved for this purpose by the United States Secretary of Education (hereinafter called the Secretary), and ending ten (10) years later, unless
that period is [shortened under paragraph III(5), or] extended under paragraphs 1II(4), III(')) (extensions), VII(I), or VII(3) (deferments).
(2) Upon my written request, the repayment period may start on a date earlier than the one indicated in paragraph III(1).
(3)(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 Institution 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 MOM), upon my written request, repayment may be made in graduated installments in accordance with a
schedule approved by the Secretary.
(4) Notwithstanding paragraph M(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 (10) years and may adjust any repayment schedule to reflect my income.
[(5)(A) If the monthly rate that would be established under paragraph M(l), or the total monthly repayment rate of principal and interest on
all my Federal Perkins Loos, including this loan, is less than $40.00 per month, I shall repay the principal and interest on
this loan at the rate of $40,00 per month (which includes both principal and interest).
(5)(B) 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 III(5)(A) includes the amounts I owe
on all my outstanding Federal Perkins 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 " $40.00 and the total of the amounts owed at a
monthly rate on my other Federal Perkins Loans.
(6) The Iastitution may permit me to pay less than the rate of $40.00 per month for a period of not mom than one (1) year
where necessary to avoid hardship to me unless that action would extend the repayment period in paragraph III(1).]
(n The Institution may, upon my written request, reduce any scheduled repayments or extend the repayment period indicated in paragraph
MM, if, in its opinion, circumstances such as prolonged illness or unemployment prevent me from making the scheduled repayments.
However, interest shall continue to accrue.
IV. re a e t
(1) I may, at my option and without penalty, prepay all or any part 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. fa It
(1) 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, laze 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
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 the 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.
(5) I understand that, if I default on my loan, I will lose my right 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 accelerates the loan under paragraph V(I), I will lose my right to receive a cancellation of a portion of
my loan for any service described in Articles VIII, DC, X, XI, X11, XIII, or XIV 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 N 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 forbearance 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 balf-time course of study at an eligible institution;
(ii) Enrolled and in attendance as a regular student in a course of study that is part of a graduate fellowship program approved by the
Secretary;
(ii) Engaged in graduate or post-graduate fellowship-ntpported study (such as a Fulbright grant) 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, X11, 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 reason that my Institution determines has caused or will cause me to have an economic hardship.
(2) 1 understand that I am not eligible for a deferment under paragraph (VII)(1)(A) 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 the expiration of any deferment provided in paragraph VII(I).
VM. Teaching 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 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 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 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(x)(2) of the Act as a school with a high concentration of students from low-income families. An official Directory of designated
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 676(6)(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 I perform qualifying service after the period for which I received the loan as a full-time
staff member in a Head Start program if-
(A) That Head Stan 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. Military Cancellation
(1) I understand that, upon making a properly 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 310 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 I received the loan.
XI. Volunteer Service Cancellation
(1) 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 I 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 Enforcement or Corrections Officer Cancellation
(1) I understand that, upon making a properly documented written request to the Institution, I son 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.
X19L Nurse or Medical Technician 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 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.
)IV. Child or Family Service Aeencv 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 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.
XVI. Chance in Name. Address. Telephone Number. or Social Security Number
I am responsible for informing the Institution of any change or changes in name, address, telephone number, or Social Security number.
Page 3 of 4 Federal Perkins/July 1993
X`M. Late Charee
(1) The Institution will impose a late charge if-
(A) I do not make a scheduled payment when it is due; and
(9) 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, VM, DI, X. XI, X11, XI11, or VV of this agreement.
(2) No charge may exceed 20 percent of my monthly, bimontbly, or quarterly payment.
(3)(A) The 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 after 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 date of the
next installment.
XVM. Assi2muent
(1) This note may be assigned by the Institution only to-
(A) The United States;
(9) 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 I could assert against the Institution that made this loan; my recovery is
limited to the amount I repaid on this loan.
M. Prior Loans
I hereby certify that I 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 OTHER INSTITUTIONS
Amount
Date
Institution
XX. Schedule of Advances
The following amounts were advanced to me under this loan agreement on the dates indicated:
Amount Date Signature of Borrower
1 $t nnn nn a/In/94 I'._/' ,51
2 $i,onn on 7/74/QS 10 ? s .t'.+/?s,,_OX
NOTICE TO BORROWER: DO NOT SIGN THIS NOTE BEFORE YOU READ ff.
I UNDERSTAND AND AGREE TO ALL OF TBE FOREGOING TERMS AND CONDMONS.
(This note is signed as a scaled insiument.]
Signature CLt r e(ir n LZLa P 00" ?f [(seal)]
Date f'/ 0, 19-rX
Permanent Address (Street or Box Number, City, State, and Zip Code)
Social Security Number (borrower must provide) X/ / a,2 Z P, /
The borrower and Institution 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 Perkins/July 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.
Dickinson College
Thomas Meyer
Assistant Treasurer of Dickinson College
Dated: 71,143
F TILES\DATAFILE\Mkinson Ca11ege7619\DickinsonCoilege allections7619QDocuments\I 12.coml
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7619C 112
DICKINSON COLLEGE,
Plaintiff
V.
ANDRE D. BLACKNALL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-3103
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 Andre D. Blacknall on
July 2, 2003, by certified mail, restricted delivery, return receipt requested.
Attached is the Post Office return receipt signed and dated July 5, 2003, and a copy of the
receipt showing the cost of service was $8.61.
MARTSON
David R. Galloway,-Esgt
I.D. No. 87326
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
WILLIAMS & OTTO
Date: July 14, 2003 Attorneys for Plaintiff
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item 4 if Restricted Delivery is desired.
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so that we can return the card to you.
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or on the front if space permits.
1. Article Addressed to:
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PS Form 3811, August 2001 Domestic Return Receipt to25g5-o2-
M-1035
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:
Mr. Andre D. Blacknall
172 Merline Avenue
Trenton, NJ 08648-3865
MARTSON DEARDORFF WILLIAMS & OTTO
By ;? -
Christina N. Yost
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: July 14, 2003
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DICKINSON COLLEGE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 03-3103
: CIVIL ACTION-LAW
ANDRE D. BLACKNALL,
Defendant JURY TRIAL OF TWELVE DEMANDED
TO: ANDRE D. BLACKNALL, DEFENDANT
NOTICE OF ENTRY OF DEFAULT JUDGMENT
You are hereby notified that on ,c? 3 , 2003, the following Judgment was entered
against you in the above-captioned case: Inkhe amount of $4,166.13 plus interest from May 28,
2003 in the amount of $43.61 and attorneys' fees in the amount of $600.00 for a total of $4,209.74,
plus costs of suit and interest accruing at $.49 per day from date of Default Judgment.
Date: September 2, 2003 L
Proth notary
Y
I hereby certify that the name and address of the proper person to receive this notice under
Pa. R. Civ. P. 236 is:
Mr. Andre D. Blacknall
172 Merline Avenue
Trenton, NJ 08648-3865
F NILMDATAFILEIDickivon College]6191DickWonCollege ollections7619C%Doeuments\i 12p sVdrg
Created 112V03 220-0] PM
Revised, 9/203 11,3253 AM
7619C.112
DICKINSON COLLEGE,
Plaintiff
V.
ANDRE D. BLACKNALL,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-3103
CIVIL ACTION-LAW
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE
Enter default judgment in the above-captioned action in favor of Plaintiff and against
Defendant in the amount of $4,166.13 plus interest from May 28, 2003 in the amount of $43.61 and
attorneys' fees in the amount of $600.00 for a total of $4,209.74, plus costs of suit and interest
accruing at $.49 per day from date of Default Judgment 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 July 30, 2003, which date
was subsequent to the date default occurred and at least ten (10) days prior to the date of this
Praecipe.
MARTSON, DEARDORFF, WILLIAMS & OTTO
4day., Bmsquire
Ten East High Stree
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Dated: September 2, 2003
P rILUIDATAFIL6VDiekin3nn t'nllcg, 71,1.1 DickLi.cmColl.Pe(allcainns]b I"ODOnnnenrsll C.noiLaiy
Rrated: 028/03 4 '.13PM
Revised'. 7?2s;03 T 15PM
7619 It2
DICKINSON COLLEGE,
Plaintiff
V.
ANDRE D. BLACKNALL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-3103
CIVIL ACTION-LAW
JURY TRIAL OF TWELVE DEMANDED
TO: ANDRE D. BLACKNALL, Defendant
NOTICE OF INTENTION TO FILE PRAECIPE
FOR ENTRY OF DEFAULT JUDGMENT
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
MARTSON DEARDORFF IAMS & OTTO
By I/fJ
David R. alloway, Esquire
L D. Number 87326
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
YOU ARE IN 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:
Dated: July 28, 2003
Attorneys for Plaintiff
I
r
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE - POSTMASTER $ J
Reoei.d From c ?t r
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PS Form 3817, Mar. 1989
CERTIFICATE OF SERVICE
I, Marti Iben, an authorized agent ofMartson Deardorff Williams & Otto, hereby certify that
a copy of the foregoing document was served this date by depositing same in the Post Office at
Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Mr. Andre D. Blacknall
172 Merlin Avenue
Trenton, New Jersey 08648-3865
MARTS'nO?N,D-E/ARDOR?JFF WIL/LIAMS & OTTO
Marti [ben
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: September 2, 2003
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F:\FILES\Clients\DickinsonCollege7619\Coilections\Cutrent\ 112\7619C.112. pra/jlb
Created: 4/28/03 1:54:03 PM
Revised: 3/6/08 11:0:22 AM
DICKINSON COLLEGE,
Plaintiff
V.
ANDRE D. BLACKNALL,
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-3103
CIVIL ACTION-LAW
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE
Please mark the judgment in the above-captioned matter satisfied and the action discontinued.
MARTSON LAW OFFICES
BY - ` S
Christopher E. Rice, Esquire
I.D. No. 90916
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Date: 5 -, & - 0 0
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller,
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. Andre D. Blacknall
10 West Randolph Street
New Hope, PA 18933
MARTSON LAW OFFICES
By V?Mary . Price
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: J/ 71eS
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