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F: IFILESIDA T AFlLEIDickinson College 7619\DickinsonCollegeColleclions7619C\Docurnentsl 1 07 ,com] !cny
Crealed:5!8!031l:50:52AM
Revised: 614/032:24:10 PM
7619C.l07
DICKINSON COLLEGE,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
NO. 63 -,310(.. c?,'c.~L <-,~
CIVIL ACTION-LAW
JACK 1. LEFKOWITH & TERI 1.
LEFKOWITH, H/W, and TRACY 1.
LEFKOWITH,
Defendants
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 DEARDO
~?
David R. Galloway,
I.D. No. 87326
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Date: 1/,(03
Attorneys for Plaintiff
Exhibit A
DICKINSON COI.LEl3E FlEXIBLE FINANCING SYSTEM - 2500 PLAN
EDUCATIONAL GCODS AND SERVICES ,RETAIL IN5TAU..MENT CONTRAcr
Date August 13, 1990
1.
Seller:
Dickinson College, Carlisle, Pennsylvania 17013
Buyer(s) :
Teri L. and Jack F. Lefkowith
118 Evans Avenue
WyomissinQ. PA 19610
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 eX'Penses incurred for goods and services to be provided and
rendered. as the case may be. to Tracy L. Lefkowith
(hereinafter "Student") during his/her enrollment at Dickinson College during the 1990-91
academic year. including tuition. room and board. rooks and supplies as herein stated
(hereinafter the "Goods and Services").
The Goods and Services shall include only tuition. room and board.
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUAL PERCENTAGE FINANCE CHARGE: AMOUNT FINANCED: TOTAL OF PAYMENTS: TOTAL SALE
RATE: Dollar Amount Amount of credit Amount paid by PRICE:
Cost of credit as credi t wi 11 provided by Buyer as total of Total cost of
yearly rate cost Buyer Dickinson College all scheduled purchase on
payments credit, in-
cluding down
Prior to repay- payment of
ment: 11 000 %
$ 16,130.00
During re~ay-
ment: 10. 59 % $ 2,001.20 $ 2.500.00 $ 4.501.20 $ 18,630.00
Rev 9/89
EXHIBIT "A"
Buyer's payment sctledule. will be as follows:
Number of Payments
Amount of Payments
When Payments are Due
.
lIS p" '(
$lT rt 9'1:-;{,
"f:)(),.9J.
monthly commencing 9/28/90 , and continuing
until 4/28/94 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.
7iiZ
9';(
4l8'
II '/7 /.5
U]J ~ 9'fX
monthly commencing 5/28/94 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 TIlE COlITRACT BELOW FDR ANY ADDITIONAL INFORMATION ABJUI' NON-PAYMENT,
DEPAULT AND REQUIRED REPAYMENT BEFORE TIlE SCHEDULED DATE FOR REPAYMENT OF TIlE AMOUNT
FINANCID .
III. ITEMIZATION OF AMOUNT FINANCID
1. Cash price of Goods and Services: $ 18,630.00
2. Total down payment: 16.130.00
3. Unpaid balance of cash price (1 - 2): 2.500.00
4. Amount paid to others on Buyer's behalf: 0
5. Amount Financed (3 + 4): $ 2.500.00
IV. CREDIT INSURANCE
Credit life insurance for the term of this Contract is not required.
V. NO WARRANTIES
THERE ARE NO WARRANI'IES. EI1HER EXPRESSED OR IMPLIED, GIVEN BY SEU.ER IN CONNECTION
WITH SALE OF THE GOODS AND SERVICES COVERED BY nus CONTRACT UNLESS BUYER HAS BEEN GIVEN A
SEPARATE WRITTEN WARRANTY.
2
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 First Wachovia, Inc. at the
following address:
First Wachovia, Inc.
P.O. Box 70095
Charlotte, NC 28272-0095
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 involving 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 SUlIlS due on the Contract to be
immediately due and payable. The Buyer agrees to pay all attorney's fees and other
reasonable collection costs and charges necessary for the collection of any amount not
paid when due.
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. APPLICABlE LAW: This Agreement, whenever called upon to be construed, shall be
governed by the domestic internal laws of the Commonwealth of Pennsylvania except to
the extent supplemented, superseded or preempted by federal law.
3
9. CONSENf TO JURISDICTION, VENUE AND ,SERVICE: The parties to this Agreement consent and
agree t.hat all legal proceedings r'elating to the subject matter hereof shall be
maintained in the Court of Common Pleas of Cumberland County, Pennsylvania. or, if
applicable. the United States District Court of the Middle District of Pennsylvania.
and all parties hereto consent and agree that jurisdiction and venue for such
proceedings shall lie exclusively within said court. Service of process in any such
proceeding may be made' by certified mail. return receipt requested. directed to the
respective party at the address set forth above.
10. This Contract shall be binding upon the parties hereto. their heirs, successors.
assigns and legal representatives.
11. TIME IS OF TIlE 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 TIlE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT
HERETO OR WITIl TIlE ffiXEEDS HEREOF. RECOVERY HEREUNDER BY TIlE DEBTOR 5'HALL NOT EXCEED
AMOUNTS PAID BY TIlE DEBTOR HEREUNDER.
NOTICE TO BUYER: (1) IX) NOT SIGN THIS AGREEMENT BEFDRE YOU READ IT OR IF IT CONTAINS ANY
BLANK SPACE. (2) YOU ARE ENTITLED TO A COMPLETELY FILLED-IN COPY OF TIllS AGREEMENT. (3)
UNDER THE LAW. YOU HAVE THE RIGHI' TO PAY OFF IN ADVANCE TIlE FULL AMOUNT DUE AND UNDER
CERTAIN CONDITIONS TO OBTAIN A PARTIAL REFlJND OF THE FINANCE CHARGE.
BUYER(S) ACKNOWLEl.X7E(S) RECEIVING A COMPLETED COPY OF THIS CONTRACT AND INTEND(S) TO
BE LEl3ALLY rouND BY ITS TERMS.
~lU ~ ~.. '11>(1 ~
yL Sf-
BUYER(S) :
I AGREE TO REPAY ALL AMOUNTS DUE ON THIS LOAN IF TIlE OORROWER(S)/BUYER(S) FAILS TO
IX) SO IN ACCORDANCE WITIl THE TERMS O~~N01E: .
STUDENT COSIGNER l/MfAI ;(~i~
DA1E:
DICKINSON COLLB3E
~'il'i(YO
BY
(~~~, <'- \
4
Exhibit B
DIO<INOON COI..LEl3E FLEXI;BLE F:j:NANCING SYSTEM - 7000 PLAN
EDUCATIONAL GCODS AND SERVICES RETAIL INSI'AI1.MENT CONTRACT
Date September 24, 1990
I.
Seller:
Dickinson College, Carlisle, Pennsylvania 17013
Teri L. and Jack F. Lefkowith
Buyer(sJ:
118 Evans Avenue
Wyomissing, PA 19610
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 Contr,~ct.
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 Tracy L.
(hereinafter "Student") during his/her enrollment at Dickinson College during the 1990-91
academic year, including tuition. room and board. books and suppl ies as herein stated
(hereinafter the "Goods and Services") ,
The Goods and Services shall include only tuition. room and board.
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUAL PERCENTAGE FINANCE CHARGE: AMOUNT FINANCED: TOTAL OF PAYMENTS: TOTAL SALE
RATE: * Dollar amount Amount of credi t Amount paid by PRICE:
Cost of credi t as credi t wi 11 provided by Buyer as total of Total cost of
yearly rate cost Buyer Dickinson College all scheduled purchase on
payments credi t, in-
cluding down
payment of
$ 13,775.00
10.812 % $ 4,079.56 $4.855.00 $ 8,934.56 $ 18.630.00
Rev 9/89
EXHIBIT "B"
Buyer's payment schedule will be as follows:
M~r of Payments Amount of Payments
152
'Variable Rate:
L3.te Charge:
Prepayment:
When Payments are Due
$58.78
Monthly commencing
until 5/28/03
10/28/90
The ANNUAL PERCENTAGE RATE disclosed arove is a variable rate and may
change. The ANNUAL PERCENTAGE RATE may increase during the term of
this transaction if the prime rate of interest announced in the Wall
Street Journal as of the close of business on June 30 of each calendar
year increases. and will be increased to the prime rate plus 1%. The
ANNUAL PERCENTAGE RATE wi 11 not increase more than once a year. and
the new interest rate will become effective on July 1 following the
increase, if any, in the prime rate of interest. Any increase will be
in the form of higher payment amount~. If your cost of the Goods and
Se{52ices sold hereunder were $ 4,8!l5.00at 11.00% per ann~ bor
~ months. and the prime rate plus 1% were incretf:a to 1. 0 %,
your regular monthly payments would increase to $' Further,
the ANNUAL PERCENTAGE RATE wi 11 not increase to more than 18% or such
other rate as may be permitted under the Pennsylvania Goods and
Services Installment Sales Act.
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 .
Buyer may prepay the unpaid b9.lance of the Amount Financed and any
FINANCE CHARGE due through the date of early payment, in full or in
p:.rt, without pem.lty.
SEE SECTION VI OF THE CONTRACT BELOW FOR ANY ADDITIONAL INFORMATION AIDJT NON-PAYMENT.
DEFAULT AND RroUlRED REPAYMENT BEFORE THE SCHEDULED DATE FOR REPAYMENT OF THE AMOUNT
FINANCED.
III. ITEMIZATION OF AMOUNT FINANCED
1. Cash price of Goods and Services:
$
18,630.00
13,775.00
4,855.00
o
4,855.00
2. Total down payment:
3. Unpaid b9.lance of cash price (1 - 2):
4. Amount paid to others on Buyer's behalf:
5. Amount Financed (3 + 4):
$
2
IV. CREDIT INSURANCE
.
Credit life insurance for the term of this Contract is not required.
V. NO WARPANTIES
TIIERE ARE NO WARRANTIES, EITHER EXPRESSED OR IMPLIED, GIVEN BY SELLER IN CONNECTION
WITI-I SALE OF TIlE GOODS AND SERVICES COVERED BY TI-lIS CONTRACT UNLESS BUYER HAS BEEN GIVEN A
SEPARA'IE WRITTEN WARRAN1Y.
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 First Wachovia, Inc. at the
fOllowing address:
First Wachovia. Inc.
P.O. Box 70095
O1ar1 otte, NC 28272-0095
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 involving 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. The Buyer agrees to pay all attorney's fees and other
reasonable collection costs and charges necessary for the collection of any amount not
paid when due.
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 C,3.use 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 right and remedies.
3
7. If any part of this Contract is held to be illegal, void or unenforceable. that
provision shall be deem~i not to have been. a part of this Contract, which shall
otherwise remain fully effective.
8. APPLICABLE LAW: This Agreement, whenever called upon to be construed, shall be
governed by the domestic internal laws of the Commonwealth of Pennsylvania except to
the extent supplemented, superseded or preempted by federal law.
9. CONSENT TO JURISDICTION, VENUE AND SERVICE: The parties to this Agreement consent and
agree that all legal proceedings relating to the subject matter hereof shall be
maintained in the Court of Common Pleas of Cumberland County, Pennsylvania, or, if
applicable, the United States District Court of the Middle District of Pennsylvania,
and all parties hereto consent and agree that jurisdiction and venue for such
proceedings shall I ie exclusively within said court. Service of process in any such
proceeding may be made by certified mail. return receipt requested. directed to the
respective party at the address set forth above.
10. This Contract shall be binding upon the parties hereto, their heirs, successors,
assigns and legal representatives.
11, TIME IS OF TIlE ESSENCE OF TIiIS CONTRACT.
NOTICE: ANY HOLDER OF TIUS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES
WHICH TIlE DEBTOR COULD ASSERT AGAINSI' TIlE SELLER OF G<XlDS OR SERVICES OBTAINED PURSUANT
1ilih'.J:;1U OR WITH TIlE PROCEE:J:S HEREOF. RECOVERY HERIDNDER BY TIlE DEm'OR SHAlL NOT EXCEED
AMOUNTS PAID BY TIlE DEm'OR HERIDNDER.
NOTICE TO BUYER: (1) 00 NOT SIGN TIiIS AGRIDlENT BEFORE YOU READ IT OR IF IT CONTAINS ANY
BLANK SPACE. (2) YOU ARE ENTITLED TO A COMPLETELY FIIlED--IN COPY OF TIllS AGREEMENT.
(3) UNDER THE LAW, YOU HAVE TIlE RIGHT TO PAY OFF IN ADVANCE TIlE FUlL AMOUNI' DUE AND UNDER
CERTAIN CONDITIONS TO OBTAIN A PARTIAL REFUND OF TIlE FINANCE CHARGE.
BUYER(S) ACIOOWLID3E(S) RECEIVING A COMPLETED COPY OF TIllS CONTRACT AND INTEND(S) 1'0
BE LB3ALLY rouND BY ITS TERMS.
~/l "~'
/// .)C./ '
'\ ld-I.i I). (" "1,.,
y--L >;'. /
BUYER(S) :
I AGREE TO REPAY ALL AMOUNTS DUE ON TIllS LOAN IF TIlE IDRROWER(S)!BUYER(S) FAILS 1'0
00 SO IN ACCORDANCE WITII THE TERMS OF TIlE OOTE:
STUDENT COSIGNER --.'0). lA-CV6' ct. ~~~
DATE:
DICKINSON COUB3E
'1 (V(( 'jo
BY
~
4
Exhibit C
DICKINOON COLUm: FLEXIBLE FINANCING SYSI'E}! - 7000 PLAN
EDUCATIONAL GCO[6 AND SERVICES RETAIL INsrAl.LMElIT CONI'RACf
Date October 9, 1991
1.
Seller:
Dickinson College, Carlisle. Pennsylvania 17013
Teri L. and Jack F. Lefkowith
Buyer(s) :
118 Evans Avenue
Wyomissin9, PA 19610
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 Contr,~ct.
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 te provided and
rendered, as the case may be, to Tracy
(hereinafter "Student") during his/her enrollment at Dickinson College during the 1991-92
academic year, including tuition, room and board. books and supplies ,~s herein stated
(hereinafter the "Goods and Services") .
The Goods and Services shall include only tuition. room and board.
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUAL PERCENTAGE FINANCE CHARGE: AMOUNT FINANCED: TOTAL OF PAYMENTS: TOfAL SALE
RA1E: * Dollar amount Amount of eredit Amount paid by PRICE:
Cost of eredi t as eredi t wi 11 provided by Buyer as total of Total cost of
yearly rate cost Buyer Dickinson College all scheduled purchase on
payments eredi t . in-
cluding dOwn
payment of
$ 12,980.00
9.499 % $4,606.00 $ 7,000.00 $ 11,606.00 $ 19,980.00
Rev 9/89
EXHIBIT "e"
fuyer's payment schedule will be as follows:
Number of Payments AmOUI:lt of Payments
140
*Variable Rate:
Late Charge:
Prepayment:
When Payments are Due
$82.90
Monthly commencing 10/28/91
until 5/28/03
The ANNUAL PERCENTAGE RJ\.1E disclosed above is a variable rate and may
change. The ANNUAL PERCENI'AGE HAlE may increase during the term of
this transaction if the prime rate of interest announced in the Wall
street Journal as of the close of business on June 30 of each calendar
year increases, and will be increased to the prime rate plus 1%. The
ANNUAL PERCENTAGE HAlE wi 11 not increase more than once a year, and
the new interest rate will become effective on July 1 following the
increase, if any, in the prime rate of interest. Any increase wi 11 be
in the form of higher payment amounts. If your cost of the Goods and
Services sold hereunder were $ 7,000.00 at q 50 % per annum for
--1All months, and the prime rate plus 1% were increased t010.500 %,
your regular monthly payments would increase to $ R6.Q1 Further,
the ANNUAL PERCENTAGE HA1E wi 11 not increase to more than 18% or such
other rate as may be permitted under the Pennsylvania G<XXls and
Services Installment Sales Act.
If a payment is more than 15 days late. a sum equivalent to 5% of the
late payment (rot no more than $2.50 and not less than $1.00) may be
charged .
:fuyer 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 CONTRACI' BELOW FOR ANY J\DDITIONAL INFDRMATION AroUT NON-PAYMENT,
DEFAULT AND RmUlRED REPAYMENT .BEFORE THE SCHEDULED DATE FOR REPAYMENT OF THE AMOUNI'
FINANCED.
III. ITEMIZATION OF AM:JUNT FINANCED
1. Cash price of Goods and Services: $ 19,980.00
2. Total down payment: 12,980.00
3. Unpaid balance of cash price (1 - 2): 7,000.00
4. Amount paid to others on fuyer's behalf: -0-
5. Amount Financed (3 + 4): $ 7,000.00
2
IV.. CREDIT INSURANCE
Credit life insl~ance fox' the term of this Contract is not rec~ired.
V. NO WARr&NTIES
THERE ARE NO WARRANTIES, EITIlER EXPRESSED OR IMPLIED. GIVEN BY SELLER IN CONNEL"'I'ION
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 ani 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 First Wachovia, Inc. at the
following address:
First Wachovia, Inc.
P.O. B:>x 70095
Charlotte, NC 28272-0095
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, ani (with Seller's
consent) to reinstate the Contract if Buyer timely cures any default.
3. fuyer 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 fuyer of crime involving fraud or
dishonesty,
(f) insolvency or bankruptcy of any fuyer.
4. Upon or after the occurrence of any Event of Default, Seller will provide fuyer with
notice, by certified mail as required by law, addressed to fuyer's last known address
as shown on Seller's records, advising fuyer of the default and of Buyer's right to
cure the default. The notice wi 11 provide the time, amount and performance necessary
to cure the default. If fuyer 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. The fuyer agrees to pay all attorney's fees and other
reasonable collection costs ani charges necessary for the collection of any amount not
paid when due.
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 fuyer shall be obligated to the Assignee of this Contract, which
Assignee shall have all of Seller's right and remedies.
3
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. APPUCABLE LAW: This Agreement, whenever called upon to be construed, shall be
governed by the domestic internal laws of the Commonwealth of Pennsylvania except to
the extent supplemented, superseded or preempted by federal law.
9. CONSENT TO JURISDlcrION, VENUE AND SERVICE: The parties to this Agreement consent and
agree that all legal proceedings relating to the subject matter hereof shall be
maintained in the Court of Common Pleas of Cumberland County, Pennsylvania, or, if
applicable, the United States District Court of the Middle District of Pennsylvania,
and all parties hereto consent and agree that jurisdiction and venue for such
proceedings shall lie exclusively within said court. Service of process in any such
proceeding may be made by certified mail, return receipt requested, directed to the
respective party at the address set forth above.
10. This Contract shall be binding upon the parties hereto. their heirs. successors,
assigns and legal representatives.
11. TIME IS OF TIlE ESSENCE OF TI-IIS OONTRAcr.
NOTICE: ANY HOLDER OF lliIS CONSUMER CREDIT OONTRAcr IS SUBJECT TO AIL CLAIMS AND DEFENSES
WHlOi TIlE DEBTOR COULD ASSERT AGAINSf TIlE SELLER OF GCODS OR SERVICES OBTAINED PURSUANf
I-tJ:;I.ililu OR WIW TIlE PROCEEC6 HEREOF. REroVERY HERIDNDER BY TIlE DEBTOR SH1\1.L NOT EXCEED
AMJUNTS PAID BY TIlE DEBTOR HEREXJNDER.
NOTICE TO BUYER: (1) 00 NOT SIGN WIS AGREEMENI' BEFORE YOU READ IT OR IF IT COtrrAINS ANY
BLANK SPACE. (2) YOU ARE ENTITI.ED TO A <XlMPlEIELY FIILID-IN COPY OF WIS AGRED!ENT.
(3) UNDER 'THE LAW, YOU HAVE TIlE RIGHI' TO PAY OFF IN ADVANCE 'THE FUIL AMOUNT DUE AND UNDER
CER'TAIN CONDITIONS TO OBTAIN A PARTIAL ID1JNI) OF TIlE FINANCE CHARGE.
BUYER(S) ACKNOWLEOOE(S) REX::EIVING A COMPLETED COPY OF lliIS CONTRAcr AND INTEND(S) TO
BE LEl3AILY :rouND BY ITS TERMS,
BUYER(S) :
I AGREE TO REPAY AIL AMOUNI'S DUE ON lliIS WAN IF TIlE IDRROWER(S)!BUYER(S) FAIIS TO
00 SO IN ACCORDANCE WIlli TIlE TERMS OF 1HE NOI'E:
STUDENT COSIGNER .-lLeLC'--j ('/:.' if..lt !"cc,.<...:.;'-S+1'--'
DATE:
DICKINSON COLLEl3E
/0-' 9- 7/
BY
~~
4
Exhibit D
DICKINOON COumE FLEXIBLE FINANCING SYSID1 - 2500 PLAN
EDUCATIONAL GCODS AND SERVICES, RETAIL INSI'ALlMENI' CONTP.ACT
Date
October 11, 1991
1.
Seller:
Dickinson College. Carlisle. Pennsylvania 17013
Ter; L. and Jack F. ~ /-ePKa/N/7t(
Buyer(s) :
118 Evans Avenue
Wyom;ss;ng, PA 19610
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 ex-penses inCUlTed for goods and services to be provided and
rendered, as the case may be. to Tracy L. Lefkow; th
(hereinafter "Student") during hislher enrollment at Dickinson College during the 1qq1-q;:>
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 tuition. room and board.
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUJl.L PERCENIAGE FINANCE CHARGE: AMOUNT FINANCED: TOTAL OF PAYMENTS: TOTAL SALE
RATE: Dollar Amount Amount of credi t Amount paid by PRICE:
Cost of credit as credit will provided by Buyer as total of Total cost of
yearly rate cost Buyer Dickinson COllege all scheduled purchase on
payments credit. in-
cluding down
Prior to repay- payment of
ment:11 000 %
$17,480.00
During repay-
ment:10.659 % $ 1,734.20 $ 2,500.00 $ 4,234.20 $19,980.00
EXHIBIT "n"
Rev 9/89
Buyer's payment s~hedule will be as follows:
32 $22.92
When Payments are Due
monthly. commencing 10/28/91 , and continuing
until 4/28/94 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.
Number of Payments Amount of Payments
72 $47.58
monthly commencing 5/28/94 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 AIDJI' NON-PAYMENT,
DEFAULT AND REQUIRED REPAYMENT BEFORE THE SCHEDULED DA1E FOR REPAYMENT OF THE AMOUNT
FINANCED .
III. ITEMIZATION OF AMOUNT FINANCED
1. Cash price of Goods and Services:
$
19,980.00
17,480.00
2,500.00
o
2,500.00
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) :
$
IV. CREDIT INSURANCE
Credit life insurance for the term of this Contract is not required.
V. NO WARRANTIES
1HERE ARE NO WARRANTIES, EITHER EXPRESSED OR IMPLIED, GIVEN BY SELLER IN CONNECTION
WIlli SALE OF THE GOODS AND SERVICES COVERED BY lliIS CONTRACf UNLESS BUYER HAS BEEN GIVEN A
SEPARA1E WRITTEN WARRANTY.
2
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 First Wachovia, Inc. at the
following address:
First Wachovia, Inc.
P.O. Box 70095
Charlotte, NC 28272-0095
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 involving fraud or
dishonesty,
(f) insolvency or bankruptcy of any fuyer.
4. Upon or after the occurrence of any Event of Default, Seller will provide fuyer with
notice, by certified mail as required by law, addressed to Buyer's last known address
as shown on Seller's records, advising fuyer of the default and of fuyer's right to
cure the defaul t. The notice wi 11 provide the time. amount' and performance necessary
to cure the default. If fuyer 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. The Buyer agrees to pay all attorney's fees and other
reasonable collection costs and charges necessary for the collection of any amount not
paid when due.
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. APPLICABLE LAW: This Agreement, whenever called upon to be construed. shall be
governed by the domestic internal laws of the Commonwealth of Pennsylvania except to
the extent supplemented, superseded or preempted by federal law.
3
9. CONSENT TO JURISDICTION, VENUE AND SERVICE: The parties to this Agreement consent and
agree that all le<;;ral proceedings l~elatil"J to the subjeGt matter hereof shall be
maintained in the Court of Common Pleas of Cumberland County, Pennsylvania, or, if
applicable, the United States DistriGt Court of the Middle District of Pennsylvania,
and all parties hereto consent and agree that jurisdiction and venue for such
proceedings shall lie exclusively within said court. Service of prOGess in any such
proceeding may be made by certified mai I, return receipt requested, directed to the
respective party at the address set forth above.
10. This Contract shall be binding upon the parties hereto, their heirs. successors.
assigns and legal representatives.
11. TIME IS OF TIlE ESSENCE OF TIllS CONTRACT.
NOTICE: ANY HOLDER OF TIllS CONSUMER CREDIT CONTRACT IS SUBJECT TO A.I.L CLAIMS AND DEFENSES
WHICH TIlE DEBTOR COULD ASSERT AGAINST TIlE SELLER OF GCODS OR SERVICES OBTAINED PURSUANr
HEREIO OR WITII TIlE PhDCEEDS HEREDF. RECOVERY HEREUNDER BY TIlE DEBTOR SHAll NOT EXCEED
AMOUNTS PAID BY TIlE DEBTOR HEREUNDER.
NOTICE TO BUYER: (1) 00 NOT SIGN TIllS AGREEMENI' BEFORE YOU READ IT OR IF IT CONTAINS ANY
BLANK SPACE. (2) YOU ARE ENTITLED TO A COMPLETELY FIlLED- IN COPY OF TIllS AGREEMENT. (3)
UNDER TIlE LAW. YOU HAVE TIlE RIGHI TO PAY OFF IN ADVANCE TIlE FULL AMOUNT DUE AND UNDER
CERTAIN CONDITIONS TO OBTAIN A PARTIAL REFUND OF TIlE FINANCE CHARGE.
BUYER(S) AC!<NOWI..ED3E(S) RECEIVING A COMPLETED COPY OF TIllS CONTRACT AND INTEND(S) TO
BE LEl3ALLY :rouND BY ITS TERMS.
(4. /'/i !(. A
~~'::7'o '
BUYER (S) :
.~
I AGREE TO REPAY A.I.L AMOUNTS DUE ON TIllS LOAN IF TIlE IDRROWER(S)/BUYER(S)
00 SO IN ACCORDANCE WITII TIlE TERMS OF TIlE NOTE:
(\ VJ .
,'1 '<'l.:C^c~ &:. C1-<-6 Ac01-0 (:+'v\..- '
FAIIS TO
SI'UDENT COSIGNER
DATE:
DICKINSON COIill3E
/6-"-"i!
BY
~~-
4
Exhibit E
, ,
DIa<INOON OOT 1:me: FLEXIBLE FINANCING SYSTEM - 2500 PIllN
IDJCATIONM. GOOOO AND smvICES REI'AIL INSI'Al.1MENl' <XlNl'RACf
Date
May 13, 1992
fuyer(s) :
Dickinson College. Carlisle. Pennsylvania 17013
Teri L. and Jack F. Lefkowith
I. Seller:
118 Evans Avenue
Wyomissing, PA 19610
If there is more than one fuyer. each of you will be obligated. jointly and severally.
for all sums due and for the perfonDance of all agreements as provided in this Contract.
Under the terms of this Etlucational Goods ani Services Retail Installment Contract.
you have agreed to pay the expenses inCUl'Ted for goods and services to be provided and
rendered. as the case may be. to Tracy L. Lefkowith
(hereinafter "Student") during his/her enrollment at Dickinson College during the SUlllller '92
academic year, including tuition. room and board. I:x:lOks and supplies as herein stated
(hereinafter the "Goods and Services") .
The Goods and Services shall include only tuition. room and board.
II. TffiMS OF PAYMENI' AND PAYMENT OCHEDULE
Disclosures Required by Federal Law
ANNUAL PERCENTAGE FINANCE CHARGE: AKXJNI' FIN1\NCED: 1Ul'AL OF PAYMENI'S: TOI'AL SALE
RATE: Dollar Amount Amount of credit Amount paid by PRICE:
Cost of credit as credit wi 11 provided by fuyer as total of Total cost of
yearly rate cost fuyer Dickinson College all scheduled purchase on
payments credit. in-
cluding down
Prior to repay- payment of
ment: 11 nn %
$ 335.00
IXlring repay-
ment: 11.00 % $ 906.64 $1.440.00 $ 2.346.64 $ 1.775.00
EXHIBIT "E"
Rev 9/89
I~_lyer'3 payment sch",dule will be as follows:
Number of Payments Amount of Payments
When Payments are D.le
25 $13.20
monthly commencing 5/28/92 and continuing
until 4/28/94 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.
72 $27.40
monthly commencing 5/28/94 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.
L,te ch'3.rge: If ,3. 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.
Frep,'lYlnent: Buyer may prepay the unpaid ba lance of the Amount Financed and any FINANCE
CHARC:E due through the date of early payment. in full or in part. without
penalty.
:::n:: ,::!'XT feJN VI OF' '!1-lE CUNTRACr BELOW FOR ANY ADDITIONAL INFORMATION AroJI' NON-PAYMENT,
DEFAULT ~Jm RB.:!UIRED REPAYMENT BEFORE 1HE SC1-lEDULED DATE FOR REPAYMENT OF 1HE AMJUNT
FlNj.\NCED.
III. ITEMIZATION OF AMOUNT FINANCED
l. ('ash price of Goods and Services: $ 1.775.00
''', Tot.al down payment: 335.00
J. Unpaid b:t.lance of cash price (1 - 2) , 1.440.00
4. l:unOWit pc~ld to others on Buyer's behalf : 0
5. IImOW1t Financed (3 + 4) : $ 1,440.00
IV . CREDIT INSURANCE
Credit life insux"ance for the term of this Contract is not required.
V. NO WARRANTIES
TIIERE ARE NO WAr;PANTIE:::. EIlliER EXPRESSED OR IMPLIED. GIVEN BY SEI1..ER IN CONNECTION
WIlli SAlE OF 1HE GCODS AND SERVICES COVERED BY lliIS CONTRACT UNLESS BUYER HAS BEEN GIVEN A
:"::EPARATE WRITTEN WAPFAN"[y.
2
VI . ADDITIONAL PROVISIONS
1. atyer agrees to pay Seller the Total Sale Price by making the total down payment am
paying Seller the Total of Payments in the number and amount ot 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 IDU5t be made to First Wachovia. Inc. at the
following address:
First Wachovia. Inc.
P.O. Box 70095
Olarlotte. NC 28272-{)095
2. fuyer's legal rights include the right to pay all or part ot the amounts due on this
Contract in advance of their due dates. to obtain a refurn or credit of unearned
Finance Olarge whenever the amount is paid in full in advance. ani (with Seller's
consent) to reinstate the Contract if fuyer timely cures any default.
3. atyer 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 outstaming with Seller.
(c) failure to perform any other provision of the Contract.
(d) providing Seller with false infornation or signatures.
(e) death. incompetence, or conviction of any fuyer of crime involving fraud or
dishonesty.
(f) insolvency or bankruptcy of any fuyer.
4. Upon or after the occurrence of any Event of Default. Seller will provide atyer with
notice. by certified mail as required by law. addressed to fuyer's last known address
as shown on Seller's records. advising fuyer of the default ani of fuyer's right to
cure the default. The notice will provide the time. amount aM. performance necessary
to cure the de fau I t. If fuyer does not cure the default as provided in the notice.
Seller's rights shall include the right to declare all SUID5 due on the Contract to be
immediately due and payable. The fuyer agrees to pay all attorney's tees am other
reasonable collection costs aM. charges necessary for the collection of any amcunt not
paid when due.
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 simi lar Event of
Default occurs later. All Seller's rights and remedies shall be CUIILllative. 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. fuyer agrees that upon receiving notice
of the assignment fuyer shall be obligated to the Assignee of this Contract. which
Assignee shall have all of Seller's rights arxI. remedies.
7. If any part of this Contract is held to be illegal. void or unenforceable. that
provision shall be deeJlled not to have been a part of this Contract. which shall
otherwise remain fully effective.
8. APPLIOJ3LE lAW: This Agreement. whenever called upon to be construed. shall be
governed by the domestic internal laws of the Commonwealth of Pennsylvania except to
the extent supplemented. superseded or preempted by federal law.
3
9. CONSENT TO JURISDICTION, VENUE AND SERVICE: The parties to this Agreement consent am
agree that all legal proceedi~ relating to the subject matter hereof shall be
maintained in the Court of Common Pleas of Cumber I ani County, Pennsylvania, or. if
applicable. the United States District Court of the Middle District of Pennsylvania,
and. all parties hereto consent and. agree that jurisdiction ani venue for such
proceedings shall lie eXClusively within said court. Service of process in any such
proceediTg' may be made by certified ,mail, return receipt requested, directed to the
respective party at the address set forth above.
10. This Contract shall be biniiTg' upon the parties hereto, their heirs, successors,
assigns and. legal representatives.
11. TIME IS OF 1HE ESSENCE OF nns <XlNTRACT.
NOTICE: ANY HOlDER OF lliIS CONSUMER CREDIT CONTRACT IS SUBJECT TO AlL ClAIMS AND DEF'ENSEE
WHICH 'lliE DEBTOR COUlD ASSERT AGAINST 1HE SEll.ER OF GCOI:6 OR SERVICES OBTAINED PURSUANI'
HERETO OR WIlli 1HE m:x:EEOO HEREOF. RECOVERY' HEREl.JNDER BY 1HE DEBTOR SHAll. NOT EXCEED
AMOUNTS PAID BY 1HE DEBTOR HEREUNDER.
NOTICE 10 BUYER: (1) 00 NOT SIGN lliIS AGREEMENT BEFORE YOU READ IT OR IF IT COOI'AINS ANi
BLANK SPACE. (2) YOU ARE ENTI1LED TO A COMPLETELY FIlLID--IN COPY OF nus AGREEMENT. (3)
UNDER 'lliE LAW, YOU HAVE 1HE RIGHI' TO PAY OFF IN ADVANCE 1HE FUlL AMOUNT DUE AND UNDER
CERTAIN CONDITIONS TO OBTAIN A PARTIAL REFUND OF 1HE FINANCE CHARGE.
~~~~E~~..rm A a>n1mD. '. /J OF lliIS CONI'RACT AND IlITEND(S) TO
IDYER(S): ,;;yd~~ ~~, ~
~!( l f~irC::.c;A
I AGREE TO REPAY AlL AMOUNI'S DUE ON lliIS WAN IF 1HE IDRROWER(Sl!BUYER(S) FAILS TO
00 SO IN ACCORDANCE WIlli 1HE TERMS OF 1HE OOI'E: ,
SIUDENT CCBIGNER ~R~~~~OI~:~io~~~~~ILL NOT BE RELEASED
IF LOAN PAYMENTS TO THE COLLEGE ARE IN ARREARS OR DEFAULT.
DATE:
DICKINSON C01LEl3E
5-/,-/-'77-
BY
,.<2-,.
4
Exhibit F
, .
DIa<INa:lN mY J:rnF. FLEXIBLE FIN1\NCING S'iS'ID4 - 2500 PLAN
EOOCATIONM. GO:It'6 AND SERVICES RETAIL INSTALlMENl' <XlI'ITHAcr
Date Au~ust 27. 199?
I.
Seller:
Dickinson College, Carlisle. Pennsylvania 17013
Buyer(s): Teri L and Jack F Lefkowith
118 Evans Ave
Wvomissin~. PA 19610
If there is more than one fuyer. each of you will be obligated. jointly am severally.
for all sums due am for the performance of all agreements as provided in this Contract.
Umer the terms of this Fducational Goods ani Services Retail Installment Contract,
you have agreed to pay the expenses incurred for goods and services to be provided am
remered. as the case may be. to Tracy Lefkowith
(hereinafter "Student") duri~ his/her enrollment at Dickinson College duri~ the 199?-CI1
academic year, includi~ tuition. room am board. books am supplies as herein stated
(hereinafter the "Goods am Services").
The Goods am Services shall include only tuition, room am board.
II. TERMS OF PAYMENT AND PAYMENT SOlEDULE
Disclosures Required by Federal Law
ANNUAL PmCENTAGE FINANCE 0il\B3E: AMJUNT FINANCED: TOTAL OF PAYMENTS: TOTAL SALE
RAm: Dollar Amount Amount of credit Amount paid by PRICE:
Cost of credit as credit will provided by fuyer as total of Total cost of
yearly rate cost Buyer Dickinson College all scheduled lXJl"Chase on
payments credit. in-
cludi~ down
Prior to repay- payment of
ment: 11.00 %
$18,860.00
Duri~ repay-
ment: 11.00 % $ 1.482.44 $ 2.500.00 $ 3.982.44 $21,360.00
EXHIBIT "F"
Rev 9/89
Buyer's payment schedule will be as follows:
Number of Payments ArnOl..U1t of Payments
When Payments are we
21 $22.92
monthly commencing 9-28-92 ,and continuing
until 4-28-94 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.
72 $47.59
monthly commencing 5-28-94 or such time as
Student is no longer enrolled at Dickinson
(or in an approved full-time off-campus
program of studies), whichever is earl ier.
L,te ch.3.rge: If a. payment is more t.han 15 days latE-, a sum equivalent to 5% of the late
payment. (but no more t.han $2.50 ard not less than $1.00) may be charged.
hep,'yment: Buyer may prepay the unpaid balance of the Amount Financed ard any FINANCE
CHAR(,E due through the date of early payment. in full or in part, without
penalty.
':EF ':'rrrION VI OF' '[HE CONTRACr BELOW FOR ANY .ADDITIONAL INFORMATION AB:Ur NON-PAYMENT..
Df.J:'Al.n.T~.ND r;:BJUIf.:rn REPAYMENT BEFORE 1HE SCHEDULED DATE FOR REPAYMENT OF 1HE AMJUNT
f j. NANCED .
III. ITEMIZATION OF AMOUNI' FINANCED
.[
i\}:=h price of Goods and Services:
$21,360.00
'Iota 1 down payment:
18,860.00
3,
Unpaid tn.lance of c.3.sh price (1 - 2):
2,500.00
4.
~~ount paId to others on BLlyer's behalf:
o
$ 2,500.0Q..
r.~
"-'.
Nnount Fi nanced ('3 + 4) :
IV. CREDIT INSURANCE
Credit life insurance for the term of this Contract is not required.
V. NO WARRANTIES
THERE APE NO WARP.ANTIES. EITIiER EXPRrnSED OR IMPLIED, GIVEN BY SELLER IN CONNECTION
WIlli SALE OF 1HE G(OOS AND SERVICES COVERED BY lliIS CONTRACT lJNLE3S BUYER HAS BEEN GIVEN A
:'iEPARATE WRITTEN WARP-WIY.
2
VI . ADDITIONAL POOVISIONS
. ,
1. B.lyer agrees to pay Seller the Total Sale Price by maJdIY;1 the total down payment arxl
paying Seller the Total of Payments in the number arxl 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 First Wachovia. Inc. at the
followiIY;1 address:
First Wachovia. Inc.
P.O. Box 70095
Charlotte. NC 28272-0095
2. B.lyer'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 refurd or credit of unearned
Finance Charge whenever the amount is paid in full in advance. arxl (with Seller's
consent) to reinstate the Contract if B..tyer timely cures any default.
3. B.lyer shall be deemed to have cOlDlDitted an "Event of Default" of the Contract upon the
occurrence of any of the followiIY;1:
(a) failure to make any payment on or before the date it is due.
(b) failure to make a payment on any other Contract outstaming with Seller.
(c) failure to perform any other provision of the Contract.
(d) providiIY;1 Seller with false information or signatures.
(e) death. incompetence. or conviction of any fuyer of crime involving fraud or
dishonesty.
(f) insolvency or bankruptcy of any B..tyer.
4. Upon or after the occurrence of any Event of Default. Seller will provide fuyer with
notice. by certified mail as required by law. addressed to fuyer's last known address
as shown on Seller's records. advisiIY;1 fuyer of the default and of fuyer's right to
cure the default. The notice will provide the time. amount arxl performance necessary
to cure the default. If fuyer does not cure the default as provided in the notice.
Seller's rights shall include the right to declare all 6lIIIlS due on the Contract to be
immediately due arxl payable. The fuyer agrees to pay all attorney's fees arxl other
reasonable collection costs arxl charges necessary for the collection of any amount not
paid when due.
5. Waiver by Seller of any event of default shall not be birrliIY;1 upon Seller if Seller
should thereafter choose to exercise that or any other right or a simi lar Event of
Default occurs later. All Seller's rights am remedies shall be CUIIlUlative. 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. B..tyer agrees that upon receiving notice
of the assignment fuyer shall be obligated to the Assignee of this Contract. which
Assignee shall have all of Seller's rights am remedies.
7. If any part of this Contract is held to be illegal. void or unenforceable. that
provision shall be deeJDed not to have been a part of this Contract. which shall
otherwise remain fully effective.
8. APPLICABLE LAW: This Agreement. whenever called upon to be construed. shall be
governed by the domestic internal laws of the Commonwealth of Pennsylvania except to
the extent supplemented. superseded or preempted by federal law.
3
9. OONSENT TO JURISDICTION. VENUE AND SERVICE: The parties to this Agreement consent am
agree that all legal proceedin;rs relating to the subject matter hereof shall be
maintained in the Court of Common Pleas of Cumberlam County, Pennsylvania, or, if
applicable, the United states District Court of the Middle District of Pennsylvania,
am all parties hereto consent am agree that jurisdiction am venue for such
proceedin;rs shall lie exclusively within said court. Service of process in any such
proceeding may be made by certified.mail, return receipt requested, directed to the
respective party at the address set forth above.
10. This Contract shall be birding upon the parties hereto, their heirs, successors,
assigns am legal representatives.
11. TIME IS OF '!HE :ESSENCE OF THIS OONI'RAC1'.
NOTICE: ANY J-K:lLDER OF THIS OONSUMER CREDIT COlolI'RAC1' IS SUBJH:T TO AIL CLAIMS AND DEFENSES
WHICH '!HE DEBTOR COULD ASSERT AGAINsr '!HE SEU.ER OF GCOOO OR SERVICES OBTAINED PURSUANr
HERETO OR WITH '!HE PROCEEI:B HERIDF. REXXlVERY HERillNDER BY '!HE DEBTOR SHAlL NOT EXCEED
AMOUNrS PAID BY '!HE DEBTOR HEREUNDER.
NOTICE TO BUYER: (1) 00 NOT SIGN THIS AGREEMENT BEroRE YOU REl\D IT OR IF IT CONTAINS ANY
BLANK SPACE. (2) YOU ARE ENTITIED TO A COMPLETELY FIlLED-IN OOPY OF THIS AGREDlENI'. (3)
UNDER '!HE LAW, YOU HAVE THE RIGHI' TO PAY OFF' IN ADVANCE '!HE RJLL AMOUNl' OOE AND UNDER
CERTAIN CONDITIONS TO OBTAIN A PARTIAL REFUND OF THE FIN7\NCE CHARGE.
BUYER(S) AQ(N()WLECGE(S) REX::EIVING A CCWLETED COPY OF THIS OONI'RAC1' AND Ilm:ND(S) TO
BE LIDAILY EOUND BY ITS TERMS.
BNm(S)o ~~
,~
I AGREE TO REPAY AIL AMOUNrS DUE ON THIS WAN IF THE OORROWER(S)/BUYER(S) FAIlS TO
00 00 IN AC<XlRDANCE WITH '!HE TERMS OF '!HE NO'IE:
STUDENT COOIGNER ,~"1l r:t~(-l ;t.jlc.'1A-~ll/~
TRANSC~T OF R STUDENT'S RECORD WILL NOT BE
RELEASED IF LOAN PAYMENTS TO THE COLLEGE ARE
IN ARREARS OR DEFAULT.
DA1E:
DIa<INOON OOLLEl3E
8 {'"L,I/~L--
BY
~0~
4
Exhibit G
DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - PLAN B
EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT
Date
September 29, 1992
1.
Seller:
Dickinson College, Carlisle, Pennsylvania 17013-2896
Teri L. and Jack F. Lefkowith
118 Evans Avenue
Wyomissing, PA 19610
Buyer(s):
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 Tracy L. Lefkowith
(hereinafter "Student") during his/her enrollment at Dickinson College during the 1992-93
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 tuition, room and board.
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUAL PERCENTAGE FINANCE CHARGE: AMOUNT FINANCED: TOTAL OF PAYMENTS: TOTAL SALE
RATE: . Dollar amount Amount of credit Amount paid by PRICE:
Cost of credit as credit will provided by Buyer as total of Total cost of
yearly rate cost Buyer Dickinson College all scheduled purcha.e on
payments credit, in-
Cluding down
payment of
$ 14,860.00
7.50 , $ 2,657.91 $ 6,500.00 $ 9,157.91 $ 21,360.00
aev 2/92
EXHIBIT "G"
Number of Payments
116
.Variable Rate:
Late Charge:
Prepayment:
Buyer's payment schedule will be as follows:
Amount of Payments
When Payments are Due
$78.95
Monthly commencing
until 5/28/92
10/28/92
The ANNUAL PERCENTAGE RATE disclosed above is a variable rate and may
change. The ANNUAL PERCENTAGE RATE may increase during the term of
this transaction if the prime rate of interest announced in the Wall
street Journal as of the close of business on June 30 of each calendar
year increases, and will be increased to the prime rate plus 1\. The
ANNUAL PERCENTAGE RATE will not increase more than once a year, and
the new interest rate will become effective on July 1 following the
increase, if any, in the prime rate of interest~ Any increase will
be in the form of higher payment amounts. If your cost of the Goods
and Services sold hereunder were $ 6.500.00 at 7.50 \ per annum
for ...1.16..- months, and the prime rate plus 1\ were increased to Fl '\0 \,
your regular monthly payments would increase to $ 82.36 . Further,
the ANNUAL PERCENTAGE RATE will not increase to more than 18\ or such
other rate as may be permitted under the Pennsylvania Goods and Services
Installment Sales Act.
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.
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-PAYHENT, DEFAULT
AND REQUIRED REPAYHENT BEFORE THE SCHEDULED DATE FOR REPAYMENT OF THE AMOUNT FINANCED.
III. ITEMIZATION OF AMOUNT FINANCED
l- Cash price of Goods and Services: $ 21,360.00
2. Total down payment. 14,860.00
3. Unpaid balance of cash price (1 - 2): 6,500.00
4. Amount paid to others on Buyer's behalf. 0
5. Amount Financed (3 + 4): $ 6,500.00
2
, 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 First
Wachovia, Inc. at the following address:
Firat Wachovia, Inc.
P.O. Box 70095
Charlotte, NC 28272-0095
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 involving 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. The Buyer agrees to
pay all attorney's fees and other reasonable collection costs and charges
necessary for the collection of any amount not paid when due.
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 right 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. APPLICABLE LAW: This Agreement, whenever called upon to be construed, shall be
governed by the domestic internal laws of the Commonwealth of Pennsylvania except
to the extent supplemented, superseded or preempted by federal law.
3
9. CONSENT TO JURISDICTION, VENUk AND SERVICE: The parties to this Agreement
consent and agree that all legal proceedings relating to the subject matter
hereof shall be maintained in the Court of Common Pleas of Cumberland County,
Pennsylvania, or, if applicable, the United States District Court of the Middle
District of Pennsylvania, and all parties hereto consent and agree that
jurisdiction and venue for such proceedings shall lie exclusively within said
court. Service of process in any such proceeding may be made by certified mail,
return receipt requested, directed to the respective party at the address set
forth above.
10. This Contract shall be binding upon the parties hereto, their heirs, successors,
assigns and legal representatives.
11. 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 BE LEGALLY BOUND BY ITS TERMS.
cY~ x:
5-4---< ';Z'
BUYER(S) :
4
I AGREE TO REPAY ALL AMOUNTS DUE ON THIS LOAN IF THE BORROWER(S)jBUYER(S) FAILS
TO DO SO IN ACCORDANCE WITH THE TERMS OF THE NOTE:
STUDENT COSIGNER \ -t"l'ZetlYo/..br),,,, L"cr1,--"
TRAKSC~T OF A STUDENT'S RECORD WILL NOT BE RELEASED
IF LOAN PAYMENTS TO TIlE COLLEGE ARE IN ARREARS OR
DEFAULT.
DATE: DICKINSON COLLEGE
Q-2<j-Cj-z..,
BY
~a-
.(
Exhibit H
DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - PLAN A
EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT
Date
August 26, 1993
1.
Seller:
Dickinson College, Carlisle, Pennsylvania 17013
Buyer(s) :
Teri L. and Jack F. Lefkowith
1531 Meadowlark Road
WyomissinQ, PA 19610
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 incurrea for goods and services to be provided and
rendered, as the case may be, to TraC'.y L. ~pf~ow;th
(hereinafter "Student") during his/her enrollment at D~ck~nson College during the 1~3 !}4
academic year, including tuition, room and board, books and supplies as herein state
(hereinafter the "Goods and Services").
The Goods and Services sh~11 include only tuition, room and board.
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Oisclosures Required by Federal Law
ANNUAL PERCENTAGE
RATE:
Coat of credit as
yearly rate
FINANCE CHARGE:
Dollar Amount
credit will
cost Buyer
AMOUNT FINANCED:
Amount of credit
provided by
Dickinson College
TOTAL OF PAYMENTS:
Amount paid by
Buyer as total of
all scheduled
payments
TOTAL SALE
PRICE:
Total cost of
purchase on
credit, in-
cluding down
payment of
Prior to repay-
ment: 11 on ,
During repay-
ment: 11.00 ,
$ 1,895.00
$ 4.000.00
$ 5,895.00
$ 18,590.00
$ 22,590.00
Rev 2/92
EXHIBIT "H"
Buyer's payment schedule will be as follows:
Number of Payments
Amount of Payments
When Payments are Due
8
$36.67
monthly commencing 9/28/93 , and continuing
until 4/28/94 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.
72
$76.14
monthly commencing 5/28/94 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.
Prepayment.
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.
Buyer may prepay the unpaid balance of the Amount Financed and any
FINANCg CHARGg due through the date of early payment, in full or in
part, without penalty.
Late charge:
Sgg SgCTION VI OF THg CONTRACT BgLOW FOR ANY ADDITIONAL INFORMATION ABOUT NON-PAYMENT,
DgFAULT 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:
$
22,590.00
18,590.00
4,000.00
2.
Total down payment:
3.
4.
Unpaid balance of cash price (1 - 2):
Amount paid to others on Buyer's behalf:
o
5.
Amount Financed (3 + 4).
$
4,000.00
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.
2
VI. ADDITIONAL PROVISIONS
. "
1. fuyer 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 First Wachovia. Inc. at the
following address:
First Wachovia. Inc.
P.O. Box 70095
Charlotte. NC 28272-0095
2. fuyer'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. fuyer 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 involving fraud or
dishonesty.
(f) insolvency or bankruptcy of any Buyer.
4. Upon or after the occurrence of any Event of Default. Seller will provide fuyer with
notice. by certified mail as required by law. addressed to fuyer's last known address
as shown on Seller's records. advising fuyer 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. The Buyer agrees to pay all attorney's fees and other
reasonable collection costs and charges necessary for the collection of any amount not
paid when due.
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 simi lar 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. fuyer agrees that upon receiving notice
of the assignment fuyer 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 deeJlled not to have been a part of this Contract. which shall
otherwise remain fully effective.
8. APPLICABLE LAW: This Agreement. whenever called upon to be constn.led. shall be
governed by the domestic internal laws of the Commonwealth of Pennsylvania except to
the extent supplemented. superseded or preempted by federal law.
3
9. CONSENT TO JURISDICITON, VENUE AND SERVICE: The parties to this l\greement consent am
agree that all legal proceediJ')J5 relatio;] to the subject matter hereof shall be
maintained in the Court of Common Pleas of CUmberlam County, Pennsylvania, or, if
applicable, the United States District Court of the Middle District of Pennsylvania,
am all parties hereto consent am agree that jurisdiction am venue for such
proceediJ')J5 shall lie exclusively within said court. Service of process in any such
proceedio;] may be made by certified,maiL return receipt requested, directed to the
respective party at the address set forth above.
10. This Contract shall be biming upon the parties hereto, their heirs, successors,
assigns am legal representatives.
11. TIME IS OF 1HE ESSENCE OF TIllS <X>NI'RACT.
NO!'ICE: ANY HOLDER OF TIllS <X>NSUMER CREDIT CONTRACT IS SUBJECI' TO AlL CLAIMS AND DEFD1SE3
WHICH 1HE DEBrOR COULD ASSERT AGAINST '!HE SELLER OF GOOI:6 OR SERVICES OBI'AINID PURSUANI'
HEREm OR WITII '!HE PROCEID3 HffiIDF. REroVERY HrnEXJNDER BY TIlE DEBrOR SHALL NO!' EXCEED
AMOUNI'S PAID BY 1HE DEBI'OR HEREUNDER.
NO!'ICE TO WYER: (1) 00 NO!' SIGN TIllS AGREEMENI' BEFORE YOU RE1\D IT OR IF IT CONI'AINS ANY
BLANK SPACE. (2) YOU ARE ENrITI..ED TO A OOMPLETELY FIlLED-IN COPY OF TIllS AGREEMEtIT. (3)
UNDER TIlE LAW. YOU HAVE TIlE RIGHI' TO PAY OFF IN ADVANCE 1HE roLL AMOUNl'DUE AND UNDER
CERTAIN CONDITIONS TO OBI'AIN A PARTIAL REFUND OF 1HE FINANCE CHARGE.
EmER(S) AaoowLEOOE(S) REX:EIVlOO A COMPLEI'ID COPY OF TIllS <X>NI'RACT AND I!ITEND(S) TO
BE LEl3AlLY OOUND BY ITS TERMS.
. //) . /).
EUYER(S): ~ 1'\.
~-::r
~
I AGREE TO REPAY AlL AMOUNI'S DUE ON TIllS LOAN IF 1HE B::lRROWrn (S) /WYER (S) FAIlS TO
00 SO IN AC<X>RDANCE WITII ~ TERMS OF '!HE ~ ' .
SIUDENr COSIGNER ,JAA.-c-...4' ~ ZhA-rtAJ..Y1.-.
TRANSCRIPTG8F A STUDE~I~. RECORD WILL NOT BE
RELEASED IF LOAN PAYMENTS TO THE COLLEGE ARE
IN ARREARS OR DEFAULT.
DATE:
DICKINSON <X>lLIDE
e 1Z-l.{:r3
BY
~~
4
EXIBIT I
DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - PLAN B
EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT
Date
August 30, 1993
1.
Seller:
Oickinson College, Carlisle, Pennsylvania 17013-2896
Teri L. and Jack F. Lefkowith
1531 Meadowlark Road
Wyomissing, PA 19610
Buyer (s) :
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 Te~4~t~-tef~e~4t" Tracy L.
(hereinafter "Student") during his/her enrollment at D~ckinson College during the 1q&~_q4
academic year, including tuition, room and board, books and supplies as herein state
(hereinafter the nGoods and Services").
The Goods and Services shall include only tuition, room and board.
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUAL PERCENTAGE
RATE: *
Cost of credit as
yearly rate
FINANCE CHARGE:
Dollar amount
credit will
cost Buyer
AMOUNT FINANCED:
Amount of credit
provided by
Dickinson College
TOTAL OF PAYMENTS:
Amount paid by
Buyer as total of
all scheduled
payments
7.00
,
$
1,061.64
$ 2.800.00
$ 3,861.64
TOTAL SALE
PRICE:
Total cost of
purchase on
credit, in-
cluding down
payment of
$ 19,790.00
$ 22,590.00
Rev 2/92
EXHIBIT "I"
Number of Payments
116
*Variable Rate:
Late Charge:
Prepayment:
Buyer's payment schedule will be as follows:
Amount of Payments
When Payments are Due
$33.29
Monthly commencing
until 5/28/03
9/28/93
The ANNUAL PERCENTAGE RATE disclosed above is a variable rate and may
change. The ANNUAL PERCENTAGE RATE may increase during the term of
this transaction if the prime rate of interest announced in the Wall
street Journal as of the close of business on June 30 of each calendar
year increases, and will be increased to the prime rate plus 1%. The
ANNUAL PERCENTAGE RATE will not increase more than once a year, and
the new interest rate will become effective on July 1 following the
increase, if any, in the prime rate of interest. Any increase will
be in the form of higher payment amounts. If your cost of the Goods
and Services sold hereunder were $ 2.800.00 at 7.00 'per annum
for --1Ul months, and the prime rate plus l' were increased to 8.00 'II,
your regular monthly payments would increase to $ ~4 74 . Further,
the ANNUAL PERCENTAGE RATE will not increase to more than 18' or such
other rate as may be permitted under the Pennsylvania Goods and Services
Installment Sales Act.
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.
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
l- Cash price of Goods and Services: $ 22.590.00
2. Total down payment: 19,790.00
3. Unpaid balance of cash price (1 - 2): 2,800.00
4. paid to others on 0
Amount Buyer's behalf:
5. Amount Financed (3 + 4): $ 2,800.00
2
lW. 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 First
Wachovia, Inc. at the following address:
First Wachovia, Inc.
P.O. Box 70095
Charlotte, NC 28272-0095
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 curee 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 involving 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. The Buyer agrees to
pay all attorney's fees and other reasonable collection costs and charges
necessary for the collection of any amount not paid when due.
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 right ana 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. APPLICABLE LAW: This Agreement, whenever called upon to be construed, shall be
governed by the domestic internal laws of the Commonwealth of Pennsylvania except
to the extent supplemented, superseded or preempted by federal law.
3
9. CONSENT TO JURISDICTION. VENUE 'AND 'SERVICE: The parties to this Agreement
consent and agree that all legal proceedings relating to the subject matter
hereof shall be maintained in the Court of Common Pleas of Cumberland County,
Pennsylvania, or, if applicable, the United States District Court of the Middle
District of Pennsylvania, and all parties hereto consent and agree that
jurisdiction and venue for such proceedings shall lie exclusively within said
court. Service of process in any such proceeding may be made by certified mail,
return receipt requested, directed to the respective party at the address set
forth above.
10. This Contract shall be binding upon the parties hereto, their heirs, successors,
assigns and legal representatives.
11. 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 (5) RECEIVING A COMPLETED COpy OF THIS CONTRACT AND INTEND(S)
ro.. ::::,:""," ~~'-
I AGREE TO REPAY ALL AMOUNTS DUE ON THIS LOAN IF THE BORROWER(S){BUYER(S) FAILS
TO DO SO IN ACCORDANCE WITH THE TERMS OF THE NOTE:
STUDENT COSIGNER ~~.O/' {L y:iL:;P4A' ( +1~'
TRANSCRIPT OF A STUDENT' S RECORD WILL NOT BE RELEASED
IF LOAN PAYMENTS TO THE COLLEGE ARE IN ARREARS OR
DEFAULT.
DATE: DICKINSON COLLEGE
8/'3,01 '13
BY
~~
4
. . .
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 docmnent
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. 9 4904 relating
to unsworn falsification to authorities, which provides that in knowingly make false averments, I may
be subject to criminal penalties.
Dickinson College
i
~
Thomas Meyer
Assistant Treasurer of Dickinson College
Dated: 7 It /03
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JUN 26 2003
"II n\.Mr
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2003-03106 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DICKINSON COLLEGE
VS
LEFKOWITH JACK L ET AL
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
LEFKOWITH JACK L
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of BERKS
County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On July
24th , 2003 , this office was in receipt of the
attached return from BERKS
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Berks County
So
18.00
9.00
10.00
46.36
.00
83.36
07/24/2003
MDW&O
~-~
R. 'Thomas Kl ine
Sheriff of Cumberland County
Sworn and subscribed to before me
this (, I? day of ~
.2~'U..3 A . D .
(I Q,~~~
~ Prothonotar1 I
SHERIFF OF BERKS COUNTY
633 Court Street, Reading, PA 19601
Phone: 610-478-6240 Main Fax: 610-478-6222 Sheriff Fax: 610-478-6072
Barry Jozwiak, Sheriff
Eric J. Weaknecht, Chief Deputy
AFFIDAVIT OF SERVICE
DOCKET NO. 03-CIV-3106
COMMONWEALTH OF
PENNSYLVANIA:
COUNTY OF BERKS
Personally appeared before me, RlCKY SCHLOUCH, Deputy for Barry J. Jozwiak, Sheriff of Berks
County, 633 Court Street, Reading, Pennsylvania, who being duly sworn according to law, deposes and says
that on JULY 10, 2003 at 10:30 AM, he served the annexed COMPLAINT IN CIVIL ACTION upon JACK
F. LEFKOWITH, within named defendant, by handing a copy thereof to MELODY DYNES, ADULT
MEMBER OF HOUSEHOLD, at 1531 MEADOWLARK ROAD, WYOMISSING, Berks County, Pa., and
made known to defendant the contents thereof. /? /. ~
~E~Rl~:BERKS CO., PA
Sworn and subscribed before me
this 21s day of JULY, 2003
Service made as set forth above.
NOTARIAL SEAL I
TAMMY RODRIGUEZ. Notary Public
Reading, Ber"s County. PA
My Commission Expires 10.06-2003
K::-e~, () (4J
SHERlFF OF BERKS COUNTY, PA
Sheriff's Costs in Above Proceedings
$ DEPOSIT
$ ACTUAL COST OF CASE
$ AMOUNT OF REFUND
All Sheriff's Costs shall be due and payable when services are performed, and it shall be lawful for him to
demand and receive from the party instituting the proceedings, or any part liable for the costs thereof, all
unpaid sheriff's fees on the same before he shall be obligated by law to make return thereof.
_Sec. 2, Act ofJune 20, 1911, P.U 1072
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2003-03106 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DICKINSON COLLEGE
VS
LEFKOWITH JACK L ET AL
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
WEISS TRACY L F/K/A TRACY L
LEFKOWITH
but was unable to locate Her
in his bailiwick. He therefore
deputized the sheriff of BERKS
County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On July
24th , 2003 , this office was in receipt of the
attached return from BERKS
Sheriff's Costs:
Docketing
Out of County
Surcharge
6.00
.00
10.00
.00
.00
16.00
07/24/2003
MDW&O
So answers_;,,,>,.,,..... ,,_ // ___
Re~~~~::'
Sheriff of Cumberland County
Sworn and subscribed to before me
this (, <r::
J-ov3
(},,..
day of ()r'M'
A.D.
Q ~(I!t..- .UJJ:;.
Prothondtary
SHERIFF OF BERKS COUNTY
633 Court Street, Reading, PA 19601
Phone: 610-478-6240 Main Fax: 610-478-6222 Sheriff Fax: 610-478-6072
Barry Jozwiak, Sheriff
Eric J Weaknecht. Chief Deputy
AFFIDAVIT OF SERVICE
DOCKET NO. 03-CIV-3l06
COMMONWEALTH OF
PENNSYLVANIA:
COUNTY OF BERKS
Personally appeared before me. CYNTHIA TOOLE, Deputy for Bany J. Jozwiak, Sheriff of Berks County,
633 Court Street. Reading, Pennsylvania, who being duly sworn according to law, deposes and says that on
JULY 10, 2003 at 9:25 AM, he served the annexed COMPLAINT IN CIVIL ACTION upon TRACY L.
WEISS, F/K/A TRACY L. LEFKOWITH, within named defendant, by handing a copy thereof to HER
PERSONALLY, at 5 SYCAMORE DRIVE, READING, EXETER TOWNSHIP, Berks County, Pa., and
made known to defendant the contents thereof.
~~FF~O"PA
Sworn d subscribed before me
S11 day of JULY,2 3
-
.,PA
Service made as set forth above.
s,,/!:e~,
()
~
SHERIFF OF BERKS COUNTY, PA
Sheriff's Costs in Above Proceedings
$ 75.00 DEPOSIT
$ 46.36 ACTUAL COST OF CASE
$ 28.64 AMOUNT OF REFUND
All Sheriff's Costs shall be due and payable when services are performed, and it shall be lawful for him to
demand and receive from the party instituting the proceedings, or any part liable for the costs thereof, all
unpaid sheriff's fees on the same before he shall be obligated by law to make return thereof.
_Sec. 2, Act ofJune 20, 1911, P.U 1072
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2003-03106 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DICKINSON COLLEGE
VS
LEFKOWITH JACK L ET AL
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
LEFKOWITH TERI L
but was unable to locate Her
in his bailiwick. He therefore
deputized the sheriff of BERKS
County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On July
24th , 2003 , this office was in receipt of the
attached return from BERKS
Sheriff's Costs:
Docketing
Out of County
Surcharge
6.00
.00
10.00
.00
.00
16.00
07/24/2003
MDW&O
So answe: .
p:;~~::..-~~
~--.-,~.-
R. Thomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
this (, ~ day of QA'r
;L 0'1>3 A. D .
n 0. ~1.~ ,~'
~ Prothonotary .
a~_~~RTNJ\!Ll~
& '7c
E- ~
"'" 02:
.- 'l' n
~*-' ~ .t>j
~ ~
',f,fS :,SR;il7
SHERIFF OF BERKS COUNTY
633 Court Street, Reading, PA 19601
Phone: 610-478-6240 Main Fax: 610-478-6222 Sheriff Fax: 610-478-6072
Barry Jozwiak, Sheriff
EricJ. Weaknecht, Chief Deputy
AFFIDAVIT OF SERVICE
DOCKET NO. 03-CIV-3106
COMMONWEALTH OF
PENNSYLVANIA:
COUNTY OF BERKS
Personally appeared before me, RICKY SCHLOUCH, Deputy for Bany J. Jozwiak, Sheriff of Berks
County, 633 Court Street, Reading, Pennsylvania, who being duly sworn according to law, deposes and says
that on JULY 10, 2003 at 10:30 AM, he served the annexed COMPLAINT IN CIVIL ACTION upon TERI
L. LEFKOWITH, within named defendant, by handing a copy thereof to MELODY DYNES, ADULT
MEMBER OF HOUSEHOLD, at 1531 MEADOWLARK ROAD, WY ISSING, Berks County, Pa., and
made known to defendant the contents thereof. J ~~
RIFF OF BERKS CO., PA
d subscribed before me
day of JULY, 2003
Service made as set forth above.
NOTARIAL SEAL
TAMMY RODRIGUEZ, Notary Public
Reading, Berks County, PA
My Commission E,p"es 10-Q6-2003
So Answers,
~O
,rJ.-/
SHERIFF OF BERKS COUNTY, PA
Sheriff's Costs in Above Proceedings
$ DEPOSIT
$ ACTUAL COST OF CASE
$ AMOUNT OF REFUND
All Sheriff's Costs shall be due and payable when services are performed, and it shall be lawful for him to
demand and receive from the party instituting the proceedings, or any part liable for the costs thereof, all
unpaid sheriff's fees on the same before he shall be obligated by law to make return thereof.
_Sec. 2, Act ofJune 20, 1911, P.U 1072
F:\FILES\DA T AFll.E\Dickinson College 7619\DickinsonCollegeCoUections7619C\Do<.:urnentsl I 07.stip I/mai
Created: 1l/J3/0211:27:29PM
Revised; 12/0Jl0303:15:36PM
7619C.J07
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03-3106
CIVIL ACTION-LAW
JACK L. LEFKOWITH & TERI L.
LEFKOWITH, H/W, and TRACY L.
WEISS, flk/a TRACY L. LEFKOWITH,
Defendants
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 Defendants Jack L. Letkowith, Teri L.
Letkowith and Tracy L. Wiess, f/k/a Tracy L. Letkowith, who stipulate and agree as follows:
1. Pa. R.C.P. 1037 (c) provides that in all cases, the Court, on motion ofa party, may enter
an appropriate judgment against a party upon admission.
2. Defendants agree and admit that Judgment should be entered against them in favor of
Plaintiff in the amount of$51,891.28 plus interest accruing at 5.75% from date of judgment and costs
of suit.
3. The parties agree that the Court, upon motion of Plaintiff, may enter Judgment pursuant
::hidu~ti~n wi 0
J:,tf~~ow'
153 l Meado rk Road
Wyomissing, PA 19610-2818
Date:
~~~~oJ ,jJj# fL
1531 Meadowlark Road
Wyomissing, PA 19610-2818
Date: I ~ ) I Ii' 103
By I~ //1 )VJ
Tracy Weiss /'
f/k/a Tracy Letkowith
5 Sycamore Drive
Reading, ~ 19606 ---!J ( J,), ,'..., ~
Date: ~~ r:Y.- \.)\JU..A/ r )
Defendants
By
avid R. Galloway, ire
Martson DearaorffWilliams & Otto
Ten East High Street
Carlisle, P A 17013-3093
(717) 243-3341
Attorney for Pllaintt' f[
Date: I Z. 2.1- \,)~
5. Upon payment ofthe Judgment amount, Plaintiff shall promptly have the Judgment
marked satisfied in the Office of Prothonotary.
6. Nothing herein shall be construed to prevent Plaintiff from transferring the Judgment
to other counties or states or to otherwise limit its rights as a judgment creditor.
7. Nothing herein shall be construed to prevent Plaintiff from filing a separate action for
additional collection or attorneys' fees if Defendants breach any provision of this Settlement
Agreement.
IN WITNESS WHEREOF, the parties hereto have executed this Settlement Agreement the
date under the signature of each.
WITNESS: ThO~7~
(Seal)
DATE:
WITNESS:
r#~ (Seal)
Ja E. Lefkowi
DATE:
WITNESS:
4iJ'~f~ /(" . 1~
\l..,)edJ.}
Teri 1. Lefkowit
DATE:
WITNESS:
JM ~ (Seal)
Tracy 1. W~
f1kIa Tracy 1. Lefkowith)
CERTIFICATE OF SERVICE
I, Martha-Anne Then, an authorized agent of Martson Deardorff Williams & Otto, hereby
certifY that a copy of the foregoing Order was served this date by depositing same in the Post
Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Lisa Marie Ciotti, Esquire
501 Park Road North
Box 6263
Wyomissing, PA 19610
MARTS ON DEARDORFF WILLIAMS & OTTO
By / . ~~Mh_. 12",,-- ~,.,../
Z~~e Then
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: January 15, 2004
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F,IFlLES\DA TAFILE\Dickinson College 7619lDickinsonCollegeCollections7619C\CuITentl 107.ord\mai
Created: 8/5/03 1:27PM
Revised: 1I15104209PM
7619CI07
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
o
v.
NO. 03-3106
CIVIL ACTION-LAW
JACK L. LEFKOWITH & TERI L.
LEFKOWITH, H1W, and TRACY L.
LEFKOWITH,
Defendants
JURY TRIAL OF TWELVE DEMANDED
J. ORDER OF COURT
AND NOW, this 2.'3 fday of January, 2004, upon consideration of the attached Stipulation
and Agreement for Entry of Judgment, judgment is hereby entered in favor of Plaintiff Dickinson
College and against Defendants, Jack L. Lefkowith, Teri L. Lefkowith and Tracy Weiss, formerly
known as, Tracy Lefkowith, in the amount of$51,891.28 plus costs of suit and interest accruing at
5.75% per annum from date of judgment. Prothonotary is directed to enter and index this judgment
accordingly.
for Plaintiff:
l.l5'avid R. Galloway, Esquire
Ten East High Street
Carlisle, P A 17013
BYT;;J:(! o~
, L/ -'7
, J.
for Defendants:
vLisa Marie Ciotti, Esquire
SOl Park Road North
Box 6263
Wyomissing, PA 19610-6263
7~
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r? r:'T
f:\FlLES\DA T AFlLE\Dickinson College 761 9\DickinsonCollegeColle.;tioos76 I 9C\DocumenlS\1 07 ,stip Ilmai
Created: 11I13/0211:27:29PM
Revised: 12101l0303:15:36PM
7619C107
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03-3106
CIVIL ACTION-LAW
JACK L. LEFKOWITH & TERI L.
LEFKOWITH, HlW, and TRACY L.
WEISS, f/k/a TRACY L. LEFKOWITH,
Defendants
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 Defendants Jack L. Lefkowith, Teri L.
Lefkowith and Tracy L. Wiess, f/k/a Tracy L. Lefkowith, who stipulate and agree as follows:
1. Pa. R.C.P. 1037 (c) provides that in all cases, the Court, on motion ofa party, may enter
an appropriate judgment against a party upon admission.
2. Defendants agree and admit that Judgment should be entered against them in favor of
Plaintiff in the amount of$51,891.28 plus interest accruing at 5.75% from date of judgment and costs
of suit.
3. The parties agree that the Court, upon motion of Plaintiff, may enter Judgment pursuant
to this Stipulation wi 0 issuance of a Rule to Show Cause, and witho furt e roceedings or notice.
By d - . By
J:~1:&ow' avid R. Galloway, ire
1531 Meado rk Road Martson Deardorff Williams & Otto
Wyomissing, P A 19610-2818 Ten East High Street
Date: Carlisle, PA 17013-3093
~ / I~ iJ, (717)243-3341
By (,.0 A, Iv ;Jj f.I..-- Attorney for p/laintt'ff
Ten . e~owtih' Date: \2.. 2.1-- us.
1531 Meadowlark Road
Wyomissing, PA 19610-2818
Date: I '7... ) I Ii' 103
By /~ //1 )0:>
Tracy Weiss -;'
f/k/a Tracy Lefkowith
5 Sycamore Drive
Reading,~ 19606 ---iJ{ /,). . '-....~
Date: ~~ r::/.--1,AlL.l/V r )
Defendants
5. Upon payment of the Judgment amount, Plaintiff shall promptly have the Judgment
marked satisfied in the Office of Prothonotary.
6. Nothing herein shall be construed to prevent Plaintiff from transferring the Judgment
to other counties or states or to otherwise limit its rights as a judgment creditor.
7. Nothing herein shall be construed to prevent Plaintiff from filing a separate action for
additional collection or attorneys' fees if Defendants breach any provision of this Settlement
Agreement.
IN WITNESS WHEREOF, the parties hereto have executed this Settlement Agreement the
date under the signature of each.
WITNESS:
ThO~~e-- (Seal)
DATE:
WITNESS:
rltffP (Seal)
Ja E. Lefkowi
DATE:
WITNESS:
~J-<il, ftL)II., (Seai)
Teri 1. Lefkowit
DATE:
WITNESS:
:1M d-~ (Seal)
Tracy 1. W~
f/kla Tracy 1. Lefkowith)
CERTIFICATE OF SERVICE
I, Martha-Anne Then, an authorized agent of Martson Deardorff Williams & Otto, hereby
certify that a copy of the foregoing Order was served this date by depositing same in the Post
Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Lisa Marie Ciotti, Esquire
SOl Park Road North
Box 6263
Wyomissing, PA 19610
MARTSON DEARDORFF WILLIAMS & OTTO
By 0 ~~"- tJ.4<C V/r.'-"/
M~~f:L Then
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: January IS, 2004
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Created: 2/13103 ~UQ39 AM
Revised:4/28/0525839PM
7619C102
David R. Galloway, Esquire
MARTS ON DEARDORFF WILLIAMS & OTTO
Ten East High Street
Carlisle, P A 17013-3093
(717) 243-3341
Attorneys for Plaintiff
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03-3106
CIVIL ACTION-LAW
JACK 1. LEFKOWITH & TERI 1.
LEFKOWITH, H/W, and TRACY 1.
LEFKOWITH,
Defendants
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.
ILLIAMS & OTTO
By
David R. Galloway
1.D. Number 87326
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Plaintiff
Date: April 28, 2005
.
CERTIFICATE OF SERVICE
I, Jean Taylor, an authorized agent for Martson DeardorffWiUiams & Otto, hereby certify
that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at
Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Miguel Debon, Esquire
501 Park Road North
Box 6263
Wyomissing, PA 19610-6263
Mr. Jack Lefkowith
Ms. Teri L. Lefkowith
1531 Meadowlark Road
Wyomissing, PA 19610-2818
Ms. Tracy Weiss
f/kla Tracy Lefkowith
5 Sycamore Drive
Reading, PA 09606
MARTSON DEARDORFF WljS & OTTO
~L
aylor
Te .. ast High Street
Car isle, P A 17013
(717) 243-3341
D.ted: April 28, 2005
------
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