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HomeMy WebLinkAbout03-3261 F:\F1LES\DA T AFlLEIDickinson College 7619IDickinsonCollegeCollections7619ClDocuments\ lSO,com Created4128/03l:54:03PM Revised: 7/9/033:22:15 PM v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. .03 - J ;;"Cs, { CJVIL ACTION-LAW DICKINSON COLLEGE, Plaintiff JOSEPH L. DONAHUE, Defendant 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 obj ections 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 D~S & OTTO ~ David R. Galloway, Esquire J.D. Number 87326 Ten East High Street Carlisle, P A 17013 (717) 243-3341 l Attorneys for Plaintiff Date: '1 If /&3 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 63 3;2.t,/ ~ 7~ CJVIL ACTION-LAW DICKINSON COLLEGE, Plaintiff JOSEPH L. DONAHUE, Defendant JURY TRIAL OF TWELVE DEMANDED COMPLAINT AND NOW, comes Plaintiff Dickinson College by and through its attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and hereby avers as follows: 1. Plaintiff Dickinson College is a Pennsylvania educational institution and nonprofit corporation with its principle place of business at West Street, Post Office Box 1773, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant Joseph L. Donahue is an adult individual with a last known address of 481 Stafford Road, #3, Mansfield Center, Connecticut 06250-1426. 3. On or about August 28, 1995, Defendant entered into a Promissory Note - Federal Perkins Loan Program (Note #1) with Plaintiff. A copy of Note #1 is attached hereto as Exhibit "A." 4. Note #1 provided for the financing of$2,000.00, plus interest and costs by Defendant on his own behalf, for educational services and benefits at Plaintiffs institution. 5. On or about September 18,1996, Defendant entered into an additional Promissory Note - Federal Perkins Loan Program (Note #2) with Plaintiff. A copy of Note #2 is attached hereto as Exhibit "B." 6. Note #2 provided for the financing of$2,000.00 plus interest and costs by Defendant on his own behalf, for educational services and benefits at Plaintiff s institution. 7. On or about September 26,1997, Defendant entered into an additional Promissory Note - Federal Perkins Loan Program (Note #3) with Plaintiff. A copy of Note #3 is attached hereto as Exhibit "C." 8. Note #3 provided for the financing of$l ,000.00 plus interest and costs by Defendant on his own behalf, for educational services and benefits at Plaintiff s institution. 9. On or about September 9, 1998, Defendant entered into an additional Promissory Note - Federal Perkins Loan Program (Note #4) with Plaintiff. A copy of Note #4 is attached hereto as Exhibit "D." 10. Note #4 provided for the financing of$l ,000.00 plus interest and costs by Defendant on his own behalf, for educational services and benefits at Plaintiff s institution. 11. On or about December 1, 1998, Defendant entered into an additional Promissory Note - Federal Perkins Loan Program (Note #5) with Plaintiff. A copy of Note #5 is attached hereto as Exhibit "E." 12. Note #5 provided for the financing of$l ,000.00 plus interest and costs by Defendant on his own behalf, for educational services and benefits at Plaintiff s institution. 13. Note #1, Note #2, Note #3, Note #4 and Note #5 are funds created under Part E of Title JV of the Higher Education Act of1965 as amended, (hereinafter the "Act") and are subject to the Act and the Federal Regulations issued under the Act. 14. As provided in the Act, Plaintiff acts in a fiduciary capacity in the handling, disbursing and collecting of funds associated with the programs under the Act. 15. The total principal for Note #1, Note #2, Note #3, Note #4 and Note #5 is $7,000.00. 16. Note #1, Note #2, Note #3, Note #4 and Note #5 grant Plaintiff reasonable collection and attorney's fees which Plaintiff has calculated to be $1,050.00. 17. As of April 3, 2003, the principal and interest due and payable by Defendant to Plaintiff was $8,096.25, plus interest accruing thereafter at $.96 per day from April, 3, 2003. 18. The outstanding balance of $8,096.25 represents the total and actual overdue value ofthe financing provided to Defendant under Note #1, Note #2, Note #3, Note #4 and Note #5 for which Defendant has yet to pay. 19. Plaintiffhas fulfilled, performed and complied with all obligations and conditions of Note #1, Note #2, Note #3, Note #4 and Note #5. COUNT I BREACH OF CONTRACT 20. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 19 of this Complaint. 21. Defendant breached the expressed and implied obligations, conditions and terms of agreement of Note #1, Note #2, Note #3, Note #4 and Note #5 by failing to pay the amounts financed therein. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of$8,096.25, plus interest accruing at $.96 per day from Apri13, 2003, collection and attorneys' fees in the amount of $1 ,050.00 and costs of suit. COUNT II IN QUANTUM MERUIT 22. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 21 of this Complaint. 23. Having requested Plaintiff to loan money, and doing so to the benefit of Defendant, Defendant became liable to Plaintiff for said money. 24. Defendant has been unjustly enriched by accepting said money without paying Plaintiff reasonable compensation therefor. 25. Defendant is liable to Plaintiff and/or has been unjustly enriched in the amount of $8,096.25, plus interest accruing at $.96 per day from April 3, 2003. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of$8,096.25, plus interest accruing at $.96 per day from April 3, 2003, collection and attorneys' fees in the amount of$1,050.00 and costs of suit. Date: 7/1/03 David R. Galloway J.D. Number 87326 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff Exhibit A PERKINS (NDSLI TRUTH-IN-LENDING STATEMENT DICKINSON 'COLLEGE \ Account Number 00271-000-1054 Name of Borrower Joseph Lawrence Donahue Address 4Rl Srnffnro Ro. Mansfield Center, CT 06250 ANNUAL PERCENTAGE RAn: AMOUNT FINANCED The cost of your credit as a yearly rate. The amount of credit provided to you. Prior to repayment During repayment o % 5 % $ 2,000.00 I Itemization of the Amount Financed: $ 2,000.00 Amount given directly to you. I Late Charge: If a payment is late, you may be charged: $1.00 for the first late payment, and $2.00 for each subsequent late payment if this loan is payable monthly, $3.00 for each late payment if this loan is payable bimonthly, $6.00 for each late payment if this loan is payable quarterly. Prepayment: If you payoff early, you will ~ have to pay a penalty. See your promissory note for any additional information about nonpayment, de- fault, any required repayment in full before the scheduled date, and pre- payment, TIlE BORROWER ACKNOWLEDGES RECEIPT OF AN EXACT COPY OF THIS STATEMENT, STUDENT 1" I j) /: ./ BORROlolER ,fl-J;-fJOfi(7 (l"na~ DATE fJl?Jl q ') INSTITurIONAL REPRESENTATIVE ~ DAn: 8- -z b -,;)' EXHIBIT "A" 00273-000-00-3054 -09 / Promissory Note-Federal Perkins Loan Pro~ram [Any bracketed clause or paragraph may be included at option of institution.). . I, Joseph Lawrence Donahue ,promise to pay to D1 ck 1 nson Co lleQe (hereinafter called lbe Institution), located at Car' is' e. PA 17013-2896 , lbe sum of lbe amounts that are advanced to me and endorsed in lbe Schedule of Advances set forth below. I promise to pay all reasonable collection costs, including attorney fees and other cbarges, Decessary for the collection of any amount not paid when due. I further understand and agree that: I. Oeoeral (1) ADPlicable Law. All sums advanced under this note are drawn from a fund created under Part E of TiUe IV of the Higher EducatioD Act of 1965, as amended (hereinafter called lbe Act), and are subject to lbe Act and lbe Federal regulations issued under lbe Act. The term. of this note shall be interpreted in accordance with the Act and Federal regulatioDS, copies of which are to be kept by the Institution. (2) Procedures for Receivin2. Deferment. Cancellation. Of Forbearance. 1 understand that. to receive a deferment, caucellation, or forbearance, I must request the deferment, cancellation, or forbearance in writing from the Institution and must submit to the Institution any documentation required by the Institution to prove that I qualify for the deferment. cancellation. or forbearance. I further undentand that. if I am eligible for deferment, cancellation, or forbearance under Articles VI through XIV, I am responsible for submitting the appropriate requests on time. I further understand that I may Jose my deferment. cancellation. and forbearance benefits if I fail to file my request on time. n. Interest Interest shall accrue from the beginning of lbe repayment period and shall be at lbe ANNUAL PERCENTAGE RATE OF nvE PERCENT (5CJo>) on the unpaid balance, except that no interest shall accrue during any deferment period described in Article vn. m. Reoavment (1) I promise to repay the principal and the interest that accrues on it to the Institution over a period beginning nine (9) months after the dale I cease to be at least a balf-time regular student at an institution of bigher education, or at a comparable institution outside the United States approved for this purpose by the United States Secretary of Education (hereinafter called the Secretary). and ending ten (10) years later, unleu lbat period i. [.hortened under paragraph m(S), or] extended under paragrapb. m(4), m(7) (extensions), Vll(l), or Vll(3) (deferments). (2) Upon my written request, the repayment period may start on a date earlier than the ODe indicated in paragraph m(l). (3)(A) I promise to repay the principal and interest over the course of the repayment period in equal monthly. bimonthly. or quarterly iustallments, as determined by the Institution. I understand that, if my installment payment for all the loans made to me by the InstitutioD is not a multiple of $S, the Institution may round that payment to the next highest dollar amount that is a multiple of $S. (9) Notwithstanding paragraph m(3)(A), upon my written request, repayment may be made in graduated installments in accordance with a schedule approved by the Secretary. (4) Notwithstanding paragraph mo), if I qualify as a low.income individual during the repayment period, the Institution, upon my written request, may extend the repayment period for up to an additional ten (10) years and may adjust any repayment schedule to reflect my income. [(S)(A) If lbe monlbly rate lbat would be e.tablished under paragraph m(l), or lbe total monlb1y repayment rate of principal and inter... on all my Federal Perkins Loans, including lbi. loan, i. Ie.. lban $40.00 per monlb, 1 shall repay lbe principal and interest on this loan at lbe rate of $40.00 per monlb (which include. bolb principal and intere..). (5)(8) If I have received Federal Perkins Loans from other institutions and the total monthly repayment ra!e on those loans i. less than $40.00 lbe $40.00 montbly payment established under subparagrapb m(S)(A) include. lbe amounts 1 owe on all my outstanding Federal Perkins Loans, including lbose received from olber institutions. The portion of lbe $40.00 monlbly payment lbat will be applied to this loan will be lbe difference between $40 . 00 and lbe total of lbe amounts owed at a monlbly rate on my olber Federal Perkins Loans. (6) The .Institution may permit me to pay Ie.. lban lbe rate of $40.00 per monlb for a period of not more lban ono (1) year where necessary to avoid hardship to me unless that action would extend the repayment period in paragraph m(l).] (7) The Institution may, upon my written request, reduce any scheduled repayments or extend the repayment period indicated in paragraph m(l), if. in its opinion, circumstances sucb as prolonged illness or unemployment prevent me from making the scbeduled repayments. However. interest shall continue to accrue. IV. PreDavment (1) I may, at my option and without penalty, prepay all or any part of the principal, plus any accrued interest thereon. at any time. (2) Amounts I repay in the academic year in which the loan was made and the initial grace period has not ended will be used to reduce the amount of the loan and will not be considered a prepayment. (3) If I repay amounts during the academic year in whicb the Joan was made and the initial grace period ended, only thOle amounts in exceu of the amount due for any repayment period shall be considered a prepayment. (4) If, iD an academic year other than the award year in wbich the loan was made, I repay more than the amount due for an installment, the excess will be used to repay principal unless I designate it as an advance payment of the next regular installment. V. Default (1) The Institution may. at its option. declare my loan to be in default and may demand immediate payment of the entire unpaid balance of the loan, including principal. interest, late charges, and collection costs, if- (A) I do not make a scheduled payment when due under the repayment schedule established by the Institution; and (B) I do not submit to the Institution. 00 or before the date on wbich payment is due. documentation that I qualify for a deferment, cancellation, or forbearance as described in Articles VI. vn, vm, IX, X. XI. XII. XIII, or XIV of this agreement. (2) I understand that the Institution may disclose to credit bureau organizations the amount of loans made to me, along with other relevant Page I of 4 Federal Perkins/1uly 1993 information. (3) I understand that. if I default on my loan. the Institution may disclose that I bave defaulted, along with other relevant information, to credit bureau organizatioDl. , (4) Further, I underltaD.d that. if I default on my loan uad the loa.o is assigned to the Secretary for collection, the Secretary may disclose that I have defaulted, along with other relevant information. to credit bureau organizations. (5) I understand that. if I default on my loan. I will lose my right to forbearance. (6) I understand that. if I default on my loan. I will lose my right to defer repayments. (T) I understand that. if the Institution accelerates the loan under paragraph V(I), I will lose my right to receive a cancellation of a portion of my loan for any service described in Articles VIII. IX. X, XI, xn. xm. or XIV performed after the date the Institution accelerated the loan. (8) I under5WId that failure to pay this obligation under the terms agreed upon win prevent my obtaining additional student financial aid authorized under Title IV of the Higher Education Act of 1965. as amended. until I have made arrangements that are satisfactory to the Institution or the Secretary regarding the repayment of the loan. VI. Forbearance (1) I understand that, upon making a properly documented written request to the Institution, I am entitled to be granted forbearance of principal and interest or principal ooly, renewable at 12-month intervals. for a period not to exceed three years. if- (A) My debt burden equals or exceeds 20 percent of my gross income; or (8) The Institution determines that I qualify for other reasons. VII. Deferment (1) I understand that. upon ma1c.ing a properly documented written request to the Institution. I may defer making scheduled installment payments and will not be liable for any interest that might otherwise accrue during the following periods: (A) For any period that I am- (i) Enrolled and in attendance u a regular student in at least a ba1f~time COUTse of study at an eligible institutioD; (ii) Enrolled and in attendance as a regular student in a course of study that is part of a graduate fellowship program approved by the Secretary; (Hi) Engaged in graduate or p05l-graduate fellowship-supported study (sucb as a Fulbright grant) outside the United. States; or (iv) Enrolled and in attendance in a course of study that is part of a rehabilitation training program for disabled. individuals approved. by the Secretary. (B) For any period that I am engaged in service described in Articles vm. IX, X, XI. xn. xm. or XIV of this agreement. (C) For a period not to exceed three (3) years during which- (i) I am seeking and unable to find full.time employment; or (ii) For any reason that my Institution determines bas caused or will cause me to have an economic hardship. (2) I understand that I am not eligible for a deferment under paragraph (V1I)(I)(A) while I am:serving in a medical internship or residency program. (3) 1 undentand that I may continue to defer making scheduled installment payments and win not be liable for any interest that JDight otherwise accrue for a six (6) month period immediately following the expiration of any deferment provided in paragraph VU(l). vm. TeachiDl~: Cancellation (1) ] undentand that, upon making a properly documented written request to the Institution, I am entitled to have up to 100 peRent of the amount of thi. loan plus the interest thereon canceled if I perform qualifying service after the period for which I received the loan- (A) As a fulJ.time teacher in a public or other nonprofit elementary or secondary school in the school district of a local educational agency that is eligible in such year of service for funds under Chapter 1 of the Education Consolidation and Improvement Act of 1981, as amended. and which has been designated by the Secretary (after consultation with each State Department of Education) in accordance with the provisions of section 465(a)(2) of the Act as a scbool with a high concentration of students from low.lncome families. An offic:ial Direetory of designated low-income schools is pUblished annually by the St(:retary; (B) As a full.time special education teacher (including teacbers of infants. toddlers, chHdren, or youth with disabilities) in a public or other nonprofit elementary or secondary school system, or as a full-time qUalified professiOnal provider of early intervention services in a public or other nonprofit program under public supervision by the lead agency as authorized in section 676(b)(9) of the Individuals With Disabilities Education Act; or (C) As a full-time teacher of mathematics. science, foreign languages, bilingual education, or any other field of expertise that is determined by the State Department of Education to have a shortage of qualified teachers. (2) A portion of this loan will be canceled for each completed year of leacbing service at the following rates: (A) 15 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for each of the first and leCond complete academic years of that teaching service; (8) 20 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for each of the third and fourth complete academic years of that teaching service; and (C) 30 perc:ent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for the fifth complete academic year of that teaching service. IX. Head Start Cancellation (1) I understand that, upon making a properly documented written request to the Institution, I am entitled to have up to 100 percent of the amount of this loan plus the interest thereon canceled if I perform qualifying service after the period for which I received the loan as a full-time staff member in a Head Start program if- (A) That Head Start program is operated for a period that is comparable to a fun school year in the locality; and Page 2 of 4 Federal Perkins/July 1993 (B) My salary is not mOre than the salary of a comparable employee of the local educational agency. (2) This loan will be canceled at the rate of 15 percent of the total principal amount of the loan plus interest on the unpaid balam::e accNmg during that year for each complete school year or equivalent period of service in a Head Start program. (3) Head Start is a preschool program carried out under the Head Start Act. X. M.ilitarv Cancellation (1) I understand that, upon making a properly documented written request to the Institution, I am entitled to bave up to 50 percent of the principal amount of this loan plus the interest thereon canceled if I serve as a member of the Armed Forces of the United States in an area of hostilities that qualifies for special pay under section 310 of Title 37 of the United Stales Code. (2) This loan will be canceled at the rate of 12 1/2 percent of the total principal amount of the loan plus interest on the unpaid balance accruing duriDg that year for eacb complete yesu of such qualifying service after the period for which I received the loan. XI. Volunteer Service Cancellation (1) I understaDd that, upon makiDg a properly documented written request to the Institution, I am entitled to have up to 70 percent of the amount of this loan plus the interest thereon canceled if I perfoCIll qualifying service after the period for which I received the loan- (A) N a volunteer under the Peace Corps Act; or (B) AA a volunteer under the Dolllestic Volunteer Service Act of 1973 (ACTION programs). (2) This loan will be canceled at the following rates: (A) 15 percent of the total principal amount of the loan plus interest on the unpaid balance accNing during that year for each of the first atui second twelve (12) month periods of volunteer service completed; and (B) 20 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for each of the third. 8Dd fourth twelve (12) month periods of volunteer service completed. XU. Law Enforcement or Correctiol1$ Officer Cancellation (1) I understand that. upon making a properly documented written request to the Institution, I am entitled to have up to 100 percent of the amount of this loan plus the interest thereon canceled if I perform qualifying service after the period for which I received the loan- (A) As a full.time law enforcement officer for service to an eligible local, State, or Federal law enforcement ageocy; or (B) As a full.time corrections officer for service to an eligible local. State, or Federal corrections agency. (2) A portiOD of this loan will be canceled for each completed year of law enforcement or correctioDl service at the following rates: (A) IS percent of the total principal amount of the loan plus interest on the unpaid balance accroing during that year for each of the first ud leCood complete years of that service; (B) 20 percent of the total principal amount of the loan plus interest 00 the unpaid balance acCNing during that year for each of the third and fourth complete years of that service; and (C) 30 percent of the total principal amount of the loan plus interest on the unpaid balance accroing during that year for the fifth complete year of that .rvice. XIII. Nurse or Medical Technician Cancellation (1) I understand that. upon making a properly documented written request to the Institution, I am entitled to have up to 100 percent of the amount of this loan plus the interest thereon canceled if I perfoCIll qualifying service after the period for which 1 received the loan as a full-time nune or medical technician providing health care services. (2) A portion of this loan will be canceled for each completed year of service at the following rates: (A) IS percent of the total principal amouDt of the loan plus interest on the unpaid balance accruing during that year for each of the first and second complete years of that service; (B) 20 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for eacb of the third and fourth complete years of that service; and (C) 30 percent of the total principal amouot of the loan plus interest on the unpaid balance accruing during that year for the fifth complete year of that service. XIV. Child or Familv Service A2ency Cancellation (1) I understand that, upon making a propcrly documented written requClt lD thelDstitution, I am entitled lD have up lD 100 pcrcent of the amount of this loan plus interest thereon canceled if I perform qualifyin& "rvice after the period for which 1 received the loan as a full-time employee of an eligible public or private nonprofit child or family service agency who is providing. or supervising the provision of, service. to high-risk children who are from low..income communities and the families of sucb children. (2) A portioo of this loan will be canceled for each completed year of service at the followiog rates: (A) 15 percent of the total principal amount of the Joan plus interest on the unpaid balance accruing during that year for each of the first and second complete years of that service; (8) 20 percent of the total principal amount of the loan plus- interest on the unpaid balance accruing during that year for each of the third and fourth complete years of that service; and (C) 30 percent of the total principal amount of the loan plus interest 00 the unpaid balance accruing during that year for the fifth complete year of that service. XV. Death and Disability Cancellation (1) In the event of my death. the total amount owed on this loan will be canceled. (2) If I become permanently and totally disabled after I receive this loan, the Institution will cancel the total amount of this loan. XVI. Chan2e in Name. Address. Teleuhone Number. or Social Security Number I am responsible for informing the Institution of any change or changes in name, address. telepbone Dumber, or Social Security number. Page 3 of 4 Federal Perkins/Iuly 1993 xvn. Late Chane (1) The Institution will impose a'late charge if- (A) I do oat make a scheduled payment when it i. due; and (B) I do not IUbmit to the Institution, on or before the'date on which payment i. due, documentation that J qualify for a deferment, cancellation, or forbearance 81 described in Articles VI. VU, vm, IX, X, XI, xn, xm, or XIV of this agreement. (2) No charge may exceed 20 percent of my monthly, bimonthly, or quarterly payment. (J)(A) The Institution may- (i) Add the late charge to the principal the day after th. scheduled repayment was due; or (ii) Include it with the next scbeduled repayment after I have received notice of the late charge. (B) If the Institution elects to add the late charge to the outstanding principal of the loan, it must so inform me before the due date of the next installment. XVID. Assilmment (I) This note may he assigned hy the Iostitution only lo- (A) The United States; (B) Another institution upon my transfer to that institution if that institution is participating in this program; or (C) Another institution approved by the Secretary. (2) The provisions of this note that relate to the Institution shall, where appropriate, relate to an assignee. (3) Auy holder of this loan is suBject to all claims and defenses that I could assert against the Institution that made this loan; my recovery i. limited to the amount I repaid on this loan. XIX. Prior Loans I hereby certify that I bave listed below all of the Federal Perkins Loans I have obtained at other institutions. (If no prior loans have been received, state -None.-) FEDERAL PERKINS LOANS AT OTHER INSTITUTIONS Amount Date Institution 1 2 3 4 /I./on€- xx. Schedule of Advances The following amounts were advanced to me under this loan agreement OD the dates indicated: Amount Date Signature of Borrower ~;>(. d~- ~ J.~ l;c:Z~,/ 1 2 3 4 Sl,OQQ,OQ $1 nnn nn 9-1-95 1-?::!-96 NonCE TO BORROWER: DO NOT SIGN 1HIS NOTE BEFORE YOU READ IT, I UNDERSfAND AND AGREE TO ALL OF THE FOREGOING TERMS AND CONDmONS. ::: is 'ig1~7;:;:JLR ~ Date g - J'6 ,I9!!5 [(seal)] permB-q;tss Zi:,iZ:te;;t s;::;:Je)c;,~1er; cf 0 6P} ~{l Social Security Number (borrower must provide) df3 - ~ -6l ~ The borrower and Institution shall execute this note without security and without endorsement. The Institution shall provide a copy of this note to you and you should retain the copy for your records. (Authority: 20 U.S.C.I087dd) Page 4 of 4 Federal PerkiDsl1uly 1993 Exhibit B FEDERAL PERKINS LOAN PROMISSORY NOTE "\ ~: ~\ "' \! .....-/ ./ Donahue, Joseph L. 2. Social Security Number Ut-S '-9{)-h I 5 g 3. Date ofi7, Lf /77 4. Area CodefTelephone Number (!j6{J) LJ)~ -7033> 5. Driver's License Number (list state abbreviation first) 0504 1. Name (last. first, middle initiaQ and Permanent Address (street, city, state. zip code) 6. School Name & Address (street, city, state, zip code) 7. Borrower Status 8. Interest Rate Dickinsa1 College P.O. BaI< 1773 Carlisle. PA 17013-2896 (l Half-time or _ 0 Less "*' hal-time 5 % 9. Loan Amount: 10. Loan Period $2,000,00 1996-97 TERMS AND CONDITIONS: [Any bracketed dauS1e or paragraph may be included ill: option of institution) APPLICABLE LAW - The terms of this nOle and any disbursements made under this note shall be interpreted In accordance with Part E oeTitIe IV of the Higher Education Act of 1965. as amended (hereinafter caJled the Act). as well as Federal regulations issued under the Act. An sums advanced under thts note are subject to the Act and Federal regulations issued under the Act. REPAYMENT + I am obligated to repay the principal and the interest that accrues on It to the above. named institution (hereinafter called the school) over a perk>d beginning 9 months (or sooner if I am a less than a hair-time borrower) after the date I cease to be at least a half-time student at an institution of higher education or a comparable school outside the United States approved by the United States Secretary of Education (hereinafter called the Secretary) and ending 10 yean later. unless I request in writing that my repllyment period begin sooner. I undentand that the school will report the amount of my installment payments. along with the amount of this loan to a national credit bureau. lnte~t on thiS loan shall accrue from the beginning of the repaymeot period. My repayment periOd may be shorter than 10 years ifl am required by my school to make minimum monthly payments. Upon my written request my repayment period may be extended during periods of deferment, hardship, or forbearance and I may make graduated installments in accordance with a schedule approved by the Secretary. I will make my installl'Tlent payments in equal monthly, bimonthly or quarterly installments as determined by the school. The school may round my Installment payment to the next highest multiple of $5. [I will make a minimum monthly repayment of S4D (or $30 if I haVe outstanding Federal Perkins loans made before October 1, 1992 that included the $30 minimum payment opUon) In accordance with the Minimum Monthly Payment Section of the Terms and Conditions contained on the reverse side of this document.} LATE CHARGES - The school will impose late charges if I do not make a scheduled payment when dm or If I fan to submit to the school on or before the dm date of the payment, a properly documented written request that I qualify for any of the forbearance. deferment or cancellation benefits as described below. No late charges may exceed 20% of my monthly. bimonthly or quarterly payment. The school may add tht late charges to principal the day after the scheduled repayment was due (lr include It with the next scheduled repayment after I have received notice of the charge, and such notice is sent before the next Installment is due. REQUESTS FOR DEFERMENT, CANCELLATION OR FORBEARANCE - To receive deferment, cancellation, or forbearance benefits, I must make a written request to the school and must submit to the school any doc\tmentatlon the school requires to prove my eligibility for these benefits. I am responsible for submitting the appropriate requests on time, and I may lose my benefits if I fall to rue my request on time. DEFAULT ~ If I fail to make a scheduled payment when due: if I fail to submit to the school, on or before the dm date of a scheduled payment. documentation that I qualify for a deferment, canceUation, or forbearance; or if I fan to comply with the terms and conditions of this promissory note or written repayment agreement. the school may, at its option, declare my loan to be in default and may accelerate my loan (demand immediate payment of the entire unpaid balance of the loan. including principal, interest, late charges, and collection costs). The school, and the Secretary, if my loan is assigned to the Secft!tary for col1ection. shall disclose to credit bureau organizations that I have defaulted and all other relevant loan information. I will lose my right to def~r payments and my right to forbearance if I default on my loan. I will lose my right to receive cancellation benefits for service that is performed after the date the school accelerated the loan. I wUl be ineligible for any further federal student financial assistance authorized under the Act until I make arrangements that are satisfactory to the school or the Secre~ry to repay my loan. CHANGE OF STATUS - I wUl inform the school of any change in my name, address, telephone number, Social Security number. or driver's license number. ASSIGNMENT. This note may be assigned by the school only to the United States. The provisiOns of this note that relate to the school shall where appropriate relate to the assignee. PROMISE TO PAY: I promise to pay the school, or a subsequent holder of the Promtssory Note, the sum of amount(s) advanced to me under the terms of this Note, plus interest and other fees which may become due as provided in this Note. I promise to pay all reasonable collection casu, including attorney fees and other charges, nece5$ary for the collection of any amount not paid when due. I wUl not sign this Note before reading it, including the provisions on the reverse side. This loan has been made to me without security or endorsement. My signature certifies I have read, understand, and agree to the terms and conditions of this Promissory Note, THIS IS A _~,":TM=;'~12 d~~U . ,,",m "," D.!/;~/rti Terms and Conditions (cant.) : , , HARDSHIP REPAYMENT OPTIONS. Upon my wn!ten request. if I qualify as a low-income individual during the repayment period. the school may extend the repayment period for up to an additional ten (10) years and may adjust any repayment schedule to reflect my income. Upon my written request. the school may extend the repayment period if. in its opinion. prolonged illness or unemployment prevent me from making the scheduled repayments during which time interest will continue to accrue. The school may permit me to pay less than the minimum monthly repayment rate for a period of not more than one year at a time if I experience a period of prolonged illness or unemployment except such action may not extend the repayment period b<yond 10 years. GRACE PERIODS. My initial grace period before begtnning repayment is 9 months. If I am a ~-'Than~Ha1r.Time Borrower with outstanding Federal Perkins Loans. my repayment begins when the next scheduled installment of my outstanding loan is due. If I am a Leo;s- Than. Half-Tune Borrower with no outstanding Federal Perkins Loans. my repayment begin'> the earlier of: 9 months from the date my loan was made, or 9 months from the date I became less than a half.time student. even if I received the loan after I became a less than half-time student. My payments will resume after. post-deferment gTllCe period of 6 months that follows deferments that apply to Federal Perklm loans. PREPAYMENf - I may prepay aU or any part of my unpaid loan balance. plus any accrued interest. at any time without penalty. Amounts I repay in the academic year in which the loan W<lS made and before the initial grace period has ended will be used to reduce the amount of the loan and will not be considered a prepayment. If I repay amounts during the academic year in which the loan was made and the initial grace period ended. only those amounts in excess of the amount due for any repayment period shall be considered a prepayment. If. in an academic year other than the award year in which the loan was made. I repay more than the amount due for an install- ment, the excess will be used to repay principal unless I designate it as an advance payment of the next regular installment. MINIMUM MONTHLY PAYMENT. I wtll make a minimum monthly repayment of $40 (or $30 if r have outstanding Federal Perkins loans made before October 1. 1992 that included the $30 minimum payment option) if required by the school. lr the total monthly repayment rate on this loan and any outstanding Federal Perkins loans I may have is less than the minimwn monthly repayment rate eitabUshed. by the school. the school may still require a minimum monthly repayment tate. A minimum monthly repayment amount will combine my obligation on t:hts and all my outstanding Federal Perkins loans. 1ncluding those made at other schools. The portion of the minimum monthly payment that will be applied to this loan will be the difference between the minimum monthly payment and. the total amounts 0W'ed at a monthly rate on my other Federal Perkins loans. H each school holding my outstanding Federal Perkins loans exercises the minimum monthly payment option. the minimum monthly repayment will be divided among the schools in proportion to the amount of principal advanced by each school. FORBFARANCE - Upon making a properly docwnented written reqUeit to the school. I am entitled to forbearance of principal and interest or principal only, renewable at intervals up to 12 months for periods that coUectively do not exceed three years. under the foDowing conditions: H my monthly ntle IV loan debt burden equals or exceeds 20% of my total monthly gross income: if the Secretary authorizeS a period of forbearance due to a national military mobilization or other national emergency; or if the school determines that I qualify due to poor health or for other reasons. includtng service in AmertCorps. Interest accrues during any period of forbearance. DEFERMENTS ~ Upon making a properly documented written reqUESt to the school. I may defer making scheduled installment payments and will not be liable for any interest that might otherwise accrue 1) during any period that I am: enroUed and attending as a regular student in at least a half-time course of study at an eligible school: enrolled and attending as a regular student a graduate fellowship program approved by the Secretary: engaged in graduate or post~graduate fellOWShip-supported study outside the US: enrolled and attending a rehabilitation training program for disabled individuals approved by the Secretary; engaged in pubUc service that qualifies me to have part or all of my loan canceled; 2) for a period not to exceed three years during which I am seeking but unable to fmd full-time employment. 3) for a period not to exceed three year.; during which I am experienCing an economic hardship as determined by the $Choo!. I am not eligible for a deferment while selVing in a medical internship or residency program. I may continue to defer making scheduled installment payments and Will not be Uable for any interest that might otherwise accrue for a six-month period immediately following the expiration of any deferment period described in this paragraph. CANCELLATIONS - Upon making a properly documented written request to the school. I am entitled to have up to 100% of the original principal loan amount of this loan canceled if I perfonn qualifying service in the areas listed in paragraphs A. B. C. 0 and E below. Qualifying Service must be performed after 1 receive the loan. A. Teaching. a full-time teacher in a public or other nonprofit elementary or secondary school. that has been designated by the Secretary in accordance with the provisions of section 465(a) (2) of the Act as a school with a high concentration of students from low-income families:. An official Directory of designated low-income schools is published annually by the Secretary. . a full~ time special education teacher in a public or nonprofit elementary or secondary $Chaol system. . a full-time teacher. in a public or other nonprofit elementary or secondary school system. who teaches mathematics. science. foreign languagei. bilingual education. or any other field of expertise that is determined by the State Department of Education to have a shortage of qualified teachers in that State. B. Early IntervenUon Services. a full-time qualified professional provider of early intervention services: in a public or other nonprofit program under public supervision by a lead agency as authorized by section 672(2) of the Individuals with DisabiUties Education At:.t. Early Intervention Servicei are provided to Infants and toddlen wtth disabilities. C. Law Enforcement or CorftCtions Officer. a full-time law enforcement officer for an eligible local, State. or Federal law enforcement agency: or . a full-time corrections officer for an eligible local. State. or Federal corrections agency. D. Nurse or Medical Technician. a full-time nurse providing health care servl.Cei: or. a full-time medical technician providing health care services. E. Child or Family Service Agency. a full-time employee of an eligible public or private non~profit child or family .service agency who is providing or supervising the provision of .services to high-risk children who are from low. income communities and the families of such children. Cancellation Rates - For each completed year of service under paragraphs A. B. C. D and E a portion of this loan will be canceled at the following rates: . 15% of the original principal loan amount for each of the rU'St and second years: . 20% of the original ptincipalloan amount for each of the third year and founh years: and . 30% of the original principal loan amount for the fifth year. F. Head Start Canc::elladon ~ Upon making a properly docwnented Written request to the school. I am entitled to have up to 100% of the original principal loan amount canceled for quaUfying service perfonned after I receive the loan as:. a full~time staff member in the educational component of a Head Start program which is operated for a period comparable to a full school year and which pays a salary comparable to an employee of the local educa~ tlonal agency. Cancellation Rat!! - For each completed year of service under the Head Start Cancellation provision. this loan will be canceled at the rate of 15% of the original prlncipalloan amount. G. Milltary Cancellation - Upon making a properly documented written request to the school. I am entitled to have up to 50% of the principal amount of this loan canceled for qualifying servtce performed after I receive the loan as: . a member of the Anned Forces of the United States in an area of hosUlities that qualifies for special pay under section 310 of Title 37 of the United States Code. Cancellation Rate - For each completed year of service under the MiUtary Cancellation provision. this loan w1l1 be canceled at the rate of 12 1/2% of the original principal loan amount. H. VolWlteer Semce Cancelladon - Upon making a properly documented written request to the school. I am entitled to have up to 70% of the original principal loan amount of this loan canceled for qualifying service performed after I received the loan as: . a volunteer under the Peace Corps Act; . a volunteer under the Domestic Volunteer Service Act of 1973 (ACTION programs) . Cancellation Rate - For each completed year of service under the Volunteer Service Cancellation provision. a portion of this loan will be canceled at the following ratei: . 15% of the original principal loan amount for each of the first and second 12-month periods of service: and . 20% of the Original principal loan amount for each of the third and fourth 12-month periods of service. I. Death and Disability Cancellation - In the event of my death. the school will cancel the total amount owed on this loan. If I become permanently and totally disabled after I receive this loan. the $Chool will cancel the totaJ amount owed on this loan. PERKINS (NDSL) TRUTH-IN-LENDING STATEMENT , . DICKI~SON COLLEGE Account Number nn?71-nnn-nn-1nS4-nQ Name of Borrower Joseph L, Donahue Address 481 Stafford Rd, Mansfield Center, CT 06250 &~AL PERCENTAGE RATE AMOUNT FINANCED The cost of your credit as a yearly rate. The amount of credit provided to you. Prior to repaytllent During repaytllent o 7. 5 7. $1.000.00 I Itemization of the Amount Financed: $ 1,000,00 Amount given directly to YOU,I Late Charge: If a paytllent is late, you may be charged: $1,00 for the first late paytllent, and $2.00 for each subsequent late paytllent if this loan is payable monthly, $3,00 for each late paytllent if this loan is payable bimonthly, $6.00 for each late payment if this loan is payable quarterly. Prepayment: If you payoff early, you will ~ have to pay a penalty, See your promissory note for any additional information about nonpayment, de- fault, any required repayment in full before the scheduled date, and pre- paytllent, TIlE BORROWER A NOZllZG S I CElPT OF AN EXACt COPY STUDENT ~ ~ ~ INSTITUTIONAL BORROWER I '" -<k~ REPRESENTATIVE DATE 9p..t;47 OAT! OF THIS STATEMENT. EXHIBIT "e" FEDERAL PERKINS LOAN PROMISSORY NOTE 00273-000-00-3054-09 "'---0/ ,-- I 1. Name (last, first. middle initial) and Permanent Address (street. city. state. zip code) Donahue, Joseph, L. 481 Stafford Rd. Mansfield Center, CT 06250 2. Social Security Number (JIfs-BO-(;,1.<,6 3. Date of Birth 1- /'1- 77 4. Area Code/Telephone Number (60)J..j~3-7D~3 5. Driver's License Number (List state abbreviation first) 6. School Name & Address (street, city, state, zip code) 7. Borrower Status 8. Interest Rate DicJOnson College P.O. Box 1773 Carlisle, PA 17013-2896 U Half-time or greater 0 Less than half-time 5% 9. Loan Amount: 10. Loan Period ~1,OOO.00 1997-1998 TERMS AND CONDITIONS: lAny bracketed clause or paragraph may be in::luded at option of institution. I APPLICABLE LAW - The terms of this note and any disbursements made under this note shall be interpreted in accordance with Part E arTitle IV of the Higher Education Act of 1965. as amended (hereinafter called the Act), as well as Federal regulations issued under the Act. All sums advanced under this note are subject to the Act and Federal regulations issued under the Act REPAYMENT - r am obligated to repay the principal and the interest that accrues on it to the above-named institution (hereinafter called the school) over a period beginning 9 months (or sooner if I am a less than a half-time borrower) after the date I cease to be at least a half-time student at an Institution of higher education or a comparable school outside the United States approved by the United States Secretary of Education (hereinafter called the Secretary) and ending 10 years later. unless I request in writinR that my repayment period begin sooner. I understand that the school will report the amount of my installment payments, along with the amount of this loan to a national credit bureau. Interest on this loan shall accrue from the beginning of the repayment period. My repayment period may be shaner than 10 years if I am required by my school to make minimum monthly payments. Upon my written request my repayment period may be extended during periods of deferment. hardship, or forbearance and I may make graduated installments in accordance with a schedule approved by the Secretary. I will make my installment payments in equal monthly, bimonthly or quarterly installments as determined by the school. The school may round my installment payment to the next highest multiple of $5. (I will make a minimum monthly repayment of $40 (or $30 if I have outstanding Federal Perkins loans made before October 1. 1992 that included the $30 minimum payment option) in accordance with the Minimum Monthly Payment Section of the Terms and Conditions contained on the reverse side of this document.] LATE CHARGES - The school will impose late charges if I do not make a scheduled payment when due or if I fail to submit to the school on or before the due date of the payment. a properly documented written request that I qualify for any of the forbearance. deferment or cancellation benefits as described below. No late charges may exceed 20% of my monthly, bimonthly or quarterly payment. The school may add the late charges to principal the day after the scheduled repayment was due or include it with the next scheduled repayment after I have received notice of the charge. and such notice is sent before the next installment is due. REQUESTS FOR DEFERMENT. CANCELLATION OR FORBEARANCE - To receive deferment, cancellation, or forbearance benefits, I must make a written request to the schaal and must submit to the school any documentation the school requires to prove my eligibility for these benefits. I am responsible for submitting the appropriate requests on time, and I may lase my benefits if I fail to file my request an time. DEFAULT - If I fail to make a scheduled payment when due: if I fail to submit to the school. on or before the due date of a scheduled payment. documentation that I qualify for a deferment. cancellation, or forbearance: or if I fail to comply with the terms and conditions of this promissory note or written repayment agreement, the school may. at its option, declare my loan to be in default and may accelerate my loan (demand immediate payment of the entire unpaid balance of the loan, including principal, interest. late charges. and collection costs). The school. and the Secretary, if my loan is assigned to the Secretary for collection. shall disclose to credit bureau organizations that I have defaulted and all other relevant loan information. I will lose my right to defer payments and my right to forbearance if I default on my loan. I will lose my right to receive cancellation benefits for service that is performed after the date the school accelerated the loan_ I will be ineligible for any further federal student financial assistance authorized under the Act until I make arrangements that are satisfactory to the school or the Secretary to repay my loan. CHANCE OF STATUS - I will inform the school of any change in my name, address, telephone number. Social Security number, or driver's license number, ASSIGNMENT - This note may be assigned by the school only to the United States, The provisions of this note that relate to the school shall where appropriate relate to the assignee PROMISE TO PAY: (promise to pay the school, or a subsequent holder of the Promissory Note, the sum of amounds) advanced to me under the terms of this Note, plus interest and other fees which may become due as provided in this Note. I promise to pay all reasonable collection costs, including attorney fees and ather charges. necessary for the collection of any amount not paid when due. I will not sign this Note before reading it. including the provisions on the reverse side. This loan has been made to me without security or endorsement. My signature certifies I have read. understand, and agree to the terms and conditions of this Promissory Note. THIS IS A WANtS) THAT MUST B EPAID Borrower' l~~tJJ~ 9/;;6/97 Date: v' Terms and Conditions (cont.) HARDSHIP REPATh1ENT OPTIONS. Upon my wrinen r('qllt~st. if I qualify as a low-income individual during the repayment pt'riod, the school may extend me repayment period for up to an additional ten (10) years and may adjust any repayment schedule to reflect my income. Upon my written requesc the school may extend the repayment period if. in its opinion, prolongt"rl illnes.s or unemp]()yment prevent me from making the scheduled repayments during which time interest will continue to accrue. The school may permit me to pay less than the minimum monthly repayment rate for a period of not more than one year at a time if I experience a period of prolonged illness or unemployment except such action may not extend the repayment period beyond 10 years. GRACE PERIODS - My initial grace period before beginning repayment is 9 months. If I am a Less-Than-Half-Time Borrower with outstanding Federal Perkins Loans, my repayment begins when the next scheduled installment of my outstanding loan is due. If I am a Less-Than-Half-Time Borrower with no outstanding Federal Perkins Loans, my repayment begins the earlier of: 9 months from the date mv loan was made. or 9 months from the date I became less than a half-time student. even if I received the loan after I became a less than half-time student. My payments will reswne after a post-deFerment grace period of 6 months that foDows deferments that apply to Federal Perkins loans. PREPAYMENT - I may prepay all or any part of my unpaid loan balance. plus any accrued interest. at any time Without penalty. Amounts I repay in the academic year in which the loan was made and before the initial grace period has ended will be used to reduce the amount of the loan and will nor be considered a prepayment. If I repay amounts during the academic year in which the loan was made and the inilial grace period ended. only those amounts in excess of the amount due for anv repayment period shall be considered a prepayment, If. in an academic year other than the award year in which the loan was made. I repav more than the amount due for an install- ment. the excess will bt. used to repay principal unless I designate it as an advance payment of the nex[ regular installment. MINIMUM MONTHLY PAYMENT - I will make a minimum monrhly repayment of 540 (or $30 if I have outstanding Federal Perkins loans made before OClOber 1. 1992 that included the $30 minimum payment option) if required by the school. If the total momhly repaymem rate on this loan and any outstanding Federal Perkins loans I may have is less than the minimum monthJy repayment rate established by the school. the school may still require a minimum monthly repayment rate. A minimum monthly repayment amount will combine my obligation on this and all my outstanding Federal Perkins loans. including those made at other schools. The portion of the minimum monthly payment that will be applied to this loan will be the difference between the minimum monthly payment and the total amounts owed at a monthlv rate on my other Federal Perkins loans. If ea<:h school holding my outs~nding Federal Perkins loans exercises the minimum monthly payment option. the minimum monthly repayment will be divided among the schools in proportion to the amoum of principal advanced by each school. FORBEARANCE - Upon making a properly documemed 'Nritten request to the school. I am entitled to forbearance of principal and interest or principal only, renewable at intervals up to 12 months for periods that collectively do not exceed three years. under the follO'Ni.ng conditions: If my monthly Title IV loan debt burden ~quals or exceeds 20% of my toral monthly gross income; If the Secretary authorizes a period of forbearance due to a national military mobilization or other national emergency; or if the school determines that I qualify due to poor health or for other reasons. including service in AmeriCorps. Interest accrues during any period of forbearance. DEFER!v1ENTS . Upon making a properly documented written request to the school. I may defer making scheduled installment payments and will not be liable for any interest that might otherwiS(' accrue t) during any period that I am: enrolled and attending as a regular student in at least a half-time course of study at an eligible school: enrolled and auending as a regular student a graduate fE'llowship program approved by the Secretary: engaged in graduate or post-graduate fellowship-supported study outside the US: enrolled and attending a rehabilitation training program for disabled individuals approved by the Secretary: engaged in public .service that qualifies me to have part or all of my loan canceled: 2) for a period not to exceed three years during which I am seeking but unable to find full-time employment. 3) for a period riot to exceed (I1rt'.. Yt'ars during which I am experiencing an economic hardship as detennint.d b\' the schuoL I am not eligible for a defennt'nt \\'hile serving in a ffil'dical illlf'rT1Ship or residency program r milV continue to defer making S{:hedukd installment payments and will nm he liJhl1' for any illterest that might utheG...-ise dccrue for a <;ixmonth period immediately following the expiration IJf ,my rlefl'rment period deSCribed in thi,s paragraph CANCELLATIONS - UPllJ1 making a properly documented wrirten request to th~ schonl. I am f'lltitled to have up to 100% of the original principal loan amount of this loan cancp]ed if I penorm qualifying :;CJ\..'ice in the areas listed in paragraphs A. B. C. D and E below. Qualifying Service must be performed after I receive the loan. A. Teaching" a fulHime teacher in a public or other nonprofit elementary or secondary school. that has been designared by the Secretary in accordance with the proVisions of .section 465(a) (2) of the Act as a school With a high concentration of students from low-income families. An official Directory of designated low-income schools is published annually by the Secretary. .. a full- time special education teacher in a public or nonprofit elementary or secondarj school system, .. a full-time teacher. in a public or other nonprofit elementary or secondary school system. who teaches mathematics, science, foreign languages, bilingual education. or any other field of expertise that is dNHmined by the State Department of Education to have a shortage of qualified teachers in that State. R Early Intervention Services .. a full-time qualified professional provider of early intervention services in a public or other nonprofit program under public supervision by a lead agency as authorized by section 672(2) of the Individuals with Disabilities Education Act. Early Intervention Services are provided to infants and toddlers with disabilities. C. Law Enforcement or COITeCtions Officer" a full-time law enforcement officer for an eligible local. State. or Federal law enforcement agency; or" a full-time correctioll.'i officer for an eligible local, State. or Federal corrections agency. D. Nurse or Medical Technician" a full-time nurse providing health care services: or . a full-time medical technician providing health care services. E. Child or Family Service Agency" a full-time employee of an eligible public or private non"profit child or family ser.;ce agency who is providing or super\ising the provision of services to lugh-risk chilriren who are from low. income communities and the families of such children. Cancellation Rates - For each completed year of service under paragraphs A, B, C. 0 and E a portion of this loan will be canceled at the following rates: .. 15% of the original principal loan amount for each of the ftrSt and second yean: .. 20% of the original principal loan amount for each of the third year and fourth years: and . 30% of the original principal loan amount for the fifth year. F. Head Start Cancellation - Upon making a properly documented written request to the school. I am entitled to have up to 100% of the original principal loan amount canceled for qualifying service performed after I receive the loan as: .. a ful1~time staff member in the educational component of a Head Start program which is operated for a period comparable to a full school year and which pays a salary comparable to an employee of the local educa- tional agency. Cancellation Rate - For each completed year of service under the Head Start Cancellation provision, this loan will he ~ance]ed at the rate of 15% of the original principal loan amount. G. :Military Cancellation - Upon making a properly documented written request to the school. I am entitled to have up to 50% of the principal amount of this loan canceled for qualifying service performed after I receive the loan as: .. a member of the Armed Forces of the United States in an area of hostilities that qualifies for special pay under .seclion 310 of Title 37 of the United States Code. Cancellation Rate. For each completed year of ser.'ice under the Military Cancellation provision, this loan will be canceled at the rate of 12 1/2% of the original principal loan amount. H. Volunteer Service Cancellarion - Upon making a properlv documented writren request to the school. I am entitled to have up to 70lYo of the original principal loan amount of this luan canceled for qualifying service performed after I received the loan as: . a volunteer under the Pt'ace Corps An: . a volunteer under the Domestic Volunteer Service Act of 1973 (ACTION programs) . Cancellation Rate - For each completed year of service under the Volunteer Service Cancellation proviSion. a porlion of this loan will be canceled at the fallowing rates: .. 15% of the original principillloan amount for each of the flf'>t and second 12-momh periods ofsen-ice: and. 200,;) of thp original principal loan amount for each of the third and fourth 12-mornh pr:riod\ of Sf'f'\.'ic(' I. Dp-ath and Disability Cancellation - In the ewnt ,If m",' dl',llh. ,he )(hool will cancel the total amollnt owed 011 this loan. If I become perll\<ll1l'ntlv and totally dL<;.ahl(>n after I recpiw this loan thf' school wilt cancel t1)(' total amount owed on this loan Exhibit D PI'RK[~S U;DSI.) TRUTH-[N-U:ND1NC STAn:~tENT DIC{INSON COLLEGE Accounc Number 00273...000-00...3054-09 Name of Borrower .ln~"rh I _ nnn~hll" Address 481 Stafford Rd. Mansfield Center, CT 06250 &~AL PERCENTAGE RATE AMOUNT FINANCED The cost of your credic as a yearly rate. The amounC of credic provided co you. Prior co repaymenc During repayment o % 5 % $ 1,000.00 I ICemization of che Amount Financed: $ 1,000.00 Amount given direccly co YOU,I Lace Charge: If a payment is late, you may be charged: $1.00 for che first late paymenc, and $2.00 for each subsequent late payment if chis loan is payable monthly, $3,00 for each lace payment if chis loan is payable bimonthly, $6.00 for each late paymene if chis loan is payable quarterly. Prepaymenc: If you payoff early, you will not have to pay a penalty. See your promissory noee for any additional information about nonpayment, de- faule, any required repayment in full before the scheduled dace, and pre- payment. TIlE BORROweR A~~OWLEDGES RECEIPT STUDENT /;: //l.;/ BORROwCR /~ rf {~..J.e DATE J 1'1/71 OF AN EXACT con OF THIS STATEXENT. INSTIT\Jl'IONAL ~,',;l., ,_~' ""-, REPRESENTATIVE (~!- ""~ qlqlq~ , ~---.~ DATE EXHIBIT "n" FEDERAL PERKINS LOAN PROMISSORY NOTE e-mcUW "5/5 m "" .' _, '70 L- 'lr, ,:t_,..! - --"" .......,--" '")' , 00273-000-00-3054-09 . / I C)/ 1; 1. Name (last. first. middle initial) and Permanent Address (street. city, state. zip code) 2. Social Security Number Donahue, Joseph L. 481 Stafford Rd. Mansfield Center, CT 06250 043...80...6138 3. Date of B7!t4/r7 4. Area CodefTelephone Number (203) 423...7033 5. Driver's License Number (Ust state abbreviation first) 6. School Name & Address (street. city, state. zip code) 7. Borrower Status 8. Interest Rate Dickinson College P.O. Box 1773 Carlisle, PA 17013-2896 lrlH...time",grea'", o Less than ha'.time 5% 9. Loan Amount: 10. Loan Period $1,000.00 1998-1999 TERMS AND CONDITIONS: IAny bracketed clause or paragraph may be included at option of irm.itution.] APPLICABLE LAW - The terms of this note and any disbursements made under this note shall be interpreted in accordance with Part E of Title IV of the Higher Education Act of 1965, as amended (hereinafter called the Act). as well as Federal regulations issued under the Act. All sums advanced under this note are subject to the Act and Federal regulations issued under the Act REPAYMENT - I am obligated to repay the princip..1 and the interest that accrues on it to the above-named institution (hereinafter called the school) over a period beginning 9 months (or sooner if I am a less than a half-time borrower) after the date I cease to be at least a half-time student at an Institution of higher education or a comparable school outside the United States approved by the United States Secretary of EducatiOn (hereinafter called the Secretary) and ending 10 years later, unless I request in writing that my repayment period begin sooner. I understand that the school will report the amount of my installment payments, along with the amoum of this loan to a national credit bureau. Imerest on this loan shall accrue from the beginning of the repayment period. My repayment period may be shofter than 10 years if I am required by my .school to make minimum monthly payments. Upon my written request my repayment period may be extended during periods of deferment, hardship, or forbearance and I may make graduated installments in accordance with a schedule approved by the Secretary. I will make my installment payments in equal monthly, bimonthly or quarterly installments as determined by the school. The school may round my installment payment to the next highest multiple of $5. (I will make a minimum monthly repayment of $40 (or $30 if I have outstanding Federal Perkins loans made before October l. 1992 that included the $30 minimum payment option) in accordance with the Minimum Month]y Payment Section of the Terms and Conditions contained on the reverse side of this document.] LATE CHARGES - The school will impose late charges if I do not make a scheduled payment when due or if I fail to submit to the school on or before the due date of the payment. a properly documented written request that I qualify for any of the forbearance, deferment or cancellation benefits as described below. No late charges may exceed 20% of my monthly. bimonthly or quarterly payment. The school may add the late charges to principal the day after the scheduled repayment was due or include il with the next scheduled repayment after I have received notice of the charge, and such notice is sent before the next installment is due. REQUESTS FOR DEFERMENT, CANCELLATION OR FORBEARANCE - To receive deferment. cancellation, or forbearance benefits. I must make a written request to the school and must submit to the schoo] any documentation the school requires to prove my eligibility for these benefits. I am responsible for submitting the appropriate requests on time. and I may lose my benefits if I fail to file my request on time. DEFAULT - If I fail to make a scheduled payment when due; if I fail to submit to the school on or before the due date of a scheduled payment. documentation that I qualify for a deferment. cancellation, or forbearance; or if I fail to comply with the terms and conditions of this promissory note or written repayment agreement. the school may, at its option, declare my loan to be in default and may accelerate my loan (demand immediate payment of the entire unpaid balance of the loan, including principal. interest. late charges. and collection COSts). The school. and the Secretary, if my loan is assigned to the Secretary for collection. shall disclose to credit bureau organizations that I have defaulted and all other relevant loan information. I will lose my right to defer payments and my right to forbearance if I default on my loan. I will lose my right to receive cancellation benefits for service that is performed after the date the school <lccelerated the loan. I will be ineligible for any further federal student financial assistance authorized under the Act until I make arrangements that are satisfactory to the school or the Secretary to repay my loan CHANGE OF STATUS. I will inform the school of any change in my name. address. telephone number. Social Security number. or driver's license number. ASSIGNMENT - This note may be assigned by the school only to the United States. The provisions of this note that relate to the school shall where appropriate relate to the assignee. PROMISE TO PAY: I promise to pay the school, or a subsequent holder of the Promissory Note. the sum of amount(s} advanced to me under the terms of this Note, plus interest and other fees which may become due as provided in this Note. I promise to pay all reasonable collection costs. including attorney fees and other charges, necessary for the collection of any amount not paid when due. I will not sign this Note before reading it. includ!ng the provisions on the reverse side. This loan has been made to me without security or endorsement. My signature certifies I have read, understand, and agree to the terms and conditions of this Promissory Note. THIS IS A WANtS) THAT MUST BE REPAID , B~_".Ifiz!/I2' r;/9l;i Date: Terms and Conditions (cont.) HARDSHIP REP:\'{j'v[ENT OPTIONS - Uptlllll1\ written rt'que.st. if I qualify a~ a low incomt' individual during the l"l'payrnelll penud. the school may extend the repayment period fOf up to an additional ten (10) years and may adlust any repayment schedule to reflect my income. Upon my written request. thl-' school may extend the repayment period if. in its opinion. prolonged illlWSS or unemployment prevent me from making the Scheduled repayments during which time interest vvill continue (0 accrue. The school may permit me to pay less than the minimum monthly repayment rate for a period of not mort' than one year al a lime if 1 experience a period of prolonged iJlrll'SS e)f unemplovmem except such action may not extend the repaymt'1l1 perind beyond 10 years. GR",-CE PERIODS - My initial grace period before beginning repayment is 9 months. If I am a Less- Than-Half- Time Borrower with oUlStanding Federal Perkjns Loans, my repayment begins when the next scheduled installment of my outstanding loan is due. If I am a Less-Than-Half-Time Borrower wilh no oUlStanding Federal Perkins Loans. my repaymem begins lhe earlier of: 9 months from the date my loan was made. or 9 months from the date I brcame less lhan a half-time stud-em. even if I received the loan after I became a less than half-time student. My payments will resume after a post-deferment grace period of 6 months that follows deferments that apply to Federal Perkins loans. PREPAThlENT - I may prepay all or any part of my unpaid loan balance. plus any accrued interest. at any time without penalty. Amounts I repay in the academic year in which the loan was made and before the initial grace period has ended will be used to r!'duce the amount of the loan and will not be considered a prepayment If I repay amounts during the academic year in which the loan was made and the initial grace period ended. only those amounts in excess of the amoum due for any repayment period shall be consid!'rpd a prepa"Tnenc, If. in an academic year other than the award year in which the loan was rnadi", 1 repay more than the amount due for an install- mt'nt. the ('xcess ,,\'ill he used to repilv principal unless [designate it as an ad..-ance p<1"TIWnl of thf' npx( rebTlJlar installment. ~nNIMUM MONTHLY PAYMENT" I will make a minimum monthly repaymf'nt of $40 (or $30 if I have outstanding Federal Perkins loans mad~ bl'fore October 1, 1992 that included the $30 minimum payment option) if required by the school. If the tolal monthly repayment rate on this loan and any outstanding Federal Pf'rkins loans I may have is less than the minimum monthly repavment rate established by the school. the school may still require a minimum monthly repayment rate. A minimum monthly repayment amount will combine mv obligation on this and all mv outstanding Federal Perkins loans. including "those made at other schools. The portion of the minimum monthly payment that will be applied to this loan will be the difference between the minimum monthly payment and the total amounts owed at a monthly rate on my other Federal Perkins loans. If each school holding mv ourstanding Federal Perkins loans exercises the minimom monthly payment option. the minimum monthly repayment will be divided among the schools in proportion to the amount of principal advanced by each school. FORBEARANCE" Upon making a properly documented written request to the school. I am entitled to forbearance of principal and interest Dr pnncipal only. renewable at intervals up to 12 months for periods that collective]y do not exceed thrf't' years. under the following conditions: If mv monthly Title IV loan debt burden f~quals or exceeds 20% of my total monthly gross income: if the Secretary authorizes a period of forbearance due to a national military mobilization or other national emergency: or if the school determines that I qualify due to poor health or for other reasons, including service in AmeriCorps. fnrerest accrues during any penod of forbearance. DEFER.MENTS - Upon making a properly documented written request (0 the schon!. I llia\ defer making scheduled installment payments Clnd will not be liabll' for all\' inu'rf'sr that might otheT"\vise accrue 1) during any period that 1;111): t"llrnlJed and ilttending:IS a regular studenr in at If'<tst a half-time course of study at an eligible schuol: enrolled and attending as a regular student a graduate ft'llowship program approved bV lhe St.-cretary: engaged in graduate or pf)~t-gTaduate fellow~hip._~uppllrted study ()u[slde the CS: enrolled and attending ~ rehabilitation training program for disabled indiViduals approved b\ the Secretarv: eng3gt>d in public service that qualifies me to have part or all llf lIlV lacm Clnceled: 2) fur a period not to eXCl"-.>d tlU"ee years during which I am wd\Jng hUlUlldbl~ to find ruJltime l'mplo'rrnern, 3) for a period not to t'xu';.d thn.;' ',('<1[, during \\tllctl 1 <.1m pxp(:rh'nClng an N:ontJTllic harctship as d!'l"rmillt'd h\.' lilt" '.. hliU) I ~HTI 1l0! digibj(' felf d (kf('rrnl'nl whdt' $('rvillg in a In(>(!ir~Jlllltprll,hlu (ir i"'\id('!:c,, prrJgrarn. I rn;ll. ('()nttnu,' to defi'r rnaking sc!,..;hlh',IW,_\I;lllmt.nt p,;ym,'llts ;md will [Hit hi, lidbh' for anI. intpreslthal rlug!\l uLhu',\l:'K clLcr-U~ lur J six muntl1 pf.'flod irnmediat~h fGlluwlIlg the (>,\pir;j(irm ill ,!th 'h.+'fll1r.ru )wriud deSCIlbed lIllhis par;Jgf<lph CAi'\JCELLATIONS Upon making a properly documented written request to the school. I am entitled to haw up to 100% of the original principal loan amount of this loan canceled if I perfoml qualifying service in the areas listed in paragraphs A, B. C, D and E below Qualifying St~Nice must be performed after I receive the loan. A. Teaching. a full-time teacher in a public or other nonprofit elementary or secondary school. that has been designated by the Secretary in accordance with the pro\fisions of section 465(a) (2) of the Act as a school with a high concentration of students from low-income families_ An official Directory of designated low-income schools is published annually by the Secretary. . a full- time special education teacher in a public or nonprofit elementary or secondary school system, . a full-time teacher. in a public or other nonprofit elementary or secondary school system. who teaches mathematics, science. foreign languages, bilingual education. or any other field of expertise that is determined by the State Department of Education to have a shortage of qualified teachers in that State. S. Early Intervention Services. a foil-time qualified professional provider of early intervention services in a public or other nonprofit program under public supervision by a lead agency as authorized by section 672(2) of the Individuals with Disabilities Education Act. Early Intervention Services are provided to infants and toddlers with disabilities. C. Law Enforcement or Corrections Officer. a full,. time law enforcement officer for an eligible local. State. or Federal law enforcement agency; or . a full-time corrections officer for an eligib]e local. State, or Federal corrections agency. D. Nurse or Medical Technician. a full-time nurse providing health care services: or . a full-time medical technician providing health care services. E, Child or Family Service Agency. a full-time employee of an eligible public or pnvate non-profit child or family service agency who is providing or supervising the provision of services to high-risk children who are from low- income cummunities and the families of such children. Cancellation Rates - For each completed year of service under paragraphs A. B. C. 0 and E a portion of this loan will be canceled at the foilowing rates: . 15% of the anginal pnncipalloan amount for each of the first and second year.;: . 20% of the onginal principal loan amount for each of the third year and fourth years: and. 30% of the anginal principal loan amount for the fifth year. F. Head Start Cancellation - Upon making a properly documented written request to the school. I am entitled to have up to 100% of the original principal loan amount canceled for qualifying seNice performed after I receive the loan as: . a full-time staff member in the educational component of a Head Start program which is operated for a period comparable to a full school year and which pays a salary comparable to an employee of the local educa- tional agency. Cancellation Rate. For each completed year of service under the Head Start Cancellation provision. this loan will be ~anceled at the rate of 15% of the original principal loan amount. G. rvlilitary Cancellation" Upon making a properly documented written request to the school. I am entitled to have up to 50% of the pnncipal amount of this loan canceled for qualifying service performed after I receive the loan as: . a member of the Armed Forces of the United States in an area of hostilities that qualifies for special pay under section 310 of Title 37 of the United States Code. Cancellation Rate - For each completed year of service under the Military Cancellation pro\fision. this loan will be canceled at the rate of 12 1/2% of the original principal loan amount. H, Volunteer Service Cancellation - Upon making a properly documented written request to the school. I am entitled to have up to 70% of the original principal loan amount of this loan canceled for qualifying service performed after I received the loan as: . a volumeer unrier the Peace Corps Act; . a volunteer under the Domestic Volunteer Service Act of 1973 (ACTION programs) . Cancellation Rate" For each completed year of service under the Volunteer Service Cancellation provision. a portion of this loan will be canceled at the following rates: . IS!);) uf the original principal loan amount for each of the first and second 12 -month periods of <;ervice: and. 20(};) of rhe original principal loan amount for each of the third and fourth 12-month pf'rions of ser;,'ic{' L Death and Disahility Cancellation - In tht' t'\'t'nt of rm (]Path (he ~Lhonl will cancel the total amount owed on this luan_ If I become pf'rmarwntlv and totally dis.abled aft("r I receive this loan. the <;chool will cancel thl' total amounr Dwed on thi..<; loan Exhibit E PFRKI'iS ('iDS!.) TRlITH-IN-U:N[)[NC STA'J'EclENT . "'.. . DIC{I~SON COLLEGE Account Number 00 dJ3. 000 /OO~ fflSt1-6"1 Name of Borrower Joseph Donahue Address LJ5/ '5ta/'l'd Rd. /J1......../l,lcl c;..n+t"'r" /"7 "''':::l~n ,/ ANNUAL PERCENTAGE RATE AMOUNT FINANCED The cost of your credit as a yearly rate. The amount of credit provided to you. Prior to repa)'1llent During repa)'1llent o 7. 5 7. $ 1,000 I Itemization of the Amount Financed: $ 1,000 Amount given directly to you./ Late Charge: If a pa)'1llent is late, you may be charged: $1.00 for the first late pa)'1llent, and $2.00 for each subsequent late pa)'1llent if this loan is payable monthly, $3.00 for each late pa)'1llent if this loan is payable bimonthly, $6.00 for each late pa)'1llent if this loan is payable quarterly, Prepa)'1llent: If you payoff early, you will ~ have to pay a penalty. See your promissory note for any additional information about nonpa)'1llent, de- fault, any required repayment in full before the scheduled date, and pre- pa)'1llent. TIlE BORROw"ER ACK.''lOWLEDGES RECEIPT OF AN EXAe! COpy OF THIS STATEMENT. STUDDlT / ~ / /J / BORROw"ER f1!"Y~:tk-L./ DATE /;J/; /t,t? INSTITlITIONAL REPRESENTATIVE ~-<-,~ ..e '-.. DATE 'Je c . I - I J~Cj f EXHIBIT "E" feDERAL PERKINS LOAN PROMISSORY NOTE 00-:) 1 ~- OCO-CO-Jd5'i-o:'1 ~, .. / 1. Name (last, first, middle initial) and Permanent Address (street, city, state. zip code) 2. Social Security Number o'l"!:r80~'~ '8 - Joseph Donahue 4'J1 5f.If;.e/ R.L, fYJpn~H.lc.I Ctutk'j c.r Ot;~~ 3. Date of Birth IlfII/77 4. Area CodefTelephone Number CUD) 'I;r!'-7o'3'3 5. Driver's License Number (List state abbreviation first) C-r 01(, 7705dl 6. School Name & Address (street, city. state, zip code) 7. Borrower Status 8. Interest Rate Dickinson College P.O. Box 1773 Carlisle, PA 17013-2896 III HaW..me a greater 0 Less than .....me 5 % 9. loan Amount: 10. loan Period $1,000 1998-1999 TERMS AND CONDITIONS: [Any bracketed clause or paragraph may be included 3toption of institution.] APPLICABLE LAW - The terms of this note and any disbursements made under this note shall be interpreted in accordance with Part E of Ti[Je IV of the Higher Education Act of 1965. as amended (hereinafter called the Act). as well il5 Federal regulatiOns issued under the Act. All sums advanced under this note are subject to the Act and Federal regulations issued under the Act. REPAYMENT - I am obligated to repay the principal and the interest that accrues on it to the above-named Institution (hereinafter called the school) over a period beginning 9 months (or sooner if t am a less than a half-time borrower) after the date I cease to be at least a half-time student at an Institution of higher education or a comparable school outside the United States approved by the United States Secretary of Education (hereinafter called the Secretary) and ending 10 years later, unless I request in writing that my repayment period begin sooner. I understand that the school will report the amount of my installment payments, along with the amount of this loan to a national credit bureau. Inte~t on this loan shall accrue from the beginning of the repayment period. My repayment period may be shorter than 10 years if I am required by my school to make minimum monthly payments. Upon my written request my repayment period may be extended during periods of deferment, hardship. or forbearance and I may make graduated installments in accordance with a schedule approved by the Secretary. I will make my installment payments in equal monthly. bimonthly or quarterly installments as determined by the school. The school may round my installment payment to the next highest multiple of $5. II will make a minimum monthly repayment of $40 (or $30 if I have outstanding Federal Perkins loans made before October I. 1992 that included the $3Q minimum payment option) in accordance with the Minimum Monthly Payment Section of the Terms and Conditions contained on the reverse side of this document.) LATE CHARGES - The school will impose late charges if I do not make a scheduled payment when due or if I fail to submit to the school on or before the due date of the payment, a properly documented written request that I qualify for any of the forbearance, deferment or cancellation benefits as described below. No late charges may exceed 20% of my monthly, bimonthly or quarterly payment. The school may add the late charges to principal the day after the scheduled repayment was due or include it with the next scheduled repayment after I have received notice of the charge. and such notice is sent before the next installment is due. REQUESTS FOR DEFERMENT. CANCELLATION OR FORBEARANCE - To receive deferment. cancellation, or forbearance benefits, I must make a written request to the school and must submit to the school any documentation the school requires to prove my eligibility for these benefits. I am responsible for submitting the appropriate requests on time. and I may lose my benefits if I fail to file my request on time. DEFAULT - If I fall to make a scheduled payment when due: if I fail to submit to the school. on or before the due date of a scheduled payment, documentation that I qualify for a deferment. cancellation, or forbearance: or if I fail to comply with the terms and conditions of this promis.sory note or written repayment agreement, the school may. at its option. declare my loan to be in default and may accelerate my loan (demand immediate payment of the entire unpaid balance of the loan. including principal, interest, late charges, and collection costs). The school, and the Secretary. if my loan is assigned to the Secretary for collection, shall disclose to credit bureau organizations that I have defaulted and all other relevant loan information. I will lose my right to defer payments and my right to forbearance if I default on my loan. I will lose my right to receive cancellation benefits for service that is performed after the date the school accelerated the loan. I will be ineligible for any further federal student financial assistance authorized under the Act until I make arrangements that are satisfactory to the school or the Secretary to repay my loan. CHANGE OF STATUS - I will inform the school of any change in my name. address, telephone number. Social Security number. or driver's license number. ASSIGNMENT - This note may be assigned by the school only to the United States. The provisions of this note that relate to the school shall where appropriate relate to the assignee. PROMISE TO PAY: I promise to pay the school. or a subsequent holder ofthe Promissory Note, the sum of amount(s) advanced to me under the terms of this Note, plus interest and other fees which may become due as provided in this Note. I promise to pay all reasonable collection costs, including attorney fees and other charges, necessary for the collection of any amount not paid when due. I will not sign this Note before reading it, Including the provisions on the reverse side. This loan has been made to me without security or endorsement. My signature cenifies I have read. understand. and agree to the terms and conditions of this Promissory Note. THIS IS A LOAN(S) THAT MUST BE REPA.lD __i~/aL /2/J/qg Date: !)f)!/' 1;,/_ ; VERIFICATION I, THOMAS MEYER, Assistant Treasurer of Dickinson College, acknowledge that I have the authority to execute this Verification on behalf of Dickinson College and certify that the foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of this lawsuit. The language of this Complaint is that of counsel and not my own. I have read the document and to the extent that this Complaint is based upon information which I have given to my counsel, it is true and correct and to the best of my knowledge, information and belief. To the extent that the content of this Complaint is that of counsel, I have relied upon counsel in making this Verification. This statement and Verification are made subject to the penalties of 18 Pa. C.S. 9 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. Dickinson College <2--\.. Thomas Meyer Assistant Treasurer of Dickinson College Dated: 7/9/03 F: \FILES\DA T A Fl LE\Dickinson College 7619\Di<:kinsonConeg~ColleClions 7619C\Documents\ 180 com - ~.'- C'! f~~ -" , . ( 1: "'-. ,- ~ ~ -- > -, ~ (\ - ........ ~ - \.\ 1..-,1 ~ ~ ""I ~ \)(\ --.1 '" "-l \) c ,) -q -..- ~ ....- .. "1 .J ()l --< F: \FILES\DA T AFILE\Dickinson College 7619\DickinsonCollegeCollections7619(" Created: 4/28/03 1:54:03 PM - Revised: 11/6/0310c58:14AM 'i\180,pral\mai DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-3261 CIVIL ACTION-LAW JOSEPH 1. DONAHUE, Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE Please reinstate the attached Complaint against Joseph 1. Donahue, in the above-captioned action and return same to the undersigned for service. David R. Galloway, Esquire J.D. Number 87326 Ten East High Street Carlisle, P A 17013 (717) 243-3341 B Date: November 6, 2003 Attorneys for Plaintiff () 0 0 C" W l~f ~: - .:'.~ "'Co, '".'- C:> Lrlr, "t!::: ", -'!.i z.. :;~ , r~. Z; - In en ' 0 ';1 -<..,; ";-,) (';, ~( , ~~'? -I", 2. -'..../"1 Z(:' :~1F~ J:; c: ~ -..,. ?g ~- '" --I "" r" -<: ... F:\FlLES\DA T AFILE\Dickinson College 7619\DickinsonColiegeColieclions7619C\CulTent\180_pra2\nlm Created4/2S/031:54:03PM Revised: S/26!042:5713 PM DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-3261 CJVIL ACTION-LAW JOSEPH 1. DONAHUE, Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE Please reinstate the attached Complaint against Joseph L. Donahue, in the above-captioned action and return same to the undersigned for service. By David R. Gallo J.D. Number 87326 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: August 26, 2004 Attorneys for Plaintiff 0 :;:; ~ ~ = .J:" -00:' ~ ~~ i~~ en N i3~ SQ,}:; -' r<C.i ~.,., J8 ~ %~ c - -'-t ~ (.1\ ~, (.1\ F: \FILES\DA T AFlLE\Dickinson COllege 7619\DickinsonCollegeCollections7619CICurrent\ 180. affduediJig Created: 6/13/0311:08AM Revised: 10/4/049A7AM 7619C.180 David R. Galloway, Esquire J.D. 87326 10 E. High Street Carlisle, PA 17013 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-3261 CJVIL ACTION-LAW JOSEPH 1. DONAHUE, Defendant JURY TRIAL OF TWELVE DEMANDED AFFIDAVIT OF DUE DILIGENCE AND COST OF ATTEMPTED SERVICE See attached Affidavit from Bernie Giusto, Sheriff ofMuJltnomah County, Oregon and receipt showing cost for attempted service in the amount of$29.00 ILLIAMS & OTTO Attorneys for Plaintiff Date: October 4, 2004 MUlTNOMAH COUNTY SHERIFF'S OFFICE 12240 NE GLlSAN S1:, . PORTLAND, OR 97230 BERNIE GIUSTO SHERIFF Exemplary service for a safe, livable community (503) 255-3600 PHON~ (503) 251.2484 TTY www.sheriff-mcso.org ~ County: CUMBERLAND Court Case: 033261 MCSO Case #: 2004.91409 Court CIRCUIT RE: DICKINSON COLLEGE VS. DONAHUE,JOSEPH L I hereby certify that the attached COMPLAINT SUMMONS waslwere delivered to me for service on the 07 day of September" 2004 . and waslwere duly certified to be true copy by . DONAHUE.JOSEPH L I further certify that after due and diligent search and inquiry, I haIJ9 been unable to find the within named party, to- wit DONAHUE,JOSEPH L within said state and <:ounty. Therefore, service was not made. BERNIE GIUSTO. Sheriff Multnomah County, Oregon By: ~2u~~ 7 EDWARDS,RODNEY ALBERT DPSST#:25677 Subscribed and sworn to before me this day of II~ It I 2604 . OfAClAl.SEAL ,. i lINDA D Me SWEENEY ',,/ NOTARYPUBl/C-OREGOH ' .-' COMMISSION NO. 3506t3 MY COMMISSION EXP RES OCTOBER 7 . - (') ~ <l;.... -ot~l:! ~iq:~: ~~<' .:< ~- r;( "'- li0. ~~ r--> ~ c:> " -< I .&:" '. """ ::It o -11 :::r!-n rn~ :g C;) S?l~>' k"'~ l,.-ItS Zrn S:'. ;!" ~ ~ W N - Multnomah County Sheriff's Off'ice CIVIL PROCESS UNIT MCSO Casa No. 9 / l.j 0 If Dale 9 - '8 - qo';/ Name: IJ1 oiu It 0 ~ /7./'-",-"",~~,;L; I - Address: City: State: Zip:. Amount Execution <2 71 tJ'O Court Case No. Type of Process Misc. Fees f)Jf~ PLAINTIFF v >< Amount Due Check# /3&0 / No. 8025721 Tola1 Received F IFILESIDA T AFILEIDickinsonCollege7619ICollectionsICurrentI1S0.pra3 Created: 11/17/04 S.44AM Revised. 11/17/04 S.47AM 7619C ISO David R. Galloway, Esquire MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-3261 CIVIL ACTION-LAW JOSEPH L. DONAHUE, Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE Please reinstate the attached Complaint against Joseph L. Donahue, in the above-captioned action and return same to the undersigned for service. MARTSON DEARD F WILLIAMS & OTTO By David R. Galloway, Esquire I. D. Number 87326 Ten East High S1treet Carlisle, PA 17013 (717) 243-3341 Date: November 17,2004 Attorneys for Plaintiff (-'} '....-' '. ,,-( r-' = :;~ (-) "f. :-:J 'IIfI':-. c., , ~, -;,1 c'1 (,.,q F.IFILESIDA T AFILElDickinsonCollege7619lCollectionslCurrentllSO.atfduedilig2 Created: 1/5/05 10.59AM Revised. 1/5105 2:20PM 7619C ISO David R. Galloway MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-3261 CIVIL ACTION-LAW JOSEPH L. DONAHUE, Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO FILE AFFIDAVIT OF DUI~ DILIGENCE TO THE PROTHONOTARY: Please file the attached Affidavit of Due Diligence from Multnomah County Sheriff s Office. The cost of attempted service was $29.00. F WILLIAMS & OTTO By Davl . Gal oway Attorney LD. No. 87326 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: January 5, 2005 Attorneys for Plaintiff MULTNOMAH COUNTY SHERIFF'S OFFICE 12240 NE GLlSAN ST., · PORTLAND, OR 97230 BERNIE GIUSTO SHERIFF Exemplary service for a safe, livable community (503) 255-3600 PHONE (503) 251-2484 TTY www.sheriff-mcso.org County: CUMBERLAND Court Case: 033261 MCSO Case #: 2004-95558 Court: : RE: DICKINSON COLLEGE VS. DONAHUE,JOSEPH L I hereby certify that the attached COMPLAINT NOTICE waslwere delivered to me for service on the 23 day of November, 2004 , and was/were duly certified to be true copy by . DONAHUE,JOSEPH L I further certify that after due and diligent search and inquiry, I have been unable to find the within named party, to- wit DONAHUE,JOSEPH L within said state and county. Therefore, service was not made. ~~ Subscribed and sworn to before me this day of ,7...[ "l- \ { ()~ ~~~~415b1, ary Public for Oregon My Commission Expires: lol1 rJ.005 OFFICIAL SEAL UNDA 0 Me SWEENEY , NOTARYPUBUC-OREGON COMMISSION NO. 350613 MY COMMISSION EXPIRES OCTOBER 7, (?2) (t~ !:.19 ~ Multnomah County Shel'iff's Office CIVIL PROCESS UNIT MCSO Case No. 9,5:55'8 Dale J /-25-4 Y Name: IJ7lJwfO ad- d0~ Address: City: " \ State:__ Zip: Amount .2 9 C/O Court Case No. f/ 3 -3 ~~ / Type of Process AJ~ Execution Misc. Fees 11~~Mt f2~~ Check # /37'15'/ N pnI1Rf')n /1, o. U' ! I t'::l 'I ',","" ~ 'lo.C !:i.... ,,! r.- Ii ! . Amount Due Total Received 27: t7ZJ IVd5l 8PST 17 PS 331 B o ~ <., ~(~~-' ~- "-:--. ~~r, ~ ~c:: l. ~E': \: "c C J;:'C. ~~ ~ c:::> c;=> c.n <- ~ % ..... 1 (J1 ~ :.:;:i fii:1J ::;; ~C? q t::> .- '" T-n ~~~ ( , =:t -0 ~ <2 N -.J ?D :< F \FI LES\OA T AFILE\OickinsonC C1l1ege7619\Collections\CUll"ent\ 180\ 180 pra4 Created 11/17/04844AM Revised: 12/14/05 11.20AM 7619(180 Christopher E. Rice, Esquire MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attol11eys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-3261 CIVIL ACTION-LAW JOSEPH 1. DONAHUE, Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE Please reinstate the Complaint against Joseph 1. Donahue, 1737 SE 39'h A venue, Portland, OR 97214 in the above-captioned action and retUl11 same to the undersigned for service. MARTS ON DEARDORFF WILLIAMS & OTTO By U~ ? K- Christopher E. Rice, Esquire I. D. Number 90916 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Date: December 14, 2005 Attorneys for Plaintiff () '" 0 = c::; = "Tl <.n < C1 --J "D (L! 1"'1 :r:::!) rn , " n1fT: ~'.- -~" -0 . ~.. -nO U} \D -.... I F . S~, :z,.. j" -ri ,2 ";1': 6~~ >~= C5 :;..': ~p.! -, CJl :n -< CO .-<; F ',FtLLSDA fAf/I_E\/Jid,i",0NC"llq;<:7b I 9\('c,))eCI,,")5\CiJfTl'JJII)"-0\ ISO prJ.j C'l'~I~J. I ].'17().j 8 .j.jA~l R<:qs<:d. :1,OIJI511'r..\ ~I,IO)C l~'.l Christopher E. Rice, Esquire MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PAl 70 \3 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-3261 CIVIL ACTION-LAW JOSEPH L. DONAHUE, Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE Please reinstate the Complaint against Joseph L. Donahue, 1737 SE 39th A venue, Portland, OR 972 I 4 in the above-captioned action and return same to the undersigned for service. MARTSON DEARDORFF WILLIAMS & OTTO BY~~ S fL- Christopher E. Rice, Esquire 1. D. Number 90916 Ten East High Street Carlisle, PAl 7013 (717) 243-3341 Date: February 17, 2006 Attorneys for Plaintiff -.,'1 -'n r-<' ~ - ", (", F \FI LES\DA TAFILr\Dickin,onColkgc76I 'J\C,-,lkc[;<)m\CllITClll\1 SUI I SiJ pl'a5 Cr~:\[cJ 1\/17IU-I b-l-lAM Rc,i;cd ~..')iI,'()b 'J ~bAM ihI9(.1::O Christopher E. Rice, Esquire MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-3261 CIVIL ACTION-LAW JOSEPH L. DONAHUE, Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE Please reinstate the Complaint against Joseph L. Donahue, 1737 SE 39th Avenue, Portland, OR 97214 in the above-captioned action and return same to the undersigned for service. MARTSON DEARDORFF WILLIAMS & OTTO By C-{ 1r.~ > r<---- Christopher E. Rice, Esquire 1. D. Number 90916 Ten East High Street Carlisle, PAl 70 13 (717) 243-3341 Date: April 10,2006 Attorneys for Plaintiff --\ 1.'.-"; c: r " F: IFILESIDA T AFILEIDickinsonCollege7619lCollectionslCurrent\1 SOIl SO.atfduedilig3 Created: 1/5/05 !0:59AM Revised: 619/06 9:0SAM 7619C.1S0 Christopher E. Rice, Esquire MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-3261 CIVIL ACTION-LAW JOSEPH L. DONAHUE, Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO FILE AFFIDAVIT OF DUE DILIGENCE TO THE PROTHONOTARY: Please file the attached Affidavit of Due Diligence from Multnomah County Sheriff's Office. The cost of attempted service at 1133 S.B. 27th Avenue, Portland, Oregon, was $29.00. MARTSON DEARDORFF WILLIAMS & OTTO BY~J.4 5".~ Christopher E. Rice, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: June 9, 2006 Attorneys for Plaintiff .. ... MULTNOMAH COUNTY SHERIFF'S OFFICE 12240 NE GLlSAN 51., · PORTLAND, OR 97230 BERNIE GIUSTO SHERIFF Exemplary service for a safe, livable community (503) 255-3600 PHONE (503) 251-2484 TTY www.sheriff-mcso.org County: CUMBERLAND Court Case: 933261 Meso Case I: 2006-126026 Court : RE: DICKINSON COLLEGE VS, DONAHUE,JOSEPH L I hereby certify that the attached COMPLAINT NOTICE waslwere delivered to me for service on the 18 day of April, 2006 , and waslwere duly certified to be true copy by , DONAHUE,JOSEPH L I further certify that after due and diligent search and inquiry, I have been unable to find the within named party, to- wit DONAHUE,JOSEPH L within said state and county. Therefore, service was not made, BERNIE GIUSTO. Sheriff Multnomah County, Oregon By: zg Xf1 ~ #--~Z DOYLE,BRIAN DPSST#:38072 Subscribed and sworn to before me this day of OFFICIAL SEAL . SUZANNE GEHRELS . NOTARY PUBUC-QREGON MY COMM1RR,~~~'~WSN~A~~N1~009 .. t-..:> = <=.:.> (.::.~ S lo..... ........ I 1...0 "'D :J2: CJ :~. - C) RECEIVE[ JUN 0 5 2006 MDW~ F:\FILESIDAT AFILEIDickinsonCollege76191CollectionslCurrentl 1 SOl ISO. praS Created: 11117/04 S:44AM Revised: 1/9/07 11:17 AM 7619C ISO Christopher E. Rice, Esquire MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-3261 CIVIL ACTION-LAW JOSEPH L. DONAHUE, Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE Please reinstate the Complaint against Joseph L. Donahue, 1133 S,E, 27th Avenue, Portland, Oregon 97214 in the above-captioned action and return same to the undersigned for service. MARTS ON DEARDORFF WILLIAMS & OTTO By CL./.r-L ~ ~ Christopher E. Rice, Esquire I. D. Number 90916 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Date: January 9,2006 Attorneys for Plaintiff ~ ~ "'() (.L' 1'"n\' , ~{. (J'1; ., ,. -;;: ~. r::;.C ,.- %1~~~..< 7C -z. 3. ~ ~:!1 -:b~ "') \ '3~\ ..,_-1'1 '"'" ,.., -""c' ':Jt "';?rf\ _ S ~ ~ ..p ~ ~ <- !i \ u:>