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Revised: 7/I0/03 I ]46:51 AM
DICKINSON COLLEGE,
Plaintiff
MEIKA WAHLSTROM,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 03- 2 _v z
C VIL ACT ON-L^W
JURY TRIAL OF TWELVE DEMANDED
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice are
served, by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to
do so, the case may proceed without you and a judgrnent 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
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
& OTTO
Attomeys for Plaintiff
Date:
DICKINSON COLLEGE,
Plaintiff
MEIKA WAHLSTROM,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03- 3.2 J'-L
CIVIL ACTION-LAW
JURY TRIAL OF TWELVE DEMANDED
COMPLAINT
AND NOW, comes Plaintiff Dickinson College by and through its attorneys, MARTSON
DEARDORFF WILLIAMS & OTTO, and hereby avers as follows:
1. Plaintiff Dickinson College is a Pennsylvania educational institution and nonprofit
corporation with its principle place of business at West Street, Post Office Box 1773, Carlisle,
Cumberland County, Pennsylvania 17013.
2. Defendant Meika Wahlstrom is an adult individual with a last known address of 2145
Nauset Road, Eastham, MA 02642-1721.
3. On or about August 26, 1996, Defendant entered into a Promissory Note - Federal
Perkins Loan Program (Note #1) with Plaintiff. AcopyofNote#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 August 31, 1997, 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 PlaintifFs institution.
7. On or about August 31, 1998, 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 $2,500.00 plus interest and costs by Defendant
on his own behalf, for educational services and benefits at Plaintiff's institution.
9. On or about August 30, 1999, 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 $2,000.00 plus interest and costs by Defendant
on his own behalf, for educational services and benefits at Plaintiff's institution.
11. Note #1, Note #2, Note #3 and Note #4 are funds created under Part E of Title IV
of the Higher Education Act of 1965 as amended, (hereinafter the "Act") and are subject to the Act
and the Federal Regulations issued under the Act.
12. 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.
l 3. The total principal for Note #1, Note #2, Note #3 and Note #4 is $8,500.00.
14. Note #1, Note #2, Note #3 and Note #4 grant Plaintiff reasonable collection and
attorney's fees which Plaintiff has calculated to be $1,275.00.
15. As of April 3, 2003, the principal and interest due and payable by Defendant to
Plaintiff was $8,913.06, plus interest accruing thereafter at $1.13 per day.
! 6. The outstanding balance of$8,913.06 represents the total and actual overdue value
of the financing provided to Defendant under Note #1, Note #2, Note #3 and Note #4 for which
Defendant has yet to pay.
17. Plaintiffhas fulfilled, performed and complied with all obligations and conditions of
Note #1, Note #2, Note #3 and Note #4.
COUNT I
BREACH OF CONTRACT
18. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 17 of this Complaint.
19. Defendant breached the expressed and implied obligations, conditions and terms of
agreement of Note #l, Note #2, Note #3 and Note #4 by failing to pay the amounts financed therein.
WHEREFORE, Plaintiffdemands judgment against Defendant in the amount of $8,913.06,
plus interest accruing at $1.13 per day, collection and attorneys' fees in the amount of $1,275.00 and
costs of suit.
COUNT II
IN 0 UANTUM MER U1T
20. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 19 of this Complaint.
21. Having requested Plaintiff to loan money, and doing so to the benefit of Defendant,
Defendant became liable to Plaintiff for said money.
22. Defendant has been unjustly enriched by accepting said money without paying
Plaintiff reasonable compensation therefor.
23. As of April 3, 2003, Defendant is liable to Plaintiff and/or has been unjustly enriched
in the amount of $8,913.06, plus interest accruing at $1.13 per day.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $8,913.06,
plus interest accruing at $1.13 per day, collection and attorneys' fees in the amount of $1,275.00 and
costs of suit.
Date:
S
ID. Number 87326
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Plaintiff
OTTO
Exhibit A
FEDERAL PERKINS LOAN
PROMISSORY NOTE
1. Name (last, firsL middle initial) and
Permanent Address (slTeet, city, state, zip code)
Wahlstrom, Meika
2. Social Security Number
3. Date of girth
4. Area Code/Telephone Number
5. Driver's License Number (List state abbreviation flint)
6. School Name & Address (sb'eet, city, state, zip code)
Dick/nsc~ Co! 1 ~cje
P.O. Bo~ 1773
Carl ~_,~le, PA 17013-2896
7. Borrower Status 8. Interest Rate
9. Loan Amount: ~ Period
$2000. O0 1996-97
TERMS AND CONDITIONS:
[Any bracketed cJatae or pa~raph may be included at option of Lr~RutionI
APPLICABLE LAW - The terms of this note and any disbursements made under this note shaU be intenpmted 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 sun~ advanced under this note are subject to the
Act and Federal regulations issued under the Act.
REPAY~vtENT - I am obligated to repay the principal and the interest that accrues on it to the above-framed institution {beteinafter called ~e school) over a period
beginning 9 months (or sooner if I am a less than a half-tim~ 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 Uniled ~tate~ Secretary of Education (hereinafter called the Secretary) and ending l0 yeats later, unle~ I
request in writing that my repayment parind 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. ]ntete~t on this loan shall accrue from the beginning of the repayment period. My repayment period may be shorter than l0 yeats if [ am
requited by my school to make minimum monthly paymenL~. Upon my written request my repayment period may be emended during periods of deferment, hardship, or
forbearance and I may make graduated instaaments in accordance with a schedule approved by the ~ecnetary. l will make my tmtallment payments in equal monthly.
bimonthly or qua~erly installments as determined by the school. The school may round my installment payment to the next highest multiple of $5. [1 will rnake a
minimum monthly repayment of $40 (or $30 if I have outstanding Federal Perkins loans nmde before October l, 1992 that included the $30 minimum payment option)
in accordance with the Minimum Monthly Payment Section or the Terrm and Conditions contained on the reverse side of this document.]
LATE CHARGES - The school will impose late charges if [ 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 beneftu as de-.crihed 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 ha~ 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 beneflu. ! must make a written request
to the school and mt~t submit to the scimol 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 Io~e my benefits if 1 fail to file my request on time.
DEFAULT - [f 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 prommory note or written repayment agreement, the
school may, at its option, declare my loan to he in default and may accelerate my loan (demand immediate payment of the entire unpaid balance of the loan. including
principal, inte~st, late charges, and collection cos~). The school, and the Secret~ry, if my loan is aasigneil to t}~ Secretary for collection. ~hail disclose to credit bureau
organizations that I have defaulted and all other relevant loan information. I will lo~e my right to defer payments and my right to forbearance ff I default on my loan. I
will I~e my tight to receive cancellation heneflt~ for se~ice 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 age 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, telaphone number, Social ~ecurity number, or driver's license number.
ASSIGNMENT - This note may be assigned by th~ school only to the [Jnised States. The provisions of this note that relate to the school shall where appropriate relate to
the a~aigne~.
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 prormae 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, lncluifing the provisions on the reverse side. This loan has b~en
made to me without security or endorsement. My signature certifies I ha~ read. understand, and agree to the terms and conditions of this Promis~ry Note. THIS IS A
LOAN(S) THAT MUST BE REPAID
Borrower s Signature
EXHIBIT "A"
Date:
Terms and Conditions (cont.)
HARDSHIP REPAYMENT OPTIONS - Upon my written request, ff I
qua]fly as a Iow-income individua] during the repayment period, the school
may extend the ~epayment pe~od for up to an addlUona] ten (10) years and
may adjust any repayment schedule to ~flect my income. Upon my written
request, the school may extend the repayment period if. in irt opinion.
prolonged illness or unemployment prevent me from making the scheduled
repayments during which time interest will continue to acon~e. The school
may permit me to pay less than the minimum monthly repayment rate for a
p~tod of not more than one year at a time ff I experience a period of
prolonged illness or unemployment except such action may not extend the
repayment period beyond 10 year~.
GRACE PERIODS- My initial grace period befor~ beginning repayment is 9
months. If I am a Less-Than-Ha]f-Time Borrower with outstanding Federal
Perkins Loar~. 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 P~ Loans. my repayment begins the earUer of: 9
months from the elate my loan was made. or 9 months from the date I became
less than a haft-time student, even if I ~celved the loan after [ became a less
~han haif-tirne student. My payments will resume after a post-deferment grace
period of 6 monks that follows deferments ~mt apply to Federal Perkins
loans.
PREPAYMENT - ! may prepay all or any part of my unpaid loan balance.
plus any accrued interest, at any time without penalty. Amounts ! repay in the
acaderrde year in which the loan was made and before the initial grace pr~od
be~ ended will be u~-d to reduce the amount of the loan and vail not be
considered a prepayment. If I repay amounts during the academic year in
which the loan was made m~d the irdOa] grace period ended, only those
amounts in excess of the amount due for any repayment period shall be
cormid~ed a prepayment. If, in an academic year other than the award year in
which the loan w~ made, I repay more than the amount due for an insta]l-
ment. th~ excess will be used to repay principal unless I designate it as an
advance payment of the next regular installment.
MINIMUM MONTHLY PAYMENT - I w~ make a minimum monthly
repayment of $40 (or $30 if I have outstanding Federal Perkim loans made
before October 1. 1992 that included the $30 minimum payment option) if
required by the school. If the total monthly repayment rote on this loan and
any outstanding Feclera] Peritins loans I may have is less than the minimum
monthly repayment rate established by the school, the school may still require
a minimum monthly repayment rate. A minimum monthly repayment
amount wUI combine my obUgaUon on this a~d all my outstanding Federal
Pedtins loans, Including those made at other schools. The porUon of the
minimum montidy payment that will be applied to this loan wig he the
difference between the minimum monthly payment and the total amounts
owed at a monthly rate on my otbet Federal Perkins loans. If each school
holding my ou~sr~cling Federal Perkins loans exercises the minimum monthly
payment opUon, the mmimmn 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 entidad to forbearance of principal and interest or principal
only, ~enewable at intervals up to 12 months for periods that collectively do
not exceed three years, under t~ foUowthg conditions; If my monthly Tide IV
loan debt burden equals or exceeds 20% of my totM monthly ~ income; if
the Sectetmy authorizes a period of forbearance due to a nationa] military
mohilization or other naUona] emergency; or if the school determines that I
qualify due to poor health or for other reasons, including service in
AmeriGorpa. ~terest accrues during any period of forbearance.
DEFERMENTS - Upon making a properly documented written request to
the school, ! may defer making scheduled instMlment payments and will not
be liable for any inte~st that might otherv~ accrue 1) during any period that
! am: enrolled and attending as a ragulat student in at least a half- Omc course
of study at an eligible school; enrolled and attending as a regular smdant a
graduate fellowship program approved by the ,~*etary; engaged in graduate
or post-g~aduate fellowship-supported study ou~ide the US: enrolled and
attending a rehabilitation training program for disabled individuals approved
by the Sec~etm'y; engaged in public service that qua]flies me to have part or all
of my loan c~nceled; 2) for a period not to e~ceed three years during which I
am seeking but unable to Fred flail-time employment. 3) for a period not to
exceed three years during which ! am experiencing an economic hardsinp as
determined by the school. ! am not eligible for a deferment while serving in a
medical i~ternship or residency program. I n-my conr/nue to defer making
scheduled insta]lment payments and will not be liable for any interest thst
might otherwise accrue for a six-month period immediately following the
expiration of any deferment period described m th~s paragraph.
· CANCELLATIONS - Upon making a properly documented written request
to the school. I am e~Utied to have up to 100% of the originel principal loan
amount of th~ loan canceled if ! pafform qua]flying service in the areas listed
in paragraphs A. B. C. D and E below. Qua]ifying Service must be performed
aft~ I receiv~ the loan.
A. Teaching · a full-time teacher in a public o~ other nonprofit elementa~ 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 ofstudenrt from low-ip~orne famUies. An official Divectocy of
designated Iow-income schools is published annually by the Secretm7. · a full-
time special education teacher in a public or nonprofit elementary or
second~cy school system. · a flail-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 o-x*pertJse that is
determined by the State Department of Education to have a shortage of
qua]ffled teachers in that State.
B. Early Intervention Services · a full-time qualified prnfes~iona] provider of
e~rly 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 EducaUon Act. Early Intewvention ,~'vices are provided to
C. Law Enforcement or Com. cUons Officer · a full-tune law enforcement
offcer for an eligible local, State, or Federal law enforcement agency: or - a
full-time corrections officer for an eligible local, State. or Federa] corrections
agency.
D. Nurse or Medicad Technician · a full-time nurse providing health care
services: or · a full-time medical technician providing health care se~ices.
E. Child or Family Service Agency · a full-time employee of an elllliifie public
or pti~ate 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 servlce under paragraphs A.
B. C, D and E a portion of this loan will be canceled at the following rates:
· 15% of the original principa] loan amount for each of the lust and second
yegg; · 20% of the ortgtna] principal loan amount for each of the third year
and fourth yea~: and · 30O/o of the origirad principal loan amount for the Fifth
E Head Start CancellaUon - Upon making a properly documented written
request to the school. I am entitled to have up to 100% of the origtoa]
principal loan amount c~ncelad for qualif3dng service performed after ! receive
the loan as: · a full-time staff member in the educaOonal component of a
Head Start program which is opera~d for a period comparable to a r~dl 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
CanceUation provision, this loan wUl be c,~nceled at the rate of 15% of the
origina] principal loan amount.
G. Military Cancellation - Upon making a properly documented written
r~luest to the school. ! am enUtied to have up to 50% of the principal amount
or' chis loan c~nceled for qua]flying service performed afte~ ! receive the loan
as: · a member of the Armed Forces of the United States in an area of
hostiUties that qualifies for special pay under section 310 of Title 37 of the
United Stat~ Code.
Cancellation Prate - For each completed year of service under the Military
CanceUation provision, this loan wi}l be canceled at the rate of 12 I/2% of the
original principal loan amount.
H. Volunteer Se~ice Cancellasinn - Upon making a properly documented
written mClUest to the school. ! am entitled to have up to 70% of the original
principal loan amount of this loan canceled for qua]flying service parformed
after ! received the loan as: · a volunteer uoder the Peace Corps Act: ° a
volunte~- under the Domestic Volunteer Service Act of 1973 (ACTION
programs).
Cancellation Pate - For each completed year of service under the Volunteer
~rvice Cancellation provision, a portion of this loan will be canceled at the
following rates:
· 15% of the original p~ncipa] loan amount for each of the lust and second
12-month periods of service; and ° 20% of the origina] ptincipa] loan amount
for each of the third and fourth 12-month periods of service.
I. Death and DL~biltiy Cancellation - ~n the event of my death, the school
will cancel the total amount owed on this l~an. If ! become permanently and
totally disabled after I receive this loan, the school will cancel the total amount
owed on this loan.
FEDERAL PERKINS LOAN
PROMISSORY NOTE
00273-000-00-3339-09
1. Name (last, first, middle initia§ and
Permanent Address (s~eet, cit~ state, zip code)
Wahlstrom, Meika
RR #2 2145 Nauset Rd.
Eastham, MA 02642-1721
2, Social Security Number
3. Date of Birth
4. ~ee Code/Telephone Number
-5. Driver's License ~umber (List s~ate abbreviation first)
6. School Name & Address (street, city, state, zip code)
Dickinson Co]lec3e
P.O. Box 1773
Carlisle, PA 17013-2896
7. Borrower Status 8. Interest Rate
~ Half-Brae (x greate~ J2~J Less tt~n half4ime 5%
9. Loan Amount: 10, Loa~ Period
$2,000.00 1997-1998
TERMS AND CONDITIONS:
REQUESTS FOR DEFERMENT, CANCELLATION OR FORBEARANCE - To receive deferment, ca~ellation, or forbearance benefits, I must make a written request
LOAN(S) THAT MUST BE REPAID
Rorrower'$ Signature EXHIBIT "g" Date:
Terms and Conditions (cont) .
H.,\RI)S}I[P REPAYMENT OPTION5 [:pon my wrm.~ request d I
may extend the repayment period for up to an addition~ mn (10) ye~ and
repayment period beyond lO ye~s
G~CE PERIODS - My inia~ ~ace pe~od ~fore begmning repayment ~ 9
mont[u. If [ am a Le~-Than H~r-Time Bo~ower wi~ ouutanding Federal
Perkins Loans. my repayment ~gi~ when the next ~heduled i~tallment of
P~PA~[ENT I may prepay all or m~y p~t of my unpaid Iota balance.
MINIMUM MONTHLY PATIENT - I ~mll make a minimum monthly
repayment or $40 (or $30 if I have outriding Federal Perki~ Ioa~ made
FORBEA~NCE - Upon making a properly d~ument~ ~itten requ~t to
DEFE~ENTS Upon ma~ng a properly d~umented ~[ten requ~t to
C,-\NCEi,LAI'IONS · Upon making a properly documented written request
in paragrap~ A, B. C. D and E below Qualirymg ~ce must ~ perfo~od
the provismm of ~ction 465(a)(2) of the Act ~m a school ~th a high
supemsion by a lead agency ~ authored by ~tion 672(2) of the Individuals
wi~ D~bi~ ~u~on Act. ~ly Intemen~on ~ic~ ~ provided to
C, ~w Enfo~ement or Co~tion$ ~cer · a full-~me law enforcement
agency
E. Child or Family ~ice Agency * a full-Omc employ~ of an eligible public
Oonal agency.
Unit~ [~tes Code
Cancellation ~te For each completed ye~ or semice under the Military
Cancellation promsion, t~s loan will ~ canceled at ~e rate of I~ b~2% of the
principal loan amount of ~s loan canceled for qualifying semite perfo~ed
volunt~r under the Domestic Volunteer ~mice Act of 1973 (ACTION
· ,RKt; (NDE],) TRtTH IN LEND[NC STATEMENT
DI~<INSON COLLEGE
Account Number 00273-000-00-3339-09
Name of Borrower Meika Wahlqtrom
Address RR #2 2145 Nauset Rd
Eastham, MA 02642-1721
ANNUAL PERC~lqTAG~
RATE
The cos= of your
credit as a yearly
rate.
AMOUNT FINANCED
amount of
credit provided
to you.
Prior =o During
repaymen= repayment
0 % 5
2.000.00
l=emiza=ion of the Amoun: Financed: $2.000.00
Amount given directly to you.
Late Charge:
If a pay~nent is late, you may be charged: $I.00 for =he 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.
Prepa3nnen=: If you pay off early, you will not have to pay a penalty.
See your promissory note for any addiulonal information about nonpayment, de-
fault, any required repayment in full before the scheduled date, and pre-
paymen=.
~IE BORROWER ACK~NOWLEDGES RECEIPT OF AN EXACT COPY OF THIS STATEMENT.
BORROWER
INSTITUTIONAL
REPRESENTATIVE
DATE
Exhibit C
~hRL[,,,S (>!I}SL) TRUTI{-I['I Li'iNDINt; STATE,"IENT
DIC~INSCN COLLEGE
Accoun: Number 00273-000-00-3339-09
Name of Borrower Meika Wmhl~trnm
Address 2145 Nauset Rd., RR 2
Eastham, MA 02642
A~NI~JAL PERCENTAGE
RATE
Tlue cost of your
credit as a yearly
rate.
AMOUNT FINANCED
l~he amoun= of
credit provided
=o you.
Prior to During
repayment repayment
0 % 5 %
$ 2,foo.oo
Itemization of the Amount Financed:
Amount given directly to you.
Late Charge:
If a payment is late, you may be charged: $i.00 for =he first
late payment, and $2.00 for each subsequent late payment if
this loan is payable monthly, $3.00 for each late paymen= if
this loan is payable bimonthly, $6.00 for each late paymen~
if this loan is payable quar=erly.
Prepayment: If you pay off early, you will not have to pay a penalty.
See your promisso~% no~a for any additional lnforma=ion about nonpayment, de-
fault, any required repayment in full before the scheduled date, and pre-
payment.
TIE BORROWER A~--~<~NOWLEDGES RECEIPT OF AN E.~LkCT COPY OF THIS STATF~MMNT.
BORRO~qER
INSTITUTIONAL
REP.~ESENTATIVE
EXHIBIT "C"
FEDERAL PERKINS LOAN
PROMISSORY NOTE
00273-000-00-3339-09
1. Name (last, first, middle initial) and
Permanent Address (s~-eet, city, state, zip code)
Wahlstrom, Meika
2145 Nauset Rd., RR 2
Eastham, MA 02642
2. Social Security Number
027-60-1293
3. Date of Birth
4. ~%rea Code/Telephone Number
(SOR) 755-5315
5. Driver's License Number (List state abbreviation first)
6. School Name & Address (street, city, state, zip code)
Dickinso~ College
P.O. Box 1773
Carlisle, PA 17013-2896
7 Borrower Status 8. Interest Rate
9. Loan Amount: ~ Period
$2,500.00 1998-1999
TERMS AND CONDITIONS:
[Any b~acketed clause or paragraph may be included at option of insut ution,]
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 196fi. 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 obit§atari 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 [ am a lex than a half-time borrower) after the date I cease to be at [e~t 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 l0 years later, unless l
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. Interest 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 i~stallments in accordance with a schedule approved by the Secretary. I will make my installment payments in equal monthly,
bimonthly or quarterly installments ~ determined by the school. The school may round my installment payment to the next highest multiple of $S. [l will make a
minimum monthly repayment of $40 (or $30 if I have outstanding Federal Perkins loans made before October I, 199Z 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 wig impose [ate charges if I do not make a scheduled payment when due or if ! 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 tokay
exceed Z0% of my mo~thly, bimonthly or quarterly payment The school may add the [ate 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 charier, and such notice is sent before the next ic~tallment is due,
REQUESTS FOR DEFERMENT, CANCELLATION OR FORBEARANCE - To receive deferment, cancellation, or forbearance benefits, I must cnake a written request
to the school and mu~t submit to the school any documentation the school requires to prove my eligibility for these benefits. I am responsible for submitting the
appropriate requests or~ time, and I may Pose my benefits if 1 fail to file my request on time,
DEFAULT if I fad 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 l
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 [ have defaulted arid 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 f~nancia[ assistance authorized under the Act until [ make arrangements that are satisfactory to the school or the Secretary to repay my loan,
CHANGE OF STATUS - l will inform the school of any change in my name. address, telephone number. Social Security number, or driver's hcens¢ number.
ASSIGNMENT This note may be assigned by the school only to the United States. The provisior~ of this note that relate to the school shall where appropriate relate to
the asstg nee
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 terrr~ 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 loc 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 wlthout security or endorsement My signature certifies I have read. understand, and agree to the terms and conditions Of this Promissory Note THIS IS A
LOAN(S) THAT MUST BE REPAID
Date:
Terms and Conditions (cont.)
HARDSHIP REPAYMENT OPTIONS L;pon my wrttterl request, ir I
may extend the repayment period for up to an additional ten (10) years and
repayment period beyond 10 years
GRACE PERIODS - My initial grace period before beginning repayment is 9
mnnths If [ am a L.exs-Than,Half-Time Borrower with outstanding Federal
my outstanding loan is due If [ am a Less-Than Half-Time Borrower with no
outstanding Federal Perkins Loans. mx repayment begins the earlier of: 9
months from the date my loan was made. or 9 months from the date I became
than half-time student. My payments will resume after a post deferment grace
period of 6 months that follows deferments that apply to Federal Perkir~
C,~kNCELLATIONS Upon making a properly documented ~vntten request
· to the school, I am entitled lo have up to 100~Yo of the original pnncipal loan
in paragraphs A, B. C. D and E below Qualifying Service must be performed
after I receive the loan,
the pro~asions of ~ectaon 455(a) (2) of the Act as a school with a high
designated low-income schools ts published araauaily by the Secretary · a full-
foreign languages, bilingual education, or any other field of expertise that is
B. Early I~tervention Services · a full time qualified professional provider of
super-nsion by a lead agency as authorized by section 6~g(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-t~me law enforcement
officer for an eligible local, State, or Federal law enforcement agency; or ° a
full-time correctior~ officer for an eligible local. State, or Federal corrections
agency
D. Nurse or Medical Technician ° a full-time nu~e prodding health care
E. Child or Family Service Agency · a full4ime epnployee of an eligible public
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 foilowing rates:
· 15% of the original principal loan amount for each of the Ftrst and second
&nd fourth years: and * 30% of the original principal loan amount for the fifth
E Head Start Cancellation Upon making a properly documented wntsen
request to the school, [ am entitled to have up to 100% of the original
tional agency.
Cancellation Pate - For each completed year of service under the Head Start
Cancellation provision, this loan will be canceled at the rate of IS°/o of the
original principal loan amount
G. Military Cancellation - Upon making a properly documented written
of this loan canceled for qualifying service performed after I receive the loan
hostilities that qualifies for special pay under section 310 of Title 37 of the
United States Code
Cancellation Pate For each completed year of service under the ~q[ilitary
Cancellation provision, Otis loan will be canceled at the rate of t~ I/~% of the
H. Volurtteer Service Caiacellation - Upon making a properly dc<umented
volunteer under the Domestic Volunteer Service Act of 1973 (ACTION
programs)
Exhibit
P!;RKfNS (NI)S[,) TR[/'?H~[N LEND[N(] STATE?lENT
DI CKiNSCN COLLEGE
Account Number 00273-000-00-3339-09
Name of Borrower M~ W~h]~rnm
Address 2145 Nauset Rd, RR 2
Eastham, MA 02642
A~YN-UAL PERCENTAGE
RATE
The cost of your
credit as a yearly
rate.
AMOUNT FINANCED
The amount of
credit provided
to you.
Prior to During
repayment repayment
0 % 5
$ 2,000.00
Itemization of the Amount Financed: $ 2,000.00
Amount given directly to you.
Late Charge:
If a payment is late, you may be charged: $i.00 for the first
la~e payment, and $2.00 for each subsequent late paymen~ if
=his loan is payable monthly, $3.00 for each late payment if
this loan is payable bimonthly, $6.00 for each late payment
if this loan is payable quarterly.
Prepayment: If you pay off early, you will ~pt 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.
T]IE BORRO6q~R ACK.NOW-LEDGES RECEIPT OF AN E~Y_ACT COPY OF THIS STATE~ENT.
INSTITUTIONAL
REPRESENTATIVE
EXHIBIT "D"
FEDERAL PERKINS LOAN
PROMISSORY NOTE
00273-000-00-3339-09
1. Name (last, first, middle initial) and
Permanent Address (sb'eet, city, state, zip code)
Wahlstrom, Meika
2145 Nauset Rd, RR 2
Eastham, MA 02642
2. Social Security Number
3. Date of Birth
4. Area Code/Telephone Number
(508) 255-5315
5. ~rhler's License Number 0Jst stat~ abbre~aflon
6. School Name & Address (street, city, state, zip code)
Dickinson College
P.O. Box 1773
Carlisle, PA 17013-2896
7. Borrower Status 8. Interest Rate
9. Loan Amount: 10. koa~ ~ Period
$2,000.00 1999-2000
TERMS AND CONDITIONS:
REQUESTS FOR DEFERMENT, CANCELLATION OR FORBEARANCE - To receive deferment, cancellation, or forbearance benefits, I must make a written request
LOAN(S) THAT MUST BE REPAID
Borrower's Signature
Terms and Conditions
HARDSHIP REPAYMENT OPTIONS [pun my written request, if
qualify as a low-income individual during the repayment period, tile 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 il'. in its opinion,
prolonged glne&s or unemployment prevenl me 6rorr~ making the scheduled
repayments during which time interest wig 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 tune ~f 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 perind before beginning repayment is g
months If I am a Leas-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 my loan was made, or § months from the date l became
less than a half-time student, even If I received die loan after I becmme 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
PREPAYMENT I may prepey all or any part of my unpaid loan balance.
plm 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 t~sed to reduce the amount of the loan and will not be
considered a prepayment. If i repev amounts (luring the academic year in
which the loan was made and the initial grace period ended, only those
MINIMUM MONTHLY PAYMENT 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) if
required by the school. If the total monthly repayment rate on this loan and
any outstanding Federal Perkins loans ! may have is less than the minimum
monthly mpeyment rate e~tablisbed by the school, the school may still require
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 monthly rate on my other Federal Perkir~s loans If each school
holding my outstanding Federal Perkins klans exercaes the ~hinimum monthly
payment option, the mtnimttm 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 ennfled to forbearance of pnncipal and interest or principal
only, renewable at intervals up to 12 months for periods that collectively do
not exceed three years, under the following conditions: If my monthly Title IV
loan debt burden equals or exceeds 20% of mv total monthly gross income; if
the Secretary authorizes a period of forbearance due to a national militaW
mobilization or other national emergency: ar if the school determines that 1
qualify due to poor health or for other reasons, including service tn
AmeriCorps. Interest accrue~ during any period of forbearance.
DEFERMENTS Upon making a properly documented written request to
the school. I may defer mating scheduled installment payments and will not
be liable for any interest that might otherwise accrue 1) during any period that
! am: enrolled 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 progra2n 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 qual~fies me to have part or all
~f my loan canceled: 2) for a period not to exceed three years during which I
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 [ perform qualifying service in the areas listed
in paragraphs A, B, C, D and E below. Qualifying Service mint 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 provisions of section 465(a)(2) of the Act as a school with a high
concentration of students from Iow-income families An o~cial Directory of
designated tow income schools is published annually by the Secretary. · a fi~ll-
tame 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.
B. Early Intervention Services · a full-time qualified professional provider of
early intervention services in a public or other nonprofit program under public
supepnsion by a lead agency as authorized by section 672(2) of the Individuals
with Disabilities Education Act. Em'ly 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 agencyl 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
serwcesl or ° a full-time medical technician providing health care services.
E. Child or Family Ser¥ice Agency * a full-time employee of an eligible public
or private non-profit child or family service agency who is providing or
supep~sing 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,
I3, C, D and E a portion of this loan will be canceled at the following rates:
· 16% of the original principal loan amount for each of the first and second
years~ ° ~D% 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
volunteer under the Domestic Volunteer Service Act of 1973 fACTION
programs)
VERIFICATION
I, THOMAS MEYER, Assistant Treasurer of Dickinson College, acknowledge that I have
the authority to execute this Verification on behalf of Dickinson College and certify that the
foregoing Complaint is based upon information which has been gathered by my counsel in the
preparation of this lawsuit. The language of this Complaint is that of counsel and not my own. I
have read the document and to the extent that this Complaint is based upon information which I have
given to my counsel, it is tree and correct and to the best of my knowledge, information and belief.
To the extent that the content of this Complaint is that of counsel, I have relied upon counsel in
making this Verification.
This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904
relating to unsworn falsification to authorities, which provides that if I knowingly make false
averments, I may be subject to criminal penalties.
Dickinson College
Tho~ &
Assistant Treasurer oT Dickinson College
Dated:
DICKINSON COLLEGE,
Plaintiff
MEIKA WAHLSTROM,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03- 3282
CIVIL ACTION-LAW
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE TO DOCUMENT SERVICE AND COST OF SERVICE
PURSUANT TO THE PENNSYLVANIA LONG ARM STATUTE
I hereby certify that a copy of the Complaint was mailed to Meika Wahlstrom on September
3, 2003, by certified mail, restricted delivery, return receipt requested.
Attached is the Post Office remm receipt signed and dated September 9, 2003 and a copy
of the receipt showing the cost of service was $8.61.
MARTSON DEARDORFF WILLIAMS & OTTO
David R. GallowaXf;-F~quire /
I.D. No. 87326 ~
Ten East High Street ~
Carlisle, PA 171)13-3093
(717) 243-3341
Date: September 17, 2003 Attorneys for Plaintiff
· Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivm7 Is desired.
· Pdnt your name and address on the reverse
so that we can return the card to you.
· Attach this card to the back of the mailpiece,
or on the front if spec, e permits.
If YES, enter delivery add ~ i i
2. Article Numbe~
PS Form 3811, Aught 2001
7001 2510 0006 5862 9398
(Endorsement Required)
(Endorsement Required)
'"
CERTIFICATE OF SERVICE
I, Marti Iben, an authorized agent ofMartson DeardorffWilliams & Otto, hereby certify that
a copy of the foregoing Praecipe to Document Service and Cost of Service Pursuant to the
Pennsylvania Long Arm Statute was served this date by depositing same in the Post Office at
Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Ms. Meika Wahlstrom
46 Tremont No. 2
Brighton, MA 02135
MARTSON DEARDORFF WILLIAMS & OTTO
Marti lben
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: September 17, 2003
DICKINSON COLLEGE,
Plaintiff
MEIKA WAHLSTROM,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03- 3282
CIVIL ACTION-LAW
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE
TO THE PROTHONOTARY:
Enter default judgment in the above-captioned action in favor of Plaintiff and against
Defendant in the amount of $8,913.06, plus interest from April 3, 2003, in the amount of $251.99,
attorneys' fees in the amount of $1,275.00 for a total of $10,440.05, plus interest accruing at $1.13
per day and costs of suit for Defendant's failure to file an answer to the Complaint.
I do hereby certify that a written notice of intention to file this Praecipe (in the form attached
hereto) was mailed to the Defendant at the address indicated thereon, on October 22, 2003, which
date was subsequent to the date default occun'ed and at least ten (10) days prior to the date of the
Praecipe.
Dated: November 12, 2003
MARTSON, DEARDORFF, WILLIAMS & OTTO
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
DICKINSON COLLEGE,
Plaintiff
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. 03- 3282
CIVIL ACTION-LAW
JURY TRIAL OF TWELVE DEMANDED
MEIKA WAItLSTROM, DEFENDANT
NOTICE OF ENTRY OF DEFAULT JUDGMENT
You are hereby notified that on ,2003, the following Judgment was entered
MEIKA WAHLSTROM,
Defendant
TO:
against you in the above-captioned case: [I]n the amount of $8,913.06, plus interest from April 3,
2003, in the amount of $251.99, attorneys' fees in the amount of $1,275.00 for a total orS 10,440.05,
plus interest accruing at $1.13 per day and costs of suit.
Date:
I hereby certify that the name and address of the proper person to receive this notice under
Pa. R. Civ. P. 236 is:
Meika Wahlstrom
46 Tremont #2
Brighton, MA 02135
DICKiNSON COLLEGE,
Plaintiff
MEIKA WAHLSTROM,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03- 3282
CIVIL ACTION-LAW
JURY TRIAL OF TWELVE DEMANDED
l_
NOTICE OF INTENTION TO FILE PRAECIPE
FOR ENTRY OF DEFAULT JUDGMENT
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU.
UNLESS YOU ACT WITHiN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
NOTICE TO A LAWYER AT ONCE. 1F YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
Date: October 22, 2003
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
& OTTO
CERTIFICATE OF SERVICE
I, Marti lben, an authorized agent ofMartson DeardorffWilliams & Otto, hereby certify that
a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at
Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Meika Wahlstrom
46 Tremont #2
Brighton, MA 02135
MARTSOCDEARDORFF WILLIAMS & OTTO
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: November 12, 2003
F.\FILESff)ATAFILEkDickinsonCollege7619\Collections\Current\ 182.pra3/jmt
Created: 12/14/04 0 38PM
Revised: 12/14/04 4:07PM
7619C. 182
David R. Galloway, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attomeys for Plaintiff
DICKINSON COLLEGE,
Plaimiff
Vo
MEIKA WAHLSTROM,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03- 3282
CIVIL ACTION-LAW
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please mark the judgment in the above-captioned case: satisfied and issue a certificate
reflecting the same.
MARTSON D~a~dLDQa~F WILLIAMS & OTTO
BYDavid R. Galloway, Esquire \
I.D. Number 87326 )
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Plaintiff
Date: December 15, 2004
CERTIFICATE OF SERVICE
I, Jean Taylor, an authorized agent for Martson Deardorff Williams & Otto, hereby certify
that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at
Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Meika Wahlstrom
P.O. Box 730
North Eastham, MA 02651-072;0
MARTSON DEARDO~~/di~MS & OTTO
~ear l~sleSj pH~g~l 7~]~et
(717) 243-3341
Dated: December 15, 2004