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Crealed:4128/031:54:03PM
Revised:7I1010311:49:03AM
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03- 3.U1. ~ ,............
CIVIL ACTION-LAW
DICKINSON COLLEGE,
Plaintiff
SIUCHUNG T. LEE,
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 objections to the claims set forth against you. You are warned that if you fail to
do so, the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiffs. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Peunsylvania 17013
Telephone (717) 249-3166
Attorneys for Plaintiff
Date: 7)v)o3
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03- 3:l.fl, ~ T~
CIVIL ACTION-LAW
DICKINSON COLLEGE,
Plaintiff
SIUCHUNG T. LEE,
Defendant
JURY TRIAL OF TWELVE DEMANDED
COMPLAINT
AND NOW, comes Plaintiff Dickinson College by and through its attorneys, MARTS ON
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 Siuchung T. Lee is an adult individual with a last known address of I 0215
62nd Drive, 2nd Floor, Forest Hills, New York 11375-1055.
3. On or about November 16, 1990, 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$l ,500.00 plus interest and costs by Defendant
on his own behalf, for educational services and benefits at Plaintiffs institution.
5. On or about October 10, 1991, 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$3,000.00 plus interest and costs by Defendant
on his own behalf, for educational services and benefits at Plaintiffs institution.
7. On or about October 30, 1992, 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. Note #1, Note #2 and Note #3 are funds created under Part E of Title IV ofthe Higher
Education Act of 1965 as amended, (hereinafter the "Act") and are subj ect to the Act and the Federal
Regulations issued under the Act.
10. 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.
11. The total principal for Note #1, Note #2 and Note #3 is $7,000.00.
12. Note#l, Note #2 and Note #3 grant Plaintiffreasonable collection and attorney's fees
which Plaintiff has calculated to be $1,050.00.
13. As of April 3, 2003, the principal and interest due and payable by Defendant to
Plaintiffwas $7,595.96, plus interest accruing thereafter at $.90 per day.
14. The outstanding balance of$7,595.96 represents the total and actual overdue value
of the financing provided to Defendant under Note #1, Note #2 and Note #3 for which Defendant
has yet to pay.
15. Plaintiffhas fulfilled, performed and complied with all obligations and conditions of
Note #1, Note #2 and Note #3.
COUNT I
BREACH OF CONTRACT
16. Plaintiff hereby incorporates by reference the averments contained in Paragraphs I
through 15 of this Complaint.
17. Defendant breached the expressed and implied obligations, conditions and terms of
agreement of Note #1 and Note #2 by failing to pay the amounts financed therein.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of$7,595.96,
plus interest accruing at $.90 per day from April 3, 2003, collection and attorneys' fees in the amount
of $1 ,050.00 and costs of suit.
COUNT II
IN QUANTUM MERUIT
18. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 17 of this Complaint.
19. Having requested Plaintiffto loan money, and doing so to the benefit of Defendant,
Defendant became liable to Plaintiff for said money.
20. Defendant has been unjustly enriched by accepting said money without paying
Plaintiff reasonable compensation therefor.
21. As of April 3, 2003, Defendant is liable to Plaintiff and/or has been unjustly enriched
in the amount of$7,595.96 plus interest accruing at $.90 per day.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of$7,595.96,
plus interest accruing at $.90 per day from April 3, 2003, collection and attorneys' fees in the amount
of $1 ,050.00 and costs of suit.
F WILLIAMS & OTTO
B.l....::::
David R. Galloway
I.D. Number 87326
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Plaintiff
Date: 1);0/03
Exhibit A
PERKINS (NDSL) TRUTH-IN-LENDING STATEMENT
DICKINSON COLLEGE
Account Number
000-00-2587-07
Name of Bor.t'o,",er
Siu Chung Lee
Address
317 Sundridge Drive
Buffalo, NY 14228
ANNUAL PERCEN'l'AGE
RAn:
AMOUN'l' FINANCED
The cost of your
credit as a yearly
rate.
The amount of
credit provided
to you.
Prior to
repaytllent
During
repaytllent
o %
5 %
$ 1.500.00
I Itemization of the Amount Financed: $ 1.500.00
Amount given directly to you. I
Late Charge: If a paytllent is late, you will be charged: $1.00 for the first
late paytllent, and $2.00 for each subsequent late paytllent if
this loan is payable monthl.y, $3.00 for each late paytllent if
this loan is payable bimonthly, $6.00 for each late paytllent
if this loan is payable quarterly.
Prepayment: If you payoff early, you ~ll ~ have to pay a penalty.
See your promissory note for any additional information about nonpayment, de-
fault, any required r~payment in full before the scheduled date, and pre-
payment.
THE BORROWER ACKNOlo1UDGES RECEIl'T OF AN EXAC! COPY OF THIS STATEMENT.
STUDENT /1 "/
BORROWER d>:Jh.lIINj/'lt ~
DATE t I (I b I q t!
INSTI'IU'I'IONAL
REPRESENTATIVE
DATE 1/((.('10
EXHIBIT "A"
~/~
J
iJll",i\lIl.)Ull l..ULLt.l;lt:.
Carlisle, PA 17013
Tel: 717-245-1383
PROMISSORY NOTE - PERKINS ~OAN PROGRAM
[Any bracketed clause or palagraph may be included at option of institution.]
I, Siu Chunq Lee promise to pay to Dic:kin<;.an CollE'ge Iheremafter
called the Lending Institution} located at r.i'Ir1 i <>.1 p Ppnnc:yl Ifi'lni i\ the sum 01 the amounts that are advanced to me and en
dorsed in the Schedule of Advances set forth below. I promise to pay all attorney's fees and other reasonable collection costs and charges necessary lor the
coHection 01 any amount not paid when due. I further understand and agree that:
I. GENERAL
(1) ArlOlicable law All sums advanced under this note are drawn from a fund created under Part E of Title IVof the Higher Education Act of 1965, as
amended, hereinafter called the Act, and are subject to the Act and the Federal Regulations issued under the Act. The terms of this note shall be interpreted in
accordance with the Act and Federal Regulations, copies of which are to be kept by the Lending Institution.
(2) Procedures for Receivino Deferment or Cancellation I understand that in order to receive a deferment or canceHation, I must request the deferment or can.
cellation in writing from the Lending Institution, and must submit to the lending Institution any documentation required by the Lending Institution to prove that
I qualify for the deferment or cancellation. I further understand that ill am eligible tor deferment or cancellation under Articles Vi through XI. I am responsible
for submitting the appropriate requests on time. I turther understand that 1 may lose my determent and cancellation benefits if I fail to file my request on \lme
II. INTEREST
Interest shall accrue from the beginning of the repayment period and shall be at the ANNUAL PERCENTAGE RATE OF FIVE PERCENT 15%) on the unpaid
balance, except that no interest shall accrue during any deferment period described in paragraph Vl(t)
III. REPAYMENT
(1) I promise to repay the principal and the interest which accrues on it to the lending Institution over a period beginning 9 months after the date I cease to be
at least a half.lime student at an Inslltution of higher education, or at a comparable institution outside the United States approved for this purpose by the
United States Secretary of Education (hereinatter called the Secretary), and ending 10 years later, unless that period is shortened under paragraph 111(5). or ex.
tended under paragraphs 111(41, 111m {extenslonsl, or VI(11 (defermentsl.
(2) Upon my written request, the repayment period may start on a date earlier than the one indicated in paragraph HI(1).
(3) (A) I promise to repay the principal and interest over the course of the repayment period in equal monthly, bimonthly or quarterly installments, as deter.
mined by the lending Institution. I understand that if my monthly payment for all the loans made to me by the lending Institution is not a multiple of $5, Ihe
Lending institution may round that payment to the next highest dollar amount that Is a multiple of $5.
(Bl Notwithstanding paragraph 11I(3)(A), upon my written request, repayment may be made in graduated installments in accordance with a schedule
approved by the Secretary
(C) The lending Institution shail attach the schedule 01 repayments and the schedule will become part olthe note,
(4) Notwithstanding paragraph IIIPI, if I qualify as a low.income individual during the repayment period, the Lending Institution, upon my written request, may
extend the repayment period lor up to an additional 10 years, and may adjust any repayment schedule to reUect my income.
[(5}(A) If the monthly rate that would be established under paragraph III(t). or the total monthly repayment rate 01 principal and interest on OIl! my Perkins
loans including this loan, Is less than $30 per month, t shall repay the principal and Interest on this loan at the rate of $30 per month (which includes both prin.
cipal and interestl.
(5) (B) If I have received Perkins loans from other institutions and the total monthly repayment rate on those loans is less fhan $30, the $30 monthly paymenf
established under subparagraph 1I1(5)(A) includes the amounts I owe on all my outstanding Perkins Loans including those received from olher institutions. The
amount of this $30 monthly payment that will be applied to this loan will be the difference between $30 and the total of the amounts owed at a monthly rate en
my other Perkins loans.
(61 The lending Institution may permit me 10 pay less than the rate of $30 per month for a period of not more than one year where necessary to avoid
hardship to me unless that action would extend the repayment period in paragraph 111(1).)
(7) The lending Institution may, upon my written request, reduce any scheduled repayments or extend the repayment period indicated in paragraph 1I1( 1), if.
in its opinion, extraordinary circumstances such as prolonged illness or .unemployment, prevent me from making the scheduled repayments. However, inter.
est shall continue to accrue.
IV. PREPAYMENT
(1) I may, at my option and without penalfy, prepay all or any part of the principal. pius the accrued interest thereon, at any time.
(2) Amounts I repay in the academic year in which the loan was made will be used to reduce the amount of the loan and will not be considered a prepaymerlt
13) If I repay more than the amount due for any installment, the excess will be used to prepay principal unless I designate it as an advance payment of the
next regular installment.
V. DEFAULT
(1) The lending Instifution 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 fhe repayment schedule established by the lending Institution, and
(6) I do not submit to lhe Lending Institution on or before the date on which payment is due, documentation that I qualify for a deferment or cancellation
described in Articles VI, VII, VIII. IX, X, or XI of this agreement.
!2) I understand fhat if I default on my loan. the Lending Instilution may disclose that I have defaulted, along with other relevant information, to credit bureau
organizations.
(3) Further, I urlderstand lhal if I delault on my loan and the loan is transferred to fhe Secretary for collection, the Secretary may disclose that i have del<!ul~ed
along with other relevant information, to credit bureau organizations.
!4) I understand that after the Lending Institution accelerates the loan under paragraph V(1). I will then lose my right fo defer repayments due alter the dJ.le
the lending Institution accelerates the loan
(5) I understand that alter the lending Institution accelerates the loan under paragraph V(tl, I will then lose my right to receive a canceilation of a portion of
my loan for any teaching, volunteer or military service described in Articles VII, VIII and IX, performed alter fhe date the lending Institution accelerated the loan
(5) I understand that failure to pay this obligation under the terms agreed upon will prevent my obtaining additional student financial aid authorized under
Title IV of the Higher Education Act of 1965, as amended, until I have made arrangements which are satisfactory to the Lending Institution or the Secretary
regarding the repayment of the loan.
VI. DEFERMENT
(1) t understand that upon making a properly documented writfen request to the lending 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) While I am enrolled and in attendance as at least a half.time student at an institution of higher education or at a comparable institution oulside the
United Slates approved for this purpose by the Secretary:
(Bl For a period 01 three (3) years during which I am n
Ii) On full.time active duty as a member of the AImed Forces of the United States (Army, Navy, Air Force, Marine COfpS, or Coast Guard) or the
~!ational Oceanic and Atmospheric Administration Corps, or as an ollicer on full.lime active duty in the Commissioned Corps of the United States Public
Health Service.
Iii) In service as a volunfeer under the Peace Corps Act,
Iii i) A volunteer under the Domestic Volunteer Service Act of 1973 IACTlQN programs),
(Iv) A full-time volunleer in a tax-exempt organization performing service comparable 10 the service performed in lhe Peace Corps or under the
Domestic Volunteer Service Act of 1973. or
(v) Temporarily totally disabled as established by an affidavit ol a qualified physician. or unable to secure employment because t am prO"iding caie
'squ:.'!d oj' a d",pe:-:d!:!:'l! who ;s sc dic.:lblcd;
(C; For a period not in excess ot two 121 years n
(i) After I receive a baccalaureate or professional degree during which time I am serving in an internship which 15 required in order that I may receive
professional recognition required to begin my professional practice or service, or
(ii) serving in an infernship or residency program leading 10 a degree or certificate awarded by an institufion of higher education, a hospital or a heai1h
-:are facility that offers postgraduate training:
(01 For a period not in excess of one (1) year during which, if I am a mother of preschool age children, I have entered or reentered the work force, and am
being paid at a rate which does not exceed $1.00 above the minimum hourly wage establIshed by section 6 01 the Fair LebOf Standards Act of 1938:
(E) For a period not in excess of six months..
(i) That follows by six months or less 01 a period during Which I was enrolled as at least a half.lime student at an eligible Institulion: and (ii) During
which I am pregnant. caring for my newborn baby, or caring for a child immediately after he or she was placed with me through adoption and I am neither
attending an eligible institution 01 higher education nor gainfully employed: and
(F) During a six (6) month period immediately following the expiration of any deferment provided in paragraphs VI(1 )(A) through VI(l)(E).
(2) The lending Institution may, upon my written request, defer my scheduled repayments If it determines that the deferment is necessary to avoid a financial
hardship for me. Interest, however, will continue to accrue.
VII. CANCELLATION FOR TEACHING
(1) I understand that upon making a properly documented written request to the lending Institution, I am entitled to have up to 100 percent of the amount ot
this loan plus the interest thereon cancelled il I perform service..
-07
(A) As a fuJi-time teacher in a public or other nonprofit elementary or secondary school which is in the school district of a local educational agency
which Is eligible in such year of service lor lunds under Chapter j of the Education Consolidation and Improvement Act 01 '981, as amended, and which has
been designated by the Secretary (after consultation with each State Department of Education) in accordaQce with the provisions of section 465(a)(2) of the
Act as a school with a high concentratIOn 01 students from low-income families. A1\ of Ii ial ulrel:tory 01 designated low-mcome schools is published annually
by the Secretary.
(B) As a full-time teacher 01 handicapped children (includIng those who are mentally retarded, hard of hearing, deef, speech and language impaired,
visually handicapped, seriously emotionally disturbed, orthopedically impaired, have specific teaming disabilities, or otherwise health-impaired children, who
by reason thereol require special education and related services) in a public or other nonprolit elementary or secondary school system.
(2) This loan will be cancelled for each completed year of teaching service at the lollowing rates:
(A) 15 percent of the total principal amount of the loan plus interest on the unpaid balance will be cancelled for the Ilrst and second complete academic
years of that teaching service,
(B) 20 percent of the total principal amount plus interest on the unpaid balance for the third and fourth complete academic years of that teaching service,
,,0
(C) 30 percent of the total principal amount plus interest on the unpaid balance for the fifth complete academic year of that teaching service.
VIII. HEAD START CANCELLATION
(1) i understand that upon making a properly documented written request to the Lending Institution, I am entitled to have up to 100 percent of the amount of
this loan plus the interest thereon cancelied if I per/arm service as a lull.time staff member in a Head Start program if-
(A) That Head Start program is operated lor a period which is comparable to a full schOOl year in the locality, and
(8) My saiary is not more than the salary of a comparable employee 01 the local educational agency.
(2) This loan will be cancelled at the rate cf 15 percent of the total principal amount plus interest on the unpaid balance for each complete school year or the
equivalent 01 seNice in a Head Start program,
(3) Head Start is a preschool program carried out under the Head Start Act.
IX. MILITARY CANCELLATION
(1) I understand that upon making a properly documented written request to the Lending Institution, I am entitled to have up to 50 percent of the principal
amount of this loan plus the interest thereon cancelled if I serve as a member of the Armed Forces of the United States in an area of hostilities that qualifies lor
special pay under section 310 of Title 37 of the United States Code.
(2) This loan will be cancelled at the rate of 12 1/2 percent of the total principal amount plus interest on the unpaid balance for each complete year of such ser-
vice.
X. PEACE CORPS CANCELLATION
(1) I understand that upon making a properly documented written request to the lending institution, I am entJtled to have up to 70 percent of the amount of
this loan plus the interest thereon cancelled if I perform service-
(A) As a volunteer under the Peace Corps Act; or
(B) As a volunteer under the Domestic Volunteer Service Act of 1973.
(2) This loan will be cancelled at the following rates;
(A) t5 percent of the total principal amount of the loan plus interest on the unpaid balance will be cancelled for the first and second twelve-month period
of volunteer service completed;
(8) 20 percent of the total principal amount of the loan plus interest on the unpaid balance will be cancelled for the third and fourth twelve.month
period of volunteer service completed.
XI. DEATH AND DISABILITY CANCELLATION
(1) In the event of my death, the total amount owed on this loan will be cancelled.
(2) If I become totally and permanently disabled after I receive this loan, the Lending Institution will cancel the total amount of this loan.
XII. CHANGE IN NAME. ADDRESS. TELEPHONE NUMBER AND SOCIAL SECURITY NUMBER
i am responsible, and any endorser is responsible, lor informing the Lending Institution 01 any change or changes in name, address, telephone number or so-
cial security number,
XIII. LATE CHARGE
(1) The Lending Institution may impose a late charge if-
(A) I do not make a SCheduled payment when it is due, and
(8) I do not submit to the Lending Institution on or belore the date on which payment is due, documentation that I qualify for a deferment or cancellaticn
described in Articles VI, VII, Viti, IX, X, and XI of this agreement.
(2) No charge may exceed twenty (20) percent of my monthly, bimonthly or quarterly payment.
(3) (A) The Lending Institution may-
(i) Add the late charge to the principal the day after the scheduled repayment was due; or
(Ii) Include it with the next scheduled repayment after I have received notice of the late charge.
(8) If the Lending Inst1lulion elects to add the assessed charge to the outstanding principal of the loan, It must so inform me before the due date 01 the next
installment.
XIV. ASSIGNMENT
(1) This note may be assigned by the Lending Institution only to--
(A) The United Slates;
(B) Another institution upon my transfer to that instituti~n if that institution is participating in this program; or
(C) Another institution approved by the Secretary,
(2) The provisions 01 this note that relate to the Lending Institution shail, where appropriate, relate to an assignee.
XV. PRIOR LOANS
I hereby certify that I have listed below aU of the Perkins Loans I have cbtained at other institutions. (If no prior loans have been received, state 'Ncne.")
SCHEDULE OF PERKINS LOANS AT OTHER INSTITUTIONS
AMOUNT DATE INSTITUTION
1.
2.
3.
4
XVI. SCHEDULE OF ADVANCES
The following amounts were advanced 10 me under this loan agreement on the dates indicated;
AMOUNT DATE ftj' 17JNATURE OF BORAOWER
$750.00 8/28/90':", ~
2. $750.00 1/22/91 flf,.J 1v---
3
4.
NOTICE TO BORROWER; DO NOT SIGN THIS NOTE BEFORE YOU READ IT. THE LENDING INSTITUTION MUST SUPPLY A COpy OF THIS NOTE
T? YOU AND&~Y CQ~NER. I~!)i's note is signed asa sealed instrument.]
Slgnaturo;, _~..(T)(__/>11"~/ .(..,....L I(seal)j Date 11/1 b ( q 0 19~,
perr:nanent ~ddress (Street 0(8ox Number, City, Stat~, an~ Zip Code) 33(-.. VVlMc;,(rldvf pro (? l.1'f'f'c\ Lo f\) y i4-ZZg
Soclaf Secunty Number, (borro~er,must provide) 13/1"'.54-- e012- . -, / ~ .
The borrower and Lendl/lg.lnstltuhon shatlexecute thiS note without security and without endorsement unless the borrower is a minor and this note td t
under the law of the State m which the Lending Institution is located, create a binding obligallon If the borrower Is a minor and this note would not t~~~efo~~ '
be legally binding, the lending Institution shall require a cosigner to this note; ,
I agree to repay all amounts due on this loan if the borrower falls to do so in accordance with the terms of the note.
Signature Of Cosigner
{(seal)] Date
19_,
Permanent Address (Street or Bcx Number, City, State, Zip Code)
(20 U.S_C_ 1087dd)
Format by the Nalional AsSOCiation of Student FlnancJal Aid Administrators, 5/88.
Exhibit B
PERKINS (NDSL) TRUTH-IN-LENDING STATEMENT
DICKINSON COLLEGE
Account Number
000-00-2587-07
Name of Borrower
Siuchung Lee
317 Sundridge Drive
Address
Buffalo, NY 14228
ANNUAL PERCENTAGE
RATE
AMOUNT FINANCED
The cost of your
credit as a yearly
rate.
The amount of
credit provided
to you.
Prior to
repaYlllent
During
repaYlllent
o
%
5
%
$ 3,000.00
I Itemization of the Amount Financed: $ 3.000.00
Amount given directly to you. I
Late Charge: If a paYlllent is late, you may be charged: $1.00 for the first
late paYlllent, and $2.00 for each subsequent late paYlllent if
this loan is payable monthly, $3.00 for each late paYlllent if
this loan is payable bimonthly, $6.00 for each late paYlllent
if this loan is payable quarterly.
PrepaYlllent: If you payoff early, you will ~ have to pay a penalty.
See your promissory note for any additional information about nonpaYlllent, de-
fault, any required repayment in full before the scheduled date, and pre-
paYlllent.
THE BORROWER A~~OWLEDGES RECEIPT OF AN EXACT COPY OF THIS STATEMENT.
STUDENT /. /7/ /J
BORROI."ER X >PJI..{ /~/ ' f-..-./---
DATE Y. (v 0 cf- Of /
INSTITIITIONAL
REPRESENTATIVE
c::Jdy/A-<'-j j?-.
.~
DATE 10 ) I 0 I c, (
EXHIBIT "B"
Addendum to Perkins Promissorv Note
I understand and agree that any funds advanced to me on or after November 29, 1990 under
this promissory note are subject to the following additional provision:
Law Enforcement or Corrections Officer CanceIlathm
(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 service after the period for which I receive the loan--
(A) As a full-time law enforcement officer for a local, State or Federal law
enforcement agency; or
(B) As a full-time corrections officer for a local, State, or Federal corrections
agency.
(2) A portion of this loan will be canceled for each completed year of law enforcement or
corrections service at the following rates:
(A) 15 percent of the total principal amount of the loan plus interest on the unpaid
balance accruing during that year for each of the first and second complete years of
that service,
(B) 20 percent of the total principal amount 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 plus interest on the unpaid balance
accruing during the year for the fifth complete year of that service.
Signature )<. ~I ~/~
Date 'f.. (0 Ocr It! ,19
DICKINSON COLLEGE
Carlisle, PA 17013
Tel: 717-245-1383
PROMISSORY NOTE - PERKINS LOAN. PROGRAM
Any bracketed clause or paragraph may be included at option of institution_]
, Siuchunq Lee promise to pay to Oickinson Col1pgp (hereinafter
~alled the lending Institution) localed at r.rlrl i ,,1 p Ppnnc:;yl viln; il the sum of the amounts that are advanced to me and en-
JOfsed in the Schedule of Advances set forth below. I promise to pay all attorney's lees and other reasonable collection costs and charges necessary lor the
:ollection of any amount not paid when due. I further underslantl and agree that:
I. GENERAL
1) Aonlicable Law All sums advanced under this note are drawn from a fund created under Part E 01 Title IV 01 the Higher Education Act 011965, as
lmended, hereinafter called the Act, and are subject to the Act and the Federal Regulations issued under the Act. The terms of this note shail be interpreted in
lccordance with the Act and Federal Regulations, copies of which are to be kept by the Lending Institution.
2) Procedures for ReceivinlJ Delerment or Cancellation I understand that in order to receive a deferment or cancellation, I must request the deferment or can-
:ellation in writing from the Lending InStitution, and must submit to the Lending Institution any documentation required by the Lending Institution to prove that
qualily for the deferment or cancellalion. I further undelstand that if I am eligible lor deferment or cancellation under Articles VI through XI, I am responsible
or submitting the appropriate requests on time. I further understand that I may lose my deferment and cancellation benefils if I fail to lile my request on time.
II. INTEREST
nterest Shall accrue from the beginning of the repayment period and shall be at the ANNUAL PERCENTAGE RATE OF FIVE PERCENT (5%) on the unpaid
Jalance. except that no interest shall accrue during any deferment period described in paragraph VI(1).
III. REPAYMENT
1) I promise to repay the principal and the Interest which accrues on it \0 the Lending Institution over a period beginning 9 months after the date I cease to be
It least a half-time student at an institution of higher education, or at a comparable institution outside the United States approved for this purpose by the
lniled States Secretary of Education (hereinafter called the Secretary). and ending 10 years iatllr, unless that period is shortened under paragraph 111(5), or ex-
ended under paragraphs 111(4). 1I!{7} (extensions). or VI(1) (deferments).
2) Upon my written request, the repayment period may start on a date eariier than the one indicated in paragraph 111(1).
3) (A) I promise to repay the principal and interest over the course of the repayment period in equal monthly, bimonthly or quarterly installments, as deter-
nined by the Lending Institution. I understand that if my monthly payment for "lithe loans mace to mil by the Lending Institution is not a multi pill of $5, the
.ending Institution may /Qund that payment to the next highest dollar amount that is a multiple of $5
(B) Notwithstanding paragraph 111(3J(A), upon my wlil1en request, repayment may be made in graduated installments In accordance with a scheduie
.pproved by the Secretary
(C) The Lending Institution shall attach the scheduie of repayments and the SChedule will become part 01 the note.
4) Notwithstanding paragraph IU(l), ill qualify as a low-income individual during the repayment period. the Lending Institution, upon my written request, may
xtend thll repayment period tor up to an additional 10 years, and may adjust any repayment SChlldule to reflect my income.
(5){A) lIthe monthly rate that would b6 established under paragraph 111(1). or the total monthiy repayment rate of principal and Interest on all my Perkins
oans including this loan, is less than $30 per month. I shall repay the principal and intllrest on this loan at the rate of $30 per month (which includes both prin-
ipal and interest).
5) (8) If I have received Perkins Loans from othllr institutions and the total monthly repayment rale on those loans is Jass than $30, the $30 monthly payment
stabiished under subparagraph ill(5)(A) inciudes the amounts I owe on all my outstanding Perkins loans including those received from other Instltutions_ The
mount of this $30 monthiy payment that will be applied to this loan will be the difference between $30 and the total of the amounts owed at a monthly rate on
lyother Perkins Loans.
5) The Lending Institution may permit me to pay less than lhe rate of $30 per month for a period 01 not more than one year where necessary to avoid
J.rdship to me unless that action would extend the repayment period in paragraph III(l).J
7) The lending Institution may, upon mywrillen request, reduce any scheduied repayments Of extend the repayment period indicated in p<lragraph 111(1), if
1 its opinion, extraordinary circumslances such as prolonged illness or unemployment. prevent me from making the SCheduled repayments However, inter-
st shaJlcontinue to accrue
IV. PREPAYMENT
lJ I may, at my option and without penalty, prepay all or any pan of the principal, plus the accrued Interest thereon, at any time.
2) Amounts I repay in the academiC year in which lhe ioan was made will be used to reduce the amount of (he loan and will not be considered a prepayment
31 If I repay more than the amount due for any instailment, the excess wiJi be used to prepay principal unless I designate it as an advance payment of the
ed regular installment
V. DEFAULT
1) The lending Institution may, at its option, declare my loan 10 be in default and may demand immlldiate payment of the entire unpaid baiance of the loan.
1eluding 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 Lending Institution, and
(8) I do not submit to the Lending Institution on or before the date on which payment is due, documentation that I qualify for a deferment or cancellation
escribed in Articles V\. VI!. VIII, IX, X, or Xl oflhis agreement
21 I understand that if I default on my loan. the Lending Inslltution may disclose that I have defaulted, along with other relevant information, to credit bureau
rganizations
31 Further, I understand that if I default on my loan and the loan is transterred to the Secretary lor Collection.lhe Secretary may disclose that I have defaulted,
long wilh other relevant information. to credit bureau organizations.
oj I understand that after the lending Institution acceierates the loan under paragraph V(1), I will then lose my right to defer repayments due afler the date
'HI lending Institution accelerates the loan
5) I understand thai after the Lending Insfitution accelerates the loan under paragraph V(l). I will then lose my right to receive a cancellation of a portion of
"Y loan for any teaching. volunteer or military service described in Articles VII, 'VIII and iX, perlormed after the date the Lllndlng Institution accelerated the loan
5) I understand that failure to pay this obligation under the telms agreed upon will prevent my obtaining additional studllnt financial aid authorized under
it Ie IV of the Higher Education Act of 1965, as amended. until I haVll made arrangements which are satisfactory to the lending Institution or the Secretary
~garding the repaymllnt of the ioan.
VI. DEFERMENT
1) I understand that upon making a ploperlydocumented written request to the lending Institution, I may defer making scheduled installment payments, and
"Ii nOl be liable for any interest that might otherwise accrue, during the following periods:
(A) Wllile I am en roiled and in attendance as at least a halt-lime student at an institution of higher education or at a comparable institution outside the
Inited States approved lor this purpose by the Secretary;
18) For a period of three (3) years during which I am -
Ii) On fuli-lime active duty as a member of the Armed Forces of the United States (Army, Navy, Air Force, Marine Corps. or Coast Guard) or the
:3(101'131 OceanIc and Atmospheric Administration Corps, 01 as an officer on full.time active duty in the Commissioned Corps of the Uniled States Public
lealth Service,
{iil In service as a volunteer under the Peace Corps Act.
(iii) A volunteer under the Domestic Volunteer Service Act of 1973 (ACTION programs).
{iv) A full. lime volunteer 10 a lax-exempt organization per10rming service comparable to the service performed in the Peace Corps Of under the
;omestic Volunteer Service Act of 1973, or
{v) Temporarily totally disabied as established by an affidavit of a qualilied physician, or unable to secure emplOyment because 1 am providing care
,quired by a dependent ""hn is so d:~:!:Jled;
(C) For a period not in excess oj two (2) years.
(i) Anerl receive a baccalaureate or professional degree during which time I am serving in an Internship whiCh is required in order that I may receive
rofessionai recognition required to begin my professional practice or service, or
(ii) serving in an internship or residency program leading to a degree or cellificate awarded by an institution of higher educatiof1, a hospital or a Malth
are facilily that offers postgraduate training';
(D) For a period not In excess of one (1) year during which. if I am a mother of preschpel age children,l have entered or reentered the work force, and am
eing paid at a rate which does not exceed $1.00 above the minimum hourlywagll estatllished by section 5 of the Fail Labor Slandards Act of 1938'
IE) For a period not In excess of six months -- .'
(i) That follows by six months or less of a period during which I was enrolled as at least a hail-time student at an eligible institution; and (iI) During
hich I am pregnant, caring for my newborn baby, or caring for a child immediately alter he 01 she was placed with me through adoption and I am neither
Ttending an eligible institution of higher education nor gainfully emplQyed; and
(F) During a six (5) month period immediately following the expiration 0' any deferment provided in paragraphs 1I1(1)(A) through VI(1)(E)
~I The lending Institution may. upon my written request. defer my scheduled repayments it it determines that the defllrment is necessary to avoid a !inanciai
ardship lor me. Intere~t, however. will continue to accrue.
VII. CANCELLATION FOR TEACHING
I) I understand that upon making a properly documented wrillen request to the Lending InstitutiOn. I am entitled 10 have up to 100 percent of the amount of
liS loan pius the interest thereon cancelied if I perlorm service-
-07
(A) As a lwll-time teacher in a public or other nonprolit elementary or secondary school which is in the school district of a local educational agency
which is eligible in such year of sel'\'ice lor lunds under Chapter I of the Education Consolidation and lmprovement Act 01 1981, as amended, and which has
been designated by the Secretary (af1er consultation with each State Department 01 Edwcalion) in accordance with the provisions of section 465(a){2) 01 the
Act as a schOol with a high concentration 01 students from low-income families. An officia~pirectory 01 designated low-income schools is published annually
by the Secretary.
(B) As a full-time teacher of handicapped children (including those who are mentally retarded, hard of hearing, deaf, speech and language impaired,
visually handicapped, seriously emotionally disturbed, or1hopedically impaired, have specific learning disabilities, or otherwise health-impaired children, who
by reason thereof require special education and related sel'\'ices) in a public or other nonprofit elementary or secondary school system.
(2) This loan will be cancelled for each completed year 01 teaching Service at the following rates:
(A) 15 percent ot the total principal amount of the loan plus interest on the unpaid balance will be cancelled for the lirst and second complete academic
years 01 that teaching service,
(B) 20 percent of the total principal amount plus interest on the unpaid balance lor the third and fourth complete academic years of that teaching sel'\'ice,
"d
(C) 30 percent of the totai principal amount plus interest on the unpaid balance for the fifth complete academic year of that teaching sel'\'ice.
VIII. HEAD START CANCELLATION
(1) I understand that upon making a properly documented writlen request to the lending Institution, I am entitled to have up to 100 percent of the amount 01
this loan plus the interest thereon cancelled ill perform sel'\'ice as a full.lime stalf member in a Head Start program if _
IA) That Head Start program Is operated for a period Which is comparable 10 a full school year in the locality, and
(S) My salary is not more than the salary of a comparable employee of the local educational agency
12) This ioan will be cancelled at the rate of 15 percent of the total principal amount plus interest on the unpaid balance for each complete school year or the
equivalent of service in a Head Start program.
(3) Head Start is a presohool program carried out under the Head Start Act.
IX. MILITARY CANCELLATION
(1) I understand that upon making a properly documented written request to the lending Institution, I am entitled to have up to 50 percent of the principal
amount of this loan plus the interest thereon cancelled if I sel'\'e 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 Titie 37 of the United States Code,
(2) This loan will be cancelled at the rate of 121/2 percent of the total principal amount plus interest On the unpaid balance for each complete year of such ser-
vice.
X. PEACE CORPS CANCELLATION
(tl I understand that upon making a properly documented written request to the lending institution,l am entitled to have up to 70 percent of the amount of
this loan plus the interest thereon cancelled if I perform service-
(A) As a volunteer under the Peace Corps Act: or
(B) As a volunteer under the Domestic Volunteer Service Act of 1973.
(2) This loan will be cancelled at the following rates'
(A) 15 percent 01 the total prinCipal amount of the loan plus interest on the unpaid balance will be canceiled for the lirst and second twelve-month period
of volunteer service completed;
(B) 20 percent of the total principal amount of the loan plus interest on the unpaid balance will be cancelled lor the third and fourth twelve-month
period 01 volunteer service completed.
XI. DEATH AND DISABILITY CANCELLATION
(1) In the event of my death, the total amount owed on this loan will be cancelled,
(2) If I become totally and permanently disabled after I receive this loan, the lending Institution will cancel the total amount of this loan.
XII. CHANGE IN NAME. ADDRESS. TELEPHONE NUMBER AND SOCIAL SECURITY NUMBER
I am responsible, and any endorser Is responsible, for informing the lending Institution of any change or changes in name, address, telephone number or so.
clalsecuritynumber
(1) The lending Institution may impose a late charge if_
(A) I do not make a scheduled payment when it is due, and
(B) I do not submit to the lending Institution on or before the date on whiCh payment is due, documentation that I quality for a deferment or cancellation
described in Articles VI, VII, VII!, IX, X, and XI Of this agreement.
(2) No charge may exceed twenty (20) percent 01 my monthly, bimonthly or quarterly payment
(3) (A) The lending Institution may_
(i) Add the late charge to the principal the day atter the scheduled repayment was due; or
(ii) Include it with the next scheduled repayment after I have received notice of the late charge.
(8) If the lending Institution elects to add the assessed charge to the outstanding principal 01 the loan, it must so inform me before the due date of the next
instailment.
XIII. LATE CHARGE
11) This note may be assigned by the lending Institution only 10 _
(A) The United States:
16) Another institutiOn upon my transfer to that instilution if that institution is participating in this program: or
(C) Another Institution approved by the Secretary
i2.) The provisions of this note that relate to the lending Institution shail, where appropriate, relale to an assignee
XV. PRIOR LOANS
I hereby certify that I have listed below all of the Perkins Loans I have obtained at other institutions. (If no prior loans have been received, state "None")
SCHEDULE OF PERKINS LOANS AT OTHER INSTITUTIONS
AMOUNT DATE INSTITUTION
XIV. ASSIGNMENT
~
3.
4.
XVI. SCHEDULE OF ADVANCES
The following amounts were advanced to me under this loan agreement on the dates indicated:
AMOUNT DATE X S~ATUF!,i'O.P"BORROW~f.:
$1.500.00 9/3/91 4?'Ufj(.~/.t ______
: $1,500.00 1/28/92 X at M:7 -
---------,---~--_.-
4.
N.OTICE TO 80RRO~E . 00 NOT SIGN THIS NOTE BEFORE YOU READ IT, THE lENDING INSTITUTION MUST SUPPLY A COPY 01'= THIS NOTE
TO YOU AND f.f':JY NE~ note is ~ned as a sealed instrument] ,
Signature X -t.-r/---[--<.7 6'-------- ..". . !(seal)]Date X//1 OCr / 19-=f;(
Pllrmanent Address (Street or Box Nufuber, City, SI' and Zip Code) )< 5:~ .$ /,t-(l.dj-;'~€ Or, 1??I/I~ /e.. /U V /L,l-2 7;g
Social Security Numbe~ (borro~er, must provide) /3 ~-- _~~ 4- _ .?{c;,C'( 2_ '
The borrower and lending Institution shall execut this note without security end without endorsement unless the borrower is a minor and th's t ld t
under the law 01 the State in which the lending Institution is located, create a binding obligation If the borrower is a minor and this note wO~ldn~ ~ ~OUel07: .
be legally binding, the lending Institution shall require a cosigner to this note: 0 er ,
I agree to repay all amounts due on this loan if the borrower taiis to dO so in accordance with the terms of the note
Signature 01 Cosigner
_[(seal)] Date
19_
Permanent Address (Street Of Box Number, City, Slate, Zip Code)
(20 U,S.C. 1087dd)
Format by the National Association 01 Student Financial Aid Administrators, 5/88
Exhibit C
PERKINS (NDSL) TRUTH-IN-LENDING STATEMENT
Ij~
, Ij
DICKINSON COLLEGE
Account Number
000-00-?5R7-OA
Name of Borrower
Siu C. Lee
Address
317 Sundridge Dr.
Buffalo,
NY 14228-1810
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 , 500 . 00
I Itemization of the Amount Financed: $ 2.500.00
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.
THE BORROWER ACKNOWLEDGES RECEIPT
STUDENT f: . {'
BORROWER, ,Z ( t 17
DATE ( 6 / ': c' I Ct L
OF AN EXACT COPY OF THIS STATEMENT.
;-
/..--......
INSTIT1ITIONAL
REPRESENTATIVE
~~"'--
/1>(>'01 "iL- .
DATE
EXHIBIT "c"
Promissory Nole - Perkins Lela'l
Siu Chuno Lee
,pro""mise 10 pay 10 Dickinson Colle~e (hereinafter called the Instilution), located at
~, the slim of the amounts Ihat are advnnced to me and endorsed in the Schedule of Adv3Jlces set forth below. J promise
eetion cosl~. including atlomey fees and other charges. necessary for the collection of any amount nol paid when due
.nd agree that:
All sums advanced under this note are drawn from a fund created under Part E of Title IV of the Higher Educati(ln Ad (If
after called the Ad). and are subject to the Act and the Federal Regulations issued under the Act. The leffils of this nole
ordanee with the Act and Federal Regulations. copies of which are to be kept by the Institution.
eeeivin!!: Defennenl or Cancel/alion. I undersland thai to receive a deferment or cancella!iofl, I must request the defennenl
from the Inslihltion, and must submit to the Institution any documentation required by the Instihltion to prove that 1 qualify
~lIalion. I further underst3Jld that if I am eligible for deferment or C3Jlcellation urtder Ar1ides Vllhrough XII, I am
the appropriate requests on time. J further understand that J may lose my deferment and cancellation benefits if I fail 10
'om the beginning of the repayment period and shall be at the ANNU:\L PERCENTAGE RATE OF FIVE I'ERCENT
ceo e:tcept thaI no interest shall ar.:C11le during any defennent period described in paragraph VI(I).
V the principal and the interest that accrues on it to the Institulion over a period beginning nine (9) months alter the d3te I
time regular- student at ar1 institution of higher education, or at a comparable instilution outside the United State.~ allrrn~'ed
lited States Secretary of Education (hereinafter called the Secretary). and ending ten (10) yeMs later. unless that pl"rioo.l is
It 1Tl(5). orf e:ltended under paragraphs ID(4), 10(1) (e:ltensions), or VI(I) (defennents).
lequest, the repayment period may start on a date earlier Ihan the one indicated i.t1 paragraph DI( I).
~ray the principal and inlerest over the course of the repayment period in equaJ monthly. bimonthly, or quarterly
I by Ihe Instillltion. I understand that if my installment payment for all lhe loans made 10 me by the Institution is not .1
ion may round that payment to the flext highest dollar amount that is a multiple of S5
)aragraph II1(J)(A), upon my written requesl, repayment may be made in graduated installments in accordam:e with :1
Secretary.
laragraph m(l). if I qualify as a low-income individual during the repayment period, the 'nsliMion, upon my written
payment period for up to an additional len (10) years and may adjust any repayment schedule to renecl my income.
'rllte that would be established under paragraph 10(1), or the lotal monthly repayment rate of principal and intCTe~t nn all
19 this loan, is less than 530 per month. 1 shall repay the principal and interest on this loan At the rate of SJO per Im'n!h
ipal and interest).
.ed Peruns Loans from other institutions and the lotal monthly repayment rale on those loans is less than .$JO. the S:\O
z..1 under subparagraph 1lI(5)(A) includes the amounts I owe on all my outst.1nding Perkins Loans, including Ihose rl"~eiv~ll
e por1ion of the .\30 monthly payment that will be applied to this loan will be the differen~ between $30 111111 the lolal or
lthJy rate on my other Perkins Loans.
y permit me to pay less thall the rate of 530 per month for a period of 1I0t more rhan one (I) year where nCl:('ssary to
s that action would extend the repayment period in paragraph ID(I).I
y. "pon my wrilten request. reduce any scheduled repayments or e'ltend the repayment period indicated in pa.r:lgl:lrh 11I(1l.
nces sllCh as prolonged illness or unemployment prevent me flom maleing the scheduled payments. However, inleH:sl _~h:lll
n and without penalty. prepay all or any part of the principal, plus any acc11led inlerest thereon. at any time.
I the academic year in which the loan was made and the initiaJ grace period has nol ended will be used to reduce the-
I not be considered a prepayment.
during rhe academic year in which the loan was made and the initial grace reriod ended. only those amnunl~ in c~~l"s~ ('If
ayment period shall be considered a prepayment.
year other than the award year in which the loan was made, I repay more than the amount due for an installOll"nl, the
I principal unless I designate il as an advance payment of the ne:tt regular installment.
" at its option. declare my loan to be in default and may demand immediate payment of the entire unpaid balance I'If the
Ierest, lale charges, and collection costs, if-
heduled payment when due under the repayment St;hedule estahlished by the Institution. and
the Institution. {In (1r before the date on which payment is due, documentation that I qualify for a deferment I'Ir
ticles VI. VII, VIH, IX, X, XI, or XII of this agreement-
I default on my loan, the Institulion may disclose that I have defaultl"l1, along with other relevant informatilln, to ""'~'1lit
d thaI if I default nn my loan and the loan is a.ssigned to the Secretary for colll"clion, Ihe Secretary mt\y disclose lh:1t I
'lher relevant informaril'ln. to credit t>ureau organizations.
I clefllUIr on rny loan. I then will lo."e my right to defer repayments
I of 4
Perkin, 1.":111
if the In.qitutilln a<.:(dera't:~ the h'an under p:Ullpilph V(I), I then willl<1se 111~' riJ:,hlIII IClTivt' a ':,llll.,c1hllioll "f il p"rtillll
l~, Head Start, military: vl,!lmtccr.:law enfllrCell1Cnt, or cuoceli....n.. ~erviu' dcsnihcll in Arlicles VII, VIII, IX. X, and Xl
le Institution IlccderateJ the loan
failure to pay this obli~ahon under the terms agreed upon will prevcnt my obtaining additional student financial aid
of the Hi~her Edllt;alion Act of 1965, 8.' amended, until I have made artiUlgcments that are satisfactory t(1 the Institution or
e repayment of the loan.
upon making a properly do..:umente~l wrillen request to the Institution, 1 may defer making ~chcdilled inslallment payments,
any interest Ihat might olherwise accrue, during the folk,wing periods:
lied and in altendance a. at least a half-time regular student at an institution of hi~her education or al a comparable
Ited States II(1proved for this purpo~e by Ihe Secret.ary.
ot to e,-ceed three (3) years during which I am -
e duty as a memher of Ihe Armed Forces of Ihe United States (Army, Navy, Air Force, Marine Corps, or Coast Guard) IIr
Atm()spheric Administration Corps, or as an officer on full-time active duty in the Commissioned Corps .of Ihe United
ice,
:llunteer under the Peace Corps Act.
er the Domestic Volunteer Service Act of 1973 (ACTION programs),
nteer in a tax-e"empl organi1.ltion performing service comparable to the service performed in the Peace Corps or under the
ice Act of 1973 (ACfION pro~rams), or
lIy disahled as established by an affidavit of a qualirled physician, or unahle to secure empk'ymenl hecause I am providing
ndent who is so disabled.
in e"'cess of two (2) yeats -
baccalaureate or professional degree during which time 1 am serving in an internship Ihat is required in order that' may
tnilion required 10 begin my professional practice or service, or
"ernship or residency program leading to a degree or certificate awarded by an institution of hi~her education, a hosrital, or a
ffa's postgTllduate training.
in excess of one (I) year during which. if I am a mother of preschool age children, I have entered or reentered the wtJrk
at a rate that does not exceed S I more than the minimum hourly wage established by section 6 of the Fair Laoor Standards
in ex-cess of si'- (6) month.. -
;i,- (6) months or less a period during which I was enrolled as at least a half-time regular student at an eligible institution:
am pregnant. caring for my newborn bahy, or caring for a child immediately after he or she was placed with me through
r anending an eligible instilution of higher ellucation nor ~ainfully employed.
month reriod immediately following the e,-piration of any deferment provided in paJagraphs VI(I)(A) through VI(I)(E).
nay, upon my written request. defer my scheduled repayments if it determines thai the deferment is neces:<tary 10 avoid a
~. Interest. however, will continue to accrue.
,achinr.
t upon making a properly documented wrillen request 10 the Institution, I am entitled to have up to 100 percent of the
the intere.~t thereon canceled if I perform service -
eacher in a public or other nonprofit elementary or secondary school in the school district of a local edllt;ational agency that
f service for fund.. under Chapter I of the Education Consolidation and Improvement Act of 1981. a~ amended, and Which
he Secretary (after consuhalion with ellCh State Derartment of Education) in accordance with the provisions of section
L school with a high concentration of students from low-income families. An official Directory of de..ignated low-income
ually by Ihe Secretary.
eacher of handicapped children (including those who are mmtally retarded. hard-of-hearing, deaf, speech. and language-
;apped, seriously emutionally disturbed, orthopedically impaired, have specific leamin~ disabilities, or are otherwise health-
JY reason Ihereof require special education and related serYices): in a public or other nonprofit elemental}' or secondary
s lORn will be canceled for each completed year of teaching service at the following fales:
Ie toll'll principal amount of the loan plus interest on the unpaid balance accruing during that year will be canceled for each of
plete academic years of thaI teaching service,
Ie total principal amount plus inlerest on the unpaid balance accruing dllring that year for each of the third and fourth
i of lhatleaching service, and
le tolal principal amounl plus interest on the uopaid balance accrUing dllring that year for the fifth complete academic year of
lIation
~n making a properly documented written request to the Institution, I am entitled to have up to 100 percent of the
: the interestlhereon canceled if I perform service as a full.lime starf member in a Head Slart program if _
1 program is operated fot a period that is comparable to a full school year In the locality, and
)1 more than Ihe salary of a comparable employee of the local educational agency.
'lC canceled at the rate of 15 percent of the total principal 'mount plus interest on the unpaid halance accruing during that year
II year or equivalent period of ..efVice in a Head Start program.
preschool program carried out under the Head Start Act.
2 of 4
I'efkin:<t Lnan
~ a properly dnnllllcntcd writlcn le'que_~l 10 Ihe III_qilulinn. I am enlitled In have up 10 50 perccnt ,,~ Ihe
interest Ihcreon <'anceJed il I serve as a Illcm~er of the Anned Forces of Ihe United States in an :lIea Ilf
. unller section ~ 10 of Title 37 of Ihe United Stales Code
Ihe rail.' of 12 1/2 percent of Ihe Inial prin(,:ipal amounl plus interest lln Ihe unpaid balance accruing Iluril1!-, Ihat
~f"\' i ce
~ a properly (Iocumenled wrillen request 10 the Instilution. I am enlilled 10 have up 10 70 perce lit (If the amnun'
ancelI'd if I perform service-
<lCe Corps Act; or
l1eshc Volunteer Service Acl of 1973 (ACTION pro~rams).
Ihe following rilles:
,al amount IIf the loan plus inlerest on the unpaid halance accruin~ during thaI year will he cancell'll for each of
, perioos of volunleer sep/ice completed;
lal amounl of Ihe loan plus interesl on the unpaid balance accruing dUr;n~ lh3t year will be cancebl fm e:-ten of
I periods ,.f volunteer sep/;ce compleled,
OUicerCancellalion
~ a properly documenled wrillen request 10 the Inslitulion, I am entitled to have up 10 1m percenl of 'he
.ereon canceled if I perfonn qualifyiog service after Ihe period for which I received Ihe loan -
nl officer for an eligible local. Stale, or Federal law enforcement a~ency; or
icer for an eligible \ocal, Slale, or Federal conections a~ency.
canceled for each completed year of law enforcement or corrections sen.'ice alibI' following ralc5
nil amounl of Ibe loan plus inlerest on Ihe unpaid balance accruin~ during that year for each of lbe llr51 and
lal amount plus interesl on Ihe unpaid balance accruing dunng that year for each of Ihe third and f,.urlh
,al amount plus inlerest on the unpaid balance accruing during Ihe year for the fifth complele yem nf th;ll
"
0la1 amounl owed on this loan will be canceled.
olally disahled after I receive this loan, the Instilulion will cancellhe total amounl of Ihi~ loan.
phone Number. or Social Securitv Number
r is resJlomil'>le. for informing the Inslilution of any change or changes in name, addres.5, telephllnl' numt-wr. or
ale l;:harge if-
ymenl when it i5 due. and
ion. on or hefore Ihe date on Which paymenfisdue, documenlalion thlll I qualify for a deferment N <';Hlll'H;ltilln
, X. XI, and XII of Ihis agreement. -
;enl of my monthly, bimonlhly,'Or quarlerly payment.
cipallh~day aflerlhe.sd'leduled repayment was due; or
Jlcd repaym~nt after I have received nolice of the late charge.
the lale charge to the oUL5tanding principal of Ihe loan, it mu.51 so inform me hefore 'he due dall' of the onl
the Inslilulion only 10 -
ransfer to Ihat institulion if Ihat institution is pal1icipalin~ in Ihis program; or
'Y the Secretary.
II rela'e 10 lhe Inslilution shall, where appropriale, relate to an assignee.
~elow all of the Perlins Loans I have obtained al olher in~litulions. (H nn rrillr loans have been len'i'l"!. ~l;tll'
PERKINS LOANS AT OTHER INSTITUTIONS
{
Dale
Insl;lution
l"f<1
l\'!kil"I,,:t1l
Adv ~UKC5
~ere advanced In me Ulll'C~ Ihi5 loan agreemenl on the date5 inoJicated:
Amount
Dale
Sigoature or BOlTowcr
_(;LAh/;;7 /2-
~;;17 2----
$1,250.00
$1,250.00
9/1/92
1/28/93
ROWER: no NOT SIGN THIS NOTE bEFORE YOU READ tr.
I\.ND AGREE TO Al.L OF THE FOREGOiNG TERMS AND CONDITIONS.
tned as a sellled instrumenl.j
((seal))
,19_
ress (Slreet or Box Number, City, Slate. and Zip Code)
Number (lxmower must provide)
nd Institution shall cxC(;ute Ihis nole without security and without endorsement unless the bolT{lwer is a minor and this nole
er Ihe law of the State in which the Institution is located, create a binding obligation. If the burrower is a minor and this note
:fore be le&ally binding, the Iml.litutioll shall require a cosigner to this note.
I all amoun~ on Ihis loa,p if the borrower faib 10 do so in IlCcordance wilh the Iem\s of the note.
signer ~'7."!:.~t<~? ((seal))
. h . 19.i.]- //
I
Iress (Street or Boll. Number, City, State. and Zip Code)
"7
.s f, :/ E _~- T .:.,
C/;,{'( Ire {::-
p/J
5"7--801'2-
7(;1
-os
7 .~
Number (collignet must provide) ":;> -~
shall provide a wpy of this note 10 you and any cosigner and you should retain the copy for your ~!;ords.
U.S.C.1087dd)
4 {If 4
Perkins Loan
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. S 4904
relating to unsworn falsification to authorities, which provides that if I knowingly make false
averments, I may be subject to criminal penalties.
Dickinson College
~
Thomas Meyer
Assistant Treasurer of Dickinson College
Dated: ?/lO)D3
F:\FILESIDAT AFILEIDickinson College 7619\DickinsonCollegeCollections7619C\Documents\184 com
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Created: 8/15103 8:51AM
Revised: 8/15/03 8:51AM
7619C184
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03-3286 CV
CNIL ACTION-LAW
SIUCHUNG T. LEE,
Defendant
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE
Please reinstate the attached Complaint to be served upon Defendant Siuchung T. Lee.
MARTS ON DEARDORFF WILLIAMS & OTTO
Date: August 15,2003
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F:\FILESIDA T AFILEIDickinsonCollege7619\Collections\Archive\ 184\ 184. pra2/n1m
Created: 4/28/03 154:03 PM
Revised 10/17/062:45:09 PM
7619C.155
DICKINSON COLLEGE,
Plaintiff
v.
SIUCHUNG T. LEE,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-3286 CV
CIVIL ACTION-LAW
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE
Please mark the above captioned matter discontinued without prejudice.
Date: /0 - 17- O~
MARTSON DEARDORFF WILLIAMS & OTTO
By ~J..,.L S I~
Christopher E. Rice, Esquire
1.D. Number 90916
Ten East High Street
Carlisle, P A 17013-3093
(717) 243-3341
Attorneys for Plaintiff
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