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F: IFILES\DA T AFlLE\Dickinson College 76 I 9\DickinsonCollegeCollections76] 9C\Documents\] 97-com I. wpd
Created: 8/6!0311:18AM
Revised: 8/26/039:21AM
76]9C.[97
DICKINSON COLLEGE,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NO. 0'3- '1)/1
CIVIL ACTION-LAW
KRISTIN T. CELENTANO
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, Pennsylvania 17013
Telephone (717) 249-3166
ILLIAMS & OTTO
ld R. Galloway, E
LD. Number 87326
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiff
Date: August 26, 2003
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 0.3 - 'f.:t"
CIVIL ACTION-LAW
DICKINSON COLLEGE,
Plaintiff
KRISTIN T. CELENTANO
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:
I, 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 Kristin T. Celentano is an adult individual with a last known address of
60 Brookside Avenue East, Westbrook, Middlesex County, Connecticut, 06498.
3. On or about August 28,1995, Defendant entered into a Promissory Note - Federal
Perkins Loan Program (Note #1) with Plaintiff for the financing of$I,OOO.OO plus interest and costs
by Defendant on her own behalf, for educational services and benefits at Plaintiffs institution. A
copy of Note #1 is attached hereto as Exhibit "A."
4. On or about September 20, 1996, Defendant entered into an additional Promissory
Note - Federal Perkins Loan Program (Note #2) with Plaintifffor the financing of $2,000.00 plus
interest and costs by Defendant on her own behalf, for educational services and benefits at Plaintiff's
institution, A copy of Note #2 is attached hereto as Exhibit "B."
5. Note #1 and Note #2 are funds created under Part E of Title IV of the Higher
Education Act of1965 as amended, (hereinafter the "Act") and are subj ect to the Act and the Federal
Regulations issued under the Act.
6. 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.
7. The total principal for Note #1 and Note #2 is $3,000.00.
8. Note #1 and Note #2 grant Plaintiff reasonable collection and attorney's fees which
Plaintiff has calculated to be $500.00.
9. As of July 15, 2003, the principal and interest due and payable by Defendant to
Plaintiff was $1,151.18, plus interest accruing thereafter at $0.15 per day.
10. As of July 15, 2003, the outstanding balance of$I,151.18 represents the total and
actual overdue value of the financing provided to Defendant under Note #1 and Note #2 for which
Defendant has yet to pay.
11. Plaintiffhas fulfilled, performed and complied with all obligations and conditions of
Note #1 and Note #2.
COUNT I
BREACH OF CONTRACT
12. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 11 of this Complaint.
13. 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$l, 151.18,
plus interest accruing at $0.15 per day from July 15, 2003, collection and attorneys' fees in the
amount of $500.00 and costs of suit.
COUNT II
IN QUANTUM MERUIT
14. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 13 ofthis Complaint.
15. Having requested Plaintiff to loan money, and doing so to the benefit of Defendant,
Defendant became liable to Plaintiff for said money.
16. Defendant has been unjustly enriched by accepting said money without paying
Plaintiff reasonable compensation therefor.
17. As of July 15, 2003 the total amount by which Defendant has become enriched is
$1,151.18, plus interest in the amount of$0.15 per day from July 15, 2003.
WHEREFORE, Plaintiff demands judgment against Defendant, Kristin T.Celentano, in the
amount of$I,151.18, plus interest in the amount of$0.15 per day from July 15, 2003, collection and
attorneys' fees in the amount of$500.00 and costs of suit.
B
David R. Galloway
LD. Number 87326
Ten East High Street
Carlisle, P A 17013-3093
(717) 243-3341
Attorneys for Plaintiff
Date: August 26, 2003
PERKINS (NDSL) TRUTH-IN-LENDING STATEMENT
DICKINSON COLLEGE
Account Number 00273-000-00-3033
Name of Borrower Kristin Tara Celentano
Address
6 Chapman Ct.
Nnrrh H~vpn. CT 06473
ANNUAL PERCENTAGE
RATE
AMOtlN'! FINANCED
The cost of your
credit as a yearly
rate.
The amount of
credit provided
to you.
Prior to
repayment
During
repayment
o
%
5
%
$ 1.000.00
I Itemization of the Amount Financed: $ 1,000.00
Amount given directly to you. I
Late Charge: If a payment is late, you may be charged: $1.00 for the first
late payment, and $2.00 for each subsequent late payment if
this loan is payable monthly, $3.00 for each late payment if
this loan is payable bimonthly, $6.00 for each late payment
if this loan is payable quarterly.
Prepayment: If you payoff early, you will not have to pay a penalty.
See your promissory note for any additional information about nonpayment, de-
fault, any required repayment in full before the scheduled date, and pre-
payment.
nlE BORROWER ACK.~OWLEDGES RECEIPT OF AN EXACT COpy OF THIS STATEMENT.
STUDENT Ihl H . "\
BORROWER r [vw..tvrlJ
DATE 812 B I C{ 5
I r1 ~ INSTITUTIONAL
( ,U; P !(l1 (vrI.QREPRESENTATIVE
DATE t5 -""'2..8
~~
("l ,--
7)
EXHIBIT "A"
00273-000-00-3033
-09
Promissory Note-Federal Perkins Loan Proemm
[Any bracketed clause or paragraph may be included at option of institution.]. .
I K,..i"H n '1'",.." Fp1F''''''i'n~ , promise to pay to 01 cln nson Coll eqe (hereinafter callad the
Institution), located at Car 1 is Ie. PA 17013-2896 , the sum of the amounts that are advancad to me and endorsed in the
Schedule of Advances set forth below. I promise to pay all reasonable collection costs, including attorney fee. and other charges, necessary for
the collection of any amount not paid when due.
I further understand and agree that:
I.~
(I) Annlicable Law. All sums advancad under this note are drawn from a fund created under Part E of TitIe IV of the Higher Education Act
of 1965, as amendad (hereinafter called the Act), and are subje<:t to the Act and the Faderal regulations issuad under the Act. The term. of this
note shall be interpreted in accordance with the Act and Federal regulations, copies of which are to be kept by the Institution.
(2) Procedures for Receivio2 Deferment. Cancellation. or Forbearance. I understand that, to receive a deferment, cancellation, Or
forbearance, I must request the deferment, cancellatioD, or forbearance in writing from the Institution and mUll submit to the InstitutiOD uy
documentation required by the InstiNtion to prove that I qualify for the deferment, cancellation, or forbearance. I further undentand. that, if I
am eligible for deferment, cancellation, or forbearance under Articles VI through XIV, I am responsible for submitting the appropriate requem
on time. I further understand that 1 may lose my deferment, cancellation, and forbearance benefits if I fail to tile lilY request on time.
n. Interest
Interest shall accrue from the beginning of the repayment period and .ball be at the ANNUAL PERCENTAGE RATE OF F1VE PERCDrr
(5-') on the unpaid balance, except that no interest shall accrue during any deferment period described in Article W.
m. ReDavment
(1) I promise to repay the principal and the interest that accNes on it to the Institution over a period begimlin& DiDe (9) months after the date
I cease to be at lUst a half.time regular student at a.a institution of higher education, or at a comparable institution outside the United States
approved for this purpose by the United States Secretary of Education (hereinafter called the Secretary), and endiDg.teD (10) years later, unleu
that period i. [shortened under paragraph ID(5), or] extended under paragraphs m(4), ID(7) (extensions), Vll(I), or Vll(3) (defermenla).
(2) Upon my written request, the repayment period may start on a date earlier than the one indicated ill paragraph ID(l).
(3)(A) I promise to repay the principal and interest over the course of the repayment period in equal monthly, bimonthly, or quarterly
installments, as determined by the Institution. I understand that, if my installment payment for all the loans made to me by the Institution i. not
a multiple of $S, the Institution may round that payment to the next highest dollar amount that is a multiple of $S.
(B) Notwithstanding paragraph ID(3)(A), upon my written request, repayment may be made in graduated installments in accordance with a
schedule approved by the Secretary.
(4) Notwithstanding paragraph m(l), if I qualify as a low.income individual during the repaYlXlent period, the Institutioo, upon my written.
request, may extend the repayment period for up to an additional ten (10) years and may adjust any repayJllent schedule to reflect my inc:ome.
[(5)(A) If the monthly rate that would be established under paragraph ID(I), or the total monthly repayment rate of principal and interest on
all my Faderal Perkins Loans, includill& this loan, i. Ie.. than $40.00 per month, I .hall repay the principal and interest on
this loan at the rate of $40.00 per month (wbich includes both principal and interest).
(5)(B) If I bave receivad Federal Perkins Loans from other institutions and the total monthly repayment rate OD thoae loans i. 1_ than
$40.00 the $40.00 monthly payment establishad under subparagraph ID(5)(A) include. the amoullla I owe
on all my outstanding Federal Perkins Loans, including those receivad from other institutions. The portion of the $40. 00
monthly payment that will be appliad to this loan will be the difference between $40.00 and the total of the amounts owed at .
monthly rate on my other Faderal Perkins Loans.
(6) The ,Institution may permit me to pay Ie.. than the rate of $40.00 per month for a period of nol more than one (I) year
where ne<:essary to avoid hardship to me unless that action would extend the repayment period in para&rapb ID(l).)
m The Institution may, upon my written request, reduce any scheduled repayments or extend the repayment perioct indicated in paragrapb
m(l), if, in its opinion, circumstaDces sucb as prolonged iIIoeu or unemployment prevent me from making the acbeduled repayments.
However, interest shall continue to &Ccrne.
IV. PreDavment
(1) I may, at my option and without penalty, prepay all or any part of the principal, plus any accrued interest thereon, at any time.
(2) Amounts I repay in the academic year in which the loan was made and the initial grace period has not ended will be used to reduce the
amount of the loan and will oot be considered a prepayment.
(3) If I repay amounts during the academic year in which the loao was made and the initial grace period ended, oo1y those amounts in excell
of the amount due for any repayment period sball be considered a prepayment.
(4) If, in an academic: year other than the award year in which the loan was made, I repay more than the amoUnt due for an installment, the
excess will be used to repay principal unless I designate it as an advance payment of the next regular installment.
V. Default
(1) Tbe Institution may, at its option, declare my loan to be in default and may demand immediate payment of the entire unpaid balance of
the loan, including principal. interest, late charges, and collection costs. if-
(A) I do not make a scheduled payment when due under the repayment schedule established by the Institution; and
(B) I do Dot submit to the Institution. on or before the date on which payment is due, documentation that I qualify for a deferment,
cancellation, or forbearance as described in Articles VI, vn, vm. IX, X, XI, XII, xm, or XIV of this agreement.
(2) I understand that the Institution may disclose to credit bureau organizations the amount of loans made to me, along with other relevant
Page I of 4
Federal Perkins/July 1993
information.
(3) I uDderstand that, if I default on :[JlY loan, the Institution may disclose that I have defaulted, aloog with other relevant information, to
credit bureau organizatioDl.
(4) Further, I understand that, if I default on my loan and the lOan is assigned to the Secretary for collection, the Secretary may disclose that
I have defaulted, along with other relevant information, to credit bureau organizations.
(5) I uDderstand that, in ilelllult Olf my loaD, r oriIl r~ my rigllrtl> forbeaJ'3Dce.
(6) I uDderstand that, if I defaul' aD my loaD, I will lose my right to defer repaymeDts.
(T) I uDderstand that, if the IostitutiOD accelerates the loaD uDder paragraph V(l), I will lose my right to receive a c8OcellatioD of a portiOD of
my loan for any aervice described in Articles vm, IX, X, XI, XII. xm. or XIV performed after the date the Institution accelerated the loan.
(8) I understand that failure to pay this ob1igatioD under the term. agreed UpOD will prevent my ObtainiD& additional student financial aid
authorized under Title IV of the Higher Education Act of 1965. as amended, uDtil I have made arrangemeots that are satisfactory to the
lnstitutioD or the Secretary regarding the repayment of the loan.
VI. Forbearance
(1) I understand that, upon making a properly documented wrineD request to the Institution, I am entitled to be granted forbearance of
priDcipal and iDterest or principal only, renewable at 12-month intervals, for a period not to exceed three years, if-
(A) My debt burden equals or exceeds 20 percent of my gross income; or
(B) The IostitutioD determiDes tha' I qualify for other re&SODS.
VII. Deferment
(1) I understand that, upon making a properly documented written request to the Institution, I may defer making scheduled iDStallment
payments and will not be liable for any interest that might otherwise ac:crue during the following periods:
(A) For 80y period that I am-
(i) EnrolJed and in attendance u a regular studeDt in at least a half.time coune of stUdy at an eligible institution;
(ii) Enrolled and in attendance as a regular studeDt in a course of INdy that is part of a graduate fellowship program. approved by the
Secretary;
(iii) EDgaged iD graduate or p05l-gradUale fellowship-supported study (such.. a Fulhright groot) outside the United States; or
(iv) Enrolled and in attendance in a coune of study that i. part of a rehabilitation training program for disabled individuals approved by the
Secretary.
(B) For any period that I am engaged in service described in Articles vm, IX. X. XI, XD, xm, or XIV of this agreement.
(C) For a period not to exceed three (3) yearl during which-
(i) I am seekiDg aod uDable to fiDd full-time employmeDt; or
(ii) For any reason that my Institution determines has caused or will cause me to bave an economic harclsbip.
(2) I uDderstand that I am Dot eligihle for a defermeDt UDder paragraph (Vll)(I)(A) while I am;serviDg iD a medical internship or resideoc:y
program.
(3) I uDderstand that I may cDDlinue to defer makiDg scheduled iostallmeDt paymeDts aod will Dot be liahle for any interest that might
otherwise accrue for a six (6) mODth period immediately followiDg the expiratioD of 80Y defermeDt provided in paragraph VU(I).
vm. Teachine. Cancellation
(I) I understand that, UPOD makiDg a properly documeDted writteD request to the IostitutiOD, I am eDtided to have up to 100 perceDt of the
amount of thil loan plus the interest thereon canc::eled if I perform qualifying service after the period for which I received the loau-
(A) As a full"time teacher in a public or other nonprofit elementary or secondary school in the school district of a local educational agency
that is eligible in IUch year of service for funds under Chapter I of the Education Consolidation and Improvement Act of 1981, as amended, and
wbich has been designated by the Secretary (after consultation with each State Department of Education) in accordance with the proviaioDS of
sectioD 465(a)(2) of the Act as a scbool with a high concentration of students from low..iDcome families. AD official Directory of deaignated.
low-income schools is published annually by the Secretary;
(B) As a full.time special education teacher (inclUding teachers of infants, toddlers, children, or youth with disabilities) in a public or other
nonprofit elementary or secondary school system, or as a full-time qualified professional provider of early intervention services in . pUblic or
other nonprofit program under pUblic supervision by the lead agency as authorized in sectiOD 676(b)(9) of the Individuals With Disabilities
EducatioD Act; or
(C) As a full~time teacher of mathematics, science, foreign languages, bilingual education, or any other field of expenise that is determined
by the SOl'e DepartmeDt of EducatioD to have a shortage of qualified teachers.
(2) A portioD of this loaD will be caoceled for each completed year of teachiDg service at the followiDg rates:
(A) 15 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for eacb of the first and
second complete academic years of that teacbin& service;
(8) 20 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for each of the third and.
fourth complete academic years of that teaching service; aIJd
(C) 30 percent of the total principal amouDt of the loan plus interest on the unpaid balance accruing during that year for the fifth complete
academic year of that teaching service.
D<:. Head Start CancellatioQ
(1) I understand that, upon making a properly documented wrinen request to the Institution. I am entitled to have up to 100 percent of the
amount of this loan plus the interest thereon canceled if I perform qualifying service after the period for whicb I received the loan as a full.time
staff member in a Head Start program if-
(A) That Head Start program is operated for a period that is comparable to a full schooJ year in the locality; and
Page 2 of 4
Federal PerkioslJuly 1993
(B) My sa1ary is not mora liwl tha salary of a comparable employea of the local educatiooal agency.
(2) This loan will be canceled at the raIB of r'~oftb<>lOllIIpriDcipal amOUDt of tha loan plus interast OIttha unpaid balotlCl>_ . I..
during that year for eacb complete school year or equivalent period of service in a Head Start program.
(3) Head Start is a preschool program carried out under the Head. Start Act.
X. l>filitarv Cancellation
(1) I undentand that, upon making a properly doeumented written request to the Institution, I am entitled to bave up to SO percent of lbe
principal amount of this loan plus the interest thereoD. canceled if I serve as a member of the Armed Forces of the United States in a.o arta of
hostilities that qualifies for special pay under section 310 of Title 37 of tha United States Code.
(2) This loan will he cancaled at the rate of 12 1/2 percent of the total principal amount of tha loan plus interest on the uDpaid balance
accruing during that year for each complete year of such qualifying service allar the period for which 1 raceived the loan.
XI. Volunteer Service CancellatioD
(1) I understand that, upon making a properly documented written request to the Institution, I am entitled to have up to 70 percent of the
amount of this loaD phu the interest thereon canceled if 1 perform qualifying service after the period for which 1 received the IOBD-
(A) ;.. a volunteer under the Peace Corps Act; or
(B) Ao a volunteer uDdar the Domestic VoluDteer Service Act of 1973 (ACTION programs).
(2) Thil loan will be canceled at the following rates:
(A) IS perceDt of the total priDcipal amount of the loao plus interest aD the uDpaid balance accruing during that year for each of the first lUllI
second twelve (12) month periods of volunteer service completed; and
(B) 20 perceDt of the total principal amouDt of the loan plus iDterest aD the unpaid balance acCruiDg dUriDg that year for each of the third lUllI
fourth twelve (12) month periods of volunteer service completed.
XII. Law Enforcement or Corrections Officer CauceUatioD
(1) I understaDd that, upon maki.og a properly documented written request to the Institution, 1 am entitled to have up to 100 percent of the
amount of this loaD plus the interest thereon canceled if I perform qualifying service after the period for which I received the loan-
(A) As a full-time law enforcement officer for service to an eligible local, State, or Federal law enforcement alency; or
(8) As a full-time cOrrectiODl officer for service to an elipble local. State. or Federal corrections agency.
(2) A portion of this loa.o will be canceled for each completed year of law enforcement or corrections aervice at the following rates:
(A) IS percent of the total principal amount of the loan plus interest on the unpaid balance ac:croing durioC that year for ueh of the tint and
second complete yean of that service;
(B) 20 peReDt of the total prillCipal amount of the loan plus intarest OD the uDpaid balance accruing during that year for each of the third aod
fourth complete years of that service; and
(C) 30 peraeDt of the total priDcipal amount of the loao plus intefast OD the unpaid balance acCruiDg dUriDg that year for the fifth complete
year of that aervice.
XID. tlurse or Medical TechniciS'n Cancellation
(1) 1 unde-.d that, UpOD making a properly documeDted writteD request to tha lnstitutioD, 1 am eDtitled to have up to 100 percent of the
amount of this loan plus the interest thereon canceled if 1 perform qualifying service after the period for which I received the loan AI a full.time
nune or medical technician providing health care services.
(2) A portion of this loan will be canceled for each completed year of service at the following rates:
(A) IS perceDt of the total priDcipal amount of the loao plus iDterest aD the uDpaid balance accruing during that year for each of the first lUllI
second complete years of that service;
(B) 20 perceDt of the total principal amount nf the loao plus interest aD the uDpaid balance accruiDg during that year for ...h of the third and
fourth complete years of that service; and
(C) 30 peReDt of the total principal amount of the loao plus interest on the uDpaid balance accruing during that year fnr the fifth complete
year of that Itrvice.
XIV. Child or Familv Service A2encv Cancellation
(1) 1 understand that, UpoD malting a properly documeDted written request to the Institution, I am eDtitled to have up to 100 perceDt of the
amount of this loan plus interest thereon canceled if I perform qualifyin& service after the period for which 1 reeetvee! the loan as a full-time
employee of an eligible public or private nonprofit child or family service agency who is prOViding, or supervising the provision of, services to
high.risk children who are from low-income communities and the families of such children.
(2) A portion of this loao will be canceled for each completed year of service at the followiDg ratas:
(A) IS percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for each of the first and
second complete years of that service;
(B) 20 percent of the total principal amount of the loao plus interest on the uDpaid balance aecruiDg during that year for each of the third and
fourth complete years of that service; and
(C) 30 percent of the total principal amount of the loan plus interest on the unpaid balance accruing during that year for the fifth complete
year of that service.
XV. Death and Disability Cancenation
(1) In the event of my death, the total amount owed on this loan will be canceled.
(2) If I become permanently and totally disabled after I receive this loan, the Institution will cancel the total amount of this loan.
XVI. ChanlZe in Name. Address. TeleDhone Number. or Social Security Number
I am responsible for informing the Institution of any change or changes in name, address, telephone Dumber, or Social Security number.
Page J of 4
Federal Perki""Iuly 1993
xvu. Late Chane
(I) The loatitutioo will imp_ a'l... cbarge if-
(A) I do not make a scbeduled payment wben it i. clue; and
(B) I do not IUbmit to the lDRitution, on or before th. date on which payment i. due, documentation thai: I qualify for a deferment.
~eUatioa"or'fv.h...._'e'" L 'LIIi;ia<Art!ider,W~ 1IIt,vm;nr, x.. XI, XII, XID., orXIVoftbis.~l.-UoI'Dt.
(2) No cbarge may exceed 20 percent of my monthly, bimootbly, or quarterly payment.
(3)(A) Tho Institutioo may-
(i) Add the late cbarge to the principal the clay after the scbeduled repayment was due: or
(ii) Include it with the next scheduled repayment after I have received notice of the late charge.
(B) If the Institution electa to add the I... cbarge to the outstanding principal of the loan, it must so inform me before the due date of the
next installment.
XYm. Assicmment
(I) This note may be assigned by the Institution only ta-
(A) The United States;
(B) ADother institution upon my transfer to that institution jf that institution is participating in this program; or
(C) Another wtitution approved by the Secretary.
(2) The provision. of this Dote that relate to the Institution sball, where appropriate, relate to an assignee.
(3) Any holder of this loan is sulSject to aU claims and defenses that I could assert against the Institution that made this loan; my recovery i.
limited to the amount I repaid on this loan.
XIX. Prior Loans
I bereby certify that I bave listed below all of the Federal Perkins Loans I have obtained at other institutions. (If DO prior loans bave been
received, state -None. -)
FEDERAL PERKINS LOANS AT OTHER INSTITUTIONS
Amount
Date
Institution
I
2
3
4
XX. Schedule of Advances
The following amounts were advanced to me under this loan agreement OD. the elates indicated:
Amount Dale Signature of Borrower
9-1-~5_ ){'{~iU Ct./--I.d2 ~
.1'-23-96 I? A .( j -i /7\ j Q.h /It. tt{,L./l,V
I
2
3
4
$500.00
$500.00
NOTICE TO BORROWER: DO NOT SIGN THIS NOTE BEFORE YOU READ IT.
I UNDERSTAND AND AGREE TO ALL OF THE FOREGOING TERMS AND CONDmONS.
[This Dote is signed as a sealed instrument.]
Signature ~/f4.;{~_ -:rfl j v7~l/hS)~ l(seaI)]
Date 8 I;;;"$) 1 . 19 C!
Permanent Addre.. (Street or Box Number, City, Slate, and Zip Code)
Social Security Number (borrower lIIust provide)
!I/()rt/) /fCi rt:l7, CT {}64 7~
040 -0;1. - (86S
(j; (!.nuj/I/}a /) r!f.
The borrower and Institution shall e~ecute this note without security and without endorsement.
The Institution shall provide a copy of this note to you and you sbould retain the copy for your records.
(Authority: 20 U.S.C.1087dd)
Page 4 of 4
Federal PerkiDsl1uly 1993
FEDERAL PERKINS LOAN
PROMISSORY NOTE
-'
.J J,=", ':) -,)~)J
1. Name (last. r..st, middle initiaQ and
Permanent Address (street, city, state, zip code)
2. Social,?ecurity Number
() /.f {; - t;? - ( E" ~"S-
cr
3. Date of Birth
/ /_;J 7 / 7 7
4. Area CodelTelephone Number
0-.:]U 3) c_~3q - {; q / 7-
5. Driver's License Number (Ust state abbreviation first)
CTOlb030s'E?'S'
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Celentano,
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Kristin T.
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6. School Name &. Address (street. city, state, zip code)
7. Borrower Status
8. Interest Rate
Dickinscn College
P.O. Box 1773
Carlisle. PA 17013-2896
~ HaIf.time or greater I:l Less than har._ 5 %
9. Loan Amount: 10. Loan Period
$2,000.00
1996-97
TERMS AND CONDITIONS:
IAny ~ """,,or pang<aph may be inc1udod at_ or_I
APPLICABLE LAW. The terms of this note and any disbursements made underthls note shall be interpreted In accordance with Part E or Title IV ofthe Higher
Education Act of 1965. as amended (hereinafter called the Act). as well as Federal regulations issued under the Act. All sums advanced under this note are subJet;t to the
Act and Federal regulations issued under the Act.
REPAYMENT. I am obligated to n!:pay the principal and the interest that accrues on it to the above-named institution (hereinafter called the school) over a period
beginning 9 months (or sooner if I am a less than a half-time borrower) after the date I cease to be at leau a half-time student at an Institution of hi8her education or a
comparable school outside the United Stat" approved by the United States Secretary of Education (hereinafter called the Secretary) and endlng 10 years later. unles.s I
request In writing that my replllyment 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 pllyl1\ents. Upon my written ~uest my repayment period may be extended during periods of deferment, hardship, or
forbearance and I may make graduated installments in accordance with a schedule approved by the Secretary. I will make my installment payments in equal monthly,
bimonthly or quarterly installments as determined by the school. The school may round my lnstallment payment to the next highest multiple of $5. II will make a
minimum monthly repayment of $40 (or $30 if I have outstanding Federal Perkins loans made before October 1, 1992 that included the $30 mlnlmum payment option)
In accordance with the Minimum Monthly Payment Section of the Terms and Conditions contained on the reverSe side of this document.)
LATE CHARGES - The school will impose late charges if I do not make a scheduled payment when due or if I faU to submit to the school on or before the due date of
the payment. a properly documented written request that I qualify for any of the forbearance. deferment or cancellation benefits as described below. No late charges may
exceed 20% of my monthly. bimonthJy or quarterly payment. The school may add the late charges to principal the day after the scheduled repayment was due or lnclude
It with the next scheduled repayment after I have received notice of the charge. and such notice is sent before the next installment is due.
REQUESTS FOR DEFERMENT. CANCELLATION OR FORBEARANCE - To receive deferment. cancellation. or forbearance benefits, I mwt make a written request
to the school and must submit to the school any documentation the school requires to prove my eligibility for these benefits. I am responsible for submittlng the
appropriate requests on time. and I may lose my benefits if I fail to me my request on time.
DEFAULT. If I fail to make a scheduled payment when due; If I faU to submit to the schooJ. on or before the due date of a scheduled payment. do<:umentatlon that I
qualify for a deferment, cancellation. or forbearance; or if I fall to comply with the terms and conditions of this promissory note or written repayment agreement. the
school may, at Its option, declare my loan to be in default and may accelerate my loan (demand immediate payment of the entire unpaid balance of the loan, induding
principal. interest. late charges. and collection costs). The school. and the Secretary. if my loan is assigned to the Secretary for collection. shan disclO$e to credit bureau
organizations that I have defaulted and all other relevant loan information. I wUllose my right to defer payments and my right to forbearance If I default on my loan. I
will lose my right to receive cancellation benefits for service that is performed after the date the school accelerated the loan. I will be ineligible for any further federal
student financial assistance authorized under the Act until I make arrangements that are satisfactory to the school or the Secretary to repillY my loan.
CHANGE OF STATUS. I will inform the school of any changeln my name. address. telephone number. Social Security number. or driver's license number.
ASSIGNMENT - This note may be assigned by the school only to the United States. The provisions of this note that relate to the school shall where appropriate relate to
the assignee.
PROMISE TO PAY: I promise to pay the school. or a sUbsequeni holder of the Promissory Note. the sum ofamount(s) advanced to me under the terms ofthls Note. plus
intere;t and other fees which may become due as provided In this Note. I promise to pay all reasonable collection costs. including attorney fees and other charges,
necessary for the collection of any amount not paid when due. I wUl not sign this Note before reading It. including the provl$lons on the reverse side. ThiS loan has been
made to me without security or endorsement. My signature certifies I have read, understand. and agree to the terms and conditions of this Promissory Note. THIS IS A
WANtS) THAT MUST BE REPAID
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Borrower's Signature
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EXHIBIT "B"
Date:
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 Compiaint 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 penaities 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
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Dated:
F,\F1LES\DA T AFILI!\DiriJl,son CoDege 7619\DickinsonCoIlegeCollettiornl7619C\DoeumentslI97_coml
CERTIFICATE OF SERVICE
I, Martha-Anne Then, an authorized agent of Martson Deardorff Williams & Otto, hereby
certifY that a copy of the foregoing Complaint was served this date by depositing same in the Post
Office at Carlisle, P A, Certified Mail, Restricted Delivery, postage prepaid, addressed as follows:
Kristin T. Celetano
60 Brookside A venue East
Westbrook, Connecticut 06498
MARTS ON DEARDORFF WILLIAMS & OTTO
ByLr)&JdtLz - L~~
Martha-Anne Then
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: August 26, 2003
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F: \FILES\DA T AFILE\Dickinson College 7619\DickinsonCollegeCollections7619C\Documents\ 197, praserv/mai
Created: lOflO/0202:46:50PM
Revised: 09/17f0311:33:18AM
7619c,197
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03-04211
CIVIL ACTION-LAW
KRISTIN T. CELENTANO
Defendant
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE TO DOCUMENT SERVICE AND COST OF SERVICE
PURSUANT TO THE PENNSYL VANIA LONG ARM STATUTE
I hereby certify that a copy of the Complaint was mailed to Kristin T. Celentano on August
27,2003, by certified mail, restricted delivery, return receipt requested.
Attached is the Post Office return receipt signed and dated September 9,2003 and a copy of
the receipt showing the cost of service was $8.38.
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David R. Galloway, Esquire
J.D. No. 87326
Ten East High Street
Carlisle, PA 171313-3093
(717) 243-3341
F WILLIAMS & OTTO
Date: September 17,2003
Attorneys for Plaintiff
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. Complete ~ems 1, 2. and 3. Also complete
~em 4 ~ Reetricted Delivery is desired,
. Print your name and address on the reverse
so thet we can retum the oerd to you,
. Attach this card to the back of the mail piece,
or on the front if space permits.
1. Article Addressed to:
o Agent
o Addressee
c. Dat()Oellvery
D. Is deliVerY addf8Sl1 dm.ent from Item 17 0 Yes
If YES, enter delivery addresS below: 0 No
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o Return Receipt for Merchandise
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4. Restricted Delivl"Y7 (Extra Fee)
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2. Article Number
(Transfer from service label)
PS Form 3811 , August 2001
7001 2510 0006 5&62 942&
Domestic Return Recelpt
102595-02-M-1035
U S. Postal Service
CERTIFIED MAIL RECEIPT
(Domestic M::III Only, No fnsurdfwc Cove/age ProVided)
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o Restricted Delivery Fee
(Endorsement Required)
CERTIFICATE OF SERVICE
I, Marti Then, an authorized agent of Marts on DeardorffWiIliams & 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, P A, first class mail, postage prepaid, addressed as follows:
Miss Kristin T. Celentano
60 Brookside Avenue East
Westbrook, CT 06498
MARTSON DEARDORFF WILLIAMS & OTTO
BY~~\~
Marti Then
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: September 17, 2003
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DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 03-04211
CIVIL ACTION-LAW
KRISTIN T, CELENTANO,
Defendant
ruRYTRIALOFTWELVEDEMANDED
TO: KRISTIN T. CELENTANO
NOTICE OF ENTRY OF DEFAULT JUDGMENT
You are hereby notified that on /?L.(" 10.::1 , 2003, the following Judgment was entered
against you in the above-captioned cas~J; t1:fe amount of$I,151,18, plus interest from July 15,
2003 in the amount of$21.15 and collection andattomeys' fees in the amount of$500,00 fora total
judgment of $1,672.33, plus costs of suit and interest accruing at $0,15 per day from date of
judgment.
Date: December 4, 2003
~
Prothonotary
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I hereby certif'y that the name and address of the proper person to receive this notice under
Pa, R. Civ, p, 236 is:
Ms, Kristin T, Celetano
60 Brookside Avenue East
Westbrook, CT 06498
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F:IFlLESIDATAFILE\Dickinson College 76]9\DickinsonCollegeCollcctions7619ClDocllmentsI197pral/nlm
Created: 1213/03 1040AM
Revised: 12/4/03 8:41AM
76]9C197
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v,
NO, 03-04211
CIVIL ACTION-LAW
KRISTIN T, CELENTANO,
Defendant
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE
TO THE PROTHONOTARY:
Enter default judgment in the above-captioned action in favor of Plaintiff and against
Defendant in the amount of$l, 151.18, plus interest from July 15,2003 in the amount of$21.1S and
collection and attorneys' fees in the amount of$SOO.OO for a total judgment of$1,672.33, plus costs
of suit and interest accruing at $0,15 per day from date of judgment
I do hereby certify that a written notice of intention to file this Praecipe (in the form attached
hereto) was mailed to Defendant at the address indicated thereon, on or about November 18, 2003,
which date was subsequent to the date default occurred and at least ten (l0) days prior to the date
ofthis Praecipe,
By
DaVId RGalloway, Esquire
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
\
Attorneys for Plaintiff
Dated: December 4, 2003
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FIFIU,S\DA T AFILEIDickinson College 76 I 9\DickinsonCollegeCollections76 I 'lCIDo!'umcnts\ I r;n.'lO[ I /nlm
Created IlII8/03 IA4PM
Revised: 11118103 3:15PM
7619C.197
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03-04211
CIVIL ACTION-LAW
KRISTIN T. CELENTANO,
Defendant
JURY TRIAL OF TWELVE DEMANDED
TO: KRISTIN T. CELENTANO, Defendant
IMPORTANT NOTICE
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 MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Lawyer Referral Service
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
MARTS ON DEARDORFF LIAMS & OTTO
By ~-),/2
David R~, EsqUIre
LD, Number 49S13
Ten East High Street
Carlisle, PAl 70 I3
(717) 243-3341
Attorneys for Plaintiff
Dated: November IS, 2003
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CERTIFICATE OF SERVICE
I, Nichole L. Myers, an authorized agent of MARTS ON DEARDORFF WILLIAMS &
OTTO, hereby certifY that a copy ofthe foregoing Praecipe was served this date by depositing same
in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Ms, Kristin T, Celetano
60 Brookside Avenue East
Westbrook, CT 06498
MARTSON DEARDORFF WILLIAMS & OTTO
By Ji(chtU lf1 n2iiLlk-
Nichole L. Myers J -
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: December 4, 2003
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F\F1LES\DA T AFILE\DickinsonCollege7619\Collections\CulTenl\ \ 97\pra \ ftde
Created 815103 I 27PM
Revised; 1118/06 10 12AM
7619C.197
Christopher E. Rice, Esquire
MARTS ON DEARDORFF WILLIAMS & OTTO
LD, 90916
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO. 03-04211
CNIL ACTION-LAW
KRISTIN T, CELENTANO,
Defendant
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE TO SETTLE. DISCONTINUE AND END
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Kindly mark the above-referenced matter as settled, discontinued and ended,
MARTSON DEARDORFF WILLIAMS & OTTO
By CL -4-<- c; /C
Christopher E. Rice, Esquire
10 East High Street
Carlisle,PA 17013
(717) 243-3341
Date: January 18, 2006
Attorneys for Plaintiff
f. , "
CERTIFICATE OF SERVICE
I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certifY
that a copy ofthe foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle,
P A, first class mail, postage prepaid, addressed as follows:
Ms, Kristin Celentano
60 Brookside Avenue East
Westbrook, CT 06498
MARTSON DEARDORFF WILLIAMS & OTTO
, la D, Eckenroad
Ten East High Street
Carlisle,PA 17013
(717) 243-3341
Dated: January 18, 2006
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