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HomeMy WebLinkAbout03-4212DICKINSON COLLEGE, Plaintiff V. OLGA N. FILIPPOVA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03 CIVIL ACTION-LAW 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 fights 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 Date: August 26, 2003 ~F,4WlLLIAMS & OTTO I.D. No. 87326 x~ Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attomeys for Plaintiff DICKINSON COLLEGE, Plaintiff OLGA N. F1LIPPOVA Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- CWIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED COMPLAINT AND NOW, comes Plaintiff Dickinson College by and through its attomeys, MARTSON DEARDORFF WILLIAMS & OTTO, and hereby avers as follows: 1. Plaintiff Dickinson College is a Pennsylvania educational institution and nonprofit corporation with its principle place of business at West Street, Post Office Box 1773, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant, Olga N. Filippova, (hereinat~er "Student"), is an adult individual with a last known address of 224 East 1 lth Street, Apartment 24, New York, NY 10003. 3. On or about October 3, 1990, Student entered into a Promissory Note (Note #1) with Plaintiff for the financing of $550.00, plus interest, for educational services and benefits to Student at Plaintiff's institution. A copy of Note #1 is attached hereto as Exhibit "A." 4. On or about Febmmy 8, 1991, Student entered into a Promissory Note (Note #2) with Plaintiff for the financing of $550.00, plus interest, for educational services and benefits to Student at Plaintiff's institution. A copy of Note #2 is attached hereto as Exhibit "B." 5. On or about July 5, 1991, Student entered into an additional Promissory Note (Note #3) with Plaintiff for the financing of $330.00, plus interest, for educational services and benefits to Student at Plaintift's institution. A copy of Note #3 is attached hereto as Exhibit "C." 6. On or about September 9, 1991, Student entered into an additional PromissoryNote (Note ~4) with Plaintiff for the financing of $600.00, plus interest, for educational services and benefits to Student at Plaintiff's institution. A copy of Note g4 is attached hereto as Exhibit "D." 7. On or about February 6, 1992, Student entered into an additional PromissoryNote (Note #5) with Plaintiff for the financing of $1,050.00, plus interest, for educational services and benefits to Student at PlaintitTs institution. A copy of Note #5 is attached hereto as Exhibit "E." 8. On or about October 6, 1992, Student entered into an additional Promissory Note (Note #6) with Plaintiff for the financing of $900.00, plus interest, for educational services and benefits to Student at Plaintiff's institution. A copy of Note #6 is attached hereto as Exhibit "F." 9. On or about February 9, 1993, Student entered into an additional Promissory Note (Note #7) with Plaintiff for the financing of $900.00, plus interest, for educational services and benefits to Student at Plaintiff's institution. A copy of Note #7 is attached hereto as Exhibit "G." 10. On or about March 11, 1993, Student entered into an additional Promissory Note (Note #8) with Plaintiff for the financing of $400.00, plus interest, for educational services and benefits to Student at Plaintiff's institution. A copy of Note #8 is attached hereto as Exhibit "H." 11. On or about September 27, 1993, Student entered into an additional Promissory Note (Note ~9) with Plaintiff for the financing of $1,700.00, plus interest, for educational services and benefits to Student at Plaintiff's institution. A copy of Note #9 is attached hereto as Exhibit "I." 12. On or about February 14, 1994, Student entered into an additional PromissoryNote (Note #10) with Plaintiff for the financing of $1,300.00, plus interest, for educational services and benefits to Student at Plaintiff's institution. A copy of Note #10 is attached hereto as Exhibit "J." 13. The collective principal balance for Note #1, Note #2, Note #3, Note ~4, Note #5, Note #6, Note #7, Note #8, Note ~9 and Note #10 is $8,280.00. 14. Note # 1 through Note # 10 grant Plaintiffreasonable collection and attorneys' fees which Plaintiffhas calculated to be $1,242.00. 15. As of July 18, 2003, the principal and interest due and payable by Student to Plaintiff was $1,274.67, plus interest in the amount of $0.18 per day fi:om July 18, 2003. 16. Student stopped making monthly payments on Note #1, Note #2, Note #3, Note #4, Note #5, Note #6, Note #7, Note #8, Note ~9, and Note #10 on or about July 20, 2000. 17. As of July 18, 2003, the outstanding balance of $1,274.67 represents the total and actual overdue value of the financing provided Student under Note # 1 through Note #10 for which she has yet to pay. 18. Plaintiff fulfilled, performed and complied with all obligations and conditions of Note #1 through Note #10. COUNT I BREACH OF CONTRACT 19. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 18 &this Complaint. 20. Student breached the expressed and implied obligations, conditions and terms of agrecnuent of Note #1 through Note #10 by failing to pay the amounts financed therein. WHEREFORE, Plaintiff demands judgment against Defendant, OlgaN. Filippova, in the amount of $1,274.67, plus interest in the amount of $0.18 per day from July 18, 2003, collection and attorneys' fees in the amount of $1,242.00 and costs of suit. COUNT II IN QUANTUM MER UI T Date: August 26, 2003 21. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 20 of this Complaint. 22. Having requested Plaintiffto loan money, and doing so to the benefit of Student, Student became liable to Plaintiff for said money. 23. Student has been unjustly enriched by accepting said money without paying Plaintiff reasonable compensation therefor. 24. The total amount by which Student has become enriched is $1,274.67, plus interest in the amount of $0.18 per day from July 18, 2003. WHEREFORE, Plaintiffdemandsjudgment against Defendant, OlgaN. Filippova, in the amount of $1,274.67, plus interest in the amount of $0.18 per day from July 18, 2003, collection and attorneys' fees in the amount o1'$1,242.00 and costs of suit. LIAMS & OTTO David R. Gallow-ay I.D. No. 87326 / Ten East High Street [ Carlisle, PA 17013-3093 \ (717) 243-3341 Attorneys for Plaintiff TRUTH-IN-LENDING STATEMENT DICKINSON COLLEGE INSTITUTIONAL LOAN Name of Borrower Address Olga N. Filippova Lomonosovskiy Str 18 Moscow 117296, USSR ANNUAL PERCMNTAGE RATE The cost of your credi: as a yearly AMOUNT FINANCED The amount of credit provided to you. Prior to Du~ing r epay~ent repayment 0 % 6 Z $ 550.00 Late Charge: Prepayment: If a payment is late, you may he 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 payabl~ quarterly. If you pay off 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. THE BORROWER A~NOVLEDGES RZCEIPT OF AN EXACT COPY OF THIS STATEMENT. STUDENT INSTITUTIONAL REPRESENTATIVE EXHIBIT "A" DICKINSON COLLEGE CARLISLE, PENNSYLVANIA 17013 Date August 28, 1990 I hereby acknowledge receipt from DICKINSON COLLEGE of a loan in the amount of Five Hundred F~ft¥ Dollars ($550.00), which is hereby applied on my College account for the Fall semester of the current academic year. I agree to repay Dickinson College according to the following plan: I. Interest Interest shall accrue from the first of the month following the month in which I graduate or cease to matriculate at Dickinson College, and shall be at the ANNUAL PERCENTAGE RATE OF 6 percent interest on the unpaid balance. Interest will accrue on a daily basis. II. Repayment I promise to repay the principal and the interest which accrues on it over a period beginning six months after the date I graduate or cease to matriculate at Dickinson College. I will repay in equal monthly installments with a minimum monthly payment of $30.00 (which includes both principal and interest), and a maximum repayment period of five years (60 months). I realize that the College is under no obligation to grant deferments during the course of the repayment period. III. Default If I fail to make a scheduled repayment of any installment, the entire unpaid indebtedness including interest due and accrued thereon, plus any applicable penalty charge, will, at the option of Dickinson College, become immediately due and payable. I understand that if I default on my loan repayments that Dickinson College may disclose that I have defaulted, along with other relevant information, to credit bureau organizations. IV. Penalty Charge If I fail to make timely payment of all or any part of a scheduled installment, I promise to pay the charge assessed against me by Dickinson college. No charge may exceed $1.00 for the first month or part of a month by which the installment is late, and $2.00 for each month or part of a month thereafter. I promise to pay all attorney's fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. Student Signature ~2~ F..~ .~ ~ ~_~,_ ~lga N. ilippova Soclal Security Number " DICKINSON COLLEGE CARLISLE, PENNSYLVANIA 17013 Date January 21, 1990 I hereby acknowledge receipt from DICKINSON COLLEGE of a loan in the amount of Five Hundred Fifty Dollars ($550.00), which is hereby applied on my College account for the Fall semester of the current academic year. I agree to repay Dickinson College according to the following plan: I. Interest Interest shall accrue from the first of the month following the month in which I graduate or cease to matriculate at Dickinson College, and shall be at the ANNUAL PERCENTAGE RATE OF 6 percent interest on the unpaid balance. Interest will accrue on a daily basis. II. Repayment I promise to repay the principal and the interest which accrues on it over a period beginning six months after the date I graduate or cease to matriculate at Dickinson College. I will repay in equal monthly installments with a minimum monthly payment of $30.00 (which includes both principal and interest), and a maximum repayment period of five years (60 months). realize that the College is under no obligation to grant deferments during the course of the repayment period. III. Default If I fail to make a scheduled repayment of any installment, the entire unpaid indebtedness including interest due and accrued thereon, plus any applicable penalty charge, will, at the option of Dickinson College, become immediately due and payable. I understand that if I default on my loan repayments that Dickinson College may disclose that I have defaulted, along with other relevant information, to credit bureau organizations. IV. Penalty Charge If I fail to make timely payment of all or any part of a scheduled installment, I promise to pay the charge assessed against me by Dickinson College. No charge may exceed $1.00 for the first month or part of a month by which the installment is late, and $2.00 for each month or part of a month thereafter. I promise to pay all attorney's fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. Student ~ Signature ~ ~'~ '~L-~?~-~'~"~__ Date Olga N. Filippova social Security Number TRUTH-IN-LENDING STATEMENT DICKINSON COLLEGE INSTITUTIONAL LOAN Name of Borrower Address Olga N. Filippova Lomonsovskiy Str 18-290 Moscow 117296 USSR ~NNUAL PERCLNTAGE RATE The cost of your credit as a yearly rate. AMOUNT FINAN C~D The amounc of credi~ provided to you. Prior to Du~ing repayment repayment 0 % 6 Z $ 330.00 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 paymen~ if this loan is payable monthly, $3.00 for each late payment if this loan is payable bimouthly, $6.00 for each late payment if this loan is payabl~ quarterly. Prepaymenti If you pay off early, you will not have to pay a penalty. See your promissory nots for any additional information about nonpayment, de- fault, any required repayment in full before the ~cheduled date, and pre- payment. THE BORROWER ACKNOW-aEDGE$ RECEIPT OF AN EXACT COPY OF THIS STATEMENT. INSTITUTIONAL REPRESENTATIVE EXHIBIT "C" DICKINSON COLLEGE CARLISLE, PENNSYLVANIA 17013 Date: July 2, 1991 I hereby acknowledge receipt from DICKINSON COLLEGE of a loan in the amount of Three Hundred Thirty Dollars ($330.00), which is hereby applied on my College account for the Summer semester of the current academic year. I agree to repay Dickinson College according to the following plan: I. Interest Interest shall accrue from the first of the month following the month in which I graduate or cease to matriculate at Dickinson College, and shall be at the ANNUAL PERCENTAGE RATE OF 6 percent interest on the unpaid balance. Interest will accrue on a daily basis. II. Repayment I promise to repay the principal and the interest which accrues on it over a period beginning six months after the date I graduate or cease to matriculate at Dickinson College. I will repay in equal monthly installments with a minimum monthly payment of $30.00 (which includes both principal and interest), and a maximum repayment period of five years (60 months). I realize that the College is under no obligation to grant deferments during the course of the repayment period. III. Default If I fail to make a scheduled repayment of any installment, the entire unpaid indebtedness including interest due and accrued thereon, plus any applicable penalty charge, will, at the option of Dickinson College, become immediately due and payable. I understand that if I default on my loan repayments that Dickinson College may disclose that I have defaulted, along with other relevant information, to credit bureau organizations. IV. Penalty Charge If I fail to make timely payment of all or any part of a scheduled installment, I promise to pay the charge assessed against me by Dickinson College. No charge may exceed $1.00 for the first month or part of a month by which the installment is late, and $2.00 for each month or part of a month thereafter. I promise to pay all attorney's fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. Student Signature Olga N. ~Yippova Social Security Number 0ets / TRUTH-IN-LENDING STATEMENT DICKINSON COLLEGE INSTITUTIONAL LOAN Name of Borrower Address Olga N. Fillipova Lomonsoskiy Str 18-290 Moscow 117296 USSR AN-N-UAL PERCENTAGE RATE The cost of your credit as a yearly rate. AMOUNT FINANCED The amount of credit provided to you. Prior to Du~ing repayment repayment 0 Z 6 Z $ 600.00 Late Charge: Prepayment: If a payment is late, you may he charged: $i.00 for the first late payment, and $2.00 for each subsequent late payment if =his loan is payable monthly, $3.00 for each late payment if this loan is payable bimouthly, $6.00 for each late if ~his loan is payabl~ quartar!y. If you pay off early, you will not have to pay a penalty. See your promissory note for any additional information about nonpayment, de- fault, an7 required repayment in full before the scheduled date, and pre- payment. THE BORROWER ACK~NOWLZDGES RZCEIPT OF AN EXACT COPY OF T~IS STATEM]ENT. STUDENT REPRESENTATIVE DATE EXHIBIT "D" DICKINSON COLLEGE CARLISLE, PENNSYLVANIA 17013 Date: September 2, 1991 I hereby acknowledge receipt from DICKINSON COLLEGE of a loan in the amount of Six Hundred Dollars ($600.00), which is hereby applied on my College account for the Fall semester of the current academic year. I agree to repay Dickinson College according to the following plan: I. Interest Interest shall accrue from the first of the month following the month in which I graduate or cease to matriculate at Dickinson College, and shall be at the ANNUAL PERCENTAGE RATE OF 6 percent interest on the unpaid balance. Interest will accrue on a daily basis. II. Repayment I promise to repay the principal and the interest which accrues on it over a period beginning six months after the date I greduate or cease to matriculate at Dickinson College. I will repay in equal monthly installments with a minimum monthly payment of $~0.00 (which includes both principal and interest), and a maximum repayment period of five years (60 months). I realize that the College is under no obligation to grant deferments during the course of the repayment period. III. Default If I fail to make a scheduled repayment of any installment, the entire unpaid indebtedness including interest due and accrued thereon, plus any applicable penalty charge, will, at the option of Dickinson College, become immediately due and payable. I understand that if I default on my loan repayments that Dickinson College may disclose that I have defaulted, along with other relevant information, to credit bureau organizations. IV. Penalty Charge If I fail to make timely payment of all or any part of a scheduled installment, I promise to pay the charge assessed against me by Dickinson College. No charge may exceed $1.00 for the first month or part of a month by which the installment is late, and $2.00 for each month or part of a month thereafter. I promise to pay all attorney's fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. Signature " Olga N. FiIlfpova Social Security Number /F~ ~ ~ -- ~' Date TRUTH-IN-LENDIN¢ STATEMENT DICKINSON COLLEGE INSTITUTIONAL LOAN Name of Borrower Olga N. Filippova Lomonosovskiy St. 18-290 117296 Moscow ~NNUAL PERC~'NTAGE RATE The cost of your credit as a yearly rate. AMOUNT FINANCZD The amount of credit provided =o you. Prior to Du~ing repayment repayment 0 % 6 % $ 1050.00 Late Charge: Prepayment: 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 =his loan is payabl~ quarterly. If you pay off 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. THE BORROWER ACKNOWLEDGES RECEIPT OF AN EXACT COPY OF THIS STATEMENT. STUDENT INSTITUTIONAL ~~.~ REPRESENTATIVE ~'g~ EXHIBIT "E" DICKINSON COLLEGE CARLISLE, PENNSYLVANIA 17013 Date: January 21, 1992 I hereby acknowledge receipt from DICKINSON COLLEGE of a loan in the amount of One Thousand Fifty Dollars ($1,050.00), which is hereby applied on my College account for the Spring semester of the 1991-92 academic year. I agree to repay Dickinson College according to the following plan: I. Interest Interest shall accrue from the first of the month following the month in which I graduate or cease to matriculate at Dickinson College, and shall be at the ANNUAL PERCENTAGE RATE OF 6 percent interest on the unpaid balance. Interest will accrue on a daily basis. II. Repayment I promise to repay the principal and the interest which accrues on it over a period beginning six months after the date I graduate or cease to matriculate at Dickinson college. I will repay in equal monthly installments with a minimum monthly payment of $30.00 (which includes both principal and interest), and a maximum repayment period of five years (60 months). I realize that the College is under no obligation to grant deferments during the course of the repayment period. III. Default If I fail to make a scheduled repayment of any installment, the entire unpaid indebtedness including interest due and accrued thereon, plus any applicable penalty charge, will, at the option of Dickinson College, become immediately due and payable. I understand that if I default on my loan repayments that Dickinson College may disclose that I have defaulted, along with other relevant information, to credit bureau organizations. IV. Penalty Charge If I fail to make timely payment of all or any part of a scheduled installment, I promise to pay the charge assessed against me by Dickinson College. No charge may exceed $1.00 for the first month or part of a month by which the installment is late, and $2.00 for each month or part of a month thereafter. I promise to pay all attorney's fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. Student .'~.~/ '~-~ Signature ' c. (.<_ / ,, C Date , OLga N. Filippova Social Security Nu~er ..~ ~' ~: '~'.~ // TRUTH-IN-LENDING .STATEMENT DICKINSON COLLEGE INSTITUTIONAL LOAN Name of Borrower Address Olga N. Filippova Lomonosovkiy St. 18-290 117296 Moscow A~NNUAL PERCENTAGE RATE The cost of your credit as a yearly AMOUNT FINANCED The amount of credi: provided to you. Prior to During repayment repayment 0 % 6 % $ 900.00 Late Charge: If a paymen: is late, you may be charged: $1.00 for :he firs: late payment, and $2.00 for each subsequen: late paymen: if this loan is payable monthly, $3.00 for each late paymen= if this loan is payable bimou=hly, $6.00 for each la:e payment if this loan is payable quarterly. Prepayment: If you pay off early, you will not have :o pay a penalty. See your promissory no:e for any additional information about nonpayment, de- fault, any required repayment in full before the scheduled date, and pre- payment. THE BORROWER ACKNOVLEDGES RECEIPT OF AN EXACT COPY OF THIS STATEMENT. REPRESENTATIVE '---~,' ~ ....... V ~-~ EXHIBIT "F" DICKINSON COLLEGE CARLISLE, PENNSYLVANIA 17013 Date: August 31, 1992 I hereby acknowledge receipt from DICKINSON COLLEGE of a loan in the amount of Nine hundred dollars ($900.00), which is hereby applied on my College account for the fail semester of the 1992-93 academic year. I agree to repay Dickinson College according to the following plan: I. Interest Interest shall accrue from the first of the month following the month in which I graduate or cease to matriculate at Dickinson College, and shall be at the ANNUAL PERCENTAGE RATE OF 6 percent interest on the unpaid balance. Interest will accrue on a daily basis. II. Repayment I promise to repay the principal and the interest which accrues on it over a period beginning six months after the date I graduate or cease to matriculate at Dickinson College. I will repay in equal monthly installments with a minimum monthly payment of $30.00 (which includes both principal and interest), and a maximum repayment period of five years (60 months). I realize that the College is under no obligation to grant deferments during the course of the repayment period. III. Default If I fail to make a scheduled repayment of any installment, the entire unpaid indebtedness including interest due and accrued thereon, plus any applicable penalty charge, will, at the option of Dickinson College, become immediately due and payable. I understand that if I default on my loan repayments that Dickinson College may disclose that I have defaulted, along with other relevant information, to credit bureau organizations. IV. Penalty Charge If I fail to make timely payment of all or any part of a scheduled installment, I promise to pay the charge assessed against me by Dickinson College. No charge may exceed $1.00 for the first month or part of a month by which the installment is late, and $2.00 for each month or part of a month thereafter. I promise to pay all attorney's fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. Signature ~' ~i~_ ·~) - '>~ ~//- ~ Cf © ' Date Olga N. Fil~ppov~ Social Security Number DICKINSON COLLEGE CARLISLE, PENNSYLVANIA 17013 Date: January 22, 1993 I hereby acknowledge receipt from DICKINSON COLLEGE of a loan in the amount of Nine Hundred Dollars ($900.00), which is hereby applied on my College account for the spring semester of the 1992-93 academic year. I agree to repay Dickinson College according to the following plan: I. Inter~st Interest shall accrue from the first of the month following the month in which I graduate or cease to matriculate at Dickinson College, and shall be at the ANNUAL PERCENTAGE RATE OF 6 percent interest on the unpaid balance. Interest will accrue on a daily basis. II. Repayment I promise to repay the principal and the interest which accrues on it over a period beginning six months after the date I graduate or cease to matriculate at Dickinson College. I will repay in equal monthly installments with a minimum monthly payment of $30.00 (which includes both principal and interest), and a maximum repayment period of five years (60 months). realize that the College is under no obligation to grant deferments during the course of the repayment period. III. Default If I fail to make a scheduled repayment of any installment, the entire unpaid indebtedness including interest due and accrued thereon, plus any applicable penalty charge, will, at the option of Dickinson College, become immediately due and payable. I understand that if I default on my loan repayments that Dickinson College may disclose that I have defaulted, along with other relevant information, to credit bureau organizations. IV. Penalty Charge If I fail to make timely payment of all or any part of a scheduled installment, I promise to pay the charge assessed against me by Dickinson College. No charge may exceed $1.00 for the first month or part of a month by which the installment is late, and $2.00 for each month or part of a month thereafter. I promise to pay all attorney's fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. Signature _ ,l ~Q ?/C,',/'-'q _~ Olga N. Filippova EXHIBIT "G" TRUTH-IN-LENDING STATEMENT DICKINSON COLLEGE INSTITUTIONAL LOAN Name of Borrower Address Olga N. Filippova Lomonosovkiy St. 18-290 117296 Moscow ANNUAL PERC~'NTAGE RATE The cos= of your credit as a 7early rate. AMOUNT FINANCED The amount of credit provided to you. Prior to During repayment repayment 0 Z 6 Z $ 400.00 Late Charge: If a payment is late, you may be charged: $1.00 for the first late payment, and $2.00 for each ~ubsequent late paymen~ if this loan is payable monthly, $3.00 for each la~e payment if this loan is payable bimonthly, $6.00 for each late payment if this loan is payable quarterly. Prepayment: If you pay off early, you will 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, THE BORROWER ACKNOWLEDGES RECEIPT OF AN EXACT COPY OF THIS STATEMENT. INSTITUTIONAL REPRESENTATIVE EXHIBIT "H" DICKINSON COLLEGE CARLISLE, PENNSYLVANIA 17013 Date: February 18, 1993 I hereby acknowledge receipt from DICKINSON COLLEGE of a loan in the amount of Four hundred dollars ($400.00), which is hereby applied on my College account for the Spring semester of the 1992-93 academic year. I agree to repay Dickinson College according to the following plan: I. Interest Interest shall accrue from the first of the month following the month in which I graduate or cease to matriculate at Dickinson College, end shall be at the ANNUAL PERCENTAGE RATE OF 6 percent interest on the unpaid balance. Interest will accrue on a daily basis. II. Repayment I promise to repay the principal and the interest which accrues on it over a period beginning six months after the date I graduate or cease to matriculate at Dickinson College. I will repay in equal monthly installments with a minimum monthly payment of $30.00 (which includes both principal and interest), and a maximum repayment period of five years (60 months). I realize that the College is under no obligation to grant deferments during the course of the repayment period. III. Default If I fail to make a scheduled repayment of any installment, the entire unpaid indebtedness including interest due and accrued thereon, plus any applicable penalty charge, will, at the option of Dickinson College, become immediately due and payable. I understand that if I default on my loan repayments that Dickinson College may disclose that I have defaulted, along with other relevant information, to credit bureau organizations. IV. Penalty Charge If I fail to make timely payment of all or any part of a scheduled installment, I promise to pay the charge assessed against me by Dickinson College. No charge may exceed $1.00 for the first month or part of a month by which the installment is late, and $2.00 for each month or part of a month thereafter. I promise to pay all attorney's fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. Signature N Social Security Number Date DICKINSON COLLEGE CARLISLE, PENNSYLVANIA 17013 Date: September 6, 1993 I hereby acknowledge receipt from DICKINSON COLLEGE of a loan in the amount of Seventeen hundred dollars ($1,700.00), which is hereby applied on my College account for the Fall semester of the 1993-94 academic year. I agree to repay Dickinson College according to the following plan: I. Interest Interest shall accrue from the first of the month following the month in which I graduate or cease to matriculate at Dickinson College, and shall be at the ANNUALPERCENTAGE RATE OF 6 percent interest on the unpaid balance. Interest will accrue on a daily basis. II. Repayment I promise to repay the principal and the interest which accrues on it over a period beginning six months after the date I graduate or cease to matriculate at Dickinson College. I will repay in equal monthly installments with a minimum monthly payment of $30.00 (which includes both principal and interest), and a maximum repayment period of five years (60 months). I realize that the College is under no obligation to grant deferments during the course of the repayment period. III. Default If I fail to make a scheduled repayment of any installment, the entire unpaid indebtedness including interest due and accrued thereon, plua any applicable penalty charge, will, at the option of Dickinson College, become im~nediately due and 9ayable. I understand that if I default on my loan repayments that Dickinson College may disclose that I have defaulted, along with other relevant information, to credit bureau organizations. IV. Penalty Charge If I fail to make timely payment of all or any part of a scheduled installment, I promise to pay the charge asaessed against me by Dickinson college. No charge may exceed $1.00 for the first month or part of a month by which the installment is late, and $2.00 for each month or part of a month thereafter. I promise to pay all attorney's fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. Signe ure Date EXHIBIT "I" AUG-!9-03 TUE 0i:54 PM TRUTH--IN-LENDING STATEMENT DICKINSON COLLEGE INSTITUTIONAL LOAN PAGE Name of Borrower Address Olga N. Filippova Lomonossvkiy St. 18-290 117296 Moscow ~YNUAL PERCENTAGE RATE The cost of your credit as a yearly rate. AMOUNT FINANCED The amount of credit provided to you. Prior ~0 During repayment repayment 0 6 % % $ 1,300.00 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 =his loan is payable monthly, $3.00 for each late payment if this loan is payable bimonthly, $6.00 for each late payment if this loan is pa~abl~ quarterly. Prepayment: If you pay off early, you will no_~t have to pay a penalty. See your promissory note for any additional information abou: nonpayment, de- fault~ any required repayment in full before the scheduled da~e, and pre- payment. THE BORROWER AC1LNOWLEDGES kSCEIPT OF AN EXACT COPY OF THIS STATEMENT. STUDENT z~/~ -,~/~. ;. INSTITUTIONAL EXHIBIT "J" DICKINSON COLLEGE CARLISLE, PENNSYLVANIA 17013 Date: January 26, 1994 I hereby acknowledge receipt from DICKINSON COLLEGE of a loan in the a~ount of Thirteen-hundred dollars ($1,300.00), which is hereby applied on my College account for the Spring semester of the 1993-94 academic y~a~. ~ agree to repay Dickinson College according to the following plan: Interest Interest shall accrue from the first of the month following the m~nth in which I graduate or cease to matriculate at Dickinson ~ollege, and shall be at the ANNUAL PERCeNTAgE RATE OF 6 percent interest on th~ unpaid balance. ~nterest will accrue on a daily basis. II. Repayment I p~omi~e to repay the principal and th~ interest which accrues on it over a ~eriod beginning six month~ after the dat~ ~ graduate or cease to matriculate at Dickinson College. I will repay in equal monthly ins%aliments with a minimum monthly payment ~f $30.00 (which includes both principal and inter~st), and a maximum repayment period of five years (60 months). I realize that the College is under no obligation to ~rant deferments during the course of the repayment period. III. Default If I fail to make a scheduled repayment of any installment, the entire unpaid indebtedness including interest due and accrued thereon, plus any applicable penalty charqe, will, at the option of Dickinson College, become immediately due and payable. I understand that if I default on my loan repayments that Dickinson College may disclose that I have defaulted, along with other relevant information, to ¢~edit bureau organization~. IV. Penalty Charg~ ~f I fail =o make timely paymen= of all or any part of a scheduled installment, I promise to pay the charge assessed against me by Dickinson College. NO charge may e~ceed $1.00 for the first month or part of a month by which the installment is late, and $2.00 fer each month or part of a month thereafter. I promise to pay all attorney's ~ees and other reasonable collection costs and charges necessary for the collection of any amount net paid when due. 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. § 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. Dated: Dickinson College Thomas Meyer Assistant Treasurer of Dickinson College CERTIFICATE OF SERVICE I, Martha-Anne Iben, an authorized agent of Mmtson 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, PA, Certified Mail, Restricted Delivery, postage prepaid, addressed as follows: Olga N. Filippova 224 East 1 lth Street Apt. 24 New York, NY 10003 MARTSON DEARDORFF WILLIAMS & OTTO Martha-Anne lben Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: August 26, 2003