HomeMy WebLinkAbout03-5080F:\FILES\DATAFILE\Dlckinson Collcge 7619\Dickinso CollegeCollcctiore761901 cumenus 214-coml. wpd\mai
Created. 4128/03 1'.5403 PM
Revised: 9831033: 45 41 PM
7619C.214
DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 03- S-'a 8 8
CIVIL ACTION-LAW
JIN G. 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, Pennsylvania 17013
Telephone (717) 249-3166
MARTSON
David R. Galloway
I.D. Number 87326
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
WILLIAMS & OTTO
Date: September 24, 2003
DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 03- So q c>
: CIVIL ACTION-LAW
JIN G. LEE
Defendant : JURY TRIAL OF TWELVE DEMANDED
COMPLAINT
AND NOW, comes Plaintiff Dickinson College by and through its attorneys, MARTSON
DEARDORFF WILLIAMS & OTTO, and hereby avers as follows:
1. Plaintiff Dickinson College is a Pennsylvania educational institution and nonprofit
corporation with its principle place of business at West Street, Post Office Box 1773, Carlisle,
Cumberland County, Pennsylvania 17013.
2. Defendant Jin G. Lee is an adult individual with a last known address of 110 Sheldon
Avenue, Tarrytown, New York, 10591.
3. On or about November 12, 1987, Defendant entered into a Promissory Note - Federal
Perkins Loan Program (Note # 1) with Plaintiff for the financing of $2,000.00, plus interest and costs
by Defendant on his own behalf, for educational services and benefits at Plaintiff's institution. A
copy of Note #1 is attached hereto as Exhibit "A."
4. On or about December 8, 1988, Defendant entered into an additional Promissory
Note- Federal Perkins Loan Program (Note #2) with Plaintiff for the financing of $2,000.00, plus
interest and costs by Defendant on his own behalf, for educational services and benefits at Plaintiff's
institution. 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 of 1965 as amended, (hereinafter the "Act") and are subject 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 41 and Note #2 is $4,000.00.
8. Note #1 and Note #2 grant Plaintiff reasonable collection and attorney's fees which
Plaintiff has calculated to be $600.00.
9. As of July 18, 2003, the principal and interest due and payable by Defendant to
Plaintiff was $4,283.59, plus interest accruing thereafter at $.49 per day.
10. As of July 18, 2003, the outstanding balance of $4,283.59 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. Plaintiff has fulfilled, performed and complied with all obligations and conditions of
Note #I and Note #2.
COUNTI
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 $4,283.59,
plus interest accruing at $.49 per day from July 18, 2003, collection and attorneys' fees in the
amount of $600.00 and costs of suit.
COUNT II
IN OUANTUMMERUIT
14. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 13 of this 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 18, 2003, the total amount by which Defendant has become enriched is
$4,283.59, plus interest in the amount of $.49 per day from July 18, 2003.
WHEREFORE, Plaintiff demands judgment against Defendant Jin G. Lee in the amount of
$4,283.59, plus interest in the amount of $.49 per day from my 18, 2003, collection and attorneys'
fees in the amount of $600.00, and costs of suit.
MARTSON DE F WILLIAMS & OTTO
By
David R. Galloway
I.D. Number 87326
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Date: September 24, 2003 Attorneys for Plaintiff
DICKINSON COLLEGE
CARLISLE, PENNSYLVANIA 17013
PROMISSORY NOTE
PERKINS LOAN PROGRAM
1, Jin G. Lee promise to pay to
Dickinson College (herein after called the Lending Institution) located at Carlisle, Pennsylvania the sum of the amounts that are advanced to
me and endorsed I. the Schedule of Advances set forth below. I promise to pay all attorney's fees and other reasonable collecting costs and
charges necessary for the collection of any amount not paid when due.
I further understand and agree that:
1. GENERAL
(1) Aoolicable Low. All sums advanced under this note are drawn from a fund created under Part E of Title TV of the Higher Education Ace of 1%5, u
amended, heminafter called the Act, and are subject to the Am and the Federal Regulations issued under the Act. The seems of this note shall be inter-
preted in amodan" with the Act and Federal Regulations, copies of which are to be kept by the lending Institution.
(2) Procedures for Reteivine Deferment or Cancellation. I understand that in order to mcelve a defemsent or cancellation. I most request the deferment or
cancellation in writing from the lending Institution, and most submit to the Lending Institution any documentation required by the lending Institution to
prow that 1 qualify for the deferment or cancellation. I further understand that if 1 am eligible for deferment or cancellation under Articles VI through XI, 1
am responsible for submitting the appropriate requests on time. I further understand that 1 may lose my deferment and cancellation benefits if 1 fail to file
my request ore time.
IT. INTEREST
Interest shall accrue from the beginning of the repayment period and shall be at the ANNUAL PERCENTAGE RAT? OF FIVE PERCENT (5%) on
the unpaid balance, except that no interest shall accrue during any deferment period described in paragraph Vill).
AT. REPAYMENT
(1) 1 promise to repay the principal and the interest which acrves on it to the lending Institution over a period beginning 9 months after the date I muse to
be at least a half-time student at an institution of higher education, or at a comparable institution outide the United States approved for this purpose by the
United States Secretary of Eduction (hercinaAer called the Secretary), and ending, unim paragraphs IHf4), III(5), III(7), or VI(I) applies, 10 years later.
(2) Upon my written request, the repayment period may star on a dale earlier than the one indicated in paragraph 111(1).
(3)(A) I promise to repay, the principal and interest over the mum 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 we by the Lending Institution u not a multiple of S5,
the Lending Institution may round that payment to the nest highest dollar amount that is a multiple of $5.
(B) Notwithstanding paragraph I1I(3)(A), upon my whom request, repayment may be made in graduated installmealse in accordance with a schedule ap-
proved by the Secretary.
(C) The Lending institution shall attach the schedule of repayments and the schedule will become gin of the note.
(s) Notwithstanding paragraph III(1), if I qualify as a low.income individual during the repayment period, the Lending Institution may, upon my written M.
quest, emend the repayment period for up to an additional 10 years, or adjust any repayment schedule to reflect my income, or both.
(5)(A) If the monthly rate that would be established under paragraph Hill), far the total monthly repayment rate of principal and interest on all my Perkins
Irons including this ban, is lees than $30 per month, I shall repay the principal and interest on this loan at the rate of $30 per month (which includes both
principal and interest).
(5)(11) If I have receivN Perkins loans from other institutions and the total monthly mpsyment rate on those loam is leis than SM, the S30 monthly core ca.
Oli ished under subparagraph 111(5)(A) is the note I pay on all my outstanding Perkins Loans and is not in addition to the amount 1 Pry on Ihose other ]mm.
The amount of my monthly repayment rate attributable to this loan is the amount which represents the difference between SM and the monthly riles I mean
pay on my other Perkim Loans.
(6) The Tending Institution may peNhit me to pay has than the cote of SM per month for a period of not more than one year where necessary to amid
hardship to me unless that action would emend the repayment period in paregraph HIG).
(7) The Lending Institution may, upon my written requmt, reduce any scheduled repayments or elected the repayment period indicated in paragraph 111(1),
if, in its opinion, utnordbary, circumstances such as prolonged illness or unemployment, prevent me from making the scheduled repayments. However, io-
te rmt shall continue to scenic.
TV. PREPAYMENT
(1) 1 may, at my option add without penalty, prepay all or any part of the principal, plus the accrued interest thereon, at any time.
(2) Amount 1 repay in the academic year in which the loan was made will be used ro reduce the amount of the two and will not he millisecond a prepayment.
(3) If I repay mom than the amount due for any installment, the excw will be used to prepay principal unusual I designate it as an advance payment of the
and regular installment.
V. DEFAULT
(1) The Lending Institution may, at it option, declam my loan to be in default and may demand immediate payment of the entire unpaid balance of the
ban, including principal, )atemsq and late charges if
(A) I do Out make a sehduled payment when it is due, and
(B) 1 do nine submit to the Lending Institution on or before the date on which payment is due, documentation that I qualify for a deferment or cancellation
described in Micles VI, VII, VIII, IX<X, or X1 of this agreement.
(2) 1 understand that if I default on my loan repayments, the Lending Institution may disclose that i haw defaulted, along with other relevant information, to
credit bureau orpnbariom.
(3) Further, I understand that if I default on my loan repayment and the loan is sent to the Secretary for collection, the Secretary may disclose that I have
defaulted, along with other relevant information, to credit bureau organtations.
(a) I understand that if the Lending Institution accelerates the loan under paragraph V(1), I will lase my cancellation and deferment benefits for service par-
formed after the 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 fsnuaial aid ovehorircd under
Title IV of the Higher Education Ad of 1%5, as amended, until I have made arrangement which are satisfactory to the lending Institution or the Secretary
regarding the repayment of the loan.
VI. DEFERMENT
(1) interest will mot Rescue, and installment of principal need not be paid -
(A) While I am enrolled and in attention" as at least half-time student at an inatituti"r of higher education or at a comparable institution outide the
United States approved for this purpose by the Secmary,
(B) For a period of three (3) year during which 1 am -
(i) On full-lime active duty as a member of the Armed Forms of the United States (Army, Navy, Air Force, Marine Corp, or Coast Guard) or tea Na-
tional Oceade and Atmospheric Administration Corps, or a i m officer on full-time active duty in the Commissioned Corps of the United States Public
Health Service,
(A) /n services u a volunteer under the Peace Corps Act,
(iii) Avolunteer under the Domestic Volunteer Service Act of 1973 (ACTION programs),
(w) A full-lime miunt"r in re txtcmmpt organication performing service comparable to the service performed in the Peace Corps or under the Doci
Ile Volunteer Service Act of 1973, or
(v) Temporarily totally disabled as established by an affidavit of a qualified physician, or unable to secure employment because I am providing care in-
quired by a dependent who is so disabled;
(C) For a period not in esceu of two (2) years after I receive a baccmawrste or professioeal degee door, which time i am serving in can internship which
is required in order that I may receive profcuional racognition required to begin my professional practice or service, or serving in on internship or residency
program leading to a degree or certificate awarded by an institution of higher education, a hospital ora health more facility that offers postgraduate training;
(D) For a period not in a eas of one (1) year during which 1 as a mother of preschool age children, who has entered or reentered the work force, am
being paid at a nee which does not exceed SLW above the minimum hourly wage established by section 6 of the Fair Labor Standards Act of 1938;
(E) For a period not in excess of six months if.
(i) I am pregnant, "ring for my newbom baby, or caring for a child immediately after he or she was placed with me through adoption and 1 am not at-
tending an eligible institution of higher education or being gainfully employed during the au month period, and
(it) I was enrolled as at least a half-time student at an eligible institution within six months of the Ant city of that period; and
(F) During a site (6) month period following the eapi"tion of any deferment provided in paragraphs VI(I)(A) through VI(1)(E).
(2) The Lending Instinsucen may, upon my written request, defer my scheduled repayment if it determines that the deferment is necesi to avoid a fdem-
dal hardship for me. Interco,, however, will combus to accrue
VII. CANCELLATION FOR TEACHING
(1) I am entitled to have up m 100 percent of the amount of this loan plus the interest thereon cancelled if I undertake "rise -
(A) As a full-time teacher for a complete academic year in a public or other nonprofit elementary, or secondary uhool which is in the school distinct of a
local educational agency which is eligible in such year of service for funds under Chapter I of the Education Consolidation and Improvement Aar of 1%l, as
amended, and which his been designated by the Secretary (after consultation with each State Department of Education) in accordance with the powl m., of
section 46.5(ax2) of the Act as a school with a high concentration of students from low-income families. An official Directory of dOupoted low-income
schools is published annually by the Secretary,
(B) As a full-time teacher of handicapped children (including mentally reladed, had of hearing, deaf, speech and language impaired, visually hand-
icapped, seriously emotionally disturbed, orthopadicaly impaired, children with specific ]taming disabilities, or other health-impaired children, who by reason
EXHIBIT "A"
___...e'--+ ...........
r......... wsuwu m pnragrapn vt(1).
(I) i promise ro repay the principal and the interest which accrues on it to he Lending Institution over a
period beginning 9 months alter the date 1 cease to
be at least a half-time student at an institution of higher education, or at a comparable 10 years later.
institution outside the United States a
United States Secretary of Education (hereinafter called the Secretary), and ending, unless paragraphs fide t 11 Unit III PProved for this purpose by the
graph (2) Upon my written request, there
payment rind may start on a date earlier than the one indicated in Pa ra (? or V1(1) applies, Ph I
(3)(A) I promise to repay the principal and interest over the nurse 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,
the Lending Institution may round that payment to the next highest dollar amount that is a multiple of S5.
(B) Notwithstanding paragraph III(3)(A), upon my written request, repayment may be made in graduated installments in accordance with a schedule ap.
proved by the Secretary.
(C) The Lending Institution shall attach the schedule of repayments and the schedule will become part of the note.
(4) Notwithstanding paragraph 111(1), if I qualify as a low-income individual during the repayment period, the Lending Institution may, upon my written re-
quest, extend the repayment period for up to an additional 10 years, or adjust any repayment schedule to reflect my income, or both.
(5)(A) If the monthly rate that would be established under paragraph 111(1), or the total monthly repayment rate of principal and interest on all my Perkins
Loans including this loan, is less than $30 per month, I shall repay the principal and interest on this loan at the rate of S30 per month (which includes both
principal and interest).
(5)(B) If I have received Perkins Loans from other institutions and the total monthly repayment rate on those loans is less than $30, the S30 monthly rate es-
tablished under subparagraph 11I(5)(A) is the rate I pay on all my outstanding Perkins Loans and is not in addition to the amount I pay on those other loans.
The amount of my monthly repayment rate attributable to this loan is the amount which represents the difference between $30 and the monthly rates I must
pay on my other Perkins Loans.
(6) The Lending Institution may permit me to pay less than the rate of S30 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 ra
if, in its opinion, extraordinary circumstances such as prolonged illness or unemployment, prevent me from making the scheduled re. shall continue to accrue. Pa graph III(I) ,
paymentsHowever, in:
(1) 1 may, at my option and without penal IV. PREPAYMENT
(2) Amounts I repay in the academic yearn
ty, which the loan was adetwillPbe u d tot reduce the amount oftthe loan ands lltnot be considered a re
(3) If I repay more than the amount due for any installment, the excess will be used to prepay principal unless 1 designate it as an advance next regular installment. P payment. ccrued thereon, at y me.
payment of the
(1) The Lending Institution may, at its option, declare my loan to be in default and may demand immediate
ban, including principal, interest, and late charges if - payment of the entire unpaid balance of the
(A) I do not make a scheduled payment when it is due, and
(B) I do no submit to the 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) 1 understand that if 1 default on my loan repayments, the Lending Institution may disclose that 1 have defaulted, along with other relevant information, to
credit bureau organizations.
(3) Further, f understand that if 1 default on my loan repayment and the loan is sent to the Secretary for collection, the Secretary may disclose that I have
defaulted, along with other relevant information, to credit bureau organizations.
(4) 1 understand that if the Lending Institution accelerate the loan under paragraph V(I), I will lose thy cancellation and deferment benefits for service per-
formed after the date the Lending Institution accelerated the loan.
(5) 1 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, a amended, until I have made arrangements which arc satisfactory to the Lending Institution or the Secretary
regarding the repayment of the loan.
(1) Interest will not accrue, and installments of principal need not be paid DEFERMENT
(A) While I am enrolled and in attendance as at least half-time student at an institution of higher education or at a comparable institution outside the
United States approved for this purpose by the Secretary
(B) For a period of three (3) years during which I am -
(i) On full-time active duty as a member of the Armed Forces of the United States (Army, Navy, Air Force, Marine Corps, Coast Guard) the Na.
burial Oceanic and Atmospheric Administration Corps, or as an officer on full-time active duty in the Commissioned Co
tio
Health nal Service,
(ii) In service as a volunteer under the Peace Corps Star" Act,
(iii) A volunteer under the Domestic Volunteer Service Act of 1973 (ACTION programs),
(iv) A full-time volunteer in a tax-exempt organization performing service comparable to the service performed in the Peace Corps tic Volunteer Service Act of 1973, or
(v) Temporarily totally disabled as established by an affidavit of a qualified or under the Domes-
quired by a dependent who is so disabled; physician, or unable to secure employment because I am providing care rc-
(C) For a period not in excess of two (2) years after 1 receive a baccalaureate or Drofessional degree during which time 1 am serving in an internship which
is required in order that I may receive professional recognition required to begin my professional practice or service, or serving in an internship or residency
program leading to a degree or certificate awarded by an institution of higher education, a hospital or a healthcare facility that offers t&
(D) For a period not in excess of one (1) year during which I as a mother of preschool age children, who has entered or reentered the work force, am
being paid at a rate which does not exceed $1.00 above the minimum hourly wage established by section 6 of the Fair Labor Standards postgraduate training
(E) For a period not in excess of six months if -
(i) I am pregnant, caring for my newborn baby, or caring for a child immediately after he or she was placed with me throw
tending an eligible institution of higher education or being gainfully employed during the six month period, and
(ii) I was enrolled as at least a half-time student at an eligible institution within six months of the first day of that period; ands adoption and I am not at.
During a six (6) month period following the expiration of any deferment provided in paragraphs VI(1)(A) through VI(1)(E).
(2) The Lending Institution may, upon my written request, defer my scheduled repayments if it determines that the deferment is necessa
cial hardship for me. Interest, however, will continue to accrue
finan-
ry to avoid a (1) 1 am entitled to have up to 100 percent of the amount tlof this loan pl1•us the intereFOR st tthercon cancelled if I undertake service -
(A) As a full-time teacher for a complete academic year 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 for funds under Chapter I of the Education Consolidation and Improvement Act of 1981, as
amended, and which has been designated by the Secretary (after consultation with each State Department of Education) in accordance with the rovisio section 465(a)(2) of the Act as a school with a high concentration of students from low-i
schools is published annually by the Secretary. ncome families. An official Directory of designated low-income -time
teacher icapped, seriously emotionally d sturb d, orthoed children pedically imrpaired, mentally relarded hard of
spec fie learning hearing, deaf, sech
gu ge impaired, visually hand-
or o her heath-impaired children, who by
rcason
thereof require special education and related services) In a public or other noopie fit elementary or secondary school system.
(2) This loan will be cancelled at the following mtes:
(A) 15 percent of the total principal amount of the loan plus interest on the unpaid balance will be cancelled for the first and second complete academic
years of that leaching 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,
(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) 1 am entitled to haw up to 100 percent of the amount of this loan plus the interest themon cancelled if I undertake sem" as a full-time staff member in
a Head Start program if -
(A) That Had Start program is operated for a period which is comparable to a full school year in the locality, and
(B) My salary is not more than the salary of a comparable employee of the local educational agency.
(2) This Into will be cancelled at the mte of 15 percent of the total principal amount films 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 preschool program carried out under the Head Stan Act. (Subchapter B. Chapter 8 of Title VI of Pub. L 97-35, the Budget Reconcilia-
tion Act of 1981; formerly authorized under section 222(a)(1) of the Economic Opportunity Ast of 1951).
IX. MILITARY CANCELLATION
(I) 1 am entitled to have up to 50 percent of the principal amount of this loan plus the interest thereon cancelled if 1 serve as a member of the Armed Forces
of the United States in an area of hostilities that qualifies for special pay under section 310 of Title 37 of the United States Code.
(2) This Ian will be cancelled at the rate of 12 12 percent of the total principal amount pier interest on the unpaid balance for each complete year of such
service.
X. PEACE CORPS CANCELLATION
(1) 1 am entitled to have up to 70 percent of the amount of this loan plus the interest themon cancelled if I undertake samce--
(A) As a volunteer under the Peace Cc" Act; or
(B) As a volunteer under the Domestic Volunteer Service Ace of 1973.
(2) This learn will be cancelled at the following rata:
(A) 15 percent of the total principal amount of the loan plus interest on the unpaid balance will be cancelled for the first and second melw-month period
of wlunreer service;
(B) M percent of the tout principal amount of the loan plus interest on the unpaid balance will b. cancelled for the third and fourth o elm-math period
ofwlunteer service.
XI. DEATH AND DISA131UTY CANCELLATION
(1) In the went of any death, the total amount it on this loam will M Uncalled.
(2) If I become totally and permanently disabled titer 1 marine this loan, the Lending Institution will cancel the oral amount of this lan.
XIL CHANGE IN NAME. ADDRESS, TELEPHONE NUMBER AND SOCIAL SECURITY NUMBER
1 am responsible, and any endorser is responsible, for informing the Lending Institution of 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
(B) I do not submit to the Lending Institution oa or before the ate on which payment is due, documentation that I quality for a deferment or cancellation
described in Articles VI, VII, VIII, IX, *and XT of.lhis agreement.
(2) No charge may exceed twenty (20) percent of my monthly, bimoathly or quarterly payment.
(3)(A) The fending Institution may-
(i) Add the lam charge to the principal the day after the scheduled repayment was due; or
(it) Include it with the neat scheduled repayment after 1 have teceivad notice of the late charge.
(B) If the Tending Institution elects to add the assessed charge to the outstanding principal of the loan, it most so inform me before the due date of the
near installment.
XIV. ASSIGNMENT
(1) This nom may be assigned by the Leading Institution only to -
(A) The United States;
(B) Another institution upon my transfer to that institution if that institution is participating in this program; or
(C) Another institution approved by the Secretary.
(2) The provision of this note that relate to the Lending Institution shall, when appropriate, relate to an assignee.
XV. PRIOR LOANS
I hereby certify that I Mw listed below ell of the Perldm Luaus I Mini Obtained at over institutions. (If no prior lam haw been rewh<d, state -None.')
SCHEDULE OF PERKINS LOANS AT OTHER INSTITUTIONS
AMOUNT DATE NAME OF INSTITUTION
XVI. SCHEDULE OF ADVANCES
The following amounts wave advanced to me under this loan agreement on the data indicated:
AMOUNT DATE SIGNATURE OF BORROWER
1. $1,000 7187
2. $1.000 12/87
3.
NOTICE TO BORROWER DO NOT SIGN THIS NOTE BEFORE YOU READ IT. THE LENDING INSTITUTION MUST SUPPLY TO
YOU AND ANY ENDORSER ACO Ol IS NOTE. (This note is signed "a soled inatrument.) ?/
SIGNATURE ¢U-1 `??")'/??, 1A?y Data ,r ??J/, ?.? ?/ r159r?
Permanent Address t or Bear Number, City, State, and Zip) /to ..>-4 I?V'?,v 71 NT xjn / ` ky. / c+.j /c?(
Social Security Number (burrower must provide) 545^'1-1 -[q 1 G? , ?? Ilrll 1
The burrower and Leading Institution shall ezpmu this nom without security sad without endomement unless the borrower is a minor and this note would
not, under the law of the Sure in which the Lending Institution is located, create a binding obligation. If the borrower is a minor and this note would not
therefore, be legally binding, the Lending institution shall mquim a cosigner to this note:
SIGNATURE OF COSIGNER
Data 19
Permanent Address (Street or Bret Number, City, State, Zip)
(2O U.S.C. 1087dd) Format by the National Association of Student Financial Aid Administrators.
(7/87)
semce.
X PF,ACE COPPS CANCELLATION
(0 1 am entitleu to have up to 70 percent of the amount of this loan plus the interest thereon cancelled if I undertake 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 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;
(B) 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.
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
1 am responsible, and any endorser is responsible, for informing the Lending Institution of 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
(B) 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
described in Articles VI, VII, VIII, IX, `4 and XI of this agreement.
(2) No charge may emceed 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 nest 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 of the loan, it must so inform me before the due date of the
next installment.
XIV. ASSIGNMENT
(1) This note may be assigned by the Lending Instifution only to -
(A) The United States;
(B) Another institution upon my transfer to that institution if that institution is participating in this program; or
(C) Another institution approved by the Secretary.
(2) The provisions of this note that relate to the Lending Institution shall, where appropriate, relate to an assignee.
XV. PRIOR LOANS
I hereby certify that 1 have listed below all of the Perkins Loans 1 have obtained at other institutions. (If no prior loans have been received, state "None.")
SCHEDULE OF PERKINS LOANS AT OTHER INSTITUTIONS
AMOUNT
I.
2.
3.
4.
DATE
NAME OF INSTITUTION
XVI. SCHEDULE OF ADVANCES
The following amounts were advanced to me under this loan agreement on the dates indicated:
AMOUNT DATE SIGNATURE OF BORROWER
1. $1.000 7/87
1 $1,000 12/87
3.
NOTICE TO BORROWER DO NOT SIGN THIS NOTE BEFORE YOU READ rT. THE LENDING INSTITUTION MUST SUPPLY TO
YOU AND ANY ENDORSER ACOP OF "IS NOTE. (This note is signed m a sealed instrument.) /r y.y
SIGNATURE `???,/ ?y,?1v ) `1,t y Date ?/ O / 19
Permanent Address k (Ikeet or Box Number, City, State, and Zip) 1/0 „347?I/t W /1:67'
Social Security Number (borrower must provide) 5 s ..--I c? -061r, . t
The borrower and Lending Institution shall execute this note without security and without endorsement unless the borrower is a minor and this note would
not, under the law of the State in which the Lending Institution is located, create a binding obligation. If the borrower is a minor and this note would not
therefore, be legally binding, the Lending Institution shall require a cosigner to this note:
SIGNATURE OF COSIGNER
Permanent Address (Street or Boa Number, City, State, Zip)
Dare
19
(20 U.S.C. 1087dd) Format by the National Association of Student Financial Aid Administrators.
(7/87)
t.AKI_ISLLr I-LilliJTLVA1111A IVUIJ
PROMISSORY NOTE - PERKINS LOAN PROGRAM
Any bracketed clause or paragraph maybe included at option of institution.)
Jin G. Lee promise to pay to. Dickinson Collpge (hereinafter
ailed the Lending Institution) located at Carl i sl P t PPnn syI Van1 A the sum of the amounts that are advanced to me and an-
orsed in the Schedule of Advances set forth below. I promise. to pay all attorney's fees and other reasonable collection costs and charges necessary for the
ollection of any amount not paid when due. I further understanb and agree that.
1. GENERAL
1) Apol'cable Law All sums advanced under this note are drawn from a fund created under Part E of Title IV of the Higher Education Act of 1965, as
mended, 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
ccordance with the Act and Federal Regulations, copies of which are to be kept by the Lending Institution.
2) Procedures for Receivine Deferment 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
qualify for the deferment or cancellation. I further understand that if I am eligible for deferment or cancellation under Articles VI through XI, I am responsible
3r submitting the appropriate requests on time. I further understand that 1 may lose my deferment and cancellation benefits if I fail to file my request on time.
II. INTEREST
Merest shall accrue from the beginning of the repayment period and shall be at the ANNUAL PERCENTAGE RATE OF FIVE PERCENT (59(,) on the unpaid
glance, except that no interest shall accrue during any deferment period described in paragraph VI(I).
III. REPAYMENT
1) 1 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
t least a half-time student at an institution of higher education, or at a comparable institution outside the United Slates approved for this purpose by the
Inited States Secretary of Education (hereinafte( called the Secretary), and ending 10 years later, unless that period is shortened under paragraph Will), or ex.
ended under paragraphs IIIN), lit(7) (extensions), or Vill) (deferments).
2) Upon my written request, the repayment period may start on a date earlier 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-
lined 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, the
ending Institution may round that payment to the next highest dollar amount that is a multiple of $5.
(S) Notwithstanding paragraph lll(3)(A), upon my written request, repayment may be made in graduated installments in accordance with a schedule
pproved by the Secretary.
(C) The Lending Institution shall attach the schedule of repayments and the schedule will become part of the note.
4) Notwithstanding paragraph III(1), if I qualify as a low-income individual during the repayment period, the Lending Institution, upon my written request, may
xtend the repayment period for up to an additional 10 years, and may adjust any repayment schedule to reflect my income.
(5)(A) If the monthly rate that would be established under paragraph 111(1), ar the total monthly repayment rate of principal and interest on all my Perkins
pans including this loan, is less than $30 per month. I shell repay the principal and interest on this loan at the rate of $30 per month (which includes both prin-
ipal and interest).
5) (S) If I have received Perkins Loans from other institutions and the total monthly repayment rate on those loans is less than $30, the $30 monthly payment
stablished under subparagraph III(5)(A) includes the amounts I owe on all my outstanding Perkins Loans including those received from other Institutions. The
mount 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 on
ny other Perkins Loans.
5) The Lending Institution may permit me to?pay less than the rate of $30 per month for a period of not more than one year where necessary to avoid
ardship to me unless that action would extend the repayment period in paragraph III(1).I
7) The Lending Institution may, upon my written request, reduce any scheduled repayments or extend the repayment period indicated in paragraph III(1), iq
t its opinion, extraordinary circumstances such as prolonged illness or unemployment, prevent me from making the scheduled repayments. However, inter-
at shall continue to accrue.
IV. PREPAYMENT
1) 1 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 the loan was made will be used to reduce the amount of the loan and will not be considered a prepayment.
3) 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
,exl regular installment.
V. DEFAULT
1) The Lending 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,
lcluding 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
(S) 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
fescribed in Articles VI, VII, VIII, IX, X, or XI of this agreement.
2) 1 understand that if I default on my loan, the Lending Institution may disclose that I have defaulted, along with other relevant information, to credit bureau
uganizations.
3) Further, I understand that if I default on my loan and the loan is transferred to the Secretary for collection, the Secretary may disclose that I have defaulted,
long with other relevant Information, to credit bureau organizations.
4) 1 understand that after the Lending Institution accelerates the loan under paragraph V(1), I will then lose my right to defer repayments due after the date
he Lending Institution accelerates the loan.
5) 1 understand that after the Lending Institution accelerates the ;can under paragraph V(1), I will then lose my right to receive a cancellation of a portion of
ny loan for any teaching, volunteer or military service described in Articles VII, VIII and IX, performed after the date the Lending institution accelerated the loan.
6) 1 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 l have made arrangements which are satisfactory to the Lending Institution Or the Secretary
egarding the repayment of the loan.
VI. DEFERMENT
1) 1 understand that upon making a properly documented written request to the lending Institution, I may defer making scheduled installment payments, and
viii 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 outside the
Jnited States approved for this purpose by the Secretary;
(S) For a period of three (3) years during which I am -
(i) On full-time active duty as a member of the Armed Forces of the United States (Army, Navy, Air Force, Marine Corps, or Coast Guard) or the
Jetional Oceanic and Atmospheric Administration Corps, or as an officer on lull-time active duty in the Commissioned Corps of the United States Public
lealth Service,
(it) In service as a volunteer under the Peace Corps Act,
(iii) Avolunteer under the Domestic Volunteer Service Act of 1973 (ACTION programs),
(iv) A full-time volunteer in a tax-exempt organization performing service comparable to the service performed in the Peace Corps or under the
Jameslic Volunteer Service Act of 1973, or
(v) Temporarily totally disabled as established by an affidavit of a qualified physician, or unable to secure employment because I am providing care
squired by a dependent who Is so disabled;
(C) For a period not in excess of two (2) years -
(1) After I receive a baccalaureate or professional degree during which time I am serving in an internship which is required in order that I may receive
xofessional recognition required to begin my professional practice of service, or
(ii) serving in an internship or residency program leading to a degree or certificate awarded by an institution of higher education, a hospital or a health
;are facility that offers postgraduate training;
fD) 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
3eing paid at a rate which does not exceed $1.00 above the minimum hourly wage established by section 6 of the Fair Labor Standards Act of 1938;
(E) 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 half-time student at an eligible institution; and (it) During
xhich 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 of higher education nor gainfully employed; and
(F) During a six (6) month period immediately following the expiration of any deferment provided in paragraphs Vill) (A) through Vill)(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) 1 understand that upon making a property 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 cancelled if I perform service -
EXHIBIT "B"
(A) As a full-time teacher in a public or other nonprofit elementary of secondary school which is in the school district of a local educational agency
which Is ell jible in such year of service for funds under Chapter I of the Education Consolidation and Improvement Act of 1981, as amended, and which has
been designated by the Secretary (after consultation with each State Department of Education) in accordance with the provisions of section 465(a)(2) of the
Act as a school with a high concentration of students from low-income families. An official Directory of designated low-income schools is published annually
by the Secretary.
(8) As a full-lime teacher of handicapped children Including those who are mentally retarded, hard of hearing, deaf, speech and language impaired,
visually handicapped, seriously emotionally disturbed, orthopedically impaired, have specific learning disabilities, or otherwise health-impaired children, who
by reason thereof require special education and related services) in a public or other nonprofit elementary or secondary school system.
(2) This loan will be cancelled for each completed year of teaching service at the following rates:
(A) 15 percent of the total principal amount of the loan plus interest on the unpaid balance will be cancelled for the first 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,
and
(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) 1 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 cancelled it I perform service as a full-time staff member in a Head Start program if .
(A) That Head Start program is operated for a period which is comparable to a lull school year in the locality, and
(8) My salary is not more than the salary of a comparable employee of the local educational agency.
(2) This loan 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 Stan program.
(3) Head Start is a preschool program carried out under the Head Start Act.
IX. MILITARY CANCELLATION
(1) 1 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 for
special pay under section 310 of Title 37 of the United States Code.
(2) This loan will be cancelled at the rate of 12 112 percent of the total principal amount plus Interest on the unpaid balance for each complete year of such set.
vice.
X. PEACE CORPS CANCELLATION
(1) 1 understand that upon making a properly documented written request to the lending institution, I am entitled to have up to 70 percent of the amount of
this loan plus the interest thereon cancelled If I perform servica-
(A) As a volunteer under the Peace Corps Act; of
(8) As a volunteer under the Domestic Volunteer Barrios Alt of 1973.
(2) This loan will be cancelled at the following rates:
(A) 15 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,
(e) 20 percent of the total principal amount of the loan plus interest on the unpaid balance will be cancelled for the third and fourth twelvemonth
period of volunteer service completed.
XI. DEATH AND DISABILITY CANCELLATION
(1) in the event of my death, the total amourLowed 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-
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) 1 do not submit to the Lending Institution on or before the sate on which payment is due, documentation that I quality for a deferment or cancellation
ieschbed in Articles VI, VII, VIII, 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.
(B) If the Lending Institution elects to add the assessed charge to the outstanding principal of the loan, it must so Inform me before the due date of the next
istallment.
XIV. ASSIGNMENT
I) This notemaybeassignedbytheLendinglnstitutiononlyto -
(A) The United States;
(B) Another institution upon my transfer to that institution if that institution is participating in this program; or
(C) Another institution approved by the Secretary.
?) The provisions of this note that relate to the Lending institution shall, where appropriate, relate to an assignee.
XV. PRIOR LOANS
iereby 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 "Novi
SCHEDULE OF PERKINS LOANS AT OTHER INSTITUTIONS
AMOUNT DATE INSTITUTION
XVI. SCHEDULE OF ADVANCES
e following amounts were advanced to me under this loan agreement on the dates indicated:
AMOUNT DATE SIGNATUR OFi,BOR OWER
$1.000.00 7188 ?^- -
$1,000.00 12/88
TICE TO BORROWER: DO NOT SIGN THIS NOTE BEFORE YOU READ IT. THE LENDING INSTITUTION MUST SUPPLY A COPY OF THIS NOTE
YOU AND ANY COS}GNghis note is signed as a sealed instrument.]
nature /imp "f [(goal)] Date L 19
manent Address (Street or Box Number, City, State, and Zip Code), I 10 c l1(6 L of V yw,
:ial Security Number (borrower must provide) 7- Z-2 ri - I ( I,; (., 1 V '
borrower and Lending institution shall execute this note without security and without on unless the borrower is a minor and this note would not,
'er the law of the State in which the Lentling Institution is located, create a binding obligation. If the borrower is a minor and this note would not therefore,
egally binding, the Lending Institution shall require a cosigner to this note:
ree to repay all amounts tlue on this loan if the borrower fails to do so in accordance with the terms of the note.
lature OI Cosigner
_[(seat)] Date 19
nanent Address (Street or box Number, City, State, Zip Code)
J.S.C. 1087dd) Format by the National Association of Student Financial Aid Administrator, 5/88.
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.
Dickinson College
Thomas Meyer
Assistant Treasurer of Dickinson College
Dated:
F TILES DATAFILE\Dickinson College 7619\DickinsonCollegeCollections7619CNOocu ents1214.com1\had
CERTIFICATE OF SERVICE
I, Marti lben, an authorized agent ofMartson 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:
Jin G. Lee
110 Sheldon Avenue
Tarrytown, NJ 10591
MARTSON DEARDORFF WILLIAMS & OTTO
By?.? \\_?
Marti Then
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: September 24, 2003
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P\ PILE&DATAPILE\Dickineon College 7619\DickiuonCallegeCollections7619C\Cu ent@14. pre l/nlm
Created. 2/17/04 2.23PM
Revised. 2/17/04 3.25PM
76190 214
DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 03- S O ?'Q
CIVIL ACTION-LAW
JIN G. LEE
Defendant : JURY TRIAL OF TWELVE DEMANDED
PRAECIPE
Please reinstate the attached Complaint against Jin G. Lee, 5311 Lakemont SE, BV 1324,
Bellevue, WA 98006, in the above-captioned action and return same to the undersigned for
service.
& OTTO
David R. Gallowal;-
L D. Number 87326
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Date: February 17, 2004 Attorneys for Plaintiff
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P \EILES\DATA ILMckinson College 7619\Dicki sonCollc eCollections7619C\Cuaent\214afG scrv
Cm.c : 3/8/04 11 36AM
Revised. 3/26/04 10: 12AM
]619c.214
DICKINSON COLLEGE,
Plaintiff
V.
JIN G. LEE,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.03-5080
CIVIL ACTION-LAW
JURY TRIAL OF TWELVE DEMANDED
PROOF OF NON-SERVICE
Please record the attached Proof of Non-Service from the King County Sheriffs Office.
MARTSON
David R. Galloway
Attorney I.D. No. 87326
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
WILLIAMS & OTTO
Date: March 26, 2004 Attorneys for Plaintiff
430118/ds
KING COUNTY
NON SERVICE NOTICE
STATE OF WASHINGTON)
SS.
COUNTY OF KING )
Dickinson College
vs
Lee, Jin G.
PENNSYLVANIA
03-5080
PROCESS Notice, Complaint;
Exhibit A, B
DATE RECEIVED
DATE (S)ATTEMPTED
DATE OF RETURN 3/14 04
NAMED PARTYJin G. Lee
PRESENT STATUS 3/3/04@0750 Per Defendant's Ex-wife, defendant
moved back to Korea. Defendant has been divored for over a year.
?er Ex-wife defendant's E-Mail addres (in Korea) is DKY496@Yahoo Com
LAST KNOWN ADDRESS 5311 Lakemont Blvd. SE #1324, Bellevue, WA
SHERIFF DAVID G. REICHERT
KING COUNTY SHERIFF'S OFFICE
Mark Aratani
DEPUTY
SHERIFF'S FEES
RETURN $ Il_DD
MILEAGE $ q - I C
TOTAL $ 22.10
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F:\FILES\Clients\DickinsonCollege7619\CollectionsW chive\214\214.pral/nlm
Created: 2/17/04 2:23PM
Revised: 10/15/07 4:19PM
7619C.214
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 03 - 5080
CIVIL ACTION-LAW
JIN G. LEE
Defendant JURY TRIAL OF TWELVE DEMANDED
PRAECIPE
To the Prothonotary:
Please enter the appearance of MARTSON DEARDORFF WILLIAMS OTTO GILROY
& FALLER as attorneys for the Plaintiff in the above-captioned matter.
MARTSON LAW OFFICES
By
Christopher E. Rice, Esquire
L D. Number 90916
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Date: l - ( ' - cl 7 Attorneys for Plaintiff
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F: \FILES\Clients\DickinsonCollege7619\Collections W rchive\214\214.pra2/nlm
Created: 2/17/04 223PM
Revised: 10/15/07 4:19PM
7619C.214
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 03- 5080
CIVIL ACTION-LAW
JIN G. LEE
Defendant : JURY TRIAL OF TWELVE DEMANDED
To the Prothonotary:
PRAECIPE
Please mark the above-captioned matter discontinued without prejudice.
MARTSON LAW OFFICES
Y
Christopher E. Rice, Esquire
I. D. Number 90916
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Date: /c - /, - v i Attorneys for Plaintiff
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