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Home My WebLink About03-5084DICKINSON COLLEGE, Plaintiff V. GORDON R. PERLMUTTER, CAROLE L. PERLMUTTER and AMBER PERLMUTTER, Defendants 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 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 Date: September 24, 2003 BY~~o~~ I.D. No. 87326 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff GORDON R. PERLMUTrER, CAROLE L. PERLMUTTER, and AMBER PERLMUTTER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- ffO '~r~/ CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED COMPLAINT AND NOW, comes Plaintiff Dickinson College by and through its attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and hereby avers as follows: 1. Plaintiff Dickinson College, (hereinal~er "Dickinson"), is a Pennsylvania educational institution and nonprofit corporation with its principle place of business at West Street, Post Office Box 1773, Carhsle, Cumberland County, Pennsylvania 17013. 2. Defendants, Gordon R. Perlmutter and Carole L. Perlmutter, (hereinafter"Parents"), are adult individuals residing as husband and wife with a last known address of 401 Burnt Mill Road, Chadds Ford, Chester County, Pennsylvania 19375-0823. 3. Defendant, Amber Perlmutter, (hereinafter "Student"), is an adult individual residing with a last known address of 51 Rue des Dervallieres, 4400 Nantes, France. 4. On or about August 21, 1992, Parents and Student entered into a Promissory Note (Note #1) with Dickinson for the financing orS 10,000.00, plus interest, for educational services and benefits to Student at Dickinson. A copy of Note #1 is attached hereto as Exhibit "A." 5. On or about September 16, 1993, Parents and Student entered into a Promissory Note (Note #2) with Dickinson for the financing of $10,000.00, plus interest, for educational services and benefits to Student at Dickinson. A copy of Note #2 is attached hereto as Exhibit "B." 6. On or about October 3, 1994, Parents and Student entered into a Promissory Note (Note #3) with Dickinson for the financing of$8,170.00, plus interest, for educational services and benefits to Student at Dickinson. A copy of Note #3 is attached hereto as Exhibit "C." 7. On or about December 14, 1994, Parents and Student entered into a Promissory Note (Note g4) with Dickinson for the financing of $1,830.00, plus interest, for educational services and benefits to Student at Dickinson. A copy of Note ~4 is attached hereto as Exhibit "D." 8. The collective phnciple balance for Note #1, Note #2, Note #3 and Note g4 is $30,000.00. 9. Note #1, Note #2, Note #3 and Note g4 grant Plaintiff reasonable collection and attorneys' fees which Dickinson has calculated to be $4,500.00. 10. As of September 3, 2003, the principal and interest due and payable by Parents and Student to Dickinson was $39,755.33 with interest accruing thereafter at $3.80. 11. As of September 3, 2003, the outstanding balance of $39,755.33 represented the total and actual overdue value of the financing provided to Parents and Student under Note #1, Note #2, Note #3 and Note g4 for which they have yet to pay. COUNT I BREACH OF CONTRACT Dickinson College v. Gordon R. & Carole L. Perlmutter and Amber L. Perlmutter 12. Dickinson hereby incorporates by reference the averments contained in Paragraphs 1 through 11 of this Complaint. 13. Dickinson has fulfilled, performed and complied with all obligations and conditions of Note #1, Note #2, Note #3 and Note g4 . 14. Parents and Student breached the expressed and implied obhgations, conditions and terms of agreement of Note #1, Note #2, Note #3 and Note ~4 by failing to pay the mounts financed therein. WHEREFORE, Dickinson demands judgment against Parents and Student in the amount of $39,755.33, plus interest in the amount of $3.80 per day, collection and attorneys' fees in the amount of $4,500.00 and costs of suit. COUNT H IN QUANTUM MER UIT Dickinson College v. Amber L. Perlmutter 15. Dickinson hereby incorporates by reference the averments contained in Paragraphs 1 through 14 of this Complaint. 16. Having requested Dickinson to loan money, and doing so to the benefit of Student, Student became liable to Dickinson for said money. 16. Student has been unjustly enriched by accepting said money without paying Dickinson reasonable compensation therefor. 17. The total amount by which Student has become enriched is $39,755.33, plus interest in the amount of $3.80 per day from September 3, 2003. WHEREFORE, Plaintiff demands judgment against Student in the amount of $39,755.33, plus interest in the amount of $3.80 per day from September 3, 2003, collection and attorneys' fees in the amount of $4,500.00 and costs of suit. Date: September 24, 2003 MARD vTi~LIAMS & OTTO ID. No. 87326 I Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff 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 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.#38423 1341 N. Delaware Avenue, Suite 405 Philadelphia, PA 19125 (800) 672-0215 Attorney for Plaintiff CREDIGY VS. TRACY R UHLER TO THE PROTHON£ Please mark tb Our File No. 018897 ) COURT OF COMMON PLEAS ) CUMBERLAND COUNTY Plaintiff, ) ) ) ) NO. 02-5084 ) ) ) ~efendant. ) ) 'RAECIPE TO MARK JUDGMENT SATISFIED FARY: Judgment Satisfied against the Defendant. Judgment has been paid in full. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff By: David J. SHERIFF'S RETURN - CASE NO: 2003-05084 P COMMONWEALTH OF P~NNSYLVANIA: COUNTY OF CUMBERLAND DICKINSON COLLEGE VS PERLMUTTER GORDON R ET AL OUT OF COUNTY R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: PERLMUTTER GORDON R but was unable to locate Him deputized the sheriff of CHESTER in his bailiwick. County, serve the within COMPLAINT & NOTICE He therefore Pennsylvania, to On October 30th 2003 attached return from CHESTER Sheriff's Costs: Docketing Out of County Surcharge Dep Chester Co 18.00 9.00 10.00 37.14 .00 74.14 10/30/2003 MDW&O Sworn and subscribed to before me this .5 ~ day of~/~_~, __ , this office was in receipt of the R. Thomas Kline' Sheriff of Cumberland County SHERIFF'S RETURN - CASE NO: 2003-05084 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DICKINSON COLLEGE VS PERLMUTTER GORDON R ET AL OUT OF COUNTY R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: PERLMUTTER CAROLE L but was unable to locate Her deputized the sheriff of CHESTER in his bailiwick. County, serve the within COMPLAINT & NOTICE He therefore Pennsylvania, to On October 30th , 2003 attached return from CHESTER Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 .00 16.00 10/30/2003 MDW&O Sworn and subscribed to before me this ~ day of ~ o~ 0~33 A.D. Prothonotary __ , this office was in receipt of the SO answers: ~/ ~ R.z Thomas Kline Sheriff of Cumberland County In The Court of Common Pleas of Cumberland County, Peo?ylvama Dickinson College vs. ~on R. Per~tter et al SE~: ~on R. Per~utt~ NO. 03-5084 Now, September 29, 2003 hereby deputize the Sheriff of C~ester deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA ANY REFUND SHOULD BE PAYABLE TO CUMBERLAND (ZXJNTY SHERIFF , I, SHERIFF OF CUMBERLAND COUNTY, PA, do County to execute this Writ, this Affidavit of Service NOW, within ,20.. , at o'clock __ M. served the upon at by handing to a and made known to' copy of the original the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this __ day of ,20 COSTS SERVICE MILEAGE AFFIDAVIT R. THOMAS KLINE Shedff EDWARD g SCHORPP Solicitor 7 SHERIFF'S COSTS - ~~i ' Chief Depu~ JODY S. SMITH Real E~ate Depu~ OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 TO: Hon. Carolyn Welsh Chester County Sheriff Dear Sir: P~: Dickinson College VS Gordon R. Perlm~tter et al 03-5084 civil Enclosed please find to be served upon Notice and Ccmplaint 1. Gordon R. Perlmutter~ 2. Carole L. Perlmutterk-' 401 Burnt Mill Road Chadds Ford, PA 19375 ANY REFJND SHOULD BE PAYABLE TO CdMBERLANDO3UNTY SHERIFF in your County. Kindly make service thereof and send us your return of service. Enclosed is the advance payment which you requested. Very truly yours, . ' R. Thomas Kline, Sheriff Cumberland County, Pem~sylvania 'Enclosures: In The Court of Common Pleas of Cumberland County, NO. Dickinson College VS. Gordon R. Perlmutter et al SERVE: Carole L. Perlmutter 03- 5084 t ~-~Ttto servic~/o.. NOW, September 29, 2003 hereby deputize the Sheriff of Chester deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA ANY REFUND SH(J3L~ BE PAYABLE TO CUMBERLAND OOUNTY SHERIFF , I, SHERIFF OF CUMBERLAND COUNTY, PA, do County to execute this Writ, this Affidavit of Service Now, ,20 . , at o'clock __ M. served the within upon at by handing to a and made known to copy of the original the contents thereof. So answers, Sheriffof County, PA Sworn and subscribed before me this __ day of ,20 COSTS SERVICE MILEAGE AFFIDAVIT R. THOMAS KLIN~ EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF JODY S, SMITH Real Estate Deputy On9 Courthouse Square Carlisle, Pennsylvania 17013 TO; Ho~o Carolyn Welsh Cheste~r County Sheriff Dear Sir: 1~: Dickin.son College VS Gordon. R. Perln~tte~ et al 03-5084 civil Enclosed please fred to be served upon Notice and Complaint 1. Gordon R. Perlmutter 2. Carole L. perlmutter 401 Burnt ·Mill Road Chadds Ford, PA 19375 ANY REFUND SHOULD BE PAYABLE TO O3MBERLAND ODUNTY SHERIFF in your County. K~ndly make service thereof and send us your return of service. Enclosed is the advance payment wlfich you requested. Very l~'aly yours, _ R. Thomas Kline, Sheriff Cumberland County, Pennsylvania DICKINSON COLLEGE, Plaintiff GORDON R. PERLMUTTER, CAROLE L. PERLMUTTER and AMBER PERLMUTTER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- 5084 CWIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED pRAE_ CIPE Please reinstate the attached Complaint against GORDON R. PERLMUTTER, CAROLE L. PERLMUTTER and AMBER PERLMUTTER, in the above-captioned action and return same to the undersigned for service. MARTSON DEARD(~ WILLIAMS & OTTO Ten East High Street ' Carlisle, PA 17013 (717) 243-3341 Date: December 16, 2003 Attorneys for Plaintiff F:/F[LES/DATAFILE/DickinsOn Co ege 7619 Dickm~onCo egeCollect/ons 7619C~Curcent/i 71 pr~2 Creaxed 12/16/03 2:20PM Revised ]/8/04 910AM DICKINSON COLLEGE, Plaintiff GORDON R. PERLMUTTER, CAROLE L. PERLMUTTER and AMBER PERLMUTTER, Defendants 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- 5084 CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED PRAECIPE Please reinstate the attached Complaint against Gordon R. Perlmutter and Ccarole L. Perlmutter, 98 Northbrook, West Chester, PA, ' · . Chester County Sheriff for service, m the above-captioned action and forward same to Date: January 8, 2004 LIAMS & OTTO I. D. Number 87326 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff GORDON R. PERLMUTTER, CAROLE L. PERLMUTTER and AMBER PERLMUTTER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- 5084 CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO DOCUMENT SERVICE AND COST OF SERVICE PURSUANT TO THE PENNSYLVANIA LONG ARM STATUTE I hereby certify that a copy of the Complaint was mailed to Amber Perlmutter on December 19, 2003, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed and dated January 5, 2004 and a copy of the receipt showing the cost of service was $10.85. MARTSON DEaF WILLIAMS & OTTO David R. Galloway, E'~uire I.D. No. 87326 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: January 14, 2004 Attorneys for Plaintiff ----~l~gistered No. Day Received by With Postal Full Va, lue $ [~ Insurance tthout Postal PS Form 3806, Receipt for Registered Mail copy I - Customer June 2002 (See Inforr~lation on Reverse) For delivery information, visit our website at www. usps. com® CERTIFICATE OF SERVICE I, Marti Iben, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Amber Perlmutter 51 Rue des Dervallieres 4400 Nantes, France MARkTS~/~EARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: January 14, 2004 -Ia The Court of Common Pleas of Cumberland County, renngylvama vs. ?il~!ui:~'~,'~!:~'*~;'~ 5~;'L~<,;F'5 C0575 SE~: Carole L. Per~tter ~OW,~ Janu~ 9, 2004 ~, I, S~FF OF C~E~ CO~y, PA, do hereby deputize ~e Sheriffof ~ester Co~ to execute ~is Writ, this deputation being made at ~e request ~d risk of~e Pla~ti~ She~ffofCm~nd Co~, PA **Please make ~y ~d ~yable to ~rland Cmnty Sheriff.* ~nk Affidavit of Service _, 20p_'.~._, at ~ £2__ o'clock ~ M. served the within __~£/_-.~.~,Or .~' -- '~ "/,~-_.Z.~,,~ z.. ~ o_Z_22,~, · . . ~-~' ~..~/d~z~7. by handing to ~ ~ ~ copy oft. he orig/nal and made known to ~ ------ ~ the contents thereof. ; ~,,,~r~t~r County I · '~rtl 14, 2005 ! Sworn and subscribed before me ~i~ day or~, 20~ 80 allSwel-s, efiff0f ' -~ ~ Count, PA COSTS SERVfCE M~EAGE~ $ In The Court o£ Common Plea~, ~umbeq~ ~o~n~, Pe~nn~ylvama Gordon R. Per]mutter ~5~R COU~ITY, ~OW, Janua~ 9, 2004 ~, I, S~FF OF C~E~ CO~Ty, PA, do hereby deputize ~e She~ffof meste~ Cowry to execute ~is Writ, ~is deputation being made at ~e request ~d risk of the Pl~nti~ Sh~riffofCum~d Co.W, PA **Please make ~y refund ~able to ~rland ~nty Sheriff** ~nk you AffidavR of Se~ce __ ~, 20d_z~, at ~ o'clock _~. within by h=ding to a copy of~e ori~nal ~d made ~o~ to ~~~~~A ~ the contents ~ereoE M. served the So answers, S,,~om me this Co~y, p~ COSTS SERVICE CERTIFICATE OF SERVICE I, Marti Iben, an authorized agent ofMartson DeardorffWilliams & Otto, hereby certify that a copy of the foregoing Affidavit of Service was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Amber Perlmutter 51 Rue des Dervallieres 4400 Nantes, France Gordon R. Perlmutter Carole L. Perlmutter 98 Northbrook Road West Chester, PA 19382 Dated: February 17, 2004 MARTSON ~ARDORFF WILLIAMS & OTTO Marti Ibe~ ,v Ten East High Street Carlisle, PA 17013 (717) 243-3341 SHERIFF'S RETURN CASE NO: 2003-05084 P COMMONWEALTH OP PENNSYLVAiqIA: COUNTY OF CUMBERLAND DICKINSON COLLEGE VS PERLMUTTER GORDON R ET AL OUT OF COUNTY R. Thomas Kline , duly sworn according to law, says, that he made and inquiry for the within named DEFENDANT PERLMUTTER GORDON R but was unable to locate Him deputized the sheriff of CHESTER serve Sheriff or Deputy Sheriff who being a diligent search and , to wit: in his bailiwick. County, the within COMPLAINT & NOTICE He therefore Pennsylvania, to On February_ 9th , 2004 attached return from CHESTER Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Chester Co 30.25 .00 67.25 02/09/2004 MDW&O Sworn and subscribed to before me this /2'~ day of t~ Juu ~ A.D. Prothonotary this office was in receipt of the So answer/ ~/ ~ ..... 122 R. Thomas Kline / Sheriff of Cumberland County SHERIFF'S RETURN - CASE NO: 2003-05084 P COMMONWEALTH OF PENNSYLV~/qlA: COUNTY OF CUMBERLAND DICKINSON COLLEGE VS PERLMUTTER GORDON R ET AL OUT OF COUNTY R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT PERLMUTTER CAROLE L but was unable to locate Her deputized the sheriff of CHESTER Sheriff or Deputy Sheriff says, that he made a diligent , to wit: in his bailiwick. County, serve the within COMPLAINT & NOTICE who being search and He therefore Pennsylvania, to On February 9th , 2004 attached return from CHESTER Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 .00 16.00 02/09/2004 MDW&O Sworn and subscribed to before me this /2 ~' day of J~7 A.D. Prothonotary this office was in receipt of the R. Thomas Kline ~-~ Sheriff of Cumberland County Codrt o~ Common Pleas of Cumberland County, Penn~y~lCama Dickinson College~h~tt,,~.?,.:~', ~,~. 5t ~ ~i C ~ COSTS ~on R. Per~tter ~.g uuu,* Now, January 9, 2004 /~'-o 03_50~i~ivi1 No. , I, S~FF OF C~E~ CO~TY, PA, do hereby deputize the Sheriffof Chester County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. . Sheriff of Cumberland County, PA **Please make ~ refund payable ~'~rland County Sheri~ Thank you Affidavit of Service Now, taft/'], '3 ,20tyq , at /2 £2 o'clock /~. M. served the by handing to t'.;O/Zbo, O /?. /°,ff_f/Z,V'o/--~'/E// ~ copy of the original and made known to the contents thereof. NOTARIAL SEAL j '" P C~OMMELYN, Notary Public [ ' "~*7"~oro, OhesterOounty ~ · ' :"%'~S April 14, 2005 [ Sworn and subscribed b,~f~e me thi¢/,~ ~y of ,Z9-¢'- ,20d9' So answers, COSTS SERVICE MILEAGE AFFIDAVIT in The Court of Common Pleas of Cumberland County, Pennsvlvama Dickinson College...~..~ ,: .~r,~i~L'B~!,~h?c'~~ S~I~.Kit r b COo ~ S ~on ~. Per~tter ~ January 9, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Chester County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Camberland County, PA **Please make any refund payable .~berland County Sheriff** Thank you Affidavit of Service Now, /:/E/~ ) ,20~ , at/?. ¢~- o'clock /~ M. served the within upon by handing to ~'O/Zf)tg~ /~. zo.~//Z.;/~7~//j/// ~1~ copy of the original and made known to ~'~o/'tg)/J~ fl /O,6/?z.~o~7./>/t the contents thereof. So answers, Sheriff of ~ County, PA COSTS SERVICE MILEAGE AFFIDAVIT DICKINSON COLLEGE, Plaintiff GORDON R. PERLMUTTER, CAROLE L. PERLMUTTER and AMBER PERLMUTTER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- 5084 CIVIL ACTION-LAW JLrRy TRIAL OF TWELVE DEMANDED PRAECIPE TO THEPROTHONOTARY: Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendants in the amount of $39,755.33 plus interest from September 3, 2003, in the amount of $1,003.20, attorneys' fees in the amount of $4,500.00 for a total of $45,258.53, plus costs of suit and interest from date of judgment as per the Notes attached to the Complaint for Defendants' failure to file an answer to the Complaint. I do hereby certify that a written notice of intention to file this Praecipe (in the form attached hereto) was mailed to Defendant, Amber Perlmutter, and Defendants, Gordon R. and Carole L. Perlmutter, at the addresses indicated thereon, on February 17, 2004 and March 9, 2004, respectively, a date subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. M~O~LIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Dated: DICKINSON COLLEGE, Plaintiff GORDON R. PERLMUTTER, CAROLE L. PERLMUTTER and AMBER PERLMUTTER, Defendants 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- 5084 CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED TO: GORDON IL PERLMUTTER, CAROLE L. PERLMUTTER & AMBER PERLMUTTER, DEFENDANTS NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on May ,~'~ , 2004, the following Judgment was entered against you in the above-captioned case: [I]n the amount of $39,755.33 plus interest from September 3, 2003, in the amount ors 1,003.20, attorneys' fees in the amount of $4,500.00 for a total of $45,258.53, plus costs of suit and interest from date of judgment as per the Notes attached to the Complaint for Defendm~ts' failure to file an answer to fl~e Complaint. Date: Prothonotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Ms. Amber Perlmutter 5 l Rue des Dervallieres 4400 Nantes, France Mr. Gordon R. Perlmutter Mrs. Carole L. Perlmutter 98 Northbrook Rd. West Chester, PA 19382 CERTIFICATE OF SERVICE I, David R. Galloway, an authorized agent of MARTSON DEARDORFF WILLIAMS & OTTO, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Amber Perlmutter 51 Rue des Dervallieres 4400 Nantes, France Mr. Gordon Perlmutter Mrs. Carole L. Perlmutter 98 Northbrook Rd. West Chester, PA 19382 MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: DICKINSON COLLEGE, Plaintiff GORDON R. PERLMUTTER, CAROLE L. PERLMUTTER and AMBER PERLMUTTER, Defendants 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O3- 5084 CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED TO: GORDON R. PERLMUTTER AND CAROLE L. PERLMUTTER, Defendants IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUT, LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROV1DE YOU WITH ENFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Date: March 8, 2004 Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 MARTSON DEARDORF[[I x~VILLIAMS & OTTO David R. Galloway, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff