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Home My WebLink About03-5215 F:\FILES\DA TAFILE\Dickinson College 7619\DickinsonCollegeCollections7619ODocuments\222-com] ,wpdlhad Created:3/17/039:2557PM Revis~: ]0/\/032:34:14 PM DICKINSON COLLEGE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-5dI5'c,:tI NO. CIVIL ACTION-LAW GLENN A. ROMERO Defendant ruRYT~ALOFTWELVEDEMANDED 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 By LIAMS & OTTO Attorneys for Plaintiff Date: October 2, 2003 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANIA NO. 03- 5..}!.:) C;..;....t T ~ CML ACTION-LAW DICKINSON COLLEGE, Plaintiff GLENN A. ROMERO 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, Glenn A. Romero, (hereinafter "Student"), is an adult individual with a last known address of 40 Cabot Street, Salem, MA 01970-4642. 3. On or about November 13, 1996, Student entered into a Promissory Note (Note #1) with Plaintiff for the financing of$2,200.00, 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 August 29, 1997, Student entered into an additional Promissory Note (Note #2) with Plaintiff for the financing of $3,500.00, 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 aboutJanuary 28, 1998, Student entered into an additional Promissory Note (Note #3) with Plaintiff for the financing of$3,300.00, plus interest, for educational services and benefits to Student at Plaintiff's institution. A copy of Note #3 is attached hereto as Exhibit "C." 6. On or aboutJanuary 25, 1999, Student entered into an additional Promissory Note (Note #4) with Plaintiff for the financing of $4,700.00, plus interest, for educational services and benefits to Student at Plaintiff's institution. A copy of Note #4 is attached hereto as Exhibit "D." 7. The collective principal balance for Note #1, Note #2, Note #3 and Note #4 IS $13,700.00. 8. Note #1, Note #2, Note #3, and Note #4 grant Plaintiff reasonable collection and attorneys' fees which Plaintiff has calculated to be $2,055.00. 9. As ofJuly 18,2003, the principal and interest due and payable by Student to Plaintiffwas $16,210.76, plus interest in the amount of $2.25 per day from July 18, 2003. 10. Student stopped making monthly payments on Note # I, Note #2, Note #3, and Note #4 on or about July 16, 2001. II. As ofJuly 18,2003, theoutstandingbalanceof$16,210.76represents the total and actual overdue value of the financing provided to Student under Note #1, Note #2, Note #3 and Note #4 for which they have yet to pay. 12. Plaintiff fulfilled, performed and complied with all obligations and conditions of Note #1, Note #2, Note #3 and Note #4. COUNT I BREACH OF CONTRACT Dickinson Colleee v. Glenn A. Romero 13. Plaintiff hereby incorporates by reference the avennents contained in Paragraphs 1 through 12 of this Complaint. 14. Student breached the expressed and implied obligations, conditions and tenns of agreement of Note #1, Note #2, Note #3 and Note #4 by failing to pay the amounts financed therein. WHEREFORE, Plaintiff demands judgment against Defendant, GlennA. Romero, in the amount of$16,21 0.76, plus interest in the amount of$2.25 per day from July 18, 2003, collection and attorneys' fees in the amount of $2,055.00 and costs of suit. COUNT II IN QUANTUM MERUIT Dickinson Collel!e v. Glenn A. Romero 15. Plaintiff hereby incorporates by reference the averments contained in Paragraphs I through 14 of this Complaint. 16. Having requested Plaintiff to loan money, and doing so to the benefit of Student, Student became liable to Plaintiff for said money. 17. Student has been unjustly enriched by accepting said money without paying Plaintiff reasonable compensation therefor. 17. The total amount by which Student has become enriched is $16,210.76, plus interest in the amount of $2.25 per day from July 18, 2003. WHEREFORE, Plaintiff demands judgment against Defendant, Glenn A. Romero(Student), in the lIIllOunt of$16,21 0.76, plus interest in the lIIllount of$2.25 per day from July 18,2003, collection and attorneys' fees in the lIIllOunt of$2,055.00 and costs of suit. MARTSON DEARDORFF By r..~ David R. Galloway I.D. No. 87326 Ten East High Street Carlisle, P A 17013-3093 (717) 243-3341 Attorneys for Plaintiff Date: October 2, 2003 VERIFICATION I, THOMAS MEYER, Assistant Treasurer of Dickinson College, acknowledge that I have the authority to execute this Verification on behalf of Dickinson College and certify that the foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of this lawsuit. The language of this Complaint is that of counsel and not my own. I have read the document and to the extent that this Complaint is based upon information which I have given to my counsel, it is true and correct and to the best of my knowledge, information and belief. To the extent that the content of this Complaint is that of counsel, I have relied upon counsel in making this Verification. This statement and Verification are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. Dickinson College c...-.... Thomas Meyer Assistant Treasurer of Dickinson College Dated: CERTIFICATE OF SERVICE I, Marti Then, an authorized agent of Marts on Deardorff Williams & Otto, hereby certify that a copy of the foregoing Complaint was served this date by depositing same in the Post Office at Carlisle, P A, Certified MaillRestricted Delivery, postage prepaid, addressed as follows: Glenn A. Romero 40 Cabot Street Salem, MA 01970-4642 MARTSON DEARDORFF WILLIAMS & OTTO Bl-4~- ~' Marti Then Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: October 2, 2003 () ~ r:, ~ ~:. '" "Ct- .:; IT,; , ~ ?>. ~ ~ Vi C)J) i' ...... 0 ~ JJ 9.J r:>... 0? ,",,) -V ~~,f~ ()' ~ a ~ )>_(0: V 3. ._fl ? ,r> ? ~ F,IFILESIDATAFILEIDickinson College 7619\DickinsonCollegeCollec!ions761 9CICurrent\222atn Itde Created: 3!l7/039:25:57PM Revised,3/llI0411:847AM DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 03-5215 CIVIL ACTION-LAW GLENN A. ROMERO Defendant JURY TRIAL OF TWELVE DEMANDED AFFIDAVIT OF DUE DILIGENCE I, David R. Galloway, Esquire, being duly sworn according to law upon my oath, depose and say, that I am at least 18 years of age. I hereby certifY and return that diligent attempts were made to serve the Complaint on the above Defendant(s) by mailing the Complaint, via Certified Mail, Restricted Delivery, to Glenn A. Romero at his last known address: 40 Cabot Street, Salem, MA 01970. That Complaint was returned to me marked "Not Deliverable As Addressed - Unable to Forward" on October 9,2003. I certify that the foregoing statements made by me are true and correct. I am aware that if any of the foregoing statements made by me are willfully false, I am su . ct to punishment. Da . R. Galloway Attorney for Plaintiff Sworn ~ and subscribed before me ~ ~/. d~of ~1: <'('l~ PV ~ Notary Public ,2004. NOTARIAL SEAL TRICIA 0 ECKENROAD, Notary Public Carlisle "ora, Cumberland County M Comr.' i' 04 ....tI<il<< I'~<t: 1<1.t~l~ " r".,-..-.----. 1',"1,' i :....." ~~.. ;,' ~IJ I II! .... ;:~ ~;,Ji . 1;~ .... Ij~~l .<", "'. , 'j. i ::.'~' I U,' l:-j 1 :771'~.?:::??C- -'- f~~ )i )~:;::.~:.:.;~:" .''r~l.c'';'~':S" " 'C',:' I~~"',..,.. ~ - - ,I 1",( -.. Ii \. ',4)', ) flO ~ u " ~ z . c ~ ~~ c --0 < fy ';2.' ill i..> E ...... ~ .~;,: ~ 9 '" ".. I)J iJ 2: " CJ ,~ ,~~ '~J f..:t ..J;1!;;d I..J.Jrg .::::;~ - I.LJ~ <.J;: 1.L.Je.> "t:'<:::l ,-' u, Cl <0 <0 <0 '"", u,', ru' m Cl Cl Cl Cl .:r- '"" '"" '"" Cl Cl ...... 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Revised J/IOI043:826PM DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 03-5215 CIVIL ACTION-LAW GLENN A. ROMERO Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE Please reinstate the attached Complaint against Defendant Glenn A. Romero, in the above- captioned action and return same to the undersigned for service. MARTS ON DEARDORF WILLIAMS & OTTO By David R. Galloway, Esqu' 1. D. Number 87326 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: March 10, 2004 Attorneys for Plaintiff (") "'" 0 => c = -n .<.- ::;!r. ..... ~ ~0 fi1:D -nhi ~rCJ F)' '::;os';?, J;:.? ~~~ ~rs -,...,' , <5 ::C,""r-p ..;" (~ ~::'; z: ':-,' ~.j c.n -.:;. -, W F:IFILESIDATAFlLE\Dickinson College 7619\DickinsonCollegeCollections7619C\Current\222.pra2\nlm Crealed:3/J7/039:25:57PM Revised: 8f26104349:42 PM 7619C.222 DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF C~ERL~)COUNTY,PENNSYLV~ v. NO. 03-5215 CIVIL ACTION-LAW GLENN A. ROMERO Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE Please reinstate the attached Complaint against Defendant Glenn A. Romero in the above- captioned action and retum same to the undersigned for service. By David R. Galloway, Es I. D. Number 87326 Ten East High Street CarJisle, P A 17013 (717) 243-3341 M Date: August 26, 2004 Attorneys for Plaintiff ~ ~ ~ ~w; ~ ~(: '3 ~:;, ,-::::0 ~ ~8 ::. ~~ ~ Q. ~~ !~ ~.,., 6~ t'Si"<'1 ."'1 ". '" ~ (.;> F: IFlLES\DA T AFILE\Dickinson College 7619IDickinsonCol1egeCollections7619C\Current\222.aff2land Created: JO/IO/020246:S0PM Revised: 09/221040J:26:45PM 7619c.222 DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-5215 CNIL ACTION-LAW GLENN A. ROMERO, Defendant JURY TRIAL OF TWELVE DEMANDED PROOF OF SERVICE AND COST O]~ SERVICE PURSUANT TO THE PENNSYLVANIA LONG ARM STATUTE To the Prothonotary: Attached is the Affidavit of Service indicating Defendant was served with the Reinstated Complaint on September 13, 2004. Additionally, we attach two invoices showing the total cost of service was $95.00. By I LD. No. 873 6 Ten East High Street Carlisle, P A 17013-3093 (717) 243-3341 Attorneys for Plaintiff Date: Gssex Counly c5henJl's LJeparlmenl 7)1;J/yion o/CI;JtlA'oce,y.> Frank G. Cousins. Jr.. Sheriff William J. Mageary, Director Aobyn Clarke, Office Manager POST OFFICE BOX 2019 36 FEDERAL STREET SALEM, MASSACHUSETTS 01970 Essex.ss. Docket # 03-- 5".::< I s.- CourG.m Ifal~ cf ~J7nM.1 c'/vj I, ~Jl-I\/ .F&4... .j.j9~3 a Deputy Sheritfin Essex Cou~~t;sa~~ftts declare that I am over the age of eighteen (I 8) ye~s and not ,a,~ to the above entitled actlOn:J4at on c;i5-jfj;7i; at..'> ; 10 AJv~ I dId personally serve upon G /b1A1 e.I<'J a copy of the within precept in the following manner; IV J/#/V/j d #f~3 eputy Sheriff of Essex County Jw c+ A/ ,;C ;3 c.e. Printed Name illS @ cg Servic1Fee: _. .,.A U TotaL ~!) , ~' Subsribed and sworn to before me, Notary Public, this, I U In the city of Salem, Massachusetts Essex County , dayo(<,/uTlrlll t~f /Joe"-/' // f ~ ~ c/ . (0; aA i J ~ ./ I /)11 f h / ' k.., /J r2 / '-Ni1a~ Public i Y II II e ()5 rJ (, r ill .f'_ - ~ My Commission Expires:lJ...).,.-'lI'1' jfJ ,) (' II F. IF] L ES\DA T Afl LE\Dickinsoll C 01 kge 7& 19\DickinsonC oll~gcC "Ii ~clions 76 19CIDocu111cntsl22 2-C0111 I , wpd\had Crcmed,YI7/039:25:S7PM R"vised 10/1103234:14 PM DICKINSON COLLEGE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-- ~i"?-J5' CIVIL ACTION-LAW (") i-::' ,', ::~: ......'J JURY TRIAL OF TWELVE D~NJjlYP :;:;. n GLENN A. ROMERO Defendant NOTICE 03 ' ~r~~~,'. 'c You have been sued in court. If you wish to defend against the claims~erforfu: in the" following pages, FlU must take action within twenty (20) days after this Complaint ~ NQti,ce a~ served, by entering a written appearance personally or by attorney and filing in writing With fff!: 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 LA WYERA T 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 DEARDO By::;;J/?c DaVId R. Galloway, Esquire LD. No. 87326 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Date: October 2, 2003 .. ;;:1) rc: '5. _..', f' . ti ~::":.,:C'; }:{c- '~ ','" ) (""j ft..".l:;{*'.~ .. ".' ',,~. ' Ji ',~-,~,.,.~>:~! PI,. ;',.~.._~ ~SAJ r I>r(..-:m;;;~- DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANIA v. NO. CIVIL ACTION-LAW GLENN A. ROMERO 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: I. Plaintiff Dickinson College is a Pennsylvania educational institution and nonprofit corporation with its principle place of business at West Street, Post Office Box 1773, Carlisle, Cumberland COlUlty, Pennsylvania 17013. 2. Defendant, Glenn A. Romero, (hereinafter "Student"), is an adult individual with a last known address of 40 Cabot Street, Salem, MA 01970-4642. 3. On or about November 13, 1996, Student entered into a Promissory Note (Note #1) with Plaintiff for the financing of $2,200.00, plus interest, for educational services and benefits to Student at Plaintiffs institution. A copy of Note #1 is attached hereto as Exhibit "A." 4. On or about August 29, 1997, Student entered into an additional Promissory Note (Note #2) with Plaintiff for the financing of $3,500.00, plus interest, fi)r educational services and benefits to Student at Plaintiffs institution. A copy of Note #2 is attached hereto as Exhibit "B." 5. On or aboutJanuary 28, 1998, Student entered into an additional Promissory Note (Note #3) with Plaintiff for the financing of$3,300.00, plus interest, for educational services and benefits to Student at Plaintiffs institution. A copy of Note #3 is attached hereto as Exhibit "C." 6. On or aboutJanuary 25, 1999, Student entered into an additional Promissory Note (Note #4) with Plaintiff for the financing of $4,700.00, plus interest, fi)r educational services and benefits to Student at Plaintiffs institution. A copy of Note #4 is attached hereto as Exhibit "D." 7. The collective principal balance for Note #1, Note #2, Note #3 and Note #4 is $13,700.00. 8. Note #1, Note #2, Note #3, and Note #4 grant Plaintiff reasonable collection and attorneys' fees which Plaintiff has calculated to be $2,055.00. 9. As ofJuly 18, 2003, the principal and interest due imd payable by Student to Plaintiffwas $16,210.76, plus interest in the amount of$2.25 per day from July 18, 2003. 10. Student stopped making monthly payments on Note # I, Note #2, Note #3, and Note #4 on or about July 16, 2001. 11. As ofJuly 18, 2003, the outstanding balance of$16,21O. 76 represents the total and actual overdue value ofthe financing provided to Student under Note #1, Note #2, Note #3 and Note #4 for which they have yet to pay. 12. Plaintiff fulfilled, performed and complied with all obligations and conditions of Note #1, Note #2, Note #3 and Note #4. COUNT I BREACH OF CONTRACT Dickinson Collel!e v. Glenn A. Romero 13. Plaintiff hereby incorporates by reference the averments contained in Paragraphs I through 12 of this Complaint. 14. Student breached the expressed and implied obligations, conditions and terms of agreement of Note #1, Note #2, Note #3 and Note #4 by failing to pay the amounts financed therein. WHEREFORE, Plaintiff demands judgment against Defendlant, Glenn A. Romero, in the amount of$16,210.76, plus interest in the amountof$2.25 per day from July 18,2003, collection and attorneys' fees in the amount of$2,055.00 and costs of suit. COUNT II IN QUANTUM MERUIT Dickinson Collel!e v. Glenn A. Romero 15. Plaintiff hereby incorporates by reference the awrments contained in Paragraphs I through 14 of this Complaint. 16. Having requested Plaintiff to loan money, and doing so to the benefit of Student, Student became liable to Plaintiff for said money. 17. Student has been unjustly enriched by accepting said money without paying Plaintiff reasonable compensation therefor. 17. The total amount by which Student has become enriched is $16,210.76, plus interest in the amount of$2.25 per day from July 18, 2003. WHEREFORE, Plaintiff demands judgment against Defcmdant, Glenn A. Romero(Student), in the amount of$16,21 O. 76, plus interest in the amount of$2.25 per day from July 18,2003, collection and attorneys' fees in the amount of$2,055.00 and costs of suit. LIAMS & ono Date: October 2, 2003 By David R. Galloway LD. No. 87326 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys fol' Plaintiff DICKINSON COLLEGE CARLISLE, PA 17013-2896 (717) 245-1383 Date: November 13, 1996 I hereby acknowledge receipt from DICKlNSON COLLEGE of a loan in the amount of Two Thousand Two HllndrP.d dollars ($2200.00) which is hereby applied on my College account for the Fall and Spring semesters of the 1996-97 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 accme on a daily basis. II. Repayment I promise to repay the principal and the interest which accmes 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 $40.00 (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 duri,ng 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 accmed 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 ./ / ./ ~: ~/: / , , Glenn A. Romero ." -c- I) (~I - ( " i\ - { I ( I X:..J Social Security Number l', J ,--' I - ~ /, Date / / /. /.. / .:/ /1.__/ "/' . " ;,' ,/ "/ / / EXHIBIT "A" DICKINSON COLLEGE CARLISLE, PA 17013-21196 (717) 245-1383 Date: August 29, 1997 I hereby acknowledge receipt from DICKINSON COLLEGE of a loan in the amount of Three Thousand Five Hundred Dollars ($3,500.00) which is hereby applied on my College account for the Spring 19~7 semester. I agree to repay Dickinson College according to the following plan: 1. 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 RA 1E 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 $40.00 (which includes both principal and interest), and a maximum repayment period of five years (60 months). I reali.;e 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 s;;heduled 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 /) /" / S. . / I, __ < ___ '_ 19nature .':::-,/-",-_ Q'r'-;:-'t'7_~_ " ._ _.J Glenn Romero Date 9 /~J.? /q'7 .I . Ii., ,/ Social Security Number (, I '.~I - r '; ,.~ ' .,.;,''';_ " EXHIBIT "B" ,'._ A ,1 I ._ .- '.- , > DICKINSON COLLEGE CARLISLE, PA 17013-2896 -u,J. (717) 245-1383 Date: January 28, 1998 wledge receipt from DICKINSON COLLEGE of a loan in the amount of I hereby ackno e Hundred Dollars ($3,300.00) which is hereby applied on my College Three Thousand Thr~g 1~8 semester. I agree to repay Dickinson College according to the account for the Spnn following plan: I. Interest crue from the first of the month following the month in which I graduate Interest ~hall a~t Dickinson College, and shall be at the ANNUAL PERCENTAGERA1E or cease to matnculate n the unpaid balance. Interest will accrue on a daily basis. OF 6 percent interest 0 II. Repayment . epay the principal and the interest which accrues on it over a period . . I promIse to r frer the date I graduate or cease to matriculate at Dickinson College. I will begmrung SIX months/ installments with a minimum monthly payment of $40.00 (which includes repay m e~ual month Yest), and a maximum repayment period of five years (60 months). I reali2e both pnnclpal an~ mtedr er no obligation to grant deferments during the course of the repayment that the College IS un period. III. Default . a scheduled repayment of any installment, the entire unpaid indebtedness . . If I fall to mak:nd accrued thereon, plus any applicable penalty chazge, will, at the option mcludmg mterest due orne immediately due and payable. of Dickinson College, bec t if I default on my loan repayments that Dickinson College may disclose I understand thalong with other relevant information, to credit bureau organizations. that I have defaulted, a IV. Penalty Charge . timely payment of all or any part of a s::heduled installment, I promise to If I faIl to mak~ against me by Dickinson College. No charge may exceed $1.00 for the pay the charge assesse I1Ionth by which the installment is late, and $2.00 for each month or part first month or part of a I promise to pay all attorney's fees and other reasonable collection costs of a month thereafter. for the collection of any amount not paid when due. and charges necessary /7,," /, ",/ /~~~;kZj r's;;.- 4~-:v- , Glenn ROmero (// f-e';/";/f/ /5 Social Security Number~ Student Signature Date y1~;r EXHIBIT "e" J"l DICKINSON COLLEGE CARLISLE, P A 17013-2896 L,I'I ,.( -4'18\--(/ (act l/ancl'.j:; (717) 245-1383 Date: January 25, ] 999 I hereby acknowledge receipt from DICKINSON COLLEGE of a loan in the amount of Four Thousand Seven Hundred ($4,700), which is hereby applied on my College account for the Fall 1998 and Spring 1999 semester. 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 (6%) 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 $40.00 (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 ifI 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 IfI 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 $ I .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, ""d,"' Sign""re ~ /' ~4 ~= ~ 0"" ':;;~3~ Glenn A. Romero , Social Security Number OJ cj'~ ;;;tJ - t/C/ %6 EXHIBIT "D" 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 t~ue 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 Ito 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 Dated: ~~ Thomas Meye~ L-.... Assistant Treasurer of Dickinson College . .. : : ~ -g . . ~~\~ ~Jt:'Zj Z. ~.. ~~ ~~ ~: .~ ~ ~sse;r County Sheriffs 'Department 1Jivision of CiviC Process POST OFFICE BOX 2019 36 FEDERAL STREET SALEM, MASSACHUSETTS 01970 Frank G. Cousins, Jr., Sheriff Richard J. Roaf, ,Jr. Director Robyn M. Clarke, Office Manager " TELEPHONE: (978) 750-1900, exl 3590 Fax: (978) 741.2585 PLEASE REMIT TO: P.O. BOX 2019 SALEM, MA 01970 * Essex County Sheriff's Department. PO Box 2019 . Salem, MA 01970 . 978-750-1900 ex!. 3590 ..~ Essex, 55. September 10, 2004 By virtue of this writ I haw made diligent search for the within-named Glenn A. Romero and for hisfher/its last and usual place of abode, and for his tenant., agent, or attorney, but could not fmd himlher/it within this county; I therefore return this writ without service. $20.00. New address is 41 Jefferson Street in Lynn, Ma. Deputy Sherilf James St. Pierre bHl~~ f Deputy Sheriff ~ [Q1 CQ) (?J ~<;SEX COUNTY ~--;HFHIf: c,S Dr:rlI\HH,~[J-n . PHDCl:.~~S ()FTICF .. 1978\ 7~ln 1 ~)OO, [xt~1'/"(1 ~ . " <~ !"~, i~<,o. ,/1 ~-"-'!.. !.-~. 'ESSe7( Coun ty ,SfierUf~'i (Department 'Division of Civil 'Process POST OFFICE BOX 2019 36 FEDERAL STREET SALEM, MASSACHUSETTS 01970 fr8nk G. Cousins, ,Ir., Sheriff Ridlard ,.1. RnaL ,Jr. Din:>r.tor nc)hyn M, CIc:lrkA. Office Manaqer _ _ _PLEASE-BETURN THI2...TOP .!:,ORTION WITH YOU.!iPAYME~ _ _ _ _ _ _ _ _ _ _ _ _ _ * Essex County Sheriff's Department. PO Box 2019 . Salem, MA 01970 . 978-750-1900 ext. 3590 . . ~ Essex, 55. September 16, 2004 I hereby certify and return that on 9/1312004 at 05: 10 pm I servc:d a true and attested copy of the notice, complaint and exhibits in this action in the following manner: To wit, by delivering in hand to Glenn A. Romero at 41 Jefferson Street ,Lynn, MA 01902. Out of State ($75.00) Total Charges $75.00 (~7f;~ ~ Deputy Sheriff Deputy SherifI' John Pace ~ ~ (Q) (Q) fJ:,';['V r::(j, ,!(T" '~:-H::'-~I:' ',l);::p/.l:nr",'FJH ~'H()i ;:~~; C)~'TI',:;F ,!i'HI F,l,:Cl Id,:;';':"!() CERTIFICATE OF SERVICE I, Ashlee N. Davis, an authorized agent for Martson Deardorff Williams & Otto, hereby certifY that a copy of the foregoing Affidavit of Service was serv,cd this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Glenn A. Romero 41 Jefferson Street Lynn, MA 01902 MARTS ON DEARDORFF WILLIAMS & OTTO Byjbhlu JJ.IG~ Ashlee N. Davis Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: September 22, 2004 ,..<'1 , , , ,:..' .r" -<. C" ~ ..-\ -l ..l t,i ......; -C'J', 0-' c_~.... ...... ~, F: \FlLES\DA T AFlLEIDi~kjn5()nCollege 7619ICollectionsICulTentl222\pra3 ,. Created: 3/15/05 11:12AM Revised: 3/16/05 81EAM 7619C222 David R. Galloway, Esquire MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorne s for Plaintiff DICKlNSON COLLEGE, Plaintiff IN THE COURT OF COM ON PLEAS OF CUMBERLAND COUNT , PENNSYLVANIA v. NO. 03-5215 CNIL ACTION-LAW GLENN A. ROMERO Defendant JURY TRIAL OF TWEL V DEMANDED PRAECIPE TO THE PROTHONOTARY: Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant as follows: Principal plus interest through July 18, 2003: Interest from July 18, 2003, through March 15,2005: Attorneys' fees: Total Judgment: $ 16,210.76 $ 1,363.50 $ 2.055.00 $ 19,629.26 Costs of suit and interest accruing at $2.25 per day from March 15,2 05, shall be added to the Judgment for Defendant's failure to file an Answer to the Complaint. I do hereby certify that a written notice of intention to file this Praecip (in the form attached hereto) was mailed to Defendant at his last known address on March 3, 2 05, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTS ON DEARD , ------. i F WI LIAMS & OTTO Dated: March 16,2005 By David R. Galloway Attorney LD. 87326 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff r . CERTIFICATE OF SERVICE I, Jean Taylor, an authorized agent of MARTS ON DEARDORFF WILLIAMS & OTTO, hereby certify that a copy of the foregoing Praecipe was served this date by epositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as ollows: Mr. Glenn A. Romero 41 Jefferson St. Lynn, MA 01902 MARTSON DEARDORFF W ~~~S & OTTO BL q,'L_ aylor Te ast High Street Carlisle, PA 17013 (717) 243-3341 Dated: March 16,2005 I' ;., ". "r\'-II.I ('. ce,', cI "! ;~i'.\' \;"",1 "1;'.\, '"I"C _" David R. Galloway, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attomeys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COM ON PLEAS OF CUMBERLAND COUNT , PENNSYLVANIA v. NO. 03-5215 CIVIL ACTION-LAW GLENN A. ROMERO Defendant JURY TRIAL OF TWELV DEMANDED TO: GLENN A. ROMERO IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO E TER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN W TING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FOR H AGAINST YOu. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE 0 THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEAR G AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORT ANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONC . IF YOU DONOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FOR H BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE A Y BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT M Y OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 Date: March 3, 2005 M~:rSO N..J)E~.,,~' F WI, ,L ( , 11l~^J\ By .,~ ,gt , , ' .' XiI , David R. Galloway, Esquir<j: J.D. 87326 Ten East High Street Carlisle, PA 17013 (71 7) 243-3341 Attorneys for Plaintiff LIAMS & OTTO u.s. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER D t Received From ,- Affixf@ehereinslarrip9 or meler postage and' postmark.II'lQuirsOl Poslmasterfo(Eurrenl ~e. PS Form 3817, January 2001 \ -'4 0J -0 ~~~ ~ ~ ~ ~ ~~ ~ ~ ~. r r ........---- ~ David R. Galloway, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF CO MON PLEAS OF CUMBERLAND COUNT , PENNSYLVANIA v. NO. 03-5215 CIVIL ACTION-LAW GLENN A. ROMERO Defendant JURY TRIAL OF TWELV DEMANDED TO: GLENN A. ROMERO, DEFENDANT NOTICE OF ENTRY OF DEFAULT JUDGMEN You are hereby notified that on ~"- I ? ' 2005, the follo entered against you in the above-captioned case as follows: ing Judgment was Principal plus interest through July 18, 2003: Interest from July 18, 2003, through March 15,2005: Attorneys' fees: Total Judgment: $ 16,210.76 $ 1,363.50 $ 2.055.00 $ 19,629.26 Costs of suit and interest accruing at $2.25 per day from March 15,20 5, shall be added to the Judgment for Defendant's failure to file an Answer to the Complaint. Prothonotary I hereby certify that the name and address of the proper person to recei e this notice under Pa. R. Civ. P. 236 is: Mr. Glenn A. Romero 41 Jefferson St. Lynn, MA 01902 MARTSON DEARD9~FF WI LIAMS & OTTO Date: March 16,2005 By David R. Gallowa Attorneys for Plaintiff