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F \FILES\DA T AFILEIDickinson College 7619\DickinsonCollegeCol1ections7619C\Documents\223-com] . wpdldrg
Created4/28/03U4:03PM
Revised: jll4/0311:27:00AM
7619c.223
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NO.03- ..5'"8'09
CIVIL ACTION-LAW
DICKINSON COLLEGE,
Plaintiff
MELINDA FOUNTAIN-KMAN,
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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE:
Cumberland COlUlty Bar Association
32 South Bedford Street
Carlisle, Peffilsylvania 17013
Telephone (717) 249-3166
Dated: November 4, 2003
~ARTSON D~F \,\'ILLIAMS & OTTO
~;~/ ..-UL.1(
'-l5avid R. Galloway, qui e
1. D. Number 87326
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NO. 03- S807
CIVIL ACTION-LAW
DICKINSON COLLEGE,
Plaintiff
MELINDA FOUNT AIN-KMAN,
Defendant
JURY TRIAL OF TWELVE DEMANDED
COMPLAINT
AND NOW, comes Plaintiff Dickinson College by and through its attorneys, MARTS ON
DEARDORFF WILLIAMS & OTTO, and hereby avers as follows:
I. Plaintiff Dickinson College is a Pennsylvania educational institution and nonprofit
corporation with its principle place of business at West Street, Post Office Box 1773, Carlisle,
Cumberland County, Pennsylvania 17013.
2. Defendant Melinda FOlUltain-Kman is an adult individual with a last known address
of 1018 Dogwood Lane, Enola, Cumberland County, Pennsylvania.
3. On or about May 23, 1988, Defendant entered into a Promissory Note - Federal
Perkins Loan Program (Note #1) with Plaintiff for the financing of$2000.00 plus interest and costs
by Defendant on her own behalf, for educational services and benefits at Plaintiffs institution. A
copy of Note #1 is attached hereto as Exhibit "A."
4. On or about December 15, 1989, Defendant entered into an additional Promissory
Note - Federal Perkins Loan Program (Note #2) with Plaintiff for the financing of $600.00 plus
interest and costs by Defendant on her own behalf, for educational services and benefits at Plaintiff's
institution. A copy of Note #2 is attached hereto as Exhibit "B."
5. Note #1 and Note #2 are finlds 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 finlds associated with the programs lUlder the Act.
7. The total principal for Note #1 and Note #2 is $2,600.00.
8. Note #1 and Note #2 grant Plaintiffreasonable collection and attorney's fees which
Plaintiff has calculated to be $500.00.
9. As of October 23,2003, the principal and interest due and payable by Defendant to
Plaintiff was $4,248.10, plus interest accruing thereafter at $.32 per day.
10. As of October 23,2003, the outstanding balance of$4,248.1 0 represents the total and
actual overdue value of the financing provided to Defendant lUlder Note #1 and Note #2 for which
Defendant has yet to pay.
11. Plaintiffhas fulfilled, performed and complied with all obligations and conditions of
Note #1 and Note #2.
COUNT I
BREACH OF CONTRACT
12. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 11 ofthis 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 amolUlt of$4,248.1 0,
plus interest accruing at $.32 per day from October 23, 2003, collection and attorneys' fees in the
amount of$500.00 and costs of suit.
COUNT II
IN QUANTUM MERUIT
14. Plaintiff hereby incorporates by reference the averments contained in Paragraphs I
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 October 23,2003, the total amount by which Defendant has become enriched
is $4,248.10, plus interest in the amount of$.32 per day from October 23,2003.
WHEREFORE, Plaintiff demands judgment against Defendant Melinda F ountain- Kman in
the amolUlt of $4,248.10, plus interest in the amolUlt of $.32 per day from October 23,2003,
collection and attorneys' fees in the amount of$500.00 and costs of suit.
Date: November 4, 2003
NDSL - TRUTH~IN-LENDING STATEMENT
DICKINSON COLLEGE
Account Number
2372-07
Name of Bono...er
Melinda Marie Fountain
Address
126 Charles Street
Torrington, CT 06790
ANNUAL PERCENTAGE
RATE
AMOUNT FINANCED
The cost of your
credit as a yearly
rate.
The amount of
credit provided
to you.
Prior to
repayment:
During
repayment
o %
5 %
$ 2000.00
I Itemization of the Amount Financed: $ 2.000.00
Amount given directly to you.
Late Charge: If a payment is late, you may be charged: $1.00 for the first
late payment, and $2.00 for each subsequent late payment if
this loan is payable monthly, $3.00 for each late payment if
this loan is payable bimonthly, $6.00 for each late payment
if this loan is payable quarterly.
Prepayment: If you payoff early, you ...i11 .!!2.t have to pay a penalty.
See your promissory note for any additional information about nonpayment, de-
fault, any required repayment in full before the scheduled date, and pre-
payment.
THE BORROWER ACKNOWLEDGES RECEIPT OF AN EXACT COPY OF THIS STATEMENT.
STUDENT,;. (-c' /( i INSTITUTIONAL
BORROWER .;/ .<: -// ]'1;f-i____......",..-REPRESEN/TATIVE
DATE ~.y/. 'J 7 q ---- DATE f 23/8.5
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U1\.._hll".)Ul~ I...,ULLL:.l.Jt:.
CARLISLE, PENNSYLVANIA 17013
PROMISSORY NOTE
PERKINS LOAN PROGRAM
~(Q)lPu
I, __-lie l i nd~ Marie FQunt~i n promise fa par 10
Dickimon College (herein afler ~;llIed the Lending Inslilution) localtd at Carlisle, Pennsylvania the sum of the amounts lhal are advanced 10
me and endorsed in the Schedule of Advances set forlh below. I promise to pay all allomey's fees and olher reasonable collection COSfS and
chargeS necessary for ttle colleclion of any amoUnl nOI paid when due.
I furlher understand and agree thac
I. GENERAL
(I) Aoelicable law. All sums adwnced.under this nott are dfilwu from a tund created under Part E of TIlle rv of the Higher Educalion Act at 196..~, as
amended, hercinafler called the Act, and are sUbjecl 10 the Act and lhe Federal Regulations issued under the Act. The terms at Ihis note shall be inler-
preted in accordance wilh Ihe Acl and Federal Regulalions, copies at which are 10 be kepI by the Lending Inslilulion.
(2) Procedures for Receivini Defel1llenl or Cancellafion. I undersland lhat in order 10 receive a defcnnenl or cancellalion, I must request 'he detemlcnl Or
canceJlalion in wriling from the Lending Instilulion, and musl sllbmil 10 Ihe Lending InSlitution any documenlation requin:d by lhe L..cnding Inslilulion 10
prove that' qualify for the defermellt or cancellation. I tunher understand lhal it I am eligible for defermenl or cancellation under Articles Vllhrough XI, J
am responsible for submilllng the approprialc requem on time. I tur'fh/:r understand lhat , may Iou my delerment and cancellation benefits it I fail to file
my request on time.
II. lNIeREST
Interest shall acctue trom the beginning o( the repayment period and shall be atlhe ANNUAL PERCENTAGE RATE Of flYE PERCENT (5%) on
lhe unpaid balance, except that no inleresl shall accrue during any defermenl period described in paragraph VI(1).
111. REPA YMENf
el) f promise 10 repay the principal and the inlerest which accrues on it to Ihe Lendillg Inslitutioll over a period beginning 9 monUts alter the daie ! cease to
be at least II half-time student al an inslitloltion of higher education, or al a companlble instilution outside the United States approved tor th.is pMrpo6C by the
United Stales Secretary-of Education (hereinafter calke! the Secretary), and ending, unless paragraphs 111(4), 111(5), 111(7), or Vl(1) applies, 10 years laler.
(2) Upon my written ~quesl, the repayment period may SIan on a date earlier lhan Ihe onc indicated in paragraph 11I(1).
(J)(A) 1 promise 10 repay the. principal alld interest over the course of the repayment period in equal monlhly, bimonthly or quanerly ins.allmenll as deler_
mined by the LendIng lrlSlilullon. 'undeC$land lhal if my monthly paymenl for all the loans made 10 me by lhe Lending Inslitulion is nOI a multiple ot 15,
the L:nding Illslitvlion may round thai p~ymenlto the next highest dollar amovnllhat is a multiple ot $5.
(8) Notwithstanding pangraph JII(3)(A), upon my written request, repaymenl may be made in gradualed installments in accordance with a schedule ap.
proved by the Secretary.
(C) The Lending Inslitution shall allach the. schedule of fCpilyments al1d the schedule will become pari at .he nOte.
(4) Nolwilhstanding paragraph m(l), if I qualify as iI low-income individual during lhe repayment period, lhe ~ndini InSlitution may, upon my wr1llcn re-
quesl, extend Ihe rcpa)'nlelll period for up to an addilionallO years, or adjllst any repaymenl schedule to reneel my inCOme, or both.
(5)(A) If lhe monthly ratc: Ihat would be eslablished under paragraph lII(t), or lhe lolal mon'hly ~payment rate of principal.and inlerest on all my Perkins
loans including Ihis loan, is Ie" Ihan $30 per month, r shaU repay the prillcipal and interesl on Ihi.5 IQ.iln iltlhe rate of $30 per mOllsh (which includes bOTh
principal alld illlereSI).
(5)(8) It I have received Perkins Loans from other instilulions and lhe lotal monlhly repaymelll nlte on those loans is Ie" than $30, the S30 monlhly rale e$.
tablished lInder subparagraph JlI(5)(A) is the rale l pay on all my outslallding Perkins Loan. ilnd is not in addition 10 the amount I pay on thO$C other loans.
The amourH of my monthly repilyment rale auributable to this loan is lhe amount which represents the ditterence between ,$,30 and lhe mOn/My nles ( m.USl
pay on my other Perkins Loans.
(6) The Lendini InSlitulion may pctlllil me 10 pay leu lhan the nile ot $30 per mOnlh for a period at not mote tnan one year whet<: l\CCessaI)' 10 avci(!
hardship to me unless Ihal action would e~lend rhe repaymelll pcrioo in paragraph m(l).
(7) The Lending Institution may, upon my wntlen requesl, reduce any scheduled repaymenlS or extend lhe repaymenl period indicated in pill'l11p3.ph 11I(1),
if, In ilS opinion, exIJ110rdinary circumslallces such as prolonged lllnesa or IInemploymenl, prevent me from making the scheduled rep.l1ymenU. H<-evc:r, in>
lerest shall continue toaccroe.
IV. _PREPAYMENT
(1) I may, at my option Illd wilhoul penallY, prepay all or any part of the principal, plus the accrued intel'U1 then:on, at anytime.
(2) Amounts I repay in the academic year in which lhe Joan w;!s made will be used to reduce the l!imOlolnt ot lhe loan and....;U nOl be considered a prepaymenl.
(3) It I repay more Ihan Ihe amount due for any inslallment, the excess will be uud to prepay prillcij.'lal ulllesa I desip'ate il as an adv3nce payment of the
next regular in.staJlmenl,
V. DEfAULT
(I) The Lcndinllnstilulion may, at its oplion, declare my loan 10 be in default and may demand immediate paymenl of the enlire unpaid balance of Ihe
loan, incl\lding principal. intere5l, and late charges if -
(A) I dO nOI make a'scheduled payDient when it is due, and
(8) I do nOI stlbmil to Ihe Lending 'ru;tilution on or before the date on which payment is due, documenlation that' qualify for a defetlllent or cancellalion
described III ArticleS VI, VII, VlII, 'X; X, or Xl of this agreement.
(2) I understand th~t it I detault on my loan repayrnenlS, the Lending Instilution may disclose that I have defallltcd, along will' olher relevant informalioll, to
credil bureall organiulions.
(3) Further, I I,lnderstartd lhllt it I default on my loan repayment and lhe loan is sent to the Sec:relal)' for COJleClion, the Secrelary may disclose lhat I have
delauhed, along with other relevant information, to credit bureau ors:allilillions.
(4) 'ufldc:rsland that if the Lending Institution accelerales lhe loan under paragraph V(l), I will lose my cancellaliolland determent be(teUts for sctvice per-
tormc:d atter the date the Le(tqill& Instilutiort accelerated the loan, .
(5) I utl(:lerslartd that failure 10 pay Ihis obligation under Ihe lerms agreed upon will prevent ~y obtaini~g add/Ilonal sluden! financial aid authoriud under
Title IV 01 the Higher Education Ad 01 1965, as amended, until 1 have made arrangements which arc 5alldactory to the l.endinglnslltution or Ihe Secrelary
regarding the repayment at the loan.
VI. DEFERMENT
(1) 'nlere,1 will not accrue, and inSlallme,lls at principal need not be paid.
(A) While I am enl'Qlled and in allendance as al least half.lime student al an institulion at higher educalion or at I Comparable institution outside the
Uniled Stales approved for this purpose by the Secretary;
(8) For a period of three (3) years dllring which J am .
(i) On tull-time aclive duly as a member of .he Armed Forces of Ihe Uniled Slales (Army, Navy. Air fotce, Marine Cotp', or Coasl Guard) 'or the Na.
tional Oceanic and Almospheric Administration Corps, or as an officer on fulj.[ime active duty in lhe Commissioned Corps at the United Slates Public
Health Servicc:,
(ii) III service as a voluntetr under t/le Peace Corps Act,
(Hi) A volunteer under lhe Domesti~ Volunleer Service Acl ot 1973 (AcnON programs),
. ~j~) A fuU:li~e ~lunt~~r_~~ a Ilu-e"empl organizalion perfotllling service comparable 10 the service performed in Ihe Pelce Corps or under Ihe Domu.
. ,:..,....;,.:.v. .........~" .-....~. "'. '"I'~,"'i
(v) 'Temporarily totally disabled as established by an afrtdavit 01 a qualified physician, or unable 10 seCllre employment because I am providing care tc-
quired by a dependent who is $0 disabled;
(C) for a period not in excess ot two (2) yeal'l> after I receive a baccalaureale or professional degrell during ...hich time I am servinn in In intemship which
is required in order lhat I may receive pr:>fo:ssinnal rec~g!lition requir~J lu b~gin lTly !,rofessioMf practice or service, or serving ill an inl,,""'~hir or resirt..'lry
program lea"ing to a degree or certificale awarded by all inslitution of higher edllcaliOll, a hospital or a heallh care facilily that oflerS poslgraduale Il'3injng;
(D) For a periOOIlOt in excess of one (1) year during which f as a mother of preschool age Children, who has enlertd or reentered Ihe work force, am
being paitJ at a rale which does 1101 exceed $1.00 i1bovc: the minimum hourly wage establiShed by section 6 ot lhe Fair Labor Sfandards Acl of 1938;
(E) for a period not in excess of six monlhs it..
(0 ram pregnanl, caring for my newborn baby, or caring for a chj/d immediately aller he or she was placed wilh me through adoplion and' am nOI al-
lending an eligible instilUlion of higher education or beina gainfully employed during lhe sbe mOlUb period, and
(ii) I _s enrolled ilS at lellSt III half-lime student at an eliaib1c inSlillllion within sOe monlhs of lhe first day of lhat period; Inti
(f) DlIring a SU: (6) monlh period lollowing the expiralion of any defermenl provided in paragraphs Vl(l)(A) through VI(I)(E).
(2) The Lending Institulion may, upon my wriuen request, defer my sCheduled repayments it it detenTlines that lhe defennc:nt is necessary 10 avoid a (inan-
dal hardship for me. tllleresl, howtvc:r. will continue: 10 accroe:
VII, CANCELLATION FOR TEACHING
(J) I am entilled 10 have up 10 100 percent of lhe amollnl of lhis loan pillS rhe inlerest therC:OIl cancelled if I undertake serV1ct -
(A) As a fulHime leacher (or a comf'lele academic year in a public Or olher nonprofil elementary or $econdary school which is in lhe $(hool district of a
local educational agency which is elirJplt in such year of service for tllnds under Chapler I of lhe Education Consolidalion and ImprOVCmenl Acl of 1981, lIS
amelnded, and which has been designated by the Secretary (after consu/talion wilh each Slate Deparlment of Educalion) in accordance with the pmvisiottl o(
section 465(a)(2) of lhe: Act as II sch.ool with a high concentratioll of studtnlS (rom low_income families. An official Directory ol design3lc:d low-income
schools is pllblished annually by the Secretary.
(8) A3 a full-time teacher ot handicapped children (including mentally relarded, hard of htaring, deaf, speech and language impaired, visually hand-
icapped, .seriollsly emotionally diSfurbed, orthopedically inlpairc:d, children wilh specific learning disabililies, or olher htallh.impairc:d children, who I:ty reason
(~~r~or T~'lUlr~ ,sp:'ci.afeduc~l~'~~ ayd rel~lcd .Icrvjc~5) in a public or oilIer nonprofit clemerllary or s<:condary $ChCJol sysl(:m,
(2) Tll.is l(l<l(l will ~e:e3nce;l\l'dallpj rtllJrJWing roles:
(A)' is percellt p(the~la~paJ <lmCll.ot of Ihe IOarl pIlls interest olllhe unpaid IJalanl:"e will be cal1C<::lIed for the nrst and second complete academic
yeats.Q('!halle3chil1gsc~ce,
(13) 20 p<:rccnl of the talal principal amOUJlt plus :nrer(!st on t/le unpaid balance for the third and (ounh complete academic yean of Ihalleaching service,
(C) 30 pc:'rtenl of lhe total principal amoUI,1 plus inrer~st olllhe unpaid balance {or the fifth complete academic year of that leaching servlce.
VIII. HEAD START CANCELLATION
(J) I am enlilled 10 have up to 100 percent of lhe arnOUII! of Ihis loan plus the inleresllhen::an canalled j{ I undertake service as a (ull-time staff mc:mbe( in
a Head Stan program if.
(A) That Head Slart program is opc:raleo for a p<riod which is comparable to a full school year in the locality, and
(0) My salary is not more than the s.alaryof a comparable employee of the local educational agenl.)'
(2) Tbis loan will be cancr:Jled at the rate of 15 perccnl of the total principal amount plus intereu on Ihe unpaid balance for each complete 5Chool year or the
equivalent of service in a Head Stan program.
(3) Ilead Stan is a presehool program carried 01,11 under the Head Start Act. (Subchapte' B, Chapter S o{olle VJ o{ Pub. 1.. 97-15, the Budget Recondlia-
ti<:ln Act of 1981; formerly authorized under section 222(a)(1) o{ the P..conomic Opponunity Act of 19(4).
IX, MIUr ARY CANCEU.A nON
(1) I am entitled 10 have up 10 50 pen:ent o{ the principal amount of this loan plus the intereSlthereon cancelled if I serve as a member of the Anned Forces
of the U~ited StateS in an area of hostilities Ihal quafilies fat special pay under section 310 of Tille 37 of the United States Code.
(2) 1l1is loan will be cancelled al the t3te of 12 1(1. flercent o{ the totlll principal amount plus interest on Ihe unpaid balance for each complete year of such
service.
X. PEACE CORPS CANCElLATION
(I) I am entilled 10 have up 10 70 perteRt oC Ihe amount of this loan plus the: interest thereon cancelled if r undenake serviee-
(A) N a volunteer under the Peace Corp6 Act; or
(n) A~ a volunteer under the Domestic Volunteer Service Act of 1973.
(2) This loan will be cancelled at the {ollowing rates:
(A) 15 percent or the tOlal principal amoullt of the lOan plus interest Oil the unpaid balance will be cancelled {or the first and second twelve-month period
ofvolunteerservicei
(8) 20 percent of the total principal amount o( the loan plus interest on the unpaid balance will be CJInc:clled (or the thitd and founh twc:lve-moruh period
or volunleecSGMce.
XI. OEATIJ AND DISABILITY CANCELLATION
(1) In the even! o{ my death, the totalamo\lnt owed on thi, loan will be eancelled.
(2) If I become 101a.lly and permanently disabled after I receive ,his loan, the lending Institution will cancel the total amount of Ihi! 1000n.
xn. CHANGE IN NAME. ADDRESS, TELEPHONE NUMBER AND SOCIAL SECURITY NUMBER
I,am responsible, and any endorser is responsible, for informing lhe Lending Institution of any change or ehanaC5 in nan1e, addRss, telephone number or so.
clalsecuritynumber.
XIII. LATE CHARGE
(1) The lending Institution may impose I late charge j(_
(A) I do nOI make a seheduled payment when it is due, and
(D) I do not submit 10 the lending Institution on or before the date on whJch payment is due, documentation that I qualify for a deferment 0' l.'ancellation
described ill Articles Yl, VII, VIII, IX, X, and Xl of Ihis agn!ement.
(2) No chafge may exceed twenty (20) pereenl of my mOnthly, bimonthly or qual1erly paymenl.
O)(A) The Lending InSlit",tion may..
(i) Add the laIC charge to the principal the day a{ler the scheduled repayment was due; at
(ii) Include it with Ihe next scheduled repaymentafler I have received notice of the late charge.
(B) Iflhe Lending Institution elects to add the assessed charge to the outstaMini principal of Ihe loan, it must 50 in{onn me before the due: datt of the
n<<xtinstallment.
XIV, ASSIGNMENT
(1) This note !l\ay be assigned by the lending InsliJutiOF'l only to.
(A) The United States;
(B) Another inslicution upon my transfer 10 that institution if that institution is partieip.ating in Ihis program' or
(C) AnOlher institutioll approved by the Sectclary. '
(2) The provisions of this nOte Ihal relate to Ihe lending Institution shall, where appropriare, relate to an assignee.
XV. I'RlOR LOANS
I hereby certify thai I have: lined below all of Ihe Perkins I..p,qns I havc obtained at other instilutions. (ll no prior loans havc been rt:ceived, stale "None.")
SCHEDULE OF PERKINS LOANS AT OrnER tNSnnmONS
AMOUNY'
DATE
NAME OF INS1l11.fIlON
I.
2.
3.
4.
. . XVI. SCHEDULE OF ADVANCES
fhe follOWlng amounts were advanced to me under this loan agreement on the dates indicated;
AMOUNY'
1. $2000.00
DATE
5/1/88
l' AWl\E o,.,ft
./ /1 ..-
...0 ( ;..' "---.
/
1.
3.
4.
NOTICE TO BORROWER: 0<2 NOT SIGN nus NOTE BEFORE YOU READ IT TIlE LENDING INSlTTUnON MUsr SUPPLY TO
YOU AND ANY 10RSErA COP'!.,. 07' TIliJ's ~ (Ilus note is signed as a Sealed instrument)
"L . -. J
SlGNA11JRE ,c>---".- . ;- -~ '? I _,
, ~- ~ _ D..< .J /~ Jj 19~.
re~llnent~d.1resf(StreetorBoxNUmbl:'CI{y,Sla ,an.dZip) I :ZL-.., (her-If') ,,/.ri--~ .1;'r-r--;,,; fO'-1/ (T '
SocIal Secunty Number (borrower must provide) (')'j.-S -- (~-. 3s:;.:>.c. C)6 ?'1C">
The bOrTOWer and Lending Institution Shall CJtecute this note wilhout security and withc.llt d I ".
not, under Ihe law of the Stale in whieh the Lending Institl,Hion is located create a bindin en b~~~ent ~F ~ss the bo~r IS.I mInor an~ thIS note would
therefore, be legally hinding, the lending Institution shall require a c05igne; to this nole: go 19atlon. t e borrowe:rls a mrnor and thiS note WlJIJld not
SIGNATURE OF COSIGNER
Date
19___.
Permanent Addrels (Street or BQx Number, City, Stale, Zip)
(20 U.S,C, J087dd)
(7/81)
Fonnat by the National Association of Studenl Financial Aid Administtlltors.
PERKINS (NDSLJ TRUTH-IN-LENDING STATEMENT
DICKINSON COLLEGE
Account Number 000-00-2372-07
Name of Borroyer
Melinda M. Fountain
Address
70 W. South St., Apt. #1
Carlisle PA 17013
ANmJAL PERcnrrAGE
RAn:
AMOUN'! FINANC1'.:D
The cost of your
cred~t as a yearly
rate.
The amount of
cred~t provided
to you.
Prior to
repayment
During
repayment
,
o %
5
%
$ 600.00
I Itemization of the Amount Financed: $ 600.00
Amount given directly to you.
Late Charge: If a payment is late, you will be charged: $1.00 for the first
late payment, and $2.00 for each subsequent late payment if
this loan is payable 1l1Ot1thly, $3.00 fol:' each late payment if
th~s loan is payable bimonthly, $6.00 fol:' each late payment
if th~s loan is payable quarterly.
Prepayment: If you payoff eal:'ly, you viII ~ have to pay a penalty.
See your promissory note for any additional information about nonpayment, de-
fault, any required repayment in full befol:'e the scheduled date, and pre-
payment.
STUDENT ( 1 /7
BORROWER Pj ~_/ I
DArEl~! I ')/~
THE BORROWER ACKNOWLEDGES RECEIPT OF AN EXACT COPY OF THIS STATEMENT.
.------7 -A. INSTITUtIONAL ~
/ ./ ~RESEN1'A1"I~~..J:n-~' 7 <'----
DAn: / t. ! I ) 1 Ii
DICKINSON COLLEGE COfY
Cdrl;sle, PA 17013
Tel: 717-245-1383
PIWMISSORY NOTE - PERKINS LOAN PROGRAM
[Any bracketed clause or par.lgraph mal' be included at option of institution,]
I, Mp linda..JL__.Lo.un.t.aiI1-~_ promise to pay to Di ckinsillL.G..all PgP (hereinaHer
called the Lending Institution) located al.J:at:.lis..le.,.-Eenns.~1.w..an i .::l the sum at the amounts that are advanced to me and en.
dorsed In the Schedule of Advances $sl forth below. I promise to pay all altorney's fees and other reasonable collection costs and cl'1arges necessary for tna
collection of any amount not paid when dUG. I further underSlant1 and agree that:
I. GENERAL
(1} Aoolicabrlll aw All sums advanced ...mder this note ars drawn tram a fund created under Part E of Tille N of the Higher Education Act of 1965, as
amended, hereinafter called the Act. and afe ,subject to the Act and the Federal Regulations issued under lhe Act. The terms althis note shall be Interpreted in
accordance with the Acr and Federal Regulations, copies of which are to be kept by the Lending Institution.
(2) Procedures for Aeceivino Deferment or COincellation I understand that in order to receive a delerment or cancellation, I must requestlhe deferment or can-
cellation in writing from the lending lnslilulion, and must submit to the Lending Institution any documentation required by thlf lending Institution to prove that
i qualify for the deferment or cancellation. I lurther understand that if I am eligible lor deferment or cancellation under Articles VI through XI, I am responsible
for submitting the appropriate requests on time. Ilurther understand that I may iose my deferment and cancellation benefits if I fail to lile my request on lime
IL INTEREST
Interest shall accrue Irom the beginning of th(f repayment period and shail be at the ANNUAL PERCENTAGE RATE OF FIVE PERCENT (5%) on the unpaid
balance, except that no interest shall accrue during any defermenl period described in paragraph VI(l).
ilL REPAYMENT
(1) I promise to repay the prlncipaf end the interest which accrues on it to the lending Institution over a period beginning 9 months efter the date I cease to be
at least a half-time swdent al an institution of higher education, or at a comparable institution outside the United States Jpproved for tnis purpose by the
united States Secretary of Educalion (nereinalter called the Secretary), and ending 10 yesrs later, unleu that period is shonened under paragraph iII(S), or ex-
tended under paragraphs JU{'l), 111(7) (extensions), or VI(1) (deferments).
(2) Upon my wriuen requesl, the fepaymenl period may start on a dale earlier than the one indicated;n paragraph 111/1).
(3} (A) I promise to repay the principal and int/Hest over the COUf$e of the repayment period in equal month IV, bimontnly or quarterly installments, as deter-
mined by the lending Institution. I understand that il my monthly payment for all the loans made to me by the lending Institution is not a multiple 01 $5, the
Lilnding Institution may round that payment to the next highest dollar amount that is a multiple 01 $5.
(8) Notwithstanding paragraph IIl(3){A), upon my written request, repayment may be made in graduated installments in accordance with a schedule
approved by The Secretary
(C) The lending Institution shall attach the schedule of repayments and the schedule wilf become part of the note,
(4) Notwithstanding paragraph 111(1), It I qualily as a low-income Individual during the repayment period, the lending Institution. upon my written request, may
extend thEllepayment period for up to an additional 10 years, and may adjust any repayment schedule to reflect my Income.
[(5)(A) It the monthly rate that would be 8stab!ished under paragraph 111(11, or the total monthly r8payment rate at principal and interest on ell my Perkins
Loans including this loan, is less than $30 per month, 'shall repay the plincipal and int8resl on this loan al ths rate of $30 p8r month (which includes botn prin-
Cipal and interest).
(5) (8) If I have raceived Parkins loens Irom other institutions and the total monthly repayment rate on those loans is less than $30, the $.30 monthly payment
established under subparagraph III(S)(A) includ~sthl) amounts I owe on all my outstanding Perkins Loans Including those received Irom othllr Instit~tion$. The
amount of this $30 monthly payment thai will be applied to this loan 1'.'111 be the dlHerence between $30 and the total of the amounts owed at a monthly rate on
my other Perkins loan/l. .
(6) The Lending InstitutiotllTlay permit me to pay less than the rale 01 $30 per month lor a period of not more than one year where necessary to avoid
hardship to m8 unleslil that action would extend tho repayment period in paragraph Hlll)_]
(7) The lending Institution may, upon my wrill(fn request, reduce any sched~led fepeyments or e.tend the repayment period indicated in paragraph 111(1), if,
in its opinion, extraordinary circumstances such as prolonged illness or unemployment, prevent me Irom making. the scheduled repayments, However, intl;lr-
e;;t shall continue 10 accrua. .
IV. PREPAYMENT
(ll I may, at my ootion and without penalty, prepay all or any part 01 the principal, plus the accrued interest thereon, at any time.
(2) Amounts I repay in the acadtlmie 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 eny installment, the excess will De used to prepay principal unless I designa~e it as an advance payment of the
ntl.dreg~larinstallment.
V. OEFAULT
(t) The lending Institution may, al its option, declare my loan to be in default and may demand immediate payment of the entire unpaid balance of the loan,
inCluding principal, int8rest, late charges and collection costs il--
(A) I do nOI make a scheduled payment when due under the repayment schedule established by the lending Institution, and
(B) I do not submit to the Lending InsUlution on-or before the date on which payment is due, documantation that I qualify for a def8fffltlnt or cancellation
described in Articles VI, Vii, VIII, IX, X, or XI of this agreement.
(2) I <,Jnderstand that If I delault on my loan, the lending Institution may disclose that I have defaulted, along with other relevant inlormation, co credit bureau
organizations.
(3) Furll1er, I undersland t/'lat if I defaull on my loan and the loan is translerrad to the Secretary lor collection, the Secretary may disclose tnat I have defaul1ed,
along with othtlr relevant information, to Cfedit buraau organizations_
(4) I understand that after Ihe lending Institution accelerates the loan under paragraph V(l), I will then lose my right to defer repayments due alter the date
the lending lnstilution accelerates the loan,
(5\ I understand thai atter the Lending lnslitution accelerates Ihe loan under paragraph VOL I will then lose my rlghl to receive a cancellation of a portion 01
my loan lor any teaching, volunteer or military service described in .Anicles VII, VUI and IX, perlormed after the date Ihe lending Institution accelerated the Joan
(6) I understand thai 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 I have made arrangements which ar8 satisfactory to the lending Institution or the Secretary
regarding the repayment of the loan.
VI. DEFERMENT
(11 i understand thai upon making a. prOperly documented wriUEln reqU8st to the lending Institution, I may defer making schedul8d installment payments, and
will n<Jt be liable for any interest l/1at might otherwise accrue, during the lollowing periods;
(A) While i am enrolled and in att8ndance as at leasl a halHime sludenl al an institution ot higher education Of at a comparable Institution outside the
United SlateS approved for this purpose by the Secretary:
(8) For a period 01 three (3) years during which I am -.
(i) On full-time active duty as a member 01 the Armed Forces of th8 Unlled States (Army, Navy, ftjr Force, Marine Corps, or Coast Guard) or the
Nallonal Dc.anie end Atmo/lpheric Administration Corps, or as an oHicer on lull-time active duty In the Commissioned Corps 01 the United States Pupllc
Health Service,
(ii) In service as a volunteer under the Peac8 Corps Act,
(ill) A volunteer under the Domestic Volunteer SeIVice Act of 1973 (ACTION programs),
(iv) A full-lime volunteer In a tax-exempt organization performing service comparable to t/'l8 service perlormed In the Peace Corps or under the
Domestic V.;.I\.i(ltaer Sarvi;;;... ;"c1 1,0; 19/3,....,
(vI Temporarily totally disabled as established by an affidavit of a qualified physician, or unable to secure employment because I am providing care
'''0'~;r2~ !;l" a dzper.dc:r.t who i::l ..,:; ~i.i..u!..(i:
'(e) for a periOd nOI in exce$S of two (2) yeers-
(i) After I receive a baccalaureate or professional degr8e during which time I am serving in an internship whlcn is required in order Ihal I may receive
professional recognition required 10 begin my professional practice or sarvice, or
(il) serving in an internship or residency program ieading to a degree or cert!licale awarded by an institution of higher Elducation, a hospital or a health
care facility that offers postgradUate !raining;
(D) For a period not in excess of one (1) year during which, if t am a mothef of prllSchool age children, I have entered or reentered the work lorce, and am
being paid at a rate which does nol exceed $1.00 above Ihe minimum hourly wage established by seClion 6 of the Fair labor Standards Act 01 1938;
(E) For a period not in excess of six months--
(II That follows by six months or less 01 a peliod during which I was enrolled as alleasl a half-lime Sludent at an eligible institution; and (ii) During
which I am pregnant. caring for my newborn baby, or caring for a child immediately aher tie or she was placed with me through adoption and I am neither
attending an eligible institution of higher education nor galnlully employed: and
(F) During a six (6) month period immediately following the expiration of any deferment provided in paragraphs VI(I)(A) through VI(l)(E).
(2) The lending Institution ma.,., upon my wrltlen requesl, deler my scheduled repayments il il determines that!ne deferment is necessary 10 avoid a financial
hardship lor me. Interest, however, will continue to accrue,
VII. CANCELLATION FOR TEACHING
(1) I understand that ~pon making a properly documented written request to !ne Lending Instilution, I am entitled fO have up to 100 percent of the amount of
tllis loan pius the interest thereon cancelled if I perform service >-
-07
,'~1If j' ))
(Al As a fUJI-tiMe teach+Jn~~er nonprofit elementary or secondary school which is in the school district of a local educational agency
which is eligible i~' such year 01 service lor funds under Chapter I of 1he Education Consolidation and Improvement Act at 1981, as amendttd, and wnich has
been designated by the Secretary (atter consultation with each Slale Department 01 Educ;1.tion) in accordance wllh the provisions of secUon 465(;1.)(2) of Ihe
Act as a school with a high concentration of students flom low-income lamilies. AA official Directory of designated low-income schools Is published annuany
by the Secretary
(B) As a lull.time teacher 01 handicapped children (including those who are mentally retarded, hard of hearing, deaf. Ipeech and language Impaired,
visually handicapped, seriously emotionally disturbed, orthopedically impaired, halle spec1f1c learn!(lg dlsabllilles, or otherwise heallh-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 lor each completed year of teaching service at th& foHowlng rales:
(A) 15 percent of Ihe lolal principal amount of the loan pillS lolersst on Ih& unpaid balance will be cancelled for Ih. first and second complete academic
yurs of Ihat teaching servic&,
(8) 2.Q percent 01 the total principal amount plus Inlerest on the unpaid balance for the Ihlrd and fourth complele academic years of that teaching servloe,
ood
(C) 30 percent of Ihe total prinoipal amounl piuS interest on lhe unpaid balance for the fifth complete academic year of that leaching servioe.
VIII. HEAD START CANCELLATION
(1) I understand that upon making a properly documer1ted wrilfEJn request 10 the Lending Ins!itution, I am entitled 10 hays up 10100 percent of the amount of
this loan plus the interest thereon cancefJed if J perform seNice as a full-lime staff member in a Hllcad Start program if -
(A) That Head Start program is operated for a period which Is comparable to a full school year in Ihe locality, and
(B) My salary is not more than the salary of a comparable employee of the local eduoationlll agency.
(2) This loan will be cancelled al the rale of 15 percenl 01 the tolal principal amount piuS Interest on the unpaid balance for each complete sohool yeer or Ihe
equivalent of seNlos In a Head Start program.
(3) Head Slart is a preschool program carried out under Ihe Heed Slart Act.
IX. MILITARY CANCELLATION
(1) I understand that upon making II propll!lrly documented written request 10 the Lending Institution, I am entitled to have up 10 50 percent of the prlnolp"l
amounl 01 Ihisloan plus the interesl thereon cancelled If I serve as a member of the Armed Forces 0' Ihe Uniled Stales In an area 01 host/Hlies Ihat qualifies lor
special pay utlder sectiotl 31001 Title 37 of thll!l United Slates Code.
(2) fhis loan will be cancelled at Ihe rate of 12 1/2 percent of the 10laJ prIncipal amount plus Inlerest on the unpaid balanoe lor each complete year of such ser.
vice.
X. PEACE CORPS CANCELLATION
III I understand Ihat upon making a properly dooumenled written requesl to the lending instilulion, I am entitled to have up to 70 percent of the amounl 01
this loan plus the interest thereon oancelled if I pertorm ,erv1ce-
(A) As a lIolunteer under Ihe Peace Corps Act; or
(B) As a volunteer under the Domestic Volunteer Service Act of 1973.
(2) fhis loan will be cancelled at Ihe following rales:
(A) 15 percent of Ihe total principal amount of the loan plus Interest on the unpaid balance will be cancelled for Ihe flrsl and second twelve-month pericd
of lIolunteer service completed;
(B) 20 percent of Ihe lotal principal amount of the loan plus interesl on the unpaId balance will be cancelled for Ihe third and fourth twelvEl-monlh
period of lIolunteer servIce eompf&ted.
XI. DEATH AND DISABILITY CANCELLATION
(1) In the ellent 01 my death, the tolal amount owed on this loan will be oancelled.
(2) II J become tolally and permanently disabled aller I receive this loan, Ihe Lending Instftutfon will canoelthe tolal amount 01 this loan.
XII. CHANGE IN NAME. AODRESS. TELEPHONE NUMBER AND SOCIAL SECURITY NUMBER
I am responsible, and any endorser Is responsible, lor Informing the Lending In,titutlon of any change or chang's in name, address, telephone number or so.
cialsecuritynumber.
Xiii. LATE CHARGE
(1) The LendIng Institution may Impose a late charge II -
(A) I do nOI make a aehedule:d paymenl when It Is due, and
(8) I do nol ,ubmit to Ihe lending Insmution on or belore the date on which payment Is due, dooumentation thai I qualify lor a deferment or oancellation
described in Artloles VI, VII, VIII, IX, X, and XI Ollhis agreement.
(2) No oharge may exceed twenty (20) p&rc&nt of my monlhly, bimonthly or qUBrterly payment.
(3) (AI The lending Institution may-
(i) Add the lale eharge 10 the principal the day alter th& scheduled repeyment was due; or
(il) Include it wilh the next soheduled repayment alter I have received nollce of Ihe late charge.
, (8) 111I1e lending Inslitulion elects 10 add Ihe assessed oharge 10 the outstanding principal of 1M loan, il must so inform me before the due date of the next
Installment.
XIV. ASSIGNMENT
(I) This note may be assigned by the Lending Institution only to -
(AI The United States;
(8) Another Institutfon upon my Iransfer to that Instilution if that Jnstllullon Is participating in this program; or
(e) Anolher institution approved by the Seoretary.
(2) The provisions of this note: Ihal retate to Ihe Lending Institution shall, where approprlale. relal.to an assignee.
XV. PRIOR LOANS
I hereby certify that I have Jlst&d belOw all of Ihe Perkins Loan, I havs oblal".d at other Instllullon,_ (If no prior loans have been received, state "None.')
SCHEDULE OF PERKINS LOANS AT OTHER INSTITUTIONS
AMOUNT DATE INSTITUTION
1.
2
3.
4.
XVI. SCHEOULE OF ADVANCES
Th~~~,%~g emounls wer& advan~~~;: me under thiS loan agreement 07~dhA~~t;:O~~~7d w~
1 $600,00 12/15/89 / v<-' / . ______
/
2
3.
4.
NOTICE TO BORROWER- 00 NOT SIGN THIS OTE; BEFORE YOU READ IT THE LENOING INSTITUTION MUST SUPPLY A COPY OF THIS NOTE
TO YOU AND! COS~R [ThiS njOll as a sealed Instrument 1 I
Signature ~~ vi. ~ 1 I
"""1) Oat. \... 1..,- 'O.1ti...
Perman8l1tAd ess (Street or Box Number, Clty,Slate, and Zip Codej '70 t.-)t-t .:)O<.~..\..t.. A./-J. ~ I (ov-I.~\lL, fA \~,
SOOlal Security Number (borro~er must prOVide) C....q '"\ - C~;t. _ ,'X., ~~,--' '.'"'' I f'.J ~
The borrower and Lending Institution Shall execute this note without security and without endorsement unless th b r . .
~:~:~~~ey ~~~d~~olh~h:t~~nl~i:oh:~:,'I~.,.oL'",dh'"IO, Insti!lJllon is ~ocaled, oreale a binding obligation. If the borrower~s : ~o;:; ~~~ 7t::~~o~;~~~~dn~~~ ~::'~o~t,
, u I n a reqUIre a cosigner to this note: '
I agree 10 repay all amounts due on this loan if the borrower faiis to do so In accordance with Ihe terms 01 the note.
Signature Of Cosigner
[(seal)} Dale
19_.
Permanent Address (Stfeet or Box Number, Cily. State, Zip Code)
(20 U.S.C. 1087dd)
Formal by the National Associa!ion of Sludent Financial Aid Administrators, 5/BB.
PU:.\.'~T HET.\[:-"; Tl--IIS D()(T~IF.'T F'OH FCTl~HE REFERE.\:(T
,IF (.IIP)" rs XI'T.\c.HED PLEASE SIC.'\" .-\:-\D flETLIC\iI
NATION.-\!. DIRECT STUDENT LOAN REPAYMENT SCHEDULE AND DISCLOSURE STATEMENT
Loan Repayable To ni rk i n~on Co 111'91'
Account Number(s) or 043-62-3526
Social Security Number
Name of
Borrower
Melinda M. Fountain
Permanent Address
70 W. South St., Carlisle, PA 17013
Billing Address
Same
This sheet (1) summarizes the student loans which you have received from this institution, (2) provides an outline of the schedule you a.re to follow
repayment, and (;3) expla.ins your rights a.nd obligations concerning your loan. A copy of this sheet should be safeguarded and retained for fUtl
reference.
Until your loans have been repaid, it is your responsibility to keep your lending institution or the billing agent servicing your student 10
account informed of any changes in your billing address.
This statement recaps the regulations covering the repayment of your student funds disbursed to you under the National Direct Student Loan Progra
You must submit timely certification when requesting anyone of the benefits explained on the reverse side of this form.
(See further explanation on reverse side of this form.)
MAIL YOUR PAYMENTS TO: First Wachovia SFS, Inc.
P.O. Box 70095
Charlotte, HC 28272-0095
A, REPAYMENT TERMS
ANNUAL FINANCE Amount loan
PERCENTAGE CHARGE Financed Principal
RATE The dollar amount The amount of credit Balance
The cost" of your the credit will cost provided to you or on
credit as a yearly you. your behalf
rate_
5.000% $632.51 $2,600.00 $2,600.00
Total of
Payments
The amoul1t you will
have paid ofter you
have made all pay-
ments as scheduled.
Program Iloan
Number(sl
$3,232.51
00273-000-00-2372-07
-01
Your payment schedule will be:
r ::"0'~8::7; ~;;~~~ o~:~y~~;ts pmts.
Final pmt. of $22.51 3/2/91 4/23/91 Monthly
late Charge: If a payment is late. you may be charged for each loan: $1.00 for the first late payment. and $2.00 for
each subsequent late payment if this loan is payable monthly. $3.00 for each late payment if this
loan is payable bimonthly. $6.00 for each late payment if this loan is payable quarterly.
Prepayment: If you payoff early. you will not have to pay a penalty.
See your promissory note(s) for any additional information about nonpayment. default. any required repayment in
full before the scheduled date and prepayment.
IntereS1Accrues
Beqinninq
FirslPaymem
Do"
Frequency
of Payments
[Itemization of the amount financed:
$
$ 2,600.00
Amount Given Directly to You.
Amount Paid to The Institution on Your Behalf.
Federal Regulations require that you must repay your loan on a timely basis as called for in the repayment agreement which was mutually agreel
upon by you and your lending institution.
Should you he unable to make payment for any reason, you must contact the lending institution prior to the due date. Provisions of your promissor:
note may allow your loan to be subject to:
t) Scheduling of repayment in minimum monthly (or quarterly! installments which will result in the loan being repaid in less than the maxim un
ten-year repayment period.
2) Late charges a.s disclosed above.
.3) Payment of the total cost of collection and/or litigation if your account becomes past due and persists to be past due without appropriat,
arrangements with your lending institution to bring the account current.
B. LOAN SUMMARY (OPTIONAL)
Dates Received Amounts Dates Received Amounts Dates Received Amounts
$ $ $
$ $ $
$ $ $
THE BORROWERA. C.XNOWLE;UG S . ECEIPTOF AN.EX.ACTCOpy OFTH..ISSTAT.EMENT.
STUDENT .,./ /' 7 INSTITUTIONAL ;~)~ .
BORROWER ---l~L. \ ~_~ REPRESB:NTATIVE. I ........ic '--'. -,c'
DATE _S-!-lJ//--'i(;~m______- DATE r::. / -
.._,,,,.,__,_'?_"'4'.""~'p-.' ,.',Ie'
PERKINS (NDSL) STUDENT LOAN DEFERMENT REQUEST
/) (Use Ren'rse Side for Cancellation 0:- Postponement)
First Wachovia Use
I 1 () 1 I 'if l) i "'0.'", ."m"',
First Wachovl<J USl:
_~y,,,,,,,N\lm""r
I &~IO -,?-, /\ j:;'1,J
Na01C I *S'l<.:ia! S~,;urity No Prograrnl,1 and L,'an Numbcr(s) As Sh(IWn on Your Billing Stalemelll
/1'\21"'{' i'i r: II IC!~.i-._-Y;:-.;z~ Il)IL!,C,- I''',('':)'''-~I:<,'h,t
Addres~(Ap!.Slrecl) .1\ p: ~e~h~~~ss ~.
L-L.'J -,'_' 11.-... '"'Jl .--,.,\, ,. Check 0
CilY State Zip Day Telephone
(', ~.--\_ -,i._ ,7;-\ \ /(../ ~ 'f17' "1'1- bGC;t, 1 1 1 , " (\<
In..':!..lrull(m Which Gr:lnfed Loom Evenmg Telephone R . A!!t U6choV/a Stu.dent Flnancwl SerVIces. Inc. Ci' I \
\) ,( \< , ~... -, \ c' I \.~, ( \; () Pf'lO'~Salem, North Carolma 27/02 0
IF YOU NEED ADDITIONAL INFORMATION PjLENiE REFER TO YOUR PROMISSORY NOTE M~e8 ~~u MAY CALL
OUR OFFICE AT (919) 770-7351. , V I 'V UJ f:\~
Student Deferments: Student status deferment IS possible If you are atlendlng an institution of higher learning are ca n half-time or grealer c f s must be t'b'l.
mitted at least annually as long as you remain m student status. Your lendmg institutIOn may require that yo I ease s~r. 9uarter. etc. A student continumg his education
must Comple~ Sections A'.B. a~d ~ of the, form indicating ex~cted enrollment at the beginning of each Ch1 ar or emester epending upon the lending institution). ihe student
must also obtam proper certificatIOn U1 Section 0 from the registrar.
*Optional: Used to Verily Identity
All Other Deferments: Fonns must be submitted annually. The total length of time for which the status en in
~\'111~1.:I"''*'IIII'll'!1(:.,f,j.:I.'.:r.U'.I'"J>l'':r::Ii'I'=--:ImniT'lhl'''"=11.:f'I'.r~('l~IIIIII:.,f,ja
_ Deferment
Check one block for type of deferment requested.
(I) 0 Deferment by reason of military service, Peace Corps. VISTA. (3~yr. limit}
(2) [VIDeferrnent by reason of at least half-time student status.
The following deferments are ONLY for funds received after 9/30/80 and Perkins
Loans.
(3) 0 Volunteer service in a non-profit organization. (3-yr. limit)
(4) 0 Officer in U.S. Public HeaJth Service Commissioned Corps. (3-yr. Iim!t)
u (;) 0 Temporary Total Disability Borrower or Spouse. (J-yr. limit)
*'" (6) 0 Internship/Residency Program. (2-yr. limit)
The fOllowing deferments are ONLY for Perkins funds received after 6/30/87 and
have a 9 month grace period.
....* (7) 0 Temporary Total Disability of Borrower or Dependent. (3-yr. limit}
(8) 0 National Oc~anic and Atmospheric Administration Corps. (3-yr. limit)
....* (9) 0 Leave from school to care for newborn or newly adopted child.
(6-mo. limit)
n( 10) 0 Mother making les~ than $1.00 more than Federal Minimum Wage and
has pre-school age children. 02-mo. limit)
:....'-111.1..:1>1.1.1"""';('-1..
(BorT()lotler must FiJI in Dales)
I B~in~~g,.., And Endinlf
111I, I ~ Iii 10,.,1'1,01
- "'f:tiUf'I""'l""t;IIr:H'lf=--a;l,jr~1!'I.' ~r.
J declare that the information shown alxwe is lroe and accur-lIe. I funher declare t/'Iat I will IIOlify my
lender ('Or First Wachovia Student Financial Services. Inc. immedialely upon change in my staNS. I
{urtherunderstllnd thar if. for 3rJ)' reason. f am unable to complete the year of service for which I have
"qu;"'" d,renno"' "'",fi". I w:" be,i, """me", 01 my ~. ''''''di', d,re<<", ""m,"". ;m-
~/'l,-v1 1-1~ Date IO/I'i!??
.-Additlonal documentali,m!!!!ill ~omp.tny this lrm: See your Disclosure StIlkment or
\.... please call our ofrlce rOl;" !'urther inrormallon. ~ '-
NOV Q } \9&'
For First Wachovia Use Onl~':
Date Processed'
Last .' DigilS SEQ
I ):'7~~ I 0'1 AM ,,, IS
LS I O~6rg;1:11 161~ID<7,0 I
"I" Yr .\1,,_ \r
LLJ
I
LlslJ Digits
Pmg No
I
T}pc
U
Ikl!innlO>!Oalc
- I' 1
y,
Mo
I
U
u
For Lending Institution Onl~::
-: R~qu~~t Disapproved Deferment Approved ~DSL
I -. Sludent Status I
Mdllary S..::n'lo.:e I
I ~ ~~~:;A Cnrps I
Intcrnship
Perkins
Volumeer Servict;'
tN\m-ProlitOrganizalll1n
LIS Public Health S..::rvil:c
rC\1mmissinncu Oftil:l'rl
T"::lllporary Tot;]l DisLltoillY
D~ltl' of St;Hus B..::ginning
Ending._
."~'l*n.rot<Uhll.'I.::t;'UI.dl"::t>l"'I'''III.I-"'f''''lil'J..'tSchool. service unit. or employer only.
Volunteer Service Organizarion must provide with this form a VerifICation of Tax Exempt Starns under
Seclion 501 (cl (3) of lhe: IRS Code.
Name of School
or Service Unit Dickinson College
Address
Post Office BOl{
Street
Office of the Registrar
City Stale
Zip
Carlisle
Phone No.
PA
17013
(717)740-1 liRO
~ I cenify Thallhis slude'" isfW".Is enrolled al least half-time lor the deferment benefit period
imJkaled in Sectil," B
_ Our Inslitulion is on The !X Seme~ler 0 Quan.::r C Trimesler SySlcm.
'~ I cenify that This borr{lwerlsiwa~ serving (during the defermenl period indil:aled in Section B)
i/l:.m inlcrn~hipf'cside/lcy program in
.I:'I""'""'''-''''~.~:~ 10/2~~~9
AJtered Dates Must 9'::led By Certirying bfiIQI.;;nnAll
(This Space For Inslilulion Seal) J( not aVAilable piOYide officialleUer of cenification
(Seal)
NOV 0 2 1989
Analy" "it'al<_~
~
Comment:
SEQ
LaSl J Digirs SEQ
PI"I\!!. No. No.
A~l No. I LU AM No.
End Dale Type Beginning Dare End Dale
, I 1 U , I , I , I 1
Mo y, M,' y, Mu. y,
I LU
U I
'10.
LLJ
I
LLJ
Perkins Funds Only Dekrmenl ApprnwJ
:~~ Internship/Residency ~ Uave from Sl:hool
~: T.:mpor.II'Y Total !v1plher making less than .'SI.OO m{)re lhan
Disabilil)' of Dependent FeJ..::r<i1 Minimum Wage :md has pre-school age
Nat'1 Oceanic and children.
Almospheric Admin. C~)rps
Sit;Ili-1IUrl'_
D;JIl'
First \V;ll'!l,lVI;1 L"c
",."","',,,,,"',',
PERn\'> (SDSLj STLDE.\T Lo....s C."VCELLIT!OS OR POSTPO.YE.llEST REQCEST
lUse _qeverse Side for Deferment) First \\'aL'hoviJ Use
Fr!r"",~ ",,",r..',
I
~
'<'IIII~
'S..c'ui .~c'c'llrL(\' :-.;" '
A"cklrc"'I..\p! SlreCl1
CilY
StOll"
Zjp
E\'cnlfl~ Tclcrhnnt'
19/9) 770-7J5
Funds receil'ell he/ore Jllly /, /972. can qualify you for postponement/cancellation if you werelare a tuJl-time reacher'
A In a public elemenwry or secondary school.
B. In a non-profit elementary or ~ecnndary schonl regislered/recognized by th<: STATE EDUCATION AGENCY.
C. In an dememary or secondary school listed by the Secretary of Educ:llion as having a high concentration of low-income students in the Federal Register.
D. In an institution of higher education.
E. rn a public or other non-profit sch(4)1 (see B above) teaching handicapped student" fulltime. Beginning wilh the 80/81 academic year feacherst of children with specific learning dis
abilities who by reason th<:reof require special educalion can qualify.
F In:l Kindergarten Dr pre^Kindergarten program considered by the stale to be an integral part of it" elementary progr:lm,
Funds rf'Ccil'ed after J/UIl' 30, 1972, and Perkins Funds. can qualify you for postponement/cancellation if you werelare a full-time tea.:her:
A, In a public or non-profit e1ememary nr secondary school listed by the Secretary 1)1' Education as having a high concentralion of low-income students in the Federal Register.
S. In a public or /lon-profit Headstart program if under the EOA Act of 1964.
C. In a public or other non~profil school which was registered/recognized by the Stale Education Agency and teaching handicapped students full time. Beginning with the 80/81
academic year teacherst qualify if the children they teach have specific learning disabililies or if they have classes where the majority of students are handicapped. Borrowers wilh
Perkins l.oan(~l only can yuaJify for cancellalion if they were serving full lime, for twelve conseculive months in: Peace Corps <Jr VISTA.
A. Years] and ~ at 15 % each 8. Years J and 4 ,1110'1 each
"0ptional: Used to Verify Identity
-:t,llltl'.'I"IIIII'IIIJ.:IA"'IIII'lt;l(:.a:mitl,,.:lm1HTlItt.',,,,""II.:{,...rn;':.l~..1l11:.j,'
In'lirun<>n Whio:;h (;r;Hl!~J Lnan
~:_tt:tlltj':llmlltt'.41111:':'i-;4H'lll:1411'i1i
. Check block for level of teaching/service
o Pre-Kinderganen [J Junior High
c:; Elcmentarv CJ Colle!!e
C High Sch~1 ::: Kinde-rgarten
C Mid-School
C Vocational
C Headstart
(EOA of 19M)
[J Peace Corps
~~ VISTA
. Check block for type of ,chool
C Public (Non-Profit) = Private (Non-Profit) = Handicappedt
legal Name Of S..:hool
County
School Dislri":l
Cil)'
SU~
Zip
.:.:I'III:.lffl:l>lHoH
Beginning
Enuing
A"d
(BorfQYrlerMuSI Enter)
:'J Cancellation
I
Mo. Yr. Mo. Yr.
~li'Ii'IIl'Ob"'iIt..m~'r:'J.':itl.141([tll.f.1'f:r"'.'l'>Ir.llmllll'IO(:J.:"''f':\".
tIF TEACHING HANDICAPPED OR LEAR..'~rlING PISABLED STUDENTS.
SUBMIT A OFSCRlPI10N OF YOUR STUOEN<S' OISABILlTIFS AND
% OF CLASS HANOICAPPEn
...l:.f..filf:llltll.t:r.I.'.I'.."'..."11.llt:IlII''''i--
J declare lhallhe information shown above is lrue and accur.lle. I funher declare tnall will nolify my
lender or First Yhchovia Sludent Financiat Services, Inc" immedialely upun change in my staNS. I
funher undersland thaI if. for any reason. I am unable 10 complete thc year of service for which I have
requesled postponemenl benefits. I wilt hegin repayment of my loan. including postponed paymenls
immediately,
~".
. .
.. '.: .:. .,
o Postponement
.,~.
Dale
La_~l ~ Di~it,
Pro!!. Nu
~
La'l J Digil'
Pm\:!. No
~
,1.,....1 No
EnJ Date
L-L.J
\1" Yr
SEQ
SEQ
No.
W
B,:"inninl! 0-11':
i', 1'1
\1'0)
N"
W
....\IN(,._
End DOlI.:
TYr<:
W
Iyrc
U
Bq!lnnlnJ! DalC
I I I
\h, Yr
Prin<:ipal c.ml.:<:lIeJ: ~~
Interesl Can,:elleJ'
,
~.1"
I
"
Fnr f~ndinJ:: Institulion Onl~; R<.'qut:~t Disappn\\-el!
Dire,'r Direct 2()"; D":~""'r!~e
Dired I:,r; Direc"t ,<0'-; Dd.....rh,' j(I";
Pl'stpllncmenl.-\ppnlVeJ
Ddi.:nst' I~r:;
Prin..:ip;ll Clncelk:tI '; ____,~ lnten.:',! C;Elc'clled-; _~_~
J'r,'~r'lJ""J ,lnd l."
,11 '>.;(lln['\'rI_,I.-\.- :.;Ill'wn"ll Y'lUr Hillin\! .)I;jt~l1lcnl
I I .
I
I
II'Th;~ ls:\
NtoWi\Jdrtoss
Ched
Day Tekphollto
Return In: Firsl Wa('/">\';lI Sill, lent FilUm,'j(l/ Sen'in'I'. hl(
PO. Box 290/. Jllin.wor/.Salem. Vonh Carolif1fj 27/02
1.~'Ll.J:..".'.~.U..!Ji""I.I""..w."l..nu....".
IJMI":'ftIjl'.y.,.~lMln.,Jill'7.':r.t"f.ml..~I..:.l'.
..If'lrnilor.l(r'JI.'II"'III,lr'\'IU[:I.\'h'lnltf':I"III:I',"r,1ffI:'::.J.14It
Name of School.
Pt~ce ,)1' Emplovment ur Servi,'e l'nit
::::; I ,'~nify that lhi.~ i~ a public elementary or ,ecandary school.
= [certify that It>is is ~ nnn-protil elementary ,Ir secondary scht,,,l regislcred by the STATE EDU-
CATION AGE!\ICY Lcucr 'hnulJ he ~Ua<.:hed t>v cenifvin\:! official
__ I <.:eniry thallhi, is ~ public or ,,{her non.pw1il ;nstituti~n :)1' higher Icarning.
-=: I certify PeaccCurp"V!STA
Addres,
CilY
Stale
Zip
Phone No
Official at sch\x)l or plm.:e of ~mployment ,)r service unit musl cenify benetit periodlSJ on
the line(s) below. to verify the accuracy of the dates for which benefil(s) are requested.. If
requesting both cancellalion and postponement. official must sign 10 the right of both dates.
Musl be completed and signed before form can be processed,
.. .-' JIOllf:lllrl""lilt.rrU"'tll":.l~IU.'llil'I.'J'mtF.'1.
D~te
~ _ l,'rlt:ll'I,,,,,,,t..mh.'ill!:.:jiUl'Jlit..IlImtF.'1.
Date
(This Space For School Seal.
ffnola\-ailable providenfficialleller
ufl:enil'kation)
(S~all
I....
.J
For First Wachovia Use Only: Date Processed: _
Analyst Initials
.:oJ
Comment:
L...".l Digits SEQ
Pm\!, No "In.
U W
Type Bel!innint: Dale
W I.II.IJ
\tin Yr
Principal Cancelled:
Inlcresl CanL'elkd.
La" 3 Digils
Pm\:!. No
~ W
Type BCl'inlling Oar.:
WIII,II
~l() Yr
Print.:ipaJ Canc~!led
ImcrcstCan<.:o:IkLl
.\1"
SEQ
N"
AM "I1l,_
EnJ Datc
AMNo,_
F.nJ 0011.:
I ,
Ie
I i
,\1" Yr
CJOcdtallon Approwd (Chct:k Box &1(,1).'
Pc'ace Corps 15<;; VISTA 15'(
P<':,lCC Corp,> 20':~ VISTA ~O";
Signal'Jre_
Oak
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. g
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
ThO~~
Assistant Treasurer of Dickinson College
Dated:
F :\FllES\DA i AFILE\Dickinson College 7619\DickinsonCollegeCollections7619C\Oocuments\223-coml .wpd
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Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Dickinson College,
v.
Melinda Fountain-Kman,
NO. 03-5809
CIVIL ACTION-LAW
Defendant
JURY TRIAL OF TWELVE DEMANDED
SUGGESTION OF BANKRUPTCY
To the Prothonotary:
Please file in the above captioned case the Suggestion of Bankruptcy as Evidence that the
Defendant, Melinda Fountain-Kman, in this case has filed for bankruptcy protection under
Chapter 7 ofthe United States Bankruptcy Code on October 9, 2003 at Docket No. 1-03-05975-
MDF.
METZGER WIC
HAM KNAUSS & ERB, P.e.
By
~,
Steven P. Miner, Esquire :r;
J.D. #: 38901
3211 N. Front Street
PO Box 5300
Harrisburg, PA 17110-0300
Dated: November L;f 2003
292906-1
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Dickinson College,
v.
Melinda Fountain-Kman,
NO. 03-5809
CIVIL ACTION-LAW
Defendant
JURY TRIAL OF TWELVE DEMANDED
CERTIFICATE OF SERVICE
fA
AND NOW, this {if- day of November, 2003, I, Steven P. Miner, Esq., of Metzger, Wickersham,
Knauss & Erb, P.C., attorneys for Defendant, hereby certifY that X served the foregoing Suggestion of
Bankruptcy this day by depositing the same in the United States mail, postage prepaid, in Harrisburg,
Pennsylvania, addressed to:
David R. Galloway, Esquire
Martson, Deardorff, Williams & Otto
Ten East High Street
Carlisle, PA 17013
Melinda Fountain-Kman
1018 Dogwood Lane
Enola, P A 17025
B, ~/-""
~v Miner, Esquire
292906-1
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SHERIFF'S RETURN - REGULAR
CASE NO: 2003-05809 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DICKINSON COLLEGE
VS
KMAN MELINDA FOUNTAIN
ROBERT BITNER
, Sheriff or Deputy Sheriff of
Cumberland County,pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
KMAN MELINDA FOUNTAIN
the
DEFENDANT
, at 1915:00 HOURS, on the 7th day of November, 2003
at 1018 DOGWOOD LANE
ENOLA, PA 17025
by handing to
MELINDA FOUNTAIN KMAN
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
11.04
.00
10.00
.00
39.04
So Answers:
.;r'J;~-<:~
R. Thomas Kline
11/10/2003
MDW&O
Sworn and Subscribed to before
me this I'It~
day of
BY~^L~~
' rIie';uty ~I'fe~f
~J l{vtK"..J<v .ltltL3 A. D .
,qJ~ () ~v ~jJdi:,
, Jl'rothonotary r7
" F:\FILES\DA T AFILE\DickinsonCollege7619\Collections\CuITent\223 pral
Created 12/6/04 9:33AM
Revised: 12115/04 406PM
7619C.223
David R. Galloway, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiff
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03- 5809
CIVIL ACTION-LAW
MELINDA FOUNT AIN-KMAN,
Defendant
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE
TO THE PROTHONOTARY:
Enter default judgment in the above-captioned action in favor of Plaintiff and against
Defendant in the amount of$4,879.62 plus costs of suit and interest from date of judgment accruing
at $.32 per day for Defendant's 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 the Defendant at the address indicated thereon, on November 17, 2004, which
date was subsequent to the date default occurred and at least ten (10) days prior to the date of the
Praecipe.
MARTSON, DEARDO
, WILLIAMS & OTTO
By
David R. Gallowa , Esquire
J.D. 87326
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiff
Dated: December 16, 2004
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Created 11/16/04 445PM
Revised 11/16104 449PM
7619C223
David R. Galloway, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiff
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03- 5809
CIVIL ACTION-LAW
MELINDA FOUNTAIN-KMAN,
Defendant
JURY TRIAL OF TWELVE DEMANDED
TO: MELINDA FOUNTAIN-KMAN
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 YOUR LA WYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, P A 17013
Telephone:(717) 249-3166
Date: November 17,2004
MARTSON DEARDO
By ~~'Z
David-<<'. Galloway,
I.D. 87326
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiff
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CERTIFICATE OF SERVICE
I, Jean Taylor, an authorized agent of Marts on Deardorff Williams & Otto, hereby certify that
a copy of the foregoing document was served this date by depositing same in the Post Office at
Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Ms. Melinda Fountain-Kman
1018 Dogwood Lane
Eno1a, P A 17025
Steven P. Miner, Esquire
3211 North Front Street
P.O. Box 5300
Harrisburg, P A 17110-0300
MARTSON DEARDORFF WC:IAMS & OTTO
~
By ~ jl-- f
Jean T lor
Ten t High Street
Carl e, PA 17013
(717) 243-3341
Dated: December 16, 2004
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Created. 12115/04 11 12AM
Revised: 12/15/04 1 12PM
76 \ 9C.223
o~~
David R. Galloway, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiff
DICKINSON COLLEGE,
Plaintiff
v.
MELINDA FOUNTAIN-KMAN,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03- 5809
CIVIL ACTION-LAW
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE
Please see attached certified copy of Discharge of Debtor.
Dated: December 15,2004
, WILLIAMS & OTTO
By
Davl . Ga way, l
J.D. 87326
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiff
Form B18 (Official Form 18)(12/03)
United States Bankruptcy Court
Middle District of Pennsylvania
Case No. 1:03-bk-05975-MDF
Chapter 7
In re: Debtor(s) (name(s) used by the debtor(s) in the last 6 years, including married, maiden, trade, and address):
Michael J Kman Jr Melinda M Kman
dba Kman and Kman Financial Group 1018 Dogwood Lane
1018 Dogwood Lane Enola, PA 17025
Enola, P A 17025
Social Security No.:
xxx-xx-9278 xxx-xx-3526
Employer's Tax J.D. No.:
DISCHARGE OF DEBTOR
It appearing that the debtor is entitled to a discharge,
IT IS ORDERED:
The debtor is granted a discharge under section 727 of title 11, United States Code, (the Bankruptcy Code).
BY THE COURT
Dated: 1/28/04
-ry~vOa~
United States Bankruptcy Judge
SEE THE BACK OF THIS ORDER FOR IMPORTANT INFORMATION.
)/1; .
CERTI.FIE? FR~M ;HE ~EG~RO lhIS~,;~
day of\' ~.~!.J ( ( J] '0/,~/ U ,20_7
Clerk, liJ.p~ BankrU:JtCj)Y our,- :,,1
I I ,I j" h, ., ti) t I
P ~ 'II."\" V-.' / (;:- (., J ,. \ iV' I...(V(,. v
e . , :Deputy CIet1<
CERTIFICATE OF SERVICE
I, Jean Taylor, an authorized agent of Marts on Deardorff Williams & Otto, hereby certify that
a copy of the foregoing document was served this date by depositing same in the Post Office at
Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Ms. Melinda Fountain-Kman
1018 Dogwood Lane
Enola, P A 17025
Steven P. Miner, Esquire
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
& OTTO
Dated: December 15,2004
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Created 3/9/05 10,23AM
Revised_ JI14105 J:26PJ\1
i619C223
David R. Galloway, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for P1ainti ff
DICKfNSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03- 5809
CIVIL ACTION-LAW
MELINDA FOUNTAIN-KMAN,
Defendant
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please mark the judgment in the above-captioned case satisfied and issue a certificate
reflecting the same.
By
David . Galloway
J.D. Number 87326
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Plaintiff
Date: March 14,2005
CERTIFICATE OF SERVICE
I, Jean Taylor, an authorized agent for 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, P A, first class mail, postage prepaid, addressed as follows:
Ms. Melinda Fountain-Kman
1018 Dogwood Lane
Enola, PAl 7025
MARTSON DEARDORFF WLL S & OTTO
~- r-TI
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By~----- -=~ I
.leal)' Iraylor U
TetL ast High Street
Carlisle, PAl 7013
(717) 243-3341
Dated: March 14,2005
~-