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F,\FILESIDA TAFlLE\Dickiosoo College 7619lDickinsonCollegeCollections7619CIDocumentsl225-comlwpdldrg
Created:4128/031:54:03PM
Revised: I lI4/032,3634 PM
7619c225
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NO. 03- !:'~f..2.3 ~ 1....-
CIVIL ACTION-LAW
DICKINSON COLLEGE,
Plaintiff
JING M, YANG,
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 MAYBE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
LIAMS & OTTO
Dated: November 5, 2003
By
David R. Galloway, Esquire
I. D. Number 87326
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
v,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03- Sf -2..3 W T..<-v-
CIVIL ACTION-LAW
DICKINSON COLLEGE,
Plaintiff
JING M. YANG,
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:
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 Jing M. Yang is an adult individual with a last known address of 9
Hawthorne Place, 9B, Boston, Massachusetts 02114.
3. On or about December 16, 1986, Defendant entered into a Promissory Note - Federal
Perkins Loan Program (Note #1) with Plaintiff for the financing of$1 ,500,00 plus interest and costs
by Defendant on her own behalf, for educational services and benefits at Plaintiffs institution, A
copy of Note #1 is attached hereto as Exhibit "A."
4. On or about November 13, 1987, Defendant entered into an additional Promissory
Note - Federal Perkins Loan Program (Note #2) with Plaintifffor the financing of$I,500.00 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, On or about December 5, 1988, Defendant entered into an additional Promissory Note
- Federal Perkins Loan Program (Note #3) with Plaintifffor the financing of$1 ,500.00 plus interest
and costs by Defendant on her own behalf, for educational services and benefits at Plaintiffs
institution. A copy of Note #3 is attached hereto as Exhibit "C."
6. Note #1, Note #2 and Note #3 are funds created under Part E ofTitleIV 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.
7. As provided in the Act, Plaintiff acts in a fiduciary capacity in the handling,
disbursing and collecting of funds associated with the programs under the Act.
8. The total principal for Note #1, Note #2 and Note #3 is $4,500.00.
9. Note #1, Note #2 and Note #3 grant Plaintiff reasonable collection and attorney's
fees which Plaintiff has calculated to be $675.00,
10. As of October 23,2003, the principal and interest due and payable by Defendant to
Plaintiff was $8,129.82, plus interest accruing thereafter at $.62 per day.
11. As of October 23,2003, the outstanding balance of$8, 129.82 represents the total and
actual overdue value ofthe financing provided to Defendant under Note #1, Note #2 and Note #3
for which Defendant has yet to pay.
12. Plaintiffhas fulfilled, performed and complied with all obligations and conditions of
Note #1, Note #2 and Note #3.
COUNT I
BREACH OF CONTRACT
13. Plaintiff hereby incorporates by reference the averments contained in Paragraphs I
through 12 of this Complaint.
14. Defendant breached the expressed and implied obligations, conditions and terms of
agreement of Note #1, Note #2 and Note #3 by failing to pay the amounts financed therein.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of$8,129.82,
plus interest accruing at $.62 per day from October 23,2003, collection and attorneys' fees in the
amount of$675.00 and costs of suit.
COUNT II
IN QUANTUM MERUIT
15. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 14 of this Complaint.
16. Having requested Plaintiff to loan money, and doing so to the benefit of Defendant,
Defendant became liable to Plaintiff for said money,
17. Defendant has been unjustly enriched by accepting said money without paying
Plaintiff reasonable compensation therefor.
18. As of October 23,2003, the total amount by which Defendant has become enriched
is $8,129.82, plus interest in the amount of$.62 per day from October 23,2003.
WHEREFORE, Plaintiff demands judgment against Defendant ling M. Yang in the amount
of $8,129,82, plus interest in the amount of $.62 per day from October 23,2003, collection and
attorneys' fees in the amount of$675.00 and costs of suit.
B
David R. Gallow
I.D. Number 87326
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Plaintiff
\
Date: November 5, 2003
NDSL - TRUTH-IN-LENDING STATEMENT
DICKINSON COLLEGE
Account Number
2~.1j' - Cf?
J//lO (11/00 V0J!9
d'&r JhY-IO)1 INtd
Ardrx'(:/~ I) If/NG
Name of Borrower
Address
k~UAL 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
(j
%
5' %
$ J; <jCO
I Itemization of the Amount Financed: $ / /./-)(;O
Amount given directly to you. I
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, $6.00 for each late payment
if this loan is payable quarterly.
Prepayment: If you payoff early, you will not have to pay a penalty.
See your promissory note for any additional information about nonpayment, de-
fault, any required repayment in full before the scheduled date, and pre-
payment.
THE BORROWER ACKNOWLEDGES RECEIPT OF AN EXACT COpy OF THIS STATEMENT.
STUDENT 1: .
BORROWER ,{A.,fJ, 7nru.c
( .J
DATE /2.. II. / x:k
I' ,
l1,~4
vel
INSTITUTIONAL ~
REPRESENTATIVE C/.:.!57~ ~
DATE_(_:.L~!?&
DICKINSON COLLEGE
CARLISLE, PENNSYLVANIA 17013
PROMISSORY NOTE
NATIONAL DIRECT STUDENT LOAN PROGRAM
,7; liQ(;{)(7D VrUiO' ',', "" .rom". '" ..".
Dickinson CoUell.c (hereinafter cII.neil the Lendirlll InUllutlon) located at Cu/isle, Pennsyl"anl., the sum of the amountl that art!
advan."cd to me "no ~ndnucd in Ufo Schedule of Advances set rorlh helo.... I promi5~ to pay IllI attorney's feu and other unoo._
fj~n c~il:$C~i'~~'lf~~~lt;~,~'~'~e ~;~a:i\:h~:i~i:S:,~bJ!~~ tl},'~ h~"~~j~t ~~b ~ fC~U~ c~~~ufrt.~tl~e~A~t':t~1l1~~).~h~s~"~~'J::t~~nL~~:t~:'~l:~1~'6
not e~ccc<l 2~""" of the unpaid ptinciJ,al and inten.t.
~-" '.. -'-'....... =o~=~"''''SC'HEO.-U,...LE=OFAO'.rA N C ES
VEA~
TERM AMOUNT O^TE
5lCNATURIE 0"- MAKE"
VEAl'
TEl'''' "''''OUNT DATE
SIO"'ATURIl 01" "'AKlER
~
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t<:(
7r;c
g!? ll//aV t!?,.~
'J-t' ":J m(cJI :/i"-)
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"
,
"
"
"
.
..
~-:;:~.""" ;~;;itlji;("0-=~i-' ,"~- ,
..,"'_.""""" . { r', jf~.tAvl poi /i.,I.'~ CiA I',O'O.j
I 7 ''(\h,celo, nox Number,Clty. S\.,l", und iJ~ Code)
Sodal Seeurlty Number I '/r- - f;" 2 -- J J-. ;/7
IfurtherUlIdentund and auecthat:
I. GENERAL
\}l6~, t.\~et~::tle~d;~'1..Cd~h~niec\,t~~d":rtee &~bl::tt:: :~~A~t'~~~ U,~a~~~d';ir,,~eR;I:~aftg~11~~~e~Vu~~~~t~lI1':f. ~t~Ct'"e~::'~ ~t~hi:
"ote must be lnluprchd in acco..hmce with the Act and Federal R".."I~Unnl, COlli..s ur which are In b, kept by the Lendirllln.
stituU"",
(2) I underU....d that If I am eli':lble for dererment <u cancellation und,,, Artic1u VI ttnou;h IX, I am ..upontlbla for aub.
mittin.. tile appropri;,tenoq",cltaontlmc.
II. INTEREST c-
Inhr...t ,h.ll lICC'U" fnun the be,innlnl of the repayment perlnd and ~hall be at the ANNUAL I'ERCENTAG1i; RATE OF \(;0/
intenst on the unpaid balan"e except that no intereat ahall acenlC durinl .my ddennent perind descriucd In IUbpllTa..,aph."V'r(t)
(A),{"8),(C) and (I)).
Ill. REPAYMENT
b~~lnnl~~C6P~~:nf~~"~1t~~ it':.:~{:t~iP~c~~~ ~~)h~ ~~nl':~:~ ~nhr:\~~tr~~".r.~~~lr~lt ,::~d l~hl~lt~~i~~'~i~\~~"arc~~~:a~~~t, c;,~a~ta re~::.d.
p..nble In.tttutlon nut~ide tha Un,te<1 Stat". approved fur thl. purpo._e by the United St.tu Seent.ry nf Edueatlnn (herainafur
c.lled the SecrHary). an~ en.,ilnll, IInlcullaulluph, III (4) nr VI 0) (delernlent) ~ppll,,", 10 yean laler.
(2) Im.y.hnw..'.H....'lUeltthatther<:p..}.m..ntPerluet.t....tnn..nellrHerdate.
(3) I PFon.lae to. repay the principal .nd inlcreat nver th.. COura.. 01 the .epayment p..riml in equal monthly, bimonthly or
~t'~i{,;,e:,~~.,"d~\~l~~f~~~d' i~. ad~~~r:l~:'~ed ~rl~h.ec~;'rln\~ie~1I al;;~~t~:d"b;' ~h:svee:.~c':a~:~1~e;i\'h"':.P:i:~~t:ct::X~: :,''ra:e''p~~~:~f~~t ~~
attOlched to and made Par1.olthianote.
(4) Notwithaland.inll; p'\l'al:.uph III (1)"H J QuaUfy "" a low.ln~ome individual durinll the. rep':lJm..nt period, th.. L..ndlnJ In.tl-
~~g~cnl ~~YI~~~~'~ ~~'l::~ti~: c"lend Ihe .epaym'lnl verlod for UP to. an addlhonlll 10 yeau or a lUlt any repayment ache ule to
[~le ~~;t) e~es;aN,,~~~~Y t ~l~e ':'~nntl:I~.alraat~d t~",,~e~~'~~'l'dl\ bt~'I:s:~~.~~J~~n~~:: ~~:ll~~ p~,e~ lV'mt'i.. (i':~.I~~~C:~:te~:,c:,~ r.~f' ~Wealt~r:\
monthly repayment rale uf principal ....d ir.ter~.t nn all my "allun..l Hired and Netiun,,1 Detan... Loanl, lneludinl thl. 10an,II
Jcuthan $.10 per month.
(5) (B) If I have reeeived National Defense or Nal.lonal Dlrut Lnan. from other instltutionl and the total monthly ""r.ayment
~~~dh,iIN':~i~~~~sd:rl:,~:et~~d Va~IJ~:1 ~i~e~loL~I~~rs ~",Id i:~a~:I~~~~JW~~: i~~~:r:~~~~tl~Ip~"'J ~~)t~o~~eo~tteer Ilg~l:n al my out_
} ~J~ C ~ Ihe~ I l~~ i~~ Oi~I~W~u'i~g~:,n;i,~ t 1<~~eU~ t e~~a ~,~~~~ n~hryer.:~::~r:~r"~~e I ~ ItI~61~ tabren~ol ~hi~e 1:,~~el~~teN a~~~~\ ~~j;~ ~enp-:;'~
lent. the difference betwecn .$30 and the monthly rat... I nlUat pal' on my othet National Detenae and National Direct Lllan..
(6) A Ichedute of repa:>;ment will\,>e attached to anet made put of Ihi. note.
(7) The Lendlnll I"-'Iil\ltinn may permit me to nay lell tlla" the rate nf $30 per month for a period 01 not more than One year
where necci.ltry to "~old hardhilP to me unlen that action would ""lend the rePltymenl period In puallraph III (1),
IV. PREP A YMENT
U~e. I may at my npllnn and wilhout penalty prepay all o. any put of Ihe llrlndpal, plu. the .ccrued inhreat thueon,.t any
~~t be ~o";'.~id~~~J ~elfra,.~~~~~I~cltdemiC yea,r In ....hleh Ihe loan wu made will be uaed to. nd\l.ee the amount nf the 10Vl a!'ld wW
(3) If I reflay mo... than th" amounl due lot any In.tallment. the exeUR will ba uaed to. "npay principal unlna I dullnat.. It a.
alladv,,"cepOlymentullhenextrcr:Ululn.tallment.
V. DEFAULT
(1) If I hail to make a scheduled repaymenl of Itny inu.ulment or I faJllo Ill. canceUaUon or deferment forma with the Lend.
tnll Inatitutlon no. time. the enlire unpald indehtedn...a indudlt\lI Inter~d due ll.nd ae"ruad thcnon, plUI ..ny applicable p"naUy
~h~"~,". ", ,I!. ~t the ,':>t..,n "r [j.e 1.,,,.-..1\'''1: ,,,.f,lt.,Ii.,,,. j-'o.."r,'~ ll'.-.mLJia",:.' <ill... i",,1 p~yable.
~~~... r~I~~~;r~~"f~~~~~fnl,~.1 t~e~;~~ll"~u~~,~"oa:~:~~.~~~~~.'1 the Lendinll 1".IIMlon may dl.do"" that I hava defltulted, alonl with
~~)crel:~r~~e: 'd~,iI~~ee~i::rt ht.hvaet di:,~JteetJ':i~o~~ -Ziih 1~~he:er~~:~~r\~I~nr~~~i"o~~i~ ~sr:~lttbt::r:~: !.el~r~ilz-:itnf:::. coUecdnn, the
VI. DEFERMENT
(1) IntereatwiUnotaeerue.andin$l.urnent$nudnotbepaid_.
(A) While 1 am ~n'oUed and in attendance as at least a half-time student at a.n Institution of hlllher education or at a compa:r..
blelnlt,tutlolllluISldethcUnitcdShteaappr('vedforthispurp...'eb}.theSecretUY,
(8) For a period nllt in exc,," of 3 yeu. durinll whicll 1 am __
(I) On full.time aClI~. duty -... a,m~mber nf the Armed Forces of the United Stat... (Army Navy All' Foree Marlne COlP' O'
Cnast Gu....d). or an nlflcer on full.tlme aclive dUlY In Ihe Commiasloncd Corps of the V. s. Public He'alth Servic~, .
(til l.n serviee aa a VOlunteer under the Peace Corp~ Act,
(tiD a volunteer under the Domestic Volunteer Service Act of 1973,
(iv) a full.tim~ volunte"" in a tax."xempt orll""l~atlon p".furminll ~ervi"e eompuable to the aervice petformed in the Peace
Corpao, unde, the O<1mestic Volunlee, S.ndce ACI of 1913. (AC'l'ION 'UI''''CY programs), o.
\vl." P.~~~J~~a~~:e ~'~~~,I,\~.~isb:~(~ ~p~>~~:cb~~1~1. ~~ d)s:~fi~dda."":t <If a qu..lifiNI plmidan, or unable 10 iecure employment becau,e
(C) For' Derlod not In exc". of two yeUII dlUin, which tln:Je I am 8l!mnlm an lntem.hlp wbleb i. required In order that I
may rllcelve prof..mona! uco,nitlon requirlld to bll.1n my profen:\oua! practlc' or .uv:lce. Uld '
~t;~t ...D:~tt'rJ't1~:c~fPhel~g:i td~c::ro~~~~u~ t~.d:a:~~~hd~r::~d~r.n~~~~ :~i~:J.:~t' ~~ ~fla(t~).(M g~i:\U::P~~:
(2) Th. Lllndln, In,etltutlon may. upOn my appUcatlon, defer or reduce any .cheduled reDaymenu If. in IU opinion. axtRor-
dlnUY cUeulnltanCtla .uch .. prolon,ed Illne.. or unemployment. prennt me from makln, auch repaymenu. However. intereat
will contlnueto accru..
VII. CANCELLATION FOR TEACHING
(1) I am enUtl.d to h.v. UP to 100 perllll!nt of the amOunt of tblllo... pi... th.lntere.t tbereoll cUlCtlUed IJ'lund.rtu' ..ni".
~~~uti';:n~'~;:.~e ,,:~~~el~ ~u:llfl~bf~~ ~~o.1~i."n~~~-.frn~ltl e~n~:t~::n~n:""'s~"e':.~1 w~u~a~:n.~:~tt'9lf:~~ ~I~
h.. been dealiinated I)y the S.cret...,. In .ccordanc. wtth the provialona of S.ctlon 461i (a)~) of the HlIher Educ.tloo Act.. a
achool wtth a n~h atlroUm..nt of lJtud.nU from low_lncom. hmlll... or
(B) .. I hill.tim. teacher 01 hUldlc.pp.d children (Iotludln'lrI.ntdly retard.d. hud of b.vinl. dllallsaleech Unpalr.d. vt.udly
~~:SPct1Jl:e~o:~~ b~~~~~~rh:::~~~::uri:t~:!cl~ll;t,le~::~~' ;:.~~:;~e~e~t~:r~~I~~t1fc~r' o~h:r ~~~.~~11~te~:~~~~:;
or ncondary uhool,yriem.
(2) ThJ,loan wUl be canceUed It the followlne utll'
(A) . 11i petcent of the total princlplll amount of the loan plu.lntenrt on tbe unpll!d blllanCtl wID be cancelled for the flnt and
second compl.t. aCl,demlc yeu. of thd t",chlne ...niee ~
(81 20 perunt of the totlllprinclpa.J Imount plua Intend on the unplld balanCtl for the third and lourth comtllet. .ead....lo
yeUII of thlt teachln, lervl~e:lnd
(C) ,30 percent or the total principal Imnunt tllus Internt on the unpaid balance lor the tilth complete Icademle y.. 01 that
teachln,..rvtee.
VIIl. HEAD START CANCELLATION
(1) I un 'ntltl.d to hlv, UP to 100 percent of the .,.,ount 01 thl.loan plua the int.rest thueoll c,,"c,U'd II I undertake ..rv:le.
u I f~I-t1me .tlff membn In a Held Start prolllm If .'
(A) that lIead St.t pro&run Ie operated for I period Which I, comparable to' I luIl.ehool '"'u in the 10c-.JJty. and
(B) my NJary la not more thUl the lalary of a comparable .mployee 01 tb.elocal ,ducatlonal..en"y.
m ..c~~:~=t:~~~le::::~;~ha: :~~I~:'::n~fo~:"~~~i: :M~d ~~~ ~~~~.emount plU,ll the t"tueat on the \lnpal4 balan...
(3) Head Sh,rt II I prllchool propam curl.d out under pcUon 222 (a) (1) of the Economic Opportunity Act of 1964.
IX. MILITARY CANCELLATION
~1~emt:"ot,~:I~~oeJ'V~r~:a t,?f ~~ePfl~t~~ t't:~e~ 'lnrin~p~.~1~J.ffutr:: \~~ :~W:. tr;:,::;:,~r:~; ~~~~U:,dcUoln '''1: :t
tltla 17 of the V~ted Statu Code.
(2) Thh 10"" wtll bl c~ceU.d It the rat. 01 12~ percent at the total prlnelpal....ount pille Iot""t on the unpald beJanc. tor
neb eornplat. y.u 01 auch ..mel.
X. OEATH AND DISABILITY CANCELLATION
If I should die or become p.rmlrl...tl,. and tot.n,. dll.b~d. the .ntb:oe I",ount 01 thlalo&o plu. tb, iflter.at U>ereotl lIhall b. ellUl_
c.U.d.
XI. CHANGE IN NAME, ADDRESS, AND SOCIAL SECURITY NUMBER
I am r..poneibl. for Inforndne the Le..dlrtl InlJtltutlon of &oY ch&o,e or chlUl'" In my nlml, Iddre... or IOclal ....lUIt,. number.
XIL PENALTY CHARGE
it~n W:~e~ '~:~.:,~etl~'::~ f~:t':r:.r" t~a~~:ll tt~::;'~~,i~~:u':.it::t:~:: yrp~~i: ~::-;~;.lri: ::::'r:=.:~:-:.~:t
me 10,. tb. l..ndln. Inltltutlon.
(21 Nocbu"'lnay,xee.d..
~~~"Id:nh:.r'l. \~:.~~d t;2~~)'e"~~ :o:rttn;~~Jr-.:r;:~:~;h ~a.~~~f\~:. ~~st month or part of I month by which the Inatdlraent
~J. 'tb:~~~"b~b:'~1~ :~:~:l.tb:a:'t ~~~'::~~eor. ~~t-::erlY tnataUrnente. 13 .nd U. mpeetlwly, tor ncb Inatalln:r..nt IIlt'rI'eJ or
~~\ore Pb:~u~~~~r~Iw...t1:~~ib..:::J1::.~t.'dd the ..meed char.. to the outlJt&odin, prinCipal 01 the lout, It rault eo Inlorrn m.
XIII. ASSICNMENT
Thll !'ote may 10, Udped by the LeDdlnllnatltutlon only..
(1) to 1Jt0ther inatltution uPon my tr&oafer to that Inetltutlon If that lnetltutlon t. particlpatb!.11n tble propuo (or tf oot 10
part!clpltl.n,.l.IeUl;lble to do ao Ilnd t. at>proved by the S.cret...,. for thlt PUl"poP), or .
1:l\U1,I:1~~~~~~~t:~,,:r:~J~t::' :.::~t~l~ ::l::::.d by the Se~tary. Th. provllion. of thil not. thlt relet_ to the Landin,
XIV. PRIOR LOANS
I h.~by CtIrttfy thd 1 have Uated below all of the NatloneJ Db-.ct Student Loana (or NltlonaJ DelanM Stud...t LOan') I hlv. ob.
tl,jnad at other Inlt(tutlona. (If no pdor 1':IIna have be.n reeelnd. atlt. ..Non....)
Sah.du]e 01 Nltiollal Dlnd Stud.ot ~oan. I1Id Natlooal Dden.. Studant J.,01ln1 at other I,oltituUonl
Amount
bIte
lnatltutlon
1...................
2...................
8...................
......................
Caveat. Thu not. II to b. ell:'cuted without eecu.rlty Uld without e~dol'lllm.nt axe.pt th.t If I Qn I minor U1d thll not. would
:,~t,;t":~;.rbt.h;.~..l1r:J..~~eSL.:~d%;t~:JM:tio~.::.:n..~~~:u:'::p~ ~f~:~,;::.t': ~:.lndlnl obUC.t1oll. either "curIty or .ndorM-
SiIo.hu.otendoreet
Olte
Pem'iUlent Add"..
19
"(Street Qr Box Number. City. Stet.. and Zip Cod.)
Soda). SecUJ;ity Numl)er
NDSL - TRUTH-IN~LENDING STATEMENT
DICKINSON COLLEGE
Accounc Number
000-00-2337-07
~ame of Borrower
Jing M. Yang
Address
#6 Nine Station Road
Ardmore, PA 19003
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
%
$1,500.00
I Itemization of the Amount Financed: $ 1,500.00
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 payabl~ quarterly.
Prepayment: If you payoff early, you will ~ 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 ->
BORROWER>'! -<. " ~~
l
DATE It/I)! 7
JILLCi{;
.1i:j'
INSTITlITIONAL ~
REPRESENTATIVE', / '---' j ~
DATE I' /13/ B7 .
DICKINSON COLLEGE
CARLISLE, PENNSYLVANIA 17013
PROMISSORY NOTE
PERKINS LOAN PROGRAM .
I, . JinQmiao Yanq promiStlOpaYlo
Dickinson Collelt (herein afler called the l.endirli Institution) located al Carlisle, Pennsylvania the sum of rhe amounlS lha' ar~ advanCe'd [0
me and endorsed in the Schedule of Advances set tanh below. J promise 10 pay aU anorney's fen and OIher reasonable collectIon com and
charges necessary for the colll:Clion of anY amount nOI paid when due.
I further um;leutand and agreelhal:
I. aBNER.AL
(1) ~DQlicjlbJe Law, All sums advanced under rhi, notc Irc dnwn from a fund created under Part E 0( Tille IV of Ihe HilJ.her Educ.tion Acl of 1965, as
amended, hereinaftef called the Act, and are 5ubjecl to [he Act Ind the Fedenl Reaulaliolll iuucd under the Act. The lerms ol rhili note shan be mler-
prelcd in accordance wilh the Atl and Federal Rcaulations, copies o(which ate; to be kepi by the Lending IlUtitution.
(2) fJ'OS'ed\lres for Recejvini Defcmnenr or Ca!lcc}larion. I unden;tand that In oroClr to recewc a ddennent or canullaliOll, I mlllt requut rhe deferment or
cancellation in writing from the unding Institution, and mUll submic to the Lending Institullon any documentalion required by thCl Lending Institution 10
prove:: that 1 qualify for the de(Clnnent or cancellation. I funher unden:tano that if I am eligiblc for defcrment or cancellation unde~ Articles Y1 ,lhrOu,gh XI: I
am respomiblCl for submittiJllthe appropriate requests on lime. I funhet unde(5tand that I may lose my dcferment and cancel/allan benefits If r f3llto fIle
my req1,lest on ume.
II. Ir-tmRESI'
Interest shall aCCNe (rom the beginning of the replyment period and shall be at the ANNUAL PERCENTAGE RATE OP filVE PERCENT (5%) on
the Urlpaid balance, CXl:ept that no intere51 shall accrue during any deferment period described in paragraph VI(t).
III. REPAYMENT
(1) I promise to repay the principallnd the interest which accruea on it to the Lending Institution over 1I period beginning 9 mOnltu: after the d,ae I cease to
be at least a half-time student at an inftilUlion of higher education, or at I comparable institution outside the Unitcd States appl'OYCd for thif purpoce by lhe
United States Secretary of Educttion (he($inafter caUed the Secretary), and endinlo unlUi patllgraphs 1lI(4), IlI(S), 1lI(?), or Y1(1) applies, 10 years later.
(2) Upon my written requat, the repayment period may stan on a dale earlier than the one indicated in plnlgnph lII(I).
(3)(A) I promiu to repay the principal and intelat over the coune o( the repayment period in equal monthly, bimonthly or quanerly illltallmentl as decer.
mine'" by the I,.e:n"'ing Institution. J understand that if my monthly payment f(lt all the loans lJUII<1c to me by the Lcndinllllllitution i. not a multiple of $.S.
the Lcndin.IMtitution may !Quod that payment 10 the next highest dollar amount that is a multiple of $S.
(B) Norwithstandin. parap1lph JII(3)(A), upon my writlen request, repayment may De made in p1lIdualed inslallments in accordance wilh a SChedule ap.
plQVCd by thc Secretary.
(C) The Lending Institution shaJJ altach the' schedule of repaymenl5 and the $Chedule will bccolM part of the note.
(4) Notwilhslanding p'rapaph III(t), i( I qualify iii' low-income individual during the repll)'l'hent period, the Lending Institution may, upon my wrinen re.
quest, extend thc repay11lCnt period for up 10 an additional 10 yearS, or adjust any repayment schedule to rcfleCl my income, or Qoth.
(5)(A) If the monthly ratc that would l:Ie cstabUlhed under parag:raph lII(i), or the tocal monlllly repayment I'lIte of principal and intclQt on all my Perkins
Loans includini this loan, is ICSll Ihan $30 per monlh, I shall n:pay the principal and incerc51 on thil Joan al the nile of S30 per month (which includel both
principal and intctesl).
(5)(1;1) I( I have received PerkifUi loans from other ilUtilutionl and the tOlal monthly repayment ralC on th05C lOin. is lea than $30, the: SJO monlhly rale es.
fablished under subparagraph 1II(5)(A) it; the tatcl pay on alII my oUlltanding perkina J,..o8ns and is not in addition 10 the amoun, I pay on thOlCl Olher loans.
n, amol,lIlt of my tJIOnthly repayment nile attributable to this loan is the amount which rep~nll the difference between 530 alld the monthly tate, I musl
pay on my other Perkins Loa"'.
(6) The Lending Institl,ltion may pennit me to pay lea than lhe rate of 530 per month fot a period o( nOf more than one year where neceS$llry 10 avoid
hardship to me: unlesa lhat .ction 1\'Ould extend the rcpa)'lllenl period ill paragraph III(t).
(7) The Lending IMtitution may, upon my written request, reduce any s.:hedule:d repaymenll or extend the repayment period indicate'" in parapaph 1lI(I),
it, in i15 opinion, ~raordinary ci~lJllItancC5 s~h as prolQIIgcd iIInCSl or unemployment, pMVCnt me from making the SCheduled repaytnenll. H~r, in-
telQtsllall continue 10 aCC11lc.
N. PREPA YMEN!'
(1) I may, at my option and wilhout penalty, prepay all or any pan of tllc principal, pllll the acc(\le", interest thereon, at any time.
(2) A.movnts I repay in the uademic year in which the loan _, made 'lViI/De u.scd to reduce the .tmount of the loan and will not bel cotUiidered a prepayment.
(3) If I repay more lhan the amo...nt duc (or any installment, the excess will be \lied to prepay principal unleu I duignate il as an .dvllncc payment of tll,
ncxtrepllrinstaUment.
V. DEPAUt.T
(1) The l,.clldinglnstitution may, at its option, declare my loan to be in default and may demand immediate paymenl of Ihe entire unpaid blJance of the
IQlIn, including prirtcipal, intcrelt, and laic chafICI if -
(A) I do !lOt make a scheduled plymenl when il iJ due, And
(8) I do not 'ubmil to the Lending inslitution on or belore the date on Which payment is due, dOC\lmentation that I quality (or a deferment or cancellation
described in Mid" VI, VII, VlII, IX: X, or Xl of Ihis agreemenl.
(2) 1 understand th.1 if I default on my loan repaymenll, the Lending Institution may disclO$C that I have defaulted, along with other relevant informalion, to
creditbllrcauorgan~tions.
(3) Funher, I understand that if I default on my loan repa)'lllent and the Joan i$ sent to the Secretary for collecdon, the Sc::cretary may disclose thaI I have
defaunC::d, along with other relevanl information, to credit Dureau organiutJons.
(4) I understand that if thc Lcndinglnstilution .ceelenlles: the loan under paragraph Vel), I willlosc my canceUalion and defennent benefit5 (or 5Ctvice per-
fonned after the date the Lending Institution acccleratc::d the loan. .
(5) I understand that faih,lle to {!IY thil obligation l,rnder the tenns apeed upon will prevent my obuuning additional student financial aid aUlhoriz.ed llnder
TItle rv ollhe Hillier 8dw:ation Act o( 1965, "amended, unlill have made amnge:ments which are 5lIfisfaclOry to the Lending Institution or the Secretary
regarding the repayment of the lOin.
Vl. DEFERMENT
(1) Inten:lt Mil nOf accruc, and installmenla of principal need not be paid-
(A) While I am enrolled and in altendance as at least half-time student at an instilUlioll of higher edllCltion or at a comparable institution outside the
Uniled StateJ approved for this putpOloC by the Secretary;
(8) Fori period of thn:e (3) years during which lam -
(i) On full-time active duty as a member of the AImed Fof'MI of the United Statu (Army, Navy, Air Porce, Marine Corps. or Caul Guard) or the Na-
tional OccaniC and Atmospheric Administration Carpi, Ot .. an officer on full-time active duty in the Commissioned Corps ol Ihe United Stales Public
Health Setvice,
(ii) In sctvicc as a volunlur under the Peace Corps Act,
(iii) A \lQluJltcet undcr the DomeSlic VoJuntur Service Act of 1913 (ACTION programs),
(iv) A lull-time voh,mteer ina,taJI<Jlempt orpni%.ation performing service comparable to the service performed in the Peace CoI'pI or under the Domes-
tic Volunteer ServiCe Act of 1973, or
(v) Tempotllrily totally disabled as established by an affidavit ol a qualified physician, or unable to secure employment because I am prQViding ca~ re-
quirc::d by a dependent who is so disabled;
(C) for a period nOI in ~cess of IWO (2) years ..fter I receive a baccaiaureate or pl"Qfcssional degree during which time I am serving in an internship which
is reqLli~d in oroer th;:ll I may receive pr~feuj,)n..1 reCOlllition requirll'd fO begin my profeSSional pi'llctice or servicc, or serving in an inlernship or residency
program leading to.ll degn:e or certificate awarded by an Inslit,unon o( hIgher education, a hospital or.ll health care facility that offers postgraduale 1l1lining;
(0) For a pcnod nOI In excess: of one (1) year dunng whIch I as a mOth.::r of pre.st:hool ,ge children, wilo hili entered or tclentered the work force. un
being- p~iQ lit a r.'te whic!l dCleS nor exc"ed ~1.00 at-.wc rh.~ IT;~,,jro:''r(, h;::l:...1; ......5(. ..~UlbIi5hca by seCCiOD 6 of rilc Fair '-'lOOr Sfandards Act 0:'1938;
(E) for a po:riod not in excC$.i of six months if .
(i) I am pregnant, carirlg for my newborn baby, or c.ring for a child immediately after he Ot she was placed with me through adoptiOn and I am not .lit.
tending an eligible InSlitution of higher eQ\lcation or being gainfully employed during lhe SIJ( month period, and
(ii) I wu enrolled as at least a half-time student al an eligible itl$tit1,ltion within six monlhs of the first day of that period; and
(F) Ouring.ll si;( (6) mQnlh period (ollowing the expinttiOn of !lny defe:nnent provided in paragraph, V1(I)(A) through VI(t)(E).
(2) The l..cndillglnstitution may, upon my WTiuen request, defer my scheduled repayments if it detennines th.tthe defermcnt is nCCClUry 10 avoid a finan.
cial hanjship for me. Jnte~t, however, will continue to aCCl'\le
Vn. CANCEI.).A nON FOR TEACHING
(1) I am entitled to have up fO 100 percent of the amount of thislcan pllllthe interest thereQft cancelled jf I undertake service.
(A) A,I. ful/-time teachet for a complele academic year in a public or pther nonprofit elementary or secondary school which il in the school district o( II.
local cducational agency .....hich is eligible in sllch ~ar of service for fundlund.::r Chllpcer I of the .e<fucation G:lnsolid.ation and Impn;wcment Act of 1981, as
amended, and which h.. been desig:natlld by lhe Secrelary (after consultation with each State Departmenl of education) in accordance 1\Iith the provis.iOfUi of
section 46.5(a)(2) of thll ACI a$ a school With a hIgh concentl11tiOn of $ludenl$ from low-income families. An official Directory of desipated low.inrom~
s.chOOlsispublishedannuaUybYfhe Secretary.
(B) As a full.time teacher of handicapped children. (including mentally retarded, h;ln:! of hearing, deaf, speech and language impaired, visually hand.
icapped, seriously emolionally dIsturbed, onhopcdicllHy Impaired, chIldren with speCIfic learning disabilitIes, or ocher health-impaired chJidrcn, who by tcason
O'
thereof require special education and n:Jated services) in a public or olher nonprOfit elementary ar secondary school system.
(2) This loan will be cancelled at the following nues:
(A) 15 percent of the tocal principal amount of the loan plus interest en the unpaid balance will be cancelled for the first and second ~omplete academic
yearsofth.llcaching5Crvice,
(B) 20 percent of the lot.l principal amount plus interest on the unpaid balance for thc third and fourth complete academic years of that teaching service,
(C) 30 perunl of the total principal amount plus interest on the unpaid balance for the fiOh complete academic y"r of that teaching seMCe.
\1'111. HEAD START CANCEU,.ATION
(1) I am entitled to hIve up to 100 percent of the amount of Ihis loan plullhc inlCl'C$llhcreon cancelled if I undertake service u a full-time sian member in
. Head Stan program if.
(A) Tha. Head Sta" program il opera led for a period which iI comparable to I full school year in Ihe IocIlity, and
(B) My sallry js nOI more lhan Ihe Sllary ot a comparable empl~e of the I~I educalional aleney.
(2) Thia loan will be cancelled al the rate of 15 percent of Ihe 100al principal amount pllll interest on. lhe unpaid balance for each complete school year or lht
equi....lent of service in a Head Slart program.
(3) Head Start is a plCKhool provam carried oul under the Head Slart Act. (Subch,pler S, Cluipler 8 otTIlie V1 of Pub. L 97-]5, the Budlel Reconcilia-
tion Act of 1981; Connerly authorized under 5CCtion 222(.)(1) of the Economic Opport1,lnity Acl of 1964).
IX. MILITARY CANCELlATION
(1) I am entitled to have up 10 SO percent at Ihe principal amount at thillOlln plllllhe inlerest thereon canceJled if I serve al a member of the Armed FOrt'e$
at the Uniled Stales in an arca of hostilities Ihal qualifies tor special pay under seclion 310 otTilie 37 of the United Stales Code.
(2) This loan will be cancelled al the rale of 12 1/2 percent at Ihe tOlal principal amounl plloll inlerest on the unpaid balance for each complele year of such
seMce.
X. PEAce CORPS CANCELlATION
(1) I am entilled 10 have up to 70 percenl of the amount or Ihia loan plUllhe intereal thereon cancelled it I undertake service.-
(A) As a volunteer under the Peace Carpi Act; or
(B) As a volunteer under the OomeatiC Yo.Iunteer Service Act of 1973.
(2) This lOin will be t'lIncelled al the folloMn, ra.es:
(A) 15 pei'c:en. of Ihe tOlal principal amount of Ihe loan pllll interesl on Ihe unpaid balan.:e will be t'lIncelled for the fiRland second hvtllve-month period
ofvolunteerscrvice;
(B) 20 percenl of the tOlal principaJ amount of Ihe 1000n plUl interest on Ihe unpllid balance will be ClInc:elled for the third and fourth mlve-month period
ofvolunlee(scrviee.
XI. OEA.1lJ AND OISABILITY CANCEU,ATION
(1) In the evenl of my dealh, the lotal amO\lnl awed on this loan will be t'lInceiled. '
(2) If I become tOlally lIInd pennanenlly disabled after I ~ceive thia lOin, lhe Lending hlltitution will cancel the lotal amol,lnt of Ihis 198n.
XII. CHANOE IN NAME, ADO~, 'J'E.l,.EPHONB Nl,1MBBR AND SOCIAL SEClJRITV Nl)MBSR
I am responsible, and any endQrser is resp()ftsible, for info""ing lhe l,ending IllItll\,\tioll of Iny chanlt: or changa in Mme, address, telephone n\lmber pr so.
cialsecuritynumber.
(1) The Lcndinllrlltill,ltion may inlpolC alate charp if-
(A) I do nol mate a $Cheduled payment when it is d\le, and
(8) I do not submit to Ihe Lendi"1 hu:til\ltion on or berere the dat~ on which payment is due, dOCl,lmen!alion lhat I qualify for a deferment aT cancellation
described in Articles V1, VII, VIII, IX, X. and XI of this agreement.
(2) No charge mlY exceed twenty (%0) percent of my monthly, bimonthly OT quarterly paymenl.
(J)(A) The Lcndinllru:tilution may-
(i) Add Ihe late chlrre to the principal the day aneT Ihe SCheduled repayment....... dl,le; or
(ii) Inchxte it with .he nut lChedvled repayment atter I h_ receMd nOlice of Ihe late chafll:.
(B) If Ihe Lendinllnstilution c1eclI to add the U&e5lCd charge !O the oullitanding principal of Ihe 1000n, il mUlt 50 inform me before the due date oC the
nexrinstallment.
XlII. I,.J\TB CHAROE
(1) This note may be assipted by the Lendinalnsli,tution only to.
(A) The United Stales;
(B) AnOlher institulion upon my transfer to lbal inlitilution if lhat inslitulion is participating in this prop'Im; or
(C) Another illltilution appJOved by Ihe Secretaty.
(2) The pTQ'\lisionli of Ihil nOle that relale to the Lending 11lIlitl,ltion Shill, where appropriare, relate to In assignee.
XV. PRIOR LOANS
I hereby certify thai I hl~ listed below all of the Perkins Loans I h.~ obtained al other instiluliolll. (It no prior loalll have been received, stile "None.")
XIV. ASSIONMENT
SCHEDULE OF PBR,KJNS LOA,NS AT OntER INSl11Vf10NS
AMOUNT
DATE
NAMB OF INSTrrlrIlON
1.
,.
3.
4.
. XVI. SCHEOULE OF ADY ANCes
The fOll","nl amounts were advanced 10 me under thilloan agreement on Ihe dales indic:ate4:
AMOUNT
L $750.09
2. $7~0. QO
3.
DATE
7/87
12/87
SIONAllJRE OF BORROWER
'!.9,"'/l '/'1>t:U) Ijtl,d'
(7~('3) ;'U/((l rJ~j
4,
NOTIce TO BORROWER,: DO NOT SIGN TIUS NOTE BEFORE YOU READ fT. TIlE LENDING INsrrruTION MUST SUPPLY TO
YOU AND ANY ENJ;>ORSER A COpy OF '!HIS NOTE. (This nOle i.s .si~'ld a.s a scrlh" in5trument.)
SIGNA'I1)R.Il."'?<'\~ 7!,(~{.y()1."'-~ Dol' 1~//3
Permanent Add~treet ~ Number, City, Slal~, and Zip) W- (., / 7' ') 7J':1 T I-/J /vi R P. /jI( OM ()t\-:J k.
SQcial Security Number (bofTO'lWr muslprovi4e) ;10. -;'2 -ll-7,7
19E
p", / 7&03
The bo~r Ind l.,en4ing Ill5ti.lutio~ shall execut.e thi, note .without security and without endorsement unleu the bol1'OWer is a minor and Ihili nOle would
nOl, under the law o{.th~ Stale In wlll.ch the ~ndlnllrtslitullon is located, create a binding obligalion. If lhe botJOll/er is a minor and this note would not
therefore, be legally blndmg, the Lendlnl In.stltulion shall require a COIiigner to th.ili note:
SIONAnJR;e OP COSIGNER
Dale
19_.
Pennanenl Address (Slreel or Box Nl,lmber, City, State, Zip)
(20 U.S.c. 10870d)
(7/87)
Format by the National Association of Sludent Financial Aid AdministralQrs,
PERKINS (NDSL) TRUTH-IN-LENDING STATEMENT
DICKINSON COLLEGE
Account Number
2288-06
Name of Bon-over
Jing Miao Yang
Address
#6 Nine Station Road
Ardmore, PA 19003
ANNUAL PERCEN'l'AGE
RAn:
AMOUNT FINANCED
The cost of your
credit as a yearly
rate.
The amount of
credit provi.ded
to you.
Prior to
repaY1l1ent
During
repayment
o %
5
%
$1,500.00
I Itemization of the Amount Financed: $ 1,500.00
Amount given directly to you.
Late Charge: If a payment is late, you may be charged: $1.00 for the first
late paY1l1ent, and $2.00 for each subsequent late paY1l1ent if
this loan is payable monthly, $3.00 for each late paY1l1ent if
this loan is payable bimonthly, $6.00 for each late paY1l1ent
if this loan is payable quarterly.
Prepayment: If you payoff early, you will ~ 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
BORROWER
./"
fi.-tAt ItI(Jt.{)
p~
INSTITtrrIONAL
REPRESENTATIVE
c:Jj 7'Z--L-J .L7
1'-/>//; g
'.... ,'.',
DATE 1!-1 ~~/~
, ' .
DATE
DICKINSON COLLEGE
CARLISLE, PENNSYLVANIA 17013
-06
PROMISSORY NOTE. PREVIOUS BORROWER
PERKINS LOAN PROGRAM (formerly National Direct Stu'dent Loan)
l. . . ,1i'1~mi~o Yano . .,' . --:____promiselopayrO
Oicldnron CollelJ.c (hertln aftef called IheLcndlnl Inslllllllon) local(-d III Carli.<le, Ptnn.~'k;lnla the .'IUll of the lIm(lunlS thai arc advanced to
me and endorsed in the Schedule of Advance's sel fOrlh IKlow. I pronllse III t'!ay;lll ;uh,rn"..'" Ie",! and or her reollsonable roll<<lion cons Ind
cnarlltS necessary for rhe collection of any amaUl'1l nor paid when "ue. I furlher unrletsland and I&ree thaI:
I. GhNERAL
(1) ADrllielble l.aw, All 111m. advanced under this note are drawn trom I fund ctelled under Pili a or TIlle IV ot the Higher EducatiOn Act ot 1965, II
amended, hcrein.ClC.l" called the Act, and Ire .subject 10 the Act and the Fedcl1Il Regulations issued under Ihe ACI, The terms ot this note shall be inter-
preted in accordance 'Vith the ACI and Federal RclUlations, copies ot which are 10 be kept by the Lending Inslitulion.
(2) ProcedufC$ .(or R~cef~J1' Determenf or Ca:,\ccllation. I undersland thai in order 10 reeeive a deferment or ancellalion, I must requeat the defermenl or
c:anc:ellation in wriling from Ihe Lending Institution, and muS! submit to the Lending Institution any documentation required by Ihe Lendins Inuitudon to
prove thai l qualil'y for the deferment or cancellalion. I further undentand that if I am eligible for deferment or canc:elfllion under Ar1ieles VIlhrough X, I
am tc5ponsible for submilting the appropriate requests on lime. I further understand that I may lose my deferment and cancell"ion benefits it I fail to file
myrtquestontimt.
II, INTEREST
Interest shall accrue from the beginning of the repayment period and shall be at the ANNUAL PERceNTAGE RATE OF FIVE PERCENT (5%) on
the unpaid balance, C.Kcept that no interest shall accrue during any defennent period described in para,graph VI(1).
III, REPAYMENT
(1) t pl'Omise to repay the principal .nd the interest whiCh a"'rues on it to the unding Institution over. period beginning 6 months .fter the date I ce.se to
be at least a half-time swdent at an institulion of higher educalion, or at . comparable institution outside the United Stales approved for this putpo&C by the
United States Secretary of Educ:ation (hereinafter called the Secretary), and endini- unless paragraphs 1lI(4), III(S), 1JI(7), or VI(I) applies, to years later.
(Z) Upon mywrltlen requesl, the repayment period may start on a date earlier than the one indicated in paragraph 11I(1).
(3)(A) J promise to repay Ihe principal and inlerest ()\Ier the course of the repaymenl period in equallnonthIy, bimonthly or quarterly installments as deter.
mined by the Lendinllnstilution. 1 understand that if my monthly payment for alJthe loans made 10 me by the Lending Institution is not a multiple ol 3:5,
the Lending Institution may round thai payment to the next highut dollar amounlthal is a multiple of 15.
(D) Notwithstanding paragraph IU(3)(A), upon my written request, repaymenf may be made in gTlduated installments in accordance with a schedule ap-
proved by the Secretary.
(C) The Lending Institution shalllllach the schedule of repayments and the schedule will become part or the note.
(4) Notwithstanding patlllJ"llph IU(l), if I qualify as a low-income individual during Ihe repayment period, the Lending Institution may, upon my written re.
queSI, extend the repa)'l:l1ent period for up to an addJtional 10 years, or adjusl any repayment schedule to reflect my income, or both.
(5)(A) If the monthly rate thai would be eslablished under p.ragraph 11I(1), or the total monthly repayment rate of principal and interest on all my Direct,
Defense and Perkins Loans includil'li this loan, is less than $30 per month, I sharr repay the principal and inte~t on this loan at Ihe rate of $30 per month
(which includes both principal and inlerest).
(5)(B) If I have received Direct, Defense and Perkins I,.o4ns from olher institutions and the tOlal monthly repayment !"lUe on those loans is leu than $30, the
3:30 monthly nte established under subparagraph 1II(5)(A) is the rate f pay on arr my outst.nding Direct, Defense and Perkins Loans and is not in addilion
to the amount I pay on Iho.lie other loans. The amounl of my monthly repayment rate aUributlble to this loan is the amount which representli the difference
between $30 anq the monthly rates I must pay on my olher Direct, Defenlie and Perkins I...o.1ns.
(6) The lendillS Instl!ulion may permit me to pay less than the rate of 3:30 per month for a period of not more than one year where necessary to avoid
hardship to me unless that aclion WQuld extend the repayment period in paragraph III(t).
(7) The Lc:nding Inslilution may, upon my written request, reduce any Kheduled repayments or ell'tend the re~yment period indicaled in paragraph UI(I),
if, in its opinion, extraordinary circumstances such If prolonged illness or unemployment, prevent me from making the scheduled repayments. However, in.
terest shall contin\le to accrue,
rv. PREPAYMENT
(1) I may, at my option and without penalty, prepay all or aily part of the principal, plus the accrued interest thereon, at any time.
(2) Amounts I repay in the ac:ademicyear in which the loan Vo'1IS made v.ill be used to reduce the Amount of the lOAn and wi1l not be considered a prepayment.
(3) It I ~pay more than Ihe amount due for any installment, the exeess v.i11 be used to prepay principal unless I designate it as an Advance payment of the
ncxtregularinst.llment.
V. DEFAULT
(1) The Lending Institution may, at its optioil, declare my loan to be in default and may demand immediate plyment ot the entire unpaid balailce of the
loall, including principal, interest and late charges if .
(A) I do not make a sch~duled payment \lIh~n itls due, and
(D) J do not submit 10 Ihe t..cndin, Institution on or before the date on which payment is dllC, doeum~ntJtion Ihat i qLlalify for a deferment or eanc~l!a1ion
described in Articles VI, VIl, vm, IX, and X of thil agreemelll,
(2) I \lndentand; that if I aee'lllt on my loan repayments, the l,.c:nding Inlliturion may disclose that I have defaulted, .Iong with other relevanr information, to
credit bUreau orpnitations,
(3) Purth~r, I undetstand Ihat ie I default on my 101/'1 repayment and the loan is s~nl to the Secretary for collection, the Secrelary may disclose that J have
defaulted, along with other rel~nt information, to credit bureau organizations.
(4) I undelltand that if the l,cnding Institution Icc:elerates the loan under paragraph Vel), I will lose my cancellation and deferment benefits for service per.
formed after the date the Lending Institution accelerated the loan.
(5) J undelltand Ihat failur$ to pay thi. obligation under the terms agreed upon will prevent my obtaining additional student financial aid authorized unQer
Tille IV of the Higher Education Act of 1965, as arnen4ed, unlill have made amngement5 which are satisfactory to the J,..cnding Jnstitution or the SecfCtary
recarding the repayment of Ihe loan.
VI. DEFERMENT
(1) Interest will nOI 'CCNe, and' installments of principal need not be paid.
(A) While I am enrolled and in attendance as at least a half'lime student at an institulion of higher education or at a comparable institution oul5id~ the
United States approved for this purpose by the St:cretal)'.
(8) For a period of three (3) )"Can during which I am .
(I) On fuJl.time aclive duly as a member of Ihe Anned Forces of the United States (Army, Navy, Air Porce, Marine Corps, or Coast Guard) or an officer
'n fuJI-time active duty in the Commissioned CQtpS of Ihe U.S. PUQlic Health Service,
(ii) In service as a volunteer under th~ Puce Corps Act,
(iii) A volunteer under the Domestio Volunteer Service Act of 1913 (ACTION prolfllms),
(iv) A full.lime VQlllnteer in A ta,x..cxempl organiution pctfonning service comparable to the lervice performed in the Peace Corps or IInder the Domu-
ic Volunteer Scrvice Act of 1973, or
(v) Temporarily totaJly disabled as Cltabllshed by An affidavit of a qualified physician, or unable 10 secure employment because I am providing care re.
luired- by my spouse who is so disabled,
(C) For a period not in ace" of two (2) yea,. after I receive a baccalaureate or professioilal degree during which time I am servin&, in an internship which
s reqllired in or<ter th.t I may receive professional recognition required to begin my profeSSional practice or service; and
(D) During: a six (6) month periOl;t foJlowlng the expiration of my defennent in paragraph VI(l)(A) through Vl(I)(C).
2) The Lc:nding Institurion may, upon my written request, defer my scheduled repayments if il delermines thai the deferment is necessary to avoid a (;nlln.
'i:l! lIal'\lshiJj iur me. IlHo;rest, h~lIer, wi1l ~ontinue 10 aCCl1Je.
VII. CANqU.ATION fOR TEACHING
1) I am entitled to h.w up to 100 percent of the amount of this loan ph"s the interest thereon cancelled if I undertake "Mce.
(A) As a full-time teacher for a cQmplete academic year in a public or other nonprofit elemental)' or secondary school which is in Ihe school d!striCf of a
ocal educational agency which is eligible in such year of service for funds under Chapter I of Ihe Educalion Om50lidation and Improvement Act of 1981, as
Imended, and which has been designated by the Sectclal)' (after consultation with each Slale Department of 8dllcation) in acC'Ordance wilh the provisions of
ection 465(a)(2) of the Act II . school with A high concentration of students from low.income familiC$. An official Directory of designated law-income
chaols is published annually by the Secrelary.
(8) As a f\lll-time t~acher of handt'cappc:d children (including mentally retarded, hard of hearing, deaf, speech And language impaired, visually hand.
Clipped, seriously emotionally diSl\'rOed, orthopedically impaired, children with specific learning disabilities, or Olher health-impaired children, who by reason
hereof require special education and related services) in,fj public or other nonprofit elemenlary or secondary school system.
2) This loan wi1J be canceJ1ed at rhe following rates:
(A) IS percent of the lotal princi~l amounl of the loan plus inrerest on the unpaid balance will be cancelled for rhe firs:t and second complete a':adenttc
earS of thai teachingsetvtce,
(8) 20 percent of the total principal amount plus interest on the unpaid balance for the third and fOllnh complete academic years of that leaching service,
,d
(C) 30 percent of the total principal amourtt plus interest on the unpaid balance for the fifth complete academic ~ar of that teaching 5ervice.
Vtn. HEAD srART CANCELLATION
(1) 11M entitled 10 have up to HIO pcreent of the amol,lntot thu Joan plus the interut thereOn cancelled Jr I undertake 'Crvice "' full-time Itlff member in
. Held Start prosram if.
(A) That Head Start ptogr'lm is operated (or a period ""hleh is compll"llblc 10' fulllChool year in the 100001lty, and
(B) My salary is nOI more than the Alary of. comp.rtl.ble emplO)"tc of the lOCI] cduCllional arncy.
(2) Thill loan will be cancelled at the I"IIte of 15 pereent ot the 10111 princip.1 amount plus lnlerul on the unpaid balance for each complete school yur Df tbe
equivalent of service in I Head Start prognm.
(3) Head Start is. preschool prognm curied out under the Head Start Act. (Subchapter B, Chapter 8 of TItle VI of Pub. L. 91.35, the Budget Recondlia..
tion Act of 1981; formerly authorized under Icctlon 222(1)(1) of the Ecorlomic OppOrtunity Act of 1964).
IX. MILITARY CANCELLt\TION
(1) I am entitied to ha~ up to SO percent or the principal amount of this I~n plus the interest thereon cancelled if I selVe as a member of the Armed Fotce5
of the United States in an area of hqstilitie.s that qualifi~ for apecial pay under section 310 ofntle 37 of Ihe United States Code.
(2) This loan will be cancelled at the rare of 12-1/2 percent of the total princiPill amount plus interest on the unpaid balance for each complete)"tllr of JUch
service.
x. DFAm ANI> VISABIUIY CANCElLATION
(1) In the event of my death, the total a."ount Q"IlIed on this loan 'Will be cancelled.
(2) If I beCQme totally and permanently diubled arrer I receive this loan, the Lending Institution will eancelthe total amount of this lOin.
Xl. CHANGE IN NAME, ADDRESS, TELEPHONE NUMBeR AND SOCIAL SEctJRrTY NUMBER
I am responsible, and any endorser Is ruponslble, for informing the Lending Institution of any change or changel in name, address, telephone n\lmber or 10-
ci.lsecuritynumber.
XII. I..ATE CHARGE
(1) The Lending Institution may impose alate charge if-
(A) I do not make a Kheduled payment when it Is due, and
(9) I do not submit to tht! I,..ending Institution on or before the date on which payment is due, documentation Ihat I qualil'y for a deferment or cancellation
described in Articles VI, VII, VlJI, IX, and X of this agreement.
(2) No cha:ge may exceed twenty (20) percent o( my monthly, bimonthly or quarterly payment.
(3)(A) The Lending Institution may.
(I) Add Ihe late chlfie to the principallhe day after the scheduled repayment _s due, or
(ii) Include il with the next liCheduled repayment alter I have received notice of the late charge.
(8) If the Lending Instilution elects to add the a"essed charge to the out$tanding principal ol the Joan, il mu.t so inlorm me belore the due date o( the
nextin.tallment.
XUI. ASSIGNMENT
(1) This nOle may be lIS$igned by the Lendin, Institution only to .
(A) The United Stat~
(B) Another institution upon my Innsfer to Ih,t institution if Ihat institution is participaling in Ihis pl'Og:ram; or
(C) AnOlher instlllltion approved by Ihe Secretary.
(2) The provisions pf thi. nPte that relale to Ihe 1-cnding Institution shall, where appropriate, ~Iale to In aulplee.
XIV. PRIOR LOANS
I hereby certify that J have listed belQllf all of the Pt!rkins Loans (National Vire~t Sludent loan. Ind National Defense Student ["QIrtS) J have obtained at
other institutions. (If no prior loans ha~ been rccei~d, stale "None..)
SCHEI;>ULa Of PERKINS LOANS (NATIONAL DIRECf S11)OENT I..OANS AND NATIONAL DEFENSE snJOENT LOANS) AT
OTHER IN~ONS
AMOUNT
DA'IB
NA,ME Of INSlTIVIlON
l.
:,
3.
..
XV. SCHEDULE Of ADVANCES
The (ollov.ing amounts"re advanced to me under this loan a~ement on the dales indicated:
AMOUNT
1, $750.00
:, $750,00,
3.
DATE
7/88
12/&8
SIGNAruR.e Of BORROweR
J'rt!W&tr) ~,
\) ie~ 111Ai:'0J I ~1
..
Nones TO PORRQWER,: 1)0 NOT SIGN nns NOTE BeFOR.B YOU R,BAV IT. 'IHE J..BN1)INO INsrrronoN MUST SUPPLY TO
YOU AND ANY ENOOR,SER A COpy ~THIS NOTE. (This note is SIgned as a sealed 1O'll'\Iment.)
5IONATUR,I! .'\ 1 11 e Ii'\.{ t([) j Cl.,~ D... i 2/r 19 e k
Pennanent Add~1Stre{J,r Sox N\lmber, City, Sllte~'nd Zip) Cl C7ft'.( (, ~-\..-~ J<o,??{ ,:/ f,,'?tt.-Vl,e,.uyp /)a. ~1 i.) (J 5-
$odaISecuriIyNumber(bo",.,.,.-ermw:tptoYide) /11./ -b 2. -(J-l1.
'The boJ'rQ'llier and Lending Institution shall execute this nole without ceCl,lrity and without endorsc:ment I,Inlcu the bOl'rOlWr is a minor and this note ""'uld
not, ulIder the la......O(.lh~ Stile in ....hic:h the Lending Institution iJ located, c~le a binding obliplion. Il the bo~r is I minor and thi. nole 'WQuld not
therefore, be legally bIndIng, tht! t.ending Institutioft sha/l require a cosigner 10 Ihis note: '
, . il f
SIGNATtJRJ3OF COSIONER --J-I i___ ~- l-lL.(fL(/ ::,>1"-,, c-
o '( i .
p,,,....,, Add.... (5'.."., Box Numb"'~ty, St.... ,"d Zlp) .
.Dlte
1"/5
et
19_.
(20 U.s.C 1087dd)
Pormat by the National Auoci.tloll of Student Financial A.Id Admilllltntofl.
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
ThO~L..
Assistant Treasurer of Dickinson College
Dated:
F ;\F JLESIDA T AFllE\Dickinson College 7619\DickinsonCollegeCollections 7619CIDocurnents\225-com1 ,'Npd
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:
ling Miao Yang
9 Hawthorne PI. 9B
Boston, MA 02114
MARTS ON DEARDORFF WILLIAMS & OTTO
BY~-~
Marti Then
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: November 5, 2003
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F: \FILES\DA T AFILE\Dickinson College 7619\DickinsonCollegeCollections7619C\Documents\225. pra I/mai
Created: 4128/03 1:54:03 PM
Revised: 11/24/034 12:06 PM
7619c.225
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-.51'23
CIVIL ACTION-LAW
DICKINSON COLLEGE,
Plaintiff
JING M. YANG,
Defendant
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE TO DOCUMENT SERVICE AND COST OF SERVICE
PURSUANT TO THE PENNSYLVANIA LONG ARM STATUTE
I hereby certifY that a copy ofthe Complaint was mailed to Jing Maio Yang on November
5, 2003, by certified mail, restricted delivery, return receipt requested.
Attached is the Post Office return receipt signed and dated November 17, 2003 and a copy
of the receipt showing the cost of service was $8,61.
F WILLIAMS & OTTO
By "-
David R. Galloway, Esquire
I.D. No, 87326
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Date: November 24, 2003
Attorneys for Plaintiff
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,....:::f Postage $
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m Return Receipt Fee
o (Endorsement Required)
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(Endorsement Required)
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Total Postage & Fees $
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CERTIFICATE OF SERVICE
I, Marti Then, an authorized agent of Marts on 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:
Jing Maio Yang
9 Hawthorne PI 9B
Boston, MA 02 I 14
MARTS ON DEARDORFF WILLIAMS & OTTO
B/---fI!vAi:;;~ UIL"i'--
Marti Then
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: November 24, 2003
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DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
NO. 03-5823
CIVIL ACTION-LAW
lING M. YANG,
Defendant
JURY TRIAL OF TWELVE DEMANDED
TO: JING M. YANG, DEFENDANT
NOTICE OF ENTRY OF DEFAULT JUDGMENT
-
You are hereby notified that on / _ / J - (J Y ,2004, the following Judgment was
entered against you in the above-captioned case: $8,129.82 plus interest from October 23,2003, in
the amount of$52.08, attorneys' fees in the amount of$675.00 for a total of $8,856.90, plus costs
of suit and interest from date of judgment as per the Notes attached to the Complaint for Defendant's
failure to file an answer to the Complaint.
Date:
/-/~'Df
prot):ot;f- ~ -,~~<:s--
I hereby certify that the name and address of the proper person to receive this notice under
Pa. R. Civ. P. 236 is:
Mr. ling Maio Yang
9 Hawthorne Pl., 9B
Boston, MA 021 14
F: IFILESIDA T AFILEIDickinson College 7619IDickinsonCollegeCollections7619C\Current\225. pral/tde
Created: 4128/03 1:54:03 PM
Rcvised: l/15104 0:58:33 PM
7619c225
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v,
NO. 03-5823
CNIL ACTION-LAW
JING M. YANG,
Defendant
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE
Enter default judgment in the above-captioned action in favor of Plaintiff and against
Defendant in the amount of$8,129.82 plus interest from October 23,2003, in the amount of$52,08,
attorneys' fees in the amount of$675.00 for a total of$8,856.90, plus costs of suit and interest from
date of judgment as per the Notes attached to the Complaint 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 December 29,2003, which
date was subsequent to the date default occurred and at least ten (10) days prior to the date of the
Praecipe.
MARTSON DEARDORFF ILLIAMS & OTTO
By
David R.
I.D. No. 87326
Ten East High Street \..
Carlisle, P A 17013-3093
(717) 243-3341
Date: January 15, 2004
Attorneys for Plaintiff
F:\FJLE.SIDA T AFlLE\Dickin~on College 76] (
Created 4/28/03 L54:0JPM
Revised: 12/29/03 9:54:00 AM
7619c.225
5onColJegcCollcClions76 I "C\DoClll11ems\225,llu( limai
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v,
NO. 03- 5823
CNIL ACTION-LAW
JING M, YANG,
Defendant
JURY TRIAL OF TWELVE DEMANDED
TO: JING M. YANG
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 MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS,
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 HIRlNG A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE 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, PA 17013
Telephone:(717) 249-3166
MARTS ON DEARDORFF
~2"/}
By <. (.(
David R. alloway, Esquire
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Dated: December 29, 2003
U,S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE - POSTMASTER .{!!J.G ,))..'5'.j ""
Received From:
ilItAl'n'DlIElliIICM WR.'-" 01TQ,
ler' Ea...j- fLl'" S1.cJ
(o.vL ,1<<- fA ) 7C(:<::,
,
One piece of ordinary mail addressed 10:
,JI"1 At".I u Ya~
9 iJaw'f/UJI;i\ e. '-rb!, 'i'-5
.l3o;,1uY\. Au ()~(I'f
\
PS Form 3817, Mar. 1989
lS
Id
"
"
CERTIFICATE OF SERVICE
I, Tricia D. Eckenroad, an authorized agent of Marts on 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:
Mr. Jing Maio Yang
9 Hawthorne PI 9B
Boston, MA 02114
MARTS ON DEARDORFF WILLIAMS & OTTO
/J
ncia D. Eckenroad
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: January 15, 2004
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F\FlLES\DA T AFILE\Dickinsl1nCollege76 19\Collectlum\C"ITcnt\2?S\jl\'''::>'
Cr~~ted 5/20/05 II :09/\11.1
Revis1:'J, 5/'-31\\5 },S5PM
7619('225
David R. Galloway, Esquire
MARTS ON DEARDORFF WILLIAMS & OTTO
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DICKINSON COLLEGE,
Plaintiff
v.
NO. 03-5823
CIVIL ACTION-LAW
JING M. YANG,
Defendant
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE
Please reinstate the attached Complaint against Jing M. Yang, in the above-captioned action
and return same to the undersigned for service,
F WILLIAMS & OTTO
By
David R. Gal oway,
1. D. Number 87326
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Date: May 23, 2005
Attorneys for Plaintiff
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