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Home My WebLink About03-6006F\FILES\DAYAFILE\Dlckinson Collage)619\DickinsmColleg ollec[ions]619C\DOumcnn\209-comI wpd\had Created -3/10/03 9.25:51 PM Revised: 11/16/03 0 49'.19 PM 1619c.209 DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff' CUMBERLAND COUNTY,, PENNSYLVANIA V. NO. C Q - `CO 1? CIVIL ACTION-LAW r ELIZABETH PACE SCHAPIRO, and KATHERINE E. SCHAPIRO, Defendants 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 County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 & OTTO Dated: November 17, 2003 David R. Gallovvay, E; I. D. Number 87326 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. ' G CIVIL ACTION-LAW ELIZABETH PACE SCHAPIRO and KATHERINE E. SCHAPIRO, Defendants JURY TRIAL OF TWELVE DEMANDED COMPLAINT AND NOW, comes Plaintiff Dickinson College by and through its attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and hereby avers as follows: 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, Elizabeth Pace Schapiro, (hereinafter "Parent"), is an adult individual with a last known address of 1500 Glencoe Road, Glencoe, Maryland, 21152. 3. Defendant, Katherine Schapiro, (hereinafter "Student"), is an adult individual with a last known address of 1500 Glencoe Road, Glencoe, Maryland, 21152. 4. On or about July 20, 1999, Parent and Student entered into a Promissory Note (Note # 1) with Plaintiff for the financing of $7,800.00, plus interest, for educational services and benefits to Student at Plaintiffs institution. A copy of Note #1 is attached hereto as Exhibit "A." 5. Note #1 grants Plaintiff reasonable collection and attorneys' fees which Plaintiff has calculated to be $1,170.00. As of November 6, 2003, the principal and interest due and payable by Parent and Student to Plaintiff was $9,084.35, plus interest in the amount of $.97 per day from November 6, 2003. Parents and Student stopped making monthly payments on Note #1 on or about March 27, 2000. 8. As of November 6, 2003, the outstanding balance of $9,084.35 represents the total and actual overdue value of the financing provided to Parents and Student under Note #I for which they have yet to pay. 9. Plaintifffulfilled, performed and complied with all obligations and conditions ofNote #1. COUNTI BREACH OF CONTRACT Dickinson College v. Elizabeth Pace Schapiro & Katherine E. Schapiro 10. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 9 of this Complaint. 11. Parents and Student breached the expressed and implied obligations, conditions and terms of agreement of Note #1 by failing to pay the amounts financed therein. WHEREFORE, Plaintiff demands judgment against Defendants, Elizabeth Pace Schapiro and Katherine E. Schapiro, in the amount of $9,084.35, plus interest in the amount of $0.97 per day from November 6, 2003„ collection and attorneys' fees in the amount of $1,170.00 and costs of suit. COUNT II INQUANTUMMERUIT Dickinson College v. Katherine E. Schapiro 12. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 11 of this Complaint. 13. Having requested Plaintiff to loan money, and doing so to the benefit of Student, Student became liable to Plaintiff for said money. 14. Student has been unjustly enriched by accepting said money without paying Plaintiff reasonable compensation therefor. 15. The total amount by which Student has become enriched is $9,084.35, plus interest in the amount of $0.97 per day from November 6, 2003. WHEREFORE, Plaintiff demands judgment against Defendant, Katherine E. Schapiro, in the amount of $9,084.35, plus interest in the amount of $0.97 per day from November 6, 2003, collection and attorneys' fees in the amount of $1,170.00 and costs of suit. MARTSON DEARDORFF WILLIAMS & OTTO 7:;; David WGallow I.D. No. 87326 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff Date: November 17, 2003 DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - PLAN B EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT July 20, 1999 1. Seller: Dickinson College, Carlisle, Pennsylvania 17013-2896 Buyer(s): Elizabeth Pace Schapiro 1500 Glencoe Road Sparks - Glencoe, MD 21152 If there is more than one Buyer, each of you will be obligated, jointly and severally, for all sums due and for the performance of all agreements as provided in this Contract. Under the terms of this Educational Goods and Services Retail Installment Contract, you have agreed to pay the expenses incurred for goods and services to be provided and rendered, as the case may be, to Katherine E. Schapiro (hereinafter "Student") during his/her enrollment at Dickinson College during the 2000 academic year, including tuition, room and board, books and supplies as herein stated (hereinafter the "Goods and Services"). The Goods and Services shall include only tuition, room and board. II. TERMS OF PAYMENT AND PAYMENT SCHEDULE Disclosures Required by Federal Law ANNUAL FINANCE AMOUNT TOTAL OF TOTAL SALE PERCENTAGE CHARGE: FINANCED: PAYMENTS: PRICE: RATE:* Dollar amount Amount of credit Amount paid by Total cost of Cost of credit as credit will provided by Buyer as total purchase on yearly rate cost buyer Dickinson College of all scheduled credit, including payments down payment of -7&t)c) $ 19,735.00 8.75% $ 631.04 $??, o00 $ 10,631.04 $ 29,735.00 Rev 2/92 Schapiro Buyer's payment schedule will be as follows: Number of Payments Amount of Payments When Payments are Due 16 $ 664.44 Monthly commencing 09/28/99 until 12/28/00 *Variable Rate: The ANNUAL PERCENTAGE RATE disclosed above is a variable rate and may change. The ANNUAL PERCENTAGE RATE may increase during the term of this transaction if the prime rate of interest announced in the Wall Street Journal as of the close of business on June 30 of each calendar year increases, and will be increased to the prime rate plus I%. The ANNUAL PERCENTAGE RATE will not increase more than once a year, and the new interest rate will become effective on July 1 following the increase, if any, in the prime rate of interest. Any increase will be in the form of higher payment amounts. If your cost of the Goods and Services sold hereunder were $10,000.00 at 8.75% per annum for 16 months and the prime rate plus I% were increased to 9.75%, your regular monthly payments would increase to $669.04. Further, the ANNUAL PERCENTAGE RATE will not increase to more than 18% or such other rate as may be permitted under the Pennsylvania Goods and Services Installment Sales Act. Late Charge: If a payment is more than 15 days late, a sum equivalent to 5% of the late payment (but no more than $2.50 and not less than $1.00) may be charged. Prepayment: Buyer may prepay the unpaid balance of the Amount Financed and any FINANCE CHARGE due through the date of early payment, in full or in art, without penalty. SEE SECTION VI OF THE CONTRACT BELOW FOR ANY ADDITIONAL INFORMATION ABOUT NON- PAYMENT, DEFAULT AND REQUIRED REPAYMENT BEFORE THE SCHEDULED DATE FOR REPAYMENT OF THE AMOUNT FINANCED. III. ITEMIZATION OF AMOUNT FINANCED 1. Cash price of Goods and Services: $ 29,735.00 2. Total down payment: 19,735.00 3. Unpaid balance of cash price (I - 2): 10,000.00 4. Amount paid to others on Buyer's behalf: - 0 - 5. Amount Financed (3 + 4): $ 10,000.00 IV. CREDIT INSURANCE Credit life insurance for the terra of this Contract is not required. V. NO WARRANTIES THERE ARE NO WARRANTIES, EITHER EXPRESSED OR IMPLIED, GIVEN BY SELLER IN CONNECTION WITH SALE OF THE GOODS AND SERVICES COVERED BY THIS CONTRACT UNLESS BUYER HAS BEEN GIVEN A SEPARATE WRITTEN WARRANTY. VI. ADDITIONAL PROVISIONS Buyer agrees to pay Seller the Total Sale Price by making the total down payment and paying Seller the Total of Payments in the number and amount of monthly payments shown in the Payment Schedule. Payments are due on or before the same date of each month as the first payment date. Payments must be made to EFG Technologies, Inc. at the following address: EFG Technologies, Inc. P.O. Box 64974 St. Paul, MN 55164 3. Buyer's legal rights include the right to pay all or part of the amounts due on this Contract in advance of their due dates, to obtain a refund or credit of unearned Finance Charge whenever the amount is paid in full in advance, and (with Seller's consent) to reinstate the Contract if Buyer timely cures any default. 3. Buyer shall be deemed to have committed an "Event of Default" of the Contract upon the occurrence of any of the following: (a) failure to make any payment on or before the date it is due, (b) failure to make a payment on any other Contract outstanding with Seller, (c) failure to perform any other provision of the Contract, (d) providing Seller with false information or signatures. (e) death, incompetence, or conviction of any Buyer of crime involving fraud or dishonesty, (f) insolvencv or bankruptcy of anv Buyer. 4. Upon or after the occurrence of any Event of Default, Seller will provide Buyer with notice, by certified mail as required by law, addressed to Buyer's last known address as shown on Seller's records, advising Buyer of the default and of Buyer's right to cure the default. The notice will provide the time, amount and performance necessary to cure the default. If Buyer does not cure the default a provided in the notice. Seller's rights shall include the right to declare all sums due on the Contract to be immediately due and payable. The Buyer agrees to pay all attorney's fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. 5. Waiver by Seller of any Event of Default shall not be binding upon Seller if Seller should thereafter choose to exercise that or any other right or a similar Event of Default occurs later. All Seller's rights and remedies shall be cumulative. Seller's exercise of one or more rights shall not cause Seller to lose any other rights. 6. This Contract is freely assignable by Seller. Buyer agrees that upon receiving notice of the assignment Buyer shall be obligated to the Assignee of this Contract. which Assignee shall have all of Seller's right and remedies. 7. If any part of this Contract is held to be illegal. void or unenforceable, that provision shall be deemed not to have been a part of this Contract, which shall otherwise remain fully effective. 8. APPLICABLE LAW: This Agreement, whenever called upon to be construed, shall be governed by the domestic internal laws of the Commonwealth of Pennsylvania except to the extent supplemented, superseded or preempted by federal law. 9. CONSENT TO JURISDICTION. VENUE AND SERVICE: The parties to this Agreement consent and agree that all legal proceedings relating to the subject matter hereof shall be maintained in the Court of Common Pleas of Cumberland County, Pennsylvania, or, if applicable, the United States District Court of the Middle District of Pennsylvania, and all parties hereto consent and agree that jurisdiction and venue for such proceedings shall lie exclusively within said court. Service of process in any such proceeding may be made by certified mail, return receipt requested, directed to the respective patty at the address set forth above. 10. This Contract shall be binding upon the parties hereto, their heirs, successors, assigns and legal representatives. 11. TIME IS OF THE ESSENCE OF THIS CONTRACT. NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST' THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. NOTICE TO BUYER: (1) DO NOT SIGN THIS AGREEMENT BEFORE YOU READ IT OR IF IT CONTAINS ANY BLANK SPACE. (Z) YOU ARE ENTITLED TO A COMPLETELY FILLED-IN COPY OF THIS AGREEMENT. (3) UNDER THE LAW, YOU HAVE THE RIGHT TO PAY OFF IN ADVANCE THE FULL AMOUNT DUE AND UNDER CERTAIN CONDITIONS TO OBTAIN A PARTIA, REFUND OF THE FINANCE CHARGE. BUYER(S) ACKNOWLEDGE(S) RECEIVING A COMPLETED COPY OF THIS CONTRACT AND INTEND(S) TO BE LEGALLY BOUND BY ITS TERMS. BUYER(S): (& - ( P/-'u. /,?J -OPA"" I AGREE TO REPAY ALL AMOUNTS DUE ON THIS LOAN IF THE BORROWER(S)/BUYER(S) FAILS TO DO SO IN ACCORDANCE WITH THE TERMS OF THE NOTE: STUDENT COSIGNER ?? ?^^{ ???a C TRANSCRIPT OF A STUDENT'S RECORD WILL NOT BE RELEASED IF LOAN PAYMENTS TO THE COLLEGE ARE IN ARREARS OR DEFAULT. DATE: Plan B Loans DICKINSON COLLEGE 7-20 -Sc BY 4 VERIFICATION I, THOMAS MEYER, Assistant Treasurer of Dickinson College, acknowledge that I have the authority to execute this Verification on behalf of Dickinson College and certify that the foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of this lawsuit. The language of this Complaint is that of counsel and not my own. I have read the document and to the extent that this Complaint is based upon information which I have given to my counsel, it is true and correct and to the best of my knowledge, information and belief. To the extent that the content of this Complaint is that of counsel, I have relied upon counsel in making this Verification. This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. Dickinson College --e- Thomas Meyer Assistant Treasurer of Dickinson College Dated: VU LESUDATA ILEVNckmew College )619U)ickh onCollegeCollmiom7619C D cu emuVN wml CERTIFICATE OF SERVICE I, Marti Iben, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Complaint was served this date by depositing same in the Post Office at Carlisle, PA, Certified Mail/Restricted Delivery, postage prepaid, addressed as follows: Elizabeth Pace Schapiro Katherine Schapiro 1500 Glencoe Road Glencoe, MD 21152 MARTSON EARDORFF WILLIIAMS &OTTO By 4L/ Marti en Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: November 17, 2003 1 ? ? i Cl) F: TILESTtATAFIM"ckisuon College]619\DickinsonCollegeCollections9619C\Wcum is\209.pra2/nlm Created 12/9/03 10 37AM Revised: 12/9/03 4;47PM 7619C209 DICKINSON COLLEGE, Plaintiff V. ELIZABETH PACE SCHAPIRO, and KATHERINE E. SCHAPIRO, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6006 CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO DOCUMENT SERVICE AND COST OF SERVICE PURSUANT TO THE PENNSYLVANIA LONG ARM STATUTE I hereby certify that a copy of the Complaint was mailed to Katherine E. Schapiro on November 18, 2003, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed by Carolyn L. Landin, agent for Katherine E. Schapiro. Attached is a Track and Confirm showing date of delivery was November 22, 2003 and a copy of the receipt showing the cost of service was $8.38. MARTSON David R. Galloway, Esqi I.D. No. 87326 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 WILLIAMS & OTTO Date: December 9, 2003 Attorneys for Plaintiff Ateow A -'4&M 7001 1140 0003 2518 8980 102M3MYrYw ( i't# ;#Pt ##1# Ip i I.11I •Y / I•: 1111/1 Ip ILY( :/1IN:11 G ,aws fiLEII * 311 2 o to rq l/-1 e' $O.&3 Postage $ $2.30 Ft.l Certiti.d Fee n \ Im O Return Receipt Fee (Endorsement Required) - ' p P } i` ? Restncted Ilelivery Fes . ? J (endorsement Required) Y t3 Total Postage & Fees s U.38 , Sent T M O ? Street Apt. No.; or PO Box No., _____----------- ?a i ................ ---------- ---------- USPS - Track & Confirm ITrAff 0 What is this? G°a k fii B11,,,, ati4 k-0rd?Pnt`;?!t 4 1i1 lY 15 1 41:P N J? i}1t pNiN? ilG i ? h .4411fl wi H §iYt.l4itd!t'ttk? !:1 it $ttl?9li h!N'M ill fti .?.?; MM Track & Confirm Current Status You entered 7001 1140 0003 2518 8980 Your item was delivered at 8:32 am on November 22, 2003 in SPARKS GLENCOE, MD 21152. Sdi,... ------------- ArelfB 'r > Notification Options ? Track & Confirm by email ® POSTALINSPECTORS Preserving the Trust Page 1 of 1 Track & Confirm Enter label number: I. Track & Confirm FAQs site map contact us government services Copyright =O 1999.2002 LISPS. All Rights Reserved. Terms of Use Privacy Policy http://trkcnfrml.smi,usps.com/netdata-egi/db2www/cbd 243.d2w/output 12/2/2003 CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Katherine E. Schapiro 1500 Glencoe Road Glencoe, MD 21152 MARTSON DEARDORFF WILLIAMS & OTTO BY YlaI& o- Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: December 9, 2003 c-; C i c. ? T r ? - n'?+ ?T7 G'. .__ t"-. .?,?' '" . '?n _ :•• i c.? -? P'.\FlLES\DATAPIL5\Dicklmon College 7619\Diak=mCollepCollectiam7619C\Doew nts@09_pal/nlm Created'. 1219103 1011AM Revmd'. 12/9/03 4'.47PM 9619C 209 DICKINSON COLLEGE, Plaintiff V, ELIZABETH PACE SCHAPIRO, and KATHERINE E. SCHAPIRO, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6006 CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO DOCUMENT SERVICE AND COST OF SERVICE PURSUANT TO THE PENNSYLVANIA LONG ARM STATUTE I hereby certify that a copy of the Complaint was mailed to Elizabeth Pace Schapiro on November 18, 2003, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed by Carolyn L. Landin, agent for Elizabeth Pace Schapiro. Attached is a Track and Confirm showing date of delivery was November 22, 2003 and a copy of the receipt showing the cost of service was $8.38. MATSONDE O 1 P BY David R. Galloway, Esquire I.D. No. 87326 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 & OTTO Date: December 9, 2003 Attorneys for Plaintiff c ,... t: . WPM. MCIG 77, ..' t * 7001 1140 0003 2518 8973 ..Y ,It I .. I ?, w f rr. • y i it . v I t111agliwt P / ?ra?7 ?n7J' 71/ ?n? IrLcr f'ov raoe Prnv/t m M1 ? ?PANIES 61.ENC?E t?'21152 - Postage $ ?. ...--. _......,. Ul IL Certified Fee t1.ia yy C3 Return Receipt Fee (Endorsement Required) _ ?. p Q Restricted Delivery Fee (Endorsement Required) @@ ?sp Total Postage & Fees y V / S / r? 8ent T. r9 Street, APt. No ? r g - O or Po Box N M1 c/ty, Ste N. Z/Pt TAI A /, fM.J] ?,/ J ?.4 USPS - Track & Confirm Page 1 of 1 Track & Confirm Current Status You entered 7001 1140 0003 2518 8973 Your item was delivered at 8:32 am on November 22, 2003 in SPARKS GLENCOE, MD 21152. Oa6sifs s '. Notification Options Track & Confirm Enter label number: I m Track & Confirm FACls Track & Confirm by email what Is this? c°s ® POSTAL INSPECTORS site map contact us government services Preserving the Trust Copyright O 1999-2002 USPS. All Rights Reserved. Terms of Use Privacy Policy http://trkcnftml.smi.usps.com/netdata-egi/db2www/cbd_243.d2w/output 12/2/2003 CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Elizabeth Pace Schapiro 1500 Glencoe Road Glencoe, MD 21152 MARTSON DEARDORFF WILLIAMS & OTTO By ? 7l /m Nichole L. Myers jJ Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: December 9, 2003 h c? r L? •i r l L ^y\ l CJ ? F\PIL5S\DATAPILO\Dickinson College 7619\Dickim,nCollege -Ilections]619C\Doeurr Un 209_stipl/drg Created 11/13/0211.2]29 PM Revised. 01/05/04020031 PM ]619c.209 DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 03-6006 CIVIL ACTION-LAW ELIZABETH PACE SCHAPIRO, and KATHERINE E. SCHAPIRO, Defendants JURY TRIAL OF TWELVE DEMANDED STIPULATION AND AGREEMENT FOR ENTRY OF JUDGMENT AND NOW, comes Plaintiff, DICKINSON COLLEGE, by and through its attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and Defendants Elizabeth Pace Schapiro and Katherine E. Schapiro who stipulate and agree as follows: 1. Pa. R.C.P. 1037 (c) provides that in all cases, the Court, on motion of a party, may enter an appropriate judgment against a party upon admission. 2. Defendants agree and admit that Judgment should be entered against them in favor of Plaintiff in the amount of $10,302.85 plus costs of suit and interest accruing per the terms of the Promissory Notes attached to the Complaint. 3. The parties agree that the Court, upon motion of Plaintiff, may enter Judgment pursuant to this Stipulation without issuance of a Rule to Show Cause, and without further proceedings or notice. /'°x By P- n ^ -B Elizabeth ace Schapiro D Galloway, s re 1500 Glencoe Road Martson Deardorff Williams & Glencoe, MD 21152 Ten East High Street Pro Se Defendant Carlisle, PA 17013-3093 Date: L(- /? 7 Byyaf? C Q? M? Katherine E. Schapiro 1500 Glencoe Road Glencoe, MD 21152 Pro Se Defendant Date: 4-19 ( 17) 243-3341 Attorney for lai?} tiff` Date: 1 (8y CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Stipulation and Agreement for Entry of Judgment was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Katherine E. Schapiro 1500 Glencoe Road Glencoe, MD 21152 Elizabeth Pace Schapiro 1500 Glencoe Road Glencoe, MD 21152 MARTSON DEARDORFF WILLIAMS & OTTO (7-4 n is D. Eckenroad Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: May 3, 2004 l7 o O (_; o T ri ' ? nib , - -c -gym G C' -?; ? r. ?- ?t i C?n -c.: -- ?jm .n _-? r w F:TILES\DATAFILE\Dlckinson College ]619? ickinsonCollegeCollectio 76190\C=en@09.ordl/tdc Crcatcd'. 12/9/03 1037" Revised: 5/3/06 3:55PM 7619C.209 DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 03-6006 CIVIL ACTION-LAW ELIZABETH PACE SCHAPIRO, and KATHERINE E. SCHAPIRO, Defendants JURY TRIAL OF TWELVE DEMANDED ORDER OF COURT AND NOW, this ay of 16d >1 , 2004, upon consideration of the attached Stipulation, judgment is hereby entered in favor of Plaintiff Dickinson College and against Defendants Elizabeth Pace Schapiro and Katherine E. Schapiro in the amount of $10,302.85 plus costs of suit and interest accruing from date of judgment per the terms of the Promissory Notes attached to the Complaint. Prothonotary is directed to enter and index this judgment accordingly. for Plaintiff: , eavid R. Galloway, Esquire Ten East High Street Carlisle, PA 17013 Pro Se Defendants: VMs. Katherine E. Schapiro 1500 Glencoe Road Glencoe, MD 21152 CA 05 .? a ?)~lizabeth Pace Schapiro 1500 Glencoe Road Glencoe, MD 21152 n V TrIR !1(1T TD T ii iij sa .01 ?1 MN U0t co'- -41 dO a:?!a??;,rQ?II, I F FILMDATAFIL6\Dlckinson College ]619\DickinsonCollcg ollections7619C\Curtent@09 odl/tde Creaz IV9103 1039AM ftmed: 5/3/04 3'55PM ]6190.209 DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 03-6006 CIVIL ACTION-LAW ELIZABETH PACE SCHAPIRO, and KATHERINE E. SCHAPIRO, Defendants JURY TRIAL OF TWELVE DEMANDED ORDER OF COURT AND NOW, this ay of y -1 , 2004, upon consideration of the attached Stipulation, judgment is hereby entered in favor of Plaintiff Dickinson College and against Defendants Elizabeth Pace Schapiro and Katherine E. Schapiro in the amount of $10,302.85 plus costs of suit and interest accruing from date of judgment per the terms of the Promissory Notes attached to the Complaint. Prothonotary is directed to enter and index this judgment accordingly. BY THE COURT, / for Plaintiff: , eavid R. Galloway, Esquire Ten East High Street Carlisle, PA 17013 Pro Se Defendants: VMs. Katherine E. Schapiro 1500 Glencoe Road Glencoe, MD 21152 5'?a , J. ?E`lizabeth Pace Schapiro 1500 Glencoe Road Glencoe, MD 21152 ,12 v - " ? t:ao H C ?3 nl ? ? tJ ??%7 ai ;r1 S F:\FILES\Clients\DickinsonCollege7619\Collections\Cutrent\209\209. pra3/tde Created: 12/9/03 10: 37AM Revised: 4/7/08 10:07AM 7619C.209 DICKINSON COLLEGE, Plaintiff V. ELIZABETH PACE SCHAPIRO, and KATHERINE E. SCHAPIRO, Defendants TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6006 CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED PRAECIPE Please mark the judgment in the above-captioned matter satisfied and the action discontinued. MARTSON LAW OFFICES By ( fv?v! S Christopher E. Rice, Esquire I.D. No. 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: !1_7 ,01? Attorneys for Plaintiff lut itsr OU :q WJ L- 8JV BOOZ ?'1UNi?" Gad. ?, ? s`? ucr. i Pv DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 63 CIO* c / 1 CIVIL ACTION-LAW ELIZABETH PACE SCHAPIRO, and KATHERINE E. SCHAPIRO, Defendants 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 County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 A 0 MARTSON DEARDO WILLIAMS & OTTO C? By Dav R. Galloway, Esquire , I. D. Number 87326 T Ten East High Street Carlisle, PA 17013 - - (717) 243-3341 Dated: November 17, 2003 Attorneys for Plaintiff