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Home My WebLink About04-0760 F: IFILES\DA T AFJ LEIDickinson College 7619\DickinsonCollegeCollections7619CICurrel1tI240-corn I. wpd Crealed:J/17JOJ9:25:S7PM Revised: 2/20/040 3:29 PM 7619c.240 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO.Ot/-- 700 CIVIL ACTION-LAW DICKINSON COLLEGE, Plaintiff KAREN M. SAMMARTINE and VINCENT SAMMARTINE, 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 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 REDUCE FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Dated: February 20, 2004 By David R. Galloway, Es L 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, PENNSYLVANIA NO. 04 - 1(00 CIVIL ACTION-LAW DICKINSON COLLEGE, Plaintiff KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants 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 principal place of business at West Street, Post Office Box 1773, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendants, Karen M. Sammartine, (hereinafter "Parent"), is an adult individual with a last known address of25 Kimball Lane, Sparta, NJ 07871-3305. 3. Defendant, Vincent Sammartine, (hereinafter "Student"), is an adult individual with a last known address of25 Kimball Lane, Sparta, NJ 07871-3305. 4. On or about August 30, 1999, Parent and Student entered into a Promissory Note (Note #1) with Plaintifffor the financing of$14,000.00 plus interest, for educational services and benefits to Student at Plaintiffs institution. A copy of Note #1 is attached hereto as Exhibit "A." 5. On or about March 22, 2000, Parent and Student entered into an additional Promissory Note (Note #2) with Plaintifffor the financing of$3,359.38, plus interest, for educational services and benefits to Student at Plaintiffs institution. A copy of Note #2 is attached hereto as Exhibit "B," 6. The collective principal balance for Note #1 and Note#2 is $17,359.38. 7. Note #1 and Note#2 grant Plaintiff reasonable collection and attorneys' fees which Plaintiff has calculated to be $2,603.91. 8. As of February 5,2004, the principal and interest due and payable by Parents and Student to Plaintiff was $15,533.87, plus interest in the amount of$1.94 per day from February 5, 2004. 9. Parent and Student stopped making monthly payments on Note #1 and Note#2 on or about December 23, 2002 10. As of February 5, 2004, the outstanding balance of $15,533.87 represents the total of Note #1 and Note#2 for which Parent and Student have yet to pay. 11. Plaintiff fulfilled, performed and complied with all obligations and conditions ofNote #1 and Note#2. COUNT I BREACH OF CONTRACT Dickinson Colle2e v. Karen M. Sammartine and Vincent Sammartine 12. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 11 of this Complaint. 13. Parent and Student 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, Karen M. Sammartine and Vincent Sammartine, in the amount of$15,533.87, plus interest in the amount of$1.94 per day from February 5,2004, collection and attorneys' fees in the amount of$2,603.91 and costs of suit. COUNT II IN QUANTUM MERUIT Dickinson Colleee v. Vincent Sammartlne 14. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 13 of this Complaint. 15. Having requested Plaintiff to loan money, and doing so to the benefit of Student, Student became liable to Plaintiff for said money. 16. Student has been unjustly enriched by accepting said money without paying Plaintiff reasonable compensation therefor. 17. The total amount by which Student has become enriched is $15,533.87, plus interest in the amount of $1.94 per day from February 5, 2004. WHEREFORE, Plaintiff demands judgment against Defendant, Vincent Sammartine, in the amount of$15,533.87, plus interest in the amount of$I.94 per day from February 5,2004, collection and attorneys' fees in the amount of$2,603.91 and costs of suit. MARTS ON DEARDORFF WILLIAMS & OTTO David R. Gallo J.D. No. 87326 Ten East High Street Carlisle, P A 17013-3093 (717) 243-3341 Attorneys for Plaintiff Date: February 20, 2004 /< "~: I " ~'I ' I "ec. ' 0- I :;:..... '-, - -----. 1081-0/ DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - PLAN B EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT August 30, 1999 I. Seller: Dickinson College, Carlisle, Pennsylvania 17013-2896 Buyer(s): Karen M. Sammartine 37 Diller Ave. Newton, NJ 07860 If there is more than one Buyer, each of you will be obligated, jointly and severally, for all sums due and for 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 expenses incurred for goods and services to be provided and rendered, as the case may be, to Vincent Sammart (hereinafter "Student") during his/her enrollment at Dickinson College during the 2000 academic year, including tuiti 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 PERCENTAGE RATE: * Cost of credit as yearly rate FINANCE CHARGE: Dollar amount credit will cost buyer AMOUNT FINANCED: Amount of credit provided by Dickinson College TOTAL OF PAYMENTS: Amount paid by Buyer as total of all scheduled payments TOTAL SALE PRICE: Total cost of purchase on credit, including down payment of 8.75 % $ 6,578.64 ~~ IY-, DOD. 0-0 _$ 10,000.00 \ Rev 2/92:))..JU aM e)V (~ffT<\ M 6 I $ 19,735.00 $ 16,578.64 $ 29,735.00 Number of Payments 152 *Variable Rate: Late Charge: Prepayment: Sammartine Buyer's payment schedule will be as follows: Amount of Payments When Payments are Due $1'tJ9':6=N V52.lpq Monthly commencing 09/28/99 until OS/28/12 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 1 %. 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 152 months and the prime rate plus l'li were increased to 9.75%, your regular monthly payments would increase to $114.81. 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. If a payment is more than 15 days late, a sum equivalent to 5% of the late payment (but no mort than $2.50 and not less than $1.00) may be charged. 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: $ 29,735.01 2. Total down payment: 19,735.01 3. Unpaid balance of cash price (1 - 2): \~~ 4. Amount paid to others on Buyer's behalf: 5. Amount Financed (3 + 4): $ \,,\~Ol IV. CREDIT INSURANCE Credit life insurance for the term of this Contract is not required. V. NO WARRANTIES THERE ARE NO WARRANTIES, EITHER EXPRESSED OR IMPLIED, GIVEN BY SELLER IN CONNECTION WITH SALI Of THE GOODS AND SERVICES COVERED BY THIS CONTRACT UNLESS BUYER HAS BEEN GIVEN A SEPARATE WRIITEl WARRANTY. VI. ADDrTIONAL PROVISIONS 1. 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 :u1dress: EFG Technologies, [nc. P.O. Box 64974 St. Paul. MN 55164 2. Buyer's legal rights include the right to pay all or part of the amounts due on this Contract in :u1vance of their due dates, to obtain a refund or credit ofuneamed Finance Charge whenever the amount is paid in full in advance, and (with Seller's consent) to reinstate the Concract if Buyer timely cures any default. 3. Buyer shall be deemed to have commined 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 orher provision of the Contract. (d) providing Sel~er wirh false informarion or signatures. (e) death. incompetence. or convicrion of any Buyer of crime involving fraud or dishonesty, (I) insolvency or bankruprcy of any Buyer. 4. Upon or atier the occurrence of any Evenr of Defaulr, Seller will provide Buyer with notice. by certified mail as required by law, addressed to Buyer's lasr 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 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 anomey's fees and other reasonable collection costs and charges necessary for the collection or 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 orher 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 rreely assignable by Seller. Buyer agrees that upon receiving notice of the assignment Buyer shall be obligated to th Assignee of this Contract. which Assignee shall have all of Seller's right and remedies. . . 7. Ifany part of this Contract is held to be illegal. void or unenforceable. that provision shall be deemed not to have been a part ofthis Comracr. which shall orhenvise remain fully ~ffective. ~.'--.. ............. ..... ~ ... . 'U" nS'o....O;UJCUL, wnenever r..:a.m;;U l.itJVII ~U U'C r..:Umil:ruC::l4 ;)Uau oe governea by the domesnc internal laws of t monwealth of Pennsylvania except to the extent supplemented. superseded or preempted by federal law. ,:: {:ONSENT TO nJRlSDICTlON. VENUE AND SERVICE: Theparties to this Agreement consent and agree that all legal proceedings relating to the subject malterhereofshall be maintained in the Court of Common Pleas of Cumberland County, Pennsylvania, or. if applicable, the United Slates District Court of the Middle District of Pennsylvania, and all parties hereto conse" 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 party 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 TH 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 TIiE DEBTOR HEREUNDER. . NOTICE TO BUYER: (I) DO NOT SIGN THIS AGREEMENT BEFORE YOU READ IT OR IF IT CONTAINS ANY BLANK SPACE. (2) YOU ARE ENTITLED TO A COMPLETELY FILLED-IN COPY OF THIS AGREEMENT. (3) UNDER THE LAW, YOU HAVE THE RlGHTTO PAY OFF IN ADVANCE THE FULL AMOUNT DUE AND UNDER CERTAIN CONDITIONS TO OBTAIN A PARTI, REFUND OF THE FINANCE CHARGE. I ! , : BUYER(S) ACKNOWLEDGE(S) RECEIVING A COMPLETED COPY OF THIS CONTRACT AND INTEND(S) TO BE LEGALL Y BOUND BY ITS TERM--7/ BUYER(S): /Jt1//1 n(--;;;L~ 1 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 ~~ YOTEt i 1 STUDENT COSIGNER Ur1fl-'!hJbl"t/lf1t/ir[} TRANSCRIPT OF A STUDENT'S RECORD WILL NOT BE RELEASED IF LOAN PAYMENTS TO THE COLLEGE ARE IN ARREARS OR DEFAULT. DATE: DICKINSON COLLEGE ~, ~f-c;7 BY (/J=)-/ ~ <'-- PI:m B loans ~. .' r-- J 6 9 / - Q'J.--.. APR 0 4 '7nl~t1 &...--'-' '..) DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - PLAN B EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT March 22, 2000 I. Seller: Dickinson College, Carlisle, Pennsylvania 17013-2896 Buyer(s): Karen M. Sannmartine 37 Diller Ave. Newton, NJ 07860 If there is more than one Buyer, each of you will be obligated, jointly and severally, for all sums due and for th performance of all agreements as provided in this Educational Goods and Services Retail Installment Contract.(th "Contract"). Under the terms of this Contract, you have agreed to pay the expenses incurred for Goods and Services (a hereinafter defined) to be provided and rendered, as the case maybe, to Vincent Sammartine (hereinafter "Student") durin) hislher enrollment at Dickinson College during the 2000 academic year, including tuition, room and board, books an< supplies as herein stated (collectively the "Goods and Services"). II. TERMS OF PAYMENT AND PAYMENT SCHEDULE Disclosures Required by Federal Law ANNUAL PERCENTAGE RATE:* Cost of credit as yearly rate FINANCE CHARGE: Dollar amount credi t will cost buyer AMOUNT FINANCED: Amount of credit provided by Dickinson College TOTAL OF PAYMENTS: Amount paid by Buyer as total of all scheduled payments TOTAL SALE PRICE: Total cost of purchase on credit, including down payment of $ 26,375.62 8.75 % $ 2,209.90 $ 3,359.38 $ 5,569.28 $ 29,735.00 Rev 10/99 --"_.~'~.__._..-,... '.'. ~ , Number of Payments 152 *Variable Rate: Late Charge: Prepayment: Sammartine Buyer's payment schedule will be as follows: Amount of Payments When Payments are Due Monthly commencing 03/28/00 until 11/28/12 $ 36.64 The initial ANNUAL PERCENTAGE RATE disclosed above is a variable rate and may change(increase or decrease) from time to time. The ANNUAL PERCENTAGE RATE may increase or decrease 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 or decreases, and will be increased or decreased to the prime rate plus I %. The ANNUAL PERCENTAGE RATE will not increase, or decrease, more than once a year, and the new interest rate will become effective on July I following the increase or decrease, 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 $3,359.38 at 8.75% per annum for 152 months and the prime rate plus 1 % were increased to 9.75%, your regular monthly payments would increase to $38.57. Further, the ANNUAL PERCENTAGE RATE will not increase to more than 18% or such other rate as may be permitted under Pennsylvania law. 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. 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. ill. ITEMIZATION OF AMOUNT FINANCED $ 29,735.00 1. Cash price of Goods and Services: 2. Total down payment: 26,375.62 3. Unpaid balance of cash price (1 - 2): 3,359.38 4. Amount paid to others on Buyer's behalf: - 0- $ 5. Amount Financed (3 + 4): 3,359.38 2 IV. CREDIT INSURANCE Credit life insurance for the term of this Contract is not required. V. NO WARRANTIES THERE ARE NO WARRANTIES, EITHER EXPRESSED OR IMPLIED, GNEN BY SELLER IN CONNECTION WITH SALI OF THE GOODS AND SER VICES COVERED BY THIS CONTRACT UNLESS BUYER HAS BEEN GIVEN A SEPARATE WRl'ITE1' WARRANTY. VI. ADDITIONAL PROVISIONS L Buyer agrees to pay Seller the Toeal Sale Price by making the total down payment and paying Seller the Total of Payments in the number and amount of monthly p~yments 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 BFG Technologies, Inc. at the fallowing address: EFG Technologies, Inc. P.O. Box 64914 St. Paul, MN 55164 2. 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 Conmet 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 signalUres, (e) death. incompetence. or conviction of any Buyer of crime involving fraud or dishonesty, (I) insolvency or bankruptcy of any Buyer. 4. Upon or after the occurrence ofany Event of Defaul~ 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 defaul~ The notice will provide the time. amount and performance necessary to cure the defaul~ If Buyer does not cure the defiwlt o. 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 noc 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 Conemct is freely assignable by Seller. Buyer agrees that upon receiving notice of the assignment Buyer shall be obligated to th. Assignee of this Contract. which Assignee shall have all of Seller's right and remedies. '.' 7. lfony parr of this Contl'oct is held to be illegal. void or unenforceable. that provision shall be deemed not to have been a pan: of this Contfact, which shall otherwise remain fully effective. _lCABLE LA W: This Agreement, whenever called upon to be constrUed, shan be governed by tlte domestic internal laws of _ommonwealth of Pennsylvania except to the extent supplemented, superseded or preempted by federal law. i. CONSENT TO JURlSDICTION. 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 ofCumbertand County, Pennsylvania, or, if applicable, the United Stares District Court of the Middle District of Pennsylvania, and an parties hereto conse~ 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 partY at the address set forth above. 10. This Contract shall be binding upon tlte parties hereto, tlteir heirs, successors, assigns and legal representatives. II. TIME IS OF THE ESSENCE OF nns 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. (2) YOU ARE ENTITLED TO A COMPLETEL Y FILLED-fN COpy OF THIS AGREEMENT. (3) UNDER THE LAW, YOU HAVE THE RlGHT TO PAYOFF IN ADVANCE THE FULL AMOUNT DUE AND UNDER CERTAIN CONDlTlONS TO OBTAIN A PARTIAi REFUND OF THE FINANCE CHARGE. BUYER(S) ACKNOWLEDGE(S) RECEIVING A COMPLETED COpy OF THIS CONTRACT AND lNTEND(S) TO BE LEGALL Y BOUND BY ITS TERMS. ( BUYER(S): K (t U'VL/ u--12)11-,,1YLcvtiz~ Q / I AGREE TO REPA Y ALL AMOUNT.. S DU. E O.N)tHIS N I~F BORROWER(S)/BUYER(S) FAILS TO DO SO IN ACCORDANCE WITH THE TERMS OF ~E!~~~E;.j /, ',), :T . . STUDENT COSIGNER /l/(IPt j ~d/# 't . TRANSCRIPT OF A STUDENT'S RECORD WILL NOT BE RELEASED IF LOAN PA YMENTS TO THE COLLEGE ARE IN ARREARS OR DEFAVL T. DATE: 3 . 2. z -c c DICKINSON COLLEGE BY'~1( l/-R..'-----' .,) ~1:u1 B Loans ....... '" 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 subj ect to criminal penalties. Dickinson College ~ Thomas Meyer Assistant Treasurer of Dickinson College Dated: F:\FILE$IDA T AFILEIDickinson College 7619\DickinsonCollegeCollections7619CICurrenl\240-coml_wpd CERTIFICATE OF SERVICE I, Martha-Anne !ben, 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, P A, Certified MaillRestricted Delivery, postage prepaid, addressed as follows: Karen M. Sammartine 25 Kimball Lane Sparta, NJ 07871-3305 Vincent Sammartine 25 Kimball Lane Sparta, NJ 07871-3305 MARTS ON DEARDORFF WILLIAMS & OTTO By cfl&/~UL - /luw ~v Martha-Anne !ben Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: February 20,2004 )D /"-'., .~ ,~ 0 uq n-- ~ ,-:-'. .:Q R ,. g ----.. ' I ':,} - )...::, v, ---C ~ 0 ~ --c. ~ c:; ~ ('"-:' F' ....... -2) ':;::- <::,' , '- -, -------- F:\F1LESIDAT AFlLEIDickinson College 7619IDickinsonCollegeCollections7619C\CurrentI240,affduedililIde C,"ealed3117/039:2557PM Revised 4/161040:59:03 PM 7619c.240 DICKINSON COLLEGE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. OL/- 7C;O ~I;ll CIVIL ACTION-LAW KARENM. SAMMARTINEand VINCENT SAMMARTINE, Defendants JURY TRIAL OF TWELVE DEMANDED AFFIDAVIT OF DUE DILIGENCE TO THE PROTHONOTARY; Please see the attached Affidavits showing Plaintiffs attempt to serve Defendant Karen M. Sammartine and Defendant Vincent Sanunertine. David R. Gallovray Attorney J.D. No. 87326 Ten East High Street Carlisle, P A 17013 (717) 243-3341 MARTS ON DEAR ~) M'ILLIAMS & OTTO Date: April 16, 2004 Attorneys for Plaintiff NOTICE TUi\!'! DF '3CR\/ICE for..; "~~ .. D" 04/01/2004 VINCENT SAMMARTINE notice I: att:cmoted to (?(vt? t,111:-:; x:}{'~~^M~~ IJn def(:~ndant ;;-(. ;,r)(!j 25 KIMBALL LANE SPARTA, NJ Defendant can ilot be located Defendant moved with i10 FOrWJi"diilq B(!drc~ Defendant nlove{~ fOi"Wdj-d)flq d(:!di'ess IS Laced below REMARI(3:UNABLE TO SERVE NAMEO DEFENDANT AT GIVEN AODRESS. THE HOUSE IS VACANT AND THERE IS A LOCK BOX ON THE FRONT DOOR. WHEREABOUTS OF DEFENDANT ARE UNKNOWN. ROBERT E. UNTIG, SHERIFF ~ ~ --- By: CPL. PETER SQUIRE ~;r>(>,,;ial I)cpl!tv (~:o::' t(oO~'::\:::h:el t~iS~;Z(ord::'~~ April 2004 8~80~ce~ !late: 01/0/;;; "'~~"=g,~,.t........ ! hEleby Ut.liP Cr1l.. PC: r[R ':lOU T I _,. .,.._, ann api'OL(ll for me and in iTl''y' ildill2 to :3cr\ie tilis writ. Witness my 11Jnc! and (?al thf idY an(~ year above wi'itten S~leriff of Susse>: COUilty f!f;~cQ~, NOTICE ,;~c IIJRN 01'- ':)::::R\/ I C[' i::OR ~ (1 C:OMPLA r NT ':3 On 04/01/2004 KAREN M. SAMMARTINE notice f ,J,tt:ernpt(~d to ~;el\le t.hi~; ~i{~ lin ere ndJ.iit' L. d, (j(J I' e<.~,; 25 KIMBALL LANE SPARTA, NJ Defendant can not be located. DefenlJant move!} with 110 forwar,!iilCj d(10rcss. Defendant moved forwardli'iq ad(lress is st:ated be]ow REriARK3:UNABLE TO SERVE NAMED DEFENDANT AT GIVEN ADDRESS. THE HOUSE IS VACANT AND THERE IS A LOCK BOX ON THE FRONT OOOR. WHEREABOUTS OF OEFENOANT ARE UNKNOWN. ROBERT E. UNTIG, SHERIFF ,~~~ Sussex Countv 3hel 'It '; ('c': $29.56 sworn to before me this~~~~ day of April 2004 ~~!:r: '"::.~~" NOTARY PIIBUC OF NJ MY "OII"4ISSION ElCPIRJ:zo 11/181fIT ''''~j)(:'C a 1 u t'v' d!):;'Ol n! CPL P!~ r'Lr,~ :.:;ou ~\l i' U( fIl': [;;1 I: h ?, ,Wi" J t. the day J jfl my !lai"~ to SPj'Vf' ~!l tn rnv r','jnd ,:ti'l,j 3':0i3.J year above wi'itten 3hei'if'f of ~;us l?;.< Count,;." Q-~~ riff of Sussex Coun't,;' ... ~ . C) '" 0 = ~~ " ~. ..<.- _._, :=0- ::::! , "'j - ~- ...,.., ::u rllr -1.'1 m CC.JQ en ....:J L I:;;":': ~--' C.J """'-r; . " "1:' ~~'j F5 () - <" ;c..;- ['n " C~ r:y '-.) ..j :2: );.~ :::?, N ~ +- F\FILES\DA T AFILE\Dickinson College 7619\DickinsonCollegeCollections7619C\CUITenl\240. pra Ilnbn Created: 8/261042:53PM Revised: 8130104 3:18PM 7619C.240 DlCKlNSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v. NO. 04-760 CIVIL ACTION-LAW KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants JURY TRIAL OF TWELVE DEMANDED pRAECIPE Please reinstate the attached Complaint against Karen M. sammartine, in the above-captioned action and return same to the undersigned for service. By David R. alloway, Esquire I. D. Number 87326 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Date: August 31, 2004 Attorneys for Plaintiff 0 ,...., 0 = c = --n " .r- l:..,(ij """ ::::l fT] r,-' c:: ::t:-'-l -:;J<-..,., (I") nl- -0:--, "_~ . fTj 1~-i,::-, eN =86 -</,. ::> rr-. "r' . <---- - II .....,~ ~ b:!J zl. ':t'U ~. ---.~ "'c: Vi' 0 ,..:.. j;! ~;;j w :n 0 .< F \FILES\DA T AFILE\Dickinson College 7619\DickinsOnCollegeCollecti0I157619C\CI.lITent\240, pm) Created: 9116104 0:26PM Revised: 9116104 0:36PM 7619C.240 David R. Galloway, Esquire 1. D. Number 87326 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. 04-760 CNIL ACTION-LAW KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants JURy TRIAL OF TWELVE DEMANDED PRAECIPE Please file the attached Retum of Service indicating formal service was not made on either Vincent Sammartine or Karen M. Sammartine referenced in the above-captioned. MART~tBORFF WILLIAMS & OTTO '~~I ~ By,.___- ' David R. Galloway, squ re 1. D. Number 87326 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Date: September 16, 2004 Attorneys for Plaintiff -") c~ " , =?- (.) -... -< - -.; ......, c-:;,:} C:::.J -"'" [,<"2 ", -"(, c~) "i: C':, ri'! li./ }:"I;'-'ill;-'J,:, 1J"liJr ", 09/03/2004 KAREN M. SAMMERTIME 219 HIGHLAND AVENUE ANDOVER (GREEN TWP.), N. J . x II n :-10 i i r r',; I'C\ ,t i :,"1 L ['I() 1,0,1 l:i' (;(,1 r'[',\I::_i 'I':,! I" ;1 t il.;"jV; Ur' i;'.;,'1 i -'1.("'1 11M: UNA81.E TO SERVE NAMED DEFENDANT AT GIVEN 11DDRESS, ADDRESS DOES NOT EXIST; CHECKED WITH ANDOVER POST OFFICE; THE CARRIFR HAS NEVER HEARD OF DFFENDANT ROBERT E. UNTIG, SHERIFf s 10, ~IJ /I ,,/,', ,'" ::It;lf '", / 16 / S!o~SKI 1,;,1,11, '_I' r3~' : $29.56 'fl z0~/ I'; l'jj'!,"'!1 I 1'1", (j, !I' 'ii ')1', o}){Q:;,.,? ,,'." ~t:;--{", 'I ,,' ' , t;;O:\1^::~E':'V[):'_C\~ ~ 1~." fA;;: ;:.r.IGH STREET CARLISLE, PENNSYL'/AN1A 17013 . n .,- r.r ,\/ ~ D ~_~____.~____ ~~_______.__ ____-'-____~.__~~t~__~_~_~~_~_;___ ----- ---- - -------------.-.. ----------. -- - ---- ---- .-.---..--., - '::'~ - \ ,---' t'" ,\ ~, D1CKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ,} --; "'-' NO ./ '! - .;u) . [/ ''( ! (j... CIV1L ACTION-LAW :--... o "C' i.._ ..:.-2. -~,":, _or' JURY TRIAL OF TWELVE DEMANDE:t\ Co,," ~ .-\ 7\~~ KAREN M. SAMMARTINE and VIN'CENT SAMMARTINE, Defendants c: You have been sued in court. If you wish to defend against the claims s",rforth-.i:n the\ following pages, you must take action within twenty (20) days after this Complaint ~nd~otiCe are.:'): served, by entering a written appearance personally or by attorney and filing in writing wIth thecourt 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 'i< requested by the Plaintiffs. You may lose money or property or other rights important to you. 'ii i;: NOTICE YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVEA 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 Dated: February 20, 2004 MART~?N DE~9Y1F ~'(( By ~ David R. Galloway, Esquire 1. D. Number 87326 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff ~:'.1 ~ LfflMS"& Olr'tb .-""", ::'--'~ ?".._~". rr"l .n -0 i....-....I ""'.' lRUE COP~f r:Ffi{J~;lJ f~E(:;ORD I f,) (Q) @ '\2) ~ "" "'<: J-? ~ _'.J co F)(hihit A Exhibit B i' 09/03/2004 VINCENT SAMMARTINE 219 HIGHLAND AVENUE ANDoVER (GREEN TWP), N. J . x- n ,'il i.',: ,'1,'.1.:, I'.',', i i",I,': M~! UNABLE CO SERVE NAMED OEFENOANI AT GIVEN AODRESS. ADORES DOES NOT EXIST; CHECK EO WITH ANODVER POST OFFICE; IHE CARRIER HAS NEVER HEARD OF DEFENDANT "','.1 ROBERT E. UNTIS, SHERIFF' ~/.?/-I=I"I 8\: S/~INSKI ':) Iii I; i $20.00 1'/1 f5 ep ~'I I)!), /1':, i;(:: J (: ill (:' ,~ fil ',"ii, i::I,1 I/',Ii I ';1 ',Ii r' (, \i,';; i,.'.)J I .1', i_.,n i(11" $;d<.~ ~~~~l};'::;::CE'~)V(~~Y~ -' TEN EAST H1GH STREET CARLlSLE., PE.NNSYLVANIA 17013 RECEIVED T--' 1,~,~'~ ,,:,:,"j - \ C-J'~\ '" ,\ ~ .,....,. ' 'j ", IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DICKINSON COLLEGE, Plaintiff - " '- ,I -? "J NO. C) i " f (;i.. CIVIL ACTION-LAW c r" ,::-::, .--.:;. o --n .-\ ?:\-,~~ v, KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants . ." -' JURY TRIAL OF TWELVE DEMANnEP 1..-" C_" y 00 ",vo b,m ;001 in ,"on. ff yoo wi,b ill dof""" 'g,i.., <b' d~m' ", forth';n <b;', [oltowmg p'''"' you mO" ",-' ~"oo wi""" twm'Y (20) day' ..~ tlll, Comp''''''' ....~o,,;;. "",3. "",01, by m"riog' wriltm "l'P,~m"p~n..ny "by ,"o""y """ filing io writiog~Th ",","'" yo~ ""[,..~ 0' ,bi~tio" to th, ""''''' re' [orth ng~'" yoo. Y 00"", -'" "'" ifyoo f.' '" do 00, "'" ,_ m'Y pro_ with"" you md 'i""gmm' m'Y "^ m'~'" ..-' yoo by th, wort witho'" """'" no"" fo' my mOlley "",mol m <b' Comphio'"' [~ my o<b~ ,hUm "",lid requested by the Plaintiffs. You may lose money or property or other rights important to you. NOTJCE yoU SHOULD TAKE THIS pAPER TO YOUR LAWYER AT ONCE. JFYOUDONOT HAVE A LAwYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE yOU WITH INFORMATION ABOUT HIRING A LA~' ....., ?-: ~ ~~' JF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY ~~~TC5:' PROVIDE YOU WITH INFORMATION ABOUT AGENCJES THAT MAY 0_ Ll;"^""~ SERVICES TO ELIGIBLE PERSONS AT A REOUCE FEE OR NO FEE, ." . ;;; ';CJ , ':) ~. ~" ",/ --:> ::-.;C '1-: .--) cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 .;.'" (~'.) _...i -( .::- --.j (Q> @ ~ ~ to, "E COpv ':;:,7'{'j)J: r:,c;r:fO~Jr-.J ?~ nv ~ 'Ij J "I....... ,"U ,. ,."'".......- \',~ '" ,..,,_ ,,'~",. ; ,*" CoM MAKfSON OEAR(>O , F ami the $<:\1\ c'; ~;2;;i ;;G.)"\ :,,: ,~",;;;\I;l. ~. By , ""-;,:,,'%';;!'~,. # _ f~'~~:'~;;it'Uirt pr()('J't;,-.t~-~ Ten East HIgh Street Carlisle, PA 17013 (717) 243-3341 Dated: February 20, 2004 Attorneys for Plaintiff r:::,~ LtiM~ of to :.-' ~~ r:r~ ~::I {.:-) J>' t' 'j.J co r"_.l...:l....i+ !:J.. Exhibit B ;r.:'-\ -r-C<~ D>~ of ~ON f'(EA-S ~12 CcJ.-~:<cP ~~S2 {'au-A} I FE~~S;!V ^ ~ t'A- ---.-------.-- - ~_.....'_ _n __ .--- --.^'--.---..---- .. _h ('vll ilc(;/p.iJ t!cte~.ff./c .1-{~',;J/Jf.A.--. .. ...._.-1?L{u:~LL FE v. .--cS;,~l~d,d-:: --~-_.- ._~-'. .TJ~~~&U-s .---- .----~.-. ...-..-----.---.-..- ___._ __.... __n" _._ ..__," _.____ _. --" u_u____....____. ..... _;Ja.~ Qf=!12{3---- - ----..' ._.--_.._.__._---_._.._~------- .--...--...------ ----------- ____------..-m. ...__ ' ---.----- 'C-eooc of G~.t:v('cr=. -------.--..-....---..-..-..-- _.- -........ _.- - .- _-;c__:Ii-<dCR' e;t- jLP;JG'"t#'/ #7fE'I7 {', . VoL ,{e~.s {j,,)gff<R- --rf-"';..p-~N.J-f; __dE-~~ - ~((2ll'L --f4c-f .x - - __Aclc- .._- ___..zf-r..~(f-Q.@e-.--'IrJ-!'l:F~~L~ ..._7$-....sPQ.tJJ~- ._oF: p!.iAf:fT Lk""",.,j: #;(:''''''1 -':;~{"-Es.-f t;R -IkL,,o ?RQlk:-6~, eF 17.<l.Co~"M~7Q; 1f,scl,'E-e .~ _(jl_Trc-ffio",,,-f:!l- At. _wJ,..d<..C;~;:/t- (} ,AJE' ___.cOd dL1.O.J.D-f.--- 8.fk-t..-A.rE'~ ..- C:,6RL:sl~( PA___LW----- _-!& ,&AcJ7f-_d ,;.1,'-. sv.-k- fAlyE' lore ~ . ~.. .8'n^J! -tW-+- sf,,-&- F"'V€. ~":. -:m-_! 4"'-- _~t-<'J..~' .. or-r,'cE:R- --f<, tk<-.c~;;- Ii-.. ;;,J'-if!t-E h.,0..(). A",JrJaf'- ..~. ,z.+ S,c;J:;" ~(7/(/ -if;: 'rtc-717 { s- 9 ~ f~0'f . n .. 'E'<2. :G'9~~-.a::6 _nn_-~~ (b?!~~~- . ---- ---~._-- ~_._- --.----. --- ----------- . - - ---"----------.-.--- ".---------...----- - -..--------- - ----------~'-_.._--~---------- ~-~ i.LI.c.: .. (~_.: ~--; C)!~: -- [3 ,~E- ,::~-! tt I "-:c -~--~--- i -- ---'.....~ , ------ ,.~. rS:: '-"'~ ~--::- ";?-;:; , -..-. -~-------_:'-,'---.,J___ '-1... '-u vy ...". ~:) ;;:,~ c~ --'_} -----.. 'b~. ~ '.:--') ---~-. II c5 .; ,,'-,;;-..'; 4~,- ------ ..__.~------------------ ~--._----------- --------~-------- ------'---'--------~~-- -~---------------------._~------- -------.- ----------------..---. -----------. ------------ '---.------ ----. '. ------.-.---- F IFlLESIDA T AFILEIDickinsonCollege7619lCollectionslCUlTent\240 pra4 Created: 11116104 3.09PM Revised. 11116104 3.IIPM 7619C 240 David R. Galloway, Esquire MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-760 CIVIL ACTION-LAW KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants JURY TRIAL OF TWELVE DEMANDED PRAECIPE Please reinstate the attached Complaint against Vincent Sammartine, in the above-captioned action and return same to the undersigned for service. MARTSON DEARDO ILLIAMS & OTTO By David R. Galloway, Esquir 1. D. Number 87326 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Date: November 16, 2004 Attorneys for Plaintiff .'''1 J C) r-..) ~~.";~.) C:~::) _l;.- o -11 Cfl -;:; (~) (,) F. \FILES\DA T AFILElDickinsonCollege7619\Collections\Current\240 praS Created \ 1116104 3.I2PM Revised' 1\116104 3'14PM 7619C240 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. 04-760 CIVIL ACTION-LAW KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants JURY TRIAL OF TWELVE DEMANDED PRAECIPE Please reinstate the attached Complaint against Karen M. Sammartine, in the above-captioned action and return same to the undersigned for service. By David R. Galloway, Esquire I. D. Number 87326 \ Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: November 16, 2004 Attorneys for Plaintiff r"" , v 9 r--:> c::"J ~~ t~ ~;>- CT' _'1"'"\ c- "n :? -.' i_~~ f.;\ ;!C( c=" ~-\l .-'1 ; (~-j :)1 n ~..-! '1-> ::Q c:': C..) vJ .""'l:... F \FILES\DA T AFILE\DickinsonCollege7619\Collections\Current\240 affduedili3 Created: 12110/04 1:20PM Revised: 12/10/04 2:04PM 76 I 9C.240 David R. Galloway 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. 04-760 CNIL ACTIO:~-LA W KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants JURY TRIAL OF TWELVE DEMANDED AFFIDAVIT OF DUE DILIGENCE TO THE PROTHONOTARY: Please see the attached Affidavit of Due Diligence. MARTSON DEAR BY~ David R. Gallow y Attorney LD. 87326 10 East High Stn~et Carlisle,PA 17013 (717) 243-3341 Date: December 10, 2004 Attorneys for Plaintiff RETURN OF SERVICE FOR NOTICE AND COMPLAINT On 12/2/04, I attempted to serve this NOTICE AND COMPLAINT on defendant KAREN M. SAMMARTINE at address 219 HIGHLAND A VENUE NEWTON, NJ 07860. X Defendant can not be located. Defendant moved with no forwarding address. Defendant moved forwarding address is statt~d below. Remarks: Date: 11/19/04 Time: 7:08 pm 219 HIGHLAND AVENUE NEWTON, NJ 07860 Unable to serve named defendant at given address. House is vacant. Robert E. Untig, Sheriff ~N By: Edmund Galinski, Special Deputy Sussex County Sheriffs Fees: $0.00 .,. ~IlAA'_'. 8.!\~!l""". ,,~ MY co~~~:~~:>....:u '.;.:~..>".';" ''',!'''' Date: December 2, 2004 I hereby deputize and appoint Edmund Galinski for me and in my name to serve this writ. Witness my hand and Seal the day and year above written. Sheriff of Sussex County ~v .......-. t [: '"' ... ~~"I:'II/;:; bee OD" L 'J 21101 ~ 1I.e-..., '/ Y l "A .. / fn/,-.. ,. ".' r .... ;~ l.::' 0 @ ~ ~ F' FILES\DA T AFI LE\Oickillson College 76 I 9\DickinsonCollegeCollectlons76 I '>C\Currem\240-coml. wpd ('reated. 3/17/03 9<~5 57 PM Revised- 2/:!O/Od 0- 3-:2.9 PM 7619c 240 RECEIVEQ~l' '\:~ _ \ ';~~ '~: ' DICKINSON COLLEGE, LJ \ rl " IN THE COURT OF COMMON PLEAS OF IDWlfmyffa A~J:.20. ~ _ .' .~. CUMBERLAND COUNTY, PENNSYLVANIA SUS{iEX COUNTY SHEI~iFF ,;".7//) NO. (.7 7' l [,~~, CIVIL ACTION-LAW KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants ,...-:> (, ';-~.'.,~ /~~-.~ -- e.: _.~ JURY TRIAL OF TWELVE DEMANDEP CL' o --n .-\ M; -,;; -,l~} r. '" -' _" NOTICE C::'~..I '-. ,") ~- ---1 ! " :--~. . . -" .. -' ~...\-, You have been sued in court. If you wish to defend against the claims s~t Jorth.in the:': following pages, you must take action within twenty (20) days after this Complaint and. Notice an~:.( served, by entering a written appearance personally or by attomey and filing in writing with thecourt your defenses or obj ections 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 CompIaint 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 r- #". I SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE:.::j . -:. 1 . 'I ,{"'" 1 ',. ~ Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 i<) ~ "~'~ ~~...,=:: . \'>.'"",."",, ~. ('.'\ , .J c::J "',', fRUE C': ;:'"/;-- ':' ': ~-:.,':\~,:~;?D In .;- ::t~l~v.,,::,~, .: ":.: .. ',", -~ ~ ",,"<;;; '~:'r-, ~'&;~(;(, B :.;, ~ ~ ~';~: ;; " - "~ . '. -...... '..., - ;.;.,., Y ~ ifl2~' :i"-.fL' ~~vi~~~~I~;3ai6 Esquire . . r:, ~:~,-:.;"l<'~ Ten East High Street - -'. Carlisle, P A 17013 (717) 243-3341 Dated: Febmary 20, 2004 Attomeys for Plaintiff ; I ) r"'-~, .::-:::) c.) ..;.;.... c:-' ,.' 1 (-) ...~- c:r (,,.) C.' , " (~) --11 .--1 fTl '1, ,', (n P'IFILESIDA T AFILEIDickinsonCoUege76191CoUectionslCurrent\240 affduedili3 Created: 12110/04 1:20PM Revised 12/10/04 2:04PM 76 I 9C.240 David R. Galloway 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. 04-760 CIVIL ACTION-LAW KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants JURY TRIAL OF TWELVE DEMANDED AFFIDAVIT OF DUE DILIGENCE TO THE PROTHONOTARY: Please see the attached Affidavit of Due Diligence. MARTSON DEARD ~) By ~ David R. Galloway Attorney J.D. 87326 10 East High S1reet Carlisle, P A 17013 (717) 243-3341 Date: December 10, 2004 Attorneys for Plaintiff .... RETURN OF SERVICE FOR NOTICE AND COMPLAINT On 12/2/04, I attempted to serve this NOTICE AND COMPLAINT on defendant VINCENT SAMMARTINE at address 219 HIGHLAND AVENUE NEWTON, NJ 07860. x Defendant can not be located. Defendant moved with no forwarding address. Defendant moved forwarding address is stated below. Remarks: Date: 11/19/04 Time: 7:08 pm 219 HIGHLAND AVENUE NEWTON, NJ 07860 Unable to serve named defendant at given address. House is vacant. Robert E. Untig, Sheriff 5/0 ~.~,/!y By: Edmund Galinski, Special Deputy Sussex County Sheriffs Fees: $0.00 lB.~(1~ Date: December 2, 2004 r'-' r ~. ~ ...... I hereby deputize and appoint Edmund Galinski for me and in my name to serve this writ. Witness my hand and Seal the day and year above written. Sheriff of Sussex COlmty ~ UnderSheriff of Sussex County I~ ~-::, -() @ ~ ~ .~ F-O F!LES\DA TAFILE\Dickinson College 761 Q\DickinsonCollegeCollec[lons76] <>C\Currem\240-com I. wpd Created: 3117/03 9"25:57 PM Revised: 2J"20f0::1 ()-J:?9 PM 7619c ::!40 R f- C F IV'f- Q.,., ":~ DICKINSON COLLEGE, L_j-\ ,1" lnHlf~tjff 8 AcU:. 20 . :~....., .: 1 "- ," $- - ,~ ;-; .- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUS-GE:~ COUr;:TY ShERiFF _ ,1 ---,~/ NO. (7 :/ -. /(:/.) CNIL ACTION-LAW KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants ,-...:> (-' ,=-.:o : ~ ~ <:..- -."-' : nJRYT~OFTWbLVEDEMAND~~ o -n __I ~~ -).-\ ~'=:. -~; ;~':.\ ;) ---- - ~ .,.------, :..,.... :-..-~ '...... (''.:~) . - ., "'--'\ You have been sued in court. If you wish to defend against the claims sl?t ',forth ~~~ th~-\' I following pages, you must take action within twenty (20) days after this Complaint and-:N'otiee are:J: served, by entering a written appearance personally or by attorney and filing in writing with thecourt 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 OT other rights important to you. NOTICE 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. TillS 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 OFEER L~GAL SERVICES TO ELIGlBLE PERSONS AT A REDUCE FEE OR NO FEE: '.,~i2 :.} '-"r~'\ ;-:i. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 1f"""~'~ '-- . i r...) --~ .... . -ot;~<.ao ~~.~l~ r~~H1 ~.:~:J :~-:. .' " .J c;) -fl ;;J~~~~f??r~?:"~;~'~;~l~'C By r":,w3'.<<2..~:' i1~'~,L F~:;~~ David R. Galloway, Esquire 1. D. Number 87326 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Dated: February 20, 2004 .. ~ ,. C) ,... , C" c::) ~) c..77J - n c--, r' I Cj r'-'. - ::..... , '. CD . , 1',) I '. -.J FIFILESIDA T AFILEIDickinsonCollege7619ICoIIections\CllfTenlI240\pra6 Created: 3/30/05 9:44AM Revised :\/:\OiIlS IO:J2AM 7619(240 David R. Galloway, Esquire MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COM~ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. i I I I JURY TRIAL OF TWELVF DEMANDED PRAECIPE I NO. 04-760 CIVIL ACTION-LAW KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants .M. t>M Please reinstate the auaell-gdComplaint against Defendants, Karen Sa martine and Vincent Sammartine, 15 Phlox Terrace, Glenwood, NJ 07418, and return same t the undersigned for servIce. W LIAMS & OTTO By David R. Galloway I. D. Number 87326 Ten East High Street Carlisle, P A 17013 (717) 243-3341 17 , I I , Date: March 30, 2005 Attorneys for Plaintiff r-' r~ I~' .~'\', .::;\-, ",\"f-:: '("" .',.> ~1 -:;d \(/. " .~~c C.-;- V- .--------- LIAMS & OTTO F\FILES\DATAFlLE\DickinsonCallcge7619\Co\\ections\Current\24D\praJ Created: 6(21105 9:31AM Revised, 6121fOS W:02AM 7ti t9C 240 David R. Galloway, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-760 CNIL ACTION-LAW KAREN M. SAMMARTlNE and VlNCENT SAMMARTlNE, Defendants JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO DOCUMENT SERVICE AND COST OF SERVICE PURSUANT TO THE PENNSYLVANIA LONG ARM STATUTE TO THE PROTHONOTARY: Please file the attached Return of Service for Notice & Complaint from Sussex County Sheriff, New Jersey, indicating formal service was made on Defendants, Karen M. Sammartine and Vincent Sanunartine on June 4, 2005, atl5 Phlox Terrace, Vernon, New Jersey 07462. Attached is the return receipt signed and dated showing cost of service was $54.04. By David R. Galloway, I.D. No. 87326 10 E. High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: June 21, 2005 Attorneys for Plaintiff J . RETURN OF SERVICE FOR NOTICE & COMPLAINT On 6/4/2005, I served this NOTICE & COMPLAINT personally on defendant KAREN M. SAMMARTINE by delivering a true copy of the same together with a copy of the complaint therein mentioned to him (her) at his (her) place of abode, 15 PHLOX TERRACE, VERNON, NJ 07462. Remarks: Date: 5/12/2005 Time: 4:14 pm 15 PHLOX TERRACE VERNON, NJ 07462 Date: 5/17/2005 Time: 12:00 pm 15 PHLOX TERRACE VERNON, NJ 07462 Date: 5/24/2005 Time: 6:00 pm 15 PHLOX TERRACE VERNON, NJ 07462 DESCRIPTION: EYES: BLUE; HEIGHT: 5'7"; D.O.B.: 10-25-58; HAIR: RED; WEIGHT: 110 Robert E. Untig, Sheriff sjP kftpl /3L 11 rP41 By: Christopher Bork, Special Deputy Sussex County Sheriff's Fees: $34.04 .~ f'J~ URlI \.'U. A.1lOVCll __ IWrAA'l'P1:lilLICm'W .n ~llllllOH Elll'VIIU 111 "/07 Date: June 4, 2005 I hereby deputize and appoint Christopher Bork for me and in my name to serve this writ. Witness my hand and Seal the day and year above written. JJJ322J Undtr'Sheriff of Sussex County . JEer-,' -n,'..,.. \'~' , ", ".-1 .,_~. __ f .,' ~...~ JUN {) 2005 \IiD!)\!'" RETURN OF SERVICE FOR NOTICE & COMPLAINT On 6/412005, 1 served this NOTICE & COMPLAINT on defendant VINCENT SAMMARTINE by delivering a true copy of the same together with a copy of the complaint therein mentioned to KAREN M. SAMMARTINE, MOTHER and member of the household residing therein for named defendant at their place of abode, 15 PHLOX TERRACE, VERNON, NJ 07462. Remarks: Date: 5/12/2005 Time: 4:14 pm 15 PHLOX TERRACE VERNON, NJ 07462 Date: 5/17/2005 Time: 12:00 pm 15 PHLOX TERRACE VERNON, NJ 07462 Date: 5/24/2005 Time: 6:00 pm 15 PHLOX TERRACE VERNON, NJ 07462 DESCRIPTION: EYES: BLUE; HEIGHT: 5'7"; D.O.B.: 10-25-58; HAIR: RED; WEIGHT: 110 Robert E. Untig, Sheriff S( tLfrp L 6L -;t;r::l<ll By: Christopher Bork, Special Deputy Sussex County Sheriff's Fees: $20.00 t8~ II ~ 8ARIlARA A. 80PCI IIOTP.Y'I'! I"'lJI!UC Of iU MY CDUlIllll$lOll EXl'tRIi!S 11118f1fT Date: June 4, 2005 I hereby deputize and appoint Christopher Bork for me and in my name to serve this writ. Witness my hand and Seal the day and year above written. u;;J2rL UnderSheriff of Sussex County {ECF\\IEJ JUI'l G 2005 -,I'l . I!. if' , ~ . CERTIFICATE OF SERVICE I, Jean Taylor, an authorized agent of Marts on Deardorff Williams & Otto, hereby certifY that . a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Ms. Karen M. Sammartine Mr. Vincent Sammartine 15 Phlox Terrace Vernon, New Jersey 07418 MARTSON DEARDORFF WILLIAMS & OTTO By Jean. aylor Te . E st High Street CarlIsle, PA 17013 (717) 243-3341 Dated: June 21, 2005 ~ '-0 :::,;. ".t-;~: ::.2 "', ("7.) CJ <J1 '-- ~~;.; o -0-, .--\ :C-r; r11p ""'Ot.\ :bO (:) ('-, :..;j ~(, c~j E~ ~~rn ::>- :'J? --< N -ry <.11 .:;.- David R. Galloway, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-760 CIVIL ACTION-LAW KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants JURY TRIAL OF TWELVE DEMANDED TO: KAREN M. SAMMARTINE, DEFENDANT NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on, )u...~';! I LJ ' 2005, the following Judgment was entered against you in the above-captioned cas as follows: Principal plus interest through February 5, 2004: Interest from February 5,2004, through July 14, 2005: Attorneys' fees: Total Judgment: $15,533.87 $ 1,018.50 $ 2.603.91 $19,156.28 Costs of suit and interest accruing at $1.94 per day from July 14, 2005, shall be added to the Judgment for Defendant's failure to file an Answer to the Complaint. Prothonotary ~ I hereby certify that the names and addresses of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Ms. Karen M. Sammartine 15 Phlox Terrace Vernon, NJ 07462 M Date: July 14, 2005 By David R. Galloway Attorneys for Plaintiff David R. Galloway, Esquire MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-760 CIVIL ACTION-LAW KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants JURY TRIAL OF TWELVE DEMANDED TO: VINCENT SAMMARTlNE, DEFENDANT NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on--Ju.l 'J 14 ,2005, the following Judgment was entered against you in the above-captioned cas as follows: Principal plus interest through February 5, 2004: Interest from February 5, 2004, through July 14, 2005: Attorneys' fees: Total Judgment: $15,533.87 $ 1,018.50 $ 2.603.91 $19,156.28 Costs of suit and interest accruing at $1.94 per day from July 14, 2005, shall be added to the Judgment for Defendant's failure to file an Answer to the comPl~aint. C-trl0 J 12 _ _~~ Prothonotary 4 I hereby certify that the names and addresses of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Mr. Vincent Sammartine 15 Phlox Terrace Vernon, NJ 07462 M F WILLIAMS & OTTO Date: July 14, 2005 By David . alloway Attorneys for Plaintiff F:\FlLES\DA T AFlLE\DickinsonCollege7619\Collections\CUITl:111\240\pra8 Created. 71UI05 !:51WM Revised: 7/14105 8:23AM 7619C240 David R. Galloway, Esquire MARTSON DEARDORFF WILLIAMS & OTTO 10 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. 04-760 CIVIL ACTION-LAW KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO THE PROTHONOTARY: Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendants as follows: Principal plus interest through February 5,2004: Interest from February 5, 2004, through July 14, 2005: Attorneys' fees: Total Judgment: $15,533.87 $ 1,018.50 $ 2.603.91 $19,156.28 Costs of suit and interest accruing at $1.94 per day from July 14, 2005, shall be added to the Judgment for Defendants' failure to file an Answer to the Complaint. I do hereby certify that a written notice of intention to file this Praecipe (in the form attached hereto) was mailed to Defendants at their last known address on June 29, 2005, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTS ON DE RFF WILLIAMS & OTTO Dated: July 14,2005 ~ / By / David R. Ga oway, Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff I: '.Flt.I'S'PAT.' FII..F\\)id,iJl.ic",r "lIq:" ~,,: 'i.C .l.'kc'[ i,'.",'..( '",Tc""\ ,.jn".!ik.\Jym'l: C,.C"I('.[' 1.,t~'iiU5 'I Y;.\M Rc\'i\:<:,j v','H\5 .J -1\A\1 7/jI'k2\() David R. Galloway, Esquire MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-760 CIVIL ACTION-LAW KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants JURY TRIAL OF TWELVE DEMANDED TO: VINCENT SAMMARTINE IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRlTTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRlTING 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 RlGHTS. 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 REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 Date: June 29, 2005 MARTSON DEARD F WILLIAMS & OTTO ~_.: /'/ By D R. Gallow I.D. 87326 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff (-:.::,:'::,\ \.>.:1 C::'; (:-::::" \>".:,'.~::2./ t...._-'-.-~. ',\CJj -.> .-'/ c_'''"-_..... "'. ~ f2) c=1.,9 <::) F.....\'ll.l.,.S.',l)Af AFJ I.Y'-,Dicki""".,(ulkg(7h I f( '"lh'l i,,,," ('l,,\~m".2~()'.1\lcby'h)ll Cre"l':,]. G.'"2'iiU.' 'rJ3/\M \<<:>",,01- bC'J.'I)5 'i_Q,'\,\1 ".Ibl'iC2J() David R. Galloway, Esquire MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKlNSON COLLEGE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-760 CIVIL ACTION-LAW KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants JURY TRIAL OF TWELVE DEMANDED TO: KAREN M. SAMMARTINE 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. Date: June 29, 2005 Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 ~y~7~""S &0100 David R. Galloway, Esquire V LD. 87326 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff CERTIFICATE OF SERVICE I, Jean Taylor, an authorized agent of MARTS ON DEARDORFF WILLIAMS & OTTO, hereby certify that a copy ofthe 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. Karen M. Sammartine Mr. Vincent Sammartine 15 Phlox Terrace Vernon, NJ 07462 MARTS ON DEARDORFF WILLIAMS & OTTO ~/! ~/ i.~../ .1-. liL By Jean Ta Ten Ea igh Street Carlisle, PAl 7013 (717) 243-3341 Dated: July 14, 2005 0 ....' q, ,p ~ ~;:. """ ~ <J' ..... ~ (J L-- :1:"'1'1. e- r\1 e~ ~ ,- ~ - -:1JJ\::J ~ I'n,,> ,L1 ~~\-(., ~ ~ ~ (.,::,~'\ - / _i'" ~-:f' (.) - .',,~ cn r- !(! (?J '-P. ' , ~~:"l ~ r- ~ 1- i'-' ~~~D w -<- N .-<. ~ () - -l) ~ - F:\FILES \Clients \7619 Dickinson College\ 7619. Collections \7619C.Current \7619C.240 Sammartine \7619C.240.pra9.wpd Christopher E. Rice, Esquire I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243 -3341 Attorneys for Plaintiff ME PRO j1i-01.Q A 20111 tiPR 16 MI IP 43 C NER. COUNT Y AMA DICKINSON COLLEGE, Plaintiff v. KAREN M. SAMMARTINE and VINCENT SAMMARTINE, Defendants TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04 -760 : CIVIL ACTION -LAW : JURY TRIAL OF TWELVE DEMANDED PRAECIPE Please mark the judgment in the above - captioned matter satisfied and the action discontinued. Dated: If MARTSON LAW OFFICES By Celt Christopher E. Rice, Esquire I.D. No. 90916 10 East High Street Carlisle, PA 17013 (717) 243 -3341 Attorneys for Plaintiff CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON LAW OFFICES, 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: Mr. Vincent Sammartine 2 Port Royal Dr, Unit 4 Carbon, NJ 07462 MARTSON LAW OFFICES By: Dated: //,//,,.. i'l s,,,,,„. Ma (. Price 10 Ea High Street Carlisle, PA 17013 (717) 243-3341