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Home My WebLink About09-6511F:\FILES\Clients\7619 Dickinson College\Collections\Current\364\7619C.364.com/drg Created: 8/12/03 8:59AM Revised: 9/4/09 0:40PM 7619C.124 Christopher E. Rice, Esquire I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 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. 2009 - fo s'fr Cllr SHAKEENA CHEPPELLE, CIVIL ACTION - LAW Defendant 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 F:\FILESUients\7619 Dickinson College\Collections\Current\364\7619C.364.com Created: 1/4/05 0:35PM Revised: 9/4/09 0:40PM Christopher E. Rice, Esquire I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 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. 2009 - 4 6'/ 1 Ctcw( -r.cti.,,-. SHAKEENA CHEPPELLE, CIVIL ACTION - LAW Defendant COMPLAINT AND NOW, comes Plaintiff Dickinson College by and through its attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, 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. Defendant, Shakeena Cheppelle, is an adult individual with a last known address of 1004 Harriet Street, Carlisle, Cumberland County, Pennsylvania 17013. COUNTI BREACH OF CONTRACT 3. Paragraphs 1 through 2 are incorporated herein by reference as if set forth in full below. 4. Student is currently or was recently enrolled at Dickinson. 5. Student opened a Student Receivables Account (hereinafter "Account") with Dickinson to pay tuition, dining service fees and other educational expenses provided and rendered to Student by Dickinson. A true and correct copy of that Account is incorporated by reference and attached as Exhibit "A." 6. Student, by opening the Account and using the goods and services provided by Dickinson, agreed to pay Dickinson for all charges made to the Account. 7. Student received and accepted all goods and services provided by Dickinson and thereby agreed to payment for said goods and services. 8. The terms of repayment required Student to pay all balances 14 (fourteen) days before the beginning of each semester. 9. Student defaulted on the repayment of the Account by not paying the balance when due. 10. Notices were forwarded to Student informing him of his default and right to cure such default. 11. Student failed to cure such defaults. 12. The total amount which is immediately due and payable to Dickinson by Student on the Account is Six Thousand Four Hundred Twenty-four and 39/100 Dollars ($6,424.39). WHEREFORE, Plaintiff Dickinson College demands judgment against Defendant, Shakeena Cheppelle, in the sum of Six Thousand Four Hundred Twenty-four and 39/100 Dollars ($6,424.39), plus late fees, costs of suit and interest from date of judgment. COUNT II IN QUANTUM MERUIT In the alternative, if this Honorable Court should determine that an express contract between Dickinson and Shakeena Cheppelle does not exist, which is denied, Dickinson pleads the following: 13. Paragraphs 1 through 12 are incorporated herein by reference as if set forth in full. 14. Because Dickinson loaned money to Student, to the benefit of Student, Student became liable to Dickinson for said money. 15. Student was unjustly enriched by accepting said money without paying Dickinson reasonable compensation therefor. 16. The total amount by which Student has become enriched is Six Thousand Four Hundred Twenty-four and 39/100 Dollars ($6,424.39). 17. Dickinson demanded payment of the above sums but Student failed and refused to do so. WHEREFORE, Plaintiff Dickinson College demands judgment against Defendant Shakeena Cheppelle in the sum of Six Thousand Four Hundred Twenty-four and 39/100 Dollars ($6,424.39) plus late fees, costs of suit and interest from date of judgment. MARTSON LAW OFFICES By: Date: 9-fig .o / Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff This a debt collecting firm for Dickinson College. Any information obtained will be used for that purpose. EXHIBIT "A" 29-SEP-200 6 12:46: 40 Dickinson College PAGE 1 ALL TERMS Student Trans S ummary Report TSRSSUM 900080589 Chappe e, -a na L Balance: 6,958.39 EFF DATE Description CHARGE PAYMENT TERM 04-APR-06 Finance Charge 395.50 200620 08-MAR-06 Student Activities Fee -160.00 200620 OB-MAR-06 Meal Plan - Spring -1,701.32 200620 08-MAR-06 Tuition Spring -15,900.00 200620 08-MAR-06 Finance Charge -395.50 200620 08-MAR-06 Housing Double - Fall -2,042.56 200620 08-MAR-06 Finance Charge -157.00 200620 01-MAR-06 Finance Charge 395.50 200620 21-FEB-06 Tuition Remission Spring -15,900.00 200620 01-FEB-06 Finance Charge 157.00 200620 30-NOV-05 Housing Double - Fall 2,350.00 200620 30-NOV-05 Tuition Remission Spring 15,900.00 200620 29-NOV-05 Student Activities Fee 160.00 200620 29-NOV-05 Tuition Spring 15,900.00 200620 29-NOV-05 Meal Plan - Spring 1,950.00 200620 23-NOV-05 Dining Services 2.94 200570 01-NOV-05 BKSTR - Miscellaneous 21.75 200570 01-NOV-05 BKSTR - Pa Sales Tax .21 200570 01-NOV-05 Dining Services 1.40 200570 01-NOV-05 BKSTR - Grocery 20.82 200570 03-OCT-05 BKSTR - Clothing 29.98 200570 03-OCT-05 BKSTR - Grocery 108.14 200570 03-OCT-05 BKSTR - Text Books 193.50 200570 03-OCT-05 BKSTR - Miscellaneous 121.21 200570 03-OCT-05 BKSTR - Pa Sales Tax 8.00 200570 03-OCT-05 Dining Services 14.75 200570 03-OCT-05 BKSTR - Supplies 11.62 200570 01-SEP-05 Dining Services 9.85 200570 22-AUG-05 BKSTR - Grocery 6.92 200570 22-AUG-05 BKSTR - Miscellaneous 4.99 200570 22-AUG-05 BKSTR - Pa Sales Tax .30 200570 01-AUG-05 BKSTR - Grocery 73.01 200570 01-AUG-05 BKSTR - Computer/Supplies 2.99 200570 01-AUG-05 BKSTR - Trade Books 24.95 200570 01-AUG-05 BKSTR - Pa Sales Tax 3.40 200570 01-AUG-05 BKSTR - Miscellaneous 14.97 200570 01-AUG-05 Dining Services 9.00 200570 01-AUG-05 BKSTR - Supplies 13.59 200570 06-JUL-05 Health Insurance Student Fall -240.00 200570 06-JUL-05 Tuition Remission Fall 15,900.00 200570 05-JUL-05 Housing Double - Fall 2,350.00 200570 05-JUL-05 Meal Pl an - Fall 1,950.00 200570 05-JUL-05 Student Activities Fee 160.00 200570 05-JUL-05 Health Insurance Student Fall 240.00 200570 05-JUL-05 Tuition Fall 15,900.00 200570 30-JUN-05 Dining Services 1.20 200550 14-JUN-05 SKSTR - Computer/Supplies .69 200550 14-JUN-05 BKSTR - Supplies 5.63 200550 14-JUN-OS BKSTR - Miscellaneous 11.57 200550 14-JUN-05 BKSTR - Grocery 42.68 200550 14-JUN-05 BKSTR - Pa Sales Tax 1.82 200550 *****CONTINUED ON NEXT PAGE***** 29-SEP-2006 12:46:40 ALL TERMS *****CONTINUED FROM P] EFF DATE Description Dickinson College PAGE 2 Student Trans Summary Report TSRSSUM 900080589 Chappelle, Shakeena L Balance: 6,958.39 tEVIOUS PAGE***** CHARGE PAYMENT TERM 02-JUN-05 Tuition SSI -1,990.00 200550 02-JUN-05 Tuition SSI 1,990.00 200550 01-JUN-05 Miscellaneous Credit 1,465.00 200560 01-JUN-05 BKSTR - Text Books 86.50 200520 01-JUN-05 Dining Services 3.94 200520 01-JUN-05 BKSTR - Pa Sales Tax 2.29 200520 01-JUN-05 BKSTR - Grocery 65.40 200520 01-JUN-05 Miscellaneous Credit 1,465.00 200550 01-JUN-05 BKSTR - Miscellaneous 57.74 200520 01-JUN-05 BKSTR - Supplies 3.38 200520 24-MAY-05 Tuition Remission (Summer RA) 1,990.00 200550 17-MAY-05 Tuition SSI -1,990.00 200550 12-MAY-05 Meal Plan - Summer Session I 820.00 200550 12-MAY-05 Housing Summer Session I 645.00 200550 12-MAY-05 Housing Summer Session II 645.00 200560 12-MAY-05 Tuition SSI 1,990.00 200550 12-MAY-05 Meal Plan - Summer Session II 820.00 200560 05-MAY-05 Tuition SSI 1,990.00 200550 03-MAY-05 Lock Ou t Fee Safety & Security 5.00 200520 02-MAY-05 BKSTR - Clothing 71.15 200520 02-MAY-05 BKSTR - Miscellaneous 39.32 200520 02-MAY-05 BKSTR - Pa Sales Tax 1.80 200520 02-MAY-05 Finance Charge 1.93 200520 02-MAY-05 BKSTR - Grocery 183.58 200520 01-MAY-05 Dining Services 3.20 200520 01-APR-05 BKSTR - Grocery 56.08 200520 01-APR-05 Dining Services .35 200520 01-APR-05 BKSTR - Miscellaneous 72.94 200520 01-APR-05 BKSTR - Pa Sales Tax .82 200520 01-APR-05 BKSTR - Supplies .50 200520 01-MAR-05 BKSTR - Text Books 45.25 200520 01-MAR-05 Dining Services 6.65 200520 01-MAR-05 BKSTR - Grocery 70.36 200520 01-MAR-05 BKSTR - Trade Books 11.50 200520 01-MAR-05 BKSTR - Pa Sales Tax 1.62 200520 01-MAR-05 BKSTR - Miscellaneous 23.22 200520 01-MAR-05 BKSTR - Supplies 2.99 200520 02-FEB-05 BKSTR - Grocery 21.06 200520 02-FEB-05 BKSTR - Supplies 2.76 200520 02-FEB-05 BKSTR - Pa Sales Tax .41 200520 02-FEB-05 BKSTR - Miscellaneous 3.99 200520 02-FEB-05 BKSTR - Text Books 295.60 200520 01-FEB-05 Dining Services 1.25 200520 14-JAN-05 Subsidi zed Federal Stafford Lo 429.00 200520 14-JAN-05 Unsubsi dized Fed Stafford Loan 1,321.00 200520 14-JAN-05 Unsubsi dized Fed Stafford Loan 850.00 200520 03-JAN-05 BKSTR - Grocery 47.12 200520 03-JAN-05 Dining Services 5.35 200520 03-JAN-05 BKSTR - Pa Sales Tax 2.63 200520 03-JAN-05 BKSTR - Miscellaneous 46.76 200520 29-NOV-04 Meal Pl an - Spring 1,840.00 200520 29-SEP-2006 12:46:40 Dickinson College PAGE 3 ALL TEWiS Student Trans Summary Report TSRSSUM 900080589 Chappelle, Shakeena L Balance: 6,958.39 *****CONTINUED FROM PREVIOUS PAGE***** EFF DATE Description CHARGE PAYMENT TERM 29-NOV-04 Tuition Remission Spring 1,500.00 200532 29-NOV-04 Tuition Remission Spring 13,500.00 200520 29-NOV-04 PA State Grant (PHEAA) 1,650.00 200520 29-NOV-04 Tuition Spring 15,000.00 200520 29-NOV-04 Student Activities Fee 150.00 200520 24-NOV-04 BKSTR - Grocery 18.77 200470 24-NOV-04 Dining Services 9.57 200470 22-OCT-04 Unsubsidized Fed Stafford Loan 157.83 200471 22-OCT-04 Unsubsidized Fed Stafford Loan 661.85 200470 22-OCT-04 Unsubsidized Fed Stafford Loan 30.32 200470 08-OCT-04 Unsubsidized Fed Stafford Loan 1,321.00 200470 04-OCT-04 BKSTR - Pa Sales Tax .60 200470 04-OCT-04 BKSTR - Grocery 7.16 200470 04-OCT-04 Finance Charge -30.77 200470 04-OCT-04 BKSTR - Clothing 26.99 200470 04-OCT-04 BKSTR - Miscellaneous 10.00 200470 01-OCT-04 Finance Charge 30.77 200470 01-OCT-04 Finance Charge 30.32 200470 01-OCT-04 Health Center Charge 10.00 200470 01-OCT-04 Dining Services 1.90 200470 28-SEP-04 PA State Grant (PHEAA) 1,650.00 200470 28-SEP-04 Subsidized Federal Stafford Lo -1,321.00 200470 27-AUG-04 BKSTR Pa Sales Tax 10.20 200470 27-AUG-04 BKSTR - Miscellaneous 170.00 200470 23-AUG-04 Subsidized Federal Stafford Lo 1,750.00 200470 12-AUG-04 Health Insurance Student Fall -200.00 200470 07-JUL-04 Tuition Remission Fall 15,000.00 200470 07-JUL-04 Meal Plan - Fall 1,840.00 200470 06-JUL-04 Housing Double - Fall 1,835.00 200470 06-JUL-04 Tuition Fall 15,000.00 200470 06-JUL-04 Student Activities Fee 150.00 200470 06-JUL-04 Health Insurance Student Fall 200.00 200470 01-JUL-04 Finance Charge 1.40 200450 01-JUN-04 Health Center Charge 56.00 200420 13-MAY-04 Lock Out Fee Safety & Security 5.00 200420 13-MAY-04 Key Charge 50.00 200420 07-MAY-04 Finance Charge -8.25 200420 07-MAY-04 Finance Charge -9.21 200420 07-MAY-04 Cash Received on Account 72.32 200420 03-MAY-04 Finance Charge 8.25 200420 05-APR-04 Cash Received on Account 550.00 200420 01-APR-04 Health Center Charge 54.00 200420 01-APR-04 Finance Charge 8.13 200420 O1-APR-04 Dining Services 10.00 200420 30-MAR-04 Check Received on Account 1,000.00 200420 30-MAR-04 Check Received on Account 500.00 200420 02-MAR-04 Finance Charge 30.18 200420 10-FEB-04 Check Received on Account 50.00 200420 03-FEB-04 Finance Charge 30.47 200420 16-JAN-04 Subsidized Federal Stafford Lo 1,312.00 200420 16-JAN-04 Unsubsidized Fed Stafford Loan 2,000.00 200420 . 29-SEP-2006 12:46:40 ALL T.RMS *****CONTINUED FROM P1 EFF DATE Description Dickinson College PAGE 4 Student Trans Summary Report TSRSSUM 900080589 Chappelle, Shakeena L Balance: 6,958.39 ZEVIOUS PAGE***** CHARGE PAYMENT TERM 07-JAN-04 Subsidized Federal Stafford Lo 1,313.00 200370 03-DEC-03 Dickinson Grant 1,900.00 200420 03-DEC-03 PA State Grant (PHEAA) 1,650.00 200420 03-DEC-03 Tuition Remission Spring 9,508.00 200420 02-DEC-03 Student Activities Fee 117.50 200420 02-DEC-03 Meal Plan - Spring 1,745.00 200420 02-DEC-03 Tuition Spring 14,190.00 200420 02-DEC-03 Housing Double - Spring 1,860.00 200420 26-NOV-03 Cash Received on Account 200.00 200370 23-NOV-03 Health Center Charge 10.00 200370 01-NOV-03 BKSTR - Miscellaneous 3.79 200370 01-NOV-03 BKSTR - Pa Sales Tax .23 200370 30-OCT-03 Finance Charge 58.86 200370 16-OCT-03 Lock Out Fee Safety & Security 5.00 200370 30-SEP-03 BKSTR - Pa Sales Tax 1.64 200370 30-SEP-03 BKSTR - Grocery 9.92 200370 30-SEP-03 BKSTR - Miscellaneous 26.00 200370 28-SEP-03 Dining Services 2.85 200370 02-SEP-03 Check Received on Account 497.00 200370 02-SEP-03 Tuition Mgmt Systems Payment -588.08 200370 04-AUG-03 Tuition Mgmt Systems Payment 588.08 200360 15-JUL-03 PA State Grant (PHEAA) 1,650.00 200370 08-JUL-03 Health Insurance Student Fall -190.00 200370 08-JUL-03 Tuition Remission Fall 9,507.00 200370 08-JUL-03 Dickinson Grant 1,900.00 200370 07-JUL-03 Transcript Fee 25.00 200370 07-JUL-03 Meal Plan - Fall 1,745.00 200370 07-JUL-03 Student Activities Fee 117.50 200370 07-JUL-03 Health Insurance Student Fall 190.00 200370 07-JUL-03 Housing Double - Fall 1,860.00 200370 07-JUL-03 Tuition Fall 14,190.00 200370 11-JUN-03 Freshman/Transfer Deposit 500.00 200370 08-APR-03 Bad Debt Write Off -397.44 200320 21-FEB-03 Cash Received on Account 50.00 200320 06-FEB-03 Finance Charge 6.61 200320 14-NOV-02 Tuition Remission Session II 934.17 200260 12-NOV-02 Cash Received on Account 25.00 200270 23-AUG-02 Check Received on Account 75.00 200260 13-JUN-02 Miscellaneous Credit 2,500.00 200260 13-JUN-02 Pre-College Program Deposit 100.00 200220 13-JUN-02 Pre-College Tuition 4,075.00 ---------- ---------- 200260 TOTAL: 106,071.88 99,113.49 29-SEP-2006 12:46:40 Dickinson College PAGE 5 ALL TERMS Student Trans Summary Report TSRSSUM * * * REPORT CONTROL INFORMATION * * * RPTNAME: TSRSSUM VERSION: 4.2 Student ID: 900080589 Term: 4 Detail Code: Date on Report: E Print Summary by Term Section: Run in Sleep/Wake mode: N Sleep/Wake Interval: 60 Printer: Print Control Report: Y SELECTION ID: APPLICATION CODE: CREATOR ID: FROM DATE: 01-OCT-1988 TO DATE: 31-DEC-2099 REPORT TOTALS BALANCE DUE: 6,958.39 ACCOUNT BALANCE: .00 RECORD COUNT: 1 VERIFICATION 1, 1,11q A, ?tckwdo rri , Bursar 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 By: Dated: Z? _ 0 f' FILE[' i it r -F Ti 2009 SE P 29 1 : l 7f -SO ,OW ,4 414 -t,;v6,;kr AO-Tw a3/ / ? a Sheriffs Office of Cumberland County R Thomas Kline Sheriff OPIPV Thy- FIFF FILEI-FILE OF TI-iE FF' )TI ]' Y' i'OTAFY Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor 2009 OCT -7 AM 8: 48 PrNN,?SYI_.VA",t'H Dickinson College vs. Shakeena Cheppelle Case Number 2009-6511 SHERIFF'S RETURN OF SERVICE 10/02/2009 08:50 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on October 2, 2009 at 2050 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Shakeena Cheppelle, by making known unto herself personally, at 1004 Harriet Street Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $33.84 October 05, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF 13y--- Depu y Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION DICKINSON COLLEGE V S. . ^ Confessed Judgment Plaintiff Q Other SHAKEENA CHEPPELLE Defendant Address: 1004 Harriet Street Carlisle, PA 17013 File No. 20096511 C o Amount Due $6,424.39 ~ 0 O Interest $1.Ob per day cn ~~ '-'i ' tt~ T ' "' """ s Comm . Atty ' _ -C Costs "~~ ~ ~ ~ r~ ~~= -a ~ TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of CUt711JePIdnCI County, for debt, interest and costs, upon the following described property of the defendant (s) Any and all personal property owned by Shakeena Cheppelle, 1004 Harriet Street, Carlisle, PA 17013 PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee (s) as a lis defendant(s) described in the attached exhibit. ODate /0 f // ~/a Signature: s Print Name: 33.8 y GB1= 78.50 ~~ l ~t. o o " a.so 15a . s~ - Po Am __ ~ 01. a0 ~Q UP Clo ~o ~Z~ ~ a~g~a3 pendens against real estate of the ~' /I~ Christopher E. Rice, Esquire Address: 10 East High Street Carlisle, PA 17013 Attorney for: Plaintiff Telephone: 717-243-3341 Supreme Court ID No: 90916 O -ri -.~ M -v ~~ ~ -Ts o-~c ~~ ---+~ -C WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-6511 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DICKINSON COLLEGE, Plaintiff (s) From SHAKEENA CHEPPELLE, 1004 Harriet Street, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell any and all personal property owned by defendant . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $6,424.39 L.L.$.50 Interest at $1.06 per day Atty's Comm % Due Prothy $2.00 Atty Paid $152.84 Other Costs Plaintiff Paid Date: 10/11 /10 uell, Prot onotary (Seal) By: Deputy REQUESTING PARTY: Name CHRISTOPHER E. RICE, ESQUIRE Address: MARTSON LAW OFFICES 10 EAST HIGH STREET CARLISLE, PA 17013 Attorney for: PLAINTIFF Telephone: 717-243-3341 Supreme Court ID No. 90916 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFF .F F? € Per Dickinson College Case Number vs. Shakeena Cheppelle 2009-6511 SHERIFF'S RETURN OF SERVICE 11/03/2010 03:00 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on November 3, 2010 at 1458 hours, he served a true copy of the within writ of execution, upon the defendant, to wit: Shakeena Chepelle, by making known unto Kitzi Chappelle, at 1004 Harriet Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on 11-04-10. 11/12/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiffs attorney. SHERIFF COST: $69.01 SO ANSWERS, November 12, 2010 RON R ANDERSON, SHERIFF &-'z- 1B3 S aron R. Lant 0 • Do /oG( to . S D L/--/d a sji ;z (c CnunrySuite 5her.ff. Te!.e.os ft. Inc. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-6511 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DICKINSON COLLEGE Plaintiff (s) From SHAKEENA CHEPPELLE, 1004 HARRIET STREET, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell ANY AND ALL PERSONAL PROPERTY OWNED BY DEFENDANT SHAKEENA CHEPPELLE. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$6,424.39 L.L. $.50 Interest $1.06 PER DAY FROM 11/2/09 Atty's Comm % Atty Paid $250.35 Plaintiff Paid Due Prothy $2.25 Other Costs Date: MAY 23, 2012 (Seal) REQUESTING PARTY: Name : CHRISTOPHER E. RICE, ESQUIRE Address: MARTSON LAW OFFICES 10 EAST HIGH STREET CARLISLE, PA 17013 Attorney for: PLAINTIFF Telephone: 717-243-3341 Supreme Court ID No. 90916 David D. Buell, Prothonotary Deputy M ILE0-0F F ICL' THE PR03HONO AFC-' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTJ0tJ1*MAJ* 11: 19 CIVIL DIVISION CUMVLANG COUNTY PRAECIPE FOR WRIT OF EXECUTION PENNSYLVANIA DICKINSON COLLEGE Plaintiff vs. SHAKEENA CHEPPELLE Defendant Address: 10of "axri& lj% Cp,r?i'y?e ? "?1 ?1ot 3 TO THE PROTHONOTARY OF THE SAID COURT: Confessed Judgment Other File No. 2009 - 6511 Amount Due 6,424.39 Interest $1.06 per day from 11/2/09 Atty's Comm Costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant (s) Any and all personal property owned by Defendant Shakeena Cheppelle PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). Date 0 (Indicate) Index this writ against the garnishee (s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. ?- rf Signature: / ?- Print Name: Christopher E. Rice, OL 33. ! 10.4 I ft )4.00 00 ai6A ? aso. 35. Address: 10 East High Street Carlisle, PA 17013 Attorney for: Plaintiff Telephone: (717) 243-3341 Supreme Court ID No: 90916 S C1• ?.. SC>u- Gc.? ?lSto?? R_a a-i Sul LP Esquire W( ti cif d SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Anderson if , ?t, of ?iatt?hf, / , 0 1 t ;l t 1 a` .ody S Smith r Chief Deputy Richard W Stewart Solicitor Dickinson College Case Number vs. Shakeena Cheppelle 2009-6511 SHERIFF'S RETURN OF SERVICE 06/01/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as STAYED per request of plaintiffs attorney. SHERIFF COST: $48.60 SO ANSWERS, June 01, 2012 RON R ANDERSON, SHERIFF I'd ? co, ..5? Lc Id- A,-0- 5?"?olelf 7& /i3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION ❑ Confessed Judgment Plaintiff ❑✓ Other File No. 2009-6511 Amount Due 6,424.39 Dickinson College VS. Shakeena Cheppelle Address: 1004 Harriet Street Carlisle, PA 17013 C. C: rrnc ✓7 [lorry Defendant Interest $1.06 per day from 11/2/09 $600.00 • Atty's Comm • Costs r� TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant (s) Any and all personal property owned by Defendant Shakeena Cheppelle PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ❑ (Indicate) Index this writ against the garnishee (s) as a lis pendens against real estate of the defen ant(s) described in the attached exhibit. Date MAY. /54' Signature: Print Name: Address: 'Pe. 50 33.84/ 6q. o qg 60 12.5b 00 2Lt .00 #-.q / 7C I 2.2.5�Jve �. FA- JEc,eCY/ Attorney for: Telephone: Christopher E. Rice, Esquire 10 East High Street Carlisle, PA 17013 Plaintiff 717-243-3341 Supreme Court ID No: 90916 m i 1/4.7 Cr; THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net Dickinson College Vs. NO 09-6511 Civil Term CIVIL ACTION — LAW Shakeena Cheppelle 1004 Harriet Street Carlisle, PA 17013 WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against Shakeena Cheppelle Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s)'interest therein; Any and all personal property owned by Defendant Shakeena Cheppelle. (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being , funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $6,424.39 Interest $1.06 per day from 11/2/09 Attorney's Comm. % $600.00 Attorney Paid $324.95 Date: 12/29/2014 REQUESTING PARTY: Name : Christopher E. Rice, Esq. Address: 10 East High Street Carlisle, PA 17013 Attorney for: Plaintiff Telephone: 717-243-3341. Supreme Court ID No. 90916. Plaintiff Paid Law Library Due Prothonotary $2.25 Other Costs David D. Buell, Prothonotary MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law C7e~eik< Deputy 2