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HomeMy WebLinkAbout11-75113 or 1: TILESTlients17619 Dickinson CollegeA7619.Collections\7619. CCuuentA380 GouldA7619C. 380,com ru-?11 n T Christopher E. Rice, Esquire Attorney I.D. No. 90916 - R'3 MARTSON DEARDORFF WILLIAMS OTTO GILROY & ALQt MARTSON LAW OFFICES Ten East High Street , . SY Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2011 - 1 s c l l CAMDEN GOULD, 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 Ct? ? ?t sc?? f? a to sag °r FAFILES\Clients\7619 Dickinson College\7619.Collections\7619.C.Cuaent\380 Gould\7619C.380.com Christopher E. Rice, Esquire Attorney 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. 2011 - CAMDEN GOULD, 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: Plaintiff, Dickinson College, is a Pennsylvania educational institution and nonprofit corporation with a business address of Post Office Box 1773, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant, Camden Gould, is an adult individual with a last known address of 149 Veazie Street, Old Town, Maine 04468. 3. On or about September 2, 2005, Defendant entered into a Promissory Note ("Note") with Plaintiff for the financing of $2,200.00 plus interest for educational services and benefits at Plaintiffs institution. A copy of the Note is attached hereto as Exhibit "A." 4. The Note is a fund created under Part E of Title IV of the Higher Education Act of 1965 as amended (hereinafter the "Act") and is subject to the Act and the Federal Regulations issued under the Act. 5. As provided in the Act, Plaintiff acts in a fiduciary capacity in the handling, disbursing and collecting of funds associated with the programs under the Act. 6. The collective principal for the Note was $2,200.00. 7. The Note grants Plaintiff reasonable collection and attorneys' fees which Plaintiff has calculated to be $500.00. 8. As of August 4, 2011, the principal and interest due and payable by Defendant to Plaintiff was $1,748.17, with interest accruing at 5% per annum. 9. Plaintiff has fulfilled, performed and complied with all obligations and conditions of the Note. COUNTI BREACH OF CONTRACT 10. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 10 of this Complaint. 11. Defendant breached the expressed and implied obligations, conditions and terms of agreement of the by failing to pay the amounts financed therein. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $1,748.17, plus interest accruing at 5% per annum, collection and attorneys' fees in the amount of $500.00, and costs of suit. COUNT II IN QUANTUMMERUIT 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 Defendant, Defendant became liable to Plaintiff for said money. 14. Defendant has been unjustly enriched by accepting said money without paying Plaintiff reasonable compensation therefor. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $1,748.17, plus interest accruing at 5% per annum, collection and attorneys' fees in the amount of $500.00, and costs of suit. MARTSON LAW OFFICES By: d1g,.44 S &..' Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: Attorneys for Plaintiff THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR DICKINSON COLLEGE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT "A" FEDERAL PERKINS LOAN MASTER PROMISSORY NOTE OMB No. 184S-0074 Form A- A Rm;rat6- rat. c AAW)nnA 1. Name (last, first, middle initial) and C a,t j, („, fa Permanent Address (street it t t d 2, Social Security Number , c y, s a e, zip co e) IH 9 5f. 3. Date of Birth (mm/dd/yyyy) I? 0 i & Tu :-, 114 E 046 t? 4. Home Area Code/Telephone Number 7.-7-, Vo-11 river License Number (List state abbreviation first) 6. Dickinson College 7. Annual Interest Rate P.O. Box 1773 5% Carlisle, PA 17013-2896 [Any bracketed clause or paragraph may be included at option of instituti on] Terms and Conditions: (Note: Additional Terms and Conditions follow on subsequent pages) APPLICABLE LAW -The terms of this Federal Perkins Loan Master Promissory Note (hereinafter called the Note) and any disbursements made under this Note shall be interpreted in accordance with Part E of Title N of the Higher Education Act of 1965, as amended (hereinafter called the Act), as well as Federal regulations issued under the Act. All sums advanced under this Note are subject to the Act and Federal regulations issued under the Act. REPAYMENT - I am obligated to repay the principal and the interest that accrues on my loan(s) to the above-named institution (hereinafter called the School) over a period beginning 9 months (or sooner if I am a Less-Than-Half-Time Borrower) after the date I cease to be at least a half-time student at an institution of higher education or a comparable School outside the United States approved by the United States Department of Education (hereinafter called the Department) and ending 10 years later, unless I request in writing that my repayment period begin sooner. I understand that the School will report the amount of my installment payments, along with the amount of this loan to at least one national credit bureau. Interest on this loan shall accrue from the beginning of the repayment period. My repayment period may be shorter than 10 years if I am required by my School to make minimum monthly payments. My repayment period may be extended during periods of deferment, hardship, or forbearance and I may make graduated installments in accordance with a schedule approved by the Department I will make my installment payments in equal monthly, bimonthly, or quarterly installments as determined by the School. The School may round my installment payment to the next highest multiple of $5. [I will make a minimum monthly repayment of $40 (or S30 if I have outstanding Federal Perkins Loans made before October 1, 1992 that included the S30 minimum payment option or outstanding National Direct Student Loans) in accordance with the Minimum Monthly Payment Section of the Terms and Conditions contained on the reverse side of this document.] LATE CHARGES - The School may impose late charges if I do not make a scheduled payment when due or if I fail to submit to the School on or before the due date of the payment, a properly documented request for any of the forbearance, deferment, or cancellation benefits as described below. No late charges may exceed 20 percent of my monthly, bimonthly, or quarterly payment The School may add the late charges to principal the day after the scheduled payment was due or include it with the next scheduled payment after I have received notice of the charge, and such notice is sent before the next installment is due. FORBEARANCE, DEFERMENT, OR CANCELLATION - I may apply for a forbearance, deferment, or cancellation on my loan. During an approved forbearance period, payments of principal and interest, or principal only, maybe postponed or reduced. Interest continues to accrue while my loan is in forbearance. During an approved deferment period, I am not required to make scheduled installment payments on my loan. I am not liable for any interest that might otherwise accrue while my loan is in deferment If I meet the eligibility requirements for a cancellation of my loan, the institution may cancel up to 100 percent of the outstanding principal loan amount Information on eligibility and application requirements for forbearances, deferments, and cancellations is provided on pages 2 and 3 of this Note. I am responsible for submitting the appropriate requests on time, and I may lose my benefits if I fail to file my request on time. DEFAULT - The School may, at its-option, declare my loan to be in default if (1) I fail to make a scheduled payment when due; (2) I fail to submit to the School, on or before the due date of a scheduled payment, documentation that I qualify for a forbearance, deferment, or cancellation; or (3) I fail to comply with the terms and conditions of this Note or written repayment agreement. The School may assign a defaulted loan to the Department for collection. I will be ineligible for any further federal student financial assistance authorized under the Act until I make arrangements that are satisfactory to the School or the Department to repay my loan. The School or the Department shall disclose to credit bureau organizations that I have defaulted and all other relevant loan information. I will lose my right to defer payments and nr right to forbearance if I default on my loan. The School or the Department may accelerate my defaulted loan. Acceleration means that the School or the Department demands immediate payment of the entire unpaid balance of the loan, including principal, interest, late charges, and collection costs. I will lose my right to receive cancellation benefits for service that is performed after the date the School or the Department accelerated the loan. CHANGE OF STATUS - I will inform the School of any change in my name, address, telephone number, Social Security Number, or driver's license number. PROMISE TO PAY: I promise to pay the School, or a subsequent holder of the Note, all sums disbursed under the terms of this Note, plus interest and other fees which may become due as provided in this Note. I understand that multiple loans may be made to me under this Note. I understand that by accepting any disbursements issued at any time under this Note, I agree to repay the loans. I understand that each loan is separately enforceable based on a true and exact copy of this Note. I understand that I may cancel or reduce the amount of any loan by not accepting or by returning all or a portion of any disbursement that is issued. If 1 do not make any payment on any loan under this Note when it is due, I promise to pay all reasonable collection costs, including attorney fees, court costs, and other fees. I will not sign this Note before reading the entire Note, even if I am told that I am not required to read it. I am entitled to an exact copy of this Note. This loan has been made to me without security or endorsement My signature certifies I have read, understand, and agree to the terms and conditions of this Note. I UNDERSTAND THAT I MAY RECEIVE ONE OR MORE LOANS UNDER THIS MASTER PROMISSORY NOTE AND THAT I MUST REPAY SUCH LOANS. Borrower's Signature Date Page I of 4 2?J VERIFICATION I, SALLY HECKENDORN, 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: Sally Heck dorn, Bursar F.\ FILES\Cliems\7619 Dickinson College\7619.Collections\7619.C.Current\380 Gould\7619C.380.com F.TILES\Clients\7619 Dickinson College\7619. Coll rations\7619. C. Current\380 Gould\7619C.380. pra Christopher E. Rice, Esquire Attorney 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 ;r ;0 " CIO ?I cry ? 1 : r ©o < ?Z^+? C C rnt-r DICKINSON COLLEGE, Plaintiff V. CAMDEN GOULD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2011 - 7511 CIVIL ACTION - LAW PRAECIPE To the Prothonotary: Please reinstate the Complaint in the above-referenced matter. Date: " otk?_1 MARTSON LAW OFFICES Bv: Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR DICKINSON COLLEGE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. w F.AFILESVClientsA7619 Dickinson CollegeA7619. Collections\7619. C Current\380 Gould\7619C.380.as Christopher E. Rice, Esquire Attorney 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. 2011 - 7511 CAMDEN GOULD, CIVIL ACTION - LAW Defendant AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Complaint in the above captioned matter was personally served upon Defendant, Camden Gould at 149 Veazie Street, Old Town, Maine. Attached is the Return of Service form signed by the Penobscot County Sheriff's Office with receipt of costs in the amount of $34.54. By Oz,/ Sworn to and subscribed before me this JJ - day of May, 2012. MARTSON LAW OFFICES 1112-1- Christopher E. Rice, Esquire Attorney I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 L r$l1 Ajouq/A, No, a ublic com OF PENNSYLVANIA No"I seal Mary M. Price, Notary Public CadUN ftm, G nberland County CMIYMipr mires Aug. 18, 2015 noN of rrolr r-S ?w N `- '.I rnw ?- =rn r-:r mac ? C :zr )> ?` ry Glenn C. Ross Sheriff lH?a?f? V Civil Division Sheriffs Return of Service STATE OF MAINE County of Penobscot, ss. Troy Morton Chief Deputy On / TGrc?j S a (date) I served the cr,, n I f upon Defendant G:r„„ /CC by delivering a copy of the same at the following address: IY5? yer, ,,p S1, old -?-cj,_,•, To the above-named Defendant in hand. To (name) a person of suitable age and discretion who was then residing at the Defendant's usual place of abode. F1 By (describe other manor of service): Cost of Service: Service Fee: $ C: Travel: $ ar Postage & Deputy Sheriff Handling Fee: $ .6-o Other: Notary $ 5.00 Penobscot County Sheriffs Office TOTAL: $ .345q State of Maine Penobscot, ss. Subscribed and sworn to before me this j t k day of?? C/ Notary Pub c Claudia M. cer T ?d/t'rMr Maine Notary Puolic • Mate olJVlA My Commission Expires: NmeMlw 27 2018"' I-Wres: November 27 2018 85 Hammond Street (P.O. Box 943) Bangor, ME 04401 (207) 947-4585 C -D 3 lV 7J F "' Christopher E. Rice, Esquire ? ?' cf Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER ` MARTSON LAW OFFICES -Ai 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, PENNSYL VANIA V, : NO. 2011 - 7511 CAMDEN GOULD, CIVIL ACTION - LAW Defendant TO: CAMDEN GOULD, DEFENDANT NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the And day of ??" , 2012, the following Judgment was entered against you in the above-captioned action: judgment in the amount of $1,748.17, plus interest accruing at 5% per annum, collection and attorneys' fees in the amount of $500.00, and costs of suit. Date: a ?--Wu 0 Prothonotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Camden Gould 149 Veazie Street Old Town, ME 04468 I FILES'UientsV7619 Dickinson CollegeA7619.Collections\7619C. Curren;A7619C380 GouldV7619C 380. pra default Christopher E. Rice, Esquire Attorney 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 -?C-, _ --J DICKINSON COLLEGE, Plaintiff V. CAMDEN GOULD, Defendant TO THE PROTHONOTARY: IN THE COURT OFCOMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2011 - 7511 : CIVIL ACTION - LAW PRAECIPE Enter default. judgment in the above-captioned action in favor of Plaintiff and against Defendant in the of amount of $1,748.17, plus interest accruing at 5% per annum, collection and attorneys' fees in the amount of $500.00, and costs of suit as prayed for in the Complaint, for failure to file an Answer to Plaintiffs Complaint. I do hereby certify that a written notice of intention to file this Praecipe was mailed to the Defendant at the address indicated thereon, on May 2, 2012, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTSON LAW OFFICES s' By_ Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Dated: 7102 hal? 41&'!50 PA Ayr-/ oc7kae-llto` lec/ F.. FILFS,Uhents'. o19 Dickln;on Col l eee,7019 Callections\7619.0 Current\350 l3oojdA76190380 Mdaynouce Christopher E, Rice, Esquire Attorney 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 NO. 2011-75H V. CAMDEN GOULD, CIVIL ACTION - LAW Defendant IMPORTANT NOTICE Date: May 2, 2012 TO: Camden Gould 149 Veazie Street, Old Town, ME 04468 YOU ARE IN DEFAULT BECAUSE YOU HAVEIFAILED IN TO ENTER A WRITTEN WITH THE APPEARANCE PERSONALLY OR BY ATTORNEY A COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS T I DSE TFOR THIS AGAINSTO ICE A UNLESS YOU ACT WITHIN TEN (10) DAYS FROM A HEARING AND YOU MAY JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER SET ONCE. I BEYOU LOW OT O S FORTH . HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE OFFICE CAN PROVIDE YOU WITH INFORMATION ER, ABOUT OFFICE MAY BE ABLE TO IF YOU CANNOT AFFORD TO HIRE A PROVIDE YOU WITH INFORMATION ABOUT E AGENCIES THAT NO MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE F FEE. This a debt collecting firm attempting to collect a debt for Dickinson College. Any information obtained will be used for that purpose. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 MARTSON LAW OFFICES By:_ °! - Christopher E. Rice, Esquire Christopher E. Rice, Esquire Attorney 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 DIUK1N5ON COLLEGE, Plaintiff V. CAMDEN GOULD, Defendant IN THE, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2011 - 7511 : CIVIL ACTION - LAW AFFIDAVIT AS TO MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he has authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and belief, the Defendant above named is not in the military service of the United States of America, that he has knowledge that the said Defendant is now living at: 149 Veazie Street, Old Town, ME 04468. Said Defendant's place of employment is unknown. L ) "-, - - )04 1 1 ? Christopher E. Rice, Esquire Sworn t and subscr'ed before me this_ day of , 2012. No ry ublic COMMOTH OF PENNSYLVANIA rial Seal :L7 ice, Notary Public CCumberland County Expires AuO. 18, 2015 M!M ANIA ASSOQATION OF NOTARIES Department of Defense Manpower Data Center Status Report Pursuant to Servielemlem ben Civil l et`Act Last Name: COULD First Name: CAMDEN Active Duty Status As Of: Jul-02-2012 Results as of : Jul-02-2012 07:38:54 SCRA 2.2.1 Active Duty Start Date Active Duty End Date Status Service Component On Active Duty On Active Duty Status Date NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date JE?Order Notcation End Date Status Service Component NA NA No -- - NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine: Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 14 Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Christopher E. Rice, Esquire Attorney 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. 2011 - 7511 CAMDEN GOULD, CIVIL ACTION - LAW Defendant : COMMONWEALTH OF PENNSYLVANIA ) : SS COUNTY OF CUMBERLAND Christopher E. Rice, Esquire, being duly swornaccording to law, deposes and says that he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, attorneys for the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, a notice of intention to enter default judgment against the Defendant was given to him by mail on May 2, 2012. Christopher E. Rice, Esquire Sworn to and subsc ibed before me this day of 12012. ate., No a ublic ?MONWEAL of PENNSYLVANIA d-1 ? Public Mary M. Price, Carusle Born, Cumberland County Expm Aug. 18, 2015 My Comm ION of NcrrnRtEs MEMBER, PENNSYI CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Pra.ecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Camden Gould 149 Veazie Street Old Town, E 04468 MARTSON LAW OFFICES By M Price Ten asst High Street Carlisle, PA 17013 (717) 243-3341 Dated: This is a debt collecting firm attempting to collect a debt for Dickinson College. Any information obtained will be used for that purpose