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HomeMy WebLinkAbout12-0648FARLES\Clients,7619 Dickinson College\7619.Collections\7619.C.Current\365 Ferrer\7619C.365.com.pl 5 Christopher E. Rice, Esquire r ± ' f r 11 Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER f? F E" -2 Pi `f MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 PEW!SyLV,;*d, r, (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, : IN THE COURT OF COMMON PLEAS OF Plaintiff V. SEBASTIAN A. FERRER, Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. 2012 - g 1 (V, : CIVIL ACTION - LAW 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 ifyou 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 CID C U. - a 1c13.7 s,?l °° t? CL# so?? (24-a`? b s7? F.\FILES\Clients\7619 Dickinson College\7619.Collections\7619.C.Current\365 Ferrer\7619C.365.com.pl 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. 2012 - SEBASTIAN A. FERRER, 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 a business address of Post Office Box 1773, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant, Sebastian A. Ferrer, is an adult individual residing at 5403 Stratford Road, Los Angeles, CA 90042-1821. 3. On or about August 30, 2005, Defendant entered into a Promissory Note ("Note") with Plaintiff for the financing of $6,570.00, plus interest for educational services and benefits at Plaintiff's 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 $6,570.00. 7. The Note grants Plaintiff reasonable collection and attorneys' fees which Plaintiff has calculated to be $1,500. 8. As of August 4, 2011, the principal and interest due and payable by Defendant to Plaintiff was $7,245,10, 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 9 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 $7,245.10, plus interest accruing at 5% per annum, collection and attorneys' fees in the amount of $1,500, 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 $7,245.10, plus interest accruing at 5% per annum, collection and attorneys' fees in the amount of $1,500, and costs of suit. MARTSON LAW OFFICES By: 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" FOAL PERKTNS LOAN MASTER PROMISSORY NOTE Ferrer, Sebastian A. 9 Barkdoll Lane Smithsburg, MD 21783 -- _ 6ollege 773 17013-2896 7. Annual Inter est Rate 5% [Any bracketed clause or paragraph may be included at option of institution] 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 wry disbursements made under this Note shall be interpreted in accordance with Part E ofTide IV 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 l 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 $30 if I have outstanding Federal Perkins Loans made before October 1, 1992 that included the $30 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 l do not make a scheduled payment when due or if l 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, may be 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 l meet the eligibility requirements for a cancellation of my loan, the institution may cancel up to 100 percent ofthe 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. 1 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 my 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 l 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 f 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 1 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.,?:P' Borrower's Signature Date ti ,r 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 documem 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 Sa ly Heck ndorn, Bursar F\FILESVClients\7619 Dickinson CollegeV7619. Col I ectionsV7619.C.CurrentA365 FerrerA7619C.365.com. pl F.\FILES\Clients\7619 Dickinson Coll ege\7619. Collections\7619.C.Current\365 Ferrer\7619C.365.pra.reinstate.pl/drg 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, Plaintiff V. SEBASTIAN FERRER, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2012-648 CIVIL ACTION - LAW PRAECIPE Please reinstate the Complaint in the above-referenced matter. MARTSON LAW OFFICES By. Date: J c -? 3 rn =M =;v C C:D c) r.) N 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. ?1?•?1 _+ il. ?spd fN?j 7,1o a +r I-11 1 > (']I ems. 1') [)1l-jsUn Col 1 ue17011) Col l ections17619(' Current?i6S FerrerA7019( 1(,5 asdre Christopher E. Rice, Esquire LD. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Fen East High Street Carlisle, PA 17013 CUMBERL ki:`0 COUN (717) 243-3341 PENNSYl..VANIA Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2012-648 SEBASTIAN FERRER, CIVIL, ACTION - LAW Defendant AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND SS. I hereby certify that a copy of the Complaint in the above captioned matter was mailed to Sebastian Ferrer, 19739 Bennie Drive, Hagerstown, MI) 21742-4254, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed by Sebastian Ferrer and dated May 12, 2012, with attached receipt of costs in the amount of $5.95. MARTSON LAW OFFICES Christopher E. Rice, Esquire Attorney I.D. No. 90916 Ten East High Street Carlisle. PA 17013 (717) 243-3341 Sworn to and subscribed before me this,? day of May, 2012. Notar uhlic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Mary M. Price, Notary Public Carlisle 8oro, Cumberland County My Commission Expires Aug. 18, 2015 mewsp, PENNswvAN1A ASSOCIATION OF NOrARIES This is a debt collecting firm attempting to collect a debt for Dickinson College. Any information obtained will be used for that purpose. ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverses so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ? r ? r A• Signatu ? Asst Addressee B. Received tfy ( Printed ame) C. Date of Delivery 1'a(I r, D. Is delivery address different from item 17 ? Yes If YES, enter delivery address below: fEA No 3. Service Type ` r h 0 r. C3 Certified Mail ? Express mail ? Registered ? Return Receipt for Merchandise ? insured mail ? C.O.D. 4. Restricted Delivery? oft Fee) 611,1es 2. Article Number 7010 1,060 0001 1,047 9425 (Ir8nsfer fiorrr service label) PS Form 3811, February 2004 Domestic Return Receipt LI (Domestic No Insurance Coverage Provided) p- For delivery Information visi t our website at www.usps.comu F r? .-. .. -41 Certlt Ved Fe4 Return Receipt Fee l 4est a k {FnonrsementRe;quired. `lestricted Delivary Fee W 0 iFndcvsement R(quirodl O 1?)tal Pcstaga F, Fees C3 Senr Ton - g O Street Ap4?N<e , I „111) P ' N ,. oi c. 'r1u aiat?. Zip+.# 3800 102595-02-M-1540 Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIANIS OTTO GILROY & FALLER MARTSON LAW OFFICES 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, PENNSYLVANII V. NO. 2012-648 SEBASTIAN FERRER, CIVIL ACTION - LAW Defendant TO: SEBASTIAN FERRER, DEFENDANT NOTICE OF ENTRY OF DEFAULT JUDGMENT 4 You are hereby notified that on the day of July, 2012, the following Judgment Was entered against you in the above-captioned action: judgment in the amount of $7,245.10, plus interest accruing at 5% per annum, collection and attorneys' fees in the amount of $1,500.00, and costs of suit. Date: 7 °L Prothonotary I hereby certify that the name and address of the proper person to receive this notice unkier Pa. R. Civ. P. 236 is: Sebastian Ferrer 19739 Bennie Drive Hagerstown, MD 21742-4254 F \FILES\Clien1s\7619 Dickinson College\7619.Coll ections\7619C.Current\7619C.365 Ferrer\7619C365.pra.defaulddrg Christopher E. Rice, Esquire Fit (- U i, _. 4 I.D. No. 90916 h*Y Y'i`J MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 2012 JUL 12 PM 2' 5 l Ten East High Street I Carlisle, PA 17013 PENNSYLVANIA (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff V. SEBASTIAN FERRER, Defendant TO THE PROTHONOTARY: Enter default judgment in the! above-captioned action in favor of Plaintiff and Defendant in the of amount of $7,245.10, plus interest accruing at 5% per annum, collection attorneys' fees in the amount of $1,500.00, and costs of suit as prayed for in the Complaint, 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 Defendant at the address indicated thereon, on June 8, 2012, which date was subsequent to the default occurred and at least ten (10) clays prior to the date of the Praecipe. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAI NO. 2012-648 : CIVIL ACTION - LAW PRAECIPE MARTSON LAW OFFICES Dated: Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff j-%b ?v ip oCw' 7 A/?? rc E ~?? F •'.FILES\C1ients\7619 Dickinson College\7619.Collections\7619C.CorrentN365 Ferrer\7619C. 365.10daynotice/drg 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, PENNSYLVAI V. : NO. 2012-648 SEBASTIAN FERRER, CIVIL ACTION - LAW Defendant IMPORTANT NOTICE TO: Sebastian Ferrer Date: June 8, 2012 19739 Bennie Drive Hagerstown, MD 21742-4254 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITTEN WITH HE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTIC , A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU ?AY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO OT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. HIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABL TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LE?IAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO 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 1'elephone:(717) 249-3166 By: MARTSON LAW OFFICES 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 DICKINSON COLLEGE, Plaintiff V. SEBASTIAN FERRER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2012-648 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 has authority to make this affidavit on behalf of his client, and to the best of his kno,n information and belief, the Defendant above named is not in the military service of the United of America, that he has knowledge that the said Defendant is now living at: 19739 Bennie Hagerstown, MD 21742-4254. Said Defendant's place of employment is unknown. Christopher E. Rice, Esquire Sworn to and subscribed before me this 10,A6 day of , 2012. t- Nothrvf)ublic I CpMMONWFJILTH OF PENNSYLVANIA Notarial Seal may M. Price, Notary Public CarNe swo, Cumberland County 015 CwInw ion bores Aug y??, TION OF NOTARIES he s Department of Defense Manpower Data Center Status Report want to Servicemembers Civil Relief Act Last Name: FERRER First Name: SEBASTIAN Active Duty Status As Of: Jul-0972012 Results as of : Jul-09-2012 09:16:51 SCRA 2.2.1 Active Duty Start Date Active Duty End Date Status Service Component On Active Duty On Active Duty Status Date - No NA j NA 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 Order Notification End Date Status Service Component NA NA No _ NA i 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, NOAH, 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. i I ?' 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, PENNSYLVAN] V. NO. 2012-648 SEBASTIAN FERRER, CIVIL ACTION - LAW Defendant COMMONWEALTH OF PENNSYLVANIA 1 : SS COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that1he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, attorn?ys 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 "Tas given to him by mail on June 8, 2012. 5- 2 Christopher E. Rice, Esquire Sworn to and subscribed before me this day of , 2012. -JUA4A4 , ) LA, QACX.' No ary ublic COW40NWI-ALTH OF PENNSYLVANIA ENotarial Seal Mary M. price, Notary Public arlisle Boro, Cumberland County CoNpnitsion Expires Aug. 18, 2015 MASSOOATION OF NOTARIES 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 Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed) as follows: Sebastian Ferrer 19739 Bennie Drive Hagerstown, MD 21742-4254 MARTSON LAW OFFICES By M . Price Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: 1 This is a debt collecting firm attempting to collect a debt for Dickinson College. ?ny information obtained will be used for that purpose