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Home My WebLink About12-0812F FILES I I -1s 7'.I I Dickinson Co11egeA7619. Col l eeti on s\7619. C. Curr_nP.402 Robinson 7619C 402.com Christopher E. Rice, Esquire Attorney I. D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER .- MARTSON LAW OFFICES Ten East 1ligh Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff _ DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. RICHARD T. ROBINSON, Defendant NO. 2012 - 810 C lV? CIVIL ACTION - LAW NOTTCV 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 ffirther 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 aN S k a (C) CC ?? c?-768( S €\FILES\Clients\7619 Dickinson College\7619.Collections\7619.C.Current\402 Robinson\7619C402.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. 2012 - RICHARD T. ROBINSON, 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, Richard T. Robinson, is an adult individual residing at 2430 7`h Avenue, New York, New York 10030. 3. On or about December 3, 2004, Defendant entered into a Promissory Note - Federal Perkins Loan Program ("Note") with Plaintiff for the financing of $6,125.00 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 are 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 principal for the Note is $6,125.00. 7. The Note grants Plaintiff reasonable collection and attorneys' fees which Plaintiffhas calculated to be $1,500.00. 8. As of. 'January 10, 2012, the principal and interest due and payable by Defendant to Plaintiff was $6,997.87, 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 $6,997.87, plus interest accruing at 5% per annum, collection and attorneys' fees in the amount of $1,500.00, and costs of suit. COUNT II IN QUANTUM MER UIT 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 $6,997.87, plus interest accruing at 5% per annum, collection and attorneys' fees in the amount of $1,500.00, 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" FEDERAL PERKINS LOAN MASTER PROMISSORY NOTE a -7q Dj Lo 1. Name (last, first, middle initial) and 2. Social Security Number Permanent Address (street, city, state, zip code) F I 3. Date of Birth (mm/dd/yyyy) T 4. Home Area CodvT'elephone Number S. Driver's License Number (List state abbreviation first) a` 3 6 -1 Ave- V w / 0 r[`, N( 1()60 6. Dickinson College 7. Annual Interest Rate P.O. Box 1773 5% Carlisle, PA 17013-2896 .L-? (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 any disbursements made under this Note shall be interpreted in accordance with Part E ofTitle 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 s. 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 l 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 S5. [I will make a minimum monthly repayment of $40 (or $30 if l 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 I meet the eligibility requirements for a cancellation of my loan, the institution may canal 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 l 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 I 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 LOAN $. MAk" Borrower's Signature Date Terms and Conditions (cont.) DISCLOSURE OF LOAN TERMS - I understand that under this Note, the principal amourit that I owe, and am required to repay, will be the sum of all disbursements issued unless I reduce or cancel any disbursements. The School will determine whether to make any loan under this Note after my loan eligibilityis determined. At or before the time of first disbursement for each loan, a disclosure statement will be provided to me identifying the amount of the loan and any additional terms of the loan. I may decline a loan or request a lower amount by contacting the School. Any disclosure statement I receive in connection with any loan under this Note is hereby incorporated into this Note. LOAN REHABILITATION - If I default on my Federal Perkins Loan, and that loan has not been reduced to a judgment as a result of litigation against me, I may rehabilitate my defaulted loan by requesting the rehabilitation and by making a voluntary, on-time, monthly payment, as determined by the School, each month for twelve consecutive months. If I successfully rehabilitate my defaulted Federal Perkins Loan, I will again be subject to the terms and conditions and qualify for any remaining benefits and privileges of this Note and the default will be removed from my credit history. I understand that I may rehabilitate a defaulted Federal Perkins Loan only once. After my loan is rehabilitated, collection costs on the loan may not exceed 24 percent of the unpaid principal and accrued interest as of the date following the application of the twelfth consecutive payment. If I default on my rehabilitated loan, the cap on collection costs is removed. ASSIGNMENT - A loan made under this Note may be assigned by the School only to the United States, as represented by the United States . Department of Education Upon assignment, the provisions of this Note that relate to the School will, where appropriate, relate to the Department HARDSHIP REPAYMENT OPTIONS - Upon my written request, the School may extend my repayment period (1) for up to an additional 10 years if I qualify as a low-income individual during the repayment period; or (2) for the period necessary beyond my 10 year repayment period if, in the School's opinion, prolonged illness or unemployment prevent me from making the scheduled repayments. Interest will continue to accrue during any extension of a repayment period. If I am required by the School to make a minimum monthly payment on my loan, the School may also permit me to pay less than the minimum monthly payment amount for a period of not more than one year at a time if I experience a period of prolonged illness or unemployment. However, such action may not extend the repayment period beyond 10 years. GRACE PERIODS - Unless I am a Less-Than-Half-Time Borrower, I will receive an initial nine-month grace period before the first payment of my Federal Perkins Loan must be made. After the close of an authorized deferment period, I will receive a post-deferment grace period of6 months before my payments resume. Interest does not accrue during the initial grace period or during the post-deferment grace period. The nine-month initial grace period for Federal Perkins Loans does not include any period up to three years during which I am called or ordered to active duty for more than 30 days from a reserve component of the Armed Forces of the United States, including the period necessary for me to resume enrollment at the next available enrollment period. I must notify the school that made my loan of the beginning and ending dates of my service, and the date I resume enrollment. If l am in my initial grace period when called or ordered to active duty, I am entitled to a new nine-month initial grace period upon completion of the excluded period. If I am a Less-Than-Half-Time Borrower with outstanding Federal Perkins Loans, my repayment period begins when the next scheduled installment of my outstanding loan is due. If I am a Less-Than-Half-Time Borrower with no other outstanding Federal Perkins Loans, my repayment begins the earlier of. 9 months from the date my loan was made, or 9 months from the date I became a less-than-half-time student, even if I received the loan after I became a less-than-half-time student PREPAYMENT - I may prepay all or any part of my unpaid loan balance, plus any accrued interest, at any time without penalty. Amounts I repay in the academic year in which the loan was made and before the initial grace period has ended ? vill be used to reduce the amount of the loan and will not be considered a prepayment If Lrepay amounts during the academic year in which the loan was made and the initial grace period has ended, only those amounts in excess of the amount due for any repayment period shall be considered a prepayment If, in an academic year other than the academic year in which the loan was made, I repay more than the amount due for an installment; the excess funds will be used to repay principal unless I designate it as an advance payment of the next regular installment MINIMUM MONTHLY PAYMENT - If required by the School, I will make a minimum monthly payment in the amount of $40 (or $30 if I have outstanding Federal Perkins Loans trade before October 1, 1992 that included the $30 minimum payment option or outstanding National Direct Student Loans) or its bimonthly or quarterly equivalent If the total monthly payment amount on this loan and any outstanding Federal Perkins Loans I may have is less than the minimum monthly payment amount established by the School, the School may still require a minimum monthly payment amount. A minimum monthly payment amount will combine my obligation on this and all my outstanding Federal Perkins Loans, unless I have received loans with different grace periods and deferments. At my request and if I am eligible, the school may combine this minimum monthly payment amount with all my outstanding Federal Perkins Loans including those made at other schools. Under these circumstances the portions of the minimum monthly payment that will be applied to this loan will be the difference between the minimum monthly payment amount and the total amounts owed on a monthly basis on my other Federal Perkins Loans. If each school holding my outstanding Federal Perkins Loans exercises the minimum monthly payment amount option, the minimum monthly payment amount will be divided among the Schools in proportion to the loan amount advanced by each school if I request this treatment from each School. FORBEARANCE - Upon making a properly documented written request to the School, I am entitled to forbearance of principal and interest or principal only, renewable at intervals of up to 12 months for periods that collectively do not exceed three years, under the following conditions: If my monthly Title IV loan debt burden equals or exceeds 20 percent of my total monthly gross income; if the Department authorizes a period of forbearance due to a national military mobilization or other national emergency; or if the School determines that I qualify due to poor health or for other reasons, including service in AmeriCorps. Interest accrues during any period of forbearance. DEFERMENTS - To apply for a deferment, I must request the deferment from the school. My request does not have to be in writing, but the School may require that I submit supporting documentation to prove my eligibility for a deferment I may defer making scheduled installment payments and will not be liable for any interest that might otherwise accrue (1) during any period that I am enrolled and attending as a regular student in at least a half- time course of study at an eligible School (If the School obtains student enrollment information showing that I qualify for this deferment, the School may grant the deferment without my request providing the School notifies me and gives me the option to cancel the deferment); (2) during any period that I am enrolled and attending as a regular student in a graduate fellowship program approved by the Department; engaged in graduate'or post-graduate fellowship-supported study outside the US; enrolled and attending a rehabilitation training program for disabled individuals approved by the Department; or engaged in public service that qualifies me to have part or all of my loan canceled; (3) for a period not to exceed three years during which I am seeking but unable to find full-time employment; and (4) for a period not to exceed three years, for up to one year at a time, during which 1 am experiencing an economic hardship as determined by the School. I may qualify for an economic hardship deferment for my Federal Perkins Loan if I provide my school with documentation showing that I have been granted such a deferment under the William D. Ford Federal Direct Loan or Federal Family Education Loan program for the period of time for which I am requesting an economic hardship deferment for my Federal Perkins Loan. If I am serving as, a volunteer in the Peace Corps, I am eligible for an economic hardship deferment for my full term of service. An economic hardship deferment based on service as a Peace Corps volunteer may not exceed the lesser ofthree years or my remaining period of economic hardship eligibility. I may continue to defer making scheduled installment payments and will not be liable for any interest that might otherwise accrue for a six-month period immediately following the expiration of any deferment period described in this section. I am not eligible for a deferment while serving in a medical internship or residency program. D..,-.. 1 ..C A Terms and Conditions (cont.) CANCELLATIONS - Upon making a properly documented written request to the School, I am entitled to have up to 100 percent of the original principal loan amount of this loan canceled if T perform qualifying service in the areas listed in paragraphs A, B, C, D, and E below. Qualifying service must be performed after the enrollment period'covered by the loan. A. Teaching • a fiill-time teacher in a public or other nonprofit elementary or secondary school, designated by the Department in accordance with the provisions of section 465(ax2) of the Act as a school with a high concentration of students from low-income families. An official Directory of designated low-income schools is published annually by the Department. • a full-time special education teacher in a public or nonprofit elementary or secondary school system; or • a full-time teacher, in a public or other nonprofit elementary or secondary school system, who teaches mathematics, science, foreign languages, bilingual education, or any other field of expertise that is determined by the State Department of Education to have a shortage o17qualified teachers in that State. B. Early Intervention Services • a full-time qualified professional provider of early intervention services in a public or other nonprofit program under public supervision by a lead agency as authorized by section 632(5) of the Individuals with Disabilities Education AcL Early intervention services are provided to infants and toddlers with disabilities. C. Law Enforcement or Corrections Officer • a full-time law enforcement officer for an eligible local, State, or Federal law enforcement agency; or • a full-time corrections officer for an eligible local, State, or Federal corrections agency. D. Nurse or Medical Technician • a full-time nurse providing health care services; or • a full-time medical technician providing health care services. E. Child or Family Service Agency • a full-time employee of an eligible public or private non-profit child or family service agency who is directly providing or supervising the provision of services to high-risk children who are from low-income communities and the families of such children. Cancellation Rates - For each completed year of service under paragraphs A, B, C, D, and E a portion of this loan will be canceled at the following rates: • 15 percent of the original principal loan amount for each of the first and second years; • 20 percent of the original principal loan amount for each of the third year and fourth years; and • 30 percent of the original principal loan amount for the fifth year. F. Head Start Cancellation - Upon making a properly documented written request to the school, I am entitled to have up to 100 percent of the original principal loan amount canceled for qualifying service performed after the enrollment period covered by the loan as: - a full-time staff member in the educational component of a Head Start program which is operated for a period comparable to a full School year and which pays a salary comparable to an employee ofa local educational agency. Cancellation Rate - For each completed year of service under the Head Start Cancellation provision, this loan will be canceled at the rate of 15 percent of the original principal loan amount G. Military Cancellation - Upon making a properly documented written request to the School, I am entitled to have up to 50 percent ofthe principal amount of this loan canceled for qualifying service performed after the enrollment period covered by the loan as: • a member of the Armed Forces of the United States in an area ofhostilides that qualifies for special pay under section 310 of Title 37 ofthe United States Code. Cancellation Rate - For each completed year of service under the Military Cancellation provision, this loan will be canceled at the rate of 12 percent of the original principal loan amount. H. Volunteer Service Cancellation - Upon making a properly documented written request to the School, I am entitled to have up to 70 percent of the original principal loan amount of this loan canceled for qualifying service performed after the enrollment period covered by the loan as: • a volunteer under the Peace Corps Act; • a volunteer under the Domestic Volunteer Service Act of 1973 (ACTION programs). Cancellation Rate - For each completed year of service under the Volunteer Service Cancellation provision, a portion of this loan will be canceled at the following rates: • 15 percent of the original principal loan amount for each of the first and second 12-month periods of service; and • 20 percent of the original principal loan amount for each of the third and fourth 12-month periods of service. DISCHARGES - My obligation to repay this loan may be partially or totally discharged for the reasons specified in paragraphs A, B, C, and D below. A. Death - In the event of my death, the School will discharge the total amount owed on this loan. B. Total and Permanent Disability - If I become totally and permanently disabled after I receive this loan, the School will discharge the total amount owed on this loan. If my disability discharge claim is approved by the School, this loan will be assigned to the United States Department of Education, which will discharge the total amount owed on this loan if it determines that I am eligible for a total and permanent disability discharge. C. School Closure - Under certain conditions, my total liability will be discharged, including refunding any amounts I have already paid on the loan, if I was unable to complete the program in which I was enrolled because my School closed. D. Bankruptcy - Under certain conditions, my loan may be discharged in bankruptcy. In order to discharge a loan in bankruptcy, I must prove undue hardship in an adversary proceeding before the bankruptcy court. Disclosure of Information STUDENT LOAN OMBUDSMAN - If I dispute the terms of my Federal Perkins Loan in writing to my School, and my School and I are unable to resolve the dispute, I may seek the assistance of the Department of Education's Student Loan Ombudsman. The Student Loan Ombudsman will review and attempt to informally resolve the dispute. disbursement is made.duri years after the date of my Sehopl ieceiyes this Note. Any amendment to the disbursed on or after the e •e on this Note, or the date'the icros the terms of any loans rr this Note D...... 'r ..FA 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, i 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: --ti.t,(?.t. Sally Hecken rn, Bursar F TILES\Clients\7c 19 Dickinson College\7619. Collections\7619.C.Cu ent\402 Robinson\7619C.402. corn F.\FILES`Clients\7619 Dickinson Coll ege\7619.Collections\7619.C. Current\402 Robinson\7619C 402_pra. reinstate 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. RICHARD T. ROBINSON, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2012 - 812 CIVIL ACTION - LAW PRAECIPE Please reinstate the Complaint in the above-referenced matter. MARTSON LAW OFFICES By: Date: rn? rn N r- hz_ r, CF » x. i 3u l'V Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff '.n'- -V THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR DICKINSON COLLEGE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. -p(.15 Pa A77- cr 6tsa?q P-* a-7 a /os F.\FILES\Cbents\7619 Dickinson College\7619.Collections\7619C. Current\402 Robinson\7619C.402.pra. reinstate Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLEN Y l M ARTSON LAW OFFICES 8 AM 53 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff V. RICHARD T. ROBINSON, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2012 - 812 CIVIL ACTION - LAW PRAECIPE Please reinstate the Complaint in the above-referenced matter. MARTSON LAW OFFICES By: Date: .5// L llpl $", /Z_ 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. //. 7 jr I " 1 ?0# S?CIG sy? 3 ,?_94 F.'TILES\Clients,7619 Dickinson College\7619.Collections\7619C.Cucent\7619C.402 Robinson\7619C. 402.pra.reinstate Christopher E. Rice Esquire , Attorney I.D. No. 90916 rn` r : n--`? n, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street " -? ? Carlisle, PA 17013 =CZ) a- (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2012 - 812 RICHARD T. ROBINSON, Defendant To the Prothonotary: CIVIL ACTION - LAW PRAECIPE Please reinstate the Complaint in the above-referenced matter. 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. 411.,7S PA A-nV &c?5'l?8 E# .777(t&8 Dicldneon College\7619.Colleaions\7619C.Currcm\76190.402 Robinson17619C.402.aa hristopher E. Rice, Esquire i` ~ ~-~ ~- , ' a ~~`~ ~~p~ ~ ~ C~: ~ ~~ .. ~l~~~t~~~ ttorney I.D. No. 90916 °' fARTSON DEARDORFF WILLIAMS OTTO GILROY 8~ FALLER 2~ 12 ~~~ ! 5 AM I 1 ~ 39 [ARTSON LAW OFFICES ~n East High Street CUM~ERLA PE`~tNS~ ~ COt1N~Y VAN{A arlisle, PA 17013 `17) 243-3341 ttorneys for Plaintiff ICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVAN v. NO. 2012 - 812 ICHARD T. ROBINSON, CIVIL ACTION -LAW Defendant the Prothonotary: Attached is the Affidavit of Service indicating Defendant was served with the dust 3, 2012, at a cost of $35.00 for service. MARTSON LAW OFFICES By ~ ,~ s ~ Christopher E. Rice, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 s~/~ ~/rte Attorneys for Plaintiff THIS )~S A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEIST DICKINSON COLLEGE. ANY INFORMATIt~N OBTAINED WILL' RE USED l THAT PURPOSE. • Attorney or Party without Attorney: MARTSON LAW OFFICES 10 EAST HIGH STREET CARLISLE, PA 17013 Case No: 20128 2 Doc. No: 31212 7301177 COUNTY OF LOS ANGELES SHERIFF'S DEPARTMENT STATE OF CALIFORNIA Court: COMMON County: CUMBERLAND State: PENNSYLVANI DICKINSON COLLEGE V5 ROBINSON, RICHARD T. AFFIDAVIT OF SERVICE I certif that EILLEN A. BORJA being fi st duly sworn, deposes and says: That he is a regularly appo qualifie deputy Sheriff of the said County of Los Angeles, in the Sta Californ'a, and over the age of twenty-one years, not a party to the a or relat d to either party, nor an attorney for a party, nor in any wa interest d in the within named action, and authorized to serve civil p NOTICE CIVIL ACTION-LAW, COMPLAINT CIVIL ACTION-LAW, EXHIBIT A ted, of ion cess On O8/0 /12 at 11:50 AM and that he served the same on the defendant nd/or responde t named below, on the date indicated, by delivering to and le ing with sai defendant and/or respondent in the County of Los Angeles, St a of Californ'a, personally, a true and correct copy thereof, with all noti s and endorsem nts thereon, in the manner and the place and time shown below: 1. Name:~ROBINSON, RICHARD T. 2. Person served aid title: ~ROBINSON, RICHARD T. 3. Person with whom left and title or relationship to person served: 4. Date nd time of delivery 11:50 AM 08/03/12 5. Maili~g date, type of mail and place of mailing 6. Addre s, city and state: 1305 INGRAHAM ST APT 212 LOS ANGELES, CA 90017 ( ] Home ( X ) Business ,7. Manned of Service: ( X ) (Personal~Service) by personally delivering true copies to the person, firm or corporation served. ( ) with endorsement of name, place of service and official title on copy served. ~( ) With required notice written or printed on the face of the process served. ',( X ) Affiant showed the original process to the defendant at the time of such service. ( X ) ( X ) 8. FEE F Deputy SHERIFF 110 N. LOS ANG (213) 97 (Identification) was made as to the identify of the person so served was as follows: ( ) Photograph of the defendant attached to the process and furnished by the plaintiff herein and made a part of thi affidavit. ( X ) Sex: M Race: BLK Hair: BLK Age: 25 Weight: Height: Ft. Ins. Drivers Lic: Other: (Military Service) That at the time of service of process, defendant stated he/she is not in the military service. R SERVICE:$ 35.00 NOTARY: ILLEN A. BORJA S OFFICE RAND AVE RM 525 LES, CA 90012 -6613 State of~California County o Los Angeles On COUNTY CLERK: LEROY D. By. TOTA .$ 35.00 BR , SHERIFF f..~ -- --- ------p--Y- ------ De ut heriff i __________ before (Name & Title o persona ly appeared ------------------------------------------------- - who pro ed to me on the basis of satisfactory evidence to be the pers n whose n me(s) is/are subscribed to the within instrument and acknowle g to me t at he/she/they executed the same in his/her/their authorized capacit (ies), and that by his/her/their signature(s) on the instrume t the per on(s), or the entity upon behalf of which the person(s) acted, execute the instrument. I certi y under PENALTY OF PERJURY under the laws of the State of Califor is that the foregoing paragraph is true and correct. WITNE~S my hand and official seal. Officer) (s) ed Si natur g ----------------------------------------------------- ( eal)