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Home My WebLink About12-1714F.\FILES\Clients\7619 Dickinson College\7619.Collections\7619.C.Cutrent\382 Guzy\7619C.382.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 2012 MAR 19 AM I0-- G ! CUMBERLAND l OUN 't PENNSYLVANIA, DICKINSON COLLEGE, Plaintiff V. RACHELLE GUZY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2012 - I ?? 1 : 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 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 • ? ??3`7d F TILEWlients\7619 Dickinson College\7619.Collections\7619.CCurrent\382 Guzy\7619C.382.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 - RACHELLE GUZY, 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, Rachelle Guzy, is an adult individual residing at 1221 Drexel Avenue, Drexel Hill, Delaware County, Pennsylvania 19026. 3. On or about September 9, 2006, Defendant entered into a Promissory Note ("Note") with Plaintiff for the financing of $2,800.00, 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 $2,800.00. 7. The Note grants Plaintiff reasonable collection and attorneys' fees which Plaintiff has calculated to be $750.00 r 8. As of August 11, 2011, the principal and interest due and payable by Defendant to Plaintiff was $2,633.20, 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 $2,633.20, plus interest accruing at 5% per annum, collection and attorneys' fees in the amount of $750.00, 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 $2,633.20, plus interest accruing at 5% per annum, collection and attorneys' fees in the amount of $750.00, and costs of suit. MARTSON LAW OFFICES By; Cam?. A 57 /Z- Date: J// 91.2i 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. EXHIBIT "A" FEDERAL PERW NS LOAN MASTER PROMISSORY NOTE Name (last, first, griddle initial) and Permanent Address (street; city, state, zip code) 'Fac,h 4I.e. G u zy gal D ue-l Ave. r),pX.P.i ( h-j ( P,4 )102(0 6. School Name & Address (street, city, state, DICKINSON COLLEGE PO BOX 1773 CARLISLE, PA. 17013-2896 2. Social Secuifty Number 3. Date of Birth (mmlddlyyyy) 4. Harms Area Coda Telephone Number 5. Driver's Lic:emse Number (List state abbreviation first) 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) AMJCABLE LAW - The tarns of tlm Feddrd Palo Loam Maw Promissory Note caDad 6se Notefiarai a:gr dishutsemenumde under thts.Note shall be interpreted in accordance wide Part E af'IiAe IV of the Higher Education Act of 1965, asamended (herd called the Act}, as well as Federal regulations issued underthe Act All sums advanced under this Note are suhjectto due Act and Federal regulations issued under the Act REPAYMENT - I am obligated to repay the pcbucipd acrd the interest that accmes an my loan(s) to the above mned institution (hosing abed the School) over & period beginning 9 months (or woner if I am a Las-Thsn-Ha1f-TimcBoaawer) alter the data I care to be at least a bolf4me student atan institutionafldgher educadm or a comparable School outside the MAW Soft approved by the Umted States Department of Edaaton (had new called to Daprrlmatu) and ending 10 yeas lobe, unless I request in writing that ny rapsyrne nt period begin soarer. l understand that the Sobool will repot rte amount of my itatsllnettpaayrments, along with the smont of this loon to at least ate national credit baaau. Interact oat this loan shall saexue flrom the beginning tithe tepsymentperiod. My rrsptiYrnentyeriod maybe shorts turn 10 years if I on bymySduoolbmalosrniainmm?tm8+lythaytatmb Mynpayenmtpeafadmaybeexteodsddmingpeniodscfaiafiatrarnt}?S1uip.afbabeasrceandIaaymaice grodwted met ftmts m rccadom wtth a rlw& is appoved bythe Department I will amiss my payrneab in equal mom, bi rronbly, or quattxy tnstallmerrts as de ruined byte School The schoolmaymrmd my iattallment payment to the next bighwt rmhtiple of $5. ii will melon a michxunurhoaWly repayment of S40 (a S30 if I have outsam t Fedad Pwkins Ioamr made bof o October 1,1993 that bwbM tae S30 n*Anmpgrnm optics cr wa Nr kod Dhect Swdeat Lom) in accordance with the Mid Monthly Payment Section of the Terms and Conditions corbined as due reverse side rile documw ) LATE CHARGES - The School may impose late cl ages M donotmob a scheduled payment when due or if I Earl to subunit to the School on or befogs the due date of the payment, a properly documental request lbr goy of the tbrbeaance, del mwn or cancellation bmatlts as described below. No bite a* jw may wmW 20 pemueat grimy monthly, bimaattR a qty paYmft The Sdeool mqr add to late changes to principal the day after the oebodi payment was due or fixi de ttwh h the next scheduled paayment after 1 bove received notice of the ebsrA and welt notice is sentbadm t e nehrt hatslhnmtis due. FORBRARANCE, DZFI PJAEff, OR CANCE[.L.AIWK - I may apply for a fodxwonoe, deferment; err. ca venation an my dom. During an approved forbearance period, payments of principal and intaeat, arparirmcW only, maybe posomad arnn&md. hnteratc onftm to accrue wbile my tom is is fabadrom During an approved delbrmentpedod,Iommnquieedtondmadhe&ged ubhnudpayarabonvwlom lamamtliableforanyl tmta>ightcdaas3aelaccrutewhibmylamisia ddament VI meat the etiglbility 1- I 'm ss for a a on ofney lam do ikon tnaycancel up to 100 pasuent aaf tae oa ogpriatfpal Io m anent Information on eligibility and applic add tegmTemtahts ft fbebamances, deferments, and cancellations is provided on pages 2 and 3 of this Note. I am raponmble for submitting the appropriate request: on time, and I nay lose mybena5ts VIM to file my Taqued on time. DEFAULT - The School may, at its option, declare my Isar Lobe in Windt if (1) I Elul to mdm a scheduled psymeatwhen dueg (2) I iltil tu arbudt tbtht School. on ax before the dare data of s, scheduled payment, doawntent slim that I quality for a Rrbeamoe, ddunmt, or cw=Uxden; or (3) I W to comply widen the tam and conditions of this Note or written rapgymett agraenent The School nay *Wp a de&ubed lcm to the Depwhvnt ibr eaUec sea. I will bs fwHglbk fbr aapr flalher federal student financial assistance authorized undertbe Act until I make arangerrnentr that are satisBecoay to the School err the l) i I tmeutto repay my mom The School a tha Department shall disclose to credit bureau organizations t atIbrra dd9atited and all r dwralevmt loaninf s ation. I walk kw myriSU to ddwpwjnwo and mpg right do fbd mmoe if I default onnny loony The School or the De partmerit may acoderste rn y delulted loan. Acceleration mean ltd the 3a hood a the Depautnoat danands iraraediate payment of the entire unpaid balance of the loan, including principal, interesk late charge, and collection costs. I will lose my right to receive won benefb for service that is performed after the daft the School or the Deportment accelerated the loan. CHANGE OF STATUS - I vAll inform the School of any change in myzam% address, telephone number, Social Security Number, or aMvaes license nuzz*rw. PROMISE TO PAY: I promise to pay the School, a a sobsequmt holder o£ dwNotk all sums disbursed under tine tame of ft Note, Pita interest snd other fear wlrioh may become due as provided in this Note. I uaderse nd that multiple leaas may be made to mam isr this Notes I umdmstsad d*by wcepting my didxmm ats issued stany tints under this Note, I agree to n 7dythe Ioans. I W*rdsd that each loan is separately entircedble bated on atone and coat copy ofthis Nam I understand that I mayemcd or reduce the anoint of any low bynot accepting orbyreturaing all or &portion of any disbursement that is issued. IfI do notmelmanyptyment oat a y los a under this Note when it is" I promise to pay all ressonoble collection costs, indndmg attorney foss, court costs, aid. of erfees. I will not sign this Nota belbre radmg the entire Note, ever if l am fold that l am nctuaquird toread it I an eadded to an void copy of this Note. This loan has beta nude to me withart security or axiortememt. My signature certifies I have rod, understand, and agree to to term and oo ditions of this Note. I UNDERSTAND THAT I MAY/ R,,ECEEI?1VE /O?N.E?ORMORE LOANS UNDERTBIS MAST?ER PROMISSORY NOTE AND THAT IMUST REPAY SUCH LOANS ! l jte . /?17 .VM? ? ` /7 - -2- 2 - /? I ! (P Boaowkr's Signature v Q Date 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 Hecken rn, Bursar F41LES\Clients\7619 Dickinson College\7619.Collections\7619.C.Current\382 GuryV619C.382.com SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor t ?sui,t?cr? THE PPQiH0N0TA 2012 APR 20 AM 8: 45 CUMBERLAND COUNTY PENNSYLVANIA Dickinson College vs. Rachelle Guzy Case Number 2012-1714 SHERIFF'S RETURN OF SERVICE 03/20/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Rachelle Guzy, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Delaware County, Pennsylvania to serve the within Complaint and Notice according to law. 04/03/2012 Delaware County Return: And now, March 29, 2012 I, Joseph F. McGinn, Sheriff of Delaware County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Rachelle Guzy the defendant named in the within Complaint and Notice and that I am unable to find her in the County of Delaware and therefore return same NOT FOUND. Request for service at 1221 Drexel Avenue, Drexel Hill, Pennsylvania 19026 the Defendant was not found. Deputies were advised, Rachelle Guzy has moved. SHERIFF COST: $37.45 April 18, 2012 SO ANSWERS, RbNNS' R ANDERSON, SHERIFF Ronny R Anderson Sheriff Jody S Smith Chief Deputy Dickinson College vs. Rachelle Guzy It7il SHERIFFS OFFICE Or CUMBERLAND COUN Y . l4 I Richard W to Solicitor Case Number 2012-1714 SERVICE COVER SHEET 0 N ao Service Detig/s: „. o Category: Civil Action - Complaint & Notice X Manner: Deputize Expires: 04118/2012 w Notes: W N O Q1 r Q a - Serve To: = Name: Rachelle Guzy X Primary 1221 Drexel Avenue uJ Address: Drexel Hill, PA 19026 Q w Phone: Z R w Alternate Q Address: J w X Phone: LX o: Attorney / Originator: N N Name: Christopher E Rice Date: Deputy: Phone: 717-243-3341 Zone: Warrant: Service Attempfs': Date: Time: N Mileage: Deputy: Notes I Special Instructions: NSYLVAM SOS:? 2. la Mary Pubk wom to and sub ribed before s t>>cstm?ber 1; 2412 this 2- day of 2c? L w Now, March 20, 2012 I, Sheriff of Cumberland County, Pennsylvania do hereby de utize the Sheriff,of Delaware County to v execute service of the documents herewith and make return thereof according,to law. Return To: N }i Cumberland County Sheriffs Office One Courthouse Square Carlisle, PA 17013 onny R Anderson, Sheriff F.\FILES\Clients\7619 Dickinson College\7619.Coll ections\7619.C.Current\382 Gury\7619C.382.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 DICKINSON COLLEGE, Plaintiff V. RACHELLE GUZY, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2012 - 1714 CIVIL ACTION - LAW PRAECIPE Please reinstate the Complaint in the above-referenced matter MARTSON LAW OFFICES Cj - rw x r-a s•? i p =IC E5 rat ?.; C3 By: Ce "1 S IF Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: _5 /%/Pa'' Attorneys for Plaintiff _? // 76??,'f t 030-a5555- P- #a7u9s/i THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR DICKINSON COLLEGE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. F.\FILES\Client0b19 Dickinson Coll ege\7619.Collections\76190 Current\76190382 Guzy\76190382. pra Christopher E. Rice. Esquire 3 r flu ti I-q - Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER r -<> MARTSON LAW OFFICES = -`tl 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. RACHELLE GUZY, Defendant To the Prothonotary: NO. 2012 - 1714 CIVIL ACTION - LAW PRAECIPE Please reinstate the Complaint in the above-referenced matter. MARTSON LAW OFFICES By: (??v 4 5_1 `? 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. 411.15 PA A77-Y c-901's-78s ea7-7y&? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ' i3`? E` ' `? : s taw . Jody S Smith Chief Deputy AM € : 2. Richard W Stewart Solicitor ?rMBEi><?.,AtC)?1E r. Dickinson College vs. Case Number Rachelle Guzy 2012-1714 SHERIFF'S RETURN OF SERVICE 05/09/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Rachellle Guzy, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Delaware County, Pennsylvania to serve the within Complaint and Notice according to law. 06/07/2012 Delaware County Return: And now, June 7, 2012 I, Carolyn B. Welsh, Sheriff of Delaware County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Rachelle Guzy the defendant named in the within Complaint and Notice and that I am unable to find her in the County of Delaware and therefore return same NOT FOUND. Request for service at 1185 Dermond Road, Apartment A, Drexel Hill, Pennsylvania 19026 the Defendant was not found. SHERIFF COST $3745 June 28, 2012 SO ANSWERS, R?O? NNYY[R ANDERSON SHERIFF SHERIFF'S OFFICE OF CUMBERLAN IT? Ronny R Anderson;,;,,,, ,r? Sheriff Jody S Smith Richard W Stewart Chief Deputy Solicitor Dickinson College ?i vs.ase Number Rachelle Guzy 2D12-1714 SERVICE COVER SHEET 0 N o Service Details: o Category: Civil Action - Complaint & Notice ZonE: w Manner: Deputize Expires: 06/08'2012 Warrant: Notes: J _J 2 J W X W 0 Serve To: Final Service: Q Z Name: Rachelle Guzy Served: Personally Adult In Charge Posted g her w Primary 1185 Dermond Road, Apartment A Adult In F- Address: Drexel Hill, PA 19026 Charge: Z Ro z° aQ Phone: DOB. Relation: a U, W O Alternate Date: J Z WO Address: Time. a - o Z OZ Phone: Deputy: Mileage. a W Attorney l Originator. s„ t Name: Christopher E Rice Phone: 717-243-3341 00 Service Attempts: Date: Time: !? - 73 N Mileage: ?°, Deputy: O Notes / Special Instructions: r - y, W w Now, May 09, 2012 i, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of C"elaware County to v execute service of the documents herewith and make return thereof according to law. Q o! Return To: Cumberland County Sheriff's Office One Courthouse Square Carlisle, PA 17013 Ronny R Andersen Sheriff or t'-L [4 " p? SHERIFF' OF DELAWARE COUNTY MEDIA, PENNSYLVANIA, 19063 JOSEPH F. McGINN PHONE (610) 891-4296 FACSIMILE (610) 891-1765 Sheriff WILLIAM C. KELLY Chief Deputy Invoice Number: PO-248666 Attorney: Cumberland County Court Term & No.: OC12-1714 P12irtiff: Dickinson County Defendant: Rachelle Guzy Case Type: CIVIL -- Complaint Cornments: Drexel Hill--Curnberland--Fld 5-9-Breach Contr Special Instructions: Check No./Cash: 25557 Date Filed: May 1(?. 2012 1185 Dermond IRoad, Apt A Account Amount County Account $25.50 Mileage $9,10 Affidavits Account $5.00 Total $39.60 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson iT #~.~.~..t-~J1' i'~C;r_ Sheriff ~~~ 7E-f~ ;'i~T!~~~'~Ttrj` ~$~~ti~ ai +t:at~brr~~d Jody S Smith Chief Deputy ~ ~ rs .~ ~ ~~ ~~~ ~ ~ ~~ ~~ ~ ~ ~r: ~ r.; Richard W Stewart ~ "~ ' ~~ ~ ~ Solicitor c~FF~~E~`T~ES.,~~IrF ~t1A~f~E~l.APdt~ G41.~T ~` P~l~WSYLw~NIA Dickinson College Case Number vs. Rachelle Guzy 2012-1714 SHERIFF'S RETURN OF SERVICE 07/06/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent sear h and inquiry for the within named defendant, to wit: Rachelle Guzy, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Delaware County, Pennsylvania to serve the within Complaint and Notice according to law. 07!30/2012 Delaware County Return: And now, July 30, 2012 at 2010 hours I, Joseph F. McGinn, Sheriff of Delaware County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry f r Rachelle Guzy the defendant named in the within Complaint and Notice and that I am unable to find h r in the County of Delaware and therefore return same NOT FOUND. Deputies attempted service at 1185 Dermond Road, Apartment A, Drexel Hill, Pennsylvania 19026 on July 30, 2012 at 2010 hours and ha found the residence to be vacant. SHERIFF COST: $37.45 August 09, 2012 SO ANSWERS, r~ ~,~ RON R ANDERSON, SHERIFF ic) ~eumy5uite Shenft.'teleosoft, In. .~-_„ ~ • 1'~ 1 SHERIFF S OFFICE OF CUMBERLAND CO N Ronny R Anderson ~aa~~tp of ~,r,,,brrr,, ~ ~~~ }r~n ~ ~) ~~39. ~D Sheriff ~ nv a~' I ~ Jody S Smith ~ ~ - Q_,7.~,'~ Richard W Stewart Chief Deputy ~~3cE ~F ~~E ~~~~~~~ ~ Lv - ~ solicitor, Dickinson College vs. Case Numb r Rachelle Guzy 2012-1714 o SERVICE COVER SHEET N >: - F<.=_ M ~~ o Cates~orv: Civil Action -Complaint 8 Notice ~ zones w Manner: Deputize -! Expires 07/30/2012 ~ Warrant• _. _ . _ - Notes: - a µ.~. ,e..e.e e. w,v,.. _ N ~sa .. J J _ J W fC W ~_............_..._.~..6~. ...,..W. .....~......._.~_.~._....._. __,,,~..._,~,.., .,.~......., _ _._.~~......._......~._. ......._... ..._ ~ Name: Rachelle Guzy Served: Personally ~ Adult In Charge ~ Posted ~ Other z ~ Primary ~Addr~ess: . _.~_m_.__ ~w.. 1185 Dermond Road, Apartment A ~~ _.. Drexel Hill PA 19026 ~ _ _ Adult In _w_ _.~ N~mm-~ Charge: - -~ ~ ° ~ , _~.m~.~.. ...-,.~-_...~,.,~,._._ __~._.,~ a Phone: DOB: ~ ,..~n _.~ ~.._....~ _ _. _____-__ _ _ _ _..._ n Relation: Alternate ~._.~.~~...~..~..~_.....~~._~~.~~... .-_.~.~_.._,._..-.~.~ w u.~. Date: Time: ~ Address: ~ rv -~.., ~.,...__..~ ~ .....3 _..mv___ . ...... ......... 0 Phone: Deputy: ~ Mileage: r _ed.~..___..___._.~..~.~. ~~. ~. ~. .. ___.. _ ~~ __~ .....w-.~ GC { ,,. W n -;5~~~ "rat t, o- ,..; ~i ~ ._ + .~~........b...~,.,~._y ~...._,..~ ~._~..,...~.~_.~..-~ ._-.m.......~..__..__........_.W.. ~... _. _.... ~ Name: ~Chnstopher E Rice Phone: 717-243 3341 .__~ ._...__rw __ _~_. ~.~...,~ ~...... _ ..w...~...~_....., .K _ .... _..._ ~_____ ~ __ ~..I a r ~jYA~Sa~ ;,j" ,~ Date: ~~ (~~~ (~- 7 Time: , ti ~~ N Mileage: c°v Deputy: ~~~p~/z ~"/~f~~"~ ~l/J~~~~,-~ ~~ otrw ~....,,_, Aram _ G ~1 EAL Sworn t~snd belies SUSA+N.,ir N E~ fl~ W this ~ ~. 1-. ~ 1., Zt}12 .. I»r w Now, July 06, 2012 I, Sheriff of Cumberland Count , enn~~~s/Ivani o hereb de utize the Sheriff of D 'I Y Y Y p e aware Cou ty to v execute service of the documents herewith and make return thereof accordingsto iaw. . Return To: Cumberland County Sheriffs Office ~ One Courthouse Square °"~-_ Carlisle, PA 17013 onny R Anderson, Sheriff F \FILES\Clients\7619 Dickinson College\7619.Collections\7619C.Cuttent\7619C.382 Gury\7619C.382.pra.reinstate Christopher E. Rice, Esquire ~. ~ ~. G. ~ .~~~ ~, Attorney LD. No. 90916 ~~' ~~ ' - ~' '~' MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER ~~~ 24 PM !2• MARTSON LAW OFFICES Ten East High Street ~ ~ Carlisle, PA 17013 ~~~` (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff v. RACHELLE GUZY, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAl NO. 2012 - 1714 CIVIL ACTION -LAW PRAECIPE Please reinstate the Complaint in the above-referenced matter. Date: 8~~ ~ e/~ MARTSON LAW OFFICES By: ~~~•- ~ S 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 FOF DICKINSON COLLEGE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. A l1~~,2G03 ~ ~~ ~