HomeMy WebLinkAbout12-4264Christopher 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
CMG Lai J1 11
PENNSYLVANI
DICKINSON COLLEGE,
Plaintiff
V.
ANDREW J. CAVERLY,
SANDRA L. CAVERLY, and
ANDREW L. CAVERLY,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVAI
NO. 2012 - ya U ? CIVIL TERM
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 wit)
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 yo>!l
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 LAWYI
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABL
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
F. TILES,Clients\7619 Dickinson College\7619.Collections\7619C.Current\7619C. 108 Caverly\7619C-108.com
Christopher E. Rice, Esquire
I.D. No. 90916
MARTSON DEARDORFF WILLIAMS
MARTSON LAW OFFICES
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
OTTO GILROY & FALLER
DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVAN
V. NO. 2012 - CIVIL TERM
ANDREW J. CAVERLY,
SANDRA L. CAVERLY, and
ANDREW G. CAVERLY,
Defendants
COMPLAINT
AND NOW, comes Plaintiff Dickinson College by and through its attorneys, MAR'
DEARDORFF WILLIAMS OTTO GILROY & FALLER, and hereby avers as follows:
1. Plaintiff, Dickinson College, is a Pennsylvania educational institution and nonprofit
corporation with its principal place of business at West Street, Post. Office Box 1773, Carlis?le,
Cumberland County, Pennsylvania 17013.
2. Defendants Andrew J. Caverly and Sandra L. Caverly, (hereinafter "Parents"),
adult individuals residing as husband and wife with a last. known address of 820 Lavers Circle,
G507, Delray Beach, FL 33444-7847, and are the parents of Defendant Andrew G. Caverly.
3. Defendant Andrew G. Caverly (hereinafter "Student"), is an adult individual witt a
last known address of 820 Lavers Circle, Apt. G507, Delray Beach, FL 33444-7847.
4. On or about August 15, 1997, Parents and Student entered into a Promissory N
(Note 41) with Plaintiff for the financing of $4,000.00, plus interest, for educational services
benefits to Student at Plaintiff s institution. A copy of Note #1 is attached hereto as Exhibit "A."
5. On or about August 1, 1997, Parents and Student entered into an additi
Promissory Note (Note #2) with Plaintiff for the financing of $10,000.00, plus interest,
educational services and benefits to Student at Plaintiff s institution. A copy of Note #2 is
hereto as Exhibit "B."
6.. The collective principal for Note #1 and Note #2 was $14,000.00.
7.. Note #1 and Note #2 grant Plaintiff reasonable collection and attorneys' fees which
Plaintiff has calculated to be $2,000.00.
8. As of May 24, 2012, the principal and interest due and payable by Parents and S
to Plaintiff was $21,527.55, plus interest and costs.
9. Parents and Student stopped making monthly payments on Note #1 and Note #2
or about March 1, 2010.
10. As of May 24, 2012, the outstanding balance of $21,527.55 represents the total
actual overdue value of the financing provided to Parents and Student under Note #I and Note
for which they have yet to pay.
1 l . Plaintiff fulfilled, performed and complied with all obligations and conditions ofN
#I and Note 42.
12. Plaintiff has made demand for payment numerous times., but Defendants have
to comply.
COUNT I
BREACH OF CONTRACT
Dickinson College v. Defendants
13. Plaintiff hereby incorporates by reference the averments contained in Paragraph 1
through 12 of this Complaint.
14. Parents and Student breached the expressed and implied obligations, conditions
terms of agreement of Note 41 and Note #2 by failing to pay the amounts financed therein.
WHEREFORE, Plaintiff demands judgment against Defendants, Andrew J. Caverly,
L. Caverly and Andrew G. Caverly, in the amount of $21,527.55, plus interest, costs and
fees in the amount of $2,000.00.
COUNT II
IN QUANTUM MERUIT
Dickinson College v. Defendants
15. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 14 of this Complaint.
15. Having requested Plaintiff to loan money, and doing so to the benefit of S
Student became liable to Plaintiff for said money.
16. Student has been unjustly enriched by accepting said money without paying Plaintiff
reasonable compensation therefor.
17. The total amount by which Student has become enriched is $21,527.55, plus inte0st
and costs.
WHEREFORE, Plaintiff demands judgment against Defendant, Andrew G. Caverly, in ?he
amount of $21,527.55, plus interest, costs and attorneys' fees in the amount of $2,000.00.
MARTSON LAW OFFICES
By: By: Ll?,4-4
5-
Christopher E. Rice, Esquire
I.D. No. 90916
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
/ Attorneys for Plaintiff
Date:
This a debt collecting firm attempting to collect a debt for Dickinson College.
Any information obtained will be used for that purpose.
EXHIBIT "A"
DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - PLANT A
EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT
August 15, 1997
Seller: Dickinson College, Carlisle, Pennsylvania 17013
Buyer(s): Andrew J. & Sandra L. Caverly
940 Macungie Ave
Emmaus, PA 18049
If there is more than one Buyer, each of you will be obligated, jointly and severally, for all sums due and for
the performance of all agreements as provided in this Contract..
Under the terms of this Educational Goods and Services Retail Installment Contract, you have a eed to pay
the expenses incurred for goods and services to be provided and rendered, as the case may be, to Andrew G. Caverly
(hereinafter "Student") during his/her enrollment at Dickinson College during the 1998 academic year, including
tuition, room and board, books and supplies as herein stated (hereinafter the "Goods and Services").
The Goods and Services shall include only tuition, room and board.
II. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUAL FINANCE AMOUNT TOTAL OF TOTAL' SALE
PERCENTAGE CHARGE: FINANCED: PAYMENTS: PRICE:
RATE: Dollar Amount Amount of credit Amount paid by Total cost of
Cost of credit as credit will provided by Buyer as total of all purchase on credit
yearly rate cost Buyer Dickinson College scheduled includin down
payments payme t of
Prior to repay-
ment: 11.00%
23,29.00
During repay-ment:
11.00% 3095.41 4,000.00 7095.41 27,29 .00
Rev 2/92
Caverly
Buyer's payment schedule will be as follows:
Number of Payments Amount of Payments When Payments are Due
monthly commencing 9/28/97, and continu ing until
04/28/01 or such time as Student is no longer e nrolled at
44 $36.67 Dickinson (or in an approved full-time o f-campus
program of studies), whichever is earlier.
monthly commencing 05/28/01 or such time as tudent is
72 $76.14 no longer enrolled at: Dickinson (or in an appr oved full-
time off-campus program of studies), whi 0ever is
earlier.
Late charge: If a payment is more than 15 days late, a sum equivalent to 5% of the late payment (but n? more than
$2.50 and not less than $1.00) may be charged.
Prepayment: Buyer may prepay the unpaid balance of the Amount Financed and any FINANCE CHARGE due
through the date of early payment, in full or in part, without penalty.
SEE SECTION VI OF THE CONTRACT BELOW FOR ANY ADDITIONAL INFORMATION AB UT NON-
PAYMENT, DEFAULT AND REQUIRED REPAYMENT BEFORE THE SCHEDULED D TE FOR
REPAYMENT OF THE AMOUNT FINANCED.
III. ITEMIZATION OF AMOUNT FINANCED
1.
2.
3.
4.
5.
Cash price of Goods and Services:
Total down payment:
Unpaid balance of cash price (1 - 2):
Amount paid to others on Buyer's behalf.
Amount Financed (3 + 4):
$ ;27,290,00
1
03,290.00
4,000.00
-0-
$ 4,000.00
2
IV. CREDIT INSURANCE
Credit life insurance for the term of this Contract is not required.
V. NO WARRANTIES
THERE ARE NO WARRANTIES, EITHER EXPRESSED OR IMPLIED, GIVEN BY SELLER IN CONNEC ION WITH
SALE OF THE GOODS AND SERVICES COVERED BY THIS CONTRACT UNLESS BUYER HAS BEEN GIVEN A EPARATE
WRITTEN WARRANTY.
VI. ADDITIONAL PROVISIONS
Buyer agrees to pay Seller the Total Sale Price by making the total down payment and paying Seller the Total o Payments in
the number and amount of monthly payments shown in the Payment Schedule. Payments are due on or before he same date
of each month as the first payment date. Payments must be made to Eduserv Technologies, Inc. at the following address:
Eduserv Technologies, Inc.
P.O. Box 64974
St. Paul, MN 5 5 1 64-0974
2. Buyer's legal rights include the right to pay all or part of the amounts due on this Contract in advance of their oue dates, to
obtain a refund or credit of unearned Finance Charge whenever the amount is paid in full in advance, and (with Sel ees consent)
to reinstate the Contract if Buyer timely cures any default.
3. Buyer shall be deemed to have committed an "Event of Default" of the Contract upon the occurrence of any of the following:
(a) failure to make any payment on or before the date it is due,
(b) failure to make a payment on any other Contract outstanding with Seller,
(c) failure to perform any other provision of the Contract,
(d) providing Seller with false information or signatures,
(e) death, incompetence, or conviction of any Buyer of crime involving fraud or dishonesty,
(f) insolvency or bankruptcy of any Buyer.
4. Upon or after the occurrence of any Event of Default, Seller will provide Buyer with notice, by certified mail as required by
law, addressed to Buyer's last known address as shown on Seller's records, advising Buyer of the default and of Buyer's right
to cure the default. The notice will provide the time, amount and performance necessary to cure the default. If Buyer does not
cure the default as provided in the notice, Seller's rights shall include the right to declare all sums due on the C ntract to be
immediately due and payable. The Buyer agrees to pay all attorney's fees and other reasonable collection costs d charges
necessary for 'he collection orany amount not paid when due.
Waiver by Seller of any event of default shall not be binding upon Seller if Seller should thereafter choose to exe ctse that or
any other right or a similar Event of Default occurs later. All Seller's rights and remedies shall be cumulative. Sell is exercise
of one or more rights shall not cause Seller to lose any other rights.
This Contract is freely assignable by Seller. Buyer agrees that upon receiving notice of the assignment Buyer shall 4e obligated
to the Assignee of this Contract, which Assignee shall have all of Seller's rights and remedies.
If any part of this Contract is held to be illegal, void or unenforceable, that provision shall be deemed not to have been a part
of this Contract, which shall otherwise remain fully effective.
3. APPLICABLE LAW: This Agreement, whenever called upon to be construed, shall be governed by the domestic internal laws
of the Commonwealth of Pennsylvania except to the extent supplemented, superseded or preempted by federal la .
CONSENT TO JURISDICTION VENUE AND SERVICE: The parties to this Agreement consent and agree that all legal
proceedings relating to the subject matter hereof shall be maintained in the Court of Common Pleas of Cumberland County,
Pennsylvania, or, if applicable, the United States District Court of the Middle District of Pennsylvania, and all pa? ies hereto
consent and agree that jurisdiction and venue for such proceedings shall lie exclusively within said court. Serviced of process
in any such proceeding may be made by certified mail, return receipt requested, directed to the respective party at !the address
set forth above.
10. This Contract shall be binding upon the parties hereto, their heirs, successors, assigns and legal representatives.
11. TIME IS OF THE ESSENCE OF THIS CONTRACT.
NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSE WHICH
THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HE TO OR
WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS AID BY
'CHE DEB"IOR HEREUNDER.
NOTICE TO BUYER: (1) DO NOT SIGN THIS AGREEMENT BEFORE YOU READ IT OR IF IT CONTAINS A BLANK
SPACE. (2) YOU ARE ENTITLED TO A COMPLETELY FILLED-IN COPY OF THIS AGREEMENT. (3) UNDER THE LAW,
YOU HAVE THE RIGHT TO PAY OFF IN ADVANCE THE FULL AMOUNT DUE AND UNDER CERTAIN CONDITIONS TO
OBTAIN A PARTIAL REFUND OF THE FINANCE CHARGE.
BUYER(S) ACKNOWLEI
BE LEGALLY BOUND B'
BUYER(S):
ACT AND INTEND(S) TO
I AGREE TO REPAY ALL AMOUNTS DUE ON THIS LOAN IF THE BORROWER(S)/BUYER(S) FAILS
ACCORDANCE WITH THE TERMS OF THE NOTE:
STUDENT COSIGNER Gmly-, .b . Q! ?
DATE:
DOSOIN
TRANSCRIPTS OF A STUDENT'S RECORD WILL NOT BE RE?EASEI
I LOAN PAYMENTS TO TiiE COLLEGE ARE i,8 ARREARS OR DL; AULT.
DICKINSON COLLEGE
BY
EXHIBIT "B"
DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - PLAN B
EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT
August 1, 1997
1. Seller: Dickinson College, Carlisle, Pennsylvania 17013-2896
Buyer(s): Andrew J. & Sandra L. Caverly
940 Macungie Ave
Emmaus, PA 18049
If there is more than one Buyer, each of you will be obligated, jointly and severally, for all sum due and for the
performance of all agreements as provided in this Contract.
Under the terms of this Educational Goods and Services Retail Installment Contract, you have greed to pay the
expenses incurred for goods and services to be provided and rendered, as the case may be, to An rew G. Caverly
(hereinafter "Student") during his/her enrollment at Dickinson College during the 1998 academic year, including tuition,
room and board, books and supplies as herein stated (hereinafter the "Goods and Services").
The Goods and Services shall include only tuition, room and board.
11. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
ANNUAL FINANCE AMOUNT TOTAL OF T AL SALE
PERCENTAGE CHARGE: FINANCED: PAYMENTS: PRICE:
RATE:* Dollar amount Amount of credit Amount paid by Total cost of
Cost of credit as credit will provided by Buyer as total p rchase on
yearly rate cost buyer Dickinson College of all scheduled cre it, including
payments do payment of
$ 27,290.00
9.50% $ 7,230.72 $ 10,000.00 $ 17,230.72 $ 17,290.00
Rev 2'92
Caverly
Buyer's payment schedule will be as follows:
Number of Payments Amount of Payments When Payments are Due
152 $ 113.36 Monthly commencing 09/28/97 until 05/28/10
*Variable Rate: The ANNUAL PERCENTAGE RATE disclosed above is a variable rate and n
ANNUAL PERCENTAGE RATE may increase during the term of this transactio;
of interest announced in the Wall Street Journal as of the close of business on
calendar year increases, and will be increased to the prime rate plus 1 %.
PERCENTAGE RATE will not increase more than once a year, and the new
become effective on July 1 following the increase, if any, in the prime rate of inter
will be in the form of higher payment amounts. If your cost of the Goods a.
hereunder were $10,000.00 at 9.50% per annum for 152 months and the prime r;
increased to 10.50%, your regular monthly payments would increase to $119.
ANNUAL PERCENTAGE RATE will not increase to more than 18% or such oth
permitted under the Pennsylvania Goods and Services Installment Sales Act.
Late Charge: If a payment is more than 15 days late, a sum equivalent to 5% of the late
than $2.50 and not less than $1.00) may be charged.
ay change. The
if the prime rate
June 30 of each
The ANNUAL
zterest rate will
st. Any increase
d Services sold
:e plus 1 % were
1. Further, the
r rate as may be
(but no more
Prepayment: Buyer may prepay the unpaid balance of the Amount Financed and any FINANCI, CHARGE due
through the date of early payment, in full or in art, without penalty.
SEE SECTION VI OF THE CONTRACT BELOW FOR ANY ADDITIONAL INFORMATION BOUT NON-
PAYMENT, DEFAULT AND REQUIRED REPAYMENT BEFORE THE SCHEDULED DATE FOR REPAYMENT
OF THE AMOUNT FINANCED.
1.
2.
3.
4.
5.
III. ITEMIZATION OF AMOUNT FINANCED
Cash price of Goods and Services: $ 27,290.00
Total down payment: 17,290.00
Unpaid balance of cash price (1 - 2): 10,000.00
Amount paid to others on Buyer's behalf: - 0 -
Amount Financed (3 + 4): $ 10,000.00
2
IV. CREDIT INSURANCE
Credit life insurance for the term of this Contract is not required.
V. NO WARRANTIES
THERE ARE NO WARRANTIES, EITHER EXPRESSED OR IMPLIED, GIVEN BY SELLER IN CONNECTION WITH SALE
OF THE GOODS AND SERVICES COVERED BY THIS CONTRACT UNLESS BUYER HAS BEEN GIVEN A SEPARATE WRITTEN
WARRANTY.
VI. ADDITIONAL PROVISIONS
1. Buyer agrees to pay Seller the Total Sale Price by making the total down payment and paying Seller the Total of
Payments in the number and amount of monthly payments shown in the Payment Schedule. Payments are due on 6r
before the same date of each month as the first payment date. Payments must be made to Eduserv Technologies, Inc. at
the following address:
Eduserv Technologies, Inc.
P.O. Box 64974
St. Paul, MN 55164-0974
2. Buyer's legal rights include the right to pay all or part of the amounts due on this Contract in advance of their due tes, to
obtain a refund or credit of unearned Finance Charge whenever the amount is paid in full in advance, and (with Sell ees
consent) to reinstate the Contract if Buyer timely cures any default.
Buyer shall be deemed to have committed an "Event of Default" of the Contract upon the occurrence of any of the
following:
(a) failure to make any payment on or before the date it is due,
(b) failure to make a payment on any other Contract outstanding with Seller,
(c) failure to perform any other provision of the Contract,
(d) providing Seller with false information or signatures,
(e) death, incompetence, or conviction of any Buyer of crime involving fraud or dishonesty,
(f) insolvency or bankruptcy of any Buyer.
Upon or after the occurrence of any Event of Default, Seiler will provide Buyer with notice, by certified mail as re irec
by law, addressed to Buyer's last known address as shown on Seller's records, advising Buyer of the default and of uye
right to cure the default. The notice will provide the time, amount and performance necessary to cure the default. I
Buyer does not cure the default as provided in the notice, Seller's rights shall include the right to declare all sums due on
the Contract to be immediately due and payable. The Buyer agrees to pay all attorney's fees and other reasonable
collection costs and charges necessary for the collection of any amount not paid when due.
Waiver by Seller of any Event of Default shall not be binding upon Seller if Seller should thereafter choose to
that or any other right or a similar Event of Default occurs later. All Seller's rights and remedies shall be cumu
Seller's exercise of one or more rights shall not cause Seller to lose any other rights.
5. This Contract is freely assignable by Seller. Buyer agrees that upon receiving notice of the assignment Buyer shall
obligated to the Assignee of this Contract, which Assignee shall have all of Seller's right and remedies.
3
!. if any part of this Contract is held to be illegal, void or unenforceable, that provision shall be deemed not to have been a
part of this Contract, which shall otherwise remain fully effective.
8. APPLICABLE LAW: This Agreement, whenever called upon to be construed, shall be governed by the domestic internal
laws of the Commonwealth of Pennsylvania except to the extent supplemented, superseded or preempted by federal law.
9. CONSENT TO JURISDICTION. VENUE AND SERVICE: The parties to this Agreement consent and agree that Oil
legal proceedings relating to the subject matter hereof shall be maintained in the Court of Common Pleas of Cumbe land
County, Pennsylvania, or, if applicable, the United States District Court of the Middle District of Pennsylvania, and all
parties hereto consent and agree that jurisdiction and venue for such proceedings shall lie exclusively within said c urt.
Service of process in any such proceeding may be made by certified mail, return receipt requested, directed to the
respective party at the address set forth above.
10. This Contract shall be binding upon the parties hereto, their heirs, successors, assigns and legal representatives.
11. TIME IS OF THE ESSENCE OF THIS CONTRACT.
NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFE]
WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSU
HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCI
AMOUNTS PAID BY THE DEBTOR HEREUNDER.
NOTICE TO BUYER: (1) DO NOT SIGN THIS AGREEMENT BEFORE YOU READ IT OR IF IT CONTAINS ANY
SPACE. (2) YOU ARE ENTITLED TO A COMPLETELY FILLED-IN COPY OF THIS AGREEMENT. (3) UNDER
LAW, YOU HAVE THE RIGHT TO PAY OFF IN ADVANCE THE FULL AMOUNT DUE AND UNDER CERTAIN
CONDITIONS TO OBTAIN A PARTIAL REFUND OF THE FINANCE CHARGE.
BUYER(S) ACKNOWLEDGE(S) RECEIVING A COMPLETED C PY OF THIS CONTRACT AND INTENDO TO
BE LEGALLY BOUND BY ITS TERMS /,? J-_)
BUYER(S):
1 AGREE TO REPAY ALL AMOUNTS DUE ON THIS LOAN IF THE BOFROANER(S)BUYEP(S) FAILS TO DO SO
IN ACCORDANCE WITH THE TERMS OF THE NOTE:
STUDENT COSIGNER
TRANSCRIPT OF A STUDENT'S RECORD WILL NOT BE RELEASED IF LOAN PAYMENTS TO THE COLLEGE
ARE IN ARREARS OR DEFAULT.
DATE: DICKINSON COLLEGE
BY
4
VERIFICATION
1. Sally Heckendorn, Bursar of Dickinson College, acknowledge that I have the authoritJi, to
execute this Verification on behalf of Dickinson College and certify that the foregoing Compli ?int
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
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 Verificat' n.
This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4 04
relating to unsworn falsification to authorities, which provides that if I knowingly make f?lse
averments, I may be subject to criminal penalties.
Dickinson College
By; J
Sally Heckend
Bursar
Dated:
F.\FILES\Clients\7619 Dickinson College\7619.Collections\7619C.Cuuent\76190.108 Caverly\76190.108. as
Christopher E. Rice, Esquire
I.D. No. 90916 i.cu...0i;:
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER f, ",E PRO H 0 Nr?
MARTSON LAW OFFICES 23 Al I
Ten East High Street JUL 7-012 Carlisle, PA 17013 CUMIOE4AND C OUN Y
(717) 243-3341 PENNSYLVANIA
Attorneys for Plaintiff
DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANI
V. : NO. 2012 - 4264 CIVIL TERM
ANDREW J. CAVERLY,
SANDRA L. CAVERLY, and
ANDREW L. CAVERLY,
Defendants
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 mailed
Andrew G. Caverly, 820 Lavers Circle, Apt. G507, Delray Beach, Florida 33444-7847, by certifi
mail, restricted delivery, return receipt requested.
Attached is the signed Post Office return receipt dated July 14, 2012, with attached recei
costs in the amount of $10.90.
MARTSON LAW OFFICES
By- ??x r vz-?
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Sworn to and subscribed
before me this day of July, 2012.
0,4?-
Noir.lublic
COMMONWEALTH OF PENNMV IA
Notarial S281
Mary M. prise, Notary Publie
Caro* Born, Cumberland County
My CworAsdon Erlp rw At* 18, 2015
MEMBER, FUM-TUANU ASSOCUTION - NOTARIES
THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR
DICKINSON COLLEGE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
¦ Complete items 1, 2, and 3. Also complete
Item 4 If Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailpiece,
or on the front If space permits.
1. Article Addressed to:
/qV ate- P,
A.
13 AQKtt
Received Pf (PffnW Nanj0' C. Date of Delivery
D. Is delivery addressQifferent from item 1? 0 Yes
If YES, enter delivery address tfeldw: ? No
3. Service Type
?VOwdfled Moil 13 Express Mail
Registered 0 Return Receipt for Merchsrldlee
O irmsed mail 0 C.O.D.
4. Restricted DelveyY (Extra Fee)
2. Article Number 7G11 2 D-0 0 0 001 2523 0091
(liwWw from sarmbe iebe
P$ Form 3811, Fdwuwy =4 Domestic Return Receipt 102595.02401-1540
ra (Dofnestic Mail Only; No Insurance Coverage . -
Ir
..
C3
r m P. Q
M
ni
Ln Postage $
111
Certified Fee
Postmark
p Return Receipt Fee
O (Endorsement Required) = .. - - (} ere
M Restricted Delivery Fee
Q (Endorsement Required) - .: .
C3 Total Postage & Fees i
ni
t `
r•q
`? Street, No-- --------
C3 or PO Box No.
.................. •-• . ...... .... ---• ..... .--=...............
CRY, sfafe. ZI J
F:\F1LES\Clients\7619 Dickinson Coll ege\7619, Collec[ions\7619C.Cutrent\7619C.108 Caverly\7619C. 108.as2
Christopher E. Rice, Esquire
I.D. No. 90916
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER ;; '? - t l r ; I
i 1,F PR0,TH0N
MARTSON LAW OFFICES
Ten East High Street 2-012 JUL 23 AM 11 28
Carlisle, PA 17013
(717) 243-3341 CUMBERLAND COUNTY
Attorneys for Plaintiff PENNSYLVANIA
DICKINSON COLLEGE,
Plaintiff
V.
ANDREW J. CAVERLY,
SANDRA L. CAVERLY, and
ANDREW L. CAVERLY,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVAI
: NO. 2012 - 4264 CIVIL TERM
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 1
Andrew J. Caverly, 820 Lavers Circle, Apt. G507, Delray Beach, Florida 33444-7847, by
mail, restricted delivery, return receipt requested.
Attached is the signed Post Office return receipt dated July 14, 2012, with attached receipt
costs in the amount of $10.90.
MARTSON LAW OFFICES
BY 4„ S r
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
w- day of July, 2012. COMMI?NW r WS PENNSYLVANIA
` Mary M. Price, Notary Public
Carlisle Boro, cumberiand County
My CorrK "wl Bou . 16, 2015
N ublic arxt, aa?NSnmm Assoa?na+ OF WTAMS
Sworn to and subscri ed
me this
before Notarial Seal
to
THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR
DICKINSON COLLEGE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
• Complete Items 1, 2, and 3. Also complete
Item 4 If Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
• Attach this card to the back of the mailpiece,
or on the front If suave nArmitc
• Arme Aaaressed to:
? evess mail
? Retort, Receipt for Mwdnrldlse
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(Domestic Mail Only, No Insurance Coverage Provtdeo?
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P$ Form 3811, Febnzary 2004 Domestic Return Receipt
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F TILES',Clients\7619 Dickinson Coll ege\7619.Collections\7619C.Current`.7619C. 108 Caverly\7619C.109.pra.
Christopher E. Rice, Esquire
I.D. No. 90916
MARTSON DEARDORFF WILLIAMS
MARTSON LAW OFFICES
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
C7 r.a --1
OTTO GILROY & FALLER =m
-
?;? c- -tyx rT
DICKINSON COLLEGE,
Plaintiff
V.
ANDREW J. CAVERLY,
SANDRA L. CAVERLY, and
ANDREW G. CAVERLY,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVAT
NO. 2012 - 4264 CIVIL TERM
PRAECIPE
Please amend the caption in the above-referenced matter to correct the name of
Caverly, erroneously listed as Andrew L. Caverly.
MARTSON LAW OFFICES
d
By
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
G.
THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR
DICKINSON COLLEGE. ANY INFORMATION OBTAINED WILL BE USED FOR THAI
PURPOSE.
F-\FILF,S\Clients\7Ei19 Dickinson College\7619.CollectionsV619C.CurrenfV619C.108 Caverly\7619C.1O8.pra.reinstate
Christopher E. Rice, Esquire c~ ~ '
LD. No. 90916
MARTSON DEARDORFF WILLIAMS GG
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OTTO GILROY & FALLER ~~ .---
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MARTSON LAW OFFICES
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DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COiJNTY, PENNSYLVANIA
v.
ANDREW J. CAVERLY,
SANDRA L. CAVERLY, and
ANDREW G. CAVERLY,
Defendants
To the Prothonotary:
NO. 2012 - 4264 CIVIL TERM
PRAECIPE
Please reinstate the Complaint in the above-referenced matter.
MARTSON LAW OFFICES
By
lJ/N /020 l~
~.~ S 2
Christopher E. Rice, Esquire
Attorney I.D. No. 90916
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR
DICKINSON COLLEGE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
~~1. 75 PA pTN
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