HomeMy WebLinkAbout12-7716F \FILES\ClientsV619 Dickinson CollegeV619.CollectionsV619C CurrentV619C.394 VinanskyV6I9C.394.com
Christopher E. Rice, Esquire ~~ ~'
' ~ [ ~ ~'
Attorney I.D. No. 90916 T
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER "~ "^ ~ ~~'` ~~ ~~~' ~ : ~ -t
MARTSON LAW OFFICES
Ten East High Street ~ t1 ~ n ~ ~~' a ~ ~) t,~~ ~,~ ~ ; ``
Carlisle, PA 17013 ' t' ~' ~ =' ~~~-~~~+~lti+
(717) 243-3341
Attorneys for Plaintiff
DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. 2012 - '~"~ I (~
JOHN J. VINANSKY, CIVIL ACTION -LAW
Defendant
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice are
served, by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to do
so, the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiffs. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
~'/03.7S7j~ f~.~/
.~
CIS .a%S3S
!~ d8y~6S
F:\FILES\Clients\7619 Dickinson Collegel'7619.CollectionsV619C.CurrentV619C.394 VinanskyV619C.394.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 - `~ ~ ~ ~ GNP I
JOHN J. VINANSKY, 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, John J. Vinansky, is an adult individual residing at 233 Gravity Avenue,
Olyphant, Lackawanna County, Pennsylvania 18447.
3. On or about September 1, 1997, Defendant entered into a Promissory Note -Federal
Perkins Loan Program ("Note 1 ") with Plaintiff for the financing of $1,500.00 plus interest for
educational services and benefits at Plaintiff s institution. A copy of the Note is attached hereto as
Exhibit "A."
4. On or about September 4, 1998, Defendant entered in a Promissory Note -Federal
Perkins Loan Program ("Note 2") with Plaintiff for the financing of $1,000.00 plus interest for
educational services and benefits at Plaintiff s institution. A copy of Note 2 is attached hereto as
Exhibit "B."
5. On or about August 30, 1999, Defendant entered into a Promissory Note -Federal
Perkins Loan Program ("Note 3") with Plaintiff for the financing of $1,000.00 plus interest for
educational services and benefits at Plaintiff's institution. A copy of the Note is attached hereto as
Exhibit "C."
6. On or about January 5, 2001, Defendant entered into a Promissory Note -Federal
Perkins Loan Program ("Note 4") with Plaintiff for the financing of $600.00 plus interest for
educational services and benefits at Plaintiff's institution. A copy of the Note is attached hereto as
Exhibit "D."
7. The Notes are 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.
8. 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.
9. The principal amount for the Notes is $4,100.00.
10. The Notes grant Plaintiff reasonable collection and attorneys' fees which Plaintiff has
calculated to be $500.00.
11. Defendant made one payment in the amount of $25.00 in March of 2012.
12. As of August 5, 2011, the principal and interest due and payable by Defendant to
Plaintiff was $1,457.68, with interest accruing at 5% per annum.
13. Plaintiffhas fulfilled, performed and complied with all obligations and conditions of
the Note.
COUNTI
BREACH OF CONTRACT
14. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 13 of this Complaint.
15. Defendant breached the expressed and implied obligations, conditions and terms of
agreement of the by failing to pay the amounts financed therein.
WHEREFORE, Plaintiffdemands judgment against Defendant in the amount of $1,457.68.
plus interest accruing at 5% per annum, collection and attorneys' fees in the amount of $500.00, and
costs of suit.
COUNT II
IN 4UANTUM MERUIT
16. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 11 of this Complaint.
17. Having requested Plaintiffto loan money, and doing so to the benefit of Defendant,
Defendant became liable to Plaintiff for said money.
18. Defendant has been unjustly enriched by accepting said money without paying
Plaintiff reasonable compensation therefor.
WHEREFORE, Plaintiffdemands judgment against Defendant in the amount of $1,457.68,
plus interest accruing at 5% per annum, collection and attorneys' fees in the amount of $500.00, and
costs of suit.
By:
Date: / 2 - 2 i- /~L..-
MARTSON LAW OFFICES
~~ sti
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 PERK/NS LDAN
PROMISSORY NOTE ~ ~- ' ~' -
1. Name past, frcst, middle initiaq and 2. Social Security Number
Permanent Address (street, city, state, zip code)
Vinansky, John J. s. Date oreirth ,
705 Clark St. '
Throop, PA 18512 -
4. Area Codeffelephone Number
5. Driver's Ucense Number p.ist state abbreviation first)
~_
6. School Name & Address (street, city, state, zip code) 7~.-1Borrower Status 8. IrK~est Rate
~..1-wt-err. or yi.abr 0 tma u~.rt h.r-eMte 59'0
P.O. Hoge 1773 _ - _ --- --- 9. Loan Amount: 10. Loan Period
t„erlislea PA 17013-2896
1 500.00 1997-1998
r~s AND t:oroDmonrs
iAny bracketed a.tbe err pars~apft may be in<r,eed,c aptbn or irstlltuiore.]
APPLICABLE LAW -The tams of fhb note and any dbbursanena made urtda fhb note shall be IrKapreted In xcordanee with Part E of Title N of the HIgMr
EAUCation AM of 1965, u amended (hereinafter called the Ace), as well n Federal reguLtiona broad under the Aet. All sureu advanced under fhb note are subJeet ro the
Aa and Federal regulations blued under the Act.
REPAYMENT • I am obligated to repay the principal and the inurcst that aeaues on n to the above-named instltutlon (hereinafter Hued the school) over a period
' beginning 9 months (or sooner Jf I am a lea than shelf--time borrower) after the date I case to be aleast a hdf-time student at an lmtitutbn of higher eduction or a
' comparable school outside the Unked Sates approved by the United Staw Secretary of Edacatlon (}KretnaRer called the Secretary) and ending 10 yeah titer, unity I
request Irt wrkbeg that my rcpaymaet period begin sooner. I understand that the sclwol w1U report the arnoeutc of trey irntWretent payrrtertts. aksng with the amount of fhb
.ban io a rutbnl ersdk bureau. Intact on this km shall accrue from the beginning of the repaymsrn period. My repaymsrn Period mry be shorter than 10 years if I am
' required by my school to make minimum monthly payrtuna. Upon my wrleten tpusa my rapaymern period relay be extended during perbda of deferment. hardship, or
forbearance ar-d I may nuke graduated irntallreterns in xeordarrct with a schedule approved by the Secretary. 1 wUl make my lrestallrreerK payments m equal monthly,
bimonthly or quarterly irutailmerrts as datamireed by the xhool. The school may round my ins4tbnern payment to the next highest multiple of SS. [I wUl males a
minimum monthly repayment of S40 (or f30 ff I have outstanding Federal Perkins loam made before October 1. 1992 that included the 330 minimum payment option)
1n xcordanee with the Minimum Monthly Payment Section of the Tams and Conditbm eonuireed on the reverse side of fhb document.]
' LATE CHARGES -The xhool will impose late charges if I do not make a xheduled paymarn when due or tf I fall to submit to the school on or before the due date of
the payment, a properly documented writun request that I quality for arty of the forbaraue, defamern or eancelletion barofip ere desalbsd bebw. No late charge may
exceed 2096 of my monthly, bimonthly or quarterly payment. The xhool rtry add the lee charges to principal the day after the xheduled repayment wu due or include
it with the next scheduled repayment after I have r«elvsd notla of the charge, and such rrotloa k sent before the next trtstallmern is due.
REQUESTS FOR DEFERMENT, CANCELLATION OR FORBEARANCE - To rcaive deferment, careceUatbn, or forbearsrea benefits. I moat make a written request
j to the xhooi and must submit to the school any doeumentatbn the xhool requtres to prove my eUgibUity for these benefits. I am responsible for submitting the
appropruu requab on time, sad 1 may kue my benefits tl' I fall to the my request on time.
i
DEFAULT - If 1 fail to make s scheduled payment when due; u I fall to submit to the xhool, on or before the due daze o/ a scheduled paymern, documentation that I
qualify for a deferment, caneellatbn, oc forbearance; or if I tail to comply with the tams and condltiorts of this promWory note or written repayment agreement, the
xhool may, at iu option, declare my loan to ix in default and may accelercu my ban (demand imrrrediau payrreern of the ernlrc uryxid balarru of the loan, Including
principal, urterest, lace chages. and collecton coats). The school, and the Secretary, u my ksan b assigned to the Seuetay for coUeetbn, shall dbcbse to cradle bureau
organisations that 1 have defaulted and all other relevant loan Information. I wW lose my right to defy payments and my right to forbearance if I dehult on my ban. I
wUl lose my right to receive areeellatton benefiu for service that b performed efts the date the school xeeleratsd the loan. I wUl be tneltglble for any further federal
studern tlruncbl aabunce authorized under the Act until I make srangemerns that arc saWEaetory to the xhool or the Seuetuy to repay my loan.
CHANGE OF STATUS • I will inform the school of any change In my name, addrear, ulephone number. Social Security number, or driver's Ucenx numbs.
ASSIGNMENT -This note may be assigned by the school only to the UNted States. The provision of this note that relate to the school shall where approprkte relate to
the assigrxe.
PROMISE TO PAY: I promix to pay the school, or a subsequent holds of the Promissory Note. the sum of amount(s) advanced to me under the tams of this Nou, plus
interest and other fees whJ<h may b«ome due a provided In fhb Nou. 1 prombe to pay au reasonable coUecUon costs, Including attorrxy foes and other charges.
n«essary for the collection of any amount not paid when dtx. I will not sign fhb Note before reading i<, lrxluding the provbsons on the revere aide. This loan has bean
' made to rree wkhout s«urity or endorsement. My signature «rtUla I have read, urtderstartd, and agree to the terms and conditions of this Promisrory Note. THIS IS A
LOANS} THAT MUST BE REPAID
Borr~er's $i_firrature Date:
EXHIBIT "B"
--FEDERAL PERKINS LOAN
PROM/SSORY NOTE
TERINSAND COND/T10NS:
[Arry bndnted dace or p~h mY be irrksded u opdort o(1
APPLICABLE LAW • The arms of this note and any dbbursements
Eduction Act of 1965, >s amended made under fhb rate siuu be i
Att and Federal regulations issued under the /~ict.~~ ~e ~' u well es Federal ~~~ ~ kcordarue with Pan E of T1tle IV of the Higher
rcgulaUOns Issued under the Aa. Ali sums advanced under this nos are subJttt co the
REPAYMENT -1 am obligaad to repay the principal and the inarcst that accrues on !t ro the above-
beginntng 9 months (or sooner ff I am a leu than ahalf--time borrower) after the ^iA1Qd irotituclon (ixreirrafter
comparable acftool outside the Unked faces due I cease to be u kau a halt- called the school) over a period
rcqueu in writ approved by the Unked Strtes Sccraory of Education (herclnafter tlrrx ttudent at an Inttiwtion of higher eduction or a
ksan to a rnbn~i! credit great ~~ begin sooner. I understand thu the selrool wui tetrad ~ ~~uY) artd ending 10 yeah later, unless I
Interest on this kran shall accrue from the ~ ~ smoum of my instrument PaYtr-e+ta, akrng wkh the amount of this
required by my school to make minimum ~~Y PaYrrtants. Upon beglrmi7lg of the rapaymern period. My raPaYrrtern rkad
forbeararttt and I may make graduaad W ^~' written raqueu my raWynxrn period ma ~ may ba ahortar than 10 yeah U I am
minimum or qusnerly irntallrexrtts as ~ ~e.~th a scltsduk aPProwd by the Secret I Y be esttended during periods of deferment, hardsh-p. or
Y btttaumant ~ ~ make equal monthly.
monthly repayment of S40 (or 530 !f I have outstrrtding Federal Per~kirts wym ~ Irtttaument payments ~
In accordance with the Minimum Month) Pa PaYmerrc to the rxxt higixsc multiple of S5. [I will make a
Y Ymern Seetbn of the Tenrts and Condicbrts oontai~orc October 1, 1992 that lnduded the S30 minimum payment option)
LATE CHARGES -The school wits irrr ^~ on ~ reverse side of this docurrxrn.]
the payment, a ro ri Poe ba charges if I do not make a schedu4d Payment when due or if I faU to submit to the
exceed 2096 of P ~ Y documerned wrkten request that I quality for any of the forbeararKe, determent or carreuatkm school on or before the due daa of
my monthly, bimonthly or quararly PaYrnent. The school may add the Ise eiu benefits as dacrlbed
it wsth the next xheduled repayment after 1 have received notka of the c ~~ ~ late ~° tray
~ to Prirrclpy the day after the xhedukd repayment was due or include
REQUESTS FOR DEFERMENT, CANCELLATION OR FORBEA ~~ and a+clr ~~ k sent before the next instrument b due.
to the school and must submit to the RANCE - To receive determent, carrcelLtion, or forbea
•PProPriaa requests on time, school any documentuton the xhooi requires to prove ranee benefits, I mutt make a written rcqueu
and I may lose my beneRts i< I feu to fue mY euglbllity for these benefits. 1 am res
DEFAULT - It J tail to make a ~' request on time, porolbk For submuting the
qualify for a deft scheduled payment when due: U I fall to submit to the school, on or before the due
anent, canttllatkm, or forbearance: or if I feu ro daa of a
xhooi may, u its option. declare m comply with fix terms and eorrdlcWns of scheduled payment. doeumentulon thu I
Pr-nciPai. inarett, lea c Y loan to be in default and may acttleraa rrry Ip~ (derrrartd immediate a~ Pro+nlatory mote or written
harges. and eoueetlon trots). The school. and the Seere P Y~nt of the entire un id raPaytrrenc agr'eerrxrrt, the
organizations that I have defaulted and au other relevant kwr Information. I w1U ff+xd to fix $arearY ~ beVrtce of the loan. Including
tary, Y my loan b assi for colkttbn, slrau disc
wul km my right to rettlve eaneelhKion berteAts for service that b ~ my rbht to defer Payments and kxx to credit bureau
student ManeW assluanee authorized P~ormed after the dau the school accelerated ~ right to forbearance if I default on my k»n. 1
under the Act urntl I make arrangements that arc the ]oars. I wlu be lneilgibk for an f
CHANGE OF STATUS - I will inform the seh satbtactory to the uhool or the Y unbar federal
ool of any change In mY name, address. akphone numbs f ~~' to repay +rry loan
ASSIGNMENT -This note may be asst ned b the Soc41 Security number, or driver's littme number.
the assignee. g Y school only to the United Strtes. Tye
provblons of fhb note that rc4te to the school shau where aPProPriate relate to
PROMISE TO PAY: I promise to pay the xhool, ors s
Interest and other fees whkh ma ubsequenc holder of the Promtoo
necessary for the coliecgon of an become due ~ provided in this Noce. I promlre to pay aryl) reamrtabie collettl~on cost:, lneludced;ttme under the tarns of this Note, plus
made to me wlclwut seeurl Y amourn not paid when due. I wul not sign fhb Noa before raadin rn6 omey fee and ocher charges,
LOAN(S) THAT MUST E REPAID rrxnt. My signature entries ]have read. and 8 k. lneluding the provbioro on
erstand, and agree to the terrru the reverse side. This tan has bsen
and eondiuoru of this Promissory Note. THIS IS A
is Signature _ ~- ~ .?~
Dare:
EXHIBIT `~C"
FERAL PERKINS LOAN _ - - - - - - - - - - - - - -
PROMISSORY NOTE
1. Name (last, first, middle initiaq and 2•:~ia1~-SeewNt
Permanent Address (street, city, state, zip code)
Vinansky, John J. 3•;. te;df8ir~~ ,
705 Clark St.
Throop, FA 18512
4. Area Code/Telephone Number
6. School Name i Address (street, ~ state, zip code) 7.8orrower Status 8. NKerest Rate
Dicldnfaan collage.- __--___-- ~wrume«yir..n.0~mahartln._ 5%
_- - ..
P.O. Boot 1773 9. Loan Amount: 10. loan Period
Carlislie, PA 17013-2896
,$1,000.00 1999-2000
TERMS AND COII®/TIONS:
(Any backeoed nitre or para~aplt mtay be trrdtrded at optkn otirsttlartlonJ
APPLICABLE LAW • The temp of fhb rate and arty dbbunements made undo this note shall be Irrterprotad b accordance with Part E of Title N of the Higher
Education Aet of 2965. s amended (herelnaftu called the Act). u Mrell s Federal regulatbro blued under the Aet. AU surrr advanced undo fhb note arc sub)ea to the
Act and Federal rcgubuons Issued undec the Act.
REPAYMENT - I am obligated to repsy the prhtclpai and the interest that accrues on K to the above-named Wtitutbn (herelrtaRer oiled the school) over a pulod
beginning 9 months (or soorur u I am a lea than ahalf-time borrower) aftu the date I ease to be u lest a t~lt-time student at an ]mtkutbn of hlgMr eduction or a
eompuabk xhooi otttskie the Uniccd States approved by the United Sates Secrcury ~ Eduettwn (-KreUUtter ailed the Secretary) and ending 10 years bau, antes I
request in wrkbtg that my repayment period begin sooner. I understand that the school wW report the amount of my butalhnent payments. abrtg with the amount of fhb
ban to a rratlorrai credit burcw. Interest on fhb kran shat! accrue from the bgbtnbtg of the repayment period. MY repayeerertt period may be ahortar than 10 yeas u I am
required by my school to malts nsintentun monthly paymertn. Upon my written request my rcpayrrtsnt period may be extended during periods of deferment. hardship. or
forbearantx and i may make grsdtrated brtaumeraa >n aceordance with • arhedule approved by the Secretary. I wiu make my buraunura paymeras in equal monthly.
bimonthly or qusrtedy Urtallmeras s detarmbud by the xhool. The school may round my bunWnent psyment to the next highest mrsklpk of 25. [I will make s
minimum monthly repaynrutt o[ 340 (or S30 U I have outstanding Federal Perkins kerns made before October 1,' 1992 that Included the S30 minimum payment option)
in accordance with the Mtnbnum Momhly Paymera Section of the Terms and Conditions corrairrcd on the reverse side of fhb document.]
LATE CHARGES -The school will impose late eharyes U I do not make a scheduled payment when due or u I tail to submit to the school on or before the due date of
the payment. a properly documarted written rpuest that I quallt~ fm sty of the torbeaeanee, tleferrrurtt or eanallatiorr bertetits s described below. No late charges may
exoced 2096 of my morrhly, bfmonehly or quarterly payment. The school may add the late charges to prbidpal the day after the xhedtrkad rcpaymertt wes due or include
it with the next seltedtrkd repayment after I have received notke of the charge, scut such none b sent before the next brtallmera b due.
REQUESTS FOR DEFERMENT, CANCELLATION OR FORBEARANCE • To mews determerrt, aneelLtton, or forbearance benefiu, I must make a written request
to the school and must submit to the selrool any doeumentatlon the xhool requires to prove my ellgibWty for these bertefln. I sm respomtbk: for submKUng the
appropriate requem on time, and I may lose mY benefits if I fall to file my request on time.
DEFAULT - If 1 Pail to make a scheduled payment when due; if 1 fall ro submit to the school, on or before the due date of a sehcdukd payment. documentatbn that I
qualify for a dafernunt, tarreellatbn. or forbearance; or if I fall to comply with the terms and eortditioru of fhb prombary note or written repayment agreement, the
xhool may. at its option, declare rrty ban to be b ddauh and may aeoeluate my loan (deertstd ittretedtate paymutt ~ the etrire unpaid balance of the kwr, irteluding
principal. irrerest. late charges, and couectbn costa). The school. and the Secretary, if my loan b aaipud to the SetYetary tw colleetfort, dteit dbcloes to crcdU bureau
organtatloro that I have defsuhcd and all other rclevara loan htformatton. I will kite my right ro defer paymerrs anti my right to forbearance iE I default on my hart. I
wttl lose my right to recewe cartoellatiorr benelhs for service that b performed after the date the school aeakueted the loan. I wIU be lneligibk for any ttrrthu fedual
student firrartelai assistance authotiaed under the Act tmtll I make srrangemena that are sttiafacwry ro the xhool or Ne Sensory to repay my losn.
CHANGE OF STATUS - I wlll inform the school of any change in my creme. sddresa, telephone number, Social Securky numbu, or driver's lleerue number.
ASSIGNMENT -This note may be assigned by the school only to the United States. The provbbns of this rote that rekue to the school shall where appropriate relate to
the assignee.
PROMISE TO PAY: I promix to pay the school, oc • subsequent holder of the Promwory Note, the sum of amount(s) adveneed to me undo the tams of this Note, plus
irnercu and other fees whkh may become due s provided in fhb Note. I prombe ro pay aU resombk collection costs, including attorney fees and othu charges,
rtecmary for the collection of any amottra rat paid when due. I will not sign fhb Note before reading It, Including the provbbns on the reverse side. This lean hs been
nude co me without security or endorsement. My signature certittes I have resd, understand, and sgree to the temu and conditions of fhb PromWory Note. THIS IS A
LOAN(S~ THAT MUST BE R-+D'" ~
EXHIBIT ~~D"
FEDERAL PERK/NS LOAN
PROMISSORY NOTE - ~
1. Name (last, first, middle inidaq and 2. Soda) Security Number
Permanent Address (street, city, state, zip code) r
~
_ d
~O~ ~
Vi nG~s~~ 3. Date of Birth
~0 5 C/ ~ r k S-~ - a. Area Code/Telephone Number
`r'h r~~ l~A- i 8 s ~ Z _ - ~
5
Dritrer's Li
N
b
.
cense
um
er (list state abbreviatbn first)
6. School Name de Address (street, dty, state, zip code) 7. Borrower Status 8. Interest Rate
Di,~Cinson Co]1iec~e _-_- -_-- r~t~aralerra«~eranr Ot.as_ttrrt_Irr-Urns 59'0
P.O. Hox 1773 9. Loan Amount: 10. Loan period
C.a1c1i.sle, PA 17013-2896
~~ , OO 00 - O 1
errs Anrv con+omavs:
[Ary brarJcebd elute «pusp~eph very be inrarded ae option otirestltution)
APPLICABLE LAW -The tercet of this note and easy dnbuesernenn reside under this note shell be interpreted !n accordance with Part E of Tick N of the Higher
Education Aa of 1965, a arexrded (teeroirssher cdkd the Act), as well a Federal reguVttom issued under the An. All sums advanced under this note are subJett to the
Act and Feder! regulatbns issued under the Act.
REPAYMENT - 1 acre obligated to repay the prlttcipd and the Interest that atxrues on it ro the above-named irrt(tutfon (hereinafter ealkd the school) over a perbd
beginning 9 months (or sooner u I am a ids than • half-time iwrrower) slier the date 1 case to be at kart a hdf--time studerrt at an Lestitutbn of higher education «a
compuabk xleool outside the United Seta approved by the United Seta Secretary of Educatbn (hereYrRer tailed the Secretary) and erdierg 30 ysan kter, unless I
request N wrk4eg that my rvpayrrrnt perbd begin sooner. I understand that the xhool will report the amount of mY Irrntiment psyeesaw, along with the amoum of t)rls
loan to a natbrri cred# bureau. lnter+ut on ehn loan shall accrue from the bsginnbeg of the repaymemt period. My repayment perbd msy be sle«ter than 10 year u I am
nqulrod by my school to make minimum monthly paymsnn. Upon my written roquat my rcpsyrneret Period may be extended duetng perloda of detereerent, hardship, or
forbearance and I may make graduated irrWineents in xcordatecs with a sclyduk approved by tlr Secretary. I wW make my Irrnlirrrnt payrrrnts In egad monthly,
bimonthly «quarterly irrtallmerss a determined by the xhool. The school may round my irasta!]rteaet payment to the pact highest multiple of S5. (I vvW make a
minimum monthly repayment of 540 (« 530 LL' I have outstanding Federal Perkins hero made before October 1,' 1992 that included the 530 minimum payrrrnt optbn)
in accordance with the Mwrnum Monthly Payment Sectbn of the Terms and Condltbro coruairrd on the reverse side of thh document.)
LATE CHARGES -The school wW impose late eMrga !f I do not make a sehedukd payment when due or U 1 fag to submit to the school on or before the due date of
~ WY~nt. a Properly dxurerepted written request that I qudlly for arty of the t«barance, defermera «careeellatlon benelles a daaibed below. No lace charges may
ttxceed 2096 of my monthly, bimorultly ar quarterly payment. The scleool may add the late charge to prlnsipd the d.y aRer the xhedukd repayment was due or include
it with the next xheduled repaynrnt atbr 1 have received ratlce of the charge, and such nonce b sam batore tlr next irotagmam 4 due.
REQUESTS FOR DEFERMENT. CANCELLATION OR FORBEARANCE - To receive determem, canceWtlon, or f«beararxe bettettn. I must make a wruten request
to the xhaot and must submit to the school any documentatbn the school require to prove my ellglbWty for these benefits. I am responsible for submitting the
appropriate requests on time. and I may lose my benefln if 1 fag to fge my request on time.
DEFAULT - If I fail to make a xhedukd payment when due; u I fag to submit to the school, on or before the due date of a xhedukd paynxm, documentation that I
gwiffy for a deferment, caneeilatbn, or forbearance: or if I fag to comply wiN the terms and conditbrr of this promissory note or wrlttsre repayment agreement. the
xhool msy, at its option, declare my ben to be In default and may aexxlerate my ban (demand immedute payment of the entire unpaid balance of the loan, ireeluding
principal. Interest, kce charges, and collection costs). The school, and the Seereury, if my loan b aeigrrd to the Secretary for colleetbn, shag dlxlose to credit bueau
organisatbns that 1 hm defaulted and all other relevant loan inforrrtatbn. I wW bee rrry right to defer payments and my right to forbearance !f I detault on my ben. I
wgl lose my right to receive earaegatbn benefits foe aervlce tMt b performed aRer the date the school aeeelerated the bare. I wgl be inellgibk for any further fedavi
studem flrear-clal asistareee authorised under the Act untg I make arrangements that arc sawhctory to the xhool « the Secretary to repay my loan.
CHANCE OF STATUS - I wgl Inform the arhool of any change !n my name, addrvs~, telephone number, Social Security number, or driver i llcenx number.
ASSIGNMENT -This note may be assigned by the school only to the United States. The provni«r of thb note that relate to the school shall where appropriate relate to
the assignee.
PROMISE TO PAY: !promise to pay the xhool, or asubsequent holder of the Promgaory Note, the sum of amount(s) advanced to me under the terror of thb Note, plw
interest and other tta whkh may become due a provided !n this Note. I promise to pay ail teasortable collection corn, including attorney fed and other charges,
ruedsary for the collectbn of any amount rat pdd when due. I wW not sign thn Note before evading k, Including the provbbns on the rvverx side. This ban hat been
made to me without security or erxbrseerrmt. My signature eertifles I lave read, understand. and agree to the [ernu and conditions of thb Promissory Note. THIS IS A
LOAN(S) THAT MUST BE REPAID
~' f~ ~ - -.. I ~,
. , ./
. ~ ~ I
Borrolylaer's Sit~riature ~ Date:
1
LSUM ACCT 174 709 246
i
00 SSN 174 70 9246 SRC D OPTION
SEL
NAME VINANSKY, JOLT J _
570 489 3939 GOOD BORR 08 28 03 MAIL
233 GRAVITY AVE "
CTY/ST OLYPHANT PA ZIP 18447 2073
SELECT =______~ 01 PRIM GOOD DOM
PG/SQ/ST: 00273 09 49 *TOTALS*
PL/FQ/RT: I M 5.000
TAJM/GRC: N O N N 009 .
' LOAN AMT: 4,100.00 .
i PRI BAL 1,306.60 4,100.00
j PRI PAID: 2,793.40 ' 1,306.60
' INT PAID: 976.31 • 2,793.40
•
FEE PAID: 108.02 ~ 976.31
LST PAID: 04 13 09 ~ 108.02
LST AMT 150.00 .
NEXT DUE: 09 13 11 150.00
i CURR DUE : 4 4 .4 9 - __---
' PAST DUE: 1,353.98 44.49
FEES DUE: _ ~ - 1,353.98
TOTL DUE:
1,398.47 .00
INT ACCR: 151.08 ~ 1,398.47
PAYOFF
1,457.68 . 151.08
SC/DI/CI: N .1790 ~ 1,457.68
h i nnan amCa~hi~l-~f i nnna- ~'I
Ai~cl S. 2~'1'I 1~:~,'~:4~ PM
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
Sally Heckendo ,Bursar
F:\F[LES\ClientsV619Diclonson College\761ACo11ectionaV619C.CurrentV619C.394 Vinansky\7619C.394.com