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F; IFILESIDA T AFILElDickinsonCollege7619\Collections\Current\296-coml, wpd
Created: 4/28/03 I 54-03 PM
Revised- 12/2/043:46 to PM
7619c_2961LC2
DICKINSON COLLEGE,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 04- t.r..~ J.- COLC-TCVt-t
CNIL ACTION-LAW
DAVID W. SHINEMAN,
Defendant
JURY TRIAL OF TWELVE DEMANDED
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 MAYBE 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
f"1
M
Dated; December 2, 2004
By
David R. Gallowa ,
1. D, Number 87326
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 04-
CIVIL ACTION-LAW
DAVID W. SHINEMAN,
Defendant
JURY TRIAL OF TWELVE DEMANDED
COMPLAINT
AND NOW, comes Plaintiff Dickinson College by and through its attorneys, MARTSON
DEARDORFF WILLIAMS & OTTO, 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, Carlisle,
Cumberland County, Pennsylvania 17013.
2. Defendant David W. Shineman is an adult individual with a last known address of
R.D. 3, Box 64, River Run, Queenstown, Maryland 21658-9779.
3. On or about November 6, 1987, Defendant entered into a Promissory Note - Federal
Perkins Loan Program (Note #1) with Plaintiff for the financing of$1,300.00 plus interest and costs
by Defendant on his own behalf, for educational services and benefits at Plaintiff s institution. A
copy of Note #1 is attached hereto as Exhibit "A."
4. On or about April 8, 1988, Defendant entered into an additional Promissory Note -
Federal Perkins Loan Program (Note #2) with Plaintiff for the financing of$950.00 plus interest and
costs by Defendant on his/her own behalf, for educational services and benefits at Plaintiffs
institution. A copy of Note #2 is attached hereto as Exhibit "B."
5. On or about December 14, 1988, Defendant entered into an additional Promissory
Note - Federal Perkins Loan Program (Note #3) with Plaintiff for the financing of$1,500.00 plus
interest and costs by Defendant on his own behalf, for educational services and benefits at Plaintiff s
institution. A copy of Note #3 is attached hereto as Exhibit "c."
6. On or about December 15, 1989, Defendant entered into an additional Promissory
Note - Federal Perkins Loan Program (Note #4) with Plaintiff for the financing of $2,000.00 plus
interest and costs by Defendant on his own behalf, for educational services and benefits at Plaintiff s
institution. A copy of Note #4 is attached hereto as Exhibit "D."
7. Note #1, Note #2, Note #3, and Note #4 are funds created under Part E of Title N 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 total principal for Note #1, Note #2, Note #3, and Note #4 is $5,750.00.
10. Note #1, Note #2, Note #3, and Note #4 grant Plaintiff reasonable collection and
attorney's fees which Plaintiff has calculated to be $862.50.
11. As of September 30, 2004, the principal and interest due and payable by Defendant
to Plaintiff was $8,078.04, plus interest accruing thereafter at $0.72 per day.
12. As of September 30,2004, the outstanding balance of$8,078.04 represents the total
and actual overdue value of the financing provided to Defendant under Note #1, Note #2, Note #3,
and Note #4 for which Defendant has yet to pay.
13. Plaintiffhas fulfilled, performed and complied with all obligations and conditions of
Note #1, Note #2, Note #3, and Note #4.
COUNT I
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 Note #1, Note #2, Note #3, and Note #4 by failing to pay the amounts financed therein.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of$8,078.04,
plus interest accruing at $0.72 per day from September 30, 2004, collection and attorneys' fees in
the amount of $862.50 and costs of suit.
COUNT II
IN QUANTUM MERUIT
16. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 15 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.
19. As of September 30,2004, the total amount by which Defendant has become enriched
is $8,078.04, plus interest in the amount of$0.72 per day from September 30,2004.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of$8,078.04,
plus interest in the amount of$O. 72 per day from September 30,2004, collection and attorneys' fees
in the amount of $862.50 and costs of suit.
F WILLIAMS & OTTO
Date: December 2, 2004
By -
David R. Galloway
LD. Number 87326
Ten East High Street
Carlisle, P A 17013-3093
(717) 243-3341
Attorneys for Plaintiff
~
DICKINSON COLLEGE
CARLISLE, PENNSYL VANIA 17013
PROMISSORY NOTE
PERKINS LOAN PROGRAM
I, David W. Shineman promise to pay 10
Dickinson CoUege (herein after caUed the Lending Ins<itution) localed at Carlisle, Pennsylvania the sum of the amounrs that are advanced to
me and endorsed in the Schedule of Advances Set fOrth below. I promise to pay all anorney's fees and other reasonable collection costS and
charges necessary for the collection of any amount not paid when due.
I funher understand and agree that:
I. GENERAL
(1) AODlicable lAw. All SIlltlS advanced under this note aR drawn Crom a fund c_led under Part E oC'TItle IV oC Ihe Higher FAucalion Acl of 1965. as
amended, heRinaCler called lhe ACI, and aR subject 10 Ihe ACI and Ihe Federal Reaulalions i..ued under lhe Act. The lerms of this nole shall be inrer-
pRted in accordance with the Act and Federal Reaulations, copies oC which are to be kept by the Lending Institution.
(2) Proceduru Cor Receivinl[ OeCerment or Cancellation. I understand that in order to receive a deferment or cancellation, I mlllt request Ihe deCerment or
cancellation in writing from the Lending Institulion, and mlllt submit 10 the Lending Instilution any documenlalion required by lhe Lending In,rirution [0
prove lhall qualify for the deferment or cancellation. I funher understand that if I am eligible for deferment or cancellation under Arllc\es VI through XI. r
am Rsponsible for ,ubmitling lh. appropriat. requ.st, on lime. I funh.r und.rsland thaI I may lose my def.rm.nt and canccollation benefils if ( fail to file
my RqUest on time.
11. Il'ITEREST
Inlerut,hall accrue Crom the beginning of th. Rpaym.nt p"riod and shall be atlh. ANNUAL PERCENTAGE RATE OF FIVE PERCENT (5%) on
the unpaid balan.., except that no interest shall aecNe during any deferm.nl p"riod described in paragraph VI(I).
Ill. REPAYMENT
(I) I promise to Rpay the principal and the interesl which accrues on it to the Lending Inslitution over a p"rlod beginning 9 months after the dale I cease to
be allust a half-lime studenl al an inslilution of higher educalion, or al a comparable inslilUlion oulside lhe Uniled Stales approved for this purpose by the
United Slales SecRlary of FAucation (heRinafter called the Secrelary), and ending, unlw paragraphs 11I(4), 11I(5), 11I(7), or VI(I) applies, 10 years laler.
(2) Upon my wrill.n Rquesl, lhe repaymenl p"riod may stan on a dale earli.r than th. 0,,", indicaled in paragraph 11I(1).
(3)(A) I promise 10 repay Ihe principal and inleRSI over Ihe course oC the Rpaymenl p"riod in "'Iual monlhly, bimonthly or quanerly installmenls .. deter-
min.d by the Lending Institution. I understand that iC my monthly payment for all the loans made to me by the Lending Institution is not a multiple of $5.
rhe Lending Institution may fOund lhat payment to lite next highest dollar amounlthat is a mulliple of $5.
(8) Notwithstanding paragraph 1II(3)(A), upon my written requesl, repayment may be made in graduated inslallmenrs in accordance wilh a schedule ap-
proved by lite Secretary.
(C) The Lending IlIStitution shall attach the'schedule of repaymenlS and tlte ",hedule will become pari of the note.
(4) Notwilhstanding paragraph. 11I(1), if I qualify as a low.income individual during Ihe Rpayment p"riod, Ihe Lending ItuirilUlion may, upon my wrillen re-
quest, extend lhe Rpayment p"riod for up to an addilionall0 years, or adjll$l any repaymenl ",hedule 10 reflect my income, or both.
(5)(A) If the monthly rate that would be established under paragraph 1II(1), or lhe total monthly repayment rate of pnncipal and interest on all my Perkins
Loa"" including rhis loan, is I.... Ihan 530 p"r month, I ,hall repay Ihe principal and interesl on Ihis loan at lhe rale of S30 p"r month (which includes both
principal and interest).
(5)(8) If I have RCeived Perkins LoaIlS Crom other instilutions and lhe total monlhly repaymenl nte On tho6e loans is I... than 530, the 530 monlhly nle e,-
lablisheel under ,ubparagraph III(S)(A) is the rate I pay on all my outslanding Perkins Loans and is nor in addition to Ihe amount I pay on Ihose olher loans.
The amount oC my monrhly Rpayment rate attributable to this loan is the amounr which Rpresenrs lhe diffeRnce between 530 and lhe monthly nles I must
pay On my other Perkins Loans.
(6) The Lending Institution may p"rmit me 10 pay less than the nte of S30 p"r monlh for a p"riod of not mOR Ihan one year where necessary 10 avoid
hardship 10 me unl.... that action would extend rhe Rpaymenr p"riod in paragraph 11I(1).
(7) The Lending Institution may, upon my wrillen request, reduce any scheduled Rpayments or extend the repayment p"riod indicated in paragraph 1lI(1),
iC, in its opinion, extraordinary circumsl8nces sllCh as prolonged iIInw or unemployment, pn:vent me from making the scheduled repayments. How<:ver, in-
teresrshall conlinue to aCCJUe.
IV. PREPAYMENT
(I) I may, ar my oplion and without p"nalty, prepay all or any part o( lhe principal, pi... the accrued inteRSttheRon. ar any lime.
(2) Amounts I repay in the academic year in which th. loan...... made will be used to redllCe the amount of the loan and will not be considered a pRpayment.
(3) If 1 repay maR lhan the amount due for any installmenl, lh. excess will be used 10 prepay principalunlca I designate il .. an advance paymenl of the
next regular insrallment.
V. DEFAULT
(1) The Lending Institution may, at its option, declaR my loan to be in default and may demand immediate payment of lhe enliR unpaid balance of the
loan, including principal, inreml, and late charges if .
(A) I do 1\01 make a sclteduled payment when it is due, and
(8) I do not submilro the Lending Instilulion on or beCore the dale on which paymenl is due, documenlalion lhatl qualify for a deferment or cancellation
described in Articles VI, VII, VIII, IX; X, or Xl o( lhi, agreement.
(2) I understand th.t if I deCault on my loan repayments, the Lending Institution may disclose that I have defaulted, along with other relevant informalion, to
cRdit bureau orpnizations.
(3) Funher, I understand thar i( I defaull on my loan Rpaymenl and the loan is sent to the Secretary (or colleclion, the Secrelary may disclose thaI I have
defaulted, along with other Rlevant information, to credit bureau organizations.
(4) I understand Ihal if Ihe Lending In'titution a""lerales the loan under paragraph V(I), I will lose my cancellation and deferment benefil' for service p"r-
formed a(ler the date lhe Lending Institulion .cceleraled the loan. .
(5) I underst.nd that f.ilure to pay this obligation under lhe terms agreed upon will pn:vent my obtaining additional student financial aid aulhorized undel
'TIlle IV 0( the Higher FAucation Acr of 1965, as amended, unlil I have made arrange_nlS which. re salisfaclory to lhe Lending Institution or the SecRtary
regarding lhe repaymenl of the loan.
VI. DEFERMENT
(1) Interesl will not.CCt'IIe, and installments o( principal need not be paid -
(A) While I am enrolled and in attendance .. at le..t half.time sludent at an inslirution of higher education or al a comparable inslitution oUlside lhe
United States approved for this purpose by the Secretary;
(B) For a p"rlod oC three (3) yeats during which I am -
(i) On (ull-lime active duty as a member of Ihe Anned Forces of lhe United Stales (Anny, Navy, Air Force, Marine Corpo;, or Coast Guard) or the Na-
tional Oceanic and Atmospheric Administration Corpo;, or .. an officer on full.time aClive duty in the Commissioned Corpo; of the United St.les Public
Health Service,
(ii) In service .. a volunleer under Ihe Peace Corpo; Acl,
(iii) A volunteer under the Domestic Volunteer Service ACI of 1973 (ArnON programs),
(iv) A Cull-time volunteer in a lax-uempt orpnization p"rforming service comparable 10 the service p"rformed in rhe Peace Corpo; or under the Dome,.
tic Volunleer Service Act of 1973, or
(v) Temporarily totally di..bled as established by an affidavit of a qualified phl"ician. or unable to secure employmenl because J am providing care re-
quired by a dependent who is so disabled;
(C) For a p"riod nol in excess of rwo (2) yealS after J rece,ve a baecalauRate or professional degree during which time I am serving in an inlemshlp which
is required in order that I may receive professional recognition required to b~gir1 my protesslO0'l3J t?"'3cuc(: Or Sc:lVJ(:e. or :.ervtng IR an Internship or residency
p"'gra'" leading to a depu o. cenificate awarded by an institution of higher education, a hospital or a heallh care facility that ofCelS postgraduate lraining:
(D) f'CJr a p"riod not in excess of one (I) year during which I as a mother of preschool age children, who h.. enteRd or reentered the work force, am
being paid at a rate which docs not exceed $1.00 above the minimum hourly ""'ge established by seclion 6 of the Fair Labor Slandards Act o( 1938:
(E) For a p"riod not in excess of six months if .
(i) I am pRgnanl, caring for my newborn baby, or caring for a child immediately afler he or she..... placed with me through adoption and I am nOl at-
lending an eligible institution of higher education or being gainfully employed during the six month period, and
(Ii) I..... enrolled.. alleasl a half-time student al an eligible institution wilhin six months of the first day 0( that p"riod; and
(F) During a ,ix (6) monlh p"riod following the expiration of any defermenr provided in paragraphs VI(I)(A) through VI(I)(E).
(2) The Lending Institution may, upon my wrillen request, defer my scheduled repayments if it determines that lhe deferment is necessary to avoid a linan.
cial h.rdship Cor me. Inrerest, however, will conlinue to accrue
VII. CANCEllATION FOR TEACHING
(1) I am entitled to have up 10 100 p"rcent of lhe amount of this loan plu, the intereslthereon cancelled if lunden.ke service _
(A) As a (ull-rime teacher for a complele academic year in a public or olher nonprofil el.mentary or secondary school whicb is in Ihe school district oC a
local educational .g.nty which is eligible in such year of service for funds under Chapler I of lhe Education Consolidarion .nd Imp1'lMlmenl Acl of 1981, ..
amended, and which h.. been designaled by rhe Secrelary (after con,ultation with each Sl.te Department of FAucation) in accordance wilh lhe provisions of
section 465(a)(2) o( the Acr as . school wilh a high concentration of sludents from low-income families. An official Directory o( designated low.ioco_
SChool, is published annually by the Secretary.
(8) As a full-lime teacher of handicapP"d children (including mentally retarded, hard of hearing, deaf, sp"ech and lanauage impaiRd, visually hand-
icapP"d, seriously emotionally disturbed, orthop"dically impaired, children with specific 'earning disabilities, or other health-impaired children, who by reaSOn
ExhilHt "A"
-y
thereof require speci.l educ.tion .nd rel.ted services) in. public or otller nonprofit element.ry or second.ry school system.
(2) This loan will be c.ncelled .t the following rates:
(A) IS pereent of Ihe tOI.1 princip.1 amount of the loan plus inleresl on Ihe unpaid b.l.nce will be cancelled for tile firsl and second complele .cademlc
ye.rs of th.t teaching service,
(B) 20 percent of the lotal principal .mounl plus interest on the unpaid b.l.nce for Ihe Ihird .nd founh complete .cademic ye.rs of th.t leaching service.
(e) 30 percent of the total principal .mount plus interest on the unpaid b.l.nce for the fifth complete .cademic year of Ih.t teaching service.
VIII. HEAD START CANCEu.ATION
(I) I.m entitled 10 h.ve up 10 100 pereenl of the amount of this loan plus the interest Ihereon cancelled if I undertake service as . full-lime slaff member in
a Head St.rt program if .
(A) Th.t Head St.n program is operaled for. period which is comparable to . full school year in Ihe locality, .nd
(B) My sal.ry is not more th.n the sal.ry of. comparable employee of Ihe loc.l education.l .gency.
(2) This loan will be cancelled .t the rate of 15 pereent of the total principal.mount plus interest on the unpaid balance for each complete ..,hool year or lhe
equivalent of service in . Head Stan program.
(3) Head St.rt is. preschool program carried out under the Head St.rt Act. (Subch.pter B, Ch.pter 8 of ntle VI of Pub. L 97-35, the Budget ReconcIlia-
tion Act of 1981; formerly authorized under section 222(.)(1) of the Economic Opportunity Act of 1964).
IX. MILITARY CANCELLATION
(1) I.m entitled to h.ve up to SO percent of the principal .mount of lhis loan plus lhe inleresl thereon cancelled if I..NO as a member of the Armed Forces
or the United St.tes in .n .re. or hostilities th.t qualifies for special pay under ..etion 310 of Title 37 of the United St.tes Code.
(2) This loan will be cancelled .t the rate of 12 1/2 percent of IlIe tot.l principal amount plus interest on tile unpaid b.lance for each complete year of svrh
service.
X. PEACE CORPS CANCEu.ATION
(1) I.m entitled to h.... up to 70 percent of the .mount of this loan plus the interest thereon cancelled if I undertake service--
(A) As. volunteer under the Peac:c Corps Act; or
(B) As. volunteer under the Domestic Volunteer Service Act of 1973.
(2) This loan will be cancelled at the following rates:
(A) 15 percent of the total principal .mount of the loan plus interest on the unpaid b.l.nce will be can"lIed for the first .nd second _""'-month period
of volunteer service:
(B) 20 percent of the total principal .mount of the loan plus interest on the unpaid b.l.nce will be can"lIed for the third .nd fourth !We""'-month period
of volunteer service.
XI. DRAm AND DISABILITY CANCEu.ATION
(1) In the ClIent of my de.th, the tolal.mount owed on Ihis loan will be c.ncelled.
(2) If 1 become tot.lly .nd perm.nently disabled after I receive this loan, Ihe lending Institution will c.ncel the 101.1 .mount of Ihis loan.
XlI. CHANGE IN NAME, ADDRESS, TELEPHONE NUMBER AND SOCIAL SECURrn' NUMBER
I am responsible, .nd .ny endorser is responsible, for infonning the Lending Institution of .ny ch.nge or ch.nges in n.me. .ddress, telephone number or so-
ci.l security number.
XIII. LATE CHARGE
(1) The Lending Institution may impooe .I.te ebatge if-
(A) I do not m.ke . scheduled payment when it is due, .nd
(B) I do not submit to Ihe lending Institution on or before the d.te on which payment is due, document.tion Ih.t I qualify for a deferment or cancellatIon
described in Articles VI, VII, VIII, IX, X. and XI of Ihis .greement.
(2) No chatge may exceed !Wenty (20) percenl of my monlllly, bimonthly or qu.nerly pa)'1llent.
(3)(A) The Lending Institution may-
(i) Add the late ch.tge 10 Ihe principallhe day .fter the scheduled repayment.... due; or
(ii) Include it with the IlCXl scheduled repayment .fter I have received notice of the 1.le ch.tge.
(B) If the Lending Institution elects to add the assessed ch.tge 10 the outstanding principal of Ihe loan, it must so inform me before the due dale of lhe
next inst.llment.
XIV. ASSIGNMENT
(I) This note may be assigned by the Lending Insti,tution only to .
(A) The United States;
(B) Another institution upon my transrer to lbat instilution if Ih.t institution is participating in this program; or
(e) Another institution .pp""",d by the Secretary.
(2) The provisions 01 this note th.t rel.te to the Lending Instilution sh.lI, wllere .ppropri.te, rel.te to .n assignee.
XV. PRIOR LOANS
I hereby certify th.tl h.... listed below .11 of Ihe Perkins Loans I h."" obt.ined .1 other instilutions. (If n~ prior loans lIave been received, state "None.")
SCHEDULE OF PERKINS LOANS AT OTIlER INSTTlUI10NS
AMoum
DATE
NAME OF INSTTlUI10N
1.
2.
3.
4.
XVI. SCHEDULE OF ADVANCES
The following amounts were .dvanced to me under this loan .greement on the dales indicated:
AMoum
1. $650
2. $650
DATE
7/87
12/87
SIGNATURE2F B RROWER
. f..
~f".tol' ,1/71''''''''
d.r#/ ~"'i1,:;1?c",~~
3.
4.
NOTICE TO BORROWER: DO NOT SIGN TIllS NOTE BEFORE YOU READ fT. TIlE LENDING INSTITUTION MUST SUPPLY TO
YOU AND ANY ENDORSER A COpy ZQF TIllS NOTE. (This note is signed as a scaled instrument.)
SIGNATURE .41MC/ ~?1..Nl"l<'- --1- Date I(/if' 19-12-.
Perm.nentAddress (Street or Box Number, City,SI.te, and Zip) -r'// /'t:till <II 4-. ~/~1'J/;~, ItO .,i./y.();'
Social Security Number (borrower must provide) . J ~ <' - Yip" - J' ([ d- Y.
The borrower .nd Lending Institution sh.1I exeeute this note without sec:urity .nd wilhout endorsement unless Ihe borrower is . minor .nd this nole would
not, under the law of the St.le in which the Lending Institution is located, cteale a binding obligation. Ir the borrower is . minor and this nOle would not
tllerefore, be legally binding, the Lending Iftstitution sball require a cosigner to this note:
SIGNATURE OF COSIGNER
Dale
19_.
Perm.nenl Address (Slreet or Box Number, City, St.te, Zip)
(20 U.S.C. t087dd)
(7/87)
Form.1 by lhe Nalion.1 Associ.tion of Student Financial Aid Adminlslnllorn.
DICKINSON COLLEGE
CARLISLE, PENNSYLVANIA 17013
PROMISSORY NOTE. PREVIOUS BORROWER
PERKINS LOAN PROGRAM (formerly National DIrect Student Loan)
I David W. Shineman _. promise 10 pay to
Dldkinson Col/e.e (herdn after called Ihe lendin, In5lilulion) Incalcd al ('arlisl.. Pcnn<vI\,:1niillhe SIII11 of Ihe amounU Ihal are advanced to
me and endorsed in the Schedule of Advances set fOrlh below. I promise'(I pay all ""mn,'Y" kcs and olher reasonable ,'ol/eelion cas IS and
cbaraes necessary for Ibe collection of any amount not paid when due. I funher unrlemand and agree that:
1. GENERAL
(1) ADDlicable Law. A1IIUJI\J advanced under Ihis nole are drawn from a fund moaled under Part B of nile IV or" Ihe Higller Educalion Act of 1965, IS
amended, hereinafter called Ihe Act, and are subject 10 Ihe ACI and Ihe Pederal Regula lions illued under Ibe ACI. The lenns of Ibis nole sball be inter.
preled in accordance wilh Ihe Act and Pederal Regulations, copies of which are to be kepi by Ihe Lendlnglnslilution.
(2) Procedures for Recelvin2 Defennenl 0. OIneell-,lon. I undersland Ihal in order 10 receive a derennenl 0. cancel/alion, I muSI requ.sI Ih. def.noenl or
canc.l/ation in writing rrom Ihe Lending Institution, and must submit to Ih. Lendinglnatitulion any documentation requir.d by the Lending Institution to
prove Ihall qualify ror the d.f.nnenl or cancellalion. I further und.rsland Ihal if I am eligible ror deferm.nl Or canc.llalion under Articl.s VI through X, I
am responsible for submitting Ihe appropriale requesls on time. I further undersland Ihall may lose my defermenl and cancel/ation benefits if I fail 10 fiI.
my requ.st on lime.
II. INI'EREST
Interest shall accrue from Ihe beginning of Ihe repayment period and shal/ be allhe ANNUAL PERCENTAGE RATE OF FIVE PERCENT (5%) on
Ihe unpaid balance, exc:epllhat no inlerellshal/ accrue during any defennenl period described in paragraph VI(I).
Ill. REPAYMENT
(1) I promise 10 repay Ihe principal and Ih.. int..resl which accruu on it to Ihe Lending Institution over a period beginning 6 months arler the dale I c.ase 10
b. atl.ast a halr-lim. slud.nt at an institution of higher education, or at a comparable instilution oulside lh. United Stales approved for Ihis purpose by th.
Uniled Slates Secretary of Education (hereinafter call.d th.. Secretary), and ending, unless paragraphs 11I(4), 11I(5),11I(1), or VI(I) appli.s, 10 years later.
(2) Upon my written request, Ihe repayment period may slart on a date earlier Ihan the on. indicaled in paragraph 11I(1).
(3)(A) I promise to repay the principal and interesl over Ihe course of th. repaymenl period in equal monthly, bimonthly or quart.rly installm.nts as deter.
mined by Ihe Lendinglnslitulion. I undersland thai if my monlhly paym..nt for alllh. loans made 10 me by the Lending Institution is not a multipl. of $5,
Ih. Lending Inslitulion may round that paym.ntlo the n.xt highest dollar amount thaI is a multipl. of $5.
(D) Notwithstanding paragraph 1II(3)(A), upon my written requesl, repaymenl may be made in graduated inslallments in accordance with a schedule ap-
proved by Ih. Secretary.
(C) Th. Lending Institution shall attach the schedule of repaymenlS and th. schedule will become part of the note.
(4) Notwilhslanding paragraph 11I(1), if I qualify as a low-incom. individual during the repayment period, Ihe Lc:ndinglnstitution may, upon my wrillen re-
qu.st, ..Iend th. repayment period for up to an additional 10 years, or adjust any repaym.nt sch.dul. to ren.ct my incom., or both.
(S)(A) If Ihe monlhly rate Ihal would b.. eslablished under paragraph 1Il(1), or Ihe 10lal monlhly repayment rate of principal and interest on all my Direct,
Defense and P.rkins Loans inc'udinglhis loan, is less Ihan $30 per month, I shall repay the principal and inl.resl on this loan atth. ral. of $30 per monlh
(which includes both principsl and interesl).
(5)(D) If I have received DirecI, Def.nse and Perkins Loans from olh.r instilutlons and Ihe tOlal monthly repaym.nl rat. on Ihose loans is J.ss than $30, the
$30 monthly rat. .stablished unller subparagraph lll(S)(A) is the rate I pay on all my outstanding Direct, D..ren", and P..rkins Loans and is nol in addition
10 lh. amount I pay on those olh..r loans. The amounl or my monlhly repaymenl rate allribul.ble to this loan ;s the amounl which represents Ih. diff.renc.
between $30 and Ihe monthly rates I must pay on my other Di~t, Defense and Perkins Loans.
(6) The Lending Instilution may permil me 10 pay I.ss than Ih. rale of $30 per month for a period of nol more Ihan one year where necessary to av<>id
hardship to me unless Ihat,clion would extend the repaymenl period in paragraph 11I(1).
(1) The Lending Institution may, upon my writt.n requ.st, reduce any schedul.d ...paym.nts or ext.nd Ihe repaymenl period indicaled in paragraph lIl(l),
if, in its opinion, .xtraordinary circumstances such as prolonged illn.ss or un.mploymenl, p...venl m. from making the schedul.d repaym.nts. Howev.r, in-
lerest shall continue 10 accrue.
IV. PREPAYMENT
(1) I may, st my option and without penalty, prepsy all or any pan of the principal, plus the seeru.d interest thereon, at any time.
(2) Amounts I repay in the academic year in which th. loan was mad. will b. used 10 reduc.the amounl or lhe loan and will not be considered a prepayment.
(3) If I repay more than th. amount due for any installm..nt, th. e.eess will be used to prepay principal unless I designat.. it as an advance payment of the
next regular inslallm.nt.
V. DEPAULT
(1) The Lending Institution may, at its option, declare my loan to be in default and may demand immediale payment of the entire unpaid balance of th.
loan, including principal, interesl .nd lal.. charg.s if.
(A) I do nol make a sch.duled payment when it is due, and
(D) I do not submillo Ihe Lending Institution on or before th.. date on which paym.nl is du., documenlation thaI i qualify ror a d.ferment or cancellation
describ.d In Articles VI, VII, VIII, IX, and X of this agreement.
(2) I understand Ihatlf I default on my loan repaymenls, th. Lending Inslilution may disclos. thai I have defaulted, along with olher r.levanl information, 10
credit bureau organizations.
(3) Punh.r, I understand that if I default on my loan repaym.nl and the loan is sent to th. Secretary for eolleclion, tb.. Secretary may disclose th.t I have
deraull.d, along with olh.r rel.....nl infonnation, to credit bur.au organizations.
(4) I und.rstand that if the Lending Inslilution accelerates the loan und.r paragraph V(I), I will lose my canc..llation and d.ferment b.nefits for service per-
formed after Ihe dat. Ih. Lending Institulion acc.leraled Ihe loan.
(5) I understand Ih.t f.i1ure 10 pay this obligalion under Ihe t.rms agreed upon will prevenl my oblaining additional sludent financial aid authorized und.r
Title IV of Ihe Higller Education ACI or 1965, as amend.d, until I have mad. amngem.nls which are satisfaClory to Ihe Lending Institulion or lhe Secretary
regardinglh. repaym.nt of Ihe loan.
VI. DEFERMENT
(1) Interesl will nolaccru.., and installments of principal ne.d nol b. paid -
(A) While I am enrolled and in att.ndance as at least a half-time student al an institution of higher education or al a comparable institution outside the
Unit.d States approved for this purpose by the Secrelary.
(D) For a period of Ihree (3) years during which I am -
(i) On full-tim. aclive duty as a m.mber of Ihe Armed Forces of the United States (Army, Navy, Air Forc., Marine Corps, or Coast Guard) or an officer
on full.time active duty in Ihe Commissioncd Corps of the U.S. Public HeaUh Service,
(i1) 'in service as a voiuOle~r \nlU~r ,he P~4Il;C CA.~ A~:,
(ijj) A ""lunt.er und.r th.. Domestia Volunt..r Service ACI of 1973 (ACI10N programs),
(iv) A full-time voluntee. In a tax.....mpt orgsnization performing service eomparable to the service performed In the P.ac. Corps or under th. Dom.s.
lie Volunt.er Service Act of 1973, or
(v) Temporarily lotally disabled as ellablish.d by an affidavil of a qualified physician, or unabl. to secure employm..nt b..cause I am providing care ....
quir.d by my spouse who is so disabled,
(C) Fa. a period nol in excess of two (2) years after I receive a baccalaureate or professional d.gre. during which time I am serving in an internship which
is required in order that I may receive prof.ssionsl recognilion required 10 begin my prof.ssional praclice or s.rvic.; and
(D) Dc:ing a six (6) month peried I,,:lowing the expiralion at my def.rmenl in paragraph VI(l)(A) througb VI(l)(C).
(2) Th. Lending Institution may, upon my writt.n requ.st, der.r my sch.duled repaym.nts if it d.tennines that the d.ferment is n.e.....ry to avoid a finan.
cial hardship for me. Interest, however, win continue to accrue.
VII. CANCELLATION FOR TEACHING
(1) I am entitl.d 10 have up to 100 pIOtCent of the amount of this loan plus the inlerestlhereon cancelled if I undertake service.
(A) As a full.time t.ach.r for a complete academic year in a public or olh.r nonprofil elem.nlary or secondary school which is in Ihe school district of a
local .dueational agency which is eligibl. in such year of s.rvie.. for funds under Chapter I of th. Education Consolidation and Improvement Act of 1981, IS
amend.d, and which has been designal.d by the Secretary (after consullation with each Stal.. D.parlmenl or Educalion) in accordanc. with the provisions or
section 465(1)(2) of the Act as a school with 1 high concentralion of stud..nts from low-incom. families. An official Directory of designaled low-ineome
schools is published annually by Ihe Secretary.
(B) As a full.lim. teacher of handicapped children (including mentally relarded, hard of hearing, d.af, spe.ch and language impaired, visually hand.
icapped, seriously .motionally disturbed, orthopedically impaired, children wilh specific learning disabilities, or other health-impair.d children, who by reason
Ihereof require special education and re'al.d services) in a public or other nonprofit el.mentary or secondary school system,
(2) This loan will be canc.lled at the following rales:
(A) IS perc.nt or the total principal amount of lh. loan plus interest on the unpaid balance will be canc.ll.d for the first and second complete acad.mic
years of thatt..ching servic.,
(B) 20 pereent of the total principal amounl plus inl.rest on Ihe unpaid balance ror the third and rounh complete academic years of that t.aching service,
and
(C) 30 percent of Ih. total principal amount plus int.resl on the unpaid balance for lhe fiflh compl.l. academic year of th.tteaching servic..
Exhibit "B"
VIU. HEAD Sf ART CANCELLATION
(1) I am entitled to have up to 100 percent oC the amount of this loan plus the interest thereon cancelled IC I undertake service as a Cull.tlme staff member in
a Head Start propm If"
(A) That Head Start prognm Is openlled for a periOd which Is compal'lble to a full school year in the locality, and
(B) My salal)' is not mon: lhan the salal)' of a c:ompal'lble employee oC the local educational agency.
(2) This lOin will be cancelled at the l'Ite oC 15 percent oC lhe total principal amount plus interest on the unpaid balance for each complete school year Dr the
equivalent of service in a Head Start prognm.
(3) Head Start Is a preschool program tlrried out under the Head Start Act. (Subchapter B, Chapter 8 of Tille VI of Pub. 1. 97-35, the Budget Reconcilia..
tion Act of 1981; formerly authorized under section 222(a)(l) of the Economic Opportunity Act of 1964).
. IX. MILITARY CANCEUATION
(1) I am entitled to have up to SO percent of the principal amount of this loan plus the inten:st thereon cancelled if I serve as a member of the Armed Forces
of the United States in an an:a of hostilities that qualifies for special pay under section 310 of Title 37 of the United States Code.
(2) This loan will be tlncelled at the l'Ile of 12.1/2 percent or lhe total principalamounl plus interesl on lhe unpaid balance for each complete year of such
service.
X. DEATIf AND DISABILITY CANCELLATION
(1) In lhe event oC my death, the totatamount owed on this loan will be cancelled.
(2) If I become totally and permanenlly disabled aCter I receive this loan, the Lending Institution "";11 eancelthe total amount or this loan.
XI. CHANGE IN NAME, ADDRESS, TELEPHONE NUMBER AND SOCIAL SECURITY NUMBER
I am responsible, and any endorser is responsible. Cor informing the Lending Institution of any change or changes in name, address, telephone number or so-
cial security number.
XII. LATE CHARGE
(1) The Lending Institution mil)' impose a late eharge if .
(A) I do not make a scheduled payment when it is due, and
(B) I do not submit to the Lending Institution on or before the date on whleh payment is due, documentation that I qualify Cor a deferment or cancellation
described in Articles VI, VII, VIII, IX, and X of this agreement.
(2) No charge may exceed twenty (20) percent or my monthly, bimonthly or quarterly payment.
(3)(A) The Lending Institution may "
(I) Add the late charge to the principal the day after the scheduled repayment ....s due, or
(ii) Include It with the next scheduled repayment after I have received notice of the late charge.
(B) Ir the Lending lnstitution elects to add the assessed charge to the oUlStanding principal or the loan, it must so inform me before the due date of the
next Installment.
XIII. ASSIGNMENT
(1) This note mil)' be assigned by the Lending Institution only to "
(A) The United States;
(B) Another institution upot\ my transfer to that Institution if that institution is participating in this program; or
(C) Another institution approYed by the SecretaI)'.
(2) The provisions oC this note that relate to lhe Lending Institution shall, when: appropriate, relate to an assignee.
XIV. PRIOR LOANS
I hereby certify that I have listed below all of the Perkins Loans (Notional Direct Student Loans and National Defense Student Loans) I ha"" obtained ot
other institutions. (If no prior loans have been received, state "None..)
SCHEDULE OF PERKINS LOANS (NATIONAL DIMeI' sruDENT LOANS AND NATIONAL DEFENSE sruDENT LOANS) AT
OTIfERINSTITU1l0NS
AMOUNT
DATE
NAME OF INSITIUI10N
1.
2-
3.
4.
XV. SCHBDULE OF ADV ANCBS
The following amounlS _te advanced to me under this lOin agreement on the dates inditlted:
AMOUNT
1. $950.00
DATE
4/88
SIGNATURE OF BORRO~R
//. /- . ;
(' ~,'t.?- C/
<r~ ~I'-J. /; ,
2-
3.
4.
NOTICE TO BORROWER: DO NOT SIGN TIfIS NOTE BEFORE YOU RFAD IT. TIfE LENDING INsrrruTION MUST SUPPLY TO
YOU AND ANY ENOORS~ 1', COPYZOF TIfIS NO, TB. (This note is signed as a sealed instnlment,) ("
~0 / 'L' , ./ ., , " / ( I .
SIGNA'IVRB .?1f' Y ,'. r' J ...... /;'" Date /;',/", ,: 19~_.
:',,"uanen< Address (:>treet or Box Number, City, State, and Zip)
:),1',
^' .
_ 'Oi//e,,'
":;1
/0/';t.'Ii.7 / ~
I
,1~V"1
J- / f'-() /
Social Security Number (bort'O"'er must provide) dJ.o - Y, r ' } (':) .;L
The borrower and Lending Institution shall execute this note without security and .".;thout endorsement unless the borrower is a minor and this note would
not, under the law of tbe State in whieb the Lending Institution is located, ctQte a binding obligation. If the borrower is a minor and this note would nOI,
therefore, be legally binding, the Lending Institution shall require a cosigner to this note:
SIGNA'IVRB OF COSIGNER
Date
19_.
Permanent Address (Street or Box Number, City, State, and Zip)
(20 U.S.c. 1087dd)
Format by the National Association or Student Financial Aid Adminisll'ltors.
DICKINSON COLLEGE
CARLISLE, PENNSYLVANIA 17013
PROMISSORY NOTE - PERKINS LOAN PROGRAM
[Any bracketed claV$8 or paragraph may be Included at option of institution.]
\, David w. Shineman promise to pay to Dickinson College (hereinafter
called the Lending Institution) located at r.~1" 1 i c: 1 p Ppnll<;yl v~lli iI the sum of the amounts that are advanced to me and en-
dorsed in the Schedule of Advances set forth below. I promise to pay all attorney's fees and other reasonable collection costs and charges necessary for t
collection of any amount not paid when due. I further understanCl and agree that:
I. GENERAL
(1) l\Qolicable Law All sums advanced under this note are drawn from a fund created under Part E of Title IV of the Higher Education Act of 1965, as
amended, hereinafter called lhe Act, and are subject to the Act and the Federal Regulations issued under the Act. The terms of this note shall be interpreted
accordance with the Act and Federal Regulations, copies of which are to be kept by the Lending Institution.
(2) ProcOdures for Receivinll Deferment or Cancellation I understand that in order to receive a deferment or cancellation, I must request the deferment or ca,
cellation in writing from the Lending Institution, and must submit to the Lending Institution any documentation required by the Lending Institution to prove th
I qualify for the deferment or cancellation. I further understand that if I am eligible for deferment or cancellation under Micles VI through Xl, I am responsible
for submitting the appropriate requests on time. I further understand that I may lose my deferment and cancellation benefits if I fail to file my request on time
II. INTEREST
Interest shall accrue from the beginning of the repayment period and shall be at the ANNUAL PERCENT AGE RATE OF FIVE PERCENT (S%) on the unpaid
balance, except that no interest shall accrue during any deferment period described in paragraph VI(I).
III. REPAYMENT
(1) I promise to repay the principal and tha interest which accrues on it to the Lending Institution over a period beginning 9 months after the date I cease to bl
at least a half-time student at an institution of higher education. or at a comparable institution outside the United States approved for this purpose by the
United States Secretary of Education (hereinafter called the Secretary), and ending 10 years later, unlass that period is shortened under paragraph III(S), or ex.
tended under paragraphs 11I(4), 111(7) (extensions), or VI(I) (deferments).
(2) Upon my written request, the repayment period may start on a date earlier than the one indicated In paragraph 111(1).
(3] (A) I promise to repay the prinCipal and interest over tha course of the repayment period in equal monthly, bimonthly or quarterly installments. as deter-
mined by the Lending Institution. I understand that if my monthly payment for all the loans made to me by the Lending Institution is not a multiple of $S, the
Lending Institution may round that payment to the next highest dollar amount that is a multiple of $S.
(6) Notwithstanding paragraph 1II(3)(A), upon my written request. repayment may be made in graduated installments in accordance with a schedula
approved by the Secretary.
(C) The Lending Institution shall attach the schadule of repayments and the schedule will become part of the note.
(4) Notwithstanding paragreph 111(1), if I qualify as a low-income individual during tha repayment pariod, the Lending Institution, upon my written request, may
extend the repayment period for up to an additiona/l0 years, end may adjust any repayment schedule to reflect my income.
[(5)(A) If the monthly rate that would be established under paragraph 111(1), or the total monthly repayment rate of principal and interest on all my Perkins
Loans including this loan, is less than $30 per month, I shall repay the principal and interest on this loan at the rate of $30 per month (which includes both prin,
eipai and interest).
(5) (B) If I have received Perkins Loans from other institutions and tha total monthly repayment rate on those loans is less than $30, the $30 monthly payment
established under subparagraph lU(5)(A) includes the amounts I owe on all my outstanding Perkins Loans including thosa received from other Institutions. ThE
amount of this $30 monthly payment that will be applied to this loan will be the difference between $30 and tha total of the amounts owed at a monthly rate or
my other Perkins Loans.
15) The Lending Institution may permit me to pay less than the rate of $30 per month for a period of not more than one year where necessary to avoid
hardship to me unless that action would extend the repayment period in paragraph 11I(1).)
(7) The Lending Institution may, upon my written request, raduce any scheduled repayments or extend the repaymant period indicated in paragraph 111(1), if,
in its opinion, extraordinary circumstances such as prolonged illness or unemployment, prevent me from making the scheduled repayments. However, inter.
est shall continue to accrue.
IV. PREPAYMENT
(1) I may, at my option and without penalty, prepay all or any part of the principal, plus the accrued interest thereon, at any time.
(2) Amounts I repay in the academic year in which the loan was made will be used to reduce the amount of the loan and will not be considered a prepayment.
(3) If I repay more than the amount due for any Installment, the excess will be used to prepay principal unless I designate it as an advance payment of the
next regular installment.
V. DEFAULT
(1) The Lending Institution may, at its option. declare my loan to be in default and may demand immediate payment of the entire unpaid balance of the loan.
including principal, interest, late charges and collection costs if-.
(A) i do not make a scheduled payment when due under the repayment schedule established by the Lending Institution, and
(6) I do not submit to the Lending Institution on or before the date on which payment is due, documentation that I qualify for a deferment or cancellation
described in Articles VI, VII, VIII, IX, X, or XI of this agreement.
(2) I understand that if I default on my loan, the Lending Institution may disclose that I have defaulted, along with other relevant information, to credit bureau
organizations.
(3) Further, I understand that if I default on my loan and the loan is transferred to the Secretary for collection, the Secretary may disciose that I have defaulted,
along with other relevant information, to credit bureau organizations.
(41 I understand that after the Lending Institution accelerates the loan under paragraph V(I), I will then lose my right to defer repayments due after the date
the Lending Institution accelerates the loan.
(S) I understand that after the Lending Institution accelerates the loan under paragraph V(l), I will then lose my right to receive a cancellation of a portion of
my loan for any teaching, volunteer or military service described in Articles VII, VIII and IX, parformed after the date the Lending Institution accelerated the loan.
(6) I understand that failure to pay this obligation under the terms agreed upon will prevent my obtaining additional student financial aid authorized under
Title IV of the H/gher Education Act of 1 965, as amended, until I have made arrangements which are satisfactory to the Lending Institution or the Secretary
regarding the repayment of the loan. .
VI. DEFERMENT
(1) 1 understand that upon making a properly documented wrlllen request to the lending Institution, I may defer making scheduled installment payments. and
will not be liable for any interest that might otherwise accrue, during the following periods:
(A) While I am enrolled and in attendance as at least a half-time student at an institution of hi9her education or at e comparable institution outside the
United States approved for this purpose by the Secretary;
(6) For a period of three (3) years during which I am -
(i) On full-time active duty as a member of the Armed Forces of the United States (Army, Navy, hr Force, Marine Corps, or Coast Guard) or the
National Oceanic and Atmospheric Administration Corps, or as an officer on full-time active duty in the Commissioned Corps of the United States Public
Health Service,
(ii) In servica as a volunteer under the Peace Corps Act,
(Iii) A volunteer under the Domestic Volunteer Service Act 011973 (ACTION programs),
(iv) A full-time volunteer in a tax-exempt organization parforming service comparable to the servica performed in the Peace Corps or under the
Domestic Volunteer Service Act of 1973, or
(v) Tem'Jorarily totally disabled as established by an aflidavit of a qualified physician. cr unable to secura employment because I am providing car.
required by a dependent who I. so disabled;
(C) For a period not in axcess of two (2) years -
(i1 After I receive a baccalaureate or professional degree during which time I am serving in an internship which is required in order that I may receive
profeSSional recognition required to begin my professional practice or service, or
(ii) serving in an internship or residency program leading to a degree or certificate awarded by an institution of higher education, e hospital or a health
care facility that offers postgraduate training;
.(0) For a pericd no~ in exCesa of one (1) year during which, if I am a mother of preschool age children, I have entered or reentered the work force, and am
being paid at a rate which does not exceed $1.00 above the minimum hourly wage established by section 6 of the Fair Labor Standards Act of 1938;
(E) For a period not in excess of six months -
(i) That follows by six months or less of a period during which I was enrolled as at least a half-time student at an eligible institution; and (ii) During
which I am pregnant, caring for my newborn baby, or caring for a Child immediately after he or she was placed with me through adoption and I am neither
attending an eligible institution Of higher education nor gainfully employed; and
(F) During a six (6) month period immediately following the expiration of any deferment provided in paragraphs VI (l)(A) through VI(1)(E).
(2) The Lending institution may, upon my written request, defer my scheduled repayments if .t determines that the deferment is necessary to avoid a financial
hardship for me. Interest, however, will continue to eccrue.
VII. CANCELLATION FOR TEACHING
(1) I understand that upon making a properly documented written request to the Lending Institution, I am entitled to have up to 100 percent of the amount of
this loan plus the interest thereon cancelled if I perform service _
Exhibit "e"
(Al As a full-time teacher in a public or other nonprofit elementary or secondary school which is in the school district of a local educational agency
which is eligible in such year of service for funds under Chapter I of the Education Consolidation and Improvement Act of 1981, as amended, and which has
been designated by the Secretary (after consultation with each State Department of Education) In accordance with the provisions of section 465(a) (2) 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 Secretary. '
(B) I>s a full-time teacher of handicapped children (including Ihose who are mentally retarded, hard ot hearing, deaf, speech and language impaired,
visually handicapped, seriously emollonally dlslurbed, orthopadically Impaired, have specific learning disabililles, or olherwise health-Impaired children, who
by reason thereof require special education and related services) In a public or olher nonprofit elemenlary or secondary school system.
(2) This loan will be cancelled for each compleled year of teaching service at the following rates;
(A) 15 percent of Ihe 10lal principal amounl of Ihe loan plus Inlerest on Ihe unpaid balance will be cancelled for Ihe firsl and second complete academic
years of thaI teaching service,
(B) 20 percent of the total principal amount plus interest on the unpaid balance for the third and fourth complete academic years of that teaching service,
and
(el 30 percent of the total principal amount plus interest on the unpaid balance for the fifth complete academic year of that teaching service.
VIII. HEAD START CANCELLATION
(1) I understand Ihat upon making a properly documenled written request to the Landing Institulion, I am antilled to have up 10100 percenl of Ihe amounl of
this loan plus Ihe Inleresl thereon oanoelled if I perform service as a full.lime slaff member in a Head Start program if -
(A) ThaI Head Start program is operated for a period which Is comparable to a full school year in the locality, and
(8) My salary Is nol more Ihan Ihe selary of a comparable employee of the local educational agency.
(2) This loan will be cancelled allhe rate of 15 percent of Ihe lotal principal amounl plus Inleresl on the unpaid balance for each complete schooi year or Ihe
equivalent of service in a Head Start program.
(3) Head Start Is a preschool program carried out under the Head Start Acl.
IX. MILITARY CANCELLATION
(1) I undersland Ihal upon making a properly documenled wrllten requesllo Ihe Lending Inslllulion, I am enlilled 10 have up to 50 percent of the principai
amounl of this loan plus the inlerest thereon cancelled if I serve as a member of the Armed Forces of Ihe Uniled States in an area of hoslilities thaI qualifies for
special pay under section 310 of Title 37 of the United States Code.
(2) This loan will be cancelled at Ihe rate of 12 1/2 percenl of Ihe tOlal principal amount plus Inleresl on the unpaid balance for each complele year of such ser.
vice.
X. PEACE CORPS CANCELLATION
(1) I understand that upon making a properly documenled written request to the lending instilulion, I am enlilled 10 have up 10 70 percent of the amount of
Ihis loan plus the Interest thereon cancelled if I perform servlce-
(Al I>s a volunleer under the Peace Corps Act; or
(8) I>s a volunteer under Ihe Domeslic Volunteer Service Act of 1973.
(2) This loan will be cancelled at Ihe following rates:
(A) 15 percenl of Ihe lolal principal amount of Ihe loan plus inleresl on Ihe unpaid balance will be cancelled for Ihe firsl and second twelve-monlh period
of volunleer service oompleted;
(B) 20 percent of the total principal amount of the loan pluslnlerest on the unpaid balance will be cancelled for the Ihird and fourth twelve.monlh
period of volunteer service completed.
XI. DEATH AND DISABILITY CANCELLATION
(1) In Ihe evenl of my dealh, Ihe tolal amount owed on this loan will be cancelled.
(2) If I become lotally and permanently disabled aller I receive this loan, the Lending Inslitullon will cancel the total amount of Ihis loan.
XII. CHANGE IN NAME, ADDRESS. TELEPHONE NUMBER AND SOCIAL SECURITY NUMBER
I am responsible, and any endorser is responsible, for Informing the Lending Institution of any change or changes in name, address, lelephone number or so-
cial security number.
XIII. LATE CHARGE
(1) The Lending inslilulion may impose a lale charge if -
IA) 1 do nol make a scheduled payment when it is due, and
(B) I do not submit to the Lending Institution on or before Ihe date on which payment is due, documenlation Ihat I qualify for a deferment or cancellation
described in Micles VI, VII, VIII, IX, X, and XI of this agreement.
(2) No charge may exceed twenty (20) percenlof my monlhly, bimonlhly or quarterly payment.
(3) (Al The Lending Instllulion may-
(i) Add Ihe late charge to the principallhe day after Ihe scheduled repaymenl was due; or
(Ii) Include il with the next scheduled repaymenl afler I have received notice of Ihe late charge.
(B) If Ihe Lending Inslilulion elects 10 add the assessed charge 10 the outslanding principal of the loan, it must so inform me before Ihe due date of the next
Installment.
XIV. ASSIGNMENT
(1) This note may be assigned by Ihe Lending Instilulion only 10-
(A) The Uniled Slales;
(B) Another instilulion upon my transfer 10 that institution if Ihat institution is participating in this program; or
(C) Anolher inslitution approved by the Secretary.
(2) The provisions of Ihis nole thaI relale 10 the Lending Inslilulion shall, where appropriale, relate 10 an assignee.
XV. PRIOR LOANS
I hereby certify that I have listed below all of the Perkins Loans I have oblained at other Institullons. (If no prior loans have been received, stale "None.")
SCHEDULE OF PERKINS LOANS AT OTHER INSTITUTIONS
AMOUNT DATE INSTITUTION
1.
2.
3.
4.
XVI. SCHEDULE OF ADVANCES
The following amounts were advanced 10 me under Ihis loan agreement on the dales indicated:
AMOUNT DATE /' ./ <-;I / /. SIGNATURE OF BORROWER
,. $750.00 7/88 .';;""1'<1':; ~ f5
2. $750.00 12/88 ~/#, _~ff
3.
4.
NOTICE TO BORROWER: DO NOT SIGN THIS NOTE BEFORE YOU READ IT. THE LENDING INSTITUTION MUST SUPPLY A COPY OFTHiS NOTE
TO YOU AND ANY ...cOSIG~R. [This n'?J8js ~Igned as a sealed instrumenl.}
Signature ~ V'..-< /~_ ,.p:
Cermanent Address (Street or Box Number, City, Stale, and Zip Code) / .?CS'
Social Security Number (borrower musl provide) rl-}O - 9r - .7":'oi j(.
The borrower and Lending Institulion shall execute this note without security and wilhout endorsement unless the borrower is a minor and this note wouid not.
Jnder the law of Ihe Stale in which Ihe Lending Institution is located, create a binding obligation. If Ihe borrower is a minor and this nole would not therefore,
Je legally binding, the Lending Institution shall require a cosigner to this note:
agree to repay all amounls due on Ihis loan if Ihe borrower fails 10 do so in accordance wilh Ihe lerms of Ihe nOla.
[(seal)] Date
Oo/~ ('/~
&ce~~/".., /f 19.U...
6?/i" A'~ u2./.~O/
3ignalure Of Cosigner
IIseal)} Date
19_,
'ermanenl Address (Slreet or Bo)( Number, City, Stale, Zip Code)
:20 U.S.C. 1087dd)
Formal by Ihe Nationall>ssocialion of Student Financial Aid Adminislrators, 5/88.
DICKINSON COLLEGE
Carlisle, PA 17013
Tel: 717-245-1383
PROMISSORY NOTE - PERKINS LOAN PROGRAM
[Any blaeketed el~uB8 or paragrap,h may be included at option of institution.]
I, Davl.d W. Sh1.neman promise to pay to Dickinson College (hereinafter
called the Lending Institution) located at r.;\rl i <; 1 p Ppnn<;yl w;\ni ;\ the sum of the amounts that are advanced to me and en.
dorsed In the Schedule of Advances set forth below. I promise to pay all attorney's fees and other reasonable collection costs and charges necessary for t
collection of any amount not paid when due. I further understanll and agree that:
I. GENERAL
(1) ~olicable I aw All sums advanced under this note are drawn from a fund created under Part E of Title N of the Higher Education Act of 1965, as
amended, heleinafter called the Act, and are subject to the Act end the Federal Regulations issued under the Act. The terms of this note shall be interpreted
accordance with the Act and Federal Regulations, copies of which are to be kept by the Lending Institution.
(2) procedures lor RecelvinQ Delerment or Cancellation I understand that in order to receive a delerment or cancellation, I must request the delerment or cal
cellation in writing from the Lending Institution, and must submit to the Lending Institution any documentation required by the Lending Institution to prove th
I qualify for the deferment or cancellation. I further understand that ill am eligible for delerment or canCellation under Articles VI through XI, I am responsible
lor submitting the appropriate requests on time. I lurther understand that I may lose my delerment and cancellation benefits ill fail to liIe my request on time
II. INTEREST
Imeresl shall acerue from the beginning 01 the repayment period and shall be at the ANNUAL PERCE!NTAGE RATE OF FIVE PERCENT (5%) on the unpaid
balance, except that no interest shall accrue during any delerment period described in paragraph VI(l).
III. REPAYMENT
(1) I promise to repay the principal and the inlerest which accrues on it to the Lending Institution over a period beginning 9 months after the date I cease to bl
at least a half.time student at an institution of higher education, or at a comparable institution outside the United States approved lor this purpose by the
United States Secretary of Education (hereinafter called the Secretary), and ending 10 years later, unless that period is shortened under paragraph 111(5), or ex.
tended under paragraphs 11I(4),11I(7) (extensions), or VI(l) (deferments).
(2) Upon my written requesl, the repayment period may start on a date earlier than the one indicated in paragraph 11I(1).
(3) (A) I promise to repay the principal and interest over the course 01 the repayment period in equal monthly, bimonthly or quarterly installments, as deter-
mined by the Lending Institution. I understand that if my monthly payment for all the loans made to me by the Lending Institution is not a multiple of $5. the
Lending Institution may round that payment to the next highest dollar amount that is a multiple of $5.
(8) Notwithstanding paragraph 1II(3)(A), upon my written request, repayment may be made in graduated installments in accordance with a schedule
approved by the Secretary.
(C) The Lending Institution shall attach the sc/ledule of repayments and the schedule will become part of the note.
(4} Notwithstanding paragraph 11I(1), if I qualify as a low.lncome individual during the repayment period, the Lending Institution, upon my written request, may
extend the repayment period for up to an additional 10 years, and may adjust any repayment schedule to rellect my income.
[(5)(A) "the monthly rate that would be established under paragraph 111(1), or the total monthly repayment rate 01 principal and interest on all my Perkins
Loans including this loan, is less than $30 per month, I shall repay the principal and Interest on this loan at the rate of $30 per month (which includes both prin.
cipal and interesl).
(5) (8) "I have received Perkins Loans from other Institutions and the total monthly repayment rate on those loans is less than $30, the $30 monthly payment
established under subperegraph 1II(5} (A) includes the amounts I owe on all my outstanding Perkins Loans including those received Irom other Institutions. The
amount of this $30 monthly payment that will be applied to this roan will be the difference between $30 and the total of the amounts owed at" a monthly rate on
my other Perkins Loans.
(6) The Lending Institution may permit me to pay less than the rate of $30 per month lor a period of not more than one year where necessary to avoid
hardship to me unless that action would extend the repayment period In paragraph 11I(1).)
(7) The Lending Institution may, upon my written request, reduce any scheduled repayments or extend the repayment period indicated in paragraph 11I(1), if,
in its opinion, extraordinary circumstances such as prolonged illness or unemployment, prevent me Irom making the scheduled repayments. However. inter-
est shall continue to accrue.
IV. PREPAYMENT
(1) I may, at my option and without penalty, prepay all or any part of the principal, plus the accrued interest thereon, at any time.
(2) Amounts I repay in the academic year in which the loan was made will be used to reduce the amount of the loan and will not be considered a prepayment.
(3) If I repay more than the amount due for any installment, the excess will be used to prepay principal unless I designate it as an advance payment of the
next regular installment.
V. DEFAULT
(I) The Lending Institution may, at Its option, declare my loan to be in delault and may demand immediate payment of the entire unpaid balance of the loan.
including principal, interest, late charges and collection costs if-
(A) I do not make a scheduled payment when due under the repayment schedule established by the Lending Institution, and
(8) I do not submit to the Lending Institution on or before the date on which payment is due, documentation that I qualify for a deferment or cancellation
described In Articles VI, VlI, VIII, IX, X. or XI of this agreement.
(2) I understand that ill delault on my loan, the Lending Institution may disclose that I have defaulted, along with other relevant information, to credit bureau
organizations,
(3) Further, I understand that ill default on my loan and the loan Is transferred to the Secretary for collection, the Secretary may disclose that I have delaulted.
along with other relevant information, to credit bureau organizations.
(4) I understand that after the Lending Institution accelerates the loan under paragraph V(l), I will then lose my right to defer repayments due after the date
the Lending Institution accelerates the loan.
(5) I understand that after the Lending Institution accelerates the loan under paragraph V(l), I will then lose my right tc receive a cancellation of a portion of
my loan for any teaching, volunteer or militery service described in Articles VII, Viii and IX, performed alter the date the Lending Institution accelerated the loan.
(6) I understand that failure to pay this obligation under the terms agreed upon will prevent my obtaining additional student financial aid authorized under
Title IV of the Higher Education Act 01 1965. as amended, until I have made arrangements which are satisfactory to the Lending Institution or the Secretary
regarding the repayment 01 the loan.
VI. DEFERMENT
(1) I understand that upon making a properly documented written request to the lending Institution, I may deler making scheduled installment payments, and
will not be liable for any interest that might otherwise accrue, during the following periods:
(A) While I am enrolled and in attendance as at least a hall-time student at an institution of higher education or at a comparable institution outSide the
United States approved lor this purpose by the Secretary;
(B) For a period of three (3) years during which I am -
(i) On full-time active duty as a member 01 the Armed Forces 01 the United States (Army, Navy, Nr Force, Marine Corps, or Coast Guard) or the
National Oceanic and Atmospheric Administration Corps, or as an officer on full-time active duty in the Commissioned Corps 01 the United States Public
Health Service,
(ii) In service as a volunteer under the Peace Corps Act,
(Iii) A volunteer under the Domestic Volunteer Service Act of 1973 (ACTION programs),
(iv) A full.time volunteer In a tax-exempt organization performing service comparable to the service performed in the Peace Corps Or under the
Domestic Volunteer Service Act of 1973, or
Iv) i~mporarily t018liy disablao as estatlllshed by an affidavit of a qualified physician, or unable to secure empioyment because I am providing care
required by a dependent who is so disabled;
(C) For a period not in excess of two (2) years -
Q} After I receive a baccalaureate or prolessional degree during which time I am serving in an internship which is required in order that I may receive
professionelrecognitlon required to begin my protessional practice or service, or
(ii) serving in an Internship or residency program leading to a degree or certificate awarded by an institution 01 higher education, a hospital or a health
care facUity that offers postgraduate training;
(D) For a period not in exce.s of one (1) year during which, if I am a mother 01 preschool age children. I have entered or reentered the worl< force, and am
being paid at a rate which does not exceed $1.00 above the minimum hourly wage established by section 601 the Fair Labor Standards Act ot 1938;
(E) For a period not in excess 01 six months -
(i) That follows by six months or less of a period during which I was enrolled as at least a half.time student at an eligible institution; and (ii) During
which I am pregnant, caring for my newborn baby, or caring for a child immediately alter he or she was placed with me through adoption and I am neither
attending an eligible institution of higher education nor gainluHy employed; and
(F) Ouring a six (6) month period immediately 10Howing the expiration of any delerment provided in paragraphs VI(l)(A) through VI(l )(E).
(2) The Lending Institution may, upon my written request, defer my SCheduled repayments if it determines that the deferment is necessary to avoid a tinancial
hardship for me. Interest, however, will continue to accrue.
VII. CANCELLATION FOR TEACHING
(1) I understand that upon making a properly documented written request to the Lending Institution. I am entitled to have up to 100 percent 01 the amount of
this loan plus the interest thereon cancelled if I perform service -.
ExhilHt "D"
(A) As a full-time teacher In a public or other nonprofit elementary or secondary school which is in the school district of a local educational agency
which is eligible In such year of service for funds under Chapter I of the Education Consolidation and Improvement Act of 1981, as amended, and which has
been designated by the Secretary (after consultation with each State Department of Education) in accordance with the provisions of section 465(a)(2} of the
Act as a school with a high concentration of students from low.income families. M official Directory of designated low-income schools is published annually
by the Secretary.
(B) As a full-time teacher of handicapped children (including those who are mentally retarded, hard of hearing, deaf, speech and language impaired,
visually handicapped, seriously emotionally disturbed, orthopedically impaired, have specific learning disabilities, or otherwise health-impaired children, who
by reason thareof require special education and related services) in a public or other nonprofit elementary or secondary school system.
(2) This loan will be cancelled for each completed year of teaching service at the following rates:
(A)' 15 percent of th.total principal amount of th. loan plus Interest on tha unpaid balanc. will be cancelled for the first and second complete academic
years of that teaching service,
(B) 20 percent of the total principai amount plus interest on the unpaid balance for the third and fourth complete academic years of that teaching service,
and
(C) 30 percent of the total principal amount plus interest on the unpaid balance for the fifth complete academic year of that teaching service.
VIII. HEAD START CANCELLATION
(1) I understand that upon making a properly documented written request to the Landing Institution, I am entitled to have up to 100 percent of the amount of
this loan plus the intarest thereon cancelled if I perform service as a full-time staff member in a Head Start program if -
(A) That Head Start program is operated for a period which is comparable to a full school year In the locality, and
(B) My salary is not more than the salary of a comparable employee of the local educational agency.
(2) This loan will be cancelled at the rate of 15 percent of the total principal amount plus interest on the unpaid balance for each complete school year or the
equivalent of service In a Head Start program.
(3) Head Slart is a preschool program carried out under the Head Start Act.
IX. MILITARY CANCELLATION
(1) I understand that upon making a properly documented wrillen request to lhe Lending Institution, I am enlltled to have up to 50 percent of the principal
amount of this loan plus the interest thereon cancelled if I serve as a member of the Armed Forces of the United States In an area of hostilities that qualifies for
special pay under section 310 of Title 37 of the United States Code.
(2) Thia loan will be cancelled at the rate of 121/2 percent of the total prln?ipal amount plus Interest on the unpaid balance for each complete year of such ser.
vice.
X. PEACE CORPS CANCELLATION
(1) I understand that upon making a properly documented written request to the lending institution, I am entitled to have up to 70 percent of the amount of
this loan plus the Interest thereon cancelled If I perform sel'llce-
(A) I>a a volunteer under the Peace Corps Act; or
(8) As a volunteer under the Domestic Volunteer Service Act of 1973.
(2) This loan will be cancell.d at the following rates:
(A) 15 percent of the total principal amount of the loan plus interest on the unpaid balance will be cancelled for the first and second twelve.month period
of volunteer service completed;
(8) 20 percent of the total principal amount of the loan plus interest On the unpaid balance will be cancelled for the third and fourth twelve-month
period 01 volunteer service completed.
XI. DEATH AND DISABILITY CANCELLATION
(1) In the event of my death, the total amount owed on this loan will be cancelled.
(2) W I become totally and permanently disabled after I receive this loan, the Lending Institution will cancel the total amount of this loan.
XII. CHANGE IN NAME. ADDRESS. TELEPHONE NUMBER AND SOCIAL SECURITY NUMBER
I am responsible, and any endorser Is responsible, for informing the Lending Institution of any change or changes In name, address, telephone number or so-
cial security number.
XIII. LATE CHARGE
(1) The Landing Institution may Impose a late charge if -
(A), I do not make a scheduled payment when Ills due, and
(B), I do not submit to the Lending Inslitution on or before the date on which payment is due, documentation that I qualify for a deferment or cancellation
descrIbed In Articles VI, VII, VIII, IX, X, and Xl of this agreement.
(2) No charge msy exceed twenty (20) percent of my monthly, bimonthly or quarterly paymant.
(3) (A) The Lending Institution may-
~) Add the late charge to the principal the day after the scheduled repayment was due; or
(Ii) Include it with the next scheduled repayment after I have received notice of the late charge.
(B) If the Lending Institution elects to add the assessed charge to the outstanding principal of the loan, it must so inform me before the due date of the next
Installment.
XIV. ASSIGNMENT
(1) This note may be assigned by the Lending Institution only to -
(A) The United States;
(8) Mother Inslltution upon my transfer to that institution if that institution is participating In this program; or
(C) Mother institution approved by the Secretary.
(2) The provisions of this note that relate to the Lending Institution shall, where appropriate, relate to an assignee.
XY. PRIOR LOANS
I hereby certify that I have listed below all of the Perkins Loans I have obtained at othef inslltutions. (W no prior loans have been received, state 'None.')
SCHEDULE OF PERKINS LOANS AT OTHER INSTITUTIONS
AMOUNT DATE INSTITUTION
1.
2.
3.
4.
XVI. SCHEDULE OF ADVANCES
The following amounts were advanced to me under this loan agreement on the dates indicated:
AMOUNT DATE /I /SIGNATUREjiJ9-'BORROWER
t. $1,000.00 7/89 ~ /.:t'/~.
~ $1,000.00 12/89 .A-~~ ~
l.
t
'lOTICE TO BORROWER: DO N~T SIGN HIS NOTE BEFORE YOU READ IT. THE LENDING INSTITUTION MUST SUPPLY A COpy OF THIS NOTE
ro YOU AND AN..): CO&!l3N~B. p'hls IS !,igned as a sealed instrument.] ./J . ./ /<,0 v Q
,ignature ~?f/ ~ [(seal)] Date o'<!C'f!4it>//" /0 19LL..
'ermanentAddress (Street or Box Number, City, State, and Zip Code) /10. /PO)'" 6S"7 S' .44/!;voci 5//1,1 ,).-/9-0/
locial Security Number (borrower must provide) (i..J() '-'7J'- .?6;).{t.:. '
rhe borrower and Lending Institution shall execute this note without security and without endorsement unless the bOrrower Is a minor and this note would not.
lOder the law of the State In which the Lending Institution is located, create a binding obligation. ~ the borrower is a minor and this note would nottherelore,
)e legally binding, the Lending Institution shall require a cosigner to this note:
agree to repay all amounts due on this Joan if the borrower falis to do so in accordance with the terms of the note.
;lgnature Of Cosigner
[(seallJ Date
19_,
'ermanent Address (Street or 80x Number. City, State, Zip Codel
20 U.S.C. 1087dd)
Format by the National Association of Sludent Financial Aid Administrators. 5/88.
VERIFICATION
I, THOMAS MEYER, 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. 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
Th:3~~
Bursar of Dickinson College
Dated: f:;< I a ) of
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F IFI LESIDA T AFILEIDickinsonCollege76I 9lCollectionslCurrent\296 pra I
Created 1/3/05 II 37AM
Revised 1/3/05 11-.47AM
7619C 296
David R. Galloway, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 04- 6082
CIVIL ACTION-LAW
DAVID W. SHINEMAN'
Defendant
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE TO DOCUMENT SERVICE AND COST OF SERVICE
PURSUANT TO THE PENNSYLVANIA LONG ARM STATUTE
I hereby certify that a copy of the Complaint was mailed to Mr. David W. Shineman on
December 21, 2004, by certified mail, restricted delivery, return receipt requested.
Attached is the Post Office return receipt signed and dated December 24, 2004 and a copy
of the receipt showing the cost of service was $8.3 8.
MARTSON DE
By
Date: January 3, 2005
Attorneys for Plaintiff
2. ." ,it ill i i 7003 1010 0001 1188 8535
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You entered 7003 10100001 11888535
Your item was delivered at 3:59 pm on December 24,2004 in
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12/29/2004
CERTIFICATE OF SERVICH
I, Jean Taylor, an authorized agent of Marts on DeardorffW'illiams & Otto, hereby certify that
a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at
Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Mr. David W. Shineman
3731 Thomas Point Rd.
Annapolis, MD 21403-5012
MARTSON DEARDORFF WILLIAMS & OTTO
aylor ~ff--
Te ast High Street
Carlisle, PA 17013
(717) 243-3341
Dated: January 3,2005
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Revised 2/2~105 .<:041'!\'1
;6\<)('2%
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David R. Galloway, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 04. 6082
CNIL ACTION-LAW
DAVID W. SHINEMAN,
Defendant
JURY TRIAL OF TWELVE DEMANDED
ACCEPTANCE OF SERVICE
I, David W. Shineman, Esquire,
Complaint on this ft day of
efendant in the above action, accept service of the
.~/
David Shineman, Esquire
6112 Good Hunters Ride
Columbia, MD 21045
~
CERTIFICATE OF SERVICE
(oj
I, Melissa A. Mowery, an authorized agent for Martson Deardorff Williams & Otto, hereby
certify that a copy ofthe foregoing Acceptance of Service was served this date by depositing same
in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows:
David W. Shineman, n, Esquire
6117 Good Hunter's Ride
Columbia, MD 21045
MARTSON DEARDORFF WILLIAMS & OTTO
By \.
Melissa A. Mowery
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: April 19, 2005
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F \FlLES\DA T AF1LE\DickinsonCoUege7619\CoUections\Current\296\296,praJ
Created: 9/6105 1l:59AM
Revised: 917105 !1:05AM
David R. Galloway, Esquire
MARTS ON DEARDORFF WILLIAMS & OTTO
10 E. High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
NO. 04- 6082
CIVIL ACTION-LAW
DAVID W. SHINEMAN,
Defendant
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE TO SETTLE. DISCONTINUE & END
Plaintiff requests the above-captioned matter be marked settled, discontinued and ended
with prejudice.
M
,F WILLIAMS & OTTO
By
David R. Gallo ay
1. D. Number 87326
10 E. High Street
Carlisle, PA 17013
(717) 243-3341
Date: September 7, 2005
Attorneys for Plaintiff
CERTIFICATE OF SERVICE
I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby
certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post
Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows:
David W. Shineman, Esquire
6117 Good Hunters Ride
Columbia, MD 21045
MARTSON DEARDORFF WILLIAMS & OTTO
Dated: September 7,2005
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