HomeMy WebLinkAbout04-6121
F. \FILES\DA T AFILE\DickinsonCollege 7619\CollectionsICurrent\290-coml wpd
Created: 4/28/03 U4:03 PM
Revised. 1212/042.24.06 PM
7619c 290
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04- & 12 I
DICKINSON COLLEGE,
Plaintiff
CIVIL ACTION-LAW
PATSY J. KEEFER,
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 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
Dated: December 2, 2004
WILLIAMS & OTTO
"
DICKINSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 04-
CIVIL ACTION-LAW
PATSY J. KEEFER,
Defendant
JURY TRIAL OF TWELVE DEMANDED
COMPLAINT
AND NOW, comes Plaintiff Dickinson College by and through its attorneys, MARTS ON
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 Patsy J. Keefer is an adult individual with a last known address of 2029
Manada Street, Dauphin County, Harrisburg, P A 17104-2952.
3. On or about May 3, 1988, Defendant entered into a Promissory Note - Federal Perkins
Loan Program (Note #1) with Plaintiff for the financing of $3,000.00 plus interest and costs by
Defendant on her own behalf, for educational services and benefits at Plaintiff s institution. A copy
of Note #1 is attached hereto as Exhibit "A."
4. Note # 1 is funds created under Part E of Title IV ofthe Higher Education Act of 1965
as amended, (hereinafter the "Act") and are subject to the Act and the Federal Regulations issued
under the Act.
5. As provided in the Act, Plaintiff acts in a fiduciary capacity in the handling,
disbursing and collecting of funds associated with the programs under the Act.
6. The total principal for Note #1 is $3,000.00.
7. Note # 1 grants Plaintiff reasonable collection and attorney's fees which Plaintiffhas
calculated to be $500.00.
8. As of August 27,2004, the principal and interest due and payable by Defendant to
Plaintiff was $4,911.16, plus interest accruing thereafter at $.41 per day.
9. As of August 27, 2004, the outstanding balance of$4,911.16 represents the total and
actual overdue value of the financing provided to Defendant under Note # 1 for which Defendant has
yet to pay.
10. Plaintiffhas fulfilled, performed and complied with all obligations and conditions of
Note #1.
COUNT I
BREACH OF CONTRACT
11. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 11 of this Complaint.
12. Defendant breached the expressed and implied obligations, conditions and terms of
agreement of Note #1 by failing to pay the amounts financed therein.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of$4,911.16,
plus interest accruing at $.41 per day from August 27, 2004, collection and attorneys' fees in the
amount of$500.00 and costs of suit.
COUNT II
IN QUANTUM MERUIT
13. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1
through 13 of this Complaint.
14. Having requested Plaintiffto loan money, and doing so to the benefit of Defendant,
Defendant became liable to Plaintiff for said money.
15. Defendant has been unjustly enriched by accepting said money without paying
Plaintiff reasonable compensation therefor.
16. As of August 27,2004, the total amount by which Defendant has become enriched
is $2,759.93, plus interest in the amount of$.41 per day from August 27,2004.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of$4,9ll.l6,
plus interest in the amount of$.41 per day from August 27,2004, collection and attorneys' fees in
the amount of $500.00 and costs of suit.
Date: December 2, 2004
By
David R. Galloway
I.D. Number 87326
Ten East High Street
Carlisle, P A 17013-3093
(717) 243-3341
Attorneys for Plaintiff
\
DICKINSON COLLEGE
CARLISLE, PENNSYLVANIA 17013
PROMISSORY NOTE
PERKINS LOAN PROGRAM
I, Patsy J. Keefer promise to pay to
Dickinson College (hetein after called the Lending Institution) located at Carlisle, Pennsylvania the sum of the amounts tltat ar~ advanced to
me and endorsed in the Schedule of Advances set fonh below. I promise to pay all anorney's fees and other reasonable collecuon COSlS and
charges necessary for the collection of any amount nOI paid when due.
I further understand and agr~ that:
I. GENERAL
(1) Applicable 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 the Act, and are subjcct to the Act and the Federal Regulations issued under the Act. The terms of this note shall be inter-
preted in accordance with the Act and Federal Regulations, copics of which are to be kept by the Lending Institution.
(2) Procedures for ReceMnll Deferment or Cancellation. I understand that in order to receive a deferment or cancellation, I must request the deferment or
cancellation in writing from the Lending Institution, and must submit to the Lending Institution any documentation required by the Lending Institution to
prove that I qualify for the deferment or cancellation. I further understand that if I am eligible for deferment Or cancellation under Articles VI through XI, 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. INI'EREST
Interest shall accrue from the beginning of the repayment period and shall be at the ANNUAL PERCENTAGE 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 10 repay lhe principal and the interesl which accrues on it to the Lending Institution over a period beginning 9 months after the date I cease to
be 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 SecretaI)' of Education (hereinafter called the Secretal)'), and ending, unless paragraphs III(4), IIl(S). III(7), or VI(l) applies, 10 years later.
(2) Upon my wrillen request, the repayment period may start on a date earlier than the one indicated in paragraph IIJ{l).
(3)(A) I promise to repay the principal and interest over the course of the repayment period in equal monthly, bimonthly or quarterly illS\allmenlS 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 10 the next highest dollar amount that is a multiple o( $S.
(B) Notwithstanding paragraph 1II(3)(A), upon my written request, repayment may be made in graduated installments in accordance with a schedule ap.
proved by the SecretaI)'.
(C) The Lending Institution shall attach thi schedule of repayments and the schedule will become part of the note.
(4) Notwithstanding paragraph III(I), if I qualify as a low-income individual durinlthe repayment period, the Lending Institution may, upon my written re..
quest, extend the repayment period for up to an additional 10 years, or adjust any repayment schedule to renect my income, or both.
(5)(A) If the monthly rate that would be established under paragraph lII(l), 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 S30 per month (which includes bOlh
principal and interest).
(5)(B) Ii I have received Perkins Loans from other institutions and the total monthly repayment rate on those loans is less than $30, the S30 monlhly rate "".
tablished under subparagraph lII(S)(A) is the rate I pay on all my outstanding Perkins Loans and is not in addition to lhe amount I pay on those other loans.
The amount of my monthly repayment rale allributable to this loan is the amounl which represents the difference between $30 and the monlhly rates I must
pay on my other Perkins Loans.
(6) The Lending Institulion may permit me to pay less titan lhe rate o( $30 per month (or a period o( nOl more than one year where necessal)' to avoid
hardship to me unless that action would extend the repayment period in paragraph nJ(l).
(1) The Lending Institution may, upon my written request, reduce any scheduled repayments or extend the repayment period indicated in paragraph 111(1),
if, in its opinion, extraordinal)' circumstances such as prolonged illness or unemployment. prevent me from making the scheduled repayments. Howeve" in-
terest 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 lime.
(2) Amounts I repay in the academic year in which the loan was made will be used to reduce the emount 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 il 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, and lale charges if -
(A) I do not make a scheduled payment when it is due, and
(B) I do not sllbmit to the Lending 'Institution on or beFon: the date on which payment is due. documentation that I qualify For a deferment 0' cancellation
described in Articles VI, VII, VIII, Ix:, X, or XI of Ihis agreement.
(2) I understand Ih~1 if I default on my loan repayments, the Lending Institution may disclose that I have defaulted, along wilh olher relevant informalion, to
credit bureau organizations.
(3) Fllrther. I understand Ihat if I default on my loan repayment and the loan is sent to the SecretaI)' for collection, the SecretaI)' may disclose that I have
defaulted, along with other relevant information, to credit bureau organizalions.
(4) I undersland that if the Lending Institution accelerates lhe loan under paragraph V(l), I will lose my canceUation and deferment benefits for $ClVice per-
formed after the date the Lending Institution accelerated the loan. .
(5) I understand that failure to pay this obligation under the terms agreed upon will prevent my obtaining additio~al student financial aid authorized IInder
Title IV of the Higher Education Act of 1965. as amended, unlill have made arrangements which are salisfactol)' to the Lending Institution or the Secretary
regarding the repayment of the loan.
VI. DEFERMENT
(1) Interest will not accrue, and installments of principal need not be paid-
(A) While I am enrolled and in attendance as at least halF-time student at an institution of higher education or at a comparable institution outside the
United Stales approved for this purpose by lhe Secretary;
(B) For a period of three (3) years during which I am -
(i) On full-time active duty as a membe, of the Armed Forces of the United States (Army, Navy, Air Force, Marine Corp<, or Coast Guard) 0, the Na-
tional Oceanic and Atmospheric Administration Corps, or as an officer on full-time active duty in the Commissioned Corp< of the United States Public
Health SelVice,
(ii) In $ClVice as a volunteer under the Peace Corps Act.
(iii) A volunteer under the Domestic Yolunteer Service Act of 1973 (ACTION programs).
(iv) A Full-time volllnteer in a tax-exempt organization performing service comparable to the service performed in the Peace Corps or under the Domes-
tic Yolunteer SelVice Act of 1973, or
(v) Temporarily totally disabled as established by an affidavit of a qualified physician, or unable to secure employment because I am providing care re-
quired by a dependent who is so disabled; .
(C) For a period not in excess of two (2) years after I receive a baccalaureate or professional degree during which time I am servinll in an internship which
i,l) requireu in ower ,nat i may receIVe proiesslonal recognitinn requ!Tcd to be&in in;" Plvt(.ss;onlia1 practice or service, or serving in an internship or residency
program leading to a degree or certificate awarded by an institution of higher education, a hospital or a health care facility thaI offers postgraduate training;
(D) 1'0' a period not in excess of one (I) year during which [ as a mother of preschool age children, who has entered or reentered the work foree, am
being paid at a rale which docs 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 silt months if .
(i) 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 not at-
tending an eligible institution of higher education or being gainfully employed during the six month period, and
(ii) I was enrolled as atlcast a half-time student at an eligible institution within six months of the first day of that period; and
(I') During a six (6) month period following the expiration of any deferment provided in paragraphs VI(l)(A) through VI(l)(E).
(2) The Lending Institution may, upon my written request, defer my scheduled repayments if il determines lhat the defermenl is nceessal)' to avoid a finan.
ciaJ hardship for me. Interest, however, will continue to accrue
VII. CANCELLATION FOR TEACHING
(1) I am entilled to have up to 100 percent of the amount of this loan plus the inlerest thereon cancelled iF I undertake service -
(A) As a full-time teacher for a complete academic year in a public Or other nonprofit elemental)' 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 Improvemenl Act of 1981, as
amended, and which has been designated by the SecretaI)' (after consultation with each State Department of Education) in accordance with the provisions of
section 465(a)(2) of the ACI as a school with a high concentration of students from low-income families. An official Directol)' of designated low-income
schools is published annually by the Secretary.
(B) As a full.time leacher of handicapped children (including mentally retarded, hard of he aring, deaf, speech and language impaired, visually hand-
icapped. seriously emotionally disturbed, orthopedically impaired, children with specific learning disabilities, or other heallh-impaired childn:n, who by reason
Exhibit IlAIl
thereof require special education and related services} in a public or other nonprofit elementary or secondary school ~tem.
(2) This loan will be cancened at the following rates:
(A) 15 percent of the total principal amount of the loan plu.. mterest on the unpaid balanCe will be caneened for the first and second complete academ1c
years of that teaching service,
(8) 20 percent of the tal.) principal amount plus inlerelt on the unpaid balance for the third and fourth complete academic yean of that teachin, service.
(C) 30 percenl of the total princi~' amount plus interest on the unpaid balance for the fifth complete academic year of that teaching service.
VIII. HEAD START CANCELLATION
(1) I am entitled to have up to 100 percent of the amount of this loan plus the interest thereon cancelled if I undenake service as a full-time staff member in
a Head Start program if -
(A) That Head Start propam is operated lor a period which jj; comparable to . full school year in the locality, and
(8) My ulary is not more than the salary of a comparable employee of the local educational agency.
(2) This JOIn will be cancelled at the rate oC 15 percent ol the total principal amount plus inlerest on the unpaid balance for each complete school year or the
equivalent of service in a Head Stan program.
(3) Head Start is a preschool propm carried out und.r th. Head Start Act. (Subthaptar B. Chaptar 8 or Title VI or Pub. L 97-35, the Budget Reconcilia-
lion Act or 1981; lonnerly authorized under ..ction 122(0)(1) of Ilia El:onomie Opportunity Act of 1964).
IX. MILITARY CANCElLATION
(1) I 1m entitled to have up to SO percent of the principallmount of this loan plus the interest thereon caneeUed if I seNe as a member of the Armed FOTtes
of the United StatC5 in an area of hostilitiea: that qualities for special plY under .section 310 of Title 37 of the United States Code.
(2) Thilloan will be caneened at the nte of 12 112 percent 01 the total principal amount plus interest on the unpaid b.lanu for each complete yelr of such
service.
X. PEACE CORPS CANCElLATION
(1) I am entitled to have up to 70 percent of the amount of this loan plUl the Interest thereon cancelled iC 1 undertake serviced
(A) ,.. a volunlur undar the Peaco Carpo Act: or
(B) M' volunteer under the Domestic Volunteer Sel'\lice Act of 1973.
(1) This loan will be cancelled a. the IoIlowing ",t..:
(A) IS percent of the total principal amount of the loan plU$ inlel'e$t on the unpaid balance wiU be cancelled (or the fint and .second twelve-month period
of volunteer service;
(B) 20 pactant or the total prin<:ipal amount 01 tha loan plus in.....t on tbe unpaid balance will be cancalled lor tha third and lourth .....Ive.monlh paried
oC voIunteet seMce.
XI. DEAW AND DISABILITY CANCElLATION
(I) In the event of my daath. the total amount owed on thilloon will be cancelled.
(2) If I become totally and permanently disabled after I receive this loan, the Lending Institution win canul the totll amount of this loan.
XII. CHANGE IN NAME. ADDRESS, TI!LEPHONE NUMBER AND SOCIAL SECURITY NUMBER
I am respol\Sible, and any endorser ia rcaponsiblc, (or inConninl the LendinllRJtituticm of any chanae or chanp in name, addrua, telephone number or so-
cial security number.
XIlI. LATI! CHARGE
(1) The Lcndinglnstitution may impose alate charge if-
(A) I do not mike a aebeduled p8YIIlenl when it iI due, and
(B) I do not submit to 'he Lendinglna:titution on or before the date on which payment is due, documentalion that I qualify for a defennent or cancellation
described in Articles VI, Vll. Vlll, IX, X, and Xl or thi. 'greement.
(2) No charga may ""cud _nly (20) par<&n. of my monthly, bimonthly or quarterly paymen..
(3)(A) Tho Lending I..tilu\ion may_
(i) Add the late charp: to the principaJ the day after the scheduled repayment was duej or
(ii) Include it wi.h the nm scheduled repaymen' after I have rccaived nolica of the late charge.
(B) If the undine Institution .:lel:lI to add the lucsscd chup: to the outltandinc principal of the 10l.~ it must so infon11 me before the due date of the
nut inatallm..t.
XlV. ASSIGNMENI'
(1) This note. may be aaip.ed by the LendinJ Inati,Jution. only to-
(A) Th. United Stat..;
(D) Another institution upon my transfer to that institution if that il\Stitution is participating in this propsm; or
(C) Another institution. .pp~d by the Scerct.ry.
(2) The provisions of tbis note. that relate to tbe. I..endinglnstitution shall, where appropriate, relate to an assignee.
XV. PRIOR LOANS
I hereby certify that I bave listed below aU of the Perkins Loans I have obtained at other institutions. (If no prior loaDl have been received, state -None.-)
SCHI!DULE OF PERKINS LOANS AT O1liER INSrrrunONS
AMOUNr
DATI:!
NAME OF INSl1TIJ110N
I.
2.
3.
4.
XVI. SCHEDULE OF ADVANCES
The foUowina: amounts wen: advanced 10 me under Ihis load agreement on the dates indicated:
AMOUNT
I. $3.000.00
DATI!
SIGNATURE OF BORROWI!R
..). J-'.I I
' "U.J LJ '/ f\ ,:' n'~,
5/88
2.
3.
4.
NOTICE TO BORROWER: DO NOT SIGN WIS N01E BEfORE YOU READ IT. TIlE LENDING INSITflITION MUST SUPPLY TO
YOU AND ANY~ORSER A COPY OF TIllS NOTE. (This no.o is signed as a ...Ied inatNmon..)
" , )" l! / .I I
SIGNATURE i'i tH" 'J ) L"'r~' "- Dale /, '-{ /'1 "~
. " I
Penn8nenlAddrus(Stretl~r Number,City,State,andZip),.t.o('(( flki_ll{;'-!-:" \-.; //;'1'''/)( 1<'"'
Social Security Number (bol'tOWer must provide) /tJ y. /t" If / t; ) t J
19..:::.L.
)
,,: .I /I("/.
The borrower Ind lending Institution chall exeC\1tc this note without security and without endorsement unless the borrower is 8 minor and this note would
not, under the law 0( the SOte in which Ihe Lending Institution is located, Crtate a binding obligation. If the borrower is a minor and this note would not
therefore, be legally bindina. the Lending Institution shall require a cosiper lo this note:
SIGNATURE OF COSIGNI!R
Date
19_.
Pennanent Addre" (Street or Box Number, City, State, Zip)
(20 U.S.c. 1087dd)
(7/87)
Format by the National Associadon of Student financial Aid Administrators.
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. 9 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
Tbomas~~~
Bursar of Dickinson College
Dated: I:R J ~ JrJ/
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F:\FILES\DA T AFlLE\DickinsonCollege7619\Collections\CulTent\290 pra2
Created: 1/26105 10:44AM
Revised 1/26/05 JlU2AM
7619C290
David R. Galloway, Esquire
MARTS ON DEARDORFF WILLIAMS & OTTO
10 E. High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiff
DICKlNSON COLLEGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V AN1A
v.
NO. 04-6121
CIVIL ACTION-LAW
PATSY J. KEEFER,
Defendant
JURY TRIAL OF TWELVE DEMANDED
PRAECIPE TO SETTLE. DISCONTINUE & END
Plaintiff requests the above-captioned matter be marked settled, discontinued and ended.
MARTSON DEARDORFF WILLIAMS & OTTO
~ ' '-
BY~l way, Es~uire
1. D. Number 87326
10 E. High Street
Carlisle, PA 17013
(717) 243-3341
Date: January 26, 2005
Attorneys for Plaintiff
CERTIFICATE OF SERVIC]~
I, Jean Taylor, an authorized agent of Marts on 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:
Ms. Patti 10 Mullins
(a.k.a Patsy J. Keefer)
1023 Fairfield Pike
Shelbyville, TN 37160
MARTSON DEARDORFF WILLIAMS & OTTO
B
Jean aylor
Ten ast High Street
CaTlsle,PA 17013
(717) 243-3341
Date: January 26,2005
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2004-06121 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DICKINSON COLLEGE
VS
KEEFER PATSY J
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
I to wit:
KEEFER PATSY J
but was unable to locate Her
In his bailiwick. He therefore
deputized the sheriff of DAUPHIN
County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On December 29th, 2004 I this office was In receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Dauphin County
18.00
9.00
10.00
26.25
.00
63.25
12/29/2004
MDW&O
So answe1:'~-:::7
,.-'~~---:~/,>,.'-::::i::;::' ....,. . .
/ ~~~~/
R.cThomas Kline
Sheriff of Cumberland County
-=-----
.,,,..-
Sworn and subscribed to before me
this
day of C)""<~7
c200 ,{ A . D .
L~Q lh~;~~-> ~ .
Prothonotafy
. Ill>
if' ~
,
In The Court of Common Pleas of Cumberland Cou.nty, Pennsylvania
Dickinson College
VS.
Patsy J. Keefer
No.
04-6121 civil
Now,
December 9, 2004
, I, SHERIFF OF CUMBEFLAND COUNTY, P A, do
hereby deputize the Sheriff of
Dauphin
County to execute this Writ, this
deputation being made at the request and risk ofthe Plaintiff.
/? A" .. .',
~-r J..e;'" . './..;(/
~~~/.".
'" ,.r?~7"'e"".c..t:" '" ..~~.r-~
~ _1-~l
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
,20_, at
0' clock
M. served the
within
upon
at
by handing to
a
copy of the original
and made lmown to
the contents thereof.
So answers,
Sheriff of
County, P A
Sworn and subscribed before
il1e this _ day of , 20_
COSTS
SERVICB
IvIILEAGE
AFFIDA VIT
$
$
@iHtt of tlp~ ~4~riff
William T. Tully
Solicitor
1. Daniel Basile
Chief Deputy
Mary Jane Snyder
Real Estate Deputy
Michael W.FUnehart
Assistant Chief Deputy
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 255-2660 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
DICKINSON COLLEGE
vs
County of Dauphin
KEEFER PATSY J
Sheriff's Return
No. 7098-T - -2004
OTHER COUNTY NO. 04 6121
I, Jack Lotwick, Sheriff of the County of Dauphin, State of
Pennsylvania, do hereby certify and return I that I made diligent
search and inquiry for KEEFER PATSY J
the DEFENDANT named in the wi thin COMPLAINT
and that I am unable to find him/her in the County of Dauphin, and
therefore return same NOT FOUND, December 22, 2004
NBA- PER CURRENT TENANT OF 1 YEAR, DEFENDANT DOESN'T LIVE THERE
TENANT IS LATINO AND SPEAKS VERY LITTLE ENGLISH
Sworn and subscribed to
So Answers I
?K~
before me this 22ND day of DECEMBER I 2004
Sheriff of Dauphin County, Pa.
~
By
NOT ARlAL SEAL
MARY JANE SNYDER, Notary Public
Highspire, Dauphin County
My Commission Expires Sept 1, 2006
Deputy Sheriff
Sheriff's Costs:$26.25 PD 12/10/2004
RCPT NO 202238