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HomeMy WebLinkAbout13-3361 Supreme Cou -1, ennsylvania Courtbf COmmo leas For Prothonotary -Use only: C11 it e6 Sheet Docket No: Cu M „ERLAND Coun 33& The information collected on this form is used solel,v for court administration purposes. This f)rm does not supplement or replace Ihe,filing and service of pleadin,C,s or other papers as required by lath' or rules of Court. Commencement of Action: S El Complaint El Writ of Summons Petition ® Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Dickinson College Sarah E. Barr T Dollar Amount Requested: Rwithin arbitration limits I Are money damages requested? 0 Yes 0 No check one) ) ®outside arbitration limits 0 N Is this a Class Action Suit? ll Yes ll No Is this an MDJAppeal? Yes lE No A Name of Plaintiff /Appellant's Attorney: Christopher E. Rice, Esquire /Martson Law Offices (heck here if you have no attorney (are it Self-Represented 11'ro Set [..itigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS n Intentional Buyer Plaintiff Administrative Agencies El Malicious Prosecution Debt Collection: Credit Card M Board of Assessment E] Motor Vehicle [E Debt Collection: Other ® Board of Elections ® Nuisance Unpaid Student Loans ® Dept. of Transportation E] Premises Liability Q Statutory Appeal: Other S 0 Product Liability (does not include l] Employment Dispute: E mass tort) n Slander/Libel/ Defamation Discrimination C l Other: Employment Dispute: Other Zoning Board T ll Other: I E] Other: O MASS TORT El Asbestos N n Tobacco E] Toxic Tort - DES 0 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS l7 Toxic Waste ® Other: 0 Ejectment n Common Law /Statutory Arbitration B ll Eminent Domain/Condemnation n Declaratory Judgment M Ground Rent n Mandamus 0 Landlord/Tenant Dispute l] Non - Domestic Relations M Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY n Mortgage Foreclosure: Commercial l Quo Warranto M Dental Partition Replevin El Legal Quiet Title ll Other: rl Medical l7 Other: rl Other Professional: Updated 1/1/2011 FABLES \Clients \7619 Dickinson College\ 7619. Collections \7619C.Current \7619C.416 Barr \7619C.416.com Christopher E. Rice, Esquire - a —r1 Attorney I.D. No. 90916 c�� ;w - MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES ' Ten East High Street '�. - „, - ” Carlisle, PA 17013 (717) 243 -3341 C I Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2013 - 330 SARAH E. BARR, CIVIL ACTION - LAW Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249 -3166 x`03. / �9/ FARLES\Clients \7619 Dickinson College\ 7619. Coll ections \7619C.Current \7619C.416 Barr \7619C.416.com Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243 -3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V• NO. 2013 - - 330 SARAH E. BARB, CIVIL ACTION - LAW Defendant COMPLAINT AND NOW, comes Plaintiff Dickinson College by and through its attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and hereby avers as follows: 1. Plaintiff, Dickinson College, is a Pennsylvania educational institution and nonprofit corporation with its principal place of business at West Street, Post Office Box 1773, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant, Sarah E. Barr, is an adult individual with a last known address of 1600 Spring Valley Road, Ossining, New York 10562. 3. On or about July 29, 2007, Defendant entered into a Promissory Note ( "Note ") with Plaintiff for the financing of a loan, plus interest and costs, for educational services and benefits at Plaintiff's institution. A copy of the Note is attached hereto as Exhibit "A." 4. The Note is a fund created under Part E of Title IV of the Higher Education Act of 1965 as amended (hereinafter the "Act ") and is subject to the Act and the Federal Regulations issued under the Act. 5. As provided in the Act, Plaintiff acts in a fiduciary capacity in the handling, disbursing and collecting of funds associated with the programs under the Act. 6. The principal amount for the Note was $11,000.00. 7 The Note grants Plaintiff reasonable collection and attorneys' fees which Plaintiff has calculated to be $2,000.00. 8. As of April 10, 2013, the principal and interest due and payable by Defendant to Plaintiff was $11,644.25, with interest accruing at 5% per annum. 9. Plaintiff has fulfilled, performed and complied with all obligations and conditions of the Note. COUNT BREACH OF CONTRACT 10. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 9 of this Complaint. 11. Defendant breached the expressed and implied obligations, conditions and terms of agreement of the Note by failing to pay the amount financed therein. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $11,644.25, plus interest accruing at 5% per annum thereafter, collection and attorneys' fees in the amount of $2,000.00 and costs of suit. COUNT II IN QUANTUMMERUIT 12. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 11 of this Complaint. 13. Having requested Plaintiff to loan money, and doing so to the benefit of Defendant, Defendant became liable to Plaintiff for said money. 14. Defendant has been unjustly enriched by accepting said money without paying Plaintiff reasonable compensation therefor. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $11,644.25, plus interest accruing at 5% per annum thereafter, collection and attorneys' fees in the amount of $2,000.00 and costs of suit. MARTSON LAW OFFICES By (� S Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 -3093 (717) 243 -3341 Date: 6 -11-1 3 Attorneys for Plaintiff This is a debt collecting firm attempting to collect a debt for Dickinson College. Any information obtained will be used for that purpose. EXHIBIT "A" � w FEDERAL PERKINS LOAN MASTER PROMISSORY NOTE '(wtY'?t4 oA4B No. 1845-0074 form A Woved t x iration Uatc 06/301Z009 1 .0 I. Name (last, tirst, middle initial) and Permanent Address (street, city, state, zip code) 2. Social Security Number Sarah E. Barr 3. Date of Birth 24 Riverview Trail 4. home Area Code/Tclephone Number Croton -On- Hudson N.Y. 10520 5. Driver's License Number (List state abbreviation first) NA Im 6. School Name & Address (street, city, state, zip code) 7. Annual Interest Rate DICKINSON COLLEGE 5% PO BOX 1773 CARLISLE, PA 17013 -2896 IAny bracketed clausc or paragraph may be included at option of institution) Terms and Conditions: (Note: Additional Terms and Conditions follow on subsequent pages) APPLICABLE IAW -The terms of this Federal Perkins Loan Master Promissory Note (hereinafter called the Note) and any disbursements trade under this Note shall be interpreted in accordance with part E of Title IV oftlx l lighcr Education Act or 1965, as amended ( hcreinafter called the Act), as well as Foetal regulations issued under the Act. All sunts advanced under this Note arc subject to the Act and Federal regulations issued under the Act, REPAYMENT - I am obligated to repay the principal and the interest that accrues on my loun(s) to the above -named institution (hereinafter called the School) over a period beginning 9 months (Or socmcr if I am a Less= That- l I&A'ime Borrower) alter the date 1 Uvsc to be at least a half student at an institution of higher education or a comparable School outside the United States approved by the United Staten request in writin that m die t of Education ((hereinafter called lc ent pW mnt) and ending 10 years later, unless I g Y repayment peria! begin sooner School I understand That die School will rtp0rt the amount of my installment paymmnts, along with the amount of this buret [Oat least one national credit bureau. Interest on this Juan shall accrue from the. beginning of the repayment period. My rcpacnt periled may be shorter than 10 years if I am required by my School make nermun monthly payments. My repayment period may he extended during periods of deferm hardship, or forbearance and 1 may make graduated installments in n accordance with a schedule approved by the Department I will make my i Intent instaftments r have d the School. 'The School may round my installment payment to the next hgest mult 55 will make a bi monthl y , minimum mo ymh quart Sd0 (or S30 if I have outstanding I ederal Perkins I.,uans made before October 1, 1992 that included th e 830 h minimum iple of nt It y repayment of d.oans) in accordance with the Minimum Monthly Payment Section of the Terms and (conditions contained on the reverse side of this doxumentt..� ing National Direct Student LA'C'E CIIARGES -The School may impasc late charges if I do not make a scheduled payment when due or if I in" to submit 10 the School on or before the due date of the Payment, a property documented request for any of ft forbearance, defemnent, or cancellation benefits as described below. No late charges may exceed 20 percent of nny monthly, lcd bimonthly, or quarterly payment lire School may add the late charges to principal the day after the scheduled payment was due or include it with the next payment after 1 have received notice of the charge, and such notice is sent before the next installment is dire. FORBEARANCE DEFERMENT, OR CANCELIATION - I may interest, or principal only may l apply for a fiu reduced. Interest est cmarnl, of cancellation on my loan, During an approved forbearance Period. Payments of principal and interest. x; defermttcnt period. I am rust required to make sehexfuleA ittstoJlmcrnt pat onl loan. l I FUn n t for any iccrut: While !at might otherwise accrue u7ti)e my Ioart is r in Y e a c rue w . l eering an approval deferment. If I meet the eligibility requirements for a cancellation of my loan, the institution may cancel up to 100 percent of the outstanding principal loan amount. Information on eligibility and application requirements for forbcnr u con. do:rLmnents, and cancellations is provided on Pages 2 and 3 of this Note. I am responsible for submitting the appropriate requests on tittle, and I may lose my benefit, if I fail to file my request on time, UEFAIJI.T -'Ihc School may, at its option, declare my heart to be in default if (1)1 fail to make a scheduled payment when due; (2)1 fail to submit to the School, on or re paymcrnt agreement. ti the due date a ym olulcd payment, documentation that I qua)ify for n fo this rbearance, d a eferment, cancellation; or (3)1 fni)10 comply with 01%, terms and conditions of s N Note or written rc 'The School may assign a defaulted loan to the Ikpatmtmt lo financial assistance authorized under the Act until I make arrangements that are satisfact extfleetiort. I will be ineligible Cor any further federal student shall disclose to credit bureau organizations that I have defaulted and all other rcicvanl loan iufomiat u W will lose p my right to defer Pasts and m ri re Y tame School or Una Department 1 default on my loan. T Uc he School or the p ding P may accelerate my &-faulted loan. Acceleration means that the School or the tkparbncm demands immoliatc puyment ncipal, intc`rest late charges Y get t0 forbearance if oftdme entire unpaid balance of The loan, including PH may performed alter the date the School or the and collection costs. I Will lose my right to receive benefits for sett ice that is 17epartmcnt accelerated the loan. CIIANGE OF 9FATUS - I will infirm the Schaml of any change in my name, address, telephone number, Social Security Number, or drivices license number. PROMISE TO PAP I promise i pay the Sclxwl, Ora subscqucm Roller of Cite Note, all suns disbu d under th rsee terms of this Note. Plus interest and ot)nx ich fees wh may be co due as Provided in this Note. 1 understand that multiple loans may be made to me une I understand bud by us into s any of hurf wh s issued at any time under this Note, der bets Not I agree to spay the to a s. I understand that each loan is WP=tcly enforceable based on a true and exact COPY of this Note. I understand that I may cancel or reduce the mount of any loan by not accepting or by returning all or a ponion of any disburser=, that is issued. If I do not make any Payment on any loan under this Note when it is due. I promise to Pay all reasonable collection to an exact on costs, including attorney fees, Court costs, and other 1'txs. I will not siing entire Note, even if[ am told that I am not required to rcad il. I am entitled Copy of go this Note before rend the this Note. Sty fies signature certi I have read, understand, and agree to the terms and conditions of this Note. 'This Ivan ha 1>eem made tome without security or endoru in I A L ti STAND TFLkT 111 RF,CEryE ONE OR MORE UNDER THIS MASTER PROMISSORY \OTF: , 1ND'TIb1T I MUST RF,PAl' SL'(:11 IAA// p t } j Borrotve,r s Signature ! Date AUG J , ' VERIFICATION I, SALLY HECKENDORN, Bursar of Dickinson College, acknowledge that I have the authority to execute this Verification on behalf of Dickinson College and certify that the foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of this lawsuit. The language of this Complaint is that of counsel and not my own. I have read the document and to the extent that this Complaint is based upon information which I have given to my counsel, it is true and correct and to the best of my knowledge, information and belief. To the extent that the content of this Complaint is that of counsel, I have relied upon counsel in making this Verification. This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. Dickinson College Sally Hecke orn Bursar Dated: FAFILES \Clients \7619 Dickinson College\ 7619. Coll ections \7619C.Current \7619C.416 Barr \7619C.416.com F:\FILES\Clients\7619 Dickinson College\7619.Collections\7619C.Current\7619C.416 Barr\7619C.416.pra.reinstate.wpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER 7 L r i y MARTSON LAW OFFICES Ten East High Street 1013 JUL 31 PM 12: 2 Carlisle, PA 17013 (717) 243-3341 CUMBERLAND 'U16UNI T Y Attorneys for Plaintiff PENNSYLVANIA DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2013 - 3361 SARAH E. BARR, CIVIL ACTION - LAW Defendant PRAECIPE To the Prothonotary: Please reinstate the Complaint in the above-referenced matter. MARTSON LAW OFFICES By: 4 4 r Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: -2/3/13 Attorneys for Plaintiff This is a debt collecting firm attempting to collect a debt for Dickinson College. Any information obtained will be used for that purpose. F:\FILES\Clients\7619 Dickinson Cot lege\7619.Collections\7619C.Current\7619C.416 Barr\7619C.416.as.wpd Christopher E. Rice, Esquire r Attorney I.D. No. 90916 E : r'fti�tiliflti'Jj,;� ' MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES ``' ' d �t '� ' Ten East High Street n.. Carlisle, PA 17013 PENI SYLV, NIA (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2013 - 3361 SARAH E. BARR, CIVIL ACTION - LAW Defendant PROOF OF SERVICE To the Prothonotary: Attached is the Sheriff's Certificate of Service signed by the Westchester County Sheriff's Department indicating Defendant was served with the Complaint on August 26, 2013. MARTSON LAW OFFICES By:��4 5- /?-_ Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: 3 Attorneys for Plaintiff This is a debt collecting firm attempting to collect a debt for Dickinson College. Any information obtained will be used for that purpose. SHERIFF'S CERTIFICATE OF SERVICE(C.P.L.R.306) CUMBERLAND COUNTY COURT OF COMMON PLEAS COURT STATE OF NEW YORK COUNTY OF INDEX: 2013-3361 DICKINSON COLLEGE Plaintiff/Petitioner -against- SARAH E BARR Defendant/Respondent I, George N. Longworth, Commissioner-Sheriff of the County of Westchester, State of New York do hereby certify that on the 8/26/2013 at 10:30 AM service was effected of the annexed SUMMONS AND COMPLAINT,NOTICE AND COMPLAINT in the above entitled action or proceeding by my undersigned Police Officer ADAM PIERAGOSTINI, upon SARAH E BARR the person named therein as defendant in said action or proceeding by depositing in a Post Official Depository of the United States Post Office at 110 Dr. Martin Luther King Jr. Boulevard, White Plains,New York, a true copy thereof enclosed in a postpaid wrapper properly addressed to said defendant at: 1600 SPRING VALLEY ROAD OSSINING,NY 10562 that being the defendant's last place of abode or place of business in the County of Westchester and State of New York; And affixing a true copy of said to the door of the same address. Service was made in the foregoing manner because the Department has been unable with due diligence to make service of said papers by delivering the same within the State personally to said defendant, as appears more fully from the following: 8/12/2013 11:30 AM 8/14/2013 9:40 AM 8/15/2013 6:34 PM Dated: 8/26/2013 Police Officer AM PIERAGOSTINI Sheriff File: 13005243 a rgangvtiorh omni'��sianer-Sheriff = 'Westchester County 7 CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Proof of Service was served this date by depositing same in the Post Office at Carlisle,PA,first class mail,postage prepaid,addressed as follows: Sarah E. Barr 1600 Spring Valley Road Ossining,NY 10562 MARTSON LAW OFFICES By.V%4M) 5�t 0,," Price 10 E t High Street Carlisle, PA 17013 Dated: o13 l� This is a debt collecting firm for Dickinson College attempting to collect a debt. Any information obtained will be used for that purpose. F'.\FILES\Clients\7619 Dickinson College\7612Collections\7619C.Current\76190.416 Barr\7619C.416.pra.defau1twpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 1 c p_6 0-€p p i 0 ,, .. MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 2013 NOV 25 Aft 10: (50 Ten East High Street CUMBERLAND COUN;-f Carlisle, PA 17013 PENNSYLVANIA (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2013 - 3361 SARAH E. BARR, CIVIL ACTION - LAW Defendant PRAECIPE TO THE PROTHONOTARY: Please enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant Sarah E. Barr in the amount of$11,644.25, plus interest accruing at the rate of 5%per annum,collection and attorney's fees in the amount of$2,000.00,and costs of suit,for failure to file an Answer to Plaintiffs Complaint. I do hereby certify that written notice of intention to file this Praecipe was mailed to Sarah E. Barr on October 28, 2013, which date is subsequent to the date default occurred and at least ten (10) days prior to the date of this Praecipe. MARTSON LAW OFFICES By: (� 5 �- Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 rr Dated: ��02�-3 Attorneys for Plaintiff C-F a 772 S' , a�e613 F TILESTlients\7619 Dickinson Co1lege\7612Co11ections\76190 Currcrn`7619C.416 Barr\76190.416.10daynotice.wpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717)243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2013 - 3361 SARAH E. BARR, CIVIL ACTION - LAW Defendant IMPORTANT NOTICE TO: Sarah E. Barr DATE OF NOTICE: October 28,2013 1600 Spring Valley Road Ossining, NY 10562 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 MARTSON LAW OFFICES By Christopher E. Rice, Esquire THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR DICKINSON COLLEGE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2013 - 3361 SARAH E. BARR, CIVIL ACTION - LAW Defendant AFFIDAVIT AS TO MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he has authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and belief, Defendant Sarah E. Barr, above named is not in the military service of the United States of America, that he has knowledge that the said Defendant's last known address is: 1600 Spring Valley Road,Ossining,NY 15062. Said Defendant's place of employment is unknown. c4 S /e—— Christopher E. Rice, Esquire Sworn to and subscribed before me thisjA day of November, 2013. 04w) e 94�r-� N to ublic COMMONWEALTH OF PENNSYLVANIA Notarial Seat Mary M.Price,Notary Public CadWe am,Cumberland County CofDin1 Expires Aug.18,2015 VANIA ASSOCIATION OF NOTARIES F:\FILES\Clients\7619 Dickinson College\7619.Collections\7619C.Current\7619C.416 Barr\7619C.416.pra.default.wpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2013 - 3361 SARAH E. BARR, CIVIL ACTION - LAW Defendant COMMONWEALTH OF PENNSYLVANIA ) : SS COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY&FALLER,attorneys for the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure,a notice of intention to enter default judgment against Defendant Sarah E. Barr, was given to her by mail on October 28, 2013. S Christopher E. Rice, Esquire Sworn to and subscribed before me thisaf�day of November, 2013. AO N 4ta6 Public COMMONWEALTH OF PENNSYLVANIA =cam.disiye otarial Seal Price,Notary Public o,Cumberland 18u 015 on Expires NOTARIES MEMB ER,PENNSYLNANIP,ASSOCIATION OF CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER,hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Sarah E. Barr 1600 Spring Valley Road Ossining, NY 15062 MARTSON LAW OFFICES By �6") ;J, (2Lc�- M Price 10 EYst High Street Carlisle, PA 17013 Dated: This is a debt collecting firm for Dickinson College attempting to collect a debt. Any information obtained will be used for that purpose. Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717)243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2013 - 3361 SARAH E. BARR, : CIVIL ACTION - LAW Defendant TO: SARAH E. BARR NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the 2C day of November,2013,the following Judgment was entered against you in the above-captioned action:judgment in the amount of in the amount of $11,644.25,plus interest accruing at the rate of 5%per annum,collection and attorney's fees in the amount of$2,000.00, and costs of suit, for failure to file an Answer to Plaintiffs Complaint. �Z— (? 'r 3.442 3woo Date: !---- Prothonotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Sarah E. Barr 1600 Spring Valley Road Ossining,NY 15062