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HomeMy WebLinkAbout13-4616 Supreme Court obRennsylvania 1 Court�Of COinmo`n leas For Protlionotary Use Only: Civil C, o er Sl eet r ` C., t� Docket No: CUMBERLAND , County The informotion collected on this form is used solely for court administration purposes. This form does not supplement or replace 1he filing and .service of pleadings or other popers as required by law or rules of court. Commencement of Action: S O Complaint 0 Writ of Summons Petition E Transfer from Another Jurisdiction Declaration of Taking C Lead Plaintiff s Name: Lead Defendant's Name: T Dickinson College Dominic R. laniro I Are money damages requested? M Yes 0 No Dollar Amount Requested: Owithin arbitration limits O (check one) Ooutside arbitration limits N Is this a Class Action Suit? 0 Yes iX No Is this an MDJAppeal? 0 Yes [X No A Name of Plaintiff /Appellant's Attorney: Christopher E. Rice, Esquire /Martson Law Office 0 Check here if you have no attorney (are a Self-Represented I Pro Sel Litigant) 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 0 Intentional 0 Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution Debt Collection: Credit Card El Board of Assessment rl Motor Vehicle Debt Collection: Other Board of Elections in Nuisance Unpaid student loans 0 Dept. of Transportation S 0 Premises Liability 0 Statutory Appeal: Other 0 Product Liability (does not include E mass tort) 0 Employment Dispute: Slander /Libel/ Defamation Discrimination C 0 Other: Employment Dispute: Other Zoning Board T Other: I 0 Other: O MASS TORT 0 Asbestos N 0 Tobacco 0 Toxic Tort - DES 0 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste Ejectment 0 Other: El � ectment El Common Law /Statutory Arbitration B 0 Eminent Domain /Condemnation 0 Declaratory Judgment 0 Ground Rent 0 Mandamus 0 Landlord /Tenant Dispute 0 Non- Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 4 Mortgage Foreclosure: Commercial 0 Quo Warranto 0 Dental 0 Partition 0 Replevin 0 Legal 0 Quiet Title 0 Other: (Q Medical 0 Other: 0 Other Professional: Updated 1/1/2011 FAFILES \Clients \7619 Dickinson College \7619.Collect ions \7619C. Current \7619C.420lanirc \7619C.420.com Christopher E. Rice, Esquire cn Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER _ c ' �7' MARTSON LAW OFFICES` Y " t-; Ten East High Street —Al 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 - /// DOMINIC R. IANIRO, 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 1 ,3 . (fig c7 r 7 FIFILMClients \7619 Dickinson Coll ege\7619.Collections\7619C. Current\7619C.420 laniro\7619C.420.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 - DOMINIC R. IANIRO 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, Dominic R. Ianiro, is an adult individual with last known addresses of 1571 Felton Road, Cleveland, Ohio 44121, or 5951 Mayland Avenue, Cleveland, Ohio 44124. 3. On or about July 3, 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 $2,800.00. 7 The Note grants Plaintiff reasonable collection and attorneys' fees which Plaintiff has calculated to be $750.00. 8. As of April 8, 2013, the principal and interest due and payable by Defendant to Plaintiff was $2,966.36, 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 $2,966.36, plus interest accruing at 5% per annum thereafter, collection and attorneys' fees in the amount of $750.00 and costs of suit. COUNT II IN QUANTUM MER UIT 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 $2,866.36, plus interest accruing at 5% per annum thereafter, collection and attorneys' fees in the amount of $750.00 and costs of suit. MARTSON LAW OFFICES By 6— Z / 7 s Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 -3093 (717) 243 -3341 Date: 7.3 /-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. EXHIBIT "A" FEDEPLAJ, Pit ;RKINS LOAN MASTER PRONUSSORY NOTE O.Ma No. 18 4S-0074 Form A rued Espirstion Date 0670/1009 i t t t 1. Name (last, first, middle initial) and Permanent Address (street, city, state, zip code) 2• Social Security Number Ll�� �:' �1 (�'� >✓i. )rC r'� 3. Date of Birth (mm/dd/yyyy) 59 'J/ Mk/LAAjt� AV = ,1j �JC 4. Home Area CodeJTe L leph one Ntunber " I!�A yr�-Lb / -��"S (1, S. Drivers License Number R.ict errata ahh.�� ;rah ,..) Ohm 1 T#1 1 1%'nI?#T1TM 6. School Name 8r' Address (street, city, state, zip code ) 7, Annual Interest Rate DIC=071773C OLLEGE Sib PO CARLISLE, PA 17013 -2896 (Any bracketed clause or Paragraph MAY be included at option of insdtudonl Terms and Conditions: (Note: Additional Terms and Conditions follow on subsequent nages) APPLICABLE LAW - The tenets of this Federal Perkins Loan Mesta Proms IT ILIPreted in Act. All sums advanced der his Note are sub ect f th e Higher to the Act and Fed r 'as a mended under the Act the Note) and any diaburxmenta mach um er this (Ixreirt Note shall be after called the A4 as well as Federal regulations issued under the REPAYMENT -I am obligated obligated to repay the principal and the interest that accrues on my 100111 to the above - named institution (hereinafter called he School) ova a period beginning 9 months (or sooner if 1 am a Less- Than•Half- -Time Borrower) after the date l cease to be at least a half-time student at an i nstitution of higher education r s comparable School outside tine United States approved by the United States Deprnrtrrnent of Education (hereinafter called the request in writing that my repayment period begin sooner. I understand that the School will report the amount of Department) and ending h years later, unless 1 to at least one national credit bureau. Interat on this loan shall acme from the beginning of the a installnnant PaYrnen[s, alon ri Yet period. M g with the amount of his'loan Y Deymenp MY repaymtent period may be extended Burin Y repayment period may be shorty than 10 yawn if I am requited by my School to make Minimum monthl S graduated installments in accordance with a schedule approved by the Department (will make 8 Periods of defennent, hardship, or forbearance and 1 may make 540 ( ltn 30 as determined by the School. The School may round my installrrnent a my installment payments In equal monthly, bimonthly, or quarterly Louts) in accordance with the M 40 (or 530 if 1 have outstanding Federal Perkins Loans made before P to the taut highest multiple of S5. ( I wll " October 1, a in um monthly repayment of im mtmum Monthly Payment Section of the Tema and Conditions contained on the rev 1992 that included the S30 minimum erse is de o� i this National Direst Student LATE CHARGES - The School may impose late charg if I do not make a uheduled Payment, a Property documented request form of the C paytrnent when due or if 1 fail to submit to the School on or before he due date of the monthly, bimonthly, or quarto Y orbearance, deforme nt or cancellation benefits as described below. No scheduled a ly Payment The School May add the late charges to principal the day after the late charges rimy exceed 20 p=mt of my pa scheduled P e received notice of the chuge and such notice is sent before the next instillment is due. yment was due or include it with the next Payment after I have FORDEARANCE, DEFERMIiM, OR CANCELLATION -1 may apply for a forbearance, deferment, a cancellation on my loan. During an approved forbearance deferment My ofprincipsh and interest, or principal only, may be post reduced. posted or redu. finetat continues to acenre while my Ian is in forbearance. During an approved deferment periodperiod , I am not required to make scheduled installment payments on my loan. I am not liable for any interest that might othawiu accrue while I deferment. If I meet the eligibility requirements for a cancellation of my loan, the insti Ntion rimy cancel up to I r')0 penrnt of the outs InforMalirrt on eligibility and application i my can is in submitting h requests on e appropriate �' rcmente for forbe /woes, deferments, and cancellations is provided on 8 principal loan amount e, and 1 may lose my benefits if 1 fail to file my request on time Page 2 and 3 of Ibis Nate I am responsible fa time, DEFAULT - The School army, at its option, declare my loan to be in defitult if (1) I rail to make a scheduled payment when due; (2) I fait to submit to the School, on or before the due date of a scheduled Payment, documentation that I qualify for a forbearance, deferment or cancellation: or (3) 1 tail to this Note or written repayment agreement. Ilia School ma assign a defaulted loan to the financial assistance authorized under the Act until I make amts ^P with the tears and conditions of Department for co4ection, [will be ineligabk for any f f urther ederal student shalt disclose to credit bureau Organizations that I have Defaulted and all oh relevant loan info th e So l or th Department to repay my loan. The School Or the 1 default on my Ian. The School or the D a my right to defer �peuncnt of the I t on unpaid balance of the loan, iDetpud,�nt may accelerate my defaulted loan. Acceleration means that the School or the Payments and my right to forbearance if g princ interest, late charges, and colic costs. 1 win my right to receive cancellation benefits th Per`ormed after the date the School or the DePartrtnent accelerated the loan. CHANCE OF STATUS - f will inform the School of any change in my name, address, telephone number, Social Security Number, or driver's license number, PROMISE TO PAY: I promise to pry the School or a subsequent holder of the Note, all sums disbursed under the terms of this Note, plus interest and other fees which' may become due as provided in this Note. I understand that mahtlple loans maybe made tome under this Vote. 1 understand that by accepting any disbursements issued any time under this hole, 1 unto to repay the !Dares. m I understand that each loan is separately enforceable based on a true and exact copy of this Note. I understand that 1 May cancel or reduce the amount of any loan by Mat accepting or by returning all or a portion of any disbursement that is issued. V 1 do not make an a t due, I promise to pay all reasonable collection costs, including attorney fees, court costs, and other fees. 1 will not sign this Note before reading the entire Not even if i em told that I am not required to read it. I am entitled to an exact copy of this Note. This losn has ban under this Note when it i My signature certifies I have /sad, understand, and agree to the terms and conditions of this Note. made tome without teeuriry endorseneent 1 UNDERSTAND THAT t MAY RECEIVE ONE OR MORE LOANS UNDER TIUS MASTER PROMISSORY NOTE AND THAT I MUST REPAY SUCH !Borrowers Signarae � a " Date Page 1 of 4 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 Hecken rn Bursar Dated: F.\FILES \Clients \7619 Dickinson College \7619. Collections \7619C. Current \7619C.420laniro \7619C.420.com F TILESVClientsV7619 Dickinson CollegeA 7619.CollectionsV7619C.CurrentV7619C 420laniroA7619C 420_as.wpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 , < MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES °;f'±. ? PM 12' Ten East High Street Carlisle, PA 17013 + ' 717 243-3341 ,'µ.. Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2013 - 4616 Co DOMINIC R. IANIRO, CIVIL ACTION - LAW _ Defendant AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND ) ,.a r*3 ' I hereby certify that a copy of the Complaint in the above captioned matter was mailed to Dominic R. Ianiro, 1571 Felton Road, Cleveland, OH 44121-2722, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office signed return receipt and dated August 8, 2013„ with attached receipt of costs in the amount of$11.06. MARTSON LAW OFFICES By Christopher E. Rice, Esquire Attorney I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Sworn to and subscribed before me this �� day of August, 2012. MMONwEALrH OF PENNSYLVANIA NotOW Seal Mary M.Price,Notary Public Carllsw s^ro,Cumberland County My Comrni pion i xplt6i Au .,18 2015_ ,f IA*q 04� ] MEMBER,PEMPdq`l'� �: N tar Public THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR DICKINSON COLLEGE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. E SECTION SENDER: COMPLETE THIS . ON DELIVERY • Complete items 1,2,and 3.Also complete A. Sign re item 4 if Restricted Delivery is desired. X ❑Agent • Print your name and address on the reverse dressee so that we can return the card to you. B. R C.�atp QiivW • Attach this card to the back of the mailpiece, 1/ {/� or on the front if space permits. l D. Is deliVe4 address different from item t? ❑Yes 1. Article Addressed to: ` �I/+ If YES,enter delivery address below: 0 No IrU�, /}.�� 3. Service Type �'! 1 1pu�Cx✓�`^e.�"' �j Certified Mail ❑Express Mail ❑Registered ❑Return Receipt for Merchandise ❑Insured Mail 13 C.O.D. 4. Restricted Delivery?(Extra Fee) es 2, Article Number ?012 2 2 1 0 0000 7?9 5 4-155- -. (transfer from service!abet) _ PS Form 3811,February 2004 Domestic Return Receipt 102595-02-M-1540 Postal RECEIPT CERTIFIED MAIL,. (Domestic In t e' Ln t� Er t D Postage $ f`- _ � > Certified Fee Q , ,,.�--- -•.,,; , f(7 Postm Q Return Receipt Fee qq ? Here 1 C3 (Endorsement Required) mot,y S Restricted Delivery Fee l 5� (Endorsement Required) `7 J C3 ft1 Total Postage&Fees j rU Sent T ru ltil�[Nif�'e�----`-- - - - ------------------------- © /) or PO Bo No. City,State,Z1P+4 PS Form :0r August 2006 See Reverse for Instructions" 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: Dominic R. Ianiro 1571 Felton Road Cleveland, OH 44121-2722 MARTSON LAW OFFICES By VJW) /j, (;Lz,� Mart TN Price 10 East High Street Carlisle, PA 17013 Dated: L I of 3 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\7619,Collect ions\76 19C.Current\76I9C.420 laniro\7619C.420.pra.default.wpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 fit; 1"t20TCdu ,�,, 'r, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER 2014 FEB AN ff: MARTSON LAW OFFICES Ten East High Street CUMBERLAND COUNTY 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 - 4616 DOMINIC R. IANIRO, : CIVIL ACTION - LAW Defendant PRAECIPE TO THE PROTHONOTARY: Please enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant, Dominic R. Ianiro, in the amount of$2,866.36,plus interest accruing at the rate of 5% per annum, collection and attorney's fees in the amount of$750.00, 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 Dominic R. Ianiro on September 9, 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: S- Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: Attorneys for Plaintiff /6. 1aa , al /W.h. :3cc/y3Y ��� / '61 F\FLEESVClients,7619 Dickinson College\7619 Collections\7619C Current17619C 4201aniroA7619C.420.10 day notice.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 - 4616 DOMINIC R. IANIRO, : CIVIL ACTION - LAW Defendant IMPORTANT NOTICE TO: Dominic R. Ianiro DATE OF NOTICE: September 9,2013 1571 Felton Road Cleveland,OH 44121-2722 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: dL4 '� 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 - 4616 DOMINIC R. IANIRO, : 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,Dominic R. Ianiro,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: 1571 Felton Road, Cleveland, Ohio 44121-2722. Said Defendant's place of employment is unknown. 4 s• Christopher E. Rice, Esquire Sworn to and subscribed before me this day of February, 2014. Notary Public 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 - 4616 DOMINIC R. IANIRO, : 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 Dominic R. Ianiro was given to him by mail on September 9, 2013. e„ ' Christopher E. Rice, Esquire Sworn to and subscribed before me this day of February, 2014. Notary Public 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: Dominic R. Ianiro 1571 Felton road Cleveland, OH 44121-2722 MARTSON LAW OFFICES By / l c Q,�c.a -3/i . Price 10 East High Street Carlisle, PA 17013 Dated: (//D/l 4f 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 - 4616 DOMINIC R. IANIRO, : CIVIL ACTION - LAW Defendant TO: DOMINIC R. IANIRO NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the /Cy 4 day of February,2014,the following Judgment was entered against you in the above-captioned action:judgment in the amount of in the amount of $2,866.36, plus interest accruing at the rate of 5%per annum, collection and attorney's fees in the amount of$750,00, and costs of suit, for failure to file an Answer to Plaintiffs Complaint. Date: 1G l N . Pr q, I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Dominic R. Ianiro 1571 Felton Road Cleveland, OH 44121-2722