Loading...
HomeMy WebLinkAbout14-1739 Supreme Court 66 Pennsylvania Court"_of,COmmo Pleas For Prothonotary Use Only: k3I, ! v;`t �;�-' i )fit CIVi11Gover Sheet Docket No: `r �; 1 Cube ands County The information collected on this form is used solely for court admin7S17 purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S 0 Complaint 0 Writ of Summons M Petition Transfer from Another Jurisdiction 0 Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: T Dickinson College James W. Lonergan Dollar Amount Requested: Mx within arbitration limits I Are money damages requested? 0 Yes 0 No (check one) outside arbitration limits O N Is this a Class Action Suit? Yes S No Is this an MDJAppeal? Yes 0 No A Name of Plaintiff /Appellant's Attorney: Christopher E. Rice, Esquire /Martson Law Offices 0 Check here if you have no attorney (are a Self (Pro Se) 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 Intentional 0 Buyer Plaintiff Administrative Agencies Malicious Prosecution 0 Debt Collection: Credit Card El Board of Assessment Motor Vehicle Q Debt Collection: Other Board of Elections Nuisance Unpaid student loams Dept. of Transportation Premises Liability Statutory Appeal: Other S 0 Product Liability (does not include 0 Employment Dispute: E mass tort) Slander/Libel/ Defamation Discrimination C Other: Employment Dispute: Other Q Zoning Board T Q Other: I Q Other: O MASS TORT E] Asbestos N Q Tobacco Q Toxic Tort -DES Q Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS Toxic Waste Other: El Ejectment 71 Common Law /Statutory Arbitration B El Eminent Domain /Condemnation [] Declaratory Judgment 0 Ground Rent E] Mandamus Land I ord/Tenant Dispute 0 Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABL.ITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto 0 Dental E] Partition Replevin El Legal 0 Quiet Title Other: Medical Other: Q Other Professional: Updated 1/1/2011 FARLEMClients \7619 Dickinson College\ 7619. Collections \7619C.Current \7619C.415 Lonergan \7619C.415.com - C'"3 � r C= < Christopher E. Rice, Esquire - cl cu � - n r Attorney I.D. No. 90916 � ,-. MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER c r � " - MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 = �, ._ (717) 243 -3341 ` 4 Attorneys for Plaintiff y DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2014 - JAMES W. LONERGAN, 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 ell ,�`3 033 77 F1FILES \Clients \7619 Dickinson Collcge\ 7619. Collections \7619C.Current \7619C.415 Lonergan \7619C.415.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. 2014 - II I ' JAMES W. LONERGAN, 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: j 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, James W. Lonergan, is an adult individual with a last known address of 103 Norfield Road, Weston, Connecticut 06883 -2224. 3. On or about July 19, 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 Plaintiffs 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 is $1,500.00. 7. The Note grant Plaintiff reasonable collection and attorneys' fees which Plaintiff has calculated to be $500.00. 8. As of March 6, 2014, the principal and interest due and payable by Defendant to Plaintiff was $1,779.26, 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 $1,779.26, plus interest accruing at 5% per annum thereafter, collection and attorneys' fees in the amount of $500.00 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 $1,779.26, plus interest accruing at 5% per annum thereafter, collection and attorneys' fees in the amount of $500.00 and costs of suit. MARTSON LAW OFFICES By Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 -3093 (717) 243 -3341 Date: !3 /�ji f /�� 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" , PERKINS LOAN MASTER PROMISSORY NOTE — OMB No. 1845.0074 Form n roved Expiration Date 0600/2009 Section A: B orrower , 1. Name (last, fast, middle initial) and 2. So cial Security Number Permanent Address (street, city, state, zip code) ~T ' /1 P 6 4 0 3. Date of Birth ( 7- i i J s/� 4. Hone Area Code/Telephone Number 5. Driver's License Number (List state ahhrr A- `-` Section B: School sectilon 6. School. Name & Address (streak city, state, zip code) 1 7. Annual Interest Rate r DICKINSON COLLEGE 5% PO BOX 1773 CARLISLE, PA 17013 -2896 (Airy bracketed clause or paragraph may be included at option of intuition) Terms and Conditions: (Note: Additional Terms and Conditions follow on subsequent pages) APPLICABLE LAW - The term of this Federal Perhdns Loan Masts Promissory Note (hereinafter called the Note) and any disbursements made under this Note shall be interpreted in accordance with Part E of Title N of the Higher Education Act of 1965, as amended (hereinafter called the Act}, as well as Federal regulations issued under the Act. All sums advanced under this Note ate subject to the Act and Federal regulation issued under the Act. REPAYMF,h'r - I am obligated to repay the principal and the interm that accrues on my loan(s) to the above -named institution (haeinatler piled the School) over a period beginning 9 months (or sooner if I am a Less -Ilan -Half -Time Borrower) after the date I cease to be at least a half-time student at an institution of hlgher education or a comparable School outside the United States approved by the United States Department of Education (hereinafter called the Department) and ending 10 years later, unless I rcqu of in writing that my repayment period begin sooner. I understand that the School will report the amount of my installment payments, along with the amount of this loan to at least one national credit bureau. Interest on this loan shall accrue from the beginning of the repayirerit period. My repayment period may be shorter than 10 years if 1 am requited by my School to make minimum monthly payments. My repayment period may be extended during periods of deferment, hardship. or forbearance and 1 may make graduated instaliments in accordance with a schedule approved by the Department I will intake my installment psymaus in equal monthly, bimonthly, or quarterly installments as deteantined by the School. The School may round my installment payment to the next highest: multiple of SS. (I will make a minimum monthly repayment of S40 (or $30 if 1 have outstanding Federal Per cans Loans arcade before October 1. IM that included the S30 mininantt payment option or outstanding Nationat Direct Student Loans) in accordance with the Minimum Monthly Payment Section of thre Terms and Conditions contained an the reverse side of this document.) LATE CHARGES -The School may Impose late charges if t do not make a scheduled payment when duo or if I fail to submit to the School on or before the due date of the payment. a property documented request for any of the forbearance, defermen% or cancellation benefits as described below. No late charges may exceed 20 percent of my monthly, bimonthly, or quarterly payment. The School may add the late charges to principal the day after the scheduled payment was due or include it with the next scheduled payment after t have received notice of the eh urge, and such notice is sent before the next installment is due. FORBEARANCE, DEFERMENT, OR CANCELLATION - I may apply for a forbearance, defament, or cancellation on my loan. During an approved forbearance period, payments of principal and interest. or principal only, may be postponed or reduced. Interest continues to accrue while my lam is in forbearance, During an approved deferment period, I am not required to make scheduled installment payments on my loan. I am not liable for any interest that aright otherwise aerate while my loan is in deferment. If I meat the eligibility requirements for a cancellation of my loan, the institution may cancel tip to 100 Percent of the numstaading principal loan amount. Information on eligibility and application requirements for forbearances, defements, and cancellations is provided on pages 2 ara13 of this Note. i am responsible fix submitting the appropriate requests on time, and i may lose my benefits i f I fail to file my request on time. DEFAULT - The School may, at its option, declare my loan to be in default if (1) I fail to male a scheduled payment when due; (2)1 fail to submit to the School, on or before the due date of a scheduled payment, documentation that I qualify for a forbearance, dcfennen , or cancellation or (3) I fail to comply with the terms and conditions of this Note or written repayment agreement. The School any assign a defaulted Irian to the Department for collection. I will be ineligible for say furtherfederal student financial assistance authorized under the Act until I make arrangements that arc satisfactory to the School or the Depa amt to repay my loan. The School or the Department shall disclose to credit bureau organizations that I have defaulted and all oilier relevant loan information. I will lose my right defer payments and my right to forbearance if I default on my lout. The School or the Department may accelerate my defaulted loan. Acceleration means that the School or the Department demands immediate payment of the entire unpaid balance of the loan, including principal, interest, late charges, and collodion costa. I will lose my right to receive canccilatiot benefits for service that is performed afhx the date the School or the Department accelerated the loan. CHANGE Of STATUS - I will inform the School of any change in trey name, address, telephone number, Social Security Number, or drive$ license number. PROMISE TO PAY: I promise to pay the School, or t 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 multiple loans may be made to me under this Now I understand that by accepting any disbursements issued at any time under this Note,1 agree to repay the loam I understand that each loan is separately enforceable based on a true and exact copy of this Note. 1 understand that l may cancel or reduce the amount of any loan by not accepting or by returning all or a portion of any disbursement that is issued. U i do not make any payment on any loan under this Note when it is due, I promise to pay all reasonable collection costs, including attorney fees, court costs, and other fees. I will not sign this Note before reading the entire Note, even if h am told that i am not required to read iL t am entitled to an exact copy of this Note. This lain has been made to me without security or endorsement My signature cetifies i have read, understand, and agree to the trans and conditions of this Note. I UNDERY15&D TIIAT I MAY RECEIVE ONE OR MORE LOANS UNDER TIIiS MAS7ER PROMISSORY NOTE AND THAT I MUST REPAY SUCH LOA � B war's Signattue ` ' Date Page t of4 VERIFICATION I, SALLY HECKENDORN, Bursar of Dickinson College, acknowledge that I have the authority to execute this Verification on behalf of Dickinson College and certify that the foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of this lawsuit. The language of this Complaint is that of counsel and not my own. I have read the document and to the extent that this Complaint is based upon information which I have given to my counsel, it is true and correct and to the best of my knowledge, information and belief. To the extent that the content of this Complaint is that of counsel, I have relied upon counsel in making this Verification. This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. Dickinson College Sally Heckendo Bursar Dated: FAFILES \Clients \7619 Dickinson College\ 7619. Collections \7619C.Cuuent \7619C.415 Lonergan \7619C.415.com FAFILES\Clien1517619 Dickinson College\7619.Colleclions\7614C.Current\7619C.415 Lonergan \7619C.4 5.affidavit of service.wpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff f!`E PRO THON3 ; OTTO GILROY & FALLER 20 APR 9 I, CUMBERLAND COUNTY PENNSYLVANIA DICKINSON COLLEGE, Plaintiff V. JAMES W. LONERGAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2014 - 1739 : CIVIL ACTION - LAW AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND I hereby certify that a copy of the Complaint in the above captioned matter was personally served upon James W. Lonergan, at 103 Norfield Road, Weston, CT 06833-2224. Attached is the Return of Service form signed by Connecticut State Marshal John M. McNicholas, showing a cost of service of $55.36. Sworn to and subscribed before me this day April, 2014 MARTSON LAW OFFICES Christopher E. Rice, Esquire Attorney I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 COMMONWEALTH COMMONWEALTh OF PENNSYLVANIA Notarial Seal Mary M. Price, Notary Public Carlisle Dom, Cumberland County Oxmnisslon Expires Aug. 18, 2.015 .T1ON OF NOTARIES '17 This is a debt collecting firm attempting to collect a debt for Dickinson College. Any information obtained will be used for that purpose. STATE OF CONNECTICUT ) SS: WESTON COUNTY OF FAIRFIELD ) APRIL 3, 2014 THEN AND THERE ON THE 3RD DAY OF APRIL, 2014, I MADE DUE AND LEGAL SERVICE OF THE WITHIN AND FOREGOING TRUE COPY OF THE ORIGINAL NOTICE; COMPLAINT; EXHIBIT "A" AND VERIFICATION BY LEAVING A TRUE AND ATTESTED COPY OF THE TRUE COPY OF THE ORIGINAL NOTICE; COMPLAINT; EXHIBIT "A" AND VERIFICATION AT THE ABODE OF: JAMES W. LONERGAN 103 NORFIELD ROAD WESTON, CT 06833 -2224 THE WITHIN AND FOREGOING IS THE TRUE COPY OF THE ORIGINAL NOTICE; COMPLAINT; EXHIBIT "A" AND VERIFICATION WITH MY DOINGS HEREON ENDORSED. SERVICE FEES: SERVICE $ 30.00 PAGES VERIFIED 7.00 ENDORSMENT 1.60 MILEAGE( 21 MI R/T) 11.76 NOTARY FEE 5.00 TOTAL FEES: $ 55.36 SWORN TO BEFORE ME THIS 4TH DAY OF APRIL, 2014 4/04 NOTARY PUBLIC MY COMMISSION EXPIRES t`2 ATTEST: HN M. MCNICHOLAS ONNECTICUT STATE MARSHAL CHIP KEATING NOTARY PUBLIC - CONNECTICUT MY COMM. EXPIRES 12/31/2016 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 Affidavit of Service was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Dated: James W. Lonergan 103 Norfield Road Weston, CT 06833-2224 MARTSON LAW OFFICES Price 10 E st High Street Carlisle, PA 17013 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. 2014 - 1739 JAMES W. LONERGAN, : CIVIL ACTION - LAW Defendant TO: JAMES W. LONERGAN NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the O- day of May, 2014, the following Judgment was entered against you in the above -captioned action: judgment in the amount of $1,779.26, plus interest accruing at the rate of 5% per annum, collection and attorney's fees in the amount of $500.00, and costs of suit, for failure to file an Answer to P1•itiffsmp1 Date: • -Pfothonotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: James W. Lonergan 103 Norfield Road Weston, CT 06833-2224 F:\FILES\Clients\7619 Dickinson College\7619.Collections\7619C.Current\7619C.415 Lonergan\ 7619C.415.pra.default.wpd Christopher E. Rice, Esquire 3 -Of F it:-_., n ,, Attorney I.D. No. 90916 t,; ; 4:in:"',D t i0NtO `,,,r\ MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 2tis 4 tifk( 22 °fti «" 18 - Ten East High Street Carlisle, PA 17013 tj PENN YL Aid A COO -1"Y (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2014 - 1739 JAMES W. LONERGAN, : CIVIL ACTION - LAW Defendant PRAECIPE TO THE PROTHONOTARY: Please enter default judgment in the above -captioned action in favor of Plaintiff and against Defendant James W. Lonergan in the amount of $1,779.26 plus interest accruing at the rate of 5% per annum, collection and attorney's fees in the amount of $500.00, 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 James W. Lonergan on April 29, 2014, which date is subsequent to the date default occurred and at least ten (10) days prior to the date of this Praecipe. Dated: ;11 MARTSON LAW OFFICES By: C-teLt 5'. Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff This is a debt collecting firm attempting to collect a debt for Dickinson College. Any information obtained will be used for that purpose. f F:\FILES\Clients\7619 Dickinson College \7619.Collections\7619C.Current\7619C.4I5 Lonergan \7619C.415.10 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. 2014 - 1739 JAMES W. LONERGAN, : CIVIL ACTION - LAW Defendant IMPORTANT NOTICE TO: James W. Lonergan Date: April 29, 2014 103 Norfield Road, Weston, CT 06833-2224 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITTEN 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. This is a debt collecting firm attempting to collect a debt for Dickinson College. Any information obtained will be used for that purpose. 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 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. 2014 - 1739 JAMES W. LONERGAN, : 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 James W. Lonergan, 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: 103 NOrfield Road, Weston, CT 06833-2224. Said Defendant's place of employment is unknown. Christopher E. Rice, Esquire Sworn to and subscribed before me this&t2L day of May, 2014. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Mary M. Price, Notary Public Carlisle Boro, Cumberland County MY Coistinission Expires Aug. 18, 2015 VANiA ASSAGIA1ION OF NOTARIES F:\FILES\Clients\7619 Dickinson College \7619.Collections\7619C.Current\7619C.415 Lonergan\7619C.415.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. 2014 - 1739 JAMES W. LONERGAN, : 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 James W. Lonergan, was given to him by mail on April 29, 2014. Sworn to and subscribed before me thiso* ti) day of May, 2014. 4 C Christopher E. Rice, Esquire COMMONWEALTH OF PENNSYLVANIA Notarial Seal Mary M. Price, Notary Public Carlisle Boro, Cumberland County My Commission Expires Aug. 18, 2015 M611184$ PENNSYLVANIA ASSOCIATION OF NOTARIES 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: James W. Lonergan 103 Norfield Road Weston, CT 06833-2224 MARTSON LAW OFFICES By Dated: 67020014 Yt, Gae, Ma Price 10 East High Street Carlisle, PA 17013 This is a debt collecting firm attempting to collect a debt for Dickinson College. Any information obtained will be used for that purpose.