The URL can be used to link to this page

Home My WebLink About14-4173 Supreme Co ennsylvania C011ACJM U leas I 14 For Prothonotary Use Only: C il ,. Ver Sheet Docket No: CUMBL`dNb County tin The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or otherpapers as required by law or rules of court. Commencement of Action: S x' Complaint 0 Writ of Summons Petition 0 Transfer from Another Jurisdiction [3 Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Dickinson College Tatia Sikharulidze T Dollar Amount Requested: Owithin arbitration limits I Are money damages requested? El Yes 0 No (check one) outside arbitration limits , O ! N Is this a Class Action Suit? 0 Yes El No Is this an MDJAppeal? 13 Yes El No iA Name of Plaintiff/Appellant's Attorney: David R. Galloway, Esquire I Check here if you have no attorney(are a Self-Represented [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 El Intentional 0 Buyer Plaintiff Administrative Agencies Malicious Prosecution 0 Debt Collection: Credit Card 17 Board of Assessment Motor Vehicle Q Debt Collection: Other 0 Board of Elections 0 Nuisance Dept.of Transportation Premises Liability Statutory Appeal: Other S Product Liability(does not include E mass tort) � Employment Dispute: Slander/Libel/Defamation Discrimination C Other: Employment Dispute: Other Zoning Board ,h Q Other: I Q Other: O MASS TORT [3 Asbestos N 13 Tobacco 0 Toxic Tort-DES [3 Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS Q Toxic Waste Other: � Ejectment E] Common Law/Statutory Arbitration B Eminent Domain/Condemnation Declaratory Judgment Ground Rent ) Mandamus Landlord/Tenant Dispute 13 Non-Domestic Relations M Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY ®-i Mortgage Foreclosure:Commercial 11 Quo Warranto 0 Dental M Partition 0 Replevin E] Legal E3Quiet Title Other: 0 Medical n Other: Other Professional: Updated 1/112011 T� E { Ra i 110�'N0 David R. Galloway Counsel for Plaintiff Attorney I.D.No. 87326 ° JUL IS AM � 23 WALTERS &GALLOWAY,PLLC ;U M B�"i i L r�N D COUNT), 54 E. Main Street PENNSYLVANIA Mechanicsburg,PA 17055 Telephone: (717) 697-4650 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA DICKINSON COLLEGE, ) Plaintiff, ) CIVIL ACTIV. ON--LAW DOCKET NO: ` ! — q(7 ,3 TATIA SIKHARULIDZE, ) Defendant ) JURY TRIAL OF TWELVE DEMANDED NOTICE TO DEFEND 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 an 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 Plaintiff. 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 REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 1-800-990-9108 717-249-3166 3. 7 S � y -11 21130�r 6�S Dickinson/Sikharulidze,Tatia David R. Galloway Counsel for Plaintiff Attorney I.D.No. 87326 WALTERS &GALLOWAY,PLLC 54 E. Main Street Mechanicsburg,PA 17055 Telephone: (717) 697-4650 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY,PENNSYLVANIA DICKINSON COLLEGE, ) Plaintiff, ) CIVIL ACTION--LAW V. ) DOCKET NO: TATIA SIKHARULIDZE, ) Defendant ) JURY TRIAL OF TWELVE DEMANDED COMPLAINT AND NOW, comes Plaintiff, Dickinson College, by and through its attorney, David R. Galloway, Esquire, and files this Complaint and is support avers as follows: 1. Plaintiff Dickinson College (hereinafter "Dickinson") is a. Pennsylvania educational institution with its principal offices located in Carlisle, Cumberland County, Pennsylvania. 2. Defendant Tatia Sikharulidze (hereinafter"Student") is an adult individual whose last known address is 1530 Beacon Street,Apt 1105,Brookline,MA 02446-2640. COUNT BREACH OF CONTRACT 3. Paragraphs 1 through 2 are incorporated herein by reference as if set forth in full below. 4. Student is currently or was recently enrolled at Dickinson. 5. Student opened a Student Receivables Account (hereinafter "Account") with Dickinson to pay tuition, dining service fees and other educational expenses provided and rendered to Student by Dickinson. A true and correct copy of that Account is incorporated by reference and attached as Exhibit"A." 6. Student, by opening the Account and using the goods and services provided by Dickinson, agreed to pay Dickinson for all charges made to the Account. Dickinson/Sikhanxlidze,Tatia 7. Student received and accepted all goods and services provided by Dickinson and thereby agreed to payment for said goods and services. 8. The terms of repayment required Student to pay all balances either 14 (fourteen) days before the beginning of each semester or by the date of Student's graduation, whichever was later. 9. Student defaulted on the repayment of the Account by not paying the balance when due. 10. Notices were forwarded to Student informing her of her default and right to cure such default. 11. Student failed to cure such defaults. 12. Student's last payment on the Account was made January 4,2011. 13. The total amount which is immediately due and payable to Dickinson by Student on the Account is $18,521.37. WHEREFORE, Plaintiff Dickinson College demands judgment against Defendant Tatia Sikharulidze in the sum of$18,521.37,plus late fees, costs of suit, attorney's fees and collection costs, and interest from date of judgment. COUNT II IN OUANTUMMERUIT In the alternative, if this Honorable Court should determine that an express contract between Dickinson and Tatia Sikharulidze does not exist, which is denied, Dickinson pleads the following: 14. Paragraphs 1 through 13 are incorporated herein by reference as if set forth in full. 15. , Because Dickinson loaned money to Student, to the benefit of Student, Student became liable to Dickinson for said money. 16. Student was unjustly enriched by accepting said money without paying Dickinson reasonable compensation therefor. 17. The total amount for which Student has become enriched is $18,521.37. 18. Dickinson demanded payment of the above sums but Student failed and refused to do so. Dickinson/Sikharulidze,Tatia WHEREFORE, Plaintiff Dickinson College demands judgment against Defendant Tatia Sikharulidze in the sum of$18,521.37,plus late fees, costs of suit, attorney's fees and collection costs, and interest from date of judgment. Respectfully Submitted, WALTERS &GALLOWAY, PLLC By: David R. Galloway Counsel for Plainti Diddnson/Sikhatulidze,Tapia VERIFICATION I verify that the facts set forth in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. I am authorized to make this verification on behalf of Dickinson College because of my position as Bursar. Date: ' 3 -ISAI& Slly-Heclyndorn Bursar cDickinson/Sikharulidze,Tatia---� Dickinson/Sikharulidze,Tatia -MAR-2011 09:29:07 AM Dickinson College PAGE 1 .L TERMS Transaction Summary Report TSRTSUM .kharulidze, Tatia 900200316 .TL Description TERM CHARGE PAYMENT BALANCE S EFF DATE RECEIPT ID TRAN TPAY 12E Freshman/Transfer Deposit 201070 500.00 -500.00 D 01-JUL-2010 POWERSD 1 .06 Transcript Fee 201070 25.00 -475.00 R 01-JUL-2010 POWERSD 2 .07 Student Activities Fee Fall 201070 175.00 -300.00 R 01-JUL-2010 POWERSD 3 :98 Tuition Fall 201070 20,585.00 20,285.00 R 01-JUL-2010 POWERSD 4 .02 Housing - Fall 201070 2,690,00 22,975.00 B 01-JUL-2010 POWERSD 5 iO4 Meal Plan - Fall 201070 2,525.00 25,500.00 V 01-JUL-2010 POWERSD 6 :98 Tuition Fall 201070 20,585.00 46,085.00 R 06-JUL-2010 HECKENDO 7 :96 Tuition Fall 201070 -20,585.00 25,500.00 R 06-JUL HECKENDO 8 .35 Student Health Insurance 201070 999.00 26,499.00 T 26-AUG-2010 ARUSER 9 •74 Tuition Mgmt Systems Payment 201070 25,500.00 999.00 T 31-AUG-2010 POWERSD 10 ;S0 BKSTR - Pa Sales Tax 201070 1.58 1,000.58 T 01-OCT-2010 ARUSER 11 ISl BKSTR -. Text Books 201070 124.50 1,125.08 T 01-OCT-2010 ARUSER 12 ,S3 BKSTR Supplies 201070 4.78 1,129.86 T 01-OCT-2010 ARUSER 13 67 BKSTR Miscellaneous 201070 30.89 1,160.75 T 01-OCT-2010 ARUSER 14 .02 Finance Charge 201070 14.99 1,175.74 L 04-OCT-2010 POWERSD 15 !SO BKSTR - Pa Sales Tax 201070 .30 1,176.04 T 01-NOV-2010 ARUSER 16 IS7 BKSTR - Miscellaneous 201070 4.99 1,181.03 T 01-NOV-2010 ARUSER 17 .31 Dining Services 201070 5.55 1,186.58 T 01-NOV-2010 ARUSER 18 .46 Health Center Charge 201070 25.00 1,211.58 T 01-NOV-2010 ARUSER 19 .02 Finance Charge 201070 17.64 1,229.22 L 02-NOV-2010 POWERSD 20 .02 Finance Charge 201070 18.44 1,247.66 L 01-DEC-2010 POWERSD 21 .08 Student Activities Fee Spring 201120 175.00 1,422.66 R 01-DEC-2010 POWERSD 27 '99 Tuition Spring 201120 20,585.00 22,007.66 R 01-DEC-2010 POWERSD 23 403 Housing - Spring 201120 2,690.00 24,697.66 B 01-DEC-2010 POWERSD 29 305 Meal Plan - Spring 201120 2,525.00 27,222.66 V 01-DEC-2010 POWERSD 25 474 TMS Cancelled 201070 -25.,5.8.0,005..2.,,Z22.66 T 04-JAN-2011 POWERSD 26 474 TMS paid to date 201070 ;8,50 ,00 44 22266 � O -JAN-2011 POWERSD 27 L08 Student Activities Fee Spring 201120 -175.00 44,047.66-R=- 7lN 2OI GOLEMBEM 28 ?99 Tuition Spring 201120 -20,585.00 23,462.66 R 13-JAN-2011 GOLEMBEM 29 103 Housing - Spring 201120 -2,690.00 20,772.66 B 18-JAN-2011 . HECKENDO 30 305 Meal Plan - Spring 201120 -2,525.00 18,247..666VV 19-JAN-2011 HECKENDO 31 TOTAL: 27,247.66 9,000.00 x'47 66 + 4-1-' ,id ilance Due: 18,247.66 Future Due: .00 Account Balance: 18,247.66 NSF Count: 0 David R. Galloway Counsel for Plaintiff WALTERS & GALLOWAY, PLLC Attorney I.D. No. 87326 54 E. Main Street Mechanicsburg, PA 17055 Telephone: (717) 697-4650 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA DICKINSON COLLEGE, ) CIVIL ACTION—LAW Plaintiff, ) v. ) ) DOCKET NO: 14-4173 TATIA SIKHARULIDZE, ) Defendants ) PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Please reinstate the complaint filed in the above captioned action. Respectfully submitted, rn WALTERS & GALLOWAY, PLLC v,'' c By: David R. Galloway# 7326 Counsel for Plaintif O (P. q PI C# 13a.2) • ,#"3/ 757 David R. Galloway Attorney LD. No. 87326 WALTERS & GALLOWAY, PLLC 54 E. Main Street Mechanicsburg, PA 17055 Telephone: (717) 697-4650 OF THE PROTHON°1 ounsel for Plaintiff Mil OCT 3 1 P11 1 ; 03 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DICKINSON COLLEGE, v. TATIA SIKHARULIDZE, Plaintiff, Defendant, CIVIL ACTION --LAW DOCKET NO: 14-4173 PRAECIPE TO DOCUMENT SERVICE AND COST OF SERVICE PURSUANT TO THE PENNSYLVANIA LONG ARM STATUTE TO THE PROTHONOTARY: I hereby certify that a copy of the Complaint was served on Tatia Sikharulidze, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed and dated October 7, 2014, and a copy of the receipt showing the cost of service was $12.05. CERTIFICATE OF SERVICE I, David R. Galloway, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Mechanicsburg, PA, first-class mail, postage pre -paid, addressed as follows. Date: October 21 , 2014 Tatia Sikharulidze 85 E India Row, Apt 11EF Boston, MA 02110 Respectfully submitted, WALTERS & GALLOWAY, PLLC By: David R. Gallowa Counsel for Plain iff SENDER: COMPLETE THIS SECTION • Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. • Print your name and address on the reverse so that we can retum the card to you. • Attach this card to the back of the mailpiece, or on the front if space permits. . Article Addressed to: —TGlt1C{ r i d i ck `35 E IrydC,t 4o ap 11 EF 130slen, our 02 i 1D COMPLETE THIS SECTION ON DELIVERY A. Signature X / 0 Agent O Addressee B. Received by ( Printed a a (c, D. is delivery address different from iteral?' ❑ Yes 0 No eof}De' eft of If YES, enter deliv 3. Service Type el Certified Mall ❑ Registered 0 Insured Mall fIssit 0 C.O.D. M 0 eceipt for Merchandise 4. Restricted Delivery? (Extra Fee) ,m y 2. Article Number (Transfer from service label) 7003 1010 0000 8126 0102 PS Form 3811, August 2001 Domestic Return Receipt 10259502-M-1540 0 ra -n r1J r-4 =O c3 U.S. Postal ServiceTM CERTIFIED MAIL. RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.0spscomaOnfflCtI USE Postage Certified Fee C3 C3 Retum Reciept Fee (Endorsement Required) CZI Restricted Delivery Fee (Endorsement Required) rn I3 12 Total Postage 8 Fee s N STA 410 gqstm '�Ien i 11/ PS Form 3800, June 2002