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HomeMy WebLinkAbout14-4815 Supreme Court -ennsylvania : r Cour of- oPleas For Prothonotary Use Only: 4 44 51 CIVil,Cover1Sh&t Docket No: 1 CUMBERLQN6 County r<y � The information collected on this form is used solelv,for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S Q Complaint 0 Writ of Summons 0 Petition 0 Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff s Name: Lead Defendant's Name: T Dickinson College John Aryeetey Dollar Amount Requested: Mwithin arbitration limits Y Are money damages requested. X�Yes � No (check one) E3outside arbitration limits N Is this a Class Action Suit? El Yes 0 No Is this an MDJAppeal? Yes 21 No A Name of Plaintiff/Appellant's Attorney: Christopher E. Rice, Esquire/Martson Law Offices 0 Check Isere if you have no attorney(are a Self-Represented {Pro Ser I..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 0 Intentional M Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Debt Collection: Credit Card 0 Board of Assessment IO Motor Vehicle iX Debt Collection: Other 0 Board of Elections M Nuisance Unpaid Student Loans El Dept.of Transportation Premises Liability El Statutory Appeal: Other S Product Liability(does not include E mass tort) El Employment Dispute: Slander/Libel/Defamation Discrimination C 0 Other: El Employment Dispute: Other r7 Zoning Board T El Other: I 0 Other: O MASS TORT 0 Asbestos N 0 Tobacco 0 Toxic Tort-DES Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS Toxic Waste B ElOther: El Ejectment � Common Law/Statutory Arbitration El Eminent Domain/Condemnation E] Declaratory Judgment El Ground Rent © Mandamus 0 Landlord/Tenant Dispute 0 Non-Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto El Dental 0 Partition 0 Replevin El Legal 0 Quiet Title Other: 0 Medical F1 Other: 0 Other Professional: Updated 1/1/2011 Christopher E. Rice, Esquire Attorney I.D. No. 90916 , AUG 14 1 3 MARTSON DEARDORFF WILLIAMS OTTO GILROY& F USTy MARTSON LAW OFFICES cumBERL Ten East High Street PCs iSYLVA �� Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA • L V. NO. 2014 - �/ Cluj JOHN ARYEETEY, 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 a4 3 09 �O FAFILES\Clients\7619 Dickinson College\7619,Collections\7619C.Current\7619C.430 Aryeetey\7619C.430.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 - JOHN ARYEETEY, 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, John Aryeetey,is an adult individual with a last known address of 6955 Chilkat Court, Atlanta, Georgia 30331. COUNT BREACH OF CONTRACT 3. On or about August 27, 2005, Defendant entered into a Abe and Cora Hurwitz Student Loan ("Loan One") with Plaintiff for the financing of a loan, plus interest and costs, for educational services and benefits at Plaintiff's institution. A copy of Loan One is attached hereto as Exhibit"A." 4. The principal amount for Loan One was $5,000.00. 5. On or about August 18, 2006, Defendant entered into a Abe and Cora Hurwitz Student Loan ("Loan Two") with Plaintiff for the financing of a loan, plus interest and costs, for educational services and benefits at Plaintiff s institution. A copy of Loan Two is attached hereto as Exhibit `B." 6. The principal amount for Loan Two was $5,500.00. 7. On or about July 5, 2007, Defendant entered into a Abe and Cora Hurwitz Student Loan("Loan Three")with Plaintiff for the financing of a loan,plus interest and costs,for educational services and benefits at Plaintiff's institution. A copy of Loan Three is attached hereto as Exhibit"C". 8. The principal amount for Loan Three was $5,900.00. 9. On or about July 9, 2008, Defendant entered into a Abe and Cora Hurwitz Student Loan ("Loan") with Plaintiff for the financing of a loan, plus interest and costs, for educational services and benefits at Plaintiff's institution. A copy of Loan Four is attached hereto as Exhibit"D". 10. The principal amount for Loan Four was $3,050.00. 11. Loan One, Loan Two, Loan Three and Loan Four are referred to as the "Loans" herein. 12. As of June 11, 2014, the principal and interest due and payable by Defendant to Plaintiff under the Loans was $21,552.43, with interest accruing at 5%per annum. 13. The Loans grant Plaintiff reasonable collection and attorneys'fees which Plaintiff has calculated to be $3,000.00. 14. Plaintiff has fulfilled,performed and complied with all obligations and conditions of the Loans. 15. Plaintiff has made demand for payment of the Loans, but Defendant has failed to comply. WHEREFORE,Plaintiff demands judgment against Defendant in the amount of$24,552.43, plus interest and other reasonable collection costs, fees and charges. COUNT III IN QUANTUM MER UIT 16. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 15 of this Complaint. 17. In the alternative,if a contract is found not to exist,then Defendant has been unjustly enriched. 18. Having requested Plaintiff to loan money,and doing so to the benefit of Defendant, Defendant became liable to Plaintiff for said money. 19. 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$21,552.43, plus interest and other reasonable collection costs and charges. MARTSON LAW OFFICES By L// 4 (� '/t Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: August 14, 2014 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" 1 / J ABE AND CORA HURWITZ STUDENT LOAN DICKINSON COLLEGE CARLISLE,PENNSYLVANIA 17013-2896 Loan Number: Date:. August 27,2005 I,John Aryeetey,hereby acknowledge receipt from Dickinso College, (hereinafter "College'),of a Hurwitz Loan in the principle amount of$5000.00w hich is hereby applied on my College account for the academic year. I agree to repay the College according to the following plan: I, Interest Interest shall accrue on the outstanding principle balance from the first day of the month following the initial six(6)month grace period in which I graduate or cease to matriculate at the College, and shall be at the FIXED ANNUAL PERCENTAGE RATE of 5.000 percent(5%). Interest shall accrue on a daily basis. II. Repayment I promise to repay the principal and the interest,which accrues thereon commencing six (6) months after the date I graduate or cease to matriculate at the College. I will repay in equal monthly installments with a minimum monthly payment of$40.00(which includes both principal and interest), and a maximum repayment period of tem(10)years(120 months). The College may,at its option, grant an additional deferment period of up to four(4) years for full-time study after a student leaves Dickinson College. III. Default I shall have been deemed to have committed an"Event of Default"of this Contract upon the I occurrence of any of the following: • Failing to make any payment on or before the date it is due, • Failing to make a payment on any other Contract outstanding with the College, • Failing to perform any other provision of this Contract, • Providing the College with false information or signatures, • My death,incompetence, or conviction of any crime involving fraud or dishonesty, insolvency or bankruptcy. Upon or after the occurrence of any Event of Default, the College will provide me with notice,by certified mail as required by law, addressed to my last known address as shown on the College records, advising me of the default and of my right to cure the default. The notice will provide the time, amount and performance necessary to cure the default. If I do not cure the default as provided in the notice, the College's rights include the right to declare all sums due on this available in equity. I agree to pay all attorney's fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. Unless otherwise specified in a legal proceeding relating to the subject matter hereof, I agree that attorney's fees shall be 15% of the Principle Amount. 1 I understand that if I default on my loan repayment,the College may disclose that I have defaulted, along with other relevant information, to credit bureau organizations. IV. Penalty Charge If I fail to make timely payment of all or any part of a scheduled installment,I promise to pay the charge assessed against me by the College. No charge may exceed$1.00 for the first month or part of a month by which the installment is late,and$2.00 for each month or part of a month thereafter. I promise to pay all attorney fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. V. Change of Status It is my responsibility to notify the Dickinson College Financial Operations Office, or its servicing agent, Campus Partners, of any change of name, address,telephone number or Social Security Number during the duration of this repayment period. VI. Additional Provisions In deference to the Hurwitz family for their generosity in providing these loan funds, I hereby authorize the College to notify the family of my acceptance of this loan and the principle dollar amount of the loan. If any part of this Contract is held to be illegal,void or unenforceable,that provision shall be deemed not to have been a part of this Contract,which shall otherwise remain fully effective. CONSENT TO JURISDICTION VENUE AND SERVICE: The parties to this Contract consent and agree that all legal proceedings relating to the subject matter hereof shall be maintained in the Court of Common Pleas of Cumberland County,Pennsylvania,or if applicable,the United States District Court of the Middle District of Pennsylvania, and all parties hereto consent and agree that jurisdiction and venue for such proceedings shall lie exclusively within said courts. Service of. process in any such proceeding may be made by certified mail,return receipt requested,direct to the respective party at the address last made known to the other party. The Borrower acknowledges receiving a completed copy of this Contract and intends to be legally bound by its terms. Signed and sealed this 31 k day of Aug S'-6 20 0 1� . Student Signature (SEAL) Student Social Security Number_ Student ID#: _ 2 EXHIBIT "B" 00 ® 22 - 06 ABE AND CORA HURWITZ STUDENT LOAN DICKINSON COLLEGE CARLISLE, PENNSYLVANIA 17013-2896 August 18, 2006 I, John Aryeetey, hereby acknowledge receipt from Dickinson College,. (hereinafter"College"), of a Hurwitz Loan in the principle amount of $5500, which is hereby applied on my College account for the academic year 2006- 2007, I agree to repay the College according to the following plan: I. Interest Interest shall accrue on the outstanding principle balance from the first day of the month following the initial six (6)month grace period in which I graduate or cease to matriculate at the College, and shall be at the FIXED ANNUAL PERCENTAGE RATE of 5.000 percent (5%). Interest shall accrue on a daily basis. II. Repayment I promise to repay the principal and the interest, which accrues thereon commencing six(6)months after the date I graduate or cease to matriculate at the College. I will repay in equal monthly installments with a minimum monthly payment of$40.00 (which includes both principal and interest), and a maximum repayment period often (10) years (120 months). The College may, at its option, grant an additional deferment period of up to four (4)years for full-time study after a student leaves Dickinson College. III. Default I shall have been deemed to have committed an "Event of Default" of this Contract upon to occurrence of any of the following: • Failing to make any payment on or before the date it is due, • Failing to make a payment on any other Contract outstanding with the College, • Failing to perform any other provision of this Contract, • Providing the College with false information or signatures, • My death, incompetence, or conviction of any crime involving fraud or dishonesty, insolvency or bankruptcy. Upon or after the occurrence of any Event of Default, the College will provide me with notice, by certified mail as required by law, addressed to my last known address as shown on the College records, advising me of the default and of my right to cure the default. The notice will provide the time, amount and performance necessary to cure the default. If I do not cure the default as provided in the notice, the College's rights include the right to declare all sums due on this available in equity. I agree to pay all attorney's fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. Unless otherwise specified in a legal proceeding relating to the subject matter hereof, I agree that attorney's fees shall be 15% of the Principle Amount. I understand that if I default on my loan repayment, the College may disclose that I have defaulted, along with other relevant information, to credit bureau organizations. IV. Penalty Charge If I fail to make timely payment of all or any part of a scheduled installment, I promise to pay the charge assessed against me by the College. No charge may exceed $1.00 for the first month or part of a month by which the installment is late, and $2.00 for each month or part of a month thereafter. I promise to pay all attorney fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. V. Change of Status It is my responsibility to notify the Dickinson College Financial Operations Office, or its servicing agent, Campus Partners, of any change of name, address, telephone number or Social Security Number during the duration of this repayment period. VI. Additional Provisions In deference to the Hurwitz family for their generosity in providing these loan funds, I hereby authorize the College to notify the family of my acceptance of this loan and the principle dollar amount of the loan. If any part of this Contract is held to be illegal, void or unenforceable, that provision shall be deemed not to have been a part of this Contract, which shall otherwise remain fully effective. CONSENT TO JURISDICTION, VENUE AND SERVICE: The parties to this Contract consent and agree that all legal proceedings relating to the subject matter hereof shall be maintained in the Court of Common Pleas of Cumberland County, Pennsylvania, or if applicable, the United States District Court of the Middle District of Pennsylvania, and all parties hereto consent and agree that jurisdiction and venue for such proceedings shall he exclusively within said courts. Service of process in any such proceeding may be made by certified mail, return receipt requested, direct to the respective party at the address last made known to the other party. The Borrower acknowledges receiving a completed copy of this Contract and intends to be legally bound by its terms. Signed and sealed this ,Zr4 day of A ust , 20 o 6 . Student Signature (SEAL) Student Social Securitv Number Student ID#: EXHIBIT "C" Read Mail ABE AND CORA HURWITZ STUDENT LOAN DICKINSON COLLEGE CARLISLE,PENNSYLVANIA 17013-2896 Date: July 5,2007 I,John Aryeetey,hereby acknowledge receipt from Dickinson College, (hereinafter"College"),of a Hurwitz Loan in the principle amount of$5900.00,which is hereby applied on my College account for the academic year 2007-2008. 1 agree to repay the College according to the following plan: I. Interest Interest shall accrue on the outstanding principle balance from the first day of the month following the initial six(6)month grace period in which I graduate or cease to matriculate at the j College, and shall be at the FIXED ANNUAL PERCENTAGE RATE of 5.000 percent(51/6). Interest shall accrue on a daily basis. II. Repayment I I promise to repay the principal and the interest,which accrues thereon commencing six(6) months after the date I graduate or cease to matriculate at the College. I will repay in equal monthly installments with a minimum monthly payment of$40.00(which includes both principal and interest),and a maximum repayment period of tem(10)years(120 months). The College may,at its option,grant an additional deferment period of up to four(4)years for full-tune study after a student leaves Dickinson College. i III. Default I I shall have been deemed to have committed an"Event of Default"of this Contract upon the occurrence of any of the following: • Failing to make any payment on or before the date it is due, • Failing to make a payment on any other Contract outstanding with the College, • Failing to perform any other provision of this Contract, • Providing the College with false information or signatures, • My death,incompetence,or conviction of any crime involving fraud or dishonesty,insolvency or bankruptcy. Upon or after the occurrence of any Event of Default,the College will provide me with notice,by certified mail as required by law,addressed to my last known address as shown on the College records,advising me of the default and of my right to cure the default. The notice will provide the time,amount and performance necessary to cure the default. If I do not cure the default as provided in the notice,the College's rights include the right to declare all sums due on this available in equity. I agree to pay all attorney's fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. Unless otherwise specified in a legal proceeding relating to the subject matter hereof,I agree that attorney's fees shall be 15%of the Principle Amount. I understand that if I default on my loan repayment,the College may disclose that I have defaulted,along with other relevant information,to credit bureau organizations. IV. Penalty Charge If I fail to make timely payment of all or any part of a scheduled installment,I promise to pay the charge assessed against me by the College. No charge may exceed$1.00 for the first month or part of a month by which the installment is late, and$2.00 for each month or part of a month thereafter. I promise to pay all attorney fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. V. Change of Status It is my responsibility to notify the Dickinson College Financial Operations Office,or its servicing agent,Campus Partners,of any change of name, address,telephone number or Social Security Number during the duration of this repayment period. VI. Additional Provisions In deference to the Hurwitz family for their generosity in providing these loan funds,I hereby authorize the College to notify the family of my acceptance of this loan and the principle dollar amount of the loan. If any part of this Contract is held to be illegal,void or unenforceable,that provision shall be deemed not to have been a part of this Contract,which shall otherwise remain fully effective. CONSENT TO JURISDICTION,VENUE AND SERVICE: The parties to this Contract consent and agree that all legal proceedings relating to the subject matter hereof shall be maintained in the Court of Common Pleas of Cumberland County,Pennsylvania,or if applicable,the United States District Court of the Middle District of Pennsylvania,and all parties hereto consent and agree that jurisdiction and venue for such proceedings shall lie exclusively within said courts. Service of process in any such proceeding may be made by certified mail,return receipt requested,direct to the respective party at the address last made known to the other party. The Borrower acknowledges receiving a completed copy of this Contract and intends to e legally bound by its terms. Signed and sealed this 4 `day of J u 20 . Student Signature (SEAL) Student Social Security Number Student ID#: EXHIBIT 66D99 R AEE AND CORA HURWITZ STUDENT LOAN DICKINSON COLLEGE CARLISLE, PENNSYLVANIA 17013-2896 Date: July 9,2008 'V6D4a I,John Aryeetey,hereby acknowledge receiptAom Dickinson College,(hereinafter"College"),of a Hurwitz Loan in the principle amount of$6M.00,which is hereby applied on my College account for the academic year 2008-2009, 1 agr4to repay the College according to the following plan: 1. Interest Interest shall accrue on the outstanding principle balance from the first day of the month following the initial six(6)month grace period in which I graduate or cease to matriculate at the College, and shall be at the FIXED ANNUAL PERCENTAGE RATE of 5.000 percent(5%). Interest shall accrue on a daily basis. 11. Repayment I promise to repay the principal and the interest,which accrues thereon commencing six(6) months after the date I graduate or cease to matriculate at the College. I will repay in equal monthly installments with a minimum monthly payment of$40.00(which includes both principal and interest),and a maximum repayment period of tem(10)years(120 months). The College may,at its option,grant an additional deferment period of up to four(4)years for full-time study after a student leaves Dickinson College. Ill. Default I shall have been deemed to have committed an"Event of Default"of this Contract upon the occurrence of any of the following: Failing to make any payment on or before the date it is due, *Failing to make a payment on any other Contract outstanding with the College, Failing to perform any other provision of this Contract, *Providing the College with false information or signatures, i I r My death,incompetence,or conviction of any crime involving fraud or dishonesty,insolvency or bankruptcy. Upon or after the occurrence of any Event of Default,the College will provide me with notice, by certified mail as required by law,addressed to my last known address as shown on the College records,advlsing me of the default and of my right to cure the default The notice will provide the time,amount and performance necessary to cure the default. If I do not cure the default as provided in the notice,the College's rights include the right to declare all sums due on this available in equity. 1 agree to pay all attorney's fee's and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. Unless otherwise specified in a legal proceeding relating to the subject matter hereof, I agree that attorney's fees shall be 15%of the Principle Amount. I understand that If I default on my loan repayment,the College may disclose that I have defaulted,along with other relevant information,to credit bureau organizations. IV. Penalty Charge If I fail to make timely payment of all or any part of a scheduled'installment,I promise to pay the charge assessed against me by the College. No charge may exceed$1.00 for the first month or part of a month by which the Installment is late,and$2.00 for each month or part of a month thereafter, I promise to pay all attorney fees and other reasonable collection costs and charges necessary for the collection of any amount not paid when due. V. Change of Status It is my responsibility to notify the Dickinson College Financial Operations Office,or its servicing agent,Campus Partners,of any change of name,address,telephone number or Social Security Number during the duration of this repayment period. VI. Additional Provisions In deference to the Hurwitz family for their generosity in providing these loan funds,I hereby authorize the College to notify the family of my acceptance of this loan and the principle dollar amount of the loan. If any part of this Contract Is held to be illegal,void or unenforceable,that provision shall be I deemed not to have been a part of this Contract,which shall otherwise remain fully effective. I i f y 1. ._._......... CONSENT TO JURISDICTION,VENUE AND SERVICE: The parties to this Contract consent and agree that all legal proceedings relating to the subject matter hereof shall be maintained in the Court of Common Pleas of Cumberland County,Pennsylvania,or if applicable, the United States District Court of the Middle District of Pennsylvania,and all parties hereto consent and agree that jurisdiction and venue for such proceedings shall lie exclusively within said courts. Service of process In any such proceeding may be made by certified mail,return receipt requested,direct to the respective party at the address last made known to the other party. The Borrower acknowledges receiving a completed copy of this.C-gatract and intends to be legally,pound by its terms. Signed and sealed this ' 1`y'� day of 20 Student Signature �� (SEAL) Student Social Security Number r -- Student ID#: 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 By: Sally Hecke orn, Bursar Dated: �/`�i j� FAFILES\Clients\7619 Dickinson College\7619.Collections\7619C.Current\7619C.430 Aryeetey\7619C.430.com t F:\FILES\Clients\7619 Dickinson College\7619.Collections\7619C.Current\7619C.430 Aryeetey \ 7619C.430.as.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, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2014 - 4815 rrl CID JOHN ARYEETEY, : CIVIL ACTION - LAW Defendant "'< > AFFIDAVIT OF SERVICE =c) COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) I hereby certify that a Complaint in the above captioned matter was served upon Defendant, John Aryeetey, by certified mail, restricted delivery, return receipt requested, at 6955 Chilkat Court, Atlanta, GA 30331. Attached is the return receipt card signed by John Aryeetey on August 18, 2014, with receipt of costs in the amount of $12.66. MARTSON LAW OFFICES By «t, 5/-- 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 9 day of September, 2014. C).144 -e/ Nrta i�•ublic COMMONWEALTH OF PENNSYLVANIA LNotarial Seal Mary M. Price, Notary Public Carlisle Boro, Cumberland County My Commission Explres Aug. 18, 2015 MEMBER, PENNSYLVANIA ASSOGIA1IAN (M NOTARIES SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY A.N ON DELIV • Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. IN Print your name and address on the reverse so that we can return the card to you. • Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Ss ) OE 53/ 7°'/,,, ❑ Agent ❑ Addressee Received by (Printed Name) C. Date of Delivery 7WE VW/Pt D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No 3. Service Type ertified Mail® 0 Priority Mail Express'" Registered 0 Return Receipt for Merchandise ❑ Insured Mail 0 Collect on Delivery 4. Restricted Delivery? (Extra Fee) jes 2. Article Number (Transfer from service labeIi 7014 0510 0002 3751 2059 PS Form 3811, July 2013 111 D Domestic Return Receipt U.S. Postal Service,. CERTIFIED MAIL,. RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.come OG FDCfIL USE Postage Certified Fee Retum Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage 8 Fees $ 76( 330 a.7o 5".o 5� $ Street,$p fNo.; or PO Box No. Oily, State, ZIP+4 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 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: John Aryeetey 6955 Chilkat Court Atlanta, GA 30331 MARTSON LAW OFFICES By re Mry1 Price 10 E st High Street Carlisle, PA 17013 Dated: 47//pA7 This is a debt collecting firm for Dickinson College attempting to collect a debt. Any information obtained will be used for that purpose.