HomeMy WebLinkAbout14-4962 V
7 4.
Supreme Connsylvania
14
Cour"t f.Co`mmo leas For Prothonotary Use Only:
Cill.. `bve `Shee't
Docket No:
.Cumberland , County
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 other papers as required by law or rules of court.
Commencement of Action:
S Ix Complaint 'J Writ of Summons Il Petition
❑ Transfer from Another Jurisdiction J Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
DREXEL UNIVERSITY VANESSA R. PAPALAZAROS
T Dollar Amount Requested: lJ within arbitration limits
I Are moneydamages requested? 2 Yes ❑ No
g 9 (check one) ❑outside arbitration limits
i 0
N Is this a Class Action Suit? ❑u Yes ED No Is this an MDJAppeal? Yes a No
A Name of Plaintiff/Appellant's Attorney: J. Scott Watson, Esquire
El 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
ID Intentional IJ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution I`il Debt Collection:Credit Card !-1 Board of Assessment
Motor Vehicle Xi' Debt Collection:Other ❑ Board of Elections
Nuisance Breach of Contract EJ Dept.of Transportation
Premises Liability LN Statutory Appeal:Other
S Ii Product Liability(does not include
mass tort) ❑ Employment Dispute:
E E] Slander/Libel/Defamation Discrimination
C ❑ Other: Employment Dispute:Other hJ Zoning Board
0Other:
,I,
I 3 Other:
MASS TORT
Ci Asbestos
N 0 Tobacco
fJ Toxic Tort-DES
0 Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
n Toxic Waste 3 Ejectment E] Common Law/Statutory Arbitration
B ❑ Other: 0❑ Eminent Domain/Condemnation
❑ Declaratory Judgment
i Ground Rent ❑ Mandamus
❑1 Landlord/Tenant Dispute 0 Non-Domestic Relations
E] Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure:Commercial 0 Quo Warranto
I- Dental ❑ Partition 0 Replevin
Legal Cl Quiet Title 0 Other:
❑ Medical J Other:
ri Other Professional:
Updated 1/112011
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DREXEL UNIVERSITY CUMBERLAND COUNTY
32"& Chestnut Streets COURT OF COMMON PLEAS
Philadelphia, PA 19104 Y
V.
VANESSA R. PAPALAZAROS
8 Ladnor Lane c�nryCD
Carlisle, PA 17015-9215
Z5 c'{f
NOTICE TO DEFEND +
� c�a
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 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 TO
FIND WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(800) 990-9108
(717) 249-3166
v
J. SCOTT WATSON,P.C.
BY: J. SCOTT WATSON, ESQUIRE
Identification Number 41060
24 Regency Plaza
Glen Mills,Pennsylvania 19342
(610) 358-9600 Attorney for Plaintiff
DREXEL UNIVERSITY CUMBERLAND COUNTY
32"d& Chestnut Streets COURT OF COMMON PLEAS
Philadelphia, PA 19104
V.
VANESSA R. PAPALAZAROS
8 Ladnor Lane
Carlisle, PA 17015-9215
COMPLAINT IN CIVIL ACTION
1. The Plaintiff, Drexel University, is'a corporation not for profit, organized and
existing under the Laws of the Commonwealth of Pennsylvania located at 32"d & Chestnut
Streets, Philadelphia, Pennsylvania 19104.
2. The Defendant, Vanessa R. Papalazaros, is an individual and citizen of the
Commonwealth of Pennsylvania, residing at 8 Ladnor Lane, Carlisle, Pennsylvania 17015-9215.
3. At the special insistence and request of the Defendant, while the Defendant was
enrolled at Drexel University,the Defendant executed three (3) Promissory Notes, pursuant to
which the Defendant was advanced by the Plaintiff the sum of$11,000.00 as Federal Perkins
Student Loans. True and correct copies of the Promissory Note, setting forth the amounts and
dates of the advancements, are attached hereto, made a part hereof and marked as Exhibit "A".
4. The Defendant defaulted upon the terms of the Promissory Notes and has an
unpaid principal balance of$11,000.00, together with accrued interest of$2,383.16 and late
charges of$29.00.
5. Pursuant to the terms of the Promissory Notes attached hereto as Exhibit "A",the
Defendant agreed that in the event of a failure to meet scheduled repayment of any installments
due on said note, the entire unpaid indebtedness, including interest due and accrued thereon,
shall, at the option of the Plaintiff, become immediately due and payable.
6. Pursuant to the terms of the Promissory Notes attached hereto as Exhibit "A", the
Defendant agreed to pay reasonable attorney fees and other cost and charges necessary for the
collection of any amount not paid when due.
7. The Plaintiff has incurred expenses, including legal fees, as a result of having
instituted this action and will be obliged to incur similar obligations in the future.
8. Defendant has breached her contract with Plaintiff by not paying said balance due.
Wherefore, Plaintiff demands judgement against the Defendant in the amount of
$13,412.16,together with reasonable attorney's fees, interest from the date of judgment and
anticipated court costs of$215.75.
J. SCOTT WATSON,ESQUIRE
Attorney for Plaintiff
1 J
FEDERAL PERKINS LOAN MASTER PROMISSORY NOTE
OMB No.1845-0074 Form Approved Eoratlan Date 6/30/2006
Section • 1 1
1. Name(last,first,middle initial)and 2. Social Security Number
Permanent Address(street,city,state,Zip code)
3. Date of Birth(mlTl/dd/yyyy)
Papalasaros,Vanessa,R
5501 Wayne Ave Apt 4026
Philadelphia, PA 19144 4. Area Codefrelephone Number
5. Driver's License Number(List state abbrevlatlon first)
Section B: School Section
6 School Name&Address(street city,state, zip 7. Annual Interest Rate
code)
DREXEL UNIVERSITY(00325600)
3141 Chestnut Street 5.00%
Philadelphia,PA 19104
[Arty bracketed clause or paragraph may be included at option of institution]
Terms and Conditions:(Note:Additional Terms and Conditions follow on subsequent pages)
APPLICABLE LAW-The terms of this Federal Perkins Loan Master Promissory Note(hereinafter called the Note)and any disbursements made under this Note shall be interpreted in
t accordance witb Part E of Title IV of the Higher Education Act of 1965,as amended(hereinafter called the Ad),as well as Federal regulations Issued under the Act All sums advanced under this
Note ata subject to the Act and Federal regulations issued under the Act
REPAYMENT-i aon obligated to repay the principal and the interest that accrues on my loon($)to the abovommried insulation(hereinafter called the School)over a period beginning 9 months
(or sooner if I am a less-Than-Half-Tac Borrower)after the date 1 cease to be at least a half-time student at an institution of higher education or a comparable Scholl outside the United States
approved by the United States Department of Education(hereinafter called the Depamnent)and ending 10 years later,unless 1 request in writing that my repayment period begin sooner,l
` understand that the School will report the amount army tnstagment Payments,along with the amount of this loan to at least one national credit bureau Interest on this leen shall accrue from the
tui{ beginning of the repayment period My repayment period maybe shorter than 10 years if I am required by my School to make minimum monthly payments My repayacnt period may be extended
during pends ofdefurrie nt,hardship,or forbearance and i may make graduated installments in accordance with a schedule approved by the Department 1 will make tory insialhnem payments in
equal monthly,bimonthly,or quarterly mstallmeots as determined by the School.The School may round my installment payment to the next highest multiple of S5 p will make a minimum
monthly repayment of$40(or$30 if I base outstanding Federal Perkins Loans made before October 1,1992 that included the S30 minimum payment option or outstanding National Direct
Student Loans)in accordance with the Minimum Monthly Payment Section of the Terns and Conditions contained on the reverse side of this document)
LATE CHARGES-The School may impose late charges if I do not make a scheduled payment when due or if I fail to submit to the School on or berbre the due date of the payment,a properly
documented request for any of the forbearance,deferment.or cancellation benefits u described below. No fait charges may exomd 20 percent of my momthly,i bnouthly,or gaanedy payment.Th
School may add the late charges to principal the day after the scheduled payment was due or include it with the meat scheduled payment after i have received notice ofthe ehugG and such notice
' is sem before the neer installment is due
FORBEARANC$DEFERMENT.OR CANCELI.A71ON-I may apply fora forbearance,deferment,or cancellation an my loan Dung an approved forbearanct period,payments of principal
and interest,or principal only,may be postponed or reduced Interest continues to action whole tory loan is in forbearance.During an approved dcfemmt period,I am not required to make
scheduled msuhllment payments an my loan, 1 am not liable for any interest ohm might otherwise acemte while my loan is to deferment. If i meet the eligibility requirements for a eoncellation of
my loan,the institution maycancel up to loo pement of the oatstandmgpdricipal loan amount information on cltgtbibty and application requirements f sr forbearances,deferments,and
cancellations is provided on pages 2 and 3 of this Nate I am responsible for subrmthng the appropriate requests on time,and 1 may lose my benefits if I fel to file my request on nine.
DEFAULT-The School may,at its option,declare my loan to be in default if(1)1 rod to make a scheduled payment when due,(2)1 fait to submit to the School,on or before the due dote are
scheduled payment,documentation that I qualify for a forbearance,deferment,or cancellation:or(3)1 tial to comply with the terms and conditions of this Note or written repayment agreement The
School may assign a defitulted loan to the Department for collection I will be ineligible for any further federal student financial assistance authorized under the Aa until I male arrangements that
are sansfuctory to the School or the Department to repay my loan The School or the Department shall disclose to credit bureau organizations that 1 have dela shed and all otter relevant loan
information I will lose my right to defer payments and my right to farbouninee off default on my loan The School of the Department may accelerate my defaulted loan Acceleration means that th
School or the Department demands Immediate payment of the entire unpaid balance of the logo,including principal.Interest,late charges,and collection costs I will lose my right to receive
canoella non benefits for sen ice that is performed after the date the School or the Depamnem accelerated the loan.
S CHANGE OF STATUS-I will inform the School ofany change in tory name,addresk telephone number,Social Security Number,or drivers license number
PROMISE TO PAY:1 prormse to pay the School,or a subsequent holder of the Note,all sans disbursed wider the terms of this Note.plus interest and ether fees which may become due as
provided in this Note I widentand that multiple baro may be made to me under this Note.I understand that by accepting any disbursements issued at any time under this Note,i agree to
repay the loans 1 understand that each loan is separately enforceable baud on a true and exact copy of this Nota 1 understand that 1 tray read or reduce the amount of any loan by not accepting
or by returning all or a portion of ally dosbimsemeo that is issued If I do not male any payment an any loan under this Note when m is dna,l promise on pay all reasonable collation costs,
t including attorney fees,court amts,and other fen i will not sign this Nam before reading the entire Nota even if I oro told that 1 am not required to read it 1 am entitled to on enact copy of dus
Noe This loan has been made to me without security or endorsement My signature certifies 1 have read,understand,and agree to the term and conditions of this Nae
I UNDERSTAND THAT I MAY RECEIVE ONE OR MORE LOANS UNDER THIS MASTER PROMISSORY NOTE AND THAT I MUST REPAY SUCH
LOANS.
20050824124849S18ZG39P5DAF3TIA4ZES 08/24/2005
Borrower's Signature Date
Page 1 of 4
C�HIBIT
4 FEDERAL PERKINS LOAN MASTER PROMISSORY NOTE
OMB No 1845-DD74 Faro A ved Ex irauon Date 06/3041009
1.Name(last,first,middle initial)and 2.Social Security Number
Permanent Address(street,city,state,zip code)
PAPALAZAROS,VANESSA R. 3.Date of Birth(mm/ddi Wy)
5501 WAYNE AVE APT 4028 4.Home Area Codt Telephone Number
PHILADELPHIA,PA 19144
S.Driver's License Number(List state abbreviation first)
Section B:School Secli()[I
6.School Name&Address(street,city,state,zip code) 7.Annual interest Rate
DREXEL UNIVERSITY 5%
3141 CHESTNUT STREET
PHILADELPHIA,PA 19104
Terms and Conditions:(Note:Additional Terms and Conditions follow on subsequent pages)
APPLICABLE LAW-The terms of this Federal Perkins Loan Master-Promissory Note(hereinafter called the Note)and any disbursements made under this Note shall be
interpreted in accordance with Part E of Title IV 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 are subject to the Act and Federal regulations issued under the Act. -
REPAYMENT-I am obligated to repay the principal and the interest that accrues on my loans)to the abir a-namod institution(hereinafter called the School)over a period
beginning 9 months(or sooner if 1 am a LewThan-Half-Time Borrower)after the date 1 cease to be at least a half-time student at an institution of higher education or a
comparable School outside the United States approved by the United States Department of Education(hereinafter called the Deportment)and ending 10 years later,unless I
request in writing that my repayment period begin sooner.I understand that the School will report the amount of my ttstaliment payments,along with the amount of this loan
to at least one national credit bureau,interest on this ban shall accrue from the beginning of the repayment period.My repayment period may be shorter than 10 years hf I am
( required by my School to make minimum monthly payments My repayment period may be extended during periods of deferment,hardship,or forbearance and i may make
graduated installments in accordance with a schedule approved by the Department I will make my installment payments in equal monthly,bimonthly,or quarterly
Installments as determined by the School The School may round my installment payment to the next highest multiple of$5 [i will make a minimum monthly repayment of
$40(or$30 if i have outstanding Federal Perkins Loans made before October 1,1992 that included the S30 rrummum payment option or outstanding National Direct Student
Loans)in accordance with the Minimum Monthly Payment Section ofthe Terms and Conditions contained on the reverse side of this document.)
LATE CHARGES-The School may impose late cliarges if 1 do not make a scheduled payment when due or if I fail to submit to the School on or before the due date of the
payment,a properly documented request for any arthe forbearance,deferment,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 n with the next
scheduled payment after I have received notice of the charge,and such notice Is sent before the neat installment is due,
FORBEARANCE,DEFERMENT,OR CANCELLATION-I may apply for a forbearance,deferment,or cancellation on my loan Dunng an approved forbearance
period,paymentsof principal and interest;orprincipal only,may be postponed or reduced Interest twntmues to accrue while my loan is in forbearance Dunng an approved
deferment period,i am not required to make scheduled installment payments on my loan 1 am not liable for any interest that might otherwise accnie while my loan is in
deferment if i meetthe eligibility requirements Cora cancellation of my loan,the institution may catncel up to loo percent of the outstanding principal loan amount
Information on eligibility and application requirements for forbearances,deferments,and cancellations is provided on pages 2 and 3 of this Note lam responsible for
submitting the appropriate requests on time,and I may lose my benefits if I fall to file my request on time
DEFAULT-The School may,at its option,declare my loan to be to default if(1)1 fail to make a scheduled payment when due; (2)1 fad to submit to the School,on or
before the due date of a scheduled payment,documentation that I qual nfy for a forbearance,deferment,or cancellation,or(3)1 fail to comply with the terms and conditions of
this Note or written repayment agreement' The School may assign a defaulted loan to the Department for collection, I wit]be ineligible for any further federal student
financial assistance authorized under the Act until I snake arrangements that are satsfactory,to the School or the Department to repay my loan The School or the Department
shall disclose to credit bureau organizations that I have defaulted and all other relevant loan information i will lose my right to defer payments and my right to forbearance if
I default on my loan The School or the Department tray accelerate my defaulted loan Acceleration meals that the School or the Department demands immediate payment
of the entire unpaid balance of the loan,including principal,interest,late charges,and collection costs I will lose my right to receive cancellation benefits for service that is
performed after the date the School or the Department accelerated the loan
CHANGE OF STATUS-i will inform the School of any change to my name,address,telephone number,Social Security Number,or driver's license member.
PROMISE TO PAY:I promise to pay the School,or a subsequent holder of the Note,all surfs disbursed under the teas of this Note,plus interest and other fees which
may become due as provided in this Note.I understand that multiple Ierans may be made to we under this Nota 1 understand that by accepting airy disburscrincirts issued
at any it=under this Note,i agree to repay the loans I understand that each loan is separately enforceable based on a true and exec[copy of this Note I understand that 1
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. If I do not make any payment on any lam
wider this Note when it is due,I promise to pay all reasonable collection costs,including attorney fees,court costs,ltd other fees I will not sign this Note before reading the
entire Note,even if 1 am told that I am not required to read it. i am entitled to an exact copy of this Note This loan has been made tome without security or endorsement
My signature certifies i have read,understand,and agree to the terms and conditions of this Note
I UNDERSTAND THAT i MAY RECEIVE ONE OR MORE LOANS UNDER THiS MASTER PROMISSORY NOTE AND THAT I MUST REPAY SUCH
LOANS
20060720221723000YRCSGBEG7YGVGVOIN 07/20/2006
Borrower's Signature Date
Page 1 cf4
i
FEDERAL PERE INS LOAN MASTER PROMISSORY NOTE
0-MB No.1$454)074 Form A cued Expiration Date 06/308009
1.Name(last,first,middle initial)and 2.Social Security Number
Permanent Address(street,city,state,zip code)
PAPALAZAROS,VANESSA R. 3.Date of Birth(mm/dd/yyyy)
49 BRACKEN PL
PITTSBURGH,PA 15235 4.Home Area Code/Telephone Number
5.Driver's License Number(List state ab revlatton ret
7DREXELUNIVERSITY
Address(street,city,state,zip code) 7.Annual Interest Rate
T STREET 5%
PA 19104
r
r Terms and Conditions:(Note:Additional Terms and Conditions fallow on subsequent pages)
APPLICABLE LAW-The terms of this Federal Perkins Loan Master PromissoryNote(hereinafter called the Note)and any disbursements made under this Note sball be
interpreted in accordance with Part E of Title Iv 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 are subject to the Act and Federal regulations Issued under the Act
REPAYMENT-I am obligated to repay the principal and the interest that accrues on my loan(s)to the above-named institution(hereinafter called the School)over a period
beginning 9 months(or sooner if I am a Less-Than-Half-Time Borrower)after the date I cease to be at least a half-time student at an institution of higher 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 lata,unless 1
request in writing that my repayment period begun sooner,l understand that the School will report the amount of city installment payments,along with the amount of this loan
to at least one national credit bureau Interest an this loan shall accrue from the beginning of the repayment period.My repayment period may be shorter than 10 years of I am
required 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 installments in accordance with a schedule approved by the Department i will make my installment payments in equal monthly,bimonthly,or quarterly
installments as determined by the School.The School may round my installment payment to the next highest muitiple of$5.[I will make a minimum monthly repayment of
S40(or$30 of I have outstanding Federal Perkins Loans made before October 1,1992 that included the S30 mmimum payment option or outstanding National Direct Student
t Loam)in accordance with the Minimum Monthly Payment Section of the Terms and Conditions contained on the reverse side of this document]
LATE CHARGES-The School may impose late charges if t do not make a scheduled payment when due or if I fail to submit to the School on or before the due date of the
payment,a properly documented request for any of the forbearance,deferment,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 atter I have received notice of the charge,and such notice is seat before the next installment is due.
FORBEARANCE,DEFERMENT,OR CANCELLATION-I may apply for a forbearance,deferment,or cancellation on my loan. During an approved forbearance
period,payments of principal and mteres4 or principal only,may be postponed or reduced Interest continues to accrue while my loan 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 might otherwise acerue while my loan is In
deferment If 1 meet the eligibility requirements for a cancellation of[ny loan,the Institution may cancel up to 100 percent of The outuauidmg pm►cipal loan amount
Information on eligibility and application requirements for fotbearances,deferments,and cancellations is provided on pages 2 and 3 of this Note. I am responsible for
{ submitting the appropriate requests an time,and I may lose my benefits if I fail to foie my request on time.
r
I DEFAULT-The School may,at its option,declare my loan to be in default if(1)I fart to make a scheduled payment when due; (2)I fad to submit to the School,on or
before the due date of a scheduled payment,documentation that I qualify for a forbearanoe,deferrn=4 or cancellation;or(3)1 fad to comply with the terms and conditions of
this Note or written repayment agreement The School may assign a defaulted loan to the Department for collection. I will be ineligible for any further federal student
finareial assistance authorized under the Act until 1 make arrangements that are satisfactory to the school or the Department to repay my loan.The School or the Department
shall disclose to credit bureau organizations that 1 have defaulted and all other relevant loan information. I will lose my right to defer payments and my right to forbearance if
I default on my loan.The School or the Department may accelerate my defaulted loan.Acceleration means that the school or the Department demands immediate payment
ofthe entire unpaid balance of the loan,including principal,interest,late charges,and collection costs. I will lose my right to receive cancellation benefits for service that is
performed after the date the School or the Department accelerated the loan.
t CHANGE OF STATUS-I 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 pay the School,or a subsequent holder of the Note,all sums disbursed under the terms of this Note,plus interest and now fees which
1 may became due as provided in this Note I understand that multiple loans may be made to ire under this Note. I understand that byaccepting any disbursements issued
at any time under this Note,I agree to repay the loans I understand that each loan is separately enforceable basad on a true and exact copy of this Note. i understand that I
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, if I do not matte any payment on any loan
under this Note when it is due,I promise to pay all reasonable collection costs,Including attorney fen,court costs,and other fees.I will not sign this Note before reading the
entire Note,even if I am told that 1 am riot required to read it I am entitled loan exactcopy of this Note.This loan has been made tome wilhout security or endorsement
My signature certifies I have read,understand,and agree to the terms and conditions of this Note.
I UNDERSTAND THAT I MAY RECEIVE ONE OR MORE LOANS UNDER THIS MASTER PROMISSORY NOTE AND THAT I MUST REPAY SUCH
LOANS.
20070710075754F7VA8744L11A65KBULGM 0711012007
Borrower's Signature Date
Page I of
tr
Disclosure Statement
DREXEL UNIVERSITY
MAIN BLDG COMPTROLLERS OFFICE
3141 CHESTNUT STREET
PHILADELPHIA,PA 19104
March 10,2009
VANESSA R PAPALAZAROS
i3 160 SFat?, An& 130
TrafF..,-dl joa 150VS-
WE URGE YOU TO CAREFULLY READ THIS DISCLOSURE STATEMENT!
Based on the terms of the promissory note you signed,disclosure is hereby made,repayment schedule established and
notification given in regard to your student account.We suggest that you file this and other documents pertaining to your account
in a safe place for future reference.
institution Number
fund Award :R,-
separa0on Grow Feat Total Perlodb R@p merit Repayment Total Total
Desmptlon Ntarrber Nurrrber AnOum(S) Date Payment Sof Frequerloy Pin Peymem Fluence
Date Pmts Amount S)( Amount(S) Charge(S)
Federal Perkkro Loan 5,800 00 Bfl'011DB 8 OIAIl10 120 6303 Pdndlrel
Monmy Indudmg 8.384.06 1.36406
Internet
FeOeralPedlk+sl0an BA0000 b000 OBf01N9 9 Pdndpal
t -- 04M1110 120 6364 MonNly Induding 7.83671 1.836.71
' Interest
You may,at your option and without penalty,repay all or part of your account at any time.The finance charge may be eliminated
if you pay the entire principal balance prior to your account entering repayment.Your interest accrual and first payment due date
{ may be affected if you are now or should become eligible for deferment or partial cancellation benefits.
r
Please refer to your promissory note for specific entitlement benefits.
Please be aware that your promissory note may contain provisions for credit bureau reporting,late charge assessment,collection
and or litigation costs.Refer to your promissory note for the terms and condition of your loan(s).
I
Please remember,if you are unable to make a payment for any reason,you are required to inform your lending institution before
the payment due date.
Please sign this document and return it to your lending institution.
i
}
r ,
Date:
31-x-9
Borrower Sig ire
Validation Notice
Unless you notify us In writing within thirty days of the receipt of this notice that you dispute this debt or any portion
thereof,we will assume that the debt is valid.
Page 1 of 1
File Numbers 20130287,2013288
-YE IFICA PION
I verify that the statements made in the attached document 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.
ILLIAM WATHINGTO
Drexel University
DATE:
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
'-1LED-OFFiCE
THE PH -THONG 1,,W;Y
7 -yq 2016, SEP -4 PM 2: 32
CUMBERLAND COUNTY
PENNSYLVANIA
OFT 1 Tn Si-CCRIFF
Drexel University
vs.
Vanessa R Papalazaros
Case Number
2014-4962
SHERIFF'S RETURN OF SERVICE
08/28/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Vanessa R Papalazaros, but was unable to locate the Defendant in
his bailiwick. The Sheriff therefore retums the within requested Complaint & Notice as "Not Found" at 8
Ladnor Lane, South Middleton, Carlisle, PA 17015. Deputes were advised by the defendant's mother that
she now resides at 3 Allegheny Center, Pittsburgh, PA 15212.
SHERIFF COST: $34.78 SO ANSWERS,
August 29, 2014 RON R ANDERSON, SHERIFF
CountySuito Sheriff, Teleosoft. Inc.
J. SCOTT WATSON, P.C.
BY: J. SCOTT WATSON, ESQUIRE
Identification Number 41060
24 Regency Plaza
Glen Mills, Pennsylvania 19342
(610) 358-9600
Zjib tS.
tic3 3
11 C
L.ic.3 LV
Attorney for Plaintiff
it)
DREXEL UNIVERSITY
V.
VANESSA R. PAPALAZAROS
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 2014-4962
ORDER TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above -captioned matter as discontinued and ended upon payment of your
costs only.
J. SCOTT WATSON, ESQUIRE
Attorney for Plaintiff