HomeMy WebLinkAbout14-6310 Supreme Court of Pennsylvania
CourPof=Commolr�, leas For Prothonotary Use Only:
Civil'Cbve Sh' et
(+ Docket No:
Cucberland" County I%
° .
The iq rmation collected on this form is used.soleh;,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 0 Writ of Summons 0 Petition
E Transfer from Another Jurisdiction Declaration of Taking
C Lead Plaintiff's Name: Lead Defendant's Name:
T Dickinson College Javan J. Howard
I Are money damages requested? 0 Yes No Dollar Amount Requested: Elwithin arbitration limits
(check one) Ooutside arbitration limits
N Is this a Class Action Suit? 0 Yes El No Is this an MDJAppeal? 0 Yes El 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 Sett-Represented IPro 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
IO Intentional 10, Buyer Plaintiff Administrative Agencies
El Malicious Prosecution 0 Debt Collection: Credit Card 0 Board of Assessment
E] Motor Vehicle Q Debt Collection: Other 0 Board of Elections
E] Nuisance Unpaid Student Loans 0 Dept.of Transportation
E] Premises Liability J Statutory Appeal: Other
S Product Liability(does not include
E mass tort) � Employment Dispute:
Slander/Libel/Defamation Discrimination
C n Other: 0 Employment Dispute:Other Zoning Board
T 0 Other:
I Other:
Q MASS TORT
0 Asbestos
N 0 Tobacco
Toxic Tort-DES
Q Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
Q Toxic Waste
Other: 0 Ejectment 0 Common LawlStatutary Arbitration
0 Eminent Domain/Condemnation 0 Declaratory Judgment
El Ground Rent - Mandamus
0 Landlord/Tenant Dispute Non-Domestic Relations
0 Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY 0 Mortgage Foreclosure:Commercial 0 Quo Warranto
0 Dental 0 Partition 0 Replevin
0 Legal 0 Quiet Title 0 Other:
0 Medical 0 Other:
0 Other Professional:
Updated 1/1/2011
p :Enn
+} "LD-0,
Christopher E. Rice, Esquire ,
Attorney I.D. 90916 Z Qtr 3�1 �Q ,
MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER"'!'OC [
MARTSON LAW OFFICES 'ENNS AND Cotj,� T�,
Ten East High Street ANIA
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 - 3
CIVIL ACTION - LAW
JAVAN J. HOWARD,
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
C�- Ag-q7 5-
710- 7,91
-
7/0- 79/
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FAFILES\Clients\7619 Dickinson College\7619.Collections\7619C.Current\7619C.431 Howard\7619C.43Lcomplaint.com
Christopher E. Rice, Esquire
Attorney I.D. 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 N0. 2014 - 3 I LI
CIVIL ACTION - LAW
JAVAN J. HOWARD, ;
Defendant ;
COMPLAINT
AND NOW,comes Plaintiff,Dickinson College,by and through its attorneys,MARTSON LAW
OFFICES, and hereby avers as follows:
1. Plaintiff,Dickinson College(hereinafter"Dickinson"),is a Pennsylvania educational
institution with its principal offices located in Carlisle, Cumberland County, Pennsylvania 17013.
2. Defendant,Javan J.Howard(hereinafter"Student"),is an adult individual whose last
known address is 2455 Williamsbridge Road, Apt. 3A, Bronx, New York 10469.
COUNT
BREACH OF CONTRACT
3. Student was recently enrolled at Dickinson.
4. On or about February 6,2006,Student entered into a Promissory Note-Federal Perkins
Loan Program("Note")with Dickinson for the financing of$6,404.00, plus interest and costs,by Student
for educational services and benefits at Dickinson. A copy of the Note is attached hereto as Exhibit"A."
5. As provided in the Act,Plaintiffacts in a fiduciary capacity in the handling,disbursing and
collecting of funds associated with the programs under the Act.
6. The Note grants Plaintiff reasonable collection and attorneys'fees which Plaintiff has
calculated to be $1,000.00.
n '
7. As of June 27,2014,the principal and interest due and payable by Defendant to Plaintiff
was $6,825.48, with interest accruing at 5%per annum.
8. Plaintiffhas fulfilled,performed and complied with all obligations and conditions ofthe
Note.
WHEREFORE,Plaintiff demands judgment against Defendant in the amount of$6,825.48,plus
interest accruing at 5%per annum on the Loans thereafter,attorney's fees in the amount of$1,000.00,and
other reasonable collection costs and charges.
COUNT II
BREACH OF CONTRACT
9. The averments of Paragraphs 1-8 are incorporated herein by reference.
10. Student opened a Student Receivables Account(hereinafter"Account")with Dickinson
to pay tuition,books,dining service fees and other educational expenses. A true and correct copy of the
Account is incorporated by reference and attached as Exhibit `B."
11. 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.
12. The terms of repayment of the Account require Student to pay the balance fourteen(14)
days before the beginning of each semester.
13. Student breached the expressed and implied obligations,conditions and terms of Account
by failing to pay the amounts stated therein.
14. The Account balance due and payable by Student to Dickinson for those educational
services was $1,718.74.
WHEREFORE,PlaintiffDickinson College demands judgment against Defendant Javan J.Howard
in the sum of$1,718.74, plus late fees, costs of suit and interest from date of judgment.
COUNT III
IN QUANTUM MER UIT
In the alternative,ifthis Honorable Court determines that an express contract between Dickinson
and Defendant does not exist in either Count I or Count II,which is denied,Dickinson pleads the following:
15. Paragraphs 1 through 15 are incorporated herein by reference as if set forth in full.
became liable to Dickinson for said money.
17. Student was unjustly enriched by accepting said money without paying Dickinson
reasonable compensation therefor.
18. The total amount by which Student became enriched was $8,544.22, plus interest
accruing thereafter.
19. Dickinson demanded payment of the above amount, but Student failed and refused
to do so pay.
WHEREFORE, Dickinson demands judgment against Student in the amount of$8,544.22,
plus interest and costs of suit.
MARTSON LAW OFFICES
'2---
Christopher E. Rice, Esquire
I. D. Number 90916
Ten East High Street
Carlisle, PA 17013
/ (717) 243-3341
`
Date: 0 &i' 1� 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.
EXHIBTT "A"
r .
FEDERAL PERKINS LOAN MASTER PROMISSORY NOTE
OMBNo.1943-0074 Form Approved Expiration Date 06/30/2006
1.Name(last,first,middle initial)and GI�J(�r 2.Social Security Number
Permanent Address(street,city,state,zip co(e)
0 0"'v k'LD j cTc W..N S 3.Date of Birth(mm/dd/yyyy)
2-1-1 5`S tN t�(i wvts brt��e. �e�r{� 44)�3 4.Home Area Code/Telephone Number
��on k N¢<v yorl� 10 4 6 5 5.Driver's License Number(List state abbreviation first)
6.Dickinson College 7.Annual Interest Rate
P.O.Box 1773 5%
Carlisle,PA 17413-2896
[Any bracketed clause or paragraph may be included at option of instittilionj
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 airy disbursements made under this Note shalt be
interpreted in accordance with part E of Tit le IV of the Higher Education Ad 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 obi igated 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-Had€Titne 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 Staten approved by the United States Department of Education(hereinafter called the Department)and ending to years later,unless I
request 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 stational credit bureau.Interest on this loan shall acme from the beginning of the repayment period MY MPayment period may be shorter than 10 years if I am
required by my School to make minimum monthly payments.My repayment period may be extended during periods of defenneK 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,
installments as determined by the School.The School may round my installment °f hlY
payment in clue next highest multiple of$5.[I will make a minimum monthly repaymexrt of
$40(or n a if I have outstanding Federal parkins Loans made before October I,1992 that included the$30 minimum payment option or outstanding National Direct Student
Loans)rn accordance with the Mmimun Monthly payment Section of the Terms and Conditions contained on the reverse side of this document.)
LATE CHARGES-11w 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 before the due date of the
Payment,a properly documented request for any of the forbeaance,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 4 with the next
scheduled payment after 1 have received notice of the charge,and such notice is sent before the next installment is due.
FORBEARANCE,DEFERMENT,OR CANCELLATION-I may apply for a forbearance,deferment,or cancellation on my baa During an approved forbearance
period,P of principal and interest,or principal only may be postponed or reduced.Interest continues to accrue while m loan is in frbearance. 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 accrue while my loan is in
deferment. If]meet the eligibility requirements for a rancelbtion of my loan,the institution maycancel to 100
Information on eligibility and application requirements for forbearances,deferments,and cancellations is provided on peg of the outstanding principal loan amount
submitting the appropriate requests on time,and I may lose my benefits if]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 make 4 scheduled
before the due date of a scheduled payment,documentation that I qualify for a forbearance,deferment, payment when due;(2)I fail to submit to the School,di ior
o
this Note or written repayment agreement The School or coil t start;or(3)I fail to comply with the terms and conditions of
may assign a defaulted loan to the Department for collection I coil!be ineligible for any further federal student
financial assistance authorized under the Act until I make arrangements that are satisfactory to the Scheel 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 an.The School or the Department may accelerate my defaulted low
llation benefits for service that is Acceleration means that the School or the Department demands immediate Payment
of the entire unpaid balance of the loan,including principal,interes4 late charges,end collection costs. I will lose my right to receive cance
performed after the date the School or the Department accelerated the loan.
CHANGE OF STATUS-I will inform the School of arty change in my name,address,telephone number,Social Socur ity Number,or driver's license number.
PROMISE TO PAY,I promise to pay the School,or a subsequent holder of the Note,all stems 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 he made to we under this Note.I understand that by accepting any disbursements issued
at any time under this Note,I agree to repay the loans.I understand that each loan is separately enforceable based on a true and exact copy of this Note.I understand that I
may cancel or reduce the amount of arty loan by not accepting or by returning all or a portion of arty disbursement that is issued. If I do not make
under this Note when it is due,I promise to pay all reasonable collection costs,includingattorney _ any payment on any loan
entire Note,even if I am told that I am not requited to read it.I am entitled to an exact cpy of this Note. This loan has beertarmade me without security or efore reading
the
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
LOANS. ISS
THIS MASTER PROMISSORY NOTE AND THAT I MUST REPAY SUCH
--�..._.. &—
B en's Signature Data b-o 6
Page I of4
Terms and Conditions(cont) which the loan was made and the initial grace period has ended,only those
amounts in excess of the amount due for any repayment period shall be
DISCLOSURE OF LOAN TERMS-I understand that under this Note,the considered a prepayment Il;in an academic year other than the academic
principal amount that I ow and am y�m which the loan was made,I repay more than the amount due for an
g requited to repay,will be the sum of all installment,the excess funds will be used to repay principal unless I
disbursements issued unless I reduce or cancel any disbumina .The designate it as an adrarmce payment of the next regular installment
School will determine whether to make any loan under this Note after my
loan eligibility is determined At or before the time of first disbursement for MINIMUM MONTHLY PAYMENT-If
each loam,a disclosure statement will be provided to me identifying the try the School,I will
amount of the loan and �`� make a minimum monthly payment in the amount of$40(or$30 if I have
any additional terms of the loan.I may decline a loan outstanding Federal Perkins Loans made before October 1,1992 that
or request a lower amount by contacting the School.
Any disclosure included the$30 minimum payment option or outstanding National Direct
statement I receive in connection with any loan under this Note is hereby Student Loans)or its bimonthly or quarterly equivalent If the total monthly
incorporated into this Note.
Payment amount on this loan and any outstanding Federal Perkins Loans I
may have is less then the minimum monthly payment amount established by
LOAN REHABILITATION-If I default on my Federal Perkins Loan, the School,the School may still require a minimum monthly payment
and that loan has not been reduced to ajudgment as a result of litigation amount A minimum monthly payment amount will combine my obligation
against me,I may rehabilitate my defaulted loan by requesting the on this and all my outstanding Federal Perkins Loans,unless I have received
rehabilitation and by making a voluntary,on-time,monthly payment,as loans with different grace periods and deferments. At my request and if I
determined by the School,each month for twelve consomdive months. IfI atm eligible,the school may combine this minimum monthly payment
successfiilly rehabilitate my defaulted Federal Perkins Losn,I will again be amount with all my outstanding Federal Perkins Loans including those
subject to the terns and conditions and qualify for any remaining benefd s made at other schools. Under these circumstances the portions ofthe
and privileges of this Note and the default will be removed from my credit fr ururmum monthly Payment that will.be applied to this loan will be the
history. I understand that I may rehabilitate a defaulted Federal difference between the minimum monthly payment amount and the total
Perkins Loan only once. After my loan is rehabilitated,collection costs on amounts owed on a monthly basis on my other Federal Perkins Loans.If
the ban may not exceed 24 penentof the unpaid principal and accrued. each school holding my outstanding Federal Perkins Loans exercises the
interest as ofthe date following the application ofthe twelfth consecutive minimum monthly payment amount option,the minimum monthly payment
payment IfI default on my rebabil itated loan,the cap on collection costs is amount will be divided among the Schools in proportion to the loan amount
removed advanced by each school if l request this treatment from each School.
ASSIGNMENT-A loan made under this Note may be assigned by the FORBEARANCE-Upon making a property documented written request
School only to the United States,as represented by the United States to the School,I am entitled to forbearance of principal and interest or
Depattment of Education.Upon assignment,the provisions of thisNote that principal only,renewable at intervals of up to 12 months for periods that
relate to the School will,where appropriate,relate to the Department collectively do not exceed throe years,under the followln g conditions:If my
monthly Title IV loan debt burden equals or exceeds 20 percent of my total
HARDSHIP REPAYMENT OPTIONS-Upon my written request,the monthly gross income;ifthe Department authorizes a period of forbearance
School may extend my repayment period(1)for up to an additional 10 due to a national military mobilization or other national emergency,or if the
years if t quW4 as a low-income individual during the repayment period; School determines that I qualify due to poor health or for other reasons,
or(2)for the period necessary beyond my I0 year repayment period if,in including service in AmeriCorps.Interest accrues during any Period of
the School's opinionun
,prolonged illness or employment prevent me from forbearance.
making the scheduled repayments. Interest will continue to accrue during
any extension of s repayment period. DEFERMENTS-To apply for a deferment,I must request the deferment
from the school. My request does not have to be in writing,but the School
IfI am required by the School to make a minimum monthly payment on my may require the I submit supporting documentation to prove my eligibility
loan,the School may also permit me to pay less thea the minimum monthly for a deferment. I may defer making scheduled installment payments and
Payment amount for a period ofnot more than ort*year at a time if I will not be liable for any interest that might otherwise e,,rue(1)during any
experience a period of prolonged illness or unemployment.However,such Prod that I am ermined and attending as a regular student in at least a half-
action may not extend the repayment period beyond 10 years, time course of stWy at an eligible School(If the School obtains student
enrollment information showing that I quality for this deferment,the School
GRACE PERIODS-Unless I sun a LcsrThan-Half-Tlme Borroww,I will may SW the deferment without my request providing the School notifies
receive an initial ninnomonth grace period Wfbre the first payment of my me and gives me the option to cancel the deferments(2)during any period
Federal Perkins Loan must be made.After the close of an authorized that I am enrolled and attending as a regular student in a graduate fellowship
deferment period,I will.receive a post-defermerd grace period of 6 months Program approved by the Department;engaged in graduate or post-graduate
before my payments resume lmerest does not accrue during the initial fellowship-supported study outside the US;enrolled and attending a
grace period or during the post-deferment grace period. The nino month rehabilitation training program for disabled individuals approved by the
initial grace period for Federal Perkins Loans does not include any period Department:or engaged in public service that qualifies me to have part or
up to three years during which I am called or ordered to active duty for all of my ban canceled;(3)for a period not to exceed tree years during
more than 30 days from a reserve component ofthe Armed Forces ofthe which I am 5eeking but unable to find full-time employment;and(4)for a
United States,including the period necessary for me to resume enrollment period not to exceed three years,for up to one year at a time,during which I
at the next available enrollment period I most notify the school that made am experiencing an economic hardship as determined by the School.I may
my loan of the beginning and ending dates of my service,and the date I qualify for an economic hardship deferment for my Federal Perkins Loan if
resume enrollment IfI am in my initial grace period when called or I provide my school with documentation showing that I have been granted
ordered to active duty,I am entitled to a new nin&month initial grace period such a deferment under the William D.Ford Federal Direct Loan or Federal
upon completion ofthe excluded period. Family Education Loan program for the period oftime fbr which I am
requesting an economic hardship deferment for my Federal Perkins Loan.if
IfI am a Less-TharrHahf--Time Borrower with outstanding Federal Perkins I am serving as a volunteer in the Peace Corps,I am eligible for an
Loafs,my repayment period begins when the next scheduled installment of economic hardship deferment for my fLll term of service. An economic
my outstanding loan is due. If I am a Lm-Than-Half-Time Borrower with hardship deferment based on service as a peace Corps volunteer may not
no other outstanding Federal Perkins Loans,my repayment begins the exceed the teaser of throe years or my remaining period of economic
earlier of. 9 months from the date my loan was made,or 9 months from the hardship eligibility.
date I became a less than-half-time student,even if I received the loan after
I became a lesmhan-halftime student I may continue to defer making scheduled installment payments and will
not be liable for any interest that might otherwise accrue for a six-month
PREPAYM NT-I may prepay all or any part of my unpaid loan balance, Period immediately following the expiration of any deferment period
plus any accrued interest,at any time without penalty.Amounts I repay in described in this section
the academic year in which the loan was made and before the initial grace
period has ended will be used to reduce the amount ofthe loan and will not I am not eligible for a deferment while serving in a medical internship or
be considered a prepayment IfI repay amounts during the academic year in residency program.
Page 2 of 4
Terms and Conditions(cont"} original principal loan amount ofthis loan canceled for qual"service
Performed after the enrollment period covered by the loan as:•a volunteer
CANCELLATIONS-Upon making a properly documented written tinter the Peace Coro Act;•a volunteer under the Domestic Volunteer
request to the School,I am entitled to have up to I00 percent of the original Service Act of 1973(ACTION prognam l
principal loan amount of this loan canceled if I perform qualifying service in
the am listed in paragraphs A,13,C,D,and E below.Qualifying service Cancellation Rate-For each completed year of service under the
m ust be performed after the enrollment period covered by the loan. Volunteer Service Cancellation provision,a portion of this loan will be
canceled at the following rates:
A,Teaching•a ftdkime teacher in a public or other nonprofit elementary •15 percent of the original principal loan amount for each of the first and
or secondary school,designated by the Department in accordance with the secomd 12-month periods of service;and•20 percent of the original
provisions of section 465(ax2)of the Act as a school with a high principal loan amount for each of the third and fourth 12-month periods of
concentration of students from low-income families.An official Directory service.
of designated lohwincome schools is published annually by the Department.
•a fi ill4ime special education teacher in a public or nonprofit elementary or DISCHARGES-My obligation to repay this loan may be partially or
secondary school system;or•a full-time teacher,in a public or other totally discharged for the reasons specified in paragraphs A,8,C.and D
nonprofit elementary or secondary school system,who teaches below.
mathematics,science,foreign languages,bilingual education,or any other
field of C)Wxtise that is determined by the State Department of Education to A.Death-In the event of my death,the School will discharge the total
have a shortage of qualified teachers in that State, amount owed on this loan.
B.Early Intervention Services•a flrlkime qualified professional provider S Total and Permanent Disability-If I become totally and permanently
of Carly intervention services in a public or other nonprofit program under disabled after I receive this to an,the School will discharge the total amount
public supervision by a lead agency as authorized by section 632(5)of the owed on this loan If my disability discharge Claim is approved by the
Individuals with Disabilities Education Ad.Early intervention services are School,this loan will be assigned to the United States Department of
provided to inlhnts and toddlers with disabilities Education,which will discharge the total amount owed an this loan if it
determines that I am eligible for a total and permanent disability discharge.
C.Law Enforcement or Corrections Officer•a fulkimelew
enforcement officer for an eligible local,State,or Federal law enforcement C.School Closure-Under certain condition my total liabilitywill be
agency;or•a full-time Corrections officer for an eligible local,State,or discharged,including refunding any amounts I have already paid on the
Federal corrections agency. loan,
iflwas unable to my School closed,complete the program in which I was enrolled
D.Nurse or Medical Technician•a fidkime nurse providing health care A Bankruptcy
servicer;or•a fWkime medical technician providing health caro services -Under certain conditions, an toes may bas discharged un in
bankruptcy. In order to discharge a loan in bankruptcy,I must prove undue
E.Child or Family Service Agency•a fhlWme employee of an eligible hardship in an adversary proceeding before the bankruptcy court
public or private non-profit child or fam ily service agency who is directly
providing or supervising the provision ofservices to high-risk children who Disclosure of Information
are.from low-Income communities and the families of such children
Cancellation Rates-For each completed year of service under paragraphs STUDENT LOAN OMBUDSMAN-IPI dispute the terms of my
A,B.C,D,and E a portion of this loan will be canceled at the following Federal Perkins Loan in writing to my School,and my School and I are
rates: unable to resolve the dispute,I may seek the assistance of the Department
•15 percent of the original principal loan amount for each of the first and of Education's Student Loan Ombudsman. The Student Loan
second years;•20 percent of tiro original principal loan amount for each of Ombudsman will review and attempt to informally resolve the disputa
the third year and fourth years;and•30 perce t ofthe original principal
loan amount for the fifth year.
Notice About Subsequent Loans Made Under This
F.Head Start Cancellation-Upon making a properly documented written Master Promissory Note
request to the school,I am entitled to have up to 100 percent of the original
principal loan amount canceled for qualifying service performed after the This Note authorizes the School to disburse multiple loans during.
enrollment period covered by the loan am•a flrlkime staff member in the the multioyear term of this Note upon my request and upon the
educational component of a Head Start program which is operated for a School's determination of my loan eligibility.
period comparable to a M School year and which paysa salary comparable Subsequent loans may be made under this Note for the same or
to an employee of a local educational agency. subsequent periods of enrollment at this School.The School,
however,May,at its discretion,close this Note at any time and .
Cancellation Rate-For each completed year of service under the Head require me to siga a new Note for additional disbursements.I
Start Cancellation provision,this loan will be canceled at the rate of 15 understand that if my School chooses to make subsequent loans
percent of the original principal loan amount, under this Note,no such loans will be made after the earliest of the
following dates: (i)the date the School reCeives my written notice
G.Military Cancellation-Upon making a properly documented written that no further loans may be.disbursed under this Note;(ii).twelve
request to the School,I am entitled to have up to 50 percent ofthe principal months after the date ofmy signature on this Note if no
amount of this loan canceled forqualifying service performed afterthe disbursement is made during such twelve-month period;or(iii)ter
enrollment period covered by the loan as:•a member of the Armed Forces years after the date of my signature on this Note,or the date the
of the United States in an area of hostilities that qualifies for special pay School receives.this Notm
under section 310 ofTitle 37 of the United States Code Any amendment to the Act governs the terms of arty loans
disbursed on or after the effective date of such amendment,and such
Cancellation Rate-For each completed year of service underthe Military amended terms are hereby ineo orated into this Note.
Cancellation provision,this loan will be canceled at the rate of 12%percent
of the original principal loan amount.
EL Volunteer Service Cancellation-Upon malting a properly documented
written request to the School,I am entitled to have up to 70 percent of the
Page 3 of4
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Important Notices
Privacy Act Notice
The Privacy Act of 1974(5 U.S.C.552a)requires that the following notice be provided to you:
The authority fbr collecting the requested information from and about you is§461 et am.of the Higher Education Ad of 1965,as amended(20 U.S.C.1087 as
,&g)and the authority for collecting and using your Social Security Number(SSN)is§484(a)(4)of the HEA(20 U.S.C.1091(a)(4)). Participating in the Federal
Perkins Loan(Perkins)Prognun and giving us your SSN are voluntary,but you must provide the requested information,including your SSN,to participate.
The principal purposes for collecting the information on this form,including your SSN,are to verify your identity,to determine your eligibility to receive a loan Ora
benefit on a loan(such as a deferment,forbearance,discharge,or cancellation)under the Perkins Program,to permit the servicing ofyotu 10 (s) and,if it becomes
necessary,to locate you and to collect on your loan(s)if your loan(s)become delinquent or in default We also use your SSN as an account identifier and to permit
YOU to access your account information electronically.
The information in your file may be disclosed to third parties as authorized under routine uses in the appropriate systems of records. The routine uses of this
information include its disclosure to federal,state,or local agencies,to other federal agencies under computer matching programs,to agencies that we authorize to
assist us in administering our loan programs,to private parties such as relatives,present and former employers,business and personal associates,to credit bureau
organizations,to educational institutions,and to contractors in order to verify your identity,to determine your eligibility to receive a loan or a benefit on a loan,to
permit the servicing or collection ofyour loans)to counselyou in repayment efforts,to enforce the terms of the loan(s),to investigate possible fraud and to ver'
compliance with federal student fmamial aid program regulations,to locate you ifyou become delinquent in your loan payments or ifyou default,to provide default
rate calculations,to provide fify
nancial aid history information,to assist program administrators with tracking refunds and cancellations,or to provide a standardized
method for educational institutions efficiently to submit student enrollment status.
In the event of litigation,we may send records to the Department of Justice,a court,adjudicative body,counsel,party,or witness if the disclosure is relevant and
necessary to the litigation. If this information,either alone or with other information,indicates a potential violation of law,we may send it to the appropriate
authority for action We may send information to members of Congress if you ask them to help you with federal student aid questions, In circumstances involving
employment complaints,grievances,or disciplinary actions,we may disclose relevant records to adjudicate or investigate the issues. If provided for by a collective
bargaining agreemem,we may disclose records to a labor organization recognized under 5 U.S.C.Chapter 71, Disclosures may also be made to qualified researchers
under Privacy Act safeguards.
Financial Privacy Act Notice
Under the Right to Financial Privacy Act of 1978(12 U.S.C.3401-3421),the U.S.Department of Education will have access to financial records in your student loan
file maintained by the lender in compliance with the administration of the Federal Perkins Loan Program.
Paperwork Reduction Notice
According to the Paperwork Reduction Act of 1995,no persons are required to respond to a collection of information unless it displays a currently
valid OMB control
number.The valid OMB control number for this information collodion is 1845.0074.The time required to complete this information is estimated to avcmge 0.5
hours(30 minutes)per response,including the time to review instructions,search existing data resources,gather end maintain the date needed,and complete and
write toc
review the information collection If You have amry comments concerning the accuracy of the time estimate(s)or suggestions for improving this form,please
U.S.Department of Education
Washington,DC 20202-4651
If you have any comments or concerns regarding the status ofyour individual submission of this form,write directly to the lender.
Page 4 of 4
EXHIBIT `B"
07-JAN-2011 01:03:55 PM
ALL TERMS Dickinson College J
Transaction Summary Report PAGE 1
y
Howard, Javan J TSRTSUM
DETL Description TERM CHARGE PAYMENT BALANCE S EFF DATE RECEIPT ID TRAN TPAY
H402 Housing Double - Fall 200570 2,075.00 2,075.00 T 05-JUL-2005 CONVERT 1
M105 Student Activities Fee 200570 160.08 2,235.08 T 05-JUL-2085 CONVERT 2
M106 Transcript Fee 200570 25.08 2,268.00 T 05-JUL-2005
T298 Tuition Fall 208570 15,908.08 CONVERT 3
M137 Health Insurance Student Fall 208570 240.08 18,160.06 T 05-JUL-2005 CONVERT 4
8304 Meal Plan - Fall 18,408.08 T 05-JUL-2005 CONVERT 5
D8118304 Dickinson Posse Grant 200578 1,950.08 20,350.08 T 05-JUL-2065 CONVERT 6
200570 16,060.00 4,298.00 T 06-JUL-2005 CONVERT 7
M137 Health Insurance Student Fall 200578 -240.00
F980 Supplemental Ed Opportunity Gr 200570 4,058.00 T 13-JUL-2005 CONVERT 8
162.00 3,888.00 T 23-AUG-2005 CONVERT 9
F970 Federal Pell Grant
208570 2,025.08 1,863.08 T 23-AUG-2005 CONVERT 10
C301 Cash Received on Account 200560 550.00 1,313.08 T 25-AUG-2005 CONVERT 11
M857 BKSTR - Miscellaneous 200570 7.25
M 1,328.25 T 03-OCT-2005 CONVERT 12
650 BKSTR - Pa Sales Tax
MBS2 BKSTR - Trade Books 200570 2.22 1,322.47 T 03-OCT-2005 CONVERT 13
MBS2 BKSTR - Text Books 200570 3.00 1,325.47 T 83-OCT-2085 CONVERT 14
20570 .60
MBSC BKSTR - Computer/Supplies 200570 342 33.93 1,668.07 T 03-OCT-2005 CONVERT 15
MBS6 BKSTR - Grocery 208570 2.79 1,702.08 T 03-OCT-2085 CONVERT 16
F980 Supplemental Ed Opportunity Gr 200570 1,704.79 T 83-OCT-2065 CONVERT 17
F970 Federal Pell Grant -162.00 1,866.79 T 18-OCT-2005 CONVERT 18
`980 Supplemental Ed Opportunity Gr 200570 -2,025.00 3,891.79 T 18-OCT-2005 CONVERT 19
-970 Federal Pell Grant 163.00 3,728.79 T 22-NOV-2005 CONVERT 20
200578 2,025.00 1,703.79 T 22-NOV-2005 CONVERT 21
.1305 Meal Plan - Spring 200620 1,958.00 3,653.79 T 29-NOV-2005 CONVERT 22
1105 Student Activities Fee 200620 160.88 3,813.79 T 29-NOV-2005 CONVERT 23
1299 Tuition Spring 200620 15,908.00 19,713.79 T 29-NOV-2005 CONVERT 24
1811 Dickinson Posse Grant 200620 16,060.00 3,653.79 T 30-NOV-2005 CONVERT 25
;402 Housing Double - Fall 200620 2,075.00 5,728.79 T 30-NOV-2085 CONVERT 26
1146 Health Center Charge 200570 15.00 5,743.79 T 03-JAN-2006 CONVERT 27
980 Supplemental Ed Opportunity Gr 200620 162.00 5,581.79 T 17-JAN-2006 CONVERT 28
970 Federal Pell Grant 200620 2,025.00 3,556.79 T 17-JAN-2006 CONVERT 29
600 Subsidized Federal Stafford Lo 200570 1,313.06 2,243.79 T 27-JAN-2006 CONVERT 30
.600 Subsidized Federal Stafford Lo 200620 1,312.00 931.79 T 30-JAN-2006 CONVERT 31
iBS3 BKSTR - Supplies 200620 6.38 938.17 T 01-FEB-2006 CONVERT 32
BSI BKSTR - Text Books 200620 196.80 1,134.97 T 01-FEB-2086 CONVERT 33
102 Finance Charge 200620 13.75 1,148.72 T 01-FEB-2006 CONVERT 34
BSO BKSTR - Pa Sales Tax 200620 .38 1,149.10 T 01-FEB-2006 CONVERT 35
710 Federal Perkins Loan 200620 750.00 399.10 T 21-FEB-2006 CONVERT 36
BS7 BKSTR - Miscellaneous 200620 98.98 498.08 T 01-MAR-2006 CONVERT 37
851 BKSTR - Text Books 200620 30.25 528.33 T 01-MAR-2006 CONVERT 38
35C BKSTR - Computer/Supplies 200620 44.93
102 Finance Charge 573.26 T 81-MAR-1006 CONVERT 39
9 200620 2.73 575.99 T 01-MAR-2006 CONVERT 40
�S4 BKSTR - Clothing 200628 27.99 603.98 T 01-MAR-2006 CONVERT 41
ASO BKSTR - Pa Sales Tax 200620 2.97 666.95 T 01-MAR-2006 CONVERT 42
t04 Lock Out Fee Safety & Security 206620 10.08
616.95 T 82-MAR-2006 CONVERT 43
110 Federal Perkins Loan 208578
750.08 -133.05 T 15-MAR-2006 CONVERT 44
IS7 BKSTR - Miscellaneous 200620 77.00 -56.05 T 03-APR-2006 CONVERT 45
;S6 BKSTR Grocery 200620 4.54 -51.51 T 03-APR-2006 CONVERT 46
02 Finance Charge 200620 2.73 -48.78 T 04-APR-2006 CONVERT 47
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7-JAN-2011 01:03:55 PM
LL' TERMS Dickinson College
• Transaction Summary Report PAGE 3
oward, Javan J TSRTSUM
*****CONTINUED FROM PREVIOUS PAGE*****
ETL Description TERM CHARGE PAYMENT BALANCE S EFF DATE RECEIPT ID
BSC BKSTR Com uter/Su lies TRAN TPAY
P PP 200720 42.90
BS6 BKSTR Grocery 200720 63.75 -259.10 T 01-FEB-2007 ARUSER 96
BSO BKSTR Pa Sales Tax 200720 2.73 -195.35 T 01-MAR-2007 ARUSER 97
BS4 BKSTR Clothing 200720 145.92 192.62 T 01-MAR-2007 ARUSER g8
BS7 BKSTR - Miscellaneous 200720 10.00 -46.70 T 01-MAR-2007 ARUSER 99
652 BKSTR Trade Books 200720 23,98 -36.70 T 91-MAR-2007 ARUSER 100
BS7 BKSTR Miscellaneous 200720 20,28 12.72 T O1-MAR-2007 ARUSER 101
BS4 BKSTR - Clothing 208720 20,98 7.56 T 02-APR-2007 ARUSER 102
356 BKSTR - Grocery 208728 22,22 28.54 T 02-APR-2087 ARUSER 103
3S3 BKSTR - Supplies 208720 15.73 50.76 T 02-APR-2007 ARUSER 104
350 BKSTR - Pa Sales Tax 200720 1.45 66.49 T 02-APR-2007 ARUSER 105
3S7 BKSTR - Miscellaneous 208720 85.88 67.94 T 02-APR-2007 ARUSER 106
3SO BKSTR Pa Sales Tax 200720 ,47 153.82 T O1-MAY-2007 ARUSER 107
356 BKSTR - Grocery 200720 56.41 154.29 T 01-MAY-2007 ARUSER 108
35 Housing Deposit Charge 200720 -200.00 210.70 T 01-MAY-2007 ARUSER 109
3S6 BKSTR Grocery 200720 5,82 10.70 T 21-MAY-2007 POWERSD 110
3S3 BKSTR Supplies 200720 6.50 16.52 T 31-MAY-2007 ARUSER 111
350 BKSTR Pa Sales Tax 200720 1,29 23.02 T 31-MAY-2007 ARUSER 112
3S7 BKSTR - Miscellaneous 200720 7.25 24.31 T 31-MAY-2087 ARUSER 113
3SC BKSTR - Computer/Supplies 200720 14.98 31.56 T 31-MAY-2087 ARUSER 114
!03 Tuition SSII 46.46 T 31-MAY-2007 ARUSER 115
103 Tuition SSII 200760 2,000.08 2,046.46 R 04-JUN-2007
200760 2,088.08 4,046.46 R 04-JUN-2007 WWW2 USER 116
iO3 Tuition SSII 208760 -2,008.08 WWW2 USER 117
07 Student Activities Fee Fall 200718 167.00 2,046.46 R 02-JUL-2007 HECKENDO 118
98 Tuition Fall 9,213.46 R 03-JUL-2007 POWERSD 119
08 Housing Apt Double - Fall 200770 17,725.08 19,938.46 R 03-JUL-2007
200770 2,590.0022POWERSO 120
08 Apt Meal Plan - Fall 200770 1,975.00 ,528.46 B 03-JUL-2007 POWERSO 121
03 Tuition SSII 24,503.46 V 03-JUL-2007 POWERSD 122
00760 009.00
07 Meal Plan - Summer Session II 200760 21755.00 26,583.46 R 03-JUL-207 WWW2 USER 123 230
13 Housing Summer Session II 200760 27,258.46 T 10-JUL-2007 SHANKP 124 130
638.00
57 BKSTR Miscellaneous 27,888.46 8 11-JUL-2887 POWERSD 125
S0 BKSTR - Pa
Mi Sales Tax 200760 5.49 27,893.95 T 01-AUG-2007 ARUSER 126
1 BKSTR - Text Books 200760 1.09 27,895.04 T 01-AUG-2087 ARUSER 127
13 BKSTR Supplies 200760 62.70 27,957.74 T 01-AUG-2007
200760 12.74 27,970.48 T 01-AUG-2007 ARUSER 128
11 Dickinson Posse Grant 200770 17,892.06 10,078.48 F 17-AUG-2007 ARUSER 129
:0 Supplemental Ed Opportunity Gr 200770 THOMPSCA 130
10 Subsidized Federal Stafford Lo 200770 68.08 10,018.48 F 17-AUG-2007 THOMPSCA 131
0 Federal Pell Grant 2,750.00 7,268.48 F 17-AUG-2007 THOMPSCA 132
0 Federal Perkins Loan 208770 2,155.00 5,113.48 F 17-AUG-2007 THOMPSCA 133
8 Apt Meal Plan - Fall 200770 775.00 4,338.48 F 28-AUG-2087 JONESS 134
4 Meal Plan - Fall 200770 -1,975.00 2,363.48 V 31-AUG-2007 HECKENDO 135
0 BKSTR - Pa Sails Tax 200770 2,175.00 4,538.48 V 31-AUG-2007 HECKENDO 136
1 BKSTR - Text Books 200870 1.64 4,540.12 T O1-OCT-2007 ARUSER 137
3 BKSTR - Supplies 200870 234.70 4,774.82 T 01-OCT-2007 ARUSER 138
- Pa Sales Tax 200870 27.32 4,802.14 T O1-OCT-2007 ARUSER 139
3 BKSTR
BKSTR - Text Books 200870 -1.64 4,800.50 T 01-OCT-2007 ARUSER 140
i BKSTR - Su lies 200870 -234.70 4,565.80 T 01-OCT-2007 ARUSER 141
PP 200870 -27.32 4,538.48 T 01-OCT-2007 ARUSER 142
BKSTR Pa Sales Tax 200770 1.64 4,548.12 T 03-OCT-2007 ARUSER 143
*CONTINUED ON NEXT PAGE*****
07-°JAN-2011 01:03:55 PM
ALL TERMS Dickinson College
Transaction Summary Report PAGE 5
Howard, Javan J TSRTSUM
----- *****CONTINUED FROM PREVIOUS PAGE*****
DETL Description TERM CHARGE PAYMENT BALANCE S EFF DATE RECEIPT ID
MB53 BKSTR - Supplies TRAN TPAY
32.18 27
F980 Supplemental Ed Opportunity Gr 208920 ,059.41 T 02-FEB
50.06 27,089.41 F 18-FEB-2009 ARUSER 192
F970 Federal Pell Grant 208920 2,365.58 24,643.91 F 18-FEB-2009 SCHENEMD 193
SCHENEMD 194
D811 Dickinson Posse Grant 200920 19,117.00 5,526.91 F 18-FEB-2009
L600 Subsidized.Federal Stafford Lo 200920 SCHENEMD 195
M102 Finance Charge 2,695.00 2,831.91 F 23-FEB-2009 THOMPSCA 196
M102 Finance Charge 288920 43.01 2,874.92 L 03-MAR-2009
200920 43.12 2,918.04 L 01-APR-2009 POWERSD 197
M110 Library Overdue Charge 200920 10.00 POWERSD 198
L710 Federal Perkins Loan 200920 2,928.04 T 23-APR-2009 POWERSD 199
M131 Dining Services 854.08 2,074.04 F 30-APR-2009
20THOMPSCA 200
M102 Finance Charge 0928 139.36 2,213.40 T 01-MAY•2009 ARUSER 201 230
200960 30.96 2,244.36 L 05-MAY-2009
M110 Library Overdue Charge 200920 15.00 POWERSD 202 230
M131 Dining Services 2009 2,259.36 T 22-MAY-2009 POWERSD 203 230
M131 Finance Charge 60 125.32 2,384.68 T O1-JUN-2009
208960 35,77 ARUSER 204 230
M107 Student Activities Fee Fall 200970 167.00 2,420.45 L 01-JUL-2009 POWERSD 205 230
T298 Tuition Fall 2,587.45 R 01-JUL-2009
200978 19POWERSD 206
8304 Meal Plan - Fall ,890.08 22,477.45 R 01-JUL-2009
200970 2,440.00 24,917.45 V 01-JUL-2089 POWERSD 207
D811 Dickinson Posse Grant 200970 20,057.00 4,860.45 F 14-AUG-2009 DC AUTO 208
F980 Supplemental Ed Opportunity Gr 200970 750.00 4,110.45 F 28-AUG-2009 DC_AUTOMMA 209
A 210
F970 Federal Pell Grant 200970 2,675.00 1,435.45 F 28-AUG-2009 DC AUTOMA 211
H402 Housing Double - Fall 200970 2,608.08
1135 Student Health Insurance 4,035.45 B 31-AUG-2009 HECKENDO 212
_600 Subsidized Federal Stafford Lo 200970 918.00 4,953.45 T 31-AUG-2009
2,708.75 2,244.70 F 15-SEP-2009 ARUSER 213
_610 Unsubsidized Fed Stafford Loan 200970 DC AUTOMA 214
1850 BKSTR - Pa Sales Tax 113.27 2,131.43 F 15-SEP-2009 DC_AUTOMA 215
1BS1 BKSTR Text Books 200970 1.79 2,133.22 T 01-OCT-2009
200978 466.35 2,599.57 T 01-OCT-2009 ARUSER 216
1853 BKSTR - Supplies 208970 16.91 ARUSER 217
1857 BKSTR - Miscellaneous 2,616.48 T 01-OCT-2089 ARUSER 218
1131 Dining Services 200970 12.95 2,629.43 T 01-OCT-2089
280970 107.46 2,736.89 T 01-NOV-2009 ARUSER 219
i102 Finance Charge 200970 39.44 ARUSER 228
:102 Finance Charge 2,776.33 L 03-NOV-2009 POWERSD 221
41.64 2,817.97 L 01-DEC-2009 POWERSD 222 266
111 Library Lost/Damage Book Chg 200970 14.00
108 Student Activities Fee Spring 201020 167.00 2,831.97 T O1-DEC-2009 POWERSD 223
299 Tuition Spring 2,998.97 R 01-DEC-2009 HECKENDO 224
4403 Housing Double Spring 201020 19,890.00 22,888.97 R O1-DEC-2089 HECKENDO 225
05 Meal Plan - S rin p g 201020 2,600.00 25,488.97 B 01-DEC-2009 POWERSD 226
3pring 201020 2,448.00 27,928.97 V 01-DEC-2009 POWERSD 227
131 Dining Services 201020 227.40 28,156.37 T 01-DEC-2009 ARUSER 228
131 Dining Services 201028 176.43 28,332.80 T 01-JAN-2010
229
ail Dickinson Posse Grant 201020 20,057.00 8,275.80 F 15-JAN-2010 DCUSER AUTOMA 230
'80 Supplemental Ed Opportunity Gr 201020 750.00 7,525.80 F 15-JAN-2010 DC AUTOMA 231
00 Subsidized Federal Stafford Lo 201020 2,708.75 4,817.05 F 15-JAN-2010 DC AUTOMA 232
)10 Unsubsidized Fed Stafford Loan 201020 113.28 4,703.77 F 15-JAN-2010 DC AUTOMA 233
;00 m.o. 16754088071 201020 75.00 4,628.77 T 25-JAN-2010 MILLEAMY 234
70 Federal Pell Grant 201020 2,675.00 1,953.77 F 25-JAN-2010 DC AUTOMA 235
31 Dining Services 201020 4.00 1,957.77 T 01-FEB-2010 ARdSER 236
SO BKSTR - Pa Sales Tax 201028 .97
S1 BKSTR - Text Books 1,958.74 T 02-FES-2010 ARUSER 237
S3 BKSTR Supplies 201020 268.20 2,226.94 T 02-FEB-2010 ARUSER 238
201020 16.22 2,243.16 T. 02-FEB-2010 ARUSER 239
***CONTINUED ON NEXT PAGE*****
1
Remit payment to:
Dickinson College PAGE 1
Q Z Student Accounts
(1 P.O. Box 1773
Carlisle, PA 17013-2896 ID#:
TERM: 201120
DUE DATE: 28—JAN-2011
Mr. Javan J. Howard TOTAL DUE: $ 1, 718.74
2455 Williamsbridge Rd Apt 3A AMOUNT ENCLOSED:
Bronx, NY 10469-4857
Student ID: Semester: Spring 2011
Student Name: Mr. Javan J. Howard Due Date: 28—JAN-2011
Tota!Due: S 1, 718.74
* PREVIOUS BILLED BALANCE
1,718.74
TOTAL DUE: $ 1, 718.74
Loan origination fees may vary depending upon your lender.
Memo items are not deducted from Total Due. These items may require additional action on your part.
If you have questions about this bill please call the Student Accounts office at 717-245-1953 or 717-245-1657.
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:
S%I y ecken , Bursar
Dated:
FARLES\Clients\7619 Dickinson College\7619.Collections\7619C.Current\7619C.431 Howard\7619C.431.com