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Home My WebLink About14-6662 Supreme Cou>rt�of Pennsylvania CourtM-Common leas For Prothonotary Use Only: Cvil'C.over�Sheet �� Docket No: Crberland`z4 County lq-- The information collected on this form is used solely for court administration purposes. This forst does not supplement or replace the filing and service of pleadings or other papers as required by lav or rules of court. Commencement of Action: S 0 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 Lauren A. Kaye I Are money damages requested? El Yes 0 No Dollar Amount Requested: Owithin arbitration limits (check one) Eloutside arbitration limits N Is this a Class Action Suit? Yes [E No Is this an MDJAppeal? 0 Yes X, 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 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 0 Intentional 0 Buyer Plaintiff Administrative Agencies Cl Malicious Prosecution El Debt Collection: Credit Card O Board of Assessment 0 Motor Vehicle [E Debt Collection: Other 0 Board of Elections 0 Nuisance Unpaid student loans Dept.of Transportation Premises Liability 0 Statutory Appeal: Other S 0 Product Liability(does not include E mass tort) 0 Employment Dispute: Slander/Libel/Defamation Discrimination C 0 Other: El Employment Dispute: Other Zoning Board T Other: I 0 Other: O MASS TORT 0 Asbestos N 0 Tobacco 0 Toxic Tort-DES 0 Toxic Tort- Implant REAL PROPERTY MISCELLANEOUS ID Toxic Waste Other: 0 Ejectment 0 Common Law/Statutory Arbitration B 0 Eminent Domain/Condemnation 0 Declaratory Judgment 0 Ground Rent 0 Mandamus 0 Landlord/Tenant Dispute 0 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 Other: 0 Medical 0 Other: 0 Other Professional: Updated 1/1/2011 % / FAFILES\Clients\7619 Dickinson College\7619.Collections\7619C.Current\7619C.436 Kaye\7619C.436.com.sa.wpd Christopher E. Rice Esquire Attorney I.D. No. 90916 1 ;LEU-O F ICtl MARTSON DEARDORFF WILLIAMS OTTO GILROY &FALLER' MARTSON LAW OFFICES 2 �� PM 12: i Ten East High Street Carlisle, PA 17013 1'UMBERLAND COUNTY (717) 243-3341 PENNSYLVANIA Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2014 - CIVIL TERM LAUREN A. KAYE. 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 D c FAFTLES\Clients\7619 Dickinson College\7619.Collections\7619C.Current\7619C.436 Kaye\7619C.436.com.sa.wpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2014 - (, CIVIL TERM LAUREN A. KAYE. 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 FAFILES\Clients\7619 Dickinson College\7619.Collections\7619C.Cuuent\7619C.436 Kaye\7619C.436.com.sa.wpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2014 - CIVIL TERM LAUREN A. KAYE, Defendant COMPLAINT AND NOW, comes Plaintiff,Dickinson College,by and through its attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, 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. 2. Defendant Lauren A. Kaye (hereinafter"Student")is an adult individual whose last known address is 2655 Lake reunion Parkway, Decatur, IL 62521-8907. COUNT BREACH OF CONTRACT 3. Paragraphs 1 through 2 are incorporated herein by reference as if set forth in full below. 4. Student was recently enrolled at Dickinson. 5. Student opened a Student Receivables Account (hereinafter "Account") with Dickinson to pay tuition, dining service fees and other educational expenses provided and rendered to Student by Dickinson. A true and correct copy of that Account is incorporated by reference and attached as Exhibit"A." 6. Student, by opening the Account and using the goods and services provided by Dickinson, agreed to pay Dickinson for all charges made to the Account. 7. Student received and accepted all goods and services provided by Dickinson and thereby agreed to payment for said goods and services. 8. The terms of repayment required Student to pay all balances 14 days before the beginning of each semester. 9. Student defaulted on the repayment of the Account by not paying the balance when due. 10. Notices were forwarded to Student informing her of her default and right to cure such default. 11. Student failed to cure such defaults. 12. The total amount which is immediately due and payable to Dickinson by Student on the Account is $65,854.71. WHEREFORE,Plaintiff Dickinson College demands judgment against Defendant Lauren A. Kaye in the sum of$65,854.71, plus late fees, costs of suit and interest from date of judgment. COUNT II IN QUANTUM MER UIT In the alternative,if this Honorable Court should determine that an express contract between Dickinson and Lauren Kaye does not exist, which is denied, Dickinson pleads the following: 13. Paragraphs 1 through 12 are incorporated herein by reference as if set forth in full. 14. Because Dickinson loaned money to Student, to the benefit of Student, Student became liable to Dickinson for said money. 15. Student was unjustly enriched by accepting said money without paying Dickinson reasonable compensation therefor. 16. The total amount by which Student has become enriched is $65,854.71. 17. Dickinson demanded payment of the above sums but Student failed and refused to do so. WHEREFORE,Plaintiff Dickinson College demands judgment against Defendant in the sum of$65,854.71, costs of suit and interest from date of judgment. MARTSON LAW OFFICES By: ��11 < /L. - Christopher E. Rice, Esquire I. D. Number 90916 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: I�� 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" Remit payment to: PAGE 1 on D-'11cons Dickinson College Student Accounts P.O. Box 1773 ID#: 900187299 Carlisle, PA 17013-2896 TERM: 201470 DUE DATE: 31-JUL-2014 Ms. Lauren A. Kaye TOTAL DUE: $ 65, 854.71 2655 Lake Reunion Pkwy Decatur, IL 62521-8907 AMOUNT ENCLOSED: $ Student ID: 900187299 Semester: Fall 2014 Due Date: 31—JUL-2014 Student Name: Ms. Lauren A. Kaye Total Due: $ 65,854.71 .Iix?;-. ,{.. �,..� `.. y.�,Y� yrs ,t�v••:n"'.. .. �^'�''if(Yy��J�.y 1;.+.fit)Ck,FT !. ..ai•., 4_ ys r'r l /��v+,{'r/ ;y1%fesf�[[ `y'.Af. ""tib 7v .�• * PREVIOUS BILLED.BALANCE * 65,854.71 TOTAL DUE: $ 65,854.71 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. Q� 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 Hecken orn, Bursar F:TILES\Clients\7619 Dickinson Coll ege\7619.Collections\7619C.Cur ent\7619C.436 Kaye\7619C.436.com.sa.wpd