HomeMy WebLinkAbout94-06375
, I
"
"
"
, I
~ 1,..1 ,
," , , ,t'.
, ,
, I
,
,I
I,
'J" I
'1,1, '"
, I
I
, I , , ' ' ,
'Ii
, , I " I,
, I
,I
I 'I
I
I
"
, I i,'
,
I ' ,
I
I , ' ,
,i, I
,
,
1", ,
"
,
" I
'I
, ,
I" ,
,"1
I " ',I,
"
"
"
II'
".
;.,
",t'
"
,I'
. , \
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
(vc <llL J~.k1'Y'-
DICKINSON COLLEGE,
plaintiff
STEPHEN T. CARNEY,
Defendant
NO. ql;- ~3 75
NOTICE
You hav~ b3en 8U8d in court. If vou wish to daf.nd aaainat
the claims set forth ~n the followina Daaes. you mu.t take action
within twentv (20\ davs after this comDlaint and notice are served.
fil~::e{ni~~i~i::~titt~n t:~p~~~::c:ou~e~:~~~~;~ 00: o~~e::[~~:-;o ~~:
claim. set forth aaainst you. You are warned that if vou fail to
do .0 the case mav \>roceed without vou and a iudamtnt may be
entered aaainst vou bv the court without further notlc~ tor any
money claimed in the comDlaint or for any other claim or relief
reauested bv the Dlaintiff. You mav lose monev or DroD4rtv or
other riqhts imDortant to vou.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE ~~E
OFFICE SET FORTH BELOW TO FIND ~WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR
Cumberland County Court House
Fourth Floor
Carlisle, PA 17013
(717) 240-6200
MC:,S, WALLA::J;E & NURICK
By_b~\) ~~.
Brett D. Dav s
I.D. No. 62668
100 pine Street
P. O. Box 1166
HarriSburg, PA 17108-1166
(717) 232-8000
Attorneys for Plaintiff
Dickinson College
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DICKINSON COLLEGE,
Plaintitt
STEPHEN ~'. CARNEY,
Detendant
NO.
COIIPLAIII'l'
1. Plaintitt, Dickinson college (hereinatter "Dickin.on"),
is an educational institution of higher learning which maintains an
addre.. at P.O. Box 2B96, Carlisle, Pennsylvania 17013.
" . Detendant, stephen T. carney, is an adult individual
whos. last known address is 191 Spring Road, North Kingstown, Rhode
Island 02852-1651.
3. On or about August 1, 1985, Defendant entered into an
Educational Goods and services Retail Installment Contract
(hel'elnatter "First Contract") tor expenses incurred tor goods and
services to be provided and rendered to Detendant by Dickinson
during the 1985-1986 academic year. A true and correct copy of the
First Contract is attached hereto and made a part hereot as Exhibit
"A".
4. On or about August 11, 1986, Detendant entered into a
Educatlonal Goods and Services Retail Installment Contract
(hereinafter "Second Contract") tor expenses incurred tor goods anC:
services to be provided and rendered to Detendant by Dickinson
during the 1986-1987 academic year. A true and correct copy ot the
Second Contract ie attached hereto and made a part hereot ae
Exhibit "B".
5. Paragraphs 1
reference thereto.
6. Under the terms of the First contract, Defendant agreed
to pay Oickinaon Seven Thousand Dollars ($7,000) with interest at
the initial rate of 10. 498t per annum in 152 equal Dlonthly
installm.nts of Eighty-three Dollars and Forty-lour Centa ($83.44)
commencing on October 1, 1985.
7. Under the terms of the Second contract, Defendant agreed
to pay Dickinson Seven Thousand Dollars ($7,000) with interest at
the initial rate of 9.499' per annum in 140 equal monthly
inatl\llments of Eighty-two dollars and Ninety Cents ($82.90)
commencing on september 30, 1986. (The First Contract and Second
Contract /Sre collectively referred to as the "contracts")
8. The Contracts further provide that "[ i J f a payment is
more than 15 days late, a sum equivalent to 5' of th~ late payment
(but no more than $2.50 and not less than $1. 00) may be charged."
9. The Contracts further provide that if an event of default
of the Contracts occurs, and is not cured by the borrower,
Dickinson had "the right to declare all sums due on the Contract to
be immediately due and payable."
10. Defendant defaulted on his obligation under the Contracts
by failing to make the required monthly payments when due. Despite
being advised of the default on his obligation, Defendant has
failed to cure such default.
11. In accordance with the terms of the Contracts, Dickinson
COUIIT I
through 4
are
incorporated herein by
- 2 -
. ha. declar.d the Contracts to be in default. The total a..ount
which beca... due and owing to Dickinson by Defendant pur.uant to
the contract. is TWelve Thousand One Hundred Thirty-nine Dollar.
and Ninety C.nt. ($12,139.90), which includes inter..t through
october 21, 1994.
12. Dickinson has demanded payment of the obligation owed to
it by Defendant, but Defendant has failed and refused to do .0.
WHEREFORE, Plaintiff demands judgment against Stephen T.
Carney ,in the sum of TWelve Thousand One Hundred Thirty-nine
Dollars and Ninety Cents ($12,139.90), plus interest at $1.86 per
diem from October 2]" 1994, until Defendant's obligation is paid in
full, plus costs of suit, which sum does not exceed the jurisdic-
tional limit for compulsory arbitration.
COUNT II
In the alternative, if this Honorable Court should determine
that an express contract between the parties does not exist, which
is denied, Plaintiff pleads the following:
13. Paragraphs 1 through 4 inclusive are hereby incorporated
herein by reference.
14. Having requested Dickinson College to loan money and
doing so to the benefit of Defendant, Defendant became liable to
Dickinson College for said money.
15. Defendant has been unjustly enriched by uccepting said
money without paying Dickinson college reasonable compen.ation
therefor.
16. The total amount by which Defend~nt has become enriched
- 3 -
on account ot the money loaned ia Fourteen Thou.and Dollara
($14,000.00).
17. Dickinaon College haa demanded that Detendant pay thia
amount but Detendant haa tailed and retused to do ao.
WHEREFORE, plaintiff demanda judglllent againet Stephen T.
carney in the IUlll ot Fourteen Thouaand Dollara ($14,000.00), plus
intereat and coate of auit, which aUlll do. a not exceed the
juriedictional limit tor cOlllpulaory arbitration.
McNEES, WALLACE ~URICJ(
By l?$() ~d,
Brett D. Davis
I.D. No. 62668
100 Pine street
P. O. Box 1166
Harriaburg, PA 17108-1166
(717) 232-8000
Attorneys tor Plaintitf
Dickinaon College
Datedl '0 .;}-qLf'
- 4 -
VERIFICATION
Subject to the penalties of 18 Pa, C.S. 54904 relating to
un.worn fal.ification to authoritie., I hereby certify that I ..
Thoaa. B. Meyer of Dickinson college, and I am authoriae4 to verify
this co.plaint on it. behalf, and further, that the fact. .et forth
in the foregoing Complaint are true and correct to the b..t of .Y
information an4 belief.
~~
D:ate4z
"
.,
,.
Number of Pa ents
1.52
*Variable Rate:
Late Charge:
Prepayment:
'.-..
,-.,
Buyer's payment schedule ~i11 be as follows:
Amount of Pa ments
-I
When Pa ents Are Due
Monthly commencinsOctober I, 1985
until /lay I, 1998
83.44
The ANNUAL PERCENTAGE RATE disclosed above is a variable rate
and may change. The ANNUAL PERCENTAGE RATE may increase during
the term of this transaction if the prime rate of interest
announced in the Wall Street Journal as of the close of
business on June 30 of each calendar year increases, and will
be increased to the prime rate plus 1%. The ANNUAL PERCENTAGE
RATE will not increase more than once a year. and the new
intereat rate will become effective on July 1 following the
increase, if any, in the prime rate of interest. Any increase
will be in the form of higher payment amounts. If your cost
of the Goods and Services sold hereunder were $ 7000.00
at 10.5 % per annum for 152 months, and the prime rate plus
1% were increased to 11. 5 %, your regular monthly payments
would increase to $ 67.64 Further, the ANNUAL PER-
CENTAGE RATE will not increase to more than 18% or such other
rate as may be permitted under the Pennsylvania Goods and
Services Installment Sales Act.
If a payment is more than 15 days late, a sum equivalent to
5% of the late payment (but no more than $2.50 and not less
than $1.00) may be charged.
Buyer may prepay the unpaid balance of the Amount Financed
and any FINANCE CHARGE due through the date of early payment,
in full or in part, without penalty. Payments greater than
the payoff amount but less than $3.00 will not be refunded.
SEE SECTION VI OF THE CONTRACT BELOW FOR ANY ADDITIONAL INFORMATION ABOIlT NON~
PAYMENT, DE1AULT AND REQUIRED REPAYMENT BEFORE THE SCHEDULED DATE FOR REPAYMENT
OF THE AMOUNT FINANCED.
-2-
"
r-,
(c) failure to perform any other provision of the Contract.
(d) providing Seller with false information or signatures,
(e) death, incompetence. or conviction of any Buyer of crime in-
volvina fraud or dishonesty,
(f) insolvency or bankruptcy of any Buyer.
4. Upon or after the occurrence of any Event of Defsu1t, Seller will
provide Buyer with notice, by certified mail as required by law, addressed to
Buyer's last known address as shown on Seller's records, advisina Buyer of the
default and of Buyer's right to cure the default. The notice will provide the
time, amount and performance necessary to cure the default. If Buyer does not
cure the default as provided in the notice, Seller's rights shall include the
right to declare all sums due on the Contract. to be immediately due and payable.
5. Waiver by Seller of any event of default shall not be binding upon
Seller if Seller should thereafter choose to exer~ise that or any other right
or a similar Event of Default occurs later. All Seller's rights and remedies
.hall be cumulative. Seller's exercise of one or more rights shall not cause
Seller to lose any other rights.
6. This Contract is freely assignable by Seller. Buyer agrees that upon
receiving notice of the assignment Buyer shall be obligated to the Assignee
of this Contract, which Assignee shall have all of Seller's rights and remedies.
7. 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.
8. The laws of the Commonwealth of Pennsylvania shall apply to this Con-
tract except to the extent supplemented, superseded or pre-empted by federal
law.
9. This Contract shall be binding upon the parties hereto, their heirs,
.uccesaora, assigns and hgal r..pre...mtativea.
10, TIME IS OF THE ESSENCE OF THIS CONTRACT.
NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS
AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF COODS OR
SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY
HEREUNDER BY THE DEBTOR SHALL NOr EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER.
NOTICE TO BUYER: (1) DO NOT SIGN THIS AGREEMENT BEFORE YOU READ IT OR IF IT
CONTAINS ANY BLANK SPACE. (2) YOU ARE ENTITLED TO A COMPLETELY Fll,LED-IN COPY
OF THIS AGREEMENT. (3) UNDER THE LAW, YOU HAVE THE RIGHT TO PAY OFF IN ADVANCE
-4-
.
.""""\
1"'\
THE rutJ. A.'tOUNT DUE AND UNDER CERTAIN CONDITiONS TO OBTAIN A PAIlTl.U. REFUND
or THE rINANCE CHARGE.
BUYER(S) ACKNOWLEDGE(S) RECEIVING A COMPLETED COPY OF THIS
CONTRACT AND INTEND( 0 LEGAL~Y ~~D BY ITS TEIIHS.
BUYER(S): ." (4'0.t'.,
DATE:
<? kl ~:S-
4~"LJ:J -;iL
By
FOR DICKINSON COLLEGE USE ONLY
For value received, Seller hereby sells, assigns, and transfers
to Industrial Valley Bank and Trust Company all of Seller's ri&hts,
title and interest in this Educational Goods and Services Retail
Installment Contract, with full recourse to Seller.
This
zZ-
day of
~:i:- /-<l5U
/ '"
a~d,,~~
TITLE
DICKINSON COLLEGE, BY:
-5-
I,
-,
EXHIBIT "B"
.. 1',; c ,;
,-"
r
BORROWER ALREADY HAS AN
ACCOUNT ESTABLISHBD....
":. (. "___j..I, J { I
DICKINSON COLLEGE FLEXIBLE FINANCING SYSTEM - 7000 PLAN
EDUCATIONAL GOODS AND SERVICES RETAIL INSTALLMENT CONTRACT
Date AUR\lst 11. 1986
1. Seller: Dickinson College, Carlisle, Pennsylvania 17013
Buyer (s):
Stephen T. Csrney
If there is more than one Buyer, each of you will be obligated, jointly
and severally, for all sums d\le and for the performance of all agreements as
provided in this Contract.
Under the terms of this Educational Goods and Services Retail Install-
ment Contract, you have agreed to pay the expenses incurred for goods and
services to be provided and rendered, as the case may be, to Stephen
(hereinafter "Student") during his/her enrollment at
Dickinson College during the 1986-87 academic year, including
tuition, room and board, books and supplies as herein stated (hereinafter the
"Goods and Services").
The Goods and Services shall include only the following: Tuition.
and room and bosrd.
f~ ,) J ( "(,
:';
I' ,
! l
'" h,/ ~
11. TERMS OF PAYMENT AND PAYMENT SCHEDULE
Disclosures Required by Federal Law
,Lj 1hz-.
ANNUAL
PERCENTAGE
RATE: *
Cost of credit
as yearly rate
FINANCF.
CHARGE:
Dollar amoun
credit will
cost Buyer
AMOUNT FINANCED:
Amount of credit
provided by
Dickinson College
TOTAL OF
PAYMENTS:
Amount paid
by Buyer as
total of all
scheduled
payments
TOTAL SALE
PRICE:
Total cost of
purchase on
credit, in-
cluding down
payment of
$ 6.35Q.&O
$ 13.350.00
9.499
$ 4,606.00
$ 7 ,000.00
$ 11,606.00
%
fi'
.""'\
1"'1
Buyer's payment schedule will be as follows:
Number of Pa ents
Amount of pa ments
When Pa ents Are Due
140
$82.90
Monthly commencina
until 5/30/98
9/30/86
*Variable Rate: The ANNUAL PERCENTAGE RATE disclosed above is a variable rat.e
and may chanae. The ANNUAL PERCENTAGE RATE may increase durina
the term of this transaction if the prime rate of interest
announced in the Wall Street Journal as of the close of
business on June 30 of each calendar year increases, and will
be increased to the prime rate plus 1%. The ANNUAL PERCENTAGE
RATE will not increase more than once a year, and the new
interest rate will become effective on July 1 followina the
increase, if any, in the prime rate of interest. Any increase
will be in the form of hiaher payment amoun.ts. If your cost
of the Goods and Services sold hereunder were $ 7.000.00
at 9.5 % per annum for l40 lIIOnths, and the prime rate plus
1% were increased to lO.5%, your reaular monthly payments
would incree.se to $ $86.91 Further, the ANNUAL PER-
CENTAGE RATE will not increase to more than 18% or such other
rate as may be permitted under the Pennsylvania Goods and
Services Installment Sales Act.
Late Charae: If a payment is more than 15 days late, a sum equivalent to
5% of the late payment (but no more than $2.50 and not less
than $1.00) may be charged.
Prepayment: Buyer may prepay the unpaid balance of the Amount Financed
and any FINANCE CHARGE due throuah the date of early payment,
in full or in part, without penalty.
SEE SECTION VI OF THE CONTRACT BELOW FOR ANY ADDITIONAL INfORMATION ABOUT NON-
PAYKENT, DEFAULT AND REQUIRED REPAYMENT BEfORE tHE SCHEDULED DATi: FOR REPAYMENT
OF THE AMOUNT FINANCED.
-2-
-~\ r-"
III. ITEMIZATION OF AMOUNT FINANCED
1. Cash price of Goods and Services: $ 13.3~0.00
2. Total down payment: 6.350.00
3. Unpaid balance of calSh price (1 - 2): 7.000.00
4. Amount paid to others on Buyer's behalf: 0
5. Amount Financed (3 + 4): $ 7.000.00
IV. CREDIT INSURANCE
Credit life insurance for the term of this Contract is not required.
V. NO WARRANTIES
THERE ARE NO WARRANTIES, EITHER EXPRESSED OR IMPLIED, GIVEN BY SELLER IN
CONNECTION WITH SALE OF THE GOODS AND SERVICES COVERED BY THIS CONTRACT UNLESS
BUYER HAS BEEN GIVEN A SEPARATE WRITTEN WARRANTY.
VI. ADDITIONAL PROVISIONS
1. Buyer agrees to pay Seller the Total Sale Price by making the total
down payment and paying Seller the Total of Payments in the number and amount
of monthly payments shown in the Payment Schedule. Payments are due on or
before the same date of each month as the first payment date. Payments must
be made to Pidelity Bank at the followins address:
PideIi ty Bank
141 Garrett Road
Upper Darby, PA 19082
2. Buyer's legal rights include the right to pay all or part of the amounts
due on this Contract in advance of their due dates, to obtain a refund or credit
of unearned Finance Charge whenever the amount is paid in full in advance, and
(with Seller's consent) to reinstate the Contract if Buyer timely cur.es any
defaul to
3. Buyer shall be deemed to have committed an "Event of Default" of the
Contract upon the occurrence of any of the following:
(a) failure to make any payment on or before the date it is due,
(b) failure to make a payment on any other contract outstanding
with Seller,
-)-
--..,
f",
(c) faiLure to perform any other provision of the Contract,
(d) providing Seller with falss information or signatures,
(e) death, incompetence. or conviction of any Buyer of crime in-
volving fraud or dishonesty,
(f) insolvency or bankruPtcy of any Euyer.
4. Upon or after the occurrence of any Event of Default, SeLler will
provide Buyer with notice, by certified mail as required by law. addressed to
Buyer's last known address as shown on Seller's records, advising Buyer of the
default and of Buyer's right to cure the default. The notice will provide the
time, amount and performance necessary to cure the default. If Buyer does not
cure the default as provided in the notice, Seller's rights shall include the
right to declare all sums due on the Contract to be immediately due and payable.
5. Waiver by Seller of any event of default shall not be binding upon
Seller if Seller should thereafter choose to exercise that or any other right
or a similar Event of Default occurs later. All Seller's rights and rem~dies
shall be cumulative. Seller's exercise of one or more rights shall not cause
Seller to lose any other rights.
6. This Contract is freely assignable by Seller. Buyer agrees that upon
receiving notice of the assignment Buyer shall be obligated to the Assignee
of this Contract, which Assignee shall have all of Seller's rights and remedies.
7. 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.
8. The laws of the Commonwealth of Pennsylvania shall apply to this Con-
tract except to the extent supplemented, superseded or pre-empted by federal
law.
9. This Contract shall be binding upon the parties hereto, their heirs,
successors, assigns and legal representatives.
10. TIME IS OF THE ESSENCE OF THIS CONT&\CT.
NOTIC~: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS
AND DEFENSES WHICH THE DEBTOR COULD ASSERt AGAINST THE SELLER OF GOODS OR
SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY
HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER.
NOTICE TO BUYER: (1) DO NOT SIGN THIS AGREEMENT BEFORE YOU READ IT OR IF IT
CONTAINS ANY BLANK SPACE. (2) YOU ARE ENTITLED TO A COMPLETELY FILLED-IN COPY
OF THIS AGREEMENT. (3) UNDER THE LAW, YOU HAVE THE RIGHT TO PAY OFF IN ADVANCE
-4-
"
"
.
,
.
DICKINSON COLLEGE,
plaintiff
IN THE COURT OF COMMON PLEAS
CuMBERLAND COUNTY, PE~SYLVANIA
NO. 94-6375
v.
STEPHEN T. CARNEY,
Defendant
CIVIL ACTION - LAW
PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Pursuant to Pa. R. Civ. P. No. 1037(b), enter judgment in
favor of Dickinson College, Plaintiff, in the above-captioned
action, and against Stephen T. Carney, Defendant, in the
above-captioned action, for failure to file an Answer to
Plaintiff's Complaint within twenty (20) days from the date of
service of said Complaint nnd assess Plaintiff's damages in the
total sum as follows:
/
Count I - $12,139.90, plus int.erest at $1.86 per diem
from October 21, 1994, until Defendant's obligation is paid in
full, plus costs of suit, which sum does not exceed the
v
jurisdictional limit for compulsory arbitration! or
Count II - $14,000.00, plus interest and costs of suit,
which sum does not exceed the jurisdictional limit for compulsory
arbitration.
,
.
I hereby certify that a written Notice of Intention to File
this Praecipe for Entry of Default Judgment was given in
accordance with Pa, R. Civ. P. No. 237.1; a true and correct copy
of the aforesaid Notice is attached hereto.
I hereby certify that the last known address of the
Defendant, Stephen T. Carney, is 191 Spring Road, North
Kingstown, Rhode Island 02852.
McNEES, WALLACE & NURICK
BY:f!.f1. j?0-
Attorney I.D. No. 62668
100 pine Street
P. O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Dated: JI~&f (~~
Attorneys for Plaintiff
.
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-6375
DICKINSON COLLEGE,
Plaintiff
STEPHEN T. CARNEY,
Defendant
CIVIL ACTION - LAW
NOTICE OF ENTRY OF JUDGMENT
TO: Stephen T. Carney, Defendant
You are hereby notified that on
following Judgment has been entered against
above-captioned case.
, 1995, the
you in the
DATE:
CUMBERLAND COUNTY PROTHO~OTARY
I hereby certify that the name and address of the proper
person(s) to receive this notice under Pa. R. Civ. P. 236 is:
STEPHEN T. CARNEY
191 SPRING ROAD
NORTH KINGSTOWN, RI 02852
McNEES, WALLACE & NURICK
By;1~QilJ--
Attorneys for Plaintiff
"....,
r-"
..
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DICKINSON COLLEGE,
Plaintiff
STEPHEN T. CARNEY,
Defendant
NO. 94-6375
NOTICE OF INTENTION TO
ENTER JUDGMENT BY DEFAULT
TO: Stephen T. Carney, Defendant
DATE OF NOTICE: October 9, 1995
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST
YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET
LEGAL HELP:
COURT ADMINISTRATOR
Cumberland County Courthouse, 4th Floor
Carlisle, PA 17013
(717) 240-6200
McNEES, WALLACE & NURICK
~~DOD.D-
Attorney 1.0. No. 62668
100 Pine Street
. P. O. Box 1166
Harrisburg, PA 17108-1~66
(717) 232-8000
Attorneys for Plaintiff
""CCO.~
~1t.IIOlfNTON..J1t
PIC I.. I"UI..a...
lICK"" M, CMIMY
'Ml..&JAM A. CMESNl,It1'
DNIIO. ClINC"
IilIICM.Al1. /10. OOCT.,.
CLlIAMTH" DOUOMI"T"
HNfvIY'_CDlN_1'O
JAMQ I.. '",11
'MHc:II., HMa, .,IN,
W. JU'~ J.-MOVNl/IoU
MICMAlI.O, J~
~VIO M, ItU""'Norlt
~14, L.AaUa.D,.,llt
DlLANO M. I.ANTJ
. .
ItICHNtO It, L.t'{VU
CAVIOI,I.IHMAN
C..."OI.W.IlfcINfY'Il
'1ItAN1WN 14. 1011"'11, ,JIt
1tOK"" /10. hllll.S
ITIJI'HIN A. 11400M:
MI"-lllllT It NU"'CK
JOHN I, OYI.IR
tIMOTH" J It'IIU''
QAlt'tA"'TfI"
IOWAlltOW *lTHMAN
0-.,..... ,tIVIN.ICAOUtO
IIttOlIlilt1'O ITITI
IItICH""D W. 111'VINtON
CIANI hi. TQIWt6lt'l'
DAVIO Ill. WAlTa. .lit
"
~
McNEES, WALLACE & NURICK
ATTORNEYS AT LAW
100 FJIN[ STREET
P. O. BOX Ilee
H!lRRISBURO, P!I "'0.'''..
TCI.l~ONI171712J2'8000
F'AXI7171237'5JOO
g, COUNYL.
NOUN1' M. I)It!IIWOLD
SAMUIL. /10. ICHRlCIU:NQ,ol,UIf. J",
,T{VIN J. WlIN~TlN
N[Al.I.UT
NOf'MANI,WIoIITI
'-"WlttNCl It, WIItDVt
WlUIAM M. YOUNO, JIt.
.",C N..TtoItY
OAVlOM,....Kllt
JONATHAN C,."""
eMlT D. DAVIII
JAfltr.llt DcANGlLO
J,tJlIIIIt. DOUI)MIMY
ICATIoILIIN A. Ol.JNIIT
1ItOIIlltT J GOOUTO
leorT A. OQUL.D
JtQKItT lJ..........
_AN " JACIC80N
OONALOI MU'''''''''
MICHAlI." Ml,LU"
!tUEII'. """ITI
J/IoMII W "'UTI
C""'IL.LICJroWItION
IHAItON N. I'/IolIlTON
CHUONO H.......AM
JONAT....AN H. RUlX)
UlUCI" ,,",Cllt
CAfIIOL A. "IINOUIt
CAn~r,lllNIII. WAI. nu.
lXlt"IC'" I' WILLII4P4ON
-
(~ ~, ~
"'~
\~
'^ ~
G' r-" C" '1
-, F\ (' (j', ,\
'-^.;~ -,,}I ;-,;
\ ~~ [:,~ ( "
t ;:-;, '1
,,~ J
~ '.' ,\
-p., \F f;.~ ( 'I
.,
~ .J" a.:..( , '
, )
~:. f r',J " I ~ 1
~ ".", "
( { ,~'\ :.' .~
~."
'-'"
~'
- ~
\ ~
....
I ~
~
Office of the Prothonotary
Attention: Janey
Cumberland County Courthouse
One Courthouse square
Carlisle, PA 17013-3387
IMUC& O. MCIUY
N,,}.HIt,IK7'rNTON,JIt
-~-
lIIOMIITM,":M&MY
QWO..[)Uiln
llftOfAIl.A.I:IOC:TM:lW
lL.I&'M:THA.~I"'"
~AI'lIIC' ..""IX""....
..IAMU '" ""TZ
W. .II""" IN<llJHI.AU
MN:HMI. 1I..JNIItAM
DOflWJ)alCAUII'MN\l
o.VIO M. ~/IIOP
IPNNIOA, I,A&lIMI.JIt,
OCLAHQM,f.ANfJ
w.
~
I:,
'I
'I
I
li.
i/:'
,
>:r~
i(
{I
~! ,.'I'
McNEES. WALLACE & NUNICK
ATTORNEYS AT LAW
lIItCHMD II. l.Ul\Illt
Di'VIOI.LlMfiIW'
CI.YOCWMcI"'f'f'''
'~IWN A. NlI.U, ..lit
~"'ANlIJ.I
I'I""[N" IiIIOOItC
HVtK'" II. NUItl(M
JOHN ._ onE"
ONfY" "'''lit
1I~*..orHJllAH
~"IVIN'1CAOU10
IW>>IJtTOlll"
ItlCHNlOW,T[VINION
~l.,'~'
CATHVIlHII ....,PI
100 PINE STREET
P. O. BOX Ilee
DAVID N, WAfTI...I1t
'T[\IINJ,~No.'Ii"U:N
N~'.wU1
N~I,WHlTI
VoWIItlNCIIt,WlIDllt
'MI.UAM N. YOUNG...I11
HARRISBURG, "A '''De'''..
TIL.I~ON117171 232-8000
F.u1117IUH5300
c:# (ClUNK&.
1tOKIn' M. 0IIlIWCllD
,~... HNlI, ..lit
INoIUII. A. ICHl'llCKtNGo'VlT, JIt
IIIIlCH....'M[\'
JONAf"-NiC,IIMY
".,..,...~N
JI,'M", CloI"""AONI
.-" 0 DAVlI
JAMU". DIAHOII.O
.JAMU". DOUQHPTY
AATMI.IINA. DUHI'
DUM", 'CUMM
April 29, 1996
(.
,
Re: DICKINSON COLLEGE
v. Stephen T. Carney
Our rile No. 00765-0100
No. 94-6375
r,'"
r
[,.,
I
~; ;
t_.,
,
.. ~. .
Dear Janey:
~co..-w.. HOUtfOH
IIIOKJtTJ.GOOVTo-
KOTTA.OOl.I'-D
-..-
"'~',JN:MIC)lIIt
....CMAI....1ilIU.n
Nflll '.llIlllTi
JAMUW, IWfI
CAMILLI c. MMlON
~MON Ill. "","ON
(MUONG Jot."'"
...ONA"...~". MIOD
IIIlIUCI II. MCIIIt
CNlQ.A. .,,1UHQUIIt
~',TPUTI
1XII'IIClC.,WlW.~ .1 J
I,',
1..;1
.,
I
I
" ::J
"If
.:)
':)
) .~.l (
...j
;jll
".
-..
- .
t.,)
"
c,
>'!
.
,,1
As per our conversation of last week, enclosed please find a
check in the amount of $9.00. Please enter the judgment on both
counts for the above-captioned matter.
If you have any additional questions, please do not hesitate
to contact me. Thank you for your assistance.
l:er truly fours,
~-JJjtJ
. Bonnie Davis
Secretary
Enclosure
, i
,"
~
ie
en
~
~
-
..>-
...,..
"l,:~:P'
. , : ~."
~~.J
-,
1.0
~
".;
'..:)
C'