Preview
> ZOrHeQNED
ZOosmAOmD
wa
For Prothonotary Use Only:
Docket No:
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:
E] Complaint
1 Transfer from Another Jurisdiction
DI writ of Summons
DO Petition
1 Declaration of Taking
Lead Plaintiff's Name:
University of the Sciences in Philadelphia
Lead Defendant’s Name:
Sarma Pin
Are money damages requested? El] Yes
0 No
Dollar Amount Requested:
(check one)
Elwithin arbitration limits
Doutside arbitration limits
Is this a Class Action Suit?
O Yes
El No
Is this an MDJ Appeal?
0 Yes El No
Name of Plaintiff/Appellant’s Attorney: Gregory J. Allard, Esquire
O Cheek here if you have no attorney (are a Self-Represented [Pro Se] Litigant)
TORT (do not include Mass Tort)
O Intentional
1 Malicious Prosecution
1 Motor Vehicle
D1 Nuisance
1 Premises Liability
D2 Product Liability (does not include
mass tort)
D1 Slander/Libel/ Defamation
D Other:
MASS TORT
DD Asbestos
1 Tobacco
1 Toxic Tort - DES
D1 Toxic Tort - Implant
1 Toxic Waste
5 Other:
CONTRACT (do not inelude Judgments)
D1 Buyer Plaintiff
1 Debt Collection: Credit Card
EK] Debt Collection: Other
Breach of Contract
1 Employment Dispute:
Discrimination
1 Employment Dispute: Other
CIVIL APPEALS
Administrative Agencies
LD Board of Assessment
(1 Board of Elections
Dept. of Transportation
Statutory Appeal: Other
DD Zoning Board
PROFESSIONAL LIABLITY
1 Dental
OD Legal
OO Medical
LD Other Professional:
DO Other:
DD Other:
REAL PROPERTY MISCELLANEOUS
Ejectment 1 Common Law/Statutory Arbitration
1 Eminent Domain/Condemnation
0 Ground Rent
D1 Landlord/Tenant Dispute
1 Mortgage Foreclosure: Residential
OO Mortgage Foreclosure: Commercial
D1 Partition
D Quiet Title
DD Other:
1 Declaratory Judgment
Mandamus
Non-Domestic Relations
Restraining Order
Quo Warranto
Oo Replevin
D other:
Updated 1/1/2011IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY, PENNSYLVANIA.
UNIVERSITY OF THE SCIENCES : DELAWARE COUNTY
IN PHILADELPHIA : COURT OF COMMON PLEAS
600 South Forty-Third Street :
Kline Hall 6
Philadelphia, PA 19104-4495
v.
SARMA PIN
708 Milmont Avenue
Swarthmore, PA 19081-2632
claims set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
court your defenses or objections to the claims set forth again
fail to do so the case may proceed without you and a judgment m
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
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 I
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LAWYERS REFERENCE SERVICE24 Regency Plaza
(610) 358-9600
Attorney for Plaintiff
UNIVERSITY OF THE SCIENCES
IN PHILADELPHIA
600 South Forty-Third Street
Kline Hall 6
Philadelphia, PA 19104-4495
v.
SARMA PIN
708 Milmont Avenue
Swarthmore, PA 19081-2632
DELAWARE COUNTY
COURT OF COMMON PLEAS
1. The Plaintiff, University of t
profit, organized and existing under the Laws of the Commonweal
2. The Defendant, Sarma Pin, is an individual and citizen of the Commonwealth of
ont Avenue, Swarthmore, Penns
3. At the special insistence and request of the Defendant, while
Promissory Notes, pursuant to whi
by the Plaintiff the sum of
ct copies of said Promissory
Notes are attached hereto, made a part hereof and marked as Exh4. The Defendant defaulted upon the terms of the Promissory Note
judgment and late charges of $265.00.
5. Pursuant to the terms of the Promissory Notes attached heret
nt of a failure to meet scheduled repayment of any installments
shall, at the option of the Plaintiff, become immediately due a
6. Pursuant to the terms of the Promissory Notes attached hereto
the collection of any amount not
7. The Plaintiff has incurred expenses, including legal fees, as
instituted this action and will be obliged to incur similar obl
8. Defendant has breached her contract with Plaintiff by not pay
Wherefore, Plaintiff demands judgement against the Defendant in the amount of
erest to the date of judgment,
interest from the date of judgement and anticipated court costFile Number 20221185
VERIFICATION
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,
LISA CORRATO
University of the Sciences in Philadelphia
pare afi vlzzEXHIBIT AWe HEALTH PROFESSIONS STUDENT LOAN PROGRAM
A MASTER PROMISSORY NOTE
I gy nN , hereinafter, called the Borrower, promise to
ay.to University of He Sciences in Philadelphia, hereinafter called the Institution located at 600 S. 43rd Street, (and Woodland Avenue),
Philadelphia, PA 19104-4495, the sum of such amounts as may from time to time be advanced to me and endorsed in the Schedule of
Advances, below with interest at the rate of five (5) percent per annum together with all attorney's. fees, collection agent costs, and other
related costs and charges for the collection of any amount not paid when in default according to the terms of this Promissory Note.
SCHEDULE OF ADVANCES
AMOUNT ADVANCED TOTAL TO DATE SJGNATURE OF BORROWER
The Borrower and the Institution further understand and agree that:
1. Consolidation (42 CFR 57.208): If the Institution makes more than one loan, with the same repayment terms, to the Borrower
under Health Professions Student Loan program, the sum of the amounts advanced to the Borrower shall be consolidated for
purposes of repayment. Each payment made by the Borrower to the Institution shall be applied first to interest which has accrued on
the unpaid principal balance and then to the principal sum of the total loan.
2.” Repayment (Section 722 Public Health Service Act, 42 CFR 57.210):
a. Repayment shall be made in equal or graduated periodic installments over the Tepayment period, except that the Institution may
Tequire repayment to be made in an amount equal to but not less than $40 per month. The Tepayment period begins one year after
the Borrower ceases to be a full-time student at aschool eligible to participate in the Health Professions Student Loart program.
‘The repayment period shall not be less than 10 years, nor more than 25 years, at the discretion of the Institution. Periods of
authorized deferment are not included as part of the repayment period, . .
b. The terms and conditions of repayment shall be set forth in a separate repayment schedule which ‘is approved by the Institution
and agreed to by the Borrower. Payments under the repayment schedule shall be made no less often than quarterly, except that
if the Borrower is more than 60 days past due on a Payment, the remaining balance to the Loan shall be repaid on a monthly
basis.
3. Interest (Section 722 Public Health Service Act, 42 CFR $7,208): Interest shall accrue from the beginning of the repayment
period. ”
I will not sign this Note before reading it, including the provisions on the reverse side. This loan has been made to me without security
or endorsement. My signature certifies I have read, understand, and agree to the terms and conditions of this Promissory Note.
THIS IS A LOAN(S) THAT MUST BE REPAID.
Address! — 4lolZ_ Wawuk Street
Address 2 City i ja State PA zip_ 141g
Social Security Number
accept use of tis oem as my Master Promissory Note for all loans received under the Health Professions Student Loan (HPSL)
Yes
program. Borrower Initial Q No Borrower Initial
School Entrance Date 4-ZS Us Borrower Initial
School Exit Date &-/- 200 Borrower Initial
In Witness id Seal
FOZ (Seal)
SIGNATURE OF BORROWER:
OVER
feet OT xand Conditions (cont. / os
Terms ent (Section 722, f ) : Periodic installments of principal and interest need not be paid, and interest Shall not
accrue, while the Borrower: (a) serves on active duty as a member ofa uniformed service of the United States, for up to three years;
(b) Serves as a volunteer under the Peace Corps Act, for up to three years; (c) pursues advanced professional training, including
internships and residencies; (d) pursues a full-time course of study at a health profession school eligible for participation in the
Health Professions Student Loan program; (e) leaves the Institution with the intent to return to the Institution asa full-time student
to engage in a full-time educational activity which is directly related to the health profession for.which the Borrower is preparing, as
determined by the Secretary of Health and Human Services (the Secretary) for up to two years; and (f) participates in a fellowship
training program or a full-time educational activity which is directly related to the health profession for which the Borrower pre-
pared at the Institution, and is engaged in by the Borrower within 12 months after the completion of the Borrower's participation in
advanced professional training (described in 4 (c) above), or prior to the completion of the Borrower’s participation in such training
for up to two years.
5. Prepayment (Section 722 Public Health Service Act): The Borrower may, at his or her option and without penalty, prépay all or
any part of the principal and accrued interest at any time.
6. Exit Interview (42 CFR 57.210): If the Borrower agreés’to attend an exit interview prior to completing or terminating full-time
“student status at the Institution, :
7. ° Default (Section 2 €) 208): If the Borrower fails to make an installmeint payment when due or fails to comply with any
..other term of the Promissory Note, the loan will be considered if default.
8. ite Charges (Section 721 jic Heal ice Act, 42 CFR 57.210): The Institution shall assess a late penalty charge for
failure of the Borrower to pay all or any part of an installment or for failure to file satisfactory evidence of entitlement to deferment,
if so entitled, at a rate not to exceed an amount equal to 6 percent of the amount of such installment on loans more than 60 days past
due.
9. Acceleration (42 CER $7,208): If the Borrower fails to make a scheduled repayment or fails to comply with any other term of the
Promissory Note, the entire unpaid balance of the loan, including interest due and accrued and any applicable penalty charges, will,
at the option of the Institution, become immediately due and payable.
10. Credit Bureaus (42 CFR 57.210): The Institution may disclose the Borrower’s loan and any other relevant information to credit
bureaus. If the Borrower is more than 120 days past due in making a scheduled repayment, the Institution will disclose the Borrower's
delinquent status and any other relevant information.to credit bureaus.
11. Collection Agents, Litig: ation, and Withholding of Services (Section 722 Public Health Service Act, 42 CFR 57.210): If the
Borrower fails to make a scheduled repayment, or fails-t@ comply with any other terms of this Promissory Note, the Institution
may: (a) refer the Borrower's loan to a collection agent for, further collection efforts; (b) initiate legal proceedings against the
Borrower; (c) withhold Institutional services, such as transcripts and letters of recommendation from the Borrower;-(d) refer the
Borroweér’s loan to the Secretary for collection assistance, including offset of Federal salaries; and (e) obtain the Borrower's
address from the Internal Revenue Service through the Secretary, if the Institution has no current address for the Borrower.
12. Death or Disability (42 CFR 57.211); In the event of the Borrower's total and permanent disability or death, the unpaid
__ indebtedness remaining on the Note shall be canceled. Subject to.the regulations of the Secretary, the Institution may assess a
charge on the Borrower's loan to cover the cost of insuring against death or disability cancellations.
13._.General:: The Borrower will.promptly inform the Institution of any change in name or address after he or she ceases to be a full-
time student at the Institution. The terms of this Note shall be construed according to the Federal statue (42 U.S.C. 294m-294q)
and regulations (42 CFR section 57.201 et seq.)-governing the administration of the Health Professions Student Loan program,
“copies of Which shall be kept by the Institution. . “
Notice About Subsequent Loans Made Under This Master Promissory Note
This Note authorizes the Institution to disburse multiple loans during the multi-year term of this Note upon the Borrower’s request and:
upon the Institution's determination of the Borrower's loan eligibility. .
Subsequent loaris may be made under the Note for the same or subsequent periods of enrollment at this Institution. The Institution
however, may at its discretion, close this Note at any time and require the Borrower to sign a new Note for additional-disbursements.
If the Institution chooses to make subsequent loans under this Note, no such loans will be made after the earliest of the following dates:
(i) the date this Institution receives the Borrower’s written notice that no further loans may be made disbursed under this note; (ii) the
date of withdrawal from the Institution by the Borrower. :
Any amendments to the Public Health Service Act governs the terms of any loans disbursed on or after the effective date of such
amendment, and such amended terms are hereby incorporated into this Note. :
NOTICE: The Institution must require security or endorsement if the Borrower is a minor and if under the applicable State law the
Note signed by him or her would not create a binding obligation. The Institution may not require security or endorsement
in any other circumstances. The Institution shall supply a copy of this Note to the Borrower.
WARNING: Any person who knowingly makes a false statement or misrepresentation in obtaining these funds is subject to penalties
which may include fines and imprisonment under Federal statute.
NOTE: This Promissory Note is for loans made on or after November 13, 1998.“ETAIYTT) UNIVERSITY OF THE . FEDERAL PERKINS LOAN
f Sir % SCIENCES IN LOAN TYPE:
PHILADELPHIA D-FIEALTH PROFESSIONS STUDENT LOAN
Q_LOANS FOR DISADVANTAGED STUDENTS
ot
'O# TOTAL LOAN 1500 -
Gh# YEAR xe
TRUTH-IN-LENDING STATEMENT
Given to Student-Borrower When Funds are Advanced
Sovial Security Nuc [i
NAME — fin Sav
(Last) . (First) * (Middie Initial)
Loca aooress: ti S y2nd St PERMANENT ADDRESS:
streer___Wilon 414 street_4bIZ_ Wl alniusé:
city Pnila adoh 3 city Saileded pid
STATE Ve zip_\aio4 STATE zip__1 9/34
TELEPHONE NO. i TELEPHONE NO,
ANNUAL PERCENTAGE] AMOUNT FINANCED
RATE
The cost of your credit The amount of credit
as a yearly rate: provided to you or an
FIVE PERCENT your behalf
5% s_/SD0.°?
LATE CHARGE:
For each scheduled payment not made by the due date, a late charge will be imposed.
PREPAYMENT:
if you prepay all or any part of the principal of this loan, you will not be charged a penalty.
ADDITIONAL INFORMATION:
if the loan is not repaid as agreed, the total loan may become due and payable. Additionally, if the loan is not repaid as agreed, you will
be held responsible for reasonable collection costs and attorney fees in addition to any outstanding obligation due to the University.
The collection cost and attorney fees may amount to 50% of the total amount owed. Legal action could also be taken if the foan is-not
repaid as agreed.
If you are definquent on your loan repayment, this information can be disclosed to credit bureau organizations, collection agencies and/or
legal counsel. .
Refer to the promissory note for any additional information about repayment, default and any required repayment in full before the
scheduled date.
Itemization of the Amount Financed: $ LS0Q.%¢
$. ISVO. oe Amount paid to University of the Sciences in Philadelphia on your behalf.
STUDENT-BORROWER PLEASE SIGN BELOW:
J attest that | have read an understand the truth-in-lending statement, my rights and responsibil
This document is signed as a sealed instrument under the law. fr
_ [ote
Date Signatyse’of Student-Borrower
ies, and my promissory note.
(seal)
USP Copy - Pink Student's Copy - Whiteoe EP HEALTH PROFESSIONS STUDENT LOAN PROGRAM
PROMISSORY NOTE
L Pin ' Sarma: herein after called the Borrower,
promise to pay to University of the Sciences in Philadelphia, hereinafter called the Institution located at 600 S. 43rd Street
(and Woodland Avenue), Philadelphia, PA 19104-4495, the sum of such amounts as may from time to time be advanced to
me and endorsed in the Schedule of Advances below with interest at the rate of five (5) percent per annum together with all
attorney's fees, collection agent costs, and other related costs and charges for the collection of any amount not paid when in,
default according to the terms of this note.
SCHEDULE OF ADVANCES
NUMBER, AMOUNT ADVANCED | TOTAL TO DATE . DATE SIGNATURE OF BORROWER . |
1 | 750-00 750-00 | 9/25/63
2| 150-60 | 1500-00 | 1/i5/o4
3
7
Ls |
The Borrower and the Institution further understand and agree that:
1. Consolidation: If the Institution makes more than one loan with the same repayment terms to the Borrower under
Health Professions Student Loan program, the'sum of the amounts advanced to the-Borrower shall be consolidated
for purposes of repayment. Each payment made by the Borrower to the-Institution shall be applied first to interest
which has accrued on the unpaid principal balance and then to the principal sum of the total loan.
~ |x LX
2. Repayment:
a Repayment shall.be made in equal or graduated periodic installments over the repayment period, except that
: the ‘Institution may require repayment to be made in an amount,equal to but not less than $40 per month. The
repayment period begins one year after the Borrower ceases to be a full-time student at a school eligible to
participate in the Health Professions Student Loan program: The repayment period-shall not be less than
10 years, nor more than 25 years, at the discretion of the Institution. Periods of authorized deferment are not
included as part of the repayment period.
b. The terms and conditions of repayment shall be set forth in a separate repayment schedule which is approved
by the Institution and-agreed to by the Borrower. Payments under the repayment schedule shall be made
no less often than quarterly, except that if the Borrower is more than 60 days past due on a payment, the
remaining balance to the Loan shall be repaid on a monthly basis.
3. Interest: Interest shall accrue from the beginning of the repayment period.
I-will not sign this Note before reading it, including the provisions on the reverse side. This loan has been made to me
without security or endorsement. My signature certifies I have read, understand, and agree to the terms and conditions of this
Promissory Note. THIS IS A LOAN(S) THAT MUST BE REPAID.
Withié3s Heregf, my Hand and Seal
x (30 JOZ x (Seal
SIGNATURE OF THE BORROWER
OVERTerms and Conditions (cont.)
4. Deferments: Periodic installments of principal and interest need not be paid, and interest shall not accrue, while the Borrower®
(a) serves on active duty as a member of a uniformed service of the United States, for up to three years, (b).serves as a volunteer
under the Peace Corps Act, for up to three years; (c) pursues advanced professional training, including internships and
residencies; (d) pursues a full-time course of study at a health profession school eligible for participation in the Loans for
Disadvantaged Students program; (e) leaves the Institution with the intent to retum to the Institution as a full-time student. to
engage in a full-time educational activity which is directly related to the health profession for which the Borrower is preparing,
as determined by the Secretary of Health and Human Services (the Secretary) for up to two years; and (f) participates in a
fellowship training program or a full-time educational activity which is directly related to the health profession for which the
Borrower prepared at the Institution, and is engaged in by the Borrower within 12 months after the completion of the Borrower's
participation in advanced professional training described in 4 (c) above, or prior to the completion of the Borrower's participation
in such training for up to two years.
5. Prepayment: The Borrower may, at his or her option and without penalty, prepay all or any part of the principal and accrued
interest at any time. . .
6. Exit Interview: If the Borrower agrees to attend an exit interview prior to completing or terminating full-time student status at the
Institution.
7. Default: If the Borrower fails to make an installment payment when due or fails to comply with any other term of the Promissory
Note, the loan will be considered in default. . . -
8. Late Charges: The Institution shall assess a late penalty charge for failure of the Borrower to pay all or any part of an installment,
or for failure to file satisfactory evidence of entitlement to deferment, if so entitled, at a rate not to exceed an amount equal to
6 percent of the amount of such installment on loans more than 60 days past due. . tt
9. Acceleration: If the Borrower fails to make a scheduled repayment or fails to comply with any other term of;the Promissory
Note, the.entire unpaid balance of the loan, including interest due and accrued and any applicable pénalty charges, will, at the
option of the Institution, become immediately due and payable.
10. Credit Bureau: The Institution may disclose the Borrower's loan and any other relevant information to credit bureaus. If the
Borrower is more than 120 days past due in making a scheduled repayment, the Institution will disclose the Borrower's
delinquent status and any other relevant information to credit bureaus.
ul. Collection Agents, Litigation, and Withholding of Services: If the Borrower fails to make a scheduled repayment, or fails to
comply with any other term of this Promissory Note, the Institution may: (a) refer the Borrower's loan to a collection agent for
further collection efforts; (b) initiate fegal proceedings against the Borrower; (c) withhold Institutional services, such as
transcripts and letters of recommendation from the Borrower; (4) refer the Borrower's loan to the Secretary for collection
assistance, including offset of federal salaries; and (e) obtain the Borrower's address from the Internal Revenue Service through
the Secretary if the Institution has no current address for the Borrower.
12. Death or Disability: {n the event of the Borrower's total and permanent disability or death, the unpaid indebtedness remaining on
the Note shall be cangeled. Subject to the regulations of the Secretary, the Institution may assess a charge on the Borrower's loan
to cover the costs of insuring against death or disability cancellations.
13. Repayment by the Secretary:
a At the option of the Secretary, the: Borrower and the Secretary. may enter into a special contract to.have this loan
partially repaid by the Secretary for service by the Borrower for at least two years in a health manpower shortage area
as identified by the Secretary. This contract will be offered only if Federal funds are available for the purpose.
b. Subject to.the availability of funds, and upon application of the Borrower, the Secretary may repay without liability to
the Borrower all or any part of the Borrower's loan under this Note which is outstanding on the date the Secretary
determines, according to applicable Federal regulations, that the Borrower: (1) failed to complete ‘the course of study
leading to his/her first professiofial dégree for which such loan was made; (2) is in exceptionally needy circumstances;
(3) is from a low-income or disadvantaged family;.and (4) has not resumed, or cannot reasonably be expected to
resume, the study of medicine, osteopathic medicine, dentistry, veterinary medicine, optometry, pharmacy, or podiatry
within a period of two years following the date upon which the Borrower ceased to pursue the study for which the loan
was made.
14. General: The Borrower will promptly inform the Institution of any change in name or address after he or she ceases to be a
fulltime student at the Institution. The terms of this Note shall be construed according to the Federal statute (42 U.S.C.
294m-294q) and regulations (42 CFR section 57.201 et seq.) governing the administration of the Health Professioris Student
Loan program, copies of which shall be kept by the Institution.
NOTICE: The institution must require security or endorsement if the Borrower is a minor and if under the applicable State law
the Note signed by him or her would not create a binding obligation. The Institution may not require security or
endorsement in any other circumstances. The Institution shall supply a copy of this Note to the Borrower.
WARNING: Any person who knowingly makes a false statement or misrepresentation in obtaining these funds is subject to
penalties which may include fines and imprisonment under Federal statute.
NOTE: | This Promissory Note is for loans made on or after November 13, 1998.. 1m a rh UNIVERSITY OF THE LOAN TYPE: OQ FEDERAL PERKINS LOAN
tS
SCIENCES IN ,
PHILADELPHIA HEALTH PROFESSIONS STUDENT LOAN
OQ LOANS FOR DISADVANTAGED STUDENTS
8, rs On ah
TRUTH-IN-LENDING STATEMENT
Given to Student-Borrower When Funds are Advanced
social Security Nuriver
NAME Pin Sarma
(Last) (First) (Middle Initial)
LOCAL ADDRESS: PERMANENT ADDRESS:
STREET. strcet4el2 Walnut St-
city ory Daladelohiae
STATE zip state_£A on P_LIBF
TELEPHONE NO. (. ) TELEPHONE NO.
ANNUAL PERCENTAGE} AMOUNT FINANCED
RATE
The cost of your credit The amount of credit
as a yearly rate: provided to you or an
FIVE PERCENT your behalf
5% 3 1500-00
LATE CHARGE:
For each scheduled payment not made by the due date, a late charge will be imposed.
PREPAYMENT:
if you prepay all or any part of the principal of this loan, you will not be charged a penalty.
ADDITIONAL INFORMATION:
if the loan is not repaid as agreed, the total loan may become due and payable. Additionally, if the loan is not repaid as agreed, you will
be held responsible for reasonable collection costs and attorney fees in addition to any outstanding obligation due to the University.
The collection cost and attorney fees may amount to 50% of the total amount owed. Legal action could also be taken if the loan is not
repaid as agreed.
If you are delinquent on yous loan repayment, this information can be disclosed to credit bureau organizations, collection agencies and/or
legal counsel.
Refer to the promissory note for any additiona! information about repayment, default and any required repayment in full before the
scheduled date.
Itemization of the Amount Financed: $. 1500 -€0
$. [S00 > oO Amount paid to University of the Sciences in Philadelphia on your behaif.
STUDENT-BORROWER PLEASE SIGN BELOW:
| attest that | have read an understand the truth-in-lending statement, my rights and responsibilities, and my promissory note.
This document is signed as a sealed instrument under the law.
wae 9/8
FILEReal)
12-06-2022 02:23 PM
OFFICE OF JUDICIAL SUPPORT
DELAWARE COUNTY, PA
nature of Student-Borrower
USP Copy - Pink Student's Copy - White
Preview
> ZOrHeQNED ZOosmAOmD wa For Prothonotary Use Only: Docket No: 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: E] Complaint 1 Transfer from Another Jurisdiction DI writ of Summons DO Petition 1 Declaration of Taking Lead Plaintiff's Name: University of the Sciences in Philadelphia Lead Defendant’s Name: Sarma Pin Are money damages requested? El] Yes 0 No Dollar Amount Requested: (check one) Elwithin arbitration limits Doutside arbitration limits Is this a Class Action Suit? O Yes El No Is this an MDJ Appeal? 0 Yes El No Name of Plaintiff/Appellant’s Attorney: Gregory J. Allard, Esquire O Cheek here if you have no attorney (are a Self-Represented [Pro Se] Litigant) TORT (do not include Mass Tort) O Intentional 1 Malicious Prosecution 1 Motor Vehicle D1 Nuisance 1 Premises Liability D2 Product Liability (does not include mass tort) D1 Slander/Libel/ Defamation D Other: MASS TORT DD Asbestos 1 Tobacco 1 Toxic Tort - DES D1 Toxic Tort - Implant 1 Toxic Waste 5 Other: CONTRACT (do not inelude Judgments) D1 Buyer Plaintiff 1 Debt Collection: Credit Card EK] Debt Collection: Other Breach of Contract 1 Employment Dispute: Discrimination 1 Employment Dispute: Other CIVIL APPEALS Administrative Agencies LD Board of Assessment (1 Board of Elections Dept. of Transportation Statutory Appeal: Other DD Zoning Board PROFESSIONAL LIABLITY 1 Dental OD Legal OO Medical LD Other Professional: DO Other: DD Other: REAL PROPERTY MISCELLANEOUS Ejectment 1 Common Law/Statutory Arbitration 1 Eminent Domain/Condemnation 0 Ground Rent D1 Landlord/Tenant Dispute 1 Mortgage Foreclosure: Residential OO Mortgage Foreclosure: Commercial D1 Partition D Quiet Title DD Other: 1 Declaratory Judgment Mandamus Non-Domestic Relations Restraining Order Quo Warranto Oo Replevin D other: Updated 1/1/2011IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY, PENNSYLVANIA. UNIVERSITY OF THE SCIENCES : DELAWARE COUNTY IN PHILADELPHIA : COURT OF COMMON PLEAS 600 South Forty-Third Street : Kline Hall 6 Philadelphia, PA 19104-4495 v. SARMA PIN 708 Milmont Avenue Swarthmore, PA 19081-2632 claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are court your defenses or objections to the claims set forth again fail to do so the case may proceed without you and a judgment m 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 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 I IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LAWYERS REFERENCE SERVICE24 Regency Plaza (610) 358-9600 Attorney for Plaintiff UNIVERSITY OF THE SCIENCES IN PHILADELPHIA 600 South Forty-Third Street Kline Hall 6 Philadelphia, PA 19104-4495 v. SARMA PIN 708 Milmont Avenue Swarthmore, PA 19081-2632 DELAWARE COUNTY COURT OF COMMON PLEAS 1. The Plaintiff, University of t profit, organized and existing under the Laws of the Commonweal 2. The Defendant, Sarma Pin, is an individual and citizen of the Commonwealth of ont Avenue, Swarthmore, Penns 3. At the special insistence and request of the Defendant, while Promissory Notes, pursuant to whi by the Plaintiff the sum of ct copies of said Promissory Notes are attached hereto, made a part hereof and marked as Exh4. The Defendant defaulted upon the terms of the Promissory Note judgment and late charges of $265.00. 5. Pursuant to the terms of the Promissory Notes attached heret nt of a failure to meet scheduled repayment of any installments shall, at the option of the Plaintiff, become immediately due a 6. Pursuant to the terms of the Promissory Notes attached hereto the collection of any amount not 7. The Plaintiff has incurred expenses, including legal fees, as instituted this action and will be obliged to incur similar obl 8. Defendant has breached her contract with Plaintiff by not pay Wherefore, Plaintiff demands judgement against the Defendant in the amount of erest to the date of judgment, interest from the date of judgement and anticipated court costFile Number 20221185 VERIFICATION 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, LISA CORRATO University of the Sciences in Philadelphia pare afi vlzzEXHIBIT AWe HEALTH PROFESSIONS STUDENT LOAN PROGRAM A MASTER PROMISSORY NOTE I gy nN , hereinafter, called the Borrower, promise to ay.to University of He Sciences in Philadelphia, hereinafter called the Institution located at 600 S. 43rd Street, (and Woodland Avenue), Philadelphia, PA 19104-4495, the sum of such amounts as may from time to time be advanced to me and endorsed in the Schedule of Advances, below with interest at the rate of five (5) percent per annum together with all attorney's. fees, collection agent costs, and other related costs and charges for the collection of any amount not paid when in default according to the terms of this Promissory Note. SCHEDULE OF ADVANCES AMOUNT ADVANCED TOTAL TO DATE SJGNATURE OF BORROWER The Borrower and the Institution further understand and agree that: 1. Consolidation (42 CFR 57.208): If the Institution makes more than one loan, with the same repayment terms, to the Borrower under Health Professions Student Loan program, the sum of the amounts advanced to the Borrower shall be consolidated for purposes of repayment. Each payment made by the Borrower to the Institution shall be applied first to interest which has accrued on the unpaid principal balance and then to the principal sum of the total loan. 2.” Repayment (Section 722 Public Health Service Act, 42 CFR 57.210): a. Repayment shall be made in equal or graduated periodic installments over the Tepayment period, except that the Institution may Tequire repayment to be made in an amount equal to but not less than $40 per month. The Tepayment period begins one year after the Borrower ceases to be a full-time student at aschool eligible to participate in the Health Professions Student Loart program. ‘The repayment period shall not be less than 10 years, nor more than 25 years, at the discretion of the Institution. Periods of authorized deferment are not included as part of the repayment period, . . b. The terms and conditions of repayment shall be set forth in a separate repayment schedule which ‘is approved by the Institution and agreed to by the Borrower. Payments under the repayment schedule shall be made no less often than quarterly, except that if the Borrower is more than 60 days past due on a Payment, the remaining balance to the Loan shall be repaid on a monthly basis. 3. Interest (Section 722 Public Health Service Act, 42 CFR $7,208): Interest shall accrue from the beginning of the repayment period. ” I will not sign this Note before reading it, including the provisions on the reverse side. This loan has been made to me without security or endorsement. My signature certifies I have read, understand, and agree to the terms and conditions of this Promissory Note. THIS IS A LOAN(S) THAT MUST BE REPAID. Address! — 4lolZ_ Wawuk Street Address 2 City i ja State PA zip_ 141g Social Security Number accept use of tis oem as my Master Promissory Note for all loans received under the Health Professions Student Loan (HPSL) Yes program. Borrower Initial Q No Borrower Initial School Entrance Date 4-ZS Us Borrower Initial School Exit Date &-/- 200 Borrower Initial In Witness id Seal FOZ (Seal) SIGNATURE OF BORROWER: OVER feet OT xand Conditions (cont. / os Terms ent (Section 722, f ) : Periodic installments of principal and interest need not be paid, and interest Shall not accrue, while the Borrower: (a) serves on active duty as a member ofa uniformed service of the United States, for up to three years; (b) Serves as a volunteer under the Peace Corps Act, for up to three years; (c) pursues advanced professional training, including internships and residencies; (d) pursues a full-time course of study at a health profession school eligible for participation in the Health Professions Student Loan program; (e) leaves the Institution with the intent to return to the Institution asa full-time student to engage in a full-time educational activity which is directly related to the health profession for.which the Borrower is preparing, as determined by the Secretary of Health and Human Services (the Secretary) for up to two years; and (f) participates in a fellowship training program or a full-time educational activity which is directly related to the health profession for which the Borrower pre- pared at the Institution, and is engaged in by the Borrower within 12 months after the completion of the Borrower's participation in advanced professional training (described in 4 (c) above), or prior to the completion of the Borrower’s participation in such training for up to two years. 5. Prepayment (Section 722 Public Health Service Act): The Borrower may, at his or her option and without penalty, prépay all or any part of the principal and accrued interest at any time. 6. Exit Interview (42 CFR 57.210): If the Borrower agreés’to attend an exit interview prior to completing or terminating full-time “student status at the Institution, : 7. ° Default (Section 2 €) 208): If the Borrower fails to make an installmeint payment when due or fails to comply with any ..other term of the Promissory Note, the loan will be considered if default. 8. ite Charges (Section 721 jic Heal ice Act, 42 CFR 57.210): The Institution shall assess a late penalty charge for failure of the Borrower to pay all or any part of an installment or for failure to file satisfactory evidence of entitlement to deferment, if so entitled, at a rate not to exceed an amount equal to 6 percent of the amount of such installment on loans more than 60 days past due. 9. Acceleration (42 CER $7,208): If the Borrower fails to make a scheduled repayment or fails to comply with any other term of the Promissory Note, the entire unpaid balance of the loan, including interest due and accrued and any applicable penalty charges, will, at the option of the Institution, become immediately due and payable. 10. Credit Bureaus (42 CFR 57.210): The Institution may disclose the Borrower’s loan and any other relevant information to credit bureaus. If the Borrower is more than 120 days past due in making a scheduled repayment, the Institution will disclose the Borrower's delinquent status and any other relevant information.to credit bureaus. 11. Collection Agents, Litig: ation, and Withholding of Services (Section 722 Public Health Service Act, 42 CFR 57.210): If the Borrower fails to make a scheduled repayment, or fails-t@ comply with any other terms of this Promissory Note, the Institution may: (a) refer the Borrower's loan to a collection agent for, further collection efforts; (b) initiate legal proceedings against the Borrower; (c) withhold Institutional services, such as transcripts and letters of recommendation from the Borrower;-(d) refer the Borroweér’s loan to the Secretary for collection assistance, including offset of Federal salaries; and (e) obtain the Borrower's address from the Internal Revenue Service through the Secretary, if the Institution has no current address for the Borrower. 12. Death or Disability (42 CFR 57.211); In the event of the Borrower's total and permanent disability or death, the unpaid __ indebtedness remaining on the Note shall be canceled. Subject to.the regulations of the Secretary, the Institution may assess a charge on the Borrower's loan to cover the cost of insuring against death or disability cancellations. 13._.General:: The Borrower will.promptly inform the Institution of any change in name or address after he or she ceases to be a full- time student at the Institution. The terms of this Note shall be construed according to the Federal statue (42 U.S.C. 294m-294q) and regulations (42 CFR section 57.201 et seq.)-governing the administration of the Health Professions Student Loan program, “copies of Which shall be kept by the Institution. . “ Notice About Subsequent Loans Made Under This Master Promissory Note This Note authorizes the Institution to disburse multiple loans during the multi-year term of this Note upon the Borrower’s request and: upon the Institution's determination of the Borrower's loan eligibility. . Subsequent loaris may be made under the Note for the same or subsequent periods of enrollment at this Institution. The Institution however, may at its discretion, close this Note at any time and require the Borrower to sign a new Note for additional-disbursements. If the Institution chooses to make subsequent loans under this Note, no such loans will be made after the earliest of the following dates: (i) the date this Institution receives the Borrower’s written notice that no further loans may be made disbursed under this note; (ii) the date of withdrawal from the Institution by the Borrower. : Any amendments to the Public Health Service Act governs the terms of any loans disbursed on or after the effective date of such amendment, and such amended terms are hereby incorporated into this Note. : NOTICE: The Institution must require security or endorsement if the Borrower is a minor and if under the applicable State law the Note signed by him or her would not create a binding obligation. The Institution may not require security or endorsement in any other circumstances. The Institution shall supply a copy of this Note to the Borrower. WARNING: Any person who knowingly makes a false statement or misrepresentation in obtaining these funds is subject to penalties which may include fines and imprisonment under Federal statute. NOTE: This Promissory Note is for loans made on or after November 13, 1998.“ETAIYTT) UNIVERSITY OF THE . FEDERAL PERKINS LOAN f Sir % SCIENCES IN LOAN TYPE: PHILADELPHIA D-FIEALTH PROFESSIONS STUDENT LOAN Q_LOANS FOR DISADVANTAGED STUDENTS ot 'O# TOTAL LOAN 1500 - Gh# YEAR xe TRUTH-IN-LENDING STATEMENT Given to Student-Borrower When Funds are Advanced Sovial Security Nuc [i NAME — fin Sav (Last) . (First) * (Middie Initial) Loca aooress: ti S y2nd St PERMANENT ADDRESS: streer___Wilon 414 street_4bIZ_ Wl alniusé: city Pnila adoh 3 city Saileded pid STATE Ve zip_\aio4 STATE zip__1 9/34 TELEPHONE NO. i TELEPHONE NO, ANNUAL PERCENTAGE] AMOUNT FINANCED RATE The cost of your credit The amount of credit as a yearly rate: provided to you or an FIVE PERCENT your behalf 5% s_/SD0.°? LATE CHARGE: For each scheduled payment not made by the due date, a late charge will be imposed. PREPAYMENT: if you prepay all or any part of the principal of this loan, you will not be charged a penalty. ADDITIONAL INFORMATION: if the loan is not repaid as agreed, the total loan may become due and payable. Additionally, if the loan is not repaid as agreed, you will be held responsible for reasonable collection costs and attorney fees in addition to any outstanding obligation due to the University. The collection cost and attorney fees may amount to 50% of the total amount owed. Legal action could also be taken if the foan is-not repaid as agreed. If you are definquent on your loan repayment, this information can be disclosed to credit bureau organizations, collection agencies and/or legal counsel. . Refer to the promissory note for any additional information about repayment, default and any required repayment in full before the scheduled date. Itemization of the Amount Financed: $ LS0Q.%¢ $. ISVO. oe Amount paid to University of the Sciences in Philadelphia on your behalf. STUDENT-BORROWER PLEASE SIGN BELOW: J attest that | have read an understand the truth-in-lending statement, my rights and responsibil This document is signed as a sealed instrument under the law. fr _ [ote Date Signatyse’of Student-Borrower ies, and my promissory note. (seal) USP Copy - Pink Student's Copy - Whiteoe EP HEALTH PROFESSIONS STUDENT LOAN PROGRAM PROMISSORY NOTE L Pin ' Sarma: herein after called the Borrower, promise to pay to University of the Sciences in Philadelphia, hereinafter called the Institution located at 600 S. 43rd Street (and Woodland Avenue), Philadelphia, PA 19104-4495, the sum of such amounts as may from time to time be advanced to me and endorsed in the Schedule of Advances below with interest at the rate of five (5) percent per annum together with all attorney's fees, collection agent costs, and other related costs and charges for the collection of any amount not paid when in, default according to the terms of this note. SCHEDULE OF ADVANCES NUMBER, AMOUNT ADVANCED | TOTAL TO DATE . DATE SIGNATURE OF BORROWER . | 1 | 750-00 750-00 | 9/25/63 2| 150-60 | 1500-00 | 1/i5/o4 3 7 Ls | The Borrower and the Institution further understand and agree that: 1. Consolidation: If the Institution makes more than one loan with the same repayment terms to the Borrower under Health Professions Student Loan program, the'sum of the amounts advanced to the-Borrower shall be consolidated for purposes of repayment. Each payment made by the Borrower to the-Institution shall be applied first to interest which has accrued on the unpaid principal balance and then to the principal sum of the total loan. ~ |x LX 2. Repayment: a Repayment shall.be made in equal or graduated periodic installments over the repayment period, except that : the ‘Institution may require repayment to be made in an amount,equal to but not less than $40 per month. The repayment period begins one year after the Borrower ceases to be a full-time student at a school eligible to participate in the Health Professions Student Loan program: The repayment period-shall not be less than 10 years, nor more than 25 years, at the discretion of the Institution. Periods of authorized deferment are not included as part of the repayment period. b. The terms and conditions of repayment shall be set forth in a separate repayment schedule which is approved by the Institution and-agreed to by the Borrower. Payments under the repayment schedule shall be made no less often than quarterly, except that if the Borrower is more than 60 days past due on a payment, the remaining balance to the Loan shall be repaid on a monthly basis. 3. Interest: Interest shall accrue from the beginning of the repayment period. I-will not sign this Note before reading it, including the provisions on the reverse side. This loan has been made to me without security or endorsement. My signature certifies I have read, understand, and agree to the terms and conditions of this Promissory Note. THIS IS A LOAN(S) THAT MUST BE REPAID. Withié3s Heregf, my Hand and Seal x (30 JOZ x (Seal SIGNATURE OF THE BORROWER OVERTerms and Conditions (cont.) 4. Deferments: Periodic installments of principal and interest need not be paid, and interest shall not accrue, while the Borrower® (a) serves on active duty as a member of a uniformed service of the United States, for up to three years, (b).serves as a volunteer under the Peace Corps Act, for up to three years; (c) pursues advanced professional training, including internships and residencies; (d) pursues a full-time course of study at a health profession school eligible for participation in the Loans for Disadvantaged Students program; (e) leaves the Institution with the intent to retum to the Institution as a full-time student. to engage in a full-time educational activity which is directly related to the health profession for which the Borrower is preparing, as determined by the Secretary of Health and Human Services (the Secretary) for up to two years; and (f) participates in a fellowship training program or a full-time educational activity which is directly related to the health profession for which the Borrower prepared at the Institution, and is engaged in by the Borrower within 12 months after the completion of the Borrower's participation in advanced professional training described in 4 (c) above, or prior to the completion of the Borrower's participation in such training for up to two years. 5. Prepayment: The Borrower may, at his or her option and without penalty, prepay all or any part of the principal and accrued interest at any time. . . 6. Exit Interview: If the Borrower agrees to attend an exit interview prior to completing or terminating full-time student status at the Institution. 7. Default: If the Borrower fails to make an installment payment when due or fails to comply with any other term of the Promissory Note, the loan will be considered in default. . . - 8. Late Charges: The Institution shall assess a late penalty charge for failure of the Borrower to pay all or any part of an installment, or for failure to file satisfactory evidence of entitlement to deferment, if so entitled, at a rate not to exceed an amount equal to 6 percent of the amount of such installment on loans more than 60 days past due. . tt 9. Acceleration: If the Borrower fails to make a scheduled repayment or fails to comply with any other term of;the Promissory Note, the.entire unpaid balance of the loan, including interest due and accrued and any applicable pénalty charges, will, at the option of the Institution, become immediately due and payable. 10. Credit Bureau: The Institution may disclose the Borrower's loan and any other relevant information to credit bureaus. If the Borrower is more than 120 days past due in making a scheduled repayment, the Institution will disclose the Borrower's delinquent status and any other relevant information to credit bureaus. ul. Collection Agents, Litigation, and Withholding of Services: If the Borrower fails to make a scheduled repayment, or fails to comply with any other term of this Promissory Note, the Institution may: (a) refer the Borrower's loan to a collection agent for further collection efforts; (b) initiate fegal proceedings against the Borrower; (c) withhold Institutional services, such as transcripts and letters of recommendation from the Borrower; (4) refer the Borrower's loan to the Secretary for collection assistance, including offset of federal salaries; and (e) obtain the Borrower's address from the Internal Revenue Service through the Secretary if the Institution has no current address for the Borrower. 12. Death or Disability: {n the event of the Borrower's total and permanent disability or death, the unpaid indebtedness remaining on the Note shall be cangeled. Subject to the regulations of the Secretary, the Institution may assess a charge on the Borrower's loan to cover the costs of insuring against death or disability cancellations. 13. Repayment by the Secretary: a At the option of the Secretary, the: Borrower and the Secretary. may enter into a special contract to.have this loan partially repaid by the Secretary for service by the Borrower for at least two years in a health manpower shortage area as identified by the Secretary. This contract will be offered only if Federal funds are available for the purpose. b. Subject to.the availability of funds, and upon application of the Borrower, the Secretary may repay without liability to the Borrower all or any part of the Borrower's loan under this Note which is outstanding on the date the Secretary determines, according to applicable Federal regulations, that the Borrower: (1) failed to complete ‘the course of study leading to his/her first professiofial dégree for which such loan was made; (2) is in exceptionally needy circumstances; (3) is from a low-income or disadvantaged family;.and (4) has not resumed, or cannot reasonably be expected to resume, the study of medicine, osteopathic medicine, dentistry, veterinary medicine, optometry, pharmacy, or podiatry within a period of two years following the date upon which the Borrower ceased to pursue the study for which the loan was made. 14. General: The Borrower will promptly inform the Institution of any change in name or address after he or she ceases to be a fulltime student at the Institution. The terms of this Note shall be construed according to the Federal statute (42 U.S.C. 294m-294q) and regulations (42 CFR section 57.201 et seq.) governing the administration of the Health Professioris Student Loan program, copies of which shall be kept by the Institution. NOTICE: The institution must require security or endorsement if the Borrower is a minor and if under the applicable State law the Note signed by him or her would not create a binding obligation. The Institution may not require security or endorsement in any other circumstances. The Institution shall supply a copy of this Note to the Borrower. WARNING: Any person who knowingly makes a false statement or misrepresentation in obtaining these funds is subject to penalties which may include fines and imprisonment under Federal statute. NOTE: | This Promissory Note is for loans made on or after November 13, 1998.. 1m a rh UNIVERSITY OF THE LOAN TYPE: OQ FEDERAL PERKINS LOAN tS SCIENCES IN , PHILADELPHIA HEALTH PROFESSIONS STUDENT LOAN OQ LOANS FOR DISADVANTAGED STUDENTS 8, rs On ah TRUTH-IN-LENDING STATEMENT Given to Student-Borrower When Funds are Advanced social Security Nuriver NAME Pin Sarma (Last) (First) (Middle Initial) LOCAL ADDRESS: PERMANENT ADDRESS: STREET. strcet4el2 Walnut St- city ory Daladelohiae STATE zip state_£A on P_LIBF TELEPHONE NO. (. ) TELEPHONE NO. ANNUAL PERCENTAGE} AMOUNT FINANCED RATE The cost of your credit The amount of credit as a yearly rate: provided to you or an FIVE PERCENT your behalf 5% 3 1500-00 LATE CHARGE: For each scheduled payment not made by the due date, a late charge will be imposed. PREPAYMENT: if you prepay all or any part of the principal of this loan, you will not be charged a penalty. ADDITIONAL INFORMATION: if the loan is not repaid as agreed, the total loan may become due and payable. Additionally, if the loan is not repaid as agreed, you will be held responsible for reasonable collection costs and attorney fees in addition to any outstanding obligation due to the University. The collection cost and attorney fees may amount to 50% of the total amount owed. Legal action could also be taken if the loan is not repaid as agreed. If you are delinquent on yous loan repayment, this information can be disclosed to credit bureau organizations, collection agencies and/or legal counsel. Refer to the promissory note for any additiona! information about repayment, default and any required repayment in full before the scheduled date. Itemization of the Amount Financed: $. 1500 -€0 $. [S00 > oO Amount paid to University of the Sciences in Philadelphia on your behaif. STUDENT-BORROWER PLEASE SIGN BELOW: | attest that | have read an understand the truth-in-lending statement, my rights and responsibilities, and my promissory note. This document is signed as a sealed instrument under the law. wae 9/8 FILEReal) 12-06-2022 02:23 PM OFFICE OF JUDICIAL SUPPORT DELAWARE COUNTY, PA nature of Student-Borrower USP Copy - Pink Student's Copy - White