mead v sallie mae pennsylvania plus loans

8/13/2019 Mead v Sallie Mae Pennsylvania PLUS Loans

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Case 5:13-cv-03964-CDJ Document 1-5 Filed 07/09/13 Page 1 of 27

EXHIBIT A


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COURT OF COMMON PLEAS OF LEHIGH COUNTYCIVIL DIVISION - LAW

Ray B. Mead, ~ \ \0 -laintiff ::cR ~No. G ;A ;a~ 7. a 9oc.C -oSallie Mae, Inc., zC.:Defendant ?_c;; ..)-

r : J / ) N\

NOTICE

You have been sued in court. If you wish to defend against the claims set forth in thefollowing pages, you must take action within twenty (20) days after this Notice and Complaint areserved, by entering a written appearance personally or by attorney and filing in writing with thecourt your defenses or object ions to the claims set forth against you. You are warned that if youfail to do so the case may proceed without you and a judgment may be entered against you by thecourt without further notice for any money claims in the Complaint or for any other claim or reliefrequested by the Plaintiff. You may lose money or property or other rights important to you.

YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DONOT 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 TOPROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGALSERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE:

Date

Lawyer Referral ServiceLehigh County Bar Association

1114 West Walnut StreetAllentown, PA 18102-4734Telephone: 6 1 0 4 3 3 7 0 ~ 4 / /

LV=V =\Douglas Jon Tkacik18 E. Market StreetP.O. Box 30Bethlehem, PA 18018

\\1\\\J

WE HEREBY CERTIFY THATTHE WITHINISA TRUEANDC RRECTCOPYOFTHEORIGINALFILE ISACTION Telephone: 610-882-3006 . 7_ . ( ?Supreme Ct. ID ~ 7 . . J . . 3 ~ ~ L L . 1 _ _ . . . . . . . . . L ~THE WITHIN COMPLAINTIS REINSTATE

I. I


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til; \Supre1.ne Court of Pennsylvania

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Court of Con1mon PleasCivil Cover Sheet::..e.::::h:.:..:i::..cg;t:.;h:.....- County

For Protlumotary Use Only:Docket No:

;/ol:3 C- ~ ~ v...._

~ : : i i ; . t f : ~ . -.: ,_o//t./f,'fi1 i'li' .:h.'.\.J(.:rJ;i ' . 1 ; : , , , . ; , 1 . : ; r t i. 1 :; . : r . i , i : / , ' i . ; '. I . . I I . . . .,,_.,u..::J ...,.,. r(/' ur( l f r e _ . r . t n _ . ~ JJ _ _\t :-,:::,.- ,;.,.- .:/ ::.' ,/},'_/ \ . t;,-; ,r . } I , I , / : ; -.. ', I I ' ':' I I i i f: :: : / i j ; i . ~ ...,.:(1 ( . . . : i .

Commencement of Action: ~ ~ ? ~ - I _ . .XX Complaint D Writ of Summons D Petition D N o f i c e = f ~ A p p e a l0 Trunsl'er from Another Jurisdiction D Declaration ofTaking 0. :; os;...- $- \_ . -1 .Lead Plaintiffs Name: Lead DeFendant's N


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...

COURT OF COMMON PLEAS OF LEHIGH COUNTYCIVIL DIVISION - LAW

Ray B Mead, Plaintiffv

Sallie Mae, Inc.,Defendant

No.

COMPLAINT FOR DECLARATORY JUDGMENT

COMES NOW, Plaintiff, Ray B. Mead, by and through his attorney, Douglas Jon Tkacik,and files this Complaint for Declaratory Judgment and in support thereof avers as follows:

1 Ray B. Mead is an adult individual who resides at 6308 Chestnut Hill RoadCoopersburg, Lehigh County, Pennsylvania 18036-1893.

2. Defendant, Sallie Mae, Inc. is a foreign corporation registered in Pennsylvania witha registered agent at CT Corporation, 116 Pine Street, Suite 320, Harrisburg, PA 17101.

3. This is an action for declaratory judgment pursuant to 42 Pa.C.S. 7531 et seq.,for the purpose of determining a question of actual controversy between the parties as hereinaftermore fully appears.

4. Upon reviewing his credit report, Plaintiff, Ray B. Mead learned that Sallie Maehad identified him as a Borrower with regard to several PLUS student loans with the accountnUinber 96913 86463.

5. t is believed and therefore averred that a PLUS loan is a Joan for highereducation that is taken by the parent for the benefit of the child.


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6. On July 18, 2012, the Plaintiff requested the Defendant to provide him with copiesof all documents and correspondence related to the account including but not limited to the LoanApplication, the Promissory Note and the loan terms.

7. The Application and Promissory Note received by the Plaint iff do not contain thePlaintiffs signature.

8. Mr. Mead has not executed a PLUS loan for the benefit of his son or daughter.9. Mr. Mead is not obligated to pay any PLUS loan.WHEREFORE, Plaintiff, Ray B. Mead, respectfully requests this Honorable Court to:

Enter judgment declaring that Ray B. ~ a d is not a party to the student loans being serviced bySallie Mae, Inc.; Order that Sallie Iv1ae Inc. is to cease all efforts to collect the debt fromPlaintiff; and direct Sallie Mae, Inc. to notify the credit reporting agencies to remove anyreference to Sallie Mae loan accounts fron1 Ray B. Mead's credit report within ten (10) days.

Date: 4 ;o 13

2

Respectfu ly Submitted,

Douglas Jon Tkaci.k18 East Market StreetPost Office Box 30Bethlehe1n, P 18016-0030Telephone: 610-882-3006Supreme Court ID #62573


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~ ~...._ -....

VERIFICATIONI Ray B Mead verify that the statements made in thjs Complaint for Declaratory

Judgment are true and correc t. I unders tand that false statements herein are made subject to thepenalties of 18 Pa.C.S.A. 4904 relating to unsworn falsification to authorities.

Date: 4 8 13 y . .ead

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T orporationTO Nicolas JafariehSallie Mae, Inc.

2 1 Edmund Halley DriveReston, VA 20191

Service of ProcessTransmittal05/20/2013CT Log Number 522762046

RE Process Served in PennsylvaniaFOR Sallie Mae, Inc. (Domestic State: DE

ENCLOSED ARE COPIES OF LEGAL PROCESS RECElVED BY THE STATUTORY AGENT OF THE ABOVE COMPANY AS FOLLOWS:TITLE OF ACTION:

DOCUMENT(S) SERVED:COURT/AGENCY:

NATURE OF ACTION:ON WHOM PROCESS WAS SERVED:DATE AND HOUR OF SERVICE:JURISDICTION SERVED :APPEARANCE OR ANSWER DUE:ATTORNEY( ) SENDER(S):

ACTION ITEMS:

SIGNED:PER:ADDRESS:

TELEPHONE:

Ray B Mead vs. Sallie Mae IncName discrepancy notedNoticeCourt Administ ration - Civil Operations Section, PCase 2013C1264Notice of Status Telephone ConferenceCT Corporation System, Harrisburg, PBy Regular Mail on 05/20/2013 postmarked on 05/14/2013PennsylvaniaJuly 2, 2013 at precisely 4:30p.m.Office of the Court Administrator455 West Hamilton StreetAllentown, PA 181101(610) 782-3657SOP Papers with Transmittal, via Fed Ex 2 Day 799818985263Email Notification, Anne Milem anne.milemsalliemae.comEmail Notification, Nicolas Jafarieh nicolas. afariehsalliemae .comCT Corporation SystemSabra Dudding116 Pine Street3rd Floor, Suite 320Harrisburg, PA 17101717-234-6004

Page 1 of 2 I JGInformation displayed on this transmittal is for CT Corporation srecord keeping purposes only and is provided to the recipient forquick reference. This information does not constitute a legalopinion as to the nature of action, the amount of damages, theanswer date or any information contained in the documentsthemselves. Recipient is responsible for interpreting saiddocuments and for taking appropriate action. Signatures oncertified mail receipts confirm receipt oi package only, notcontents.


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T orporation

TO:

RE:FOR:

Nicolas JafariehSatlie Mae, Inc.2001 Edmund Halley DriveReston, VA 20191Process Served in PennsylvaniaSallie Mae, Inc. Domestic State: DE

DOCKET HISTORY:OOCUMENT S) SERVED:Notice

DATE AND HOUR OF SERVICE:y Regular Mail on 04/22/2013

postmarked on 04/17/2013

Service of ProcessTransmittal05 20 2013CT Log NumbC>r 522762046

TO:Nicolas JafariehSallie Mae, Inc.

Page 2 of 2 JG

CT LOG NUMBER:522566874

Information displayed on this transmittal is for CT Corporation srecord keeping pur poses only and is provided to the recipient forquick reference. This information does not constitute a legalopinion as to the nature of action, the amount of damages, theanswer date or any information contained in the documentsthemselves. Recipient is responsible for interpreting saiddocuments and for taking appropriate action. Signatures oncertified mail receipts confirm receipt of package only, notcontents.


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Ray B MeadvsSallie Mae Inc

COURT ADMINISTRATIONCIV1L OPERATIONS SECTION455 WEST HAMILTON STREETALLENTOWN, P 18101-1614

610) 782-3657 FAX NUMBER (610) 871-2779

May 13, 2013

File No 2013-C-1264

NOTICE OF ST TUS TELEPHONE CONFERENCEPlease be advised that a st tus telephone conference is scheduled forJuly 02, 2013 at precisely 4:30PM.Counsel for plaintiff shall initiate the call a few minutes in advance of thescheduled time, and once all counsel of record are on the line, shall call the

Chambers ofThe Honorable Michele A Varricchio at 610} 782-3026. Onlyattorneys of record, as well as any substitutes for counsel of record, shallparticipate by phone. All pro se parties and attorneys not of record sh ll

t tend the status conference in person at the Old Lehigh County Courthouse 1Courtroom lB, 501 West Hamilton Street, Allentown, Pennsylvania. Notifycounsel for plaintiff and judge s chambers of any substitutions at least 24hours prior to the conference.

A status conference memorandum must be submitted to CourtAdministration five days prior to the conference date. The following informationshall be included in the memorandum, which should not exceed two pages:

1. A statement of facts;2. Legal basis for the cause of action;3. The demand; and4. Estimated length of Jury Trial if Jury Trial demanded).

Continuances are granted only in extraordinary circumstances.Requests for a continuance must be submitted on an official continuance format least ten days before the conference is to be held.

If you have any questions regarding your scheduling, please contact theCivil Operations Office at 610) 782-3657.

Civil Operations Office

\ - .-


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OFFICE OFTHE OURT ADMINISTRATOR

LEHIGH OUNTY COURTHOUSE455 WEST HAMILTON STREETALLENTOWN PENNSYLVANIA 18101 1614

I

\allie Mae Inc

CT CorporationSuite 320116 Pine StHarrisburg PA 17101

-. OROPSH PMEf::JS- 6 - J ? ' $ ~ . 'Ai t i i i . . i i 'U ' ' o f ?A r ' j -. . . . . r . AC . CI:l l o l L ~ ~ ~ ~ ' ; ~ ~ ; . ; ~ ; ~V)t- ...,._.~ .f U

121 OQF SSS 17101 I Iu I t ' ,I . I IJJlI


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T CorporationTO Nicolas JafariehSallie Mae, Inc.2001 Edmund Halley DriveReston, VA 20191

Service of ProcessTransmittal06 07 2013CT Log Number 522878495

RE Process Served in PennsylvaniaFOR Sallie Mae, Jnc. (Domestic State: DE)

ENCLOSED ARE COPIES OF LEGAL PROCESS RECEIVED BY THE STATUTORY AGENT OF THE ABOVE COMPANY AS FOLLOWS:TITLE OF ACTION:DOCUMENT S) SERVED:COURT/AGENCY:

NATURE OF ACTION:

ON WHOM PROCESS WAS SERVED:DATE AND HOUR OF SERVICE:JURISDICTION SERVED :APPEARANCE OR ANSWER DUE:

ATTORNEY S) SENDER S):

ACTION ITEMS:

SIGNED:PERADDRESS:

TELEPHONE:

Ray B Mead, Pl tf. vs. Sallie Mae, Inc., DftLetter, ApplicationLehigh County - Court of Common Pleas, PCase 2013C1264Defendant has not been served - Continuance is being requested to allow additionaltime for serviceCT Corporation System, Harrisburg, PABy Regular Mail on 0610712013 postmarked on 0610312013PennsylvaniaJuly 2, 2013 at 4:30 p.m. - Status Conference 81512013 at 4:00 p.m. - Case isContinuedAndrea E. Naugle, ClerkOffice of the Court Administrator455 West Hamilton StreetAllentown, PA 18110161 0) 782-3657SOP Papers with Transmittal, via Fed Ex 2 Day , 799958322291Email Noti ficati on, Anne Milem [email protected] Notification, Nicolas Jafarieh [email protected] Corporation SystemSabra Dudding116 Pine Street3rd Floor, Suite 320Harrisburg, PA 17101717-234-6004

Page 1 of 2 DBInformation displayed on this transmittal is for T Corporation srecord keeping purposes only and is provided to the recipient forquick reference. This information does nol constitute a legalopinion as to the nature of action, the amount of damages, theanswer date or any information contained in the documentsthemselves. Recipient is responsible for interpreting saiddocuments and for taking appropriate action. Signatures oncertified mail receipts confirm receipt of package only, notcontents.


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T orporation

TO: Nicolas JafariehSallie Mae, Inc.2001 Edmund Halley DriveReston, VA 20191RE: Process Served in PennsylvaniaFOR: Sallie Mae, Inc. Domestic State: DE

DOCKET HISTORY:DOCUMENT S) SERVED:NoticeNotice

DATE AND HOUR OF SERVICE:By Regular Mail on 05/20/2013postmarked on 05/14/2013By Regular Mail on 04/22/2013postmarked on 04/17/2013


TO:Nicolas JafariehSallie Mae, Inc.Nicolas JafariehSallie Mae, Inc.

Page 2 of Z DB

CT LOG NUMBER:522762046522566874

Information displayed on this transmittal is for T Corporation srecord keeping purposes only and is provided to the recipient forquick reference. This information does not constitute a legalopinion as to the nature of action, the amount of damages, theanswer date or any information contained in the documentsthemselves. Recipient is responsible for interpreting saiddocuments and for taking appropriate action. Signatures oncertified mail recei pts confirm receipt of package only, notcontents.


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IN THE COURT OF COMMON PLEAS OF LEHIGH COUNTY PENNSYLVANIACIVIL COURT DIVISION

Sallie Mae IncCT CorporationSuite 320116 Pine StHarrisburg PA 17101

File No.: 2013-C-1264

Ray B Mead-

Sallie Mae Inc

Copies of this Order were n1.ailed to all counsel of record and prose litigants.

Rule 236 NOTICEPursuant to Pa.R.C.P. 236 notice is hereby given that an order decree or

judgment in the above captioned matter has been entered.

Andrea E. NaugleClerk of Judicial Records

-_


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IN THE COURT OF COMMO N PLEAS OF LEH GH COUNTY: PENNSVLVANfACIVIL APPLICATION FOR CONTINUANCE

INSTRUCTIONS:I. Print legibly and complete Sections I through IV.2 Submit completed Application to the assigned Judge, except:

In Arbitration cases, obtain a date certain from Cowt Administration whichparties agree on and submit completed Application to Court Administration.I. APPLICATION TO CONTINUE THE FOLLOWING CASE S):

Ray B. Mead,Plain t i f f

vs.Sal l ie Mae, Inc .

Defendant

CASE SCHEDULED ON: DATETYPE OF PROCEEDING: CHECK BELOW)

File No.: 2.013-C-1264

July 2, 2013@4:30 p.m. J ~ G E

FOR OFFICE USE ONLY

Michele A Varricchio

D ARBTTRATTON 0 PRE-TRIAL CONFERENCED ARGUMENT 0 SETTLEMENT CONFERENCEJ ] STATUS CONFERENCE 0 TRTALD LICENSE APPEALD CERT OF TITLED NAME CHANGE

0 STRUCTURED STLMNT. D MISC HEARINGD OTHERIl. NUMBER OF PREVIOUS CONTINUANCES: BY PLAINTIFF 0 BY DEFENDANT 0Ill. APPLICATION IS MADE FOR THE FOLLOWING REASON S):

Defendant has not beenfor service.Continuance is being requested to allow addit ional t ime

Telephone:APPLYING PAKPr :PRrNT AND SlGN610) 882,-3006. Fax No.

Plain t i f fREPRESENTING

610) 882-3766IV. APPLICATION IS OPPOSED/UNOPPOSED FOR THE FOLLOWING REASON S):

OPPOSING PARTY: PRINT ANO SIGN DATE REPRESENTING. Telephone: Fax No.

FOR COURT USE ONLYV. ORDER: AND NOW, this, 5 31 20 3~ ~ ~

Q APPLICATION IS GRANTED AND THE CASE IS CONTINUEDD GE1\TERALL yD NEXT AVAILABLE LIST)?[ TO I s- I I 3 ( ) if: cDp \_DATE/TIME

~ 1 /;P I '~ ~ ; l n ~ . p Wh t..COURTROOM

Rev pdf 11/12/12

.

0 APPLICATION IS REFUSEDD NO FURTHER CONTINUANCES

JUDGE


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Q T Corporation

TO: Nicolas JafariehSallie Mae, Inc.2001 Edmund Halley DriveReston, VA 20191

RE Process Served in PennsylvaniaFOR: Sallie Mae, Inc. Domestic State: DE

DOCKET HISTORY:DOCUMENT S) SERVED:Letter, ApplicationNoticeNotice

DATE AND HOUR OF SERVICE:By Regular Mail on 06/07/2013postmarked on 06/03/2013By Regular Mail on 05/20/2013postmarked on 05/14/2013By Regular Mail on 04/22/2013postmarked on 04/17/2013


TONicolas JafariehSallie Mae, Inc.Nicolas JafariehSallie Mae, Inc.Nicolas JafariehSallie Mae, Inc.

Page 2 of 2 FA

CT LOG NUMBER:522878495522762046522566874

Information displayed on this transmittal is for T Corporation srecord keeping purposes only and is provided to the recipient forquick reference. This information doe s not constitute a legalopinion as to the nature of action, the amount of damages, theanswer date or any information contained in the documentsthemselves. Recipient is responsible for interpreting saiddocuments and for taking appropriate action. Signatures oncertified mail receipts confirm receipt of package only notcontents.


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Ray B Meadvs

Sallie Mae Inc

COURT ADMINISTRATIONCIVIL OPERATIONS SECTION

455 WEST HAMILTON STREETALLENTOWN, PA 18101-1614610) 782-3657 FAX NUMBER 610) 871-2779

June 07, 2013

FileNo. 2013-C-1264

NOTI E OF ST TUS TELEPHONE ONFEREN EPlease be advised that a status telephone conference is scheduled for August

05, 2013 at precisely 4:00PM.

Counsel for plaintiff shall initiate the call a few minutes in advance of thescheduled time, and once all counsel of record are on the line, shall call the Chambersof The Honorable Michele A Varricchio at 610) 782-3026. Only attorneys of record,as well as any substitutes for counsel of record, shall participate by phone. All proseparties and attorneys not of record sh ll ttend the status conference in person atthe Old Lehigh County Courthouse, Courtroom lB, 501 West Hamilton Street,Allentown, Pennsylvania. Notify counsel for plaintiff and judge s chambers of anysubstitutions at least 24 hours prior to the conference.

A status conference memorandum must be submitted to Court Administrationfive days prior to the conference date. The following information shall be included inthe memorandum, which should not exceed two pages:

1 A statement of facts;2. Legal basis for the cause of action;3. The demand; and4. Estimated length of Jury Trial if Jury Trial demanded).

Continuances are granted only in extraordinary circumstances. Requests for acontinuance must be submitted on an official continuance form at least ten daysbefore the conference is to be held.

f you have any questions regarding your scheduling, please contact the CivilOperations Office at 610) 782-3657.

Civil Operations Office


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OFFICE OF THE COURT ADMINISTRATORLEHIGH COUNTY COURTHOUSE

455 WEST HAMILTON STREETALLENTOWN, PENNSYLVANIA 18101-1614

1 Sallie Mae IncCT CorporationSuite 320116 Pine StHarrisburg PA 17101

DROPSHIPMENT . oYlAUTHORiZATION 2E-145 ~ ~MAILED AT READING PA go(1)'1-w


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CT CorporationTO Nicolas JafariehSallie Mae, Inc.2001 Edmund Halley DriveReston, VA 20191


RE Process Served in PennsylvaniaFOR Sallie Mae, Inc. Domestic State: DE

ENCLOSED ARE COPIES OF LEGAL PROCESS RECEIVED BY THE STATUTORY AGENT OF THE ABOVE COMPANY AS FOLLOWS:TITLE OF ACTION:

D O C U M E N T ~ S E R V E ~COURT/AGENCY:

NATURE OF ACTION:ON WHOM PROCESS WAS SERVED:DATE AND HOUR OF SERVICE:JURISDICTION SERVED :APPEARANCE OR ANSWER DUE:ATTORNEY S) SENDER S):

REMARKS:ACTION ITEMS:

SIGNED:PERADDRESS:

TELEPHONE:

Ray B. Mead, Pltf vs. Sallie Mae, Inc., Oft.Praecipe, Cover Sheet, Notice sL Complaint, VerificationLehigh County - Court of Common Pleas, PACase 2013C1264Praecipe to reinstate complaintCT Corporation System, Harrisburg, PBy Process Server on 06/18/2013 at 08:45PennsylvaniaWithin 20 days after serviceDouglas Jon Tkacik18 East MarketPost Office Box 30Bethlehem, PA 18016-003061 0-882-3006Document is underlined to indicate the intended entitySOP Papers with Transmittal, via Fed Ex 2 Day , 796035530198Email Notification , Anne Milem [email protected] Notification, Nicolas Jafarieh [email protected] Corporation SystemSabra Dudding116 Pine Street3rd Floor, Suite 320Harrisburg, P 17101717-234-6004

Page 1 of 2 IGInformation displayed on this transmittal is for CT Corporation srecord keeping purposes only and is provided to the recipient forquick reference. This information does not constitute a legalopinion as to the nature of action, the amount of damages, theanswer date or any information contained in the documentsthemselves. Recipient is responsible for interpreting saiddocuments and for taking appropriate action. Signatures oncertified mail receipts confirm receipt of package only notcontents.


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. CT ~ o r p o r a t i o n

TO Nicolas JafariehSallie Mae, Inc.2001 Edmund Halley DriveReston, VA 20191


RE Process Served in PennsylvaniaFOR Sallie Mae, Inc. Domestic State: DE

DOCKET HISTORYDOCUMENT( ) SERVED:NoticeLetter, ApplicationNoticeNotice

DATE AND HOUR OF SERVICE: TO: CT LOG NUMBER:By Regular Mail on 06/14/2013 t 09:30 Nicolas Jafari eh 522929170postmarked on 06/11/2013 Sallie Mae, Inc.By Regular Mail on 06/07/2013 t 10:00 Nicolas Jafariehpostmarked on 06/03/2013 Sallie Mae, Inc. 522878495By Regular Mail on 05/20/2013 t 09:30 Nicolas Jafarieh 522762046postmarked on 05/14/2013 Sallie Mae, Inc.By Regular Mail on 04/22/2013 at 09:30 Nicolas Jafarieh 522566874postmarked on 04/17/2013 Sallie Mae, Inc.

Page 2 of 2 IGInformation displayed on this transmittal is for CT Corporation srecord keeping purposes only and is provided to the recipient forquick reference. This information does not constit ute a legalopinion as to the nature of action, the amount of damages, theanswer date or any information contained in the documentsthemselves. Recipient is responsible for interpreting saiddocuments and for taking appropriate action. Signatures oncertified mail receipts confirm receipt of package only notcontents.


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COURT OF COMMON PLEAS OF LEHIGH COUNTYCIVIL DIVISION - LAWRay B Mead,

PlaintiffV

No. 2013-C-1264r nro r

Sallie Mae, Inc., ~ :2- - - - ~ r e f e n d a n t ; ;C?;a< - nc:;::::.c-;C. c:-< ::;:;. - 1o c.flPRAECIPE TO REINSTATE C O M P L I ~ T

TO THE CLERK OF COURTS CIVIL DIVISION:

w. - .c::zIJo;:1:

)1

Kindly reinstate the Complaint which was originally filed on April 11, 2013.

Date: j f-- IDouglas Jon Tkacik18 East Market Street

11-rn0

Post Office Box 30Bethlehem, P A 18016-0030Telephone: 610-882-3006Supreme Court ID 62573


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\Supretne Court of Pennsylvania

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Court of Cotnmon PleasCivil Cover S I H ~ e t For Protho11otary Use Only:~ L _ e h i g h County Docket No:

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Commencement of Action: ~ ~ ? ~ _...- \...:- ,.,--.tzl Complaint 0 Writ of Summons D Petition 0 N o ( i c c = 6 f ~ A p p e a l f\\Trunsfcr from Another Jurisdiction 0 Declaration of Taking c9._:.z.t_.;t ,_....1 . rLend Plaintiff's Narne: I end De O.,dm>


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COURT OF COMMON PLEAS OF LEI-IIGI-I COUNTYCIVIL DIVISION - LAW

Ray B. Mead \ \r ; ~ -laintiff c,.o. l;f_rQ --o. ; ) ~ - 1 . ;o::t:7 -. o oc QSallie Mae Inc., ~ .Defendant :2_c:: '-8- ?- -- / ) N

NOTICE

You have been sued in court. If you wish to defend against the claims set forth in thefollowing pages, you must take action within twenty (20) days after this Notice and Complaint areserved, by entering a written appearance personally or by attorney and filing in writing with thecourt your defenses or objections to the claims set forth against you. You are warned that if youfail to do so the case may proceed without you and a judgment may be entered against you by thecourt without further notice for any money claims in the Complaint or for any other claim or reliefrequested by the Plaintiff . You may lose money or property or other rights i1nportant to you.

YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DONOT 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 TOPROVIDE YOU WITH INFORMATH)N ABOUT AGENCIES THAT MAY OFFER LEGALSERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE:

Date

Lawyer Referral ServiceLehigh County Bar Association1114 West Walnut Street

Allentown, PA 18102-4734Telephone: 6 1 0 - 4 3 3 - 7 0 ~ 4 } _~ V l

--I-r\ I \\0

WE HEREBY CERTIFY THAT THE WITHINISA TRUEANDC RRECTCOPYOFTHE

Douglas Jon Tkacik8 E. Market Street

P.O. Box 30B e t h l e h e m ~ PA 18018Telephone: 610-882-3006 /.--/?,.--(?Supreme Ct. ID N f i f ' N J , 7 . . . . z . 3 ~ ~ ~ ---LL-__....2 '=--RIGINAL FILE IS ACTION THE WITHIN COMPLAINTIS REINSTATE


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. \

O U R T ~ OF COMMON PIJEAS OF LEHIGH COUNT YCIVIL DIVISION LAW

Ray B I\1ead, Plaintiffv.

Sallie Mae, Inc.,Defendant

No.

COMPLAINT FOR DECLARATORY JUDGMENTCOMES NOW, Plaintiff, Ray B Mead, by and through his attorney, Douglas Jon Tkacik,

and files this Complaint for Declaratory Judgment and in support thereof avers as follows:1 Ray B Mead is an adult individual who resides at 6308 Chestnut Hill Road,

Coopersburg, Lehigh County, Pennsylvania 18036-1893.2. Defendant, Sallie Mae, Inc. is a foreign corporation registered in Pennsylvania with

a registered agent at CT Corporation, 116 Pine Street, Suite 320, Harrisburg, PA 17101.3. This is an action for declaratory judgment pursuant t 42 Pa.C.S. 7531 et seq.,

for the purpose of determining a question o actual controversy between the parties as hereinaftermore fuJiy appears.

4. Upon reviewing his credit report, Plaintiff, Ray B Mead learned that Sallie Maehad identified him as a Borrower with regard to several PLUS student loans with the accountnumber 9691386463.

5. It is believed and therefore averred that a PLUS loan is a loan for highereducation that is taken by the parent for the benefit of the child.


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6. On July 18, 2012, the Plaintiff requested the Defendant to provide him with copiesof all documents and correspondence related to the account including but not litnited to the LoanApplication, the Promissory Note and the loan terms.

7. The Application and Promissory Note received by the Plaintiff do not contain thePlaintiff's signature.

8. Mr. Mead has not executed a PLUS loan for the benefit of his son or daughter.9. Mr. Mead is not obligated to pay any PLUS loan.WHEREFORE, Plaintiff, Ray B. Mead, respectfully requests this Honorable Court to:

Enter judgment declaring that Ray B. Mead is not a party to the student loans being serviced bySallie Mae, Inc.; Order that Sallie tvlae, Inc. is to cease all efforts to collect the debt fromPlaintiff; and direct Sallie Mae, Inc. to notify the credit reporting agencies to remove nyreference to Sallie Mae loan accounts fron1 Ray B. Mead's credit report within ten 10) days.

2

Respectfu ly Submitted,

I/v: /

Douglas on Tkacik18 East Market StreetPost Office Box 30Bethlehe1n, PA 18016-0030Telephone: 610-882-3006Supreme Court ID 62573


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VERIFIC TION

I Ray B Mead verify that the statements made in this Complaint for DeclaratoryJudgment are true and correct. I understand that false statements herein are made subject to thepenalties of 18 Pa.C.S.A. 4904 relating to unsworn falsification to authorities.

Date: ~ ~ 13

3

mead v sallie mae pennsylvania plus loans

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