HomeMy WebLinkAbout97-04452
~
)
~
~
.\l
~
{
I
:1
.
rot
'c'\
~
~'
KI'
0".
~I
I
The restaurant known as La Fontana, known as 420 Market street,
Lemoyne, PA, which is a rental property located on the following
described premises:
ALL TBAT'~AIB lot or piece of ground with the buildings and
improvements thereon erected, situate in the Borough of Lemoyne,
Cumberland County, pennsylvania, bounded and described in
accordance with a Final Subdivision Plan prepared by Robert J.
Fisher, Registered professional Engineer, dated september 1, 1993
and recorded in the Office of the Recorder of Deeds of Cumberland
County, Pennsylvania, at Plan Book 67, page 10.
BEGIBBIBG at the northern most point of the boundary line
dividing Lot 11 from adjoining lands now or formerly of Thomas and
Elena D'Agostino to the East, proceeding along said boundary line
South 24 degrees 40 minutes 00 seconds East 135 feet to a point on
the northern side of the right-of-way for Oak Street, thence along
the northern side of the right-of-way for Oak Street South 65
degrees 20 minutes 00 seconds West 157.50 feet to a point, thence
along the line dividing Lot 11 and land now or formerly of Lawrence
~. and Candace N. Dipietro North 24 degrees 40 minutes 00 seconds
West 135 feet to a point on the southern line of the right-of-way
for Market Street, thence along the southern line of the right-of-
way for Market Street North 65 degrees 20 minutes 00 seconds East
151.50 feet to the place of BEGIBBIBG. Containing .49 acres, more
or less.
IZIBG Lot 11 on said Final Subdivision Plan.
!06UAAA WID a ten foot strip of land adjoining Lot 11 to the
South, .hown on the Final Subdivision Plan as part of a ten-foot
addition to the dedicated right-of-way, and bounded and de.cribed
in accordance with the Final subdivi.ion plan a. followsl
IIZODllfIJIG at the southern most point of the boundary line
dividing Lot 11 from lands now or formerly of Lawrence E. and
Candace N. Dipietro to the West, and proceeding along the southern
boundary of Lot t1 Horth 65 degrees 20 minutes 00 seconds East
151.50 feet to the southern IDOst point of the boundary line
dividing Lot t1 from lands nOW or formerly of ThOlllls and Ilena
D' Agostino to the Ea.t, thence proceeding South 24 degrees 40
minutls 00 seconds last 10 feet to a point within the dedicated
right-of-wey, thence proceeding South 65 deqrees 20 minute. 00
..cond8 West 157.50 feet to . point within the dedicated right-of-
way, thence proceeding North 24 deqree. 40 Idnute. 00 ..conds "..t
10 feet to the place of alGl"1IG.
EXIUBtT A
~ p ~ ~
,.. ...,
'""Cu~; ,...
C!:'f~' c:: ~
.j.':>", ~ -,
. .. ,j - ::';1
w'/ .....
~ ".~. Ul
n - re' '~
.,
?l) .$:. ~\-... ..~~
~ ~ ,.,C' ~
It. . or"",! -.
-~
t;. t9 r.~ fr.>> ~.. (,)
~ .~ 6"'
l) --J ':) ~
~ - "'t -.; -
!; 00
~
~ ~
0\
,
~
PAUL L, KOSTICK t/a
PLK PROPERTIES,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
.
.
No.
<77 - '1.i/.5J..
VINCENZO MARCHIANO and
GUISEPPE RUSSO,
Defendants
.
.
COMPLAINT IN CONFESSION OF JUDGMENT
FOR EJECTMENT
1. plaintiff is Paul L. Kostick, an adult individual,
trading as PLK Properties (hereinafter "PLK"), with an office
address of 418R Market Street, Lemoyne, Cumberland County,
Pennsylvania.
2.
Defendant,
Vincenzo Marchiano
(hereinafter
"Marchiano"), is an adult individual, former owner/operator of La
Fontana, Inc., a Pennsylvania Corporation doing business at 420
Market street, Lemoyn., Cumberland County, Pennsylvania.
3. Defendant, Guiseppe Russo (hereinafter "Russo"), is
an adult individual, and current owner/operator of La Fontana,
Inc., a P.nn.Ylvania corporation doing business at 420 Market
Street, Lemoyn., CUmberland County, PennRylvania.
4. At all time. her.in mentioned, plaintiff wa., and now
i., the owner in f.. simpl., and entitled to the pos....ion of,
c.rtain real property located at 420 Market Street, Lemoyne,
cumberland county, Penn.ylvania, and IIOre fully described in
Exhibit A attached hereto.
5. on or about NOveaber 19. 1993, plaintiff entered into
a written Lea.e with Francesco Failla (the "Lea.e"), a true and
.. '."'f'f'1l''J;\ _ '~\mD.t"n.Kll'lI!to""~
..-". ......."
.. , >
.. ~ Jli.
correct copy of which is attached hereto as Exhibit B, for the
Lease of Plaintiff's property located at 420 Market street,
Lemoyne, Cumberland County, Pennsylvania.
6. On or about September 14, 1995, pursuant to a Lease
Addendum, a true and correct copy of which is attached hereto as
Exhibit C, Marchiano, assumed full responsibility for the
obligations of the said Lease.
7. On or about April 19, 1996, pursuant to an agreement
between Marchiano, Russo and PLl<, a true and correct copy of which
is attached hereto as Exhibit 0, Russo assumed possession of the
premises and the responsibility for the obligations of the Lease.
Marchiano also remained responsible for the Lease obligations.
8. Judgment on the Agreement has not been entered in any
jurisdiction.
9. Pursuant to the terllls of the Lease, Plaintiff is
authorized to enter judgment by confession for ejectment after
default by Defendants.
10. Defendants are in default of the terms of the Lease
hereinabove described, by failing and refusing to make the monthly
payaents in a ti.ely manner.
11. This judqment is not being entered by confesslon
aqalnst a natural person in cOMection with a consWler credit
transaction.
12. JudClMnt has not been entered on the inatruHnt in
any jurisdiction.
1). Defendants have f"Uad and refuaed to surrender
.. '. "'f1o'tt'.A\I".lITll:1 \ '.1'\.Kllt -", ""
The restaurant known as La Fontana, known as 420 Market Street,
Lemoyne, PA, which is a rental property located on the following
described premises:
ALL TBA~~AI. lot or piece of ground with the buildings and
improvements thereon erected, situate in the Borough of Lemoyne,
Cumberland County, Pennsylvania, bounded and descritled in
accordance with a Final Subdivision Plan prepared by Robert J.
Fisher, Registered Professional Engineer, dated September 1, 1993
and recorded in the Office of the Recorder of Deeds of Cumberland
County, Pennsylvania, at Plan Book 67, Page 10.
8EOI&I80 at the northern most point of the boundary line
dividing Lot '1 from adjoining lands now or formerly of Thomas and
Elena D'Agostino to the East, proceeding along said boundary line
South 24 degrees 40 minutes 00 seconds East 135 feet to a point on
the northern side of the right-of-way for Oak Street, thence along
the northern side of the right-of-way for Oak Street South 65
degrees 20 minutes 00 seconds West 151.50 feet to a point, thence
along the line dividing Lot 11 and land now or formerly of Lawrence
a. and Candace N. Dipietro North 24 degrees 40 minutes 00 seconds
West 135 feet to a point on the southern line of the right-of-way
for Market Street, thence along the southern line of the right-of-
way for Market Street North 65 degrees 20 minutes 00 seconds East
157.50 feet to the place of BEOIRRIIO. Containing .49 acres, more
or less.
BEllO Lot .1 on said Final Subdivision Plan.
TOG~~II&K 111ft a ten foot strip of land adjoining Lot 11 to the
South, shown on the Final Subdivision Plan as part of a ten-foot
addition to ths dedicated ri9ht-of-war' and bounded and described
in accordance with the Final Subdivis on Plan as follows:
IBGIDIIIO at the southern most point of the boundary line
dividing Lot 11 from lands now or formerly of Lawrence E. and
Candace N. Dipietro to the West, and proceeding along the southern
boundary of Lot 11 North 65 degrees 20 minutes 00 seconds East
151.50 feet to the southern most point of the boundary line
dividing Lot 11 from lands now or formerly of Thomas and Elena
D' Aqo.tino to the Ealt, thence proceeding South 24 degree. 40
minutes 00 second. East 10 feet to a point within the dedicated
right-of-way, thence proceeding South 65 degrees 20 IIinute. 00
.econd. We.t 157.50 feet to a point within the dedicated right-of-
way, thence proceeding North 24 degree. 40 IIinute. 00 seconds West
10 feet to the place of IIOI..IIIO.
URflllT A
KOSTICK/FRANCESCO FAILLA LEASE
TABLE OF CONTENTS
ARTICLE 1. TERM . . . . . . . . . . . . . . . . . 1
ARTICLE 2. RENT . . . . . . . . . . . . . . . . 2
ARTICLE 3. USE OF PREMISES. . . . . . . . . . . . 3
ARTICLE 4. REPAIRS AND MAINTENANCE. . . . . . . . 4
ARTICLE 5. UTILITIES AND TAXES. . . . . . . . . 5
ARTICLE 6. ALTERATIONS, ADDITIONS, AND
IMPROVEMENTS . . . . . . . . . . . . 6
ARTICLE 7. TRADE FIXTURES AND SIGNS . . . . . . . 7
ARTICLE 8. MECHANICS I LIENS . . . . . . . . . . . 8
ARTICLE 9. INSURANCE AND INDEMNITY. . . . . . . . 8
ARTICLE 10. DAMAGE OR DESTRUCTION OF PREMISES. . . 10
ARTICLE 11. CONDEMNATION . . . . . . . . . . . . . 12
ARTICLE 12. EVENTS OF DEFAULT. . . . . . . . . . . 13
ARTICLE 13. INSPECTION BY LESSOR . . . . . . . . . 17
ARTICLE 14. ASSIGNMENT AND SUBLEASE. . . . . . . . 18
ARTICLE 15. ENVIROJlKENTAL COMPLIANCE . . . . . . . 18
ARTICLE 16. RULES AND REGULATIONS. . . . . . . . . 21
ARTICLE 17. CONDmOll PRECZDENT. . . . . . . . . . 21
ARTICLE 18. MISCELLAHJ:OUI. . . . . . . . . . . . . 21
nM181t 8
LEASE
This Lease is made and entered this 19th day of
November, 1993, between Paul L. Kostick, referred to in thiu
Lease as Lessor, and Francesco Failla, referred to in this Lease
as Lessee.
In consideration of the mutual covenants and agreements
set forth in this Lease, and other good and valuable
consideration, Lessor leases to Lessee, and Lessee leases from
Lessor, retail space at the west end of 420 Market Street,
Borough of Lemoyne, Cumberland County, Pennsylvania, and more
particularly described on Exhibit A attached to this Lease, and
referred to herein as the Premises.
AR'1'ICLE 1. '1'ERM
'1'e1'lll of Leas.
1.01 The "Commencement Date" of the term of this Lease
shall be the later of December 1, 1993 or the date when the
Premises and the improvements required to be constructed by
Lessor under Paragraph 6.01 hereof shall have been substantially
completed; provided that if Lessee shall take possession of the
Premises or any portion thereof prior to either of the foregoing
dates, then the Commencement Date shall be the date on which
Lessee takes such possession. Unless sooner terminated in
accordance with the terms hereof, the term of this Lease shall
end without the necessity for notice from either party to the
other at 12:01 a.m. local time on the third (3rd) anniversary of
the first day of the first full calendar month during the term
(herein called the "Expiration Date").
When the date of commencement of the term of this lease
is establi.hed, Lessor and Lessee shall promptly execute a
memorandum acknowl.dging sam..
Option to btlU14 '1'.J:II
1.02 Le.... has the right to .xtend this Lea.. beyond
the .xpiration date provided in S.ction 1.01 on the following
t.ras and conditions:
(a) Should Le.... fully perf ora all of the t.ras and
condition. of this Le.... Le.... may extend the t.ra of this
Le... for a period of three (3) years, with the .xtended t.ra to
beqin on the day following the .xpiration d.t. of the Leas. t.ra
.pecified in S.ction 1.01. However, if at the date of expiration
of the oriVinal tera IA.... ia in default beyoncl .ny vrace period
provided 1n this Le... for the performance of any of
1
the terms or provisions of this Lease, or any event has occurred
which with the giving of notice or passage of time or both could
constitute a default under this Lease, Lessee's exercise of any
option exercised and shall be null and void. All of the terms,
covenants, and provisions of this Lease shall apply to all
extended Lease terms except that the rent for each such extended
term shall be adjusted as set forth in section 2.01 hereof.
(b) Lessee may exercise each option to extend this
Lease by giving to Lessor notice of its intention to do so not
later than six (6) months prior to the expiration of the initial
Lease term. To constitute effective notice of an intention of
exercise an option under this Lease, the notice must be sent by
certified or registered mail or nationally recognized overnight
courier to Lessor at the address and in accordance with the
procedures provided in section 16.01 of this Lease and must be
postmarked no later than the date provided in this Article for
Lessee'. exercise of the option.
Holdover
1.03 If Lessee hold. over and wrongfully continues in
posse..ion of the Premi.e. after expiration of the term of this
Lease or any extension of that term, Lessee will be deemed to be
occupying the Premi.es at sufferance from month-to-month tenancy,
without limitation on any of Les.or'. right. or remedies
hereunder and subject to all of the terms and conditions of this
Lease, except that the fixed rent shall be increased to twice the
fixed rent payable for the last month of the term of this Lease
prior to the holdover.
Delivery of po.....iOD
1.04 If Les.or i. unable to deliver actual posses.ion
of the leased Premise. on the commencement date of the term for
any rea.on beyond Lessor'. control, including without limitation,
because the building has not been sufficiently completed to make
the Premise. ready tor occupancy, or if repairs or improvement.
to be perform.d by l.s.or, are not compl.ted because of the
holding ov.r ot a pr.vious occupant, the Le..or .hall not be
liable in damag.. to the Le...., and during the period that the
l...or i. unable to give po.....ion, no rent .hall accru.. No
.uch tailure to give po.....ion shall in any oth.r re.pect att.ct
the validity ot this l.as. or any obligation ot Lesse. her.under.
U'fICLJI I. aarr
Pia" aut
2.01 Letls_ aqr._ to pay to Lessor the sua of on.
Thousand on. Hundred rifty ($1,150.00) Dollars per IIOnth in
2
advance on or before the first day of each month, throughout the
term of this Lease as the fixed rent. The first and last monthly
rent installments shall be paid at the signing of this Lease.
Rent for any fractional month at the beginning of the Lease term
shall be prorated on a per diem basis.
At the conclusion of the third full Lease year and
every Lease year thereafter, should the Lease term be extended,
the fixed rent for the Premises shall be adjusted annually,
provided that the fixed rent shall never be less than One
Thousand One Hundred Fifty ($1,150.00) Dollars per month, by
applying fluctuations in the Consumer Price Index as follows:
(a) The Consumer Price Index for the purposes of this
Lease shall be the Consumer Price Index for All Items for All
Urban Consumers (unadjusted), published by the Bureau of Labor
Statistics of the United States Department of Labor. For All
Items, 1982-100. If the Consumer Price Index ceases to be
published by the United States Department of Labor, Bureau of
Statistics, then the calculation shall be based on the closest
successor index as identified by the United States Department of
Labor. If no such successor exists, the calculation shall be
based on an index that is mutually agreed between Lessor and
Lessee.
(b) The Base Date shall be the month of October, 1993.
(c) The adjusted rent shall be determined by
multiplying the fixed rent by a fraction, the numerator of which
shall be the Consumer Price Index for October of the third full
Lease year and of each Lease year thereafter (the "Comparison
Date"), as the case may be, and the denominator of which shall be
the Consumer Price Index for the Base Date. The resulting sum,
if greater than the fixed rent, shall be the adjusted rent
payable monthly for the following Lease year.
U'l'ICLB 3. USI or PJlIKISU
perait:te" U.e
3.01 Les.e. may use th. Premis.s to op.rate and
conduct a r.staurant and take-out busines., and tor no other
purpoee, but in any event only in complianc. with any applicable
laws, rule., regulations, statutes and applicable ordinances new
or hereafter in ettect. Les.ee i. re.ponsible to procure all
license., perait. and approval. required to conduct it. bu.ine..
on the Pr..i.... Le.... may not u.e the Pr..ia.. for any other
purpo.e without the prior writt.n cons.nt of Le..or Which cons.nt
may be withheld tor any reason or no reason, in the sole
di.cretion ot Le..or.
)
Waste, Nuisance, or Illegal Uses
3.02 Lessee shall not use or permit the use of the
Premises in any manner that results in waste of the Premises or
constitutes a nuisance or violates any statute, ordinance, rule,
or regulation applicable to the Premises or for any illegal
purpose. Lessee, at its sole cost, shall comply, and cause its
officers, employees, agents and invitees to comply with all
applicable laws, ordinances, rules or regulations or any other
requirement of any duly constituted public authority having
jurisdiction over the Premises or the use of the Premises,
including, without limitation, the provisions of the Americans
with Disabilities Act.
ARTICLE 4. REPAIRS AND MAINTENANCE
Repair. and Kaintenance by Les.ee
4.01 Lessee acknowledges and agrees that Lessee is
familiar with and has inspected the Premises, and has apprised
itself about the surrounding properties and neighborhood, the
availability or unavailability of public water and sewer or other
utility service to the Premises, and the zoning and other
requirements applicable to the Premises, and that, except for the
structural improvements identified in Section 6.01 to made by
Lessor, the Premises is being leased in its "as is" "where is"
condition without any representation by or on behalf of Lessor
concerning the Premises.
4.02 Lessee shall, throughout the term of this Lease
and any extensions of that term, at its own expense and risk,
maintain the leased Premises in good order and condition,
including but not limited to, making all repairs and
replacements, renewals and additions, interior and exterior,
ordinary and extraordinary, foreseen and unforeseen, necessary to
keep and maintain the Premises and all syste.., equipment and
apparatus appurtenant thereto or used in connection therewith and
improvements (inClUding HVAC and glass) in good order and
condition. All maintenance, repairs, and replacements required
by this Article must be performed promptly when required and in a
manner that will not cause depreciation in the value of the
Prai.es. Lassee shall return the Premises to Lessor in such
good order and condition at the expiration of the term hereof,
ordinary wear and tear excepted. Any repairs, replacement.,
renewals and additions and any labor performed or material.
furnished in, on or about the Premise. shall be performed and
furnished in strict compliance with all applicable lava,
regulation., ordinances and requirement. ot all duly constituted
municipal authorities or other governmental bodies having
4
jurisdiction over the Premises. PROVIDED, NEVERTHELESS, that
Lessor shall make all necessary structural and roof repairs
required during the term of this Lease, and shall maintain the
parking lot and sidewalk.
4.03 In the event Lessee fails to perform its
obligation to repair, replace, or maintain as set forth in
Section 4.02, after a reasonable time after notice from Lessor of
the need for such repair, replacement, or maintenance, Lessor may
enter the Premises and make such repairs or replacements, or
perform such maintenance or cause such repairs or replacements to
be made or maintenance to be performed, at its own expense. Upon
Lessor's notice to Lessee of the performance and cost of any
maintenance, repairs, or replacements, Lessee shall immediately
reimburse Lessor for any reasonable costs incurred by Lessor,
together with interest on any such sum at 1 1/2\ per month from
the date of the notice until the date paid by Lessee to Lessor.
ARTICLE 5. UTILITIES AND TAXES
Utility Charg..
5.01 Lesse. shall pay all utility charges for water,
electricity, heat, gas, steam, telephone and all other services
or utilities used in and about the leased Premises during the
term of the Lea.e. The Lessee shall pay all such charges
directly to the utility company or municipality furnishing the
service, before the charges shall become delinquent, or shall
reimburse Lessor the cost thereof, in the event Lessor chooses to
furnish same, as Lessor may direct.
aarbag. ...oval
5.02 Le.... .hall be re.pon.ibl. for and .hall pay for
the removal of all garbage and rubbi.h from the lea.ed Premi.es
dur inl,1 the t.rm of the Lea...
per.oll&l Property Tu..
5.0J Le.... .hall be liable for .11 tax.. l.vied or
a......d al,1ain.t per.onal property, furnitur., or fixtur.. placed
by Le.... in or on the Pr..ia... If .ny .uch t.x.. for which
Le.... i. liable ar. l.vied or .......d .gain.t Les.or or
Le..or'. property, and if Le..or el.ct. to pay them, or if the
a.....ed value of Le..or'. property i. incr.ased by inclusion of
per.onal property, furnitur., or fixtur.. placed by 1..... in the
Pr.mi.... and Le..or .l.ct. to pay tha tax.. ba..d on .uch
incr...., Le.... shall pay to Le..or on d.lI&nd th.t part of the
taxe. for which 1..... i. prill&rily li.bl. under this Articl..
5
Real property Taxes and Assessments
5.04 Lessor shall pay and fully discharge all real
property taxes andl assessments imposed on the leased Premises
during the term of this Lease.
Rent Tax; Us. and occupancy Tax
5.05 If, during the term of this Lease or any renewal
or extension thereof, any tax is imposed upon the privilege of
renting or occupying the Premises or upon the amount of rentals
collected therefore, Lessee will pay each month, as additional
rent, a sum equal to such tax or charge that is imposed for such
month, but nothing herein shall be taken to require Lessee to pay
any income, estate, inheritance or franchise tax imposed upon
Lessor.
ARTICLE 6. ALTERATIONS, ADDITIONS, AND IHPROVEHEHTS
Improvem.nt of premis..
6.01 Lessor shall make the following improvements to
the Premises: Vanilla box only.
Consent of L.ssor
6.02 Lessee shall not make any alterations, additions
or improvements to the leased Premises without the prior written
consent of Lessor. Consent for nonstructural alterations,
additions, or improvements shall not be unreasonably withheld by
Lessor, provided such non-structural alterations, additions or
improvement. .hall not adversely affect the .tructural soundness
of the Premises or reduce the value of any existing structure or
improvement.
prop.rty of L...or
6.03 All alterations, additions, or improvements
mad. by Lesse. shall b.com. the property of Lessor at the
termination of this Leas.. Lessor may, how.v.r, require that
Le.... remove any or all alterations, addition., and improvements
in.talled or mad. by Le.... on termination of the La.... In the
.v.nt that Le..or r.quir.. Le.... to remove .uch alt.ration.,
additions, or improvement., Le..e. ahall repair any damage or
in::lury to the Premiaes caused by such removal.
6.04 Le..or, at it. option, may in any ca.. in which
it. con..nt i. r.quired pursuant to S.ction 6.02 h.r.of r.quir.
Le.... to furnlah it with copies of the applicabl. plan. and
.pecification. and any r.l.vant contract betwe.n Le.... and any
6
contractor or supplier. Lessor may also require, at its option
and as a condition precedent to giving any approval, (i) a
performance bond and a labor and material payment bond, both in
form and substance satisfactory to Lessor, given by an
independent financially responsible corporate surety, to assure
completion of the work in accordance with the plans and
specifications, free of liens, and (ii) evidence that each
contractor has adequate workmen's compensation insurance and
general liability insurance with unimpaired limits of at least
$1,000,000 for injury to anyone person or injuries in anyone
occurrence and property damage of $500,000, together with a
certificate from the insurer to the effect that such insurance
may not be canceled or substantially modified without at least 30
days prior written notice to Lessor.
ARTICLE 7. TRADE FIXTURES AND SIaHS
Trad. Fiztur..
7.01 Lessee has the right at all times to erect or
install shelves, bins, machinery, equipment, or other trade
fixtures in, on, or about the leased Premises, provided that
Lessee complies with all applicable governmental laws,
ordinances, and regulations regarding such fixtures. Lessee has
the right to remove all trade fixtures at the termination of this
Lease, provided Lessee is not in default under the Lease and that
the fixtures can be removed without structural damage to the
building. Lessee must repair and restore any damage or injury to
the building, structures and improvements now or hereafter
erected on the Premises caused by installation or removal of
trade fixtures, and all such repairs must be completed prior to
the termination of the LeaBe. Any trade fixtures that have not
been removed by LesB.e at the termination of this Leas. .hall be
deemed abandoned by the Le..ee and .hall automatically become the
prop.rty of Lessor. In the event any trade fixture in.tall.d by
Lesse. is abandoned at the termination of the Leas., Le.... mu.t
pay Les.or any r.a.onabl. .xpens. actually incurred by Le..or to
remove the fixture from the Premises, provid.d the fixture is
remov.d prior to the entrance of any sub..quent Lessee onto the
Pr.mi....
8iqn.
7.02 Le.... may not in.tall any .ign or about the
lea..d premi... without fir.t obtaining the writt.n approval of
Le.sor with regard to the .ile, type, .hap., d..ign, color,
mat.rial, cont.nt, and ..thod of attachm.nt of the .ign.
Les.or'. approval shall not be unrea.onably withh.ld. Le....
au.t, at its sol. .xpen.., remove any signs installed on or about
7
the leased Premises by Lessee and repair any damage done to the
leased Premises or the building in which the leased Premises are
located or the land surrounding the leased Premises by the
installation or removal of the signs. This removal and repair
must be completed not later than the termination date of this
Lease.
ARTICLB 8. HECRANICS' LIENS
B.01 Lessee shall promptly pay any contractors and
materialmen who supply labor, work or materials to Lessee at the
Premises or the Building so as to avoid the possibility of a lien
attaching to the Premises. Lessee will not permit any mechanic's
lien or liens to be placed on the Premises or improvements on the
Premises. If a mechanic's lien is filed on the Premises or on
improvements on the leased Premises, Lessee will promptly cause
it to be discharged of record by payment, deposit, bond, order of
court or otherwise or will pay the lien. If default in payment
of the lien continues of record for twenty days after written
notice from Lessor to Lessee, Lessor may, at its option, pay the
lien or any portion of it without inquiry as to its validity.
Any amounts paid by the Lessor to remove a mechanic's lien caused
to be filed against the Premises or improvements on the Premises
by Lessee, including expenses and interest, shall be due from
Lessee to Lessor and shall be repaid to Lessor immediately on
receipt of notice, together with interest at the rate of 18l per
annum from the date Lessor paid to remove such lien until the
date Lessee repays Lessor. Nothing in this Lease is intended to
authorize Lessee to do or cause any work or labor to be done or
any materials to be supplied for the account of Lessor, all of
the sam. to be solely for Lessee's account and at Lessee's risk
and expens.. Throughout this Lease the term "mechanic's lien" is
u.ed to include any lien, encumbrance or charg. levied or imposed
upon the Premise. or any interest therein or income therefrom on
account of any mechanic's, laborer. or materialman'. lien or
claia or arising out of any debt or liability to or any claim or
demand of any contractor, mechanic, supplier, materialman or
laborer.
U'fICU ,. DflUJIAHCB AHD IHDBJDrIT1'
Li&bi1itJ ID.uraDO.
9.01 Le...., at its own expen.e, .hall provide and
maintain in force during the t.ra of this Leas., compreh.n.ive
98"eral liability insurance prot.cting Le.sor and Le.... again.t
injury or daug. to any person or property occurring in, on or
aboUt the Preais.. or any sidewalks, driveways, perki"9 lot. or
other area. appurtenant to the Pr..i.... SUch insurance ahall be
in the aaount of at le.at $1.000,000 .ingle li.it for injury to
.
anyone person or injuries in anyone occurrence, and $500,000
for property damage, unimpaired. Such policies shall name Lessor
and Lessee as insureds. This insurance is to be carried by one
or more insurance companies authorized to do business in
Pennsylvania.
Rem.dy for Failur. to Provide Insuranc.
9.02 Lessee shall furnish Lessor with certificates of
all insurance required by this Article. If Lessee does not
provide such certificates on Lessor's delivery of possession to
Lessee or if Lessee allows any insurance required under this
Article to lapse, Lessor may, at its option, take out and pay the
premiums on the necessary insurance to comply with Lessee's
obligations under the provisions of this Article. Lessor is
entitled to reimbursement from Lessee for all amounts spent by it
to procure and maintain such insurance, with interest at the rate
of lB' per annum from the date of receipt of Lessor's notice of
payment until reimbursement by Lessee.
Bold-Barml... Clau..
9.03 Lessor shall not be responsible for and is hereby
relieved from all liability for any damage, expense, cause of
action, suits, demands, judgments, and claims of any nature
whatsoever, arising from or by reason of any injury to any person
or persons or any damage to any property which may arise from any
caus. (including, without limitation, n.gligence of L.ssor or its
agent., servants or employees), or from present or future
structural defects or other conditions in, on or about the
Premi.e. or any part thereof or any sid.walk., streets,
driveway., rights-of-way or roadways adjacent thereto, or in any
manner growing out ot or conn.cted with the use and occupancy of
the Premi.e. or any part th.reof by Le.... or any other party
during the term of this Leas. or any renewal or .xt.nsion
ther.of. Le.... acc.pts and as.um.s such liability and agr... to
prot.ct, indemnity and hold Lessor harml.s. against any and all
liability, claims, demands, damages, costs, and expenses,
including rea.onable attorney.' fee. for the defense of such
clai.. and demand., arising froa the conduct or managem.nt of
Le....'. bu.in.s. on the pr.mi.e., or it. u.e of the Pr.mi.e. or
froa any br.ach on the part of L..... of any condition. of this
Lea.., or from any act or n.glig.nc. of Le...., it. ag.nts,
contractors, employe.., suble....., conc.ssionaire., or license..
in or about the Premis... In ca.. of any action or proce.ding
brought against Le.sor by r.a.on of any .uch claim, Le...., on
notice froa Le..or, agr... to defend the action or proc.eding.
Thi. .hall not be con. trued a. in any way limiting Le....'.
obligation. under Articl. 9.
9
9.04 The insurance policies referred to above shall be
underwritten by insut'ance companies with Best's "A" rating or
better. Lessee shall deliver to Lessor certificates of all
insurance policies on or before the first day of the term hereof
and thereafter ten days prior to the execution of any such
pOlicy. Lessee shall also deliver to Lessor receipts evidencing
payment of all insurance premiums, which delivery shall be at
least ten days prior to the date such premiums are due.
ARTICLE 10. DAMAGE OR DESTRUCTION OF PREMISES
10.01 If the Premises should be damaged or destroyed
by fire, flood, or other casualty, Lessee shall give immediate
written notice of the damage or destruction to Lessor, including
a description of the damage and, as far as known to Lessee, the
cause of the damage.
Total Destruction
10.02 If the Premises are totally destroyed by fire,
flood, or other casualty not the fault of Lessee or any person in
or about the Premises with the express or implied consent of
Lessee, or if the Premises should be so damages by such a cause
that rebuilding or repairs cannot, in Lessor's reasonable
judgment, be completed within ninety (90) calendar days and at a
cost not to exceed available insurance proceeds, this Lease shall
terminate, and rent shall be abated for the unexpired portion of
this Lease, effective as of the date of written notification as
provided in section 10.01.
partial Destruction
10.03 If the Premises are damaged by fire, flood, or
other casualty not the fault of Lessee or any person in or about
the Premises with the express or implied consent of Lessee, but
not to such an extent that rebuilding or repairs cannot
reasonably be completed within ninety (90) calendar days and at a
cost not to exceed available insurance proceeds, this Lease shall
not be terminated except as provided in Subparagraphs (a) and
(b).
(a) If the partial destru~tion of the Premises occurs
prior to the final six (6) months of the then current Lease term,
Lessor shall, at its .ole cost and ri.k, proceed immediately to
rebuild or repair the damaged buildings and improvements to
substantially the condition in which they existed prior to such
dUlllqe; provided, however, that Lessor shall not be required to
expend monies in exce.. of insurance proceeds made available to
Les.or for such purpose. If the premi.e. are untenantable in
whole or 1n part followih9 such damage, the rent payable dur1h9
10
the period in which they are untenantable shall be adjusted
equitably. In the event that Lessor should fail to complete such
rebuilding or repairs with ninety (90) calendar days from the
date of written notification by Lessee to Lessor of the
occurrence of the damage, Lessee may terminate this Lease by
written notification to Lessor. On such notification, all rights
and obligations under this Lease shall cease.
(b) If partial destruction of the Premises occurs in
the final six (6) months of the then current Lease term, or if
any mortgagee holding a lien on the premises refuses to permit
insurance proceeds to be applied to the restoration of the
Premises, or if the insurance proceeds available for restoration
are not sufficient to restore the Premises to substantially its
condition prior to the casualty, Lessor need not rebuild or
repair the premises and shall notify Lessee in writing of its
intention not to rebuild or repair. If Lessor elects not to
rebuild or repair the Premises and the Premises are untenantable
in whole or in part following such damage, Lessee may elect to
terminate the Lease as of the date of Lessee's notice described
in Section 10.01 above or to continue the Lease with the rent for
the remainder of the Lease period adjusted equitably. Lessee
shall notify Lessor of such election within ten (10) days after
receipt of Lessor's notice described above.
ARTICLE 11. CONDEH!iATIOB
Total condemnation
11.01 If the whole of the Premises shall be taken by
any public or quasi-public authority under the power of eminent
domain, condemnation, or expropriation, or, in the event of a
conveyance in lieu thereof, then this Lease shall terminate on
the date when title vesta in the condemning authority. Rent
shall abate and Lessee shall have no claim against Lessor or the
condemning authority for the value of the unexpired term of this
Lease.
Partial condemnation
11.02 If any part of the Premise. shall be .0 taken or
convey.d and if such partial taking or conv.yanc. .hall r.nder
the Premi... unsuitable for the busin.ss of the Le...., or if in
Les.or'. 801. opinion, it would be impractical or the
condeanation proceeds are insufficient to r.store the remaind.r
of the Preai.e., th.n the t.t'll of this Lea.. shall cea.. and
tet'llinate a. of the date on which title to the Preai... veat. in
the condemning authority. Le.... .hall have no claia against
Les.or or the cond.aninq authority for the value of any unexpired
11
portion of this lease. In the event such partial taking or
conveyance is not extensive enough to rend.r the pr.mis..
unsuitable for the business of Lessee, this Leas. shall continu.
in full force and effect except that the r.nt shall b. adjust.d
equitably during the unexpired portion of the Lease.
L.ssor'. Damag.a
11.03 In the event of any condemnation or taking,
whether whole or partial, the Lessee shall not be .ntitl.d to any
part of ~l. award. Lesse. hereby .xpressly waiv.. any right or
claim to any part of such amount and assign. to Les.or any .uch
right or claim to which Lesse. might become .ntitl.d.
L.....'. Damag..
11.04 Although all damag.. in the .v.nt of any
condemnation are to belong to the Les.or, Le.... .hall have the
right, to the .xtent that it .hall not dimini.h the Le..or'.
award, to claim and r.cover from the cond.mning authority, .uch
compensation as may be separat.ly award.d or r.cov.rabl. by
Less.. und.r the Emin.nt Domain Cod. in Le....'. own right for or
on account of, and li.ited .ol.ly to, any co.t to which Le....
might be put in removing Le....'. ..rchandi.., furnitur.,
fixtures, leasehold improv...nt., and .quip..nt.
Teaporarr Taking
11.05 If the cond.anor .hould take only the right to
posae.sion for a fixed p.riod of ti.. or for the duration of an
..erqency or other t..porary condition, th.n notwith.tanding
anything h.r.inabov. provid.d, thi. Lea.. .hall continue in full
force and .ffect without any abete..nt of r.nt, but the amount.
payable by the condemnor with r..pact to any p.riod of ti.. prior
to the expiration or .oon.r t.rmination of this Le.a. .hall be
paid by the cond.mnor to Le.sor and the cond.anor shall be
con.idered . .ubt.nant of Le..... Le.sor .hall apply the amount
r.ceived trom the condeanor applicabl. to the r.nt due hereund.r
n.t at cost. to La.sor for the coll.ction th.reof, or a. much
ther.ot a. .ay be n.c...ary tor .uch purpo.., toward the amount
due troa Le.... .. r.nt tor the pariod: and, La.... .hall p.y to
Lassor any d.tici.ncy betwe.n the a.ount thua paid by the
condemnor and the amount of the rent, or La..or .hall pay to
Le.... any .xc... of the a.ount of the Avard ov.r the amount of
the r.nt.
UTtc:tA 11. n...rr. or DII'J.Ut.t'
12.01 The followi", .venta or anyone or eor. of thea
.hall be .venta of d.fault unet... t.M. La....
12
(a) Lessee shall fail to pay any fixed rent,
additional rent or other sum payable hereunder; or
(b) Lessee shall fail to perform or comply with any of
the other terms, covenants, agreements or conditions hereof (and
such failure shall continue for more than five (5) days after
written notice thereof from Lessor) or (provided, if the default
cannot be cured within five (5) days), Lessee shall not be
considered in default if Lessee shall, within such period, have
commenced with due diligence and dispatch to cure such default,
and shall thereafter complete with due diligence the curing of
such default; or
(c) Lessee shall make a general assignment for the -
benefit of creditors, or shall admit in writing its inability to
pay its debts as they become due, or shall file a pgtition in
bankruptcy, or shall be adjudicated a bankrupt or insolvent, or
shall file a petition seeking any reorganization, arrangements,
composition readjustment, liquidation, dissolution or similar
relief under any present or future statute, law or regulation, or
shall file an answer admitting or not contesting the material
allegations of a petition against it in any such proceeding, or
shall seek or consent to or acquiesce in the appointment of any
trustee, receiver or liquidator of Lessee or any material part of
its properties; or
(d) If within 60 days after the commencement of any
proceeding against Lessee seeking any reorganization,
arrangement, composition, readjustment, liquidation or
dissolution or similar relief under any present or future
statute, law or regulation, such proceeding shall not have been
dismissed, or if, within 60 days after the appointment without
the consent or acquiescence of Lessee, of any trustee, receiver
or liquidator of Lessee, or of any material part of its
properties, such appointment shall not have been vacated.
12.02 In the event of any such event of default
(regardless of the pendency of any proceeding which has or might
have the effect of preventing Lessee from complying with the
terms of this Lease), Lessor at any time thereafter may exercise
anyone or more of the following remedies:
(e) Termination of Lease. Lessor may terminate this
Lease, without any right by Lessee to reinstate its rights by
payment of rent due or other performance of the terms and
conditions hereof. Upon such termination Lessee shall
immediately surrender posse..ion of the Premi..s to Lessor and
Lessor shall immediately become entitled to receive froa Le....
damage. equal to the difference between the a99Teqate rentals
13
reserved for the balance of the term and the tair rental value of
the Premises for that period, determined as ot the date ot such
termination.
(b) Reletting. With or without terminating this
Lease, as Lessor may elect, Lessor may re-enter and repossess the
Premises, or any part thereof, and lease them to any other person
or entity upon such terms as Lessor shall d.em reasonable, tor a
term within or beyond the term ot this Lease; provided, that any
such reletting prior to termination shall be tor the account ot
Lessee, and Lessee shall remain liable tor (a) all minimum rent,
additional rent and other sums which would be payable under this
Lease by Lessee in the absence ot .uch expiration, termination or
repossession, less (b) the net proceed., it any, ot any reletting
(including, without limitation, all ropo.....ion co.t., brokerage
commissions, legal expenses, attorney.' t.e. and exp.n.es,
employees' expenses, reasonable alt.ration co.t., and .xpenses of
preparation for such reletting).
It the Premise. are at the time ot detault sublet or
leased by Lessee to others, Les.or may, a. L.....'. agent,
collect rents due tram any .ubtenant or oth.r tenant and apply
such rents to the rent and other amount. due h.r.under without in
any way affecting Lessee'. obligation to Le..or h.r.under. Such
agency, being given for .ecurity, i. her.by d.clared to b.
irrevocable.
(c) Acceleration of R.nt. Le..or may d.clare rent and
all items of additional rent for the .ntir. balanc. ot the then
current term immediat.ly due and payabl., tog.th.r with all other
charges, payment., costs, and .xp.n... payable by L....e a.
though .uch amounts w.r. payable in advanc. on the date the event
of default occurr.d.
(i) No expiration or t.rmination at thi. Leas. term
pursuant to Section 12.02(a) hereot or by operation ot law or
otherwise (except a. .xpre..ly provided h.rein), and no
reposses.ion of the Premi... or any part ther.ot pur.uant to
Section 12.02(b) her.ot or otherwi.. .hall r.lieve Lesse. of its
liabiliti.s and obliqation. hereund.r, all of which shall .urvive
such .xpiration, termination or r.po.....ion, and Lessor may, at
its option, .u. tor and coll.ct rent and oth.r charge. due
h.r.under at any ti.. and troa tim. to time a. and when .uch
charq.. accrue.
12.03 With re.p.ct to any portion ot the Premise.
which i. vacant or Which i. phy.ically occupied by L....., Le..or
..y reaove all per.ons and property th.r.tro., and .tore .uch
property 1n a public warehoue. or el.ewhere at the co.t ot and
14
for the account of Lessee, without service of notice or resort to
legal process (all of which Lessee expressly waives) and without
being deemed guilty of trespass or becoming liable for any loss
or damage which may be occasioned thereby. Lessor shall have a
lien for the payment of all sums agreed to be paid by Lessee
herein upon all Lessee's property, which lien is to be in
addition to any Lessor's lien now or hereafter provided by law.
12.04 The parties hereby waive trial by jury in any
action, proceeding, or counterclaim brought by either of them
against the other on any matters arising out of or in any way
connected with this Lease, the relationship of Lessor and Lessee,
Lessee's use or occupancy of the Premises, and/or any claim or
injury or damage. In the event Lessor commences any proceedings
for non-payment of rent or additional rent, Lessee will not
interpose any counterclaim of any nature or description in any
such proceedings. This shall not be construed, however, as a
waiver of Lesseels right to assert any such claims in any
separate action brought by Lessee.
12.05 Lessee hereby expressly waives any and all
rights of redemption granted by or under any present or future
law in the event this Lease is terminated or Lessee is evicted or
dispossessed by reason of violation by Lessee of any of the
provisions of this Lease.
12.06 In the event of breach or threatened breach by
Lesse. of any provision of this Lease, Lessor shall have the
right of injunction as if other remedies were not provided for
herein.
12.07 No right or remedy herein conferred upon or
reserv.d to Lessor is intended to be .xclusiv. of any other right
or rem.dy h.rein or by law provid.d, but .ach .hall be cumulativ.
and in addition to ev.ry other right or remedy given h.rein or
now or her.after .xisting at law or in equity or by statut..
12.08 Any rent (including charges collectible a.
additional r.nt) overdue for a period of aor. than five (5) day.
.hall bear inter..t at the rat. of 18' p.r annum until paid.
12.09 If Le.... .hall d.fault in the performance of
any covenant required to be performed by it under thia Leas.,
Les.or ..y perfon the .aII. for the account and at the expan.. of
Le...., after fir.t giving notic. to Le.... of it. int.ntion to
do so. If Le..or at any tia. i. comp.ll.d to pay, or .l.cta to
pay, any .U11 of aon.y' by r.a.on of the faUur. of Le.... to
coaply with any proy .ions h.r.of, or if Le.sor i. compelled to
incur any .xpen.., includinq r.a.onabl. counsel f..., in
15
instituting, prosecuting or defending against any action or
proceeding instituted by reason of any default of Lessee
hereunder, the amount of such payments or expenses shall be paid
by Lessee to Lessor as additional rent on the next day following
such payment or the incurring of such expense upon which a
regular monthly rental payment is due, together with interest
thereon at the rate of 1B' per annum.
12.10 No waiver by Lessor of any breach by Lessee of
any of its obligations, agreements or covenants hereunder shall
be a waiver of any subsequent breach or of any other Obligation,
agreement or covenant, nor shall any forbearance by Lessor to
seek a remedy for any breach by Lessee be a waiver by Lessor of
its rights and remedies with respect to such or any subsequent
breach.
12.11 Lessee expressly waives any right of defense
which it may have based on any purported merger of any cause of
action, and neither the commencement of any action or proceeding
nor the settlement thereof or entering of judgment therein shall
bar Lessor from bringing subsequent actions or proceedings from
time to time.
THE FOLLOWING SECTIONS SET FORTH WARRANTS OF AUTHORITY
FOR AN ATTORNEY TO CONFESS JUDGMENT AGAINST KAKER. IN GRANTING
THIS RIGHT TO CONFESS JUDGMENT AGAINST LESSEE, LESSEE HEREBY
KNOWINGLY, INTENTIONALLY AND VOLUNTARILY, AND, ON THE
ADVICE OF THE SEPARATE COUNSEL OF LESSEE, UNCONDITIONALLY WAIVES
ANY AND ALL RIGHTS LESSEE HAD OR MAY HAVE TO PRIOR NOTICE AND AN
OPPORTUNITY FOR HEARING UNDER THE RESPECTIVE CONSTITUTIONS AND
LAWS OF THE UNITED STATES AND THE COMMONWEALTH OF PENNSYLVANIA.
12.12 LESSEE HEREBY EMPOWERS ANY PROTHONOTARY OR
ATTORNEY OF ANY COURT OF RECORD TO APPEAR FOR LESSEE IN ANY AND
ALL ACTIONS WHICH KAY BE BROUGHT FOR RENT AND/OR THE CHARGES,
PAYMENTS, COSTS AND EXPENSES HEREIN RESERVED AS RENT, OR HEREIN
AGREED TO BE PAID BY LESSEE AND/OR TO SIGN FOR LESSEE AN
AGREEHENT FOR ENTERING IN ANY COMPETENT COURT AN AMICABLE ACTION
OR ACTIONS FOR THE RECOVERY OF SUCH RENT OR OTHER CHARGES OR
EXPENSES, AND IN SAID SUITS OR IN SAID AMICABLE ACTION OR ACTIONS
TO CONFESS .:rtlDGHENT AGAINST LESSEE FOR ALL OR ANY PART OF THE
RENT SPECIFIED IN THIS LEASE AND THEN DUE AND UNPAID, AND OTHER
CHARGES, PAYMENTS, COSTS AND EXPENSES RESERVED AS RENT OR AGREED
TO BI PAID BY LESSEE AND THEN DUE AND UNPAID, AND FOR INTEREST
AND COSTS TOGETHER WITH A REASONABLE ATTORNEY' S COMMISSION or
15'. SUCH AUTHORITY IOHALL NOT BE EXHAUSTED BY ONE EXERCISE
THEREOr, BUT .:rtlDGHENT KAY BE CONFESSED AS AFORESAID FROM TIME TO
TIME AS OFTEN AS ANY or SAID RENT AND/OR OTHER CHARGES RESERVED
AS RENT OR AGREED TO Bl PAID BY LESSEE SHALL FALL out 0. 81 IN
ARUARS .
l'
12.13 UPON THE EXPIRATION OF THE THEN CURRENT TERM OF
THIS LEASE OR THE EARLIER TERMINATION OR SURRENDER HEREOF AS
PROVIDED IN THIS LEASE, IT SHALL BE LAWFUL FOR ANY ATTORNEY TO
APPEAR AS ATTORNEY FOR LESSEE AS WELL AS FOR ALL PERSONS CLAIMING
BY, THROUGH OR UNDER LESSEE AND TO SIGN AN AGREEMENT FOR ENTERING
IN ANY COMPETENT COURT AN AMICABLE ACTION IN EJECTMENT AGAINST
LESSEE AND ALL PERSONS CLAIMING BY, THROUGH OR UNDER LESSEE AND
THEREIN CONFESS JUDGMENT FOR THE RECOVERY BY LESSOR OF POSSESSION
THE HEREIN PREMISES, FOR WHICH THIS LEASE SHALL BE ITS SUFFICIENT
WARRANT, WHEREUPON, IF LESSOR SO DESIRES, A WRIT OF POSSESSION OR
OTHER APPROPRIATE WRIT UNDER THE RULES OF CIVIL PROCEDURE THEN IN
EFFECT MAY ISSUE FORTHWITH, WITHOUT ANY PRIOR WRIT OR
PROCEEDINGS; PROVIDED, HOWEVER, IF FOR ANY REASON AFTER SUCH
ACTION SHALL HAVE BEEN COMMENCED, THE SAME SHALL BE DETERMINED
AND THE POSSESSION OF THE PREMISES HEREBY DEMISED REMAIN IN OR BE
RESTORED TO LESSEE, LESSOR SHALL HAVE THE RIGHT FOR THE SAME
DEFAULT AND UPON ANY SUBSEQUENT DEFAULT OR DEFAULTS, OR UPON THE
TERMINATION OF THIS LEASE UNDER ANY OF THE TERMS OF THIS LEASE TO
BRING ONE OR MORE FURTHER AMICABLE ACTION OR ACTIONS AS
HEREINBEFORE SET FORTH TO RECOVER POSSESSION OF THE SAID PREMISES
AND CONFESS JUDGMENT FOR THE RECOVERY OF POSSESSION OF THE
PREMISES AS HEREINABOVE PROVIDED.
12.14 IN ANY AMICABLE ACTION OF EJECTMENT AND/OR FOR
RENT IN ARREARS, LESSOR SHALL FIRST CAUSE TO BE FILED IN SUCH
ACTION AN AFFIDAVIT MADE BY IT OR SOMEONE ACTING FOR IT, SETTING
FORTH THE FACTS NECESSARY TO AUTHORIZE THE ENTRY OF JUDGMENT,
AND, IF A TRUE ::OPY OF THIS LEASE (AND OF THE TRUTH OF THE COpy
SUCH AFFIDAVIT SHALL BE SUFFICIENT EVIDENCE) BE FILED IN SUCH
ACTION, IT SHALL NOT BE NECESSARY TO FILE THE ORIGINAL AS A WAR-
RANT OF A'l"l'ORNEY. ANY RULE OF COURT, CUSTOM OR PRACTICE TO THE
CONTRARY NOTWITHSTANDING. LESSEE HEREBY RELEASES TO LESSOR AND
TO ANY AND ALL ATTORNEYS WHO MAY APPEAR FOR LESSEE ALL ERRORS IN
SAID PROCEEDINGS AND ALL LIABILITY THEREOF. IF PROCEEDINGS SHALL
BE COKKENCED BY LESSOR TO RECOVER POSSESSION UNDER THE ACTS OF
ASSEKBLY AND RULES OF CIVIL PROCEDURE, EITHER AT THE END OF THE
TERM OR EARLIER TERMINATION OF THIS LEASE, OR FOR NON-PAYMENT OF
RENT OR ANY OTHER REASON, LESSEE SPECIFICALLY WAIVES THE RIGHT TO
THE J MONTHS' NOTICE AND TO THE 15 OR 30 DAYS' NOTICE REQUIRED
BY THE LANDLORD AND TENANT ACT OF 1951, AND AGREES THAT 5 DAYS'
NOTICE SHALL BE SUFFICIENT IN EITHER OR ANY SUCH CASE.
ARTICLI 13. I.I'ICTI05 BY LEIIOR
13.01 Le.... shall p.rmit Les.or and Les.or'. ag.nt.,
r.pr...ntatives, and e.ploy... to .nt.r the Premi.e. at all
r.asonable ti... tor the purpo.. at inspection, repair or any
other purpo.. nece..ary to prot.ct Lea.or'. intere.t in the
Preai... or to perform Le..or'. duti.. under this Le....
11
MTICLB U. ASSIGNMENT AND SUBLEASB
Assignm.nt and Subletting by Lesse.
14.01 Lessee may not sublet, assign, encumber, or
otherwise transfer this Lease, or any right or interest in this
Lease or in the Premises or the improvements on the Premises,
without the prior written consent of Lessor, which consent may be
withheld in Lessor's sole discretion. If Lessee sublets,
assigns, encumbers, or otherwise transfers its rights or
interest. in this Lease or in the Premises or the improvements on
the Premises without the written consent of Lessor, Lessor may,
at its option, declare this Lease terminated. In the event
Lessor consents in writing _0 an assignment, sublease, or other
transfer of all or any of Lessee's rights under this Lease, the
assignee or sublessee must assume all of Lesseels obligations
under this Lease, and Lessee shall remain liable for every
obligation under the Lease.
Aa.iqnaent by L.s.or
14.02. Lessor may assign or transfer any or all of its
interests under the terms of this Lease.
AJlTICLB 15. _Y.l.~OIlKD'l'AL COHPLIAJlCB
15.01 Without limiting the generality of any
provisions set forth .lsewhere in this Leas., Lessee agree. as
follow.:
(a) Les.e. .hall not (either with or without
neglig.nc.) cau.. or permit the escap., dispo.al or r.lea.. of
any Hazardous Substanc.., as hereinafter defin.d, on, in or und.r
the Premi.... Les... .hall not allow the storag. or u.. of .uch
.Ub.tanc.. in any manner not .anction.d by law or by the high..t
.tandards pr.vailing in the industry for the .torag. and u.. of
.uch .ub.tanc.s, nor allow to be brought onto the Premi... any
.uch .Ub.tanc.s exc.pt to u.. in the ordinary cou=s. of Le....'.
bU.in..., and th.n only aft.r writt.n notic. i. giv.n to Le..or
of (1) the id.ntity of .uch .ub.tanc.., and (2) the ..thod for
pr.v.nting the .scape of any .uch .ubstanc.., and Las.or'. prior
writt.n approval i. grant.d. Le.... cov.nants and agr... that
the Premis.. will, at all ti... durinq its u.. or occupancy
ther.of, be k.pt and maintained .0 a. to comply with all nov
exi.ting or h.r.att.r .nacted or i..ued .tatut.., lava, rul..,
ordinanc.., order., pe1"1lits and r.qulations ot all stat.,
f.d.ral, local, and oth.r governm.ntal and requlatory
authoriti.., agenci.. and bodi.. applicabl. to the Pr..i...,
pertaini"9 to environaental ..Uers, or requlat1nv, probibit11\9
11
or otherwise having to do with Hazardous Substances and all other
toxic, or hazardous wastes (collectively called "Environmental
Laws"). Lessee shall execute affidavits, representations and the
like from time to time a~ Lessor's request concerning Lessee's
best knowledge and belief without limiting any of the obligations
of Lessee under the provisions set forth in this Lease. Lessee
agrees to clean up all spills and discharges of Hazardous
Substances on the Premises in a manner which shall comply with
all applicable environmental laws. Lessee shall notify Lessor in
writing of all such incidents.
(b) Lessee shall immediately deliver to Lessor a copy
of any summons, citation, directive, notice, complaint, letter or
other communication from any federal, state or local
environmental agency, concerning any alleged violations of any
environmental laws or regulations on the Premises, or concerning
any investigation or request for information relating to the use,
generation, handling, treatment, storage or disposal of Hazardous
Substances in connection with the Premises.
, (c) Upon request, Lessee shall cooperate in obtaining
evidence of compliance with any environmental law, regulation,
order of any governmental authority, which cooperation may
includ., without limitation, providing affidavits, reports or
response. to questions. Lessee shall provide access to the
premise., upon r.que.t, for inspections and testing of the
Premises regarding the presence of Hazardou. Substances.
(d) Lessor and its engineers, technicians, and consul-
tants (collectively the "Auditors") may, from time to time a.
Lessor d.ems appropriat., conduct periodic t.sts and examinations
("Audits") of the Premises to confirm and monitor Lesse.'.
complianc. with the Leas.. Such Audit. shall be conducted in
.uch a manner a. to minimize the interference with Le.....s
permitted activiti.. on the premi.es; how.v.r, in all cas.s, the
Audit. .hall be of .uch nature and .cop. a. shall be r.a.onably
r.quired by th.n .xi.ting t.chnology to confirm Le......
complianc. with this Leas.. Less.. .hall fully coop.rate with
Le..or and ita Auditor. in the conduct of .uch Audit..
(.) Le...e .hall indemnify, d.fend and hold Lessor,
ita partn.r., affiliat.., parent., officer., dir.ctor. and em-
ploy..., and other occupant. of the Premi... (coll.ctiv.ly,
the .Indemnit....), fr.., harmle.. and indemnified from any
.xpen.... penalti.., fin.., claias, demand.. liabiliti.., co.t..
per.onal injuri.., property daaag.. action. and cau... of action,
.uit., deba. judg1aent., demands or charq.. What.oev.r which the
Indemnit... .hall or ..y incur. or which any such party would
oth.rwis. incur, by rea.on of Le...... failur. to coap y with
l'
this Lease including, but not limited to: (i) the cost of
bringing the Premises into compliance with all laws; (ii) the
reasonable cost of all appropriate tests and examinations of the
Premises to confirm that the Premises has been brought into
compliance with all laws; and (iii) the reasonable fees and
expenses of the Indemnitees' attorneys, engineers, and
consultants incurred by the Indemnitees in enforcing and
confirming compliance with this Lease.
(f) The covenants contained in this Article shall
survive the expiration or termination of this Lease, and shall
continue for so long as Lessor and its successors and assigns,
and the Indemnitees, may be subject to any expenses, obligations,
penalties, fines, claims, demands, liabilities, costs, personal
injuries, property damage, actions and causes of action, suits,
debts, judgments, demands or charges whatsoever against which
Lessee has agreed to indemnity the Indemnitees under this Lease.
(g) All terms, except as otherwise defined herein,
shall have the meanings as set forth in the Lease. For purposes
hereof, Hazardous Substances shall mean (i) any "Hazardous
Substance", "Pollutant" or "Contaminant" (as defined in Section
101(14) and (33) of the Comprehensive Environmental Response and
Compensation and Liability Act ("CERCLA"), 42 U.S.C.A. section
9601(14) and (33)) or 40 C.F.R. Part 302; (ii) any hazardous
substance, hazardous waste or solid waste, as those terms are
defined in applicable state or local law; (iii) any substances
containing petroleum as that term is defined in Section 9001(8)
of the Resource Conservation and Recovery Act, as amended, 42
U.S.C.A. Section 6991(8) or 40 C.F.R. 280.1; or (iv) any other
substance for which any governmental entity requires special
handling in its collection, storage, treatment or disposal.
(h) Le.sor represents and warrants that, to the best
Of Le..or'. Itnowledgel
(1) No notice has been given to Lessor, by any
governmental authority or any person claiming any violation of,
or requiring compliance with, any federal, stata or local
statute, ordinance, regulation or other raquir_ent of an
Itnvironaental LaV, or d...ndinq r_ediation ot or payment of
contribution tor any environaantal contamination or any damaga.
attributable thereto;
(2) There are no underground storage tanks or saptic
srst..., located at the Preais..;
(3) No inveatiqation, adainistrative ordar, con.ent
order, lien, superlien or .gr....nt, litigation or .ettl...nt
with rulMlCt to any Ilalardoua SUbstance of anI kind located on,
&beNt or under .U or any portion of the Prell ... exists, 18
pend1l'lCJ. pcopotled, tbrutened or atltic1p.ted.
n
(i) Lessor shall defend, indemnify and hold Lessee
harmless from and against any liability, loss, damage, costs and
expense suffered, incurred or threatened as a result of any
breach of any representation or warranty hereunder or as a result
of notice, complaint, claim, demand, suit, order, judgment or any
legal requirement, including without limitation of the generality
of the foregoing, court costs, attorney's and consultant's fees,
environmental clean-up costs, natural resources damages, fines,
penalties and damages to persons, personal property, real
property and business enterprises, arising out of or relating to
an environmental condition on the Premises caused by Lessor.
ARTICLB 16. RULES AND REGULATIONS
16.01 Lessor shall have the right to make reasonable
rules and regulations for the purpose of ensuring or enhancing
the safety, care, cleanliness, maintenance, or preservation of
the Premises and common areas, as well as for the purpose of
preserving good order in and on the Premises and common areas.
(specifically including but not limited to the allocation and
identification of parking spaces among tenants.) Lessee and its
officers, employees, agents, and invitees agree to be bound by
any such rules and regulations on receipt by lessee of written
notice from Lessor setting forth same, and any changes, additions
and/or deletions. Lessee shall be responsible for the compliance
of its officer., employees, and invitee. with all such rules and
regulations.
ARTICLB 17. CONJ)I'l'IOB PUCEDEN'1'
17.01 This Lease is expressly conditioned upon the
acquisition of fee simple title to the premises by Lessor. Should
such settlement not occur for any reason, Lessor shall return all
said rent payments to Lessee, and neither party shall have any
liability to the other hereunder.
AR'l'ICLB 18. Ja8('ft.T.~U8
18.01 All notices required under this Lease shall be
effectively given only if by certified mail, registered mail, or
nationally recognized overniqht courier service, addre.sed to the
proper party, .t the followinq .ddre....:
Lessor
Paul L. Ito.tick
41 C.orqe Circle
M.cbanIcaburq, PA 17055
W. Scott Staruch, Esquire
20 Irfotd Road. SuIte 21.
~yn.. PA 1704'
with. copy tOI,
21
Lessee
Francesco Failla
663 wyndamere Road
Lewisberry, PA 17339
with a copy to:
Either party may change the address to which notices
are to be sent by giving the other party notice of the new
address in the manner provided in this Section.
parti.s Bound
18.02. This Leas. shall be binding on, and inure to
the benefit of, the parties to the Lease and their respective
heirs, .xecutors, administrators, legal representatives,
successors, and assigns when permitted by this Lease.
PelUl8Y1VlUlia Law to Apply
18.03 This agreement shall be governed by and
construed under the laws of the Commonwealth of Pennsylvania.
Legal construction
18.04 In the event anyone or more of the provisions
contained in this agre..ent ahall tor any reason be held by a
court ot comp.tent jurisdiction to be invalid, illeqal, or
un.ntorc.abl. in any respect, such invalidity, ill.gality, or
unentorcubllity shall not attect any other provision ot the
agr.ement, .nd thb agr....nt shall be constru.d .s it the
invalid, ill.qal, or un.ntorc.abl. provision had n.ver be.n
included in this .gr....nt.
Prior &gr...enu SUpers.eld
18.05 Thi. Laas. constitut.s the only .gr....nt
between the Le.sor .nd Leas.. and super.edes any prior
understandin9s or writt.n or oral agr....nu betwe.n the partie.
r.spectin9 the subject aatt.r of this Leas..
Menaent
18.06 No aaendaent, aodification, or alteration of the
teraa of thb Lees. shall be bindi", un1... it 18 in writin9,
dated .ubII.ent to the dau of thia Lus., and duly lIftC\Ited bf
the Leaaor and Le.....
2J
Attorneys' Pees and Costs
18.07 In the event that at any time during the term of
this Lease either Lessor or Lessee shall institute any action or
proceeding against the other relating to the provisions of this
Lease or any default of this Lease, then the unsuccessful party
shall reimburse the successful party for reasonable attorneys'
fees and expenses incurred to enforce the Lease,
Unavoidable Delay
18.08 Except for the payment of rent, utility charges,
and other sums of money to be paid under this Lease, neither
Lessor nor Lessee shall be required to perform any term,
condition, or covenant in this Lease so long as such performance
is hindered or prevented by unavoidable delays. For purposes of
this Section, unavoidable delays shall be defined as natural
disasters; strikes, lockouts, or labor disputes; governmental
regulations, restrictions, or controls; enemy or hostile
government action; civil riots; fire, floods, or nuclear
accident; or any other cause not reasonably within the control of
Lessor or Lessee and that by the exercise of due diligence Lessor
or Lessee is unable, wholly or in part, to prevent or overcome.
Time of Bssence
18.09 Time is of the essence of this agreement.
QUiet EnjoJllent
18.10 Lessee, upon paying the rent and upon ob.erving
and keeping the covenants, agreements and conditions of this
Lea.a on it. part to be performed, shall quietly have and enjoy
the Premi.e. during the tera of this Lease without hindrance or
mola.tation by Lessor or by anyone claiming through or under
Lessor, subject to the terms, covenant., conditions and
excaption. herain contained, and subject a180 to any restric-
tions, easements or other agreement. of record. This covenant i.
given in lieu of any implied covenant of quiet enjoyment.
.alation.hip of Parties
18.11 Tha relationship between the parties hereto
shall be that of Laasor and La.... and nothiJ1C) contained herein
shall be construed to changa or BOdify that relationship so a. to
make Les.or and Les.ee partner., joint venturers, or debtor and
creditor.
:n
Requirements of Public Authoritie.
18.12 Lessee will promptly and faithfully comply with,
conform to, and obey all present and future laws, ordinances,
rules, regulations and requirements of every duly constituted
governmental authority or agency having jurisdiction over Lessee
and/or the Premises or any part thereof.
B.toppel certificate
18.13 Lessee agrees to execute and deliver to any
mortgagee or purchaser of the Premises, immediately upon request,
an "estoppel certificate" stating the amount of rent due from
Lessee hereunder, that this Lease remains in full force and
effect without modification, and that Lessee has no set-offs
against rent; or, if this Lease has been modified, or if Lessee
has any set-offs against rent, the exact nature of the
modifications and the precise amount of the set-offs.
Ro Brokers
18.14 Lessee represents and warrants to Lessor that
Lessee has had no dealings, negotiations or consultations with
respect to the Premises or this transaction with any broker or
intermediary and that no broker or intermediary called the
Premises to Lessee'. attention for lease or took any part in any
dealing., negotiations or consultation. with respect to the
Premises or this Lease. In the event that any broker or
intermediary claims to have subaitted the Premises to Lessee, to
have induced Lessee to lease the Pr8lllise. or to have taken part
in any dealings, negotiations or consultations with respect to
the Premis.. or this Leas., Lessee will be responsible for and
will indemnifY, defend and save Lessor harmless from and against
any co.t., fe.. (inclUding without limitation, attorney'. fees),
expenses, liabilitie., and claims incurred or suffered by Lessor
as a result thereof.
JIortVaq..
18.15 Le.... accepts this Leas. subject to any deed.
of tru.t, .ecurity inter..ts. or mortgage. that might now or
later constitute a li811 on the Premi.... Le.... sust. on d8lUlnd.
execute any inst:ruaents, rel...... or other docuaents that are
required by any aortgagee for the purpo.e ot subjecting and
8Ullordinatlng thi. lAaH to the Uen ot any such deed of trust,
.ecurity intere.t, or IIOrtga98 constituting a lien on the
Preai....
)4
. .
Parties Bound
18.16 Subject to the provisions of Article 14 hereof,
this Lease shall be binding upon the parties hereto and shall be
binding upon the inure to the benefit of and be enforceable by
their respective successors and assigns. This Lease is expressly
conditioned upon the approval of its terms and conditions by
Lessor's mortgagee, Dauphin Deposit Bank and Trust company, of
Harrisburg, Pennsylvania. Lessee agrees to execute a consent to
the Assignment of Leases executed between Lessor and its said
mortgagee.
waiver of custom
18.17 Lessor shall have the right at all times, any
law, usage or custom notwithstanding, to enforce strictly the
provisions of this Lease, and the failure of Lessor at any time
or times strictly to enforce any provision hereof shall not be
construed as having created a custom or waiver in any way
contrary to the specific provisions of this Lease or as having in
any way or manner modified this Lease.
certain H.anings; Liaitation of Liuility
18.18 (a) The word "Lessee" as used in this Leas.
shall be construed to mean tenants in all cases where there i.
more than on. tenant (and in .uch case the liuility of such
tenanta .hall be joint and several), and the necessary
grammatical change. required to make the provision. hereof apply
to corporation, partnerShip. or individuals, men or women, shall
in all ca.e. be assumed as though in each case fully expressed.
Each provi.ion hereof shall extend to and shall, a. the ca.e may
require, bind and inure to the benefit of Le..ee and ita
.ucc..sors and as.igns, provided that this Lea.. shall not inure
to the benefit of any assigne. or successor of Les.e. except upon
the express written consent of Lessor a. herein provid.d.
(b) Th. term "Les.or" a. used in this Leas. means the
fe. owner of the Premis... In the event of the voluntary or
involuntary tran.fer of .uch own.rship or right to a .ucces.or in
interest of Les.or, Les.or .hall be freed and r.li.v.d of all
liability and obligation hereunder which shall thereafter accru.
and Le.... .hall look .olely to such .ucce..or in intere.t for
the performance of the covenant. and obligations of the Le..or
her.under which .hall ther.after accrue. Th. liability of Les.or
and ita .ucc...or. in inter..t, under or with r..pect to thi.
Lea.e, .hall be strictly liaited to and enforceable only out of
ita or th.ir inter..t in the Pruise. and th. tract of real
e.tate of which the Preais.. are a part. and shall not be
25
enforceable out of any other assets. No mortgagee or ground
lessor which shall succeed to the interest of Lessor hereunder
(either in terms of ownership or possessory rights) shall: (1)
be liable for any previous act or omission of a prior Lessor, (2)
be subject to any rental offsets or defenses against a prior
Lessor, (3) be bound by any amendment of this Lease made without
its written consent, or by payment by Lessee of rent in advance
in excess of one (1) month's rent, (4) be liable for any
security not actually received by it, or (5) be liable for any
initial construction of the improvements to be made to the
Premises or for any allowance or credit to Lessee for rent,
construction costa or other expenses. Subject to the foregoing,
the provisions bereof sball be binding upon and inure to the
benefit of the successors and assigns of Lessor.
captiou
18.19 The captions contained berein ere for the conve-
nience of the parties only. They do not in any way modify,
amplify, alter or give full notice of the provisions hereof.
~_~ck vsrV;
.~
v--
/<;
a
~:
// .,/
t,.....
Francesco
f:\wpwin\kostiCk2
26
.1 ..
_.:.-
~
~
,~
.~
19 F:'
C>>~ ~io
,yII e ,..
~: 0 ~
"
. ,
'I Q.
;)
III
M...
0...
....
4111I
-..""
SOCl\
-u;,
oil...
",J ..:llll_
.... 0...
C.! ... c ...
Co i :: 'C
-' Do .. 1II
U C ....
III
.. ....to
... ...
... o. 1II
(II CD _ _ II
a. ... _. III
u: a .!.!~
y
o .
Go
I
%, II
U .,
g I
Go ,
. III
" ~
t
I ~
.
0 ...
I
il I I
t (") .D ,-,
( -.I II
...
.. ,- ...
,: ; ,.,. r
- :.1 .;~
+- ~. .j
~. 0-"
~ t:. .... .,
-', [
! J - :<.)
~ .,
, .....
CV . . o- J
';po ~ , .n
.
~ , ::J :..J
~ ...;.
'f\
~~
~.
(1
)
PAUL L. KOSTICK t/a
PLK PROPERTIES,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
:
.
.
No.
.
.
:
VINCENZO MARCHIANO and
GUISEPPE RUSSO,
Defendants
Notice under Rule 2913.3 of Judgment
and Execution Thereon
Notice of Defendants' Rights
To: Vincenzo Marchiano and
Guiseppe Russo
A judgment for possession of real property has been
entered against you and in favor of the plaintiff without prior
notice and hearing based on a confession of judgment contained in
a lease allegedly executed by you. The court has issued and the
sheriff has served a writ of possession which directs the sheriff
to remove you from possession of the real property.
You may have legal rights to defeat the judgment or to
prevent your being relloved from the property or to regain
possession of the property if you have been removed, if you cSid not
voluntarily,
intelligently and knowingly
give
up your
constitutional right to notice and hearing prior to the entry of
judqwent or if you have defenses or other valid objections to the
judqllent. ANY PETITION SEEXINC RELIEF FROM THE JUDGMENT AND TO
REGAIN POSSESSION MUST BE FILED WITHIN THIRTY (30) DAYS AFTIR THE
DAT! ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSI YOUR
RIGHTS.
F \1\Fl11'1t\~1'1nl'i,m':I."\"Ji.1I1.lII'lI \" 1M
PAUL L. KOSTICK t/a
PLK PROPERTIES,
plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
.
.
v.
: No.
VINCENZO MARCHIANO and
GUISEPPE RUSSO,
Defendants
.
.
PETITION TO STRIKE JUDGMENT
REQUEST FOR PROMPT HEARING
I hereby certify that I did not voluntarily,
intelligently and knowingly give up my right to notice and hearing
prior to the entry of judqment. I petition the court to strike the
judgment on this ground and request a prompt hearing on this issue.
I verify that the statements made in this Request for
Hearing are true and correct. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. S 4904
relating to unsworn falsification to authorities.
Notice of the hearing should be given to me at
street Addre..
City, State
Telephone Nuaber
Dauch
Defendant (e)
f' \(""'~ \1lw>>."-!I'f'If:l.''''lUJlt'!l!tll " 1M
D
i
tll
(?
"t1
A.l (") U,J
c Q
- n ,:- _J
- ..0 -f:- :h -~..'"" r- oo
$= {I' C -
. ..-. '.01
. ~ ",.' - -
8 ~ ti .:'.:'" ~ ~g8
Ul ~ - !1,~,' -
(; L'\ Ol ;:",;: u,
'11 s.J ..-" . .
() -a. :( B ' ~..., ...... .h 1/)....
-a. rl ..,... ~...' ~~.~
0 U\ .. ~ _ I
J- 00 .-~. '.. :J uM '
. j- -a. .J ..
\.1\ ~~'. ':::I ...:i
Q... -' ~
. '0
c 1
~
~
PETER J. RUSSO, ESQUIRE
PA Supreme Court ID: 72897
61 West louther Street
Carlisle, PA 17013
(717) 249-2721
Attorney for Defendant Russo
PAUL L KOSTICK tie
PLK PROPERTIES,
PlaIntiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
v.
NO. 97-4452
.
.
V1NCENZO MARCHIANO and
GUISEPPE RUSSO,
o.randanta
.
.
.
.
Al'ID NEW _lTER
AND NOW, COMES o.t.ldant, Gulseppe Russo, by and through his atIomey,
PM J. Russo and answers Plaintifr's Complaint In ConfeIsion of Judgmft for
Ejectment and avers the following In support ~
t. kll\6ld.
2. Admitted.
3. MwtlhcL
4. Denied. Defendant lacks sufficient knowledge or information so as to form
a belief as to the truth or falsity of the averment in paragraph number four. By way of
further response, Defendant admits that attached to Plaintiff's complaint was a property
description and avers that said description is a written document which speaks for itself.
5. Denied as stated. Defendant lacks sufficient knowledge or information so
as to form a belief as to the truth or falsity of the averment in paragraph number five. By
way of further response. Exhibit B of Plaintiff's complaint appears to be a copy of a lease
executed by Francesco Failla but as a written document. said exhibit speaks for itself.
6. Denied as stated. Defendant lacks sufficient knowtedge or information so
as to form a belief as to the truth or falsity of the averments in paragraph number six.
By way of further response, Exhibit B of Plaintiff's complaint appears to be a copy of a
lease executed by Francesco Failla but as a written document, said exhibit speaks for
itself.
7. Denied as stated. The contents of the averments In paragraph number
....... are related to a written document which speaks for Itself and any lnterprWdional
gloss placed on said documant by PlaIntiff is denied.
8. DanIed. The ....-mants set forth in paragraph eight contain Itatements
which do not r.quire a response. In the evw1t any portion of the averm<<1ts in par1lgraph
eight .. dllfMd faetua~ 0 _blldant Ruuo IlIc:kI adllciellt ~ or lnformdcn 10
IS to farm a beW IS to the tnJth or falsity 01 the awrmant In pIlfIQfaph eIgtd.
9. Denied as stated. The averments set forth In paragraph nine contain
conclusions of law to which a response is not required. Additionally, the Lease Is a
written document which speaks for itself and any interpretational gloss placed on said
Lease by Plaintiff is denied.
10. Denied. The averments set forth in paragraph ten contain conclusions of
law to which a response is not required. In the event any portion of the averments in
paragraph ten are deemed factual. Defendant Russo denillS the allegation that he was
in default of the terms of the Lease by failing and refusing to make the monthly rent
payment in a timely manner as Plaintiff granted Defendant Russo an extension of time
in order to submit August's rent payment which extended beyond August 15, 1997, the
date which Defendant Russo attempted to remit the required rent payment to Plaintifl's
agwd. Seid paymn wu rejected by Plaintlfts agent prior to the initiation of any suit
11. DenIed. The averments set forth in paragreph eleven contain statements
which do not require a respclnSe.
12. Denied. The averments HI forth in peragraph tnt.. contain ....Tlenta
Whidt do not require a response.
13. AdI. dth.d.
14. Denied. The averments set forth in paragraph fourteen contain conclusions
of law to which a response is not required. By way of further response, Plaintiff failed
to comply with the provisions of the warrant of attorney as set forth in the lease
agreement. Additionally, the Lease is a written document which speaks for itself and any
interpretational gloss placed on said Lease by Plaintiff is denied.
WHEREFORE, Defendant demands a judgment dismissing this suit in his favor
and against Plaintiff.
NEW MAma
,. Defendant, Guiseppe Russo never signed a lease agreement with the
Plaintiff which contained a confession of judgment clause or warrant of attorney.
2. Defendant, Guiseppe Russo was, at an times relevant hereto, without benefit
of advice and direction from legal counsel.
3. At various times, including, but not timited to, August of 1997, Plaintiff
waived the rights provided in Article 2 of the subject Ieaae agreement by granting
Defendant Russo an extension of time in order to rwnit rent payments.
4. On August 15, 1997 at 1 :00 p.m. o.t.ndant remitted to the PIaintItf the sum
of One Thousand Two Hundred Fifty ($1,250.00) 00llIn, in lawful money of the UnIttd
StabII. which is the amcult d<<nanded in his ~
5. The remitted ~ on August 15. 1997 at 1:00 p.m. WIll ~ by
Pl.iltMr. agert HMn Wood
AFFIDAVIT OF GUISEP~I; RUSSO
The undersigned Affiant, being duly sworn according to law and possessed with
personal knowledge, information. and belief as to the matters set forth herein, hereby
deposes and says as follows:
1. I am a named defendant in Kostick v. Russo. et ai,
2. I operate La Fontana Restaurant in Lemoyne, Pennsylvania
3. My rent is generally due on the first of the month.
4. In past months, Paul Kostick has granted me more time to pay the rent if
I cannot on the first of the month.
5. In August of 1997. Paul Kostick agreed to give me additional time so that
I could pay August's rent.
6. Sometime at the end of the first week of August, Paul Kostick agreed that
I could pay the rent by the 20th of August.
7. At 1:00 p.m. on Monday, August 15. 1997. I tried to pay my rent to Helen
Wood.
S. She would not take the rent and told me that PIUI'I tawyer said she (;Q iJdn't
take the rtnl
9. I askad her to gIw me a note to show that I tried to pay the rW'It. I gave
that note to fff'/ Iaw/W
'0 Later I found out I was belrlQ sued bee... I dldr11 pay the rtnl
11. I came to this country from Italy several years ago and I started a family and
a business.
12. I have never been to school in the United States.
13. At times, I have difficulty with English, especially with large words and legal
tanns.
14. When I agreed to operate La Fontana I did not have a lawyer to represent
me. Everyone told me that I didn't need a lawyer.
15. I never knew that I gave up any rights when I took over the business.
16. No one ever explained to me that I gave up any rights when I took OYW the
business.
17. The foregoing statement, consisting of sixteen (16) numbered paragraphs,
having been made under penalty of law, is true and correct to the best of my knowledge.
information an belief.
This Aflidavit is made subject to the penalties of 18 Pa. C.S. S4904 relating to
unsworn falsification to authorities.
-
oc.: 'l....... 1av. &.~... 27. '997
..JJ l_
_c ~......'-&
ClII.., .. 1. ' ""0 III ..
..~ ~ONIft.'a_
,- .!' ,-
. ,
c -.
."
" ~
"_J
I
..
-'~
-,
GLLIHpfL ~t..loS 0
~ .).. () J?2 ad~.. ct- S"'-I R.I f -J-.
J..t_rnoYAJ (, PA l?dlJ
0 \0 0
<:: .... "
?
-Ct":' !: --I
r..,--: :i \::'l
,;:. ~ :-... ...
~. ~ t N -j~
(: -, N
-,
r;; :;-..
..^.." .,: )
,~" (: --,
,", g;; 'm
~:" ~
-J ~ ~
-. (l)
, "
.
.
~:: i ;; :j,;;;
,........'
,
3. The lease agreement which is the document which contains the warrant of
attorney was not executed by either Defendant in this matter.
4. The relevant lease agreement was executed by the Plaintiff and Francesco
Failla and Vincenzo Mazzamuto on or about November 19, 1993. A true and correct
copy of said lease agreement is attached hereto as Exhibit A.
5. Said lease agreement provides that Lessee shall pay Lessor One Thousand
One Hundred Fifty ($1.150.00) Dollars per month as rent.
6. On or about April 19, 1996. Defendants Russo and Marchiano signed a
Ietler which purported to allow Defendants Russo and Marchiano to assume the lease
signed by Francesco Failla and Vincenzo Mazzamuto. A true and correct copy of said
letter is attached hereto as Exhibit B.
7. At the time Defendant Russo assumed said lease agreement. he was
urnpresented by counsel. A true and correct copy of Defwldant Russo's Alfidavit is
attached heleto as Exhibit C.
8. 0tMndant Russo, a resident of the United States who was born In Italy and
who has nevw had any formal educ:ation within the United States, did not and could not
~ mq of the provisions of the subject lease agrMmeld, 1nc:Iuding, but not
Iirnited to the COt ,1..11on of judgmIIlll and WlImIf1t of ettor'n4ty tlel..... A true and correct
c::opy of Oetw ldflnt Rusao't M4hIt it atIaC:tIed ... eta as EJttWbIt C.
9. At 1:00 p.m. on August 15, 1997, Defendant Russo attempted to pay Helen
Wood, General Manager of PLK Properties, the rent which was due pursuant to the
subject lease agreement.
10. Said rental payment was refused by Plaintiff's agent. A true and correct
copy of a letter from Ms. Wood is attached hereto as Exhibit D.
11. Plaintiff filed the confession of judgment after Defendant Russo's attempt
to make the required rent payment.
12. Defendant, Guiseppe Russo did not voluntarily, intelligently and knowingly
give up his rights to notice and hearing prior to the entry of a judgment against him.
13. Defendant Russo's petition is timely, he has averred and produceclevidence
that would support a meritorious defense to the allegations raiSed by Plaintiff complaint
In Defendanrs Answer to Plaintiff's Complaint in Confession of Judgment for Ejection.
A true and correct copy of said pleading is attached hereto as Exhibit E.
14. Defendant Russo has been Informed by counsel and beUeves. and theJ8fore
lMI1l that the said warrant of attorney ia not sutficIent In law to II.lthorize the
prothonotary to enter the said judgment, ~. IS8 no judgment was COl'lfesMd In h
said warrant and b--IMIt contains no warrant tot an atlooney at law or other 1*10I.
to confesa judgment IUI'IIcHlnt In law.
K08TICX/I'RUCZSCO J'AILU LEUZ
TULZ 01' CCDlTD'l'S
ARTICLE 1. TERM . . . . . . . . . . . . . . . . . 1
ARTICLE 2. REH'l' . . . . . . . . . . . . . . . . . 2
ARTICLE 3. USE OF PREMISES. . . . . . . . . . . . 3
ARTICLE 4. REPAIRS AND MAINTENANCE. . . . . . . . 4
ARTICLE 5. tJ'l'ILI'l'J:ES AND TAXES. . . . . . . . . . 5
ARTICLE 6. AL'l'ERA'l'J:ONS, ADDITIONS, AND
IMPROVEMENTS . . . . . . . . . . . . 6
ARTICLE 7. TRADE FIXTtJRES AND SIGNS . . . . . . 7
ARTICLE B. HECBANJ:CS' LIENS . . . . . . . . . . . a
ARTICLE 9. INSURANCE AND INDEMNITY. . . . . . . . a
ARTICLE 10. DAKAGE OR DESTRUCTION OF PREMISES. . . 10
ARTICLE 11. CONDEKNA'l'J:ON . . . . . . . . . . . . . 12
ARTICLE 12. EVEN"1'S OF DEFAULT. . . . . . . . . . . 13
ARTICLE 13. INSPECTION BY LESSOR . . . . . . . . . 17
ARTICLE 14. ASSIGHHENT AND SUBLEASE. . . . . . . . 11
ARTICLE 15. ENVDlORHEHTAL COHPLIAHCZ . . . . . . . 11
ARTICLE 16. RULES AND R!GULA'l'J:ONS. . . . . . . . . 21
ARTICLE 17. CONDITION PRECEDZIIT. . . . . . . . . . 21
ARTICLE 11. IIISCIIUHIOOS. . . . . . . . . . . . . 21
LEASE
This Lease is made and entered this 19th day of
November, 1993, between Paul L. Kostick, referred to in this
Lease as Lessor, and Francesco Failla, referred to in this Lease
as Lesse..
In consideration of the mutual covenants and agreements
set forth in this Lease, and other good and valuable
consideration, Lessor leases to Lessee, and Lessee leases from
Lessor, retail space at the west end of 420 Market Street,
Borough of Lemoyne, cumberland County, Pennsylvania, and more
particularly described on Exhibit A attached to this Lease, and
referred to herein as the Premises.
ARTICLE 1. 'l'DH
Term of L....
1.01 'I'he "Commencement Date" of the term of this Lease
shall be the later of DeCember 1, 1993 or the date when the
Premises and the improvements required to be constructed by
Lessor under Paragraph 6.01 hereof shall have been Substantially
completed; provided that if Lessee shall take possession of the
Premises or any portion thereof prior to either of the foregoing
dates, then the COlIIlDencement Date shall be the date on which
Le.see takes such possession. Unless sooner terminated in
accordance with the terms hereof, the term of this Lea.e shall
end without the necessity for notice frOlll either party to the
other at 12:01 a.m. local time on the third (3rd) anniversary of
the first day of the first full calendar month during the term
(her.in called the "Expiration Date").
When the date of commenc8Jllent of the term of this l.a..
i. establish.d, Le..or and Lea.ee shall prOlllptly ex.cute a
lIemorandua acknowledqinq aUle.
OptiOD to ~8D4 'fUa
1.02 Le.... ha. the riqht to ext.nd this Lea.e beyond
the expiration date provided in Section 1.01 on the followinq
teras and conditions:
(a) Should Le.... fully perform all of the teras and
conditions of this Lea.., Le.... may .xt.nd the tera of thia
Lea.. for a period of three (3) y.ar., with the extend.d tera to
be9in on the day following the expiration date of the Leu. tera
.pecified in Section 1.01. However, if at the date of expiration
of the Oriqlnsl ten Le.... i. in d.fault beyond any qrac. period
provided in thi. Lea.. for the performance of any of
1
the terms or provisions of this Lease, or any event has occurred
which with the giving of notice or passage of time or both could
constitute a default under this Lease, Lessee's exercise of any
option exercised and shall b. null and void. All of the terms,
covenant., and provision. of this Lease shall apply to all
ext.nd.d Leas. tarma except that the rent for each such extended
term shall be adjUsted as set forth in Section 2.01 hereof.
(b) Le.... may exerci.. each option to extend this
Leas. by giving to Lessor notic. of its intention to do so not
later than six (6) months prior to the expiration of the initial
Leas. term. To constitut. .ff.ctiv. notic. of an intention of
.xercis. an option under this Laas., the notic. must be s.nt by
certifi.d or r.gister.d mail or nationally recognized overnight
courier to Lessor at the addres. and in accordance with the
procedures provided in S.ction 16.01 of this Lease and must be
postmark.d no later than the date provided in thi. Articl. for
Le....'. exerci.. of the option.
Holdover
1.03 If Le.... holds over and wrongtully continue. in
Pos....ion ot the Prud..s atter expiration ot the term of this
Lea.. or any extension ot that term, Les... will be d....d to be
occupyinq the Prud... at .utteranc. frOll month-to-month t.nancy,
without limitation on any of Le.sor's rights or remedies
her.under and .ubj.ct to all of the t.rms and conditions of this
Leas., except that the fixed rent .hall be incr.as.d to twice the
fixed rent paYable for the last month of the term of this Laase
prior to the holdover.
DellVV7 of PO....sioa
1.04 If Le..or i. unabl. to deliVer actual po.....ion
of the l....d Preai... on the commencem.nt date of the t.rm for
any r.a.on beyond Las.or'. control, inClUding without limitation,
becau.. the building has not be.n .Ufficiently complet.d to make
the Preai... r.ady tor occupancy, or if r.pair. or improvement.
to be perfOrmed by 1...01', are not COllpl.t.d becau.. of the
hold1nq over of . pr.vioW! occupant, the Le.sor sball not be
liable in daaag.. to the Le...., and during the period that the
l...or i. unable to give po.....ion, no rent .hall accru.. No
.uch failure to give po.....ion lIball in any other r..pect aff.ct
the validity of thia 1.... or any Obligation of Le.... ber.under.
AaUCLI I. Uft
rUed aut
:1.01 Las... avreu to pay to Le..or the .U11 of One
'1'bousand One RundrecI rifty ($1,150.00) Dollars per aonth in
:I
advance on or before the first day of each month, throughout the
term of this Lease as the fixed rent. The first llnd last monthly
rent installments shall be paid at the signing of this Lease.
Rent for any fractional month at the beginning of the Lease term
shall be prorat.d on a per diem basis.
At the conclusion of the third full Lease year and
every Lea.. y.ar th.reafter, should the Lease term be extended,
the fix.d rent for the Premises shall be adjusted annually,
provid.d that the fixed rent shall never be less than One
Thousand One Hundred Fifty ($1,150.00) Dollars per month, by
applying fluctuations in the Consumer Price Index as follows:
(a) 'l'b. Consumer Pric. Index for the purposes of this
Leas. shall be the Consumer Price Index for All Items for All
Urban Consumers (unadjusted), published by the Bureau of Labor
statistics of the Unit.d States Department of Labor. For All
Items, 1982-100. If the Consumer Price Index ceases to be
published by the United States Department of Labor, Bureau of
Stati.tics, then the calculation shall be baaed on the closest
.ucce.sor index aa identified by the United States Department of
Labor. If no such succes.or exists, the calculation shall be
based on an index that is mutually aqre.d betw.en Lessor and
Lea....
(b) 'l'b. Bas. Oat. shall be the month of october, 1993.
(e) 'l'be adjust.d rent shall be determin.d by
multiplying the fix.d rent by a fraction, the num.rator of which
ahall be the Consumer Pric. Index for October of the third full
Leas. y.ar and of each Leas. y.ar th.r.after (th. "Comparison
Date"), u the case may be, and the denominator of which shall be
the COn&wlar Price Index for the Bas. Date. The resulting sum,
it qr.ater than the fixed rent, shall be the adjust.d rent
payable monthly for the following Leu. year.
MrlCU 3. VII 01' HIla...
,ami 1:t:lId V..
3.01 La.... may us. the Premis.s to operate and
conduct a rutllurant and taIt.-out busin.s., and tor no other
purpos., but in any event only in complianc. with any applicabl.
law., rul.., requlatlons, statut.. and applicabl. ordinanc.. now
or hereafter in .ffect. Le.... is responsible to procur. all
licena.., peraita and approvala required to conduct ita bwline..
on the Prai.... Le.......y not us. the Preai... for any other
purpoae without the prior written consent of Les.or which consent
uy be vl\:bbeld tor eny rea.on or no reason, in the sol.
di.cret1on of T ",,,or.
3
...t., Hui.ano., or Ill.gal D...
3.02 Le..e. shall not use or permit the us. of the
Premises in any manner that results in waste of the Premises or
constitute. a nuisance or violate. any statute, ordinance, rule,
or regulation applicable to the Premises or for any illegal
purpoae. Laaase, at its aole cost, shall comply, and causs ita
Officers, employ.e., agents and invitees to comply with all
applicable laws, Ordinances, rules or regulations or any other
requiremant of any duly constituted public authority having
juriSdiction over the Premis.. or the use of the Premises,
inclUding, without limitation, the provisions of the Americans
with Diaabilities Act.
UTICLJ: .. 1lBP,UJlB un KAIH'l'DUlCB
a.pair. aDd JlaiAt8D&Jlo. by Le....
..01 Le.a.. acknowledges and agrees that Lea see is
familiar with and has inspected the Premiaes, and has apprised
it.elf about the surrounding properties and neighborhood, the
availability or unavailability of public water and sewer or other
utility .ervice to the Premises, and the zoning and other
requiremen1:ll applicable to the Premises, and that, except for the
atructural improv8II\8n1:ll idantified in Section 6.01 to made by
Le..or, the Premi.e. i. being leased in it. "a. is" .wher. i..
condition without any r.pr.s.ntation by or on behalt ot Les.or
Concarning the Premi._.
· .02 Le.s.. shall, throughout the term ot this Leas.
and any extensions of that t.rm, at its own expense and ri.k,
maintain the lea..d Premi... in good order and condition,
inclUding but not limit.d to, making all r.pairs and
replacement., ren.wal. and addition., interior and exterior,
ordinary and extraordinary, toreseen and untoreseen, nece..ary to
ke.p and maintain the Premises and all syste.., equip..nt and
apparatus appurtenant thereto or u.ed in connection ther.with and
improvements (inclUding HVAC and glass) in good order and
condition. All maintenance, repairs, and replace.ents required
by this Article must be performed pro.ptly when required and in a
manner that will not CAuse depreciation in the value of the
Preai.... La.a.e shall return the Premises to Le.sor in .uch
good order and condition at the expiration ot the term hereot,
ordinary wear and t.ar exc.pted. Any repair., replacements,
renewal. and additions and any labor performed or materials
turniabed in, on or about the Premises shall be perforaed and
turniabed in .trict coapliance with all applicable lava,
regulations, ordinanc_ and requiraaenta of all duly constituted
aunicipal authoritie. or other 90vernaental bodi_ havinv
4
jurisdiction over the Premises. PROVIDED, NEVERTHELESS, that
Lessor shall make all necessary structural and roof repairs
required during the term of this Lease, and shall maintain the
parking lot and sidewalk.
4.03 In the event Lessee fails to perform its
Obligation to repair, replace, or maintain as set forth in
S.ction 4.02, after a reasonable time after notice from Lessor of
the need for such repair, replacement, or maintenance, Lessor may
enter the Premises and make such repairs or replacements, or
p.rform such maintenance or cause such repairs or replacements to
be made or maintenance to be performed, at its own expense. Upon
Lessor's notice to Lessee of the performance ~nd cost of any
maintenanc., repairs, or replacements, Lessee shall immediately
reimburse Lessor for any reasonable costs incurred by Lessor,
together with interest on any such sum at 1 1/2' per month from
the date of the notice until the date paid by Lessee to Lessor.
AR'1'ICLE 5. UTILI'1'IES AHJ) '1'AUS
Utility Charg..
5.01 Less.e shall pay all utility charqes for water,
electricity, heat, gas, steam, telephone and all other services
or utilities uS.d in and about the l.ased Premises during the
term of the Lea... '1'he Les.ee shall pay all such charge.
dir.ctly to the utility company or municipality furnishing the
.ervic., before the charges shall become d.linquent, or shall
r.imburse Le.sor the cost thereof, in the event Lessor chooses to
furni.h .ame, a. Lessor may direct.
caarbeq. Raoval
5.02 Lease. shall be responsible for and shall pay for
the r..oval of all garbage and rubbish from the l.as.d Premise.
during the term of the Lea...
Per.oual proparty '1'as..
5.03 Le.... shall be liable for all taxes l.vi.d or
......ed again.t personal property, furnitur., or fixture. placed
by Le.... in or on the Premi.... If any .uch tax.s for which
Le.... i. liable are l.vi.d or ......ed again.t Le..or or
Le..or'. property, and if Le..or el.cts to pay the., or if the
......ed value Of Le..or'. property is incr.a.ed by inclusion of
personal property, furniture, or fixture. plac.d by 1..... in the
Praai..., and Le..or .l.ct. to pay the tax.. ba..d on .uch
increa.., Le.... shall pay to Le..or on demand that part of the
tax.. for ~1ch 1..... is priaarlly liable Under this Articl..
5
'.
a..l Property Tax.. IlDd A.......lSt.
5.04 Le..or shall pay and tully di.charg. all r.al
property tax.. andl a.....m.nt. impo..d on the lea.ed Premi...
during the term ot this Lea...
aut Tax; 0.. aDd OOOUPIlDO}' Tax
5.05 It, during the term ot this Lea.. or any r.n.wal
or ext.nsion ther.ot, any tax i. impo.ed upon the privilege ot
r.nting or occupying the Premi.e. or upon the amount ot rental.
coll.ct.d ther.tore, Le.... will pay each month, a. additional
r.nt, a .um equal to .uch tax or charg. that i. impo..d tor such
month, but nothing her. in .hall be taken to require Le.... to pay
any incOJll., ..tate, inheritance or tranchise tax imposed upon
Le..or .
UTICLZ I. AL~TIOIfS, ADDITIOIfS, AIm IJaIaOVZImJr.rs
~t ot Prea.f....
6.01 Les.or .hall lIl8ke the following improvement. to
the Prai...: Vanilla box only.
Couut of Lea.or
6.02 Le.... shall not 1Il8k. any alteration., adc1itions
or iaprovuent. to the l.a..d Prais.. without the prior written
consent of Leasor. Cons.nt for nonstructural alteration.,
additiona, or improv..enta shall not be unreasonably withheld by
Le..or, provid.d .uch non-.tructural alt.rations, addition. or
~ta ahall not adv.r..ly aff.ct the .tructural .oundn...
of the Prai... or reduce the value of any exi.ting .tructur. or
iaprovuent.
>>ro~ of La..or
6.03 All alterations, addition., or ilIprovuenta
llacla by Le.... &hall beCOll8 the property ot Leasor at the
terain&tion of this Lea... Le..or IlaY, how.ver, require that
Leaa.. rSllOV. any or all alterations, additions, and ilIprov...nta
installed or llad. by Le.... on termination of the Lea... In tha
eVent that Leasor requir.. Le.... to reao~ .uch .lterationa,
adc1it.lona, or iaprovuenta, Lea... .hall repair any daaag. or
injury to the Prai... cauaed by .uch raaoval.
6.04 Lea.or, at ita option, IlaY in any ce.. in Which
ita con.aent i. required punuant to Section 6.02 hereot requ1n
Lea... to turni&h it with capi.. ot the applicabl. Plana and
llpeCj.ticationa and any releVant contract betvun Lea... and any
,
contractor or supplier. Lessor may also require, at its option
and as a condition precedent to qiving any approval, (i) a
performance bond and a labor and material payment bond, both in
form and .Ub.tance satisfactory to Le..or, given by an
independent financially re.ponsibl. corporat. .urety, to as.ur.
compl.tion of the work in accordance with the plana and
.p.cifications, free of lien., and (ii) evidence that each
contractor has adequate workmen's compen.ation insuranc. and
general liability insurance with unimpaired limits of at least
$1,000,000 for injury to anyone person or injuries in anyone
occurrence and property damage of $500,000, together with a
certificate from the in.urer to the effect that such insurance
may not be canceled or sUbstantially modified without at least 30
clay. prior written notic. to Len.or.
UTICWI 7. 'nW)J: J'IrJ.'URU ~ 8Ial
'l'rad. I'~ur.s
7.01 Le.... has the riqht at all tim.s to erect or
install &b.lv.., bins, machinery, equipment, or other trade
fixtures in, on, or about the l.as.d Premis.., provided that
Le.... complies with all applicabl. governmental laws,
ordinances, and regulations regardinq .uch fixtures. Lessee has
the right to remove all trade fixtures at the termination of this
Leu., provided Le.... is not in default under the Lease and that
the fixtur.. can be removed without structural damage to the
building. Le.... must r.pair and r..tore any damage or injury to
the builcUng, .tructures and improvem.nts now or her.after
er.cted on the Premi... cau..d by in.tallation or removal of
trade fixtur.., and all .uch r.pair. must be compl.t.d prior to
the termination of the Leas.. Any trade fixture. that have not
been removed by Le.... at the termination of this Lea.. .hall be
d.eaed abandon.d by the Le.... and .hall automatically beco.. the
property of Le..or. In the .vent any trade f ixtur. in.tall.d by
Le.... i. abandon.d at the termination of the Lea.., Lea... must
pay Le..or any r.a.Onabl. expena. actually incurred by Le..or to
remOVe the fixture from the Premis.., provid.d the fixture is
remov.d prior to the entrance of any .ubsequ.nt Le.... onto the
Preabes.
.igu
7.02 Le.... aay not inatall any .i9l1 or about the
lea.ed Prai.es without first obtainill9 the written approval of
Laasor vith Z'89ard to the .ia., type, &bape, desi9l1, color,
uterial, content, and aathod of attacbaent of the a1qn.
Luaor '. approval aball not be unreaaonably vi thhelcl. IA....
1Wat, at ita sol. upenae, ruova any aiqna inatalled on or about
,
the leased Premises by Lessee and repair any damage done to the
leased Premises or the building in which the leased Premises are
located or the land surrounding the leased Premises by the
installation or removal of the signs. This removal and repair
must be completed not later than the termination date of this
Lease.
U~ICI.I 8. HJ:CDHIC8' LIBIIS
8.01 Lessee shall promptly pay any contractors and
materialmen who supply labor, work or materials to Lessee at the
Premis_ or the BUilding ao aa to avoid the possibility of a lien
attaching to the Premises. Lessee will not permit any mechanic's
lien or liens to be placed on the Premises or improvements on the
Premises. If a mechanic's lien is filed on the Premises or on
improvements on the leased Premises, Lessee will promptly cause
it to be discharged of record by payment, deposit, bond, order of
court or otherwise or will pay the lien. If default in payment
of the lien continues of record for twenty days after written
notice from Lessor to Lessee, Lessor may, at its option, pay the
lien or any portion of it without inquiry as to its validity.
Any amounts paid by the Lessor to remove a mechanic's lien caused
to be filed against the Premises or improvements on the Premises
by Less.., including exp.ns.s and int.rest, shall be due from
Le.... to Le..or and shall be repaid to Lessor immediately on
r.ceipt ot notice, together with interest at the rate of 18' per
annwa from the date Le..or paid to remove such li.n until the
date Le..e. repays Les.or. Nothing in this Lease i. intend.d to
authorize Les.ee to do or cause any work or labor to be done or
any materials to be supplied for the account of Lessor, all of
the .... to be solely for Le..ee's account and at Le...... ri.k
and expens.. Throughout this Lease the term "mechanic'a lien" is
used to include any li.n, encumbrance or charge l.vied or impos.d
upon the Premis.. or any inter.st th.r.in or income th.r.trom on
account ot any mechanic'., labor.rs or mat.rialman'. lien or
claim or ari.ing out of any debt or liability to or any claim or
deaand ot any contractor, .echanic, .upplier, materialJDan or
laborer .
U'l'ICLJI ,. IDUJtUCJ: UID D1DDDII'1'Y
L.t.U1l1 tJ IlUIuraaae
t.Ol Lu..., at ita OVll expen.., lIbaU provide and
IlAintain in force during the tera of this Leas., comprehensive
general Uahil! ty inaurance protecting L...or and Leas.. against
injury or :;=ye to any person or property occurring in, on or
about the ... or any .id.walks, drivevaya, parkiftCJ lot. or
othar aru. appurt.nant to the Prube.. Such in.urance lIball be
ill the aaount of at lean $1,000,000 aiftCJle liait for injury to
.
anyone person or injuries in anyone occurrence, and $500,000
for property damage, unimpaired. Such policies shall name Lessor
and Lessee a. insureds. Thi. insurance is to be carried by one
or more insurance companies authorized to do business in
P.nnsylvania.
R...dy for Failure to Provide %nsuraDoe
9.02 Les.ee shall furnish Lessor with certificate. of
all in.uranc. required by thi. Article. If Lessee does not
provide such certificates on Lessor's delivery of possession to
Less.. or if Lessee allow. any insurance required under this
ArtiCle to lap.e, Le..or may, at its option, take out and pay the
premiums on the neces.ary insurance to comply with Lessee's
obligations under the provisions of this Article. Lessor is
entitled to reimbursement from Les.ee for all amounts spent by it
to pro cur. and maintain such insurance, with interest at the rate
of 18' per annum from the date of receipt of Lessor's notice of
payment until r.imbursement by Le.see.
Bold-Baral... Claus.
9.03 Lessor shall not be responsible for and is h.reby
r.li.Ved from all liability for any damage, expens., cau.e of
action, .uits, d.mand., judgment., and claim. of any nature
what.o.ver, eri.ing from or by rea. on of any injury to any person
or per.ons or any damage to any property which may arise from any
caus. (inClUding, without limitation, negligence of Le..or or its
agents, servants or employees), or from pre.ent or future
Structural dst.cts or other conditions in, on or about the
Premi... or any part ther.of or any sidewalk., str..ts,
driv.way., rights-ot-way or roadways adjacent th.reto, or in any
manner qrowing out of or connected with the u.e and occupancy of
the Pr8llli... or any part thereof by Lessee or any other party
during the term of this Lease or any renewal or exten.ion
ther.of. Less.. acc.pts and assumes such liability and agre.. to
prot.ct, indemnify and hold Le.sor harmless against any and all
liability, claims, demands, damages, costs, and expense.,
inclUding r.asonabl. attorney.' f... tor the d.fense of such
claw and demand., arising frOJl\ the conduct or manag8lllant of
Le..ee '. buaine.s on the Premi.es, or ita use ot the Pr8llli.e. or
from any br.ach on the part of Le.... of any condition. of this
Lea... or frOJl\ any act or negligence of Le...., its ag.nts,
contractor., amploy.... .Ubl......, conce..ionair... or lic.nse..
in or &})out the Premis... In ca.e of any action or proc..ding
brought again.t Le..or by reason of any .uch cla1&, Le..... on
notic. froa Le..or, aqr... to defend the action or proceeding.
This aball not be construed .. in any way liaiting Lea...'.
obligaUona under ArUch ,.
t
9.04 The insurance policies referred to above shall be
underwritten by insurance companies with Best's "A" rating or
better. Lessee shall deliver to Lessor certificates of all
insurance policies on or before the first day of the term hereof
and thereafter ten days prior to the execution of any such
policy. Lessee shall also deliver to Lessor receipts evidencing
payment of all insurance premiums, which delivery shall be at
least ten days prior to the date such premiums are due.
UTICIoI: 10. nlt.""GJ: OR DUTJlUCTIOII OJ' PREH%SES
10.01 If the Premi.e. .hould be damaged or destroyed
by fire, flood, or other casualty, Lessee shall give immediate
written notice of the damage or destruction to Lessor, including
a description of the damage and, as far as known to Lessee, the
cauae of the damage.
Total Destruction
10.02 If the Premises are totally destroyed by fire,
flood, or other casualty not the fault of Lessee or any person in
or about the Premi.es with the express or implied consent of
Les.ee, or if the Premises should be so damages by such a cause
that rebuilding or repairs cannot, in Lessor's reasonable
jud91llent, be completed within ninety (90) calendar days and at a
co.t not to exc.ed available insurance proceeds, this Lease shall
terminat., and rent shall be abated for the unexpired portion of
this Leas., eff.ctiv. as of the date of written notification as
provided in S.ction 10.01.
1I~ia1 DeetruotiOIl
10.03 If the Premis.s are damaged by tire, flood, or
other casualty not the fault of Les.ee or any person in or about
the Premi... with the expr.ss or implied con..nt of Le...., but
not to such an ext.nt that rebuilding or r.pairs cannot
r.asonably be compl.ted within ninety (90) calendar days and at a
cost not to exc.ed available insurance proceeds, this Lease shall
not be terminated exc.pt .. provided in Subparagraph. (a) and
(b) .
(a) It the partial de.truction of the Premi..s occurs
prior to the final six (6) months of the then current Le..e tera,
Lessor ahall, at ita .ole cost and ri.k, proceed imm.diately to
relNild or repair the dauged buildings and improv._nt. to
substantially the condition in which they existed prior to such
daaag.; provided, how.ver, that Le.sor ahall not be required to
expend monie. in exc... of insurance proceed. _de available to
lAaaor for .uch purpo... It the Praia.. are untenantable in
Wbol. or in part fol1owinv such ctauge, the rent payable durinv
10
the period in which they are untenantable shall be adjusted
equitably. In the event that Lessor should fail to complete such
rebuilding or repairs with ninety (90) calendar days from the
date of written notification by Lessee to Lessor of the
occurrence of the damage, Lessee may terminate this Lease by
written notification to Lessor. On such notification, all rights
and obligations under this Lease shall cease.
(b) If partial destruction of the Premises occurs in
the final six (6) months of the then current Lease term, or if
any mortgagee holding a lien on the Premises refuses to permit
insurance proceeds to be applied to the restoration of the
Premises, or if the insurance proceeds available for restoration
are not sufficient to restore the Premises to substantially its
condition prior to the casualty, Lessor n.ed not rebuild or
r.pair the Premises and shall notify Lessee in writing of its
intention not to rebuild or repair. If Lessor elects not to
rebuild or repair the Premises and the Premises are untenantable
in whole or in part following such damage, Lessee may elect to
terminate the Lease as of the date of Lessee's notice described
in S.ction 10.01 above or to continue the Lease with the rent for
the rlllll8inder of the Lease period adjusted .quitably. Lessee
ahall notify Lessor of such .lection within ten (10) days after
r.c.ipt of Lessor's notice described above.
unCLI 11. cOJmEHHJ.nOJl
~otal COndaDaUon
11.01 If the whole of the Premises shall be taken by
any public or quasi-public authority under the power of eminent
dOll&in, condemnation, or expropriation, or, in the .vent of a
conv.yance in lieu thereof, then this Lease shall terminate on
the date when title vests in the condemning authority. Rent
shall abate and Le.... shall have no claim against Lessor or the
COndemning authority for the value of the unexpir.d t.rm of this
Lea.. .
Partial COndaDatioD
11.02 If any part of the Premi... shall be ao tak.n or
conveyed and if auch partial taking or conveyance shall render
the Praia.. unsuitable for the busine.s of the Les..e, or it in
Lasaor'. sol. opinion, it would be impractical or the
condemnation proceeda are insufficient to restore the rlllll8inder
of the Praiae., thtUI the tara of thb Leu. ahall cu.. and
tenUnate .. of the date on which title to the Preai.e. ve.ts in
the COndUlning authority. Leas.. shall have no claill allainat
Lauor Ol' the Condemning authority for the value of any unexpired
11
portion of this lease. In the event such partial taking or
conveyance is not extensive enough to render the Premises
unsuitable for the business of Lessee, this Lease shall continue
in full force and effect except that the rent shall be adjusted
equitably during the unexpir.d portion of the Lease.
Le..or'. Daaaq..
11.03 In the event of any condemnation or taking,
whether whole or partial, the Lesse. shall not be entitl.d to any
part of the award. Le.se. hereby expressly waives any right or
claim to any part of such amount and assiqns to Lessor any such
right or claim to which Less.e might become entitled.
Le...... Daaaq..
11.04 Although all damages in the event of any
condemnation are to belong to the Lessor, Lessee shall have the
right, to the ext.nt that it shall not diminish the Lessor'.
. , award, to claim and r.cover from the condemning authority, such
compenaation a. may be separately award.d or r.cov.rable by
Le.... under the Emin.nt DOlIIAin Cod. in Le....' s own right for or
on account of, and limited .ol.ly to, any co.t to which Le....
might be put in removing La.S..' s merchancUse, furniture,
fixtur.., lea.ehold improv_enta, and equipment.
~~&rJ ~.ktftq
11.05 If the condaanor .hould take only the right to
po.s.ssion for a fixed period of time or for the duration of an
_erqency or other temporary condition, then notwi th.tandift9
anything her.inabov. provided, this Leas. shall continu. in full
force and .ff.ct without any abat...nt of r.nt, but the amounts
p.yabl. by the condemnor with r..pect to any period of time prior
to the expiration or sooner termination of this Lea.. .hall be
paid by the condemnor to Lassor and the condemnor shall be
considered a .ubtenant of Le..... Le..or .hall apply the lUIOWlt
r.c.ived from the condemnor applicabl. to the r.nt due h.r.under
net of Cotlta to Le..or f.or the coll.ction ther.of, or as much
thereof.. may be n.cessary for such purpo.., toward the IUIOWlt
d.ue froa Le.... a. rent for the period: and, Le.... shall pay to
Lea.or any d.ficiency betw..n the ..ount thus paid by the
condanor and the lUIOunt of the rent, or Le..or shall pay to
Le.... any exce.. ot the lUIOunt ot the award over the eaount of
the rent.
~CLI u. .._... 01' DlI'a:G1.~
12 . 01 'l"ba follovinv .vents or any one or IIOrtl of tba
eh&ll !Ie 8"...1:8 of default \!Mer this Lea..:
12
(a) Lessee shall fail to pay any fixed rent,
additional rent or other sum payable hereunder; or
(b) Lessee shall fail to perform or comply with any of
the other terms, covenants, agreements or conditions hereof (and
such failure shall continue for more than five (5) days after
written notice thereof from Lessor) or (provided, if the default
cannot be cured within five (5) days), Lessee shall not be
considered in default if Lessee shall, within such period, have
comm.nced with due diligence and dispatch to cur. such default,
and shall thereafter complete with due dilig.nce the curing of
.uch d.fault; or
(c) Le.se. shall make a general assignment for the
ben.fit of creditors, or shall admit in writing ita inability to
pay its debts aa th.y become due, or shall file a p.tition in
bankruptcy, or shall be adjudicated a bankrupt or insolvent, or
.hall file a petition seeking any reorganization, arrangement.,
composition readjustment, liquidation, dissolution or similar
relief under any present or future statute, law or regulation, or
shall file an answer admitting or not contesting the material
allegations of a petition against it in any such proceeding, or
shall seek or consent to or acquiesce in the appointment of any
trust.e, receiver or liquidator of Lesse. or any material part of
ita properti..; or
(d) If within 60 days after the commencement of any
proc..ding against Le.... .eeking any reorganization,
arrangement, compo.ition, readjustm.nt, liquidation or
di..olution or .imilar r.lief under any pre..nt or future
.tatute, law or regulation, such proce.ding .hall not have been
dismi...d, or if, within 60 days after the appointm.nt without
the ccn..nt or acqui..c.nc. of Le...., of any trust.., r.ceiver
or liquidator of Le.s.., or of any mat.rial part of ita
properti.., .uch appointm.nt shall not have been vacat.d.
12.02 In the .v.nt ot any .uch .v.nt of default
(r.gardl... of the pend.ncy ot any proc.eding which has or might
have the .ff.ct ot pr.venting Le.... from complying with the
teras ot this Lea.e), Le..or at any time ther.after may exercise
any one or aore ot the following remedi..:
(a) 'l'enination of Lea... Le.sor uy terminate this
Lea.., without any right by Le.... to r.instat. ita rights by
pe~t ot rant due or other performance ot the terms and
conditione hereof. Upon .uch tenination Le.... shall
i--.di.tely .urr.nder po.....ion ot the Pr..i... to Le..or and
Leasor ahall t-..diat.ly becoaa .ntitled to rec.ive troa Le....
d.&aa".. ~l to the cUtterence betw.an the alJ9reqat. rantala
13
reserved ror the balance or the term and the rair rental value or
the Premise. ror that period, determined a. or the date or such
termination.
(b) Ral.tting. With or without terminating this
Lea.e, a. Le..or may .l.ct, Le.sor may re-ent.r and reposse.s the
Premises, or any part thereor, and lease them to any other person
or .ntity upon such t.rm. as Lessor shall deam reasonable, ror a
term within or beyond the term or this Leas.; provid.d, that any
.uch r.l.tting prior to t.rmination shall be ror the account or
Le...., and Les... shall remain liable ror (a) all minimum rent,
additional rent and other sums which would be payable under this
Lea.. by Les.e. in the absence or such expiration, termination or
repos....ion, l.s. (b) the n.t proceed., if any, of any r.letting
(inClUding, without limitation, all repos.e.sion costs, brokerage
commis.ions, legal expens.., attorney.' ree. and expen.es,
amploy.... exp.ns.., r.a.onabl. alt.ration coats, and expenses at
pr.paration for such r.l.ttinq).
It the Premi... are at the time at derault subl.t or
l.a..d by Le.... to other., Le..or may, a. Le...... ag.nt,
coll.ct rents due trom any subtenant or other tenant and apply
.uch rents to the r.nt and other amounts due hereund.r without in
any way affecting Less.e'. obligation to Le..or hereunder. Such
ag.ncy, being given for ..curity, is hereby d.clar.d to be
irr.vocaQl..
(c) Acc.leration of Rant. Le..or may d.clar. rant and
all it... of additional r.nt tor the entire balanc. of the th.n
currant term imm.diately due and payabl., tog.ther with all other
charg.., payments, co.ts, and expen... payable by Le.... a.
though .uch lUIIOunts war. payable in advanc. on the date the .vant
of d.fault occurred.
(i) No expiration or termination at this Lea.. tara
pur.uant to S.ction 12.02 (a) hereot or by operation at law or
otherwi.. (exc.pt a. expr...ly provided h.r.in), and no
r.po.....ion ot the Preai... or any part th.r.ot pur.uant to
S.ction 12. 02 (b) her.ot or otherv is. shall r.lieve Le.... of ita
liabiliti.. and obligations her.und.r, all at which .hall .urviv.
.uch expiration, termination or r.po.....ion, and Le..or aay, at
its option, .u. tor and coll.ct rent and other charg.. due
ber.Under .t any tiae and troll tiae to tin a. and wh.n .uch
ch&rqea accru..
12.03 With re.pect to any portion of the Prai...
VI1ich is vacant or wnich is pbyai,*lly occupied by Lea..., Le..or
..y reaove all persona and property ther.troa, and .tore .uch
property in a public varaboun or .l.aw.re at the coat ot and
1C
for the account of Lessee, without service of notice or resort to
legal process (all of which Lessee expressly waives) and without
being d.em.d guilty of trespass or becoming liable for any loss
or damage which may be occasioned thereby. Lessor shall have a
li.n for the payment of all sums agreed to be paid by Less..
herein upon all Lessee's property, which lien is to b. in
addition to any Lessor's lien now or hereafter provided by law.
12.04 The parties hereby waive trial by jury in any
action, proc..ding, or counterclaim brought by either of them
again.t the other on any matters arising out of or in any way
conn.cted with this Lea.e, the relationship of Lessor and Lesse.,
Lesse.'. us. or occupancy of the Premises, and/or any claim or
injury or damage. In the event Lessor commences any proceedings
for non-payment of r.nt or additional rent, Lessee will not
interpo.. any count.rclaim of any nature or description in any
.uch proce.dings. This shall not be construed, howev.r, as a
waiver of Lessee's right to assert any such claims in any
s.parat. action brOUght by Les....
12.05 Le.... h.r.by expressly waives any and all
rights of r.demption grant.d by or under any pres.nt or future
law in the .vent this Lease i. t.rminated or Lessee i. evicted or
d.ispo.....ed. by reason of violation by Less.e of any of th.
provi.ions of thi. Lea...
12.06 In the .v.nt of breach or thr.at.n.d br.ach by
Le.... of any provi.ion of this Lea.., Lessor shall have th.
right of injunction a. if other rem.di.. were not provided for
her.in.
12.07 No right or rem.dy herein conf.rred. upon or
r..erv.d to Le..or i. int.nd.d to be exclusive of any other right
or remedy herein or by law provided, but each .hall be cumulative
and in addition to .very other right or rem.dy given h.r.in or
now or hereafter .xi.tit\9 at law or in equity or by .tatute.
12.08 Any rent (includit\9 charges coll.ctible ..
additional rent) overdue for a period of more than five (5) clay.
.hall bear intere.t at the rat. of 18' per annua until paid.
12.0' If Le.... shall d.fault in the perforaanoe at
any covenant required to be perforud by it under this Lea..,
Les.or aay perforll the .... for the account and at the expens. ot
Les..., atter tirat givit\9 notice to Le.... of ita intention to
do .0. It Lessor at any t1ae is coapelled to pay, or el.eta to
pay, any sua of IIOMr' by reason of the failure ot Leas.. to
COIIply with any prav dona hereof, or if Lessor is capelled to
incur any upanae, includin9 reasonable counael f..., in
1$
instituting, prosecuting or defending against any action or
proceeding instituted by reason of any default of Lessee
hereunder, the amount of such payments or expenses shall be paid
by Lessee to Lessor as additional rent on the next day following
such payment or the incurring of such expense upon which a
regular monthly rental payment is due, together with interest
thereon at the rate of 18' per annum.
12.10 No waiver by Lessor of any breach by Lessee of
any of its Obligations, agreements or covenants hereunder shall
be a waiver of any subsequent breach or of any other obligation,
agreement or covenant, nor shall any forbearance by Lessor to
seek a. remedy for eny breach by Lessee be a waiver by Lessor of
its rights and remedies with respect to such or any subsequent
breach.
12.11 Lessee expressly waives any right of defense
which it may have based on any purported merger of any cause of
action, and neither the commencement of any action or proceeding
nor the settlement thereof or entering of judgment therein shall
bar Leasor from bringing subsequent actions or proceedings from
time to time.
THE FOLLOWING SECTIONS SET FORTH WARRANTS OF AUTHORITY
FOR AN ATTORNEY TO CONFESS JUDGMENT AGAINST MAKER. IN GRANTING
THIS RIGHT TO CONFESS Jt1DGKENT AGAINST LESSEE, LESSEE HEREl'V
KNOWINGLY, INTENTIONALLY AND VOLUNTARILY, AND, ON THE
ADVICE OF THE SEPAllATE COtmsEL OF LE~SE!:.. UNCONDITIONALLY WAIVES
ANY AND ALL RIGHTS LESSEE HAD OR MAY HAVE TO PRIOR NOTICE AND AN
OPPORTUNITY FOR HEARING UNDER THE RESPECTIVE CONSTITtl'l'IONS AND
LAWS OF THE UNITED STATES AND THE COMMONWEALTH OF PENNSYLVANIA.
12.12 LESSEE HEREBY EKPOWERS ANY PROTHONOTARY OR
A'l'TORNEY OF ANY COURT OF RECORD TO APPEAR FOR LESSEE IN ANY AND
ALL ACTIONS WHICH MAY BE BROUGHT FOR RENT AND/OR THE CHARGES,
PAYHIHTs, COSTS AND EXPENSES HEREIN RESERVED AS RENT, OR HEREIN
AGREED TO BE PAID BY LESSEE AND/OR TO SIGN FOR LESSEE AN
AGREEMENT FOR EHTElUNG IN ANY COMPETENT COURT AN AMICABLE ACTION
OR ACTIONS FOR THE RECOVERY OF SUCH RENT OR OTHER CHARGES OR
EXPENSES, AND IN SAID SUITS OR IN SAID AMICABLE ACTION OR ACTIONS
TO COHFE$S JODGHENT AGAINST LESSEE FOR ALL OR ANY PART or THE
lU:Il't SPECIFIED IN THIS LEASE AND THEN DUE AND UNPAID, AND OTHER
CHARCO, PAYHENTS, COSTS AND EXPENSES RESERVED AS RENT OR AGREED
TO BE PAID BY LESSEE AND THEN DUE AND UNPAID, AND FOR INTEREST
AND COSTS TOGETHER WITH A REASONABLE ATTORNEY'S COHHISSION or
15'. SUCH AUTHORITY SHALL NOT BE EXHAUSTED BY ON!: EXERCISE
THIREOF. BUT J't1DGM:!NT MAY BE CONFUSE%) AS AFORESAID FROM TIME TO
TDCZ AS OPTEN AS ANY OF SAID RENT AND/OR OTHER CHARCES RESERVED
AS RIHT OR AGREED TO BE PAID BY LESSEE SDu.r FALL DUE OR BE IN
AJtRlU.,.
11
12.13 uPON THE EXPIRATION OF THE THEN Ct1RREN'1' TERM OF
THIS LEAsE OR THE EARLIER TERMINATION OR SURRENDER HEREOF AS
PROVIDED IN THIS LEASE, IT SHALL BE LAWFUL FOR ANY A'l"l'ORNEY TO
APPEAR AS ATTORNEY FOR LESSEE AS WELL AS FOR ALL PERSONS CLAIMING
BY, THROUGH OR UNDER LESSEE AND TO SIGN AN AGREEMENT FOR ENTERING
IN ANY COMPETENT COURT AN AMICABLE ACTION IN EJECTMENT AGAINST
LESSEE AND ALL PERSONS CLAIMING BY, THROUGH OR UNDER LESSEE AND
THEREIN CONFESS JUDGMENT FOR THE RECOVERY BY LESSOR OF POSSESSION
THE HEREIN PREMISES, FOR WHICH THIS LEASE SHALL BE ITS SUFFICIENT
WARRANT, WHEREoPON, IF LESSOR SO DESIRES, A WRIT OF POSSESSION OR
OTHER APPROPRIATE WRIT UNDER THE RULES OF CIVIL PROCEDURE THEN IN
EFFECT MAY ISSUE FORTHWITH, WITHOUT ANY PRIOR WRIT OR
PROCEEDINGS; PROVIDED, HOWEVER, IF FOR ANY REASON AFTER SUCH
ACTION SHALL HAVE BEEN COMMENCED, THE SAME SHALL BE DETERMINED
AND THE POSSESSION OF THE PREMISES HEREBY DEMISED REMAIN IN OR BE
RESTORED TO LESSEE, LESSOR SHALL HAVE THE RIGHT FOR THE SAME
DEFAULT AND uPON ANY SUBSEQUENT DEFAULT OR DEFAULTS, OR UPON THE
TERMINATION OF THIS LEAsE UNDER ANY OF THE TERMS OF THIS LEAsE TO
BRING ONE OR MORE FURTHER AMICABLE ACTION OR ACTIONS AS
HEREINBEFORE SET FORTH TO RECOVER POSSESSION OF THE SAID PREMISES
AND CONFESS JtlOGMENT FOR THE RECOVERY OF POSSESSION OF THE
PREKISES AS HEREINABoVE PROVIDED.
12.14 IN ANY AMICABLE ACTION OF EJECTMENT AND/OR FOR
RENT IN ARREARs, LESSOR SHALL FIRST CAUSE TO BE FILED IN SUCH
ACTION AN AFFIDAVIT MADE BY IT OR SOMEONE ACTING FOR IT, SETTING
FORTH THE FACTS NECESSARY TO AOTHORIZE THE ENTRY OF Jt1DGHENT,
AND, IF A TRUE COpy OF THIS LEASE (AND OF THE TRUTH OF THE COpy
SOCII AFFIDAVIT SHALL BE SUFFICIENT EVIDENCE) BE FILED IN SUCH
ACTION, IT SHALL NOT BE NECESSARY TO FILE THE ORIGINAL AS A WAR-
RANT OF ATTORNEY, ANY RULE OF COURT, CUSTOM OR PRACTICE TO THE
CONTRARy NOTWITHSTANDING. LESSEE HEREBy RELEAsES TO LESSOR AND
TO ANY AND ALL ATTORNEYS WHO MAY APPEAR FOR LESSEE ALL ERRORS IN
SAID PROCEEDINGS AND ALL LIABILITY THEREOF. IF PROCEEDINGS SHALL
BE COHHENCED BY LESSOR TO RECOVER POSSESSION UNDER THE ACTS OF
ASSEMBLy AND RULES OF CIVIL PROCEDURE, EITHER AT THE END OF THE
TERM OR EARLIER TERMINATION OF THIS LEASE, OR FOR NON-PAYMENT OF
RENT OR ANY OTHER REASON, LESSEE SPECIFICALLY WAIVES THE RIGHT TO
THE 3 MONTHs' NOTICE AND TO THE 15 OR 30 DAYS' NOTICE REQUIRED
BY THE LANDLORD AND TENANT ACT OF 1951, AND AGREES THAT 5 DAYS'
NOTICZ SVTT. BE SUFFICIENT IN EITHJ:R OR ANY SOCH CASE.
U'l'ICLa 13. nr".WIOII 8f LUaoa
13.01 lA.... ll!uall peraJ.t lA8aor and lAJI.or'. aq.nu,
repreaenutiva., and eaplo)'ee8 to enter the !>real... at all
re&aonabl. ti... tor the P\U'pO.. ot inapection, repeir or any
other P\IZ'POH neceaaary to prat~ lAuor'. interut in the
Prai... or to perfon lA..or'. c1IlUu WlCler thia lAu..
11
U'lICLI: 16. USICUIHEIIT AIm SUBLlmSB
a..igDaaDt aDd Subl.ttiDq by L.....
16.01 Leaae. may not sublet, assign, encumber, or
otherwia. tranater thLa Leaae, or any right or interest in this
Leaae or in t.b. Premiaea or the improvements on the Premises,
without the prior written consent of Le.sor, which consent may be
withh.ld in Le..or'. sole discretion. It Lessee sublet.,
a.signs, encumber., or oth.rwis. transfera it. rights or
inter..ts in this Lease or in the Premises or the improvements on
th. Premi... without the written con..nt of Lessor, Leasor may,
at its option, d.clar. thi. Leas. terminated. In the ev.nt
Le..or consents in writing to an assignment, sublease, or other
tran.fer of all or any of Le....'. rights under this Lea.., the
a.sign.. or .ubl..... must a.sume all of Lessee's obligations
under this Lease, and Leas.. shall remain liable for every
obliqation under the Lea.e.
a..igDaeDt bJ Lee.or
16.02. Le..or may as.ign or transter any or all of ita
inter..ts under the terms of this Lea.e.
U1'%CLI u. a.-..J.l'n_......u. CODLIUCI:
15.01 Without liaitinq the gen.rality of any
provi.ions ..t forth el..where in this Leas., Le.... agr... a.
tOllow.,
(a) Lea... aball not (either with or without
negligenc.) caus. or permit the ..cape, dispo.al or relea.. of
any HaZardous Substanc.., a. hereinatter defin.d, on, in or under
th. Premi.... Le.... ahall not allow the .torage or us. ot .uch
.ubstanc.. in any manner not sanction.d by law or by the high..t
.tandarda pr.vailinq in the indu.try for the storage and u.. ot
such .ubstanc.., nor allow to be brought onto the Premi... any
.uch .ubstanc.. except to u.. in the ordinary cour.. of Le....'s
busin..., and then only atter written notice i. given to Le..or
ot (1) th. identity ot .uch substanc.s, and (2) the .ethod for
pr.venting th. ..cape of any .uch substances, and Leasor's prior
written approval is grantaci. Le.... covenants and agr.e. that
th. Preai... vill, at all time. during its us. or occupancy
ther.of, be kept and maintained so a. to cOllply vith all now
axi.tineJ or her_tter enactaci or i.sued .tatut.., laWII, rul..,
ordJ.nancaa, orders, peraita and requlations of all .tata,
tacieral, local, and other 9oVU1lllent&1 and regulatory
authoriti.., aqanci.. and bodi.. applicable to the Pnai...,
per1:&inJ.ncJ to environaental ..tters, or regulatinq, prohibiting
11
,..... -,'.
or otherwise having to do with Hazardous Substances and all other
toxic, or hazardous wastes (collectively callea "Environmental
Laws"). Lessee shall execute affidavits, representations and the
like trom time to time at Lessor's request concerning Lessee's
be.t knowl.dg. and beliet without limiting any of the obligations
ot Le.s.. under the provisions set torth in this Lea.e. Lessee
agree. to clean up all spills and discharges ot Hazardou.
Sub.tanc.. on the Premises in a manner which shall comply with
all applicabl. environmental laws. Lessee .hall notity Lessor in
vritilU1 ot all .ucb incidenta.
(b) Le.... shall immediately deliver to Les.or a copy
ot any .ummons, citation, directive, notice, complaint, lett.r or
other communication trom any tederal, state or local
environm.ntal ag.ncy, conc.rning any alleged violation. of any
environm.ntal lava or regulations on the Premi.e., or concerning
any inv..tigation or request tor intormation relating to the use,
generation, handling, treatment, storage or disposal of Hazardous
Sub.tanc.. in conn.ction with the Premises.
Cc) Upon reque.t, Le.se. shall cooperate in Obtaining
.videnc. of complianc. with any environmental law, regulation,
order of any governmental authority, which cooperation may
inclucl., without limitation, providing affidavit., reports or
r..pons.. to qu..tion.. Le.... .hall provide acc.s. to the
Premi..., upon request, tor inspections and testing of the
Premi... r.garding the pr..ence of Hazardous Substanc...
Cd) Le..or and ita engin..r., t.chnicians, and consul-
tanta Ccoll.ctiv.ly the "Auditors") may, from tim. to tim. a.
Lea.or d.... appropriat., conduct periodic te.t. and examinations
("AUdita.) of the Premi.e. to confirm and monitor Les...'a
complianc. with the Lea... Such Audit. shall be conducted in
auch a lIIUUler a. to llinimize the interference with Le.s.e'.
permitted activiti.s on the Premise.; howev.r, in all ca..., the
Audita .hall be of .uch nature and scope .. .hall be r.a.onably
required by then existing technology to contirm Le..ee'.
compliance with thb Leu.. Les.e. shall fully cooperate with
Lea.or and ita Auditors in the conduct of .uch Audit..
(.) Le.... .hall indemnifY, d.fend and hold Le..or,
ita partners, affiliat.., par.nt., offic.r., dir.ctor. and em-
ploy..., and other occupant. of the Premi... C collect! v.ly ,
the .lndeanit....), fr.., harml... and indemnifi.d froa any
expens.., penalti.., fin.., claiaa, deaand., liabiliti.., co.t.,
per.onal injuri.., property d...g., action. and cau.e. of action,
.uita, dGta. judqaenta, deaancta or c:barc;.. vbataoaver Which the
Indeanit... .ball or uy incur, or whicb any .uch party would
otharvi.. incur, by r...on of Le...... failure to coaply with
1t
this Lease including, but not limited to: (i) the cost of
bringing the Premises into compliance with all laws; (ii) the
reasonable cost of all appropriate tests and examinations of the
Premises to confirm that the Premises has been brought into
compliance with all laws; and (iii) the reasonable fees and
expenses of the Indemnitees' attorneys, engineers, and
consultants incurred by the Indemnitees in enforcing and
confirming compliance with this Lease.
(f) The covenants contained in this Article shall
survive the expiration or termination of this Lease, and shall
continue for so long as Lessor and its successors and assigns,
and the Indemnitees, may be subject to any expenses, obligations,
penalties, fines, claims, demands, liabilities, costs, personal
injuries, property damage, actions and causes of action, suits,
debts, judgments, demands or charges whatsoever against which
Lessee has agreed to indemnity the Indemnitees under this Lease.
(g) All terms, except as otherwise defined herein,
shall have the meanings as set forth in the Lease. For purposes
hereof, Hazardous Substances shall mean (i) any "Hazardous
Substance", "Pollutant" or "Contaminant" (as defined in Section
101(14) and (33) of the Comprehensive Environmental Response and
Compensation and Liability Act ("CERCLA"), 42 U.S.C.A. Section
9601(14) and (33)) or 40 C.F.R. Part 302; (ii) any hazardous
substance, hazardous waste or solid waste, as those terms are
defined in applicable state or local law; (iii) any substances
containing petroleum as that term is defined in Section 9001(8)
of the Resource Conservation and Recovery Act, as amended, 42
U.S.C.A. Section 6991(8) or 40 C.F.R. 280.1; or (iv) any other
substance for which any governmental entity requires special
handling in ita collection, storage, treatment or disposal.
(h) Lessor represents and warrants that, to the best
of Lessor'a knowledge:
(1) No notice has been given to Lessor, by any
governmental authority or any person claiming any violation of,
or requiring compliance with, any federal, state or local
statute, ordinance, regulation or other requirement of an
Environmental Law, or deunding remediation of or paym.nt of
contribution for any environm.ntal contamination or any damag.s
attributa.bl. ther.to;
(2) There are no underground storag. tanks or s.ptic
systems, located at the Preaues;
(3) No invaatiqation, ac1ainistrati ve order, con.ent
order, lien, auperlien or .gr....nt, litigation or settlement
vith respect to any Hazardous Subat.nce of .ny kind located on,
about or under all or .ny portiOll of the Pr_b.. uiata. is
pending. ~ed. thnatened or antiCipated.
20
(i) Lessor shall defend, indemnify and hold Lessee
harmless from and against any liability, loss, damage, costs and
expense suffered, incurred or threatened as a result of any
breach of any representation or warranty hereunder or as a result
of notice, complaint, claim, demand, suit, order, judgment or any
legal requirement, including without limitation of the generality
of the foregoing, court costs, attorney's and consultant's fees,
environmental Clean-up costs, natural resources damages, fines,
penalties and damage. to person., personal property, real
property and busines. enterprises, arising out of or relating to
an environmental condition on the Premises caused by Lessor.
ART%CLK 11. RULlI AIm UQtlUT%0If8
16.01 Les.or shall have the right to make reasonable
rul.s and r.gulation. for the purpose of en.uring or enhancing
the safety, car., cleanline.s, maintenanc., or preservation of
the Premi.e. and common areas, as well as for the purpose of
preserving good order in and on the Premises and common areas.
(specifically including but not limited to the allocation and
id.ntification at parking .paces among tenants.) Lesse. and ita
ofticer., employe.., agent., and invitees agree to be bound by
any such rules and regulations on receipt by 1..... of written
notic. from Les.or s.tting forth same, and any change., additions
and/or deletions. Le..ee .hall be responsible for the complianc.
at its officers, employe.., and invitees with ell .uch rule. and
r.gulations.
ARUCLK 17. CClIIJ)n'%OIf PUCBDIft
17.01 Thi. Lea.e is expres.ly condition.d upon the
acqui.ition at f.. .impl. title to the premi.e. by Le..or. Should
such ..ttlement not occur for any rea.on, Le.sor shall return all
said rent payments to Lessee, and neither party shall have any
liability to the other her.under.
ARUCLK 11. Ja,/,!lPu.1lVWOV8
18.01 All notices requir.d under this Lea.. ahall be
effectively given only if by certified mail, registered ..il, or
nationally recognized overnight courier service, addr....d to tbe
proper party. at the followinv addres...:
Le..or
Paul L. Kostick
41 Georve Circle
Hecbanicabu.r9, PA 17055
W. Scott Stu'uch, Eaquin
20 Irlord Road, Suite 215
LelIoyne, PA 17043
with a copy to:
21
Lessee
Francesco Failla
663 Wyndamere Road
Lewisberry, PA 17339
with a copy to:
Either party IIllY change the address to which notice.
are to be sent by gi vinq the other party notice of the new
addr... in th. manner provided in this S.ction.
Put1.. BoWUS
18.02. This Leas. shall be binding on, and inure to
th. benefit of, th. partie. to the Lease and their respective
heir., executors, administrators, legal representatives,
.uccea.or., and a.signa when permitted by this Lease.
PelluJ'lVUia loa. to app11
18. 03 '1'hJ.s agreaaent shall be governed by and
construed under the lava of the ColIIlIIonwaalth of Pennsylvania.
Legal Coutzuotiu
18.0C In the event anyone or IlOre of the previsiona
contained in thi. agr._ent ahall for any re..on be held by a
court of COIIpatent jurisdiction to be invalid, illegal, or
unenforceable in any r..pact, such invalidity, illegality, or
unanforceability shall not affect any other provision of the
.gr.......t, and this aqreaaent ahall be conatrued as if the
invalid, illeqal, or unenforceable provision had n.ver been
included in thia agr.8MDt.
Pl:i~ ,a,p-..au luper.adad
11.05 Thi. Lea.. con.titut.. the only agre8MDt
between th. Lea.or and Lea... and supersed.. any prior
undera1:ancUnqa or written or oral agre_enu between the parti..
r..JI8Ctinv the .ubject utter of this Lea.e.
.-~""'-.Ilt
11.06 No aaandaant, lIOClification, or alteration of the
t:eraa of tbia Leue &ball be bindineJ unle.. it i. in writinq,
dated .1I~equent to the date of this Leue, and duly executed by
tbe ,.....car aDd 7.......
22
Attorneys' ~ees aDd Costs
18.07 In the event that at any time during the term of
this Lease either Lessor or Lessee shall institute any action or
proceeding against the other relatinq to the provisions of this
Lease or any default of this Lease, then the unsuccessful party
shall reimburse the successful party for reasonable attorneys'
fe.. and axpena.. incurred to enforce the Lea.e,
VDavoida!lle ~lay
18.08 Except for the payment of rant, utility charqes,
and other SW118 of mon.y to be paid under this 'Leas., n.i ther
Lessor nor Less.e shall be r.quired to perform any term,
condition, or covenant in this Lea.e so lonq as such performance
i. hinder.d or prevented by unavoidable delay.. For purpos.s of
this Section, unavoidable delays shall be defined as natural
di.aster.; strik.., lockouts, or labor disput.s; qovernmental
requlations, r.strictions, or controls; enemy or hostile
qovernment action; civil riots; fire, flood., or nuclear
accident; or any other cause not reasonably within the control of
Las.or or Las.e. and that by the &xercis. of due diliq.nce Les.or
or Le.... i. unable, wholly or in part, to prevant or overcOJlle.
!'iae at "SU08
18.0' Time is of the e.senc. of this agr.eaent.
Quiet IDjOJlWlt
18.10 Le...., upon paying the r.nt and upon observing
and k.epinq the covenants, agreement. and conditions of this
Lea.. on ita part to be perform.d, .hall quietly have and enjoy
the Prai... durinq the tarm of this Lease without hindrance or
mol..tation by Les.or or by anyone claiming through or under
Les.or, .ubject to the terms, covenants, conditions and
exceptions herein contained, and su!lject also to any r..tric-
tions, ".eaenta or other agreeaents ot record. '!'hi. covenant is
given in lieu of any t.plied covenant ot quiet enjoyment.
blaUOIUIllip ot Parti..
11.11 The relationship betwe.n the parti.. hereto
lIball be that of Las.or end Lea... and nothing contained herein
shell be construed to change or aodity that relationsbip ao .. to
ulte Lessor end te.... partnera, joint venturera, or debtor end
cnd1tor .
u
Requir8aaDta of Publio Authoriti..
18.12 Less.. will promptly and faithfully comply with,
confora to, and obey all pre.ent and future laws, ordinanc..,
rule., regulations and r.quirement. of every duly constituted
governm.ntal authority or agency having jurisdiction over Le....
anc1/or the Premi... or any part thereof.
..tappal Certifiaaa
18.13 LeII... agr... to ex.cut. and deliver to any
mortgag.. or purcha.er of the Premi..., imm.diat.ly upon r.quest,
an -..toppel certificat.- stating the amount -of r.nt due frOll
Lease. hereunder, that this Leas. remain. in full force and
.ff.ct without lIIodification, and that Less.e has no s.t-off.
against rent; or, if this Lease hu be.n lIIodified, or if Le....
haa any ..t-offa against r.nt, the exact nature of the
modifications and the pr.ci.e amount of the s.t-offs.
110 ~oker.
18.14 Lea... r.pr..enta and warranta to Lessor that
Lea... baa had no dealing., negotiations or consultations with
r..pect to the Premi... or this transaction with any broker or
intermediary and that no broker or interm.diary called the
Prai... to LeII..e'. attention for l.a.. ur took any part in any
dealing., negotiations or consultation. with respect to the
Prai... or this Lea... In the .v.nt that any broker or
interaediary claw to have sublllitted the Premis.. to Le.s.e, to
have induced LeII... to l.a.. the Premise. or to have taken part
in any dealing., n.gotiations or consultations with resp.ct to
the Premi... or this Lea.., Le.... will be re.pon.ibl. for and
will ind8lllnify, d.f.nd and .av. Leeeor harml... from and against
any costa, f... (inClUding without lilllitation, attorney's f...),
expena.., liabilities, and claillla incurred or suffered by Le..or
as a reault ther.of.
lIort9a9.s
18.15 LeII... acc.pta this Lease subj.ct to any deeds
of trust, ..curity inter..ta, or mortgage. that lIIight now or
later constitute a lien on the Prai.... LeII... lIIust, on deaand,
execute any instruaenta, r.I....., or other dOCWIaDta that are
required by eny mortgag.. tor the purpos. ot .ubj.cting and
.Ubordinatinq thi. Leaa. to the lien of any sucb deed of trWI1:,
.ecurity inter1ult, or lIort9ave constituting a lien on the
pz-..t....
24
Parti.. BoUDIS
18.16 Subject to the provisions of Article 14 hereof,
thia Lea.e .ball be binding upon the parties hereto and Shall be
binding upon the inure to the benefit of and be enforceable by
their reapective succeasors and assigns. Thia Lease is expressly
conditioned upon the approval of ita terms and conditions by
Lesaor's mortgagee, Dauphin Deposit Bank and Trust Company, of
Harrisburg, Pennsylvania. Lessee agrees to execute a consent to
the Aaaiqlllllent of Leaa.s executed between Le.sor and its aaid
mortgag...
W.i ver of CUatoa
18.17 Laaaor shall have the right at all tim.s, any
law, usag. or custom notwithstanding. to enforce strictly the
provisiona of this Lea.e, and the failure of Lessor at any time
or tim.. strictly to enforce any provision her.of sball not be
construed as having cr.at.d a cuatom or waiver in any way
contrary to the specific provisions of this Lease or a. having in
any WilY or l18Mer IIlCIdiried this Laas..
cartaiJa II-Jlhllq.; LiaitatiOJl of L1abiliq-
18.18 Ca> '!'be word .La..... a. used in thia Lea..
lIball be construed to m.an tenanta in all ca..a where there i.
more than on. tenant C and in such ca.. the liability of such
tenanta shall be joint an4 .everal), and the n.c...ary
CjJrlUllll8tical chang.. required to lIII1ke the provisiona hereof apply
to corporation, partnerahips or individuals, men or WOllen, shall
in all case. be assumed as though in .ach ca.. fully expressed.
Each provi.ion hereof lIball extend to and shall, a. the ca.. I114Y
requir., bind and inure to the benetit of Lea..e and ita
succe..ors and a..igna, provided that this Lea.e shall not inure
to the benefit of any a.signee or succe.sor of Les... except upon
the expre.. written COMent of Lea.or as herein provided.
Cb) 'l'he term "Lessor. a. used in this Laa.. aeaM the
f.. owner of the Premi.... In the .vent of the voluntary or
inVOluntary transfer of .uch owner.bip or rigbt to a .ucce.sor in
inter..t of Leaaor, Le.sor shall be fr.ed and relieved of all
liability and obligation hereunder which shall thereafter accru.
and ~..ee .hall look 801ely to .uch succes.or in int.r..t for
the pertOl'llaJ\c. of the cov.nants and obligations of the Le.sor
ber.under which lIball ther.after accrue. 'l'he liability of Lessor
and ita .uce..sora in interut, under or with respect to this
Lease, aball be .trictly l1aitlld to and enforceable only out of
ita or th.u inter..t in the Praai... and the trsct ot real
..tate ot which the Preal... are a part, and shall not be
25
enforc.abl. out of any other assets. No mortgagee or ground
lessor which shall succeed to the interest of Lessor hereunder
(either in terms of ownership or possessory rights) shall: (1)
be liable for any previous act or omission of a prior Lessor, (2)
be .ubject to any rental offset. or defen.es against a prior
Le..or, (3) be bound by any amendment of this Lea.e made without
its written consent, or by payment by Lessee of rent in advance
in axe... of one (1) month'. r.nt, (4) be liable for any
s.curity not actually received by it, or (5) be liable for any
initial construction of the improvements to be made to the
Preai... or for any allowance or credit to Le.... for rent,
construction costs or other expenses. Subject to the for.going,
the provisions hereof shall be binding upon and inure to the
ben.fit of the succeasors and assigns of Lessor.
captiollUl
18.19 The captions contained herein are for the conv.-
nience of the parti.. only. They do not in any way modify,
amplify, alter or give full notice of the provisions her.of.
~Ko.~ck \~
<;-/,
. I
c.-- I
rS-
a
I.giiE:
.,. ",,"
L...";
rranceaco
fa \vpvin\k08tict2
21
.
EXHIBIT B
AFFIDAVIT OF GUI$EPPE RUSSQ
The undersigned Affiant, being duly swom according to law and possessed with
personal knowledge, information, and belief as to the matters set forth herein, hereby
deposes and says as follows:
1. I am a named defendant in Kostick v. Russo. et al.
2. I operate La Fontana Restaurant in Lemoyne, Pennsylvania
3. My rent is generally due on the first of the month.
4. In past months, Paul Kostick has granted me more time to pay the rent if
I cannot on the first of the month.
5. In August of 1997, Paul Kostick agreed to give me additional time so that
I could pay August's rent
6. Sometime at the end of the first week of August, Paul Kostick agreed that
I could pay the rant by the 20th of August
7. At ':00 p.m. on Monday, August 15,1997, I tried to pay my rent to Helen
Wood.
8. She would not take the rent and told me that Pau/'s Iawyw said she COl tIc:/n't
taIat the f1II'It.
9. I asked her to give me a nobt to show that I tried to pay the f1II'It. I gaw
that nca to my Iawyw.
10. Later I found out I was being sued ~..I didn't pay the f1II'It.
PETER J. RUSSO, ESQUIRE
PA Supreme Court ID: 72897
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
Attomey for Defendant Russo
PAUL L KOSTICK tie . IN THE COURT OF COMMON PLEAS
.
PLK PROPERTIES, . CUMBERLAND COUNTY, PENNSYLVANIA
.
Plaintiff .
.
.
.
Y. . NO. 97-4452
.
.
.
V1NCENZO MARCHIANO and .
.
GU/SEPPE RUSSO, .
.
DefIIndants .
.
Atm..HEYl..MmE8
AND NOW, COMES Defendant. Gulseppe Ruao, by and thraugh his IIIo.ney,
PttIIr J. Ruuo and 8nS\1.I11 Plaintlfrs Complairlt In Confeulon of Judgment for
Ej.,h._1t and lMl'S the fallowing in support thlleof.
1. Adlllltted.
2. Adtultbod.
3. Aclrr6o.d.
4. Denied. Defendant lacks sufficient knowledge or information so as to form
a belief as to the truth or falsity of the averment in paragraph number four. By way of
further response, Defendant admits that attached to Plaintiff's complaint was a property
description and avers that said description is a written document Which speaks for itself.
5. Denied as stated. Defendant lacks sufficient knowledge or information so
as to form a betief as to the truth or falsity of the averment in paragraph number five. By
way of further response, Exhibit B of Plaintlfl's complaint appears to be a copy of a lease
8llecllt8d by Francesco Failla but as a written document, said exhibit speaks for itself.
6. Denied as stated. Defendant lacks sufficient knowledge or infonnation so
as to form a belief as to the truth or falsity of the averments in paragraph number six.
By way of fLI'ther response, Exhibit B of Plaintifl's complaint appears to be a copy of a
lease executed by Francesco Failla but as a Writt8n document. said exhibit speaks for
itself.
7. Denied as stahod. The co.lbo. a. of the IMlr'IlW1tS in paragraph number
lIMn are ~ to a writtan document which speaks for itself and any intwp.~
gloa placed on said document by Plaintlff Ia denied.
8. 0eniec1 The lIYWm4lf\ta SlIt farth in pII'agI'aph eight COl ~, 1ItlIltWl.....
wtlic:h do not r'IIqIJQ . response. In the lMnt any portiCll. at the a\WTl1o.1tlo In ~
eight.. dllllltodt.l"'ftlA\, O"1dw1t f\.-o lIlc:Ica tutIIciellt Icnonttdg. or if~ 10
as to form . belli as to the truth or WiIity at the ~ in I*lQlaph tigtlt.
9. Denied as stated. The averments set forth in paragraph nine contain
conclusions of law to which a response is not required. Additionally, the Lease is a
written document which speaks for Itself and any interpratatlonal gloss placed on said
Lease by Plaintiff is denied.
10. Denied. The averments set forth in paragraph ten contain conclusions of
law to which a response is not required. In the event any portion of the averments in
paragraph ten are deemed factual, Defendant Russo denies the allegation that he was
in defau/t of the terms of the Lease by faiting and refusing to make the monthly rent
payment in a timely manner as Plaintiff granted Defendant Russo an extension of time
in order to submit Augusts rent payment which extended beyond August 15, 1W1, the
datil which Defendant Russo attempted to remit the required rent payment to PIaintifrs
agent. Said payment was rejected by Plaintifl's agent prior to the Initiation of any suit
11. Denied. The averments set forth in paragraph eleven contain statMlents
which do not require a response.
12. Denied. The averments set forth in paragraph t'ftlve cantain ~lla
which do not r.quinI.response.
13. AdmIbd.
14. Denied. The averments set forth in paragraph fourteen contain conclusions
of law to which a response is not required. By way of further response, Plaintiff failed
to comply with the provisions of the warrant of attorney as set forth in the lease
agreement. Additionally, the Lease is a written document which speaks for itself and any
interpretational gloss placed on said Lease by Plaintiff is denied.
WHEREFORE, Defendant demands a judgment dismissing this suit in his favor
and against Plaintiff.
tfm.MA1IER
1. Defendant. Guiseppe Russo never signed a lease agreement with the
PlaintIff which COlitained a COtlfession of judgment clause or warrant of attorney.
2. Defendant. Guiseppe Russo was, at all times relevant hel eta, without ben8IIt
of 8dvlc:a and direction from legal counsel.
3. At various times, Including, but not Imlted to, August of 1997, PIalnlIf
l..wMd the rights pnMded in Article 2 of the subject lease Bgl ~ by gi" dIllg
DafJndant Rullo an tllCtIInIicn of time In ordw to remit t8I1t paymecD.
4. On AuglIIt 15. 1887 at 1 :00 p.m. 0IIfendant rwnltI.s to the PIIIntitf the UTI
of One ~ Two Hu'.cIlwd Fifty ($1,2!50.00) oc...... in lawful money of the UnIId
9t -. I. wI'Iic:h Is ... ImClLI'll cMnw lded in I'lia COlI~"1l
5. lhe ~ ~lt QI'I ....9.. 15. 1917 .. 1:00 p.rn. .. refund by
Pl.iQlIIf. .... Helen Wood.
.--
.;;1
~ ~~'.-:-'
~....~.:. :~;~~~.
-;:.:.::.,.........{lO:
:-.~-.....:~..
'::A/~;:'~
,'~.
,,~~:.::
-_.7"'-:-~'
-~~:
~ .;"'":. .:'7:3',
....
'",-
...........
.'
.. ~.
-.
.~..:
,,' ",:-
-'~"
,;
_..~.
- ..
~
.
~
:~"'~'"7
-.
.
~..
. .
~---.
,-"t.. . ~_
.. .t.....
-~~...~..
':.~-::-
" ....
?;'
,
."-'.-..
.
-
-
-
..
-
-
.. .
~
,
.-,-.
'-, ~
.
_.
.:- ".. .-.,....-r. .: _. ..... '~~_._ __.__'":.". ,;...
:.....~... . _. .....:. .... -' ...'-
.....-~ - ~.~ ........,~. Y. '~"":,-,-.t..~ ~~.~.
''',\ - ~:,L. .~._~..~..'jr; __L 7"". '~~'~" .,. -l'
~. ," ... .-, ."~" - ........ ~ -- .............
-. ~~-: ...~.~~ -...., j .... ~\Ifr~-:--~.~'" . _ ..
" .....~ - --~'.~"-' .; ~,....._.... ..
.... ~~~'.., ..,_........~- . ~ .,~-~.. ~f~:~::......~...~~
.,.::.:......:.~.... -_ - _. - - OJ..... _
:' ~.~~ .... - .....~ ....~... - ...., .... ,--',.,-- ..~
"..._"'~.'- . ~-J - ~-"~_."':."'t-.--:",-
"........ '.. '\' ~
,. .~..-~,_ .~. . .._....:._...... .............'"t~........_ "''"'' ."",,:
... -~-....... "... -..-, .... '" ......... ,-": . ,.~._.,
........ ~-- . ........
. ~_..".... '*
. ~1
-'
.
.. . .:."
., .
~"",'
..
.,
,
. .'.
'l.-,-:,... .~-
'l .,~t'" ""-
.-.
"'$: . -
. -., -.
, "-
. .'
'" ,-.
.
"
-.
. .....;.
"ji. i_
..
." .
-
~
-
- .-
..
....
--=-
EXHIBIT A
The undersigned Affiant, being duly sworn according to law and possessed with
personal knowledge, information, and belief as to the matters set forth herain, hereby
deposes and says as follows:
1. I am a named defendant in Kostick v. 8usso. et al.
2. I operate La Fontana Restaurant in Lemoyne, Pennsylvania.
3. My rent is generally due on the first of the month.
4. In past months, Paul Kostick has granted me mora time to pay the rent if
I cannot on the first of the month.
5. In August of 1997, Paul Kostick agreed to give me additional time so that
I could pay August's rent.
6. Sometime at the end of the first week of August. Paul Kostick agreed that
I could pay the rent by the 20th of August
7. At 1:00 p.m. on Monday, August 15,1997, I tried to pay my rent to HelIn
Wood.
S. She wauId not take the fW1t and told me that PauI's Iawyw Slid she ccuIdn't
take tM rft.
9. I asked her to giw me a nobt to show that I tried to pay the ttnt. I;IM
that nobt to my taw,..,..
10. Later I found cut I wa *"g ..-1 ~_I didn't pay tM lW'lt.
11. I came to this country from Italy several years ago and I started a family and
a business.
12. I have never been to school in the United States.
13. At times, I have difficulty with English, especially with large words and legal
terms.
14. When I agreed to operate La Fontana I did not have a lawyer to represent
me. Everyone told me that I didn't need a lawyer.
15. I never knew that I gave up any rights when I took over the business.
16. No one ever explained to me that I gave up any rights when I took over the
business.
17. The foregoing statement, consisting of sixteen (16) numbered paragraphs,
having been made under penalty of law, is true and correct to the best of my knowledge,
information an belief.
This AtIIdavit is made subject to the penalties of 18 Pa. c.S. S4904 relating to
unsworn faIsiftcation to authorities.
Data: V.... -'tv Ai...... 27 111I7
('.... ~ ',:.' C)
"_I :,
~-",'
1 ,
.;
, ..
t"..: J
>
.,
--1
"...; -...
'" ..... <<2:
...,.. ~.
-~ -
or ~. -
....'_. :s:: ,-
:: - -;<<2:
.. ... .~ -;.
. ,of
... c:o .--
IL ~0
C' ~
, ~
.;1. en ~:.. :z:
=-, w
k:> g
..... 0-
0 -
~
r
~
i!: -: ~_
i 3 j
:i ~ ~ --:<-
p~
l;j'::l
~i
m~
O::T
...
III
8
&
~I~ilbl
.:, If.' S
...,J ~. en a
U1 0 ~
b' a. ~ :-
"''0 R
g~8' ::T ~
...B. ~ e
~' 'tl ii
""~ It I::
~ a.~
...' "'.Q
o .
U1
..
::<
~
~~
- .
i
,
~,
-..
.- :;;
-'"
~'""!
...""
-
- -
- ~
1
:;
:,'
-
..
1
.
....-
:A
~~
::.,~
~~
.1 ~
- -
;:\2
..,
~
s
,
e
.
,
2.
... ~ ... ....
;
.
...
~
o
o
U1
o
.
."Jt
~~
....
~r
!~
...~
m...
III n
'"
~
....
III
...
~2
"" .
-..,
--
=-
::::P.
- -
>:
2-::
- -
w'"
-~
.i.:_
- -
- -
2-
--
~;
. -
-7'
.,:-
.-. -
2w
22
:;:-
.;-
~~
~;,
;:.t:
2-
_ w
;,.~
Ev .'r:ueoi ;l\.""":'Il..,n ~'e ....J.7.tJl.mm...._:3\ .. ...:!.I!P.~~~~!!.~u......u._.__.... :r..?~..
r .:~".... ::hoe ..it:tin "'.1:": ..?~~.~..~:.~?!I.~}.c:~..~{..a...!'.~~..~:.~t>~r:~.~~~---........._..-...m___ .~
.~.. ?",,,,w.:n .?i ,i;r ?r=.,"", c.....:.b-.l l(IIJlaX~)IlWlJ(~x.1fJI ..!lO..H.u:ut..5Ueat...1.ellIO)U1a
...... r;.1.C:~.~~~J!!!.~ ..i.I}~.~ ~~.<:!.~C:!l_~. .f.r:?!'!.!':. ~!.C:!.r!~Y..~.~! !I.~}.~~. _!;?~p. ~~~~~~ ......! !.'-. .1.'!?.7.'
Sheriff's Costsl
$ 30.92 refund to atty
......-........---...-----....---.----....--------.--------.----------------.-------.---------------.-
69.08
....---.----------..-------------..---....----------.---_..__.._----~----------------------_.._--_.-
----_.- .. .-------------.--.---.......-.. -.. ..--...-.....-.....---..........---.---....----..-...
t
t
~
...
.,
...
...
U1
'"
()
...
<
...
....
~
~
1"
.~
t
, lr~.
....".~ .L"'tc. ~..,~; t)f>~ .;: ."'~ '~~....'.'.l". ~"'-........_._.,~
t ....J."'1t....~1,,~.._......._.._.... '.'!:L
,. \"'~~~~~
..... ~.~ .'~.....-.~ ......... .....~._...._>_._..'" ." ~.
:A ,1\ 'r
'''_. .,. , , il.___ . ..'
..On__ _~.. .. \...\.......~~.......
# f!'v....;, '\fl\~.. "
A
/.'-/
..t?1.lI.... ....
.".-."
.,.y~'
. ~ .; yI."t.-
",-.-~rrk ~ ......._. ~ .-. ..............-
-,..~:\
\ \\"