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HomeMy WebLinkAbout01-06665 ~}~1'i II i , . . Plaintiff ) ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SZELES REAL ESTATE DEVELOPMENT COMPANY, L.P., CIVIL ACTION - LAW vs. ARBROS COMMUNICATIONS. INC., Defendant NO. OI-/"'~I.'5'~ 0- NOTICE ..i' ._'il-. TO DEFENDANT NAMED HEREIN: YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO, THE CASE MAY PROCEED WITHOUT YOU, AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 ',,- -"-~/' ~-,'-,.~-, ~ II 'ii'- "", I, SZELES REAL ESTATE DEVELOPMENT COMPANY, L.P., Plaintiff ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. OJ- {. (, (, <;' ~ ~/:- ARBROS COMMUNICATIONS, INC., Defendant COMPLAINT AND NOW comes the above-named Plaintiff, by his attorney, Samuel L. Andes, and makes the following Cornplaint against the Defendant: 1. The Plaintiff is Sze1es Real Estate Development Company, L.P., a limited partnership which maintains its offices at 5112 Lancaster Street in Harrisburg, Pennsylvania, 17111. 2. The Defendant is Arbros Communications, Inc., a corporation which Plaintiff believes is organized under the laws of the State of Maryland, and which maintains offices at 1100 Wayne Avenue, 8th Floor, in Silver Spring, Maryland, 20910. 3. At all times relevant to this action, Plaintiff has been, and continues to be, the owner of a commercial office building at 4999 Louise Drive in Mechanicsburg, Cumberland County, Pennsylvania, known as the "Rossmoyne Corporate Center." 4. By a lease dated in February of 2001, and executed by the Plaintiff on 19 February 2001 and the Defendant on 13 February 2001, Plaintiff leased to Defendant office space within the Rossmoyne Corporate Center which consisted of 2,706 usable square feet, or 3,112 rentable square feet, for which the Defendant agreed to pay annual rent of $54,460.00, with escalations as provided in the lease, for a term of 60 months. Attached hereto and marked as Exhibit A is a copy of the said lease. 5. After the execution of the lease, the parties amended it by two separate amendments which are: A. Amendment No.1 extended to the Defendant a limited and conditional right to the early termination of the lease, provided that Defendant was in full '",-' .c-,,~,-~'-".' 'l;F " ., "" t, compliance with the lease and satisfied certain other conditions, none of which have been satisfied as of this date. Attached hereto and marked as Exhibit B is a copy of Amendment NO.1. B. Amendment No.2 modified the commencement date for the lease to 15 April 2001. A copy of Amendment No.2 is attached hereto and marked as Exhibit C. 6. Plaintiff has well and truly performed all of its obligations under the lease. 7. Defendant has breached its obligations under the lease and violated the said lease. Specifically, Defendant has failed to make the rental payments due for the rnonths of October 2001, and all subsequent months and have failed to make payment of late payments and other fees due in accordance with the lease. 8. Because of Defendant's breach of the lease and default of its obligations under the lease, Plaintiff is entitled, pursuant to Paragraph 34 of the lease, to accelerate the rent due for the unexpired term of the lease and to collect such rent from Defendant. 9. Because of Defendant's breach of the lease, and in accordance with Paragraph 34 of the lease, Defendant owns to Plaintiff, and Plaintiff is entitled to have and receive from Defendant, damages for such breach as follows: A. Rent due for the balance of the first year of the lease term (six months) $27,230.00 B. Late charges due for the month of October 2001 $226.92 C. Rent for second year of lease (with 3% escalation in accordance with Paragraph 27 of lease) $56,093.80 D. Rent for third year of lease (with 3% escalation in accordance with Paragraph 27 of lease) $57,776.61 E. Rent for forth year of lease (with 3% escalation ion accordance with Paragraph 27 of lease) F. Final year of lease (with 3% escalation in accordance with Paragraph 27 oflease) Total Due " ;""~-;'."-- ,," ',':P.:''' ",..";__,";'i'. ~~-~~ .", - ':-r-- -'j'''"<',- '.~. ":~",- ~, ", :,'}- .~' , "';>'~""'<" ~ .,.--- - , $59,509.91 $61,295.21 $262,132.45 - ?1j,r~ - II . . 10. Defendants, by their breach of the lease, have injured Plaintiff in the amount of $262,132.45, plus interest after 31 October 2001, plus the costs of suit. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $262,132.45, plus interest from and after 31 October 2001, plus costs of suit. ~~~ Samuel L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 ,'y,-<.,,- --~,.,,',,;,~,'"'" :~ II . . VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: 71 j 11/01 I "'0."-<"<_ STANDARD OFFICI!; LEASE' THIS LEASE is made between Landlord and Tenant named below. 1. THE PARTIES. (a) The name and address of Landlord is: Szeles Real Estate Development Company, L.P. 5112 Lancaster Street Harrisburg, P A 17111 (b) The name and address of Ten ant is: Arbros Communications, lnc. 1100 Wayne Avenue, 8th Floor Silver Spring, MD 20910 2. BUILDING AND PREMISES. (a) The name and address of the Building in which the premises will be located is: Rossmoyne Corporate Center 4999 Louise Drive Mechanicsburg, PA 17055 (b) The premises covered by this Lease are described as follows: 1st Floor: 2,706 usable square feet or 3,112 rentable square feet. 3. RELOCATION OF PREMISES. (a) Landlord may, at its option, before or after the Commencement Date, elect by written notice ("Relocation Notice") to Tenant to substitute for the Premises other office space as designated by Landlord in the Building ("Substitute Premises"), provided that the Substitute Premises contains at least the same usable square foot area as the Premises [and has a configuration substantially similar to that of the Premises]. [The Relocation Notice shall be accompanied by a plan of the Substitute Premises, and such notice or the plan shall set forth the usable square foot area of the Substitute Premises.] Tenant shall vacate and surrender the Premises and shall occupy the Substitute Premises promptly (and, in any event, not later than thirty (30) days after the later of (i) Landlord has substantially completed the work to be perf0n11ed by Landlord in .i{NIjf)!.'r -,' I ~',~,~" " '_ .,.,~ --, -I' ,_,_, A^ ,,""'.~'3jijt~JT ~" 0 the Substitute Premises, if any, pursuant to Patagraph 3(b) or (ii) the date of the Relocation Notice. Tenant shall pay the lessor of the same square foot rental or no more than 10% more than the then current rental on the Additional Rent and all other charges with respect to the Substitute Premises as were payable with respect to the Premises. (b) Tenant shall not be entitled to any compensation for any inconvenience or interference with Tenant's business nor to any abatement or reduction of Rent, Additional Rent or any other charges due under the Lease [,but Landlord shall, at Landlord's expense, do the following: (i) furnish and install in the Substitute Premises fixtures, equipment, improvements and appurtenances at least equal in kind and quality to those contained in the Premises as of the date of the Relocation Notice; (ii) promptly reimburse Tenant for Tenant's actual and reasonable out-of-pocket costs incurred by Tenant in connection with the relocation from the Premises to the Substitute Premises, including such costs as relocation of any telephone or other communications equipment, changes to stationery, etc.]. Tenant agrees to cooperate with Landlord so as to facilitate [the prompt completion by Landlord of its obligations, if any, under this Paragraph 3 and] the prompt surrender by Tenant ofthe Premises. Without limiting the generality of the preceding sentence, Tenant agrees (i) to provide to Landlord promptly any approvals or instructi9ns and any plans and specifications or any other information reasonably requested by Landlord and (ii) to promptly perform in the Substitute Premises any work to be performed therein by Tenant to prepare the same for Tenant's occupancy. (c) From and after the date that Tenant shall vacate and surrender the Premises to Landlord, this Lease (i) shall no longer apply to the Premises, except with respect to obligations which accrued on or prior to such date and (ii) shall apply to the Substitute Premises as if the Substitute Premises had been the space originally demised under this Lease. 4. TERM. The term of this Lease begins on the later of 60 days following Tenant receipt ofa fully executed Lease document or upon the substantial completion of tenant improvements. The term of this Lease ends sixty months after the Lease begins. 5. RENT. The yearly rent is $54,460.00 payable without demand, set-off or counterclaim in equal monthly installments of$4,538.33, subject to adjustment as provided in Paragraphs 26 and 27. Rent, Additional Rent, and all other charges are due on the first of each month. (a) In the event Landlord receives rent payment five (5) days after due date, Landlord shall be entitled to assess and collect, as additional rent, a late charge of 5% of such monthly installment and an additional 5% for each and every month the balance remains unpaid. 2 . ".'"., ',r ~ ". .~ , 6. LEASING CLAUSE. Landlord is the owner bfthe Building and has full rights and authority to make this Lease. Landlord hereby leases the Premises to Tenant in accordance with the provisions ofthis Lease. Tenant hereby accepts this Lease. 7. NOTICES. A requirement in this Lease that notice be given shall be satisfied by actual notice in writing: if to Landlord, at the address shown in Paragraph 1; and if to Tenant, by delivery to Tenant at the Premises with a copy mailed to Tenant at the address shown in Paragraph I, Attention: Facilities Manager. 8. ENTIRE AGREEMENT. This Lease constitutes the entire agreement between the parties and may be amended only by written agreement of the parties. No agreement will be binding upon Tenant unless signed by its President, a Vice President, or a Secretary of the corporation. 9. SUCCESSOR AND ASSIGNS. This Lease is for the benefit of and is binding upon the parties hereto and their respective heirs, executors, administrators, successors and assigns. 10. OCCUPANCY LEVEL. The systems in this building are designed to accommodate up to one employee for every 100 square feet of office space. The Tenant agrees to limit the density of occupants within the suite to no more than one (1) person for every 100 square feet occupied. If at anytime during this Lease Tenant exceeds this ratio, it is the Tenant's sole financial responsibility to make any modifications within the suite necessary to insure the suite meets all applicable federal, state, and local codes. 11. ASSIGNMENT. Tenant will not assign this Lease or sublet the Premises or any part thereof, except to a subsidiary or affiliate of Tenant, without the prior written consent of Landlord, but such consent shall not be unreasonably withheld or delayed. An assignment or subletting will not release Tenant from Liability under this Lease. Upon any assignment or subletting of the Premises, Tenant shall immediately provide Landlord with a true and correct copy of the assignment or subletting agreement. 12. ENJOYMENT OF PREMISES. Landlord covenants that Tenant will be entitled to peaceful and quiet enjoyment of the Premises during the term of this Lease. Landlord will maintain the character of the Building as a first-class office building. 13. INSPECTION AND REPAIR OF PREMISES. Landlord shall inspect and repair the Premises at reasonable times with the consent of Tenant, which consent shall not be unreasonably withheld or delayed. Landlord may make emergency repairs without 3 q"",~ .C' _._~~^' ~"."._ "" ., ,~. I!""""'" - ._~, p , ' ~,! II I I I :1 I ! I I , I I :1 'I :-! :-:1 I ,I :1 ,I 'I :1 ':! :1 ,I ! II 'I , " :1 " ,I :1 .-; '-.-r~fJ_4, r_. Ten~nt's co~sent. In making any repairs to the Premises, Landlord will take reasonable measures to protect Tenant's property and personnel from loss and injury and to avoid disrupting Tenant's regular business routine. Landlord may show the Premises to prospective lessees at reasonable times during the last six (6) months of the term. 14. DAMAGE TO PREMISES. If the Premises or Building are for any reason so damaged as to become totally or substantially untenantable, Landlord or Tenant may thereupon, by written notice to the other within thirty (30) days of the date ofthe damage, end the term of this Lease effective as of the date of the damage. If the term is not so ended or if the Premises or Building are for any reason damaged to a lesser extent, Landlord will promptly restore the Premises or Building to its previous condition. In the latter case, a just proportion of the rent, according to the extent that the Premises or Building are untenantable, will abate until the restoration is fully completed. 15. EMINENT DOMAIN. If the Premises or Building, or any part of either, is taken by the right of eminent domain, which such taking renders the Tenant premises untenantable, Tenant may thereupon end the term of this Lease, effective as of the date of such taking. If the term is not so ended, ajust proportion of the rent will abate, according to the extent the Premises are untenantable. 16. TENANT'S OBLIGATIONS. (a) Tenant will conduct its business in a quiet, lawful and orderly manner and in such a way that will not interfere with or be disruptive to other Tenants in the building. (b) Tenant will pay the rent on the first day of each month to Landlord or to whomever Landlord may from time to time name in writing. (c) At the end of the term, Tenant will remove its property from the Premises and will surrender the Premises to the Landlord without further notice and in as good a condition as when entered by Tenant, except for loss or damage resulting from hostile or warlike action in time of peace or war, unavoidable accident, ordinary wear and tear, or perils covered by the standard fom1s of fire and extended coverage insurance policies. 17. LANDLORD'S OBLlGA nONS. (a) Landlord will deliver the Premises to Tenant on the occupancy date in good condition. (b) Landlord. will carry standard fire and extended coverage insurance policies on the Building and Premises. -l "< , ,''''-" - ~ ,. ""'1-1'" I,'",' - -~ (c) :Landlord will maintain the Building, the Premises, and any parking lot, Building grounds or appurtenant structures without cost to Tenant in a first-rate manner. (d) Landlord will furnish the following facilities, maintenance and services without cost to Tenant with first-rate materials and in a first-rate manner: (1) Electricity for lighting and customary office machinery. (2) Elevator services. (3) Such repainting as is necessary to maintain Premises in first-class condition. (4) Sufficient heat, air conditioning and fresh air supply to keep the Premises comfortable for office use throughout Tenant's regular business hours. Landlord hereby agrees .that the lighting, heating, air conditioning and ventilation systems of the building will be operational Monday through Friday, from 7:30 A.M. to 6:00 P.M. and 8:00 A.M. to 1:00 P.M. Saturdays to provide the above-mentioned comfortable office environment (climate control). Overtime, i.e., other than during the hours specified above, usage of HV AC and lighting in the office building will be monitored by the computerized mechanical systems. This overtime usage will be billed at a rate of$7.50 per hour per 1500 square feet. Not withstanding the foregoing the Tenant shall have access to the Building and Premises 24 hours per day, 7 days per week, 365 days per year. (5) Adequate toilet facilities, hot and cold water, and sewage disposal. (6) Refrigerated drinking water. (7) Complete janitor service, including the following: Dailv (except Saturdays, Sundays and holidays): Vacuum floors in Premises and all Building areas used by Tenant; dust furniture, equipment, woodwork, etc. in Premises; clean ashtrays and empty wastebaskets; and wash all fixtures and floors in toilet rooms. Monthlv: Wash vinyl tile floors, inside window surfaces, and partition glass. Semi-annuallv: Wash exterior window surfaces. Annually: Wash lighting fixtures and lamps. 5 .4,~ , ,,_~J _~ 0 ~ ~" < . . " ~ ",~~~"..,,~ As necessary: Replace fluorescent lamps and ballast. Wash walls, ceilings, , partitions and venetian blinds, clean draperies. Spot clean and shampoo carpet; provided, however, that the frequency of washing ofthe walls, ceilings, partitions and venetian blinds, and cleaning and shampooing the' carpet shall not be any greater than quarterly. 18. ELECTRICITY EXPENSE. Landlord agrees to pay all electric costs for the facility up to $2.00 per rentable square foot. Any cost over this amount will be billed to the Tenant on a pro rata basis. This facility is 58,000 rentable square feet. Tenant's proportionate share of this facility is 5.36%. 19. LIABILITY AND INDEMNITY. (a) Tenant shall store its property in and shall occupy the Premises at its own risk and releases Landlord to the full extent permitted by law from all claims of every kind resulting in loss of life, personal or bodily injury or property damage. (b) Landlord shall not be responsible or liable at any time for any loss or damage to the Tenant's equipment, fixtures, merchandise or other personal property of Tenant or Tenant's business. (c) To the extent covered by Tenant insurance required per this Lease and subject to the terms outlined in Paragraph 21, Landlord shall not be responsible or liable to Tenant or those claiming by, through or under Tenant for any loss or damage to either the person or property of Tenant that may be occasioned by or through the acts or omissions of persons occupying adjacent, or adjoining Premises. . (d) To the extent covered by Tenant insurance required per this Lease and subject to the terms outlined in Paragraph 21 Landlord shall not be responsible or liable for any defect, latent or otherwise in the Premises or in the building or any of the equipment, machinery, utilities, appliances or apparatus therein. (e) Tenant shall indemnify Landlord and save it harmless from suits, actions, damages, liability and expense (including reasonable attorney's fees) in connection with loss of life, bodily or personal injury or property damage arising from or out of any occurrence in, upon or at the Premises or the occupancy or use by Tenant of the Premises or any part thereof, or occasioned wholly or in part by any act or omission of Ten ant, its agents, contractors, employees, servants, invitees or licensees. Tenant shall, at its own cost and expense, defend any and all suits or actions (just or unjust) which may be brought against Landlord or in which Landlord may be impleaded with others upon any such above mentioned matter, claim or claims. 6 ;-CWil'~ {J'J~ . "~,_ ~= ,~, ," 'I, _ ~--, ,...,., - -~ ~- -_'t!~,,,,,__,,, (f) Tenant agrees tobe responsible for any damage'to the property of Landlord which may result from any use of the Premises or any act done thereon by the Tenant or any person coming or being therein by the license or permission of the Tenant express or implied. (g) Tenant shall provide at its expense and keep in force during the term of this Lease, general liability insurance in a good and solvent insurance company or companies licensed to do business in the Commonwealth of Pennsylvania selected by Tenant and approved by Landlord. Certificates of insurance shall be provided to Landlord prior to the commencement of the Lease and evidence of renewal of the coverage shall be furnished to Landlord at least thirty (30) days prior to the date upon which any such insurance expires. Without limiting the foregoing, Tenant shall provide a minimum of Two Million Dollars ($2,000,000.00) in liability insurance against damage to person or property and shall name Landlord as an additional insured. 20. ALTERATIONS AND INSTALLATIONS BY TENANT. (a) Provided that this Lease is in full force and effect and Tenant is not otherwise in default of any of the obligations by it to be performed hereunder, the Tenant may, at its expense, make such interior, non-structural alterations and improvements to the Premises or install interior partitions as it may require, provided that such alterations and improvements are done in a workmanlike manner in keeping with all applicable building codes, ordinances, and regulations, and in no way harm or impair the structure of the building or the Premises or diminish the value thereof. At the expiration date or sooner termination of the Lease term, Tenant, if requested to do so by Landlord, shall restore the Premises to substantially the same condition as existed on the commencement date and repair any damage thereto resulting from the installation or removal of any such improvements, partitions, fixtures or equipment as may have been so installed by Tenant. (b) All of such changes, additions or alterations shall be made solely at the expense of Ten ant and Tenant agrees to protect, indemnify and save harmless the Landlord on account of any injuries to third persons or property, by reason of any such changes, additions or alterations, and to protect, indemnify and save hamlless Landlord from the payment of any claim of any kind or character on . account of bills for labor or materials furnished or claimed to have been furnished therewith. (c) Tenant shall not permit any mechanics or similar liens to be lodged against or remain unbonded upon the Premises for labor performed or materials furnished to Tenant or claimed to have been performed or furnished to, on behalf of, or otherwise at the direction of or with the consent of Tenant, at, in, or upon the 7 ~ ,"^~r=""_, -_'," - -,-," \ . Premises, whether such work was performed or materials furnished before or . after the commencement of the term of this Lease. (d) Excepting those items which Landlord specifically requests be removed from the Premises, any alterations, additions improvements and fixtures therein installed or paid for by the Tenant, other than unattached movable trade fixtures and decorations, shall, upon the expiration date or earlier termination of this Lease become the property of the Landlord. 21. W AlVER OF SUBROGATION. Each party hereto does hereby waive, for itself and its insurance company, any right of or claim to subrogation against the other party as a result of any loss covered by insurance as provided for herein, but such waiver shall extend only to the coverage of such insurance. Provided, however, that if either party cannot obtain insurance as required by this lease solely as a result of this waiver of subrogation, such waiver shall be null and void and the parties shall meet and negotiate a solution to that problem and to the need by either of them for a waiver of subrogation as provided for herein. 22. SUBORDINATION. This lease shall be subject and subordinate to the lien of any present or future mortgage or Deed of Trust on the Building, the land upon which it stands, or both, or to any present or future underlying Lease without the necessity of any further instrument or act on the part of Ten ant. Tenant covenants and agrees to execute and deliver upon demand such further instrument or instruments evidencing such subordination of this Lease to the lien of such mortgage, Deed of Trust, or Lease, as shall be desired by any party thereto. 23. ESTOPPEL CERTIFICATES. Tenant shall, without charge, within ten (10) days after receipt of any request therefor, execute and deliver to Landlord a certificate stating: (i) whether this Lease is unmodified and in full force and effect (or ifthere has been modifications, that the Lease is in full force and effect and setting forth all such modifications); (ii) whether there then exist any defenses against the enforcement of any right of Landlord hereunder (and if so specifying the same in detail); (iii) The dates to which rent and any other charges hereunder have been paid by Tenant; (iv) The Tenant has no knowledge of any then uncured defaults under this Lease (or if Tenant has knowledge of any such defaults, specifying the same in detail); (v) That the Tenant has no knowledge of any event that will or may result in the termination of this Lease (or if Tenant has knowledge, specifying the same in detail); (vi) The address to which notices to Tenant are to be sent; and (vii) such other information as may be reasonably requested. It is understood that any such certificates may be relied upon by Landlord, any Mortgagee, prospective Mortgagee, Ground Lessor, prospective Ground Lessor, or purchaser or prospective purchaser of the Land or the Building. 8 "t""~r._~l",_"",,,,<=_ "._,'5",'_,,__ _ "'"""""1" ~" .~~ ~- - 24. INSOLVENCY. (a) The appointment of a receiver' or trustee to take possession of all or a portion of the assets of Ten ant, or (b) an assignment by Tenant for the benefit of creditors, or ( c) the institution by or against Tenant of any proceedings for bankruptcy or reorganization under any state or federal law (unless in' the case of involuntary proceedings, the same shall be dismissed within sixty (60) days after institution), or (d) any execution issued against Tenant which is not stayed or discharged within sixty (60) days after issuance of any execution sale of the assets of Ten ant, shall constitute a breach of this Lease by Tenant. Landlord in the event of such a breach, shall have, without need offurther notice, the rights enumerated in Paragraph 33 herein. 25. SUBST ANTrAL COMPLETION OF PREMISES. Prior to the commencement date of this Lease, Landlord will substantially complete the following improvements in the Premises in a first-class and workmanlike manner, at no cost to Tenant: (a) Landlord will furnish and install all items appearing on Tenant's preliminary floor plans to be delivered to Landlord no later than January 25,2001, attached as Exhibit "A" to this Lease, including but not limited, to the following: (1) Floor to ceiling partitions constructed of lI," thick gypsum board on metal studs. All partitions and interior walls are to be decorative vinyl wall coverings of Ten ant's selection. (2) Doors and door hardware all as indicated on Tenant's plans. (3) Carpeting throughout the Premises of a type and quality to be approved by Tenant ($20.00 square yard price). During the term of this Lease, Landlord will be responsible for repair and/or replacement of the carpet when deemed necessary by Landlord due to ordinary wear. It is understood that Tenant will be using chair pads in the Premises. Landlord will also install all base molding throughout the Premises. Notwithstanding anything to the contrary contained herein, if carpet is damaged at any time during the term of the Lease as a result of negligence on the part of the Tenant, Tenant's employees, or agents, then the replacement or repair of the carpet in such damaged area shall be made entirely at Tenant's expense. Landlord will provide vinyl tile with rubber base in areas to be designated on Tenant's floor plans. (4) Suspended acoustical tile ceiling throughout the Premises utilizing factory finished tiles having a minimum thickness of 5/8 of an inch and a minimum Noise Reduction Coefficient rating of. 70. 9 "',,~~,,,. (5) Fluorescent lighting fixtures sufficlent to 'maintain a minimum of70 foot. candles of illumination uniformly distributed throughout the Premises at desk level, complete with acrylic lenses, lamps, ballast and switches. (6) Telephone conduit into the building adequate to meet telephone company's specifications for Tenant's telephone system installation. (7) Electrical outlets, all located as shown on Tenant's plans, and complete electrical wiring. (8) Lavatories, complete with all necessary plumbing and fixture. 26. MEASUREMENT OF PREMISES - COMPUTATION OF RENT. The rent stated in Paragraph 5 is calculated on the basis of $17.50 per square foot per year for the rentable floor space. Upon completion of the Premises, the floor space shall be measured by authorized representatives of Ten ant and Landlord to determine the actual rentable square footage according to the BOMA measurements standards. The square foot area resulting from this measurement shall be multiplied by $17.50 per rentable square foot and the result shall be the Adjusted Yearly Rent. Landlord and Tenant will execute an amendment to the Lease amending Paragraphs 2 (b) and 4 of the Lease to conform to the Adjusted Yearly Rent within thirty (30) days following completion of the measurements. 27. INCREASE IN ANNUAL RENT. The annual rent stated in Paragraph 5 for each subsequent year of this lease will be increased by three (3) percent, over the prior year. 28. PARKING. Landlord agrees that Tenant shall have the right to four (4) parking spaces at any time during the term of this Lease. Said parking spaces shall be located in the adjacent paved parking lot and may be used as Tenant requires. Landlord will keep the parking area clean, lighted, and in good repair. Landlord hereby agrees that during the term of this Lease, Landlord will maintain separate parking spaces for the subject premises, which spaces shall be clearly reserved for visitors to the Premises. It is understood that use of the parking area is a right shared in common with all other tenants and with the Landlord. 29. SIGNS. Landlord will pay the cost of the manufacture, foundation, construction, erection and maintenance of the Landlord's base building signs and will also pay for the cost of electricity when required. Landlord reserves the right to approve all Tenant signage. This is subject to the rules and ordinances of township or other governing body. 10 --.,.,~~,C[ ~~~ q -~ < ""'-'1.,' ;-'- 30. BUILDING DIRECTORY. Landlord shall im;tall, at Landlord's sole cost, Building Directories on the first floor of the Building. 31. SPECIAL EQUIPMENT. If Tenant shall use special equipment, such as but not limited to computer and related cooling equipment, Tenant agrees to separately meter such equipment and its accessories, and pay for the utility expense to operate the same, said payment to be to the Landlord as additional rent, or by direct payment to the utility company. Standard office equipment, such as servers, printers, and personal computers is not considered special equipment. 32. SMOKING REGULATIONS. Employees may smoke outside at the rear employee entrance only. If smoking is allowed in other areas ofthe Tenant Premises, exhaust fans will be installed in those specific areas at the Tenant's expense. 33. DEFAULT BY TENANT. IfTenant shall default in fulfilling any of the covenants or provisions of this Lease on its part to be performed and shall fail to remedy such default within ten (l0) days after Landlord shall have given Tenant written notice of such default or within such period as may reasonably be required to remedy the default, if the default cannot be cured within ten (10) days, then Landlord shall have any right, power or remedy permitted to it by law, except that Landlord shall not have the right to terminate this Lease unless it has given Tenant prior written notice of the date of termination. 34. REMEDIES OF LANDLORD. Upon default by Tenant, Landlord shall have, in addition to the remedies hereinabove referred to, the following remedies: (a) The right to terminate this Lease without any right on the part of Ten ant, or those claiming under Tenant, to reinstate the lease by payment or other performance of the conditions or provisions violated and, thereupon, any attorney may as attorney for Tenant, or those claiming under Tenant, at the request of Landlord, sign an agreement for entering in any competent court an amicable action and confession of judgment in ejectment to any term then past or present (without any stay of execution) against Tenant and all persons claiming under Tenant for the recovery by Landlord of possession of the Premises together with costs, including reasonable attorney's fees for which a copy of this Lease shall be a sufficient warrant; and (b) The right to accelerate the rent due for the unexpired term of this lease ahd to have any attorney, as attorney for Tenant, or those claiming under Tenant, at the request of Landlord, sign an agreement for entering in any competent court an amicable action and confession of judgment to obtain the right to enter the Premises for the purpose of taking possession of the Premises. (c) The right to enter the Premises for the purpose of taking possession of the Premises without liability to Tenant or those claiming under Tenant. 11 -~, --' -"', '-"'"-',"'-~-~- ., r"'" _ " ,~-" IC_ _ The warrants of attorney herein provided for shall not be exhausted by the exercise thereof but may be employed from time to time as often as any breach of the terms, conditions, covenants, or provisions of this Lease shall occur. Tenant, for itself and those claiming under Tenant hereby releases to Landlord all errors and defects whatsoever in entering such action or judgments or causing such writs of execution to issue. Tenant, on behalf of Tenant and those claiming under Tenant, further expressly waives all right to an appeal from, writ of error, or certiorari to any judgment, order, or decree that may be given or entered by any court against Tenant or those claiming under Tenant for rent, damages, costs, or any other charges payable as rent, possession or otherwise, and agrees that such judgment, order, or decree shall be final and conclusive upon Tenant and those claiming under Tenant. All of the remedies provided for at law or in equity or in any of the terms or provisions of this Lease shall be cumulative and concurrent. 35. ENVIRONMENTAL COMPLIANCE. (a) Tenant hereby covenants and agrees to use and occupy the Premises and to conduct its business and operations thereupon in full compliance with all applicable statutes, codes, rules, regulations and ordinances as they may change from time to time pertaining to the protection of the environment and to hazardous substances and hazardous wastes as those terms may be defined from time to time in such statutes, codes, rules, regulations and ordinances ("Environmental Laws"). (b) Tenant shall promptly provide Landlord with copies of an correspondence from or to the U. S. Environmental Protection Agency, the Pennsylvania Department of Environmental Resources or any other federal, state or local governmental agency which pertains to the Premises regarding but not limited to the following: (l)Tenant's compliance with the Environmental Laws; (2) any permits which Tenant may be required to obtain pursuant to the Environmental Laws; (3) any release or threat of release of a hazardous substance or hazardous waste which has occurred in the Premises. (c) Tenant shall immediately notify Landlord of its receipt of any notices of alleged violations of the Environmental Laws from any other party including but not limited to governmental agencies including request for information. (d) Tenant shall promptly provide Landlord with copies of any documents required to be kept or prepared by Tenant or maintained at the Premises pursuant to the Pennsylvania Worker Right to Know Act, 35 P.S. 7301 et seq.. and the regulations promulgated thereunder. (e) Tenant shall promptly supply to Landlord true and complete copies of all sampling and test results obtained from any samples and tests taken at or around the Premises. 12 'C-"_'._~,~o " ~ ~ 'N'f_~,J,,- -!t- , ' (f) In the event of any "release" of a "hazardous'silbstance" or "hazardous waste" by Tenant as those tenns are defined in any of the Environmental Laws, which release requires notification of any governmental agency, Tenant shall immediately notify Landlord of the release and provide a full, true and complete description of the release, the substances involved and the remedial efforts taken. (g) At anytime during the tenn hereof, Landlord shall have a right to enter upon the Premises to inspect the Premises and to evaluate Tenant's compliance with the Environmental Laws. Such right of access shall include a right to review Tenant's records pertaining to compliance with the Environmental Laws. Tenant hereby agrees to cooperate with Landlord in any such inspection and evaluation. (h) Tenant hereby agrees to indemnify, defend and hold Landlord hannless from and against, any and all claims, demands, judgments, suits, liens, actions and other proceedings, arising out of or relating to the removal, remediation, corrective action or cleanup of any hazardous waste or hazardous substance as defined in the Environmental Laws or any other proceedings or actions threatened, or brought for the enforcement of any Environmental Laws now or hereafter applicable to the Premises and resulting from or arising out of Tenant's use, operation and occupation thereof during the tenn of this Lease. Such indemnification shall include but not be limited to costs of investigation, engineering fees, attorney's fees, costs ofremediation and cleanup and future site maintenance. (i) Prior to the commencement date of this Lease, Tenant shall supply to Landlord a certificate of an officer or principal of Ten ant setting forth a detailed description of Ten ant's operation and the processes Tenant will undertake at the Premises, including a description and quantification of any hazardous substances and hazardous waste generated, manufactured, refined, transported, treated, stored, handled or disposed of at or from the Premises. Following the commencement of the Lease tenn, Tenant shall update this certificate in the event of any changes in Tenant's operations, or use of hazardous substances and waste. (j) All of the tenns and conditions of this section shall survive the tennination of this Lease agreement for so long as any liability may arise under the Environmental Laws with respect to the Premises. 36. REQUIREMENTS OF LAW. Landlord shall at its own expense promptly observe and comply with all present and future laws, ordinances, requirements, orders, directions, rules and regulations of the federal, state, county and city governments and of all governmental authorities having jurisdiction directly or indirectly over 13 -,""I"" -I -- . . ~ the Premises, Building or appurtenances or' any part thereof (including, but not limited to Title ill of the Americans with Disabilities Act and such regulations or standards as are or may be promulgated under- the Federal Occupational Safety and Health Act of 1970, or similar federal, state or local requirements pertaining to the Tenant's use of the Premises and the Building) whether the same are in force at the commencement of the term or may in the future be passed, enacted or directed. It is understood, however, that the Landlord is not required to procure any permits or licenses or certificates or other authorizations necessary for the Tenant to conduct its business in the leased Premises. Tenant shall at its own expense, promptly observe and comply with all present and future laws, ordinances, requirements, orders, directions, rules and regulations of the federal, state, county, and city governments and of all other governmental authorities having jurisdiction with respect to the operation of the Tenant's business. 37. RULES AND REGULATIONS. Tenant and Tenant's officers, employees, agents, and invitees shall comply fully with all ofthe rules and regulations pertaining to the Building, the Premises, and related facilities. Current rules and regulations, if any, are attached to this Lease as Exhibit _and they are made a part of the Lease as though fully set out in the Lease. The absence of rules and regulations at the inception of this Lease shall not preclude Landlord's adoption and implementation of rules and regulations at any time during the term of the Lease or any extensions or renewals thereof. Landlord shall at all times have the right to make reasonable changes, additions, or deletions to any such rules and regulations for the purpose of ensuring or enhancing the safety, care, cleanliness, maintenance, or preservation of the Building, the Premise, and related facilities, as well as for the purpose of preserving good order in and on the Building, the Premises, and its related facilities. Tenant and Tenant's officers, employees, agents, and invitees shall be bound by the adoption and implementation of rules and regulations and by any changes, additions, or deletions to the rules and regulations upon receipt by Tenant of written notice from Landlord setting forth the rules and regulations or the changes, additions, or deletions, as the case may be. Tenant shall be fully responsible and accountable for the compliance of Tenant's officers, employees, agents, and invitees with all such rules and regulations. A TT ACHMENTS AND DELETIONS. The following exhibits attached to this Lease form a part hereof and were attached hereto before this Lease was signed by the parties: EXHIBIT "A" - Floor Plan EXHIBIT "B" - Temporary Space Floor Plan ADDENDUM #1 14 .!~~-. o. ~I~-~, ' IN WITNESS WHEREOF, Landlord and Tenant have signed aJ;lddated this Lease. LANDLORD: TENANT: By ~~ Title: /Il1?n17 ~,:et/- Date: '2-1 ( .,/ltJtlt I By' ~ Szeles Real Estate Development Company, L.P. Date: ~ ( orporate Seal) APPROVED JAN 3 1 200\; ~, MBRDS co , UNICATI NS LEGAL DEPARTMENT :~ 15 . ,o~'ffl, .___ _,,.,.-_ ."q L . "~ '--' ~ ~N"_~_~ ADDENDUM #1. , , A. Temporary Premises: The Tenant will have the right to occupy and use temporary space in the facility as shown on Exhibit "B" to the Lease, rent free, commencing the earlier of February 1, 2001 or upon completion of the temporary space The temporary space will be delivered to the Tenant, builtout and in working order as shown on Exhibit "B" to this Lease. B. Tenant Improvement Allowance: Landlord shall provide Tenant a "Turn Key" buildout for the premises in accordance with the following specifications. All finishes and colors shall be selected by the Tenant. . 4 private offices. . 1 large training room (500-600 square feet). . I storage utility area. . 1 kitchen (100-200 square feet) with cabinets above and below sink and appropriate area and power for vending machines. . 2x4 drop ceiling. . Deep cell parabolic lights. · Electric for standard office use inclusive of the necessary (4 circuit I 8 wire power drops as discussed) for systems furniture in accordance with Tenant's final plan. . Vinyl wallcovering throughout. . Lees Faculty IV carpet throughout. . Vinyl base throughout. C. Base Building/Landlord's Work: Any asbestos or other hazardous materials in the Premises or in any rise/shaft or roofing material required for Tenant's conduit or equipment will be removed in compliance with all applicable laws. If such materials cannot be removed, all such materials would be abated in compliance with all applicable laws. The Building and Premises shall be in compliance with all applicable laws, codes and ordinances, including the American With Disabilities Act (ADA). Landlord shall guaranty the Base Building from latent defects throughout the Lease term. Notwithstanding any items constructed by Tenant, or base Building items effected by Tenant's construction, throughout the Lease term Landlord shall repair, maintain and replace all structural items of the Building, including the roof. D. Space Planning/Design: Landlord shall at Landlord's expense provide architectural and full design services and all documents associated with building the Tenant's space, provided that Landlord's architects and vendors supply the services. '-;.mWi~ ,-, -,". -p .. ,._-"~~- !liI E. Options To Renew: With six (6) months prior written notice for the Renewal, Tenant will have one (1) Option to Renew for five (5) years at a rental rate not to exceed $2.50 per rentable square foot more than the Tenant is paying in the last year of the original lease term, subject to the limit in the preceding sentence. The fair market value determination will be based on office space in similar Buildings and similar locations in the HarrisburgIRossmoyne area. If Tenant exercises its right to renew, Landlord and Tenant shall amend this Lease to reflect this renewal. F. Holdover: The Tenant shall have the right to holdover in the Premises at current rental rate for initial three (3) months and thereafter at 150% of the last month's rent. During such holdover period, the Landlord and Tenant will have the option to terminate the Lease with 30 days prior written notice to the other party. G. Audit Rights: On an annual basis, Tenant shall have the Right to Audit the Landlord's financial records related to the Building and the last three (3) years of Operating Utility Expenses. This audit right will pertain to utility charges only. H. Roof Rights: Tenant shall have the Right to use the Roof to install necessary antenna, satellite and/or global positioning satellite equipment, provided that the Landlord will have the right to approve the size and location of antennas and satellites and no more than 2 devices will be permitted on the roof. I. Tenant shall deposit with Landlord upon execution hereof $40,000.00 as security for Tenant's faithful performance of Tenant's obligations hereunder. If Tenant shall be in default in the payment of arty installment of rent hereunder, or otherwise defaults with respect to any provisions of this Lease, Landlord may, with notice to Tenant, use, apply or retain all or any portion of said deposit for the payment of any rent, any sum for which Landlord may become obligated by reason of Tenant's default or to compensate Landlord for any loss or damage which Landlord may suffer thereby. If Landlord so uses or applies all or any portion of said deposit, Tenant shall, within fifteen (15) days after written demand therefor, deposit an additional sum with Landlord in an amount sufficient to restore said deposit to the full amount. Tenant shall be entitled to interest on such deposit at the then-prevailing rate for similar deposits in the region in which the Building is located. If Tenant performs all of Ten ant's obligations hereunder, said deposit or so much thereof as has not theretofore been applied by Landlord, shall be resumed, without payment of interest or other increment for its use, to Tenant promptly after Tenant has vacated the Premises. Landlord shall deliver such deposit by Tenant to the purchaser of the Building in the event the Building is sold (or give such purchaser a credit against the purchase price in the amount of such deposit), and thereupon Landlord shall be discharged from all further liability to Tenant with respect to such deposit, provided Tenant is notified of said transfer and such purchaser acknowledges Tenant's deposit. ~ ."""-""'" ",? llfJ .-~ ..~ - "'-'", " 1- w, ( J. Tenant unconditionally grants to Landlord a conti~uirig security interest in and to all personal property of Tenant located or left at the Premises. The security interest granted to Landlord hereunder secures payment and performance of all obligations of Tenant under this Lease now or hereafter arising or existing, whether direct or indirect, absolute or contingent, or due or to become due. In the event of a default under this Lease which is not cured within the applicable grace period, if any, Landlord is and shall be entitled to all the rights, powers and remedies granted a secured party under the laws ofthe Commonwealth of Pennsylvania and otherwise available at law or in equity. Tenant agrees that it will execute such other documents or instruments as may be reasonably necessary to carry out and effectuate the purpose and terms of this Section, or as otherwise reasonably requested by Landlord, including without limitation, execution of a UCC-1 financing statement. Tenant's failure to execute such documents within ten (10) days after written demand shall constitute a material default byTenant hereunder and, at Landlord's option, Landlord shall have the right to execute such documents on behalf of Tenant as Tenant's attorney-in-fact. Tenant does hereby make, constitute and irrevocably appoint Landlord as Tenant's attorney-in-fact, and Landlord shall have the right to execute such documents in Tenant's name. 2 .,"'~t~;._,__. ,,~ . .~ 11 - "I ~,' , r- '[::7 ('l Jrp f 8 pI1J"l (A ,.., 1P . 'n u -1 ~ ~ 0 ? l 0 J 0 4-.) , (~ cjJ ~, ]J C ~Z7 D 0' /" P L q ~ 0 e ~ "), I~ ?; if \/" ~ (/.J l [;.'J ~I ~t c> ;1 t" "P r (! ir ';'1 ~I (I 13'11" /--- . -...} c--'-''---- I I:-.'-~"\ !! -"-~-'-"'I i'-. 'I ""'j '--~i-i I II :r'- ,,!!' I: l' ' I . \ . Ji i. \ Nl I I ! 1,001 :! i I 'ii il , " 'I: VI' :: ~L-II :::j". jl ----,..~' !i I, Jiil ':'-'- .J I II : 0\ . ':JI.__n~ iJ !. q 1~~~N~ ~~' I ---l 'I ... I ::: it r'" I j' ::='1-' .,c=n ~\)!'r:>\-c::i {2",,0 ,I _, ",_11 / l~' L-... I-i'~~:;, =,'lillD" _ . l.il ......l. ';l '>.-. " I , , '.' " "' ld -- l~d0c :100 100c cl 'ue[ rrJ~-'~_U: _ .-' ~'",_,>~ '_C''' '",- ~'I'" !~~~ //~~~~ ,~~q~ ,"'\.&:), '- 'J? ~ "1~ !' ,'~,~ ';JP ". '. '~/.~ ~-(-~\" ...")'~/ J.~'" '. v. '0./ f/ X )~ '.... 6'- ,.,\. ~'-" \.;:"~/i ' I "."),,- ) ~ '-_/ '....v-',-0-. '/.~ "', '~.f.~) ''', .....\0-1"- "-'-, ~", /<5:'.)1.//):/;:/ " -., ~.0'" " ,..' './ '. . " , , ,'),i.n. .- .... " ..-,.f< / , . ". ". , " l (~. ,.,"",. ( .' . . 20'2" ~.~.~~-~t: .~ ~ I ! l"'-" ,.rll. ..~ I I I ., I ~ / \ ,,"';__H;-, I '=l u'~ ~u I r" ; --,_." \ r.--'l r--'u,-----.-... r :' !,U( I riibJ'" " ~!&;c:;;l....~,~!=.1 ,r I' !. I bJ (\[ :L(.\ ,""'! 'I' ..'"-"t!,;~~ C.l,'--'I I 1-1 0', \ U 7~, r--irl'; -= I~~~I I Lr '1"7;~ i l~g~~ I - c.' ..-: I ! C':... ,,-_ ! ;..(.,l......J..._c:- Ii) I r I, I t ~ ., . 1=1 .~., I '=' 's I I , I ,--I j r'") T i p= .~~. : ~,~,J__r,'.I. = ; . u i I I"~ '-"" I I,' " ,-,,=-'- r ~ iLl I, <;;:,; tr' 'I rr II II' "- 1 --__,,' ,=;oL, ! "J I .Ii I iU . ON ~t~OHd tI ;:; I ,~J i 'f,,- i 00 0\ w = ",.. , ,..(k;~ I. _"_~ .' ) . STANDARD OFFICE LEASE ADMENDMENT AMENDMENT NO. I TO LEASE EFFECTIVE DATE OF LEASE: March 1,2001, or substantial completion offitout EFFECTIVE DATE OF THIS ADMENDMENT: March 1, 2001, or substantial completion of fitout LANDLORD: Szeles Real Estate Development Company, L.P. TENANT: Arbros Communications, Inc. LOCATION OF PREMISES: Rossmoyne Corporate Center 4999 Louise Drive Mechanicsburg, PA 17055 This lease is hereby amended as follows: Tenant has a one time option to terminate this Lease at the conclusion of the 361h month of the Lease. This option must be exercised in the following manner. Tenant will send written notification of its intent to exercise this option to Landlord along with an early termination fee of 555,000.00 no later than the conclusion of the 30th month of the Lease. 1fwritten notice or the early termination fee has not been received bv the Landlord by the end of the 30th month, this option is forfeited and the Lease c;ntinues in effect. Except as otherwise provided above, all tem1S and conditions of this Lease shall remain unchanged. IN WITNESS WHEREOF, Landlord and Tenant have signed and dated this Amendment. LANDLORD: Szcles Real Estate Development ,Company, L.P. TENANTrArbrOS Communications. 1nc.~ I ~v~ DATA 2001 Plamt,i1's Fhnlb't BY. TITLE: ~'1t7 DATE: ~~L<OI r ,~ ., ?", ,- ""'"T= T___~ ..' .I .' STANDARD OFFICE LEASE ADMENDMENT AMENDMENT NO.2 TO LEASE EFFECTIVE DATE OF LEASE: March 1, 2001 EFFECTIVE DATE OF THIS ADMENDMENT: April 15, 2001 LANDLORD: Szeles Real Estate Development Company, L.P. TENANT: Arbros Communications, Inc. LOCATION OF PREMISES: Rossmoyne Corporate Center 4999 Louise Drive Mechanicsburg, P A 17055 This lease is hereby amended as follows: The commencement date for this lease is changed to April15, 2001. The termination date is now April 14, 2006. Except as otherwise provided above, all terms and conditions of this Lease shall remain unchanged. IN WITNESS WHEREOF, Landlord and Tenant have signed and dated this Amendment. LANDLORD: Szeles Real Estate Development ~panY, L.P. BY: ~<. .'-'-- TITLE: N4n//7 k~,- DATE: ;'f/~./Ol I TENANT: Arbros Communications, lJ.C? J BY: ~""..h ,.f DATE: APPROVED Plaimill's Exhibit "'''[\~~~,J', '_,~ "", ,.<_, ~~,", "". ~ I, .' '-" - ""F'~ Ir- =?!J< - M \0 00 , ..-A" PHOI~E 110. ",. ."J. ,-' Jan. 12 200l 09: 20P~1 PI n...... , , '" , , ,..... " .(?' ~ , .-1')' / \.. "- .: ;.':-", "'- ....../ " "\ "'~'~ ' , 7( )j'\ "c, '',r-.....,;'v./ " ';,)'-/, , 'i:: '// ", '.z '" ~>? C' -", -', ~ (~, ,r.' / .\ /;i. ~ v' '\:-. ~~ ", ; V"~" /'::, (C' " , .~}".tr)' g;,;....z:". 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I r --- 1'" J I I... __.L 1,_=:1 I r"loAn~~ "]' ~AL__'i~~~L~ v....,i \-" \ ! i-I ij~li ~~ _. ....____1-- I L-:J , I--'--p . _.J I rl..L!'rCi A ["I 'n ,'. !..-l~! II.."" 11 , I ~, L.....-::.~=-~-,-.- {-"--, 1___1 , ...:;;;11 ,1:.---- ,,(;,OZ J .. ;) \".. l '-. ~, t"- OO '-0 " .~ J <l. .2- I;: I) 1- /1 ~IJ .1, I;:: 'r;<J ') ;:/j f) Gllt/ o ~ (. JI ifiJ ,~ \,fi :z g 3 tJ rJ..U! 4. jl [Ij 'r-~ i ~ 6 f ;; \/1 ~ l,..' v) ~ ~ 1 f2J o J) --J 4.. UCl. ~ ([ ~~) 9 ~ \.1 .:/1 {) ~.- '" ." ~. ," ''>~1~'''' ~"~--< >....."',.,< ',,' .. ..... ,. '>,., ~'~, " , ... ~ F ~ ~ 0 (-.-- ~ C e. -,... -rJ-I":;::;, ~ ~~:) ':::J -'- ',-" "- W r-,,] '- ..l;l CJ -..;. -- l;.l ~ ...c. 2;: C) ',' ... ~C' .... )> -c--: 0? ?\ z ::;! J'J 'e ,l:- "-"" -1!!liJifJSj~[l..l!l]1!, ~~~..,._~_.~m:'ti'i:I@lgr IT: ~~",_~"~~""""";W(;e'~~+~i):~~'8"~~'''''''''''(._'~C''P~':''B_;l'',,,,%C;;1" ,"-, ~ffll'~~~-'''1W"!iliij'~i'IT'l,~,Y0~'!i!'1~~!\M_JJ , - -- /1'~"" . ~, " SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2001-06665 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SZELES REAL ESTATE DEVELOPMENT VS. ARBROS COMMUNICATIONS INC R. Thomas Kline Sheriff of Cumberland County, pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,ARBROS COMMUNICATIONS INC by United States Certified Mail postage prepaid, on the 28th day of November ,2001 at 0000:00 HOURS, at 1100 WAYNE AVENUE 8TH FLOOR pILVER SPRING, MD 20910 and attested copy of the attached COMPLAINT & NOTICE , a true Together with The returned receipt card was signed by N. DAVIS 12/07/2001 on Additional Comments: Docketing Cert Mail Affidavit Surcharge 18.00 4.86 .00 10.00 .00 32.86 S~:/_/=~ ..----.- ..~ /~ / R. Thomas Kline Sheriff of Cumberland County Sheriff's Costs: Paid by SAMUEL ANDES on 12/11/2001 . Sworn and subscribed to before me this /Jt day of /JJpo.. tvJ ,;kn}/ A.D. Ctf{~en~'~ ""''''--C"'''"''''''or",~. ~,~ Pr '1"J1"'i''''1i"._.N ~I_'~. '-1- '-;;,..-;,. Complete items 1, 2, and 3. Als.o complete item 4 if Restricted Delivery is desired. . .. R~,~..Y,9.YL.na:~e and address on the reverse so.."tliat)~'Ei:can return the card to you. . Attach this card to the back of the mailpiece. or on the:.:ITont if space permits. 1. Article:Aadr.essed to: ltrbibs. Carmuni UQD ciie:YGe Silver ions, Inc. 8th Floor g, MD 20910 3. Service Type ~ Certified Mail 0 Express Mai o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Copy from service label) 70001670 0001 8790 0994 PS Form 3811, July 1999 Domestic Return Receipt 01-6665 civil. J02595-99-M-1789 . PIPER MARBURY RUDNICK & WOLFE LLP By: Jennifer E. Clark Attorney LD. No. 82390 3400 Two Logan Square 18th and Arch Street Philadelphia, Pennsylvania 19103 (215) 656-3300 PLAINTIFF: You are hereby notified to file a written response to the enclosed NEW MATTER within twenty (20) days from service hereof or a judgment may be entered against you. IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY CIVIL ACTION - LAW SZELESREALESTATE DEVELOPMENT COMPANY, L.P., CNIL TERM Plaintiff, CASE NUMBER: 01-6665 v. ARBROS COMMUNICATIONS, INC., Defendant. ANSWER AND NEW MATTER Defendant, Arbros Communications, Inc. ("Arbros"), by and through its attorneys, answers the Complaint filed by the Plaintiff, Szeles Real Estate Development Company, L.P. ("Szeles"), as follows: 1. Denied. After reasonable investigation, Arbros is without knowledge or information sufficient to form a belief as to the truth of the allegations in this paragraph ofthe Complaint and the same are, therefore, denied. By way of further answer, the allegation that Szeles is a limited partnership is a conclusion of law to which no responsive pleading is required under the Pennsylvania Rules of Civil Procedure. However, Arbros admits that the lease I.-.C" '~,~,',--, '''-'-, ~., '~,n"'!';'" "~"_, ~c_ 17,_,_r - agreement at issue in this proceeding, which is attached to the Complaint as Exhibit A, identifies the address of Szeles as 5112 Lancaster Street in Harrisburg, Pennsylvania 17111. 2. Admitted in part; denied in part. Arbros admits it is a corporation organized under the laws of the State of Maryland. Arbros admits that at the time that the lease was executed it maintained an office at 1100 Wayne Avenue, 8th Floor, Silver Spring, Maryland 20910. However, Arbros now maintains an office at 880 Elkridge Landing Road, Elkridge, Maryland. By way of further answer, after reasonable investigation, Arbros is without knowledge or information sufficient to form a belief as to the truth of the allegation in this paragraph of the Complaint as to what Sze1es believes regarding Arbros' address and the same is, therefore, denied. 3. Admitted in part; denied in part. After reasonable investigation, Arbros is without knowledge or information sufficient to form a belief as to the truth of the allegation in this paragraph of the Complaint that "[a]t all times relevant to this action, Plaintiff has been, and continues to be, the owner of a commercial office building at 4999 Louise Drive in Mechanicsburg, Cumberland County, Pennsylvania, known as the 'Rossmoyne Corporate Center.'" By way of further answer, Arbros admits that the lease agreement, which is attached to the Complaint as Exhibit A, identifies the subject property as Rossmoyne Corporate Center, 4999 Louise Drive, Mechanicsburg, Pennsylvania. 4. Admitted in part; denied in part. Arbros admits the allegations of this paragraph insofar as such allegations are substantiated by the lease agreement, which is attached to the Complaint as Exhibit A. That document, being in writing, speaks for itself and Arbros refers Szeles to that written document for its precise terms. By way of further answer, Arbros denies all allegations of this paragraph to the extent that they are inconsistent with the lease agreement. - 2- ::OC:12121/2001 "jO~(.r~,.!~" .' '~', ,~,__ 1, , r: ' '"-L-1 .' -"9""'''' -"""fI!.-- _'"_7~__ - 5. Admitted in part; denied in part. Arbros admits the allegations of this paragraph insofar as such allegations are substantiated by Amendment No.1 and Amendment No.2, which are attached to the Complaint as Exhibit B and Exhibit C, respectively. Those documents, being in writing, speak for themselves and Arbros refers Sze1es to those written documents for their precise terms. By way of further answer, Arbros denies all allegations of this paragraph to the extent that they are inconsistent with Amendment No.1 and Amendment No.2. 6. Denied. The allegations in this paragraph of the Complaint state conclusions of law to which no responsive pleading is required under the Pennsylvania Rules of Civil Procedure. By way of further answer, after reasonable investigation, Arbros is without knowledge or information sufficient to form a belief as to the truth of the allegations in this paragraph of the Complaint and the same are, therefore, denied. To the extent that these allegations are deemed factual, it is specifically denied that Sze1es has "well and truly performed all of its obligations under the lease." 7. Denied. The allegations in this paragraph of the Complaint state conclusions of law to which no responsive pleading is required under the Pennsylvania Rules of Civil Procedure. By way of further answer, after reasonable investigation, Arbros is without knowledge or information sufficient to form a belief as to the truth of the allegations in this paragraph of the Complaint and the same are, therefore, denied. To the extent that these allegations are deemed factual, it is specifically denied that Arbros breached its obligations under the lease and violated the lease and it is further denied that Arbros has failed to make the rental payments due for the month of October 2001 and all subsequent months and has failed to make payment oflate payments and other fees due under the lease. - 3 - ::OC:12121/2001 ,~"~~l "'0'5 '~" -"-,,,_~ . " ., T ~ .'- r-'_,_"'f c" ~ "~~ 8. Denied. The allegations in this paragraph of the Complaint state conclusions of law to which no responsive pleading is required under the Pennsylvania Rules of Civil Procedure. By way of further answer, after reasonable investigation, Arbros is without knowledge or information sufficient to form a belief as to the truth of the allegations in this paragraph ofthe Complaint and the same are, therefore, denied. To the extent that these allegations are deemed factual, it is specifically denied that Arbros breached the lease and is in default of its obligations under the lease. It is further denied that Sze1es is entitled to accelerate the rent due for the unexpired term of the lease and to collect such rent from Arbros. By way of further answer, Paragraph 34 ofthe lease is in writing and speaks for itself. 9. Denied. The allegations in this paragraph of the Complaint state conclusions of law to which no responsive pleading is required under the Pennsylvania Rules of Civil Procedure. By way of further answer, after reasonable investigation, Arbros is without knowledge or information sufficient to form a belief as to the truth of the allegations in this paragraph ofthe Complaint and the same are, therefore, denied. To the extent that these allegations are deemed factual, it is specifically denied that Arbros breached the lease and that Arbros owes to Sze1es and Szeles is entitled to have and receive from Arbros damages in the amounts listed in the Complaint. Byway of further answer, Paragraph 34 of the lease is in writing and speaks for itself. 10. Denied. The allegations in this paragraph of the Complaint state conclusions of law to which no responsive pleading is required under the Pennsylvania Rules of Civil Procedure. By way of further answer, after reasonable investigation, Arbros is without knowledge or information sufficient to form a belief as to the truth of the allegations in this paragraph of the Complaint and the same are, therefore, denied. To the extent that these -4- ::OC:12121/2001 ';'.~if"'~~'\:,'fr"'__ __">< _ ",' ~"" ,.-:.~_ " 'I , " "- .. '. -~ '-S"",'," ., '~'''''IM.I'~~."_. .' allegations are deemed factual, it is specifically denied that Arbros breached the lease and that Arbros has injured Sze1es in the amounts listed in the Complaint. NEW MATTER 11. Szeles has failed to state a claim upon which relief can be granted. 12. Szeles' claims are barred under the applicable statute(s) oflimitations. 13. Szeles' claims are barred by the doctrine of setoff. 14. Sze1es' claims are barred by estoppel. 15. Sze1es' claims are barred by waiver. 16. Sze1es' claims are barred or limited because Sze1es failed to mitigate its damages, the existence of which Arbros denies. 17. Arbros expressly reserves the right to amend this answer by way of adding affirmative defenses, counterclaims, cross-claims and/or third-party claims as additional facts are obtained through further investigation and discovery. WHEREFORE, the Complaint having been fully answered, Arbros demands entry of judgment in favor of Arbros and against Szeles together with costs of suit, attorneys' fees and such other and further relief as is just and appropriate under the circumstances. ~i?~R~ A rney for Arbros Communications, Inc. Piper Marbury Rudnick & Wolfe LLP 3400 Two Logan Square 18th and Arch Streets Philadelphia, Pennsylvania 19103-2762 (215) 656-3300 Of Counsel s:I' Dated: December~, 2001 - 5 - ::OC:12121/2001 '-_~:-1~' .~ r, I'r- -~ ., 1-0, c. ,"< -" . , VERIFICATION I, Jennifer E. Clark, state that I am an attorney with the law firm of Piper Marbury Rudnick & Wolfe LLP; that I represent defendant Arbros Communications, Inc. in this action; and that I am authorized to make this verification on behalf of Arbros Communications, Inc. I am making this verification because Arbros is located outside of the jurisdiction of this Court, and the verification of an employee of Arbros could not be obtained within the time allowed for filing this pleading. The statements made in the foregoing answer and new matter are true and correct to the best of my knowledge, information and belief, based on my own investigation and information I have received from Arbros. I make this verification subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. b'~.0A>~(7~ ifer E. k ~ Dated: December c2/ ,2001 <'!"Wi;~' ~'.' ~ _' "'_~""',_ tt ,__!,,_ '" _'"", '7_',:'1-t "0 " ,~l I ,~ ''--"" _ < ~, . - r " .. \<~'W,~ " CERTIFICATE OF SERVICE I HEREBY CERTIFY that, on this d I V" day of December, 2001, copies of the foregoing Answer to Complaint were sent by first-class mail, postage prepaid, to the following: Samuel L. Andes, Esquire 525 North 12th Street Lemoyne, Pennsylvania 17043 ~*~~ 'fer E ark _'n ~ !-'. ._~. '~>::."""'. -~T'I I ' " ;--,1', ~~ -. -'~ ,'~ r .!nl~,"", -" ,.~ ," , ,~~~ " '0 ~ "" ~"- .~"~ *r..'"_ ,-,. _ ~_ _J'_' _,_"'" (") C ? -oO:J O)CU .#-.--"-! ZC (j) r-~~ =<. :LJ= '20 :r-~(") ~g ~ o c::> ,-il ,.., f"" cr> -0 ::J: ~ '..TI ~ - r' :---: -, '.',;0 ~~ s..B :'::)f'n S. ~ ES BIf _ ",:~E!'j,~_1J!iS~,~;gq;'!,,":''''",<;K1'17!g;!I'W",-;'''-%'!fr'''~~~Tflii;'li~~~~1J_:U!!p~J'f -. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND 'COUNTY, PENNSYLVANIA SZELES REAL ESTATE DEVELOPMENT COMPANY, L.P., vs. CIVIL ACTION - LAW ARBROS COMMUNICATIONS, INC., Defendant NO. 01-6665 PLAINTIFF'S REPLY TO DEFENDANTS NEW MATTER AND NOW comes the above-named Plaintiff, by its attorney, Samuel L. Andes, and makes the following Reply to Defendant's New Matter in this action: 11. No answer required because these represent conclusions of law. However, to the extent that an answer is required, Plaintiff denies those statements and avers that its Complaint states a valid claim upon which this court can grant relief. 12. No answer required because these represent conclusions of law. However, to the extent that an answer is required, Plaintiff denies that its claims are barred under any applicable statute of limitations. 13. Denied that the Plaintiff's claim is denied by the doctrine of setoff. 14. Denied that the Plaintiff's claim is denied by estoppel. 15. Denied that the Plaintiff's claim is denied by waiver. 16. Denied. Plaintiff has acted promptly and properly in an effort to mitigate its damages and it is Defendant who has failed to mitigate its losses in this matter. 17. Denied. Plaintiff denies that Defendant has any basis to amend its answer in the future to add affirmative defenses, counterclaims, cross claims, or third-party claims. To the extent any of those claims exist they are, or should be, known to Defendant and must be pled at this time. ~WJ~ m el L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 .', '-~', ,. M'i VERIFICATION I verify that the statements made in this Reply to New Matter are true and correct. I understand that any false statements in this Reply to New Matter are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: 1/ If /0"2- I I ~ A. Richard Szeles Managing Partner l' I ~ ' i .~~ ,--"..' ,<.,_J,U__,.7"""!'",'!;,..-_,_I~_ ". " W_F':ilil .' ~ ~"'" -.. .' -~." ""=--"',..,.,.!""'~~ b",,",<" '""," '" '~'-'I- ._~ .= o ~:; ;.J;-:;:-~ ~Q::: CD :::'- E;i~:-; ~:;,."-- ~2; '":;7 '"1 -, -" C':) P,..:' -'-"-" '-- J~ . t=:: _'_ )~~iJ~;_1_T;!jl-~~~!!f_l;<-OO~Wf,~"'f3l1:l!~lP.!~~~,~~,lEi~:: _~~,~ ~ II Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SZELES REAL ESTATE DEVELOPMENT COMPANY, L.P., vs. CIVIL ACTION - LAW ARBROS COMMUNICATIONS, INC., Defendant NO. 01-6665 CIVIL TERM PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned matter "settled and discontinued." 19 April 2002 ~ Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 ~; " . .--"'~, ". ", .-. ",. - . _ ~_..' .".' '0',.' - , ~,""""" .,. 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