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HomeMy WebLinkAbout99-00265 . 21, Denied, 1>lalntlff spedflcally denies that It fnlled to procure n tennnt for the Defendant, By way of further llllswer. Plaintiff contacted nnd Introduced to Defendant, n representative of KidsPeace National Center for Kids in Crisis, Jnc" the eventual tenant of the property in question. 22. Denied. The allegations contained within Paragraph 22 of Defendant's New Matter relate to and concern the terms and conditions of a document which speaks for itself, By wny of further answer, nt all time material hereto, Plaintiff ncted with all due diligence in procuring and attempting to procure tennnts for the Defendant. 23. Denied. The allegations contained within Paragraph 23 of Defendant's New Matter contain legal conclusions to which no tespOlwive pleading is required. To the extent a response is deemed necessary. said allegations arc denied as Plaintiff acled diligently in procuring tenants for the Defendant and at all times material hereto. fully complied with and satisfied all duties and obligations required under the Agreement. 24. Denied, The allegations contained within Paragrnph 24 of Defendant's New Matter contain legal conclusions to which no responsive pleading is required, To the extent a response is deemed necessary, Plaintiff denies that it failed to fulfill Its obligations under the agreement and has therefore breached the same. To the contrary and by way of further answer, at all times material hereto, Plaintiff acted in good faith and in accordance with the duties and obligations as provided in the Agreement entered into between the parties. 25. Denied. Plaintiff specifically denies that it failed to fulfill Its contractual obligations to the Defendant. By way of further answer. Plaintiff is without knowledge or information sufficient to form a belief as to the truth of the remaining averments contained 2 ", '>- \t) c.; i'.r .,,-.(' .;:j l , I ,::~-.; (f,,; :"$ :$ , ) ( ""~~ :') ,c_", I u... ,,~ ( ~~ \":'. t'.,j ", I:'. ,.. ;y" liiJ "'... !!(~ " ", lor, ;-'} , , Ci', CJ ./. " ominercial Realty, Inc. 't.,.,"". . o'ld, :i'p ;(>17043 I W." , 1,"1' :;Thomas Posavec . -,~,:t, ~:" Joi~I' ('.i;i~'f.I};;':" ':DearTom:";' . r;" .' " ,;_~~~.~A\. ' _' - ') am iri'~Pt of your invoice #658 dated 10/31/98, for Kidspeace commission from 1111198- "'4/30/98 ; ."'. '\'. ,. . ....tJ,:(,' .. " . : ",t. Ji.::..~~~'" , "i' . . . I know we spoke briefly on the telephone regarding this transaction and our dissatisfaction for the manner in which this lease was handled. I have detailed the chronological order of events that have happened with Kidspeace, Larldmark, and myself. ',', . I. On or about the beginning of June 1998, Landmark showed suites 500 & 600 to Kidspeace/Cindy Knox, 2. June 4'h . received a fax from Tom PasaveclLandmark to discuss potential tenant for 1895 square feet. 3. June 16'h 1998, I called Tom PasaveclLandmlllk to see if Kidspeace still had an interest. At that time you told me their budget was $1750.00 per month. We were looking for $1825.00 per month. Tom Pasavec said he'd call to Kidspeace main office in Philadelphia and request additional money for lease, 4. Throughout the remainder of June, I made several phone calls to Tom Pasavec and Roy Brenner at Landmark regarding the status with Kidspeace lease, 5,.' During one of these conversations with Tom Pasavec, I was told sometimes these leads just don't materialize. At that time I asked Tom Pasavec ifhe had been in contact with Kidspeace lately and he said no. However, he might have some . engineers interested in the leaSe space, '. ' 6. Only July 15th, 1998, I received a fax from Roy Brenner asking me to prepare a lease for Kidspeace. I called Roy Brenner tofind out the specifics since no lease negotiations had been done by Kidspeace, Landmark, or myself, Roy said to send a general lease that we can use for them to review, 7, July 17'h . 1998, I faxed a lease to Dick Boyer at Kidspeace. ", ' 8, On August 20'h, I received a call from Tom Pasavec ILandmark asking if we were planning on renewing the listing agreement that expired July 31" , 1998. I told him at this time we listed the space with CIR America. Obviously, Landmark had lost touch with our listing and the dealings involved with the listing. Tom Pasavec said that he expects full commission from Kidspeace if the deal is completed and asked me what the status was, I told Tom Pasav,ec that I would be --- .-'-- -.--.--..-- 'I willing to pay a findcrs fcc bccause he was not acting on the best interest of leasing the spacc. 9, From July 17'h thru Septcmbcr 10'h, [ telephoncd Dick Boyer at least a dozen times to tlnd out ifhc received the lease [had faxed and ifhc had anlntcrcst in pursing the lease SpIlCC, On Septembcr 14'h. I received II call from Dick Boyer asking for some moditications to be mllde to the lease, Wc camc to agrecd upon tCI111S, 10. On September 22"". Cindy Knox from Kidspeace came into our officc asking about the space, She said she has not heard from Tom Pas avec or anyonc from Landmark, regarding the lease, We made an appointment to meet on 9/23/98. to go over lease transactions. II. On September 23'", Cindy met with Edsel and myself, She express,~d a need to get things expedited. We also worked on a build out drawing of the splice. She said Kidspeace sent a proposal to Landmark for our space. We never received any documentation of such, Hcr last conversation with Tom Pasavcc was in June when Tom Pasuvec told her $11.00 per square foot was enough to pay for our space, 12, September 25'h. Cindy from Kidspeace came into the office to discuss new drawings. 13. September 28'h, Cindy from Kidspeace requested additional space to accommodate their organization. Changes were made accordingly. 14, October I ", I sent the lease to Diek Boyer, priority mail. 15. October 13'11, Tom Pasavec called our office asking what's happening with Kidspeace. 16. October 14'h, Dick Boyer faxed signed lease, October 19'h. a hard copy of the lease was received, Lease to start December I II 1998 - based on build out being finished, I'm sure you will agree that yes you did bring Kidspeace to look at our lease space however, in no way have you been instrumental in completing this transaction. If! had not been persistent with Dick Boyer and Cindy Knox this lease contract would not have ever taken place. As you can see, a lot of time was ~pent on my behalf negotiating the terms and following up on open items. My husband and I will pay you, in good faith, a finder's fee in the amount 01'$778.86 for bringing Kidspeace to us, No other payments to Lundmark 01' Tom Pasavec will be made from us, due to the lack of service and the fact that the listing agreement expired on July 31 ", and no retainers were macle to reserve Kidspeace prior to the expiration of the contract. ~~reIY" I ..... ) "' J \~, . ,.-- I / -J ,'i _ ~ :-.-~- , ) \ I l. . lL ~~ tL/.,LL / l( l) (e' /7 - Suz ne Delerme ~- cc: Augusto N. Delemle. Esq. Sent certi fied return receipt .'fI COMMONWEALTH CORPORATION 764 Corporate Circle Limekiln Commerce Park New Cumberland, P A. 17070 ..FAX . folO .JCf I. 8UO To:Thck '730YL~ From: ~CLl"'U (J).f.JJtI/-C. Date: IO-N.qro Number of Pages: .:z Phone: 717-770-2000 Fax: 717-770-0605 Remarks: M- etTf1l{. ~ 1Ja~ 1J...h-~ ~c.I(f;Z .f1UltJuly. cUfOud q. LA. 'le.W/ I " . , , 3, TERM The primary tenn oftllis lease sh:lll be five (5) years to commence on December 1" , 1998 or completion date of build out (hereinafter the 'Commencement Date') and to end November 3D, 2003. The first month's lease charge will begin December I", 1998, or be prorated for the portion of November /December 1998 when available to the Tenant for occupancy. 4, RENTAL a) IN CONSIDERA nON of which, during the ba.qe tenn of the lease, Tenant agrees to pay to the landlord for the use of the space, the following payments: Rental payments of Forty-Four Thousand Five Hundred Six DoUars ($44,506.00) for the first two (2) years; said sum to be paid in monthly ulStaUments of $1854.42 due and payable by the first (l'~ day of each month beginning NovemberlPecember, or prorated for NovemberfDecember, as noted above. Years 3, 4, 5 shall be based on $1854.42 plus the Consumer Price lodex rates, Not to exceed 5% increase per year, b) Any rent not paid within the ten (10) days of its due date shall be subject to a five percent (5%) late charge. Payments, when received by the Landlord, shall be applied first to delinquent rents and late charges, if any. 5, SECURITY DEPOSIT JIoS"o,oo ~I( Tenant shall pay a security deposit in th0:rnount of Three Thousand S- Hundred f,r r ~ , Dollars 3.l11111ight"J F~1!j ,ants ($~ prior to obtaining possession oethe leased premised upon signing of lease, To be retained in an interest bearing account in~ir!lerest 'Z 'Yo RENEWAL This Agreement shall automatically renew for an additional two (2) years unless written notice of the Tenant's intention not to renew is given to the Landlord ninety (90) days prior to the expiration of the initial tenn or any renewal tenn. The rent for the first two (2) years will be fixed, For subsequent years the rent shall mcre:lSe in accordance with the current Consumer Price Index rates/not to exceed 5% increase per year. 7, LEASING CLAUSE Landlord is the owner of the building and has full right and authority to make this lease. Landlord hereby leases the premiser! to the Tenant in accordance with the provisions of this lease, Tenant hereby accepts this lease, -2. ;sO I"!>' ""t. 1."~ 'V"T_l "'..1 r:'Jno ,,\..,.., c\n '10\ QjQr) 0"1'/ " en ".... 0' "~~'5.",t, ~oe. f;;. ~<$' ~<}oe. &""-<:-0 -t-',o .~ e~ ~ ~ ~' >1<; ~, ",,'" ,,0' e'5. ."," ,"" ': .A- ",<.C; O~ ~ ,(,\> ;:s- ....."" ~ I- ~ ~~~ ~-.& ..0 ~~~~,~~~ ~~'" ~.t-~r.S><.,'" ~, ",'i 1'$-"" ~ ',<ce .....e ,0 j~O i:>v <<"'" ;., -0-"'" \\....: "ve\> . .,"'_ <,;-O~.. # ~' t,"" 0<':> ,~~ #., ;" ,& '"p ,,-. ,,,- ..' '" >> ,. ~'" ,>' ..,.. '" ..',po ~~# .~~, ~ ~. ''', ... '" ." '" " '> ... <i>'~' V ~ ~'.t · '" ,,' . · ,,,,' .. .'" ",' " "'~ ~.. ','" .,-' " (ji ..',1>' J' .." .Jf' J.o~ ,." J>' .. " ,'" ,.. .., ., <1-" ,.p ,'" ",' .# ,V-;" .# ":.<" ..' <if#,' .~ <; .., .# .~ ' .... ~ ."V #'" '" ..~ ,;> ..,' . ,. "~',~ ~ ~# ;,.... ".... ,~. ,,:." ", ;,' .... ,. .o/.v <<J' ",. #.,..~ "'" ,'" "" Ifr ~ ", ~'. '" ",,!' .,G ~ ~ ,,!' ,., .' . ~~ :. "": ..:.... ",. 6 '. ,<i .., -t' '*' ;; ;; '," !l? " ,<< ~, .. .,' " ,,~,. . f' / ,," ,.";, '" .....,... ~ .~ ';,.., ,# ~~;/' . ,*':.. :""./ ~... "J>.... j.'I1". ~ ~.,~ <S>:~ 'Q:~'" 0# .-."" .y< .#' c,' ":"... ".".;1' <<J' ';,.. ".._:.p' .' 4'.' ,,'^,j , .., ,. -. · '~'V.." ..s>' V ,,,",, . ~ .. .~ ~ ," .. .'" , ' "'",,"'# <J?' .,"., ..,. ,,"'.... .'" ,./'" ,.' #,,~ ,.\<< .,~", .,'".... 1'.,. ..1",:," .~' ~~ .0" #. ," 0" .~:. .~", -<,"",' ~$,." #'#. ." $>:'.< ~':.~' '" ...\,QT~~#"" ~. ,W ~ .v'iVif$,'~' ,"" ,.'V:".".......":"iP,,,'" <,,' <:!' '" - ~. .." " ,. , J> ,p ~ ~ ...., ,vc'i'.. ,"' .~ 0 ..... "'. .. .... ,'" ..s> ,,".< A' .-' .... ." ," V... .," ,.' ~ , ,w ." .~. "" , ,<, .<P ~. , '" ~ ,<\ ,.' '" ." ,. " ,," .," '" ",' ..." '" " '" ~ " " <Y"".~~, "" ," fj ,.' '''';, .i> ,'.l>- , ",. .;."._" (f' "'.. '., ~ ," ," '{ '''':11''' 6,0 ~J' .#:..~" <;".<< < ..v # -:../' ....,#' ,f~<., ... " '" ., .,. ." ~.v 5? .v .'.". '" ,< ,#.' " '" ,;; .' ,"" " <$'. ",' A'. .", " '" "'.' <t..;. · '*' ...< >?, '" ,..... ..... 1':;"<:." "", s"..' ,,' " '" , '" # ,/> f" .<..... w '" .." .. .' "'" <" "" , ,,0 · .. '" ",' ,<!' it' .~ ,.-''" ,. ,,~" ~") ~~S>~ ~ 0"" 0" ~v> A~<iI ~ . ~Cl~~~,\~~ ,u~ .~~?-.'. ~ 20. PARKING Landlord agrees that Tenant, its employees, agents, customers and visitors shaU have the right to use such parking spaces lIS may adjoin the building at IIl\Y time during the term of the leMe. . 21. SIGNS Tenlll\t shall not place any signs upon the exrcrior of the premises nor cause any leltCling of any Icing whatsoever to be placed upon the outside windows of the premises without the permission of the landlord, Tenant will be identified on any sign 01' directory to be placed outside or inside the building by Landlord for the purpose ofidentit'ying Tenants. The Tenunt will be charged a fee to have a plaque/sign made and installed on their mairl entrance. Tenant. wlll be notified o~ the price prior to ordering. 22, DEFAULT BY LANDLORD If the Landlord shall default in fulfillrncnt of any of the covenants 0.( provisions of this lease or attachments on its part to be perfonned and shall fail to remedy the default within thirty (3D) days or such time as is reasonably required to cure such default (eltcept that any default consisting of or amounting to dispossession of the TCllant shall be immediately actionable) after Tenant shall have given Landlord written notice of such default, then Tenant shall ha',e right, power or remedy permitted to it by law, and shall have, without limiting the generality of the foregoing the right to (a) remedy Landlord's default and charge Landlord for the cost of remedying the aefault by withholding rent or otherwise, or (b) allow the default to continue and reduce the payment of rent by reason of default. If Landlord docs not remedy such default within thirty (30) d.1YS or within such period as may be reasonably required to remedy the default if it cannot be done within thirty (30) days, the Tenant, while such default shall continue, shall have the further right to give Landlord written notice of its intention to terminate this lease on the date of such notice or on any later date and on the datc specified in this notice, Tenant's obligation to pay rent shall cease and this lease shalltenninate. 23, DEFAULT BY TENANT If Tenant shall default in fulfillment of any of the covenants or provisions of this lease on its patt to be perfonned and shall fail to remedy such default within thirty (30) days (Cltcept the Landlord may sue for any paY1l1ent of rent immediately after it becomes due) after Landlord shall have givell Tenant written notice of such defa~lt ifit cannot be done within thirty (30) days (except that Landlord may sue for llny payment or rent immediately after it becomes due) after Landlord shall have givcn Tenant written notice of such default or within such period as may reasonably be required to remedy the default if it cannot be done wiUlin thirty (30) days, then Landlord shall have the right to terminate this lease unless it has given Tenant prior written noticc of the dale of tennination. In the event of default by the Tenant, Tenant shall be re~;ponsible for payrnCllt of all rents still due and owing under the terms of this agreement; all continuing rent unless and WItH the premised arc re-rented or until the end of the initial lease -7- OCT-14-1998 14:25 6 to 391 8280 97~; P,08 term, which ever comes first; all costs incurred by the Landlord as a result of the default, including but not limited to, advertising costs, renovation and redecorating costs, fecs to rental agents, rent loss and/or rent differential, and reasonable attorneys' fees not to excced thcllmount of fifteen percent (15%) of 0.11 monies due and owing 10 Landlord, 24.. REQUIREMENTS BY LAW Landlord shall at its own expense promptly observc and comply with all prosent laws, ordinances, requirements, orders, directions, rules and regulations of tile federal, stahl, l10lU1ly and city government and of all governmental authorities having jurisrliction directly Or lndirC<1t1y over the premised, building or appurtenances of allY pall thereof, including but nOllimited to, such regulations or standards as are or may be promulgated under the Fedcral OCCUpilliollal Safety and Health Act of 1970, or similar federal, state or local requirements pertaining 10 the Tenant's use of the premises and the bllJlding. It is understood, however, that the Landlord is nol required to prOllllrc any pClll1lllt or licenses or certificate or other authorizations necessary for the Tenant to eonductlts business in the lease premises. Landlord, however. will provide the premises per codc so thaI an occupancy permit can be obtained. Tenant shall at its own expense, promptly observe and comply with all pnllent und fUtlllo laws, Qrdinances, requirements, orders, directions, rules and regula!ioll~ of the federal, 8tale, county and city governments and of all other govemmentaJ alllhorities having julisdktlon with respect to the operations of Tenant's business, 25. SUBORDINATES AND NON-DISTURBANCE Landlord is her~by vested with full power and authoril)' to subordinate T~l1al1t'y intarest hereunder to any montage or deed of trust which may now or hereafter be placed Oil the building or underlying leasehold estate and also to all renewals, modifications, consolidation Ilnd replacement of such montage or deed of trust. Landlord shall obtain from IIny present 01' flllure mortgagee, trustee, fee owner, prime lessor and any olhl'l' person having an interest In the premises superior to this lease a written non-disturbance agreementl1rovidlng that so long as Tenant perfonns all the terrrlS, covenants and condition.\ of this lease and agl'ecfi with an altorney to the mortgage, beneficiary of the deed oftruSl, purchaser at foreclosure sale, prime lessor or f(~e owner, Tenant's right to possession urlder this lease shall not be disturbc[1 and all of the rights of Tenant hereunder shall remain in full force and effoct for the full terlll of lhls Jel1-le and any renewal periods, and Tenant shall not be named or joined in any action ofprocce[lillg to foreclosure by the holder of any mortgage or deed of trust. 26, INDEMNITY Each party shall indemnify and hold harmless, the other 1\0111 allY liability for inJnry to or death of any person or damage to any property caused hy I1c~lil1ellrO or rn!1c,oflllllct of sllch party, its agents. employees or contractors, or hy such pany's (alllllo to perlllnn tbe covenants of the leuse. In case, either party shall, without fault 011 its p,lfl, b,~ I1Hlde il party to any Iltillalioll .H OCT-14-1998 14'27 Gl0 ~r_q li:.,'f1il i,"; r,09 LANDMARK COMMERCIAL REALTY, INC.. IN THE COURT OF COMMON ['LEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, {L~ <,.xl- ,/1" J'i 'j .b uJ-,,"\ 0 SUZANNE DELEf,RME, Defendant CIVIL ACTION - LAW No, qq. dll>5 NOTICE TO DEFEND 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 cla.ims set forth against you. You are warned that if you fail to do so the case may procced 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. LA WYER REFERRAL SERVICE DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17101 (717) 232-7536 4. Plaintiff believes and therefore avers that at 1111 times material hcreto, Defendant and her hushand, Augusto DelcI'IllC IIrc thc owncrs of relll pl'Opcl'ly ]o(:lIlcd at 764 Corporate Circle, Limekiln COlllmerce Park. New Cumherland, CUlllherlllud County, Pennsylvllnill. 5, On or ahout March 6, 1998 Defendanl emploYl'd Pllllutlff pursullnt to II written contract entitled "Exclusive Authorization to Lease" (hereafter "Agrecment") to procure a tenant for a rental portion of the premises located at 764 Corporate Circle, Limekiln Commerce Park, New Cumberland, Cumberland County, Pennsylvania. A true and correct copy of the Exclusive Authorization to Lease Agreement Is attached bereto and marked as Plaintiff's Exhibit "A", 6. Pursuant to the terms and conditions of the Agreement, the Agreement between the parties was to be effective upon cxecution of the same, and was to terminate on July 31, 1998, 7, The Agreement also contained a provision whereby Defendant agreed to pay Plaintiff as compensation for services rendered a commission of: 7 % of the first year rent; 5% for the secoud and third years; 4% for the fourth and fifth years; and, 3% for any and all subseqnent years, 8, Pursuant to the Agreement, all commission payments were due and payable in advance, semi-annually upon commencement of the lease. 9, In or about late March, or early April, 1998, Plaintiff contacted and introduced to Defendant a representative of KidsPeace National Center for Kids In Crisis, Inc. (hereafter "KidsPeace") as a potential tenant for the rental space locate at the address noted above. 10, Thereafter, up to and including October of 1998, Plaintiff expended its time and efforts to procure KidsPeace as a tenant for the Defendant, such efforts include but are not II."", " II" "".....,,, 'f , "" ,f "" ''''''''y, ,,,,.,,,~. 'f "'"""'" ""'" ".. '" /h, ""'" ."" """""", ""d "" '",.,,,,,,,'" ,,, "'''''m", d'".",,,,,, with 'h, ""f,"d.", alld POICII/illl ICI/alll 10 I/cgoli/Uc II leitole 01' lIit' Pl'Operly, , " ,,, A.,,,, " "", 'PI", h, ,.. ."', "'" h, ""f"""", II,,, "" ''"'"'''' h"" "". "..'" w'/h ""'/h" "', ''''', ''''.y, p,. ''''' II """dol "'",," "m"'m."" "/h, A,,,,,,,,,,, wh,,",y ""'''d.", "m"" Ii,,,, ,,, '" "" "'"_" ""y I"" "",oJ ,"', w'/h Kid,,,,,,,, """''''''' " 0" "..,"'"" " '" A ._",,,, A,,,, '" """" ","y ,'''" w""" "'.".... ,." '''''' ,,' A.."" 20, "" ,. '''''''''' h'm,,, ''''' "',',' " Plalllliff's Exhibll "B". Il, 0.", '"'' 0""", 13, '99', "",,"".., """" '''''' "" y", ,,,,, W',h K''''""" ,,,' /h, ."'" ''''''''' " 764 C""""." C'''''' I.....,,,. c_,,,, ""', Now """h"'""" "'mh"'.",, C""'y, "',,'" y' "",., A '''''' '''' '''''''' "'py 'f /h, I"" agrcemelll is al/llchcd hereto IInd marked 11.1 Plaintiff's Exhlbil "C". 13, 0.", ,"" N""",,,, " I 998 ""',"",,' ,ro""", d,,, "'" """',' '''''I wn"", "'''''' " PI""" ff " ", """,''',,,, """"'" of 'h, A,-,,,, Wh"", ." ,,""" ""011" '" ""h",,,,,.. ",""","J" ",ym,,,,.,, P''''''ff, A.. 000'",""" II.."" "",,,', '" '''''''''''' , """ "'..., "".hI, " PI".'ff', '" 'm,,,, " $778,,, " · '."" "'/h "oil,,, f,," " h, d"""" ,," "'" "'" "',""''', C'P'" 01 /h, N,,,,,,,, " 1998 J",,, ,"" 'h", 're """"" h""o "d "''''''' " P.'''Jrr, E.h/h', '0' 14, A, ," "m" m,,,,,., h,,,,,, PI. """ "'''' ,. ."" fol/h '011 ,. ","'d.", WI/h 'Ire '''''' '011 ""Ii""." " ,m 'Id", '. /h, A""m,. "",'" '''' "",w,,. /h, ""'.., ", By""", "f I., ""..., ,"" "P"".",,,,,", "",_. '" h."h'd lh, "'.'", 10m" ''''' ,,,"",",,, ,,' 1I" E",,,,,, A ,/hot""'" " "'" A ,re,,,,,,,,, Sxhlblt A ~H.d41IU\'l~( IIJllt\H'I!, llilllll l'l'liQ Ifill ~iiTc~ln (j) exhibit B Exhibit 0 A(\-'I~II.i.dAt iIoIJni I)'ji~ 1lI11 ~ICI~UI @ exhibit c 20. PARKING Landlord agrees that Tenant, its employees, agents, customers and vislton shall have the right to use such parking spaces as may adjoin the building at any time during the term of the lease. 21. SIGNS Tenant shall not place any signs up..,n the exterior of the premises nor cause any lettering of any king whatsoever to be placed upon the outside windows of the premises without the pennission of the landlord, Tenant will be identified on any sign or directory to be placed outside or imide the building by Landlord for the pwpose ofidentiJYjng Tenants. The Tenant will be charged a fee to have a plaqne/sign made and installed on their main entrance. Tenant will bc notified of the price prior to ordering, 22, DEFAULT BY LANDLORD If the Landlord shall default in fulfillment of any of the covenants or provisions of this lease or attachments on its part to be perfonned and shall fail to remedy the default within th.irty (30) days or such time as is reasonably required to cure such default (eKcept that ~ny default comisting of or amounting to dispossession of the Tenant shall be immediately actionable) after Tenant shall have given Landlord written notice of such default, then Tenant shall have right, power or remedy permitted to it by law, and shall have, without limiting tlle generality of the foregoing the right to (a) remedy Landlord's default and charge Landlord for the cost of remedying the default by withhOlding rent or otherwise, or (b) allow the default to continue and reduce the payment of rent by reason of default. If Landlord does lIot remedy such default within thirty (30) days or within such period as may be reasonably required to remedy the default if it cannot be done within thirty (30) days, the Tenant, while stlch default shall continue, shall have the further right to give Landlord written notice of its intention to terminate this lease on the date of such notice or on any later date and on the date specified in this notice, Tenant's obligation to pay rent shall cease and this lease shall tenninate, 23. DEFAULT BY TENANT If Tenant shall default in fulfillment of any of the covenants or provisiom oftbis lease on its part to be performed and shall fail to remedy such default within thirty (30) days (except the Landlord may sue for any payment of rent immediately after it becomes due) after Landlord shall have given Tenant written notice of such default if it cannot be done within thirty (30) days (except thatl.andlord may sue for any payment or rent immediately after it becomes due) 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 it r.annot be done wiUlin thirty (30) days, then Landlord shall have the right to tenninate this lease unless it has givcn Tenant prior written notice of the date of termination. In the event of default by the Tenant, Tenant shall be responsible for payment of all rents still due and owing undcr the tenns of this agreement; all eontinuing rent unless and until the premised are re-rented or until the end of the initial lease -7. OCT-14-1998 14'25 610 391 8280 97l; P.08 term, wWch ever cornel first; all costs Incurred by,he Landlord as a result of the default, . Including butllot limited to, advertising costs, renovation and redecorating oosta, fees 10 rental agents, rent loss andlor rent differential, and rellSonable attorneys' foes not to exceed the amoullt of fifteen percent (15%) of all monies due and owing to Landlord, 24. REQUIREMENTS BY LAW Landlord shall at its own expense promptly observe and comply witl1 all present laws, ordinances, requirements, orders, directions, rules and regulatioflS of the federal, state, oounty and city government and of all governmental authorities having jurisdiction directly or indirectly over the premised, building or appurtenances of any part thereof, including but not limited to, such regulations or stand'll'ds as are or may be promulgated undel' the Federal Occupational Safety and Health Act of 1970, or similar federal, state or locnl requirements pertaining 10 the Tenant's use of the premises and the building, It is understood, however, that the Landlord is not rcquired to procure any permits or liceflSes or certificate or other authorizations necessary for the Tenant to conduct its business in the lease premises. Landlord, however, will provide the premises per code so that an occupancy permit can be obtained. 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 operations of Ten ant's business, 25, SUBORDINATES AND NON-DISTURBANCE Landlord is hereby vested with full power and authority to subordinate Tenant's interest hereunder to any montage or deed of trust which may now or hereafter be placed on the building or underlying leasehold estate and also to all renewals, modifications, consolidation and replacement of such montage or deed of trust. Landlord shall obtain from any present or Mure mortgagee, trustee, fee owner, prime lessor and any other person having an interest in the premises superior to this lease a written non-disturbance agreement providing that so long as Tenant performs all the temlS, covenants and conditions of this lease and agrees with an attorney to the mortgage, beneficiary of the deed of trust, purchaser at foreclosure sale, prime lessor or fee owner, Tenant's right to possession under this l~ase shall not be disturbed and all of Ule rights of Tenant hereunder shall remain in full foIU and effect for the full term of this lease and any rencwal periods, and Tenant shall not be named or joined in any action ofpl'oceeding to foreclosure by the holder of any mortgage or deed of tnIst, 26, INDEMNITY Each party shall indemnify and hold harmless, the other from any liability for injury to or death of any person or damage to any property caused by negligence or misconduct of such party, its agents. employees or contractors, or by such pany', failure to perform the covenants of the lease. In case, either party shnll, without fault on its part, be made a pat1y to any litigation .8- OCT-14-'1'l'lB 14'27 6Hl 391 8280 971; P,e<J ~U-111~fl'((u~( IWlIl Uj.""U 11I11 ~~r.'LIUl @ Elchlblt 0 .: .. ',.;., " t.. ... :beai Tom:": . .....~.I.:\. . ~.' , i., '. '" 't'.' ... .. ,. . .,'; 1,"-" " '. 'I am In'i?9~jpf of you\" invoice #658 dated )0/31/98, for Kidspeace commission from 11/1/98- '" ...':4/30/98>"''''\" . ... ...~",:,~~:,;"."'( . , ' I know we spoke briefly on the telephone regarding this transaction and our dissatisfaction for the manner in which this lease was handled, I have detailed the chronological order of events that have happened with Kidspeace, Landmark, and myself, ~ I, I, On or about the begimling of June 1998, Landmark showed suites 500 & 600 to KidspeacelCindy Knox. 2. June 4'h , received a fax from Tom Pasavec/Landmark to discuss potential tenant for 1895 square feet. 3, June 16th 1998, I called T;Jm Pasavec/Landmark to see if Kidspeace still had an interest. At that time you told me their budget was $1750,00 per month, We were looking for $1825,00 per month, Tom Pasavec said he'd call to Kidspeace main office in Philadelphia and request additional money for lease, 4. Throughout the remainder of June, I made several phone calls to Tom Pasavec and Roy Brenner at Landmark regarding the status with Kidspea~e lease, 5..' During one of these conversations with Tom Pasavec, I was told sometimes these leads just don't materialize, At that time I asked Tom Pas avec ifhe had been in contact with Kidspeace lately and he said no, However, he might have some . engineers interested in the lease space. . 6, Only July 15th, 1998, I received a fax from Roy Brenner asking me to prepare a . lease for Kidspeace, I called Roy Brenner to find out the specifics since no lease negotiations had been done by Kidspeace. Landmark, or myself, Roy said to send a general lease that we can use for them to review, 7. July 17th, 1998, I faxed a lcase to Dick Boyer at Kidspeace. . . 8. On August 20'h, I received a call from Tom Pasavec /Landmark asking if we were planning on renewing the listing agreement that expircd July 31" , 1998, r told him at this time we listed the space with erR America. Obviously, Landmark had lost touch with our listing and the dealings involved with the listing. Torn Pas avec said that he expects full commission from Kidspeace if the deal is completed and asked me what the status was. r told Torn Pas avec that I would be - - --~ ------~- --- --- ---- ------ .- ,. .. ." , ... willing to pny a finders fee bccnuse he was not acting on the best interest of leasing the space, 9, From July 17'h thru Septcmhcl' 10'h, I telephoned Dick Boyer utleust a dozen times to find out ifhe received the lease I had faxed and ifhe had un interest in pursing the lease space, On September 14'h, I received a call from Dick Boyer asking for some modifications to bc made to the lease, We came to agrecd upon terms, 10, On Scptember 22"'1, Cindy Knox from Kidspeace came into our office asking about the space, She said she has not heard from Tom Pasavec 01' anyone Irom Landmark, regarding the lease, We made an appointment to meet on 9/23/98, to go over lease transactions. II. On September 23''', Cindy met with Edsel and myself. She expressed a need to get things expcdited, We also worked on a build out drawing oflhe space, Sbe said Kidspea~'e sent a proposal to Landmark for our space. We never received any documentation of such, Her last conversation with Tom Pasavec W(lS in June when Tom Pasavcc told her $11,00 per square foot was enough to pay for our space. 12, September 25'h, Cindy from Kidspeace came into the office to discuss new drawings, 13, September 28'h, Cindy from Kidspeace requested additional space to accommodate thcir organization, Changlls were made accordingly, 14. October I", I sent the lease to Dick Boyer, priority mail. 15, October l3'h, Tom Pasavec culled our office asking what's happening with Kidspeace, 16, October 14'h, Dick Boycr faxed signed lease, Octoher 19'" , a hard copy of the lease was received, Lease to start December I" 1998 - based on build out being finished, I'm sure you will agree that yes you did bring Kidspel\(~e to look at our leasc space however, in no way have you been instrumental in completing this transaction, If! had not been persistent with Dick Boyer and Cindy Knox this lease cuntract would not have ever taken place, As you can see, a lot of time was ,pent on my behalf negotiating the terms and following up on open items. My husband and I will pay you, in good faith, a linder's fee in the amount of$778,86 for bringing Kidspeace to us. No other payments to Landmark or Tom Pasavec will be made from us, due to the lack of service and the fact that the listing agreement expired on July 31 ", and no retainers were made to reserve Kidspeace prior to the expiration of the contract. ~jQereIYr' ~ q~ .) ;" ) .' _ cu- .' . \ . I. ' II C})LL /t.1u..I {. 1/7- suza~:t'Delenne ' cc: Augusto N, DelernlC, Esq, Sent certi ticd rcturn rcceipt ~ \:) Cl... &S 00 O' n, 1, l() " @ ., v: ..9 , , .. g t(l ., ~. ,-, If) r- ,.. ::t , :+t "'\1 , , I',., .,. (-, !,iI' ~ ~ ~ Ii' ;;' .' . d. ,. t',) ; l.' en (.) 6 "",."toI. . ,.. '" "" ",1",1 ~ , ~~~-- f {\lr\het \\l'Is\,/er. \\J ,. 1 ,.",,,toI. ., .., , ' '" ..... ... . & fu\\ \'lCt{ot~\\l'Iee 0 & 1""1'1 \>\\\II'I\I{\' s \'ltl,\lCt \\1'1 \,/0\1\& ol'l\~ \lI:eolllC \Ie I ,.- ..."..Ion" ",on" .'" '0 ,I< ",I",I~ { {ut\het \\l'Is\,/ct. \\1'1)' \'l\\)' ,. "",,,,,,. 'W .., " . p, .",.. ... d {u\\ \,cr\otl,,\\l'Ice 0 \ C &ue u\WI'I \>\\\11'1\\\1' s \'lto\'let \\1'1 \,/ou\& 01'1\)' beco~ \\\\i"e ofi,i&s\'e\\ce . . I~" \to&UCel\ \\ tQ\'ltesel'l . & . & \h\\\ \>\\\111\1" III Q. nellle&. \\ IS e,,\e \ ~ loAI\tC'" ot e\\t\)' < & \ il'l ot \\\>0\1\ \\ e . . CtislS. \IIC, \0 nc,e" \\11 . "..""", C.",. '0' ~ ," " . "~"",,,,,,, o( ~"."", o{ {11r\het a"s\'/et. \\ l' ",,\1:,,\1\\\ te"all\' B)' \,/\\)' I\.\'ltl\ \ I)QI.' as a ,._ S ,,\ '0)' \hc p\al,,\I\{, I" l\llle \l}l) . ." I"''''''''' " ,I< .0'''''' . . . ,I''''' ,I<' rI.I.,1 ~ on""'''' · . . ar\ a"l\ &el'lle& 11'1 \,ar\, \\ IS a 1\ \0, I\&I"I\\C& 11'1 \'l . \llllo \\ Is de"lc& \\11\\ p\a\I'I\I\{\,te\,ated . 'r\)' Il'IlU"c .,. D. "'" o( "" """"on' ,,,"I" . .. \'" ,'''' V\n\",I~ ....." .1 \hc ne{e"dal'l\' \\ IS 1''' , . '0< II< ...... """ ' ",,,,,,,,,,, ""'" , on. 11.1 ...., " ",.,.1'" · """ · , . \h \he ne{e"da"\ ""d "o\CI'I In ....00'" ""...,on' .' , I' , . ,I.no .'" o~"""""" ... . '1'Iled \ha\ \\\C P\al..\\i~ C1\\\CI'Il CI 1$ II< "".."". " " .,~"k . . · .~,'" ,,,"'.... " II< . { {a\\ a\\c\1,cd \I"w a" e , ().\ bet \ QI)S a"d s\tlc\ \'tOO 0 Inc\udl"\1, e 1\ P\a\n\l\{ Is &en\anded. ' .1 ,.\.t \ha\ \he \>\ain\i\{ sen\ .' \ \\ \$ all~h Cll , . \\nd dCII\I~d \11 ,,\\t' ' \ \ . ,,,,,,,,,'" .. "" . . "". I"":"" , 1.'\,\ "W' \1' \\\C ne\CIII\\\II\ \1'1 " d II' \>\\\il\\i\l' S \',1\"\ \ . _""..,......0<, . " ,\ ,1.1.,I(\"' C"""I.I., '" , .' . ,r\\\ III "at\\\1,ta\'\\ "U\"bct ' tC~\\llIi"\1, a"ct"'CI'I\' se\ II ' .1 '\' \\\1' C1\\l:I\\ \ha\ a te,,,,,,,,e \S , ,"U\tClI 0 \'i .\\ ,,0 tC'\'OI'l'C \S t"... . conc\U,IO'" o{ \a\'/ \I' \'/ \e ob\i\1,a\IOI'I" required. it is denied that Dr-fendant was liable or is liabl~' for any commission to the Plaintiff. By way of further response, I'luintltT did not fulfill its obligutions and duties . under the purties' Agreement as I'laintltT fuiled to act with diligence us required under the Agreement. 12. Denied as stated, It is denied thllt Defendant entered into a lease agreement with Kidsl'eaee, By way of further answer, the Defendant, Jointly with her husband, entered into a live (5) year leuse agreement with KidsPeaee for a portion of the space available to be rented, It is denied thut the location leased was in cumberlund County as the locution is actually in York County. 13. Admitted in purl and denied in purt, It is admitted that Defendant corresponded with the Plaintiff and lorwarded a check, in the amount of $778,86, in an attempt to resolve the parties' dispute, It is denied that Defendant repudiated or breached the parties' Agreement in any way. The remaining averments of paragraph thirteen (D) ofPlaintifl's Complaint arc denied. By way of further unswer, Plaintifffuiled to perform its obligations and duties under the parties' Agreement by failing to uet with diligence in procuring a tenant for the Defendant. 14, Denied, It is denied that I'laintift. acted in good fuith during the term of the parties' Agreement. It is denied that Pluintiffperfomled the duties und obligations providcd in the parties' Agreement. By wuy of further answer, l'luintifl's inuetivity, inattention and rel\tsal to provide the services required by the purties' Agreement resulted in Defendant being forced to perform those duties, AddltionuUy, without Defendant's efforts and perlbrmance ofthe dlltles which Plaintiff fulled to perform the lease agreement would not have heen consummutcd, 15, Denied. Paragraph fil\een (15) ofPlaintltl's Complaint consists of conclusions of law to which no response is necessary. To the extcntthat a response Is required, it is denied that the Defcndant breuehed the parties' Agreement. 16. Admitted in part and denied in part, It Is udrnltted that the only payment which Defendant hus remitted to the PlaintilTconsists ofa che()k in the amount of $778.86 and that Defendant has refused to muke any further payments, The remainder of Plaintiff's uverments in paragraph sixteen (16) of Plaintiffs Complaint are expressly denied as Defendant has not breached the parties' Agreement. It is further denied that any commission payments arc due by the Defendanlto the Pluintiff, 17, Denied. Paragraph seventeen (17) of Plaintifl's Complaint consists of conclusions of law to which no response is necessary, To the extent that a response is required, it is denied that the Defendant repudiated or breached the parties' Agreement. It is further denied thut any actions or representations by the Dd\mdant have resulted in any loss to the Pluintifi: WHEREFORE, Defendant respectfully requests this Honorable Court to enter judgment in Defendant's favor for the costs of suit and against Plaintiff. 21, Plflil/tif!' ' 2~ fiJllcd tell '7'hc 01/r,. to proc/Jrc llf/t(Sj for I lJ tCI/ICl/t r, fI tCl/lIl/t Ii 'hc DCIi c9Uircs I'L Or thc D ~ el/dll.. IIC P' . Cfel A <;.1, "t lY}d Ii 11I1/Jtif!' l'IlIl/t, Plflil/tlff . /Jllillil/g i to lICt wi 2". dId 1/ ts Ob" th d./J .., I Ot it Ill/Ill' C dil' th 'llIil/ . Ct dil' 10l/S Ilfcl/ ' crcforc tlf!' fiJ/~C IgCl/tly il/' Cc 11/ PrOc . brellCht..1 d to Iitllil . Proc/Jr' /Jrl/Jg 'I thc, III Its . I/Jlf tc 25, PlIttlt's, A Oblllllll' 1JlIl/t(Sj Ii 01 v '1gre , 10/JS U Or th rcq/Jircd I'll re.V/Jlt 01'1 c1J}Cl/t, 1Jdcr tht. 01 e !Jcfe/Jdll o cO/Jtl/Ct 'II/i/Jtilt' llrlJcl/Jc 1Jt, Pro.vPc ' s fttil/J 1Jt I//Jd h Ctl...c I tc to Ii lis le.vSCC /Jllil! ' s, I/cg. . It.V 0'111' Otlfltc ICll . Illl/tiol/,I' /J 'Ve lel'fJ c fe/Jd. Is. 1I1/d . lI/Jt w. 11/J1I!;. lI8 "-c ICIl ' ,Ic teJoo. IN, . Defe 7'he"...c ~ '/Jdll/Jt's 'I'11](J/]ts i " o1llsWcr /] Ptirll r. 19 llre i/]co 'II lIPhs o/] . 7; ffJof1l C OJ With !Jcli 'hc /)cfe/Jdll tCd herel/] , throUlll1 .VC~ Cl/dll/Jt'9 1Jt cO/Jtr. lI.v If fUll c/]tcc/] (J , rC/]tlll p ltCtcd 1Io/. ~ St/JtCd. Jj Of tOIICttlc' . th the p . . lIj lid S. l/]clu." 1/Jll/ti/J' "'Cttl . "'/]11 top sl/]ll /1 ... h/Jt crro1'l/] hj PrOIJ} , cli.'/Jdll/]t, /JOt lillJltcd Scrl'lctJ.f. Otl/]I/ th S P/~)Pcrt. to: . , IIs,vOclftt. Cj /)1 ' e ICftSIr, ~ lor!. Cd II,gC/]tly Igo/'thc c/J,I'C; dj IV. ProcUri ProPett ' CgOtiftll' /]g le,vsl'A Ics; /]g Ie -"'S; ej Pill . lIsc tCI>.. <l11~//] - "IS lY}d fo 'l! /JII detllllv /Jlfrccl/Jc/] 20 t DCfel/ ' rCI/Jtl/] ts; fllld . 1'llI . dlY}t:v rc 'l! to lI/]d Pllrtlcs' l/]tlf!'llt ~ '/Jt/ll sP/J . lIs,vOCiftl o111rec I Cd to tes. Cd IIolt'h h 'lJ}e/Jr F Pcrro ObI '/. erel/]) ,1I COpy 1'1/] the. , 1I1/1/]1l t. . ~~1. ~~f ~~ ,v lit 0 Se . tllchCdh 'lVICCV Cr, , req/J' Cto /J , Irccl s t;xhlb' /J/Jder t/I 'It {~" e Il/]d I.. ..CO% rllted ~i iN I' i I , I I .:J , I j,! i I tl l . ~ .o' J NO'I,!~~ it: " , ~.~~IQ I I ":!:l'llll I I !DOI .... I I '~I K)' ~~"H1 ~ ..., , ~ ~ f , .... ....~~~ :s:: . I ~ ""';~~ ~~Jil'" 0 . lII~t)(l ~ l , ~I ~I .;:Il!llll "" ~ ,.,~~~;;; I I I I NIn:Sj::JJjt ! I I ! I ., , I I I I I I I J ;,11 '" III ~I ~ ~ I ... I 0- I I -.j - t- Ot. ........ \.) ... DO \!l ~ l::J III c:::.. -.j 0 -- .... (!. :t: 0 0 Q ~I & ,I .... '" ~ "! . , ; I, "I':'.'. 0 I... ;!Ii.'./.: C4- '.:' ,(: ...; I r. ~ '" J :I CC i ""~J:lll '~"'\!l~1tl i ~ ' ""~~I(l I I ~:lPJ~ I "':'jl!l~ I .:1!\!Q . ' .,' ,.\~t:l~ Q., ~ ... 1; ~ I 'II <:J... J NOlI~'" ;1 ~"~;:j~ 94 "', ,..~~~ I i "t1Ii1~ I i I I ~ I I I I I I ~ , , I I I i l!l! CD, C Q till, ... CD .Q Ii CD .... Q. eX j F .lll ~ I I ] \1 .; i; LU :jr) ~ ~ \"~ ~ ii~ , 'I 'R1 I:!.:' ~! ,~1 ,,~ :'1,. ;;;1 (Ii '-'..--r j'l Iii "1 'i '1;,1 I I )~I II ~ tI1 \ i ~ ;'1 I l~1 ifii.}j ~ ... ...; I I .K ~"\QJ:j1Q ,..~~~ . ~:J1iI1:l ~ ~~l'llll I .::l1l1Q M2~1f~ NOIi!lJ:lll CD o o All .h"~. ~' :::I .., ., .<4 F III ~ ..; J I , , "'I I r:1r,1Q I u. "'~"IQ i It" NOl~~~ , J ~"fl~f1ill 1 I j ',~~~ I I ....1 1(01 .. ....' ..... '4l~lklf4 I r~f1ill I I I r..~F1~ , T::: l ~ .. "'~~l(J Q ,..,~t::;~~ I.... l,f 1"f00~fQ~ ! I N 0\ )!l I I I I i I I I I i ! .. i~ , I I I 0 0 CD ;...' ~ N , U :J 'en :I CC CIIMIU~R"ANIl ('(HiN'l'V,I'" IU!:COIUJI<:" (JIIllt;t:UN FicE SCHEDULE EFFECTIVE JANUARY 1,1000 DBBD 2~.~0 Rtal.tratlon for Camp lilli, Lomoyno & Now Cumborlll1d 1.00 Slatomont of Valuo 1.00 Act N319 Clean & Green 2~,SO MORTGAGE 25,50 MlSCBLLANEOUS INSTRI JMIlNTS AGRIlI!MllNT 14.00 ASSIGNMENT 14.00 CANCELLATION 14.00 CHARTER 14.00 CONDEMNATION 14.00 DECLARATION OF TA.l<ING 14.00 DECLARATION OF TRUST 14.00 EXTENSION OF EASBMENT 14,00 GAS & OIL LEASE 14.00 . . HIGHWAY MAP (I" page) 10.00 Addilional pago, each 3,00 Copy, por page 1.00 LEASE 14.00 MEMORANDUM/AGREEMENT 14.00 MEMORANDUMlLEASE 14.00 MERGER 14.00 MORTGAGE EXTENSION 14.00 NOTICE OF CONDEMN A TION 14.00 OPTION 14.00 . ORDINANCE 14.00 . PARTIAL RELEASE 14.00 PERMITS - Sowage & Water 1400 PLANS 18" x 24" maximum 10.00 Addillonal page, each 2.00 Copy, por page 1.00 POSTPONEMENT 14.00 POWER OF ATTORNEY 14.00 POWER OF ATTORNEY TO SATISFY 14.00 PROTECTIVE COVENANTS 14.00 RELEASE I too RELEASB OF MORl'OAGl! 14,00 Additional rol".e, eaoh 1,00 REVOKE POWER OF AlTORNEY 14.00 RlOHT OF WAY 14.00 SATISFACTION PlECE 14.00 UNDERGROUND RIW ACT N287 5.00 Copy 200 NOTARY PUBLIC Bond & Commission 29.50 FINANCING STATEMENTS 1 Sl debtor namo 59.50 Each additional debtor 57.50 Ancillary Iransaction 59.50 NonstandIVd fonns 13 3.50 Additional pagos. each 2.00 OTHER ITEMS Certification 1.50 Extra pages over 4 2.00 Exlra names over 4 .50 Coplos, por shoel .50 Change of name search 5.00 Marginal notation 2,00 Maps attachod Oversized. I" page 10,00 AddltloMI page 2.00 Above per Senale Bill No 125 I April 8, 1982. Effective dalo for recording purposes June I. 1982. (ACT 87) · As ameaded by Cumborland COUflly Board of Commissioners effective July I. 1996. (Ordinance 1996.1) "As further amended by HB196 (ACT 8,1998) d7/0&/1999 12:14 71 722185&& G.L. ROTHSClHL/), (SO PI\l1 01 "ril ~. ~l ~ ~ f. ," 1" . l I 1 . '. I' . >' \ ' .' ~ . I ~ " '. ," . 1 "" , . . . . . . . . . 3207 NOR11I FRONT S11UlIT HAIUU8BlmO,I'A ll1ll0 TllUl, (mUII-tlJO PAX (m):I2I..'" ~1k'ct1 eft-hr, tfSGl... F.: ,..., Olll'jl L. ROIlIJchlld, I!tqulnl DiIIIt: lie, L lit wMItIUt ", 1>ctftCrt c ......: ee, .!,In..f.Z.z1 ~h' z. · (InGIudInI COy,," Pllc) ~ ""'~ .,... c-..........L ,....... ...... ...... . . . . . . . -rt~1 ~ 'ItlII1NRlllMot.'IlON CXlN1'AlHID IN 'nil "M .. WII "GI. H'CNU.'IlQfl """'" ,Uio Jt( AI I~ f.a.llN1' Na:lIIlHI A.T'I'OI1NIVIWOAK I'AOllUCT P'II\'UGI! rr .INrUIlIDCHL Y IQI 'IMI &-. OF TN! INIJIIIIIll.W. HAlle AIICMI *' THI! l'llMl.I!IllII AIW NlJT WAI\IIO Wi wmJIOfI'1'MI "'WIG _1IlIiNf.,.,...' II 111 II!. II' TIll '"- AC'I\W.Lll'._A.lNG TMI r'"'17 - · OIl Nf1 one IlIADI!R OF nE FN: I ml.!. NOT 1llI1WIlID. _IT Oft THe IIIII'lDYB 0IIM8IT 1lIIPOl1I..#.TOIII!lNIR "TOM rw.D~,NlY_ . I UWiTlCll, ~ OIl COfI'nNO Of' TIll C~17T\lN1C:AllOH .ITIICTLY lWliI_.au,.YOU HAl/! ~ 'MI C~1fT INICATlON IN IiMOR, PlEAII! FT'Rr\;1ILY CONrN..'neraIlAT (T17) Dt.alOOII "Ale AT (717) an.... ltWI( YOU, 'f'.._1II " '. !.' . . . . . . . , . . . . . . . , . ,. . . . .. . . COUNTY OF YOFlK ,.-"",.. OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MAI1KET ST., YOI1K, PA 17401 '~r---~---- INSTRUCTIONS I PLEASE TYPE ONLY LINES 1 TO. 12 DO NOT DETACH ANY COPI!:S. 2. COURT NUM8ER ----L.i.Uldrn<.l.l:k.C_vrnmQI"<.: till R~ELL~y.. I II" , 99 - 2 65 Civ il 3.0EFENOANT/SI . ..--.-....----- -''-TYPE OF WRiroR COMPLAINT se:~I~, ~ldi\'6-F.m~Vi51J.iJ.-.' COMf;ANY.: COfiPO, fiAtj(jN~-E.-TC. .T6"SEAVEOR'.OESCiiiPfION OF PR~~~~~~~ 8EaL~~EOCAO,TT~~~;:' ~~ S~LO-- . Suzanne Deloenno . .. -----6:AllooESSlSTREET'oliAI'DWfTRilbx :>iUiJotA.-APT No;-eii'fiioRO: Tw"f["STATE ANO ZIP CODE---' ~-- cL<L_!~QI!lITlQ.!}_I.'Lfl..a1.!.!.1.__C.~_LJ_6_q CorE. Ci,cle, Limekiln Comm~5k'p~e.., C\lrpbe 7.INDtCATf IERVleE: IJ PERSONAL IJ PERION IN CHAROE XI DEPUTIZE Cum* I.lAUld IJ 1ST CLASS MAIL IJ PDITEO C1J,i\~7 0 NOW.. 1 Uc~[9-~:'~--:'::,,--==- -=:-==-19'=':__,. S~iERIFF OF-~UNTY, p~ ~bY,dftpUtlze rIN of ~~<~~ d.piii.T~n 118ln~-mld..i-'hjlr'-q~8.i-~nd r~~~~~.U~~;:~~~~~U~~~ t ~ ,~;Ing 8. IPECIALINSTRucnDNS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITINO SERVICE: Cumberland SHERIFF SERVICE FoROCIESS RECEIPT, and AFFIDAVIT OF RETURN tfi[AiiiTiFFllir-----.,... ,-~--_. ' Serve at. c/o Commonwealth Corporation 764 Corporate Circle, Limekiln Commerce Park Now Cumberland, P^ 17070 ." ADVAOCE FEE PAID BY ClJMBERLl\ND COUNTY SHERIFF NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN. AnV deputy sheriff IO'v)/lng upon or attaching any property under within writ may leave 8iIme without 8 walchman, In cuSIOdy ot whomevor Is found In pcss6sslon, altor noUfying purson 01 levy or allachmenl, wllhoulliabilily on the pan or such deputy or the sherIff I~.ny phllnlitr herein for any loss, deslrlJCllon, or rflmoval of Rny property belote sheriff's sale lhereor. 9.TYiiENAME AND ADDRESS 01 iTfOANEV/ORlOINATOR and'SIO'NATURE ~o. TELEPHONE NUMBER 11.0ATE Thomas L, Isenb9rg, Jr, Esg, 213 Market Street, Harrisburg, PA 17108 717-237-6000 1/14/S9 12. lEND NOTICE OF 81!RVICE COPY-TO NAME AND ADDRESS BELOW: (Thll .re. mU'1 be completed If notlc&""lato be milled). Cumberland County Sheriff, 1 Courthouse &luare, Carlisle, PA 17013 SPACE BELOW FOR USE OF THE SHERIFF ONLY. DO NOT WRITE BELOW THIS LINE 13.I.cknowledge receipt 01 the will SIGNATURE OF AUTHORIZED CLERK "J 14. Dale Received 15. ExpiratiOn/HearIng Date o,compl.lnl..lndlCaled.bove. 8, Feeser . 1/27/99 2/13/99 ._--~-----~._-~---_. 16.1 hereby CERTIFY and RETURN that I U have personally sorved, U havo posted property, U have legal ovidence 01 servIce as shown In "Remarks., U hftl/o executed a9 in "Aemtrks', Ihe wrll 01 complaint descrlbecl on Iho individual, company, cor. poratlon, 91C, allhO address In.'ertod bolow by handing II TRUE and ATTESTED COPY Ihoreol. ~-----------. "'-. 17 U I horeby corufy and relurn II NOT POUND bocause I am unoblo to locale the mdlvldual, company. corporation ole, named abovo (See remarks below) 18 NAME AND TtTL EhOF INDIVloUAiSERVEp I L1ST-~ORE99 HE~ IF 'Nor SHOWN AB'!VE (R.lallan.hlp -IOD.f.nd.nll-~te of ServIce 20 TIme 01 Sorvlc. -'" Z ,(... ,<~t" ~~;;: ,..' / ~ ~>(;- ,~.': " &T~ L_J...L::.2</ 'i'; , ..- po " m'~ - '~....'(.r;r..[~ U~MII'.I :1'" Tlm'MII'. nl. 0,1. Tim. Mil.. Inl. D.,. TIm. Mil.. Inl. ~ 22 Advance Costs 2~ Service (':081!! 24 NOI Found -is -MII'oage 26 Poslagn 27Pounda00T26 -Notary Fee 29 Surcha/ge 30 Total Cost 31 Cost DUG or efund c-"'> $100: 00 _J f, CQ._ __.__~ L, 5 _____c !,d.2~L ,..{, CO 6- I,. 32 REMARKS CI{if /3IST/ ------------,--.---..-.-..-.-----..-. ...----- -_._.....--_...--.~-.SD ANSWEit"-. 2nd 34. day 01 _..___ 35. MCi.QQMM!SSION EXPiRES _. _ 'Q~.=__"::-___ 42.1 ACKNOWLEDGE RECEIPT 0 THE SHERIFF'8 RETURN SIONATURE OF AUTHORIZED ISSUING AUTHORITV AND TITLE ~ WHlii-~;ulng A~h~;jIY"'2~PlN~4:11~';;;-(;~; i-EANA'A~htl(itr; Ofllc~'" 4.-a'L'ur: :S.t;~~;--O-f!;~-(l ." ---[:':i'oale Recfllved ------ .-. ...--.... .....-..._..._._-~_._-~---- , , '~ CUUNTY DF YORK "DFFICEo.(i~E .SJ:lEI3JEE'M.;..~;~~~~t.'i~~.~~,~, ;,!>; ,~,' -'~\h;~;". 'I.e',;:' -, ~8 (lAST MAAKET Sr., YOflK, PA 17401 ~ ''! '''< If'" ;,>! .. . ",,,,.--,,,..,,,,,,~. I ,II H Iq!;; I l- :rbilfllNoAlitilll '-!l'l' j" ' ,,11 ! I '-~'-------iNSTRUCTlON8. . . PLEASE TYPE ONLVLINE$j T812 DO NOT DETACH ANY OOPIES. 2 COUflT NUMBER Ill) ) I, t', ,.- I ) SHERIFF SERVICE PROCESS RECEIPT, end AFFIDAVIT OF RETURN niAiNlifititiii '.:i.. ~E.."'Y '{II' ~ n 'Allrttll'fll\ (lImEn C>nfll'll Wf'ffTfibxNuMliliFi:APfNb-,'ciTY:'\lOOo;t'iiF':s'fA'ftA/mZiji'e.ODE---'---,- ~;::r~ I'~~~)'~ "U Pr."~~~AI: ,. "~'P~#O~I~~~~e_ ~~ii~~~f~;R~~~~~~;;9d;~~~:~-~~~~:l~ ~:~:~:~I~I~~ ~jJ~1 :.:'" ,-, i .. ., ....._..._,_ COUNTY to exeoute thla Wrlland make return lhereof aooordlng ~_~~~~,_"_T_~I~__~~_ut~_Uunb._I~~ _~_~~~;~t th~.q~.._~~~~~~_~.!.~~.~.~alnU~. --"-;'._".'-~.':-----illrn[LCg.t~:~J:lliitfIT:-. . _._._____~_~_.__ 8 IP'OIAI.INMTAUOTlON8 on OTH8R INfORMATION THAT WILL ASSIS,. IN EXPEOITlNO SEfIVIOE: '. I iqd ' i I .----.-.--,--- "..-TYiiE'O.F WRIT OR COMPLAINT 1."_:)-"1_11'_ "'> _,__ _" " _, _ ',__ i\!"i '(' lilil (' dl1p liLIl\ -~ --NAMII '(W INtlIVIlIli^t', CO.,fPANY. 6bnf-it)fiAfltfN,~li>ib SE.AV(Clfi-o'E$OAlfITlON Or"fi'FfOPEATY TO BE lEVIED, ATIACHEO-:-ciR SOtD, !" I 'ill' '1'1' V, i I i ~) 1 I!" ')1' il I lill f 1':1 ""II,!II;_' Ir j, :'I,i ',11"1. I' '~-, ! 'I. I'i\:i ',',,' ". ;ii:H';(:iil J\ ,ii' i.n") -;ilj.:i:I!':.' r'-. HOll ONLV A....UOA.Ul ON~W.A1T-op-execuTloN: N,B. WAIVER OP WATCHMAN. Any dopt~y sheriff lovylng upon or a"achlng any property ~Inder within Wfil may leave - ...m. wilholll ,. WAIL'fml4lll, HlqlJllod~ of whomever Is found in possession, aflflr notifying parson ollovy or altactmlenl, wllhcutllabllily onlhe part of such de. or Ihe lhert" to any {Mlnli" 11I1I'in 1m IIlV loll, tMlIlrUCl!on, or romoval of any properly before sholiff's sale lhereot. nV~,~~~~-AiI~~ADDiI~~}:'A~~~N~;IO~IOII~~~~.R and SIONATUHE . ~o. TELEPHONE NUMBER fl. OATE . ,'11 (-LitH 'I. "t!,~'Li itllf_;;;(l\l:'_JI }\f\ i/i(l( /1/<-)'.IJ.ilUl;U 'l/l.L/t,l;,! ""'--,---"--,~._.~._'.",' ,~-,,~.~',--"--,",,', -',"-,---_& . . . .----.:... . It, ..HO NOTlOI or ..RVIOI COPY TO NAMe ANO ADDRESS BELOW: (Thla araa muat be completed II nollea 10 to be m.llad), ('ll;l~/\f 1.\111 C"il'ld,i ~.h-':!. itr, I t\A!rUI:il!:::'c' ;',};l'Il,H i-')1'1i'l, 1\\ I'IU: ~ " ==:"77:"iT7"~_LOWfQA UBI! OP THEIHE8IfJl.oNI.Y. QQJ!OT WR E BEL W'THIS LINE 'W~H~ j t31.,*~f6il"I/>I.flhowrFI' _ATllIIljjj:~.. 1~ ~It,~ ',' T~:el\fOlI.tlilll'--'-~ '1 OfOOfllp'alflIIU,lndlCl\!odahovu 'I r I I; :1/ I I [}Ij \ ~ - - . .. - ~ tn_l h.,Ohy CftATl'Y itlld RetURN null' U hiNt porsonally sorved, U ha....e pOSlod properly, U have legal ovidonce of sorvlce as shown In 'nflllll,k,", U h....... DJ(;;r.ulctd nu In 'nonl/ukll', tho wrll or complaint deSCflbed on tho Individual, company, cor. f'OIalkm, Itlfl, nlltlo addlflll" IfllfH1ed tmlow hy handing fl TRUE! and ATTESTED COP'Y Ihereol. ",~.--".~--, "---,'-~-..-----~'.." ---..------..-----.--..-.---------.-- 11_ W_l hltldhy t:IHUly And "IurrI_ft_ HOTrC?~_NOboClHISI) 'I flfT1Unablo to loclteltla Indivldll1ll, col'npany. oorporalton, ole, named above. (See remalks below.) tt' HAioifANII TilL! O'-INOIVIDlfAl tir.~vIiDTI.IST ADO~E8S HERE '" NOT SHOWN ABOVE (Rotello.'hip to Deland,nl) 19.0... 01 S.rv.... 20. Tlma olServ\ca 1 . '''''-'' '~"'''''''~, t.,-_~ I~'''''''F",...,~,J .........;.",1",.;"'-_ ~'Jh ')"1 36. Signalure of Dep. Shflriff ~i7:Slgnalui~lol.yoik.- uu_.9otJ/1~t_~~~~~ .m_. 38 SlgnnlufO of Forolgn ~?(!~!Y.,~~?~~t_,._ .', , ., --:" /-!~'{I,-. '\" ' "'-~~-\__foAHl' ~,l J ' ._~ '\f ,','-~"'. -.-.,--.-,-~~---'----.-- '--~_. :t:t AfilIlHMi!() IlId .utllir,rlb,ild 10 bfdoro mo this t "'!l if'; l-I ~t", Il<<i~ III 19 .. __ >-')\."jt'~_/ .,_ ,- /' ,r. _,'. .A',. ,t. ~_~_J.:__L~_!:.~.-~~;~~:~~::: 'e ;," "1 39, Dale ~'i..// 40.0alo' <",;I; ''''"'7 - .' 41-:-0ate _.__.._.......,~-'_._-------._--~ -..,~.- i,,' I! -' :.' '1\\/ 1/ ;,\ I J-;- '-;',. //; " .. ____.....__~J....i.:~.-___:_.-.---~.-.-.J-!...-.,_ , / f\'l:lt~1)'I.N()t,1IYf'~1.>1I~ _,' ~,ylti;!:~m~~~8~~'1t~rTBtiHE SitER~Ff'~ REtuRN-sloNATuiiE' (I! AIITlIOIIIZEn ISSUINOAUTHORITY AND TITLE -- - ..~..__._-,---_._-"_...'- ._-----~--- WHIff 1~l411lno A.llltl0rilV 2_ PINK Allollloy 3 CANARY. ._.__n--~'[-43. DalO Received -..---'.'-.-_.._,.....'. -'.,....'.-..-- Shorill'l\ Olhco "lIl.ur < StlOrilfs allieo ~ (.u- ~v ~ ~:~~ I(~'v~ ~~'\ ~ (.-.J~~o:,~'v ~~~ "b~ ~.. " ~O. '. " " ,~'v ~~G ,..O~~ It-'"' ~~~ ,~C. '~~, .... " " ~1..1.. ~,~~ '. " . ~\.f,~' "o:,'1>~" ~~~\ ~ ~~~ i..\.<:J ,,'1><:1 ~. ~'. ::<F'" ~~~ ~~'li -,-0 10.\~ ~~O'" #'~ (j ~ \~~~ ~~~ ~f, ~~ ~'1>~ ~O ~"\ ~\.~ ~~ "'. ~'v~~ '\1 ~~~ o:,-.J1.>~ ~'1>~ s..f,~ '\1f, "c ~:V o ~'v\) ~~ ~~ (.~~ ~~~o:, S~~ 1\- 'i-~~ ~G .~ ~"/'i ~:~ 0/ ~,,~ b'\.' ~'If'\~' ~'1b\<:J<:J\ '''~~ ,'Y' ~ "i "V' ~\\. f,\.' ,\:\' <:J<$>'li ~ (P o:,\.~~ ,'I ' ~~~ ;:..~\. ~~ o:,~~ ~'I! ~\~' '\.,,,, \~ ~'1>\\ '\.~ ~'\.' ~ ,,~~ ~<:J 1o.f," '\1'1! .-. , '7:." \:;0" <,,>~ ",." \')>;?. ';8 \,:.tD '-'Y{~ \\\(0 'i~.~}..o .~\ o -.' 'r(~ ~.^: ,. \1\ ': ,. \:~ \,l. ;.h ~.. ",.:1. ,. ~;..~ ~--'J ';:_'J . , ))"'-I'd~<t, k~f;r"" ; ,JL,I1""'>- JJ i,l /3, /..A>" ,Vl(.Y"- . ~(Jdwll ,{}r{.(/:r ..- 7~lt;;"" '~~. ( I' A.u C. ~1W:t,~, ~. \ U ",. 'II.. ~O.).I . 'I IjdL~ ~, l.i.t. /W '1,,,' (JOY H. RROOkS 00 (lOW..RO, KATZMAN 60 SUI!'MAN, P.O, ,1.:rl,\LHllO:'1 SlUH:T . S"It^\\'IIEkItY SUI'^Il~: p,o, Bux I~Mi t1.\ilJOSIlI'IW, /'ENN\;YI,\'.vn^ 17JOR.I;;f.!l 717,:\.1.41(,1 I 717.?.I4.liHI(lIF,IXl ~:hh~Kks'''w'<-'l/m fE'MAIL) ~ fg C:'I n C:~ ") C. ~f_T! "" ::t;- c::: 00 ~n rn I'r', ~ 2'c" I 't'..' . ",'fTI ~ (j!.~~ .r;'. 'il ('~_, ;:SC, H(~ . "';:, ~" " ?:n 'r"',', ~ ~~.. IL:i~r~ ....., :Jl;O .... Cl ~ C: Cot) ~ .. "I r:- ). ....1 ~q "'" 6" J\