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Home My WebLink About99-07347I BROWN & CONNERY, LLP Steplianic E. Nolan, Esquire Attorney ID # 80770 1500 Market Street 12" Floor, East Tower Centre Square Philadelphia, PA 19102 TELERENT LEASING CORPORATION Plaintiff, vs. COAST TO COAST MOTEL, INC. T/A/ TRAVELODGE, WILLIAM F. PRICE, III, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA PRICE, AND JANE LUNSFORD, 11"Orneps for Plaintiff, Telerent Leasing Corp. COURT OF COMMON PLEAS CUMBERLAND COUNTY December Term 1999 No. 99_7347 Civil Action ORDER OF THE COURT AND NOW, this ? Oday of ?.f"?? 2000, IT IS ORDERED h BROWN S CO9NF.RY, t at the previous Order of the Court in this matter entered on June 20, 2000, it hereby VACATED, and IT IS FURTHER ORDERED that this matter will be continued generally and can be placed on the calendar again at the request of any party. itephanie E. Nolan, Esquire 'or Plaintiff )avid A. Baric, Esquire 'or* Defendants 15;:::.... ?a =`f )4i. ,,_ ,.,.. ?, ?• l; .:.j ;.:u;?11 CUB.^c??'•`?'? y? ?iA PcN???YL . •' Court of Common Pleas of Cumberland County For Prothonotary EUseOnly (Docket Number) Trial Division CIVIL COVER SHEET 4 PLAINTIFF'S NAME TELERENT LEASING CORPORATION ENDANTS' NAME AST TO COAST MOTEL, INC., T/A TRAVELODGE; 2?, LLIAM F . PRICE, III; 'WILLIAM PRICE, JR.; MARGARET PRICE; 'PATRICIA PRICE; AND 'JANE LUNSFORD PLAINTIFF'S ADDRESS 4191 FAYETTE ROAD RALEIGH NC 27611 DEFENDANTS' ADDRESS 1 , , 1252 HARRISBURG PK., CARLISLE,, PA; 1310 HICKORY RD., CARLISLE, PA; 11252 HARRISBURG PK., CARLISLE, PA; 11252 HARRISBURG PK., CARLISLE, PA; 5310 HICKORY RD., CARLISLE, PA; AND 5910 Mt. Pleasant Rd., Woodbine, NJ 08270 TOTAL NO. OF TOTAL NO. OF COMMENCEMENT OF OTHER PLAINTIFFS (70) DEFENDANTS (71) ACTION 1 91. Complaint 02 W i f C15. Arbitration 010. In Forma Pauperis 6 . r t o Summons C6. Jury 011. Transfer from Other AMOUNT IN CONTROVERSY 030. 550,000 or less 03. Notice of Appeal C4. Petition Action Jurisdiction )(7. Non-Jury 8 Equity 012. Minors/Incompetent 2131. More than 350,000.00 032. A.1.11m.nt.r d.m.5., h..M,, 1Nm.d Compromise 08. Class Action 013. Survival Action 09 033. A...I...t W E.m.q., hti p rot required . Savings Actions 014. Wrongful Death Action (Inv. minors) ACCRUAL OF CAUSE OF ACTION X40. Action arose in Cumberland County DEFENDANT INFORMATION 0 50 All 041, Action did not arise In Cumberland County . defendants are residents of (or have offices in) Cumberland County (,bt,, no,on for".C ,n ea., cwnt, Ni. in.ae) 042. Transaction or occurrence giving rise to action x51. Main defendant is a resident of (or has offices in) Cumberland County arose in Cumberland County 643. Transaction or occurrence giving rise to action did [152. All defendants regularly conduct business in Cumberland Count y (see instruction F) not arise in Cumberland County (dmmh...n,., o w.camenu W...90) 0 53. Main defendant regularly conducts business in Cumberland Count y (see instruction q 1154. Defendants are not residents of (and do not have offices in) Cumberland County (state below in 460",- on /orfiling action in Cumberland County) 1360. CODE NUMBER AND TYPE OF ACTION (See Instruction G) STATUTORY BASIS FOR CAUSE OF ACTION (See Instruction H) RELATED PENDING CASES (List by Docket Number- Indicate Whether the Related Cases Have Been Consolidated) None NAME OF PLAINTIFF'SIAPPELLANTS ATTORNEY ADDRESS (See Instruction J) Stephanie E. Nolan, Esquire PHONE NUMBER SUPREME COURT 1500 Market Street, 12'h Floor, East Tower, Centre Square (215) 592.4352 IDENTIFICATION 080770 Philadelphia, PA 19102 SIGNATURE DATE DECEMBER3, 1999 For official use only STATUS ? 1001 Deferred TRIAL LIST 0 1010 Arbitration NEXT COURT ACTION 0 1101 Arbitration Hearin ? 1102 Settlement Conference ? 1103 El 1011 Jury g Hearing/Trial 01012 Non-Jury Date:_ ? 1104 Status Conference ? 1105 Other G 1013 Agency/Tax Time: Date: Filing Fee Appeals Time: 0 1014 Mass Tort Place: ? 1015 Other Y BROWN & CONNERY, LLP By: Stephanie E. Nolan, Esquire Ally. I.D. #80770 1500 Market Street 12i6 Floor, East Tower Centre Square Philadelphia, PA 19102 (215)592.4352 TELERENT LEASING CORPORATION, Plaintiff, vs. COAST TO COAST MOTEL, INC. t/a TRAVELODGE, WILLIAM F. PRICE, III, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA PRICE, AND JANE LUNSFORD, Defendants. Attorneys JorPlainitff relerent Leasing Corporation COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL DIVISION DECEMBER TERM, 1999 N0. (??- -134/ 7 6f/"'r NOTICE TO DEFEND --M NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must lake action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and riling 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 SEr FORTH BELOW TO FIND OUT WHERE YOU CAN GLT LEGAL HELP. BAR ASSOCIATION LAWYER REFERRAL S INFORMATION SERVICE 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AVISO Le han demandado a usted en In core. Si usted quiere defenderse de eslas demandas expuestas en las paginas sigulenles, usled liene veinle (20) dins de plaza al partir de lafechadelademandaylanotificacion. Hacefallaasenlar una comparencia escrita o en persona o con un abogado y entregar a la core en forma escrita sus defenses o sus objeciones a las demandas on contra de su persona. Sea avisado que si usted no se deftende, la cane lomara medidas y puede conlinuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usled cumpla con todas [as provisiones de esla demanda. Usted puede Perrier dincro o sus propiedades u otros derechos importantes pars usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SINOTIENEABOGADOOSINOTIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA CSCRITA ABAJO PARA AVERIGUAR CONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. ASOCIACION DE LICENDIADOS SERVICIO DE REFERENCIA E INFORMACION LEGAL 2 LiberlyAvenue Carlisle PA 17013 (717) 2,19-3100 L ti 1 BROWN & CONNERY, LLP Stephanie E. Nolan Attorney I.D. N 80770 1500 Market Street 12°i Floor, East Tower Centre Square Philadelphia, PA 19102 TELERENT LEASING CORPORATION Plaintiff, VS. Attorneys for Plaintiff, Telerent Leasing Corporation COURT OF COMMON PLEAS CUMBERLAND COUNTY DecemberTerm, 1999 No. 79.73q;?a,--I COAST TO COAST MOTEL, INC. T/A TRAVELODGE, WILLIAM F. PRICE, III, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA PRICE, and JANE LUNSFORD, Civil Action COMPLAINT Plaintiff, Telerent Leasing Corporation (hereinafter "Telerent"), a Delaware corporation, way of complaint against die defendants, Coast to Coast Motel, Inc., t/a Travelodge, William III, William Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford (the ") says: VENUE 1. Telerent is a corporation incorporated under die laws of Delaware and doing business the State of Pennsylvania. 2. Defendant, Coast to Coast Motel, Inc. t/a Travelodge, ("Coast to Coast") is a corporation doing business at 1252 Harrisburg Pike, Carlisle, PA 17013. 3. Defendant, William Price III, is an individual residing at 310 Hickory Road, Carlisle, 17013. 4. Defendant, William Price, Jr., is an individual residing at 1252 Harrisburg Pike, PA 17013. I1ROWN & CoNNt:RV, 1V"tm""p N.1118108 5. Defendant, Margaret Price, is an individual residing at 1252 Harrisburg Pike, Carlisle, A 17013. 6. Defendant, Patricia Price, is an individual residing at 310 Hickory Road, Carlisle, PA 17013. 7. Defendant, Jane Lunsford, is an individual residing at 971 Mt. Pleasant Road, New Jersey, 08270. GENERAL ALLEGATIONS 8. Telerent hereby repeats and incorporates die allegations of the preceding paragraphs this Complaint as if set forth at length herein. 9. On or about June 10, 1998, Telerent and Coast to Coast executed lease agreement no. 7-000 (the "Master Lease") whereby Telerent leased certain personal property to Coast to Coast gibed in the schedules to the Master Lease and made a part thereof. A true and correct copy of Master Lease and addenda thereto are attached as Exhibit A. 10. On or about June 10, 1998, defendants William Price Jr., and Margaret Price, executed Master Lease, which was approved by Telerent. See Exhibit A. 11. Pursuant to the terns of the Master Lease, defendants William Price Jr. and Margaret ;e agreed to be bound as co-lessees to all terms of the Master Lease. See Exhibit A. 12. On or about June 10, 1998, defendant William Price, III, executed an agreement known Lease Addendum I to the Master Lease, which was accepted and approved by Telerent on June 7, 1998 ("Master Lease Addendum V). See Exhibit A. 13. Pursuant to the terms of Master Lease Addendum I, defendant William Price, III, agreed be bound as a co-lessee to all terms of the Master Lease. See Exhibit A. 14. On or about July 2, 1998, defendants, Jane Lunsford and Patricia Price, executed an known as Lease Addendum II to the Master Lease, which was accepted and approved by on July 9, 1998 ("Master Lease Addendum II"). See Exhibit A. BROWN & CONNERY, LIRII 2 W mtmunt, NJ ONION .M 15. Pursuant to the terms of Master Lease Addendum 11, defendants, Jane Lunsford and Patricia Price, agreed to be bound as co-lessees to all terms of the Master Lease. See Exhibit A. 16. On or about August 31, 1998, defendants, William Price, Jr., William Price, III, ricia Price, Margaret Price and Jane Lunsford, executed an agreement known as Lease Addendum to the Master Lease, which was accepted and approved by Telerent on September 7, 1998 r Lease Addendum III"). See Exhibit A. 17. Pursuant to the terms of Master Lease Addendum III, defendants, William Price, III, Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford, agreed to be bound as co- to all terms of Lease Schedule 1, identified by Telerent as Lease No. 9907-001; Lease chedule 11, identified by Telerent as Lease No. 9907-002; Lease Schedule III, identified by Telerent s Lease No. 9907-003; Lease Schedule IV, identified by Telerent as Lease No. 9907-004; Lease chedule V, identified by Telerent as Lease No. 9907-005; Lease Schedule VI, identified by Telerent s Lease No. 9907-006; and Lease Schedule 9907-008, identified by Telerent as Lease No. 9907-008. See Exhibit A. COUNT ONE-BREACH OF CONTRACT (Lease No. 9907-001) 18. Telerent hereby repeats and incorporates the allegations of the preceding paragraphs of this Complaint as if set forth at length herein. 19. On or about June 10, 1998, Telerent and Coast to Coast executed Lease Schedule I the Master Lease which was identified by Telerent as lease agreement no. 9907-001 ("Lease ). 9907-001 ") whereby Telerent leased certain personal property to Coast to Coast (the "9907- 1 Equipment"), described in Exhibit A to Lease No. 9907-001 and made a part thereof. A true d correct copy of Lease No. 9907-001 with exhibits is attached as Exhibit B. 20. On or about June 10, 1998, defendants William Price Jr. and Margaret Price d Lease No. 9907-001, which was approved by Telerent. See Exhibit B. BROWN S CONNERY, UPII Wn1m..[,NJ 08108 21. Pursuant to the terms of the Lease No. 9907-001, defendants William Price Jr. nd Margaret Price agreed to be bound as co-lessees to all terms of Lease No. 9907-001. See xhibit B. 22. Pursuant to the terms of Lease No. 9907-001, the defendants agreed to pity t a monthly lease payment of $4,173.00 for sixty (60) months for the lease of the 9907- 1 Equipment. See Exhibit B. 23. On or about July 23, 1998, defendant Coast to Coast executed an agreement n as Lease Addendum I to Lease No. 9907-001, which was accepted and approved by Mt on July 23, 1998("Lease No. 9907-001 Addendum I"). See Exhibit B. 24. On or about August 18, 1998, defendant Coast to Coast executed an agreement t as Lease Addendum II to Lease No. 9907-001, which was accepted and approved by !nt on August 18, 1998("Lease No. 9907-001 Addendum 11"), See Exhibit B. 25. On or about November 5, 1998, defendants Coast to Coast, William Price Jr., and ret Price executed an agreement known as Lease Addendum III to Lease No. 9907-001, was accepted and approved by Telerent. ("Lease No. 9907-001 Addendum III"). See t B. 26. On or about August 20, 1998, defendant Coast to Coast executed an agreement i as Lease Addendum IV to Lease No. 9907-001, which was accepted and approved by at on August 27, 1998 ("Lease No. 9907-001 Addendum IV"). See Exhibit B. 27. On or about December 16, 1998, defendant Coast to Coast executed an agreement as Lease Addendum V to Lease No. 9907-001, which was accepted and approved by it on December 22, 1998 ("Lease No. 9907-001 Addendum V"). See Exhibit B. 28. On or about November 23, 1998, defendants, Coast to Coast, William Price III, a Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford, executed an agreement as Lease Addendum VI to Lease No. 9907-001, which was accepted and approved by t on November 23, 1998 ("Lease No. 9907-001 Addendum VV). See Exhibit B. BROWN & CONNERV, LLP W"tm"nt. NJ ORIIIR II 4 go29. On or about September 23, 1998, defendants Coast to Coast and William Price d an agreement known as Lease Addendum VII to Lease No. 9907-001, which was and approved by Telerent on October 1, 1998 ("Lease No. 9907-001 Addendum VII"). Exhibit B. 30. In March 1999, defendants, Coast to Coast, William Price III, William Price, Jr., et Price, Patricia Price and Jane Lunsford, defaulted under the terms of Lease No. 9907- 1, as amended and the Master Lease, by failing to make certain monthly payments when due. 31. As of November 15, 1999, the Defendants were in arrears in the amount of ,181.34 under the terms of the 9907-001 Lease, as amended, and the Master Lease. 32. The Defendants' default terminated any and all of rights of the Defendants under terms of the 9907-00ILease, as amended, and the Master Lease, including the right to use and sess the 9907-001 Equipment. 33. Pursuant to the terms of the 9907-00ILease, as amended, and the Master Lease, has elected that all amounts due or to become due under the terms of Lease No. 9907- , as amended, be and are immediately due and payable. 34. As of November 15, 1999, the balance due under Lease No. 9907-001, as I?mended, was $260,553.00. I 35. Telerent has demanded payment from the Defendants but no payment has been See Exhibit I. 36. Telerent is entitled to recover attorneys' fees and costs from the Defendants under terms of the 9907-001 Lease, as amended, and the Master Lease. WHEREFORE, Telerent Leasing Corporation demands judgment against defendants to Coast, William Price Ili, William Price, Jr., Margaret Price, Patricia Price and Jane jointly and severally, for money damages in the amount of $260,553.00, together with charges, pre judgment interest, costs of suit, attorneys' fees, and such other relief as the may deem just. BROWN & CONNENY, LLP \Ynlmnn1. NJ tltl 11tl II 5 L.4YY` ? ' ? ' _ Jwr A• COUNT II - BREACH OF CONTRACT (Lease No. 9907-002) 37. Telerent hereby repeats and incorporates the allegations of the preceding paragraphs f this Complaint as if set forth at length herein. 38. On or about June 10, 1998, Telerent and Coast to Coast executed Lease Schedule II the Master Lease which was identified by Telerent as lease agreement no. 9907-002 ("Lease No. whereby Telerent leased certain personal property to Coast to Coast (the "9907-002 i, described in Lease No. 9907-002 and made a part thereof. A true and correct copy Lease No. 9907-002 is attached as Exhibit C. 39. On or about June 10, 1998, defendants William Price Jr. and Margaret Price d Lease No. 9907-002, which was approved by Telerent. See Exhibit C. 40. Pursuant to the terns of the Lease No. 9907-002, defendants William Price Jr. and Price agreed to be bound as co-lessees to all terms of Lease No. 9907-002. See Exhibit 41. Pursuant to the terms of Lease No. 9907-002, the defendants agreed to pay Telerent monthly lease payment of $1,028.00 for sixty (60) months for the lease of the 9907-002 Equipment. Exhibit C. 42. On or about August 31, 1998, defendants Coast to Coast, William Price, III, William ce, Jr., Margaret Price, Patricia Price, and Jane Lunsford, executed an agreement known as Lease dendum I to Lease No. 9907-002, which was accepted and approved by Telerent on September 1998 ("Lease No. 9907-002 Addendum I"). See Exhibit C. 43. Pursuant to the terms of Lease No. 9907-002 Addendum I, defendants William Price, William Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford agreed to be bound as co- sees to all terms of Lease Schedule 1, identified by Telerent as Lease No. 9907-001; Lease iedule 11, identified by Telerent as Lease No. 9907-002; Lease Schedule III, identified by Telerent Lease No. 9907-003; Lease Schedule IV, identified by Telerent as Lease No. 9907-004; Lease 4 IIAOWN & CONNr.RY, LLP II 6 Walmanl, NJ NNIIN hedule V, identified by Telerent as Lease No. 9907-005; Lease Schedule VI, identified by Telerent Lease No. 9907-006; and Lease Schedule 9907-008, identified by Telerent as Lease No. 9907-008. Exhibit C. 44. In March 1999, defendants, Coast to Coast, William Price III, William Price, Jr., argaret Price, Patricia Price and Jane Lunsford, defaulted under the terms of Lease No. 9907-002, amended, and the Master Lease, by failing to make certain monthly payments when due. 45. As of November 15, 1999, the Defendants were in arrears in the amount of 1,387.12 under the terms of the 9907-002 Lease, as amended, and the Master Lease. 46. The Defendants' default terminated any and all of rights of the Defendants under the of the 9907-002 Lease, as amended, and the Master Lease, including the right to use and s the 9907-002 Equipment. 47. Pursuant to the terms of the 9907-002 Lease, as amended, and the Master Lease, lerent has elected that all amounts due or to become due under the terms of Lease No. 9907-002, amended, be and are immediately due and payable. 48. As of November 15, 1999, the balance due under Lease No. 9907-002, as amended, s $51,400.00. 49. Telerent has demanded payment frotn the Defendants but no payment has been made. Exhibit I. 50. Telerent is entitled to recover attorneys' fees and costs from the Defendants under the erms of the Master Lease. WHEREFORE, Telerent Leasing Corporation demands judgment against defendants Coast o Coast, William Price III, William Price, Jr., Margaret Price, Patricia Price and Jane Lunsford, ointly and severally, for money damages in the amount of $51,400.00, together with late charges, re judgment interest, costs of suit, attorneys' fees, and such other relief as the Court may deem just. nROWN S CONNr.R1', W"tMen I, NJ 118108 7 J11 COUNT THREE-BREACH OF CONTRACT (Lease No. 9907-003) 51. Telerent hereby repeats and incorporates the allegations of the preceding aragraphs of this Complaint as if set forth at length herein. 52. On or about June 10, 1998, Telerent and Coast to Coast executed Lease Schedule to the Master Lease which was identified by Telerent as lease agreement no. 9907-003 ("Lease 9907-003") whereby Telerent leased certain personal property to Coast to Coast (the "9907- Equipment"), described in Lease No. 9907-003 and made a part thereof. A true and correct y of Lease No. 9907-003 is attached as Exhibit D. 53. On or about June 10, 1998, defendants William Price Jr., and Margaret Price, d Lease No. 9907-003, which was approved by Telerent. See Exhibit D. 54. Pursuant to the terms of the Lease No. 9907-003, defendants William Price Jr. Margaret Price agreed to be bound as co-lessees to all terms of Lease No. 9907-003. See [bit D. 55. Pursuant to the terms of Lease No. 9907-003, the defendants agreed to pay a monthly lease payment of $1,156.00 for sixty (60) months for the lease of the 9907- I Equipment. See Exhibit D. 56. On or about August 31, 1998, defendants Coast to Coast, William Price, III, liam Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford, executed an agreement wn as Lease Addendum III to Lease No. 9907-003, which was accepted and approved by :rent on September 7, 1998 ("Lease No. 9907-003 Addendum 111"). See Exhibit D. 57. Pursuant to the terms of Lease No. 9907-003 Addendum 111, defendants William :e, III, William Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford agreed to be nd as co-lessees to all terms of Lease Schedule I, identified by Telerent as Lease No. 9907- ; Lease Schedule II, identified by Telerent as Lease No. 9907-002; Lease Schedule III, Itified by Telerent as Lease No. 9907-003; Lease Schedule IV, identified by Telerent as Lease 9907-004; Lease Schedule V, identified by Telerent as Lease No. 9907-005; Lease Schedule BROWN & CONNERY, LLPII 8 W.1mont,NJ OAIOB Prl"TP9 .Is identified by Telerent as Lease No. 9907-006; and Lease Schedule 9907-008, identified by as Lease No. 9907-008. See Exhibit D. 58. In December 1998, defendants, Coast to Coast, William Price 111, William Price, , Margaret Price, Patricia Price and Jane Lunsford, defaulted under the terms of Lease No. , as amended, and the Master Lease, by failing to make certain monthly payments when 59. As of November 15, 1999, the Defendants were in arrears in the amount of under the terms of the 9907-003 Lease, as amended, and the Master Lease. 60. The Defendants' default terminated any and all of rights of the Defendants under terms of the 9907-003 Lease, as amended, and the Master Lease, including the right to use possess the 9907-003 Equipment. 61. Pursuant to the terms of the 9907-003 Lease, as amended, and the Master Lease, t has elected that all amounts due or to become due under the terms of Lease No. 9907- as amended, be and are immediately due and payable. 62. As of November 15, 1999, the balance due under Lease No. 9907-003, as d, was $54,332.00. 63. Telerent has demanded payment from the Defendants but no payment has been lee- Exhibit I. 64. Telerent is entitled to recover attorneys' fees and costs from the Defendants under terms of the Master Lease. WHEREFORE, Telerent Leasing Corporation demands judgment against defendants st to Coast, William Price III, William Price, Jr., Margaret Price, Patricia Price and Jane sford, jointly and severally, for [Honey damages in the amount of $54,332.00, together with charges, pre judgment interest, costs of suit, attorneys' fees, and such other relief as the rt may deem just. BROWN & CONNERY, LLP II 9 Wnlmanl, NJ 08108 COUNT FOUR-BREACH OF CONTRACT (Lease No. 9907-004) 65. Telerent hereby repeats and incorporates the allegations of the preceding of this Complaint as if set forth at length herein. 66. On or about June 10, 1998, Telerent and Coast to Coast executed Lease Schedule to the Master Lease which was identified by Telerent as lease agreement no. 9907-004 ("Lease 9907-004") whereby Telerent leased certain personal property to Coast to Coast (the "9907- Equipment"), described in Lease No. 9907-004 and made a part thereof. A true and correct of Lease No. 9907-004 is attached as Exhibit E. 67. On or about June 10, 1998, defendants William Price Jr. and Margaret Price Lease No. 9907-004, which was approved by Telerent. See Exhibit E. 68. Pursuant to the terms of the Lease No. 9907-004, defendants William Price Jr. Margaret Price agreed to be bound as co-lessees to all terms of Lease No. 9907-004. See ibit E. 69. Pursuant to the terms of Lease No. 9907-004, the defendants agreed to pay t a monthly lease payment of $942.00 for sixty (60) months for the lease of the 9907-004 See Exhibit E. BROWN & CONNERY, W.M.M. M 08108 70. On or about August 20, 1998, defendant Coast to Coast executed an agreement as Lease Addendum I to Lease No. 9907-004, which was accepted and approved by nt on August 27, 1998 ("Lease No. 9907-004 Addendum V). See Exhibit E. 71. On or about September 9, 1998, defendant Coast to Coast executed an agreement as Lease Addendum 11 to Lease No. 9907-004, which was accepted and approved by it on September 9, 1998 ("Lease No. 9907-004 Addendum II"). See Exhibit E. 72. On or about August 31, 1998, defendants Coast to Coast, William Price, III, i Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford, executed an agreement as Lease Addendum III to Lease No. 9907-004, which was accepted and approved by t on September 7, 1998 ("Lease No. 9907-004 Addendum 111"). See Exhibit E. 10 A. 73. Pursuant to the terms of Lease No. 9907-004 Addendum 111, defendants William 'rice, 111, William Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford agreed to be ound as co-lessees to all terms of Lease Schedule I, identified by Telerent as Lease No. 9907- )l; Lease Schedule II, identified by Telerent as Lease No. 9907-002; Lease Schedule 111, entified by Telerent as Lease No. 9907-003; Lease Schedule IV, identified by Telerent as Lease o. 9907-004; Lease Schedule V, identified by Telerent as Lease No. 9907-005; Lease Schedule 1, identified by Telerent as Lease No. 9907-006; and Lease Schedule 9907-008, identified by :lerent as Lease No. 9907-008. See Exhibit E. 74. On or about June 17, 1998, defendant Coast to Coast executed an agreement own as Lease Addendum IV to Lease No. 9907-004, which was accepted and approved by lerent on June 17, 1998 ("Lease No. 9907-004 Addendum IV"). See Exhibit E. 75. On or about September 25, 1998, defendant Coast to Coast executed an agreement )wn as Lease Addendum V to Lease No. 9907-004, which was accepted and approved by erent on September 25, 1998 ("Lease No. 9907-004 Addendum V"). See Exhibit E. 76. In March 1999, defendants, Coast to Coast, William Price III, William Price, Jr., rgaret Price, Patricia Price and Jane Lunsford, defaulted under the terms of Lease No. 9907- as amended, and the Master Lease, by failing to make certain monthly payments when due. 77. As of November 15, 1999, the Defendants were in arrears in the amount of ,051.74 under the terms of the 9907-004 Lease, as amended, and the Master Lease. The mdants' default terminated any and all of rights of the Defendants under the terms of the 7-004 Lease, as amended, and the Master Lease, including the right to use and possess the 7-004 Equipment. 78. Pursuant to the terms of the 9907-004 Lease, as amended, and the Master Lease, rent has elected that all amounts due or to become due under the terms of Lease No. 9907- as amended, be and are immediately due and payable. 79. As of November 15, 1999, the balance due under Lease No. 9907-004, as was $54,400.00. BRowN& Cormay, wnimnne, NJ UBaUB I;?MI 80. Telerent has demanded payment from the Defendants but no payment has been ade. See Exhibit 1. 81. Telerent is entitled to recover attorneys' fees and costs from the Defendants under terms of the Master Lease. WHEREFORE, Telerent Leasing Corporation demands judgment against defendants to Coast, William Price 111, William Price, Jr., Margaret Price, Patricia Price and Jane sford, jointly and severally, for money damages in the amount of $54,400.00, together with charges, pre judgment interest, costs of suit, attorneys' fees, and such other relief as the ourt may deem just. COUNT FIVE-BREACH OF CONTRACT (Lease No. 9907-005) 82. Telerent hereby repeats and incorporates the allegations of the preceding aragraphs of this Complaint as if set forth at length herein. 83. On or about June 10, 1998, Telerent and Coast to Coast executed Lease Schedule to the Master Lease which was identified by Telerent as lease agreement no. 9907-005 ("Lease 1. 9907-005") whereby Telerent leased certain personal property to Coast to Coast (the "9907- 5 Equipment"), described in Lease No. 9907-005 and made a part thereof. A true and correct of Lease No. 9907-004 is attached as Exhibit F. 84. On or about June 10, 1998, defendants William Price Jr. and Margaret Price d Lease No. 9907-005, which was approved by Telerent. See Exhibit F. 85. Pursuant to die terms of the Lease No. 9907-005, defendants William Price Jr. Margaret Price agreed to be bound as co-lessees to all terms of Lease No. 9907-005. See ibit F. 86. Pursuant to die terms of Lease No. 9907-005, the defendants agreed to pay a monthly lease payment of $300.00 for sixty (60) months for the lease of the 9907-005 (Equipment. See Exhibit F. BROWN & CONNERY, I Walman4 NJ 08111X 12 87. On or about August 31, 1998, defendants Coast to Coast, William Price, 111, illiam Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford, executed an agreement sown as Lease Addendum III to Lease No. 9907-005, which was accepted and approved by elerent on September 7, 1998 ("Lease No. 9907-005 Addendum 1II"). See Exhibit F. 88. Pursuant to the terms of Lease No. 9907-005 Addendum III, defendants William ice, 111, William Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford agreed to be and as co-lessees to all terms of Lease Schedule I, identified by Telerent as Lease No. 9907- 1; Lease Schedule II, identified by Telerent as Lease No. 9907-002; Lease Schedule III, ntified by Telerent as Lease No. 9907-003; Lease Schedule IV, identified by Telerent as Lease 9907-004; Lease Schedule V, identified by Telerent as Lease No. 9907-005; Lease Schedule identified by Telerent as Lease No. 9907-006; and Lease Schedule 9907-008, identified by as Lease No. 9907-008. See Exhibit F. 89. In March 1999, defendants, Coast to Coast, William Price III, William Price, Jr., argaret Price, Patricia Price and Jane Lunsford, defaulted under the terms of Lease No. 9907- 5, as amended and the Master Lease, by failing to make certain monthly payments when due. 90. As of November 15, 1999, the Defendants were in arrears in the amount of ,323.10 under the terms of the 9907-005 Lease, as amended, and the Master Lease. 91. The Defendants' default terminated any and all of rights of the Defendants under terms of the 9907-005 Lease, as amended, and the Master Lease, including the right to use possess the 9907-005 Equipment. 92. Pursuant to the terms of the Master Lease, Telerent has elected that all amounts or to become due under the terms of Lease No. 9907-005, as amended, be and are due and payable. 93. As of November 15, 1999, die balance due under Lease No. 9907-005, as d, was $15,000.00. 94. Telerent has demanded payment from the Defendants but no payment has been See Exhibit I. BROWN & CO.NNr..R1', I.1J. \Yntmont. NJ 08108 1 3 95. Telerent is entitled to recover attorneys' fees and costs from die Defendants under lie terms of the Master Lease. WHEREFORE, Telerent Leasing Corporation demands judgment against defendants to Coast, William Price 111, William Price, Jr., Margaret Price, Patricia Price and Jane , jointly and severally, for money damages in the amount of $15,000.00, together with charges, pre judgment interest, costs of suit, attorneys' fees, and such other relief as the ourt may deem just. COUNT SIX-BREACH OF CONTRACT (Lease No. 9907-006) 96. Telerent hereby repeats and incorporates the allegations of the preceding aragraphs of this Complaint as if set forth at length herein. 97. On or about June 10, 1998, Telerent and Coast to Coast executed Lease Schedule to the Master Lease which was identified by Telerent as lease agreement no. 9907-006 ("Lease . 9907-006") whereby Telerent leased certain personal property to Coast to Coast (the "9907- . Equipment"), described in Lease No. 9907-006 and made a part thereof. A true and correct iv of Lease No. 9907-006 is attached as Exhibit G. 98. On or about June 10, 1998, defendants William Price Jr. and Margaret Price J Lease No. 9907-006, which was approved by Telerent. See Exhibit G. 99. Pursuant to the terms of the Lease No. 9907-006, defendants William Price Jr. Margaret Price agreed to be bound as co-lessees to all terms of Lease No. 9907-006. See G. 100. Pursuant to die terms of Lease No. 9907-006, the defendants agreed to pay a monthly lease payment of $1,020.00 for sixty (60) months for the lease of the 9907- Equipment. See Exhibit G. BROWN & CONNERY, I.LPII Wblmum, NJ 08108 14 6?SLtcmo=SMCt.v+w.?rs?s???pgG J .'{ i, v A. BROWN& CONNERV, Wnlmon4 NJ ostos ., Margaret Price, Patricia Price and Jane Lunsford, defaulted under the terms of Lease No. 107-006, as amended and the Master Lease, by failing to make certain monthly payments when 101. On or about July 2, 1998, defendant Coast to Coast executed an agreement known Lease Addendum Ito Lease No. 9907-006, which was accepted and approved by Telerent on ly 9, 1998. ("Lease No. 9907-006 Addendum 111). See Exhibit G. 102. On or about August 31, 1998, defendants Coast to Coast, William Price, III, illiam Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford, executed an agreement own as Lease Addendum 11 to Lease No. 9907-006, which was accepted and approved by lerent on September 7, 1998 ("Lease No. 9907-006 Addendum 11"). See Exhibit G. 103. Pursuant to the terms of Lease No. 9907-006 Addendum 11, defendants William ce, III, William Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford agreed to be nd as co-lessees to all terms of Lease Schedule I, identified by Telerent as Lease No. 9907- ; Lease Schedule II, identified by Telerent as Lease No. 9907-002; Lease Schedule III, ttified by Telerent as Lease No. 9907-003; Lease Schedule IV, identified by Telerent as Lease 9907-004; Lease Schedule V, identified by Telerent as Lease No. 9907-005; Lease Schedule identified by Telerent as Lease No. 9907-006; and Lease Schedule 9907-008, identified by rent as Lease No. 9907-008. See Exhibit G. 104. On or about November 23, 1998, defendants Coast to Coast, William Price III, am Price, Jr., Margaret Price, and Jane Lunsford, executed an agreement known as :ndum III to Lease No. 9907-006, which was accepted and approved by Telerent on mber 23, 1998 ("Lease No. 9907-006 Addendum III"). See Exhibit G. 105. In December 1998, defendants, Coast to Coast, William Price III, William Price 106. As of November 15, 1999, rite Defendants were in arrears in the amount of ,843.75, under the terms of the 9907-006 Lease, as amended, and the Master Lease. 15 107. The Defendants' default terminated any and all of rights of the Defendants under terns of the 9907-006 Lease, as amended, and the Master Lease, including the right to use possess the 9907-006 Equipment. 108. Pursuant to the terms of the 9907-006 Lease, as amended, and the Master Lease, rent has elected that all amounts due or to become due under the terms of Lease No. 9907- as amended, be and are immediately due and payable. 109. As of November 15, 1999, die balance due under Lease No. 9907-006, as :d, was $88,083.24. 110. Telerent has demanded payment from the Defendants but no payment has been lee Exhibit 1. III terms of the Master Lease. WHEREFORE, Telerent Leasing Corporation demands judgment against defendants st to Coast, William Price III, William Price, Jr., Margaret Price, Patricia Price and Jane sford, jointly and severally, for money damages in die amount of $88,083.24, together with charges, pre judgment interest, costs of suit, attorneys' fees, and such other relief as the rt may deem just. COUNT SEVEN-BREACH OF CONTRACT (Lease No. 9907-008) 112. Telerent hereby repeats and incorporates the allegations of the preceding aragraphs of this Complaint as if set forth at length herein. 113. On or about June 10, 1998, Telerent and Coast to Coast executed Lease Schedule III to the Master Lease which was identified by Telerent as lease agreement no. 9907-008 Lease No. 9907-008") whereby Telerent leased certain personal property to Coast to Coast (the Equipment"), described in Lease No. copy of Lease No. 9907-008 is attached as Exhibit H. Telerent is entitled to recover attorneys' fees and costs from die Defendants under 9907-008 and made a part thereof. A true and BROWN & CONNERY, I.I.PII W"Im"N,NJ08108 16 j 114. On or about June 10, 1998, defendants William Price Jr., and Margaret Price, Lease No. 9907-008, which was approved by Telerent. See Exhibit H. 115. Pursuant to the terms of the Lease No. 9907-008, defendants William Price Jr. Margaret Price agreed to be bound as co-lessees to all terms of Lease No. 9907-008. See bit H. 116. Pursuant to the terms of Lease No. 9907-008, die defendants agreed to pay a monthly lease payment of $50.00 for sixty (60) months for the lease of the 9907-008 nt. See Exhibit H. 117. On or about August 31, 1998, defendants Coast to Coast, William Price, III, i Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford, executed an agreement as Lease Addendum III to Lease No. 9907-008, which was accepted and approved by t on September 7, 1998 ("Lease No. 9907-008 Addendum See Exhibit H. 118. Pursuant to the terms of Lease No. 9907-008 Addendum III, defendants William ce, III, William Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford agreed to be nd as co-lessees to all terms of Lease Schedule I, identified by Telerent as Lease No. 9907- Lease Schedule II, identified by Telerent as Lease No. 9907-002; Lease Schedule III, ttified by Telerent as Lease No. 9907-003; Lease Schedule IV, identified by Telerent as Lease 9907-004; Lease Schedule V, identified by Telerent as Lease No. 9907-005; Lease Schedule identified by Telerent as Lease No. 9907-006; and Lease Schedule 9907-008, identified by as Lease No. 9907-008. See Exhibit H. 119. In December 1998, defendants, Coast to Coast, William Price III, William Price, , Margaret Price, Patricia Price and Jane Lunsford, defaulted under the terms of Lease No. )7-008, as amended, and the Master Lease, by failing to make certain monthly payments when 120. As of November 15, 1999, the Defendants were in arrears in the amount of under the terms of the 9907-008 Lease, as amended, and the Master Lease. 1 BROWN & CONNBRY, LLP Wntmont, N.1081OR 17 IS 1 121, The Defendants' default terminated any and all of rights of the Defendants under terms of the 9907-008 Lease, as amended, and the Master Lease, including the right to use possess the 9907-008 Equipment. 122. Pursuant to the terms of the 9907-008 Lease, as amended, Master Lease, Telerent elected that all amounts due or to become due under the terms of Lease No. 9907-008, as 1, be and are immediately due and payable. 123. As of November 15, 1999, the balance due under Lease No. 9907-008, as 1, was $2,350.00. 124. Telerent has demanded payment from the Defendants but no payment has been See Exhibit I. 125. Telerent is entitled to recover attorneys' fees and costs from the Defendants under terms of the Master Lease. WHEREFORE, Telerent Leasing Corporation demands judgment against defendants st to Coast, William Price 111, William Price, Jr., Margaret Price, Patricia Price and Jane sford, jointly and severally, for money damages in the amount of $2,350.00, together with charges, pre judgment interest, costs of suit, attorneys' fees, and such other relief as the may deem just. COUNT EIGHT-REPLEVIN (Lease Nos. 9907-001,-002,-003,004, -005,-006,-008) 126. Telerent hereby repeats and incorporates the allegations of the preceding of this Complaint as if set forth at length herein. 127. The Defendants are in possession of certain personal property leased by Telerent nt to the terms of the Master Lease and Leases 9907-001, 9907-002, 9907-003, 9907-004, 105, 9907-006, and 9907-008 (collectively the "Equipment"). 128. Telerent, having determined to repossess die Equipment and being the full and lifted owner of the Equipment, is entitled to remove the Equipment in accordance with the of the Master Lease. BROWN &CONNF.R1', IA II 18 Watmnnt, NJ 0XIRN 129. The estimated fair market value of the Equipment is $457,901.98. 130. Defendants unjustly detain the Equipment. 131. Tile value of the Equipment and Telerent's interest in the Equipment will be dversely affected by the continued possession and use of the Equipment by the Defendants. 132. Defendants or other person in possession of the Equipment may dispose, , or waste the Equipment or remove the Equipment from the jurisdiction of the WHEREFORE, Telerent Leasing Corporation demands judgment against defendants oast to Coast, William Price III, William Price, Jr., Margaret Price, Patricia Price and Jane unsford, jointly and severally, for possession of the Equipment, together with late charges, pre- judgment interest, costs of suit, attorneys' fees, and such other relief as the Court may deem just. BROWN & CONNERY, LLP Attorneys for Plaintiff, Telerent Leasing Corporation 01 aced: Novembera,, 1999 By: C l?? teph• ie E. Nolan BROWN & CONNF.RY, LIX W.1monl, NJ 08108 19 t , VERIFICATION I verify that the statements in this Complaint are true and correct. I understand that statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to nsworn falsification to authorities. TELERENT LEASING CORPORATION ated: November/_1 1999 ckie Coo r BROWN & CONNERY,1.1.1' Nntmony NJ OMUS 20 ? i F i 6 Q a I i r I Q w LearL Number 9907 STATE OF NORTH COUI TYOF WAKE CAROLINA MASTER LEASE AGREEMENT' LESSOR: TELERENT LEASING CORPORATION 4191 Fayetteville Road Raleigh, Wake County, NC 27603 Telephone (919) 772.5604 FAX (919) 662.7012 OAIe: .tuna 10, 1998 This MASTER LEASE AGREEMENT n road. And mined Wle a. of the dale test vnnen.Mate by aba mWea Me NMN heated lain SM Lesseee Laos" hereby MISS-1. Losses. AM Lease. hereby base, hthn Losses. Me shear And type of MMpmenl moor" W The Len. Suloome. mete heel. Std ease. pan harm ("Mclbely, the'E9Wpmm1.). upon Ine caMdbn, eel Falls hneM MN as Me Luse SdMMMI 1. LEASING COMMITME119.ROm 1.So Me .4this Aprembeld4as .Aed.lest.- mAy rvad,. b... ra l ter -Taps, to Leeea tell as eanMn-Ibn loud MA Nm Washes-, n n -Nal dr W e lm• oh-M-1 be had to xeetd Last" - "Pa"I xM 4ne,var-9uynleM as nMhl was IM1- term. -M emdAlm, d We All-" W ahem ramahehl by Flee'. awl-eo'n eslMa Py lout. w k..eeTrlMn dw, a- tmut a Leas. SdaM41...pb d -M.elated by Lessee. 2, TERM. Suhnrao nnVUgnl to lemW-Ia WM A9reemn We lmmMNM as elrpYnM Ism Alf Inn Axeemanl Mae M M e M.M oMnp nlrm dale d We Mft-hMM tell. SM-Ato n IM. Lease Aprnmml. S RENT PAYMENTS. Anmal per We ETrSm.nl. Lueel Mal My Is L-'W- Md... ,et M npo. V We,.NouN- MdM, Sol IMh M We Laos. sNed.M. base. WMA Pa all .uN peymad to be We M a basal. Ne M1N day of We ranN IolWni NmealYn as We ETdMrenl Me delh.q Y Leua la Me ISNPM b IN Sell ..mm n nN la Lena Nagle MreKUraYmmM eN IMh„naUl nepMNe LASSO SN-Ab.Mn In ill event of Mal ea Wery States MeaAMM d he EMAMo l• lose.. Ma, p-1 soodw pannl as mWants baelf pp upMeO m.Nemaleal vO w that N Epull Set"We lame &^l bag, Add n lase applicable Lem MMMed and. W lease Io ea IdIN Mt cM. peb 9mpmmlAnee [amens ell the MIN EM.AM . Me a II L bea ya Lease Item u aa S ,,R .mint nymml Mal N Aa a1 Me tell ll MIS'N day a E MY d the monN Idlmvnp the LanDlelgn IN Led deWery.MM neMANbt T. n as Ine .dearth. II MY peymtd ereWtld M., ApeemenI b vast labelled by Lessee M We one E IS Ae• Lade easel pay to Latest sal Me Metal payment "a" ell let nlerMl M IM WKdn PaYmMI JIM Me dale We to IM data Me pAymed n nUNM .1 Me gale of Sallee, prrMl (15%1 Per ..ml be. a WIN. Me hgnetl gala MnlMed by ter, b eddnMn. INS Ma94s Ploy to .......d to Me mnMM "I .IIMlOWS PMM She "IM th o-li-II we sent MYmenn%gym wMN mosto SIHOlN has w n. Tdf Ap Mpg be MndMbe IN Ied .11.14 . Say pal a Wed. d.. " Tay Aprelmanl art m 1 m be a MI I.e.. Bose, She term'. M1gesJ M MY n may. e. Me a Md. a gewreal .11.1. M Say all e art un " lab mpj,d to lase" .'"Lad . lei Yger cM.M1y. "d nMMMeay artcoldIM be .uek to . I.L --Is vM. eetmu. damn mM. audel he lay MW SaMflays 1. MY e erx. 11 MY E epmM M W u easy ease. Lomas She' male All m InNN MnM,t t bd mleWn do I.My Ass Fes " shpgn of Me Ea lananl art es" .wU dg ?. his nn Ap,oh as to . ,d auburn enale StMlnb We SMprynIe MMMdesn i Axeeatml n A lbiNDlA SAY. a. OELNERY, INSTALLATION. INSPECTION ON AND ACCEPT 1 ACCEPTANCE. lasw"e1 pmt .r. M Me "Mats .peered as Me amealu Lease 50MAto M-.- ruaN Mn9efeMeM heath Wa maMHANIMnF W-eMMACb L<ne 2, a.1 II laud ILAIO LrNaL Ile Egdpnenl. Lufee boa parted InAMMb ebepap p abed" , by Leaaempbyeea ".9enl. w. J.9 M -be P11W1e1 rn.b9 I. chafe d No .,,.AN. "teas eall Io gestalt Leafed Mel ProMe " opmett nxelnrY 1. Me mevedlal high. EWThhnl M Ll111." Sold "11 II L..... or 1, Iden11"cNed a Mlle [eaten Ia neMery arW nllavalP of lase E9rnxnml xr9 ntlelnen IN MnYad beta ... N. Prehh.a .1. MI F"tee a tells M, Fds'... losses..1 e1 xM ..Pena, e,.1 pwnn wmM shame. Mn Nw.dn by be ETdpnenl gale 'be Memrln age aloha .M re"Y W MI".Im pl .1. E eeb?Wann he, 11th 1uM hon..." la. She 0.0 hom IS". hamoel. hood. . delay. Laew Shag MI M Nble M why delay n 1.11.1 as -melbas d. a I.Ma 10 de Mena. Me v" ".A rI., swell a a?bGdotl raM•... KWentaM. dnPAS, Mtd MMro...mbales Meth hal.abn. it b1. a letw"IW I"ManIM d Me E[anpl AIM d SWa aallleage. mE Ill. CSIW.d shall .11. la ly la"ma" Seew Coast To COREL Hotels Inc. LESSEE: 1252 Harrisburg Pike AGernss: Carl Lsle PA 17013 ". n.. c...r a hone: T l 717-243-8535 e ep Ship To: T[nvelodge Snmc as Lessee n/ an. [ww/ t0 Telephone: .,der, darted. PSIeM comp" aeml M Me poet elane Iss' parlbp hell" Ine an YMpeabn IS NAM W nn' "OW M " SIMIM ochn 19 hay. d ..wary of M,Mda Io Nlped Mhopad aema. W"s, plebs .teas Ne Ln dos'. Japan Y art MNIIMnM to I .alMMaay, an,a. Nall hasped J."St. lepx-he be adored ghte" N- Ine'. ' •IapIKKMnn ....w ama,l" "It [else Pa.. hotel a'. OamA9n my, u.wl Me nes M disposed as xMo wIRM aYWpNmbas tone Lnfa. ASSIGNMENT. Lean bell sal eubtun. IIM, as OI law Or dh.Mlasl.r punt•.aouery MINW In. E9ulDmant of this A91..m.at without Me p"rY- be H.Me dxNpee pas ea m Saba me nil Pln, .. east. Mad lebpnm. IaeMn. plardig ten boas We canter art u 1". Inner Jay np.rNfnn v easy Pon of la Inlxnl IP N. n. w Jpmsh mnunl dl Lmo, hlelasl h Aa or pen of le apple, pbn, ell f-daM. NN "Y ,"A 9xneaan un nd he"No% Mpel m-I". Lee' LSAI.e. y,P"Md dapopme MI. W. by Lea.... bn be obbl.1.1 ubaar Af Apream . Me meleNay Wauu -a'. dell be . under %I%A9aemml. Leased ben Wen Mx Less" mq.INM th be,IN-r •. Me1n1 as Ne EwFmsnt led" WIA AgameasM even E Reh mgrMeM at NM Aa.em-m, the ole-•...•-• -•-.. .__._.._.._ Iran Na E9ummeM leeMccl Ina prix of Los'.. to b",In We AlMhopenl be ea Epubnenll Io Ivan. Ne pdnpl plxMnl ell MneslnxK- d buoy hd.Ele<a... W oOIgeIIMf ubx mn Apeemed. 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Mt.AIa nMd xlanN Nnlx.bIW Nae Me dM1er mx and mhst --deroe M Me EMdPMnt Me aMl -1. tiro nom Joan, a Nn peat, a -"urn d [aeDIIIM PMItlk1M We Met l Me Ayxn rtn 11 pay I.ten, / ahead S bast Mmdld as .ntl SlaNM• Ideas a NN balm W f la Ne y pas be," P•MS-W-red, .Ma to Mmae 1 ll Mwq "al Mdnl M ha Ap Ev1p Me b tan mall glossas Lena - • a EWIManA ly n xSsee aI 1-1 Me A- " d d eba then". tan m EWI" M y So .. My My,, , Ne D agalal Pe lam lanl -u d bNleepM-LISM-itie MM "Mode Sax We see pom Dap" APa meal. II II ells N, MIM of Ne pnMe t Spot Da Attempted a Y gs. My teen, as tleM" N Mrs 2A d Me Mn.oM LamM1" 4N Cape 'I ee app"ppl" as h Airy -ppMW LesscelY Coast To 3-d91/s> IsedA?se"Ian rat o73LI'o?SS^ $e,d9 • V?(nass ? riYd • ? ]l1 TELERENT LEASING CORPORATION Gr: Anal CO-LESSEEI__?tl Axfla (CC IXj^ INamdl nltd,n, _? a? CI?? re PA 17o(3 C." ''ale alp rwdNSdW/,b?7'N? 3 -'?y?f 7 a 9(G i?ne„ .aLld ?u y ADDENDUMI LEASE ADDENDUM I TO LEASE AGREEMENT DATED JUNE 10, 1998 BY AND BETWEEN COAST TO COAST MOTEL, INC. T/A TRAVELODGE HOTEL, CARLISLE, PA AND TELERENT LEASING CORPORATION, RALEIGH, NORTH CAROLINA. It is mutually agreed and understood that William Price III will be listed as a co- lessee to the above mentioned lease. All other terms and conditions remain unchanged. Lessee: Coast to Coast Motel Inc. T/A Travelodge, Carlisle, PA By: ?G Title: Date: Lessor: Telerent Leasing Corporation Raleigh, North Carolina By: Title: Senior ice President Date: June 17, 1998 Co LessseeeZLz William Price III Date June, 10th 1998 r II Addendum to Lease Agreement No. Coast To Coast Motel, Inc. LEASE ADDENDUM?? 9907 Dated June, 10th 98 1g_, By and 8etween T/A Travelodoe And Telerent Leasing Corporation, Raleigh, North Carolina. It is hereby mutually agreed and understood that the following shall be co-lessee(s): Jane Lunsford Patricia Price All other terms and conditions shall remain unchanged. LESSEE: Coast To Coast Motel, Inc. `X X LESSOR: TELERENT LEASING CORPORATION B o V ce President DRIP 7/09/93 Social Security No. City Slate Zip social security Na. City Slate Zip Social Security No. Type or Print Individual's Namo Witness City Slate Zjp 842(3,000) White d Yellow - LESSOR'S COPIES Pink - LESSEE'S COPY (Approved) Green - LESSEE'S COPY o r PriIn ?Vldarj m/? Wltne55 or 7? ?// L_117C-n' Aug-27-98 02:OOP Franl Capana ADDENDUM III Lease Number 9907 ADDENDUM III TO MASTER LEASE DATED JUNE 10, 1998 BY AND BETWEEN COAST TO COAST MOTEL, INC. T/A TRAVELODGE, CARLISLE, PA AND TELERENT, RALEIGH, NORTH CAROLINA. It is mutually agreed and understood that the following shall be co-les5ees on Lease Schedule 1 (FF&E), Lease Schedule 2 (Televisions), Lease Schedule 3 (Air Conditioners), Lease Schedule 4 (Doorlocks), Lease Schedule 5 (Ice Machines), Lease Schedule 6 (Installation), Lease Schedule 7 (Third Party Signage), and Lease Schedlule 8 (Washer and Dryer). All other terms and conditions remain unchanged. X i _ X Pa Lessee: Coast to Coast Motel, Inc. T/A Travelodge Carlisle, Pa l J By. J Title: l? X? Lessor: Telerent Raleigh, North Carolina By Ttle: Senior V President 2L5 -?G 7715 P,OL Date: Date: 9/07/98 William Price ID LEASE SCHEDULE 1 Lessor: TELERENT LEASING CORPORATION 4191 Fayetteville Road Raleigh, NC 27603 Telephone (9191772.8604 FA%19191662.7075 rs EIGHT, pnin,raa X PreDaN Coned INSTALUTION, [WUlanal __ ar vean?v nruffee or Leffa(SEE SCHEOIILE 6) 11l511MNLG IIM?MMeI _ Pno ldDyL.11- X Pined by Lea+ee SERVICE. Il"n Imel Pfaddederleun X P,a .dMLeff.- Date: - J11ne 10, 1998 Coast To Coast Hotel, Inc. LESSEE: 1252 Ilarriahurg Pike Address: Carlisle PA 17013 nr a.e, a..w !v hMIM: Tela 717-243-8535 P Shi To: Travelod6e p Same as I.essee c., aid. c..... n Telephone: FAX: T[RMn 60 MONTHS ..-_ ._...,..w ...uem, N ua Ina nano no. -P.. -......._ - .._ -..r..._.. _... _ _ EndDmen111 Mnaeallon MI Padamwd er laam) on WOmIal d boa., NH Sale Is be mnMn.d M MIM u n u.al d r.W.nl. Rzw PAYNENTsf $4173.00 PER MONTH Aa Nnltl fares Epnnpmnl L.nu 0-1Dar Me Sen. .ma/j la T. W.nl N Reath, Norm Croma, duMe In. mn lean M In IMh W MIS Leaf. StMdob, PUS .PPeMd. "I.. d [eU1PM[NTI L SEE EXHIBIT "A" ATTACHED FOR DF.SCRIPTIOII OF EQUIPMENT Anvnuee PAYMENT. lo,ee 1h.1 mmn me U11 1- In naPnanN M advnnm mne am+nl d 1 8846.76 . au..nne mnNANe uiaa lee, n. a cdM.Mn d -W..1 of mi. leafs SNedWe LESSEE, Coast To Coast Hotel, Inc. J/??ol rorrualwn. rannenl??P an(M'nenl v,e P.? ITfpe a ram name ane uny z3-d1YS7J`Z LE5SORI TELERENT LEASING CORPORATION A or noel of++lanl5eaebry co.LESSeef Margaret Price (rYM or Ponl Name) roul,n„ j or L. _FICL.rY.IeJbLir CKe Carl s? ?0 ?]?? Cny 51a1n l?P - -?2:2 - 2h,_ -LOni., Ne d_a?l- >ra rtb ? .. I,'Xnnt1T' A"I'O SCIiED11I E I DATED IIINR 10, 1998 List of Equipment Valuc Line Genreelmwr Series: 20 IIVL2910 tv armoire 20 II V L2907 42" desk 20 I/VL2935 616 panel headboard 63 IIVL2924 mirror R3 HVL2912nightstand 43 HV1,2902 4-drawer credenza 43 HV 1,2919 30" parsons table 43 I/ V 1.2934 5/0 federal headboard Valnc Line (.'nrnnrnle lirlte Series: 34 HV1.25024-drawer credenza y1 HVL251930"parsons table 52 HV1.2534 510 panel hcadboanl 34 IIV 1.2524 mirror 50 11 V 1.2512 nightstmtd Is IIVI,2513 luggage bench Lexntnrk Carnet: 1208 sg yds 111.1528 11118 2210 sg yds 111,1528 1/ 154 3418 sg yds padding/Vistn 65 Miliken Cnmct: 375 sg yds "Mill 36" Wallcovering: .1150 No yds NCI (7-2946) 1260 Iin yds NCI (IC-3,115) AC purnitnrc: 20 I/AC61R deskchair 20 HAC9400 lounge chair 20 IIAC941 ottoman 154 HAC2200 lounge chair Amen Lightim 72 IIT-704-13 powder coal table lamp 97 HP-840.12 Pace SOW 111 swing arm floor lamp 61 HW-715-12 Pace Scttcr III wall Inmp Challenger Li hlg ing_ 20 II WA-1071 traditional style Cherokee Prantc Compn nv: 291 HART1620NPAD Designer collection 16' x 20" self-mailed PaNex IVihninelnn Series fedsprends: Ottawn Nuern/Hanh Color 20 Kingsize 16 Quccnsizc Pabtex I7ibnint/nn Series Bedsareadq: Ollawn 1'aticm/Scafemn Color 36 Pull XI, 86 Quccnsizc Pnhtcx IVihninclnn Series Drapes: Madison Patlcm/Earth Color 36 72" x 57" pnbtex IPilmintrnn Series Drapes: Madison Pmtem/Scafotun Color 61 72"s, 57" 97 59" center draw/single and LESSEE: COAST -ro LESSOR: LEASING CORPORATfON rXIII11111A1 TO SCIIRDIII F I DATED.IIINR 10.1998 List or rquipment.• Value Line Georgetown Series: 20 I/V1,2910 lv armnire 20 0111.2907 42" desk 20 IIVL2935 6/6 panel headboard 63 11VI.2924 mirror 83 I/V1.2912 nightsland 43 11111.2902 4-drawer credenza 43 IIVL2919 30" parsons table 43 UVL2934 510 federal headboard value Linc Cornnrate Etkc Series.' 34 IIV 1.2502 4-drawer cralenza 3,1 UVI.251930" parsons table 52 I/V1,2534 510 panel headboard 34 IIVI.2524 mirror 50 11 VL2512 nightstmrd is 11V1.2513luggagc bench 1 exmark Camel: 1208 sq ycls 111.1528 11118 2210 sit ycls 111.1528 11154 3,119 sq yds padding/Vista 65 Milikcn Carpel: 375 sq yds"Mill 36" Wnl Icnvcring: 3150 lin ycls NO (7-2946) 1260 lin yds NCI (IC-3415) AC Ftimiture: 20 UAC618 desk chair 20 HAC9400 lounge chair 20 IIAC941 otlommn 154 IIAC2200 lounge chair .Iilpcn Lighting, 72 IIT-704-13 powder coal table Imnp 97 1111-840-12 pace Scllcr III swing arm noor Imnp 61 HW-715-12 face Scllcr III wall Imnp Challen uc6 r Lighting: 20 IIWA-1071 Imdilional style Cherokee Frame Company: 291 HAWN620NMDDesigner collection IG'x20"self-nmucd Fnbtcx n'anatlgton Series Fled uoi!S Omova Pattern/nanh Color 20 Kingsize 16 Quccnsizc Fabtcx IPihnington Scrics Rcdsnrcmis: Ollmva 1lallcro/Scaromn Color 36 Full XI. 86 Quccnsizc F,Ihlcx IPi6ninginn Series Drgu!a b4adison Paltcrn/Garlh Color 36 72" x 57" r•lhlcx il'ilruin¢ron Series Drapes: Madison 1lattern/Scafnnnl Color 61 72" x 57" 97 59" miler draw/single rod LGSSGG: LESSOR: COAST TO COAST MOTIi1., INC. TFURGNT LEASING CORPORATION `?TIIrlEr !/!a 'IIY715 Sep nr VI a Prenldgnt ?` DAIR DA'rr.: e / 2 7 / 911 Lr, I FXHIBIT'A' TO SCHEDULE I DATrn.ITINR 10, 1998 List nr 8g it ipmcnt: Valuc I.inc renr'cclmrn Series: 20 I/VI =710ly arnmire 20 11 V 1.2907 42" desk 20 IIV1,2935 6/6 panel headboard 63 OV1,2924 mirror 83 IIVI.2912 nightstancl 43 11V1.2902 Mdrawcr crcclenn 43 IIVL2919 30" parsons tahlc 43 OV 1,2934 5/0 rcdcml hcodbnmcl Value Line C'nrnnrn/ei/ve Scrics: 34 11V I,L502 4-drawer credenza 34 IIVL251930" parsons tahlc 52 JIVL2534 510 panel headboard 34 IIV 1.2524 mirror 50 IIVL2512 nightstancl 19 IIVL2513 luggage bench Lexntark Cnrncl: 12(18 sq yds 111.1529 11118 2210 sq ycls 111.1528 1115'1 3,118 sq yds pruldingfVista 65 Milikcn Camcl: 375 sq ycls "Mill 36" Wnllcovcrins: 3150 lin ycls NCI (7.2946) 1260 No yds NCI (IC-3415) AC hnrnittlre: 20 IIAC618 deskchair 20 HAC9400 loungechair 20 IIAC941 ollonnan 154 IIAC2200 lounge chair .limen Li htin': 72 O'I'-704-13 powder coat lahle lamp 97 IIP-840-12 Pace Setter III swing arm floor lamp 61 OW-715-12 Pace Setter III wall lamp Challenger Lightine: 20 11 WA-1071 tmditionnl style Cherokee Frame Com an : 291 LIARTI620Nh4D Designercollcclioi 16" x 20" sclGmalled Fahlex Wiln h ion Scrics IlcdsLrcads: Ollawa Pollernlliarlh Color 20 Kingsize 16 Quecnsizc Fahtex Wiluliu¢Inrr Series Reds p rends: Ottawn Pa0em/Scaroam Color 36 Full XI. 86 Quecnsizc Fal Icx Wilnrinrlnn Series Drnpes: Madison Palter/Earth Color 36 72" x 57" Labtcx Itrilnrincrn-)r Scrics Drancs: Madison I'allern/Scaroam Color 61 72" x 57" 97 59" center draw/single rod LESSU: LESSOR: COAST'r0 cop %s?O'rET„ INC. 'rm.r-w N*r LGASINCi CORPORATION /n L IIY: I lZfr?_ Ill'rLG: c//f C /.L? TI= Ben or Vtr.? Pros t<t ent DA-1 F- fil Z It 9h X rxlnlirr'A' TO SCIIEDIILE,, 1 DATE.D.IIINP, 10 1998 List of Equipment: Value Line GennysOn91 Scrics: 20 11 VI,291o Iv armoire 20 UVI.290742"desk 20 nVL2935 616 pnncl hcadboanl 63 HVI.2924 mirror 83 /1VL2912 nightstmtd 43 IIVI,2902,1-drnwcr credenza 43 II VI.2919 30" parsons table 43 IIV 1,2934 510 fcdcrnl headboard Value Line C'nrimne bNgc SSercs: 34 IIV 1.2502 Mdrnwcr eretIC11'La 34 I1V 1,2519 30" parsmrs lahlc 52 IIVL2534 510 panel bcadbnard 34 IIVL2524 mirror 5o 11VL2512nighlstand 18 11 V1,2513 luggage heneh Lcunnrk C0r 1q: 1209 sq yds 111.1528 1/118 2210 sq yds /11.1528 11151 3,118 sq yds pmlding/Vista 65 Miliken Carncl: 375 sq yds "Mill 36" Wallcoyerh g: 3150lin yds NCI (7-2946) 1260lio yds NCI (IC-3415) AC purnitnrc: 20 IIAC618 desk chair 20 IIAC9400 mm,ge chair 20 IIAC941 ollommn 154 IIAC2200 Inunge chair Allen Li 4nin': 72 HT-704-13 pnwdcr coal (able lamp 97 lip-840.12 pace Sellcr III swing non (10017 1,11111" 61 Il \V-715-12 Pace Seller III wall Innip Challenger Li d1, rllllg: 20 BNA-11171 trnditi0nal slylc Chcrnkee rune COMP-111Y: 291 IIART1620NMD)esignercnllec(inoI(i' 20"self-nlatled rohtcx IPilmin¢ton Series Ilcds rcn ads: Ottawa I'allcrn/L•arth Color 20 Kingsizc 16 Quccnsizc Pabtcx IPilnrinelnn Scrics oafs rc11 ads: Ollawn Pattern/Scafnenl Color 36 full XI, 86 Quccnsizc Palhtcx wilminvtrm Scrics Drapes: Madison I'attanllliarth Color 36 72" s 57" Irahtcx IPilmin, ton Scrics Dmges: Mndison I'nltcol/Sc;dmmn Color 61 72".\ 57" 97 59" ccoler draw/single rod LESSEE: LESSOR: CO-AS*S'r?-ro c1" S'r MOTEL, INC. 'rr -lil' 'I' I EASING CORI'ORA'I'ION BY: !r,;c? ?'Trrt.r::-/i(?!° I°fC:: Sent r Vlc Pres lenc DA'I'li; 6/27/7tl DAT ': CO-I,fiS'liliS: /\ R 11.1. I'ItlCli dP • ? IIIAR(itlil' PRICE Jul.-17-98 12:05P Frar Capana 21: '50 7715 P.01 ADDENDUMI Lease Number 9907-001 Page one LEASE ADDENDUM I TO SCHEDULE 1 DATED JUNE 10, 1998 BY AND BETWEEN COAST TO COAST MOTEL, INC. T/A TRAVELODGE, CARLISLE, PA AND TELERENT LEASING CORPORATION, RALEIGH, NORTH CAROLINA. It is mutually agreed and understood that quantities for the following items will be changed on above mentioned Schedule 1. The new quantities are as follows: 42 - #VL2902 Value Line 42 - #VL2919 Value Line 42 - #VL2934 Value Line 33 - nVL2502 Value Line 33 - TVL2519 Value Line 50 - #VL2534 Value Line 33 - nVL2524 Value Line 49 - #VL2512 Value Line 16 - #V1_2513 Value Line 150 - #AC2200 AC Furniture 4 z5-g? cr o*17 '72f- C?18.oo)-N? s. rwM2. 14 - Fabtex Wilmington Series King Bedspreads - Ottawa Pattern, Earth Color 60 - Fabtex Wilmington Series Queen Bedspreads - Ottawa Pattern, Earth Color 14 - Fabtex Wilmington Series Full XL Bedspreads - Ottawa Pattern, Earth Color 18 - Fabtex Wilmington Series Full XL Bedspreads - Ottawa Pat. Seafoam Color 40 - Fabtex Wilmington Series Queen Bedspreads - Ottawa Pat. Seafoam Color 7 - Wilmington Series King Bedspreads - Ottawa Pattern, Seafoam Color 55 - Fabtex Wilmington Series 72" x 57" Drapes - Madison Pattern, Earth Color 40 - Fabtex Wilmington Series 72" x 57" Drapes - Madison Pat, Seafoam Color 95 - Center Draw/Single Rod 59" As a result lessee's monthly payment will be $18.00 less per month. All other terms and conditions remain unchanged. Continue to page two... Jul-17-98 12:05P Fvar Capano Lease %lumber 9907-001 ADDENDUMI Lessee: COAST TO COAST MOTEL INC. CARLISLE, PA 21 750 7715 P.02 Lessor: TELERENT RALEIGH, NC page two BY: TITLE: TITLE: Senio. Vice President DATE: DATE: July 23, 1998 a.. _., Aug-1.1-98 06:30P Fran :apana 21_` SO 7715 P.01 Lease Number 9907-001 15- ADDENDUM LEASE AGREEMENT DATED 3UNE 10, 1998 LEASE ADDENDUM AST TO COAST MOTEL, INC. T/A TRAVELODGE BY AND BETWEEN CO HOTEL, CARLISLE, PA AND TELERENT LEASING CORPORATION, RALEIGH, NORTH CAROLINA. It is mutually agreed and understood that the following items will be changed to the above mentioned lease: 375 sq. yards of Milliken Carpet will be reduced to 300 square yards. 300 square yards of carpet padding will be added as well. There will be no change to lessee's monthly payment. All other terms and conditions remain unchanged. LESSEE: LESSOR: COAST TO COAST MOTEL, INC TELERENT T/A TRAVELODGE, RALEIGH, NC CARLISLE, PA BY: TITLE: TITLE: senior vice President DATE: DATE: August 18, 1998 FROM :.TRAUELODGE 11109?Ya la.aa CHANGE ORDER LEASE SCHEDULE i U"cr. TELERENT I?J1&ING CORpORAT10N x101 Fay0lkvHls Raid RRlaigh, MC 1700 Tdephmm (010) 7TIa60d }AX (810) 602.7075 GRAN{ W RORT MTY1Ir0 luR ¦ 1---_•J S376.1i I` r6,%A pq M 31M aMon to T, aP r WRCIR1Cy4 Vwdb 20;GOa1R GCBs 6CUIPMENW •: " ' ' ' •Rf LS LftMAL1T AWAM AND UNOSAW.C0 au Lessor Wo •idd a . aa+ w 1-- ;1619 YD5•B00•S•VINYL (PAITT.AV4 7-2966) ;YD9.iYAW 8 L'OBHT:'VIBYL (PATTER"i;9.;.IC-?415 COAST TO COAST MOTEL. INC 1252 RARRI-MW ME TelRphana: VARe Te: TRAVELODGE SA,X AS FAX: m:r=fi Le"Iso ooRpo"MDN WILLIAM F. PRICE, III VICE PRESIDENT aaM"W' -&n)-3&" J2 7- f2- ar Agest Ac t3ecmy y Br• - 1 FAX NO. : 717 249 4950 Jcv. 10 159E7 eS:eePM P1 IJa a &gl? Lease dumber 9907-001 Date, QOVWER 51 1993 Lease dumber 9907 - 001 ADDENDU LEASE ADDENSU O LEASE SCHEDULE 1 DATED 6110198 BY AND BETWEEN COAST TO COAST MOTEL, 0C. T/A TRAVELODGE, CARLISLE, PA AND TELERENT, RALEIGH, NORTH CAROLINA. It is mutually agreed and understood that the following items will be added to the above mentioned agreement: a) 190 square yards of Miliken Carpet installed for Breakfast Room, Lobby, and Meeting Room. b) S AC Furniture Sofas c) 6 MTS Breakfast Tables d) 24 MTS Breakfast Room Chairs e) 6 EF Series Meeting Room 7A&t- s 0 25 MTS Meeting Room Chairs g) 6 Laundry Carts h) 2 Luggage Carts 1) 3 Maid Carts As a result lessee's monthly payment will be increased by an additional $461.00 per month, plus tax. It is also agreed and understood that the 300 square yards of Ensign 3/8 padding will be deleted from above mentioned lease. LESSEE: LESSOR: COAST TO COAST MOTEL, INC TELERENT T/A TRAVELODGE RALEIGH, NC CARLISLE, PA BY: - BYE TITLE, -L' TITLE: Senior ce President DATE: 9 f7' O DATE: 8/27/98 lYRliFH .... Dec-17-98 08:15A Franl capanc .ro, wm rrt•1 rnUt+t .N. r Kurl I UHF' rU ADDENDU , I Y 215 -50 7715 P.01 VIC. LC I-...- ... . Lease Number 9907-001 Lcecz anDENDUMITO LEASE AGREEMENT DATED JUNE 10, 1999856Er AND AND BET`NEE"l COAST TO COPST MOTFI, IN C. (/N?RTHODROLINA. n •rr r cAerAtr rnpoOD,grrnNr RALEIGH. TELEnEr, r ? •r, s in'1 M n .nn.?n fan rrulenva will It is muNairy agreed and undesstuou G'?°` one be added to above mentioned lease. There. will be no change to lessee's monthly payment. Att 0-k,r `terms and condleons remaln tmchrnged. nrr Var..... lessee: l(,o.st to CC-35r Motel, Inc. T JA Travei^dge o //_ ZX. By: V / / , Xl Title: _ na-.... /t:2 -( -2 n -- v LesW(: Telerent Raleigh; North Carolina By: IQC1-P? Itle:se_nior V'c President pate: L2 2 !=° 8 -- NOV -i/ -yti uD: JI rrann •.ur?? ADDENDUM,V'y 4 Lease Number 9907-001 LEASE ADDENDUMy' LEASE AGREEMENT DATED JUNE 10, 1998 By AND BETWEEN COAST TO COAST MOTEL, INC. T/A TRAVEL.ODGE, CARLISLE, PA AND lELERENT LEASING CORPORATION, RALEIGH, NORTH CAROLINA. It is mutually agreed and understood that the following items will be added to above mentioned lease: 10,500 Lln. feet of carpet base 100 square yards of Mlilken Hallway Carpeting 42 Value Une Georgetown Headboards #VL2934 As a result le::ee's monthly payment will Increase by an additional $353.91 per month, plus tax. All other terms and conditions remain the same. Coast to Coast Motel, Inc. T/A Travelodge, Pa X Lessor: Telerent Raleigh, North Carolina Co-Lessee: Telerent eigh, North Carolina J? By _e :Se i r ice President Date: November 23, 1998 u2 Sep,-23-98 08:23A Franl :apanc 215 '50 7715 p,02 Lease Number 9907-001 ADDENDUM III LEASE ADENOUt+1,3Ii T0 LEASE SCHEDULE I DATED 6110/98 BY AND BETWEEN COAST TO COAST MOTEL. INC. T/A TRAVELODGE, CARLME AND TELERENT, RALEIGH. NORTH CAROLINA. It is mucogy agir eed and urdersaood that the following wla be added to the above mentioned lease sdiedule! it70 sgArt yards of Milliken Carpet *A048 Solid Blue As a result less ses's morroy payment will Increase tD an addhional W,DD per .'='d7, *S taw. All other terns and condldor~s remain unchanged. COAST TO CDA.aSr MOTEL. INC T/A TRAVEL CARLISLE, PA BY TITLE: 41 X DATE! e-7- oI 3 ^ W@1am Prke TELERENTLFAMNG CORPORATION RALEIGH, NORTH CAROLINA BY: ? ?L- ?nior ice President TITLE, S -s . DATE: 1.0/01/98 11, 1 1 J 1 L S P 1 i i I i I I U .n r x W III LEASE SCHEDULE 2 Lessor: TELERENT LEASING CORPORATION 4191 Fayetteville Road Raleigh, NC 27603 Telophonal9171772.8604 FAX (719)6624075 FREIGHT, (WIN mw x PmPea [Dees INSTALLATION, Ilnual Onel ny Vemd Pyle,.... _X_ ny Le„m (SEE SCIIENIIId. fi) INSURANCE, hmul Onel _ P.mveE Vy Leud ?? Prar"etl by levee SERVICE$ IWrytl Oee) P'w ed EY Leud EQUIPMENT, I.eRSG Nllmllcr 7707-002 Data: JUNE 10, 1990 LESSEE: COAST TO COAST MOTEL, INC. Addrosl:1252 IIARRTSRURGII PIKE _CAgLISLR n.. PA rM. 17017 rP TolPpllGnp: ?1? OAi 6575 Ship To: 'nnaHCT nDc Telaph-M: FAX: 6O MONTHS RENTPAYMENTs, $1026.00 PER MOM" uanw u.. ..... _ _ . . C"Mru. robe IM1e NR W- n I" loop by IM. Lem aaleNb, P 1• GATE, 2 - MAGNAVOX $TS3654C 36" CONSUMER TELEVISION WITH REMOTE 118 - _ MAGNAVOX $TL6132C 32" COMMERCIAL TELEVISION WITH REMOTE 118 - MAGNAVOX #AJ3040-17 CLOCK RADIO 1 - RG4172BK SET-UP TRANSMITTER 1 - RT.5I ROCK SMART LOAORR 7c,.l 3•1 6 wkLN`g•nrnaad. ube N., e.•ymmpna.Fawaaw. ADVANCE PAYMCNh 1 Dore fMe I<m.l lne la.l Me Ill PeY^Rnb LI etlnMe n IS. ...N a S ?Ly?.. ?? dNSnL IX teue SOetlub antlaeun,,pee, oaf el rua, ha, pwJ, IF SERVICE IS PROVIDED RY LlISOR( Oam•Oa lalre ETOpme^I tlue IOlr.e •tle of dnL.M, el lO.ee, b •9enb vulld empFryee O INS, 1". ewele re nolC ...4 pY IMf AOreemenl It tlme^M ewer mlu"ed•Wla of lla lxm'Kl, panerkL tleWery. mlaNlwld ulu aM.ImemeaeP^.dne,ymua...A.m•I m"m., Ma1.9m1 nee0lan a.N,ryS. novel EamapnJmnendrLE'S'. r d Imole maaN^•n[e LESSle,_-COAST TO-COAST-MOTEL[-INC.- ?j In.,IPnm Cy?lw,. l'aimenu,pm Ow^mI lJljjl4ry ? lQlr! r bi•C Q.{r+1 rl IIYM m 1'nm Ibme am Inbl 7 - z 9 7 5'7 Y.L. NTIA y13 AP He TELERENT LEASING CORPORATION Gy a11eH ? `/ - Avl,Mnl sedelary Co.LESSEE, FIARrrARET-P'jTOF; rrvr a Pnm Ilanb) litrl.ca; ? St.11. 3- Cny SMItl d!Q, „Np cn.3 - 38 I'I I ) T, ,; I 1 - n^Memm LEsstc'S copy Lull.", EMe a ree.w. IECSOn SCpnlES r", •1 ERSLLG COPY l4 nwem ?? Au9731-98 01:53P Frar Capano 21; 750 7715 P_01 ADDENDUM Ill ADDENDUM 121 TO MASTER LEASE DATEO JUNE 10, 1998 BY AND BETWEEN COAST TO COAST MOTEL, INC. T(A TRAVELODGF, CARLISLE, PA AND TELERENT, RALEIGH, NORTH CAROLINA, It is mutually agreed and understood that the fokwing shall be co-lessees on Lease Schedule 1 (FFBE), Lease Schedule 2 (Televisions), Lease Schedule 3 (Air Condlboners), Leese Schedule 9 (Doorlocks), Lease Schedule 5 (Ice Machvxs), Lease Schedule 6 (Installation), Lease Schedule 7 (Thins Party Signage), and Lease Schedule 8 (Washer and Dryer). AM other terms and condMons remaln undianged. X" Wllltam Prlct Ill Pa Lessee: Coast to Coast Motel, Inc. T/A Travelodge Carlisle, Pa A X ?` Hoot . /?r/ Date; . .11 Lessor: Telerent Raleigh, North Carolina Date: 9/07/98 D- a c 4 A- -. i i 1 F e 9 S e 0 .G L X W ' i ....... ... . 9907-0031 LEASE SCHEDULE 3 Le SSOr; TELERENT LEASING CORPORATION 4191 Fayetteville Road Raleigh. NC 27603 Telephone (919) 772.9604 FAX (919) 662-7075 FREIGHT. (lonw, One) % PuP.M -? C.M.d INSTALLATI ONl II410SI Ond nrvaMd aria... x nrL.uN INSURANCE. II.A1 ONI pnxM.d Drt.Nw X Punwaled by Lowell SERVICE, pmmon.) _ MoMded by Lufor R Punnud by leefe. Date: lime 10, 1998 LESSEE: CDnBt To Coast, Inc. AdduLs: 1252 linryIslearr, Pike Carlisle PA 17013 Z; hone: Tele veal 717-21.3-8535 e.., n p Ts: Shi Trove lodge p same or. Lessee ur hnne: l T ur, ar h a op FAX: TERM. 60 MONTHS IDS Nlm RN. nee. on qe SPAS Of ON ednrblM d qe nNetlM w OUIM M M. Emilprw,l IY hfIASAIM kit performed eYLN.N) m p.IM.e. M Leeue, Sakidale to N .dM enl Fall MONTH A, NnIal - . 4 .p edha lean udul Iaq Dy q LUU S&W.4, PWe SPpmwe. EQUIPMENT. 31, GE BRAC61 grille Oloige) 70 Carrier 952SF.-312-3 PTAC Units 70 Carrier NCR ILLE-PLA -BEIGE 70 Carrier #WALL SLEEVE-lPK ADVANCE PAYMENT. L.111. 0.9 NM m. All Nwe(T) p.ymenlA h.drmuhqumdml Nf 2650.72 , yyAgLy AppoMDle laws law, n e e im a eppanal of WS Ie an StAwule. NON.FinUnt. II In mWNh Wave and IMenIeM Intl Ina dlud. low me PTAMAC MIS Moon! Dneh Are • del.D.Me AM NDIweaDle Pol uM h we ANY W D.rame A Pad Tea DemlAnenl.In'.., DISCLAIMER. Mo.bpdnAMlp Tabdnt drenPN N[drvnaM qa l,,. nl MAll lYadmAlo Flown. AeenYelled maenA nl dbpaf.p of fendenNlL IIdN. rynbmIA M1 NRLd. ma Atlu1N AnNd TabNM In"hN ."Al M Met. larAgemvgleMbldanean. NOMINISTANDINO ANY Roommate NmEm TO THE CONTRARY (EXCEPT SUCH PROVISION CONCERNING TILE STANDARD MANUFACTURER'S WARRANTY APPLICABLE 10 TIRE EQUIPMENT) DR NIYCOIRRAnY REPRESENTATIONS, VENIAL OR WTIITTEN. MADE TO LESSEE BY AN AGENT OF LESSOR. THERE ARE ILO WARRANTIES. EXPRESS OR IMPLIED. RELATING TO THE EOVIPMENT INCLUDING HIE IMPLIED WARRANTY OF MERCNANTAORITY AND THE IMPLIED WARMNTY OF FITNESS FOR A PARTICULAR PURPOSE. Uwe ANNWedpeA In.1 a h.. NI Noed upon the L..,Wl Nh M Fbpmml In uwd.e d West" me EeulpmM laced neleuMer In Le.fes nW N.na ids feleded ma ElMlpmenl h MNrce upon N mm nA AMNdemenl. InIN rvnnl IN Ewlpnenl h NIw4Ne Id qe Luue S pMYMIM purpeu. LeeMe msa nal Dueeeved d14 oPnetlbn In DAY real bleed lor qe nman.q Lem. M FMS Aeleemeni AM h N NeM fNaenee De enlnbd to oenuNUeMldd uedU dhnAeu Pn Adami W qe Inm4Dary DIIo.ERWNnent. II SERVICE N tndewerd EDY M-1 APNeme 1n The NmlmhJ oeemplacemeM ofnny emlenl la and m Powotl pAa Niue 10rIRN dMeaS p owlNX)?NPA.emenl 0l ny Plot. d flaw. Coast To coast Nntel, rnc• LESSOR, TE/?LERENT LEASING CORPORATION ` IN n401 . Pdalen, P.MeNMpw Owncll Senmr mPlpfldenl /lM rC(rn /!/ yl or LAYS .? 3 rtrrn!o? r PnRNanna ag(J / noel - O Al- Anee ANIINnI ECUCIary Margaret Price ALAI Price Jr, coaessee, tvMPrEnn1 Name) ? (iYpe or PMI Ibllel yJ ? _. V_ A,Pnd., _I2L?nrr_SLrcf Lle lasZLlnr_r_islrn V I?oi3 ?1 !1 1`7013r?!5?--i fl ? J Ewl. l Zm CIN 5111. '1 ZIP EY3Lir` a`J- o=' I 5 SlSedunNe X13 F 10?? umatf Capano ADDENDUM 11r 21_ 750 7715 P.01 ADDENDUMZFTO MASTER LEASE DATED JUNE 10, 1998 BY AND BETWEEN COAST TO COAST MOTEL, INC. T/A TRAVELODGE, CARLISLE, PA AND TELERENT, RALEIGH, NORTH CAROLINA. It is muCialiy agreed and understood fhat the fokwing shag be co-iessm on Lease Schedule 1 VFW, Lease Schedule 2 (Teieylslons), Lease Schedule 3 (Alr Conditsoners), Lease Schedule 9 (Dooe=W, Lease S&*dule 5 (Ice Machines), Lease Schedule 6 (Installation), Lease Schedule 7 CrNrd Party %nage), and Leap Schedlule 8 (Washer and Dryer). AY other terms and condltfons remaln unchanged. X *pa Lessee: Coast to coast motel, Inc. r/A Tra"lodge Carllsfe, Pa . X ey?? v l J? ,Q \ Y" Title: I y ' X, Date; Td X Lessor: Telerent RQ?qigh, North Carollna 8y: T1tIe;Senior ice Date: 9/07/98 Presid ^?k _? 1 W C M LEASE SCHEDULE =Fayettaville CORPORATION R NC 271503 4 FAy.191916s2.7075 FREIGHT.PmNl Onsl %_ rreP•N _? ceeen INSTAL"TIONt Pd4•I Onel nrvrndM - ?? OYlnfu _x _ nYLeuM IIISURANCE. p .w o..) _ p,w40nrl•11d x Nm 141L.f\ee SERVICE. p wOml _ PIeWMDibpM X AmN•d Ml u... Lcnno Number 9907-004 Data: .lone to, 1990 LESSEE: ConsC To ConaG Nn [EL Inc. 1252 Ilnrrist Pike Andreela 17011 CnrliSle PA TDluphnneL 717-240-fl575 Ship TO: Trnvc lodge Same as Lesson FAX: 60 MONTHS b RENTRAYMCSTS[ $962.00 RtR MONTH Ma. LOUIFMlIIT ?- Tesn Lock Egnlpmcnt: 2 Spares 60 IIT24tlT261• IOCILSets 60 IIT24tIT26R Lockscts 120 TSE14NV exterior Heather package northern version 1 IIT201 Insertion mini front desk station on-site training 120 installations koycard L,00 T5990000 s?lnndnrdykeycnrdss 7 TSPNII oncesn ,.,It render H/box panic 7 SA-1 ACCesa singic 'Innr H/mng lock & pnn 1997.04 NW""pse.Ne MH. b.,u Y[ 14Yn d epp -l Olml, ADVANCE PAYMENT. te,.nn 11.1 11" Ne I.M. n) p•Ymenb N MvnL. N Ne.meunl d f?---? bole N,dvm[e, uedA APMm•I AM •M MEANnN N nrvey Mlpmtlbn n.MM to pd..0 Mdrt. SNenrtle.^ ?_\Idt m+labl\.n, rolurnkN Inmlum MUeEn m e. U\I mrmrN\ • Ln\\ne WJlpmne M<NnneNeTIMn11nM<n nn emra •........•IE n....nvln. <[E n<Id nnemr•nr. I.. In ]D Len\enrlNe •djKenlNem. pel Y Ae finolPpm rnlr,Ke d...... dnFpennma oC. pen q lMUevmepn mpen,e. IlMVeI, IMM. K[rrod Ne tlm M rv•ry dry lmOPen Iran T.Inm, L<e\Yq IMKa M., T.Kmue In+unn\DMn numM lennS a1d ejP1 mneN?iYaudunn.tfy win mndiY $ idea N INS Apeement. lee leree \n•e ne nmmd •1 M. Mln of f31E1 b P er Y Mr De MTlbd W b bvek•dtl MV GMMMe1en.Y,lOe"' bole\W.arN a\\YjM peln<Me to Mnl\^re lm??elf MY pdjnMilxNl Pr[M1MKI\Id $<NYm11m11a le lU\pNp nlMMUnd d<n4N Cae e4menl\wnldLnrv<MI • lhn\IrIM?al\IlndSenknfet_mll/shA\Mnen lee.See SravM1 PM edml Mre toleLd LdnLef\eebelocolnNY lxOdgtPa\I doe AMI[mnl dru0a\ mW elte d TMs in [ever nedaTrele d n[dnd nlpmalm pmMe 1 •IM <peet • Ief,dflhen nemnl Yn MYn ImUnel nnablmbtMTnmre lE llerNbmeKf\ITMeI<\KeN rIMndPO\Ie\OrtNH pemYUd N<E%rIMR<E. INen <omrmPl•Ied. ncYldp oMmn+dY. dun E M\eL IeLM nd\ ".-A'm., Z. N pYpeu d,<'ADM Nn LeffM mnMf n?e lhem eM meet Y\NMdemeMt. • Innt ln<fam<ue AP,.np e IM n\lee<IdI PIIXe\\,a\L<ffd A\nme\MIef IMn\ILetlY r'n•Iteerll lM d•m•EM ddIMpM•r edN. fMlanle dlM p< le\tee vn enYb pnp[rMn<drl MIeMeKMr•INe\.p le\\ee'\L<anlf • MlM lnau.<\emPYrynf. Mrn\ itn<c nelaY eTnlmenl reMdlnde[bn Mdl[nalfale\Ielnf YemeM\\naena NelApn\IdIXYdlb tef\aaal le\tee'e te4 PpenU. N me er•nl M dsNUll ln\fM M pp •'Pesrdn Ir INSTALLATION I3llRIORMCe nY L[SSGRr AIeb[IrkMIpMrM. M'ef.Lnnle,nmFUP eM •ne nl<rp Tn 4e 05 _LLLan_ ! ";'YIl?ryfin111AmnAM linel a 3 - d 91 .S7 10- ill 19 IM L[SSOP. TELEPEIIT LEASING COapOPATION Pr / ?Ser dVC pmsi AneLL AeVLlanlsmd.[Y 11-LE It arga rr11L_P ylI rlNl namn? c,ty ?v Slate 033 35 N -7a .rdcgl5ean In lu VAlnn. ?/1=-?? ? _ np 0.4eea pv? •.,.,,.,... _ DAR?R? ADDENDUM,11-'-)- Lease Number 9907- 00- LEASE ADDENDUM IF TO LEASE SCHEDULE 4 DATED JUNE 10, 1998 BY AND BETWEEN COAST PA AND TE EREPIT TLLEASING CORPORATION, /RALEIGH,. NORTH CAROLINA. It is mutually agreed and understood that the following Items will be added to the above mentioned lease: 1- TSPMR ACCESS WALL READER W/BOX 1- SA-1 ACCESS SINGLE DOOR W/MAG LOCK AND PANIC 1- HT201P TWO STATION FRONT DESK ENCODER The following item will be deleted from the lease: 1- HT201 ONE STATION FRONT DESK ENCODER The correct numbers of dooriocks are: 76 - RIGHT HANDED DOORLOCKS 42 - EFT HANDED DOORLOCKS As a result of above Lessee's monthly payment will be Increased by an additional $146.00 per month, plus tax. All other terms and conditions remain unchanged. LESSEE: COAST TO COAST MOTEL., INC. T/A TRAVELODGE, CARLISLE, PA BY: 6%f-? LESSOR: TELERENT RALEIGH, NORTH CAROLINA BY: ?- TITLE: _4Sen Vice President DATE: DATE: 8/ 2 7/ 9 5 sap-02-98 08:04P Frank ':apana 215 -50 7715 ADDENDUM P. 03. Lease Number 9907-004 LEASE ADDENDUM?TJrTO LASE SCHEDULE 4 DATED JUNE 10, 1998 BY AND BETWEEN COAST TO COAST MOTEL INC. T/A TRAVELODGE HOTEL, CARLISLE, PA AND TELERENT LEASING CORPORATION, RALEIGH, NORTH CAROLINA. It is mutually agreed and understood that the following Is what is to be leased in total on the above mentioned lease schedule: 77 - HT24MT26R DOORLOCKS 43 - HT24MT26L DOORLOCKS 120 - TSEWNV WEATHER PACKAGE 1 - HT201P DUAL STATION FRONT DESK ENCODER 1 - TSTRAIN TRAINING 62 - TSINSTPP INSTALLATION PRE-PREPPED DOORS 39 - TSINSTMDEC INSTALLTION METAL DOORS 17 - TSINSTWDEC INSTALLATION WOOD DOORS 1500 TS990000 GUEST ROOM KEYCARDS 300 TS990002 EMERGENCY KEY CARDS 3 - TSPMR WALL READER WITH POWER SUPPLY 5 - SA-4 ACCESS DOOR FOR ELECTRIC LATCH 3 - TSINSTWR INSTALLATION FOR TSPMR 5 - TSINSTASD INSTALLATION FOR SA-4 55 - TSCP COVER PLATES 55 - TSDJBF161 COVER PLATES 34 - TSDJEF160 COVER PLATES 120 - FREIGHT There will be no change to monthly payment. All other terms and conditions remain unchanged. LESSEE: COAST TO COAS MOTEL, INC T/A TRAVELODGE, CARLISLE, PA BY: TITLE: DATE: LESSOR: TELERENT RALEIGH, NORTH CAROLINA BY: TITLE: ten ice Presid DATE: September 9, 1998 F.__'. Aug-31-98 01:53P Frar Capano 21' 750 7715 P.01 ADDENDUM III Lease Number 9907-004 ADDENDUM III TO MASTER LEASE DATED JUNE 10, 1998 BY AND BETWEEN COAST TO COAST MOTEL, INC. T/A TRAVELOOGE, CARLISLE, PA AND TELERENT, RALEIGH, NORTH CAROLINA. It is mutually agreed and understood that the following shad be C7-lessees on Lease Schedule 1 (FFdE), Lease Schedule 2 (Teievislons), Lease Schedule 3 (Air Conditioners), Luse Schedule 9 (0= M), Lease Sd v&le 5 (Ice Machrom), Lease Schedule 6 (Installatlon), Lease Schedule 7 (TNrd Party %nage), and Lease Schedkie 8 (Washer and Dryer). AM other terms and condttfons remain unchanged. X Pa Lessee: Coast to Coast Motel, Inc. r/A T"lodge Carlls?e, Pa X 8YCs1[?'1 Title: 4 )l Date: Lessor: Telerent Raktiigh, North Cardlna e • met. Tltje: *enio?? ice President DaL.:September 7, 1998 Lease Number 9907-004 ADDENDUM IV LEASE ADDENDUM IV TO LEASE SCHEDULE 4 DATED JUNE 10, 1998 BY AND BETWEEN COAST TO COAST MOTEL INC. T/A TRAVELODGE, CARLISLE, PA AND TELERENT LEASING CORPORATION, RALEIGH, NORTH CAROLINA. It is mutually agreed and understood that the following items will be added to the above mentioned lease schedule: 3 - #TS510PS Power Supply There will be no change to lessee's monthly payment. All other terms and conditions remain unchanged. Lessee: Coast to Coast Motel Inc. T/A Travelodge, Carlisle, Pa By: 2 , Title: Lessor: Telerent Leasing Corporation Raleigh, NC Title: Senior Vice President Date: Date: June 17, 199S p-18-98 09:24A Frank :apano 215 '50 7715 P.01 . ADDENDUM V Lease Number 9907-004 LEASE ADDENDUM V TO LEASE SCHEDULE 4 DATED JUNE 10, 1998 BY AND BETWEEN COAST TO COAST MOTEL INC. TIA TRAVELODGE, CARLISLE, PA AND TELERENT LEASING CORPORATION, RALEIGH, NORTH CAROLINA. It Is mutually agreed and understood that 79 dooriock installations are for new pre-prepped doors and 39 doorlock installations are for exisiting metal doors. All other terms and conditions remain unchanged. LESSEE: COAST TO COAST MOTEL INC. TJA TRAVELODGE, CARLISLE, PA BY: TITLE: DATE: LESSOR: TELERENT LEASING CORPORATION RALEIGH, NC (BY: / o9-- J TITLE: Senior ice President DATE: September 25, 1998 L; 11 i t LL m L F i s` 9 y CY W • rt, Lease Number 9907-0051 LEASE SCHEDULE 5 Data: ,lane 10, 1998 Lessor: TELERENT LEASING CORPORATION 4191 Fayetteville Road Raleigh, NC 27603 Telephone (919) 7726604 FAX (919) 662.7075 FREIGHT, (IMnal Ony X P"'m _ Con, INSTALLATION: rlanel Onnl P, While nr l.na. eC OYLa,,. INSURANCE[ 0d".1 One) P,.W,d by letter % MoMed be le+rta SERVICE: (lnntl need RmHeday Lawn K ramose er lnt•ee LESSEE: Const To Coast Motel, Inc. Add,ote: 1252 Harrisburg Pike Carlisle PA 17019 [. Telephone: P•, c e t. 717-243-8535 Shin TG: Travelodge Snmc As Lessee r4 Tafaphone• un [ Y ry FAX: I TERM. 60 MONTHS wl wnwmau el. ,th,a PIy.w. $700.00 At. lute llna NE lenn n MI M pramlw W 4m•, r .nyr u uW IO• to M PER MONTH 4 Scotsman OCME256WE-IA water-cooled either if Scotsman RCD200E-16 dispensers 4 RSSIII water filter 4 Installations ADVANCEPAYMENT. LesseeteMUmA IN InI NnI}I DermeMSb Nr•rxs Mlne emnnl olS 676.00 la•tt ScheaN ,H[LMba•PPRAM•uNS I..,•u tmE+Idn M•Daarn MVU. e IF INSTAL4YION 19 PIgSORM[n EY V W OOq OR L[990p IIUmN MNnMIM MYMS+ all laed Mrl malerl[N to male Mal [dnMMl to u1Mla• wX11N +M1 19) MN el M• InE. let. IM lOsee'a retry Sib""In Drwod•NryMewater, ar.M,ape ele<nGYas.1. rurall6b ape,eel uJS1a umma 1 Inslatl6n most mul all[M[NW!r mwNt SIRE MNa+aNke m•eMI In;A..d.ealna MaarX1. ImIaONUn aeet Mllnc•Me rdrlne•M MnnMtp Me+eN•Mrtmde[maen+a elealxaN Mdpn erelnelM DenelralMn Ne1mtl Y1NWI1wl EOes nM lYAga Ent M"M PerrM+. ncenset, At Moser "V0 Feet. avc,1-. MM, mr NM. male,W [mq la cane,l of wale( p•H d eear4al Wallet eve. Mad m 16) feet lydn Me mt. oral gneth.11m p nllaealm PI laal In[tt rand IaiN t ncm .''P...I Cwle IemM1emenlt III back Hey Fevenlerl, sellgelanl venlt go Mul, elC I. dnPU+al n lemwal npn the Neml+eL M Me eQWPMnI w1r, "cw.E SERVICE Alln COMPONENTS NOS COVERCO GY MANIIFACTIIRE'9 WARRRIITY: 11,.-11-.. aq,. rx 0her Memh mChrvees are rape cmmrcE try Me WMCeet, P/O d Mbn crags Ina [mrnmem MAne n nlhel daT.Nle letunne nMn NI re.-W Para a waMnuWrN "..e m the .. ..1.- In Nr Retm Inl npmMe ma padll0 baygM me IPenM IML Iel n Irre tenon nmh1a.11IrNYVe br rkyl.vxl nrenlJVr at let Wn at I'll 1"..... IEI IntMM1llml rant n -e- Mil lose lervve mynel LESSEE, Con St To Con5L 110 tC I, InC. LESSOR, TELERENT LEASING CORPORATION CplMydtnn. PiEnmtniPMaNnep ,1.?? 17 Jl!// ??JJ IIY U"' li/,111A. r, lof, e, etEr tCr,,S SenRjVxePletb?- -J9vr7 Aultpnl SecmlAry C WJ. 11 inn-P7? Jr. Iln _ a3Ll -afr-F(, CO LESSEE. Iln rgnrRk Price (Type ed Prlnl Hamel ?S,rnej Last! l ar_ abitra- -me _Nr_Ii1- ill )-o)s oN Sble rap Aug-31-9S 01:53P Franl :apano 215 50 7715 P.01 ADDENDUM41r Lease Number 9907-005 ADDENDUM.Fll'TO MASTER LEASE DATED JUNE 10, 1998 BY AND BETWEEN COAST TO COAST MOTEL, INC. TIA TRAVELODGE, CARLISLE, PA AND TELERENT, RALEIGH, NORTH CAROLINA. It is mutually agreed and understood that the following shall be co-lessees on Lease Schedule 1 (FF&E), Lease Schedule 2 (Televisions), Lease Schedule 3 (Air Condltlooers), Lease schedule 9 (DoortocM), Lease Schedule 5 (ice MadrNxs), Lease Schedule 6 (Installation), Lease schedule 7 (TMrd Party Signage), and Lem Schedkie 8 (Washer and Dryer). AN other terms and condttions remaln unctonged. X" x .1 P Lessee: Coast to Coast Motel, Inc. T1A Travelodge Carlisle Pa I X BYCaG Title: I U Data; ???g ar . Ile Lessor: Telerent Raleigh, North Carolina Date: c7 F- _m x I.CGHC tit, mher 9 901-uu0 LEASE SCHEDULE 6 Date: June 10, 1998 Coast TO Const Motcl, Inc. LESSEE: Lessor: TELERENT LEASING CORPORATION 1292 Iinrrishurg Pike e]s: dd r A 17017 4191 Fayetteville Road Carlisle PA rr Raleigh, NC 21603 .7075 772.6604 FAX(919)662 9 [„ rr• [`"" ) Telephone (91 717-247-8579 7elaphane• Travelodgc FREIGHT, PnnN mn Ship To: Snmc ns Lessee _ rmP•M ?? f.Mne' xr• err q IN]t1LlAt1GN1 hxn•IGnsl C Telephone: nrveMn ?_ nr Laolp FAX: K nYIM•n 60 MONTHS M INSURANCE, hxnal Onnl TER . - _ •nid d [ha 1•ml •hae enpm M In• n•le d mx C.10 t. e' M•a •d L•,+U.+•H dM. It t ts••almp• n rlo-mea Mlend M EenbMml]x•,eenw, nnl ptnmm• _ [Mnmen NtMRM 1 Ip,ld T•NI•nl. _ rlmNen MlM•ee $1020.00 PER MOWN R[NT PIITMENTS. Rmetl Onel SERVICLI 1. T.Irw .1 R 5 muol A. 1•nMl Id Ne [Rdpmenl, Luue an• PN 81• Shc•nuND + •PP? t 1 r,e uen M le+w .0 NH elMh C•lea•. dmbe Ihs 1.R lean a +pl IMh M r,e.Hnn nr,nn.. _ R.RUat.d G.ux•a Gaa ry1Mn.Mt[ lltt<Cr fe.•VMIMI,x EQUIPMENT, INSTALLATION OF THE FOLLOWING: 118 televisions 77 credenzas 20 armOires 159 headboards 177 nightstands 97 mirrors 77 tnhics 20 desks 18 luggngc I'C"CheS 194 chairs 61 all mounted lights 189 Lamps 97 drapes 291 all nrL 1+410 lin yds ball covering 3800 s <Is car ec ,+xnnaq•PPtC•ela uN+IV.n pratlebn obPNe°n p1m0 2162 AovANQE PAYMEW.ta+n mat mmt melw,.epl P•rmenn rl•m•neexme •meRnd] .40 I.I.I. Slnend• e, Cnns[ To fnnst NOLCI, I.nr.. Lesse ?I?nn nl rmPnmmn. ra?mmsuipn Onnell Ily 3- 15ys78z RI 1'LERENT LEASING CORPORATION i R?-? ? rpnl IVKe I•IatMltnl AlleM ??' 1a1alanl5e e e ry co Lessea._._-Iin rgprS?P? nl Ilnme) ITYM d PdN ?M Ann,.JJ ./c2 1a llc?cr_i '.•- ?c?Lr1? (?o_ (iar li Slr ----- nn Coy tle ADDENDUM,B"= Lease Number 9907-006 LEASE ADDENDUMjrTO LEASE AGREEMENT DATED JUNE 10, 1998 BY AND BETWEEN COAST TO COAST MOTEL, INC. T/A TRAVELODGE HOTEL, CARLISLE, PA AND TELERENT LEASING CORPORATION, RALEIGH, NORTH CAROLINA. It is mutually agreed and understood that the payment term as described on Lease Schedule 6 will be reduced to 36 months and as a result the payment will be changed to $1,700.00 per month, plus tax. All other terms and conditions remain unchanged. LESSEE: COAST TO COAST MOTEL INC. T/A TRAVELODGE, CARLISE, PA DATE: LESSOR: TELERENT LEASING CORPORATION RALEIGH, NORTH CAROLINA BY: TITLE: Senio ice President DATE: 7/9/98 v*311111111 Aug-31-98 01:53P Fr•ani :apana ADDENOUMYf X ?f X X ADDENDUM'P?K/O MASTER LEASE DATED JUNE 10, 1998 BY AND BETWEEN COAST TO COAS"r MOTEL, INC. T/A TRAVELODa, CARLISLE, PA AND TELERENT, RALEIGH, NORTH CAROLINA. P.01 Lease Number 9907-006 it is mutually agreed and understood that the fclCwing shall be CO-lessees on Lease Schedule 1 (FFBE), Lease Schedule 2 (Televisfons), Lease Schedule 3 (Air Conditioners), Lease Schedule 9 (Dooriocks), Lease Sdx%dute 5 (Ice Machnes), Lease Scheduk 6 (Installation), Lease Schedule 7 (Thud Party Slgnage), and Luse Sthedkile 8 (Washer and Dryer). AN other terms and conditions remain unchanged. Lessee: Coast to Coast Motel, Inc. 17A TMvelodge Carlisle, Pa t?vfr.lD X Lessor: Telerent R8lalgh, North Carolina TRIO: SenIor t pG oct /r Date; Date: Sentember 07, 1445 I I a- .. - - --_ 215 iO 7715 William Price III r P ADDENDUM III LEASE ADDENDUM III TO LEASE SCHEDULE 6 DATED ]UNE 10, 1998 BY AND BETWEEN COAST TO COAST MOTEL, INC. T/A TRAVELOOGE, CARLISLE, PA AND TELERENT LEASING CORPORATION, RALEIGH, NORTH CAROLINA. it is mutually agreed and understood that the following Items will be added to above mentioned lease: The following is to be Installed: additional wall vinyl additional hallway carpet additional carpet base - carpet transition strips - floor patch for carpet - assembly of casegoods - showerrods - bathroom vinyl base - HVAC trimming - Install stairwell carpeting As a result lessee's monthly payment will be Incrased by an additional Q344sM per month, plus tau. All o&Aw terms and conditions remain unchans*. Coast to Coast Motu, Inc. T/A Trweeiodge, Pa F. W42 III 'Y wpw R?rmr. LCggpr Telerent Rafth, North Caroifia Co?.awee: Le sor: Teleren[ ti, Vor=a Carolina Bv: / IiLCle: Vice President Date: `:ovenbe: 23, 1995 7 r m x x w S. i 11 1 w ' Lease Number 9907-008 LEASE SCHEDULE R Dala: AUGUST 24, 1990 Lessor: TELERENT LEASING CORPORATION 4191 Fayollavllia Road Raleigh, NC 27687 Telephone 1919) 7728604 FAX (919) 662.7075 IRe1011T, PnnnlMq _L Pleretl fnneM INSTALLATtorn llnha Mel Ay Vella x nr L..... Ayleva INSURANCEI p.htl end Mwtlee ey boa Sf Prortled by blue SERVICE, fee., Mel _ P,hee.dMb..a % MwtleebrLwln EOUIPMENTI 9-1-90 1- GENERAL ELECTRIC 4114CC132050 COIN OPERATED WASHER 1- GENERAL ELECTRIC ifDDC4500 COIN OPERATED GAS DRYER 2- GENERAL ELECTRIC 0VERTR COIN SAUTE AOVANCEPAYMENT. leuee+M.lame the lest 1" 121 peymen,, hedrenu MMe enveml M S 106. 00 Leaf. 51hedu1 ,MLMnq eCDllbMe ulMMr,uermeeMbeppwstbmh usseel COAST'??'0 COAST FIOT Ei. INC. ///?A Ir?la!'y? IC elmn, P.nrnenlup rx LTxnerl - NY. _LiG. I lrrn a I•nnl fume ArN Lpel ste,.w se,, .tl I. ttmne LESSEE:-CQASZTO_COAST MOTEL. IN('.. Address: 1252 IIARRISOURG PIKE -cnrsr7srr.-rA-r?o'13 c r ?nr c...r u Telbphena:-?7 243 F1535 Ship To: TRAVELODGE SAME INS bESSRE pp un. c..er b Telephone' FAX: TERM, 60 MONTHS EM IN ? bo.w) on p.o pe ..gym . xghe ml1111e by.MV• b Let..., MW eo. 1 d M tm" MneEMwf upon UrPn+I0 TebreM. R ENT PAYM ENT11 % 50.00 PER MONTH •e renl.l la Ne EPlpn.nl, Letlu ehe@ PAY Ne .M ewz7t le 7.51".I flMgh r1awA CemMA p..N he M Nrm a eel Ia by NI. bne SeAe , Nlg eppe bS LESSOR TELERENT LEASING CORPORATION nr _ t?m We rn+xlem Alln]I Kl r??,_ .Q AS+nMnt Sevm." CntesseE,_t'1ARGARET PRICE _ITrpla rnM rM!eor AhUnv .,_ ? _ I:nr iln n! )r1 .,aiAl SeflneV it. YAhmS -58 01:SSP Fran :apana w ADDENDUM 131 21° 50 7716 Lease Number 9907-008 ADDENDUM III TO MASTER LEASE DATED JUNE 10, 1998 BY AND BETWEEN COAST TO COAST MOTEL, INC. T/A TRAVELODGE, CARLISLE, PA AND TELERENT, RALEIGH, NORTH CAROLINA. It is mutually agreed and understood that the following shall be co-lessees on Lease Schedule 1 (FFBE), Lease Schedule 2 (Televisions), Lease Schedule 3 (Air Condlooners), Lease Schedule 9 (Doorlocks), Lease Schedules 5 (Ice Machlnes), Lease Schedule 6 (Installation), Lease Schedule 7 (third Party %nage), and Lease SchedUe 8 (Washer and Dryer). AY other terms and conditions remain unchanged. x ZLwli-lav William Price III r P Lessee: Coast to Coast Motel, Inc. r/A Trevelodge Carlisle, Pa , f X 7( Title: . 11 Lessor: Telerent Ra4gh, North Carolina P.O1 3 4?w91 1- Date; L - __ Date: E -a ET m C) ? J ?J I._ c - c U v; ; f_•C_'1 G !_'i J LLI Lr ; Li 7 ?l V ?. BROWN & CONNERY, LLP Stephanie E. Nolan Attorney I.D. # 80770 1500 Market Street 12°i Floor, East Tower Centre Square Philadelphia, PA 19102 TELERENT LEASING CORPORATION Plaintiff, VS. COAST TO COAST MOTEL, INC. T/A/ TRAVELODGE, WILLIAM F. PRICE, III, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA PRICE, and JANE LUNSFORD, Attorneys for Plaintiff, Telerent Leasing Corp. COURT OF COMMON PLEAS CUMBERLAND COUNTY December Term, 1999 No. q / - 73 L/7 Civil Action ENTRY OF APPEARANCE TO THE PROTHONOTARY: I roily enter my appearance on behalf of the plaintiff, Telerent Leasing Corporation, with respect to the above-captioned matter. BROWN & CONNERY, LLP Attorneys for the Plabli ff BROWN ,4' CONNF.NY, W"Imonl, NJ 08108 y.. Dated: December 3, 1999 B?/ t Thanie E. Nolan Lr c- i : -::_ C' U ti TELERENT LEASING CORPORATION, Plaintiff, V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-7347 CIVIL COAST TO COAST MOTEL, INC. t/a : CIVIL ACTION-LAW TRAVELODGE, WILLIAM F. PRICE, III, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA PRICE, and JANE LUNSFORD, : JURY OF TWELVE (12) DEMANDED Defendants. PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of all defendants in the above-captioned matter. Respectfully submitted, ,O'BRIEN, BARK TER David A. Baric, Esquire /Z11 7 I.D.9 44853 Date: 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Defendants CERTIFICATE OF SERVICE I hereby certify that on December 2 , 1999, I, David A. Baric, Esquire, of O'Brien, Baric & Scherer, did serve the Praecipe for Entry of Appearance, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Stephanie E. Nolan, Esquire Brown & Connery, LLP 1500 Market Street 12th Floor, East Tower Centre Square Philadelphia, Pennsylvania 19102 David A. Baric, Esquire TELERENT LEASING CORPORATION, Plaintiff, V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-7347 CIVIL COAST TO COAST MOTEL, INC. t/a : CIVIL ACTION-LAW TRAVELODGE, WILLIAM F. PRICE, III, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA PRICE, and JANE LUNSFORD, : JURY OF TWELVE (12) DEMANDED Defendants. PRELIMINARY OBJECTIONS OF DEFENDANTS TO PLAINTIFF'S COMPLAINT AND NOW, come defendants, by and through their attorneys, O'BRIEN, BARIC & SCHERER, and file these Preliminary Objections to the complaint of plaintiff, and, in support thereof, set forth the following: Plaintiff's complaint sets forth multiple counts sounding in breach of contract and replevin relating to certain equipment and materials allegedly supplied by plaintiff to defendants under and subject to certain lease agreements amongst the parties. 2. At paragraph 9 of the complaint, plaintiff alleges that it has appended to the complaint a copy of the "Master Lease". The Master Lease as appended to the complaint served upon the defendants, contains only a portion of an apparent "Master Lease". A copy of the redacted portion of the Master Lease as appended to the complaint is attached hereto as Exhibit 1 and is incorporated. 4. Plaintiff relies upon the Master Lease to assert that it is entitled to attorney fees and other remedies, however, the redacted portion of the Master Lease as appended to the complaint contains no reference to attorney fees and/or other remedies sought by plaintiff. 5. Certain of the materials allegedly provided by plaintiff to defendants would, by their nature, be affixed and attached to the building of the defendants. For instance, but not by way of limitation, Exhibit "B" to the complaint references carpeting, wall coverings (wallpaper), carpet padding, door locks. 6. The materials aforementioned have been incorporated into and have become a part of the building. 1. FAILURE OF COMPLAINT TO CONFORM TO LAW OR RULE OF COURT Paragraphs one through six are incorporated herein as though set forth at length. 8. Pa.R.C.P. 1019(h) requires that a party attach a copy of the writing or the material part thereof upon which a claim is based . 9. Plaintiffs complaint fails to conform to Pa.R.C.P. 1019(h) in that plaintiff has failed to attach to its complaint the provisions of the "Master Lease" upon which it bases its claim. 10. Pa.R.C.P. 1019(c) requires that conditions precedent be generally averred as having occurred. 11. Plaintiff has failed to aver generally or specifically that all conditions precedent to recovery under the contracts have occurred. 12. Plaintiff seeks, under Count Eight of its complaint, to replevy "equipment" allegedly provided pursuant to the leases appended to the complaint. 13. An action for replevin is not appropriately asserted for materials which are affixed to and which have become a part of a building. WHEREFORE, Defendants request that this preliminary objection be sustained and plaintiff be a required to file an amended complaint which conforms to law and rule of court. IT. INSUFFICIENT SPECIFICITY 14. Paragraphs one through thirteen are incorporated herein by reference as though set forth at length. 15. Plaintiffs complaint is insufficiently specific in that it has failed to append to its complaint the provisions of the Master Lease which it appears to rely upon in asserting its claims and demands. WHEREFORE, Defendants request that this preliminary objection be sustained and the plaintiff be directed to file an amended complaint which contains sufficient specificity. III. FAILURE TO JOIN AN INDISPENSABLE PARTY 16. Paragraphs one through fifteen are incorporated herein as though set forth at length. 17. The building of defendants which operates as a hotel is subject to an existing lien of mortgage in favor of Orrstown Bank, said mortgage recorded in the office of the Recorder of Deeds of Cumberland County at book , page which is incorporated herein by reference. 18. Upon information and belief, the lien of mortgage of Orrstown Bank may extend to and include materials allegedly supplied by plaintiff which have been affixed to the building. 19. To the extent plaintiff requests to replevy these materials, its interest would appear to be joint with Orrstown Bank. 20. Pa.R.C.P. 2227(a) requires parties having ajoint interest to be joined as plaintiffs or defendants. 21. Plaintiff has failed to join an indispensable party. WHEREFORE, Defendants request that this preliminary objection be sustained and plaintiff be required to file an amended complaint which joins an indispensable party. IV. IMMUNITY OR EXEMPTION OF PROPERTY FROM REPLEVIN 22. Paragraphs one through twenty-one are incorporated herein by reference. 23. The materials which have become affixed to and incorporated into the building of the defendants are exempt from replevin. WHEREFORE, Defendants request that plaintiffs complaint be amended to exempt from replevin those materials which have been affixed to and incorporated into the building of defendants. Respectfully submitted, O'BRIEN, BARK & SC R A4 David A. Baric, Esquire ID #44853 17 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Defendants dab.d i r/litigation/coast/p rcli minary.ob j i 1 i I• ' I VERIFICATION I verify that the statements made in the foregoing Preliminary Objections of Defendants To Plaintiffs Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. A,44 ! David A. Baric, Esquire DATED: ?Z Z c/ 4trATE OF NORTH CAROLINA COUNTY OF WAKE Lease Number,9907, MASTER LEASE AGREEMENT LESSOR: TELERENT LEASING CORPORATION 4191 Fayetteville Road Raleigh, Wake County, NC 27603 Telephone (919) 772.8604 FAX (919) 662-7012 Date: June 10, 1998 This MASTER LEASE AGREEMENT Is made me Misted into as Is the dale fast written above by and between the herein named Lessee and Lessor. Lessor hereby bases to Lessee, and Lessee hereby loans hoes Lessee, the number and type of equipment SPeC11ed In the Lease SdWdUbs aff&dW handle and mads pad heed (selectively, the 'Equipment'), upon me conditions lit forth hmain and in the Lane Schedules. 1. LEASING COMMITMENTS. From sans to time while this Agreement Is In effect, Lessee may wend a lease proposal for equipment to Lassee for its comdanllon. Lessor shall than di armMe, in its soh, dsaellun, whether or not to acwpl Lessee's proposal and loan such equipment In accordance whh the lams and conditions of MIS Agreemant and an aPpdeble Lease Schedule. Nothing in this Agreement Shan be deemed a ram adds or "Paw commitment by Lessor n" a commended by Lessor to lease equipment said such INm as a Lean Schedule Is accepted and executed by Lessor. 2. TERM. Subject to Lassoes right to terminate this Agreement upon Lessee's dafauh, the term of this Agreement shall be fa a period ending upon the Iwminaton a axpkollen dale of the east effedhro Lease Schedule to this Lease Agreement. 3. RENT PAYMENTS. As rental for Me Equpnanl, Lessee shad pay to Lassoes address "l out above, fee the respedlve pariods Set form in the Lease Schedules herein, without deduction or snW. the rant payments specified In the Lease Schedules, plus applicable Sales and use twos. Rent payments man be due on or before me fail day of the month. the deal Such payment to be due an or before the tint day of the month following Installation of the Equipment for dalnary d Lessor is not rssponnbse for Installation hereunder). Cardamom with the axeation of each Lease Schedule hereto, Lessee shall remit Io Lessor those advance Palmate, lit lath in such respadlve Lasso schedule. N the "ant of partial delivery "or Installation of the Equipment. Lessee shall pay monthly an an Interim basis pro red move of the rent set wt in me applicable Lease Schedule 1" such Equipment based upon me mathematirat proportion that me Equipment delivered andr" installed bean to the total Equipment described in the applicable Lease Schedule, and the Lasso term applicable to such Equipment mad pemanence and the real Wg rnW payment shag be due on the fart day of me month following the ccmplallod of full delivery, and/or installation. Tine Is of the essence. If any payment due under this Agreement Is not received by Lesser on the date If Is due. Lessee shad pay to Lass" (a) the overdue payment heed: and (b) Mend an the ovmdue payment Rom the date due to me dale me payment is received at Use role of alghleen percent (15%) Per annum or, it loss, the highest rate PermmW by Law, in addition. Iota charges may be asnssad to me muvnum WAS allowed by law. Payments recolved from Lessee shad be applied free to unpaid interest, at Lessees option, and then to the past due tent payments upon whlth such interest has awned. This Agreement cannot be canceled or terminated except as expressly provided herein. This Agreement Shan be a net lease, and Lessee's obligation to pay OR ram and other sumo when due and to otherwise part= as required under this Agreement shag be absolute. unWndsbnal, Irrevocable and inoeprdenl, and shag not be Subject W any abwemenl, reduction, set-off, defense, counter clam, interruption or rscoupnenL fat my reason whatsoever. If any Equipment Is unsatisfactory for any reason, Losses shad make any clam solely against me manuscorar or fuppeer of me Equipment end shad nevertheless, pay Lassa, No successors a assigns all amounts due and payable haraea. This Agreement is subject to a Prepayment penalty. 4. DELIVERY, INSTALLATION, INSPECTION AND ACCEPTANCE. Lessor or $s agent abed deliver the Equipment at promises owned, leased or lawfully operated by Lessee and s,-r.,, + ,r .,wa...,,..r,.d v, new raawrsiva tea" Srhadule aool"Isle thereto EXHIBIT 1 Coast To Coast Hotel, Inc. 1252 Harrisburg Pike Carlisle PA 17013 Ca na. w,.a, ad Telephone: 717-243-8535 Ship To: Travelodge Same as Lessee c„ Cara, Te FAX: 717-243-9711 Upon lender of delivery. Lessee mall veiny mat Na Equipment conforms se any applirabla Lease Schedule. Lessee mall inspect the Equipment and. d the Equipment Is In good cedar. Lessee shall accept delivery and execuls a Coruscate of Acceptance in the farm provided by Lasser caddying me delivery. Impactors and acceptance of the Equipment by Lessee. Lessee shall variy, count and note any Shortages. or visible damages on all copses of the delivery recalPL Ail Canons should be opened and Inspected for concealed damage. If any damage Is noted that mould have been found at dalnery, the Win wit be denied. Retch danuged awns at the point where taceNed along with all containers and packing msteral mid an inspection s made by curler. Contact the height Carter to request an inspection wimp 48 boon of dalnary of any damaged freight. Allow the Inspect" to inspect damaged rams, Words. packing materials and (might lea. Do not sign the Wpexloes report a any sntemens we dspuled. Unless lopais will be aslisfactory, ensure that Impeder requests replacement an the report. No new pens wed be ordered unless the repM specdss'topscemwL' Send via cadined mail, (alum receipt requested With contact name, hotel name, address sad telephone number. Consul items cannot be used or disposed of wNwul permission from the carrier and winners ftevebation from Lessor. ASSIGNMENT. Luna mall not sublease. land, sell, assign, transfer (by opentlor of law or otherwise) of grant a security Interest In all or any pan of Its Interest In the Equipment or this Agrumenl without the prior express written consent of Lessor Lessee may land, sag, assign. unit" or grant a sunnily Interest in ad or pad of Its rights abligatlens, Idle a Interest n me Equipment or this Agreement, "my amounts payable under this Agreement, whoa nice to Lessee. Lessee hereby cansarm to way sac uansaobn, and acknowlodges that any Such bwssactlon Shad red mstmially inpal Lessee's prospect of obtaining (atum perfomsnce by Lester. materially chenga Lessee'! duties or obligations uadw ms Agreement, nor tralmlaly Increase Lsesse's risk's o burdens under this Agreement. Lessee further agrees that Lass" may assigns in bansfe Lassoes interest in the Equipment udror this Agroement even d such assignment c transfer could be deemed to Materially affect the Interests or the Lessee. SECURITY INTEREST. Lessee hereby grans to Less" a first pncray searty intense . m6 Ag:ear..e:fL the Equipment and in all accefsorn to, replacamenb of Nd poceed frees the Equipment (wMout me power of Losses to evensfer this Agreement or th Equipment) to sawed me prompt payment and periwmanea of Loom's Indeblednas and obligations under ms Agreement. The parlles Intend and agree that the EgUIPmer shad romIn personal popery, notwithstanding the manner in watch k is amaed to an real property. Al Lessees request, Lessee shag clients and deliver to Lessee waivers e any mortgage, ban, anambrance or Interest with (aspect to the equipment. Lease agrees to maintain the Equipment free item 81 Wins, ens and loped Processes l aeditaa and daknans of Lessee. Lessee will defend Lessees interest In the Equlpmm 777 SHERIFF'S RETURN - REGULAR CASE NO: 1999-07347 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TELERENT LEASING CORP VS. COAST TO COAST MOTEL INC ET AL KATHY CLARKE , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE & COMPLAINT was served upon COAST TO COAST MOTEL INC T/A TRAVELODGE the defendant, at 9:10 HOURS, on the 9th day of December 1999 at 1252 HARRISBURG PIKE CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to WILLIAM PRICE, III (OWNER) a true and attested copy of the NOTICE & COMPLAINT and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 3.10 . Affidavit .00 Surcharge 8.00 omas ine, er.I $29.10 NNERY ROWN & C B 9 by La"6i, epu y 5 eri-- Sworn and subscribed to before me this 3C 't day of 19gey A. D. ror-nonocarv, SHERIFF'S RETURN - REGULAR CASE NO: 1999-07347 P COUNTYWOFLCUMBERPLANDSYLVANIA: TELERENT LEASING CORP VS. COAST TO COAST MOTEL INC ET AL KATHY CLARKE , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE & COMPLAINT was served the upon PRICE WILLIAM JR defendant, at 9:10 HOURS, on the 9th day of December 1999 at 1252 HARRISBURG PIKE CUMBERLAND, CARLISLE, PA 17013 County, Pennsylvania, by handing to WILLIAM PRICE, III a true and attested copy of the NOTICE & COMPLAINT and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answ:9:? Docketing 6;00 ll Service 00 Affidavit 8 00 kt. omas 2i?n ri Surcharge •. .._....._ ..... . p'0-.U by_ ,/Le --? - ep? y erifl Sworn and subscribed to before me this 3of day of? 4- 199C_ A.D. l 1 w n 11n tQ w "Q+o'4 ' r ono ? r SHERIFF'S RETURN - REGULAR CASE NO: 1999-07347 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TELERENT LEASING CORP VS. COAST TO COAST MOTEL INC ET AL KATHY CLARKE , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE & COMPLAINT was served upon PRICE MARGARET the defendant, at 9:10 HOURS, on the 9th day of December 1999 at 1252 HARRISBURG PIKE CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to WILLIAM PRICE, III a true and attested copy of the NOTICE & COMPLAINT and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing G.OO Affidavit .00 Surcharge 8.00 omas ine, eri $T4?QO-B2/14/1990NNERY by u y eri Sworn and subscribed to before me this u-t-' day of hQe??w Qf* 1991 A. D. rocnonotar SHERIFF'S RETURN - REGULAR CASE NO: 1999-07347 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TELERENT LEASING CORP VS. COAST TO COAST MOTEL INC ET AL KATHY CLARKE , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE & COMPLAINT was served upon PRICE WILLIAM F III the defendant, at 9:10 HOURS, on the 9th day of December 1999 at 310 HICKORY ROAD CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to WILLIAM PRICE III a true and attested copy of the NOTICE & COMPLAINT and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing 6.00 Q? Service .00 d Affidavit .00 ??11 Surcharge 8.00 A-' omas ine,TS eri U BROWN &999NNERY by e u y eriu ty? eri Sworn and subscribed to before me this 3U t day of Qtz C ,... 19 _ A.D. Q Lc- ?Lt ceP? . hQ/- rocnonoca SHERIFF'S RETURN - REGULAR CASE NO: 1999-07347 P COMM COUNTYWOFLCUMBERLLAND YLVANIA: TELERENT LEASING CORP VS. COAST TO COAST MOTEL INC ET AL KATHY CLARKS , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according was served to law, says, the within NOTICE & COMPLAINT upon PRICE PATRICI the A defendant, at 9:10 HOURS, on the 9th day of December 1999 at 310 HICKORY ROAD CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to WILLIAM PRICE, III (HUSBAND) a true and attested copy of the NOTICE & COMPLAINT and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answer Docketing 6.00 Service .00 Affidavit .00 Surcharge 5.00 omas ine, eri B1ROWN &999NNERY by e y eri Sworn and subscribed to before me this It) 1? day of ?? . 19Q_ A.D. ro ono ary I .1 SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 1999-07347 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TELERENT LEASING CORP VS. COAST TO COAST MOTEL INC ET AL R. Thomas Kline , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, served the within named DEFENDANT, LUNSFORD JANE by United States Certified mail postage prepaid, on the 8th day of December 1999 , at 8:00 HOURS, at 971 MT PLEASANT ROAD WOODBINE, NJ 08270 a true and attested copy of the attached NOTICE & COMPLAINT The returned receipt card was signed by JOHN T. LUNSFORD, JR on 12/10/1999. Sheriff's Costs: So answ s: Docketing .00 Service 7.79r/`f`? Affidavit .00 Surcharge 8.00 omas K1in 5 eri -BROWN &999NNERY 12/14/1 Sworn and ?subscribed this 30 day of AO ,to'tibZefore me - rotnonocar ( 1 r r i I ?y ' 1 i? 9- ,?1L } . m SENDER * Complete llam30%. 2 loradditional services. H •COmplela , de, anoab. ll- me 3 I y • Print your name d IaISO Wish to rBCBIVe the •Z an i cam to yYou. services (tor an etltlross on the reverse of this loon sa that wo wn (Dturn this e • At llo f ' tach Ih'a loon to the front of the mailpiece, or on the back If space does net ` pormn. • nta 'Return ROreipr RO ' x ee) 1. ? Addressee's Add ? Z quosfoU on thQ mailpiece • The Rolurn necolpl will show to whom tallow the artloo tlolrvacedoratl. the number. art,clo was delivered and the bar. ress 2. ? Resld Cled Delivery ' e 3, gnicle Addressed to: Consult postmaster for lee . ?d Article Number .2- R Jane Lunsford E 9 d M r } 4 71 Mt. Pleasant Roe Woodbine, Na 08270 NJ yo E ' - Ex \ a YW Cenilied all ? O ' 1 k% Q Q Relu Insured ceipt for Merchandise ?COD 1 , f O 7. D S. Received By: (print Na o Delivery X33 Q 3 ~ ' i ,, e) CV 8. A sae's Adtlress (Onlyi/requested o m 6. Stgnat re: (Address a orAyenr S a is paid) I l .. X ` =' PS Form 3811, December 1994 u y t.^' - _ v y_` 1089S91113g22e Domestic Return Receipt i ! ?. - A i r _. I =PoFot UNITED ST ATES POSTAL SERVICE G 10 I • P •nt our name address, and ZIP Code in this box • 9 1 a: I tr?t i i I rl I I '>< I I ? R. *nwinas .Cline, Sheriff { County oe` Cumberland I Court House Carlisle, PA 17013 I I ? I d I Irrrnlrrrulmr„a,.nnnnur,rl,lrrnrrrur„rrrulnrll ,? .y' t r E I i 1 t ROWN & CONNERY, LLP ephanie E. Nolan ttorney I.D. # 80770 500 Market Street 2"' Floor, East Tower entre Square hiladelphia, PA 19102 TELERENT LEASING CORPORATION Plaintiff, VS. Attorneys for Plaintiff, Telerent Leasing Corp. COURT OF COMMON PLEAS CUMBERLAND COUNTY December Term 1999 No. 99-7347 COAST TO COAST MOTEL, INC. Civil Action T/A/ TRAVELODGE, WILLIAM F. PRICE, III, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA PRICE, and JANE LUNSFORD, ORDER OF THE COURT AND NOW, this 19 day of January, 2000, IT IS ORDERED that the previous Order the Court in this matter entered on January 10, 2000, it hereby VACATED, and IT IS ORDERED that a hearing on the within motion to seize equipment shall be conducted Courtroom Number 2, Cumberland County Courthouse, at 1:30 p.m., Wednesday, February 2000. ihanie E. Nolan, Esquire Plaintiff id A. Baric, Esquire Defendants BROWN S CONNF.RY, 1-19-00 cc . cu;Jl'v'C!5??+? caurmI '? S1i`!fu'! A PENi BROWN & CONNERY9 LLP Stephanie E. Nolan, Esquire Attorney ID N 80770 1500 Market Street 12R' Floor, East Tower Centre Square Philadelphia, PA 19102 TELERENT LEASING CORPORATION Plaintiff, VS. COAST TO COAST MOTEL, INC. T/A/ TRAVELODGE, WILLIAM F. PRICE, III, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA PRICE, AND JANE LUNSFORD, Defendants. Attorneys for Plaintiff, Telerent Lensing Corp. COURT OF COMMON PLEAS CUMBERLAND COUNTY December Term 1999 No. 99-7347 Civil Action ORDER OF THE COURT AND NOW, this to d of February, 2000, IT IS ORDERED that the previous Order of the Court in this matter entered on January 19, 2000, it hereby VACATED, and IT IS FURTHER ORDERED that a hearing on the within motion to seize equipment shall be conducted in Courtroom Number 2, Cumberland County Courthouse, at 2:00 p.m., Wednesday, March 1, 2000. Stephanie E. Nolan, Esquire For Plaint?1j, David A. Baric, Esquire For Defendants RKS BROWN & d-/y-00 .. .? li: ..iili:l;g _; BROWN & CONNERY, LLP Stephanie E. Nolan, Esquire Attorney ID N 80770 1500 Market Street 12"' Floor, East Tower Centre Square Philadelphia, PA 19102 TELERENT LEASING CORPORATION Plaintiff, VS. COAST TO COAST MOTEL, INC. T/A/ TRAVELODGE, WILLIAM F. PRICE, III, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA PRICE, AND JANE LUNSFORD, ORDER OF THE COURT Civil Action AND NOW, this day of March, 2000, IT IS ORDERED that the previous Order of the Court in this matter entered on February 10, 2000, it hereby VACATED, and IT IS FURTHER ORDERED that a hearing on the within motion to seize equipment shall be conducted in Courtroom Number 2, Cumberland County Courthouse, at 1:30 p.m., Wednesday, April 19, 2000. BY TFIE Stephanie E. Nolan, Esquire For Plaintiff David A. Baric, Esquire For Deferrdcrn(s Atronzeys for Plaintiff, Teleren! Leasing Corp. COURT OF COMMON PLEAS CUMBERLAND COUNTY December Term 1999 No. 99-7347 ,3-3-do RKS BROWN & CoNNERY, a B? BROWN & CONNERY, LLP Stephanie E. Nolan, Esquire Attorney ID # 80770 1500 Market Street 12'h Floor, East Tower Ccntre Square Philadelphia, PA 19102 TELERENT LEASING CORPORATION Plaintiff, VS. COAST TO COAST MOTEL, INC. T/A/ TRAVELODGE, WILLIAM F. PRICE, 111, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA PRICE, AND JANE LUNSFORD, Defendants. Altonreps for Plaintiff, Teierent Leasing Corp. COURT OF COMMON PLEAS CUMBERLAND COUNTY December Term 1999 No. 99-7347 Civil Action ORDER OF THE COURT AND NOW, this "710 day of April, 2000, IT IS ORDERED that the previous Order of the Courtin this matter entered on March 3, 2000, it hereby VACATED, and IT IS FURTHER ORDERED that this matter will be continued generally and can be placed on the nR01M & calendar again at the request of any party. Stephanie E. Nolan, Esquire For Plaintiff David A. Baric, Esquire For Defendant f. r BROWN & CONNERY, LLP Stephanie E. Nolan, Esquire Attorney ID # 80770 1500 Markel Street 121 Floor, East Tower Centre Square Philadelphia, PA 19102 TELERENT LEASING CORPORATION Attorneys for Plaintiff, Telerent Leasing Corp. COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, VS. COAST TO COAST MOTEL, INC. TIM TRAVELODGE, WILLIAM F. PRICE, 111, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA PRICE, AND JANE LUNSFORD, December Term 1999 No. 99-7347 Civil Action Defendants. ORDER OF THE COURT AND NOW, this Z'o day of June, 2000, IT IS ORDERED that the previous Order of the Court in this matter entered on April 20, 2000, it hereby VACATED, and IT IS FURTHER ORDERED that a hearing on the within motion to seize equipment shall be conducted in Courtroom Number 2, Cumberland County Courthouse, at 1:30 p.m., Thursday, June 29, 2000. Stephanie E. Nolan, Esquire For Plaintiff Plaintiff /"f L-21-oa / David A. Baric, Esquire For Defendants RICO /,t„,,;, t -t/..(tJJ. ?. .: .. ?.?___ _,., t., a? TELERENT LEASING CORPORATION, PLAINTIFF V. COAST TO COST MOTEL, INC. T/A TRAVELODGE, WILLIAM F. PRICE, III, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA PRICE AND JANE LUNSFORD, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-7347 CIVIL TERM ORDER OF COURT AND NOW, this 1 10 day of January, 2000, IT IS ORDERED that a hearing on the within motion to seize equipment shall be conducted in Courtroom Number 2, Cumberland County Courthouse, at 1:30 p.m., Thursday, January 27, 2000. By the Court, B. Stephanie E. Nolan, Esquire For Plaintiff David A. Baric, Esquire For Defendants RK? :saa C?; rv U y of rG?U?tiU ? , NSyZVa.?W???IY ROWN & CONNERYi LLP :ephanie E. Nolan ttorney LD. # 80770 500 Market Street 2" Floor, East Tower entre Square hiladelphta, PA 19102 TELERENT LEASING CORPORATION Plaintiff, JAN - 7 Attorneys for Plaintiff, Telerent Leasing Corp. VS. COAST TO COAST MOTEL, INC. T/A/ TRAVELODGE, WILLIAM F. PRICE, III, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA PRICE, and JANE LUNSFORD, ORDW FOR ISSUANCE OF WRIT OF SEIZURE THIS MATTER being opened to the court by Brown & Connery, LLP, attorneys for f, Telerent Leasing Corporation, on motion for seizure of property, and the Court determined that the plaintiff, Telerent Leasing Corporation, is entitled to the lion of the Equipment described in the Complaint and supporting papers; and it further ing from the certifications filed herewith that demand in writing for the delivery of sion of such Equipment has been duly served upon Defendants and that Defendants failed to make delivery; IT IS on this day of 2000, ORDERED that the Plaintiff entitled to possession of the Equipment and IT IS FURTHER ORDERED that a Writ of Seizure shall issue out of this Court commanding the leriff of Cumberland County to seize the Equipment described in Plaintiffs complaint. COURT OF COMMON PLEAS CUMBERLAND COUNTY December Term 1999 No. 99-7347 Civil Action BROWN & CONNF.RY, W"'."t, NJ RRIR8 Order shall be served upon the following parties: David A. Baric, Esquire O'Brien Baric and Scherer 7 West South Street Carlisle, PA 17013 tttorney for all Defendants BROWN & CONNr.RY, W.Imom, NJ OR ION )WN & CONNERY9 LLP hanie E. Nolan rney I.D. N 80770 Market Street Floor, East Tower PA 19102 Attorneys for Plaintiff, Telerent Leasing Corporation TELERENT LEASING COURT OF COMMON PLEAS CORPORATION CUMBERLAND COUNTY Plaintiff, December Term 1999 VS. No. 99-7347 COAST TO COAST MOTEL, INC. Civil Action T/A TRAVELODGE, WILLIAM F. PRICE, III, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA MOTION FOR PRICE, and JANE LUNSFORD, SEIZURE OF PROPERTY Plaintiff, Telerent Leasing Corporation ("Telerent"), moves the court for an order :tins the Sheriff of Cumberland County, Commonwealth of Pennsylvania, to seize and ,er the equipment described in Lease Nos. 9907-001, -002, -003, -004, -005, -006, and -008 "Equipment"), attached to Telerent's Complaint, which is attached to the notice of this to Telerent pending the final determination of this action. This motion is based on the grounds that the Defendants have failed to make timely onthly lease payments under Lease Nos. 9907-001, -002, -003, -004, -005, -006, and -008. s of November 15, 1999, the Defendants were in arrears in the following amounts: (1) 38,181.34 under the terms of the 9907-001 Lease, as amended, and the Master Lease; (2) 11,387.12 under the terms of the 9907-002 Lease, as amended, and the Master Lease; (3) 16,664.92 under the terms of the 9907-003 Lease, as amended, and the Master Lease; (4) 12,051.74 under the terms of the 9907-004 Lease, as amended, and the Master Lease; (5) 3.323.10 under the terms of the 9907-005 Lease, as amended, and the Master Lease; (6) BROWN & CONNF.RY, WnlmnnL NJ 08108 ,843.75, under the terms of the 9907-006 Lease, as amended, and the Master Lease; and (7) 0.80, under the terms of the 9907-008 Lease, as amended, undertLease aNosL9907-001, -002, - The failure to make timely monthly lease payments -004, -005, -006, and -008 is a material default under the terms of the Master Lease. The ms of the Master Lease state that when the Defendants are in default, Telerent is entitled to ver the Equipment. The Defendants are in possession of the Equipment. Telerent has demanded the return of Equipment but the Defendants refuse to return the Equipment. Defendants unjustly detain the tipment. Telerent, having determined to repossess the Equipment and being the full and qualified owner of the Equipment, is entitled to remove the Equipment in accordance with the ms of the Master Lease. The value of the Equipment and Telerent's interest in the Equipment 11 be adversely affected by the continued possession and use of the Equipment by the :fendants. Defendants or other person in possession of the Equipment may dispose, encumber, waste the Equipment or remove the Equipment from the jurisdiction of the Court. This motion is based on the records and files of this case, such supplemental affidavits r documents as may be filed, and such oral and documentary evidence as may be presented at a on this motion. December 21, 1999 BROWN & CONNERY, LLP Attorneys for Plaintiff Telerent Leasing Corporation By. 1 Step me E1 Nolan i i I1NnW%& C0N.%FRV, \VnIww' \J 0X108 )WN & CONNERY, LLP hanie E. Nolan rney I. D. !/ 80770 1 Market Street Floor, East Tower PA 19102 TELERENT LEASING CORPORATION Attorneys for Plaintiff, Telerent Leasing Corporation Plaintiff, VS. COAST TO COAST MOTEL, INC. T/A/ TRAVELODGE, WILLIAM F. PRICE, III, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA PRICE, and JANE LUNSFORD, Defendants. the Sheriff of Cumberland County: COURT OF COMMON PLEAS CUMBERLAND COUNTY December Term 1999 No. 99-7347 Civil Action WRIT OF SEIZURE You are directed to seize the property listed on Lease Nos. 9907-001, -002,-003, -004, -006, and -008, attached to Plaintiff's Complaint. If the property is found in the possession of anyone not already a defendant, you are ted to add him as a defendant, and notify him that he has been added as a defendant and is red to defend this action. of Writ Prothonotary By: Deputy BROWN & CONNr.RY, Wnlmonl. NJ ONIR8 ,.. ,? ,, 4 ?' ?• ?3! _. ? `: ' __ u _ f:.:.. ' ? C) ?.. u .. ? G:' t- -? t:_ p `'i c: v G ., _ ,. ?:' y? ??""' l JAN - 7 2000 V IROWN & CONNERY, LLP tephanie E. Nolan atorney I.D. # 80770 500 Market Street 2°i Floor, East Tower PA 19102 Attorneys for Plaintiff, Telerent Leasing Corporation TELERENT LEASING COURT OF COMMON PLEAS CORPORATION CUMBERLAND COUNTY Plaintiff, December Term 1999 VS. No. 99-7347 COAST TO COAST MOTEL, INC. T/A/ TRAVELODGE, WILLIAM F. PRICE, III, WILLIAM PRICE, JR., MARGARET PRICE, PATRICIA PRICE, and JANE LUNSFORD, Coast to Coast Motel, Inc. t/a Travelodge 1252 Harrisburg Pike Carlisle, PA 17013 William F. Price, III 310 Hickory Road Carlisle, PA 17013 Margaret Price 310 Hickory Road Carlisle, PA 17013 William Price, Jr. 1252 Harrisburg Pike Carlisle, PA 17013 Patricia Price 1252 Harrisburg Pike Carlisle, PA 17013 Jane Lunsford 971 Mt. Pleasant Road Woodbine, NJ 08270 Civil Action NOTICE OF MOTION FOR SEIZURE OF PROPERTY BROWN & CONNr.RV. %VmImmf. NJ 081118 .1 . + ''r You are hereby notified that (1) Plaintiff has commenced an action of replevin against you and has filed a motion for zure of the property described in the Complaint. A copy of the Complaint and motion is to this notice; (2) There will be a hearing on this motion on at l (3) You may appear in person or by a lawyer at the time and place set forth above or file objectibns setting forth your reasons why the property should not be seized; (4) Your failure to appear at the hearing may result in the seizure of the property I by the plaintiff before a final decision in this case. BROWN & CONNERY, LLP Attorneys for Plaintiff, Telerent Leasing Corporation December 21, 1999 By: teplt ie E. Nolan BROWN k CONNEHY, N'nlmunl. NJ IIN ION I f f i i Q r L Lx W ? e`... . _,? .., F ?.ry" For Prothonotary Use Only (Docket Number) ' Court of Common Pleas of Cumberland County Trial Division CIVIL COVER SHEET DEFENDANTS' NAME PLAINTIFF'S NAME COAST TO COAST MOTEL, INC., TIA TRAVELODGE; TELERENT LEASING CORPORATION ?WILLIAM F. PRICE, III; WILLIAM PRICE, JR.; MARGARET PRICE; 'PATRICIA PRICE; AND 6JANE LUNSFORD DEFENDANTS' ADDRESS PLAINTIFF'S ADDRESS 1252 HARRISBURG PK., CARLISLE„ PA; 4191 FAYETTE ROAD, RALEIGH, NC 27611 2310 HICKORY RD., CARLISLE, PA; 31252 HARRISBURG PK., CARLISLE, PA; 61252 HARRISBURG PK., CARLISLE, PA; 5310 HICKORY RD., CARLISLE, PA; AND 6910 Mt. Pleasant Rd., Woodbine, NJ 08270 TOTAL NO. OF TOTAL NO. OF COMMENCEMENT OF OTHER PLAINTIFFS (70) DEFENDANTS (71) ACTION 05. Arbitration 010. In Forma Pauperis 011. Transfer from Other Complaint 91 6 . 06 Jury 02. Writ of Summons Jurisdiction 1 C3. Notice of Appeal )(7, Non-Jury & Equity 012. Minors/Incompetent AMOUNT IN CONTROVERSY C4. Petition Action Compromise Survival Action 013 030. $50,000 or less More than $50.000.00 1131 . r-8. Class Action C9. Savings Actions 014. Wrongful Death . Action (inv. minors) 032. A.u..mw6 a 6,m+t.. r.amv.ww.. 033. ,.u.vnm,ormmaan M,rv,y mr e? ACCRUAL OF CAUSE OF ACTION DEFENDANT IDGORMATION sidents of (or have offices in) Cumberland County r - ]040. Action arose in Cumberland County e 150. All defendants are G11. Action did not arse in Cumberland County em, m.m r«rrro aaa,n a.n..cwnnab+..eoi J(51. Main defendant is a resident of (or has offices in) Cumbertand County 042. Transaction or occunence giving rise to action fendants regularly conduct business in Cumbedantl County (see instruction F) All d 52 arose in Cumberland County e 7] . 043. Transaction or occurrence giving rise to action did siness in Cumberland County (see instruction F) b d t not arse in Cumberland County Ia..w. u,n.xwn s u uc C 53. Main defendant regulady con aoranerc, gbwn,9o1 U 54. Defendants are not residents of (and do not have offices in) Cumberland County (state below in 960 reason for filing action In Cumberland County) 060. CODE NUMBER AND TYPE OF ACTION (See Instruction G) STATUTORY BASIS FOR CAUSE OF ACTION (See Instruction H) None PENDING ING CASES (List by Docket Number - Indicate Whether the Related Cases Have Been Consolidated) TIFF'S/APPELLANTS ATTORNEY ADDRESS (See Instruction J) * . Nolan, Esquire East Tower, Centre Square l2m Floor t Street k M , , e ar 1500 R SUPREME COURT Philadelphia, PA 19102 IDENTIFICATION #80770 DATE DECEMBER3,1999 For official use only LIST NEXT COURT ACTION 01102 Settlement Conference Arbitration .7 1101 Arbitration Hearing 1103 Hearing/Trial n 1104 Status Conference Jury _I 1105 Other Dale: PFn-Jury Non-Jury Agencyrrax __ Time: Dale: Time: ls Place: Mass Tort 5 Other BROWN & CONNERY, LLP Stephanie E. Nolan Attorney I.D. # 50770 1500 Market Street • 121h Floor. East Tower Centre Square Philadelphia, PA 19102 TELERENT LEASING CORPORATION Plaintiff, vs. COAST TO COAST MOTEL, INC. T/A/ TRAVELODGE, WILLIAM F. PRICE, III, WILLIAiM PRICE, JR_, MARGARET PRICE, PATRICIA PRICE, and JANE LUNSFORD, Defendants. Attorneys for Plaintiff, Telerent Leasing Corp. COURT OF COIXLVION PLEAS CUMBERLAND COUNTY `, r'':. -I December Term, 1999 No. q1j, 73 Y-7 c r, l Civil Acton: ENTRY OF APPEARANCE TO THE PROTHONOTARY: ICndly enter my appearance on behalf of the plaintiff, Telerent Leasing Corporation, with respect to the above-captioned matter. BROWN & CONNERY, LLP Attorneys for the Plaintiff BROWN & CONNERY, Wnlmaal, NJ 08108 Dated: December 3, 1999 By: tephanie E. Nolan 1 1 ,. . 1 BROWN & CONNERY, LLP By: Stephanie E. Nolan, Esquire Atty. I.D. #80770 15001jktarket Street I2"' Floor, East Tower Centre Square Philadelphia, PA 19102 (215)592.4352 TEL$RENT LEASING CORPORATION, Plaintiff, Vs. COASTTO COAST MOTEL, INC. 1/a. TRAVELODGE, WILLIAM F. PRICE, Ill, WILLIAM PRICE,JR., MARGARET PRICE, PATRICIA PRICE, ANDJANE LUNSFORD, Defendants. Attornrcc J r!'landi j,'Felerent Leasing Corporation COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL DIVISION DECEMBERTERM, 1999 NO. NOTICE TO DEFEND NOTICE You have been sued fn 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 it written appearance personally or by attorney and riling 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 SEr FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. BAR ASSOCIATION LAWYER REFERRAL & INFORMATION SERVICE 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 AVISO Le ban demandado a usted en la come. Sf usted quiere defenderse the estas demandas expueslas en ]as paginas siguientes, usted lien veinte (20) dias de plazo at partirde lafechadelaclemandaylanolificacion. Hacefaltaasenlar una cornparencfa escrita o en persona o con on abogado y entregar a la code en forma escrita sus defensas o sus objeciones a las demandas en contra the so persona. Sea avisado que sf usted no se defiende, la code tomara medidas y puede continuer la demanda en contra suya sin previo aviso o notificacion. Ademas, la code puede decidir a favor del demandanle y requiere que usted cumpla can todas las provisioner de esta demands. Usled puede perder dinero o sus propiedades a otros derechos impodantes para. usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAAIENTE. SINOTIENEABOGADOOSINOTIENE EL DINERO SURCIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LI.AME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. ASOCIACION DE LICENDIADOS SERVICIO DE REFF.RENCIA E INFORMACION LEGAL 2 Liberty Avenue Carlisle PA 17013 (717) 249.3100 IWN & CONNERY, LLP tanie E. Nolan rney I.D. N 80770 I Market Street Floor, East Tower PA 19102 Attorneys for Plaintiff, Telerent Leasing Corporation TELERENT LEASING CUMB OF COMMON EAS CUMBERLAND COUNTY CORPORATION Plaintiff, DecemberTerm. 1999 No. VS. Civil Action COAST TO COAST MOTEL, INC. P/RIICE' III WILLIAM PRICE, R., COMPLAINT PRI PPR CE, an, JANECLUNSFORDA Plaintiff, Telerent Leasing Corporation (hereinafter "Telerent"), a Delaware corporation, way of complaint against the defendants, Coast to Coast Motel, Inc.. t/a Travelodge, William ice 111. William Price, Jr.. Margaret Price, Patricia Price, and Jane Lunsford (the says: VENUE Telerent is a corporation incorporated under the laws of Delaware and doing business the State of Pennsylvania. Coast to Coast") is a 2. Defendant, Coast to Coast Motel, Inc. t/a Travelodge, (' :nnsylvania corporation doing business at 1252 Harrisburg Pike, Carlisle, PA 17013• 3. Defendant, William Price 111, is an individual residing at 310 Hickory Road, Carlisle, 17013. William Price, Jr., is an individual residing at 1252 Harrisburg Pike, . Defendant, 4 PA 17013. aflmrd & CONNLRY, w",. NJ 08,08 5. Defendant, Margaret Price, is an individual residing at 1252 Harrisburg Pike. Carlisle, 17013. 6. Defendant. Patricia Price, is an individual residing at 310 Hickory Road, Carlisle. PA 7013. 7. Defendant, Jane Lunsford, is an individual residing at 971 Mt. Pleasant Road, New Jersey, 08270. GENERAL ALLEGATIONS 8. Telerent hereby repeats and incorporates the allegations of the preceding paragraphs this Complaint as if set forth at length herein. 9. On or about June 10, 1998, Telerent and Coast to Coast executed lease agreement no. )0 (the "Master Lease") whereby Telerent leased certain personal property to Coast to Coast !d in the schedules to die Master Lease and made a part thereof. A true and correct copy of Master Lease and addenda thereto are attached as Exhibit A. 10. On or about June 10, 1998, defendants William Price Jr., and Margaret Price, executed Master Lease, which was approved by Telerent. See Exhibit A. 11. Pursuant to the terms of the Master Lease, defendants William Price Jr. and Margaret agreed to be bound as co-lessees to all terms of the Master Lease. See Exhibit A. 12. On or about June 10, 1998, defendant William Price, 111, executed an agreement known Lease Addendum I to the Master Lease, which was accepted and approved by Telerent on June 7, 1998 ("Master Lease Addendum 1"). See Exhibit A. 13. Pursuant to the terms of Master Lease Addendum I, defendant William Price, III, agreed be bound as a co-lessee to all terms of the Master Lease. See Exhibit A. 14. On or about July 2, 1998, defendants, Jane Lunsford and Patricia Price, executed an !nt known as Lease Addendum 11 to the Master Lease, which was accepted and approved by on July 9, 1998 ("Master Lease Addendum 11"). See Exhibit A. 1) wcimonti NJ 08108 15. Pursuant to the terms of Master Lease Addendum IL defendants. Jane Lunsford and Patricia Price, agreed to be bound as co-lessees to all terms of the Master Lease. See Exhibit A. 16. On or about August 31, 1998, defendants, William Price, Jr., William Price, III, atricia Price, Margaret Price and Jane Lunsford, executed an agreement known as Lease Addendum I to the Master Lease, which was accepted and approved by Telerent on September 7, 1998 Lease Addendum III"). See Exhibit A. 17. Pursuant to the terms of Master Lease Addendum III, defendants. William Price, III, 1 Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford, agreed to be bound as co- to all terms of Lease Schedule I, identified by Telerent as Lease No. 9907-001; Lease nedule 11, identified by Telerent as Lease No. 9907-002; Lease Schedule III, identified by Telerent Lease No. 9907-003; Lease Schedule IV, identified by Telerent as Lease No. 9907-004; Lease hedule V, identified by Telerent as Lease No. 9907-005; Lease Schedule V1, identified by Telerent Lease No. 9907-006; and Lease Schedule 9907-008, identified by Telerent as Lease No. 9907-008. See Exhibit A. COUNT ONE-BREACH OF CONTRACT (Lease No. 9907-001) 18. Telerent hereby repeats and incorporates the allegations of the preceding of this Complaint as if set forth at length herein. 19. On or about June 10, 1998, Telerent and Coast to Coast executed Lease Schedule 1 the Master Lease which was identified by Telerent as lease agreement no. 9907-001 ("Lease ). 9907-001 ") whereby Telerent leased certain personal property to Coast to Coast (the "9907- 1 Equipment"), described in Exhibit A to Lease No. 9907-001 and made a part thereof. A true d correct copy of Lease No. 9907-001 with exhibits is attached as Exhibit B. 20. On or about June 10. 1998, defendants William Price Jr. and Margaret Price d Lease No. 9907-001, which was approved by Telerent. See Exhibit B. BROWN & CONNERY. LLPII WaImonL NJ 08108 21. Pursuant to the terms of the Lease No. 9907-001, defendants William Price Jr. Margaret Price agreed to he bound as co-lessees to all terms of Lease No. 9907-001. Sec B. 22. Pursuant to the terms of Lease No. 9907-001, the defendants agreed to pay t a monthly lease payment of $4,173.00 for sixty (60) months for the lease of the 9907- 1 Equipment. See Exhibit B. 23. On or about July 23, 1998, defendant Coast to Coast executed an agreement as Lease Addendum I to Lease No. 9907-001. which was accepted and approved by t on July 23, 1998("Lease No. 9907-001 Addendum I"). See Exhibit B. 24. On or about August 18. 1998, defendant Coast to Coast executed an agreement as Lease Addendum II to Lease No. 9907-001, which was accepted and approved by at on August 18. 1998("Lease No. 9907-001 Addendum 11"). See Exhibit B. 25. On or about November 5, 1998, defendants Coast to Coast, William Price Jr., and ret Price executed an agreement known as Lease Addendum III to Lease No. 9907-001, was accepted and approved by Telerent. ("Lease No. 9907-001 Addendum III"). See B. 26. On or about August 20, 1998. defendant Coast to Coast executed an agreement as Lease Addendum IV to Lease No. 9907-001, which was accepted and approved by It on August 27, 1998 ("Lease No. 9907-001 Addendum IV" ). See Exhibit B. 27. On or about December 16, 1998, defendant Coast to Coast executed an agreement as Lease Addendum V to Lease No. 9907-001, which was accepted and approved by at on December 22, 1998 ("Lease No. 9907-001 Addendum V"). See Exhibit B. 28. On or about November 23, 1998, defendants, Coast to Coast, William Price III, m Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford, executed an agreement i as Lease Addendum VI to Lease No. 9907-001, which was accepted and approved by :nt on November 23, 1998 ("Lease No. 9907-001 Addendum VI"). See Exhibit B. BROWN & CONNERV. LLPII 4 %V"Monk NJ oe108 29. On or about September 23, 1998, defendants Coast to Coast and William Price an agreement known as Lease Addendum VII to Lease No. 9907-001, which was and approved by Telerent on October 1. 1998 ("Lease No. 9907-001 Addendum V11"). Exhibit B. 30. In March 1999, defendants, Coast to Coast, William Price 111, William Price, Jr.. aret Price, Patricia Price and Jane Lunsfc.d, defaulted under the terms of Lease No. 9907- as amended and the Master Lease, by failing to make certain monthly payments when due. 31. As of November 15, 1999, the Defendants were in arrears in the amount of 181.34 under the terms of the 9907-001 Lease, as amended, and the Master Lease. 32. The Defendants' default terminated any and all of rights of the Defendants under terms of the 9907-001 Lease, as amended, and the Master Lease, including the right to use and the 9907-001 Equipment. 33. Pursuant to the terms of die 9907-001 Lease, as amended, and the Master Lease, t has elected that all amounts due or to become due under the terms of Lease No. 9907- as amended, be and are immediately due and payable. 34. As of November 15, 1999, die balance due under Lease No. 9907-001, as was $260,553.00. 35. Telerent has demanded payment from the Defendants but no payment has been See Exhibit I. 36. Telerent is entitled to recover attorneys' fees and costs from the Defendants under terms of the 9907-00ILease, as amended, and the Master Lease. WHEREFORE, Telerent Leasing Corporation demands judgment against defendants 1st to Coast, William Price III, William Price, Jr., Margaret Price, Patricia Price and Jane tsford, jointly and severally, for money damages in the amount of $260,553.00, together with charges, pre-judgment interest, costs of suit, attorneys' fees, and such other relief as the may deem just. BROWN & CONNERV. LLPII wwwo.4 M 08108 COUNT 11-BREACH OF CONTRACT (Lease No. 9907-002) 37. Telerent hereby repeats and incorporates the allegations of the preceding paragraphs of this Complaint as if set forth at length herein. 38. On or about June 10, 1998, Telerent and Coast to Coast executed Lease Schedule 11 o the Master Lease which was identified by Telerent as lease agreement no. 9907-002 ("Lease No. 907-002") whereby Telerent leased certain personal property to Coast to Coast (the "9907.(H)2 quipment"), described in Lease No. 9907-002 and made a part thereof. A true and correct copy if Lease No. 9907-002 is attached as Exhibit C. 39. On or about June 10, 1998, defendants William Price Jr. and Margaret Price d Lease No. 9907-002, which was approved by Telerent. See Exhibit C. 40. Pursuant to the terms of the Lease No. 9907-002, defendants William Price Jr. and Price agreed to he bound as co-lessees to all terms of Lease No. 9907-002. }yg Exhibit 41. Pursuant to the terms of Lease No. 9907-002, the defendants agreed to pay Telerent monthly lease payment of $1,028.00 for sixty (60) months for the lease of t'tc 9907-002 Equipment. Exhibit C. 42. On or about August 31, 1998, defendants Coast to Coast, William Price, III, William Jr., Margaret Price, Patricia Price, and Jane Lunsford, executed an agreement known as Lease I to Lease No. 9907-002, which was accepted and approved by Telerent on September , 1998 ("Lease No. 9907-002 Addendum I"). See Exhibit C. 43. Pursuant to the terms of Lease No. 9907.002 Addendum I, defendants William Price, William Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford agreed to be bound as co- to all terms of Lease Schedule I, identified by Telerent as Lease No, 9907.001; Lease 11, identified by Telerent as Lease No. 9907-002; Lease Schedule III, identified by Telerent Lease No. 9907-003; Lease Schedule IV, identified by'relerent as [.ease No. 9907-004; Lease BROWN & CONNERY, LLPII Watmont, NJ 09103 6 V. identified by Telerent as Lease No. 9907-005; Lease Schedule VI. identified byTelerent Lease No. 9907-006; and Lease Schedule 9907-008, identified by Teierent as Lease No. 9907-008. Exhibit C. 44. In March 1999. defendants, Coast to Coast, William Price 111, William Price, Jr., Price, Patricia Price and Jane Lunsford, defaulted under the terms of Lease No. 9907-002. amended, and the Master Lease, by failing to make certain monthly payments when due. 45. As of November 15, 1999, the Defendants were in arrears in the amount of 1,387.12 under the terms of the 9907-002 Lease, as amended, and the Master Lease. 46. The Defendants' default terminated any and all of rights of the Defendants under the of the 9907-002 Lease, as amended, and the Master Lease, including the right to use and s die 9907-002 Equipment. 47. Pursuant to the terms of the 9907-002 Lease, as amended, and the Master Lease. nt has elected that all amounts due or to become due under the terms of Lease No. 9907-002. amended, be and are immediately due and payable. 48. As of November 15, 1999, the balance due under Lease No. 9907-002, as amended, $51.400.00. 49. Telerent has demanded payment from the Defendants but no payment has been made. Exhibit 1. 50. Telerent is entitled to recover attorneys' fees and costs front the Defendants under the s of the Master Lease. WHEREFORE. Telerent Leasing Corporation demands judgment against defendants Coast Coast, William Price III, William Price, Jr., Margaret Price, Patricia Price and Jane Lunsford, and severally, for money damages in the amount of $51,400.00, together with late charges, interest, costs of suit, attorneys' fees, and such other relief as the Court may deemjust. BROWN & CONNERY, UP II W.2...q NJ 8810 7 4° COUNT THREE-BREACH OF CON'rRAC'1' (Lease No. 9907-003) 51. Telerent hereby repeats and incorporates the allegations of the preceding of this Complaint as if set forth at length herein. 52. On or about June 10, 1998, Telerent and Coast to Coast executed Lease Schedule to the Master Lease which was identified by Telerent as lease agreement no. 9907-003 ("Lease 9907-003") whereby Telerent leased certain personal property to Coast to Coast (the "9907- Equipment"), described in Lease No. 9907-003 and made a part thereof. A true and correct y of Lease No. 9907-003 is attached as Exhibit D. 53. On or about June 10. 1998, defendants William Price Jr., and Margaret Price, :uted Lease No. 9907-003, which was approved by Telerent. See Exhibit D. 54. Pursuant to the terms of the Lease No. 9907-003, defendants William Price Jr. Margaret Price agreed to be bound as co-lessees to all terms of Lease No. 9907-003. See bit D. 55. Pursuant to the terms of Lease No. 9907-003, the defendants agreed to pay rent a monthly lease payment of $1,156.00 for sixty (60) months for the lease of the 9907- Equipment. See Exhibit D. 56. On or about August 31, 1998, defendants Coast to Coast, William Price, III, iam Price. Jr., Margaret Price, Patricia Price, and Jane Lunsford, executed an agreement vn as Lease Addendum III to Lease No. 9907-003, which was accepted and approved by rent on September 7, 1998 ("Lease No. 9907-003 Addendum 111"). See Exhibit D. 57. Pursuant to the terms of Lease No. 9907-003 Addendum III, defendants William III, William Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford agreed to be d as co-lessees to all terms of Lease Schedule 1, identified by Telerent as Lease No. 9907- 1; Lease Schedule 11, identified by Telerent as Lease No. 9907-002; Lease Schedule III, tified by Telerent as Lease No. 9907-003; Lease Schedule IV, identified by Telerent as Lease 9907-004; Lease Schedule V. identified by Telerent as Lease No. 9907-005; Lease Schedule BROWN & CONNERY. LLPII 8 Wnlmoo4 NJ 08108 identified by Telerent as Lease No. 9907-006; and Lease Schedule 9907-008, identified by ;lerent as Lease No. 9907-008. See Exhibit D. 58. In December 1998, defendants, Coast to Coast, William Price Ill, William Price, ., Margaret Price, Patricia Price and Jane Lunsford, defaulted under the terms of Lease No. 107-003, as amended, and the Master Lease, by failing to make certain monthly payments when 59. As of November 15, 1999, the Defendants were in arrears in the amount of 1.92 under the terms of the 9907-003 Lease, as amended, and the Master Lease. 60. The Defendants' default terminated any and all of rights of the Defendants under terms of the 9907-003 Lease, as amended, and the Master Lease, including the right to use possess the 9907-003 Equipment. 61. Pursuant to the terms of the 9907-003 Lease, as amended, and the Master Lease, ent has elected that all amounts due or to become due under the terms of Lease No. 9907- as amended, be and are immediately due and payable. 62. As of November 15, 1999, the balance due under Lease No. 9907-003, as ded, was $54,332.00. 63. Telerent has demanded payment from the Defendants but no payment has been See Exhibit L 64. Telerent is entitled to recover attorneys' fees and costs from the Defendants under terms of the Master Lease. WHEREFORE, Telerent Leasing Corporation demands judgment against defendants st to Coast, William Price 111, William Price, Jr., Margaret Price, Patricia Price and Jane sford, jointly and severally, for money damages in the amount of $54,332.00, together with charges, pre judgment interest, costs of suit, attorneys' fees, and such other relief as the may deem just. 'AWN & CONNr.RY. LLPII 9 W. m.. 1J OE108 COUNT FOUR-BREACH OF CONTRACT (Lease No. 9907-004) 65. Telerent hereby repeats and incorporates the allegations of the preceding Inaragratilis of this Complaint as if set forth at length herein. 66. On or about June 10, 1998, Telerent and Coast to Coast executed Lease Schedule to the Master Lease which was identified by Telerent as lease agreement no. 9907-004 ("Lease 9907-004") whereby Telerent teased certain personal property to Coast to Coast (the "9907- Equipment"), described in Lease No. 9907-004 and made a part thereof. A true and correct v of Lease No. 9907.004 is attached as Exhibit E. 67. On or about June 10. 1998, defendants William Price Jr. and Margaret Price uted Lease No. 9907-004, which was approved by Telerent. See Exhibit E. 68. Pursuant to the terms of the Lease No. 9907-004, defendants William Price Jr. Margaret Price agreed to be bound as co-lessees to all terms of Lease No. 9907-004. See ibit E. 69. Pursuant to the terms of Lease No. 9907-004, the defendants agreed to pay rent a monthly lease payment of $942.00 for sixty (60) months for the lease of the 9907-004 See Exhibit E. 70. On or about August 20, 1998, defendant Coast to Coast executed an agreement as Lease Addendum I to Lease No. 9907-004, which was accepted and approved by it on August 27, 1998 ("Lease No. 9907-004 Addendum V). See Exhibit E. 71. On or about September 9, 1998, defendant Coast to Coast executed an agreement as Lease Addendum 11 to Lease No. 9907-004, which was accepted and approved by at on September 9, 1998 ("Lease No. 9907-004 Addendum 11"). See Exhibit E. 72. On or about August 31, 1998, defendants Coast to Coast, William Price, III, in Price, Jr., Margaret Price, Patricia Price, and Jane Lansford, executed an agreement as Lease Addendum III to Lease No. 9907-004, which was accepted and approved by nt on September 7, 1998 ("Lease No. 9907-004 Addendum III"). See Exhibit E. BROWN & CIINNRRY. LLYII 10 W.Imon4 NJ AAIOA 12,051.74 under the terms of the 9907-004 Lease, as amended, and the Master Lease. The efendants' default terminated any and all of rights of the Defendants under the terms of the 107-004 Lease, as amended, and the Master Lease, including the right to use and possess the t07-004 Equipment. 73. Pursuant to the terms of Lease No. 9907-004 Addendum Ill. defendants William 'rice, III, William Price, Jr., Margaret Price, Patricia Price. and Jane Lunsford agreed to he ound as co-lessees to all terms of Lease Schedule 1, identified by Telerent as Lease No. 9907- DI; Lease Schedule 11, identified by Telerent as Lease No. 9907.002; Lease Schedule III, entified by Telerent as Lease No. 9907-003; Lease Schedule IV, identified by Telerent as Lease o. 9907-004; Lease Schedule V. identified by Telerent as Lease No. 9907-005; Lease Schedule identified by Telerent as Lease No. 9907-006; and Lease Schedule 9907-008, identified by lerent as Lease No. 9907-008. See Exhibit E. 74. On or about June 17, 1998, defendant Coast to Coast executed an agreement Iwn as Lease Addendum IV to Lease No. 9907-004, which was accepted and approved by Brent on June 17, 1998 ("Lease No. 9907-004 Addendum IV"). See Exhibit E. 75. On or about September 25. 1998, defendant Coast to Coast executed an agreement wn as Lease Addendum V to Lease No. 9907-004, which was accepted and approved by rent on September 25, 1998 ("Lease No. 9907-004 Addendum V"). See Exhibit E. 76. In March 1999, defendants, Coast to Coast, William Price III, William Price, Jr., ;aret Price, Patricia Price and Jane Lunsford, defaulted under the terms of Lease No. 9907- as amended, and the Master Lease, by failing to make I ertain monthly payments when due. 77. As of November 15, 1999, the Defendants were in arrears in the amount of 78. Pursuant to the terms of the 9907-004 Lease, as amended, and the Master Lease, 'em: has elected that all amounts due or to become due under the terms of Lease No. 9907- as amended, be and are immediately due and payable. 79. As of November 15, 1999, the balance due under Lease No. 9907-004, as Iprttended, was $54,400.00. BROWN& CONNERV. LLP wntmnn1. NJ 08188 80. Telerent has demanded payment from the Defendants but no payment has been Lade. See Exhibit 1. 81. Telerent is entitled to recover attorneys' fees and costs from the Defendants under terms of the Master Lease. WHEREFORE, Telerent Leasing Corporation demands judgment against defendants to Coast, William Price 111, William Price, Jr., Margaret Price, Patricia Price and Jane jointly and severally, for money damages in the amount of $54,400.00, together with charges, pre-judgment interest, costs of suit, attorneys' fees, and such other relief as the may deem just. COUNT FIVE-BREACH OF CONTRACT (Lease No. 9907-005) 82. Telerent hereby repeats and incorporates the allegations of the preceding ?aragraphs of this Complaint as if set forth at length herein. 83. On or about June 10. 1998. Telerent and Coast to Coast executed Lease Schedule to the Master Lease which was identitted by Telerent as lease agreement no. 9907-005 ("Lease ). 9907-005") whereby Telerent leased certain personal property to Coast to Coast (die "9907- 5 Equipment"), described in Lease No. 9907-005 and made a part thereof. A true and correct py of Lease No. 9907-004 is attached as Exhibit F. 84. On or about June 10, 1998, defendants William Price Jr. and Margaret Price uted Lease No. 9907-005, which was approved by Telerent. See Exhibit F. 85. Pursuant to the terms of the Lease No. 9907-005, defendants William Price Jr. Margaret Price agreed to be bound as co-lessees to all terms of Lease No. 9907-005. See ibit F. 86. Pursuant to the terms of Lease No. 9907-005, the defendants agreed to pay :rent a monthly lease payment of $300.00 for sixty (60) months for the lease of the 9907-005 ?quipment. See Exhibit F. BROWN & CONNERY, I." Wntmont, NJ 08109 12 87. On or about August 31, 1998. defendants Coast to Coast, William Price, 111, n Price, Jr.. Margaret Price, Patricia Price, and Jane Lunsford, executed an agreement as Lease Addendum III to Lease No. 9907-005, which was accepted and approved by it on September 7, 1998 ("Lease No. 9907-005 Addendum III"). See Exhibit F. 88. Pursuant to the terms of Lease No. 9907-005 Addendum IIL defendants William e, III, William Price, Jr., Margaret Price, ,Patricia Price, and Jane Lunsford agreed to be nd as co-lessees to all terms of Lease Schedule I. identified by Telerent as Lease No. 9907- ; Lease Schedule 11, identified by Telerent as Lake No. 9907-002; Lease Schedule III. tified by Telerent as Lease No. 9907.003; Lease Schedule IV, identified by Telerent as Lease 9907-004; Lease Schedule V. identified by Telerent as Lease No. 9907-005; Lease Schedule identified by Telerent as Lease No. 9907-006; and Lease Schedule 9907-008, identified by as Lease No. 9907-008. See Exhibit F. 89. In March 1999, defendants, Coast to Coast, William Price III, William Price, Jr., aret Price, Patricia Price and Jane Lunsford, defaulted under the terms of Lease No. 9907- as amended and the Master Lease, by failing to make certain monthly payments when due. 90. As of November 15, 1999, the Defendants were in arrears in the amount of ,323.10 under the terms of the 9907-005 Lease, as amended, and the Master Lease. 91. The Defendants' default terminated any and all of rights of the Defendants under terms of the 9907-005 Lease, as amended, and die Master Lease, including the right to use d possess die 9907-005 Equipment. 92. Pursuant to the terms of the Master Lease, Telerent has elected that all amounts e or to become due under the terms of Lease No. 9907-005, as amended, be and are due and payable. 93. As of November 15, 1999, the balance due under Lease No. 9907-005, as d, was $15,000.00. 94. Telerent has demanded payment from the Defendants but no payment has been See Exhibit 1. TOWN & CONNERY, LLP W,tmon4 NJ 08108 'J [, 4.Iw 95. Telerent is entitled to recover attorneys' fees and costs from the Defendants under terms of the Master Lease. WHEREFORE, Telerent Lcasine Corporation demands judgment against defendants st to Coast, William Price Ill, William Price, Jr.. Margaret Price, Patricia Price and Jane sford, jointly and severally, for money damages in the amount of $15,000.00, together with charges, pre-judgment interest, costs of suit, attorneys' fees, and such other relief as the rt may deem just. COUNT SIX-BREACH OF CONTRACT (Lease No. 9907-006) 96. Telerent hereby repeats and incorporates the allegations of the preceding of this Complaint as if set forth at length herein. 97. On or about June 10, 1998, Telerent and Coast to Coast executed Lease Schedule to the Master Lease which was identified by Telerent as lease agreement no. 9907-006 ("Lease 9907-006") whereby Telerent leased certain personal property to Coast to Coast (the "9907- Equipment"), described in Lease No. 9907-006 and made a part thereof. A true and correct y of Lease No. 9907-006 is attached as Exhibit G. 98. On or about June 10, 1998, defendants William Price Jr. and Margaret Price d Lease No. 9907-006, which was approved by Telerent. See Exhibit G. 99. Pursuant to the terms of the Lease No. 9907-006, defendants William Price Jr. Margaret Price agreed to be bound as co-lessees to all terms of Lease No. 9907-006. See ibit G. 100. Pursuant to the terms of Lease No. 9907-006, the defendants agreed to pay a monthly lease payment of $1,020.00 for sixty (60) months for the lease of the 9907- Equipment. See Exhibit G. BROWN & CONNERY LLP , II 14 Wnm..4 NJ ORIG .an 101. On or about July 2, 1998, defendant Coast to Coast executed an agreement known as Lease Addendum I to Lease No. 9907-006, which was accepted and approved by Telerent on 9, 1998. ("Lease No. 9907-006 Addendum I"). See Exhibit G. 102. On or about August 31, 1998, defendants Coast to Coast, William Price, III, am Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford, executed an agreement m as Lease Addendum II to Lease No. 9907-006, which was accented and approved by ent on September 7, 1998 ("Lease No. 9907-006 Addendum IF'). See Exhibit G. 103. Pursuant to the terms of Lease No. 9907.006 Addendum 11, defendants William III, William Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford agreed to be i as co-lessees to all terms of Lease Schedule 1, identified by Telerent as Lease No. 9907- I; Lease Schedule II, identified by Telerent as Lease No. 9907-002; Lease Schedule III, by Telerent as Lease No. 9' 07-003; Lease Schedule IV, identified by Telerent as Lease 9907-004; Lease Schedule V, identified by Telerentas Lease No. 9907-005; Lease Schedule identified by Telerent as Lease No. 9907-006; and Lease Schedule 9907-008, identified by as Lease No. 9907-008. See Exhibit G. 104. On or about November 23, 1998, defendants Coast to Coast, William Price III, Price, Jr., Margaret Price, and Jane Lunsford, executed an agreement known as um III to Lease No. 9907-006, which was accepted and approved by Telerent on ter 23. 1998 ("Lease No. 9907-006 Addendum III"). See Exhibit G. 105. In December 1998, defendants, Coast to Coast, William Price III, William Price, ., Margaret Price, Patricia Price and Jane Lunsford, defaulted under the terms of Lease No. as amended and the Master Lease, by failing to make certain monthly payments when 106. As of November 15, 1999, the Defendants were in arrears in the amount of ,843.75, under the terms of the 9907-006 Lease, as amended, and the Master Lease. n ROWN & CONNCRV, LLPII \Vnlmoot, NJ 0810A 15 1 107. The Defendants' default terminated any and all of rights of the Defendants under he terms of the 9907-006 Lease, as amended, and the Master Lease. including the right to use possess the 9907-006 Equipment. 108. Pursuant to the terms of the 9907-006 Lease, as amended, and the Master Lease, ent has elected that all amounts due or to become due under the terms of Lease No. 9907- as amended, be and are immediately due and payable. 109. As of November 15, 1999, the balance due under Lease No. 9907-006, as ded, was $88,083.24. 110. Telerent has demanded payment from the Defendants but no payment has been See Exhibit 1. 111. Telerent is entitled to recover attorneys' fees and costs from the Defendants under terms of the Master Lease. WHEREFORE, Telerent Leasing Corporation demands judgment against defendants st to Coast, William Price 111• William Price, Jr.. Margaret Price, Patricia Price and Jane sford, jointly and severally, for money damages in the amount of $88.083.24, together with charges, pre-judgment interest, costs of suit, attorneys' fees, and such other relief as the rt may deem just. COUNT SEVEN-BREACH OF CONTRACT (Lease No. 9907-008) 112. Telerent hereby repeats and incorporates the allegations of the preceding graphs of this Complaint as if set forth at length herein. 113. On or about June 10, 1998, Telerent and Coast to Coast executed Lease Schedule to the Master Lease which was identified by Telerent as lease agreement no. 9907-008 ase No. 9907-008") whereby Telerent leased certain personal property to Coast to Coast (the Equipment"), described in Lease No. 9907-008 and made a part thereof. A true and copy of Lease No. 9907-008 is attached as Exhibit H. BROWN & CONNL'RV. LIS 16 Wntmon I. NJ 08108 11 114. On or about June 10. 1998, defendants William Price Jr., and Margaret Price, •xecuted Lease No. 9907.008, which was approved by "referent. See Exhibit li. 115. Pursuant to the terms of the Lease No. 9907-008, defendants William Price Jr. nd Margaret Price agreed to be bound as co-lessees to all terms of Lease No. 9907-008. See H. 116. Pursuant to the terms of Lease 1Jo. 9907-008, the defendants agreed to pay a monthly lease payment of $50.00 for sixty (60) months for the lease of the 9907-008 See Exhibit H. 117. On or about August 31, 1998, defendants Coast to Coast, William Price, III, t Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford, executed an agreement as Lease Addendum 111 to Lease No. 9907-008. which was accepted and approved by it on September 7. 1998 ("Lease No. 9907-008 Addendum 111"). See Exhibit 11. 118. Pursuant to the terms of Lease No. 9907-008 Addendum Ill, defendants William ice, Ill, William Price, Jr., Margaret Price, Patricia Price, and Jane Lunsford agreed to be ,und as co-lessees to all terms of Lease Schedule I, identified by Telerent as Lease No. 9907- 11; Lease Schedule 11, identified by Telerent as Lease No. 9907-002; Lease Schedule III, entified by Telerent as Lease No. 9907-003; Lease Schedule IV, identified by Telerent as Lease D. 9907-004; Lease Schedule V, identified by Telerent as Lease No. 9907-005; Lease Schedule 1, identified by Telerent as Lease No. 9907-006; and Lease Schedule 9907-008, identified by Ierent as Lease No. 9907-008. See Exhibit H. 119. In December 1998, defendants, Coast to Coast, William Price 111, William Price, Margaret Price, Patricia Price and Jane Lunsford, defaulted under the terms of Lease No. 907-008. as amended, and the Master Lease, by failing to make certain monthly payments when 120. As of November 15. 1999, the Defendants were in arrears in the amount of I. under the terms of the 9907.008 Lease. as amended. and the Master Lease. IIROIYN & CONNr.RV, MY 17 Wnlmon4 NJ 08108 11 f 121. The Defendants' default terminated any and all of rights of the Defendants under he terms of the 9907-008 Lease, as amended, and the Master Lease, including the right to use possess the 9907-008 Equipment. 122. Pursuant to the terns of the 9907-008 Lease, as amended, Master Lease, Telerent elected that all amounts due or to become due under the terms of Lease No. 9907-008, as nded, be and are immediately due and payable. 123. As of November 15, 1999, the balance due under Lease No. 9907-008, as was $2,350.00. 124. Telerent has demanded payment from the Defendants but no payment has been See Exhibit 1. 125. Telerent is entitled to recover attorneys' fees and costs from the Defendants under terms of the Master Lease. WHEREFORE, Telerent Leasing Corporation demands judgment against defendants st to Coast, William Price III, William Price, Jr., Margaret Price, Patricia Price and Jane sford, jointly and severally, for money damages in the amount of $2,350.00, together with charges, pre-judgment interest, costs of suit, attorneys' fees, and such other relief as the may deem just. COUNT EIGHT-REPLEVIN (Lease Nos. 9907-001, -002, -003, 004, -005, -006, -008) 126. Telerent hereby repeats and incorporates the allegations of the preceding of this Complaint as if set forth at length herein. 127. The Defendants are in possession of certain personal property leased by Telerent t to the terms of the Master Lease and Leases 9907-001, 9907-002, 9907-003, 9907-004, 9907-006, and 9907-008 (collectively the "Equipment"). 128. Telerent, having determined to repossess the Equipment and being the full and ied owner of the Equipment, is entitled to remove the Equipment in accordance with the 1erms of the Master Lease. BROWN & CONNERY, LLP Wn10Cn4 NJ 08109 18 129. The estimated fair market value of the Equipment is $457,901.98. 130. Defendants unjustly detain the Equipment. 131. The value of the Equipment and 'felerent's interest in the Equipment will be ly affected by the continued possession and use of the Equipment by the Defendants. 132. Defendants or other person in possession of the Equipment may dispose, er, or waste the Equipment or remove the Equipment from the jurisdiction of the WHEREFORE, Telerent Leasing Corporation dentandsjudgment against defendants to Coast, William Price 111, William Price, Jr.. Margaret Price, Patricia Price and Jane trd, jointly and severally, for possession of the Equipment, together with late charges, pre- ent interest, costs of suit, attorneys' fees, and such other relief as the Court may deem just. BROWN & CONNERY, LLP Attorneys for Plaintiff, Telerent Leasing Corporation November,V 1999 By: QC teph ie E. Nolan BROWN & CONNFRV. I.I.I. Wmm0n4 NJ OXI( 11 19 VERIFICATION I verity that the statements in this Complaint are true and correct. I understand that alse statements herein are made subject to the penalties of IS Pa. C.S.A. §4904 relating to falsification to authorities. TELERENT LEASING CORPORATION ated: Novemberd 1999 r? ckie Coo r BROWN & CONNERY. I.I.P Wotm at. NJ 08108 20