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HomeMy WebLinkAbout07-3232Robert D. Kodak, Esquire Supreme Court I.D. 18041 KODAK & IMBLUM, P.C. Post Office Box 11848 407 North Front Street Harrisburg, PA 17108-1848 717-238-7152 Fax: 717-238-7158 email: robert.kodak@verizon.net Attorney for Plaintiff PENNSYLVANIA STATE BANK, IN THE COURT OF COMMON PLEAS Division of BLC BANK, N.A. Plaintiff V. : CUMBERLAND COUNTY, PENNSYLVANIA NO. DONALD B. LEGGETT and MELISSA M.LEGGETT Defendants CIVIL DIVISION - LAW : CONFESSED JUDGMENT CONFESSION OF JUDGMENT Pursuant to the authority contained in the warrant of authority, a true and correct copy of which is attached to the Complaint filed in this action, I appear for the Defendants and confess Judgment in favor of Plaintiff and against Defendants as follows: Principal Amount Due ............................... $ 630,643.13 Interest Amount Due @ 7.45% p/a ...................... $ 2,285.01 Attorney Collection Fees ..................... .. $ 63,292.81 TOTAL ............................... .... 696 220.95 Judgment entered as above. -- Robert D. Kodak, Esquire ' - Attorney for Defendants Prothonotary PENNSYLVANIA STATE BANK, Division of BLC BANK, N.A. Plaintiff V. DONALD B. LEGGETT and MELISSA M. LEGGETT Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. CIVIL DIVISION - LAW : CONFESSED JUDGMENT CONFESSED JUDGMENT COMPLAINT Plaintiff files this Complaint pursuant to Pa. R.C.P. No. 2951(b) for Confession of Judgment and avers the following: 1. Plaintiff is Pennsylvania State Bank, a Division of BLC Bank, N.A., a financial organization duly organized and existing under Federal laws, with its principal office and place of business at 2148 Market Street, Camp Hill, Cumberland County, Pennsylvania 17013. 2. Defendant, Donald B. Leggett, is an adult individual, who maintains an address at 150 East Lauer Lane, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Defendant, Melissa M. Leggett, is an adult individual, who maintains an address at 150 East Lauer Lane, Camp Hill, Cumberland County, Pennsylvania 17011. F:\USER\BONNIEJO\PSB\CONFJUDG\Spankeys et al\comp leggett gty 3070109.wpd:25May07 1 4. In an effort to induce Plaintiff to extend credit to the business operating as Spankey's Auto Sales, a Pennsylvania Business Trust, Donald B. Leggett, Trustee, on or about January 26, 1999, Defendants did execute an a Commercial Guaranty as a guaranty of payment on a principal Note in the amount of One Million, One Hundred Thousand ($1,100,000.00) Dollars. A true and correct copy of said Commercial Guaranty is attached hereto, marked as Exhibit "A" and made a part hereof. 5. As a furtherance of their Guaranty, Defendants did also initial and sign a Disclosure for Confession of Judgment in favor of Plaintiff. A true and correct copy of said Disclosure for Confession of Judgment is attached hereto, marked as Exhibit "B" and made a part hereof. 6. The attached Commercial Guaranty has not been assigned. 7. Judgment has not been previously entered on the attached Commercial Guaranty in any jurisdiction. 8. The business known as Spankey's Auto Sales, a Pennsylvania Business Trust, Donald B. Leggett, Trustee, is indebted to Plaintiff in the principal amount of Six Hundred Thirty Thousand, Six Hundred Forty-Three Dollars and Thirteen Cents ($630,643.13), for which no payment has been received when due and payable, which constitutes a default, whereby Plaintiff exercises its option F:\USER\BONNIEJO\PSB\CONFJUDG\Spankeys et al\comp leggett gty 3070109.wpd:25May07 MAY-24-2007 11:05 COMMERCIAL LOAN DOCUMENTA 7177354764 P.005 COMMERCIAL GUARANT. Guarantor: Donald B. Leggett and Melissa M. Leggett 150 E. Lauer Lane Camp MII, PA 17011 AMOUNT OF GUARANTY. This Is a guaranty of payment of 100.000% of the Note, Including without limitation the principal Note amount of One Million One Hundred Thousand & 00/100 Dollars ($1,100,000.00). GUARANTY, For good and valuable consideration, Donald B. Leggett and Melissa M. Leggett ("Guarantor") absolutely and unconditionally guarantee and promise to pay, jointly and severally, to PENNSYLVANIA STATE BANK ("Lender") or Its order„ In legal tender of the United States of America, 100.000% of the Indebtedness (as that term is defined below) of Spankey's Auto Sales, A Pennsylvania Business Trust ("Borrower") to Lender on the terms and conditions set forth In this Guaranty. Guarantor agrees that Lender, In its sole discretion, may determine which portion of Borrower's Indebtedness to Lender is covered by Guarantor's percentage guaranty. DEFINITIONS. The following words shall have the following meanings when used In this Guaranty: Borrower. The word "Borrower" means Spankey's Auto Sales, A Pennsylvania Business Trust. Guarantor. The word "Guarantor" means Donald B. Leggett and Melissa M. Leggett, who are signing this Guaranty jointly and severally. Guaranty. The word "Guaranty" means this Guaranty made by Guarantor for the benefit of Lender dated January 26, 1999. Indebtedness. -The word "Indebtedness" means the Note, including (a) all prlnolpal, (b) all interest, (c) all late charges, (d) all loan fees and loan charges, and (e) all collection costs and expenses relating to the Note or to any collateral for the Note. Collection costs and expenses include without limitation all of Lender's attorneys' fees and Lender's legal expenses, whether or not suit is instituted, and attorneys' fees and legal expenses for bankruptcy proceedings (Including efforts to modify or vacate any automatic stay or Injunction), appeals, and any anticipated post-judgment collection services. Lender. The word 'Lender" means PENNSYLVANIA STATE BANK, Its successors and assigns. Note. The word "Note" means the promissory note or credit agreement dated January 26, 1999, In the original principal amount of $1,100,000.00. from Borrower to Lender, together with all renewals of, extensions of, modifications of, refinancings of, consolidations of, and substitutions for the promissory note or agreement. Related Documents. The words "Related Documents" mean and Include without limitation all promissory notes, credit agreements, loan agreements, environmental agreements, guaranties, security agreements, mortgages, deeds of trust, and all other Instruments, agreements and documents, whother now or hereafter extsting, executed in connection with the indebtedness. MAXIMUM LIABILITY. The maximum liability of Guarantor under this Guaranty shall not exceed at any one time 100.000% of the amount of the indebtedness described above, plus all costs and expenses of (a) enforcement of this Guaranty and (b) collection and sale of any Collateral securing this Guaranty. The above limitation on Ilablilty Is not a restriction on the amount of the Indebtedness of Borrower to Lender either in the aggregate or at any one time. If Lender presently holds one or more guaranties, or hereafter receives additional guaranties from Guarantor, the rights of Lender under all guaranties shell be cumulative. This Guaranty shall not (unless specifically provided below to the contrary) affect or invalidate any such other guaranties. The liability of Guarantor will be the aggregate liability of Guarantor under the terms of this Guaranty and any such other unterminated guaranties. NATURE: OF GUARANTY. Guarantor Intends to guarantee at all timers the performance and prompt payment when due, whether at maturity or earlier by reason of acceleration or otherwise, of all Indebtedness, within the limits set forth In the preceding section of this Guaranty. The obligations of Guarantors shall be joint and several. Lender may proceed against any of the Guarantors individually, against any group of Guarantors, or against all the Guarantors in one action, without affecting the right of Lender to proceed against other Guarantors for amounts that are covered by this Guaranty. Any inability of Lender to proceed against any Guarantor (whether caused by actions of a Guarantor or of -Lander) will not affect Lender's right to proceed against any or all remaining Guarantors for all or part of the amounts covered by this Guaranty. DURATION OF GUARANTY. This Guaranty will take effect when received by Lender without the necessity of any acceptance by Lender, or any notice to Guarantor or to Borrower, and will continue in full force until all Indebtedness shall have been fully and finally paid and satisfied and all other obligations of Guarantor under this Guaranty shall have been performed In full. Release of any other guarantor or termination of any other guaranty of the indebtedness shall not affect the liability of Guarantor under this Guaranty. A revocation received by Lender from any one or more Guarantors shall not affect the liability of any remaining Guarantors under this Guaranty. GUARANTOR'S AUTHORIZATION TO LENDER.. Guarantor authorizes Lender, without notice or demand and without lessening Guarantor's liability under this Guaranty, from time to time: (a) to 'make one or more additional secured or unsecured loans to Borrower, to lease equipment or other goods to Borrower, or otherwise to extend additional credit to Borrower; (b) to alter, compromise, renew, extend, accelerate, or otherwise change one or more times the time for payment or other terms of the Indebtedness or any part of the Indebtedness, Including increases and decreases of the rate of Interest on the Indebtedness; extensions may be repeated and may be for longer than the. Indebtedness, and exchange, enforce, waive, original loan term; (c) to take and hold security for the [17 nt At Itho subordinate, rail or tlecide not to perfect, and release any he substitution of new collateral; (d) to release, substitute, agree not to sue, or deal with any one or more ers, or other guarantors on any terms or In any manner Lender may choose; (e) to determine how, when aand credits shall be made on the Indebtedness; (f) to apply such' security and direct the order or manner olimitation, any nonjhdlcial sale permitted by the terms of the controlling security agreement or deed of trustdetermine; (g) to sell, transfer, assign, or grant partlcipatlons In alt or any part of the Indebtedness; and (n) ty In whole or in part. GUARANTOR'S REPRESENTATIONS AND WARRANTIES. Go Lender tha t (a) no representations or agreements of any kind have been mado to Guarantor which would limit or cualifv in anv wav the tams of this (;narnnty /h? thl't (4#-Anh, iC own-stmA of Borrower: Spankey's Auto Sales, A Pennsylvania Business Lender: PENNSYLVANIA STATE BANK Trust Cumberland Parkway Donald B. Leggett, Trustee 91 Cumberland Parkway 701 E. Locust Street Mechanicsburg, PA 17065 Mechanicsburg, PA 17055 MAY-24-2007 11:05 COMMERCIAL LOAN. DOCUMENTAI 7177354764 P.006 rdgt: ` Loan No 64000102 (Continued) this Guaranty do not conflict with or result In a default under any agreement or other instrument binding upon Guarantor and do not result in a violation of any law, regulation, court decree or order applicable to Guarantor; (a) Guarantor has not and will not, without the prior written consent of Lender, sail, lease, assign, encumber, hypothecale, transfer, or otherwise dispose of all or substantially all of Guarantor's assets, or any Interest therein; (f) upon Lender's request, Guarantor will provide to Lender financial and credit information In form acceptable to Lender, and all such financial information which currently has been, and all future financial information which will be provided to Lender is and will be true and correct in all maleHal respects and fairly present the financial condition of Guarantor as of the dates the financial Information is provided; (g) no material adverse change has occurred in Guarantor's financial condition since the date of the most recent financial statements provided to Lender and no event has occurred which may materially adversely affect Guarantor's financial condition; (h) no litigation, claim. Investigation, administrative proceeding or similar action (including those for unpaid taxes) against Guarantor is pending or threatened; (I) Lender has made no representation to Guarantor as to the creditworthiness of Borrower: and 0) Guarantor has established adequate means of obtaining from Borrower on a continuing basis Information regarding Borrower's financial condition. Guarantor agrees to keep adequately Informed from such means of any facts, events, or circumstances which might in any way affect Guarantor's risks under this Guaranty, and Guarantor further agrees that Lender shall have no obligation to disclose to Guarantor any information or documents acquired by Lender In the course of its relationship with Borrower. GUARANTOR'S WAIVERS. Except as prohibited by applicable law. Guarantor waives any right to require Lender (a) to continue lending money or to extend other credit to Borrower, (b) to make any presentment, protest, demand, or notice of any kind, including notice of any nonpayment of the Indebtedness or of any nonpayment related to any collateral, or notice of any action or nonaetfon on the part of Borrower, Lender, any surely, endorser, or other guarantor in connection with the Indebtedness or in connection with the creation of new or additional loans or obligations; (c) to resort for payment or to proceed directly or at once against any person, Including Borrower or any other guarantor; (d) to proceed directly against or exhaust any collateral held by Lender from Borrower, any other guarantor, or any other person; (e) to give notice of the terms, time, and place of any public or private sale of personal property security held by Lender from Borrower or to comply with any other applicable provisions of the Uniform Commercial Code; (1) to pursue any other remedy within Lender's power; or (g) to Commit any act or omission of any kind, or at any time, with respect to any matter whatsoever. If now or hereafter (a) Borrower shall be or become Insolvent, and (b) the Indebtedness shag not at all times until. paid be fully secured by collateral pledged by Borrower, Guarantor hereby forever waives and relinquishes in favor of Lender and Borrower, and their respective successors, any claim or right to payment Guarantor may now have or hereafter have or acquire against Borrower, by subrogation or otherwise, so that at no time shag Guarantor be or become a 'creditor' of Borrower within the meaning of 1 t 'U.S.C. section 647(b), or any successor provision of the Federal bankruptcy laws. Guarantor also waives any and all rights or defenses arising by reason of (a) any "one action" or 'anil-deficiency" law or any other law which may prevent Lender from bringing any action, including a claim for deficiency, against Guarantor, before or after Lender's commencement or completion of any foreclosure action, either judicially or by exercise of a power of sale; (b) any election of remedleS by Lender which destroys or otherwise adversely affects Guarantor's subrogation rights or Guarantor's rights to proceed against Borrower for reimbursement, including without limitation, any loss of rights Guarantor may suffer by reason of any law limiting, qualifying, or discharging the Indebtedness; (c) any disability or other defense of Borrower, of any other guarantor, or of any other person, or by reason of the cessation of Borrowers liability from any cause whatsoever, other than payment In full in legal tender, of the Indebtedness; (d) any right to claim discharge of the Indebtedness on the basis of unjustified Impairment of any collateral for the Indebtedness; (e) any statute of limitations, 11 at any time any action or suit brought by Lender against Guarantor is commenced there is outstanding Indebtedness of Borrower to Lender which is not barred by any applicable statute of limitations; or (0 any defenses given to guarantors at law or In equity other than actual payment and performance of the indebtedness. if payment Is made by Borrower, whether voluntarily or otherwise, or by any third party, on the Indebtedness and thereafter Lender is forced 10 remit the ainount of that payment to Borrower's trustee In bankruptcy or to any similar person under any federal or state bankruptcy law or law for the relief of debtors, the Indebtedness shall be considered unpaid for. the purpose of enforcement of this Guaranty. Guarantor further waives and agrees not to assert or Claim at any time any deductions to the amount guaranteed under this Guaranty for any claim of setoff, counterclaim, counter demand, recoupment or similar right, whether such claim, demand or right may be asserted by the Borrower, the Guarantor, or both. GUARANTOR'S UNDERSTANDING WITH RESPECT TO WAIVERS. Guarantor warrants and agrees that each of the waivers sat forth above Is made with Guarantor's full knowledge of its significance and consequences and that, under the circumstances, the waivers are reasonable and not contrary to public policy or law. If any such waiver is determined to be contrary do any applicable law or public policy, such waiver shall be effective only to the extent permlded by law or public policy. LENDER'S RIGHT OF SETOFF. In addition to all liens upon and rights of setoff against the moneys, securities or other property of Guarantor given to Lender by law, Lender shall have, with respect to Guarantors obligations to Lender under this Guaranty and to the extent permitted by law, a contractual security interest in and a right of setoff against, and Guarantor hereby assigns, convoys, delivers, pledges, and transfers to Lender all of Guarantor's right, title and interest In and to, all deposits, moneys, securities and other property of Guarantor now or,hereafier in the pOSSession of or on deposit with Lender, whether held in a general or special account or deposit, whether held jointly with someone also, or whether held for safekeeping or otherwise, excluding however all IRA, Keogh, and trust accounts. Every such Security interest and right of setoff may be exercised without demand upon or notice to Guarantor. No security interest or right of setoff shall be doomed to have been waived by any act or conduct on the part of Lender or by any neglect to exercise such right of setoff of to enforce such Security interest or by any delay In So doing. Every right of setoff and security interest shall continue In full force and effect until such right of setoff or security interest Is specifically waived or released by an instrument in writing executed by Lender. SUBORDINATION OF BORROWER'S DEBTS TO GUARANTOR. Guarantor agrees that the Indebtedness Of Borrower to Lander, whether now existing or hereafter created, Shall be prior to any claim that Guarantor may now have or hereafter acquire against Borrower, whether or not Borrower becomes Insolvent. Guarantor hereby expressly subordinates any claim Guarantor may have against Borrower, upon any account whatsoever, to any claim that Lender may now or hereafter have against Borrower. In the event of Insolvency and consequent Ilquidation of the assets of Borrower, through bankruptcy, by an assignment for the benefit of creditors, by voluntary liquidation, or otherwise, the assets of Borrower applicable to the payment of the claims of both Lender and Guarantor shall be paid to Lender and shall be first applied by Lender to the Indebtedness of Borrower to Lender. Guarantor does hereby assign to Lender all claims which it may have or acquire against Borrower or against any assignee or trustee in bankruptcy of Borrower; provided however, that Such assignment Shall be effective only tot the purpose of assuring to Lender full payment in legal tender of the Indebtedness. It Lender so requests, any notes or credit agreements now or hereafter evidencing any debts or obligations of Borrower to Guarantor Shall be marked with a legend that the same are subject to this Guaranty and shall be delivered to Lender. Guarantor agrees, and Lender hereby is authorized, In the name of Guarantor, from time to time to execute and file financing statements and continuation statements and to execute such other documents and to take such other actions as Lender deems necessary or appropriate to perfect, preserve and enforce Its rights under this Guaranty. MISCELLANEOUS PROVISIONS. The following miscellaneous provisions are a part of this Guaranty: Amendments. This Guaranty, togr•"r with any Related Documents, constitutes the entire derstanding and agreement of the parties as to the matters sat forth In this Guaranty. Iteration of or amendment to this Guaranty shall be :ive unless given in wrlfing and signed by the party or parties sought to be charged Or L and by the alteratlOn or amendment. MA'Y-24-2007 11:05 COMMERCIAL LOAN DOCUMENTA 7177354754 P.007 01-26-1999 COMMERCIAL GUARANTN Page 3 Loan No 64000102 (Continued) Applicable Law. This Guaranty has been delivered to Lender and accepted by Lender in the Commonwealth of Pennsylvania. If there is a lawsuit, Guarantor agrees upon Lender's request to submit to the jurisdiction of the courts of Cumberland County, Commonwealth of Pennsylvania. This Guaranty Shall be governed by and construed In accordance with the laws of the Commonwealth of Pennsylvania. Attorneys' Fees; Expenses. Guarantor agrees to pay upon domand all of Lenders costs and expenses, including attorneys' fees and Lenders legal expenses, incurred in connection with the enforcement of this Guaranty. Lender may pay someone else to help enforce this Guaranty, and Guarantor shall pay the costs and expenses of such enforcement. Costs and expenses Include Lender's attorneys' fees and legal expenses whether or not there is a lawsuit, including attorneys' fees and legal expenses for bankruptcy proceedings (and including efforts to modify or vacate any automatic stay or injunction), appeals, and any anticipated posHudgment collection services. Guarantor also shall pay all court costs and such additional fees as may be directed by the court. Notices. All notices required to be given by either party to the other under this Guaranty shall be In writing, may be sent by telefacsimile (unless otherwise required by law), and shall be effective when actually delivered or when deposited with a nationally recognized overnight courier, or when deposited In the United States mail, first class postage prepaid, addressed to the party to whom the notice is to be given at the address shown above or to such other addresses'as either party may designate to the other in writing. If there is more than one Guarantor, notice to any Guarantor will constitute notice to all Guarantors. For notice purposes, Guarantor agrees to keep Lender informed at all times of Guarantor's current address. Interpretation. In all cases where there is more than one Borrower or Guarantor, then all words used In this Guaranty In the singular shall be deemed to have been used In the plural where the context and construction so require; and where there Is more than one Borrower named in this Guaranty or when this Guaranty is executed by more than one Guarantor, the words "Borrower" and "Guarantor" respectively Shan mean all and any one or more of them. The words "Guarantor," "Borrower," and "Lender" include the heirs, successors, assigns, and transferees of each of them. Caption headings in this Guaranty are for convenionce purposes only and are not to be used to interpret or define the provisions of this Guaranty. If a court of competent jurisdiction finds any provision of this Guaranty to be invalid or unenforceable as to any person or circumstance, such finding Shall not render that provision invalid or unenforceable as to any other persons or circumstances, and all provisions of this Guaranty in all other respects shall remain valid and enforceable. If any one or more of Borrower or Guarantor are corporations or partnerships, it IS not necessary for Lender to inquire into the powers of Borrower or Guarantor or of the officers, directors, partners, or agents acting or purporting to act on their behalf, and any Indebtedness made or created in reliance upon the professed exercise of such powers shall be guaranteed undor.this Guaranty. Waiver. Lender shall not be deemed to have waived any rights under this Guaranty unless such waiver Is given In writing and signed by Lender. No delay or omission on the part of Lender in exercising any right shall operate as a waiver of such right or any other right. A waiver by Lander of a provision of this Guaranty shall not prejudice or constitute a waiver of Lender's right otherwise to demand strict compliance with that provision or any other provision of this Guaranty. No prior waiver by Lender, nor any course of dealing between Lender and Guarantor, shall constitute a waiver of any of Lenders rights or of any of Guarantor's obligations as to any future transacilons. Whenever the consent of Lender IS required under this Guaranty, the granting of such consent by-Lander in any Instance shall not constitute continuing consent to subsequent instances where such consent is required and in all cases such consent may be granted or withheld in the sole discretion of Lender. DEFAULT INTEREST RATE. In the event of default for which Lender does not accelerate the Loan, Including the failure of Borrower to provide the financial statements as required hereunder or under the Loan Agreement, the applicable Interest rate on the Loan, for a period beginning three (3) days after written notice of such default and ending upon the curing of said noticed default, shall increase one quarter of one percent (•2596) for the first thirty (30) days of sald default and increase an additional one quarter (.2596) during each thirty (30) day period thereafter during which the notice default continues. Such default interest rates shall apply to the outstanding principal balance of the Loan. Upon the outing of the noticed default, the interest rate on the Loan shalt revert to the initially agreed-upon Interest rote effective on the date on which the default Is cured. FINANCIAL STATEMENTS. Furnish Lender with, as soon as available, but in no event later than one hundred twenty (120) days after the end of each fiscal year. Guarantor's personal financlal statement and federal income tax return. AN financial reports required to-be provided under this Agreement shall be prepared in accordance with generally accepted accounting principles, applied on consistent basis, and certified by Guarantor as being true and correct. CONFESSION OF JUDGMENT. GUARANTOR HEREBY IRREVOCABLY AUTHORIZES AND EMPOWERS ANY ATTORNEY OR THE PROTHONOTARY OR CLERK OF ANY COURT IN THE COMMONWEALTH OF PENNSYLVANIA, OR ELSEWHERE, TO APPEAR AT ANY TIME FOR GUARANTOR AFTER A DEFAULT UNDER THIS GUARANTY, AND WITH OR WITHOUT COMPLAINT FILED, AS OF ANY TERM, CONFESS OR ENTER JUDGMENT AGAINST GUARANTOR FOR THE ENTIRE PRINCIPAL BALANCE OF THIS GUARANTY, ALL- ACCRUED INTEREST, LATE CHARLES, AND ANY AND ALL AMOUNTS EXPENDED OR ADVANCED BY LENDER RELATING TO ANY COLLATERAL SECURING THE INDEBTEDNESS TOGETHER WITH INTEREST ON SUCH AMOUNTS, TOGETHER WITH COSTS OF SUIT, AND AN ATTORNEY'S COMMISSION OF TEN PERCENT (10%) OF THE UNPAID PRINCIPAL BALANCE AND ACCRUED INTEREST FOR COLLECTION, BUT IN ANY EVENT NOT LESS THAN FIVE HUNDRED DOLLARS ($500) ON WHICH JUDGMENT OR JUDGMENTS ONE OR MORE EXECUTIONS MAY ISSUE IMMEDIATELY; AND FOR SO DOING, THIS GUARANTY OR A COPY OF THIS GUARANTY VERIFIED BY AFFIDAVIT SHALL BE SUFFICIENT WARRANT. THE AUTHORITY GRANTED IN THIS GUARANTY TO CONFESS JUDGMENT AGAINST GUARANTOR SHALL NOT BE EXHAUSTED BY ANY EXERCISE OF THAT AUTHORITY, BUT SHALL CONTINUE FROM TIME TO TIME AND AT ALL TIMES UNTIL PAYMENT IN FULL OF ALL AMOUNTS DUE UNDER THIS GUARANTY. GUARANTOR HEREBY WAIVES ANY RIGHT GUARANTOR MAY HAVE TO NOTICE OR TO A HEARING IN CONNECTION WITH ANY SUCH CONFESSION OF JUDGMENT, EXCEPT ANY NOTICE AND/OR HEARING REQUIRED UNDER APPLICABLE LAW WITH RESPECT TO EXECUTION OF THE JUDGMENT, AND STATES THAT EITHER A REPRESENTATIVE OF LENDER SPECIFICALLY CALLED THIS CONFESSION OF JUDGMENT PROVISION TO GUARANTOR'S ATTENTION OR GUARANTOR HAS BEEN REPRESENTED BY INDEPENDENT LEGAL COUNSEL. EACH UNDERSIGNED GUARANTOR ACKNOWLEDGES HAVING READ ALL THE PROVISIONS OF THIS GUARANTY AND AGREES TO ITS TERMS. IN ADDITION, EACH GUARANTOR. UNDERSTANDS THAT THIS GUARANTY IS EFFECTIVE-UPON GUARANTOR'S EXECUTION AMD DELIVERY OF THIS GUARANTY TO LENDER AND THAT THE GUARANTY WILL CONTINUE UNTIL TERMINATED IN THE MANNER SET FORTH IN THE SECTION TITLED "DURATION OF GUARANTY." NO FORMAL ACCEPTANCE BY LENDER IS NECESSARY TO MAKE THIS GUARANTY EFFECTIVE. THIS GUARANTY IS DATED JANUARY 26, 1999. THIS GUARANTY HAS SEEN SIGNED AND SEALED BY THE UNDERSIGNED. GUARANTO a.:.. vim... ::x?::: °;,........ ,,:.,.,.... ..:........„....:?:;:::.. `??t .:?:•:::-::?; eggett Metlssa M. Leggett MAY-24-2007 11:06 COMMERCIAL LOAN DOCUMENTA 7177354764 P.006 Loan No 64000102 (Continued) STATE OF (1?11AOL-- COUNTY OF INDIVIDUAL ACKNOWLEDGMENT ) rbs On this, the day 1efore me theundersigned Notary Public, personally red D 8Legassa M. Leggett, kn tom (a satlsfa7ctoort van) t t he person whose names are subscribed to the wi In instrurne nd acknowledged that they executed the same for te purposes n coot ' d. In witness whereof, f hereunto set my hand and offleial seal. l Notary Public In and for the State of Lnacn rnu. Meg u,5. 1-At. A T.M. Off.. Ver. o-M (c)1999 CFI ProSwvlces, Inc. Ali rlghto reAerved. (PA-EZO 5PANKEYf.(.N R5.OVL.) Notarial Sea) Ueda H. Ztater, Notary Public SusquahanndTWp., Dauphin County My Commission Expires Sept. 23, 2002 MAY-24-2007 11:04 COMMERCIAL LOAN DOCUMENTA 7177354764 DISCM..JRE FOR CONFESSION OF :,JOGMENT Guarantor: Donald B. Leggett and Melissa M. Leggett ISO E. Lauer Lane Camp Hit, PA 17011 P.004 DISCLOSURE FOR CONFESSION OF JUDGMENT I AM EXECUTING, THIS 21,- -DAY OF VA_j , 19_?L, A GUARANTY OF A, PROMISSORY NOTE FOR $1,100,000.00 OBLIGATING ME TO REPAY THAT AMOUN . A. 1 UNDERSTAND THAT THE GUARANTY CONTAINS A CONFESSION OF JUDGMENT PROVISION THAT WOULD PERMIT LENDER TO ENTER JUDGMENT AGAINST ME IN COURT, AFTER A DEFAULT ON THE GUARANTY, WITHOUT ADVANCE NOTICE TO ME AND WITHOUT OFFERING ME AN OPPORTUNITY TO DEFEND AGAINST THE ENTRY OF JUDGMENT. IN EXECUTING THE GUARANTY, BEING FULLY AWARE OF MY RIGHTS TO ADVANCE NOTICE AND TO A HEARING TO CONTEST THE VALIDITY OF ANY JUDGMENT OR OTHER CLAIMS THAT LENDER MAY ASSERT AGAINST ME UNDER THE GUARANTY, 1 AM KNOWINGLY, INTELLIGENTLY, AND VOLUNTARILY WAIVING THESE RIGHTS, INCLUDING ANY RIGHT TO ADVANCE NOTICE OF THE ENTRY OF JUDGMENT, AND I EXPRESSLY AGREE AND CONSENT TO LENDERS ENTERIN GHENT AINST ME BY CONFESSION AS PROVIDED FOR IN THE CONFESSION OF JUDGMENT PROVISION. INITIALS::«1/7l 8. 1 FURTHER UNDERSTAND THAT IN ADDITION TO GIVING LENDER THE RIGHT TO ENTER JUDGMENT AGAINST ME WITHOUT ADVANCE NOTICE OR A HEARING, THE CONFESSION OF JUDGMENT PROVISION IN THE GUARANTY ALSO CONTAINS LANGUAGE THAT WOULD PERMIT LENDER, AFTER ENTRY OF JUDGMENT, TO EXECUTE ON THE JUDGMENT BY FORECLOSING UPON, ATTACHING; LEVYING ON, TAKING POSSESSION OF OR OTHERWISE SEIZING MY PROPERTY, IN FULL OR PARTIAL PAYMENT OF THE JUDGMENT. HOWEVER, LENDER MUST PROVIDE NOTICE TO ME UNDER APPLICABLE LAW IN EXECUTING ANY CONFESSED JUDGMENT. IN EXECUTING THE GUARANTY, BEING FULLY AWARE OF MY RIGHTS TO ADVANCE NOTICE AND A HEARING AFTER JUDGMENT IS ENTERED AND BEFORE EXECUTION ON THE JUDGMENT, 1 AM KNOWINGLY, INTELLIGENTLY AND VOLUNTARILY WAIVING THESE RIGHTS, AND 1 EXPRESSLY AGREE AND CONSENT TO LEND 'S EX CUTING ON THE JUDGMENT, IN ANY MANNER PERMITTED BY APPLICABLE STATE AND FEDERAL LAW. INITIALS: C. AFTER HAVING READ AND DETERMINED WHICH OF THE FOLLOWING STATEMENTS ARE APPLICABLE, AND BY PLACING MY INITIALS NEXT TO EACH STATEMENT WHICH APPLIES, 1 REPRESENT THAT: INITIALS ' 001, 1. 1 WAS REPRESENTED BY MY OWN INDEPENDENT LEGAL COUNSEL IN CONNECTION WITH THE GUARANTY. 2. A REPRESENTATIVE OF LENDER SPECIFICALLY CALLED THE CONFESSION OF JUDGMENT PROVISION IN THE GUARANTY TO MY ATTENTION. D. I CERTIFY THAT MY ANNUAL INCOME EXCEEDS 510,000; THAT THE BLANKS IN THIS DISCLOSURE WERE FILLED IN WHEN 1 INITIALED AND SIGNED IT; AND THAT I RECEIVED A COPY AT THE TIME OF SIGNING. THIS DISCLOSURE HAS BEEN SIGNED AND SEALED BY THE UNDERSIGNED. AFFIANT: B. M. Leggett (SEAL) LASER PHO, Rep. U.S. PAL. S T.M. Off., Ver. 3.26&(c) I$N CFI Pr0SOrV1ces, Inc. j PANKEYB.LN NS.OVL) Borrower: Spankey's Auto Sales, A Pennsylvania Business Lender, PENNSYLVANIA STATE BANK Trust Cumberland Parkway Donald B. Legged, Trustee 91 Cumberland Parkway 701 E. Locust Street Mechanicsburg, PA 17055 Mechanicsburg, PA 17055 ?: - : 7- F ? .v^'r .frt Tyr:'" s ?,I f1 '` 3 de Programs Irx:ury Screens - 4 ,.- No*Inquiry Next Display C'g Basic NOte Data Maintainable. Field Note number 04 080182 a0 G 01 Short name Si'R1 WYG- RUTSskE MEMOAGTNE M. Customer Data Balance Data- ---- --- ..?...« q%WEY'S AUTO SALES Note amount 1,180, ],08 3T R Pe#GYL'VRNIR BUSINESS TRUST Principal balance 630,643.13 1? 1M11 U B LEGGET I TRUSTEE Interest balance 2 285 81 281 E LQCt1ST ST , , tt£CWCSM ?R 17055 P/0 5-25-87 632,928.14 Avail for disb M Gontaci{Title Interast Data Tax ID 23.2131896 Int rate P+ 1.0000 8 5:7588 Home phone 717-737-7777 Deily intfactor 99.347890 Business phone 717-737-7777 Interest paid 1rTD 15,578.74 Officer 2747 Dates Next Payment Data Note date- 1-26-99 Next due date 6-01-07 Last renewed Next pmt amount 9,333.11 Maturity date 2-01-14 Total past due arnt .00 Lest active 5-82-07 - Sold Data Last paidinstsPme^t 5-81-87 Percentage` sold Q0w interest paid-to date 5-02-07 To l s ta old 00 f 5f25/2007 ?.QPR6EV003F LMBROOME ' (3546) 58-8705-2 ?? 4:05;2 PPM ERIFICATION I, DAVID W. PREVOST, Vice-President/Special Assets Officer, of PENNSYLVANIA STATE BANK, Division of BLC BANK, N.A., verify that the statements made in the aforegoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904, relating to unsworn falsification to authorities. PENNSYLVANIA STATE BANK, Division of BLC B K, N.A. kCCfkV1 R David W. Prevost Vice-President/Special Assets Officer Dated: '? Q7 O '}y v rv 0 W W q V PENNSYLVANIA STATE BANK, IN THE COURT OF COMMON PLEAS Division of BLC BANK, N.A. CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO. 07-?a3? l:Cuc l,, / DONALD B. LEGGETT and MELISSA : CIVIL DIVISION - LAW M.LEGGETT Defendants : CONFESSED JUDGMENT PLAINTIFF'S AFFIDAVIT/AVERMENT CONFESSION OF JUDGMENT FOR MONEY (x) Pursuant to Pa. R.C.P. No. 2951(1)(2)(ii), I certify that this judgment is not being entered by confession against a natural person in connection with a consumer credit transaction. (a) A consumer credit transaction means a credit transaction in which the party to whom credit is offered or extended is a natural person and the money, property or services which are the subject of the transaction are primarily for personal, family or household purposes. CONFESSION OF JUDGMENT FOR CONFESSION OF REAL PROPERTY () Pursuant to Pa. R.C.P. No. 2971(1)(1), I certify that this judgment is not being entered against a natural person in connection with a residential lease. ??????????????? The above certification is made subject to the penalties of 18 Pa. § 4 r lating to unsworn falsification to authorities. Dated:_ May 25, 2007 Robert D. Kodak, Esquire Attorney for Plaintiff I.D. No. 18041 Address: Kodak & Imblum, P.C. 407 North Front Street Post Office Box 11848 Harrisburg, PA 17108-1848 (717) 238-7152 Fax: (717) 238-7158 n = c -V LLI o -4 O D C" N W PENNSYLVANIA STATE BANK, Division of BLC BANK, N.A. Plaintiff V. DONALD B. LEGGETT and MELISSA M. LEGGETT Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. : CIVIL DIVISION - LAW CONFESSED JUDGMENT NOTICE UNDER RULE 2958.1 OF JUDGMENT AND EXECUTION THEREON NOTICE OF DEFENDANT'S RIGHTS TO: DONALD B. LEGGETT, DEFENDANT A Judgment in the amount of $696,220.95 has been entered against you and in favor of Plaintiff without a prior notice or hearing based on a Confession of Judgment contained in a written agreement or other paper allegedly signed by you. The Sheriff may take your money or other property to pay the Judgment at any time after thirty (30) days after the date on which this notice is served on you. You may have legal rights to defeat the Judgment or to prevent your money or property from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NOT FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 ROBERT D. KODAK, ESQUIRE POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 (717) 238-7152 ATTORNEY FOR PLAINTIFF AM C; 5 „?: W ^gf7T --t W m K EV ?C7 PENNSYLVANIA STATE BANK, Division of BLC BANK, N.A. Plaintiff V. DONALD B. LEGGETT and MELISSA M.LEGGETT Defendants TO: DONALD B. LEGGETT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 67^ 3ZI.Z CIVIL DIVISION - LAW : CONFESSED JUDGMENT You are hereby notified that on , 2007, Judgment by confession was entered against you in the sum of $696,220.95 in the above-captioned case. n DATE:_1?Y 2007 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YdU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. I hereby certify that the following is the address of the Defendant(s) stated in the Certificate of Residence: 150 EAST LAUER LANE CAMP HILL PA 17011 Robert D. Kodak, Attorney for Plaintiff CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 N 0 a J CAJ O w N PENNSYLVANIA STATE BANK, Division of BLC BANK, N.A. Plaintiff V. DONALD B. LEGGETT and MELISSA M.LEGGETT Defendants IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL DIVISION - LAW : CONFESSED JUDGMENT NOTICE UNDER RULE 2958.1 OF JUDGMENT AND EXECUTION THEREON NOTICE OF DEFENDANT'S RIGHTS TO: MELISSA M. LEGGETT, DEFENDANT A Judgment in the amount of $696,220.95 has been entered against you and in favor of Plaintiff without a prior notice or hearing based on a Confession of Judgment contained in a written agreement or other paper allegedly signed by you. The Sheriff may take your money or other property to pay the Judgment at any time after thirty (30) days after the date on which this notice is served on you. You may have legal rights to defeat the Judgment or to prevent your money or property from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NOT FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 ROBERT D. KODAK, ESQUIRE POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 (717) 238-7152 ATTORNEY FOR PLAINTIFF ? C= rY: C 1 v co PENNSYLVANIA STATE BANK, Division of BLC BANK, N.A. Plaintiff V. DONALD B. LEGGETT and MELISSA : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-2.2.3.2 l.lc Z(c7;ri 41 : CIVIL DIVISION - LAW M.LEGGETT Defendants : CONFESSED JUDGMENT TO: MELISSA M. LEGGETT, Defendant You are hereby notified that on /LSv )e) , 2007, Judgment by confession was entered against you in the sum of $696,220.95 in the above-cap 'oned case. DATE: .2007 Prot onotary YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. I hereby certify that the following is the address of the Defendant(s) stated in the Certificate of Residence: 150 EAST LAUER LANE CAMP HILL PA 17011 s Robert D. Kodak, Attorney for Plaintiff CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 = M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PENNSYLVANIA STATE BANK, NO. 2007-3232 Division of BLC BANK, N.A., now by merger PNC BANK, NATIONAL ASSOCIATION, Plaintiff V. zz?t, DONALD B. LEGGETT and MELISSA M., S LEGGETT Defendants CIVIL ACTION LAW - Q PARTIAL RELEASE OF JUDGMENT LIEN WHEREAS, on May 30, 2007, Judgment was entered in favor of Plaintiff and against Defendants in the Court of Common Pleas of Cumberland County at No. 2007-3232; and WHEREAS, Defendants own an interest in that certain real property known as 1115 County Club Road, East Pennsboro Township, Cumberland County, Pennsylvania, as more particularly described on Exhibit "A" attached hereto and made a part hereof (the "Property"); and WHEREAS, the Defendants have requested the Plaintiff to release the Property from the lien of the Judgment, which Property constitutes a portion, but not all, of the Property that is subject to the lien of the Judgment. NOW, THEREFORE, for good and valuable consideration, the receipt of which is hereby acknowledged, and intending to be legally bound, Plaintiff, PNC Bank, National Association, for itself and its successors and assigns, agrees that it will not attach or levy upon, sell or dispose of, or claim or demand the Property as a result of the Judgment, and further releases the lien of the Judgment only on the Property; provided, however, that neither this Partial Release nor anything herein contained invalidates, diminishes, alters, or otherwise affects the Judgment or the lien or security of the Judgment upon or against any other property of Defendants or either of them in Cumberland County, Pennsylvania, or elsewhere; and provided further that neither this Partial Release nor anything contained herein is or should be construed to be or to evidence satisfaction or discharge of the debt of the Defendants to the Plaintiff, PNC Bank, National Association. #llo.oo PP PLFF Ce Sgaq 0 aylsa7 IN WITNESS WHEREOF, the Undersigned executed this Partial Release this day of February, 2010. PNC BANK, NATIONAL ASSOCIATION By: Brett A. Bertoli Assistant Vice President COMMONWEALTH OF PENNSYLVANIA COUNTY OF SS.. On this, the 1 day of February, 2010, before me, the undersigned officer, personally appeared Brett A. Bertoli, who acknowledged himself to be the Assistant Vice President of PNC Bank, National Association, who being authorized to do so, executed the foregoing instrument for the purposes therein contained as such officer. IN WITNESS WHEREOF, I hereunto set my hand and notarial seal the day and year aforesaid. " No ary Public My Commission Expires: 0/ ik . 01 EXHIBIT "A" The property known as 1115 Country Club Road, identified as Tax Parcel No. 09-16-1054-125, located in East Pennsboro Township, Cumberland County, Pennsylvania. BEING THE SAME PREMISES which were granted and conveyed to Donald B. Leggett, Mortgagor herein, by Deed dated November 30, 2004, and recorded in the Office of the Recorder of Deeds for Cumberland County, Pennsylvania, on December 6, 2004, in Record Book 266, page 2902. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PENNSYLVANIA STATE BANK, Division of BLC BANK, N.A., now by merger PNC BANK, NATIONAL ASSOCIATION, Plaintiff V. DONALD B. LEGGETT and MELISSA M. LEGGETT, Defendants NO. 2007-3232 Z5 r . w -n C 9? 0 CIVIL ACTION - LAW' PARTIAL RELEASE OF JUDGMENT LIEN WHEREAS. on May 30, 2007, Judgment was entered in favor of Plaintiff and against Defendants in the Court of Common Pleas of Cumberland County at No. 2007-3232; and WHEREAS. Defendants own an interest in that certain real property known as 150 East Lauer Lane, East Hampden Township, Cumberland County, Pennsylvania, as more particularly described. on Exhibit "A" attached hereto and made a part hereof (the "Property"). and WHEREAS, the Defendants have requested the Plaintiff to release the Property from the lien of the Judgment, which Property constitutes a portion, but not all, of the Property that is subject to the lien of the Judgment. NOW, THEREFORE, for good and valuable consideration, the receipt of which is hereby acknowledged, and intending to be legally bound, Plaintiff, PNC Bank, National Association, f'or itself and its successors and assigns, agrees that it will not attach or levy upon, sell or dispose of, or claim or demand the Property as a result of the Judgment, and further releases the lien of the Judgment only on the Property; provided, however, that neither this Partial Release nor anything herein contained invalidates, diminishes, alters, or otherwise affects the Judgment or the lien or security of the Judgment upon or against any other property of Defendants or either of them in Cumberland County, Pennsylvania, or elsewhere; and provided further that neither this Partial Release nor anything contained herein is or should be construed to be or to evidence satisfaction or discharge of the debt of the Defendants to the Plaintiff, PNC Bank, National Association. X8.00 NO ATM e* 19 -115570 0,2 L1 7qSI IN WITNESS WHEREOF, the Undersigned executed this Partial Release this 19 day of August, 2010. PNC BANK, NATIONAL ASSOCIATION By: ?-" Brett A. Bertoli Vice President COMMONWEALTH OF PENNSYLVANIA COUNTY OF 2(Z-0 6C.c? K - SS.: On this, the ) ? day of August, 2010, before me, the undersigned officer, personally appeared Brett A. Bertoli, who acknowledged himself to be the Vice President of PNC Bank, National Association, who being authorized to do so, executed the foregoing instrument for the purposes therein contained as such officer. IN WITNESS WHEREOF, I hereunto set my hand and notarial seal the day and year aforesaid.. Notary Public My Commission Expires: C1 111110,0,0- COMMONWEALTH UF° PENNSYLVANIA Nota,ial Seal Connie Birder, Notary Public Manheim Twp., Lancaster County My Commission Expires Jan. 31, 2012 9 Member. Pennsylvania Association of Notaries EXHIBIT "A" ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden. County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the western line of East Lauer Lane at the dividing line between Lots Nos. 106 and 107 as shown on the hereinafter mentioned Plan of Lots; thence along said dividing Line North 64 degrees 1 minute West 167.36 feet to a point; thence along other land now or late of Kurvin. W. Lauer and Eva S. Lauer, his wife, North 14 degrees 35 minutes West 56.60 feet to a point; thence along other land now or late of Lauer, North 70 degrees 20 minutes East 150 feet to East Lauer Lane; thence along the western line of East Lauer Lane South 19 degrees 40 minutes East 110.82 feet to a point; thence continuing along the same in a southwesterly direction on a curve to the right having a radius of 75 feet, an ac distance of 79.15 feet to the place of BEGINNING. BEING Lots No. 106, Plan of Section 4, Point Ridge farms, said plan being recorded in the Cumberland County Recorder's Office in Plan Book 15, Page 38. Tax Parcel No. 10-19-1598-033.