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HomeMy WebLinkAbout08-2109IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LEAF FUNDING, INC. 2005 Market Street, 15th Floor Philadelphia, Pennsylvania 19103 Plaintiff, V. No. 0$- alo9 l.?lvi ( Term VILLAGECRAFT FACTORY DIRECT, INC. 1446 Holly Pike Carlisle, Pennsylvania 17013 : and VILLAGECRAFT CONTRACT FURNISHINGS, L.P. 1446 Holly Pike Carlisle, Pennsylvania 17013 and JERRY M. TROLINGER, JR. 2551 Spring Road : Carlisle, Pennsylvania 17013 Defendants. NOTICE TO DEFEND "You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the 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." 379861_1.DOC "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 REDUCED FEE OR NO FEE." LAWYER REFERRAL SERVICE CUMBERLAND COUNTY COURTHOUSE 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar action dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABODAGO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY COURTHOUSE 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 379861_1.DOC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LEAF FUNDING, INC. 2005 Market Street, 15'' Floor Philadelphia, Pennsylvania 19103 Plaintiff, : V. No. C P_ X109 VILLAGECRAFT FACTORY DIRECT, INC. 1446 Holly Pike Carlisle, Pennsylvania 17013 and VILLAGECRAFT CONTRACT FURNISHINGS, L.P. 1446 Holly Pike Carlisle, Pennsylvania 17013 : and JERRY M. TROLINGER, JR. 2551 Spring Road Carlisle, Pennsylvania 17013 Defendants. COMPLAINT Plaintiff, LEAF Funding, Inc., (hereinafter referred to as "LEAF" or "Plaintiff'), by and through its undersigned attorneys, Lamm Rubenstone LLC, brings this action against the above- named Defendants, Villagecraft Factory Direct, Inc., VillageCraft Contract Furnishings, L.P. and Jerry M. Trolinger, Jr., and in support thereof avers as follows: 379861 1.DOC 1. Plaintiff, LEAF, is a Delaware corporation, registered to conduct business in the Commonwealth of Pennsylvania, with a principal place of business located at 2005 Market Street, 15th Floor, Philadelphia, Pennsylvania 19103. 2. Defendant, Villagecraft Factory Direct, Inc. ("Villagecraft") is, upon information and belief, a Pennsylvania corporation whose last known address to LEAF is 1446 Holly Pike, Carlisle, Pennsylvania 17013. 3. Defendant, Villagecraft Contract Furnishing, L.P. ("Villagecraft LP") is, upon information and belief, a Limited Partnership whose last known address to LEAF is 1446 Holly Pike, Carlisle, Pennsylvania 17013. 4. Defendant, Jerry M. Trolinger, Jr., ("Trolinger") is, upon information and belief, an adult individual and officer of Villagecraft, whose last known address to LEAF is 2551 Spring Road, Carlisle, Pennsylvania 17013 5. On or about December 14, 2006, Villagecraft entered into a certain Master Lease Agreement ("Lease") with Direct Capital Corporation, which provided for the lease and hire of certain items of equipment as more particularly described therein ("Equipment"). A true and correct copy of the Lease is attached hereto, incorporated herein, and marked as Exhibit A. 6. The Lease requires Villagecraft to, inter alia, pay to Direct Capital Corporation a security deposit of $1,593.86, an advance rental payment of $1,593.86, a documentation fee of $550.00 and sixty (60) consecutive monthly payments of $1,593.86 each, commencing January 23, 2007 and on the 22nd day of each month thereafter, until the entire obligation of the Lease is paid in full. 7. On or about December 14, 2006, Trolinger made, executed and delivered to Direct Capital Corporation a Master Guaranty of Lease ("Individual Guaranty") wherein he, 379861 1.DOC inter alia, jointly and severally, and unconditionally personally guaranteed to Direct Capital Corporation, and any assignee of Direct Capital Corporation, the full and prompt payment of all rent to be paid by Villagecraft and the performance when due by Villagecraft of all terms, conditions, covenants and agreements of Villagecraft, irrespective of any invalidity or unenforceability thereof for the security therefore. See, Exhibit A - A true and correct copy of the Guaranty is contained within Exhibit A. 8. On or about December 14, 2006, Villagecraft LP made, executed and delivered to Direct Capital Corporation a Corporate Guaranty of Lease ("Corporate Guaranty") wherein it, inter alia, absolutely and unconditionally guaranteed to Direct Capital Corporation, and any assignee of Direct Capital Corporation, the full and prompt payment of all rent to be paid by Villagecraft and the performance when due by Villagecraft of all terms, conditions, covenants and agreements of Villagecraft, irrespective of any invalidity or unenforceability thereof for the security therefore. A true and correct copy of the Corporate Guaranty is attached hereto, incorporated herein, and marked as Exhibit B. 9. Thereafter, LEAF became the holder of all right, title and interest in and to the Lease and Equipment by virtue of assignment from Direct Capital Corporation. A true and correct copy of the Lease Portfolio Purchase Agreement is attached hereto, incorporated herein, and marked as Exhibit C. 10. Villagecraft breached the terms and conditions of the Lease, Villagecraft LP breached the terms and conditions of the Corporate Guaranty and Trolinger breached the terms and conditions of the Individual Guaranty, and each became in default thereof, by reason of their failure to make the monthly payments due under the Lease for September, 2007, and all subsequent monthly payments thereafter. 379861 1.DOC 11. As a result of the aforementioned defaults, LEAF exercised its right to declare the entire balance of the unpaid lease payments immediately due and payable. 12. Despite demand for payment, Villagecraft, Villagecraft LP and Trolinger have failed and refused to pay LEAF the accelerated balance due, or any portion thereof, in accordance with the terms and provisions of the Lease, Corporate Guaranty and Individual Guaranty. 13. In accordance with the terms and conditions of the Lease, Corporate Guaranty and Individual Guaranty, Villagecraft, Villagecraft LP and Trolinger are liable to LEAF for reasonable attorneys' fees, costs and expenses, presently in the amount of $2,000.00. 14. In accordance with the terms and conditions of the Lease, Corporate Guaranty and Individual Guaranty, Villagecraft, Villagecraft LP and Trolinger are obligated and liable to LEAF for the following: Remaining Lease Payments $86,068.44 Attorneys' Fees 2,000.00 Total $88,068.44 WHEREFORE, Plaintiff, LEAF Funding, Inc. demands judgment in its favor and against Defendants, VillageCraft Factory Direct, Inc., Villagecraft Contract Furnishings, L.P. and Jerry M. Trolinger, Jr. in the amount of $88,068.44, plus additional attorneys' fees as they accrue, costs of suit, interest, and such other relief as the Court deems just and proper. LAMM RUBENWQNE LL By: N " --, A ` Davi . DeFlece, Esquire ??? Attorney ID No. 207052 3600 Horizon Boulevard, Suite 200 Trevose, PA 19053 215-638-9330; 215-638-2867f Attorneys for Plaintiff 379861 1.DOC VERIFICATION James J. Grant, Vice President of LEAF Funding, Inc., being duly sworn according to law, verifies that he is a duly authorized representative of Plaintiff, LEAF Funding, Inc., and that he is authorized to make this Verification on behalf of Plaintiff; that the facts set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief; and that he understands that the foregoing statements are made subject to the penalties of 18 Pa.C.S.A. §4904 related to unsworn falsifications to authorities. By: LEAF_Villageeraft_Complaint (Cumberland) ?K?,i 6?tA 10. Loss and Damage. You shall at all times bear the entire risk of loss, theft damage, condemnation, governmental seizure or destruction of the Equipment from any cause whatsoever, and no such event shall relieve you of the obligation to pay rent or to comply with any other obligation under this Lease. In the event of damage to any part of the Equipment, You shall immediately either repair to good condition or replace with like equipment, in each can at Your expense. If We determine that any part of the Equipment is condemned, taken, lost, stolen, destroyed, seized by a governmental entity or damaged beyond repair, You shall, at our option: a) replace with like equipment in good repair, acceptable to Us, or b) on the next Rent payment date following such event, pay us the full remaining balance on this Lease, including the contract balance, discounted to present value at the annual rate of 4%, and the residual value of the Equipment, as determined pursuant to this Lease, plus any lax charges, advances for insurance or taxes, any fees or costs due. We shall retain any physical damage insurance proceeds arising out of a theft, loss or damage up to the full amount owed under this Lease. You will remain responsible fur any deficiency. 11. Collateral Protection; Insurance. You shall obtain and maintain insurance against loss, theft, damage or destruction of the Equipment in an amount not less than original cost of the Equipment for the duration of this Lease and comprehensive public liability insurance in amounts acceptable to us. These policies must name Us as 'loss payee' and additional insured'. You must provide us with proof of insurance satisfactory to Us at the time of signing this Lease, prior to each insurance renewal and within ten (10) days of the date of any written request to You for proof of iasunnee. You agree that if said property and/or liability insurance is not received by us, is cancelled or expires and is not replaced, we have the right, but not the obligation, to (a) enroll you in our property damage coverage program and bill you a property damage surcharge as a result of our increased administrative cost and credit risk or (b) secure insurance on the Equipment from a carrier of our choosing in such forts and amounts as we deem reasonable to protect our interest. You agree that, if we secure insurance on the Equipment, said insurance will not name you as an insured and may not fully protect your interests and you will pay us an insurance charge that will include a premium, which may be substantially higher than the premium that you would pay if placed indeperdentiy. You agree that, in addition to the premium, the fee will include an interest charge and administrative and processing fees, which will result in profit to us and our agents. You can cancel the insurance coverage fee and or property damage surcharge fee at any time by delivering the required proof of insurance to us. You agree to arbitrate any dispute regarding insurance under the flutes of the American Arbitration Association in Rockingham County, New Hampshire. This agreement to arbitrate applies to this paragraph only and not to any other term of this Lease. 12. Llens; Taxes. You shall keep the Equipment free and clear of all levies, liens, claims and encumbrances. You agree to pay monthly when due or at a frequency determined solely by all taxes including sales, use, and property taxes and any and all fines and penalties. You shall reimburse Us for all charges and taxes (local, state, and federal) which may now or hereafter be imposed upon the ownership, leasing, rental, sate, purchase, possession or use of the Equipment. The total amount due on Your monthly invoice may include sales and/or use taxes charged from time to time in compliance with the tax laws of the state in which the Equipment is located. You agree to pay Us a property tax administrative fee of $79 each year for each Lease. 13. Limited Prearranged Amendments; Specific Power of Attorney. You authorize Us to insert or correct information on this Lease. You grant Us a specific power of attorney for Us to use as follows: 1) We may sign and file on Your behalf any document we deem necessary to perfect or protect Our interest in the Equipment or pursuant to the Uniform Commercial Code ("UCC), and 2) We may negotiate and settle for our benefit all property damage claims and all liability claims involving us or the Equipment and may sign or endorse the Your name on any draft, check or instrument representing insurance proceeds covering the Equipment. 14. Grant of Security Interest and Perfection. This is a "true lease". You hereby grant us a first priority security interest in the Equipment and authorize Us and Our agents to file UCC Financing Statements or similar instruments recording such security interest (in case this is later determined not to be a "true lease"). You hereby grant us a security interest in all goods, inventory, equipment, accounts, accounts receivable, chattel paper, contract rights, general intangibles, investment property, securities entitlements, fixtures and other property, whenever located, now or hereafter belonging to you or in which you have an interest, and in all proceeds, insurance proceeds, substitutions, replacements, replacement parts, additions and accessions of to all of the foregoing (collectively, the "Collateral"). You authorize Us and our agents to file UCC Financing Statements or similar instruments to perfect such security interest. 15. Choice of Law; Consent to Jurisdiction; Venue. This Lease is governed exclusively by the laws of New Hampshire. You agree and consent to the exclusive jurisdiction and venue of any State or Federal Court in Rockingham County, New Hampshire. You consent to personal jurisdiction in such court. You waive any right to challenge the jurisdiction or venue for say reason. However, We may, in our sole discretion, elect to waive the venue requirement and sue in Your home state without waiving any other rights. YOU AGREE TO WANE ALL RIGHTS TO A JURY TRIAL. 16. Default and Remedies. A condition of default shall exist If (a) you fail to make any payment required pursuant to this Lease when due, (b) You fail to perform any obligation in this Lease or any other agreement with us, (c) any representation or warranty made by you is false, (d) a material adverse change (as determined by us) occurs in Your financial condition or We believe the prospect of payment or performance is impaired, (e) any insolvency, bankruptcy or other similar proceedings, (f) equipment condition or operation, delivery, defect in title, or seizure of the equipment (g)death of a personal guarantor or (h) You attempt or actually repudiate or revoke any agreement with Us ("Default'). If You am in Default, we, with or without notice to you, shall have the right to exercise any one or more of the following remedies, concurrently or separately, and without any election of remedies being deemed to have been made. We may (a) retain Your security deposit, (b) cancel any of our remaining obligations to You and declare all Your obligations to Us immediately due and payable, (c) sue for and recover from you any and all amounts due under this Lease, including the contract balance discounted to present value at the annual rate of 4%, late charges, advances, fees and interest on the same as may be provided for in this Lease, (d) enter upon Your premises and without any court order or other process of law and repossess and remove the Equipment and/or the Collateral, or render such unusable without removal, either with or without notice, provided that such action shall not terminate the Lease unless We notify You as such in writing, (e) require You to assemble and make the Equipment available to Us at a location determined by Us, (f) sell the Equipment or other Collateral to any party without notice to You at a private or public age, at which sale We may be the purchaser, (g) upon such terms and conditions as the we alone shall determine, re-lease the Equipment or other Collateral with or without notice to You to any third party, or (h) pursue oany other remedy available to us under any agreement, any applicable law or the UCC. You agree to pay all costs of collection including, but not limited to, costs of repossession, attorney's fees and expenses, actual court costs, and any other expenses associated with the collection efforts, including but not limited to repossession and remarketing costs, telephone charges and travel costs. You agree that we will not be responsible for paying You for any consequential or incidental damages resulting from or in connection with default by Us. You agree that Your rights and remedies are governed exclusively by this Lease and You waive Your rights under Article 2A of the UCC. You agree that any delay or failure to enforce Our rights does not prevent Us from enforcing any rights at a later time. We may use any of the remedies available under Article 2A of the UCC or any other law. If You fail to make any payment required by this Lease within 3 days of the due date, You shall pay Us a late charge of 15% of the amount due and You will pay Us interest on any delinquent amount due under this Lease from the dire date thereof until paid at the maximum rate of interest allowed by law. You will pay Us any actual expenses incurred by Us in collection efforts, including but not limited to telephone charges, travel expenses, all reasonable legal fees, costs and expenses incurred with or without action, suit or proceedings, in pursuit of Our rights under this Lease, at common law or otherwise. 17. Purchase Option; No more than 10 days after the end of the Rental Term of the Lease, provided you are not in Default, you may, after written notice to us 60 days prior to the end of the Rental Term set forth on the Schedule, purchase the Equipment according for fair market value, such term shall be defined as fair market replacement value, and shall be the cost of replacing the Equipment with new exact or similar equipment, but depreciated by the term of the Schedule. The amount of fair market value shall be initially determined by Us. If you disagree with our determination of fair market value, you have the right to pay for and appoint a personal property appraiser from the Credit Managers Association of New Hampshire to issue an opinion as to fair market value as defined by this Lease, and You must also pay for any personal property appraiser We select from the Credit Managers Association of New Hampshire, and those two appraisers may reach a final dollar amount for the fair market value of the Equipment. In the event You fail to exercise this right, then our initial determination of fair market value shall prevail in a court of law. Any purchase under either option shall be on an "as is, w here is" basis, with all faults and without representation by or warranty from Us. In the event You are unwilling or unable to exercise either purchase option, You must return the as W Equipment in good repair, ordinary wear and tear resulting from proper use thereof alone excepted, by delivering it, property packed and ready for shipment to such place may specify at your expense. If We do not receive such notice of intent to exercise the purchase option, the Lease shall automatically renew for successive one month periods and You must pay Us monthly rent at the amount set for on the Schedule until the Equipment is returned to Us. 18. Indemnity. You indemnify Us and our shareholders, directors, officers, employees, agents and assignees against any claims, actions, damages, fines, penalties, causes of action, suits or other legal proceedings or liabilities including all attorney fees, arising out of or connected with the ownership, acquisition, use, possession, operation, leasing, subleasing, financing or ells sition of this Lease or any Equipment, without limitation. Such indemnification shall survive the expiration, cancellation or terminati on of this Lease. You waive say ' pity you may have under any industrial insurance act, with regard to indemnification of us or any other person for any reason whatsoever: Lessee Initials: 19. Assignment: You may not assign, sell or otherwise transfer this Lease, the Equipment, possession of the Equip=A or its interests thereunder or enter into any sublease with reapeot to the Equipment We may assign without Your consent any and all of our rights, including our interests in the Equipment You recognize and hereby consent to any assignment by Us and shall not assert against arty assignee any defense, counterclaim ar setoff that you may have against Us or any other person. Any Assignee of Ours shall have all of Our rights but none of Our obligations. Subject to this paragraph, this Lease inures to the benefit of and is binding upon the heirs, devisees, personal representatives, survivors, successors in interest and permitted assigns of You and Us. 20. Mheellaseous: This Lease constitutes the entire agreement between the parties. No provisions may be modified or rescinded unless signed by Us in writing. Waiver of one provision in one instance shall not imply waiver in arty other instance. This Lease is intended to constitute a valid and enforceable legal instrument and no provision of this Lease that may be deemed unenforceable shall in any way invalidate any other provision or provisions hereof all of which shall remain in full force and effect 21. Notices: All notices or other communications hereunder shall be in writing, addressed to you at your address stated here or addressed to us at 155 Commerce Way, Portsmouth, NH 03801, Attention Customer Service or such other address as instructed by written notice. Service of all notices shall be deemed to have been given and to be effective when delivered personally, by a recognized overnight mail service, by fax or by U.S. mail. 22. Execution in Counterparts; Chattel Paper: This Lease may be executed in any number of counterparts and in each case such Counterparts shall constitute but one and thepame inst pruensidedho however, to the extent that a Schedule Constitutes chattel paper (as such tenn is defined in the UCC) no security interest in the Schedule may be Lease with our signatures possession of the originally exacted Schedule. For all other purposes, You and We intend and agree that a photocopy or fax copy of this on it shall be treated as an original and shall be deemed to be binding, genuine and authentic as an original signature document for all purposes, including all matters of evidence and the "best evidence" rules. LESSOR, "Us"M u " ACCEPTANCE DATED:-Z3 ?O LESSOR: ni~-t -nn.tsl ?.....eti SIGNATURE: (c7/B7a TITLE: A to "ve CUSTOMER/LESSEE, "You"/"Your" ACMIPT DATED: j CUSTOMER Vrtlag ra F dory sec t, I SIGNATURE: X Wx X" TITLE: Press n the Sflnle IDeatl -- - - - -------?- ••••••,•••• ••••°"•• "8` wuaca.. mg given to it in the above-referenced Master Lease Agreement unless otherwise defined herein. As additional inducement for Direct Capital (and our assignees, together "We", "Us", or "Lessor') to enter into this Lease, the undersigned ("You')jointly and severally, unconditionally personally guarantees that the Customer will make all payments and meet all obligations required under this Lease fully and promptly. You agree that We may maize other arrangements including compromise or settlement with the Customer and You waive all defenses and notice of those changes and will remain responsible for the payment and obligations of this Lease. If the Customer defaults, You will immediately pay in accordance with the default provision of the Lease all sums due under the terms of the Lease and will perform all obligations of the Lease. If it is necessary for us to proceed legally to enforce this guaranty, You expressly consent to the exclusive jurisdiction of New Hampshire and agree to pay all costs, including attorneys fees incurred in enforcement of this guaranty. It is not necessary for us to proceed first against the Customer or the Equipment before enforcing this guaranty or to notify You if the Customer is in default By signing this guaranty, You authorize us to obtain credit bureau reports on You. X CJ? name X rgnamro Print name of Guarantor Date X Signature Print name of Guarantor Date EQUIPMENT SCHEDULE NO. 6597 TO MASTER L S NO. 19633 Dated: _ --o Dl RECTCAPITAL C O R P O R A T 1 O N CUSTOMER: ('7.enee')CTou" "Your'): Villager-raft Factory Direct, Inc. CUSTOMER NAME (full, exact, legal name) 1446 Mount Holly Pike Carlisle PA 17013 7172497515 VillageCraft Factory Direct, Inc. 1446 Mount Holly Carlisle PA 17013 Pike BILLING NAME BILLING ADDRESS This Equipment Schedule incorporates the terms and conditions of the above-referenced Master Lease Agreement. Each capitalized term used herein shall have the same meaning given to it in the above-referenced Master Lease Agreement unless otherwise defined herein. Equipment Suppliers and Description: See Attached Exhibit A and Invoice(s) Equipment Location: 1446 Mount Holly Pike Carlisle, PA 17013 SOS) 60 Payments of $1,593.86 Amounts Paid: Rent Commencement Date: l (plus applicable taxes) $1,593.86 Security Deposit Rental Period is MONTHLY union otherwise IndicMd $1,593.86 Advance Rental Pmt. $550.00 Documentation Fee This Schedule shall commence upon our written acceptance. Your monthly Rent is set forth above and is due monthly in advance on the due date (such date established by us on our acceptance). LESSOR, "Us"/"Our" ACCEPTANU CUSTOMER/LESSEE, "You 'Your" CC PTANCE DATED: t I h., DATED: LESSOR: -Ilmxt Cap orporation CUSTOMER: Vi Fac D' ry t; InA SIGNATURE: SIGNATURE: X ' TITLE: orize epresentative TITLE: Presid EQUIPMENT ACCEPTANCE FOR EQUIPMENT SCHEDULE No. 6597 TO MASTER LEASE AGREEMENT No: 04-19633 This Equipment Acceptance incorporates the terms and conditions of the above-referenced Equipment Schedule and Master Lease Agreement. Each capitalized term used herein shall have the same meaning given to it in the above-referenced Master Lease Agreement unless otherwise defined herein. You certify that all Equipment pursuant to the referenced Equipment Schedule has been furnished, that delivery and installation and other work necessary prior to use has been fully completed to your satisfaction. The Equipment is in good condition, working order and repair and is in compliance with all your requirements. All conditions and terms of this Lease have been reviewed and acknowledged You authorize Us to pay the Equipment Supplier(s) pursuant to the attached Invoice. Upon signing below, your promises herein will be irrevocable and unconditional in all respects and you irrevocably accept the Equipment "as is", "where is" and without recourse, representation or warranty of any kind express or implied, VillageCraft Factory Direct, Inc. X -15 -01 President ?? ????? Iv CORPORATE GUARANTY To induce Direct capital Corp. ("Lessor") to lease equipment to vftwcmeFeawy ohx "Lessee'l pursuant to Lease No. o4-19633 (the or pursuant to r Lease No. 04 t 9633 and all Supplements thereto (cross out and complete as required) (the "Lease'). 1 • The undersigned hereby absolutely and unconditionally Guarantees to Lessor full and rom t a performance when due of each and every obligation p P P 3 went and 2. The undersigned here ?' gation of Lessee under the Lease. by waives (i) notice of the acceptance hereof by Lessor an of the creation and existence of the Lease and (ii) any and all defenses otherwise available to a guarantor or accommodation party. 3. This Guaranty is absolute and unconditional, and the liability of the undersigned hereunder shall not be affected or impaired in any way by any of the following, each of which Lessor may agree to without the consent of the undersigned: (a) any extension or renewal of the Lease whether or not for longer than the original period; (b) any change in the terms of payment or other terms of the Lease or any collateral therefor or any exchange, release of or failure to obtain any collateral therefor, (c) any waiver of forbearance granted to Lessee or any other person liable with respect to the Lease or any release of, compromise with, or failure to assert rights against Lessee or any such other person; and (d) the application or failure to apply in any particular manner any payments or credits on the Lease or any other obligation Lessee may owe Lessor. 4. Lessor shall not be required before exercising and enforcing its rights under the Guaranty first to resort for payment under the Lease to Leasee or to any other person or to any collateral. The undersigned agrees not to obtain reimbursement or payment from Lessee or any other person obligated with respect to the Lease or from any collateral for the Lease until the obligations under the Lease have been fitly satisfied. 5. The undersigned shall be and remain liable for any deficiency following foreclosure of any mortgage or security interest securing the Lease whether or not the liability of Lessee under the Lease is discharged by such foreclosure. 6. The undersigned shall be and remain liable for any deficiency following the initiation of bankruptcy or other insolvency actions affecting the Lease or the Lessee, whether or not the liability of the Lessee is discharged in whole or in part by such action. 7. The undersigned agrees to pay all costs, expenses and attorneys' fees paid or incurred by Lessor in endeavoring to enforce the Lease and this Guaranty. 8. If any payment from the Lessee or anyone else is applied to the Lease and is thereafter set aside, recovered, rescinded, or required to be returned for any reason (including as a preference in the ban Lessee), the obligations under the Lease to which such payment was ?Pe3' of the Guaranty be deemed to have continued in existence notwithstanding sucapplied h application, thhiissGuaz my shall be enforceable as to such obligations as folly as if such applications had never been made. 9. If more than one person signs this Guaranty, then the liability of the undersigned hereunder shall be joint and several, and this Guaranty shall by enforceable in full against each of the undersigned. 10. This Guaranty shall be binding upon the estate, heirs, successors and assigns of the undersigned, and shall insure to benefit of the successors and assigns of Lessor. CONSENT TO LAW, JURISDICTION AND VENUE. The subject Lease shall be deemed fully executed and performed in the state ofLessor's or its Assignee's principal place of business and shall be governed by and construed in accordance with the law thereof. If the Lessor or it's Assignee shall bring any judicial proceeding in relation to any matter arising under the Lease Agreement and for this guaranty, the undersigned hereby irrevocably agrees that any such matter may be adjudged or determined in any court or courts in the state of the Lessor's or its Assignee's principal place of business, or any U.S. federal court sitting in the state of the Lessor's or its Assignee's principal place of business, or in any court or courts in Lessee's state of residence, or in any other court having jurisdiction over the lessee or assets of the Lessee, all at the sole election of the lessor. The undersigned hereby irrevocably submits generally and unconditionally to the jurisdiction of any such court so elected by Lessor or its Assignee in relation to such matters. Dated 1? , 20_ '7 . urilageCraft Co ct Fumishin LP Corporation or Partnership Signature General Pa er Title EXHIBIT "A" This Exhibit A is referred to in and made part of the Equipment Schedule numberto Master Lease Agreement number 04-1903 between iltageCraft Factory Direct, Inc. (Lessee) and Direct Capftai Corporation (Lessor). All equipment as set forth on below invoice No(s) dated as listed, Including all attachments, accessories and Inclusions per Invoice. See the attached invoices for the purposes of listing the equipment only. Lessee acknowledges that the Lessee is choosing to lease the referenced equipment over time per the payment schedule and terms and conditions set out in the above referenced Agreement which control rather than the cash price as referenced on the invoices. Refer to Bill of Sale from National Auto Centre, Inc, dated January 17'h, 2007 VillageCraft Factory Dirac, Ina President Sy signing above, I at- wish m. ue to receive updates from Direct Capital Corp. regarding my corporate account Please Bend Information to the fax and/or email address given for the account Lessor: Direct Capital Corpo ion 0 epees From:DIRECT CAMAL CORP. 603 373 1980 BILL OF SALE 01/16/2007 18:55 X064 P.002/002 GRANTOR. National Auto Centre, Inc. ADDRESS: 4801 South Eagle Valley Road ADDRESS: Julian, PA 16844 TELEPHONE: (814)353-88ao SOLD TO: Direct Caoital Coro SHIP TO: ViilageCraft Factory Direct, Inc. ADDRESS: 155 Commerce Wav ADDRESS: 1446 Mount Holly Pike ADDRESS: Portsmouth NH 03801 ADDRESS: Carlisle, PA 17013 Know all men by these presents; That in hereby acknowledged the undersigned r consideration of V-ZAQQ._Qg the receipt of which is t , g an or does hereby grant Dk= Capital Cozy. (Grantee). its Heirs, Executors, Administrators land assigns Grantee the following described e ui t q pmen : QUANTITY ITEM DESCRIPTION UNIT PRICE TO 2 - Dust Collection System 2 - Downdraft Sanding Tables $9.600.00 $19,200.00 2 - Bench Lathe #40006 $4,400.00 $ 8,900.00 $3 500 00 1-Milling Machine '1- Milt & Drift Combo Machine , . $ 7,000.00 $2.500.00 $ 4,500.00 4- Metal Cutting Band Saw $2,000.00 $ 2,000.00 000 $2 00 2 - 48' Pan Brakes #5769G , . $ 8,000.00 $6,500.00 $43,000.00 TOTAL: $62,600.00 To have and to hold, all and singular, the eq Grantee that they are the lawful owner of uipment forever. Grantor he ? covenants with the i except as follows: equ pment; that it is free from all encumbrances, And that Grantor will warrant and defend the We of equipment to Grantee against all and every Person and persons who claims any other interest in equipment. In Witness whereof, the Grantor(s) have hereunto set their hands and seat this day of_, 200 7 . 17th of January National Auto Centre Inc. a ---4 SI natu itle g Office Manager 7th day of January 2007 JLL-3-2002 WED 03:37PM ID: PAGE:2 MASTER DELIVERY GUARANTY And MASTER ASSIGNMENT OF INVOICES Addendum to Master Lease Agreement # 04-19633 ("Agreement") dated 'between Direct Caoital Corooration as Lessor and vykvc.n vmr caw, i.. , as Customer. In reliance on your promise to pay Lessor under the Agreement and this Master Delivery Guaranty and Master Assignment of Invoices, we will pay all of the supplier(s) requested by you under the Agreement (up to the total approval amount provided under the Agreement) prior to delivery of the equipment from such supplier(s), if required by the supplier(s). In such case, Customer understands that, despite the fact that certain items of Equipment to be leased have not been delivered or installed, Customer authorizes Lessor to pay the supplier(s) in advance of delivery of the Equipment, and Customer's obligations under the Agreement will commence Immediately. Customer understands and agrees that in the event the Customer is not satisfied with the working condition of the Equipment, that Customer shall only look to persons other than Lessor or its assigns, such as the supplier, manufacturer, vendor, installer, or carrier, and shall not assert against Lessor or Its assigns any claim or defense that Customer may have with reference to the Equipment, Its installation, or delivery. An cases where a vendor of the Equipment covered under the Agreement has directly invoiced the. Customer for any or all of the Equipment ("Invoice'), the Customer hereby agrees that, pursuant to the terms of this Master Delivery Guaranty and Master Assignment, each an every Invoice is hereby sold, assigned and transferred to Lessor, including all of the Customer's rights, title and interest in and to the Invoice and the Equipment covered therein. Direct Capital CorDOration nat /? Title Date V*C SaQ F"etory Deep, I- C Omer X Signature PftW= Title Daft, x ???``+ ? LEASE PORTFOLIO PURCHASE AGREEMENT This Lease Portfolio Purchase Agreement ("Agreement") is made, entered into and effective as of March 30, 2007 by and between Direct Capital Corporation, a New Hampshire corporation with a principal place of business located at 155 Commerce Way, Portsmouth, New Hampshire (the "Seller' and LEAF Funding, Inc., a Delaware corporation with offices located at 1818 Market Street, 9m Floor, Philadelphia, PA 19103 (the "Buyer"). WHEREAS, the Seller owns the equipment lease transactions (the "Contracts) listed on Schedule I to this Agreement and has offered to sell the remaining regular rental payment stream for each Contract ("Payments") listed on Schedule I (the "Assets"); and WHEREAS, the Buyer desires to purchase such Assets from the Seller upon the terms and subject to the conditions contained in this Agreement. NOW, THEREFORE, Seller and Buyer hereby agree as follows: 1. Sale of Assets and Assignment of Rights Subject to the terms and provisions of this Agreement, the Seller hereby sells, assigns and transfers to Buyer the Assets associated with the Contracts included on the attached Schedule I and in and to all related documents executed relating to this Agreement, including but not limited to: (a) all of Seller's rights, remedies, title and interest in and to each Contract Payments; (b) a first priority perfected security interest in and to all items of property subject to each Contract ("Equipment'; (c) all Payments relating to such Contracts, including late fees and indemnification payments; (d) all of Seller's right, title and * interest in and to policies of insurance or surety bonds with respect to the Equipment and Contracts and rights. to receive payments or proceeds under any such policies of insurance; and (e) all guaranties and additional security for the Contracts, including any security deposit. Buyer shall have, in addition to all other rights hereunder, the right to receive and retain any and all Payments and rights thereto under any referenced Contract. Upon, receipt.by Buyer of all Payments and other amounts due and payable with respect to a Contract structured as an fair market piitchage option, and provided (i) no default has occurred and remains uncured under the Contract and (ii) no material default by §elferder has occ rrr an 3it Y`nam-rmotTod; Buyershall-termin to-its security-interest ------ in and to the related Contract acid Equipment, subject to any applicable residual sharing rights. Except as to fulfilling payment on Contracts at or prior to obligor. verbal confirmation identified on Schedule A as "prefunded contracts', Buyer does not assume (and Seller shall retain) any of the obligations of the Seller under any Contract or with respect to the Equipment amid shall have no duties in respect thereof. 2, Schedule I Purchase Price. In consideration of the sale by the Seller to Buyer of the Assets listed on Schedule I pursuant to this Agreement, Buyer hereby agrees to pay on the Closing Date to the Seller the sum (the "Schedule I Purchase Price") which has been calculated in the manner described Schedule I in immediately available Rinds to such account as specified by Seller, 3. Delivery of Contracts and Other Documents to Buyer, Page I of 6 Concurrently with the payment of the Schedule I Purchase Price, Seller shall deliver to Buyer: (a) all the original signed counterparts of all Contracts and related documents included in the Schedule I; (b) all originals or complete and accurate copies of related documents; (c) any evidence held by the Seller of ownership and the Seller's security interest in, each item of Equipment and of miy filings or other recordation of such interest made with respect to each lessee or obligor in any relevant jurisdictions and evidence of payment of the purchase price to the applicable vendor with respect to each item of Equipment; (d) copies of the purchase orders, invoices and executed bills of lading with respect to the equipment described in each Contract (if applicable); (e) such other documents, insurance certificates, if applicable, and instruments included in the Contract Files provided to Buyer at due diligence and others as Buyer- may reasonably request to further implement and effectuate the purposes of this Agreement. 4. Warranties as to Lease Transactions; Doctunentation. (a) As to each Asset assigned by the Seller to Buyer pursuant to this Agreement and its associated Contract, each listed on Schedule I, the Seller represents and warrants that as of the date of this Agreement: (1) it is the owner of the Equipment described in the Contract, or has a perfected first security interest or lien thereon effective against all persons, free from all security interests, liens and encumbrances, except for the rights of the lessee or obligor, (2) such Contract and all accompanying guaranties, waivers and other instruments are true, valid, genuine, binding and enforceable in accordance with their respective terns; ?? ?_.__ ?. ?? ?-?3)-. s`ucli Contract: i?'•tke'onlyContract-with-respect to••the.-Equipment..deseri>zed.?he?ein and is a Contract which Buyer is authorized to purchase and hold, and the Seller has the full legal power, right and authority to sell to Buyer; (4) such Contract is legal, valid, binding, and enforceable in accordance with its terms and, except as otherwise provided herein, is non'cancelable for its remaining term as such term is indicated on the attached Schedule ly (5) as to each Contract delivered to Buyer on or prior to. the Closing Date, such Contract constitutes the genuine sole original counterpart of all of the original instruments executed. for the disposition by Seller of the Equipment described therein, and constitutes the entire agreement of the patties thereto; (6) all information provided by_ Seller to Buyer concerning such Contract,. including, without limitation, the information included -on the Schedule h has been provided with the knowledge that Buyer has been induced to enter into this Agreement to purchase the Assets on the terms agreed upon in reliance on such information and Seller Page 2 of 6 warrants that, to the best of its knowledge, all such inforrnation was accurate and correct as of the date it was obtained by Seller, () all taxes imposed prior to the Closing Date by any taxing authority in connection with the sale, lease, use or ownership of the Equipment covered by an assigned Contract or Equipment have been or will be properly paid and discharged by Seller in accordance with applicable law, unless Seller is contesting such taxes in good faith and in accordance with applicable laws and regulations; (8) such Contract entered into by Seller arose out of bona fide business transactions in the ordinary course of business and, to the best of Seller's lrnowledge, the Equipment covered thereby is, in conformity with all applicable jaws and regulations; (9) as to such Contract, the Equipment has been accepted by, and with the exception of Contracts listed as 'preftuided contracts' on Schedule I, and delivered to, the lessee under the terms of the Contract, and the -lessee is obligated to make the Payments specified in the related Contract; (10) except as provided on a Schedule I, Seller is not holding any escrow, maintenance or other reserves or deposits pursuant to such Contract, and agrees to indemnify and hold Buyer harmless from any claims of any 1 essee or obligor to that effect; (11) all fees in connection with such Contract have been indefeasr"bly paid and satisfied in full; (12) such Contract is in full force and effect and has not been terminated or is subject to litigation and no material event of default has occurred and remains uncured thereunder . and no Contract has been restructured, extended or otherwise materially modified; . (13) Seller has the absolute right to sell and transfer the Contract and Payments and such Contract does not contain a prohibition against such sale and {Assignment and Buyer shall acquire good and valid title thereto, free from all liens and encdi ibrance's; (14) there is not an snot any act, f'ailu`re o?'aicC ?iiniotr't5r?iiisrepresentatiorr of------ Seller, any vendor or Seller, or the agents or employees of vendor or Seller, which nullifies, modifies, -limits or in any way affects the genuineness, validity or enforceability of any obligation of any lessee or obligor under such contract; (15) the payment status of such Contract is as stated on Schedule I and is not' subject to any offset, deduction, defense, counterclaim or lien and no Payment under any Contract is more thirty-four (34)'days past due; (15) the vendor of the Equipment has been paid in full, except as relates to Equipment subject to a Contract identified as "pre-funded" on Schedule 1. (b) The Buyer represents and warrants that it has made an independent credit deoision to purchase each Contract on Schedule L Buyer has completed a full detailed credit and documentation review of each Contract and has reviewed all documents associated with the Contracts and all additional assignments, schedules and other supporting documentation and Page 3 of 6 finds all to be in form and substance acceptable to it, Buyer has received and reviewed all requested information needed to complete its review. (c) 1n purchasing each Contract under this Agreement, the Seller acknowledges that Buyer is relying upon the warranties of the Seller contained herein and other agreements between the parties as to such Contracts, and agrees that the knowledge of Buyer of any breach of any such warranties at the tiine of its sale of each Contract or the failure of Buyer to call any such breach to the attention of the Seller, shall not impair, limit or constitute any waiver of any such warranties or of the obligations of the Seller with respect to such transaction, and that the Seller shall remain fully liable for any such breach. Furthermore, the review of any such transaction by Buyer and the furnishing of any comments in respect thereof to the Seller, or the failure to do so in any case, shall not impair, limit, or constitute any waiver of any of the obligations or warranties of the Seller with respect to such transaction. 5. Servicing and Remarketing. Both parties expressly agree that: Buyer (including Buyer's successors, assigns and/or designees) shall collect and receive all lease payments; shall exercise all other rights, powers and privileges of the lessor or lender under each Contract, and generally provide all necessary administration for each Contract. In the event that Seller receives any amounts constituting Assets which have been assigned to Buyer hereunder, Seller shall receive same as trustee for Buyer and remit to Buyer all. amounts so received within two (2) days of receipt thereof. Seller covenants that it will take such action as Buyer may reasonably request to facilitate the transfer of servicing responsibility. Buyer may take or fail to take whatever action with respect to the collection of such sums and receipt of such funds as Buyer, in its sole. discretion, may deem proper.. In connection therewith, Buyer may agree with any Lessee as to any modification, alteration, release, compromise, extension, waiver, consent or similar or dissimilar indulgence of or with respect to such Contract. Billing, collection and. servicing of Contracts by Buyer shall, to the fullest extent permitted by law and regulation. and without the necessity of Buyer filing, registering, or licensing any trade name and without misleading any lessee or borrower which inquires with respect to such matters and subject to the provisions set forth below, be done using the name of Seller ( `Piivate,4bel AdmiV'stration"). Seller hereby consents to the exclusive use by Bu er of Seller's name and logo, in connection with the performance by Buyer of & Private Label A! MR 01 cts ,..., Buyer may at its discretion cease Private Label Administration with respect any Contract that is in default and/or any and all Contracts it Seller im s def Elt of ifS 6bTigafions hemufiTa"std-failt-ttr re"surh-default-- within thirty (30) days of written notice from Buyer or if this Agreement is terminated. Notwithstanding the use of Private Label Administration, Buyer shall be entitled to file any and all Uniform Commercial Code financing statements, continuations, assignments and/or other filings as Buyer may deem necessary to evidence Buyer's interest in the Assets and/or Contracts. At the Buyer's written request, Seller shall use its reasonable best efforts to assist in the repossession, storage and sale of equipment included in a Contract. Buyer shall pay Seller a fee equal to 10% of any amount realized by Buyer as a result of these efforts. Should Seller sell the equipment for more than the then remaining outstanding balance of the Contract as calculated by the Buyer, any remaining additional amount shall be paid to or retained by Seller. Buyer will notify Seiler of the resolution of each Contract and the end of its term and the completion -of all payments by lessee or obligor. 6. Repurchase of Assets. Page 4 of 6 - 1 (a) Upon the occurrence of a material breach by Seiler. of any representation, warranty, covenant, or obligation of this Agreement relating to the Assets, Seller shall, within ten (10) days after the receipt of a written demand from Buyer, repurchase the .affected Assets for an amount equal to Buyer's book value thereo4 plus Swap breakage costs, all as reasonably detierrnined by Buyer according to its customary practices Investment Balance, as defined herein, with respect to such Asset. Upon receipt of the repurchase amount, Buyer shall promptly execute all appropriate documents to convey Buyer's interest in and to the underlying Contract and Equipment on an AS-IS, WF1ERE-1S basis, without representation or warranty, (b) Tn lieu of requiring a repurchase of a Contract as set forth above, the parties may at their discretion agree to substitute a new transaction acceptable to Buyer for the Contract which Seller would otherwise be obligated to repurchase. Any such substitution shall be upon mutually satisfactory terms and conditions. 7. Indemnity, Seller shall indemnify and hold Buyer harmless against and from any and all losses clams and expenses, including legal fees and expenses. ("Claims') arising from: (i) any breach by Seller of any warranty, covenant or other obligation of Seller in this Agreement; (ii) Seller's negotiating, arranging and documenting a Contract and administration thereof or assertion of a claim against Buyer to the extent which, if valid, would reflect a breach by Seller of any of Seller's warranties or agreements hereunder. 8. Power of Attorney. Seller hereby irrevocably appoints Buyer its attorney-in-fact to do, at Buyer's option and expense, all lawfid acfs and things which Buyer may deem necessary to: (a) perfect, continue pprfecr the security or title interest conveyed* to Buyer pursuant to an Contract; to endn, amend or Ors Seller's name, any derivation thereof on all Contracts, all documents ancillary thereto, all asso or sign igru and/or participations of Contracts to Buyer and/or other participants, bills of sale (whether to or- from Buyer), checks, collections, receipts, financing statements or assignments, or other documents related to the servicing Of -a Contractwith the terms ooff this 4. Agreeme.nt; and (c) to take possession "of and.,6gezt mail received by Buyer but addressed to Seller relating to such collections and remove payments and collateral proceeds (including any insurance `pTaoe-bds):"Seller•irrevocably-authrndmentsizes statements --Buyer-tofile-an}?.and_a11-Uniform..Convnercial._Code_financing_ , assignments, amen and/or continuations as Buyer may deem necessary or prudent to perfect and/or maintain Buyer's interest in and to the Assets, including Uniform Commercial Code filings that identify Seller as having sold the Assets to Buyer. Buyer shall be entitled to sign Seller's name to any form document to evidence the conveyance of any Contract from Seller to Buyer on an individual basis so disclosure of this Agreement would not be necessary, 9. Term of Agreement, This Agreement shall continue ui effect so long as any Contract shall be outstanding. 10. Modification and Waiver. No modification or waiver of any provision of this Agreement or any other agreement executed between the parties shall be effective unless such modification or waiver shall be in writing and signed by a duly autborized officer of Buyer and the Seller and the same shall then 'be effective only for the period and on the conditions and for the specific instances and purposes specified in such writing. Page 5 of 6 1 I 1. Notices; Choice of Law; Successors and Assigns. This Agreement shall be govemed by and construed in accordance with the internal laws of the State of New Hampshire. This Agreement shall be binding upon and inure to the benefit of the Seller and Buyer and their respective successors and assigns, but nothing herein shall give the Seller the right to assign this Agreement or its rights hereunder without the express prior written consent of Buyer. IN WITNESS WHEREOF, the parties hereto have caused this PORTOI 0 PURCHASE AGREEMENT to be signed by their duly authorized officers on their respective behalf as of the date first above written. LEAF ING, INC. By: ' Type Name: ; l y Title: re ` DIRECT CAPITAL CORP TION By: Type NameVf6L yTitle: C. Page 6 of 6 SCHEDULE I TO PURCHASE AGREEMENT This Schedule I ("Schedule t') to Purchase Agreement dated March 30, 2007 ("Agreement"), is executed ~r by and among LEAF Funding, Inc. (`Buyer") and Direct Capital ("Seller'). Seller, for and in consideration of the Schedule I Purchase Price indicated below paid or to be paid by Buyer to Seller this day, hereby transfers and assigns to Buyer, all Seller's right, title and interest in and to the following Assets, all pursuant to the terms of the Agreement, the terms of which are incorporated herein by reference: Contrac : Each of the one hundred seventy seven (177) lease transactions identified on that certain Excel spreadsheet attached hereto as Exhibit A shall constitute a separate Contract. Lessee Name and Address: Each as identified. in Exhibit A attached hereto and the applicable Contract. Payments:- Each Contract shall have the number and amount of remaining monthly Payments, plus applicable taxes, as specifically described in Exhibit A (and/or in the applicable Contract coming due on or after the date specified below). Due Date for first Payment assisned to Buyer. With respect to each Purchased Lease, Buyer shall be entitled to receive all Payments which remain unpaid under the Contracts as of March 27, 2007, as reflected in the attached Exhibit A. Equipment Description and Location: As set forth in each Contract. Sehedxile IPurchase Price: $7,886,091.83. Security Deposit: Each as set forth in Exhibit A or as otherwise specified by the parties. IN WITNESS WHEREOF, the parties hereto have executed this Assignment by their duly authorized officers as of the date first above written. LEAF FUNDING, INC. DIRECT CAPITAL, INC. By. 13 . Name: Name: _c r't+ - u 5eA.0 -Title:- Title: Ca=d i R88s?q?EsE@ 5s? if st SE ? 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T? Fg' ?a4 swwwwwwwwNN„wwww wwwwNwNwNwMww«NwwNNwNwww .S ql1py; .w wwS .?`. lialx_+§?? + .01 ualluX4 rr?RwN? r-; ?a 73 SHERIFF'S RETURN - REGULAR CASE NO: 2008-02109 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LEAF FUNDING INC VS VILLAGECRAFT FACTORY DIRECT IN NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WTT T.7\=r?nnWT WnrTr1RV nTRF.r'T T-NTr the DEFENDANT , at 0905:00 HOURS, on the 4th day of April , 2008 at 1446 HOLLY PIKE CARLISLE, PA 17013 JERRY TROLINGER by handing to ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.00 Affidavit .00 Surcharge 10.00 .00 ??',u??& ? 33.00 Sworn and Subscibed to before me this of day So Answers: - f;, 011 R. Thomas Kline 04/07/2008 LAMM RUBENSTONE By: Deputy Sheriff A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-02109 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LEAF FUNDING INC VS VILLAGECRAFT FACTORY DIRECT IN NOAH CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon 11- T T/ 11Tl7TPT /"nMrrDAOrr T:TTDNTTQWTNT(_'C T,p the DEFENDANT , at 0905:00 HOURS, on the 4th day of April 2008 at 1446 HOLLY PIKE CARLISLE, PA 17013 by handing to JERRY TROLINGER, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 00 16.00 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 04/07/2008 LAMM RUBENSTONE By: Deputy Sheriff A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-02109 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LEAF FUNDING INC VS VILLAGECRAFT FACTORY DIRECT IN NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon mMrNT TTTh LSD T'GDDV M .7D the DEFENDANT , at 0905:00 HOURS, on the 4th day of April , 2008 at 1446 HOLLY PIKE CARLISLE, PA 17013 by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 0 16.0 0 Sworn and Subscibed to before me this of So Answers: R. Thomas Kline 04/07/2008 LAMM RUBENSTONE By day Deputy Sheriff A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LEAF FUNDING, INC. Plaintiff, V. No. 2008-2109 VILLAGECRAFT FACTORY Civil Term DIRECT, INC. and VILLAGECRAFT CONTRACT FURNISHINGS, L.P. and JERRY M. TROLINGER, JR. Defendants. PRAECIPE FOR DEFAULT JUDGMENT AGAINST DEFENDANTS, VILLAGECRAFT FACTORY DIRECT, INC. and VILLAGECRAFT CONTRACT FURNISHINGS, L.P., ONLY Please enter judgment in favor of Plaintiff and against Defendants, Villagecraft Factory Direct, Inc. and Villagecraft Contract Furnishings, L.P., ONLY, for want of an answer to Plaintiff s Complaint. Judgment should entered for $88,068.44, plus interest and additional attorneys' fees and costs as they accrue, as set forth below: Remaining Lease Payments Attorneys' Fees Total $86,068.44 2,000.00 $88,068.44 PAGE 1 OF 2 381962_1.DOC X I certify that the foregoing assessment of damages is for specified amounts averred to be due in the Complaint and is calculable as a sum certain from the Complaint. X Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe and copies of the Notices are attached as Exhibit A. Respectfully submitted, LAMM RUBENSTONE LLC By: David A. DeFlece, Esquire 3600 Horizon Boulevard, Suite 200 Trevose, PA 19053 215-638-9330; 215-638-2867f Attorneys for Plaintiff 381962_1.DOC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LEAF FUNDING, INC. Plaintiff, V. No. 2008-2109 VILLAGECRAFT FACTORY Civil Term DIRECT, INC. and VILLAGECRAFT CONTRACT FURNISHINGS, L.P. and JERRY M. TROLINGER, JR. Defendants. AFFIDAVIT OF LAST KNOWN ADDRESS I, David A. DeFlece Esquire, of full age, being duly sworn according to law, upon my oath, depose and say that I am the attorney for Plaintiff, that I am authorized to make this Affidavit on behalf of Plaintiff; that to the best of my knowledge, information and belief, the last known addresses of the above named Defendants are: Villagecraft Factory Direct, Inc. 1446 Holly Pike Carlisle, PA 17013 Villagecraft Contract Furnishings, LP 1446 Holly Pike Carlisle, PA 17013 LAMM RUBENSTON LC By: David A. DeFlece, Esquire Attorneys for Plaintiff Swo to and S bscribed before me i da of , 2008. o y Public COMMONWtALTFI F' ,__VLVANIA NOTARIAL SEAL LYNNE M. STARKMAN, Notary Public Bensalem Twp., Sucks County 381962_LDOC My Commission Evires July 14, 2010 ("?j b;+ 4- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LEAF FUNDING, INC. V. No. 2008-2109 VILLAGECRAFT FACTORY Civil Term DIRECT, INC. and VILLAGECRAFT CONTRACT FURNISHINGS, L.P. and JERRY M. TROLINGER, JR. Defendants. To: Villagecraft Factory Direct, Inc. Date: April 28, 2008 1446 Holly Pike Carlisle, PA 17013 NOTICE - RULE 237.1 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT 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 PROM DE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 Plaintiff, M RUBENSTONE LC By: David A. DeFlece, Esquire 3600 Horizon Boulevard, Suite 200 Trevose, PA 19053 215-638-9330 Attorneys for Plaintiff 381427_1.DOC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LEAF FUNDING, INC. V. Plaintiff, No. 2008-2109 VILLAGECRAFT FACTORY Civil Term DIRECT, INC. and VILLAGECRAFT CONTRACT FURNISHINGS, L.P. and JERRY M. TROLINGER, JR. Defendants. To: Villagecraft Contract Furnishings, L.P. Date: April 28, 2008 1446 Holly Pike Carlisle, PA 17013 NOTICE - RULE 237.1 IWORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT 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 PROVI DE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 AMM RUBENSTO C w By: David A. DeFlece, Esquire 3600 Horizon Boulevard, Suite 200 Trevose, PA 19053 215-638-9330 Attorneys for Plaintiff 381427_I.DOC U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY - PRO , R I.ANm RUMNSTO c FE .. . 3600 HORIZON BOU '1s? w A w SUITE 2000 - F? D m a TREVOSE, PA 190 9 _ L No 0 C N ? w3 One piece of ordinary mea addressed 11, cn Oo m o {,y y .. G 00 co m PS Forth 3817. January 2001 U.S. POSTAL SERVICE CERTIFICATE OF MAILING PPRROrn FEgs? F? R LAmm RuBENSTo Aso .. I. 3600 HORIZON BOU - _ SUITE 200 - °T TREVOSE, PA 1905 cp One piece of ordinary rtrail addressed ro: N'? 0 3 (o vei oNO o C p .& y I 0 co rn PS Form 3817, January 2001 E' O rl : R- O ? 04 W q? t. ?" 7 .:e f r`o ? r, s.? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LEAF FUNDING, INC. Plaintiff, V. No. 2008-2109 VILLAGECRAFT FACTORY' Civil Term DIRECT, INC. and VILLAGECRAFT CONTRACT FURNISHINGS, L.P. and JERRY M. TROLINGER, JR. Defendants. To: Villagecraft Factory Direct, Inc. 1446 Holly Pike ' Carlisle, PA 17013 NOTICE Notice is hereby given that a judgment has been entered against you in the amount of $88,068.44 plus interest and additional attorneys' fees and costs as they accrue, on 2008. Copies of all documents filed with the Prothonotary/Clerk of Courts, ivil Division, in support of the within judgment are enclosed. Prot onotary/ ivil Division BY: If you have any questions regarding this Notice, please contact the filing party: David A. DeFlece, Esquire, 3600 Horizon Boulevard, Suite 200, Trevose, Pennsylvania 19053 215-638-9330; 215-638-2867f (This Notice is given in accordance with Pa.R.C.P. 236) 328822-1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LEAF FUNDING, INC. Plaintiff, V. No. 2008-2109 VILLAGECRAFT FACTORY Civil Term DIRECT, INC. and VILLAGECRAFT CONTRACT FURNISHINGS, L.P. and JERRY M. TROLINGER, JR. Defendants. To: Villagecraft Contract Furnishings, L.P. 1446 Holly Pike Carlisle, PA 17013 NOTICE Notice is hereby given that a judgment has been entered against you in the amount of $88,068.44 plus interest and additional attorneys' fees and costs as they accrue, on 5 /i , 2008. Copies of all documents filed with the Prothonotary/Clerk of Co , Civil Division, in support of the within judgment are enclosed. Prot ono4Ty/ Civil Division BY: If you have any questions regarding this Notice, please contact the filing party: David A. DeFlece, Esquire, 3600 Horizon Boulevard, Suite 200, Trevose, Pennsylvania 19053 215-638-9330;215-638-2867f (This Notice is given in accordance with Pa.R.C.P. 236) 381962_I.DOC IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: JERRY M. TROLINGER, JR., Debtor JERRY M. TROLINGER, JR., Movant V. LEAF FUNDING, INC., Respondent CHAPTER 7 SSN: xxx-xx-0673 CASE NO: 1-08-bk-01425-RNO (LIEN AVOIDANCE) ORDER AVOIDING A JUDICIAL LIEN The Motion of Debtor, Jerry M. Trolinger, Jr., to Avoid a Judicial Lien, having come this day before the Court, it is: HEREBY ORDERED that the judgment entered by Leaf Funding, Inc., in the Court of Common Pleas of Cumberland County, Pennsylvania to No. 2008-2109 is avoided and declared void as to all of the real property located at 2551 Spring Road, Carlisle, Cumberland County, Pennsylvania and 202 Texaco Road, Mechanicsburg, Cumberland County, Pennsylvania owned by the Debtor in that it impairs an exemption claimed by the Debtor in such real properties to which the Debtor would otherwise be entitled ,? !Z 7 CERTIFIED FROM THE RECORD this-=-? day of L ' 20 Clerk, U.S. Bar, p y curt cwk Per DtY, By the CouM Robert N. Opel, Wauptcy Judge (DB) This document rs elwtronscrslly signed and filed on the same date. Dated: October 23, 2008 06- 2.169 j!L Case 1:08-bk-01425-RNO Doc 71 Filed 10/23/08 Entered 10/23/08 10:51:12 Desc Main Document Page 1 of 1 1 J X ?'t t C p rA V 4 p? r