HomeMy WebLinkAbout11-6698WEIR & PARTNERS LLP
By: Daniel D. Haggerty, Esquire
Attorney ID No. 77894
The Widener Building, Suite 500
1339 Chestnut Street
Philadelphia, PA 19107
dhaggerty@weirpartners.com
P: (215) 665-8181
F: (215) 665-8464
OF TH'PE PROTHONOTARY
2011 AUG 23 PM 2: 06
CUMBERLAND COUNTY
PENNSYLVANIA
Attorneys for Narberth Property Acquisition, LLC
NARBERTH PROPERTY ACQUISITION, LLC : COURT OF COMMON PLEAS
732 Montgomery Avenue
Narberth, PA 19072
Plaintiff,
V.
NARBERTH PROPERTY ACQUISITION, LLC,
Successor in Title to Shippensburg Apex, LP
732 Montgomery Avenue
Narberth, PA 19072
Defendant.
CUMBERLAND COUNTY
CIVIL ACTION
NO.
NOTICE TO DEFEND
NOTICE
You have been sued in court. If you wish to
defend against the claims set forth in the following
pages, you must take action within twenty (20)
days after this complaint and notice are served, by
entering a written appearance personally or by
attorney and filing in writing with the court your
defenses or objections to the claims set forth
against you. You are warned that if you fail to do
so the case may proceed without you and a
judgment may be entered against you by the court
without further notice for any money claimed in
the complaint or for any other claim or relief
requested by the plaintiff. You may lose money or
property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION
AVISO
Le han demandado a ustted en la corte. Si usted quiere
defenderse de estas demandas expuestas en las paginas
siguientes, usted tiene veinte (20) dias de plazo al partir
de la fecha de la demanda y la notificacion. Hace falta
a sentar una comparencia escrita o en persona o con un
abogado y entregara la cortte en forma escrita sus
defensas o sus objeciones a las d mandas en contra de
su persona. Sea a visado que si usted no se defiende, la
corte tomara medidas y puede continuar la demands en
contra suya sin previo aviso o notificacion. Ademas, la
corte puede decidir a favor del demandante y requiere
que usted cumpla con todas las provisioner de esta de
manda. Usted puede perder dinero o sus propiedades o
otros de rechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IN
MEDIATAMENTE SI NO TIENE ABOGADO 00 SI
NO TIENE EL DINEROSUFICIENTE DE PAGAR
TAL SERVICIO, VAYA EN PERSONA O LLAME
POR TELEFONO A LA OFICINA CUY DIRECCION
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e?Crf 5Y'?9 ?
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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.
Cumberland County Bar Association
Cumberland Law Journal
32 South Bedford Street
Carlisle, PA 17013
Telephone: 717-249-3166
SE ENCUENTRA ESCRITA ABAJO PARA
AVERICUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Asociacion de Licenciados de Filadelfia
Servicio de Referencia a Informacion Legal
32 South Bedford Street
Carlisle, PA 17013
Telephone: 717-249-3166
2
WEIR & PARTNERS LLP
By: Daniel D. Haggerty, Esquire
Attorney ID No. 77894
The Widener Building, Suite 500
1339 Chestnut Street
Philadelphia, PA 19107
dhaggerty@weirpartners.com
P: (215) 665-8181
F: (215) 665-8464
Attorneys for Narberth Property Acquisition, LLC
NARBERTH PROPERTY ACQUISITION, LLC COURT OF COMMON PLEAS
732 Montgomery Avenue CUMBERLAND COUNTY
Narberth, PA 19072
Plaintiff,
V.
NARBERTH PROPERTY ACQUISITION, LLC,
Successor in Title to Shippensburg Apex, LP
732 Montgomery Avenue
Narberth, PA 19072
Defendant.
CIVIL ACTION
NO.
COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiff, Narberth Property Acquisition, LLC, by and through its undersigned counsel,
hereby brings this complaint in mortgage foreclosure to foreclosure upon a mortgage on real
property located in Shippensburg Township, Cumberland County, Pennsylvania and says:
1. Narberth Property Acquisition, LLC ("Narberth") is holding company for Royal
Bank America organized and existing under the laws of the Commonwealth of Pennsylvania,
with an office located at 732 Montgomery Avenue, Narberth, Pennsylvania 19072.
2. Royal Bank America, is a Pennsylvania banking corporation with its principal
place of business at 732 Montgomery Avenue, Narberth, Pennsylvania 19072 (the "Bank").
_ a
3. Shippensburg Apex, LP ("Apex") is a Pennsylvania limited partnership with its
principal place of business at 401 East Elm Street, Conshohocken, Pennsylvania 19428.
4. On or about October 26, 2007, Apex executed and delivered to the Bank, a
Promissory Note (the "Note"), evidencing a loan extended to Apex by the Bank in the principal
amount of $16,667,015 (the "Loan"). A true and correct copy of the Note is attached hereto as
Exhibit "A".
5. To secure payment of the Loan, Apex executed and delivered to the Bank a
mortgage dated October 26, 2007, which was duly recorded of record on November 8, 2007, in
the Office of the Recorder of Deeds, Cumberland County, at Instrument No. 200742316 (the
"Mortgage"). A true and correct copy of the Mortgage is attached hereto as Exhibit "B". (The
Note and the Mortgage, in addition to any and all documents or instruments executed or created
in connection with the Loan, shall sometimes be collectively referred to herein as the "Loan
Documents.")
6. The Mortgage was executed in favor of the Bank, and granted a mortgage lien to
the Bank upon the premises commonly known as Rocktowne at Shippensburg, a commercial
property, more fully identified in the Mortgage, including all improvements thereon (the
"Mortgaged Property")
7. The Mortgaged Property, which is more fully described in the Mortgage,
includes:
ALL THAT CERTAIN tracts of land situate in Shippensburg
Township, Cumberland County, Pennsylvania, as shown on a
Subdivision Plan for G & C Associates for Apex Village, by
Fischbach Morgan & Associates, R.S. dated August 10, 2006,
recorded in Cumberland County Recorder of Deeds Office Plan
Book 93, Page 60, being designated as Lot 7, more particularly
bounded and described as follows:
2
I A
BEGINNING at a point on the southwestern edge of Asper Drive;
thence by other lands of Grantors North 43 degrees 12 minutes 00
seconds West a distance of 581.53 feet to an iron pin to be set at
the corner of the storm water basin North 47 degrees 18 minutes 16
seconds East a distance of 290.31 feet to an iron pin to be set;
thence continuing by the edge of the storm water basin North 43
degrees 13 minutes 31 seconds West 215.75 feet to a point at lands
nor or formerly of Conrail Lurgan Branch Railroad; thence along
said Conrail Railroad lands North 76 degrees 48 minutes 08
seconds East a distance of 106.35 feet to a point; thence continuing
by said Conrail Railroad property North 79 degrees 38 minutes 43
seconds East a distance of 306.07 feet to a point; thence along
other lands of G & C Associates South 42 degrees 44 minutes 58
seconds East a distance of 581.17 feet to a point; thence by other
lands of G & C Associates on the southeastern Asper Drive South
47 degrees 18 minutes 23 seconds West a distance of 634.90 feet
to an existing iron pin, the point and place of BEGINNING.
CONTAINING 9.388 acres, more or less and being all of Lot 7.
BEING a portion of the real estate which Galen S. Asper and
Jeannette A. Asper, by their attorney in fact by deed dated July 30,
1992 and recorded in Cumberland County Deed Book "L" Volume
36, Page 809, granted and conveyed to H. Scott Garling and
Michael J. Cassidy, co-partners, t/d/b/a G & C Associates. H.
Scott Garling died July 29, 1994. Letters of Administration were
issued to Barbara L. Garling on August 8, 1994, by the
Cumberland County Register of Wills. By specific provision of
the Partnership Agreement between H. Scott Garling and Michael
J. Cassidy, the personal representative of a deceased partner,
succeeded to the interest of the deceased partner and continued to
conduct partnership business. Barbara L. Garling previously
elected to succeed to the interest of the deceased partner, but has
since withdrawn from the partnership. Julie A. Cassidy became a
partner and joined in the deed of conveyance with Michael J.
Cassidy as Grantors to Educational Property Group, Inc. The
parties who executed the deed of conveyance were all of the
partners of G & C Associates, and their deed of conveyance was
approved in accordance with the requirement of the Partnership
Agreement.
BEING Tax Parcel Number: 36-35-2385-131
8. By way of an Assignment of Mortgage dated June 29, 2010, which was duly
recorded of record on July 6, 2010, in the Office of the Recorder of Deeds, Cumberland County,
3
at Instrument No. 201017880 (the "Assignment"), the Bank assigned its rights under the
Mortgage to Narberth. A true and correct copy of the Assignment is attached hereto as Exhibit
«C„
9. On or about June 27, 2010, Narberth took title to the Mortgage Property from
Apex by way of a Deed in Lieu of Foreclosure, which was duly recorded of record on July 12,
2010, in the Office of the Recorder of Deeds, Cumberland County, at Instrument No. 201018539
(the "Deed").
10. Under the terms of the Deed, Narberth preserved its rights under the Mortgage to
file the present foreclosure action. A true and correct copy of the Deed in attached hereto as
Exhibit "D".
11. Apex is in default under the terms of the Mortgage, in that Apex has failed to
comply with or perform the obligations under the terms and provisions of the Loan documents
despite demand therefore.
12. As of August 12, 2011, Apex is indebted to Plaintiff under the terms of the Loan
as follows:
Principal $16,067,681.94
Interest Accrued to Payoff Date $ 629,011.54
TOTAL REAL DEBT: $16,696,693.48*
*Plus attorneys' fees, costs, and continuing interest.
13. In addition, interest continues to accrue on principal at the per diem rate of
$1,313.09, plus attorneys' fees and costs.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in its favor and
against Narberth Property Acquisition, LLC, in the amount of $16,696,693.48 plus per diem
4
interest of $1,313.09, plus attorney's fees, costs of suit, expenses, and costs for foreclosure and
sale of the Mortgaged Property.
WEIR & PARTNERS LLP
By:
Attorneys fof-N'arberth Property Acquisition, LLC
Dated: August 23, 2011
VERIFICATION
I, Daniel D. Haggerty, hereby verify that I am the attorney for Plaintiff, Narberth
Property Acquisition, LLC, and that I am authorized to make this verification on its behalf, and
that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are true and correct to
the best of my knowledge, information and belief.
I understand that this verification is made subject to the penalties 18 Pa. C.S.A. §4904,
relating to unsworn falsification to authorities.
Dated: August 23, 2011
PROMISSORY NOTE
$16,667,015.00 October 26, 2007
FOR VALUE RECEIVED, and intending to be legally bound hereby, SHIPPENSBURG APEX,
LP, a Pennsylvania limited partnership .Hereinafter called "Maker"), promises to pay to the order
of ROYAL BANK AMERICA, a Pennsylvania banking corporation (hereinafter called "Bank"),
the sum of Sixteen Million Six Hundred Sixty-Seven Thousand Fifteen and 00/100 Dollars
($16,667,015.00) (or so much thereof as may be disbursed pursuant to the Loan and Security
Agreement of even date herewith between Maker and Bank), with interest as hereinafter
provided on the unpaid principal balance until paid; lawful money of the United States of
America in immediately available funds, without setoff or defalcation, at the offices of Bank at
732 Montgomery Avenue, Narberth, Pennsylvania 19072 or such other address as Bank may
designate by written notice to Maker. p
DEFINITIONS: For purposes of this Note, the following terms shall have the meanings ascribed to
them below (with any capitalized term used herein without separate definition. to have the
meaning ascribed to such term in the Loan and Security Agreement of even date herewith
between Maker and Bank):
"Business .Day" shall mean any day other than a Saturday, Sunday or other day on
which commercial banks in the Commonwealth of Pennsylvania are authorized or required to be
closed under the laws of the Commonwealth of Pennsylvania and, if the applicable day relates to
any borrowing to which LIBOR applies, such day must also be a day on which dealings in Dollar
deposits are also carried on in the London interbank market and banks are open for business in
London.
"LIBOR" shall mean, for any day, the rate (rounded upward, if necessary, to the
nearest 1/100th of 1%) equal to the composite London Interbank Offered Rate for one month
United States Dollar deposits which appears on the Telerate British Bankers Association LIBOR
Rates Page (or on any successor to or substitute for such Page providing rate quotations
comparable to those currently provided on such Page, or if there shall no longer exist a Telerate
British Bankers Association LIBOR Rates Page or no such rate is published or available at such
time for any reason, a comparable replacement rate determined by Bank in accordance with its
usual procedures) at approximately 11:00 a.m., London time, on the day that is (i) the date hereof
in calculating the interest rate for the period from the date hereof through and including October
31, 2007, and (ii) two (2) Business Days preceding the first day of the month in which such day
occurs, or if such day is not a Business Day, then the immediately preceding Business Day, in
calculating the interest rate from and after November 1, 2007.. As used herein, "Telerate British
Bankers Association LIBOR Rates Page" means the display designated as Page 3750 on the
Telerate System.
INTEREST: The unpaid balance of the loan evidenced by this Note (the "Loan") shall bear
interest at a rate per annum equal to the sum of (A) LIBOR lp tM (B) two hundred seventy-five
(275) basis points. Upon Maker's obtaining a certificate of occupancy with respect to the
improvements from the governmental authority having jurisdiction over the Real Property, the
interest rate will adjust to the sum of (A) LIBOR plus (B) two hundred fifty (250) basis points.
Such rate shall be reset as of the'first day of each calendar month during the term of this Note
commencing November 1, 2007.
PHLLI6.2120909.2-CL14EFFLE 1026107 817 AN
Interest shall be calculated on the basis of a 360 day year by multiplying the
interest rate in effect by a fraction, the numerator of which is the actual number of days in the
current billing period and the denominator of which is 360.
If Bank determines (which determination shall be final and conclusive) that, by
reason of circumstances affecting the eurodollar market generally, deposits in dollars (in the
applicable amounts) are not being offered to banks in the eurodollar market for the selected term,
or adequate means do not exist for ascertaining LIBOR, then Bank shall give notice thereof to
Maker. Thereafter, until Bank notifies Maker that the circumstances giving rise to such
suspension no longer exist, the interest rate for all amounts outstanding under this Note shall be
converted at the next rate reset date to a comparable interest rate determined by Bank exercising
reasonable commercial judgment. In addition, if, after the date of this Note, Bank shall
determine (which determination shall be final and conclusive) that any enactment, promulgation
or adoption of or any change in any applicable law, rule or regulation, or any change in the
interpretation or administration thereof by a governmental authority, central bank or comparable
agency charged with the interpretation or administration thereof, or compliance by Bank with
any guideline, request or directive (whether or not having the force of law) of any such authority,
central bank or comparable agency shall make it unlawful or impossible for Bank to make or
maintain or fund loans based on LIBOR, Bank shall notify Maker. Upon receipt of such notice,
until Bank notifies Maker that the circumstances giving rise to such determination no longer
apply, the interest rate on the outstanding balance of the Loan shall be converted to a comparable
interest rate determined by Bank exercising reasonable commercial judgment either (i) on the
next rate reset date if Bank may lawfully continue to maintain indebtedness based on LIBOR to
such day, or (ii) immediately if Bank may not lawfully continue to maintain indebtedness based
on LIBOR.
PAYMENT TERMS: The principal sum and interest shall be paid by Maker to Bank as follows:
A. Interest Only With Principal At Maturity: Interest shall be due and payable
commencing on December 1, 2007, and continuing on the first day of each month
thereafter until the indebtedness evidenced hereby has been paid in full. Any
outstanding principal and accrued interest shall be due and payable in full on
November 1, 2010 (the "Maturity Date").
B. Renewal Term: Maker shall have the privilege of extending the Maturity Date for
two successive periods of twelve (12) months each (the "Renewal Terms"),
provided (i) Maker shall give Bank at least sixty (60) days prior written notice of
Maker's election to extend; (ii) Maker is not then and has not previously been in
default under the Loan Documents (as hereinafter defined); and (iii) Maker shall
pay to Bank at the time of Maker's exercise of each extension option, an extension
fee in an amount equal to one-half of one percent (1/2%) of the aggregate of
(a) the amount of the Loan outstanding and unpaid as of the date Maker provides
Bank with notice of its election to exercise its extension option, plus (b) the
amount of the Loan which is unfunded as of such date.
Maker hereby authorizes Bank to charge Maker's deposit account at Bank for any
payment when due hereunder. Payments received will be applied to charges, fees and expenses
(including attorneys' fees), accrued interest and principal in any order Bank may choose, in its sole
discretion.
Maker agrees to pay Bank a prepayment fee in the event prepayment is made at
any time during the ten, of this Note in whole or in part for any reason and whether or not such
prepayment is voluntary. The fee shall be three percent (3%) of the amount prepaid. Said fee
shall be due and payable at the time prepayment is made and prior to satisfaction of any Loan
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Documents (as hereinafter defined). Any such prepayment shall be applied to installments due
hereunder in the inverse order of their maturity.
If any payment hereunder is not paid when due and continues unpaid for a period
of six (6) days thereafter, Maker agrees to pay to Bank, in addition to all amounts of principal
and interest, a late charge of five cents ($.05) for each one dollar ($1.00) so overdue, or such
lesser late charge as may be required by law, but in no event shall the late charge be less than
$25.00. The late charge is imposed for the purpose of defraying the Bank's expenses incident to the
handling of delinquent payments and is in addition to, and not in lieu of, the. exercise by Bank of
any rights and remedies hereunder, under the other Loan Documents or under applicable laws, and
any fees and expenses of any agents or attorneys which Bank may employ.
In order to secure payment of this Note and all other obligations of Maker to Bank
presently existing or hereafter arising or incurred (collectively, the "Obligations"), Maker hereby
pledges to Bank and grants to Bank a security interest in and a continuing lien and right of setoff
against, all property (real and personal, tangible and intangible) owned by Maker or in which
Maker has any interest or any power of pledge, hypothecation or other disposition, which Bank
shall have in its possession or control (including items in transit to Bank) at any time for any
reasons whatsoever, including, but not limited to monies, deposit accounts, stocks, bonds,
securities, mortgages, judgments, security interests, chattel paper, accounts, accounts receivable,
contract rights, general intangibles, insurance policies, instruments, documents, motor vehicle
titles, real estate, fixtures, goods, chattels, merchandise, inventory, equipment and all other items
of like kind and type and all additions and accessions thereto and all proceeds therefrom
(hereinafter called "Collateral"). The Bank shall have no duty or obligation with respect to the
Collateral.
Maker agrees to comply with each and every covenant, condition and term set
forth in this Note as well as all other documents (collectively, the "Loan Documents") given by
Maker or any other Obligor (as hereinafter defined) to Bank and agrees that any default under
any of the other Loan Documents shall also be an Event of Default hereunder. The terms and
provisions of the other Loan Documents are incorporated herein by reference. As used herein,
the term "Obligor" means any Maker and any Guarantor, and the term "Guarantor" means any
guarantor or surety of the Obligations of Maker to Bank existing on the date of this Note or arising
in the future.
Bank shall have the right at Makers expense to audit Maker's books and records
periodically including access to accounts receivable and payable as well as executory contract
records. Maker agrees to provide Bank and to cause any Obligor to provide Bank with periodic
financial statements as requested from time to time by Bank in form satisfactory to Bank.
Upon the occurrence of any of the following events, each of which shall constitute
an "Event of Default" hereunder, the entire unpaid amount of principal and interest hereunder
shall at the option of Bank become immediately due and-payable, together with the prepayment
fee described above (if any), without notice or demand: (a) if payment of principal or interest, as
aforesaid, is not paid when due, and continues unpaid for a period of five (5) days after written
notice from Bank to Maker (provided that Bank shall not be required to provide such notice more
than once in any twelve month period, and -after once giving such notice in any twelve month
period the failure of Maker to make any such payment for a period of five (5) days after the due
date shall constitute an Event of Default); or (b) a default under any instrument or agreement
evidencing and/or securing any other obligation of any Obligor to Bank; or (c) if any Obligor is
unable to pay its debts as they mature or if any Obligor becomes insolvent or shall voluntarily
suspend transaction of its business or operations; or (d) if any Obligor shall make an assignment
for the benefit of creditors or file a voluntary petition to reorganize or to effect a plan or other
arrangement with creditors or apply for or consent to the appointment of a receiver or trustee of
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all or part of its property, or (e) if any Obligor shall file an answer admitting the jurisdiction of
the court and the material allegations of an involuntary petition filed pursuant to the United
States Bankruptcy Code, as amended, or shall be adjudicated a bankrupt; or (f) if an order shall
be entered approving an involuntary petition to reorganize any Obligor or to effect a plan or
other arrangement with its creditors, or appointing a trustee or receiver of all or part of its
property; or (g) if any Obligor shall institute liquidation, dissolution, merger or consolidation
proceedings; or (h) if any Obligor dies or is incarcerated, or is adjudicated legally incompetent;
or (i) if there is entered against any Obligor a judgment, levy or lien or if a writ or warrant of
attachment, execution, garnishment, distraint, possession, or any similar process. shall be issued
by any court against all or a part of the property of any Obligor; or 0) if there is a taking of
possession of a substantial part of the property of any Obligor at the instance of any
governmental authority; or (k) if any Obligor fails to pay any income, excise, or other taxes of
any nature whatsoever prior to the time that they become delinquent; or (1) if any information or
signature heretofore or hereafter furnished to Bank by any Obligor in connection with any
Obligations is materially false or incorrect; or (m) if any Obligor fails to timely furnish to Bank
such financial and other information as Bank may reasonably request or require; or (n) if any
Obligor fails to perform or comply with any agreement with Bank or to pay any obligation
whatsoever to Bank when due; or (o) if Bank, in view of circumstances which in its
commercially reasonable judgment it considers adequate, believes that the credit of any Obligor
has become impaired or that a material adverse change has occurred in the financial condition of
any Obligor.
After an Event of Default, interest shall continue to accrue and be payable on
demand at a rate equal to three percent (3%) per annum in excess of the contracted interest rate
which would otherwise be applicable under this Note but not more than the maximum rate
allowed by law (the "Default Rate"). The Default Rate shall apply retroactively to the first such
Event of Default and shall continue until all Events of Default have been cured. Such interest
shall accrue notwithstanding the entry or opening of any judgment and shall be added to and
become part of the Obligations.
Upon the occurrence of an Event of Default hereunder, Bank shall have all rights
and remedies provided under all applicable law and shall be deemed to have exercised the same
immediately upon the occurrence of any such event without notice or future action, irrespective
of when any record of the same may thereafter be entered on Bank's books and Bank shall have
and may exercise as to the Collateral all rights and remedies provided under the Uniform
C
ommercial Code of Pennsylvania and under all other applicable laws; and Bank shall have the
right
Bank iimnme iately and without further action by it, to setoff against this Note all money owed by
any capacity to Maker, whether or not due, and also to setoff against all other
obligations of Maker to Bank all money owed by Bank in any capacity to Maker, and Bank shall
be deemed to have exercised such right of setoff and to have made a charge against any such
money immediately upon the occurrence of such default even though such charge is made or
entered on the books of Bank subsequent thereto. In addition thereto Bank may sell. all or any
part of any Collateral at private or public sale without advertisement or notice to or demand upon
Maker or any other Obligor, or upon seven (7) days notice, if notice is required, and Bank may
purchase the same or any part thereof at any such sale free of all trusts, claims or equity of
redemption. Bank shall not be required to resort to any particular security or persons to enforce
payment and Bank shall not be subject to any marshaling requirements or equities among the
person(s) designated as Maker or among any other Obligors.
No waiver of any default hereunder shall be construed as a waiver of any
subsequent default, and the exercise of any right hereunder shall not waive the right to exercise
such right thereafter.
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Maker does hereby authorize and empower the prothonotary or clerk or any
attorney of any court of record, following the occurrence. of an Event of Default, to appear
for and to CONFESS AND ENTER A JUDGMENT OR JUDGMENTS against Maker .or
any one of them, in favor of Bank, its successors and assigns, and any other holder hereof,
for which this, or a true copy hereof, shall be a sufficient warrant: (a) for such SUMS as are
due and/or may become due under this Note and the other Loan: Documents, and/or (b) in
any action of replevin instituted by Bank to obtain possession of any Collateral securing
any of the Obligations, with interest at the Default Rate as above provided and. the
prepayment fee described above (if any), with fifteen percent (15%) thereof added for
collection fees, and with costs of suit, at any one or more times after this Note becomes due,
with or without declaration filed with release of all errors, and without stay of execution;
and does hereby waive and release all relief. from any and all appraisements, stay,
exemption and homestead laws of any state, now in force or hereafter passed, and any right
to except to, strike off, appeal from or open any judgment so entered; and further does
waive the right of inquisition on any real estate that may be levied upon to collect this Note,
hereby voluntarily condemns the same and authorizes the entry upon the writ of execution
of such voluntary condemaation, and agrees that such real estate may be sold on a writ of
execution. MAKER FURTHER WAIVES ALL RIGHT TO PRIOR NOTICE AND
HEARING BEFORE ENTRY OF JUDGMENT: If a copy of this Note, verified by
affidavit by Bank or someone on behalf of Bank, shall have been filed in such action, it
shall not be necessary to. file the original Note as a warrant of attorney.
The authority and power to appear for and CONFESS JUDGMENT against
.Maker, shall not be exhausted by the initial exercise thereof and may be exercised as often
as Bank shall find it necessary and desirable and this Note shall be a sufficient warrant
therefor. Bank may CONFESS one or more JUDGMENTS in the same or different
jurisdictions for all or any part of the Obligations, without regard to whether JUDGMENT
has theretofore been CONFESSED on more than one occasion for the same obligations. in
the event any JUDGMENT CONFESSED against Maker is stricken or opened, upon
application by or on Maker's behalf for any :reason, Bank is hereby. authorised and
empowered to again. appear for and CONFESS JUDGMENT against Maker for any part
or all of the Obligations, as provided for herein, if doing so win cure any errors or defects
in such prior proceedings.
MAKER (ON BEHALF OF ITSELF AND ALL OBLIGORS) AND BANK
(BY ITS ACCEPTANCE HEREOF) KNOWINGLY, VOLUNTARILY,
INTENTIONALLY, AND IRREVOCABLY WAIVE ANY AND ALL RIGHTS SUCH
PARTIES MAY HAVE TO A, TRIAL BY JURY. MAKER (ON BEHALF OF ITSELF
AND ALL OBLIGORS) ALSO KNOWINGLY, VOLUNTARILY,,.INTENTIONALLY,
AND IRREVOCABLY WAIVES ANY AND ALL RIGHTS WHICH MAKER MAY
HAVE TO RAISE COUNTERCLAIM IN CONNECTION WITH ANY LITIGATION
ARISING OUT OF THIS NOTE OR THE LOAN DOCUMENTS, OR ANY COURSE OF
CONDUCT, COURSE OF DEALING, STATEMENTS (WHETHER VERBAL OR
WRITTEN) OR ACTIONS OF BANK AND/OR ANY OBLIGOR OR IN. ANY
LITIGATION IN ' WHICH ANY OBLIGOR AND BANK ARE ADVERSE PARTIES.
THIS PROVISION IS A MATERIAL INDUCEMENT FOR BANK'S GRANTING THE
LOAN(S) SUBJECT TO THIS NOTE.
If any provision of this Note shall for any reason be held to be invalid or
unenforceable, such provision shall not affect. any other pro
vision of this Note that can be given
effect without such provision and this Note shall be construed
contained herein. as if such provision has never been
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All agreements between Maker and Bank are hereby expressly limited so that in
no contingency or event whatsoever, whether by reason of acceleration of maturity of the
indebtedness evidenced hereby or otherwise, shall the amount paid or agreed to be paid to Bank
for the use or the forbearance of the indebtedness evidenced hereby exceed the maximum rate
permissible under applicable law. As used herein, the tern "applicable law" shall mean the law
to effect as of the date hereof; provided, however, that in the event there is a change in the law
which results in a higher permissible rate of interest, then this Note shall be governed by such
new law as of its effective date. If, under or from any circumstances whatsoever, fulfillment of
any provision hereof or of any of the Loan Documents at the time of performance of such
provision shall be due, shall involve transcending the limit of such validity prescribed by
applicable law, then the obligation to be fulfilled shall automatically be reduced to the limits of
such validity; and if, under or from any circumstances whatsoever Bank should ever receive as
interest an amount which would exceed the highest lawful rate, such amount which would be
excessive interest shall be applied to the reduction of the principal balance evidenced hereby and
not to the payment of interest. This provision shall control every other provision of all
agreements between Maker and Bank.
This Note shall be binding upon the undersigned and their respective heirs,
personal representatives, successors and assigns, and the benefits hereof shad inure to the benefit
bf Bank and its successors and assigns. If this Note is executed by more than one party, it shall
e the joint and several obligations of all such parties and the word "Maker„ whenever used
herein shall be construed to mean each of the persons or entities who have executed this Note.
In the event that Bank engages an attorney to represent it in connection with
(1) any alleged default by any Obligor under any.of the Loan D
administration or modification of any of Bank's ri
? oedies under the enforcement,
Documents, (3) any. potential and/or actual b s and remedies under any. of the Loan
commenced by or against any Obligor, and/or. (4) any or other insolvency proceedings
out of or related to any of the foregoing, the Loan Documents potential
or any of the Obligaationss,then
Maker shall be liable to and shall reimburse Bank, on demand for all attorneys' fees, costs and
expenses incurred by Bank in connection with any of the foregoing. Maker shall also be liable
and shall reimburse Bank, on demand, for all other costs and ex ,
incurred by Bank in connection with the collectio preservation n (indr. liquidation attorneys fees)
Collateral and/or in the enforcement of any Obligor's obligations hereunder ad dr an any
Loan Documents. any o of the
Presentment for payment or acceptance, demand and protest, and notice of
dishonor of payment or acceptance, notice of protest and notice of any renewal, extension,
modification or change of time, manner, place or terns. of payment are hereby waived by Maker.
Any notice to Maker shall be sufficiently served for all purposes if placed in the mail addressed
to, or left upon the premises of the address of Maker shown on the Bank's records. Bank may
surrender this Note to any person paying the final installment or payment due hereunder, and
may endorse or assign it to such person or his order without recourse.
The parties agree and consent to the exclusive jurisdiction of the federal and state
courts located in Pennsylvania in connection with any matters arising hereunder, including the
collection and enforcement hereof, except as Bank may otherwise elect.
Pennsylvania. This Note shall be governed by the substantive laws of the Commonwealth of
-6-
WITNESS the due execution hereof as a document under seal, as of the date first written above,
with the intent to be legally bound hereby.
WITNESS:
i
SHIPPENSBURG APEX, LP, a Pennsylvania
limited partnership
By: Shippensburg Apex, LLC, a Pennsylvania
limited liability company, its sole general
partner
By: 2vl'c
Robert P. S anaging Member
-7-
06/16/2010 08:29 7172332730 SECURITY SEARCH PAGE 17/22 'I
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 204742316
Recorded On 11/0007 At 11:09:18 AM
* Instrument Type - MORTGAGE
Invoice Number - 8434 - User ID - RAK
* Mortgagor - SHIPPENSBURG APEX LP
* Mortgagee - ROYAL BANK AMERICA
* Customer - SUBURBAN PHIL
* FEES
STATE WRIT TAX $0.50
STATE JCS/ACCZSS TO $10.00
JUSTICE
RECORDING FEES - $47.50
RECORDER OF DEEDS
AFFORDABLE SOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCSIVZS FEE $3.00
TOTAL PAID $74.50
* Total Pages - 23
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
I Certify this to be recorded
in Cumberland County PA
AA%
OR RECORDER O D DS
• - Information denoted by an asterisk may, change during
the verification process and may not be reflected on this page.
imu?dnio
iZ
Prepared By and Return To:
Curt L. Heftler, Esquire
Reed Smith LLP
2500 One Liberty Place
1650 Market Street
Philadelphia, PA 19103
(215) 851-8186
Tax Parcel Number: 36-35-2385-131
OPEN-END MORTGAGE AND SECURITY AGREEMENT
THIS MORTGAGE SECURES FUTURE ADVANCES.
THIS MORTGAGE made this 26th day of October, 2007, from SHIPPENSBURG
APEX, LP, a Pennsylvania limited partnership with an address of 401 E. Elm Street,
Conshohocken, Pennsylvania 19428 ("Mortgagor"), to ROYAL BANK AMERICA, a
Pennsylvania banking corporation with an office at 732 Montgomery Avenue, Narberth,
Pennsylvania 19072 ("Mortgagee").
WITNESSETH:
Mortgagor has executed and delivered to Mortgagee a promissory note bearing even date
herewith, wherein Mortgagor promises to pay to the order of Mortgagee the principal sum of
Sixteen Million Six Hundred Sixty-Seven Thousand Fifteen and 00/100 Dollars
($16,667,015.00) lawful money of the United States of America, with interest thereon at the rate
and times, in the manner and according to the terms and conditions specified in such note
(together with any and all restatements thereof or amendments thereto, the "Note"). Mortgagor
has also executed and delivered or caused to be executed and delivered certain other agreements
and instruments in connection with the Note (the Note, and all other agreements and instruments
executed in connection with the loan evidenced thereby, being sometimes hereinafter collectively
referred to as the "Loan Documents").
NOW, THEREFORE, for the purpose of securing the payment and performance of all
indebtedness, obligations and liabilities of Mortgagor to Mortgagee of every kind and
description, direct or indirect, secured or unsecured, joint or several, absolute or contingent, due
or to become due, including any overdrafts, whether for payment or performance, now existing
or hereafter arising, whether presently contemplated or not, regardless of how the same arise, or
by what instrument, agreement or book account they may be evidenced, or whether evidenced by
any instrument, agreement or book account, including, but not limited to all obligations under the
Note, all loans (including, any loan by modification, renewal or extension), all indebtedness,
obligations and liabilities under or in connection with swap agreements (as defined in l 1 U.S.C.
§ 101, as in effect from time to time) with Mortgagee or any of its affiliates, all undertakings to
take or refrain from taking any action, all indebtedness; liabilities or obligations owing from
PHLL18-2120914,1-CI14EFFLE 10ri=7 &tS AM
Mortgagor to others which Mortgagee may have obtained by purchase, negotiation, discount,
assignment or otherwise, and all interest, taxes, fees, charges, expenses and attorney's fees
(whether or not such attorney is a regularly salaried employee of Mortgagee, any parent
corporation or any subsidiary or affiliate thereof, whether now existing or hereafter created)
chargeable to Mortgagor or incurred by Mortgagee under this Mortgage, or any other document
or instrument delivered in connection herewith or therewith (collectively, the "Obligations"),
Mortgagor has granted, conveyed, aliened, enfeoffed, released, confirmed and mortgaged, and by
these presents does hereby grant, convey, alien, enfeoff', release, confirm and mortgage unto
Mortgagee, all that certain tract or parcel of land located in Shippensburg Township,
Cumberland County, Pennsylvania and more particularly described in Exhibit "A" attached
hereto and made a part hereof (hereinafter referred to as the "Land").
TOGETHER WITH all of Mortgagor's right, title and interest now owned or hereafter
acquired in:
(a) all easements, rights-of-way, gores of land, streets, ways, alleys, passages,
rights, waters, water courses, water rights and powers, riparian rights, mineral rights, privileges,
tenements, hereditaments and appurtenances whatsoever in any way belonging, relating or
appertaining to any of the Land or which hereafter shall in any way belong, relate or be
appurtenant thereto, whether now owned or hereafter acquired by Mortgagor, and the reversions
and remainders; and
(b) all rents, issues, profits, receipts, lodging revenues, hotel revenues and
other income of any and all kinds received or receivable and due or to become due in connection
with the Land or in the operation of any buildings and improvements now or hereafter erected
thereon, including but not limited to the lease of, or operation of any income-producing facility
on, the Land or the buildings and improvements thereon; and
(c) all buildings and.other improvements erected or hereafter erected.upon the
Land and all building materials, fixtures, building machinery and building equipment delivered
on site to the Land during the course of, or in connection with, the construction of, or
reconstruction of, or remodeling of any buildings and improvements from time to time during the
term hereof, and
(d) all fixtures, appliances, machinery, furniture and equipment of any nature
whatsoever, and other articles of personal property now or at any time hereafter installed in,
attached to or situated in or upon the Land or any buildings and improvements now or hereafter
erected on, upon, under or forming a part of the Land, or used or intended to be used in
connection with the Land, or in the.operation of any buildings and improvements now or
hereafter erected thereon, or in the operation or maintenance of any. such building or
improvement, plant or business situate thereon, whether or not the personal property is or shall
be affixed thereto; and
(e) all licenses (including but not limited to operating licenses or similar
matters), contracts, management contracts or agreements, franchise agreements, permits, bonds,
authorities or certificates required or used in connection with the ownership of, or the operation
or maintenance of the real property or improyernents or personal property, provided that no such
contract, agreement, license or the like shall be binding upon Mortgagee except with Mortgagee's
prior consent; and
-2-
(f) all proceeds of the conversion, voluntary or involuntary, of any of the
foregoing into cash or liquidated claims, including, without limitation, proceeds of insurance and
condemnation awards.
All of the Land, buildings and improvements, fixtures, machinery, furniture, equipment,
tenements, hereditaments and appurtenances, proceeds and other property interests above
described and hereby mortgaged are sometimes collectively referred to herein as the "Mortgaged
Property".
TO HAVE AND TO HOLD the Mortgaged Property hereby conveyed or mentioned and
intended so to be, unto Mortgagee, forever.
PROVIDED ALWAYS, and this instrument is upon the express condition that, if
Mortgagee is paid the principal sum mentioned in the Note, the interest thereon and all other
sums payable to Mortgagee as are secured hereby, in accordance with the provisions of the Note
and this Mortgage, at the times and in the manner specified, without deduction, fraud or delay,
and Mortgagor performs and complies with all the agreements, conditions, covenants, provisions
and stipulations contained herein and in the Loan Documents, then this Mortgage and the estate
hereby granted shall cease and become void.
1. Mortgagor's Representations. Mortgagor warrants and represents that it possesses
a good and marketable title to an indefeasible fee simple estate in the Mortgaged Property, that
Mortgagor has full power and lawful authority to subject the Mortgaged Property to the lien of
this Mortgage in the manner and form herein provided; that it shall be lawfW for Mortgagee at aII
times to enter upon, hold, occupy and enjoy the Mortgaged Property and every part thereof; that
this Mortgage is a valid and enforceable first lien on the Mortgaged Property; that the Mortgaged
Property is free from all liens and encumbrances subject only to those title exceptions listed in
the mortgagee title insurance policy approved by and issued to Mortgagee, insuring the priority
of the lien of this Mortgage; that all information, reports, papers and data given to Mortgagee
with respect to the Mortgaged Property or Mortgagor are accurate in all material respects; that no
notice of taking by eminent domain or condemnation of any part of the Mortgaged Property has
been received, and Mortgagor has no knowledge that any of such is contemplated; that the
Mortgaged Property-and the present use and occupancy thereof are in compliance with all
applicable laws, rules, ordinances, statutes and regulations and is not a nonconforming use; that
Mortgagor has received no notice with respect to the Mortgaged Property from any
governmental authority of any violation of any codes, zoning or use regulations or other laws or
ordinances; that there are no unpaid bills in existence for labor or materials used in making
improvements or repairs respecting the Mortgaged Property or for the services of architects,
surveyors, engineers or interior designers incurred in connection therewith or for equipment,
appliances, fixtures or other personalty attached to the Mortgaged Property except as may have
previously been disclosed to'Mortgagee in writing, and that no part of the Mortgaged Property is
located in an area designated by any federal, state or local governmental entity as having a
special flood hazard.
2. Pavment and Performance. Mortgagor shall pay to Mortgagee, in accordance
with the terms of the Note and this Mortgage, the principal and interest, and other sums therein
set forth; shall perform and comply with all the agreements, conditions, covenants, provisions
and stipulations of the Loan Documents and this Mortgage; and shall timely perform all of its
material obligations and duties as landlord under any lease of all or any portion of the Mortgaged
Property now or hereafter in effect.
-3-
3. Maintenance of Mortgaged Propert y. Mortgagor shall keep and maintain or cause
to be kept and maintained all buildings and improvements now or at any time hereafter erected
on the Mortgaged Property, the sidewalks and curbs abutting them and all items of inventory,
equipment and any other personal property necessary for or used in the maintenance and
operation of the Mortgaged Property, in good order and condition and in a rentable and
tenantable state of repair, and will make or cause to be made, as and when necessary, all repairs,
renewals and replacements, structural and nom, exterior and interior, ordinary and
extraordinary, foreseen and unforeseen; provided, however, that no new construction on the
Mortgaged Property or any structural work on any building erected at any time on or constituting
a part of the Mortgaged Property shall be performed (including without limitation the removal or
demolition of such building or the alteration of the structural character or exterior of such
building) without the prior written consent of Mortgagee. Mortgagor shall abstain from and shall
not permit the commission of waste in or about the Mortgaged Property or permit the Mortgaged
Property to become vacant, deserted or abandoned. Mortgagor shall not take or permit any
action with respect to a change in the zoning ordinances or regulations affecting the Mortgaged
Property without the prior written consent of Mortgagee.
4. Insurance.
(a) Mortgagor shall keep the Mortgaged Property continuously insured, to the
extent of its full insurable value, against loss or damage by fire, with extended coverage and
against such other hazards (including, without limitation, coverage against loss or damage by
vandalism, malicious mischief, sprinkler leakage and flood) as Mortgagee may reasonably
require, and shall maintain commercial general liability insurance and worlonen's compensation
insurance in such total amounts as Mortgagee may reasonably rewire from time to time. Such
insurance shall contain agreed amount endorsements, inflation guard endorsements and
replacement cost endorsements reasonably satisfactory to Mortgagee. During the course of any
construction or repair of improvements on the Mortgaged Property for which builder's risk
insurance may be obtained, Mortgagor shall acquire and maintain builder's completed value risk
insurance against all risks of physical loss, including collapse and transit coverage, during
construction of such improvements, with deductibles not to exceed $10,000 in non-reporting
form, covering the total value of work performed and equipmerrt, supplies aad materials
furnished. All property and builder's risk insurance shall include protection for continuation of
income for a period of twelve (12) months, in the event of any damage caused by the perils
referred to above. All policies of insurance, including policies for any amounts carried in excess
of the required minimum and policies not specifically required by Mortgagee, shall be in form
satisfactory to Mortgagee, issued by an insurance company or companies qualified to insure
property located in Pennsylvania and satisfactory to Mortgagee; shall name Mortgagee as an
additional insured, shall name Mortgagee as the loss payee, shall be endorsed with a standard .
mortgagee clause in favor of Mortgagee (substantially equivalent to the Insurance Services
Office standard mortgagee endorsement) not subject to contribution, and shall provide for at least
thirty (30) days' notice of cancellation, termination, modification, refusal to renew or reduction
to Mortgagee. If the insurance, or any part thereof, shall expire, or be withdrawn, or become
void or unsafe by Mortgagor's breach of any condition thereof, or become void or unsafe by
reason of the failure or impairment of the capital of any company in which the insurance may
then be carried, or if for any reason in the reasonable opinion of Mortgagee the insurance shall be
unsatisfactory to Mortgagee, Mortgagor shall place new insurance on the Mortgaged Property
satisfactory to Mortgagee.
(b) In the event of loss, Mortgagee shall have the exclusive right to adjust,
collect and compromise all insurance claims, and Mortgagor shall not adjust, collect or
-4-
compromise any claims under said policies without Mortgagee's prior written consent. Each
insurance company concerned is hereby authorized and directed to make payment under such
insurance, including return of unearned premiums, directly to Mortgagee instead of to Mortgagor
and Mortgagee jointly, and Mortgagor irrevocably authorizes Mortgagee to endorse any draft
therefor, such authority to be deemed to be a power coupled with an interest. Mortgagee shall
have the right to retain and apply the proceeds of any such insurance, at its election, to reduction
of the indebtedness secured hereby, or to restoration or repair of the property damaged on such
terns as Mortgagee may specify, at Mortgagee's sole discretion (and if the proceeds are applied
to restoration or repair Mortgagee may apply any excess proceeds to the reduction of the
indebtedness secured hereby), If Mortgagee elects to retain and apply such proceeds to the
reduction of the indebtedness secured hereby, Mortgagee shall have the right in its sole
discretion to apply any such proceeds, in such order and in such amounts as Mortgagee may
elect, against: (i) any amounts payable by Mortgagor hereunder or under the Loan Documents,
and/or (ii) accrued and unpaid interest under the Note, and/or (iii) the outstanding principal
balance of the Note. No application of insurance proceeds to the payment of the Note shall
postpone any of the current installments of principal or interest becoming due under such Note
until such Note and all interest and other sums due hereunder and thereunder have been paid in
full.
(c) Such policies of insurance and all renewals thereof are hereby assigned to
Mortgagee as additional security for payment of the indebtedness hereby secured and Mortgagor
hereby agrees that any values available thereunder upon cancellation or termination of any of
said policies or renewals, whether in the form of return of premiums or otherwise, shall be
payable to Mortgagee as assignee thereof. If Mortgagee becomes the owner of the Mortgaged
Property or any part thereof by foreclosure or otherwise,. such policies, including all right, title
and interest of Mortgagor thereunder, shall become the absolute property of Mortgagee. In
addition, Mortgagor will deliver the originals or certified copies of all such policies to
Mortgagee, and, not less than thirty (30) days.prior to the expiration date of each such policy,
will deliver to Mortgagee a renewal policy or policies (or certified copies of such policies)
marked "premium paid" or accompanied by other evidence of payment satisfactory to
Mortgagee. Mortgagor shall not change the resent use of any portion of the Mortgaged
Property in any manner or permit any condition to exist on the Mortgaged Property which would
permit an insurer to cancel or increase the premium for any insurance policy or invalidate such
policy in whole or in part. - Mortgagor shall not take out separate insurance concurrent in form or
contributing in the event of loss with that required to be maintained under this Paragraph 4 unless
Mortgagee is included thereon as a named insured with loss payable to Mortgagee under a non-
contributory mortgagee clause satisfactory to Mortgagee.
whenever any rY Mortgagor shall immediately notify
Mortgagee y separate insurance is taken out, specifying the insurer thereunder
and full particulars as to the policies evidencing the same.
5. Taxes and Other Char es. Before interest or penalties are due thereon and
otherwise when due, Mortgagor shall pay all taxes, assessments, levies, liabilities, obligations,
encumbrances, water and sewer rents and all other charges or claims of every nature and kind
which may be imposed, suffered, placed, assessed, levied, or filed at any time against Mortgagor,
the Mortgaged Property or any part thereof or against the interest of Mortgagee therein, or with
respect to the Note or Mortgage and/or the ownership of either thereof by Mortgagee, or which
by any present or future law may have priority over the indebtedness secured hereby either in
lien or in distribution out of the proceeds of any judicial sale, without regard to any law
heretofore or hereafter to be enacted imposing payment of the whole or of any part upon
Mortgagee. Within fifteen (15) days after the payment of any such tax, assessment, levy,
liability, obligation or encumbrance, Mortgagor shall deliver to Mortgagee evidence acceptable
-5-
to Mortgagee of such payment. Provided, however, that if, pursuant to this Mortgage or
otherwise, Mortgagor shall have deposited with Mortgagee before the due date thereof sums
sufficient to pay any such taxes, assessments, levies, water and sewer rents, charges or claims,
and Mortgagor is not otherwise in default, they shall be paid by Mortgagee. It is expressly
agreed that no credit shall be claimed or allowed on the interest payable on the Note because of
any taxes or other charges paid.
6. Installments for Insurance, Taxes and Other Charges. Without limiting the effect
of Paragraphs 4 and 5 hereof, Mortgagee may require Mortgagor to pay to Mortgagee (or to such
other entity as Mortgagee shall designate), monthly with the monthly installments of interest (or
the monthly installments of principal and interest when applicable), an amount equal to one-
twelfth (1/12) of the annual premiums for the insurance policies referred to hercinabove and the
annual real estate taxes, water and sewer rents, any special assessments, charges or claims and
any other item which at any time may be or become alien upon the Mortgaged Property prior to
the lien of this Mortgage; and on demand from time to time Mortgagor shall pay to Mortgagee
any additional sums necessary to pay the premiums and other items, all as estimated by
Mortgagee. The amounts so paid shall be security for the premiums and other items and shall be
used in payment thereof if Mortgagor is not otherwise in default hereunder. No amount so paid
shall be deemed to be trust funds but may be commingled with general funds of Mortgagee and
no interest shall be payable thereon. If, pursuant to any provision of this Mortgage or the Note,
the whole amount of the unpaid principal debt becomes due and payable, Mortgagee shall have
the right, in its sole discretion, to apply any amount so held, in such order and in such amounts as
Mortgagee may elect, against: (a) any amounts payable by Mortgagor hereunder or under the
Loan Documents, and/or (b) accrued and unpaid interest under the Note, and/or (c) the
outstanding principal balance of the Note. At Mortgagee's option, Mortgagee from time to time
may waive, and after any such waiver may reinstate, the provisions of this paragraph requiring
the monthly payments. Mortgagor will furnish to Mortgagee bills and other requests for
payment in sufficient time to enable Mortgagee to pay such premiums, taxes, assessments,
levies, charges and fees as provided above.
7. Mortor's Existence and Taxes. Mortgagor shall keep in effect its existence
and rights under the laws of the state of its formation, if applicable, and its right to own property
and transact business in the state in which the Mortgaged Property is situated during the entire
time that it has any ownership interest in the Mortgaged Property. Mortgagor shall file returns
for all taxes owing by Mortgagor with the proper authorities, bureaus or departments and it shall
pay, when due and payable and before interest or penalties are due thereon, all taxes owing by
Mortgagor to the United States, to such state of formation and to the state in which the
Mortgaged Property is situated and any political subdivision thereof, and shall produce to
Mortgagee recerpts showing payment of any and all such taxes, charges or assessments prior to
the last dates upon which such taxes, charges or assessments are payable without interest or
penalty charges, and within ten (]0) days of receipt thereof all settlements, notices of deficiency
or ovcrassessment and any other notices pertaining to Mortgagor's tax liability which may be
issued by the United-States, such state of formation, the state in which the Mortgaged Property is
situated and any political subdivision thereof.
8. Documentary and Other Stamps. If at any time the United States, the state in
which the Mortgaged Property is located or any political subdivision thereof, or any department
or bureau of any of the foregoing, shall require documentary, revenue or other stamps on the
Note secured hereby or this Mortgage, Mortgagor on demand shall pay forthem with any interest
or penalties payable thereon.
-6-
9. Future Taxes. If hereafter any law or ordinance shall be adopted imposing a tax
directly or indirectly on Mortgagee with respect to the Mortgaged Property, the value of
Mortgagor's equity therein, or the indebtedness evidenced by the Note and secured by this
Mortgage, Mortgagee, at its election, shall have the right at any time after the tax has been
imposed to give Mortgagor written notice declaring that the principal debt, with interest and
other appropriate charges, shall be due on a specified date not less than sixty (60) days thereafter
which notice shall specify the nature of the tax which is the basis for acceleration; provided,
however, that such election shall be ineffective if, prior to the specified date, Mortgagor lawfully
pays the tax (in addition to all other payments required hereunder) and agrees to a the tax
whenever it becomes due and payable thereafter, which agreement shall then constitute a part of
this Mortgage.
10. Security Agreement.
(a) This Mortgage constitutes a security agreement within the meaning of the
Uniform Commercial Code, as adopted and enacted and as in effect from time to time in the
Commonwealth of Pennsylvania (the "Uniform Commercial Code"). Terms used herein which
are defined in the Uniform Commercial Code and not otherwise defined herein shall have the
respective meanings ascribed to such terms in the Uniform Commercial Code. To the extent the
definition of any category or type of collateral is modified by any amendment, modification or
revision to the Uniform Commercial Code, such modified definition will apply mitomatically as
of the date of such amendment, modification or revision.
(b) To secure the Obligations, Mortgagor, as debtor, hereby assigns and giants
to Mortgagee; as secured party, a continuing hen on and security interest in all personal property
of Mortgagor, including the following, all whether now owned or hereafter acquired or arising
and wherever located: (i) accounts (including health-care-insurance receivables and credit card
receivables); (ii) securities entitlements, securities accounts, commodity accounts, commodity
contracts and investment property; (iii) deposit accounts; (iv) instruments (including promissory
notes); (v) documents (including warehouse receipts); (vi) chattel paper (including electronic
chattel paper and tangible chattel paper); (vii) inventory, including raw materials, work in
process, or materials used or consumed in Mortgagor's business, items held for sale or lease or
furnished or to be furnished under contracts of service, sale or lease, goods that are returned,
reclaimed or repossessed; (viii) goods of every nature, including stock-in-trade, goods on
consignment, standing timber that is to be cut and removed under a conveyance or contract for
sale, the unborn young of animals, crops grown, growing, or to be grown, manufactured homes,
computer programs embedded in such goods and farm products; (ix) equipment, including
machinery, vehicles and furniture; (x) fixtures; (xi) agricultural ,liens; (xii) as-extracted collateral;
(xiii) commercial tort claims, if any; (xiv) letter of credit rights; (xv) general intangibles, of
every kind and description, including payment intangibles, software, computer information,
source codes, object codes, records and data, all existing and future customer lists, choses in
action, claims (including claims for indemnification or breach of warranty), books, records,
patents and patent applications, copyrights, trademarks, tradenames, tradestyles, trademark
applications, goodwill, blueprints, drawings, designs and plans, trade secrets, contracts, licenses,
license agreements, formulae, tax and any other types of refunds, returned and unearned
insurance premiums, rights and claims under insurance policies; (xvi) all supporting obligations
of all of the foregoing property; (xvii) all property of Mortgagor now or hereafter in Mortgagee's
possession or in transit to or from, or under the custody or control of, Mortgagee-or any affiliate
thereof, (xviii) all cash and cash equivalents thereof; and (xix) all cash and noncash proceeds
(including insurance proceeds) of all of the foregoing property, all products thereof and all
additions and accessions thereto, substitutions therefor and replacements thereof.
-7-
(c) By its signature hereon, Mortgagor hereby irrevocably authorizes
Mortgagee to file against Mortgagor one or more financing, continuation or amendment
statements pursuant to the Uniform Commercial .Code in form satisfactory to Mortgagee, and
Mortgagor will pay the cost of preparing and filing the same in all jurisdictions in which such
filing is deemed by Mortgagee to be necessary or desirable in order to perfect, preserve and.
Protect its security interests. If required by Mortgagee, Mortgagor will execute all
documentation necessary for Mortgagee to obtain and maintain perfection of its security interests
in the personal property of Mortgagor.
(d) Upon any Event of Default hereunder or under the Note, Mortgagee shall
have, in addition to any other rights and remedies hereunder .or under the Note, all of the rights
and remedies granted to a secured party under the Uniform Commercial Code with respect to
such personal property. To the extent permitted by law, Mortgagor and Mortgagee.agree that the
items set forth on the financing statements shall be treated as part of the real estate and
improvements regardless of the fact that such items are set forth in the financing statements.
Such items are contained in the financing statements to create a security interest in favor of
Mortgagee in the event such items are detm-rnined to be personal property under the law.
Notwithstanding any release of any or all of that property included in the Mortgaged Property
which is deemed "real property", any proceedings to foreclose this Mortgage or its satisfaction of
record, the terms hereof shall survive as a security agreement with respect to the security interest
created hereby and referred to above until the repayment or satisfaction in full of the obligations
of Mortgagor as are now or hereafter evidenced by the Note.
(e) To the extent permitted under the Uniform Commercial Code, Mortgagor
waives all rights of redemption and all other rights and remedies of a debtor thereunder and all
formalities prescribed by law relative to the sale or disposition of the personal property after the
occurrence of an Event of Default hereunder and to all other rights and remedies o Mortgagor
with respect thereto. In. exercising its right to take possession of the personal property upon 'the
occurrence of an Event of Default. hereunder, Mortgagee may enter upon the Mortgaged Property
without being guilty of trespass or any other wrong-doing, and without liability for damage
thereby occasioned
(fl Mortgagor shall reimburse Mortgagee, on.demand, for all reasonable
expenses of retaking, holding, preparing for sale, lease or other use or disposition, selling,
leasing or otherwise using or disposing of the personal property which are incurred or paid by
Mortgagee, including, without limitation, all attorneys' fees, legal expenses and costs, and all
such expenses shall be added to Mortgagor's obligations to Mortgagee and shall be secured
hereby.
11. Compliance with Laws and R-e ulabons. Mortgagor shall comply with all laws,
ordinances, regulations and orders of all federal, state, municipal and other governmental.
authorities relating to the Mortgaged Property, including without limitation the Americans with
Disabilities Act (the "ADA"). Mortgagor certifies that all renovations; construction and
improvements with respect to the Mortgaged Property are and shall be in compliance with the
ADA. Mortgagor will pay all license fees and similar municipal charges for the use of the
Mortgaged Property and any other areas now or hereafter comprising part thereof or used in
connection therewith and will not, unless so required by a governmental agency having
jurisdiction, discontinue use or occupancy of any portion of the Mortgaged Property without the
prior written consent of Mortgagee. Mortgagor shall not take or permit any action with respect
to the Mortgaged Property which will in any manner impair the security of this Mortgage.
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12. In ection• Undated A raisal. Mortgagee and any persons authorized by
Mortgagee shall have the right at any time, to enter the Mortgaged Property at a reasonable hour
to inspect and photograph its condition and state of repair and/or for the purpose of appraising
the same. Mortgagee may, from time to time, order an updated appraisal of the Mortgaged
Property, which appraisal shall be prepared by an appraiser selected by Mortgagee at the sole
cost of Mortgagor..
13. Declaration of No Set-Off. Within one (1) week after being requested to do so by
Mortgagee, Mortgagor shall certify to Mortgagee or to any proposed assignee of this Mortgage,
in a writing duly acknowledged, the amount of principal, interest and other charges then owing
on the obligation secured by this Mortgage and by prior liens, if any, and whether Mortgagor
claims any set-offs or defenses against Mortgagor's obligation to pay such amounts, and if so the
precise basis for such set-offs or defenses.
14. Financial Statements and Information.
(a) Mortgagor shall furnish Mortgagee, by June 1st of each year during-the
entire term of the loan secured hereby, with financial statements reflecting, in reasonable detail, a
balance sheet for the operation of the Mortgaged Property, a fully itemized statement of the gross
income and expenses of the Mortgaged Property for such fiscal year, and a balance sheet and
profit and loss statement for Mortgagor including contingent liability schedules, with notes to the
financial statements, all prepared by a certified public accountant acceptable to Mortgagee.
(b) . Mortgagor shall furnish Mortgagee copies of its federal income tax returns
(including K-1 schedules, if applicable) within fifteen (15) days after the filing thereof.
(c) Mortgagor agrees to make the books and accounts relating to the
Mortgaged Property and Mortgagor's operations available for ion by Mortgagee, or its
representatives, upon written request at any reasonable time and er agrees to furnish
Mortgagee with such additional financial statements or information as may be requested from .
time to time by Mortgagee.
(d) Mortgagor shall cause each guarantor or surety of the loan secured hereby
to furnish Mortgagee such financial information as may be requested from time to time by
Mortgagee including (i) financial statements in a form satisfactory to Mortgagee with
verification of liquid assets by June 1st of each year during the entire term of the loan secured
hereby, and (ii) copies of their federal income tax returns (including K 1 schedules, if applicable)
within fifteen (15) days after the filing thereof.
15. R aired Notices. Mortgagor shall notify Mortgagee promptly of the occurrence
of any of the following:
(a) a fire or other casualty causing damage to the Mortgaged Property;
(b) receipt of notice of eminent domain proceedings or condemnation of all or
any part of the Mortgaged Property;
(c) receipt of notice from any governmental authority relating to the structure,
use or occupancy of the Mortgaged Property;
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(d) receipt of any notice from any tenant of all or any portion of the
Mortgaged Property;
(e) substantial change in the occupancy of the Mortgaged Property;
(f) commencement of any litigation affecting the Mortgaged Property;
(g) receipt of any notice from the holder or claimant of any lien or security
interest in the Mortgaged Property or any part thereof; or
(h) receipt by any Obligor (as defined in the Note) of any notice of default
with respect to any other indebtedness of any Obligor for borrowed money.
16. Condemnation.
(a) In the event of any condemnation or taking of any part of the.Mortgaged
Property by eminent domain, or other injury to or decrease in the value of the Mortgaged
Property by any public or quasi-public authority or corporation, all proceeds (that is, the award
or agreed. compensation for the damages sustained) allocable to Mortgagor are hereby assigned
by Mortgagor to Mortgagee to fiuher secure the payment of the indebtedness secured hereby.
No settlement for damages sustained shall be made by Mortgagor without Mortgagee's prior
written approval. Mortgagee is authorized and empowered (but not required) to collect and
receive any such condemnation award and all condemnation proceeds which then shall be
applied in the order and in the amounts that Mortgagee, in Mortgagees sole discretion, may
elect, to the reduction of the indebtedness secured hereby, or toward payment to Mortgagor, on
such terms as Mortgagee may specify, to be used for the sole purpose of altering, restoring or
rebuilding any part of the Mortgaged Property which may have been altered, damaged or
destroyed as a result of the taking, or other injury to the Mortgaged Property. Mortgagor shall
execute such further assignments of any such awards as Mortgagee may require. If Mortgagee
elects to apply such proceeds to reduction of the indebtedness secured hereby, Mortgagee shall
have the right in its sole discretion to apply any such proceeds, in such order and in such
amounts as Mortgagee may elect, against: (i) any amounts payable by Mortgagor hereunder or
under the Loan Documents, and/or (ii) accrued and unpaid interest under the Note, and/or
(iii) the outstanding principal balance of the Note.
(b) If prior to the receipt of the proceeds by Mortgagee the Mortgaged
Property shall have been sold on foreclosure of this Mortgage, Mortgagee shall have henght to
receive the proceeds to the extent of (i) any deficiency found to be due to Mortgagee in
connection with the foreclosure sale, with legal interest thereon, and (ii) counsel fees, costs and
disbursements incurred by Mortgagee in connection with collection of the proceeds and the
proceedings to establish the deficiency.
(c) If the amount of the initial award of damages for the condemnation is
insufficient to pay in full the indebtedness secured hereby with interest and other appropriate
charges, Mortgagee shall have the right to prosecute to final determination or settlement an
appeal or other appropriate proceedings in the name of Mortgagee or Mortgagor, for which
Mortgagee is hereby appointed irrevocably as attorney-in-fa for Mortgagor. In that event, the
expenses of the proceedings, including .counsel fees, shall be paid first out of the proceeds and
only the excess, if any, paid to Mortgagee shall be credited against the.amounts due under this
Mortgage.
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(d) Nothing herein shall limit the rights otherwise available to Mortgagee, at
law or in equity, including the right to intervene as a party to any condemnation proceeding.
(e) No application of condemnation proceeds to the payment of the Note shall
postpone any of the current installments of principal or interest becoming due under such Note
until the Note and all interest and other sums due thereunder and hereunder are paid in full.
17. Leases.
(a) Mortgagor hereby assigns to Mortgagee all existing and future leases (the
"Leases") and all rents and profits of the Mortgaged Property as further security for payment
of the indebtedness hereby secured and Mort the
the Mortgaged Pr g? grants to Mortgagee the right to enter upon
gag operty for the purposes of collecting the same and to let the Mortgaged
Property or any part thereof This assignment and grant shall continue in effect until the
indebtedness secured by this Mortgage is paid. Mortgagee hereby waives the right to collect said
rents and profits, and Mortgagor shall be entitled to collect and receive the.same until the
occurrence of an Event of Default under this Mortgage, and Mortgagor agrees to use such rents
and profits in payment of principal and interest becoming due on this Mortgage and.in.payment
of taxes, assessments, sewer rents, water rents and charges becoming due as aforesaid, but such
privilege of Mortgagor may be revoked by Mortgagee upon an Event of Default without notice.
Mortgagor shall not, without the written consent of Mortgagee, receive or collect rent or other
charge for a period of more than one month in advance. Mortgagee shall not be deemed to have
accepted the assignment except as a pledge or be obligated as lessor by virtue of this assignment
except by a separate and express written agreement of Mortgagee.
(b) Mortgagor hereby authorizes and instructs each and every present and
future tenant of any of the Mortgaged Property to pay all rents directly to Mortgagee and to
perform all other obligations of that tenant for the direct benefit of Mortgagee, as if Mortgagee
were the landlord under the lease with that tenant, immediately upon receipt of a demand by
Mortgagee to make such payment or perform such obligations. No tenant shall have any
responsibility to ascertain whether such demand is permitted hereunder or whether a default shall
have occurred. Mortgagor hereby waives any right, claim or demand it may now or hereafter
have against any such tenant by reason of such payment of rents or performance of obligations to
Mortgagee; and any such payment or performance to Mortgagee shall discharge the obligations
of the tenant to make such payment or performance to Mortgagor. Mortgagor shall indemnify
Mortgagee and hold Mortgagee harmless from any and all liability under any lease and for any
and all claims and demands which may be asserted against Mortgagee by reason of any alleged
obligations to perform any provision of any lease, except as to Mortgagee's own gross negligence
or willful misconduct.
(c) Mortgagor represents and warrants to Mortgagee that the Mortgaged
Property is not subject to any leases or other occupancy rights, and no tenant or any other party
has any option or right to purchase the Mortgaged Property or any part of the Mortgaged
Property. Mortgagor will deliver to Mortgagee upon written request a certified statement setting
forth the names of all tenants occupying space in the Mortgaged Property, a brief description of
the space occupied, the rental payable and the date of expiration of the respective leases, and the
status of the rental payments due thereunder.
the (d) Mortgagor shall promptly (i) perform all of the provisions of the Leases on
part of the landlord thereunder to be performed; (ii) enforce all of the provisions of the
Leases on the part of the tenants thereunder to be performed; and (iii) appear in and defend any
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action or proceeding arising under, growing out of or in any manner connected with the Leases
or the obligations of Mortgagor as landlord or of the tenants thereunder.
(e) Mortgagor shall deliver to Mortgagee copies of any new Leases or
amendments to existing Leases within fifteen (15) days of the execution of such new Leases or
amendments to existing Leases. Mortgagor shall not enter into any new Leases or amend any of
the terms of any of the existing Leases without obtaining the prior written approval of
Mortgagee. All Leases (existing and future) shall, unless Mortgagee otherwise elects in its sole
discretion, be subject and subordinate in all respects to the lien of this Mortgage.
18. No Other Financing or Liens. Without the prior written consent of Mortgagee,
which Mortgagee can grant or withhold in its sole discretion, Mortgagor shall not create or cause
or permit to exist any lien on, or security interest in the Mortgaged Property or any part thereof
(whether or not such lien or security interest is subordinate to the lien of this Mortgage),
including any furniture, fixtures, appliances, machinery, equipment, or other items of personal
property which are intended to be or become part of the Mortgaged Property, or securing
repayment of monies paid to or for the benefit of Mortgagor.
19. No Transfer. Without the prior written consent of Mortgagee, which Mortgagee
can grant or withhold in its sole discretion, Mortgagor will abstain from and will not cause or
permit any sale, assignment or transfer of (a) all or any part of the Mortgaged Property or any
beneficial interest therein, or any estate or other interest in the Mortgaged Property or-any part
thereof, or (b) any beneficial interest in Mortgagor, in either case whether voluntarilyy or by
operation of law, whether by sale, exchange, conveyance, merger, division, consoi. 'On or
otherwise. Any consent given by Mortgagee hereunder shall pertain only to the proposed
transfer for which the consent was requested and shall not obligate Mortgagee to approve any
further transfers.
20. Right to Remedy Defaults. In the event that Mortgagor should fail to pay
corporate taxes, real estate or other taxes, assessments,. water and sewer rents, charges and claims
on or before the date on which any penalty may be imposed with respect thereto, or fail to pay
insurance premiums, or fail to make necessary repairs, or permit waste, or fail to comply with
any other provision of this Mortgage or the Loan Documents; Mortgagee, at its election and
without notice to Mortgagor, shall have the right to make any payment or expenditure and to take
any action which Mortgagor should have made or taken, or which Mortgagee deems advisable to
protect the security of this Mortgage or the Mortgaged Property, without prejudice to an of
Mortgagee's rights or remedies available hereunder or otherwise, at law or in equity. All such
sums, as well as costs, advanced by Mortgagee pursuant to this Mortgage shall be due
immediately from Mortgagor to Mortgagee, shall be secured hereby, and shall bear interest at the
Default Rate (as defined in the Note) from the date of payment by Mortgagee until the date of
repayment.
21. Actions of Mortgagee. Mortgagee may, at any time and from time to time,
without notice to and without the consent of any other person or entity, (a) extend or accelerate
the time of payment of the indebtedness secured hereby, (b) agree to modify the terms of the
Note or this Mortgage, including increasing payments of interest and principal, (c) release=any
person liable for payment of any indebtedness secured hereby or for performance of any
obligation, (d) release all or any part of the security held for the indebtedness secured hereby or
(e) exercise or refrain from exercising or waive any right Mortgagee may have. Mortgagee shall
have such rights and may exercise them without affecting the lien or priority of this Mortgage
upon the Mortgaged Property or any part thereof notwithstanding the fact that junior mortgages,
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judgments or other claims or encumbrances may be impaired, prejudiced or otherwise adversely
affected thereby.
22. Security and Priority of Advances. This Mortgage secures future advances.
Advances may be made and indebtedness incurred from time to time hereafter, but each such
advance or indebtedness shall be secured hereby as if made on the date hereof. The maximum
amount of Indebtedness (as defined in 42 Pa. C.S.A. §8143, which tern excludes interest and
excludes the protective advances and expenses referred to in the immediately following
sentence) outstanding at any time which is secured by this Mortgage is double the face amount of
the Note. This Mortgage also secures (i) all advances made by Mortgagee with respect to the
Mortgaged Property for the payment of real estate taxes, water and sewer rents, assessments,
maintenance charges, insurance premiums or costs incurred for.the protection of any of the
Mortgaged Property or the lien of this Mortgage, (ii) all expenses incurred by Mortgagee by
reason of an Event of Default hereunder, and (iii) all advances made by Mortgagee to enable
completion of construction of improvements to the Mortgaged Property. As provided in 42 Pa.
C.S.A. §8144, this Mortgage shall constitute a lien on the Mortgaged Property from the time this
Mortgage is left of record (or, if this is a purchase money mortgage, from: the time of delivery
hereof to Mortgagee) for, among other things, all such advances and expenses, plus interest
thereon, regardless of the time when such advances are made or such expenses are incurred.
Mortgagor hereby covenants and agrees that it will not exercise,. and hereby waives, its right
under 42 Pa. C.S.A. §8I43(c) to limit the indebtedness secured by this Mortgage.
23. Notice to Prior Lienholders. Mortgagor hereby authorizes Mortgagee, without
liability and at Mortgagee's sole discretion, to give notice in form and substance satisfactory to
Mortgagee of the lien and security interest created by this Mortgage to a holder of a previously
recorded mortgage which is a lien on the Mortgaged property in order, among other things, to
subordinate further advances by such mortgage holder.
24. Events of Default. Each of the following shall constitute an event of default
(hereinafter called an "Event of Default") hereunder: (a) any Event of Default?(as defined in any
of the Obligations); (b) any default under any of the Obligations that does not have a defined set of
"Events of Default" and the lapse of any notice or cure period provided in such Obligations with
respect to such default; (c) demand by Mortgagee under any of the Obligations that have a demand
feature; (d) the failure by Mortgagor. to perform any of its obligations under this Mortgage;
(e) falsity, inaccuracy or material breach by Mortgagor of any warranty; covenant, representation
or statement contained in this Mortgage or otherwise made or furnished to Mortgagee by or on
behalf of Mortgagor; (f) an uninsured material loss, theft, damage, or destruction to any of the
Mortgaged Property, (g) the entry of any lien against or the making of any levy, seizure or
attachment of or on the Mortgaged Property, (h) the failure of Mortgagee to have a mortgage lien
on the Mortgaged Property with the priority required under Paragraph I of this Mortgage; (i) any
indication or evidence received by Mortgagee that Mortgagor may have directly or indirectly been
engaged in any type of activity which, in Mortgagees discretion, might result in the forfeiture of
any of the Mortgaged Property to any governmental entity, federal, state or local; 0) foreclosure or
execution proceedings are instituted against the Mortgaged Property upon any other lien or claim,
whether alleged to be superior or junior to the lien of this Mortgage; (k) the failure by Mortgagor to
pay any taxes or other charges as required under Paragraph 5 of this Mortgage, or to maintain in
full force and effect any insurance required under Paragraph 4 of this Mortgage; or (1) Mortgagor
or any other obligor or guarantor of any of the Obligations, shall at any time deliver or cause to be
delivered to Mortgagee a notice pursuant to 42 Pa. C.S.A. §8143 electing to limit the indebtedness
secured by this Mortgage.
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25. Remedies.
(a) Upon the happening of any Event of Default, the entire unpaid balance of
the principal, the accrued interest and all other sums secured by this Mortgage shall become
immediately due and payable; without notice or demand.
(b) _ When the entire indebtedness shall become. due and payable, either
because of maturity or because of the occurrence of any Event of Default, or otherwise, then
forthwith:
(i) Foreclosure. Mortgagee may institute an action of mortgage
foreclosure against the Mortgaged Property, or take such other action at law or in equity for the
enforcement of this Mortgage and realization on the mortgage security or any other security
herein or elsewhere provided for, as the law may allow, and may proceed therein to final
judgment and execution for the entire unpaid balance of the Obligations, with interest at the rate
stipulated in the Note.to the date of default, and thereafter at the Default Rate (as defined in the
Note), together with all other sums due by Mortgagor in accordance with the provisions of the
Note and this Mortgage, including all sums which may have been loaned by Mortgagee to
Mortgagor after the date of this Mortgage, and all sums which may have been advanced by
Mortgagee for taxes, water or sewer rents, charges or claims, payments on prior liens, insurance,
utilities or repairs to the Mortgaged Property, all costs of suit, together with interest at such rate
on any judgment obtained by Mortgagee from and after the date of any Sheriffs or other judicial
sale until actual payment is made -of the full amount due Mortgagee, and a reasonable attorney's
commission for collection; or
(ii) Possession. Mortgagee may enter into possession of the
Mortgaged Property, manage, lease and operate the Mortgaged Property, collect therefrom all
rentals (which term shall also include sums payable for use and occupancy) and, after deducting
all costs of collection and administration expense, apply the net rental to any or all of the
following in such order and amounts as Mortgagee, in Mortgagee's sole discretion, may elect:
the payment of taxes, water and sewer rents, charges and claims, insurance premiums and all
other carrying charges, and to the maintenance, repair or restoration of the Mortgaged Property,
and on account and in reduction of the principal or interest, or both, hereby secured; in and for
that purpose Mortgagor hereby assigns to Mortgagee all rentals due and to become due under
any lease or leases or rights to use -and occupancy of the Mortgaged Property hereafter created,
as well as all rights and remedies provided in such lease or leases or at law or in equity for the
collection of the rentals. For the purpose of obtaining possession of the Mortgaged Property
upon the occurrence of an Event of Default hereunder or under the Note, Mortgagor
hereby authorizes and empowers any attorney of any court of record in the
Commonwealth of Pennsylvania or elsewhere, as attorney for Mortgagor and all persons
claiming under or through Mortgagor, to appear for and confess judgment against
Mortgagor, and against all persons claiming under or through Mortgagor, in favor of
Mortgagee, for recovery by Mortgagee of possession of the Mortgaged Property, for which
this Mortgage, or a copy thereof verified by affidavit, shall be a sufficient warrant; and
thereupon a writ of possession may immediately issue for possession of the Mortgaged
Property, without any prior writ or proceeding whatsoever and without any stay of
execution. If for any reason after such action has been commenced it shall be discontinued,
or possession of the Mortgaged Property shall remain in or be restored to Mortgagor,
Mortgagee shall have the right for the same default or any subsequent default to bring one
or more further actions as above provided to recover possession of the Mortgaged
Property. Mortgagee may bring an action in ejectment and confess judgment therein
-14-
before or after the institution of proceedings to foreclose this Mortgage or to enforce the
Note, or after entry of judgment therein or on the Note, or after a Sheriff's sale or other
judicial sale of the Mortgaged Property in which Mortgagee is the successful bidder, it
being the understanding of the parties that the authorization to pursue such proceedings
for obtaining possession and confession of judgment therein is an essential part of the
remedies for enforcement of the Mortgage and the Note, and shall survive any execution
sale to Mortgagee; or
(iii) Receiver. Mortgagee may, upon any proper action or proceeding
being commenced for the foreclosure of this Mortgage, apply for, and Mortgagee as a matter of
right; without consideration of the value of the Mortgaged Property as security for the amount
due Mortgagee, or of the solvency of any person, firm or corporation obligated for the payment
of such amount, shall be entitled to, the appointment by any competent court or tribunal, without
prior demand or notice to any party, of a receiver of rents and-profits and rental value of the
Mortgaged Property, with power to take possession of the Mortgaged Property, including
possession from Mortgagor if in possession and occupying any portion of the Mortgaged
Property, and in the latter case to require Mortgagor, as a condition of remaining in possession
and occupation, to pay the reasonable rental value for the use and occupation thereof, with
further power to lease and repair the Mortgaged Property and to renovate same to suit new
tenants and with such other powers as may be deemed necessary, and such receiver after
deducting all proper charges and expenses attending the execution of the said trust -as receiver,
shall each month pay over to Mortgagee the residue of the said rents and profits and rental value,
to be applied by Mortgagee to the payment of the amount remaining secured hereby, or to any
deficiency (whether or not any judgment therefor may be entered and irrespective of the market
value of the Mortgaged Property) which may exist in the event of foreclosure-by sale after
applying the proceeds of the sale of the Mortgaged Property to the payment of the amount due,
including interest, costs and expenses of such foreclosure and sale, or in the event of strict
foreclosure to the payment of any deficiency existing thereunder. A receiver, while in
possession of the Mortgaged Property, shall have the right to make repairs and to make
improvements necessary or advisable in its or his opinion to preserve the Mortgaged Property, or
to make and keep them rentable to the best advantage, and Mortgagee may advance moneys to a
receiver for such purposes. Any moneys so expended or advanced by Mortgagee or by a
receiver shall be repaid so far as possible out of the tents collected after payment of other
expenses properly chargeable against said rents, and any unpaid balance of moneys so advanced
or expended shall be added to and become a part of the debt secured by this Mortgage.
(c) Mortgagee shall have the right, from time to time, to bring an appropriate
action to recover any sums required to be paid by Mortgagor under the terms of the Note (or any
other documents evidencing the Obligations) and this Mortgage, as they become due, and
proceed thereafter to an execution sale, and without prejudice to the right of Mort
thereafter to bring an action of mortgage foreclosure, or any other action, for any defaugageelt by
Mortgagor existing at the time the earlier action was commenced.
(d) Any real estate sold pursuant to any writ or order of execution issued on a
judgment obtained by virtue of the Note or this Mortgage, or pursuant to any other judicial
proceedings under the Mortgage, may be sold in one parcel, as an entirety, or in such parcels,
and in such manner or order as Mortgagee, in its sole discretion, may elect.
26. Non MeW. Notwithstanding the recovery or entry of any judgment against
Mortgagor (whether in foreclosure or otherwise), all of the terms, provisions, covenants,
undertakings and agreements of Mortgagor whether hereunder or under the Note or any other
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note, instrument, document or undertaking of Mortgagor, whether relating thereto or not, shall
remain in full force and effect and shall be enforceable strictly in accordance with their terms as
fully as though no such judgment had been entered or recovered against Mortgagor, and such
provisions, covenants, undertakings and agreements (including the obligation to pay the
Obligations at the rate or rates set forth in the Note) shall not merge with any such judgment.
27. Cumulative Riszhts. The rights and remedies of Mortgagee as provided in this
Mortgage, the Note, and every Loan Document, shall be cumulative and concurrent; may be
pursued separately, successively or together against Mortgagor or against the Mortgaged
Property, or both, at the sole discretion of Mortgagee; and may be exercised as often as occasion
therefor shall arise. The failure to exercise any such-right or remedy shall in no event be
construed as a waiver or release thereof.
28. No Waiver Implied. Any failure by Mortgagee to insist upon strict performance
by Mortgagor of any of the terms and provisions of this Mortgage or the Note shall not be
deemed to be a waiver of any of the terms or provisions of the Mortgage or Note, and Mortgagee
shall have the right thereafter to insist upon strict performance by Mortgagor of any and all of
them. Neither Mortgagor nor any other person now or hereafter obligated for payment of all or
any part of the sums now or hereafter secured by this Mortgage shall be relieved of such
obligation by reason of the failure of Mortgagee to comply with any request of Mortgagor or of
any other person so obligated to take action to foreclose on this Mortgage or otherwise enforce
any provisions of the Mortgage or the Note, or by reason of the release, regardless of
consideration, of all or any part of the security held for the indebtedness secured by this
Mortgage, or by reason of any agreement or stipulation between any subsequent owner of the
Mortgaged Property and Mortgagee extending the time of payment or modifying the terms of the
Mortgage or Note without first having obtained the consent of Mortgagor or such other person;
and in the latter event Mortgagor and all such other persons shall continue to be liable to make
payments according to the terms of any such extension or modification agreement, unless
expressly released and discharged in writing by Mortgagee.
29. Operating Accounts and Escrow Accounts. Throughout the term of the loan
secured hereby, Mortgagor's operating accounts and escrow accounts with respect to the
Mortgaged Property shall be maintained with Mortgagee.
30. Waiver of Jury Trial. Mortgagor and Mortgagee (by its acceptance hereof)
irrevocably waive jury trial and the right thereto in any and all disputes involving
Mortgagee or Mortgagee's parent, affiliates or related entities or any officer, director,
shareholder, attorney or partner of any of them, whether hereunder or under any other
agreements, notes, papers, instruments or documents heretofore or hereafter executed or
any other contract whether similar or dissimilar. This. shall be deemed a covenant
enforceable independently of all other provisions of this Mortgage.
31. Other Waivers. Mortgagor hereby waives and releases:
(a) all errors, defects and imperfections in any proceeding instituted by
Mortgagee under the Note or this Mortgage, or both;
(b) all benefit that might accrue to Mortgagor by virtue of any present or
future law exempting the Mortgaged Property, or any part of the proceeds arising from any sale
thereof, from attachment, levy or sale on execution, or providing for any stay of execution,
exemption from civil process or extension of time for payment;
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(c) unless specifically required herein, all notices of Mortgagor's default or of
Mortgagee's election to exercise, or Mortgagee's actual exercise of any option under the Note,
this Mortgage or the other Loan Documents;
(d) after sale or sales of the Mortgaged Property any right under any statute
heretofore or hereafter enacted to redeem the property so sold or any part thereof; and
(e) any right to have the Mortgaged Property marshaled upon any foreclosure
hereunder. The right is hereby given by Mortgagor and reserved by Mortgagee to make partial
release or releases of security hereunder, agreeable to Mortgagee without notice to, or the
consent, approval or agreement of other parties in interest, which partial release or releases shall
not impmn in any manner the validity of or priority of this. Mortgage on the security remaining,
nor release the personal liability of Mortgagor for the debt hereby secured.
Mortgagor hereby expressly waives all benefit or advantage of any such law or
laws to the extent that it lawfully may, and covenants not to hinder, delay or impede the
execution of any power herein granted or delegated to Mortgagee, but to suffer and permit the
execution of every power as though no such law or laws had been made or enacted.
32. Environmental Matters.
(a) For purposes of this Paragraph 32, the term "Environmental Laws" shall
mean all federal, state and local laws, regulations and orders, whether now or in the future enacted
or issued, pertaining to the protection of land, water, air, health, safety or the environment. The
term "Regulated Substances" shall mean all substances regulated by Environmental Laws or the
presence of which may require investigation, notification or re mediation under the Environmental
Laws. The term "Contamination" shall mean the discharge, release, emission, disposal or escape
of any Regulated Substances into the environment.
(b) Mortgagor represents and warrants that to the best of its knowledge, (i) no
contamination is present at, on or under the Mortgaged Property and that no Contamination is
being or has been emitted onto any surrounding property; (ii) all operations and activities on the
Mortgaged Property have been and are being conducted in accordance with all Environmental
Laws, and Mortgagor has an permits and licenses required under the Environmental Laws; (iii) no
underground or aboveground storage tanks are or have been located on or under the Mortgaged
Property; and (iv) no legal or administrative proceeding is pending or threatened relating to any
environmental condition, operation or activity on the Mortgaged Properly, or any violation or
alleged violation of Environmental Laws. These representations and warranties shall be true as of
the date hereof, and shall be deemed to be continuing representations and warranties which must
remain true, correct and accurate during the entire duration of the term of this Mortgage.
(c) Mortgagor shall ensure, at its sole cost and expense, that the Mortgaged
Property and the conduct of all operations and activities thereon comply and continue to comply
with all Environmental Laws. Mortgagor shall notify Mortgagee promptly and in reasonable detail
in the event that Mortgagor becomes aware of any violation of any Environmental Laws, the
presence or release of any Contamination with respect to the Mortgaged Property, or any governmental or third party claims relating to the environmental condition of the Mortgaged
Property or the conduct of operations or activities thereon. Mortgagor also agrees not to permit or
allow the presence of Regulated Substances on any part of the Mortgaged Property, except for
those Regulated Substances (i) which are used in the ordinary course of Mortgagor's business, but
-17-
only to the extent they are in all cases used in a manner which complies with all Environmental
Laws; and (ii) those Regulated Substances which are naturally occurring on the Mortgaged
Property. Mortgagor agrees not to cause, allow or permit the presence of any Contamination on
the Mortgaged Property.
(d) Mortgagee shall not be liable for, and Mortgagor shall indemnify, defend
and hold Mortgagee and all of its officers, directors, employees and agents, and all of their
respective successors and assigns harmless from and against all losses, costs, liabilities, damages,
fines, claims, penalties and expenses (including reasonable attorneys', consultants' and contractors'
fees, costs incurred in the investigation, defense and settlement of claims, as well as costs incurred
in connection with the investigation, remediation or monitoring of any Regulated Substances or
Contamination) that Mortgagee may suffer or incur (including as holder of the Mortgage, as
mortgagee in possession or as successor in interest to Mortgagor as owner of the Mortgaged
Property by virtue of a foreclosure or acceptance of a deed in lieu of foreclosure) as a result of or in
connection with (i) any Environmental Laws (including the assertion that any lien existing or
arising pursuant-to any Environmental Laws. takes priority over the lien of the Mortgage); (ii) the
breach of any representation, warranty, covenant or undertaking by Mortgagor in this Paragraph
32; (iii) the presence on or the migration of any Contamination or Regulated Substances on, under
or through the Mortgaged Property; or (iv) any litigation or claim-by the government or by any
third party in connection with the environmental condition of the Mortgaged Property or the
presence or migration of any Regulated Substances or Contamination on, under, to or from the
Mortgaged Property.
33. Further Assurances; Replacement Documents. Mortgagor will execute and
deliver such further instruments and perform such further acts as may be requested by Mortgagee
from time to time to confirm the provisions of this Mortgage or the Note, to carry out more
effectively the purposes of this Mortgage or the Loan Documents securing the Note, or to
confirm the priority of the lien created by this Mortgage on any property, rights or interest
encumbered or intended to be encumbered by the lien of this Mortgage or the Loan Documents.
Upon receipt of an affidavit of an officer of Mortgagee as to the loss, thef, destruction or
mutilation of the Note or any other Loan Document which is not of public record and, in the case
of any such destruction or mutilation, upon surrender and cancellation of such Note or other
Loan Document, Mortgagor will issue, in lieu thereot a replacement Note or other Loan
Document in the same principal amount thereof and otherwise of like'tenor.
34. Indemnification. Mortgagor hereby irrevocably agrees to indemnify and save
harmless Mortgagee from and against any and all loss or damage of whatsoever kind and from
any suits, claims or demands, including, without limitation, Mortgagee's legal fees and expenses,
on account of any matter or thing arising out of this Mortgage or in connection herewith.
35. Counsel Fees. If Mortgagee becomes a party to any suit or proceeding affecting
the Mortgaged Property or title thereto, the lien created by this Mortgage or Mortgagee's interest
therein, or if Mortgagee engages counsel to collect any of the indebtedness or to enforce
performance of the agreements, conditions, covenants, provisions or stipulations of this
Mortgage or the Loan Documents, Mortgagee's costs, expenses and reasonable counsel fees,
whether or not suit is instituted, shall be paid to Mortgagee by Mortgagor, on demand, with
interest at the then effective rate set forth in the Note, and until paid they shall be deemed to be
part of the indebtedness evidenced by the Note and secured by this Mortgage.
36. Communications. All notices and other communications under this Mortgage
shall be in writing and shall be sent to the party to receive such notice at its address set forth in
-18-
the heading of this Mortgage, or to such other address as either party may designate from time to
time by notice to the other in the manner set forth herein. A notice shall, for all purposes, be
deemed given and received: (a) if hand delivered to a party against receipted copy, when the
copy of the notice is receipted; (b) if given by a nationally recognized and reputable overnight
delivery service company, the day on which the notice is delivered'by the delivery service
company to such party; or (c) if given by certified mail, two (2) business days after it is posted
with the United States Postal Service. Notwithstanding the foregoing, any notice given by
Mortgagor to Mortgagee purportedly pursuant to 42 Pa. C.S.A. §8143 shall be given by
registered or certified mail, to the address of Mortgagee specified on page 1 of this Mortgage and
only to that address, and such notice shall be deemed to have been received no earlier than the
date actually and physically received at such address.
37. Covenant Runningwith the Land. Any act or agreement to be done or performed
by Mortgagor shall be construed as a covenant running with the land and shall be binding upon
Mortgagor and its successors and assigns as if they had personally made such agreement.
38. Amendment. This Mortgage cannot be changed or amended except by agreement
in writing signed by the party against whom enforcement of the change is sought.
39. Governin Law and Jurisdiction. This Mortgage has been delivered to and
accepted by Mortgagee and will be deemed to be made in the Commonwealth of Pennsylvania.
THIS MORTGAGE WILL BE INTERPRETED AND THE RIGHTS AND.LIABELITIES OF
MORTGAGOR AND MORTGAGEE DETERMINED-IN ACCORDANCE WITH THE LAWS
OF THE COMMONWEALTH OF PENNSYLVANIA WITHOUT GIVING EFFECT TO
PRINCIPLES OF CONFLICT OR CHOICE OF LAWS. Mortgagor hereby irrevocably consents
to the exclusive jurisdiction of any state or federal court in the county or judicial district in which
the Mortgaged Property is located; provided that nothing contained in this Mortgage will prevent
Mortgagee from bringing any action, enforcing any award or judgment or exercising any rights
against Mortgagor individually, against any seewity or against any property of Mortgagor within
any other county, state or other foreign or domestic jurisdiction. Mortgagor acknowledges and
agrees that the venue provided above is the most convenient forum for both Mortgagee and
Mortgagor. Mortgagor waives any objection to venue and any objection based on a more
convenient foram in any action instituted under this Mortgage.
40. Interpretation. Whenever used in this Mortgage, unless the context clearly
indicates a contrary intent:
(a) The word "Mortgagor" shall mean the entity which executes this Mortgage
and any subsequent owner of the Mortgaged Property and their respective legal representatives,
successors and assigns;
(b) The word "Mortgagee" shall mean the person or entity specifically named
herein as "Mortgagee" or any subsequent holder of this Mortgage;
(c) The word "entity" shall mean individual, corporation, partnership, limited
liability company or unincorporated association;
(d) The use of any gender shall include all genders;
(e) The singular number shall include the plural and the plural the singular as
the context may require.
-19-
41. Severabilitv. If any provision of this Mortgage or the application thereof is held
by a court of competent jurisdiction to be invalid or unenforceable, the remaining provisions
hereof shall not be affected thereby, and each provision of this Mortgage shall be valid and
enforceable to the fullest extent permitted by law.
42. Powers ofAttomev. This Mortgage and the other Loan Documents -contain
powers of attorney given by Mortgagor to Mortgagee. Such powers are coupled with an interest
and are for the sole benefit of Mortgagee. Mortgagee, as agent for Mortgagor under the powers
of attorney, is not a fiduciary for Mortgagor. Mortgagee, in exercising any of its rights or powers
pursuant to the powers of attorney, may do so for the sole benefit of Mortgagee and not for
Mortgagor. The parties acimowledge and agree that the provisions of Section 5601 of Chapter
56 of Title 20 of the Pennsylvania Consolidated Statutes; as amended, shall not be applicable to
the powers of attorney granted herein and in the-other Loan Documents.
43. Captions. The captions preceding the text of the paragraphs or subparagraphs of
this Mortgage are inserted only for convenience of reference and shall not constitute a part of this
Mortgage, nor shall they in any way affect its meaning, construction or erect.
44. Purchase Moneg Mortgage. This Mortgage is a "purchase money mortgage"
within the meaning of 42 Pa. C.S.A. §8141.
WITNESS the due execution hereof as a document under seal, as of the date first written above,
with the intent to be legally bound hereby.
WITNESS:
SHIPPENSBURG APEX, LP, a Pennsylvania
limited partnership
By: Shippensbmg Apex, LLC, a Pennsylvania
limited liability company, its sole general
partner
By:
4Roert. 1h4agingg Member
The address of Mortgagee is:
732 Montgomery Avenue
Narberth, Pennsylvania 19072
4n Beh o agee
-20-
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF /W09% ss
On this, the 26th day of October, 2007, before me, the subscriber, a Notary Public in and
for the State and County aforesaid, personally appeared Robert P. Shaffer, who acknowledged
himself to be the Managing Member of Shippensburg Apex, LLC, a Pennsylvania limited
liability company, which is the sole general partner of SHIPPENSBURG APEX, LP, a
Pennsylvania limited partnership, who I am satisfied is the person who signed the within
instrument, and who acknowledged that being validly authorized to do so he executed same as
such officer for the purposes therein contained as the voluntary act and deed of such limited
liability company.
WITNESS my hand and seal the day
EXI:IIBIT A
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Shippensburg Township, Cumberland County,
Pennsylvania, as shown on a Subdivision Plan for G & C Associates for Apex Village, by Fischbach
Morgan & Associates, R.S. dated August 10, 2006, recorded in Cumberland County Recorder of Deeds
Office Plan Book 93, Page 60, being designated as Lot 7, more particularly bounded and described as
follows:
BEGINNING at a point on the southwestern edge of Asper Drive; thence by other lands of Grantors
North 43 degrees 12 minutes 00 seconds West a distance of 581.53 feet to an iron pin to be set at the
comer of the storm water basin and the emergency access road as shown on the Subdivision plan; thence
along the edge of the existing storm water basin North 47 degrees 18 minutes 16 seconds East a distance
of 290.31 feet to an iron pin to be set; thence continuing by the edge of the storm water basin North 43
degrees 13 minutes 31 seconds West 215.75 feet to a point at lands now or formerly of Conrail Lurgan
Branch Railroad; thence along said Conrail Railroad lands North 76 degrees 48 minutes 08 seconds East a
distance of 10635 feet to a point; thence continuing by said Conrail Railroad property North 79 degrees
38 minutes 43 seconds East a distance of 306.07 feet to a point; thence along other lands of G & C
Associates South 42 degrees 44 minutes 58 seconds East a distance of 581.17 feet to a point; thence by
other lands of
G & C Associates on the southeastern Asper Drive South 47 degrees 18 minutes 23 seconds West a
distance of 634.90 feet to an existing iron pin, the point and place of BEGINNING.
CONTAINING 9.388 acres, more or less and being all of Lot. 7.
BEING a portion of the real estate which Galen S. Asper and Jeannette A. Asper, .by their attorney in fact
by deed dated July 30, 1992 and recorded in Cumberland County Deed Book "L" Volume 36, page 809,
granted and conveyed to H. Scott Garling and Michael J. Cassidy, co-partners, t/d/b/a G & C Associates.
H. Scott Garling died July 29, 1994. Letters of Administration were issued to Barbara L. Garling on
August .8, 1994, by the Cumberland County Register of Wills. By specific provision of the Partnership
Agreement between K Scott Garling and Michael J. Cassidy, the personal representative of a deceased
partner, suixwded to the interest of the deceased partner and continued to conduct partnership business.
Barbara L. Garling previously elected to succeed to the interest of the deceased partner, but has since
withdrawn from the partnership. Julie A. Cassidy became a partner and joined in the deed of conveyance
with Michael J. Cassidy as Grantors to Educational Property Group, Inc. The parties who executed the
deed of conveyance were all of the partners of G & C Associates, and their deed of conveyance was
approved in accordance with the requirements of the Partnership Agreement.
BEING Tax Parcel Number. 36-35-2385-131
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 201017880
Recorded On 7/6/2010 At 10:45:00 AM * Total Pages - 5
* Instrument Type - ASSIGNMENT OF MORTGAGE
Invoice Number - 68541 User ID - AF
* Mortgagor - ROYAL BANK AMERICA
* Mortgagee - NARBERTH PROPERTY ACQUISITION LLC
* Customer - WEIR
* FEES
STATE WRIT TAX
STATE JCS/ACCESS TO
JUSTICE
RECORDING FEES -
RECORDER OF DEEDS
PARCEL CERTIFICATION
FEES
COUNTY ARCHIVES FEE
ROD ARCHIVES FEE
TOTAL PAID
$0.50
$23.50
Certification Page
DO NOT DETACH
$11.50
$10.00
$2.00
$3.00
$50.50
This page is now part
of this legal document.
I Certify this to be recorded
in Cumberland County PA
of C M
F E
RECORDER O D DS
t?ao
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
III i?uiiiniiiiidmi
Prepared By:
Daniel D. Haggerty, Esquire
Weir & Partners LLP
1339 Chestnut Street
Widener Building
Suite 500
Philadelphia PA 19107
Parcel No. 36-35-2385-131
ASSIGNMENT OF MORTGAGE
V??InI?'d?IIViV?I?
KNOW ALL MEN BY THESE PRESENTS, that ROYAL BANK AMERICA, with an
office located at 732 Montgomery Avenue, Narberth, PA 19072 ("Assignor"), the mortgagee in
the mortgage hereinafter mentioned, for and in consideration of the sum of One Dollar ($1.00)
lawful money, unto it in hand paid at the time of execution hereof, the receipt whereof is hereby
acknowledged, does hereby grant, bargain, sell, assign, transfer, and set over unto NARBERTH
PROPERTY ACQUISITION, LLC, with an office located at 732 Montgomery Avenue,
Narberth, PA 19072 ("Assignee"), its successors and assigns, all that certain Open-End
Mortgage and Security Agreement given and executed by Shippensburg Apex, LP to Royal Bank
America, dated October 26, 2007 (the "Mortgage"), and recorded on November 8, 2007 with the
Recorder of Deeds of Cumberland County, Commonwealth of Pennsylvania at Instrument No.
200742316, to secure the payment of the principal sum of $16,667,015.00 and known as a tract
of land situate in Shippensburg Township, Cumberland County, Pennsylvania beginning at a
point on the southwestern edge of Asper Drive, containing 9.388 acres, more or less and being
all of Lot 7, Parcel No. 36-35-2385-131 and described as follows:
See attached Exhibit "A"
360211-1
Together will all singular rights, remedies and incidents thereunto belonging, and all its
right, title, interest, property, benefit, advantage, claim and demand in and to the same and every
part thereof.
To have, hold, receive and take all and singular the hereditaments and premises hereby
granted and assigned or mentioned and intended to with the appurtenances and unto the said
Assignee, its successors and assigns, to and for its only property use, benefit and behoof forever.
IN WITNESS WHEREOF, the undersigned officer, having due authority to do so, has
caused this instrument to be executed on this 29th day of June, 2010.
ROYAL BANK AMERICA
Attest:
By. (Seal)
avid A. Schultz,
Senior Vice P ent
360211-1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF PHILADELPHIA
ss.
On this, the `'--F- day of , 2010, before me, a Notary Public in and for the
Commonwealth of Pennsylvania, personal y appeared David A. Schultz, the Senior Vice
President of Royal Bank America, who acknowledged himself to be the person whose name is
subscribed to the within instrument, and executed the foregoing instrument for the purposes
therein contained and desired that the same be recorded as such.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notary Public
My Commission Expires I DA t,I o
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Christina ZuNo, Notary Public
City Of Philadelphia, Philadelphia County
My Cornnvssion E)ires Dec. 17, 2011
Member, Pennsylvania Association of Notaries
360211-1
.
EXHIBIT "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Shippensburg Township, Cumberland County,
Pennsylvania, as shown on a Subdivision Plan for G&C Associates for Apex Village, by
Fischbach Morgan & Associates, R.S. dated August 10, 2006, recorded in Cumberland County
Recorder of Deeds Office Plan Book 93, Page 60, being designated as Lot 7, more particularly
bounded and described as follows:
BEGINNING at a point on the southwestern edge of Asper Drive; thence by other lands of
Grantors North 43 degrees 12 minutes 00 seconds West a distance of 581.53 feet to an iron pin to
be set at the corner of the storm water basin and the emergency access road as shown on the
Subdivision plan; thence along the edge of the existing storm water basin North 47 degrees 18
minutes 16 seconds East a distance of 290.31 feet to an iron pin to be set; thence continuing by
the edge of the storm water basin North 43 degrees 13 minutes 31 seconds West 215.75 feet to a
point at lands now or formerly of Conrail Lurgan Branch Railroad; thence along said Conrail
Railroad lands North 76 degrees 48 minutes 08 seconds East a distance of 106.35 feet to a point;
thence continuing by said Conrail Railroad property North 79 degrees 38 minutes 43 seconds
East a distance of 306.07 feet to a point; thence along other lands of G&C Associates South 42
degrees 44 minutes 58 seconds East a distance of 581.17 feet to a point; thence by other lands of
G&C Associates on the southeastern Asper Drive South 47 degrees 18 minutes 23 seconds West
a distance of 634.90 feet to an existing iron pin, the point and place of BEGINNING.
CONTAINING 9.388 acres, more or less and being all of Lot 7.
BEING a portion of the real estate which Galen S. Asper and Jeannette A. Asper, by their
attorney in fact by deed dated July 30, 1992 and recorded in Cumberland County Deed Book "L"
Volume 36, Page 809, granted and conveyed to H. Scott Garling and Michael J. Cassidy, co-
partners, t/d/b/a G&C Associates. H. Scott Garling died July 29, 1994. Letters of
Administration were issued to Barbara L. Garling on August 8, 1994, by the Cumberland County
Register of Wills. By specific provision of the Partnership Agreement between H. Scott Garling
and Michael J. Cassidy, the personal representative of a deceased partner, succeeded to the
interest of the deceased partner and continued to conduct partnership business. Barbara L.
Garling previously elected to succeed to the interest of the deceased partner, but has since
withdrawn from the partnership. Julie A. Cassidy became a partner and joined in the deed of
conveyance with Michael J. Cassidy as Grantors to Educational Property Group, Inc. The parties
who executed the deed of conveyance were all of the partners of G&C Associates, and their deed
of conveyance was approved in accordance with the requirements of the Partnership Agreement.
BEING Tax Parcel Number: 36-35-2385-131
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 201018539
Recorded On 7/12/2010 At 10:15:04 AM * Total Pages - 6
*-Instrument Type - DEED
Invoice Number - 68903 User ID - KW
* Grantor - SHIPPENSBURG APEX LP
* Grantee - NARBERTH PROPERTY ACQUISITION LLC
* Customer - WEIR & PARTNERS LLP
* FEES
STATE WRIT TAX
STATE JCS/ACCESS TO
JUSTICE
RECORDING FEES -
RECORDER OF DEEDS
PARCEL CERTIFICATION
FEES
AFFORDABLE HOUSING
COUNTY ARCHIVES FEE
ROD ARCHIVES FEE
SHIPPENSBURG AREA SCHOOL
DISTRICT
SHIPPENSBURG TOWNSHIP
TOTAL PAID
$0.50
$23.50
$12.50
$10.00
$11.50
$2.00
$3.00
$0.00
$0.00
$63.00
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
I Certify this to be recorded
in Cumberland County PA
co?e?
0 `o
RECORDER O D ;DS
r?
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
m
Prrb a
IIpII
I1dINIIN __
0020W3 Daniel 579aggerz!7! e
DEED IN LIEU OF FORECLOSURE
70
THIS DEED IN LIEU OF FORECLOSURE is made this 21 day of June, 2010, by and
between SHIPPENSBURG APEX, LP, a Pennsylvania limited partnership (hereinafter
"Grantor"), with a principal place of business of 401 East Elm Street, Conshohocken,
Pennsylvania 19428, and NARBERTH PROPERTY ACQUISITION, LLC ("Grantee"), a state
bank organized and existing under the laws of the Commonwealth of Pennsylvania with an office
located at 732 Montgomery Avenue, Narberth, Pennsylvania 19072.
Witnesseth; that the Grantor, for and in consideration of the sum of One Dollar ($1.00)
lawful money of the United States of America, unto it well and truly paid by the said Grantee, at
or before the sealing and delivery, hereof, the receipt whereof is hereby acknowledged, has
granted, bargained and sold, aliened, released and confirmed and by these does present grant,
bargain and sell, alien, release and confirm unto the said Grantee, its successors and assigns.
All That Certain tract of land situate in Shippensburg Township, Cumberland County,
Pennsylvania, beginning at a point on the southwestern edge of Asper Drive, containing 9.388
acres, more or less and being all of Lot 7, Parcel No. 36-35-2385-131, (the "Premises"), and, all
as more particularly described on Exhibit "A" attached hereto and made a part hereof.
Together with all singular the tenements, hereditaments and appurtenances, thereunto
belonging, or in any wise appertaining, and the reversions and remainders, rents, issues and
profits thereof; And also, all the estate, right, title, interest, property, claim and demand
whatsoever, as well as in law as in equity of the said parties of the first part, of, in, or to the
above-described premises, and every part and parcel thereof with appurtenances.
To have and to hold all and singular the above-mentioned and described premises,
together with the appurtenances, unto the'said party of the second part, its successors and assigns
forever.
UNDER AND SUBJECT, NEVERTHELESS TO THAT CERTAIN OPEN-END
MORTGAGE AND SECURITY AGREEMENT IN THE AMOUNT OF $16,667,015.00
DATED OCTOBER 26, 2007, GIVEN BY GRANTOR TO ROYAL BANK AMERICA,
WHICH MORTGAGE WAS DULY RECORDED ON NOVEMBER 8, 2007 WITH THE
RECORDER OF DEEDS OF CUMBERLAND COUNTY AT INSTRUMENT NO. 200742316
(THE "MORTGAGE"). IT BEING EXPRESSLY INTENDED THAT THE EXECUTION AND
DELIVERY OF THIS INDENTURE BY GRANTOR TO GRANTEE SHALL NOT
DISCHARGE BY MERGER SAID MORTGAGES, AND THE OBLIGATIONS THAT IT
SECURES. UNDER NO CIRCUMSTANCES SHALL ANY SUCH MERGER OCCUR
UNTIL SUCH TIME AS MORTGAGEE EXECUTES AND RECORDS IN THE OFFICE OF
THE RECORDER OF DEEDS, PH ILADELPHIA COUNTY, COMMONWEALTH OF
PENNSYVLANIA, A WRITTEN SATISFACTION INSTRUMENT SPECIFICALLY
EFFECTUATING SUCH MERGER.
THIS IS A DEED IN LIEU OF FORECLOSURE OF THE FOREGOING RECITED
MORTGAGE, INSOFAR AS GRANTOR IS THE FEE OWNER OF THE PREMISES
CONVEYED HEREBY, WHICH IS ENCUMBERED BY SAID MORTGAGE AND
MORTGAGEE IS THE HOLDER OF SAME.
IT IS THE INTENTION OF THE GRANTOR TO TRANSFER ABSOLUTE TITLE TO
THE WITHIN DESCRIBED PREMISES TO GRANTEE AND ITS SUCCESSORS AND
ASSIGNS FREE OF ANY EQUITY OF REDEMPTION OF GRANTOR OR ITS SUCCESSOR
OR ASSIGNS.
IN THE EVENT OF THE SETTING ASIDE OF THIS CONVEYANCE AND/OR ANY
PROCEEDINGS INITIATED UNDER THE BANKRUPTCY CODE, MORTGAGEE SHALL
HAVE THE RIGHT TO PROCEED TO FORECLOSURE OF THE MORTGAGE AS IF THIS
INSTRUMENT HAD NOT BEEN EXECUTED AND DELIVERED TO GRANTEE.
THIS TRANSFER IS EXEMPT FROM PENNSYLVANIA STATE REALTY
TRANSFER TAX PURSUANT TO 72. P.S. SECTION 8102-C.3(16) BECAUSE IT IS A
TRANSFER TO THE HOLDER OF A BONA FIDE MORTGAGE IN DEFAULT IN LIEU OF
FORECLOSURE.
IN WITNESS WHEREOF, the said Grantor has caused these presents to be duly
executed dated the day and year first above written.
GRANTOR: ATTEST:
SHIPPENSBURG APEX, LP, a Pennsylvania
Limited Partnership
By: SHIPPENSBURG APEX, LLC, a
Pennsylvania Limited Liability Company,
Its sole general partner
By
359908-1 2
- s
COMMONWEALTH OF PENNSYLVANIA
: ss
COUNTY OF \Q.j
On this a'\ day of June, 2010, before me the undersigned personally appeared Robert
P. Shaffer, who acknowledged himself to be the Managing Member of Shippensburg Apex,
LLC, the sole general partner of Shippensburg Apex, LP, a Pennsylvania Limited Partnership,
who signed the foregoing instrument, and who did acknowledge that he signed, sealed and
delivered the same, and that the foregoing instrument is the voluntary act and deed of Robert P.
Shaffer, for the purpose therein expressed, and who made this Deed on behalf of Shippensburg
Apex, LP for the sum of $1.00 as the full and actual consideration paid for the transfer of such
title.
Witness my hand and official seal the day and year aforesaid.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF PHILADELPHIA
Notary Pu I'
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Christina Zullo, Notary Public
City Of Phiadeiphia, Philadeipnia County
My Commission E)ires Dec. 17, 2011
Member, Pennsylvania Association of Notaries
: ss
On this QFday of June, 2010, before me, personally appeared, Mr. Robert P. Shaffer
known to me or satisfactorily proven to be the person whose name is subscribed to the foregoing
instrument, and acknowledged that they executed it for the purposes therein contained.
Witness my hand and official seal the ay and year a resaid
Notary Pu li
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Christina Zmlo, Notary Public
City Of Philadelphia, Philadelphia County
My Commission E)pires Dec. 17, 2011
Member, Pennsylvania Association of Notaries
The address of the within named Grantee is:
Narberth Property Acquisition, LLC
732 Montgomery Avenue
Narberth, PA 19072
359908-1
EXHIBIT "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land situate in Shippensburg Township, Cumberland County,
Pennsylvania, as shown on a Subdivision Plan for G&C Associates for Apex Village, by
Fischbach Morgan & Associates, R.S. dated August 10, 2006, recorded in Cumberland County
Recorder of Deeds Office Plan Book 93, Page 60, being designated as Lot 7, more particularly
bounded and described as follows:
BEGINNING at a point on the southwestern edge of Asper Drive; thence by other lands of
Grantors North 43 degrees 12 minutes 00 seconds West a distance of 581.53 feet to an iron pin to
be set at the corner of the storm water basin and the emergency access road as shown on the
Subdivision plan; thence along the edge of the existing storm water basin North 47 degrees 18
minutes 16 seconds East a distance of 290.31 feet to an iron pin to be set; thence continuing by
the edge of the storm water basin North 43 degrees 13 minutes 31 seconds West 215.75 feet to a
point at lands now or formerly of Conrail Lurgan Branch Railroad; thence along said Conrail
Railroad lands North 76 degrees 48 minutes 08 seconds East a distance of 106.35 feet to a point;
thence continuing by said Conrail Railroad property North 79 degrees 38 minutes 43 seconds
East a distance of 306.07 feet to a point; thence along other lands of G&C Associates South 42
degrees 44 minutes 58 seconds East a distance of 581.17 feet to a point; thence by other lands of
G&C Associates on the southeastern Asper Drive South 47 degrees 18 minutes 23 seconds West
a distance of 634.90 feet to an existing iron pin, the point and place of BEGINNING.
CONTAINING 9.388 acres, more or less and being all of Lot 7.
BEING a portion of the real estate which Galen S. Asper and Jeannette A. Asper, by their
attorney in fact by deed dated July 30, 1992 and recorded in Cumberland County Deed Book "L"
Volume 36, Page 809, granted and conveyed to H. Scott Garling and Michael J. Cassidy, co-
partners, t/d/b/a G&C Associates. H. Scott Garling died July 29, 1994. Letters of
Administration were issued to Barbara L. Garling on August 8, 1994, by the Cumberland County
Register of Wills. By specific provision of the Partnership Agreement between H. Scott Garling
and Michael J. Cassidy, the personal representative of a deceased partner, succeeded to the
interest of the deceased partner and continued to conduct partnership business. Barbara L.
Garling previously elected to succeed to the interest of the deceased partner, but has since
withdrawn from the partnership. Julie A. Cassidy became a partner and joined in the deed of
conveyance with Michael J. Cassidy as Grantors to Educational Property Group, Inc. The parties
who executed the deed of conveyance were all of the partners of G&C Associates, and their deed
of conveyance was approved in accordance with the requirements of the Partnership Agreement.
BEING Tax Parcel Number: 36-35-2385-131
WEIR & PARTNERS LLP
By: Daniel D. Haggerty, Esquire
Attorney ID No. 77894
The Widener Building, Suite 500
1339 Chestnut Street
Philadelphia, PA 19107
dhaggerty@weirpartners.com
P: (215) 665-8181
F: (215) 665-8464
Attorneys for Narberth Property Acquisition, LLC
NARBERTH PROPERTY ACQUISITION, LLC
732 Montgomery Avenue
Narberth, PA 19072
Plaintiff,
V.
NARBERTH PROPERTY ACQUISITION, LLC,
Successor in Title to Shippensburg Apex, LP
732 Montgomery Avenue
Narberth, PA 19072
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION
C -*'
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PETITION FOR JUDGMENT IN
MORTGAGE FORECLOSURE BY CONSENT
TO THE PROTHONOTARY:
Kindly enter the Proposed Judgment in Mortgage Foreclosure by Consent.
Dated: August 23, 2011
Counsel for Narberth Property
Acquisition, LLC
WEIR & PARTNERS LLP
By: Daniel D. Haggerty, Esquire
Attorney ID No. 77894
The Widener Building, Suite 500
1339 Chestnut Street
Philadelphia, PA 19107
dhaggerty@weirpartners.com
P: (215) 665-8181
F: (215) 665-8464
Attorneys for Narberth Property Acquisition, LLC
NARBERTH PROPERTY ACQUISITION, LLC
732 Montgomery Avenue :
Narberth, PA 19072
Plaintiff,
V.
NARBERTH PROPERTY ACQUISITION, LLC,
Successor in Title to Shippensburg Apex, LP
732 Montgomery Avenue
Narberth, PA 19072
Defendant
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION
NO.
CERTIFICATE OF SERVICE
I, Daniel D. Haggerty, Esquire, hereby certify that a copy of the Petition for Judgment in
Mortgage Foreclosure by Consent was served via U.S. First Class Mail, postage prepaid upon the
following:
NARBERTH PROPERTY ACQUISITION, LLC,
Successor in Title to Shippensburg Apex, LP
c/o Daniel D. Haggerty, Esquire
The Widener Building, Suite 500
1339 Chestnut Street
Philadelphia, PA 19107
Date: August 23, 2011
WEIR & PARTNERS LLP
By: Daniel D. Haggerty, Esquire
Attorney ID No. 77894
The Widener Building, Suite 500
1339 Chestnut Street
Philadelphia, PA 19107
dhaggerty@weirpartners.com
P: (215) 665-8181
F: (215) 665-8464
Attorneys for Narberth Property Acquisition, LLC
NARBERTH PROPERTY ACQUISITION, LLC
732 Montgomery Avenue
Narberth, PA 19072
Plaintiff,
V.
NARBERTH PROPERTY ACQUISITION, LLC,
Successor in Title to Shippensburg Apex, LP
732 Montgomery Avenue
Narberth, PA 19072
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION
NO
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JUDGMENT IN MORTGAGE FORECLOSURE BY CONSENT
AND NOW, this 2y' day of 2011, it is hereby
ORDERED and DECREED that Judgment in Mortgage Foreclosure is hereby entered in favor of
Plaintiff, Narberth Property Acquisition, LLC and against Defendant, Narberth Property
Acquisition, LLC in the total amount of $16,696,693.48 as of August 12, 2011, plus continuing
interest, attorneys' fees and cost until paid in full.
BY THE COURT:
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Approved as to form:
WEIR & PARTNERS LLP
BY:
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Daniel D. Haggerty, Esquire
Counsel for Narberth Property
Acquisition, LLC (Plaintiff and Defendant)
THORP REED & ARMSTRONG, LLR ErJTNIPIT?'
By: JONATHAN W. HUGG 7D13 JAPE _8 AM 9. 55
j hugg@a,thorpreed. com
Attorney ID No. 73589 1'(1P1?ERlA10 ?Y for Plaintiff,
One Commerce Square, Suite 1000 pNSYL o
Yberneyrth Property Acquisition, LLC.
2005 Market Street
Philadelphia, PA 19103
Phone: (215) 640-8500
Fax: (215) 640-8501
NARBERTH PROPERTY ACQUISITION, LLC,
Plaintiff, COURT OF COMMON PLEAS
CUMBERLAND COUNTY
V.
NARBERTH PROPERTY ACQUISITION, LLC,
Successor in Title to Shippensburg Apex, LP
Defendant.
: NO. 11-6698
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of Jonathan W. Hugg, Esquire of Thorp Reed & Armstrong,
LLP on behalf of Plaintiff, Narberth Property Acquisition, LLC.
Dated: December 26, 2012
THORP REED & ARMSTRONG, LLP
By:- k? 9
JONATHAN W. GG, Esq.
Attorney ID No.73589
One Commerce Square, Suite 1000
2005 Market Street, Suite 1000
Philadelphia, PA 19103
(215) 640-8500
j huggna,thorpreed. c om
(PO16T790)
THORP REED & ARMSTRONG, LLP
By: JONATHAN W. HUGG
jhugg@thorgreed.com
Attorney ID No. 73589
One Commerce Square, Suite 1000
2005 Market Street
Philadelphia, PA 19103
Phone: (215) 640-8500
Fax: (215) 640-8501
NARBERTH PROPERTY ACQUISITION, LLC,
Plaintiff,
V.
NARBERTH PROPERTY ACQUISITION, LLC,
Successor in Title to Shippensburg Apex, LP
Defendant.
Attorney for Plaintiff,
Narberth Property Acquisition, LLC.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 11-6698
CERTIFICATE OF SERVICE
I, Jonathan W. Hugg, hereby certify that I caused to be served, this 26th day of December,
2012, a true and correct copy of my Entry of Appearance, via first class mail, postage prepaid, as
follows:
Narberth Property Acquisition, LLC
732 Montgomery Avenue
Narberth, PA 19072
(Defendant)
December 26, 2012 w l
JONATHAN W. H G, Esq.
{eo1e779o}
THORP REED & ARMSTRONG ItilO `
By: JONATHAN W. HUGG 2013 JAN -g AM 9: 55
Jhuggka thorpreed.com
Attorney ID No. 73589 CUMSE LAND COUNTY
One Commerce Square, Suite 1000 PENNSYLVANIA Attorney for Plaintiff,
2005 Market Street Narberth Property Acquisition, LLC.
Philadelphia, PA 19103
Phone: (215) 640-8500
Fax: (215) 640-8501
NARBERTH PROPERTY ACQUISITION, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
V.
NARBERTH PROPERTY ACQUISITION, LLC,
Successor in Title to Shippensburg Apex, LP
Defendant.
: NO. 11-6698
PRAECIPE TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Kindly mark the judgment in the above-captioned matter as Satisfied.
Dated: December 26, 2012
THORP REED & ARMSTRONG, LLP
By: "
JONATHAN W. INUGG, Esq.
Attorney ID No.73589
One Commerce Square, Suite 1000
2005 Market Street, Suite 1000
Philadelphia, PA 19103
(215) 640-8500
jhugg@thorpreed.com
0 I ?
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THORP REED & ARMSTRONG, LLP
By: JONATHAN W. HUGG
j hugg(&thorpreed.com
Attorney ID No. 73589
One Commerce Square, Suite 1000
2005 Market Street
Philadelphia, PA 19103
Phone: (215) 640-8500
Fax: (215) 640-8501
NARBERTH PROPERTY ACQUISITION, LLC,
Plaintiff,
V.
NARBERTH PROPERTY ACQUISITION, LLC,
Successor in Title to Shippensburg Apex, LP
Defendant.
Attorney for Plaintiff,
Narberth Property Acquisition, LLC.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
: NO. 11-6698
CERTIFICATE OF SERVICE
I, Jonathan W. Hugg, hereby certify that I caused to be served, this 26th day of December,
2012, a true and correct copy of the foregoing Praecipe to Satisfy Judgment, via first class mail,
postage prepaid, as follows:
Narberth Property Acquisition, LLC
732 Montgomery Avenue
Narberth, PA 19072
(Defendant)
December 26, 2012 'N? ?rJ ?Jl{,
JONATHAN W. HU , Esq.
IP0167791}
THORP REED & ARMSTRONG;:LILW ORO x HotJI IAR
By: JONATHAN W. HUGG
jhugg_gthorpreed.com W3 JAN "8 AM 9' 55
Attorney ID No. 73589 CUMSERLAND GOV TA&orney for Plaintiff,
One Commerce Square, Suite 1000 ?Et 14S*L11ANIA Narberth Property Acquisition, LLC.
2005 Market Street
Philadelphia, PA 19103
Phone: (215) 640-8500
Fax: (215) 640-8501
NARBERTH PROPERTY ACQUISITION, LLC,
Plaintiff, COURT OF COMMON PLEAS
CUMBERLAND COUNTY
V.
NO. 11-6698
NARBERTH PROPERTY ACQUISITION, LLC,
Successor in Title to Shippensburg Apex, LP
Defendant.
PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Please mark the above-captioned matter settled, discontinued and ended, without
prejudice.
THORP REED & ARMSTRONG LLP
By: W
/,E-sq-.
JONATHAN W. 2_3
Attorney ID No.73589
One Commerce Square, Suite 1000
2005 Market Street, Suite 1000
Philadelphia, PA 19103
(215) 640-8500
j hugg.@a,thomreed. com
Dated: December 26, 2012
{P0167792}
THORP REED & ARMSTRONG, LLP
By: JONATHAN W. HUGG
ihuga(aAhorpreed.com
Attorney ID No. 73589
One Commerce Square, Suite 1000
2005 Market Street
Philadelphia, PA 19103
Phone: (215) 640-8500
Fax: (215) 640-8501
NARBERTH PROPERTY ACQUISITION, LLC,
Plaintiff,
V.
NARBERTH PROPERTY ACQUISITION, LLC,
Successor in Title to Shippensburg Apex, LP
Defendant.
Attorney for Plaintiff,
Narberth Property Acquisition, LLC.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 11-6698
CERTIFICATE OF SERVICE
I, Jonathan W. Hugg, hereby certify that I caused to be served, this 26th day of December,
2012, a true and correct copy of the foregoing Praecipe to Settle, Discontinue and End, Without
Prejudice, via first class mail, postage prepaid, as follows:
Narberth Property Acquisition, LLC
732 Montgomery Avenue
Narberth, PA 19072
(Defendant)
December 26, 2012
(A ? I l? t)'' f L
JONATHAN W. HUG (f, Esq.
{P016779z,