HomeMy WebLinkAbout13-1392 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH OF IN THE COURT OF COMMON PLEAS
PENNSYLVANIA by the CUMBERLAND COUNTY,
DEPARTMENT OF COMMUNITY AND PENNSYLVANIA
ECONOMIC DEVELOPMENT,
Plaintiff
V. No. 13 - /39 a,
IAN ANDERSON
Defendant CIVIL ACTION — LAW
CONFESSION OF JUDGMENT
Pursuant to the authority contained in the Warrant of Attorney, the original or a copy of which is
attached to the complaint filed in this action, I appear for the defendant and confess judgment in
favor of the plaintiff and against defendant as follows:
c cm =;
Principal Balance $83,805.69 -om _.; ` +
x'M
Accrued Interest
through 3/1/13 at 2.00%
g $1,257.12
Late Charges $73.12
TOTAL $ 135.93 i
j
BY: /
John WA. Quain
Supreme Court No. 311983
Governor's Office of General Counsel
Department of Community &
Economic Development
400 North Street, Plaza Level
Harrisburg, PA 17120 -0225 Q 0
(717) 214 -5300 - Phone
(717) 772 -3103 -Fax �
Counsel for Plaintiff 17-rY-
��� �I18 I
R.L
)0 MC(_?j&(
THIS IS NOT AN ARBITRATION CASE
AN ASSESSMENT OF DAMAGES HEARING IS NOT'_FREQUIRED
John M. Ouain Jr.
Supreme Court No. 311983
Governor's Office of General Counsel
Department of Community &
Economic Development
400 North Street, Plaza Level
Harrisburg, PA 17120 -0225
(717) 214 -5300 - Phone
(717) 772 -3103 - Fax
iquain(a)_pa.gov
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH OF IN THE COURT OF COMMON PLEAS
PENNSYLVANIA by the CUMBERLAND COUNTY,
DEPARTMENT OF COMMUNITY AND PENNSYLVANIA
ECONOMIC DEVELOPMENT,
Plaintiff
V. No.13 u
IAN ANDERSON
Defendant CIVIL ACTION — LAW
COMPLAINT IN CONFESSION OF JUDGMENT UNDER PA.R.C.P. 7951
1. Plaintiff, Pennsylvania Department of Community and Economic Development
(hereinafter "DCED "), is a political body organized and existing under and by
virtue of the laws of the Commonwealth of Pennsylvania, having its principal
place of business at the Commonwealth Keystone Building, 400 North Street, 4th
Floor, Harrisburg, Pennsylvania 17120 - 022.5.
2. Defendant, Ian Anderson ( "Defendant ") is an adult individual with a last known
address of 412 Shed Road, Newville Pennsylvania 17241.
3. Daniel Parson d /b /a Shooting the X, ( "Borrower ") is a Pennsylvania limited
liability company with a last known business address of 233 Allen Road, Carlisle
Pennsylvania, 17013.
4. On or about November 18, 2011, Borrower executed a Note ("Note") in the
principal amount of Eighty Eight Thousand Dollars ($88,000.00). A true and
correct copy of this Note is attached hereto as "Exhibit A ".
5. Borrower has defaulted on the Note attached hereto as "Exhibit A" by failing to
make payments when due.
6. On or about November 7, 2011, Defendant Ian Anderson entered into a Guaranty
and Surety Agreement ( "Guaranty ") promising to pay any amounts due under the
Note attached as "Exhibit A." A true and correct copy of the Guaranty and Surety
Agreement executed by Defendant is attached hereto as "Exhibit B."
7. The Borrower has defaulted under the agreement attached hereto as "Exhibit A"
by failing to make payment as demanded.
8. The judgment is not being entered against a natural person in connection with a
consumer credit transaction.
9. No assignment has been made of the Note attached hereto as "Exhibit A."
10. No assignment has been made of the Guaranty attached hereto as "Exhibit B."
11. Judgment has not been previously entered against the Defendant in any
jurisdiction on the Guaranty attached as "Exhibit B ".
12. The Defendant has thus become liable to Plaintiff for the following sum set forth
in "Exhibit A":
Principal Balance $83,805.69
Accrued Interest
through 3/1/13 at 2.00% $1,257.12
Late Charges $73.12
TOTAL $85,135.93
13. Judgment is demanded as authorized by the Warrant of Attorney contained in
Exhibit B.
14. The Warrant of Attorney appearing in the attached exhibit is less than twenty
years old.
WHEREFORE, Plaintiff demands judgment in its favor and against Defendant,
Ian Anderson, in the total amount of Eighty Five Thousand One Hundred Thirty Five
Dollars and Ninety Three Cents ($85,135.93) together with interest accruing at the rate
set forth in the instrument.
COMMONWEALTH OF PENNSYLVANIA
DEPARTM F COMMUNITY &
ECO O C DEV LOPMENT
z
oh M. Quain Jr.
Supreme Court No. 311983
Governor's Office of General Counsel
Department of Community &
Economic Development
400 North Street, Plaza Level
Harrisburg, PA 17120 -0225
(717) 214 -5300 - Phone
(717) 772 -3103 - Fax
4quain(a-D.pa.gov
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH OF IN THE COURT OF COMMON PLEAS
PENNSYLVANIA by the CUMBERLAND COUNTY,
DEPARTMENT OF COMMUNITY AND PENNSYLVANIA
ECONOMIC DEVELOPMENT,
Plaintiff
V. No. `3 — !3 9 Ovv i
IAN ANDERSON
Defendant CIVIL ACTION — LAW
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Jared Lucas, being duly sworn according to law, deposes and says that he is the
Director of the Small Business First Office for Plaintiff herein that he is authorized to
make this affidavit on behalf of Plaintiff that the facts set forth in the foregoing Complaint
for Confession of Judgment are true and correct to the best of his knowledge,
information and belief and that the Exhibits attached to the Complaint are true and
correct copies of the originals.
�Mp
BY
Jare6 Luca
Director, mall Business First
Sworn to and subspribed
before me this %� `` day
,of 2013.
otary , ublic
GMEMKk ONWEALT Of PENNSYLVANIA
Notarlai seal
nifer Ann Fogarty, Notary Public
y of Harrisburg, Dauphin County
Commission res Dec. 19, 2016
OENNSYLVAN IA ASSpCIA110N OF NOTARIES
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH OF IN THE COURT OF COMMON PLEAS
PENNSYLVANIA by the CUMBERLAND COUNTY,
DEPARTMENT OF COMMUNITY AND PENNSYLVANIA
ECONOMIC DEVELOPMENT,
Plaintiff
V. No.
IAN ANDERSON
Defendant CIVIL ACTION — LAW
CERTIFICATION OF ADDRESSES
John M. Quain Jr., attorney for the Commonwealth of Pennsylvania.. Department
of Community and Economic Development, certifies that the present address of the
Plaintiff, Department of Community and Economic Development is, 400 North Street,
Fourth Floor, Harrisburg, Pennsylvania 17120; and the last kn n re Df Defendant
Ian Anderson is 412 Shed Road, Newville Pennsylvania 17
I i
BY: k
John W. Quain Jr. T
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH OF IN THE COURT OF COMMON PLEAS
PENNSYLVANIA by the CUMBERLAND COUNTY,
DEPARTMENT OF COMMUNITY AND PENNSYLVANIA
ECONOMIC DEVELOPMENT,
Plaintiff
V. No.
IAN ANDERSON
Defendant CIVIL ACTION — LAW
AFFIDAVIT PURSUANT TO PA.R.C.P. 2951(a)(3)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND :
Jared Lucas, being duly sworn according to law, deposes and says that he is the
Director of the Small Business First Office for Plaintiff herein; that he is authorized to
make this affidavit on behalf of Plaintiff; and that judgment is not being entered by
confession against a natural person in connection with a consumer credit transaction.
B) ":
Jar d Luca
Director, Small Business First
Sworn to and subscribed
before me this ,p day
bf? March, 2013.
''Notary P4blic
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH OF IN THE COURT OF COMMON PLEAS
PENNSYLVANIA by the CUMBERLAND COUNTY,
DEPARTMENT OF COMMUNITY AND PENNSYLVANIA
ECONOMIC DEVELOPMENT,
Plaintiff
V. No.
IAN ANDERSON
Defendant CIVIL ACTION — LAW
AFFIDAVIT THAT ACTION DOES NOT
ARISE OUT OF RETAIL INSTALLMENT CONTRACT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Jared Lucas, being duly sworn according to law, deposes and says that he is the
Director of the Small Business First Office for Plaintiff herein; that he is authorized to
make this affidavit on behalf of Plaintiff; and that this is not an action by a seller, holder
or assignee arising out of a retail installment sale, contract or account.
BY:
Jare6 Luca
Director, Small Business First
Sworn to and subscribed
before me this iaJ `' day
f March, 2013.
'Notary public '
CQMMONM&M QF PENN SYLVANIA
Notarial Seal
Jennifer Ann Fogarty, Notary Public
City of Harrisburg, Dauphin County
My Commission Expires Dec. 19, 2016
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH OF IN THE COURT OF COMMON PLEAS
PENNSYLVANIA by the CUMBERLAND COUNTY,
DEPARTMENT OF COMMUNITY AND PENNSYLVANIA
ECONOMIC DEVELOPMENT,
Plaintiff
V. No.
IAN ANDERSON
Defendant CIVIL ACTION — LAW
AFFIDAVIT OF BUSINESS TRANSACTION
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Jared Lucas, being duly sworn according to law, deposes and says that he is the
Director of the Small Business First Office for Plaintiff herein; that he is authorized to
make this affidavit on behalf of Plaintiff; and that this transaction upon which judgment is
being entered by confession was a business and commercial transaction. BY-
Ja ed Luc
Director, mall Business First
Sworn to and subscribed
before me this % day
of March, 2013.
;lotary ,ublic
IME SY��ANIA �NOterY public V,Dauphi 1�g my MEMBER, PENNSYLVANIA ASOaA ION NOTARIES
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH OF IN THE COURT OF COMMON PLEAS
PENNSYLVANIA by the CUMBERLAND COUNTY,
DEPARTMENT OF COMMUNITY AND PENNSYLVANIA
ECONOMIC DEVELOPMENT,
Plaintiff
V. No.
IAN ANDERSON [
Defendant CIVIL ACTION — LAW
AFFIDAVIT OF NON - MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Jared Lucas, being duly sworn according to law, deposes and says that he is the
Director of the Small Business First Office for Plaintiff herein; and that to the best of his
knowledge, information and belief the Defendant, Ian Anderson, is not in the Military
Service of the United States, nor any State or Territory thereof or its allies as defined in
the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto.
f
BY - . r
Jar d Luc
Director mall Business First
Sworn to and subscribed
before me this day
of- March, 2013.
otary. ublic
co TN P 'ENNSYWANIA
Notarial Seai
Jennifer Ann Fogarty, Not Public
city of Harrisburg, Dauphin county
My commission Expires Dec• 19, 2016
MEMBER,PENNSYLVANIA ASSOCIATION OF NOT
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH OF IN THE COURT OF COMMON PLEAS
PENNSYLVANIA by the CUMBERLAND COUNTY,
DEPARTMENT OF COMMUNITY AND PENNSYLVANIA
ECONOMIC DEVELOPMENT,
Plaintiff
V. No. 3 — �,3 �� G✓v . 'f
IAN ANDERSON
Defendant CIVIL ACTION — LAW
NOTICE OF ENTRY OF JUDGMENT, ORDER OR DECREE
Pursuant to requirements of Pennsylvania Civil Procedural Rule 236, you are notified
that there was entered in this office today, in the above - captioned case.
❑ Judgment of $85,135.93 for Plaintiff and against Defendant.
❑ Judgment for Defendant and against Plaintiff.
❑ Order of Decree in favor of
PROTHON TARY OF CUMBERLAND C UNTY
Dated J// S //v
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH OF IN THE COURT OF COMMON PLEAS
PENNSYLVANIA by the CUMBERLAND COUNTY,
DEPARTMENT OF COMMUNITY AND PENNSYLVANIA
ECONOMIC DEVELOPMENT,
Plaintiff
V. No. 3 of c,V,^�
IAN ANDERSON
Defendant CIVIL ACTION — LAW
Notice Under Rule 2958.1 of Judgment and Execution Thereon
Notice of Defendant's Rights
To Ian Anderson
412 Shed Road
Newville, Pennsylvania 17241
A judgment in the amount of $85,135.93 has been entered against you and in favor of
the Plaintiff without any prior notice or hearing based on a confession of judgment contained in
a written agreement or other paper allegedly signed by you. The sheriff may take your money
or other property to pay the judgment at any time after thirty (30) days after the date on which
this Notice is served on you.
You may have legal rights to defeat the judgment or to prevent your money or property
from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT
AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH
THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
Court Administrator
4 Floor, Cumberland County Courthouse
Carlisle, PA 17103
717- 240 -6200
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH OF IN THE COURT OF COMMON PLEAS
PENNSYLVANIA by the CUMBERLAND COUNTY,
DEPARTMENT OF COMMUNITY AND PENNSYLVANIA
ECONOMIC DEVELOPMENT,
Plaintiff
V. No.
IAN ANDERSON
Defendant CIVIL ACTION — LAW
AVERMENT OF DEFAULT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Jared Lucas, being duly sworn according to law, deposes and says that he is the
Director of the Small Business First Office for Plaintiff herein; that he is authorized to make this
affidavit on behalf of Plaintiff; and that Defendant Ian Anderson, entered into a Guaranty and
Surety Agreement dated November 7, 2011, guaranteeing the Note dated November 18, 2011
in the principal amount of Eighty Eight Thousand Dollars ($88,000.00) and that Borrower has
defaulted on the Note. A true and correct copy of the Guarantee dated November 7, 2011 is
attached as "Exhibit B ". Deponent also avers that there is $85,135.93 due and owing under the
Note.
BY:
Jar d Luc
Direct Small Business First
Sworn to and subscribed
before me this - day
of, March, 2013.
'L (,� (�
Notary F)'ublic
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Jennifer Ann Fogarty, Notary Public
City of Harrisburg, Dauphin County
My Commission Expires Dec. 19, 2016
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH OF IN THE COURT OF COMMON PLEAS
PENNSYLVANIA by the CUMBERLAND COUNTY,
DEPARTMENT OF COMMUNITY AND PENNSYLVANIA
ECONOMIC DEVELOPMENT,
Plaintiff
V. No.
IAN ANDERSON
Defendant CIVIL ACTION — LAW
PRAECIPE FOR ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Please assess damages now due on the judgment in this action against
Defendant as follows:
Principal Balance $83,805.69
Accrued Interest
through 3/1/13 at 2.00% $1,257.12
Late Charges $73.12
TOTAL ,1�
BY:
John M. Quain Jr.
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH OF IN THE COURT OF COMMON PLEAS
PENNSYLVANIA by the CUMBERLAND COUNTY,
DEPARTMENT OF COMMUNITY AND PENNSYLVANIA
ECONOMIC DEVELOPMENT,
Plaintiff
V. No.
IAN ANDERSON
Defendant CIVIL ACTION — LAW
JUDGMENT AND ASSESSMENT OF DAMAGES
I assess damages as above and judgment is entered for Plaintiff, Department of
Community and Economic Development, and against Defendant, Ian Anderson, in the
amount of $85,135.93, plus interest after judgment at the rate of $1.42 per diem.
PROTHONO RY OF CUMBERLAND COUNTY
Dated: / 5
KMKJI 1 -07 -11 CEDL #210 - 212 -297
NOTE
Dated: November 18, 2011
At: Carlisle, Pennsylvania
588,000
FOR VALUE RECEIVED, the undersigned, DANIEL F. PARSON, JR.,d/b /a SHOOTING THE X,
a,sole proprietorship, existing under and by virtue of the laws of the Coinmonwealth of Pennsylvania (the
"Maker "), irrevocably promises to pay to the order of the COMMONWEALTH OF PENNSYLVP N1A, acting
by and through its DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT (the
"Department ") at the COMMUNITY ECONOMIC DEVELOPMENT LOAN PROGRAM at the Pennsylvania
Department of Labor and Industry, Loan Accounting, Box 884, Federal Square Station, Harrisburg,
Pennsylvania 17108, or at such other place as the Department may direct, the principal sum of Eighty -Eight
Thousand Dollars ($88,000) (the "Loan "), or so much thereof as will be disbursed to the Maker pursuant to the
terms of the Loan Agreement between the Department and the Maker dated the same date as this Note (the
"Loan Agreement "), together with interest as provided below, in lawful money of the United States of
America, payable in monthly instalhments, a portion of which will be interest at the rate of 2% per annum on
the outstanding principal balance calculated on the 30/360 accrual basis, and a portion of which will be a
payment of principal.
The first monthly payment of principal and interest is due on the first day of the month following the
first full month after closing. The entire unpaid balance due will be paid on December 1, 2016 (the "Maturity
Date "), or earlier if the repayment of the Loan is accelerated after Maker's default. Upon each disbursement,
the level monthly payment will be set at an amount calculated to fully amortize the outstanding principal
balance of the Loan by the Maturity Date. The Maker will onlybe charged for interest on the principal amount
actually outstanding and any portion of the payment in excess of accrued interest will be applied to principal.
The interest which accrues from the date of this Note through the last day of this month will be due at
the same time and in addition to the first monthly installment of principal and interest. The monthly
installments, and any partial prepayments, will be applied to any late charges, then to interest or., the unpaid
principal. and the balance to principal. In addition, if the Maker fails to pay any monthly installment on the
17nal -Note
]'age I of 4
date that it is due, the Maker will pay a late charge of twelve and one -half percent (12-1/2%) per amium of any
such over due amount to compensate the Department for damages suffered because of Maker's failure to make
prompt payments.
This Note is executed and delivered pursuant to the ]Loan Agreement, and is subject to all the tenns
and conditions thereof This Note is entitled to the security provided for in the Loan Agreement.
THE MAKER HEREBY COVENANTS AND AGP'.EES AS FOLLOWS:
1. All the terms, covenants, conditions and provisions of the Mortgage, the Security Agreement
and the Loan Agreement are incorporated herein by reference: and are made a part hereof, and any breach or
� thereof will constitute a breach or violation of this Note.
Each of the following shall constitute an event of default hereunder (an "Event of Default "):
(a) the Maker shall fail to pay any sum required to be paid by the Maker under this Note, the Loan Agreement,
the Mortgage or the Security Agreement within thirty (30) days after the same becomes due and payable; or (b)
there is an Event of Default as defined in the Loan Agreement.
3. Upon the occurrence of an Event of Default other than an Event of Default deriving
exclusively from a breach of Section 9(b), " Job Retention," of the Loan Agreement (a "Job Retention
Default "), pertaining to job retention, the Department may, in its discretion: (i) declare the whole unpaid
balance of the principal indebtedness, together with all interest. thereon and all other sums due hereunder, due
and payable immediately without notice to the Maker; and (ii) increase the rate of interest under this Note to a
rate not to exceed the greater of twelve and one -half percent (12 ' /2 %) per annum or the prime interest rate plus
two percent (2 %) per annum. For purposes of this Note, the prime interest rate shall be the rate o:" interest per
annum specified as Prone Rate in the Wall Street Journal under the table entitled "Money Rates." The increased
rate of interest shall apply retroactively to the first date of the event or conduct giving rise to the declaration of
the Event of Default and continue until such Event of Default is cured, and all additional unpaid interest that
accrues from the first date of the event or conduct giving rise to the declaration of the Event of Default shall be
immediately due and payable.
4. Upon the occurrence of a Job Retention Default, the Department shall have the right to
increase the rate of interest under this Note up to the prime interest rate plus two percent (2 %) per annum
unless the penalty is waived by the Secretary of the Department because such noncompliance is due to
f - Note
I'age 2 of 4
circumstances beyond the control of the Borrower. The increased rate of interest shall be effective as set forth
in a written notice from the Department to the Maker and continue prospectively until the Note is paid in full.
Upon the occurrence of an Event of Default under this Note (of which an affidavit on
behalf of the Department will be sufficient evidence), the Maker hereby irrevocably authorizes and
empowers any attorney of any court of record in the Commonwealth of Pennsylvania, or elsewhere, to
appear for and to enter and confess judgment against the Maker, at any time or times and as of any
term, for the principal sum above mentioned, with or without declaration, with interest and costs of
suit, without stay of execution, and with reasonable attorney's fees. The Maker agrees that any of its
property may be levied upon to collect said judgment and may be sold upon a writ of execution, and
hereby waives and releases all laws, now or hereafter in force, relating to exemption, appraisement or
stay of execution. The authority hereby granted to confess judgment will not be exhausted by any
exercise thereof, but will continue from time to time and at all times until the Maker has paid all sums
required to be paid by the Maker under this Note, the Loan Agreement,the Mortgage and the Security
Agreement and has performed all of the other provisions hereof or thereof to be performed by the
Maker.
5. The Maker may make partial prepayments on the principal indebtedness at any t fine, without
penalty or premium. The Maker may make prepayments of the entire principal indebtedness at any time,
without premium and without the approval of the Department.
6. All of the covenants herein contained will accrue to the benefit of the successors and assigns,
voluntary or involuntary, of the Department, including the Commonwealth.
7. The Maker hereby waives the technical requirements of demand, grace, presentment for
payment, protest, notice of dishonor or nonpayment and notice: of the exercise of any option hereunder, except
as notice and grace are specifically provided for in this Note or the Loan Agreement.
8. The remedies provided in this Note„ the Mortgage, the Security Agreement, and the Loan
Agreement or otherwise available to the Department for the enforcement of the payment of the principal sum
together with interest and the performance of the covenants, conditions, and agreements, matters and things
herein and therein contained are cumulative and concurrent and the Department at its sole discretion may
pursue them singly or successively or together and the Department may exercise them from time to time as
often as occasion occurs until the Department has been paid all sums due in full.
9. The terms and provisions of this Note are severable. This means that if any of the terms,
covenants, conditions or provisions of this Note are unenforceable or invalid under federal, state or other
Final - Nate
Page 3 of 4
applicable law, such unenforceability or invalidity will not make any other of the terms, covenants, conditions
or provisions hereof unenforceable or invalid. If any waiver by Maker in this Note is prohibited by law,
including but not limited to the waiver of exemption from execution, such waiver will be and be e'ecmed to be
deleted herefrom.
IN WITNESS WHEREOF, intending to be legallybound hereby, the Maker has caused this Note to be
(July executed, the day and year first above written.
W IINES S:
r '
Dani--04arson, Jr.
J' `'hzal - Note
.Page 4 of 4
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Commonwealth of Pennsylvania 000002 85 64930635
Remittance Advice
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Control Number Number Date Number Amount
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.J/24/2011 Page 1
CED LOAN # 17300221
COMPTROLLER'S OFFICE P.O. BOX 884 PROJECT #210- 212 -297
H ARRIS B URG, PA 17108 -0884 TEL: 717 - 425 -6587
DANIEL F. PA RSON, Jr. d /b /a SHOOTING THE X
Compound Period .......: Monthly
Nominal Annual Rate...: 2.000 %
Effective Annual Rate ..: 2.018 %
Periodic Rate ..............: 0.1667 %
Daily Rate _..._ ............: 0.00556 %
CASH FLOW DATA
Event Start Date Amount Number Period End D a_ to _
1 Loan 12/01/2011 88,000.00 1
2 Payment 01/01/2012 1,542.44 59 Monthly 11/01/2016
3 Payment 12/01/2016 1,542.65 1
AMORTIZATION SCHEDULE - Normal Amortization, 360 Day Year
Date Pa Interest Principal Bala
Loan 12/01/2011 88, 000.00
2011 Totals 0.00 0.00 0.00
1 01/01/2012 1,542.44 146.67 1,395.77 86,604.23
2 02/01/2012 1,542.44 144.34 1,398.10 85,206.13
3 03/01/2012 1,542.44 142.01 1,400.43 83,805.70
4 04/01/2012 1,542.44 139.68 1,402.76 82,402.94
5 05/01/2012 1,542.44 137.34 1,405.10 80, 997.84
6 06/01/2012 1,542.44 135.00 1,407.44 79, 590.40
7 07/01/2012 1,542.44 132.65 1,409,79 78,180.61
8 08/01/2012 1.542A4 130.30 1,412.14 76, 768.47
9 09/01/2012 1,542.44 127.95 '1,414.49 75,353.98
10 10/01/2012 1,542.44 125.59 1,416.85 73, 937.13
11 11/01/2012 1,542.44 123.23 1,419.21 72,517,92
12 12/01/2012 1,542.44 120.86 1,421.58 71,096.34
2012 Totals 18,509.28 1,605.62 16,903.66
13 01/01/2013 1,542.44 118.49 1,423.95 69, 672.39
14 02/01/2013 1,542.44 116.12 1,426.32 68, 246.07
15 03/01/2013 1,542.44 11 3.74 1,428.70 66,817.37
16 04/01/2013 1,542.44 111.36 1,431.08 65, 386.29
17 05/01/2013 1,542.44 108.98 1,433.46 63,952.83
18 06/01/2013 1,542.44 106.59 1,435.85 62, 516.98
19 07/01/2013 1,542.44 104.19 1,438.25 61, 078.73
20 08/01/2013 1,542.44 101.80 1,440.64 59,638.09
21 09/0112013 1,542.44 99.40 1,443.04 58,195.05
22 10/01/2013 1,542.44 96.99 1,445.45 56,749.60
2.3 11/01/2013 1,542.44 94.58 1,447.86 55, 301.74
24 12/01 /2013 1,542.44 92.17 1,450.27 53,851.47
X0/24/20 Page 2
DANIEL F. P ARSON, Jr. d /b /a SHOOTING THE X
Date Payment Interest Principal Balan
2013 Totals 18,509.28 1,264.41 17,244.87
25 01/01/2014 1,542.44 89.75 '1,452.69 52,398.78
26 02/01/2014 1,542.44 87.33 1,455.11 50,943.67
27 03/01/2014 1,542.44 84.91 1,457.53 49,486.14
28 04/01/2014 1,542.44 82.48 1,459.96 48,026.18
29 05/01/2014 1,542.44 80.04 1,462.40 46,563.78
30 06101/2014 1,542.44 77.61 '1,464.83 45,098.95
31 07/01/2014 1,542.44 75.16 '1,467.28 43,631.67
32 08/01/2014 1,542.44 72.72 1,469.72 42,161.95
33 09/01/2014 1,542.44 70.27 1,472.17 40,689.78
34 10101/2014 1,542.44 67.82 1,474.62 39,215.16
35 11/01/2014 1,542.44 65.36 1,477.08 37,738.08
36 12/01/2014 1,542.44 62.90 1,479.54 36,258.54
2014 Totals 18,509.28 916.35 17,592.93
37 01/0112015 1,542.44 60.43 1 ,482.01 34,776.53
38 02/01 /2015 1,542.44 57.96 1,484.48 33,292.05
39 03/01/2015 1,542.44 55.49 1 ,486.95 31, 805.10
40 04101/2015 1,542.44 53.01 1,489.43 30,315.67
41 05/01/2015 1,542.44 50.53 1,491,91 28,823.76
42 06/01/2015 1,542.44 48.04 1 ,494.40 27,329.36
43 07/01/2015 1 ,542.44 45.55 1,496,89 25,832.47
44 08/01/2015 1,542.44 43.05 1,499.39 24,333.08
45 09/01/2015 1,542.44 40.56 1,501.88 22,831.20
46 10/01/2015 1,542.44 38.05 1,504.39 21, 326.81
47 11/01/2015 1 35.54 1,506.90 19, 819.91
48 12/01/2015 1,542.44 33.03 1,509.41 18,310.50
2015 Totals 18.509.28 561.24 17,948.04
49 01/01/2016 1,542.44 30.52 1,511.92 16,798.58
50 02/01/2016 1 28.00 1,514.44 15,284.14
51 03/01/2016 1,542.44 25.47 1,516.97 13, 767.17
52 04/01/2016 1,542.44 22.95 1,519.49 12,247.68
53 05/01/2016 1,542.44 20.41 1,522.03 10,725.65
54 06/01/2016 1,542.44 17.88 1,524.56 9,201.09
55 07/01/2016 1,542.44 15.34 1,527.10 7,673.99
56 08/01/2016 1,542.44 12.79 1,529.65 6,144.34
57 09/01/2016 1,542.44 10.24 1,532.20 4,612.14
58 10/01/2016 1,542.44 7.69 1,534.75 3,077.39
59 11/01/2016 1,542.44 5.13 1,537.31 1,540.08
60 12/01/2016 1,542.65 2.57 1,540.08 0.00
2016 Totals 18,509.49 198.99 18,310.50
Grand Totals 92,546.61 4,546.61 88,000.00
KMIUI 1 -07 -11 CEDL #210- 212 -297
GUARANTY AND SURETY ,AGREEMENT
of
IAN AN
THIS GUARANTY AND SURETYSHIP AGREEMENT is being made on this day of November,
2011, effective as of November 18, 2011, BY IAN ANDERSON, an individual (the "Guarantor "), to the
COMMONWEALTH OF PENNSYLVANIA, acting by and through the DEPARTMENT OF
COMMUNITY AND ECONOMIC DEVELOPMENT (the "Department "), having its principal place of
business at Commonwealth Keystone Building, 400 North Street, Fourth Floor, Harrisburg, Pennsylvania
17120_
BACKGROUND OF AGREEMENT
A. Daniel F. Parson, Jr. d/b /a Shooting the X (the "Borrower") has entered into a Loan Agreement
with the Department dated the same date as this Guaranty (the "Loan Agreement ") for a loan from the
Department to the Borrower in the principal amount of Eighty Eight Thousand Dollars ($88,000) (the "Loan ").
B. The Loan and the obligations of the Borrower to repay the Loan with interest are contained in a
Note from the Borrower to the Department dated the same date as this Guaranty (the "Note "), and are secured
by a Mortgage, a Security Agreement and Financing Statement(s) in favor of the Department (collectively, the
"Security Documents "). The Security Documents create alien on the real property on which Borrower's place
of business is located of which Borrower is the owner in fee (the "Premises ") and a security interest in all
business assets and other personal property on the Premises. The Loan Agreement, the Note and the Security
Documents are sometimes collectively called the "Borrower's .Agreements,"
C. The proceeds of the Loan will be used by the Borrower toward the costs of a project described in
the Loan Agreement (the "Project ") in connection with Borrower's business at the Premises located at 233
Allen Road, Carlisle, Cumberland County, Pennsylvania.
D. The Department would not make the Loan without this Guaranty from the Guarantor.
Final — Guaranty and Surety .1greement
Page I of 9
NOW, THEREFORE, in order to induce the Department to make the Loan to the Borrower and for
other good and valuable consideration, the receipt of which is hereby acknowledged, the Guarantor does
hereby agree as follows:
L Unconditional Guaranty of Payment and Performance The Guarantor absolutely and
unconditionally promises and guarantees to the Department the due and punctual payment and full and faithful
performance of all amounts and obligations required to be paid or performed by the Borrower pursuant to the
Borrower's Agreements when and as the same shall become due and payable or subject to performance,
whether at maturity, by acceleration or otherwise according to the terns of the Borrower's Agreements.
2. Guaranty Not Affected The Guarantor agrees that neither an assignment nor a sale of the
Premises will have any affect on the obligations assumed and guaranteed by the Guarantor, which shall
continue with the same force and effect as if the assignment or sale had not been made. The Guarantor also
agrees that the Department may make a claim against the Guarantor under this Guaranty and demand payment
and performance by the Guarantor without any requirement that the Department proceed first against the
Borrower, the Project, the Premises or any other collateral securing the Loan or any other entity hai ing liability
for the Loan. The Guarantor agrees that the Department may make changes in any or all of the Borrower's
Agreements (provided that those changes do not include an increase in the principal amount of the Loan,
except by reason of increases to the principal from accrued and unpaid interest or other reimbursement
obligations of the Borrower) and such changes will not discharge the obligations of the Guarantor under this
Guaranty, which shall continue with the same force and effect as if the changes had not been made.
3. CONFESSION OF JUDGMENT AGAINST THE GUARANTOR IF ANY A OU
DUE TO TIM DEPARTMENT UNDER THE NOTE THE SECURITY DO CUMENT[Sl OR T H E LOAN
AGREEMENT REMAINS UNPAID OR IF THE BORROWER 1S IN DEFAULT U AN OF THE
T ERMS OF THE BORROWER'S AGREEMENTS THEN THE GUA HEREBY A UTHORIZES
A ND EMPOWF,RS IRREVOCABLY, THE PROTHONO CLERK OF COURT OR ANY
ATT ORNEY OF ANY COURT OF RECORD TO AP FOR THE GUA IN SU COURT,
I N TERM OR VACATION, AT ANY TIME AND CONFESS JUDGMENT IN F AVOR. OF THE
D EPARTMENT, WITH OR WITHOUT THE FILIN OF AN AVERMENT OR DECLARATION OF
D EFAULT, FOR SUCH AMOUNT AS MAY APPEAR TO BE UNPAID, ALL INTER DUE
"I HER EON AND ALL REASONABLE C OSTS INCURRED IN _ CONNECTION W THE
CO LLECTION OF SUCH AMOUNT TOGETHER WITH REASONABLE ATTORNEY'S F S. THE
G UA RANTOR SHALL NOT CAUSE ANY B IN E UIT TO BE FILED TO INTERFER IN ANY
MA NNER _W_ ITH THE OPERATION OF SUCH JUDGMENT, HEREBY RATIFYI AND
CONFIRMIN ALL 'THAT SAID ATTOR MAY DO B VIRTUE HEREOF. T HE
AU
Filial — Guaranty and Surety Agreement
Page 2 of 9
i
I
IIEREINABOVE GRANTED SHALL NOT BE EXHAUSTED BY ONE EXERCISE THERE BUT
_ I UDGMENT MAY BE CONFESSED AS AFORESAID FROM TIME TO TIME AND AS OFT AS ANY
DEFAULT SHALL OCCUR HEREUNDER. CONFESSION OF JUDGMENT MAY BE M ADE BY
FILING COPIES OF THE BORROWER'S AGREEMENTS AND THIS GUARANTY AGRE IN
LIEU OF ORIGINALS THEREOF.
THE GUARANTOR ACKNOWLEDGES THAT GUARANTOR UNDERS THE
ME ANING AND EFFECT OF THE CONFESSION CONTAINED IN THE FOREGOING PARAGRAPH.
S PECIFICALLY, THE GUARANTOR UNDERSTANDS AMONG OTHER THIN THAT
I ? GUA IS RELINQUISHING THE RIGHT TO HAVE NOTICE EXCEPT AS P
HEREIN, AN OPP TO BE HEARD AND THE RIGHT TO HAVE THE BURDEN OF PROOF
OF D EFAU LT REST ON THE DEPARTMENT PRIOR TO THE ENTRY OF JU (2) THE
ENT OF JUDGMENT MAY RESULT IN A LIEN ON GUARANTOR'S E Q PERTY,
(3) GUARANTOR WILL BEAR THE BURDEN AND EXPENSE OF ATTACKING THE J
AND CHALLENGING EXECUTION ON THE LIEN AND SALE OF THE PROPERTY CO VERE D
T HEREBY, AND (4) ENOUGH OF GUARANTOR'S PROPERTY MA BE TAKEN TO P AY THE
PRINCIPAL AMOUNT. INTEREST, COSTS AND ATTORNEY'S FEES.
4. Guaranty as Suretyship Agreement This Guaranty will be interpreted and construed as a
contract of suretyship in accordance with the laws of the Commonwealth of Pennsylvania.
5. Costs of Collection and Legal Fees In addition to all of the sums payable hereunder, the
Guarantor agrees to pay the reasonable costs and expenses incurred by the Department in connection with all
action taken to enforce collection under this Guaranty or any or all of the Borrower's Agreements upon default
by the Borrower and the Guarantor, whether by legal proceedings or otherwise, including reasonable attorney's
fees and court costs.
6. Guarantor's Review of the Borrower's Agreements The Guarantor has been afforded the
opportunity to examine and review the Borrower's Agreements and understands the obligations of the
Borrower which the Guarantor is agreeing to pay and perform.
1. Sub ordination of the Guarantor's Interests The Guarantor agrees that whatever right, title and
interest the Guarantor may have in and to the Project shall be, and the same is hereby made, subject and
subordinate to the security interest of the Security Documents.
8. Notic es . . Any notice or consent required or permitted by this Guaranty shall be in writing and
shall be deemed delivered if delivered in person or if sent by registered or certified mail, postage pre -paid,
return receipt requested, as follows, unless such address is changed by written notice hereunder:
Final — Guaranty and Surety 9greement
Page 3 of 9
(a) If to the Department:
Commonwealth of Pennsylvania
Department of Community and Economic Development
Commonwealth Keystone Building
400 North Street, Fourth Floor
Harrisburg, Pennsylvania 17120
Attention: Program Director - CEDL
(b) if to the Guarantor:
Ian Anderson
412 Shed Road
Newville, Pennsylvania 17241
Notice shall be effective upon delivery if delivered in person or on the second business day
following mailing if mailed.
9. Absolute and Unconditional Nature of Guarantor's Obligation The liability of the Guarantor
under this Guaranty is absolute and unconditional, without regard to the liability of any other person. The
Guarantor's liability will not in any manner be affected by reason of any action taken or not taken by the
Department, which action or inaction is herein consented and agreed to, nor by the partial or complete
unenforceability or invalidity of the Borrower Agreements or any other guaranty or surety agreement, pledge,
assignment or other security for any of the obligations guaranteed hereunder. No delay in making; demand on
the Guarantor or satisfaction of Guarantor's liability hereunder will prejudice the Department's right to enforce
such satisfaction. All of the rights and remedies of the Department will be cumulative. Any failure of the
D eparhment to exercise any right hereunder will not be construed as a waiver of the right to exercise the same
or any other right at any time or times thereafter.
10. Pennsylvania Law Governs The Guarantor agrees that this Guaranty will be governed by the
substantive law of the Commonwealth of Pennsylvania, including its statutes of limitations, but without regard
to its principles of conflict of laws. The Guarantor hereby consents to the application of Pennsylvania law to
this Guaranty and to the jurisdiction of the courts of the Commonwealth of Pennsylvania including, without
limitation, the Common Pleas Courts of Dauphin County.
H. The Guarantor's Consents and Waivers The Guarantor hereby:
(a) Consents that the Department may without the Guarantor's consent and without
affecting the Guarantor's obligations:
Final — Guaranty and Surety Agreement
Page 4 of 9
(i) Exchange, release or surrender any collateral under the SecurityDocument[s],
or waive, release or subordinate any security interest, in whole or in part, now or hereafter held as security for
any of the obligations guaranteed hereunder;
(ii) Waive or delay the exercise ofany of the rights or remedies of the Department
against the Borrower or any other person or entity, including, without limitation, the Guarantor;
(iii) Release the Borrower or any other person or entity;
(iv) Renew, extend, or modify the terns of any of the obligations guaranteed
hereunder or any instrument or agreement evidencing the same; and
(v) Apply payments by the Borrower, the Guarantor, or any other person or entity,
to any of the obligations guaranteed hereunder.
(b) Waives all notices whatsoever with respect to this Guaranty or with respect to the
obligations guaranteed hereunder, except as provided in paragraph 3 hereinabove, including, without
limitation, notice of:
(i) The acceptance hereof by the Department or the intention to act, or the action,
by the Department, in reliance hereon;
(ii) The present existence or future incurring of any of the obligation, guaranteed
hereunder or any terms or amounts thereof or any change therein;
(iii) Any default by the Borrower or any surety, pledgor, grantor of security, or
guarantor, and
(iv) The obtaining or release of any guaranty or surety agreement (in addition to
this Guaranty), pledge, assignment, or other security for any of the obligations guaranteed hereunder.
The Guarantor waives notice of presentment, demand, protest and notice of non - payment,
protest in relation to any instrument evidencing any of the obligations guaranteed hereunder, and any other
demands and notices required by law, except as such waiver may be expressly prohibited by law.
12. Successors and Assigns This Guaranty will inure to the benefit of the Department and the
Department's successors and assigns and will be binding upon the Guarantor, and the Guarantor's successors
and assigns.
13. Repre and Warranties of the Gua rantor (s) . In order to induce the Department to
enter into the Loan Agreement and to perform its obligations thereunder, the Guarantor makes the following
representations and warranties to the Department:
(a) The Guarantor is an adult individual of legal age and has unimpaired legal capacity to
enter into contracts and agreements, including, without limitation, this Guaranty. This Agreement and each of
the Loan Documents to which the Guarantor is a party constitute the duly authorized, legal and valid and
Final — Guaranty and Surety Agreement
Page 5 of 9
binding obligations of the Guarantor, except as the enforceability thereof may be limited by bankruptcy,
insolvency, or other substantially similar laws of general application relating to the enforcement of creditors
rights or by general principles of equity.
(b) No approval is required to authorize, or is otherwise required in connection with, the
execution, delivery and performance by the Guarantor of, or the legality, validity, binding effect or
enforceability of the obligations of the Guarantor under, this Agreement or the Loan Documents to which
Gu arantor is a party, including the making of any of the payments provided for herein or therein, the absence of
which approval could have a material adverse effect on the ability of the Guarantor to make payments or
perform and observe their other material obligations hereunder or thereunder, other than has been validly
obtained. The Guarantor is not aware of any circurnstances as a result of which any such approval may be
revoked or cancelled.
(c) The Guarantor is not in default under any agreement to which Guarantor is a party
which default could have a material adverse effect on the ability of such Guarantor to make payments
hereunder or perform and observe his or her other material obligations hereunder, and the execution, delivery
and performance of this Agreement and the Loan Documents to which the Guarantor is a party, the
consummation of the transactions contemplated in this Agreement and the Loan Documents and the
compliance with the terns and provisions of this Agreement and the Loan Documents to which Guarantor is a
party, do not (i) contravene any provision of law, statute, rule or regulation to which the Guarantor is subject or
any judgment„ decree, franchise, order or permit applicable to the Guarantor, or (ii) conflict with, or result in
any breach of any of the terns, covenants, conditions or provisions of, or constitute a default order, or result
in the creation or imposition of (or the obligation to create or impose) any lien upon any of the assets or
revenues of the Guarantor pursuant to the terms of, any indenture, mortgage, deed of trust, agreement or other
instrument to which the Guarantor is a party or by which Guarantor is bound or to which Guarantor may be
subject.
(d) "There are no court actions, suits or proceedings, and no proceedings before any
arbitral tribunal or by or before any governmental commission, board, bureau or other administrative agency,
pending or threatened in writing, against the Guarantor which could have a material adverse effect on the
financial condition of the Guarantor or the ability of the Guarantor to perform their obligations under this
Agreement or the .Loan Documents to which the Guarantor is a party.
(e) All written agreements relating to the acquisition or construction or financing of the
Project (the "Project Docuuments") (including any amendments thereto), originals or true and correct copies of
which (or, if the Department shall have pennitted, fair and accurate summaries ofwhich) have heretofore been
supplied to the Department, and the Loan Documents, will be in full force and effect on the Closing Date, and
Final — Guaranty and Sureh� Agreement
Page 6 of 9
there are in existence no agreements, laws, rules, regulations, orders, judgments, injunctions, decrees,
resolutions, determinations, awards or other instruments whatsoever amending, supplementing or affecting, or
affecting the rights and obligations of the Guarantor under the Loan Documents, or the Project Documents, in a
manner which could have a material adverse effect on the ability of the Guarantor to make payments or to
perfonn and observe the Guarantor's other material obligations under this Agreement, the Project Documents
and Loan Documents to which the Guarantor is and on the Closing Date will be a party.
(f) To the best knowledge and belief of the Guarantor, all information supplied to the
Department in connection with the Loan Documents, as of the respective dates of such materials were, and as
of the date hereof, are true and accurate in all material respects and did not and do not contain any untrue
statement of a material fact or omit to state any material fact necessary to make the statements therein not
misleading, provided that (i) the statements therein describing documents and agreements are summaries only
and such summaries are qualified by reference to such documents and agreements, and (ii) to the extent any
such information therein provided by the Guarantor was based upon or constitutes a forecast, projection or
other data which by its nature is uncertain, the Guarantor represents only that Guarantor acted in good faith and
utilized due and careful consideration and the best inforniation known to them Guarantor in the pr -.paration of
such information.
(g) No default with respect to any agreement pursuant to which the Guarantor, or any
affiliate the Guarantor, has borrowed money or (except for (i) endorsement of negotiable instruments in the
ordinary course of business or (ii) guaranties in the ordinary course of business of travel or relocation expenses
of employees in non - material amounts) guaranteed the obligations of others has occurred and is continuing
which default potentially may have a material adverse effect on the financial condition of the Guarantor.
(h) All financial statements of the Guarantor and all supplementary financial information
delivered to the Department fairly present what they purport to present as of the dates and for the periods
presented. Guarantor has no material direct or indirect, absolute or contingent, liabilities except as shown
therein. Since the date of the most recent financial statements furnished to the Department prior to approval of
the Loan by the Department there has not been a material adverse change in the financial condition of the
Guarantor.
(i) Guarantor has good and marketable title to all assets shown as owned by Guarantor in
the financial statements delivered to the Department in connection with the Application, subject to no
mortgage, lien, pledge, judgment, or encumbrance except as previously disclosed to the Department in writing.
(j) Except as disclosed in an Exhibit hereto, the Guarantor has not been convicted by any
court of any felony, or any misdemeanor involving theft, dishonesty, deception, false swearing, or the filing or
submission of any false or misleading information to any agency of government.
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PaA,e 7 of 9
14. Docum under Seal This Guaranty is intended to be a document under seal.
15. Term of Guaranty This Guaranty shall be effective from the date hereof until the payment in
full of all amounts due under the Loan or any of the Borrower's Agreements.
[Signatures on Next .Page]
Final — Guaranty and Surety ,1greement
Pu €,e 8 of 9
IN WITNESS WHEREOF, the Guarantor, intending to be legally bound hereby, has executed this
Guaranty Agreement, as of the day and year first above written, for the purposes herein stated.
WITNESS:
Ian Anderson
Final — Guaranty and Surety Agreement
PaA,e 9 of 9