Loading...
HomeMy WebLinkAbout04-5958 HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION BY: James T. Shoemaker, Esquire IDENTIFICATION NO. 63871 LAW OFFICES 600 THIRD AVENUE KINGSTON, PA 18704 (570) 287-3000 ATTORNEY FOR PLAINTIFF MELLON BANK, N.A., now by assignment CITIZENS BANK OF PENNSYL VANIA 8 West Market S 1. Wilkes-Barre, PA 18701, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. CIVIL ACTION -- LAW REPLEVIN SANG HO KW AK, Individually and d/b/a Young's Food Market, and YONHWAKWAK: 2208 Chatham Way Harrisburg, PA 17110, Defendants NO.OY --~5f LLU'll~~ 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 637973.1 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 ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THA T MAY OFFER LEGAL SERVICES TO ELIGmLE PERSONS AT A REDUCED FEE OR NO FEE. COURT ADMINISTRATOR Cumberland County Court House Carlisle, PA 17013 (717) 249-1133 -or- PENNSYLVANIA LAWYERS REFERRAL SERVICE P.O. Box 1086, 100 South Street Harrisburg, P A 17108 (pennsylvania residents phone: 1-800-692-7375; out-of-state residents phone: 1-717-238-6715) HOURIGAN, KLUGER & QUINN, P.C. BY: "- James T. Shoemaker, Esquire Counsel for the plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania 637973.1 HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION ALLAN M. KLUGER RICHARD M. GOLDBERG JOSE PH A. LACH RONALD V. SANTORA JOSEPH E. KLUGER JAMES T. SHOEMAKER MICHAEL J. KOWALSKI RICHARD M. WILLIAMS JENNIFER L. ROGERS L1TTzr' JOSEPH A. QUINN. JR ARTHUR L. PICCONE RICHARD S. BISHOP DANIEL J. DISTASIO DONALD C. L1GORIO MICHELLE M. OUINN DAVID AIKENS. JR. AMANDA V. WRIGHT-KLUGER MICHAEL A LOMBARDO III LAW OFFICES SUITE TWO HUNDRED 434 LACKAWANNA AVENUE SCRANTON. PA t 8503-20 14 (570) 346.84 t 4 FACSIMILE (570) 961-5072 600 THIRD AVENUE KINGSTON, PA 18704-5815 (570) 287-3000 FACSI MILE (570) 287-8005 E-MAIL: hkq@hkqpc.com OF COUNSEL ROBERT C CORDARO ANDREW HOURIGAN, JR 1948~'978 Ext. 1126 Direct e-mail: ishoemaker(Q)hkQPC.com 'ALSO MEMBER NJ BAR November 23, 2004 Sang Ho K wak, Individually and d/b/a Young's Food Market 2208 Chatham Way Harrisburg, P A 17110 Property Address: Account No.: Young's Food Market, RD 3 Box 672 Newville, PA 17241 0805386-0101 IMPORTANT NOTICE THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. UNLESS YOU, WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS NOTICE, DISPUTE THE VALIDITY OF THE DEBT, IT WILL BE ASSUMED TO BE VALID. IF YOU NOTIFY THIS OFFICE IN WRITING WITHIN THIRTY (30) DAYS THAT THIS DEBT, OR ANY PORTION THEREOF IS DISPUTED, WE WILL OBTAIN AND FORWARD TO YOU A VERIFICATION OF THE DEBT OR THE JUDGMENT AGAINST YOU. WE WILL ALSO PROVIDE, UPON WRITTEN REQUEST WITHIN THIRTY (30) DAYS OF THE DATE OF THIS NOTICE, THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR. - V~truly yours, .' - . "--'-~ "--!~es T. Shoemaker, Esquire ITS :je THIS NOTICE DOES NOT SUPERCEDE YOUR OBLIGATIONS UNDER THE FOREGOING NOTICE TO PLEAD 638028.2 HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION BY: James T. Shoemaker, Esquire IDENTIFICATION NO. 63871 LAW OFFICES 600 THIRD AVENUE KINGSTON, PA 18704 (570) 287-3000 MELLON BANK, N.A., now by assignment CITIZENS BANK OF PENNSYLVANIA 8 West Market St. Wilkes-Barre, PA 18701, ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. CNILACTION --LAW REPLEVIN SANG HO KW AK, Individually and d/b/a Young's Food Market, and YON HWA KWAK: 2208 Chatham Way Harrisburg, PA 17110, Defendants NO. Oy - S9SR c~U\ tTUJ; COMPLAINT The plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania (the "Bank"), by and through its counsel, Hourigan, Kluger & Quinn, P.c., complains of the defendant, Sang Ho Kwak, Individually and d/b/a Young's Food Market ("Mr. Kwak"), R.D. 3, Box 672, Newville, PA 17241, as follows: 638018] 1. The Bank is a Pennsylvania state chartered bank conducting business in the Commonwealth of Pennsylvania, having an office located at 8 West Market Street, Wilkes-Barre, PA 18711-0101. 2. Mr. Kwak is an adult individual with a last known address of2208 Chatham Way, Harrisburg, P A 17110. 3. Upon information and belief, Yon Hwa Kwak is deceased. 4. On or about May 28, 1999, the Bank made a loan to Mr. Kwak, individually and d/b/a Say-Ford Supermarket and Yon Hwa Kwak (jointly, the "Kwaks"), in the amount of $395,000.00, as evidenced by a note, disclosure and security agreement (the "Note"). (A true and correct copy ofthe Note is attached hereto as Exhibit "A" and incorporated herein by reference.) 5. In order to induce the Bank to make the aforesaid loan, Mr. K wak granted the Bank a security interest in , among other things, his equipment, machinery, motor vehicles, furniture, fixtures, inventory, accounts and contract rights (collectively, the "Collateral"), as evidenced by a security agreement (the "Security Agreement") and as protected by certain UCC-l financial statements (the "UCC-l Financial Statements"). (A true and correct copy of the Security Agreement and the UCC-l Financial Statements is attached hereto as Exhibit "B" and incorporated herein by reference.) 6. The Note was not assigned, except as stated above. 7. Mr. Kwak defaulted under the terms ofthe Note by failing to make monthly payments of principal and interest due under the Note. 638018.1 2 8. The fair market value of the Collateral is unknown, but is believed to be less than the amount due and owing the Bank by the Kwaks under the Note. 9. The Bank believes and therefore avers that Mr. Kwak has possession ofthe Collateral. 10. Mr. Kwak has failed and refused, despite repeated demands by the Bank, to pay the balance due under the Note or to deliver possession of the Collateral to the Bank. 11. The balance of the Note as of October 26,2004 was $320,245.20, consisting of principal in the amount of$311,149.22, accrued interest in the amount of$8,512.74, and late charges in the amount of$583.24, exclusive ofattomeys' fees and costs. WHEREFORE, the Bank demands judgment in replevin in favor of the Bank and against the Kwaks in the amount of $320,245.20, plus interest from October 26,2004, attorneys' fees and costs, and requests this Court to enter an Order directing the Prothonotary to issue a writ of possession to the Sheriff directing the Sheriff to seize the Collateral. Respectfully submitted, HOURIGAN, KLUGER & QUINN, P.C. BY: ~.. S --- James T. Shoemaker, Esquire ill No.: 63871 Counsel for the plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania 600 Third Avenue Kingston, PA 18704 Telephone (570) 287-3000 638018.1 3 P~omi~sorv Note" ,1. , $ 395,000.00 Promise To Pay,. FOR VALUE RECEIVED,aIid intending to be legally bound, Undersigned, as defined below, promises to pay to: Mellon Bank. N.A. ("Bank") or its order at Harrisburg, Pennsylvania the sum of Three Hundred Ninety Five Thousand and 00/100 Dollars ($ 395,000.00 ), ;with interest on the outstanding balance from the date of: this Promissory Note ("Note") at the rate(s) ("Contractual Raters)") and in accordance with the repayment schedule specified belqw. Contractual Rate(s); Repayment Schedules. : o Interest at a rate per annum:which is % above Bank's Prime Rate, such rate to change from time to time as of the effective date of each announcea change in such Prime Rate, shall ~ .paid when principal ~nts are due. Principal shall be paid m consecutive n;lOnthly installments of $ each, commencing bn and continuing thereafter on the i day of each month with the balance of the indebtedness, if n~t sooner paid, due and payable on : , o Interest at a rate per annum which is % above the CD Rate, such rate to change from time to time as of the effective date of each change in or re$etting of the CD Rate sh~lI ~ paid when principal pa~ents ar~ due. Principal shall ~ paid 10 consecutIVe mdnthly installments of $ each, 1 commencing on , and continui~g thereafter on the day of each month wit~ the balance of the indebtedness, if not sooner paid, que and payable on i r o The principal balance he~f, together with all accrued and unpaid interest, shall be 'paid on d . " an mterest at a rate per annum whiclj1 is % above Bank's Prime Rate, such rate to change from time to time as of the effective date of each announced chaqge in such Prime Rate shall be paid on the day of eachi month commencing o~ . I , I o The principal balance hr' f, together with all .accrued and unpaid interest, shall be pai on , and interest at a rate per annum which . % above the CD Rate, such rate to change from me to time as of the effectiye date of each change in or resetti~ of the CD Rate, shall be paId on the day of each ronth commencing on ! o In no event shall the rate charged ,'on this Note exceed . % per annum. I o The principal balance hereof, together with all a~ed and unpaid interest, shall be paid on , and mterest at the rate of % per annum shall be paid on the day of each month commencing on ...... y.~' I' fXJ '- -S" F) Interest shall be ca1cu*ed at the rate of ~ , c;o % per annum. Principal and~terest shall be paid in 1 7 q consecutive monthly installments of S ',92'.65 -'r'oo 'j~~ . . "~L; .' II .' , . ~ ~., Mellon Bank Date '::"'- /A/97 07/01/1999 , and continuing thereafter on the 1ST day of each month with the balance of the indebtedness if not soo~er paid, due and payable on 06/01/2014. During any penod that the ~ntractual Rate(s) is reduced by 0.25% per annum, as descnbed elsewhere in this Note installments of princrl and interest shall instead be in 'the amount of $ ,864.70 each. If the reduction in the Contractual Rate(s) is no longer in effect, the amount of installments of principal and interest shall return to and be the same as the amount of such installments prior to the reduction in the Contractual Rate(s). Un.dersigned shall pay Bank concurrently with the execution and dehvery hereof, or Undersigned previously has paid Bank, an origination fee of $ 3 I 950. 00 ,to compensate Bank for its underwriting, origination and administration of the loan evidenced by this Note. This fee shall be deemed fully earned by Bank on the date hereof, shall not be refunded, and is in addition to any other fees, costs or expenses which may be due and payable hereunder. , Unless Undersigned has authorized Bank to take payments out of a Mellon Olecldng Account, as set forth below Undersigned will mail or deliver to Bank the amount billed by Bank each month. Undersigned will mail or deliver the payments so that Bank receives all payments no later than the due date shown on each bill. o Undersigned authorizes Bank to take all payments of principal and/or interest and/or other amounts due under this Note out of Undersigned's Mellon O1eclting Account Number , titled in the name(s) of , on or after the day of each month. Undersigned will keep a sufficient balance in this account to cover the full amounts of all required payments. At. its option, Bank may terminate Undersigned's ability to use this service. This authorization shall remain in effect until revoked by Undersigned in writing or until the loan evidenced by this Note is paid in full or until Bank has termin~ted Undersigned's ability to use this service, as the case may be. Pnor to maturity, while this authorization is in effect and provided that Undersigned keeps a sufficient balance in this account to cover the full amounts of all required payments, the Contractual Rate(s) shall be reduced by 0;25% per annum. This authorization will be effective even though this Note and the account may be titled in different versions of Undersigned's name. If the original principal amount of this Note is in excess of $10,000.00, or if U~dersigned is a corporation, interest shall be calcul~t~ on ~he. basis of a 360-day year and actual'days elapsed. If the anginal pnnClpal amount of this Note is $10,000.00, or less, and Undersigned is not a corporation, interest shall be calculated on the basis of a 365-day year or 366-day year, as the case may be, and actual days elapsed. "Prime Rate" shall mean the interest rate per annum announced from time to time by Bank as its Prime Rate. The Prime Rate may be greater or less than other interest rates charged by Bank to ?ther borrowers. and is not solely based or dependent upon the Interest rate which Bank may charge any particular borrower or class of borrowers. If a single certificate of deposit is held by Bank as collateral security for the indebtedness evidenced by this Note, as more fully described in the Assignment of Deposit Account expressly referring to this Note, "CD Rate" shall mean.. the interest rate paid by Bank on such certificate of deposit (the "ditificate"), said CD Rate to be .' , ( Page 1 of 5 .;~I, , .-If reset by Bank at each renewal of the Cetuticate. If more than one certificate of deposit is held by Bank as collateral security for the indebtedness evidenced by this Note, as more fully described in the Assignment(s) of Deposit Account expressly referring to this Note, "CD Rate" shall mean the highest of the interest rates paid by Bank on such certificates of deposit (the "Certificates"), said CD Rate to be reset at each renewal of each Certificate. Late Charge. If any payment (including without limitation any regularly scheduled payment, balloon payment or final payment) is not paid within 15 calendar days after it is due, Undersigned will pay a late charge of the greater of $25.00, or three percent (3%) of the unpaid portion of the scheduled payment due (regardless of whether the payment due consists of principal and interest, principal only or interest only). Such late charge shall be in addition to any increase made to the Contractual Rate(s) applicable to the outstanding balance hereof as a result of maturity of this Note or otherwise, as well as in addition to any other applicable fees, charges and costs. Default Rate(s); Post-Maturity Rate(s). Upon the occurrence of any Event of Default (as defined in this Note), at Bank's option, interest shall accrue at a rate equal to two percent (2%) per annum above the Contractual Rate(s) until the earlier of the date that such Event of Default has been cured or until and including the date of maturity hereof. After maturity, whether by acceleration or otherwise, interest shall accrue at a rate equal to two percent (2%) per annum above the Contractual Rate(s) until all sums due hereunder are paid. Interest shall continue to accrue after the entry of judgment (by confession or otherwise) at the Contractual Rate(s) until all sums due hereunder and/or under the judgment are paid, except that after maturity or, at Bank's option, upon the occurrence of any Event of Default, interest shall accrue at a rate equal to two percent (2%) per annum above the Contractual Rate(s). Books and Records; TIme of Essence. So long as Bank is the holder hereof, Bank's books and records shall be presumed, except in the case of manifest error, to accurately evidence at all times all amounts outstanding under this Note and the date and amount of each advance and payment made pursuant hereto. The prompt and faithful performance of all of Undersigned's obligations hereunder, including without limitation time of payment, is of the essence of this Note. _ Security Interest, Setoff and Assignments. To secure all amounts at any time owing or payable under this Note and Undersigned's obligations hereunder, as well as to secure all costs and expenses incurred by Bank in the collection or enforcement of this Note or the - protection of any collateral securing this Note (including without limitation all advances made by Bank: for taxes, levies, insurance, filing fees, and repairs to or maintenance of said collateral), Undersigned hereby grants to Bank a security interest in, lien upon, and right of setoff against, all deposit accounts, credits, securities, moneys, or other property of Undersigned which may at any time be in the possession of, delivered to, or owed by Ban~ including any proceeds or returned or unearned premiums of insurance, and the proceeds of all the foregoing property. Other property, real or personal, may secure this Note, as set forth in other documents and agreements. Undersigned aclcnowIedges and agrees that Undersigned shall renew, or cause to be renewed, the Certificate(s), if any, until the indebtedness evidenced by this Note has been paid in full. Undersigned further agrees tbat Undersigned will execute, or will cause to be executed, upon demand by Bank any financing statements or other documents, induding, without limitation, additional Assignments of Deposit Account, wbicb Bank: may deem necessary or desirable to evidence, perfect or maintain perfection of the security interests created in the Certificate(s) and any renewals, replacements and substitutions thereof. ,< I Additional Tenus and Conditions 1. Covenants. Undersigned covenants and agrees that until all indebtedness evidenced hereby has been paid in full, Undersigned shall: (a) maintain at all times a positive tangible net worth; (b) (1) have all Environmental Permits necessary for the conduct of each of Undersigned's businesses and operations, (2) conduct each of Undersigned's businesses and operations in material compliance with all applicable Environmental Laws and Environmental Permits, (3) not permit to exist any event or condition that requires or is likely to require Undersigned under any Environmental Law to pay or expend funds by way of fines, judgments, damages, cleanup, remediation or the like in an aggregate amount, the payment of which could reasonably be expected to interfere substantially with normal operations of Undersigned or materially adversely affect the financial condition of Undersigned, (4) notify Bank promptly upon becoming aware of any pending or tbreatened proceeding, suit, investigation, allegation or inquiry regarding any alleged event or condition that, if resolved unfavorably to Undersigned or any of Undersigned's subsidiaries or affiliates, is likely to cause Undersigned or any of its subsidiaries or affiliates under any Environmental Law to pay or expend funds by way of fines, judgments, damages, cleaning, remediation or the like, and (5) provide at Undersigned's cost, upon request by Bank, certifications, documentation, copies of pleadings and other information regarding the above, all in form and content satisfactory to Bank; (c) conduct each of Undersigned's businesses and operations in material compliance with all federal, state or local laws, statutes, regulations, rules, ordinances, court or administrative orders or decrees, or private agreements or interpretations, now or hereafter in existence, directly or indirectly relating to or affecting Undersigned's businesses or operations; (d) use the proceeds of the loan evidenced hereby only for business purpose(s) specified to Bank at or prior to the execution hereof; (e) promptly notify Bank in writing of any change in Undersigned's residence or Chief Executive Office; (f) purchase and maintain policies of insurance (including flood insurance) to protect against such risks and casualties, and in such amounts, as shall be required by Bank: and/or applicable law, wbich policies shall (1) be in form and substance satisfactory to Ban~ (2) at Bank's option, designate Bank as loss payee and/or as additional insured, and/or contain a lender's loss payable endorsement, and (3) be (or certificates evidencing same shall be) deposited with Bank; (g) (1) maintain and keep proper records and books of account in conformance with generally accepted accounting principles applied on a consistent basis in which full, true and correct entries shall be made of all Undersigned's dealings and business affairs, (2) provide to Bank at Undersigned's cost, upon Bank's request, financial or other information, documentation or certifications (including without limitation annual and periodic balance sheets and income statements, personal financial statements, federal income tax returns, inventory reports (including a description of raw materials, finished goods, and the aging thereof, as applicable), and accounts receivable and payable aging reports), all in form and content satisfactory to Ban~ and (3) permit, upon request by Bank:, any of the officers, employees or representatives of Bank to visit and inspect any of Undersigned's properties and locations and to examine its books and records and discuss the affairs, finances and accounts of Undersigned with representatives thereof, as often as Bank may request; (h) provide additional collateral at such times and having such value as Bank may request, if Bank shall bave reasonable grounds for believing that the value of the collateral securing the indebtedness evidenced by this Note has become iosufficient to secure said indebtedness; (i) pay, upon demand by Ban~ (1) all costs and fees pertaining to the filing of any financing, continuation or termination statements, mortgages, satisfaction pieces, judgments and any other type of document which Bank deems necessary or desirable to be filed with regard to security interests which secure the indebtedness evidenced bereby, regardless of whether such secl,f.1nty interests were granted by Undersigned, and (2) all costs and expeqses incurred by Bank in Page 20f5 , ')i,' 'cvnnection with any collateral securing this Note (including without limitation all advances made by Bank for taxes, levies, insurance, repairs to or maintenance of said collateral, appraisal or valuation of said collateral, and determination of flood hazard), regardless of whether such collateral is owned by Undersigned; and (j) pay, upon demand by Bank, all amounts incurred by Bank in connection with any action or proceeding taken or commenced by Bank to enforce or collect this Note, including attorney's fees equal to the lesser of (1) 20% of the outstanding principal balance and interest then due hereunder or $500.00, whichever is greater, or (2) the maximum amount permitted by law, plus attorney's costs and all costs of legal proceedings. 2. Events of Default. The occurrence of any of the following shall constitute an "Event of Default" hereunder: (a) default in payment or performance of any of the indebtedness or obligations evidenced by this Note or any other evidence of liability of Undersigned to Bank; (b) the breach by any Obligor (defined as Undersigned and each surety or guarantor of any of Undersigned's liabilities to Bank as well as any person or entity granting Bank a security interest in property to secure any indebtedness) of any covenant contained in this Note or in any separate security, guarantee or suretyship agreement between Bank and any Obligor, the occurrence of any default hereunder or under the terms of any such agreement, or the discovery by Bank of any false or misleading -representation made by any Obligor herein or in any such agreement or in any other information submitted to Bank by any Obligor; (c) with respect to any Obligor: (1) death or incapacity of any individual or general partner, or (2) dissolution of any partnership or corporation; (d) any assignment for the benefit of creditors by any Obligor; (e) insolvency of any Obligor; (f) the filing or commencement of any petition, action, case or proceeding, voluntary or involuntary, under any state or federal law regarding bankruptcy, insolvency, reorganization, receivership or dissolution, including the Bankruptcy Reform Act of 1978, as amended, by or against any Obligor; (g) default under the terms of any lease of or mortgage on the premises where real or personal property securing the indebtedness evidenced by this Note is located; (h) the garnishment, tax assessment, attachment or taking by governmental authority or other creditor of any property of any Obligor which is in Bank's possession or which constitutes security for any indebtedness evidenced hereby; (i) entry of judgment against any Obligor in any court of record; (j) the assessment against any Obligor by the 'Internal Revenue Service or any other federal, state or local taxing authority of unpaid taxes, or the issuance of a levy or the entering of a lien in connection therewith; (Ie) change in control of or transfer of any interest in any Obligor - (other than an Obligor who is an individual); (I) a determination by Bank, which determination shall be conclusive if made in good faith, that a material adverse change has occurred in the financial - or business condition of any Obligor; (m) the maturity of any life insurance policy held as collateral for the indebtedness evidenced by this Note by reason of the death of the insured or otherwise; or (n) default by Undersigned in the payment of any indebtedness of Undersigned or in the performance of any of Undersigned's obligations (other than indebtedness or obligations evidenced by this Note or any other evidence of liability of Undersigned to Bank) and such default shall continue for more than any applicable grace period. 3. Acceleration: Remedies. Upon the occurrence of any Event of Default: (a) all amounts due under this Note, including the unpaid balance of principal and interest hereof, shall become immediately due and payable at the option of Bank, without any demand or notice whatsoever; and (b) Bank may immediately and without demand exercise any of its rights and remedies granted herein, under applicable law, or which it may otherwise have, against Undersigned or otherwise. Notwithstanding any provision to the contrary contained herein, upon the occurrence of an Event of Default as described in Section 2(f) hereof, aU amounts due under this Note, including w....Jut limitation the unpaid balance of principal and interest hereof, shall become Immediately due and payable, without any demand, notice or further action by Bank whatsoever, and an action therefor shall immediately accrue. 4. Bank's Rights. Undersigned hereby authorizes Bank, and Bank shall have the continuing right, at its sole option and discretion, to: (a) do anything which Undersigned is required but fails to do, and in particular Bank may, if Undersigned fails to do so, obtain and pay any premiums payable on any policy of insurance required to be obtained or maintained hereunder; (b) direct any insurer to make payment of any insurance proceeds, including any returned or unearned premiums, directly to Bank, and apply such moneys to any indebtedness or other amount evidenced hereby in such order or fashion as Bank may elect; (c) pay the proceeds of the loan evidenced by this Note to any or all of the Undersigned individually or jointly, or to such other person(s) as any of the Undersigned may direct, except to the extent otherwise provided in Section 6 hereof; and (d) add any amounts paid or incurred by Bank under Section l(i), Section 10) or Section 4(a) to the principal amount of the indebtedness evidenced by this Note. 5. Authorization to Borrow. Undersigned hereby represents, warrants, certifies and covenants as follows: (a) If Undersigned is a corporation, that the person(s) signing below hold(s) the office(s) indicated below (and continue to hold such office(s) until Bank has received notice to the contrary in writing from Undersigned), and that the Board of Directors of Undersigned has adopted resolutions providing that: (1) the person(s) executing and delivering this Note on behalf of Undersigned is/are authorized (i) to incur indebtedness and obligations on behalf of Undersigned by borrowing or making other financial arrangements with Bank from time to time, upon terms and conditions as they in their sole discretion deem desirable, (ii) to make, execute and deliver promissory notes, letter of credit agreements, security agreements, assignments, mortgages and all other documents required by Bank in connection with the incurring of indebtedness or obligations, and (m) to assign and pledge as collateral secUrity for any such indebtedness or obligations, now or hereafter existing, any real or personal property of Undersigned; (2) the actions of anyone or more officers of Undersigned in borrowing money from Bank heretofore for the account of Undersigned, in assigning or pledging any of Undersigned's property for the payment thereof, or in doing any other act in connection therewith are hereby ratified, confirmed and approved; and (3) said resolutions shall have the force of a continuing agreement with Bank, and shall be binding upon Undersigned until a resolution amending them shall have been duly and legally adopted and Bank furnished a certified copy thereof. (b) If Undersigned is a partnership, that (1) Undersigned's name shown below is a trade name of Undersigned's firm used in the conduct of an unincorporated business owned entirely by the persons signing this Note on behalf of said partnership; (2) the partners executing and delivering this Note are authorized (i) to incur indebtedness and obligations on behalf of Undersigned by borrowing from or making other financing or credit accommodations with Bank from time to time, upon such terms and conditions as they in their sole discretion deem desirable, (ii) to make, execute, and deliver promissory notes, letter of credit agreements, security agreements, assignments, mortgages and all other documents required by Bank in connection with the incurring of indebtedness or obligations, and (iii) to assign and pledge as collateral security for any such indebtedness or obligationS:"oaw or hereafter existing, any real or personal property of Undersigned; (3) the actions of anyone or more partners of Undersigned in borrowing money from Bank heretofore for the account of Undersigned, in assigning or pledging any of Undersigned's property for the payment thereof, or in doing any other act in connection therewith..are hereby ratified, confirmed, and approved; (4) notwithstanding any Ynodification or terminatiOn of the Page 3 of5 '"" ~ .:\" . power of any of the partners to represe~~id firm, whether by expiration of the partnership agreement, by death or retirement of any partner, or the accession of one or more new partners, or otherwise, and notwithstanding any other notice thereof Bank may receive, this authority shall continue to be binding upon each of the Undersigned individually and upon their legal representatives, and upon Undersigned and its successors, until Bank has received notice in writing to the contrary signed by one of the Undersigned or by Undersigned's duly authorized agent (Receipt of such notice will not relieve any partner of any liability arising from obligations incurred prior to Bank's receipt of such notice.), and (5) nothing herein shall be construed to limit the rights granted to a partner by law or by the partnership agreement, but all rights granted herein shall be in addition to such rights. 6. Definitions; Miscellaneous Provisions. (a) Undersigned waives (except where requested hereby) notice of action taken by Bank; and hereby ratifies and confirms whatever Bank may do. Bank shall be entitled to exercise any right notwithstanding any prior exercise, failure to exercise or delay in exercising any such right. (b) Bank shall retain the lien of any judgment entered on account of the indebtedness evidenced hereby. Undersigned warrants that Undersigned has no defense whatsoever to any action or proceeding that may be brought to enforce or realize on any such judgment. (c) If any provision hereof shall for any reason be held invalid or unenforceable, no other provision shall be affected thereby, and this Note shall be construed as if tbe invalid or unenforceable provision had never been a part of it. The descriptive headings of this Note are for convenience only and shall not in any way affect the meaning or construction of any provision hereof. (d) The rights and privileges of Bank contained in this Note shall inure to the benefit of its successors and assigns, and the duties of Undersigned shall bind all heirs, personal representatives, successors and assigns. (e) This Note shall in all respects be governed by the laws of the state in which this Note is payable (except to the extent that federal law governs). (f) Undersigned hereby irrevocably appoints Bank and each holder hereof as Undersigned's attorney-in-fact to endorse Undersigned's name to any draft or check which may be payable to Undersigned in order to collect the proceeds of any insurance or any returned or unearned premiums in respect of any policies of insurance required to be maintained hereunder. Undersigned hereby acknowledges that this appointment of Bank and each holder hereof as attorney-in-fact is irrevocable and is coupled with an interest. (g) Undersigned assigns to Bank all moneys which may become payable on any policy of insurance required to be maintained under this Note, including any returned or unearned premiums. (h) "Environmental Law" means any _ federal, state or local environmental law, statute, regulation, rule, ordinance, court or administrative order or decree, or private agreement or interpretation, now or hereafter in existence, relating to the manufacture, distribution, labeling, use, handling, collection, storage, treatment, disposal or otherwise of Hazardous Substances, or in any way relating to pollution or protection of the environment or public health. (i) "Environmental Permit" means any federal, state or local permit, license or authorization issued under or in connection with any Environmental Law. (j) #'. .. "Hazardous Substances" means petIdeum and petroleum products, radioactive materials, asbestos, radon, lead containing materials, sewage or any materials or substances defined as or included in the definition of "hazardous wastes," "hazardous substances," "hazardous materials," "toxic substances," "hazardous air pollutants," "toxic pollutants," "pollution," or terms of similar meaning, as those terms are used in any Environmental Law. (k) "Chief Executive Office" means the place from which the main part of the business operations of an entity is managed. (I) "Undersigned" refers individually and collectively to all makers of this Note, including, in the case of any partnership, all general partners of such partnership individually and collectively, whether or not such partners sign below. Undersigned shaD each be jointly and severally bound by the terms hereof, and, with respect to any partnership executing this Note, each general partner shall be bound hereby both in such general partner's individual and partnership capacities. 7. Diroction to Pay Proceeds.Undersigned hereby authorizes and directs Bank to pay the proceeds ofthis Note by: . '7 tJ crediting Account Number 000- f.;'l1 ~ 1 if c..fl, .tl (p /, z. 6 I i ~in~~~~ / / 5flNb liD ~ DN l+wlt- K ~ rt'f\. in the amount of$ I . " ./ '" . I n m R :il' 52 q 0/' ~i.lft.fJn'1llJ t I/O llIpaying (no (1)" IOJ-fJ7~- J"2 &C;S- - j'\ A It\,} r. :#-3 I! 3Q 5..3~ i1/qq (P2.. q 2'-' J the amount of$ Rpaying /;CNLi/Cf)L! '!1;/J9tj. ~'/ the amount of $ 8. Affidavit of Business Loan. (This Affidavit is not applicable if Undersigned is a corporation.) Undersigned, being duly authorized, depose(s) and say(s) under penalty of perjury that Undersigned: (a) Is/Are engaged in business aslXl Owner(s), 0 General Partner(s) of: (name and nature of business) YOUNG' i FOOD MARKET AND . SAY-F~ SUPERMARKET i (_ 1''- FOOD MARKET (b) Hereby make(s) application to Bank for a loan, the proceeds of which will be utilized for the purpose(s) of REFINANCE MELLON DEBT. OTHER DEBT CONSOLIDATION & EQUIPMENT & INVOICE PURCHASE (c) Exercise(s) actual control over the managerial decisions of the business. (Remainder of page intentionally left blank) .) Page40f5 '.)," -9. Confession of Judgment. UNDERSIGNED HEREBY EMPOWERS TIlE PROTIlONOTARY OR ANY ATTORNEY OF ANY COURT OF RECORD TO APPEAR FOR UNDERSIGNED AND TO CONFESS JUDGMENT AS OFfEN AS NECESSARY AGAINST UNDERSIGNED IN FAVOR OF TIlE HOLDER HEREOF, REGARDLESS OF WI-IETIlER ANY EVENT OF DEFAULT HAS OCCURRED, AT ANY TIME AND AS OF ANY TERM, FOR TIlE OUTSTANDING PRINCIPAL BALANCE HEREOF PLUS INTEREST DUE UNDER TIlE TERMS HEREOF AND ALL OTIlER AMOUNTS DUE HEREUNDER, TOGETIlER WI1lI COSTS OF LEGAL PROCEEDINGS AND AN ATTORNEY'S COMMISSION EQUAL TO TIlE LESSER OF (A) 20% OF TIlE OUTSTANDING PRINCIPAL BAlANCE AND INTEREST TIlEN DUE HEREUNDER OR $500.00, WHICHEVER IS GREATER, OR (B) TIlE MAXIMUM AMOUNT PERMITIED BY LAW, WITH RELEASE OF ALL ERRORS. UNDERSIGNED WAIVES ALL LAWS EXEMPTING REAL OR PERSONAL PROPERTY FROM EXECUTION. By signing this Note, Undersigned agrees to all terms of the Note and swears, under penalty of perjury (as set forth in 18 Pa.C.S. ~904, If governed by Pennsylvania law), to the Amdavlt of Business Loan (if completed) set forth in Section 8 of this Note. Signatures Witness the due execution hereof under seal. x Witness: x Mellon Bank, N.A Mellon Bank (DE) National Association CUS43 Rev.(lWJ6) LC. 9196 ill 9196 OZT5 p 166~-3823 1 cl4S43(01) 052799,1605 . I~-dU(il: ~ <. x )., . I ~G HU KW . , J., UUAL AJ.IlU ~~~/~ U u~~T-,h~fJ ~/FZ~"71,i.J/(,2 7 672 B ERVILLE ROAD . / / NEWVILLE, PA 17241 >~ 7~ Individual: ~U~ t1j ~AK !JUJi(L (L-q ~ (Seal) 672~s~~tILLE ROAD NEWVILLE, PA 17241 ). Page 5 of 5 . .),' - . .. $..curlty.4g~,..ment. '. ..~~,.i'~1ri~'~ '~.%..~~".;~~:...x.., ....b..::,,':J...;~.:.~..y...;,;..-.<...:~....A..~,;:.;..l.'-,~. "" ",: . .....y.>.~;,: '-l(''''': ~~..:'.." ",...~."f,... ."'''').,~'J)1:''"IlJJJ;JjJm)j1j'''~3mIJ',.i!IlRIf~r~'~~~,?'W)l'Q1~.r.y,'',,:-,.I'..,~..~'VIIL')IIM., .' . 'PT" @ Mellon Bank For value received, and intending to be legally bound, in consideration of a loan or other credit accommodation in the amount of Three Hundred Ninetv Five Thousand and 00/100 Dollars ($ 395,000.00 ) made by Nellon ~ank. N.A. ("Bank") to SANG HO KWAK, INDIVIDUALLY AND D /PJ~UNG' S FOOD ~~RlC1r.~ID SAY- SUPERMARKET 7U YON KWA~ ' ("Borrower(s)"), said obligation evidenced by a PROMISSORt NOTE dated _ S-.. iff)." '1 'I , (the "Note") Undersigned, intending to be legally bound, hereby agrees as follows: 1. Security Interest. Undersigned hereby grants to Bank a security interest in the following property now owned or hereafter acquired by Undersigned: (Certain terms used herein are defined in Section 13 below.) IX! ~.P 'l/6t) all equipment, wherever located, including mac~tfrr, mbtorvehicles, furniture and fixtures; /,/y IX] C' ~ fb}1i11 inventory (whether held for sale or lease or to be iu(nisJ?ed under contracts of service), raw materials, work in process, and materials used or consumed in the conduct of Undersigned's business, and all books, records, invoices or other documents which describe or evidence the same; IX! <'"'~ Y&fall accounts, contract rights, general intangibles, chart~r, chases in action, instruments, documents (including all documents of title and warehouse receipts) and all rights to the payment of money, however evidenced or arising; o (d) all securities; all cash, stock or other dividends or distributions paid upon or made in respect of such securities in any form; all securities received in addition to or in exchange for such securities; and all subscription rights incident to such securities; o (e) all farm products; and o (f) all property or rights described below under the caption "Description of Collateral." Description of Collateral (Give a sufficiently detailed description to identify each item). .....'.,','.. ..:'".: ',..V' . In addition to the foregoing, Undersigned: (1) grants to Bank a security interest in all accessions, parts, accessories, attachments and appurtenances in any way used with, attached or related to, or installed in, or intended to be so used, attached, related to or installed in, any equipment or inventory constituting "Collateral" hereunder; (2) grants to Bank a security interest in all substitutions for, renewals of, improvements, replacements and additions to, and the products and proceeds (cash and non-cash) of all of the foregoing property and any insurance policies relating thereto; (3) grants to Bank a security interest in, lien upon, and right of setoff against, all deposit accounts, credits, securities, moneys or other property of Undersigned which may at any time be in the possession of, delivered to or owed by Bank, including any proceeds or returned or unearned premiums of insurance, and the proceeds (cash and non~h) of all the foregoing property; and (4) assigns to Bank all moneys which may become payable on any policy of insurance required to be maintained under this Agreement, including any returned or unearned premiums. All such property subject to Bank's security interests described in this Section 1 is referred to herein collectively as the "Collateral." With respect to Section 4 hereunder, the term "Collateral" shall not include the property described in Subsection (3) of this Section 1. AIl security interests in Collateral shall be deemed to arise and be perfected under and governed by the Uniform Commercial Code, except to the extent that such law does not apply to certain types of transactions or Collateral, in which case applicable law shall govern. 2. Obligations Secured. The Collateral shall secure the following obligations ("Obligation(s)"): (a) all amounts at any time owing or payable under the Note, and any other indebtedness, liability or obligation of Borrower(s) or of Undersigned to Bank, now existing or Page 10f4 hereafter incurred, whether direct or indirect, absolute or contingent, individual, joint or several, now due or to become due, and whether owed as drawer, maker, endorser, guarantor, surety or othelWise; (b) all costs and expenses incurred by Bank in the collection of the same; and (c) all future advances made by Bank for taxes, levies, insurance, and repairs to or maintenance of the Collateral. Provided, however, the interests assigned hereby shall not secure any obligation (other than the Obligation evidenced by the Note) which is defined as "consumer credit" by Federal Reserve Board Regulation Z, 12 C.F.R. f 226.1 et 1Cq., and is not exempted from the application of that Regulation. 3. Representations. Undersigned hereby makes the following representations and warranties which shall be true and correct on the date of this Agreement and shall continue to be true and correct at the time of the creation of any Obligation secured hereby ~ until the Obligations secured hereby shall have been paid in full: (a) Undersigned's residence and/or Chief Executive Office, as the case may be, is as stated below or as otherwise stated in a subsequent written notice delivered to Bank pursuant to the terms hereof; (b) Undersigned has good and marketable title to the Collateral subject to no security interest, lien or encumbrance, except as indicated to the contrary to Bank in writing prior to the execution of this Agreement; and (c) if any of the Undersigned is an individual, each such individual is at least 18 years of age and under no legal disability or incapacity. 4. Covenants. Undersigned covenants and agrees that until the Obligations secured hereby have been paid in full Undersigned shall: (a) not permit the use of the Collateral for any illegal purposes; (b) promptly notify Bank in writing of any change in its or their residence or Chief Executive Office; (c) not permit removal of any of the Collateral from county to county or state to state unless Bank has given written consent in advance; (d) maintain at all times good and marketable title to all Collateral, free and clear of any security interest, lien or encumbrance (except as to which Bank may grant its prior written consent pursuant to Section 4 (e) below), and defend such title against the claims and demands of all persons; (e) not (1) affix the Collateral or permit the Collateral to be affixed to real estate or to any other goods, (2) lease, mortgage, pledge or encumber the Collateral, (3) permit the Collateral's identity to be lost (4) permit the Collateral to be levied upon or attached under any legal process, (5) permit or cause any security interest or lien to arise with respect to the Collateral (other than thCl')C created in this Agreement), or (6) except Collateral customarily sold by Undersigned in the ordinary coune of business and so sold in such manner for full value, sell, consign, part with possession of, or otherwise dispose of the Collateral or any rights therein, except as Bank may grant its prior specific written consent with respect to acts or events specified in Subsections (1), (2), (5) or (6) hereof; (f) maintain the Collateral in good condition and repair, excepting only reasonable wear and tear; pay and discharge all taxes and other levies on the Collateral. As well as the costs of repair and maintenance thereof; and furnish to Bank upon request documental}' proof of payment of such taxes, levies and costs; (g) purchase and maintain policies of insurance (including flood insurance) to protect the Collateral or other property against such risks and casualties, and in such amounts, as shall be required by Bank anellor applicable law, which policies shall (1) be in form and substance satisfactory to Bank, (2) at Bank's option, designate Bank as loss payee and/or as additional insured, and/or contain a lender's loss payable endorsement, and (3) be (or certificates evidencing same shall be) deposited with Bank; (h) execute, upon demand by Bank, any financing statements or other documents which Bank may deem necessary to perfect or maintain perfection of the security interest(s) created in this Agreement and pay, upon demand by Bank, (1) all casts and fees pertaining to the filing of any financing, continuation or termination statements, mortgages, satisfaction pieces, judgments and any other type of document which Bank deems necessary or desirable to be filed with regard to the Collateral, and (2) all costs and expenses incurred by Bank in .; .,.,.-- connection with the Collateral (including without limitation a)} advances made by Bank for taxes, levies, insurance, repairs to or maintenance of the Collateral, appraisal or valuation of said collateral, and determination and monitoring of flood hazard status); (i) procure, and cause a statement of Bank's security interest to be noted on, any certificate of title issued or required by law to be issued with respect to any motor vehicle constituting part of the Collateral, and cause any such certificate to be delivered to Bank within 10 days from the later of the date of this Agreement or the date of the issuance of such certificate; 0) pay, upon demand by Bank, all amounts incurred by Bank in connection with any action or proceeding taken or commenced by Bank to enforce this Agreement or protect, insure or realize upon the Collateral, including attorney's fees equal to the lesser of (a) 20% of the amount of the Obligations secured hereby then due or $500.00, whichever is greater, or (b) the maximum amount permitted by law, and attorney's costS and all costs of legal proceedings; (k) reimburse Bank on demand for any advances made by it for payment of (1) premiums to insure the Collateral, or (2) taxes, levies or casts, together with interest thereon at the highest rate allowed by law; and (I) immediately notify Bank if any of Undersigned's accounts arise out of contracts with the United States or any department, agency or instrumentality thereof, and execute any instruments and take any steps required by Bank in order that all moneys due and to become due under any such contracts shall be assigned to Bank and notice thereof given to the United States under the Federal Assignment of Claims Act. s. Events of Default. The occurrence of any of the following shall constitute an "Event of Default" hereunder: (a) default (i) in the performance of any covenant hereunder or (ii) under any other instrument or document evidencing or securing the Obligations; (b) any warranty, representation or statement made or furnished to Bank by or on behalf of the Undersigned proving to have been false in any material respect when made or furnished; (c) loss, theft, substantial damage, destruction, sale or encumbrance to or of any of the Collateral, or the making of any levy, seizure or attachment thereof or thereon; or (d) death, dissolution, termination of existence, insolvency or business failure of the Undersigned, appointment of a receiver for Undersigned or any part of the Collateral, assignment for the benefit of creditors or the commencement of any proceeding under any bankruptcy or insolvency law by or against the Undersigned. 6. Remedies of Bank. Upon the occurrence of any Event of Default: (a) Undersigned shall, upon demand by Bank, assemble the Collateral and promptly make it available to Bank at any place designated by Bank which is reasonably convenient to both parties; (b) Bank may immediately and without demand exercise any of its rights and remedies granted herein, under applicable law, or which it may otherwise have, against the Undersigned, the Collateral, or otherwise; and (c) Bank may, without notice or process of any sort, peaceably enter any premises where any Collateral is located and take possession, retain and dispose of such Collateral and all property located in or upon it. Bank shall have no obligation to return any such property not constituting Collateral unless Bank actually receives Undersigned's written request therefor specifically describing such property within 72 hours after repossession thereof. 7. Bank's Rights. Undersigned hereby authorizes Bank, and Bank shall have the continuing right, at its sole option and discretion, to: (a) do anything which Undersigned is required but fails to do hereunder, and in particular Bank may, if Undersigned fails to do so, (1) insure or take any reasonable steps to protect the Collateral, (2) pay all taxes, levies, expenses and costs arising with respect to the Collateral, or (3) pay any premiums payable on any policy of insurance required to be obtained or maintained hereunder; (b) direct any insurer to make payment of any insurance proceeds, including any returned or unearned premiums, directly to Bank, and apply such moneys to any Obligations evidenced or secured hereby in such order or fashion as Bank may elect; and (c) inspect the Collateral at any reasonable time. P 2 4 age of .. ,. . .. In addition to the rights given to Bank in this Agreement, Bank shall have all the rights and remedies of a secured party under any applicable law, including without limitation, the Uniform Commercial Code. 8. Additional Representations. In addition to the representations and warranties set forth elsewhere in this Agreement, Undersigned hereby makes the following representations and warranties which shall be true and oorrect on the date of this Agreement and shall continue to be true and correct at the time of any borrowing under any line of credit with Bank and until the Obligations secured by this Agreement shall have been paid in full: (a) each account: (1) represents an amount actually owing to Undersigned by the account debtor (less discounts allowed for prompt payment); (2) is valid and enforceable according to Its terms without further performance of any kind; (3) is not evidenced by any instrument or chattel paper unless the original of such instrument or chattel paper has been deposited with Bank; and (4) is not evidenced by any judgment unless such judgment has been assigned of record to Bank; and (b) the locations of all of Undersigned's places of business are as stated below, and the inventory and records of the accounts are kept at the places indicated below. 9. Additional Covenants. In addition to the covenants set forth elsewhere in this Agreement, Undersigned covenants and agrees that until the Obligations secured by this Agreement have been paid in full Undersigned shall: (a) immediately notify Bank in writing in the event that any of the following occurs: (1) any account is or becomes entitled or eligible for discount for prompt payment; (2) any account debtor has or may have any defense to payment of, or right of setoff, counterclaim, or recoupment against any account; (3) any account represents an amount which is disputed by the account debtor or the payment of which is in any way contingent or conditional; or (4) the desirability, usefulness, or marketability of any of the inventory has been in any way reduced or impaired by reason of physical deterioration, technical obsolescence, or otherwise; (b) keep accurate and complete books and records in accordance with generally accepted accounting principles and, at Undersigned's expense, promptly furnish Bank such information and documents relating to the Collateral at such times and in such form and detail as Bank may request, including without limitation: (1) copies of invoices or other evidence of Undersigned's accounts and schedules showing the aging, identification, reconciliation, and collection thereof; (2) evidence of shipment and receipt of goods and the performance of services or obligations covered by accounts; and (3) reports as to Undersigned's inventory and purchases, sales, damage, or loss thereof; all of the foregoing to be certified by authorized officers or other employees of Undersigned; (c) not change any location listed below regarding places of business, inventory and records of accounts without Bank's prior written consent; (d) at Undersigned's expense, diligently collect the accounts on behalf of Bank until such time as Bank exercises its right to directly collect the accounts, and upon notice from Bank, deliver all proceeds of accounts to Bank forthwith upon receipt, in the original form in Which received; (e) immediately upon Bank's request, open a cash collateral account ("Cash Collateral account") at Bank and deposit therein all cash proceeds of collections on the accounts; (f) immediately upon Bank's request, give the Bank assignments, in form acceptable to Bank, of specific accounts or groups of accounts and specific general intangibles, and immediately repay the amount loaned against any account so assigned to the Bank if the contract with the account debtor is breached, cancelled or terminated; (g) immediately upon Bank's request, furnish Bank with all information received by Undersigned regarding the financial condition of any account debtor, except to the extent prohibited by law; (h) immediately deliver to Bank all instruments, documents or chattel paper representing any of the Collateral and immediately assign of record to Bank any judgment representing any account constituting Collateral; and (i) immediately upon Bank's request, mark its records evidencing its accounts in a manner satisfactory to Bank so as to show which accounts have been assigned to Bank. 10. Additional Rights of Bank. In addition to the Bank's rights set forth elsewhere in this Agreement, Undersigned hereby authorizes Bank, and Bank shall have the continuing rights at any time, whether or not any default has occurred under this Agreement, and at its sole option and discretion, without notice, to: (a) take over and collect any or all of the accounts and to take any other action pursuant to its power of attorney granted herein; (b) exercise absolute and exclusive dominion and control over all funds deposited in the Cash Collateral account; apply any funds therein against any Obligations; and charge to any deposit account of Undersigned any Item of payment credited to the Cash Collateral account which is subsequently dishonored; (c) at any reasonable time, through its authorized agents and employees, inspect, audit, and verify the accounts and the inventory, review Undersigned's books and records, and copy or make excerpts from any document; and (d) verify accounts with debtors in the name of Undersigned, Bank, or Bank's designee. 11. Miscellaneous Provisions. (a) Undersigned waives protest of all commercial paper at any time held by Bank on which Undersigned is in any way liable, notice of nonpayment at maturity of any and all accounts, and (except where requested hereby) notice of action taken by Bank; and hereby ratifies and confirms whatever Bank may do. The rights and remedies of Bank hereunder are cumulative. Bank shall be entitled to exercise any right notwithstanding any prior exercise, failure to exercise or delay in exercising any such right. (b) If any provision hereof shall for any reason be held invalid or unenforceable, no other provision shall be affected thereby, and this Agreement shall be construed as if the invalid or unenforceable provision had never been a part of it. The descriptive headings of this Agreement are for convenience only and shall not in any way affect the meaning or construction of any provision hereof. (c) The rights and privileges of Bank contained in this Agreement shall inure to the benefit of its successors and assigns, and the duties of Undersigned shall bind all heirs, personal representatives, successors and assigns. (d) No modification of this Agreement, nor any waiver of any provision hereof, shall be effective or enforceable unless set forth in writing and signed by an officer of Bank. (e) This Agreement shall in all respects be governed by the laws of the state where the Obligations are payable as reflected in the document(s) evidencing such Obligations (except to the extent that federal law governs), and all references to the Uniform Commercial Code shall be deemed to refer to the Uniform Commercial Code as enacted in such state. (f) Undersigned hereby irrevocably appoints Bank and each holder hereof as Undersigned's attorney-in-fact to: (1) endorse Undersigned's name to any draft or check which may be payable to Undersigned in order to collect the proceeds of any insurance or any returned or unearned premiums in respect of any policies of insurance required to be maintained hereunder; and (2) take any action Bank deems necessary to perfect or maintain perfection of any security interest granted to Bank herein, including executing any document on Undersigned's behalf. (g) Undersigned shall bear the risk of loss of, damage to, or destruction of the Collateral, and Undersigned hereby releases Bank from all claims for loss or damage to the Collateral caused by any act or omission on the part of Bank, except for willful misconduct. (h) The prOlhpt and faithful performance of all of Undersigned's Obligations hereunder, including without limitation, time of payment, is of the essence of this Agreement. (i) Copies or reproductions of this document or of any financing statement may be filed as a financing statement. 12. Additional Power of Attorney. In addition to the powers of attorney granted to Bank by Undersigned elsewhere in this Agreement, Undersigned hereby appoints Bank and its officers, Page 3 of 4 employees and agents as its irrevocable, true and lawful attorneys in fact with all necessary power and authority to: (a) endorse Undersigned's name on all media of payment delivered to Bank or deposited in the Cash Collateral account; (b) notify Undersigned's account debtors of the assignment of their debts and direct them to make all payments thereon to Bank; (c) in Bank's name or in the name of Undersigned, demand, sue for, collect, compromise, settle, and give releases from any account; and (d) take such other action as Bank may deem appropriate for any such purpose. In exercising its rights under this section, Bank shall have no liability to Undersigned except for willful misconduct. 13. Definitions. As used herein: (a) "account," "chattel paper," "contract right," "document," "instrument" and "inventory" have the same respective meanings given to those terms in the Uniform Commercial Code; (b) "Chief Executive Office" means the place from which the main part of the business operations of an entity is Signature. Witness the due execution hereof this ".9 t) 7 II '. " managed; (c) "general intangibles" has the meaning given to't1:lf! term in the Uniform Commercial Code, including without limitation, customer lists, books and records (including without limitation, all correspondence, files, tapes, cards, book entries, computer runs, computer programs and other papers and documents, whether in the possession or control of Undersigned or any computer service bureau), rights in franchises and sales contracts, patents, copyrights, trademarks, logos, goodwill, trade names, label designs, royalties, brand names, plans, blueprints, inventions, patterns, trade secrets, licenses, jigs, dies, molds and formulas; and (d) "Undersigned" refers individually and collectively to all makers of this Agreement, including, in the case of any partnership, all general partners of such partnership individually and collectively, whether or not such partners sign below. Undersigned shall each be jointly and severally bound by the terms hereof, and with respect to any partnership executing this Agreement, each general partner shall be bound hereby both in such general partner's individual and partnership capacities. day of /'''//J Y 19$:9 Witness: x Location OrlDveDtory: RP 3 BO~ 6?2 NF.'(lVTT.T.1P., p~ 17'41 LZ-012S Rev.(10196) L.C 9196 LD 9196 0275 P 166-64-3823 1 LZ012S (02) 052799,1605 /~ ?)~fb/a 672 E, PA 17241 Location or records CODcemiDa the aceouDts: RD 3 BOX 672 NF.WVTT.T.F., p~ 17'41 Page 4 of 4 IllI ("""'* 0IIIy Il ~ J'II!lI5\lC11 OCtk 1IIlIalt:nI.... aiaO-- Uoadl:1n1alal.......... if ~bk: .n.,~io,...illduda . (.-cAIIJpID"""'1G(o))- .. . -' .' . o nolcma~IDd"Soo:u_J'ony"_~ ...~..~. ...D ......p:oMaC....IO-_ClIl-.. ...... C I;Idlcorll. ~iuioa. UIDilv. 3 "-III ..........ic:II.......n....... '"""""" ~ ....,.: . SECOJU':DPAaTJSICKATUU(S) c.[J --- ........Iil=("~alI;.;..j.~);.~__ """__ ~ 1Ilal-.1Io -..IY 1Ia5=_hl!ta~ 1\1I .. Cl - ...aJUo.&............ e(...... ."';IIR(lu6MIIo..' u4 tAl)" ~. -ltI1 t.c.w. La....... (~IP(lIiaall. bc;aI('..)) ~ doc....w.CId.,....... OIl - . *~CIIllI_1C ...C:r\.~~.~.r_"Id""'CllIJaIlIIto_ '-'~ :-'~I~ :1"7Xl ' , .. Caa.. IIIaidlIlle 1IlIna-1lIpI& ~... ~ _ llC(cIlaoi:....) 0 D-.:Ia O~ c. ..cc:ady.Glojoool.....-dcyia_.1A _.......,Ia Ol~.) 110I' ct.ocBmAMD' :. ". ~;.:. ~- Coun&r. UalCana_~~.-., :.......;.,,; [J '"""" II>c ClOIIa.IonI_ -..110 .... llDUIl)<. 0 Dc:ocribaf ClIl.AddiaJoo.! S....... o .......~. ...............0. p_.r~__........ ""_.r-.. _ (~0l&Iy II DODcIM<<IlU iillacaaii: OC~ aaIblsGlCla<y. . . "ow';- ~:-. d. akadJan]a:l"'"-..day"~ia -....JutsdIaIaaa- DEllTOIt.SJGl'CA:~a.E(S) . 0_...........1____ 1O~ 0....".. Jloob.....I'-do.__IoP~1:L ~? ~~ 1lWC. . ".-. c.D wlaJQ" ...... ordlca:alWasldlSCZllllSllDNodlP. ". ~('i'aiJ'~~~ . _.:.. . m.n..,.. .....hb.II:aIri.,~-~Q\ISIJ~CaIao4clalldbe ". r l"--'"i11 bIack'.It~~lh_~IlllI_ aoIc1l11101y da<:r\ll<d... aile arlpa.llIII........'-I). 5aE1.W"_~~~~ _ .._.J~~coaI)'lCla{Q1)" Ibo\I*~ IEI.~ (~. sr~l'gD('J'DJllIo(pA.u:c.l ~.:JM) .......... .,s.:,....,.vI.~.a a(1'~ ~2R-42S6) LC.II~[J) 1M lIZ7S B ~1n.l4& 10-20-'04 11:22 FRQM- 1'-"t111t'l Dci.~ ...-o-t- w..iCiAclloIdual) u4 ,..s1"'C.ddras: '. / ~.:~,~:::a:~;:,:1~~~~ 'C-." .~JLL",'A 1~1 ~ _ (laa IIlIlDt am It IlIdMdII.Il) an4 ~ib, addras: -.oN" Ii Fa:ID 1WIa:T ~o 3 IIaX .. c,,"J.... lIe1/11ILLE.... 17241 1101>_ _o-......;c'rolltltindmdual)........iU.t_ ~ r.....(""" ~,) (\;lot "'11I0 Gal i1IDCrMdual)_ ..........""...nIt~I.~l1oa: IIIn... ..... .... _I".,.. '_IN! \..... CctIc.r ~ "el\~ lIIN: '.....r. IIll. is 1'l27V Pit.utaH'OIt. ,.. 152S8'''''01 1 ..-......c..) "'_1'~ -.0(') ONIUlII& l\I'Illt""'~ ..... addraa rat Ittirril)'lIl.......lne.lIIIIlloA. SpodaI 'ID- '" ~ (dlcl:k if .JlfIi...bk): o nc_ "J)cllroI"..... "Sa:ur..s Pant'......"I..<sJ ....~..~. 1 T-442 P05/11 U-170 FINANaNC STIt.TDlar "alto"", OIaIImotdo.l <:.a. E_ vce.t I.,~ ':l J JMl'Olt'IANt -I'l_ nad La.ftrIII:dou ,~ 11 ~1'\II"u111W6l'l!......"leti... I'\lIacNa. (tWllpt.d Dy aUnt oOi=O;:I!t"t: ~ !~ C'-pod by GIia.~ :":.~!::'D~:{ JF DEEOS ;.:::~.1!;:. :t!.AND COUNT!. PA 1a '97 JUH 26 AI'IID 51 .~7l) .. . . J "IlIfI 11DaDI;\lI&1i1D_1 II ~_lIllDt:pumllllC Iou.. l1aitocmCoaaav:tciaI ~ .adl... ..liIed ~ Ce (........ppllc:allk~ o ~aClllc~..... C l'tllllloaot.>lyQC IllI ca1_....... aC ~fBI NID 1b JIl-WorMdllIoIWAoo';' ['!CAm' 0".-- /llodooJ 1dao\lllQ"'1I o.IlIIC.)1) &:lI.Ulew>~: COLt.A.TEftAl. -.&11-'" t., lIal 00IdIWtype; All.. DEIITDII.'S U/iltT, TIUE. """ INTEREST. IIIlfTllEI *'" 11II IEREAfTEIl EXISTING III AtmllltED. III AIlD TO ALL lllYEllTlRf UICUOIIlG 'em_NEll OIl 1f1lQS$E$UlI GCZlD$), utalfiS. IlI'IiN ~S. GENEIlA!. III.NG..LES. llCIt\IIElITS, PlATTU ,.am, INSTllJ\l;NTS, NDTES, aWn. U1TfllSOll CVltfS Of ClEOIT. lIEailv",Ln. mf. AIICUITS CllIINIO TO DOTGI. F1XTU1\U, flJIlNI1I1l& ~o IOllIPWT, ~L NClDIICl'S NIII CASH AND 1IOlI-CA$1\ PlIClC1!COI lINC~1lO1111 INIIJIAIIC! PDlI~res AIIIl .lllC.EtOn DF TIE FllllECOlNG AlII AU. QJAI.l~Tl". CUI"" IJCHT', IlElEOIEI AID '1IVIl.E., IE\JlTl.I Tall'tII. C-Oljr- ea.a..17. , 7. 8 2a 9 10 110 Jlm:URNlU!QlIPl"1'Q: ""lien lent, ....... luslness tI:oill:frcl L.... ~...,... ".0. aos 3IIllD Plccsba.-lIh. .... t$ZJQ'SlIIII At~: CoU.tor.' !MIl 't. ',l r ~"P . i'.....f '. u :_~~. . 'l~ ~''':.. ..~ \ 'J . ..;..: -I' .',u ,-' .~:~ .q i ~, .~,:, : . 12 c.tUGno.s. 00Pr z CUI2 l.WIl -'.... ....."'. " ....,.. '.. 10-20-'04 11:23 FROM- T-44~ PH6/11 U-170 '-. ..~? :. - . - .. ,: t.C:EOS .11r-laEi{lAtln C"U~TY-P4 'az RPR S M 11 lI2 UCC FINANCING STATEMENT AM, ENDMENT /7 ::r:..;~ ~~,....--~? '4/~~ ~ ... ....NE:.._lECI~CCIICt~.TI1l.P~ ~ .. "1"l6~"_lCr: __-.oj tide.. ...... tit '-"11_la :':':!":: =1"1 L... tonur .1 tQCIoII'JIl. ,I. 15ZSr1-3Ilatl .u... CoU,ICf'.\ It-!ll ~..aoveSl'tl.C:El!u:t)Il"".llllG~U$jQlol\." ..._"_rr..__ I~_~~ . . Y\::-...........-tt- '" -"'..... ~.'LQ...: . . ___ ... 4- Cl~ ---....__......_"'___.__..._...._....__ ~ ~_.....---_......_.._..__..._----_. ..._~......~.,.....- '. ... 0-'''',,-- --._Io_...'!-_.__.._"'oM_..._..;...._.L .. .....o.cw.....,.--._ -......:.--o---or-...,._ _.....__ --.....-...--a-__Io_._~ C~------_.._....____ c-- ___ O.ICD_....._'-.~..._ __ -..-..................---,-_......tc. ....._.._..... .....rc__-___..--. I. =-___ .._~- JOifN(. IJIIIl; Ito. OIl .. ~"u.ro_. Yo:nII:O"s rOOD IlAIlb:t' f. ~"'IIIIoC1:1l1_ -;.. ---...... ..1-- t-- f-...- " , 0' 00l ... ~'S...-r_ ,/ .....,.- ......- , -- fc. _-=01 llI)'-3 ,. r.u:Dtlt...~... I. , ~ ,.. r.... B?;. "2 .Jl8tIl(IUE I~=':' Itc.-...- ,,"~aI____ , ,I' I. ------8- --- 0-- 0-......- 0 ---....__ 0......... -,-.o..cz;H n.... ..),1241.. . ..~........ -...... USl 0_ . .......~ ..' fO ,,, .. -.---..-----................-...-. .........:.-.........._- -.........-........~. -t.... ,..,................cw.......... (] _..__.............~~ .. ..........."...,. - . Cl" _ ~~w~ hMI,IWWlh \:::""'"" --'1", ....... c..ic;;r~' I' -".'. '.. " -~"...~~'" 21S - . ~~. ~J: \.:""110 ~,A"',-..&:.~.. L:D..... . ~~ uo:o~C\HG ST&TE.lwIs;MT ~ (pC,... UCQ) ~,~~ ",- . ~,.......... I ""~I'h '~.Ihl '. . o. 01 " ~ Ii .....~ II or. """ '.#':"';<' . !/:' Oct-20-2004 08:32am . . . PA.RTIf:S _. Debu,r name O-St IIJlme lin<11C iI1diWlulll) a.nd mallin, addn:= ." ~l(IJM:,'$ANli HO . " RP 3 BOX ~ ' '1 a.. )IE\oIVILLE, PA 1 ?241 Dcblow _c (la&t.lUlmc flpi if indivi4ual) .114 JlIlIilinll ad4~ YDUllG' S ~OOO MAIUCIiT RD 3 BOIC ~ (jo,"", NEWILL!!, PA 17241 Dcblllr name (laat name rJl1t IClndividl1al) and llllIiling llddrcaa: Bee1lftd Parl1(Ics) nJmC(;) (Wt DMlC 6DI iC lndividuaI) anc1 ucIdrua lot.ecurlty Inu:rcal inrol'lllallon: Mellon aank, N.~. ll\l8frwOG lIanlc.ng loan C:..,Cer 0l'\4' MoHon fhlnk Center 1 Rill. 1S'-1i!70 Pltt~burg~. PA 1S2Sa-Ov01 "2- AKfaacc(-) or ~ p~ 1IIII\l!(af (I.W DIImc tItst If lncllvldllal) ~ addtaa for IOCluity IaICI'CIiC Information.. Spcdal 'I)pu 01 lI'lII1IclI (cbcck'lCappl1cable): o 'IIIe lena "Pcbtcx" and "Secured I'.nyt IlWID "LeAc:c" ad "Lcaor,. rcapeaWe!)'. C ne CenD& "Dcbcot' .Illl "SccuRd Party" J:O.Wl "CoImgnce" pel "CoaIlpor.' rc:spectively. o DdKor fa 1\ TrllmmltUllr; Utility- SECURED PAIn'YSIGNATIJRE(S) "'slaktDaJ.t" aw.....1h oDlY the 8ec1llllll Putt' aIpAare to pedect .lICCIldty iatcraUn collatcal (c:bcckappli<:ab1c bcK(~))- ~~~'.~ ~~; . .. .~T~729: P.002/008 F-210 t1NM<<:1NU 8i~1'~ Uniform Cou\mllmal Code FonnUCC-l II A:> 1_ IMPORTANT - Please rWI1nstruc:1iou 1lP1 r; _ dl\!fuU,.btrorerompletine _ . FII1ngNo. (s1llo1l1ped by filing offlCeP):: ~t"t. ~ .!t~~ (llImped t:f.J fi1ius oCfice&?: :::. :)0:. qn'~~'o~_ DEEDS ::i' !.H;;, :~LAtI[) COUNTY - flA 1 1. 9-r7T'J 'S'/ JUH2~_~.~~ 1~ ~1 _.. s . nil FIDaoc/.Dc SlAlc~ iii plllICftKll for filing'puDWIDlIO 1IIe Unifotlll CollUIltrCial CodA!, and ia lOb:1iJedl\'llh lhc(da:chpP1lcable~~ C SeeretatyaC\hec.........: .~.AIth. ': '. Ill.., "j'" [J 'Prothouowyof. " ,.,. !XI real ClIlato (CCOrcJa of CIJ4III!RUJlp ,_ .. ~,: . ~~ iii (cha;:k~ it~ J'rod~oClhc col~ in;.,ClOVere4.. 'ldcaUJy nIa\c4 RGl....k, Ihppilallble: "fIII;\101~ iI, or Inc!ucles. (checlcappropriale~CI))- ~. '-:;' a. [J Ctvpl p;owiaJortobc~OA- .;, -' .,.... b. iii goodawllldUrcorlltClObcccuDc:,QxI~ ~-:f Il. [J mlNl'lllI ot 1hc IIU (lDcludiq 011 and PS)a..,l!la&1lC:tCcI oa- If. 0 _ala l'CtulUll& ftom ui&--..Li ot'p"~;,Cir lIle IIfcc (iadudius nil.ad gas) at Ibewc1J1leBdotmincheadClll~ ',' ,\0\11:"1'1 :-:J. . r- Ille rol1owill, RllI CSlllle: : I:, a. [] ao:jllltecl After. chaa... or Aa~~ Idcrdll,1 or 001'padte IItnIctw:c RD 3 lOX 3U , of (he Deblor. SIoctM~ NEWlLLE PA ln41' . b. C as to which the IlUPI baa lapsed. DeoIcriW ~ Dook~at (llhecI(cil\etCl Deeds 0 MorIpics, c. altead)' aabJact to. &CQlf\ly Interest III _..ther coanl1m at. Pa&e(s) _. . Cor CUMIrEIit;Alllf':;:;f;':';~~ I'cmmyJ\lal1la - Collnty. UlIiConu PlItCd ldeatlilCt .~. ""'W,~~... D Vthen tho C4J1ataal wu ID.IIW to IIUs 1lOUDl)'. . ,;:: ". ~ o Dcsc:n'b6donAddiIiouAISbeet.," "<1':" ~ '.;,. C -::. ~~... _I".-nee 01' J;>1Iu:c oI'bvah1e8llll'llIlAovcd Ha_ .t-=onI 0WDu (rl!qtUred on'; tt:~ ~~ all'lalereSt of I'CIOOO.\): d. a1ceady lubJ~ 10 a accllr.ityInwrflSt In _ther juda.cI1eUoll_ DEBTOR Si(;N~'A;..'i'V~s) o when ~ coilaleral wa RWved to Pr:lUlS)'lvaAb. ., " . Owllcu lhe Dcbtor'l\ocaUoD"" "'0\'611 \D P~lVl1nb. .. ~~:7~'~~ ~..~-'_ :.~", ',':. m.. . ~~,. e.n which la ~ ofth4cml1at~ dcscn"W 111 b1oclt9. ~(.5~ ;cco MAR~T '. . . in ..bleb ucc:urily lJ11'erect __ pa:viOual)' perfected (alaa drscrlbc: 11\. . ~..'. . ~ III bIoc:k9.lfpurc:based with cath ~ and not ': ; - adequatl:\y deac:rlbc1 OD \he original fllWlClllt: IlJltCllSCllt). Ib S-UCd p~ SlpatDrt:C') Rln'URNlU!ClW'TTO: (requited otIly lf1ialt(ca)'" cheeked aboYe)\ Mellon Bant~ N .A. Mel.LO~BA.N:r._)J ~, ._ BUS.ness aai\k..ng lOllll c.nt.~. G~ ~ P.O. BoX 3080 Pittsburgh, Pol 1SnO-JD8ll _ 'W/ . AU., Coll._.I ..." I STItNtJARD l'OICM - fORMPA Ucc.l (Rd. 3,'93) ApJl"OWlll bySm'du1otC:O-Q~ 6rPnllly{vnla CL-2121tcv.l7M) LC. 11m U> ~ f1Z1$ JI 2$.1~ ".1I " , h - nr '" ." "uvr.~., lb NumMJ'-otMdllloIlQ.S te~ l~8Dy.. . ~',,:,_ _ _ . Optlo\SldSpeclalllfaltltl"ad01l (Max. \Oeliar8aC1J!): COUA.'l'EJ.UL"f'...':',,: . . .. .' ~-<"'~'~'i:1I.:. JckDurr~nrI by1lcmlUldlorl:ypQ:,.,l- \~"~:.y..!i AlL DE1J1"OR'S IltGllT, TtTLe, AND INTEREST.i~\lIiS'\'HER NOll Clt HEREAFTER ~TSTII/G OR ACOUIIlE~~ ANO TO ALL INVEHTllRY (INClUDING lE1lJRNED Oil REPOSS COODS)'~ ACCOUIlT$. OPEl ACCWNTS, GENEAAl. INTAJlGI8LES, <l)OC\JI4ENlli.j":CllATTEL PAPER, IIISTRUMeiITS, NOTES, DRAUS, Ll!lTElS ClR ADVIUS or CREDIT. RECEIVABlES, Ol'IIER JMClJIITS WING TO DlOBTOI, FIXTURES. FURNITURE .uo EQlJIPMM, ALL ~R.CID\JCTS AIlll CASH AND NOIH:A$H PROCEEtl$ (1NCLlJ)UIG 11ISURANCE, pOLICIES AllD PRCCEEOS) OF TilE fORSGOltl(; lIIll All GUARAIITrES, CLAIMS, RIGKTS, REJQ;OlES AND PUVILEGES'llELAnNli~,:TIleJU:TO. "f" \ '.,' .;", 2a ,.-) ~.~~ .' i' '. 3 . ., :J" " ;.. ORIGINAL COP~ 3 CU1.2 (01) o6G.moOSOl ..'.r. P.......... ,. ~ ...:~~~f.Y ~:." .. .." ~. .' .~;,~,~':;- .. "',1~,'.'; , ~.' .. l'~l~t:' ~ 't~ ~ County. Collllly. 6 1 8 9 10 11 11 . . Oct-20-2004 08:32am _. T~729 P.003/009 F-210 ~ ..l..l~ ,.. ,.,. .. .....,-,~ , . . :. -'.~"'" ;,:... ,'!.o etOS .'tihlU~R'~.t~i) C"UNTY.. PA · O? ftPR"g MIl 02 ... UCC FINANCING STATEMENT AMENDMENT FOWlWIN~"""'_~ . _ IYj"J..ft; -~ NAME I. PHONe all cONTIoCt' AT fUR (QII\lOMIt 8. 'SlONOAC:I<NOWlJitlGIWfTTOlIJ'IMu.MAddrWl Ci~tl~ ..~ vi 'ennlYlv.n', SUI;,,"J '~I/'llI LIlt! C*IlUI' '.0. lu 3llSD ,.1 tts~"I", PI. 1S230.lOlIQ Ann: coU,ter.' Ilnh: .. THe A90Vj S?ACI: IS POI' FII.lN)t.oFli1e'i.~e QNl Y '''' ~NWlC"4CUl'...t1IJ.IiHC'N" \ ~Jl>>WlQNClalTAmIENl'~'" ~ :;lIlMlJIr*"lIW -.. III"" "'4,"7n ~_""_Cl'7'.. . '. . ~BTIo""~ ._ 2. O~ ~tI...""-MIl>c ~~ _;0*--......__ ~........,....~"""~ ...1'____ ,. ~~'T'ICk .~..... ~...__...__...._~__,...,.... .c"'SoC_rtl\r~..._____.. .. ~1W"'~,*,"~IIr~- . . .',"'\".. '", D~ ....... -- ..........."'-.,.,,"'.....~-..__lll"""'.Mll-.....:.....-a-.._... L -Ai.~,MfYIHrOll"~,...tQ ~~......Oc.-.o..-iJi~...-.. ~-!!l!._---" - --awl .....-..~-I!!lt...... ~..-.-.. _1M' ....,...,. . O~_MCI/lor- __--'-Iot..............._ 0 Clt!I.D'iMMl '""~ - CI H)O--.: c-.....*"'.,....,.,....... _1I_.tIonttt...... ),,."'__ _11_ -.,.Ift)ell"'" '" M._ '" _....... ......0:_...... _ '"'' . UJIlIMlIM(. ,. .. CI.lI'llllHf /'Cl:IICI"'~ ... CI'llWW._~ ~ KRAK, SAbta RO, ClI'- '- ... ll"O\IICUN...uartWUl . r _. , YQt1NG"S FOOD ~ ~--,~M7 .;1.~~'jJ;. \ ~NAI&C ..\~~ - . " ~ . \~.. 1. ~rCWI~loCQIJI~ ,...~~ CI"I ..... INCI'<<JUI;a vCr ~ , . F\N'1' NANlt ~Pi'AM1 ~ 'c.' ~1oQORD:S ~..... .. llD.uJ BOX 61~ blEWV~.... 7a. TAlI'~"'HlIUlH I::":' I'. '/'t'I'i0ll~ 'If. oIU~QIl'~1lCN L ....CNCIYINr~T1M.~1 clMckarlyJl!lJ.... . ~......... 0---" 0 -.....- 0 --~""""'It....o........"" 0 ~ 11'''1'& l/lOCT.Al.allll! ti2\ . 17241 '.~~~....., ~ ~ ON:M ,.,III'I';o~, . ~..... : I ~ ~~~ ? ;. ...i.i... ...- "" :,.;t~' ...,..... ... .. .....i.. L _....~PMlY..~~'llGNol~_~.....'._...~. ._"'-';'-"'-_~.Olo_~ __...._N,-....ac.-.._."""".'~~Of.O'_._..... n ""'__tlI11ftTOi'__~.._ ... ~TOl'&NAH& " ',Jo.!S ~ f_, 1 ~. 0" .. t;h:lu". lant at ,emsVlwnh '\llIil\cu IIfI\:fntl LlIan C.n1:U'-:~-u-" .. . . ... ~"IM1'''''''' . I'M1':". ,..t~~tWoIt: lWtrllt 111 ~l'U"~vo(U:C:Gl.t'A 2'5 .. ... _" aofJ C\JW:lli:.~D L;t.\l''''$ k...~..q" \"I:'.'U& IJJ WI' - . . N.I>oT'e.o':u.l. ucc:. FINANCING ~T""TEMeNT "MeiO~ lF6RM ~~~, ti'IEv. oi~,al ",,,. 1& >1'_'" I \.7~V"'r-,Gh 1~.1J~. ... . .'_..' .. ,~ ... '.. .".- -~_._-+- ....-, iI' \ . I " . of -..~. ! )"" l "... L Detail report item #1 printed by: DOTTIE HOFFMAN on 2/22/01 ================================~============================================== PENNSYLVANIA Dee DETAIL REPORT DATA COVERAGE THROUGH FE B 0 5 , 2 0 0 1 SEARCH COMPLETED FEB 22, 2001 08:59 AM (CST) ~==~~~~=====~==~=======~===~====~=============================================~ Filing Location: SECRETARY OF STATE OF PENNSYLVANIA 308 NQRTH OFFICE BUILDING HARRISBURG, PA. 17105-8722 Original Filing Number: Original Filing Date: 26811373 06/23/1997 Collateral: FURNITURE AND FIXTURES HEREAFTER ACQUIRED PROPERTY INVENTORY MACHINERY AND EQUIPMENT OTHER Debtor: KWAK, SANG HO RD 3 BOX 672 NEWVILLE, PA. 17241-0000 Additional Debtor: YOUNG'S FOOD MARKET RD 3 BOX 672 NEWVILLE, PA. 17241-0000 Secured Party: MELLON BANK NA BUSINESS BANKING LOAN CENTER PGH, PA. 15258-0001 THE INFORMATION IN THIS REPORT IS PROVIDED IN CONFIDENCE SOLELY FOR YOUR USE IN EVALUATING ACTUAL OR CONTEMPLATED BUSINESS TRANSACTIONS INVOLVING THE BUSINESS ENTITY TO WHICH SUCH INFORMATION RELATES. NEITHER EXPERIAN NOR EXPERIAN'S SOURCES WARRANT THE ACCURACY, COMPLETENESS, CURRENTNESS, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OF SUCH INFORMATION. IN NO EVENT WILL EXPERIAN BE LIABLE FOR INDIRECT, INCIDENTAL, CONSEQUENTIAL OR SPECIAL DAMAGES RESULTING FROM THE USE OF SUCH INFORMATION. THE FOLLOWING DATA IS FOR INFORMATION PURPOSES ONLY AND IS NOT AN OFFICIAL RECORD. CERTIFIED COPIES MAY BE OBTAINED FROM THE PENNSYLVANIA DEPARTMENT OF STATE. ~ VERIFICATION I, Joseph E. Sweeney, hereby certify that I am an Assistant Vice President of Citizens Bank of Pennsylvania I have the authority to make this verification on its behalf. I hereby verify that the factual averments contained in the foregoing complaint are true upon my personal knowledge or information and belief. I understand that this verification is made subject to the penalties of 18 Pa.C.S.A. 94904 relating to unsworn falsification to authorities. 637979.] (:) ""9 t ~ ~ lI{ ........ a:- D n ,......, 0 c:;-..> en c.' c',:" -11 ~ .' .x- ~ Vv -cJ, <" 0 :r 5; )v ~~.,.. f1,,:;;Q ....:; ~ " ~ ,...,) ~Ct n, t ,'; :~)? " -, - w ~1\;.,? ~ r' :_ t" I:. '., ':~:Jr5 :.t: :~'.r; - l).Tl .. . .", ~ "....,'':10 ::) (.f1 "j,) """' en -< , :. HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION BY: JAMES T. SHOEMAKER ESQUIRE IDENTIFICATION NO. 63871 LAW OFFICES 600 Third Avenue Kingston, PA 18704 (570) 287-3000 ATTORNEY FOR PLAINTIFF MELLON BANK., N.A., now by assignment CITIZENS BANK OF PENNSYLVANIA 8 West Market St. Wilkes-Barre, PA 18701, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. CIVIL ACTION -- LAW REPLEVIN SANG HO KW AK, Individually and d/b/a Young's Food Market, and YON HW A KW AK: 2208 Chatham Way Harrisburg, PA 17110, Defendants NO. 04 - ~"'5y C21,J~'UL~ PLAINTIFF'S MOTION FOR WRIT OF SEIZURE The plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania, by and through its counsel, Hourigan, Kluger & Quinn, P.c., hereby submits, pursuant to Pa.R.c.P. 1075.1, its motion for writ of seizure, against the defendants, Sang Ho. Kwak, individually and d/b/a Young's Food Market, and Yon Hwa Kwak, as follows: 638031.1 .~ On even date herewith, the plaintiff is filing a complaint in replevin against the defendants. (A true and correct copy of plaintiff s complaint in replevin is attached hereto pursuant to Pa. R.C.P. No.1 075 .1 (b), incorporated herein by reference pursuant to Pa. R.C.P. No. 1019(g) and marked as Exhibit "I.") WHEREFORE, the plaintiff prays this Court to enter an Order directing the Prothonotary to issue a writ of seizure to the Sheriff directing the Sheriffto seize the Collateral. Respectfully submitted, HOURIGAN, KLUGER & QUINN, P.C. BY: ~~ James T. Shoemaker, Esquire ill No.: 63871 Counsel for the plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania 600 Third Avenue Kingston, PA 18704 Telephone (570) 287-3000 Facsimile (570) 287-8005 Dated: November z,:} , 2004 638031.1 2 " VERIFICATION I, Joseph E. Sweeney, hereby certify that I am an Assistant Vice President of Citizens Bank of Pennsylvania I have the authority to make this verification on its behalf. I hereby verify that the factual averments contained in the foregoing motion are true upon my personal knowledge or infc,nnation and belief. I understand that this verificatio~ is made subject to the penalties of 18 Pa.C.S.A. ~ 4904 relating to unsworn falsification to authorities. ftLir 637979.1 .. HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION BY: James T. Shoemaker, Esquire IDENTIFICATION NO. 63871 LAW OFFICES 600 THIRD AVENUE KINGSTON, PA 18704 (570) 287-3000 ATTORNEY FOR PLAINTIFF MELLON BANK, N.A, now by assignment CITIZENS BANK OF PENNSYLVANIA 8 West Market St. Wilkes-Barre, PA 18701, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. CIVIL ACTION -- LAW REPLEVIN SANG HO KW AK, Individually and d/b/a Young's Food Market, and YONHWAKWAK: 2208 Chatham Way Harrisburg, P A 1711 0, Defendants NO. 2004 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 Notic,e 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 637973.1 'k ' EXHIBIT .~~. .' , \ ~ . 1,\,:: ., u./Il .... .., .... l.~:. 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 HA VE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGmLE PERSONS AT A REDUCED FEE OR NO FEE. COURT ADMINISTRATOR Cumberland County Court House Carlisle, P A 17013 (717) 249-1133 -or- PENNSYL VANIA LAWYERS REFERRAL SERVICE P.O. Box 1086, 100 South Street Harrisburg, P A 17108 (pennsylvania residents phone: 1-800-692- 7375 ; out-of-state residents phone: 1-717-238-6715) HOURIGAN, KLUGER & QUINN, P.e. BY: '- James T. Shoemaker, Esquire Counsel for the plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania 637973.1 " HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION ALLAN M KLUGER RICHARD M GOLDBERG JOSEPH A LACH RONALD V SANTORA JOSEPH E HUGER JAMES T SHOEMAKER MICHAEL J KOWALSKI RICHARO M WILLIAMS JENNIFER L ROGERS L1TTZr JOSEPH A QUINN JR ARTHUR L PICCONE RICHARD S. BISHOP DANIEL J DISTASIO DONALD C. L1GORIO MICHELLE M. OUINN DAVID AIKENS, JR AMANDA V WRIGHT.KLUGER MICHAEL A LOMBARDO III LAW OFFICES SUITE TWO HUNDRED 434 LACKAWANNA AVENUE SCRANTON. PA 18503 2014 (570) 346.8414 FACSIMILE (570) 961.5072 600 THIRD AVENUE KI NGSTON, PA 18704-5815 (570) 287-3000 FACSIMILE (570) 287-8005 E-MAIL: hkq@hkqpc.com OF COUNSEL ROBERT C CORDARO ANDREW HOURIGAN. JR. 1948+1978 Ext. 1126 Direct e-mail: ishoemaker(aJ)Jkqpc.com "ALSO MEMBER NJ BAR November 23, 2004 Sang Ho K wak, Individually and d/b/a Young's Food Market 2208 Chatham Way Harrisburg, P A 17110 Property Address: Account No.: Young's Food Market, RD 3 Box 672 Newville, PA 17241 0805386-0101 IMPORTANT NOTICE THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE, UNLESS YOU, WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS NOTICE, DISPUTE THE VALIDITY OF THE DEBT, IT WILL BE ASSUMED TO BE VALID. IF YOU NOTIFY THIS OFFICE IN WRITING WITHIN THIRTY (30) DAYS THAT THIS DEBT, OR ANY PORTION THEREOF IS DISPUTED, WE WILL OBTAIN AND FORWARD TO YOU A VERIFICATION OF THE DEBT OR THE JUDGMENT AGAINST YOU. WE WILL ALSO PROVIDE, UPON WRITTEN REQUEST WITHIN THIRTY (30) DAYS OF THE DATE OF THIS NOTICE, THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR. , Very truly yours, . - . ,,---...- -~.~ I ''-{anles T. Shoemaker, Esquire JTS:je THIS NOTICE DOES NOT SUPERCEDE YOUR OBLIGATIONS UNDER THE FOREGOING NOTICE TO PLEAD 638028.2 \ HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION BY: .James T. Shoemaker, Esquire IDENTIFICATION NO. 63871 LAW OFFICES 600 THIRD AVENUE KINGSTON, PA 18704 (570) 287-3000 MELLON BANK, N.A., now by assignment CITIZENS BANK OF PENNSYLVANIA 8 West Market St. Wilkes-Barre, PA 18701, ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. CIVIL ACTION -- LAW REPLEVIN SANG HO KW AK, Individually and d/b/a Young's Food Market, and YON HW A KW AK : 2208 Chatham Way Harrisburg, P A 17110, Defendants NO. 2004 COMPLAINT The plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania (the "Bank"), by and through its counsel, Hourigan, Kluger & Quinn, P.c., complains of the defendant, Sang Ho Kwak, Individually and d/b/a Young's Food Market ("Mr. Kwak"), R.D. 3, Box 672, Newville, PA 17241, as follows: 63XOI8.! " 1. The Bank is a Pennsylvania state chartered bank conducting business in the Commonwealth of Pennsylvania, having an office located at 8 West Market Street, Wilkes-Barre, PA 18711-01Ol. 2. Mr. Kwak is an adult individual with a last known address of2208 Chatham Way, Harrisburg, P A 17110. 3. Upon information and belief, Yon Hwa Kwak is deceased. 4. On or about May 28, 1999, the Bank made a loan to Mr. Kwak, individually and d/b/a Say-Ford Supermarket and Yon Hwa Kwak (jointly, the "Kwaks"), in the amount of $395,000.00, as evidenced by a note, disclosure and security agreement (the "Note"). (A true and correct copy ofthe Note is attached hereto as Exhibit "A" and incorporated herein by reference.) 5. In order to induce the Bank to make the aforesaid loan, Mr. Kwak granted the Bank a security interest in , among other things, his equipment, machinery, motor vehicles, furniture, fixtures, inventory, accounts and contract rights (collectively, the "Collateral"), as evidenced by a security agreement (the "Security Agreement") and as protected by certain UCC-l financial statements (the "UCC-l Financial Statements"). (A true and correct copy of the Security Agreement and the UCC-I Financial Statements is attached hereto as Exhibit "B" and incorporated herein by reference.) 6. The Note was not assigned, except as stated above. 7. Mr. Kwak defaulted under the terms of the Note by failing to make monthly payments of principal and interest due under the Note. 6380\8.\ 2 " 8. The fair market value of the Collateral is unknown, but is believed to be less than the amount due and owing the Bank by the Kwaks under the Note. 9. The Bank believes and therefore avers that Mr. Kwak has possession of the Collateral. 10. Mr. Kwak has failed and refused, despite repeated demands by the Bank, to pay the balance due under the Note or to deliver possession of the Collateral to the Bank. 11. The balance of the Note as of October 26,2004 was $320,245.20, consisting of principal in the amount of$311,149.22, accrued interest in the amount of$8,512.74, and late charges in the amount of$583.24, exclusive of attorneys' fees and costs. WHEREFORE, the Bank demands judgment in replevin in favor of the Bank: and against the Kwaks in the amount of$320,245.20, plus interest from October 26,2004, attorneys' fees and costs, and requests this Court to enter an Order directing the Prothonotary to issue a writ of possession to the Sheriff directing the Sheriff to seize the Collateral. Respectfully submitted, HOURIGAN, KLUGER & QUINN, P.e. BY: ~.. S -.-- James T. Shoemaker, Esquire ill No.: 63871 Counsel for the plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania 600 Third Avenue Kingston, P A 18704 Telephone (570) 287-3000 638018.1 3 :"'::'::':':'Plomi~s6 Note ." ..... ...... .. rv :. :. ~ . ."..". . . . .. . $ 395,000.00 Promise To Pay.. FOR VALUE RECElVED,a~d intending to be legally bound, UndersIgned, as defined below, promises to pay to: Mellon Bank, N.A. ("Bank") or its order at Harrisburg, Pennsylvania the sum of Three Hundred Ninety Five Thousand and 00/100 Dollars ($ 395,000.00 ), :with interest on the outstanding balance from the date of: this Promissory Note ("Note") at the rate(s) ("Contractual Rate(s)") and in accordance with the repayment schedule specified belqw. Contractual Rate(s); Repayment Schedules. : o Interest at a rate per annum:which is % above Bank's Prime Rate, such rate to change from time to time as of the effective date of each announce<I change in such Prime Rate, shall be paid when principal paympnts are due. Principal shall be paid in consecutive D;lonthly installments of $ each, commencing on and continuing thereafter on the : day of each month with the balance of the indebtedness, if n~t sooner paid, due and payable on : , i o Interest at a rate per annum which is % above the CD Rate, such rate to change from time to time as of the effective date of each change in or re$etting of the CD Rate shall be paid when principal payments arc; due. Principal shall ~ paid in consecutive m9nthly installments of $ each, commencing on , and continuir g thereafter on the day of each month witt the balance of the indebtedness, if not sooner paid, clue and payable on I I n The principal balance he~~f, together with all accrued and unpaid interest, shall be 'paid on and interest at a rate per annum WhiCtl is % abov~ Bank's P~e Rate, such rate to change o~ time to time as of the effective date of each announced cha ge m such Prime Rate shall be paid on the day of eachi month commencing o~ , I I I o The principal balance hereof, together with all .accrued and unpaid interest, shall be paid on , and interest at a rate per annum which ~ % above the CD Rate, such rate to change from ti me to time as of the effect~e date of each change in or resetti~ of the CD Rate, shall be pald on the day of each ronth commencing on I o In no event shall the rate charged ,'on this Note exceed . % per annum. I o The principal balance he~ f, together with all accrued and unpaid interest, shall be pai on and interest at the rate of % r annum shall be paid on the day of each m th commencing on fXI "- S"' :;; ..' 'Yr~.rest shall be calculted at' the rate of R, c:;n % per annum. Principal and ~terest shall be paid in 17q consecutive monthly installments of S 3,923.65 . ead>,Ton :..:- .::t" ., "I <~~~~ - _j:- . - ..d:;., ,,)). '.- 1 ~ :' ~:i.Lo ,-'\ ; ~t~ ~~ 1 , ". _ c .. ~ 'Mellon Bank Date ~';.-- /;4/11 07/01/1999 ,and continuing thereafter 011 the 1ST day of ea~h month with the balance of the indebtedness, if not soo?er paId, due and payable on 06/01/2014 . During any penod that the Clmtractual Rate(s) is reduced by 0.25% per annum, as described elsewhere in this Note, installments of principal and interest shall instead be in the amount of $ 3,864.70 each. If the reduction in the Contractual Rate(s) is no longer in effect, the amount of installments of principal and interest shall return to and be the same as the amount of such installments prior to the reduction in the Contractual Rate(s). Undersigned shall pay Bank concurrently with the execution and delivery hereof, or Undersigned previously bas paid Bank, an origination fee of $ 3 I 950 . 00 , to compensate Bank for its underwriting, origination and administration of the loan evidenced by this Note. This fee shall be deemed fully earned by Bank on the date hereof, shall not be refunded, and is in addition to any other fees, costs or expenses which may be due and payable hereunder. , Unless Undersigned has authorized Bank to take payments out of a Mellon Olecking Account, as set forth below Undersigned will mail or deliver to Bank the amount billed by Bank each month. Undersigned will mail or deliver the payments so that Bank receives all payments no later than the due date shown on each bill. o Undersigned authorizes Bank to take all payments of principal and/or interest and/or other amounts due under this Note out of Undersigned's Mellon Olecking Account Number , titled in the name(s) of , on or after ~he . ~y of each ~tith. Undersigned will keep a suffiCient balance m this account to cover the full amounts of all required payments. At. its option, Bank may terminate Undersigned's ability to use this service. This authorization shall remain in effect until revoked by Undersigned in writing or until the loan evidenced by this Note is paid in full or until Bank has terminated Undersigned's ability to use this service as the case may be. Prior to maturity, while this authorization is in effect and provided that' Undersigned keeps a sufficient balance in this account to cover the full amounts of all required payments, the Contractual Rate(s) shall be reduced by 0:25% per annum. This authorization will be effective even though this Note and the account may be titled in different versions of Undersigned's name. If the original principal amount of this Note is in excess of $10,000.00, or if U~dersigned is a corporation, interest shall be calculated on the basis of a 360-day year arid actual'days elapsed. If the original principal amount of this Note is $10,000.00, or less, and Undersigned is not a corporation, interest shall be calculated on the basis of a 365-day year or 366-day year, as the case may be, and actual days elapsed. "Prime Rate" shall mean the interest rate per annum announced from time to time by Bank as its Prime Rate. The Prime Rate may be greater or less than other interest rates charged by Bank to ?ther borrowers. and is not sOlely based or dependent upon the IOterest rate which Bank may charge any particular borrower or class of borrowers. . If a single certificate of deposit is held by Bank as collateral security for the indebtedness evidenced by this Note, as more fully d~bed in the Assignment of Deposit Account expressly referring to thIS Note, "CD Rate" shall mean~he interest rate paid by Bank on such certificate of deposit (the "~t1ifi~t~"), said CD Rate to be Page 1 of5 '.~;. < reset by Bank at each renewal of the Ce(~te. If more than one certificate of deposit is held by Bank as collateral security for the indebtedness evidenced by this Note, as more fully described in the Assignment(s) of Deposit Account expressly referring to this Note, "CD Rate" shall mean the highest of the interest rates paid by Bank on such certificates of deposit (the flCertificates"), said CD Rate to be reset at each renewal of each Certificate. Late Charge. If any payment (including without limitation any regularly scheduled payment, balloon payment or final payment) is not paid within 15 calendar days after it is due, Undersigned will pay a late charge of the greater of $25.00, or three percent (3%) of the unpaid portion of the scheduled payment due (regardless of whether the payment due consists of principal and interest, principal only or interest only). Such late charge shall be in addition to any increase made to the Contractual Rate(s) applicable to the outstanding balance hereof as a result of maturity of this Note or otherwise, as well as in addition to any other applicable fees, charges and costs. Default Rate(s); Post-Maturity Rate(s). Upon the occurrence of any Event of Default (as defined in this Note), at Bank's option, interest shall accrue at a rate equal to two percent (2%) per annum above the Contractual Rate(s) until the earlier of the date that such Event of Default bas been cured or until and including the date of maturity hereof. After maturity, whether by acceleration or otherwise, interest shall accrue at a rate equal to two percent (2%) per annum above the Contractual Rate(s) until all sums due hereunder are paid. Interest shall continue to accrue after the entry of judgment (by confession or otherwise) at the Contractual Rate(s) until all sums due hereunder and/or under the judgment are paid, except that after maturity or, at Bank's option, upon the occurrence of any Event of Default, interest shall accrue at a rate equal to two percent (2%) per annum above the Contractual Rate(s). Books and Records; Time of Essence. So long as Bank: is the holder hereof, Bank's books and records shall be presumed, except in the case of manifest error, to accurately evidence at aU times all amounts outstanding under this Note and the date and amount of each advance and payment made pursuant hereto. The prompt and faithful performance of all of Undersigned's obligations hereunder, including without limitation time of payment, is of the essence of this Note. _ Security Interest, Setoff and Assignments. To secure all amounts at any time owing or payable under this Note and Undersigned's obligations hereunder, as well as to secure all costs and expenses _incurred by Bank in the collection or enforcement of this Note or the protection of any collateral securing this Note (including without limitation aU advances made by Bank for taxes, levies, insurance, filing fees, and repairs to or maintenance of said collateral), Undersigned hereby grants to Bank a security interest in, lien upon, and right of setoff against, all deposit accounts, credits, securities, moneys, or other property of Undersigned which may at any time be in the possession of, delivered to, or owed by Bank, including any proceeds or returned or unearned premiums of insurance, and the proceeds of all the foregoing property. Other property, real or personal, may secure this Note, as set forth in other documents and agreements. Undersigned aclcnowledges and agrees that Undersigned shall renew, or cause to be renewed, the Certificate(s), if any, until the indebtedness evidenced by this Note has been paid in full. Undersigned furthec agrees that Undersigned will execute, or will cause to be executed, upon demand by Bank any financing statements or other documents, including, without limitation, additi<?fi3l Assignments of Deposit Account, which Bank may deem necessary or desirable to evidence, perfect or maintain perfection of the security interests created in the Certificate(s) and any renewals, replacements and substitutions thereof. ;, I Additional Terms and Conditions 1. Covenants. Undersigned oovenants and agrees that until all indebtedness evidenced hereby bas been paid in full, Undersigned shall: (a) maintain at all times a pooitive tangible net worth; (b) (1) have all Environmental Permits necessary for the conduct of each of Undersigned's businesses and operations, (2) conduct each of Undersigned's businesses and operations in material compliance with all applicable Environmental Laws and Environmental Permits, (3) not permit to exist any event or condition that requires or is likely to require Undersigned under any Environmental Law to pay or expend funds by way of fines, judgments, damages, cleanup, remediation or the like in an aggregate amount, the payment of which could reasonably be expected to interfere substantially with normal operations of Undersigned or materially adversely affect the financial ooodition of Undersigned, (4) notify Bank promptly upon becoming aware of any pending or threatened proceeding, suit, investigation. aUegation or inquiry regarding any alleged event or condition that, if resolved unfavorably to Undersigned or any of Undersigned's subsidiaries or affiliates, is likely to cause Undersigned or any of its subsidiaries or affiliates under any Environmental Law to payor expend funds by way of fines, judgments, damages, cleaning, remediation or the like, and (5) provide at Undersigned's cost, upon request by Bank, certifications, documentation, copies of pleadings and other information regarding the above, aU in form and content satisfactory to Bank; (c) conduct each of Undersigned's businesses and operations in material compliance with aU federal, state or local laws, statutes, regulations, rules, ordinances, court or administrative orders or decrees, or private agreements or interpretations, now or hereafter in existence, direct1y or indirect1y relating to or affecting Undersigned's businesses or operations; (d) use the proceeds of the loan evidenced hereby only for business purpose(s) specified to Bank at or prior to the execution hereof; (e) promptly notify Bank in writing of any change in Undersigned's residence or Chief Executive Office; (f) purchase and maintain policies of insurance (including flood insurance) to protect against such risks and casualties, and in such amounts, as shaU be required by Bank and/or applicable law, wbicb policies shall (1) be in form and substance satisfactory to BanIc, (2) at Bank's option, designate Bank as loss payee and/or as additional insured, and/or contain a lender's loss payable endorsement, and (3) be (or certificates evidencing same shall be) deposited with Bank; (g) (1) maintain and keep proper records and books of account in conformance with generally accepted accounting principles applied on a consistent basis in which full, true and correct entries shall be made of all Undersigned's dealings and business affairs, (2) provide to Bank at Undersigned's cost, upon Bank's request, financial or other information, documentation or certifications (including without limitation annual and periodic balance sheets and income statements, personal financial statements, federal income tax returns, inventory reports (including a description of raw materials, finished goods, and the aging thereof, as applicable), and accounts receivable and payable aging reports), aU in form and content satisfactory to Bank, and (3) permit, upon request by Bank, any of the officers, employees or representatives of Bank to visit and inspect any of Undersigned's properties and locations and to examine its books and records and discuss the affairs, finances and accounts of Undersigned with representatives thereof, as often as Bank may request; (h) provide additional collateral at such times and having such value as Bank may request, if Bank shall have reasonable grounds for believing that the value of the collateral securing the indebtedness evidenced by this Note bas become iosufficieot to &ealrc said indebtedn~; (i) pay, upon demand by Bank, (1) all costs and fees pertaining to the filing of any financing, continuation or termination statements, mortgages, satisfaction pieces, judgments and any other type of document which Bank deems necessary or desirable to be filed with regard to security interests which secure the. indebtedness evidenced hereby, regardless of whether such seqirity interests were granted by Undersigned, and (2) aU costs and expel}SCS incurred by Bank in Page 20f5 . '.~~j, ' , " connection with any collateral securing this Note (including without limitation all advances made by Bank for taxes, levies, insurance, repairs to or maintenance of said collateral, appraisal or valuation of said collateral, and determination of flood hazard), regardless of whether such collateral is owned by Undersigned; and (j) pay, upon demand by Bank, all amounts incurred by Bank in connection with any action or proceeding taken or commenced by Bank to enforce or collect this Note, including attorney's fees equal to the lesser of (1) 20% of the outstanding principal balance and interest then due hereunder or $500.00, whichever is greater, or (2) the maximum amount permitted by law, plus attorney's costs and aU costs of legal proceedings. 2. Events of Default. The occurrence of any of the following shall constitute an ftEvent of Defaultft hereunder: (a) default in payment or performance of any of the indebtedness or obligations evidenced by this Note or any other evidence of liability of Undersigned to Bank; (b) the breach by any Obligor (defined as Undersigned and each surety or guarantor of any of Undersigned's liabilities to Bank as well as any person or entity granting Bank a security interest in property to secure any indebtedness) of any covenant contained in this Note or in any separate security, guarantee or suretyship agreement between Bank and any Obligor, the occurrence of any default hereunder or under the terms of any such agreement, or the discovery by Bank of any false or misleading representation made by any Obligor herein or in any such agreement or in any other information submitted to Bank by any Obligor; (c) with respect to any Obligor: (1) death or incapacity of any individual or general partner, or (2) dissolution of any partnership or corporation; (d) any assignment for the benefit of creditors by any Obligor; (e) insolvency of any Obligor; (1) the filing or commencement of any petition, action, case or proceeding, voluntary or involuntary, under any state or federal law regarding bankruptcy, insolvency, reorganization, receivership or dissolution, including the Bankruptcy Reform Act of 1978, as amended, by or against any Obligor; (g) default under the tenus of any lease of or mortgage on the premises where real or personal property securing the indebtedness evidenced by this Note is located; (h) the garnishment, tax assessment, attachment or taking by governmental authority or other creditor of any property of any Obligor which is in Bank's possession or which constitutes security for any indebtedness evidenced hereby; (i) entry of judgment against any Obligor in any court of record; (j) the assessment against any Obligor by the 'Internal Revenue Service or any other federal, state or local taxing authority of unpaid taxes, or the issuance of a 1e\Y or the entering of a lien in connection therewith; (k) change in control of or transfer of any interest in any Obligor - (other than an Obligor who is an individual); (I) a determination by Bank, which determination shall be conclusive if made in good faith, that a material adverse change has occurred in the financial - or business condition of any Obligor; (m) the maturity of any life insurance policy held as collateral for the indebtedness evidenced by this Note by reason of the death of the insured or othetwise; or (n) default by Undersigned in the payment of any indebtedness of Undersigned or in the performance of any of Undersigned's obligations (other than indebtedness or obligations evidenced by this Note or any other evidence of liability of Undersigned to Bank) and such default shall continue for more than any applicable grace period. 3. Acceleration; Remedies. Upon the occurrence of any Event of Default: (a) all amounts due under this Note, including the unpaid balance of principal and interest hereof, shall become immediately due and payable at the option of Bank, without any demand or notice whatsoever; and (b) Bank may immediately and without demand exercise any of its rights and remedies granted herein, under applicable law, or which it may otherwise have, against Undersigned or otherwise. Notwithstanding any provision to the contrary contained herein, upon the occurrence of an Event of Default as described in Section 2(1) hereof, aU amounts due under this Note, including w....Jut limitation the unpaid balance of principal and interest hereof, shall become immediately due and payable, without any demand, notice or further action by Bank whatsoever, and an action therefor shall immediately accrue. 4. Bank's Rights. Undersigned hereby authorizes Bank, and Bank shaH have the continuing right, at its sole option and discretion, to: (a) do anything which Undersigned is required but fails to do, and in particular Bank may, if Undersigned fails to do so, obtain and pay any premiums payable on any policy of insurance required to be obtained or maintained hereunder; (b) direct any insurer to make payment of any insurance proceeds, including any returned or unearned premiums, directly to Bank, and apply such moneys to any indebtedness or other amount evidenced hereby in such order or fashion as Bank may elect; (c) pay the proceeds of the loan evidenced by this Note to any or all of the Undersigned individually or jointly, or to such other person(s) as any of the Undersigned may direct, except to the extent othetwise provided in Section 6 hereof; and (d) add any amounts paid or incurred by Bank under Section l(i), Section 1(j) or Section 4(a) to the principal amount of the indebtedness evidenced by this Note. S. Authorization to Borrow. Undersigned hereby represents, warrants, certifies and covenants as follows: (a) If Undersigned is a corporation, that the person(s) signing below hold(s) the office(s) indicated below (and continue to hold such office(s) until Bank has received notice to the contrary in writing from Undersigned), and that the Board of Directors of Undersigned has adopted resolutions providing that: (1) the person(s) executing and delivering this Note on behalf of Undersigned is/are authorized (i) to incur indebtedness and obligations on behalf of Undersigned by borrowing or making other financial arrangements with Bank from time to time, upon terms and conditions as they in their sole discretion deem desirable, (ii) to make, execute and deliver promissory notes, letter of credit agreements, security agreements, assignments, mortgages and all other documents required by Bank in connection with the incurring of indebtedness or obligations, and (Iii) to assign and pledge as collateral secUrity for any such indebtedness or obligations, now or hereafter existing, any real or personal property of Undersigned; (2) the actions of anyone or more officers of Undersigned in borrowing money from Bank heretofore for the account of Undersigned, in assigning or pledging any of Undersigned's property for the payment thereof, or in doing any other act in connection therewith are hereby ratified, confirmed and approved; and (3) said resolutions shall have the force of a continuing agreement with Bank, and shall be binding upon Undersigned until a resolution amending them shall have been duly and legally adopted and Bank furnished a certified copy thereof. (b) If Undersigned is a partnership, that (1) Undersigned's name shown below is a trade name of Undersigned's firm used in the conduct"of an unincorporated business owned entirely by the persons signing this Note on behalf of said partnership; (2) the partners executing and delivering this Note are authorized (i) to incur indebtedness and obligations on behalf of Undersigned by borrowing from or making other financing or credit accommodations with Bank from time to time, upon such terms and conditions as they in their sole discretion deem desirable, (ii) to make, execute, and deliver promissory notes, letter of credit agreements, security agreements, assignments, mortgages and all other documents required by Bank in connection with the incurring of indebtedness or obligations, and (Iii) to assign and p~~ge as collateral security for any such indebtedness or obligationS;'oaw or hereafter existing, any real or personal property of Undersigned; (3) the actions of anyone or more partners of Undersigned in borrowing money from Bank heretofore for the account of Undersigned, in assigning or pledging any of Undersigned's property for the payment thereof, or in doing any other act in connection therewith _.acc hereby ratified, confirmed, and approved; (4) notwithstanding any modification or tenninatlOn of the .~ Page30f5 .".',," , .~1', power of any of the partners to represent said firm, whether by e~iration of the partnership agreement, by death or retirement of any partner, or the accession of one or more new partners, or otherwise, and notwithstanding any other notice thereof Bank may receive, this authority shall continue to be binding upon each of the Undersigned individually and upon their legal representatives, and upon Undersigned and its successors, until Bank has received notice in writing to the contrary signed by one of the Undersigned or by Undersigned's duly authorized agent (Receipt of such notice will not relieve any partner of any liability arising from obligations incurred prior to Bank's receipt of such notice.), and (5) nothing herein shall be construed to limit the rights granted to a partner by law or by the partnership agreement, but all rights granted herein shall be in addition to such rights. 6. Definitions; Miscellaneous Provisions. (a) Undersigned waives (except where requested hereby) notice of action taken by Bank; and hereby ratifies and confirms whatever Bank: may do. Bank shall be entitled to exercise any right notwithstanding any prior exercise, failure to exercise or delay in exercising any such right. (b) Bank shall retain the lien of any judgment entered on account of the indebtedness evidenced hereby. Undersigned warrants that Undersigned has no defense whatsoever to any action or proceeding that may be brought to enforce or realize on any such judgment. (c) If any provision hereof shall for any reason be held invalid or unenforceable, no other provision shall be affected thereby, and this Note shall be construed as if the invalid or unenforceable provision had never been a part of it. The descriptive headings of this Note are for convenience only and shall not in any way affect the meaning or construction of any provision hereof. (d) The rights and privileges of Bank contained in this Note shall inure to the benefit of its successors and assigns, and the duties of Undersigned shall bind aU heirs, personal representatives, successors and assigns. (e) This Note shall in aU respects be governed by the laws of the state in which this Note is payable (except to the extent that federal law governs). (f) Undersigned hereby irrevocably appoints Bank and each holder hereof as Undersigned's attorney-in-fact to endorse Undersigned's name to any draft or checlc which may be payable to Undersigned in order to collect the proceeds ofaoy insurance or any returned or unearned premiums in respect of any policies of insurance required to be maintained hereunder. Undersigned hereby acknowledges that this appointment of Bank and each holder hereof as attorney-in-fact is irrevocable and is coupled with an interest. (g) Undersigned assigns to Bank all moneys which may become payable on any policy of insurance required to be maintained under this Note, Including any returned or unearned premiums. (h) "Environmental Law" means any _ federal, state or local environmental law, statute, regulation, rule, ordinance, court or administrative order or decree, or private agreement or interpretation, now or hereafter in existence, relating to the manufacture, distribution, labeling, use, handling, collection, storage, treatment, disposal or otherwise of Hazardous Substances, or in any way relating to pollution or protection of the environment or public health. (i) "Environmental Permit" means any federal, state or local permit, license or authorization issued under or in connection with any Environmental Law. (j) #'. .'- "Hazardous Substances" means petrolewn and petroleum products, radioactive materials, ~ radon, lead containing materials, sewage or any material'l or substances defined as or included in the definition of 'bazardous wastes," "hazardous substances," "hazardous materials," "toxic substances," "hazardous air pollutants," "toxic pollutants," "pollution," or terms of similar meaning, as thooe terms are used in any Environmental Law. (k) "aller Executive Office" means the place from which the main part of the business operations of an entity is managed. (I) "Undersigned" refers individually and collectively to all makers of this Note, including, in the case of any partnership, all general partners of such partnership individually and collectively, whether or not such partners sign below. Undersigned sbaI each be jointly and severally bound by the terms hereof, and, with respect to any partnership executing this Note, each geoeraI partner shall be bound hereby both in such general partner's individual and partnership capacities. 7. Direction to Pay Proceeds.Undersigned hereby authorizes and directs Bank to pay the proceeds of this Note by: . . '1 !'t crediting Account Number 000- r.o z 7 '1 if '1y I :tI {p I; 2. B /. i in the name 0511Nb "0 ~ OrJ JfWfr KW rrrC. in theamountof$ I . '. .1 tt/ I R 5 q 0/' E-t./#/t?'j mtllO '1Z)paying rn.0~ :#lPj' 2_. IDJ-fJi'Y-j7.&cjS-- /'\. AItJ.L- :i'I-3!I,!,.(J?36 J?/qq Vz.q 2'-' I the amount of $ . ~ying f)CtJtF/Cf)L! 1/;/19tj. tp'l the amount of $ 8. Affidavit of Business Loan. (Ibis Affidavit is not applicable if Undersigned is a corporation.) Undersigned, being duly authorized, depose(s) and say(s) under penalty of perjury that Undersigned: (a) Is/Are engaged in business 38&1 Owner(s), 0 General Partner(s) of: (name and nature of business) YOUNG' Ii FOOD MARKET AND . SAY-F~.{> SUPERMARKET ~ (, C, f'- FOOD MARKET (b) Hereby make(s) application to Bank for a loan, the proceeds of which will be utilized for the purpose(s) of REFINANCE MELLON DEBT, OTHER DEBT CONSOLIDATION & EQUIPMENT & INVOICE PURCHASE (c) Exercise(s) actual control over the managerial decisions of the business. (Remainder of page intentionally left blank) .'~, ' Page 4 of 5 "..)1, r .,' " 9. Confession of Judgment. UNDERSIGNED HEREBY EMPOWERS 1HE PR01HONOTARY OR ANY ATIORNEY OF ANY COURT OF RECORD TO APPEAR FOR UNDERSIGNED AND TO CONFESS JUDGMENT AS OFTEN AS NECESSARY AGAINST UNDERSIGNED IN FAVOR OF TIlE HOLDER HEREOF, REGARDLESS OF WHEnIER ANY EVENT OF DEFAULT HAS OCCURRED, AT ANY TIME AND AS OF ANY TERM, FOR 11IE OUTSTANDING PRINCIPAL BALANCE HEREOF PLUS INTEREST DUE UNDER TIlE TERMS HEREOF AND ALL OTIIER AMOUNTS DUE HEREUNDER, TOGE1HER WITH COSTS OF LEGAL PROCEEDINGS AND AN A 1TORNEY'S COMMISSION EQUAL TO nIE LESSER OF CA) 20% OF HIE OlITSTANDING PRINCIPAL BAlANCE AND INTEREST THEN DUE HEREUNDER OR $500.00, WHICHEVER IS GREATER, OR Cll) TIlE MAXIMUM AMOUNT PERMITTED BY LAW, WITII RELEASE OF ALL ERRORS. UNDERSIGNED WAIVES ALL LAWS EXEMPTING REAL OR PERSONAL PROPERTY FROM EXECUTION. By signing this Note, Undersigned agrees to all terms of the Note and swears, under penalty of perjury (as set forth in 18 Pa.e.S. ~904, If governed by Pennsylvania law), to the Amdavit of Business Loan (If completed) set forth In Section 8 of this Note. Signatures Witness the due execution hereof under seal. x Witness: x Mellon Bank, NA Mellon Bank (DE) National Association C[A543 Rev.(lWJ6) L.c. 9/96lD 9/96 0275 P 1~-3823 1 cl4543 (01) 052199.1605 I~-dU{ll: . ~ ( X ) , . I ~G HU KW . , i' UUAL ~U DB/A . U ' S FOOD MARKET AND . .., . ~_ tJP~T S'"H-"/-F~-..:z,-J <::;,;../'1=z'"lp;..;lc,c / 672 B ERVILLE ROAD }'j/ c-J/ NEWVILLE, PA 17241 .~ l~ Individual: ~UN tV~AK jJUP(L {~~ (Seal) 672~tOSERVILLE ROAD NEWVILLE, PA 17241 ..~, . Page 5 of 5 ....}r Security Agr~eme~t . 8 . Mellon Bank ~.. ,~.'II I" ,'" "~" " ',1"" :.''''illl~l~''. ".~ . ~ '.~ ~~~ " I, ~ ," .:~~'" . I ." .," '!I. i "'~' ",~;" _,'" .~, '. ~ I " ~II~ "oo'I~IM ~ , oj I ,t1~.. ~..." ".~" /"i.~ "~lt~, I ~,"'1 '., : ~". y" j. ,.' ^'II~~ ~'" ~fI;ta It" ,,'!'; iN \/, ~....', ; ,,'..... ..~ .~~ ~'" ,...I"~.~'..II".,,: ,..... ".....,.., . For value ~ived, and intending to be legally bound, in consideration of a loan or other credit accommodation in the amount of Three Hundred Ninetv Five Thousand and 00/100 Dollars ($ 395,000.00 ) made by Mellon Bank. N.A. ("Bank") to SANG HO KWAK, INDIVIDUALLY AND D/B/A:iONG'S FOOD MA~KRVD SAY- SUPERMARKET "'7 YON HW l{W1',T{ ("Borrower(s)"), said obligation evidenced by a PROMISSORY NOTE dated ~S--;;;"fJ. '1';/ , (the "Note") Undersigned, intending to be legally bound, hereby agrees as follows: 1. Security Interest Undersigned hereby grants to Bank a security interest in the following property now owned or hereafter acquired by Undersigned: (Certain terms used herein are defined in Section 13 below.) Iil C:l~ V /6.) aU equipment, wherever located, including mac~, m{,t~r vehicles, furniture and fixtures; Iil c./ ~.f;1l inventory (whether held for sale or lease or to be 1Ufuis~ed under contracts of service), raw materials, work in process, and materials used or consumed in the conduct of Undersigned's business, and all books, records, invoices or other documents which describe or evidence the same; Iil <:"'~ Y~ll accounts, contract rights, general intangibles, chart~r, chases in action, instruments, documents (including all documents of title and warehouse receipts) and all rights to the payment of money, however evidenced or arising; o (d) all securities; all cash, stock or other dividends or distributions paid upon or made in respect of such securities in any form; all securities received in addition to or in exchange for such securities; and all subscription rights incident to such securities; o (e) all farm products; and o (f) all property or rights described below under the caption "Description of Collateral." Description of Collateral (Give a sufficiently detailed description to identify each item). In addition to the foregoing, Undersigned: (1) grants to Bank a security interest in all accessions, parts, accessories, attachments and appurtenances in any way used with, attached or related to, or installed in, or intended to be so used, attached, related to or installed in, any equipment or inventory constituting "Collateral" hereunder; (2) grants to Bank a security interest in all substitutions for, renewals of, improvements, replacements and additions to, and the products and proceeds (cash and non-cash) of all of the foregoing property and any insurance policies relating thereto; (3) grants to Bank a security interest in, lien upon, and right of setoff against, all deposit accounts, credits, securities, moneys or other property of Undersigned which may at any time be in the possession of, delivered to or owed by Bank, including any proceeds or returned or unearned premiums of insurance. and the proceeds (cash and non-cash) of all the foregoing property; and (4) assigns to Bank all moneys which may become payable on any policy of insurance required to be maintained under this Agreement, including any returned or unearned premiums. All such property subject to Bank's security interests described in this Section 1 is referred to herein collectively as the "Collateral." With respect to Section 4 hereunder, the term "Collateral" shall not include the property described in Subsection (3) of this Section 1. All security interests in Collateral shall be deemed to arise and be perfected under and governed by the Uniform Commercial Code, except to the extent that such law does not apply to certain types of transactions or Collateral, in which case applicable law shall govern. 2. Obligations Secured. The Collateral shall secure the following obligations ("Obligation(s)"): (a) all amounts at any time owing or payable under the Note, and any other indebtedness, liability or obligation of Borrower( s) or of Undersigned to Bank, now existing or Page 1 of 4 hereafter incurred, whether direct or indirect, absolute or contingent, individual, joint or several, now due or to become due, and whether owed as drawer, maker, endorser, guarantor, surety or otherwise; (b) all costs and expenses incurred by Bank in the collection of the same; and (c) all future advances made by Bank for taxes, levies, insurance, and repairs to or maintenance of the Collateral. Provided, however, the interests assigned hereby shall not secure any obligation (other than the Obligation evidenced by the Note) which is defined as "consumer credit" by Federal Reserve Board Regulation Z, 12 c.F.R.f226.1 et seq., and is not exempted from the application of that Regulation. 3. Representations. Undersigned hereby makes the following representations and warranties which shall be true and correct on the date of this Agreement and shall continue to be true and correct at the time of the creation of any Obligation secured hereby and until the Obligations secured hereby shall have been paid in full: (a) Undersigned's residence and/or Chief Executive Office, as the case may be, is as stated below or as otherwise stated in a subsequent written notice delivered to Bank pursuant to the terms hereof, (b) Undersigned has good and marketable' title to the Collateral subject to no security interest, lien or encumbrance, except as indicated to the contrary to Bank in writing prior to the execution of this Agreement; and (c) if any of the Undersigned is an individual, each such individual is at least 18 years of age and under no legal disability or incapacity. 4. Covenants. Undersigned covenants and agrees that until the Obligations secured hereby have been paid in full Undersigned shall: (a) not permit the use of the Collateral for any illegal purposes; (b) promptly notify Bank in writing of any change in its or their residence or Chief Executive Office; (c) not permit removal of any of the Collateral from county to county or state to state unless Bank has given written consent in advance; (d) maintain at all times good and marketable title to all Collateral, free and clear of any security interest, lien or encumbrance (except as to which Bank may grant its prior written consent pursuant to Section 4 (e) below), and defend such title against the claims and demands of all persons; (e) not (1) affix the Collateral or permit the Collateral to be affixed to real estate or to any other goods, (2) lease, mortgage, pledge or encumber the Collateral, (3) permit the Collateral's identity to be lost (4) permit the Collateral to be levied upon or attached under any legal process, (5) permit or cause any security interest or lien to arise with respect to the Collateral (other than those created in this Agreement), or (6) except Collateral customarily sold by Undersigned in the ordinary course of business and so sold in such manner for full value, sell, consign, part with possession of, or otherwise dispose of the Collateral or any rights therein, except as Bank may grant its prior specific written consent with respect to acts or events specified in Subsections (1), (2), (5) or (6) hereof; (f) maintain the Collateral in good condition and repair, excepting only reasonable wear and tear; pay and discharge all taxes and other levies on the Collateral. As well as the costs of repair and maintenance thereof; and furnish to Bank upon request documentary proof of payment of such taxes, levies and costs; (g) purchase and maintain policies of insurance (including flood insurance) to protect the Collateral or other property against such risks and casualties, and in such amounts, as shall be required by Bank and/or applicable law, which policies shall (1) be in form and substance satisfactory to Bank, (2) at Bank's option, designate Bank as loss payee and/or as additional insured, and/or contain a lender's loss payable endorsement, and (3) be (or certificates evidencing same shall be) deposited with Bank; (h) execute, upon demand by Bank, any financing statements or other documents which Bank may deem necessary to perfect or maintain perfection of the security interest(s) created in this Agreement and pay, upon demand by Bank, (1) all costs and fees pertaining to the filing of any financing, continuation or termination statements, mortgages, satisfaction pieces, judgments and any other type of document which Bank deems necessary or desirable to be filed with regard to the Collateral, and (2) all costs and expenses incurred by Bank in connection with the Collateral (including without limitation all advances made by Bank for taxes, levies, insurance, repairs to or maintenance of the Collateral, appraisal or valuation of said collateral, and determination and monitoring of flood hazard status); (i) procure, and cause a statement of Bank's security interest to be noted on, any certificate of title issued or required by law to be issued with respect to any motor vehicle constituting part of the Collateral, and cause any such certificate to be delivered to Bank within 10 days from the later of the date of this Agreement or the date of the issuance of such certificate; (j) pay, upon demand by Bank, all amounts incurred by Bank in connection with any action or proceeding taken or commenced by Bank to enforce this Agreement or protect, insure or realize upon the Collateral, including attorney's fees equal to the lesser of (a) 20% of the amount of the Obligations secured hereby then due or $500.00, whichever is greater, or (b) the maximum amount permitted by law, and attorney's costS and aU costs of legal proceedings; (k) reimburse Bank on demand for any advances made by it for payment of (1) premiums to insure the Collateral, or (2) taxes, levies or costs, together with interest thereon at the highest rate allowed by law; and (1) immediately notify Bank if any of Undersigned's accounts arise out of contracts with the United States or any department, agency or instrumentality thereof, and execute any instruments and take any steps required by Bank in order that all moneys due and to become due under any such contracts shall be assigned to Bank and notice thereof given to the United States under the Federal Assignment of Oairns Act. 5. Events of Default. The occurrence of any of the following shall constitute an "Event of Default" hereunder: (a) default (i) in the performance of any covenant hereunder or (ii) under any other instrument or document evidencing or securing the Obligations; (b) any warranty, representation or statement made or furnished to Bank by or on behalf of the Undersigned proving to have been false in any material respect when made or furnished; (c) loss, theft, substantial damage, destruction, sale or encumbrance to or of any of the Collateral, or the making of any levy, seizure or attachment thereof or thereon; or (d) death, dissolution, termination of existence, insolvency or business failure of the Undersigned, appointment of a receiver for Undersigned or any part of the Collateral, assignment for the benefit of creditors or the commencement of any proceeding under any bankruptcy or insolvency law by or against the Undersigned. 6. Remedies of Bank. Upon the occurrence of any Event of Default: (a) Undersigned shall, upon demand by Bank, assemble the Collateral and promptly make it available to Bank at any place designated by Bank which is reasonably convenient to both parties; (b) Bank may immediately and without demand exercise any of its rights and remedies granted herein, under applicable law, or which it may otherwise have, against the Undersigned, the Collateral, or otherwise; and (c) Bank may, without notice or process of any sort, peaceably enter any premises where any Collateral is located and take possession, retain and dispose of such Collateral and all property located in or upon it. Bank shall have no obligation to return any such property not constituting Collateral unless Bank actually receives Undersigned's written request therefor specifically describing such property within 72 hours after repossession thereof. 7. Bank's Rights. Undersigned hereby authorizes Bank, and Bank shall have the continuing right, at its sole option and discretion, to: (a) do anything which Undersigned is required but fails to do hereunder, and in particular Bank may, if Undersigned fails to do so, (1) insure or take any reasonable steps to protect the Collateral, (2) pay all taxes, levies, expenses and costs arising with respect to the Collateral, or (3) pay any premiums payable on any policy of insurance required to be obtained or maintained hereunder; (b) direct any insurer to make payment of any insurance proceeds, including any returned or unearned premiums, directly to Bank, and apply such moneys to any Obligations evidenced or secured hereby in such order or fashion as Bank may elect; and (c) inspect the Collateral at any reasonable time. PllOP ? nf .d. In addition to the rights given to Bank in this Agreement, Bank shall have all the rights and remedies of a secured party under any applicable law, including without limitation, the Uniform Commercial Code. 8. Additional Representations. In addition to the representations and warranties set forth elsewhere in this Agreement, Undersigned hereby makes the following representations and warranties which shall be true and correct on the date of this Agreement and shal1 continue to be true and correct at the time of any borrowing under any line of credit with Bank and until the Obligations secured by this Agreement shall have been paid in full: (a) each account: (1) represents an amount actually owing to Undersigned by the account debtor (less discounts allowed for prompt payment); (2) is valid and enforceable according to Its terms without further performance of any kind; (3) is not evidenced by any instrument or chattel paper unless the original of such instrument or chattel paper has been deposited with Bank; and (4) is not evidenced by any judgment unless such judgment has been assigned of record to Bank; and (b) the locations of al1 of Undersigned's places of business are as stated below, and the inventory and records of the accounts are kept at the places indicated below. 9. Additional Covenants. In addition to the covenants set forth elsewhere in this Agreement, Undersigned covenants and agrees that until the Obligations secured by this Agreement have been paid in full Undersigned shall: (a) immediately notify Bank in writing in the event that any of the following occurs: (1) any account is or- becomes entitled or eligible for discount for prompt payment; (2) any account debtor has or may have any defense to payment of, or right of setoff, counterclaim, or recoupment against any account; (3) any account represents an amount which is disputed by the aerount debtor or the payment of which is in any way contingent or conditional; or (4) the desirability, usefulness, or marketability of any of the inventory has been in any way reduced or impaired by reason of physical deterioration, technical obsolescence, or otherwise; (b) keep accurate and complete books and records in accordance with generally accepted accounting principles and. at Undersigned's expense. promptly furnish Bank such information and documents relating to the Collateral at such times and in such form and detail as Bank may request, including without limitation: (1) copies of invoices or other evidence of Undersigned's accounts and schedules showing the aging, identification, reconciliation, and col1ection thereof; (2) evidence of shipment and receipt of goods and the performance of services or obligations covered by accounts; and (3) reports as to Undersigned's inventory and purchases, sales, damage, or loss thereof; all of the foregoing to be certified by authorized officers or other employees of Undersigned; (c) not change any location listed below regarding places of business, inventory and records of accounts without Bank's prior written consent; (d) at Undersigned's expense. diligently collect the accounts on behalf of Bank until such time as Bank exercises its right to directly collect the accounts, and upon notice from Bank. deliver all proceeds of accounts to Bank forthwith upon receipt. in the original form in which received; (e) immediately upon Bank's request, open a cash collateral account ("Cash Collateral account") at Bank and deposit therein all cash proceeds of collections on the accounts; (f) immediately upon Bank's request, give the Bank assignments, in form acceptable to Bank, of specific accounts or groups of accounts and specific general intangibles, and immediately repay the amount loaned against any account so assigned to the Bank if the contract with the account debtor is breached, cancelled or terminated; (g) immediately upon Bank's request, furnish Bank with all information received by Undersigned regarding the financial condition of any account debtor. except to the extent prohibited by law; (h) immediately deliver to Bank all instruments. documents or chattel paper representing any of the Collateral and immediately assign of record to Bank any judgment representing any account constituting Col1ateral; and (i) immediately upon Bank's request, mark its records evidencing its accounts in a manner satisfactory to Bank so as to show which accounts have been assigned to Bank. 10. Additional Rights of Bank. In addition to the Bank's rights set forth elsewhere in this Agreement, Undersigned hereby authorizes Bank, and Bank shalt have the continuing rights at any time, whether or not any default has occurred under this Agreement, and at its sole option and discretion, without notice, to: (a) take over and collect any or all of the accounts and to take any other action pursuant to its power of attorney granted herein; (b) exercise absolute and exclusive dominion and control over al1 funds deposited in the Cash ColIateral account; apply any funds therein against any Obligations; and charge to any deposit account ot Undersigned any Item ot payment credited to the Cash ColIateral account which is subsequently dishonored; (c) at any reasonable time, through its authorized agents and employees, inspect, audit, and verify the accounts and the inventory, review Undersigned's books and records, and copy or make excerpts from any document; and (d) verify accounts with debtors in the name of Undersigned, Bank, or Bank's designee. 11. Miscellaneous Provisions. (a) Undersigned waives protest of all commercial paper at any time held by Bank on which Undersigned is in any way liable, notice of nonpayment at maturity of any and all accounts. and (except where requested hereby) notice of action taken by Bank; and hereby ratifies and confirms whatever Bank may do. The rights and remedies of Bank hereunder are cumulative. Bank shall be entitled to exercise any right notwithstanding any prior exercise, failure to exercise or delay in exercising any such right. (b) If any provision hereof shall for any reason be held invalid or unenforceable, no other provision shall be affected thereby, and this Agreement shall be construed as if the invalid or unenforceable provision had never been a part of it. The descriptive headings of this Agreement are for convenience only and shall not in any way affect the meaning or construction of any provision hereof. (c) The rights and privileges of Bank contained in this Agreement shall inure to the benefit of its successors and assigns, and the duties of Undersigned shall bind all heirs, personal representatives. successors and assigns. (d) No modification of this Agreement, nor any waiver of any provision hereof, shall be effective or enforceable unless set forth in writing and signed by an officer of Bank. (e) This Agreement shall in all respects be governed by the laws of the state where the Obligations are payable as reflected in the document(s) evidencing such Obligations (except to the extent that federal law governs), and all references to the Uniform Commercial Code shalI be deemed to refer to the Uniform Commercial Code as enacted in such state. (f) Undersigned hereby irrevocably appoints Bank and each holder hereof as Undersigned's attorney-in-fact to: (1) endorse Undersigned's name to any draft or check which may be payable to Undersigned in order to collect the proceeds of any. insurance or any returned or unearned premiums in respect of any policies of insurance required to be maintained hereunder; and (2) take any action Bank deems necessary to perfect or maintain perfection of any security interest granted to Bank herein, including executing any document on Undersigned's behalf. (g) Undersigned shall bear the risk of loss of. damage to, or destruction of the Collateral, and Undersigned hereby releases Bank from all claims for loss or damage to the ColIateral caused by any act or omission on the part of Bank, except for willful misconduct. (h) The prolhpt and faithful performance of all of Undersigned's Obligations hereunder, including without limitation, time of payment, is of the essence of this Agreement. (i) Copies or reproductions of this document or of any financing statem~nt may be filed as a financing statement. 12. Additional Power of Attorney. In addition to the powers of attorney granted to Bank by Undersigned elsewhere in this Agreement. Undersigned hereby appoints Bank and its officers, Page 3 of 4 employees and agents as its irrevocable, true and lawful attorneys in fact with all necessary power and authority to: (a) endorse Undersigned's name on all media of payment delivered to Bank or deposited in the Cash Collateral account; (b) notify Undersigned's account debtors of the assignment of their debts and direct them to make all payments thereon to Bank; (c) in Bank's name or in the name of Undersigned, demand, sue for, collect, compromise, settle, and give releases from any account; and (d) take such other action as Bank may deem appropriate for any such purpose. In exercising its rights under this section, Bank shall have no liability to Undersigned except for willful misconduct. 13. Definitions. As used herein: (a) "account," "chattel paper," "contract right," "document," "instrument" and "inventory" have the same respective meanings given to those terms in the Uniform Commercial Code; (b) "Chief Executive Office" means the place from which the main part of the business operations of an entity is Signatures \\IlIlC~ lh~ lIuc CXc\;UllUIl bcr~llhJS ,,,"tj' . x Witness: Locations of inventory: Rn 3 BOX 672 NF.WVTT.T.F., PA 17241 LZ-Ol2S Rev.(10196) LC. 9196 ill 9196 0275 p 166~.3823 1 LZOl25 (02) 052799,1605 managed; (c) "general intangibles" has the meaning given to 'thft term in the Uniform Commercial Code, including without limitation, customer lists, books and records (including without limitation, all correspondence, files, tapes, cards, book entries, computer runs, computer programs and other papers and documents, whether in the possession or control of Undersigned or any computer service bureau), rights in franchises and sales contracts, patents, copyrights, trademarks, log~ goodwill, trade names, label designs, royalties, brand names, plans, blueprints, inventions, patterns, trade secrets, licenses, jigs, dies, molds and formulas; and (d) "Undersigned" refers individually and collectively to all makers of this Agreement, including, in the case of any partnership, all general partners of such partnership individually and collectively, whether or not such partners sign below. Undersigned shall each be jointly and severally bound by the terms hereof, and with respect to any partnership executing this Agreement, each general partner shall be bound hereby both in such general partner's individual and partnership capacities. ""l ui I~~:" , J~ V -~~~ ../~ /U~(Seal) indiviqaa y and d/b/a YOUNG /S DMARKET RD 3 a 672 NEWV E, PA 17241 Locations ofreeords concerning the accounts: RD 3 BOX 672 NF.WVTT.T,'Ii!, PA 17241 Page 4 of 4 s,....ny..."'...- Cdllc:cl:if.Pfli.,.IlII:): till (""""OlIIylrdeoltal)l'IDIl\lOltOClklDllolt:ftluukO-. [] nnDII"DcbroI"lIlIII"Sa:u=1'1nt'_"I..aoa:" J~~~nJ.faI~..":.~ If._.....:'*= n...~-.... ....'__L..._ .ood'lDa<<.'~. __ _ .....-- .....- C-a/JplaptWk1a(..))- " .:. '.'... . C 'J'Ilo1aa."Dcbtal".1ld __J'any"_""" ~ ....~..~. ..OcnplpooioCD<'IO..........""_.. ',..,', '"'. C tlcbror..'1nao.ioiaJ U\mlV- 3 b.1II p:xoo&......_..........-a.e ~ ...,,.: . . SECUtiDPAa'tl'SlC/(A.'IURX(S) ~C _1OC1/Ic1k(~ali~'~)N~""_ tw. _ ..1Ilool-... -..b> a.ScI:.....r~~ 11;I 01. Cl -...~......... eI. -... ...v...:Jh(tAdlullac qlI aIld ta.).' ~._$y~,,,,,,,,",(~.,picllo'\llc~..))- dac.allscad4ltalood.o.dOll-.. ' dlc~raoI-.1C ..C:c\~='~eI._C,w..w,""""""fCc- ~~ r~,~ W172f.l' .-, '1, Il. 0 1ot",1IIIIda1lle IIIla& 11M rop.c. ~ lll: ...... _ "'Cdltd:CllIC) [] Demo OIolarll/lP. c....ltaIlr.lIlojoo:I....-..d.,ia&cn:ll.IA_-..,.. Ilh&<(.) /be adea':"WD'. :"'.',::.:., Pc.aao,kala- eo....",. u.w....p.....n'~~..-~ "-'.,..;,,; o """" IIoc: ClOIIaknI.... -... 10 ..... """"I)<. C DcxzibaI.....I\&ScIidomI'...... C......dre DcII...... ....,J~.,p_.rb__mowd /lo_.r~_ C~ oo.b'lf""tIclli<<"'u"'ca.Ste(~ mdUo_oq.. ..' ".." '.':!~=' ~.:.-. d. oI&ady...\~I...lOO:III:IcylalCtcnla _lIIuJ...wJaIoa-. DEIl'tOkSJcau.:~, ~ " []uoha "'" ..ua....,_...-..f ... ~ O_....JW.lAI'..........__k>I'CIMI)1_l:L ~7 ~~lWlC " . '-."-' ' r:.[] ...IUQIo .-...sa al'W:calI&unIdC5C1lbalIa~P.'" ~G;; 'lDI'~~~ . ,.:.. . m.m.... ...,,!ll<sa-=rityilut:ra< -~\>\lIl7 ~ (oIoo4sodbe "" T l"-*iA bIc>dI:,.I(~ ~lh _ ~ """.... aoIcquar.eJr cloalb<d...1IIc ~ III\&AAaJ"'feIIIaI). _r_~~~f4 ~lIin:oIooalyl(1Io(~)" .boy.~ Iofl.lDI 0~~' sr~1'CKN,J'QJtX.A.lJCC.l pl&o.:Ii") ~ tfs.......,.oIc:-.-J1i o(rn...... a..ZI.2~LC.UIJSUll/9G a.m B~T.':.'4I& '" 10-20-'04 11:22 FROM- rA~t1&"i od.~ ..""'(Jut..-c GD>j{iAdloldlW) &Ad .,..u..,.ddrac:: .' :~:SA~;tltJ ~~/ ~... .~ ',o:i:iOX"~~.1.~..~';~:~'.~ .lI€WtLll', r~ ,~, DcbIa<' _ (Ia<l nalll' am It iMMlIIW) anlt ~ili., addrcs: 'IltUWC;'( I'aXl IWlCET ~O] 1lCl(~""''''' NelNllLE,." 17241 J)ob.... ....... (I... n..... (".rat It i1Id.oiduel) ..d _iUrtt ~ ~rll11(loo) 1lIolII<:(>)(botllfGlcGa1iC1Dd-.",,,..I)- 04d.-I<<....eurll,\' ~.ltltDnDaa1oa: ""Uan 'ank, ~". _,...... ._.... t.-. Co"c.r _ lid \c.n ...... c..,<.~. .11I_ 1~ I- 1210 P'intl;urgh. PA 15'258-""01 2- ~o) "'-"'urt IIAIIl"(.J 0-<'''1110 tlnlll'iad~ _ _ focll:dld<yltl_lnll>nllI!laA. 1-442 P05/11 U-170 FINANaNC ST~DfENr VIli(qna~'" c::.&,E_ VCC,1 I..,~ ':l h JMl"01tUItt-I'l_rIl1C1Wtrucdau I~ ~l'\lftdl"W...........plotiaft rw..eN... (IWII~ llyaulltofti=O::~,-'io: ~ ~~{,~pod ~ ~a~ :":.~!;:'D~;l, i:li" DEEDS ;.:::~.lS:. ;{!..AtJO COUNT~ - PA 1 10 '97 JUH 26 AI'IIO S1 :9411) ., ,. _ $ "DIll ~1I111_ "~l<<lIIlA~'punWllltk>.lIaili>rmCl:lmml:rcia' c:..dc. IDd luo K1ilrd"lllh CIle (clod: .,pIlable~" o ~oC~~'" o l'tollloao\>ly Q( Ill! <al_~oCNUI~RI~ Ib H.....woJA4dltlo.wSJ-.. l'Ir.m . Op1"-111~IdonU/lra"'1I ~]O~ctcp): COLU'fERAL Uoallly~ l!1 iIr:oa oadI<ot~ .IU. lI.elITOl'S lIGHT, TITLE. .ua IWTEaen. l/Iffl'lIEJ !It/'J IIR 1El/El.fTE2 EX'STIICG III Ac:IlUlltEII. III _ TO All 1I1\IEIITIlRY UKCUDllIC IETU_WEIl OIl lfl'Q$$iSUIl GCDlS). aa:tWTS. llPE~ ACCQM'S. GElIWl I_TAIIGlllEr. ~Ilf$. PlAna 'If<<. IMS1l\J4.EMTS. kOTES, DWTS. LfTTRS CIlt AlIYlas Of CIOn. tECE'''~U:S. OTlltl AilcIJNTS IN,." TO DE8TClII. ,F1lmJaU, NlIIIIYlIll& #Jlo IQlJlPlIIl/T, ~l HCDUCT! &110 CASK ~ lII:llI'c:.I$lI ..oczca. UlIClllCllM IIl~CI! P<<o"res ... 'llUQn ClI' TIE ~~DlIfG ... ALl. CUI.lA~TIU. Cl.AJN. IICllTI, 8EIlEDlEI AID .arvrU:lIl!t ULATIIIII Tllum, Cou"*1- ~11. , 7 8 2a , 10 1~ JlSIURNllSODPT'IO: Mellan lant, "'" ""nes:s I:>nt.fqj LaM Cent..;. ',0. lu 3CIllII 'lcc~bc.rgh. ... t$2JQ.SlIJO Attll: Coll.t.,_l &Mlt II "\4" .......'..' I....... .. ~ '. u :-.'~' . . '.It i. _: ~ .:: \ ~i : ..rill _to' .'.>1 . -:;~ ~! 4( f;... '~7;) . . .---." J :" ~ :. . u O1l:tGINAI. cot'r Za.2l2l!'11 -'.- :. '.. ',; ..... ~. .. 10-20-'04 11:23 FHOM- 'j"-44Z PH6/11 U-17B '- . -1-E? :. - . . .. ,: !.cfDS .tJl-iiH:n.LAtlll cou"YY-PIo "02 tiPR 5 (1ft 11 02 UCC ANANCING STATEMENT AM. ENDMENT L7 -i;t:;;.~ ~~~..._...-..~ Jl//~~ ~~ .. ~""4""'NE DFCcooTl\CT I>T FUR ~ ~ .. ...o4O~C_lO: __-.. tit"... I"" fit '_'1'1.....10 :~~":: ='11\1 1.- t........ .. notall'llI. ,. lSZ3l1-3D.!ll .t..... "'1I_ut'.' !tile -n,e.o.9O\lfJ~I5FQ11I'1\.l1'1G~use""",, ...~--,..._- . - I~::="::----=--" - . Y'~afJK_ ~67~ ~~~_Q7'. . . .. Cl~-~--..--_"___.__",__""_,,,,__ ... ~-~..~_......-...._..__...._......_--_. ...............--............~..... '. .. O..-i ...-_ ~-"_"""".~__"",,,_,"_......._..._...:-.._.. .. ----.....~-l:Jr:>oo_.O'_,....._ -"'0.-- --IlI........--a---.._._7. 0--------..----.;__- c-- --- 0-_.....-."."'..__ ....".......,............t.......,........_~...........k ...__ ~....... _~c _~.....'ftI4'............ ..~--- ...--- "" JOifA.K.'~ 1i0. .. ~.."",_c yQOtallO"S I'COO !IlUZD:t' f. __...,lIIl__ .....---- \-- ,..... I~~.... 011 __ ..-...&.'S""'-_ '. r.J: '....; ..;n_ loIiI:'!'l- ft :1 :_ -' I-CIlPf. Pllo.-.,.l1.1241< . ,~......., .' /._~ -- Ie. _-'" ~ . JlI) 'h:J B?: Ei'l2 .REWltn.tE ..._-._aallor I~:~ I"'-"'~ ft.~o1o.a-:..- ,----.....I!ll- .,. -- 0-- 0--.,..- O-_____Q_ .~ \&, 0-" ~ ._..~...' r . . ~ .. .,....1;. .. .........tm::UICl......" ~~,.. ~ .................................. ...........:..-........... .~__ .....-........._.........,~. fII~.... .~........... ........e.w... 0 .......__.~ ...........~ ...--~- ll" elth_ Iri ~ ,-,,_it ... -'-'- ......fna.a I..tI1tCf'l ....... c:.;.c~ ...... #.~ .;... ....- 1"....-.. . .' .I~~.._ I....~.. .. _"'-tfl_............llI. 21.5 ' . JIOQ ~~ l,Uo.ll.....~.....u:.....IJJ~ ~nOM.Ol. UCX: ~CII<lG sr"TEM~ ~ 11'0"'" ~ f\e", 1I7_ It.. . ="'t~. . ""......,." t~..'na. ". ..,...' , . ...........-- ... -Ii...',. "h ~ --....{..:;~;:. . ~l :. Oc~-20-2004 08:32am . 'PARTIfS .. . ~btll~ name (last name arM Ie individuo1) and mallin, .dd= .' '~AK, SP.N: "0 RP 3 !lOX 3tt\ (. '7 ~ ,NEWVILLE, PA 11'241 Dcbla~ l\lWlC (!ll&I. name t'Il"'t if indm4ual) 1114 JUlIilin; .dd~ YDUlIG'S Fooo KAlOOiT lID 3 BOX ~ "',~ NEWILL!!, Pol 17241 Debtor name: (Jut name ril1t If Individual) lad lnIliling ~dx'aw: 8oe1lftd PG11(lw) namc(;) (Wt D8mC fiIJI !C.Indivi4ua1) aad uddraa lor lICCIItity IIIlUC8t iuro~tIoa: Mellon Bank, M.A. .~fnooo lIaillr;in; loan Co:nter ~ Mellon aank ccnter6 Rm. 1S'-1~70 Pltt&burQ/l, PI. 152Sa-O 01 2- ~.) ofStcaHd. P~ ~af(I:WDllmc flrslIClnc1lvld\lal) ~ Iddtaa roc ICCIIdty 1nlc:R:5C Inlonnation. Spcdal'l)puall"lIl'iId (cbctX fr applicable): o The lema "Pc:bIar" and "Scc\Ired 1'1ftt" Ill.Wl ~ aIIll "[.cs,ar,- R&pcaM:lt. C ne tetm& "Dcbccx" &lid "$ccul'Cd Patty" llIean "ConIi;pec;" pel "CoaIfanor." zapc:ctivdy. C DdK<< /lI.Il Tn\DmIlUiar; Ulllity. s~~ PARTYSIGNATURE(S) TIak .tdcmall" SSW ~(h: ouJ.y the ~un4 Parlflllr;mlCwe to perfect. ~l)' iutaatln c:alIa~ (dlceklp(llialb1c boz(ec))- ~~<::~ .{:j; - - ,'T~7Z9' '.0021008 F-210 t1NANC1NUb-i~.r~ UnlCoJ:1ll Commen:ial Code Forni UCCI I' A ~ J, IMPORTANT - Please read I.nsttucIions 1!J.1 t7 . dlreruU,btrorerompletjn~ . F~No. (Stlllllpo:! by filing olflCCP):: ~'Ltat. ~ ~~~ (1Imnpc:d ~ filio& ott:ice": :..: ....'F il:-:~~""'"'I'; OEED~ ...... 'l". -;...' v.:~ ~ "" ::i' !.l:;;;:lLAt(O COUNTY - flA 1 II 9-l17) .9" JUH2~~ _~~ 10 ~1 5 .ilu. F~ SlAldUCLI. iii pacnlCCl tor IilinC'puDUIIDl io UIc Uaiform eoiniDerdal ~.1Id ia 10 'be fi)cchrilh the (c:btlctapPlleableboa:~ [J Secrclal)'oC1heCam~th. ': ; 0:". "Y. o 1'rothonowyot. " ,.... . IXI real ~ (C.CO\."d,o otctJlBERLAJ(p . . .[. , . '.10 ~.~ Ib Num~lDtA4dll'onQ1S~b (lCaay): 't. ~1.. ~:'~~ _ Optlo\SldBpcclaJ llfenlltlc.1Io1I (Max. \O~~'):. COLI..A.'I'ERAL~'.... .: ';'. . . . . - ~"'~.;"o.'IJA: IlkaW'y co~rltl by ltclllllACJ.W type;: ,,A' )::!~ ::. Y .f., AlL oalM'S IttGHT. nTle. AHD INTERES'r{ \lItl!'l'Hell NOU CR HERnFTER ~ISTJNG OR ACOUIIlED, .111 AIlO TO.ALl INVENTORY (INCUlDING lEltJRNED Qlt REPOS$E$$El) COClOS)!~ Accoulln, Cl'EIl ACCOOKTS, GENEIVII.. IIITAlIGI8LES. <l)OC\JI4EIIlli;.t.alAfTEL PA.PER. INSTlWHElITS, WOlES. DRAnS, WTERS OR AOVICES Of CREDIT. RECEIVAB~,- oll1ER .uIClJlITS OIIIIlG TO !laTOR. FIXTURES. FURMITl$E AIlU EQlJII'MEllr. ALL ~~.ClD\JCTS ANllCASH AND NOM-CA.$K PRQCEEl)$ (1NCunIKG JIlSURAllCE, POLICIES AIlO PROCEEDS) OF TilE fQRliCOJlfc; IJID AllGUARAIITIE$, CLAIMS, RIGHTS. ItEMallES AND PRtvJt.EGES'.~~Tl,~~::~HEIl.ETO. :. '.' ,.1 ~ ~~ . - r. '-.' 2a Collnty. CoUllly. 6 1 8 m (clIc:ckORly it ~ J'roduas oldle col\lllem ~ aIoo covered.. l"caUJyft1a~%e8Icm.." IrappliCabi= ~~ia,OrlndU~ (dledtappropriar.:ld(ea))-. ;",,:,. -:-;:' a. [J ctopll p;uwiaior~bc~Oa- .;, " ." b.1il &OOdawltlctun:Ol'are(O~e,~~ ~7 D. 0 ~~ ot1hcIlU(\IId~olIan&ips)a.eaocledaa- cS. [J ~c'''''''nctu1Un&from uit:'~J.~;;ilrlhe IIkc (iQd.ucI1n, aaaDd 14') At IbewclDleadotllllncheadOQ -;. ':". ; ,i'l\~:".l' J ':.1. . r: 3 . .... ~...J,l.";' ORIGINAL COPY :l ~ (01) OG4m.osos Ibc rollowia& ccaI esllltc:: : ,;, _ .. [] a.c:."lllltecl attcncbaal:C or~... Idcal1~ or col'podlUtnlctmc RD 3 lOX 326 . . .' ot:theDeblor. ~AddNu: NEWILLE JIll 17241> . b. 0 as 10 which lbc DUnabalJlapNd. DMcriW ~ Dook;~ (chc:clt<ibe~:[J Dccd5 0 Mortpscs, Co aJtcadyallbjllcuo. SCQIill:y b1terest It\ _1Jurc:,,,mlJ In at Pate(s) u .. Cor CUKaER'AlIif;;'t;~~ :: l'caDarJ.'anle- County. UnIfQnuPucdldcaUIlet~" ':"w,"'~... o 1I-bell &ho c.o1\al.enl was m."c;l1O thla COWlt)'. 0 Oacribcd OIl Addlliadl Sbeet..;:'/ )~-.:.,~ [J ::. ~~~. t#1~ or J'llIccorb~_lI'llIlRoftd Name ot-=orol 0WDcl' (req11ktd.onl.Y ~jio ~~aa'lnicrest ofrcocxd): Ii. a1Rady lubJcet 10 a KCdlily Intc:ceat 10 lUIAthcr ,Juda.dtctJo.. - DEBTOR SiG~:U.~S) ~ o wilen UK "Ua"'..I...... _ved to PCIUI5)'lYaI\b. D~i): SAlle 110 K\IAK '/':~. ~ ~D~=..t=~':::.7===t <~, )~~~;~Q;f" :~.'" _ . OWTl~r u.'f'h1cbueCUDtyiw:crectwaapa:vloual)'.PetfectCid(abadaCrlbc: . 1a ~ . .."" " . ~ III bIock9,If purclwod 'With c:uh rrooeeds and lIot ",' . adcquat.:ly deterlbcl au \he orIalNlllinanaac ltateDWlt). Ib . , . ! s.cun:cI Pari,! Sta-tarc(.) REI'URN ReclW'TTO: (mqulted 01\11 Jr1iall(aa) " cbliCked a~)l . MeLLON BAHL.-LA. Helloo !lank. M.A. ;;..--: .." -, Business flank.ing \.011I1 ~ttr~. L~ .. P.o. Box 3080 . . ~;.? ~. U PltcIlburgh. PA 15230-'3080 ~./ ./ Attn: Coll.tar.' UnIt: " <I- ST.u(OARD FORK -I'ORMPA Ucc.l (Rd. 3,93) .I.ppnlwd by~..teo-oawWfIa 6fP""uylvaaia ClAJ21tcv.(1M)LC. u~U>~ OZTS JI Z-172U4& ,..f. .,...."t. . p. . .~~~...1f.) ..~.' '9 )' ~. if; ;J;....2.:~. ..... "',!~.' ,.; .~ :' .... . .,.,';,.~.tr: . - "\* ~ t 10 11 12 OcHO-2004 OS: S2am .. IT, - I r .. T~T29 P.OOS/OOS F-210 -:. " .. \..1:? ....~._..--::.,':'.. ,: r.c-cOS ,'HM9ER~.tHJ C"UNTY~PA · O~ f1P.R "g M 11 02 FO~ ~..-.... _ CIJIIli1'\/\J.Y -~ NAI.4E" PHONe at' QONTM:\" A'r I'll.l;a (QjI\t~1IaI) UCC FINANCING STATEMENT AMENDMENT - lYJ ~~ a. 'iEHQA~DG"eHTTOl ~ ~ Add_' ttthllNl 11M "I '~lv."I. 8\d;l\dS '~11l\J Lu" aIIur p.o. lax 3CaO '1 tUt:l.Jl'll", PI. 1S2JQ.3ClIlI .nl\: CaUncnl Un." . .- ,... ",""""-~Il',,t'III.IQ<<fft.E" THE ...~ SPAce IS fQA r:JUNG. OFf:lel: ~l: QNl Y \ ~P-.cHCI~"T'GIUll'~1o lI..lIlMtI9r~IIN-"'''''''' 'l~7n ~-1~-a," ....... . . " . MlLbTA1W~ . :L O~ ~tI...""-cttc~.....,... _;0*",-_"'__ _~"___"""'-""'I""T_~ '" 'It;~~"_~"'_~_"_"MoR'f~oC"~~~"'~___" . .. ~W""dd_PI'Io4-"""''''''-'-. .. .'.'~1".. '" (J~ ....~~ _~_""""'lo_"&""'ud__"'~llIl1t11'1r.~_""";'''__la''''''' &. ~!MC>>oIOll' 'MfY~ 1w.~....tJo.-~-;~.,,-. CIIodl_~.,__' __atll......-.........-I!l!t~-.....I~.....INI'JII4(..,. OQWIIU--- 1hI___"'1olK............._ O~fl&IHIlilolI'--' - tI AC{).~ 0..._-....,..."'" 1M _ fI_dIonttIlo_ tu'''' fIJ4J9r__"""'-"'" ...."" "'''_''' _...... ..,.,<1;_...... _''''I "U~ . ,- .. CUl</'$<<lCCf(l~ .... c,-.Hl.."rN."ll&o\C KWAlC, SANG no, Of' -. . I&. ~..U81'_ . t . ;;" ." . "~ '.: " - ;~:~~'j~; \~~ , ..1 _ ~ \~ 1C0tJNG. S FOOD MAIU(Et lllVlSl't&AMI -~'-;Ir~ 1. ~ ~ Clll..tOQaI~llC>>C: - - "" TL~~( CI'I 7&.~'SVliT_ FINT .w..c ~1Wn IiUl'fll( .\ " ~.IoOC.\IIDS . _ fU).U.:LllC)jC 672 7a. T,l,l[~,,"~1lM (~.,:. \'.. fYI't;()lI~llON .' . L ~~ lCQUATOI.lI..~1 ~ atIt Jl!llbaor. ~ IoIllowlf 0 _ II 0............-. 0 -~ -..p......*_mIluo... 0-.11-' '!. .ool' .. ..-"". em' mW'll'IL1.E 7t .lU~QlI'~1lON I'l'A'lli' 11'0(1'-"1.. CQIlE p~ . 17241 '" ~'llOIr~.'"" ~ V$A [IN:Jt4 ~'''''''.. ,)f-J ; r .....'"~40.~ I' ....i.i..t ........ :r ..' J. ,"....,,- .. .........._~.tIlfYtfI~~1tGNoI(:HI:lI./CIa"_.;-'9-.M.......-..-. ._~:'~___~.o._'M'loII __....._w-...a_...I_".T_~O'I.O'___"'" n .....__..a~__""....._ ~~_-NAi4 .. .' .... ,"_. .. 0" C{"lnna lank IIf hmlIy\~h l\I1Iil'lcSl I",'d"'ll laan CM\Ut'-- ......".. . . ... _"W1'_ . I 'NT":" ":;::l~IllI:'-' lSU1'''Jl( .,Cl- ~..u"NtIVlt~DA.YA 2'15 ~ ' _,~ aob CU~D LZ.Qf,1S k...~..alll..c..QI UJ WI WoTloW.t.. ucc i:wANCIN~ su. TeMEMT AMalOMl!NT lFORM ;"~Cb, (~: aimiMi 1111111 u ~II_'" I \.:1~\f.'1~IGI\ l~UQI.tJ,~ .... . .~,._ . ~, . '" .-. l' .... .:. ' :'~ -.,~ , .y ....~" I>'" ..-., L Detail report item #1 printed by: DOTTIE HOFFMAN on 2/22/01 ====r===========================4============================================== ~ PENNSYLVANIA Dee DETAIL REPORT DATA COVERAGE THROUGH FEB 05, 2001 SEARCH COMPLETEIl FEB 22, 2001 08:59 AM (CST) ~~===================================~===~===~~==================~============~ Filing Location: SECRETARY OF STATE OF PENNSYLVANIA 308 NORTH OFFICE BUILDING HARRISBURG, PA. 17105-8722 Original Filing Number: Original Filing Date: 26811373 06/23/1997 Collateral: FURNITURE AND FIXTURES HEREAFTER ACQUIRED PROPERTY INVENTORY MACHINERY AND EQUIPMENT OTHER Debtor: KWAK, SANG HO RD 3 BOX 672 NEWVILLE, PA. 17241-0000 Additional Debtor: YOUNG'S FOOD MARKET RD 3 BOX 672 NEWVILLE, PA. 17241-0000 Secured Party: MELLON BANK NA BUSINESS BANKING LOAN CENTER PGH, PA. 15258-0001 THE INFORMATION IN THIS REPORT IS PROVIDED IN CONFIDENCE SOLELY FOR YOUR USE IN EVALUATING ACTUAL OR CONTEMPLATED BUSINESS TRANSACTIONS INVOLVING THE BUSINESS ENTITY TO WHICH SUCH INFORMATION RELATES. NEITHER EXPERIAN NOR EXPERIAN'S SOURCES WARRANT THE ACCURACY, COMPLETENESS, CURRENTNESS, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OF SUCH INFORMATION. IN NO EVENT WILL EXPERIAN BE LIABLE FOR INDIRECT, INCIDENTAL, CONSEQUENTIAL OR SPECIAL DAMAGES RESULTING FROM THE USE OF SUCH INFORMATION. THE FOLLOWING DATA IS FOR INFORMATION PURPOSES ONLY AND IS NOT AN OFFICIAL RECORD. CERTIFIED COPIES MAY BE OBTAINED FROM THE PENNSYLVANIA DEPARTMENT OF STATE. VERIFICATION I, Joseph E. Sweeney, hereby certify that I am an Assistant Vice President of Citizens Bank of Pennsylvania I have the authority to make this verification on its behalf. I hereby verify that the factual averments contained in the foregoing complaint are true upon my personal knowledge or information and belief. I understand that this verification is made subject to the penalties of 18 Pa.C.S.A. ~ 4904 relating to unsworn falsification to authorities. ~~tQ sep, E. tSweene 637979.1 ..... () /'-.) :,' -: c:::) 0 c:::.., ..<:- -n -"; t', ) Z :Tl ,", c::> ..r_., -< tn:n (/I " "' 1',) ""rJr., -.,.... \.D :oC( , ..' 1 S:~; C) ) ;g ::-~:::p (, )....1 ).. '",,"() j urn ~-i Ul 1:; 0\ -< ,.! HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION BY: James T. Shoemaker, Esquire IDENTIFICATION NO. 63871 LAW OFFICES 600 THIRD AVENUE KINGSTON, PA 18704 (570) 287-3000 ATTORNEY FOR PLAINTIFF MELLON BANK, N.A., now by assignment CITIZENS BANK OF PENNSYLVANIA 8 West Market St. Wilkes-Barre, PA 18701, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. CNIL ACTION -- LAW REPLEVIN SANG HO KW AK, Individually and d/b/a Young's Food Market, and YON HWA KWAK 2208 Chatham Way Harrisburg, P A 1711 0, Defendants NO. 04 - 5958 CNIL TERM NOTICE OF HEARING FOR SEIZURE OF PROPERTY TO: Sang Ho Kwak, individually and d/b/a Young's Food Market 2208 Chatham Way Harrisburg, PA 17110 You are hereby notified that 1. Plaintiff has commenced an action of replevin and has filed a motion for writ of seizure of the property described in the complaint. A copy ofthe complaint, the motion for writ of seizure, the brief in support of motion for writ of seizure and the Court's Rule dated December 14, 2004 is attached to this notice. 2. There will be hearing on this motion for writ of seizure on January 3,2005 at 3:00 p.m., at the Cumberland County Courthouse, Carlisle, Pennsylvania, Court Room No.5. 644890.1 {' 3. You may appear in person or by a lawyer at the time and place set forth or file written objections setting forth your reasons why the property should not be: seized. 4. Your failure to appear at the hearing may result in the seizure ofthe property claimed by the plaintiff before a final decision in this case. Respectfully submitted, HOURIGAN, KLUGER & QUINN, P.C. BY: \/~ James T. Shoemaker, Esquire ID NO.: 63871 Counsel for the plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania 600 Third Avenue Kingston, PA 18704 (570) 287-3000 Telephone (570) 27-8005 Facsimile Dated: December 28, 2004 644890.1 :. i'\. (' ",' HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION BY: James T. Shoemaker, Esquire IDENTIFICATION NO. 63871 LAW OFFICES 600 THIRD AVENUE KINGSTON, PA 18704 (570\ 287-3000 MELLON BANK, N.A., now by assignment CITIZENS BANK OF PENNSYLVANIA 8 West Market St. Wilkes-Barre, PA 18701, ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. CIVIL ACTION -- LAW REPLEVIN SANG HO KW AK, Individually and d/b/a Young's Food Market, and YON HWAKWAK: 2208 Chatham Way Harrisburg, P A 1711 0, Defendants NO.04-sq~f C-<JiJ)-~ NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, Y9U 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 637973.1 :J' <:/; .': ~l. .~:. r1., ~'\~:f~ ;"""~~- I'~ ~: ~.~ :-~'::. :~~ ~~"~D :;; i ',:.~.' '.,':' . " -, ~.--} (, ':1 ~',9"'" ~ . ::"""'-' . ,/. ~'~J, ..f'G l.li..llN ~~~....: -i~J ~:t~:'.~'J -::5 ~.. f) ,~,_- . ~! f I~.~.: ~~~~~, P.i.. ___ nl~~'~c~.~$f~ (:rm.-W3fK~(!ry 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 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 ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. COURT ADMINISTRATOR Cumberland County Court House Carlisle, PA 17013 (717) 249-1133 -or- PENNSYL VANIA LAWYERS REFERRAL SERVICE P.O. Box 1086, 100 South Street Harrisburg, P A 17108 (pennsylvania residents phone: 1-800-692-7375; out-of-statle residents phone: 1-717-238-6715) HOURIGAN, KLUGER & QUINN, P.c. BY:~~ James T. Shoemaker, Esquire Counsel for the: plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania .)' 637973.1 HOURIGAN, KLUGER & QUINN ^ PRor[SSIONAl CORPORATION Al LAN M KLUGLh' RICHARD M GOLDBERG JOSEPH A I ACH RONALD V S^N10R^ JOSEPH E KLUGER JAMES T SHOEMAKER MICHAEL J KOWALSKI RICHARD M WILL!AMS JENNIFER l ROGERS ulTzr JL,Sl \'. i I~ tHJlNN jp ARTHUR l PICCONE RrtH^RD S RISHOP l)t\NH-L.l \)1$1^$IO DON/,Lf) C LlGORIO MICHELLE M. QUINN DAVID AIKENS, JR AMM'>lO^ V WRIGHT,KLUGER MICHAEL ^ LOMBARDO III LAW OFFICES ~,IJl TI 1 'vH) I !(d~lJl.'! fl GOO THIRD AVl:-NUE 434 LACKA\'\IANNf\ ^VLNIJf KINGSTON. PA 18704-5815 SCRANTON, PA 1 H'\d,J ~() III (~) "/0) J .1u t';; 1 -1 (570) 287-3000 FACSIMILE (570) 287-8005 E-MAIL: hkq@hkqpc.com FACSIMILE (f)70) ()(ll 50?? OF COUNSEL ROBERT C CORDARO ANDREW HOURIGAN. JR 1948-1978 Ext. 1126 Direct e-mail: ishoemaker(l2)hkqpc.com "ALSO MEMBER NJ BAR November 23,2004 Sang Ho Kwak, Individually and d/b/a Young's Food Market 2208 Chatham Way Harrisburg, PA 17110 Property Address: Account No.: Young's Food Market, RD 3 Box 672 Newville, PA 17241 0805386-0101 IMPORTANT NOTICE THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED }10R THAT PURPOSE. UNLESS YOU, WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS NOTICE, DISPUTE THE VALIDITY OF THE DEBT, IT WILL BE ASSUMED TO BE VALID. IF YOU NOTIFY THIS OFFICE IN WRITING WITHIN THIRTY (30) DAYS THAT THIS DEBT, OR ANY PORTION THEREOF IS DISPUTED, WE WILL OBTAIN AND FORWARD TO YOU A VERIFICATION OF THE DEBT OR THE JUDGMENT AGAINST YOU. WE WILL ALSO PROVIDE, UPON WRITTEN REQUEST WITHIN THIRTY (30) DAYS OF THE DATE OF THIS NOTICE, THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR. - Very truly yours, . ( . --_/~ '----', - ''---1~mes T. Shoemaker, Esquire ITS :je THIS NOTICE DOES NOT SUPERCEDE YOUR OBLIGATIONS UNDER THE FOREGOING NOTICE TO PLEAD 638028.2 . i' HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION BY: James T. Shoemaker, Esquire IDENTIFICATION NO. 63871 ATTORNEY FOR PLAINTIFF LAW OFFICES 600 THIRD AVENUE KINGSTON, PA 18704 (570) 287-3000 MELLON BANK, N.A., now by assignment CITIZENS BANK OF PENNSYLVANIA 8 West Market St. Wilkes-Barre, PA 18701, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. crVIL ACTION -- LAW REPLEVIN SANG HO KW AK, Individually and d/b/a Young's Food Market, and YON HWA KWAK: 2208 Chatham Way Harrisburg, P A 17110, Defendants NO. 2004 COMPLAINT The plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania (the "Bank"), by and through its counsel, Hourigan, Kluger & Quinn, P.c., complains of the defendant, Sang Ho Kwak, Individually and d/b/a Young's Food Market ("Mr. Kwak"), R.D. 3, Box 672, Newville, PA 17241, as follows: 63~Olg.1 "J 1. The Bank is a Pennsylvania state chartered bank conducting business in the Commonwealth of Pennsylvania, having an office located at 8 West Market Street, Wilkes-Barre. PA 18711-0101. 2. Mr. Kwak is an adult individual with a last known address of2208 Chatham Way, Harrisburg, P A 17110. 3. Upon information and belief, Yon Hwa Kwak is deceased. 4. On or about May 28, 1999, the Bank made a loan to Mr. Kwak, individually and d/b/a Say-Ford Supermarket and Yon Hwa Kwak (jointly, the "Kwaks"), in the amount of $395,000.00, as evidenced by a note, disclosure and security agreement (the "Note"). (A true and correct copy ofthe Note is attached hereto as Exhibit "A" and incorporated herein by reference.) 5. In order to induce the Bank to make the aforesaid loan, Mr. Kwak granted the Bank a security interest in , among other things, his equipment, machinery, motor vehicles, furniture, fixtures, inventory, accounts and contract rights (collectively, the "Collateral"), as evidenced by a security agreement (the "Security Agreement") and as protected by certain UCC-1 financial statements (the "UCC-I Financial Statements"). (A true and correct copy of the Security Agreement and the UCC-1 FinaIlcial Statements is attached hereto as Exhibit "B" and incorporated herein by reference.) 6. The Note was not assigned, except as stated above. 7. Mr. Kwak defaulted under the terms of the Note by failing to make monthly payments of principal and interest due under the Note. 638018.1 2 ), 8. The fair market value of the Collateral is unknown, but is believed to be less than the amount due and owing the Bank by the K waks under the Note. 9. The Bank believes and therefore avers that Mr. Kwak has possession ofthe Collateral. 10. Mr. Kwak has failed and refused, despite repeated demands by the Bank, to pay the balance due under the Note or to deliver possession of the Collateral to the Bank. 11. The balance of the Note as of October 26,2004 was $320,245.20, consisting of principal in the amount of$311,149.22, accrued interest in the amount of$8,512.74, and late charges in the amount of$583.24, exclusive of attorneys' fees and costs. WHEREFORE, the Bank demands judgment in replevin in favor ofthe Bank and against the Kwaks in the amount of $320,245.20, plus interest from October 26,2004, attorneys' fees and costs, and requests this Court to enter an Order directing the Prothonotary to issue a writ of possession to the Sheriff directing the Sheriff to seize the CollateraL Respectfully submitted, HOURIGAN, KLUGE~ & QUINN, P.c. BY: ~S _'- James T. Shoemaker, Esquire ID No.: 63871 Counsel for the plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania 600 Third A venue Kingston, P A 18704 Telephone (570) 287-3000 638018.1 3 .'~J. I '1i~1iii<J~'.'IV_I1Il![ $ 395,000.00 Promiso To Pay. FOR VALUE RECEIVED, and intending 10 be legally bound, Undersigned, as defined below, promises 10 pay to: Mellon Bank, N.A. ("Bank") or its order at Harrisburg, Pennsylvania Ihe sum of Three Hundred Ninety Five Thousand and 00/100 Dollars ($ 395,000.00 ), ~wilh interesl on the outstanding balance from the date of: this Promissory Note ("Note") at the rate(s) ("Contractual Rate(s)") and in acwrdancc with the repayment schedule specified belqw. Contractual Rate(s); Repayment Schedules. : o Interest at a rate per annum:which is % above Bank's Prime Rate, such rate to ch.~nge from time to time as of the effective date of each announccil change in such Prime Rate, shall be paid when principal paym,ents are due. Principal shall be paid in consecutive D,lOOthJy installments of S each, commencing bn , and continuing thereafter on the i day of each month with the balance of the indebtedness, if n~t sooner paid, due and payable on : , o Interest at a rate per annum which is % above the CD Rate, such rate to change tram time to time as of the effective date of each change in or r$tting of the CD Rate, shall be paid when principal payments ar4 due. Principal shall be paid in Consecutive m9nthly installments of S each, . I commencing on , and continu~ thereafter on the day of each month witli the balance of the indebtedness, if not sooner paid,. que and payable on I I o The principal balance heJ~f, together with all accrued and unpaid interest, shall be' paid on , and interest at a rate per annum whicJ) is % above Bank's Prime Rate, such rate to change from time to time as of the effective date of each announced chaqge in such Prime Rate shall be paid on the day of eachjmonth commencing o~ . , .. I I o The principal balance ht' r. together with all .accrued and unpaid interest, shall be pa' on . , and interest at a rate per annum which . % above the CD Rate, such rate to change from me to time as of the eff~e date of each change in or resetti~ of the CD Rate, shall be paId on the day of each tOnth commencing on ! o In no event shall the rate charged Ion this Note exceed % per annum. I o The principal balance htr. together with all accrued and unpaid interest, shall be pai. on , and interest at the rate of % annum shall be paid on the day of each m nth commencing on fXI ....5';J)... ~~~est shall be calcJted at' the rate of A . c;n % per annum. Principal and ~terest shall be paid in 17q consecutive monthlY installments of $ 3 , q 23 . 65 each, coo1meocin on . .l;f:~':!'I!'::;:.'::;';';;"t'.:.:ti;::;<::~t:f:t .:::::=::::::::::::::::::::::::::::::~~~~~~~~~W~~~~~~~:~:~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~i~~t::::: ate -.::-- /AJ,97 07/01/1999 , and continuing thereafter on the 1ST day of each month wilh the balance of Ihe indebledne~~, if not soo~er paid, due and payable on 06/01/2014 . During any penod Ihat Ihc ~nlraetual Rat~(s) is reduced by 0.25% per annum, a~ descnbed elsewhere In this Note, inslallments of principal and interest shall instead be in the amount of $ 3,864.70 each. If the reduction in the Contractual Rate(~) i~ no longer in effect, Ihe amount of in~tal1ments of principal and inlercst shall return to and be the same as the amount of such install men Is prior to the reduction in the Contractual Ratc(s). Undersigned shall pay Bank concurrently with the execution and delivery hereof, or Undersigned previously has paid Banle, an origi.nation fee ~~ $ .. ~ ' 950. 00 , to compensate Bank for Its underwnting, onglOatiOn and administration of the loan evidenced by this Note. This fee shaU be deemed fully earned by Bank on the dale hereof, shall not be refunded, and is in addition to any other fees, costs or expenses which may be due and payable hereunder. , Unless Undersil~ed has authorized Bank to take payments out of a ~ellon ~eckmg Account, as set forth below, Undersigned will mad or deliver to Bank the amount billed by Bank each month. Undersigned will mail or deliver the payments so that Bank receives all payments no later than the due date shown on each bill. o Undersigned authorizes Bank to take all payments of priincipal and/or interest and/or other amounts due under this Note: out of Undersigned's Mellon Olecldng Account Number . titled in the name(s) of . , on or after ~e _~ ~y of each ~th. Undersigned will keep a suffiCIent balance 10 this account to cover the full amounts of all requiw;! ~yme?~ At. its . option, Bank may terminate UndersIgned s ~.bility to use this service. This authorization shall remain in ~ffect until r~oked by, Undersigned in writing or until the loan evIdenced by this Note IS paid in full or until Bank has termin~ted Und~rsi~ed's a~i1ity ~o use this service, as the case may be. Pnor to matunty, whIle thIS authorization is in effect and provided that Undersigned keeps a sufficient balance in this account to cover the full amounts of all required payments, the Contractual Rate(s) shall be reduced by O~25% per annum. This authorization will be effective even though this Note and the account may be titled in different versions of Undersigned's name. If the original principal amount of this Note is in excess of SlO,OOO.OO, or if U~dersigned is a corporation, interest shall be calculated on the: basis of a 360-day year and actual'days elapsed. If the original principal amount of this Note is $10,000.00, or less, and Undersigned is Dot a corporation, interest shall be calculated on the basis of a 365-day year or ~ay year, as the case may be, and actual days elaps.ed. "Prime Rate" shall mean the interest rate pee annum announced from time to time by Bank as its Prime Rate. The Prime Rate may be greater or less than other interest rates charged by Bank to ?ther borrowers.. and is not Solely based or dependent upon the mterest rate whl:ch Bank may charge any particular borrower or dass of borrowers. . If a single oertifi<:ate of deposit is held by Bank as collateral security for the indebtedness evidenced by this Note as more fully described in the .t\ssi.gnment of Deposit Account ~ressly referring to this Note, "cn Rate" shall ~the interest rate paid by Bank on such certificate of deposit (the "G&1ificat~~), Said CD Rate to be . . q . ';;2 ;'>' Page 1 of 5 .. .., ;', ~~t by Bank at each renewal of the Certltfate. If more than one certificate of deposit is held by Bank as collateral security for the indebtedness evidenced by this Note, as more fully described in the Assignment(s) of Deposit Account expressly referring to this Note, "CD Rate" shall mean the highcst of the intercst rates paid by Bank on such certificates of deposit (the "Certificates"), said CD Rate to be reset at each renewal of each Certificate. Late Charge. If any payment (including without limitation any regularly scheduled payment, balloon payment or final payment) is not paid within 15 calendar days after it is due, Undersigned wilI pay a late charge of the greater of $25.00, or three percent (3%) of the unpaid portion of the scheduled payment due (regardless of whether the payment due consists of principal and interest, principal only or interest only). Such late charge shall be in addition to any increase made to the Contractual Rate(s) applicable to the outstanding balance hereof as a result of maturity of this Note or otherwise, as well as in addition to any other applicable fees, charges and costs. Default Rate(s); Post-Maturity Rate{s). Upon the occurrence of any Event of Default (as defined in this Note), at Bank's option, interest shall accrue at a rate equal to two percent (2%) per annum above the Contractual Rate(s) until the earlier of the date that such Event of Default bas been cured or until and including the date of maturity hereof. After maturity, whether by acceleration or otherwise, interest shall accrue at a rate equal to two percent (2%) per annum above the Contractual Rate(s) until all sums due hereunder are paid. Interest shall continue to accrue after the entry of judgment (by confession or otherwise) at the Contractual Rate(s) until aU sums due hereunder and/or under the judgment are paid, except that after maturity or, at Bank's option, upon the occurrence of any Event of Default, interest sball accrue at a rate equal to two percent (2%) per annum above the Contractual Rate(s). Books and Records; Time of Essence. So long as Bank is the holder hereof, Bank's books and records shaU be presumed, except in the case of manifest error, to accurately evidence at aU times all amounts outstanding under this Note and the date and amount of each advance and payment made pursuant hereto. The prompt and faithful performance of all of Undersigned's obligations hereunder, including without limitation time of payment, is of the essence of this Note. _ Security Interest, Setoff end Assignments. To secure all amounts at any time owing or payable under this Note and Undersigned's obligations hereunder, as well as to secure all costs and expenses incurred by Bank in the collection or enforcement of this Note or the -protection of any collateral securing this Note (tncluding without limitation all advances made by Bank for taxes, levies, insurance, filing fees, and repairs to or maintenance of said collateral), Undersigned hereby grants to Banle a security interest in, lien upon, and right of setoff against, all deposit accounts, credits, securities, moneys, or other property of Undersigned which may at any time be in the possession of, delivered to, or owed by Banle, including any proceeds or returned or unearned premiums of insurance, and the proceeds of all the foregoing property. Other property, real or persooa~ may secure this Note, as set forth in other documents and agreements. Undersigned acknowledges and agrees that Undersigned shall renew, or cause to be renewed, the Certificate(s), if any, until the indebtedness evidenced by this Note bas been paid in fulL Undecsigned further agrees that Undersigned will ac:cute, or will cause to be executed, upon demand by Bank any financing statements or other documents, including, without limitation, additic?oal Assignments of ~ Aocount, wbicb Bant may deem oecx:ssary or desirable to evidence, perfect or maintain perfection of the security interests created in the Certificate(s) and any renewals, replacements and substitutions thereof. Additional Tenus and Conditions 1. Covenants:. Undersigned COIIaJallts and agrees that until all indebtedness evidenced hereby has been paid in full, Undersigned shall: (a) maintain at all times a positive tangible net worth; (b) (1) have all Environmental Permits necessary for the conduct of each of Undersigned's businesses and operations, (2) conduct each of Undersigned's businesses and operations in material compliance with all applicable Environmental Laws and Environmental Permits, (3) not permit to exist any event or condition that requires or is likely to require Undersigned under any Environmental Law to payor (:xpend funds by way of fines, judgments, damages, cleanup, remediation or the like in an aggregate amount, the payment of which could reasonably be expected to interfere substantially with normal operations of Undersigned or materially adversely aflCct the financial condition of Undersigned, (4) notify Bank promptly upon becoming aware of any pending or threatened proceeding, .suit, investigation, allegation or inquiry regarding any alleged event or condition that, if resolved unfavorably to Undersigned or any of Undersigned's subsidiaries or affiliates, is likely to cause Undersigned or any of its subsidiaries or affiliates under any Environmental Law to pay or expend funds by way of fines, judgm~nts, damages, cleaning, remediation or the like, and (5) provide at Undersigned's cost, upon request by Bank, certifications" documentation, copies of pleadings and other information regarding the above, all in form and content satisfactory to Bank; (c) conduct each of Undersigned's businesses and operations in material compliance with all federal, state or local laws, statutes, regulations, rules, ordinances, court or administrative orders or de<:rees, or private agreements or interpretations, now or hereafter in ,existence, directly or indirectly relating to or affecting Undersigned's businesses or operations; (d) use the proceeds of the loan evidenced hereby only for business purpose(s) specified to Bank at or prior to the execution hereof; (e) promptly notify Bank: in writing of any change in Undersigned's residence or OIief Executive Office; (f) purchase and maintain policies of insurance (including tlooc.f insurance) to protect against such risks and casualties, and in such amounts, as sIiaIl be required by Bank: and/or appli<:able law, which policies shal1 (1) be in form and substance satisfactory to Bank, (2) at Bante's option, designate Bank as loss payee and/or as additional insured, and/or contain a lender's loss payable endorsement, and (3) be (or certificates evidencing s:JiIDe shall be) deposited with Banle; (g) (1) maintain and keep proper records and books of account in conformance with generally accepted accounting principles applied on a consistent basis in whicl1 full, true and correct entries shall be made of all Undersigned's dealings and business affairs, (2) provide to Bank at Undersigned',s cost, upon Bank's request, financial or other information, documentation or certifications (including without limitation annual and periodic balance sheets and income statements, personal financial statements, federal income tax returns, inventory reports (including a description of raw materials, finished goods, and the aging thereof, as applicable), and accounts receivable and payable aging reports), all in form and content satisfactory to Banle, and (3) permit, upon request by Banle, any of the officers, employees or representatives of Bank to visit and inspect any of Undersigned's properties and locations and to examine its books and records and discuss the affairs, finances and accounts of Undersigned with representatives thereof, as often as Bank may request; (h) provide additional collateral at such times and having such value as Bank may request, if Bank shall bave reasonable grounds for believing that the value of the collateral securing the indebtedness evidenced by this Note has become insufficient to secure said indebtedness; (i) pay, upon demand by Banle, (1) all (osts and fees pertaining to the filing of any financing, continuation or termination statements, mortgages, satisfaction pieces, judgments and any other type of document which Bank deems necessary or desirable to be filed with regard to security interests whkb secure the.. indebtedness evidenced hereby, re~ of whether such q!rity interests were granted by Undersrgned, and (2) all costs an<fC:xpe.yses incurred by Bank: In Page20f5 .' ');.' ronnection with any collateral securing this Note (including without Iim1tation all advances made by Bank for taxes, levies, insurance, rcpairs to or maintenance of said collateral, appraisal or valuation of said collatcral, and determination of flood hazard), rcgardless of whcther such collatcral is owned by Undcrsigned; and (j) pay, upon demand by Bank, all amounts incurred by Bank in connection with any action or proceeding taken or commenced by Bank to enforce or collect this Note, including attorney's fees equal to the lesser of (1) 20% of the outstanding principal balance and intcrcst then due hereunder or $500.00, whichever is greater, or (2) the maximum amount permitted by law, plus attorney's costs and all costs of legal proceedings. 2. Events of Default. The occurrence of any of the following shall constitute an ftEvent of Dcfaultft hereunder. (a) default in payment or performance of any of the indebtedness or obligations evidenced by this Note or any other evidence of liability of Undersigned to Bank; (b) the breach by any Obligor (defined as Undersigned and each surety or guarantor of any of Undersigned's liabilities to Bank as well as any person or entity granting Bank a security interest in property to secure any indebtedness) of any covenant contained in this Note or in any separate security, guarantee or suretyship agreement between Bank and any Obligor, the occurrence of any default hereunder or under the terms of any such agreement, or the discovery by Bank of any false or misleading representation made by any Obligor herein or in any such agreement or in any other information submitted to Bank by any Obligor; (c) with respect to any Obligor. (1) death or incapacity of any individual or general partner, or (2) dissolution of any partnership or corporation; (d) any assignment for the benefit of creditors by any Obligor; (e) insolvency of any Obligor; (f) the filing or commencement of any petition, action, case or proceeding, voluntary or involuntaty, under any state or federal law regarding bankruptcy, insolvency, reorganization, receivership or dissolution, including the Bankruptcy Reform Act of 1978, as amended, by or against any Obligor; (g) default under the terms of any lease of or mortgage on the premises where real or personal property securing the indebtedness evidenced by this Note is located; (11) the garnishment, tax assessment, attachment or taking by governmental authority or other creditor of any property of any Obligor which is in Bank's possession or which constitutes security for any indebtedness evidenced hereby; (i) entry of judgment against any Obligor in any court of record; (j) the assessment against any Obligor by the 'Internal Revenue Service or any other federal, state or local taxing authority of unpaid taxes, or the issuance of a levy or the entering of a lien in connection therewith; (Ie) change in control of or transfer of any interest in any Obligor - (other than an Obligor who is an individual); (I) a determination by Bank, which determination shall be conclusive if made in good faith, that a material adverse change bas occurred in the financial - or business condition of any Obligor; (m) the maturity of any life insurance policy held as collateral for the indebtedness evidenced by this Note by reason of the death of the insured or otherwise; or (n) default by Undersigned in the payment of any indebtedness of Undersigned or in the performance of any of Undersigned's obligations (other than indebtedness or obligations evidenced by this Note or any other evidence of liability of Undersigned to Bank) and such default shall continue for more than any applicable grace period. 3. Acceleration; Remedies. Upon the oceurrence of any Event of Default: (a) all amounts due under this Note, including the unpaid balance of principal and interest hereof, shall become immediately due and payable at the option of Bank, without any demand or notice whatsoever; and (b) Banle may immediately and without demand exercise any of its rights and remedies granted herein, under applicable law, or which it may otherwise have, against Undersigned or otherwise. Notwithstanding any provision to the contrary contained bcrein, upon the occurrence of an Event of Default as described in Section 2(f) hereof, aU amounts due under .( ; this Note, incJ:uding WI...Jut limitation the unpaid balance of principal and interest hereof, shall become immediately due and payable, without any demand, notice or further action by Bank whatsoever, and an action therefor shall immediately accrue. 4. Bank's Rights. Undersigned hereby authorizes Bank, and Bank shall have the continuing right, at its sole option and discretion, to: (a) do anything which Undersigned is required but fails to do, and in particular Banle may, if Undersigned fails to do so, obtain and pay any premiums payable on any policy of insurance required to be obtained or maintained hereunder; (b) direct any insurer to make payment of any insurance proceeds, including any returned or unearned premiums, directly to Bank, and apply such moneys to any indebtedness or other amount evidenced hereby in such order or fashion as Bank may elect; (e) pay the proceeds of the loan evidenced by this Note to any or all of the Undersigned individually or jointly, or to such other person(s) as any of the Undersigned may direct, except to the extent otherwise provided in Section 6 hereof; and (d) add any amounts paid or incurred by Bank under Section l(i), Section 1(j) or Section 4(a) to the principal amount of the indebtedness evidenced by this Note. 5. Authorization to Borrow. Undersigned hereby represents, warrants, certifies and covenants as follows: (a) If Undersigned is a corporation, that the person(s) signing below hold(s) the office(s) indicated below (and continue to hold such office(s) until Bank has received notice to the contrary in writing from Undersi,~ned), and that the Board of Directors of Undersigned has adopted resolutions providing that: (1) the person(s) executing and deliverinE this Note on behalf of Undersigned is/are authorized (i) to incur indebtedness and obligations on behalf of Undersigned by borrowing or making other financial arrangements with Bank from time to time, upon terms and conditions as they in their sole discretion deem desirable, (d) to make, execute and deliver promissory notes, letter of credit agreements, security agreements, assignments, mortgages and aU other documents required by Bank in connection wilh the incurring of indebtedness or obligations, and (Iii) to assign and pledge as collateral secUrity for any such indebtedness or obligatiorn~ now or hereafter existing, any real or personal property of Undersigned; (2) the actions of anyone or more officers of Undersignc:d in borrowing money from Bank heretofore for the account of Undersigned, in assigning or pledging any of Undersigned's property for the payment thereof, or in doing any other act in connection therewith are hereby ratified, confirmed and approved; and (3) said resolutions shall have the force of a continuing agreement with Bank, and shall be binding upon Undersigned until a resolution am~ding them shall have been duly and legally adopted and Bank furnished a certified copy thereof. (b) If Unden.igned is a partnership, that (1) Undersigned's name shown below is a trade name of Undersigned's firm used in the conduct of an unincorporated business owned entirely by the persons signing this Note on behalf of said partnership; (2) the partners executing and delivering this Note are authorized (i) to incur indebtedness Md obligations on behalf of Undersigned by borrowing from or makiI:lg other financing or credit accommodations with Bank from time to ltime, upon such terms and conditions as they in their sole discretion deem desirable, (ii) to make, execute, and deliver promissol}' notes, letter of credit agreements, security agreements, assignments, mortgages and all other documents required by Bank in connection with the incurring of indebtedness or obligations, and (iii) to assign an~ Irledge as collateral security for any such indcbtedness or obligatiOnS; :oaw or hereafter existing, any real or personal property of Undersigned; (3) the actions of anyone or more partners of Undersigned in borrowing money from Bank heretofore for the account of Undersigned, in assigning or pledging any of Undersigned's property for the payment thereof, or in doing any other act in CXJonection therewith.at:C hereby ratified, confirmed, and approved; (4) notwithstanding anylmodiftcation or termination of the :. Page30f5 ....\1..' ,. '- ~ power of any of the partners to represent said firm. whether by expiration of the partnership agreement, by death or retirement of any partner, or the accession of one or more new partners, or otherwise, and notwithstanding any other notice thereof Bank may receive, this authority shall continue to be binding upon each of the Undersigned individually and upon their legal representatives, and upon Undersigned and its sucecssors, until Bank has received notice in writing to the contrary signed by one of the Undersigned or by Undersigned's duly authorized agent (Receipt of sueh notice will not relieve any partner of any liability arising from obligations incurred prior 1O Bank's receipt of such notice.), and (5) nothing herein shall be construed to limit the rights granted to a partner by law or by the partnership agreement, but all rights granted herein shall be in addition to such rights. 6. Definitions; Miscellaneous Provisions. (a) Undersigned waives (except where requested hereby) notice of action taken by Banle; and hereby ratifies and confirms whatever Bank: may do. Bank shall be entitled to exercise any right notwithstanding any prior exercise, failure to exercise or delay in exercising any such right. (b) Bank shall retain the lien of any judgment entered on account of the indebtedness evidenced hereby. Undersigned warrants that Undersigned has no defense whatsoever to any action or proceeding that may be brought to enforce or realize on any such judgment. (c) If any provision hereof shall for any reason be held invalid or unenforceable, no other provision shaD be affected thereby, and this Note shall be construed as if the invalid or unenforceable provision had never been a part of it. The descriptive headings of this Note are for convenience only and shall not in any way affect the meaning or construction of any provision hereof. (d) The rights and privileges of Bank: contained in this Note shall inure to the benefit of its successors and assigns, and the duties of Undersigned shall bind all heirs, personal representatives, successors and assigns. (e) This Note shall in aD respects be governed by the laws of the state in which this Note is payable (except to the extent that federal law governs). (f) Undersigned hereby irrevocably appoints Bank: and each holder hereof as Undersigned's attorney-in-fact to endorse Undersigned's name to any draft or check: which may be payable to Undersigned in order to collect the proceeds of any insurance or any returned or unearned premiums in respect of any policies of insurance required to be maintained hereunder. Undersigned hereby acknowledges that this appointment of Bank and each holder hereof as attorney-in-fact is irrevocable and is coupled with an interest. (g) Undersigned assigns to Bank all moneys which may become payable on any policy of insurance required to be maintained under this Note, including any returned or unearned premiums. (h) "Environmental Law" means any _ federal, state or local environmental law, statute, regulation, rule, ordinance, court or administrative order or decree, or private agreement or interpretation, now or hereafter in existence, relating to the manufacture, distribution, labeling, use, handling, collection, storage, treatment, disposal or otherwise of Hazardous Substances, or in any way relating to potlutkln or protection of the environment or public health. (i) "Enviroomental Permit" means any federal, state or local permit, license or authorization issued under or in connection with any Environmental Law. (j) "Hazardous Substances" means petroleum and petroleum products, radioactive materials, asbestos, radon, lead containing materials, sewage or any materials or substances defined as or included in the definition of "hazardous wastes" "hazardous substances," "hazardous materials," "toxic substances," "hazardous air pollutants," "toxic pollutants," "pollution," or terms of similar meaning, as those terms are used in any Environmental Law. (k) "Chief Executive Office" means the place from which the main part of the business operations of an entity is managed. (I) "Undersigned" refers individually ;:lOd collectively to all makers of this Note, including, in the case of any partnership, all general partners of such partnership individually and collectively, whether or not such partners sign below. Undersigned shaU each be jointly and severally bound by the terms hereof, and, with respect to any partnership executing this Note, each general partner shall be bound hereby both in such general partner's individual and partnership capacities. 7. Direction to Pay Proceeds.Undersigned hereby authorizes and direets Bank to pay the proceeds of this Note by: . . Vi crediting Accclunt Number ()ti)- ro z 1 '1 if+(, :tl &; I; 2a / i (\inthenameof I / 51lN6 tlO ~DtJ IfWIr K \oJ It(\. in the amount of $ I .,1 fI/ I R 529 00 Ei.I~J('19 mtkO ''0paying rnDI~ :fI (Pl' _' IDJ-fJ1:;- J 2. &~S- - /\ A 1,J L $1-3 J .30fJ.3 - if ,q "2-1 u the amount of S . ~ying f)tN<EICfJL! q/;;l9'1<~f the amount of $ 8. Affidavit of Business Loan. (This Affidavit is not applicable if Undersigned is a corporation.) Undersigned, being duly authorized, depose(s) and say(s) under penalty of perjury that Undersigned: . (a) Is/Are enl:aged in business aslia Owoer(s), 0 General Partoer(s) of: (name and nature of business) YOUNG~ooD MARKET AND SAY-Fop-R-SUPERMARKET if. yl-- FOOD MARKET (b) Hereby make(s) application to Bank for a loan, the proceeds of which will be utilized for the purpose(s) of REFINANCE MELLON DEBT. OTHER DEBT CONSOLIDATION & EQUIPMENT & INVOICE PURCHASE (c) Exercise(s) actual control over the managerial decisions of the business. (Remainder of page intentionally left blank) .".' .,)t Page 4 of 5 . ~ .. , .:~, ' - ~." 9. Confession of Judgment. UNDERSIGNED HEREBY EMPOWERS TIlE PROTIlONOTARY OR ANY ATTORNEY OF ANY COURT OF RECORD TO APPEAR FOR UNDERSIGNED AND TO CONFESS JUDGMENT AS OFTEN AS NECESSARY AGAINST UNDERSIGNED IN FAVOR OF TIlE HOLDER HEREOF, REGARDLl1')S OF WHETHER ANY EVENT OF DEFAULT liAS OCCURRED, AT ANY 11ME AND AS OF ANY TERM, FOR TIlE OUTSTANDING PRINCIPAL BALANCE HEREOF PLUS INTEREST DUE UNDER TIlE TERMS HEREOF AND ALL OTIIER AMOUNTS DUE HEREUNDER, TOGETIlER wnH COSTS OF LEGAL PROCEEDINGS AND AN ATfORNEY'S COMMISSION EQUAL TO TIlE LESSER OF (A) 20% OF TilE OUTSTANDING I'RINCIPAL BALANCE AND INTEREST HIEN DUE HEREUNDER OR $500.00, WlUCIIEVER IS GREATER, OR (13) TIlE MAXIMUM AMOUNT PERMITTED BY 1A W, WITH RELEASE OF ALL ERRORS. UNDERSIGNED WAIVES ALL LAWS EXEMPTING REAL OR PERSONAL PROPERTY FROM EXECUTION. By signing this Note, Undersigned agrees to all terms of the Note and swears, under penalty of perjury (as set forth in 18 Pa.C.S. ~904, If governed by Pennsylvania law), to the Aftldavlt or BusIness Loan (IC completed) set Corth In Section 8 of this Note. 11~~~!!II'~!ga!li~II!II!lllllllll!I!I~I!I!III!lllllll!Il~~llll!II!~llllllllll~lll~I!!!I!I~I!ll~:::::::::::::::::::::::::l~~lll~lllllllllll!IIIII~I.:.;~~:I:lll~I~1:1!:I:l:I~lll:I~1111Ij:I~I)ll~::I!!!~:j:~:11:11:~I~~:1l::I:::I~I:I~ljll~~l[I~I~I~I~III~111;:ll!jlll:lll[I~~1i!II;I!II:I:I:llllllll1:llI1I,::ll:,11:1!:ll:I!!I!!111Illl!!::::::: Witness the due execution hereof under seal x witness: :itne.~~ , Mdlon Banlc, NA Mdlon Bank (DE) National Association CL-450 Rev.(t0i96) LC 9196 ill 9196 0275 r l(i6.6.(-3823 1 d4543 (01) 052799,1605 ~~a" \ . . x ?f/ . . \ . eal) . , , ~~~(J ~~~lF~tl <;V'/'}-:~~1#;.;}lu~7 672 B :imVILLE ROAD . /..- NEWVILLE, PA 17241 ) k-. ftC Individual:. . /_ X.~~AK /J>>P- (~F'-.J (Seal) ~~RVILLE ROAD NEWVILLE, PA 17241 "., "'.:,.. ~~. Page 5 of 5 -or ....\" ' For value received, and intending to be legally bound, in consideration of a loan or other credit accommodation in the amount of Three Hundred Ninetv Five Thousand and 00/100 Dollars ($ 395,000.00 ) made by Mellon Bank. N.A. ~Bank"UO ;~~; =~r~ SAY- . SUPERMARKET V ("Borrower(s)"), said obligation evidenced by a PROMISSORY NOTE dated _1,-- CJ-f) - '1'1 . (the "Note") Undersigned, intending to be legally bound, hereby agrees as follows: 1. Security Interest. Undersigned hereby grants to Bank a security interest in the following property now owned or hereafter acquired by Undersigned: (Certain terms used herein are defined in Section 13 below.) IXI ~ ~ (6.) all equipment, wherever located, including ala ry, m tor vehicles, furniture and fixtures; IXI fi'~ 'if;n inventory (whether held for sale or lease or to be . ed under contracts of service), raw materials, work in process, and materials used or consumed in the conduct of Undersigned's business, and all books, records, invoices or other documents which describe or evidence the same; IX! 0~ Y ~II accounts, contract rights, general intangibles, ~ chases in action, instruments, documents (including all documents of title and warehouse receipts) and all rights to the payment of money, however evidenced or arising; o (d) all securities; all cash, stock or other dividends or distributions paid upon or made in respect of such securities in any form; all securities received in addition to or in exchange for such securities; and all subscription rights incident to such securities; o (e) all farm products; and o (f) all property or rights described below under the caption "Description of Collateral." Description of CoUateral (Give a sufficiently detailed description to identify each item). In addition to the foregoing, Undersigned: (1) grants to Bank a security interest in all accessions, parts, accessories, attachments and appurtenances in any way used with, attached or related to, or installed in, or ~l1tended to be so used, attached, related to or installed in, any equipment or inventory constituting "Collateral" hereunder; (2) grants to ~lDk a security interest in all substitutions for, renewals of, improvements, replacements and additions to, and the products and proceeds (cash and non-cash) of all of the foregoing property and any insurance policies relating thereto; (3) grants to Bank a security interest in, lien upon, and right of setoff against, all deposit accounts, credits, securities, moneys or other property of Undersigned which may at any time be in the possession of, delivered to or owed by Hank, including any proceeds or returned or unearned premiums of insurance, and the proceeds (cash and non-cash) of all the foregoing property; and (4) assigns to Bank all moneys which may become payablt: on any policy of insurance required to be maintained under this Agreement, including any returned or unearned premiums. AIl such property subject to Bank's security interests described in this Section 1 is referred to herein collectively as the "Cotlateral." With respect to Section 4 hereunder, the term "Collateral" shall not include the property described in Subsection (3) of this Section 1. All security intl~rests in Collateral shall be deemed to arise and be perfected under and governed by the Uniform Commercial Code, except to the e:rtent that such law does not apply to certain types of transactions or Collateral, in which case applicable law shall govern. 2. Obligations Secured. The Collateral shall secure the following obligations ("Obligation(s)j: (a) all amounts at any time owing or payable under tbe Note, and any other indebtedness, liability or obligation of Borrower(s) or of Undersigned to Bank, now existing or Page 1 of 4 In addition to the rights given to Bank in this Agreement, Bank shall have all the rights and remedies of a secured party under any applicable law, including without limitation, the Uniform Commercial Code. 8. Additional Representations. In addition to the representations and warranties set forth elsewhere in this Agreement, Undersigned hereby mak:es the following representations and warranties which shall be true and correct on the date of this Agreement and shall continue to be true and correct at the time of any borrowing under any line of credit with Bank and until the Obligations secured by this Agreement shall have been paid in full: (a) each account: (1) represents an amount actually owing to Undersigned by the account debtor (less discounts allowed for prompt payment); (2) is valid and enforceable according to i~ terms without further performance of any kind; (3) is not evidenced by any instrument or chattel paper unless the origina1 of such instrument or chattel paper has been deposited with Bank; and (4) is not evidenced by any judgment unless such judgment has been assigned of record to Bank; and (b) the locations of all of Undersigned's places of business are as stated below, and the inventory and records of the accounts are kept at the places indicated below. 9. Additional Covenants. In addition to the covenants set forth elsewhere in this Agreement, Undersigned covenants and agrees that until the Obligations secured by this Agreement have been paid in full Undersigned shall: (a) immediately notify Bank in writing in the event that any of the following occurs: (1) any account is or becomes entitled or eligible for discount for prompt payment; (2) any account debtor has or may have any defense to payment of, or right of setoff, counterclaim, or recoupment against any account; (3) any account represents an amount which is disputed by the aCcount debtor or the payment of which is in any way contingent or conditional; or (4) the desirability, usefulness, or marketability of any of the inventory has been in any way reduced or impaired by reason of physical deterioration, teehnical obsolescence, or otherwise; (b) keep accurate and complete books and records in accordance with generally accepted accounting principles and, at Undersigned's expense, promptly furnish Bank such information and documents relating to the Collateral at such times and in such form and detail as Bank may request, including without limitation: (1) copies of invoices or other evidence of Undersigned's accounts and schedules showing the aging, identification, reconciliation, and coUeetion thereof; (2) evidence of shipment and receipt of goods and the performance of services or obligations covered by accounts; and (3) reports as to Undersigned's inventory and purchases, sales, damage, or loss thereof; all of the foregoing to be certified by authorized officers or other employees of Undersigned; (c) not change any location listed _ below regarding places of business, inventory and records of accounts without Bank's prior written consent; (d) at Undersigned's expense, diligently collect the accounts on behalf of Bank until such time as Bank exercises its right to direetly colleet the accounts, and upon notice from Bank, deliver all proceeds of accounts to Bank forthwith upon receipt, in the original form in which received; (e) immediately upon Bank's request, open a cash coIlateral account ("Cash Collateral account") at Bank and deposit therein all cash proceeds of collections on the accounts; (f) immediately upon Bank's request, give the Bank assignments, in form acceptable to Bank, of specific accounts or groups of accounts and specific general intangibles, and immediately repay the amount loai1ed against any account so assigned to the Bank if the contract with the account debtor is breached, cancelled or terminated; (g) immediately upon Bank's request, furnish Bank: with all information received by Undersigned regarding the financial condition of any account debtor, except to the extent prohibited by law; (h) immediately deliver to Bank all instruments, documents or chattel paper representing any of the Collateral and immediately assign of reeord to Bank any judgmcnl representing any account constituting Collateral; and (i) imllll'1fisttely upon Bank's request, mark its records evidencing its accounts in a manner satisfactory to Bank so as to show which accounts have been assigned to Bank. 10. Additional Rights of Bank In addition to the Bank:'s rights set forth elsewhere in this Agreement, Undersigned hereby authorizes Bank:, and Bank shall have the continuing rights at any time, whether or not any detmIt has occurred under this Agreement, and at its sole option and disc:retion, without notice, to: (a) take over and collect any or all of the Blccounts and to take any other action pursuant to its power of attorney granted herein; (b) exercise absolute and exclusive dominion and control over all funds deposited in the Cash Collateral account; apply any funds therein against any Obligations; and charge to any deposit account of Undersigned any Item of payment credited to the Cash Collateral account which is subsequently dishonored; (c) at any reasonable time, through its authorized agents and employees, inspect, audit, and verify the accounts and the inventory, review Undersigned's books and records, and copy or make excerpts from any document;. and (d) verify accounts with debtors in the name of Undersigned, Hank, or Bank's designee. 11. Mrscellaneow Provisions. (a) Undersigned waives protest of all commercial paper at any time held by Bank on which Undersigned is in any way liable, notice of nonpayment at maturity of any and all accounts, and (except where requested hereby) notice of action taken by Bank; and hereby ratifies and confirms whatever Bank may do. The rights andl remedies of Bank hereunder are cumulative. Bank shall be entit\ied to exercise any right notwithstanding any prior exercise, failur(: to exercise or delay in exercising any such right. (b) If any provision hereof shaD for any reason be held invalid or unenforceable, no other provision shall be affected thereby, and this Agreement shall be construed as if the invalid or unenforceable provision had never been a part of it. The descriptive headings of this Agreement are for convenience only and shall not in any way affect the meaning or construction of any provision hereof. (c) The rights and privileges of Bank contained in this Agreement shall inure to the benefit of its successors and assigns, and the duties of Undersigned shaD bind all heirs, personal representatives, successors and assigns. (d) No modification of this Agreement, nor any waiver of any provision hereof, shall be effective or enforceable unless set forth in writing and signed by an officer of Bank. (e) This Agreement shall in all respects b4~ governed by the laws of the state where the Obligations are payable as reflected in the document(s) evidencing such Obligations (except to the extent that federal law governs), and all references to the Uniform Commercial Code shall be deemed to refer to the Ullliform Commercial Code as enacted in such state. (f) Undersigned hereby irrevocably appoints Bank: and each holder hereof as Undersigned's attorney-in-fact to: (1) endorse Undersigned's Ill8me to any draft or check which may be payable to Undersigned in order to collect the proceeds of any insurance or any returned or unearned premiums in respect of any policies of insurance requ:ired to be maintained hereunder; and (2) tak:e any action Bank dec~ms necessary to perfect or maintain perfection of any security interest granted to Bank herein, including executing any document on Undersigned's behalf. (g) Undersigned shall bear the risk of loss of, damage to, or destruction of the Collateral, and Undersigned h(:reby releases Bank from all claims for loss or damage to the Collateral caused by any act or omission on the part of Bank:, except for willful misconduct. (h) The proihpt and faithful performance of all of Undersigned's Obligations hereunder, including without limitation, time of payment, is of the essence of this Agreemen~. (i) Copies or reproductions of this document or of any financing statetTI~nt may be filed as a financing statement. 12. Additional Power of Attorney. In addition to the powers of attorney grantl~ to Bank by Undersigned elsewhere in this Agreement, Undersigned hereby appoints Bank and its officers, Page 3 of 4 ~ 10-20-'04 11:22 FROM- r....~ . Dd>~ I\OoODC(la>(....-Iia<il:WlIwld.W)"'" ....u...,.cldr=c . _ .~. llA~',1lD '. ~ " dO" -"7',:':'~ '0.3 iOlC~. ..,'_,~".._ .-cWlLlf:,'A t7V'l . D<bIM ~ (IA<l"'lIIl aM It' IndMdIW) one! will., addr=: 'lllUNC'S fOal 1Wlt:ET 'D ) IIOX ~ c.,.... wellVIlLE..... In41 o.-b___ Ir.AJJ)e (I~ n..ftlc raat It ind,vidaal) aDd ~IUt\t ~ ~ ror1t(j,q<) UlII<(.) (bot ",,"c!;at ilID<fMdu&!)- oddl"dJo 6>c ~lt w-t Itllac1uatlaa: lion... ,_, M.A. _I...... '_IN! '-__ ,""car ~ "eU<<t ""'" c....c.~. (III- 1SI-1a70 .,usbut"gh. PI. 1S1S8-0II01 2 ............c.) .,~ rant --<.J (IoIlaolllC tin. It ia<lMd~ol) ODd oddrao liJcoa::ilCi<yia....,..hlll'ltIlItlalI. s,...w"t:n- 101""- (cIlcdo:ihppli...&k} o nc1alllll "J:ld>loI".... "Sa::wai httf'....... "Laoa!' ...,j'l..a>r<<..~. o no _ "DcbIec".1I4 '$o:Jcu"..s~..,.._ ~ -~:~. o tld>....-..~.UIlIiIv- s.ECORl:D FAIt'tl'SIC/(A'IUlU:(S) nw_"IIIal........zra.:5c<uoIP~~ lliI pod'.ot:la .....ritt...-... 4aIIot-1lI (~apt>lica~ct.;..{,,))- a.Cd~.=:.__.r-c,~.,.__lt:- b. 0 Ai ICI \IbldI..,.. IIlIda ... rap.<<. L a1<=ly.ejas....-=aod.,.II..:n:.U" -""""'7 III p~- O.......I/>c: ~__Io""-.aty. o .........doc~c_"""""....-.n.__-..s tlJdlis""""Y. d.. -,.....}a:l.... ~ ItICctc$tla __~- 0..................1__ ...~ 0_110: Jlm...... .....c/c._ __ laI'ClIW)'l_1:L C.O~" ~ otdaccalW.cnl4caalb<dltt ~ P. iIl.bd. e:>:arityilur:ral: -.-.IQ\ldJ ~ (aIoo dG<<lbo ~ """"""'" iA blcxi:"I(~ "'.,. CJUIl ~ Illd_ odcqua1dy do:x:I\bo4... ~ ~ lIMa4a. ...fQIlQ(). Sc<:wJ r_~~04 . '*rl('-{~" AbooIA): $Tl\l(tINWl'OJOo(-lOJDoCPAlrC-l (1l&o<.~ ............Ws........,."'~o(p~ a.~2 --(WIll LC IlfJS un".; IIZlS B ~1:.144& 1-442 P05/11 U-170 FlNANONC ST47DfDft' t,lDi(q""I~...o.a.E_~ JMl'01(UNl-I'l_ naa Waw:dau 11'\11'001(1-..... ......"l~ FIlIneN... (IWIlP"l by DUne olf.aaO::~'-'?: ~~ (.-.~ ~ ~Q~ :::, ~(':, [\~ ~ ;;;:- O[[OS ;.:;:~,lr;=-'lLAlJ(l COUNT~'-PA 1 s 'S'/ JUH 20 ArJ 10 51 1. 1 1llla ~ lillJI<IIICII' .. pn:lIOO'fC:d t<< aJlIli:punu&II[ la_l1oirocm~1 Cod<; .Pdlo... lo:tilal..11ll....(docd:.ppl!ablel."9' o ~oC~c.~ o I'r'Olboaobly <Ie _ IllI (cal_IUOIIlaOC~P~Bl-AW .~~ ..., lb N"",lIotur """lIlonal n.... tiC .~ "-Ill t..I1<IrntI/I.slI." CMl!lt.l0~~\: COlL\'fERAL Llcslllyaolloknol ", iIeall ..... cyP:; AlL 1IBl1llll'S UCllT. 'rITLE. AlICI luearsr. UlETIEa .-o.l CIll 18lEt.fTBl EXI!ITlIIG at &C4lIREII. III NO to loll Il'4EJlTllRl UlICUOl1lC '~UEll Ill! IfPQS$USeJ GQ:D$J. AaIUlTS. oPElI 4CQV11TS. "IIE~ ,.'rIJlGl8lU. ~. PlAna PAI'fW.. )lIS1klJ1EMTs, IOTU. llWT$. lfTTns.ClIt AllV1CfS Df QEIlIl. aEd:'Y~l.n, errN'_ IJICLIITS ~IMli TO DElTClII. IIXTUllU. =~~~(~~~~I~~~Iw~~ ~'=..~:c~ NOa6DIJ lll' TIlE 1cIRI:cotllG AIIO ALL QJUi&lT,iI. Q.tJq. 11M', ElEUIEI IJ.o ..rvll.l!Ol!' uu.T111G 1111uw. ea..ty. C<uaolcr. , 7 8 2a :I IllI (cf,ed: lIlIIyl[ detIraIJ l'oa:rllat OUkaallaJaol_,a/o!O..-..:d. u-Jr1rdafal....~ ;hpp&:.bIc:: 'll>c~io,_itl<IIaIa (c'-upPcopo:;....la(a))- ' . __ ' " ,,'. . a.O aupopoooiaca.-",l.._...-, .,(,... ..''- \1.11I ,...,........icllacear.......laziate iictiia.! .....:..- , . '.": '. ._';"~~. ..~. c. [] .......... IlC "'" lib: I~ ell a4 p')_ c:oin.:laf....- ... 0 _...~.._IIlcMlcO(__ ...u..:JIU(lNWlac.hAdt",.1 ....-w.<a4actalad....rOll- ',. . .~c..s..1C -~I :O~I~~ H'17241; .~, ' ~II: Jloao: __ "'(d".cboacl OD-la O~ ..her(.) IDoc a.Cliea(....D'..:."~ ~,.:;':: Cotaoq.. UaaUl1llPwccI~...''-.:J. .~4~~..~.a;..:1:~~ o Daaibod GIl.MclidoDIl,...... ""_.r_ _ (""f'~00ly llllODeloC<<.oiM"la<cn:Ot e(~ . ....... .....r-=-.~..: DEJJrOR.SJQCA~' 0' ~ ~.)< WIG ;~ ElW: . .~ .. -',' .' -~'~-"'" G'S FlDI'.....IlCET 9 10 lI. '.l.. ......,. . ........ . ~ '- 11 l~ 1lS1llRN 1Q!CBIPTttk Mellon ienl:. ..A.. lkalncss &:Int.f~ l_' c_..~ J1.D. ."" 3lIllO J1lcc~, Po. U;!JO.SlIIG &ttlt: coU.t.re' 1.\'1(1: ,. . :-_~. - '.~ ,. .:.. : ':';'IU':,.rlC. 0"_0' -:it.. ..... (-:;..~!: 4l t;..~ -;';'1: ;\" ':' ~;.. "t~. . CJUOINM. COPr ZCU12(11lJ _._ . 1:1 ......"'., } ;, :. -":J, .~ ~..... "'), , 10-20-'04 11:23 FROM- 'I"-44L PfiiG!l1 t1-17l1, ~ ..,d,:~ :. - , - .. ,: ~'cfDS: .UI-lCJfnlAtIl) CdUNTY-Pl '02 flPR 5 an 11 02 ~~~-'" ~~A~.:~::;ATEMENT ~MENOMENT ,~ .. IlA..eA""'NEOFCOoOt.u:T."IUR~ _~ ..... ~c..a<n"'__"""""'I (;.'1..... l..c lit '_1'_10 ~'::~":: =1/11 l.... CoftUr .\ usoJrJll. .~ lSZl4-:1D8lI atal' (011..-.1 ,..i. ... __ff-_ c:...,.. &: 71: a,- .'" . C- O~-.,.._--_.._-_.__....--""",---- :L -""~_,,,,~___"_.___"I_h.-____. ~................................,... ...... ... 0""""" ..-...... ......................~.1t... ............-............ ....................~... .. ___-.o.____tJooo-.a<-....._ -"'1:1--- --IIl.----a---.-'-~ C~............-: ...................... -aa;.. ea-... C aaD1i....... ............... 0 AOdi..... ....................... -- ......,.......... ........._........_.____....._......k. ......... k_"'." ....~c _~....,.....~ " ~"-"""---.. .._..........._ 01_ ......-- ..~-- i-- ClIO x.lIIC;.'~ HO, .. ~..~_c f. __--.11I___ Y~.li FOOD ~ 1-- l-"~. I~ - f.f! " '. .j - OIl _~ucr_ -- ~..... " - ~ : <I " .. "'--..,.".."" ~ -- ,t:--~ ~ JQ) '.:J BM 612 1lEMVn.u: - ...... ~_.",,' .. PA.,J .1;7241, \ISo. ,~ TKoPs-'CIlIIfIIW I~~ l~-"'~ "- - ~ -.'" - " 0_ .. ---.OoOOcIQ:--a-- -- 0-- 0--....- 0--____ 0__ '_~':'" f'" &. ........~....-w _-...rD ~..... ~ ...............,..... ...............1. ....... ......-.........., .0.&....... ....-.......-... ~.~. ......,...,............... .~-...,. ....._.....~......... ~ ""ncu .......RJ ..._' c..i.c~'''. ."- ~." .... ______-..orU-too S --- 'n' 'I~~. COlUlJ::- I.Uoo.lf....,.........e...IJI.... .,.l1Qk.Il.UCX:F\t<.VlC\lolG sr"TEM~.l.MEl<llMI!loIf 1l'0I\60~ ~:II7_ .... . :'0.1.......... t l.7~.." .~Jn. . '. .....~. ... ~ . ...., #. 'r, :.. "'i',".:;:'. . ~l :_. )" Oct-20-2004 08:32am , PARTIES -x;:bror n:unc (ltlsl name !in-t If individual) and maillot addl'C83: .' ~ ~Al:,' SAN~ /lO RP 3 {lOX m " '7 ~ ,NEWVILLE, P^ 11241 Dcblar I\JlIlC (lMt nam" f1~t IT indh'idual) and JlIlIilin!; Idd.~ YOUllG'S FOOO Hl.ltKET RD 3 lIol( ~ ",..... f1EllVtLLI:, PA 17241 Debtur nam<= (l.ul name flllt I! individual) and IXIlIilina:.d<Jrc;u: 80(~ Putt(la.) namc(.) (last D8lIlC Mt iC iDdividu4l) Me! addreu fIx 50CIIrity 11Iu:rcat information: Mellon Rank, ..~. 1IllAfMOO lIail!t;lng loan Center ~ Mellon ~ Center! Rm. 15'-1~70 plttsbul"g~, PA lS2Sa-Ou01 1- Aaw-(.) of &<ared. Putt JWl\e(.) (!.ad DIme: Ilrst l'inc11vld\l.ll) ~ .ddtesa ror l<<llrity lnlc:rG( Jntormation. Spcda1 'l)puGfl'uilC$ (~thpplieable): a The tenDI "Pc:btor" and "Sa:ured Pant' meAll "U!Aec" ad "Lcuor: (QIpcetM:1j. C 'I'M Cerm& "Oc:bcor" ancl ~ Party" 1l1ea4 "Coadp><<" pd "CoaI1lP'<<: I"IpcctiYdy. o DdXor I&.ll TrauamIUiur; Ulili;y_ S~ PA.RTYSIGNATIIRE(S) ~ IWcmcu.t t. aw. with GIllY the 8f(lIhlcl Padta a/pnlm'e to pcd'ect OICCdn"t)' IlltuaUn collatcnl (d1cc:kopplicablc ~~)- a. [] ""jGltcd aRo:. chalice of AaDl~ ld"afI~ or OOl'padte ._arc ottMDebtor. b. C as 10 wbicb tbe 111I"1 balJ Zapud. c:. alrcad1IlIbjCC:UOa &cQUitylnlet'e$t 11\ aJIufh"r ~lIDl1ln ~J\'aDla - o v.bclI mo CAJ1aknt WIllI m."" to thla OOIIDty. o wilen ~ Dcbla.... tc<<ld_ or l'lace orbutln_ __ _ftd to uu. COWIty. cl. aI<<ady subJcc:t to a lICCl1tily In~(w In .....lhcr jucbd1ct1o.. - o wlleft the cow.kral,..... Rl4..e<t to Pcnao:JIlYal\b. o wilen lhe DcbI6r'. 10000U"o w... "'01'~ UJ l'auIq'lvauia. e.O wbIch Ia proccc:.da of th<scollat~ d=~ III block. 51, in~hIcb a --'t11I1tete$t......... P~usl.1 perfected (1Ilaa <kseribc: ~ III block 9,If putdwod 'With c:W& J'rweed1 and lIot adcquatc:11 cIetcrlbol on Iha orlalnal fUlllnane Il1IleIl1Ctlt). s.curcd Pan)' S~tve(.) (r0quite4 OdlylfOO<<:ca) Ii dJecedabovc): MELlOM II srlU(flA1U) POIQ.( .l'ORMl'A UCCl ~.!,93) ~ lorSca..c.u1oleo.....OlNI'Ultk dtl""'U'",Mcia ~2Jl.cy.(7M)LC. 11m U>tM: OZ7S D :n.ln3<<& ~""J~:~.~; - r r .-r.,T29' '.0021008 F-210 nrlANClNU :ii.UKMUff Unlform OJ,IIlJIIfici,.} Code- Forni UCC-l IMPORTANT - Please reQd l.nstn1dious dlrel'nUJbtfore rompletinl': FllIn& No. (SUlPlpot 1>)' tiling offlCC\',): ~ l!t~.~ .~~ (8\JUDpol by filin& oCGcel'): ;'::. ~(F Dr-i:~\ Qr, DEE OS ::i' !.1 :;;;:( LAt(O COUNTY - h1 1 It , 9'/ JUH 26 flf) 10 51 1 ,'_ _.'.' 5 11lia FInandng S"'~ II ~ ,ox- tilinC'pll1IIUlIII1lD 1M Uoito= Commeccid coo.., audia 10 'befikdwlUllhc(duockapPllablelx:<<): o ~oCtbeCnau:lI(JIIWedtlL. '~ ,lil~, '7"" o 'huthonowyoC _' -~. ' il!l realcPterecoccbol !~ERlJlIiQ "....: .=~ . . 4~. :II... ColJnty. CoUllI)'. 6 1 8 Ib NumMl'AtMdlllonQl~1 !!f81lT'l: 't. >t \W(l\~ o 110tbd g)l4aJtltl~.dOll '(Max. \Ge1iarictaz): c.()LIA.'I'ERAL'>9: :".# ,"~ ' . '. ~~~.~~ I<kDtl1;y~rd bykclnlUld,W~,-A' I~'!~"i',:t,' AlL DElITM'C ItICHT, Tt1l.E. AND I"TEREST~:\lKET1IEIl NOlI Oll RERa.fTCl P(ISTUCG 0<< ~lCOlJIIlI3J. ,II( AND, TO ,Al.L tNVEllTORT (INCUJl)ING lEl\lRNUl oa IEPQSSESSfl) COOOS)~ ACCOUllrs, OPEl( ACCOOl{T$, GEM€Ul. IIlTIJIGIat.ES. 'f)ot1JI(BlTS~'JFlAfTEt. PA.PEIl., IIlS11tUHEIlTS, WOTES, DIU,nS, lETTERS QR ADvltES Of CiEDtT. RECEIVIJIlES, O1'llER .AMOlIltTS W1NG TO DlillfOlt, FIXTURES. FURHI'JUIlE All) ECllJIPMOO', ALL ~R.OOUcYS AlID.CASH .ANO NoM'CA.S1f PROCB:O$ (lNCtmlJlQ IKSURANCE. I'ClICIE$ AllD PRCCEEO$) OF TilE RJREClCIIIIC4 AlIll All 'GUARAIITtE$. CLAIMS, RIG"1$, RaQ;01ES AND p':fVn..EGES',~LAnJjli~TlIfll,ETO. . r ': .r ..... ... ~ 2a "..". .....)~;~~.~.{..1 '. ." 3 iii (dlc:ckMlyit~ J"rcd...:tioC~,col~.ii:>= ako~ 1dcaWy ftIa\ll4 nel cda"'- ".ppr"",ble: Tht;~ I:a, or Incllldcf. (dleckapprnprialCbt<<(et))-' ,C.;,:- '>: ' ' iL 0 ClIIpI~~ortobc~OlI- ','.' ,~, b.12l &oodtwblchrcoc.n!II01><:ealDc,l(xt~ 0:'17 e. 0 ~1'll1I DCtbc:Ilko(llldadilllaltawips)a.,ClClBCtCdQU- IS. C AUGaIlla rctlJ1U.a& troII~ tJK: a.L;J";l~-;-=~;"~ the Ulce (illdud.ia; ail aad tu) At lhewcU1\eadat'll1iaeheIdOQ.... ':'. ;.t1{o:",1<j , " ~J, - i" lhc ro1lowiac real estate:: : L, ,. JlD 3 BOX 326 " ~Addreas: NEWILLE PA 1n4" , . n-:n1ocd~ Ilook ':ot(CJhc:dC'oneiO DccdIi OMortgll~a, at l'lI&e(s) , ,---c;;;ti;8ER(Allo-'~~~#:~: , Cc:Juaty. UnUOmll'atcd 16enU!ld '," ':"'f<',..-~... . .~~~~ :",t:..~ o Ocacnbecl 011 Mdilimd.lJlheeL,:, ", ,a,," ",,' ..;;, " NIl"", .t~ CIWDU (nlqlllrtdonl1 ~jo P1t~~ aa'ln~ of r'COlXI1): . .' .... .' '. ~. . . . ~.~ ..::.;;!~~., , S FOOO MARt:ET ' ' , 9 10 o 1 ....:. 1:\ Ib REI'URN~TO: MeUon Bank, I/.A. BusIness Ba~fng los~1 ~t<<~, P.O. BOl( 5080 , Pltutxlrl2h. PA 15230-3080 Attn: COUat...., Unft 11 ......:;.:.. "'... 4 11 ORIGXRAL COPY :I c:un (01) <<M91~ t.~,.. : '.. :; .~. ..... f. ,',),' ,. - ~~~~;~y ~..: ~ '. ~~; . :.t~j~. . f 4- . ~. ~,l".: ..-; ~~:' .. .-' "'1~~.(t!. .,-. ' Oct-20-2004 08:32am , .;~. J';'~' i:.'~ .-. " ~ ."\.... l-1Z&' P.OOS/OOS F-2l0 -:. '.~ _" ..d? , -. '-',-., ..' '. ,: l'rcDS ,'HMBER~t~{J C"UNrY~F" · O~ f1PR.-'S ImIl 02 y UCC FINANCING STATEMENT AMENDMENT ,c?' ..;/i;.~ ~~~...._~ ~ l~.=:'------- "'-. NAIAE .. PHONe at' cONTM:t' 11."( FlI.EA C"""OIUllt ::.:---- . --- . . A. ~IOHO AC:IQol()Wl.EQGwaq-TOI piau _ AddnooII CHh._ I"'" vi '~"'.nl. 8uj;l\lISS Ut\I(lng Lun Cafttlt" p.O. Ilia 3080 '1 tuturQl'I, PI. 1$230-10&11 "'~tI\; cQUltcnl Unit " __ JllNUolQlHCIIfAt1D.Ilil<< (fIJl.1 SP.~ISF A .. NLY ~~~TDID4l'~. ."foIO<ItlIr-...-...",,,,, ~4..,n t:..--)I;_o7. .'" .. NN.urAlI~ 2. O~ ~"''''~~~_il__'''_._III\OmII'''''''''~'"",-''''oI'''T_~ '- '''rk~TlOR ~""'~-~---"--r~""'''-PcIlr",,"-''''~_'' ~w..._""""..........,..-._ ""_'~" .._ , D~ ...<<~ __..~..._7....7Uu__ot~........rc__..._or~fI&.....- L Io),lQlO,lOll' ,AArtlN~~ ~~"""~~'oIt/"'~ l:l\odllllfr~~._~ ....-atl...............-er...-e ~.--.. ....., _"1. OOWlalE__- ----"'.........-.-__ OQl!J>>'iMlHllilOll-.l- [J~...",.: e-_....1...,..1IC 1M _11_-.... "'_~c.'" ___1_-.,... .....7c. .... _"'_,...,... ,.....~_......_'...tl"M8IIo&/oMl. .. CJI'I'I8M1'~~ ... CIIlUN2A1It>>nIlWC lGmlC.. SANG 110, CI' I.. ~'I;U#_ . ..r --, . . ~ ...... : ", - ~;... ;;t *~ 'i..i ,~~ . "l ,;4 ll\Hl( yOtJNG.S FOOD ~ -tw&( ,. ~ P4I!INI Of!..4oCOUl ~lDC: fa. ~~ A '. ....~. Cl'l 7lr. ~'Sl.ASl'_ Rl'CTNAN( ~~ , . 8UI'f'll( . .' .. 1... 1U/UPla~ em' Ct'A'l1I: '~""CCllE ~ RD.''''~ BOX 672 NEWI/'lLLE PA 17241 VU TeL t~IO<'o_~1lI( ( AQCn.lI/fO ~ f" 1YI'fi:ClI~ W. olU~QI<(~1'/:IH \.,. ~TICOllO#. .." - ~l1Ool OIQ4 ~ L '""C>lOYIHt~~: ~tritJl!ll.""'" llnA1bor..-- 0 -... 0.............- 0 -~ -..Ip........._......... 0 ~~ <:':"~ :>':~~'. ~..."'~, .' y.... ;", :...,f~" r.-- ,. '...i.1'..1 ...~ ". :.'.."" . '''':0- .~ . L rv.IA....CUllS:l.MIV.~~1H4""~__~.._.....~lNI_ ._..-___.o.-~ __..._..._-._._".1__"'.0.___..... ___..CllltlR_......._ ... ~-- Oft eltlttn& .~ at '~Y'Yanf. . ... __..vo.-r_ ',to~ ~.,_. , ::;::: '~f", laanc.~.~:,:~i~~~:~ \~..Qt 2'15 '.'. .' _.. RO C }wI:;~D . ,"', .."I,. U.a<.'J~ k..f"al' t..C'.'oILD Mil NATlo..w. UCC fDlANClNG ST A.TaAENT AAU;JiOMeNT (FQRM IJCC31 lnEv. crrmrnll .."". tI ~I._I.. I 1,;1~\<.'1~lall l:1'101.lS~ .',., " .,~.._ "_' .Q ~"U!"~Do\'r" .. ~-. ..... -~-.--.- II :-." .... ;' < r~~~.~ T I).. ,.... L' i j j i I I I j I j I j I I I I I i i ! j I ! I ! I ! , i i i ! 1 ! J I i i ! I i I i i .Deta~l report item #1 printed by: DOTTIE HOFFMAN on 2/22/01 ._______________________________J___________~_________--------_________________ --------------------------------J-------------~-------------------------------- PENNSYLVANIA Dee DETAIL REPORT DATA COVERAGE THROUGH FES OS, 2001 SEAFCH COMPLETE]) FEG 22, 2001 U8:59 AM (CST) ._~----------------------------------------------------------------------------- -------------------------------------------------------------------------------- Filing Location: SECRETARY OF STATE OF PENNSYLVANIA 308 NORTH OfFICE BUILDING HARRISBURG, PA. 17105-8722 Original Filing Number: Original Filing Date: 26811373 06/23/1997 Collateral: FURNITURE AND FIXTURES HEREAFTER ACQUIRED PROPERTY INVENTORY MACHINERY AND EQUIPMENT OTHER Debtor: KWAK, SANG HO RD 3 BOX 672 NEWVILLE, PA. 17241-0000 Additional Debtor: YOUNG'S FOOD MARKET RD 3 BOX 672 NEWVILLE, PA. 17241-0000 Secured Party: MELLON BANK NA BUSINESS BANKING LOAN CENTER PGH, PA. 15258-0001 TBE INFORMATION IN THIS REPORT IS PROVIDED IN CONFIDENCE SOLELY FOR YOUR USE IN EVALUATING ACTUAL OR CONTEMPLATED BUSINESS TRANSACTIONS INVOLVING THE BUSINESS ENTITY TO WHICH SUCH INFORMATION RELATES. NEITHER EXPERIAN NOR EXPERIAN'S SOURCES WARRANT THE ACCURACY, COMPLETENESS, CURRENTNESS, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OF SUCH INFORMATION. IN NO EVENT WILL EXPERIAN BE LIABLE FOR INDIRECT, INCIDENTAL, CONSEQUENTIAL OR SPECIAL DAMAGES RESULTING FROM THE USE OF SUCH INFORMATION. THE FOLLOWING DATA IS FOR INFORMATION PURPOSES ONLY AND IS NOT AN OFFICIAL RECORD. CERTIFIED COPIES MAY BE OBTAINED FROM THE PENNSYLVANIA DEPARTMENT OF STATE. ',),' VERIFICATION I, Joseph E. Sweeney, hereby certify that I am an Assistant Vice President of Citizens Bank of Pennsylvania I have the authority to make this verification on its behalf. I hereby verify that the factual averments contained in the foregoing complaint are true upon my personal knowledge or information and belief. I understand that this verification is made subject to the penalties of 18 Pa.C.S.A. ~ 4904 relating to unsworn falsification to authorities. 637979,] .)J, t HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION BY: JAMES T. SHOEMAKER ESQUIRE IDENTIFICATION NO. 63871 LAW OFFICES 600 Third Avenue Kingston, PA 18704 (570) 287-3000 ATTORNEY FOR PLAINTIFF MELLON BANK, N.A., now by assignment CITIZENS BANK OF PENNSYLVANIA 8 West Market St. Wilkes-Barre, PA 18701, f' .) IN THE COURT OF COMMON PLEAS ':~ OF CUMBERLAND COUNIY~; ~ " (> " , \_:~J n -0 ,-; .~'c OJ'' 1" I '1., rl-:~ CJ ( ) ,'/ :~" \ ,- \ - --T1 ,-) ~::- '''.< ... :,- )rn ~:':\ ." ~....~ .~- Plaintiff vs. CNIL ACTION -- LAW ~ .-# ItEPLEVIN ( '\ 0" SANG HO KW AK, Individually and d/b/a Young's Food Market, and YON HWA KWAK: 2208 Chatham Way Harrisburg, PA 17110, Defendants NO. OLf - Cl'al{c,-~ PLAINTIFF'S MOTION FOR WRIT OF SEIZURE The plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania, by and through its counsel, Hourigan, Kluger & Quinn, P.c., hereby submits, pursuant to Pa.R.C.P. 1075.1, its motion for writ of seizure, against the defendants, Sang Ho. Kwak, individually and d/b/a Young's Food Market, and Yon Hwa Kwak, as follows: 63g03 L 1 ,\. On even date herewith, the plaintiff is filing a complaint in replevin against the defendants, (A true and con"ect copy of plaintiffs complaint in replevin is attached hereto pursuant to Pa. R.C.P. No, 1075.1 (b), incorporated herein by reference pursuant to Pa. R.c.P. No. 1019(g) and marked as Exhibit "1.") WHEREFORE, the plaintiff prays this Court to enter an Order directing the Prothonotary to issue a writ of seizure to the Sheriff directing the Sheriff to seize the CollateraL Respectfully submitted, HOURIGAN, KLUGER & QUINN, P.C. BY: ~5-- James T. Shoemaker, Esquire ID No.: 63871 Counsel for the plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania 600 Third Avenue Kingston, PA 18704 Telephone (570) 287-3000 Facsimile (570) 287-8005 Dated: November l-.} , 2004 (,JXOJ LI 2 .)' VERIFICA TION I, Joseph E. Sweeney, hereby certify that I am an Assistant Vice President of Citizens Bank of Pennsylvania I have the authority to make this verification on its behalf. I hereby verify that the factual averments contained in the foregoing motion are true upon my personal knowledge or infem!ation and belief. I understand that this verificatio~ is made subject to the penalties of 18 Pa.C.S.A. S 4904 relating to unsworn falsification to authorities. j-t/r 637979, t ) HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION BY: James T. Shoemaker, Esquire IDENTIFICATION NO. 63871 LAW OFFICES 600 THIRD AVENUE KINGSTON, PA 18704 (570) 287-3000 ATTORNEY FOR PLAINTIFF MELLON BANK, N.A., now by assignment CITIZENS BANK OF PENNSYLVANIA 8 West Market St. Wilkes-Barre, PA 18701, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff Ys. CIVIL ACTION -- LAW REPLEVIN SANG HO KW AK, Individually and d/b/a Young's Food Market, and YONHWAKWAK: 2208 Chatham Way Harrisburg, P A 1711 0, Defendants NO. 2004 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 6379nl ~~. -i:XHIBIT 11/1J ,).' 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 THI~ OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE ALA WYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. COURT ADMINISTRATOR Cumberland County Court House Carlisle, P A 17013 (717) 249-1133 -or- PENNSYL V ANlA LAWYERS REFERRAL SERVICE P.O. Box 1086, 100 South Street Harrisburg, P A 17108 (Pennsylvania residents phone: 1-800-692- 7375 ; out-of-state residents phone: 1-717 -238-6715) HOURIGAN, KLUGER & QUINN, P.c. '-~; BY:~"~ James T. Shoemaker, Esquire Counsel for the plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania ,~; 637973.1 HOURIGAN, KLUGER & QUINN A, PROfESSIONAL CORPORATION Al LAN M KI lJ~,1 I.,' RICHARD M GOLORf l:;>(-j JOSEPH ^ I ACH RONALD V SANTQP^ JOSEPH E Io<lUGER JAMES T SHOEMAKE:R MICHAEL J KOWALSKI RICHARD M WILLIAMS Jl::.NNlrEh' L ROGE!~S 1.11 rZI- ,HY;' l'H t, U\JINN ,]I"> AR1HUR l PICCONE RleHM.!D S BISHOP nANIIl J OlSlAS10 DONAI [) C LIGORlt1 MICHU.Lf:. M. OUINN DAVID AIKENS, JR AMANOA V WRIGHT-KLUGER MICHAEL ^ LOMBARDO III LAW OFFICES C,[)I]I l\/'vU IllH~I)I.'1 [~ GOO THIRD AVE NUE 434 '-ACKAWANt>JA ^V[NlIF KINGSTON. PA 18704-5815 ~CR^NTON I--'A lH'lO:J ')();/! ('J-;(I) JI1(1-l::H 1 <1 (570) 287-3000 FACSIMILE (570) 287-8005 E-MAIL: hkq@hkqpc.com FACS1MIl E (fl70) <)61 ~:dJ7~) OF COUNSEL ROBERT C CORDARO ANDREW HOURIGAN JR 1948-1978 Ext 1126 Direct e-mail: ishoemaker(iil.hkqpc.com -ALSO MEMBER NJ BAR November 23, 2004 Sang Ho Kwak, Individually and d/b/a Young's Food Market 2208 Chatham Way Harrisburg, P A 17110 Property Address: Account No.: Young's Food Market, RD 3 Box 672 Newville, PA 17241 0805386-0101 IMPORTANT NOTICE THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED ]~OR THAT PURPOSE. UNLESS YOU, WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS NOTICE, DISPUTE THE VALIDITY OF THE DEBT, IT WILL BE ASSUMED TO BE VALID. IF YOU NOTIFY THIS OFFICE IN WRITING WITHIN THIRTY (30) DA YS THAT THIS DEBT, OR ANY PORTION THEREOF IS DISPUTED, WE WILL OBTAIN AND FORWARD TO YOU A VERIFICATION OF THE DEBT OR THE JUDGMENT AGAINST YOU. WE WILL ALSO PROVIDE, UPON WRITTEN REQUEST WITHIN THIRTY (30) DAYS OF THE DATE OF THIS NOTICE, THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR. - Very truly yours, _/' \ -,-'- '---~.... e , '--fames T. Shoemaker, Esquire JTS:je THIS NOTICE DOES NOT SUPERCEDE YOUR OBLIGATIONS UNDER THE FOREGOING NOTICE TO PLEAD 638028,2 :1' HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION BY: James T. Shoemaker, Esquire IDENTIFICATION NO. 63871 ATTORNEY FOR PLAINTIFF LAW OFFICES 600 THIRD AVENUE KINGSTON, PA 18704 (570) 287-3000 MELLON BANK, N.A., now by assignment CITIZENS BANK OF PENNSYLVANIA 8 West Market St. Wilkes-Barre, PA 18701, IN THE COURT OF COMMON PLEAS 01' CUMBERLAND COUNTY Plaintiff vs. CIVIL ACTION -- LAW REPLEVIN SANG HO KW AK, Individually and d/b/a Young's Food Market, and YON HW A KW AK : 2208 Chatham Way Harrisburg, P A 17110, Defendants NO. 2004 COMPLAINT The plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania (the - "Bank"), by and through its counsel, Hourigan, Kluger & Quinn, P.c., complains of the defendant, Sang Ho Kwak, IndividuaIIy and d/b/a Young's Food Market ("Mr. Kwak"), R.D. 3, Box 672, Newville, PA 17241, as follows: 63~Olg.1 .).' 1. The Bank is a Pennsylvania state chartered bank conducting business in the Commonwealth of Pennsylvania, having an office located at 8 West Market Street, Wilkes-Barre, P A 18711-01Ol. 2. Mr. Kwak is an adult individual with a last known address of2208 Chatham Way, Harrisburg, PA 17110. 3. Upon information and belief, Yon Hwa Kwak is deceased. 4. On or about May 28, 1999, the Bank made a loan to Mr. Kwak, individually and d/b/a Say-Ford Supermarket and Yon Hwa Kwak (jointly, the "Kwaks"), in the amount of $395,000.00, as evidenced by a note, disclosure and security agreement (the "Note"). (A true and correct copy of the Note is attached hereto as Exhibit "A" and incorporated herein by reference.) 5. In order to induce the Bank to make the aforesaid loan, Mr. Kwak granted the Bank a security interest in , among other things, his equipment, machinery, motor vehicles, furniture, fixtures, inventory, accounts and contract rights (collectively, the "Collateral"), as evidenced by a security agreement (the "Security Agreement") and as protected by certain UCC-1 financial statements (the "UCC-1 Financial Statements"). (A tme and correct copy of the Security Agreement and the UCC-1 Financial Statements is attached hereto as Exhibit "B" and incorporated herein by reference.) 6. The Note was not assigned, except as stated above. 7. Mr. Kwak defaulted under the terms of the Note by failing to make monthly payments of principal and interest due under the Note. 638018.1 2 ) . . 8. The fair market value of the Collateral is unknown, but is believed to be less than the amount due and owing the Bank by the Kwaks under the Note, 9. The Bank believes and therefore avers that Mr. Kwak has possession of the Collateral. 10. Mr. Kwak has failed and refused, despite repeated demands by the Bank, to pay the balance due under the Note or to deliver possession of the Collateral to the Bank:. 11. The balance ofthe Note as of October 26, 2004 was $320,245.20, consisting of principal in the amount of$311,149.22, accrued. interest in the amount of$8,512.74, and late charges in the amount of$583.24, exclusive of attorneys' fees :md costs. WHEREFORE, the Bank demands judgment in replevin in favor of the Bank and against the Kwaks in the amount of $320,245.20, plus interest from October 26,2004, attorneys' fees and costs, and requests this Court to enter an Order directing the Prothonotary to issue a writ of possession to the Sheriff directing the Sheriff to seize the Collateral. Respectfully submitted, HOURIGAN, KLUGER & QUINN, P.e. BY: ~S _'-- James T. Shoemaker, Esquire ill No.: 63871 Counsel for the plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania 600 Third A venue Kingston, P A 18704 Telephone (570) 287-3000 638018.1 3 .~, 1!;:]ii:::~:~~~~~~~~ll::ilill;l:i!lll:!::ijijjl!!lj!!j:jji::'::::"", $ 395,000.00 Promiso To Pay, FOR VALUE RECEIVED,and intending to be legally bound, Undersigned, as defined below, promises to pay to: Mellon Bank, N.A. ("Bank") or ils order at Harrisburg, Pennsylvania the sum of Three Hundred Ninety Five Thousand and 00{100 Dollars ($ 395,000.00 ), ~wilh interest on the outstanding balance from the date of: this Promissory Note ("Note") at the cate(s) ("Contractual Ratqs)") and in accordance with the repaymcnt schedulc specified belqw. Contractual Rate(s); Repayment Schedules. : o Interest at a rate per annum:which is % above Bank's Prime Rate, such rate to ch3nge from time to time as of the effective date of each announce<I change in such Prime Rate, shaU be paid when principal ~nts are due. Principal shall be paid in consecutive D;lODthIy installments of $ each, commencing 9n , and continuing thereafter on the i day of each month with the balance of the indebtedness, if n~t sooner paid, due and payable on : o Interest at a rate per annum which is % above the CD Rate, such rate to change from time to time as of the effective date of each change in or r~g of the CD Rate, shaU be paid when principal payments a~ due. Principal shall be paid in consecutive mdpthly installments of $ each, . I commencing on , and continu~ thereafter on the day of each month witli the balance of the indebtedness, if not sooner paid,. que and payable on I I o The principal balance ~f, together wilh aU accrued and unpaid interest, shaU be "paid on and interest at a rate per annum whicJ\i is % abov~ Bank's Prime Rate, such rate to change from time to time as of the effective date of each announced chaqge in such Prime Rate shall be paid on the day of eachj month commencing o~ , . .- I I o The principal balance ht' f, together with all _accrued and unpaid interest, shaU be pa' on . , and interest at a rate per annum which . % above the CD ~ate, such rate to .change from e to time as of the eff~e date of each change in or resetti~ of the CD Rate, shall be paId on the day of each ronth commencing on I o In no event shall the rate charged I' on this Note exceed . % per annum. I o The principal balance~ h f, together with all accrued and unpaid interest, shaU be pai on , and interest at the rate of % annum shall be paid on the day of each th commencing on IX! sA'" ~~est shall be calClJted at. the rate of A . c;n % ,per annum. Principal and ~terest shaU be paid in 17q consecutive mon~ installments of $ 3,'23,65 coch." . . . 'I --fit . , U"%1,t~'-ljl:9:n~!:li:!I:!::!;'!:!,:! ' 07/01/1999 ,and continuing thereafter on thc 1ST day of each month wilh lhe balance of the indebtedness, if nol s<Xl,ncr p..l1d, due and p..lyable on 06/01/2014 . During any penod that the <:Ontractual Rate(s) is reduced by 0.25% pcr annum, as d~.cnbcd elsewhere in this Note installments of princrl and interest shall instead be in 'the amounl of $ ,864.70 each. If the reduction in the OJntractual Ratc(s) is no longer in cffcct, the amount of installments of principal and interest shall return to and be thc same as the amount of such installments prior to the reduction in the OJntractual Rate(s). Undersigned shall pay Bank concurrently with the execution and delivery hereof, or Undersigned previously has paid Bank, an origi.nation fee I~~ $ .. ~, 950.00 , to compensate Bank for Its underwnting, ongmatloo and administration of the loan evidenced by this Note. This fee shall be deemed fully earned by Bank on the date hereof, shall not be refunded, and is in addition to any other fee~, costs or expenses which may be due and payable hereunder. Unless Undersi~:ned has authorized Bank to take payments out of a Mellon Oleck:ing Account, as set forth below Undersigned will mail or deliver to Bank the amount billed by Bank each month. Undersigned will mail or deliver the payments so that Bank receives all payments no later than the due date shown on each bill. o Undersigned authorizes Bank to take all payments of principal amI/or interest and/or other amounts due under this Note out of Undersigned's Mellon Olecldng Account Number . , titled in the name(s) of , on or after ~e _~ ~y of each ~nth. Undersigned will k:eep a suffiCIent balance In this account to cover the fuU amounts of all requir~ ~e?!S. At. its option, Bank may terminate UndeCSlgned s abilIty to use this service. This authorization shall remain in ~ffect until revoked by Undersigned in writing or until the loan CVlden<:ed by this Note is paid in full or until Bank has termin?ted Und(~rsi~ned's a~i1ity to use this service, as the case may be. Poor lo matunty, while this authorization is in effect and provided that Undersigned keeps a sufficient balance in this account to cover the full amounts of all required payments, the OJntractual Rate(s) shall be reduced by 0.25% per annum. This authorization will be effective even though this Note and the account may be titled in different versions of Undersigned's name. If the -Original principal amount of this Note is in excess of $10,000.00, or i:f U~dersigned is a corporation, ipterest shall be calcu~t~ on ~e.basis of a 360~y year and actual days elapsed. If the ongmal pnnclpal amount of this Note is $10,000.00, or less, and Undersigned is not a corporation, interest shall be calculated on the basis of a 365-day year or 366~y year, as the case may be, and actual days elapsl~. "Prime Rate" shall mean the interest rale per annum announced from time to time by Bank as its Prime Rate. The Prime Rate may be greater or less than other interest rates charged by Bank to ?ther borrowers. and is not sOlely based or dependent upon the mterest rate which Bank may charge any particular borrower or class of borrowers. . If a single certiti<:3te of deposit is held by Bank as collateral security for ~ i?debtedn~ evidenced by this Nole, as more fully desa;abed 10 the ASSIgnment of Deposit Account expressly referring to this Note! "CD Rate" s~lI meaQ, flIe interest rate paid by Bank 00 such certificat,e of depOSIt (the "~ifi~t~")' said CD Rate to be ";',' Page 1 of5 , ~y. I ;. I ., reset by Bank at each renewal of thc Ce[ufi~tc_ If more than onc certificate of deposit is hcld by Bank as collateral security for thc indcbtcdness evidcnced by this Notc, as marc fully described in the Assignmcnt(s) of Dcposit Account cxpressly referring to this Note, .CD Rate" shall mean the highcst of the intcrcst ratcs paid by Bank on such certificatcs of deposit (thc "Certificates"), said CD Ratc to be rcset at each rcncwal of each Certificatc. Late Charge, If any payment (including without limitation any regularly scheduled paymcnt, balloon paymcnt or final payment) is not paid within 15 calendar days after it is duc, Undersigned will pay a late charge of thc greater of $25.00, or three percent (3%) of the unpaid portion of the scheduled payment due (regardless of whether the payment due consists of principal and interest, principal only or interest only). Such late charge shall be in addition to any increase made to thc Contractual Rate(s) applicable to the outstanding balance hereof as a result of maturity of this Note or otherwise, as well as in addition to any other applicable fees, charges and costs. Default Rate(s); Post-Maturity Rate(s). Upon the occurrence of any Event of Default (as defined in this Note), at Bank's option, interest shaD accrue at a rate equal to two percent (2%) per annum above the Contractual Rate(s) until the earlier of the date that such Event of Default bas been cured or until and including the date of maturity hereof. After maturity, whether by acceleration or otherwise, interest shall accrue at a rate equal to two percent (2%) per annum above the Contractual Rate(s) until all sums due hereunder are paid. Interest shall continue to accrue after the entry of judgment (by confession or otherwise) at the Contractual Rate(s) until aD sums due hereunder and/or under the judgment are paid, except that after maturity or, at Bank's option, upon the occurrence of any Event of Default, interest shall accrue at a rate equal to two percent (2%) per annum above the Contractual Rate(s). Books and Records; Time of Essence. So long as Bank is the holder hereof, Bank's books and records shall be presumed, except in the case of manifest error, to accurately evidence at all times all amounts outstanding under this Note and the date and amount of each advance and payment made pursuant hereto. The prompt and faithful performance of all of Undersigned's obligations hereunder, including without limitation time of payment, is of the essence of this Note. _ Security Interest, Setoff and Assignments. To secure all amounts - at any time owing or payable under this Note and Undersigned's obligations hereunder, as well as to secure all costs and expenses incurred by Bank in the collection or enforcement of this Note or the -protection of any collateral securing this Note (including without limitation all advan~ made by Bank for taxes, levies, insurance, filing fees, and repairs to or maintenance of said coUateral), Undersigned hereby grants to Bank: a security interest in, lien upon, and right of setoff against, all deposit accounts, credits, securities, moneys, or other property of Undersigned which may at any time be in the possession of, delivered to, or owed by Bank, including any proceeds or returned or unearned premiums of insurance, and the proceeds of aU the foregoing property. Other property, real or personal, may secure this Note, as set forth in other documents and agreements. Undmigned aclmowledges and agrees that Undersigned shall renew, or cause to be renewed, the Certificate(s), if any, until the indebtedness evidenced by this Note has been paid in full. Undersigned further agrees that Undersigned will execute, or will cause to be executed, upon demand by Bank: any fioancing statements or other documents, including, without limitation, additft?oal Assignments of Deposit Account, which Bank: may deem oeocssary or desirable to evidence, perfect or maintain perfection of the security interests created in the Certificate(s) and any renewals, replacements and substitutions thereof. Additionul Tenus and Conditions 1. Cov6n8Irts. Undersigned c:ow:oants and agrees that until aU indebtcdl1<~ evidenced hereby has been paid in fuU, Undersigned shall: (a) maintain at aU timcs a positive tangiblc net worth; (b) (1) havc all Environmental Pcrmits nccessary for thc conduct of cach of Undersigned's businesses and operations, (2) conduet eaeh of Undersigmxl's businesses and operations in matcrial compliancc with aU applicablc Environmental Laws and Environmental Permits, (3) not permit to cxist any event or condition that requircs or is likely to require Undersigned under any Environmental Law to payor expend funds by way of fines, judgmcnts, damagcs, cleanup, n~mediation or the like in an aggregatc amount, thc payment of which could reasonably be expected to interfere substantia1l!y with normal operations of Undersigned or materially adversely lllffeet the financial condition of Undersigned, (4) notify Bank promptly upon becoming aware of any pending or threatened proceeding, suit, investigation, allegation or inquiry regarding any alleged event or condition that, if resolved unfavorably to Undersign<::d or any of Undersigned's subsidiaries or affiliates, is likely to cause Undersigned or any of its subsidiaries or affiliates under any Environmental Law to pay or expend funds by way of fines, judgments, damages, cleaning, remediation or the like, and (5) provide at Undersigned's cost, upon request by Bank, certificatiolllS, documentation, copies of pleadings and other informatiOIl regarding the above, all in form and content satisfactory to Bank:; (c) conduct each of Undersigned's businesses and operations in material compliance with all federal,litate or local laws, statutc:s, regulations, rules, ordinances, court or administrative orders or d1x:rees, or private agreements or interpretations, now or hereafter ill existence, directly or indirectly relating to or affecting Undersigned's businesses or operations; (d) use the proceeds of the loan evidCllGed hereby only for business purpose(s) specified to Bank at or prior to the execution hereof; (e) promptly notify Bank in writing .of any change in Undersigned's residence or Chief Executive Office; (f) purchase and maintain policies of insurance (mcluding 11l00d insurance) to protect against such risks and casualties, und in such amounts, as shall be required by Bank and/or applicable law, which policies shall (1) be in form and substance satisfactory to Ban1c, (2) at Bank's option, designate Bank: as loss payee and/Or as additional insured, and/or contain a lender's loss payable endorsement, and (3) be (or certificates evidencing ~;ame shall be) deposited with Bank; (g) (1) maintain and keep proper records and books of account in conformance with generally accepted accounting principles applied on a consistent basis in which full, true and correct entries shall be made of aU Undersigned's dealings and business affairs, (2) provide to Bank at Undersigned's cost, upon Bank's request, financial or other information, documentation or certifications (including without limitation clinnual and periodic balance sheets and income statements, personal financial statements, federal income tax returns, inventory reports (including a description of raw materials, finished goods, and the aging thereof, as applicable), and accounts receivable and payable aging reports), all in form and content satisfactory to Bank, and (3) permit, upon request by Bank, any of the officers, employees or representatives of Bank to visit and inspect any of Undersigned's properties and locations and to examine jts books and records and discuss the affairs, finances and accounts of Undersigned with representatives thereof, as often as Bank may ((:quest; (b) provide additional collateral at such times and having ~;uch value as Bank may request, if Bank: shall have reasonable grounds for believing that the value of the collateral securing the indebtedness evidenced by this Note has become insufficient to secure said indebtednessj (i) pay, upon demand by Bank, (1) all costs and fees pertaining to the filing of any financing, continuation or termination statements, mortgages, satisfaction pieces, judgments and any other type of document which Bank deems neoes:;ary or desirable to be filed with regard to security interests which secure the.. indebtedness evidenced hereby, regardless of whether such secirity interests were granted by Undersigned, and (2) aU oosts an<f~ incurred by Bank in Page20f5 .' .~~j,. r cOnnection with any collateral securing this Note (mcluding without limitation all advances madc by Bank for taxes, Ievics, insurance, repairs to or maintcnance of said collateral, apprai<>al or valuation of said collatcral, and dctcrmination of flood hazard), regardlcss of whcther such collatcral is owned by Undersigned; and (j) pay, upon demand by Bank, all amounts incurred by Bank in connection with any action or proceeding takcn or commenced by Bank to enforce or collect this Notc, including attorncy's fees equal to thc lesser of (l) 20% of the outstanding principal balance and intcrest thcn due hcrcundcr or $500.00, whichcver is grcatcr, or (2) thc maximum amount permitted by law, plus attorncy's costs and all costs of Icgal proceedings. 2. Events of Default. The occurrence of any of thc following shall constitute an "Event of Default" hcreunder: (a) default in payment or performance of any of the indebtedness or obligations evidenced by this Note or any other evidence of liability of Undersigned to Bank; (b) the breach by any Obligor (defined as Undersigned and each surety or guarantor of any of Undersigned's liabilities to Bank: as welt as any person or entity granting Bank. a security interest in property to secure any indebtedness) of any covenant contained in this Note or in any separate security, guarantee or suretyship agreement between Bank. and any Obligor, the occurrence of any default hereunder or under the terms of any such agreement, or the discovery by Bank of any false or misleading representation made by any Obligor herein or in any such agreement or in any other information submitted to Bank by any Obligor; (c) with respect to any Obligor: (1) death or incapacity of any individual or general partner, or (2) dissolution of any partnership or corporation; (d) any assignment for the benefit of creditors by any Obligor; (e) insolvency of any Obligor; (f) the filing or commencement of any petition, action, case or proceeding, voluntary or involuntary, under any state or federal law regarding bankruptcy, insolvency, reorganization, receivership or dissolution, including the Bankruptcy Reform Act of 1978, as amended, by or against any Obligor; (g) default under the terms of any lease of or mortgage on the premises where real or personal property securing the indebtedness evidenced by this Note is located; (11) the garnishment, tax assessment, attachment or taking by governmental authority or other creditor of any property of any Obligor which is in Bank's possession or which constitutes security for any indebtedness evidenced hereby; (i) entry of judgment against any Obligor in any court of record; (j) the assessment against any Obligor by the 'Internal Revenue Service or any other federal, state or local taxing authority of unpaid taxes, or the issuance of a levy or the entering of a lien in connection therewith; (k) change in control of or transfer of any interest in any Obligor ... (other than an Obligor who is an individual); (I) a determination by Banlc, which determination shall be conclusive if made in good faith, that a material adverse change has occurred in the financial -or business condition of any Obligor; (m) the maturity of any life insurance policy held as coltateral for the indebtedness evidenced by this Note by reason of the death of the insured or otherwise; or (n) default by Undersigned in the payment of any indebtedness of Undersigned or in the performance of any of Undersigned's obligations (other than indcbtedness or obligations evidenced by this Note or any other evidcnce of liability of Undersigned to Bank) and such default shalt continue for morc than any applicable grace period. 3. Acceleration; Remedies. Upon the occurrence of any Event of Default: (a) aU amounts due undcr this Note, including the unpaid balance of principal and interest hereof, shall become immediately due and payable at the option of Bank, without any demand or notice whatsoever; and (b) Bank. may immediately and without demand exercise any of its rights and remedies granted herein, under applicable law, or which it may otherwise have, against Undersigned or otherwise. Notwithstanding any provision to the contrary contained herein, upon the occurrence of an Event of Default as described in Section 2(f) hereo[, aU amounts due under this Note, inc:luding w.<..JUt limitation the unpaid balance of principal and inteccst hereof, shall become hnmediately due and payablc, without any demand, notice or further action by Bank whatsoever, and an action thcrcfor shaH immediately accruc. 4. Bank's Rights, Undersigned hcreby authorizes Bank, and Bank shall have the continuing right, at its sole option and di'iCretion, to: (a) do anything which Undcrsigned is required but fails to do, and in particular Bank may, if Undersigned fails to do so, obtain and pay any premiums payable on any policy of insurance rcquired to be obtained or maintained hereunder; (b) direct any insurer to make payment of any insurance proceeds, including any returned or unearned premiums, directly to Bank, and apply such moneys to any indcbtedness or other amount evidenced hereby in such ordcr or fashion as Dank may elect; (c) pay the proceeds of the loan evidenced by this Note 10 any or all of the Undersigned individually or jointly, or to such other person(s) as any of the Undersigned may direct, except to the extent otherwise provided in Section 6 hereof; and (d) add any amounts paidl or incurred by Bank: under Section 1(i), Section 1(j) or Section 4(a) to the principal amount of the indebtedness evidenced by this Note. 5. Authorization to Borrow. Undersigned hereby represents, warrants, certifies and covenants as follows: (a) If Undersigned is a corporation, that the person(s) signing below hold(s) the office(s) indicated below (and continue to hold such office(s) untiJI Bank has received notice to the contrary in writing from Undersigned), and that the Board of Directors of Undersigned has adopted resolutions providing that: (1) the person(s) executing and delivering this Note on behalf of Undersigned Ware authorized (i) to incur indebtedness and obligations on behalf of Undersigned by borrowing or making other financial arrangements with Bank from time to time, upon terms and conditions as they in their sole discretion deem desirable, (d) to mak:e, execute and deliver promissory notes, letter of credit agreements, security agreements, assignments, mortgages and aU other documents required by Bank in connection with the incurring of ind~tedness or obligations, and (ui) to assign and pledge as collateral security for any such indebtedness or obligations, now or hereafter existing, any real or personal property of Undersigned; (2) the actions of anyone or more officers of U ndersign<:d in borrowing money from Bank: heretofore for the account of Undersigned, in assigning or pledging any of Undersigned's property for the payment thereof, or in doing any other act in connection therewith are hereby ratified, confirmed and approved; and (3) said resolutions shall have the force of a continuing agreement with Banlc, and shall be binding upon Undersigned until a resolution am<~nding them shall have been duly and legally adopted and Bank: furnished a certified copy thereof. " '- ~ power of any of the partners to represent said firm, whether by expiration of the partnership agreement, by death or retirement of any partner, or the accession of one or more new partners, or othcrwise, and notwithstanding any othcr notice thercof Bank may receive, this authority shall continue to be binding upon cach of the Undcrsigned individually and upon their legal representatives, and upon Undcrsigned and its successors, until Bank has receivcd notice in writing to the contrary signed by one of the Undersigned or by Undersigncd's duly authorizcd agent (Rcceipt of such notice will not relieve any partncr of any liability arising from obligations incurred prior to Bank's receipt of such notice.), and (5) nothing herein shall be construed to limit the rights granted to a partner by law or by thc partnership agrecment, but all rights granted herein shall be in addition to such rights. 6. Definitions; Misceffaneous Provisions. (a) Undersigned waives (except where requested hereby) notice of action taken by Banle; and hereby ratifies and confirms whatever Bank: may do. Bank shall be entitled to exercise any right notwithstanding any prior exercise, failure to exercise or delay in exercising any such right. (b) Bank shall retain the lien of any judgment entered on account of the indebtedness evidenced hereby. Undersigned warrants that Undersigned has no defense whatsoever to any action or proceeding that may be brought to enforce or realize on any such judgment. (c) If any provision hereof shall for any reason be held invalid or unenforceable, no other provision shall be affected thereby, and this Note shaD be construed as if the invalid or unenforceable provision had never been a part of it. The descriptive headings of this Note are for convenience only and shall not in any way affect the meaning or construction of any provision hereof. (d) The rights and privileges of BanIc contained in this Note shall inure to the benefit of jts successors and assigns, and the duties of Undersigned shall bind all heirs, personal representatives, successors and assigns. (e) This Note shaD in aU respects be governed by the laws of the state in which this Note is payable (except to the extent that federal law governs). (f) Undersigned hereby irrevocably appoints Bank and each holder hereof as Undersigned's attorney-in-fact to endorse Undersigned's name to any draft or check: which may be payable to Undersigned in order to collect the proceeds of any insurance or any returned or unearned premiums in respect of any policies of insurance required to be maintained hereunder. Undersigned hereby acknowledges that this appointment of Bank and each holder hereof as attorney-in-fact is irrevocable and is coupled with an interest. (g) Undersigned assigns to Bank all moneys which may become payable on any policy of insurance required to be maintained under this Note, including any returned or unearned premiums. (h) "Environmental Law" means any _ federal, state or local environmental law, statute, regulation, rule, ordinance, court or administrative order or decree, or private agreement or interpretation, now or hereafter in existence, relating to the manufacture, distribution, labeling, use, handling, collection, storage, treatment, disposal or otherwise of Hazardous Substances, or in any way relating to pollution or protection of the environment or public health. (i) "Environmental Permit" means any federal, state or local permit, license or authorization issued under or in connection with any Environmental Law. (j) "Hazardous Substances" means petroleum and petroleum products, radioactive materials, asbestos, radon, lead containing materials, sewage or any materials or substances defined as or included in thc dcfinition of "hazardous wastes,. "hazardous substances," "hazardous materials," "toxic substances," "hazardous air pollutants," "toxic pollutants," "pollution," or terms of similar meaning, as those terms arc uscd in any Environmental Law. (k) "Chicf Exeeutivc Office" mcans the place from which thc main part of the business operations of an entity is managed. (I) "Undcrsigncd" refers individually and collcctively to all makcrs of this Note, including, in :thc case of any partnership, all gcneral partners of such partner.iliip individually and coDectively, whether or not such partners sign below. Undersigned shaU each be jointly and severally bound by the terms hereof, and, with respect to any partnership (Jrccuting this Note, each general partner shall be bound hereby both in such general partner's individual and partnership capacities. 7. Direction tGI Pay Proceeds.Undersigned hereby authorizes and directs Bank: to pay the proceeds of this Note by: . ' .~ ft " 1.),~7'1;'cI,1 f/I 1)6./,: creditiogAceount Number oco- vl. 777 I (JIll LU in the name of / / 5{1N6 UO ~DtJ JfWit K\J!f(\. in tile amoun:t 0($ I . . _I I R 5 q 00 b/.ljl-Jt?Cj mtl/clV ''{7)paying fh.0m :fi (PI' 2. ID}-fJ7:J#f2 G,cjS- _ /'\ A ""rI :t1,3 J .305.3- iUq '<2-1 lL the amount of $ . ~ying f)lf1JtJ/CnL! 9/;)tjt/-/P'l the amount 0:[ $ 8. Affidavit ofJ'3usiness Loan.(1bis Affidavit is not applicable if Undersigned is a corporation.) Undersigned, being duly authorized, d'~pose(s) and say(s) under penalty of perjury that Undersigned: . (a) WAre elligaged in business astXI Owoer(s), 0 General Partner( s) of: (name and nature of business) YOUNG~?ooD MARKET AND . SAY-F<>fW- SUPERMARKET 'I (. y 1'- FOOD MARKET (b) Hereby make(s) application to Bank for a loan, the proceeds ofwrnch will be utilized for the purpose(s) of REFINANC]~ MELLON DEBT, OTHER DEBT CONSOLID1~TION & EQUIPMENT & INVOICE PURCHASE (c) Exercise(s) actual control over the managerial decisions of the business. (Remainder of page intentionally lell: blank) .....1.. ':~V' Page40f5 .~; . . '.,i, r "- 9~ Confession of Judgment. UNDERSIGNED HEREBY EMPOWERS TIlE PROTIlONOTARY OR ANY ATIORNEY OF ANY COURT OF RECORD TO APPEAR FOR UNDERSIGNED AND TO CONFESS JUDGMENT AS OFTEN AS NECESSARY AGAINST UNDERSIGNED IN FAVOR OF TIlE HOLDER HEREOF, REGARDLESS OF WHETHER ANY EVENT OF DEFAULT HAS OCCURRED, AT ANY TIME AND AS OF ANY TERM, FOR TIlE OUTSTANDING PRINCIPAL BALANCE HEREOF l'LUS INlEREST DUE UNDER nlE TERMS HEREOF AND ALL OTIffiR AMOUNTS DUE HEREUNDER, TOGETIlER WIlli COSTS OF LEGAL PROCEEDINGS AND AN ATrORNEY'S COMMISSION EQUAL TO TIlE LESSER OF (A) 20% OF TIlE OUTSTANDING PRINCIPAL BALANCE AND INTEREST TllEN DUE HEREUNDER OR $500,00, WIIICIIEVER IS GREATER, OR (13) TIlE MAXIMUM AMOUNT PERMITTED BY LAW, WIlTI RELEASE OF ALL ERRORS. UNDERSIGNED WAIVES ALL LAWS EXEMPTING REAL OR PERSONAL PROPERTY FROM EXECUTION. By signing this Note, Undersigned agrees to all terms of the Note and swears, under penalty of perjury (as set forth in 18 Pa.C.s. ~904, if governed by Penn$ylvanla law), to the Amdavit of BIllslness Loan (If completed) set forth In Section 8 ofthis Note. Witness the due execution hereof under seal. x Witness: :itne~~ -- Mdlon Banlc, NA Mellon Banlc (DE) National Association CL-4S0 Rev.(IQfJ6) LC. 9196 ill 9196 0275 r 166~-3823 1 d4S43(OI) OS2799.160S ~)Z~l' . -- X ~ . \ . eat) , , D/B/A~U 's FOOD MARKET AND _ _ _ sAy -F ~T S"fi i - FL- /:?_J. S.:- / '?,F<"~?7,.i I.! I( ,2 / 672 B ERVILLE ROAD . / / NEWVILLE, PA 17241 } lL- 7K- Individual: ~~AK IJ.vp- I~~ (Seal) 672~LOSERVILLE ROAD NEWVILLE, PA 17241 -,;~;;- Page 5 of 5 .t; .,. '). ' For value received, and intending to be legally bound, in consideration of a loan or other credit accommodation in the amount of Three Hundred Ninetv Five Thousand and 00/100 Dollars ($ 395,000.00 ) made by Mellon Bank. N.A. ("Bank") to SANG HO KWAK, INDIVIDUALLY AND ~/~S FOOD ~ ~ SAY- . SUPERMARKET V ("Borrower(s)"), said obligation evidenced by a ~ROMISSbRY NOTE dated ~ --:;-- Ol-fi. '1 '1 , (the "Note") Undersigned, intending to be legally bound, hereby agrees as follows: 1. Security Interest. Undersigned hereby grants to Bank a security interest in the following property now owned or hereafter acquired by Undersigned: (Certain terms used herein are defined in Section 13 below.) IX) ~ ~ /(a) aU equipment, wherever located, including ma ry, m tor vehicles, furniture and fixtures; IX) ~ r'f;n inventory (whether held for sale or lease or to be . Cd under contracts of service), raw materials, work: in process, and materials used or consumed in the conduct of Undersigned's business, and all books, records, invoices or other documents which describe or evidence the same; . IX) c-'P Y &Y all accounts, contract rights, general intangibles, ~ chases in action, instruments, documents (including all documents of title and warehouse receipts) and all rights to the payment of money, however evidenced or arising; o (d) all securities; all cash, stock or other dividends or distributions paid upon or made in respect of such securities in any form; aU securities received in addition to or in exchange for such securities; and all subscription rights incident to such securities; 0- (e) all farm products; and o (I) all property or rights described below under the caption "Description of Collateral." Description of Collateral (Give a sufficiently detailed description to identify each item), In addition to the foregoing, Undersigned: (1) grants to Bank a security intereS1t in all accessions, parts, accessories, attachments and appurtenances in any way used with, attached or related to, or installed in, or intended to be so used, attached, related to or installed in, any equipment or inventory constituting "Collateral" hereunder; (2) grants to Bnnk a security interest in all substitutions for, renewals of, improvements, replacements and additions to, and the products and proceeds (cash and non-cash) of all of the foregoing property and any insurance policies relating thereto; (3) grants to Bank a security interest in, lien upon, and right of setoff against, all deposit accounts, credits, securities, moneys or other property of Undersigned which may at any time be in the possession of, delivered to or owed by Bank, including any proceeds or returned or unearned premiums of insurance, and the proceeds (cash and non-cash) of all the foregoing property; and (4) assigns to Bank all moneys which may become payabk: on any policy of insurance required to be maintained under this Agreement, including any returned or unearned premiums. All such property subject to Bank's security interests described in this Section 1 is referred to herein collectively as the "Collateral." With respect to Section 4 hereunder, the term "Collateral" shall not include the property dCliCribed in Subsection (3) of this Section 1. All security int<<:rests in Collateral shall be deemed to arise and be perfected unde,r and governed by the Uniform Commercial Code, except to the Q1ent that such law does not apply to certain types of transactions or Collateral, in which case applicable law shall govern. 2. Obligations Secured. The Collateral shall secure the following obligations ("Obligation(s)"): (a) all amounts at any time owing or payable under the Note, and any other indebtedness, liability or obligation ofBorrower(s) or of Undersigned to Bank, now existing or Page 1 of 4 in addition to the rights given to Bank in this Agreement, Bank shall have all the rights and remedies of a secured party under any applicable law, including without limitation, the Uniform Commercial Code. 8. Additional Representations. In addition to the representations and warranties set forth elsewhere in this Agreement, Undersigned hereby makes the following representations and warranties which shall be true and correct on the date of this Agreement and shall continue to be true and correct at the time of any borrowing under any line of credit with Bank and until the Obligations secured by this Agreement shall have been paid in full: (a) each account: (1) represents an amount actually owing to Undersigned by the account debtor (less discounts allowed for prompt payment); (2) is valid and enforceable according to its terms without further performance of any kind; (3) is not evidenced by any instrument or chattel paper unless the original of such instrument or chattel paper has been deposited with Bank; and (4) is not evidenced by any judgment unless such judgment bas been assigned of record to Bank; and (b) the locations of all of Undersigned's places of business are as stated below, and the inventory and records of the accounts are kept at the places indicated below. 9. Additional Covenants. In addition to the covenants set forth elsewhere in this Agreement, Undersigned covenants and agrees that until the Obligations secured by this Agreement have been paid in full Undersigned shall: (a) immediately notify Bank in writing in the event that any of the following occurs: (1) any account is or becomes entitled or eligible for discount for prompt payment; (2) any account debtor bas or may have any defense to payment of, or right of setoff, counterclaim, or recoupment against any account; (3) any account represents an amount which is disputed by the aCcount debtor or the payment of which is in any way contingent or conditional; or (4) the desirability, usefulness, or marketability of any of the inventory bas been in any way reduced or impaired by reason of physical deterioration, technical obsolescence, or otherwise; (b) keep accurate and complete books and records in accordance with generally accepted accounting principles and, at Undersigned's expense, promptly furnish Bank such information and documents relating to the Collateral at such times and in such form and detail as Bank: may request, including without limitation: (1) copies of invoices or other evidence of Undersigned's accounts and schedules showing the aging, identification, reconciliation, and collection thereof; (2) evidence of shipment and receipt of goods and the performance of services or obligations covered by accounts; and (3) reports as to Undersigned's inventory and purchases, sales, damage, or loss thereof; all of the foregoing to be certified by authorized officers or other employees of Undersigned; (C) not change any location listed below regarding places of business, inventory and records of accounts without Bank's prior written consent; (d) at Undersigned's expense, diligently collect the accounts on behalf of Bank: until such time as Bank exercises its right to direetly collect the accounts, and upon notice from Bank, deliver all proceeds of accounts to Bank forthwith upon receipt, in the original form in which received; (e) immediately upon Bank's request, open a cash collateral account ("Cash Collateral account") at Bank and deposit therein all cash proceeds of collections on the accounts; (f) immediately upon Bank's request, give the Bank assignments, in form acceptable to Bank, of specific accounts or groups of accounts and specific general intangibles, and immediately repay the amount loaned against any account so assigned to the Bank if the contract with the account debtor is breached, cancelled or terminated; (g) immediately upon Bank's request, furnish Bank: with all information received by Undersigned regarding the financial condition of any account debtor, except to the extent prohibited by law; (h) immediately deliver to Bank all instruments, documents or chattel paper representing any of the Collateral and immediately assign of record to .Bank any judgment representing any account constituting Collateral; and (i) immediately upon Bank's request, mark its records evidencing its accounts in a manner satisfactory to Bank so as to show which accounts have been assigned to Bank. 10. Additional Rights of Bank. In addition to the Bank's rights set forth elsewhere in this Agreement, Undersigned hereby authorizes Bank, and Bank shall have the continuing rights at any time, whether or not any defllult has occurred under this Agreement, and at its sole option and dis<:retion, without notice, to: (a) take over and collect any or all of the accounts and to take any other action pursuant to its power of attorney granted herein; (b) exercise absolute and exclusive dominion and control over all funds deposited in the Cash Collateral account; apply any funds therein against any Obligations; and charge to any deposit account ot Undersigned any Item ot payment credited to the Cash Collateral account which is subsequently dishonored; (c) at any reasonable time, through its authorized agents and employees, inspect, audit, and verify the accounts and the inventory, review Undersigned's books and records, and copy or make excerpts from any document; and (d) verify accounts with debtors in the name of Undersigned, Bank, or Bank's designee. 11. MisceUaneous Provisions. (a) Undersigned waives protest of all commercial paper at any time held by Bank on which Undersigned is in any way liable, notice of nonpayment at maturity of any and all accounts, and (except where requested hereby) notice of action taken by Banle; and lI1ereby ratifies and confirms whatever Bank may do. The rights and remedies of Bank: hereunder are cumulative. Bank: shall be entitl4~ to exercise any right notwithstanding any prior exercise, failure to exercise or delay in exercising any such right. (b) If any provision hereof shall for any reason be held invalid or unenforceable, no other provision shall be affected thereby, and this Agreement shall be construed as if the invalid or unenforceable provision bad never been a part of it. The descriptive headings of this Agreement are for convenience only and shall not in any way affect the meaning 01' construction of any provision hereof. (e) The rights and privileges of Bank contained in this Agreement shall inure to the benefit of its successors and assigns, and the duties of Undersigned shall bind all b:irs, personal representatives, successors and assigns. (d) No modification of this Agreement, nor any waiver of any provision hereof, shall be effective or enforceable unless set forth in writing and sigr,led by an officer of Banlc. (e) This Agreement shall in all respects bl: governed by the laws of the state where the Obligations are payable as reflected in the document(s) evidencing such Obligations (except to the extent that federal law governs), and all references to the Uniform Commercial Code shall be deemed to refer to the Uniform Commercial Code as enacted in such state. (f) Undersigned hereby irrevocably appoints Bank and each holder hereof as Undersigned's attorney-in-fact to: (1) endorse Undersigned's name to any draft or check: which may be payable to Undersigned in order to collect the proceeds of any. insurance or any returned or unearned premiums in respect of any policies of insurance required to be maintained. hereunder, and (2) tak:e any action Bank: de<:rns necessary to perfect or maintain perfeetion of any security interest granted to Bank herein, including executing any document on Undersigned's behalf. (g) Undersigned shall bear the risk of loss of, damage to, or destruction of the Collateral, and Undersigned hereby releases Bank from all claims for loss or damage to the Collateml caused by any act or omission on the part of Bank, except for willful misconduct. (h) The prOlhpt and faithful performance of all of Undersigned's Obligations hereunder, including without limitation, time of payment, is of the essence of this Agreement. (i) Copies or reproductions of this document or of any financing statem~Qt may be filed as a financing statement. 12. Additional Power of Attorney. In addition to the powers of attorney grantl~d to Bank by Undersigned elsewhere in this Agreement, Undersigned hereby appoints Bank and its officers, Page 3 of 4 10-20-'04 11:22 FROM- rA"l1Rli D<Io~ ...~(\ool...-Ii=j(iAd~) ud .".u..;-.ddrcs: .' :~:!AI/..G;1Itl ,.......- --',o.3l1OJ:m41F"::"";.., ~-':~ "EWjLL~, PA IWl . D<b1aI' lQJDC (klA IIlllllt em II' /rldMcIUIJ) .n~ wili., addr= lOUWC:" fO(Jl IWlCET .03 BOX ~ c.,.... NtlNllLE,.... 1124' J).b~ e.a.mc; (I~ fI.~C fllat If indiYidu.a!) ud m;aiUttt ~ _..~('"'" 1l&m<{.) (bot...",cfiat iClo.dMdIal} &<l4 __ ""'..nrllt ~t IllfD.....doo: ....Uon 1_, .... _lhllU ._,"" '-__ Cc<\C4r """ ....Ucn ..... c_c..~. .... 1~'-1270 "...sb.M'\lh, ." lSzsa.....Ol 1 Aalpeo(o) ~-......., ~., (Ioo1.._lIn' ltilodMdlAl) _ ~ ....oa:lIticyio...-InO'rmalia... ~Tn-"""- (_ihpPi"",*,): o ne_"Ddlror" * "S<aItalhnt'_ ~ ....~..~. o 'J1lo_~.Dd"S<al_"&l)"'_~ ...~,'~. C Elcbl<<Io'~JUIili4'- SEC'ORDJ PAlt'tl' SlCI't4:IU~(S) nil _ llll1lail-l1!I...rY lbo5a1lRllrC!ta....... Il;I porf.o<:Ia .....dlyr.c_,IA~(~.~\lIce.;..c"'))- ..c~~.=:.~61.......~ldcodq_~~_ "0" VI to/aldlu.e au..... ~ c- oIcadrHL.i-'" .--1.,. "'''='I.lA __-..cy Ill. p~- o ....... u.e ...u.......I............. 10 mla -"'<y_ O..........~. _~.'JIl-.rIl__mowd ... dJls -Gl)'. 4. aI<ad1..n)a:llD a..ed" Iol=>t:a ...~ Ju1:idJaJoa - [J_"", -a......__...~ [J _tile Jldo1Ar'.Ioc4..... ___ VI rClW)1W1ll1. c.[J wIoJQ.lt ~ otdaccdWcnl d-'-llI ~ 9. ill "hO:a. .....n1Jila&cra< _ "",,,0\l<l7 ~ (aloo <Icaadbo 101 ..-iAllla<:t',It~W(<hC:uh ~...,d_ ~ &::oalW... &lie ..tslaalllMMa. 'lafClDa<). ~r_~'A~t.oC ( ..u..l ~1(1Iao("', It .b.w.~ ~==='.,f;"~ a.~2~LCIl/.lSU>1I06 Il27S Il;&.l~ T-442 PB5/11 0-170 FlNANCINCST~ \l1lU'q1l'1~" c.4.E_vcx:.a JMI'01l:rANr-l'lca_a ~ !l''fto1(11)d,,,,, ......"I~ ftlIGe No. (ttaJIlP"l by CDIIC olf."'*:1!"..'?: ~~l.UaIpcd ~ w..; ~ :'"', ':!':, ~t:. ~ vi' DEEDS ;,:;:~.1'::'l!.AlJD COUNT~'-rA 1 ~ '9'/ JUH 20 fll'110 51 1 s JlIlI ~1I"'~" b~Sor\IJi<l&:puwam"'_\Ioil'um~' Cod<:, and II... llc1iI<d..-1IlIIIlc (doodc .JlpllClble~ o ~oC~O~"" o I'ralllallabcyaC_ IllI (cal_........OC~ _~_ ." 11> N.....l..l'Or M.llJloftaI n... (lC am lomd l' Ida.M'IllletJ a~!I.uo <:A.t11~ePl: COUA'fttAL YoadIJ- llf i1a,...!o<oc type; All. DalTll1l.'S RIeHl, Tlru. AlIlI I_Team. llIEfB ., lIll ISIEUTBt EllI~II(' III ACOI/lltE11. 1" ... TO AU. InEIlTlIllf UlCUO'IC '~Will ,III 16'QS$USal GaZI$), AaXlIJIlT$, lIPEl/ ~, ~ ,_'''Cleus, fIClCl,IofllT$. PlAna ..am, JlISfllJCfllT$, IIllTes, :lI<<Aff5. LaTElI$ oc .avICfS ~ ctallT. ~c:ar:~:. o:~,~::":..r::~~cJ~xn:u. II:llI'WII ..ocrlDl UIIIC"Go'11Cl 1_lUL\Ilce 'IlUCIU ... .Icx:aon Of TIE 'OCI:l:OlIlG ... AlL ClJAI.l~IU. CUI"'. IICHT.. IlaEOIEl AID PaIVIU!GI!' UlAn" TIlI.UO. a.uGI1_ ~11. , 1 II 22 :I lIlI (d>cd: OIIIylrdtsltal)lr.adllCll<ol.lk~ "",d!O..-...L ~Jdac..l.......w.;, Ihpp/iQtblc: 'tbcc:D1lolo::ndfa,_iIIdwIoa (-~1G(ClI)'- ", ,..'. a.O aapopooiocOCIO'''_'''-__ '.':. 1I.lIlI ,.,........fcilacc....""...lD:Iliae.~ _~- , . '0 ...,. acMsc:Iib:(~aIl~~l.tip.);'~__ ol[J -......tuA&._llocMkot__ ....;-~..lll4tW).1 da...odllocad.....J.c_..._ .: _' . dlt;~ roaIlllaw: -~ :M,~: :r1~1; ,'~ -, ~.... JIaaot__IJ((dla:I::-=) ODeodo O~ atJ'qt(.) Ibr a.oi!iE1llAlIII.'.:,,<';~: eo...rr. u_.......~~.,":> .~.-..~':,,; o Oaaib<d _JI<ld;daoal s-.. _-r__ (~~-'1i1)'o~.u;;Iau:ccite(~ . ~.~. .....r.....::;. ',,:,,~.., IlDrOlUiJGl'<<A:~. .' ~ ~.): SAlta 110 aIAlC .." .. -', ,.-- . ~.~_...~ "S FlDI'Ilo\1l1U ,. .,' 9 11 ~..~l; ,~:~.". u 11. JlBnlRNllaCBIPTTO: lieU..... lint, II.A- lusll\C$S tlnt.h~ La.. C_..r ',0. I. 3GllO . .,.cslo.r..... .... '$230'$lIIll AU": c.U.tonl \inN :-.":. " '.If. ~,IIl:.. .;., Q"';~. t"' :",lI 4i f;... )"':;. .-.'...:! -':":\i . ~ ;.~ . .. 1:1 OlUQtRr.L 00t'Y 2 = fII1 -.1._ ......r. -,. )' 10-20-'04 11:23 FROM- T-44Z P~6/11 U-170 ~ .Ii & .-d.:;.: , ~'cfDS .UI~iJf~LMID C13UHTY-Pl . 02 fiPR 5 fil'j 11 D2 ,'f -, ~.., > -'. ..' - ': ~'~. ,.' UCC FINANCING STATEMENT AMENDMENT Ll A?;;;.~ -~_..._~~ ;). ~~ ... 'laME" ""'Nt: OFCOlCT4ICT.' rull ~ _:::.::---- .... ~''''&<TTO: ___ C;.'I.... 1.4 d .__...,.....co :'::~":: t:'l1lI 1.-' Cw>W- .ICUCIJ/'IlI. ... lSZ34-JIlM aU.., taU.=al &h.c ..._~"-"-- C:.lI'7f'1l1 e. 11&: a.,,,: . 4- a~-------"--_._--""-~-""-- ~ "'w:,~___.......___..._.__..._...._--_. ~.....~..... ....................... ... O~ ..-~ c.............61...'JlII."...-......_.....ht......1,..~......._... .. ____-_.....lJ&>oo-orCJr-.""._-...II:I.--. --III."---I:S---"-'-" O~"""""-'-'- .........................-.;.......... C DElDI__ ..........,..... 0 Aaa-.. .,......."........... -- ....."............ ~......._ .....,..,___ ___...............fc. ........""..,....... "''!'_~'''' J44'..~ " ~,..--~.. ."-~*"'"I"-"''' .......,..."MClIQI. YQll:>>:l:"S FClOD ~ -- l........~... ~ f. __.....01__ ........-...-.- , ..J; '.) ~ "- ~"\M1'_ -- ~~ " -- ~ .. :. t' , ..._~ ~ -- l-Q;IK =-nor 1lD ._~ J<M 1';72 REWvILI.E .' ...... ..-.".... l'A.--' ,};7,241., tISol .,.. t_DII'l~G'." I~~ I"-"'~ 71. .-.- ~ ....., - ~ 0--. .. ---------- -- 0-- 0-.....- 0--_-__.0_ . --..;:.0' ~ . IlL .......~........ ~ ~,.... ~........IIC................ ...,........... ....._.................... .0.-........ ....-....... -... ~. ."..... .~............,.~O.W... ...,....,,....._~.....-._,......,.....,. - ~~"tC"ClilllCtCXu.:tIli l.Uor.ll......'4&I. ...c.... LD"" ...T1OkIoL UO:: _CIIolG Sta.-re...an- AM6~ Cl'c~ \,Ic:Q flleV, ll'7_ IIt_ . :'o.1&.r"'t1'" I l.7~,'h I~"I>> . "."... s "'Sncu ......Cfll l......n" ~(;r'- -- ""\~~-" )rOO J:-- C\Jl1Il , ~ iI- .a.J. .. 'r, 1-':.... . ~I :. .). Oct-20-2004 08:32am . P}.RTI~ ----n:bu.r name (lluit name umit indiWlun1) artd malllnt add=: . _ ~ lCIJAK,' SANe; /lo . . RP 3 !lOX m (. '7 :L- ,N~WVILLE. PA lr.241 Deb..... I\lIlIlC (ia&l. name flI'-1t if indMdual) and JlIlIiling add~ YDU!lG's Fooo MARKET IlO 3 sOl( ~ ",.... tlEllV(LlE, PA 17241 Dcblur nilii<' (IUl n.3me fllll Ie individUAl) and mllllin,addlar. 8ee1lftCl Partt(l-) JWIlC(I) (Wt lI11me fmt iCindividuaI) and addr<* w.- 50CIIrity 11Iu:ra1 infOrmation: Mellon aank~ M.A. ~fMG. W41*(ng Loan Centu ~ Mellon ~ ccnttr6 R~. 15'-1~70 Pltt$burgh. PA 1S2S!-O 01 1- Aalpec(.) of ~d p~ -Ca) (Ia.st name tIrst It lndLvld\1ll) ~ addteR fOt: &Cellrily Inlens( Intormation. Spcd81'1>>>u.'~ (cb<;QciCappncabk): [] 'the tuma "Pcbllx" 2.lld "Sccul'l:d Pant' IlloWI ~ allII "Lcuor,- fQI~1. C no cenu. "Oc:bc0l"' and "$ccuRxI1'Atty" 1l1ea4 "ColIci~. pd "CoatIpQr,WlQpcclNdy. o DdlC.x" JI'lnmmlUiuJ: UIl"Uty. S~CURED PARTY SIGNATDRE(S) 11ak aWccbco.t '-aw 1I1(11.nJy the 8eeue4 PuC"'~ lQ perfect II 1CCdn'1y InterelUn collat~ (check IIpp1icablc bQ.( <<)) - .. [] """idlted after a chao~ ot~e, Idcad1(y WClOrpcxate ~e of the Debtor. b. 0 as l.Q which lhc IIIJ"I blI& lapud.. eo attcad11ubJOQt to a .comly intCt'Cl:! III anufJur e4DDI;J In J'amsyJ.-an1a - o l'tbCll dlo colla~...l,.... m.,," to this 00Wl11. o wilen the: Deblor'lI aul.lmee 01' J>lacc ol:bvaIn_ lI'N )Roved to tIIi.I county. cl. aIt'eacfy '\IbJQ;t 10 a accdrlty Int<:ceat (a IUlOlhcr .)udodtctSo.. _ o wilen Ule caDate..l...... IIIO"H to Pcllll&)'lYaAl2. D wilen [he Dcbl6t'1 I6aaUoa "a h\01'H 10 PauIq'IVlIlIia. eoO wIilch.. ~ of thccoUaleal describo!d ia block 9, In...hkba 8Oattil)' lliIerect -- ~ti perfected Cabo dambc ~ III block 9, Ifplltl:lwod '&'ilk cuh ~ and lIot adcqUAtclt deterlbot on \b4 odgtmt fll1lUlallC 100teDWlt). Secured Party SltpAtu<:(lI) (requited Ol\ly lC~ca) ... d.ec:tcd above): MeLLON B ST.ucDARD POlU(- pCllU'(l'A Ucx::.l (Rd.3193) AppcovoI1>y~dCo_oDW<&1d< c>lP"".oytv&llia CL-2J2Jleor-(7M) LC. JIM U> 119' OZlS B 2S.t12:UU ~~f:~:~ _ 1 r ,-.1""129: '.00Z/008 F-210 t11'lMllCINU N'i~'TKMmT Uutrorm c.~.u Code Forni lJ<:c.l I' A :;) / JMPORTAr-IT - Please read lnstrucIioIIlI 1c..v1 V Q\r...rutl~ bt:fore completing Filln&1'1o. (sUlmpcrll')' (jlin~; offlCa): ~ !lil.8r': ~ ~~~ (Ilmnpc:d by 1iIin& oClJcet'): ::: ;",;r,~';1 :'::~"''''~r DEED' . ~. ~ .. _, ... c . v.. . . ... ::;" ~.l:; i:.;1 L A'(O COUNTY - f'A 1& ~91 JUI4 26 AI') 10 51 1 5 Thia FIwmc:lDg SI4/dDMlf. Is plUCRted toc- tiling"pumum11O tIIc UaiCol1ll CoIlUll<<Cial Cod~ and illO bc:fiI~ wlIhthc (du:c:bspPlkablcbol)= o ~tyoCthe~l~th. .~ '.""-,'"? o 1'rotlsonoU1yot _ . - : · ..,.. ' IllJ reaI~~otctJolBERllllio __ .~:.: <". ,- ......11 :I-oc Co'Jnly. Collllty. 6 7 8 1b 1a c V )}t.iO\"'" Num1l4'erMdlCfonCllShutl (fhay):' . _ o Uott>ds aJtcf.ealltk..tJloa{Max.\Qdi.an;~); OOLU..~~;:'i':J. ' Ickutlry ~ral by 1cell1lUldIbr r,yp.;: ,.,i, '~~.i~' :/'4 ,; ALL oeaTM'C _ICHT, Tt1t\.E. AND IllTElEST~"\lKET1\E1t IIOU OR HEREAFTER fOXISTIICG OR ~lcaulllEll.~ ,III AND. TO:ALL IIIVEIITQRY (INCUlOING ael1JRNEll Clll. REPOSSESSeD COODS)'; AcaJUIITS. OPEl( ACaurrS. GEN~sv.1.. IIlTAJ/GI9lfS, 'POClJI(EJITS-~'1;QfAn(L '''''Ell, INSTRlAEIlTS, IIOTES, DRJlfts. WTERS.ClR AO(jIUS Of CRl;DIt. RECEIVABlES, orltER >>tt'lIlTS (lI((NQ To llEaTOl~ FIXTURES. FURIlITlJll.E AID eQl./IPMl!Jl1~, ALL ~COIJC'(S Al/fI -CASH AIID llOlI-tIIS1t PRQCEEl)$ (111ClmUIQ JIISllRAlI~ 'OllelEs AIlD I'Rot:Ea)$) ~ TIlE RJIU:Q(llllG AlID AU .GUAlWlTtES. CLAIMS, RIGHTS, REKEOIES AI<<) P~:fVlt.EGES.lCu.nljl1::TIleIl.ETO. ~= ::.,. "1.~i,-'-'. ~:.'~ ." . .....1 t~~ .-Ll.' 3 IXJ (dlcckORly If ~ J'Klducu otdlecoll4Ceol ~ 8koCOYered- .ld-wyftla,"Ra1c$kt I(applicable: ~\'loI~ia,orllldllcb (d\eeltappropriatelx:lK(ea))-. . . r";,~ ",;';:.' . a. 0 etvpI p;uwiui:ortobcPaOu-': '~.' -' .~. b. I2I &oOO.w1skls,...,ot'_'IObcea=e,l(xt~ <>:"7 c. [J ~n>Is ottbcUke(UId~ol1llUiPs)"~OlI- d. a &<<011.... rcllu1ctrl& fr6II~ uic-..L;d";r;..~;,~ i1ae IIIcc (iadudin, ail.ad J") at lheweU1lead<< millCheod ()Q -;. ,.,.., ; .illo;",l< J '. ":.t . r," 9 IIIe rotlowia& l'elII estate: : ,;, RD 3 BOX 3U " $tn:c(.Addruc NEWllLE PA 1~4" ., DMc:riLod..: Dook _~;Ot(chcck;<d~~:O Dced5 OMongaa.::s. alPateet) ~ Cci'r ttJHtr€Rt:AlIo-'~f,'-P.~~ : . c.,unty. UaUQrm PAted ldenuild ~" ':"'H-.'-!'-.., . -~ ;.::.:,.~ o 0c:0cdbe4 011 Addlliaaal8heeL ,;". ~.. '.,' '.';;,. NIl...., ot~ ClWDCr (reql1ircd onl1l!~ P.!;~~ an'ln~ of rcooo1): In:nTORsi'cm-tu~S) ~ D ~'): ~c ..~ t\w:? ~~~,. ~ 1 ,..~,(~~... '5 fOOO flARm ' . . 10 13 ..... Ib R.BT:lJRN~ctm'TTO: Hellon Ilank, II.A. Busfness Ilai\kfng lOGn C~t..~, P.O. Box 3080 . PltccburQh, PA 15230-'5080 Attn: Collat..r.t Un(~ . 11 . .... ::.:~ ";. <I. 12 ORIGIRAL COPX' :I c:t.2l2 (Ill) OGOm.osos ,.;.~,. : ..... ....1. ....1. . ~. . .. ; '"'!, .' ,~" ,. , ~::~~,..)- :...~ 1i .-" 4-. ~( <.,,,'. "'f~. . ." .\.....:..::..;.;_l... .... ....,h,...-",.,.:. .-" .....,~~~... ."" " Oct-20-2004 08:32am '-:.~,;.~ ,..J "~'. ...~;.~ ,... AfI T~729 P.003/008 F-210 -:. . ,l...l? " ,..,.. , . - ".~" ,.'.. ,: I.EtDS .i.1/.1!JER~t~i'l C"UNTY~FA "D? ftPR "g MIl 02 v' . F(lUQW""~~""_~ ~ ..AIoCE" PHONe aI' CONTIoCt' 10."( ~ (~Onall UCC FINANCING STATEMENT AMENDMENT ~ '-.~ /~ -- a. SEHO ACl<HOWt,ECG...arrTOl l"'*- aM Add...., t1thlltl& ... af '.mtylv&n'. 8t.d;l\4IlS latIk(FIlI LUll CM~tr ".0. 1411 lOdO l'auturGll, J'A 1S23Q.30lllI "11m: (QUltent Ilnit THEAe Sf'Aet:lSF A NLY " __~ 11''''1''GIU<<fftJZ'' ~PlHo&tlQHCIIlfATnIOIl' ~lo . ....lIIooI oar **GI ... -... "... t;4?n ~_oI)~_a.,. .- . IWLBrAll'fIECOIIa a. O~ ~""'~~__il__"'_.__""""'__'Ml'-"""""T_,,""- . J- .lt1~~ ---""~""-"""'-"""-~M<Ilnf(""'.c...~-~~....~, __ ~,,",""-~""""'by-"'" ";;~"" ... D~ ,..,...~ -- "..........._7&"',...__ot~..hoIll.lIt__...._.._fI!N..- lL ~ ,MfY~ 'Iw.~....ac.-..o.--.,oItf"'-' CI\OdlInfr!!!!---'" 80W -a"'................ - el.-4oK ~................ C __1'. OQWloU-------...-..........-- OOl!l.D'iMMl.....,-- O~,-..:c:-_...7...,..__ _1I_d\ono4t........t...,.___fII_~..._7c. 111.._100_,&....... ,_h;_......_7..tl"u~ . "r .. CUlOI'lllNf re;:cI'ClwQllM,(l1>c ....~tpcW~ KHAK.. SANG 110r C/lI ... ~"l.AllT__ yOtJNGlIIS FOOD ~ noIIr....... ~:.: :11t~-i~i '~",'~~ ,_ '. . 1 ~ . l~ 7. ~~Ol'..com~'lICI'l: &. ~IW'E :. .~~. ~ 711. IIClMClu,tl.;s~_ ANT"""": " ~1WiI 1iUI'f'llC ,,~~ _ pn.....:f lJQjt 67:2 7a. TAl<~_Mr:.H ):oIllO'\.lIlfOflE> ~t1Orc - ~ 17"TlKC)II~ em' m:WILLE 'n. oIU~Qf~1IClN n...l1l 1~""CQlJE PA 117241 "" ~ToClOl~.'-..t ~ ~ OtQ4 ... .....(fIDUINl'~TCI\oIl..~: ~arIr Jt!lI........ IlootowbrIoJlkMrll 0-..-... 0.............- 0 --..-...,.......*__... O~~ ........:..... :;':-~ ~ . ~.".:. .,.... :, ......t........!'"' ,.' ,,;,.i. (,1 ,..... '. ;..f.... -- --.. ..- ~ ~^....; . ... lIMA "1<<CU*EOPuqy..~ ~ 'ltlG "'"bCWa<<_......... ._. ........;:;-.. ,_"'___ _..000__ __.._..._c..-._._"..T__~.o.___...... ....~___..ao~__""...._ ""'- ~TlCN'&_ '," ,"_, , 01\ (I~tn"" .ant ..t Ilenrdvtwnh '1IS;l\eU IlR\UI'IlI LIdtI CIlRUI'--------,- - . ... ~"vn_ .lNT.......w; "" .:'~~1~0lI:- : "{Wq( .CI ~~"NO~llA.T" 2?5 " BOll C MBEbD L;t.QC,7$ A~~"alt LC.'UI UJ Mjl ~TIONlJ. ucc fIN~C1NG STA11OaA~ AIJENOJwU;NT (FO~ ~~~, {t:\EV. G1mMl ""11' 11 ::'-1'_1" 1 \.:1~""~lall l~.U:t' ,'", '0 ..~,.' ' .~ ,ii :..' '..~;' .t..':;,".~ I ~... .,-.# L Detail report item #1 printed by: DOTTIE HOFFMA1\r on 2/22/01 . . ================================~============================================== PENNSYLVANIA uee DETAIL FEPORT DATA COVERAGE THROUGH FEG 05, 2001 SEAHCll C:()M[,LET1'~]} FEB 22, 2 () 0 ] 08 : ~) C) AM (C; T ) -------------------------------------------------------------------------------- --------------------------------------------------------------------------------- Filing Location: SECRETARY OF STATE OF FENNSYLVANIA 308 NORTH OfFICE BUILDING HARRISBURG, PA. 17105-8722 Original Filing Number: Original Filing Date: 26811373 06/23/1997 Collateral: FURNITURE AND FIXTURES HEREAFTER ACQUIRED PROPERTY INVENTORY MACHINERY AND EQUIPMENT OTHER Debtor: KWAK, SANG HO RD 3 BOX 672 NEWVILLE, PA. 17241-0000 Additional Debtor: YOUNG'S FOOD MARKET RD 3 BOX 672 NEWVILLE, PA. 17241-0000 Secured Party: MELLON BANK NA BUSINESS BANKING LOAN CENTER PGH, PA. 15258-0001 T~E INFORMATION IN THIS REPORT IS PROVIDED IN CONFIDENCE SOLELY FOR YOUR USE IN EVALUATING ACTUAL OR CONTEMPLATED BUSINESS TRANSACTIONS INVOLVING THE BUSINESS ENTITY TO WHICH SUCH INFORMATION RELATES. NEITHER EXPERIAN NOR EXPERIAN'S SOURCES WARRANT THE ACCURACY, COMPLETENESS, CURRENTNESS, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OF SUCH INFORMATION. IN NO EVENT WILL EXPERIAN BE LIABLE FOR INDIRECT, INCIDENTAL, CONSEQUENTIAL OR SPECIAL DAMAGES RESULTING FROM THE USE OF SUCH INFORMATION. THE FOLLOWING DATA IS FOR INFORMATION PURPOSES ONLY AND IS NOT AN OFFICIAL RECORD. CERTIFIED COPIES MAY BE OBTAINED FROM THE PENNSYLVANIA DEPARTMENT OF STATE. ,}' VERIFICA TION I, Joseph E. Sweeney, hereby certify that I am an Assistant Vice President of Citizens Bank of Pennsylvania I have the authority to make this verification on its behalf. I hereby verify that the factual averments contained in the foregoing complaint are true upon my personal knowledge or information and belief. I understand that this veJification is made subject to the penalties of 18 Pa.C.S.A. ~ 4904 relating to unsworn falsification to authorities. 637979,1 ',\" ' NO\} 3 G 2nul, t HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION BY: JAMES T, SHOEMAKER ESQUIRE IDENTIFICATION NO, 63871 LAW OFFICES 600 THIRD AVENUE KINGSTON PA 18704-5815 (570) 287-3000 ATTORNEY FOR PLAINTIFF MELLON BANK, N.A., now by assignment CITIZENS BANK OF PENNSYLVANIA 8 West Market St. Wilkes-Barre, PA 18701, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. crVIL ACTION -- LAW REPLEVIN SANG HO KW AK, Individually and d/b/a Young's Food Market, and YON HWA KWAK: 2208 Chatham Way Harrisburg, PA 17110, Defendants NO.(Jli-5q~ 2004 BRIEF IN SUPPORT OF PLAINTIFF'S MOTION FOR WRIT OF SEIZURl8: The plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania (the "Bank"), by and through its counsel, Hourigan, Kluger & Quina, P.c., hereby submits its brief in support of plaintiffs motion for writ of seizure against the defendants, Sang Ho Kwak, individually and d/b/a Young's Food Market ("Mr. Kwak") and Yon Hwa Kwak (jointly, the "Kwaks"), as foUows: I. HISTORY OF THE CASE The Bank is a Pennsylvania state chartered bank conducting business in the Commonwealth ofPcnnsylvania, having an office located at 8 West Market Street, Wilkes- Barre, Luzerne County, PA 18711. Mr. Kwak is an adult individual having a last known address 638041.1 >, of2208 Chatham Way, Harrisburg, PA 17110. Upon information and bclicf, Yon Hwa Kwak is deceased, On or about May 28, 1999, the Bank made a loan to Mr. Kwak, individually and d/b/a Say-Ford Supermarket and Yon Hwa Kwak (jointly, the "Kwaks"), in the amount of$395,000.00 as evidenced by a note, disclosure and security agreement (the . 'Note"). (A true and correct copy ofthe Note is attached hereto as Exhibit "A" and incorporated herein by reference.) In order to induce the Bank to make the aforesaid loan, Mr. Kwak granted the Bank a security interest in, among other things, his equipment, machinery, motor vehickles, furniture, fixtures, inventory, accounts and contract rights (collectively, the "Collateral"), as evidenced by a security agreement (the "Security Agreement") and as protected by certain UCC-l financial statements (the "UCC-l Financial Statements"). (A true and correct copy of the Security Agreement and the UCC-l Financial Statements is attached hereto as Exhibit "B" and incorporated herein by reference. ) Mr. K wak defaulted under the terms ofthe Note by failing to make monthly payments of principal and interest due under the Note. The fair market value ofthe Collateral is unknown, but is believed to be less than the amount due and owing the Bank by the Kwaks under the Note. The Bank believes and therefore - - avers that Mr. Kwak has possession of the Collateral. Mr. Kwak has failed and refused, despite repeated demands by the Bank, to pay the balance due under the Note or to deliver possession of the Collateral to the Bank. 63804 1.1 2 ~, The balance of the Note as of October 26,2004 was $320,245,20, consisting of principal in the amount of$311,149.22, accrued interest in the amount of$8,512.74, late charges in the amount of$583.24, exclusive ofattomeys' fees and costs. II. STATEMENT OF THE QUESTION INVOLVED WHETHER THE BANK IS ENTITLED TO POSSESSION OF THE COLLATERAL WHEN THE BORROWER HAS DEFAULTED UNDER THE TERMS OF THE NOTE? III. ARGUMENT Pa.R.Civ.P. No.1 075.1 sets forth the procedure for the issuance of a prejudgment writ of seizure after notice and hearing which is designed to be in accordance with the due process requirements enumerated in Fuentes v. Shevin. 407 U.S. 67,92 S.Ct. 1983,32 L.Ed.2d 556, reh. den., 409 U.S. 902, 93 S.Ct. 177,34 L.Ed.2d 165 (1972). The procedure set forth in Pa.R.Civ.P. No. 1075.1 is one of two means for obtaining the remedy of a prejudgment seizure of property in a replevin action. In appropriate cases, the plaintiff may cause a writ of seizure to be issued ex parte with notice and a hearing postponed until after the property is seized. See Pa.R.Civ.P. No. 1075.2. To invoke the remedy of a prejudgment seizure of property in a replevin action after notice and. a h~aring, the plaintiff must file a motion for writ of seizure. See Pa.R.Civ.P. No. 1075.1(a). The plaintiff may move for the issuance of a writ of seizure after the complaint has been filed, whether or not the complaint has been served. Pa.R.Civ.P. No. 1075.1(a). Upon the filing of the motion for issuance ofa writ of seizure, the court must fix the date and time for a hearing on the motion. See Pa.R.Civ.P. No. 1075.1 (a), A hearing on a motion for ()3~041.1 3 > a writ of seizure of the property in a replevin action must be held whether or not the defendant or other person found in possession of the property appears. See Pa,R.Civ.P. No, I075.1(e); see also Equico Lessors Inc. v. Ewing. 281 Pa. Super. 147, 152,421 A.2d 1190, 1193 (1980) (holding that prima facie right established by testimony of plaintiffs employees that property was deteriorating and in jeopardy). Pursuant to Pa.R.Civ.P. No. 1075.1(e), the court must initially make a determination at the hearing whether the notice required by Pa.R.Civ.P. 1075, or a reasonable attempt to give notice has been made. See 4 Goodrich Amram 2d S 1075 .1 (e): L (1991). If the court is satisfied that the notice requirements ofPa.R.Civ.P. No. 1075 have been met, the court must determine from the complaint, affidavits, testimony, admissions, or other evidence which may be received whether the plaintiff has established the probable validity of his claim and, if so, the court may order a writ of seizure to be issued upon the filing of a bond as provided by the Pennsylvania Rules of Civil Procedure. See 4 Goodrich Amram 2d Sl075.1(e):1. The rule does not mandate any particular form of hearing on the motion for a writ of seizure. It seems that all that is required is an opportunity for the plaintiff to show that the action is free of fraud, accident, or mistake, and that there is a probability that he or she may sustain his right to poss~ssion of the property. See 4 Goodrich Amram 2d S1075.1(e): I (1991). The hearing is not for the purpose of making a final determination on the merits of the plaintiffs claimed right to possession of the property, but merely for determining whether the plaintiff has a probable right to possession. See Hamilton Bank v. Seiaer. 22 D&C 3d 534, 537 (1982). 63804 LI 4 " Except where the sheriff is authorized by the plaintiff to leave the subject property in a replevin action with the defendant or any other person found in possession, the Pennsylvania Rules of Civil Procedure require the sheriff, upon service of the writ of seizure, to take possession of the subject property. See Pa.R.Civ.P. No. 1075.4(a); see also Mayer v. Chelten Ave. Bldg. Corp., 321 Pa. 193, 196, 183 A. 773, 774 (1936); General Motors Acceptance Corp. v. Bums, 25 D&C 2d 293, 296-300 (1961). Additionally, the form of the writ of seizure prescribed by the Pennsylvania Rules of Civil Procedure specifically directs the sheriff to seize the subject property. See Pa.R.Civ.P. No. 1354. Furthermore, ilt has been held that even a defendant who is properly in possession of the subject property by virtue of a valid lien is obligated to surrender possession to the sheriff. See Mitchell v. McKinnis, 284 Pa. Super. 469, 473,426 A.2d 142, 144 (1981) (noting that the defendant had no right to give a counter-bond and keep possession since his lien was fully protected by the plaintiffs bond). The sheriff must take physical possession of the property. The sheriff has the right to enter the defendants' house for the purpose of searching for tht: goods, provided that in so doing he does not exceed the limits prescribed by the law. See Kneas v. Fitter, 2 Serg & R 263, 264 (Pa. 1816); Mayer, 321 Pa. at 196, 183 A. at 774. The sheriff has the right to enter a door already opened and may even be authorized to break open doors and enter by force in order to execute the writ of seizure. See Commonwealth v. Temple, 38 D&C 2d 120, 127 (1965). However, the sheriff may use no more force than necessary and must exercise due care. Sce Mayer, 321 Pa. at 196, 183 A, at 774. The burden is upon the plaintiff in a replevin action to establish every material elemcnt of his case upon which an issue is raised unde:rhis pleadings, Blossom Prods. 63804 Ll 5 :v Corp. v. National Undclwear Co., 325 Pa. 383,387, 191 A.40, 42 (I937). The plaintiff must establish his right to possession of the subject property by a preponderance of the evidence. See Petition of Allstate Ins. Co., 289 Pa. Super. 329, 333,433 A.2cl91, 93 (1981). A claimant who asserts a lien and a right to possession until the lien is discharged is not required to prove a title in addition to the right of possession. See Griffin v. Keefer, 30 Dauph. Co. Rep. 315, 317 (1927). Once the plaintiff establishes his right to possession, the burden of proof shifts to the defendants to prove his right to retain possession. See Petition of Allstate, 289 Pa. Super. at 333, 433 A.2d at 93; Carroll v. Godding, 155 Pa. Super. 490,492, 38 A.2d 720, 721 (1944); Johnson v. Staples. 135 Pa. Super. 274, 280, 5 A.2d 433,436 (1939). IV. CONCLUSION In light of the foregoing, the plaintiff prays this Court to enter an Order directing the Prothonotary to issue a writ of seizure to the Sheriff directing the Sheriffto seize the Collateral. Respectfully submitted, HOURIGAN, ~~~UINN, P.c. BY: ~ James T. Shoemaker, Esquire ill No.: 63871 Counsel for the plaintiff, Mellon Bank, N.A., now by assignment, Citizens Bank of Pennsylvania 600 Third Avenue Kingston, PA 18704 (570) 287-3000 Telephone (570) 287-8005 Facsimile Dated: November L'~ ,2004 63804Ll 6 ,} It'\ili:G~~gmi~!g~ii:'f!gl~:iill'I'[illiil':li~~'i\\!i!1\lii'!tl: .-.......... .;.-;.._.;;........ "-:':':':':-:':':'::-.:' ..... .... ... H_O.. $ 395,000.00 Promise To Pay, FOR VALUE RECEIVEn,ar\d intcnding to be Icgally bound, Undersigned, as defincd belo\\', promises to pay to: Mellon Bank, N.A. ("Bank") or its order at Harrisburg, Pennsylvania the sum of Three Hundred Ninety Five Thousand and 00/100 Dollars ($ 395,000.00 ), :with interest on thc outstanding balance from the date of: this Promissory Note ("Note") at the rate(s) ("Contractual Ratqs)") and in accordance with the repayment sehedu1e specified bclqw. Contractual Rate(s); Repayment Schedules. : o Interest at a rate per annum:which is % above Bank's Prime Rate, such rate to cb:ange from time to time as of the effective date of each announcciI change in such Prime Rate, shall be paid when principal paym,ents are due. Principal shall be paid in consecutive qKmthly installments of $ each, commencing bn , and continuing thereafter on the i day of each month with the balance of the indebtedness, if n~t sooner paid, due and payaNeoo : j I o Interest at a rate per annuni which is % above the CD Rate, such rate to change trom time to time as of the effective date of each change in or r~ting of the CD Rate shall be paid when principal payments ar,~ue. Principal shall ~ paid in Consecutive mOfth1y installments of $ each, _ I commencing on , and continu~ thereafter on the day of each mooth witli the balance of the indebtedness, if not sooner paid,. 4ue and payable on I I i o The principal balance he~f, together with all accrued and unpaid interest, shall be 'paid 00 and interest at a rate per annum whi~ is % abov~ Bank's Prime Rate, such rate to change om time to time as of the eff~e date of each announced tha ge in such Prime Rate, shall be paid on the day of eachlmonth commencing on . I - I I o The principal balance ht' f, together with all _a<x:ruod and unpaid interest, shall be pai 00 ' . and interest at a rate per annum which . % above the CD Rate, such. rate to change from me to time as of the eff~ date of each change in or resetti~ of the CD Rate, shall be paid on the day of each tOOth commencing on ! o In no event shall the rate charged Ion this Note exceed % per annum. I o The principal balance htf' together with all accrued and unpaid interest, shall be pai on and interest at the rate of % annum shall be paid on the . day of each +th commencing on lXI S;~... ~~erest shalI be calcu.lted at' the rate of A., tin % per annum. Principal and ~terest shall be paid in 17q consecutive monthly installments of $ 3,923.65 each, co 00. .'rUire:-: 07/01/1999 , and continuing thereafter on Ihe 1ST d:1Y of c.1ch month with thc halancc of the indchtednes.~, if not S(xl!lCr paid, due and payable on 06/01/2014. During an)' pcnod that the Contractual Rate(s) i" reduced by 0.25% pcr annum, as d(~<;cribcd elsewherc in Ihis NoIe, installmcnts of princft and, interest shall instead be in Ihe amount o[ $ ,864. 70 each. If the reduction in the Contractual Ratc(s) is no longcr in effect, the amount of installmcnts of principal and intcrest shall return to and be the same as the amount of such installments prior to the reduction in the Contractual Rate(s). Undersigned shall pay Bank concurrently with the execution and de.li~ery. hereof, or Undersigned previously has paid Banlc, an ongmation fee of $ 3 , 950. 00 . to compensate Bank for its underwriting, origination and administration of the loan evidenced by this Note. This fee shall be deemed fully earned by Bank on the date hereof, shall not be refunded, and is in addition to any other fec~, costs or expenses which may be due and payable hereunder. . Unless Undersigned has authorized Bank to take payments out of a Mellon Olecldng Account, as set forth below Undersigned will mail or deliver to Bank the amount billed by Bank each month. Undersigned \1\~D mail or deliver the payments so that Bank receives all payments no later than the due date shown on each bill. o Undersigned authorizes Bank to take all payments of principal and/or interest and/or other amounts due under this Not,~ out of Undersigned's Mellon O1ecIdng Account Number ' , . titled in the name(s) of . . , on or after ~e _-;- ~y of each n;iOOth. Undersigned will keep a suffiCient balance In this account to cover the fun amounts of all required payments. At, its option, Bank may terminate Undersigned's ability to use this service. This authorization shall remain in effect until revoked by Undersigned in writing or until the loan evidenced by this Note is paid in full or until Bank has terrnin?ted Undersi~ed's a~ility to use this service, as the case may be. Pnor to matunty, while this authorization is in effect and provided that Undersigned keeps a sufficient balance in this account to eov<:r .the full amounts of all required payments, the Contractual Ra1le(s) shall be reduced by 0:25% per annum. This authorization ",ill be effective even though this Note and the account may be titled in different versions of Undersigned's name. If the original principal amount of this Note is in excess of S10,OOO.OO, or ii~ U~dersigned is a corporation, ipterest shall be calcul~tc:<l on ~~:. basIS of a 360-<fay year and actual days elapsed. If thc ongmal pnn'::lpal amount of this Note is SlO,OOO.OO, or less, and Undcrsigned is not a corporation, interest shall be calculated on the basis of a 365-<1ay year or 366-<1ay year, as the case may be, and actual days elapsed. "Prime Rate" shall mean the interest rate per annum announced from time to time by Bank as its Prime Rate. The Prime Rate may be greater or kss than other interest rates charged by Bank to ?ther borrowers. and is not sOlely based or dependent upon the mterest rate which Bank may charge any particular borrower or class of borrowers. . If a single certificate o( deposit is held by Bank as cotlateral securily (or t~e i?debt<:dnc:ss evidenced by this Note, as more fully descnbed U1 thc Assignment of ~posit Account expressly referring to this Note! "CD Rate" shall mean: (be interest rate paid by Bank on such certificate of deposit (the ..C&tjfi~te")' Said CD Rate to be '~}.-I ':':.' Page 1 of 5 ' ,- . ---r- ,I., . rcsct by Bank at each renewal of thc Cc(ufi~tc. If more than onc certificate of dcposit is held by Bank as collateral security for thc indcbtedness evidenced by this Notc, as marc fully dcscribed in thc A,>signmcnt(s) of Deposit Account cxpressly rcferring to this Note, "CD Rate" shall mean the highest of the interest rates paid by Bank on such certificates of deposit (the "CertifiC<l1es"), said CD Rate to be rcsct at each renewal of each Certificatc, Lato Chargo, If any pa)ment (including without limitation any regularly scheduled payment, balloon payment or final payment) is not paid within 15 calendar days after it is due, Undersigned will pay a latc charge of the greater of $25.00, or three percent (3%) of the unpaid portion of thc scheduled paymcnt due (regardless of whether thc payment due consists of principal and interest, principal only or interest only). Such late charge shall be in addition to any increase made to thc Contractual Rate(s) applicablc to the outstanding balance hereof as a result of maturity of this Note or othcrwise, as well as in addition to any other applicable fees, charges and costs. Default Rate(s); Post-Maturity Rate(s). Upon the occurrence. of any Event of Default (as defined in this Note), at Bank's option, interest shaU accrue at a rate equal to two percent (2%) per annum above the Contractual Rate(s) until the earlier of the date that such Event of Default has been cured or until and including the date of maturity hereof. After maturity, whether by acceleration or otherwise, interest shaII accrue at a rate equal to two percent (2%) per annum above the Contractual Rate(s) until all sums due hereunder are paid. Interest shall continue to accrue after the entry of judgment (by confession or otherwise) at the Contractual Rate(s) until all sums due hereunder and/or under the judgment are paid. except that after maturity or, at Bank's option, upon the occurrence of any Event of Default, interest shaU accrue at a rate equal to two percent (2%) per annum above the Contractual Rate(s). Books and Records; Time of Essence. So Ioi1g as Bank is the holder hereof, Bank's books and records shall be presumed, except in the case of manifest error. to accurately evidence at aU times all amounts outstanding under this Note and the date and amount of each advance and payment made pursuant hereto. The prompt and faithful performance of all of Undersigned's obligations hereunder, including without limitation time of payment, is of the essence of this Note. __ Security Interest. Setoff and Assignments. To secure all amounts at any time owing or payable under this Note and Undersigned's obligations hereunder, as well as to secure all costs and expenses incurred by Bank in the collection or enforcement of this Note or the -protection of any collateral securing this Note (including without limitation. aU advances made by Bank: for taxes, levies, insurance, filing fees. and repairs to or maintenance of said collateral), Undersigned hereby grants to Bank: a security interest in, lien upon, and right of setoff against, all deposit accounts, credits, securities, moneys. or other property of Undersigned which may at any time be in the possession of, delivered to, or owed by Bank, including any proceeds or returned or unearned premiums of insurance, and the proceeds of aU the foregoing property. Other property, real or personal, may secure this Note, as set forth in other documents and agreements. Undersigned acknowledges and agrees that Undersigned shall renew, or cause to be renewed, the Certifacate(s), if any, until the indebtedness evidenced by this Note has been paid in full. Undersigned further agrees that Undersigned will execute, or will cause to be executed, upon demand by Banle any financing statements or other documents, including, without limitation, additi<?Ml Assignments of Deposit Aooount, wbich Bank may deem I1<lCaS3IY or desirable to evidenoc; perfect oc maintain perfection of the security interests created in the Certificate(s) and any renewals, replacements and substitutions thereoL Additional Tcnns and Conditions 1. CownaRIs. Undersigned cxwenants and agrees that until all indcbtcdoc!iS evidenced hercby has been paid in full, Undersigned shall: (a) maintain at all times a positive tangible net worth; (b) (I) have all El:IVironmental Permits neccssary for the conduct of each of Undcrsi,gned's busines.<;cs and operations, (2) conduct each 01 UndcrsiglKd's businesses and operations in material compliancc with all <Ipplicable Environmcntal Laws and Environmental Permits, (3) not pcrmit to exist any event or condition that requires or is likely to require Undersigned under any Environmental Law to pay or expend funds by way of fines, judgments, damages, cleanup, [(:mediation or the like in an aggrcgate amount, the payment (]{ wbich could reasonably be expected to interferc substan~, with normal operations of Undersigned or materially adversely alfect the financial condition of Undersigned, (4) notify Bank: prompdy upon becoming aware of any pcnding or threatened proceeding, suit, investigation, allegation or inquiry regarding any alleged al:ol or condition that, if resolved unfavorably to Undersigned or any of Undersigned's subsidiaries or affiliates, is lik:ely to QIl1SC Undersigned or any of its subsidiaries or affiliates under any :Environmental Law to pay or expend funds by way of fines, judgments, damages. deaning, remediation or the like, and (5) provi&~ at Undersigned's cost, upon request by Bank, certifications, documentation. copies of pleadings and other information regarding the above, all in form and content satisfactory to Bank; (c) conduct each of Undersigned's businesses and operations in material compliance with aU federal, state or local laws, statute:$, regulations, rules, ordinances, court or administrative orders or dc:crees, or private agreements or interpretations, now or hereafter in existence, direct1y or indirectly relating to or affecting Undersigned's businesses or operations; (d) use the proceeds of the loan evideuced hereby only for business purpose(s) specified to Bank at or :prior to the execution hereof; (e) promptly notify Bank in writing It)f any change in Undersigned's residence or Olief Executive Office; (f) purchase and maintain policies of insurance (mcluding lllooc;l insurance) to protect against such risks and casualties, 2m in such amounts, as sfiall be required by Bank and/or applicable law, which policies shall (1) be in form and substance satisfactory to Bank, (2) at Bank's option, designate Bank as loss payee and/or as additional insured, and/or contain a lender's loss payable endorsement, and (3) be (or certificates evidencing lialIlC shall be) deposited with Banle; (g) (1) maintain and keep pmper records and books of account in conformance with generally accepted accounting principles applied on a consistent basis in which full, true and correct entries shall be made of all Undersigned's dealings and business affairs, (2) provide to Bank at Undersigned's, cost, upon Bank's request, financial or other information, documentation or certifications (including without limitation 2l1Ulual and periodic balance sheets and income statements, personal financial statements. federal income tax returns, ilMntory reports (including a description of raw materials, finished goods, and the aging thereof, as applicable), and accounts receivable and payable aging reports), all in form and content satisfactory to Bank, and (3) permit, upon request by Bank, any of the offioea, employees or reprcscntatives of Bank to visit and inspect any of Undersigned's properties and locations and to examine its books and reCords and discuss the affairs, finances and accounts of Undersigned with representatives thereof, as often as Banle may I'equest; (h) provide additional collateral at such times and having :such value as Bank: may request, if Banle shall have reasonable l:rounds for believing that the value of the collateral securing thc:: indebtedness evidcnced by this Note has become insufficient 10 iCCUre said indebtedness; (i) pay, upon demand by Eanle, (1) aU costs and fees pertaining to the filing of any financing, cootinuatioo or termination statements. mortgages. satisfaction picoes, judDnents and any other type of document which Bank: deems nOCClsaty or desirable to be filed with regard to security interests wllicb secure the 'indebtedness evidcnced hereby, regardless of whether such ~rity interests were granted by Undersignod, and (2) all costs an<fCxre.yses incurred by Bank in Page 20(5 .> '.~~;. ~ wnnection with any collateral securing this Note (induding without limitation all advances made by Bank for taxes, levies, insurance, rcpairs to or maintcnance of said collatcral, appraisal or valuation of said collateral, and determination of flood hazard), regardless of whether such collateral is owned by Undersigned; and (j) pay, upon demand by Bank, all amounts incurred by Bank in connection "..ith an)' action or proceeding taken or commenced by Bank to cnforce or collect this Note, including attorney's fees equal to the lesser of (1) 20% of the outstanding principal balance and intcrcst then duc hereunder or $500.00, whichever is grcater, or (2) thc maximum amount permitted by law, plus attorney's costs and all costs of legal proceedings, 2. Events of Default The occurrence of any of the following shall constitute an "Event of Default" hercunder: (a) default in payment or performance of any of the indebtedncss or obligations evidenced by this Note or any other evidcnce of liability of Undersigned to Banle; (b) the breach by any Obligor (defined as Undersigned and each surety or guarantor of any of Undersigned's liabilities to Bank as well as any person or entity granting Bank a security interest in property to secure any indebtedness) of any covenant contained in this Note or in any separate security1 guarantee or suretyship agreement between Bank and any Obligor, the occurrence of any default hereunder or under the terms of any such agreement, or the discovery by Bank of any false or misleading representation made by any Obligor herein or in any such agreement or in any other information submitted to Bank by any Obligor; (c) with respect to any Obligor: (1) death or incapacity of any individual or general partner, or (2) dissolution of any partnership or corporation; (d) any assignment for the benefit of creditors by any Obligor; (e) insolvency of any Obligor; (f) the filing or commencement of any petition, action, case or proceeding, voluntary or involuntary, under any state or federal law regarding bankruptcy, insolvency, reorganization, receivership or dissolution, including the Bankruptcy Reform Act of 1978, as amended, by or against any Obligor; (g) default under the terms of any lease of or mortgage on the premises where real or personal property securing the indebtedness evidenced by this Note is located; (h) the garnishment, tax assessment, attachment or taking by governmental authority or other creditor of any property of any Obligor which is in Bank's possession or which constitutes security for any indebtedness evidenced hereby; (i) entry of judgment against any Obligor in any court of record; (j) the assessment against any Obligor by the 'Internal Revenue Service or any other federal, state or local taxing authority of unpaid taxes, or the issuance of a levy or the entering of a lien in connection therewith; (Ie) change in control of or transfer of any interest in any Obligor - - (other than an Obligor who is an individual); (I) a determination by Banlc, which determination shall be conclusive if made in good faith, that a material adverse change has occurred in the financial -or business condition of any Obligor; (m) the maturity of any life insurance policy held as collateral for the indebtedness evidenced by this Note by reason of the death of the insured or otherwise; or (n) default by Undersigned in the payment of any indebtedncss of Undersigned or in the performance of any of Undersigned's obligations (other than indebtedncss or obligations evidenced by this Note or any other evidence of liability of Undersigned to Bank) and such default shall continue for more than any applicable grace period. 3. Acceleration; Remedies. Upon the occurrence of any Event of Default: (a) all amounts due under this Note, induding the unpaid balance of principal and interest hereof, shall become immediately due and payable at the option of Bank, without any demand or notice whatsoever; and (b) Bank may immediately and without demand exercise any of its rights and remedies granted herein, under applicable law, or which it may otherwise have, against Undersigned or otherwise. Notwithstanding any provision to the contrary contained herein, upon the occurrence of an Event of Default as described in Section 2(l) hereof., all amounts due undcc this Note, induding w....)ut limitation the unpaid balance of principal and interest hereof, shall become immediately due and payable, without any demand, notice or further action by Bank. whatsoevcr, and an action therefor shall immcdiatcly accrue. 4, Bank's Rig/Its, Undersigncd hercby authorizes Bank, and Bank shall have the continuing right, at its sole oplion and discretion, to: (a) do anything which Undersigned is required but fails to do, and in particular Bank may, if Undcrsigned fails to do so, obtain and pay an)' prcmiums payable on any policy of insurance required to be obtaincd or maintaino:J hereunder; (b) dircct any insurer to make payment of any insuran.:;e procecds, including any returned or unearncd prcmiums, directly to Bank, and apply such moneys to any indebtedncss or other amount evidenced hereby in such order or fashion as B<llnk may elect; (c) pay the proceeds of the loan evidenced by this Note 110 any or all of the Undersigned individually or jointly, or to such other person(s) as any of the Undersigned may direct, except to the extent otherwise provided in Section 6 hereof; and (d) add any amounts paid or incurred by Bank under Section l(i), Section 1(j) or Section 4(a) to the principal amount of the indebtedness evidenced by this Note. 5. Authorization to Borrow. Undersigned hereby represents, warrants, certifies and <:ovenants as follows: (a) If Undeniigned is a corporation, that the person(s) signing below hold(s) the office(s) indicated below (and continue to hold such office(s) until Bank has received notice to the eontrary in writing from Undersigned), and that the Board of Directors of Undersigned has adopted resolutions providing that: (1) the person(s) executing and deliverini~ this Note on behalf of Undersigned is/are authorized (i) to incur indebtedness and obligations on behalf of Undersigned by borrowing or making other financial arrangements with Bank from time to tilIl(:, upon terms and conditions as they in their sole discretion d<:em desirable, (Ii) to make, execute and deliver promissory Dotes, letter of credit agreements, security agreements, assignments, mortgages and all other documents required by Bank in connection wi:th the incurring of indebtedness or obligations, and (ill) to assign and pledge as collateral secUrity for any such indebtedness or obligations, now or hereafter existing, any real or personal property of Undersigned; (2) the actions of anyone or more officers of Undersigned in borrowing money from Bank heretofore for the account of Undersigned, in assigning or pledging any of Undersigned':, property for the payment thereof, or in doing any other act in connection therewith are hereby ratified, confirmed and approved; and (3) said resolutions shall have the force of a continuing agreement with Banlc, and shall be binding upon Undersigned until a resolution amending them shall have been duly and legally adopted and Bank furnished a certified copy thereof. (b) If Undersigned is a partnership, that (1) Undersigned's name shown below is a trade name of Undersigned's firm used in the conduct of an unincorporated business owned entirely bY the persons signing this Note on behalf of said partnership; (2) the partners executing and delivering this Note are authorized (i) to incur indebtedncss :and obligations on behalf of Undersigned by borrowing from or making other financing or credit accommodations with Bank from time to time, upon such terms and conditions as they in their sole discretion deem desirable, (ii) to make, execute, and deliver promissory notes, 1ctter of credit agreements, security agreements, assignments, mortgages and all other documents required by Bank in connection wi:lh the incurring of indebtedncss or obligations, and (iii) to assign an~ pledge as collateral security for any such indebtedncss or Obligatiolt~ :nOw or hereafter existing, any real or personal property of UlI1<krsigned; (3) the actions of anyone or more partners of Undersign<:d in borrowing money from Bank heretofore for the account of Undersigned, in assigning or pledging any of Undersigned'~ property for the payment thereof, or in doing any other act in (X)nncction therewith ace hereby ratified, confirmed, and appro-.tOO; (4) notwithstanding anY~odi~cation pc tenninatiOO of the -'. " rage 3 of 5 '~~;:' power of any of the partners to rcprcscnt said firm, whether by expiration of the partncrship agreement, by death or retirement of any partner, or the accession of one or more new partners, or otherwise, and notwithstanding any othcr notice thereof Bank may receivc, this authority shall continuc to be binding uJXJn eaeh of the Undersigned individually and uJXlI1 their legal representatives, and upon Undersigned and its sucecssors, until Bank has received notice in writing to the contrary signcd by onc of the Undersigned or by Undersigned's duly authorized agcnt (Receipt of such notice will not relieve any partner of any liability arising from obligations incurred prior to Bank's receipt of such notice,), and (5) nothing hercin shall be construed to limit thc rights granted to a partncr by law or by the partnership agreemcnt, but all rights granted hcrein shall be in addition to such rights. 6. Definitions; Misceflaneous Provisions. (a) Undersigned waives (except where requested hereby) notice of action taken by Banle; and hereby ratifies and confirms whatever Bank: may do. Bank shaD be entitled to exercise any right notwithstanding any prior exercise, failure to exercise or delay in exercising any such right. (b) Bank shall retain the lien of any judgment entered on account of the indebtedness evidenced hereby. Undersigned warrants that Undersigned has no defense whatsoever to any action or proceeding that may be brought to enforce or realize on any such judgment. (c) If any provision hereof shall for any reason be held invalid or unenforceable, no other provision shall be affected thereby, and this Note shall be construed as if the invalid or unenforceable provision had never been a part of it. The descriptive headings of this Note are for convenience only and shan not in any way affect the meaning or construction of any provision hereof. (d) The rights and privileges of Bank contained in this Note shall inure to the benefit of its successors and assigns, and the duties of Undersigned shall bind aU heirs, personal representatives, successors and assigns. (e) This Note shaD in all respects be governed by the laws of the state in which this Note is payable (except to the extent that federal law governs). (f) Undersigned hereby irrevocably appoints Bank and each holder hereof as Undersigned's attorney-in-fact to endorse Undersigned's name to any draft or check: which may be payable to Undersigned in order to collect the proceeds of any insurance or any returned or unearned premiums in respect of any policies of insurance required to be maintained hereunder. Undersigned hereby acknowledges that this appointment of Bank and each holder hereof as attorney-in-fact is irrevocable and is coupled with an interest. (g) Undersigned assigns to Bank all moneys which may become payable on any policy of insurance required to be maintained under this Note, including any returned or unearned premiums. (h) "Environmental Law" means any _ federal, state or local environmental law, statute, regulation, rule, ordinance, court or administrative order or decree, or private agreement or interpretation, now or hereafter in existence, .relating to the manufacture, distribution, labeling, use, handling, coltection, storage, treatment, disposal or otherwise of Hazardous Substances, or in any way relating to pollution or protection of the environment or public health. (i) "Environmental Permit" means any federal, state or local permit, liccnse or authorization issued under or in connection with any Environmental Law. (j) "Hazardous Substances" means pc:tnjcum and petroleum products, radioactive materials. ~ radon, lead containing matcrials, sewage or any malaials or substances defined as or included in the dcfinition of "hazardous wastes," "hazardous substances,. "hazardous materials: "toxic substances," "ha7.ardous air JXlllutants," "toxic pollutants," "pollution,. or tcrms of similar meaning, as those tcrms are used in any Environmental Law. (Ie) "Old Executive Office. means the place from which the main part of the business operations of an entity is managed. (I) .Undersigned" refers individually and collectively to all makers of this Note, including, in the case of any partnership, all general partners of such partnership individually and ooIIcctM:Iy, whether or not such partners sign below. Undersigned sball each be jointly and severally bound by the terms hereof, and, with respect to any partnership executing this Note, each ~ partner shall be bound hereby both in such general partner's individual and partnership capacities. 7. Direction Ita Pay Proceeds.Undersigned hereby authorizes and directs Bank: to pay the proceeds of this Note by: . . , .:tl' ',- ti crediting Aooount Number ()ti)-i.{;"l1 ~1 if tff, (y J; 2.8, . ~in~M~~ / / 511N6}/D ~orJ 1M/} K~frf'- in the amoullt 0[$ J ../ I 'f1 5 q 00 ' Gi./7hnCj m t//Cfl( ''{7Jpaying rnbmn :U(p/, 2., 1D/-fj7:J-/"2-&</J" 1" A l.Jr. ~3J ,3(;)5.3 if ,e; ~.z-q II the amount t)f$ . Rpaying f)ltJif/ G f} Li q /;/19 if. ~ tf the amount ofS 8. Affidavit of Business Loan.(1bis Affidavit is not applicable if Undersigned is a corporation.) Undersigned, being duly authorized, depose(s) and say(s) under penalty of perjury that Undersigned: . . (a) WAre engaged in business aslXI Owner(s), 0 General Partner(s) of: (name and nature of business) YOUNG' S FOOD MARKET AND . SAY-F~ SUPERMARKET if, 1"- FOOD MARKET (b) Hereby make(s) application to Bank for a loan, the proceeds of which win be utilized for the purpose(s) of REFINANCE MELLON DEBT. OTHER DEBT CONSOLIDATION & EQUIPMENT & INVOICE PURCHASE (c) Exercise(l;) actual control over the managerial decisions of ~ business. (Remainder of page intentionally lelt blank) ',.:,~'" ,~.' Page4of5 .- -.. " "'V. I :.' " 9. Confession of Judgment. UNDERSIGNED HEREBY EMPOWERS TIm PROTI-IONOTARY OR ANY ATfORNEY OF ANY COURT OF RECORD TO APPEAR fOR UNDERSIGNED AND TO CONfESS JUDGMENT AS OFIl2N AS NEcr',SSARY AGAINST UNDERSIGNED IN FAVOR OF 111E HOLDER HEREOF, REGARDLESS OF WHETHER ANY EVENT OF DEFAULT HAS OCCURRED, AT ANY TIME AND AS OF ANY TERM, FOR TIlE OUTSTANDING IlRlNCIPAL BALANCE I IEREOf PLUS INTEREST DUE UNDER 11 IE TERMS HEREOF AND ALL Oll-IER AMOUNTS DUE HEREUNDER, TOGETIIER WITl-I rosrs OF LEGAL PROCEEDINGS AND AN ATTORNEY'S COMMISSION EQUAL TO TIlE LESSER OF (A) 20% OF TIlE OlffSTANDlNG PRINCIPAL BALANCE AND IN'IB~EST THEN DUE HEREUNDER OR $50000, WlllCHEVER IS GREATER, OR (U) 11IE MAXIMUM AMOUNT PERMrrrED BY LAW, wmf RELEA"iE OF ALL ERRORS. UNDERSIGNED WAIVES ALL LAWS EXEMPllNG REAL OR PERSONAL PROPERTY FROM EXECUTION. By signing this Note, Undersigned agrees to all terms of the Note and swears, under penalty of perjury (as set forth in 18 Pa.C.S. ~904, if governed by Pennsylvania law), to the Affidavit or Business Loan (if completed) set forth In Section 8 of this Note. Il~~l~'II~!gDlltil!I!lllllll!I~I!I~IIIIIIIIII~II~I~~'l1~~,:~I:!~II~I~lll~I\~~I~I~j\II~I\\!l~llljl~I~,\I[[I[!jlj\I!![I!ll~!!j\!~!~[\I:I~jl!I~~~I\[~I~~~!l!\lll~jl~1:[jll!\!'j~lj!j!~ll,lll!j!.!!!~~ll:!j!j:~l\!ll~,:j:~__:!;j!,[!j'~,I!~!:!\!:ll!~I\:~!~ll\III!II~ljlljl!I!llljljl:!lljllljl::!I!llljl~ljljl[~jlllll~j~llll!I~~jlll!l\Ij!\I!!!jll~~!I\I~~jl~lllllljl~ Witness the due execution hereof under seaL x Witness: :itnes~~ -- Mellon Bank, N.A Mellon Bank: (DE) National Association CL-4S0 Rcv.(IW16) LC. 9196lD 9196 OIlS r 166~.3823 1 d4543(OI) ilS2799.160S .....-....-.-...-..........---...................-......-..,.-.......,.....,.......-..-..-.-.-................-.'. . .........................---............--........... ..................-...............................-......................-.._....-..................... . ..............................,............... .:.:.;.:.:.;::;:;:::::::::::;::;;:::::;:::::;::;;;;:::::::::::;::::::=:::::::::;;:;.:.:.;.:.:.:.:.': ...,............................,.......... ::::?:::;;;:::::::::~::::;::::::::::::::::::::~::::::::::::::::::~:::::::::::::::::::: ..-.............-.................-...........................-.......................... ~~:~l' . x/.- I ,:Seal) , . D/B~~.U 's FOOD MARKET AND .., _ __ sM 'UPE-RMA-RKBT 5:'k/ -Fe.' "2-d 5:,-'/ '?~(j'7,.i '.! 1(,<:; / 672 B ~:ERVILLE ROAD )'1/ Cl/ NEWVILLE:, PA 17241 I'- I K- Individu.a1:. . /_ x_~lli::(AK lJv-rL {.c(~rL (Seal) ~ERVILLE ROAD NEWVILLE, PA 17241 ".4~;~~ PageS 0(5 "'\" ' For value received, and intending to be legally bound, in consideration of a loan or other credit accommodation in the amount of Three Hundred Ninetv Five Thousand and 00/100 Dollars ($ 395,000.00 ) made by Mellon Bank. N.A. ~Bank"~to ~~~s =v~r~ SAY- SUPERMARKET v ("Borrower(s)"), said obligation evidenced by a PROMISSORY NOTE dated _1,--,;;..fi - '1 'j . (the "Note") Undersigned, intending to be legally bound, hereby agrees as follows: 1. Security Interest Undersigned hereby grants to Bank a security interest in the following property now owned or hereafter acquired by Undersigned: (Certain terms used herein are defined in Section 13 below.) IX! ~ ~ /(a) aU equipment, wherever located, including oi3 ry, m tor vehicles, furniture and fixtures; IX! ~~ )lJ1i11 iovcntory (whether held for sale or lease or to be . Cd under contracts of service), raw materials, work: in process, and materials used or consumed in the conduct of Undersigned's business, and all books, records, invoices or other documents which describe or evidence the same; IXI cP y~u accounts, contract rights, general intangibles, ~ chases in action, instruments, documents (including all documents of title and warehouse receipts) and all rights to the payment of money, however evidenced or arising; D (d) all securities; all cash, stock or other dividends or distributions paid upon or made in respect of such securities in any form; all securities received in addition to or in exchange for such securities; and all subscription rights incident to such securities; D- (e) all farm products; and D (f) all property or rights described below under the caption "Description of Collateral." Description of Collateral (Give a sufficiently detailed description to identify each item). In addition to the foregoing, Undersigned: (1) grants to Bank a security interest in all accessions, parts, accessories, attachments and appurtenances in any way used with, attached or related to, or installed in, or intended to be so used, attached, related to or installed in, any equipment or inventory constituting "Collateral" hereunder; (2) grants to Bank a security interest in all substitutions for, renewals of, improvements, replacements and additions to, and the products and proceeds (cash and non-cash) of all of the foregoing property and any insurance policies relating thereto; (3) grants to Bank a security interest. in, lien upon, and right of setoff against, all deposit accounts, credits, securities, moneys or other property of Undersigned which may at any time be in the possession of, delivered to or owed by Bank, including any proceeds or returned or unearned premiums of insurance, and the proceeds (cash and non-cash) of all the foregoing property; and (4) assigns to Bank all moneys which may become payable: on any policy of insurance required to be maintained under this A;greement, including any returned or unearned premiums. All such propeClty subject to Bank's security interests described in this Section 1 is referred to herein collectively as the "Collateral." With respect to Section 4 hereunder, the term "Collateral" shall not include the property dCli:cribed in Subsection (3) of this Section 1. All security interests in Collateral shall be deemed to arise and be perfected under and governed by the Uniform Commercial Code, except to the e1l1ent that such law does not apply to certain types of transactions or Collateral, in which case applicable law shall govern. 2. Obligations secured. The Collateral shall secure the following obligations ("Obligation(s)"): (a) all amounts at any time owing or payable under the Note, and any other indebtedness, liability or obligation of Borrower(s) or of Undersigned to Bank, now existing or Page 1 of 4 ,In addition to the rights given to Bank in this Agreement, Bank shall have all the rights and remedies of a secured party under any applicable law, including without limitation, the Uniform Commercial Code. 8. Additional Representations. In addition to the representations and warranties set forth elsewhere in this Agreement, Undersigned hereby mak:es the following representations and warranties which shall be true and correct on the date of this Agreement and shaH continue to be true and correct at the time of any borrowing under any line of credit with Bank and until the Obligations secured by this Agreement shall have been paid in full: (a) each account: (1) represents an amount actually owing to Undersigned by the account debtor (less discounts aHowed for prompt payment); (2) is valid and enforceable according to its terms without further performance of any kind; (3) is not evidenced by any instrument or chattel paper unless the original of such instrument or chattel paper has been deposited with Bank:; and (4) is not evidenced by any judgment unless such judgment has been assigned of record to Baolc; and (b) the locations of aU of Undersigned's places of business are as stated below, and the inventory and records of the accounts are kept at the places indicated below. 9. Additional Covenants. In addition to the covenants set forth elsewhere in this Agreement, Undersigned covenants and agrees that until the Obligations secured by this Agreement have been paid in full Undersigned shall: (a) immediately notify Bank in writing in the event that any of the foHowing occurs: (1) any account is o{ becomes entitled or eligible for discount for prompt payment; (2) any account debtor has or may have any defense to payment of, or right of setoff, counterclaim, or recoupment against any account; (3) any account represents an amount which is disputed by the aCcount debtor or the payment of which is in any way contingent or conditional; or (4) the desirability, usefulness, or marketability of any of the inventory has been in any way reduced or impaired by reason of physical deterioration, technical obsolescence, or otherwise; (b) keep accurate and complete books and records in accordance with generally accepted accounting principles and, at Undersigned's expense, promptly furnish Bank such information and documents relating to the Collateral at such times and in such form and detail as Bank may request, including without limitation: (1) copies of invoices or other evidence of Undersigned's accounts and schedules showing the aging, identification, reconciliation, and collection thereof; (2) evidence of shipment and receipt of goods and the performance of services or obligations covered by accounts; and (3) reports as to Undersigned's inventory and purchases, sales, damage, or loss thereof; all of the foregoing to be certified by authorized officers or other employees of Undersigned; (c) not change any location listed below regarding places of business, inventory and records of accounts without Bank's prior written consent; (d) at Undersigned's expense, diligently coHect the accounts on behalf of Bank until such time as Bank exercises its right to direetly collect the accounts, and upon notice from Bank, deliver all proceeds of accounts to Bank: forthwith upon receipt, in the original form in which received; (e) immediately upon Bank's request, open a cash collateral account ("Cash Collateral account") at Bank and deposit therein all cash proceeds of collections on the accounts; (f) immediately upon Bank's request, give the Bank assignments, in form acceptable to Bank, of specific accounts or groups of accounts and specific general intangibles, and immediately repay the amount loaned against any account so assigned to the Bank if the contract with the account debtor is breached, cancelled or terminated; (g) immediately upon Bank's request, furnish Bank with all information received by Undersigned regarding the financial condition of any account debtor, except to the extent prohibited by law; (h) immediately deliver to Bank all instruments, documents or chattel paper representing any of the Collateral and immediately assign of record to Bank any judgment representing any account constituting O)lIateral; and (i) immediately upon Bank's request, mark: its records evidencing its accounts in a manner satisfactory to Bank so as to show which accounts have been assigned to Bank. 10. Additional Rights of Bank. In addition to the Bank:'s rights set forth elsewhere: in this Agreement, Undersigned hereby authorizes Bank, and Banl[ shall have the continuing rights at any time, whether or not any default has occurred under this Agreement, and at its sole option and discretion, without notice, to: (a) tak:e over and collect any or all of the ac:counts and to take any other action pursuant to its power of attorney granted herein; (b) exercise absolute and exclusive dominion and (ootral over all funds deposited in the Cash Collateral account; apply any funds therein against any Obligations; and charge to any deposit lIccount or Undersigned any item or payment credited to the Cash Collateral account which is subsequently dishonored; (c) at any reasonable time, through its authorized agents and employees, inspect, audit, and verify the accounts and the inventory, review Undersigned's lbooks and records, and copy or make excerpts from any document; and (d) verify accounts with debtors in the name of Undersigned, Bank, or Bank:'s designee. 1 L MlSceUaneous Provisions. (a) Undersigned waives protest of all commercial paper at any time held by Bank: on which Undersigned is in any way liable, notice of nonpayment at maturity of any and all accounts, and (c~cept where requested hereby) notice of action taken by Bank; and hereby ratifies and confirms whatever Bank may do. The rights and remedies of Bank hereunder are cumulative. Bank shall be entitled to exercise any right notwithstanding any prior exercise, failure to exercise or delay in exercising any such right. (b) If any provision hereof shall for any reason be held invalid or unenforceable, 1110 other provision shall be affected thereby, and this Agreement shaD be construed as if the invalid or unenforceable provision had nc:ver been a part of it. The descriptive headings of this Agreement are for convenience only and shall not in any way affect the meaning or construction of any provision hereof. (c) The rights and privileges of Bank contained in this Agreement shall inure to the benefit of its successors and assigns, and the duties of Undersigned shall bind all h(:irs, personal representatives, successors and assigns. (d) No modific:ation of this Agreement, nor any waiver of any provision hereolF, shall be effective or enforceable unless set forth in writing and signed by an officer of Bank. (e) This Agreement shall in all respects be governed by the laws of the state where the Obligations are payable as reflected in the document(s) evidencing such Obligation:~ (except to the extent that federal law governs), and all references to the Uniform Commercial Code shall be deemed to refer to the Uniiform Commercial Code as enacted in such state. (f) Undersigned h4:reby irrevocably appoints Bank and each holder hereof as Undersigned's attorney-in-fact to: (1) endorse Undersigned's name to any draft or cheek which may be payable to Undersigned in order to collect the proceeds of any. insurance or any returned or unearned premiums in respect of any policies of insurance requiired to be maintained hereunder; and (2) tak:e any action Bank deems necessary to perfect or maintain perfection of any security interest granted to Bank: herein, including executing any document on Undersigned's behalf. (g) Undersigned shall bear the risk of loss of, damage to, or destruction of the Collateral, and Undersigned hereby releases Bank from all claims for loss or damage to the Collateral caused by any act or omission on the part of Bank, except for willful misconduct. (h) The prorhpt and faithful performance of all of Undersigned's Obligations hereunder, including without limitation, time of payment, is of the essence of this Agreemen~. (i) Copies or reproductions of this document or of any financing statem~nt IDay be filed as a financing statement. 12 Additionall'ower of Attorney. In addition to the powers of attorney grant(:d to Bank by Undersigned elsewhere in this Agreement, Undersigned hereby appoints Bank and its officers, Page 3 of 4 10-20-'04 11:22 FRQM- rARl1~ Dcl.~ r..""'(Iut GUJC li= j( W1l-lJ.W) ~ .,..u;"".ddras: ..:~.':lA~;lltl.. - /' -- "'0,) ~ =..?~lt~:.:.:..:~.__~ .,,(WiLlE, rA In", DdlIM l'>"'" (lo<l ""." OM It lMMcru.l) .nd ~ili', addt= _we'i f<XD IWlUT ~D ) IlGX ~ ",-.--- MtlNllLE, 0" In, 1 o..bLa< ~ (1~ n."J.c ClRt It indt:vidu.a.Q 'tW tn:IiU~t ~ $,,,,,,,,,.,,",,(,,,, lWll<(.> (bot ..me!inl ir 1DQMdual) ...4 ad4..... t<<-..rllf ~11at=D>d.0ll: ...lton 'ri, _.j. _t~ '_1... l..... t-d't4r Q". Il"n<>tl PaN: C"'Ct~. C.._ 1SI.n7Q .,ns"""gh. PI. 15lS8.""Ol ~.) ...__rq -<<'J (looc..lII<lClnllt...,....lAI) .... odd=o 1i>t_<rillun:uIn&(1lllI"all. s,....wTw-"'...... (chcd;ihppli...llk): P ne~"J)cbrot"_~Pon;-_~ ..wI 'l.aror"~. o n..1aca"DdJ<<<'.IId_J'ony"_~ ....~:~- C tldl....-ioo.-n-iuia.UIiJi,Iy_ SEC1JRED l'ARn'SICNA'IllRr(S) nAo_..IQat.ll!a...rra..6cc......h:!to~ CQ ~. .....cfIy~. Ll ~ (chcdta9(llica*t.oI(~)- ...c:c\~-=.~<l(.......<;I<.fcG<II)'...__"'- "'0" '" wI>ll:IL CIle tII.ldc... ~ c. "&adr o4Iojas.... -...19' ialc<<:olla. --0>IIII0lJ III r~- [] ""-CIle colWchl_....-4 10..... """"'1_ [].......doc Ddococ'. ~.rpla<<.lI.__mowd ... chis CDClO<)'. , oItocIJ-ja:lmu,,:zu:l.,l4Ier<:n... ...."-~_ C"",,",dIe -no......__...~ C1lo\\a "," Jldo...... LococIa.. _ __ ...r~lL c.C -.(UQ" ,......,..s. at W: calloIcnl dcsalb:d 100 ~ '. io:"L:dk. -=u'il)'iII<qa(_ pmlQ\fSlJ ~ (oloo~ ~ l""JCiO"Ia ia l>lad: ',I( ~ OO(da <lUI>.........,u 04'Cf_ ~U&ldy4oalbod... ohc ~ ~IIQI<ca<:o<). -..r_Ao-~..d ( .....,.. ~1(l><x(<S)" .bow): ==~.rr:-~;, a.~2l1--flJll'l LC IlI>S U> ~ rrns B 2A=>c& T-442 P05(11 U-173 1'lNANC1NC ST-alO.ft:Nr l,l"ifalPl ,~., c::..t.Eot1JI ~ IMl'OItIAHI -~ rud WIXlICdau 'l'\Ofod(l'''''~ ......"ldi.,ft Flllac N... (Wl.Olpol byOUll(oD<c:uoj;:~<.'~ ~ ~~ (,""'pdl ~ ~, ~ ::::~(':. ~\:. ~ Vf DEEDS ;,:;:~,E:. 'l!..AtJlJ COUNT~' - PA '97 JUH 20 API 10 51 ~ 1 llllI ~ll,"laonIl b~to<lIJlAt'l'un......[...tllelIoilOOnCil>cwnotioI c..t.:, and lu" \oclilcd "<II. d1c(doecI: appllable ""4 o ""-"'YaC~eo."""""""''''- o halll""oWyQ( IX! ccal_C<<O<Jla.cN!PEB~HD _~ ~ '." 5 110 l(""",",,".rA4.1lllotl<lln-... (ll'a"n: bmd!: ~...... rM<<]O~!lltttl>~: 'COUA'fERAL LbcUry......... by ... ..Io<occypc; .IlL 1IBln>>.'S tIGltT. TInE. _ J~TEllEST. I/llfI'IIElI JI/1IJ CIll 1EJlaf113l IXISTIl/1i (II 1aIIl11tED. 1" UP TO All fMtlTGRT UrCUOrtlC; .~l/EO 01 1EPQ$$ESSaI GCalS" UOUIT$, llPEl/ ~S. 1iE~ 1.,.1IIIiraLEE, ~Cl$. PlAna rAf'fW.. JlIS1llJlEllTs, trolES, DWU. lm<<$.~ CIIVlCfS Of aEOn. Ud:IY~U:S, ClTlltI A/ll;Llll$ CIOlfI!; TO DElTClI. IIX'IIRfS. Nll.lTlJIl( #JIG llllJlf'l(IJl', All HODUl:TS NIO .CASN IJIO Ml4I-C&$lI ..oa:CDI Ul/l:UlOld I.-....a PQC.1,rec IJIA ..ocaiQIJ Of TIE lClle;otlla IJIA ill QU.UlI1'rU. CLi.lll1. .JGIIT., llEllEOlEC AlO l..rvJLEaI!l .ev.nlUl '.....TO. ea.'C)'- c.....u" , 7 8 2 :b :I 12I (clacd::0III!y1r delIn!d,Jrlltalll<Dt OClkoallal<nl...,,""'--' ~RIofal_....... lhpplbbl<: 1:bc~ia,..-joc:IudQ (~~ldr:(QD- '.'<:: ,.., .,."'.. ..0 Chf"pao.iacOCla1Jo,_oq..... ,,,;'. ........ lo.lBl ,.........id...c......,..~,~...:,,:- , . '0 ~ ac-.c:Iib:C:~el~.~);.~__ 4. 0 ~ ...lIlUA&.....lkwk e( -.so ...u..:Jlkc-~.' oA4 tU).1 doc...m.ta4.. .J.d.J04.... - :: _ . dlc~cad_,", -~ :Jl~: :r1nt:l; ,~-' ~aI: JlaGll: e(C-aac)ODaaolo. O~ olhe<(l) C;;;c;;GElIi:A~"":'.<;;~:' OMact. 1Jair~hnz:1~~~"'~ .!.......~.:t,~ o Docn"bod ocaJ\ddRlomI SUtL ...._.r__ (..~~lf.,~o.:.;,"M~e(~ ~ ',- ~. ....-f~=- .-:-.;.... '." . IJ1::BTOlt.SJQCA:~' .' ~ ~.): SAlta 10 CIJ.A::. ... ': -', . .-. . '~.'...~._..T' 's Fo:n'MlI.CET -.''-- 9 10 If. ". \ ~ .....0:.. o. J...... .. ~ '.. tt 1& Il.6:l:URN ll.BCBIPTTO: lleUGR In. ....... _1_ bllf<>:ll..... C_d; ".ll. ..... 3O!lD . pi ccs:b<c-olI. .... t$ZJII-'Jll8O &tfll: COU.tdr.t Ikl(t :...... ". . ~" I,":... ':'\~':J.;,;.. ..,-' ,'.11 .~ ~j';. r-~~~~ . ,. 1 ~: i.. "1.~.' .. u C!ltClm.L to?r 2 = l"Q _._ '.'~- .. _.....c. -."-" ..... :. "-,: .-;:: --', .". .~~,.' 10-20-'04 11:23 FBQM- T-44Z Nl6/11 U-1711 ~> L A ..1l:? .: !.'c'fDS .tJl~CJf~LAtllJ CclUHTY-P4 '02 flPR 5 M 11 02 ':li;.!o",,,':~l;::~l'.::::': . ...~ ?":' ...~...~.)"nt-~i". :;.' ~." . ~ I.. '. '''i UCC FINANCING STATEMENT AMENDMENT ..Cl ~h~ -~_..._~.,. ~ .~~ ... .....e..""'HEDFCCo<t~.TIllD~ _~ .. .. ...~_TO: ......._--.., ci,ilew ........ .. '-11....,1. :'::~":: C1tIlI l'" Con<ar O'ttsOoJJ'lIll. " lR3o!-JIlM ata\l taU~t clut ... ........~fU-- V 9Ef'IWC3G--" ... ...,..~............. ~7" "-1'" Q.,,: . ......-"""""""- C- O~-""----"---"--""-"-"""-""-- s. ~~ ...........-.. ~----=............... ........~........ ....~...... ........-...~--.-. ~........................................ ..... .. 0""""""'" ...-..... c.......fII~.. ...,...".....-........-........... ...........~........ ;- ~_~_-_.....CJ<>-..O'-......_-..,~I.._- . "...... a- .................. t:I ~ ........................... .......7.. O~................-: ..--................-.;........... OOB.D'l:..- ~......,.... 0 1m...,.. ~~..."'..... -- ....."..,.................___",....... _ __ ..............I'c. ............... ..,. ....~ ~~....~..~ 'T1-E SI IS ..~-- 1-- 0<0 JO(Nl;. ~ so. .. ~..~....c f. _-...._-..oc - YQO>>::;:"S FOOD !(ARDl:!' r-- I~- "'.-. . L _. ~J!.:~"..j ~ ...-..aUCT....... -- ~~"- : c; :.. r- -- ... -~ JtD"" '''' T....m-r...CJII...... ,,_011_ Glf> JlEtIItIUE Jl .. ........,...-..... .t 0-... - , --------..... -- 0-- 0-.",,- 0--_-__ 0_ .- -..:~' ~ ":. . ,* . .. ~. ......r... &. ........~....... .~~,.... ~"""."""""..".6lI'~" ..............................CliI&.-...... _______... ~.." ,..... .,.-................'" .0......0......,. __......,__~ ~_.............. - cltlc_.... of -tl-;' -- - ~ ~Sncu ......tnQ l";: c...;c;;':-: u_ ~.... -. -- , ' ',',,: >,~~. ~J;:- ~~.....CJIlt.CZQII.'" 5 lUor-lf ...._.~....lD ""' ....T1O<<Al.. UCC fIt<.1I<CY<lG sr.."tl:M~ AMeIQlolENf jP.Of\Ioo \/CCl flEv,..._ ~.. . ~.~.. I t.7JJCJ1..*" '~"I>> . ". '.'~. __. " ~........... To ~ "N>. .~c ,).' .,..:" . . .... ~.."":.......fo ;r-~'. ".,", :.~ r..... ..... Oct-20-2004 09:32am l"ARTIES IXb~r n:lllle (last name [il).llf wdivlduul) and m311lnt add=: _' '1(':JAl: I SAIi~ /10 RD 3 nox ~ " '] <- ,NEWVILLE, P^ 17241 Dcbl.a<' =e (Ia&l. nam" fl~t if indi,.,;(\ual) and mailing add~: YDUlIG'S FOOO MARKET 1lD 3 llOl( :!ttr t.>,"\-- NEWILL!:, PA 17241 Debtor IUIII1<' (hat n2me fUlt If individual) and mlliling addlOlK: kllft<ll'utt(ta.) ltI.D1C(a) (Wt D4me fmt i( lndMdual) :md ~4re.u tonel:ul'ity mu:rcat ml'otmatlon: Helton Bank, ..~. wuafnGoe lIa~1ng \.om Center ~ Kellon ~ CenterI Rm. 151-1~70 Pltt$bJrllh. ". 1S2SS-0uOl 1- ~.) of St<urod Putt JUI~a) (!aU mmc first If indlvld\lal) ~ ~ tor I<<IIdty Inten:.( lnt.o=tion- Spcdd'l}puaU'IU'UCll (cb<xXlCappliQb1c): o 'Ibe lena "Pcbkx":lIId "Sccurall'.nt' meAlI ~ a4 "[.cuor:l'CllpoaM:It. C 'IM<<elm& "Ocbcot" n4 "$ecIm:d PUty" a1W1 "Comigt>e<;. . pcf"OkdI&nor"~. D DdX<<1&~~lUiJ1r; UIlUty_ Sli:CURE:P PARTYSICNA-TUIU:(S) 'l'IWI.Wcmcut lalSJid.....01 aM the Se<:llhld panta ~ to ped'ec:t .lCCIIdty iatcratln coIlata:l1 (cheek.appli<:ablc bax(<<))- a.[]~.ure4 ancracban~ or pa~.... 1dc:a.U\]' or <<ll'p<><llt.e ~ur" o!tMDebt<<. b. 0 as 1Q which chc 1I1I"i baa lapud. Co ~laQbJOCl: lO a &CCIU1r:y mtct'el;( III au..1hc:r coon\]' In J'clmsyh'aala - o 'l<bCQ mo C4l1aknl'Wllll mo""" 1Q thia OOUDty. o wilen ~ DdJ""'. tt<<'d~ or pIli"" orb...tntM 'II'AlI D:\ov.od to uu. QOlIIlry. d. alceadl nbJc:ct 10 a aeccnity Intcceat In _lither juri.dtct1o.. - o "'lien \h<; <o&t....al....... "'4".0<1 10 P",",">,NaI\l:L [J wll= [he Dcbtor'. lOOlUoa""" ","ond to Pcnnqlwni:1. e.O vMch" proccccL. ofth4a>lla[<<ddescnb!dill b1ock.9. in .Web.. 8C:aUit)' l.hr~ -.. P~W1ti perCectcd (lIbo dGcribc ~ In b1ack9. ffpurclwod.....th ctilt p~ and not adcquatc:11 deacdbol on Ihts odalnal fmanaa,IUllemcnt). $ecUftcf Paz(1 S~I1U<:(.) (mqWted OI\ty ICbo:>;(ca) " c:bOc:Ud above): KELLON B srAmlARD POlQ.( -fORM!'A 00;.1 (Rd.3,93) ~ 1Iy~oleo-oJlVl'<&1lh6l:1'""aaytvaaia ~2~.(7M) LC. UbS Ll> 1M OZTS JI ~-t7n<<& ~"o(~f:~ .~~; . 1 f ,-r..,T29' P.OOZl009 F-210 tll'ti\NCINU ::;iJ\T~C Un{form Co[Qm~cci,.} Code Forni UCC-l 17"::) I IMPORTANT - P1CllSt; rt'fld !.n-'ltruct1oWl l..L1 \'7 dlfl.'fllllJbdore romplelin?, FUlDl: No. (s1l>mp<:d by filing ()f[ICC~): ~ ~t~, ~'Uw>. ~~~ ($t=lpcd tfj filin. o[G~t): :-::, :~O~, ~l~i:Fi)r: DEEDS ::;".1:;;; :lLAllo COUNTY - f'A 1& '9" JUH 26 APlIO 51 1 .'__ ___ _ . .5 ThiI FInanc:lDg 8tald>leaL lllpRKRtcd for tiling'puIaWlll1 to ll1e Unifol1ll Commt;(dal ~ and ia IQ befib:l"liLb tbc(c:hcetappllQbIc'boJ)o O "----or1heCommomialth.. ". '. "I" ",;", . ~~7 ,'1'., o l'rothooot2.tyot _~'d !XI rcal~ra:ocdsotSUKllERll\li.D "'. Ib t' ~1 u.vl)~.&. Namhu-ot Mellffon"} ~ (!fhy):' '_ o tf011tdS Icfea.ltlm...... '(M2x. \OehA~Creoo): (XILLA.'I'ERAL.~~-" ,,-';" , . -' \i.....:.........'I~ IckaUf)"co1t.t.eral bykclnllAd.w~=-i' \:!":;~.y.:" AlL DElI~'C ItICKT, T1T1L.e. AND JNTERES'rYUtIE'I'IleR "OU OR IlEREA.I'TElt f;XtSTJIlG OR ,.::OUIIIE/), ,IX AND. TO .ALL I NVENTOR.l' (IIlCUlllIIIG lEl1JRNEO Qll IIlEI'OSSESSfl) coonS)'; ACCOUJlT$, oPEl( ACaXJNTS, GENnI.L IIItAlJ1;Iat.Es, '~EJlTS~':.CltAtTEL PAPER, 11lS11llJHE1ITS:, WOTES, DRAUS, lETTElS<lR AOVICES Of CREDIT. RECEIVABlES, tJ1'IER JJ.lIXJIITS OII'ING To DEBTOR, fiXTURES. fURIIITUIl1: .AID fWIPMM, ALL ~~~UCTS' AIIll,CASH IJlO NOJI-C4$M PROCEBlS (tNaJ.DUlG IllSURANCE. POLICIES IJlO PRCCEEO$) ()l: Tl\E rotlEQQtl4C4 AJltl All. 'GUARAIlTtES, C:V.ll<S, RIGHTS, aau:oU,S All) Pltvn..EGES'~~LAIINli'~TlIeIU:TO, ..:.: ~.'r "1" .;, .? -:" ~ ". :. : i.-:..! ~~; . ~.r.1,' Collnly. Couucy. 6 1 8 2a 3 " ...~. ... \XI (dlc:d:.OAlyit~),...fw:u oC~ ooI~ ~ ab>O coYUed- UcaUlyl'da1D4-.lcm.... Ifappli<:4b1e: ~~~ il,ar llIclucb (dledcappropriatc1ltA:(ea))- " ,",: ",:,'::" ' a. C C'apCcwwtn&:ortobcl~Cm--;;,-':'~; :.:~ b.12l &OOdt.....IdtJICcnR'o~c.J1xl~~7 ~ ... f C. a ~ ot1hcIlk4(111c:lndilttollandpt)"'~all- II. C auoaub~rr-I~~:J~~,i:1he~(iodudin,..a.odt4li) At lbewcUbcadQ('llllAChe"clCQ~ .."" ;.i<lG:"-1-J . . " " ';,1-. -'i'" Illc r~ rcal csJatc: ~ ,~, " RD 3 BOX 3;1.6 , ..: ~J.4drus: IlEWtLLE I'A 1m" . ;' ~~ Dook _~:c:i(~o,ii40 Dcods DMOl'tpl<:s, lit 'Pate(s) . fOr CUKlft~tAllo-,:;;,~:ft.~ :, - CQIIQry. Unl1Qrmpatcd:lcknuild,~-' -:<<-w..~~..-. . _..~..;.;:~.~. ... O~OlI.t\dditioaalShoe1..,.-'" <{>" ':' :.'.:(, Nil..... ot--.l CIWDU (""J1IIlred~~~~ ~~~ aa'tni.cmtoCRXXX'<i): : . ; = ~.. .",. ~ . "'. . . Dl1:BTOR SIGM-TU~S) ~ ._IS): SANe It) k\lAX:: '/-: ~.:,;t;;;:.;:: " 'WD :--.... - '!:F _ ".... ,. . . "2Q"( ". "', ("Y' '5 fc(o t4AAm ,. , 9 10 1 h Ib RElURN~TO: HeUCK\ 1I&nIi:. . eA. Busl~s 1I~{CllIlOGl1I ~t..t: P.O_ BOIl 3080 " " PHubur"". PA 1S230.3080 Attn: CoUat..ra1 UnIt ' ..f. 11 ., !),l:"';" :- 4 12 ORIGINAL COPY :l ~ (01) 06Gm.osoe -," ~ l' rl'~r ;. ~:" ;'.,:: "'" ......r.. ; r.'~ .-. . . '- ..' . "" ...~ . .~j, ;. ~; ~i;f- '. 9 ~~ 4-. .:.. ;;, , .... ~''''.h,:''';;~",,!, ~ ._,' -'~"~~:.' Oct-20-2004 OB:32am ~'. ','--;};:"':'f~:~:{..~r::'; ;\-~~~ ~,..: T~7Z9' P.003/008 F-Z10 -=- ,. ...._.r~.' -:',.. ::;'~ "_;;~"'" '.~ ~: ..J:::-.l-~: ..d? . ,- ---- - - . -.'- ".~" ... -- .~ I.cEOS .i.-i/.lBER9t~iJ C"UNTY~PA ~OZ flPR ~S M 11 02 - UCC FINANCtNG STATEMENT AMENDMENT ,r;;J' A;/;-;;,~ F()UDVfIN~'-""~~ ;2. t~~. ~ 'lAME" PHONE: of' COflTM:t',.;r fl(.fIt ~ ::-:----- . -- '. a. sEKO~C;"'alTTOl ll'l-- ~ ct,h._ 14nl< aI ,~V.",. BusilWU IV>k11'\1l Lun canur p.o. In 3allO Pi tUtlLlrslll. PI. lS2JlI-lO&lI "<1:0\; (aU.cent Unit 14. __~ ITAl'IDIU<<tft,.II:. SI'I.o= IS F ~ Nt Y ~~8tt.'tD.\BII'~1o ... t.hd llIr*"llN ~,,"" ~4..7n 1:.-"':'-07. ." .. M,l.Lur"lI:~ ~ O~ ~fI"'f'IrooMko4~"'-_il___"___!Il."'~'~-"""""T_--- J- 'l'A~'T'lOf<: ~.....~_____~~~.c..,._rc>;r~....__. ~w...__~w...-.- ~ '";'-'1" ~ .. O~ ........,cc __ "-""""_'&""'&Ml""_"'~1lI"""701;"",,,_""_"'_,,!"""". . .. .aJ.lrNCl.lOQ' 'MfY~ 1W4'--_eJoo-..O.......ooov...-. CI\oldl_!e!~"-~ _~at/....~__el..-.~......-.........._T. OOWlat___lIhoI___IIt_"'.._-__ OoeutriMlMl Qooto.--- O~~c-~....,....~-- _,,_~"'_).."'-__...-Gw'V"I...-)... ""_100_1"'...... . ......ao:_....._'4-'I"M~ .. ~re;:oI'QM'QI\III.lqIc . ':r _-::::. :.:: ... c.o<uKV.~"1W4: l:Hl\1Cr SANG HO, ClI' Ie. ~,*UQ1'_ 1'l1E ... ~OONG.s FOOD ~ .~:.~ _IWOC \~ T. ~~Ofl.~~~ TL ~tw-tE -.;'. ~,,~ . 01'1 7L ~~V.sT_ ANT_ ~~ . . WHlX ...... 1.. ~,/o()()I\CD em' 1l'''11l T l"OC.N.c:aat ~ _ PD ,u-:( 'An1/' 612 NEWIUE PA 17241 1JU 7... l,l.ll:~_MIll( 1 ~J;. I'" 'I'/l'ii:0II~ It olU~Of' C~11CH '-' ~11CH 104'...." tJlQl4 ... ~(HOUVIC' ~~: ~""'I!It."-' ~"""'"'" 0-.. 0-......- 0 _-...-..,......*__01 0""-- ~. ......c ~ ,;..,:.; .~~~::. .:~ ~._...~, ..~.. :'~ .....,.~.. .!:"" i'" .,;..i.""....~ ....... ;-. :......... ... ....i. .. ..........$CeuotaIPMIYtIl~~..-~-""........._...~""'l. ._..-___OIt'O'_-.. __w_"'_Dfo<oor._I_".T__~.Oo___"'" ......._..an'rolO_........-. ....~~- :....,..-. ,. 01\ ClctuM. In af hn"lY\VlInh IVOI1C'1c:U IlIf\\lnlI L..anC""1:....-.:~-..--'- . . - lP<CJMQ<JA<.-v.sT- 'HT-"t;~:" ::":~\'70<!:-: : FIi ," ~~"'~t<CI:D'.'C" 215 __ .'... ... .. _._ PJ) C WU::'&:L1um l.Z.C1C;fj: .....~"a'lu:..v' W...U tU-T.OtUJ..UCCRNJ.NC1NG STATE6AENT At.4l:NOMeNT.(F(:;~ ~~l tru:v.07~1 "".. II ~,."""'c.. I l7.\~~.Gh l;:1l&Ol.U~ .',.... .' .......4~ ..--.. .i1 ~ ". - 0,' .. ...,......- :-. "....: .....~."":...-. ~"r .~" , ).. .. .~.. '- i I ! I I 1 i I , ! i j i i i I i I ! , , i I 1 I ! j i I ! ! i I Detail report item #1 printed by: DOTTIE HOF8MAN on 2/22/01 ________________________________J_____________________-------__________________ --------------------------------,---------------------------------------------- PENNSYLVANIA UCC DETAIL REPORT DATA COVERAGE THROUGH FE G O~) I 2 CJ 0 ] SEl\I<Cll COMPLETE!) FE n ;; 2 I ;; () () 1 o l3 : ~) 9 AM (CS T ) ~~~~~~~~~~~==~=======~======================================================~~.= Filing Location: SECRETARY OF STATE OF PENNSYLVANIA 308 NORTH OfFICE BUILDING HARRISBURG, PA. 17105-8722 Original Filing Number: Original Filing Date: 26811373 06/23/1997 Collateral: FURNITURE AND FIXTURES HEREAFTER ACQUIRED PROPERTY INVENTORY MACHINERY AND EQUIPMENT OTHER Debtor: KWAK, SANG HO RD 3 BOX 672 NEWVILLE, PA. 17241-0000 Additional Debtor: YOUNG'S FOOD MARKET RD 3 BOX 672 NEWVILLE, PA. 17241-0000 Secured Party: MELLON BANK NA BUSINESS BANKING LOAN CENTER PGH, PA. 15258-0001 THE INFORMATION IN THIS REPORT IS PROVIDED IN CONFIDENCE SOLELY FOR YOUR USE IN EVALUATING ACTUAL OR CONTEMPLATED BUSINESS TRANS;~CTIONS INVOLVING THE BUSINESS ENTITY TO WHICH SUCH INFORMATION RELATES. NEITHER EXPERIAN NOR EXPERIAN'S SOURCES WARRANT THE ACCURACY, COMPLETENESS, CURRENTNESS, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OF SUCH INFORMATION. IN NO EVENT WILL EXPERIAN BE LIABLE FOR INDIRECT, INCIDENTAL, CONSEQUENTIAL OR SPECIAL DAMAGES RESULTING FROM THE USE OF SUCH INFORMATION. THE FOLLOWING DATA IS FOR INFORMATION PURPOSES ONLY AND IS NOT AN OFFICIAL RECORD. CERTIFIED COPIES MAY BE OBTAINED FROM THE: PENNSYLVANIA DEPARTMENT OF STATE. ).,' 12/28/2004 08:17 71 72~0~5.I3 PROTHONOT AI~Y C LONG PAGE 01/02 --- .~ \ NO\l 3 {} 2.004 f' MELLON BANK, N.A.~ now by assignment CITIZENS BANK OF PENNSYL V ANlA 8 West Market St. Wilkes-Barre, PA 18701, Plaintiff , ...... ".. nrT~E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY VS. CML ACTION -- LAW REPLEVIN SANG HO KW AK and YON HW A KW AK 672 Bloserville Road Newville, PA 17241, Defendants NO.C'Y - ~r;sP Go~LT~ ORDER AND NOW, this/9~day of ~2004~ 3tH: ~() o'clockA-.m., it is hereby ordered that there will be a hearing on the Plaintiff's motion for writ of seizure, on the '.3nJ dayof~L1FfIL'I ,20QJat 3:~ o'c1ock,_em.,attheCumberland County Courthouse, One Courthouse Square, Carlisle, Pen-osylvarua. Court Ro~m 5' . J. sc: Sang Ho Kwak Yon Hwa Kwak James T. Shoemaker, Esquire 638046,1 . , - HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION BY: James T. Shoemaker, Esquire IDENTIFICATION NO, 63871 A ITORNEY FOR Plaintiff 600 Third Avenue Kingston, P A 18704 (570) 287-3000 MELLON BANK, N.A., now by assignment CITIZENS BANK OF PENNSYLVANIA 8 West Market St. Wilkes-Barre, PA 18701, Plaintiff IN THE COURT OF COMMON PLEAS OF CillvfBERLAND COUNTY vs. CIVIL ACTION -- LAW CONFESSION OF JUDGMENT SANG HO KW AK and YON HW A KW AK 2208 Chatham Way Harrisburg, PA 17110, Defendants NO. 04 - 5958 CIVIL TERM CERTIFICATE OF SERV][CE I, James T. Shoemaker, Esquire, hereby certify that I am serving a true and correct copy of the foregoing notice of hearing upon the defendants, by forwarding said document, via overnight courier, addressed as follows: Sang Ho Kwak, individually and d/b/a Young's Food Market 2208 Chatham Way Harrisburg, P A 17110 Respectfully submitted, 600 Third Avenue Kingston, PA 18704 (570) 287-3000 Telephone (570) 287-8005 Facsimile Dated: December 28, 2004 HOURIGAN, KLUGER & QUINN, P.C. BY\~ Jamest. S oemaker, Esquire ill No.: 63871 Counsel for the plaintiff, Tammac Corporation 644837.1 (") ......) <=.:> 0 (:.~ c.::) 11 ~"'" ..;;;- L'I ;.'r:~ 0 '-1 Q}, PI ffi::n ("") r- ~ :o~ L: ", Cr ,- \.0 ~Uy ,. . S:-)g ~~,~:i :t1oo :::r .~~~ ~. .. ~', :!:: ~(-:) " ' ~ 6 l~5m ...;::> 5~ =< N ::n w --< . HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORATION BY: James T. Shoemaker, Esquire IDENTIFICATION NO. 63871 ATTORNEY FOR Plaintiff 600 Third Avenue Kingston, P A 18704 (570) 287-3000 MELLON BANK, N.A., now by assignment CITIZENS BANK OF PENNSYLVANIA 8 West Market St. Wilkes-Barre, PA 18701, Plaintiff IN THE COURT OF COMMON PLEAS OF CUlv1BERLAND COUNTY vs. CIVIL ACTION -- LAW CONFESSION OF JUDGMENT SANG HO KW AK and YON HW A KW AK 2208 Chatham Way Harrisburg, PA 17110, Defendants NO. 04 - 5958 CIVIL TERM PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE To the Clerk of Courts: Please discontinue the above-captioned action without prejudice. Thank you. 600 Third Avenue Kingston, PA 18704 Telephone (570) 287-3000 FacsImile (570) 287-8005 Dated: January 3,2005 Respectfully Submitted, HOURIGAN, Ia..UGER & QUINN, P.C. ~7~ BY:~ James T. Shoem er, EsqUIre LD. No. 63871 Counsel for the Plaintiff, Mellon Bank, N.A. 645386-1 " HOURIGAN, KLUGER & QUINN A PROFESSIONAL CORPORA nON BY: James T. Shoemaker, Esquire IDENTIFICATION NO, 63871 A TIORNEY FOR Plaintiff 600 Third Avenue Kingston, P A 18704 (570) 287-3000 MELLON BANK, N.A., now by assignment CITIZENS BANK OF PENNSYLVANIA 8 West Market St. Wilkes-Barre, PA 18701, Plaintiff IN THE COURT OF COMMON PLEAS OF CillvlBERLAND COUNTY vs. CNIL ACTION -- LAW CONFESSION OF JUDGMENT SANG HO KWAK and YON HWA KWAK 2208 Chatham Way Harrisburg, PA 17110, Defendants NO. 04 - 5958 CNIL TERM CERTIFICATE OF SERVICE I, James T. Shoemaker, Esquire, hereby certify that I am serving a true and correct copy of the praecipe to discontinue upon the defendants, by fOlwarding said document by U.S. first class mail, postage prepaid, addressed as follows: Sang Ho Kwak, individually and d/b/a Young's Food Market 2208 Chatham Way Harrisburg, P A 17110 Yon Hwa Kwak 2208 Chatham Way Harrisburg, P A 17110 Respectfully submitted, 600 Third Avenue Kingston, P A 18704 (570) 287-3000 Telephone (570) 287-8005 Facsimile Dated: January 3, 2005 HOURIGAN, KLUGER & QUINN, P.C. BY~~ James T. Shoemaker, EsqUIre ID No.: 63871 Counsel for th{~ plaintiff, Mellon Bank, N.A. 645389,} ... (") f'.) c = 0 c.:::.'> c.n -n ---~ f--;. L -l , : :.-~ m:!J ..- Z r- ~?~ I I,m -"S? ~~~; w ~")u -\~- . \'l =-;J -f' . -,,-+1 .'.- C: -.. ~o S> -L. c::;.- I"V ::-c=;;m ~- .. :.=:::t --I 0 1!J':'-"> -< ..J1 N .-< , . SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-05958 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MELLON BANK NA VS KWAK SANG HO ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: KWAK SANG HO but was unable to locate Him In his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within ORDER, MOTN-WRIT SEIZ, CO On January 7th , 2005 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin County Mileage So answers :-- :~,--~ 18.00 9.00 10.00 36.00 7.40 80.40 01/07/2005 HOURIGAN KLUGER ,s::;','_;~~~__/ -- - --- R. Thomas Kline--- Sheriff of Cumberland County QUINN Sworn and subscribed to before me (\ this J( day of j~ '0P1 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-05958 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MELLON BANK NA VS KWAK SANG HO ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: KWAK YON HWA but was unable to locate Her In his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within ORDER, MOT-WRIT SEIZ, COM On January 7th , 2005 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 01/07/2005 HOURIGAN KLUGER So answer~.-:<:,_-? ....--.. ---' ...//. '.-,d..,. ~,/ .----; c::?,P R. Th~mas Kline <-/ .. Sheriff of Cumberland County QUINN Sworn and subscribed to before me this day of ~o In The Court of Common Pleas Qf Cumberland County, Pennsylvania Mellon Bank NA VS. Sang Ho Kwak et al Sang Bo Kwak SERVE: No. 04-5958 civil T-Jow, December 22, 2004 , I, SHERIFF OF CUMBERLi\.ND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~./? ...:?' . <'~~' ~......-. ~~ J>' ~~,...... 0> .r....~?"""""~ "'/''' _.(f;;~~ I' "oj' Sheriff of Cum berland County, P A Affidavit of Service Now, ,20_, at 0' clock M. served the within upon at by handing to a copy of the original and made mown to the contents thereof. So answers, Sheriff of County, PA Sv\'om and subscribed before me this _ day of , 20 COSTS SERVICE MILEAGE -,-\FFIDA VIT $ $ In The Court of Common Pleas of Cumberland County, Pennsylvania Mellon Bank NA VS. Sang Ho Kwak et al Yqn Hwa Kwak SERVE: No. 04-5958 civil Now, Decanber 22, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~" <~ ~~' ;r ';'?~""ett.<. 4if' ~~-f" ~ ? ~ Sheriff of Cumberland County, P A Affidavit of Service Now, ,20_, at 0' clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of , 20 COSTS SERVICE MILEAGE AFFIDA V1T $ $ @Hite of tlp~ ~4er-iff William T. Tully So Ii citor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (7] 7) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania MELLON BANK NA vs County of Dauphin KWAK SANG HO Sheriff's Return No. 7210-T - -2004 OTHER COUNTY NO. 04 5958 AND NOW:December 30, 2004 at 8:13AM served the within ORDER,MOTION-WRIT OF SEIZURE,NOT&COMPLT upon KWAK SANG HO by personally handing to DEFENDANT 1 true attested copy(ies) of the original ORDER,MOTION-WRIT OF SEIZURE,NOT&COMPLT and making known to him/her the contents thereof at 2208 CHATHAM WAY HARRISBURG, PA 17110-0000 Sworn and subscribed to So Answers, JK~ before me this 3RD day of JANUARY, 2005 ,~ Sheriff of Dauphin County, Pa. /"C/ .1 1/f;J C:::;;'?>.~;~':~/S:'_I (--d-v..1L- I ieputly Sheriff By NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. 1, 2006 Sheriff's Costs:$36.00 PD 12/28/2004 RCPT NO 202588 KC @ffitt of tqr ~1rrriff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania MELLON BANK NA vs County of Dauphin KWAK SANG HO Sheriff's Return No. 7210-T - -2004 OTHER COUNTY NO. 04 5958 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for KWAK YON HWA the DEFENDANT named in the within ORDER, MOTION-WRIT OF SEIZURE,NOT&COMPLT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, January 3, 2005 PER SANG HO KWAK, DEFENDANT IS DECEASED 5/27/2005 Sworn and subscribed to So Answers, JK~ before me this 3RD day of JANUARY, 2005 Sheriff of Dauphin County, Pa. ~ By NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept I, 2006 Deputy Sheriff Sheriff's CostS:$36.00 PD 12/28/2004 RCPT NO 202588