HomeMy WebLinkAbout14-7126 ADG-1300 PLAZA WEST ASSOCIATES, IN THE COURT OF COMMON PLEAS OF
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
CHESTNUT STREET TOWNHOUSES,
LLC, P.J.S. PROPERTIES, INC., and : Y
OPEN SKY, INC., :
Defendants CIVIL ACTION - LAW
PRAECIPE TO TRANSFER JUDGMENT
TO THE PROTHONOTARY:
Pursuant to Pa.R.C.P. No. 3002, ADG-1300 Plaza West Associates, by and through its
undersigned counsel, hereby transfers to this Court the money judgment entered in its favor in
the Court of Common Pleas of Dauphin County, Pennsylvania, on December 5, 2014 in the
amount of $158,210.00 (along with interest accruing at the per diem rate of $41.67 after
December 4, 2014 until paid in full), at Civil Action Docket No. 2014-CV-10642-NT against
Chestnut Street Townhouses, LLC, P.J.S. Properties, Inc., and Open Sky, Inc.
A certified copy of the docket entries and judgment in the Dauphin County action, which
Plaintiff seeks to transfer, are attached hereto as Exhibit"A".
McNEES WALLACE &NURICK LLC
Date: December 10, 2014 By
Clayton W. Davidson
PA Attorney I.D. 79139
McNees Wallace &Nurick LLC
100 Pine Street- P. O. Box 1166
Harrisburg, PA 17108-1166
Direct Fax: 717-260-1678
Phone: 717-232-8000
cdavidsonamwn.com
Attorneys for Plaintiff, ADG-1300 Plaza West
Associates
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In The (Court of (Common PCeag of Mdupbirt QCountp, pennop1bania
ADG-1300 Plaza West Associates,LLC
VS. No. 2014-CV-10642-NT
Chestnut Street Townshouses,LLC,
PJ's Properties,Inc. and Open Sky, Inc.
CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT
I,the undersigned Prothonotary of the Court of Common Pleas of Dauphin County, Pennsylvania,
do hereby certify that the attached is a full, true and correct copy of the docket entries in the above
captioned case.
I further certify that judgment was entered in favor of ADG-1300 Plaza West Associates,
Plaintiff and against Chestnut Street Townouses, LLC, P.J.'s Properties, Inc., and Open Sky, Inc.,
Defendant on December 5, 2014 in said case in the amount of$158,210.00 plus cost.
In Tegtimonp Wbereof, I have hereunto set my hand and affixed the seal.of the Court, on
Monday, December 08, 2014.
GVdA
Prothono hry
By: ecca
Deputy
Date: 12/8/2014 Dauphin County User: LBECHTEL
Time: 02:39 PM Complete Case History
Page 1 of 3 Case: 2014-CV-10642-NT
ADG 1300 Plaza West Assoc iatesys.Chestnut Street Townshouses,etal.
Filed: 12/5/2014
Subtype: Notes
Physical File: Y Appealed: N
Comment:
Status History
Pending 12/5/2014
Pending/Judgment 12/5/2014
Judge History
Date Judge Reason for Removal .
12/5/2014 No Judge, Current
Payments Receipt Date Type Amount
Davidson, Clayton W (attorney f 328338 12/5/2014 Civil Filing 63.75
NcNees Wallace & Nurick, LLC 328404 12/8/2014 Miscellaneous 26.25
Exemplified Record 26.25
Total 90.00
Miscellaneous Receipts
Receipt Date
328404 12/8/2014 Exemplified Record 26.25
Sum: 26.25
Plaintiff
Name: ADG 1300 Plaza West Associates SSN:
Address: DOB:
Sex:
Phone: Home: Work:
Employer: Send notices: Y
Litigant Type:
Comment:
Attorneys
Davidson, Clayton W (Primary attorney) Send Notices
Defendant
Name: Chestnut Street Townshouses SSN:
Address: DOB:
Sex:
Phone: Home: Work:
Employer: Send notices: Y
Litigant Type:
Comment:
Attorneys
Davidson, Clayton W (Primary attorney) Send Notices
Date: 12/8/2014 Dauphin County User: LBECHTEL
Time: 02:39 PM Complete Case History
Page 2 of 3 Case: 2014-CV-10642-NT
ADG 1300 Plaza West Assoc iatesys.C hestn ut Street Townshouses, etal.
Defendant
Name: PJs Properties Inc SSN:
Address: DOB:
Sex:
Phone: Home: Work:
Employer: Send notices: Y
Litigant Type:
Comment:
Attorneys
Davidson, Clayton W (Primary attorney) Send Notices
Defendant
Name: Open Sky Inc SSN:
Address: DOB:
Sex:
Phone: Home: Work:
Employer: Send notices: Y
Litigant Type:
Comment:
Attorneys
Davidson, Clayton W (Primary attorney) Send Notices
Register of Actions
12/5/2014 New Civil Case Filed This Date. No Judge,
Plaintiff: ADG 1300 Plaza West No Judge,
Associates Attorney of Record: Clayton
W Davidson
Filing: Complaint with Confession of No Judge,
Judgment Paid by: Davidson, Clayton W
(attorney for ADG 1300 Plaza West
Associates) Receipt number: 0328338
Dated: 12/5/2014 Amount: $63.75
(Check) For:ADG 1300 Plaza West
Associates (plaintiff)
Defendant: Chestnut Street Townshouses No Judge,
Attorney of Record: Clayton W Davidson
Defendant: PJs Properties Inc Attorney of No Judge,
Record: Clayton W Davidson
Defendant: Open Sky Inc Attorney of No Judge,
Record: Clayton W Davidson
Date: 12/8/2014 Dauphin County User: LBECHTEL
Time: 02:39 PM Complete Case History
Page 3 of 3 Case: 2014-CV-10642-NT
ADG 1300 Plaza West Assoc iatesys.Chestnut Street Townshouses,etal.
Register of Actions
12/5/2014 On Complaint filed Judgment in No Judge,
favor of Plaintiff and against Defendant in
the sum of One Hundred Fifty-Eight
Thousand Two Hundred Ten and 00/100
Dollars ($158,210.00)
by virtue of authority contained in the
Warrant of Attorney
filed dated September 18, 2008
payable installments with interest, costs,
etc. ---for colt'n.
Inquisition and Exemption Waived.
Entered At 12:25 p.m.
Stephen E. Farina; Prothonotary
Copies of all documents mailed.
12/8/2014 Miscellaneous Payment: Exemplified No Judge,
Record Paid by: NcNees Wallace &
Nurick, LLC Receipt number: 0328404
Dated: 12/8/2014 Amount: $26.25
(Check)
Judgment
Order date In Favor Of Disposition Judgment
12/05/2014 Plaintiff 12/05/2014 Open Judgment
Comment: 158210.00
Plaintiff: ADG 1300 Plaza West Associates
Defendant: Chestnut Street Townshouses
Open Sky Inc
PJs Properties Inc
hereby ce y t foregoing s"
true and correct copy f the origi I fi ed.
a
Prothonota •
1 C(oCS. o
ADG-1300 PLAZA WEST ASSOCIATES, IN THE COURT OF COMMON PLEAS
Plaintiff, OF DAUPHIN COUNTY, PENNSYLVANIA j
V. N0. '2olq GU )w a N
CHESTNUT STREET TOWNHOUSES,
LLC, P.J.S. PROPERTIES, INC.,and
OPEN SKY, INC.,
Defendants CIVIL ACTION - LAW
NOTICE OF ENTRY OF JUDGMENT N CO3, /
T0: Chestnut Street Townhouses,LLC P.J.S. Properties, Inc.
30 Maplewood Avenue 30 Maplewood Avenue
Mechanicsburg, PA 17055 Mechanicsburg, PA 17055
c:l
Open Sky, Inc.
30 Maplewood Avenue -�
Mechanicsburg, PA 17055 r,
DEC p
You are hereby notified that on December______, ZC}1� a judgment by confession was
entered against each of you in the above-captioned case in favor of ADG-1300 Plaza West
Associates as follows:
Principal: $ 150,000.00
Accrued Interest(10%): $ 710.00
Attorney's Fees 5% commission): $ 7,500.00
Total: $ 158,210.00*
*along with interest accruing at the current per diem rate of$41 from
December 4, 2014 until paid in full,plus costs{the"Indebtedne's' .
i
qsE'' 'Ju�i
DATE: DEC 0 6 2M4
PROTHONOTARY
0 F C 0 8 2014
Ep it to certi'N:,tat,the
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ADG-1300 PLAZA WEST ASSOCIATES, : IN THE COURT OF COMMON PLEAS
` Plaintiff, . OF DAUPHIN COUNTY, PENNSYLVANIA
V. NO.
ar-\1%4 C 1 bc�fa N
CHESTNUT STREET TOWNHOUSES,
j LLC, P.J.S. PROPERTIES, INC.,and
OPEN SKY, INC.,
Defendants CIVIL ACTION - LAW
CERTIFICATE OF RESIDENCE
1, Clayton W. Davidson, certify that the addresses for the Defendants are as follows:
Chestnut Street Townhouses, LLC P.J.S. Properties, Inc.
30 Maplewood Avenue 30 Maplewood Avenue
j Mechanicsburg,PA 17055 Mechanicsburg, PA 17055
r�
Open Sky, Inc.
30 Maplewood Avenue
Mechanicsburg,PA 17055
The following address for the Plaintiff is as follows: r .
ADG-1300 Plaza West Associates
1300 Market Street,PO Box 622
Lemoyne,PA 17043-0622
McNEES WALLACE&NURICK LLC
Date: December 5, 2014 By
ClaytorZ W. Davids6n I
PA Attorney I.D. No. 79139
McNees Wallace&Nurick LLC
100 Pine Street-P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 260-1678 (Direct Fax)
(717) 232-8000 (Phone)
cdavidson@mwn.com
Attorneys for Plaintiff, Attorneys for Plaintiff, ADG-
1300 Plaza West Associates
ADG-1300 PLAZA WEST ASSOCIATES, IN THE COURT OF COMMON PLEAS
Plaintiff, OF DAUPHIN COUNTY, PENNSYLVANIA
V. NO.
�o lL4 r oGYa lo
CHESTNUT STREET TOWNHOUSES,
LLC,P.J.S. PROPERTIES, INC., and
OPEN SKY,INC.,
Defendants CIVIL ACTION- LAW
CONFESSION OF JUDGMENT
Pursuant to the authority contained in the Guarantees attached as Exhibit B to the
Complaint filed in the above captioned case,we appear for Defendants, Chestnut Street
Townhouses, LLC, P.J.S. Properties, Inc., and Open Sky, Inc., and confess judgment against
them in favor of Plaintiff, ADG-1300 Plaza West Associates, as follows:
Principal: $ 150,000.00
Accrued Interest(10%): $ 710.00 c
Attorney's Fees (5%commission): $ 7,500.00
Total: $ 158,210.00*
*along with interest accruing at the current per diem rate of$41.67 from `cr,,
December 4,2014 until paid in full,plus costs (the"Indebtedness").
McNEES WALLACE &NURICK LLC
Date: December 5, 2014 By
Clayto . Davi son
PA Attorney I.D.No. 79139
McNees Wallace&Nurick LLC
100 Pine Street- P.O. Box 1166
Harrisburg, PA 17108-1166
(717)260-1678 (Direct Fax)
! (717)232-8000 (Phone)
cdavidson@mwn.com
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Attorneys for Plaintiff, Attorneys for Plaintiff, ADG-
1300Plaza West Associates
ADG-1300 PLAZA WEST ASSOCIATES, IN THE COURT OF COMMON PLEAS
Plaintiff, OF DAUPHIN COUNTY, PENNSYLVANIA
V. NO.
�O C %J I d !o Yd �J f
CHESTNUT STREET TOWNHOUSES,
LLC, P.J.S. PROPERTIES, INC., and
OPEN SKY, INC.,
Defendants CIVIL ACTION -LAW
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NOTICE UNDER PA.R.C.P. NO.2958.1 OF JUDGMENT
AND EXECUTION THEREON
TO: Chestnut Street Townhouses, LLC P.J.S. Properties,Inc.
;3
30 Maplewood Avenue 30 Maplewood Avenue
Mechanicsburg,PA 17055 Mechanicsburg, PA 17055
Open Sky, Inc.
30 Maplewood Avenue
Mechanicsburg, PA 17055 Ln
A judgment in the amount of$158,210 along with interest accruing at the per diem rate
of$41.67 from December 4,2014 until paid in full,plus costs,has been entered against you and
in favor of ADG-1300 Plaza West Associates, in the above captioned case without any prior
notice or hearing based on a confession of judgment contained in a written agreement or other
paper allegedly signed by you. The sheriff may take your money or other property to pay the
judgment at any time after thirty(3 0) days after the date on which this notice is served on you.
You may have legal rights to defeat the judgment or to prevent your money or property
from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE
JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY(30)DAYS AFTER THE
DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR
RIGHTS.
YOU SHOULD-TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
DAUPHIN COUNTY LAWYER REFERRAL SERVICE
213 North Front Street
Harrisburg,PA 17101
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(717)232-7536
McNEES WALLACE&NURICK LLC
Date: December 5,2014 By:
Clayton W. Davidson
Attorney I.D. 79139
100 Pine Street-P.O. Box 1166
Harrisburg,PA 17108-1166
Direct Fax: 717-260-1678
Phone: 717-232-8000
cdavidson a,mwn.com
Attorneys for Plaintiff, Attorneys for Plaintiff, ADG-
1300 Plaza West Associates
Clayton W. Davidson
PA Attorney I.D. No. 79139
McNees Wallace& Nurick LLC '
100 Pine Street-P.O. Box 1166 ;:1
Harrisburg,PA 17108-1166
(717)260-1678 (Direct Fax)
(717)232-8000(Phone) J j
cdavidson(q-)mwn.com `c
Attorneys for Plaintiff,ADG-1300 Plaza West Associates
ADG-1300 PLAZA WEST ASSOCIATES, IN THE COURT OF COMMON PLEAS
Plaintiff, OF DAUPHIN COUNTY,PENNSYLVANIA
V. NO. �-,' Y C 1� j �tooZ I
CHESTNUT STREET TOWNHOUSES, �`
LLC,P.J.S. PROPERTIES, INC., and
OPEN SKY, INC.,
Defendants CIVIL ACTION - LAW
COMPLAINT FOR CONFESSION OF JUDGMENT
Plaintiff, ADG-1300 Plaza West Associates,by and through its undersigned counsel,
hereby files this Complaint for Confession of Judgment pursuant to Pa.R.C.P.No. 2951(b)and in
support thereof avers the following:
1. Plaintiff, ADG-1300 Plaza West Associates ("Lender"), is a Pennsylvania limited
partnership with a place of business at 1300 Market Street, PO Box 622, Lemoyne, Pennsylvania
17043-0622.
2. Defendant, Chestnut Street Townhouses, LLC, is a Pennsylvania limited liability
company with an address at 30 Maplewood Avenue,Mechanicsburg,Pennsylvania 17055.
3. Defendant,P.J.S. Properties, Inc., is a Pennsylvania corporation with an address at
30 Maplewood Avenue,Mechanicsburg, Pennsylvania 17055.
4. Defendant, Open Sky, Inc., is a Pennsylvania corporation with an address at 30
Maplewood Avenue, Mechanicsburg,Pennsylvania 17055.
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5. On September 18, 2008, Lender loaned 1300 Market, LLC ("Borrower")the sum
of$325,000.00 (the "Loan") for a commercial purpose as evidenced by a Promissory Note (the
"Note"). Attached hereto as Exhibit A and incorporated herein by reference is a true and correct
copy of the Note.
6. The Borrower's obligations to the Lender are guaranteed by Chestnut Street
Townhouses, LLC, P.J.S. Properties, Inc., and Open Sky, Inc. (collectively the"Guarantors")
pursuant to certain Guaranty and Suretyship Agreements(collectively the"Guarantees")
executed by each of the Guarantors in favor of the Lender. Attached hereto as Exhibit B and
incorporated herein by reference are true and correct copies of the Guarantees.
7. The Loan is in default as the result of the Loan maturing on September 18, 2012.
8. There is no right to cure the default under the Note and/or the Guarantees.
9. The entire indebtedness is now immediately due and owing.
10. Each of the Guarantees provides that the Lender may confess judgment against
each of the Guarantors for the entire principal balance due and owing thereunder along with
accrued interest, costs of suit, and an attorney's commission of 5% of such unpaid principal and
interest.
11. The total sum due and owing under the Note and the Guarantees as of December
4, 2014 is itemized as follows:
Principal: $ 150,000.00
Accrued Interest (10%): $ 710.00
Attorney's Fees (5% commission): $ 7,500.00
Total: $ 158,210.00*
*along with interest accruing at the current per diem rate of$41.67 from
December 4,2014 until paid in full,plus costs(the"Indebtedness").
12. All conditions precedent have been satisfied to allow the Lender to confess
judgment against the Guarantors under the Guarantees for the Indebtedness.
13. The fender is the holder of the Note and Guarantees.
14. The Note and the Guarantees were executed and delivered in connection with a
commercial transaction and judgment is not being entered by confession against a natural person
in connection with a consumer credit transaction.
15. Judgment has not been confessed against Guarantors in any other jurisdiction.
16. The 5% attorney's fee commission included in the confessed judgment is
authorized under the Guarantees is being used to calculate a sum certain for purposes of
confessing judgment; however, the Lender will only seek and recover its actual and reasonable
attorney's fees for costs of collection until paid in full in this matter.
WHEREFORE, Plaintiff, ADG-1300 Plaza West Associates,hereby requests this Court
to enter judgment by confession against Chestnut Street Townhouses, LLC, P.J.S. Properties,
Inc.,and Open Sky, Inc., in the amount of$158,210 along with interest accruing at the per diem
rate of$41.67 from December 4, 2014 until paid in full.
McNEES WALLACE&NURICK LLC
Date: December 5, 2014 By
Clayton . Davidson
PA Attorney I.D. No. 79139
McNees Wallace&Nurick LLC
100 Pine Street-P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 260-1678 (Direct Fax)
(717) 232-8000 (Phone)
cdavidson�dmwn.com
Attorneys for Plaintiff, Attorneys for Plaintiff, ADG-
1300 Plaza West Associates
VERIFICATION
I, David E. Dyson, Senior Vice President of Rhodes Development Group, Inc., the
general part of ADG-1300 Plaza West Associates, hereby verify that I am authorized to make this
Verification on behalf of Plaintiff,and the facts contained in the foregoing Complaint are true and correct
to the best of my information,knowledge and belief and are made subject to the penalties of 18 Pa.C.S.A.
§4904 relating to unsworn falsification to authorities.
David E.Dyson, Senior Vice President of
Rhodes Development Group,Inc., the general
partner of ADG-1300 Plaza West Associates
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360 days and actual days elapsed) which shall be three percent (3.00%) in excess of the
interest rate in effect from time to time under this Note but not more than the maximum rate
allowed by law (the "Default Rate"). The Default Rate shall continue to apply whether or not
judgment shall be entered on this Note. Both the Late Charge and the Default Rate are
imposed as liquidated damages for the purpose of defraying the Lender's expenses incident to
the handling of delinquent payments, but are in addition to, and not in lieu of, the Lender's
exercise of any rights and remedies hereunder, under the other Loan Documents or under
applicable law, and any fees and expenses of any agents or attorneys which the Lender may
employ. In addition, the Default Rate reflects the increased credit risk to the Lender of carrying
a loan that is in default. The Borrower agrees that the Late Charge and Default Rate are
reasonable forecasts of just compensation for anticipated and actual harm incurred by the
Lender, and that the actual harm incurred by the Lender cannot be estimated with certainty and i
without difficulty.
4. Prepayment. The Loan may be prepaid in whole or in part without any
prepayment fee.
S. Other Loan Documents. This Note is issued in connection with the Open-End
Mortgage, Security Agreement, Assignment of Leases and Rents and Fixture Filing given the by
Borrower to the Lender and the other agreements and documents executed in connection
therewith or referred to therein, the terms of which are incorporated herein by reference(as
amended, modified or renewed from time to time, collectively the "Loan Documents"), and Is
secured by the property described in the Loan Documents and by such other collateral as
previously may have been or may in the future be granted to the Lender to secure this Note.
6. Events of Default. The occurrence of any of the following events will be
deemed to be an "Event of Default" under this Note: (i) the nonpayment of any principal,
interest or other indebtedness under this Note within ten (10) days of the due date of same; (ii)
the occurrence of any event of default or default and the lapse of any notice or cure period
under any Loan Document or any other debt, liability or obligation to the Lender of any Obligor;
(iii) the filing by or against any Obligor of any proceeding in bankruptcy, receivership,
insolvency, reorganization, liquidation, conservatorship or similar proceeding (and, in the case
of any such proceeding instituted against any Obligor, such proceeding is not dismissed or
stayed within 60 days of the commencement thereof); (iv)any assignment by any Obligor for the
benefit of creditors, or any levy, garnishment, attachment or similar proceeding is instituted
against any property of any Obligor held by or deposited with the Lender; (v) a default with
respect to any other indebtedness of any Obligor for borrowed money in excess of $25,000, if
the effect of such default is to cause or permit the acceleration of such debt; (vi) the
commencement of any foreclosure or forfeiture proceeding, execution or attachment against
any collateral securing the obligations of any Obligor to the Lender; (vii) the entry of a final
judgment against any Obligor in excess of$25,000 and the failure of such Obligor to discharge
the judgment or otherwise bond off any judgment lien resulting therefrom within thirty (30) days
of the entry thereof, (viii) any material adverse change in any Obligor's business, assets,
operations, financial condition or results of operations; (ix) any Obligor ceases doing business
as a going concern; (x) the revocation or attempted revocation, in whole or in part, of any
guarantee by any Guarantor; (xi) the death or legal incompetency of any individual Obligor; (xii)
any representation or warranty made by any Obligor to the Lender in any Loan Document, or
any other documents now or in the future evidencing or securing the obligations of any Obligor
to the Lender, proves to be false, erroneous or misleading in any material respect as of the date
made; or(xiii) any Obligor's failure to observe or perform any covenant or other agreement with
the Lender contained in any Loan Document or any other documents now or in the future
(A1346023:1)
2
evidencing or securing the obligations of any Obligor to the Lender. As used herein, the term
"Obligor" means the Borrower and the Guarantor, and the term "Guarantor" means any
guarantor of the Borrower's obligations to the Lender existing on the date of this Note or
thereafter.
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Upon the occurrence of an Event of Default: (a) the Lender shall be under no further
obligation to make advances hereunder; (b) if an Event of Default specified in clause (iii) or(iv)
above shall occur, the outstanding principal balance and accrued interest hereunder together
with any additional amounts payable hereunder shall be immediately due and payable without
demand or notice of any kind; (c)if any other Event of Default shall occur, the outstanding
principal balance and accrued interest hereunder together with any additional amounts payable
hereunder, at the Lender's option and without demand -or notice of any kind, may be
accelerated and become immediately due and payable; (d)at the Lender's option, this Note will
bear interest at the Default Rate from the date of the occurrence of the Event of Default; and
(e)the Lender may exercise from time to time any of the rights and remedies available under
the Loan Documents or under applicable law.
7. Power to Confess Judgment. The Borrower hereby empowers any attorney
of any court of record, after the occurrence of any Event of Default hereunder, to appear
for the Borrower and, with or without complaint filed, confess judgment, or a series of
judgments, against the Borrower in favor of the Lender or any holder hereof for the entire
principal balance of this Note, all accrued interest and all other amounts due hereunder
or under any of the other Loan Documents,together with costs of suit and an attorney's
commission of the greater of 5% of such principal and interest or $5,000 added as a
reasonable attorney's fee, and for doing so,this Note or a copy verified by affidavit shall
be a sufficient warrant. The Borrower hereby forever waives and releases all errors in
said proceedings and all rights of appeal and all relief from any and all appralsement,
stay or exemption laws of any state now in force or hereafter enacted. Interest on the
principal balance portion of the judgment shall accrue at the Default Rate.
No single exercise of the foregoing power to confess judgment, or a series of
judgments, shall be deemed to exhaust the power, whether or not any such exercise
shall be held by any court to be invalid,,voidable, or void, but the power shall continue
undiminished and it may be exercised from time to time as often as the Lender shall elect
until such time as the Lender shall have received payment in full of the debt, interest and
costs. Notwithstanding the attorney's commission provided for in the preceding
paragraph (which Is included in the warrant for purposes of establishing a sum certain),
the amount of attorneys' fees that the Lender may recover from the Borrower shall not
exceed the actual attorneys' fees incurred by the Lender.
8. Miscellaneous. All notices, demands, requests, consents, approvals and other
communications required or permitted hereunder must be in writing (except as may be agreed
otherwise above with respect to borrowing requests) and will be effective upon receipt. Such
notices and other communications may be hand-delivered, sent by facsimile transmission with
confirmation of delivery and a copy sent by first-class mail, or sent by nationally recognized
overnight courier service, to the addresses for the Lender and the Borrower set forth above or to
such other address as either may give to the other in writing for such purpose. No delay or
omission on the Lender's part to exercise any right or power arising hereunder will impair any
such right or power or be considered a waiver of any such right or power, nor will the Lender's
action or inaction impair any such right or power. No modification, amendment or waiver of any
provision of this Note nor consent to any departure by the Borrower therefrom will be effective
{A1346023:1}
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unless made in a writing signed by the Lender. The Borrower agrees to pay on demand, to the
extent permitted by law, all costs and expenses incurred by the Lender in the enforcement of its
rights in this Note and in any security therefor, including without limitation reasonable fees and
expenses of the Lender's counsel. If any provision of this Note is found to be invalid by a court,
all the other provisions of this Note will remain in full force and effect. The Borrower and all
other makers and indorsers of this Note hereby forever waive presentment, protest, notice of
dishonor and notice of non-payment. This Note shall bind the Borrower and its successors and
assigns, and the benefits hereof shall inure to the benefit of the Lender and its successors and
assigns; provided, however, that the Borrower may not assign this Note in whole or in part
without the Lender's written consent and the Lender at any time may assign this Note in whale
or in part.
This Note has been delivered to and accepted by the Lender and will be deemed to be
made in the Commonwealth of Pennsylvania. THIS NOTE WILL BE INTERPRETED AND THE RIGHTS
AND LIABILITIES OF THE LENDER AND THE BORROWER DETERMINED IN ACCORDANCE WITH THE LAWS
OF COMMONWEALTH OF PENNSYLVANIA, EXCLUDING ITS CONFLICT OF LAWS RULES. The Borrower
hereby irrevocably consents to the exclusive jurisdiction of the Court of Common Pleas of
Cumberland County, Pennsylvania; provided that nothing contained in this Note will prevent the
Lender from bringing any action, enforcing any award or judgment or exercising any rights
against the Borrower individually, against any security or against any property of the Borrower j
within any other county, state or other foreign or domestic jurisdiction. The Borrower
acknowledges and agrees that the venue provided above is the most convenient forum for both
the Lender and the Borrower. The Borrower waives any abjection to venue and any objection
based on a more convenient forum in any action instituted under this Note.
9. WAIVER OF JURY TRIAL. THE BORROWER IRREVOCABLY WAIVES ANY AND ALL
RIGHTS THE BORROWER MAY HAVE TO A TRIAL BY JURY IN ANY ACTION, PROCEEDING OR CLAIM OF
ANY NATURE RELATING TO THIS NOTE, ANY DOCUMENTS EXECUTED IN CONNECTION WITH THIS NOTE
OR ANY TRANSACTION CONTEMPLATED IN ANY OF SUCH DOCUMENTS. THE BORROWER
ACKNOWLEDGES THAT THE FOREGOING WAIVER IS KNOWING AND VOLUNTARY.
The Borrower acknowledges that it has read and understands all the provisions of
this Note, including the confession of judgment and waiver of jury trial, and has been
advised by counsel as necessary or appropriate.
WITNESS the due execution hereof as a document under seal, as of the date first
written above, with the intent to be legally bound hereby.
BORROWER:
WITNESS: 1300 MARKET, LLC,
a Pennsylvania limited liability company
By J. J�� -4+4
Name: K John Sop nsk
Title: Sole Member
! {A1346023:1)
4
DISCLOSURE FOR CONFESSION OF JUDGMENT
Undersigned: 1300 MARKET,LLC
30 Maplewood Avenue
Mechanicsburg,Pennsylvania 17055
Lender: ADG—1300 Plaza West Associates
1300 Market Street
P.O.Box 622
Lemoyne, Pennsylvania 17043.0622
The undersigned has executed, and/or is executing, on or about the date hereof, the following
document under which the undersigned is obligated to repay monies to Lender:
Promissory Note-$325,000.00
A. THE UNDERSIGNED ACKNOWLEDGES AND AGREES THAT THE ABOVE DOCUMENT CONTAINS
PROVISIONS UNDER WHICH LENDER MAY ENTER JUDGMENT BY CONFESSION AGAINST THE UNDERSIGNED. BEING
FULLY AWARE OF ITS RIGHTS TO PRIOR NOTICE AND A HEARING ON THE VALIDITY OF ANY JUDGMENT OR OTHER
CLAIMS THAT MAY BE ASSERTED AGAINST IT BY LENDER THEREUNDER BEFORE JUDGMENT IS ENTERED, THE
UNDERSIGNED HEREBY FREELY, KNOWINGLY AND INTELLIGENTLY WANES THESE RIGHTS AND EXPRESSLY
AGREES AND CONSENTS TO LENDER'S ENTERING JUDGMENT AGAINST IT BY CONFESSION PURSUANT TO THE
TERMS THEREOF.
B. THE UNDERSIGNED ALSO ACKNOWLEDGES AND AGREES THAT THE ABOVE DOCUMENT CONTAINS
PROVISIONS UNDER WHICH LENDER MAY, AFTER ENTRY OF JUDGMENT AND WITHOUT EITHER NOTICE OR A
HEARING, FORECLOSE UPON, ATTACH, LEVY, TAKE POSSESSION OF OR OTHERWISE SEIZE PROPERTY OF THE
UNDERSIGNED IN FULL OR PARTIAL PAYMENT OF THE JUDGMENT. BEING FULLY AWARE OF ITS RIGHTS AFTER
JUDGMENT IS ENTERED(INCLUDING THE RIGHT TO MOVE TO OPEN OR STRIKE THE JUDGMENT),THE UNDERSIGNED
HEREBY FREELY, KNOWINGLY AND INTELLIGENTLY WANES ITS RIGHTS TO NOTICE AND A HEARING (BUT NOT
THE RIGHT TO MOVE TO OPEN OR STRIKE THE JUDGMENT)AND EXPRESSLY AGREES AND CONSENTS
TO LENDER'S TAKING SUCH ACTIONS AS MAY BE PERMITTED UNDER APPLICABLE STATE AND FEDERAL LAW
WITHOUT PRIOR NOTICE TO THE UNDERSIGNED.
C. The undersigned certifies that a representative of Lender specifically called the confession of
judgment provisions in the above documents to the attention of the undersigned, and/or that the
undersigned was represented by legal counsel in connection with the above documents.
D. The undersigned hereby certifies. that its annual income exceeds$10,000;that all references I
to "the undersigned" above refer to the entity signing below; and that the undersigned received a copy
hereof at the time of signing.
Dated: September 18, 2008
! WITNESS: 1300 MARKET,LLC,
a Pennsylvania limited liability company
A-do By
Name: P. John So ens
Title: Sole Member
(A1346023:1)
5
i
i
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i
i
GUARANTY AND SURETYSHIP AGREEMENT
THIS GUARANTY AND SURETYSHIP AGREEMENT (this "Guaranty") is made and
entered into as of September 18, 2008, by CHESTNUT STREET TOWNHOUSES,
LLC, a
Pennsylvania limited liability company ("Guarantor"), with an address at 30 Maplewood
Avenue, Mechanicsburg, Pennsylvania 17055, in consideration of the extension of credit by in
consideration of the extension of credit by ADG-1300 PLAZA WEST ASSOCIATES, a
Pennsylvania limited partnership, its successors and assigns(the "Lender"),with an address at
1300 Market Street, P.O. Box 622, Lemoyne, Pennsylvania 17043-0622 to 1300 MARKET,
LLC, a Pennsylvania limited liability company (the "Borrower'), and other good and valuable !
consideration, the receipt and sufficiency of which are hereby acknowledged. j
1. Guaranty_ of Obligations. The Guarantor hereby guarantees, and becomes
surety for, the prompt payment and performance of. all loans, advances, debts, liabilities,
obligations, covenants and duties owing by the Borrower to the Lender, of any kind or nature,
present or future (including any interest accruing thereon after maturity, or after the filing of any
petition in bankruptcy, or the commencement of any insolvency, reorganization or like
proceeding relating to the Borrower, whether or not a claim for post-filing or post-petition interest
is allowed in such proceeding), whether or not evidenced by any note, guaranty or other
instrument, whether arising under any agreement, instrument or document, whether or not for
the payment of money,whether arising by reason of an extension of credit, opening of a letter of
credit, loan, equipment lease or guarantee, under any interest or currency swap, future, option
or other interest rate protection or similar agreement, or in any other manner, whether arising
out of overdrafts on deposit or other accounts or electronic funds transfers (whether through
automated clearing houses or otherwise) or out of the Lender's non-receipt of or inability to
collect funds or otherwise not being made whole in connection with depository transfer check or
other similar arrangements, whether direct or indirect (including those acquired by assignment
or participation), absolute or contingent,joint or several, due or to become due, now existing or
hereafter arising, and any amendments, extensions, renewals or increases and all costs and
expenses of the Lender incurred in the documentation, negotiation, modification, enforcement,
collection or otherwise in connection with any of the foregoing, including reasonable attorneys'
fees and expenses (collectively, the "Obligations").
If the Borrower defaults under any such Obligations, the Guarantor will pay the amount
of the Obligations to the Lender. Until the Obligations are indefeasibly
liability hereunder shall not be reduced in any manner whatsoever by any amounts whchaid in full, torthe
Lender may realize before or after maturity of the Obligations, by acceleration or otherwise, as a
result of payments made by or on behalf of the Borrower or by or on behalf of any other person
or entity other than the Guarantor primarily or secondarily liable for the Obligations or any part
thereof, or otherwise credited to the Borrower or such person or entity, or as a result of the
exercise of the Lender's rights with respect to any collateral for the Obligations or any part
thereof.
2. Nature of Guaranty Waivers. This is a guaranty of payment and not of
collection and the Lender shall not be required, as a condition of the Guarantor's liability, to
make any demand upon or to pursue any of its rights against the Borrower, or to pursue any
rights which may be available to it with respect to any other person who may be liable for the
payment of the Obligations.
(A1346840:1)
I
This is an absolute, unconditional, irrevocable and continuing guaranty and will remain in
full force and effect until all of the Obligations have been indefeasibly paid in full, and the Lender
has terminated this Guaranty. This Guaranty will remain in full force and effect even if there is
no principal balance outstanding under the Obligations at a particular time or from time to time.
This Guaranty will not be affected by any surrender, exchange, acceptance, compromise or
release by the Lender of any other party, or any other guaranty or any security held by it for any
of the Obligations, by any failure of the Lender to take any steps to perfect or maintain its lien or
security interest in or to preserve its rights to any security or other collateral for any of the
Obligations or any guaranty, or by any irregularity, unenforceability or invalidity of any of the
Obligations or any part thereof or any security or other guaranty thereof. The Guarantor's
obligations hereunder shall not be affected, modified or impaired by any counterclaim, set-off,
deduction or defense based upon any claim the Guarantor may have against the Borrower or
the Lender, except payment or performance of the Obligations.
Notice of acceptance of this Guaranty, notice of extensions of credit to the Borrower
from time to time, notice of default, diligence, presentment, notice of dishonor, protest, demand
for payment, and any defense based upon the Lender's failure to comply with the notice
requirements of the applicable version of Uniform Commercial Code§9-610 are hereby waived.
The Guarantor waives all defenses based on suretyship or impairment of collateral.
The Lender at any time and from time to time, without notice to or the consent of the
Guarantor, and without impairing or releasing, discharging or modifying the Guarantor's
liabilities hereunder, may (a)change the manner, place, time or terms ofa
performance of or interest rates on, or other terms relating to, any of the Obligations; (b) renew,
substitute, modify, amend or after, or grant consents or waivers relating to any of the
Obligations, any other guaranties, or any security for any Obligations or guaranties; (c)apply
any and all payments by whomever paid or however realized including any proceeds of any
collateral, to any Obligations of the Borrower in such order, manner and amount as the Lender
may determine in its sole discretion; (d)settle, compromise or deal with any other person,
Including the Borrower or the Guarantor, with respect to any Obligations in such manner as the
Lender deems appropriate in its sole discretion; (e)substitute, exchange or release any security
or guaranty, or(f)take such actions and exercise such remedies hereunder as provided herein.
3. Repayments or Recovery from the Lender. If any demand is made at any
time upon the Lender for the repayment or recovery of any amount received by it in payment or
on account of any of the Obligations and if the Lender repays all or any part of such amount by
reason of any judgment, decree or order of any court or administrative body or by reason of any
settlement or compromise of any such demand, the Guarantor will be and remain liable
hereunder for the amount so repaid or recovered to the same extent as if such amount had
never been received originally by the Lender. The provisions of this section will be and remain
effective notwithstanding any contrary action which may have been taken by the Guarantor in
reliance upon such payment, and any such contrary action so taken will be without prejudice to
the Lender's rights hereunder and will be deemed to have been conditioned upon such payment
having become final and irrevocable.
4. Financial Statements. Unless compliance is waived in writing by the Lender or
until all of the Obligations have been paid in full, the Guarantor will promptly submit to the
Lender such information relating to the Guarantor's affairs (including but not limited to annual
financial statements and tax returns for the Guarantor) or any security for the Guaranty as the
Lender may reasonably request.
{A1348840:1}
-2-
5. Enforceability of Obligations. No modification, limitation or discharge of the
Obligations arising out of or by virtue of any bankruptcy, reorganization or similar proceeding for
relief of debtors under federal or state law will affect, modify, limit or discharge the Guarantor's
liability in any manner whatsoever and this Guaranty will remain and continue in full force and
effect and will be enforceable against the Guarantor to the same extent and with the same force
and effect as if any such proceeding had not been instituted. The Guarantor waives all rights
full extent hereunder, irrespective of any modification, limitation or discharge of the Iiand benefits which might accrue to it by reason of any such proceeding and will be liable to the
Borrower that may result from any such proceeding. ability of the
6. Events of Default. The occurrence of any of the following shall be an "Event of
Default": (i)any Event of Default (as defined in any of the Loan Documents); (ii) any default
under any of the Loan Documents that does not have a defined set of"Events of Default" and
the lapse of any notice or cure period provided in such Obligations with respect to such default;
(iii) demand by the Lender under any of the instruments or agreements giving rise to any of the
Obligations that have a demand feature; (iv) the Guarantor's failure to perform any of its
obligations hereunder; (v) the falsity, inaccuracy or material breach by the Guarantor of any
written warranty, representation or statement made or furnished to the Lender by or on behalf of
the Guarantor; or (vi) the termination or attempted termination of this Guaranty. Upon the
occurrence of any Event of Default, (a) the Guarantor shall pay to the Lender the outstanding
amount of the Obligations; or (b) on demand of the Lender, the Guarantor shall immediately
deposit with the Lender, in U.S. dollars, the outstanding amount of the Obligations, and the
Lender may at any time use such funds to repay the Obligations; or (c) the Lender in its
discretion may exercise with respect to any collateral any one or moreof the rights and
remedies provided a secured party under the applicable version of the Uniform Commercial
Code; or (d) the Lender in its discretion may exercise from time to time any other rights and
remedies available to it at law, in equity or otherwise.
7. Collateral. This Guaranty is secured by the property described in any collateral
s
security documents which the Guarantor executes and delivers to the Lender and by uch other
collateral as previously may have been or may in the future be granted to the
any obligations of the Guarantor to the Lender. Lender to secure
8• Costs. To the extent that the Lender incurs any costs or expenses in protecting
or enforcing Its rights under the Obligations or this Guaranty, including reasonable attomeys'
fees and the costs and expenses of litigation, such costs and expenses will be due on demand,
will be included in the Obligations and will bear Interest from the incurring or payment thereof at
the Default Rate(as defined in any of the Obligations).
9. Postpone
ostnonement of Subrogation. Until the Obligations are Indefeasibly paid in
full, the Guarantor irrevocably postpones and subordinates in favor of the Lender any and all
rights which the Guarantor may have to (a) assert any claim against the Borrower based on
subrogation rights with respect to payments made hereunder, and (b) any realization on any
property of the Borrower, including participation in any marshalling of the Borrower's assets.
10. Power to Confess Judgment. The Guarantor hereby empowers any
attorney of any court of record,after the occurrence of any Event of Default hereunder,to
appear for the Guarantor and, with or without complaint filed, confess judgment, or a
series of judgments, against the Guarantor in favor of the Lender for the amount of the
Obligations, together with interest thereon at the Default Rate set forth in the Note, costs
of suit and an attorney's commission of the greater of 5% of such principal and interest
(AIW840:1)
-3-
or$5,000 added as a reasonable attorney's fee, and for doing so, this Guaranty or a copy
verified by affidavit shall be a sufficient warrant. The Guarantor hereby forever waives
and releases all errors in said proceedings and all rights of appeal and all relief from any
and all appraisement, stay or exemption laws of any state now in force or hereafter
enacted.
No single exercise of the foregoing power to confess judgment or a series of judgments,
shall be deemed to exhaust the power, whether or not any such exercise shall be held by
any court to be invalid, voidable, or void, but the power shall continue undiminished and
it may be exercised from time to time as often as the Lender shall elect until such time as
the Lender shall have received payment in full of the outstanding balance due on the
Obligations and costs. Notwithstanding the attorney's commission provided for in the
preceding paragraph (which is included In the warrant for purposes of establishing a
sum certain), the amount of attorneys' fees that the -Lender may recover from the
Guarantor shall not exceed the actual attorneys' fees incurred by the Lender.
11. Notices. All notices, demands, requests, consents, approvals and . other
communications required or permitted hereunder must be in writing and will be effective upon
receipt. Such notices and other communications may be hand-delivered, sent by facsimile
transmission with confirmation of delivery and a copy sent by first-class mail,der and the
or sent by
nationally recognized overnight courier service, to the addresses for the Len
Guarantor set forth above or to such other address as one may give to the other in writing for
such purpose.
12. Preservation of Rights. No delay or omission on the Lender's part to exercise
any right or power arising hereunder will impair any such right or power or be considered a
waiver of any such right or power, nor will the Lender's action or inaction impair any such right
or power. The Lender's rights and remedies hereunder are cumulative and not exclusive of any
other rights or remedies which the Lender may have under other agreements, at law or in
equity. The Lender may proceed in any order against the Borrower, the Guarantor or any other
obligor of, or any collateral securing, the Obligations.
13. life-gal . In case any one or more of the provisions contained in this Guaranty
should be invalid, illegal or unenforceable in any respect, the validity, legality and enforceability
of the remaining provisions contained herein shall not in any way be affected or impaired
thereby.
14. Changes in Writing. No modification, amendment or waiver of any provision of
this Guaranty nor consent to any departure by the Guarantor therefrom, will be effective unless
made in a writing signed by the Lender, and then such waiver or consent shall be effective only
in the specific instance and for the purpose for which given. No notice to or demand on the
Guarantor in any case will entitle the Guarantor to any other or further notice or demand in the
same, similar or other circumstance.
15. Entire greement. This Guaranty (including the documents and instruments
referred to herein) constitutes the entire agreement and supersedes all other prior agreements
and understandings, both written and oral, between the Guarantor and the Lender with respect
to the subject matter hereof, provided, however, that this Guaranty is in addition to, and not in
substitution for,any other guarantees from the Guarantor to the Lender.
{A1346M:1)
-4-
i
16. Successors and Assigns. This Guaranty will be binding upon and inure to the I
benefit of the Guarantor and the Lender and their respective heirs, executors, administrators,
successors and assigns;RMXiLded, however, that the Guarantor may not assign this Guaranty in
whole or in part without the Lender's prior written consent and the Lender at any time may
assign this Guaranty in whole or in part.
17. Interpretation. In this Guaranty, unless the Lender and the Guarantor otherwise
agree in writing, the singular includes the plural and the plural the singular, references to
statutes are to be construed as-including all statutory provisions consolidating, amending or
replacing the statute referred to; the word "or" shall be deemed to Include "and/or", the words
"including", "includes" and "include" shall be deemed to be followed by the words "without
limitation"; and references to sections or exhibits are to those of this Guaranty unless otherwise
indicated. Section headings in this Guaranty are included for convenience of reference only and
shall not constitute a part of this Guaranty for any other purpose. If this Guaranty is executed by
more than one party as Guarantor, the obligations of such persons or entities will be joint and
several.
18. Indemnity. The Guarantor agrees to indemnify each of the Lender, its partners,
directors, officers and employees and each legal entity, if any, who controls the Lender (the
"Indemnified Parties")and to hold each Indemnified Party harmless from andagainst any and
all claims, damages, losses, liabilities and expenses (including all fees and charges of internal
or external counsel with whom any Indemnified Party may consult and all expenses of litigation
or preparation therefor) which any Indemnified Party may incur or which may be asserted
against any Indemnified Party as a result of the execution of or performance under this
Guaranty; 2MAded, however, that the foregoing indemnity agreement shall not apply to claims,
damages, losses, liabilities and expenses solely attributable to an indemnified Party's gross
negligence or willful misconduct. The indemnity agreement contained in this Section shall
survive the termination of this Guaranty. The Guarantor may participate at its expense in the
defense of any such claim.
19. Governing Law and Jurisdiction. This Guaranty has been delivered to and
accepted by the Lender and will be deemed to be made in the Commonwealth of Pennsylvania.
THiS GUARANTY WILL BE INTERPRETED AND THE RIGHTS AND LIABILITIES OF THE LENDER AND THE
GUARANTOR DETERMINED IN ACCORDANCE WITH THE LAWS OF COMMONWEALTH OF PENNSYLVANIA,
EXCLUDING iTS CONFLICT OF LAWS RULES. The Guarantor hereby irrevocably consents to the
exclusive jurisdiction of the Court of Common Pleas of Cumberland County, Pennsylvania;
provided that nothing contained in this Guaranty will prevent the Lender from bringing any
action, enforcing any award or judgment or exercising any rights against the Guarantor
individually, against any security or against any property of the Guarantor within any other
county, state or other foreign or domestic jurisdiction. The Guarantor acknowledges and agrees
that the venue provided above is the most convenient forum for both the Lender and the
Guarantor. The Guarantor waives any objection to venue and any objection based on a more
convenient forum in any action instituted under this Guaranty.
20. WAIVER OF JURY TRIAL. THE GUARANTOR IRREVOCABLY WAIVES ANY
AND ALL RIGHT THE GUARANTOR MAY HAVE TO A TRIAL BY JURY IN ANY ACTION,
PROCEEDING OR CLAIM OF ANY NATURE RELATING TO THIS GUARANTY, ANY
DOCUMENTS EXECUTED IN CONNECTION WiTH THIS GUARANTY OR ANY
TRANSACTION CONTEMPLATED IN ANY OF SUCH DOCUMENTS. THE GUARANTOR
ACKNOWLEDGES THAT THE FOREGOING WAIVER 1S KNOWING AND VOLUNTARY.
(A1346840:1)
- 5-
The Guarantor acknowledges that it has read and understands all the provisions
of this Guaranty, including the confession of judgment and waiver of jury trial, and has
been advised by counsel as necessary or appropriate.
WITNESS the due execution hereof as a document under seal, as of the date first
written above, with the intent to be legally bound hereby.
vATfST/WITNESS: GUARANTOR:
CHESTNUT STREET TOWNHOUSES, LLC,
a Pennsylvania limited liability company
qray �
N e:
itle: Name:
Title:
(AI346e40:1)
DISCLOSURE FOR CONFESSION OF JUDGMENT
Undersigned: CHESTNUT STREET TOWNHOUSES,LLC
30 Maplewood Avenue
Mechanicsburg,Pennsylvania 17055
Lender: ADG—1300 Plaza West Associates
1300 Market Street
P.O. Box 622
Lemoyne, Pennsylvania 17043-0622
The undersigned has executed, and/or is executing, on or about the date hereof, a Guaranty and
Suretyship Agreement in respect of the obligations owed to Lender by 1300 MARKET, LLC, a
Pennsylvania limited liability company, under which the undersigned is obligated to repay monies to
Lender.
A. THE UNDERSIGNED ACKNOWLEDGES AND AGREES THAT THE ABOVE
FULLY AWARE OF ITS RIGHTS TO PRIOR NOTICE AND A HEARING ON THE VALIDITY OF ANY DOCUMENT CONTAINS
PROVISIONS UNDER WHICH LENDER MAY ENTER JUDGMENT BY CONFESSION AGAINST THE UNDERSIGNED. BEING
JUDGMENT OR OTHER
CLAIMS THAT MAY BE ASSERTED AGAINST IT BY LENDER THEREUNDER BEFORE JUDGMENT IS ENTERED, THE
UNDERSIGNED HEREBY FREELY, KNOWINGLY AND INTELLIGENTLY WAIVES THESE RIGHTS AND EXPRESSLY
AGREES AND CONSENTS TO LENDER'S ENTERING JUDGMENT AGAINST IT BY CONFESSION PURSUANT TO THE
TERMS THEREOF.
B. THE UNDERSIGNED ALSO ACKNOWLEDGES AND AGREES THAT THE ABOVE DOCUMENT CONTAINS
PROVISIONS UNDER WHICH LENDER MAY, AFTER ENTRY OF JUDGMENT AND WITHOUT EITHER NOTICE OR A
R OTHER
HEARING, FORECLOSE UPON, ATTACH L ,
UNDERSIGNED IN FULL OR PARTIAL PAYMENT O THE JUDGMENT SSESSION OBEIONG FULLY AWARE OF ITS WISE SEIzE RIGHTPERTY OAFTTHHE
JUDGMENT fS ENTERED(INCLUDING THE RIGHT TO MOVE TO OPEN OR STRIKE THE JUDGMENT),THE UNDERSIGNED
HEREBY FREELY, KNOWINGLY AND INTELLIGENTLY WAIVES ITS RIGHTS TO NOAND EX TICE AND A HEARING {BUT NOT
THE RIGHT TO MOVE TO OPEN OR STRIKE THE JUDGMENT)
TO LENDER'S TAKING SUCH ACTIONS AS MAY BE PERMITTED UNDER APPLICABLE STATE AND PRESSLY AGREES AND
LAW
WITHOUT PRIOR NOTICE TO THE UNDERSIGNED.
C. The undersigned certifies that a representative of Lender specifically caped the co
judgment provisions In the above documents to the attention of the undersigned, and/orf that the
undersigned was represented by legal counsel In connection with the above documents.
D. The undersigned hereby certifies: that its annual Income exceeds$10,000;that all references
to "the undersigned"above refer to the entity signing below; and that the undersigned received a copy
hereof at the time Of signing.
Dated as Of September 18, 2008
GUARANTOR:
,--ATTEST/WITNESS; CHESTNUT STREET TOWNHOUSES, LLC,
a Pennsylvania limited liability company
y e. By P. 1It-At
ide: Name:
Title:
(A1346840:1)
-7-
GUARANTY AND SURETYSHIP AGREEMENT
THIS GUARANTY AND SURETYSHIP AGREEMENT (this "Guaranty") is made and
entered into as of September 18, 2008, by P.J.S. PROPERTIES, INC., a Pennsylvania
corporation ("Guarantor"!, with an address at 30 Maplewood Avenue, Mechanicsburg,
Pennsylvania 17055, in consideration of the extension of credit by in consideration of the
extension of credit by ADG-1300 PLAZA WEST ASSOCIATES, a Pennsylvania limited
partnership, its successors and assigns (the "Lender"), with an address at 1300 Market Street, I
P.O. Box 622, Lemoyne, Pennsylvania 17043-0622 to 1300 MARKET, LLC, a Pennsylvania
limited liability company (the `Borrower"), and other good and valuable consideration, the
receipt and sufficiency of which are hereby acknowledged.
1. Guaranty of Obligations. The Guarantor hereby guarantees, and'becomes
surety for, the prompt payment and performance of. all loans,
advances,
obligations, covenants and duties owing by the Borrower to the Lender, of any k debts,
oranatu e,
present or future (including any Interest accruing thereon after maturity, or after the filing of any
petition in bankruptcy, or the commencement of any insolvency, reorganization or like
proceeding relating to the Borrower, whether or not a claim for post-filing or post-petition interest
is allowed in such proceeding), whether or not evidenced by.any note, guaranty or other
instrument, whether arising under any agreement, instrument or document, whether or not for
the payment of money, whether arising by reason of an extension of credit, opening of a letter of
credit, loan, equipment lease or guarantee, under any interest or currency swap, future, option
or other interest rate protection or similar agreement, or in any other manner, whether arising
out of overdrafts on deposit or other accounts or electronic funds transfers (whether through
automated clearing houses or otherwise) or out of the Lender's non-receipt of or inability to
collect funds or otherwise not being made whole in connection with depository transfer check or
other similar arrangements, whether direct or indirect (including those acquired by assignment
or participation), absolute or contingent,joint or several, due or to become due, now existing or
hereafter arising, and any amendments, extensions, renewals-or.increases and all costs and
expenses of the Lender incurred in the documentation, negotiation, modificationenforcement
, enforcorc
collection or otherwise in connection with any of the foregoing, including re
fees and expenses(collectively, the"Obligations"). asonable attorneys,
If-the Borrower defaults under any such Obligations, the Guarantor will pay the amount
of the Obligations to the Lender. Until the Obligations are indefeasibly paid in full, Guarantor's
liability hereunder shall not be reduced in any manner whatsoever by any amounts which the
Lender may realize before or after maturity of the Obligations, by acceleration or otherwise, as a
result of payments made by or an behalf of the Borrower or by or on behalf of any other person
or entity other than the Guarantor primarily or secondarily liable for the Obligations or any part
thereof, or otherwise credited to the Borrower or such person or entity, or as a result of the
exercise of the Lender's rights with respect to any collateral for the Obligations or any part
thereof.
2. Nature of Guaran - Waivers. This is a guaranty of payment and not of
collection and the Lender shall not be required, as a condition of the Guarantor's liability, to
make any demand upon or to pursue any of its rights against the Borrower, or to pursue any
rights which may be available to It with respect to any other person who may be liable for the
payment of the Obligations.
JA1346873:11
This is an absolute, unconditional, irrevocable and continuing guaranty and will remain in
full force and effect until all of the Obligations have been indefeasibly paid in full, and the Lender
has terminated this Guaranty. This Guaranty will remain in full force and effect even if there is
no principal balance outstanding under the Obligations at a particular time or from time to time.
This Guaranty will not be affected by any surrender, exchange, acceptance, compromise or
release by the Lender of any other party, or any other guaranty or any security held by it for any
of the Obligations, by any failure of the Lender to take any steps to perfect or maintain its lien or
security interest in or to preserve its rights to any security or other collateral for any of the
Obligations or any'guaranty, or by any irregularity, unenforceability or invalidity of any of the
Obligations or any part thereof or any security or other guaranty thereof. The Guarantor's
obligations hereunder shall not be affected, modified or impaired by any counterclaim, set-off,
deduction or defense based upon any claim the Guarantor may have against the Borrower or
the Lender, except payment or performance of the Obligations.
Notice of acceptance of this Guaranty, notice of extensions of credit to the Borrower
from time to time, notice of default, diligence, presentment, notice of dishonor, protest, demand
for payment, and any defense based upon the Lender's failure to comply with the notice
requirements of the applicable version of Uniform Commercial Code §9-610 are hereby waived.
The Guarantor waives all defenses based on suretyship or impairment of collateral.
The Lender at any time and from time to time, without notice to or the consent of the
Guarantor, and without impairing or releasing, discharging or modifying the Guarantor's
liabilities hereunder, may (a)change the manner, place, time or terms of payment or
performance of or interest rates on, or other terms relating to, any of the Obligations; (b) renew,
substitute, modify, amend .or alter, or grant consents or waivers relating to any of the
Obligations, any other guaranties, or any security for any Obligations or guaranties; (c)apply
any and all payments by whomever paid or however realized including any proceeds of any
collateral, to any Obligations of the Borrower in such order, manner and amount as the Lender
may determine in its sole discretion; (d)settle, compromise or deal with any other person,
including the Borrower or the Guarantor, with respect to any Obligations in such manner as the
Lender deems appropriate in its sole discretion; (e)substitute, exchange or release any security
or guaranty; or(f)take such actions and exercise such remedies hereunder as provided herein.
3. Repayments or Recovery from the Lender. If any demand is made at any
time upon the Lender for the repayment or recovery of any amount received by it in payment or
on account of any of the Obligations and if the Lender repays all or any part of such amount by
reason of any judgment, decree or order of any court or administrative body or by reason of any
settlement or compromise of any such demand, the Guarantor will be and remain liable
hereunder for the amount so repaid or recovered to the same extent as if such amount had
never been received originally by the Lender. The provisions of this section will be and remain
effective notwithstanding any contrary action which may have been taken by the Guarantor in
reliance upon such payment, and any such contrary action so taken will be without prejudice to
the Lender's rights hereunder and will be deemed to have been conditioned upon such payment
having become final and irrevocable.
4. Financial Statements. Unless compliance is waived in writing by the Lender or
until all of the Obligations have been paid in full, the Guarantor will promptly submit to the
Lender such information relating to the Guarantor's affairs (including but not limited to annual
i financial statements and tax returns for the Guarantor) or any security for the Guaranty as the
Lender may reasonably request.
(AlM873:1}
-2-
or$5,000 added as a reasonable attorney's fee, and for doing so,this Guaranty or a copy
verified by affidavit shall be a sufficient warrant. The Guarantor hereby forever waives
and releases all errors in said proceedings and all rights of appeal and all relief from any
and all appraisement, stay or exemption laws of any state now in force or hereafter
enacted.
No single exercise of the foregoing power to confess judgment, or a series of judgments,
shall be deemed to exhaust the power,whether or not any such exercise shall be held by
any court to be invalid, voidable, or void, but the power shall continue undiminished and
it may be exercised from time to time as often as the Lender shall elect until such time as
the Lender shall have received payment in full of the outstanding balance due on the
Obligations and costs. Notwithstanding the attorney's commission provided for in the
preceding paragraph (which is included in the warrant for purposes of establishing a
sum certain), the amount of attorneys' fees that the Lender may recover from the
Guarantor shall not exceed the actual attorneys' fees incurred by the Lender.
11. Notices. All notices, demands, requests, consents, approvals and other
communications required or permitted hereunder must be in writing and will be effective upon
receipt. Such notices and other communications may be hand-delivered, sent by facsimile
transmission with confirmation of delivery and a copy sent by first-class mail, or sent by
nationally recognized overnight courier service, to the addresses for the Lender and the
Guarantor set forth above or to such other address as one may give to the other in writing for
such purpose.
12. Preservation of Rights. No delay or omission on the Lender's part to exercise
any right or power arising hereunder will impair any such right or power or be considered a
waiver of any such right or power, nor will the Lender's action or inaction impair any such right
or power. The Lender's rights and remedies hereunder are cumulative and not exclusive of any
other rights or remedies which the Lender may have under other agreements, at law or in
equity. The Lender may proceed in any order against the Borrower,the Guarantor or any other
obligor of, or any collateral securing, the Obligations.
13. Illegality. In case any one or more of the provisions contained in this Guaranty
should be invalid, illegal or unenforceable in any respect, the validity, legality and enforceability
of the remaining provisions contained herein shall not in any way be affected or impaired
thereby.
14. Changes In Writing. No modification, amendment or waiver of any provision of
this Guaranty nor consent to any departure by the Guarantor therefrom, will be effective unless
made in a writing signed by the Lender, and then such waiver or consent shall be effective only
in the specific instance and for the purpose for which given. No notice to or demand on the
Guarantor in any case will entitle the Guarantor to any other or further notice or demand in the
same, similar or other circumstance.
15. Entire Aureement. This Guaranty (including the documents and instruments
referred to herein) constitutes the entire agreement and supersedes all other prior agreements
and understandings, both written and oral, between the Guarantor and the Lender with respect
to the subject matter hereof; provided, however, that this Guaranty is in addition to, and not in
substitution for, any other guarantees from the Guarantor to the Lender.
{A134073:1}
-4-
16. Successors and Assigns. This Guaranty will be binding upon and Inure to the
benefit of the Guarantor and the Lender and their respective heirs, executors, administrators,
successors and assigns; provided, however, that the Guarantor may not assign this Guaranty in
whole or in part without the Lender's prior written consent and the Lender at any time may
assign this Guaranty in whole or in part.
17. Interpretation. In this Guaranty, unless the Lender and the Guarantor otherwise
agree in writing, the singular includes the plural and the plural the singular; references to
statutes are to be construed as including all statutory provisions consolidating, amending or
replacing the statute referred to; the word "or" shall be deemed to include "and/ori', the words
"including", "includes" and 'include" shall be deemed to be followed by the words "without
limitation"; and references to sections or exhibits are to those Of this Guaranty unless otherwise
indicated. Section headings in this Guaranty are included for convenience of reference only and
shall not constitute a part of this Guaranty for any other purpose. If this Guaranty is executed by
more than one party as Guarantor, the obligations of such persons or entities will be joint and
several.
18. Indemnitf.. The Guarantor agrees to indemnify each of the Lender, its directors,
officers and employees and each legal entity, if any, who controls the Lender(the`indemnified
Parties") and to hold each Indemnified Party harmless from and against any and all claims,
damages, losses, liabilities and expenses (including all fees and charges of internal or external
counsel with whom any Indemnified Party may consult and all expenses of litigation or
preparation therefor)which any Indemnified Party may incur or which may be asserted against
any Indemnified Party as a result of the execution of or performance under this Guaranty;
provided, however, that the foregoing indemnity agreement shall not apply to claims, damages,
losses, liabilities and expenses solely attributable to an Indemnified Party's gross negligence or
willful misconduct. The indemnity agreement contained in this Section shall survive the
termination of this Guaranty. The Guarantor may participate at its expense in the defense of
any such claim.
19. Governinq Law and Jurisdiction. This Guaranty has been delivered to and
accepted by the Lender and will be deemed to be made in the Commonwealth of Pennsylvania.
THIS GUARANTY WILL BE INTERPRETED AND THE RIGHTS AND LIABILITIES OF THE LENDER AND THE
GUARANTOR DETERMINED IN ACCORDANCE WITH THE LAWS OF COMMONWEALTH OF PENNSYLVANIA,
EXCLUDING iTS CONFLICT OF LAWS RULES. The Guarantor hereby irrevocably consents to the
exclusive jurisdiction of the Court of Common Pleas of Cumberland County, Pennsylvania;
provided that nothing contained in this Guaranty will prevent the Lender from bringing any
action, enforcing any award or judgment or exercising any rights against the Guarantor _
individually, against any security or against any property of the Guarantor within any other
county, state or other foreign or domestic jurisdiction. The Guarantor acknowledges and agrees
that the venue provided above is the most convenient forum for both the Lender and the
Guarantor. The Guarantor waives any objection to venue and any objection based on a more
convenient forum in any action instituted under this Guaranty.
20. WAIVER OF JURY TRIAL. THE GUARANTOR IRREVOCABLY WAIVES ANY
AND ALL RIGHT THE GUARANTOR MAY HAVE TO A TRIAL BY JURY IN ANY ACTION,
PROCEEDING OR CLAiM OF ANY NATURE RELATING TO THIS GUARANTY, ANY
DOCUMENTS EXECUTED IN CONNECTION WITH THIS GUARANTY OR ANY
TRANSACTION CONTEMPLATED IN ANY OF SUCH DOCUMENTS. THE GUARANTOR
ACKNOWLEDGES THAT THE FOREGOING WAIVER 1S KNOWING AND VOLUNTARY.
(A1346873:1)
-5-
The Guarantor acknowledges that it has read and understands all the provisions
of this Guaranty, including the confession of judgment and waiver of jury trial, and has
been advised by counsel as necessary or appropriate.
WITNESS the due execution hereof as a document under sea[, as of the date first
written above,with the intent to be legally bound hereby.
GUARANTOR:
,rp�TE 'i: P.J. S. PROPERTIES, INC.,
a Pennsylvania corporation
BY �.
Y
Na Name:
itle: Title:
{A1346873:1)
-6-
DISCLOSURE FOR CONFESSION OF JUDGMENT
Undersigned: P.J.S.PROPERTIES, INC.
30 Maplewood Avenue j
Mechanicsburg,Pennsylvania 17055
Lender: ADG—1300 Plaza West Associates
1300 Market Street
P.O. Box 622
Lemoyne,Pennsylvania 17043-0622
The undersigned has executed, and/or is executing, on or about the date hereof, a Guaranty and
Suretyship Agreement in respect of the obligations owed to Lender by 1300 MARKET, LLC, a
Pennsylvania limited liability company, under which the undersigned is obligated to repay monies to
Lender.
A. THE UNDERSIGNED ACKNOWLEDGES AND AGREES THAT THE ABOVE DOCUMENT CONTAINS
PROVISIONS UNDER WHICH LENDER MAY ENTER JUDGMENT BY CONFESSION AGAINST THE UNDERSIGNED. BEING
FULLY AWARE OF ITS RIGHTS TO PRIOR NOTICE AND A HEARING ON THE VALIDITY OF ANY JUDGMENT OR OTHER
CLAIMS THAT MAY BE ASSERTED AGAINST IT BY LENDER THEREUNDER BEFORE JUDGMENT IS ENTERED, THE
UNDERSIGNED HEREBY FREELY, KNOWINGLY AND INTELLIGENTLY WAIVES THESE RIGHTS AND EXPRESSLY
AGREES AND CONSENTS TO LENDER'S ENTERING JUDGMENT AGAINST IT BY CONFESSION PURSUANT TO THE
TERMS THEREOF.
B. THE UNDERSIGNED ALSO ACKNOWLEDGES AND AGREES THAT THE ABOVE DOCUMENT CONTAINS
PROVISIONS UNDER WHICH LENDER MAY, AFTER ENTRY OF JUDGMENT AND WITHOUT EITHER NOTICE OR A
HEARING, FORECLOSE UPON, ATTACH, LEVY, TAKE POSSESSION OF OR OTHERWISE SEIZE PROPERTY OF THE
UNDERSIGNED IN FULL OR PARTIAL PAYMENT OF THE JUDGMENT. BEING FULLY AWARE OF ITS RIGHTS AFTER
JUDGMENT IS ENTERED(INCLUDING THE RIGHT TO MOVE TO OPEN OR STRIKE THE JUDGMENT),THE UNDERSIGNED
HEREBY FREELY, KNOWINGLY AND INTELLIGENTLY WAIVES ITS RIGHTS TO NOTICE AND A HEARING (BUT NOT
THE RIGHT TO MOVE TO OPEN OR STRIKE THE JUDGMENT)AND EXPRESSLY AGREES AND CONSENTS
TO LENDER'S TAKING SUCH ACTIONS AS MAY BE PERMITTED UNDER APPLICABLE STATE AND FEDERAL LAW
WITHOUT PRIOR NOTICE TO THE UNDERSIGNED.
C. The undersigned certifies that a representative of Lender specifically called the confession of
judgment provisions in the above documents to the attention of the undersigned, and/or that the
undersigned was represented by legal counsel in connection with the above documents.
D. The undersigned hereby certifies: that its annual income exceeds$10,000;that all references
to "the undersigned" above refer to the entity signing below; and that the undersigned received a copy
hereof at the time of signing.
Dated as of September 18, 2008 GUARANTOR:
P.J.S.PROPERTIES,INC.,
a Pennsylvania corporation
By
Name:
Title: Title:
(A1346873:1)
-7-
GUARANTY AND SURETYSHIP AGREEMENT
THIS GUARANTY AND SURETYSHIP AGREEMENT (this "Guaranty") is made and
entered into as of September 18, 2008, by OPEN SKY, INC., a Pennsylvania corporation
("Guarantor"), with an address at 30 Maplewood Avenue, Mechanicsburg, Pennsylvania
17055, in consideration of the extension of credit by in consideration of the extension of credit
by ADG-1300 PLAZA WEST ASSOCIATES, a Pennsylvania limited partnership, its
successors and assigns (the "Lender"), with an address at 1300 Market Street, P.O. Box 622,
Lemoyne, Pennsylvania 17043-0622 to 1300 MARKET, LLC, a Pennsylvania limited liability
company (the "Borrower"), and other good and valuable consideration, the receipt and
sufficiency of which are hereby acknowledged.
1. Guaranty of Obligations. The Guarantor hereby guarantees,'and becomes
surety for, the prompt payment and performance of: all loans, advances, debts, liabilities,
obligations, covenants and duties owing by the Borrower to the Lender, of any kind or nature,
present or future (including any interest accruing thereon after maturity, or after the filing of any
petition in bankruptcy, or the commencement of any insolvency, reorganization or like
proceeding relating to the Borrower,whether or not a claim for post-filing or post-petition interest
is allowed in such proceeding), whether or not evidenced by any note, guaranty or other
instrument, whether arising under any agreement, instrument or document, whether or not for
the payment of money, whether arising by reason of an extension of credit, opening of a letter of
credit, loan, equipment lease or guarantee, under any interest or currency swap, future, option
or other interest rate protection or similar agreement, or in any other manner, whether arising
out of overdrafts on deposit or other accounts or electronic funds transfers (whether through
automated clearing houses or otherwise)'or out of the Lender's non-receipt of or inability to
collect funds or otherwise not being made whole in connection with depository transfer check or
other similar arrangements, whether direct or indirect (including those acquired by assignment
or participation), absolute or contingent,joint or several, due or to become due, now existing or
hereafter arising, and any amendments, extensions, renewals or increases and all costs and
expenses of the Lender incurred in the documentation, negotiation, modification, enforcement,
collection or otherwise in connection with any of the foregoing, including reasonable attorneys'
fees and expenses (collectively, the "Obligations").
If the Borrower defaults under any such Obligations, the Guarantor will pay the amount
of the Obligations to the Lender. Until the Obligations are indefeasibly paid in full, Guarantor's
liability hereunder shall not be reduced in any manner whatsoever by any amounts which the
Lender may realize before or after maturity of the Obligations, by acceleration or otherwise, as a
result of payments made by or.on behalf of the Borrower or by or on behalf of any other person
or entity other than the Guarantor primarily or secondarily liable for the Obligations or any part
thereof, or otherwise credited to the Borrower or such person or entity, or as a result of the
exercise of the Lender's rights with respect to any collateral for the Obligations or any part
thereof.
2. Nature of Guaranty; Waivers. This is a guaranty of payment and not of
collection and the Lender shall not be required, as a condition of the Guarantor's liability, to
make any demand upon or to pursue any of its rights against the Borrower, or to pursue any
rights which may be available to it with respect to any other person who may be liable for the
payment of the Obligations.
(A1346876:1)
This is an absolute, unconditional, irrevocable and continuing guaranty and will remain in
full force and effect until all of the Obligations have been indefeasibly paid in full, and the Lender
has terminated this Guaranty. This Guaranty will remain in full force and effect even if there Is
no principal balance outstanding under the Obligations at a particular time or from time to time.
This Guaranty will not be affected by any surrender, exchange, acceptance, compromise or
release by the Lender of any other party, or any other guaranty or any security held by it for any
of the Obligations, by any failure of the Lender to take any steps to perfect or maintain its lien or
security interest in or to preserve its rights to any security or other collateral for any of the
Obligations or any guaranty, or by any irregularity, unenforceability or Invalidity of any of the
Obligations or any part thereof or any security or other guaranty thereof. The Guarantor's
obligations hereunder shall not be affected, modified or impaired by any counterclaim, set-off,
deduction or defense based upon any claim the Guarantor may have against the Borrower or
the Lender, except payment or performance of the Obligations.
Notice of acceptance of this Guaranty, notice of extensions of credit to the Borrower
from time to time, notice of default, diligence, presentment, notice of dishonor, protest, demand
for payment, and any defense based upon the Lender's failure to comply with the notice
requirements of the applicable version of Uniform Commercial Code §9-610 are hereby waived.
The Guarantor waives all defenses based on suretyship or impairment of collateral.
The Lender at any time and from time to time, without notice to or the consent of the
Guarantor, and without impairing or releasing, discharging or modifying the Guarantor's
liabilities hereunder, may (a) change the manner, place, time or terms of payment or
performance of or interest rates on, or other terms relating to, any of the Obligations; (b)renew,
substitute, modify, amend or alter, or grant consents or waivers relating to any of the
Obligations, any other guaranties, or any security for any Obligations or guaranties; (c)apply
any and all payments by whomever paid or however realized including any proceeds of any
collateral, to any Obligations of the Borrower in such order, manner and amount as the Lender
may determine in its sole discretion; (d)settle, compromise or deal with any other person,
including the Borrower or the Guarantor, with respect to any Obligations in such manner as the
Lender deems appropriate in its sole discretion; (e)substitute, exchange or release any security
or guaranty; or(f)take such actions and exercise such remedies hereunder as provided herein.
3. Repayments or Recovery from the Lender. If any demand is made at any
time upon the Lender for the repayment or recovery of any amount received by it in payment or
on account of any of the Obligations and if the Lender repays all or any part of such amount by
reason of any judgment, decree or order of any court or administrative body or by reason of any
settlement or compromise of any such demand, the Guarantor will be and remain liable
hereunder for the amount so repaid or recovered to the same extent as if such amount had
never been received originally by the Lender. The provisions of this section will be and remain
effective notwithstanding any contrary action which may have been taken by the Guarantor in
reliance upon such payment, and any such contrary action so taken will be without prejudice to
the Lender's rights hereunder and will be deemed to have been conditioned upon such payment
having become final and irrevocable.
4. Financial Statements. Unless compliance is waived in writing by the Lender or
until all of the Obligations have beer' paid in full, the Guarantor will promptly submit to the
Lender such information relating to the Guarantor's affairs (including but not limited to annual
financial statements and tax returns for the Guarantor) or any security for the Guaranty as the
Lender may reasonably request.
{A1346876:7}
-2-
5. Enforceability of Obligations. No modification, limitation or discharge of the
Obligations arising out of or by virtue of any bankruptcy, reorganization or similar proceeding for
relief of debtors under federal or state law will affect, modify, limit or discharge the Guarantor's
liability in any manner whatsoever and this Guaranty will remain and continue in full force and
effect and will be enforceable against the Guarantor to the same extent and with the same force
and effect as if any such proceeding had not been instituted. The Guarantor waives all rights
and benefits which might accrue to it by reason of any such proceeding and will be liable to the
full extent hereunder, irrespective of any modification, limitation or discharge of the liability of the
Borrower that may result from any such proceeding.
6. Events of Default. The occurrence of any of the following shall be an "Event of
Default": (i)any Event of Default (as defined in any of the Loan Documents); (ii) any default
under any of the Loan Documents that does not have a defined set of"Events of Default" and
the lapse of any notice or cure period provided in such Obligations with respect to such default;
(ill) demand by the Lender under any of the instruments or agreements giving rise to any of the
Obligations that have a demand feature; (iv) the Guarantor's failure to perform any of its
obligations hereunder; (v) the falsity, inaccuracy or material breach by the Guarantor of any
written warranty, representation or statement made or furnished to the Lender by or on behalf of
the Guarantor, or (vi) the termination or attempted termination of this Guaranty. Upon the
occurrence of any Event of Default, (a) the Guarantor shall pay to the Lender the outstanding
amount of the Obligations; or (b) on demand of the Lender, the Guarantor shall immediately
deposit with the Lender, in U.S, dollars, the outstanding amount of the Obligations, and the
Lender may at any time use such funds to repay the Obligations; or (c) the Lender in its
discretion may exercise with respect to any collateral any one or more of the rights and
remedies provided a secured party under the applicable version of the Uniform Commercial
Code; or (d) the Lender in its discretion may exercise from time to time any other rights and
remedies available to it at law, in equity or otherwise.
7. Collateral. This Guaranty is secured by the property described in any collateral
security documents which the Guarantor executes and delivers to the Lender and by such other
collateral as previously may have been or may in the future be granted to the Lender to secure
any obligations of the Guarantor to the Lender.
8. Costs. To the extent that the Lender incurs any costs or expenses in protecting
or enforcing its rights under the Obligations or this Guaranty, including reasonable attorneys'
fees and the costs and expenses of litigation, such costs and expenses will be due on demand,
will be included in the Obligations and will bear interest from the incurring or payment thereof at
the Default Rate (as defined in any of the Obligations).
9. Postponement of Subrogation_. Until the Obligations are indefeasibly paid in
full, the Guarantor irrevocably postpones and subordinates in favor of the Lender any and all
rights which the Guarantor may have to (a) assert any claim against the Borrower based on
subrogation rights with respect to payments made hereunder, and (b) any realization on any
property of the Borrower, including participation in any marshalling of the Borrower's assets.
10. Power to Confess Judgment. The Guarantor hereby empowers any
attorney of any court of record,after the occurrence of any Event of Default hereunder,to
appear for the Guarantor and, with or without complaint filed, confess judgment, or a
series of judgments, against the Guarantor in favor of the Lender for the amount of the
Obligations, together with interest thereon at the (Default Rate set forth in the Note, costs
of suit and an attorney's commission of the greater of 5% of such principal and interest
(A1346876:1)
-3-
or$5,000 added as a reasonable attorney's fee, and for doing so,this Guaranty or a copy
verified by affidavit shall be a sufficient warrant. The Guarantor hereby forever waives
and releases all errors in said proceedings and all rights of appeal and all relief from"any
and all appraisement, stay or exemption laws of any state now in force or hereafter
enacted.
No single exercise of the foregoing power to confess judgment, or a series of judgments,
shall be deemed to exhaust the power,whether or not any such exercise shall be held by
any court to be invalid, voidable, or void, but the power shall continue undiminished and
It may be exercised from time to time as often as the Lender shall elect until such time as
the Lender shall have received payment in full of the outstanding balance due on the
Obligations and costs: Notwithstanding the attorney's commission provided for in the
preceding.paragraph (which Is Included in the warrant for purposes of establishing a
sum certain), ;the amount of attorneys' fees that the Lender may recover from the
Guarantor shall not exceed the actual attorneys'fees incurred by the Lender.
11. Notices. All notices, demands, requests, consents, approvals and other
communications required or permitted hereunder must be in writing and will be effective upon
receipt. Such notices and other communications may be hand-delivered, sent by facsimile
transmission with confirmation of delivery and a copy sent by first-class mail, or sent by
nationally recognized overnight courier service, to the addresses for the Lender and the
Guarantor set forth above or to such other address as one may give to the other in writing for
such purpose.
12. Preservation of Rights. No delay or omission on the Lender's part to exercise
any right or power arising hereunder will impair any such right or power or be considered a
waiver of any such right or power, nor will the Lender's action or inaction impair any such right
or power. The Lender's rights and remedies hereunder are cumulative and not exclusive of any
other rights or remedies which the Lender may have under other agreements, at law or in
equity. The Lender may proceed in any order against the Borrower, the Guarantor or any other
obligor of, or any collateral securing, the Obligations.
13. Illegality. In case any one or more of the provisions contained in this Guaranty
should be invalid, illegal or unenforceable in any respect, the validity, legality and enforceability
of the remaining provisions contained herein shall not in any way be affected or impaired
thereby.
14. Changes in Writing. No modification, amendment or waiver of any provision of
this Guaranty nor consent to any departure by the Guarantor therefrom, will be effective unless
made in a writing signed by the Lender, and then such waiver or consent shall be effective only
in the specific instance and for the purpose for which given. No notice to or demand on the
Guarantor in any case will entitle the Guarantor to any other or further notice or demand in the
same, similar or other circumstance.
15. Entire Agreement. This Guaranty (including the documents and instruments
referred to herein) constitutes the entire agreement and supersedes all other prior agreements
and understandings, both written and oral, between the Guarantor and the Lender with respect
to the subject matter hereof; provided, however, that this Guaranty is in addition to, and not in
substitution for, any other guarantees from the Guarantor to the Lender.
{A13465876:1}
-4-
16. Successors and Assigns. This Guaranty will be binding upon and inure to the
benefit of the Guarantor and the Lender and their respective heirs, executors, administrators,
successors and assigns; provided, however, that the Guarantor may not assign this Guaranty in
whole or in part without the Lender's prior written consent and the Lender at any time may
assign this Guaranty in whole or in part.
17. Interpretation. In this Guaranty, unless the Lender and the Guarantor otherwise
agree in writing, the singular includes the plural and the plural the singular, references to
statutes are to be construed as including all statutory provisions consolidating, amending or
replacing the statute referred to; the word "or" shall be deemed to include "and/or", the words
"including", "includes" and "include" shall be deemed to be followed by the words "without
limitation"; and references to sections or exhibits are to those of this Guaranty unless otherwise
indicated. Section headings in this Guaranty are included for convenience of reference only and
shall not constitute a part of this Guaranty for any other purpose. If this Guaranty is executed by
more than one party as Guarantor, the obligations of such persons or entities will be joint and
several.
18. Indemnity. The Guarantor agrees to indemnify each of the Lender, its directors,
officers and employees and each legal entity, if any, who controls the Lender(the"Indemnified
Parties") and to hold each Indemnified Party harmless from and against any and all claims,
damages, losses, liabilities and expenses (including all fees and charges of internal or external
counsel with whom. any Indemnified Party may consult and all expenses of litigation or
preparation therefor) which any Indemnified Party may incur or which may be asserted against
any Indemnified Party as a result of the execution of or performance under this Guaranty;
provided, however, that the foregoing indemnity agreement shall not apply to claims, damages,
losses, liabilities and expenses solely attributable to an Indemnified Party's gross negligence or
willful misconduct. The indemnity agreement contained in this Section shall survive the
termination of this Guaranty. The Guarantor may participate at its expense in the defense of
any such claim. .
19. Governing Law and Jurisdiction. This Guaranty has been delivered to and
accepted by the Lender and will be deemed to be made in the Commonwealth of Pennsylvania.
THIS GUARANTY WILL BE INTERPRETED AND THE RIGHTS AND LIABILITIES OF THE LENDER AND THE
GUARANTOR DETERMINED IN ACCORDANCE WITH THE [AWS OF COMMONWEALTH OF PENNSYLVANIA,
EXCLUDING ITS CONFLICT OF LAWS RULES. The Guarantor hereby irrevocably consents to the
exclusive jurisdiction of the Court of Common Pleas of Cumberland County, Pennsylvania;
provided that nothing contained in this Guaranty will prevent the Lender from bringing any
action, enforcing any award or judgment or exercising any rights against the Guarantor
individually, against any security or against any property of the Guarantor within any other
county, state or other foreign or domestic jurisdiction. The Guarantor acknowledges and agrees
that the venue provided above is the most convenient forum for both the Lender and the
Guarantor. The Guarantor waives any objection to venue and any objection based on a more
convenient forum in any action instituted under this Guaranty.
20. WAIVER OF JURY TRIAL. THE GUARANTOR IRREVOCABLY WAIVES ANY
i AND ALL RIGHT THE GUARANTOR MAY HAVE TO A TRIAL BY JURY IN ANY ACTION,
PROCEEDING OR CLAIM OF. ANY NATURE RELATING TO THIS GUARANTY, ANY
DOCUMENTS EXECUTED IN CONNECTION WITH THIS GUARANTY OR ANY
TRANSACTION CONTEMPLATED IN ANY OF SUCH DOCUMENTS. THE GUARANTOR
ACKNOWLEDGES THAT THE FOREGOING WAIVER IS KNOWING AND VOLUNTARY.
{a1346876:1}
-5-
The Guarantor acknowledges that it has read and understands all the provisions
of this Guaranty, including the confession of judgment and waiver of jury trial, and has
been advised by counsel as necessary or appropriate.
WITNESS the due execution hereof as a document under seal, as of the date first
written above, with the intent to be legally bound hereby.
GUARANTOR:
TFfSrt: OPEN SKY, INC.,
a Pennsylvania corporation
gy
By Pf�;1�C ri
e: Name:
Title: Title:
(AlM876:1)
-6 -
DISCLOSURE FOR CONFESSION OF JUDGMENT
Undersigned: OPEN SKY, INC.
30 Maplewood Avenue i
Mechanicsburg,Pennsylvania 17055
Lender. ADG—1300 Plaza West Associates
1300 Market Street
P.O.Box 622
Lemoyne,Pennsylvania 17043-0622
The undersigned has executed, and/or is executing, on or about the date hereof, a Guaranty and
Suretyship Agreement in respect of the obligations owed to Lender by 1300 MARKET, LLC, a
Pennsylvania limited liability company, under which the undersigned is obligated to repay monies to
Lender.
A. THE UNDERSIGNED ACKNOWLEDGES AND AGREES THAT THE ABOVE DOCUMENT CONTAINS
PROVISIONS UNDER WHICH LENDER MAY ENTER JUDGMENT BY CONFESSION AGAINST THE UNDERSIGNED. BEING
FULLY AWARE OF ITS RIGHTS TO PRIOR NOTICE AND A HEARING ON THE VALIDITY OF ANY JUDGMENT OR OTHER
CLAIMS THAT MAY BE ASSERTED AGAINST IT BY LENDER THEREUNDER BEFORE JUDGMENT IS ENTERED, THE
UNDERSIGNED HEREBY FREELY, KNOWINGLY AND INTELLIGENTLY WAIVES THESE RIGHTS AND EXPRESSLY
AGREES AND CONSENTS TO LENDER'S ENTERING JUDGMENT AGAINST IT BY CONFESSION PURSUANT TO THE
TERMS THEREOF.
B. THE UNDERSIGNED ALSO ACKNOWLEDGES AND AGREES THAT THE ABOVE DOCUMENT CONTAINS
PROVISIONS UNDER WHICH LENDER MAY, AFTER ENTRY OF JUDGMENT AND WITHOUT EITHER NOTICE OR A
HEARING, FORECLOSE UPON, ATTACH, LEVY, TAKE POSSESSION OF OR OTHERWISE SEIZE PROPERTY OF THE
UNDERSIGNED IN FULL OR PARTIAL PAYMENT OF THE JUDGMENT. BEING FULLY AWARE OF ITS RIGHTS AFTER
JUDGMENT IS ENTERED(INCLUDING THE RIGHT TO MOVE TO OPEN OR STRIKE THE JUDGMENT),THE UNDERSIGNED
HEREBY FREELY, KNOWINGLY AND INTELLIGENTLY WAIVES ITS RIGHTS TO NOTICE AND A HEARING (BUT NOT
THE RIGHT TO MOVE TO OPEN OR STRIKE THE JUDGMENT)AND EXPRESSLY AGREES AND CONSENTS
TO LENDER'S TAKING SUCH ACTIONS AS MAY BE PERMITTED UNDER APPLICABLE STATE AND FEDERAL LAW
WITHOUT PRIOR NOTICE TO THE UNDERSIGNED.
C. The undersigned certifies that a representative of Lender specifically called the confession of
judgment provisions in the above documents to the attention of the undersigned, and/or that the
undersigned was represented by legal counsel in connection with the above documents.
D. The undersigned hereby certifies: that Its annual income exceeds$10,000;that all references
to "the undersigned" above refer to the entity signing below; and that the undersigned received a copy
hereof at the time of signing.
Dated as of September 18, 2008 GUARANTOR:
AA ,T OPEN SKY, INC.,
t Jew'%A**, : a Pennsylvania corporation
By , X P1'es�
Nam Name:
Titie:
i
I
(A1346876:1)
-7-
ADG-1300 PLAZA WEST ASSOCIATES, IN THE COURT OF COMMON PLEAS OF
Plaintiff, CUMBERLAND COUNTY, PENNSY VANIA
V. NO. GT Ctut
CHESTNUT STREET TOWNHOUSES,
LLC, P.J.S. PROPERTIES, INC., and
OPEN SKY, INC.,
Defendants CIVIL ACTION - LAW
NOTICE OF ENTRY OF JUDGMENT
TO: Chestnut Street Townhouses, LLC P.J.S. Properties, Inc.
30 Maplewood Avenue 30 Maplewood Avenue
Mechanicsburg, PA 17055 Mechanicsburg, PA 17055
Open Sky, Inc.
30 Maplewood Avenue
Mechanicsburg, PA 17055
You are hereby notified that on December 2014, a judgment was entered against you
in the amount of$158,210.00 (along with interest accruing at the per diem rate of $41.67 after
December 4, 2014 until paid in full), in the above-capti ned case.
DATE:
Prothonotary
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 or (800) 990-9108
I hereby certify that the addresses for the Defendants are as follows:
Chestnut Street Townhouses, LLC P.J.S. Properties, Inc.
30 Maplewood Avenue 30 Maplewood Avenue
Mechanicsburg, PA 17055 Mechanicsburg, PA 17055
Open Sky, Inc.
30 Maplewood Avenue
Mechanicsburg, PA 17055
McNEES WALLACE &NURICK LLC
Date: December 10, 2014 By ae'04��
Clayton W. Davidson
Attorney I.D. 79139
100 Pine Street- P. O. Box 1166
Harrisburg, PA 17108-1166
Direct Fax: 717-260-1678
Phone: 717-232-8000
cdavidson@rnwn.com
Attorneys for Plaintiff, ADG-1300 Plaza West
Associates