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HomeMy WebLinkAbout05-2395 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MASSIMO TRATTORIA, INC., a Pennsylvania Corporation and MASSIMO NAPOLI, individually Plaintiffs No. 05 - ;2.3'1-5 C~u,L~V-1 vs. WILLIAM F. ROTHMAN, CHARLES F. SCHUBERT and SAMUEL L. REED, co-partners tJd/b/a ROTHMAN, SCHUBERT & REED, a Pennsylvania General Partnership Defendants JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 2 LIBERTY AVENUE CARLISLE PA 17013 800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MASSIMO TRATTORIA, INC., a Pennsylvania Corporation and MASSIMO NAPOLI, individually Plaintiffs vs. No. DS' -;).39--S C/u~l~~ WILLIAM F. ROTHMAN, CHARLES F. SCHUBERT and SAMUEL L. REED, co-partners tJd/b/a ROTHMAN, SCHUBERT & REED, a Pennsylvania General Partnership Defendants JURY TRIAL DEMANDED COMPLAINT Plaintiffs Massimo Trattoria, Inc., a Pennsylvania Corporation and Massimo Napoli, individually, by and through their attorneys, Goodall & Yurchak, P.C., files the following Complaint: 1. Massimo Napoli is an individual with an address of 2248 Saw Palmetto Lane, Building 7, Apt. 117, Orlando, FL 32825. 2. Massimo Trattoria, Inc. is a Pennsylvania corporation with a mailing address of 2248 Saw Palmetto Lane, Building 7, Apt. 117, Orlando, FL 32825. 3. Upon information and belief, Rothman, Schubert and Reed (hereinafter referred to as "RSR") is a Pennsylvania General Partnership, with a business address of 3 Lemoyne Drive, Suite 100, Lemoyne, PA 17043. 4. Defendant William F. Rothman, an individual, with an address of 3 Lemoyne Drive, Suite 100, Lemoyne, PA 17043. 5. Defendant Charles F. Schubert, an individual with an address of 3 Lemoyne Drive, Suite 100, Lemoyne, PA 17043. 6. Defendant Samuel L. Reed, an individual with an address of 3 Lemoyne Drive, Suite 100, Lemoyne, PA 17043. 7. On or about November 8, 2004, RSR entered into a Lease Agreement (the "Lease") with Massimo Trattoria for the lease of approximately 2,460 square feet of gross leasable area identified as Block H, Unit 7 and 8 with an address of 385 East Penn Drive, Enola, Pa 17025 (the "Leased Premises"). A copy of the Lease Agreement is attached as Exhibit ''1''. 8. The Leased Premises is located in Pennsboro Commons Shopping Center, Cumberland County, PA. 9. The Lease term was for five (5) years. 10. At the time of entry into the Lease, RSR was aware and had been advised that the purpose of Massimo Trattoria's leasing of the Leased Premises was for an eat- in Italian restaurant serving lunch and dinner with a high-end atmosphere. 11. At the time the Lease was signed, RSR knew or should have known that the current heating and cooling units in location on the Leased Premises were not sufficient to allow operation, under the applicable building code requirements, of a dine- in restaurant serving lunch and dinner with a high-end atmosphere. 12. RSR failed to advise Plaintiffs that the current heating and cooling units were not sufficient. 13. Immediately after the Lease was executed, Massimo Trattoria began completing the buildout of the Leased Premises including floor covering, additional plumbing and additional hot water heater as contemplated to serve the Leased Premises. 14. This buildout, floor covering and additional plumbing was done at Massimo Trattoria's expense in an amount exceeding $90,000.00. 15. Additionally, Massimo Trattoria and Massimo Napoli individually incurred other expenses in the preparation for the opening of a restaurant including advertising services, utility service and other purchase of equipment totaling approximately $35,000.00. 16. Plaintiffs incurred additional damages in time and expenses in preparation for the opening of the contemplated restaurant. 17. After signing of the Lease, construction proceeded at the Leased Premises with Massimo Napoli and Massimo Trattoria expending money in preparation for opening of the facility. 18. Construction done at the Leased Premises was subject to permitting and inspection by East Pennsboro Township. 19. In December 2004, the East Pennsboro Township Building Inspector- Codes Enforcement Officer notified Plaintiffs that it could not provide an occupancy permit and/or was issuing a stop work order because, among other things, the HVAC equipment was not acceptable to handle the air requirements for the assembly occupancy load. 20. Defendants were aware or should have been aware that the HVAC equipment could not handle the air requirements for the use of a restaurant as contemplated. 21. In short, RSR leased the Leased Premises to Massimo Trattoria, which premises could not support its intended use. 22. The Plaintiffs relied on the representations made by RSR regarding its intended use and that the premises would be suitable for a restaurant for a restaurant facility. 23. Except for the HVAC and air supply issue, Massimo Napoli was in the position to complete construction to open his restaurant on or about January 9, 2005. 24. Because Plaintiffs were not able to open its restaurant due to the air supply restrictions, the Plaintiffs have not been earning income to pay back his bank loan and Lease payments. 25. The inability of Plaintiffs to open their restaurant because of the current state of the HVAC equipment forced Plaintiffs into a position where they were unable to open up the restaurant and earn an income. I. Breach of Contract 26. The preceding paragraphs 1 through 25 are incorporated herein by reference as if set forth at length. 27. By failing to provide a Leased Premises which was sufficient for its permitted use, Defendants breached the November 8, 2004 Lease Agreement. 28. As such, the Defendants are responsible for damages for breach of Lease, including all expenses related to the build out and accompanying costs, interests, lost profits and attorneys fees. WHEREFORE, Plaintiffs demand judgment against Defendants for compensatory damages in an amount in excess of $35,000.00 plus costs. II. Recession 29. The preceding paragraphs 1 through 28 are incorporated herein by reference as if set forth at length. 30. The determining motive for the Lease was to secure a Leased Premises for an Italian restaurant. 31. The state of the HV AC was essential for the operation and opening of the business. 32. This determining motive was known to the Defendants at the time of signing of the Lease. At the time of signing of the Lease, Defendants knew or should have known that the HVAC system was not sufficient to support the determining motive for the Leased Premises. 33. The Plaintiffs did not and should not have known about the state of the HVAC system. 34. As a result, Plaintiffs seek recision for unilateral mistake relating to the Leased Premises with attendant damages relating to costs of renovation, and any other charges incurred as a result of entering into this Lease. WHEREFORE, Plaintiff demands judgment against Defendants for compensatory damages in an amount in excess of $35,000.00 plus costs. III. Fraud/MisreDresentation 35. The preceding paragraphs 1 through 34 are incorporated herein by reference as if set forth at length. 36. The Defendants failed to disclose to the Plaintiffs material facts known to them concerning the Leased Premises, specifically relating to the HVAC system. 37. Defendants through the oral and written statements in the Lease, represented that the facility was sufficient for its intended use. 38. Defendants had a duty to disclose to the Plaintiffs all material information relating to the state of the premises. 39. The Plaintiff justifiably relied upon the representations made by the Defendants. 40. Had the Plaintiffs known all the material facts relating to the state of the Leased Premises, they would not have proceeded with entry into the Lease. As a result of the Defendants' actions, the Plaintiffs were ultimately forced to expend money for the buildout and construction of the premises. 41 . Plaintiffs seek recision of the Lease on the basis of fraud and/or misrepresentation, with restitution and for compensatory damages. WHEREFORE, Plaintiffs demand judgment against Defendants for compensatory damages in an amount in excess of $35,000.00 and costs. Respectfully submitted, GOOD L & YURCHAK .C. Kathleen V. Yurch ,Esq. PA. 1.0. 55948 328 South Athert State College, P (814) 237-4100 Date: April 27, 2005 VERIFICATION Massimo Napoli individually and as Massimo Trattoria, avers that the factual averments contained in the foregoing Complaint are true and correct to the best of his knowledge, information and belief, and the statements in said Complaint are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsifications to authorities. J dlb\rsr\MassimoNapoli.lse November 4, 2004 LEASE LETTER Pennsboro Commons Shopping Center Rothman, Schubert & Reed 3 Lemoyne Drive, Suite 100 Lemoyne, PA 17043 Lease dated (1) C; \ ;~ , 2004 between William F. Rothman, Charles F. Schubert & Samuel L. Reed, Co-Partners, tfd/b/a Rothman, Schubert & Reed, a Pennsylvania General Partnership, Owner, and Massimo Napoli, Inc., a Pennsylvania corporation, Tenant, covering Premises located in Pennsboro Commons Shopping Center, East Pennsboro Township, Cumberland County, Pennsylvania. RE: The undersigned, as Tenant, hereby confirms the following: 1. Tenant has accepted possession of the Premises demised pursuant to the terms of the above- described Lease. 2. The improvements and space required to be furnished according to the aforesaid Lease have been completed and supplied in all respects. 3. Landlord-Owner has fulfilled all of its duties of an inducement nature. 4. The aforesaid Lease has not been modified, altered or amended except as set forth below. 5. There are no offsets or credits due against rentals nor have rentals been prepaid except as provided by the Lease terms. 6. The initial term of said Lease began on the ---I day of jleV ,2004, and rentals commenced to accrue on that date; the initial Lease Term expires on () I.fV-1 ;:) OQ i 7. or of the Lease. By: MaSliimo / Exhibi t 1 LEASE AGREEMENT PENNSBORO COMMONS SHOPPING CENTER 2 LEASE AGREEMENT WITNESSETH, that in consideration of mutual covenants, Owner and Tenant hereby agree as follows: SECTION A. BASIC LEASE PROVISIONS AND ENUMERATION OF EXHIBITS Section A-I. Basic Lease Provisions. DATE: ,2004 SHOPPING CENTER: Pennsboro Commons Shopping Center Cumberland County, Pennsylvania OWNER: William F. Rothman, Charles F. Schubert & Samuel L. Reed, Co-Partners, t/d/b/a Rothman, Schubert & Reed, a Pennsylvania General Partnership with an address of 3 Lemoyne Drive, Suite JOO, Lemoyne, PA 17043. -ir'-flJfoR\11 Massimo ~~ a Pennsylvania corporation 384 East Penn Drive, Enola, P A 17025 TENANT: TENANT'S ADDRESS: TENANT'S PHONE NUMBER: 407-491-7686 TENANT'S TRADE NAME: ~ MASSIH01hmfO(1JA ~ LEASED PREMISES: The Premises outlined in red on Exhibit A containing approximately 2,460 square feet of Gross Leasable Area and identified as Block H, Units 7 and 8 with an address of 384 East Penn Drive, Enola, PA 17025. LEASED TERM: Five (5) Years. RENEWAL TERM: Two (2), Five (5) Year options. 3 PERIOD FOR COMPLETION OF TENANT'S WORK: PERMITTED USES: ANNUAL MINIMUM RENT: PERCENTAGE RATE: BREAKPOINT: INITIAL ESTIMATED COMMON FACILITIES CONTRIBUTION FOR TENANT: INITIAL ESTIMATED TAX CHARGE FOR TENANT: Tenant's work shall be completed on or before 30 days after Owner substantially completes Owner's Work set forth in Exhibit B and makes the Leased Premises available to Tenant. The term "substantially completes" as used in this paragraph shall mean that Owner has completed Owner's Work with the exception of minor items which can be fully completed prior to completion of Tenant's Work without material interference with Tenant's Work or upon receipt of a certificate of occupancy from East Pennsboro Township, whichever occurs sooner. Eat-inJDine-in Italian Trattoria restaurant serving lunch and dinner with a high end atmosphere, white table cloths, BYOB, and serving such menu items as are set forth on the attached Exhibit E, and not otherwise in violation of any currently granted or existing exclusives granted to other Tenants. Tenant shall pay to Owner, as Annual Minimum Rent, on the first day of every month, in advance, and at a rate of $16.00 per square foot, the sum of $39,360 annually ($3,280/month) for the five (5) year Lease Term. The Annual Minimum Rent for the renewal term(s), if any, shall be: First Option: $17.00 per square foot, $41,820 annually ($3,485/month) Second Option: $18.00 per square foot, $44,280 annually ($3,690/month) N/A% $N/A $3,690.00 per calendar year ($307.50 per month) (subject to adjustment as set forth in Article vn of this Lease) $2,460.00 per tax year ($205.00 per month) (subject to adjustment as set forth in Article VI of this Lease) 4 INITIAL ESTIMATED INSURANCE CHARGE FOR TENANT: $615.00 per calendar year ($51.25 per month) (subject to adjustment as set forth in Article X of this Lease) SECURITY DEPOSIT: Upon execution of this Lease, Tenant shall deposit the sum of $3,280.00 with Owner to secure the performance of the obligations of Tenant herein contained. Section A-2. Effect of Reference to a Basic Lease Provision. Each reference in this Lease to any of the Basic Lease Provisions contained in Section A-I shall be deemed to incorporate all of the terms provided under each such Basic Lease Provision. Section A-3. Enumeration of Exhibits. The Exhibits enumerated in this Section and attached to this Lease are hereby incorporated in this Lease by reference and each party agrees to perform all obligations binding upon it under such Exhibits. Exhibit A Exhibit A-I Exhibit B Exhibit C Exhibit D Exhibit E Site Plan Legal Description of Owner's Tract Owner's Work Rules and Regulations Guaranty of Lease Sample Menu RECITALS Owner owns fee title to certain real property described on Exhibit A-I. The real property described on Exhibit A-I (as the same may be expanded or reduced as contemplated in this Lease) is herein called "Owner's Tract." The term "Shopping Center" shall mean Owner's Tract, together with the buildings and other improvements thereon from time to time. ARTICLE I - GRANT AND TERM Section 1.01. Leased Premises and Common Areas. Owner leases to Tenant and Tenant rents from Owner those premises located in the Shopping Center and described as the "Leased Premises" in Section A-I of the Basic Lease Provisions, together with the appurtenances specifically herein granted. The use by Tenant of the Leased Premises shall include the non-exclusive use of the "Common Facilities" (as defined in Section 7.02) shown on Exhibit A, and such other Common Facilities as may be designated from time to time by Owner, subject, however, to the provisions of Section 4.02 and 7.04 and to the other terms and conditions of this Lease. 5 Section 1.02. Term. The term of this Lease and Tenant's obligation to pay rent shall, subject to the provisions of Section 23.02, commence upon the earlier of the following dates (the "Commencement Date"): (i) the date on which Tenant shall open the Leased Premises for business with the public, or (ii) the date of expiration of the "Period For Completion of Tenant's Work" designated in Section A-I of the Basic Lease Provisions, but no later than that date which is sixty-days (60) days after the date the Lease is signed by both parties. The term of this Lease shall expire, unless sooner tenninated as in this Lease provided, on the last day of the last "Leased Year" (as defined in Section 23.04) provided under "Lease Term" in Section A-I of the Basic Lease Provisions. In order to extend the Leased Term as provided under "Renewal Term" in Section A-I of the Basic Lease Provisions, Tenant shall give Owner ninety (90) days written notice of its intention to renew the Leased Term prior to the end of the then current term at the amount designated for the renewal terms provided under Annual Minimum Rent in Section A-I of the Basic Lease Provision. Section 1.03. Obligations Prior to Commencement of Term. Tenant shall perform all of its obligations under this Lease (except its obligations to pay rent and other charges) from the date upon which the Leased Premises are first made available to Tenant until the Commencement Date. Section 1.04. Owner's Financing Contingencv. INTENTIONALLY OMITTED ARTICLE II. RENT Section 2.0 I. Annual Minimum Rent. Tenant shall pay to Owner, without any prior demand, deduction or setoff, the "Annual Minimum Rent" specified in Section A-I of the Basic Lease Provisions, in equal monthly installments on or before the first day of each calendar month in advance. Annual Minimum Rent for a fractional calendar month shall be prorated. Section 2.02. Percentage Rent. INTENTIONALLY OMITTED Section 2.03. Gross Receipts Defined. The term "Gross Receipts" is defined to mean: (i) the entire amount of the price charged, whether wholly or partially in cash or on credit, or otherwise, for all goods, wares, merchandise and chattels of any kind, sold, leased, licensed or delivered, and all charges for services sold or performed in, at, upon or from any part of or through the use of the Leased Premises or any part thereof by Tenant and any other person, firm or corporation, or by means of any mechanical or other vending device (other than pay telephones and those soft drink and other similar vending devices operated primarily for the convenience of Tenant's employees); and (ii) all gross income of Tenant and any other person, firm or corporation from any operations in, at, upon or from the Leased Premises which are neither included in nor excluded from Gross Receipts by other provisions of this Lease. but without any duplication. Gross Receipts shall not include the amount of any sales tax, use tax or retail excise tax which is imposed by any duly constituted governmental authority directly on sales and which is both added to the selling price (or absorbed therein) and is paid to the taxing authority by Tenant (but not any vendor of Tenant). No franchise or capital stock tax, and no income or similar tax based upon income or profits as such, and no personal property tax, shall be deducted from Gross Receipts. 6 Section 2.04. Additional Rent. Tenant shall pay, upon demand as additional rent, all charges required to be paid by Tenant under this Lease, whether or not the same are designated "additional rent". Section 2.05. Interest. If Tenant shall fails to pay within five (5) days from when the same is due and payable, any rent or any additional rent, Tenant shall, upon demand, pay Owner (i) a late charge of $100.00 for each installment of Annual Minimum Rent or other charge past due and (ii) interest at the "Interest Rate" (as defined in Section 23.04) on the arrearages from the due date thereof until paid. ARTICLE ill - RECORDS; REPORTS AND AUDIT Section 3.01. Tenant's Records; Reports and Audit. Tenant agrees to prepare and keep true and complete records and accounts for at least 24 months after each Lease Year during the term of this Lease of all final records including but not limited to income statement, balance sheet and financial statement for each such Lease Year in accordance with generally accepted accounting principles consistently followed. Tenant shall provide such financial records to Owner within 15 days of Owner's written request for the purpose of satisfying a current or future mortgagee or purchaser in the event that Owner would refinance or sell the Shopping Center and such mortgagee or purchaser would request such information; provided that Owner shall (i) keep confidential, not disclose (other than to the mortgagee or purchaser) or otherwise use for its benefit, such information, and (ii) cause the mortgagee or purchaser to agree in writing to keep confidential, not disclose or otherwise use for its benefit such information. ARTICLE IV - CONSTRUCTION. ALTERATIONS. ADDITIONS AND RELOCATIONS OF IMPROVEMENTS Section 4.01. Owner's and Tenant's Work. (A) Owner and Tenant shall construct the Leased Premises in accordance with the provisions of Exhibits B. All of Tenant's Work with respect to utility installations shall also be subject to approval, when applicable, by the utility company furnishing the service. (B) Owner or an authorized utility company shall have the right to construct, maintain, repair, replace and relocate utility lines, pipes, conduits and duct work where necessary or desirable, through attic space, column space or other similar areas of the Leased Premises, and to repair, alter, replace or remove the same, all in a manner which does not interfere unreasonably with Tenant's use thereof, and Tenant shall not be entitled to an abatement or reduction of rent or to claim an actual or constructive eviction by reason thereof. "Owner's Work" (hereinafter defined in Exhibit B) shall be deemed approved by Tenant in all respects except for items of Owner's Work which are not completed or do not conform to Exhibit B and as to which Tenant shall have given notice to Owner within 30 days after the commencement of the term. Section 4.02. Changes and Additions to the Shopping Center. Notwithstanding anything set forth in this Lease to the contrary, it is agreed that Owner reserves the right, without invalidating this Lease or modifying any provision thereof except Exhibit A, at any 7 time either before, during or after the initial construction thereof, (i) to make alterations, changes, deletions and additions (including additional stories) to the buildings, Common Facilities and other improvements in the Shopping Center (excluding the interior of the Leased Premises); (ii) to add and permit to be added additional land(s) to the Shopping Center and to exclude land(s) therefrom; (iii) to construct and to permit to be constructed additional buildings and other improvements in the Shopping Center; (iv) to remove or relocate the whole or any part of any building or other improvement in the Shopping Center; and (v) to relocate the premises leased to any other tenant. PROVIDED, HOWEVER, the foregoing shall not be construed as permitting Owner to change the location of, or otherwise unreasonably interfere with Tenant's use of the Leased Premises. ARTICLE V - CONDUCT OF BUSINESS BY TENANT Section 5.01. Use of Premises. Tenant shall operate the Leased Premises under the "Trade Name", if any, specified in Section A-I of the Basic Lease Provisions and shall use the Leased Premises solely for the "Permitted Uses" specified therein and for no other use or purpose whatsoever. Tenant shall not permit any business to be operated in or from the Leased Premises by any concessionaire or licensee without the prior consent of Owner. Section 5.02. Operation of Business. Tenant shall, subject to the provisions of Section 22.02, (i) open the Leased Premises by the date provided in Section 1.02 and thereafter continuously operate all of the Leased Premises in good faith during the term so as to produce the maximum profitable and practical Gross Receipts which may be produced by such manner of operation; and (ii) keep the Leased Premises open for business and the signs therefore lighted during such reasonable and customary lunch and dinner hours for an eat in/dine in restaurant. If Tenant defaults in respect to any of the foregoing covenants then Tenant shall, in recognition of the difficulty or impossibility of determining Owner's damages, pay to Owner, upon demand, as liquidated damages (and not as a penalty) and in addition to the Annual Minimum Rent and other charges payable under this Lease, a separate charge equal to 1/365 of the then applicable Annual Minimum Rent for each day, or part thereof, Tenant fails to open or operate the Leased Premises in accordance with the provisions of this Section. 5.03. Radius Restriction. If Tenant or "Guarantor" (if any) or (if Tenant is not an individual or partnership) any subsidiary or parent corporation of Tenant or Guarantor, or any affiliate of Tenant or Guarantor shall directly or indirectly engage or participate in, as owner, principal, employee or agent, or through any subsidiary, or affiliate, or furnish financial or other aid or support to, any business enterprise or undertaking which is materially competitive with the uses specified in Section 5.01 of the Lease Agreement, and such business is located within 3 miles from any boundary line of the Shopping Center, then Owner shall have the right, in recognition of the fact that the Annual Percentage Rent payable hereunder may be reduced by such competition, to require by notice to Tenant that 33 % of any and all gross sales (which shall be coextensive in scope to Gross Receipts as defined in this Lease) made at, in or from any such competing operation shall be deemed Gross Receipts for the purpose of computing the Annual Percentage Rent due under this Lease, with the same force and effect as though such percentage of gross sales had actually been made in the Leased Premises and in such event the provisions of Article ill shall be applicable to such competing operation and the gross sales received therein. 8 Section 5.04. Parking. Tenant and employees of Tenant shall park their automobiles in the side and rear parking areas designated by Owner for employees. Owner shall provide appropriate lighting for said area. In the event that Owner observes or becomes aware of a pattern of Tenant's employees parking in unauthorized areas, Owner shall notify Tenant in writing. If Tenant's employees continue parking in such areas after such written notice, Owner shall be entitled to tow improperly parked vehicles at the automobile owner's expense and without further notice. ARTICLE VI - TAXES Section 6.0 I. Taxes. (A) The term "Taxes" shall mean the aggregate of the real estate taxes, assessments and other governmental charges and levies, general and special, ordinary and extraordinary, foreseen and unforeseen, of any kind or nature whatsoever (including assessments for public improvements or benefits and interest on unpaid installments thereof) which may be levied, assessed or imposed or become liens upon the Shopping Center, or which arise out of the use, occupancy or possession of the Shopping Center (land, buildings and permanent improvements) from time t6 time. The term "Taxes" shall not, however, include inheritance, estate, succession, transfer, gift, franchise, corporation, income or profit tax imposed upon Owner, nor penalties imposed upon Owner for Owner's delinquent payment of the Taxes; PROVIDED, HOWEVER, that if at any time during the term of this Lease the methods of taxation prevailing at the commencement of the term of this Lease shall be altered so that in addition to or in lieu of or as a substitute for the whole or any part of the Taxes now levied, assessed or imposed on real estate as such there shall be levied, assessed or imposed (i) a tax on the rents received from the Shopping Center; or (Ii) a license fee measured by the rents receivable by Owner from the Shopping Center; or (iii) a tax or license fee imposed upon Owner which is otherwise measured by or based in whole or in part upon the Shopping Center or any portion thereof, then such tax or fee shall be included in the computation of Taxes, computed as if the amount of such tax or fee so payable were that part due if the Shopping Center were the only property of Owner subject thereto. (B) The term "Tax Year" shall mean the 12 month period established as the real estate tax year by the taxing authorities having jurisdiction over the Shopping Center. (C) The term "Tenant's Tax charge" shall mean an amount equal to the product obtained by multiplying the sum of the Taxes for each Tax Year plus all costs, expenses and attorneys' fees incurred by Owner in contesting any Taxes during such Tax Year (which Owner may do at its option) by "Tenant's Percentage Share" (hereinafter defined in Section 23.04) as of the date the Taxes for such Tax Year are assessed. For the Tax Year in which this Lease commences or terminates, Tenant's Tax Charge shall be prorated. (D) Tenant's Tax Charge shall be paid to Owner in monthly installments (as estimated by Owner) in advance on the first day of each calendar month during such Tax Year. Owner's estimate of Tenant's Tax Charge for the Tax Year in which this Lease commences is set forth in Section A-I of the Basic Lease Provisions. Within 90 days after the end of each Tax Year, Owner shall deliver a copy to Tenant of all tax bills for such Tax Year and certify to Tenant the amount of Tenant's Tax Charge and Owner and Tenant shall then adjust any overpayment or underpayment by Tenant of Tenant's Tax Charge for such Tax Year. Any payment required in connection with an overpayment or underpayment shall be due within thirty (30) days. Owner's failure to provide such information within the 90 days shall in no way excuse the Tenant from its obligations to pay any underpayment or constitute a waiver of Owner's right to bill and collect such underpayment from Tenant in accordance with this paragraph. 9 (E) Tenant shall pay (or reimburse Owner upon demand if the same are levied against Owner or the Shopping Center), before delinquency, any and all taxes, assessments, license fees and public charges, of whatever kind or nature, levied or assessed during the term by any governmental authority against Tenant's business in the Leased Premises and the fixtures, furniture, appliances and any other personal property therein. (F) Owner shall have the sole, absolute and unrestricted right (but not the obligation) to contest and/or compromise the validity or amount of any Tax by appropriate proceedings. Owner shall have the right (but not the obligation), if permitted by law, to make installment payments of any assessments levied against the Shopping Center, and in such event, Tenant's share of the Taxes shall be computed upon the installments thereon paid by Owner in each Tax Year. ARTICLE VII - COST OF MAINTENANCE AND CONTROL OF COMMON FACILITIES Section 7.01. Common Facilities Contribution. In each calendar year during the term, Tenant shall pay to Owner an amount (the "Common Facilities Contribution") equal to a proportion of the "Operating Cost" (as defined in Section 7.02) of the Common Facilities ("Tenant's Common Facilities Contribution"). Tenant's Common Facilities Contribution for each calendar year during the term shall be that portion of the Operating Cost for such calendar year equal to the product obtained by multiplying the Operating Cost for such calendar year by Tenant's Percentage Share (hereinafter defined in Section 23.04) as of the first day of such calendar year. Section 7.02. Operatinl! Cost and Common Facilities Defined. (A) The term "Operatinl! Cost" shall mean the total cost (other than the cost properly chargeable to capital account, except as herein specifically provided) and expense incurred in operating, maintaining, equipping, inspecting, protecting and repairing the Common Facilities, including without limitation, the cost or expense of, or incurred in connection with or reasonably attributable to: water, gas, electricity and other utilities; gardening and landscaping (including planting and replacing flowers and shrubs); cleaning; fire protection (including installation and maintenance of an ADT or similar type system); fees for required licenses; all Taxes levied, assessed or imposed or which may become a lien on the Common Facilities or which may arise out of the use thereof and not otherwise collected elsewhere under the terms of this Lease; line painting; the repair and maintenance of the roof and finished ceiling (including lighting) of all Shopping Center canopies; operating of loudspeakers and other equipment supplying music; sanitary control; security services (if any); sewer service charges; removal of ice, snow, trash, rubbish, debris, garbage and other refuse (including ice and snow removal immediately in front of Tenant's storefront); depreciation on machinery and equipment used in such maintenance; resurfacing and restriping of parking areas; repairing the roof of the Shopping Center; and on-site personnel to provide and supervise such services (including wages, unemployment and social security taxes and the cost of uniforms for such personnel); plus an amount equal to ten percent (10%) of the total of all of the foregoing as an agreed upon reimbursement covering the administrative costs to be incurred by Owner in connection with the operation of the Common Facilities. (B) The term "Operating Cost" shall also include any municipal improvements required by the local municipality to be made to the Common Facilities including but not limited to traffic signals, stop signs, and road repair. Tenant's Common Facility Contribution for any improvements or repairs required under this Section 7.02(B) shall be obtained by multiplying the cost of the municipal improvements or repairs made to the Common Facilities by Tenant's Percentage Share. (C) The term "Common Facilities" shall mean all areas, space, equipment and special services in or serving the Shopping Center, provided for the common or joint use and benefit of Owner, 10 the occupants of the Shopping Center, and their employees, agents, servants, customers and other invitees, including, without limitation: any open pedestrian malls; parking areas and parking lot improvements; access roads; driveways; retaining walls; exterior boundary walls and fences; water, sanitary and storm sewer (including any off-site sewer lines which Owner is required to maintain), gas, electric, telephone and other utility lines, systems, conduits and facilities to the perimeter walls of any building (even though intended for the use of only one or a limited number of occupants) and those within a building serving more than one premises, and any of the foregoing which serve the Common Facilities; on or off-site water detention and retention ponds, facilities and systems; on-site trash compactor; plantings; landscaped areas; truck service ways or tunnels; loading dock areas and facilities; the roof and finished ceiling (including lighting) of all Shopping Center canopies; courts; ramps; sidewalks; comfort and first aid stations; washrooms; parcel pick-up stations; any Shopping Center pylon sign; drinking fountains; vertical transportation equipment (including elevators and escalators); auditoriums; community centers; bus stations; and the facilities appurtenant to each and all of the foregoing. Section 7.03. Pavment. (A) Tenant's Common Facilities Contribution shall be paid in monthly installments on the first day of each calendar month during the term in advance, in an amount reasonably estimated by Owner. Owner's estimate of Tenant's Common Facilities Contribution for the calendar year in which this Lease commences is set forth in Section A-I of the Basic Lease Provisions. Within 90 days after the end of each calendar year during the term, Owner shall furnish Tenant with a statement summarizing the actual Operating Cost for such calendar year and setting forth the method by which Tenant's Common Facilities contribution was detennined as herein provided, and Owner and Tenant shall then adjust any overpayment or underpayment by Tenant of Tenant's Common Facilities Contribution for such calendar year with any resultant payment to be due within thirty (30) days. Owner's failure to provide such statement within the 90 days shall in no way excuse Tenant from its obligations to pay any underpayment or constitute a waiver of Owner's obligations to bill and collect such underpayment from Tenant in accordance with this Paragraph. Any claim by Tenant for revision of any statement submitted by Owner hereunder for any such calendar year which is not made within 90 days after receipt of such statement, shall be deemed waived and discharged. For the calendar year in which this Lease commences or tenninates, Tenant's Common Facilities Contribution shall be prorated. (B) Any municipal improvements or repairs as contemplated in Section 7 .02(B) shall be paid within thirty (30) days of Tenant's receipt from Owner of a payment statement. As such municipal improvements are outside the control of the Owner, the Owner agrees to give Tenant prompt written notice of any municipal improvements or repairs upon Owner's receipt of such notice from the municipality. Section 7.04. Control bv Owner. Notwithstanding anything set out in this Lease to the contrary, it is agreed that (i) all Common Facilities shall be subject to the exclusive control and management of Owner, and Owner may permit the owners or occupants of land located outside the Shopping Center and their invitees to use the Common Facilities, provided such use does not unreasonably interfere with Tenant's or its customer's use of the Leased Premises; (ii) Owner shall have the right to temporarily close all or any portion of the Common Facilities (including parking areas), provided, such closure does not unreasonably interfere with Tenant's or its customers' use of the Leased Premises; (iii) Owner shall be required to keep the parking areas lighted from dusk to dawn and not during any daylight hours, and (iv) Owner shall have the right to do and perform such other acts in and to the Common Facilities as Owner shall determine to be advisable with a view to the improvement of the convenience and use thereof by tenants of the Shopping Center and their customers, including the right to pennit, in Owner's sole discretion, promotions in and 1l decorations of the sidewalks and parking areas; PROVIDED, HOWEVER, Owner shall maintain the Common Facilities in the Shopping Center in reasonably good order and repair, and shall keep the parking area and other Common Facilities in the Shopping Center reasonably free of snow, ice and debris and adequately lighted, but these obligations shall not inure to the benefit of any third party nor confer upon any third party any rights or remedies in the event of Owner's failure to perform such obligations. ARTICLE vm AL TERA TIONS; SIGNS: SURRENDER AND TENANT LIENS Section 8.01. Alterations. Tenant shall not make or cause to be made any alterations, additions or improvements in or to the Leased Premises without submitting to Owner plans and specifications therefore and obtaining Owner's consent thereto, which consent shall not be unreasonably withheld or delayed. Section 8.02. Surrender; Title to Improvements; Removal and Restoration bv Tenant. (A) On the last day of the term or on the sooner termination thereof, Tenant shall (i) subject to the provisions of Articles XVI and XVII, peaceably surrender the Leased Premises broom clean and in good order, condition and repair except for reasonable wear and tear; (ii) at its expense remove from the Leased Premises the signs, moveable furniture and trade fixtures (including, without limitation, molly- bolts, screws and other items inserted into the walls of the Leased Premises) which were furnished and installed by Tenant at Tenant's sole expense ("Tenant's Propertv") and, if requested by Owner, remove, at Tenant's expense, the carpeting in the Leased Premises, and (iii) deliver to Owner a certificate of inspection from a reputable mechanical systems contractor that the heating, ventilating, air conditioning, electrical and plumbing systems are in good order, condition and repair. Any damage to the Leased Premises caused by Tenant in the removal of Tenant's Property shall be repaired by Tenant at Tenant's expense (including, without limitation, the patching and sanding of molly-bolt holes and other similar type holes in the walls of the Leased Premises). (B) Except for Tenant's property, the title to all alterations, additions, improvements, repairs, decorations, non-trade fixtures, equipment (including heating and air conditioning equipment) and appurtenances attached to or built into the Leased Premises which shall have been made, furnished or installed by or at the expense of either Owner or Tenant in or upon the Leased Premises shall become upon the installation thereof and remain a part of the Leased Premises without disturbance or charge, except that Owner may elect to require Tenant, at Tenant's expense, to remove any or all of such alterations, additions, improvements, non-trade fixtures, equipment, and/or appurtenances, and Tenant shall upon such removal restore the Leased Premises to good condition, subject to ordinary wear and tear. Section 8.03. Tenant's Liens. (A) Before Tenant permits any work, labor, services or materials to be performed for or furnished to the Leased Premises, Tenant shall require any party with whom Tenant contracts to perform said work to Tenant or anyone holding all or any part of the Leased Premises under Tenant to file a stipulation against liens pursuant to ~1402 of the Pennsylvania Mechanics' Lien Law of 1963 (49 P.S. ~1401, et seq.). (B) Tenant shall not suffer any mechanics' or materialmen's lien to be filed against the Leased Premises or the Shopping Center by reason of work, labor, services or materials performed or furnished to Tenant or anyone holding all or any part of the Leased Premises under Tenant. If any such 12 lien shall at any time be filed as aforesaid, Tenant may contest the same in good faith but notwithstanding such contest, Tenant shall, within 15 days after the filing thereof, cause such lien to be released of record by payment, bond, order of a court of competent jurisdiction, or otherwise. In the event that Tenant fails to take the actions that are necessary to cause such lien to be released, then the Owner shall have the right to take whatever actions are necessary to have said liens released. In such event, Tenant agrees to reimburse the Owner for all costs incurred by the Owner, including attorneys' fees. A failure by the Tenant to reimburse the Owner these costs shall be a default by Tenant pursuant to Article XVllI. (C) Tenant shall not create or suffer to be created a security interest or other lien against any improvements, additions or other construction made by Tenant in or to the Leased Premises or against any equipment or fixtures installed by Tenant therein (other than Tenant's Property). Section 8.04. Tenant's Signs. Tenant shall not install any sign, billboard, marquee, awning, placard, lettering, advertising matter or other thing of any kind, whether permanent or temporary, on the exterior of the Leased Premises, or in or on any glass window, window showcase, .or door of the Leased Premises until the same has been approved by the Owner in writing. Owner has the right to control the size, location, design and materials of the same for the purpose of establishing and maintaining the appearance of the Shopping Center. Owner shall not unreasonably withhold or delay its approval of Tenant's sign(s). ARTICLE IX - MAINTENANCE OF LEASED PREMISES: RULES AND REGULATIONS Section 9.01. Maintenance bv Tenant. Subject to the provisions of Articles XVI and xvn, Tenant shall, at its sole cost, keep and maintain the interior of the Leased Premises [together with exterior (i) feature lighting, (ii) windows, including sashes, (iii) heating, ventilating and air conditioning equipment and sewer and other lines serving the Leased Premises exclusively, (iv) doors, including frames, locks, hardware and track, (v) store front of the Leased Premises, and (vi) signs and other equipment referred to in Section 8.04], including without limitation, the partitions, ceiling, interior portions of exterior walls, floor covering therein, and the fixtures, equipment, machinery, appliances and utility lines therein and appurtenances thereof [such as, but not limited to, lighting fixtures and lenses and such fixtures, equipment, machinery controls, appliances and utility lines and appurtenances thereof, as are used for, in connection with or which are a part of the electrical, plumbing, heating, air conditioning, ventilating, sprinkler, or any other mechanical systems in or serving the Leased Premises], in confonnity with all rules and regulations of Owner's hazard insurer, neat and clean and in good order, condition, maintenance and repair. Tenant shall also at its cost procure and maintain in the Leased premises all safety appliances required by Owner's hazard insurer to be maintained therein. Tenant shall replace any and all plate, window and other glass (structural or otherwise) in, on or about the Leased Premises, which may be broken or destroyed, with glass of the same or similar quality. Before undertaking repairs to the Leased Premises (other than minor interior non-structural repairs), Tenant shall first obtain Owner's approval of the plans and specifications therefore, which approval is not to be unreasonably withheld. Owner shall authorize one (I) heating and air conditioning contractor who shall provide a complete service and maintenance contract to Tenant who shall be the named party on the contract for the changing of filters at least once per month, the monthly inspection of the HV AC equipment serving the Leased Premises, including a written report of the condition there of to be provided to Owner and Tenant, the periodic oiling of the equipment where required, the tightening of belts, the filling of pitch pans and the sealing of water leaks, among other things. The service and maintenance contract and its related costs shall be the sole cost and 13 expense of the Tenant. The existence of a service contract with an Owner approved vendor shall not relieve Tenant of its obligations to maintain and repair such equipment as above provided. Section 9.02. Maintenance bv Owner. Subject to the provisions of Articles XVI and xvn and to the obligations of Tenant under the provisions of Sections 9.01, the foundations, roof (excluding interior ceilings), and exterior portions of the exterior walls (excluding store front) of the Leased Premises shall be maintained by Owner at its expense in good order, condition, maintenance and repair. Owner shall not be deemed to have breached its obligation to make the repairs required of Owner as set forth in this Section, or to be liable for any damages resulting therefrom, unless Owner fails to make the same within a reasonable period (taking into consideration the type of repair involved) after receiving notice from Tenant of the need therefore. Section 9.03. Rules and Regulations. Tenant agrees to comply with and observe the rules and regulations set forth in Exhibit C. Owner reserves the right, at any time, once or more often, by notice to Tenant, to amend or supplement said rules and regulations in a reasonable and non-discriminatory manner. ARTICLE X - INSURANCE AND INDEMNITY Section 10.01. Liabilitv Insurance. Tenant shall keep in force with an insurance company authorized to do business in the State in which the Leased Premises are located and which has a Best's Insurance Guide Rating of A+:XV ("Oualified Carrier"), a policy of comprehensive public liability insurance, including property damage, with respect to the Leased Premises and the business operated by Tenant and any other occupant of the Leased Premises, in which the limits of coverage shall not be less than $3,000,000.00 (combined single limit bodily injury and property damage). Such policy shall also insure the performance by Tenant of the indemnity agreement set forth in Section 10.04. In addition to Tenant, the policy shall also name Owner and any other person, firm or corporation designated by Owner and in privity with it, as an additional insured. Tenant shall continually provide Owner with a certificate of such insurance (the first of which shall be provided prior to commencement of Tenant's Work), which shall provide that the insurer will give Owner at least 30 days' written notice prior to any cancellation of, lapse or material change in the insurance. The insurance required in this Section and in Section 10.02 may be covered under a so-called "blanket" policy covering other stores of Tenant and its affiliates. Section 10.02. Fire Insurance. Tenant shall keep in force with a Qualified Carrier fire insurance (with extended coverage and vandalism and malicious mischief coverage), water damage, sprinkler leakage and plate glass. insurance, on the standard forms, insuring all of Tenant's Property in the Leased Premises, and all betterments, additions, repairs, improvements and alterations made to the Leased Premises by Tenant, and all plate glass windows, plate glass doors and other plate glass in the Leased Premises, in an amount equal to 100% of the replacement cost thereof. The proceeds of such insurance shall be held in trust by Owner and Tenant for use in repairing and restoring the items covered thereby and the proceeds shall be made payable to Owner and Tenant and may only be disbursed jointly by Owner and Tenant. The foregoing policy of insurance shall be issued in favor of and in the names of Owner and Tenant, as their interests may appear, and Tenant shall furnish Owner and the holder of any mortgage on the Leased Premises with a certificate evidencing such coverage, which certificate shall provide that the insurance shall not be canceled, materially amended or allowed to lapse without thirty (30) days' prior written notice thereof being given by the insurance carrier to Owner. 14 Section lO.03. Insurance on Buildings and Improvements in the Shopping Center. (A) In each calendar year during the term, Tenant shall pay to Owner an amount (the "Tenant's Insurance Contribution") equal to a proportion of the "Insurance Cost" (as defined in paragraph (B) of this Section). Tenant's Insurance Contribution for each calendar year during the tenn shall be that portion of the Insurance Costs for such calendar year equal to the product obtained by multiplying the Insurance Cost for such calendar year by Tenant's Percentage Share (hereinafter defined in Section 23.04) as of the first day of such calendar year. (B) The tenn "Insurance Cost" shall mean the total cost of insuring the buildings and improvements in the Shopping Center (including Common Facilities), including public liability, (including "umbrella coverage"), workmen's compensation and hazard insurance (including rental value insurance, fire and extended coverage [with vandalism and malicious mischief endorsement]; boiler and machinery, and all-risk policies). (C) Tenant's Insurance Contribution shall be paid in monthly installments on the first day of each calendar month during the term in advance, in an amount reasonably estimated by Owner. Owner's estimate of Tenant's Insurance Contribution for the calendar year in which this Lease commences is set forth in Section A-I of the Basic Lease Provisions. Within 90 days after the end of each calendar year during the tenn, Owner shall furnish Tenant with a statement summarizing the actual Insurance Cost for such calendar year and setting forth the method by which Tenant's Insurance Contribution was determined as herein provided and Owner and Tenant shall then adjust any overpayment or underpayment by Tenant of Tenant's Insurance Contribution for such calendar year with any resultant payment to be due within thirty (30) days. Any claim by Tenant for revision of any statement submitted by Owner hereunder for any such calendar year, which claim is not made within 90 days after receipt of such statement, shall be deemed waived and discharged. For the calendar year in which this Lease commences or terminates, Tenant's Insurance Contribution shall be prorated, if applicable, on the basis of a 360-day year. (D) Tenant shall provide Owner on an annual basis with proof of all insurance policies which shall provide that the insurer will give the Owner at least 30 days' written notice prior to any cancellation of, lapse of or material change in the insurance. Section 10.04. Business Liabilitv Insurance. Tenant shall keep in force with a Qualified Carrier, a policy to cover business liability, including premises operations liability and business interruption liability, in which the limits of coverage shall not be less than $1,000,000.00, single limit. In addition to Tenant, the policy shall name Owner as an additional insured. Tenant shall continually provide Owner with a certificate of such insurance, which shall provide that the insurer will give the Owner at least 30 days' written notice prior to any cancellation of, lapse or material change in the insurance. Section 10.05. Indemnification. Tenant will, subject to the provisions of Section 10.06, indemnify, save harmless and defend Owner and its officers, agents and servants, from and against any and all claims, actions, liability and expense in connection with loss of life, bodily injury and/or damage to property arising from or out of any occurrence in, upon or at the Leased Premises, or the occupancy or use by Tenant, its agents, employees, servants, subtenants, licensees or concessionaires, of the Leased Premises or any part thereof, or outside the Leased Premises which is occasioned wholly or in part by any willful or negligent act or omission of Tenant, its agents, employees, servants, subtenants, licensees or concessionaires, unless the same be caused by the willful or negligent act or omission of Owner, its agents, employees or servants. 16 Section 10.06. Waiver of Subrogation: Limitation of Liabilitv. (A) Anything in this Lease to the contrary notwithstanding, it is agreed that each party (the "Releasing Party") hereby releases the other (the "Released Party") from any liability which the Released Party would, but for this Section 10.05, have had to the Releasing Party during the term of this Lease, resulting from the occurrence of any accident or occurrence or casualty (i) which is or would be covered by an "all-risk" policy (irrespective of whether such coverage is being carried by the Releasing Party), or (ii) covered by any other casualty or property damage insurance being carned by the Releasing Party at the time of such occurrence, which accident, occurrence or casualty may have resulted in whole or in part from any act or neglect of the Released Party, its officers, agents or employees; PROVIDED, HOWEVER, the release hereinabove set forth shall become inoperative and null and void if the Releasing Party wishes to place the appropriate insurance with an insurance company which (a) takes the position that the existence of such release vitiates or would adversely affect any policy so insuring the Releasing Party in a substantial manner and notice thereof is given to the Released Party, or (b) requires the payment of a higher premium by reason of the existence of such release, unless in the latter case the Released Party within 10 days after notice thereof from the Releasing Party pays such increase in premium. (B) Anything in this Lease to the contrary notwithstanding, it is agreed that neither Tenant nor Owner shall be liable to the other for any damage arising from the willful or negligent act or omission of any other tenant or occupant of the Shopping Center. Section 10.07. Notice bv Tenant. Tenant shall within 24 hours after the occurrence of any casualty damage to or accidents in the Leased Premises, gi ve Owner notice of such casualty damage or accident. ARTICLE XI - UTILITIES Section 11.01. Utilitv Charges. Tenant shall contract in its own name for and promptly pay all charges for electricity, gas, water, sewer, telephone and any other utility used or consumed in the Leased Premises to the concern furnishing the same. In the event that separate service arrangements cannot be provided for any of the above, then the Tenant agrees to pay their proportionate share of the utility charges which shall be collected as part of the Common Facilities Contribution set forth in Article VII herein. Section 11.02. Owner's Liabilitv for Interruption. Owner shall not be liable in any way to Tenant or to any other party occupying any part of the Leased Premises for any failure or defect in or of any utility service furnished to the Leased Premises or the Common Facilities, by reason of any requirement, act or omission of the public utility company serving the Shopping Center with electricity, water or other utility service, or because of necessary repairs or improvements, or by reason of any cause referred to in Section 23.02. 17 ARTICLE XII - ESTOPPEL CERTIFICATE; ATTORNMENT; PRIORITY OF LEASE; RIGHTS OF MORTGAGEE Section 12.01. Estoppel Certificate. Tenant agrees, within 10 days after written request by Owner, to execute, acknowledge and deliver to and in favor of any proposed mortgagee or purchaser of the Shopping Center, an estoppel certificate, in the form customarily used by such proposed mortgagee or purchaser, evidencing the status of performance under this Lease and the terms of this Lease. Tenant agrees, within 10 days after written request by Owner, to deliver to Owner a current financial statement of Tenant, duly certified by an officer thereof (if Tenant is a corporation) and an independent certified public accountant and such other financial information of Tenant as Owner shall reasonably request; provided, that the confidentiality of such information is maintained in accordance with Section 3.01. Section 12.02. Attornment. Tenant shall, in the event any proceedings are brought for the foreclosure of, or in the event of the exercise of the power of sale under, any mortgage made by Owner covering any part of the Shopping Center, or in the event of any sale of the Shopping Center, attorn to the purchaser upon any such foreclosure or sale and recognize such purchaser as Owner under this Lease. Upon the request of any interested party, Tenant shall execute, acknowledge and deliver an instrument, in form and substance satisfactory to such party, evidencing the attornment provided for in this Section if, and only if, such party acknowledges in such instrument, and agrees to be abide by, such party's obligations as "Owner" under this Lease, and agrees therein (i) to recognize and abide by Tenant's rights under this Lease and (ii) not to disturb Tenant's use or occupancy of the Leased Premises. Section 12.03. Prioritv of Lease. Upon written request of the holder of any first mortgage now or hereafter covering any part of the Shopping Center, Tenant will subordinate its rights under this Lease or make this Lease prior in right and priority to the lien thereof and to all advances made or hereafter to be made upon the security thereof, and Tenant shall, within ten (10) days after written demand therefore, execute, acknowledge and deliver an instrument, in the form customarily used by such encumbrance holder, effecting such priority; PROVIDED, HOWEVER, at the option of the holder of such mortgage, such holder shall be entitled to effect such priority by filing a unilateral declaration to that effect with the recorder of deed in the County and State in which the Leased Premises is located. Section 12.04. Rights of Owner's Mortgagee. Within 10 days after demand by the holder of any mortgage covering all or any part of the Shopping Center, Tenant shall execute, acknowledge and deliver an agreement in favor of and in the form customarily used by such encumbrance holder, by the terms of which Tenant will agree to give prompt notice to such encumbrance holder in the event of any casualty damage to the Leased Premises or in the event of any default on the part of Owner under this Lease, and will agree to allow such encumbrance holder a reasonable length of time (taking into consideration for the purpose of determining such permitted length of time any delays encountered by reason of any of the causes referred to in Section 23.02), after notice to cure or cause the curing of such default before exercising Tenant's rights of self-help under this Lease, if any, or terminating or declaring a default under this Lease. In addition, within 10 days after demand by the holder of any such mortgage or after demand by owner, Tenant shall deliver to such encumbrance holder a current financial statement of Tenant and such other financial information as such holder or Owner shall reasonably request; provided, that the confidentiality of such information is maintained in accordance with Section 3.01. 18 ARTICLE xm - ASSIGNMENT, SUBLETTlNG AND CORPORATE OWNERSHIP Section 13.01. Consent Required. (A) Tenant shall not voluntarily, involuntarily or by operation of law assign or encumber this Lease, in whole or in part, nor sublet all or any part of the Leased Premises without the prior consent of Owner in each instance. Notwithstanding any assignment or subletting, Tenant shall remain fully liable under this Lease and shall not be relieved from performing any of its obligations hereunder. As a condition to any assignment of this Lease by Tenant, which is permitted under this Lease, the assignee thereof shall be required to execute and deliver to Owner an agreement in recordable form, whereby such assignee assumes and agrees with Owner to discharge all obligations of Tenant under this Lease. (B) If Tenant shall request Owner's consent to an assignment of this Lease and Owner shall consent thereto, the assignee ("Assignee") shall pay directly to Owner, as additional rent hereunder, at such times as the Assignee shall have agreed to pay Tenant, an amount equal to any consideration the Assignee shall have agreed to pay Tenant on account of such assignment. If Assignee shall fail to pay Owner any such consideration when due, such failure shall constitute a default under this Lease. (C) If Tenant shall request Owner's consent to a subletting of the Leased Premises or any part thereof and Owner shall consent thereto, Tenant shall pay Owner, as additional rent, in addition to the Annual Minimum Rent and other charges payable hereunder, an amount equal to any consideration paid by the subtenant to Tenant in excess of (i) the Annual Minimum Rent and other charges payable hereunder if all of the Leased Premises are so sublet or (ii) if less than all of the Leased Premises are so sublet, the Annual Minimum Rent and other charges payable hereunder allocable to the portion of the Leased Premises so sublet based on the number of square feet of Gross Leasable Area in the Leased Premises so sublet divided by the total number of square feet of Gross Leasable Area in the Leased Premises prior to such subletting. The foregoing amount shall be determined monthly and paid by Tenant to Owner on the first day of each calendar month in advance during the term of such sublease. If Tenant shall fail to pay Owner any such consideration, such failure shall be a default under this Lease. Section 13.02. Corporate Ownership. If at any time during the term a cumulative total of more than 49% of the voting stock of Tenant (if Tenant shall be a corporation) shall be transferred, directly or indirectly, by sale, assignment, gift or in any other manner, any such transfer shall, unless made with Owner's prior consent (which shall not be unreasonably withheld or delayed), be deemed an unauthorized assignment of this Lease and a default by Tenant under this Lease. Section 13.03. Owner's Right to Assign. If Owner conveys or transfers its interest in this Shopping Center or in this lease (which sale or transfer may be effected without Tenant's consent), upon such conveyance or transfer, Owner (and in the case of any subsequent conveyances or transfers, the then grantor or transferor) shall be released of and from all liability with respect to the performance of any covenants and obligations on the part of Owner to be performed after the date of such conveyance or transfer; it being intended hereby that the covenants and obligations on the part of Owner to be performed under this Lease shall, subject to the provisions of Section 21.01, be binding on Owner, its successors and assigns, only during and in respect of their respective periods of ownership of an interest in the Shopping Center or in this Lease. 19 ARTICLE XIV REGULA nONS WASTE; HAZARDOUS WASTE; GOVERNMENTAL AND INSURANCE Section 14.01. Waste or Nuisance. Tenant shall not commit or suffer to be committed (i) any waste in or upon the Leased Premises or (ii) any nuisance or any other act or thing (whether a nuisance or otherwise) which may disturb tbe quiet enjoyment of any other tenant or occupant in the Shopping Center or its or their customers or other invitees. Section 14.02. Hazardous Waste. (A) Tenant hereby covenants, represents and warrants that it shall not generate, transport, handle, store or otherwise encounter in, on or about the Real Property, any hazardous waste or substance (for purposes of this Section herein called "hazardous waste ") as defined by the applicable federal, state or local environmental or occupational standards, including but not limited to material defined as such in, or for purposes of, the Comprehensive Environmental Response, Compensation and Liability Act of 1980 ("CERCLA"), as amended by the Superfund Hazardous Materials Transportation Act (49 U.S.c. ~ 1802 et seq.), the Resource Conservation and Recovery Act ("RCRA") (42 U.S.c. ~ 1802, et ~.), the Federal Water Pollution Control Act (33 U.S.C. ~1251, et ~.), the Safe Drinking Water Act (42 U.S.c. ~300(f), et .llij.), the Toxic Substance Control Act (15 D.S.C. ~2601, ~ .llij.), the Clean Air Act (42 U.S.C p401, et ~.), or any other federal, state or local statute, ordinance, code, rule, regulation, order or decree regulating, relating to or imposing liability or standards of conduct concerning any hazardous, toxic or dangerous waste, substance, element or material as now or at any time hereafter in effect or amended (for purposes of this Section herein collectively called the "Laws"). Tenant further covenants, represents and warrants that there will be no underground storage tanks in, on, under, within or about the Real Property. (B) Tenant shall not use, store or permit to be stored on the Leased Premises any asbestos in any form, urea formaldehyde foam insulation, transfonners or other equipment which contains dielectric fluid or other fluids containing levels of polychlorinated biphenyls in excess of fifty (50) parts per million. If Tenant shall utilize the Leased Premises for medical office purposes, Tenant shall dispose of all syringes, blood products, "sharps", medical instruments and all other types of medical waste in a safe, clean, sanitary manner and in accordance with all applicable laws and regulations. (C) Tenant covenants, represents and warrants that it will indemnify and hold Landlord harmless from and against any and all liability, actions, claims, losses, damages and expenses arising out of, or in any way relating to, a breach of the representations, warranties, covenants and agreements set forth in this Section, including: (a) claims of third parties (including governmental agencies) for damages, including personal injury or property damages, penalties, response costs, injunctive or other relief; (b) costs or removal and restoration, including fees of attorneys and experts, costs of reporting to any governmental agency the existence of hazardous substances, hazardous waste, pollutants and/or contaminants and costs of preparing or causing to be prepared any and all studies, tests, analyses or reports in connection with any environmental matter: (c) all expenses or obligations, including attorneys' fees, incurred at, before and after any trial or appeal therefrom whether or not taxable as costs, including attomeys' fees, witness fees, deposition costs and other expenses; (d) all other costs, expenses and liabilities arising from Tenant's violation of the laws or any other environmental regulation now in force or hereafter enacted; and (e) Tenant's disposal of medical waste as set forth in paragraph (A) above. The obligations of Tenant as contained in this Section shall survive the termination of the Lease. 20 Section 14.03. Governmental and Insurance Regulations. Tenant shall, at Tenant's sole cost, comply with all of the requirements of all governmental authorities (including without limitation those requiring replacements, additions, repairs and alterations, [structural or otherwise]), and with all directions, rules, regulations and recommendations of Owner's hazard insurer, now in force, or which may hereafter be in force, pertaining to (i) the Leased Premises, (ii) all of Tenant's Property in the Leased Premises and (iii) the use and occupancy of the Leased Premises. ARTICLE XV - MERCHANTS ASSOCIATION INTENTIONALLY OMITTED ARTICLE XVI - DESTRUCTION Section 16.01. Destruction of Leased Premises (A) If the Leased Premises are damaged or destroyed by fire or other casualty insurable under standard fire and extended coverage insurance so as to become partially or totally untenantable, the same, unless this Lease is terminated as provided in paragraph (B), shall be repaired and restored by Owner and Tenant with due diligence, and during such restoration period, the Annual Minimum Rent (but not the Annual Percentage Rent) and other charges payable hereunder shall equitably abate to the extent the Leased Premises are materially affected thereby. Owner's obligation under this paragraph (A) to repair and restore shall be limited to the repair and restoration of those parts of the Leased Premises which were originally constructed and or installed by Owner at its expense including but not limited to Owner's Work set forth in Exhibit B. All other repair and restoration shall be the responsibility and at the expense of the Tenant. (B) If the Leased Premises are damaged or destroyed to the extent the cost of restoration thereof would exceed 15% of the amount it would have cost to replace the Leased Premises in its entirety at the time such damage or destruction occurred, then either party may elect to terminate this Lease by giving notice to the other party of its election to do so within 30 days after such occurrence. If either party exercises its right to terminate this Lease, then this Lease shall cease, effective as of the date of such damage or destruction, and all rent and other charges payable by Tenant shall be adjusted as of that date. Section 16.02. Destruction of Shoooing Center. Notwithstanding anything to the contrary set forth in Section 16.01, in the event all or any portion of the Shopping Center shall be damaged or destroyed by fire or other cause (notwithstanding that the Leased Premises may be unaffected thereby), to the extent the cost of restoration thereof would exceed 25% of the amount it would have cost to replace the Shopping Center in its entirety at the time such damage or destruction occurred, then either party may terminate this Lease by giving 30 days' prior notice to the other party of it's election so to do, which notice shall be given, if at all, within 90 days following the date of such occurrence. In the event of the termination of this Lease as aforesaid, this Lease shall cease 30 days after such notice is given, and the rent and other charges hereunder shall be adjusted as of that date. ARTICLE XVII - EMINENT DOMAIN Section 17.01. Condemnation of Leased Premises. 21 In the event of any condemnation or conveyance in lieu thereof of the Leased Premises or the Shopping Center, or both, whether whole or partial, either party may terminate this Lease, and in any event, Tenant shall have no claim against Owner or the condemning authority for the value of the unexpired term, and Tenant shall not be entitled to any part of the compensation or award, whether paid as compensation for diminution in value to the leasehold or to the fee of the Leased Premises, and Owner shall receive the full amount thereof, Tenant hereby waiving any right to any part thereof and assigning to Owner its interest therein. ARTICLE XVIII - TENANT'S DEFAULT: AND SECURITY DEPOSIT Section 18.01. Default bv Tenant If the Annual Minimum Rent, Annual Percentage Rent, additional rent, or any other charge payable by Tenant under this Lease shall be unpaid on the date payment is required by the terms hereof and shall remain so for a period of 5 days after Owner gives Tenant notice of such default, or if Tenant fails to perform any of the other terms, conditions, covenants and obligations of this Lease to be observed and performed by Tenant for more than 21 days after Owner gives Tenant notice of such default (it being agreed that a default, other than the failure to pay money, which is of such a character that rectification thereof reasonably requires longer than said 21 day period. and completes the same with due diligence), or if Tenant shall vacate or abandon the Leased Premises (it being agreed that, subject to the provisions of Articles XVI and XVIl and to Section 23.02, Tenant's failure to operate its business in the Leased Premises for seven consecutive days or more shall conclusively be deemed an abandonment) or suffer this Lease to be taken under any writ of execution, attachment or other process of law, or if this Lease shall by operation of law devolve upon or pass to any other party other than a party, if any, to whom Tenant is authorized to assign this Lease by the provisions of Section 13.01, or if an "Act of Bankruptcy" (as defined in Section 18.02) shall occur, or if Owner shall have notified Tenant of Tenant's default three (3) or more times in any twelve calendar month period, then, in any of such events, Owner shall have, besides its other rights or remedies, the following immediate rights: (1) At its option, to terminate this Lease and the term hereby created without any right on the part of Tenant to waive the forfeiture by payment of any sum due or by other performance of any condition, term or covenant broken, whereupon Owner shall be entitled to recover, in addition to any and all sums and damages for violation of Tenant's obligations hereunder in existence at the time of such termination, damages for Tenant's default in an amount equal to the amount of the rent reserved for the balance of the term of this Lease, as well as all other charges, payments, costs and expenses herein agreed to be paid by Tenant, all discounted at the rate of six percent (6%) per annum to their then present worth, less the fair rental value of the Premises for the remainder of said term, also discounted at the rate of six percent (6%) per annum to its then present worth, all of which amount shall be immediately due and payable from Tenant to Owner. (2) At its option, by notice to Tenant, to re-enter and take possession of the Leased Premises without tenninating this Lease. No re-entry or taking possession of the Leased Premises by Owner pursuant to this clause (2) shall be construed as an election on its part to tenninate this Lease unless a notice of such intention is given to Tenant (all other demands and notices of forfeiture or other similar notices being hereby expressly waived by Tenant). (3) At its option, to require that upon (i) any termination of this Lease, whether by lapse of time or by the exercise of any option by Owner to tenninate the same or in any other manner whatsoever, or (ii) any tennination of Tenant's right to possession without tennination of this Lease, Tenant shall immediately surrender possession of the Leased Premises to Owner and immediately vacate the same, and remove all effects therefrom, except such as may not be removed under other provisions of this Lease. 22 (4) At its option, to make such alterations and repairs as Owner shall determine may be reasonably necessary to relet the Leased Premises, and to relet the same or any part thereof for such term or terms (which may be for a term extending beyond the term of this Lease) and upon such tenns and conditions as Owner in its sole discretion may deem advisable. Upon each reletting, all rentals received by owner from such reletting shall be applied as follows: first, to the payment of any indebtedness other than rent or other charges due under this Lease from Tenant to Owner; second to the payment of any reasonable costs and expenses of such reletting, including brokerage fees and attorneys' fees and costs of such alterations and repairs, each of which fees and costs shall be reasonable in amount; and third, to the payment of rent and other charges due and unpaid hereunder. In no event shall Tenant be entitled to receive any surplus of any sums received by Owner on a reletting in excess of the rental and other charges payable hereunder. If such rentals and other charges received from such reletting during any month are less than those to be paid during that month by Tenant hereunder, Tenant shall pay any such deficiency to Owner (notwithstanding the fact that Owner may have received rental in excess of the rental and other charges payable hereunder in previous or subsequent months), such deficiency to be calculated and payable monthly. Notwithstanding any reletting without termination, Owner may at any time thereafter elect to terminate this Lease for such previous breach in the manner provided in this Section. (5) If Tenant shall default in the payment of the rent herein reserved or in the payment of any other snms due hereunder by Teuant, Tenant hereby authorizes and empowers auy Prothouotary or attorney of any court of record to appear for Tenant in any and all actions which may be brought for said rent and/or said other sums; and/or to sign for Tenant an agreement for entering in any competent court an amicable action or actions for the recovery of said rental and/or other SUIOS; and in said suits or in said amicable action or actions to confess judgment against Tenant for all or any part of said rental and/or said other sums, including but not limited to the amounts due from Tenant to Owner under subparagraphs (1), (2), (3) and/or (4) of the Paragraph; and for interest and costs, together with any attorneys' commission for collection of ten percent (10 %). Such authority shall not be exhausted by one exercise thereof, but judgment may be confessed as aforesaid from time to time as often as any of said rental and/or other sums shall fall due or be in arrears, and such powers may be exercised as well after the expiration of the initial term of this Lease and/or during any extended or renewal term of his Lease and/or after the expiration of any extended or renewal term of this Lease. (Tenant) (6) When this Lease and the term of any extension or renewal thereof shall have heen terminated on account of any default by Tenant hereunder, and also when the term hereby created or any extension or renewal thereof shall have expired, it shall be lawful for any attorney of any court of record to appear as attorney for Tenant as well as for all persons claiming by, through or under Tenant, and to sign an agreement for entering in any competent court an amicable action in ejectment against Tenant and all persons claiming by, through or under Tenant and therein confess jndgment for the recovery by Owner of possession of the Premises, for which this Lease shall be his sufficient warrant; thereupou, if Owner so desires, an appropriate writ of possession may issue forthwith, without any prior writ or proceeding whatsoever, and provided that if for any reason after such action shall have been commenced it shall be determined that possession of the Premises remain in or be restored to Tenant, Owner shall have the right for the same default and upon any subsequent default or defaults, or upon the termination of this Lease or Tenant's right of possession as hereinbefore set forth, to bring one or more further amicable action or actions as hereinbefore set forth to recover possession of the Premises and C!feSS judgment for the recovery of possession of the Premises as hereinbefore provided. ~ \ , \ I (Tenant) 23 (7) In any amicable action of ejectment and/or for rent and/or other sums brought hereon, Owner shall first cause to be rued in such action an affidavit made by Owner or someone acting for Owner, setting forth the facts necessary to authorize the entry of judgment, of which facts such affidavit shall be prima facie evidence, and if a true copy of this Lease (and of the truth of the copy such affidavit shall be sufficient evidence) shall be filed in such suit, action or actions, it shall not be necessary to file the original as a ~. arr nt of attorney, any rule or Court, custom or practice to the contrary notwithstanding. , (Tenant) (8) At its option, to collect from Tenant any other loss or damage which Owner may sustain by reason of any breach and any diminished value of the Leased Premises resulting from said breach. 'ves any notice to quit required by any law now in force of hereafter enacted. (Tenant) Nothing in this Section shall be deemed to limit Owner's rights and remedies in the event of a default by Tenant, and the Owner's rights and remedies set forth in this Lease shall be in addition to those available to Owner at law or in equity. Section 18.02. Bankruptcv. (A) If at any time prior to or after the commencement of the term of this Lease there shall be filed by Tenant or Guarantor, in any court pursuant to any statute either of the United States or of any State, a petition in bankruptcy (including, without limitation, a petition for liquidation, reorganization or for adjustment of debts of an individual with regular income), or if any case, proceeding or other action shall be commenced seeking to have an order for relief entered against Tenant or Guarantor as a debtor in bankruptcy proceedings or to adjudicate Tenant or Guarantor a bankrupt or insolvent, or seeking reorganization, arrangement, adjustment, liquidation, dissolution or composition of it or its debts under any law relating to bankruptcy, insolvency, reorganization or relief of debtors, or seeking appointment of a receiver, trustee, custodian or other similar official for it or for all or any substantial part of its property, and such case, proceeding or other action results in the entry of an order for relief or is not dismissed within 30 days of the filing thereof, or if Tenant or Guarantor becomes insolvent or is generally not paying or admits in writing its inability to pay its debts as they mature, or makes an assignment for the benefit of creditors or petitions for or enters into an arrangement with its creditors or a custodian is appointed or takes possession of Tenant's or Guarantor's property (whether or not a judicial proceeding is instituted in connection with such arrangement or in connection with the appointment of such custodian), or if Tenant or Guarantor shall take any action to authorize or in contemplation of any of the events set forth above (each of the foregoing events to be hereinafter referred to as an "Act of Bankruptcv"), then, in addition to Owner's other rights and remedies under this Lease and applicable law, this Lease shall, at Owner's option (and if permitted by law), be terminated, in which event neither Tenant nor Guarantor, nor any person claiming through or under Tenant or Guarantor or by virtue of any statute or of an order of any court, shall be entitled to possession of the Leased Premises, and Owner, in addition to the other rights and remedies given by this Lease, or by virtue of any statute or rule of law, may retain as liquidated damages any rent, Security Deposit or moneys received by Owner from Tenant or others in behalf of Tenant. All rent, additional rent and other charges payable by Tenant under this Lease shall constitute rent for the purpose of applying the provisions of Section 502(b )(7) of the Federal Bankruptcy Code. (B) In the event an act of bankruptcy shall occur and this Lease is not terminated pursuant to the provisions of paragraph (A), the parties agree that: 24 (i) If there shall be a default in the payment of Annual Minimum Rent or any additional rent, or a default in the observance or performance of any other provision of this Lease binding on Tenant, Owner shall be entitled to immediately discontinue fumishing any utilities and other services it has been providing to the Leased Premises, until such time as such defaults have been fully cured, it being agreed that the foregoing action by Owner shall in no way cause or result in any abatement of Annual Minimum Rent or any other charge payable by Tenant during the continuance of the term of this Lease. (ii) If the Lease is assumed by a trustee in bankruptcy, and assigned by the trustee to a third party, then such party shall (a) execute and deliver to Owner an agreement in recordable form whereby such party confirms that it has assumed and agrees with Owner to discharge all obligations (including, without limitation, the provisions of Article VI respecting the Permitted Use of the Leased Premises and the manner of operation thereof) binding on Tenant under this Lease, (b) represent and warrant in writing to Owner that such party has a net worth and operating experience at least comparable to that possessed by Tenant named herein and Guarantor as of the execution of this Lease, (c) deposit with Owner a Security Deposit and advance rent equal to that initially deposited by Tenant named herein, and (d) grant Owner, to secure the performance of such party's obligations under this Lease, a security interest in such party's merchandise, inventory, personal property, fixtures, furnishings, and all accounts receivable (and in the proceeds of all of the foregoing) with respect to its operations in the Leased Premises, and in connection therewith, such party shall execute such security agreements, financing statements and other documents (the forms of which are to be designated by Owner) as are necessary to perfect such lien. (iii) Lease shall be deemed a lease of "Nonresidential Real Property" within a "Shopping Center" for the purpose of Section 365 of the Federal Bankruptcy Code. (C) Any person or entity to which this Lease is assigned pursuant to the provisions of the Bankruptcy Code, 11 U.S.C. Section 101, et ~ (the "Bankruptcy Code") shall be deemed without further act or deed to have assumed all of the obligations arising under this Lease on and after the date of such assignment. If this Lease is assigned to any person or entity pursuant to the provisions of the Bankruptcy Code, any and all monies or other considerations payable or otherwise to be delivered in connection with such assignment shall be paid or delivered to Owner, shall be and remain the exclusive property of Owner and shall not constitute property of Tenant or of the estate of Tenant within the meaning of the Bankruptcy Code. Any and all monies or other considerations constituting Owner's property under the preceding sentence not paid or deli vered to Owner shall be held in trust for the benefit of Owner and be promptly paid or delivered to Owner. 25 Section 18.03. Owner's Ril!ht to Cure Defaults. If Tenant fails to perform any agreement or obligation on its part to be performed under this Lease, Owner shall have the right (i) if no emergency exists, to perform the same after giving 15 days' notice to Tenant; and (ii) in any emergency situation, to perform the same immediately without notice or delay. For the purpose of rectifying Tenant's defaults as aforesaid, Owner shall have the right to enter the Leased Premises. Tenant shall, on demand, reimburse Owner for the costs and expenses incurred by Owner in rectifying Tenant's defaults as aforesaid, including reasonable attorneys' fees. Owner shall not be liable or in any way responsible for any loss, inconvenience, annoyance, or damage resulting to Tenant or anyone holding under Tenant for any action taken by Owner pursuant to this Section. Section 18.04. Security Deoosit. (A) Tenant, contemporaneously with the execution of this Lease, has deposited with Owner the sum designated as the "Security Deposit" in A-I of the Basic Lease Provisions, receipt of which is hereby acknowledged. The Security Deposit shall be held by Owner, without liability for interest, as security for the faithful performance by Tenant of all of the terms, covenants and conditions of this Lease by Tenant to be performed. Owner shall not be required to hold the Security Deposit as a separate fund, but may commingle it with other funds. If after the execution of this Lease Agreement and Owner's receipt of the Security Deposit, Tenant would fail to commence under the terms of this Lease Agreement, Tenant shall forfeit the Security Deposit, which shall be retained by Owner, this Lease Agreement shall terminate and all of the Owner and Tenants obligations hereunder shall become null and void. B. If at any time during the term any Annual Minimum Rent, Annual Percentage Rent, or additional rent payable by Tenant shall be overdue, or if Tenant fails to perfonn any of the other terms, covenants or conditions to be performed by Tenant, then Owner, at its option, may appropriate and apply all or any portion of the Security Deposit to the payment of any such overdue Annual Minimum Rent, Annual Percentage Rent, or additional rent and to the compensation of Owner for loss or damage sustained by Owner due to a breach by Tenant as aforesaid, without prejudice to Owner's other remedies. Should all or any part of the Security deposit be appropriated and applied by Owner as provided above, then Tenant shall, upon demand of Owner, forthwith remit to Owner a sufficient amount in cash to restore the same to the original sum deposited. Should Tenant comply with all of the tenns, covenants and conditions of this Lease binding on Tenant, the Security Deposit shall be returned in full to Tenant within 60 days after the later of the following dates; (i) the date of expiration of the term or (ii) the date Tenant shall deliver to Owner such inspection reports as Owner shall require setting forth that the Leased Premises were surrendered in accordance with Section 11.02 of this Lease ARTICLE XIX - ACCESS BY OWNER Section 19.01. Ril!ht of Entrv. Owner and its designees shall have the right to enter the Leased Premises during reasonable business hours (except in the event of emergency, when Owner may enter at any time) for all lawful purposes (including the right to show the Leased Premises to prospective purchasers of the Shopping Center, and, during the last six months of the term, the right to show the Leased Premises to prospective tenants) and to whateyer extent necessary or appropriate to enable Owner to exercise all of its rights under this Lease (including without limitation the right to perform certain provisions of th.is Lease on Tenant's behalf as set forth in Section 18.02) and to carry out all of Owner's obligations hereunder. Owner and Owner's representatives sh.all also h.ave the right to enter the Leased Premises and to erect scaffolding and barricades around the same (but not so as to preclude entry thereto) in order to make such. repairs, alterations, improyements and additions to the building of which the Leased Premises form a part and the foundarions and walls of the Leased Premises as Owner may deem necessary or desirable (and 26 Owner shall be allowed to take all equipment and material upon the Leased Premises which may be required therefore), but Owner shall use reasonable efforts consistent with accepted construction practice to minimize interference to Tenant's business caused by reason thereof. The exercise by Owner of its rights of entry and other rights granted under this paragraph shall not constitute an eviction of Tenant and the rent payable under this Lese shall not abate by reason thereof. Owner shall provide reasonable notice to Tenant prior to such entry. ARTICLE XX - ARBITRATION; RIGHT TO APPEAL Section 20.01 - Arbitration. Any disagreement between Owner and Tenant with respect to the interpretation or application of this Lease, or the obligation of the parties hereunder, shall be determined by arbitration unless the parties otherwise mutually agree in writing. Owner and Tenant shall agree upon one arbitrator, otherwise there shall be three (3), one named in writing by the Owner and one named in writing by tbe Tenant within ten (10) days after notice of arbitration is served by either upon the other, and a third arbitrator selected by those two arbitrators within ten (10) days thereafter. No one shall serve as an arbitrator who is in any way financially interested in this Lease or in the affairs of either party hereto. This agreement to arbitrate shall be specifically enforceable under the prevailing arbitration laws. The arbitrator or arbitrators shall have the power to award to either party to the dispute such sums, costs, expenses, and attorney's fees as the arbitrator or arbitrators may deem proper. The award rendered by the arbitrator or arbitrators shall be appealable to a court of competent jurisdiction within thirty (30) days of notice of the arbitrators' award. Such appeal shall be prosecuted without delay and as rapidly as possible. Section 20.02 - Waiver of Trial By Jurv. THE PARTIES HEREBY WAIVE TRIAL BY JURY IN ANY ACTION, PROCEEDING, COUNTERCLAIM OR APPEAL BROUGHT BY EITHER PARTY AGAINST THE OTHER ON ANY MATTER. Tenant agrees that any action brought in connection with this Lease may be maintained in any court of competent jurisdiction in the Commonwealth of Pennsylvania. Tenant hereby appoints Owner as agent for the purpose of accepting service of any process, subject only to the condition that Owner promptly send Notice of such process to Tenant at the address of Tenant set forth in A-I of the Basic Lease Provisions. In case suit shall be brought because of the breach of any agreement or obligation contained in this Lease on the part of Tenant or Owner to be kept or performed, and a breach shall be established, the prevailing party shall (to the extent permitted by law) be entitled to recover all expenses incurred therefore, including reasonable attorneys' fees. Owner's rights and remedies shall be cumulative and may be exercised and enforced concurrently. Any right or remedy conferred upon Owner under this Lease shall not be deemed to be exclusive of any other right or remedy Owner may have. All rights and liabilities herein given to or imposed upon the respective parties hereto shall, except as may be otherwise herein provided, extend to and bind the respective heirs, executors, administrators, successors and assigns of the said parties; and if there shall be more than one Tenant, they shall all be bound jointly and severally by the terms, covenants and agreements herein contained. This paragraph shall only become effective in the event that there is an appeal of an arbitrators award. ARTICLE XXI - OWNER'S LIABILITY Section 21.01. Limitations on Liability (A) Anything contained in this Lease to the contrary notwithstanding, Tenant agrees that Tenant shall look solely to the fee simple interests or leasehold estate of the Owner in the Shopping Center for the collection of any judgment (or other judicial process) requiring the payment of money by Owner in the event of any default or breach by Owner with respect to any of the terms and provisions of 27 this Lease to be observed or performed by Owner, subject, however, to the prior rights of the holder of any mortgage covering the Shopping Center, and NO OTHER ASSETS OF OWNER SHALL BE SUBJECT TO LEVY. EXECUTION OR OTHER JUDICIAL PROCESS FOR THE SATISFACTION OF TENANT'S CLAIM. AND OWNER SHALL NOT BE LIABLE FOR ANY SUCH DEFAULT OR BREACH WPT TO THE EXTENT OF OWNER'S INTEREST IN THE SHOPPING CENTER. (Tenant) (B) Except where Owner has breached or failed to abide by its obligations set forth in this Lease, Owner shall not be liable for any damage occasioned by failure of the Premises to be in repair, nor for any damage done or occasioned by or from plumbing, gas, water, sprinkler, steam or other pipes or sewerage, or the bursting, leaking or running of any tank, washstand, water closet or waste pipe in, above, upon or about the Premises or improvements constituting a part thereof, nor for any damage occasioned by water, snow or ice being upon or coming through the roof, skylights, trap door or otherwise. (C) In the event that in this Lease it is provided that the exercise of any right by Tenant or the performance of any obligations of Tenant shall be subject to the consent or approval or Owner and that the consent or approval of Owner shall not be unreasonably withheld or delayed. then in any case in which Owner shall withhold or delay its consent, Tenant hereby waives any and all rights it may have to recover (and Tenant shall not seek in any proceeding) any damages from Owner on account thereof; it being agreed that Tenant's sole remedy for Owner's withholding or delaying of consent shall be injunctive relief (without any right to damages). (D) Notwithstanding anything to the contrary contained in this Lease, if Owner shall elect to provide security service then (i) any security service that may be provided by Owner is intended solely for the protection and benefit of the Common Facilities and not for the protection or benefit of the Leased Premises or any other premises; and (ij) Owner shall not be liable in any manner whatsoever to Tenant or to any third party by reason of Owner's act or failure to act in providing or maintaining security in the Shopping Center. Section 21.02. Owner's Obli!!ations With Resl'ect to Future Buildin!! Areas. Notwithstanding anything set out in this Lease to the contrary, it is understood and agreed that (i) Tenant will not cancel this Lease nor be entitled to claim any actual or constructive eviction because of a default of Owner either by act or omission under this Lease when such act or omission relates to any Future Building Area shown on Exhibit A, and Tenant will not abate rentals or otherwise credit or offset damages against rental under this Lease because of any act or omission of Owner under this Lease which relates to any Future Building Area shown on Exhibit A, but shall not be construed as a waiver of any rights Tenant may have in person against or as a waiver of any remedies by way of injunctive relief which Tenant may have against Owner (other than one who becomes such after the foreclosure of any first mortgage covering any part of the real property which is contained within the Shopping Center, or after the execution of a deed in lieu thereof); and (ii) the restrictions set out in this Lease, if any, to the extent the same relate to any Future Building Area shown on Exhibit A, and all obligations of Owner with respect to such restrictions shall absolutely and automatically terminate for all purposes from and after the date the holder of any first mortgage affecting the real property which is contained within the Shopping Center, forecloses its mortgage or obtains a deed in lieu thereof. For purposes of this Section, an "Outlot" shall be considered the same as a Future Building Area. ARTICLE XXII - HOLDING OVER Section 22.01. Holdin!! Over. 28 In the event Tenant remains in possession of the Leased Premises after the expiration of the tenancy created hereunder, and without the execution of a new lease, Tenant, at the option of Owner, shall be deemed to be occupying the Leased Premises as a tenant from month-to-month, at a rate equal to 125% of the Annual Minimum Rent for the last Lease Year of the term, subject to all the other conditions, provisions and obligations of this Lease insofar as the same are applicable to a month-to- month tenancy. Section 22.02. Time is of the Essence. Time is of the essence of each provision of this Lease. Tenant hereby waives notice to quit the Premises at the expiration of the term of this Lease or any earlier termination, and this Lease shall constitute sufficient notice to quit without any obligation upon Owner to provide Tenant with any additional notice thereof. ARTICLE XXIII - WAIVER; NOTICE; DEFINITIONS; MISCELLANEOUS. Section 23.01. Waiver. No delay or omission in the exercise of any right or remedy of Owner on any default by Tenant shall impair such a right or remedy or be construed as a waiver. No covenant, term or condition of this Lease shall be deemed to have been waived unless such waiver be in writing signed by the party charged therewith. )(" Section 23.02. Force Maieure. \ In the event either party hereto shall be delayed or hindered in or prevented from the performance of any act required under this Lease by reason of strikes, lockouts, labor troubles, inability to procure materials, failure of power, restrictive governmental law or regulations, riots, insurrection, war or other reason of a like nature not the fault of the party delayed in performing work or doing acts required under ttie terms of this Lease, then performance of any such act shall be extended for a period equivalent to the period of such delay. The provisions of this Section shall not (a) operate to excuse Tenant from prompt payment of Annual Minimum Rent or any other payment required by the terms of this Lease, and (b) be applicable to delays resulting from the inability of a party to obtain financing or to proceed with its obligations under this Lease because of a lack of funds. Section 23.03. Notices and Pavments. (A) Whenever any notice, consent, approval or authorization ("Notice") is required or permitted under this Lease, the same shall be in writing and all oral notices, consents, approvals and authorizations shall be of no effect. All Notices by Tenant to Owner shall be sent to Owner by registered or certified mail (return receipt requested), postage prepaid, or by a nationally recognized overnight courier service (Federal Express, AirBorne, UPS Next Day Air or similar) at the "Address of Owner" designated in Section A-I of the Basic Lease Provisions, or to such other address(es) as Owner may later designate in writing (including, without limitation, any notice which Tenant shall be required to give Owner's mortgagee pursuant to Section 12.04). Until Owner is notified otherwise by Tenant, all Notices by Owner to Tenant shall be deemed to have been duly given if sent by registered or certified mail (return receipt requested), postage prepaid, or by a nationally recognized overnight courier service (Federal Express, AirBorne, UPS Next Day Air or similar) to Tenant at the "Address of Tenant" designated in Section A-I of the Basic Lease Provisions. In the case of notices sent by overnight courier, delivery shall be deemed effective one day after such notice is sent. Until otherwise notified in writing by Owner, Tenant shall pay all rent and other sums required to be paid hy it under this Lease by check 29 payable to the order of Owner and shall deliver the same, together with all sales reports required under Article ill and all certificates of insurance required to be furnished by Tenant pursuant to Article X, to the address of Owner designated in Section A-I of the Basic Lease Provisions. (B) All Notices shall be effective upon being deposited in the United States mail in the manner prescribed in paragraph (A) of this Section. However, the time period in which a response to any such Notice must be given shall commence to run from the date of receipt by the addressee thereof as shown on the return receipt of the Notice. Rejection or other refusal to accept or the inability to deliver because of changed address of which no Notice was given, shall be deemed to be receipt of the Notice as of the date of such rejection, refusal or inability to deliver. Section 23.04. Definitions. (A) The term "calendar year" shall mean a period of 12 consecutive full calendar months, commencing January 1 and ending December 31. (B) The term "Guarantor" as used in this Lease shall be deemed to mean any person (and their spouse, if any), partnership, corporation or other entity which has undertaken, by separate instrument, endorsement on this Lease or in any other manner, to warrant, agree or guarantee that the obligations of Tenant, or any portion thereof, shall be performed by Tenant. (C) The term "Gross Leasable Area" shall mean the aggregate floor area within the exterior faces of the exterior walls (except party walls as to which the center thereof, instead of the exterior faces thereof, shall be used). Changes in Gross Leasable Area occurring during any calendar month shall be effective on the first day of the next succeeding calendar month and, unless otherwise herein specified to the contrary, the total number of square feet of Gross Leasable Area in effect for any calendar year shall be the average of the number of square feet of Gross Leasable Area on the first day of each calendar month in such calendar year. (D) The term "includine:" as used in this Lease shall mean "including without limitation". (E) The term "Interest Rate" shall mean a rate of interest, per annum, equal to the lessor of (i) the highest lawful rate of interest that may be charged Tenant under the laws of the State in which the Leased Premises is located or (ii) two percent (2%) in excess of the "Effective Rate" of Chase Manhattan Bank. N.A., New York, New York (or its successor) (the "Bank") initially determined as of the date any rent, additional rent or other payment under this Lease is due and for which interest at the mterest Rate is charged and thereafter adjusted daily; PROVIDED, HOWEVER, if the Bank should cease to exist as a viable commercial bank. then the "Effective Rate" of any commercial bank selected by Owner and having capital and surplus of at least $50,000,000.00 shall be used to determine the Interest Rate. The tenn "Effective Rate" shall mean the rate of interest announced by the Bank or other commercial bank selected by Owner as aforesaid, as the case may be, as its prime lending rate. The Effective Rate shall be as announced by the Bank notwithstanding that the Bank may actually charge other rates, and a written statement from the Bank or any national investment brokerage firm or national bank as to what the Effective Rate was on any given day shall be deemed conclusive. (F) The term "Lease Year" shall mean a period of twelve consecutive full calendar months. The first Lease Year shall begin on the date of commencement of the term if such date of commencement shall occur on the first day of a calendar month; if not, then on the first day of the calendar month next following such date of commencement. Each succeeding Lease Year shall commence upon the anniversary date of the first Lease Year. 30 (G) The term "Mortgage" shall include a deed of trust. The term "mortgagee" shaH mean the holder of a mortgage and beneficiary under a deed of trust. (H) The term "Tenant's Percentage Share" shall mean the Tenant's proportionate share based on the calculated percentage of Tenant's Gross Leasable Area as herein defined in relation to the total gross leasable area of the shopping center. (I) The word "Tenant" shaH mean each and every person or party mentioned as Tenant herein, and if there shall be more than one Tenant, any Notice required or pennitted by the tenns of this Lease may be given by or to anyone thereof and shall have the same force and effect as if given by or to all thereof. (1) The word "term" shaH mean the period from the date of the commencement of this Lease to the expiration or sooner tennination thereof, including any extension thereof, all as herein provided. Section 23.05. Miscellaneous. (A) Recording of Lease. Neither party shall record this Lease in its entirety. However, upon the request of either party, the other party shall join in the execution of a memorandum or so-called "short form" of this Lease for the purpose of recordation. (B) Obligations Surviving Termination. All obligations of Tenant and Owner which by their nature involve performance, in any particular, after the end of the term, or which cannot be ascertained to have been fully performed until after the end of the term, shall survive the expiration or sooner termination of the term. (C) Governing Law and Jurisdiction. The laws of the Commonwealth of Pennsylvania shall govern the validity, performance and enforcement of this Lease. (D) No Accord And Satisfaction. No payment by Tenant or receipt by Owner of a lesser amount than the monthly rent and other charges, nor shall any endorsement or statement on any check or on any letter accompanying any check be deemed an accord and satisfaction. (E) Alterations And Amendments. Except as herein otherwise expressly provided, no subsequent alteration, amendment, change or addition to this Lease, nor any surrender of the term, shall be binding upon Owner or Tenant unless reduced to writing and signed by them. (F) No Partnership. Owner does not in any way or for any purpose become a partner of Tenant in the conduct of its business or otherwise, nor a joint venturer or a member of a joint enterprise with Tenant. (G) Withholding Consent. Wherever in this Lease a party's consent or approval is required, such approval may be withheld arbitrarily unless otherwise herein specifically provided to the contrary. (H) Cal'tions; Article Numbers. The captions, section numbers, article numbers and index appearing in this Lease in no way define, limit, construe or describe the scope or intent of such sections or anicles of this Lease. The language in all parts of this Lease shall in all cases be construed as a whole according to its fair meaning, and not strictly for not against either Owner or Tenant, and should a court be caHed upon to interpret any provision hereof, no weight shall be given to, nor shall any construction or interpretation be influenced by, any presumption of preparation of a lease by Owner or by Tenant. 31 (D Guaranty. At the time of executing this Lease, Tenant shall provided to Owner a signed Guaranty of Lease including the signature of the spouse, if any, in fonn and substance as set forth in Exhibit D hereto. Each Guarantor shall provide Owner with an annual financial statement upon request. (J) Severabilitv. In the event that one or more provisions of this Lease shall be found to be unenforceable at law or in equity, the remainder of the Lease shall not be affected and shall remain in full force and effect. (K) Successors and Assilms. This Lease shall be binding upon and shall inure to the benefit of the parties hereto and their respective legal representative, heirs, successors and assigns. (L) Tenant's Corporate Authority. If Tenant is a corporation, it shall, concurrently with the signing of this Lease, furnish to Owner certified copies of the resolutions of its Board of Directors (or of the executive committee of its Board of Directors) authorizing Tenant to enter into this Lease; and it shall furnish to Owner proof that Tenant is a duly organized corporation under the laws of the state of its incorporation, is qualified to do business in the Pennsylvania, is in good standing under the laws of Pennsylvania, and has the power and authority to enter into this Lease, and that all corporate action requisites to authorize Tenant to enter into this lease has been duly taken. (M) Brokers. Except as set forth below, Tenant represents and warrants that it has not dealt with any broker in respect to this Lease, and agrees to defend, indemnify and save Owner harmless against all demands, claims and liabilities arising out of any dealings between Tenant and any other broker in respect to this Lease: Rothman, Schubert & Reed Realtors TIDS LEASE CONSTITUTES THE ENTIRE AGREEMENT TIDS LEASE AND THE EXHIBITS AND RIDER, IF ANY, ATTACHED HERETO, IS THE COMPLETE AGREEMENT BETWEEN OWNER AND TENANT CONCERNING THE LEASED PREMISES AND THE SHOPPING CENTER. THERE ARE NO ORAL AGREEMENTS, UNDERSTANDINGS, PROMISES OR REPRESENTATIONS BETWEEN OWNER AND TENANT AFFECTING THIS LEASE. ALL PRIOR NEGOTIATIONS AND UNDERSTANDINGS, IF ANY, BETWEEN THE PARTIES HERETO WITH RESPECT TO THE LEASED PREMISES AND THE SHOPPING CENTER SHALL BE OF NO FORCE OR EFFECT AND SHALL NOT BE USED TO INTERPRET TIDS LEASE. IN WITNESS WHEREOF, the parties hereto have executed this Lease as of the date first-above written. WITNESS: OWNER: Rothman, Schubert & Reed, a Pennsylvania General ~ership _ ~ By: ~cfa A...o1 (SEAL) Samuel L. Reed, Attorney-in-Fact pursuant to Power of Attorney dated August 21, 1996, and recorded in Misc. Book 528, Page 480. -aP ~~DU<-- . \l~Li ;, . -~\t,--,\<,~ J I--' 'l'-- ATTEST: By: (SEAL) 32 EXHIBIT B OWNER'S WORK Executed with Lease dated f\ ,-N '6 . 2004, between William F. Rothman, Charles F. Schubert & Samuel L. Reed, Co-Partners, t/d/b/a Rothman, Schubert & Reed, a Pennsylvania General Partnership, as Owner and Massimo Napoli. Inc., as Tenant. Owner agrees, at its expense, to deliver the Leased Premises to Tenant with the following work set forth below. Owner has not agreed to perform any other work in the premises, and all other work necessary to complete the Leased Premises shall be done at Tenant's sole cost and expense. Owner shall provided Tenant with a "pure vanilla box" which shall include the following work/construction to the Leased Premises: I. Four (4) walls, y," dry-walled and primed. 2. 2x4 grid ceiling with fluorescent lighting through out. 3. HV AC--heated and cooled with roof top units, gas fIred heat, and electric cooling. Cooling based on one (I) ton per 400 square feet, turned over in good working order. 4. Two (2) bathrooms with standard plumbing in compliance with ADA in currently existing rough-in locations. 5. One (1) hot water heater for bathrooms only. 6. 200 amp electrical service with miscellaneous receptacles through out as required by Code. 7. Concrete flooring. 4" thick, 3000 psi. 8. Glass front, all windows and maintenance doors to be aluminum as manufactured by Kawaneer or equivalent. 9. Water, sewer and gas to be supplied at rear of property. 10. Demising wall. Tenant shall be responsible for build-out, floor covering, additional plumbing and additional hot water heater to service the Leased Premises and such other work necessary to complete the Leased Premises all at Tenant's sole cost and expense and not without Owner's approvaL 33 EXHIBIT C RULES AND REGULA nONS Tenant shall at all times during the term of the Lease: 1. Observe all traffic regulations, including posted speed restrictions and warnings and stop signs. Owner shall have the right of enforcing these regulations and of prohibiting use of access streets, service driveways and parking areas to violators. 2. Not permit smoking in the Leased Premises. 3. Use, maintain and occupy the Leased Premises in a careful, safe, proper and lawful manner, keep the Leased Premises and its appurtenances, including adjoining areas and sidewalks, in a clean and safe condition. 4. Keep the sidewalks and areas contiguous to the Leased Premises free of ice, snow and litter. 5. Keep all glass in the doors and windows of the Leased Premises clean. 6. Not, without prior written consent of the Owner, place. maintain or sell any merchandise in any vestibule or entry to the Leased Premises. on the sidewalks adjacent to the premises. or elsewhere on the outside of the Leased Premises. 7. Keep the Leased Premises clean, orderly and in sanitary condition, free of insects, rodents, vermin and other pests, and if by reason of any infestation of the Leased Premises by insects, rodents, vermin or other pests, any other store in the Shopping Center becomes infested by any such condition, Tenant shall be responsible for exterminating any such condition in other infested stores. 8. Not permit undue accumulations of garbage, trash, rubbish and other refuse in or around the Leased Premises, keep refuse in closed containers within the interior of the premises or a designated dumpster until removed, and arrange for regular removal of refuse at its expense. 9. Not use. permit or suffer the use of any apparatus or instruments for musical or other sound reproduction or transmission in such manner that the sound emanating therefrom or caused thereby shall be audible beyond the interior of the Leased Premises. 10. Not load or unload fixtures or merchandise from any premises entrance except the rear delivery entrance. 11. Not deliver or suffer or permit delivery of merchandise to, or collection of refuse from, the Leased Premises after 11:00 a.m. on any day. 12. Light the show windows and exterior signs of the premises to the extent that Owner may from time to time require. 13. Keep all mechanical apparatus free of vibration and noise. which may be transmitted beyond the confines of the Leased Premises. 14. Not cause or permit objectionable odors to emanate or be dispelIed from the premises. 15. Not overload the floors or electrical wiring and not install any additional electrical wiring or plumbing without Owner's prior written consent. 16. Not use show windows in the Leased Premises for any purpose other than display of merchandise for sale in a neat and attractive manner. 34 17. Not conduct, permit or suffer any public or private auction sale to be conducted on or from the Leased Premises. 18. Not solicit business in the common areas of the Shopping center or distribute hand bills or other advertising materials in the common areas, and if this provision is violated Tenant shall pay Owner the cost of collecting same from the common areas for trash disposal. 19. Automobiles belonging to Tenant. its employees and invitees, shall be parked only in the areas that may be designated by Owner, subject to the provisions of this Lease. 20. Doors in the Leased Premises shall not be covered or obstructed by Tenant. 21. Water closets and other plumbing shall be used for no other purpose than those for which they were intended and no sweepings, rubbish, rags, or improper articles and materials shall be thrown therein. It is recognized by the parties that chemicals, paints and thinners are especially injurious to the functioning of the property's sewage disposal system and, without limitation, shall not be disposed of in such sewage system. 22. No signs, advertisements or notices of any kind shall be painted or affixed to any part of the outside of the Leased Premises without the prior written permission of Owner. 23. Premises. No person of disorderly character will be allowed to frequent or remain on or about the Leased 24. No nuisance, public or private, shall be created or permitted in the demised premises and the Leased Premises shall be conducted so as that no annoyance is caused to Owner, Owner's employees or other tenants of the Owner. It is recognized that the Leased Premises are part of a Shopping Center in which numerous tenants are located and that absolute supervision of the use of the Leased Premises is necessary in order to officially maintain and operate an entire Shopping Center, and the parties therefore agree that the Owner shall have the exclusive and sole right of determining as to what constitutes a nuisances and that its determination shall be binding and absolute. 25. Upon termination of the Lease, doors and windows of the building shall be left securely fastened and the keys to the leased premises shall be delivered to the Owner. 26. Tenant's fire fighting and prevention apparatus shall be adequate and sufficient and shall be kept in proper working condition and accessible at all times so as to conform to all applicable laws, ordinances and regulations. J I 11 IN WITNESS WHEREOF, the parties set forth theirs hands this -i- day of {V~'l' ~"\ 2004. WITNESS: OWNER: Rothman, Schubert & Reed, a Pennsylvania Gene:&:::; By: cf tZ " c~ (SEAL) Samuel L. Reed, Attorney-in-Fact pursuant to Power of Attorney dated August 2 I, 1996, and recorded in Misc. Book 528, Page 480. --~Q~c;vU~ v By: (SEAL) ATTEST: --- !'....j"l\,,!i,,<~, .::;.\C~'-' _,V'-'J "'J 35 EXHIBIT 0 GUARANTY OF LEASE In consideration of the making of the above Lease dated rIll\] i$ , 2004, by the Tenant with the Owner at the request of the undersigned, and in reliance of the Guaranty, the undersigned hereby unconditionally and irrevocably guarantees the payment of the rent to be paid by the Tenant and the performance by the Tenant of all the tenus, conditions, covenants and agreements of the Lease and its Exhibits, and the undersigned promises to pay all of the Owner's expenses, including reasonable attorney's fees, incurred by the Owner in enforcing this Guaranty. The Owner's consent to any assignment or assignments, and successive assignments by the Tenant and Tenant's assigns, of this Lease, made either with or without notice to the undersigned, Or a changed or different use of the Leased Premises, or Owner's forbearance delay, extensions of time or any other reason whether similar to or different from the foregoing, shall in no way or manner release the undersigned from liability as Guarantor. Where the undersigned include more than one party, the obligation of each such party hereunder will be joint and several. It will not be necessary for Owner to proceed first against Tenant in invoking any of Owner's lease remedies before proceeding to enforce this Guaranty of Lease. WITNESS the hand and seal of the undersigned at the date of the above Lease. --". i \. , I "._ \\LLl0L'-\ ~Q)~ U ~ WITNESS: 36 ~ REAGER & ADLER PC l:/04/2004 15:0S 717'313'34'33'3 I \;\ --..~~ ~ :-~.---- _ ---=:e... .~-~~ . ~ . "\I \~ ii' \ \~ \ i!~\U\\~~ 11 , l\lIi1!\' '1.I!Il\l\iI'll .,:......,,,' \ \I'~ ~"'J i ' . , I I 1 I I \\\111 il\l i _,Ut \11I' nl Ii au II 1\ 1 U , \~ ~ n ,\~\~ i I "lit \:'11~ 111.~ J ~l\ v. \Ii I tj\, \ , \ ~ \I 1 ~ t .. ..' \~ ~ iI \\~\Il~! \l~1 il \' 11\ . 1'1 If '. (\ \il \'1 ~' ann 'Iill'l,' "'11\ Ill' li,!\ \ '\11 lill EXHIBIT A. /{'tJ 1:/84/2804 15:05 7173034333 REAGER & ADLER PC PAGE 03 RS&R SHOPPING CENTER -OVERALL A1Ilhal certain tract orland situate ill ~ Penntboro Township, Cumberland County, PeMsylVlllia, more partkularly bounded lUId described u follows: BEGINNING al a point <<.long lhe nort~ riglll of way line of Pennsylvania R.oule 944, <<.110 known as WefU:Villo R~ and on the line of ~joi"cr between lols no,. J and 3 on the hereinafter mentioned Plan ofLoI; lhatce, a101lS wd line of adjoillel' by a CIINC 10 the lel\ ....;lh a radiu, of 10.00' and an an: lC1lgth 0(15.71' to a paint~ , thalce, continuins along,.id line ofadjoincrN 17"n'J3'W, I distMce of ISS,5S'l0 a poinl; t/1alc.e., eolltlnuill8 &IonS &aid line ofadjoiller S 12027'27" W, . distance: of241.55' to I poitrt on the c:dIterline of an CIlOit;.,g 20' .,mill)' ~er easement thence, oontinuins along uid centerline the following COUlUS and dlstanccs; N 27"20'00" W, . diltll\co of 138.95' to a point; , N 17"15'30" W, a dittllle4 or263.28' to. point: N 4.10'00" E, a distlllU of 130.24' to. point; N 4.20')0" E. a dilt&l1CC of \23.12' to a point; N--13.3&'~. diltance-of2S9S1' Io-a point: N OO'SI'E.. diltlnccofJ4!.\<4' to a point 011 thcdinc ofa6joinerbetwcen Lot NO.3 and lands now or formerly (nit) pf Jacob R. RenniIl8cr: thence. alons wd Jill\! ofadjoiner N ~59'42" E, a distante ort02.70' to a point on the line or adjoincr bttwcen Lot No.3 and land. fIIf ofllobert B~ thence. along ~d line of lIdjoiner and along lands nlrofMargaret and Jacob Ulrick S 22024'4'1" E. . diJtance of2oo.1 J' 10 an iron pi!\; Iheneo, N 8100S'07" E, adlAUll.c;eof298.94'IO a point; them;.o. S :nos \'00" E, . di,tance of217.0S' to. point; lhcnc:e, alona u.id lands nlfof Conaervatlve Ilartilll Churdt S 11024'00" W, a distance of 125.44' to an iron pin; thence, along &aid line ofadjoiner S :n-s 1 'OS" E, a diatlllce of349.9S' to an iron pin; thence, aIon& said line ofadjoinerN 81024' E a distance \'If 123,44' to III Iron pin on tbe \WStern end ort.inden Street; , thence, donalllid western end orLirodm Sueet S 16015'0" E, a distance or 41.34 , to an Iron pin on landa nlf ofHden B. Hdsey; t~ Ilona said lands S 22-5)'35" E. d1.tlll'lee ortS2.38' to an Iron pinu!atl(b l1Ifof Dnnatd E. Shul1; tbcnc:e.. alolI& said lands nit or Shutt and land. nlf of Robert Bretz S 7)0<<'35" W . diltance orJ79.42' to an Iron pin; thence, along lIlid lAnd. ofBrdz SI7"3S'3S" E. d1stal1cc oflU.OJ' to a poinl on the nonhern line or Lot No.2; ExnmIT "'A.I" 'W\f ::/04/2004 15:05 717'30'34'33'3 REAGER & ADLER PC PAGE 04 .' thence. S 72"'17'2T" W . distamc of \99 .SO' 10 . point; thenee, S \"')2'33" E. di~ of208.00' to. point: thence, by. eurvc 10 lite left having a ndius of 10' (or an arc dist~c.c of 15.7" 10 . roint an thellOrthc:m line ofPennaylvanil Route 944, known a., Werlzvllle Road~ thence. S 72"27'27'" W . disUnee of79.().4' to a point the place ofIJEOlNNlNO. Containid8; 579,784~. n. (13.J \ Screll) BEING 1..01 No. J WERTZVILLE ROAD R1W CONVEYANCE All that certain tract orland aituate in East POItII&bot'o Township, Cumberland County, PenJlI)'lvlllia, more partia.alarly bounded and described IS follows; BEGINNING al a paml along the exlsting northern rlBltt of wa.y Unc orpcM~y(vania Route 944, also known u Wcrtzville Road, aaid point being located atlhe southeastern eorno::t of IlJlds now or fotlllcrly orErie Shore E.nterprise" Ine. thenc.c along said lands by . curvo to the lell having. radius of 10.00 and an arc length ort 5.71' to. poinl; thence, by same N ] 7"32')3" W a diltance of 5.14' to a point on the required nortllern right-of. way line ofWert:Ml1e Road; tha\ce, by wd right-of-way line N 72"26' \ r E. disWtec of 59.04' 10 & point al land, now or formerly orUni-Matts, Tne.; thence, along land. orUni. Maru, IllC. S 17.)2'))" E adlat.anc.e of 5,16' 10. point; thence, by same by a curvo to the left baYing. radius of 10.00, and.n arc length or IS.71' \0 a pOint on the nortbernrighl- or.way Iinc ofWertzvinc lloed; tbence, by said right-or-way line S 12<>27'27" W a distance of 79.(>>' to & point, the p~ce orBEOINNING. Containing: 938 "'1, fl. (0.02 a~) CONVEYANCE TO RS &R AU eM! ~n IUct: orland altuatc in Eat PCMIbora Township, Cumberland County, Pennsylv.ns.. moce partte.mrly bounded U1d described u Ibllowa: BEGINNING .1 a point on the eastern righr-<lr-way of Salt Road RoaIiJlMlcnl, Mid point bcins on tbe ct1Ileriine of an existing 20' sanitary IeWtf easement; thence, 110"1 said sewer ccnt~ine N 17"'S')0" WI diJtance of70.96'lo a point; theM.e. by same N 04.'0'OO~ E. di!tance of 130.:24' to a point; tlu:llce, along lands now or ronncr/y orWcst Shore rll'St Assembly ofGocl S 67"54'41" W I distamc of 116.45' to I point on the eutem rlght-Or-WIY line of Salt R04d Rea\lgnmcnt; thenee, a1on. said risllt-or.way line S ~ ., '" .' I, 1:/04/2004 15:05 PAGE 05 71 7505453'3 REAGER & ADLER PC 22605'19" E I diltancc of 113.65' 10 I point~ thence, by same: N 6"S4'.4\" ~,distanc:ll of 5.00' 10 I point; thalcc, by ~ S 22-05'19" Ii I distllllCC of II 3.65' to I point; thence, by _N 67'"S4'41~ E .diatanee Of47..6',0. point, the placeofOEGINNlNG. Containing: 13,618 sq. ft. (0.31 aerea) '\AN 1:/04/2004 15:05 717'309493'3 REAGER & ADLER PC PAGE 05 EXHIBIT E , SAMPLE ~NU INSALATE mTlP.<STO AU. '1TI-UAN'" W$.Al.A1'''' CBSARB lN8......T... OIPOlLO fN'S.4LA.TA O~ CAS4 lNBAL.A 7'..... CAMtES!! ANTIPASTI ANTIP.\STO Pllr.l..'. CASA .....MIIEIU II ~I PfllTI'l v.-.MJ~JlCAlAMAJ\1 Ml;r...'l'l SRU5C1O!1'1'A t.l. /'OIdOI:lOkO MAZZARel-LII JlIUTTS PROSCtU'T'l'O B MRt..OIo/U P Al'iINl '..."DlO CON 1'OmO ,ANlNO eON PRD.CllITTO PhNINO AlJ:rrAUANA PANlNO CON POt.l.O ^,-I..A. 0RKl1.lA P ANINO CON CAI.Nli ""NINO VIl0BTALB PIZZE1'TE I'IZZAMMOIl'llIln'... Pll.zA N.APOt.IlT "NA ,=^ Qtl..'I"nlO STAG.IONI ,lUAOlA"OLA ~ lllANCA PIZZ",,\A,J It(J2ro((]JI(I f'IZZA V~~T...UI PlUM! PIA Tn 1V.'V10U'COII p~ BI'ROACIU'T'l'OCO'M'O RIS01'TO ,oJ fUNQffi RISOTTO AU.A Pll8CATOIU GNoc:<:>Il ~ 1lOI.tXll<Ul! rhST.. CON PO/'''''''''_O 1'JtIl3C0 "IOATONI~ PllTl'IJCClJ>/T l'UIT.4N&IC:A I'llNNi CmI POl.LO II rAN>lA 915=... Al FeP.1U !'E.'Cal>llI.O~ArJlllIUl1 DOLCI tlUIlEKTS WllX. <::IWlCI1I ....UK.l. Y BEVANDE CAPI't1CC!>IO !lllPfU!lSO CAPVIlLATTR ACQUA MI>W<ALIl MA.'NCIATA UMOIolA ~^ CI1INO'M'O BI!llT& GASJAn: Date;// - ~ '1. tJ V as received assess ion to Possession Date //-o9-a'l Code 11- 7+8 J'5l./ East Penn Dr. I Enola, PA 17025 By signing this letter you agree on the following: Occupancy Date //-o9-a'l 1- (j 9 - ~S Rent Commencement Initial Monthly Base Rent Amount Initial Monthly Additional Rent 3dKtJ .()o l1.3.:J~D, 00 Security Deposit Pre-Paid Rent Amount Partial Rent Payment Due $1' ..3,;{ 80 ,0 0 .;;J.~(f1.0S -r Sfc3. 7~ CAU1-f4)ce-J ,.~s Next Full rent Payment Date of Base Rent Increases 1- CJ'1 - , 0 + I - ~9. /6 - /- 0 c, - ;;. 0 /-f)'-/I (c;1,) F/VE \/ ~ . I Lease Termination Date Options Please review and sign letter of acknowledgment and agreement. It is our policy that we do not release key until this worksheet is returned. By returning it immediately to my attention (by fax (717) 763-1656) you will avoid delay in receiving your key and help us facilitate our accounting process. If you have any questions regarding the above. please contact me at (717) 763-1212. Thank vau ~~M. Landord Name: Rothman. Schubert & Reed ~ R,I / f11 'v< P' . Print: HA5) 1~10 NA PQ, SSN#: ZOb' -1-8 -5:194- Drivers LiC#fL /40 -~~4r. _ +'( -050-Q Rothman, Schubert & Reed 3 Lemoyne Drive. Suite 100. Lemoyne PA. 17043-717-763-12]2 - fax (717) 763-1656 l: (.:J ~ '1 .Vi ...... ~ ~ "', g (') c:...~, C) C. <"":':':1 " ~ ~ ~ '--1 ~ ~,-- ~-:- r+" - . " r5' I --'J \.0 1? C) ~~ r,)l r" REAGER & ADLER, PC Theodore A. Adler, Esquire Attorney J.D. No. 16267 John H. Pietrzak, Esquire Attorney J.D. No. 79538 2331 Market Street Camp Hill, P A 17011 Telephone: (717) 763-1383 Attorneys for Defendant, Rothman, Schubert & Reed MASSIMO TRATTORIA, INC. a Pennsylvania Corporation and MASSIMO NAPOLI, individually, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiffs v. CNIL TERM No. 05-2395 WILLIAM F. ROTHMAN, CHARLES F. SCHUBERT AND SAMUEL L. REED, co-partners t/d/b/a ROTHMAN, SCHUBERT & REED, a Pennsylvania General Partnership, Defendants NOTICE TO PLEAD To: Kathleen V. Yurchak, Esquire Goodall & Yurchak, P.C. 328 South Atherton Street State College, P A 16801 YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED DEFENDANT, ROTHMAN, SCHUBERT & REED'S PRELIMINARY OBJECTIONS WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. Date: June 9, 2005 Respectfully SUb, itt,et REAGER AD Ej .c.! I '., /' I' I ~ i Theodore . Ad1 , Esquire REAGER & ADLER, PC Theodore A. Adler, Esquire Attorney I.D. No. 16267 John H. Pietrzak, Esquire Attorney I.D. No. 79538 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Defendant, Rothman, Schubert & Reed MASSIMO TRATTORIA, INC. a Pennsylvania Corporation and MASSIMO NAPOLI, individually, : IN THE COURT OF COMM<DN PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiffs v. CIVIL TERM No. 05-2395 WILLIAM F. ROTHMAN, CHARLES F. SCHUBERT AND SAMUEL L. REED, co-partners t/d/b/a ROTHMAN, SCHUBERT & REED, a Pennsylvania General Partnership, Defendants ROTHMAN SCHUBERT & REED'S PRELIMINARY OBJECTIO S TO COMPLAINT FILED BY MASSIMO TRATTORIA INC. AND MASSIM NAPOLI Rothman, Schubert & Reed ("RSR") by and through its undersigned counsel Reager & Adler, P.c., hereby files the following Preliminary Objections to the Complaint filed by Massimo Trattoria, Inc. and Massimo Napoli ("Massimo") in the above-captioned action, and in support thereof avers as follows: 1. RSR is a Pennsylvania General Partnership, with a business address of 3 Lemoyne Drive, Suite 100, Lemoyne, PA 17043. 2. RSR is the owner of the property located at 385 East Penn Drive, Enol~, PA 17025, known as the Pennsboro Commons Shopping Center. 3. Massimo Trattoria, Inc. is a Pennsylvania Corporation with a mailing! address of 2248 Saw Palmetto Lane, Building 7, Apt. 117, Orlando, Florida 32825. 4. Massimo Napoli is an individual with a mailing address of2248 Saw Palmetto Lane, Building 7, Apt. 117, Orlando, Florida 32825. 5. On November 8, 2004, RSR and Massimo entered into a lease agreement ("Lease") for a commercial space located at 385 East Penn Drive, Enola, P A 17025, identified as Block H, Unit 7 and 8. A copy of the lease agreement is attached as Exhibit "A". 6. On May 9, 2005, Massimo filed a Complaint with the Cumberland County Prothonotary, alleging three counts, including Breach of Contract, Rescission and FraudlMisrepresentation. A copy of the Complaint is attached hereto as Exhibit "B" without admitting any of the allegations contained therein. 7. Pursuant to Pa.R.C.P. 1028(a), RSR hereby files the following preliminary objections to the Complaint filed by Massimo. First Preliminary Objection Pa.R.C.P. l028(a)(6) - Agreement for Alternative Dispute Resolution 8. The written lease between the parties, a copy of which is attached hereto and incorporated herein by reference, contains at Section 20.02 a clear Alternative Dispute Resolution provision, which states in pertinent part: "Any disagreement between Owner and Tenant with respect to the interpretation or application of this Lease, or the obligatioI1l of the parties hereunder, shall be determined by arbitration unless the parties otherwise mutually agree in writing. . . This agreeIlllent to arbitrate shall be specifically enforceable under the prevailing arbitration laws." 9. The parties have not made any other agreements regarding the procedpre for resolving disputes. 10. The Courts in Pennsylvania have consistently held that contractual ptpvisions requiring disputes to be submitted to arbitration are binding and preclude a party from pursuing its claim in a court oflaw. DiLucent Corp. v. Pennsylvania Roofing Co., Inc., 655 A.2d 1035 (Pa. Super. 1995). 11. Because the written contract between the parties contains an Alternative Dispute Resolution provision requiring arbitration, the Plaintiffs' Complaint must be dismissed. WHEREFORE, Defendant Rothman, Schubert & Reed respectfully requests this Honorable Court to dismiss Plaintiffs' Complaint with prejudice. Second Preliminary Objection Pa.R.c.P. 1028(a)(3) - Insufficient Specificity in Count One 12. In Count One of its Complaint, Massimo avers at Paragraph 27 that RlSR breached the lease agreement by "failing to provide a Leased Premises which was sufficient for its permitted use." (emphasis added). 13. At Paragraph 11 of its Complaint, incorporated by reference into Count One, Massimo avers that "At the time the Lease was signed, RSR knew or should have kniown that the current heating and cooling units in location on the Leased Premises were not sufficient to allow operation, under the applicable building code requirements, of a dine in restaurant[. ]" (emphasis added). 14. At Paragraph 19 of its Complaint, incorporated by reference into Count One, Massimo avers that "In December 2004, the East Pennsboro Township Building Inspector- Codes Enforcement Officer notified Plaintiffs that it could not provide an occupancy permit and/or was issuing a stop work order because, among other things, the HVAC equip",:ent was not acceptable to handle the air requirements for the assembly occupancy load." (emph4sis added). 15. Pennsylvania Rule of Civil Procedure 1019(a) requires Massimo to state the material facts upon which its claim is based. The Complaint must contain specific material facts that apprise the defendant of the nature and extent of the plaintiffs claim so that the defendant has notice of what the plaintiff intends to prove at trial and may prepare a defense. Weiss v. Equibank, 460 A.2d 271 CPa. Super. 1983) 16. Paragraphs 11, 19 and 27 of Massimo's Complaint fail to plead material facts with sufficient specificity to allow RSR to either admit or deny the allegations or to II>repare a defense. 17. Massimo's reference in Paragraph 11 to "applicable building code requirements" fails to adequately plead any material facts. 18. Massimo's general allegations in Paragraphs 11 and 19, that the HV AC system was "not sufficient" and "not acceptable" fail to inform RSR of the nature and extent of its claim and fail to adequately plead any material facts. In addition, with regard to Paragrap1l19, Massimo has not identified the name of the inspector, the specific date on which thelinspection took place or provided a copy of the inspection report. 19. Massimo's allegation in Paragraph 27, that RSR breached the lease agreement by failing to provide a Leased Premises which was "sufficient for its permitted use" faHs to adequately plead any material facts. 20. Nowhere in Massimo's Complaint does it define these terms or provitle any further description of what is meant. WHEREFORE, Defendant, Rothman, Schubert & Reed respectfully requests this Honorable Court to dismiss Count One of the Plaintiffs' Complaint with prejudice, Of to Order the Plaintiffs to file a more specific Complaint with regard to Count One. Third Preliminary Objection l028(a)(3) - Insufficient Specificity in Count Two 21. In Count Two of its Complaint, Massimo avers at Paragraph 31 that "the state of the HV A C was essential for the operation and opening of the business." (emphasis added). 22. At Paragraph 32 of its Complaint, Massimo avers, in pertinent part, that "At the time of the signing of the lease, Defendant's knew or should have known that the HVAC system was not sufficient to support the determining motive for the Leased Premises." (Emphasis added). 23. At Paragraph 33 of its Complaint, Massimo avers that "The Plaintiffsidid not and should not have known about the state of the HVAC system." (emphasis added). 24. The general allegations of the sufficiency or state of the HV AC system fail to comply with the requirement ofPa.R.C.P. 1019(a) that a pleading contain "material facts." 25. Pennsylvania Rule of Civil Procedure 1019(a) requires Massimo to state the material facts upon which its claim is based. The Complaint must contain specific material facts that apprise the defendant of the nature and extent of the plaintiffs claim so that the <,lefendant has notice of what the plaintiff intends to prove at trial and may prepare a defense. Weiss v. Equibank, 460 A.2d 271 (Pa. Super. 1983) 26. Paragraphs 31, 32 and 33 of Massimo's Complaint fail to plead mateqal facts with sufficient specificity to allow RSR to either admit or deny the allegations or to prepare a defense. 27. Massimo's general allegations in Paragraphs 31 and 33, regarding the "state of the HV AC system" fail to plead any material facts. RSR cannot determine what is meanit by the "state of the HV AC system. 28. Massimo's general allegation in Paragraph 32 that the HV AC system was "not sufficient" fails to inform RSR of the nature and extent of its claim and fails to adeqlllately plead any material facts. 29. Nowhere in Massimo's Complaint does it define these terms or provide any further description of what is meant. WHEREFORE, Defendant, Rothman, Schubert & Reed respectfully requests this Honorable Court to dismiss Count Two of the Plaintiffs' Complaint with prejudice, or to Order the Plaintiffs to file a more specific Complaint with regard to Count Two. Fourth Preliminary Objection l028(a)(3) - Insufficient Specificity in Count Three 30. In Count Three of its Complaint, Massimo requests rescission of the lease agreement due to alleged fraud/misrepresentation on the part of Defendant, RSR. 31. At Paragraph 12 of its Complaint, incorporated by reference into Count Three, Massimo avers that "RSR failed to advise Plaintiffs that the current heating and cooling units were not sufficient." (emphasis added). 32. At Paragraph 37 of its Complaint, Massimo avers that "Defendants through the oral and written statements in the Lease, represented that the facility was sufficient for its intended use." (emphasis added). 33. These general allegations of sufficiency fail to comply with the requinement of Pa.R.C.P. 1019(a) that a pleading contain "material facts." 34. Pennsylvania Rule of Civil Procedure 1019(a) requires Massimo to state the material facts upon which its claim is based. The Complaint must contain specific material facts that apprise the defendant of the nature and extent of the plaintiffs claim so that the defendant I has notice of what the plaintiff intends to prove at trial and may prepare a defense. Weiss v. Equibank, 460 A.2d 271 (Pa. Super. 1983) 35. Paragraphs 12 and 37 of Massimo's Complaint fail to plead material f~cts with I sufficient specificity to allow RSR to either admit or deny the allegations or to prepare a defense. 36. Massimo's general allegations in Paragraphs 12 and 37, regarding the sufficiency of the HV AC system fail to inform RSR of the nature and extent of its claim and failto adequately plead any material facts. 37. Nowhere in Massimo's Complaint does it define these terms or provide any further description of what is meant. WHEREFORE, Defendant, Rothman, Schubert & Reed respectfully requests this Honorable Court to dismiss Count Three of the Plaintiffs' Complaint with prejudice, or to Order the Plaintiffs to file a more specific Complaint with regard to Count Three. Fifth Preliminary Objection - Demurrer to Count Two Pa.R.C.P. 1028(a)(4) - Failure to State a Cause of Action 38. In Count Two of its Complaint, Massimo requests rescission of the lease agreement due to unilateral mistake on the part of Massimo. 39. Massimo's Complaint fails to state a cause of action under Count Two for which relief can be granted because a unilateral mistake is not a basis for rescission of a lease. 40. "The fact that one of the parties entered into a transaction as a result of a purely unilateral mistake affords no basis for rescission or other relief, where the other party to the transaction was in no way responsible for the existence of such misapprehension, and in entering into the contract acted in good faith without knowledge of such mistake." Woodsmarz of the World Life Ins. Soc. v. Arnold, 166 A.2d 290,297 (Pa. Super. 1960) citing, Summary of Pennsylvania Jurisprudence, Contracts, Sect. 223. 41. In an attachment to the lease referred to as "Exhibit B - Owner's Wotk", RSR represented to Massimo in item No.3 that it would provide "HV AC-heated and co01led with roof top units, gas fired heat, and electric cooling. Cooling based on one (1) ton per 400 ~quare feet, turned over in good working order." 42. Massimo has not alleged anywhere in its Complaint that the HV AC system did not provide cooling as set forth in Exhibit B to the lease. 43. The lease terms regarding the HV AC system were clearly spelled out in the lease agreement signed by Massimo. 44. Massimo's unilateral mistake, i.e. its unwarranted belief that the HV AC system would perform other than as specified in Exhibit B to the lease, is not due to any fra4d or misrepresentation on the part of RSR. 45. As such Massimo's Complaint fails to state a cause of action under Count Two for which relief can be granted. Sixth Preliminary Objection - Demurrer to Count Three 1028(a)(4) - Legal Insufficiency of a Pleading 46. In Count Three of its Complaint, Massimo requests rescission of the lease agreement due to fraud/misrepresentation on the part of Defendant, RSR. 47. Pa.R.c.P. 1019(b) requires that averments of fraud or mistake shall be averred with particularity. Malice, intent, knowledge, and other conditions of mind may be averred generally. 48. The plaintiff must set forth in the complaint the exact statements or actions that constituted the alleged fraudulent misrepresentations, stated with adequate specificity to enable the defendant do prepare a defense. Y oundt v. First National Bank of Port Allegany, 868 A.2d 539 (Pa. Super. 2005). 49. In Paragraph 22 of its Complaint, incorporated by reference into Count Three, Massimo avers that "The Plaintiffs relied on the representations made by RSR regarqing its intended use and that the premises would be suitable for a restaurant facility." (empqasis added). 50. In Paragraph 39 of its Complaint, Massimo avers that "The Plaintiff justifiably relied upon the representations made by the Defendants." (emphasis added) 51. In Paragraph 40 of its Complaint, Massimo avers, in pertinent part, "As a result of the Defendants' actions, the Plaintiffs were ultimately forced to expend money for the buildout and construction of the premises. (emphasis added) 52. These general allegations of representations made by RSR fail to comply with the requirement ofPa.R.C.P. I 019(b) that averments of alleged fraud be averred with particularity, and of Youndt, that the Complaint set forth the exact statements allegedly constituting fraudulent misrepresentation. 53. Paragraphs 22,39 and 40 of Massimo's Complaint do not set forth an~ alleged "exact statements" or actions on the part of RSR, and are insufficiently plead to allow RSR to either admit or deny the allegations or to prepare a defense. 54. Nowhere in Massimo's Complaint does it aver what statements or actions on the part ofRSR constitute fraudulent misrepresentation. WHEREFORE, Defendant, Rothman, Schubert & Reed respectfully requestsl this Honorable Court to dismiss Count Three of the Plaintiffs' Complaint with prejudice. Seventh Preliminary Objection - Demurrer to Count Three Pa.R.C.P. 1028(a)(4) - Failure to State a Cause of Action 55. In Count Three of its Complaint, Massimo requests rescission of the Lease agreement due to fraud/misrepresentation on the part of Defendant, RSR. 56. Assuming arguendo that Massimo properly pled a claim for I fraud/misrepresentation, Massimo's Complaint still fails to state a cause of action for which relief can be granted, because the Parol Evidence Rule would bar the introduction oft evidence regarding Defendant RSR's alleged representations that occurred prior to the signingiofthe lease. 57. "Where the parties to an agreement adopt a writing as the final and complete expression of their agreement, alleged prior or contemporaneous oral representations or agreements concerning subjects that are specifically covered by the written contract are merged in or superseded by that contract." Youndt v. First National Bank of Port Allegany, 868 A.2d 539, 545-546 (Pa. Super. 2005) citing, Blumenstock v. Gibson, 811 A.2d 1029, 1037 CPa. Super. 2002). 58. The lease agreement between RSR and Massimo contained the following language, just above the signature lines on pg. 32 of the agreement: THIS LEASE CONSTITUTES THE ENTIRE AGREEMENT THIS LEASE AND THE EXHIBITS AND RIDER, IF ANY, ATTACHED HERETO, IS THE COMPLETE AGREEMENT BETWEEN OWNER AND TENANT CONCERNING THE LEASED PREMISES AND THE SIjIOPPING CENTER. THERE ARE NO ORAL AGREEMENTS, UNDERSTANDINGS, PROMISES OR REPRESENTATIONS BETWEEN OWNER AND tENANT AFFECTING THIS LEASE. ALL PRIOR NEGOTIATIONS AND UNDERST ANDINGS, IF ANY, BETWEEN THE PARTIES HERETO WITH RESPECT TO THE LEASED PREMISES AND THE SHOPPING ciENTER SHALL BE OF NO FORCE OR EFFECT AND SHALL NOT BE U$ED TO INTERPRET THIS LEASE. 59. In an attachment to the lease referred to as "Exhibit B - Owner's Work", RSR represented to Massimo in item No.3 that it would provide "HV AC-heated and cooled with roof top units, gas fired heat, and electric cooling. Cooling based on one (1) ton per 400 square feet, turned over in good working order." 60. The lease agreement and the Owner's Work rider, attached to the lease at Exhibit "B", constitute the final and complete agreement concerning the HV AC system. 61. Massimo has not alleged anywhere in its Complaint that the HV AC slfstem did not operate as set forth in Exhibit "B" to the lease. 62. Parol evidence may be admissible in proving a claim for fraud if the ~laintiff alleges "fraud in the execution", in which the plaintiff signed the lease only because he was misled into believing it contained terms that were actually omitted. Blumenstock v. Gibson, 811 A.2d 1029 (Pa. Super. 2002). 63. Massimo has not alleged that it signed the lease because it was misled that terms were included in the lease that actually were omitted. 64. Parol evidence may also be admissible to prove a claim for alleged fraud where the plaintiff alleges "fraud in the inducement", in which the plaintiff alleges that but for the alleged prior representations, he would not have entered into the contract. However, parol evidence is still inadmissible to prove fraud in the inducement where the written agreement contains terms that deny the existence of such prior representations. Youndt v. First National Bank of Allegany, 868 A.2d 539, 545 (Pa. Super. 2005). 65. Massimo does not specifically allege that but for the alleged prior representations, it would not have entered into the lease. 66. Even if Massimo had so alleged, the language contained on page 32 dfthe lease, reproduced above in Paragraph 51, specifically denies the existence of such prior representations, when it states that there are no oral agreements, understandings, promises or representations affecting the lease, and that all prior such understandings shall have no effect. 67. Parol evidence cannot be admitted to interpret the lease. As such Massimo's Complaint fails to state a cause of action under Count Three for which relief can be granted. WHEREFORE, Defendant, Rothman, Schubert & Reed respectfully request$ this Honorable Court to dismiss Count Three of the Plaintiffs' Complaint with prejudice, WHEREFORE, Rothman, Schubert & Reed respectfully requests that the C~urt sustain these Preliminary Objections and enter an Order in the form attached hereto. Date: June 9, 2005 BY: Theod e . ir Attorney LD. No. 16267 John H. Pietrzak, Esquire Attorney I.D. No. 79538 2331 Market Street Camp Hill, P A 17011 Telephone: (717) 763-1383 Attorneys for Defendant, Rothman, Schubert & Reed --------- CXh\Q'\{ A - dlblrsr\MassimoNapoli.lse November 4, 2004 LEASE LETTER I 1 Pennsboro Commons Shopping Center I Rothman, Schubert & Reed I 3 Lemoyne Drive, Suite 100 Lemoyne, PA 17043: ~ I Lease dated (!) D \J -, 2004 between William F. Rothman, Charl~ls F. Schubert & Samuel L. Reed, Co-Partners, tJdIb/a Rothman, Schubert & Reed, a Penn ylvania General Partnership, Owner, and Massimo Napoli, Inc., a Pennsylvania corporation, enant, covering Premises located in Pennsboro Commons Shopping Center, East Penns ora _Township, Cumberland County, Pennsylvania. 1 I i \ 1 i - I Tenant has accepted possession of the Premises demised pursuant to the temts of the above- described Lease., t The improvements and space required to be furnished according to the aforesaid ease have been completed and supplied in all respects. i -I RE: The undersigned, as Tenant, hereby confirms the following: 2. 3. 4. 5. 6. 7. 1. Landlord-Owner has fulfilled all of its duties of an inducement nature. The aforesaid Lease has not been modified, altered or amended except as set forth below. There are no offsets or credits due against rentals nor have rentals been pre~aid except as provided by the Lease terms. I The initial term of said Lease began on the --.r day of commenced to accrue on that date; the initial Lease Term expires on r I I I ~- MasSimo - I ;/ Exhibit 1 LEASE AGREEMENT PENNSBORO COMMONS SHOPPING CENTER 2 LEASE AGREEMENT WITNESSETH, that in consideration of mutual covenants, Owner and Tenan hereby agree as follows: SECTION A. BASIC LEASE PROVISIONS AND ENUNIERATION OF EXHIBITS Section A-1. Basic Lease Provisions. DATE: ,2004 SHOPPING CENTER: Pennsboro Commons Shopping Center Cumberland County, Pennsylvania William F. Rothman, Charles F. Schubert & Samuel L. Ret, Co-Partners, t/dIb/a Rothman, Schubert & Reed, a Pennsylvania General Pa ership with an address of 3 Lemoyne Drive, Suite :100, Lemoyne, P A 17043. I ~O~A I Massimo ~ a Pennsylvania corporation 384 East Penn Drive, Enola, P A 17025 OWNER: TENANT: . TENANT'S ADDRESS: TENANT'S PHONE NUMBER: 407-491-7686 TENANT'S TRADE NAME: ~- Jv1/~S.s/Ho -ir-JiJror,-tA &i LEASED PREMISES: The Premises outlined in red on Exhibit A containing appro iffiately 2,460 square feet of Gross Leasable Area and identified as Block H, Units 7 and 8 with an address of 384 East Penn Drive, Enola, P A 17025. LEASED TERM: Five (5) Years. RENEW AL TERM: Two (2), Five (5) Year options. 3 PERIOD FOR COMPLETION OF TENANT'S WORK: PERMITTED USES: ANNUAL MINIMUM RENT: PERCENTAGE RATE: BREAKPOINT: INITIAL ESTIMATED COMMON FACll...ITlES CONTRIBUTION FOR TENANT: INITIAL ESTIMATED TAX CHARGE FOR TENANT: Tenant's work shall be completed on or before 30 days after 0 ner substantially completes Owner's Work set forth in Exhibit B and makes the Leased Premises available to Tenant. The term "substantially completes" as used in this paragraph shall mean that Owner has completed Owner's Work with the exception of minor items which can be fully completed prior 0 completion of Tenant's Work without material interference with Tenant's War or upon receipt of a certificate of occupancy from East Pennsboro Township, hichever occurs sooner. Eat-inlDine-in Italian Trattoria restaurant serving lunch and di ner with a high end atmosphere, white table cloths, BYOB, and serving such ill nu items as are set forth on the attached Exhibit E, and not otherwise in iolationof any currently granted or existing exclusives granted to other Tenants. Tenant shall pay to Owner, as Annual Minimum Rent, on the fi st day of every month, in advance, and at a rate of $16.00 per square foot, the urn of $39,360 annually ($3,280/month) for the five (5) year Lease Term. The Annual Minimum Rent for the renewal term(s), if any, shall e: First Option: $17.00 per square foot, $41,820 annually ($3,485/m nth) Second Option: $18.00 per square foot, $44,280 annually ($3,69 /month) N/A% $N/A $3,690.00 per calendar year ($307.50 per month) (subject to adjustment as set forth in Article vn of this Lease) $2,460.00 per tax year ($205.00 per month) (subject to adjustmen as set forth in Article VI of this Lease) 4 INITIAL ESTIMATED INSURANCE CHARGE FOR TENANT: $615.00 per calendar year ($51.25 per month) (subject to adjus ment as set forth in Article X of this Lease) SECURITY DEPOSIT: Upon execution of this Lease, Tenant shall deposit the sum 0 $3,280.00 with Owner to secure the performance of the obligations of Tenant h rein contained. Section A-2. Effect of Reference to a Basic Lease Provision. Each reference in this Lease to any of the Basic Lease Provisions contained in ection A-I shall be deemed to incorporate all of the terms provided under each such Basic Lease Provisio . Section A-3. Enumeration of Exhibits. The Exhibits enumerated in this Section and attached to this Lease are hereby incorporated in this Lease by reference and each party agrees to perform all obligations binding up it under such Exhibits. Exhibit A Exhibit A-I Exhibit B Exhibit C Exhibit D Exhibit E Site Plan Legal Description of Owner's Tract Owner's Work Rules and Regulations Guaranty of Lease Sample Menu RECITALS Owner owns fee title to certain real property described on Exhibit A-I. Th real property described on Exhibit A-I (as the same may be expanded or reduced as contemplated i this Lease) is herein called "Owner's Tract." The term "Shopping Center" shall mean Owner's Tract, t gether with the buildings and other improvements thereon from time to time. ARTICLE I - GRANT AND TERM Section 1.01. Leased Premises and Common Areas. Owner leases to Tenant and Tenant rents from Owner those premises located i the Shopping Center and described as the "Leased Premises" in Section A-I of the Basic Lease Provi ions, together with the appurtenances specifically herein granted. The use by Tenant of the Leased remises shall include the non-exc1usive use of the "Common Facilities" (as defined in Section 7.02) sh wn on Exhibit A, and such other Common Facilities as may be designated from time to time by wner, subject, however, to the provisions of Section 4.02 and 7.04 and to the other terms and conditions this Lease. 5 Section 1.02. Tenn. The term of this Lease and Tenant's obligation to pay rent shall, subject to he provisions of Section 23.02, commence upon the earlier of the following dates (the "Commenceme t Date"): (i) the date on which Tenant shall open the Leased Premises for business with the public, 0 (ii) the date of expiration of the "Period For Completion of Tenant's Work" designated in Section A-I 0 the Basic Lease Provisions, but no later than that date which is sixty-days (60) days after the date the Lase is signed by both parties. The term of this Lease shall expire, unless sooner terminated as in this Le se provided, on the last day of the last "Leased Year" (as defined in Section 23.04) provided under 'Lease Term" in Section A-I of the Basic Lease Provisions. In order to extend the Leased Term as provided under "Renewal Term" in Section A-I of the Basic Lease Provisions, Tenant shall give Owner inety (90) days written notice of its intention to renew the Leased Term prior to the end of the then cu ent term at the amount designated for the renewal terms provided under Annual Minimum Rent in Se tion A-I of the Basic Lease Provision. Section 1.03. Obligations Prior to Commencement of Term. Tenant shall perform all of its obligations under this Lease (except its obligation to pay rent and other charges) from the date upon which the Leased Premises are first made available to enant until the Commencement Date. Section 1.04. Owner's Financing Contingency. JNTENTIONALL Y OMITTED ARTICLE II. RENT Section 2.01. Annual Minimum Rent. Tenant shall pay to Owner, without any prior demand, deduction or seta , the "Annual Minimum Rent" specified in Section A-I of the Basic Lease Provisions, in equal monthly nstallments on or before the first day of each calendar month in advance. Annual Minimum Rent or a fractional calendar month shall be prorated. Section 2.02. Percentage Rent. JNTENTIONALL Y OMITTED Section 2.03. Gross Receipts Defined. The term "Gross Receipts" is defined to mean: (i) the entire amount of the price ch ged, whether wholly or partially in cash or on credit, or otherwise, for all goods, wares, merchandise nd chattels of any kind, sold, leased, licensed or delivered, and all charges for services sold or perla d in, at, upon or from any part of or through the use of the Leased Premises or any part thereof by Tenan and any other person, firm or corporation, or by means of any mechanical or other vending device ( ther than pay telephones and those soft drink and other similar vending devices operated primarily for t e convenience of Tenant's employees); and (i1) all gross income of Tenant and any other person, firm r corporation from any operations in, at, upon or from the Leased Premises which are neither included i nor excluded from Gross Receipts by other provisions of this Lease, but without any duplication. Gross Receipts shall not include the amount of any sales tax, use tax or retail excise tax which is impose by any duly constituted governmental authority directly on sales and which is both added to the se ling price (or absorbed therein) and is paid to the taxing authority by Tenant (but not any vendor of Tenant). No franchise or capital stock tax, and no income or similar tax based upon income or profits a such, and no personal property tax, shall be deducted from Gross Receipts. 6 Section 2.04. Additional Rent. Tenant shall pay, upon demand as additional rent, all charges required to b paid by Tenant under this Lease, whether or not the same are designated "additional rent". Section 2.05. Interest. If Tenant shall fails to pay within five (5) days from when the same is due and ayable, any rent or any additional rent, Tenant shall, upon demand, pay Owner (i) a late charge of 100.00 for each installment of Annual Minimum Rent or other charge past due and (ii) interest at the" terest Rate" (as defined in Section 23.04) on the arrearages from the due date thereof until paid. ARTICLE III - RECORDS; REPORTS AND AUDIT Section 3.01. Tenant's Records; Reports and Audit. Tenant agrees to prepare and keep true and complete records and accounts for at least 24 months after each Lease Year during the term of this Lease of all final records including b t not limited to income statement, balance sheet and financial statement for each such Lease Year in ccordance with generally accepted accounting principles consistently followed. Tenant shall provid such financial records to Owner within 15 days of Owner's written request for the purpose of satisfy ng a current or future mortgagee or purchaser in the event that Owner would refinance or sell the Shop ing Center and such mortgagee or purchaser would request such information; provided that Owne shall (i) keep confidential, not disclose (other than to the mortgagee or purchaser) or otherwise use for ts benefit, such information, and (ii) cause the mortgagee or purchaser to agree in writing to keep c nfidential, not disclose or otherwise use for its benefit such information. ARTICLE N - CONSTRUCTION ALTERATIONS. ADDITIONS AND RELO ATIONS OF IMPROVEl\1ENTS Section 4.01. Owner's and Tenant's Work. (A) Owner and Tenant shall construct the Leased Premises in accordance wit of Exhibits B. All of Tenant's Work with respect to utility installations shall also be subj when applicable, by the utility company furnishing the service. (B) Owner or an authorized utility company shall have the right to cons ct, maintain, repair, replace and relocate utility lines, pipes, conduits and duct work where necessa or desirable, through attic space, column space or other similar areas of the Leased Premises, and t repair, alter, replace or remove the same, all in a manner which does not interfere unreasonably wit Tenant's use thereof, and Tenant shall not be entitled to an abatement or reduction of rent or to c1ai an actual or constructive eviction by reason thereof. "Owner's Work" (hereinafter defined in Exhi it B) shall be deemed approved by Tenant in all respects except for items of Owner's Work which are n t completed or do not conform to Exhibit B and as to which Tenant shall have given notice to Owner ithin 30 days after the commencement of the term. Section 4.02. Changes and Additions to the Shopping: Center. Notwithstanding anything set forth in this Lease to the contrary, it is agreed that wner reserves the right, without invalidating this Lease or modifying any provision thereof except Ex ibit A, at any 7 time either before, during or after the initial construction thereof, (i) to make alte ations, changes, deletions and additions (including additional stories) to the buildings, Common Fac lities and other improvements in the Shopping Center (excluding the interior of the Leased Premises) (ii) to add and permit to be added additional land(s) to the Shopping Center and to exclude land(s) t erefrom; (iii) to construct and to permit to be constructed additional buildings and other improvements 'n the Shopping Center; (iv) to remove or relocate the whole or any part of any building or other imp ovement in the Shopping Center; and (v) to relocate the premises leased to any other tenant. PROVIDE , HOWEVER, the foregoing shall not be construed as permitting Owner to change the location f, or otherwise umeasonably interfere with Tenant's use of the Leased Premises. ARTICLE V - CONDUCT OF BUSlNESS BY TENANT Section 5.01. Use of Premises. Tenant shall operate the Leased Premises under the "Trade Name", if any, spec fied in Section A-I of the Basic Lease Provisions and shall use the Leased Premises solely for the" ennitted Uses" specified therein and for no other use or purpose whatsoever, Tenant shall not permit an business to be operated in or from the Leased Premises by any concessionaire or licensee without the rior consent of Owner. Section 5.02. Operation of Business. Tenant shall, subject to the provisions of Section 22.02, (i) open the Leased Pre ses by the date provided in Section 1.02 and thereafter continuously operate all of the Leased Premise in good faith during the term so as to produce the maximum profitable and practical Gross Receipts which may be produced by such manner of operation; and (ii) keep the Leased Premises open for busine s and the signs therefore lighted during such reasonable and customary lunch and dinner hours for an eat in/dine in restaurant. If Tenant defaults in respect to any of the foregoing covenants then T nant shall, in recognition of the difficulty or impossibility of determining Owner's damages, pay t Owner, upon demand, as liquidated damages (and not as a penalty) and in addition to the Annual Mini urn Rent and other charges payable under this Lease, a separate charge equal to 1/365 of the then app icable Annual Minimum Rent for each day, or part thereof, Tenant fails to open or operate the Leas d Premises in accordance with the provisions of this Section. 5.03. Radius Restriction. If Tenant or "Guarantor" (if any) or (if Tenant is not an individual or partnership) ny subsidiary or parent corporation of Tenant or Guarantor, or any affiliate of Tenant or Guarantor s all directly or indirectly engage or participate in, as owner, principal, employee or agent, or through any subsidiary, or affiliate, or furnish financial or other aid or support to, any business enterprise or unde king which is materially competitive with the uses specified in Section 5.01 of the Lease Agreement, an such business is located within 3 miles from any boundary line of the Shopping Center, then Owner shall ave the right, in recognition of the fact that the Annual Percentage Rent payable hereunder may be re uced by such competition, to require by notice to Tenant that 33 % of any and all gross sales ( hich shall be coextensive in scope to Gross Receipts as defined in this Lease) made at, in or from any s ch competing operation shall be deemed Gross Receipts for the purpose of computing the Annual Perce tage Rent due under this Lease, with the same force and effect as though such percentage of gross sale had actually been made in the Leased Premises and in such event the provisions of Article ill shall applicable to such competing operation and the gross sales received therein. 8 Section 5.04. Parking, Tenant and employees of Tenant shall park their automobiles in the side and r ar parking areas designated by Owner for employees. Owner shall provide appropriate lighting for said ea. In the event that Owner observes or becomes aware of a pattern of Tenant's employees parking in u authorized areas, Owner shall notify Tenant in writing. If Tenant's employees continue parking in suc areas after such written notice, Owner shall be entitled to tow improperly parked vehicles at the au omobile owner's expense and without further notice. ARTICLE VI - TAXES Section 6.01. Taxes. (A) The term "Taxes" shall mean the aggregate of the real estate taxes, asses ments and other governmental charges and levies, general and special, ordinary and extraordin , foreseen and unforeseen, of any kind or nature whatsoever (including assessments for public improve ents or benefits and interest on unpaid installments thereof) which may be levied, assessed or imposed or become liens upon the Shopping Center, or which arise out of the use, occupancy or possession of the hopping Center (land, buildings and permanent improvements) from time t6 time. The term "Taxes" sh 11 not, however, include inheritance, estate, succession, transfer, gift, franchise, corporation, income or pr fit tax imposed upon Owner, nor penalties imposed upon Owner for Owner's delinquent payment of the Taxes; PROVIDED, HOWEVER, that if at any time during the term of this Lease the met ods of taxation prevailing at the commencement of the term of this Lease shall be altered so that in addi ion to or in lieu of or as a substitute for the whole or any part of the Taxes now levied, assessed or impos d on real estate as such there shall be levied, assessed or imposed (i) a tax on the rents received fro - the Shopping Center; or (ii) a license fee measured by the rents receivable by Owner from the Shoppin Center; or (iii) a tax or license fee imposed upon Owner which is otherwise measured by or based in hole or in part upon the Shopping Center or any portion thereof, then such tax or fee shall be i eluded in the computation of Taxes, computed as if the amount of such tax or fee so payable were tha part due if the Shopping Center were the only property of Owner subject thereto. (B) The term "Tax Year" shall mean the 12 month period established as th year by the taxing authorities having jurisdiction over the Shopping Center. (C) The term "Tenant's Tax charge" shall mean an amount equal to the prod ct obtained by multiplying the sum of the Taxes for each Tax Year plus all costs, expenses and attome 'fees incurred by Owner in contesting any Taxes during such Tax Year (which Owner may do at its option) by "Tenant's Percentage Share" (hereinafter defined in Section 23.04) as of the date the Tax s for such Tax Year are assessed. For the Tax Year in which this Lease commences or terminates, Tena t's Tax Charge shall be prorated. (D) Tenant's Tax Charge shall be paid to Owner in monthly installments ( estimated by Owner) in advance on the first day of each calendar month during such Tax Year. Own r's estimate of Tenant's Tax Charge for the Tax Year in which this Lease commences is set forth in Sec ion A-I of the Basic Lease Provisions. Within 90 days after the end of each Tax Year, Owner shall de iver a copy to Tenant of all tax bills for such Tax Year and certify to Tenant the amount of Tenant's T Charge and Owner and Tenant shall then adjust any overpayment or underpayment by Tenant of Tena t's Tax Charge for such Tax Year. Any payment required in connection with an overpayment or underpa ment shall be due within thirty (30) days. Owner's failure to provide such information within the 90 d ys shall in no way excuse the Tenant from its obligations to pay any underpayment or constitute a wai er of Owner's right to bill and collect such underpayment from Tenant in accordance with this paragraph. 9 (E) Tenant s'haIl pay (or reimburse Owner upon demand if the same are levi d against Owner or the Shopping Center), before delinquency, any and all taxes, assessments, licens fees and public charges, of whatever kind or nature, levied or assessed during the term by any gove mental authority against Tenant's business in the Leased Premises and the fixtures, furniture, applianc s and any other personal property therein. (F) Owner shall have thesole,absolutellndmunrestrlcted right (but not t e obligation) to contest and/or compromise the validity or amount of any Tax by appropriate proceedin s. Owner shall have the right (but not the obligation), if permitted by law, to make installment yments of any assessments levied against the Shopping Center, and in such event, Tenant's share of th Taxes shall be computed upon the installments thereon paid by Owner in each Tax Year. ARTICLE vn - COST OF MAlNTENANCE AND CONTROL OF COMMON FACIL Section 7.01. Common Facilities Contribution. In each calendar year during the term, Tenant shall pay to Owner an amount (the "Common Facilities Contribution") equal to a proportion of the "Oper~ting Cost" (as defined in See ion 7.02) of the Common Facilities ("Tenant's Common Facilities Contribution"). Tenant's Co on Facilities Contribution for each calendar year during the term shall be that portion of the Operati g Cost for such calendar year equal to the product obtained by multiplying the Operating Cost for such alendar year by Tenant's Percentage Share (hereinafter defined in Section 23.04) as of the first day of suc calendar year. Section 7.02. Operating Cost and Common Facilities Defined. (A) The term "Operating Cost" shall mean the total cost (other than th cost properly chargeable to capital account, except as herein specifically provided) and expense incurr d in operating, maintaining, equipping, inspecting, protecting and repairing the Common Facilities, in luding without limitation, the cost or expense of, or incurred in connection with or reasonably attributabl to: water, gas, electricity and other utilities; gardening and landscaping (including planting and replaci g flowers and shrubs); cleaning; fire protection (including installation and maintenance of an ADT r similar type system); fees for required licenses; all Taxes levied, assessed or imposed or which may b come a lien on the Common Facilities or which may arise out of the use thereof and not otherwise coil cted elsewhere under the terms of this Lease; line painting; the repair and maintenance of the roof and mished ceiling (including lighting) of all Shopping Center canopies; operating of loudspeakers and 0 her eqwpment supplying music; sanitary control; security services (if any); sewer service charges; re oval of ice, snow, trash, rubbish, debris, garbage and other refuse (including ice and snow removal ediately in front of Tenant's storefront); depreciation on machinery and equipment used in suc maintenance; resurfacing and restriping of parking areas; repairing the roof of the Shopping Cent r; and on-site personnel to provide and supervise such services (including wages, unemployment and social security taxes and the cost of uniforms for such personnel); plus an amount equal to ten percent (1 %) of the total of all of the foregoing as an agreed upon reimbursement covering the administrative costs to be incurred by Owner in connection with the operation of the Common Facilities. (B) The term "Operating Cost" shall also include any municipal improveme ts required by the local municipality to be made to the Common Facilities including but not limited to affic signals, stop signs, and road repair. Tenant's Common Facility Contribution for any improvem nts or repairs required under this Section 7.02(B) shall be obtained by multiplying the cost of e municipal improvements or repairs made to the Common Facilities by Tenant's Percentage Share. (C) The term "Common Facilities" shall mean all areas, space, equipme t and special services in or serving the Shopping Center, provided for the common or joint use and hen fit of Owner, I 10 the occupants of the Shopping Center, and their employees, agents, servants, cust mers and other invitees, including, without limitation: any open pedestrian malls; parking areas and parking lot improvements; access roads; driveways; retaining walls; exterior boundary walls d fences; water, sanitary and storm sewer (including any off-site sewer lines which Owner is required 0 maintain), gas, electric, telephone and other utility lines, systems, conduits and facilities to the perim ter walls of any building (even though intended for the use of only one or a limited number of occu ants) and those within a building serving more than one premises, and any of the foregoing which se ve the Common Facilities; on or off-site water detention and retention ponds, facilities and syste s; on-site trash compactor; plantings; landscaped areas; truck service ways or tunnels; loading dock are s and facilities; the roof and finished ceiling (including lighting) of all Shopping Center canopies courts; ramps; sidewalks; comfort and first aid stations; washrooms; parcel pick-up stations; any Shopp ng Center pylon sign; drinking fountains; vertical transportation equipment (including elevators d escalators); auditoriums; community centers; bus stations; and the facilities appurtenant to eac and all of the foregoing. Section 7.03. Payment. (A) Tenant's Common Facilities Contribution shall be paid in monthly ins aIlments on the first day of each calendar month during the term in advance, in an amount reasonab y estimated by Owner. Owner's estimate of Tenant's Common Facilities Contribution for the calendar y ar in which this Lease commences is set forth in Section A-I of the Basic Lease Provisions. Within 90 d ys after the end of each calendar year during the term, Owner shall furnish Tenant with a statement s rnrnarizing the actual Operating Cost for such calendar year and setting forth the method by which .Ie ant's Common Facilities contribution was determined as herein provided, and Owner and Tenant shall then adjust any overpayment or underpayment by Tenant of Tenant's Common Facilities Contribution f r such calendar year with any resultant payment to be due within thirty (30) days. Owner's failure provide such statement within the 90 days shall in no way excuse Tenant from its obligations to pay an underpayment or constitute a waiver of Owner's obligations to bill and collect such underpayment rom Tenant in accordance with this Paragraph. Any claim by Tenant for revision of any statement sub 'tted by Owner hereunder for any such calendar year which is not made within 90 days after receipt of uch statement, shall be deemed waived and discharged. For the calendar year in which this Lease commences or terminates, Tenant's Common Facilities Contribution shall be prorated. (B) Any municipal improvements or repairs as contemplated in Section 7.02( ) shall be paid within thirty (30) days of Tenant's receipt from Owner of a payment statement. As uch municipal improvements are outside the control of the Owner, the Owner agrees to give Tenant rompt written notice of any municipal improvements or repairs upon Owner's receipt of such n tice from the municipality. Section 7.04. Control by Owner. Notwithstanding anything set out in this Lease to the contrary, it is agreed that ( ) all Common Facilities shall be subject to the exclusive control and management of Owner, and Owner ay permit the owners or occupants of land located outside the Shopping Center and their invitees to us the Common Facilities, provided such use does not unreasonably interfere with Tenant's or its custo r's use of the Leased Premises; (ii) Owner shall have the right to temporarily close all or any portion 0 the Common Facilities (including parking areas), provided, such closure does not unreasonably interfer with Tenant's or its customers' use of the Leased Premises; (iii) Owner shall be required to keep the parking areas lighted from dusk to dawn and not during any daylight hours, and (iv) Owner shall have the right to do and perform such other acts in and to the Common Facilities as Owner shall determine t be advisable with a view to the improvement of the convenience and use thereof by tenants of the Sh pping Center and their customers, including the right to permit, in Owner's sole discretion, pro tions in and 11 decorations of the sidewalks and parking areas; PROVIDED, HOWEVER, Owner s all maintain the Common Facilities in the Shopping Center in reasonably good order and repair, a d shall keep the parking area and other Common Facilities in the Shopping Center reasonably free f snow, ice and debris and adequately lighted, but these obligations shall not inure to the benefit of a y third party nor confer upon any third party any rights or remedies in the event of Owner's failure to perform such obligations. 1 ARTICLE vrn - ALTERATIONS; SIGNS; SURRENDER AND TENANT LIENS Section 8.01. Alterations. Tenant shall not make or cause to be made any alterations, additions or improve ents in or to the Leased Premises without submitting to Owner plans and specifications therefore and 0 taining Owner's consent thereto, which consent shall not be unreasonably withheld or delayed. Section 8.02. Surrender; Title to Improvements; Removal and Restoration by Tenant. (A) On the last day of the term or on the sooner tennination thereof, Tenant shall (i) subject to the provisions of Articles XVI and XVII, peaceably surrender the Leased Premises br om clean and in good order, condition and repair except for reasonable wear and tear; (ii) at its expense emove from the Leased Premises the signs, moveable furniture and trade fixtures (including, without Ii 'tation, molly- bolts, screws and other items inserted into the walls of the Leased Premises) which we e furnished and installed by Tenant at Tenant's sole expense ("Tenant's Property") and, if requested by 0 ner, remove, at Tenant's expense, the carpeting in the Leased Premises, and (iii) deliver to Owner a certificate of inspection from a reputable mechanical systems contractor that the heating, ventilating, ir conditioning, electrical and plumbing systems are in good order, condition and repair. Any damag to the Leased Premises caused by Tenant in the removal of Tenant's Property shall be repaired by Te ant at Tenant's expense (including, without limitation, the patching and sanding of molly-bolt holes a d other similar type holes in the walls of the Leased Premises). (B) Except for Tenant's property, the title to all alterations, additions, improv ments, repairs, decorations, non-trade fixtures, equipment (including heating and air conditioning quipment) and appurtenances attached to or built into the Leased Premises which shall have been ma e, furnished or installed by or at the expense of either Owner or Tenant in or upon the Leased Premis s shall become upon the installation thereof and remain a part of the Leased Premises without disturb nee or' charge, except that Owner may elect to require Tenant, at Tenant's expense, to remove any or all of such alterations, additions, improvements, non-trade fixtures, equipment, and/or appurtenanc s, and Tenant shall upon such removal restore the Leased Premises to good condition, subject to ord nary wear and tear. \ Section 8.03. Tenant's Liens. (A) Before Tenant permits any work, labor, services or materials to be pe formed for or furnished to the Leased Premises, Tenant shall require any party with whom Tenant contr cts to perform said work to Tenant or anyone holding all or any part of the Leased Premises under nant to file a stipulation against liens pursuant to ~ 1402 of the Pennsylvania Mechanics' Lien Law of 1963 (49 P.S. ~1401, et seq.). (B) Tenant shall not suffer any mechanics' or materialmen's lien to be fil d against the Leased Premises or the Shopping Center by reason of work, labor, services or material performed or furnished to Tenant or anyone holding all or any part of the Leased Premises under Tena 1. If any such 12 lien shall at any time be filed as aforesaid, Tenant may contest the same in good faith b t notwithstanding such contest, Tenant shall, within 15 days after the filing thereof, cause such lien to be eleased of record by payment, bond, order of a court of competent jurisdiction, or otherwise. In the event that Tenant fails to take the actions that are necessary to caus such lien to be released, then the Owner shall have the right to take whatever actions are necessary t have said liens released. In such event, Tenant agrees to reimburse the Owner for all costs incurre by the Owner, including attorneys' fees. A failure by the Tenant to reimburse the Owner these costs hall be a default by Tenant pursuant to Article XVID. (C) Tenant shall not create or suffer to be created a security interest or othe lien against imy improvements, additions or other construction made by Tenant in or to the Leased Pr mises or against any equipment or fixtures installed by Tenant therein (other than Tenant's Property). Section 8.04. Tenant's Signs. Tenant shall not install any sign, billboard, marquee, awning, placard, lette ing, advertising matter or other thing of any kind, whether permanent or temporary, on the exterio of the Leased Premises, or in or on any glass window, window showcase, :or door of the Leased Premis s until the same has been approved by the Owner in writing. Owner has the right to contra] the size, lac tion, design and materials of the same for the purpose of establishing and maintaining the appearance f the Shopping Center. Owner shall not unreasonably withhold or delay its approval of Tenant's sign(s). ARTICLE IX - MAINTENANCE OF LEASED PREMISES' RULES AND REGULATI Section 9.01. Maintenance by Tenant. Subject to the provisions of Articles XVI and XVII, Tenant shall, at its sole cost, keep and maintain the interior of the Leased Premises [together with exterior (i) feature lightin , (ii) windows, including sashes, (iii) heating, ventilating and air conditioning equipment and sewer nd other lines serving the Leased Premises exclusively, (iv) doors, including frames, locks, hardwar and track, (v) store front of the Leased Premises, and (vi) signs and other equipment referred to in Section 8.04], including without limitation, the partitions, ceiling, interior portions of exterior walls, floor covering therein, and the fixtures, equipment, machinery, appliances and utility lines therein an appurtenances thereof [such as, but not limited to, lighting fixtures and lenses and such fixtures, equip ent, mac,hinery controls, appliances and utility lines and appurtenances thereof, as are used for, in con ection with or which are a part of the electrical, plumbing, heating, air conditioning, ventilating, sprinkl r, or any other mechanical systems in or serving the Leased Premises], in conformity with all rules an regulations of Owner's hazard insurer, neat and clean and in good order, condition, maintenance and epair. Tenant shaH also at its cost procure and maintain in the Leased premises all safety applianc s required by Owner's hazard insurer to be maintained therein. Tenant shall replace any and all plat , window and other glass (structural or otherwise) in, on or about the Leased Premises, which rna be broken or destroyed, with glass of the same or similar quality. Before undertaking repairs to the Lased Premises (other than minor interior non-structural repairs), Tenant shall first obtain Owner's appro al of the plans and specifications therefore, which approval is not to be unreasonably withheld. Owner hall authorize one (1) heating and air conditioning contractor who shall provide a complete service an maintenance contract to Tenant who shall be the named party on the contract for the changing of tilte s at least once per month, the monthly inspection of the HV AC equipment serving the Leased Premis s, including a written report of the condition there of to be provided to Owner and Tenant, the periodi oiling of the equipment where required, the tightening of belts, the filling of pitch pans and the sealing f water leaks, among other things. The service and maintenance contract and its related costs shall be th sole cost and 13 expense of the Tenant; The existence of a service contract with an Owner approved vendor shall not relieve Tenant of its obligations to maintain and repair such equipment as above provide Section 9.02. Maintenance by Owner. Subject to the provisions of Articles XVI and xvn and to the obligations of enant under the provisions of Sections 9.01, the foundations, roof (excluding interior ceilings), and ext rior portions of the exterior walls (excluding store front) of the Leased Premises shall be maintained by Owner at its expense in good order, condition, maintenance and repair. Owner shall not be deemed 0 have breached its obligation to make the repairs required of Owner as set forth in this Section, or to e liable for any damages resulting therefrom, unless Owner fails to make the same within a reasonable p . od (taking into consideration the type of repair involved) after receiving notice from Tenant of the need erefore. Section 9.03. Rules and Regulations. Tenant agrees to comply with and observe the rules and regulations set fort in Exhibit C. Owner reserves the right, at any time, once or more often, by notice to Tenant, to amen or supplement said rules and regulations in a reasonable and non-discriminatory manner. ARTICLE X - INSURANCE AND INDEMNITY Section 10.01. Liability Insurance. Tenant shall keep in force with an insurance company authorized to do busines in the State in which the Leased Premises are located and which has a Best's Insurance Guide Raing of A+:XV ("Qualified Carrier"), a policy of comprehensive public liability insurance, including pr perty damage, with respect to the Leased Premises and the business operated by Tenant and any other ccupant of the Leased Premises, in which the limits of coverage shall not be less than $3,000,000.00 (c mbined single limit bodily injury and property damage). Such policy shall also insure the performance b Tenant of the indemnity agreement set forth in Section 10.04. In addition to Tenant, the policy shall al 0 name Owner and any other person, firm or corporation designated by Owner and in privity with it, an additional insured. Tenant shall continually provide Owner with a certificate of such insurance (th first of which shall be provided prior to commencement of Tenant's Work), which shall provide that t e insurer will give Owner at least 30 days' written notice prior to any cancellation of, lapse or materia change in the insurance. The insurance required in this Section and in Section 10.02 may be covered u der a so-called "blanket" policy covering other stores of Tenant and its affiliates. Section 10.02. Fire Insurance. Tenant shall keep in force with a Qualified Carrier fire insurance (with extende coverage and vandalism and malicious mischief coverage), water damage, sprinkler leakage and plate g ass, insurance, on the standard forms, insuring all of Tenant's Property in the Leased Premises, and a 1 betterments, additions, repairs, imprclVements and alterations made to the Leased Premises by Tenan , and all plate glass windows, plate glass doors and other plate glass in the Leased Premises, in an a ount equal to 100% of the replacement cost thereof. The proceeds of such insurance shall be held in st by Owner and Tenant for use in repairing and restoring the items covered thereby and the proceeds shall be made payable to Owner and Tenant and may only be disbursed jointly by Owner and Tenant. he foregoing policy of insurance shall be issued in favor of and in the names of Owner and Tenant, as their interests may appear, and Tenant shall furnish Owner and the holder of any mortgage on the Leased Premises with a certificate evidencing such coverage, which certificate shall provide that the insuranc shall not be canceled, materially amended or allowed to lapse without thirty (30) days' prior written otice thereof being given by the insurance carrier to Owner. 14 15 - Section 10.03. Insurance on Buildings and Improvements in the Shopping Center. (A) In each calendar year during the term, Tenant shall pay to Owner an amount (the "Tenant's Insurance Contribution") equal to a proportion of the "Insurance Cost" (as de ned in paragraph (B) of this Section). Tenant's Insurance Contribution for each calendar year during the erm shall be that portion of the Insurance Costs for such calendar year equal to the product obtained b multiplying the Insurance Cost for such calendar year by Tenant's Percentage Share (hereinafter d fined in Section 23.04) as of the first day of such calendar year. (B) The term "Insurance Cost" shall mean the total cost of insuring t e buildings and improvements in the Shopping Center (including Common Facilities), including public liability, (including "umbrella coverage"), workmen's compensation and hazard insurance (inclu ing rental value insurance, fire and extended coverage [with vandalism and malicious mischief endorse ent]; boiler and machinery, and all-risk policies). (C) Tenant's Insurance Contribution shall be paid in monthly installments 0 each calendar month during the term in advance, in an amount reasonably estimated by estimate of Tenant's Insurance Contribution for the calendar year in which this Lease c mmences is set forth in Section A-I of the Basic Lease Provisions. Within 90 days after the end of ea h calendar year during the term, Owner shall furnish Tenant with a statement summarizing the actual In urance Cost for such calendar year and setting forth the method by which Tenant's Insurance C ntribution was determined as herein provided and Owner and Tenant shall then adjust any verpayment or underpayment by Tenant of Tenant's Insurance Contribution for such calendar year wi h any resultant payment to be due within thirty (30) days. Any claim by Tenant for revision of any stat ment submitted by Owner hereunder for any such calendar year, which claim is not made within 90 day after receipt of such statement, shall be deemed waived and discharged. For the calendar year in w ich this Lease commences or terminates, Tenant's illsurance Contribution shall be prorated, if applicable on the basis of a 360-day year. (D) Tenant shall provide Owner on an annual basis with proof of all insuranc shall provide that the insurer will give the Owner at least 30 days' written notice prior to of, lapse of or material change in the insurance. policies which y cancellation Section 10.04. Business Liability Insurance. Tenant shall keep in force with a Quali led Carrier, a policy to cover business liability, including premises operations liability and busin ss inteITUption liability, in which the limits of coverage shall not be less than $1,000,000.00, single limit ill addition to Tenant, the policy shall name Owner as an additional insured. Tenant shall continually provide Owner with a certificate of such insurance, which shall provide that the insurer will give the 0 ner at least 30 days' written notice prior to any cancellation of, lapse or material change in the insurance. Section 10,05. Indemnification. Tenant will, subject to the provisions of Section 10.06, indemnify, save harml ss and defend Owner and its officers, agents and servants, from and against any and all claims, actio , liability and expense in connection with loss of life, bodily injury and/or damage to property arising from or out of any occurrence in, upon or at the Leased Premises, or the occupancy or use by Ten nt, its agents, employees, servants, subtenants, licensees or concessionaires, of the Leased Premises or y part thereof, or outside the Leased Premises which is occasioned wholly or in part by any willful or gligent act or omission of Tenant, its agents, employees, servants, subtenants, licensees or concess~on es, unless the same be caused by the willful or negligent act or omission of Owner, its agents, employees or servants. 16 Section 10.06. Waiver df Subrogation: Limitation ofLiabilitv. (A) Anything in this Lease to the contrary notwithstanding, it is agreed th t each party (the "Releasing Party") hereby releases the other (the "Released Party") from any liability w 'cb the Released Party would, but for this Section 10.05, have had to the Releasing Party during the te of this Lease, resulting from the occurrence of any accident or occurrence or casualty (i) which is or ould be covered by an "all-risk" policy (irrespective of whether such coverage is being carried by the Re easing Party), or (ii) covered by any other casualty or property damage insurance being carried by the R leasing Party at the time of such occurrence, which accident, occurrence or casualty may have resulted in whole or in part from any act or neglect of the Released Party, its officers, agents or employe s; PROVIDED, HOWEVER, the release hereinabove set forth shall become inoperative and null nd void if the Releasing Party wishes to place the appropriate insurance with an insurance company w ich (a) takes the position that the existence of such release vitiates or would adversely affect any polic so insuring the Releasing Party in a substantial manner and notice thereof is given to the Released Part , or (b) requires the payment of a higher premium by reason of the existence of such release, unless in t e latter case the Released Party within 10 days after notice thereof from the Releasing Party pays s ch increase in premIUm. (B) Anything in this Lease to the contrary notWithstanding, it is agreed tha neither Tenant nor Owner shall be liable to the other for any damage arising from the willful or egligent act or omission of any other tenant or occupant of the Shopping Center. Section 10.07. Notice bv Tenant. Tenant shall within 24 hours after the occurrence of any casualty damage to or ccidents in the Leased Premises, give Owner notice of such casualty damage or accident. ARTICLE XI - UTILITIES Secti on 11. 0 1. Utili tv Charges. Tenant shall contract in its own name for and promptly pay all charges for electri ity, gas, water, sewer, telephone and any other utility used or consumed in the Leased Premises to the con ern furnishing the same. In the event that separate service arrangements cannot be provided for any of he above, then the Tenant agrees to pay their proportionate share of the utility charges which shall be coIl cted as part of the Common Facilities Contribution set forth in Article VII herein. Section 11.02. Owner's Liabilitv for Interruption. Owner shall not be liable in any way to Tenant or to any other party occupying ny part of the Leased Premises for any failure or defect in or of any utility service furnished to the Leas d Premises or the Common Facilities, by reason of any requirement, act or omission of the public u ility company serving the Shopping Center with electricity, water or other utility service, or becaus of necessary repairs or improvements, or by reason of any cause referred to in Section 23.02. 17 ARTICLE XII - ESTOPPEL CERTIFICATE' ATTORNMENT- PRIORITY OF LEA E' RIGIITS OF MORTGAGEE Section 12.01. Estop{Jel Certificate. Tenant agrees, within 10 days after written request by Owner, to execute, a knowledge and deliver to and in favor of any proposed mortgagee or purchaser of the Shopping Ce reF, an estoppel certificate, in the form customarily used by such proposed mortgagee or purchaser, evid ncing the status of performance under this Lease and the terms of this Lease. Tenant agrees, within 10 ys after written request by Owner, to deliver to Owner a current financial statement of Tenant, duly certified by an officer thereof (if Tenant is a corporation) and an independent certified public accounta t and such other financial information of Tenant as Owner shall reasonably request; provided, that the c nfidentiality of such information is maintained in accordance with Section 3.01. Section 12.02. Attornment. Tenant shall, in the event any proceedings are brought for the foreclosure of, 0 in the event of the exercise of the power of sale under, any mortgage made by Owner covering any part f the Shopping Center, or in the event of any sale of the Shopping Center, attorn to the purchaser upon any such foreclosure or sale and recognize such purchaser as Owner under this Lease. Upon th request of any interested party, Tenant shall execute, acknowledge and deliver an instrument, in fa and substance satisfactory to such party, evidencing the attornment provided for in this Section if, a d only if, such party acknowledges in such instrument, and agrees to be abide by, such party's obligati os as "Owner" under this Lease, and agrees therein (i) to recognize and abide by Tenant's rights unde this Lease and (ii) not to disturb Tenant's use or occupancy of the Leased Premises. Section 12.03. Priority of Lease. Upon written request of the holder of any first mortgage now or hereafter cove 'ng any part of the Shopping Center, Tenant will subordinate its rights under this Lease or make this Lea e prior in right and priority to the lien thereof and to all advances made or hereafter to be made up n the security thereof, and Tenant shall, within ten (10) days after written demand therefore, execute, acknowledge and deliver an instrument, in the form customarily used by such encumbrance holder, effectin such priority; PROVIDED, HOWEVER, at the option of the holder of such mortgage, such holder sh 1 be entitled to effect such priority by filing a unilateral declaration to that effect with the recorder of dee in the County and State in which the Leased Premises is located. Section 12.04. Rights of Owner's Mortgagee. Within 10 days after demand by the holder of any mortgage covering all or y part of the Shopping Center, Tenant shall execute, acknowledge and deliver an agreement in favo of and in the form customarily used by such encumbrance holder, by the terms of which Tenant wi! agree to give prompt notice to such encumbrance holder in the event of any casualty damage to the Leas d Premises or in the event of any default on the part of Owner under this Lease, and will agree to allow such encumbrance holder a reasonable length of time (taking into consideration for the purpose f determining such permitted length of time any delays encountered by reason of any of the causes referred to in Section 23.02), after notice to cure or cause the curing of such default before exercising Te ant's rights of self-help under this Lease, if any, or terminating or declaring a default under this Leas . In addition, within 10 days after demand by the holder of any such mortgage or after demand by owne , Tenant shall deliver to such encumbrance holder a current financial statement of Tenant and such ther financial information as such holder or Owner shall reasonably request; provided, that the confide tiality of such information is maintained in accordance with Section 3.01. 18 ARTICLE xm - ASSIGNMENT, SUBLETTING AND CORPORATE OWNERSHIP Section 13.01. Consent Required. (A) Tenant shall not voluntarily, involuntarily or by operatiopof law assign rencumber this Lease, in whole orIn part, nor sublet all or any part of the Leased Premises without the prior consent of Owner in each instance. Notwithstanding any assignment or subletting, Tenant shall re ain fully liable under this Lease and shall not be relieved from performing any of its obligations h reunder. As a condition to any assignment of this Lease by Tenant, which is permitted under this Le se, the assignee thereof shall be required to execute and deliver to Owner an agreement in recordable fo , whereby such assignee assumes and agrees with Owner to discharge all obligations of Tenant under this Lease. (B) If Tenant shall request Owner's consent to an assignment of this Lease nd Qwner shall consent thereto, the assignee ("Assignee") shall pay directly to Owner, as additional re t hereunder, at such times as the Assignee shall have agreed to pay Tenant, an amount equal to any c nsideration the Assignee shall have agreed ~o pay Tenant on account of such assignment. If Assignee hall fail to pay Owner any such consideration when due, such failure shan constitute a default under this ease. (C) If Tenant shall request Owner's consent to a subletting of the Leased Pre ses or any part thereof and Owner shall consent thereto, Tenant shall pay Owner, as additional rent, in addition to the Annual Minimum Rent and other charges payable hereunder, an amount equal to any co sideration paid by the subtenant to Tenant in excess of (i) the Annual Minimum Rent and other c arges payable hereunder if all of the Leased Premises are so sublet or (ii) if less than all of the Leased remises are so sublet, the Annual Minimum Rent and other charges payable hereunder allocable to th portion of the Leased Premises so sublet based on the number of square feet of Gross Leasable Are in the Leased Premises so sublet divided by the total number of square feet of Gross Leasable Area in the Leased Premises prior to such subletting. The foregoing amount shan be determined monthly and aid by Tenant to Owner on the first day of each calendar month in advance during the term of such subl ase. If Tenant shall fail to pay Owner any such consideration, such failure shall be a default under this Lase. Section 13.02. Corporate Ownership. If at any time during the term a cumulative total of more than 49% of the voting tack of, Tenant (if Tenant shall be a corporation) shall be transferred, directly or indirectly, by sale, assign ent, gift or in any other manner, any such transfer shall, unless made with Owner's prior consent (whi h shall not be unreasonably withheld or delayed), be deemed an unauthorized assignment of this Lease a d a default by Tenant under this Lease. Section 13.03. Owner's Rilrht to Assign. If Owner conveys or transfers its interest in this Shopping Center or in this lease which sale or transfer may be effected without Tenant's consent), upon such conveyance or transfer, Ower (and in the case of any subsequent conveyances or transfers, the then grantor or transferor) shall be r leased of and from all liability with respect to the performance of any covenants and obligations on the art of Owner to be performed after the date of such conveyance or transfer; it being intended hereby that the covenants and obligations on the part of Owner to be performed under this Lease shall, subject to th provisions of Section 21.01, be binding on Owner, its successors and assigns, only during and in r spect of their respective periods of ownership of an interest in the Shopping Center or in this Lease. 19 ARTICLE XIV - WASTE: HAZARDOUS WASTE' GOVERNMENTAL REGULATIONS Section l4.01. Waste or Nuisance. INSURANCE Tenant shall not commit or suffer to be committed (i) any waste in or upon the eased Premises un <:lrjii) _~T?-), nuisance or:my otheL act or thing (W_Qelhcr-.a_mJisance -.Or otherwise~hicbma}'-disturb the quiet enjoyment of any other tenant or occupant in the Shopping Center or its or their cu tamers or other invitees. Section 14.02. Hazardous Waste. (A) Tenant hereby covenants, represents and warrants that it shall not generate, ansport, handle, store or otherwise encounter in, on or about the Real Property, any hazardous waste 0 substance (for purposes of this Section herein called "hazardous waste") as defined by the applicable eder_al, state or local environmental or occupational standards, including but not limited to material defin d as such in, or for purposes of, the Comprehensive Environmental Response, Compensation and Liabilit Act of 1980 ("CERCLA"), as amended by the Superfund Hazardous Materials Transportation Act (4 US.c. 91802 et seq.), the Resource Conservation and Recovery Act ("ReRA") (42 U.S.c. 91802, et s .), the Federal Water Pollution Control Act (33 U.S.C. S1251, et gm.), the Safe Drinking Water Act (42 US.c. g300(t), et gg.), the Toxic Substance Control Act (15 D.S.C. g2601, et gm.), the Clean Air Act ( 2 US.C g7401, et ~.), or any other federal, state or local statute, ordinance, code, rule, regulation, rder or decree regulating, relating to or imposing liability or standards of conduct concerning any haz dous, toxic or dangerous waste, substance, element or material as now or at any time hereafter in effect r amended (for purposes of this Section herein collectively called the "Laws"), Tenant further covenants represents and warrants that there will be no underground storage tanks in, on, under, within or about the eal Property. (B) Tenant shall not use, store or permit to be stored on the Leased Premises ny asbestos in any form, urea formaldehyde foam insulation, transformers or other equipment which co tains dielectric fluid or other fluids containing levels of polychlorinated biphenyls in excess of fifty (50) parts per million. If Tenant shall utilize the Leased Premises for medical office purposes, Tenant hall dispose of all syringes, blood products, "sharps", medical instruments and all other types of medical aste in a safe, clean, sanitary manner and in accordance with all applicable laws and regulations. (C) Tenant covenants, represents and warrants that it will indemnify and hold Landlord hannless from and against any and all liability , actions, claims, losses, damages and expe ses arising out of, or in any way relating to, a breach of the representations, warranties, covenants and greements set forth in this Section, including: (a) claims of third parties (including governmental agencies) for damages, including personal injury or property damages, penalties, response costs, inju ctive or other relief; (b) costs or removal and restoration, including fees of attorneys and experts, costs f reporting to any governmental agency the existence of hazardous substances, hazardous waste, po lutants and/or contaminants and costs of preparing or causing to be prepared any and all studies, tes s, analyses or reports in connection with any environmental matter; (c) all expenses or obligations, indu ing attorneys' fees, incurred at, before and after any trial or appeal therefrom whether or not taxable as c sts. including attorneys' fees, witness fees, deposition costs and other expenses; (d) all other costs, expenses and liabilities arising from Tenant's violation of the laws or any other environmental regulatio now in force or hereafter enacted; and (e) Tenant's disposal of medical waste as set forth in paragraph ( ) above. The obligations of Tenant as contained in this Section shall survive the termination of the Leas . 20 Section 14.03. Governmental and Insurance Regulations. Tenant shall, at Tenant's sole cost, comply with all of the requirements of 11 governmental authorities (including without limitation those requiring replacements, additions, repair and alterations, [structural or otherwise]), and with all directions, rules, regulations and recommenda ions of Owner's hazard insurer, now in force, or which may hereafter be in force, pertaining t6 (i) the eased Premises, (ii) all of Tenant's Property in the Leased Premises and (iii) the use_aIld_9_<:~pan~ of the J"~_<lsed ----pfemises.~- - - ---- ---.. ---------- ARTICLE XV - MERCHANTS ASSOCIATION lNTENTIONALL Y OMITTED ARTICLE XVI - DESTRUCTION Section 16.01. Destruction of Leased Premises (A) If the Leased Premises are damaged or destroyed by fire or other ca ualty insurable under standard fire and extended coverage insurance so as to become partially or totally ntenantable, the same, unless this Lease is terminated as provided in paragraph (B), shall be repaired d restored by Owner and Tenant with due diligence, and during such restoration period, the Annual Minimum Rent (but not the Annual Percentage Rent) and other charges payable hereunder shall equita ly abate to the extent the Leased Premises are materially affected thereby. Owner's obligation under tho paragraph (A) to repair and restore shall be limited to the repair and restoration of those parts of the eased Premises which were originally constructed and or installed by Owner at its expense including b t not limited to Owner's Work set forth in Exhibit B. All other repair and restoration shall be the resp nsibility and at the expense of the Tenant. (B) If the Leased Premises are damaged or destroyed to the extent the cos of restoration thereof would exceed 15% of the amount it would have cost to replace the Leased Premis s in its entirety at the time such damage or destruction occurred, then either party may elect to terminat this Lease by giving notice to the other party of its election to do so within 30 days after such occu ence. If either party exercises its right to terminate this Lease, then this Lease shall cease, effective a of the date of such damage or destruction, and all rent and other charges payable by Tenant shall be adjusted as of that date. Section 16.02. Destruction of Shopping: Center. Notwithstanding anything to the contrary set forth in Section 16.01, in the e ent all or any portion of the Shopping Center shall be damaged or destroyed by fire or other cause ( otwithstanding that the Leased Premises may be unaffected thereby), to the extent the cost of restoratio thereof would exceed 25% of the amount it would have cost to replace the Shopping Center in its ent" ety at the time such damage or destruction occurred, then either party may terminate this Lease by givin 30 days' prior notice to the other party of it's election so to do, which notice shall be given, if at all, ithin 90 days following the date of such occurrence. In the event of the termination of this Lease as aforesaid, this Lease shall cease 30 days after such notice is given, and the rent and other charges her under shall be adjusted as of that date. ARTICLE XVII - EMINENT DOMAIN Section 17.01. Condemnation of Leased Premises. 21 In the event of, any condemnation or conveyance in lieu thereof of the Lease Premises or the Shopping Center, or both, whether whole or partial, either party may terminate this ease, and in any event, Tenant shall have no claim against Owner or the condemning authority for he value of the unexpired term, and Tenant shall not be entitled to any part of the compensation or aw d. whether paid as compensation for diminution in value to the leasehold or to the fee of the Leased Pre . ses, and Owner shall receive the full amount thereof, Tenant hereby waiving any right to any part ther f and assigning to Owner its interest therein. ARTICLE XVIII - TENANT'S DEFAULT; AND SECURITY DEPOSIT Section 18.01. Default by Tenant If the Annual Minimum Rent, Annual Percentage Rent, additional rent, or yother charge payable by Tenant under this Lease shall be unpaid on the date payment is required by e terms hereof and shall remain so for a period of 5 days after Owner gives Tenant notice of such defa It, or if Tenant fails to perform any of the other terms, conditions, covenants and obligations of this Leas to be observed and performed by Tenant for more than 21 days after Owner gives Tenant notice of such efault (it being agreed that a default, other than the failure to pay money, which is of such a character at rectification thereof reasonably requires longer than said 21 day period: and completes the same wit due diligence), or if Tenant shall vacate or abandon the Leased Premises (it being agreed that, subject t the provisions of Articles XVI and XVII and to Section 23.02, Tenant's failure to operate its busines in the Leased Premises for seven consecutive days or more shall conclusively be deemed an abando ment) or suffer this Lease to be taken under any writ of execution, attachment or other process of law, or if this Lease shall by operation of law devolve upon or pass to any other party other than a party, i any, to whom Tenant is authorized to assign this Lease by the provisions of Section 13.01, or if an "Act of Bankruptcy" (as defined in Section 18.02) shall occur, or if Owner shall have notified Tenant of Tenan 's default three (3) or more times in any twelve calendar month period, then, in any of such events, 0 ner shall have, besides its other rights or remedies, the following immediate rights: (1) At its option, to terminate this Lease and the term hereby created without ny right on the part of Tenant to waive the forfeiture by payment of any sum due or by other perla ce of any condition, term or covenant broken, whereupon Owner shall be entitled to recover, in add'tion to any and all sums and damages for violation of Tenant's obligations hereunder in existence at t time of such termination, damages for Tenant's default in an amount equal to the amount of the rent r served for the balance of the term of this Lease, as well as all other charges, payments, costs and e penses herein agreed to be paid by Tenant, all discounted at the rate of six percent (6%) per annum to th ir then 'present worth, less the fair rental value of the Premises for the remainder of said term, also discou ted at the rate of six percent (6%) per annum to its then present worth, all of which amount shall be i ediately due and payable from Tenant to Owner. (2) At its option, by notice to Tenant, to re-enter and take possession of the Lased Premises without terminating this Lease. No re-entry or taking possession of the Leased Pre ses by Owner pursuant to this clause (2) shall be construed as an election on its part to terminate this ease unless a notice of such intention is given to Tenant (all other demands and notices of forfeiture 0 other similar notices being hereby expressly waived by Tenant). (3) At its option, to require that upon (i) any termination of this Lease, whet er by lapse of time or by the exercise of any option by Ow"ner to terminate the same or in any other mann r whatsoever, or (ii) any termination of Tenant's right to possession without termination of this Leas . Tenant shall immediately surrender possession of the Leased Premises to Owner and immediately va ate the same, and remove all effects therefrom. except such as may not be removed under other pro isions of this Lease. 22 (4) At its option, to make such alterations and repairs as Owner shall d termine may be reasonably necessary to relet the Leased Premises, and to relet the same or any part ther of for such term or terms (which may be for a term extending beyond the term of this Lease) and upo such terms and conditions as Owner in its sole discretion may deem advisable. Upon each reletting, al rentals received by owner from such reletting shall be applied as follows: first, to the payment of any in ebtedness other than rentor other charges due under this Lease from Tenant to Owner; secondto ~~e paY~t?~~?fany reasuna:ble-custrand -expenses of sUCh releTting, lriCIuamg-Erokerage- fees andattorneys' ees and costs of such alterations and repairs, each of which fees and costs shall be reasonable in amount; and third, to the payment of rent and other charges due and unpaid hereunder. In no event shall Ten t be entitled to receive any surplus of any sums received by Owner on a reletting in excess of the ental and other charges payable hereunder. If such rentals and other charges received from such rele ting during any month are less than those to be paid during that month by Tenant hereunder, Tenant sh 11 pay any such deficiency to Owner (notwithstanding the fact that Owner may have received rental 'n excess of the rental and other charges payable hereunder in previous or subsequent months), such eficiency to be calculated and payable monthly. Notwithstanding any reletting without termination, 0 ner!naY at any time thereafter elect to terminate this Lease for such previous breach in the manner rovided in this Section. (5) If Tenant shall default in the payment of the rent herein reserved or the payment of any other sums due hereunder by Tenant, Tenant hereby authorizes and mpowers any Prothonotary or attorney of any court of record to appear for Tenant in any and al actions which may be brought for said rent and/or said other sums; and/or to sign for Tenant an agreement for entering in any competent court an amicable action or actions for the recovery of said rental and/or other sums; and in said suits or in said amicable action or actions to co. fess judgment against Tenant for all or any part of said rental and/or said other sums, including ut not limited to the amounts due from Tenant to Owner under subparagraphs (1), (2), (3) an or (4) of the' Paragraph; and for interest and costs, together with any attorneys' commission f: r collection of ten percent (10%). Such authority shall not be exhausted by one exercise thereof, but judgment may be confessed as aforesaid from time to time as often as any of said rental an or other sums shall fall due or be in arrears, and such powers may be exercised as well after the e iration of the initial term of this Lease and/or during any extended or renewal term of his Lease a dlor after the expiration of any extended or renewal term of this Lease. 'J l (6) When this Lease and the term of any extension or renewal thereof s all have been tenninated on account of any default by Tenant hereunder, and also when the tenn ere by created or any extension or renewal thereof shall have expired, it shall be lawful for any a tarney of any court of record to appear as attorney for Tenant as well as for all persons claiming y, through or under Tenant, and to sign an agreement for entering in any competent court an ami able action in ejectment against Tenant and all persons claiming by, through or under Te and therein confess judgment for the recovery by Owner of possession of the Premises, for wh ch this Lease shall be his sufficient warrant; thereupon, if Owner so desires, an appropriate wri of possession may issue forthwith, without any prior writ or proceeding whatsoever, and provided hat if for any reason after such action shall have been commenced it shall be determined that po session of the Premises remain in or be restored to Tenant, Owner shall have the right for the sa e default and upon any subsequent default or defaults, or upon the tennination of this Lease or Te nt's right of possession as hereinbefore set forth, to bring one or more further amicable action or actions as hereinbefore set forth to recover possession of the Premises ~nd c,\nfess judgment fo the recovery of possession of the Premises as hereinbefore provided. 0.. W 'T'1 ( enant) 23 (7) In any amicable action of ejectment and/or for rent and/or othe sums brought hereon, Owner shall first cause to be fIled in such action an affidavit made by Ower or someone acting for Owner, setting forth the facts necessary to authorize the entry of jud ent, of which facts such affidavit shall be prima facie evidence, and if a true copy of this Lease ( nd of the truth of the copy such affidavit shall be sufficient evidence) shall be filed in such suit, acti nor actions, it ~:~~';\~h:e;::~y,:~~=:,:~:';.l as a ~nt of attorney' any ~_or C nrt,_cnst-"Dlor (8) At its option, to collect from Tenant any other loss or damage which 0 by reason of any breach and any diminished value of the Leased Premises resulting from Tenant wjj:- any "otice to quit reqnired by any law now in force of ber after enacted. i~' , - ~-c Tenanfj Nothing in this Section shall be deemed to limit Owner's rights and remedies i the event of a default by Tenant, and the Owner's rights and remedies set forth in this Lease shall b in addition to those available to Owner at law or in equity. Section 18.02. Bankruptcy. (A) If at any time prior to or after the commencement of the term of this Leas there shall be filed by Tenant or Guarantor, in any court pursuant to any statute either of the United tates or of any State, a petition in bankruptcy (including, without limitation, a petition for liquidation, re rganization or for adjustment of debts of an individual with regular income), or if any case, proceeding or other action shall be commenced seeking to have an order for relief entered against Tenant or Guarant as a debtor in bankruptcy proceedings or to adjudicate Tenant or Guarantor a bankrupt or insolve t, or seeking reorganization, arrangement, adjustment, liquidation, dissolution or composition of it or i s debts under any law relating to bankruptcy, insolvency, reorganization or relief of debtors, or seeking ppointment of a receiver, trustee, custodian or other similar official for it or for all or any substantial part f its property, and such case, proceeding or other action results in the entry of an order for relief or is not dismissed within 30 days of the filing thereof, or if Tenant or Guarantor becomes insolvent or i generally not paying or admits in writing its inability to pay its debts as they mature, or makes an assi ent for the benefit of creditors or petitions for or enters into an arrangement with its creditors or a custodian is appointed or takes possession of Tenant's or Guarantor's property (whether or not a judi ial proceeding is instituted in connection with such arrangement or in connection with the appoin ent of such custodian), or if Tenant or Guarantor shall take any action to authorize or in contemplatio of any of the events set forth above (each of the foregoing events to be hereinafter referred to s an "Act of Bankruptcy"), then, in addition to Owner's other rights and remedies under this Lease d applicable law, this Lease shall, at Owner's option (and if permitted by law), be terminated, in whic event neither Tenant nor Guarantor, nor any person claiming through or under Tenant or Guarantor or b virtue of any statute or of an order of any court, shall be entitled to possession of the Leased Premises, nd Owner, in addition to the other rights and remedies given by this Lease, or by virtue of any statute r rule of law, may retain as liquidated damages any rent, Security Deposit or moneys received by Own r from Tenant or others in behalf of Tenant. All rent, additional rent and other charges payable by Te ant under this Lease shall constitute rent for the purpose of applying the provisions of Section 502(b)(7) of the Federal Bankruptcy Code. (B) In the event an act of bankruptcy shall occur and this Lease is not terminat d pursuant to the provisions of paragraph (A), the parties agree that: 24 (i) If there shall be a default in the payment of nual Minimum Rent or any additional rent, or a default in the observance or pe ormance of any other provision of this Lease binding on Tenant, Owner sh 11 be entitled to immediately discontinue furnishing any utilities and other se ices it has been providing to the Leased Premises, until such time as such de aults have been fully cured, it being agreed that the foregoing action by Owne sball in no way ________---Cause..or-result-in-al1.y-a.eate-mBnt-ef-Anuual--M-iuimum-Rent-o y-othercharge payable by Tenant during the continuance of the term of this Le se. (ii) If the Lease is assumed by a trustee in bankrupt y, and assigned by the trustee to a third party, then such party shall (a) execu and deliver to Owner an agreement in recordable form whereby such party co firms that it has assumed and agrees with Owner to discharge all obligations (in luding, without limitation, the provisions of Article VI respecting the Permi ted Use of the Leased Premises and the manner of operation thereat) binding n Tenant under this Lease, (b) represent and warrant in writing to Owner that uch party has a net worth and operating experience at least comparable to th t possessed by Tenant named herein and Guarantor as of the execution of this Lase, (c) deposit with Owner a Security Deposit and advance rent equal to that in tially deposited by Tenant named herein, and (d) grant Owner, to secure the perl rmance of such party's obligations under this Lease, a security interest' such party's merchandise, inventory, personal property, fixtures, furnishings, nd all accounts receivable (and in the proceeds of all of the foregoing) wit respect to its operations in the Leased Premises, and in connection therewith, uch party shall execute such security agreements, fmancing statements and other documents (the forms of which are to be designated by Owner) as are necessary 0 perfect such lien. (iii) Lease shall be deemed a lease of "Nonresidential Real Property" within a "Shopping Center" for the purpose of Section 365 f the Federal Bankruptcy Code. (C) Any person or entity to which this Lease is assigned pursuant to the pr visions of the Bankruptcy Code, 11 U.S.C. Section 101, et seq. (the "Bankruptcy Code") shall be d emed without further act or deed to have assumed all of the obligations arising under this Lease on and fter thedate of such assignment. If this Lease is assigned to any person or entity pursuant to the pr visions of the Bankruptcy Code, any and all monies or other considerations payable or otherwise to delivered in connection with such assignment shall be paid or delivered to Owner, shall be and remai the exclusive property of Owner and shall not constitute property of Tenant or of the estate of Te ant within the meaning of the Bankruptcy Code. Any and all monies or other considerations consti ting Owner's property under the preceding sentence not paid or delivered to Owner shall be held in trust for the benefit of Owner and be promptly paid or delivered to Owner. 25 Section 18.03. Owner's Right to Cure Defaults. If Tenant fails to perform any agreement or obligation on its part to be perf rmed under this Lease, Owner shall have the right (i) if no emergency exists, to perform the same afte giving 15 days' notice to Tenant; and (ii) in any emergency situation, to perform the same immediately ithout notice or delay. For the purpose of rectifying Tenant's defaults as aforesaid, Owner shall have he right to enter the Leased Prerni ses.-Jenant-shal1.,oo--clemand,-reime-urse-Bwner-f-orthe-costs-ami-e incurred 5y Owner in rectifying Tenant's defaults as aforesaid, including reasonable attorneys' fees. Owner shall not be liable or in any way responsible for any loss, inconvenience, annoyance, or da ge resulting to Tenant or anyone holding under Tenant for any action taken by Owner pursuant to this S ction. Section 18.04. Security De-posit. (A) Tenant, contemporaneously with the execution of this Lease, has depos ted with Owner the sum designated as the "Security Deposit" in A-I of the Basic Lease Provisions, rec ipt of which is hereby acknowledged. The Security Deposit shall be held by Owner, without liabilit for interest, as security for the faithful performance by Tenant of all of the terms, covenants and eonditi ns of this Lease by Tenant to be performed. Owner shall not be required to hold the Security Deposit as separate fund, but may commingle it with other funds. If after the execution of this Lease Agreem t and Owner's receipt of the Security Deposit, Tenant would fail to commence under the terms of this Lase Agreement, Tenant shall forfeit the Security Deposit, which shall be retained by Owner, this Lease greement shall terminate and all of the Owner and Tenants obligations hereunder shall become null and v id. B. If at any time during the term any Annual Minimum Rent, Annual Pere ntage Rent, or additional rent payable by Tenant shall be overdue, or if Tenant fails to perform any of he other terms, covenants or conditions to be performed by Tenant, then Owner, at its option, may appro riate and apply all or any portion of the Security Deposit to the payment of any such overdue Annual inimum Rent, Annual Percentage Rent, or additional rent and to the compensation of Owner for I ss or damage sustained by Owner due to a breach by Tenant as aforesaid, without prejudice to Owner's ther remedies. Should all or any part of the Security deposit be appropriated and applied by Owner as ovided above, then Tenant shall, upon demand of Owner, forthwith remit to Owner a sufficient am unt in cash to restore the same to the original sum deposited. Should Tenant comply with all of the te s, covenants and conditions of this Lease binding on Tenant, the Security Deposit shall be returned i full to Tenant within 60 days after the later of the following dates: (i) the date of expiration of the term or (ii) the date Tenant shall deliver to Owner such inspection reports as Owner shall require setting forth hat the'+-eased Premises were surrendered in accordance with Section 11.02 of this Lease ARTICLE XIX - ACCESS BY OWNER Section 19.01. Right of Entry. Owner and its designees shall have the right to enter the Leased Premises dur ng reasonable business hours (except in the event of emergency. when Owner may enter at any time) for an lawful purposes (including the right to show the Leased Premises to prospective purchasers of the Shopping Center, and, during the last six months of the term, the right to show the Leased Premises 0 prospective tenants) and to whatever extent necessary or appropriate to enable Owner to exercise a I of its rights under this Lease (including without limitation the right to perform certain provisions of this Lease on Tenant's behalf as set forth in Section 18.02) and to carry out all of Owner's obligati ns hereunder. Owner and Owner's representatives shall also have the right to enter the Leased Premise and to erect scaffolding and barricades around the same (but not so as to preclude entry thereto) in orde to make such repairs, alterations, improvements and additions to the building of which the Leased Premi es form a part and the foundations and walls of the Leased Premises as Owner may deem necessary or esirable (and 26 Owner shall be allowed to take all equipment and material upon the Leased Premis which may be required therefore), but Owner shall use reasonable efforts consistent with accepted con truction practice to minimize interference to Tenant's business caused by reason thereof. The exercise by Owner of its rights of entry and other rights granted under this paragraph shall not constitute an evicti n of Tenant and the rent payable under this Lese shall not abate by reason thereof. Owner shall provide r asonable notice to Tenant prior to such entry. ARTICLE XX - ARBITRATION; RIGID' TO APPEAL Section 20.01 - Arbitration. Any disagreement between Owner and Tenant with respect to the interpretation r application of this Lease, or the obligation of the parties hereunder, shall be determined by arbitration u less the parties otherwise mutually agree in writing. Owner and Tenant shall agree upon one arbitrator, otherwise there shall be three (3), one named in writing by the Owner and one named in writing by the T nanL within ten (10) days after notice of arbitration is served by either upon the other, and a third arbitr tor selected by those two arbitrators within ten (10) days thereafter. No one shall serve as an arbitrator w 0 is in any way financially interested in this Lease or in the affairs of either party hereto. This agree ent to arbitrate shall be specifically enforceable under the prevailing arbitration laws. The arbitrator or rbitrators shall have the power to award to either party to the dispute such sums, costs, expenses, and a torney's fees as the arbitrator or arbitrators may deem proper. The award rendered by the arbitrator or arb trators shall be appealable to a court of competent jurisdiction within thirty (30) days of notice of the ar itrators' award. Such appeal shall be prosecuted without delay and as rapidly as possible. Section 20.02 - Waiver of Trial By Jury. THE PARTIES HEREBY WANE TRIAL BY JURY IN ANY ACTION, ROCEEDING, COUNTERCLAJ1v1 OR APPEAL BROUGIIT BY EITHER PARTY AGAINST THE OT R ON ANY MATTER. Tenant agrees that any action brought in connection with this Lease may b maintained in any court of competent jurisdiction in the Commonwealth of Pennsylvania. Tenant h reby appoints Owner as agent for the purpose of accepting service of any process, subject only to the condition that Owner promptly send Notice of such process to Tenant at the address of Tenant set fort in A-I of the Basic Lease Provisions. In case suit shall be brought because of the breach of any agreement or obligation contained in this Lease on the part of Tenant or Owner to be kept or performe . and a breach shall be established, the prevailing party shall (to the extent permitted by law) be entitle to reC0ver all expenses incurred therefore, including reasonable attorneys' fees. Owner's rights and re edies shall be cumulative and may be exercised and enforced concurrently. Any right or remedy conferr d upon Owner under this Lease shall not be deemed to be exclusive of any other right or remedy Owner ay have. All rights and liabilities herein given to or imposed upon the respective parties hereto shall, ex ept as may be otherwise herein provided, extend to and bind the respective heirs, executors, administrat rs, successors and assigns of the said parties; and if there shall be more than one Tenant, they shall all b bound jointly and severally by the terms, covenants and agreements herein contained. This paragr ph shall only become effective in the event that there is an appeal of an arbitrators award. ARTICLE XXI - OWNER'S LIABll...ITY Section 21.01. Limitations on Liability (A) Anything contained in this Lease to the contrary notwithstanding, Ten t agrees that Tenant shall look solely to the fee simple interests or leasehold estate of the Owner in the Shopping Center for the collection of any judgment (or other judicial process) requiring the paymen of money by Owner in the event of any default or breach by Owner with respect to any of the terms and provisions of 27 this Lease to be observed or performed by Owner, subject, however, to the prior right of the holder of any mortgage covering the Shopping Center, and NO OTHER ASSETS OF OW R SHALL BE SUBJECT TO LEVY EXECUTION OR OTHER JUDICIAL PROCESS FOR THE ATISFACTION OF TENANT'S CLAIM AND OWNER SHALL NOT BE LIABLE FOR ANY SUC DEFAULT OR BREACH E PT TO THE EXTENT OF OWNER'S INTEREST IN THE SHO lNG CENTER. (Tenant) n~~_---'1 (B) Except where Owner has breached or failed to abide by its obligation set forth in this Lease, Owner shall not be liable for any damage occasioned by failure of the Premises t be in repair, nor for any damage done or occasioned by or from plumbing, gas, water, sprinkler, steam r other pipes or sewerage, or the bursting, leaking or running of any tank, washstand, water closet r waste pipe in, above, upon or about the Premises or improvements constituting a part thereof, nor for any damage occasioned by water, snow or ice being upon or coming through the roof, skylig s, trap door or otherwise. (C) In the event that in this Lease it is provided that the exercise of any ri ht by Tenant or the performance of any obligations of Tenant shall be subject to the consent or approv 1 or Owner and that the consent or approval of Owner shall not be unreasonably withheld or delayed, th n in any case in which Owner shall withhold or delay its consent, Tenant hereby waives any and all righ s it may have to recover (and Tenant shall not seek in any proceeding) any damages from Owner on ac ount thereof; it being agreed that Tenant's sole remedy for Owner's withholding or delaying of c nsent shall be injunctive relief (without any right to damages). CD) Notwithstanding anything to the contrary contained in this Lease, if Ower shall elect to provide security service then (i) any security service that may be provided by Owner is intended solely for the protection and benefit of the Common Facilities and not for the protection 0 benefit of the Leased Premises or any other premises; and (ii) Owner shall not be liable in any mann whatsoever to Tenant or to any third party by reason of Owner's act or failure to act in providing or maintaining security in the Shopping Center. Section 21.02. Owner's Obligations With Respect to Future Building Areas. Notwithstanding anything set out in this Lease to the contrary, it is understood an agreed that (i) Tenant will not cancel this Lease nor be entitled to claim any actual or constructive evicti n because of a default of Owner either by act or omission under this Lease when such act or omissio relates to any Future Building Area shown on Exhibit A, and Tenant will not abate rentals or otherwise credit or offset damages against rental under this Lease because of any act or omission of Owner under t is Lease which relates to any Future Building Area shown on Exhibit A, but shall not be construed as waiver of any rights Tenant may have in person against or as a waiver of any remedies by way of i junctive relief which Tenant may have against Owner (other than one who becomes such after the for closure of any first mortgage covering any part of the real property which is contained within the Shop ing Center, or after the execution of a deed in lieu thereof); and (ii) the restrictions set out in this Leas, if any, to the extent the same relate to any Future Building Area shown on Exhibit A, and all obliga ions of Owner with respect to such restrictions shall absolutely and automatically terminate for all pu oses from and after the date the holder of any first mortgage affecting the real property which is cont ned within the Shopping Center, forecloses its mortgage or obtains a deed in lieu thereof. For purposes f this Section, an "Outlot" shall be considered the same as a Future Building Area. ARTICLE XXII - HOLDING OVER Section 22.01. Holding Over. 28 In the event Tenant remains in possession of the Leased Premises after the xpiration of the tenancy created hereunder, and without the execution of a new lease, Tenant, at the ption of Owner, shan be deemed to be occupying the Leased Premises as a tenant from month-to-month, at a rate equal to 125% of the Annual Minimum Rent for the last Lease Year of the term, subject to all the other conditions, provisions and obligations of this Lease insofar as the same are applicab to a month-to- month tenancy, ___.__._____~__,________.._____~u_ Section 2To2 Time is of the Essence. Time is of the essence of each provision of this Lease. Tenant hereby waives notice to quit the Premises at the expiration of the term of this Lease or any earlier termination, and this Lease shall constitute sufficient notice to quit witho t any obligation upon Owner to provide Tenant with any additional notice thereof. ARTICLE xxm - WAIVER; NOTICE; DEFINITIONS; MISCELLANEOUS. Section 23.01. Waiver. No delay or omission in the exercise of any right or remedy of Owner on any d fault by Tenant shall impair such a right or remedy or be construed as a waiver. No covenant, term or ondition of this Lease shall be deemed to have been waived unless such waiver be in writing signed by t e party charged therewith. '/ Section 23.02. Force Majeure. '\, " In the event either party hereto shall be delayed or hindered in or prev nted from the performance of any act required under this Lease by reason of strikes, lockouts, labor tr ubles, inability - to procure materials, failure of power, restrictive governmental law or regulations, riots, i surrection, war or other reason of a like nature not the fault of the party delayed in performing wor or doing acts required under the tenns of this Lease, then performance of any such act shall be exten d for a period equivalent to the period of such delay. The provisions of this Section shall not (a) op rate to excuse Tenant from prompt payment of Annual Minimum Rent or any other payment required y the terms of this Lease, and (b) be applicable to delays resulting from the inability of a party to obtain financing or to proceed with its obligations under this Lease because of a lack of funds. Section 23.03. Notices and Payments. (A) Whenever any notice, consent, approval or authorization ("Notice") s required or pennitted under this Lease, the same shall be in writing and all oral notices, consents, approvals and authorizations shall be of no effect. All Notices by Tenant to Owner shall be sent to Own r by registered or certified mail (return receipt requested), postage prepaid, or by a nationally recogn zed overnight courier service (Federal Express, AirBorne, UPS Next Day Air or similar) at the "Addr ss of Owner" designated in Section A-I of the Basic Lease Provisions, or to such other addressees) as 0 ner may later designate in writing (including, without limitation, any notice which Tenant shall be re uired to give Owner's mortgagee pursuant to Section 12.04). Until Owner is notified otherwise by Ten t, all Notices by Owner to Tenant shall be deemed to have been duly given if sent by registered or certified mail (return receipt requested), postage prepaid, or by a nationally recognized overnight c urier service (Federal Express, AirBorne, UPS Next Day Air or similar) to Tenant at the "Addre s of Tenant" designated in Section A-I of the Basic Lease Provisions. In the case of notices sent by ove ight courier, delivery shall be deemed effective one day after such notice is sent. Until otherwise noti led in writing by Owner, Tenant shall pay all rent and other sums required to be paid by it under this Lase by check 29 payable to the order of Owner and shall deliver the same, together with all sales repo s required under Article ill and all certificates of insurance required to be furnished by Tenant pursua t to Article X, to the address of Owner designated in Section A-I of the Basic Lease Provisions. ' (B) All Notices shall be effective upon being deposited in the United Sates mail in the manner prescribed in paragraph (A) of this Section. However, the time period in which response to any such. N oti<=.~_m\l~ _ huiyeIl shalLc.Qmmence.-1orurLfr--Om.t-he-date--Gf-F~i}lt---B:Y--t-he--acld ;essee-t-hereof-as shown on the return receipt of the Notice. Rejection or other refusal to accept or the i bility to deliver because of changed address of which no Notice was given, shall be deemed to be receip of the Notice as of the date of such rejection, refusal or inability to deliver. Section 23.04. Definitions. (A) The term "calendar year" shall mean a period of 12 consecutive full alendar months, commencing January 1 and ending December 31. (B) The term "Guarantor" as used in this Lease shall be deemed to mean ny person (and their spouse, if any), partnership, corporation or other entity which has undertak n, by separate instrument, endorsement on this Lease or in any other manner, to warrant, agree or g arantee that the obligations of Tenant, or any portion thereof, shall be performed by Tenant. (C) The term "Gross Leasable Area" shall mean the aggregate floor area wi 'n the exterior faces of the exterior walls (except party walls as to which the center thereof, instead of t e exterior faces thereof, shall be used). Changes in Gross Leasable Area occurring during any calendar month shall be effective on the first day of the next succeeding calendar month and, unless otherwise he ein specified to the contrary, the total number of square feet of Gross Leasable Area in effect for any cal ndar year shall be the average of the number of square feet of Gross Leasable Area on the fIrst day 0 each calendar month in such calendar year. (D) The term "including" as used in this Lease shall mean "including without imitation". (E) The term "Interest Rate" shall mean a rate of interest, per annum, equal 0 the lessor of (1) the highest lawful rate of interest that may be charged Tenant under the laws of the St te in which the Leased Premises is located or (ii) two percent (2%) in excess of the "Effective Rate" of Case Manhattan Bank, N.A., New York, New York (or its successor) (the "Bank") initially determined as f the ~te any rent, additional rent or other payment under this Lease is due and for which interest at the terest Rate is charged and thereafter adjusted daily; PROVIDED, HOWEVER if the Bank should cea e to exist as a viable commercial bank, then the "Effective Rate" of any commercial bank selected by 0 er and having capital and surplus of at least $50,000,000.00 shall be used to determine the Interest te. The term "Effective Rate" shall mean the rate of interest announced by the Bank or other commercia bank selected by Owner as aforesaid, as the case may be, as its prime lending rate. The Effective R te shall be as announced by the Bank notwithstanding that the Bank may actually charge other rates, and a written statement from the Bank or any national investment brokerage fIrm or national bank s to what the Effective Rate was on any given day shall be deemed conclusive. (F) The term "Lease Year" shall mean a period of twelve consecutive full ca endar months. The first Lease Year shall begin on the date of commencement of the term if such date of c mmencement shall occur on the first day of a calendar month; if not, then on the first day of the calen ar month next following such date of commencement. Each succeeding Lease Year shall comme ce upon the anniversary date of the first Lease Year. 30 (G) The term "Mortgage" shall include a deed of trust. The term "mortgage" shall mean the holder of a mortgage and beneficiary under a deed of trust. (H) The term "Tenant's Percentage Share" shan mean the Tenant's proporti nate share based on the calculated percentage of Tenant's Gross Leasable Area as herein defined in reI tion to the total gross leasable area of the- shopping center. (I) The word "Tenant" shall mean each and every person or party men oned as Tenant herein, and if there shall be more than one Tenant, any Notice required or permitted by he terms of this Lease may be given by or to anyone thereof and shall have the same force and effect as 'f given by or to all thereof. (J) The word "term" shall mean the period from the date of the commencem nt of this Lease to the expiration or sooner termination thereof, including any extension thereof, all as her in provided. Section 23.05. Miscellaneous. (A) Recordin?: of Lease. Neither party shall record this Lease in its entirety. However, upon the request of either party, the other party shall join in the execution of a memorand m or so-called "short form" of this Lease for the purpose of recordation. (B) Obligations Surviving Termination. All obligations of Tenant and Owne which by their nature involve performance, in any particular, after the end of the term, or which cannot b ascertained to have been fully performed until after the end of the term, shall survive the expir tion or sooner termination of the term. (C) Governing Law and Jurisdiction. The laws of the Commonwealth of Pe nsylvania shall govern the validity, performance and enforcement of this Lease. CD) No Accord And Satisfaction. No payment by Tenant or receipt by 0 ner of a lesser amount than the monthly rent and other charges, nor shall any endorsement or statement n any check or on any letter accompanying any check be deemed an accord and satisfaction. (E) Alterations And Amendments. Except as herein otherwise expressl provided, no subsequent alteration, amendment, change or addition to this Lease, nor any surrender of the term, shall be binding upon Owner or Tenant unless reduced to writing and signed by them. - CF) No Partnership. Owner does not in any way or for any purpose beco e a partner of Tenant in the conduct of its business or otherwise, nor a joint venturer or a member of a oint enterprise with Tenant. CG) Withholding Consent. Wherever in this Lease a party's consent or appro al is required, such approval may be withheld arbitrarily unless otherwise herein specifically provided to he contrary. (H) Ca{ltions; Article Numbers. The captions, section numbers, article nurn ers and index appearing in this Lease in no way define, limit, construe or describe the scope or intent 0 such sections or articles of this Lease. The language in all parts of this Lease shall in all cases be cons ed as a whole according to its fair meaning, and not strictly for not against either Owner or Tenant, and should a court be called upon to interpret any provision hereof, no weight shall be given to, nor shall any onstruction or interpretation be influenced by, any presumption of preparation of a lease by Owner or by enant. 31 (1) Guaranty. At the time of executing this Lease, Tenant shall provided t Owner a signed Guaranty of Lease including the signature of the spouse, if any, in form and substan e as set forth in Exhibit D hereto. Each Guarantor shall provide Owner with an annual financial stateme t upon request. (1) Severability. In the event that one or more provisions of this Lease sha 1 be found to be unenforceable at law or in equity, the remainder of the Lease shall not be affected and sh 11 remain in full force a.nd~ffect~ ---- - (K) Successors and Assi~s. This Lease shall be binding upon and shan in re to the benefit of the parties hereto and their respective legal representative, heirs, successors and assi s. (L) Tenant's Corporate Authority. If Tenant is a corporation, it shall, conc rrendy with the signing of this Lease, furnish to Owner certified copies of the resolutions of its Board 0 Directors (or of the executive committee of its Board of Directors) authorizing Tenant to enter into this Lase; and it shall furnish to Owner proof that Tenant is a duly organized corporation under the laws 0 the state of its incorporation, is qualified to do business in the Pennsylvania, is in good standing u er the laws of Pennsylvania, and has the power and authority to enter into this Lease, and that all orporate action requisites to authorize Tenant to enter into this lease has been duly taken. (M) Brokers. Except as set forth below, Tenant represents and warrants tha with any broker in respect to this Lease, and agrees to defend, indemnify and save against all demands, claims and liabilities arising out of any dealings between Tenan broker in respect to this Lease: Rothman, Schubert & Reed Realtors it has not dealt wner harmless and any other THIS LEASE CONSTITUTES THE ENTIRE AGREEMENT THIS LEASE AND THE EXH1BITS AND RIDER, IF ANY, ATTACHED HE TO, IS THE COMPLETE AGREEMENT BETWEEN OWNER AND TENANT CONCERNING HE LEASED PREMISES AND THE SHOPPING CENTER. THERE ARE NO ORAL A REEMENTS, UNDERSTANDINGS, PROMISES OR REPRESENTATIONS BETWEEN OWNER TENANT AFFECTING THIS LEASE. ALL PRIOR NEGOTIATIONS AND UNDERSTAND GS, IF ANY, BETWEEN THE PARTIES HERETO WITH RESPECT TO THE LEASED PREMIS S AND THE SHOPPING CENTER SHALL BE OF NO FORCE OR EFFECT AND SHALL NOT BE USED TO INTERPRET TillS LEASE. IN WITNESS WHEREOF, the parties hereto have executed this Lease as of the written. WITNESS: '~ ~DbL-- ATTEST: "---''i\LltLt''-'-iJtG~'~''- -~-- - ,) i j './ OWNER: Rothman, Schubert & Reed, a Pennsylva a General ~ership ~ BY:~~ Samuel L. Reed, Attorney-in-Fact pursu Attorney dated August 21, 1996, and ree Book 528, Page 480. TENANT~'l\ . \:)'i\. \. ~ '{\J~ Massimo' -', c. \ \ By: (SEAL) t to Power of rded in Misc. (SEAL) 32 EXHIBIT B OWNER'S WORK Executed with Lease dated 1) \JV 1) , 2004, between Will' am F. Rothman, Charles F. Schubert & Samuel L. Reed, Co-Partners, tJdIb/a Rothman, Schubert & Ree , a Pennsylvania General Partnership, as Owner and Massimo Napoli, Inc., as Tenant.-- Owner agrees, at its expense, to deliver the Leased Premises to Tenant with th following work set forth below. Owner has not agreed to perform any other work in the premises, an all other work necessary to complete the Leased Premises shall be done at Tenant's sole cost and expens . Owner shall provided Tenant with a "pure vanilla box" which shall includ the fol1owing work/construction to the Leased Premises: 1. Four (4) walls, W' dry-walled and primed. 2. 2x4 grid ceiling with fluorescent lighting through out. 3. HV AC--heated and cooled with roof top units, gas :fIred heat, and electric cooling. Cooling based on one (1) ton per 400 square feet, turned over in good working or er. 4. Two (2) bathrooms with standard plumbing in compliance with existing rough-in locations. A in currently 5. One (1) hot water heater for bathrooms only. 6. 200 amp electrical service with miscellaneous receptacles through out as equired by Code. 7. Concrete flooring, 4" thick, 3000 psi. 8. Glass front, all windows and maintenance doors to be aluminum as manu ctured by Kawaneer or equivalent. 9. Water, sewer and gas to be supplied at rear of property. 10. Demising wall. Tenant shall be responsible for build-out, floor covering, additional plumbing and addit onal hot water heater to service the Leased Premises and such other work necessary to complete the Leas d Premises all at Tenant's sole cost and expense and not without Owner's approval.- 33 EXHIBIT C RULES AND REGULATIONS Tenant shall at all times during the term of the Lease: 1. Obs~rv_e an traffic regulations, including posted speed restrictions and warnin sand stop- signs. Owner shall have the right of enforcing these regulations and of prohibiting use of access streets, service driveways and parking areas to violators. 2. Not permit smoking in the Leased Premises. 3. Use, maintain and occupy the Leased Premises in a careful, safe, proper and la ful manner, keep the Leased Premises and its appurtenances, including adjoining areas and sidewalks, in a clean and afe condition. 4. Keep the sidewalks and areas contiguous to the Leased Premises free of ice, sno and litter. 5. Keep all glass in the doors and windows of the Leased Premises clean. 6. Not, without prior written consent of the Owner, place, maintain or sell any m rchandise in any vestibule or entry to the Leased Premises, on the sidewalks adjacent to the premises, or elsewhere on the outside of the Leased Premises. 7. Keep the Leased Premises clean, orderly and in sanitary condition, free of insec , rodents, vennin and other pests, and if by reason of any infestation of the Leased Premises by insects, rodents, ver in or other pests, any other store in the Shopping Center becomes infested by any such condition, Tenant shall b responsible for exterminating any such condition in other infested stores. 8. Not permit undue accumulations of garbage, trash, rubbish and other refuse n or around the Leased Premises, keep refuse in closed containers within the interior of the premises or a designat d dumpster until removed, and arrange for regular removal of refuse at its expense. 9. Not use, permit or suffer the use of any apparatus or instruments for musica or other sound reproduction or transmission in such manner that the sound emanating therefrom or caused thereb shan be audible beyond the interior of the Leased Premises. 10. Not load or unload fixtures or merchandise from any premises entrance except he rear delivery entrance. 11. Not deliver or suffer or permit delivery of merchandise to, or collection of refuse om, the Leased Premises after 11:00 a.m. on any day. 12. Light the show windows and exterior signs of the premises to the extent that Own may from time to time require. 13. Keep all mechanical apparatus free of vibration and noise, which may be transm tted beyond the confines of the Leased Premises. 14. Not cause or permit objectionable odors to emanate or be dispelled from the premi es. 15. Not overload the floors or electrical wiring and not install any additional ele trical wiring or plumbing without Owner's prior written consent. 16. Not use show windows in the Leased Premises for any purpose other than display of merchandise for sale in a neat and attractive manner. 34 17. Not conduct, permit or suffer any public or private auction sale to be conduc ed on or from the Leased Premises. 18. Not solicit business in the corrunon areas of the Shopping center or distribute and bills or other advertising materials in the common areas, and if this provision is violated Tenant shall pay wner the cost of collecting same from the common areas for trash disposal. 19. Automobiles belonging to Tenant, its employees and invitees, shall be parked 0 ly in the areas that may be designated by Owner, subject to the provisions of this Lease. 20. Doors in the Leased Premises shall not be covered or obstructed by Tenant. 21. Water closets and other plumbing shall be used for no other purpose than th se for which they were intended and no sweepings, rubbish, rags, or improper articles and materials shall be thr wn therein. It is recognized by the parties that chemicals, paints and thinners are especially injurious to the nctioning of the property's sewage disposal system and, without limitation, shall not be disposed of in such sewage ystem. 22. No signs, advertisements or notices of any kind shall be painted or affixed t any part of the outside of the Leased Premises without the prior written permission of Owner. 23, Premises. No person of disorderly character will be allowed to frequent or remain on or about the Leased 24. No nuisance, public or private, shall be created or permitted in the demised remises and the Leased Premises shall be conducted so as that no annoyance is caused to Owner, Owner's employe s or other tenants of the Owner. It is recognized that the Leased Premises are part of a Shopping Center in which nu erous tenants are located and that absolute supervision of the use of the Leased Premises is necessary in order to fficially maintain and operate an entire Shopping Center, and the parties therefore agree that the Owner shall have e exclusive and sole right of determining as to what constitutes a nuisances and that its determination shall be bindi g and absolute. WITNESS: OWNER: Rothman, Schubert & Reed, a Pennsylva General P ership 25. Upon termination of the Lease, doors and windows of the building shall be left and the keys to the leased premises shall be delivered to the Owner. 26. Tenant's fire fighting and prevention apparatus shall be adequate and sufficient a proper working condition and accessible at all times so as to conform to all applicable laws regulations. IN WITNESS WHEREOF, the parties set forth theirs hands this r 2004. --~ Q~s;)h <-- By: (SEAL) Samuel L. Reed, Attorney-in-Fact p suant to Power of Attorney dated August 21, 1996, a d recorded in Misc. Book 528, Page 480. (...---.....'\.: /7.., !./ '- ,-_;_._k--te- L \: 1- lG\----- - By: (SEAL) ATTEST: "...... 35 EXHIBIT D GUARANTY OF LEASE In consideration of the making of the above Lease dated n lS\J ~ , 2004, by the Tenant with the Owner at the request of the undersigned, and in reliance of t e Guaranty, the undersigned hereby unconditionally and irrevocably guarantees the payment of the rent 0 be paid by the Tenant and the performance by the Tenant of all the terms, conditions, covenants and a eements of the Lease and its Exhibits. and the undersigned promises to pay all of the Owner's ex enses, including reasonable attorney's fees, incurred by the Owner in enforcing this Guaranty. The 0 ner's consent to any assignment or assignments, and successive assignments by the Tenant and Tenant' assigns, of this Lease, made either with or without notice to the undersigned, or a changed or different se of the Leased Premises, or Owner's forbearance delay, extensions of time or any other reason whet er similar to or different from the foregoing, shall in no way or manner release the undersigned om l}ability as Guarantor. Where the undersigned include more than one party, the obligation of ach such party hereunder will be joint and several. It will not be necessary for Owner to proceed first gainst Tenant in invoking any of Owner's lease remedies before proceeding to enforce this Guaranty of Le se. WITNESS the hand and seal of the undersigned at the date of the above Lease. /'-'\ ' ()/ J ;,-._--.i(\tt.,l,VC>-\ (tv )~- () ~ WITNESS: 36 11/04/2004 15:05 7179Bo~939 I REAGER & ADl ~~ PC I PAGE 02 (,Ii ,slj. i JIB ';I.J j: ! IA ., .. i ~:I It i,i ft 'ilj rd' . d~!~ ~ .. ~ II. 111 ~ I!J ; ;H :r I~ ill III ~ I~!llmn~ It IJ ;niiJ{'~ n.J~II!IIII~ll J J I~': '::)'1: I nu , 1 i illf i i ,ftl , I Jill ' - iJ;r If I l!I, ;11 d' :1: I . ~, I hi !i Ii { IH ~ .ldlW ~'J " 'I c:J !, II Ii -, EXHIBIT A ~0 1:/04/2004 15:05 71 79E1~ . CJ39 j REAGER & AD' ., PC ) PAGE 03 RS&R SHOPPING CENTER -OVERALL Alllhat eenain 1ract or land Jitulte in But P~ro Township. Cumberland Pes>>1sytvatlia.. more putkutarty bounded and described u fonows: , BEGrNNTNG at & point along the northern right orway 1iltc or Pcnn~IVti\i. R ute 944. .bo known as Wet1.xVillo Road and on the line of adjoinct between tot~ no~, 1 a 3 on the hereinafter mentioned Plan of Lot; _ thtn~ alOrtg wd line ofadjoit\(::l" by a curve to the let\ with 1 radiuI,or 10.00' d &1\ arc lenSth of 15.71' to I point~ _ thalce, continuing along ~d line: ofad,iolnc:r N tr32')J"W, a distance of 185. 8~ to a point; t~ continuing a10nS &aid line or adjoinet S 12027'27" W, a distAru;c: of 241. S' to a point on the: eenterliM cr J.Jl etlOJtirtg ZO' sanitary sewu casement. thence, contUtuing aJong wd centerline t~ following cout'$e! and distances: N 21"20'00" W, a distaneo of 138. 9S' to a point; N 11915'30" W, . diftanGe of263.28' to a point N 4010'00" E, .a distanu of 130.24' to a point~. N 4-20'30"' E. & di.t&11c.c: of 123.12' to I point; N- J3oJ&'W;-a ~of2S9S1' to-a poUrt; N oouSI'E. . diatatlcc'ofJ'4S.14' to.a point on. the tine ofadjoiner between Lot . lands now or formc:riy (nit) of Jacob R. Renninger. thence., along iAid line or sdioiner N ~S9t42" a a distlnCC or 102.70' to a poi t on the tine ofadjoinct ~ Lot No.3 and la.nda nJfofRo"cn B~ th~ along said line of Idjoincr and along lands nlr ofMarga.ret and Jlcob Ulri k S 22~4t4T' E, .. diJtance of200,J I' to tn iron pin; , thcncc:r, N 8)005'07" E. .-dIaUft.ce of298.94 , to. point: thenco, S 22.51'00" ~.. distance or'-17.0~' to. point~ thence, aloni said l4nds nlrofContervatfve nartilt Chutdt S "024'00" W, a dis cc of J2S.44' to an iron pin; th~ along said Iin6 of adjoincr S 226S t 'OgK ~ a diltlncc or 349.95' to an iro pin; thence. aJon& said line of ad joiner N 81024' E a disunce of 1 ~.44' to .1ft Iron pi on the western end oftinden Street; . thence. dop8 ISA1d western end orLinden Street S t 6- J S' 43" E. . distance of 48. 4' to an iron pin On land.. nit ofHden B. Hd~ thence, a.lona said land5 S 22.53'J5.' E a dlatanc:c or 152.38' to an iron pin at Ian nlfor Donald E. Shutt; thence.. along said lands rJ(0( Shutt and land, nlfofRobert Brm S 'TJG44'3S" diatance or 179.42' to An iron pin; thence. &1ongNid land. DfBrctz S17035':B" E. distlnec: of t82.03' to II point 0 the northern line of Lot No.2; EXHmIT uA~ 1". .W\( 1~!04!2004 15:05 ,r 717g8n~g3g I REAGER & AD' - --, PC ! PAGE 04 , , , thence, S /2027'2T W a dist~ce of J 99.80' to a point; thonec, S 17032'33'0 E & dillance of208,OO' to I point; tbence. by a curve to the left having .. radiu~ of JO' for an arc distance of 1 ~.7IO to a point on thenorthcm tine ofPenn.sylv.m1l Route 944, known.., Wer1zviUe R.oad~ theau. S 121127'27" W. dilUnce of 79.0-4' to.. point the place ofBEQ1NNlN . Containins: S 19. 784 ~. ft. BEING Lot No. J (13.31 sacs) WERTZVILLE ROAD aM' CONVEYANCE All that CCTtain tract orland tituate in East Ponnsbcro Townihip, Cumberland C unty, Pennsylvan1a.. more particularly bounded and dexribtd 13 rollows; BEGINNING at a point along the existing nonhcm right or way line ofPcnn!.ylY 'a Route 944, aJJO known u Wcrt%Yil/.c Jtoad. said point bdflg located at the Sout ~tem eomc:r ofla.o.:b now or formerly of Eric Shore Enterpri!eS, Inc, thenu JJong uid f411ds by . curve to the !eft hiving a radilU of 10.00 .Il1d IJ1 arc te1lgtn or IS. 71 t to a point: then~ by sameN ,7932'))" W I. diatanc.e or .5.14' to I point on the required northern ri ht..of. ~y tine ofWertzviUe Road; t~, by said rlgJrt-<)C-way line N 72026'17" E a di tanee of S9.04' to A point 11 lands now or formerly arUm-Matts., Inc.; thence. along lands ofUnl4 Marts, Inc:. S 17032'))" E adistAnet o( 5,16' to a point; thence, by same by A cuo to the left having a radius of 10.00, and &J'1 arc tcnBth or 15.71' to a point on the north right- - of-way line ofWertzviUc Road; thence. by said right~r.way tine S 720?7'2T' W dimn.ce of79.M' to a point., the p~ce otBEGINNING. ContaIt\ing: 93& 5q. ft, (0,02 ICTe.3) CONVEY ANCE TO RS &R All thai cer:&n tract otland dtuatc in wt PeMSbom Township, Cumberland Co nty, PennsylvanJa, more particularly bounded Uld de~cribed u fbl1owa: BEOlNNlNG af .. point on the eutem rig1rr.-(Jf-~IY of Salt Rom Roalignmcnt. Pi point bcina on the centerline of an existlng 20' sanituy sewer easement; thence. atong 'd sewer centerline N 17" r 5'JO" W a distance oC70.96' to & point; thence, by same 04-)0'00" E I distance of 130.2'" to a point~ thence, along land. now or formerly Shore FIrst Auembly of God S 6JOS4'41" W. distance of 116.o4S' to.. point on t eutcm rigbtyo(..way line or Salt Roed ReaJl8M1Cnt; thence. alons Slid right--of-w ~. t ~..': r. " 1:/04/2004 15:05 PAGE 05 71 7'3I?F' ~'33'3 \ REAGER & AD' 'PC ) :12,.05'J9" E a distan<< of 113.6S' to a point; thence. by same N 6"54'41" ~. lstanco ors.oo' to to poinl; thctlc.e. by ssm~ S 21.05"19" E a dis1ancc of11J.6S' to" int; thCf1Ce. by $&me N 6rS4'41" E .. diJ1anee of 47.86. to I point. the place' orBE INNING. COl\u..ining: 13,618 sq. ft. (0.31 acr") YN 1:/134/21304 15:85 717'31304939 REAGER & ADLr~ PC ) PAGE 135 EXHIBIT E , S.A1\.1PLE 1v1ENU INSALATE ,4,NTIr"Sro AU. 'rr~'N^ lNs,ALAl'A CSSA~g lNSAU-T ^ 01 pou.o fNS..u......TA OEl.I..A CAB'" u.sl\J..J, l'^ CAPltES~ ANTIPASTI AN'1'1PJ\STO P'RUA CASA o...M1lER.1 It ~1 P1UrT'! v<'.Ma~lItCAI..AMAA1 MT.T...'rJ -aRU5c:K!Tr^ A1.l"OMOtlOJtO MAZZ~E!1-t.~ ~ flROSCIUTT'O S MRt..O~ p~ l'.AJ'.llJolO CON 1~ l'AN'lNO ctfN PRO'CIUTTO P/\NINO AU,.".AUANA I'.AMNo CON POt.l.O AJ,.r..A. GRJGlJA J>IIMNO CON CAJ.m ,^NINO WOETA.!..H PIZZETTE R'tZZA MAACl-l'lllU'r4 ttll..zA NAJlIOLET ANA P!ZZ.4. QtlATrRO Sr~NI P~ DLAVOLA PJ.ZZ..1. SiANCA ~l zz..". .AJ ItUNOJol I Pl1Z.A V,eO!l'..-.Ul PlUMI PIA Tn IV. 1'10l.I COW F'~ E ~IUTI'Q COT"l'O Il.ISorro AJ f"t1NQffi II"tSOTI"O ^"^ ~TClR.A GNoCcH'J IU.I.J...JI, ~2 1'1l.S'i''''CON~OP~O ll.T0A1"ONf c..'\JUICINAR.J\ nn1J~l>tTIT.Io:NUCA ~ CON POUt.> a YANNA. 1I1STBCC^ ;'1 FmUtf l'i.1Ci DIU. OlOltNCl ...( l'RRRl DOLeI p.llalSER7S WILt.. CUANaD WUIC.L Y BE'VANDE C4.IIPUCC!N'O 1!l8f'l'U!1SO C.AWIl U'JTJiI: ACQUA~ AAANCIATA UMONA TA CHl'NO't"'l'O Sllil"T1i (jo'\SjAtt Date: I/-CJ ?O f./ 3g</ East Penn Dr. Enola, PAl 7025 By signing this letter you agree on the following: s received ossession to Possession Date //-o9-a'l Code 11- 7+-9 Occupancy Date Rent Commencement -~s Initial Monthly Base Rent Amount Initial Monthly Additional Rent Security Deposit . 'digtJ .00 t:f 3.J;.() I () 0 Pre-Paid Rent Amount Partial Rent Payment Due ? d~8() ,00 ;;;Z - 69 .os -r Date of Base Rent Increases c ~U1- TP. 't e-Jr ~ Next Full rent Payment + 1- O?-- /-CJ '7-;;2.0 Lease Termination Date Options 1'<. Please review and sign letter of acknowledgment and agreement. It is our poli y that we do not release key until this worksheet is returned. By returning it immediately to my attention (by fax (717) 763-1656) you will avoid delay in receiving your key a d help us facilitate our accounting process. If you have any questions regarding the abov , please contact me at (717) 763-1212. Thank you ~c/~ & Reed /:' - ./fO LA-f) SSN#: UDb - (CJ - -~ I / 'f _O)V-Q Drivers Lic# Rothman. Schubert & Reed I 3 Lemoyne Drive, Suite] 00. Lemoyne P A. 17043- 717-763-1212 - fax (717) 763-165~ }~D\t 0 - --- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PE NSYLVANIA CIVIL ACTION - LAW MASSIMO TRATTORIA, INC., a Pennsylvania Corporation and MASSIMO NAPOLI, individually Plaintiffs No, OS - ~9S c- ~ll~€rL~ vs. WILLIAM F, ROTHMAN, CHARLES F. SCHUBERT and SAMUEL L. REED, co-partners tJd/b/a ROTHMAN, SCHUBERT & REED, a Pennsylvania General Partnership Defendants JURY TRIAL DEMANDED o S; ~ff- Z~. J ~~)J:'. " '-- -,- -0 ~C-) ~ :::O~'c-, )> c:: w Plaintiffs Massimo Trattoria, Inc., a Pennsylvania Corporation and M s~o ;;, N Napoli, individually, by and through their attorneys, Goodall & Yurchak, P .C:, files the COMPLAINT following Complaint: 1. Massimo Napoli is an individual with an address of 2248 Saw almetto Lane, Building 7, Apt. 117, Orlando, FL 32825. 2. Massimo Trattoria, Inc. is a Pennsylvania corporation with a m i1ing address of 2248 Saw Palmetto Lane, Building 7, Apt. 117, Orlando, FL 328 3. Upon information and belief, Rothman, Schubert and Reed (h referred to as "RSR") is a Pennsylvania General Partnership, with a busine s address of 3 Lemoyne Drive, Suite 100, Lemoyne, PA 17043. 4. Defendant William F. Rothman, an individual, with an address Lemoyne Drive, Suite 100, Lemoyne, PA 17043. 5. Defendant Charles F. Schubert, an individual with an address r-.;} = = c..r" -!'t'" - :::P1,:iI -< t l.O o -n ::;:! ",*- -n 1.'[= -om ::09 0- ,-"c) -r -1"1 ('5 :JJ -'-..(; c5rn --I :1;.. ~JJ -< Lemoyne Drive, Suite 100, Lemoyne, PA 17043. 6. Defendant Samuel L. Reed, an individual with an address of Lemoyne Drive, Suite 100, Lemoyne, PA 17043. 7. On or about November 8, 2004, RSR entered into a Lease A (the "Lease") with Massimo Trattoria for the lease of approximately 2,460 s uare feet of gross leasable area identified as Block H, Unit 7 and 8 with an address of 3 5 East Penn Drive, Enola, Pa 17025 (the "Leased Premises"). A copy of the Leas Agreement is attached as Exhibit "1 ". 8. The Leased Premises is located in Pennsboro Commons Sho ping Center, Cumberland County, PA. 9. The Lease term was for five (5) years. 10. At the time of entry into the Lease, RSR was aware and had b en advised that the purpose of Massimo Trattoria's leasing of the Leased Premises wa for an eat- in Italian restaurant serving lunch and dinner with a high-end atmosphere. 11. At the time the Lease was signed, RSR knew or should have nown that the current heating and cooling units in location on the Leased Premises were not sufficient to allow operation, under the applicable building code requirement , of a dine- in restaurant serving lunch and dinner with a high-end atmosphere. 12. RSR failed to advise Plaintiffs that the current heating and coo ing units were not sufficient. 13. Immediately after the Lease was executed, Massimo Trattoria completing the buildout of the Leased Premises including floor covering, ad plumbing and additional hot water heater as contemplated to serve the Leas d Premises. 14. This buildout, floor covering and additional plumbing was do eat Massimo Trattoria's expense in an amount exceeding $90,000.00. 15. Additionally, Massimo Trattoria and Massimo Napoli individu lIy incurred other expenses in the preparation for the opening of a restaurant including advertising services, utility service and other purchase of equipment totaling approxim tely $35,000.00. 16. Plaintiffs incurred additional damages in time and expenses i preparation for the opening of the contemplated restaurant. 17. After signing of the Lease, construction proceeded at the Lea ed Premises with Massimo Napoli and Massimo Trattoria expending money in preparation for opening of the facility. 18. Construction done at the Leased Premises was subject to pe mitting and inspection by East Pennsboro Township. 19. In December 2004, the East Pennsboro Township Building In pector- Codes Enforcement Officer notified Plaintiffs that it could not provide an oc upancy permit and/or was issuing a stop work order because, among other things, he HVAC equipment was not acceptable to handle the air requirements for the asse occupancy load. 20. Defendants were aware or should have been aware that the equipment could not handle the air requirements for the use of a restaurant as contemplated. 21. In short, RSR leased the Leased Premises to Massimo Tratto ia, which premises could not support its intended use. 22. The Plaintiffs relied on the representations made by RSR re intended use and that the premises would be suitable for a restaurant for facility. 23. Except for the HVAC and air supply issue, Massimo Napoli w position to complete construction to open his restaurant on or about Janua 9, 2005. 24. Because Plaintiffs were not able to open its restaurant due to the air supply restrictions, the Plaintiffs have not been earning income to pay back his bank loan and Lease payments. 25. The inability of Plaintiffs to open their restaurant because of t e current state of the HVAC equipment forced Plaintiffs into a position where they we e unable to open up the restaurant and earn an income. I. Breach of Contract 26. The preceding paragraphs 1 through 25 are incorporated here n by reference as if set forth at length. 27. By failing to provide a Leased Premises which was sufficient f permitted use, Defendants breached the November 8, 2004 Lease Agreem nt. 28. As such, the Defendants are responsible for damages for brea h of Lease, including all expenses related to the build out and accompanying co ts, interests, lost profits and attorneys fees. WHEREFORE, Plaintiffs demand judgment against Defendants for compensatory damages in an amount in excess of $35,000.00 plus costs. II. Recession 29. The preceding paragraphs 1 through 28 are incorporated he in by reference as if set forth at length. 30. The determining motive for the Lease was to secure a Lease Premises for an Italian restaurant. 31. The state of the HV AC was essential for the operation and 0 ening of the business. 32. This determining motive was known to the Defendants at the ime of signing of the Lease. At the time of signing of the Lease, Defendants kne or should have known that the HVAC system was not sufficient to support the determining motive for the Leased Premises. 33. The Plaintiffs did not and should not have known about the st te of the HVAC system. 34. As a result, Plaintiffs seek recision for unilateral mistake relati g to the Leased Premises with attendant damages relating to costs of renovation, a d any other charges incurred as a result of entering into this Lease. WHEREFORE, Plaintiff demands judgment against Defendants for compensatory damages in an amount in excess of $35,000.00 plus costs. III. Fraud/Misrepresentation 35. The preceding paragraphs 1 through 34 are incorporated here n by reference as if set forth at length. 36. The Defendants failed to disclose to the Plaintiffs material fact known to them concerning the Leased Premises, specifically relating to the HVAC sys em. VERIFICATION Massimo Napoli individually and as Massimo Trattoria, avers that th factual averments contained in the foregoing Complaint are true and correct to the best of his knowledge, information and belief, and the statements in said Complaint ar made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsificatio authorities. ,( p.; \~ ~.\ "~,,, .... J C. ~. 37. Defendants through the oral and written statements in the Lase, represented that the facility was sufficient for its intended use. 38. Defendants had a duty to disclose to the Plaintiffs all materia information relating to the state of the premises. 39. The Plaintiff justifiably relied upon the representations made y the Defendants. 40. Had the Plaintiffs known all the material facts relating to the s ate of the Leased Premises, they would not have proceeded with entry into the Leas . As a result of the Defendants'actions, the Plaintiffs were ultimately forced to expend oney for the buildout and construction of the premises. 41. Plaintiffs seek recision of the Lease on the basis of fraud and r misrepresentation, with restitution and for compensatory damages. WHEREFORE, Plaintiffs demand judgment against Defendants for compensatory damages in an amount in excess of $35,000.00 and costs. Respectfully submitted, GOOD L & YURCHAK Kathleen V. Yurch , Esq. PA. 1.0. 55948 328 South Athert State College, P (814) 237-4100 Date: April 27,2005 VERIFICATION I, SAMUEL L. REED, hereby verify that I am of Rothman, Schubert & Reed and, as such, I am authorized to verify the averments of he foregoing document are true and correct to my personal knowledge, information and belief. I nderstand that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904, r lating to unsworn falsification to authorities. ~ Date: t, ,- ~ -0 ~ Ot-L1tV~~-t flJ By: Samuel L. Reed CERTIFICATE OF SERVICE AND NOW, this 9th day of June, 2005, I hereby verify that I have caused ate and correct copy of the foregoing document to be placed in the U.S. Mail, postage prepa d and addressed as follows: Kathleen V. Yurchak, Esquire Goodall & Yurchak, P.C. 328 South Atherton Street State College, PA 16801 , ' ,..../ p -'p < ...::..- -....! ..../ '- t--...) C:::J = <:;Jl <.- (= :I!: o " -f ffi-n f'-' ",:;rP, ~;~O ',j(~ ~-1~; 2~~~ -"}::! ~ .< I \.D :? r:-:) .r.- \.C CENTRAL PA DATA SERVICES, INC., : IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW : 2003 - 2395 CIVIL TERM RICHARD DAME d/b/a Shared Data Services and BANCTEC, INC., Defendants. : JURY TRIAL DEMANDED DEFENDANT BANCTEC. INC.'S PETITION FOR LEAVE TO AMEND NEW MATTER AND NOW, this 22nd day of November, 2005, comes Defendant BANCTEC, [NC. by and through its attorneys, Irwin & McKnight, and petitions this Court under Pa. R.C.P. [033 for leave to amend its new matter, and in support thereof represents the following: 1. [n his complaint, Plaintiff alleges that there is an issue of fact as to whether the Plaintiff was a subcontractor of Defendant, Richard Dame or a temporary employee of Defendant Banctec, Inc. 2. In a prior action against Richard Dame d/b/a Shared Data Services that was filed with this Court at Docket No. 2002 - 2590, Civil Term, Plaintiff pled that it was a subcontractor of Richard Dame d/b/a Shared Data Services, 3, Plaintiff alleged that Richard Dame d/b/a Shared Data Services breached its subcontractor agreement and that Plaintiff had rendered services for which it was owed $107,047.02. 4. In that prior action, Plaintiff received a default judgment against Defendant Richard Dame d/b/a Shared Data Services, 5. The instant action was filed against both the Petitioning Defendant and Richard Dame d/b/a Shared Data Services, requesting the same damages of $107,047.02, 6. Defendant BancTec, Inc. was unaware of the prior action by Plaintiff against Richard Dame until its legal counsel was recently contacted by Defendant Richard Dame. 7. During that conversation, Richard Dame indicated that he had been deposed by Plaintiff, but legal counsel for Defendant BancTec, Inc. had not been part of any such discovery, 8. Defendant Richard Dame subsequently provided a copy of his deposition, upon which time legal counsel for Defendant BancTec, Inc_ was made aware of the prior action filed by Plaintiff and resulting default judgment against Defendant Richard Dame d/b/a Shared Data Services, 9. Plaintiff's current attempt to question his status as a subcontractor of Defendant Richard Dame is barred by his previous admission of the status in the prior suit against Defendant Richard Dame under the doctrines of Judicial Estoppel and/or Collateral Estoppel. See e.g. Wallace v. Workers' Compensation Appeal Board (Bethlehem Steel), 854 A.2d 613, 618 (pa. Commw. 2004). [0, As a general rule, a party to an action is estopped from assuming a position inconsistent with its successful assertion in a previous action. Wallace, 854 A.2d at 618. 2 11, Judicial estoppel is particularly concerned with the integrity of the courts and there is no requirement that the issue actually be litigated or adjudicated. See In re Adoption of S.A..T., 575 Pa. 624, 635-636, 838 A.2d 616, 622-623 (2003) 12. Plaintiff will not be unduly prejudiced or surprised by this amendment, especially since the Plaintiff instituted the prior action, obtained the default judgment, and then elected to file a new action against both the same Defendant Richard Dame d/b/a Shared Data Services and the new Defendant BancTec, Inc. 13. Neither Plaintiff nor its legal counsel informed Defendant BancTec, Inc. of the existence of the prior litigation and judgment for the same amount now claimed against Petitioner. 14, Rule 1033 allows amendment of pleadings at any time with leave of court, and the generally recognized policy is to liberally allow amendments in accord with Rule 126_ See 3 Goodrich-Amram 2d ~ 1033:6, WHEREFORE, Defendant BancTec, Inc. respectfully requests that this Court enter an order allowing defendant to amend its new matter as aforesaid. IRWIN & McKNIGHT Douglas . Mill r, Esquire Supreme Court LD. No. 83776 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Attorney for Defendant, BancTec, [nc, By: Date: November 22,2005 3 VERIFICATION The foregoing document is based upon information that I have gathered in my capacity as corporate counsel and in the preparation of this action, 1 have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. 1 understand that false statements herein made are subject to the penalties of 18 Pa.C.S,A. Section 4904, relating to unsworn falsification to authorities. BANCTEC,INC. "'-1.., //. By: '4~. .-- Date: ,1/ vC-'<u; de /( , 2005 CERTIFICA TE OF SERVICE 1, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by facsimile and/or first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: David A. Baric, Esquire 19 West South Street Carlisle, PA 17013 (Attorney for Plaintiff) Shared Data Services Attn: Richard Dame PNB 204, 60 Chelsea Comers Chelsea, Alabama 35043 (Defendant) Date: November 22, 2005 IRWIN & McKNIGHT L . Miller, Esquire Supreme ourt J.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Attorney for Defendant Banctec, Inc_ \<:: \->,,) C'~ (':"J .J . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVil ACTION - LAW MASSIMO TRATTORIA, INC" a Pennsylvania Corporation and MASSIMO NAPOLI, individually Plaintiffs No. 05-2395 vs, WilLIAM F. ROTHMAN, CHARLES F. SCHUBERT and SAMUEL L REED, co-partners Ud/b/a ROTHMAN, SCHUBERT & REED, a Pennsylvania General Partnership Defendants JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above matter as settled and discontinued with prejudice. GOODAll & YURCHAK, P.C. Dated: December 28, 2005 V. Yurchak, Esq. Atto ne for Plaintiffs Pa . . 55948 3 outh Atherton Street State College PA 16801 (814) 237-4100 , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVil ACTION - lAW MASSIMO TRATTORIA, INC., a Pennsylvania Corporation and MASSIMO NAPOLI, individually Plaintiffs No, 05-2395 vs. WilLIAM F. ROTHMAN, CHARLES F. SCHUBERT and SAMUEL L REED, co-partners tld/b/a ROTHMAN, SCHUBERT & REED, a Pennsylvania General Partnership Defendants JURYTR~lDEMANDED CERTIFICATE OF SERVICE I hereby certify that on this 28'h day of December, 2005, a true and correct copy of the Praecipe to Discontinue has been served by United States first class mail, postage prepaid to the following: John H. Pietrzak, Esq. Reager & Adler, PC 2331 Market Street Camp Hill, PA 17011 ~/ .~ 11 {/l~/// Kathlee . Yurchak, P.C. Attorney for Plaintiff ,-, c:-::> c:? b'"" ,- ~...." ....0-- 1 C,) o -r\ -I :r..., f.~;:f.; ,')'-,-' -', ~,~' S~! ',~)' '"\ -.-\ ~i c-'