Loading...
HomeMy WebLinkAbout06-0433 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SNAP-ON CREDIT, LLC Plaintiff No, Olo - /..j J3 Ct'uiL"T~ vs. COMPLAINT IN REPLEVIN JOHN M . CRIST and JOHN M. CRIST HOLDINGS, INC. Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA!.D. #47437 WELTMAN, WEINBERG & REIS CO., L,P.A. 2718 Koppers Building 436 Seventh A venue Pittsburgh, PAl 5219 (412) 434-7955 WWR 1\0. 049636t8 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DlV1SION SNAP-ON CREDIT, LLC Plaintiff vs. Civil Action No, 0'- - 'i'::: 3 ~TIl- JOHN M . CRIST and JOHN M, CRIST HOLDINGS, INC. Defendants COMPLAINT IN REPLEVIN AND NOTICE TO DEFEND 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 an 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 prope11y or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. OF YOU DO NOT HAVE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP Cumberland County Bar Association 32 South Bedford Street Carlisle, Pa 17013 (717) 249-3166 WWR No. 04963618 COUNT I - REPLEVIN ]. Plaintiff is a corporation having offices at Libertyville, II 60048. 2. Defendant, John M, Crist, is an adult individual residing at 1201 Cross Creek Drive, Mechanicsburg,Pa 17050. Defendant, John M. Crist Holdings, lnc" is a Pennsylvania Corporation doing business at 1201 Cross Creek Drive, Mechanicsburg,Pa 17050. 3. Plaintitl'is the holder ofa Loan and Promissory Note (hcreinaftcr the "Contract'.) and Security Agreement secured by a equipment duly executed and delivered by Defendant in favor of Snap-On Credit. LLC all or about August 13, 2004, A true and correct copy of the Contract and Security Agreement is attached hereto. marked as Exhibit "1" and made a part hereof. 4, Pursuant to said Contract and Security Agreement, Defendant took possession of the equipment more particularly identified in the attached exhibit "2". 5. Snap-On Credit, LLC subsequently assigned its right, title and interest in said Installment Sale Contract and Security Agreement to Plaintiff. 6. Under the terms of the Contract, Defendants were to make Five Hundred and Nineteen (519) consecutive monthly payments of $551.11 beginning May 5.2000. 7. The total principal amount due to Plaintiff pursuant to the Contract was $179.168,22. 8. Plaintiff maintains a first lien on the aforesaid equipment. WWR No. 04963618 9. Defendant is in default of the terms and conditions of the Contract because Defendant has failed to make the required monthly payments since September 26, 2005. ] O. Plaintiff is entitled to immediate possession of said equipment which Plaintiff holds a security interest in and any proceeds of/he equipment by virtue of Defendants' default. 11. Defendant has made partial payment under the Contract leaving an unpaid balance in the amount of $164,619.96 as of January 1],2006. 12. Plaintiff avers that the Contract provides for finance charges at the rate of 10.25% per annum. 13. Plaintiff has performed all conditions precedent as holder of all right, title and interest in the collateral, but Defendant wrongfully remain in possession of the cquipment at the above-stated address. 14. By virtue of Defendants' default. PlaintilThas an immediate right to possession of the equipment covered by the Security Agreement ] 5, Under the terms of the Contract, Defendant has undertaken to pay to Plaintiff its reasonable attorneys' fees and costs of retaking possession of the collateral. WHEREFORE, Plaintiff prays for Judgment against Defendant, John M, Crist and John M. Crist Holdings, Ind., jointly and severally, in Count I of this Complaint In Replevin. as follows: A, For possession of the equipment, morc particularly identilied as a exhibit "2". WWR No. 049636 t 8 COUNT II ACTION IN CONTRACT FOR IN PERSONAM DAMAGES 16. Plaintiff incorporates herein by reference thereto each of the preceding paragraphs of this Complaint in their entirety as if the same were more fully set forth herein. 17, In the alternative to Count I, Plaintiff pleads an action in contract as a result of Defendants' default for the accelerated balance due under the Contract in the amount of $164.619 .96, plus appropriate additional finance charges at the rate of 10.25% per annum on the balance due from January 1].2006 and costs. 18. Under the terms of/he Contract, Plaintiff is entitled to recover reasonable attorneys' fees and costs of retaking possession of the collateral. 19, Plaintiff avers that such attorneys' fees amount to $1,500,00 to date, WHEREFORE, Plaintiff prays for the entry of Judgment on Count II against Defendant, John M, Crist and John M, Crist Holdings, Inc. jointly and severally, in the amount of$164.619.96 plus continuing linance chargcs at the aforesaid rate of 1 0.25% per annum from January 11. 2006, expenses for retaking possession. attorneys fees of $1,500.00 and costs, WELTMAN. W9,dNBERG AND REIS. CO, L.P.A. t/," / 1'/1. i /.......----: II. V~ 1_.. (;tr--- William . Molcza Sq~. PA J.D. #47437 / WELTMAN, WEINBER(f & REIS CO., L.P.A, 2718 Koppers Building 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR 1\0.04963618 LOAN AND SECURITY AGREEMENT . .. This Lc:'AN AND SEC~ AGREEMENT (this "Agreement") is made between Snap-on Credit LLC, a Delaware limited liability company with Its pnnclpal place of bus mess at 1125 Tn-State ParJ..."'Way, Gurnee, Illinois, 60031 ("Lender"), and JOHN M. CRIST HOLDINGS. INC. ("Borrower"), a corporation with its principal place of business at 120J CROSS CREEK DR. MECHANICSBURG, FA 17050. WHEREAS, Borrower has entered into a Dealer Franchise Agreement with Snap-on Tools Company LLC ("Snap.on"), an affiliate of Lender, pursuant to which Borrower will operate a Snap-on dealership ("Dealership"); and WHEREAS, in order to finance certain costs associated with the Borrower's Dealership and to provide working capital for such Dealership, Borrower desires to borrow, and Lender is willing to lend money to Borrower upon the terms and conditions herein (the "Dealer Finance Program"). NOW, THEREFORE, the Lender and Borrower hereby agree as follows: I. TIlE LOAN. Subject to the tenns and conditions of this Agreement, Lender will lend to Borrower the sum of$]79.]68.22 and such additional amounts as agreed by addendum by the parties from time to time (the "Loan"). The Loan shall be evidenced by Borrower's promiss01)' note(s), in fonn and substance acceptable to Lender, in the principal amount specified in the preceding sentence (hereafter collectively referred to as the "Note"). The Note shall be executed and delivered to Lender before or concurrently with Lender's disbursement of the Loan. The unpaid principal amount of the Loan shall bear interest and shall be due and payable as provided in the Note. As used in this Agreement, the term "Borrower's Liabilities" shall include principal and interest under the Note and any additional notes, together with all costs and expenses (including reasonable attoTlleys' fees) to he paid by Borrower as provided in this Agreement together with any other amount owed under any other agreement between Borrower and Lender or Lenders and Assignees or under any Lender sponsored van lease program ("Van Lease Program"). 2. GENERAL TERMS. a Default Rate. After the occurrence of an Event of Default under this Agreement and so long as such Event of Default continues, the Note and all other Borrower's Liabilities shall (subject to any limitations of applicable law) bear interest at rates per annum equal to the respective rate applicable to such Note and other Borrower's Liabilities prior to such Event of Default plus four percent (411/,,), or the maximum rate pennitted by applicable law. b. Pavrnents. All payments under this Agreement and with respect to a Note shall be made in immediately available funds by Borrower to Lender by debiting Borrower's bank account, pursuant to instructions duly executed by Borrower and delivered to Borrower's bank, on the date when payments are due. Prepayments, if pennitted hereunder or under a Note. may be made at Lender's offices at 1125 Tn-State Parkway, Gurnee. Illinois, 60031 ('ILender's Principal Office") or at such other 10catiQn as Lender may designate. Whenever any payment to be made hereunder or with respect to a Note shall be stated to be due on a date other than a business day (or if Borrower's bank is not open on a business day when an account is to be debited), such payment shall be made on the next succeeding business day, and such extension of time shall be included in the computation of interest or any fees. As used herein, "business day" means any day on which Lender is open for business at Lender's Principal Office. Lender may, at its option and upon notice to Borrower, require Borrower to make all payments in immediately available funds to Lender at Lender's Principal Office. c. Mandatorv Preoavrnent for Reiected Revolvine: Accounts. In the event Borrower receives Loan funds for the acquisition of accounts receivable, commonly referred to as "Revolving Accounts" ("RA's") and Borrower rejects all or any portion of said Revolving Accounts within forty-five (45) days from date of disbursement of this Loan in accordance with the provisions of Borrower's Dealer Franchise Agreement with Snap-on, then upon receipt of reimbursement from Snap won for said rejected Revolving Accounts, Borrower shall be required to prepay a portion of the Loan in an amount equal to the amount loaned for the acquisition of the rej~cted Revolving Accounts, d. Van r ease Reouirement. Borrower acknowledges that Borrower is obligated under his Dealer Franchise Agreement to acquire a van meeting certain specifications. Borrower acknowledges that the van is an integral part of Borrowers business operations. Borrower shall be obligated under this Agreement to meet said van requirements through a purchase or lease of a designated van from a designated source. However, if Borrower acquires a van with no continuing financial obligations by Borrower, then this specified van requirement shall not apply, Van leasing may be with a third party unrelated to Lender ("ussor"). Borrower agrees to permit any infonnation regarding the van lease to be obtained from Lessor at any time during the term of this Agreement. In the event Borrower elects to pwiicipate under this Dealer Finance Program and enter into this Agreement, Lender shall designate both the van and the source. Payment for said van lease or purchase shall be made through Lender in accordance with Section 2.b above and the van lease Of purchase documents. Lender shall forward payments to Lessor or lender of Ute van; provided, however, that in no event shall Lender be obligated to make payments on behalf of LesseefBorrower when such payment has not been paid to Lender by Borrower. No portion of Borrower's payments to Lender with respect to the van lease shall be retained by Lender beyond the period necessary for transmittal on a monthly basis to Lessor or Lessors agent. e. Aoolication of Payments. Lender will apply against Borrower's Liabilities, on the date of receipt all payments received thereon, including cash, collections of Accounts Receivable, proceeds of Collateral (as hereinafter defined) and any other amounts; provided that (n Lender shall charge back to Borrow~r any payments that may be required to be returned to the entity making such payment and Borrower shall continue to pay interest on the amount charged back from the date that such payment was applied against Borrower's Liabilities; (ii) Lender shall have the exclusive right to determine how, when and in what amounts application of such payments and such credits shall be made on Borrower's Liabilities, and such determination shall be conclusive and binding upon Borrower. Lender's decision with respect to payment of Borrower's Liabilities shall in no way relieve Borrower from its obligation for payments. under Borrower's van lease or unoer this Agreement or any other agreement. Pwiial prepayments by Borrower, if permitted, shall not relieve Borrower from Borrower's obligation to make weekly payments. Prepayments may be subject to a prepayment premium and pwiiaI prepayments may be prohibited as provided under the Note. Notwithstanding the foregoing or the tenns of any Note, in the event the Borrower's Dealership is tenninated, unless tennination is due to the relocation to another Dealership, Borrower shall not be obligated to pay a prepayment premium or penalty, If Borrower's Dealership is relocated, provided Borrower is not in default under this Agreement or any Note, Borrower may elect to continue the existing Loan and, thus, avoid a prepayment penalty. If upon relocation, Borrower elects to repay the Loan in full. then Borrower may be subject to a prepayment premium as pro~ided under the Note. 1 12/01 LSA 03/03 EXHIBIT l .. f. Late Charees and NSF Check Charees. To the extent pennitted by and subject to applicable law, if Borrower fails to make payments under the Loan within 10 days after the due date, Borrower may be assessed a Late Charge of $10.00 or 5% of the amount due. whichever is greater (or the maximum permitted by applicable law if less). To the extent permitted by and subject to applicable law. if Borrower makes payments by check under the Loan and Borrower's check is not paid because of non-sufficient funds in Bonower's checking account or a closed accoW1t, Borrower may be assessed an NSF Check Charge of $25.00 (or the maximum permitted by applicable law iflcss). g. Statement of Account. An of Borrower's Liabilities shall constitute one loan secured by the Collateral and by all security interests, liens, claims and encumbrances heretofore, now or from time to time hereafter granted by Borrower to Lender. In determining Borrowers Liabilities, the books and records of Lender shall be controlling. All statements of accounts rendered by Lender to Borrower concerning Borrower's Liabilities hereunder, including all statements of principal, interest, fees, expenses and costs owing to Lender by Borrower, shalt be presumed correct and accurate and shall constitute an account stated between Lender and Borrower unless Borrower, within 180 days after receipt of the statement, delivers to Lender written objection, specifying the error or errors, if any, contained in such statement. Lender, at its sole discretion, may request Borrower to certify as to the accuracy of Lender's records relative to Borrower's Liabilities and Borrower shall comply within 30 days of such request. 3. COLLATERAL a. Descrintion, Borrower hereby grants and assigns to Lender, and agrees that Lender shall have, a security interest in the following business property, assets, rights and interests of Borrower, whether now owned or existing or hereafter acquired or arising (collectively, the ~Conateraln): i. All of Borrower's Accounts (the tenn "Accounts" as used herein includes, without limitation, aU of Borrower's accounts receivable arising out of the sale or lease of Inventory or other goods or out of the rendering of services), whether or not specifica1.1y assigned to Lender~ ii. All of Borrower's Inventory (the term "Inventory" as used herein includes, without limitation, all of Borrower's goods held for sale or lease or being processed for sale or lease, including all materials, work-ill-process, finished goods, supplies and other goods - customarily classified as inventory), including Inventory at any time in the possession of any bailee; iii. All of Borrower's business equipment (1he "Equipment"); iv. All of Borrower's goods, vehicles, (including Borrower's van or truck) furnishings and fixtures wherever located but only to the extent that such items are used primarily in connection with Borrower's Dealership; v. All of Borrower's cash, negotiable instrUments, documents of title, warehouse receipts, chattel paper, general intangibles, securities, leases, contract rights, certificates of deposit, deposit accounts, cash equivalents, interest or dividends on any of the foregoing, insurance claims, patents, trademarks, good will and other property of any kind or description, wherever now or hereafter located, but only to the extent that such items are used primarily in connection with Borrower's Dealership; and vi. Without limiting the foregoing, all substitutions, renewals, improvements and replacements ot: and additions and accessions to, the foregoing, and all products and proceeds of the foregoing, including, without limitation. all of the proceeds in any form of Borrower's Accounts and Inventory, whether specifically assigned to Lender or not. Notwithsttmding the foregoing, if Borrower is an individual, Borrower's residence, personal, family or household goods and assets not related to or used primarily in connection with Borrower's Deatership are specifically excluded from the definition of "Collateral." The tenns used herein to identify the Collateral shall have the respective meanings assigned to such tenns as of the date hereof in the Uniform Corrunercial Code, as amended, in effect in the state listed in the introductory paragraph as Borrower's adrlress (the "Dee"). The security interest granted hereby shalt continue to attach to the Collateral notwithstanding MY sale, exchange or other disposition of the Collateral by Borrower, except for Inventory sold in the ordinary course of business. The security interest herein granted is to secure the payment of all of Borrower's Liabilities and the perfotll1ance of all of Borrower's obligations to Lender hereunder and any and all other obligations of Borrower to Lender of every kind and description, direct or indirect, absolute or contingent, due or about to become due, now existing or hereafter arising. b. Financiml Statements. Borrower shall sign and deliver such financing statements and other documents, in form satisfactory to Lender, as Lender may at any time reasonably request in order to effectuate or perfect Lender's security interest in the Collateral hereunder, or facilitate the reaJization by Lender upon the Collateral, or any part thereot: and shatl reimburse Lender for the costs of preparing and filing the same. Further, to the extent permitted by and subject to applicable law, Borrower hereby grants Snap-on or its agent or assigns the power of attorney and right to sign on behalf of Borrower and file or record, any and all such financing statements and related documents as may be necessary to perfect or maintain the security interest granted by Borrower under this Agreement. Borrower authorizes Lender the right to describe the collateral in any financing statement as "all business assets." This statement in any financing statement shall not expand or limit the property given as security for perfonnance of obligations under this Agreement as described above. c. lnsocction. Lender or its agents may at any reasonable rime conduct a physical audit of Borrower's Inventory and inspect the CoUateral and the books. and records of Borrower pertaining to the Collateral, or any part thereat: and may make or require Borrower to furnish copies or extracts from such books and records. Borrower, at its sole cost and expense, shall keep and maintain satisfactory and complete books and records of the Collateral until all of Borrower's Liabilities shall have been fully paid and discharged. Lender shall have a special property interest in and to any and all books and records of Borrower pertaining to the Collateral, including any books and records retained by Snap-on Tools Company LLC or its subsidiaries or affiliates, and upon the occurrence of an Event of Default Borrower shan deliver such books and records to Lender at the demand of Lender. At the request of Lender, Borrower shall duly cause its accounts receivable ledger and other books and records relating to the Collateral to be stamped, in fonn and manner satisfactory to Lender, with a proper reference to the fact that the Collateral has been assigned to Lender. d. Preservation. Lender may, but shall not be obligated to, take such action from time to time as it may in its sole judgment deem appropriate to maintain or protect the Collateral, and for that purpose may, among other things, at its option (i) payor obtain the removal of any tax, lien, security interest, claim or encumbrance that may be levied or placed on or with respect to any of the Collateral; (ii) pay the costs of insurance on any of the Collateral; or (Hi) make any payment under any lease or contract to which Borrower is a party in order to cure or avoid a default thereunder. Borrower shall reimburse Lender, promptly upon demand by Lender, for any costs or expenses incurred by Lender in the protection or maintenance of the Collateral, including the expenditures described herein and any costs to move the Collateral to another location. Lender shall have exerdsed reasonable care in the custody and preservation of any Collateral in its possession or control if it takes such action for that purpose as Borrower shall request in writing, but the failure to comply with any such request shall not be deemed a failure to exercise reasonable care. Borrower shall have the sole responsibility for taking such steps as may be necessary from time to time to preserve all rights of Borrower and Lender in the Collateral against other parties. Borrower shall keep the Collateral in good condition and repair and shall not waste, destroy, hide, misappropriate any of the Collateral. c. Insurance. Borrower shall maintain in effect at all times policies of insuring against loss of or damage to all tangible property constituting Collateral. Such insurance shall, except as may othelWise be agreed to 2 12/01 LSA 03/03 .. in writing by Lender, (i) cover all risks, (ii) be in amounts equal to the full value of the Collateral, (iii) be provided by such companies as are satisfactory to Lender, (iv) contain a lender's [ass payable clause naming Lender as payee as its interest may appear, and (v) provide at least 10 days' prior wrinen notice to Lender of any cancellation. Borrower shall cause a certificate of insurance evidencing the insurance coverage required under this Agreement to be delivered to Lender prior to the closing of the Loan under this Agreement After an Event of Default, as hereinafter defined, Lender may act as attorney for Borrower in obtaining and canceling such insurance and in adjusting and settling any claims with respect thereto and endorsing any drafts received as a result thereof. f. Liens. Borrower represents and warrants that the Collateral is, and covenants and agrees that it will keep the Collateral free from, any lien, security interest (other than the security interest herein granted; other security interests granted to Lender, Snap-on Tools Company LLC, or their affiliates; and other liens pennitted under Section 5.aii below), claim or encumbrance, and agrees to defend the Collateral against any and all claims and demands of all persons at any time claiming the same or any interest therein. g. Use. Borrower shall not sell, assign, lease, transfer or convey any of the Collateral or any interest therein; provided that, so long as no Event of Default, as hereinafter defined, has occurred under this Agreement, Borrower may sell Inventory in the ordinary course of business (not including any transfer in connection with or in satisfaction of any debt) and may sell or assign Accounts and equipment leases to Lender, Snap.on Tools Company LLC, or their affiliates in the ordinary course of business. Borrower may use and consume any supplies, the use and consumption of which is necessary in order to carry on Borrower's business, may use and operate any Equipment and may otherwise use the Collateral in any lawful manner not inconsistent with this Agreement, so long as no Event of Default has occurred under this Agreement. h. Locations. Borrower represents and warrants that all Collateral shall be kept at the location indicated in the first paragraph of this Agreement or other location preapproved by Lender; provided that Borrower may move its business vehicles and their contents, including Inventory and Equipment, so long as they are routinely returned to the referenced location. Borrower shall notify Lender promptly in writing of any change in Borrower's address or in the location of any Collateral or use of any other names under which it is doing business. i. Collection of Accounts. The collection of the Accounts and the application of the proceeds received therefrom shall be subject to the following: i. Borrower is authorized to collect the Accounts or any part thereof, but such authorization may be restricted or terminated by Lender at any time in the Event of Default, as hereinafter defined. Borrower shall not, without the prior written consent of Lender (i) grant any extension of time for the payment of the Accounts; (ii) compromise, compound or settle the Accounts or any part thereof for less than the full amount thereof; (iii) release, in whole or in part, any person liable for the payment of the Accounts or any part thereot: or allow any credit, discount or allowance whatsoever upon the Accounts or any part thereof, unless such activity shall be deemed to be in the ordinary course of Borrower's business and will not occasion or threaten a material adverse change in the financial condition or results of Borrower's business operations. ii. Upon the occurrence of an Event of Default (as hereinafter defined) Lender may, without notice to or assent of Borrower, extend the time of payment or compromise, settle for cash or credit or otherwise settle, upon any terms or conditions, any part of the Accounts and thereby discharge or release the person or persons liable for the payment of the Accounts or any part thereof without affecting Borrower's Liabilities to Lender. Lender may. but shall not be obliged to, demand or enforce payment of the Accounts or any part thereof and shall not be liable for its failure to collect or enforce the payment thereof or for the negligence of its agents or attorneys with respect thereto. iii. Upon the occurrence of an Event of Default, Lender, without notice to Borrower, may notifY any person. corporation or partnership (the "Obligorn) liable for the payment of any Account of the fact that the Account has been assigned to Lender and may direct that payment of such Account be made directly to Lender. If Lender so requests after the occurrence of an Event of Default, all bills and statements rendered by Borrower to the Obligor shall state that the same has been assigned to Lender and is payable solely to Lender. When requested by Lender after the occurrence of an Event of Default, Borrower will notifY or cause to be notified the Obligor to pay directly to Lender any sum or sums then due or to become due on account of the Accounts or any part thereof. 4. REPRESENTATIONS AND WARRANTIES OF BORROWER. a. Borrower represents and warrants to Lender that, except as may have been previously disclosed in writing to Lender; i. Borrower is a sole proprietor of an unincorporated business or is a duly organized, validly existing corporation or limited liability company in good standing under the laws of its jurisdiction of organization, and, if a corporation or a limited liability company, is duly qualified and in good standing and authorized to do business in each other jurisdiction where, because of the nature of Borrower's activities or properties, such qualification is required; ii. The execution and delivery of this Agreement, the borrowings hereunder, the execution and delivery of the Note, and the perfonnance by Borrower of its obligations under this Agreement and the Note are within Borrower's powers and have been duly authorized by all necessary action (corporate or other), and do not and will not contravene or conflict with any provision of any organizational documents (including, without limitation. any articles of incorporation or by-laws) of Borrower or of any agreement or other document binding upon Borrower or to which its assets are subject; iii. This Agreement is, and the Note, when executed and delivered will be legal. valid and binding obligations of Borrower enforceable against Borrower in accordance with their respective tenns, subject only to bankruptcy, insolvency and other similar laws generally relating to or affecting the enforceability of creditors' rights; iv. There are no legal. governmental, arbitration or other actions or proceedings which are pending or threatened against Borrower which might result in (a) any material adverse change in Borrower's financial condition, or results of Borrower's business operations; or (b) materially and adversely affect Borrowers' use of Borrower's property or assets, including the Collateral; v. Except as disclosed in the financial statements of Borrower most recently delivered to Lender pursuant to or in connection with this Agreement, Borrower has no indebtedness or other liabilities; vi. Borrower is solvent and generally paying its debts as they mature, and Borrower has capital sufficient to carry on its current and proposed business and transactions; vii. The financial statements, schedules and other infonnation furnished to Lender prior to and after the execution and delivery of this Agreement fairly and accurately present the financial condition and, if applicable, results of operations of Borrower (and any other persons described therein) as of and for the period ending on the date as of which such financial statements are presented; and since the date of the financial statements of Borrower most recently furnished to Lender, there has been no material adverse change in the financial condition or results of business operations of Borrower; viii. Borrower has timely filed all material tax returns and reports required to be filed by Borrower with any governmental entity, and has timely paid all taxes, assessments, fees and other charges upon Borrower and upon Borrower's properties, assets and income due and payable; ix. None of Borrower's Liabilities violates the provisions of the usury laws or any other laws governing interest rates of any state having jurisdiction over Borrower's Liabilities, this Agreement or any transaction contemplated hereby; and the Loan is a loan to a business 3 12/01 LSA 03/03 ... and each of Borrower's Liabilities under this Agreement is primari\)' for a business or commercial purpose and does not consist of or involve any credit offered or extended to a consumer primarily for personal, family or household purposes; and x. The Borrower is not in violation of any applicable law, regulation or ordinance of the United States of America or any state, city, town, municipality, county or other jurisdiction. or arWlY agency or instrumentality of any of the foregoing, in any respect materially and adversely affecting its financial condition, results of operations of Borrower's business. Of its property or assets, including, without limitation, any law, regulation or ordinance relating to occupational health or safety or protection of the environment, including hazardous substances. b. Borrower further represents and warrants that as of the date of this Agreement and as of the disbursement of the Loan, Borrower is in full compliance with aJl of Borrower's covenants under this Agreement and there does not exist any Event of Default or other event which, but for the passage oftime or giving of notice would be an Event of Default. 5. COVENANTS OF BORROWER. a Nee:ative Covenants. Borrower shall not: i. Sell, assign, lease, transfer or convey any of Borrowers property or assets or any interest therein except sales of Inventory, sales or assignmerlts of Accounts and equipment leases to Snap-on Tools Company LLC, Lender, or their affiliates, and use of cash in the ordinary course of business; and Borrower shall at all times have good title to and ownership of its property and assets, including the Collateral, and shall, except as permitted in Section S.a.\\ below, not allow, suffer or cause to exist thereon any lien, claim, security interest or encumbrance (including, without limitation, any lien or encumbrance of any governmental entity or agency or with respect to any taxes or debts owed thereto); provided that Borrower shall have the right to contest, in good faith, with reasonable diligence and by appropriate proceedings, the validity of any lien or encumbrance or claim thereot: but only if none of the property or assets of Borrower is subject to sale or foreclosure during such contest, and Borrower shall promptly pay any judgment rendered against Borrower in connection with any such contest~ ii. Incur any indebtedness or guarantee or otherwise become liable with respect to the obligation or indebtedness of any other person or entity, whether for borrowed money or otherwise, except for (a) indebtedness incurred in connection with the lease or purchase of Borrower's van, computer system and other business equipment, provided Lender consents in its sole discretion to such loan or lease, (b) Borrower's Liabilities and any other indebtedness owed to Lender, (c) extensions of the maturities of existing indebtedness and interest thereon, (d) indebtedness which is unsecured and is to persons who execute and deliver to Lender (in fonn and substance acceptable to Lender) agreements subordinating such indebtedness and their claims against Borrower irl connection therewith to the payment of Borrower's Liabilities, (e) indebtedness for personal, family or household purposes that is either unsecured or secured by assets other than the Collateral, and (f) trade payables and other obligations arising in the ordinary course of business; iii. Enter into any transaction which materially and adversely affects Borrower's ability to repay Borrowers Liabilities or any other indebtedness of Borrower; iv. Close or deplete the bank account from which payments on the Note are to be debited pursuant to Section 2.b above, unless suitable arrangements are made upon 30 days' written notice to Lender prior to such closure or depletion for Lender to debit a different bank account; and v. Use the Loan or any portion thereof to make any "R.A. Deposit" or other payment to Snap-on Tools Company LLC or its affiliates (other than Lender) except payments for the purchase of Inventory, Accounts or other assets for use in Borrower's Dealership. b. Affirmative Covenants. Borrower shall: i. Operate Borrower's business and properties in accordance with and comply in all respects with all applicable laws, regulations and ordinances of the Unitea States of America, of any state, city, town, municipality, county or other jurisdiction, and of any agency or instrumentality of any of the foregojng~ ii. Timely file all tax returns and reports required to be filed by Borrower with any governmental entity, and timely pay all taxes, assessments, fees and other charges upon Borrower and upon Borrower's properties, assets and income; Hi. Maintain sufficient funds in the bank account to be debited pursuant to Section 2.b above to make each payment on the Note and under this Agreement when and as due; iv. Maintain levels of Inventory (at Borrower's cost) and Accounts (excluding Accounts or equipment leases sold or assigned to Snap-on Too]s Company LLC, lender or their affiliates in exchange for consideration other than the Loan) at least equal to the original principal amount of the Loan less any mandatory prepayments as required herein; v. Use the Loan solely to acquire Inventory, Accounts and other assets and for working capital in conneCtion with the commencement and operation of Borrowers Dealership; vi. Prepare and deliver to Lender, from time to time as requested, financial statements and other information regarding the financial condition and result'i of operations of Borrower's Dealership; and vii. Comply with all tenus of the van lease and any van maintenance agreement. 6. DEFAVL T AND ACCELERATION BV LENDER. a. Automatic Acceleration Without Notice. Borrower shall be deemed in default under this Agreement and Lender may, at its option, without prejUdice to any and all other rights and remedies it may have under this Agreement or under applicable law, accelerate the Loan and declare the entire unpaid amount of Borrower's Liabilities to be immediately due and payable under this Agreement without notice to Borrower in the following instances each of which shall be considered an Event ofDefau]t: i. If Borrower is adjudicated a bankrupt or becomes insolvent, or has a trustee or receiver appointed by a court of competent juriSdiction for all or any part of Borrower's property; or ii. If a plan of liquidation, reorganiZation, composition or arrangeroer.t ofBoITOwer's Bflairs is sought to be instituted for or against Borrower, whether or not the same is subsequerltly approved by a court of competent jurisdiction; or Hi. If a proceeding is filed under any bankruptcy laws or other similar laws and such proceeding is not dismissed within ninety (90) days after filing; iv. If Borrower makes a genera] assignment for the benefit of creditors; or v. Upon the death or incapacity of Borrower (or the stockholder of a corporate Borrower)~ or vi. If Borrower shall cease to be an authorized Snap-on Dealer because of the termination of,. or the transfer or assignment of rights under, the Dealer Franchise Agreement, the Conversion Dealer Franchise Agreement, or any other Dealer Agreement betweerl Borrower and Snap-on Tools Company LLC (or an affiliate thereof). b. Acceleration Uoon Notice. Borrower shall be deemed in default under this Agreement and Lender may, at its option, without prejudice to any and all otl1er rights and remedies it may have under this Agreement or under applicable law, accelerate the Loan and declare the entire unpaid amount of Borrowers Liabilities to be immediately due and payable under this Agreement effective upon Borrower's receipt of written notice of acceleration in the following instances each of which shall be considered an Event of Default i. If Borrower fails to satisfy any material judgment against Borrower within thirty (30) days after the judgment is entered and becomes final; or ii. If any representation or warranty of Borrower contained in this Agreement or in any document or instrument delivered pursuant to this Agreement is untrue or incorrect; or 4 12101 LSA 03/03 . .. Hi. If Borrower falsifies any report or document required to be furnished Lender, or has made a material misrepresentation in connection with the approval of Borrower under this Agreement, or engages in conduct involving dishonesty in dealing with Lender; or iv. If Borrower has any obligations outstanding to Lender under this Agreement and Borrower's equity, as determined in accordance with a physical inventory, and review of RA balances has declined from the previous inventory and review of RA balances (or, if no physical inventory has yet been conducted, since Borrower began operations) and Borrower's equity in Borrowers Dealership is not restared by the next physical inventory and review of RA balances (which may be taken thirty (30) days or more after the previous inventory); or v. If Borrower remains in default beyond the applicable cure period, if any, under any other vvritten agreement with Lender or Snap- on (or any subsidiary or affiliate of Snap --on) or under any van lease; or vi. If any guarantee of any of Borrower's Liabilities is tenninated or limited fOf any reason, including, without limitation, because of revocation or the death of any guarantor. c. Acceleration UnoR Exniration of Cure Period. i. Except for those items listed in preceding Sections 6,8 ~ b, Borrower shall have thirty (30) days after written notice of default from Lender within which to remedy any Event of Default under this Agreement, including but not limited to, those items set forth below as (1) through (3) of this Section 6c, and provide evidence of that remedy to Lender. If any such default is not cured within that time, Lender may accelerate all Loans and declare the entire unpaid amount of Borrower's Liabilities to be immediately due and payable without further notice to Dealer effective immediately upon expiration of that time, unless Lender shall notifY Borrower otherWise in writing. (1) Failure by BDrrower to comply with the proviSions of this Agreement or any van lease or any other written agreement with Lender (or any subsidiary or affiliate including Snap-Dn Tools Company LLC) or tD carry out the tenns of this Agreement in good faith; Dr (2) Failure of BOIJower to observe or to comply with any of the covenants set forth in this Agreement, or (3) Failure of Borrower to submit when required any reports pertaining to the Dealership. ii. Notwithstanding the provisions of preceding Section 6.c.i, if the Event of Default consists of Borrower's failure tD pay any monies owed to Lender when such monies become due and payable, whether pursuant to this Agreement, any Loan, or otherwise (whether upon maturity, acceleration or otherwise), and Dealer fails to pay such monies within ten (10) days after receiving "Mitten notice of default, then, unless Lender shall notifY Borrower otherwise in writing, the entire amount Df Borrower's Liabilities and all balances due under this Agreement shall be accelerated and shall be immediately due and payable in full without prejudice to any and all other rights and remedies Lender may have under this Agreement or under applicable law. 7. EFFECT OF DEFAULT AND ACCELERATION ON BORROWER'S RIGHTS. If an Event of Default under this Agreement shall occur, then Lender may, at its option, exercise any Dne or more of the following rights and remedies: a, Ifno Loan has been disbursed, Lender may tenninate and cancel this Agreement, or if an additional Loan has not been disbursed, Lender may refuse to disburse the additional Loan amount; b. Lender may accelerate all Loans and declare the entire unpaid amount of Borrower's Liabilities to be immediately due and payable; c. Except as may Dtherwise be required by law, Lender (a) may sell aU or any of the Collateral at public or private sale or sales upon such tenns and conditions as Lender deems proper (and Lender may purchase any or all of the Collateral at any such sale), and apply the net proceeds of such sale, after deducting all costs, expenses and attorneys' fees incll-md at any time in the collection of Borrower's Liabilities and in the protection and sale of the Collateral or Lender's assignee or vendors under any Van Lease Program, first to the payment of Borrower's Liabilities and then to the payment of any other liabilities of Borrower to Lender, and shall return any remaining proceeds to Borrower; provided that Borrower shall remain liable for any Borrower's Liabilities or other amounts remaining unpaid alter such application and interest thereon; and (b) may take such other actions as it may deem appropriate or in its interest with respect tD the Collateral including, without limitation, (i) transferring the whole or any part of the Collateral intD its name ortbe name Df a nominee, (ij) collecting any amounts due on the Collateral directly from the persons obligated thereon, (iii) exercising any voting or other rights with respect to any Collateral consisting Df securities, (iv) taking possession and control of the Collateral and any proceeds thereof and (v) suing or making any compromise or settlement with respect to any of the Collateral; and d. Lender may exercise from time to time any rights and remedies available to it under all applicable laws, including, without limitation, the uee and the commercial cDde of any other applicable state. In addition to and not in limitation of all rights of ofiSet that Lender may have under applicable law, Lender shall, upon the occurrence of an Event of Default, have the right to appropriate and apply to the payment of and to set-off against Borrower's Liabilities any and all balances, credits, accounts or money of Borrower then or thereafter received or held by or under the control of Lender. Except as may otherwise be required by law, including with respect to notice of any sale of Collateral, Borrower hereby waives, in connection with this Agreement and Borrower's Liabilities. any right under or benefit of any law (whether or not intended for its advantage or protectiDn) that would restrict or limit the right or ability of Lender to obtain payment of Borrower's Liabilities, including any law that would restrict or limit Lender in the exercise of right to appropriate at any time hereafter any indebtedness owing from Lender to Borrower and any property of Borrower in the possession or control of Lender and apply the same toward or set-off the same against the payment of Borrower's Liabilities. AU rights of Lender under this Agreement are cumulative. 8. INDEMNIFICATION BY BORROWER. Borrower shall indemnitY and hold Lender, its officers, directors, agents and employees from and against any and all loss, liability or damage (including attorney's fees) arising out of or related to <t) Borrower's violation of applicable law, including. without limitation, any law, regulation or ordinances relating to taxation, employment, the environment or hazardous substances; and (ii) any hazardous substances disposed of or located, released or transported from any property oWIled, leased or used by Borrower, or (iii) any claim of my of the foregoing. 9. ARBITRATION; CERTAIN WAIVERS; MISCELLANEOUS. a. Agreement to Arbitrate. Except as otherwise provided in Section 9(d) below, any controversy or dispute arising out of, or relating to the Dealership or this Agreement including, but nDt limited to, any claim by Borrower, or any person in privity with or cla.itning through, on behalf of or in the right of Borrower, concerning the entry into, perfonnance under, nomenewal of, or tennination of, this Agreement; any claim against a past or present employee. officer. director, agent or affiliate of Lender; any claim of breach of this Agreement or any agreement between the parties or their respective affiliates (whether existing before or after this Agreement); and any claims arising under state or federal laws. including any statutes, rules, or regulations, shall be submitted to final and binding arbitration as the sole and exclusive remedy for any such controversy or dispute. Unless prohibited by applicable law, any claim shall be made by filing a written demand for arbitration within one (1) year following the conduct, act or other event or occurrence first giving rise to the claim; otherwise, the right to any remedy shall be forever bartOO. Persons in privity with or claiming through, on behalf of or in the right of Borrower include, but are not limited to. spouses and other fantily members, heirs, executors, representatives, successors and assigns. BORROWER AND LENDER ACKNOWLEDGE AND AGREE 5 12101 LSA 03103 TIlAT, BY ENTERING INTO AN ARllITRATlON AGREEMENT, THEY ARE WAIVING ANY RIGHT TO A TRIAL BY JURY IN ANY COURT PROCEEDING. b. Procedures for Arbitration. The right and duty of the parties to this Agreement to resolve any disputes by arbitration shall be governed exclusively by the Federal Arbitration Act, as amended, and arbitration shall take place according to the commercial arbitration rules of the American Arbitration Association in effect as of the date the demand for arbittation is filed. The arbitration shall be held at the office of the Amerit;;an Arbitration Association nearest the Snap-on Branch Office to which Borrower was assigned prior to the dispute; provided, however. if such office is outSide the state in which the Borrower resides, Borrower may cause the arbitration to be held within the Borrower's state of residence at a place mutually convenient to the parties and the arbitrator(s). The arbitration shall proceed before either a single arbitrator Of three arbitrators. Borrower shall have the option to choose within 10 days after the filing of a demand for arbitration between whether to proceed before one arbitrator or three arbitrators. Failure to select the number of arbitrators within the time allowed shall result in the use of a single arbitrator. If a single arbitrator procedure \s selected, the arbitrator shall be chosen by the striking method from a panel of neutral arbitrators provided by the American Arbitration Association. Lender shall pay the fees and expenses of the single arbitrator and shall also pay the filing fees and costs charged by the American Arbitration Association to the extent they exceed the amount the Borrower would otherwise have had to pay to file a suit in court. If a three arbitrator procedure is selected, each pany shall cboose one arbitrator and the two so chosen will select a third, and failing selection of an arbitrator by either party or by the two chosen by the parties. the arbitrator(s) shall be selected from a panel of neutral arbitrators provided by the American Arbitration Association and shall be chosen by the striking method. In a three arbitrator procedure, the parties sball bear their own costs of the arbitration, provided, however, that the fees and ex:penses of the arbitrators shall be paid 50% by each side. Unless otherwise agreed by the parties or ordered by the arbitrator(s), pre~hearing discovery in any arbitration is limited to the following: (1) production of all documents that will be introduced at the hearing; (2) production of written or recorded statements; (3) production of all documents relied upon by experts in the hearing; and (4) not more than two depositions per side. c. Limitation on Damav.es. Enforceability. Each party further agrees that. unless such a limitation is prohibited by applicable law. the other party shall not be liable for punitive or exemplary damages and that the arbitrator{s) shall have no authority to award the same. The award or decision by the arbitrator(s) shall be final and binding on the parties and may be enforced by judgment or order of a court having subject matter jurisdiction in the state where the arbitration took place. The parties consent to the exercise of personal jurisdiction over them by such courts for the purpose of carrying out this provision; and they waive any objections that they would othern<ise have to the same. Unless prohibited by applicable law, (i) no arbitration under Section 9 shall include, by consolidation, joinder or in any other manner, any person other than Borrower and Lender and any other person in privity with or claiming through, in the right of or on behalf of Borrower or Lender, unless both Borrower and Lender CQment in writing, and (ii) no finding or stipulation of fact in any other arbitration, judicial or similar proceeding shall be given precllliiive or collateral estoppel effect in any arbitration hereWlder, and no conclusion of law in any other arbitration shall be given any weight in any arbitration hereunder, except to the extent such finding, stipulation or conclusion may have been determined in another proceeding between BOrfwer and Lender or any person in privity with or claiming through, in the right of or on behalf of Borrower or Lender. In the event any provision in this Section 9 is determined by the arbitrator(s) or a court of competent jurisdiction to be legally invalid or unenforceable under the law applicable in a particular case, then it is the intention of the parties to this Agreement that such provision be deemed inoperative and stricken from this Agreement, and that the remainder of this Section 9, to the extent not legally invalid or unenforceable under applicable law, be enforced as written and as if the invalid or unenforceable provision or provisions had not been included in this Section 9. d. Each party shall have the right to seek from an appropriate court provisional remedies including, but not limited to, temporary restraining orders or preliminary injunctions before, during or after arbitration. Neither party need await the outcome of the arbitration before seeking provisional remedies. Seeking any such remedies shall not be deemed to be a waiver of either party's right to compel arbitration. Any such action shall be brought by Lender or Borrower in the county (or similar political unit) or federal judicial district where Borrower resides, or where any property that may be the subject of the action is located. The parties consent to the exercise of personal jurisdiction over them by courts located there and to the propriety of venue in such courtS for the PUl1lose of carrying out this provision; they waive any objections that they would otherwise have to the same; and they waive the right to have any such action decided by ajury. e. Waiver of Demand Etc Borrower hereby waives demand. presentment and protest, and notice of demand, presentment, protest, nonpayment or dishonor, with respect to the Note and Borrower's Liabilities, and with res.pect to any notes, checks or other \'Wgotiable instruments which may be included in the Collateral or held by Lender with respect to which Borrower is an endorser, drawer, surety or other responsible party, and Borrower hereby consents to any and every renewal or extension of time that may be granted with respect to such instruments. f. Collection Costs. Except as provided under Section 9(b). above Borrower shaH pay all reasonable costs of coUection of Borrower's Liabilities. all reasonable costs in connection with the use, custody, protection and sale of the Collateral and reasonable all costs paid or incurred in enforcing or preserving any of under's rights hereunder Of in connection with any transaction or proceeding in which Lender may became concerned or involved by reason ofits interest in this Agreement Of any of Borrower's Liabilities or any action by Borrower, in each case including reasonable attorneys' fees, all promptly on demand of Lender or other person incurring the same. Borrower shall also pay interest on the foregoing amounts at the highest defauh rate provided under Section 2.a. Any such costs may be deducted by Lender from any money received under this Agreement {lr on the Note. g. No Waiver bv Lender Lender shall not (by act, delay, omission or otherwise) be deemed to have waived any of its rights or remedies hereunder, or provision hereof, unless such waiver is in writing and signed by Lender, and any such waiver shall be effective only to the extent specifically set forth therein; and a waiver by Lender of any right or remedy under this Agreement on anyone occasion shall not be construed as a bar to or waiver or any such right or remedy which Lender would otherwise have had on any future occasion. h. Further Acts. Borrower shall do and perform aU further acts and deeds and shall execute and deliver to Lender all instruments, documents, assignments, assurances or other writings that may be necessaJ)' or desimble to Lender to carry out the tenns and intent of this agreement or effectuate the rights of Lender hereunder. i. Limitation of Lender's Liabilitv. Borrower agrees that Lender shall not be liable to Borrower for (i) any failure of Lender to protect, enforce or collect in whole or in part any of the Collateral; (ii) Lender's notification to any Obligor of Lender's security interest in the Accounts; (iii) Lender's directing any Obligor to pay any sums owing to Borrower directly to Lender; and (iv) any other act or omission to act on the part of Lender, its officers, agents or employees, except for gross negligence or willful misconduct j. Severability. If any provision of this Agreement or the application thereof to any person or circumstance is held invalid or unenforceable, the remainder of this Agreement and the application of such provision to other ptr.:.ons or CircumstWlCes shail not be affected thereby and the invalid or unenforceable provision of this Agreement shall be severable in any such instance. 6 12/0 I LSA 03/03 k. Successors and Assilms. This Agreement shalt be binding upon and inure to the benefit of the successors and assigns of Borrower and Lender, provided that this Agreement may not be assigned by Borrower without the prior written cOl15ent of Lender. I. Notices. All notices or other communications hereunder shall be in writing, shall be given either by hand delivery or by certified or registered mail addressed to Borrower or Lender, as the case may be, at the addresses indicated 10 the fil'3t paragraph of this Agreement, to the attention of the person or persons indicated below the signatures to this Agreement, and shaH be deemed given when so delivered or delivery is refused by the addressee. Lender may, at its option, rely upon notice or other communications received from Borrower by facsimile (FAX) communication. Either party to this Agreement may change the name or address to which notices shall be sent to it, by written notice to the other party given in accordance with this Section. m. Amendments. This Agreement may be amended from time to time by amendments duly executed by Borrower and Lender; provided that any amendment hereto signed by Borrower shall be binding upon Borrower. n. Multiole Borrowers. If this Agreement (inClUding any counterpart hereof) is signed by more than one Borrower, the liability of each Borrower shall be joint and several, and each reference herein to Borrower shaJl be deemed to refer to each such Borrower. No release, discharge or modification of the obligations of, or the Collateral provided by, any person liable under this Agreement shall affect the obtigations of any other person under this Agreement. o. Entire A!!l'Cement. This Agreement and the Note and the other documents delivered or to be delivered in conn~ction with or pursuant to this Agreement contain all of the agreements of Lender and Borrower with respect to the subject matter hereof. p. Goveminll Law. This Agreement shall be construed in accordance with the laws (without regard to the conflicts of laws provisions) of the State Illinois in which the Lender's office is located, except to the extent the Federal Arbitration Act governs in accordance with Section 9.a above. FOR CALIFORNIA RESIDENTS: This Agreement is made pursuMt to Section 22500 of the: California Financial Code. IMPORTANT: READ BEFORE SIGNING. THE TERMS OF TillS AGREEMENT SHOULD BE READ CAREFULLY BECAUSE ONLY THOSE TERMS IN WRITING ARE ENFORCEABLE. NO OTHER TERMS OR ORAL PROMISES NOT CONTAINED IN TillS WRITTEN CONTRACT MAY BE LEGALLY ENFORCED. YOU MAY CHANGE THE TERMS OF THIS AGREEMENT ONLY BY ANOTHER WRITTEN AGREEMENT. IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be duly signed this 08/13/Z004 BORROWER- ::HNM.CR1~ , c> . C/ t""' ~ PnntName ;:--\nhn C 6 -;-,-r- Title: Vi-Pf,ickD+ 7 12/01 LSA 03/03 .... PROMISSORY NOTE $179.168.22 For value received, the undersigned ("Borrower") hereby promises to pay to the order of Snap-on Credit LLC ("Lender") the principal sum of $179.168.22, together with interest thereon at the rate of 10.25% per annum (calculated on the basis of a 365-day year). Principal and interest shall be payable in 519 weekly installments consisting of principal and interest of $551.11, commencing on 08/30/2004 , and continuing on the same day of each successive week thereafter until Paid in Full with the last installment equal to the balance due 08/11/2014. The entire unpaid balance, together with all accrued and unpaid interest and all other sums due hereunder, if not sooner due or paid, shall be immediately due and payable in full on 08/11/2014. After the occurrence of an Event of Default and for so long as such Event of Default continues, Borrower promises to pay Lender interest on the unpaid principal amount hereof and on all other Borrower's Liabilities at a rate per annum that is equal to the interest rate specified above plus four percent (4%); provided, however, such rate shall not exceed the highest rate permitted by applicable law. This Note is issued pursuant to, secured by and is subject to all of the terms and provisions of, the Loan and Security Agreement dated as of 08/13/2004 between Borrower and Lender, as such Loan and Security Agreement may be amended from time to time (the "Loan and Security Agreement), the terms and provisions of which are hereby incOlporated by reference. A mandatory prepayment may be required in accordance with the terms of the Loan and Security Agreement. For a statement of the terms and conditions under which the maturity of this Note may be accelerated, reference is made to the Loan and Security Agreement. Capitalized terms used herein and not otherwise defined herein are used with the meanings attributed to them in the Loan and Security Agreement. Unless otherwise prohibited by law or as permitted hereunder, Borrower shall be subject to a prepayment premium if Borrower elects to prepay this Note in full. Except as required under the LOAN AND SECURITY AGREEMENT for rejected Revolving Accounts and partial prepayments of not more than one additional weekly payment per week, no partial prepayments shall be permitted or accepted. Notwithstanding the foregoing, there shall be no prepayment premium in the event the Borrower's Dealership is terminated, unless termination of the 1 3/0 I PN 03/03 ~ Dealership occurs due to Borrower relocating and entering into another Dealership. Such prepayment premium shall be equal to: if the term a/this Note is five (5) years oriess, then the prepayment premium is: (i) one (1) monthly payment if prepaid on or before the end oftenn of this Note. Or if the term a/this Note is more than 5 years, then the prepayment premium is: (i) two (2) monthly payments if prepaid on or before the end of the 59th month of this Note, or (ii) one (1) monthly payment if prepaid on or after the 60th month but on or before the final payment on this Note. In no event shall the aforementioned prepayment premium exceed the highest amount allowable under applicable law. Such prepayment premium, represents the costs of prepayment incurred by Lender. The monthly prepayment premium shall be based on the monthly equivalent of the total number of weekly payments, which is calculated by multiplying 4.33 times the weekly payment. Borrower represents, warrants and covenants that (a) this Note evidences a Loan for business and commercial purposes; (b) the proceeds of the Loan evidenced by this Note have not and will not be used for personal, family or household purposes; (c) neither this Note nor any other Borrower's Liabilities violates the provisions of the usury laws or any other applicable laws governing interest rates of any state having jurisdiction over this Note, Borrower's Liabilities or the Loan and Security Agreement; (d) neither this Note nor any other Borrower's Liabilities is subject to Regulation Z of the Board of Governors of the Federal Reserve System. Borrower hereby waives demand, presentment, protest, and notice of demand, nonpayment or dishonor with respect to this Note. Borrower agrees to pay all reasonable costs of collection of this Note and any other Borrower's Liabilities, all reasonable costs in connection with the use, custody, protection and sale of the Collateral and all reasonable costs paid or incurred in enforcing or preserving any of Lender's rights hereunder or in connection with any transaction or proceeding in which Lender may become concerned or involved by reason of its interest in this Note or any other Borrower's Liabilities or any action by Borrower, in each case including reasonable attorneys' fees, all promptly on demand of Lender or other person incurring the same. Lender shall not (by act, delay, omission or otherwise) be deemed to have waived any of its rights or remedies hereunder, or any provision hereof, unless such waiver is in writing signed by Lender, and any such waiver shall be effective only to the extent specifically set forth therein; and a waiver by Lender of any right or remedy under this Note on anyone occasion shall not be construed as a bar to or waiver of any such right or remedy which Lender would otherwise have had on any future occasion. This Note shall be deemed to have been delivered and made at Gurnee, Illinois and shall be interpreted and the rights and liabilities of the parties hereto determined in accordance with the laws 2 310 I PN 03103 . JI (without regard to the conflicts oflaws provisions) of the State of Illinois. Whenever possible each provision of this Note shall be interpreted in such manner as to be effective and valid under applicable law, but if any provision of this Note shall be prohibited by or invalid under applicable law, such provision shall be ineffective to the extent of such prohibition or invalidity, without invalidating the remainder of such provision or the remaining provisions of this Note. Whenever in this Note reference is made to Lender or Borrower, such reference shall be deemed to include, as applicable and to the extent permitted by the Loan and Security Agreement, a reference to their respective successors and assigns, and the provisions of this Note shall be binding upon and shall inure to the benefit of such successors and assigns, including, without limitation, a receiver, trustee or debtor in possession of or for Borrower. Lender may at any time transfer this Note and Lender's rights in any or all of the Collateral. Any transfer by Lender of its rights in any Collateral shall relieve Lender from all liability with respect to such Collateral. BORROWER: JOHN M. CRIST HOLDINGS, By: Print Name: \JCShn rn'~--r Title: 'V, c6iden-t' Date: 9; - I ?S--C::-W 3 3/0 I PN 03/03 " . .' ,. . CONTINUING UNCONDITIONAL GUAR.ANTEE (FOR CORPORATE BORROWER or LIMITED LIABILITY COMPANY BORROWER) FOR VALUE RECENED, and to induce Snap-on Credit LLC, formerly Snap-on Credit Corporation, (the "Lender") to lend money, extend credit or provide other financial accommodation, or to oontinue any of the foregoing, to John M. Crist Holdin!!s, Inc., a Pennsvlvania cmporation ("Borrower") the stock of which or all of the membership interest in which is owned by the Guarantor or Guarantors, and in consideration thereof, the undersigned Guarantor or Guarantors (hereafter collectively the "Guarantor") hereby unconditionally absolutely guarantees: (A) the full and prompt payment when due (whether at maturity or by declaration, acceleration or otherwise) and at all times thereafter of all indebtedness, obligations and liabilities of every kind and nature whatsoever 0 f Borrower to Lender howsoever created, a rising, acquired, held 0 r evidenced, and whether direct or indirect, primary or secondary, absolute or contingent, joint or several, now or hereafter existing, due or to become due; and (B) the full, prompt and faithful perfonnance and discharge by Borrower of each and every term, condition, agreement, representation and warranty on the part of Borrower contained in any agreement (including any amendment, modification or supplement thereof) relating to any loan, credit or other financial accommodation from Lender to Borrower (all such obligations referred, to in (A) and (B) above being hereinafter collectively referred to as the "Liabilities"). The Guarantor further agrees to pay to Lender, upon demand, all costs and expenses, including attorneys' fees, paid or incurred by Lender in collecting or obtaining payment or performance of any Liabilities or in enforcing Lender's rights under or with respect to any agreement or collateral or other security in connection with any Liabilities, or in enforcing this Continuing Unconditional Guarantee (this "Guarantee"). In the event that Borrower fails to pay, perform or discharge the Liabilities when such Liabilities become due and payable (whether by default, acceleration or otherwise), or in the event of the death, incompetency, dissolution, insolvency or bankruptcy of Borrower or the Guarantor or the inability of Borrower to pay its debts as they mature, or in the event of an assignment by Borrower for the benefit of creditors, or the institution of any proceeding by or against Borrower alleging that Borrower is insolvent or unable to pay its debts as they mature, and if such event shall occur at a time when any of the Liabilities may not then be due and payable, the Guarantor agrees to pay to Lender, immediately upon demand, the full amount which would be payable hereunder by the Guarantor if all oft he Liabilities were then due and payable and to () therwise perform and discharge such Liabilities. This Guarantee shall be a continuing, absolute and unconditional guarantee, and shall remain in full force and effect until written notice of its discontinuance shall be actually received by Lender, and also until any and all of said Liabilities created before receiving such notice of discontinuance shall be fully paid, performed or discharged. The death of the Guarantor shall not terminate this Guarantee until written notice of such death shall have been actually received by Lender, and also until all of said Liabilities created before receiving such notice shall be fully paid, performed or discharged. The liability of the Guarantor under this Guarantee shall not be affected, impaired, reduced, released, limited or modified by any of the following (any or all of which may be done or omitted by Lender in its sole discretion and without notice): (a) any act or failure to act by Lender with respect to Borrower, the Liabilities or any collateral or security therefor; (b) any sale, pledge, CG04 , surrender, compromise, release, renewal, extension, indulgence, alteration, disposition, exchange, change or modification in or of any of the Liabilities (including, without limitation, any renewal note), any collateral or security for the Liabilities or any agreement or instrument relating to the Liabilities; (c) the acceptance, rejection or release by Lender of any collateral or security for, any obligor with respect to, or any other guarantee of, any of the Liabilities; (d) any failure, neglect or omission by Lender to realize upon any of the Liabilities or upon any collateral or security therefor (including any failure to protect or insure or to perfect any lien on any such collateral or security); (e) the invalidity or unenforceability of or any irregularity with respect to any Liability; (t) the bankruptcy or insolvency of Borrower or the application to Borrower or its estate of any provision of the United States Bankruptcy Code or any other bankruptcy or insolvency law; (g) the extension of additional loans, credits or other financial accommodations made to Borrower without notice to or approval ofthe Guarantor; (h) any change in Borrower's name or any merger, acquisition or consolidation involving Borrower; or (i) any other act or failure to act of any kind by Lender, other than the execution and delivery by Lender to the Guarantor of a written document clearly and expressly amending, releasing or canceling this Guarantee. The Guarantor hereby waives: (a) notice of the acceptance ofthis Guarantee; (b) notice of the existence, creation, extension or modification of any of the Liabilities, any collateral or other security therefor or any agreement relating thereto; (c) demand, presentment, protest and notice of demand, presentment, protest, nonpayment, dishonor or default, and all other notices whatsoever; and (d) all diligence in collection or protection of or realization upon any Liabilities, any obligation of the Guarantor hereunder or any collateral or other security for any of the foregoing. This Guarantee is a guaranty of payment and not of collection. There shall be no conditions to the obligation of the Guarantor to pay, perform and discharge any Liabilities upon failure by Borrower to pay, perform or discharge such Liabilities when due (whether at maturity or by declaration, acceleration or otherwise), and Lender shall be under no obligation to seek to obtain payment, performance or discharge from Borrower or any other person or entity or to resort to or seek to realize upon any collateral or any other security or property whatsoever prior to obtaining payment, performance or discharge by the Guarantor on this Guarantee. Lender shall have the exclusive right to determine how, when and what application shall be made of any payments and credits on the Liabilities or under this Guarantee. Until all of the Liabilities are fully paid, performed and discharged, the Guarantor hereby: (a) assigns to Lender as security for the Guarantor's obligations under this Guarantee, and subordinates to the Liabilities, any liabilities, indebtedness and obligations of Borrower held by or owed to the Guarantor, including any collateral or other security therefor, and (b) and assigns to Lender, and agrees that Lender shall have, a security interest in the following business property, assets, rights and interests of Borrower or Guarantor (as applicable), whether now owned or existing or hereafter acquired or arising: (1) Any collateral, including, but not limited to, any goods, equipment, chattel paper, accounts, general intangibles, or any other assets it may now own or hereafter acquire CG-4 -2- which may constitute Collateral (as such term is defined in (b) (1) through (6), infra), or proceeds of Collateral of Borrower or Guarantor (as applicable) for any amounts owed to Lender by Borrower, and; (2) All of Borrower's or Guarantor's (as applicable) Accounts (the term "Accounts" as used herein includes, without limitation, all of Guarantor's accounts receivable arising out of the sale or lease of Inventory or other goods or out of the rendering of services), whether or not specifically assigned to Lender; (3) All of Borrower's or Guarantor's (as applicable) Inventory (the term "Inventory" as used herein includes, without limitation, all of Borrower's or Guarantor's goods held for sale or lease or being processed for sale or lease, including all materials, work-in-process, finished goods, supplies and other goods customarily classified as inventory), including Inventory at any time in the possession of any bailee; (4) All of Borrower's or Guarantor's (as applicable) business equipment (the "Equipment"); (5) All of Borrower's or Guarantor's (as applicable) goods, vehicles, (including Borrower's or Guarantor's van or truck) furnishings and fixtures wherever located but only to the extent that such items are used primarily in connection with Borrower's or Guarantor's (as applicable) Snap-on dealership ("Dealership"); (6) All of Borrower's or Guarantor's (as applicable) cash, negotiable instruments, documents of title, warehouse receipts, chattel paper, general intangibles, securities, leases, contract rights, certificates of deposit, deposit accounts, cash equivalents, interest or dividends on any of the foregoing, insurance claims, patents, trademarks, good will and other property of any kind or description, wherever now or hereafter located, but only to the extent that such items are used primarily in connection with Borrower's or Guarantor's (as applicable) Dealership; and Without limiting the foregoing, all substitutions, renewals, improvements and replacements of, and additions and accessions to, the foregoing, and all products and proceeds of the foregoing, including, without limitation, all of the proceeds in any form of Borrower's or Guarantor's (as applicable) Accounts and Inventory, whether specifically assigned to Lender or not. Notwithstanding the foregoing, if Guarantor is an individual, Guarantor's residence, personal, family or household goods and assets not related to or used primarily in connection with Borrower's or Guarantor's (as applicable) Snap-on Dealership are specifically excluded from the definition of "Collateral." The terms used herein to identify the Collateral shall have the respective meanings assigned to such terms as of the date hereof in the Uniform Commercial Code, as amended, in effect in the state listed in the introductory paragraph as Borrower's address (the "UCC"). The security interest granted hereby shall continue to attach to the Collateral notwithstanding any sale, exchange or other disposition of the Collateral by Borrower or Guarantor (as applicable), except for Inventory sold in the ordinary course of business. The security interest herein granted is to secure the payment of all of Guarantor's obligations to guarantee payment andlor performance to Lender of all of the Liabilities; all costs and expenses, including attorneys' fees, paid or incurred by Lender in collecting or obtaining payment or performance of any Liabilities or in enforcing Lender's rights under or with respect to any agreement or collateral or other security in connection with any Liabilities, or in enforcing this Guarantee and the performance of all of Guarantor's obligations to Lender CG-4 -3- hereunder; and any and all other obligations of Borrower or Guarantor to Lender of every kind and description, direct or indirect, absolute or contingent, due or about to become due, now existing or hereafter arising. And; (c) waives any rights that the Guarantor may have against Borrower or with respect to the Liabilities or any collateral or other security therefor by reason of anyone or more payments or acts in compliance with the obligations of the Guarantor under this Guarantee. Lender may, without notice, sell, assign or transfer all or any of the Liabilities and, in such event, each and every immediate and successive assignee, transferee or holder of, or any participant in, any of the Liabilities shall have the rights, powers and benefits granted to Lender in this Guarantee, including the right to enforce this Guarantee by suit or otherwise. In the event that a claim (a "repayment claim") shall be made upon Lender at anytime for repayment of any amount received by Lender in payment of any of the Liabilities, whether received from Borrower or the Guarantor, or received as the proceeds of collateral, or otherwise, by reason of: (a) any judgment, decree or order of any court or administrative body having jurisdiction over Lender or any of its property; or (b) any settlement or compromise of any such repayment claim effected by Lender with the claimant (including Borrower), the Guarantor shall remain liable to Lender for any amount repaid pursuant thereto to the same extent as if such amount had never originally been received by Lender, notwithstanding any termination hereof or the cancellation of any note or other instrument evidencing any of the Liabilities. Except as otherwise provided below, any controversy or dispute arising out of, or relating to tbis Guarantee including, but not limited to, any claim by Guarantor, or any person in privity with or claiming through, on behalf of or in the right of Guarantor, concerning the entry into, performance under, or tennination of, tbis Guarantee; any claim against a past or present employee, officer, director, agent or affiliate of Lender; any claim of breach of this Guarantee or any agreement between the parties or their respective affiliates (whether existing before or after this Guarantee); and any claims arising under state or federal laws, including any statutes, rules, or regulations, shall be submitted to final and binding arbitration as the sole and exclusive remedy for any such controversy or dispute. Unless probibited by applicable law, any claim shall be made by filing a written demand for arbitration within one (1) year following the conduct, act or other event or occurrence first giving rise to the claim; otherwise, the right to any remedy shall be forever barred. Persons in privity with or claiming through, on behalf of or in the right of Guarantor include, but are not limited to, spouses and other family members, heirs, executors, representatives, successors and assigns. GUARANTOR AND LENDER ACKNOWLEDGE AND AGREE THAT, BY ENTERlNG INTO AN ARBITRATION AGREEMENT, THEY ARE WANING ANY RIGHT TO A TRIAL BY JURY IN ANY COURT PROCEEDING. The right and duty of the parties to this Guarantee to resolve any disputes by arbitration shall be governed exclusively by the Federal Arbitration Act, as amended, and arbitration shall take place according to the commercial arbitration rules of the American Arbitration Association in effect as ofthe date the demand for arbitration is filed. The arbitration shall be held at the CG-4 -4- , office of the American Arbitration Association nearest the Snap-on Branch Office to which Guarantor was assigned prior to the dispute; provided, however, if such office is outside the state in which the Guarantor resides, Guarantor may cause the arbitration to be held within the Guarantor's state of residence at a place mutually convenient to the parties and the arbitrator(s). The arbitration shall proceed before either a single arbitrator or three arbitrators. Guarantor shall have the option to choose within 10 days after the filing of a demand for arbitration between whether to proceed before one arbitrator or three arbitrators. Failure to select the number of arbitrators within the time allowed shall result in the use of a single arbitrator. If a single arbitrator procedure is selected, the arbitrator shall be chosen by the striking method from a panel of neutral arbitrators provided by the American Arbitration Association. Lender shall pay the fees and expenses of the single arbitrator and shall also pay the filing fees and costs charged by the American Arbitration Association to the extent they exceed the amount the Guarantor would otherwise have had to pay to file a suit in court. If a three arbitrator procedure is selected, each party shall choose one arbitrator and the two so chosen will select a third, and failing selection of an arbitrator by either party or by the two chosen by the parties, the arbitrator(s) shall be selected from a panel of neutral arbitrators provided by the American Arbitration Association and shall be chosen by the striking method. In a three arbitrator procedure, the parties shall bear their own costs ofthe arbitration, provided, however, that the fees and expenses of the arbitrators shall be paid 50% by each side. Unless otherwise agreed by the parties or ordered by the arbitrator( s), pre-hearing discovery in any arbitration is limited to the following: (1) production of all documents that will be introduced at the hearing; (2) production of written or recorded statements; (3) production of all documents relied upon by experts in the hearing; and (4) not more than two depositions per side. Each party further agrees that, unless such a limitation is prohibited by applicable law, the other party shall not be liable for punitive or exemplary damages and that the arbitrator( s) shall have no authority to award the same. The award or decision by the arbitrator(s) shall be final and binding on the parties and may be enforced by judgment or order of a court having subject matterjurisdiction in the state where the arbitration took place. The parties consent to the exercise of personal jurisdiction over them by such courts for the purpose of carrying out this provision; and they waive any objections that they would otherwise have to the same. Unless prohibited by applicable law, (i) no arbitration under this Guarantee shall include, by consolidation, joinder or in any other manner, any person other than Guarantor and Lender and any other person in privity with or claiming through, in the right of or on behalf of Guarantor or Lender, unless both Guarantor and Lender consent in writing, and (ii) no finding or stipulation of fact in any other arbitration, judicial or similar proceeding shall be given preclusive or collateral estoppel effect in any arbitration hereunder, and no conclusion of law in any other arbitration shall be given any weight in any arbitration hereunder, except to the extent such finding, stipulation or conclusion may have been determined in another proceeding between Guarantor and Lender or any person in privity with or claiming through, in the right of or on behalf of Guarantor or Lender. In the event any provision in this Guarantee is determined by the arbitrator( s) or a court of competent jurisdiction to be legally invalid or unenforceable under the law applicable in a particular case, then it is the intention of the parties to this Guarantee that such provision be deemed inoperative and stricken from this Guarantee, and that the remainder ofthis Guarantee, to the extent not legally invalid or unenforceable under applicable law, be CG-4 -5- " enforced as written and as if the invalid or unenforceable provision or provisions had not been included in this Guarantee. Each party shall have the right to seek from an appropriate court provisional remedies including, but not limited to, temporary restraining orders or preliminary injunctions before, during or after arbitration, Neither party need await the outcome of the arbitration before seeking provisional remedies, Seeking any such remedies shall not be deemed to be a waiver of either party's right to compel arbitration. Any such action shall be brought by Lender or Guarantor in the county (or similar political unit) or federal judicial district where Guarantor resides, or where any property that may be the subject of the action is located. The parties consent to the exercise of personal jurisdiction over them by courts located there and to the propriety of venue in such courts for the purpose of carrying out this provision; they waive any objections that they would otherwise have to the same; and they waive the right to have any such action decided by a jury. This Guarantee shall be deemed to have been delivered and made and shall be interpreted and the rights and liabilities of the parties hereto determined in accordance with the laws (without regard to the conflicts oflaws provisions) of the State of the Borrower's Regional Customer Service Center in which the Lender's office is located, except to the extent the Federal Arbitration Act governs the provisions of any arbitration agreement herein. Whenever possible each provision of this Guarantee shall be interpreted in such manner as to be effective and valid under applicable law, but if any provision of this Guarantee shall be prohibited by or invalid under applicable law, such provision shall be ineffective to the extent of such prohibition or invalidity, without invalidating the remainder of such provision or the remaining provisions of this Guarantee, This Guarantee shall be binding upon the Guarantor and upon the heirs, legal representatives and successors of the Guarantor, and shall inure to the benefit of Lender, its legal representatives, successors and assigns. If this Guarantee (including any counterpart hereof) is signed by more than one Guarantor, the liability of each Guarantor shall be joint and several, and each reference herein to the Guarantor shall be deemed to refer to each such Guarantor. In furtherance and not in limitation of the rights and remedies of Lender hereunder or at law, Lender may proceed under this Guarantee against any or all Guarantors in its absolute and sole discretion for any Liabilities or other obligations of Borrower arising hereunder. No release, discharge or modification of the obligations of, or the collateral provided by, any party liable on this Guarantee shall affect the obligations of any other party on this Guarantee. CG4 -6- , ", ' ~ '.' . IN WITNE~ qREOF, t~dersigned has caused this Guarantee to be executed delivered this day of -J Lt l , 20..12.-. t ' CG-4 -7- '" gg \: ~~ ;;; .....J ('"l~ 0 0;-0;- '" ,.. ~~ 00 tl '" ",,,, ~U~<< ';:l~r-:-1'- ~..J~;S ",'" ~~ "" .... 0< rr:,f,,\ ~~ -- ",,,, ;." z< ",,,, -'" "0 ~v ",.", "'<", ~~ ';"'- ::^::; z'" ;;; :I 00 '" -'" ~ ~~ ~ .. Q< 00 ~ '; ':l 1" Q .... Z "l '" '" I.:i ~ ,,~ ~ "'''' '" ... ';'" '" :A "- l < ~ \;l ~ i ~ ~ .. <: >J -' ::l :5~ " vO Cl~" "- '" ='" g ~" ",,,, ~, .... <~ ~ " v< S~ ",.. ~ ~~ t/) In Q Q .... ='" ~ r! ~ ~ ",," ~ '" ~~ - <~ '" .... ~ '" Q oc: ",-' 00 v< '" ~tl .... "" ~ ';~ ". ~ fi\ \.) "''' ~ '" p: ~'" '" Cl -<: ",,,, ~ ~ r- oJ ~'" 'Q~ o-v r-' Z ..l o-t: :e "'~ ~ ~ u "'i '" UZ~ '; '" ~ ~o~ .. oJ 0", z'Qo c. g oJ U $.~ 8~= ~'" ~ - 0& M 0 ,.. -", ~'" 1;; ';;> :<'V ~ " ~~ Z ~~ " '"'" .... '" '" "'- v" '" "''' ~ Z:<. "' '" 0 ~'" .. ;;;- ~ "" o-\::. a--' '" '" ",e ~ ;.t ~E: ~j ::; 0 ~ M ~ ",0 :::: ';V -' ~ <", '" \:,.. 0 "'- '" "'i 0 0 0:<. '" 0 '" '"- 00 ,..", ~ e-' v ~" ~ '" '" :,; v'" '" ~ OV "" v ::; '" ,.~ .. ~ 0- " ~. M "- "" ~~ ~ :::: . d '" 0 ~'" '; ~ ~11~ ~ O'e~ Cl '"'" ..,"'P: ~ ~;.t M ~oJ '" ::; VV "" .. ~Jz ~ -~ .. ~~ .... '" ~. ;!a~O ~~ 0- '" 0-, '" ~, ~< '" ,,~t-- P:"l '; ~ -'" U"'''' ~oc: oJ Cl :I: "'''' t/) ;"l ~ '" es ~... ~ '" Q -<: -<:~ ~ .... '" ~ Cl ~ :I:c::. ~ ..... ~ ~ .. .. ~ ... "l ; .... S< oc: P: :I: l>; ..... >v: ~ ~ t.:i U "- >v: ~ ~ Z Cl 2 -<: Cl ~ ~ ol ~ 0 oJ U v Cl ..l i:Q 0 oJ .... '" .;; -- u", "'" ",,,, .", ~~ "''' ~~ ~~ ;;;", "''' "",. ~~ ~~ ~~ ........~ t-n tw ~~ <z ~'" ~ 0 0 ~~ s <'" - -' ;;; ;. ~~ ,..~ ~~( ~'" ~~ -,,,, ~~ z -- ~-' -- c,M #~ ~~ ~ ~~ ~ ~<.:> MM ~~ "'~ ..", :; N~ "'<.:> .... ~ ~J';" '"~ '" .... 99 00 ~~ ~~ f"'i'M' 5<.:> ::::: ~~ "'''' MN .. - '2'" 0 0 <~ r:; In'" ~ "' EXHIBIT ~ ti' ;;; "l >' l-' :z;- :1:5 Ow -.,..J 1;;< olb Ul-' VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4r04 relating to unsworn falsifications to authorities, that he/she is 150'1/\ L. W l~~ (NAME) p ~~O ~WA~ev (TITLE) of S~-M G-eJd- (COMPANY) , plaintiff herein, that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. " FFI AL" Stephanie L. Bruebach Notary Public, Stale of Illinois My Commission Exp. 11/01/2009 J'().,t~::{ Y6{'~ciL().t'{"'- (- j U -0(" d~Cl-O / RE) () ~ - 8 , 1J <n ::.,. r::- 111 , ~ l\:- tn "'0 CJ ,:,.'; - -J ~ ~ ~ ~ l-) }.) - J:: -_.~ ...c ..() ~ -r- . SHERIFF'S RETURN - REGULAR ., CASE NO: 2006-00433 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SNAP-ON CREDIT LLC VS CRIST JOHN M ET AL JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - REPLEVIN was served upon CRIST JOHN M the DEFENDANT , at 1830:00 HOURS, on the 24th day of January ,2006 at 1201 CROSS CREEK DRIVE MECHANICSBURG, PA 17050 by handing to JOHN CRIST a true and attested copy of COMPLAINT - REPLEVIN together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 10.56 .00 10.00 .00 38.56 ~~G).:'/ . //~ -:? /.~~","";'d<..., ~ 7 "/ R. Thomas Kline 01/25/2006 WELTMAN WEINBERG REIS Sworn and Subscribed to , i-A )0/ day of before By: ~"%f me this , SHERIFF'S RETURN - REGULAR 'I CASE NO: 2006-00433 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SNAP-ON CREDIT LLC VS CRIST JOHN M ET AL JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - REPLEVIN was served upon JOHN M CRIST HOLDINGS INC the DEFENDANT , at 1830:00 HOURS, on the 24th day of January 2006 at 1201 CROSS CREEK DRIVE MECHANICSBURG, PA 17050 by handing to JOHN CRIST ADULT IN CHARGE a true and attested copy of COMPLAINT - REPLEVIN together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 -,-;..~.::;.;'-" ",-- , ,..1':,.":/' .".,. . .-,--~<~_.,,'::.:~~ R. Thomas Kline 01/25/2006 WELTMAN WEINBERG REIS Sworn and Subscribed to before By: 9pu~riff me this 501/, day of A.D. IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SNAP-ON CREOlT, LLC Plaintiff No. 06-433 Civil Term vs. PRAECIPE FOR DEFAULT Jl.JDGMENT JOHN M. CRIST and JOHN M. CRIST HOLDINGS, INC. Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA.I.D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, P A 15219 (412)434-7955 WWR#04963618 \ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIV]SION SNAP-ON CREDIT, LLC Plaintiff vs. Civil Action No. 06-433 Civil Term JOHN M. CRIST and JOHN M. CRIST IIOLDINGS, INC. Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendants, John M. Crist and John M. Crist Holdings, Inc., above named. in the default of an Answer as follows: For possession of the equipment, more particularly identified in the attached exhibit. I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. i /. j // h ~-- By: "VI ({.. William T. Molczal1, Esq PA. 1.0.#47437 WELTMAN, WEINBERG & RE]S CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04963618 PlaintiWs address is: c/o Weltman, Weinberg & Rcis 27] 8 Koppers Building, 436 7'h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendants arc: 1201 Cross Creek Drive, Mechanicsburg, P A 17050 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ClVIL DIVISION SNAP-ON CREDIT, LLC Plaintiff 06-433 CIVIL TERM JOHN M CRIST and JOHN M CRIST HOLDINGS INC Defendants IMPORTANT NOTICE TO: John M Crist 120 I Cross Creek Drive Mechanicsburg,Pa 17050 Date of Notice: ~\\(A~ YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTI'I AGAINST YOU. UNLESS YOU ACT WITHIN TEN DA YS FROM THE DATE OF THIS NOTICE. A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RlGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 By: William T. MoIczan, Esq . e PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.PA 2718 Koppers Building 436 Seventh A venue Pittsburgh, PA 15219 (412) 434-7955 WWR #04963618 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV ANIA CIVIL DIVISION SNAP-ON CREDIT, LLC Plaintiff 06-433 CIVIL TERM JOHN M CRIST and JOHN M CRIST HOLDINGS INC Defendants IMPORTANT NOTICE TO: John M Crist Holdings Inc 120 I Cross Creek Drive Mechanicsburg.Pa 17050 Date of Notice: <Q \\(Aaooc. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITlNG WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DA YS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HA VE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 WELTMA{;L' WINBERG & REIS CO.. L.P.A. i / /I" By: Will . ~ William T. Molezan, Esq e PA I.D. #47437 WELTMAN, WEINBERG & REIS CO.. L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, P A 15219 (412)434-7955 WWR #0496361 8 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members ofthe Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, WEINBERG & REIS CO.. L.PA I I,. //~ By: V}/., j ~ M/}, William T. Molcz n, Es PA.1.0.#47437 WELTMAN, WEINBERG & REIS CO.. L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittshurgh, P A 15219 (412) 434-7955 WWR#04963618 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SNAP-ON CREDIT, LLC Case no: 06-433 Civil Term Plaintiff NON-MILITARY AFFIDAVIT vs. JOHN M. CRIST and JOHN M. CRIST HOLDINS, INC. Defendants The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. ~ 521. Affiant further states that based upon investigation it is the affiant's beliefthat the Defendant, JOHN M. CRIST and JOHN M. CRIST HOLDINS, INC. is not in the military service. Affiant further states that this belief is supported by the attached certificate Patti Jo Bryner is not in the military service. Further Affiant sayeth naught. SWORN TO AND SUBSCRIBED in my presence this _ day of NOTARY PUBLIC This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. t t::J '}- 1!- ~ ~ ~ ~ ~ cq [: D -:t ~~ ~ -J ~ r ~~ -~ (.... ~-_. c::.--' -, L ..--------- IN HIE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SNAP-ON CREDIT. LLC Plaintiff vs. Civil Action No. 06-433 Civil Term JOHN M. CRIST and JOliN M. CRIST HOLDINGS, INC. Defendant NOTICE OF JUDGMENT OR ORDER TO: () Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on (Y?'::Jn r j 10, d-"OOb (xx) Assumpsit Judgment for possession of the equipment more particularly identified in the attached exhibit. () Trespass Judgment in the amount of $ plus costs. () Ifnot satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety. Harrisburg, P A. (xx) Entry of Judgment of () Court Order () Non-Pros () Confession (xx) Default () Verdict () Arbitration Award Prothonotary John M Crist 120 I Cross Creek Drive Mechanicsburg,Pa 17050 B, ~J>~ PROTHC OT AR . DE TY) IN Tl IE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SNAP-ON CREDIT, LLC Plaintiff vs. Civil Action No, 06-433 Civil Term JO\lN M. CRIST and JO\lN M. CRIST HOLDINGS, INC. Defendant NOTICE OF JUDGMENT OR ORDER TO: () Plaintiff (xx) Defendant ( ) Garn ishee You are hereby notified that the following Order or Judgment was entered against you on (Yl';1/J" 1-.. I 0 I ).DDfc, (xx) Assumpsit Judgment for possession of the equipment more particularly identified in the attached exhibit. ( ) Trespass Judgment in the amount of $ plus costs. ( ) Ifnot satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, \larrisburg, PA. (xx) Entry of Judgment of () Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict () Arbitration Award Prothonotary John M Crist \loldings Inc 120 I Cross Creek Drive Mechanicsburg,Pa 17050 Y) , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SNAP-ON CREDIT, LLC Plaintiff No. 06-433 Civil Term vs. PRAECIPE FOR SATISFACTION OF ,IUDGMENT JOHN M. CRIST i1aJd/b/a JOHN M. CRIST HOLDINGS, INC. Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D #42524 WELTMAN, WEINBERG & REIS CO., L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR No. 0496361g . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SNAP-ON CREDIT, LLC Plainti!'!' vs, Civil Action No, 06-433 Civil Term JOHN M. CRIST i/a1d/b/a JOHN M. CRIST HOLDINGS. INC. Defendants PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff. you are directed to satisfy the above-captioned Judgment. WELTMAN. WEINBERG & REIS CO.. L.P.A. Sworn to and subscribed bel' re me this :) 0 y f March. 06 ' r 7t .":'~,;"c0':':'\~~~(-'si;,,;iJ'L""J:'.;::... \ Heidi ,J. Kei!y, Notuy eubiic "\ IL Cit; O~ Pitt., 2,bU,.gl'.i. A\lt~~h~.ny CO~ill~l i tJiV Ccrnnv"';wn EXP'(E,'" f\JW_ 4" ()'.:'- . tk:r,)\~~;,--;-::,~~:_~,:~:,-;;::~,;'~~;G~~-';~"~;J"~(.~ WWR No. 04963618 , c:i