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MID PENN BANK,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: NO.
!lIp' /1;;' ~ CwJ
v.
JOEY V'S, INC.,
d/b/a JOEY'S IT ALlAN GRILL,
and JOEY V. SULLENBERGER,
a/k/a JOSEPH V. SULLENBERGER,:
Defendants
CONFESSION OF JUDGMENT
Pursuant to the authority contained in the Warrant of Attorney, the original or a copy of
which is attached to the Complaint filed in this action, I appear for the Defendant and confess
judgment in favor of the Plaintiff and against the Defendant as follows:
Principal:
Interest:
Late Charges:
Attorneys Fees and Legal Expenses:
$49,205.36
$ 1,337.67 (Plus $12.30 per diem)
$ 67.85
$ 500.00
Total: $51, II 0,88
plus continuing interest from February 15,2006, at the rate of$I2.30 per diem, continuing late
charges, continuing costs, and continuing attorneys fees.
By:
it I , Es lr (PA AttyNo. 29929)
. Knigh , E quire (P A Atty. No. 87365)
2320 orth Second Street
Harrisburg, PA 171\0
Telephone: (717) 238-6570
Attorneys for Defendants
i
Date: ,'. '" 1/,
,2006
'-;.1.
;".\
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Cunningham & Chemicoff, P,C.
Marc W. Witzig, Esquire
P A Attorney Ident. No. 29929
Kelly M. Knight, Esquire
PA Attorney Ident. No. 87365
2320 North Second Street
Harrisburg, PA 17110
Telephone: (717) 238-6570
mwitziglq)cclawoc.com
kkni ghtialcclawoc .com
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
J{}{)&.II~(y
: NO.
MID PENN BANK,
v,
JOEY V'S, INe.,
d/b/a JOEY'S ITALIAN GRILL,
and JOEY V. SULLENBERGER,
a/k/a JOSEPH V. SULLENBERGER,:
Defendants
COMPLAINT FOR CONFESSION OF JUDGMENT
NOW COMES the Plaintiff, Mid Penn Bank, by and through its counsel, Cunningham &
Chemicoff, P .C" and states it Complaint for Confession of Judgment as follows:
l. Plaintiff, Mid Penn Bank (the "Plaintiff' or the "Bank") is a Pennsylvania banking
institution with a principal place of business located at 349 Union Street, Millersburg, Dauphin
County, Pennsylvania 1706l.
. .
2. Defendant, Joey V's, Inc., d/b/a Joey's Italian Grill ("Borrower") is a Pennsylvania
corporation with a principal place of business located at 433 North 21" Street, Camp Hill,
Cumberland County, Pennsylvania 17011.
3. Defendant, Joey V. Sullenberger (the "Guarantor") is an adult individual believed to
be residing at 481 Sample Bridge Road, Enola, Cumberland County, Pennsylvania 17025,
4. Guarantor also is known as Joseph V. Sullenberger.
5. On or about May 10,2005, Borrower executed a Promissory Note in favor of the Bank
in the initial principal amount of $50,000.00 (the "Note"). A true and correct copy of the Note is
attached hereto as Exhibit "A" and is incorporated herein by reference,
6, On or about May 10,2005, Defendant, Joey V, Sullenberger ("Guarantor") executed
his certain Commercial Guaranty (the "Guaranty"), dated May 10, 2005, absolutely and
unconditionally guaranteeing and promising to pay the Bank, on demand, all indebtedness of
Borrower under the Note, A true and correct copy of the Guaranty is attached hereto as Exhibit
"B" and is incorporated herein by reference.
7. As set forth in the Note, the Borrower promised to pay the Bank, or order, in lawful
money of the United States of America, on demand, the principal amount of $50,000.00, together
2
with interest at the initial rate of 7.250% per annum, on the unpaid balance from May 10, 2005,
until paid in full.
8. In the Note, Borrower agreed to pay the Note in full immediately upon the Bank's
demand.
9, By means of the Note, Borrower agreed to pay regular monthly payments of all
accrued unpaid interest due as of each payment date, beginning June 1,2005, with all subsequent
interest payments to be due on the same day of each month after that.
10. The Bank has made demand upon Borrower and Guarantor for payment in full of all
amounts owed to the Bank under and in connection with the Note.
11. To date Defendants have refused and failed to pay in full all sums due and owing
under the Note and the Guaranty.
12. According to the Note, if Borrower made any payment fifteen (15) days or more late,
Borrower would be charged 10.000% ofthe regularly scheduled payment or $25.00, whichever
was greater.
]3, According to the Note, if the Bank demanded payment of the Note, and Borrower did
not pay the Note in full within fifteen (15) days after the Bank's demand, then Borrower would
3
also be charged either 10.000% of the sum of the unpaid principal plus accrued unpaid interest or
$25.00, whichever was greater.
14. According to the Note, any failure by the Borrower to make any payment when due
under the Note constitutes a default under the Note.
15. According to the Note, a material adverse change in the Borrower's financial
condition, or a belief by the Bank that the prospect of payment and performance ofthe
indebtedness is impaired, constitutes a default under the Note.
16. According to the Note, a default occurs if the Bank, in good faith, believes itself
msecure.
17. According to the Note, upon default, including but not limited to failure to pay upon
final maturity, the Bank, at its option, could increase the variable interest rate on the Note to
6.500 percentage points over the Index defined therein.
18. According to the Note, if judgment is entered in connection with the Note, then
interest will continue to accrue on the Note after judgment at the interest rate applicable to the
Note at the time when such judgment is entered.
4
" .
19, According to the Note, the Bank may hire or pay counsel to help collect under the
Note if the Borrower does not pay. Borrower agreed to pay the Bank that amount, including but
not limited to, the Bank's attorneys fees and legal expenses, whether or not their was a lawsuit,
including attorneys fees. Borrower is in default under the Note in that Borrower has failed to
make payments when due under the Note.
20. Borrower did not make the regular payments of all accrued and unpaid interest that
were due and owing on January I, 2006, and February I, 2006, respectively.
21. There have occurred material adverse changes in the Borrower's and the Guarantor's
financial condition.
22, The Bank believes the prospect of payment or performance under the Note is
impaired.
23. As of February 15,2006, the sum due and owing under the Note is:
Principal: $49,205,36
Interest: $ 1,337,67 (plus $12.30 per diem)
Late Charges: $ 67.85
Attorneys Fees and Legal Expenses: $ 500.00
Total: $51,11 0.88
5
,.
plus continuing interest from February 15, 2006, at the rate of$12.30 per diem, continuing late
charges, continuing costs, and continuing attorneys fees.
24. Borrower and Guarantor have no legal excuse or defense for failure to perform and
pay their obligations under and in connection with the Note and Guaranty as hereinabove alleged.
25. Because of the Defendants' failure and refusal to perform and pay their obligations
under and in connection with the Note and Guaranty and to pay the amount owed to the Bank,
the Bank has been damaged in a sum not less than $51,110.88 plus continuing interest, late
charges, costs, and attorneys fees.
26. The Note authorizes the Bank to confess judgment against the Borrower.
27. The Guaranty authorizes the Bank to confess judgment against the Guarantor.
28. Judgment has not been entered against either Defendant in any jurisdiction under the
Note or the Guaranty.
29. Neither the Note nor the Guaranty have been assigned.
30. Judgment by confession is not being sought herein against a natural person in
connection with a consumer credit transaction.
6
31. Defendants' failure to pay under the Note and Guaranty and continuing default
thereunder provides the Bank with the authority to file this Complaint against both Defendants.
32. All conditions precedent to the Bank's recovery hereunder an entry of judgment by
confession, in favor of the Bank, have been performed, satisfied, and/or waived.
WHEREFORE, Plaintiff, Mid Penn Bank, herein prays that this Honorable Court enter
Judgment by Confession against the Defendants, Joey V's, Inc. d/b/a! Joey's Italian Grill and
Joey V. Sullenberger a/kla Joseph V. Sullenberger, in the amount of$51,110.88, plus continuing
interest from February 15,2006, at a rate of$12.30 per diem, continuing late charges, continuing
costs, and continuing attorneys fees, and further grant Plaintiff such additional relief as is just and
proper.
B
Marc
Kell . Knig , squire (PA Atty. No. 87365)
2320 North Second Street
Harrisburg, P A 1711 0
Telephone: (717) 238-6570
Attorneys for Plaintiff
,
I'.
Date:
,2006
home/tlf/complain/mid.joev
7
717 238 4809
Cunningham and Cherni
11 :03:00 a.m 02-22-2006
38/58
.'
MID PENN BANK,
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSYL VANIA
Plaintiff
: NO.
v.
JOEY V'S, INC.,
d/b/a JOEY'S ITALIAN GRILL,
and JOEY V. SULLENBERGER,
aIkIa JOSEPH V. SULLENBERGER,:
Defendants
AFFIDAVIT OF LAST KNOWN ADDRESS
1, Larry L. Novinger, Collections Manager of Mid Penn Bank, hereby certify that the last
known address of Defendant, Joey V's, Inc., d/b/a Joey's Italian Grill, is 433 North 21d Street,
Camp Hill, Cumberland County, Pennsylvania 17011. The last known address of Defendant,
Joey V. Sullenberger a!k/a Joseph V. Sullenberger, is 481 Sample Bridge Road, Enola,
Cumberland County, Pennsylvania 17025.
MID PENN BANK
awo~ to me this
~n (lay of February, 2006
~f"
~8mo~ JirH Of PENNSYLVA IA
Notarial Seal
Dixie L. Ross, Notary Public
MiHersburg Boro, Dauphin County
My Commission Expires May 5. 2007
Member, Pennsy\'1sroi3 Associa1ion of Nctartes
MID PENN BANK,
Plaintiff
v.
JOEY V'S, INC.,
d/b/a JOEY'S ITALIAN GRILL,
and JOEY V. SULLENBERGER,
a!k1a JOSEPH V. SULLENBERGER,:
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
NO.
AFFIDAVIT OF KELLY M. KNIGHT. ESOUlRE
I, Kelly M. Knight, Esquire, attorney for Plaintiff, Mid Penn Bank, swear and aver as
follows:
I. The judgment is not being entered by confession against a natural person in connection
with a consumer credit transaction.
Swom to before me
this.~ day of February, 2006
, '_ ~ ~L_l jj_ <
Notary Public
I-~-~ ....
I" _, / >_/__(
:UT}\:iiJ\L SF/i(_
c)LA-J;t.,.!;\!"- A:\~::,THi\"-; ;":>'1'1 ~.
By:
MID PENN BANK,
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: NO.
v.
JOEY V'S, INC.,
d/b/a JOEY'S ITALIAN GRILL,
and JOEY V. SULLENBERGER,
a!k1a JOSEPH V. SULLENBERGER,:
Defendants
CERTIFICATE OF RESIDENCE
The address of the Plaintiff, Mid Penn Bank, is 349 Union Street, Millersburg, Dauphin
County, Pennsylvania 17061.
The last known address of Defendant, Joey V's, Inc., d/b/a Joey's Italian Grill, is 433
North 21 ,t Street, Camp Hill, Cumberland County, Pennsylvania 17011.
The last known address of Defendant Joey V. Sullenberger a!k!a Joseph V. Sullenberger,
is 481 Sample Bridge Road, Enola, Cumberland County, Pennsylvania 17025.
,1\ '
Date: ;' I. ,{,'t
^ ,2006
By:
Marc
Kelly, i t, Esquire (P A Atty. No. 87365)
232 North Second Street
Harrisburg, PA l7110
Telephone: (717) 238-6570
Attorneys for Plaintiff
717 238 4809
Cunningham and Cherni
11 :03:44 a.m 02~22-2006
43/58
MID PENN BANK,
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: NO.
v.
JOEY V'S, INC.,
d/b/a JOEY'S ITALIAN GRILL,
and JOEY V. SULLENBERGER,
aIkIa JOSEPH V. SULLENBERGER,:
Defendants
AFFIDAVIT OF NON.MILlTARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
: ss;
COUNTY OF DAUPHIN
The undersigned, being duly sworn according to law, deposes and says that he, Larry
Novinger, is Collections Manager of Mid Penn Bank, Plaintiff in the above captioned matter; and
that he personally knows that Defendant Joey V. Sullenberger a!k/a Joseph V. Sullenberger is
over tbe age of eighteen (I 8) years.
The Plaintiff further avers that the Defendants are not in the Military Service or in any
branch oftbe Armed Forces of the United States of America or its Allies or otherwise within the
provisions of the Soldier's and Sailors' Civil Relief Act of Congress of 1940 and its
Amendments.
SWORN and Subscribed to
Before me thi~:1Z:DdaY
Ofu~v
QOTAR PUBLl
COMMONWEALTH Of PENNSYLVANI~
Notarial Seal
Dixie L. Ross. NotaJy Public
Millersburg Bom, Dauphin County
My Commission Expires May 5, 2001
Member, Pennsylvania Association of Notarles
717 238 4809
Cunningham and Cherni
110336 a.m. 02-22-2006
42/58
.
MID PENN BANK,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
Plaintiff
: NO.
v.
JOEY V'S, INC.,
d/b/a JOEY'S ITALIAN GRILL,
and JOEY V. SULLENBERGER,
a!k/a JOSEPH V. SULLENBERGER,:
Defendants
VERIFICATION
I, Larry Novinger, Collections Manager of Mid Penn Bank, verify that the statements
made in the foregoing Complaint for Confession of Judgment are true and correct to the best
of my knowledge, information and belief: I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. ~4904, relating to unsworn falsification to authorities.
-;
Date: rO)eUa ('I .2<../
,2006
SWORN and Subscribed to
Before me this 2Znd day
of "b~
/
~i02--' ...
~ARY~LIC .
COMMONWEALTH Of PENNSYLVANIA
Notarial Seal
Dixie L. Ross, Notary Public
Millersburg Bom, Dauphin County
My Commission Expires May 5, 2007
Member, P'?'l;'syfvZ!lli~ ,t.,!s'JoahcfI of Notaries
.
EXHIBIT "A"
PROMISSORY NOTE
... Prinolpal.
....A. "^" AA
......~<.~~w<o:-:'
ng9jriQ.,.m
. (5411)._/
References in the shaded area are for Lender's use only and do not limit the applicability of this document to any particular loan or item.
Any item above containin ...U has been omitted due to text len h limitations.
Borrower: Joey V'., Inc. D/B/A Joey'. italian Grill (TIN:
03-0555654)
433 North 21.t Str881
Camp Hili, PA 17011
Lender;
Mid Penn Bank
Derry Str881 Office
4098 Derry Str881
Harrl.burg, PA 17111
Principal Amount: $50,000.00 Initial Rate: 7.250% Date of Note: May 10, 2005
PROMISE TO PAY. Joey V'" Inc. D/B/A Joey'. italian Grill ("Borrower") proml.... to pay to Mid Penn Bank ("Lender"), or order, In lawful
money of the United Stat... of America, on demand, the prlnclpel amount of FIfty Thou.and " 00/100 Dollars ($50,000.00) or .0 muclt a. may be
oul8tandlng, together with Inter...t on the unpaid outstanding principal balance of each advance. Interest .hall be c.lculated from the date of
each advance until repayment of each advance.
PAYMENT. Borrower will pay thlalo.n In tulllmmedlately upon Lender'. dem.nd. Borrower will pay regular monthly payment. of all accrued
unp.ld Inter...t due a. of ...ch payment date, beginning June I, 2005, with all .ubsequent Interest payment. to be due on the same day of
each month after that. Unl.... otI1erwlae agreed or required by applicable law, paymenta will be epplled flr.t to any accrued unpaid Interest:
then to principal; then to any unpaid collection costl; and then to any late chargee. The annual Interest rate for thl. Note 18 computed on 8
3651380 beala: that I., by .pplylng the ratio of tlte annual Interest rete over a y...r of 380 daya, multiplied by the outstanding principal balance,
multiplied by the actual number of day. the principal balance la out8landlng. Borrower will pay Lender 8l Lender'. addr.... .hown .bove or at
auch other place a. Lender may d...lgnate In writing.
VARIABLE INTEREST RATE. The interest rate on this Note is subject to cltange from time to time based on changes in an independent index which
is the the Prime Rate as quoted in the Wall Street Journal (the 'Index.). The Index is not necessarily the lowest rate charged by Lender on its loans. If
the Index becomes unavailable during the term of this loan, Lender may designata a substitute index after notice to Borrower. Lender will tell Borrower
the current Index rate upon Borrower's request. The Interest rate change will not occur more often than each month, on the first business day of the
mootlt. Borrower understands that Lender may makeloane based on other rates as well. The Index currently la 5.750% par annum. The Interest
rete to be applied to the unpaid principal belanca of tltla Note will be at a rate of 1.500 parcenl.ge polnta over tlte Index, r...ultlng In an Initial
rate of 7.250% per annum. NOTICE: Under no circumstances will the interest rate on this Note be more than the maximum rate allowed by applicable
law.
PREPAYMENT. Borrower may pay wilhout penalty all or a portion of 1he amount owed earlier than tt is due. Early payments will not, unless agreed to
by Lender in writing, relieve Borrower of Borrower's obligation to continue to make payments of accrued unpaid interest. Rather, early payments will
reduce the principal balance due. Borrower agrees not to send Lender payments marked -paid In full-, -without recourse-, or similar language. If
Borrower sends such a payment, Lender may accept it without losing any of Lender's rights under this Note, and Borrower will remain obligated to pay
any further amount owed to Lender, All written communications concerning disputed amounts, including any check or other payment instrument that
indicates that the payment constitutes "payment in 1ull" 01 the amount owed or that is tendered with other conditions or limitations or as full satisfaction
of a disputed amount must be mailed or delivered to: Mid Penn Bank, Derry Street Office, 4098 Derry Street, Harrisburg, PA 17111.
LATE CHARGE. "a regularly sclteduled interest payment is 15 days or more late, Borrower will be cltargad 10.000% of the regularly .cheduled
payment or $25.00, whichever Is greeter. If Lender demands payment of this loan, and Borrower doa8 not pay the loan In full within 15 day. after
Lender'. demand, Borrower alao will be charged eltlter 10.000% of tlte .um of the unpaid principal plu. accrued unpaid Interest or $25.00,
whichever 18 greater.
INTEREST AFTER DEFAULT. Upon default, including lallure to pay upon tinal maturity, Lender, at its option, may, "parmitted under applicable iaw,
increase the variable interest rate on this Note to 6.500 percentage points over the Index. The interest rate will not exceed the maximum rate permitted
by applicable law. If judgment is entered in connectiOn with th~ Note, interest will continue to accrue on this Note aiter judgment at the interest rate
applicable to this Note at the time judgment is entered.
DEFAULT. Eaclt of the following shall constitute an event 01 defau~ ('Event of Defau~') under this Note:
Payment Default. Borrower fails to make any payment when due under this Note.
Other Defaults. Borrower fails to comply with or to perform any other term, obligation, covenant or condition contained in this Note or in any of
the related documents or to comply with or to perform any term, obligation, covenant or condition contained in any other agreement between
Lender and Borrower.
False Statements. Any warranty, representation or statement made or furnished to Lender by Borrower or on Borrower's behalf under this Note
or the related documents is false or misleading in any material respect, either now or at the time made or furnished or becomes false or misleading
at any time thereafter.
Insolvency. The dissolutIon or termination of Borrower's existence as a going business, the insolvency of Borrower, the appointment of a receiver
for any part of Borrower's property, any assignment for the benefit of creditors, any type of creditor workout, or the commencement 01 any
proceeding under any bankruptcy or insolvency laws by or against Borrower.
Creditor or Forfeiture Proceeding.. Commencement of foreclosure or forfeiture proceedings, whether by judicial proceeding, self-help,
repossession or any other method, by any creditor of Borrower or by any governmental agency against any collateral securing the loan. This
includes a garnishment of any of Borrower's accounts, including deposit accounts, with Lender. However, this Event of Default shall not apply if
there is a good faith dispute by Borrower as to the validity or reasonableness of the claim which is the basis 01 the creditor or forfeiture proceeding
and it Borrower gives lender written notice of the creditor or forfeiture proceeding and deposits with lender monies or a surety bond for the
creditor or forfeiture proceeding, in an amount determined by Lender, in its sole discretion, as being an adequate reserve or bOnd for the dtspute.
Events Affecting Guarantor. Any of the preceding events occurs with respect to any Guarantor of any of the indebtedness or any Guarantor dies
or becomes incompetent, or revokes or disputes the validity of, or liability under, any guaranty of the indebtedness evidenced by this Note.
Change In Ownership. Any change in ownership of twenty-five percent (25%) or more of the common stock of Borrower.
Adverse Change. A material adverse change occurs in Borrower's financial condition, or Lender believes the prospect of payment or
performance of this Note is impaired.
Insecurity. Lender 'In good faith believes itself Insecure,
LENDER'S RIGHTS. Upon default, Lender may, after giving such notrces as required by applicable law, declare the entire unpaid principal balance on
Loan No: 500029863
PROMISSORY NOTE
(Continued)
Page 2
this Note and all accrued unpaid interest immediately due, and then Borrower will pay that amount.
ATTORNEYS' FEES; EXPENSES. Lender may hire or pay someone else to help collect this Note if Borrower does not pay. Borrower will pay Lender
that amount. This includes, subject to any limits under applicable law, Lenders attorneys' fees and Lender's legal expenses, whether or not there is a
lawsuit, including attorneys' fees, expenses for bankruptcy proceedings (including efforts to modify or vacate any automatic stay or injunction), and
appeals. If not prohibited by applicable law, Borrower also will pay any court costs, in addition to all other sums provided by law.
JURY WAIVER. Lender and Borrower hereby waive Ihe right 10 any jury Irlal In any action, proceeding, or counterclaim brought by either
lender or Borrower against the other.
GOVERNING LAW. Thla Note will be governed by federal law applicable to Lender and, to the extent not preempted by federal law, the lawe of
the Commonwealth of Pennsylvania without regard to It I conflicts of law provisions. This Note has been accepted by Lender In the
Commonwealth of Pennsylvania.
CHOICE OF VENUE. If there is a lawsuit, Borrower agrees upon Lender's request to submit to the jurisdiction of the courts of Dauphin County,
Commonwealth of Pennsylvania.
RIGHT OF SETOFF. To the extent permitted by applicable law, Lender reserves a right of setoff in all Borrower's accounts with Lender (whether
checking, savings. or some other account). This includes all accounts Borrower holds jointly with someone else and all accounts Borrower may open in
the future. However, this does not include any IRA or Keogh accounts, or any trust accounts for which setoff would be prohibited by law. Borrower
authorizes Lender, to the extent permitted by applicable law, to charge or setoff all sums owing on the indebtedness against any and all such accounts,
and, at Lender's option, to administratively freeze all such accounts to allow Lender to protect Lender's charge and setoff rights provided in this
paragraph.
COLLATERAL Borrower acknowledges this Note is secured by the following collateral described in the security instrument listed herein: inventory,
chattel paper, accounts, equipment and general intangibles described in a Commercial Security Agreement dated May 10, 2005.
UNE OF CREDIT. This Note evidences a revolving line of credit. Advances under this Note, as well as directions for payment from Borrower's
accounts, may be requested orally or in writing by Borrower or by an authorized person. Lender may, but need not, require that all oral requests be
confirmed in writing. Borrower agrees to be liable for all sums either: (A) advanced in accordance with the instructions of an authorized person or (B)
credited to any of Borrower's accounts with Lender. The unpaid principal balance owing on this Note at any time may be evidenced by endorsements
on this Note or by Lender's internal records, including daily computer print-outs. Lender will have no obligation to advance funds under this Note if:
(A) Borrower or any guarantor is in default under the terms of this Note or any agreement that Borrower or any guarantor has with Lender, including
any agreement made in connection with the signing of this Note; (B) Borrower or any guarantor ceases doing business or is insolvent; (C) any
guarantor seeks, claims or otherwise attempts to limit, modify or revoke such guarantor's guarantee of this Note or any other loan with Lender; (0)
Borrower has applied funds provided pursuant to this Note for purposes other than those authorized by Lender; or (E) Lender in good faith believes
itself insecure.
PRIMARY DEPOSIT ACCOUNTS. Borrower agrees to open and maintain its primary business deposit account ("Account") with Lender so long as this
Note has an outstanding balance or loan availability. If Borrower does not open or maintain the Account with Lender, Borrower authorizes Lender to
increase the interest rate on this loan by one-quarter of one percent (0.250%).
DEMAND LOAN MATURITY AND ANNUAL REVIEW. This loan Is written on demand with no specific malurily date. This ioan Is subject 10 an annual
review by Lender of financial information and loan performance. The first annual review is scheduled for July 1, 2006. To facilitate the annual review
process, Lender may use a maturity date on its computer system or systems which may appear on billing statements or other mailings and notices to
Borrower. The presence of a maturity date on billing statements or other mailings and notices shall not be considered a waiver of Lenders right to
demand full repayment of the loan at any time.
SUCCESSOR INTERESTS. The terms of this Note shall be binding upon Borrower, and upon Borrower's heirs, personal representatives, successors
and assigns, and shall inure to the benefit of Lender and its successors and assigns.
NOTIFY US OF INACCURA TE INFORMATION WE REPORT TO CONSUMER REPORTING AGENCIES. Please nOllfy us If we report any Inaccurate
information about your account(s) to a consumer reporting agency. Your written notice describing the specific inaccuracy(ies) should be sent to us at
the following address: Mid Penn Bank, Derry Street Office, 4098 Derry Slreet, Harrisburg, PA 17111.
GENERAL PROVISIONS. This Note Is payable on demand. The inclusion of specific defau" provisions or rights of Lender shall nol preclude Lender's
right to declare payment of this Note on its demand. Lender may delay or forgo enforcing any of its rights or remedies under this Note without losing
them. Borrower and any other person who signs, guarantees or endorses this Note, to the extent allowed by law, waive presentment, demand for
payment, and notice of dishonor. Upon any change in the terms of this Note, and unless otherwise expressly stated in writing, no party who signs this
Note, whether as maker, guarantor, accommodation maker or endorser, shall be released from liability. All such parties agree that lender may renew
or extend (repeatedly and for any length of time) this loan or release any party or guarantor or collateral; or impair, fail to realize upon or perfect
Lender's security interest in the collateral; and take any other action deemed necessary by Lender without the consent of or notice to anyone. All such
parties also agree that Lender may modify this loan without the consent of or notice to anyone other than the party with whom the modification is made.
The obligations under this Note are joint and several. If any portion of this Note is for any reason determined to be unenforceable, it will not affect the
enforceability of any other provisions of this Note.
CONFESSION OF JUDGMENT. BORROWER HEREBY IRREVOCABLY AUTHORIZES AND EMPOWERS ANY ATTORNEY OR THE PROTHONOTARY
OR CLERK OF ANY COURT IN THE COMMONWEALTH OF PENNSYLVANIA, OR ELSEWHERE, TO APPEAR AT ANY TIME FOR BORROWER AFTER
A DEFAULT UNDER THIS NOTE AND WITH OR WITHOUT COMPLAINT FILED, CONFESS OR ENTER JUDGMENT AGAINST BORROWER FOR THE
ENTIRE PRINCIPAL BALANCE OF THIS NOTE AND ALL ACCRUED INTEREST, LATE CHARGES AND ANY AND ALL AMOUNTS EXPENDED OR
ADVANCED BY LENDER RELATiNG TO ANY COLLATERAL SECURING THIS NOTE, TOGETHER WITH COSTS OF SUIT, AND AN ATTORNEY'S
COMMISSION OF TEN PERCENT (10%) OF THE UNPAID PRINCIPAL BALANCE AND ACCRUED INTEREST FOR COLLECTION, BUT IN ANY EVENT
NOT LESS THAN FIVE HUNDRED DOLLARS ($500) ON WHICH JUDGMENT OR JUDGMENTS ONE OR MORE EXECUTIONS MAY ISSUE
IMMEDIATELY; AND FOR SO DOING, THIS NOTE OR A COpy OF THIS NOTE VERIFIED BY AFFIDAVIT SHALL BE SUFFICIENT WARRANT. THE
AUTHORITY GRANTED IN THIS NOTE TO CONFESS JUDGMENT AGAINST BORROWER SHALL NOT BE EXHAUSTED BY ANY EXERCISE OF THAT
AUTHORITY, BUT SHALL CONTINUE FROM TIME TO TIME AND AT ALL TIMES UNTIL PAYMENT IN FULL OF ALL AMOUNTS DUE UNDER THIS
NOTE. BORROWER HEREBY WAIVES ANY RIGHT BORROWER MAY HAVE TO NOTICE OR TO A HEARING IN CONNECTION WITH ANY SUCH
CONFESSION OF JUDGMENT AND STATES THAT EITHER A REPRESENTATIVE OF LENDER SPECIFICALLY CALLED THIS CONFESSION OF
JUDGMENT PROVISION TO BORROWER'S ATTENTION OR BORROWER HAS BEEN REPRESENTED BY INDEPENDENT LEGAL COUNSEL
Loan No: 500029863
PROMISSORY NOTE
(Continued)
Page 3
PRIOR TO SIGNING ntlS NOTE, BORROWER READ AND UNDERSTOOD ALL THE PROVISIONS OF ntlS NOTE, INCLUDING THE VARIABLE
INTEREST RATE PROVISIONS. BORROWER AGREES TO ntE TERMS OF ntE NOTE.
BORROWER ACKNOWLEDGES RECEIPT OF A COMPLETED COPY OF ntlS PROMISSORY NOTE.
ntlS NOTE IS GIVEN UNDER SEAL AND IT IS INTENDED ntAT ntlS NOTE IS AND SHALL CONSTITUTE AND HAVE THE EFFECT OF A
SEALED INSTRUMENT ACCORDING TO LAW.
BORROWER:
Seal)
v.sEflPRO~v...5.i6.cnOO5Cop'~'.........~.lnc.'iIlJ1,2OOI5.AlI~Reurvecl.'PAL'CfllLPl.\02I).FCTR'3OI2Pf1-Sec..u"fe
DISCL( JRE FOR CONFESSION OJ
UDGMENT
, PrIncIpal
$5000\),00
l.oan Date
()50.1().m5
. ... l.oan NO
500029863
hlltlale
References in the shaded area are for Lender's use only and do not limit the applicability of this document to any particular loan or item.
Any item above containing uu. has been omitted due to text length limitations.
Declarant: Joey V's, Inc. D/B/A Joey's Ranan Grill (TIN:
03-(555554)
433 North 2181 Street
Camp Hili, PA 17011
Lender:
Mid Pann Bank
Darry Street Office
4098 Derry Street
Harrisburg, PA 17111
DISCLOSURE FOR CONFESSION OF JUDGMENT
10 M'L"
THE UNDERSIGNED IS EXECUTING ON BEHALF OF DECLARANT, THIS DAY OF !!L!!. <
PROMISSORY NOTE FOR $50,000.00 OBLIGATING DECLARANT TO REPAY THAT AMOUNT.
A. THE UNDERSIGNED UNDERSTANDS THAT THE NOTE CONTAINS A CONFESSION OF JUDGMENT PROVISION THAT WOULD PERMIT
LENDER TO ENTER JUDGMENT AGAINST DECLARANT IN COURT, AFTER A DEFAULT ON THE NOTE, WITHOUT ADVANCE NOTICE TO
DECLARANT AND WITHOUT OFFERING DECLARANT AN OPPORTUNITY TO DEFEND AGAINST THE ENTRY OF JUDGMENT. IN EXECUTING
THE NOTE, BEING FULLY AWARE OF DECLARANrS RIGHTS TO ADVANCE NOTICE AND TO A HEARING TO CONTEST THE VALIDITY OF
ANY JUDGMENT OR OTHER CLAIMS THAT LENDER MAY ASSERT AGAINST DECLARANT UNDER THE NOTE, THE UNDERSIGNED, ON
BEHALF OF THE DECLARANT, IS KNOWINGLY, INTELLIGENTl.Y, AND VOLUNTARILY WAIVING THESE RIGHTS, INCLUDING ANY RIGHT TO
ADVANCE N TICE OF THE ENTRY OF JUDGMENT, AND THE UNDERSIGNED EXPRESSLY AGREES AND CONSENTS TO LENDER'S ENTERING
JUDGMENT AI ST DECLARA T BY CONFESSION AS PROVIDED FOR IN THE CONFESSION OF JUDGMENT PROVISION.
INITIALS:
, 200f ,
B. THE UND RSIGNED FURTHER UNDERSTANDS THAT IN ADDITION TO GIVING LENDER THE RIGHT TO ENTER JUDGMENT AGAINST
DECLARANT WITHOUT ADVANCE NOTICE OR A HEARING, THE CONFESSION OF JUDGMENT PROVISION IN THE NOTE ALSO CONTAINS
LANGUAGE THAT WOULD PERMIT LENDER, AFTER ENTRY OF JUDGMENT, AGAIN WITHOUT EITHER ADVANCE NOTICE OR A HEARING, TO
EXECUTE ON THE JUDGMENT BY FORECLOSING UPON, ATTACHING, LEVYING ON, TAKING POSSESSION OF OR OTHERWISE SEIZING
DECLARANrS PROPERTY, IN FULL OR PARTIAL PAYMENT OF THE JUDGMENT. IN EXECUTING THE NOTE, BEING FULLY AWARE OF
DECLARANrS RIGHTS TO ADVANCE NOTICE AND A HEARING AFTER JUDGMENT IS ENTERED AND BEFORE EXECUTION ON THE
JUDGMENT, THE UNDERSIGNED, ON BEHALF OF THE DECLARANT, IS KNOWINGLY, INTELLlGENl1. Y AND VOLUNTARILY WAIVING THESE
RIGHTS, A D THE UNDERSIGNED EXPRESSLY AGREES AND CONSENTS TO LENDER'S IMMEDIATELY EXECUTING ON THE JUDGMENT IN
ANY MANN R P RMITTED B PPLlCABLE STATE AND FEDERAL LAW, WITHOUT GIVING DECLARANT ANY ADVANCE NOTICE.
INITIALS:
C. AFT AVING READ AND DETERMINED WHICH OF THE FOLLOWING STATEMENTS ARE APPLICABLE, BY INITIALING EACH
STATEMENT THAT APPLIES, THE UNDERSIGNED REPRESENTS THAT:
INITIALS
~. DECLARANT WAS REPRESENTED BY DECLARANrS OWN INDEPENDENT LEGAL COUNSEL IN CONNECTION WITH THE
NOTE.
. 2. A REPRESENTATIVE OF LENDER SPECIFICALLY CALLED THE CONFESSION OF JUDGMENT PROVISION IN THE NOTE TO
DECLARANT'S ATTENTION.
THIS DISCLOSURE IS GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS DISCLOSURE IS AND SHALL CONSTITUTE AND HAVE THE
EFFECT OF A SEALED INSTRUMENT ACCORDING TO LAW.
DECLARANT:
JOE
EY'S ITALIAN G I
/C
Joey V'., Inc.
y V. erger. President 0
A Joey's Itanan Grill
l.ASfRPRCllO<'o:lf'o;l,Y...!.2I.OQ.OQ! c.:.pt. ...._I'~ Soou_.'roc, 'WI.1OOIi. NlAoQrQ_...... f'A '-Cf"CPl'.030.FC rR_JOQ PFl-SfC_LiNE
EXHIBIT "B"
COMMERCIAL GUARAN'.
References in the shaded area are for Lender's use only and do not limit the applicability of this document to any particular loan or item.
Any item above containin "'u. has been omitted due to text length limitations.
Borrower: Joey V'a, Inc. DIBIA Joey'a Italian Grill (TIN:
03-0555654)
433 North 210t Stroet
Camp Hili, PA 17011
Guarantor: Joey V. Sullenberger (SSN: 197-60-6048)
481 Sample Bridge Rood
Enole, PA 17025
Lender:
Mid Penn Bank
Derry Slroet Office
4098 Derry Stroet
Harrisburg, PA 17111
AMOUNT OF GUARANTY. This Is a guaranty of payment of the Note, Including wllhoUlllmllotlon the principal Note amounl of Fifty Thousand
<<< 0011 00 Dollaro ($50,000.00).
GUARANTY. For good and valuable conslderotlon, Joey V. Sullenberger ("Guarantor") absolUlely and uncondlllonally guarant_ and
promisee to pay to Mid Penn Bank ("Lender") or Ita order, on demand, In legal tender of the Unllad Stot.. of America, the Indabtadn..a (as
that term la deflnad below) of Joey V'a, Inc. D/B/A Joey'a lIallan Grill ("Borrower") to Lender on the terma and condltlona aot forth In this
Guaranty.
MAXIMUM L1ABIUTY. The maximum liability of Guarantor under this Guaranty shall not exceed at anyone time the amount of the Indebtedness
described herein, plus all costs and expenses of (A) enforcement of this Guaranty and (8) collection and sale of any collateral securing this Guaranty.
The above limitation on liability is not a restriction on the amount of the Indebtedness of Borrower to Lender either in the aggregate or at anyone time.
If Lender presently holds one or more guaranties, or hereafter receives additional guaranties from Guarantor, Lender's rights under all guaranties shall
be cumulative. This Guaranty shall not (unless specifically providad below to the contrary) affect or invalidate any such other guaranties. Guarantor's
liability will be Guarantor's aggregate liability under the terms of this Guaranty and any such other unterminatad guaranties.
INDEBTEDNESS GUARANTEED. The Indebtedness guarantead by lI1is Guaranty includes the Note, including (a) all principal, (b) all interest, (c) all
late charges, (d) all loan fees and loan charges, and (e) all collection costs and expenses relating to lI1e Note or to any collateral for lI1e Note.
Collection costs and expenses Include without limitation all of Lender's attorneys' fees.
DURATION OF GUARANTY. This Guaranty will take effect when receivad by Lender without lI1e necessity of any acceptance by Lender, or any notice
to Guarantor or to Borrower, and will continue in full force until all Indebtedness shall have been fully and finally paid and satisfied and all of Guarantor's
other obligations under this Guaranty shall have been performed in full. Release of any other guarantor or termination of any other guaranty of the
Indebtedness shall not affect the liability of Guarantor under this Guaranty. A revocation Lender receives from anyone or more Guarantors shall not
affect the liability of any remaining Guarantors under this Guaranty. This Guaranty covera a revolving line of credit and It 'a specifically anticipated
that fluctuations will occur In the aggregate amount of Indebtednees owing from Borrower to Lender. Guarantor specifically acknowJedgea
and agrees that fluctuations In the amount of Indebtednes8, even to zero dollars ($ 0.00), shall not con8tltute a termination of this Guaranty.
Guarantor'a liability under thla Guaranty ahalllermlnote only upon (A) termlnotlon In writing by Borrower and Lender of tha line of cradll, (B)
paymen1 of tha Indabtadnesa In full In legal tender, and (C) payment In full In legal tender of all of Guarantor'a other obl/gallona under thla
Guaranty.
GUARANTOR'S AUTHORIZATION TO LENDER. Guarantor authorizes Lender, wlthoUl notice or demand and wllhoUl '..aenlng Guarantor'a
liability under this Guaranty, from time to time: (A) to make one or more additional secured or unsecured loans to Borrower, to lease equipment or
other goods to Borrower, or otherwise to extend additional credit to Borrower; (8) to alter, compromise, renew, extend, accelerate, or otherwise
change one or more times the time for payment or other terms of the Indebtedness or any part of the Indebtedness, including increases and decreases
of lI1a rata of intarest on lI1e Indabtadness; extensions may be repeated and may be for longer lI1an 1110 original loan term; (el to taka and hold
security for the payment of this Guaranty or the Indebtedness, and exchange, enforce, waive, subordinate, fail or decide not to perfect, and release any
such security, with or without the substitution of new collateral; (0) to release, substitute, agree not to sue, or deal with anyone or more of Borrower's
sureties, endorsers, or other guarantors on any terms or in any manner Lender may choose; (E) to determine how, when and what application of
payments and credits shall be made on the Indebtedness; (F) to apply such security and direct the order or manner of sale thereof, including without
limitation, any nonjudicial sale permitted by the terms of the controlling security agreement or deed of trust, as lender in its discretion may determine;
(G) to sell, transfer, assign or grant participations in all or any part of the Indebtedness; and (H) to assign or transfer this Guaranty in whole or in part.
GUARANTOR'S REPRESENTATIONS AND WARRANTIES. Guarantor represents and warrants to Lender lI1at (A) no representations or agreements
of any kind have been made to Guarantor which would limit or qualify in any way the terms of this Guaranty; (B) this Guaranty is executed at
Borrower's request and not at the request of Lender; (e) Guarantor has full power, right and authority to enter into this Guaranty; (D) the provisions
of this Guaranty do not conflict with or result in a default under any agreement or other instrument binding upon Guarantor and do not result in a
violation of any law, regulation, court decree or order applicable to Guarantor; (E) Guarantor has not and will not, without the prior written consent of
lender, sell, lease, assign, encumber, hypothecate, transfer, or otherwise dispose of all or substantially all of Guarantor's assets, or any interest therein;
(F) upon Lender's request, Guarantor will provide to Lender financial and credit information in form acceptable to Lender, and all such financial
information which currently has been, and all future financial information which will be provided to Lender is and will be true and correct in all material
respects and fairly present Guarantor's financial condition as of the dates the financial Information is provided; (G) no material adverse change has
occurred in Guarantor's financial condition since the date of the most recent financial statements provided to Lender and no event has occurred which
may materially adversely affect Guarantor's financial condition; (H) no litigation, claim, investigation, administrative proceeding or similar action
(including those for unpaid taxes) against Guarantor is pending or threatened; (I) Lender has made no representation to Guarantor as to the
creditworthiness of Borrower; and (J) Guarantor has established adequate means of obtaining from Borrower on a continuing basis information
regarding Borrower's financial condition. Guarantor agrees to keep adequately informed from such means of any facts, events, or circumstances which
might in any way affect Guarantor's risks under this Guaranty, and Guarantor further agrees that Lender shall have no obligation to disclose to
Guarantor any information or documents acquired by Lender in the course of its relationship with Borrower.
GUARANTOR'S FINANCIAL STATEMENTS. Guarantor agrees to furnish Lender withll1e following:
Annual Statement.. As soon as available, but in no event later than one-hundrecHwenty (120) days atter the end of each fiscal year,
Guarantor's balance sheet and income statement for the year ended, prepared by Guarantor.
Tax Return.. As soon as available. but in no event later than thirty (30) days after the applicable filing date for the tax reporting period ended,
Federal and other governmental tax returns, prepared by Guarantor.
All financial reports required to be provided under this Guaranty shall be prepared in accordance with GAAP, applied on a consistent basis, and
certified by Guarantor as being true and correct.
Loan No: 500029863
COMMERCIAL GUARANTY
(Continued)
Page 2
GUARANTOR'S WAIVERS. Except as prohibited by applicable law, Guarantor waives any right to require Lender (A) to continue iending money or to
extend other credit to Borrower; (8) to make any presentment, protest, demand, or notice of any kind, including notice of any nonpayment of the
Indebtedness or of any nonpayment related to any collateral, or notice of any action or nooaction on the part of Borrower, Lender, any surety, endorser,
or other guarantor in connection with the Indebtedness or in connection with the creation of new or additional loans or obligations; (C) to resort for
payment or to proceed directly or at once against any person, Including Borrower or any other guarantor: (0) to proceed directly against or exhaust
any collateral held by Lender from Borrower, any other guarantor, or any other person; (E) to give notice of the terms, time, and place of any public or
private sale of personal property security held by Lender from Borrower or to comply with any other applicable provisions of the Uniform Commercial
Code; (F) to pursue any other remedy within Lender's power; or (G) to commit any act or omission ot any kind, or at any time, with respect to any
matter whatsoever.
In addition to the waivers set forth herein, if now or hereafter Borrower is or shall become insoNent and the Indebtedness shall not at all times until paid
be fully secured by collateral pledged by Borrower, Guarantor hereby forever waives and gives up in favor of Lender and Borrower, and Lender's and
Borrower's respective successors, any claim or right to payment Guarantor may now have or hereafter have or acquire against Borrower, by
subrogation or otherwise, so that at no time shall Guarantor be or become a .creditor" of Borrower within the meaning of 11 U.S.C. section 547(b), or
any successor provision of the Federal bankruptcy taws.
Guarantor also waives any and all rights or defenses arising by reason of (A) any "one action" or "antiMdeficiency" law or any other law which may
prevent Lender from bringing any action, including a claim for deficiency, against Guarantor, before or after Lender's commencement or completion of
any foreclosure action, either judicJal1y or by exercise of a power of sale; (B) any election of remedies by Lender which destroys or otherwise adversely
affects Guarantor's subrogation rights or Guarantor's rights to proceed against Borrower for reimbursement, including without limitation, afYol loss of
rights Guarantor may suffer by reason of any law limiting, qualifying, or discharging the Indebtedness; (C) any disability or other defense of Borrower,
of any other guarantor, or of any other person, or by reason of the cessation of Borrower's liability from any cause whatsoever, other than payment in
full in legal tender, of the Indebtedness; (0) any right to claim discharge of the Indebtedness on the basis of unjustified impairment of any collateral for
the Indebtedness; (E) any statute of limitations, if at any time any action or suit brought by Lender against Guarantor is commenced, there is
outstanding Indebtedness of Borrower to lender which is not barred by any applicable statute of limItations; or (F) any defenses given to guarantors
at taw or in equity other than actual payment and performance of the Indebtedness. If payment is made by Borrower, whether voluntarily or otherwise,
or by any third party, on the Indebtedness and thereafter Lender Is forced to remit the amount of that payment to Borrower's trustee in bankruptcy or to
any similar person under any federal or state bankruptcy law or law for the relief of debtors, the Indebtedness shall be considered unpaid for the
purpose of the enforcement of this Guaranty.
Guarantor further waives and agrees not to assert or claim at any time any deductions to the amount guaranteed under this Guaranty for any claim of
setoff, counterclaim, counter demand, recoupment or similar right, whether such claim, demand or right may be asserted by the Borrower, the
Guarantor, or both.
GUARANTOR'S UNDERSTANDING WITH RESPECT TO WAIVERS. Guarantor warrants and agrees that each of the waivers set forth above is made
with Guarantor's full knowledge of its significance and consequences and that, under the circumstances, the waivers are reasonable and not contrary to
public policy or law. If any such waiver is determined to be contrary to any applicable raw or publiC policy, such waiver shall be effective only to the
extent permitted by law or public poflCY.
RIGHT OF SETOFF. To the extent permitted by applicable law, lender reselVes a right of setoff in all Guarantor's accounts with Lender (whether
checking, savings, or some other account). This includes all accounts Guarantor holds jointfy with someone else and all accounts Guarantor may open
in the future. However, this does not include any IRA or Keogh accounts, or any trust accounts for which setoff would be prohibited by law. Guarantor
authorizes Lendef,to the extent permitted by appltcable law, to hold these funds if there is a default, and Lender may apply the funds in these accounts
to pay what Guarantor owes under the terms of this Guaranty.
SUBORDINATION OF BORROWER'S DEBTS TO GUARANTOR. Guarantor agrees that the Indebtedness of Borrower to Lender, whether now
existing or hereafter created, shall be superior to any claim that Guarantor may now have or hereafter acquire against Borrower, whether or not
Borrower becomes insolvent. Guarantor hereby expressly subordinates any claim Guarantor may have against Borrower, upon any account
whatsoever, to any claim that Lender may now or hereafter have against Borrower. In the event of insolvency and consequent liquidation of the assets
of Borrower, through bankruptcy, by an assignment for the benefit of creditors, by voluntary liquidation, or otherwise, the assets of Borrower applicable
to the payment of the claims of both Lender and Guarantor shall be paid to Lender and shall be first applied by Lender to the Indebtedness of Borrower
to Lender. Guarantor does hereby assign to Lender all claims which it may have or acquire against Borrower or against any assignee Of trustee in
bankruptcy of Borrower: provided however, that such assignment shall be effective only for the purpose of assuring to Lender full payment in legal
tender of the Indebtedness. If Lender so requests, any notes or credit agreements now or hereafter evidencing any debts or obligations of Borrower to
Guarantor shall be marked. with a legend that the same are subject to this Guaranty and shaH be delivered to lender. Guarantor agrees, and Lender is
hereby authorized, in the name of Guarantor, from time to time to file financing statements and continuation statements and to execute documents and
to take such other actions as Lender deems necessary or appropriate to perfect, preserve and enforce its rights under this Guaranty.
MISCELLANEOUS PROVISIONS. The failowing miscellaneous provisions are a part of this Guaranty:
Amendments. This Guaranty, together with any Related Documents, constitutes the entire understanding and agreement of the parties as to the
matters set forth in this Guaranty. No alteration of or amendment to this Guaranty shall be effective unless given in writing and signed by the party
or parties sought to be charged or bOund by the alteration or amendment.
Attorneys' Fees; Expenses. Guarantor agrees to pay upon demand all of Lender's costs and expenses, including Lender's attorneys' fees and
Lender's legal expenses, incurred in connection with the enforcement of this Guaranty. Lender may hire or pay someone else to help enforce this
Guaranty, and Guarantor shall pay the costs and expenses of such enforcement. Costs and expenses include Lender's attorneys' fees and legal
expenses whether or not there is a lawsuit, including attorneys' fees and regal expenses for bankruptcy proceedings (inctuding efforts to modify or
vacate any automatic stay or injunction), appeals, and any anticipated post-judgment collection services. Guarantor also shall pay all court costs
and such additional fees as may be directed by the court.
Caption Headings. Caption headings in this Guaranty are for convenience purposes only and are not to be used to interpret or define the
provisions of this Guaranty.
Governing Law. This Guaranty will be governed by federal law applicable to Lender and, to the extent not preempted by feclerallaw, the
laws of the Commonwealth of Pennsylvania without regard to its conflicts of law provisions. This Guaranty has been accepted by Lender
in the Commonwealth of Pennsylvania.
Choice of Venue. If there is a lawsuit, Guarantor agrees upon Lender's request to submit to the jurisdiction of the courts of Dauphin County,
Commonwealth of Pennsylvania.
Integration. Guarantor further agrees that Guar8l1tor has read and fully understands the terms of this Guaranty; Guarantor has had the
opportunity to be advised by Guarantor's attorney with respect to this Guaranty; the Guaranty fully reflects Guarantor's intentions and parol
evidence is not required to interpret the terms of this Guaranty. Guarantor hereby indemnifies and holds Lender harmless from all losses, claims,
damages, and costs (including Lender's attorneys' fees) suffered or incurred by Lender as a result of any breach by Guarantor of the warranties,
Loan No: 500029863
COMMERCIAL GUARANTY'
(Continued)
Page 3
representations and agreements of this paragraph.
Interpretation. In all cases where there is more than one Borrower or Guarantor, then all words used in this Guaranty in the singular shall be
deemed to have been used in the plural where the context and construction so require; and where there is more than one Borrower named in this
Guaranty or when this Guaranty is executed by more than one Guarantor, the words "Borrower" and "Guarantor" respectively shall mean all and
anyone or more of them. The words "Guarantor,. "Borrower,. and "lender" include the heirs. successors, assigns, and transferees of each of
them. If a court finds that any provision of this Guaranty is not valid or should not be enforced, that fact by itself will not mean that the rest of this
Guaranty will not be valid or enforced. Therefore, a court will enforce the rest of the provisions of this Guaranty even if a provision of this Guaranty
may be found to be invalid or unenforceable. If anyone or more of Borrower or Guarantor are corporations, partnerships, limited liability
companies, or similar entities, it is not necessary for lender to inquire into the powers of Borrower or Guarantor or of the officers, directors,
partners, managers, or other agents acting or purporting to act on their behalf, and any indebtedness made or created in reliance upon the
professed exercise of such powers shall be guaranteed under thIs Guaranty.
Notices. Unless otherwise provided by applicable law, any notice required to be given under this Guaranty shall be given in writing, and shall be
effective when actually delivered, when actually received by telefacsimile (unless otherwise required by law), when deposited with a nationally
recognized overnight courier, or, if mailed, when deposited in the United States mail, as first class, certified or registered mall postage prepaid,
directed to the addresses shown near the beginning of this Guaranty. Any party may change its address for notices under this Guaranty by giving
formal written notice to the other parties, specifying that the purpose of the notice is to change the party's address. For notice purposes,
Guarantor agrees to keep Lender informed at all times of Guarantor's current address. Unless otherwise provided by applicable law, if there is
more than one Guarantor, any notice given by Lender to any Guarantor is deemed to be notice given to all Guarantors.
No Waiver by Lender. Lender shall not be deemed to have waived any rights under this Guaranty unless such waiver is given in writing and
signed by Lender. No delay or omission on the part of Lender in exercising any right shall operate as a waiver of such right or any other right. A
waiver by Lender of a provision of this Guaranty shall not prejudice or constitute a waiver of Lender's right otherwise to demand strict compliance
with that provision or any other provision of this Guaranty. No prior waiver by Lender, nor any course of dealing between Lender and Guarantor,
shall constitute a waiver of any of Lender's rights or of any of Guarantor's obligations as to any future transactions. Whenever the consent of
Lender is required under this Guaranty, the granting of such consent by Lender in any instance shall not constitute continuing consent to
subsequent instances where such consent is required and in all cases such consent may be granted or withheld in the sole discretion of Lender.
Successors and Assigns. The terms of this Guaranty shall be binding upon Guarantor, and upon Guarantor's heirs, personal representatives,
successors, and assigns, and shall be enforceable by Lender and its successors and assigns.
Waive Jury. Lender and Guarantor hereby waive the right to any jury trial In any action, proceeding, or counterclaim brought by either
Lender or Borrower agalnBt the other.
DEFINmONS. The following capitalized words and tenns shall have the following meanings when used in this Guaranty. Unless specffically slated to
the contrary, all references to dollar amounts shall mean amounts in lawful money of the United States of America. Words and terms used in the
singular shall include the plural, and the ptural shall include the singular, as the context may require. Words and terms not otherwise defined in this
Guaranty shall have the meanings attributed to such terms in the Uniform Commercial Code:
Borrower. The word "Borrower" means Joey Vs, Inc. D/B/A Joey's Italian Grill and includes all co-signers and co-makers- signing the Note.
GAAP. The word "GMP" means generally accepted accounting principles.
Guarantor. The word "Guarantor" means each and every person or entity signing this Guaranty, including without limitation Joey V. Sullenberger.
Guaranty. The word "Guaranty" means the guaranty from Guarantor to Lender, including without limitation a guaranty of all or part of the Note.
Indebtedness. The word "Indebtedness" means Borrower's indebtedness to Lender as more particularly described in this Guaranty.
Lender. The word "Lender" means Mid Penn Bank, its successors and assigns.
Note. The word "Note" means the promissory note dated May 10, 2005, In the original principal amount of $501000.00 from Borrower to Lender,
together with all renewals of, extensions of, modifications of, refinancings of. consolidations of, and substitutions for the promissory note or
agreement.
Related Documents. The words "Related Documents" mean all promissory notes, credit agreements, loan agreements, environmental
agreements, guaranties, security agreements. mortgages, deeds of trust, security deeds, collateral mortgages, and all other instruments,
agreements and documents, whether now or hereafter existing, executed in connection with the Indebtedness.
CONFESSION OF JUDGMENT. GUARANTOR HEREBY IRREVOCABLY AUTHORIZES AND EMPOWERS ANY ATTORNEY OR THE
PROTHONOTARY OR CLERK OF ANY COURT IN THE COMMONWEALTH OF PENNSYLVANIA, OR ELSEWHERE, TO APPEAR AT ANY TIME FOR
GUARANTOR AFTER THE AMOUNTS HEREUNDER BECOME DUE AND WITH OR WITHOUT COMPLAINT FILED, CONFESS OR ENTER JUDGMENT
AGAINST GUARANTOR FOR THE ENTIRE PRINCIPAL BALANCE OF THIS GUARANTY AND ALL ACCRUED INTEREST. LATE CHARGES AND ANY
AND ALL AMOUNTS EXPENDED OR ADVANCED BY LENDER RELATING TO ANY COLLATERAL SECURING THE INDEBTEDNESS, TOGETHER
WITH COSTS OF SUIT, AND AN ATTORNEY'S COMMISSION OF TEN PERCENT (10%) OF THE UNPAID PRINCIPAL BALANCE AND ACCRUED
INTEREST FOR COLLECTION, BUT IN ANY EVENT NOT LESS THAN FIVE HUNDRED DOLLARS ($500) ON WHICH JUDGMENT OR JUDGMENTS
ONE OR MORE EXECUTIONS MAY ISSUE IMMEDIATELY; AND FOR SO DOING, THIS GUARANTY OR A COPY OF THiS GUARANTY VERIFIED BY
AFFIDAVIT SHALL BE SUFFICIENT WARRANT. THE AUTHORITY GRANTED IN THIS GUARANTY TO CONFESS JUDGMENT AGAINST GUARANTOR
SHALL NOT BE EXHAUSTED BY ANY EXERCISE OF THAT AUTHORITY, BUT SHALL CONTINUE FROM TIME TO TIME AND AT ALL TIMES UNTIL
PAYMENT IN FULL OF ALL AMOUNTS DUE UNDER THIS GUARANTY. GUARANTOR HEREBY WAIVES ANY RIGHT GUARANTOR MAY HAVE TO
NOTICE OR TO A HEARING IN CONNECTION WITH ANY SUCH CONFESSION OF JUDGMENT AND STATES THAT EITHER A REPRESENTATIVE
OF LENDER SPECIFICALLY CALLED THIS CONFESSION OF JUDGMENT PROVISION TO GUARANTOR'S ATTENTION OR GUARANTOR HAS BEEN
REPRESENTED BY INDEPENDENT LEGAL COUNSEL
Loan No: 500029863
COMMERCIAL GUARANTY
(Continued)
Page 4
EACH UNDERSIGNED GUARANTOR ACKNOWLEDGES HAVING READ ALL THE PROVISIONS OF THIS GUARANTY AND AGREES TO ITS
TERMS. IN ADDI110N, EACH GUARANTOR UNDERSTANDS THAT THIS GUARANTY IS EFFECTIVE UPON GUARANTOR'S EXECUTION AND
DELIVERY OF THIS GUARANTY TO LENDER AND THAT THE GUARANTY WILL CONTINUE UNTIL TERMINATED IN THE MANNER SET FORTH
IN THE SECTION TITLED "DURATION OF GUARANTY". NO FORMAL ACCEPTANCE BY LENDER IS NECESSARY TO MAKE THIS GUARANTY
EFFECTIVE. THIS GUARANTY IS DATED MAY 10, 2005.
THIS GUARANTY IS GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS GUARANTY IS AND SHALL CONSTITUTE AND HAVE THE EFFECT
OF A SEALED INSTRUMENT ACCORDING TO LAW.
cI
V. Sullenberger
Seal)
X
J
INDIVIDUAL ACKNOWLEDGMENT
COMMONWEALTH OF PENNSYLVANIA
)
)SS
)
COUNTYOF ]1'f'/J
flY-/'
On this, the
,2041" ,before me ~~. .4.1J,~v-
blic, personally appeared Joey V. Sullenberger, kno to me (or s factorily
instrument, and acknowledged that he or she executed the same for the purposes
day of
, the undersigned Notary
proven) to be the person whose name is subscribed to the w'
therein contained.
In witness whereof, I hereunto set my: hand and official seal.
COMMONWEALTH OF PENNSYLVANIA
_Sell
Wer4y A. WItmyer, NoIaJy Public
0IIvet Twp., Petry County
My COITrnIooIon ElcpIres Jan. 4, 2009
Member, Pennaytvanla AaaociaUon Of Notarl..
USERPAO..........V..5.21l.OIl.o:lll ~.___.I...1W7.:/OO5, ....1ligIU__ .p,," l;lCf1IU'I.\E20.FC TR-JOlI2 PA-SfC-LlNE
DISCLC. JRE FOR CONFESSION OF JDGMENT
PrIncipal Loan Date . Loan No Inltlaht
$50000.00. 05-10<200$.. . 500029863
References in the shaded area are for Lender's use only and do not limit the applicability of this document to any particular loan or item.
An item above containing ....... has been omitted due to text len h limitations.
Borrower: Joey V's, Inc. D/B/A Joey's italian Grill (11N:
03-05S5654)
433 North 21st Street
Camp Hili, PA 17011
Declarant: Joey V. Sullenberger (SSN: 197-60-6048)
481 Sample Bridge Road
Enola, PA 17025
Lender:
Mid Penn Ban~
Derry Street Office
4098 Derry Street
Harrisburg, PA 17111
DISCLOSURE FOR CONFESSION OF JUDGMENT
viA.. <I'
I AM EXECUTING, THIS I 0 DAY OF ","
,
OBLIGATING ME TO REPAY THAT AMOUNT.
. 200 r. A GUARANTY OF A PROMISSORY NOTE FOR $50,000.1
A. I UNDERSTANO THAT THE GUARANTY CONTAINS A CONFESSION OF JUDGMENT PROYISION THAT WOULD PERMIT LENDER TO ENTER
JUDGMENT AGAINST ME IN COURT, AFTER A DEFAULT ON THE GUARANTY, WITHOUT ADVANCE NOTICE TO ME AND WITHOUT OFFERING
ME AN OPPORTUNITY TO DEFEND AGAINST THE ENTRY OF JUDGMENT. IN EXECUTING THE GUARANTY, BEING FULLY AWARE OF MY
RIGHTS TO ADVANCE NOTICE AND TO A HEARING TO CONTEST THE VALIDITY OF ANY JUDGMENT OR OTHER CLAIMS THAT LENDER
MAY ASSERT AGAINST ME UNDER THE GUARANTY, I AM KNOWINGLY, INTELLIGENTLY, AND VOLUNTARILY WAIVING THESE RIGHTS,
INCLUDING Y RIG T TO ADVANCE NOTICE OF THE ENTRY OF JUDGMENT, AND I EXPRESSLY AGREE AND CONSENT TO LENDER'S
ENTERING D AGAINST ME BY CONFESSION AS PROVIDED FOR IN THE CONFESSION OF JUDGMENT PROVISION.
/. INITIALS:
B. I FUR R UNDERSTAND THAT IN ADDITION TO GIVING LENDER THE RIGHT TO ENTER JUDGMENT AGAINST ME WITHOUT ADVANCE
NOTICE A HEARING, THE CONFESSION OF JUDGMENT PROVISION IN THE GUARANTY ALSO CONTAINS LANGUAGE THAT WOULD
PERMIT LENDER, AFTER ENTRY OF JUDGMENT, AGAIN WITHOUT EITHER ADVANCE NOTICE OR A HEARING, TO EXECUTE ON THE
JUDGMENT BY FORECLOSING UPON, ATTACHING, LEVYING ON, TAKING POSSESSION OF OR OTHERWISE SEIZING MY PROPERTY, IN
FULL OR PARTIAL PAYMENT OF THE JUDGMENT. IN EXECUTING THE GUARANTY, BEING FULLY AWARE OF MY RIGHTS TO ADVANCE
NOTICE AND A HEARING AFTER JUDGMENT IS ENTERED AND BEFORE EXECUTION ON THE JUDGMENT, I AM KNOWINGLY,
INTELLIGENTLY AND VOLUNTARILY WAIVING THESE RIGHTS, AND I EXPRESSLY AGREE AND CONSENT TO LENDER'S IMMEDIATELY
EXECUTING N THE JUDGMENT IN ANY MANNER PERMITTED BY APPLICABLE STATE AND FEDERAL LAW, WITHOUT GIVING ME ANY
ADVANCE TIC
" INITIALS:
C. AFTE HAVING READ AND DETERMINED WHICH OF THE FOLLOWING STATEMENTS ARE APPLICABLE, BY INITIALING EACH
STATEMENT THAT APPLIES, I REPRESENT THAT:
INITIALS
JrL 1. I WAS REPRESENTEO BY MY OWN INDEPENDENT LEGAL COUNSEL IN CONNECTION WITH THE GUARANTY.
, 2. A REPRESENTATIVE OF LENDER SPECIFICALLY CALLED THE CONFESSION OF JUDGMENT PROVISION IN THE GUARANTY
TO MY ATTENTION.
D. I CERTIFY THAT MY ANNUAL INCOME EXCEEDS $10,000; THAT THE BLANKS IN THIS DISCLOSURE WERE FILLED IN WHEN I INITIALED
AND SIGNED IT; AND fHAT I RECEIVED A COPY AT THE TIME OF SIGNING.
THIS DISCLOSURE IS GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS DISCLOSURE IS AND SHALL CONSTITUTE AND HAVE THE
EFFECT OF A SEALED INSTRUMENT ACCORDING TO LAW.
DECLARANT:
Seal)
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6
MID PENN BANK,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
,xO(p 0- i/:J(P Ci v/
NO.
v.
JOEY V'S, INC.,
d/b/a JOEY'S ITALIAN GRILL,
and JOEY V. SULLENBERGER,
a!k1a JOSEPH V. SULLENBERGER,:
Defendants
NOTICE OF ENTRY OF JUDGMENT
TO: Joey V's, Inc.
d/b/a Joey's Italian Grill
433 North 21 ,t Street
Camp Hill, PA 17011
Joey V. Sullenberger
a!k1a Joseph V. Sullenberger
481 Sample Bridge Road
Enola, P A 17025
YOU ARE HEREBY NOTIFIED that on the following
Judgment has been entered against you in the above-captioned case in the sum of $49,205.36
plus continuing interest from February 15, 2006, at the rate of$12.30 per diem, continuing late
charges, continuing costs, and continuing attorneys fees.
{}UA~
Protho otary /" ---- 7
I hereby certify that the name and address of the proper person to receive this notice under
Pa.R.C.P. 236 is:
Date:
Joey V's, Inc.
d/b/a Joey's Italian Grill
433 North 21" Street
Camp Hill, P A 170 II
Joey V. Sullenberger
a!k1a Joseph V. Sullenberger
481 Sample Bridge Road
Enola, PA 17025
Por este medio se Ie esta notificando que el de del 2006, el/la siguiente
Fallo he sido anotado en contra suya en el caso mencionado en el epigrafe.
FECHA:
Protonotario
Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado
de residencia:
Joey V's, Inc.
d/b/a Joey's Italian Grill
433 North 21" Street
Camp Hill, P A 17011
Joey V. Sullenberger
a!k1a Joseph V. Sullenberger
481 Sample Bridge Road
Enola, P A 17025
MID PENN BANK,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
NO. 06-1126
JOEY V'S, INC.,
d/b/a JOEY'S ITALIAN GRILL,
and JOEY V. SULLENBERGER,
a!k/a JOSEPH V. SULLENBERGER,
Defendants
AFFIDAVIT OF SERVICE OF
NOTICE UNDER RULE 2958.1 OF JUDGMENT IN EXECUTION THEREON
NOTICE OF DEFENDANT'S RIGHTS TO JOEY V'S, INC., d/b/a JOEY'S IT ALlAN
GRILL, AND JOEY V. SULLENBERGER a/k/a JOSEPH V. SULLENBERGER
I, Elisabeth Benecke, hereby affirm the following:
I. I am an adult over the age of eighteen (18), and I am not a party to the action nor an
employee of a party to the action.
2. On March 8, 2006, at approximately 3 :04 p.m., I served the Notice Under Rule 2958. I
of Judgment and Execution Thereon Notice of Defendants' Rights to Joey V's, by handing a
copy of the same to an individual, ofthe approximate height of five feet, five inches, an
approximate age of 45-50 years, with short auburn colored hair, and who identified herself as
"Bev" and claimed to be the individual in charge, at Joey's Italian Grill, located at 433 North 21,t
Street, Camp Hill, Cumberland County, Pennsylvania 170 II.
( OA~o.b.dh.~IJA1@O;P )
Elisabeth Benecke
Sworn to before me
this 8th day of March, 2006
t~/!J)~
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Linda B. Deaven. Notary Public
CIty Of Harrisburg, Dauphin Coonty
My Convnission Expires Feb. 25, 2010
Member, Pennsylvania Association 01 Notaries
"
",--,
MID PENN BANK,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
NO. 06-1126
JOEY V'S, INC.,
d/b/a JOEY'S ITALIAN GRILL,
and JOEY V. SULLENBERGER,
aIkIa JOSEPH V. SULLENBERGER,
Defendants
AFFIDAVIT OF SERVICE OF
NOTICE UNDER RULE 2958,1 OF JUDGMENT IN EXECUTION THEREON
NOTICE OF DEFENDANT'S RIGHTS TO JOEY V'S, INC., d/b/a JOEY'S ITALIAN
GRILL, AND JOEY V, SULLENBERGER a/k1a JOSEPH V. SULLENBERGER
I, Elisabeth Benecke, hereby affirm the following:
1. I am an adult over the age of eighteen (18), and I am not a party to the action nor an
employee of a party to the action.
2. On March 8, 2006, at approximately 2:34 p.m., I served the Notice Under Rule 2958.1
of Judgment and Execution Thereon Notice of Defendants' Rights to Joey V. Sullenberger, by
handing a copy of the same to an individual, of the approximate height of six feet, an
approximate age of38-45 years, with short curly brown hair, and who, when asked if this was the
Sullenberger residence, answered, "Yes.", at the residence on Sample Bridge Road, Enola,
Cumberland County, Pennsylvania 17025.
u,'Q..lA'N \:\ ~ II. Q~Du. )
Elisabeth Benecke
Sworn to before me
this 8th day of March, 2006
I~~ If ,Au~
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Linda B. Deaven, Nolaty Public
City O! Harrisburg, Dauphin County
My Commission Expires Feb. 25, 2010
Member, Pennsylvania Association of Notaries
c