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HomeMy WebLinkAbout09-12-06 ESTATE OF FLORENCE J. GORDON, (Deceased), : IN THE ORPHANS COURT OF : CUMBERLAND COUNTY, PENNSYL V ~IA c:;:;) c:::> c:r- (/) r1 '""\:J : NO. 2005-00916 (} C~~ 1_ _~IJ:g N PETITION TO ISSUE CITATION PURSUANT TO ORPHANS' COURT RULE 3 ;" C-) -n -1j 1---\ ~~- 1. The decedent, Florence J. Gordon, died testate on July 23,2005. A copy_--6f1the Death . - -, :'~~ --- __~ \.0 Certificate is attached hereto as Exhibit "A" and is incorporated herein by reference. 2. The estate of Florence J. Gordon was probated on October 17,2005. A copy of the Certificate of Grant of Letters is attached hereto as Exhibit "B" and is incorporated herein by reference. 3. Adam Gordon has been named Executor according to the Last Will and Testament left by the late Florence J. Gordon. A copy of the Last Will and Testament of Florence J. Gordon is attached hereto as Exhibit "C" and is incorporated herein by reference. 4. The estate is nearly void of assets, except for the late Florence J. Gordon's minority ownership in the Mandon Partnership. A copy of the Mandon Partnership Agreement is attached hereto as Exhibit "D" and is incorporated herein by reference. 5. Counsel for the Estate of Florence J. Gordon is Mark A. Mateya, Esquire. A copy of the Estate Information Sheet and Petition for Grant of Letters is attached hereto as Exhibit "E" and is incorporated herein by reference. 6. The surviving partners of the Mandon Partnership are, Fred R. Lerman and Robert R. Lerman, who are represented by Richard Engel, Esquire, Nottingham Law Office, One Lincoln Center, Syracuse, New York 13202. 7. An offer of $80,000.00 was made from Attorney Engle on behalf of Fred R. Lerman and Robert R. Lerman, to the beneficiary Adam Gordon in exchange for his share inherited from -n ".,.-, (') (---;J ~-(j :-;; I::J .\ (~f; .- ~"I! _~ C') ,_Of 1 '/ the Estate of Florence J. Gordon of Mandon Partnership. 8. The beneficiary, Adam Gordon, believes that the value offered for his inherited share of Mandon Partnership is substantially below the fair market value. 9. Attorney Mateya has negotiated on behalf of the Estate of Florence J. Gordon with Attorney Engle, negotiating on behalf of Fred R. Lerman and Robert R. Lerman to no avail. 10. Mandon Partnership clearly states the mechanism whereby the final price is arrived upon when the surviving partners and the new inheriting partner can not reach an agreement, naming a M.A.!. qualified appraiser. 11. The brothers, Fred R. Lerman and Robert R. Lerman continue to the present time to be unwilling to employ an M.A.!. approved appraiser in order to arrive at an equitable price for the purchase of the beneficiaries share. WHEREFORE, the Estate of Florence J. Gordon, requests this Honorable Court to issue a Citation directing Fred R. Lerman and Robert R. Lerman comply with the language of the Mandon Partnership Agreement, namely to hire a MAl approved appraiser and thereafter to follow through with the purchase of the decedent's share of the Partnership, according to the Mandon Partnership Agreement. Respectfully submitted, Date: qWO~ ~~~m Attorney LD. No. 78931 P.O. Box 127 Boiling Springs, P A 17007 (717) 241-6500 (717) 241-3099 Fax ~HoO!\MAIL ..~ powtfrod Oy . 0UTSIDE IN-, Pnnt - Close Window HTML f.xpORr VERIFICATION I, Adam Gordon, executor of the will of the late Florence J. Gordon I verify that the facts set forth in the foregoing pleading are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are subject to the penalties of 18 Pa. e.s. ~4904, relating to unsworn falsification to authorities. Adam Gordon ~ Executor of Estate of Florence J. Gordon DATED: ~ 11" J00 -........-.............. This is to certify that the information here given is correctly copied from an original certificate of death d~ly filed with.me as Local Registrar. The original certificatr '. 'HI be forwarded to the State Vital Recor Jffice for permanent filing. .. WARNING: It is illegal to duplicate this copy by photostat or photograph. Fee for this certificate, $6.00 J.lhVlnH:" ~~.~..~ . Local R gistrar ", '.;.;... ~..~ . ).'b.~e8Aj- :..: ;~:: :' Hl05 14J Rei, 2181 COMMONWEALTH OF PENNSYLVANIA' DEPARTMENT OF HEALTH' VITAL RECORDS CERTIFICATE OF DEATH ilAlE flll.....MlliIl SOCIAl. SECUHl TY NUMBER 3.05'Z -U:> - J 71 8- DATE OF DEATH (_. O;,Y. v.." - Z3 -oS- TYprll'RlIfT IN I'EICMIINfllT lILAClC1NK . z ... Q ... c.) ... Q ~ ~ z .. ..._~ :=,..,D RACE . Arnone"" _./llaQ.. Whole. ., (S~I .I- 10 WhIle SURVIVING :.POUSE ,.,....., eo.......... MIl.) ...~ 1:A.,~c" 17'b:J-~- ~ III :J r? ;J M. ~ w............. b ...1........'11"'..- ! . _ f...... UNDeRLYING . . CAU'f(IlIw_...~""" c. - . "'_._M. '-'8""-' LAST II WAS AN AUIOl'SY WERE AUIOl'SY flNOlNGS MANHE/Hlf?EATtl PfllfORMEll'I AVAIlMLE ""10/\ TO C~ETlOH OF CAUSE ""WI'" Of Dl:A 1 H1 Act.'''~ 0 v.. 0 l"'~ Suiod. 0 A OftSE 'HQ; I 0.0.11: Of INJUIlY tMunu.. 0." V..4) lIME OF INJURY INJURY 1.1 WORK1 OESC/USE /lOW INJURY OCCUHR~D P-.M.SW\Q hIVU~U"..liol1 ewld not b.. dbl.,'min"d o o 30.. JOb. M. o PLACE Of INJURY. A' hofJltI. '.,no. .,,""'. ~<to<y. oIf... ~. .~. CS~i.tII'J 30.. Y~. 0 NQ 0 ll<Jnoldd~ 21. ~c'~~:. " .~ tJ(J 'J REGISTER OF WILLS CUMBERLAND County, Pennsylvania CERTIFICATE OF GRANT OF LETTERS No. 2005-00916 FA No. 21-05-0916 Es ta te Of: FLORENCE J GORDON (First, Middle, Last) Late Of: SIL VER SPRING TOWNSHIP CUMBERLAND COUNTY Deceased Social Securi ty No: 052-26-1718 WHEREAS, on the 17th day of October 2005 an instrument dated May 18th 2005 was admitted to probate as the last will of FLORENCE J GORDON .. ;,.' (First, Middle, Lllst) la te of SIL VER SPRING TO WNSHIP, CUMBERLAND County, who died on the 23rd day of July 2005 and, WHEREAS; a true copy of the will as probated is annexed hereto. THEREFORE, I, GLENDA FARNER STRASBAUGH , Register of Wills in and I for CUMBERLAND County, in the Commonwealth of Pennsylvania, hereby certify that I have this day granted Letters TESTAMENTARY to: ADAM M GORDON who has duly qualified as EXECUTORfRIX) and has agreed to administer the estate according to law, all of which fully appears of record in my office at CUMBERLAND COUNTY COURT HOUSE, CARLISLE, PENNSYL VANIA. IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the seal of my office on the 17th day of October 2005. ,)d~enr&..~.Hl Q4 \~(]f;)kaAAuhd Register of I S I ~ %Oj~ eputy **NOTE** ALL NAMES ABOVE APPEAR (FIRST, MIDDLE, LAST) LAST~LLANDTESTAMENT OF FLORENCE J. GORDON ~(Q)fPV I, Florence J. Gordon, of 111 Maple Drive, Mechanicsburg, Cumberland County, Pennsylvania, make this my will. I revoke any other wills or codicils to wills made by me. ARTICLE I. DISTRIBUTION OF MY ESTATE A. I give my personal property, including my jewelry and all personal effects that I may own at the time of my death to my son, Adam Gordon. B. If my son Adam predeceases me, I leave my personal property, including my jewelry and personal effects that I may own at the time of my death, to my daughter-in-law, Bonnie Kimble-Gordon. C. I leave my shares of the Mandon Partnership to my son, Adam Gordon. If my son, Adam Gordon predeceases me, then I leave my shares of Man don Partnership to my daughter-in-law, Bonnie Kimble-Gordon. D. Whenever property is to be distributed to the descendants of a person (the "ancestor"), such property shall be divided into equal shares, one share for each then living descendant in the first generation below the ancestor in which at least one descendant is living, and one share for each deceased descendant in such generation who has a descendant then living. Each share created for a living descendant shall be distributed to such descendant. Each share created for a deceased descendant shall be divided and distributed according to the directions in the two preceding 1 ,.' ~. . "",..,. >.' " f. sentences until no property remains undistributed. E. Any beneficiary or the legal representative of any deceased beneficiary shall have the right, within the time prescribed by law, to disclaim any benefit or power under my will and the interest so disclaimed shall be distributed as if such beneficiary predeceased me. F. Gifts of specific items of property mentioned in this will or any separate writing that is binding upon my Executor shall fail to the extent that I, or any duly authorized agent of mine, dispose of such property prior to my death. My Executor shall not substitute cash or any other assets for any such property. G. I give my residuary estate to my son, Adam Gordon. H. Ifmy son Adam Gordon predecease me, I give my residuary estate to my daughter-in- law, Bonnie Kimble-Gordon. ARTICLE II. PROVISIONS FOR INTERESTS VESTING IN BENEFICIARIES UNDERAGE TWENTY-FIVE Notwithstanding the foregoing provisions, whenever any interest in my estate vests absolutely in a beneficiary under age twenty-five, my Trustee may retain the interest upon a separate trust and pay to the beneficiary as much of the net income or principal as my Trustee may deem appropriate to provide for the beneficiary's support, other needs, or education until the beneficiary reaches age twenty-five, when the interest shall be paid outright to the beneficiary. If the beneficiary dies before reaching that age, the interest shall constitute a part of the beneficiary's estate. 2 ARTICLE III. PAYMENT OF EXPENSES AND OTHER CHARGES I direct my Executor to pay my funeral and burial expenses (including the cost of a monument or marker over my grave). The estate, inheritance and similar taxes assessable on my death (including taxes on assets not passing under this will) shall also be paid as a cost of administering my estate and my Executor shall not request any beneficiary to pay any part of such tax. ARTICLE I V. APPOINTMENT OF FIDUCIARIES AND POWERS A. I name my son, Adam M. Gordon, to be my Executor(hereinafter "Executor" and "Trustee"). Should he fail or cease to act, I name my daughter-in-law Bonnie Kimble-Gordon, to be my Executrix. If administration of my estate or trust should be necessary in any jurisdiction where my Executor or my Trustee is unable to qualify, [or if my Executor or my Trustee deems it necessary for any other reason,] I give to my Executor and my Trustee the power to designate any individual or corporation with trust powers to serve with my Executor or my Trustee or in my Executor's or my Trustee's stead. I request that no security be required of any Executor or Trustee, including an Executor or Trustee named pursuant to the preceding sentence. References in my will to my "Executor" and my "Trustee" are to the one or ones acting at the time, except where otherwise specifically provided. B. Any corporate Executor or Trustee shall receive for its services the compensation for which it is willing to undertake similar services for others at the time such services are rendered, as evidenced by its published fee schedule in effect from time to time, unless it is willing to agree upon a fee that is less than its customary fee. [Any individual who serves as Executor or Trustee shall be 3 - '". ,-"',J-<. . ~'.' ~"."'"''''<''''' '~~l ."~j~J'. .-: . :. '. "i .:i~' ..~ ,~,.,.-",,-,( entitled to receive reasonable compensation for his or her services and, whether or not such individual receives compensation, shall be entitled to be reimbursed for expenses incurred for such services. C. I grant my Executor and my Trustee the powers set forth in 20 Pa.C.S. ~~ 3311-3332 and 20 Pa.C.S. ~9 7131-7143 respectively. In addition, my Trustee may merge any trust under this will with any trust having the same trustee and substantially the same dispositive provisions. If at any time after my death the size of any trust under this will is so small that, in the opinion of my Trustee, the trust is uneconomical to administer, my Trustee may terminate the trust and distribute the assets to the person or persons authorized to receive the trust income in such shares as my Trustee may deem appropriate. No Trustee who is also an income beneficiary of the trust at issue shall exercise any discretion granted in the preceding sentence. My Executor and my Trustee may distribute tangible personal property passing to a minor to any adult person with whom the minor resides, and that person's receipt shall be a sufficient voucher in the accounts of my Executor and my Trustee. ARTICLE V. MISCELLANEOUS PROVISIONS If any beneficiary in any manner, directly or indirectly, contests this will or any of its provisions, any interest in my estate given to the beneficiary is revoked and shall be disposed of in the same manner as if the beneficiary had predeceased me without leaving surviving issue. THIS SPACE LEFT BLANK INTENTIONALLY 4 ARTICLE VI. FINAL DISPOSITION I desire to have a modest Jewish burial, and direct the payment of my final expenses to come from my estate, at my Executor's final discretion. Executed this / y;tiaayof 1YJ~ , 2005. ~if~ Florence J. Gordo . (SEAL) Signed, sealed, published, and declared for and as her last will and testament by the testatrix. in our presence, we all being present at the same time; and we, in her presence and at her request and in the presence of each other, have subscribed our names as witnesses whereof, all on the date last above written. ( -M&l~.~~ fh~~ OF )1'1 ~W- :X" '8~~ cPA ./ ) '1 DO? OF/I/ >%fit aAu l!/Pk/~v"i#c-" . / ' 0 /'7dJu 5 COMMONWEALTH OF PENNSYLVANIA DAUPHIN COUNTY, to wit: Before me, the undersigned authority, on this date personally appeared Florence J. Gordon and ~tvJt a. YrJa.b;~ ,and ~ ~ known to rne to be the testatrix and witnesses, respectively, whose names are signed to the foregoing instrument and, all of these persons being by me first duly sworn, Florence J. Gordon, the testatrix, declared to me and to the witnesses in my presence that said instrument is her last will and testament and that she had willingly signed and executed it in the presence of said witnesses as her free and voluntary act for the purposes therein expressed, that said witnesses stated before me that the foregoing will was executed and acknowledged by the testatrix as her last will and testament in the presence of said witnesses who in her presence and at her request and in the presence of each other did subscribe their names thereto as attesting witnesses on the day of the date of said will and that the testatrix, at the time of the execution of said will, was over the age of eighteen years and of sound and disposing mind and memory. Sworn and acknowledged before me by Florence '!4 Mi- 11. ~ ~I..- , witness, and this J'!,#i-dayof ~ Cuf ,200 . , witness, Flol~on } ~ A-~ Notarla ' Frances A. Aumiller, Nt! C Df Harrisburg. O~U My ~mISSior> EXC,II';;' 81.18, M8nDJr,PennsylvaOlaAssoclationof~~ My commission expires: 6 ~j . FROM :~ FAX NO. Jan. 14 2004 03:24PM P2 I~O n ~ .( RESTATED AGREEMENT OF GENERAL PARTNERSHIP OF MANnON COMPANY November 1993 "') II ~ROM )I .,! Article I II III IV v VI VII FAX NO. Jan. 14 2004 03:24PM P3 . . TABLE OF CONT~NTS FORMATION OF PARTNERSHIP.................... 'NAME, PURPQSE, PLACE OF BUSINESS AND TERM or PARTNERSHIP...................... , DEFINITIONS. . . ,; ~ ~ . . . . . . .' . . . . . . . . . . . . .. . . . . . . . CAPITAL CONTRIBUTIONS, ACCOUNTS AND WITHDRA,W~S. . . . . . . . . . ... . . . . . . . . . . . · . ~ . . . " . · · DUTIES AND POWERS OF. PARTNERS; PARTNERSHIP EXPENSES. ................ ....... DISTRIBUTIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PROFITS AND LOSSES...................;...... VIII .' DISSOLUTION AND WINDING UP OF THE IX x XI ~ 1 2 3 8 9 15 17 PARTNERSHIP. . . . . . . . . . . . . . . . , . . . . . . . . . , . '. . . . . 20 WITHDRAWAL AND TRANSFER BY PARTNERS......... RECORDS AND ACCOUNTING...................... MI SCELLANEOUS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 23 25 FROM : .f~ -.....- ,. FAX NO. Jan. 14 2004 03:25PM P4 RESTATED AGREEMENT OF GENERAL PARTNERSHIP OF MANDON COMPANY THIS IS AN AGREEMENT OF GENERAL.PARTNERSHIP made as of October , 1993, by and among each of the persons executing this Agreement as a Partner (hereinafter collectively referred to as the .Partners"). AR~IGLE I FORMATIQN OF PARTNERSHIP 1.1 Form~tion. The Partners formed a general partnership pursuant to the laws of the State of New York on June 20, 1961. , , 1.2 Certificate. The Partners executed a Business Certificate for Partners in accordance with the provisions of the Partnership Law of the State of New York and filed the Certificate with the Clerk of Onondaga County on June 211 1961. An Amended Business Certificate 1 changing the business address of the Partnership, was filed with the Clerk of Onondaga County on April 16, 1973. ~ '"1 I FROM :. FAX NO. Jan. 14 2004 03:25PM P5 .' ART..ICLE I I NAME, PURPOSE" PLACE OF BUSINESS AND TERM OF PARTNERSHIP 2.1 ~. The name of the partnership is Mandon Company (hereinafte~ referred to as "the Partnership-). 2.2 PurDose. ;The purpose of the Partnership is to engage in the purchase, s~le, development, rental, repair, lease, ownership, mort9ag~ng, of the Property, and to engage in any other activities or transactions as may be permitted by law, and which are necessary or desirable to accQmplish,the foregoing purpose. 2.3 Place ~f Business. The principal place of business of the Partnership is 6790 Schuyler Road, East Syracuse, New York 13057, or any other location as may hereafter be determined by the Partners. 2.4 ~. The term of the Partnership commenced as of the date of the filing of the Certificate under the laws of the State'of New York and shall continue until June 20, 2020 unless sooner dissolved or terminated as provided in paragraph 8.1 of this Agreement. > -2- FROM : FAX NO. Jan. 14 2004 03:26PM P6 " " . " ARTICLE III DEFINITIONS 3.1 Defini~ions. As used herein the following terms shall have the following meanings. (~) "Accountants" shall ~ean such firm of certified public accountants that may be engaged for the Partnership by the Partners. ,(b) "Affiliat~d ..F~r;:is:m" shall mean, when used with reference to a specified' Pers'on, '( i) any Person that di rectly or indirectly through one or more intermediaries controls or is controlled by or is under common control with the specified Person, (ii) any Person that is an officer, partner or trustee of, or serves in a similar capacity with respect to, the specified Person or of which the specified Person is an office~, partner or trustee, or with respect to which the specified Person serves in a similar capacity, (iii) any person that, directly or indirectly, is the the beneficial owner of ten percent or more of any class of equity securities of, or otherwise has a substantial beneficial interest in, the specified Person or of which the specified Person is ditectly or indirectly the o~ner of ten percent or more of any class of equity securities or in which the specified Person has a substantial beneficial interest and (iv) any ancestor, descendant, brother, sister or spouse of the specified Person. (c) "Aareement" or "Partnership Aoreement.. shall mean this Agreement, as originally executed and as amended from time to time, as the context requires. Words such as "herein," "hereinafter," "hereof," "hereto," "hereby," and "hereunder," when used with refe+ence to this Agreement refer to this Agreement as a >'whole, unle,ss the context otherwise requires. > , , (d) "Caoital Account" shall mean the account established and maintained for each Partner on the books of the Partnership which account shall be credited with or increased by (i),the amount of money contributed by him to the Partner- ship, (ii) the fair market value of property contributed by him to the Partnership (net of liabilities securing such contributed property that the Partnership is considered to assume or take subject to under Section 752 of the Code), and (iii) allocations to him of Partnership income and gain (or items thereOf), including income and gain exempt from tax and income and gain described in Treasury Regulation Section 1.104-1{b)(2)(iv)(g) (concerning allocations of income -3- FROM : FAX NO. Jan. 14 2004 03:26PM P7 I, . and loss reflected on the books of account of the Partnership and the capital accounts of the Partners under Treasury Regulation Section 1.704-1(b)(2)(iv)(f) to reflect fair market value). but excluding income and gain described in Treasury Regu'1ation Section 1.704-1(b)~4)(i) (concerning allocations of Partnership taxable income and loss with respect to (1) prop- erty c6ntributed to the Partnership and (2) property which has been revalued on the books of the partnership and the capital accounts of the Partners under Treasury Regulation Sec- tion 1.704~1(b}(2}(iv)(f) to reflect fair market value); and is debited with or decreased by (i) the amount of money distributed to him by the Partnership, (ii) the fair market value of property distributed to him (net of liabilities securing such distributed property that such Partner is considered to assume or take subject to under Section 752 of the Code), (iii) allocations to him of expenditures of the Partnership not deductible in computing the Partnership's taxable income and not properly chargeable to a capital account. as described in Section 705(a)(2)(B) of the Code, and (iv) allocations of Partnership loss and deduction (or items thereof), including loss and deduction described in Treasury Regulation Section 1.704-1(b)(2)(iv)(g) (concerning allocations of income and loss reflected on the books of account of the Pa!tn~,rship with respect to (1) property contributed to the Partnership and (2) property which has been revalued on the books of the Partnership and the capital accounts of the Partners under Treasury Regulation Section 1.704-1(b)(2)(iv)(f) to reflect fair market value), but excluding items described in (iii) above and loss or deduction described in Treasury Regulation Section 1.704-1(b)(4)(i) or 1.704-l(b)(4)(iii) (concerning, among other items, allocations of Partnership taxable income and loss with respect to (1) property contributed to the Partnership and (2) property which has been revalued on the books of the Partnership and the capital accounts of the Partners under Treasury Regulation Section 1.704-1 (b)(2)(iv)(f) to reflect fair market value), This provision and the other provisions of this Agreement relating to the maintenance of Capital Accounts are intended to comply with Treasury Regulation Section 1.704-l(b) and shall be interpreted and applied in a manner consistent with such Regulations. Therefore, notwithstanding anything contained herein to the contrary and in further defining the method in which the Capital Accounts of the Partners shall be maintained by the Partnership as described herein, the Capital Accounts of the Partners shall, in all respects, be maintained in accordance with Treasury Regulation Section 1.704-1(b)(2)(iv), and any optional charges, credits or adjustments to such Capital Accounts of the Partners which are provided for in such~ -4- ,F="ROM :. '. FAX NO. Jan. 14 2004 03:27PM P8 Regulations, and are otherwise proper under state law and this Agreement, and which are ~ade br the Partnership, ~~all be made with~ny and all correlat~ve ?dJustments to the Caplt~l Accounts of the Partners requlred by Treasury Regulat10n section 1.704-1(b)(2)(iv). In conformity with the foregoing, in the event that the Partners shall determine that it is prudent to modify the manner in which the~Capital ~ccounts, or any debits or credits thereto, are computQd in order to comply with, such Regulations, the Partners may make such modification, provided that''it is hot likely to have a material effect on the amount distributed to any Partners uPO~ the dissolution of the partnership_ Furthermore, the Partners shall adjust the amounts debited or credited to ~he Capital Accounts of the Partners with respect to (a) any property contributed to the Partnership or distributed to the Partners, and (b) any liabilities secured by such contributed or distributed property or that are assumed by the Partnership or any Partner, in the event the Partners shall determine such adjustments are necessary or appropriate pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv). The Partners shall make any appropriate modification in the event unanticipated events might otherwise cause this Agreement not tp comply with Treasury Regula~ion Section 1.704-1(b). In addition, upon the transfer of all, or a part of, a Partner's interest in the Partn~r5hip, the Capital Account of the transferor or that is attributable to the transferred interest will carryover to the transferee Partner, giving effect to any and all charges, credits or adjustments to the Capital Accounts of the Partners .provided for in Treasury Regulation Section 1.704-1(b)(2)(iv}, including any such charges, credits or adjustments resulting from any elections under Section 754 of the Code or from a termination of the Partnership under Section 708(b)(1)(B). (e) "Certificate" shall mean the Certificate of Partnership of the Partnership, duly filed and amenged, as herein required, in accordance wi~h (and in all respects sufficient in form and substance under) the laws of the State of New York. (f) "Code" shall mean the Internal Revenue Code of 1986, as amended, or corresponding provisions of future laws. (g) "Interest'. shall mean the ownerShip interest of a Partner in the Partnership, including the rights and obligations'of such Partner under this Agreement. .,. -5- FROM ,: FAX NO. Jan. 14 2004 03:27PM P9 . . (h) "Net Cash Flow" shall mean for each Fiscal Year all cash funds of the Partnership received from operations, . less the sum of.(i) current charges and expenses, (ii) debt service payments with respect to any partnership loan, (iii) expenditures for acquisition Df Partnership property and for capital improvements or replacements not financed through capi tal contributions, bor.rowing, or reserves previous ly set aside by the Partnership for those purposes, and (iv) payments to reserves for working capital, contingencies, capital improvements, and replacements paid by the partnership in that year. Net Cash Flow shall not incluae Net Cash Proceeds. (i) "Net Cash ~r9ceeds" shall mean the cash proceeds to the Partnership resulting from any loan secured by the. Property or from the sale, eXChange, condemnation or similar eminent domain taking, casualty, or other disposition of all or substantially all of the Partnership's Property, or from the sale of interests in the Partnership's Property or any other similar items which in accordance with generally accepted accounting principles are attributable to capital, after payment of or provision for debts and obligations, repairs and replacements, deduction of all expenses incurred in connection with the cash proceeds and satisfaction of liens pertaining thereto. (j) "Ncnrecours@ Deductions" has the meaning set forth in Section 1.704-2(c) of the Treasury Regulations. (k) "Partners" shall refer, collectively, only to those Persons admitted to the Partnership as a Partner. Reference to a "Partner" shall be to any of the Partners. (1) .Partnership" shall mean Mandon Company, the general partnership subject to this Agreement. (m) .Partnershio Lawd shall mean the New York State Partnership Law. (n) "Partnershio Percentaae" shall mean the percentage set forth next to the Partner's name and address at Exhibit A. (0) "Person" or "person" shall mean any individual, partnership, corporation, trust or other entity. (p) "ProDerty" shall mean the real property described at Exhibit B hereto, and any other property, real, personal, tangible, or intangible, which the Partnership may acquire by any lawful means. ,. -6- FROM .: FAX NO. Jan. 14 2004 03:28PM P10 -. (q) RStat~" shall mean the State of New York. (r) "Substitut:ed parl:ner" shall mean any Person admitt~d to the Partnership as a Partner 'pursuant to Article X 'hereof. (s) "TrQa~urv ReaulatiQns" shall mean the IncQrne Tax Regulatiods (final, ,temporary and, as.applicable, proposed) promulgated.,under the Code. References, to specific sections of the Treasury Regulaeions shall be to such sections as amended, supplemented or superseded by Treasury Regulations currently in effect. (t) "Withdrawa~" shall mean any of ~he following: (i) The 'voluntary withdrawal of. a Partner from the P~rtnership, by tender of his written resignation to the Partnership, which withdrawal must be consented to by a majority in interest of the remaining Partners. (ii) The sale, assignment or encumbrance by a Partner of his Partnership interest without the consent of a majority in interest of the remaining Partners (subject to, the exclusions of paragraph 9.2. (iii) The transfer, other than by reason of a Partner's death, of his Interest by operation of law to any person other than the Partnership, such as, but not limited to, a Partner's trustee in bankruptcy, a purchaser at any creditors. or judicial sale, or the guardian or conservator of an incompetent Partner. ':' -7- . FROM :. ~__...J_. __ -.. -.... .-. FAX NO. Jan. 14 2004 03:28PM Pi1 AR-r'ICLE IV Cl\PITAL CONTRIBUTIONS. ACCOUNTS AND WITHDRAWALS 4.1 Canital Contribu~ions. Subject to the terms and conditions of this Aqreement, ~he Partners have contributed to the capital o~ the partnership the cash and property set forth at Exhibit C to this Agreement. . 4.2 ~o Int.erest on Caoitpl Cont~ihut;oOs. No interest shall be paid by the Partnership on any contribution to Partnership capital. 4~3 Caoital Accounts. A Capital Account shall be maintained for each Partner. A Partner shall not be entitled to withdraw any part of his Capital Account or to receive any distribution from the Partnership except as provided in this Agreement. ., -8- rROM '. FAX NO. Jan. 14 2~04 03:29PM P12 ~~1~~L~ V DUTIES AND POWERS OF PARTNERS; PARTNXRSHIP EXPE~S~S 5.1 Deci&ions bY Vote Accordina to Partner's p~T~ner~h;~ ~p.rc~nhaae. All decisions to be made by the Partners shall be made by the casting of votes at a meeting of such Partners. Each Partner authori~ed to vote shall be entitled to cast one vote for every percentage point (or fractional part thereof) in such Partner's Partnership Percentage in effect as of the date such vote is taken. The affirmative vote of. Partners owning greater than 50 percent of the Partnership Percentages entitled to vote shall be required to approve any mat~er presented for decision, except where this Agreement shall expressly require a greater proportion of affirmative votes, in which case such greater proportion of affirmative votes of all the Partners shall be necessary for approval. The presence of Partners (by person or Proxy) posse~~ing at least seventy-five percent (75%) of the total Partnership Percentages held by all of the Partners shall be ~equired to constitute a quorum at any meeting of the Partners where a vote is to be taken, except in any case where this Agreement shall expressly require the unanimous agreement of all Partners, in ~hich case the presence of all Partners (in person or by written delegation of authority to vote) shall be required for a quorum. 5.2 Proxv. Any Partner may authorize, by execution of a Proxy, any other Partner to vote at a meeting of the Partnership on behalf of such authori~ing Partner by Proxy which shall be duly signed by the authorizing Partner containing such restrictions and instruction regarding such authority to vote (and .the period. of time for which such Proxy shall be valid but if no period is specified such Proxy shall be valid for one year after the date of the Proxy., or if it be undated then one year after the date of receipt by the Partnership) as the authori~ing Partner shall determine, provided however that such Proxy shall not be effective unless and until an executed copy thereof be duly filed with the . Partnership. If any such Proxy is so given, the authorizing Partner shall be deemed to be present at any meeting of Partners if the Partner so authorized to vote is personally present at such meeting. ., -9- FROM FAX NO. Jan. 14 2004 03:29PM P13 5.3 Annual Meetina, There shall be held an annual meeting of all Partners at the office "of the Partnership, or such other place as designated in the Notice of Meeting, on the irst Tttursda in Jul at 10:00 o'clock in the forenoon of each .~r~l Yea~ or at such other ~me or ate in eaoh year as the Partnership shall designate and notify the Partners. No later than ten days before each annual meeting the Partnership .shall furnish to each Partner an agenda setting forth all matters of business which are required by this agreement to be, and such other matters as the Partnership intends to be, brought before such annual meeting. Any Partner wishing to discuss. other items shall provide Notice to the other .pa~tners at least t~ree days prior to such annual meeting. 5.4 Soecial Meetin9. Any Partner or Partners may call a special meeting of Partners at the office of the Partnership, or such other place as designated in the Notice of Meeting, on at least three days' prior Notice of the date, time and purpose thereof, to consider any business deemed pertinent to the Partnership. Any meeting of the Partners shall be held at the principal office of the Partnership, unless otherwise designated in the Notice of Meeting. 5.5 Res~onsibilities for ManaaemeQt= ComD~n5ation. The Partners shall share equally the responsibilities for the management of the Partnership business and shall receive no compensation therefore except their share of the allocations or distributions expressly provided for in this Agreement, provided, however, that the Partnership may authorize the payment of salaries at professional fees to one or more Partners, which salaries and fees shall constitute expenses of the Partnership. 5.7 Reliance. Any person dealing with the Partnership or the Partners may rely upon a certificate signed by any two Partners as to: fa) The identity of any Partner, (b) The existence or non-existence of any fact or facts which constitute conditions precedent to acts by the Partnership or in any other manner germane to the affairs of the Partnership, (c) The Persons who are authorized ~o execut~' and deliver any instrument or document of the Partnership, or ., -10- . FROM FAX NO. Jan. 14 2004 03:30PM P14 '. (d) Any act or failure to act by the Partnership or as to any other matter whatsoever involving the Partnership or any Partner. The signature of two Partners on behalf of the Partnership on any document or instrument in connection with any transaction herein authorized to be engaged in by the Partnership shall be sufficient and binding upon the Partnership .as to third parties dealing with the Partnership. S.8 AarRQrnQnts with Partners. The Partnership may enter into such agreements, contracts or the like, in addition to those contemplated hereby, with any Partner in an independent capacity, as distinguished from his" capacity as a Partner, or an Affiliated Person to a Partner, to undertake and carry out the business of the Partnership as if such partner were an independent contractor, including the furniShing or leasing of goods, the furnishing of services and supplies and the loaning of money. Any such agreemants, contracts and arrangements not prohibited by the preceding sentence shall. be subject to the conditions specified in paragraph 5,.9. 5.9 ComOADsatiQO. The Partnership may pay reasonable compensation for and on account of any services not prohibited by paragraph 5.10 (including the payment of " reasonable compensation to any Partner or an Affiliated Person'to a Partner for services rendered) provided that: (a) Any such agreements, contracts or arrangements shall be fully and promptly disclosed to all Partners and shall be embodied in a written contract which .precisely describes the subject matter thereof and all compensation to be paid therefor; (b) The compensation, price, fee, interest, charge or. other consideration therefor shall be comparable and compe~iti~e with that of any other Person rendering comparable services or sellin9 or leasing comparable goods or supplies which would reasonably be made available to the Partnership and shall be on competitive terms, and shall be reasonable and paid only for goods and services reasonable fot, and actually furnished to, the Partnership; (c) No rebates or "give-ups" may be received by any Partner or any Affiliated Person of any Partner, nor may any Partner or any Affiliated Person of any Partner participate in any reciprocal business arrangements whiCh would have the effect of circumventing any of the provisions of this paragraph; and ~ -11- .FROM '. FAX NO. Jan. 14 2004 03:30PM PiS (d) Neither any Partner nor any Affiliated Person of any Partner shall receive any brokerage commissi.on (or any other form of compensation) from any Person in connection with the sal~ of P~rtnership assets except with the consent of the other Partners possessing greater than fifty percent of the Partnership Percentages of all Partners. , 5.10 Event of Conflict. In the case of a conflict between a Partner's fiduciary obligation to the Partnership, on the one hand, and his fiduciary or other obligations to other part:ne'rships or entities' or his own. self interest I on the other hand, the Partnership shall not enter into any transaction with any Partner which may'significantly benefit any Partner in his independent capacity unless. the transaction is entered into principally for the benefi~ of the Partnership. 5.11 Consent Reauired. Without the Consent of all the Partners, neither the Partnership nor any Partner shall have the authority to: (a) Do any act in contravention of this Agreements; (b) Do any act which would make it impossible to carry on'the ordinary business of the Partnership; (c) Confess a judgment against the Partnership; (d) Admit a Person as a Partner, except as provided in this Agreement; or (e) Terminate the Partnership for any reason other than those set forth in paragraph 8.1. 5.12 Separate ~c~ion. No Partner acting separately shall have the authority to, without the Consent of Partners possessing greater than fifty percent of the Partnership Percentages of all Partners: (a) Sellar otherwise dispose of all or substantially all of the assets of the Partnership to any Person, including any Partner or Affiliated Person of any Partner, or (b) Elect to dissolve the Partnership. The foregoing limitations on the au~hority of the Partnership and its Partners shall be binding only upon the Partners but shall in no way be construed as binding upon third parties or as limitations on the right of third parties to rely upon the acts or signatures of the Partnership or any Partner " thereof. -12- ..FROM.: FAX NO. Jan. 14 2004 03:31PM P16 5.13 ~n5urance. The partnership shall obtain and keep In force dhring the term hereof fire and extended coverage, worker's cbmpensation and public liability insurance in favor bf the Partnership with such insurers and in such amounts as the Partnership shall deem advisable, but in amounts not less (and with deductible amounts not greater) than those tustomarilY maintained with respect to properties and risks comparable to those of the Partnership. . 5.14 Tax Returns. The partnership shall prepare or bause to he prepared and shall file on or before the due date (or any e%tension thereof) any federal, state or local tax returns required to be filed by the Partnership. 5.15 A~craisal. The Partnership shall maintain in its records for at least five years any appraisal required by this- agreement to be obtained in connection with any transaction, which appraisal shall be available to any Partner and his duly authorized representative for their inspection and duplication at any and all reasonable times. 5.16 Fiduciarv Dutv. Each Partner shall be under a fiduciary duty to conduct the affairs of the Partnership in the best interests of the Partnership, including the safekeeping and use of all Partnership funds and assets and the use thereof for the benefit of the Partnership. Each Partner shall at all times act in good faith and exercise due diligence in all activities relating to the conduct of the business of the Partnership. 5.17' Other Business ventures. The Partners may engage in or possess interests in other business ventures of every kind and description for their own account including, without limitation, the ownership or management of real or personal property similar to the real or personal property to be owned by this partnership. Neither the Partnership nor any of the Partners shall have any right by virtue of this Agreement in and to such independent business venture or to the profits derived therefrom. 5.18 Good Faith Acts. No partner shall be liable, r~sponsible or accountable in damages or otherwise to any of the partners for any act or omission performed or omitted by such member in good faith on behalf of the Partnership and in a manner reasonably believed by him to be within the scope of the authority granted to him by this Agreement and in the best interests' of the Partnership, provided that such Partner was not guilty of neqligence, willful misconduct or any other breach of his fiduciary duty with respect to such acts or ~ -~3- ", FROM .: FAX NO. Jan. 14 2004 03:31PM Pi? omissions. Any loss or damage incurred by such Partner by teason of act or omission performed by him in good faith on behalf of the Partnership and in a manner reasonably believed by him to be within the scope of the authority granted to him by this Agreement and in the best interests of the PartnerShip (but not, in any event, any loss or damage incurred by such Partner by reason of negligence, willful misconduct or any breach of his fiduciary duty with respect to such acts or Omissions) shall be paid from Partnership assets to the extent ~vailable, but the other Partners shall not have any personal iiability to such Pa~tner under any circumstances on account of any 'such loss or damage incurred by such Partner or on account of the payment thereof. -14- tROM " FAX NO. Jan. 14 2004 03:32PM Pi8 ART!~~E VI DISTRIBUTIONS 6.1 Net Cash Flow and Net Cash Proceeds Other than in the EVAnt of DissOlution and Liauidation. Net Cash Flow and Net Cash proceeds other than in the event of dissolution and liquidation of the Partnership shall be distributed to each Partner accordinq to each Partner's Partnership Percentage. 6.2 ~t Cash Proceeds in the Event of Dissolution and Liauidation. Upon the dissolution of the Partnership and liquidation of its assets: (a) I.ax Consp-a~u:~nces tQ Dat~ of Dis~Ql\ltion. . The Capital Accounts of the Partners shall be adjusted to the date of dissolution to reflect income, gain, loss, or deduction accrued or incurred, as the case may be, from the date of the last accounting to the date of the dissolution. Any gain or loss on disposition of Property in the process of liquidation shall be charged or credited to the Partners' Capital Accounts in accordance with the ptovisions of paragraph 7.1. Any property distributed in kind in the liquidation shall be valued and treated as though the Property were sold and the cash proceeds where distributed. The difference between the value of property distributed in kind and its book value shall be treated as a gain or loss on sale of the Property and shall be credited to the Partners' Capital Accounts in accordance with the provisions of paragraph 7.1. (b) Distributions in Liquidation. Following the adjustment required by paragraph 6.2(a), the affairs of the Partnership shall be forthwith wound-up and the proceeds from the liquidation of the Property shall be distributed in the following priority: (i) First, to payor provide and reserve for all debts (known and contingent) of the partnership including any funds loaned or advanced to the Partnership by any of the Partners; (ii) The balance, if any, is to be distributed to each Partner in accordance with his positive Capital Account balance. In connection with any winding up and liqUidation, the Accountants shall compile a balance sheet of the Partnership as , -15- FROM ~ FAX NO. Jan. 14 2004 03:32PM P19 of the date of dissdlution, and such balance sheet shall be furnished promptly ~o all Partners. . (c) Distributions Accordina to positive Caoital Account Balan~es. Notwithstanding anything contained in this Agreement to ~he corltrary, upon liquidation of the Partnership (or any Partner's interest in the Partnership)" l~quidating distributions are require4 in all cases to be made in accordance with the positive Capital Account balances of the Partners, as' determined after taking into account all Capital Account adjustments ,for the Partnership taxable year during which such liquidat~on occurs (other than those made pursuant to 'this paragraph) by the end of such taxable year (or, if fater, within 90 days after the date of such liquidation) in strict compliance with Section 1.704-1(b)(2)(ii)(b)(2) of the Treasury Regulations. , I ~ -16- .,FROM " FAX NO. : Jan. 14 2004 03:33PM P20 . . ARTICLE VII. PROFITS AND LOSSES 7.1 Income. G&in. Los~es. and Deductions. (a) Gener.ally. The income, gain, losses, and deductions of the p'artnership shall be determined for each fiscal year in accordance with the accounting method followed by the Partnership for federal income tax purposes and otherwise in accordance with generally accepted accounting principles applied in a consistent manner. Income, gain; losses, and deductions shall be allocated to the Partners according to their varying interests in the Pa~tnership on a semi-monthly basis. For this purpose, the Partnership will utilize the "interim closing of the books" method and the books of the Partnership will be closed at the close of the 15th day of the month and at the close of the last day of the month: In- determining the varying interest of the Partners in the Partnership during the semi-monthly allocation period provided herein, Partners entering the Partnership during the first 15 days of the month shall be deemed to have entered into the . Partnership on the first day of the month and the Partners entering the Partnership after the 15th day of the month (but before the end of the month) will be deemed as entering the Partnership on the 16th day of the month. (b) Iransferor-Transferee Allocations. As between a Partner and his transferee, profits and losses for any month shall be apportioned to the person who is the holder of the Interest transferred (determined in accordance with hereof) on' the last day of the semi-monthly allocation period provided without regard to the results of the Partnership's operaticins during the period before and after such transfer. (c) Income. Gain. Lossp-s ~nd De(lJJ~ions. Income, gain, losses, and deductions of the Partnership will be allocated among the Partners according to each Partner's Partnership Percentage. 7.2 R@oulatorv Allocations. (a) Minimum Gain Chargeb~cks. The Partners shall make such allocations of i~ems of income and gain as are necessary to comply with the "minimum gain chargeback" pro~isions of Sections 1.704-2(f) and 1.704-2(i)(4) of the Treasury Regulations or any ~uccessor provisions thereto. .,. -17- I.FROM ". FAX NO. : Jan. 14 2004 03:33PM P21 (b) Parr.np-r Nonrecourse Deductions. The Partners . shall make such allocations of "partner nonrecourse deductions" of the Partnership as defined in Section 1.704-2(i>{2) of the Treasury Regulations or any successor provisions thereto, as are necessary to comply with Section 1.704-2 of the Treasury Regulations or any successor provisions thereto. (c) Curativ~ Allo~ations. The allocations set forth in paragraphs 7.2(a) and (b) hereof (the "Regulatory . Allocationsft) are intended to comply with certain requirements of Sections 1.704-1(b) and 1.704-2 of the Treasury Regulations (and any successor provisions thereto). Notwithstanding any other provision of this Article, the Regulatory Allocations . shall be taken into account in allocating other profits, losses and it~ms of income, gain, loss and deduction amortg the Partners' so that, to the extent possible, the net amount of such allocations of other profits, losses and other items and the Regulation Allocations to each Partner shall be" equal to the net amount that would have been allocated to each such Partner if the Regulatory Allocations had not been made. (d) ~xcess Nonrecourse Liabilities. Solely for purposes of determining a Partner's proportionate share of the '.excess nonrecourse liabili ties" .of the Partnership wi thin the. meaning of Treasury Regulation Section 1.752-3(a)(3), the Partners' interests in Partnership profits are the same as each Partner"s Partnership Percentage. (e) Contributed Property. (i) In accordance with Section. 704{c) and the Treasury Regulations thereunder, income, gain, loss, and deduction with respect to any property contributed to the capital of the Partnership shall, solely for tax purposes, be allocated among the Partners so as to take account of any ~ariation between the adjusted basis of such property to the Partnership for Federal income tax purposes and its fair market value at the time of contribution. (ii) In the event any Partnership property has' been revalued on the books of the Partnership and the capital accounts of the Partners under Treasury Regulation Section 1.704-1(b)(2)(iv)(f), subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for Federal income tax purposes and its fair market value in the same manner as under Code Section 704(c) and the Treasury Regulations thereunder. ~ -18- FROM : F~X NO. Jan. 14 2004 03:34PM P22 . . (iii) Any elections or other decisions relating to allocations under this pa~agraph 7.2(e) shall be made by the Partners in any mannet that reasonably reflects the purpose and intention of this Agreement. 7.3 IncomA Tax Elections. (a) Section 743 ~~p Section 734 Adiustments. For federal,' state and local income tax purposes, the income, gains, losses and deductions of the Partnership shall, for each ta~able period, be allocated among the Partners in accordance with their Partnership Percentages, provided, that (i) any adjustments made pursuant to Section 743 or 734 of the Code shall be taken into account and (ii) items of income, gain, loss and deduction with respect to Partnership Property reflected in the Partners' Capital Accounts and on the books of the Partnership at a value that differs from the Partnership's' adjusted tax basis in such property shall be allocated, solely for tax purposes, among the Partners so as to take account of that difference in value in accordance with Code Section'704(c) and Treasury Regulations Sections 1~704-1(b}(2)(iv)(f) and 1.704-1(b)(4)(i). (b) Section 754 Election. Upon the written request of any'partner that an election provided for in Section 754 of the Code be made, notice shall promptly be given to all the other Partners of such request. Unless written objection to the making of such election is received within 30 days of such notice, the Partnership shall. if then permitted by applicable law, make such election. All costs and expenses incurred by the Partnership in connection with the making of such an election shall be borne by the partner(s) requesting the same. 7.4 Caoital Account M~intenance. Notwithstanding anything contained in this Agreement to the contrary, the Capital Accounts of the Partners shall, in all respects, be maintained in accordance with Treasury Regulation . Section 1.704-1(b)(2)(iv), and any optional charges, credits or adjustments to such Capital Accounts of the Partners which are provided for in such Regulations, and are otherwise proper under state law and this A9reement, and which are made by the Partnership shall be made with any and all correlative adjustments to the Capital Accounts of the Partners required by Treasury Regulation Section 1.704-1(b){2)(iv). This provision and the other provisions of this Agreement relating to the maintenance of Capital Accounts are intended to comply with Treasury Regulation Section 1.704-1(b) and shall be interpreted and appli~d in a manner consistent with such Regulations. , -19- FROM : FAX NO. : Jan. 14 2004 03:35PM P23 " . . ARTTCLE VIII DISSOLUTION AND WINDING UP OF THE PARTNERSHIP 8.1 DissolutiQ~ and Windinq UP. (~) ni~~~l'ltian. .The Partnership shall be dissolv~d upon the happening of anY,of the following events: (i) An election to dissolve the partnership made in writing unanimously by the Partners; " (1i). Th~~~~~hJ~~~9val, Withdrawal, assianment for the benef1t'of crea1cors, bankruptcy, or legal Tncapac1 ty at a J:',~.~.t)i.~.r.L___.._.__.__. ----. .--------- - - .--...-.. .......... -- ..~ {iii} The sale, exchange, or other disposition of all or substantially all of the Property; (iv) The expiration of the term provided for in patagraph 2.4; or (v) The happening of an event that, under New York State law, causes the dissolution of a' partnership. (b) winding-Up. Upon the dissolution of the Partnership, unless the Partnership is to be continued with the consent of a majority in interest of the then existing Partners, the Partners shall: (i) Cause the cancellation of the Certificate; (ii) Subject to the provisions of paragraph 8.1(c), liquidate the partn~rship's assets: and (iii) Apply and distribute the proceeds of such liquidation in accordance with paragraph 6.2. (c) Avoidqn9~ of Un~ue Loss. Notwithstanding the provisions of paragraph 8(b), if, on dissolution of the Partnership, the remaining Partners shall determine that an immediate.sale of part or all of the Partnership's assets would cause undue loss to the Partners, the remaining Partners may, in order to avoid such 1~5ses, either: (i) Defer the liquidation of, and withhold from ., distribution for a reasonable time, any assets of the '1l -20- , FROM.: , '. : .. FAX NO. Jan. 14 2004 03:35PM P24 .' Partnership except those necessary to satisfy debts and liabilities. of the Partnership (other than those to remain- ing Partners) and the Partnership's obligation to a Partner due upon his death, total and permanent disability, or withdrawal from the Partnership; or (ii) ;Distribute to the Partners, in lieu of cash, undivided interests in any Partnership assets as tenants in common"and liqdidate only such assets as are.necessary in order to pay the debts and liabilities of the Partnership and the obligations of the Partnership due to a terminated Partner. , , , -21- . rROM FAX NO. Jan. 14 2004 03:35PM P25 ARTICLE IX WJTHDRAWAL AND TRANSFER BY PARTNERS 9.1 Restriction on Assianment or Transfer. . Except as otherwise provided in this paragraph, no Partner may sell, assign or encumber his Partnership interest or voluntarily withdraw from the Partnership unless (~the consent of a majority in interest of the Partners, eXCTualng the interest of ~the w~tharaw1ng partner, ~s ootalned and (b) such sale, assign- ment, encumbrance or withdrawal is not prohibited by law. Any assignment by a Partner without such consent shall be deem~d to be a withdrawal from the Partnership in contravention of this Agreement, for which damages shall be recoverable and liquidated, which damages shall be a charge upon .and, at the option of the Partnership, shall be.satisfied out of any amounts otherwise payable to the former Partner or to anyone claiming under him. Any attachment, in whatever form, by creditors of a Partner of his Partnership interest shall, if such attachment continues for more than three months, be deemed to be ~n assignment for the purpose of this Agreement. 9.2 ~ssianment as Securitv. An assignment by a Partner of his Partnership interest as security for an obligation shall not be deemed to be a withdrawal from the partnership under paragraph 9.1 if, put onlv if: (a) the secured party is a financial institution approved by the other Partners before the date o,! such assignment and (b) the secured party is obligated to offer to assign. the Partner's obligation, after default and before enforcing its security interest, to the other Partners at a price equal to the lesser of the amount in default or the assigning Partner's capital account. 9.3 Admission of Substi~d Partner. No assignee of a Partner shall become a substituted Partner in the place of his assignor without the consent of all of the remaining Partners. The Partnership shall have nO obligation to recognize, or furnish information or make distribution to, any assignee of a Partner who does not become a substituted Partner, and such assignee's right shall be ~nly against his assignor. -22- FROM: FAX NO. Jan. 14 2004 03:36PM P26 ,. ARTICLE X ~~CORDS AND ACCOUNTING' 10.1 Books. Reccrds. and Reoorts. (a) Availabilitv.. At all times during the existence of the Partnership, the Partners shall keep or cause to be kept full and true books of account in accordance with the accounting method fol~owed by the Partnership for federal income tax purposes which shall reflect all Partnership transactions and shall be appropriate and adequate for the Partnership's business. Such books of account, together with a copy of this Agreement and any amendments thereto and a list of names and addresses of all of the partners shall be available to the Partners and the Partners shall have the right at any, time to inspect and copy from such b90ks and documents during normal business hours upon reasonable notice. (b) Finan~ial Rp.ports. .' (i) distributed to of each fiscal preparation of The partners shall cause to be prepared and each Partner, within 75 days after the close year, all information necessary for the the Partner's federal income tax return. " (ii) Within 180 days after the end of each fiscal year, the Partners shall deliver to each Partner a financial report of the Partnership for such calendar year, including a balance sheet, a profit and loss statement prepared by the Accountants on the comprehensive method of accounting (i.e., the accrual method used for federal income tax reporting purposes), and a report by the Partnership showing: (a) distributions to the Partners and allocations to the Partners of partnership taxable income, gains, losses, "deductions, credits, and item"s of tax preference; and (b) on request, a copy of the tax returns (federal, state, and local, if any) of the Partnership for such ,fiscal year. (e) Bank Accoun~s. The Partners shall open and maintain on behalf of the Partnership a bank account or accounts with depositaries as it shall determine, in which all monies received by or on behalf of the partnership shall be deposited. All withdrawals from the accounts shall be made upon the signature of the person or persons as the Partners may from time to time designate. " -23- . FROM.: FAX NO. Jan. 14 2004 03:36PM P27 10.2 Accoun~ina. i v (a) ~countina Deci~i9ns. All decisions as to accounting matters shall be made by the Partners in accordance with the cash method of accounting for tax purposes applied on a consistent basis. Such decisions must,be acceptable to the Accountants. (b) 18%ahle Year and Accountina Method. The Partnership's taxable and fiscal year shall b~ the calendar year. The Partnership shall use the cash method of accounting for tax purposes. ~ll elections required or permitted to be made by the Partner~hip under the Code shall be made by the Partners in such manner as will, in the bpinion of the Accountants, be most advantageous to the Partners. " -24- FROM. : FAX NO. Jan. 14 2004 03:37PM P28 '. ARTICI.E XI MISCELLANEOUS 11.1 No~i~es. Any notice, payment, demand or communication required or permitted to be given by any provision of this Agreement shall be in writing and shall, be deemed to have been delivered, given and received for all purposes (a) if delivered personally to the Partner or to an officer of the Partner to whom the sam~ is directed, or (b) whether or not the same is actually rece,ived, if sent by registered or certified mail, postage and charges pre-paid, addressed as follows: if to the Partnership, to, the principal office of the Partnership as set forth inhparagraph 2.3 hereof, or to such other address as the partnership may from time to time specify by notice to the partners; if to a Partner, to such Partner at the address set forth on Exhibit A hereto, or to such other address as such Partner may from time to time specify by notice to the Partnership. Any such no~ice shall be deemed to be delivered, given and received as of the date so delivered, if delivered personally, or as of the date on which the same was deposited in a tegularly maintained receptacle for the deposit of United states mail, addressed and sent as aforesaid. 11.2 Severability. Each provision hereof is intended to be severable, and the invalidity or illegality of any provision of this Agreement shall not affect the validity or legality of the remainder hereof. 11.3 Cautions. Paragraph captions contained in this Agreement are inserted only as a matter of convenience and for reference and in no way define, limit, extend, or describe tbe scope of this Agreement or the intent of any provision hereof. 11.4 Variation of Pronouns. All pronouns and any variations thereof shall be deemed to refer to masculine, feminine or neuterr singular or plural, as the identity of the person or persons may require. 11.5 Bindipg Aareement. Subject to the restrictions on assignment herein con~ained, the terms and provisions of this Agreement shall be binding upon, and inure to the benefit of the successors, assigns, personal representatives, estates, heirs, and legatees of the respective Partners. 11.6 AD9licable Law. Notwithstanding the place where this Agreement may be executed by any of the terms hereto, the -25- FROM : FAX NO. Jan. 14 2004 03:37PM P29 II ~ J .. parties expressly .gtee ~hat all the terms and provlslons hereof shall be construed uBder the laws of the State and that the partnership Law and other applicable laws of the State as now adcpted or as ~ay hereafter amended shall govern the partnership aspects of this Agreement. 11.7 Entire Aateemen~. This Agreement constitutes the entire agreement of the parties hereto with ~espect to the matters se~ forth herein and supersedes any prior understanding or agreement, oral:or written, with respect thereto. . 11.8 Agreementlin Counternarts. executed in several counterparts and constitute one Agreement, binding on notwithstanding th~t all the parties original or the same counterpart. 11.9 .c.o.D~j:ruction. Every covenant, term and provision of'. this Agreement shall he construed simply according to its fair meaning and not strictly for or against any Partner. This Agreement may be all so executed shall all the parties hereto, are not si9natories to the 11.10 lD&Qrporation bv Reference. Every exhibit, schedule and other appendix attached to this Agreement and.referred to here~ is hereby incorporated in this Agreement by reference. 11.11 ~urther Action. Each Partner agrees to perform all further acts and execute, acknowledge and deliver any documents which may be reasonably necessary, appropriate or desirable to carry out the provisions of this Agreement. IN WITNESS WHEREOF, the parties hereto have executed and delivered this Agreement as of the day and year first above written. THE PARTNERS: ,J-" ./' /~. f'1L~! f?,~ j2A'.'lt(Q;, Fred R. Lerrn~n ~~ PLUSCORl/586 <...-, . "./' ~ ~ .' . 1 . Jtw,~a. \ C/o . D1/ Floreilce J. Gordon \ I .\ , U -26- . ~ROM.: FAX NO. Jan. 14 2004 03:38PM P30 STATE OF NEW YORK ) ) 55.: COUNTY OF ONONDAGA ) .. On this ~ Id y'k day Of. ~~:~~~: 1993, before me personally came FRED'R~ LERMAN, to me known and known to me to be the same person ~escribed in and who executed the within instrument,_ and he 6uly aCknowledged that he e%ecut~d the same. ~ 1;h \ ~ .-' I/. " t'\ fl,d,-7....:. '. A .-; iitf'/.- Notary Public ~-- ;,,:\,::,'1 PIalI...........-. \.i~>3lt.1dinOlr&Qa...0tHft4 1M tRrQ.. .. ...FllL1." STATE OF NEW YORK ) ) 55.: COUNTY OF ONONDAGA ) I n.J ~~ll.t'- On this o~ day of r, 1993, before me personally came ROBERT R. LERMAN, to me known and known to me .to be the same person described in and who executed the within instrument, and he duly acknowledged that he executed the same. 0_'(rA~ ///,~1 Notary PubllC STATE OF NEW YORK ) ) 5S.: COUNTY OF ONONDAGA ) On this ~5 day of Ne-'1l;lilber, 1993, before! be personally came FLORENCE J. GORDON, to melknown\and~~own to me to be the same person described in and Wh/ ~xec~ted:~~e within instrument, and he duly aCknOWledg~j~f.).t at hr e%i~/tiijthe same. t 1/\ f,,; I MM~UN B. KISSELSTEIN th):;:.''Y ~::,).I': Jr: ~--.c ~:=:.: ~I 'J:."fJ '.O~IC / Nq-t ry ~uo 1 i c:.., O\:~!~ c~ Cno.~8 O:.r.:, No. ~.::,~~ ! I' / My ~omm&6iOf'I EXQ~fcOc\.o3ty~. ~!L..fol DEWRES .:L~AA Notary Public S!:nte of NY Qual. Or-Otl. Co.) !io. '~v3g,Q9? My Cv~. Exp. ~~y 9, 19~~ k J1l ~~r -27- I FROM .: . FAX NO. Jan. 14 2004 03:38PM P31 . . EXHIBIT A PARTNERS (Under paragraph 3.l(n)) Partner Percentage 1. Fred R. Lerman 305 Edwards Drive Fayetteville, New York 2. Florence G. Gordon 207 Scottholm Blvd. Syracuse, New York 33 1/3 % 33 1/3 % 3. Robert R. Lerman 8 Caton Drive East Syracuse, New York 33 1/3 % " -28- FROM : FAX NO. '. ' EXHIBIT B DESCRIPTION OF PARTNERSHIP PROPERTY (Under paragraph 3.1(p)) -29- -30- ~~n. 14 2004 03:39PM P32 FROm : FAX NO. EXHIBITC CAPITAL CONTRIBUTIONS (Under-paragraph 4.1) Part:ner Amount 1. Fred R. Lerman .305 Edwards Drive Fayetteville, New York 2. Florence G. Gordon 207 Scottholm Blvd. Syracuse, New York Robert R. Lerman 8 Caton Drive East Syracuse, New York 3. -30- Jan. 14 2004 03:40PM PI '. FROtt1 : . FAX NO. Jan. 14 2004 03:40PM P2 SECOND AMENDMENT TO ~STATED AGREE~NT OF GENERAL PARTNERSHIP OF MANnON COMPANY This is the SECOND AMENDMENT TO 1HE RESTATED AGREEMENT OF GENERAL P AR.1NERSHIP ofMANDON COMPANY which was executed by and among each of the persons executing this Amendment as a Partner (hereinafter ' collectively referred to as the' "Partners'') 'on the 13rd day of December, 1993 (hereinafter refetTed to as "Restated Agreemenf'). ' The Partners hereby agree that the following provisions shall be added as Article XII to the Restateq. Agreement, and that all other provisions therein shall remain fu full force and effect, e~cept as the same may be altered, changed or modified by this Amendment. " ARTICLE XII , TRANSFER OF PARTNER'S INTEREST IN THE EVENT OF DEATH 12.1 Notwithstanding any provision to the contrary contained in the Restated Agreement, including the provisions of Article VIII and any prior Amendments thereof, a Partner may In the event ifhis or her dea~ by will or otherwise. bequeath or transfer his or her interest in the partnerShip to his or her spouse or to all or certain ofms or her children. The deceased Partner's spouse or such children shall, if they elect to do so under the terms of this Amendment, succeed to the interest of the deceased Partner. In such instance, the Partnership sh~ continue~ and the spouse or such children shall share in the net profits or losses ofthe"Partnership in the same way the deceased Partner would have shared 'in them. bad he or sh~ survived. 12.2 If the spouse or such children of a deceased Partner elect( s) to succeed to his or her interest, they shall notify the surviving Partners in writing to that effect. Notification shall be made by ce~~, or registered mail within sixty days of the death of the deceased Partner. In the case of the succession of such childr~n, the right to succeed to a Partner's interest must be made by:th~ deceased Partner's children who succeed to the interest in the Partnership and who ~ust first agree to be bound by aU the temis of the Restated Agreement, prior Amendments, and by this Amendment. The said children must also agree in writing prior to their receivmg mty interest in the Partnership that as long as they hold any interest in the Partnership, the surviving Partners shall be designated by the children as managing Partner(s) who shall.\l1anage the company and make all decisions concerning the business affairs of the comp~y. No attempt to sell or convey the interest of a deceased P~er to any person other ttum. a sUIViving Partner, or to his or ber spouse or such children jn the ev~t of his or her prior,death, shall be valid or enforceable. 12.3 If the spouse or any of such children of a deceased Partner do not elect to' succeed to his or her interes~ in the mann,er stated above, the surviving Partners shall have FROM : . FAX NO. Jan. 14 2ee4 e3:41PM P3 " the right to purchase the interest of the deceased Partner in all the Partnership business and property and shall, effective as of the date of death of the deceased Partner, asslune all the then existing liabilities of the Partnetship. The price to be paid for such purchase shall be equal to the sum of the following items: the capital account of the deceased Partner as disclosed by the books of the Partnership as at the end of the last fiscal year . before his or her death, except that any real estate shall be adjusted to fair market value. For the purpose of the fOregoing computatio~ the books of the Partnership shall be accepted as correct and all computations shall be made and certified by the accounting finn servicing the Partnership at the date of de~ and when so certified, shall be binding and conclusive. . 12.4 If the surviving Partners and the survivors of the deceased Partner shall be unable to agree upon the fair market value of the real property owned by the Partnership, the surviving Partners shall cause an independent appraisal of the property to be . . performed by an Appraiser with M.A.I. credentials. The appraisal shall be binding and conclusive. 12.5 The purchase price shall be paid .as follows: twenty per cent (20%) within three (3) months after the date of death of the Partner and the balance in eq~al quarterly installments over forty-eight (48) months with interest on tlte declining balance at the rate of one per cent (1 %) per annum under the rate charged by Key Bank of Central New York, to prime commercial borrowers on a ninety (90) day matmity basis (hereinafter referred to as "prime rate"). The prime rate shall be set on an annual basis as close to January 1 as ~y be feasible. Such rate shall be used for the ensuing year. If a purchase takes place, the estate of the deceased Partner shall not be entitled to share in any increase or profits gained. nor be liable for any losses incurred; in the business after the date of death of the Partner. . 12.6 Each of the 'Partners hereto do severally bind themselves to execute all documents, including their will, to provide for the continuance of the Partnership for the full tenn thereof, to implement this Amendment, and to authorize and direct th.eir executors, severally, to do every act needful therefor. IN WITNESS WHEREOF, 'the parties hereto have executed and delivered this Agreement as of the day and year first above Written~ Pi. ,~ . Fred R. Lerman ~4~ . Ro R. Lenn 2 f;'ROM : . FAX NO. Jan. 14 ~ 03:41PM P4 stATE OF NEW YORK. dOUNTY OF .ONONDAG~A ) 88.: . " O~ the I? Nay of , 2003, before me, the undersigned, personalfyappeared FRtD R. LE , personally known to me or proved td me on the basis of .tisfaetory evidence to be. e individual whose name is subscribed to the within instrumeitt and acknowledged to me that he execUted the same in.his capacity, iuld that by his signature on the instrument, the individual, or the person upon behalf ofwltlch the individ~ ~ executed. the instrument. ) L~~ I . Notary "~1.1. .j.;". . Notary Public in the Stat~ of r,. Qualified in OnOl'l. Ce.. No. 34.11lJ ,;.~~ STAlE OF NEW YORK) . My Commission f '''''''. ,... 2~ . COUNTY OF ONONDAGA ) S8.: On the;#- day Of~ ,2003, before me, the undersigned, personally appeared ROBERT R! L AN, personally known to me or proved to me on the basis of satisfactory evidence t e the individual whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his capacity, and that by his signature on the instrument, the individual, or the person upon behalf of which the individual acted, executed the instrument. Notary Pu~ieHAR L. ENGEL Notary Public 10 1he State of New \ Qualified in Onon. Co.. No. 34.1y.' My CommissIon Expires .h.llv 1". / STATEOFNEWYORK ) COUNTY OF ONONDAGA ) 88.: On the I Z day of ::fv ~ e.. , 2003, b~fore me, the undersigned, personally appeared FLORENCE J. GORDON, personally known to me or proved to me on the basis of satisfactory evidence to be the individual whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his capacity, and thai by his signature on the instnnnent, the individual, or the person upon behalf of which the individual acted, executed the instrument. BARBARA E. WALSH No. 5001346 Rot8l'Y Public. State 01 New ~ Qualified ill Onolldaga Countv,N_ ., Caminission EJpices 09108flOj.&.' . 1f6~Cti {A'KO,(1; Notary Public 3 F.ROM . . FAX NO. Jan. 14 2004 03:42PM PS DURABLE GENERAL POWER OF ATTORNEY NEW YORK STATUTORY SHORT FORM THE POWERS YOU GRANT BELOW CONTINUE TO BE EFFECTIVE SHOULD YOU BECOME DISABLED OR INCOMPETENT (CAUTION: THIS IS AN IMPORTANT DOCUMENT, IT GIVES THE PERSON WHOM YOU DESICNA "n:(VOUR "AC~N"") 8ROAD POWERS TO HANDLE YOUR PROPERTY, DURING YOUR LIFETIME, WHICH MAY INCLUDE PowERS TO MORTGAGE, SELL, OR OTHERWISE DISPOSE OF ANY REAL OR PERSONAL PROPERT\' WITHOUT AnV ANCE NOTICE TO YOU OR APPROVAL BY YOU. THESE POWERS WILL CONTINUE TO EXIST EVEN AFTER YOU BECOME DISABLEO OR INCOMPETENT. THESE POWERS ARE EXPLAINED MORE FULLY IN NEW YORK GENERAL OBLICA TIONS LAW, ARTICLE S, TITLE 15, SECI10NS 5-~502A m:aOUGH 5-1503, WHICH' EXPRESSLY. P~T THE USE OF ANY OTHER OR DIFFERENT 'ORM OF tOWER OF ATIORNEY . THIS DOCUMENT DOES NOT. AUI1IOlUZE ANYONE TO MAKE MEDICAL OR. 0TBE1l HEALTH CARE DECISIONS YOU MA V . EXECUTE A HEALTH CARE PROXY TO DO THIS. . IF THERE IS ANYTmNG ABOUT THIS FORM THAT YOU DO NOT UND'ERSTAND, YOU SHOULD ASK ALA WVER TO EXPLAIN IT TO VOU.) THIS IS intended to constitute a GENBRALPOWER OF ATTORNEY, pursuant to Article 5, Title 15 of the New York General' Obligations Law: . , I, ~ORENC~ J. GORDON. of 159 Idlewood Boulevard. Baldwinsville. New York 13027 , . , ,(insert name and address of the princiPal) , ..~~-':'_~...d~.hctcbv~~nit1t'M.>AM C,oRDON~ ~f607 Heritage Coutt Mech~i~bur'g~'PA i70~O' ..'-'.' "0' ,. (Ifonc ~ ~ to,~ appoi~ced A~&. iNert ~c' name IIld addrcsa of your asent above.) (If two (2) or marl perroDS ate to be appointed agents by You lnscrt their names and addresses above. myattomey(s)-in-fact TO' ACT (tfmorc rhan one llFflds designated choose ODe ofth.e fOUowins two choiOc:s by puui~g your initials in one of the bl~k spaces to the left of your choic~o . , (.~......) Each agent may separately act. , (.........) All agents must act together. (If neither blank space is initialed, the agents will be required to act together.) IN MY NAME, PLACE AND STEAD in any way which I myself could do, if 1 were personally present, with respect to the following matters as each of them is defined in Title 15 Article 5 of the New York General Obligations Law to the extent that,I am pe~itted by law to act through an agent: DIRECTIONS: INITIAL IN THE BLANK SPACE TO THE LEFT OF YOUR CHOICE ANY ONE OR MORE OF THE FOI..I..OWING LETTERED SUBDMSJONS AS TO WHICH YOU W AN-r:TO GIVE YOUR AGENT AUTHORITY. IFTHE BLANK SPACE WITHIN A BOX TO THE LEFT OF ANY PARTICVLAR. U!TTERED SUBDIVISION IS NOT INITIALED, NO AUTHORITY WILL BE 'GRANTED FOR MATfERS THAT ARE INCLUDED IN THAT SUBDIVISION. ALTERNATIVELY, mE LETTER CORRESPONDING TO EACH l'OWER YOU WISH TO GRANT MAY BE WRlTIEN OR TYPED ON THE BLANK LINE IN SUBDMSJON "(Q)~, AND YOU MAY THEN PUTYOVR INITIALS IN THE BLANK SPACE TO THE LEFT OF SUBDMSION "(Q)" IN ORDER TO GRANT EA~H ~~ ~~E, PO~~.1!5 SO INDICA TED. .' l . ,. ;.: . '.. 'f '; t.. .. '. ... ...~. ~:': :.~ \;..:,:::~.' '.:::" : . ,...... ~.~t' . I :;~.~:..,.,'./:...~~~:; .:.... FROM . (........ ) (........) (........) (........) (........) (........) (........) (........) (........) (........) (........) (....~...) (........) . (........) I (........) (........) <1..) FAX NO. : Jan. 14 2004 03:43PM P1 (A) real estate transactions; (8) chattel and goods transac:tions; (C) bond, share and commodity transactions; (D) banking transac:tions; (E) business operating transactions; (F) insurance transactions; (G) estate transactions; (H) claims and litigations; (I) personal relationships and affairs; (J) benefits from military service; (K) records, repons and statements; (L) retirement benefit transactions . (M) making gifts to my spouse, children and more remote descendants, and parents, Dot to exceed in the aggregate S 1 0,000 to each of such persons in any year. (N) taxmatters (0) all other matters; (P)' full and unqualified authority to my attomey(s)-in-factto delegate any or all of the foregoing powers to any person or persons whom my attomey(s)-in-fact shall select; <Q} each of the above matters ident~ed by the following letters: ..A,B,C,D,E,F,G,H,I),K,L,M,N, O,P. ....... ...... ......... ...... ....... ... ... ......... ............... ....... ...... ... .... '" ..... (Special provisions and limitations may be included in the statutory short form durable power of attorney 9PJy if they r:nnfnrm !'" 'h~ rftnnla.mlmm nfnftATtna S li,Yi .i... -ti.... If ..H,t-r -... n:' I~' ';' } TIDS DURABLE POWER OF AITORNEY. S~L NOT BE AFFECTED. BY MY SUBSEQUENT -..--D!SABILI'R.4)R-IN€GMPETENCE. ..- .---. ...--- _u_. ----.-.,-'. --- -_.,-- .. ...... ..._...... . ..:,...,.....:.:.:.:.:~..:_.::.~~... ..~ ,.::.",~~",":,'. ...:.;~.:.........,: " ...' ... ........._:..: ".:.. '. _.~ ~"'''''''._''''':', .::.... ...7..:"'-:':'P~~ .....-...:,..... ..,:.... ........ .. .. . If every agent naDu~d above is unable'orunwillinsto serve? I appoint 'ILENE G01U>QN..qr'87Qy ~lnj~d KinfTnnm nri~e... AlJ$tin~ IXl 7.S.7~8 -' . . . . (11IICtt Name lAd Address or Svtceuor) I9J'f.ll'rJl~~1~5Wd.R~Q~EOF11IIS INS'l"KlJ~NT MAY ACT HEREUNDER, AND THAi REVOCATION OR TERMINATION HEREOF SHALL BE INEFFECTIVE AS TO SUCH mJRD PARTY UNLESS AND UNTIL ACTUAL NOTICE OR KNOWLEDGE OF SUCH REVOCATION OR TERMINATION SHALL HAVE BEEN RECEIVED BY SUCH THIRD PARTY, AND I FOR MYSELF AND FOR MY HEms~ EXECUTOltS,LEGAL REPRESENTATIVES AND ASSIGNS, HEREBY AGREE TO INDEMNIFY AND HOLD HARMLESS ANY SUCH THIRD PARTY FROMAN>> AGAINST ANY AND ALL CLAIMS THAT MAY ARJ.SE AGAINST SUCH THIRD PARTY BY REASON OF SUCH THIRD PARTY HAVING RELIED ON THE PROVISIONS OF TmS INSTRUMENT. THIS DURABLE POWER OF ATrORNEY MAYBE REVOKED , BY ME AT, ANY TIME., , ' . IN WITNESS WHEREOF, I have hereunto signed my name this 24th day of March. 20 . (You Sign Here:) State of New York, County of Onondaga) sS.: On this 24th day of March, 2003, before me, the undersigned, a notary public in and for said state, personally appeared FLORENCE J. GORDON, personally known to me or proved to me on the basis of satisfactory evidence to be the individual whose name is subscribed to the within instrument and acknowled me that she executed the same in her capacity, and that by her signature on the instrument, the individual or the 0 of which the individual acted, executed tbe instrument. ROBERT F. BAlDWIN, JR. '**'Y PUb/lc. Stat. of New York ,.., -IU! No. 028M815221 --med In Onon~. Cau~ MyCo....M... Expires 0808mber3i.a6-'. . , COpy SECONt> AMENDMENT TO ~STATEDAGREEMENT OF GENERAL PAR1NERSHIP OF MANDON COMPANY This is the SECOND AMENDMENT TO THE REST A TED AGREENffiNT OF GENERAL PARTNERSIllP ofMANDON COMPANY which was executed by and among each of the persons executing this Amendment as a Partner (hereinafter collectively referred to as the "Partners") on the 23rd day of December, 1993 (hereinafter referred to as'''Restated',Agreement''). The Partners heteby agree that the following provisions shall be added as Article XII to the Restated Agreement, and that all other provisions therein shall remain in full force and effect, -except as the same may be altered, changed or modified by this Amendment. ARTICLE XII TRANSFER OF PARTNER'S INTEREST IN THE EVENT OF DEATH 12.1 Notwithstanding any provision to the contrary contained in the Restated Agreement, including the provisions of Article VIll and any prior Amendments thereof, a Partner may, in the event if his or her death, by will or otherwise, bequeath or transfer his or her interest in the partnership to his or her spouse or to all or certain of his or her children. The deceased Partner's spouse or such children shall, if they elect to do so Wlder the terms of this Amendment, succeed to the interest of the deceased Partner. In such instance, the Partnership shall continue, and the spouse or such children shall share in the net profits or losses of the Partnership in the same way the deceased Partner would have shared in them had he or she survived. 12.2 If the spouse or such children of a deceased Partner elect(s) to succeed to his or her interest, they shall notify the surviving Partners in writing to that effect. Notification shall be made by certified or registered mail within sixty days of the death of the deceased Partner. In the case of the succession of such children, the right to succeed to a Partner's interest must be made by the deceased Partner's children who succeed to the interest in the Partnership and who must fIrst agree to be bound by all the terms of the Restated Agreement, prior Amendments, and by this Amendment. The said children must also agree in writing prior to their receiving any interest in the Partnership that as long as they hold any interest in the Partnership, the surviving Partners shall be designated by the children as m~ging Partner(s) who shall manage the company and make all decisions concerning the business affairs of the company. No attempt to sell or convey the interest ofa deceased Partner to any person other than a surviving Partner, or to his or her spouse or such children in the event of his or her prior death, shall be valid or enforceable. 12.3 If the spouse or any of such children of a deceased Partner do not elect to succeed to his or her interest in the manner stated above, the surviving Partners shall have .., . .. " PETITION FOR GRANT OF LETTERS Estate of Florence J. Gordon also kndwn as No. Florenc. J. Gordon , Deceased Social Security No. 052-26-1718 Adam M. Gordon Petitioner(s), Who is/are 18 years of age or older, apply(ies) for: (COMPLETE "A" OR "B" BELOW:) [i] A. Probate and Grant of Letters and aver that Petitioner(s) is/are the execut or Decedent, dated 5/18/2005 and codicil(s) dated named in the Last Will of the State relevant circumstances, e.g., renunciation, death Of executor, ete Except as follows, Decedent did not marry, was not divorced and did not have a child born or adopted after execution of the documents offered for probate; was not the victim of a killing and was never adjudicated incapacitated: o B. Grant of Letters of Administration (c.I.a., d.b.n.c.t.a.: pendente lite, durante absentia; durante minoritate) Petitioner(s) after a proper search haslhave ascertained the Decedent left no Will and was survived by the following spouse (if any) and heirs: I Name Relationship Residence I " (COMPLETE IN ALL CASES:) Attach additional sheets if necessary. Decedent was domiciled at death in Cumberland County, Pennsylvania, with his/her last family or principal residence at 111 Maple Drive, SilversprinQ Township, MechanicsburQ (list street, number and municipality) Decedent, then 74 years of age, died July 23 ,2005 ,at 111 Maple Drive. MechanicsburQ, PA (Location) Decedent at death owned property with estimated values as follows: (if domiciled in PA) All personal property ......................................... $ (if not domiciled in PA) Personal property in Pennsylvania .................... $ (If not domiciled in PA) Personal property in County.............................. $ Value of real estate in Pennsylvania ........................................................................................ $ Total ..................................................................................................................... $ 150,000.00 150,000.00 Real Estate situated as follows: Wherefore, Petitioner(s) respectfully request(s) the probate of the Last Will and Codicil(s) presented with this Petition and the grant of letters in the appropriate form to the undersigned: Signature Typed or printed name and residence RW.7 17055 ,." t... Oath of Personal Representative Commonwealth of Pennsylvania County of Cumberland The Petitioner(s) above-named swear(s) and affirm(s) that the statements in the foregoing Petition are true and correct to the best of the knowledge and belief of Petitioner(s) and that, as personal representative(s) of the Decedent, Petitioner(s) will well and truly administer the estate according to law. Sworn to and affirmed and subscribed before me this day of DECREE OF REGISTER Estate of Florence J. Gordon also known as Deceased No. Social Security No: 052-26-1718 Date of Death: 7/23/2005 AND NOW, , in consideration of the Petition on the reverse side hereon, satisfactory proof having been presented before me, IT IS DECREED that Letters !XI Testamentary 0 of Administration are hereby granted to Adam M. Gordon (c.t.a., d.b.n.c.t.; pendente lite; durante absentia; durante minoritate) in the above estate and that the instrument{s), if any, dated 5/18/05 described in the Petition be admitted to probate and filed of record as the last Will of Decedent. FEES Letters.. .................. ................ $ ;. Short Certificate( s) ............... $ $ $ $ $ $ Inventory & Tax Forms............. $ $ Renunciation .......................... Affidavit ( ) ....................... ).............. Extra Pages ( Codicil................................. JCP Fee ................................. Other.... .................................. TOTAL .......... ........ ...........$ RW-7A Register of Wills Attomey Attorney: Mark A. Mateva 1.0. No: 78931 Address: P.O. Box 127 BoilinQ SprinQs Telephone: 717-241-6500 DATE FILED: PA 17007