HomeMy WebLinkAbout06-6679FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/9163
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
HOME ELITE LTD., INC. and
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046
Plaintiffs,
V.
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R.
Real Estate, LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION - LAW
HONG TSANG,
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant.
Docket No. o . 1d1o7cl
CONFESSION OF JUDGMENT FOR MONEY
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, we appear for the
Defendant and confess judgment in favor of the Plaintiffs and against the Defendant
as follows:
Unpaid Rent $7,126.7.1
(including Minimum Rent and Additional Rent)
Attorney's Commission 712.67
$7,839.38
Judgm t Entered Above
Prothonotary
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
By: a4w&. ;??w
Frank G. Murphy, Es ire
Christina M. Hughes, Esquire
Attorneys for Defendant
FIND ?..1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
HOME ELITE LTD., INC. and
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiffs,
V.
CIVIL ACTION - LAW
HONG TSANG, Docket No.
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant.
236 NOTICE
NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER
HAS BEEN ENTERED AGAINST YOU FOR PAST RENT OWED IN THE AMOUNT OF
$7,839.38 (principal sum plus reasonable attorneys' fees). ENCLOSED HEREWITH IS
A COPY OF ALL THE DOCUMENTS FILED IN SUPPORT OF THE SAID JUDGMENT.
CURTIS R. LONG
PROTHONOTARY
IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT:
FREY, PETRAKIS, DEEB, BLUM
8v BRIGGS, P.C.
By: 6?-ARQf!!!? I.D. Nos. 65886 91635
Frank G. Murph , Esquire
Christina M. Hughes, Esquire
1601 Market Street, Suite 2600
Philadelphia, PA 19103
(215) 563-0500
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R. Real Estate,
LLC
Dated: ?l D6
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/91635
1601 Market Street, 261h Floor
Philadelphia, PA 19103
(215) 563-0500
HOME ELITE LTD., INC. and
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046
Plaintiffs,
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R.
Real Estate, LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION - LAW
V.
HONG TSANG,
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant
Docket No.
COMPLAINT FOR CONFESSION OF JUDGMENT
UNDER PENNSYLVANIA RULES OF CIVIL PROCEDURE 2950, ET SE-O
Plaintiffs, Home Elite Ltd., Inc. and P.R. Real Estate, LLC, (hereinafter
"Plaintiffs" or "Landlords"), by and through their attorneys Frey, Petrakis, Deeb, Blum
& Briggs, P.C., file this Complaint for judgment by confession pursuant to Rules 2950
et seq., of the Pennsylvania Rules of Civil Procedure and, in support hereof, state as
follows:
THE PARTIES
1. Plaintiffs, Home Elite Ltd., Inc. and P.R. Real Estate, LLC, are owners of
a shopping center commonly known as East Gate Plaza, located at 5205 Simpson
Ferry Road, Mechanicsburg, Pennsylvania 17055, as tenants in common and have a
place of business located at 491 Old York Road, Suite 200, Jenkintown, Pennsylvania
19046.
2. Defendant, Hong Tsang t/d/b/a China Garden (hereinafter
"Defendant/ Tenant"), upon information and belief, is a business operating a
restaurant and has a last known address of 5205 Simpson Ferry Road, Suite 11,
Mechanicsburg, Pennsylvania 17055.
3. Pintzuk Brown Realty Group, (hereinafter "Pintzuk") is an authorized
agent of and acts on behalf of Landlords and has a place of business located at 491
Old York Road, Suite 200, Jenkintown, Pennsylvania 19046. (See Affidavit of Scott
Homel attached hereto, incorporated herein, and marked as Exhibit A).
COUNT I
FOR JUDGMENT OF MONEY (PAST RENT OWED)
Pa.R.C.P. 2950 et seq.
4. Landlords incorporate by reference the foregoing paragraphs as if fully
set forth herein at length.
5. Defendant/ Tenant is in occupancy and possession of 1,600 square feet
of commercial space known as space L, (the "Property") currently being utilized as a
restaurant known as China Garden and located at the shopping center commonly
known as East Gate Plaza, located at 5205 Simpson Ferry Road, Mechanicsburg,
Pennsylvania 17055.
6. The owners of the Property are Home Elite Ltd., Inc. and P.R. Real
Estate, LLC. The Defendant/Tenant leases the Property from Landlords for
commercial use pursuant to a written agreement (as the same has been amended,
assigned, restated, or otherwise modified through the date hereof, "Lease"). (A copy
representing a true and correct reproduction of the original Lease is attached hereto,
incorporated herein and marked as Exhibit B; all applicable terms are highlighted in
yellow for the Court's convenience).
7. Defendant /Tenant is subject to the Lease pursuant to an Assignment of
Lease dated November 8, 1993 (the "Assignment of Lease"), an Addendum dated
August 25, 2004 (the "Addendum"), and an Estoppel Letter dated August 31, 2004
(the "Estoppel Letter"). (A copy representing a true and correct reproduction of the
Assignment of Lease is attached hereto, incorporated herein, and marked as Exhibit C;
all applicable terms are highlighted in yellow for the Court's convenience). (A copy
representing a true and correct reproduction of the Addendum is attached hereto,
incorporated herein, and marked as Exhibit D; all applicable terms are highlighted in
yellow for the Court's convenience). (A copy representing a true and correct
reproduction of the Estoppel Letter is attached hereto, incorporated herein, and
marked as Exhibit E; all applicable terms are highlighted in yellow for the Court's
convenience).
8. Landlords are entitled to enforce the Lease by virtue of an assignment of
rights, which took place upon Landlord's acquisition of the Property from its prior
owner. (See a true and correct reproduction of Settlement Statement attached hereto,
incorporated herein, and marked as Exhibit F).
9. Pursuant to the terms of the Lease, Assignment of Lease, Addendum,
and Estoppel Letter, during the relevant time period, the Defendant/ Tenant is
required to pay to the Landlords a monthly fixed Minimum Rent of $1,472.00. (See
Exhibits B, C, D, and E).
10. In addition, the Defendant/ Tenant is obligated under the Lease,
Assignment of Lease, Addendum, and Estoppel Letter to pay the Landlords Additional
Rent in the form of, inter alia, operating expenses, utilities, insurance, and taxes. (See
Exhibits B, C, D, and E).
11. Defendant/ Tenant has defaulted on its obligations under the Lease by
virtue of its failure to pay Landlords Minimum Rent and Additional Rent in the
amount of $7,126.71, as follows:
Description Amount Owed
Outstanding Late Fees as of 2 / 28 / 06 $1,117.23
Outstanding Rent as of 2/26/06 $2,944.00
Returned Check Charge 12/1/05 $30.00
Outstanding CAM as of 2/28/06 $875.94
Outstanding RE Tax as of 2/28/06 $260.00
Outstanding INSR as of 2/28/06 $96.30
Outstanding YE 2004 CAM REC $691.34
Outstanding 2004 YE INSR Reconciliation $209.26
Outstanding 2004 YE RETAX reconciliation $506.91
Rent (3/2006) $1,472.00
CAM (3/2006) $437.97
Property Taxes Pass Thru (3/2006) $130.00
Insurance Pass Thru (3/2006) $48.15
March Late Fees, 5% of $2,088.12 $104.41
Check #0615 -$2,088.12
Rent (4/2006) $1,472.00
CAM (4/2006) $437.97
Property Taxes Pass Thru (4/2006) $130.00
Insurance Pass Thru (4/2006) $48.15
April Late Fees, 5% of $4,176.24 $208.81
Check #0617 -$2,088.12
Rent (5/2006) $1,472.00
CAM (5/2006) $437.97
Property Taxes Pass Thru (5/2006) $130.00
Insurance Pass Thru (5/2006) $48.15
May Late Fees, 5% of $4,176.24 $208.81
Check #0621 -$2,088.12
Rent (6/2006) $1,472.00
CAM (6/2006) $437.97
Property Taxes Pass Thru (6/2006) $130.00
Insurance Pass Thru (6/2006) $48.15
June Late Fees, 5% of $4,176.24 $208.81
Check #0622 -$2,088.12
Rent (7/2006) $1,472.00
CAM (7/2006) $437.97
Property Taxes Pass Thru (7/2006) $130.00
Insurance Pass Thru (7/2006) $48.15
July Late Fees, 5% of $4,176.24 $208.81
Check #0624 -$2,088.12
Rent (8/2006) $1,472.00
CAM (8/2006) $437.97
Property Taxes Pass Thru (8/2006) $130.00
Insurance Pass Thru (8/2006) $48.15
August Late Fees, 5% of $4,176.24 $208.81
Check #0629 -$2,088.12
Rent (9/2006) $1,472.00
CAM (9/2006) $437.97
Property Taxes Pass Thru (9/2006) $130.00
Insurance Pass Thru (9/2006) $48.15
September Late Fees, 5% of $4,176.24 $208.81
Check # 0630 -$2,088.12
Y/E 2005 CAM Reconciliation Credit -$1,501.06
Y/E 2005 Insurance Reconciliation Credit -$86.65
Y/E 2005 RE Tax Reconciliation Charge $104.68
Rent (10/2006) $1,472.00
CAM (10/2006) $437.97
Property Tax Pass Thru (10/2006) $130.00
Insurance Pass thru (10/2006) $48.15
October Late Fees, 5% of $4,176.24 $208.81
Check # 0631 -$2,088.12
Rent (11 /2006) $1,472.00
CAM (11/2006) $437.97
Property Tax Pass Thru (11/2006) $130.00
Insurance Pass Thru (11/2006) $48.15
November Late Fees, 5% of $6,264.36 $313.22
Check #0636 -$2,088.12
TOTAL: $7,126.71
12. By letter dated September 28, 2005, Pintzuk notified Defendant/ Tenant
of the failure to comply with various provisions of the Lease. Through the letter,
Pintzuk further advised Defendant/ Tenant that, unless Defendant/ Tenant made
payment in full of the amounts owing under the Lease, Pintzuk would exercise any
and all rights and remedies available to Landlords for non-payment of rent. (A true
and correct copy of the September 28, 2005 letter is attached hereto and incorporated
herein by reference as Exhibit G).
13. By letter dated October 26, 2005, Pintzuk notified Defendant/ Tenant of
the failure to comply with various provisions of the Lease. Through the letter, Pintzuk
further advised Defendant/ Tenant that, unless Defendant /Tenant made payment in
full of the amounts owing under the Lease, Pintzuk would exercise any and all rights
and remedies available to Landlords for non-payment of rent. (A true and correct copy
of the October 26, 2005 letter is attached hereto and incorporated herein by reference
as Exhibit H).
14. By letter dated April 24, 2006, Pintzuk notified Defendant/ Tenant of the
failure to comply with various provisions of the Lease. Through the letter, Pintzuk
further advised Defendant/ Tenant that, unless Defendant/ Tenant made payment in
full of the amounts owing under the Lease, Pintzuk would exercise any and all rights
and remedies available to Landlords for non-payment of rent. (A true and correct copy
of the April 24, 2006 letter is attached hereto and incorporated herein by reference as
Exhibit I).
15. By letter dated May 19, 2006, Pintzuk notified Defendant /Tenant of the
failure to comply with various provisions of the Lease. Through the letter, Pintzuk
further advised Defendant /Tenant that, unless Defendant/Tenant made payment in
full of the amounts owing under the Lease, Pintzuk would exercise any and all rights
and remedies available to Landlords for non-payment of rent. (A true and correct copy
of the May 19, 2006 letter is attached hereto and incorporated herein by reference as
Exhibit J).
16. By letter dated July 14, 2006, Pintzuk notified Defendant/ Tenant of the
failure to comply with various provisions of the Lease. Through the letter, Pintzuk
further advised Defendant/Tenant that, unless Defendant/ Tenant made payment in
full of the amounts owing under the Lease, Pintzuk would exercise any and all rights
and remedies available to Landlords for non-payment of rent. (A true and correct copy
of the July 14, 2006 letter is attached hereto and incorporated herein by reference as
Exhibit K).
17. As of the date hereof, the Defendant /Tenant has not cured its default.
18. Under the Lease, the Landlords are empowered to confess judgment
against Defendant/ Tenant for all back rent owed. (See Exhibit B).
19. Under the Lease, Landlords are also entitled to recover from the
Defendant/ Tenant reasonable attorneys' fees, or ten percent (10%). (See Exhibit B).
20. Thus, as of November 13 2006, the amounts due and owing by the
Defendant/ Tenant to Landlords under the Lease are as follows:
Unpaid Rent $7,126.71
(including Minimum Rent and Additional Rent)
Attorneys' Commission 712.67
*$7,839.38
*Total amount due under the lease as of November 13, 2006 (subject to increase for
interest at a rate equal to the greater of (1) the prime rate of interest charged by the
York Bank & Trust Company of York, Pennsylvania, or its successors, plus two
percent (2%); or (2) six percent (6%) per annum; but in no event shall the rate be
greater than the legal rate of interest which may be charged to borrower of the same
character as Defendant/Tenant; See Exhibit B).
21. Judgment is not being entered by confession against a natural person in
connection with a consumer credit transaction.
22. Judgment is not being entered against a natural person in connection
with a residential lease.
23. No judgment has been entered on the Lease in any jurisdiction.
24. The Warrant of Attorney is less than twenty (20) years old.
WHEREFORE, Landlords, Home Elite Ltd., Inc. and P.R. Real Estate, LLC,
hereby demand judgment by confession in the amount of $7,839.38 (principal sum
plus reasonable attorneys' fees) against Defendant/ Tenant, Hong Tsang t/d/b/a
China Garden, as authorized by the warrant of attorney appearing in the attached
Lease, together with such other and further relief as the Court may deem proper.
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
By: .
Frank G. Murphy, Es ire
Christina M. Hughes, Esquire
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R. Real Estate,
LLC
Dated: 1117-010G
VERIFICATION
I, Mary Duffy, state that I am authorized to make this Verification on behalf of the
Plaintiffs, and that the facts set forth in the preceding Complaint are true and correct to
the best of my information and belief. This Verification is made with knowledge of the
penalties contained in 18 Pa. C.S.A. §4904, relating to unsworn verification to authorities.
By:
dry Deify, AOdtManager
-ntzuk Brown Realty Group,
Agent of Home Elite Ltd., Inc. and P.R. Real
Estate, LLC
Dated: l fldb
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/91635
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
HOME ELITE LTD., INC. and
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046
Plaintiffs,
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R.
Real Estate, LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION - LAW
V.
HONG TSANG,
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant.
Docket No.
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter our appearance for the Defendant, Hong Tsang t/d/b/a China
Garden, on whose behalf we confess judgment for money in the sum of $7,839.38
(principal sum plus reasonable attorneys' fees).
FREY, PETRAKIS, DEEB, BLUM
8v BRIGGS, P.C.
By: 4-7W?- - A06t;,'
Frank G. Murphy, E uire
Christina M. Hughes, Esquire
Dated: ? 2,0Attorneys for Defendant
/0?
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/91635
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
HOME ELITE LTD., INC. and
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046
V.
HONG TSANG,
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road,
Mechanicsburg, PA 17055
TO THE PROTHONOTARY:
Plaintiffs,
Suite 11
Defendant.
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R.
Real Estate, LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION - LAW
Docket No.
ORDER FOR APPEARANCE
Kindly enter our appearance as attorneys for the Plaintiffs, Home Elite Ltd., Inc.
and P.R. Real Estate, LLC, in the above-entitled matter.
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
By:
Frank G. Murphy, squire
Christina M. Hughes, Esquire
Dated: j> Attorneys for Plaintiffs
?10?D?O
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/91635
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
HOME ELITE LTD., INC. and
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046
Plaintiffs,
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R.
Real Estate, LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION - LAW
V.
HONG TSANG,
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant.
Docket No.
CERTIFICATION OF ADDRESSES
Christina M. Hughes, Esquire, certifies, to the best of her knowledge,
information, and belief, that the addresses of Plaintiffs, Home Elite Ltd., Inc. and P.R.
Real Estate, LLC, and Pintzuk Brown Realty Group, Agent of Plaintiffs, are 491 Old
York Road, Suite 200, Jenkintown, Pennsylvania 19046; and the last known address
of Defendant, Hong Tsang t/d/b/a China Garden, is 5205 Simpson Ferry Road, Suite
11, Mechanicsburg, Pennsylvania 17055.
FREY, PETRAKIS, DEEB, BLUM
8v BRIGGS, P.C.
By: 246140
Christina M. Hug , Esquire
Attorney for Plaintiffs,
Home Elite Ltd., Inc. and P.R. Real Estate,
LLC
Dated: A
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/91635
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
HOME ELITE LTD., INC. and
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046
Plaintiffs,
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R. Real
Estate, LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION - LAW
V.
HONG TSANG,
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant.
Docket No.
AFFIDAVIT
STATE OF PENNSYLVANIA
SS.
COUNTY OF CUMBERLAND
Mary Duffy, being duly sworn according to law, deposes and says that she is an
Asset Manager for Pintzuk Brown Realty Group, Agent of Home Elite Ltd., Inc. and P.R.
Real Estate, LLC; that she is authorized to make this affidavit on behalf of Plaintiffs, Home
Elite Ltd., Inc. and P.R. Real Estate, LLC; that the facts set forth in the Complaint in
Confession of Judgment are true and correct to the best of her knowledge, information,
and belief; and, that the Exhibits attached to the Complaint in Confession of Judgment
are true and correct copies of the originals, highlighted for the Court's convenience.
Sworn to and Sub ribed
before e t4is day
oD r ?'9 ,l- A ,
2006.
Notary Public
NOTARIAL SEAL
Daniel R. Henderson, Notary Public
Jenkintown Township, Montgomery County
My commission expires May 14, 2009
Agent of Home Elite Ltd., Inc. and P.R.
Real Estate, LLC
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/91635
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
HOME ELITE LTD., INC. and
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046
Plaintiffs,
V.
HONG TSANG,
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant.
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R. Real
Estate, LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION - LAW
Docket No.
AFFIDAVIT OF INCOME
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
Mary Duffy, being duly sworn according to law, deposes and says that she is an
Asset Manager of Pintzuk Brown Realty Group, Agent of Home Elite Ltd., Inc. and P.R.
Real Estate, LLC; that she is authorized to make this affidavit on behalf of Plaintiffs, Home
Elite Ltd., Inc. and P.R. Real Estate, LLC; and, that to the best of her knowledge,
information, and belief, at the time of the signing of the document containing provision for
judgment by confession in the said matter, the income of Defendant, Hong Tsang t/d/b/a
China Garden, was in excess of $10,000 per year.
Sworn to and Subscribed
before me this 1'5- day
of 1V0V*-Fkf)P7t- 2006.
Notary Public
NOTARIAL SEAL
Daniel R. Henderson, Notary Public
Jenkintown Township, Montgomery County
My commission expires May 14, 2009
11AIA411 41?
4a?y D sset a er
ntzuk 13rown Re ty roup,
Agent of Home Elite Ltd., Inc. and P.R.
Real Estate, LLC
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/91635
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R. Real
Estate, LLC
HOME ELITE LTD., INC. and COURT OF COMMON PLEAS
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046 CUMBERLAND COUNTY
Plaintiffs, CIVIL ACTION - LAW
V.
HONG TSANG, Docket No.
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant.
AFFIDAVIT OF NONAPPLICABILITY OF GOODS AND SERVICES
INSTALLMENT SALES ACT AND AFFIDAVIT OF NON-CONSUMER CREDIT
TRANSACTION AND NON-RESIDENTIAL LEASE
STATE OF PENNSYLVANIA
SS.
COUNTY OF CUMBERLAND
Mary Duffy, being duly sworn according to law, deposes and says that she is an
Asset Manager for Pintzuk Brown Realty Group, Agent of Home Elite Ltd., Inc. and P.R.
Real Estate, LLC; that she is authorized to make this affidavit on behalf of Plaintiffs; that
the Confession of Judgment does not arise out of a retail installment sale, contract, or
account, as defined under the Goods and Services Installment Sales Act, 69 P.S. §1101, et
seg.; that the Confession of Judgment is not being entered against natural person(s) in
connection with a "consumer credit transaction" as that term is defined in Pa.R.C.P. 2950
(as amended); that the Confession of Judgment is not being entered in connection with a
residential lease; and, that the foregoing facts a and correct to the best of her
knowledge, information, and belief. ar ?
Sworn to and Subscribed
before me this IS' day
of N?VP-MOG'!Z- , 2006.
Notary Public
NOTARIAL SEAL
Daniel R. Henderson, Notary Public
Jenkintown Township, Montgomery County
My commission expires May 14, 2009
Mary ffy, A4e/ Mager
Pintzdk Brown Reajty Group,
Agent of Home Elite Ltd., Inc. and P.R.
Real Estate, LLC
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/91635
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R. Real
Estate, LLC
HOME ELITE LTD., INC. and COURT OF COMMON PLEAS
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046 CUMBERLAND COUNTY
Plaintiffs, CIVIL ACTION - LAW
V.
HONG TSANG, Docket No.
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant.
AFFIDAVIT OF DEFAULT
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
Mary Duffy, being duly sworn according to law, deposes and says that she is an
Asset Manager of Pintzuk Brown Realty Group, Agent of Home Elite Ltd., Inc. and P.R.
Real Estate, LLC; that she is authorized to make this affidavit on behalf of Plaintiffs; that
Defendant, Hong Tsang t/d/b/a China Garden, entered into the Lease (as defined in the
Complaint in confession of judgment filed in the within action), a true and correct copy of
which is attached to the Complaint; that Defendant is in default under the Lease by failing
to pay rent owed to Plaintiffs. There is presently $7,839.38 (principal sum plus reasonable
attorney's fees) due and owing under the Lease.
Sworn to and Subscribed
before me this jr day
of -tbQV- A L-(L-- , 2006.
Notary Public
NOTARIAL SEAL Public
Daniel R. Henderson,
ornery County
Jenkintown Township, B 14, 2009
my commission expires May
J?m
anger
Du
to
Pintzuk rown V y roup,
Agent of Home Elite Ltd., Inc. and P.R.
Real Estate, LLC
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/91635
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R. Real
Estate, LLC
HOME ELITE LTD., INC. and COURT OF COMMON PLEAS
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046 CUMBERLAND COUNTY
Plaintiffs, CIVIL ACTION - LAW
V.
HONG TSANG, Docket No.
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant.
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF PENNSYLVANIA
COUNTY OFCUMBERLAND
SS.
Mary Duffy, being duly sworn according to law, deposes and says that she is an
Asset Manager of Pintzuk Brown Realty Group, Agent of Home Elite Ltd., Inc. and P.R.
Real Estate, LLC; that she is authorized to make this affidavit on behalf of Plaintiffs; and,
that to the best of her knowledge, information, and belief, the Defendant is not in the
Military or Naval Service of the United States, nor any State or Territory hereof or its allies,
or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940 and
the amendments thereto or the Servicemembers Civil lief Act.
Sworn to and Subscribed
before me this )'- day M Duffy Asset er
of k%WkPW0, , 2006. Pi tzuk own Re ty roup,
S_ Agent of Home Elite Ltd., Inc. and P.R.
Not?n? n„>1 ir- Real Estate. LLC
NOTARIAL- SEAL
Daniel R. Henderson, Notary Public
Jenkintown Township, Montgomery County
My commission expires May 14, 2009
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/9163
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
HOME ELITE LTD., INC. and
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046
Plaintiffs,
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. And
P.R. Real Estate, LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION - LAW
V.
HONG TSANG,
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant.
Docket No.
PRAECIPE FOR ASSESSMENT OF DAMAGES AND JUDGMENT BY
CONFESSION FOR MONEY PURSUANT TO PA.R.C.P. 2951 ET SEQ.
TO THE PROTHONOTARY:
Pursuant to Pa.R.C.P. 2951 et seq., please assess damages and enter
judgment against Defendant, Hong Tsang t/d/b/a China Garden, in favor of
Plaintiffs, Home Elite Ltd., Inc. and P.R. Real Estate, LLC, in the amount of
$7,839.38 (principal sum plus reasonable attorneys fees), as follows:
Unpaid Rent $7,126.71
(including Minimum Rent and Additional Rent)
Attorneys' Commission 712.67
$7,839.38
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
By: 64=?2 AA!?
Frank G. Murphy, Es ire
Christina M. Hughes, Esquire
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R. Real
Dated: /? Estate, LLC
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/91635
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
HOME ELITE LTD., INC. and
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046
Plaintiffs,
V.
HONG TSANG,
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant.
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R. Real
Estate, LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION - LAW
Docket No.
AFFIDAVIT OF BUSINESS TRANSACTION
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
Mary Duffy, being duly sworn according to law, deposes and says that she is an
Asset Manager of Pintzuk Brown Realty Group, Agent of Home Elite Ltd., Inc. and P.R.
Real Estate, LLC; that she is authorized to make this affidavit on behalf of Plaintiffs; and,
that the transaction upon which Judgment is being entered by Confession was a business
and commercial transaction.
Sworn to and Subscribed
before me this ?- day
of hb19MBC19- , 2006.
Notary Public
NOTARIAL SEAL
Daniel R. Henderson, Notary Public
Jenkintown Township, Montgomery County
My commission expires May 14, 2009
Mary D , s ger
Y p,
Agent of Home Elite Ltd., Inc. and P.R.
Real Estate, LLC
Pintzuk rown alt Grou
FREY, PETRAKIS, DEER, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/91635
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
HOME ELITE LTD., INC. and
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046
Plaintiffs,
V.
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R.
Real Estate, LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION - LAW
HONG TSANG, Docket No.
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant.
Notice Under Rule 2958.1
of Judgment and Execution Thereon
Notice of Defendant's Rights
To: Hong Tsang t/d/b/a China Garden (Defendant)
A judgment in the amount of $7,839.38 (principal sum plus reasonable
attorneys' fees) has been entered against you and in favor of the Plaintiffs
without any prior notice or hearing based on a confession of judgment
contained in a written agreement or other paper allegedly signed by you. The
sheriff may take your money or other property to pay the judgment at any time
after thirty (30) days after the date on which this notice is served on you.
You may have legal rights to defeat the judgment or to prevent your
money or property from being taken. YOU MUST FILE A PETITION SEEKING
RELIEF FROM THE JUDGMENT AND PRESENT IT TO A JUDGE WITHIN
THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS NOTICE IS SERVED ON
YOU OR YOU MAY LOSE YOUR RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR
NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
FREY, PETRAKIS, DEEB, BLUM
8s BRIGGS, P.C.
By: & 6*Vj e ? ?
Frank G. Murphy, E uire
Christina M. Hughes, Esquire
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R.
Real Estate, LLC
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
Dated: ";X0
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/9163
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
HOME ELITE LTD., INC. and
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046
Plaintiffs,
V.
HONG TSANG,
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant. :
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R.
Real Estate, LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION - LAW
Docket No.
NOTICE UNDER 42 PA. C.S.A. 9 2737.1
To: HONG TSANG,
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
A judgment in the amount of $7,839.38 (principal sum plus reasonable
attorneys' fees) has been entered against you and in favor of the Plaintiffs
without any prior notice or hearing based on a confession of judgment
contained in a written agreement or other paper allegedly signed by you.
42 Pa. C.S.A. § 2737 states in part as follows:
A debtor who has been incorrectly identified and had a confession
or judgment entered against him may petition the court for costs
and reasonable attorney fees as determined by the court.
The written instructions regarding the procedure to follow to strike the
judgments are not prescribed in detail. For this reason, you should contact an
attorney for assistance. However, you are advised that Pa. R.C.P. 2959,
provides as follows:
Striking Off or Opening Judgment; Pleadings; Procedure
(a)(1) Relief from a judgment by confession shall be sought by petition. Except
as provided in subparagraph (2), all grounds for relief whether to strike
off the judgment or to open it must be asserted in a single petition. The
petition may be filed in the county in which the judgment was originally
entered, in any county which the judgment has been transferred or in
any other county in which the sheriff has received a writ of execution
directed to the sheriff to enforce the judgment
(2) The ground that the waiver of the due process rights of notice and
hearing was not voluntary, intelligent and knowing shall be raised only
(i) in support of a further request for a stay of execution where
the court has been stayed execution despite the timely filing of a petition
for relief from the judgment and the presentation of prima facie evidence
of a defense; and
(ii) as provided by Rule [of Civil Procedure] 2958.3 or Rule
2973.3.
(3) If written notice is served upon the petitioner pursuant to Rule [of
Civil Procedure] 2956.1(c)(2)or Rule [of Civil Procedure] 2973.1(c), the
petition shall be filed within thirty days after such service. Unless the
Defendant can demonstrate that there were compelling reasons for the
delay, a petition not timely filed shall be denied.
(b) If the petition states prima facie grounds for relief the court shall issue a
rule to show cause and may grant a stay of proceedings. After being served
with a copy of the petition the Plaintiff shall file an answer on or before the
return day of the rule. The return day of the rule shall be fixed by the court by
local rule or special order.
(c) A party waives all defenses and objections which are not included
in the petition or answer.
(d) The petition and the rule to show cause and the answer shall be
served as provided in Rule [of Civil Procedure] 440.
(e) The Court shall dispose of the rule on petition and answer, and on any
testimony, depositions, admissions and other evidence. The court for cause
shown may stay proceedings on the petition insofar as it seeks to open the
judgment pending disposition of the application to strike off the judgment. If
evidence is produced which in a jury trial would require the issues to be
submitted to the jury the court shall open judgment.
(f The lien of the judgment or of any levy or attachment shall be preserved
while the proceedings to strike off or open the judgment are pending.
(g)(1) A judgment shall not be stricken or opened because of a creditor's failure
to provide a debtor with instructions imposed by an existing statute, if
any, regarding procedures to follow to strike a judgment or regarding any
rights available to an incorrectly identified debtor.
(2) Subdivision (g) (1) shall apply to (1) judgments entered prior to the
effective date of subdivision (g) which have not been stricken or opened
as of the effective date and (2) judgments entered on or after the effective
date.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IT YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR
NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
FREY, PETRAKIS, DEEB, BLUM
Ss BRIGGS, P.C.
By:
'4'-
Frank G. Murphy, uire
Christina M. Hughes, Esquire
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R.
Real Estate, LLC
1601 Market Street, 26th Floor
Philadelphia, PA 19103
?f/w/0o (215) 563-0500
Dated: !
?X?ibi+ ?
FREY, PETRAKIS, DEER, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/91635
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
HOME ELITE LTD., INC. and
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046
Plaintiffs,
V.
HONG TSANG,
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant.
AFFIDAVIT
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and
P.R. Real Estate, LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION - LAW
Docket No.
: SS.
being duly sworn according to law, deposes and
says that N1AJ(Ly D-?( is authorized to make this affidavit on
behalf of Home Elite Ltd., Inc. and P.R. Real Estate, LLC; that Pintzuk Brown
Realty Group is an authorized agent of and authorized to act on behalf of Home
Elite Ltd., Inc. and P.R. Real Estate, LLC, as concerns the property owned by
Home Elite Ltd., Inc. and P.R. Real Estate, LLC as tenants in common at East
Gate Plaza, located at 5205 Simpson Ferry Road, Mechanicsburg, PA 17055.
Sworn to and Subscribed
before me this %4-k day Signed:
of N)6w- , 2006. ?c-'vz t: b °r^EL
Name (printe ):
Notary Public n c F ??? ?-
Title:
Daaiel R- Hen&"m?Notay ?
ltarinWwa Towas6i M ?lblic
P, 0ft7 covoty
My commission expires May 14, 2009
?xh?bi+ J3
10/09/92:10:42am:kac r`l.doc
J r
LEASE
Between
WESLEY ASSOCIATES,
Landlord
and
Say Quan Ly,
Tenant
TDBA CHINA WOK
10/09/92:10:42am:kac- l _doc
TABLE OF CONTENTS
Paae
ARTICLE 1 - Premises
ARTICLE
2 -
Construction and Improvements
. •
. . .
. . .
. . 1
.
ARTICLE
3 - _
_
Advertising Signs . .
.
• .
• 1
ARTICLE
4 - .
Common Area . .
•
. . . . . . . 1
ARTICLE
5 - . . . . . . . .
Contributions . .
. . . . . . . 2
.
ARTICLE
6 - . . .
Term • . . . . . 3
ARTICLE
7 - . . . . .
Rent and Late Payment Charge • . • • • •
. . . . . . 4
• 5
ARTICLE 8 - . .
Interest . .
ARTICLE
9 - . . . . . . . . . . .
. . .
Renewal
. 6
ARTICLE
10 . . . . . . . .
.
. .
. . .
- Rental Escalation . 6
ARTICLE
11 . . . . . . . .
- Taxes and Assessments
• • • • • 7
.
ARTICLE
12 . . . . .
- Tenant's Share of Taxes and Assessments. . • • 7
• 7
ARTICLE 13 - Use and Operations .
. .
ARTICLE
14 . . . . .
- Utilities
. . . . _ . 8
'
ARTICLE
15 .
, . . .
- Assignment and Subletting . .
. 8
ARTICLE
16 .
- Fire Insurance .
.
• • . • . . . 9
•
ARTICLE
17 . . .
- Increased Insurance Cost
• 10
ARTICLE
18 . . .
- Landlord's Right to Cure Tenant's •Defaults . 10
10
ARTICLE 19 - Liability Insurance and Indemnification • • 11
ARTICLE 20 - Tenant's Share of Landlord's Insurance Costs . 12
ARTICLE 21 .
- Waiver of Liability . .
ARTICLE
22 . . . . .
- Repair and Maintenance
• • . • 13
•
ARTICLE
23 . . .
- Alterations • . . •
• • 13
.
ARTICLE
24
- Surrender of the Demised Premises • • . •
. 15
16
ARTICLE 25 - Waste or Nuisance
• • •
ARTICLE
26 . . . . . . .
- Governmental Regulations . . . . • . .
. • • . . 16
• 17
ARTICLE 27 - Warranties . .
ARTICLE
28 . . . . . . . .
- Trade Fixtures
. • . • • 17
•
ARTICLE
29 . . , , , . . . .
- Access of Landlord
• • 17
.
ARTICLE
30 . . . . . . .
- Default by Tenant .
. • . . . 17
.
ARTICLE
31 . . . . . . . .
- Damage or Destruction
• • • • • 18
.
ARTICLE
32 . . . . .
- Hazardous Substances
. • . • • • 23
•
ARTICLE
33 . . . .
- Eminent Domain
• •
. • • • • . 24
•
ARTICLE
34 . . . . . . . .
- Subordination
. . . • . . 26
•
ARTICLE
35 , , , , . .
- Relationship of•Parties
. . • 27
•
ARTICLE
36 . . .
- Definitions
. . . . • 28
.
ARTICLE
37 , . .
- Accord and Satisfaction • • . 28
•
ARTICLE
38 .
. . . . . .
- Quiet Enjoyment . . . 29
ARTICLE
39 . . . . .
- Holding over . . .
.
• • . • • • . 29
•
ARTICLE
40 . . . _
Recording . . . .
• • • • 29
.
ARTICLE
41 . . . . .
. .
- Delays . . . . . .
• • . . . 30
ARTICLE
42 . . . . . .
- Captions
• . 30
.
ARTICLE
43 . . . . . .
- Partial Invalidity and Construction
. . 30
30
ARTICLE 44 - Binding Effect .
. .
ARTICLE-
45 - . . . . . .
Arbitration
. • . • 30
ARTICLE
46 - . . . . . . . . .
Notices .
. .
. • • 31
ARTICLE
47 - . . . . • .
Commissions Due Real Estate Broker . • • • 31
31
ARTICLE 48 - Exhibits
. . . . . . . . . . . . . . . . . . . . 32
- i -
10/09/92:10:42am:kac7^lI,doc
ARTICLE 49 - Entire Agreement
ARTICLE
50
- Security Deposit _ 32
. .
ARTICLE
51
- Limitation Upon Landlord's Liability . . . 32
.
32
ARTICLE 52 - Time of the Essence . .
Exhibit
A - . . . . .
SITE PLAN . . . 33
• •
EXHIBIT
B - . . . . . . . .
SIGNAGE . . . 34
. . . . . . . . . . . . . . . . . . 35
- ii -
10/09/92:10:42am:kac:O
T.doc
AGREEMENT OF LEASE
THIS AGREEMENT OF LEASE, made this - day of October,
1992, by and between WESLEY ASSOCIATES, having a place of business
at C/O Bennett Williams, Inc.135 North George Street, York,
Pennsylvania 17401, its successors or assigns (hereinafter called
Landlord"), and Say Quan Ly, tdba China Wok, having a mailing
address of 5205 Simpson Ferry Road, Mechanicsburg, Pennsylvania
17055, its successors or assigns (hereinafter called "Tenant").
W I T N E S S E T H:
ARTICLE 1 - Premises
(a) In consideration of the rents and covenants herein
set forth on the part of the Tenant to be paid, performed and
observed, the Landlord does hereby lease the premises (hereinafter
referred to as "Demised Premises") within the Eastgate Plaza
(hereinafter referred to as the "Shopping Center") situated in
Hampden Township, New Cumberland, Pennsylvania.
(b) The Shopping Center consists of the land (and all
improvements that are to be constructed thereon) as shown. on
Exhibit A attached hereto.
(c) The purpose of Exhibit A is to show the location of
the Demised Premises and the entrances and exits for the Shopping
Center. Landlord reserves the right, at any time, to relocate,
modify, eliminate or add to the various buildings, stores and other
improvements, whether or not shown on Exhibit A, provided that
Landlord shall not materially interfere with access to the Demised
Premises.
(d) The Demised Premises consists of the retail space
designated as Store #K & L, as shown on Exhibit A containing
approximately 3,200 square feet, measured to the center line of all
party or common walls, and to the exterior faces of all other
walls.
ARTICLE 2 - Construction and Improvements
Tenant agrees to take the space "As Is".
ARTICLE 3 - Advertising signs
(a) All signage is subject to Townships and local
municipalities approval.
(b) Tenant shall have the right to incorporate its trade
name or store identification within the area or areas provided for
by Landlord; provided, however, that any such signs shall strictly
10/09/92:10:42am:kac:cjq,doc
conform in color, style, design and in all other respects to the
criteria established by Landlord for the Shopping Center. No other
exterior sign or advertising will be permitted by Tenant, outside
of the Demised Premises or the Shopping Center. However, Landlord
acknowledges the difference between "temporary point-of-sale mate-
rial" and permanent advertising signs, and permission for this type
of temporary advertising on glass area of the store front is
granted to Tenant, provided said advertising is in good taste and
professional in appearance. Landlord shall approve all signs such
approval not to be unreasonably withheld.
follows: (c) Approval for location and dimension of signs is as
(1) Front of building - See sign criteria.
ARTICLE 4 - Common Area
(a) All those portions of the Shopping Center not shown
as building areas on Exhibit A shall be "Common Areas". Tenant
shall have the right to use the Common Areas but Tenant's right to
use the Common Area is not exclusive to Tenant, but shall be for
the common use of Tenant and the other tenants and lawful occupants
of the Shopping center and their employees, agents, customers,
licensees and invitees and parties with whom they do business. The
Common Area shall also be for the location and maintenance therein
of all the utilities, services and other installations serving the
buildings in the Shopping Center and with Landlord's prior written
permission for special promotional-type activities and events for
the Shopping Center. Landlord, or its designee, and the other ten-
ants and lawful occupants of the Shopping Center, shall also have
the right to go over and on the Common Area with men and materials
as reasonably required to construct, repair and alter any buildings
in the Shopping center, provided that such persons shall not
thereby unreasonably interfere with Tenant's use of the Demised
Premises.
(b) Except as otherwise provided in this Lease, and as
they may otherwise hereafter agree in writing, the parties hereto
shall not:
(1) Obstruct the free passage of vehicles to and
from the entrances of the Shopping Center.
(2) Interfere with the installations in the Common
Areas which are for the service of the building and the
Shopping Center.
(c) Landlord agrees, as hereinafter set forth:
(1) To maintain and keep in good repair all por-
tions of the Common Area, including, but not limited to
any and all roads, driveways, curbs, culverts, drainage
- 2 -
10/09/92:10:42am:kac:^(q.doc _
facilities, surfacing, landscaping, fences, gates,
directional and Shopping Center signs, grading, paving
marking of the parking area, plumbing systems, sewer and
sewage disposal lines, water supply lines, sprinkler
lines and other requisite services and utility lines,
pipes and installations of every kind.
(2) To keep the Common Area open for use and
adequately lighted for a period of at least thirty (30)
minutes prior to and until (30) minutes subsequent to the
operating hours of the Shopping Center.
(3) To keep the sidewalks and curbs, adjacent to
and immediately in front of the Demised Premises and
throughout the Shopping Center, reasonably free from
accumulated snow, ice and refuse and to comply with all
governmental requirements respecting same.
(d) The Landlord shall have the right to make changes,
additions, alterations, or improvements in the Common Area, pro-
vided that, other than temporary inconvenience necessitated by
construction activities, there shall be no unreasonable obstruction
of Tenant's right of access to the Demised Premises or any unrea-
sonable interference with Tenant's use thereof.
ARTICLE 5 - Contributions
(a) Tenant agrees to pay to the Landlord, as additional
rent, Tenant's Share of the Cost of maintenance and operation of
the Common Area.
(b) Tenant's Share of the Cost of the maintenance and
operation of the Common Area shall be determined by the following
formula:
The number of square feet of floor area in the
Demised Premises (3,200 square feet) shall be multiplied
by the fraction, the numerator of which shall be the
total cost of the maintenance and operation of the Common
Area, and the denominator of which shall be the sum of
the total leasable building area in the Shopping Center
(36,000 square feet).
(c) Tenant's Common Area maintenance contribution shall
be paid within thirty (30) days after receipt of a Landlord's bill
therefore setting forth Tenant's share of the Common Area contribu-
tion. Tenant shall be invoiced monthly or, at Landlord's discre-
tion, quarterly, semi-annually or annually. Within sixty (60) days
following the end of each calendar year, Landlord will deliver to
Tenant an itemized breakdown of the Common Area maintenance charges
signed by Landlord or a duly authorized agent of Landlord.
- 3 -
10/09/92:10:42am:kac:I F.doc
(d) During any part of the term hereof, which shall be
less than the full annual period used to compute Tenant's share of
the cost of the maintenance and operation of the Common Area, any
Common Area contribution payable by Tenant shall be prorated on a
daily basis to the end that Tenant shall only pay the contribution
attributable to that fractional part of the annual period occurring
within the term of this Lease.
(e) The cost of the maintenance and operation of the
Common Area shall mean the total costs and expenses incurred in
operating and maintaining the Common Area, including, without limi-
tation, compensation to a management company equal to four percent
(40) of the gross rents received from all tenants; Christmas or
other seasonal decorations; gardening and landscaping; gIgn insur-
ance, replacement, repairs and maintenance of all parts of the
Common Area, including restriping and repaving of the parking area;
lighting; rental of signs and equipment; sanitary control; removal
of snow and ice; and all other similar direct costs, charges and
expenses resulting from the maintenance and operation of the Common
Area, including the cost of removing Tenant's trash.
(f) The various costs of the maintenance and operation
of the Common Area shall not exceed the costs incurred in connec-
tion with the operation of first class shopping center common areas
in the Hampden Township, New Cumberland, Pennsylvania business
area.
ARTICLE 6 - Term
(a) The term and rental of this Lease shall be for a
period of -(? years, and shall commence upon the earlier of:
C
(i??
1) The new rental shall commence Felgrua*y 1, 1993.
Tenant will pay rent of $1,333.33 per month until that
timer eXcev+ +ke, - NaV*_IKbec- mck-L ?-? - wit( P-,Y 44 6 X.67_
(2) The original term of this lease will terminate
?e .
Y 2 7.00 1
(b) An instrument setting forth the date of commencement
of the term of this Lease shall be prepared by Landlord and
executed by Tenant and Landlord.
(c) The Demised Premises shall be accepted by Tenant
notwithstanding the existence of relatively minor "punch list"
items which will not prevent the Tenant from operating its business
in a normal manner. Any such "punch list" items shall continue to
be Landlord's responsibility to complete as soon as possible.
(d) A "lease year," as herein referred to, shall then
consist of that full twelve (12) month period commencing on the
first day of the first full month during which this Lease is in
full force and effect and of each full twelve (12) month period
- 4 -
10/09/92:10:42am:kac-"1'1-doc
' thereafter. If the commencement date of this Lease, as provided as
af-oresaid, is a day not the first day of the month, the first lease
year shall consist of the remainder of that first month and of the
first full twelve (12) months thereafter.
(e) If the Landlord notifies the Tenant that the Demised
Premises is ready for possession and the Demised Premises is ready
for possession, and the Tenant fails to take possession and to open
the Demised Premises for business fully fixtured, stocked and
staffed within sixty (60) days from the date of said notice then
the Landlord may, in addition to any and all remedies herein
provided, at its option, collect not only the minimum rent herein
provided, but additional rent at the rate of one-fifteenth (1/15)
of the fixed minimum monthly rental per day for each and every day
that the Tenant shall fail to commence to do business as herein
provided. Said additional rental shall be deemed to be in. lieu of
any percentage rent that might have been earned during such period
of Tenant's failure to open.
ARTICLE 7 - Rent and Late Pa ent Charge
(a) Tenant agrees to pay Landlord, each month, during
the term hereof, a Fixed Monthly Rental for the Demised Premises,
as follows:
Year Rental
Monthly
Year
1
2 $2,200.00
$26,400.00'15
$2,200.00 t'
$28
400.00 qi
3
4 $2,300.00 ,
$27,600.001
9
5
5 $2,500.00 $30,000.004}
$2,500.00 $30,000.00
7 $2,616.00 $31,392.00
8 $2,695.00 $32,340.00
9 $2,775.00 $33,300.00
10 $2,859.00 $34,308.00 0
$2,944.00 $35,328.00 Q
plus all cumulative increments produced by the Rental Escalation
Articles as hereinafter set forth, per month in advance without
offset or demand. Payment shall be made to the Landlord at the
place hereinafter specified for the giving of notices to Landlord
or at such other places as Landlord shall designate in writing.
(b) The Minimum Annual Rent shall be the product of the
Fixed Monthly Rental, as adjusted, multiplied by twelve (12).
Following any adjustment for Rental Escalation, the Fixed Monthly
Rental shall be the quotient of the Minimum Annual Rent divided by
twelve (12).
c In the event the a day other than the first ay ofmthecmonth, d hen in that e events
- 5 -
' the rent for the balance of that month shall be determined by
multiplying the aforementioned monthly rental by the fraction, the
numerator of which is the number of days remaining in that month,
and the denominator of which is the total number of days in that
month. The result of the above computation shall be paid to the
Landlord on or prior to such commencement date.
(d) In addition to any other rights or remedies given to
Landlord, in the event Tenant fails to make payment of its regular
monthly rental payment by the fifth day of the month, or fails to
make any payment when due of additional rent due hereunder, Tenant
shall pay to Landlord the additional sum of five percent (5%) of
the amount due as a late payment charge, which late payment charge
shall become additional rent.
(e) The first rental year of this Lease shall commence
on the first day of the term and shall end at the close of the
twelfth full calendar month of the Term; thereafter, such rental
year shall consist of periods of twelve (12) full calendar months
commencing with each anniversary of the first day of the first full
calendar month of the term.
(f) All rents payable and all statements deliverable by
Tenant to Landlord under this Lease shall be paid and delivered to
WESLEY ASSOCIATES, C/O Bennett Williams, Inc., 135 North George
Street, York, Pennsylvania 17401.
ARTICLE 8 - Interest
Wherever in this Lease there is a provision that Tenant
shall be liable for the payment of any sum to Landlord, together
with interest thereon, or whenever Tenant shall fail to pay any sum
when due, such sum shall bear interest until paid at a rate equal
to the greater of:
r
(1) The prime rate of interest charged by the York
Bank & Trust Company of. York, Pennsylvania, or its
successors, plus two percent (2%); or
(2) Six percent (6%) per annum; but, in no event
shall the rate be greater than the legal rate of interest
which may be charged to borrowers of the same character
as Tenant.
ARTICLE 9 - Renewal
(a) Provided Tenant has complied with all the terms and
conditions of this Lease, then Tenant shall have the option to
renew this Lease for one (1) successive additional period(s) of
five (5) years after the expiration of the original term hereof on
the same terms and conditions as herein provided, except, however,
- 6 -
10109/92:10:42am:kac:1j n.doc
that the fixed minimum rent shall be increased pursuant to the
Rental Escalation Article hereinafter set forth.
(b) Such options to renew shall be deemed to be exer-
cised by Tenant at the end of the original five (5) year term,
unless Tenant shall notify Landlord in writing of its intention not
to renew its Lease at least six (6) months before the end of the
original term.
ARTICLE 10 - Rental Escalation
V`hS`11??;U Ori?? '7?dC/?hnvaC(y 7?iece4,?.
TICLE 11 - Taxes and Assessmexts /
(a) Subject to the reimbursement provisions of Article
12, all Real Estate Taxes, as hereinafter defined, on the land and
the buildings in the Shopping Center shall be paid by the Landlord.
(b) Tenant shall pay any and all taxes, assessments or
charges which may be levied upon or attributable to goods or
merchandise or fixtures or other items and improvements placed upon
and in the Demised Premises by Tenant.
(c) The term "Real Estates Taxes" shall mean and include
all real estate taxes, assessments, water and sewer rents and other
governmental impositions and charges of every kind and nature what-
soever, special as well as regular, extraordinary as well as ordin-
ary, foreseen and unforeseen, and each and every installment there-
of, which shall or may during the Lease term be levied, assessed,
imposed, become due and payable, or liens upon, or arising in
connection with the use, rental, occupancy or possession of, or
growing due and payable out of, or for the Shopping Center or any
part thereof, on any land, building, other improvements, or any
leasehold interest thereto, or any payments made by Landlord in
lieu of any of the foregoing. Such term shall not include any
charge, such as water meter charges or any sewer rent based there-
on, which is measured by the consumption by the actual user of
service for which the charge is made. Whether or not the Landlord
shall take the benefit of the provisions of any statute or ordin-
ance permitting any assessment for public betterments or improve-
ments to be paid over a period of time, Landlord shall, neverthe-
less, be deemed to have taken such benefit so that the "Real Estate
Taxes" shall include only the current annual installment of any
such assessment and the interest on unpaid installments.
ARTICLE 12 - Tenant's Share of Taxes and Assessments
(a) Tenant agrees to pay to Landlord each year during
the term hereof, on demand, as additional rent, Tenant's Share of
Real Estate Taxes, as hereinafter described.
- 7 -
10/09/92:10:42am:kac:9-- 10C
(b) Tenant's Share of Real Estate Taxes shall be
computed as follows:
(1) The total Real Estate Taxes payable for the
Shopping Center, as shown on Exhibit A, shall be divided
by the total number of square feet of leasable retail
floor area (36,000 square feet) of the Shopping Center.
(2) The result of Step (1) shall be multiplied by
number of square feet in the Demised Premises (3,200
square feet), and the result of Step (2) shall be the
amount of Tenant's Share of Real Estate Taxes.
(c) Tenant shall pay to the Landlord Tenant's Share of
Real Estate Taxes, as herein defined, within fifteen (15) days
after receipt by Tenant of a bill from Landlord setting forth
Tenant's Share of Real Estate Taxes. Landlord may bill from time
to time as such expenses are incurred.
ARTICLE 13 - Use and Operations
(a) Tenant shall use and occupy the Demised Premises
solely as a chinese restaurant, trading and doing business under
the name of CHINA WOK or such other trade name as Landlord may
approve in writing.
(b) Tenant shall operate its business in all of the
Demised Premises continuously, actively and diligently during the
entire term of this Lease and shall at all times keep the Demised
Premises fully equipped and fixtured and shall maintain a fall
inventory of merchandise. Tenant shall keep the Demised Premises
open for business and adequately staffed during the regular and
customary days and hours for the operation of similar stores in the
business area of Hampden Township, New Cumberland, Pennsylvania,
except during periods the Demised Premises may be untenantable by
reason of fire or other unavoidable casualty or causes. Tenant
shall use for clerical offices or other non-selling purposes only
such space in the Demised Premises as is from time to time
reasonably required for conduct of Tenant's business at the Demised
Premises.
(c) Without the prior written approval of Landlord, in
Landlord's sole discretion, Tenant shall not display or sell goods
or merchandise in the Common Areas or otherwise outside of the
Demised Premises.
ARTICLE 14 - Utilities
(a) The Landlord agrees that, during the term of this
Lease or any extensions thereof, the Demised Premises shall, at all
times, be connected to the electric, gas, water and sewer lines or
systems, as applicable, serving the Shopping Center.
- 8 -
10/09/92:10:42am:kac:T .doc
1__
(b) Landlord shall not be liable to Tenant for the
failure of any of the above utility services. However, Landlord
agrees, in the event of any suspension or failure of service, to
proceed with all due diligence to restore or cause the restoration
of such services as soon as is reasonably practical under the cir-
cumstances. Tenant will not hold Landlord responsible if the gas
to the Demised Premises becomes unavailable, nor will Tenant hold
Landlord responsible for any equipment conversion or installation
costs caused by such unavailability of gas.
(c) Landlord agrees that the connections of the elec-
tric, gas, water and sewer.lines will be brought to the Demised
Premises to the points designated, in accordance with Exhibit ?.
(d) Tenant shall promptly pay, as the same becomes due,
all bills for telephone services, gas, electricity, fuel, oil,
water, sewer and similar utilities consumed on or applicable to the
Demised Premises.
ARTICLE 15 --Assignment and Subletting
(a) Tenant shall not, during the term of this Lease or
extension thereof, assign, transfer, mortgage, pledge or otherwise
encumber this Lease or the leasehold estate created hereby or any
part of Tenant's title hereto or interest herein, in whole or in
part, nor shall Tenant sublease the -Demised Premises, in whole or
in part, without the prior written consent of Landlord., in Land-
lord's sole discretion. In the event of any such assignment or
subletting with the consent of Landlord, Tenant will nevertheless
remain liable for the performance of all the terms, covenants and
conditions. of this Lease and, in addition, will require any as-
signees or sublease to execute and deliver to Landlord an assump-
tion of liability agreement in form acceptable to Landlord as a
condition precedent to the assigning or subletting. Consent by
Landlord to any assignment or subletting shall not constitute a
waiver of the requirement of such consent to any subsequent assign-
ment or subletting. Any assignment by operation of law, attachment
or assignment for the benefit of creditors shall, at Landlord's
option, be inoperative. An assignment within the meaning of this
paragraph shall be deemed to include one or more sales or trans-
fers, by operation of law or otherwise, or creation of new stock,
by which an aggregate of more than fifty percent (50%) of Tenant's
stock, if Tenant is a corporation, of the ownership interest of
Tenant, if Tenant is another form of entity, shall be vested in a
party or parties who are non-stockholders or non-owners as of the
date hereof.
(b) The interest of the Landlord herein may be assigned
in whole and also in one or more parts. In the case of any such
assignment, the Landlord shall advise the Tenant of the name or
names of the assignee or assignees, and Landlord shall have no
liability hereunder from and after the effective date of any such
- 9 -
10109/92:10:42am:kac:'I doc
assignment, except for obligations which may have theretofore
accrued.
ARTICLE 16 - Fire Insurance
(a) Landlord agrees throughout the term of this Lease
and any extensions thereof to carry fire and extended insurance
coverage on the Demised Premises in an amount not less than the
actual replacement value without deducting physical depreciation on
the building, but exclusive of costs of excavation, foundations and
footings below the underside of the lowest floor, if excluded by
the policy, to the extent of Landlord's work as set forth in this
Lease.
(b) Tenant agrees throughout the term of this Lease and
extensions thereof to carry fire and extended insurance coverage in
an amount equal to the replacement cost of fixtures, normal inven-
tory and leasehold improvements in the Demised Premises, including,
but not limited to any improvements installed at Tenant's expense.
Such insurance may be included in a blanket policy or policies.
ARTICLE 17 - Increased Insurance Cost
Tenant shall comply with all laws and ordinances and
recommendations of the Association of Fire Underwriters and will
not do, nor permit anything to be done, nor neglect to do anything,
nor bring nor keep nor permit anything to be brought into or kept
on the Demised Premises which shall cause an increase beyond normal
premiums that may be charged during the term of this Lease on any
public liability, casualty, fire and extended coverage insurance
carried on the Demised Premises or the Shopping Center. If, by any
reason of any act or omission of Tenant, the insurance premiums are
increased beyond normal premiums, Tenant shall pay as additional
rent hereunder the amount of such increased premiums. A schedule
issued by the organization establishing the insurance rate on the
Shopping Center, showing the component of such rate, shall be
conclusive evidence of the amount of such increased premiums.
ARTICLE 18 - Landlord's Right to Cure Tenant's Defaults
Tenant agrees that, if Tenant fails to make any. repairs
or do any work required of the Tenant by the provisions of this
Lease, or if Tenant shall in any other respect fail to perform any
covenant or agreement in this Lease contained on the part of the
Tenant to be performed, then, and in any such event, after the
continuance of any such failure or default for ten (10) days after
notice in writing thereof is given by the Landlord to the Tenant,
notwithstanding any delay or forbearance in giving such notice,
Landlord may cure such.defaults, all on behalf of and at the ex-
pense of. the Tenant, and shall have a right of entry into the
Demised Premises for such purposes. Landlord may further do all
- 10 -
10/09/92:10:42am:kac-j'I.doc
'necessary work and. make all necessary payments in connection there-
with, including, but not limiting the same, to the payment of any
attorney's fees and costs and charges of or in connection with any
legal action which may have been brought. Tenant agrees to pay to
Landlord forthwith any amount so paid by Landlord. All sums
charged to Tenant by Landlord hereunder shall be indebtedness of
Tenant to Landlord and shall become due as additional rents.
ARTICLE 19 - Liability Insurance and Indemnification
(a) Throughout the term of this Lease and any extensions
thereof, Tenant shall obtain, maintain and pay for policies of
comprehensive general liability (including products liability)
insurance covering the Demised Premises, the business operated by
Tenant in and from the Demised Premises and the contractual lia-
bility of Tenant under this Lease in form and with insurers
satisfactory to Landlord in amounts required by Landlord's mort-
gagees, from time to time, but not less than Five Hundred Thousand
($500, 000.00).Dollars with respect to property damage, Five Hundred
Thousand ($500,000.00) Dollars with respect to death or personal
injuries to any one (1) person, and One Million ($1,000.000.00)
Dollars arising out of any one (1) occurrence. Such insurance may
be included in a blanket policy or policies.
(b) All insurance policies required to be maintained by
Tenant under this Lease shall be with insurance companies licensed
to do business in the State of Pennsylvania and satisfactory to
Landlord and shall protect both Landlord, Landlord's mortgagees and
Tenant, as their respective interests may appear. Certificates of
such insurance shall be delivered to Landlord a minimum of thirty
(30) days prior to possession of the Demised Premises by Tenant
with renewals thereof delivered to Landlords a minimum of thirty
(30) days prior to the expiration of any such policies. If re-
quested to do so, Tenant shall also provide Landlord with copies of
the pertinent portions of all such policies and shall also permit
Landlord to examine the original policies. Each policy and certif-
icate evidencing the same shall contain an agreement by the insurer
that such policy shall not be cancelled or modified without ten
(10) days' written notice to Landlord and that no act or omission
of Tenant shall invalidate the interest of Landlord under such
insurance. If Tenant fails to obtain and maintain any such insur-
ance or to deliver any of the certificates as required in this
Lease, Landlord may, in addition to any other remedy under this
Lease, procure such insurance at the expense of Tenant and pay the
cost thereof. Such cost shall be deemed additional rent and shall
be payable by Tenant to Landlord immediately upon demand, together
with interest until paid.
(c) During the term of this Lease or any extension here-
of, Tenant hereby agrees to indemnify and hold Landlord and Land-
lord's mortgage lenders harmless from any and all claims and
demands arising out of the negligent acts or omissions of Tenant,
its officers and employees, and resulting in the loss of or damage
- 11 -
10/09/92:10:42am:kac:OF doc
to property or for injury to or death of any person while in, upon
or about said Demised Premises.
(d) Landlord covenants and agrees that it shall maintain
a comprehensive policy of general liability insuring Landlord, Land-
lord's mortgagees and Tenant, as additional insured, against any
liability occasioned by accident on or about any portion of the
Common Area of the Shopping Center, which insurance shall protect
the interest of Tenant against any liability whatsoever, except
such as shall arise out of Tenant's agents, employees or servants,
licensees or invitees, or any contract of Tenant, or by default of
Tenant under this Lease. The aforesaid liability policy shall be
written by good and solvent insurance companies duly licensed to do
business in the State of Pennsylvania and shall be in amounts not
less than Five Hundred Thousand ($500,000.00) Dollars with respect
to property damages, One Million Dollars ($1,000,000.00) Dollars
with respect to death or personal injury to any one (1) person, and
Five Million ($5,000,000.00) Dollars with respect to death or per-
sonal injuries out of any one (1) occurrence. Such insurance may
be carried under a blanket policy covering other-locations of Land-
lord, provided the protection and coverage afforded Tenant is not
reduced thereby. Landlord agrees to deliver to Tenant at least ten
(10) days prior to the time such liability insurance is first
required to be carried by Landlord and, thereafter, at least thirty
(30) days prior to the expiration of any such policy, either a
duplicate original or a certificate of all policies procured by
Landlord in compliance with its obligations hereunder.
ARTICLE 20 - Tenant's Share of Landlord's Insurance Costs
(a) Tenant agrees to pay to Landlord each year during
the term hereof, on demand, as additional rent, Tenant's Share of
the Landlord's insurance costs as set forth in Article 16(a) and
Article 19(d) or any place else in this Agreement as hereinafter
described.
(b) Tenant's Share of Landlord's insurance costs shall
be computed as follows:
(1) The total of Landlord's insurance costs, pay-
able for the Shopping Center, as shown on Exhibit A shall
be divided by the total number of square feet of leasable
retail floor area (36,000 square feet) of the Shopping
Center.
(2) The result of Step (1) shall be multiplied by
the number of square feet in the Demised Premises (3,200
square feet), and the result of Step (2) shall be the
amount of Tenant's Share of insurance costs.
(c) Tenant shall pay to the Landlord, Tenant's Share of
Landlord's insurance costs as herein defined, within fifteen (15)
days after receipt by Tenant of a bill from Landlord setting forth
- 12 -
10/09/92:10:42am:kac:9j- doc
Tenant's Share of Landlord's insurance expense and, if requested by
Tenant, proof of payment by Landlord of such expenses. Landlord
may bill from time to time as such expenses are incurred.
ARTICLE 21 - Waiver of Liability
(a) Notwithstanding anything in this Lease to the con-
trary, Tenant shall not be liable to Landlord or to any insurance
company insuring Landlord for any loss or damage to the Demised
Premises or to any improvement or property located within the
entire Shopping Center which was covered by fire and extended
coverage insurance even though such loss or damage may have been
occasioned by the negligence of Tenant, its agents or employees.
(b) Conversely, anything in this Lease to the contrary
notwithstanding, Landlord shall not be liable to Tenant or any
insurance company insuring Tenant for any loss or damage to any
property of Tenant located within the entire Shopping Center which
was or could have been covered by fire and extended coverage insur-
ance even though such loss or damage. may have been occasioned by
the negligence of Landlord or its agents or employees.
(c) The parties hereto agree that their policies will
include such waiver, clause or endorsement so long as available and
so long as the other party pays such extra cost. If extra cost
shall be chargeable therefore, each party-shall advise the other of
the amount of the extra cost, and the other party, at its election,
may pay the same, but shall not be obligated to do so, in which
case there shall be no-.waiver by either party.
ARTICLE 22 - Repair and Maintenance
(a) Tenant shall at all times maintain the Demised Pre-
mises (including the inside and outside of all exterior entrances,
store front and the glass and-moldings in the doors and windows)
and all partitions, doors,-'fixtures, equipment and appurtenances
thereof, in good order, condition and.repair and including reasona-
ble periodic painting, making proper replacements when necessary,
all at its own expense,' except. for structural portions of the roof,
foundation, exterior walls, structural floors, ceiling supports,
all outside electrical service to the building and the outside por-
tion of the water and sewer lines, which shall be maintained by
Landlord; but, if Landlord is required to make repairs by reason of
Tenant's willful or negligent acts or omissions to act, the cost of
such repairs shall be paid by Tenant and shall thereafter become
due as additional rent.
(b) All electrical and plumbing systems and fixtures,
heating and air conditioning systems shall be maintained by Land-
lord, except that Tenant shall be responsible for ordinary main-
tenance of RVAC, plumbing and electrical systems, such as replace-
ment of filters and seasonal maintenance. Notwithstanding anything
- 13 -
10/09/92:10:42am:kac:T.doc
herein to the contrary, Landlord shall be responsible for broken
glass caused by the settling of the building for the first lease
year.
(c) Tenant shall maintain the Demised Premises at its
own expense in a clean, orderly and sanitary condition, free of
insects, rodents, vermin and other pests and shall not permit undue
accumulation of garbage, trash, rubbish and other refuse, but shall
remove the same at its own expense and shall keep such refuse in
proper containers. Landlord shall provide and designate a place
(reasonably convenient to the Demised Premises) and manner for
picking up refuse and garbage, and Tenant shall use such place and
avail itself of such refuse disposal service and shall reimburse
Landlord for Tenant's proportionate share of the costs thereof.
(d) Tenant further covenants that Tenant:
(1) Will promptly replace at its own expense with
?B.?S glass of like kind and quality, and plate glass, door or
?N 5h window glass of the Demised Premises which may become
cracked or broken except as provided in Article 22(b)
above.
(2) Will not use or permit the use of any apparatus
of sound reproduction or transmission, or any musical in-
strument, in such a manner that the sound so reproduced,
transmitted or produced shall be audible beyond the con-
fines of the Demised Premises.
(3) Will keep all mechanical apparatus free of
vibrations and noise which may be transmitted beyond the
confines of the Demised Premises.
(4) Will not, without the consent in writing of
Landlord, place or maintain any merchandise or other
articles in any-vestibule or entry of the Demised Pre-
mises, on the walkways adjacent thereto, or elsewhere on
the exterior thereof.
(5) Will keep the Demised Premises at a temperature
sufficiently high to prevent the freezing of water and
pipes and fixtures.
(6) Will not use the plumbing facilities for any
purpose than that for which they are constructed and will
not permit any foreign substance of any kind to be thrown
therein. The expense of repairing any stoppage, seepage
or damage, whether occurring on or off the Demised Pre-
mises, resulting from a violation of this provision by
Tenant or Tenant's employees, agents or invitees, shall
be borne by Tenant. All grease traps and other plumbing
traps shall be kept clear and operable by Tenant at
Tenant's own cost and expense.
- 14 -
10/09/92:10:42am:kac:91- doc
(7) Will, notwithstanding anything in this Lease to
the contrary, be responsible for all repairs and replace-
ments to the Demised Premises necessitated by a burglary
or attempted burglary, or any illegal forcible entry into
the Demised Premises.
(8) Will comply with all laws and ordinances and
all valid rules and regulations of governmental
authorities.
(9) Will not receive or ship articles of any kind
except through facilities provided or designated for that
purpose by Landlord. Front door receiving is approved by
Landlord.
(10) Will conduct its business in the Demised Pre-
mises in all respects in a dignified manner in accordance
with standards of operation of such type of business.
(11) Will comply promptly with all reasonable rules
and regulations established by Landlord for all tenants
of the Shopping Center.
(e) If Tenant refuses or neglects to repair, replace and
maintain property as required hereunder as soon as reasonably pos-
sible after written notice from Landlord to do so, Landlord may
undertake the same without liability of Landlord to Tenant for any-
loss or damages that may accrue to Tenant's merchandise, fixtures
or other property or to Tenant's business by reason thereof, pro
vided that Landlord acts reasonably in effecting such repair,
replacement and/or maintenance, Tenant shall pay, upon demand, as
additional rent, Landlord's cost and expense in effectuating the
same upon presentation of bills therefor, plus fifteen percent
(15%) for overhead and supervision. Said bills shall include
interest on said cost and expense from the date of completion by
Landlord.
ARTICLE 23 - Alterations
(a) Tenant may make any and all interior nonstructural
alterations or interior nonstructural improvements to the Demised
Premises at its sole cost and expense, provided that any such
alterations shall be made in a good, workmanlike manner and not
weaken the structure thereof, and Tenant, before commencing such
work, shall take appropriate steps to comply with all lawful
requirements, including, but not limited to procuring any and all
required governmental permits, and shall secure from its general
contractor and properly file a valid stipulation against liens (or
waiver of liens) to avoid subjecting the property of Landlord or
any portion of the Demised Premises or Shopping Center to any lien
for labor, materials or equipment supplied to any part thereof.
- 15 -
10/09/92:10:42am:kac:91T 10c
(b) Tenant shall not have the right to make any other
alterations, additions or improvements to the Demised Premises
without first obtaining, in each instance, the prior written con-
sent of Landlord, which consent (except to external alterations,
additions or improvements) may not be unreasonably withheld.
(c) Tenant shall not permit any mechanic's or other lien
or claim for lien or notice in respect thereto to be filed against
the Demised Premises or the Shopping Center or any fixtures, equip-
ment or furnishing contained therein. If any such lien or claim be
made or filed, Tenant shall, within ten (10) days after notice of
the filing thereof, cause such said lien, notice or claim for lien
to be effectively removed and discharged of record; provided, how-
ever, that Tenant shall have the right to contest the amount or
validity, in whole or in part, of any such lien, notice or claim by
appropriate proceedings, but, in any event, Tenant shall promptly
bond such lien, notice or claim with a surety company satisfactory
to Landlord and shall prosecute such proceedings with all due
diligence and dispatch. If Tenant fails to so discharge or bond
such lien, Landlord may, at its election, remove or discharge such
lien, notice or claim by paying the full amount thereof, or other-
wise, and without any investigation or contest of validity thereof,
and Tenant shall pay to Landlord, upon demand, as additional rent,
the amount paid by the Landlord, including Landlord's costs,
expenses and counsel fees.
ARTICLE 24 - Surrender of the Demised Premises
At the expiration of, or sooner termination of this
Lease, Tenant shall peaceably surrender the Demised Premises in the
same condition as they are required hereby to be kept by Tenant,
excepting normal wear and tear and any alterations and improvements
permitted by this Lease or effected with Landlord's consent. At
such time, Tenant shall surrender all keys for the Demised Premises
to Landlord at the place then fixed for payment of rent and shall
inform Landlord of all combinations on locks, safes and vaults, if
any, in the Demised Premises. Tenant shall in accordance with
Article 28 of this Lease, remove all its trade fixtures from the
Demised Premises and shall repair any damages to the Demised Pre-
mises caused thereby not later than the time hereby fixed for such
surrender.
ARTICLE 25.- Waste or Nuisance
Tenant shall not commit or suffer to be committed any
waste upon the Demised Premises. Tenant shall not commit or suffer
to be committed any nuisance or other act which may disturb the
quiet enjoyment of any other Tenant or occupant of the Shopping
Center, nor shall it engage in any activity which may reasonably be
expected to attract to the Demised Premises or to the Shopping
Center any person who might reasonably be objectionable to, disturb
-. 16 -
10/09/92:10:42am:kac:9F doc
the operation or decorum of or otherwise cause a disturbance in the
Shopping Center.
ARTICLE 26 - Governmental Requlations
Tenant shall, at Tenant's cost, comply promptly with and
observe all requirements of all federal, state and local govern-
mental authorities having jurisdiction over the Demised Premises or
the use and occupancy thereof or the operation of Tenant's
business.
ARTICLE 27 - Warranties
Landlord will pass on to Tenant all warranties applicable
to the Demised Premises and the improvements located thereon.
Landlord further agrees to unconditionally guarantee workmanship
and material for the first year following Tenant's possession of
the Demised Premises.
ARTICLE 28 - Trade Fixtures
Trade fixtures shall remain the property of Tenant and
shall be removed at -the expiration or sooner termination of the
term of this Lease or any renewal or extensions thereof, provided
Tenant shall not then be in default under any covenant or agreement
contained in this Lease and that Tenant shall have promptly re-
paired any damage to the Demised Premises caused-by such removal.
If Tenant fails to remove any such trade fixtures upon expiration
or sooner termination of this Lease, such trade fixtures shall, at
Landlord's election, be deemed abandoned and shall become the prop-
erty of Landlord, or may be removed by Landlord at Tenant's ex-
pense, which expense shall be additional rent hereunder. Lighting
fixtures, heating and air conditioning equipment, plumbing and
electrical systems and fixtures and floor covering shall not be
deemed to be trade fixtures whether installed by Tenant or by any-
one else and shall not be removed from the Demised Premises, but
shall upon installation become the property of Landlord without any
compensation to Tenant.
ARTICLE 29 - Access of Landlord
Landlord and/or its designee(s) may enter the Demised
Premises during reasonable times, from time to time, for the pur-
pose of examining or exhibiting the same or to make necessary
repairs or for the reasonable exercise of any rights granted or
reserved to Landlord pursuant to the terms of this Lease, provided
that, so long as Tenant is not in default hereunder, the making of
repairs to the Demised Premises shall not unreasonably interfere
with Tenant's use of the Demised Premises. Tenant will allow to
have placed upon the Premises at any time "For Sale" signs and,
- 17 -
10/09/92:10:42am:kac:9i doc _
during the last three (3) months of the term of this Lease, "To
Rent" signs and will not interfere with the same.
ARTICLE 30 - Default by Tenant
(a) Events of Default. The following shall be con-
sidered "Events of Default":
(1) The failure of Tenant to pay, when due, any
installment of rent or additional rent or any other sum
payable by Tenant under this Lease, which failure shall
continue unremedied by Tenant for a period of five (5)
days after written notice thereof shall have been given
to Tenant by Landlord; provided, however, that, if Tenant
defaults in making its payments of rent or additional
rent requiring Landlord's written notice on three (3)
occasions within any twelve (12) month period, then, at
Landlord's election, such third (or subsequent) default
shall not be capable of cure by Tenant.
(2) The failure to perform any terms, covenants or
conditions of this Lease or the violation or breach
thereof by Tenant, which failure, violation or breach
shall continue unremedied by Tenant for a period of ten
(10) days after written notice thereof shall have been
given to Tenant by Landlord, or for such additional
period as may be necessary to remedy such failure,
violation or breach with due diligence.
(3) The closing by Tenant of the Demised Premises
for a period in excess of five (5) consecutive business
days, unless such closing shall be caused by labor dis-
putes, fire, condemnation or other causes beyond the
control of Tenant except for Tenant may close for 7
consecutive days once a year for vacation.
(4) The abandonment.by Tenant of the Demised Pre-
mises or the removal or attempted removal by Tenant,
except in the ordinary course of business, of any goods
or property from the Demised Premises without having paid
and satisfied Landlord in full for all rent and other
charges then due or that may thereafter become due until
the expiration of the term of this Lease.
(5) The insolvency of Tenant or the making of an
assignment for the benefit of creditors, or the filing by
Tenant of a petition in bankruptcy or a bill in equity or
other proceedings for the appointment of a receiver for
Tenant, or the filing against Tenant of such petition or
bill which is not dismissed, or the commencement of such
proceedings which are not discharged within forty-five
(45) days, or the institution by Tenant of proceedings
for reorganization or for the composition or arrangement
- 18 -
10/09/92:10:42am:kac:9P' doc
with creditors under any state or federal law, or an
assignment of this Lease by operation of law, or the sale
or levy upon the real or personal property of Tenant by
any sheriff, marshal or constable or other authorized
officer.
(b) Landlord's Remedies. Upon the occurrence of an
Event of Default by the Tenant, in addition to any other rights or
remedies that Landlord may have under this Lease or at law or in
equity, Tenant covenants and agrees that Landlord shall have the
following rights:
(1) To accelerate the whole or any part of the rent
for the entire unexpired balance of the term of this
Lease, as well as all other charges, payments, costs and
expenses herein agreed to be paid by Tenant, and any rent
or other charges, payments, costs and expenses if so
accelerated shall, in addition to any and all install-
ments of rent already due and payable and in arrears and/
or any other charge or payment herein reserved, included
or agreed to be treated or collected as rent and/or any
other charge, expense or cost herein agreed to be paid by
Tenant which may be due and payable and in arrears, be
deemed due and payable as if, by the terms and provisions
of this Lease, such accelerated rent and other charges,
payments, costs and expenses were on that date payable in
advance.
(2) To enter the Demised Premises and without fur-
ther demand or notice proceed to distress and sale of
goods, chattels and personal property there found, to
levy the rent and/or other charges herein payable as
rent, and Tenant shall pay all costs and officers' com-
missions, including watchmen's wages and sums chargeable
to Landlord, and further including the five percent (5%)
chargeable by the Act of Assembly as commissions to the
constable or other person-making the levy, and, in such
case, all costs, officers'. commissions and other charges
shall immediately attach and become part of the claim of
Landlord for rent, and any tender of rent without said
costs, commissions and charges made, after the issuance
of a warrant of distress, shall not be sufficient to
satisfy the claim of Landlord.
(3) To reenter the Demised Premises and remove all
persons and all or any property therefrom, either by
summary dispossess proceedings or by any suitable action
or proceeding at law, or by force or otherwise, without
being liable to indictment, prosecution or damages there-
fore, and repossess and enjoy the Demised Premises, to-
gether with all additions, alterations and improvements.
Upon recovering possession of the Demised Premises by
reason of or based upon or arising out of a default on
the part of Tenant, Landlord may, at Landlord's option,
- 19 -
10/09/92:10:42am:kac--1O.doc -
either terminate this Lease or make such alterations and
repairs as may be necessary in order to relet and/or
operate the premises or any part or parts thereof, either
in Landlord's name or otherwise, for as term or terms
which may at Landlord's option be less than or exceed the
period which would otherwise have constituted the balance
of the term of this. Lease to such person or persons as
may in Landlord's discretion seem best; upon each such
reletting, all rents received by Landlord from such
reletting shall be applied: first, to the payment of any
costs and expenses of such reletting, including brokerage
fees and attorney's fees and all costs of such altera-
tions and repairs; second, to the payment of rent due and
unpaid hereunder; and third, to the payment of any in-
debtedness other than then rent due hereunder from Tenant
to Landlord; and the residue, if any, shall be held by
Landlord and applied in payment of future rent as it may
become due and payable hereunder. If.such rentals re-
ceived from such reletting during any month shall be less
than that to be paid during that month by Tenant here-
under, Tenant shall pay any such deficiency to Landlord.
Such deficiency shall be calculated and paid monthly. No
such reentry or taking possession of the Demised Premises
or the making of alterations and/or improvements thereto
or the reletting thereof shall be construed as an elec-
tion on the part of Landlord to terminate this Lease
unless written notice of such intention be given to Ten-
ant. Landlord shall in no.event be liable in any way
whatsoever for failure to relet the Demised Premises or,
in the event that the Demised Premises or any part or
parts thereof are relet, for failure to collect the rent
thereof under such reletting. Tenant, for Tenant and
Tenant's successors and assigns, hereby irrevocably con-
stitutes and appoints Landlord as its agent to collect
the rents due and to become due under all subleases of
the Demised Premises or any parts thereof without in
anyway, affecting Tenant's obligation to pay any unpaid
balance of rent due or to become due hereunder. Notwith-
standing any such reletting without termination, Landlord
may.at any time thereafter elect to terminate this Lease
for such previous breach.
(4) To cure any default by Tenant at Tenant's cost.
If Landlord at any time, by reason of-Tenant's default,
pays any sum or does any act that requires the payment of
any sum, the sum paid by Landlord shall be due immediate-
ly from Tenant to Landlord at the time the sum is paid
shall be additional rent.
(5) To terminate this Lease and the term hereby
created without any right on the part of Tenant to waive
the forfeiture by payment of any sum due or by other
performance of any condition, term or covenant broken,
whereupon Landlord shall be entitled to recover, in
- 20 -
10/09/92:10:42am:kac:°'(?.doc
addition to any and all sums and damages for violation of
Tenant's obligations hereunder in existence at the time
of such termination, damages for Tenant's default in an
amount equal to the amount of the rent reserved for the
balance of the term of this Lease, as well as all other
charges, payments, costs and expenses herein agreed to be
paid by Tenant, all and expenses herein agreed to be paid
by Tenant, all discounted at the rate of nine percent
(9%) per annum to their then present worth, less the fair
rental value of the Demised Premises for the remainder of
said term, also discounted at the rate of nine percent
(9%) per annum to its then present worth, all of which
amount shall be immediately due and payable from Tenant
to Landlord.
(6) If Tenant shall default in the payment of the
rent herein reserved or in the payment of any other sums
due hereunder by Tenant, Tenant hereby authorizes and
empowers any Prothonotary. or attorney of any court of
record to appear for Tenant in any and all actions which.
may be brought for said rent and/or said other sums and/
or to sign for Tenant an agreement for entering in any
competent court an amicable action or actions for the
recovery of said rental and/or other sums; and, in said
suits or in said amicable action or actions, to confess
judgment against Tenant for all or any part of said
rental and/or said rental and/or said other sums, in-
cluding, but. not limited to the amounts due from Tenant
to Landlord under Article 30(b)(1), (2), (3), (4) and/or
(5), and for interest and costs, together with any at-
torney's commission for collection of ten percent (10%).
Such authority shall not be exhausted by one exercise
thereof, but judgment may be confessed as aforesaid from
time to time as often as any of said rental and/or other
sums shall fall due or be in arrears, and such powers may
be exercised as well after the expiration of the initial
term of this Lease and/or during any extended or renewal
term of this Lease and/or after the expiration of any
extended or renewal term of this Lease.
(7) When this Lease and the term or any extension
or renewal thereof shall have been terminated on account
of any default by Tenant hereunder, and also when the
term hereby created or any extension or renewal thereof
shall have expired, it shall be lawful for any attorney
of any court of record to appear as attorney for Tenant,
as well as for all persons claiming by, through or under
Tenant, and to sign an agreement for entering in any
competent court an amicable action in ejectment against
Tenant and all persons claiming by, through or under Ten-
ant and therein confess judgment for recovery by Landlord
of possession of the Demised Premises, for which this
Lease shall be its sufficient warrant; thereupon, if
Landlord so desires, an appropriate writ of possession
- 21 -
10109/92:10:42am:kac-?0-doc -
may issue forthwith without any prior writ or proceeding
whatsoever, and provided that, if for any reason after
such action shall have been commenced, it shall be deter-
mined that possession of the Demised Premises remain in
or be restored to Tenant, Landlord shall have the right
for the same default and upon any subsequent default or
defaults, or upon the termination of this Lease or Ten-
ant's right of possession as hereinbefore set forth, to
bring one or more further amicable action or actions as
hereinbefore set forth to recover possession of the
Demised Premises as hereinbefore provided.
(8) In any amicable action of ejectment and/or for
rent and/or other sums brought hereon, Landlord shall
first cause to be filed in such action an affidavit made
by Landlord or someone acting for Landlord, setting forth
the facts necessary to authorize the entry of judgment,
of which facts such affidavit shall be prima facie evi-
dence, and, if a true copy of this Lease (and of the
truth of the copy such affidavit shall be sufficient
evidence) shall be filed in such suit, action or actions,
it shall not be necessary to file the original as a war-
rant of attorney, any rule of court, custom or practice
to the contrary notwithstanding.
(9) No right or remedy herein conferred upon or
reserved to Landlord is intended to be exclusive of any
other right or remedy herein or by law provided, but each
shall be cumulative and in addition to every other right
or remedy given. herein or now or hereafter existing at
law or in equity or by statute.
(10) Tenant hereby waives and releases all errors
and defects which may intervene in the Landlord's exer-
cise of any of its remedies hereunder, including the sum-
mary remedies. Tenant further waives the right of inqui-
sition on any real estate levied on, and Tenant volun-
tarily condemns the same.and consents to an immediate
execution upon any judgment obtained by Landlord. Tenant
also waives and releases all relief from any and all
appraisement, stay or exemption law of any state now in
force or hereafter enacted. Tenant waives any notice to
quit required by any law now in force or hereafter
enacted.
(11) In case suit shall be brought for recovery of
possession of the Demised Premises, for the recovery of
rent or any other amount due under the provisions of this
Lease, or because of the breach of any other covenant
contained herein on the part of Tenant to be kept or per-
formed, and a breach shall be established, Tenant shall
pay to Landlord all expenses incurred therefor, including
reasonable attorney's fees.
- 22 -
10/09/92:10:42am:kac_11O.doc
ARTICLE 31 - Damage or Destruction
(a) Notice of Damage. If an part of the Demised
Premises shall be damaged or destroyed by fire or other casualty,
Tenant shall give prompt notice thereof to Landlord.
(b) Damage or Destruction to the Demised Premises.
Subject to the requirements of Landlord's mortgagees:
(1) If the Demised
are damaged or destroyed
are not hereby rendered
shall, at its own expense
work as set forth in this
repaired.
Premises or any portion thereof
by fire or other casualty but
wholly untenantable, Landlord
and to the extent of Landlord's
Lease, cause such damage to be
(2) If the Demised Premises shall be rendered
wholly untenantable-by reason of such occurrence, Land-
lord shall promptly, at its own expense, cause such dam-
age to be repaired to the extent of Landlord's work, as
set forth in this Lease; provided, however, Landlord
shall have the right, to be exercised by notice in writ-
ing to Tenant within sixty (60) days from and after such
occurrence, to elect not to repair or reconstruct the
Demised Premises, and, in such event, this Lease shall
cease as of the date of such notice, and Landlord and
Tenant shall each thereupon be released from any obliga-
tion or liability thereafter accruing in respect of or
arising out of this Lease. Except as herein provided,
there shall be no obligation on Landlord to repair or
rebuild in case of fire or other casualty.
(3) Unless Landlord shall so terminate this Lease,
Tenant shall promptly restore and replace all fixtures
and improvements. on the. Demised Premises (except those
included in Landlord's work), including, but not limited
to those-installed and made by Tenant, and shall apply
the proceeds of all fire and extended coverage insurance
maintained by Tenant as required.by this Lease to such
restoration and replacement.
(c) Damage or Destruction to the Shopping Center.
(1) If,' in the opinion of Landlord, the building of
which the Demised Premises is a part, or if the Shopping
Center is substantially damaged or destroyed by fire or
other casualty (whether or not the Demised Premises are
affected), Landlord may terminate this Lease by written
notice delivered to Tenant within sixty (60) days after
the dates of such occurrence. If Landlord does so ter-
minate this Lease, Landlord shall be under no obligation
to repair, restore or replace any part or all of the
Shopping Center.
- 23 -
10/09/92:10:42am:kar T O.doc
(2) If this Lease shall be terminated as provided
in this Article, Tenant shall surrender the Demised Pre-
mises within thirty (30) days after delivery of any
notices of termination, whereupon this Lease shall expire
as though the date of such surrender were the date herein
set forth for the expiration of the term hereof.
(d) Rent Abatement. In the case of fire or damage, the
rent shall be abated proportionately with the degree in which the
Tenant's use of the Demised Premises is impaired during the period
of damage. If the Landlord repairs the damage, the abatement shall
end five (5) days after notice that the Demised Premises have been
repaired.
ARTICLE 32 - Hazardous Substances
(a) Tenant shall not use the Demised Premises to treat,
produce, store, handle, transfer, process, transport, dispose or
otherwise release any Hazardous Substances .(hereinafter defined)
on, from, or affecting the Demised Premises which has caused, is
causing or could cause contamination (hereinafter defined). Tenant
has not received any summon, citation, notice of violation, admin-
istrative order, directive, letter or other communication, written
or oral, from any governmental or quasi-governmental authority
concerning any intentional or unintentional action or omission on
the part of Tenant with regard to Hazardous Substances on, from or
affecting the Demised Premises.
(b) Tenant covenants that the Premises shall be kept
free of any Hazardous Substance which is causing or could cause
Contamination, and shall not be used to generate, manufacture,
refine, transport, treat, store, handle, dispose, or cause Con-
tamination. Tenant shall not cause or permit as a result of
intentional or unintentional act or omission on the part of Tenant
or any subtenant the installation of any Hazardous Substance in or
on the Premises or a release of any Hazardous Substance onto or
from the Demised Premises or suffer the presence of any Hazardous
Substance on the Premises which in any such case is causing or
could cause Contamination.
(c) Tenant shall comply with and ensure compliance with
all applicable federal, state and local laws, ordinances, rules and
regulations, with respect to Hazardous Substances, and shall keep
the Demised Premises free and clear of any liens imposed pursuant
to such laws, ordinances, rules and regulations. If Tenant re-
ceives any notice from any governmental authority with regard to
Hazardous Substances on, from or affecting the Demised Premises,
Tenant shall (i) immediately notify Landlord and any other person,
governmental or quasi-governmental authority that it is required to
notify pursuant to any applicable law at such time as it is aware
of a release or a threatened release of a Hazardous Substance on,
from or affecting the Demised Premises,. (ii) immediately notify the
Landlord at such time as an environmental investigation or clean-up
- 24 -
10/09/92:10:42am:kac• I doc
proceeding is instituted by any person in connection with the De-
mised Premises, (iii) fully comply with and assist such environ-
mental investigation and clean-up proceeding, (iv) promptly execute
and complete any remedial actions necessary to ensure that no en-
vironmental liens or encumbrances are levied against or exist with
respect to the Demised Premises, and (v) promptly, upon written
request of Landlord, provide Landlord from time to time with an
environmental site assessment or report, in form and substance
satisfactory to Landlord. Tenant shall conduct removal and other
actions necessary.to clean-up and remove all Hazardous Substances
on, from or affecting the Demised Premises in accordance with all
applicable, federal state and local laws, ordinances, rules, regu-
lations and policies and to the satisfaction of Landlord. If Ten-
ant shall fail to take such action, Landlord may make advances or
payments towards performance or satisfaction of the same but shall
be under no obligation to do so; and all sums so advanced or paid,
including all sums advanced or paid in connection with any judicial
or administrative investigation or proceeding relating thereto
including without limitation reasonable attorneys' fees, fines or
penalty payments shall be immediately repayable by Tenant to Land-
lord and shall bear interest at the rate of the prime interest rate
as established from time to time by Meridian Bank, Reading, Penn-
sylvania, plus one and one-half percent (11-,%) per annum from the
date advanced or paid by Landlord until the date paid by Tenant to
Landlord, and all sums so advanced shall be considered Rent.
(d) For the purposes of this paragraph "Hazardous Sub-
stances" shall include without limitation any flammable explosives,
radio-active materials, hazardous materials; hazardous wastes,
hazardous or toxic substances, hazardous or toxic pollutant or re-
lated materials, asbestos or any material containing asbestos, or
any other substance, mixture, waste, compound, material, element,
product or matter as defined by any Federal, state or local en-
vironmental law, ordinance, rule or regulation including without
limitation the Comprehensive Environmental Response, Compensation
and Liability Act of 1980, as amended (42 U.S.C. Section 9601 et
se q.), the Hazardous Materials Transportation Act, as amended (49
U.S.C. Sections 9601 et sec.), the Clean Water Act, as amended (33
U.S.C. Sections 1251 et secy.), the Clean Air Act, as amended (42
U.S.C. Sections 7401 et seg.), the Clean Streams Law, as. amended
(35 P.S. Section 691.101 et sec.), the Solid Waste Management Act,
as amended (35 P.S. Section 6801.101 et sea.), and in the regula-
tions adopted and publications promulgated pursuant thereto any
time.
(e) Tenant agrees to defend, indemnify and hold Landlord
harmless from and against any losses, expenses, liabilities and
claims arising from any breach or default by Tenant of its repre-
sentations or obligations under this Article, including without
limitation enforcing the obligations of Tenant under this Article
and including without limitation reasonably attorney's fees.
(f) The obligations and liabilities of Tenant under this
Article shall survive the termination of this Lease.
- 25 -
10/09/92:10:42am:kac:'-(`.doc .
(g) For the purposes of this Article, the term "Contami-
ria'cion" shall mean the uncontained presence of hazardous substances
on the Demised Premises or the Shopping Center or arising from the
Demised Premises which may require Remedial Action (hereinafter
defined) under applicable law.
(h) The term "Remedial" shall mean without limitation
(i) the clean-up or removal of hazardous substance, (ii) such ac-
tions as may be necessary to monitor, assess or evaluate the re-
lease or threatened release of hazardous substance, (iii) the prop-
er disposal or release of hazardous substances, (iv) the taking of
such other actions as may be necessary to prevent, minimize or
mitigate the damages caused by a release or threatened release of
hazardous substances to the public health or welfare or to the
environment.
ARTICLE 33 - Eminent Domain
Subject to the requirements of Landlord's mortgagees:
(a) Total Condemnation of the Demised Premises. If all
or a substantial portion of the Demised Premises is taken by or
pursuant to governmental authority or by the exercise of right of
eminent domain or by agreement between the Landlord and those
authorized to exercise such right (all such procedures being
collectively referred to herein as "a taking in condemnation"), the
obligations of the Tenant accruing subsequent to such taking in
condemnation shall cease and determine absolutely, and the Tenant
shall surrender possession of the Demised Premises to Landlord as
of the date title vests in the condemnor or, at Landlord's option,
if permitted by applicable law, the obligation of the parties
hereto shall continue in full force and effect as to all of the
terms and conditions of this Lease until Tenant, by reason of an
official order or direction of the condemning authority, vacates
the Demised Premises.
(b) Condemnation of the Shopping Center. If any mate-
rial part of either the building of which the Demised Premises are
a part of or the Shopping Center shall be taken in condemnation
(whether or not the Demised Premises shall be affected), Landlord,
at Landlord's option, made by written notice given to Tenant within
sixty (60) days after the date of such taking in condemnation,
elect to treat such taking in condemnation as a taking in condemna-
tion of the entire Demised Premises with the same effect as if the
entire Demised Premises had in fact been taken.
(c) Condemnation Awards. In the event of a taking in
condemnation of the Demised Premises, whether partial or total, or
in the event that Landlord elects as above provided to treat a
taking in condemnation as a taking of the entire Demised Premises:
(1) Tenant hereby waives all claims against Land-
lord in connection with such taking, except as specifi-
- 26 -
10109/92:10:42am:kac-I I.doc
cally provided in Article 33(d) entitled "Partial Con-
demnation," and hereby assigns to Landlord all claims of
any nature against the condemnor arising out of such
taking, including, but not limited to all claims for loss
of Tenant's leasehold estate.
(2) Tenant shall make no claim against the con-
demnor for the value of Tenant's leasehold estate.
(3) Notwithstanding the foregoing, Tenant shall be
entitled to the extent applicable law permits to claim
against the condemnor for removal expense, business
dislocation damage, moving expenses and delay compensa-
tion, if any, provided that such claim shall not reduce
any award to Landlord.
(d) Partial Condemnation. In the event of a condemna-
tion of any portion of the Demised Premises, Tenant may elect to
terminate this Lease by the effective date of the taking in
condemnation.
If this Lease continues after a partial taking in
condemnation, the minimum rent payable hereunder shall be reduced
from and after the taking of possession by the condemnor in the
same proportion as the area, if any, of the Demised Premises taken
bears to the area of the entire Demised Premises.
ARTICLE 34 - Subordination
(a) Subject to the terms hereinafter set forth, this
Lease and the estate hereby demised shall be and remain junior to
any and all mortgages on the Demised Premises or the Shopping
Center or any part thereof of which the Demised Premises constitute
as part; provided, however, that:
(1) So long as Tenant continues to pay the rent as
in this Lease reserved and otherwise complies with the
terms and provisions hereof:
(i) The right of possession of the Tenant to
the Demised Premises and the provisions and terms
of this Lease otherwise shall not be affected or
disturbed by mortgagee in the exercise of any of
its rights under the said mortgage, or the bond or
debt secured thereby or otherwise by law provided.
(ii) In the event that the mortgagee comes
into possession of or ownership of the title to the
Shopping Center or Demised Premises by foreclosure
of said mortgage, or by proceedings on the said
bond, or otherwise, this Lease shall continue in
effect and shall not be terminated by any of said
proceedings.
- 27 -
10/09/92:10:42am:kac fO.doc
(2) In the event that the Demised Premises are sold
or otherwise disposed of pursuant to any right or any
power contained in the said mortgage or the said bond, or
as a result of proceedings thereon, the purchaser of said
Demised Premises at such sale, or pay person acquiring
title through or by virtue of said sale, shall become
liable to perform all of the obligations of Landlord
under this Lease.
(3) This Lease shall be binding upon and inure to
the benefit of mortgagee, owner and Tenant, and their
respective heirs, executors, administrators, successors
and assigns, except as otherwise expressly provided
herein.
(4) The foregoing provisions shall be self-opera-
tive, but Landlord agrees to attempt to secure the
mortgagee's written confirmation thereof, as reasonably
requested by Tenant.
(b) Offset Statement. Within ten (10) days after
request therefor by Landlord or any mortgagee, a statement shall be
required from Tenant, and Tenant agrees to deliver in recordable
form a statement in writing to any proposed mortgagee or purchaser
or lender or to Landlord, certifying (if or to the extent that such
be the case) that this Lease is unmodified and in full force and.
effect, that Tenant has accepted the Demised Premises and is in
possession thereof, that Tenant has commenced the payment of rent,
that Landlord is not in default under this Lease and that there are
no deficiencies or offsets to the Lease claimed by Tenant.
(c) Failure of Compliance. If Tenant shall fail to com-
ply with any of the terms of this Article or to execute any state-
ment or agreement herein required within fifteen (15) days after
written request from Landlord, Landlord may terminate this Lease by
written notice to Tenant, whereupon the term shall expire as though
the date of such notice were the date herein set forth for the
expiration of the term hereof.
ARTICLE 35 - Relationship of Parties
The relationship of the parties under this Lease is sole-
ly that of Landlord and Tenant and shall in no way be construed as
a partnership, joint venture or other joint enterprise.
ARTICLE 36 - Definitions
(a) The word "Tenant" used in this Lease shall mean
every person or party named as Tenant in this Lease. Any notice
given as provided in this Lease shall bind all such parties, and it
shall have the same force as if given to all of them.
- 28 -
10/09/92:10:42am:kar O.doc
(b) The use of the neuter singular pronoun to refer to
Landlord and Tenant shall be deemed a proper reference to either of
them whether they be an individual, a corporation, a partnership or
any form of joint venture.
ARTICLE 37 - Accord and Satisfaction
No acceptance by Landlord of an amount less than the
monthly rent and other payments stipulated to be due under this
Lease shall be deemed to be other than a payment on account; of the
earliest such rent or other payments then due or in arrears nor
shall any endorsement or statement on any check or letter accom-
panying any such payment be affective to constitute an accord and
satisfaction. Landlord may accept any check for payment by Tenant
without prejudice to Landlord's right to recover the remainder of
any rent or other payment then in arrears, and Landlord may pursue
any other right or remedy provided in this Lease. No acceptance by
Landlord of any payment of rent or other sum by Tenant shall be
deemed a waiver of any of the obligations of Tenant under this
Lease.
ARTICLE 38 - Quiet Enjoyment
Upon payment of the rent and performance of all the other
covenants, terms, conditions and provisions of this Lease on the
part of the Tenant to be performed, Tenant shall peaceably and
quietly hold and enjoy the Demised Premises for the term herein
specified, subject nevertheless to all the covenants, terms,
conditions and provisions of this Lease.
Landlord represents that it is well seized of the land as
outlined on Exhibit A and may legally enter into this Lease with
Tenant.
ARTICLE 39 - Holding Over
Any holding -over after the expiration of the term of this
Lease shall, at Landlord's option upon notice to Tenant, be con-
strued to be a tenancy either from month-to-month or from year-to-
year at the rent and other payments herein specified and shall
otherwise be subject to the conditions, covenants and agreements of
this Lease. If Tenant shall hold over after the termination of
this Lease for any reason whatsoever, and Landlord has notified
Tenant in writing that such holding over shall not be permitted,
Tenant shall pay as liquidated damages and not as a penalty an
amount equal to twice the monthly rent in effect for the last month
of Tenant's lawful occupancy prorated for the period during which
such holding over continues. Nevertheless, the acceptance of such
amount by Landlord shall be without prejudice to any other rights
or remedies of Landlord at law or in equity or under this Lease.
- 29 -
10/09/92:10:42am:ka, J10.doc
ARTICLE 40 - Recording
If requested by Tenant, Landlord, at Tenant's expense,
shall prepare, have executed and promptly files a Memorandum of
this Lease in the Recorder of Deeds Office of Hampden Township, New
Cumberland, Pennsylvania, and provide proof of such recording to
the Tenant. Landlord's obligation is expressly conditioned on
Tenant delivering to Landlord's attorney, to be held in escrow, a
Memorandum of Termination of this Lease, executed and in recordable
form.
ARTICLE 41 - Delays
If either party to this Lease shall be delayed or pre-
vented from the performance of any obligation hereunder (other than
the obligation of Tenant to pay rent of additional rent or other
charges when due) by reason of labor disputes, inability to procure
materials, failure of utility service, restrictive governmental
laws or regulations, riots, 'insurrection, war, adverse weather,
Acts of God, or other similar cause beyond the control of such
party, the performance of such obligation shall be excused for the
period of delay. The provisions of this Article shall not excuse
Tenant from the prompt payment of any sums payable under any of the
provisions of this Lease.
ARTICLE 42 - Captions
The captions, section numbers, paragraph numbers and
index appearing in this Lease are inserted only for convenience and
shall not in any way affect the meaning or intent of any portion of
this Lease.
ARTICLE 43 - Partial Invalidity and Construction
The sections of this Lease are intended to be severable.
If any section or provision--of this Lease shall be held to be
unenforceable by any court of competent jurisdiction, this Lease
shall-be construed as though such section had not been included in
it. If any section or provision of this Lease shall be subject to
two constructions, one of which would render such section or
provision invalid, then such section shall be given the construc-
tion which would render it invalid.
ARTICLE 44 - Binding Effect
(a) The provisions of this Lease shall extend to and be
binding upon the parties hereto and their respective personal
representatives, successors and assigns except that this provision
shall not be construed as a consent by Landlord to any subletting
or assigning by Tenant.
- 30 -
10/09/92:10:42am:kar 1'0.doc
(b) All liability of Tenant for the payment of rents or
ai.y other obligation shall survive the expiration or sooner
termination of this Lease.
ARTICLE 45 - Arbitration
Any disagreement between the parties hereto, including
any interpretation of the provisions of this Lease, shall be
decided according to the rules set forth by the American Arbitra-
tion Association, and any decision handed down by said Association
shall be final and binding and not subject to appeal.
ARTICLE 46 - Notices
(a) All notices or demands required or permitted to be
given or served under this- Lease .shall be deemed to have been given
or served only if in writing forwarded by registered or certified
mail, postage prepaid, return receipt requested, and addressed as
follows:
To Landlord at:
WESLEY ASSOCIATES
C/O Bennett Williams, Inc.
135 North George Street
York, Pennsylvania 17401
To Tenant at:
Say Quan Ly
CHINA WOK
Eastgate Plaza
5205 Simpson Ferry Road
Mechanicsburg, PA 17055
(b) Such address may be. changed by either party by
notice delivered as above provided to the other party. If Landlord
or any mortgage shall so request of Tenant, Tenant shall sends such
mortgagee a copy of any notice thereafter sent to Landlord.
ARTICLE 47 - Commissions Due Real Estate Broker
The parties acknowledge that Bennett Williams, Inc. is
the sole broker involved in this Lease Agreement. Landlord and
Tenant acknowledge that all commissions due Bennett Williams, Inc.
and/or its agents are to be paid by Landlord, its heirs, executors,
administrators, successors and assigns. The total commission due
is five (5%) of all gross rents for the primary term to be paid as
collected by Landlord.
- 31 -
'10 CIM
I
J,,
ARTICLE 48 - Exhibits
The following attached Exhibits, initialed by the parties
hereto, are deemed part of this Lease.
A Site Plan
B Sign Criteria
ARTICLE 49 - Entire Agreement
This Lease and the Exhibits attached hereto set forth the
entire agreement between the parties, and there are no other agree-
ments, expressed or implied, oral or written, except as herein set
forth. This Lease may not be amended altered or changed except in
writing by both of the parties hereto. This Agreement shall be
interpreted under the laws of the Commonwealth of Pennsylvania.
ARTICLE 50 - Security Deposit
Landlord hereby acknowledges receipt from Tenant of the
sum equal to one (1) month's rental to be held by Landlord as
security for the payment of rent and the performance of Tenant's
other obligations under this Lease. Said deposit shall be returned
to Tenant at the termination of this Lease if all Tenant's obliga-
tions hereunder are performed to the date of termination. If
Tenant defaults in the payment of rent or in the performance or
observance of any obligation on its part under this Lease, Landlord
may apply the deposit to payment of rent in default or other money
arrearage and/or to the damages and costs incurred by Landlord as
a result of any default and/or to costs incurred by Landlord in
rectifying and default and/or to the prepayment of minimum rent for
any subsequent period of the term; and Tenant shall promptly there-
after restore the security deposit to the original amount above
specified (except the extent the said sum is applied by Landlord to
prepayment of minimum rent). The right of Landlord to apply the
security deposit as above specified shall not be construed as a
limitation upon Landlord's right to invoke any other remedy avail-
able under this Lease or at law or in equity for breach of this
Lease, or to collect the full amount of damages owing by Tenant on
account of such breach.
ARTICLE 51 - Limitation Upon Landlord's Liability
Neither Landlord nor any principal of Landlord, whether
disclosed or undisclosed, shall have any personal liability with
respect to any of the provisions of this Lease or the Demised
Premises, and, if Landlord is in breach or default with respect to
Landlord's obligations under this Lease or otherwise, Tenant shall
look solely to the equity of Landlord in the Demised Premises for
the satisfaction of Tenant's remedies.
- 32 -
c'rIU.aOc
ARTICLE 52 - Time of the Essence
Time is of the essence to each provision of this Lease.
IN WITNESS WHEREOF, the parties hereto have executed this
Lease on the day and year first above written.
WITNESS:
LANDLORD:
WESLEY ASSOCIATES
? ? .
BY= V1 - OR ?
David Schad
Title: General Partner
ATTEST (OR WITNESS): TENANT:
CHINA WOK
By : ?--?
Say Quan Ly
Title: Owner
- 33 -
EXHIBIT B - SIGNAGE
EAST WING
Following letter shall all be non-illuminated and will be manufac-
tured from #k2418 Rohm & Haas plexiglas complete with All wide- brown
jewelite. All letters shall begin 2" up from bottom of sign
fascia, no letter to exceed 16" in height, 2 lines of copy are
permissible but both lines shall not exceed the 16" height
combined. When applying the letters on the sign panel there must
be a margin of 10" left and right. Landlord provides recessed
lighting above letters for night time effect. Styles of letters
may vary so long as they do not go beyond the specifications above.
No logo boxes or outlines of images.
SOUTH WING
Whatever remaining space exists between the top of the awning and
the top of the parapet wall shall be used for the signage. This
measurement has not been determined at this point but is approxi-
mately 3'x6", all signage will be centered vertically between these
points. No letters shall- exceed 18" in height, if necessary to
install two lines of copy the two lines combined shall not exceed
30" in height. The lettering must be 24" from adjoining tenants
left and right. All lettering in this area shall be non-illumi-
nated letters fabricated from Rohm & Haas dark brown plexiglas with
V1 wide jewelite brown. No box type signs permitted. Landlord
provides recessed lighting above letters for night time effect.
Before proceeding with any signs tenant must submit drawings to the
Landlord for approval. It is the tenant's responsibility to secure
proper sign permits from the Township.
It will be the Landlord's responsibility to furnish directional
signs for traffic as well as identification for the Shopping Center
in general.
Window signs are permissible providing they are vinyl and applied
to window surface in good taste.
Entrance door will be lettered, indicating store name and store
hours. Letter style will be Helvetica, material will be white
vinyl.
Under Canopy Signs:
11x5' double face sign case and faces to be baked enamel aluminum,
color bronze. Letter style will be Helvetica, material will be'
white vinyl. Lettering will be limited to store name. Sign frame
and sign faces to be supplied by Landlord.
Any. changes in the above specifications without written approval
will be considered a violation of the lease and dealt with accordingly.
- 35 -
ASSIGNMENT OF LEASE
This Agreement, made this ?`f l\ day of November, 1993, by and
among SAN QUAN LY (hereinafter referred to as Assignor),
HOM HUNG LAI, HONG YAU TSANG, and HOM CHUNG LAI (hereinafter
referred to as Assignees), and WESLEY ASSOCIATES,/BENNETT WILLIAMS,
INC., of 135 North George Street, York, Pennsylvania 17401
(hereinafter referred to as Lessor);
WHEREAS, Lessor and Assignor entered into Lease Agreement
dated October _ , 1992, for the premises located at 5205
Simpson Ferry Road, Mechanicsburg, Pennsylvania; and
WHEREAS, Assignor desires to assign said Lease to Assignee and
Lessor's consent to said assignment is required.
NOW THEREFORE, in consideration of the mutual promises
expressed herein, the parties agree as follows:
1. Effective as of November , 1993, Assignor assigns,
transfers and sets over to Assignee all his rights, title and
interest in and to said Lease Agreement, including security deposit
of $ 7,?aD- now held by Lessor. Assignee accepts said
assignment and agrees to perform all the terms, covenants and
conditions on the part of the Lessee to be performed under said
Lease Agreement.
2. Lessor hereby consents to the assignment provided
Assignors pay all rent and other charges to the effective date of
this Assignment.
3. All other terms and conditions of said lease shall remain
and continue in full force and effect and shall be deemed unchanged
to the extent provided herein, with the following Amendment to
Article 15(a): Tenant shall not, during the term of this Lease or
extension thereof, assign, transfer, mortgage, pledge or otherwise
encumber this Lease or the leasehold estate created hereby or any
part, nor shall Tenant sublease the Demised Premises, in whole or
in part, without the prior written consent of Landlord, whose
consent shall not be withheld unreasonably.
1
Assignment of Lease
page 2
IN WITNESS WHEREOF, the parties have hereunto set their hands
and seals the day and year first above written.
6 Assignor: 'e"
SAY QUAN LY
. .?
Assigneesu-?%
HOM HUNG I
HONG YA'U T ANG
L D .1 C?6' .4-,
HOM CHUNG LA
No sew
my Camissim E)O- W .uc5";`9s
. Aeaoaaiio? Notaries
/
Lessor: L?' /-!'? \\
WESLEY ASSOCIATES/
ej AAt"
ADDENDUM
This document amends the lease dated 9-October-1992, between Wesley
Associates (landlord) and Hong Tsang, TDBA China Garden.
The revised lease terms are (5 years) beginning 1-September-2004 and
ending 31-August-2009, at a monthly rent of $1,472.00 and an
annual rent of $17,644.00.
All pro rata share of taxes, insurance, and other CAM charges will be billed
monthly, and will be based on 1600 sq. ft. of leased space.
Estimated expenses at present are as follows.
CAM $ 437.97
Ins. $ 48.15
Taxes $ 130.00
Landlord to extend separating wall at its cost tenant to separate electric at its
expense.
Wesley Associates
aA J'/
David Schad, General Partner
Date
China Garden
Witness
Date
ess
long Tsa
g
Date
ate
ESTOPPEL LETTER
August 31, 2004
RE: Confirmation of Lease Agreement for Eastgate Shopping Center, Hampden
Township, Cumberland County, Pennsylvania
Ladies and Gentlemen:
At the request of Wesley Associates ("Landlord") the undersigned hereby certifies
to you and agrees as follows recognizing [hat you will rely on the information contained
herein:
1. The undersigned is the tenant under a lease with Landlord, as follows: Lease
dated October 9, 1992 (the "Lease"), as amended by an Addendum dated August 25,
2004, which Addendum, among other things,r educed the Demised Premises from 3,200
square feet to -1,600 squgre-feet; changed the trade- name from China Wok to- U-4na - -
Garden; -and changed the Tenant from Say Quan Ly to Hong Tsang (the 'Addendurel)-
The Lease and the Addendum are incorporated herein by reference. The undersigned
Tenant occupies the premises demised thereunder.
2. The above lease as amended and/or assigned is in full force and effect and has
not otherwise been amended, modified, supplemented or superseded, and together
herewith constitutes the entire agreement between the undersigned and Landlord with
respect to said premises. There is no other agreement (except for the agreements
contained herein) between the undersigned and the Landlord with respect& to said
premises or any other space at the above referenced property.
3. Neither the undersigned nor the Landlord is in default under the Lease. There
is no defense, offset, claim or counterclaim by or in favor of the undersigned against
Landlord under the Lease or against the obligation of the undersigned under the Lease_
4. The undersigned has not received notice and is not aware of any prior transfer,
assignment, hypothecation or pledge by Landlord or any of the Landlord's interest in the
Lease, except to you. .
5. The monthly base rent of $1,472.00 due under the lease has been paid through
August 31, 2004, and all additional rent due under the Lease has been paid through
August 31, 2004.
6. The tenant has a security deposit of $2,200.00 deposited with the Landlord.
7. There are no actions, voluntary or otherwise, pending or, to the best knowledge
of the undersigned, threatened against the undersigned under the bankruptcy,
reorganization, moratorium or similar laws of the United States, any state thereof or any
other jurisdiction.
8. The undersigned has accepted possession, taken occupancy of, and is
conducting operations at the premises; the term of the Lease has commenced; the
undersigned has commenced the payment of rents for all space subject to the Lease; and
the expiration of the lease is August 31, 2009.
9. All work to be performed by Landlord under the Lease has been completed in
accordance with the Lease and has been accepted by the undersigned and all
reimbursements and allowance due to the undersigned under the Lease in connection with
any work has been paid in full.
10. The Lease contains no first right of refusal, option to expand, option to
terminate, or exclusive business rights, except as follows: None.
11. Tenant has not entered into any sublease, assignment or any other agreement
transferring any of its interest in the Lease or the Premises except as follows-
12_ Tenant has not generated, used, stored, spilled, disposed of, or released any- --
hazardous substances at or in the Premises. "Hazardous Substances" means any
flammable, explosive, toxic, carcinogenic, mutagenic, or corrosive substance or any
flammable, explosive, toxic, carcinogenic, mutagenie, or corrosive substance or waste,
including volatile petroleum products and derivatives and drycleaning solvents- To the
best of Tenant's knowledge, no asbestos or polychlorinated biphenyl ("PCB") is located
at, or in the Premises. The term "Hazardous Substances" does not include those materials
which are technically within the definition set forth above but which are contained in pre-
packaged office supplies, cleaning materials or personal grooming items which are sold
for consumer or commercial use and typically used in other similar buildings or space.
'eery truly yours,
B . N 14: a :Hog sang, T BA C rna Garden
F.MaMQ313 - WESLEY ASS0CIATES15766 •GoneraRDocxmentskChina Garden Estoppiawoc 912104 3:40 PM
THE Abstract Comppny A. Settlement Statement FN
Ar
p- of HmS
°
UMW na ?°
1723 Pine Strut, 1st Floor US'
"?';° p `
,
ose
R
LOArt
&TfK Philadelphia
PA 19103
.OFM
,
Phone: (215)545-1180 4. °P" S o? 3. j]Cen.. tAn s.
4. VA S. CIXrV. hns.
o R I.LOANrarMDER
Fax: (215)545
11 93 W
1
-
1
e44
6. MORTGAGE INSUR"CE CASE NUMBER
C. Nde: awm.n++'M-e-T ..?'i ww.wr?i. .ei.m°.rer?dswwr.,.w..w..,s, ,0wan yraa
ar.soew rs +r.rr.
T*E
a
a
?~4"
i s
?1°
*
a`w
,
?a. uiw
sro
xpr Sdd m tSysie
a
.
rw tam.n ra..
io .
'
0. NAME OF r.«wrrie.wu o.s t?ar.ra.ea.-fna Rb5M W177R004 at 11495
Horne EIMe Ltd and PR Rol Esta k LLC
ADDRESS. 45 East Line Arera0 Suit' 377 Bala CV!
Vd. !w
19004
E NAME OF SELLER TWO".Assodates
ADDF2ES$; do M4lliams 110 N. Geor StreN York PA 19401
F. NAME OF LENDER Wachoria Bardr
2240 Butler PA 19462
G. PROPERTY ADDRESS: >11 Simpson Ferry Rwd, MredWdC6btrr% PA 17055
"m WN-t"
tL SETTLEMENT AGENT: TM Abstract Compatry, Telephone: 215445.1140 -Fa=215,4&1 193'
PUKE ITnP160 gbyet 1st Floor Ph0 'r A10103
1. SETTU34M DATE ? 0011
J. y
100. OROSS AMOUNT OUE FROM BORRCIMER 5 ?f7 -
101. Cardr 400. CROW AMOUNT DUE TO SELLER
102. Personal 1• w
103. SeUlempB b hortower 1400
40.
04.
1
404
105.
405.
AduStmerds for
ikrie arNler n
106
Ilownla
09117
advance
uctrnanlc nor Gems aid seller b
edvarxy
.
m
b12131N
106. SdrodTaass 09117104 06130/05
109
se
ver 04
406 0911T1040N31104
406. SdmdTam 0QMTH14iDW0aW _
.
r
117104
110 sewer 09N7104b09130104
- i
410 e1M
111. .
112
120. GROSS AMOUNT DUE FROM BORROWER 412.
A20. OROSS AMOUNT 0 TO SELLER --
200- AMOUNTS P BY OR ON BEHALF OF
201
D REDUCTIONS IN AMQUIff DUE TO SELLER
.
evmRaraww%
iusrrgiom
202. RkxW am unt olnow Loans
203
E
& 502 Se0lementdl b t "
.
4s
v b s taken Emeglo 503. taken bledta
204. 504. P 10
+b bank _
505. ft0o(SemW
atts
COmmmky Bank
206. homeeete17201vaAace 10'7L
207. 1726 rraoome 201 tam aRe : 507. --
208. 1728 1AIM 7 201 tym al, - 506. --
209. 2100 Yana!
dqe Wg -'
1rIrblMlde fo
r ROM seller tmeMs 1w items seller
213. 513.
214.
14.
215. 515.
216. - 16.
217. 517.
210. 18.
219 51
. TOTAL PAID OYIFOR BORR04I1?T • . 020. TOTAL REDUCTION AMOUNT DUE SELLER
300. CASH AT SETTLEMEW OR 70 600 CASH AT SETTLEMENT TO OR FROM SELL ER
301. GlobearlloA(Wfrom 1
W1. wpAdre1osenei 4 _
302 Less arrutrds ' Hon bmmaer 220 W2 Less reduction arrant due weer fine 5
303. CASH FROM B 0.00 003. CASH TO SELLER 441
lUnbySTyaN?1E rwu tsasaatan SiAIFRNR?I..M.I?sfwmaaorrwnY.wdMMnF irowbtlat YiMwMsr rq kN4'a M.rIMJ p era NNanM Mmw lw+kr. a yw ?n rouilne
?v?aM1 lira Gwrtrsnlnraa Pke M+i
f.e7M Maap?Iw??lreaw ?~ MMsYw Wpa?`a.rbreyWNa6a..pawa rM Mnli bemmwnwnit lra.we4an iaa
vsa ae narree Inrrapwide b..resrrrsYwstw?rr?,..,??rennrr.?an.anm+r..m.iwk.sor nr..r_c?ywbnarpa.warwr..r..araww.. ra
•+Oe.F.r?ae 6n mbtaerb CMOr oiArrMPdrnem rwaRpwresuaaprp,,lawYrYtlu/M nlmibvsrmnn ee tlaa nals.wn Ar^rcm.Ml.nPI?W.r?aP?rs...
TM•--""-? r SCLLra9srllGNl1TRLL151: I ..
SEItERtbl rlaw anaJrrG AW aalS:
$Euvqs?lk? "Mom:
PINTZUK BROWN REALTY GROUP
September 28, 2005
China Garden
5205 Simpson Ferry Road
Suite #11
Mechanicsburg, PA 17055
RE: Outstanding Balance
Dear Tenant:
Enclosed is a copy of your ledger. Currently you have an outstanding balance of
$1477.51, which includes the Reconciliation charges for the 2004 Year. Also enclosed is
a copy of the detailed correspondence you have already received regarding these 2004
Reconciliation charges. Please forward payment immediately to clear your account of
these delinquent charges and avoid further action. If you have any questions contact me
at the numbers found below. Thank you for your immediate attention to this matter.
Sincerely,
/?41 (A
Mary Duffy
Accounting Manager
491 Old York Road, Suite 200 • Jenkintown, PA 19046
Office: 215-881-8980 1 Fax: 215-881-8983 • Web: www.pbrginc.com
PINTZUK BROWN REALTY GROUP
October 26, 2005
China Garden
5205 Simpson Ferry Road
Suite 11
Mechanicsburg, PA 17055
Via Certified Mail 7 --tt- q o0q
MOO OO boo-:t) cf`?)ao nci `-{
RE: Outstanding Balance
Dear Tenant -
This letter should serve as a follow up to our conversation last week regarding the
outstanding 2004 Operating Expense Reconciliation charges still owed. Pursuant to your
Lease Agreement you are required to pay these charges. Within the Lease Agreement,
please refer to Article S - Contributions Sections (a) through (d) which clearly outline
Tenant's obligations regarding Common Area Maintenance contributions.
Also make specific note within Article S - Contributions Section (b), "Tenant's share of
the Cost of the maintenance and operating shall be determined by the following formula:
"The number of square feet of floor area in the Demised Premises (3200 sq. ft.)
shall be multiplied by the fraction, the numerator of which shall be the total cost
of the maintenance and operation of the Common Area, and the denominator of
which shall be the sum of the total leasable building area in the Shopping Center
(36,000 sq. fl)."
Enclosed is a copy of your ledger to date. Please forward payment IN FULL
immediately to avoid further action. If you have any questions regarding this issue,
contact me at the numbers found below. Thank you for your immediate attention to this
matter.
Si cerely,
Mary uffy
Accounting Manager
mpd@tbrg.net
491 Old York Road, Suite 200 • Jenkintown, PA 19046
Office: 215-881-8980 • Fax: 215-881-8983 • Web: www.pbrginc.com
PINTZUK BROWN REALTY GROUP
April 24, 2006
China Garden
5205 Simpson Ferry Road
Smite 1 1
Mechanicsburg, PA 17055
RE: Outstanding Balance
Enclosed is a copy of your ledger to date. Note that there is currently a delinquent
balance of $7,044.20. Please send payment in full to resolve this issue. If you have any
questions regarding this matter, please contact me at the number or email address found
below. Thank you for your immediate attention to this matter.
Sincerely,
z
Tara Malone
Property Accountant
215-881-8980 x206
tem@tbrg.net
491 Old York Road, Suite 200 • Jenkintown, PA 19046
Office: 215-881-8980 • Fax: 215-881-8983 • Web: www.pbrginc.com
E xtiib?t T
PINTZUK BROWN REALTY GROUP
May 19, 2006
Via Certified Mail
China Garden
5205 Simpson Ferry Road
Suite 11
Mechanicsburg, PA 17055
RE: Outstanding Balance
Pursuant to your Lease Agreement you are required to pay Operating Expense
Reconciliation charges. Within the Lease Agreement, please refer to Article 5 -
Contributions Sections (a) through (d) which clearly outline Tenant's obligations
regarding Common Area Maintenance contributions.
Also make specific note within Article S - Contributions Section (b), "Tenant's share of
the Cost of the maintenance and operating shall be determined by the following formula:
"The number of square feet of floor area in the Demised Premises (3200 sq. ft.)
shall be multiplied by the fraction, the numerator of which shall be the total cost
of the maintenance and operation of the Common Area, and the denominator of
which shall be the sum of the total leasable building area in the Shopping Center
(36,000 sq. ft)."
Enclosed is a copy of your ledger to date. Please forward payment IN FULL
immediately to avoid further action. Your account is accumulating late fees each month
for your ongoing balance. If you have any questions regarding this issue, please contact
me. Thank you for your immediate attention to this matter.
Sincerely,
Tara Malone
Property Accountant
215-881-8980 x206
491 Old York Road, Suite 200 • Jenkintown, PA 19046
Office: 215-881-8980 • Fax: 215-881-8983 • Web: www.pbrginc.com
SeP 21. 2006 12:14PM No 146. P- 4
PINTZUIK BROWN REALTY GROUP
VIA CERTIFIED & REGULAR US MAIL
July 14, 2006
China Garden
5205 Simpson Ferry Road
Mechanicsburg, PA 17055
Attention: Tin
RE; NOTICE OF DEFAULT
Dear Tin:
This letter shall serve as formal notice of Monetary Default of the Lease
agreement for the Leased Premises known as East Gate Plaza. The current balance on
your account as of the date of this letter is $10,027.44. You must immediately make
payment on this account or the Landlord will be forced to proceed with its remedies
under Article 30 (b) of the Lease Agreement. Please note that Article 30 (b) of the Lease
Agreement includes acceleration of Rent, dispossession and eviction, termination and
legal proceeding for judgments of possession and money damages.
If payment in full is not received by this office on or before July 24, 2006 we will
turn this matter to our attorneys and proceed with the Landlord's full rights in law and
equity at your expense.
Thank You,
Mazy Duffy,
Asset Manager
491 Old York Road. Suite 20U • Jenkintown, PA 19046
rlrrec: 215-881-8980 - Fax; 215-881-8983 - Web- www.pbrgine.com
eP-21• ZUU6 12:14NM
Ledger
Date : 7/11/2006
Code chinagar
Name CHINA GARDEN
Address 5205 SIMPSON FERRY RD
SUITE # 11
City St. Zip MECHANICSBURG, PA 17055
IJ0 X140 P.
Page 1 of 2
Tenant Ledger
Property ceast
Unit 1l
Status Current
Rent 1472
Phone(O)- (717) 766-1536
Lease From 9/1/2004
Lease To 8/31/2009
Move In 9/1/2004
Move Out
Phone(H )-
vase
2/28/2006 Description
Out
t
d Charge Paymen t Balance Chg/Rec
2/28/2006 s
an
ing Late Fees as of 2/28/06
Out
t
d 1,117.23 1,117.23 58382
2/28/2006 s
an
ing Rent as of 2/28/06
Ret
d Ch
rn 2,944.00 4,061.23 58383
2/28/2006
2/28/2006
2/28/2006
2/28/2006 u
e
eck Charge 12/1/05
Outstanding CAM as of 2/28/06
Outstanding RE TAX as of 2/28/06
Outstanding INSR as of 2/28/06
O
t
d 30.00
875.94
260.00
96.30 4,091.23
4,967.17
5,227.17
5,323.47 58384
5838S
58386
58387
2/28/2006
2/28/2006 u
stan
ing YE 2004 CAM REC
Outstanding 2004 YE INSR Reconciliation
Outsta
di
2 691.34
209.26 6,014.81
6,224.07 58388
58389
3/1/2006 n
ng
004 YE RETAX Reconciliation
RENT (03/2006 506.91 6,730.98 58390
3/112006 )
CAM (03/2006 1,472.00 8,202.98 58663
3/1/2006
3/1/2006
3/6/2006
3/20/2006 )
Property Tax Pass Thru (03/2006)
Insurance Pass Thru (03/2006)
March Late Fees, 5% of $2088.12
hk# 437.97
130.00
48.15
104.41 8,640.95
8,770.95
8,819.10
8,923.51 58664
58665
58666
58904
4/1/2006
4/1/2006
4/1/2006 c
0615
RENT (04/2006)
CAM (04/2006)
Pro
ert
T
1,472.00
437.97 2,088.12 6,835.39
8,307.39
8,745.36 41878
59109
59110
4/1/2006 p
y
ax Pass Thru (04/2006)
Insurance Pass Thru (04/2006) 130.00
48.15 8,875.36
8,923.51 59111
59112
4/6/2006
4/18/2006 April Late Fees, 5% Of $4176.24
chk# 0617 208.81 9,132.32 59351
5/1/2006
5/1/2006
5/112006
511/2006
5/6/2006
RENT (05/2006)
CAM (05/2006)
Property Tax Pass Thru (05/2006)
Insurance Pass Thru (05/2006)
May Late Fees, 5% of $4176.24
1,472.00
437.97
130.00
48.15
208.81 2,088.12 7,044.20
8,516.20
8,954.17
9,084.17
9,132.32
9,341.13 42054
59883
59884
59885
59886
60126
5/15/2006 chk# 0621 2,088.12 7,253.01 42200
6/1/2006 RENT (06/2006) 1,472.00 8,725.01 60323
6/1/2006 CAM (06/2006) 437.97 9,162.98 60324
6/1/2006 Property Tax Pass Thru (06/2006) 130.00 9,292.98 60325
6/1/2006 Insurance Pass Thru (06/2006) 48.15 9,341.13 60326
6/6/2006 3une Late Fees, 5% of $4176.24 208.81 9,549.94 60478
6/16/2006 chk,# 0622 2,088.12 7,461.82 42634
7/1/20Q6 RENT (07/2006) 1,472.00 8,933.82 60676
littps://www.yardiaspia5.com/20220pintzuklrepoas/Resident i.edger.asp?h'1'ent=1524&Re_.. 7/11/2006
?G• Z:14NM
I edger
No•u14L' P. 6
Page 2 of 2
7/1/2006 CAM (0712006) 437.97 1 1 9,371.79 60677
7/1/2006 Property Tax Pass Thru (07/2006) 130.001 1 9,501.78 60678
7/1/2006 Insurance Pass Thru (07/2006) 48.151 1 9,549.94 60679
X /0
/o, szrl,113
https://www.yardiaspla5.corn/20220piniruk/reports/Resident Ledger.asp?Ifrent--I 524&Re... 7/11/2006
?? ,
4ZI
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Identification Nos. 65886/91635
1601 Market Street, 26th Floor
Philadelphia, PA 19103
(215) 563-0500
HOME ELITE LTD., INC. and
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046
Plaintiffs,
V.
Attorneys for Plaintiffs,
Home Elite Ltd., Inc.
and P.R. Real Estate, LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION - LAW
HONG TSANG, Docket No. 06-6679 (Civil)
t/d/b/a CHINA GARDEN,
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant.
PRAECIPE TO REINSTATE
TO THE PROTHONTARY:
Kindly reinstate the Civil Action Complaint in the above-captioned
matter.
Dated:
FREY, PETRAKIS, DEEB, BLUM
& BRIGGS, P.C.
By: I.D. Nos. 65886/91635
Frank G. urphy, Esquire
Christina M. Hughes, Esquire
1601 Market Street, Suite 2600
Philadelphia, PA 19103
(215) 563-0500
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and P.R. Real
Estate, LLC
r.a
C-i
J
FREY, PETRAKIS, DEEB,
BLUM & BRIGGS, P.C.
BY: Frank G. Murphy, Esquire
Christina M. Hughes, Esquire
Attorney I.D. No. 65886/91635
1601 Market Street, Suite 2600
Philadelphia, PA 19103
(215) 563-0500
HOME ELITE LTD., INC. and
P.R. REAL ESTATE, LLC
491 Old York Road, Suite 200
Jenkintown, PA 19046
Plaintiffs,
V.
HONG TSANG
t/d/b/a CHINA GARDEN
5205 Simpson Ferry Road, Suite 11
Mechanicsburg, PA 17055
Defendant
Attorneys for Plaintiffs,
Home Elite Ltd., Inc. and
P.R. Real Estate, LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
Docket No. 06-6679
PRAECIPE FOR WRIT OF EXECUTION UPON A CONFESSED JUDGMENT
TO THE PROTHONOTARY:
Issue a writ of execution upon a judgment entered by confession in the above
matter,
(1) directed to the Sheriff of Cumberland County;
(2) against Hong Tsang t/d/b/a China Garden, Defendant; -4 41
(3) and index this writ
(a) against Hong Tsang t/d/b/a China Garden, Defendant
(4) Amount due $7,126.71
Attorney's fees 712.67
Total $7,839.38
.4
CERTIFICATION
I certify that:
(a) This Praecipe is based on a judgment entered by confession, and
(b) Notice has been served pursuant to Rule 2958.1 at least thirty days prior
to the filing of this Praecipe as evidenced by a return of service filed of record.
FRANK G. MURPHY, QUIRE
CHRISTINA M. HUGHES, ESQUIRE
Attorneys for Plaintiffs, Home Elite, Ltd., Inc. and
P.R. Real Estate, LLC
FREY, PETRAKIS, DEEB, BLUM & BRIGGS, P.C.
1601 Market Street, Suite 2600
Philadelphia, PA 19103
215-563-0500
9P
1
V
44
5
.- a c o CD t ,
-2L 1
1 '
4
07
ATTORNEYS AT LAW
January 25, 2007
Reply To:
PHILADELPHIA
1601 Market Street
Suite 2600
Philadelphia, PA 19103
(215) 563-0500
Fax: (215) 563-5532
10 Melrose Avenue
Suite 430
Cherry Hill, NJ 08003
(856) 216-2322
Fax: (856) 216-2392
15 North Shore Road
Marmora, NJ 08223
(609) 390-0127
Fax: (609) 390-0244
VIA OVERNIGHT MAIL
Prothonotary of Cumberland County
1 Courthouse Square
Carlisle, PA 17013
Re: Home Elite Ltd., Inc. and P.R. Real Estate, LLC v. Hong
Tsang t/d/b/a China Garden
Docket No: 06-6679 and 06-6680
Dear Sir/Madam:
Enclosed please find an original and one copy of the Praecipe for
Writ of Execution Upon a Confessed Judgment, an original and one copy
of the Praecipe for Writ of Possession Upon a Confessed Judgment, and
two checks in the amount of $15.00 each, payable to Prothonotary of
Cumberland County. I understand that you will provide the Writs of
Execution and Possession. Kindly file the originals and return time-
stamped copies to me in the enclosed self-addressed stamped envelope
provided herewith.
I have also included a check in the amount of $250.00, payable to
Sheriff of Cumberland County, for enforcement of the writs.
To satisfy the judgment for possession in the above matter, the
www.fpdb.com Sheriff is to place the Plaintiffs, Home Elite Ltd., Inc. and P.R. Real
Estate, LLC, in lawful possession of the 1,600 square feet of commercial
space known as space L (the "Property"), currently being utilized as a
restaurant known as China Garden and located at the shopping center
commonly known as East Gate Plaza, located at 5205 Simpson Ferry
Road, Mechanicsburg, PA 17055.
To satisfy the judgment, interest, and costs against the Defendant,
Hong Tsang t/d/b/a China Garden, the Sheriff is to levy upon the
property of the Defendant located at the above-described Property,
including but not limited to any and all tangible property, possessions,
Frey Petrakis Deeb Blum & Briggs, P.C.
e. at F R E Y P E T R A K I S D E E B B L U M & B R I G G S, P. C.
Page 2
January 25, 2007
Prothonotary of Cumberland County
contents, equipment, appliances, fixtures, inventory, and the contents of any cash
register or safe located therein.
Please do not hesitate to contact me if you have any questions on the above.
Very truly yours,
404?- ??
CHRISTINA M. HUGHES
CMH/
Enclosures
cc: Ms. Mary Duffy
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-6679 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HOME ELITE LTD., INC. AND P.R. REAL ESTATE,
LLC, Plaintiff (s)
From HONG TSANG T/DB/A CHINA GARDEN, 5205 SIMPSON FERRY ROAD, SUITE 11,
MECHANICSBURG, PA 17055
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON THE
PROPERTY OF THE DEFENDANT LOCATED AT THE ABOVE-DESCRIBED
PROPERTY, INCLUDING BUT NOT LIMITED TO ANY AND ALL TANGIBLE
PROPERTY, POSSESSIONS, CONTENTS, EQUIPMENT, APPLIANCES, FIXTURES,
INVENTORY, AND THE CONTENTS OF ANY CASH REGISTER OR SAFE LOCATED
THEREIN.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $7,839.38
Interest
Atty's Comm %
Atty Paid $75.07
Plaintiff Paid
Date: JANUARY 30, 2007
(Seal)
L.L. $.50
Due Prothy $1.00
Other Costs
Curti . Long, Pro of
By:
Deputy
REQUESTING PARTY:
Name CHRISTINA M. HUGHES, ESQUIRE
Address: FREY, PETRAKIS, DEEB, BLUM & BRIGGS, P.C.
1601 MARKET STREET, SUITE 2600
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-563-0500
Supreme Court ID No. 91635
CASE NO: 2006-06679 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOME ELITE LTD INC ET AL
VS
TSANG HONG TDBA CHINA GARDEN
SHAWN HARRISON Sheriff or Deputy Sheriff f
Cumberland County,Pennsylvania, who being duly sworn acco ing to law,
says, the within NOTICE was served upo
TSANG HONG T/D/B/A CHINA GARDEN the
DEFENDANT at 1030:00 HOURS, on the 26th day of Dec
at 5205 SIMPSON FERRY RD SUITE 11
MECHANICSBURG, PA 17055 by handing to
a true and attested copy of NOTICE
r , 2006
tog?llher with
and at the same time directing His attention to the conte4s thereof.
Sheriff's Costs:
Docketing
Service
Postage
Surcharge
q1t
SHERIFF'S RETURN - REGULAR
So Answers:
18.00
9.68
.39
10.00 R. Thomas Kline
.00
? 38.07 00/00/0000 n
Sworn and Subscibed to
before me this day
of ,
By:
Deputy Sherip
A. D.
-.114
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that a
Sheriff's Sale of-personal property was held on Wednesday, June 6, 2007,
at which time the personal property of Hong Tsang T/DB/A China Garden, was sold to,
Home Elite LTD, Inc., et. al., of, 491 Old York Road, Suite 200, Jenkintown, PA 19046,
for the sum of $1.00, it being the highest bid and best price quoted for the same. Date
and Time of Sale, Wednesday, June 6, 2007 at, 11:00 A.M.E.D.S.T., at, 5205 Simpson
Ferry Road, Suite 11, Mechanicsburg, PA 17055.
Sheriff's Costs:
Docketing $ 18.00
Poundage 1.85
Advertising 10.00
Law Library .50
Prothonotary 1.00
Milage 23.04
Surcharge 20.00
Levy 20.00
Post Pone Sale
Garnishee
Postage
TOTAL $ 94.39 ? i ?b L T,
Pd by Defendant
So Answe • ;
R. Thomas Kline, Sheriff
By Ojqtt
0
r
c?
s?
?L G 4 ??9
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-6679 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HOME ELITE LTD., INC. AND P.R. REAL ESTATE,
LLC, Plaintiff (s)
From HONG TSANG T/D/B/A CHINA GARDEN, 5205 SIMPSON FERRY ROAD, SUITE 11,
MECHANICSBURG, PA 17055
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON THE
PROPERTY OF THE DEFENDANT LOCATED AT THE ABOVE-DESCRIBED
PROPERTY, INCLUDING BUT NOT LIMITED TO ANY AND ALL TANGIBLE
PROPERTY, POSSESSIONS, CONTENTS, EQUIPMENT, APPLIANCES, FIXTURES,
INVENTORY, AND THE CONTENTS OF ANY CASH REGISTER OR SAFE LOCATED
THEREIN.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $7,839.38
Interest
Atty's Comm %
Atty Paid $75.07
Plaintiff Paid
Date: JANUARY 30, 2007
(Seal)
L.L. $.50
Due Prothy $1.00
Other Costs
Curtis .
ng, Pro
By:
Deputy
REQUESTING PARTY:
Name CHRISTINA M. HUGHES, ESQUIRE
Address: FREY, PETRAKIS, DEER, BLUM & BRIGGS, P.C.
1601 MARKET STREET, SUITE 2600
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
?f
API a
SHERIFF'S SALE
BY VIRTUE OF WRIT OF EXECUTION NO. 2006-6679 CIVIL TERM ISSUED OUT
OF THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA, AND
TO ME DIRECTED, I WILL EXPOSE TO PUBLIC SALE ON WEDNESDAY, THE
6TH DAY OF JUNE 2007 AT 11:00 A.M., THE PROPERTY OF HONG TSANG,
T/DB/A CHINA GARDEN, AT, 5205 SIMPSON FERRY ROAD, SUITE 11,
MECHANICSBURG, CUMBERLAND COUNTY, PENNSYLVANIA.
THE FOLLOWING PROPERTY TO WIT:
CASH ON HAND:
$ 3.30 (NICKLES)
$ 13.80 (DIMES)
$ .50 (QUARTERS)
$ .20 (PENNIES)
17.80 TOTAL
BLACK NISSAN MAXIMA
REG. NO. FJG9884
VIN. NO. JN1HJOlF6PT11655
(REGISTERED TO HONG TSANG ONLY)
FRONT SALES/DINING AREA
CHAIRS (23)
TABLES (6)
CASH REGISTER (SANYO)
STEREO SYSTEM W/ SPEAKER (SONY)
CREDIT CARD PROCESSOR/PRINTER-MODEL 250
GLASS FRONT REFRIGERATOR UNIT CONTAINING- 24 OZ PEPSI PRODUCTS (24)
AND 12 OZ PEPSI PRODUCTS (11)
DECORATIVE GOLD BUDDHA STATUE
JADE ENCLOSED PICTURE IN FRAME
JADE/BLACK DECORATIVE FOLDING SCREEN
ARTIFICIAL FLOWER ARRANGEMENTS (5)
GLASS TABLE VASES (3)
FLOOR PLANTS (3)
CANDY/PEANUT MACHINE
NEON WINDOW SIGN
r
FRONT KITCHEN AREA
TELEPHONES (2) ?? r? -
ADDING MAC
VINYL TOPED COUNTER UNIT (3FT)
TABLES (2)
CHAIRS (4)
DEEP FRYING SYSTEM W/ 5 FRYING BASKET UNIT (DEAN)
COMMERCIAL STAINLESS STEEL STOVE - 2 BURNER (GARLAND)
10 FT STAINLESS STEEL GRILL UNIT W EXHAUST FAN AND SPRINKLER SYSTEM
(STANDARD)
STAINLESS STEEL SERVING TABLE WITH 7 STAINLESS STEEL CANISTERS W/LIDS
REFRIGERATOR UNIT/SERVING TABLE (5FT)
STAINLESS STEEL SERVING TABLES - 4 FT (2)
SERVING/STORAGE TABLE (2 SHEL
TOASTER OVEN (BLACK & DECKER)
MICROWAVE (SHARP) ?.
COUNTER DISPLAY W/GREEN VINYL TOP (5FT)
STORAGE/SERVING CO - GRAY- (3FT)
VACUUM (KENMORE)
STAINLESS STEEL 3 T WITH DRAINAGE COUNTERS (10 FT)
ASST POTS/PANS/WOKS
ASST UTENSILS
UPRIGHT WARMING OVEN (NO MANUFACTURER VISABLE)
COMMERCIAL RI RS (2)
PORCELAIN S
WALK IN COOLER W. WINTER) EMPTY
WALL CLOCK
STORAGE RACKS W/SHELVES (2)
FIRE EXTINGUISHER (COMMERCIAL SIZE)
REAR KITCHEN AREA
TABLE
CHAIRS (5)
ROUND TABLE TOPS (3)
OFFICE CHAIRS (2)
TABLE BASES (7)
COMMERCIAL ICE MACHINE (ICE-O-MATIC)
STAINLESS STEEL COFFEE MAKER (3 STATION)
STAINLESS STEEL 2 SHELF UNIT
SERVING TRAY RACK
SMALL TEA POTS - STAINLESS- (7)
?,
LARGE WHITE CHEST FREEZERS (3)
WIRE TRAYS (3)
VCR (SONY)
TELEVISION (SHARP- BROKEN)
DVD (MAGNAVOX)
WOODEN TABLE
HALOGEN FLASHLIGHT (YELLOW)
GOLF CLUB
PAPER CUTTER (2'X 2')
UPRIGHT VACUUM (DIRT DEVIL)
PVC PIPE (3 SECTIONS)
UMBRELLAS (3)
SMALL FLOOR JACK (BLUE)
TENNIS RACKET (WILSON)
(A) ALL CLAIMS TO PROPERTY MUST BE CERTIFIED AND FILED WITH
THE SHERIFF BEFORE THE SALE, ALONG WITH THE PRESCRIBED FEE
OF FIFTY-FIVE DOLLARS ($55.00)
(B) ALL CLAIMS TO THE PROCEEDS MUST BE FILED WITH THE SHERIFF
BEFORE DISTRIBUTION.
(C) THE SHERIFF'S SCHEDULE OF DISTRIBUTION WILL BE FILED IN HIS
OFFICE ON THE 11' DAY OF JUNE 2007 NOT LATER THAN FIVE (5)
DAYS AFTER THE SALE, AND DISTRIBUTION WILL BE MADE IN
ACCORDANCE WITH THE SCHEDULE UNLESS EXCEPTIONS ARE FILED
WITHIN THE TEN (10) DAYS THEREAFTER.
TOGETHER WITH ALL THE BALANCE OF THE DEFENDANT'S PERSONAL
PROPERTY SEIZED AND TAKEN IN EXECUTION AS PROPERTY OF HONG
TSANG, T/DB/A CHINA GARDEN, AT, 5205 SIMPSON FERRY ROAD, SUITE 11
MECHANICSBURG, CUMBERLAND COUNTY, PENNSYLVANIA.
AND TO BE SOLD BY:
R. THOMAS KLINE, SHERIFF
CUMBERLAND COUNTY SHERIFF'S OFFICE
CARLISLE, PA 17013
POSTED`
CUMBERLAND COUNTY
SHERIFF'S OFFICE c
CARLISLE, PA 17013
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that a
Sheriffs Sale of-personal property was held on Wednesday, June 6, 2007,
at which time the personal property of Hong Tsang T/DB/A China Garden, was sold to,
Home Elite LTD, Inc., et. al., of, 491 Old York Road, Suite 200, Jenldntown, PA 19046,
for the sum of $1.00, it being the highest bid and best price quoted for the same. Date
and Time of Sale, Wednesday, June 6, 2007 at, 11:00 A.M.E.D.S.T., at, 5205 Simpson
Ferry Road, Suite 11, Mechanicsburg, PA 17055.
Sworn and Subscribed to before me this
day of)xmM16a-"- 2008 A.D.
Notary Public
So Answ
R. Thomas Kline, eriff
By