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(Barton, Thomas) (Entered: 02/11/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/454825759/","id":454825759,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/72261396/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/469754553/","id":469754553,"tags":[],"absolute_url":"/docket/72261396/2/lex-capital-llc-v-first-american-title-insurance-company/","date_created":"2026-02-23T23:20:41.898785-08:00","date_modified":"2026-02-23T23:20:41.924977-08:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"2","attachment_number":null,"pacer_doc_id":"055018050854","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"","acms_document_guid":""}],"date_created":"2026-02-23T23:20:41.763235-08:00","date_modified":"2026-02-23T23:20:41.792241-08:00","date_filed":"2026-02-10","time_filed":null,"entry_number":2,"recap_sequence_number":"2026-02-10.002","pacer_sequence_number":9,"description":"ANSWER to 1 NOTICE OF REMOVAL with Jury Demand by First American Title Insurance Company. Discovery ends on 7/10/2026. Filed in the Superior Court of Henry County on 2/9/2026(ajw) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 02/11/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/454825758/","id":454825758,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/72261396/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/469754552/","id":469754552,"tags":[],"absolute_url":"/docket/72261396/1/lex-capital-llc-v-first-american-title-insurance-company/","date_created":"2026-02-23T23:20:41.640364-08:00","date_modified":"2026-02-23T23:20:41.694935-08:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"1","attachment_number":null,"pacer_doc_id":"055018050824","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/469754565/","id":469754565,"tags":[],"absolute_url":"/docket/72261396/1/1/lex-capital-llc-v-first-american-title-insurance-company/","date_created":"2026-02-23T23:21:10.662076-08:00","date_modified":"2026-02-26T05:01:18.306376-08:00","sha1":"284fafba6158e3f5efcd5b04bb235e45398dbe50","page_count":25,"file_size":11834798,"filepath_local":"recap/gov.uscourts.gand.355402/gov.uscourts.gand.355402.1.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.gand.355402/gov.uscourts.gand.355402.1.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 1:26-cv-00765-WMR Documenti-1 Filed 02/10/26 Page 1of 25\n\n\u20ac2 EFILED IN OFFICE\npemaerecs aa ta ay ec -- _CLERK_OF SUPERIOR.COURT_\u2014\nHENRY COUNTY, GEORGIA\n\nSUCV20250041 35\n\nDEC 306, 2025 11:49 AM\n\nIN THE SUPERIOR COURT OF HENRY COUNTY\n\nSTATE OF GEORGIA Are, [be\n\nLEX CAPITAL, LLC, a Georgia ) See\nLimited Liability Company, )\n\nPlaintiff, )\nVS. ) Ctvil Action File No.\nFIRST AMERICAN TITLE )\nINSURANCE COMPANY, )\nA Nebraska Corporation, )\n\nDefendant )\n\nCOMPLAINT FOR BREACH OF CONTRACT\n\nCOMES NOW, LEX CAPITAL, LLC, a Georgia Limited Liability Company,\nPLAINTIFF, and hereby files this COMPLAINT FOR BREACH OF CONTRACT\nagainst FIRST AMERICAN TITLE INSURANCE COMPANY, A Nebraska\n\nCorporation, DEFENDANT, and shows the Court as follows:\n\nl.\n\nDefendant is a corporation organized and existing under the laws of the State\nof Nebraska. Defendant may be served with process by serving its registered agent\nin the State of Georgia, Corporation Service Company, 2 Sun Court, Suite 400,\n\nPeachtree Corners, GA 30092.\n\fCase 1:26-cv-00765-WMR Documenti1-1 Filed 02/10/26 Page 2 of 25\n\nOn October 17, 2016, Plaintiff purchased an improved tract of land at 6941\nPeachtree Industrial Boulevard, Peachtree Comers, GA 30092, hereinafter referred\nto as \u201cthe property.\u201d In connection with that acquisition and on the same date,\nDefendant sold Plaintiff an owner\u2019s policy of title insurance, insuring against loss or\ndamage sustained or incurred by Plaintiff as a result of certain risks associated with\nthe ownership of the property. A true and accurate copy of the described owner\u2019s\npolicy of title insurance is attached hereto as Exhibit \u201cA.\u201d The owner\u2019s policy of\n\ntitle insurance is hereinafter referred to as \u201cthe title policy.\u201d\n\nIn selling the title policy to Plaintiff, Defendant purposefully performed acts\nand consummated a business transaction in the State of Georgia. This action arises\nfrom such acts and transaction. Defendant is therefore within the jurisdiction of the\n\ncourt pursuant to OCGA \u00a79-10-91.\n\nPlaintiff's office and place of doing business is in Henry County, Georgia.\nThe title policy was sold, issued and delivered to Plaintiff in Henry County, Georgia\n\nby Defendant\u2019s agent William A. Miller, P.C., whose office and place of business\n\fCase 1:26-cv-00765-WMR Documenti1-1 Filed 02/10/26 Page 3 of 25\n\nwas also in Henry County Georgia. Henry County is therefore a legally appropriate\n\nand correct venue for this action pursuant to OCGA \u00a79-10-93.\n\nSubject to specifically stated exclusions and exceptions, the title policy\ninsured against specified risks associated with ownership of the property, including,\nbut not limited to: (a) title being vested other than as stated in the policy; (b) any\ndefect in or lien or encumbrance on the title; and (c) any encroachment,\nencumbrance, variation, or adverse circumstance affecting the title that would be\ndisclosed by an accurate survey of the land, specifically including encroachments\n\nonto the land of existing improvements located on adjoining land.\n\nIn July of 2022, a large sinkhole developed on the property, blocking\nPlaintiffs access to it and the business premises located on it. Upon investigation.\nPlaintiff discovered that the sinkhole was caused by the failure of a system of\nunderground pipes designed to convey under and through Plaintiff\u2019s property and\nadjoining tracts of land to a retention pond owned by Gwinnett County large amounts\nof stormwater runoff collected along Peachtree Industrial Boulevard. Plaintiff at this\ntime has not determined who installed the system of underground pipes. However,\n\nexamination of the title to the property reveals that the discharge of stormwater\n\fCase 1:26-cv-00765-WMR Documenti1-1 Filed 02/10/26 Page 4of 25\n\nrunoff from Peachtree Industrial Boulevard onto Plaintiff\u2019s property and one or more\nadjoining tracts of land is authorized by an casement granted to the Georgia State\nHighway Department in 1966 by one of Plaintiff\u2019s predecessors in title. The\ndescribed easement, which is recorded at Deed Book 260, Pages 402-404, Gwinnett\nCounty records, was not disclosed in the title report prepared by Defendant\u2019s agent\nat the time Plaintiff purchased the property, is not set out as an exception to the\nguaranty of fee simple title in the title policy, and is not excluded from coverage by\n\nthe terms of the policy.\n\nOn September 27, 2022, Plaintiff sent written notice to Defendant of the\nexistence of the sinkhole, the system of underground pipes, and the undisclosed\ndrainage easement described in paragraph 6, and demanded that Defendant honor its\nobligations under the title policy. Defendant initially denied the claim, but after\nreconsideration acknowledged in a letter dated October 31, 2022 that coverage is\nafforded for the drainage easement granted to the Georgia State Highway\nDepartment. A true and accurate copy of Defendant\u2019s October 31, 2022 letter is\n\nattached as Exhibit \u201c\u201cB.\u201d\n\fCase 1:26-cv-00765-WMR Documenti-1 Filed 02/10/26 Page 5of 25\n\nThe title policy gives Defendant the right to elect from specified remedies to\nsatisfy its obligations under the policy, including legal or other action to cure or\nremove a title defect or encumbrance, or payment of Plaintiff\u2019s monetary loss. In its\nletter of October 31, 2022, Defendant stated it would pay the monetary loss, which\nit contends is defined by the title policy as the difference between the value of the\ntitle without the drainage easement and the value of the title subject to the drainage\neasement. Defendant thereafter obtained a diminution in value appraisal and\nprovided a copy of it to Plaintiff. However, the appraisal grossly underestimated the\ndiminution in value of the property caused by the drainage easement; and Defendant\nsince has failed, despite a written, time-limited demand from Plaintiff, to pay the\n\nactual diminution in value of the property caused by that easement.\n\nDefendant has refused to honor its obligations pursuant to the title policy and\nhas breached its contract with Plaintiff. Plaintiff is entitled to a judgment against\nDefendant for breach of contract and damages for the actual diminution in value of\nPlaintiff\u2019s property caused by the Georgia State Highway Department drainage\n\n\u2018easement.\n\fCase 1:26-cv-00765-WMR Documenti1-1 Filed 02/10/26 Page 6 of 25\n\nIn addition to breaching its contract with Plaintiff, Defendant\u2019s refusal to pay\nthe loss covered by the title policy was in bad faith. More than sixty days have\npassed since Plaintiff's demand for payment was made, and Defendant is liable to\nPlaintiff, in addition to the damages stated above, for bad faith damages of not more\nthan fifty percent of the liability of the insurer for the loss or $5,000.00, whichever\nis greater, and all reasonable attorney's fees for the prosecution of the action against\n\nthe insurer, pursuant to O.C.G.A, \u00a7 33-4-6.\n\nWHEREFORE, Plaintiff demands:\n\n(a) that a summons be issued requiring Defendant to answer this complaint\nwithin the time permitted by law;\n\n(b) that process be served on Defendant in a manner authorized by law;\n\n(c) trial by jury;\n\n(d) a judgment against Defendant for such sum as may be established by the\nevidence;\n\n(e) ajudgment against Defendant for bad faith damages, pursuant to O.C.G.A.\n\u00a7 33-4-6;\n\n(f) a judgment for the costs of this action; and\n\n(g) such additional relief as may be appropriate.\n\fCase 1:26-cv-00765-WMR Documenti-1 _ Filed 02/10/26 Page 7 of 25\n\nAusband & Dumont\n\n825 Fairways Court, Suite 300\nStockbridge, GA 30281\n\n(678) 593-3000\nandyausband@ausbandlaw.com\n\nRespectfully submitted,\n\n/s/Andrew C. Ausband//\nAndrew C. Ausband\nGa. Bar No. 028602\n\nAttorney for Plaintiff\n\fCase 1:26-cv-00765-WMR Documenti-1 _ Filed 02/10/26 Page 8 of 25\n- EXHIBIT A .\n\nof | Owner's Policy of Title Insurance\n\u00bb | First American Tile\" \u201csar ls cab _ |\n\nFirst American Title Insurance Company\n\nOwner's Policy | sortai3-01310786\n\nAny notice of clalm-and ary other-notico of statement in writing required to be'divan to the Company under this polley must be given to the\nCompany at the address shown In Se\u00e9tion 18-0f the Conditions.\n\n\u201cCOVERED RISKS\n\nSUBJECT TO THE EXCLUSIONS: FROM COVERAGE, THE EXCEPTIONS FROM COVERAGE CONTAINED: IN SCHEDULE 8, AND THE\nCONDITIONS, FIRST AMERICAN TITLE INSURANCE COMPANY, a Nebraska corporation (the *Company\u2019) insures, as of Date of Policy and, to-the\n\u2018extent stated in Covered Risks 9 and.10, afler'Date of Policy, against loss or. damage, not exceeding the Amountof Insurance, sustained or incurred by\nthe Insured by reason of: ,\n\n1. Title being vested other tan as stated in Schedule A,\n\n2. Any defect incor lien or encumbrance on the Title. This Covered Risk includ\u00e9s But is nof fimited to insurance against loss from\nfa}. Adefectin the Title caused by. : . . -\n() forgery, fraud, undue influence, duress, incompetency, incapacity, Grimpersonation;\n(). fallure\u2018of any person or Entity to have authorized a transfer or-conveyance;\n{i}. a document affecting Title not property created, executed, witnessed, sealed, acknowledged, notarized; or delivered;\n(iv) Jaiture to perform those acts necessary to.creale.a document by electronic means.authorized by-law,\n(v}. a documentexacuted under a falsified, expired, or. otherwise invalid power of attorney,\n\n{vij a document not properly filed, recorded, or indexed in the. Public Records including failute to perform those acts by electtonic means\n\nauthorized by. law; or\n- {vil} a defective judicial or administrative proceeding. 2 i, .\n\n(b) The lien ofreal estate taxes cf assessments imposed on the Tite by a governmental authority due or payable, but unpaid.\n\n(c). Any encroachment; encumbrance, violation, vafiation, ar adverse circumstance affecting the Title that would be disclosed by an-accurate and\ncomplete land survay-of the Land. The term. \u201cenerdachment\u00ae inclides; ancroachmants of existing. improvements located onthe Land onto\nadjoining fand, and encroachments onto tie Land of existing improvements located on adjoining land.\n\nUnmarketable Tile, .\n\nNo right of ace\u00e9ss'to and from the Land,\u201d\n\nBe\n\n(Covered Risks Continued on Page 2)\n\nWrisinocs Whore! Evel Amarean Tile Insurance Company has caused its corporate name. to be fereunto affixed by is authorized officers as of Date\n\nof Poli\u00a2y.shown in Schedule. A, a Z\nFirst American Title Insurance Company For Reference:\n| aes ee a Fila #: 16-2266\n\n_Issued By: _ oo\n\n: \u2018William A. Miller,P.C.\n\u2018Dennis J, Gilmore \u2018William A. Mifler, P.C., 2330 Patrick Henry Parkway,\n; \u2018President. Suite.350 . ie at\na Oe. McDonough, GA 30253\nJeffrey S::Robingon\nSecretary.\n(This Policy is valid-only when Sthedulea A and:B are attached) This jacket was created clectronically snd constfutes an criginal document\nCepyright 2606.2008 Anierican Lang Tinie Association, All rights re\u00e9servad, Tha use of th form is Faiicted tn ALTA Jicengens and ALTA members in good sanding os of tne date.o} use.\nAll other uses ate prohibited: Reprinted undar izense from the Amarcen Land Tile Associaton, ~ : ss :\nFor 5019413 (734-14) ~ Page of \u00a7 F BO : a ALTA-Gwoer's Policy of Tite Inistiance (6-17-06)\n2 Georgia.\n\f_ Policy #; 5019413-0131078e:\n\nCase 1:26-cv-00765-WMR Documenti1-1 Filed 02/10/26 Page Qof 25\n\n- \u2014COVERED-RISKS {Continued} \u2014 \u2014\u2014-\n\u00a7. Tho Vidlation or enforcement of any law, ofdinance; permit, of gavemmental regulation. (including those relating to building and zoning) restrieting,\n\nregulating, prohibiting, or relating to\n(a) the-occupancy, usd, or enjoyment of the Land}.\n\nib} the character, dimensions, or location:of any improvement erected on the Land;\n\n(c). the:subdivision:of land; or\n\n(d) environni\u00e9ntal protection\n\nif a notice, describing any part of- the Land, is: recorded in the.Public Records satting forth the violation or infention fo enforce, but only to the extent\n\nof the violation cr enforcement referred to:in that notice.\n\n6. An enforcement-action based on the exercise ofa govermmental-police powers not covered by Covered Risk 5 if a notice of the enforcement action,\n\u2018describing any part-of the Land, is.fecofd\u00e9d inthe Public Records, but only to the extent of the enforcement refered to in that notice.\n\n7. The exercise of the rights \u2018of eminent domain if'a notice of the exercise, describing any part of the Land, is. recorded in the Public Records.\n\n8. Any taking by a dovernmenital body. that has occurr\u00e9d afd fs binding on the rights of a purchaser for value without Knowledge.\n\n9. Title being vested other than as slated In Schedule A or being defective\n\nfa) as.a\u2018result of the avoidance .in whole or\u2018in part, or from.acourt order providing an altematlve remedy, of a transfer of all or-any:part of the title\nto-or any Int\u00e9rest In the Land occurring prior to the transaction vesting Tille-as: shown in Schedule A-bacause thal prior transfer constituled a\nfraudulent or pref\u00e9rential transfer under federal bankruptcy, state insolvency, or similar creditors\u2019 rights laws; or\n\n(b) because the instrument of transfer vesting Titie as shown in Schedule A constitutes a preferential transfer under federal bankruptcy, state\ninsolvency, or similar creditors\u2018 rights laws by-reason of the failure of its r\u00e9cording in the Public Records\n\nii) tobe timely, or\n\n{ii}. to impart notice:of its existence to'a purchaser for value or toa judgment or lier: creditor:\n10, Any defect in or fen or encumbrance on: tha Title or:other matter included in Covered Risks 1 through 9 that has-been created or atlached orhas\n\nte Public Records that vests Title as shown in Schedule A.\n\n\u2018been filed or recorded in-the.Public Records subsequent to Date of Policy and ptior to i racotding ofthe dead or other instrument of trarisfer In\n\nThe Company will also pay: the cols, | \u2018attorneys\" fees, and expenses incurred in dafens\u00e9-of any matter insured against. by this: Policy, Dut only te the\nextent.provided in the Conditions.\n\nThe'\u2018following matters\u2018are: xnreasiy excluded from the'e coverage Gfithis -\n\nEXCLUSIONS FROM COVERAGE\n\npolicy, and.the: \u2018Company will-aot pay loss or damage,. cosls,. atlomneys'\nor expenses that atise byreasonof! = =~\n\n(a) Any law, ordinance, permit, of goverfimental regulation ..\n(including those relaling to building and: zoning) restricting, ~:\n\nregulating, Brohibiting, or relating to\n\n(i) the occupancy, use, or enjoyment of the Land;\n\n(ij}- the character, -\nimprovement efectad on the Land;\n\n{ji} the:subdivision:of Jand; or.\n\n(iF environmental protection:\n\nor the effect of any: violation of these\u2019 laws, cna, of\n\ngov\u00e9rnmental regulations. \u201cThis. Exclusion: 1{a) does -not\n\nmodify of limit the coverage. provided under Covered Risk 5.\n\n~ {b) Any. govermental. police:power, \u2018This Exclusion 1(b)\": \u201cd\u00e9as\nnot modify or limit the coverage, provided under'Covered Risk .-\n\ndimerisions, of locatitn. of .any ~\n\no net Known io the Company, not recorded in the Public\nRecords at Date-of Palicy, but Known {0 the Insured Claimant\nand not disclosed in writing tothe Canipany by the Insured\nClaimant prior to the date the Insured Claimant became an\nInsured undar this policy;\n\n{c). resulting inno loss or damage to the tisured Claimant;\n\n_(d} attaching or created subsequent to: Dale of Policy (however,\n\nthis'.does' not modify\u2019 or limit the coverage provided \u2018under \u00b0\nCovered Risk 9 and 10); or\n\n\u201c{@) resulting In loss or damage that would not have been\n\nsustained if the Insured Claimant had paid value for the Title.\n\n. Any claim, by-reason of the operation of federal bankruptcy, state\n- \u2018Insolvency, -or similar creditors\u2019 fights laws, that the transaction\n\nvesting the Title as shown in\u2019Schedule A, is.\n\n\u201c\u2014~(a)_ afraudulent conveyance or fratidulent transfer; or\n:(b) a preferentiattansfer for any feason not stated in Covered\n\n6, Risk 9 of.this policy..\n2, Rights of. eminent domain.. This: Exclusion dees.nat \u2018modify or fimit .., Any lien on-the Tite for real estate taxes or assesstitents imposed\nthe coverage provided under Covered Risk:7 or 8. \u2018by govemmental authority and created or \u2018aitaching between Date\n3. Defects, Hens, encumbrances, adverse.claims, or other matters of Policy'and the:date of recording of the deed or other instrument\n\n(a) ct\u00e9ated, suffered, assumed, or agreed fo by the. Insured\n\n__Of transfer in the Public Records that vests Title as shown: in\n\u201cSchedule A.\n\nForm 5014413 (71-14)\n\n= \"Page Dot 5 | =\n\nALTA \u2018Ownar's Pollcy of Title Insurance (6-17-06)\nGeorgia\n\f___ Policy #:, 5011413-0131078e\n\n1,\n\n~=() \"Land\":\n\n(h) \u201cMortgage*:\n\nCase 1:26-cv-00765-WMR Document 1-1\n\nDEFINITION OF TERMS\nThe following:terms when used in this poligy: mean:\n\n(a) \u201cAmount of Insurance\u2019: The amount stated in Schedule A, as.\n\nmay be increased or decreased by endorsement to this policy,\nincreased by Section 8(b), or decreased:by Sections 10.and 14\nof these Conditions.\n\n(b) \u201cDate of Policy\": The date designated as \u201cDate. of Polley\u201d in\nSchedul\u00e9:A.\n\nfc) \u201cEntity: A cofporation, parthership, frust, lirnited iability\n\ncompany, or other similar legal: entity.\n(d} \u201cInsured\u2122 \u201cThe insured.named int Schedule A.\n(i) The term\u201cInsured\u2019 also includes \u2014\n\n(A) successors fo the Title: ofthe Insured by operation of |\n\nlaw as .distinguished \u2018fram purchase, including helrs,\ndevisees, suryivors;. \u2018personal representatives, or\nText of kin;\n\n(B)- successors to. an. Insured: by dissolution, merger, \u2014\n\n- consolidation, distribution, or: Feorganization:\n\n(C) successors to an Insured by: its conversion to-another\n\nkind of Entity;\n\n{D) a grantee of an Insured under a. deed dajivered:\n. without payment of actual. Valuable :consideration:\n\nconveying the Tile\n(1) if the stock, shares, memberships, of other\n- seguity interests of the grantes ee wn\n\u2018by the named Insured,\n\u201d (2) ifthe grantee wholly owns the'named Insured,\n(3) if the grantee is wholly-owned.by an affiliated\n\nEntity of the named:Insured, provided, the |\n\naffiliated Entity. andthe named insured are both\nwholly-owned \u2018by! the same'person or Entity, of\n\n(4) \u2018Wfthe granteeis:a trustee or beneficiary of a tris:\n\ncreated: by a.written instrument established by\n\nthe Insured: h\u00e9med.in Schedule A for estate\n\nplanning purposes.\n\n(i) \u2018Wilh regard to (A), (B), (C),-and (D). reserving, however:\nall rights.and defenses as to any successor that. the\n\u2018Company -woutd: have . had against any Pletecestor\n\nInsured.\n\n{e) \"insured: Claimant\": An Insured claiming loss OF: damage.\n\n(f) \"Knowledge\" or \u201cKnown\u201d: Actual\u2019 knowledge; net constructive\nknowledge or notice that {may be imputed to aq insured by\n\nreason of the. Public Records. or any othar records that inpar.\n\nconstru\u00e9tive nolice of matters affecting the Tile;\n\nimprovements that by] law constilule-real property. The term\n\n\u2018and\u2019 does not include any property: bayond the lines of the.\n\narea-dascribed in Schedule.A, nor-any right, \u2018tile; interest;\n\u2018estate, or easement in abutting\u2019streets, roads, avenues, alleys,\n\nJanes, ways, or waterways; but.this does not modify or fimit the:\n\nextent that a right of access fo\u2019and from. the kand'is insured by\n\n\u2018this policy. .\n\nMortgage, deed -of trust; inost_ deed; \u2018or -other\nsecurity instrument, including. one evidenced \u2018by electronic\nmeans authorizedbylaw.\n\n(i) \u201cPublic Records\": Records. established under-state statutes \u2018at\nDate.of Policy for the purpose of: imparting constructive naiice.\nof matters relating to.real property to purchasers for valle and\n\n\u201cThe \u2018land deserb\u00e9d-in Schedule\u201dA, and afixed .-\n\nFiled 02/10/26 Page 10 of 25\n\nCONDITIONS\n\nRecords\u201d shalliaiso Includ\u00e9 envizonmental protection liens filled\nin the records of the clerk of the United States District Court for\n_ the district where the Landis located.\n{}) \u201cTitle\u201d: The estate or interest described in Schedule A.\n\n{x} \"Unmarketable Tite\u2019: Title affected by.an alleged or apparent\n\nmatter fiat would permit.a prospective purchaser or lessea of\nthe Title. or lender -on the Title to be released from the\nobligation to purchase, tease, oF lend if there is a contractual\ncondition requiring the delivery of marketable fitle.\n\n2. GONTINUATION OF INSURANCE\n\nThe coverage of this policy sha'l continue in force as of Dale of\nPolicy in favor of an Insured, bul only so.long as the Insured retains.\nan estate or interest in the. Land, of holds an obligation secured by.a\npurchase money Mortgage given by a purchaser from the insured,\nor only so long as the Insured shall have liabifiy by reason of\nwarranties: in; any transfer or conveyance-of the Tita, \u2018This policy\nshall nat continue in force in favor of any purchaser from the Insured\nof either (1) an estate or interest in the Land, or i} an obligation\nsecured by a purchase money Morigage given to the Insured,\nNOTICE OF CLAIM TO BE GIVEN BY INSURED CLAIMANT\n\nThe Insured. shall notify the Company promptly in, writing (i) incase\nof any lifigation as set forth in Section 5(a) of these Conditions, {i i) in\n\ncase Knowledge shall come fo.an Jnsured:heraunder of any.claim of\n\ntile or interest thal is adverse to th\u00e9 Tille; as insured, and'that might\n\n~ -gause loss or damage for which the Company may be Hable by:\nvirtue of this policy, or (ii) if-the \u201cTitle, as insured, is rejected as\n\nUnenarketable Tite. If the Company is prejudiced by the failure of.\nthe Insured Claimant to provide prompt notice, the Company's\nliability to the Insured Claimant under the:policy shall be reduced to\nthe extent of the prejudice.\n\nPROOF OF LOSS:\n\ninthe evertithe Conipany is whable to determine the amount of loss\nor damaga, the: Company may, at its option, require as a: condition\nof payment thal the Insured Claimant furrish a.signed proof of loss.\nThe: proof of loss must describe \u2018the defect, lien, encumbrance, or\nother malter.insured against -by this policy that constitutes the basis\nof loss or damage atid shall state, to the extent possible. tha basis\nof calculating the amount of the loss or damage.\n\n_ DEFENSE AND PROSECUTION OF ACTIONS\n\n{a) -\u2018Upon-written-request by the Ingured, and subject to'the options\n-\u00e9ontained in Section 7 of these Conditions; the Company, at its\nown cost and withoul unreasonable delay, shall provide for the\n_ defense of an, Insured in litigation in which any third party\nasserts a claim covered by this policy adverse to the Insured,\nThis: obligation: is limited to only thas.stated: causes of action\nalleging matters insured against by this policy, The Company\n_shall have the right to select counsel of its choice {subject to\n--the right of tle Inguf\u00e9d to cbject for reasonable cause). to\nrepresent the Insured as to those stated causes of'action. It\nshail not be\u2018 fable for and will nct:pay the fees of any other\n\u201ccounsel... The Company will not \u2018pay any fees, costs, or\nexpenses In\u00e9urred by the. insured in the defansa of those\n\u201ccauses of action that allege matters not insured against by this\npolicy.\n{b}. The C\u00e9rmpariy shall have the right,, in addition to.tha options\ncontained in Section 7 of these Conditions, al its own cost, to\ninstitute and prosecute any aclion or proceeding. or to do any\n_ other. act that\u2018in its opinion: may be.necessary oF desirable\u2019 to\nestablish the Title, a8 insuzed, or to. prevent of reduce loss or\n\nwithout Knowledge. Wilh respect to Covered Ri Risk $k 5), \u201cPublic\n| Form 8011413 (7-1-14)\n\nPage. 3: ofS | -\n\n\"ALTA Owners: Poly of Tide insurance. (6-17-08)\nGeorgia\n\f_____ Polley #:, 5014413-01310788._ =. se\n\n(c)\n\nCase 1:26-cv-00765-WMR Document1-1_ Filed 02/10/26 Page 11 of 25\n\ndamage td the insured. The arpa 3 may take any\nappropriate action under the'terms of Ihis'palicy, whether-or nat\nit shall be liable-to the Insured. The exercise-of these sights\nshall not'be-an admission. of liability or waiver of any provision\nof this policy, If the Company exercises Its righls. under this\nsubsection,.it must do sodiligently.\n\nWhenever tha Company brings .an action'or asserts a defense\nas required or permitted by this policy, the Company may\npursue the: litigation to:.a final determination by a court of\ncompetent jurisdiction, and It expressly reserves: he: right, in its\nsole discration, to.appeal any adverse judgment or order.\n\n6. DUTY-OF INSURED CLAIMANT TO.COOPERATE\n\n(a)\n\n{oy\n\n7. OPTIONS TO PAY OR OTHERWISE SETTLE CLAIMS;\n\nIn-all cases where this policy parmnits or requires the Company.to-\n\nprosecute or provide forthe defense of any action or praceeding\n\n\u2018and any appeals, the Insured shall secure tothe Company the\n\nright to so prosecute or provide defense in the action or\nproceeding, including the right to-use, at ils option; the name of\n\n\u2018the Insured: for this: purpose. Whenever requested by the\n\nCompany, the Insured, at the Company's. EXPENSE, shali-give the:\n\n\u2018Company all reasonable aid (i), in securing evidence, obtaining\n\nwithasses, prosecuting or defending the-action:\u00e9r proceeding, or\neffecting: settlement, and:-(i) in any-other lawful act that in the\nopinion of the Company maybe necessary. or desirable ta\nestablish tie Tille or any.cther matter as insured. If the Company.\n\nis-prejudiced by the failure of the Insured to.furnish the. requited\n\ncooperation, the\u2019 Compariy\u2019s obligations to the Insured under the\npolicy shai \u2018terminate, including any Tability of obligation to\n\ndefand, prosecula, or continue\u2019 any Mitigation, with, regard tothe.\n\nmatter of matters requiring such cooperation.\nTha Company may reasonably require-ttie Insured Claimant to\n\nsubmit, fo examination undar oath by any authorized:\nrepresentative of the. Company andito produce for examination;\ninspection, and | \u2018copying, at'such- reasonable tithes arid plac\u00e9s:\n\nas may be.designaled by the authorized. rapresentative. of the.\nCompany, all. records, in whatever medium malitaited,\nincluding books, ledgers, checks, \u00a9 memoranda,\ncorrespondence, reports, e-mails, Gisks, fapes, and\u2019 videos\nwhether bearing a date before or after Date of Polly, that\n\nreasonably pertain fo theloss: ordamage. Further, ifrequested.\n\nby any authorized representative of the Company, the Insured\nClaimant shall grant its permission; in writing, for any\nauthorized representative of the Company to examine; inspect,\nand copy. all of these:records inthe custody of-control of 8 third\nparty. that reasonably pertain\u2019 \u2018to the: losger damage. Ail\n\ninformation. designated as. confidential\u2018by the Insured Claimant:\n\u2018provided to the Company: pursuant to'this Section shall not-be:\ndisclosed to otiers unless, in: the reasonable. judgment of tha.\n\u2018Company, it is necessary In. the administration of the claim.\n- Failure of the insured Claimant to.subinit for examination under\noath, produce any reasonably requested information, or grant\npermission, to. secure reasonably necessary information from:\nthird parties as- required\u2019 in this subsection, unless prohibited by.\n\nFaw of govemmerital regulation, shall: terminate.any fi fability: of\nthe Company under.this policy'as'to that claim.\n\nTERMINATION OF LIABILITY =...\n\nJn case of @ claim under this poricy, the Company shail. hav\u00e9 the\nfollowing additional options:\n\n(a) To Pay or Tender Paymant of the Amount of Insurance.\n\n4 \u00ab =~ CONDITIONS (Continued) \u2014-\u2014 \u2014\n\nTo payor tender payment of the Amount of Insurance under\nthis policy togelhar with any. cosis, altomeys' fees, and\nexpenses Incurred by the Insured Claimant that were\nauthorized by the Company up to the time of payment or tender\nof paym\u00e9nt and that the Gompany is obligated'to pay.\nUpon the exercise by the Company. ef this option,. all Rabliity:\n\u2018and obfigations of the Company to the Insured under this\npolicy, other tlian to make the payment required in this\n\u2018subsection, shail terminate, ingluding any liability or obligation\nto defend, prosecute, or continue any litigation.\n(b). To Pay or Otherwise Settle With Parties Other Than the\ninsured or Wilh the Insuted Claimant.\n()} To pay or otherwise settle with other parties for or:in the\n\"name of an Insured. Claimant any claim insured against\nunder this policy. If addition, the Company will pay any\ncosts, attorneys\u2019 fees, and expenses incurred, by the\nInsured Claimant that were.authorized by:the Company up\ntothe Unie-of payment and that the\u2019 Company is obligated\nto-pay; or\nffi) To:pay er- -othaniise settle with the Insured Claimant the\n\u201c\u201d fass or damage \u2018provided for under this policy, together\nwith-any costs, atlomeys' fees, and expenses incurred. by\nthe Insured Claimant. that were authorized by the\nCompany: up to \u2018the time of payment and\u2019 that we)\nCompany-is obligated to: pay,\n\u2018UJjpon the exercis\u00e9 by the Company of either of the options\nprovided for in subsections (6)()), or (i), the Company's\n-ebligations to the Insur\u00e9d under this policy for the claimed loss:\nor damage, other than the payments requited:to be made, shail\n\u2018terminate, including any liability or obligation te defend,\n\u201cprosecute, or continue any. litigation.\n& DETERMINATION. AND EXTENT OF LIABILITY\nThis policy is.a contract of indemnity against acival monetiry loss:or\ndamage \u2018sustained or incurred by the Insured Claimant wha has\nsuffered loss or damage by reason of matters insured against: by .\nthis policy.\n(a) \u201cThe extent of lability of the Company for loss or damage under\nthis policy shall not exceed the lesser of\n(7) the Amount of Insurance;-or\n\u201cfii) the difference between the value of the Tille as insured\n\"and the value of the Title subject to the risk insured\nagainst. by thisipalicy,\n(b} if the Company pursues its. fights \u2018under: Section. 5: -of these\nConditions and is unsuccessful in estabiishing the Title, as\ninsured,\n\n~,- --7@) the Amount of Insurance shall be increased by 10%, and =\n\n\u201cfi, the Insured\u2019 Claimant shall have the right to have the-toss\nof. damage delaimined elther as of the date the claim was\nmade'by the Insured Claimant or as of the date itis settied\nand paid,\n\n4c} ln addition: fo the -extent of fiabifity under (a) and {b), the\nCompany will also \u2018pay those costs, attomays\u201d fees, and\n\u2018expanses incurred in \u2018accordance with: Sections 5 and 7 of\n\n\u201cthese Conditions.\n\n$, LIMITATION OF LIABILITY\n\n* {aj It the Company establishes. the Title, or fernoves the alleged\ndefect, fen, of eficumbrance, or cures the lack of a right of\naccess to or. from the:'Land, or cures the claim of Unmarketable\n\u201cTitle, all as\u2019 insured, in| a reasonably \u2014 diligent\n\n[Form s011473,(7-1-44) Pago sors |\n\nALTA Owner's Policy of Title Insurance (8-17-06)\nGeorgia\n\fPolicy #: 5011413-0131078e\u2014 _ -- --- eae ee\n\n10.\n\nT1.\n\niz.\n\n13.\n\n14.\n\nCase 1:26-cv-00765-WMR Document 1-1\n\nmanner by any method, including litigation andthe completion\nof any appeals, it shall have fully performed is obligations with\nrespect to that matter and shall not ba liable for any loss or\ndamag\u00e9.caused to the Insured.\n\nIn the event of any fitigation, including litgation by the\nCompany or with the Company's consent, the Company shall\nhave no liability for loss or damage until there has been a final\ndetermination by a court of competent jutisdiction, and\ndisposition of all appeals, adverse to the Title, as insured.\n\nThe Company shall not be liable for loss ar damage to the\nInsured for liability voluntanly assumed by: the Insured in\nsalting any claim-or suit withoutthe prior written consant of the\nCompany,\n\nREDUCTION OF INSURANCE; REDUCTION OR TERMINATION\nOF LIABILITY -\n\nAll payments under this policy, excapt payments made for costs,\natlomeys' fees, and expenses, shail reduce the Amount of\nInsurance by the amount of the payment,\n\nLIABILITY NONCUMULATIVE\n\nThe Amount of Insurance shall be reduced \u2018ty any amount the\n\n{b}\n\n(c)\n\nCompany: pays under any \u2018policy insuring @ Morigage to Which:\n\nexception is taken in Schedule B or to which the Insured has\nagreed, assumed, or taken subject, or which is executed by an\ntnsured after Date of Poticy and which is a charge or tien on the\nTitle, and the amount so paid shall be deemed. payment to the\n\n\u2018Insured under this policy.\n\nPAYMENT GF LOSS:\n\nWhen liability and the extent ofloss or damage have been definitely\n\nfixed in accordafce with: these Conditions,. the: payrient shall be\n\nmade within 30 days.\n\nRIGHTS OF RECOVERY UPON PAYMENT.OR SETTLEMENT:\n\n(a) Whenever the Company shall have settled and paid a claim\nunder this policy, il shail ba subrogated and. entitled to the\nrights of the Insured Claimant In the Title-and all other rights\n\u2018and remedies in respect to the claim that the Insured. Claimant\nhas against any person or property, to the extent of the amount\nof any loss, costs, attomays' fees, and expenses paid by the\nCompany. If requested: by the Company, the insured Claimant\nshall execute documents to evidence the transfer to the\nCompany of these.rights and remedies, The insured Claimant\nshall permit the Company to sue, compromise, or settle in the\nname of the insured Claimant and to use the name of the\nInsured Claimant in.any bransaction or litigation involving these\niights and remedies. ,\n\nIf a payment on account of a claim does not fully cover tha loss\nof the Insured Claimant, the Company shall defer the exercise\n\n15.\n\n16.\n\niT.\n\nof its right to recoveruntil after the Insured Cigimant shaithave . -\n\nrecoverad its-loss,\n\nThe Company's right of subrogation includes the rights of the\nInsured to indemnifies, guaranties, other policies of insurance,\nor bonds, notwithstanding any terms or condillens contained in\nthose instruments that address subrogation rights.\n\n(o)\n\nARBITRATION (DOES NOT APPLY IN GEORGIA)\n\nEither the Company: or the Insured may demand: that the claim or\ncontroversy shall ba submitted to arbitration purauant to the Tile\nInsurance Arbitration Rules of the American Land Title Association\n(\"Rules\"), Except as provided In the Rules, there. shail be no joinder\nor consolidation with claims or controversies of clher persens.\n\nAtbitrable matters may include, but are not fimited to, any\n\n18.\n\n(a\n\nFiled 02/10/26 Page 12 of 25\n\nCONDITIONS (Continued)\ncontroversy or claim between tha Company and the Insured arising\n\n\u2018out of or relating to this policy, any service in connection with ils\n\nissuance dr the bradch of @ policy provision, of to any other\ncontroversy or claim arising out of the transaction giving tise to this\nfoley. All arbitrable matters when the Amount of Insurance is\n$2,000,000 or fess shall be arbitrated al the option of elther the\nCompany or the Insured, All arbitrable matters when the Amount of\nInsurance is in excess of $2,000,000 shall be arbitrated only when\n\n4greed to by Soth the Company and the Insured. Avbitration\n\npursuant to. this policy and under the Rules shall b\u00e9 binding upon\nthe.parlies. Judgment. upon the award rendered by the Arbilrater(s)\n\n-inay be entefed in any court:of competent jurisdiction.\n\nLIABILITY UMITED TO. THIS POLICY; POLICY ENTIRE\n\nCONTRACT:\n\n(a) This policy together with-all endorsements, If any, attached to it\nby tha Company is the-entira policy and contract between the\nInsured and the Coripany. In interpreting any provision of this\npolicy, this policy shall. be conslued a3 a-whols.\n\nAny claim ol loss. or damage thal arises out of the.status of the\nTitle or by any action asserting such claim sha) be restricted to\nthis poilcy,\n\n{c) Any amendment of or endorsement to this policy must be in\nwriting and authenticated by an authorized: person, or expressly.\nincorporated by-Schedula A of this policy.\n\nEach endorsement to-this policy issued at any time is made a\npart of this policy and is subject to all of its terms and\nprovisions. Except as the endorsement expressiy states, it\ndoes not (} modify any of the terms and: provisions of the\npolley, (ii) modity any prior endorsement, (i) extend the Date\nof Policy, or-{iv} increase the Amount of Insurance,\nSEVERABILITY\n\n(b}\n\n{nthe event any.provision of this policy, in whole or in part, is held\n\ninvalid or unenforceable under applicable law, the: policy shall be\nd\u00e9amed not to include that provision or such part held to.be invalid,\n\n\u2018but all other provisions shail remain in full forca and effect.\nCHOICE OF LAW; FORUM,\n\n(a) Choice of Law: The Insured nee the Company has\ntiideniritten the risks covered by this policy and detennined\nthe premium charged therefor in reliance upos the law affecting\ninterests in real property and applicable to the interpretation,\nsights, remedies, or enforcement of policies of tile insurance of\nthe jurisdiction where the Land is located.\n\nTherefore, the court.or\u2019an arbitrator shall apply. the law of the\nfurisdiction where the Land Is located lo determine the validity\nof claims against the Tile that are adverse to the: insured and\nto interpret and enforce the terms of this policy. In neither case\nshall the court or arbitrator apply its conflicts of law principles 10\ndetermina the appilcable law.\n\n\u2018Choice of Forum: Any litigation or other proceeding brought by\nthe Insured against ihe Company must be filed only in a stale\nor federal court within the United States of America or its\nterritories having appropriate jurisdiction.\n\nNOTICES, WHERE SENT\n\nAny- notice of claim and any other notice or statement in writing\ntequired to be given to ihe. Company under this. policy must be given\nto the Company at First American: Title Insurance Company,\nAttn: Clalms National Intake Center, 1 First American. Way;\nSenta Ana, California. 92707. Phone: 888-632-1642.\n\nob)\n\nPage 5 of 5. |\n\nALTA Owners Polley-of Title Insurance (6-17-06) \u2014\nGeorgia\n\fCase 1:26-cv-00765-WMR_ Document 1-1 \u00a9 Filed 02/10/26 Page 13 of 25\n\n_ First American Title Insurance Company\n\nSCHEDULE A\n\nFIRST AMERICAN TITLE INSURANCE COMPANY\n1 FIRST AMERICAN WAY \u2014__\nSANTA ANA, CALIFORNIA 92707\n\nAgent's File'No: 16-2266 Policy:No.: FA-501 4413-0131078E\n\nAdiiress Reference: 6941 PEACHTREE: INDUSTRIAL BLVD\n_, \u2018NORCROSS, \u201cGA, GA\n\nDate. of Policy: @ OCTOBER 47, 2016 . - \u2018Amount of Insurance $1,375,000.00\n\n{. Name of insured\nLEX. CAPITAL, LLC\n\n2. The oddly OF interest in-the- Eand that is: dasuied by this palicy is: Foo sii\n\n\u20183. Title is vasted.in:\n\nLEX CAPITAL, LLC\n\n4. 'Thetand referted. to in this Policy. is described. as follows:\n\nSee Schedule A attached. hereto.and made 3 part hereof:\n\n| BF\n\n\u201c Authorized\u2019Signatory we\n\nFATIC-Si6\nSchedule A\nALTA Ownar's Folicy er\n\fCase 1:26-cv-00765-WMR Documenti-1 Filed 02/10/26\n\nPage 14 of 25\n\nne te \u2018First American Title-Insurance Company\nSCHEDULE A (Continued)\nAgent's File No.: 16.2286. oo Policy No.: FA-5014413-0131078E\n\nALL that tract or parce? of land lying and baing in tand Lok 277 of\nthe Gth Diatrick of eyuiniett County, Georgia being more particularily\n\n\u2018deseribed as POllows:\n\n0. FIND. THE CRUE. POTHT oF BEGINNING, begin at an iron pin found at the\n\nintersection of the. northwesterly right-of-way lina of.\n\nwith the northeasterly ling of: Zand Lok 2777\n\nPeachtree\n\nindustrial Boulevard (Gaorgia Highway Ho. 4) (cight-of\u2014way vaxies),\n\nee t \u2018 ence kun soy\nalong \u2018tha northwesterly right-of-way dine of Peachtree _\n\nithvdsterly\nIndustrial\n\nBoulevard a distance \u2018of 105.0 feat \u2018to an ixon \u2018pin found, being tha\nTrue: Point of Beginning; from. suid True Point: oe Beginning, thus\nestablished, \u2018thence continuing along said right-of-way line qf\nPeach&rea Industrial Boulevard South 55 degreas 19 idnutes 55 seconds,\nweet a \u2018distance of 4.49: feet to a point} thence Gontinuing along said\nxight-of-vay.lina. sonth 42 degrees 22. minutes 57 seconds fest 4g\ndistance of 37,20 feet to an ixeon pin gat; thence leaving sala\nright-of-way Line of Peachtree Industrial. Boulevard and running noxth\n34, degrees. 66 minutes 56 Seconds west a distance of 230.6 feet. to an .\ndyon pin gets thenee. south 58. degraes 53 minutes 03 seconds west a\ndistance of 82.20 feat to an dvon pin set: thence north 34 Geyress u6\nminutes 50 secards west a distance of 288.40 feet to an iron pin sat;\nthence south 59 degrees 53 minutes 10 seconds west a distance of -cotoo\nfect. to an dron pin seb; thence. north 31 degrees 05 minutes \u201850 seconds:\nWest a distanoa of..93.00 feet. to on \u2018drow pin set: thenee north \u201c5s\nfegrees' 53 minutes 19\u2019 seconds east a distance of 60,00 feat to an dixon\npin set; Chence horth 3% degrees 06. minutes 50 seconds wast. a distanaa.\nof 15.00 faet to an iron pin. sat; thenca. north BS degrees 19 minutes.\n31 seconds aast a distance of 65.50 feet te an iron pin. set; thence\nMOrth 31 aegrees 40 minutes. 38. Seconds east a distance of 140.07 feat\n\u2018to an dron pin found; thenge senth 31. deqraes 06 inutes 50 saronds\nast a distance of 499.30 feat to an dren'pin. found; thencs south ss\ndegrees 38 minutes. 55 seconds vest o distance of 108.80 feet to ah\niron pin g\u00e9br thence: south 32\u00b0 degrees 07 minutes 06 Seconds aast a\ndistance of 481.60 feat te an iron pin found located. on the\nnorthwesterly xight-of=way \u2018lina | of Yeacntres \u2018Industrial Boulevard\nbeing the Pre Point: ef Beginning; said property \u201containing 2,90 acrap\naccording to plat prepared for Anheuser Narketiny, Inc., Colonial Bank\n\nand Cemmonweaith Land Pitle Insurance Company by Solar Land\n\nSurveying\n\nCompany, John \u00a5. Stanzilis, R.b.S. Nox 2105, dated dune 9, 1997.\n\nTOGETHER WITH tha sasdhent xights arising out of that vartain Easement.\n\ndated August 31, 1982, batween Clardy Auto. Air Farts,\n\nMorlarty Sales Co., Inc, wecorded in\u2019 Deed Book 2441,\nGwinnett County, Georgia \u2018Records,\n\nFATIC-516.\nScheduleA -\nALTA Oumer's Poly (6-17-06)\n\ninc, \u2018and\n\n\u2018Page 318,\n\fCase 1:26-cv-00765-WMR Documenti1-1_ Filed 02/10/26 Page 15 of 25\n\n~ \u201cFirst American Title Insurance Company\n\nSCHEDULE B\nEXCEPTIONS FROM COVERAGE\n\nAgent's File No.: 16-2266 Policy No.: FA-5011413-0131678E\n\nThis policy does not insure against loss or damage (and the Company will not pay costs, attorneys\u2019 fees, or expenses) that arise\n\nby reason.of:\n\nFATIC-517\nSchedule B\n\n(2) Taxes or assessments that are not shown as existing liens by the records of any taxing authority that levies taxes or\nassessments on real properly or by tha Public Records; (b) proceedings by a public agency that may. result in taxes or\nassessments, or notices. of such proceedings, whether or not shown by the records of such agency or by the Public\nRecords.\n\nAny facts, rights, interests, or claims that are nat shown by the Public Records -but that could be ascertained by an\ninspection of the Land:or thal may \u2018be asserted by persons in \u2018possession of the Land.\n\nEasements, liens of encumbrances, or claims thereof, not shown by the Public Records.\n\nAny encroachment, encumbrances, violations, variations, or adverse circumstance affecting the Title that would be\ndisclosed by an accurate and complete land survey ofthe Land and-not shown by the Public Records.\n\nAny mineral or mineral sights leased, granted or retained by current or prior owners.\n\nTaxes and assessments for the year 2016 and subsequent years, not yet due and payable,\n\nWater Line Easement recorded in Deed Book 2426, Page 620, Gwinnett County,\n\nGeorgia records.\n\nDriveway Easement recorded in Deed Book 2441, Page 318, Gwinnett \u2018County,\nGeorgia records.\n\nEasement for Ingress & Egress recorded in Deed Book 2425, Page 635, Gwinnett\n\nCounty, Georgia records. .\n\nALTA Owner's Policy (6-17-68)\n\f2230 Patrick Henry Pkwy, S350 a preizO@\n\nCase 1:26-cv-00765-WMR Documenti-1_ Filed 02/10/26 Page 16 of 25\nBSh68) POGT7\n\nFILED AMG'RECORDED\nGWMETT COURTY GA\n\n2016 OCT 25 PM 2: 09\n\nKiLRARD Ale AANDER. CLERK\n\nReturn To:\nWillam- AJ Miller, Esq, -\n\nMcDonough, GA 30253 WINNETT CO.GEORGIA\nFile #162266 - Ora ESTATE, TRANSFER TAX\nts \u2014\u2014\u2014\u2014_____-\u2014 ps se rcernemn\n\nSTATE OF GEORGIA...\nCOUNTY OF HENRY _-\n\nTHIS DEED (\u201cDeed\u201d) made this the: 17th day of OCTOBER, 2016, by ANHEUSER\nMARKETING, INC., a Delaware Corporation, a\u00a7 party of the first part, hereinafter called\nGrantor, and LEX CAPITAL, LL, a Georgia limited liability company hereinafter-called\nGrantee (the words \u201cGrantors\u201d arid \u201cGrantee\u201d to inelude their\u2018respective heirs, successdrs and\n\nassigns where the coritext requires of permits)...\u201d\n\nThat Grantor, for and.in consideration of the sum of Ten. Dollars ($10.00) and other .good\nand valuable consideration, cash in, hand paid at and before :the sealing and: delivery of these\npresents, the r\u00e9ceipt and sufficiency of which are hereby acknowledged, by these presents does\ngrant, bargain, sell, alien, convey, remise, rel\u00e9ase and forever quit-claim to the Grantee, their\nheirs and assigns, all the right, title, interest, claim\u2019 or demand which the \u2018Grantor, either jointly or\n\n\u00a9 individually, have \u2018or: may have had in and to.'the following described\u2019real property (the\n\nSEE ATTACHED EXHIBIT \u201cA\u201d\n\nTO HAVE AND TO'HOLD the Property with all atid singular\u2019 the rights, members and\n\nappurtenances. thereof, to the same being, belonging, or in: anywise appertaining, unto the\n\nGrantee, their successors, heirs and-assigns, so that neither the said Grantors:nor their successors,\n\nnor any other person:cldiming under them shall at any time, claim or demand any right, title or\ninterest to the Prop\u00e9rty or.its appurtenances. .\n\n099968 at\n\nie\n\f2 Case 1:26-cv-00765-WMR Documenti-1 Filed 02/10/26 Fagg 75 of 25\n\nM5468) BWOKIR Phec 2 ae Gurr Cram\nRe Peg \\Feee (Petr ee\n\nfod. Salt Sh Gant Ces 4\n\nIN WITNESS WHEREOF, Grantor has executed this. DEED: as of the day and year first\nabove written. : a . -\n\nBe , ANHEUSER MARKETING, INC.\nSigned, sealed and delivered in the A Delaware Corporation\npresence of: PU\n\n_ er Gls.\nBy: (SEAL)\n\n'L RICHARD ANHEUSER, PRESIDENT\n\nMy ission expires: ; een OY a\n\n[Notary Seal]\n\n\fCase 1:26-cv-00765-WMR Docume\u00e9nti1-1 Filed 02/10/26 Page 18 of 25\n\nao 6 BPG O79 ne\n\n\u2014 a i\n\nEXHIBIT \"A\" \u2018\n\nMeee,\n\nAll that tract or parcel of land lying and heing in Land Lot 277 of\n\nthe Sth District of eyinnett County, Georgia being more particilarly\nascribed as follove: . :\n\nTO FIND THE TRUE FOINT oF BEGIHNING, begin at an iron pin found at the\nintersection of the \u2018northwesterly xight-of-way lina of Peachtree\nIndustrial Boulevard (Georgia Highway Na. 143) - (right-of-way varias)\nwith the northeasterly ling of Land Let 477; hence run southwesterly\nalong the northwesterly right-of-way line of Peachtrae Industrial\n\u2018Boulevard a distance of 105.0 feat to an iron pin. found, baing the\nTrue Point of Beginning: from said frue- Point of. poginning thus\nestablished, thence continuing along said right-of-way line of\nPeachtzes Industrial Boulevard \u2018south \u00a76 degrees 18 minutes 55 seconds\nvest a distance of 4.40 feat te a pointy thence continuing along said\nright-of-yay lima south 42 degrees 22 minutes 67 seconds. vost a\n\ngistance of 37.20 Zest to an ivon pin set; thenee Jeaying said\n\nright*of-way line. of Peachtree Industrini Boulevard and running north\n\na3 degrees 06 minutes 50 seconda wast a distance of 230.0 feet to an\niron pin set; thence south 56 degrees 53 minutes 03 seconds wast a\ndistance of 51.20 feat to an iron pin set; thence north Jl degrees 06\nminutes 80 seconds west.a distance of. 189.40 feat to an iron pln set:\nthence south 5& dagrees 53 minutes 106 Seconds wast a dietanea oF s6100\nfeet to an iron pin set; thence north 31 degreea 06 minutes 50 seconds\nwast a distance \u201cof 93.00 feet to an iron pin set; thence north 5a\ndegrees 53 minutes 10 seconds east 2 distance of 60.00 feat to an iron\npin set? thence north 31 degrees 08 minutes 60 seconds weet a distance\nof 19.60 feet to an izon pin set; thenca north 55 degrees 19 minutes\n31 seconds east a distance of 65,59 feet to: an iron pin sat; thence\nnorth 31 degrees 40 minutes. 38 seconds east a distance of 148,07 feet\n\u2018to an iron pin foundy thenee gouth 32 degrees 06 minutes 50 seconds\neast a distance of 409.30 fmat ta en iron pin found; thence seuth 52\ndegrees 38 minutes 55 &econds wost adistance of 105.80 feat to an\ndron pin sets thence south 32 degrees 07 minutes 06 seconde sagt a\n@istanca cf 181.60 feat to an tren Pin found located on the\nnorthwesterly right-of-way line of Peachtrea industrial Boulevard\nbeing thea frue. Point of Baginning: sald property containing 1,59 acres\naccording to plat prepared for Anheuser Marketing, Ino., Colonial Bank\nand Commonwealth Land Title Insurance Company by Solar Land Surveying\nCompany, John #. Stangilis, Rot.8. No. 2109, dated Tune 9, L997. 7\n\nTOGETHER WITH the easement rights arising out of that eertain Easement\n\nGated August 22, 12982, between Clardy Auto Air Parts, Inc. and\nMoriarty Sales ta,, Ino., \u2018\u00e9corded in Weed Hook 2441, Page 218,\n\nGwinnett County, Georgia Records,\n\fCase 1:26-cv-00765-WMR Document1-1 Filed 02/10/26 Page 19 of 25\n= ou. 5e68! OK72\n\nECORDED\naE oent\nRLY G aa &\n\n216 OCT 25 PH 2: 00\n\nbrink ALC AANOER, CLERK\n\n2o5\nmy\n\nAfter recording, please: return: 10; \u2014\nWilliam A. Miller,P:C.\n2330 Patrick Henry Pkwy, Suite \u00b0350\n\nMcDonough, Georgia 30253 - RS : pTared@ ]- 2O1G~G230E.\nFILE -#16-2266. . GWINNETT CO. GEORGIA\n. : TATE TRANSFER TAX\nSTATE-OF GEORGIA ~ _ + pe ree E. 1O\nCOUNTY OF HENRY __ RICHARDT. ALEXANDER, JR. CLERK OF\n/ . i LIMITED \u2018 RRAN TY DEED SUPERIOR COURT\n\nTHIS LIMITED WARRANTY DEED i is made this 17TH day of. OCTOBER,\n2016, by and between ANHEUSER MARKETING, INC. a Delaware Corporation (hereinafter\ncalled. \u201cGrantor\u201d); and LEX CAPITAL, LLC a Georgia Limited Liability. Company \u00b0\n(hereinafter called \u201cGrantee\u201d). The words \u201cGrantor\u201d and \u201cGrantee\u201d include the neuter,\nmasculine and feminine genders, and the singular and the plural.\n\now ITNES s E TH:\n\n| FOR. AND'IN CONSIDERATION of the\u2018sum of Ten Dollars ($10.00) in hand\npaid to Grantor by Grantee at and before the execution, sealing and delivery hereof, and.other\ngood and valuable consideration, the receipt and sufficiency of which are hereby. acknowledged,\nGrantor has:-pranted, bargained, sold, aliened, conveyed and confirmed; and by these presents\ndoes grant, bargain, sell, alien, : \u2018convey and confirm unto Grantee, in fee simple, all that tract or\nparcel of land lying and. being in GWINNETT County, Georgia, being more. particularly\ndescribed on Exhibit \u201cA\u201d, attached hereto and incorporated herein by reference, together with all\nand \u2018singular the\u201d buildings; improvements: thereupon erected, and all an every the ways,\neasements, rights, privileges and. appurtenances: to the same \u2018belonging or in any. way\nappertaining and all the estate, right; title, interest and.claim, either at law-or equity, or otherwise\nhowever, ofthe Grantor of ih, to, or out of the property\n\nTO HAVE AND To HOLD the property for the use: aod benefit of Grantees, his\nheirs, Personal Tepheschlalives and assigns, in. fee simple.\n\fCase 1:26-cv-00765-WMR_ Document1-1 Filed 02/10/26 Page 20 of 25\n\nSee 5 et\n\n_ GRANTOR SHALL WARRANT and forever defend the right and title to said\ntract or parcel of land unto. Grantee, and the successors, legal: representatives and assigns of\nGrantee, against the claims of all persons claiming by, through or under Grantor, but not\notherwise. Title to the Property is subject to those matters of public record as of the date hereof,\nas shown among the current-public records of GWINNEFT County, Georgia..\n\n. IN WITNESS WHEREOF, Grantor has\u2019 caused its, duly: authorized agent to\u00bb\nexecute this indenture, and to deliver this. indenture to Grantee, all the-day and year first written\nabove. . - 8 oo\n\nSighed, sealed arid delivered in the GRANTOR; =i;\nmete 2 4 A ., \u00b0\u00b0 ANHEUSER MARKETING, INC.\n\na Delaware Corporation\n\nL. RICHARD ANHEUSER, PRESIDENT\n\nWo\n\fCase 1:26-cv-00765-WMR Documenti-1 _ Filed 02/10/26 Page 21 of 25\n\nEXHUBIT aan\n\nALL THAT TRACT OR PARCEL OF LAND lying and being im Land het 297 oF\nthe 6th. District of. Gwinnett County; Georgia, as shown on survey\n-.for Moriarty \u201cSates- Company, \u201c\u201cInc., prepared by Georgia band\n\nSurveying Co., Ind., dated June 1, 1984, bearing the seal of Josh\nL. Lewis, ILI,\u2019 Georgia Registered Land Suxveyor No. L751 which\nsurvey is incorporated herain by reference as is fully get forth\nh\u00e9rein and. which property. ig more particularily deseribed ae\n\nfollows:\n\nTO. FIND THE TRUE POINT OF BEGINVING,, begin at an iron pin found at\nthe. intersection \u201cof the northwesterly right-of\u00abway line of\nPeachtree Industria) Boulevard {Georgia Highway No. 141)-with the\nnortheasterly line \u2018of 1: re\n' the noxthwesterly: right-of-way line of Peachtree Industrial\nRoulavard a distancs of 105.0 feet to an iron pin. placed at a point\nbeing the TRUE POINT OF BEGINNING; from said true point of\nbeginning as thus established, thence rum southwesterly along the\nnorthwesterly right-of-way Line of Peachtree Industrial Boulevard\nSOUEH 55 degrees. 18 minutes. \u00a75 seconds wast a distamos of 4.40 feet\nto an iron pin placed: thence run south 42 degreas 22 minutes 57\nseconds west a distance of 37.2 feet to a nail @et.in an Saphalr\n@rive; hence run morth 31. degrees 06 \u201cminutes. 51 setonds west a\ndistance of 236..0 Leet toa aA nail set in an asphalt Grive; thence\nxn south 58 degrees 53 minutes 03. seconds wast and a distance of\n51.2 feet to on iron pin found; thenge xun north 31 degrees Of\nminigtes 50. seconds: west a distance of 177.40 f\u00e9et to an iron pin\nplaced; thence run south 58 degrees 53 minutes 10 seconds west a\n\niron pin found; thence run north 55\n\negress -19 minutes 31 saconds\n\n(@ast a-distance of 65.50 feat bo an iron pin found; thence run\n\nnerth 31 d\u00e9grees 40 minut\u00e9e 38 \u2018seconds @ast a distance of 148.07\nfeet to an iron pin found on the northeasterly lot line of hand Lot\n2773 then\u00e9e run south 31 degrees 06 minutes 50 seconds east along\nthe northeasterly line ef Land. Get 277 a\u2018 distance of 209.30 Fest t6\nan iron pin founds thence run south 58 degrees 38 minut\u00e9s 55\nssconds. west a distance of- 105.8 feek to an \u2018iron pin placed;\nth\u00e9nea xun south 31 degr\u00e9as 07 minutes 06 seconds sagt & distance\no\u00a3 101.6 \u00a3Leek t6 an iron pin plated an the northwesterly right-of-\n, way Jine of Peachtree Industrial Boulevard. and tha TRUE POINT OF\nBEGINNING, being tha Same property as shown on survey for \u201cHARRIS\nBEAUTY SUPPLY CG., INC.\" prepared by Alvin E. Vaughn & Associates,\ntnc., dated Jun\u00e9 5, 1987, ag revised on dune L9, 1987.\n\n: Exhibit \"A\" Page 1 of 3\n\nand Lot 277: thence run southwesterly along\n\fCase 1:26-cv-00765-WMR Document 1-1' Filed 02/10/26 Page 22 of 25\nK5468t POuTS\n\n: +\naoa a\n\nTOGETHER WITH:\n\nALL THAT LOT, TRACT OR PARCEL OF LAND gituat\u00e9, lying and being in\nland Lot numbered 277 of. the 6th District, Gwinnett County,\nGeorgia, being particularly degeribed as Follows: \u2018\n\nTo find tha time point of beginning, begin at an ixon pin found at\nthe intersection of the northwesterly xight of way line of\nPeachtree .Industrial. Boulevard (Georgia \u2018Highway #141) with the\nnortheasterly line of Land bot, 277; thence run southwesterly along.\nthe northwesterly right of way line cf Peachtree Industrial\nBoulevard a distance of 109.40 feet to a point; continuing thenes\n\nalong the northwesterly line of the aforesaid right of way\u2019 of +>\n\n- Peachtre\u00e9 Industrial Boulevard South 42 d\u00e9grees 01 minutes 07\n\"seconds West a distance of 37.20 feet to a point; thence Leaving\nthe right of way of P\u00e9achtres Industrial Bottlevard rumning North 31\ndegrees 06 minutes 16 seconds West a distance of 230.00 feet to a\npoint; running thenca South $8 degrees 53 minutes 44 seconds West\na distance of S1.20 feet to an iren pin aat; sunning. thence North\n(31 degress 06\u2019 minutes 16 seconds West a distance of 270.4 feet to\na point WHICH POINT Is THE POINT OF BEGINNING OF THE PROPERTY\n\u2018DESCRIBED HEREIN: thence from said point of beginning running\u2019 South\n38 degrees 53 minut\u00e9s: 44 seconds West a. distance of 60.00 feet to\na point; cunning therice North 31 degrese 0\u00a2 minute 16 seconds West\na distance of 11 feet to a point; sunning thence North 58 degrees\n\u201c83 minutes. 44. seconds Hast a distance of 60,00 Feet to a point;\nrunning thence South 31 degrees 06 minutes 16 seconds Bast a\n\ndistance of 11.0 feet to the point of beginning, said property\nfor D. T. Burdette and Southern\n\nbeing shown on that certain survey\n\u2018National Bank, dated April 77, 4985, last revised May 17, 1889, by\nJiek A. Paye, G.Rib.S. No. 1894. \u00a9 :\n\nLESS AND EXCEPT: -\n\nALL THAT LOT, TRACT OR PARCEL OF Land eittiate, lying and being in\nLand Lor numbered 277 of the Sth District, Gwinnett County,\nG\u00e9orgia, being partioularly d\u00e9scribed as E\u00e9llows: .\n\nTo \u00a3ind the trie poink of begimning, b\u00e9gin at an ivon pin found at\nthe intersection of the northwestezly xvight of way line o\u00a3\nPeachtree Induetrial Boulevard- (Georgia Highwey. #141) with tha\nnortheasterly line of Land hot 277; thence run southwesterly along\nthe. nerthwesterly- right of way line of Peachtree \u2018Industrial\nBoulevard a distance of 1059.40 feet to a point; continuing thence\nalong the. northwesterly line of the afovesaid right of way of |\nP\u00e9achtree Industrial Boulevard South 42: degrees 01 minutes 07\n. Seconds West a distance of 37.20 feet to a point; thence leaving ._\n\u2018the right. of way of Peachtree Industrial Boulevard running North 31\ndegrees 06 minutes 16 s\u00e9conds West a distance of 230.00 E\u00a3eet to a\npoint; running thence South 58 degrees 53 wWinutes 44 peconds West\n- 8 distance of 51.20 feat. to an iron pin set; running thence North\n\n\u2018Exhibit \u201cA Page 2 of 3\n\naon\n\fCase 1:26-cv-00765:WMR* Document 1-1\nKS668)\n\nns i be gf ard\nte \u00ab\n\n31 degrees 05 minutes 16 seconds West a distanc\n\nOUTS\n\nFiled 02/10/26\n\nPage 23 of 25\n\na point WHICH POINT Is THE POINT oF BEGINNING OF THE PROPERTY\nDESCRIBED HEREIN; thence from said point of beginning running South\n58 degrees 53 minutes 44, seconds West a distance of \u201860.00 Feat to\n\u2018@ point; runhing Ehenae North 31L. degrees 65 minutes 16 seconds West\n\na distanca of 21 feat. te a point; running: thence North 58 degrees\n33 minutes 44 seconds Bast a distance of 60.06 Zeet to a pointe;\nfunning theice South 31 degrees 06 minutes 16 seconds East a\n\ndistance of 11.0 feet to the point of beginning,\n\nbeing shown on that certein Survey for D. T. Burdette and Southern\nNational Bank, dated. April 17, 1985, last revised May 17, 1989, by\n\nJick A. Faye, G.R.L.8, No. 1894.\n\nExhibits: tae Page 3 of 3.\n\n2 of 177.40 feet to\neaid property\n\fCase 1:26-cv-00765-WMR Documenti-1 _ Filed 02/10/26 Page 24 of 25\n\nEXHIBIT B\n\u2018+,-|-FirstAmerican~ ~~~\" tt\u2014i