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CABLE TELEVISION .' 'uJ Robert J ,~':ei'.yes '" . Municipal Affairs Manager \v~' veriZJl!l Reply to: 600 Hidden Ridge,HQE02E65 (972)718-6648 Fax: (972)-719-7948 Verizon Communications Corporation March 7 I 2002 Mr. William Horne City Manager Clearwater City Hall, 3rd Floor 112 S. Osceola Avenue Clearwater, FL 33756 (727) 562-4040 COpy Subject: Cable Television Franchise Transfer Request Dear Mr. Horne, Verizon Media Ventures Inc. ("Verizon"), is pleased to announce that it has reached an agreement with Adelphia Communications Corporation ("Adelphia") to sell the cable system serving Clearwater, Florida. Adelphia is one of the largest cable television operators in the country, serving more than 5 million subscribers. Additional information about Adelphia is provided in the attached documents. We believe that the financial resources and expertise of Adelphia will bring cable customers in your community the best possible cable service, as well as, expanded choices in products and services. We request the consent of your community to transfer the cable television franchise and system from Verizon to Adelphia PineHas County, LLC, a wholly-owned subsidiary of Adelphia. Adelphia Communications Corporation will execute an Assignment and Assumption Agreement to assign its rights under the Purchase Agreement to Adelphia Pinellas County, LLC. Such transfers are routine in the industry and are allowed under Section 16.9 of the attached Asset Purchase Agreement. This wholly-owned Adelphia subsidiary, Adelphia Pinellas County, LLC, is identified as the Transferee in the accompanying FCC Form 394 application. Adelphia Communications Corporation will have ultimate control of the franchise and related assets. (Please see the attached structure chart.) We therefore request your consent forthe transaction described in the application. Page 2 Enclosed are an original and two copies of Federal Communications Commission ("FCC") Form 394, "Application for Franchise Authority Consent to Assignment or Transfer of Control of Cable Television Franchise", which consists of the following sections: I. General Information: Transferor/Assignor (Part I); Transferee/Assignee (Part II) II. Transferee's/Assignee's Legal Qualifications III. Transferee's/ Assignee's Financial Qualifications IV. Transferee's/Assignee's Technical Qualifications V. Certification: Transferor/Assignor (Part I); Transferee/Assignee (Part II) We recognize that under Section 617(e) of the Cable Television Consumer Protection and Competition Act of 1992 (47 U.S.C.A. 9537), the franchise authority shall have up to 120 days from the date of filing of this form, complete with all exhibits and any information required by the franchise agreement or applicable state or local law, to act upon such request. If the franchise authority fails to render a final decision on such request within 120 days, such request shall be deemed granted unless the requesting party and the franchise authority agree to an extension of time. We believe the enclosed materials provide you with the information necessary to make a speedy determination on our request for the transfer of the franchise to Adelphia. The information contained within the Form 394 establishes that Adelphia Pinellas County LLC, as the transferee/assignee, satisfies the requisite legal, technical and financial qualifications. Accordingly, Verizon believes that to the extent consent is required, it should be granted. If you find the enclosed information acceptable, please place approval of the transfer on the next community meeting agenda. We have enclosed a proposed form of resolution that we request you adopt, or use as a model for a resolution by which you would grant such consent. To the extent that you desire to change the form of resolution - and we understand and appreciate that you might - we would like to be involved in that process to ensurethat the final language of the resolution is acceptable to all parties. We look forward to meeting with you personally to answer any questions you may have, and to work with you to obtain swift transfer approval and welcome Adelphia as the cable television provider in your community. If you have any questions, please call Robert J. Hayes, Municipal Affairs Manager, at Verizon at 972-718-6648, or Randall D. Fisher, Vice President and General Counsel, at Adelphia at 814-274- 9830. Page 2 Page 3 Sincerely, ~.~ Robert J.Hayes Verizon Municipal Affairs Manager Page 3 ,,: ~ 1- eo ..c U (]J 1- :J ~ U :J 1- ~ CJ) c o ..... CO So.... o o..c So.... 0 o ._ u..... CO (/) So.... C 0 oe- .....0 ~u 'c Q) ::J So.... E CO E ~ o Q) uo .CO <( ..c:: a.. Q) "'C <( c '0 (.) .- c..... - CO So.... - 0 (/)0.. C So.... .0 0 .....u ~ Q) ~ a.. CO o ~ UCO UQ) <(0 <( ~ c CO uo.. ...J E ...J 0 ~U -:=~ - ..... ::J := 0..0 U .CO (/)...J CO-o Q)$ c .- .- E 0.. .- ...J CO :.c~ a.. CO - ~ ~ CO <( Q) o <( RESOLUTION NO. RESOLUTION OF THE OF APPROVING THE TRANSFER OF THE CABLE TELEVISION FRANCHISE WHEREAS, Verizon Media Ventures Inc. ("Franchisee"), owns, operates and maintains a cable television system (the "System") in the of (the "Franchise Authority"), pursuant to a cable television franchise agreement (the "Franchise"), and Franchisee is the duly authorized holder of the F ranch ise; WHEREAS, Franchisee and Adelphia Communications Corporation ("Adelphia") are parties to an Asset Purchase Agreement (the "Agreement"), pursuant to which the System and the Franchise will be transferred (the "Transfer") from Franchisee to Adelphia Pinellas County, LLC (the "Transferee"), an affiliate of Adelphia, at the consummation of the transaction contemplated by the Agreement (the "Closing"); and WHEREAS, Franchisee and Transferee have requested consent by the franchise Authority to the Transfer in accordance with the requirements of the Franchise and have filed an FCC Form 394 with the Franchise Authority; and WHEREAS, the Franchise Authority has investigated the qualifications of Transferee and finds it to be a suitable transferee; NOW THEREFORE BE IT RESOLVED BY THE FRANCHISE AUTHORITY AS FOLLOWS: SECTION 1. The Franchise Authority hereby consents to and approves, subject to applicable law, the assignment by Franchisee of its right, title and interest in the Franchise to Transferee, and the assumption by Transferee of the obligations of Franchisee under the Franchise from and after the Closing. SECTION 2. The Franchise Authority confirms that: (a) the Franchise was properly granted or transferred to Franchisee; (b) the Franchise supersedes all other agreements between the parties; (c) the Franchise represents the entire understanding of the parties and the Franchisee has no obligations to the Franchise Authority other than those specifically stated in the franchise; and (d) Franchisee is materially in compliance with the provisions of the Franchise and there exists no fact or circumstance known to the Franchise Authority which constitutes or which, with the passage of time or the giving of notice or both, would constitute a material default or breach under the Franchise or would allow the Franchise Authority to cancel or terminate the rights thereunder, except upon the expiration of the full term of the Franchise. SECTION 3. Transferee may transfer the System and/or the Franchise, or control related thereto, to any entity controlling, controlled by, or under common control with Adelphia. SECTION 4. The Franchise Authority hereby consentsto and approves the assignment, mortgage, pledge, or other encumbrance, if any, of the. Franchise, the System, or assets relating thereto, as collateral for a loan. SECTION 5. This Resolution shall be deemed effective for purposes of the Transfer upon the Closing of the Transfer. SECTION 6. The Franchise Authority releases Franchisee, effective upon the Closing, from all obligations and liabilities under the Franchise that accrue on and after the Closing; provided that Transferee shall be responsible for any obligations and liabilities under the Franchise that accrue on and after the Closing. SECTION 7. This Resolution shall have the force of a continuing agreement with Franchisee and Transferee, and Franchise Authority shall not amend or otherwise alter this Resolution without the consent of Franchisee and Transferee. PASSED, ADOPTED AND APPROVED this day of 2002. By: ATTEST: Clerk ************* I, the undersigned, being the duly appointed, qualified and acting (Clerk) of the of , hereby certify that the foregoing Resolution No. is a true, correct and accurate copy as duly and lawfully passed and adopted by the governing body of the on the day of ,2002. Clerk Federal Communications Commission Washington, DC 20554 c - - ....., WI III Approved by OMB 3060-0573 FCC 394 APPLICATION FOR FRANCHISE AUTHORITY CONSENT TO ASSIGNMENT OR TRANSFER OF CONTROL OF CABLE TELEVISION FRANCHISE FOR FRANCHISE AUTHORITY USE ONLY SECTION I. GENERAL INFORMATION DATE 03/07/02 1. Community Unit Identification Number: FL1192 2. Application for: ~ Assignment of Franchise o Transfer of Control 3. Franchising Authority: Cit of Clearwater, Florida 4. Identify community where the system/franchise that is the subject of the assignment or transfer of control is located: Cit of Clearwater, Florida 5. Date system was acquired or (for system's constructed by the transferor/assignor) the date on which service was provided to the first subscriber in the franchise area: 6. Proposed effective date of closing of the transaction assigning or transferring ownership of the system to transferee/assignee: 04/02/96 When all closing conditions are met. Anticipate no later than 120 da s from this filin . 7. Attach as an Exhibit a schedule of any and all additional information or material filed with this application that is identified in the franchise as required to be provided to the franchising authority when requesting its approval of the type of transaction that is the subject of this application. Exhibit No N/A PART I - TRANSFEROR/ASSIGNOR 1. Indicate the name, mailing address, and telephone number of the transferor/assignor. Legal name of Transferor/Assignor (if individual, list last name first) Verizon Media Ventures Inc Assumed name used for doing business (if any) Verizon Media Ventures Inc. Mailing street address or P.O. Box 6665 N. Macarther Blvd. - Mailcode HQK02B75 City Irvin State TX Telephone No. (include area code) 972-718-6648 2.(a) Attach as an Exhibit a copy of the contract or agreement that provides for the assignment or transfer of control (including any exhibits or schedules thereto necessary in order to understand the terms thereof). If there is only an oral agreement, reduce the terms to writing and attach. (Confidential trade, business, pricing or marketing information, or other information not otherwise publicly available. may be redacted). Exhibit No. 1 (b) Does the contract submitted in response to (a) above embody the full and complete agreement between the transferor/assignor and the transferee/assignee? [Kl Yes D No If No, explain in an Exhibit. Exhibit No. NIA FCC 394 (Page 1) September 1996 PART II - TRANSFEREE/ASSIGNEE 1.(a) Indicate the name, mailing address, and telephone number of the transferee/assignee. Legal name of TransfereelAssignee (if individual, list last name first) Adel hia Pinellas Count , LLC Assumed name used for doing business (if any) Mailing street address or P.O. Box 1 North Main Street City Couders ort State PA ZIP Code 16915 Telephone No. (include area code) 814 274-9830 (b) Indicate the name, mailing address, and telephone number of person to contact, if other than transferee/assignee. Name of contact person (list last name first) Fisher, Randall D. Firm or company name (if any) Adel hia Communications Cor Mailing street address or P.O. Box 1 North Main Street City Couders ort oration State PA ZIP Code 16915 Telephone No. (include area code) 814 274-9830 (c) Attach as an Exhibit the name, mailing address, and telephone number of each additional person who should be contacted, if any. (d) Indicate the address where the system's records will be maintained. Street address 1 North Main Street City State Couders ort P A ZIP Code 16915 2 Indicate on an attached exhibit anv D'?ns to change the current terms and conditions of service and operations of the system as a consequence of the transaction for which approval is sought. FCC 394 (Page 2) September 1996 Exhibit No. N/A Exhibit No 2 SECTION II. TRANSFEREE'S/ASSIGNEE'S LEGAL QUALIFICATIONS 1. Transferee/Assignee is: o Corporation a. Jurisdiction of incorporation: d. Name and address of registered agent in jurisdiction: b. Date of incorporation: c. For profit or not-for-profit: o Limited Partnership a. Jurisdiction in which formed: c. Name and address of registered agent in iurisdiction: b. Date of formation: o General Partnership a. Jurisdiction whose laws govern formation: b. Date of formation: D Individual V L::.J Other. Describe in an Exhibit. I EXhib; No. 2. List the transfereelassignee, and, if the transferee/assignee is not a natural person, each of its officers, directors, stockholders beneficially holding more than 5% of the outstanding voting shares, general partners, and limited partners holding an equity interest of more than 5%. Use only one column for each individual or entity. Attach additional pages if necessary. (Read carefully - the lettered items below refer to corresponding lines in the following table.) (a) Name, residence, occupation or principal business, and principal place of business. (If other than an individual, also show name, address and citizenship of natural person authorized to vote the voting securities of the applicant that it holds.) 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'" ~ ~ -5 '" .3 <;:;' ':f? o o o 0" lii -5 '" .3 ~ <;:;' ~ ~ o o o on ~ ~ lii -5 '" '" " ....I S ~ c '" -5 '" .3 s Has an adverse finding been made or an adverse final action been taken by any court or administrative body with respect to the transfereelassignee in a civil, criminal or administrative proceeding, brought under the provisions of any law or regulation related to the following: any felony; revocation, suspension or involuntary transfer of any authorization (including cable franchises) to provide video programming services; mass media related antitrust or unfair competition; fraudulent statements to another government unit; or employment discrimination? If the answer is Yes, attach as an Exhibit a full description of the persons and matter(s) involved, including an identification of any court or administrative body and any proceeding (by dates and file numbers, if applicable), and the disposition of such proceeding. Are there any documents, instruments, contracts or understandings relating to ownership or future ownership rights with respect to any attributaole interest as described in Question 2 (including, but not limited to, non-voting stock interests, beneficial stock ownership interests, options, warrants, debentures)? If Yes, provide particulars in an Exhibit. 7. Do documents, instruments, agreements or understandings for the pledge of stock of the D Yes ~ No transfereelassignee, as security for loans or contractual performance, provide that: (a) voting rights will remain with the applicant, even in the event of default on the obligation; (b) in the event of default, there will be either a private or public sale of the stock; and (c) prior to the exercise of any ownership rights by a purchaser at a sale described in (b), any prior consent of the FCC andlor of the franchising authority, if required pursuant to federal, state or local law or pursuant to the terms of the franchise agreement will be obtained? Federal Communications Commission Washington, DC 20554 Approved By OMB 3060-0573 3. If the applicant is a corporation or a limited partnership, is the transferee/assignee formed under the laws of, or duly qualified to transact business in, the State or other jurisdiction in which the system operates? If the answer is No, explain in an Exhibit 4. Has the transfereelassignee had any interest in or in connection with an applicant which has been dismissed or denied by any franchise authority? If the answer is Yes, describe circumstances in an Exhibit. 5. 6. If No, attach as an Exhibit a full explanation. SECTION III. TRANSFEREE'S/ASSIGNEE'S FINANCIAL QUALIFICATIONS 1. The transferee/assignee certifies that it has sufficient net liquid assets on hand or available from committed resources to consummate the transaction and operate the facilities for three months. Attach as an Exhibit the most recent financial statements, prepared in accordance with generally accepted accounting principals, including a balance sheet and income statement for at least one full year, for the transfereelassignee or parent entity that I:las been prepared in the ordinary course of business, if any such financial statements are routinely prepared. Such statements, if not otherwise pUblicly available, may be marked CONFIDENTIAL and will be maintained as confidential by the franchise authority and its agents to the extent pennissible under local law. 2. SECTION IV. TRANSFEREE'S/ASSIGNEE'S TECHNICAL QUALIFICATIONS Set forth in an Exhibit a narrative account of the transferee'slassignee's technical qualifications, experience and expertise regarding cable television systems, including, but not limited to, summary infonnation about appropriate management personnel that will be involved in the system's management and operations. The transferee/assignee may, but need not, list a representative sample of cable systems currently or fonnerly owned or operated. FCC 394 (Page 4) September 1996 DYes D No N/A I Exhibit No. IN/A DYes 0 No Exhibit No. N/A DYes IKJ No Exhibit No. N/A DYes [K] No Exhibit No. 4 o Yes D No Exhibit No. 5 Exhibit No. 6 SECTION V - CERTIFICATIONS Part I - Transferor/Assignor All the statements made in the application and attached exhibits are considered material representations, and all the Exhibits are a material part hereof and are incorporated herein as if set out in full in the application. Signature Verizon Media Ventures Inc, I CERTIFY that the statements in this application are true, complete and correct to the best of my knowledge and belief and are made in good faith. Print full name Anna Marie Moran - Vice President - General Manager WILLFUL FALSE STATEMENTS MADE ON THIS FORM A PUNISHABLE BY FINE AND/OR IMPRISONMENT. U,S, TITLE 18, SECTION 1001. Check appropriate classification: D . Individual D General Partner o Corporate Officer (Indicate Title) D Other.. Explain: Part II - Transferee/Assignee All the statements made in the application and attached Exhibits are considered material representations, and all the Exhibits are a material part hereof and are incorporated herein as if set out in full in the application. The transferee/assignee certifies that he/she: (a) Has a current copy of the FCC's Rules governing cable television systems. (b) Has a current copy of the franchise that is the subject of this application, and of any applicable state laws or local ordinances and related regulations. (c) Will use its best efforts to comply with the terms of the franchise and applicable state laws or local ordinances and related regulations, and to effect changes, as promptly as practicable, in the operation system, if any changes are necessary to cure any violations thereof or defaults thereunder presently in effect or ongoing. I CERTIFY that the statements in this application are true, complete and correct to the best of my knowledge and belief and are made in good faith. Signature Adelohia Pinellas County. LLC .~. . ;/ tJ /J (\ L--' /J .jIV.J:A,49ld4..,lV IV I ,..0WU~./v 'Z'l ~D 0 1.. WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMPRISONMENT. U.S. CODE, TITLE 18, SECTION 1001. Date Randall 0, Fisher Check appropriate classification: D Individual D General Partner D Corporate Officer (Indicate Title) fJ Other. Explain: Vice President of ACC Operations, Inc., the Member FCC .394 (Page 5) September 1996 FCC 394 APPLICATION FOR FRANCHISE AUTHORITY CONSENT TO ASSIGNMENT OR TRANSFER OF CONTROL OF CABLE TELEVISION FRANCHISE March 7, 2002 EXHIBIT 1 (Part I, Q. 2a) [Attach as an Exhibit a copy of the contract or agreement that provides for the assignment or transfer of control (including any exhibits or schedules thereto necessary in order to understand the terms thereof). If there is only an oral agreement, reduce the terms to writing and attach. (Confidential trade, business, pricing or marketing information, or other information not otherwise publicly available, may be redacted).] Attached is a copy of the Asset Purchase Agreement between Verizon Media Ventures Inc, and Adelphia Communications Corporation (dated December 17,2001) including Exhibits, Confidential information has been redacted. VERIZ()N MEDIA VENTURES INC. Page ARTICLE I . Definitions and Interpretation :...... ~.;....., ..~..... ,'" .....;.; .....,... ............. :..... ..... ...... ..1 1.1 DefinItIons .~....,.. ....,... .........,. ....:...... ..,...... ........... ........,... ......;. ..............:...... ..,...... .......... ..1 1.2 Interpretation.,...,......:. ............. ...... ..........,. ........ ............. "".' ... .~:...........,.. .... ......... ........ 10 ARTICLE U TheAcqUlred Assets ........... ..., .... .".... ;" ... ....... .... ...... ............ .......;. ,. ........... ...,.. 10 2.1 AssetsSubject to Agreement................... .......... ......... .......... ........... ............. ... ..... ...,... 10 2.2 Excluded Assets ...,......, ......... .......... .................... ......... ... ..,.... ........... .......... ".'''. ,........... 12 2.3 Third Party Consents .............. ....... ~...............:................................. ..~.. .................... ,.. .13 2.4 LIcense.... ............. ........ ........... ........ ...................... ......... ......... ..,...... ....... .... .....:.......... .14 . ARTICLE ill Assumption of Liabilities ........;.....~.....:.............:.......,.........................,..........14 3.1 Assumption of Liabilities ...... ...... ....... ...... ,........ ....~............ ............. ..;....... ,.. .......... .,.... 14 3.2 Excluded Liabilities..........:.... ......... .... .......... :.... ......... ........ .... ......... ....,....... ;........~ ...... ..14 .ARTICLE IV.. Consideration ............ ..;............... ..... ......... ................. ....... ... .'........... .,'.... ... '....... 15 4.1 Consideration .. .......... ............. .................: ......... ............. .... ............ .......... ........,. .,....... 15 4.2 AdJustments..........,... ...~. ..... .,..,.... .... .;.................. ........ ..... ,. ....... ;...... ........... ...,'.......... ,.15 .4.3 Final Adjustment ..:..;,................................ ........ ......;.......:...... ......,..;......... ................... 16 4.4 Purchase Price Allocations ............................... .......................................... ................. 17 ARTICLES Representations and Warranties of Verizon .,.....................,..........................:.17 5.1 Organization, Standing and Power ...........................,............................;.. ................... 17 .5.2 Authority........>'. ........... ................ ............ ........... .........; ......... .......... ........... ........... ...;. .17 5.3 No Breach or Conflict ...,....., ........ .......,.... .,...... ..... ..~........... .;.. ..................... ...,u......; ," 18 5.4 Material Consents,..............,... ..... ........... ........~.... ............... ..... .......,.. ........... ,...... ........... .18 5.5 Receivables ............... ............. .......... ......... ........:... ........ ....... ,. ................,..... .."..... ....... 18 5.6 Tangible Assets ~. ...... ..... ..,....... ..... ............ ....... .,.... .......... .,..~.. ....,..........;..... ............ ...:.. 18 5.7 Claims, Litigation and Disputes ......................~......;..... ..,.....,.......,.....,........................ 19 5.8 Acquired Contracts ....... ......... ...... ......... ..,....................... ....... .............. ,.... ........, ....:..... 19 5.9 Compliance With Laws ..... ....................... ........ .............,.. ...... .......... ........... ...~.... ..:..... 19 , .5.10.. Taxes, Fees' aIld Utilities .;................................. ...............;.......,.............~...........,........ 19 5.11 : .FraIlchises.,:......~. ,....... ............. .........~.."..... ................ ..... .......... ...,..;... .......... ........ ......... 20. 5.12 . . financiaLStatements.. ....uo.............. .......... .......... .......,.. .;................ ...,........~ ,....... ~,... ,..,. .21 5; 13,<El11ploy~aridRelated f\.1atters .....................:.. ......... ..~. .;;;...,........;. .,.. ..,.... ...:;..:... ...... 21... 5.14 ."Environmental. Matters.....;..... ........~...........,....... ............ .................. ........;... .......... "',' 23 5 .15 ..Brokerage. Fees .,.................... ...... ............. ......... ... ........ ...'....... .....;..... ....... ..... ...... .;......,...23 5.16 ..Free Service Liability ...... ...... ...... ........... ....... ... .............. ........... ;.... ......... ......,.:... .;...... 23 5.17 . . Local .Office....... ....:............... .............. ..... ......... ............ .~... ............ .....,...... ...,....... ..:... 23 .5.18 Poh;Attachments,..................... ..................:........ ............ ". .......... .... .....;...., ... .........:....... 23 5.19 . Restorati()n<.:. ..,. ........:..........,.., .....~....................... .................... .......... ..., ................,. ...... .24 .5.20 · Right of First Refilsal ou......... ..................ou.................... ......... ,......., ..,...... ....ou.. ....... .... .24 . .5 .21 The Syst~l11.................. .;..... ,," ....................................................... ..;....... ,............. ~ .... ..:. 24 ..... .. ......... . :... .... ...... .. .... ...... . . ... <. .. ... ....... . ..... ...... 26 . 5.22 .'. Investment Purpose .......................,~.......ou...........................,.......,......u......".............. ... 5 ~23 .. l)isclaimer ........., ..,n.............. ....... ........ ................... ......... ,................... ......... ;.~. .......,....27 ARTlc:LEVI.. ... Representations. and W mantles. of Adelphia.............n..........~............;.......,.... 27 6.1'.' .'Orgaruzation, Standing and Power ou...............................:.,............ .....................:~'7.;.. ~7 A. .h.' . . ".. . .. ut... onty .~,...... .,~... ...... ........ ~,... ....~.......,... ........;... '" ..... ........... .......... ........... ,..........~..~.....,... 27. ~o Breac11orConflict. .......... ........ ..;............,........,..,............... ~......n.... ..;..... ..... .............. 28 Third.. Party. Consents... ....................,. ..;..........;......... ................................... .... ,: ..... ,.... ,.28 Claims, Litigation and Disputes ,. ........... .... ....... ............ ........... ...... ............ ....... ..... ......... 28 Brokerage Fees ............... ................. .....;.,................ .......... ,.................... ....,. .... ...,.... ~......... 28 Qualification ..... ........... ...........~.................. ........~. ............... .~.. .... ......., ......... ............. ~ ......... 28 Adelphia's Investigation ...... ~,.. .............. ........... ... ......... ...,...... .......... ........,. ,...... ,.. ...,.... 28 6.9 Adelphia and the Adelphia Common Shares ..............................;.....................,....~.~... 29 ARTICLEVn: Verizon's Covenants...... ........,.... ........... ........ .................. ............ .....;.. .......... 30 7.1 Access................................... ......,. .............. ........... .......... ..,..... ........ .......... ......,... ...... .,.. 30 7.2 Conduct of Business Pending Closing ..................................................................,..... 30 7.3 HSR Act .........................~....... ...... .............. .....,.......,.... ..................... ...:;... ............, ...,;... 32 7.4 . Third-Party Consents................... ............ .......... ............. ....... ..~:.... ........... ~.. ........ ........ ~. 32 7.5 Further Assurances .............. ......... ...... .,...... ......... ........ ..........'. .......... ........... .................. 33 7.6 Confidentiality.... ............ ....... ...,............. :.. ............................. ........... .............~.............. 33 7.7 Schedule Updates ..~.. ..... ;;... .~...... .............. ........... ........................ ~... ..;........... ......... ........ 33 7.8 Agreements with Affiliates ................,....................... ............~.............~.. ................,.. .33 . 7.9 Bonds ami Letters of Credit.................,......................................~.................................. 34 . 7.1 O. Non..Competition ....... .... ...,;. .......:.. ........... ....................... ...... ......;... ........... ................. 35 ARTICLE VIII Covenants of Adelphia ....................................................,.........................:' 35 8.1 .. HSR.. Act;........... ..,..,.. ............ ...... ................. ...................... .... ...... ... ........... ......... "'..." 35 8.2 Third-Party Consents........... ......~... ........... ............. ........... ...... .,........ ........... '................. ..36 8.3 Discharge of Assumed Liabilities,......... ............. ....... ........;.. ............................ ........... 36 8.4 Confidentiality .... .................... ........ ...................... ........ .................... ........ ,........... ..........,36 8 .5 Access... ....;................;........................... ....... .......... ........................ ......... ............. .....;........... 36 8.6 Bonds, Letters of Credit, Etc ............ ........ ............... ......... .... ... ...:.......... ......... .... ..~. ..........37 8.7 Further Assurances .... ...... ................. ..................... .................. ........... .......... ......... .........37 8.8 Intellectual Property ...... ........ ....;.........,..;:.. ........... ............. .;.... ......... ........... ..........., ......37 8.9: Vehicles ... ........,. ........ ..... ..... ........ .... ..................... ......... ........ ........... ......... ................... 37 8.11 Gulf Power Case.................. ........... ........... .... ........ ......, .......... .;........ ........... ........ ......... 37 8.12 Operation Deficit Payments .... ...... .............. ....... ........... ....... ...... ......... .,..;...... .,............... 37 8.13. . . Registration of Adelphia Common Shares...,.....~..........................:..........................ou...39 . . AR'n9W IXCollditions .to..Verizon's. Obligations .;..........................~...~.. ......,. .......... :.... ."" 49 . 9.1 ...... Adelphia's Representations and Warranties ..........;...................................~................. 40 .9.2. Adelphia 'sCovenants .......... ;..........; ......... .......,...... ....... .......... ........... ......... ........ ............. 40 9 .3. .Consent~ .... ............ .;.".,......... ........... ............ ...;..... ........ .................;.... ........... ......,.....;.....40. '. 9.4 The Adelphia's Deliveries ..:.................... ........................................... ...,......;........;........AO 9.5 . .. ... .No.Proceedings.................... .................... .;. ........ .....:.......................... ........ ................ .... ...40 ARTISLE X . Conditions to Obligations........... ....... ..................................................... .:......... .41 10.1 ... Yerizon's Representations and Warranties .....................................................................41 10.2 Verizon's Covenants.........;.. .:... ................ ............:......................... ..~............ ............. ,,~;, 41 10.3 . Consents ............. ............................................... .......... ..:..... ...:......... ................... ....... ............ 41 1.0.4 V... '.D..I' . .. '. ...... .". .... ... ..,'41. .. .. enzon s ...e Ivenes ............ ..;........ ................... '~""'"''''''''''.''''''''''''''''''' ................... 10:5 No Proceedings.............. ....... .......;... .:....... ..........:.... .............. ... ~.... ..... ............ ......;... ........42 ARTICLEXI CI . ....d.T . . . .>.... ..... ..... ....... ...... . ... .... .. . ... . ... .i dos~ngan ... emunatIOIl.........,..............."...............,...........,~..................;.....42, 11.1 ClOSing ,........,..;..;......... .....;... ........; ......;.... ;...... .... ....... ......,.;.. ......,.. ...,...,... ........... ,...... 42 " , ' -' , , "- " . . . II 2 T. t...... .... . .4 . . 1 ernuna Ion .....,.................. ......,..... .......... ..;.... .......,..,.. :....,. .;;~.;.. ;.........:.. ............ ..,...... . 3 11.3 Effect of Temunation ..,....,.....ou.......................,............,....... ..........................;..,...:.... 43 ARTICLE xn. . Verizon's Deliveries at Closing...............ou.......;.,..........,...................;;......... 44 12 1 B. D C'fi . 44 . nng- own.. erti Icate ......;..............;...... ................. ............ ......... ........ ..."........;... ",' . 12 2 S '..C.. 'fi 44 . . ecretary s erti Icate.. ........... ....;... ............. .........,.................,........ ......"... ..".:........... . 12.3 V erizoD Ancillary. Agreements.................;......;.., ......... ~...;;.. '............ ....,.;.................... 44 12.4 Other Agreements........................ ....,......... ;....... ........... ......... ........ ........,.,.... ....... .......... 44 1.2 6 G. d S. . d' . .. .C. 'fi . 44 . 00 . .. . tan lng. eItllcates... ......... .......... ........... ,....;. ...,......., ..~....... .~......... ........., ....... 12 7. FCC 0.' . 44 . ..... .. pinion..... ......... .................... ........... .........; ...,......... .... ......... .... .,................ ........., . 12.8 Opinion of Counsel ...........;. ........ ;...... .... .......... ........... .......... ........ ."...,.... ",'" "," ........44 ARTICLE XillAdelphia'sDeliveries at Closing .......~....................,......................,~....,....... 44 13.1 The Payment............................... ... ..>. .~...... .,...... .......... ......;; ..... ........ ............ ........... ...... 44 13 2 B. . D. C 'fi 44 . nng- own ert! Icate ............... ............ ....,.... ........... ........ ............ .....,.. ..~..,...........;.. . 13 3 S ., .C. 'fi 44 . . ecretary s ertl .Icate......... ........... ............ ........ .........;.. ........ ......, ....,......... ........... ....;. .. 13 4 Ad I hi A.. '11 A 45 . . e pa . nClary . greements.....................,................................,........,.................. 13.5 Other. Agreements.:.,......~.......,..... ...;........; ..... ...., .......... ........... ...;.... ...,........ .......... ........ 45 13 6 Opinion of Counsel .. ............................................ 45 ARTICLE XNTax Matter~.~~d.A~~~~.~. ::::::::::: :::::::::::: ::::::: :::::...... ..;...;.............. .......... ... .;.. 45 14.1 . Filirigof Returns .........; .......... ............ ...... ..... ...,;... ...,.... ................... ...,....,... ....;;.........,. 45 14.2 Access to Books and Records ....................................................,.;.............................. 45 14.3 Indemnification for Taxes..... ...... .............. ....;... ......... ............ .......... ,........ ,"'" ..:.... .,.... 45 14.4 Transaction Taxes ....... ........... .......... ..... ............ ...................... ........ ........ .......... ,. ........ 47 1 ~.5Tax Prorations. ,.... ....,..... .,..:.......; ................., ..;;.... .....,... .........., ..;.;... ........... ,'" ," .......;;. 47 14.6 Tax Refunds and Tax Treatment .;....;...............................,............. .............................47 ARTICLE XV Indemnification....... ...... ..;........... ........ .......... ........,..................... ,. ............;..048 15.1 SurvivatofRepresentations, Warranties and Covenants ..............................,............048 15.2 Indemnification ......... ;....... ...;............ ...... .......... ..................... .......... ........., ................: 49 153 Limitations on Liability......;.....no. ...,......... ............ ...... ............ ........ ............ ........... ...;.. 49 15.4 Pefenseof Claims ..... ..:.......,........; .......... ........... ........... ......... .......:; ......... ...,.... ;;.. ........ 51 15,5 No IndemnifiableClairnsResultirigFrom Governmental Entity .. . Acti()n ,........ ..... ....;. ;;...;. ....~..'... ',,' ,", ..,.......... .......................... ,.............;. ...... .; ... ........ ...:.... 53 IIlfringement ... ................ .~...... ..................... ........................................ ........................... 53 Securities Indemnity ...... ..:................................... ,;................... ..;;.............., ................. 53 15,8 . ... Inapplicability to Taxes....... ......... ..............,........ ..~...;.......... .......... .......... ....".~..;,..... ,..54. AR TICLEXVI Miscellaneous.......,......... ............ .................. .... ,..;......................................... .-54 16.1 Expenses..... ..... ..... ............,.. ................... :............ .....,.,..............,........;:...... "".. ......;..... 54 16.2 .Governing Law... ........:........ .... .......... ..........;......... ..................,... .,........,.. ".......,.. ......... 54 16.3 . N otice~,... ...; .;;:.......,' ........ .,............;.. ....;..... "'"',''' .;.......,................. ~..... .................... n.~. 54 16.4 ...... ... Denriitionof Agreement..... .....,..., ,........... ........ .....~:...... ...;....... .... '.... ..;...~... ................. 55 16 5 H. .d' .... G . .d. ...... .......... ... . .. ... . ...... ...... ......... . ......55 ,. . ..ea. .1Dgs, en er...n..................... ........;.,. ..................,..,."..............,........ .,......~..... ...... 16.6 .Counterparts; Third. Party Beneficiaries.;. ........... ................. ........... ........... .~..... ......,. .;56. 16.7 . ...iEntire AgreelIlent ......... ........ ..... ~..; ........n... om.................".... ~... ..... .,. .....;;.. ,........,.. .,. ..... 56 .. .. .16.8.. . ... ..Modifications....n...,~..........................:..,...............,...........................~;.......,................. 56 16. 9.. .A....... ..... dB; .d'. .E". .. .. .... .. H . ... .. ..... .... ....... ......... ........ ...56 . . ... s~lgDlnent an. m mg. uecL........,.........,.......~.................................,.....~~....~".... ... Schedule .1.1 Schedule 2. 1 (d) (i) Schedule 2.1 (d)(ii) Schedule 2.I(d)(iii) . Schedule 2.1 (d)(vii) Schedule 2. 1 (d)(ix) Schedule 2,2(h) Schedule 5.3 Schedule 5.4 Schedule 5.6 Schedule 5.7 Schedule 5.8 Schedule 5.9 Schedule 5.10 Schedule 5.11 ' Schedule 5.12 Schedule 5.l3a Schedule 5.13b Schedule 5.l3c Schedule 5,16 Schedule 5.17 Schedule 5.18 Schedule 5.19 Schedule 5.20 Schedule 5.21 Sl:hedule7.2 Sched~le7.8(b), Schedule 9.3, Verizon'sKnowledge Real Estate Leases Equipment Leases ..Pole Attachment and Conduit Agreements Franchises . Other Contracts Excluded Assets No Breach or Conflict MateriarConsents. Tangible Assets Claims, Litigation and Disputes Acquired Contracts Compliance with Laws Taxes, Fees and Utilities Franchises Financial Statements Employee Benefit Plans Employee Benefit Plans-- Pending Actions, Chums or Lawsuits Employee Matters Free Service Liability Local Offices Pole Attachments Restoration Right of First Refusal The System Conduct of Business Pending Closing Tariff RateS. ' Required Consents LeaSe Agreement .. ..... ....... .... ... . .. ... ...., .. .. Pole Attachment and Conduit Occupancy Licensing. Agreeijlent FCCOpinion Opinion of Counsel forVerizon Opinion of Counsel for Adelphia Transition Services Agreefilent This Asset Purchase Agreement .. (this "Agreement") is made and entered into this 17th day of December, 2001, by. and between Verizon Media V enturesInc.,a Delaware corporation ("Verizon") and.. Adelphia Communications Corporation, .a.Delawarecorporation ("Adelphia"). Adelphia and Verizon shatl be referred. to herein individually as a "Party" and collectively as the "Pauties". WHEREAS, Verizon owns and operates the cable television system approximately 58,000 subscribers in the geographical areas listed on Annex I hereto; WHEREAS, Verizon desires to sell, convey, transfer and assign toAdelphia,' and Adelphia desires to acquire from Verizon, the assets relating to the Business (as such term is defined herein) described herein and, in connection therewith, Adelphia has agreed tqassume certain liabilities of Veriz()nrelating to the Business, all on the terms and conditions set forth herein. NOW THEREFORE, the Parties hereto agree as follows: "1984 Act" is defined in Section 5.21 (b )(i). j'Accounts Receivable;' means the aggregate accounts receivable exclusively related to the System on Verizon's booksasoftheClosing Date. "Adelphia ApcilIatyAgreements" is defined in Section. 6.2. ltAdelphia COmmon Shares" means shares of Class Acommon stock, par value $0.01 per share, of Adelphia. . "Adelphia PerShareValue"means the closing price of an AdelphiaCommon Share,as quoted on the NASDAQ National Market, as reported in the Wall Street Journal (NY morning edition), for the full trading day that is three trading days prior to the Closing Date. "Adjustment Amount" is defined in Section 4.2(b). "Affiliate" means any Person who, directly or indirectly, controls, is controlled by oris under common control with the relevant Party. "Agreement"is defined in the introductory paragraph of this Agreement. "Allocation". is defined inSectio1l4.4. "Ancillary Agreements" means the Assumption Agreement, the Bill ofSale~nd Assignment Agreement, the Intellectual Property Agreement, the Transition Services Agreement and the Employee Matters Agreement. . . "Assumption Agreement". means the. Assumption. Agreement of Adelphia, dated. as of the Closing Date, in substantially the fOrInofExhibit A. . "Bill of Sale and Assignment Agreeinent" means the Bill of Sale and Assignment Agreement of Verizon, dated as of the Closing pate,. in substantiall ytheform of ExhibitB. "BusinessNon~Statutory Intellectual Property'" means the. Non-$tatutoryIntellectuaI Property, excluding. Proprietary Business Information, which. is used in and required for use in .. the Bllsiness..as.ofthe Closing Date and. is:. (i) owned by.Verizon asoftheClosiItg..Date;or(ii) owned byanyPersonandlicensed to Verizonwiththe rightofVerizon to grant sublicenses to any other Person who is not ail Affiliate of Verizon, without the payment of compensation or , other consideration to ally Person. .. . .. .. . ... . ., .... ... . . . "Code" means the United States Internal Revenue Code of 1986, as amended;. "Commission" means the United StatesSecuritiesand Exchange Commission. "Contract" means any written contract, agreement, lease, license, commitment or other legally binding written agreement. "Court Order" means any judgment, decree,injunction, order,writ()rruling of any Governmental Entity or arbitrator. "Copyright Act" is defined in Section 5.21 (b )(i). "Customer" means any Person who is subscribing to billable video or data services provided by the System. "Customer Discount" . means, in the event the number of Equivalent Basic Subscribers. for th. e s.y... ste.m... . on.. the. . dater.. h. at is~.our. bU~.in.e. ss d~.YS .prio. rto .the. CI..O.. s..... n. .D.. a.t.e. i.S......1. e..s..s. ..t.h. .....~..... '......... .. . ... .... .........e number equal to the product of (1) the dIfference between mmUs the~of Equivalent Basic Subscribers for the System on such date, multiph by(ii)_. ' "Employee" means each active employee, tull-timeorpart-time~ofVerizon(or.an Affiliate of Verizon) who, as of the date of this Agreement, is determined by Verizonto have.. perfonned {during the 12-month period immediately preceding the date of this Agreement (or the period of the employee's employment with Verizonand its Affiliates, if less)) substantially all of such employee's services in connection with or for the benefit of the System (other than employees based. at the Wentzville, Miss()uri call center). Subject to the provisions of the Employee Matters Agreement, the tenn "active employee" shall include anyemplo}'ee wh()is on !lliIitary leave, maternity/paternity leave, . other approved leave. ofabsen~e,.~~~~-:t~IlI1dis~1:Jility, 19n9tennJiisability, workers'. compensation, or Iayoffwith Tefall or otherretutnrights<:. .. "Employee Matters Agreement" means the Employee Matters Agreement between Verizon and Adelphia, executed byVerizon and Adelphia as of the date hereof in thefoon of Exhibit D. "Environmental Laws" means .. the .. Comprehensive . Environmental. Response, Compensation, and Liability Act, the Emergency Planning and Community Right-to-Know Act, . the Water Pollution Control Act, the Air Pollution Control Act, the Hazardous Materials Transportation Act, the Toxic Substances Control Act, the Resource Conservation and Recovery Act, the Occupational Safety and Health Act as well as all other. federal, state or .locallaws, regulations or requirements that are similar to the above-referenced laws or that otherwise govern chemicals, products, materials or wastes that pose risks to human health or safety, or the environment. "Equipment" is defined in Section2.1(c)~ "Equivalent Basic Subscribers" shall. mean the number obtained by. adding (i) the number of first outlet residential non-seasonal subscribers for ~asic cable television service of the System who have paid the applicable connection and installation fee and have made at least one monthly payment for service anhe applicable monthly rate for basic service and whose accounts. are . not more. than. 60 days past due fro. m thefirs.t. da.y.o.fthe...month ..f;. o.r.....w..... hi.'chservice was rendered(or.,ifmo.f..ethan....60days .' -', " . past due, who owe less than $10.00), . . .. . . , . (ii) .. the resultobtainedby dividing the aggregatepf the gross monthly billing (excluding installation,connection, relocation and disconnection fees and miscellaneous rental charges for equipment such as remote control devices and converters) from business and commercial accounts, residential bulk units, hotels/motelsandother conunercial establishments who have paid the applic::ableconnection fee. and who have mad.... e.. a. t. Ie..... as. t.....o.D..e.... mo.nt.hly.... p.......aym..... en.....t..fi.o.. r.. .se....,rv.. ..ic.e.at. th....eaP. pli.c..a.b.le..... month.....l.y........r~t.ea.....n.d... w.. h.....o..s. e accounts are . DOt more thaIl60 days past due from the first day()f the m.onth for which such service was rendered, by $30.20, which represents the average monthly service charge in effect for a first outlet residential connection for expanded basic cable television service, plus . "ElUSA" means the Employee RetirelIlenflncomeSecurityAct of1974,asamended, and the rules and regulations promulgated thereunder. "ERISAAffiliatei'means any entity tbat with the subject Person is: (3;) a member ora controlled group of corporations within the meaning of Section 414(b) of the Code; (b) a member of a group of trades or businesses undercommon control within the meaning of Section 414(<:) of the Code; (c) a member of an affiliated service group within the meaning of Section 414(m) of the Code; or (d) a member of a group of organizations required to be aggregated under Section414(o) of the Code, . "Estimate Statement" isdefinedin Section 4.2(c). . "Exchange Act" means the United States Securities Exchange Act of 1934, as amended, and the rules and regulations promulgated thereunder. "Exchange Act Reports" means Ade1phia'sAnnual Report on FormlO~K for the fiscal year ended December 31,2000, Adelphia'sQuarterly ReportonForm lO-Qforthe qUai!ers ended March 31, 2001; June 30,2001 and September 30, 2001, all reports filedbyAdelphia on Form 8-K after December3l, 2000,andall.documents filed by Adelphia with the Commission pursuant to SectionJ3(a), 13(c)or 15(d) of the Exchange Act onor prior to the date hereof orth~ Closing Date, as the case may be. "ExdudedLiabilities" is defined inSectioIl3.2. "Excluded Marks" means all Trademarks and related registrations aIid applications Jor registrlitionowned by Verizon or an Affiliate of Verizon, or licensed to Verizon or an Affiliate ofV.erizon b. yany Person, and any derivations9f th.e ~. orego..ing. . .- '-,', .- - : ," . "GAAP"means United States generally accepted accounting principles. "Governmental Entity" means any court, administrative agency or commission or other governmental authority or instrumentality, domestic or foreign, means the Hart-Scott-Rodino Antitrust Improvements "Intellectual Property" means all Statutory Intellectual Intellectual Property. N on-S tatutory "Intellectual Property. Agreement" means the Intellectual Property...Agreernentbetween Verizon and Adelphia, dated asof the <::losing Date, in sub~tantially the form of Exhibit C. patents or patent applications claiming a filingdate on Qraftefthe Closing (b) copyrights in copyrightable subject matter..having .acreation date on Or after the Closing Date; (e) Intellectual Property developed or acquired by Verizon or any of its Affiliates after the Closing Date; (g) Third Party Intellectual Property (other than thatex:presslyinclude~ in Business Non-Statutory Intellectual Property or Business Statutory Intellectual Property). "Material Acquired Contracts" is defined in Section 5.8. "Material Adverse Effect" means withrespect to the System a material adverse effect on the financial condition or business operations of the System or the Acquired Assets, taken as a , whole. (a) mechanics', carriers', workmen's, repairmen'sand other likeLiensimposed by law arising or incurred in the ordinary cOUrse of business consistent with past practices, (c) such other imperfections in title, charges, easements, restrictions and encumbrance~which do not,.materially detract. from the value ofpf materially interfere with the present use of the assets to which they relate, (d) retention of title agreements with suppliers entered into in the ordinary course of business, or other Liens thatare released concurrently with or prior to the Closing. "Software" means all software, in object, human-readable or source code fonn,as such software exists as of the Closing, inc1udingto the extent such exist: programs,applications, datab~es, datafiles,compon~nts or elements thereof; and all versions, upgrades, updates, enhancements and error corrections of all of the foregoing and documentationtherefor. "Stahltory Intellectual Property" means all United States and foreign patents and patent' applications of any kind, United States and foreign works of authorship,mask-1,Vorks,copyrights, and.. copyright and Jnask . work registrations and .. applications for registration,and.. any rights or licenses in the foregoing. "System" means the cable television system serving the geographical areas identified on Annex I hereto. "Tariffs" means,collectively, the Verizon Tariff,FCC No. lO,section 4,effective January 25, 2001, for broadband video services and the Verizon Tariff, FCC No. 14, section 20, effective May 2,2001, for optical networking services. . ''TaX Indemnitee" is defined in Section 14.3(c). .... E~ecutjo1l Copy Confidential 0,,",, Proprietary "Third Party Intellectual Property" means any and all. Intellectual property. owned by any Person, otherthanVerizon,inc1udingAffiliates of Verizon, without regard as to whether Verizon has any rights therein or the right to assign such rights to Adelphia. "Trademarks".. means trademarks, tradenames, applications for trademark registration; service marks, applications for service mark registration, domain names, registrations and applications for registrations pertaining thereto, and all goodwill associated therewith. . "VerizonAncillary Agreements" isdetined in SectionS.2. "Verizon BenetitPlans" isdetined in Section 5. 13(a). "Verizon's Knowledge" (or any similar phrase) means the actual knowledge (after reasonable inquiry) of the individuals listed on Schedule 1.1. 1.2 ... InterpretatiOl1'. When a reference is made in this Agreement toa Section, Schedule, Annex or Exhibit, such. reference shall be toa Section, Schedule, Annex or Exhibit of .this. AgreeIIlent. .unl~ss otherwise indicated.. ... The. headings. contained in this. Agreement ... are. for reference purposes only and shall not affect in any way the meaningorinterpretation of this Agreement . Whenever the words "included, "includes" or "inc111ding"are used in this .. Agreement, they shall be deemed to be followed by the phrase "without limitation."Whenused in this Agreement, the word "primarily" shall be deemed to be followed by the phrase "or exclusively. II All accounting terms not defined in this Agreement shall have the meanings determined by GAAP. Unless otherwise indicated, all references to dollars refer to United States d. o.I...lar.so.. ..The. Part. ies. adco. ow....ledge . t.hatbo.. th .P..arties.... have. .....p... art.. i..c..i......p. a...te....d...........i.n....th. e.... ...dl".a...~...t..in..g............an.......d.. prepar.ation "of ..... thiliAgreeIDent. . an4the. AncillaryAgreements;u14agreet~ataI1Yrule.Of., . construction to the:effectthatambiguities are. to. be construed against the. drafting party shall <not be applied to the construction or interpretation of this Agreement .orthe AncillaryAgreements. \lerizon and either (i}held.. solely for. use in the operation ofthe.Systelll or (ii) held fof multiple uses including use in the operation of the System and that can r~asonably. be divided into a pan pertaining exclusively to System use and a partpertaining to non..Systemus~,pr()vided that such divisiondoes not adversely affecttherespectiv~ JunctioningoHheparts, in any ofthe follOWing (in each case, other than the Excluded Assets): . (a) (e) Equipment. All equipment and other personal property (the "Equipment"), including:headendequipment" origination equipment, transmission and electronicequipmeIlt; distribuHon equipment, including trunk, distribution . and drop lines; amplifiers; powersupplies~conduit, vaults, pedestals, grounding and pole hardware; routers; customer. devices, including converters, encoders and taps; installer. and technician equipment. including vehicles, tools and test equipment; cable data terminals; and office eqUipment. All of the following Contracts and Permits (the Verizon's real estate leases with third partiesseHorthonSchedule (ii). V erizon's~q\li}Jment leases (excl~ding Software) with thirdparties~ including those,equipment.leases set .forth'on Schedule.. 2.1 (d)(ii) (which is alist of such leasesthat require annual or one-time expenditures by Yerizon in excess of$25,000); '. (ix).. Allother Contracts used by Verizon. primllrily. in. itsopenition of the System, inclu~ing those set forth on Schedule 2.1 (d)(ix), (which is a list of such other Contracts which. require annual or one-time expenditures by Verizon in excess of $25,000). 2~2 Excluded Assets. Notwithstanding. anything contained in Section 2.1 hereof to the contrary, the term "Excluded ASsets"shaU consist of the following properties, assets and rightsofVerizon: (a) . Cash. Cash or cash equivalents, on hand or in banks, owned byVerizon, certificates of deposit, bank or savings and loan accounts, u.s. government securities, any other marketable securities of any kind or nature or notes receivable. (h) . AssetsNot Used Primarily forSvstem. All assetsofVerizonthat are (i) not held solely for use in the operationoftheSyst~mor (ii) heldJormultiple Uses including use. in the operation of the System and that cannotreasonably be divided into a part pertaining exclusively to System use and a part pertaining to non-System use without such division having an adverse affect on the respective functioning of the parts, including those assets listed on Schedule 2.2(h) and any assets of anyVerizonBenefit Plan, except as provided otherwise in the Employee Matters Agreement. (i) . . Rillhts under Agreements. All rights of Verizon and its Affiliates under this Agreement, the Ancillary Agreements, the Lease Agreements, the Pole Attachment and Conduit Occupancy Licensing Agreements and the certificates. and other documents delivered by Adelphia in connection with the transactions contemplated by this Agreement and the Ancillary Agreements. (j) Records of Sale. All records prepared in connection with the sale of the System, including bids received from third parties and analyses relating to the System. ' (I) ... .. Proi!ramminll Agreements. All of V erizon 'sprogramIriing contracts, affiliation agreements, retransmission consent agreements aIld similar agreements. . . . 2.3. Third-PartvConsents. .. Nothing inthisAgreementshaIlbeconstrued as an attempt by Verizon to assign any Contract or to transfer anyPennit to the extent that such Contract or Permit is not aSsignable without the necessary consent, authorization or approval of the other party or parties thereto (including any Governmental Entityt If the Closing is consummated rtotvvithstanding the absence of one or more Material Consents or any other conseIlt, authorization orapproval, at such time as such Material Consent or other consent, authqrizationorapprqval hll$ t>eenobtained,orany.. requisite Jiling .0rnoticehCiS. beell IDa~e or delivered, ll$applicable;suchContract ... or. PemUt shall be ...assigned ()f transferred to Adelphia automatically without. any other conveyance or other action by Adelphia..Following the Closing and . for a period of 12. months thereafter, the Parties. shall. use their commercially reasonable efforts, and shall cooperate with each other.. to obtain promptly . any such consent, .authorization or approval; provided, however, Verizon shall not be required topayany cOIDpepsationorother , consideration therefor. During this 12-monthtimeperiod and pending or in the. abse.nce of any such consent, authorization..or. approval, the . Parties shall.. cooperate with .each.....other in.any reaso.n. able and la. wful arrangements...toprovide .toAd.elp. hiatheb... ene.fit.san. ..d liabi..lities .ofuseof such Acquired Contract... . (a). .. Verizonshallexecuteand deliver to Adelphia on. the Closing Date the Intellectual Property Agreement pursuant to which Verizon shall grant to Adelphia a limited license on the terms and conditions set forth therein for Licensed Intellectual Property. (b) . Except and to the extent expressly provided in the Intellectual Property Agreement or transfeITed pursuant to an Acquired Contract, if any, and subject to Section 2.3, (i) no rights or licenses, express or implied, to use or possessanylntellectual Property, including Third Party Intellectual Property, or any Software are transferred to Adelphia and (ii) nothing shall constitute. or be construed as a license by Verizon under any Intellectual Property now Or hereafter owned, obtained or licensable byVerizon or any Affiliate of V erizon or under any Third Party Intellectual Property. ARTICLE ill 3.1.... . Assumpti?nof Liabilities. Upon the terms and subject to the conditions . of this . Agreement, Adelphia shall assume, pay, perform and discharge when due, effective as of the Closing, the following liabilities, responsibilities and obligations(the "Assumed Liabilities"): (a) Acquired Contracts. All of Verizon's liabilities, responsibilities and obligations under the Acquired Contracts pertaining to, . or to be satisfied or performed, in the periodonor after the Closing Date. . .. . (b) Current and Accrued Liabilities. All of Verizon's accounts payable relating to the operation of the System remaining unpaid on the Closing Date and accrued current liabilities as of the Closing Date to the extent such liabilities are included in the calculation required by Section 4.2(b). '<. ...... . ..(c). . QpcratingLlabilities.Allliabtlities, . respqnsibiliti~s,obligations, costs and 'expenses with respect to claims arising in any way with respedto .or as a result of the operation of the System on orafter the Closing Date,including(i} any and aU franchise fees, pole attachment and ccmduit rentals, copyright fees, Taxes or tort claims arising ollt of or attributable to the operation of the System or the ownership of the Acquired Assets on or after the Closing Date and (ii) any and all termination or similar fees, costs or liabilities relatingto anY Contracts covered by Section 2.2(1), 4.1 Consideration. Except as provided in the next sentence, the. total consideration to be paid by Adelphia to Verizon for the Acquired Assets shall be (i . which shall consist oCa number of Adelphia Common Shares issued at the Closing-equ t divided bytheAd~lphia Per Share Value, subject to the adjustments required by Section . an Section8.ll(d) (if applicable) hereof, and(ii) the assumption by Adelphiaof thc:Assumed Liabil.i.ties.. N. Qt~.it~.standi.n....g.the. p.recedi.ng s.ent.e..nce, A.. de. l.p.hia.m~.......in...'ts.. di. .....s.....c~r~t~.o.......Il.} m.~e... .a. ' cash payment, 10 heuof Adelphla Common Shares,' equal to~nmlInedlately available funds asconsideration~subject to the adjustments required by Section 4.2 and Section 8.ll(d) (if applicable)hereof, forthe Acquired Assets andthe other transactions contemplated by this Agreement. The payment toVerizonof Adelphia Common Shares or cash, as the case may be, is herein referred to as the "Payment." . Adiustments. The value of the Payment shall be: (a). Increased by anamountequalto the sum of (i) anymoniestelatingto the System that are on deposit with third partiesas security for Veri;zon's performance of the AcquiredContracts as. of the Closing Date provided such deposits will be treated as AcquiredAssets, and (ii) the.value of the Accounts Receivable and the prepaid expenses related to the System (including prepaid pole, conduit and manhole . rentals, utility charges,. water and sewer charges, municipal garbage and. rubbish removal charges, and similar charg~s, but excluding prepaid expenses relating toanyContracts that will not be assumed by Adelphia or relate to Excluded Assets). . .. . (b).. .. Red~cedbyan amount equal to the sum of (i}theCustomer Discount(if applicable), (ii) the accrued expenses, prepaid income, amounts payable and accrued cUfl:eIltli~bilities (including.. accrned.. but unpaid pole, . conduit~d'rnClnhol~r~n~als,>~ees ..payableuncier.the Franchises, and. copyright. royalty payments,'t,urexcludirig,inallcases, Tax items governed by Section 14.5) related to the System, inc1udedintheAssumed Liabilities and to be paid after the Closing Date butthatrelatetotheperiodprior to the Closing Date, (iii) any monies. held by Verizonasrefundablecustomer deposits (including refundable deposits from customers for converters, encoders, decoders . and any related equipment), liability for which will be assumed by Adelphia, (iv) the . amount of service charges that have been prepaid by Customers prior to the Closing Date butthat . . relate to the period after the Closing Date. and (v) the pro. rata share of accrued but unpaid, ..as of the . Closing Date, rentals, utility charges, water and sewer charges, municipal garbage and rubbish removal charges, rents and other custOIoarily'proratable items (}fVerizon included in the Assumed Liabilities. ' The net amo~ntof theincreasesandlor reductions to . the total value . of the Payment . (the "Adjustment Amount") shall be detennined in. accordance..\VithGAAp. and,. where applicable, to refl~ct the principle that, except as qualified in. this Section. 4.2, all income and expenses attribUtable to the System. fortheperiod>befor~ 12:01 a.m. (Eastern Standard Time) on the morning of the Closing Date are for the account of Verizon, and allincome and expenses attributable to the System for the period 011 or after 12:01 a.m. (Eastern Standard Time) on the morning of the Closing Date are for the account of Adelphia.; (c) . Verizon shall prepare and deliver to Adelphia, at least five business days prior to the Closing Date, a statement (the "Estimate Statement") showing in reasonable detail the amount reasonably estimated byVerizon, ingood faith, to be the net amount, if any, of the adjustments provided for in this Section 4.2 and,ifapplicable, Section B.II(d). Within 45 days after the Closing Date, Verizon shall prepare. and deliver to Adelphia a statement (the "Final Statement"), setting forth Verizon'sgood faith determination of theactual Adjustment Amount (the "Final AdjustmentAmount").Each of Verizon and Adelphia shall provide the other Party with access during normal business hours. to . any books, records,' working papers. or other information. in. its. possession after the Closing reasonably necessary or useful in the preparation of the Final Statementand the calCUlation of the Final Adjustment Amount. The Final StatemeIlt shall becoIl1efinal and binding. upon aU.Parties hereto on the 45th day following delivery. thereof (without counting such dayofddivery) to Adelphia unless Adelphia gives written notice of disagreement withthe Final Statement (anNotice of Disagreement") toVerizon prior to such date. Any Notice of Disagreement shall specify in reasonable detail the nature of . any disagreement so asserted and relate solely to the review of the Filial Statementand the calculation of the Final Adjustment Amount. '. (b) '... . IfaNotice of Disagreement is deliveredbyAdelphiainatimelymanner, then.. the Final Statement shall become final. and bindingup()n allpartie~her~toonthe ecirlierof (x) 'the date Verizon and Adelphia resolve in. writing. any differences they may have with respect to all matters specified in the Notice of Disagreement and (y) the date all disputed matters are finally resolved in writingby an independent public accounting firm (the "Independent Accountants").During the30~day period following the delivery ofa Notice of Disagreement, Verizon and Adelphia shall seek in good faithtotesolve any differences which tbeymay have with respect to any matterspecifiedintl1eNoticeof Disagreement and each shall provide' the other with reasonable access to. any books, . records, working. papers or other' information. reasonably. necessary or .useful in.. the preparation or calculation of (i) the Final Adjustment Amount, (ii)the Final Statement, or (iii)the Notice of Disagreement. At the end ofsuch30-day period iftberehasbeennQ resolution of the matters specified in the Notice of Disagreement, VerizonandAdelphia shall submit any and all matters arising under thisSection 4.3.which remain in dispute to thelIidependeIlt AccouIltants for review and. resolution; The IndependentAccountants . , . . shallbeK}>MG,L~Por,.if suchfinn is unable orunwilli~g tQact,s~ch other nationally recognized independent public accQuntingfinn as shall be agreed upon by Verizonand Adelphia... The.. Independent Accountants shall render a decision . resolving the matters submitted tothe Independent Accountants within 30 days following submission thereto (or as soon. thereafter as reasonably practicable). The fees. and expenses .ofthe Independent Accountants incurred pursuant to this Agreement shall be shared equally by Adelphia and Verizon. (c) lfas a result of any adjustments made pursuant to this Section 4.3, Adelphia is finally detennined to owe an amount to Verizon, Adelphia shall within three business days pay cash equal to such amount to Verizon; provided, however, that if Adelphiais .. required to. pay. more. than $100'000 pursuant to this S~ction 4.3,. Adelphia may pay such amount in . non-restricted, freely-tradable. AdelphiaCommon. Shares instead of cash. Further, if as a result of any adjustments made pursuant to this Section 4.3, Verizon is finallydetennined to owe an amount to Adelphia, Verizon shall within three business days pay cash equal to such amount to Adelphia. 4.4 Purchase Price Allocations. No later than 90 days subsequent to the Closing Date,Verizon shall provide Adelphia with the allocation of the Payment, the Assumed Liabilities and other relevantiteI11s (including, for example, adjustments to the Payment) to individual assets (includingthe Intellectual Property Agreement) or classes of assets within the meaning of Section 10600f the Code (the"Allocation") and shall cooperate with Adelphiainpreparing Form 8594 for filing by each~ If Adelphiaand Verizon agree to anAllocation, Adelphiaand Verizoncovenant and agree that (i) such Allocation shalL be conclusive and final for all purposes, and (ii) neitherAdelphia nor V erizonwilltakeany position before an yGovemmental Entity or in any judicial proceeding that is in any way inconsistent with such Allocation unless otherwise required by Law. Notwithstanding the foregoing, if Adelphiaand Verizon cannot agree to an Allocation, Adelphia and Verizon covenant and agree to file and cause their respective Affiliates to file all Tax Returns and schedules thereto consistent with each of Adelphia and Verizon's respective good faith allocations, unless other",:ise required by Law. Agreetnent.Th~executionanddelivery . of this Agreement andth~YerizonAnci1lary .AgreeIIlents,and the. consummation ..ofthe transactions contemplated hereby and thereby. by Verizon, have been duly authorized by all necessary corporate action. This Agreement constitutes, . and upon execution of each of the. Verizon Ancillary Agreements such. agreements c()nstitute or will constitute, valid and binding. obligations of Verizon, enforceable against Verizon .in accordance with .their respective terms, such enforcement subject to bankruptcy, insolvency, reorganization, . moratorium, or similar Jaws of general application affecting creditors' rights and theappl,ication of general principles of equity. 5.3 No Breach or Conflict. Except as would not have a Material Adverse Effect, and subJecno the receipt of the approvals described on Schedule S.3,neither the execution, deliyery aIldperfonnance . of this Agreement and theVerizonAncillary Agreements, nor the consummation ()f the transactions contemplated hereby and thereby, will (a}causeVerizon to breach any Law or Court Order that is applicable to the System, (b) conflict with or result in a . violation of Verizon's Certificate of Incorporation or. Bylaws,. (c) conflict with. or result in a breachofany Material AcquiredContraet or (d) result in the creation of any Lien other than a Permitted Lien, or give to others any interest or rights, in or with respect to any of the Acquired Assets. . 5:4 Material Consents. Schedule 5.4 contains a list of (i) Acquired Contracts pursuant to whichaPerson'sconsent tathe execution, delivery or performance of this Agreement by. Verizonislegally()r contractually required, ... and (ii) each Govemmental. Entity which must . consent to the execution, delivery or performance of this Agreement. by.. Verizon, except where the failure to obtain any such consent of such Person or Governmental Entity would not have a Material Adverse Effect or would Ilottnaterially adversely effect the ability ofVerizon to consummate the transactions contemplated hereunder (the "Material Consents"). 5.5 Receivables. All Accounts Receivable were created in the ordinary course of business of the System consistent with past practice. Verizon has good and marketable title to the Accounts Receivable. . 5.7ClaiIns. Litigation and Disputes.E~cept as set forth on Schedule 5.7, and except for actions, proceedings or investigations aff~cting th~ cable television industry in general, there isno claim, litigation, action or legal.proceedingpendingbefore a Governmental Entity or, to Verizon's Knowledge, threatenedagainstVerizon, adversely affecting (i)Verizon's ability to perform its obligations hereunder, (ii)the rights granted under the Acquired Contracts, (iii) the financial condition or business operations of the System, or (iv) the ownership, use, maintenance or operation of the Acquired Assets and the System, that in any such case if determined adversely toVerizon, would reasonably be expected to have a Mat.erial Adverse Effect or materially adversely effect Verizon'sabilityto consummate the transactions contemplated hereby. 5.8 ... Acquired Contracts. Except as set forthon Schedule 5.8 or except as would not have a Material AdyerseEffect, (i) to Verizon's Knowledge, each Material Acquired Contract is valid,. bindinguponVerizon and in full force and effect, and (ii) neither Verizon, nor, to Verizon's Knowledge, any other party to any Material Acquired Contract is in breach thereof or . default thereunder and there does not exist, to Verizon's Knowledge, any event, occurrence, condition, or act that, with the giving of notice, the lapse of time, or the happening of any further. event or condition, would become a breach or default under any Material Acquired Contract As of the date hereof, to Verizon's Knowledge, Verizon has not received any written notice of the intention of any party to tenninateany Material Acquired Contract The term "Material Acquired Contract" means the (i) Franchises, (ii)Pole Attachmentand Conduiti\greements,and (iii) any other Acquired Contract that provides. foraggre gate future. annual payments to ... or from Verizon in excess of $500,000. ... . . .. . :,', . 5.9 . Compliance With Laws. ' Except as disc1osedon Schedule 5.9, the System is in compliance with all Laws applicable to the System, except in any such case where the failure to ...bein compliancewouldnot have a Material Adverse Effect. To Verizon'sKnowledge, Verizon has not received any written notice within the past 12 months relating to violations or alleged violations or defaults under any applicable Law or Court Order,where the failure to cure could resultin a Material Adverse Effect. For the purposes of this Section 5.9, thetenn"Laws" shall bede~mednot to include (i) Laws applicable to Taxes (which are thesubjectofSecti(}n 5.10), (ii).La.......... ...w. s....a..p....p.l.i....c..,.a..b....l..e.,..t...o.....~. ..e Verizo~. Be.n.. .e.fi..tP.....I..an. .....s.......in...c.l......u. d....i.n. .g.. E. R... IS......^..an.. d.......~.h.e.(~.9d...e. '. ....(w.'..,.....h......i.c.h.............a.r...e.>t.h.... e subject of SectionS.13),. (Hi) EnvironmentalJ..a.ws (which are the subject of Section 5.14), 'arid (iv).the Rules. and Regulations of the FCC and the FAA..the Copyright Act, the 1984.A.ct,and the Cable Television Consumer Protection and Competition Act of 1992 (which are the subject of Section 5.21). for any Taxesbave been asserted in writing orassessed.aga.instVerizoIl.... that remain unpaid and would have a Material Adverse Effect; (iii) Verizonhas withheld all required federal, state and local payroll taxes relating to the System required to be withheld and bas remitted or will remitallamountsrequiredto be remitted to the appropriate taxing authorities; (iv) there are no Tax Liens upon the System except for statutory liens covering Taxes not yet due and payable; and (v) Verizonis nota"foreign person" within the meaning of Section 1445(b )(2) of the Code. (b) . Veriz()n has paid in JullanYandalllicense fees, fees owed under the Franchises, business permit costs, pole attachment fees, unemployment and worker's compensation insurance contribUtions and utility bills required to be paid, except where failure to pay such fees, costs or bills wouldnothaveaMaterial Adverse Effect. (c) There are no Un assessed tax deficiencies proposed or threatened. against Verizon,nor.are there any agreements, waivers, or other arrangements providing for extension of time with respect to the assessment or collection of any Taxes against V erizonor any actions, suits, proceedings,. investigations or claims now. pending against Verizon withrespectto any Taxes, orany matter under discussion with anyfederal,state, local or foreign authority relating to any Taxes. I (d) . None of the Acquired Assets is property that Verizon is required to treat as being owned by any Other person pursuant to the so,:-called "safe harbor lease II provisions of former section 168(t)(8)of the Code. (a) Listed and identified onSchedale 2(d)(vii) attached hereto are all. of the Franchises presently heldbyV erizonfor the System, and. the political entity or authority which has granted each Franchise. Except as disclosed on Schedule 5;11 or as would not ,have a Material Adverse Effect: . (i) to Verizon's Knowledge, allgovemmental authorizations. necessary or.. required for. thecon~truction,. maintenance and . operation. of the System have been obtained by. Verizon;...(ii)theFranchisesare.yalidlyexisting~ .l~gally. enf()rceCible .0bligati()11s. ofVerizon and,to. V erizon'sKn?wledg~; <are/validly.. existing, legally enIorceabie obligations ()fthe. other parties. thereto, .inaccordancewith their terms; and (iii) Verizon. is validly and lawfully operating the System under the provisions of the Franchises. ' . . (b) .. . Each of the Franchises expires on the dates set forth on. Schedule 5.J 1. Except asdisc10sed on Schedule 5.1101' as wouldnothave a Material Adverse Effect: (ilyerizon has duly complied. with all of the tenns and conditions of the Franchises and has notdoneorperformedany act which would invalidate or impair its rights under, or give to the granting authority the right to terminate,theFranchises;and(ii) toVerizon's ' Knowledge,there. is no pending assertion or claim.. by.. the. franchising authority of any Franchise that operations . pursuant to any Franchisehave"7en iInproperly . conducted or ,. maintained,. or,.. toV enzon's . Knowledge, any facts or circumstances that might give rise ,to any.such assertion or chum; . 5.12 Financial Statements. Attached to Sc;hedule 5.J2are true and complete copies of the.. unaudited statements of operations of the System for. the year ended December .31, 2000, which were prepared from the books and records of account of VerizonkepUn thenonnal COurse of business (the "Financial Statements"). ExcepLas disclosed on Schedule 5.12, the Financial Statements fairly reflect in all material respects the operating results .0ftheSystem for the peri04s indicated. Since the System represents only a portion of the operations of Verizonand since Verizon materially relied on Inter-Unit Services in operating the System, the Financial Statements are basedontheextensive. use of estimates . and allocations. Verizon believes. these estimates and. allocations have been. perfonned on. a reasonable .basis.. However,. since .A.delphia ' is not acquiring significant elements of support to the System that are contained in the Inter-Unit Services, Adelphia will operate under new programming contracts and other conditions that will significantly impact the future operations of, and revenues relating to, the System, and since the System represents only a portion of the operations of V erizon, the Financial Statements may. not be representative of the operating results of the System during Juture periods. 'Theamounts recorded by Verizon for. aS$etimpainne:mts in connection with the System . are not indicative of the value of the assets in the context of the opera.tion of the System by Adelphiaas a going concern. Except as disclosed on Schedule 5.12, from December 31, 2000to the date hereof, there has been no material adverse change in. the. financial. condition. of the System. . ' ,', . (a) Schedule 5.l3a sets forth a complete and correct list, as of thedateheredf, of all Employee Benefit Plans maintained or contributed to by Verizonorany ERISA Affiliate in respect of or for the benefit of Employees (the"Verizon Benefit Plans"). V erizon has made available. to Adelphia true, complete and correct copies of the' Verizon BenefitPlan documents, summary plan descriptions and all related documents. . . , (i)...... ....EachVerizon.BenefitPlan has been maintwned.andoperated. in allmat~ricU,respe<;ts.~n. compliance with applicable Law, inc:luding the: Fode .and ERISA,and in a.ccordancewith the tenns of such plan. EachVerizonBenefit Plan intended to qualify under Section 401 of the Code (and each related trust intended to be exempt from federal income taXation under Sectiol150 1 of the Code) has received a fav. arable determination letter [rOln the Internal Revenue .. - - ',. Service (or an application for such a letter is pending or will be filed within the applicableremedialarnendment period). ....... ... ........ . Execution Copy Confidelltial.andProprietary of the VerizonBenefitPlansor by Law (without fegardloany waiversgfanted under Section 412 of the Code) to 3DY funds or trusts. established thereunder Or in connection therewith have b~en made by the due date thereof (including any valid extension), and ail contributions for any period ending on or beforelhe Closing Date which are not yet due. will be paid by the required due date. . No. accumulated funding deficiencies (whether or not waived) exist in any Verizon Benefit Plan subjectto Section 4120f the Code or Section 302 of ERISA. Neither Verizon nor any ERISA Affiliate thereof has provided, oris required to provide, security to any VerizonBenefit Plan under Section 401 (a)(29) of the Code. (iv) Except as specifically provided in the Employee Matters Agreement, no event. has occurred nor shall any event occur. as a result of the transaCtions . contemplated by this Agreement. which will result in the imposition upon Adelphiaor any Affiliates of Adelphiaof any material liability directly or indirectly attributable to or relating to the Verizon Benefit Plans or any other Employee.BenefitPlanmaintained or sponsored by, or contributed toby, Verizon oranyERISA Affiliate thereof. (v) No liabilityunderSubtitleC orD of Title NofERISAhas been or is expected to be incurred by Verizon with respect to any ongoing, frozen or terminated "single-employer plan". within the meaning of Section 4oo1(a)(15) of ERISA,currentlyor JormerlYIIlaintained by Verizon or an ERISA Affiliate thereof. No notice ofa "reportable event", within the meaning of Section 4043 of ERISA for which the 30-day reporting requirement has not been waived Or extended, other than pursuant to PBGCRegulationSection 4043.66; has been required tobefileclfor anyVerizon Benefit Planwithinthe12-month period ending on the date hereof or will be required to be.. filed in. connection with the transactions contemplated by this Agreement. NeitherVerizon nor any ERISA Affiliate thereof has engaged in a transaction described in Section 4069 of ERISA. . . . (b.) Except as .set forth on Schedule 5. 13b , there are no pending actions, '... clainis.or . lawsuits which have been asserted or instituted against. the V ~~~oIlBenefit . Plans;, the assets of any of the trusts under such plans or the plan sponsor or the plan administrator, or against any fiduciary of the Verizon Benefit.. Plans with respect to . the operation of such plans (other than .routine benefit claims), nor to..Verizon's Knowledge are there any facts which could form the basis for any such claim or lawsuit. ' . (c),E~ceptas setforthonScheduleS.13c, (i)none of the Employees are represented l,>y. a labor union or labor organization; (ii) Verizon. is not subject. and is not a party to any collective bargaining agreement covering any Employee; (iii) there are no labor strikes, slowdowns, work stoppages or lockoutscurrentl ypending or, to V erizon' s Knowledge, threatened against VerizonwithrespecttoanyEmploy~s; (iv) to Verizon's Knowledge, during the 12 months preceding the date of thisAgre~Illent, there have not been any Jabor union organizational campaigns by or directed at any Employees; (v) there is nounfa4'practice complaintpendingagiunst Verizon with respect tOL any Employees or, to Verizon' s Knowledge,threaten~d before the<N ational.. Labor Relations. Boardor.cmy otherGovemmentalEntity; . and (vi) there ..is. no grievance. regarding. unfair labor practices or collective bargaining pending against or involving Verizon with respect to any Employees. 5.14 Environmental Matters... The.operatIons conductedbyVerizon on itsleased.real properties related exclusively to theSystc:marecurrently. being conducted under aU environmental, health and safety permits, licenses and other authorizations required under aU applicable Environmental Laws to carry onthe Business as it is being conducted, except for such permits, licenses and other authorizations,. the Jailure of which to. obtain would not reasonably be expectedtobave a Material Adverse Effect. . All n,ecessary. permits, lic.enses and authorizations are in full Jorce and effect. The operations conducted byVerizon have been andcurrentIyare beingconduct~d in cOlnpliance with applicable Environmental Laws, except ~ would not have a Material Adverse Effect. To Verizon's Knowledge: (i) no written notice, notification,demand, request for information, citation, summons or order has been issued to Verizon with respect to any such properties, (ii) no written complaint has been filed against Vc:rizon,(iii) no material penalty has been assessed, (iv) no investigation or review.is pending or threatened by any Governmental Entity with respect to any alleged failure byVerizon to have any enviromnental, health or safety permit, license or other authorization required . under any applicable Environmental Lawin connection . with the operation of the System; and (v) no investigation or review is pending or threatened by any Governmental Entity with respect to. an alleged violation by Verizon of any applicable En,viromnentalLaw inconnectionwith the Business. . 5.15 Brokerage. Fees; Except for Goldnian Sachs & Co., whoseJee will be paid by V erizonpursuantto a~eparate agreement, no Person acting onbehalfof yerizon is entitled to any brokerage or finder's fee or commission in connectioriwith the transactions contemplated by this Agreement.. . 5.16, Free Service Liability: Except as set forth on ScheduleS.16 or as required byany franchise agreement relating to the Business; there is no free service liability to Customers existing with respect to the Business. Except with respect to deposits for. conveI1ers, encoders, decodersandrelatedequipment, and any other prepaid income item which is or will be reflected . inth~~djustIn~ntc.~ntemplatedbY Section. 4.2,yerizOllhas .110. obligation or liability for ... the refuIld of a II late rial amount of money to its Custoniers~ . ..., . . .... ~xecutionCopy Confidential and Proprietary 5..19 . Restoration. . Except as set forthon.Schedule S.19 or as would liot .have .aMateriaI Adverse Effect there is,.(i) no restoration,repaving~ repair or other work required to be made by Verizon to any street,sidewalk or abutting or adjacent area pursuant to the requirements of any Law relating to the installation, (:onstruction or operationof the Business, or (ii) no property of any Person that .has been damaged, destroyed, disturbed or removed in the process of construction or maintenance of the Business which has notbeen, or will not be, prior to Closing, repaired, restored or replaced, or, jf not repaired, restored or replaced, for which an adequate reserve has not been accrued byVeriZon prior to Closing. 5.20 Rie:htofFirstRefusaL Exceptas set forth on ScheduleS.20, no Person has any option, warrant or right of first refusal to purchase either the Business or any of the Acquired Assets, . . (a) The information as to the mileageoftrunk and feederplant of the System, the channel capacity of the System and the dwelling units passed by the System set forth on Schedule 5.211s alltrue and correct in all material respects. The. System, when loaded with the number of television channels (picture and sound) currently offered in the Businessperfonntothe standards required by the FCC Rules and Regulations. There are no less than 3,300. miles of energized cable plant. (b) Except as set forth in Schedule 5.21 or to the extent that any failure to perfoIm any of the actions or comply with any of the requirements set forth.belowwould not have a Material Adverse Effect: (i) Verizonhas complied with all notification and reporting provisions and all other provisions of the FCC Rules and Regulations applicable to the System; the System has been and is being operated incompliance with the Communications Act of 1934, as amended, including the amendmentseffected by the CableCoinmunicationsPolicyAct of 1984 (the "1984 Act"), the Cable , Television Consumer Protection and Competition. Act .of.l 9Q2.arid ..the Copyright Act of 1976, ..a$. . amended (the' "Copyright ..Act"),anclwith.aIIRulesand RegulationsoftheFCC and the U.S. Copyright Office. Without limiting the generality of the foregoing, all of the performance tests on the System described in Section 76.60 1. of the FCC Rules and Regulations have been made by Verizon; the.System currently meets the technical standards set forth in the FCC Rules and. Regulations, including the leakage limits containedinSection76.6Q5(a)(U); and . Vetizonhas delivered toAdelphia a copy of the most recent FCC Forms 320 filed with the FCC (Basic Signal Leakage PerforrnanceReport)by Verizon.Copiesof the most recenfsignalleakagetestsconducted on the Systeminaccordance with Section 76.611 of the FCC Rules and Regulations and copies of the most recent . "proof of performance" tests on the System have been delivered to Adelphiaby Verizon (the ':ProofofPerfonnance Tests"). Each ofthesignaUeakage tests and the.ProofofPerformanceTests (i) was conducted in accordance with the testing pr~edures set forth in Sections 76.601 and 76;609 of the. FCC Rules and Ex~cutio,,~opy Confide;('tiIll and Proprietary Regulations and (ii)evidencedthat the System meets or exceeds all of the techIlical standards set forth ill Section 76.605 of the FCC Rules and ReguJations. The System is . being operated in compliance. with the provisions of Sections 76.610 . through 76.619 of .the FCC .Rules and Regulations .(midband ..and superbandsignalcarriage); appropriate authorization from the FCC has been obtained for the use of all aeronautical frequencies in use in the System; the System is . presently. being operated in compliance with such . aeronautical authorization;Verizon has provided privacy notices to Customers of the System in accordance with the requirements of Section 631(a)(l) of the 1984 Act; and the System is incompliance with the requirements of. Sections 76.92 (Network Non-Duplication Protection) and 76.151 (Syndicated Program Exclusivity) of the FCC Rules and Regulations. . (ii) Thernonthlyrates charged by Verizon for each service provided by Verizon to Custo'mers are set forth on ScheduleS.21. To the extent required by applicable Law, such rates were calculated in good faith in accordance with the FCC Rules and Regulations as of the date of their respective calculations. ,(Hi) Verizon holds all material FCC licenses, permits and authorizations necessary to operate the System. in the manner. in . which they. are operated on the date hereof and such FCC licenses, permits or authoriZations. are listed on Schedule 5.21. Each of the licenses, pennits and authorizations li~ted on Schedule 5.21 is in full Jorce and effect, has been validly issued or assigned to Verizon, . accuratel y lists the current. param~ters . of the facility licensed and is not subjecttoany special conditions or limitations not specifically set forth therein, All licensed facilities operated by Verizon are being operated in accordance with the operating parameters of the relevantFCC license. (iv) All broadcast television signals carried on the System is being caniedin accordance with the requirements of the Communications Act of J 934, as .amended, .and FCC regulations promulgated thereunder. The stations that Verizon is. carrying pursuant tpFCC must-canyrules ~~de?tifieti.onSchedule $~.1J.V erizonhas.. not received any.. written complaint frornallY bro~dcaster of television signals regarding Verizon's channel positioning Or such broadcaster's carriage rights~ . (c)., Except to the extent thatthefailureto complyorperform anyof the acts set forth below would not have a Material Adverse Effect: (i) the System is in compliallce with respect to all notices,> filings and payments ofcopyrighffees rc:quiredby Section 111. ofthe. CopyiightAct and the United States Copyright Office regulations; . (ii). Verizon has calculated the copyright fees shown to be due . on all statementsofaccount require.d to be , filed with the FCC (as amended by any requiredplings andloranY.Qther co. IT.. ective. . ...s. .up.p.l. e.. m. en.ts. ) ...in acc. ordan. ce... w.... ith th. e. regu.. lat.i.ons of th. ,e.. .U..n. ite...d . Sta.t.e.s Copyright Office issued pursuant to the Copyright Act; and (iii)Verizonbas not received any written notices from the United States Copyright Office, or any other Person either c.. hallenging any copyright filingorpayrIlent,or the failure to. makeanyco.pyri.ghtfiling . -,' - . - -' ,c' _ . , . _ . , ,', . . - - -- - . . (d) . Ex:ceptta the extent that the failure ta camplyor perform any anhe acts set farth bel .ow wauldnat have a Material Adverse Effect: .(i) Verizan is operating the System in campliancewiththe Rules and Regulatians.of the FAA; (ii) without limiting the generality .of the foregaing,the existing towers aftheSystemareobstructianmarked and lighted in accardance with the Rules and Regulatians .of the FAA and FCC .or are exempt from such requirements; and (iii) all required authorizatians, inc1udingHazard to Air Navigation determinatians, far suchtawers have been issued by and pursuant ta the Rules and Regulations .of the FAA. Capiesof all FAA documents and correspondence relating to such towers have been made available .or deliveredtoAdelphia. Schedule ,5.21 lists all .of the existing tawers .of the System. (e) Except assetfarthooSchedule 5.21or to the extent thatthe failure to camply .or perf arm any .of the acts set farth belowwauld nat have a MaterialAdverse Effect: (i) there are na unfulfilled written pramises .or commitmentsta any Governmental Entity far capital impravements which Verizonhas made in cannection with the System; (ii) there are na written obligations. taCustamers which have arisen .outside of the .ordinary course aperatianofthe System, except: (A) with respect to depasits made by Customers; and(B} the .obligation t.o supply services t.o Custamers in the ordinaryc.o':lrse .of business, pursuant ta any franchises relating t.o the System; and (iii) to V eriz.on' s Knawledge, no formal writtencamplaints have been made by Customerstrat are not being addressed in g.oad faith. . . . (a) . Veriz.on represents andackn.owledges thatit (i) is receiving the Adelphia Camman Shares hereunder for investmentpurpasesanly, andnat with aview toarfor resale in cannectian with any distribution, except in accardancewith an effective registration statement .or an exemptian from the Securities Act and (ii) understands that until the effectiveness .of the Registration Statement on .or pri.ortatheClosing Date, the . A(jelphia. Camman Shares being acquired bereunder wil I be' char~cteri7;edas "restricted .securitiesi'.under the.....~ecurities Act inasmuch as. they .are..beingacquirediri .a.transac~ian nat invalvingapublic .offering. ........ ..Execution Copy Confid.~ntiahmdProprjetary theCqmmission on its EDGAR System, allqfwhich are available to (and hereby deemed to be delivered to and received by) Verizonoverthe Internet at the Commission's web site athttp://www.sec.gov,and Oi) has had the opportunity to make detailed inquiry concemingAdelphia,itsbusiness,its officers and its personnel, and has had answered by the officers of Adelphia to its own satisfaction all inquiries which it has made. .. (e) .. Verizon acknowledges that the certificates. for the Adelphia Common Shares sold hereundershall.bear the following legend: THE SECURITIES REPRESENTED HEREBY HAVE NOT BEEN REGISTERED UNDER THE SECURITIES ACT OF 1933, AS AMENDED, OR ANY STATE SECURITIES LAW,AND MAYNOT BE OFFERED, SOLD OR OTHERWISE TRANSFERRED,PLEDGED OR HYPOTHECATED UNLESS AND, UNTIL REGISTERED UNDER SAID ACT OR, IN THE OPINION OF COUNSEL IN FORM AND SUBSTANCE SATISFACTORY TO THE ISSUER OF THESE SECURITIES,SUCH ... OFFER, SALE, TRANSFER, PLEDGEOR HYPOTHECATION DOES NOT VIoLATE THE PROVISIONS THEREOF. 5.23 . Disclaimer. EXCEPT. AS SPECIFICALLY SET FORTH . IN TUIS AGREEMENT OR IN THE. ANCILLARY AGREEMENTS, VERIZON DOES. NOT MAKEANYRE~RESENTATION ORWARRi\N'fY AS TOANYMAl'TER,EXPRESS OR . IMPLIED, INCLUDING ANY EXPRESS OR IMPLIEDW ARRANTXOF MERCHANTABILITY>ORFITNESSFORAPARTJCULARPURPOSE,W ARRANTY AGAINST INFRINGEMENTORANYOTHERWARRANTYAS TO THE CONDITION OR OPERATION OF ANY Ol'THEACQUIREDASSETS~ .6.1 . Organization. Standine: and Power. Adelphia is a corporation, is duly organized, validly existing and in good standing under the laws of the State. of Delaware, and has the' requisitepowerandauthorityto conduct its business as currently conducted and as contemplated by this Agreement,andlo own, lease, operate or hold the Acquired Assets. Adelphia is duly qualified of registered to do business, andis in>goodstancling, inthe StateofFlorida. . .. . 6.2 .. ..Authority.Adelphia has all power and authoritynecessarytoexecutelhis Agreement and the Ancillai}' Agreements to which it isor wiUbea party (the "Adelphia Ancillary Agreements") and to consummate the transactions contemplated thereby and by this Agreement The execution and delivery of this Agreement and the AdelphiaAncillary Agreements, and ... the consummation .... of the transactions contemplated hereby and thereby (including, but not limited to, the issuance of AdelphiaCoIllIIlonShares toVerizon,if applicable ),have ..1>eendulyauthorized by all necessary ..action.. of Adelphia. ...This. Agreement constitutes and, upon execution, each of the Adelphia Ancillary Agreements constitute orwill constitute. valid. and binding obligations of Adelphia,.enforceableagainstAdelphia in accordance with their respective terms, such enforcement subjectto bankruptcy, insolvency, reorganization, moratorium, or similar laws ofgeIieralapplicationaffectingcreditors 'rights and the application of general. principles of equity. 6.3 No Breach or Conflict. The execution, delivery and performance of this .. Agreement and the Adelphia Ancillary Agreements and consummation. of the transactions contemplated thereby and by this Agreement (including, but not limited to, the issuance of Adelphia Common Shares toVerizon, if applicable) will not (a) cause Adelphia to breach any Law or Court Order, (b) conflict with or result in a viOlation of the Certificate of Incorporation or Bylaws. of Adelphia,. or (c) conflict with or result ina breach of any of theterms,conditions or provisions of any Contract or Permit to which Adelphia is a party or by which it may be bound, or constitute a default thereunder or result in the creation of any Lien, whichbreach,conflict, default or creation would materially affect Adelphia's ability to perform its obligations hereunder or under the AdelphiaAncillary Agreements, 6.4 Third-PartvConsents. Each Person whose consent to the execution, delivery or performanceofthisAgreement and the AdelphiaAncillary Agreements by Adelphia is legally or contractually required bas .been obtained. 6.5 ..... Claims. Litie:ation and Disputes. Except for actions, proceedings or investigations affecting the cable television industry. in general, there is .no claim or. Iitigation. or investigative proceeding. pending or, to the knowledge of Adelphia, threatened against Adelphia thatwould materially affect. Adelphia's ability to perform its obligations hereunder. or under. the Adelphia Ancillary Agreements. . .." ,. . 6.6 Brokera.ge Fees. No Person or other entity acting on behalf of Adelphia is entitled to any brokerage or finder's fee or commission in connection with the transactions contemplated by this Agreement or the Adelphia Ancillary Agreements~ .,- - .'.'.-, . ....... ....... .. 6. ;....7... ...... .. .0.. .. '11. al.i.fi..l.c. at. io.n. . A. ..d. e.lp. .h...l....a. has.. .....n. oreas... ..on.. t. obeli.eve .tha.. t. .i..tw. .... .0. u... I.d.....n.........o.....t.....'........q...u.....al....'......i. f. y... 3.5... 8.. .... traI1sfere~'of the Franchises.. or. any.. other licenses,.Pennits and .authorizatic>Ds.. to be.'assignedto AdeJphiapursuanttothis Agreement and to otherwise continue to operate the Business, Should . .' . . Adelphia become aware of any facts that would cause it not. to so qualify or be able to operate the System as currently operated, it will promptly notify Verizon in writing. thereofand. use its best efforts to prevent any such cllsqualification or failure. .6.8 . Adelphia's Investigation. Adelphia representsthatit isasophisticated entity that was advised by knowledgeable counsel and financial advisors and hereby acknowledges that it has conducted8J}investigation of the physical plants ofthe System, which investigation included evaluation of the.conditionand performance of such. physical plants. Notwithstanding anything in this Agreement to the contrary; .Adelphia.acknowledges. that itis accepting>theAcquired Assets in their. present . condition and locations and.with, their... present operating capabilities; Adelphia ackno\\,ledgesthat Verizon makes no warranty,~xpres~ or implied, as to the condition , , of. the Acquired Assets except as expressly set forth in this.. Agreement. Adelphiahasnot relied upon, and Verizonshallnot be liable for or bound in any manner by, any express or implied verbal . or written infonnation, warranties,guarantees, promises, statements, inducements, representations or opinions pertaining to theSystemor the Acquired Assets, except as may be contained in this Agreement and certificates delivered hereunder. To> the extent any member of Adelphia's management has actual knowledge of any facts relating to any items covered by the representations and warranties of Verizonin Article V (by reason of Adelphia's due diligence review of Verizon or otherwise), such knowledge shall be deemed to modify any applicable representation and warranty of Verizon, including any Schedulesthat relate. thereto. 6.9 Adelphiaarid the Adelphia Common Shares. lithe Payment consists of Adelphia Common Shares: (a) The Exchange Act Reports, when they were or are filed with the Commission, conformed or will confonn ina11 material respects with the applicable requirements. of the Exchange Act and the applicable nIles and regulations .of the Commission thereunder. The Exchange Act Reports did not and will Dot,as of their respective dates,contain an untrue statement of a material fact or omit to state a material fact necessary in .orderto make the statements therein, in the light of the circumstances under which they were made, not misleading, Moreover, the copsolidated financial statements ofAdelphia and its subsidiaries included. ill the Exchange ActReponscomply as to form. in. all material respects with applicable accounting. requirements and with the published rules and regulations of the Commission with respect thereto; have. been prepared in accordance withGAAP applied on a consistent basis thro~ghoutthe periods involved and fairly present in all material respects the consolidated financial position. of Adelphia and its subsidiaries as at the dates thereof and the consolidated results of their operations and cash flows for the.periods then ended. (b) Since the date of the latest audited financial statements included in the Exchange Act Reports, (i) Adelphia and its subsidiaries have conducted their operations only in the ordinary course of business consistent with pastpractice.and(ii) neither Adelphia porany .of its subsidiaries has s\lstainedany(n?rdoeSJ\~elphi~kI1o\Vofany fac. ts. or circumstances that could likely give. rise to. any) materiallQSs orjnt~rfere[}cewith .... its business, .whetherornot. covered. by . insurance,.orCromahylahordisptiteOrcourf or governmental action,order or decree, otherwise than as set forth the Exchange Act Reports. Additionally, there has been no material adverse change,oranydevelopment involving a prospective material adverse change, in or affecting the general affairs, management, financial position, stockholders 'equity or results. of operations of Adelphia and its ~ubsidiaries,except as setforthintheExchangeActR.eports. . . , , . . ., - , (c) .. The Adelphia CommonShares have beellduly and validly authorized and reserved for issuance and, when issued to Verizon inaccordaIlce with this Agreement, will bevalidly.issued,.fully paid and non;-assessable, free. and. clearo! all Liens, and will confonntothe description of the Adelphia COmmon Shares ,contained in. theExchange Act Reports. Assuming the accuracy of Verizon's represent~tionsinSectionS.22,none . '," "',,', ',' ofth~ transactions 90ntempla.tedbythis Agreement will violate or resultinaviolation of the Exchange Act or the Securities Actor blue sky laws. (d) . Adelphiahas the authorized . capitalization set forth in.. the Exchange . Act Reports and all issued shares of capital stock of Adelphia have been duly and validly authorized and issued, and are fully paid and non-assessable. No vote or consent of Adelphia's stockholders or noteholdersis required to approve this..Agreement or any of the Adelphia Ancillary Agreements or JorAdelphia to consummate the transactions and perfonn its obligations contemplated hereby and thereby~ Executi(Jncopy Conftde1)titl' andPr?prietary Except and to the extent Adelphia may otherwise pennit in writing,Verizon covenants and agrees as follows: Access. Betwec;:n the date of this Agreement and the Closing, Verizon shall give to Adelphia, its officers,agehts, employees,counsel,. accountants, engineers . and other representatives, reasonable access to the premises and books and records relating to the System and, to the extent permiUedby Law, cause Verizon's employees to furnish to Adelphia such information related to.the System.asAdelphia.shall from. time to time reasonably request for the purposes of prepaI"ing for the transition of the System from V erizonto Adelphia;provided, h.owever, that any such investigation shall be conducted.. (a) dur..ing normal. bus.ine. SShOU.fS. and (b) in such a . manner as not to. unreasonably interfere . with the. operation. of the System .by Verizon. Notwithstanding the foregoing, (i) no environmental sampling or other testing maybe perfonned withoutVerizon'spriorwritten consent, which consent may be given or withheld inVerizon's sole discretion, and (ii) Adelphia will not contact any employee, customer or supplier of Verizon with respect to this Agreement without the prior written consent of Verizon~ Adelphia acknowledges that any information made available to Adelphia pursuant to this Section 7.1 is subject to the terms of the Non-Disclosure Agreement aJ1d Section 8.4. . - , - . - . , , ' .. . - ,- ." .'...... .......... ..................'.. ....... .. ... ......... .'. .......... ...... . .............. ... '......-" --.. ....... ........ ....... ..... . .....":............. .... ..'..... ........'.. ,\.7-2 i.. ..Con~uct.ofBusiness...PendingClosing..Exc:eptasc()nteIIlpla.te~pI) .$cltedule7.2, until the Closing,Verizon shall continue to operate the System substantially in the manner as heretofore conducted. Verizon shall use commercially reasonable efforts to preserve the existing business relationships with its Customers, suppliers, GovemmentalE;ntities, employees and others having businessrelatioris with Verizon in connection with the System. Without limiting the scope of the foregoing, Verizon shall: Execution COpy Con.fid~ntilll and ProPrietary (t) Not enter into any agreemenroragreements for the sale of a material amount of any of the Acquired Assets, except for sales of Equipment provided that, unless such . item of Equipment . is no Iongernecessary for the. operation of the. System, any item of Equipment sold shall be replaced with. an item. of Equipment of like value and quality; (g) ... Not increase. or decrease any of its Customerrates, conduct any sales, marketing, amnesty or similar programs,. unless consistent with past practices; provided, however, that this AgreemenrshaII not preclude Verizonfrom (i) seeking usual and ordinary rate increases, or (ii)decreasing rates in accordance with applicable Laws orin connection with marketing programs conducted consistently with past practice; (i) . Not, without prior consent of Adelphia,grllIltany raises to Employees, except in the ordinary course of business and iilaccordancewithpast practices and provided that no across-the-board raises shall exceed the percentage increase for any other Verizon Communications Inc~ business unit, or amend any existing or enter into any new collective bargaining agreements with Employees, provided that Verizon and its Affiliates may, with prior notice to Adelphia and an opportunityby Adelphia to provide input toVerizon,enter into new collective bargaining agreements or amend existing collective bargaining agreements with Employees to the extent. the same succeed any c()Uective bClI"gainingagreementthat expires on or prior to the Closing; any material respedany Material Acquired 7.3 HSR Act. Verizon agrees to make any appropriate filings of a Notification and Report Formpursuantto the HSR Act with respect to the transactions contemplated hereby. Verizon agrees to s~pply promptly any additional information and documentary material that may be reasonably requested pursuant to the HSR Act or otherwise and will comply promptly with any reasonablerequestsbyany Governmental Entity for additional information concerning the transactions contemplated hereby. Verizon agrees to use commercially reasonable efforts to cooperate and oppose any preliminary injunction sought by any Governmental Entity preventing the consummationof the transactions contemplated hereby. Verizonagrees that it will make all filings required by this Section 7.3 on Or before the 70th day following the Franchise Filing Date; provided, however, that if such dayis a holiday or non-business day,Verizonwillmake such filings on the first business day following such date. Verizon agrees not tomake anyfilings pUrsuant to this Section 7.3 prior tothe 70th day following the Franchise Filing Date without the written consent of Adelphia, andVerizonagrees to coordinate, and cooperate, in good faith with Adelphia in relation to Adelphia's obligations contained in Section 8.1. (a) Verizonshall give all notices to Governmental Entities and any other Person required to be given by itunder the Material Acquired Contracts or otherwise in connection with the transactions contemplated hereby; provided, however, that yerizon shall not give any . notices. pursuant to . this. Section ...7.4 prior to the Franchise Filing Date. In order to facilitate the orderly. assignment and transfer oral1 rights, privileges, , Franchises and Acquired Contracts necessary to own and operate the System, and to facilitate the securing of all Material Consents by franchising authorities or any other GovemmentalEntity necessary for the Closing of the System, Veriion shall proceed following the execution of this Agreement, to prepare and (after the Franchise Filing Date) tofil~and prosecute each request and application therefor together with such information ~lsmaybe necessary and appropriate to · effect sUch approvals. N9twitbstanding theJoregoing,Verizonshallfileall necessary Form 394s with appropriate franchising authorities no earlier than the Franchise Filing Date, but within 10. days after the Franchise. Filing Date, provided. that Adelphiahas.. provided all necessaryinformation, completed its portion of such forms and has delivered them to Verizonas required by Section 8.2; ... , (b) In obtaining Material Consents, (i) Verizonmay agreetoconunercially reasonablenon~materialchangestothe Acquired Contracts, and (ii)wlth the consent of Adelphia (which shall not be unreasonably withheld), Verizonmayagree to other commercially reasonable changes to the Acquired Contracts. N9thing herein shall. require the expenditure or payment .of any monies (other than inrespectofnormaland usual filing fees ) 'or the giving of any other. consideration by Verizon in order to obtain any of such consents. . . .......ExeclltiqnCopy COllfuJential.andProf'rietary . .. . (c). Additionally, V erizonshallusegood faitheffortstoiriclude a provisiohin eacht~ird-party consent. permitting.. Adelphia to . assign the applicable agreement to an AffiliateofAdelphiaat any time after the applicable Closing without further consent from such third-party. If a third party will not agree to such a provision, then Verizon shall so notify Adelphia,. and Adelphia may discuss the inclusion of the provision with such third party. In such case, Verizon shall have no further obligation to seek the inclusion of such a provision in the applicable consent. 7.5 Further Assurances. Subject to the terms and conditions of this Agreement, Verizon will use all reasonable efforts to take, or cause to be taken, all actions, and to do, or cause to be done, all things necessary, proper or advisable under applicable Law to consummate and make effectivethe.transactions contemplated by.this Agreement,. the Ancillary Agreements and the other documents and instrurnentstobedelivered pursuant hereto. 7.6 Confidentiality. Verizon acknowledges Adelphia's representations that.Adelphia would be irreparably damaged if Proprietary Business Information weredisclosed to or utilized by or on behalf of any Person not aparty to this Agreement { except. andt(). the extent expressly pennitted pursuanno this Agreement). Verizoncovenants and agrees that fora period of two years after the dateofthisAgreement, it will not directly or indirectly, except in connection with the transactions contemplated hereby or to the extent required by Law orCourt Order (provided prior timely notice has been provided to Adelphia to permit Adelphiato limitsuchdisclosure or to seek appropriate protective orders) divulge, or permit any of its agents or employees to divulge, Proprietary Business Infonnation. The obligations contained in this Section 7.6 are in addition to and independent of the obligations contained in the Non-Disclosure Agreernent 7.7 Schedule Updates. No<laterthan five business days prior to the anticipated Closing Date (but noearlierthan ten days prior to the anticipated Closing Date),Verizon shall deliver to Adelphia updated Schedules to this Agreement to reflect. changes occurring following the date of this Agreement, which updated . Schedules shall be deemed 'to modify the representations and warranties of Verizon set forth in this Agreement unless such changes would have a Material Adverse Effect, other than material adverseeffectsrelatingtoor resulting from. <.a)economiccQnditionsapplicable to jndustry~wide occurrences, or (b) .theexecutio.n.... of... thi.s Agreerne~totthe .itran~actions....... contemplate4.. "hereby. ......an<t. thar'Yeie.,...~otaihreach.of. ..a representationol warranty contained in this Agreement on the date hereof. bonds, letters of credit, indemnity. agreements and similar items necessary inconnec.tionwitb the AcquiredContrllcts, if any; provided, however, that all such actions contemplated by this Section 7.9 shall be at Adelphi<.l'S expense> and. Verizon shall not be required to pay any compensation or other consideration pursuant to this Section 7.9,. .. 7.10 Non-Competition. Verizon and its Affiliates will not fora period of one year following the Closing. Date, without the express written consent of Adelphia in tbegeographical areas listed on Annex I hereto engage or participate in a direct marketing or direct mail advertising campaign directed specifically arid exclusively atsuch geographical areas relating to a multi-channel, subscription, video broadcast television system business which. specifically requests or recommends to customers of Adelphia to cancel any broadcast cable television . service that they may receive from Adelpbia. Nothing in this Section 7.10 shall be deemed to limit. .the right. of Verizon or any .of its Affiliates . to . enter into a transaction involving a multi- , channel, subscription, video broadcast television business or any other cable, wireless or satellite television.. business outside of. the. geographical areas listed on Annex I hereto or within such geographical areas except as specifically provided herein. For greater certainty,-nothing in this Section 7.10 shall prohibit Verizon or. any of its Affiliates from (i) investing in the securities of any enterprise, entering into any joint venture, partnership or strategic alliance, or from acquiring, or being acquired by, all or any portion of any Person who provides cable television; video OJ:' similar services and/or products as long as such Person 's revenues froIIfsuchbusinessas conducted in the applicable geographical areas listed on Annex I hereto are less than 10%.ofthe total annual revenues of such Person, or (ii) participating in. or conducting any regional,. state or national marketing or advertising campaign of any nature not specifically directed at the applicable geographical locations subject to this Section 7.10. Except and to the extent Verizonmay otherwise permit in writing, Adelphia covenants and agrees as follows: '. ..8.1 HSR Act Adelphia agrees to make any appropriate filiIlgs: ofa~otifi<:ationand ReportFQrm..pursuantto ..the.HSR Act with.. respect to .the.. transac;ti9nsc()nt9JllPl~tedhereby........ Adelphiaagrees to. supply. prOlnptly any additional infonnationanddocumentarymaterial that may be reasonably requested pursuant to the HSR Act or otherwise and will comply promptly with any reasonable requests by any Governmental Entity for additional infonnationconceming the transactions contemplated hereby. Adelphia agrees to use commercially reasonable efforts to cooperate and oppose any preliminary injunction sought by any Governmental Eritity preventing the consummation of the transactions contemplated hereby. Adelphia agrees that it will make all ' filings required by this Section 8.1 on or before the 70th day following the Franchise Filing Date; provided, however,thatif such day is aholiday ornon-businessday,Adelphi~willmake such filings on the firs~ business day following such date. Adelphia agreesnottomakeany . filings pursuant to this Section 8.1 prior to the 70th day followingJheFranchise filing Date without the. written consent of Verizon and Adelphia agrees to coordinate, and cooperate~ iogood faith with Verizon in relation to Verizon's obligations contained in Section. 7.3,... . ... 8.2 Third-Partv Consents. Adelphia shall give all notices .to GovemmentalEIltities and any other Person required to be givenbyitinconnection with the transactions contemplated hereby; provided, however,thatAdelphia shall not give any notices pursuant to this Section 8.2 prior to the Franchise Filing Date. In order to facilitate the orderly assignmentandtransferof all rights, privileges, Franchises. and Acquired Contracts, and to facilitate the. securing of all Material Consents by franchising authoritiesoranyother third party, Adelphia shall cooIJerate in good faith withVerizon, shall provide reasonable assistance to Verizon in a timely manner to obtain such consents and shall promptly provideVerizon with such information and>complete such application forms as may reasonably be requested by Verizon. Without limiting the forego.ing, Adelphia will provide Verizon with all necessary information, and complete and deliver their portions. of such. forms within 70 days following. the. date of this Agreement, and otherwise cooperate..with..Verizon,....to permitVerizon to<file all Form 394s . with'. appropriate franchising authorities, for which COnsent to transfer a Franchise is required. Adelphia shall attend such meetings as Verizon may reasonably request in connection with obtaining third-party consents, and Adelphia shaUprovide such financial information as third parties may reasonably request. in. connectionwith. the review of transfer requests. Adelphia acknowledges that it may need to enter into direct agreements with franchising authorities, other Governmental Entities or other third parties. 8.3. Dischar2e. of Assumed Liabilities.. Adelphia shall pay, perfonn arid discharge the . Assumed Liabilities as they become due, including the discharge and performance when due of each and every obligation ofVerizon to be satisfied or performed on or after the Closing pate under the Acquired Contracts.. . .. . 8.4 . Confidentiality. Adelphia acknowledgesVerizon's representationsthatVerizon would be irreparably damaged if confidential information concerning the business and affairs of Verizon anditsAffiliateswereclisclosed to or utilized by or on behalf of any Person not a party totms Agreement (except. and to the extent expressly permitted pursuant to this Agreement); Adelphia covenants and agrees that itwill not, directly or indirectIy,ex.cept inconnectionwith the. tnmsactions contemplated hereby or totheextentrequired by Law or Court Order (provided prior timely notice bas been provided to Verizon to permitVerizontolimitsufhdisclo~~reqr to see.k... a.1'. p......r.......o......p.n.. .ate....p....r.o. t..ecti.v. e... ..o.....r. ders.),. II1ak. e.....use...o...f. ordiw....l.g. ..e. '....'...or. p...e.'.rm1..'..... ..'t...<.an.. y. L.o..........,.f.......:.i.,t...s..".....a. g.e...n... t.5... ..0. r. ... . employees to make use of or . divulge,nonpublic information concerning the business, . financial. or other affairs of Verizonor any of its Affiliates... The obligations contained in this Section 8.4 are in addition to and independent of the obligations contained in the Non-Disclosure Agreement,> Notwithstanding the foregoing,neither this Section .8.4 nor the Non-Disclosure Agreement shall.restrict Adelphia's use of any confidential information.contained inlhe Acquired Assetsafterthe Closing~ 8.5 .. ...Access..... Verizon shall, fora period of seven years. from the Closing Date,.have accessto, and the right to copy, at its expense, for bona fide business purposes and during usual business. hours upon reasonable prior notice to Adelphia,aIl books and records relating to the o.pe.....ra.t.i.o.n.. o.fthe.. ..Syste. ffi. '....A..d.elphia .shall.re. tain. an. d pre. serv... ..eall.suc.b.b.o.ok....s.. and. rec.o...r..d.. .s.~. o..rs.uch seven year period. Adelphia may discard or. destroy anysuch booksorrecords,provide~ that ... ... .E~eclltion(::opy ConfidentialllndProprietary Adelphia shallsonotifyVerizonandallowVerizon, within 30 days of such. notification,t(). elect to take. possession ofsuchbooksand records... ... . ' .. 8.6.. B()nds..tettersofCredit.Etc....Adelphiashall take all necessary steps,.and execute and deliver all necessary documents, to ensure that on the Closing Date Adelphia has in place the bonds, letters of credit, indemnity agreements and similar items necessary in connection with the Acquired Contracts, if any. 8.7 .. Further Assurances. Subject to the terms and. conditions of this Agreement, Adelphia willuseallreasonable efforts to take, or cause to be taken, all actions, and to do, or cause to be done, aU things necessary, proper or advisable under applicable Laws to consummate and make effective the transactions contemplated by this Agreement, the Ancillary Agreements and the otherdQcumentsandinstrumentsto b<: delivered pursuant hereto. . 8.8 Intellectual Propeitv.Subject to the rights and licenses expressly granted to Adelphiapursuanuo the Intellectual Property Agreement, Adelphia shall promptlyretum or destroy and shall. notpuseanyIntellectual Property, including any Third PartylIltellectual Property, Software or Excluded Marks, of which Adelphia acquires possession. in connection with the Acquired Assets. and which is not the subject of an Acquired Contract that has been rightfully. transferred to Adelphia or for which Adelphia has not separately and directly acquired rights from the Person who is the owner of such Third PartylntellectualProperty. 8.9 .. . Vehicles. .... Adelphiaagrees to use. commerciall y reasonable efforts to filepromptl y theappropriatevehic1e titIeapplicationsand registrations to change the name of thetitled owner on each . vehicle. title certificate and change . the. motor vehicle registration (with respect to license plateinfonnation) on' each vehicle being transferred to Adelphia from Verizon pursuant to this Agreement. Adelphia agrees. that it. shall remove and destroy Verizon 's existing license plates. from all vehicles received uponJheearlier of receipt of new license plates Or 90 days following theClosing. . . 8.1 0 Gulf Power . Case. If. as a result of the lawsuit styled Federal Communications Commission and the United States of America.et al. v.Gulf PowerCompanv.etaLAdelphia recejve~.asettlemel1t'ireimQursemeDtor other similar. payment.....withrespecttothe System relating t(lanypenod of time prior to the applicable Closing, ihenAdelphiashallpromptly transfer all such amounts to Verizon.. ,.. .... (bY. IfAdelphiachooses to issue Adelphia Comrnon$hares to Verizonfor any or all of these payment obligations, the number of shares that shall be issued to Verizon for any particular payment willbe deterinined by dividing the applicable payment amount by the applicable Deficit Payment Value (as defined below). For the purposes of this Section 8.11, the term "Deficit Payment Value" shall mean the closing price of an Adelphia Common Share, as quoted on the NASDAQ National Market, as reported in the Wall Street Journal (NY morning edition), for the full trading day that is immediately priorto the applicable payment date, (c) Exceptasprovideclby the next sentence, the paymeIltobligations required by this Section .8.11 . are independent of all other obligations of the Parties contained in this Agreement and are not subject to set-off for any amounts Verizon may owe Adelphia pursuant to or as a result of this Agreement. Notwithstanding the preceding sentence, if at any time the closing conditions set forth in Section 10.5(bJ of thisAgreement cannot be satisfied, regardless of whether the other conditions set forth in ArtiCle X could be satisfied at such time, the payment obligations required by this Section shall continue to accrue, but Adelphia'sobligationto rnakepayments of such accrued amounts shallbe suspended until the conditions in Section IO.5(b) can either be satisfied or are waived by Adelphia. In theeyent Adelphia'spaymentobligationsare . no longer suspended, as contemplated by the previous sentence, AdeIphia shall pay (within five business days after thereinstatementofthep~yment obligation) all... payments thatw~re due and payable; but not paid, during the period Adelphia's' payment obligation was suspended. If this Agreement isterminatedpursuanuo Section 11.2 and, at such time, Adelphia is not in material breach oftrus Agreement and Adelphia'sobligation tornakeanypayments required by this Section8.II are suspended, then Adelphia's obligation to inakeany payments of accrued amounts shall also be tenninated. (d) All payments made pursuant tothisSection8.11arei1on~refundableunder all c..ircumst..an.... c.e.s., ..In..the eve..nt...t...h. ..e.C...., lo..s.i.n...g.. Da....t.....e. ,o.cd..a.....te.. .....o.n..........w....h.i.,.Fh...... t....h.....l....S....,:.A....g..f...ee...m.e.n. ....tis telminatecl,is . ()n, Ii date. other than.. the date a . payment isdueinaccgrdaIlc~~i!h$ection 8..11(D.).(...ii)..,.. AdeIP...h.....l.a :will p. ay.... v.e. riZo.......n...(iIieith. er cas. h.....'.O.. f. ...A~....l.. h, i.3..........'.o.......rnm........:m..... on:.. :S..har...es... as provided above) a prorated amount with a value equal t~ltipliedbythe number of days. from the due date of the previous. payment. to. andincluding. the. Closing Date or date of tennination, as applicable, AddItionally, in the ~vent heClo iog occurs. .. and Adelphia makes. aggregate payments to Verizon in excess 0 uanno thisSe~tion8.11, the Payment shall.bedecreasedbyanarnountequaltote...l ference between e gregateamount receivedbyVerizon pursvanttothisSection 8.11 minus 8.12.. . ReEistrationofAdelphia Common. Shares.. Adelphiasliall.within 40 days after the Franchise FilingDate,prepareaIldfile withtheU,s. Securities and ~xchangeCommissiona registration statementon an appropriate form under the Securities Act (the "Registration Statement") covering the sale by Verizon or its designated Affiliate of all of the Adelphia Common Shares received by Verizon in connection with any of the trans~ctionscontemplated by this Agreement. For purposes of this Section 8.12 the term "Adelphia Common Shares" shall include any securities issuable,. issued or distributed in respect of any of the Adelphia COmmon Shares, by way of stock dividend orstocksplit.orin connection with a combination of shares, recapitalization. reorganization.. merger, consolidation or . otherwise.. . Adelphiaagrees .,.to promptly respond to any request~ or comments made, and supply any infonnation that may be requested. by the U.S. Securities and Exchange Commission in connection its review or the Registration Statement. After the U.S. Securities and Exchange Commission has provided Adelphia \Vith notice that it will not review or has completed its review of the Registration Statement. Adelphia shalIpromptly (but in no event prior to the Closing and subject to the receipt of necessary information from Verizon as described below), cause (i) .the Registration Statement to become effective and to remain continuously effective in order to pennit the prospectus included therein to be lawfully delivered to purchasers of the Adelp~iaCommon Shares through the first anniversary of the Closing Date, and (ii) the shares covered by the Registration Statement to be included for quotation on the NASDAQ National Market System. Adelphiashall (i) fUrnish Verizon with copies of prospectuses inconformity with the requirements of the Securities Act,al1dsuch other documents as Yerizonshall reasonably request asrequir~d underthe.SecuriliesActto keep the Registration Statement effective.inaccordance with this Section 8.12, and (ii) 'prepare and file such amendments andsupplernents to the Registration Statement as required. by. Law and as, may benecessaryJo. keep the Registration Statement effective through the first anniversary of the Closing Date. Adelphia shall bear all expenses in connection with the procedures described in this Section 8.12 in connection with the registration of the Adelphia Common Shares pursuant to the Registration Statement, Other than fees and expenses, if any. of counsel or Other advisers toVerizon or any other selling shareholder. expenses (including counsel fees) of any underwriter, and any underwriting discount or commission. or broker's commission payable in connection with any sale of the Adelphia Common Shares, which shall be borne by V erizonor the relevant selling shareholder. . If Adelp~ia has. delivered preliminaryorfinal prospectuses.. to Verizon~d .afterhavingdone so thepr9~I>e~t~s ..mustbeaI1l~Ildedor suppleInented (whether throughin~()rpor~tilJnJ)yr~ference.. or. otherwise) to comply with the requirements of the Securities Act,. Adelphias}iallpromptly notify. V~rizon and promptly (but in all events within 20 daysafterprovidingnoticelpr(}vide Yerizon with revised. prospectuses or make a filing incorporating such <requirednlaterial . in the Registration Statement and, if requested in order to comply with applicable securities Laws, Verizon shallimmediatelyceasemaking offers and sales in accordance with Law. If Adelphia is required to amend or supplement such preliminaryorfinal prospectuses; upon receipt of the am.ende..d o. r . suP. pl. em. e.ot.... p. rospectu..ses, ,Y... e.riz. Qn's.hall u.s.e. .....the. f. ev..i.se.d.o...f.. su.'.p..plem.ented prospectus~s. Each holder QfAdelphia C()mmon Shares included. in anyRegistrationStatement filed pursuant to this Section 8.12 shall furnish to 'Adelphiasucbinformationregarding such holder and . the distribution proposed by such holder. as Adelphiamay reasonably request in writing and . as shall be required in comiection with any re~istration, qualification or compliance under the Securities Act. .. . The obligation of Verizon tocoilsummate the Closing shall be subject to the fulfillment, prior to or at the Closing, of each of the following conditions unless waived by Verizon in writing: 9.1 . .. Adelphia's Reoresentationsand Warranties. Each representation and warranty made by Adelphia in Article VI hereto that is modified by materiality shall be true and correct in all. respects, and those. that are not so modified shall be true and correct in all material respects on and as of the Closing Date with the same effect as though each such representationar warranty . had been made or given an and as of the Closing Date, other than representations and warranties made asoCa specific date, which shall be true and correct as of such specific date. 9.2 . Adelphia's Covenants. Adelphia shall have performed and complied in all material respects with all of the covenants set forth herein which are to be perfonnedor complied with by it before or as of the Closing Date. 9.4.. ... Adelphia's Deliveries. Adelphiashall have executed and delivered to Vetizon the AdelphiaAncillaryAgreementsand other documents and items referred to in Article XIII . hereof. No action, suitor proceeding (which, in the case of an action suit or proceeding brought .... by a. non,;,Governmental Entity, has a. reasonable likelihood of success)ispending before any Governmental Entity to enjoin, restrain, prohibit orobtain substantial~arnages in respect of the transfer ()f the S ystemascont~mpl~tedby this Agreement or t~e Ancillary Agreements,orwhich would be reasonably likelYJo. prey. ent.. 6iima1ceiUegal thec()l1sumrmition ~fanyttartsactionscontetnplatedbythisAg'feemeIltor ., the Ancillary Agreements. beenreceived~ this condition shall nevertheless be Julfilled .andshall not delay the Closing if such regulatory Governmental Entity withdraws its notice,terminates the proceeding or action subject to the notice, or fails. to open a fonnal investigation or commence a proceeding or action Viithin areasonable time (which in no event shall be.later than 60 days after receipt of the initial notice). (c) Verizonshalloot have received written notification from a regulatory GovemmentalEntity indicating that such regulatory Governmental Entity is threatening to COmrIlence a proceeding or action in relation to the sale of the System ascootemplated by this Agreement; provided, however, that if a written notification has been received, this . condition shall nevertheless be . fulfilled .. and shall not delay the Closing if such regulatory Governmental Entity withdraws its notice, tenninatesthe proceeding or action subject to the notice,or fails to open. a JOrI1lal investigation or commence a proceeding or , action within a reasonable time (which in no event shall be later than 60 days after receipt of the initialnotice). ARTICLE X Conditions to Adelphia's Obligations The obligation ofAdelphia to consummate the Closing shall be subject tothefulfilllI!ent, prior to or at the Closing, of each of the following conditions unless. waived by Adelphia in writing: 10.1 Verizon's. Representations and Warranties. Each representation and warranty made by Verizon. in Article V hereof that is modified by materiality.. shall be true. and correct in all respects, and those that are not so modifiedshallbe true and correct in all materialrespects, on and as of the Closing Date with the same effect as though each such representation and warranty had been made or given on aIld as of the Closing Date other than (i) representations and warranties made as of a specific date, which shall be true arid correct as of such specific date,and (ii) any breach ofa representation or warranty that (a) has not, indi viduall y or in the. aggregate, resulted ina Material Adverse Effect, or (b) is related to or resulted from either (x) economic . . conditiollS applicable to industry:-wideoccurrences, or (y) the execution of tl1isAgre~m~nt or the transCictioJ,ls. ~ontemplated...herebyandthat. was not a breach of a ..representationor.warranty contained in this Agreementon the date hereof. (a) . No action, suit or proceeding (which, in the. case of an action, suit Or proceeding brought by a non-GovemmentalEntity, has a reasonable likelihood of success) is pending before any Governmental Entity to enjoin, restrain, prohibit or obtain substantial damages in respect of the transfer of the System as contemplated by this Agreement or the Ancillary Agreements, or which would be reasonably likely to prevent or make illegal the consummation of any transactions contemplated by this Agreement Or the AncillaryAgreements; (b) (i) No action, suit or proceeding is pending, and no order has been issued, whereby a Govemmental Entity seeks to enjoin, void or prohibit the transfer of any material assets ofVerizon to Adelphia or any Affiliate of Adelphia, and (ii) Adelphia shall not have received written notifi~ation from a regulatory Governmental Entity indicating that ~uch regulatory Government Entityisthreatening to commence a proceeding or action seeking toenjoin, void or prohibit the transfer of any material assets of Verizon to Adelphia or any Affiliate of Adelphia; provided,however,that if such a written notification has been received, this condition shall nevertheless be fulfilled and shall not delay' the Closing if such regulatory.. Governmental Entity withdraws its notice, terminates the proceeding or action subject to the Ilotice, or fails to open a fonnal investigation or commenCe a proceeding or action within a reasonable time (which in no event shall be later than 60 days afterreceiptoftl1e initial notice). (c)' Adelphiashallnot have received written notification from a regulatory Governmental Entity indicating that such regulatory Governmental Entity is threatening to commence a proceeding or action in relation to the sale of theS ystem as contemplated by this Agreement;provided,however, thatif a written notification has been received, this condition shall nevertheless be fulfilled and shall not delay the Closing if such regulatory ..OovemmentalEntity. withdraws its. notice;. terminates t~eproceedingor. action. s.... u........b....... ~.....e ct... ..t. oth. e....o.... ..0.. tic..... e.,. .o.r. . f3.l. .'ls to.ope. D.. a fonnal. ..i. nv. e.. sti. g.3ti.o.. 0.. . Of.C. 0.. mrn. .. . ...~oc.e a.. p.. .r...'..o. c.e. e.ding. . .. D.C. '.. actionwithina>reasonable time (which inno event shall be Illterthan60 days lifter receipt of the initial notice). n~tice . to!heQtherParty . at least ten days. priort<> the date of the Closing. . The Closing wIll take place at the offices ofVerizonConunuIlications Inc.locatedatJ095 Avenue of the Americas, New York, New York, at 10:00 a.m. New York City time on such.date. The date on which the Closing occursisreferred to herein as the "ClosingDate." Upon the satisfaction or waiver of the conditions set forth in Articles IX and X, the Parties shall promptly proceed with the Closing of the transfer of the. Acquired Assets and ASSUmed Liabilitiesin accordance with this Section 11.1. Notwithstanding the foregoing, in no event shall the Closing occur prior to the llOthdayafterof the Franchise Filing Date withoutthe written consent of the Parties. (b) Verizon and Adelphia shall meet on the date preceding the Closing Date at the offices of Verizon Communications Inc. to conduct a pre-Closing at which all deliveries to be made at Closing will be reviewed by the parties and placed in escrow. At 11:59 p.m., Eastern Standard Time, on the date preceding the Closing Date , Verizon shall terminate its operation of the System. At 12:01 a.m., Eastern Standard Time, on the Closing Date, Adelphia.shall commence operation of the System. At 10:00 a.m. on the Closing Date New York.Citytime, all instruments and payments held in escrow shall he distributed and disbursed to Verizonand Adelphia, and the Closing shall be consummated. 11.2 Termination. This Agreement (and the transactions contemplated hereby) may not be terminated except as follows: (a) Upon the mutual written consent ofVerizonand Adelphia; (b) ByVerizon,.ifAdelphiais in material breachof.this..Agreernentand such breach has not been cured within ten days following the delivery of notice thereof to Adelphia; , (c) By Adelphia, if Verizonis in material.breach of this...Agreelllent .andsuch breach . has . not been cured within ten days following the delivery .of notice thereof to Verizon; or I 1.3 Effect of Termination. Upon the termination of this Agreement in accordance with Section 11.2 hereof, the Parties shall be relieved of any further obligationsorJiabilityunder this Agreement other than the following sections or obligations which shall survive tennination: ,. (1) confidentiality obligations contained in. Section 7.6 (with. respett6nly to confidential in.. fonn... atio. n.....re.g. ar. di.n....g'.^. d. e.lph. ia) an.. d.Se..ction 8.4. ..(with. .re.spe.. c.. t o..nly. to.confi. ld...en.t.ial.,..i.nform...ation. regardingVerizon), (2). Adelphia's. obligations contained in Section 8.11,(3) the confidentiality obl~gationscontained in the Non-Disclosure Agreement, (4) obligations forb~aches of this Agreement occurring prior to such tennination,and (5) the provisions of this Section 11.3, Article 15 and Article 16. . At Closing, Verizon shall deliver the following to Adelphia: 12.1 Bring-Down Certificate. A bring-down certificate executed by an executive officer of Verizoncertifying that the conditions specified in Sections 10;1 and 10.2 have been satisfied. 12.2 Secretary's Certificate. A certificate. executed on behalf of Verizon by V erizon 's Secretary or Assistant Secretary certifying. as to .the incumbency, .and .authenticating the signatures of, officers executing this Agreement and certificates delivered hereunder on behalf of Verizon, and certifying as to the adoption and continuing effect of appropriate resolutions authorizing V erizon 's execution, delivery and perfonnanceof this Agreement. The Verizon Ancillary Agreements duly 12.4 Other Agreements. TheI...ease Agreements and the Pole Attachment and.Conduit Occupancy Licensing Agreements duly executed by the appropriate Affiliate of Verizon. 12.5 Good Standing Certificates. Good Standing CertificatesofVerizon dated not more than 10 days prior to Closing from the State of Delaware and the State of Florida. 12.6 FCC Opinion. An opinion of Wiley Rein & Fielding LLP, Verizon's FCC counsel, in the form of Exhibit G. 12.7 Opinion of Counsel. An opinion of Baker Botts L.L.P., counsel to Verizon, in the fonnof Exhibit Hi ........ .. .... .....~;r:ecuti()n Copy ConjUle".~oJ (lnd~roprietary certifying as to the .. adoption. and continuing effect ofappropriateresolutioIlsauth()rizingthe execution, delivery and perfoImance Of this Agreement by Adelphia. . 13.4 AdelphiaAncillarv executed by Adelphia. Agreements duly 13.5 Other A2Teements. The LeaSe Agreements and the Pole Attachment and Conduit Occupancy Licensing Agreements duly executed by Adelphia. 13.6 Opinion of Counsel. An opinion of Colin Higgin, general counsel to Ade1phia,. in the form of Exhibit I. 14.1 Filing of Returns. In connection with the preparation and filing of Tax Returns as of and after the Closing Date,thePartiesshall cooperate and exchangeinfonnationas reasonably required to accomplish the matters contemplated by this Article XIV. 14.2 . Access to Books and Records. After the Closing, upon reasonable notice, and subject to Seetion7.6andSeetion8.4hereof (as applicable to each Party), each Party will give to the representatives, employees, counsel and accountants of the other J>arty ; access, during nonnal business hours~ to records, and will pennit suchpers?ns to examine and copy such records, in each case to the extent reasonably requested by the other Party in connection . with Tax and financial reporting matters, audits, legal proceedings, governmental investigations and other business purposes (including such financial information and any receipts evidencing paynientofTaxes as may. be requested to substantiate any claim forTax credits or refunds); provided, however, that nothing herein will obligate any Party to rake actions that would unreasonably disrupt the normaL course of its business or violate the terms of any Contract to which it is a party or to which any of its assets is subject. The Parties will cooperate with e~ch other in the. conduct of any Tax audit. or similar. proceedings. involvin~ or otherwise ~elating to : th.. e......... S..... y. s.t...e.m.... ...... (or the. ... ..i.n. c.ome. ... theref...r. om. O.f.. I1S.. s.e. ...t.s.. ...t.he..re. .0. ..f).. . w... 1. .th... . res.,.' p.. .ec. t. t. o. . an......y..:.T. ,.ax... . an. d... .... e. .3.......c........h... .... .w....... . ill...... .', - ,'-', -- - ". '-' " '--' . - -. -, ," - --. --. ".-., '.,' , .-" '-,' .. ." . execute and deIiversuch. powers .ofattomeyandother documents as areriecessary to carry OUt theinterit of this Seetion 14.2 and Section 143.. , . -' . .. (a) , . In accordance. with the provisions of Article III, and subject toSeetion 14.5,Verizon agrees to indenmifyand hold harmless Adelphia, its Affiiiates, success.ors andpermitted assigns fr()mandagainst anyandall Indemnifiable<Lossesincurred Of suffered by.. Adelphiaarising from ... (i) . any. Taxes ( other than Taxes that are Assumed Liabilities) of 'I erizon or its Affiliates, orattrlbutat>leto th(::oper~tions of the System Of ownershipoftheAcquired Assetsfor all Tax periods (or portionsth~reof)ending priorto the. applicable Closing. Date, (ii) any matericilbreach of the represeritatioris contained in ...... ..~xecution Copy Confiden~al and PrOPrietary SectionS.10(a), (c) and (dJ or (iii)the failure of.Verizonto agreements or undertakings made by Verizcm in this Artic1eXIV. (b) In . accordance with the provisions of Article .111, and. sUbject. to. Section 14.5, Adelphiaagrees to indemnify and hold harmlessVerizon, its Affiliates, Successors and permitted assigns from and agaillst any and all Indemrtifiable Losses incurred or suffered by Verizon. arising from(i} any Taxes that. are Assumed Liabilities,. of Adelphia or its Affiliates,or attributable to the operations of the. System or ownership of the AcquiredAssets for all Tax periods (or portions thereof) ending on or after the applicable Closing Date,or (ii) the failure of Adelphia to perform any of the agreements or undertakings made by Adelphia in this Article XIV. (c) .. .Any. Party....seeking.jndemnification under .thisArticleXlV(the "Tax Indemnitee") shall give the other Party (the "Tax Indemnitor") written notice of any audit, proposed adjustment or assessment, or proceeding bya Tax. authority involving Taxes for which the Tax Indemnitee will seek indemnification no later than 20 business days after receipt of notice of such proceeding by the Tax Indemnitee; provided, however, that the failure. of the Tax Indemnitee to so notify the Tax Indemnitorshallnot preclude any indemnity h~reunderunlessand to the extent that such failure has materially and adversely affected the Tax Indemnitor's contest rights with respect to the proceeding. At its own cost, the. Tax Indemnitor shall have the right to control and settle such proceeding; provided, however, that to the extent the Tax Indemnitor is not liable . under this Article XIV for the entire amount ofth~Tax .relatingto..suchpJ:'oceeding, at the Tax Indemnitee's option~ (i)theTCi}tIndemnitor shall have the right t()control the proceeding at its cost and to settle such proceeding with the written approval of the TaxIndemoitee (which approval shall not be unreasonably withheld), (ii) theTax Indemnitee shall have the right to control the proceeding at its cost and to settle such proceeding with the written approval of. the Tax Indemnitor (which approval shall not be unreasonably withheld), or (iii) the Tax. Indemnitor and Tax Indemnitee shall joindycontrol, share the. cost and mutually agree ona settlementof such proceeding. (e) Notwithstanding contrary in repres.en..t~tions and warranties contained in Section S.10(a), (eX and(dJ and>the obli&ations jmposedbyArticle XIVshalls\lfViveuntil the expiration of 60 days ,following the ..expiration .of the applicable.. statute of . limitations . for ..' assessment. and collection of each Tax; prollided, however,that in the event that a notice of claim for indemnity pursl,lant to this ArticleXIVis made during such period, indemnity with respecUosuch claim shall.survive until such time as the (:laim is fiIlallyresolved. ,....ExeclltionCopy ConjidentialandProprietary 14.4 . Transaction Taxes. Adelphia shall bear and be responsibleforpayingany sales, use, stamp, transfer,dQCum~ntary; registration,business and occupation and other similar taxes (including. related penalties . (civil or . criminal), additions to tax and interest) imposed by any Governmental Elltity with respect to. the transfer of the System and any. Acquired Assets to Adelphia ("Transaction Taxes"), regardless of whether the Tax authority seeks to collect SUch taxes from Verizon or Adelphia. Adelphiashallalso be responsible for(i) administering the payment of such Transaction Taxes,. (ii) defending or pursuing any proceedings related thereto, and (iii) paying any expenses related thereto. Verizon shall give prompt written notice to Adelphiaof.any proposed. adjustment or assessment of any. Transaction Taxes. with respect to the transactions contemplated hereby and in the AncillaryAgreements. Inanyproceedings, whether formal or informal, Verizon shall pennitAdelphiato participate and control the defense of such proceeding, with respect to such .Transaction .Taxes .and shall. take all actions and execute all documents required toallo'r\'Sl1chparticipation. . Verizon shall not negotiate a settlement or compromise of any Transaction Taxes without the written consent of Adelphia, which consent shall not be unrea.sonablywithheld. 14.5 Tax Prorations.. Asto the System orthe Acquired Assets acquitedbyAdelphia, Verizon and Adelphia shall apportion the liability for real and personal property taxes, ad valorem taxes, franchise fees or taxes ("Periodic Taxes") for all TaXable periods including but not ending on the Closing Date (all such periods of time being hereinafter called "Proration Periods"). The Periodic Taxes described in this Section 14.5 shall be apportioned between Verizon and Adelphiaas. of the Closing Date, with Adelphia liable for that portion of the Periodic Taxes equal to the Periodic Tax for the Proration Period multiplied bya fraction, the numerator of which is the number of days remaining in the applicableProrCitionPeriod including and after the ClosingDate,andthe'denomiIlator of which.isthetotal number~fdayscovered by .. suchProrationPeriod.Verizon shallbe liable for that portion of the Periodic Taxes for a Proration Period for which.Adelphia is notJiable under the preceding sentence. Adelphia and Verizon shall payor be reimbursed for real and personal property taxes (including instances in which such property taxes have been paid before the Closing Date) onthis prorated basis: If a payment on a tax bill is due after the Closing, the Party that is legally required to make such payment shall make such payment and promptly forward an invoice to the other party forits pro rata share, ifany. If the other Party does not pay the invoice within 30 calendar days of receipt, the ...amount. of such...... payment shall. ..bear ...interestat.....therateof8~peI:annuT~!heParty .. responsil?le for paying a tax,d~scribedin thisSectjon 14.5 shall be responsible for . adiriinistering the paymentof(andanyreimbursementfor)suchTax. . For purposes of this Section 14.5,the ProrCitionPeriod for ad valorem taxes and real and pers()nal property taxes shall be the fiscal period for which such taxes were assessed by the Tax jurisdiction. 14.6 Tax Refunds and Tax Treatment. Any Tax refunds (inCluding any interest related thereto) received by Adelphia, its Affiliates or successors relating to Tax periods (or portions , thereof) ending on ()r before the Closing Date shall be for the account of Verizon, and Adelphia shallpayovertoVerizon any such am()unt within five business days of receipt thereof. Adelphiashall,..if Verizon so.requests and atVerizon's direction and..expellse, flle.orcause its Affiliates tome for. and. obtain any Tax refunds with. respect to Tax periods. or p()Itlons . thereof . ending on or before the Closing. Date.. Provided that Verizonis notliquidated on or before 'the ~rst anniversary of the Closing. Date,. Adelphia and V erizonagree that this transaction.. shall be treated as a taxable asset sale for all TaX purposes and no Party shall take a position that is inconsistent with such sales treatment in any governmental filing, Tax Return or otherwise. Indemnification 15.1 SUrVival of Representations.W arrantiesal1d Covenants. (a) The representations and warranties contained in the second sentence of Section 5.5, and Sections 5.6(b), 5.15 and 6.6 will survive the Closing and remain in full force and effect indefinitely. The representations and warranties contained inSection 5.14 will SUrVive the Closing and remain infuII force and effect until the fifth anniversary of the CloSingDate.'Eachof the .other. representations and warranties contained in Article V and Article VI will terminate, without further action, on the date which is one yearJollowiIlg the Closing Date (the "Expiration Date"). (b) This. Article XV will sUrVive any termination of this.. Agreement and the Ancillary Agreements. ThisArtieleXVwill survive the Closing.anclshall remain in effect: (i) indefinitely, with respectto anyindemnifiable claim related to the indemnitycontainedinSeetion IS. 7 or related t<> the breach of any covenant or the breach of any representation or warranty which pursuant to See/ion 15.1(a) .suririvesindefinitely;.'. . (ii) . indefinitely, with respecUo any indemnifiable claim arising under or related to Excluded Liabilities pursuant to Section 15.2(a)(iii), except for Excluded Liabilities relating to environmental liabilities, which shall survive for five years.from the Closing; (Hi) . . indefinitely, with respect to any indemnifiable claim arising under or. relat~~. t~ ~$sume4. Liabiliti~sP\Jrsuant to. .~ection .1,5.2(b)(#i);. and ..... .. 'Eiecution Copy Confidential andJ'roprietary surVival period for such representation orwarranty, or (y)totheextentbased on IndemnifiableLossesactually incurred by an Indemnitee prior to the expiration of the survival period for such representation or warranty . . (a) Following the Closing andsubjectto the other sectionsofthisArticle XV, Verizon will indemnify, defend and holdhannless Adelphia and its Affiliates and their respective directors, officers, and agents from and against all IndemnifiableLosses relating to, resulting from orarising out of: (i) any inaccuracy.in any of the representations. and warranties made by Yerizon in Article. V of this Agreement, (ii) a breach byVerizon of any covenant or agreement ofVerizon contained in this Agreement or any Ancillary Agreement, which covenant or agreement requires performance by Verizon at or after the Closing, and (iii) (b). .. Following the Closing and subject to the other sections ofthis Article. XV, Adelphia will indemnify, defend and hold harmless Verizon and its Affiliates and their respective. directors; officers, agents, shareholders and partners from and against all Indemnifiable lpsses relating to, r:esulting from or arising out of: (i) any inaccuracy in any of the representations or warranties made. by Adelphia in Article VI of this Agreement, .., , Oi) a breach by Adelphiaof any covenant or agreeinentof Adelphia contained in this Agreement or any Ancillary Agreement, which covenant or agreement requires performance by Adelphia at. or after the Closing, and Executi~n....Copy Conjidentiallfnd Proprietary (i) "Indemnification Payment" means any amount of Indemnifiable Losses required to be paidpur~uant to this Agreement, or entity entitled to (ii) "Indemnitee" means indemnification under this Agreement, (iii) "Indemnifying Party" means any Person or entity required to provide indemnification under this Agreement, and (iv) "Indemnifiable Losses" means any losses, liabilities, damages, costs and expenses (including reasonable out-of-pocket attorneys' fees and expenses)a:ctually incurred in connection with . any actions,~uits, demands, asse~sments, judgments and settlements, in any such case reduced by the amount of insurance proceeds recovered from any Person or entity with respect thereto. (b) . As between Verizon and any Affiliate of Verizon, on the one hand, and Adelphiaandany Affiliate of Adelphia, on the other hand, the remedies, rights and obligations set forth in this Article XV, Section 14.3 (Indemnification for Taxes), Sections J 1.2 and 11.3 (Termination) and the Ancillary Agreements will be the exclusive remedies, rights and obligations with respect to the liabilities and obligations referred to in Section 15.2 andanybreach of the representations, warranties orcovenants set forth in this Agreement or. the AnciUary . Agreements. Without limiting the . foregoing, as a material inducement to entering into this Agreement and the AncillaryAgreements, to the fullest extentperrtIitted by Law, each. of the Parties waives any claim or cause of action that it otherwiseinight assert, and any breach of the representations, warranties or covenants setforth in this Agreement, except for claims or causes of action brought under and subjectto the terms and conditions ofthisArticle X~ Section J4.3(Indemnification for Taxes), Sections 1J.2 and 11.3 (Termination) and the AncillaryAgreements. (c) Except as provided by Section J5.8, notwithstanding any other provision of this Agreement..or.of . anY applicable Law, no .IndemniteewiU. beeqtitled to. make .a claim again~tanIn<leII1Ilifyi{lgPlJItY fo.r Indemnifiable. Losses arising . outoforrelating to any inaccuracy of repr~entaiions()rwarrantiesunderSectionsJ 5~2( a)(i) ot15.2(b)(i) until the aggregate amount f .. maybe asserted for such IndemnifiableLosses exceeds an amount equal t and only to the extent such amount, if any, (a) . exceeds an amount equal and (b) is less than' the amount set forth in SectionJ5.3(d). ... I . . , its indemnification obligation.contained in Section lS.2(a)(ii) ClS.itrelates . to. the covenantsbyVerizoncontained in the . first sentence of Section 7.8(b) and the last sentence of Section 7.8(c), and (ii) its reimbursement obligations>containedin the first sentence of Section 7~8(c)and Section7.8(d)(i).Except as provided in this Section 15.3, any Party shall be obligated to provide indemnification for aU IndemnifiableLosses that may be asserted pursuantto Sections 15.2(a)(ii), 15.2(a)(iii), 15.2(b)(ii), and1S.2(b)(iii), as applicable~ (e) . Except with respect to the indemnification by Verizonof Indemnifiable Losses relatingto the covenants by Verizon contained in the first sentence of Section 7.8(b) and the last sentence of Section7.8(c), no Indemnifying Party shallbe liable to or obligated to indemnify any Indemnitee hereunder for any consequential, special, multiple, punitive.. or exemplary.. damages including damages arising from loss or interruption of business, profits, business opportunities or goodwill, loss of use of facilities, loss of. capital,cIaims of customers, or any cost or expense related thereto, except to the extent such damages have been recovered by a third person (including a Governmental Entity) and are the subject of a Third Party Claim for which indemnification is available under the express teonsof this Article XV. (f) The Parties shall Cooperate with each other with.respectto resolving any cIaimor liability with respecUo which one Party isobligated to indemnifytheother Party hereunder, including by making commercially reasonable efforts to mitigate or resolve any such cla.imor liability. (a) . If any Indemnitee receives notice of the assertion of any claimorof.the commencement of any action or proceeding byany Person or GovemmentalEntitythatis not a party to this Agreement (a ''Third Party Claim") against such> Indemnitee, with respect to which an Indemnifying Party is obligated to provide indemnification under this Agreement, the Indemnitee will give such Indemnifying Party reasonably prompt written . notice thereof, but in any event notIater than 10 calendar days after receipt of notice of such Thirdrarty Claim; provided, however,> that the . failure()fthe~demnit~~()l1otifythe Inde.mnifyillg .,.PaI1y:.shall,J>nly. relieve the ..Indelll11ifying..,..p~y, fromits,qobligatio~l...to indemnify the Indeinnitee.pursuantto this Article XV to the extent that the Indemnifying Party is materially prejudiced by such failure (whether asaresult of the forfeiture of substantiverights or defenses or otherwise). Upon receipt ofnotificationofaThirdParty Claim,the Indemnifying Party shall be entitled, upon written notice to the Indemnitee; to ..' assume thejnvestigation and defense thereof. Whether or not the . IndemnifyiIlg Party elects to assume the investigation and defense of any Third Party Claim, the Indemnitee shallhayethe right to employ separate counsel and to. participate.in the . investigation and defense thereof; provided,. however, that the Indemnitee shall pay the fees. and disbursements of. such.. separate . counsel unless ... (i) .theemploYIlleIlt of such separate counsel has been specifically authorized in writing by the Indemnifying Party.. (ii)the Indemnifying Party has failed to assume the defense of such Third Party Claim within a reasonable time after receipt. of notice thereof. or.(iii) the named parties to the pr()ceeding . ~~e€utionCopy Confide."tia1iUld Proprietary in which such claim, demand~.action or cause of action hasbeenllSsertedinc16d~both the Indemnifying Party and such Indemnitee and, int~ereasonable judgment of counsel to such Iridemnitee, there exists one or more defenses that maybe available. to the Iridemnitee that . are . in conflict with those available to the Indemnifying Party. Notwithstanding the foregoing, the Indemnifying Party shall not be liable for the fees and disbursements of more than one counsel for aHIridenmified PartiesinconIlection with any one proceeding or any similar or related proceedings arising from. the same general allegations or circumstances. Without the prior written consent of the Indemnitee, the Indemnifying Party will not enter into any settlement of any Third Party Claim that would lead to liability o(create anyflnancial Or other obligation on the part of the Indemnitee unless such settlement inc1udesasan unconditionaltenn thereof the release of the Indemnitee from all liability in respect of such Third Party Claim. If a settlement offer solelyJor money damages is made by the applicable third part yc1aimant, and the Indemnifying Party notifies the Indemnitee in writing of the Indemnifying Party's willingness to . accept the settlement offer and pay the amount called for by.. such offer without reservation of any rights or defenses against the Indemnitee, the Indemnitee may continue to contest such claim, free of any participation by the Indemnifying Party,and the .. amount of . any ultimate liability with. respect. to. such Third Party Claim ... that the Indemnifying Party has an obligation to pay hereunder shall be li!TIited to the lesser of (A) the amount oLthe settlement offer that the Indemnitee declined to accept plus the Indemnifiable Losses of the. Indemnitee relating. to. such Third Party Claim through. the _ date of its rejection of the settlement offeror(B) the aggregate Iridemnifiable Losses of the Indemnitee with respect to such claim. . . ,,-., (b) ... .. Any claim by an Indetnniteeon account of an Indernnifiable Loss that does not result Jroma Third Party Claim will.be asserted by giving .the Indemnifying Party reasonably prompt written notice thereof, but in any event not later than 30 calendar days after the incurrence thereof, and the Indemnifying Party will have a period of 30 calendar days within which to respond in writing to such claim. If the Indemnifying Party does not so respond within such 30 calendar day period, the Indemnifying Party will be deemed to have rejected such claim, in which. event the In. .d. e..mn. ... it. e.e.......w..,...i..l.l.. b...efr.e. e. ..to. p.. ...u..rs.u...e.... su...c...h..... r.e.m. e.di.e... s...as... m.. a.ybeavailableto...t. h..e Indemnitee 9D .. . . . the te~sllIl~subjc:cttoJl1~~r(),,-isionsof thisArti~le XV. .. .... <Execution COpy Confulentia(and Proprfetary. IndemnifyingParty against any such third party onaccountof~aidIndenmification Pa~ent. will be subrogated. and .. subordinate<i in . right . of payment to the Indemnitee 's rights against such third party. Without limiting the generality or effect of any Other provision of this ArlicleXV, each such Indemnitee and Indemnifying Party will duly execute upon request all instruments reasonably necessary to evidence and perfect the above.,.described subrogation and. subordination rights. 15.5 No Indemnifiable Claims Resultin~ From Governmental Entitv Action. Adelphia has no indemnitiable or otherwise compensable claim that any of Verizon'srepresentations or warranties in Article V is inaccurate, or that any covenant or agreement has been breached, if such claim is predicated on any Law enacted..or. issued by a Governmental Entity after the Closing and that is effective retroactively for periods oftime prior to the Closing. (a) Notwithstanding anything in this Agreement tathe contrary; Verizon shall have no obligation to defend, indemnify or hold harmless Adelphia or any of its Affiliates from damages, costs or expenses resulting frornanyobligation, suit C>f proceeding based ... upon any claim that any activity. subsequent to the. Closing Date engaged in by Adelphia, a customer of Adelphia'sor . anyone claiming under Adelphia constitutes director contributory infringement, misuse or misappropriation of orinducement to infringe: any Third Party Intellectual Property. (b) .. Adelphiashall defend, indemnify andhold hannlessVerizon and any of its Affiliates. from and against any and all Indemnifiable Losses resulting from any obligation, proceeding or suit based upon any'c1aima1legingor asserting direct or contributory infringement; misuse or misappropriation of or inducement to infringe by, Verizon arany of its Affiliates of any Third Party IntellectualPropertyto the. extent that such claim is based on, or would not have arisen but for, activity conducted or engaged in subsequent to the Closing Date by Adelphia, a customer of Adelphia's or anyone claiming underAdelphia. -". ".'.' . ',,' (a) Adelphia shall indemnifyandholdhairnIessVerizoI1, each of its Affiliates holding AdeIphia Common Shares obtained hereunder and each other person who controls Verizon within the meaning of the Securities Act against any In<iemnifiable Losses, to which any such Indemnitee may become subject under the Securitie& Act, the Securities and Exchange Act of 1934, as amended, or any other applicable securities Law, insofar as such Indemnifiable Losses arise out of or are based tiponanyuntrue statement or alleged untrue statement of any material fact contained in the Registration Statement, any prelilI1inaryprospect1.1s, final prospectus orsummaryprospectus contained ,therein, orany amendment or supplementthereto. or any omission or allegedorrllssion to state therein a material fact 'required to. be stated therein or necessary to make the, statementS.therein notlI1isleading; provided, however, that Ac:te1phia shall notbe liable in any such case to the extent that any. such IndemnifiableLosses arise out of or is based solely. upon . an untrue . statement or alleged untruestatementoroinissionor.alleged omission made in the Registration.. Statement, .any.such prelirninar~prospectus, .final .. prospectus, summary prospectus, amendment or supplement in reliance upon and in conformity. with information furnished. to Adelphiaby or .on. . behalf. of . Verizon or any Affiliate of Verizon for use in the preparation thereof. . (b) Verizon shall indemnify and hold harmless Adelphia,eachdirector of Adelphia, each officerofAdelphia that signs the Registration Statement and each other person if any, who controls Adelphiawithin the meaning of the SecuritiesAct,with respect to any untrue statement or alleged untrue statement of any material fact contained in the Registration Statement, any preliminary prospectus, final prospectus or summary prospectus contained therein, or any amendment or supplement thereto, or any omission or alleged omission to state therein a material fact required to be stated therein or necessary to make. the statements therein not misleading, but only to the extent that such statement or alleged. statement or omission was made in. reliance upon and in conformity with written informationfurriishedto Adelphia by or on behalf ofVerizon specifically fOr use in the preparation of the Registration Statement, preliminary prospectus, final prospectus, summary prospectus, amendment or supplement. 15.8 Inapplicability to Taxes. Except as provided expressly in this Article .XV,this Article XV shall not apply with respect to indemnification of the Parties for Taxes, which liability shall be subject toArticleXIV hereof. 16.1 Expenses, Except as otherwise expressly provided for elsewhere in this Agreement, each Party hereto. shall pay. its own expenses and costs relating to . the negotiation, execution and perfonnance of this Agreement. Verizon and Adelphia shall each bear all of its own costs and expenses incurred in securing the appropriate governmental. approvals 10 the assignment of the AcquiredContracts. Adelphia, shall pay all HSR Act filing fees~. . . VerizonMedia Ventures Inc. Clo VerizonCommuIiications Inc. 1095.. A venue of the Americas NewYork,New'york 10036 Attn: · Executive Director -'- ...Corporate Development Fax Number: (212)597-2741 With a copy to: Verizon Communications Inc. 1095 A venue of the Americas New York., New York 10036 Atto: Associate General Counsel- Strategic Transactions FaxNumber: (212) 764..2432 Adelphia Communications Corporation One North Main Street Coudersport,Pennsylvania ,16915~ II Attn: Colin Higgin Fax:Nuinber:(814) 274-6586 , 16.6. Countetparts:Third Party Beneficiaries. This Agreementmaybeex~uted in one or more counterparts, each. of which. shall. be deemed an original but. all of which together shaH constitute one and the. same instrument. No provision of this Agreeme~t, other than as expressly provided inthe indemnificati()n provisions of Articles XIV and XV, is intended to (i) confer upon. any Person other than the Parties hereto and their successors and permitted assigns, any rights or remedies herel1nder,(ii)relieveor discharge the obligation or liability of any third party or (iii) give any third party any right of subrogation or action against any Party. 16.7 Entire Asrreement. This Agreement, the Ancillary Agreements, the Non- Disclosure Agreement, the Lease AgreementsandthePole Attachment and Conduit Occupancy Licensing Agreements, embody the entire agreement and understanding between Verizon and Adelphia withrespect to the subject matter hereOf and supersede all priora~reements and understandings related to the subject matter hereof. There are no representations, warranties; covenants, promises Or agreements on the part of any Party to the other hereto which are not explicitly set forth herein. .... .i.ExecutionCopy Con.fid~ntial antJProprietary 16.8 Modifications. Any modification, amendmentor waiver of or withrespect to any provision ofthisAgreementor any agreement; instrument. or docurnentdelivered pursuant hereto shall not be effective unless it shall be in writing and signed by Verizon and Adelphia and shall designate specifically the terms and provisions so modified. 16.9 . . AssimmentandBinding:EffecLThis Agreement shall be binding upon and inure to the benefit of the Parties hereto and their respective successors and permitted assigns, but (except as provided for in this Section 16.9)neither this Agreement nor any of therigl1ts, interests or obligations hereunder shall be assigned by AdelphiaorVerizon without the prior written consent of the other. Notwithstanding the previous sentence, (i) Verizon may assign this Agreement or any interest herein (a) iiLconnection with a change of control, merger or reorganization of Verizon or a sale of all or substantially all of Verizon's assets or (b) to any AffiliateofVerizon, provided thattheassigneeofVerizon agrees in writing to be bound by the provisions of this Agreement, and(ii) Adelphia may assign this Agreement or any interest herein to any Affiliate ofAdelphia provided that Adelphia shall continue lobe responsible for the obligations containe(}iIl this Agreemeritand the Ancillary AgreeIIl. ents; , - .-- - .' -'- , . '- - - ,- -"-.' ",. . - --- ,,-,.-. '. - ., '-...-, - ,-, . . ".- . 16..11' POblicAnnouncements: Confidentiality. V erizonand Adelphiawill consultwith .eachotherbeforeissui.ng or prior to the issuance by any Affiliate of, and. will provide each o. th.er < the opportunity to review and comment upon, any press release or other public statements (or . relevant portions thereof) relating to the transactions contemplated by this Agreement and shall not issue,and shall ensure that theirrespective Affiliates shall not issue, any such press release or make~anysuchpublic statement prior to such consultation, except as may l>erequired by applicable.. Law ,'icourtprocess or.. by obligations. pursuant ... to .. any. listing agreement with. any natiol1als~curitiesexchange. Each Party also agrees that it will not; directly or indirectly, except to,theexterit required by Law or Court Order (providc:~ priortimely notice has been provided to ., . .............. .....Ex;ecutionCopy Conjidentialan.d Proprietary the otherPartytopennit such Party to limit such disclosure or toseek appropriate protective orders), make use of or divulge; or permit any of its agentS, employees or Affiliates to make USe of ordivulge,any tenns or conditions of this Agreement or the Ancillary Agreements. The obligations contained in t~is. Section 16~11. are in addition to and independent of the obligations contained in the Non"Disc1osureAgreement 16;12 Right to Specific Performance. The Parties acknowledgethatthe uniquenature.of the transactions contemplated by this Agreement may render money damages an inadequate remedy for the breach by either Party of its obligations under this Agreement. Each Party agrees thatin the event. of such breach, (i) the non-breaching Party may, upon proper action instituted by it, be entitled to. seek.a decree of specific performance of this Agreement, and (ii) such rights are cumtllative and in addition to any other remedy to which the Parties maybe entitled at law or equity. 16.13 Bulk Sales Laws. The Parties waive compliance with applicableJaws under any version of Article 6 of the Uniform Commercial Code adopted by any state or any similar law relating to thesaIe of inventory, equipment or other assets in bulk in connection with thesaIe of theSystem. [Remainder of page. intentionally left blank.. Signature pages follow.] IM\III~ WH~ot. lbOPII'Ii<s. f><lina "",,\111& 1l1o~ aul~ ""thC1lzed ~..,;i."" 13vcOdi:- ibi~ ".....1\..".. oflll/lcl&" firsl.1>Cl'It wn\l.... ~. By:.. .. ....... .. .. ... . ... ......... .... . ... =-_.:. ~y,,~ ~ AllW}Il#.COMWuN1CAnQNS C01tPOllAnON . '&~ NlIIlc: Title: - --- V21170)(WEDlA vENTURES INC. AlliUHlA CONMUNlc.\UONS CQJtPOJAnON :~~.~ ~ -; . .. ... ..E~eCutionCopy Conjidentitll antl ProPrietary .CityofClearwater City of SLPetersburg City of Ounedin City of OldsII1ar City of Tarpon Springs City of Safety Harbor City of SeminQle City of Largo Pinellas County. . This ASSUMPTION AGREEMENT(th~"Agreement")isente(ed into as of[.], 2oo[e] (the "Effective Date") by and between VerizonMediaVenturesJnc.,apelaware ("Seller"), and Adelphia Communications COIporation,aDelawarecorporation WHEREAS, pursuant to .that certain Asset Purchase Agreement (the "Asset Purchase Agreement"), dated as of December 17, 2001, by and between SellerandBuyer,Buyer has agreed to assume, pay, perform and discharge when due,the.AssumedLiabilities; and WHEREAS, all capitalized terms not otherwise defined herein shall have the respective meanings ascribed thereto in the Asset Purchase Agreement. .. Nbw, THEREFORE, in consideration of the premises, the tennsandconditions setforth herein aild in the Asset Purchase Agreement, the mutualbenefits to be gained by the performance hereofand other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the Parties hereto agree that, as of the EffectiveDate,Buyer hereby assumes and agrees to pay, perfonnand discharge when due, the AssUlned Liabilities. This Agreement shall be governed by, and construed in accordance with; the J~ws of the State of New York without giving effect to principles of conflict of laws. This Agreement may be executed in any number of counterparts, each of which shall be deemed an original, but all of which together shall constitute one and thesame instrument. ADELPHIA COMMUNICATIONS CORPORATION This BILL .OF SALE. AND. ASSIGNMENT AGREEMENT. (this "Bill of Sale"), is entered into as of[e],2oo[e], by and between VerizonMediaVenturesJnc., a Delaware corporation (the "Seller"), for the benefit of Adelphia Communications. Corporation, aDelaware corporation (the "Buyer"). . WIT N E SSE T H: WHEREAS, pursuant to that certain Asset Purchase Agreement (the "Asset Purchase Agreement"), dated as of December 17,2001, by and between Seller and Buyer, Seller has . agreed to sell, assign, transfer, convey and deliver to Buyer for the consideration specified therein, and Buyer has agreed to purchase, assume and acquire from Seller all of Seller's right, title and interest in, to and under the Acquired Assets as the same shall existoD the dateberc:of; . and . ..' ... ... WHEREAS, all capitalized tenns not otherwisedetined herein shall have the respectivemeanings~cribed thereto in the Asset Purchase Agreement. NOW, THEREFORE, in. consideration of the premises,thle consideration specified in the Asset Purchase. Agreement, the assumption of the Assumed Liabilities pursuant to the Asset Purchase Agreement and other good and valuable consideration, the receipt 'and sufficiency of which are hereby acknowledged,.. Seller herebysells,assigns,transfers,conveys and delivers to Buyer, all oCSeller's right, title and interest in,toand under the Acquired Assets as. the. same shall exist on the date .hereof. EXCEPT ASSPECIFICALL Y SET FORTH INJlIEASSETPURCHASE AGREEMENT OR llf THE ANCILLARY AGREEMENTS, SELLER DOES NOT MAKE ANYREPRESENTATIONORW ARRANTYAS TO ANY. MATTER, EXPRESS OR IMPLIED,INCLUDING ANY EXPRESS OR IMPLIED WARRANTY OF MERCHANTABILITY OR .FITNESS FOR A<PARTICULAR PURPOSE, .WARRANTY . - -, - . AGAINST INFRINGEMENTORANY.OTHERW ARRANTY AS TO THE CONDITION .OR OPERATION or ANY OFTHE A~QUIREDASSETS. VERIZONMEDIA VENTURES INC. By: Name: Title: ..AI>ELPHIA COMMUNICA nONS CORPORATION FCC 394 APPLICATION FOR FRANCHISE AUTHORITY CONSENT TO ASSIGNMENT OR TRANSFER OF CONTROL OF CABLE TELEVISION FRANCHISE March 7, 2002 EXHIBIT 2 (Part II, Q. 2) [Indicate on an attached exhibit any plans to change the current terms and conditions of service and operations of the system as a consequence of the transaction for which approval is sought.] Adelphia does not currently have any plans to change the service and operations of the system, FCC 394 APPLICATION FOR FRANCHISE AUTHORITY CONSENT TO ASSIGNMENT OR TRANSFER OF CONTROL OF CABLE TELEVISION FRANCHISE March 7, 2002 EXHIBIT 3 (Section II, Q. 1) [Section II, TRANSFEREE'S/ASSIGNEE'S LEGAL QUALIFICATIONS. If Other, Describe in an Exhibit.] Assignee is a limited liability company formed in Delaware on August 11, 1998. Its registered agent in Delaware is Corporation Service Company, 2711 Centerville Road, Suite 400, Wilmington, DE 19808. FCC 394 APPLICATION FOR FRANCHISE AUTHORITY CONSENT TO ASSIGNMENT OR TRANSFER OF CONTROL OF CABLE TELEVISION FRANCHISE March 7, 2002 EXHIBIT 4 (Section II, Q. 7) [Do documents, instruments, agreements or understandings for the pledge of stock of the transferee/assignee, as security for loans or contractual performance, provide that; (a) voting rights will remain with the applicant, even in the event of default on the obligation; (b) in the event of default, there will be either a private or public sale of the stock; and (c) prior to the exercise of any ownership rights by a purchaser at a sale described in (b), any prior consent of the FCC and/or of the franchising authority, if required pursuant to federal, state or local law or pursuant to the terms of the franchise agreement will be obtained?] The answer is in the negative because there are no documents, instruments, agreements or understandings for the pledge of Adelphia stock, or the stock of its subsidiaries, as security for loans or contractual performance. FCC 394 APPLICATION FOR FRANCHISE AUTHORITY CONSENT TO ASSIGNMENT OR TRANSFER OF CONTROL OF CABLE TELEVISION FRANCHISE March 7, 2002 EXHIBIT 5 (Section III, Q. 2) [Attach as an Exhibit the most recent financial statements, prepared in accordance with generally accepted accounting principals, including a balance sheet and income statement for at least one full year, for the transferee/assignee or parent entity that have been prepared in the ordinary course of business, if any such financial statements are routinely prepared. Such statements, if not otherwise publicly available, may be marked CONFIDENTIAL and will be maintained as confidential by the franchise authority and its agents to the extent permissible under local law.] Attached are the Form 10-K for 2000 and the Form 10-Q for the third quarter 2001 filed with the Securities and Exchange Commission by Adelphia Communications Corporation,