Appellant tells court the guarantee is a 'stand‑alone' contract limiting Paul's liability

James Ware, counsel for appellant Anthony Paul, told the panel the heart of the dispute is textual: "The guarantee of lease is a stand alone agreement," he said, arguing the guarantee contains the necessary definitions of "tenant" and "lease" and therefore controls the scope of Paul's liability.

Ware warned that excising the preamble definitions would render paragraph 16 and other provisions ambiguous and that inserting extrinsic conditional language would improperly transform an unambiguous contract. He told the bench that if the guarantee is unambiguous, its interpretation is a matter of law and summary judgment was appropriate rather than remand for further factual development.