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Ordinance 2007-041 STAT OF ILLINOIgg COUN�FIIF YNDALL MAY 15 2007 County Clerk Kendall County UNITED CITY OF YORKVILLE ]KENDALL COUNTY STATE OF ILLINOIS �I ORDINANCE NUMBER 2007 -41 AN AMENDED AND RESTATED ORDINANCE PROVIDING FOR ISSUANCE OF UNITED CITY OF YORKVILLE, KENDALL COUNTY, ILLINOIS SPECIAL SERVICE AREA NUMBER 2006 -113 AD VALOREM TAX BONDS, SERIES 2007 (CANNONBALL /BEECHER ROAD PROJECT) ADOPTED BY THE CITY COUNCIL I OF THE UNITED CITY OF YORKVILLE KENDALL COUNTY STATE OF ILLINOIS The 14' day of May, 2007 Published in pamphlet form by authority of the City Council of the United City of Yorkville, Kendall County, Illinois this 14 day of May, 2007. CH 12_715664.2 I LED MAY 15 2007 ORDINANCE NO. 2007-41 County Clerk Kendall County AN AMENDED AND RESTATED ORDINANCE PROVIDING FOR ISSUANCE OF UNITED CITY OF YORKVILLE, ]KENDALL COUNTY, ILLINOIS SPECIAL SERVICE AREA NUMBER 2006 -113 AD VALOREM TAX BONDS, SERIES 2007 (CANNONBALL/BEECHER ROAD PROJECT) BE IT ORDAINED BY THE CITY COUNCIL OF THE UNITED CITY OF YORKVILLE, KENDALL COUNTY, ILLINOIS, AS FOLLOWS: Section 1. Findings and Declarations. It is found and declared by the City Council of the United City of Yorkville, Kendall County, Illinois (the " City ") as follows: a. The City has previously established Special Service Area Number 2006- 113 described more fully in Exhibit A to this Ordinance ' (the "Special Service Area ") pursuant to Ordinance Number 2007 -26 adopted on March 13, 2007 (the "Establishing Ordinance "), the provisions of the Special Service Area Tax Law, 35 ILCS 200/27 -5 et sew., as amended (the "Special Service Area Act ") and the provisions of Section 7 of Article VII of the 1970 Constitution of the State of Illinois, and has otherwise complied with all other conditions precedent required by the Special Service Area Act. b. It is necessary and in the best interests of the City to provide at this time special services benefiting the Special Service Area consisting of the acquisition, construction and installation of public improvements including, but not limited to, engineering, surveying, soil testing and appurtenant work, mass grading and demolition, storm water management facilities, storm drainage systems and storm sewers, site clearing and tree removal, public water facilities, sanitary sewer facilities, erosion control measures, roads, streets, curbs, gutters, street lighting, traffic controls, sidewalks, paths and related street improvements, and equipment and materials necessary for the maintenance thereof, landscaping, wetland mitigation, public park improvements and tree installation, costs for land and easement acquisitions or dedications relating to any of the foregoing improvements, required tap -on and related fees for water or sanitary sewer services and other eligible costs to serve the Special Service Area (the " Special Services "). The City presently estimates the total cost of these Special Services together with costs of borrowing money for that purpose, funding administrative expenses and providing for necessary debt service reserves and capitalized interest (collectively, the "Costs of the Special Services ") to be approximately $15,000,000. C. The City does not have sufficient funds on hand or available from other sources with which to pay the costs of the Special Services. d. It is in the best interests of the City to issue not to exceed $15,000,000 principal amount of its Special Service Area Number 2006 -113 Ad Valorem Tax Bonds, Series 2007 (Cannonball/Beecher Road Project) (the " Bonds ") as provided in this Ordinance, to pay or provide funds for a portion of the Costs of the Special Services. CH12_715664.2 I I e. The borrowing of the sum of not to exceed $15,000,000 and the issuance of the Bonds in that amount are for purposes constituting special services in the Special Service Area under the Special Service Area Act. f. After due publication of a notice as required by the Special Service Area Act, a public hearing to consider the establishment of the Special Service Area, the issuance of the Bonds for the purpose of paying the costs of the Special Services and the manner in which the Bonds are proposed to be retired and the proposed tax levy, was held on October 3, 2006 at 7:00 p.m. No objection petition has been filed with respect to the establishment of the Special Service Area or the issuance of the Bonds within the period of time allowed pursuant to the Special Service Area Act. g. The City previously adopted Ordinance Number 2007 -27 (the " Prior Ordinance ") on March 27, 2007 authorizing the issuance of the Bonds in an amount not to exceed $12,500,000. h. It has become necessary to amend and restate the Prior Ordinance to authorize the issuance of the Bonds in an amount not to exceed $15,000,000. Section 2. Issuance of Bonds. The City shall borrow the sum of not to exceed $15,000,000 by issuing the Bonds as provided in this Ordinance. The Bonds which shall be designated "United City of Yorkville, Kendall County, Illinois Special Service Area Number 2006 -113 Ad Valorem Tax Bonds, Series 2007 (Cannonball /Beecher Road Project)," and shall be issued for the purpose of providing a portion of the funds needed for the Costs of the Special Services. The Bonds shall be issued pursuant to the powers of the City pursuant to Section 7 of Article VII of the 1970 Constitution of the State of Illinois; the Special Service Area Act; and the Local Government Debt Reform Act, 30 ILCS 350/1 et se . (the "Debt Act "). Section 3. Approval of Documents. There have been submitted to the City Council forms of the following documents relating to the issuance of the Bonds: a. a form of Trust Indenture (the "Indenture ") between the City and The Bank of New York Trust Company, N.A., as Trustee, to be dated as of April 1, 2007, which form of Indenture is attached as Exhibit B to this Ordinance; b. a form of Bond Purchase Agreement (the "Bond Purchase Agreement") among the City, William Blair & Company, L.L.C., as Underwriter (the "Underwriter "), and Cannonball LLC (the "Developer ") to be dated as of the date the offer of the Underwriter to purchase the Bonds is accepted by the City, which form of Bond Purchase Agreement is attached as Exhibit C to this Ordinance; C. a form of Development Agreement between the Developer and the City, which form of Development Agreement is attached as Exhibit D to this Ordinance; and d. a form of the preliminary Limited Offering Memorandum (the "Limited Offering Memorandum ") used by the Underwriter in its initial offering of the Bonds, which form of Limited Offering Memorandum is attached as Exhibit E to this Ordinance. 2 CH 12_715664.2 II I Such documents are approved as to form and substance and the Mayor and the City Clerk of the City are authorized and directed to execute and deliver and /or authorize the use of such documents on behalf of the City in the forms submitted with such additions, deletions and completions of the same (including the establishment of the terms of the Bonds within the parameters set forth in this Ordinance) as the Mayor and the City Clerk deem appropriate; and when each such document is executed, attested, sealed and delivered on behalf of the City, as provided herein, each such document will be binding on the City; from and after the execution and delivery of each such document, the officers, employees and agents of the City are hereby authorized, empowered and directed to do all such acts and things and to execute all such additional documents as may be necessary to carry out, comply with and perform the provisions of each such document as executed; and each such document shall constitute, and hereby is made, a part of this Ordinance, and a copy of each such document shall be placed in the official records of the City, and shall be available for public inspection at the office of the City Clerk. Either the Mayor or the City Clerk is authorized and directed, subject to the terms of the Bond Purchase Agreement as executed, to execute the final Limited Offering Memorandum in substantially the form of the preliminary Limited Offering Memorandum presented hereto with such changes, additions or deletions as they deem appropriate to reflect the final terms of the Bonds, the Indenture and other matters. Section 4. Bond Terms. The Bonds shall be issued as provided in the Indenture and shall be issued in the principal amount of not to exceed $15,000,000, shall be dated, shall mature, shall bear interest at the rates (not to exceed in any year seven percent (7 %) per annum) and shall be subject to redemption at the times and prices as set forth in the Indenture, and shall be sold to the Underwriter at a purchase price of not less than 98.5% of the principal amount of the Bonds with an original issue discount of not to exceed 2% of the principal amount of the Bonds, all as set forth in the Bond Purchase Agreement. The execution and delivery of the Bond Purchase Agreement by the Mayor and the City Clerk shall evidence their approval of the terms of the Bonds set forth above. Section 5. Execution and Delivery of Bonds. The Mayor and the City Clerk are authorized and directed to execute and deliver the Bonds and, together with other Authorized Officers (as defined in the Indenture), to take all necessary action with respect to the issuance, sale and delivery of the Bonds, all in accordance with the terms and procedures specified in this Ordinance and the Indenture. The Bonds shall be delivered to the Trustee who is directed to authenticate the Bonds and deliver the Bonds to the Underwriter upon receipt of the purchase price for the Bonds. The Bonds shall be in substantially the form set forth in the Indenture. Each Bond shall be executed by the manual or facsimile signature of the Mayor and the manual or facsimile signature of the City Clerk and shall have the corporate seal of the City affixed to it (or a facsimile of that seal printed on it). The Mayor and the City Clerk (if they have not already done so) are authorized and directed to file with the Illinois Secretary of State their manual signatures certified by them pursuant to the Uniform Facsimile Signatures of Public Officials Act, as amended, which shall authorize the use of their facsimile signatures to execute the Bonds. Each Bond so executed shall be as effective as if manually executed. In case any officer of the City whose signature or a facsimile of whose signature shall appear on the Bonds shall cease to be such officer before authentication and delivery of any of the Bonds, that signature or facsimile 3 CH12_715664.2 I I signature shall nevertheless be valid and sufficient for all purposes, the same as if the officer had remained in office until delivery. I No Bond shall be valid for any purpose unless and until a certificate of authentication on that Bond substantially in the form set forth in the bond form in the Indenture shall have been duly executed by the Trustee. Execution of that certificate upon any Bond shall be conclusive I evidence that the Bond has been authenticated and delivered under this Ordinance. Section 6. Bonds are Limited Obligations; Levy of Ad Valorem Tax; Pledge. The Bonds shall constitute limited obligations of the City, payable from the Ad Valorem Taxes (as defined below) to be levied on all taxable real property within the Special Service Area as provided below. The Bonds shall not constitute the general obligations of the City and neither the full faith and credit nor the unlimited taxing power of the City shall be pledged as security for payment of the Bonds. There are hereby levied Ad Valorem Taxes upon all taxable real property within the Special Service Area sufficient to pay and discharge the principal of and interest on the Bonds at maturity or mandatory sinking fund redemption dates and to pay interest on the Bonds for each year at the interest rates to be set forth in Section 2.3 of the Indenture and to pay for the Administrative Expenses (as defined in the Indenture) of the City and Kendall County, if any, for each year including specifically the following amounts for the following years, in each case to be collected in the next succeeding year (the "Ad Valorem Taxes "): An Amount Sufficient Year of Levy to Produce the Sum of: 2008 $ 856,750.00 2009 951,750.00 2010 961,287.50 2011 1,094,962.50 2012 1,160,587.50 2013 1,206,612.50 2014 1,243,900.00 2015 1,277,737.50 2016 1,298,125.00 2017 1,335,637.50 2018 1,369,125.00 2019 1,393,587.50 2020 1,414,312.50 2021 1,431,300.00 2022 1,454,550.00 2023 1,468,487.50 2024 1,488,400.00 2025 1,518,712.50 2026 4,203,562.50 4 CH 12_715664.2 The City shall take all actions which shall be necessary to provide for the levy, extension, collection and application of the taxes levied by this Ordinance, including enforcement of such taxes as provided by law but only as set forth in Section 7(a) below. The Ad Valorem Taxes levied as provided above shall be deposited in the Debt Service Fund created pursuant to the Indenture and are appropriated to and are irrevocably pledged to and shall be used only for the purposes set forth in Section 4.3 of the Indenture. Section 7. Special Covenants. The City covenants with the holders of the Bonds from time to time outstanding that it (i) will take all actions which are necessary to be taken (and avoid any actions which it is necessary to avoid being taken) so that interest on the Bonds will not be or become included in gross income for federal income tax purposes under existing law, including without limitation the Internal Revenue Code of 1986, as amended (the " Code "); (ii) will take all actions reasonably within its power to take which are necessary to be taken (and avoid taking any actions which are reasonably within its power to avoid taking and which are necessary to avoid) so that the interest on the Bonds will not be or become included in gross income for federal income tax purposes under the federal income tax laws as in effect from time to time; and (iii) will take no action or permit any action in the investment of the proceeds of the Bonds, amounts held under the Indenture or any other funds of the City which would result in making interest on the Bonds subject to federal income taxes by reason of causing the Bonds to be "arbitrage bonds" within the meaning of Section 148 of the Code, or direct or permit any action inconsistent with the regulations under the Code as promulgated and as amended from time to time and as applicable to the Bonds. The Mayor, the City Clerk, the City Treasurer and other Authorized Officers of the City are authorized and directed to take all such actions as are necessary in order to carry out the issuance and delivery of the Bonds including, without limitation, to make any representations and certifications they deem proper pertaining to the use of the proceeds of the Bonds and other moneys held under the Indenture in order to establish that the Bonds shall not constitute arbitrage bonds as so defined. The City further covenants with the holders of the Bonds from time to time outstanding that: a. it will take all actions, if any, which shall be necessary in order further to provide for the levy, extension, collection and application of the Ad Valorem Taxes imposed by or pursuant to this Ordinance; b. it will not take any action which would adversely affect the levy, extension, collection and application of the Ad Valorem Taxes; and C. it will comply with all present and future laws concerning the levy, extension and collection of the Ad Valorem Taxes; in each case so that the City shall be able to pay the principal of and interest on the Bonds as they come due and replenish the Reserve Fund to the Required Reserve and it will take all actions necessary to assure the timely collection of the Ad Valorem Taxes, including without limitation, the enforcement of any delinquent Ad Valorem Taxes as described in paragraph (a) above. 5 CH12_715664.2 Section 8. Additional Authoritv. The Mayor, the City Clerk and the other officers of the City are authorized to execute and deliver on behalf of the City such other documents, agreements and certificates and to do such other things consistent with the terms of this Ordinance as such officers and employees shall deem necessary or appropriate in order to effectuate the intent and purposes of this Ordinance, including, without limitation, to make any representations and certifications they deem proper pertaining to the use of the proceeds of the Bonds in order to establish that the Bonds shall not constitute arbitrage bonds as defined in Section 7 above. Section 9. Filinl7 of Ordinance. The City lerk is directed to file a certified co of Y copy this Ordinance, and an accurate map of the Special Service Area, with the County Clerk of Kendall County. Section 10. Severabilitv. If any section, paragraph, clause or provision of this Ordinance (including any section, paragraph, clause or provision of any exhibit to this Ordinance) shall be held invalid, the invalidity of such section, paragraph, clause or provision shall not affect any of the other sections, paragraphs, clauses or provisions of this Ordinance (or of any of the exhibits to this Ordinance). Section 11. Repealer; Effect of Ordinance. All ordinances, resolutions and orders or parts of ordinances, resolutions and orders in conflict with this Ordinance are repealed to the extent of such conflict. Taxes levied pursuant to the Prior Ordinance are hereby abated in their entirety. The City Clerk shall cause this Ordinance to be published in pamphlet form. This Ordinance is passed as an emergency measure, as it is urgent that this Ordinance become effective to permit the immediate issuance of the Bonds and the use of proceeds of the Bonds to pay expenses which are presently due and payable. Therefore, this Ordinance shall be in full force and effect immediately upon passage and approval, provided it is passed by the affirmative vote of at least two - thirds of the members of the City Council. This Ordinance shall be effective upon its passage and publication as provided by law. PASSED BY THE CITY COUNCIL OF THE UNITED CITY OF YORKVILLE, KENDALL COUNTY, ILLINOIS this 14 day of May, 2007. VOTING AYE: VOTING NAY: --- ABSENT: — ABSTAINED: NOT VOTING: APPROVED: Mayor ATTEST: 6 CH 12_715664.2 i Exhibit A i UNITED CITY OF YORKVILLE SPECIAL SERVICE AREA NUMBER 2006 -113 Leaal Description of Propertv THAT PART OF THE SOUTHEAST QUARTER OF SECTION 19, PART OF THE SOUTH HALF OF SECTION 20 AND PART OF THE NORTHWEST QUARTER OF SECTION 29, TOWNSHIP 37 NORTH, RANGE 7 EAST OF THE THIRD PRINCIPAL MERIDIAN DESCRIBED AS FOLLOWS: BEGINNING AT THE SOUTHEAST CORNER OF THE SOUTHEAST QUARTER OF SAID SECTION 19; THENCE NORTH 01 DEGREES 13 MINUTES 53 SECONDS WEST, ALONG THE EAST LINE OF SAID SOUTHEAST QUARTER 310.20 FEET; THENCE WESTERLY PERPENDICULAR TO SAID EAST LINE 198.00 FEET; THENCE NORTH 16 DEGREES 23 MINUTES 58 SECONDS WEST, 862.81 FEET; THENCE NORTH 46 DEGREES 51 MINUTES 14 SECONDS EAST, 126.15 FEET; THENCE WESTERLY ALONG A NONTANGENTIAL CURVE TO THE RIGHT WITH A RADIUS OF 25.00 FEET AND A CHORD BEARING OF NORTH 86 DEGREES 29 MINUTES 53 SECONDS WEST, AN ARC LENGTH OF 40.71 FEET; THENCE NORTHWESTERLY ALONG A CURVE TO THE RIGHT WITH A RADIUS OF 950.00 FEET AND A CHORD BEARING OF NORTH 30 DEGREES 00 MINUTES 26 SECONDS WEST, AN ARC LENGTH OF 326.41 FEET; THENCE NORTH 67 DEGREES 35 MINUTES 57 SECONDS EAST, 243.73 FEET; THENCE SOUTHEASTERLY ALONG A NONTANGENTIAL CURVE TO THE LEFT WITH A RADIUS OF 500.00 FEET AND A CHORD BEARING OF SOUTH 31 DEGREES 07 MINUTES 50 SECONDS EAST, AN ARC LENGTH OF 209.70 FEET; THENCE SOUTH 43 DEGREES 08 MINUTES 45 SECONDS EAST, 52.80 FEET; THENCE NORTH 46 DEGREES 51 MINUTES 15 SECONDS EAST, 287.40 FEET; THENCE SOUTH 43 DEGREES 08 MINUTES 45 SECONDS EAST, 80.00 FEET; THENCE NORTH 46 DEGREES 51 MINUTES 15 SECONDS EAST, 162.29 FEET; THENCE NORTH 43 DEGREES 08 MINUTES 45 SECONDS WEST, 7.00 FEET; THENCE NORTH 46 DEGREES 51 MINUTES 15 SECONDS EAST, 60.76 FEET; THENCE NORTHEASTERLY ALONG A CURVE TO THE RIGHT WITH A RADIUS OF 367.00 FEET AND A CHORD BEARING OF NORTH 58 DEGREES 18 MINUTES 15 SECONDS EAST, AN ARC LENGTH OF 146.68 FEET; THENCE NORTH 69 DEGREES 45 MINUTES 15 SECONDS EAST, 121.97 FEET; THENCE NORTHEASTERLY ALONG A CURVE TO THE LEFT WITH A RADIUS OF 433.00 FEET AND A CHORD BEARING OF NORTH 37 DEGREES 51 MINUTES 31 SECONDS EAST, AN ARC LENGTH OF 482.09 FEET; THENCE NORTHEASTERLY ALONG A CURVE TO THE RIGHT WITH A RADIUS OF 25.00 FEET AND A CHORD BEARING OF NORTH 51 DEGREES 23 MINUTES 20 SECONDS EAST, AN ARC LENGTH OF 39.64 FEET; THENCE SOUTH 83 DEGREES 11 MINUTES 08 SECONDS EAST, 763.20 FEET; THENCE SOUTHEASTERLY ALONG A CURVE TO THE RIGHT WITH A RADIUS OF 367.00 FEET AND A CHORD BEARING OF SOUTH 57 DEGREES 07 MINUTES 07 SECONDS EAST, AN ARC LENGTH OF 333.94 FEET; THENCE SOUTH 31 DEGREES 03 MINUTES 05 SECONDS EAST, 123.11 FEET; THENCE SOUTH 58 DEGREES 56 MINUTES 55 SECONDS WEST, 7.00 FEET; THENCE SOUTHEASTERLY ALONG A NONTANGENTIAL CURVE TO THE LEFT WITH A CH 12_715664.2 RADIUS OF 440.00 FEET AND A CHORD BEARING OF SOUTH 42 DEGREES 20 MINUTES 40 SECONDS EAST, AN ARC LENGTH OF 173.45 FEET; THENCE NORTH 32 DEGREES O1 MINUTES 21 SECONDS EAST, 80.28 FEET; THENCE SOUTHEASTERLY ALONG A NONTANGENTIAL CURVE TO THE LEFT WITH A RADIUS OF 360.00 FEET AND A CHORD BEARING OF SOUTH 60 DEGREES 42 MINUTES 59 SECONDS EAST, AN ARC LENGTH OF 101.11 FEET; THENCE SOUTH 68 DEGREES 45 MINUTES 32 SECONDS EAST, 784.84 FEET TO THE CENTER LINE OF CANNONBALL TRAIL; THENCE SOUTH 21 DEGREES 40 MINUTES 31 SECONDS WEST, ALONG SAID CENTER LINE, 331.43 FEET; THENCE SOUTH 21 DEGREES 14 MINUTES 17 SECONDS WEST, ALONG SAID CENTER LINE, 1261.58 FEET; THENCE NORTH 68 DEGREES 45 MINUTES 43 SECONDS WEST, 48.00 FEET; THENCE SOUTH 21 DEGREES 14 MINUTES 17 WEST, 470.00 FEET; THENCE SOUTH 57 DEGREES 14 MINUTES 17 SECONDS WEST, 74.81 FEET TO THE NORTH LINE OF U.S. ROUTE 34; THENCE NORTH 85 DEGREES 32 MINUTES 10 SECONDS WEST ALONG SAID NORTH LINE, 1983.32 FEET TO THE WEST LINE OF THE NORTHWEST QUARTER OF SAID SECTION 29; THENCE NORTH O1 DEGREES 14 MINUTES 12 SECONDS WEST ALONG SAID WEST LINE, 378.99 FEET TO THE POINT OF BEGINNING, IN THE UNITED CITY OF YORKVILLE, KENDALL COUNTY, ILLINOIS, AND CONTAINING 143.40 ACRES OF LAND MORE OR LESS. PIN'S 02 -19- 400 -003 02 -29 -100 -001 02-20-351-001 2 CH 12_715664.2 (51 T (lj F &L DRAFT 03/15/07 TRUST INDENTURE Between UNITED CITY OF YORKVILLE, ILLINOIS and THE BANK OF NEW YORK TRUST COMPANY, N.A., as Trustee Dated as of April 1, 2007 UNITED CITY OF YORKVILLE, KENDALL COUNTY, ILLINOIS SPECIAL SERVICE AREA NUMBER 2006 -113 AD VALOREM TAX BONDS, SERIES 2007 (CANNONBALLBEECHER ROAD PROJECT) � CH12_650171.5 TABLE OF CONTENTS Page ARTICLE I DEFINITIONS AND INTERPRETATIONS .............. ............................... 2 Section1.1 Definitions .................................................................... ............................... 2 Section 1.2 Rules of Interpretation ............................................... ............................... 11 ARTICLE II AUTHORIZATION, EXECUTION, AUTHENTICATION, REGISTRATION AND DELIVERY OF BONDS ... ............................... 12 Section 2.1 Authorization of Bonds; Limitation ........................... ............................... 12 Section 2.2 Bonds Limited Obligations ........................................ ............................... 12 Section 2.3 Details of Bonds ......................................................... ............................... 12 Section 2.4 Execution of Bonds .................................................... ............................... 13 Section 2.5 Authentication of Bonds ............................................ ............................... 13 Section 2.6 Form of Bonds ............................................................. .............................13 Section 2.7 Delivery of Bonds ...................................................... ............................... 13 Section 2.8 Registration of Transfer and Exchange of Bonds; Persons Treated asBondholders ........................................................... ............................... 14 Section 2.9 Temporary Bonds ....................................................... ............................... 14 Section 2.10 Mutilated, Lost or Destroyed Bonds .......................... ............................... 15 Section 2.11 Cancellation and Disposition of Bonds ...................... ............................... 15 Section 2.12 Securities Depository Provisions ............................... ..................:............ 15 ARTICLE III REDEMPTION OF BONDS ..................................... ............................... 17 Section 3.1 Redemption Dates and Prices .................................... ............................... 17 Section 3.2 Mandatory Sinking Fund Redemption of Bonds ....... ............................... 17 Section 3.3 Optional Redemption of Bonds ................................. ............................... 17 Section 3.4 Special Mandatory Redemption from Surplus Bond Proceeds ................. 18 Section 3.5 Selection of Bonds for Redemption ........................... ............................... 18 Section 3.6 Notice of Redemption ................................................ ............................... 18 Section 3.7 Purchase at Any Time ................................................ ............................... 19 ARTICLE IV FUNDS AND ACCOUNTS ...................................... ............................... 20 Section 4.1 Creation of Funds; Deposit of Bond Proceeds ........... ............................... 20 Section 4.2 Improvement Fund ..................................................... ............................... 20 Section 4.3 Debt Service Fund ...................................................... ............................... 21 Section 4.4 Reserve Fund ............................................................. ............................... 22 Section 4.5 Revenues to Be Held for All Bondholders, With Certain Exceptions.................................................................. ............................... 23 Section4.6 Rebate Fund ............................................................... ............................... 24 Section 4.7 Administrative Expense Fund .................................... ............................... 24 Section 4.8 Special Redemption Fund .......................................... ............................... 24 Section 4.9 Repayment to the Issuer from Amounts Remaining in Any Funds .......... 24 Section 4.10 Additional Funds and Accounts ................................. ............................... 24 i CH12_650171.5 I ARTICLE V INVESTMENT OR DEPOSIT OF FUNDS .............. ............................... 25 Section 5.1 Deposits and Security Therefor ................................. ............................... 25 Section 5.2 Investment or Deposit of Funds ................................. ............................... 25 Section 5.3 Valuation of Funds ..................................................... ............................... 26 I ARTICLE VI COVENANTS AND AGREEMENTS OF THE ISSUER ....................... 27 Section 6.1 Covenants and Agreements of the Issuer ................... ............................... 27 Section 6.2 Observance and Performance of Covenants, Agreements, Authority and Actions ................................................ ............................... 28 I Section 6.3 Tax Covenants ........................................................... ............................... 28 Section 6.4 Limited Obligations ................................................... ............................... 29 Section 6.5 Levy of Ad Valorem Tax; Abatement ....................... ............................... 30 ARTICLE VII EVENTS OF DEFAULT AND REMEDIES ............ ............................... 30 Section 7.1 Events of Default Defined ......................................... ............................... 30 Section 7.2 Remedies Upon Default ............................................. ............................... 30 Section 7.3 Additional Remedies .................................................. ............................... 31 Section 7.4 Marshaling of Assets .................................................. ............................... 31 Section 7.5 Trustee May File Proofs of Claim ............................. ............................... 32 Section 7.6 Possession of Bonds Not Required ............................ ............................... 32 Section 7.7 Notice and Opportunity to Cure Certain Defaults ..... ............................... 32 Section 7.8 Priority of Payment Following Event of Default ....... ............................... 33 Section 7.9 Bondholders May Direct Proceedings ....................... ............................... 34 Section 7.10 Limitations on Rights of Bondholders ....................... ............................... 34 Section 7.11 Unconditional Right of Bondholder to Receive Payment ......................... 35 Section 7.12 Restoration of Rights and Remedies .......................... ............................... 35 Section 7.13 Rights and Remedies Cumulative .............................. ............................... 35 Section 7.14 Delay or Omission Not Waiver .................................. ............................... 35 Section 7.15 Waiver of Defaults ..................................................... ............................... 35 Section 7.16 Notice of Events of Default ....................................... ............................... 35 ARTICLE VIII THE TRUSTEE ......................................................... ............................... 36 Section 8.1 Duties and Responsibilities of the Trustee ..:.............. ............................... 36 Section 8.2 Certain Rights of the Trustee ..................................... ............................... 37 Section 8.3 Trustee Not Responsible for Recitals ........................ ............................... 39 Section 8.4 Trustee May Own Bonds ........................................... ............................... 39 Section 8.5 Compensation and Expenses of the Trustee .............. ............................... 40 Section 8.6 Qualifications of Trustee ............................................ ............................... 40 Section 8.7 Resignation or Removal of Trustee; Appointment of Successor Trustee........................................................................ ............................... 41 Section 8.8 Acceptance of Appointment by Successor Trustee ... ............................... 41 Section 8.9 Merger, Succession or Consolidation of Trustee ....... ............................... 42 Section 8.10 Notices to Bondholders; Waiver ................................ ............................... 42 ARTICLE IX DISCHARGE AND DEFEASANCE ........................ ............................... 44 Section9.1 Discharge ................................................................... ............................... 44 Section 9.2 Defeasance; Deposit of Funds for Payment of Bonds .............................. 44 ii CH12_650171.5 Section 9.3 Notice of Defeasance ................................................. ............................... 45 ARTICLE X SUPPLEMENTAL INDENTURES AND AMENDMENTS .................. 45 Section 10.1 Supplemental Indentures Without Bondholders' Consent ........................ 45 Section 10.2 Supplemental Indentures Requiring Bondholders' Consent ..................... 46 Section 10.3 Consents of Bondholders and Opinions ..................... ............................... 47 Section 10.4 Notation on Bonds ..................................................... ............................... 47 Section 10.5 Delivery of Counsel's Opinion with Respect to Supplemental Indentures................................................................... ............................... 47 Section 10.6 Effect of Supplemental Indentures ............................. ............................... 48 ARTICLE XI MISCELLANEOUS PROVISIONS .......................... ............................... 48 Section 11.1 Security Agreement; Financing Statements ............... ............................... 48 Section 11.2 Limitation of Rights ................................................... ............................... 48 Section11.3 Severability ................................................................ ............................... 48 Section11.4 Notices ....................................................................... ............................... 49 Section11.5 Holidays ..................................................................... ............................... 49 Section11.6 Counterparts ............................................................... ............................... 50 Section 11.7 Applicable Law .......................................................... ............................... 50 Section 11.8 Limitation of Liability of Officials of the Issuer ....... ............................... 50 Section 11.9 Successors and Assigns .............................................. ............................... 50 Section 11.10 Form of Documents Delivered to Trustee ................. ............................... 50 Section 11.11 Consent of Holders .................................................... ............................... 51 Appendix A — Form of Bond Appendix B — Description of Special Service Area Number 2006 -113 Appendix C — Request for Payment iii CH12 650171.5 TRUST INDENTURE THIS TRUST INDENTURE (the "Indenture ") dated as of April 1, 2007 is made by and between the United City of Yorkville (the " Issuer '), a municipal corporation organized and existing under the laws of the State of Illinois, and The Bank of New York Trust Company, N.A. (the "Trustee "), a national banking association authorized to exercise corporate trust powers: WITNESSETH: WHEREAS, the Issuer has by Ordinance Number 2007- established Special Service Area Number 2006 -113 (the " SSA "); and WHEREAS, the Issuer has by Ordinance Number 2007- (the "Bond Ordinance ") authorized the issuance of its Special Service Area Number 2006 -113 Ad Valorem Tax Bonds, Series 2007 (Cannonball/Beecher Road Project) (the ` Bonds ") in the aggregate principal amount of not to exceed $12,500,000 to finance the construction of special services within the SSA (the "Special Services ") pursuant to the provisions of Article VII; Section 6 of the Illinois constitution and the Special Service Area Tax Law, 35. ILCS 200/27 -5 et seq. (the "Act "); and WHEREAS, the Issuer has determined that, in the issuance and sale of the Bonds, it will be acting to farther the public purposes of the Act; and WHEREAS, all things necessary to make the Bonds, when issued, executed and delivered by the Issuer and authenticated by the Trustee, to the extent required pursuant to this Indenture, the valid, binding and legal limited obligations of the Issuer, and to constitute this Indenture as a valid assignment and pledge of the revenues herein pledged to the payment of the principal of, redemption premium, if any, and interest on the Bonds and a valid assignment and pledge of certain rights of the Issuer has been done and performed, and the creation, execution and delivery of this Indenture, and the execution, issuance and delivery of the Bonds, subject to the terms hereof, have in all respects been duly authorized; NOW, THEREFORE, THIS TRUST INDENTURE WITNESSETH, that to secure the payment of principal of, redemption premium, if any, and interest on the Bonds according to their true intent and meaning, and all other amounts due from time to time under this Indenture, including those due to the Trustee, to secure the performance and observance of all of the covenants, agreements, obligations and conditions contained in the Bonds and in this Indenture, and to declare the terms and conditions upon and subject to which the Bonds are and are intended to be issued, held, secured and enforced and in consideration of the premises and the acceptance by the Trustee of the trusts created herein and of the purchase and acceptance of the Bonds by the Bondholders and for other good and valuable consideration, the receipt of which is acknowledged, the Issuer has executed and delivered this Indenture and absolutely and irrevocably pledges and assigns to the Trustee and to its successors in trust, on the basis set forth herein, and its and their assigns, all right, title and interest of the Issuer in and to the Trust Estate as defined in Article I; TO HAVE AND TO HOLD unto the Trustee and its successors in trust and its and their assigns forever; CH12_650171.5 BUT IN TRUST, NEVERTHELESS, and subject to the provisions hereof, (a) for the equal and proportionate benefit, security and protection of all Bonds, (b) for the enforcement of the payment of the principal of, redemption premium, if any, and interest on the Bonds, and all other amounts due from time to time under this Indenture, including those due to the Trustee, when payable, according to the true intent and meaning thereof and of this Indenture, and (c) to secure the performance and observance of and compliance with the covenants, agreements, obligations, terms and conditions of this Indenture and the Bond Ordinance, in each case, without preference, priority or distinction, as to lien or otherwise except as provided herein, of any one Bond over any other by reason of designation, number, date of the Bonds or of authorization, issuance, sale, execution, authentication, delivery or maturity thereof, or otherwise, so that each Bond and all Bonds shall have the same right, lien and privilege under this Indenture and shall be secured equally and proportionately by this Indenture, it being intended that the lien and security of this Indenture shall take effect from the date hereof, without regard to the date of the actual issue, sale or disposition of the Bonds, as though upon that date all of the Bonds were actually issued, sold and delivered to purchasers for value; provided, however, that, upon satisfaction of and in accordance with the provisions of Article IX, the rights assigned hereby shall cease, determine and be void to the extent described therein; otherwise, such rights shall be and remain in full force and effect; IT IS DECLARED that all Bonds issued under and secured by this Indenture are to be issued, authenticated and delivered, and that all Revenues assigned or pledged hereby are to be dealt with and disposed of under, upon and subject to, the terms, conditions, stipulations, covenants, agreements, obligations, trusts, uses and purposes provided in this Indenture; and the Issuer has agreed and covenanted, and agrees and covenants with the Trustee and with each and all Bondholders, as follows: ARTICLE I DEFINITIONS AND INTERPRETATIONS Section 1.1 Definitions. Unless the context otherwise requires, the terms defined in this Article I shall, for all purposes of this Indenture and of any indenture supplemental hereto, have the meanings herein specified: "Accounting Date" means January 1 of each year, commencing January 1, 2008. "Act" means the Special Service Area Tax Law, 35 ILCS 200/27 -5 et M. "Ad Valorem Tax" or "Ad Valorem Taxes" means the ad valorem property tax or taxes levied by the Issuer on all taxable property within the SSA to pay for the Special Services. 2 CHI2_650171.5 "Administrative Expense Fund" means the Trust Fund so designated which is described in Section 4.7. "Administrative Expense Fund Requirement" means, (1) from the Issue Date though December 31, 2007, $ , (2) for each calendar year beginning on and after January 1, 2008, the Administrative Expense Fund Requirement on December 31 of the previous year plus an amount equal to 3% of such Administrative Expense Fund Requirement on December 31 of the previous year. "Administrative Expenses" means the following actual or reasonably estimated costs permitted in accordance with the Act and directly related to the administration of the SSA and the Bonds as determined by the Issuer or a consultant on its behalf: the costs of computing or abating the Ad Valorem Tax; the costs of collecting the Ad Valorem Tax (whether by the Issuer, the County or otherwise); the costs of remitting the Ad Valorem Tax to the Trustee; the costs of the Trustee and any fiscal agent (including its legal counsel) in the discharge of the duties required of it under this Indenture or any trustee or fiscal agent ,agreement; the costs of any rebate consultant; the costs of the Issuer or its designee in complying with disclosure requirements of applicable federal and state securities laws and of the Act, including, but not limited to, public inquiries regarding the Ad Valorem Tax; and amounts advanced by the Issuer for any other administrative purposes of the SSA; and the reasonable fees of legal counsel of the Issuer incurred in connection with the foregoing. "Attesting Officer" means the Clerk or Assistant Clerk of the Issuer. "Authorized Denomination" means denominations of $100,000 and any integral multiple of $5,000 in excess thereof. "Available Funds" means additional funds of the Issuer available to pay debt service on the Bonds or abate the Ad Valorem Taxes. "Bankruntcv Law" means Title 11 of the United States Code, as it is amended from time to time and any successor to or replacement of such Title and any other applicable federal or state bankruptcy, insolvency or other similar law. "Beneficial Owner" means, for any Bond which is held by a nominee, the beneficial owner of such Bond. " Bond " or " Bonds " means the Issuer's Special Service Area Number 2006 -113 Ad Valorem Tax Bonds, Series 2007 (Cannonball/Beecher Road Project) issued under this Indenture in the aggregate principal amount of $ "Bond Counsel" means, with respect to the Bonds, Foley & Lardner LLP, Chicago, Illinois, or any other firm of attorneys experienced in the matters covered by the opinion selected by the Issuer and acceptable to the Trustee. "Bondholder" or "holder of Bonds" or "Owner of Bonds" means the Person who owns a Bond, provided that, pursuant to Section 2.8, the Person in whose name a Bond is registered in the Bond Register shall be regarded for all purposes as such owner. 3 CH12_650171.5 "Bond Ordinance" means Ordinance Number 2007- authorizing the Bonds. "Bond Register" and "Bond Re6strar" shall have the respective meanings specified in Section 2.8. "Book Entry Bonds" means those Bonds for which a Securities Depository or its nominee is the Bondholder. "Business Day" means any day of the year other than (a) a Saturday or Sunday, (b) any day on which banks located in the City of Chicago, Illinois or the city in which the Office of the Trustee is located are required or authorized by law to remain closed, or (c) any day on which the New York Stock Exchange is closed. "Business District" means the Kendall Marketplace Business District within the Issuer created pursuant to the Business District Act and legally described on Exhibit B to the Business District Revenue Bond Indenture and incorporated by reference therein whose boundaries are coterminous with the SSA. "Business District Act" means the Business District Development and Redevelopment Act, 65 ILCS 5/11 -74.3 et seq. "Business District Revenue Bond Indenture" means the Trust Indenture dated as of January 1, 2007, by and between the Issuer and the Business District Revenue Bond Trustee pursuant to which the Business District Bonds were issued. "Business District Revenue Bond Trustee" means The Bank of New York Trust Company, N.A., and its successors and assigns, as trustee for the Business District Revenue Bonds. "Business District Revenue Bonds" means the Issuer's Business District Revenue Bonds, Series 2007 (Storm Water/Water Improvement Project) in the aggregate principal amount of $ issued by the Issuer to fund all or a portion of certain municipal improvements in the Business District in accordance with the Business District Act. "Business District Sales Tax Account" means the Account created and so designated in Section 5.2 of the Business District Revenue Bond Indenture. "Business District Sales Taxes" means the one -half of one percent (.5 %) Business District Sales Tax levied by the Issuer in the Business District on sales by retailers and servicemen operating in the Business District, and any tax intended to replace the same as enacted by law or ordinance of the Issuer or any governmental authority. "Business District Tax Allocation Fund" means the trust fund created and so designated in Ordinance Number 2006- of the Issuer adopted on December 12, 2006 pursuant to the Business District Act. " Code " means the Internal Revenue Code of 1986, as amended, and the Regulations. 4 CH 12_650171.5 i "Conditional Redemption" means a redemption where the Issuer has stated in the redemption notice to the Trustee that (a) the redemption is conditioned upon deposit of funds or (b) the Issuer has retained the right to rescind the redemption, as further described in Section 3.9. "Costs of the Special Services" or " Costs " means any acquisition or construction cost properly incurred in connection with the Special Services. "Counsel" means an attorney or law firm (who may be counsel for the Issuer), acceptable to the Trustee. "Coun " means Kendall County, Illinois. "Debt Service Fund" means the trust fund so designated which is described in Section 4.3. "Default" means any event which, with the giving of notice or the lapse of time or both, would constitute an Event of Default. "Defeasance Obligations" means noncallable, non - redeemable direct obligations of the United States of America or noncallable obligations which are fully and unconditionally guaranteed by the United States of America. "Deposit" shall have the meaning given to such term in Section 6.5. " Depository Participants" means any Person for which the Securities Depository holds Bonds as securities depository. "Developer" means Cannonball LLC, an Illinois limited liability company, and its successors and assigns. "Developer's Counsel" means the lawyer or law firm retained from time to time to represent the Developer in connection with the development of property within the SSA. "Development Agreement" means the Development Agreement dated as of , 2007 between the Issuer and the Developer, as the same may be amended, modified, amended and restated, and supplemented from time to time. " shall have the meaning given to such term in Section 2.12. "Eligible Investments" means, to the extent permitted by then applicable Illinois law, the following: (a) Governmental Obligations; (b) bonds, notes, debentures, or other similar obligations of the United States of America or its agencies, including (i) federal land banks, federal intermediate credit banks, banks for cooperative, federal farm credit banks, or any other entity authorized to issue debt obligations under the Farm Credit Act of 1971 (12 U.S.C. 2001 et. seq.); (ii) 5 CH12_650171.5 the federal home loan banks and the federal home loan mortgage corporation; and (iii) any other agency created by Act of Congress; ) (c) interest bearing obligations of any county, township, city, town, incorporated town, municipal corporation or school district, which obligations are registered in the name of the Issuer or held under a custodial agreement at a bank, if such obligations at the time of purchase are in one of the two highest general classifications established by a rating service of nationally recognized expertise in rating bonds of states and their political subdivisions; (d) interest bearing certificates of deposit, interest bearing savings or money market accounts, interest bearing time deposits, or other investments constituting direct obligations of any bank as defined by the Illinois Banking Act which are insured by the Federal Deposit Insurance Corporation; or which are with a bank rated in the highest short-term rating category established by a national recognized rating service; (e) repurchase agreements of government securities which are subject to the Government Securities Act of 1986. The government securities, unless registered or inscribed in the name of the Issuer, shall be purchased through banks or trust companies authorized to do business in the State of Illinois; (f) repurchase agreements (other than those described in clause (e) of the definition of "Eligible Investments ") meeting the following requirements: (1) the securities, unless registered or inscribed in the name of the Trustee, are purchased through banks or trust companies authorized to do business in the State of Illinois; (2) an Authorized Officer after ascertaining which firm will give the most favorable rate of interest, directs the custodial bank to "purchase "' specified securities from a designated institution. The "custodial bank" is the bank or trust company, or agency of government, which acts for the Trustee in connection with repurchase agreements involving the investment of funds by the Trustee. The State Treasurer may act as custodial bank for the Trustee; (3) a custodial bank must be a member bank of the Federal Reserve System or maintain accounts with member banks. All transfers of book -entry securities must be accomplished on a Reserve Bank's computer records through a member bank of the Federal Reserve System. These securities must be credited to the Trustee on the records of the custodial bank and the transaction must be confirmed in writing to the Trustee by the custodial bank; (4) trading partners shall be limited to banks or trust companies authorized to do business in the State of Illinois or to registered primary reporting dealers; (5) the security interest must be perfected; 6 CHI2_650171.5 (6) the Trustee must enter into a written master repurchase agreement which outlines the basic responsibilities and liabilities of both buyer and seller; (7) the repurchase agreement shall be for periods of 330 days or less; I (8) the Trustee Representative must inform the custodial bank in writing of the maturity details of the repurchase agreement; (9) the custodial bank must take delivery of and maintain the securities in its custody for the account of the Trustee and confirm the transaction in writing to the Trustee. The Custodial Undertaking shall provide that the custodian takes possession of the securities exclusively for the Trustee; that the securities are free of any claims against the trading partner; and any claims by the custodian are subordinate to the Trustee's claims to rights to those securities; (10) the obligations purchased by the Trustee may only be sold or presented for redemption or payment by the fiscal agent bank or trust company holding the obligations upon the written instruction of the Trustee or Trustee Representative; and (11) the custodial bank shall be liable to the Trustee for any monetary loss suffered by the Trustee due to the failure of the custodial bank to take and maintain possession of such securities; (g) short-term obligations of corporations organized in the United States with assets exceeding $500,000,000 if (i) such obligations are rated at the time of purchase in one of the three highest rating categories by at least two standard rating services and which mature not later than 180 days from the date of purchase, (ii) such purchases do not exceed 10% of the corporation's outstanding obligations and (iii) no more than one- third of the Issuer's funds are invested in short-term obligations of such corporation as evidenced by a certificate from an Issuer Representative; and (h) money market mutual funds registered under the Investment Company Act of 1940 as amended invested solely in obligations listed in paragraph (a) and (b) above and in agreements to repurchase such obligations, including those for which the Trustee or an affiliate performs services for a fee, whether as a custodian, transfer agent, investment advisor or otherwise.; together with such other investments as shall from time to time be lawful for the investment of Issuer funds and shall be approved by the holders of fifty -one percent (51 %) of aggregate principal amount of Bonds outstanding; provided that `Eligible Investments" shall not include a financial instrument, commonly known as a "derivative," whose performance is derived, at least in part, from the performance of any underlying asset, including, without limitation, futures, options on securities, options on futures, forward contracts, swap agreements, structured notes and participations in pools of mortgages or other assets. 7 CH12_650171.5 II "Event of Bankruptcy" means the filing of a petition in bankruptcy (or other commencement of a bankruptcy or similar proceedings) by or against the Issuer, as debtor, under Bankruptcy Law. "Event of Default" means any of the events specified in Section 7.1 to be an Event of Default. "Excess Business District Sales Taxes" means (i) so long as the Business District i Revenue Bonds remain outstanding, the Business District Sales Taxes remaining on deposit in the Business District Sales Tax Account on December 1 of each year after payment pursuant to Section 5.3 of the Business District Revenue Bond Indenture of debt service on the Business District Revenue Bonds, administrative expenses and a debt service reserve requirement relating to the Business District Revenue Bonds, but in no event more than the amount, together with Available Funds, necessary to fully abate the Ad Valorem Taxes for the following year and (ii) after the Business District Revenue Bonds are retired or defeased, and so long as the Bonds remain outstanding, the Business District Sales Taxes, if any, but in no event more than the amount, together with Available Funds, necessary to fully abate the Ad Valorem Taxes for the following year. "Executive" means the Mayor of the Issuer. " Funds " means the Improvement Fund, the Debt Service Fund, the Reserve Fund, the Administrative Expense Fund and the Rebate Fund, and (a) any account within each such Fund, and (b) any other Fund designated as such with respect to the Bonds. 3 "Governmental Obligations" means (a) noncallable, non - redeemable direct obligations of the United States of America, (b) obligations the timely payment of the principal of, and interest on which, is fully and unconditionally guaranteed by the United States of America, and (c) securities or receipts evidencing ownership interests in obligations or specified portions (such as principal or interest) of obligations described in (a) or (b). "Immediate Notice" means notice transmitted by electronic means, in writing, by telecopy or other electronic means or by telephone (promptly confirmed in writing), and received by the party addressed. "Improvement Fund" means the trust fund so designated which is described in Section 4.2. "Indenture" means this Trust Indenture as amended or supplemented from time to time. "Interest Pavment Date" means, (a) for the Bonds, the first day of March and September of each year beginning March 1, 2008, (b) for Bonds subject to redemption in whole or in part on any date, the date of such redemption, and (c) for all Bonds any date determined pursuant to Section 7.8. "Issuance Costs" means costs incurred by or on behalf of the Issuer including, without limitation, the following: payment of financial, legal, accounting, consultant and appraisal fees, expenses and disbursements; the Issuer's fees and expenses attributable to the issuance of the 8 CH12_650171.5 Bonds; the cost of printing, engraving and reproduction services; legal fees and expenses for Bond Counsel, Issuer's counsel, Trustee's counsel, Developer's Counsel and Underwriter's counsel relating to the issuance of the Bonds; the initial or acceptance fee of the Trustee; and all other fees, charges and expenses incurred in connection with the issuance of the Bonds and the preparation and filing or recording of this Indenture and of any document relating to the issuance of the Bonds. "Issue Date" means the date of issuance and delivery of the Bonds to the Original Purchaser. " Issuer " means the United City of Yorkville, Illinois and its successors and assigns. "Issuer Representative" means the Executive or the Attesting Officer. "Legislative Authority" means the City Council of the Issuer. "Letter of Representations" means when all the Bonds are Book Entry Bonds, the Blanket Letter of Representations previously executed by the Issuer and delivered to the Securities Depository and any amendments thereto or successor blanket agreements between the Issuer and any successor Securities Depository, relating to a system of Book Entry Bonds to be maintained by the Securities Depository with respect to any bonds, notes or other obligations issued by the Issuer. "Office of anv Paving Agent" means the office of any Paying Agent designated in writing to the Trustee. "Office of the Trustee" means the designated corporate trust office or offices of the Trustee, which office or offices at the date of acceptance by the Trustee of the duties and obligations imposed on the Trustee by this Indenture are set out in Section 11.4. "Officer's Certificate of the Issuer" means a written certificate, statement, request, direction or order signed in the name of the Issuer by its Executive, Attesting Officer, an Issuer Representative, or such other person as may be designated and authorized in writing to sign for the Issuer and forwarded to the Trustee. "Original Purchaser" means William Blair & Company, L.L.C. "Outstanding," in connection with Bonds means, as of the date in question, all Bonds authenticated and delivered under this Indenture, except: (a) Bonds theretofore cancelled or delivered to the Trustee for cancellation under Section 2.11; (b) Bonds which are deemed to be no longer Outstanding in accordance with Article IX; and (c) Bonds in substitution for which other Bonds have been authenticated and delivered pursuant to Article II. 9 CH12_650171.5 "Paving Agent" or "Co- Paving Agent" means any national banking association, state bank, bank and trust company or trust company appointed by the Issuer and meeting the qualifications of, and subject to the obligations of, the Trustee in Article VIII. Initially, the Trustee shall be the Paying Agent. " Person " or " verso n " means an individual, corporation, firm, association, partnership, j limited liability company, trust, or other legal entity or group of entities, including a governmental entity or any agency or political subdivision thereof. "Rating Service" means any nationally recognized securities rating service that shall have assigned a rating that is then in effect with respect to the Bonds upon application of the Issuer. "Rebate Amount" has the meaning ascribed in Section 1.148 -3(b) of the Regulations and generally means the excess as of any date of the future value of all receipts on non purpose investments over the future value of all payments on nonpurpose investments all as determined in accordance with Section 1.148 -3 of the Regulations. "Rebate Fund" means the fund so designated which is described in Section 4.6. "Record Date" means, (1) in the case of Bonds which are not Book Entry Bonds the Trustee's close of business on the 15th day of the calendar month next preceding the Interest Payment Date, regardless of whether such day is a Business Day, and (2) in the case of Book Entry Bonds the Trustee's close of business on the Business Day preceding the Interest Payment Date. "Regulations" means any applicable Internal Revenue Service Regulations promulgated in proposed, temporary or final form. Proposed regulations are "applicable" only if, in the event they are adopted in final form, such regulations would apply to the Bonds. "Reauired Reserve" means an amount equal to $ "Reporting Period" means the period of time covered by a report of the sales taxes in the Business District. "Reserve Fund" means the trust fund so designated which is described in Section 4.4. "Responsible Officer," when used with respect to the Trustee, means any officer in the corporate trust department (or any successor thereto) of the Trustee, or any other officer or representative of the Trustee customarily performing functions similar to those performed by any of such officers and also means, with respect to a particular corporate trust matter, any other officer of the Trustee to whom such matter is referred because of that officer's knowledge of and familiarity with the particular subject. "Revenues" means (a) the Ad Valorem Taxes as and when received by the Issuer, (b) Excess Business District Sales Taxes, (c) Available Funds, and (d) investment income with respect to any moneys held by the Trustee in the Improvement Fund, the Debt Service Fund, the Reserve Fund and the Administrative Expense Fund. The term "Revenues" does not include any moneys or investments or investment income in the Rebate Fund. 10 CHI2_650171.5 "Securities Depositorv" means a person that is registered as a clearing agency under Section 17A of the Securities Exchange Act of 1934 or whose business is confined to the performance of the functions of a clearing agency with respect to exempted securities, as defined in Section 3(a)(12) of such Act for the purposes of Section 17A thereof. "Special Redemption Fund" means the trust fund so designated which is described in Section 4.8. "Special Services" means the improvements benefiting the SSA consisting of engineering, soil testing and appurtenant work, mass grading and demolition, storm water management facilities, storm drainage systems and storm sewers, site clearing and tree removal, public water facilities, sanitary sewer facilities, erosion control measures, roads, streets, curbs, gutters, street lighting, signalization, bicycle paths, sidewalks and related street improvements, and equipment and materials necessary for the maintenance thereof, landscaping and tree installation, costs for land and easement acquisitions relating to any of the foregoing improvements, other eligible costs of improvements to serve the SSA and reimbursement of eligible costs incurred prior to the issuance of the Bonds. " means the Issuer's Special Service Area Number 2006 -113 as described in Appendix B. " State " means the State of Illinois. "Trust Estate" means all right, title and interest of the Issuer in and to (a) Revenues, (b) Funds (except for the Rebate Fund) and all money and investments therein, and (c) all other property of every name and nature from time to time hereafter by delivery or by writing mortgaged, pledged, delivered or hypothecated as and for additional security under this Indenture by the Issuer or by anyone on its behalf or with its written consent in favor of the Trustee. " Trustee " means The Bank of New York Trust Company, N.A., a national banking association and any successor trustee under this Indenture, acting in its trust capacity. Section 1.2 Rules of Interpretation. For purposes of this Indenture, except as otherwise expressly provided or the context otherwise requires: (a) The words "herein," "hereof' and "hereunder" and other similar words refer to this Indenture as a whole and not to any particular Article, Section or other subdivision. (b) The definitions in this Article are applicable whether the terms defined are used in the singular or the plural. (c) All accounting terms which are not defined in this Indenture have the meanings assigned to them in accordance with then applicable generally accepted accounting principles. (d) Any pronouns used in this Indenture include both the singular and the plural and cover both genders. 11 CH12_650171.5 (e) Any terms not defined in this Indenture but which are defined in the Bond Ordinance have the same meaning in this Indenture as are given to them in the Bond Ordinance. (f) Any terms defined elsewhere in this Indenture have the meanings attributed to them where defined. (g) Words referring to the redemption or calling for redemption of Bonds shall not be deemed to refer to the payment of Bonds at their stated maturity. i (h) The captions or headings herein are for convenience only and in no way define, limit or describe the scope or intent, or control or affect the meaning or construction, of any provisions or sections hereof. (i) Any references to Section numbers are to Sections of this Indenture unless stated otherwise. ARTICLE II AUTHORIZATION, EXECUTION, AUTHENTICATION, REGISTRATION AND DELIVERY OF BONDS Section 2.1 Authorization of Bonds: Limitation. The Bonds are hereby authorized to be issued in the aggregate principal amount of $ designated "Special Service Area Number 2006 -113 Ad Valorem Tax Bonds, Series 2007 (Cannonball/Beecher Road Proiect)." Section 2.2 Bonds Limited Obligations. The Bonds shall be limited obligations of the Issuer, payable solely from the Trust Estate. The Bonds shall constitute a valid claim of the respective owners thereof against the Trust Estate, which is pledged to secure the payment of the principal of, redemption premium, if any, and interest on the Bonds, and which shall be utilized for no other purpose, except as expressly authorized in this Indenture. The Bonds shall not constitute general obligations of the Issuer and under no circumstances shall the Bonds be payable from, nor shall the holders thereof have any rightful claim to, any income, revenues, funds or assets of the Issuer other than those pledged hereunder as security for the payment of the Bonds. Section 2.3 Details of Bonds. The Bonds shall be issued in Authorized Denominations, shall be dated the date of delivery thereof, shall be numbered from R -1 upward, and shall bear interest (calculated on the basis of a 360 -day year of twelve 30 -day months) payable on September 1, 2007, and thereafter on each Interest Payment Date at the rate per annum and shall mature on March 1, 2028 as follows: Amount Rate $ All Bonds shall bear interest (a) from the Issue Date, if authenticated prior to the first Interest Payment Date, or (b) otherwise from the Interest Payment Date that is, or that 12 CH12_650171.5 immediately precedes, the date on which such Bond is authenticated (unless payment of interest is in default, in which case such Bond shall bear interest from the date to which interest has been paid). The principal of, redemption premium, if any, and interest on the Bonds shall be payable in lawful money of the United States of America. Principal of and redemption premium, if any, on the Bonds shall be payable by the Paying Agent upon presentation and surrender of the Bonds as they become due at the corporate trust office of the Paying Agent. Interest on the Bonds shall be payable by the Paying Agent to the Bondholders of Bonds by check or draft mailed to such Bondholders at their addresses as they appear on the Bond Register on the Record Date. Principal of, redemption premium, if any, and interest payable to any person holding Bonds in aggregate principal amount of $1,000,000 or more will be paid, upon the written request of any such Bondholder in form and substance satisfactory to the Paying Agent, by wire transfer of immediately available funds to an account within the United States of America designated by such Bondholder on or before the Record Date. If any principal of, redemption premium, if any, or interest on any Bond is not paid when due (whether at maturity, by acceleration or call for redemption or otherwise), then the overdue installments of principal and, to the extent permitted by law, interest and redemption premium, if any, shall bear interest until paid at the same rate set forth in such Initial Bond. Section 2.4 Execution of Bonds. The Bonds shall be signed by the manual or facsimile signature of the Executive of the Issuer and attested by the manual or facsimile signature of the Attesting Officer of the Issuer. The Bonds shall bear the seal of the Issuer or a facsimile thereof will be affixed to or imprinted on the Bonds. In case any officer whose signature or a facsimile of whose signature shall appear on any Bond shall cease to be such officer before the delivery of such Bond, such signature or facsimile shall nevertheless be valid and sufficient for all purposes as if such officer had remained in office until such delivery. Section 2.5 Authentication of Bonds. The Bonds shall bear a certificate of authentication, substantially in the form set forth in Appendix A. duly executed by the Trustee. The Trustee shall authenticate each Bond with the manual signature of a Responsible Officer of the Trustee, but it shall not be necessary for the same Responsible Officer to authenticate all of the Bonds. Only such authenticated Bonds shall be entitled to any right or benefit under this Indenture. Such certificate on any Bond issued hereunder shall be conclusive evidence that the Bond has been duly issued and is secured by the provisions hereof. Section 2.6 Form of Bonds. The Bonds shall be substantially in the form set forth in Appendix A with such appropriate variations, legends, omissions and insertions as permitted or required by this Indenture. Section 2.7 Delivery of Bonds. The Trustee shall authenticate and deliver the Bonds when there have been filed with it the following: (a) A copy certified by the Attesting Officer of the Issuer of the Bond Ordinance authorizing (1) the execution and delivery of this Indenture, and (2) the issuance, sale, execution and delivery of the Bonds; 13 CH12_650171.5 (b) An original executed counterpart of this Indenture; ?1 (c) An opinion or opinions of Bond Counsel, addressed to the Issuer and the Trustee, to the effect that this Indenture and the Bonds have each been validly authorized, are binding and enforceable against the Issuer, subject to bankruptcy and equitable principles, that the issuance of the Bonds has been duly authorized and that interest on the Bonds is not included in gross income for federal income tax purposes under the Code; and (d) A request and authorization of the Issuer, signed by its Executive, to the Trustee to authenticate and deliver the Bonds to such person or persons named therein upon payment for the account of the Issuer of a specified sum plus accrued interest to the date of delivery. Section 2.8 Re1?istration of Transfer and Exchanee of Bonds; - Persons Treated as Bondholders. The Trustee shall act as initial bond registrar (the "Bond Rep-istrar ") and in such capacity shall maintain a bond register (the "Bond Re>ister") for the registration and transfer of Bonds. Upon surrender of any Bonds at the Office of the Trustee, together with an assignment duly executed by the current Bondholder of such Bonds or such Bondholder's duly authorized attorney or legal representative in such form as shall be satisfactory to the Trustee, such Bonds may, at the option of the Bondholder, be exchanged for an equal aggregate principal amount of Bonds of the same maturity, of Authorized Denominations and bearing interest at the same rate and in the same form as the Bonds surrendered for exchange, registered in the name or names requested by the assignee of the then Bondholder; provided the Trustee is not required to exchange or register the transfer of Bonds after the giving of notice calling such Bond for redemption, in whole or in part. The Issuer shall execute and the Trustee shall authenticate any Bonds whose execution and authentication is necessary to provide for exchange of Bonds pursuant to this Section and the Issuer may rely on a representation from the Trustee that such execution is required. Any exchange or registration of transfer of Bonds shall be at the expense of the Issuer except that the Trustee may make a charge to any Bondholder requesting such exchange or registration in the amount of any tax or other governmental charge required to be paid with respect thereto but will not impose any other charge. Prior to due presentment for registration of transfer of any Bond, the Trustee shall treat the Person shown on the Bond Register as owning a Bond as the Bondholder and the Person exclusively entitled to payment of principal thereof, redemption premium, if any, and interest thereon and, except as otherwise expressly provided herein, the exercise of all other rights and powers of the owner thereof, and neither the Issuer, the Trustee nor any agent of the Issuer or the Trustee shall be affected by notice to the contrary. Section 2.9 Temporary Bonds. Prior to the preparation of definitive Bonds, the Issuer may issue temporary Bonds in registered form and in such denominations as the Issuer may determine but otherwise in substantially the form provided for definitive Bonds with appropriate variations, omissions and insertions. The Issuer shall promptly prepare, execute and deliver to the Trustee before the first Interest Payment Date for such Bonds, definitive Bonds and, upon 14 CH12_650171.5 presentation and surrender of Bonds in temporary form, the Trustee shall authenticate and deliver in exchange therefor definitive Bonds the same maturity for the same aggregate principal amount. Until exchanged for definitive Bonds, Bonds in temporary form shall be entitled to the lien and benefit of this Indenture. Section 2.10 Mutilated, Lost or Destroyed Bonds. If any Bond has been mutilated, lost or destroyed, the Issuer shall execute, and the Trustee shall authenticate and deliver to the Bondholder, a new Bond of like date and tenor in exchange and substitution for, and upon cancellation of, such mutilated Bond or in lieu of and in substitution for such lost or destroyed Bond but only if the Bondholder has paid the reasonable expenses and charges of the Issuer and the Trustee in connection therewith and, in the case of a lost or destroyed Bond, (a) filed with the Trustee evidence satisfactory to the Trustee that such Bond was lost or destroyed and (b) furnished to the Trustee and the Issuer indemnity satisfactory to each. If any such Bond has matured or been called for redemption and is payable, instead of issuing a new Bond the Trustee may pay the same without issuing a replacement Bond. If, after the delivery of such replacement Bond, the original Bond in lieu of which such replacement Bond was issued is presented for payment or registration, the Trustee shall seek to recover such replacement Bond from the person to whom it was delivered or any person taking therefrom and shall be entitled to recover from the security or indemnity provided there for to the extent of any loss, damage, cost or expense incurred by the Trustee or the Issuer in connection therewith. Section 2.11 Cancellation and Disposition of Bonds. The Issuer may deliver Bonds to the Trustee for cancellation at any time and for any reason and the Trustee is hereby authorized to cancel such Bonds. All Bonds that have been paid (whether at maturity or by acceleration, upon redemption or pursuant to Section 3.10) or delivered to the Trustee for cancellation shall not be reissued. Unless otherwise directed by the Issuer, the Trustee shall treat such Bonds in accordance with its document retention policies or as may be directed by state law. Section 2.12 Securities Depository Provisions. All Bonds shall be Book Entry Bonds. All Book Entry Bonds shall be registered in the name of Cede & Co., as nominee of The Depository Trust Company ( " DTC "). The Issuer and the Trustee acknowledge that they have executed and delivered a Letter of Representations to DTC. All payments of principal of, redemption premium, if any, and interest on the Book Entry Bonds and all notices with respect thereto, including notices of full or partial redemption, shall be made and given at the times and in the manner set out in the Letter of Representations. The terms and provisions of the Letter of Representations shall govern in the event of any inconsistency between the provisions of this Indenture and the Letter of Representations. The Letter of Representations may be amended without Bondholder consent. The book -entry registration system for all of the Book Entry Bonds may be terminated and certificates delivered to and registered in the name of the Beneficial Owners, under either of the following circumstances: (a) DTC notifies the Issuer and the Trustee that it is no longer willing or able to act as Securities Depository for the Book Entry Bonds and a successor Securities 15 CH12_650171.5 Depository for the Book Entry Bonds is not appointed by the Issuer at the direction of the Issuer prior to the effective date of such discontinuation; or 1 i (b) The Issuer determines that continuation of the book -entry system through DTC (or a successor securities depository) is not in the best interest of the Owners of the Book Entry Bonds. In the event a successor Securities Depository is appointed by the Issuer, the Book Entry Bonds will. be registered in the name of such successor Securities Depository or its nominee. In the event certificates are required to be issued to Beneficial Owners, the Trustee and the Issuer shall be fully protected in relying upon a certificate of DTC or any DTC participant as to the identity of and the principal amount of Book Entry Bonds held by such Beneficial Owners. The Beneficial Owners of Bonds will not receive h sical delivery of certificates exce t p Y rY P as provided herein. For so long as there is a Securities Depository for Bonds, all of such Bonds shall be registered in the name of the nominee of the Securities Depository, all transfers of beneficial ownership interests in such Bonds will be made in accordance with the rules of the Securities Depository, and no investor or other parry purchasing, selling or otherwise transferring beneficial ownership of such Bonds is to receive, hold or deliver any certificate. The Issuer and the Trustee shall have no responsibility or liability for transfers of beneficial ownership interests in such Bonds. The Issuer and the Trustee will recognize the Securities Depository or its nominee as the Bondholder of Book Entry Bonds for all purposes, including receipt of payments, notices and voting; provided the Trustee may recognize votes by or on behalf of Beneficial Owners as if such votes were made by Bondholders of a related portion of the Bonds when such votes are received incompliance with an omnibus proxy of the Securities Depository or otherwise pursuant to the rules of the Securities Depository or the provisions of the Letter of Representations or other comparable evidence delivered to the Trustee by the Bondholders or as provided in Sections 8.10 and 11.11 of this Indenture. With respect to Book Entry Bonds, the Issuer and the Trustee shall be entitled to treat the Person in whose name such Bond is registered as the absolute owner of such Bond for all purposes of this Indenture, and neither the Issuer nor the Trustee shall have any responsibility or obligation to any Beneficial Owner of such Book Entry Bond. Without limiting the immediately preceding sentence, neither the Issuer nor the Trustee shall have any responsibility or obligation with respect to (a) the accuracy of the records of any Securities Depository or any other Person with respect to any ownership interest in Book Entry Bonds, (b) the delivery to any Person, other than a Bondholder, of any notice with respect to Book Entry Bonds, including any notice of redemption or refunding, (c) the selection of the particular Bonds or portions thereof to be redeemed or refunded in the event of a partial redemption or refunding of part of the Bonds Outstanding or (d) the payment to any Person, other than a Bondholder, of any amount with respect to the principal of, redemption premium, if any, or interest on Book Entry Bonds. i 16 CH 12_650171.5 i I ARTICLE III REDEMPTION OF BONDS Section 3.1 Redemption Dates and Prices. The Bonds may not be called for redemption by the. Issuer except as provided in this Article III. Section 3.2 Mandatory Sinkina Fund Redemption of Bonds. The Trustee shall redeem Bonds on March 1 in the years and in the principal amounts and at a price of 100% of the principal amount of the Bonds to be redeemed plus interest accrued to the redemption date, as follows: Year Maturity Amount Year Maturitv Amount When such Bonds have been redeemed as set out above, the balance of $ will mature on March 1, , unless otherwise previously retired. On or before the thirtieth (30th) day prior to each such sinking fund redemption date, the Trustee shall proceed to call the principal amount of the Bonds indicated above for redemption on the next March 1, and give notice of such call. At its option, to be exercised by delivery of an Officer's Certificate of the Issuer to the Trustee not more than 360 days nor less than 65 days preceding the applicable sinking fund redemption date, the Issuer may (a) deliver to the Trustee for cancellation, Bonds of the applicable maturity date subject to redemption pursuant to the terms of the mandatory sinking fund provided in this Section in an aggregate principal amount desired or (b) receive credit in respect of its sinking fund redemption obligation for any Bonds of the applicable maturity date subject to redemption pursuant to the terms of the mandatory sinking fund provided in this Section, which prior to said date have been canceled (otherwise than through the operation of the sinking fund redemption schedule) by the Trustee and not theretofore applied as a credit against such sinking fund redemption obligation. Each Initial Bond of the applicable maturity date so delivered or previously redeemed shall be credited by the Trustee at the principal amount thereof against the obligation of the Issuer on such sinking fund redemption date, and the principal amount of Bonds to be redeemed by operation of such sinking fund redemption schedule on such date shall be accordingly reduced; and any excess over the principal amount of Bonds to be redeemed by operation of the sinking fiend redemption schedule on any sinking fiord redemption date shall be credited as specified in a certificate of the Issuer or, in the absence of such certificate against the next scheduled sinking fluid redemption. Section 3.3 Optional Redemption of Bonds. The Bonds are subject to redemption by the Issuer on or after March 1, 2017, in whole or in part at any time from any moneys that may be available for such purpose, upon payment of the following redemption prices (expressed as a percentage of principal amount of Bonds to be redeemed) plus interest accrued to the redemption date: 17 CHI2_650171.5 102% if redeemed on March 1, 2017 and thereafter through February 28, 2018; 101% if redeemed on March 1, 2018 and thereafter through February 28, 2019; and ) 100% if redeemed on March 1, 2019 and thereafter prior to maturity. Section 3.4 Special Mandatory Redemption from Surplus Bond Proceeds. To the extent that moneys are transferred from the Improvement Fund to the Debt Service Fund pursuant to Section 4.2(c) for purposes of redeeming the Bonds, the Bonds are subject to special mandatory redemption in part in Authorized Denominations on the next scheduled Interest Payment Date at a redemption price equal to 100% of the aggregate principal amount of the Bonds to be redeemed lus accrued interest to the redemption date. p p Section 3.5 Selection of Bonds for Redemption. If less than all of the Bonds are called for redemption pursuant to Sections 3.3 or 3.4, they shall be redeemed in inverse order of maturity and in inverse order of sinking fund installments within any maturity (provided, however, that if an Event of Default has occurred and is continuing any Bonds called for redemption shall be redeemed in proportion by maturity and within, maturities in inverse order of sinking fund installments), subject to selection by the Trustee as provided below. The portion of any Bond to be redeemed shall be an Authorized Denomination or any multiple thereof and in selecting Bonds for redemption, each Bond shall be considered as representing that number of Bonds which is obtained by dividing the principal amount of such Bond by the minimum Authorized Denomination. If a portion of a Bond shall be called for redemption, a new Bond in principal amount equal to the unredeemed portion thereof shall be issued to the Bondholder upon the surrender thereof. If for any reason the principal amount of Bonds called for redemption would result in a redemption of Bonds less than the Authorized Denomination, the Trustee, to the extent possible within the principal amount of Bonds to be redeemed, is hereby authorized to adjust the selection of Bonds for such purpose in order to minimize any such redemption. Notwithstanding the foregoing, the Securities Depository for Book Entry Bonds shall select the Bonds for redemption within particular maturities according to its stated procedures. Section 3.6 Notice of Redemption. (a) When Bonds (or portions thereof) are to be redeemed pursuant to Section 3.3 the Issuer shall give or cause to be given notice of the redemption of the Bonds to the Trustee no later than forty-five (45) days prior to the redemption date or such shorter time as may be acceptable to the Trustee. The notice may state (1) that it is conditioned upon the deposit of moneys, in an amount equal to the amount necessary to effect the redemption, with the Trustee no later than the date that is five (5) Business Days prior to the redemption date or (2) that the Issuer retains the right to rescind such notice on or prior to the scheduled redemption date (in either case, a "Conditional Redemption "), and such notice and optional redemption shall be of no effect if such moneys are not so deposited or if the notice is rescinded as described in subsection (d) of this Section. The Trustee, at the expense of the Issuer, shall send notice of any redemption, identifying the Bonds or portions thereof to be redeemed, the redemption date and the method and place of payment and the information required by subsection (b) of this Section, by first class mail to each holder of a Bond called for redemption to the holder's address listed on the Bond Register. Such notice shall be sent by the Trustee by first class mail between twenty (20) and sixty (60) days prior to the scheduled redemption date. With respect to Book Entry Bonds, if the Trustee sends notice of redemption to the Securities Depository pursuant to the 18 CHI2_650171.5 Letter of Representations, the Trustee shall not be required to give the notice set forth in the immediately preceding sentence. If notice is given as stated in this paragraph (a), failure of any Bondholder to receive such notice, or any defect in the notice, shall not affect the redemption or the validity of the proceedings for the redemption of the Bonds. (b) In addition to the foregoing, the redemption notice shall contain with respect to each Bond being redeemed, (1) the CUSIP number, (2) the date of issue, (3) the interest rate, (4) the maturity date, and (5) any other descriptive information determined by the Trustee to be needed to identify the Bonds. If a redemption is a Conditional Redemption, the notice shall so state. The Trustee shall also send each notice of redemption at least thirty (30) days before the redemption date to (A) any Rating Service then rating the Bonds to be redeemed; (B) all of the registered clearing agencies known to the Trustee' to 'be in the business of holding substantial amounts of bonds of a type similar to the Bonds; and (C) one or more national information services that disseminate notices of redemption of bonds such as the Bonds such services to be identified by the Trustee. Each redemption notice shall also be sent to participants of the Securities Depository and to Beneficial Owners as provided in Section 8.10. (c) On or before the date fixed for redemption, subject to the provisions of subsections (a) and (d) of this Section, moneys shall be deposited with the Trustee to pay the principal of, redemption premium, if any, and interest accrued to the redemption date on the Bonds called for redemption. Upon the deposit of such moneys, unless the Issuer has given notice of rescission as described in subsection (d) of this Section, the Bonds shall cease to bear interest on the redemption date and shall no longer be entitled to the benefits of this Indenture (other than for payment and transfer and exchange) and shall no longer be considered Outstanding. (d) Any Conditional Redemption may be rescinded in whole or in part at any time prior to the fifth Business Day prior to the redemption date if the Issuer delivers an Officer's Certificate to the Trustee instructing the Trustee to rescind the redemption notice. The Trustee shall give prompt notice of such rescission to the affected Bondholders. Any Bonds subject to Conditional Redemption where redemption has been rescinded shall remain Outstanding, and the rescission shall not constitute an Event of Default. Further, in the case of a Conditional Redemption, the failure of the Issuer to make fiends available in part or in whole on or before the redemption date shall not constitute an Event of Default, and the Trustee shall give Immediate Notice to the Securities Depository or the affected Bondholders that the redemption did not occur and that the Bonds called for redemption and not so paid remain Outstanding. Section 3.7 Purchase at Any Time. The Trustee, upon the written request of the Issuer shall purchase Bonds as specified by the Issuer in the open market at a price not exceeding a price set by the Issuer. Such purchase of Bonds shall be made with funds provided by the Issuer and not with any portion of the Trust Estate or any Defeasance Obligations. Upon purchase by the Trustee, such Bonds shall be treated as delivered for cancellation pursuant to Section 2.11. Nothing in this Indenture shall prevent the Issuer from purchasing Bonds on the open market without the involvement of the Trustee and delivering such Bonds to the Trustee for cancellation pursuant to Section 2.11. Bonds purchased pursuant to this Section which are subject to the mandatory sinking fund redemption schedule in Section 3.2 shall be credited against future mandatory sinking fund redemption payments in accordance with Section 3.2. The principal 19 CH12_650171.5 amount of Bonds to be redeemed by optional redemption under this Indenture may be reduced by the principal amount of Bonds purchased by the Issuer and delivered to the Trustee for ? I cancellation at least forty-five (45) days,prior to the redemption date. ARTICLE IV FUNDS AND ACCOUNTS Section 4.1 Creation of Funds; Deposit of Bond Proceeds. The following funds are hereby created and the proceeds of the Bonds and all Revenues received by the Trustee are, subject to the provisions of Section 7.8, to be deposited by it in the Funds described herein and held in trust for the purposes set forth herein: (a) Improvement Fund, consisting of a Project Account and an Issuance Expense Account. (b) Debt Service Fund, including a Capitalized Interest Account. (c) Reserve Fund. (d) Rebate Fund. (e) Administrative Expense Fund. (f) Special Redemption Fund. The proceeds of the sale of the Bonds shall, on the Issue Date, be delivered to the Trustee who shall forthwith deposit $ of such proceeds in the Issuance Expense Account, $ of such proceeds representing capitalized interest in the Capitalized Interest Account of the Debt Service Fund, an amount equal to the Required Reserve in the Reserve Fund, $ of such proceeds in the Administrative Expense Fund, and the balance of such proceeds in the Project Account. Section 4.2 Improvement Fund. Payments from the Improvement Fund, shall be made by the Trustee as follows: (a) Payments from the Improvement Fund shall be made within three (3) Business Days only upon receipt by the Trustee of a requisition executed by the Issuer in the form of Request for Payment set forth in ADDendix C. (b) Upon the later of six months from the Issue Date or the payment of all Issuance Costs (as evidenced by a certificate of Issuer delivered to the Trustee), any moneys remaining in the Issuance Expense Account shall be transferred to the Project Account. (c) Upon completion of the Special Services (as evidenced by a certificate of the Issuer delivered to the Trustee), any moneys remaining in the Improvement Fund shall be transferred to the Debt Service Fund to redeem Bonds pursuant to Section 3.4, 20 CH12 650171.5 unless the Issuer directs that such moneys be deposited into the Reserve Fund, or applied to any other use, accompanied in either case by an opinion of Bond Counsel to the effect that such application will not adversely affect any applicable exemption from federal income taxation of the interest on the Bonds. (d) Notwithstanding anything to the contrary herein, to the extent an Event of Default described in clause (a) or (b) of Section 7.1 shall have occurred and be continuing and no other moneys are available under this Indenture to cure such Event of Default, no moneys on deposit in the Improvement Fund shall be applied in accordance with Section 4.2(c). In such event, moneys on deposit in the Improvement Fund shall be applied by the Trustee in accordance with Article VII. Section 4.3 Debt Service Fund. (a) The Trustee shall deposit into the Debt Service Fund (1) all Revenues, (2) all Available Funds, and (3) all other amounts required or permitted hereunder to be deposited in the Debt Service Fund. (b) Moneys on deposit in the Debt Service Fund shall be set aside and applied on each Accounting Date as follows in the following order of priority: (i) To the payment, when due on the next two succeeding Interest Payment Dates of interest, on all Outstanding Bonds, including any accrued interest due in connection with redemptions of Bonds; (ii) To the payment, when due on the next succeeding March 1, of the principal of or redemption premium on the Bonds then payable at maturity or upon redemption; I (iii) To the payments of any deficiencies in the Reserve Fund in accordance with the requirements of Section 4.4, including for reimbursement to the provider of any credit facility deposited in the Reserve Fund pursuant to Section 4.4(d); (iv) To the Administrative Expense Fund, an amount equal to the difference, if any, between the Administrative Expense Fund Requirement and the amount then on deposit in the Administrative Expense Fund; (v) To the abatement of Ad Valorem Taxes pursuant to Section 6.5 of this Indenture; and i (vi) To the Special Redemption Fund, any surplus remaining on March 2 of each year after application to the uses set forth in (i) -(v) above., (c) Moneys on deposit in the Debt Service Fund shall at all times be invested at a yield equal to or less than the yield on the Bonds or in obligations issued by any state or political subdivision the interest on which is exempt from inclusion in gross income of the holder under Section 103 of the Code, provided that such obligations are rated in one of the two highest 21 CH12_650171.5 general classifications established by a rating service of nationally recognized expertise in rating bonds of states and their political subdivisions. j Section 4.4 Reserve Fund. (a) The Trustee initially shall deposit in the Reserve Fund an amount equal to the Required Reserve on the Bonds from the proceeds of the Bonds. The amount of any withdrawal j for the purpose of subsections (b)(i) of this Section shall be restored by the Issuer from available Revenues in the Debt Service Fund after satisfying the requirements of Section 4.3(b)(i) through (iii). In addition, if the fair market value of the investments in the Reserve Fund is less than the Required Reserve on any valuation date in accordance with Section 5.3, the difference between such Required Reserve and the value of the Reserve Fund shall be restored by the Issuer but solely from the first available surplus Revenues in the Debt Service Fund. (b) Moneys on deposit in the Reserve Fund shall be applied as follows: (i) On the date of each required payment from the Debt Service Fund, moneys in the Reserve Fund shall be applied to cure any deficiency in the Debt Service Fund with respect to payments of principal of and interest on the Bonds when due and payable; (ii) Upon delivery of an Officer's Certificate of the Issuer delivered to the Trustee, any amount in the Reserve Fund in excess of the Required Reserve on any valuation date shall be transferred to the Debt Service Fund. (c) The Issuer shall be permitted to substitute a letter of credit, surety bond or other credit enhancement (each, a "credit facility ") for funds on deposit in the Reserve Fund, provided that: (i) the credit facility (including any replacement credit facility) is issued by a bank, trust company, national banking association or insurance company whose unsecured long term debt obligations (in the case of a bank, trust company or national banking association) or whose claims paying abilities (in the case of an insurance company) are rated by a Rating Service, at the time the credit facility is issued and at the time of each extension or renewal thereof, in one of the two highest rating categories maintained by such Rating Service at the time of substitution; (ii) the issuer of the credit facility does not receive as security for any reimbursement obligation in respect of the credit facility any lien, security interest or other similar right or interest in any property within the Trust Estate which is superior to the rights of the Trustee in respect of such property; (iii) the credit facility (including any replacement credit facility, if provided by a different issuer) has an initial term of not less than three (3) years and any extension, renewal or replacement (if provided by the same issuer) thereof has a term of not less than one year; 22 CHI2_650171.5 i (iv) the Trustee is authorized and has the duty and right to draw on the credit facility to satisfy the purposes for which the Reserve Fund was established; and (v) The Trustee shall receive an opinion of Counsel to the effect that all of the requirements set forth above have been satisfied and an opinion of Bond Counsel to the effect that the substitution of the credit facility will not, in and of itself, adversely affect the tax- exempt status of the Bonds. Upon such substitution, funds on deposit in the Reserve Fund which, when added to the face amount of the credit facility, exceed the Required Reserve on all Outstanding Bonds shall be applied as provided in subsection (b)(ii) above. Thereafter, the credit facility shall be considered a part of the Reserve Fund and the amount available thereunder shall be included in any calculation of the amount required to be retained in the Reserve Fund; provided that, (A) if the sum of the amount available under the credit facility and the amount of moneys on deposit in the Reserve Fund exceeds the amount required to be on deposit pursuant to subsection (a) of this Section, the Issuer shall be permitted to (i) cause the amount available under the credit facility to be reduced by an amount equal to such excess, or (ii) direct that the excess moneys be applied as permitted under subsection (b)(ii) of this Section, and (B) if the credit facility is not extended, renewed or replaced at least three (3) months prior to its scheduled expiration or termination date, the Trustee shall, not later than five days prior to such date, draw on the credit facility for the full amount thereof. (d) If there are cash and Eligible Investments on deposit in the Reserve Fund in addition to a credit facility, such cash and Eligible Investments will be drawn on prior to any draws on such credit facility. Section 4.5 Revenues to Be Held for All Bondholders, With Certain Exceptions. Until applied as herein provided and except where moneys have been deposited with or paid to the Trustee pursuant to an instrument restricting the application of such moneys to particular Bonds, the moneys and investments held in all Funds (other than amounts required to be on deposit in the Rebate Fund) established hereunder and the proceeds of any remedies exercised under Article VII hereof shall be held in trust pursuant to the terms of this Indenture for the equal and proportionate benefit of the holders of all Outstanding Bonds, except that: (a) on and after the date on which the interest or redemption premium on or principal of any particular Bond or Bonds is due and payable from the Debt Service Fund or, with respect to which a call for redemption has been given and funds for such redemption have been deposited with the Trustee and, if a Conditional Redemption, the rescission date has passed, the unexpended balance of the amount deposited or reserved in the Debt Service Fund for the making of such payments shall, to the extent necessary therefor, be held solely for the benefit of the Bondholder or Bondholders entitled thereto; and (b) any special redemption fund established in connection with the defeasance of any Bonds in accordance with Article IX shall be held for the benefit of the holders of Bonds being defeased. 23 CH12_650171.5 Section 4.6 Rebate Fund. The Issuer has covenanted to calculate and pay directly to the government of the United States of America all amounts due for payment of "arbitrage rebate" under Section 148(f) of the Code with respect to the Bonds. Accordingly, no amounts are expected to be deposited in the Rebate Fund. The Issuer may deposit with the Trustee or direct the Trustee to deposit in the Rebate Fund amounts held in any Fund hereunder for any or all Bonds (which direction shall specify the procedures for collection and payment of amounts due in respect of arbitrage rebate) if (a) required under to Section 148(f) of the Code, or (b) the Issuer determines that the funding of the Rebate Fund prior to the due date of any payment to the United States of America is desirable and appropriate. The Rebate Fund is a trust fund, but amounts therein do not constitute part of the Trust Estate. Amounts on deposit in the Rebate Fund may be used solely to make payments to the United States of America under Section 148 of the Code and to pay costs related to the calculation of the amounts due. Upon satisfaction of the Issuer's covenants described above, any amounts remaining in the Rebate Fund shall be applied in accordance with Section 4.8. Section 4.7 Administrative Expense Fund. The Administrative Expense Fund shall be used to pay Administrative Expenses. Moneys on deposit in the Administrative Expense Fund shall be applied to the payment of any Administrative Expenses requested by the Issuer to be paid. All amounts in the Administrative Expense Fund in excess of the Administrative Expense Fund Requirement shall be transferred to, and deposited in, the Debt Service Fund. Section 4.8 Special Redemption Fund. (a) When the amount on deposit in the Special Redemption Fund on any date equals $5,000, such amount shall be used to redeem the Bonds on any date in accordance with Section 3.3. On each such date, the Trustee shall withdraw from the Special Redemption Fund and pay to the owners of the Bonds the amounts to redeem the Bonds pursuant to Section 3.3. (b) Any amounts contained in the Special Redemption Fund on the final maturity date of the Bonds shall be used to pay outstanding debt service on the Bonds. (c) Moneys on deposit in the Special Redemption Fund shall be invested at a yield equal to or less than the yield on the Bonds or in obligations the interest on which is exempt from inclusion in the gross income of the holder under Section 103 of the Code to the extent such moneys are on deposit or are expected to be on deposit in the Special Redemption Fund for greater than thirteen (13) months. Section 4.9 Repavment to the Issuer from Amounts Remainina in Any Funds. Any amounts remaining in any Funds (a) after all of the Outstanding Bonds shall be deemed paid and discharged under the provisions of this Indenture, and (b) after payment of all fees, charges and expenses of the Trustee, the Bond Registrar and any Paying Agents and of all other amounts required to be paid under this Indenture, shall be paid to the Issuer to the extent that such amounts are in excess of those necessary to effect the payment and discharge of the Outstanding Bonds and payment of the Rebate Amount, if any. Section 4.10 Additional Funds and Accounts. In addition to the funds and accounts specifically authorized under this Article, the Trustee shall have the authority to create and 24 CH12_650171.5 maintain such other funds and accounts as it may deem necessary for proper administration hereunder. ARTICLE V INVESTMENT OR DEPOSIT OF FUNDS Section 5.1 Deposits and Security Therefor. All moneys received by the Trustee under this Indenture for deposit in any Fund established hereunder shall be considered trust funds. All moneys on deposit with the Trustee shall, to the extent not insured, be secured in the manner required or permitted by State or other applicable law. Subject to the foregoing requirements as to security, if at any time the commercial department of the Trustee is unwilling to accept such deposits or unable to secure them as provided above, the Trustee may deposit such moneys with any other depository which is authorized to receive and secure them as aforesaid and the deposits of which are insured by the Federal Deposit Insurance Corporation. All security for deposits shall be perfected in such manner as may be required or permitted under applicable law in order to grant to the Trustee a perfected lien on or security interest in such security. Section 5.2 Investment or Deposit of Funds. Moneys on deposit in the Funds established pursuant to Article IV shall be invested and reinvested by the Trustee as follows: I (a) All moneys on deposit in Funds shall be invested in Eligible Investments which shall mature, or be subject to repurchase, withdrawal without penalty or redemption at the option of the holder on or before the dates on which the amounts invested are reasonably expected to be needed for the purposes hereof. (b) All purchases or sales of Eligible Investments shall be made at the direction of the Issuer (given in writing or orally, confirmed in writing). If the Issuer elects to give the Trustee oral investment instructions and the Trustee in its discretion elects to act upon such oral investment instructions, the Trustee's understanding of such oral investment instructions shall be deemed controlling. The Trustee shall not be liable for any losses, costs or expenses arising directly or indirectly from the Trustee's reliance upon and compliance with such oral investment instructions notwithstanding such oral investment instructions conflict or are inconsistent with a subsequent written investment instruction. The Trustee may conclusively rely upon such instructions as to both the suitability and legality of the directed investments. The Trustee may make any and all such investments and such investments through its own investment department or that of its affiliates or subsidiaries, and may charge its ordinary and customary fees for such trades, including cash sweep account fees. (c) (1) Any securities or investments held by the Trustee may be transferred by the Trustee, if required in writing by the Issuer, from any of the Funds or accounts mentioned in Article IV to any other Fund or account mentioned in Article IV at the then current market value thereof without having to be sold and purchased or repurchased; provided, however, that after any such transfer or transfers, the investments in each such Fund or account shall be in accordance with the provisions as stated in this Indenture; and (2) whenever any other transfer or payment is required to be made from any particular 25 CH12_650171.5 Fund, such transfer or payment shall be made from such combination of maturing principal, redemption premiums, liquidation proceeds and withdrawals of principal as the i Trustee deems appropriate for such purpose. J (d) Neither the Issuer nor the Trustee shall be accountable for any depreciation in the value of Eligible Investments or for any losses incurred upon any authorized disposition thereof. (e) Subject to the foregoing, the Trustee is expressly authorized to invest moneys in two or more Funds in a single investment, provided that a portion of the investment allocable to each such Fund, and all payments received with respect to such allocable portion, shall be applied in accordance with the applicable provisions governing such Fund hereunder. (f) Prior to the completion of the Special Services, investment income on amounts on deposit in the Reserve Fund, the Debt Service Fund and the Administrative Expense Fund shall be transferred to the Improvement Fund to the extent that no deficiency will exist in the Reserve Fund or the Debt Service Fund after such transfer or shall be applied to such other purpose or purposes as directed by the Issuer with an opinion of Bond Counsel addressed to the Trustee to the effect that such application will not cause interest on the Bonds to be includable in gross income for federal income tax purposes. After completion of the Special Services, investment income on amounts on deposit in the Reserve Fund shall be transferred to the Debt Service Fund to the extent that no deficiency will exist in the Reserve Fund after such transfer. In all other situations, earnings from investment shall remain in the respective Fund where earned. (g) Although the Issuer recognizes that it may obtain a broker confirmation or written statement containing comparable information at no additional cost, the Issuer hereby agrees that confirmations of permitted investments are not required to be issued by the Trustee for each month in which a monthly statement is rendered. No statement need be rendered for any fund or account if no activity occurred in such fund or account during such month. Section 5.3 Valuation of Funds. The Trustee shall determine the market value of the assets in each of the Funds established hereunder annually on a date not earlier than three days prior to December — of each year. As soon as practicable after each such valuation date, the Trustee shall furnish to the Issuer a report of the status of each Fund as of such date. The Trustee shall also advise the Issuer at such time of the amount then available in the Debt Service Fund as a credit against the Issuer's obligation to levy and collect the Ad Valorem Taxes for deposit to the Debt Service Fund prior to the next valuation date. In computing the value of assets in any Fund, investments shall be valued at the fair market value thereof and shall include accrued but unpaid interest on each investment, and all investments (valued as aforesaid) and accrued interest thereon shall be deemed a part of such Funds. All Eligible Investments that mature within six (6) months of any valuation date or are payable on demand shall be valued at par plus any accrued and unpaid interest. Upon the request of the Issuer, the Trustee shall also provide the Issuer with monthly or other periodic statements showing amounts deposited into and withdrawn from each 26 CHI2_650171.5 Fund, the investments made with amounts in each Fund and the investment income received from such investments. ARTICLE VI COVENANTS AND AGREEMENTS OF THE ISSUER Section 6.1 Covenants and Agreements of the Issuer. In addition to any other covenants and agreements of the Issuer contained in this Indenture or the Bond Ordinance, the Issuer further covenants and agrees with the Bondholders and the Trustee as follows: (a) To take all actions, if any which shall be necessary, in order further to provide for the levy, extension, collection and application of the Ad Valorem Tax including enforcement of the Ad Valorem Tax by institution of foreclosure proceedings as provided by law; (b) To not take any action which would adversely affect the levy, extension, collection and application of the Ad Valorem Tax levied pursuant to the Bond Ordinance and Indenture, except to abate the Ad Valorem Tax to the extent permitted by the Indenture; (c) To comply with all requirements of the Act, the Bond Ordinance and other applicable present and future laws concerning the levy extension and collection of the Ad Valorem Tax levied pursuant to the Bond Ordinance and Indenture, in each case so that the Issuer shall be able to pay the principal of and interest on the Bonds as they come due and replenish the Reserve Fund to the Required Reserve and it will take all actions necessary to assure the timely collection of the Ad Valorem Tax, including without limitation, the enforcement of any delinquent Ad Valorem Tax by providing Kendall County with such information as is deemed necessary to enable the County to include any property subject to delinquent Ad Valorem Tax in the County Collector's annual tax sale and in the event the tax lien is forfeited at such tax sale, by the commencement and maintenance of an action to foreclose the lien of any delinquent Ad Valorem Tax, all in the manner provided by law; (d) To not encumber, pledge or place any charge or lien upon any of the Ad Valorem Tax or other amounts pledged to the Bonds superior to, or on a parity with, or junior to, the pledge and lien created in the Indenture for the benefit of the Bonds, except as permitted by, or specifically set forth in, the Indenture; (e) To take all actions which are necessary to be taken (and avoid any actions which it is necessary to avoid being taken) so that interest on the Bonds will not be or become included in gross income for federal income tax purposes under existing law; (f) To keep, or cause the Trustee to keep, proper books of record and accounts, separate from all other records and accounts of the Issuer, in which complete and correct entries will be made of all transactions relating to the deposits to and expenditure of amounts disbursed from the Funds and Accounts created under the Indenture and the Ad Valorem Tax; 27 CH12_650171.5 (g) To take all actions which are necessary to be taken to enforce the Issuer's rights under the Development Agreement; 1 i (h) To make the Bond Register available at reasonable times and under reasonable regulations established by the Bond Registrar, to be inspected and copied by or delivered to the Issuer, the Trustee, the holders of 25% or more in principal amount of the Bonds then Outstanding, or a designated representative thereof; (i) To furnish to the Trustee, the Original Purchaser and the Beneficial Owner of $500,000 or more in Bonds who so requests, within ten (10) days of receipt by the Issuer, a copy of each annual audit of the Issuer, the schedule of tenants and lease expiration dates for each tenant's lease provided to the Issuer by the Developer, any publicly available information received from the Illinois Department of Revenue of the Business District Sales Taxes, and any abatement ordinance adopted by the Corporate Authorities abating any of the Ad Valorem Taxes; and 0) To provide or cause the Trustee to provide to the Original Purchaser and to the Beneficial Owner of $500,000 or more in Bonds who so requests, copies of any reports (including quarterly construction progress reports) or disclosure which the Developer provides to the Issuer or the Trustee pursuant to the terms of the Development Agreement. Section 6.2 Observance and Performance of Covenants, Aaeeements, Authoritv and Actions. The Issuer hereby agrees to observe and perform at all times all covenants, agreements, authority, actions, undertakings, stipulations and provisions to be observed or performed on its part under this Indenture, the Bond Ordinance and the Bonds which are executed, authenticated and delivered under this Indenture, and under all proceedings of its Legislative Authority pertaining thereto. The Issuer represents and warrants that: (a) It is duly authorized by the Constitution and laws of the State, including particularly and without limitation the Act, to issue the Bonds, to execute and deliver this Indenture and to provide the security for payment of the principal of, redemption premium, if any, and interest on the Bonds in the manner and to the extent set forth in this Indenture. (b) All actions required on its part to be performed for the issuance, sale and delivery of the Bonds and for the execution and delivery of this Indenture have been or will be taken duly and effectively; provided no representation is made as to compliance with any state securities or "Blue Skv" laws. (c) The Bonds will be valid and enforceable limited obligations of the Issuer according to their terms, subject to bankruptcy and equitable principles. Section 6.3 Tax Covenants. 28 CH12_650171.5 (a) The Issuer covenants that it will neither make nor direct the Trustee to make any investment or other use of the proceeds of the Bonds that would cause such Bonds to be "arbitrage bonds" as that term is defined in Section 148(a) of the Code, and that it will comply with the requirements of the Code throughout the term of such Bonds. The Trustee covenants that in those instances where it exercises discretion over the investment of funds, it shall not knowingly make any investment inconsistent with the foregoing covenants. (b) The Issuer covenants that it (i) will take, or use its best efforts to require to be taken, all actions that may be required of the Issuer for the interest on the Bonds to be and remain not included in gross income for federal income tax purposes and (ii) will not take or authorize to be taken any actions within its control that would adversely affect that status under the provisions of the Code. (c) The Issuer further covenants as follows with respect to the requirements of Section 148(f) of the Code, relating to the rebate of "excess arbitrage profits" (the "Rebate Reauirement") to the United States: i (i) Unless an applicable exception to the Rebate Requirement is available to the Issuer, the Issuer will meet the Rebate Requirement. (ii) Relating to applicable exceptions, the Issuer shall make such elections under the Code as it shall deem reasonable and in the best interests of the Issuer. If such election may result in a "penalty in lieu of rebate" as provided in the Code, and such penalty is incurred (the "Penalty "), then the Issuer shall pay such Penalty. (iii) The Issuer shall, not less frequently than annually, cause to be transferred to the Rebate Fund the amount determined to be the accrued liability under the Rebate Requirement or Penalty. The Issuer shall cause to be paid to the United States, without further order or direction from the Legislative Authority, from time to time as required, amounts sufficient to meet the Rebate Requirement or to pay the Penalty. (iv) Interest earnings in the Debt Service Fund and the Reserve Fund are hereby authorized to be transferred, without further order or direction from the Legislative Authority, from time to time as required, to the Rebate Fund for the purposes herein provided; and proceeds of the Bonds, investment earnings or amounts on deposit in any of the other funds and accounts created hereunder and any other funds of the Issuer are also hereby authorized to be used to meet the Rebate Requirement or to pay the Penalty, but only if necessary after application of investment earnings as aforesaid and only as appropriated by the Legislative Authority. Section 6.4 Limited Obliszations. The Bonds shall constitute limited obligations of the Issuer, payable from the Revenues and other moneys deposited in the Funds established pursuant to Article IV other than the Rebate Fund. The Bonds shall not constitute general obligations of 29 CHI2_650171.5 the Issuer and neither the full faith and credit nor the unlimited taxing power of the Issuer shall be pledged as security for payment of the Bonds ); Section 6.5 Lew of Ad Valorem Tax; Abatement. Pursuant to the Bond Ordinance there has been levied an Ad Valorem Tax upon all taxable real property within the SSA sufficient to pay and discharge the principal of the Bonds at maturity or mandatory sinking fund redemption dates and to pay interest on the Bonds for each year at the interest rates set forth in Section 2.3 of this Indenture. The Clerk of Issuer has been directed to file a certified copy of the Bond Ordinance, and an accurate map of the SSA, with the County Clerk of the County. The Ad i Valorem Tax shall be divided among all taxable real property within the SSA. On each Accounting Date, the Trustee shall determine the amounts remaining on deposit in the Debt Service Fund, after application of moneys pursuant to paragraphs (i) through (iv) of Section 4.3(b) (the "Deposit "). On or before January _ of each year, the Trustee will provide notification containing the amount of the Deposit to the Issuer and request that the Issuer abate no later than the last Business Day of February of such year the Ad Valorem Taxes for the current year in an amount equal to the Deposit. By proper proceedings, the Issuer shall direct the abatement of such Ad Valorem Taxes as evidenced by the notification provided by the Trustee. The Issuer shall take all actions which shall be necessary to provide for the levy, extension, collection and application of the taxes levied by the Bond Ordinance, including enforcement of such taxes by institution of foreclosure procedures as provided by law. ARTICLE VII EVENTS OF DEFAULT AND REMEDIES Section 7.1 Events of Default Defined. Each of the following is an "Event of Default" hereunder: (a) Default in the payment of any installment of interest on any Bond when it becomes due and payable; (b) Default in the payment of principal of (or redemption premium, if any, on) any Bond when it becomes due and payable; (c) Subject to the provisions of Section 7.7, default in the performance, or breach, of any covenant, warranty or representation of the Issuer contained in this Indenture (other than a default under subsections (a) and (b) of this Section); (d) (1) An Event of Bankruptcy of the Issuer; (2) the appointment of a receiver, liquidator, assignee, custodian, trustee, sequestrator or other similar official of the Issuer or of any substantial portion of its property; or (3) the ordering of the winding up or liquidation of the affairs of the Issuer. Section 7.2 Remedies Upon Default. 30 CH12_650171.5 (a) If an Event of Default under Section 7.1 occurs and is continuing, the Trustee may, and upon the written request to the Trustee by the holder or holders of not less than 25% in aggregate principal amount of the Bonds then Outstanding shall, subject to the requirements of Section 8.2(e), by written notice to the Issuer, proceed to protect and enforce its rights and the rights of the holders of the Bonds by a suit, action or special proceeding in equity or at law, by mandamus or otherwise, either for the specific performance of any covenant or agreement contained herein or in aid or execution of any power herein granted or for any enforcement of any proper legal or equitable remedy as the Trustee, being advised by counsel, shall deem most effective to protect and enforce any of the rights or interests of the holders of the Bonds under the Bonds or this Indenture. (b) During the continuance of an Event of Default, all moneys received by the Trustee under this Indenture from the Issuer or from any other source shall be applied by the Trustee in accordance with the terms of Section 7.8 hereof. Upon the occurrence of an Event of Default described in Section 7.1(a) or (b) of this Indenture, which occurs during such time as amounts remain on deposit in the Improvement Fund, upon the written request of the holders of 25% in principal amount of the outstanding Bonds, the Trustee shall transfer any amounts on deposit in the Improvement Fund to the Debt Service Fund to be applied by the Trustee in accordance with Section 7.8 hereof; (c) Any judgment against the Issuer shall be enforceable only against the amounts pledged pursuant to this Indenture. There shall not be authorized any deficiency judgment against any assets of, or the general credit of, the Issuer. (d) The Bonds shall not be subject to acceleration upon the occurrence of an Event of Default. Section 7.3 Additional Remedies. Without limiting the generality of the foregoing Section 7.2, the Trustee shall at all times have the power to institute and maintain such proceedings as it may deem expedient: (1) to prevent any impairment of the Trust Estate by any acts which may be unlawful or in violation of this Indenture, and (2) to protect its interests and the interests of the Bondholders in the Trust Estate and in the issues, profits, revenues and other income arising therefrom, including the power to maintain proceedings to restrain the enforcement of or compliance with any governmental enactment, rule or order which may be unconstitutional or otherwise invalid, if the enforcement of, or compliance with, such enactment, rule or order would impair the Trust Estate or be prejudicial to the interests of the Bondholders or the Trustee. Section 7.4 Marshaling of Assets. Upon the occurrence of an Event of Default, all moneys in all Funds (other than moneys in the Rebate Fund) shall be available to be utilized by the Trustee in accordance with this Article. The rights of the Trustee under Section 8.5 shall be applicable. During the continuance of any such Event of Default, all provisions of this Indenture relating to the utilization of Funds, including but not limited to those set out in Article IV, shall be superseded by this Article. Subsequent to the curing or waiver of any such Event of Default, the provisions of this Indenture relating to utilization of Funds, including the provisions of Article IV, shall be reinstated. 31 CH12_650171.5 Section 7.5 Trustee May File Proofs of Claim. (a) In case of the pendency of any receivership, insolvency, liquidation, bankruptcy, reorganization, arrangement, adjustment, composition or other judicial proceeding under the Bankruptcy Code relating to the Issuer or any property of the Issuer, the Trustee (whether or not the principal of the Bonds shall then be due and payable by acceleration or otherwise, and whether or not the Trustee shall have made any demand upon the Issuer for the payment of overdue principal, redemption premium, if any, and interest) shall be entitled and empowered, by intervention in such proceeding or other means: (i) to file and prove a claim for the whole amount of the principal, redemption premium, if any, and interest owing and unpaid in respect of the Bonds then Outstanding or for breach of this Indenture and to file such other papers or documents as may be necessary or advisable in order to have the claims of the Trustee (including any claim for the reasonable compensation, expenses, disbursements and advances of the Trustee, its agents and Counsel) and of the holders allowed in such proceeding; and (ii) to collect and receive any moneys or other property payable or deliverable on any such claims and to distribute the same; and any receiver, assignee, trustee, liquidator, sequestrator or similar official in any such judicial proceeding is hereby authorized by each holder to make such payments to the Trustee, and, in the event that the Trustee shall consent to the making of such payments directly to the holders, to pay to the Trustee any amount due it for the reasonable compensation, expenses, disbursements and advances of the Trustee, its agents and Counsel, and any other amounts due the Trustee under Section 8.5.(b). No provision of this Indenture empowers the Trustee to authorize or consent to or accept or adopt on behalf of any holders of the Bonds any plan of reorganization, arrangement, adjustment or composition affecting any of the Bonds or the rights of any holder thereof, or to authorize the Trustee to vote in respect of the claim of any holder in any proceeding described in subsection (a) of this Section. Section 7.6 Possession of Bonds Not Required. All rights under this Indenture and the Bonds may be enforced by the Trustee without possession of any Bonds or the production of them at trial or other proceedings. Any proceedings instituted by the Trustee may be brought in its name for itself or as representative of the Bondholders without the necessity of joining Bondholders as parties, and any recovery resulting from such proceedings shall, subject to Section 7.8, be for the ratable benefit of the Bondholders. Section 7.7 Notice and Opportunity to Cure Certain Defaults. No default under Section 7.1(c) shall constitute an Event of Default until written notice of such default shall have been given to the Issuer by the Trustee or by the holders of at least 25% in aggregate principal amount of the Bonds Outstanding, and the Issuer shall have had thirty (30) days after receipt of such notice to correct such default or cause such default to be corrected, and shall have failed to do so. In the event, however, that the default be such that it cannot be corrected within such 32 CH 12_650171.5 thirty (30) day period, it shall not constitute an Event of Default if corrective action is instituted by the Issuer within such period and diligently pursued (as determined by the Trustee) until the default is corrected. Section 7.8 Prioritv of Pavment Followins? Event of Default. (a) If at any time after the occurrence of an Event of Default the moneys held by the Trustee under this Indenture (other than amounts in the Rebate Fund) shall not be sufficient to pay the principal of and interest on the Bonds as the same become due and payable, such moneys, together with any moneys then available or thereafter becoming available for such purpose, whether through the exercise of remedies in this Article or otherwise, shall, subject to subsections (b) and (c) of this Section, be applied by the Trustee as follows: (i) first, to the payment of all amounts due the Trustee under Section 8.5; (ii) second, to the payment of all installments of interest on the Bonds then due and payable in the order in which such installments became due and payable, and, if the amount available shall not be sufficient to pay in full any particular installment, then to the payment, ratably, according to the amounts due on such installments, without discrimination or preference; (iii) third, to the payment of the unpaid principal amount of any of the Bonds which shall have become due and payable, in the order of due dates (other than Bonds called for redemption or contracted to be purchased for the payment of which moneys are held pursuant to the provisions of this Indenture), with interest upon the principal amount of the Bonds from the respective dates upon which they shall have become due and payable, and, if the amount available shall not be sufficient to pay in full the principal of such Bonds due and payable on any particular due date, together with such interest, then to the payment first of such interest, ratably, according to the amount of principal due on such date, without any discrimination or preference; and (iv) fourth, to the payment of principal of, interest on and redemption premium if any, on Bonds called for redemption under Section 3.3, if any. (b) If the principal of all Bonds shall have become due and payable, whether by their terms or by a declaration of acceleration, and subject to subsection (a)(1) of this Section regarding payment to the Trustee, all such moneys shall be applied to the payment of the principal and interest then due and unpaid upon the Bonds, without preference or priority of principal over interest or of interest over principal, or of any installment of interest over any other installment of interest, or of any Bond over any other Bond, ratably, according to the amounts due respectively for principal and interest, without any discrimination or preference. (c) Whenever moneys are to be applied pursuant to the provisions of this Section, the Trustee may, in its discretion, establish and maintain a reserve for future fees 33 CH12 650171.5 and expenses, and may apply moneys to be distributed at such times, and from time to time, as the Trustee shall determine, having due regard for the amount of such moneys i available for application and the likelihood of additional moneys becoming available for such application in the future. Whenever the Trustee shall apply such funds, it shall fix a date (which shall be an Interest Payment Date unless it shall deem another date more suitable) upon which such application is to be made and upon such date interest on the amounts of principal to be paid on such dates, and for which moneys are available, shall cease to accrue. The Trustee shall also select a Record Date for such payment date if the payment date is not an Interest Payment Date. The Trustee shall give such notice as it may deem appropriate of the deposit with it of any moneys and of the fixing of any such i Record Date and payment date, and shall not be required to make payment to the holder of any Bond until such Bond shall be presented to the Trustee for appropriate endorsement or for cancellation if fully paid. Section 7.9 Bondholders May Direct Proceedings. The owners of a majority in aggregate principal amount of the Bonds Outstanding shall, subject to the requirements of Section 8.2(e), have the right, by an instrument or instruments in writing executed and delivered to the Trustee, to direct the method and place of conducting all remedial proceedings by the Trustee hereunder, provided that such direction shall not be in conflict with any rule of law or this Indenture and that the Trustee shall have the right to decline to follow any such direction which in the opinion of the Trustee would be unduly prejudicial to the rights of Bondholders not parties to such direction or would subject the Trustee to personal liability or expense. Notwithstanding the foregoing, the Trustee shall have the right to select and retain Counsel of its choosing to represent it in any such proceedings. The Trustee may take any other action which is not inconsistent with any direction under this Section. Section 7.10 Limitations on Rights of Bondholders. (a) No Bondholder shall have any right to pursue any other remedy under this Indenture or the Bonds unless: (1) an Event of Default shall have occurred and is continuing; (2) the owners of not less than 25% in aggregate principal amount of all Bonds then Outstanding have requested the Trustee, in writing, to exercise the powers hereinabove granted or to pursue such remedy in its or their name or names; (3) the Trustee has been offered indemnity satisfactory to it against costs, expenses and liabilities reasonably anticipated to be incurred; (4) the Trustee has declined to comply with such request, or has failed to do so, within sixty (60) days after its receipt of such written request and offer of indemnity; and (5) no direction inconsistent with such request has been given to the Trustee during such 60 -day period by the holders of a majority in aggregate principal amount of the Bonds Outstanding. (b) The provisions of subsection (a) of this Section are conditions precedent to the exercise by any Bondholder of any remedy hereunder. The exercise of such rights is further subject to the provisions of Sections 7.9, 7.11 and 7.14. No one or more Bondholders shall have any right in any manner whatever to enforce any right under this Indenture, except in the manner herein provided. All proceedings at law or in equity with respect to an Event of Default shall be instituted and maintained in the manner herein provided for the equal and ratable benefit of the Bondholders of all Bonds Outstanding. 34 CH12 650171.5 Section 7.11 Unconditional Right of Bondholder to Receive Payment. Notwithstanding any other provision of this Indenture, any Bondholder shall have the absolute and unconditional right to receive payment of principal of, redemption premium, if any, and interest on the Bonds on and after the due date thereof, and to institute suit for the enforcement of any such payment. Section 7.12 Restoration of Rights and Remedies. If the Trustee or any Bondholder has instituted any proceeding to enforce any right or remedy under this Indenture and any such proceeding has been discontinued or abandoned for any reason, or has been determined adversely to the Trustee or such Bondholder, then the Trustee and the Bondholders shall, subject to any determination in such proceeding, be restored to their former positions hereunder, and all rights and remedies of the Trustee and the Bondholders shall continue as though no such proceeding had been instituted. Section 7.13 Rialits and Remedies Cumulative. No right or remedy herein conferred upon or reserved to the Trustee is intended to be exclusive of any other right or remedy, but each such right or remedy shall, to the extent permitted by law, be cumulative of and in addition to every other right or remedy given hereunder or now or hereafter existing at law, in equity or otherwise. The assertion or employment of any right or remedy hereunder shall not prevent the concurrent assertion or employment of any other appropriate right or remedy. Section 7.14 Delay or Omission Not Waiver. No delay or omission by the Trustee or any Bondholder to exercise any right or remedy accruing upon any Event of Default shall impair any such right or remedy or constitute a waiver of such Event of Default. Every right and remedy given by this Article or by law to the Trustee or the Bondholders may be exercised from time to time, and as often as may as deemed expedient, by the Trustee or the Bondholders, as the case may be. Section 7.15 Waiver of Defaults. (a) The holders of a majority in aggregate principal amount of the Outstanding Bonds may, by written notice to the Trustee and subject to the requirements of Section 8.2(e), waive any existing default or Event of Default and its consequences, except an Event of Default under Section 7.1(a) or (b). Upon any such waiver, the default or Event of Default shall be deemed cured and shall cease to exist for all purposes. No waiver of any default or Event of Default shall extend to or effect any subsequent default or Event of Default or shall impair any right or remedy consequent thereto. (b) Notwithstanding any provision of this Indenture, in no event shall any Person, other than all of the affected Bondholders, have the ability to waive any Event of Default under this Indenture if such event results or may result, in the opinion of Bond Counsel, in interest on any of the Bonds becoming includable in gross income for federal income tax purposes. Section 7.16 Notice of Events of Default. If an Event of Default occurs of which the Trustee has or is deemed to have notice under Section 8.2(h), the Trustee shall give Immediate Notice thereof to the Issuer. Within fifteen (15) days thereafter (unless such Event of Default has been cured or waived), the Trustee shall give notice of such Event of Default to each holder of Bonds then Outstanding, provided, however, that except in the instance of an Event of Default 35 CH12_650171.5 under Section 7.1(a) or (b), the Trustee may withhold such notice to Bondholders if and so long as the Trustee in good faith determines that the withholding of such notice is in the interests of Bondholders, and provided, further, that notice to Bondholders of any Event of Default under Section 7.1(c) shall be subject to the provisions of Section 7.7 and shall not be given until the grace period has expired. ARTICLE VIII THE TRUSTEE Section 8.1 Duties and Responsibilities of the Trustee. (a) Prior to the occurrence of an Event of Default of which it has or is deemed to have notice hereunder, and after the curing or waiver of any Event of Default which may have occurred: (i) the Trustee undertakes to perform such duties and only such duties as are specifically set forth in this Indenture, and no implied covenants or obligations shall be read into this Indenture against the Trustee; and (ii) in the absence of bad faith on its part, the Trustee may conclusively rely, as to the truth of the statements and the correctness of the opinions expressed therein, upon certificates or opinions furnished to the Trustee that conform to the requirements of this Indenture; but the Trustee is under a duty to examine such certificates and opinions to determine whether they conform to the requirements of this Indenture. (b) In case an Event of Default of which the Trustee has or is deemed to have notice hereunder has occurred and is continuing, the Trustee shall exercise such of the rights and powers vested in it by this Indenture, and use the same degree of care and skill in their exercise, as a prudent person would exercise or use in the conduct of such person's own affairs. (c) No provision of this Indenture shall be construed to relieve the Trustee from liability for its own grossly negligent action, its own grossly negligent failure to act, or its own willful misconduct, except that: (i) this subsection shall not be construed to limit the effect of subsection (a) of this Section; (ii) the Trustee is not liable for any error of judgment made in good faith by a Responsible Officer, unless it is proven that the Trustee was grossly negligent in ascertaining the pertinent facts; (iii) the Trustee is not liable with respect to any action it takes or omits to be taken by it in good faith in accordance with the direction of the Bondholders under any provision of this Indenture relating to the time, method and place of 36 CH12 650171.5 conducting any proceeding for any remedy available to the Trustee, or exercising any trust or power conferred upon the Trustee under this Indenture; and (iv) no provision of this Indenture shall require the Trustee to expend or risk its own funds or otherwise incur any liability in the performance of any of its duties hereunder, or in the exercise of any of its rights or powers, if it has reasonable grounds for believing that the repayment of such funds or adequate indemnity against such risk or liability is not reasonably assured to it. (d) The Trustee shall maintain records of all investments and disbursements of proceeds in the funds and accounts established pursuant to this Indenture through the date ending six (6) years following the date on which all the Bonds have been retired. (e) Whether or not expressly so provided, every provision of this Indenture relating to the conduct or affecting the liability of or affording protection to the Trustee is subject to the provisions of this Section. (f) To assist the Issuer in complying with its obligations under Section 6.5 hereof, the Trustee shall on or before November 15 of each year notify the Issuer of the amount of the Deposit and on or before December 10 of each year notify the Issuer of the amount of Ad Valorem Tax to be abated for the next succeeding year. (g) The Trustee shall provide to the Original Purchaser and any Beneficial Owner, upon request, copies of all monthly account statements and any information provided to the Trustee by the Issuer pursuant to this Indenture and any information provided to the Trustee by the Developer pursuant to the Development Agreement. Section 8.2 Certain Ridits of the Trustee. Except as otherwise provided in Section 8.1: (a) the Trustee may rely and is protected in acting or refraining from acting upon any resolution, certificate, statement, instrument, opinion, report, notice, request, direction, consent, order, approval, bond, debenture or other paper or document believed by it to be genuine and to have been signed or presented by the proper party or parties; (b) any request, direction, order or demand of the Issuer under this Indenture shall be sufficiently evidenced by an Officer's Certificate (unless other evidence thereof is specifically prescribed); (c) whenever in the administration of this Indenture the Trustee deems it desirable that a matter be proved or established prior to taking, suffering or omitting any action hereunder, the Trustee (unless other evidence thereof is specifically prescribed) may, in the absence of bad faith on its part, rely upon an Officer's Certificate; (d) the Trustee may consult with Counsel and the written advice of such Counsel or an opinion of Counsel shall be full and complete authorization and protection for any action taken, suffered or omitted by it in good faith and in accordance with such advice or opinion; 37 CH12_650171.5 (e) the Trustee is under no obligation to exercise any of the rights or powers vested in it by this Indenture at the request or direction of any of the Bondholders unless such holders have offered to the Trustee security or indemnity satisfactory to the Trustee as to its terms, coverage, duration, amount and otherwise with respect to the costs, expenses and liabilities which may be incurred by it incompliance with such request or direction, and the provision of such indemnity shall be mandatory for any remedy taken upon direction of the holders of 25% in aggregate principal amount of the Bonds; (f) the Trustee is not required to make any inquiry or investigation into the facts or matters stated in any resolution, certificate, statement, instrument, opinion, report, notice, request, direction, consent, order, approval, bond, debenture or other paper or document but the Trustee, in its discretion, may make such further inquiry or investigation into such facts or matters as it may see fit and, if the Trustee determines to make such further inquiry or investigation, it is entitled to examine the books, records and premises of the Issuer in person or by agent or attorney; (g) the Trustee may execute any of its trusts or powers or perform any duties under this Indenture either directly or by or through agents or attorneys, and may in all cases pay, subject to reimbursement as provided in Section 8.5, such reasonable compensation as it deems proper to all such agents and attorneys reasonably employed or retained by it, and the Trustee shall not be responsible for any misconduct, negligence or gross negligence of any agent or attorney appointed with due care by it; (h) the Trustee is not required to take notice or deemed to have notice of any default or Event of Default hereunder, except Events of Default under Section 7.1(a) and (b), unless a Responsible Officer of the Trustee has actual knowledge thereof or has received notice in writing of such default or Event of Default from the Issuer or the holders of at least 25% in aggregate principal amount of the Outstanding Bonds, and in the absence of any such notice, the Trustee may conclusively assume that no such default or Event of Default exists; (i) the Trustee is not required to give any bond or surety with respect to the performance of its duties or the exercise of its powers under this Indenture; 0) in the event the Trustee receives inconsistent or conflicting requests and indemnity from two or more groups of holders of Bonds, each representing less than a majority in aggregate principal amount of the Bonds Outstanding, pursuant to the provisions of this Indenture, the Trustee, in its sole discretion, may determine what action, if any, shall be taken; (k) the Trustee's immunities and protections from liability and its right to indemnification in connection with the performance of its duties under this Indenture shall extend to the Trustee's officers, directors, agents, attorneys and employees. Such immunities and protections and right to indemnification, together with the Trustee's right to compensation, shall survive the Trustee's resignation or removal, the defeasance or discharge of this Indenture and final payment of the Bonds; 38 CH12_650171.5 (1) the permissive right of the Trustee to take the actions permitted by this Indenture shall not be construed as an obligation or duty to do so; (m) except for information provided by the Trustee concerning the Trustee, the Trustee shall have no responsibility for any information in any offering memorandum or other disclosure material distributed with respect to the Bonds, and the Trustee shall have no responsibility for compliance with any state or federal securities laws in connection with the Bonds; and (n) the Trustee agrees to accept and act upon instructions or directions pursuant to this Indenture sent by unsecured e-mail, facsimile transmission or other similar unsecured electronic methods, provided, however, that (a) the Issuer, subsequent to such transmission of written instructions, shall provide the originally executed instructions or directions to the Trustee in a timely manner, (b) such originally executed instructions or directions shall be signed by a person as may be designated and authorized to sign for the Issuer or in the name of the Issuer, by an authorized representative of the Issuer, and (c) the Issuer shall provide to the Trustee an incumbency certificate listing such designated persons, which incumbency certificate shall be amended whenever a person is to be added or deleted from the listing. If the Issuer elects to give the Trustee e- mail or facsimile instructions (or instructions by a similar electronic method) and the Trustee in its discretion elects to act upon such instructions, the Trustee's understanding of such instructions shall be deemed controlling. The Trustee shall not be liable for any losses, costs or expenses arising directly or indirectly from the Trustee's reliance upon and compliance with such instructions notwithstanding such instructions conflict or are inconsistent with a subsequent written instruction. The Issuer agrees to assume all risks arising out of the use of such electronic methods to submit instructions and directions to the Trustee, including without limitation the risk of the Trustee acting on unauthorized instructions, and the risk of interception and misuse by third parties. Section 8.3 Trustee Not Responsible for Recitals. The recitals contained in this Indenture and in the Bonds (other than the certificate of authentication on the Bonds) are statements of the Issuer, and the Trustee assumes no responsibility for their correctness. The Trustee makes no representations as to the value, condition or sufficiency of any assets pledged or assigned as security for the Bonds, the right, title or interest of the Issuer therein, the security provided thereby or by this Indenture, the technical or financial feasibility of the Special Services, the compliance of the Special Services with the Act, or the tax - exempt status of the Bonds. The Trustee is not accountable for the use or application by the Issuer of any of the Bonds or the proceeds of the Bonds, or for the use or application of any moneys paid over by the Trustee in accordance with any provision of this Indenture or the Bond Ordinance. Section 8.4 Trustee May Own Bonds. The Trustee, in its commercial banking or in any other capacity, may in good faith buy, sell, own, hold and deal in any of the Bonds and may join in any action which any Bondholder may be entitled to take with like effect as if it were not Trustee. The Trustee, in its commercial banking or in any other capacity, may also engage in or be interested in any financial or other transaction with the Issuer and may act as depository, trustee or agent for any committee of Bondholders secured hereby or other obligations of the 39 CH12_650171.5 Issuer as freely as if it were not Trustee. The provisions of this Section shall extend to affiliates of the Trustee. Section 8.5 Compensation and Expenses of the Trustee. The Issuer covenants and agrees as follows: (a) to pay to the Trustee compensation for all services rendered by it hereunder and under the other agreements relating to the Bonds to which the Trustee is a party in accordance with terms agreed to from time to time, and, subsequent to default, in accordance with the Trustee's then- current fee schedule for default administration (the entirety of which compensation shall not be limited by any provision of law regarding compensation of a trustee of an express trust); (b) to reimburse the Trustee upon its request for all reasonable expenses, disbursements and advances incurred or made by the Trustee in accordance with any provision of this Indenture, any other agreement relating to the Bonds to which it is a party or in complying with any request by the Issuer or any Rating Service with respect to the Bonds, including the reasonable compensation, expenses and disbursements of its agents and Counsel, except any such expense, disbursement or advance attributable to the Trustee's gross negligence or bad faith; and (c) to indemnify, defend and hold the Trustee harmless from and against any loss, liability or expense incurred without gross negligence or bad faith on its part, arising out of or in connection with the acceptance or administration of the office of Trustee under this Indenture, including the costs of defending itself against any claim or liability in connection with the exercise or performance of any of its powers or duties hereunder or thereunder. In the event the Trustee incurs expenses or renders services in any proceedings under Bankruptcy Law relating to the Issuer the expenses so incurred and compensation for services so rendered are intended to constitute expenses of administration under Bankruptcy Law. As security for the performance of the obligations of the Issuer under this Section, the Trustee shall have a lien prior to the lien securing the Bonds, which it may exercise through a right of setoff, upon all property or funds held or collected by the Trustee pursuant to this Indenture (other than moneys in the Rebate Fund). The obligations of the Issuer to make the payments described in this Section shall survive discharge of this Indenture, the resignation or removal of the Trustee and payment in full of the Bonds. Section 8.6 Oualifications of Trustee. There shall at all times be a trustee hereunder which shall be a corporation or banking association organized and doing business under the laws of the United States of America or of any state, authorized under such laws to exercise corporate trust powers, which has a combined capital and surplus of at least $50,000,000, or is an affiliate of, or has a contractual relationship with, a corporation or banking association meeting such capital and surplus requirement which guarantees the obligations and liabilities of the proposed trustee), and which is subject to supervision or examination by federal or state banking authority. If such corporation or banking association publishes reports of condition at least annually, 40 CH12_650171.5 pursuant to law or the requirements of any supervising or reexamining authority above referred to, then for purposes of this Section, the combined capital and surplus of such corporation or banking association shall be deemed to be its combined capital and surplus as set forth in its most recent report of condition so published. If at any time the Trustee shall cease to be eligible in accordance with the provisions of this Section, it shall resign promptly in the manner and with the effect specified in this Article. Section 8.7 Resianation or Removal of Trustee: Appointment of Successor Trustee. (a) No resignation or removal of the Trustee and no appointment of a successor Trustee pursuant to this Article shall become effective until the acceptance of appointment by the successor Trustee under Section 8.8. (b) The Trustee may resign at any time by giving written notice to the Issuer. Upon receiving such notice of resignation, the Issuer shall promptly appoint a successor Trustee by an instrument in writing. If an instrument of acceptance has not been delivered to the resigning Trustee within thirty (30) days after the giving of such notice of resignation, the resigning Trustee or any holder of a Bond then Outstanding may petition a court of competent jurisdiction for the appointment of a successor Trustee. (c) Prior to the occurrence and continuance of an Event of Default hereunder, or after the curing or waiver of any such Event of Default, the Issuer, the holders of a majority in aggregate principal amount of the Outstanding Bonds, may remove the Trustee and shall appoint a successor Trustee. In the event there shall have occurred and be continuing an Event of Default hereunder, the holders of a majority in aggregate principal amount of the Outstanding Bonds may remove the Trustee and shall appoint a successor Trustee. In each instance such removal and appointment shall be accomplished by an instrument or concurrent instruments in writing signed by the Issuer or such holders, as the case may be, and delivered to the Trustee, the Issuer and holders of the Outstanding Bonds. (d) If at any time: (1) the Trustee shall cease to be eligible and qualified under Section 8.6 and shall fail or refuse to resign after written request to do so by the Issuer or the holder of any Bond, or (2) the Trustee shall become incapable of acting or shall be adjudged insolvent, or a receiver of the Trustee or its property shall be appointed, or any public officer shall take charge or control of the Trustee, its property or affairs for the purpose of rehabilitation, conservation or liquidation, then in either such case (A) the Issuer may remove the Trustee and appoint a successor Trustee in accordance with the provisions of subsection (c) of this Section; or (B) any holder of a Bond then Outstanding may, on behalf of the holders of all Outstanding Bonds, petition a court of competent jurisdiction for removal of the Trustee and appointment of a successor Trustee. (e) The Issuer shall give written notice of each resignation or removal of the Trustee and each appointment of a successor Trustee to each holder of Bonds then Outstanding as listed in the Bond Register. Each such notice shall include the name and address of the applicable corporate trust office of the successor Trustee. Section 8.8 Acceptance of Appointment by Successor Trustee. 41 CH12_650171.5 (a) Every successor Trustee appointed hereunder shall execute, acknowledge and deliver to the Issuer and the predecessor Trustee an instrument accepting its appointment. The resignation or removal of the retiring Trustee shall thereupon become effective, and the successor Trustee shall, without further act, deed or conveyance become vested with all the estates, properties, rights, powers and duties of the predecessor Trustee. Upon the request of the Issuer or the successor Trustee, the predecessor Trustee shall execute and deliver an instrument transferring to the successor Trustee all the estates, properties, rights, powers and duties of the predecessor Trustee under this Indenture, and shall duly assign, transfer, deliver and pay over to the successor Trustee all the Trust Estate and moneys and other property then held under this Indenture, subject, however, to the lien provided for in Section 8.5. The successor Trustee shall promptly give written notice of its appointment to the holders of all Bonds Outstanding in the manner prescribed herein, unless such notice has previously been given. (b) No successor Trustee shall accept appointment as provided in this Section unless, as of the date of such acceptance, it is eligible and qualified under the provisions of Section 8.6. Section 8.9 Mercer, Succession or Consolidation of Trustee. Any corporation or association: (a) into which the Trustee is merged or with which it is consolidated; (b) resulting from any merger or consolidation to which the Trustee is a parry; or (c) succeeding to all or substantially all of the corporate trust business of the Trustee, shall be the successor Trustee without the execution or filing of any document or the taking of any further action. Any such successor must nevertheless be eligible and qualified under the provisions of Section 8.6. Section 8.10 Notices to Bondholders; Waiver. Where this Indenture provides for notice to Bondholders of any event, such notice shall be sufficiently given (unless otherwise herein expressly provided) if in writing and mailed, first -class postage prepaid, to each Bondholder affected by each event, at his or her address as it appears on the Bond Register, not later than the latest date, and not earlier than the earliest date, prescribed for the first giving of such notice. In any case where notice to Bondholders is given by mail, neither the failure to mail such notice, nor any default in any notice so mailed to any particular Bondholder shall affect the sufficiency of such notice with respect to other Bondholders. Where this Indenture provides for notice in any manner, such notice may be waived in writing by the Person entitled to received such notice, either before or after the event, and such waiver shall be the equivalent of such notice. Waivers of notice by Bondholders shall be filed with the Trustee, but such filing shall not be a condition precedent to the validity of any action taken in reliance upon such waiver. For so long as the Bonds are registered solely in the name of the Securities Depository or its nominee, the Trustee, on behalf of the Issuer, shall maintain a register (the `Beneficial Owner Register") in which the Trustee shall record the name and address of any person that is identified to the Trustee as a beneficial owner of an interest in the Bonds and for which the Trustee has: (i) information sufficient to permit delivery of first class mail and (ii) either:(x) a certificate executed, as depository or securities intermediary, by any trust company, bank, banker or member of a national securities exchange (wherever situated), if such certificate is in form satisfactory to the Trustee, or (y) a certificate or affidavit of the Person executing such instrument or writing as a beneficial owner if such certificate or affidavit is in form satisfactory to the Trustee or (z) such other instrument or writing as the Trustee deems sufficient for the purposes of this Section. The Trustee and the Issuer shall not be responsible for the accuracy of 42 CH 12_650171.5 the Beneficial Owner Register, and no Person listed in the Beneficial Owner Register shall be entitled to any rights under this Indenture other than the right to receive notices in the manner provided in the following paragraph. For so long as the Bonds are registered solely in the name of the Securities Depository or its nominee, where this Indenture provides for notice to the Bondholders of the existence of, or during the continuance of, any Event of Default or at any time upon the written request of the Issuer, the Trustee, at the expense of the Issuer, shall: (i) establish a record date (the " Record Date ") for determination of the Persons entitled to receive such notice; (ii) request a securities position listing from the Securities Depository showing the Depository Participants holding positions in the Bonds affected by such notice as of the Record Date for such notice; (iii) mail, first class postage prepaid, copies of the notice as provided above to each Depository Participant identified in the securities position listing as holding a position in the Bonds as of the Record Date for the notice, to each Person listed in the Beneficial Owner Register, to each nationally recognized municipal securities information repository and state information depository (within the meaning of Rule 15c2 -12 of the United States Securities and Exchange Commission under the Securities Exchange Act of 1934), and to any Person identified to the Trustee as a nonobjecting beneficial owner pursuant to the immediately following clause; (iv) request that the Depository Participant retransmit the notice to all Persons for which it served as nominee on the Record Date, including nonobjecting beneficial owners, or retransmit the notice to objecting beneficial owners and provide a listing of nonobjecting beneficial owners for whom the Depository Participant served as nominee on the Record Date to the Trustee, (v) provide on behalf of the Issuer and not as its agent, an undertaking of the Issuer to pay to any Depository Participant or other nominee (other than the Securities Depository) the reasonable costs of transmitting the notice to Persons for whom the Depository Participant acts as nominee; and (vi) provide as many copies of the notice as may be requested by any nominee owner of the Bonds. Any default in performance of the duties required by this paragraph shall not affect the sufficiency of notice to the Bondholders given in accordance with the first paragraph of this Section, nor the validity of any action taken under this Indenture in reliance on such notice to Bondholders. Where this Indenture provides for notice to the Bondholders of any event, the form of the notice shall prominently include a title block, separate from the body of the notice, which shall include the following information: (i) the complete title of the Bonds; (ii) the complete name of the Issuer; (iii) the entire nine -digit CUSIP number of each affected maturity of the Bonds; (iv) the Record Date; and (v) a summary that is no more than the maximum number of characters permitted by the Securities Depository. Any notice required or permitted by this Indenture to be given to the Securities Depository shall be given to it in the manner provided by this Section forgiving notice to Bondholders, and also shall be given in ASCII (or other format requested by the Securities Depository) format on magnetic medium, and shall be sent to: The Depository Trust Company, Proxy Department, 55 Water Street, 50th Floor, New York, New York 10041 -0099, (telecopy: (212) 855 - 5181), or such other address as may be specified by the Securities Depository in writing to the Trustee. 43 CH12_650171.5 ARTICLE IX DISCHARGE AND DEFEASANCE Section 9.1 Discharae. If (a) the principal of any Bonds and the interest due or to become due thereon together with any redemption premium required by redemption of any of the Bonds prior to maturity shall be paid, or is caused to be paid, or is provided for under Section 9.2, at the times and in the manner to which reference is made in the Bonds, according to the true intent and meaning thereof, or the outstanding Bonds shall have been paid and discharged in accordance with this Article, and (b) all of the covenants, agreements, obligations, terms and conditions of the Issuer under this Indenture shall have been kept, performed and observed and there shall have been paid to the Trustee, the Bond Registrar and the Paying Agents all sums of money due or to become due to them in accordance with the terms and provisions hereof, then the right, title and interest of the Trustee in the Trust Estate shall there upon cease and the Trustee, on request and at the expense of the Issuer, shall release this Indenture and the Trust Estate and shall execute such documents to evidence such release as may be reasonably required by the Issuer and shall turnover to the Issuer, or to such other Person as may be entitled to receive the same, all balances remaining in any Funds hereunder except for amounts required to pay such Bonds or held pursuant to Section 4.9. Section 9.2 Defeasance; Deposit of Funds for Payment of Bonds. If the Issuer deposits with the Trustee moneys or Defeasance Obligations which, together with the earnings thereon, are sufficient to pay the principal of and redemption premium on any particular Bond or Bonds becoming due, either at maturity, by means of mandatory sinking fund redemption or by call for optional redemption or otherwise, together with all interest accruing thereon to the due date or Redemption Date, and pays or makes provision for payment of all fees, costs and expenses of the Issuer and the Trustee due or to become due with respect to such Bonds, all liability of the Issuer with respect to such Bond or Bonds shall cease, such Bond or Bonds shall be deemed not to be Outstanding hereunder and the holder or holders of such Bond or Bonds shall be restricted exclusively to the moneys or Defeasance Obligations so deposited, together with any earnings thereon, for any claim of whatsoever nature with respect to such Bond or Bonds, and the Trustee shall hold such moneys, Defeasance Obligations and earnings in trust for such holder or holders. In dete the sufficiency of the moneys and Defeasance Obligations deposited pursuant to this Section, the Trustee shall receive, at the expense of the Issuer, and may rely upon: (a) a verification report of a firm of nationally recognized independent certified public accountants or other qualified firm acceptable to the Issuer and the Trustee; and (b) an opinion of Bond Counsel to the effect that (1) all conditions set forth in this Article have been satisfied and (2) that defeasance of the Bonds will not cause interest on the Bonds to be includable in gross income for federal income tax purposes. Upon such defeasance all rights of the Issuer, including its right to provide for optional redemption of Bonds on dates other than planned pursuant to such defeasance, shall cease unless specifically retained by filing 44 CH12_650171.5 a written notification thereof with the Trustee at the time the Defeasance Obligations are deposited with the Trustee. At such times as a Bond shall be deemed to be paid hereunder, as aforesaid, it shall no longer be secured by or entitled to the benefits of this Indenture, except for the purposes of any such payment from such money or Defeasance Obligations and except for the provisions of this Section, Section 2.3, 2.4, 2.5, 2.7, 2.8, 2.10, 2.11, 2.12, 4.3, 11.8 and Article X, and the Issuer shall continue to be subject to the provisions of Section 8.5. Section 9.3 Notice of Defeasance. (a) In case any of the Bonds, for the payment of which moneys or Defeasance Obligations have been deposited with the Trustee pursuant to Section 9.2, are to be redeemed on any date prior to their maturity, the Issuer shall give to the Trustee in form satisfactory to it irrevocable instructions to give notice of redemption of such Bonds on the redemption date for such Bonds as provided in Section 3.6. (b) In addition to the foregoing notice, in the event such Bonds to be redeemed are not by their terms subject to redemption within the next succeeding sixty (60) days, the Trustee shall give further notice to the Bondholders that the deposit required by Section 9.2 has been made with the Trustee and that said Bonds are deemed to have been paid in accordance with this Article and stating the maturity or redemption date or dates upon which moneys are to be available for the payment of the principal of and redemption premium, if any, on said Bonds; such further notice shall be given promptly following the making of the deposit required by Section 9.2; and such further notice also shall be given in the manner set forth Section 3.6(b); but no defect in said further notice nor any failure to give all or any portion of such further notice shall in any manner defeat the effectiveness of the deposit. (c) If the Issuer has retained any rights pursuant to the last sentence of Section 9.2, notice thereof shall be sent to Bondholders of such Bonds as soon as practicable and not later than any notice required by subsections (a) or (b) of this Section. ARTICLE X SUPPLEMENTAL INDENTURES AND AMENDMENTS Section 10.1 Supplemental Indentures Without Bondholders' Consent. The Issuer and the Trustee may from time to time and at any time enter into trust indentures supplemental to this Indenture, without the consent of or notice to any Bondholder, to effect any one or more of the following: (a) cure any ambiguity or defect or omission or correct or supplement any provision herein or in any supplemental indenture; (b) grant to or confer upon the Trustee for the benefit of the Bondholders any additional rights, remedies, powers, authority or security that may lawfully be granted to or conferred upon the Bondholders or the Trustee which are not contrary to or inconsistent with this Indenture as then in effect or to subject to the pledge and lien of 45 CH12_650171.5 this Indenture additional revenues, properties or collateral including Defeasance Obligations; i (c) add to the covenants and agreements of the Issuer in this Indenture other covenants and agreements thereafter to be observed by the Issuer or to surrender any right or power herein reserved to or conferred upon the Issuer which are not contrary to or inconsistent with this Indenture as then in effect; (d) permit the appointment of a co- trustee under this Indenture; (e) modify, alter, supplement or amend this Indenture in such manner as shall permit the qualification of this Indenture, if required, under the Trust Indenture Act of 1939 or, the Securities Act of 1933, as from time to time amended, or any. similar federal statute hereafter in effect; (f) make any other change herein that is determined by the Trustee to be not materially adverse to the interests of the Bondholders; or (g) if the Bonds are all Book Entry Bonds, amend, modify, alter or replace the Letter of Representations as provided in Section 2.12 or other provisions relating to Book Entry Bonds. The Trustee shall not be obligated to enter into any such supplemental indenture which adversely affects the Trustee's own rights, duties or immunities under this Indenture. Section 10.2 Supplemental Indentures Requirina Bondholders.' Consent. The Issuer and the Trustee, at any time and from time to time, may execute and deliver a supplemental indenture for the purpose of making any modification or amendment to this Indenture, but only with the written consent, given as provided in Section 10.3, of the holders of at least two- thirds in aggregate principal amount of the Bonds Outstanding at the time such consent is given, and in case less than all of the Bonds then Outstanding are affected by the modification or amendment, of the holders of at least two - thirds in aggregate principal amount of the Bonds so affected and Outstanding at the time such consent is given; provided, however, that if such modification or amendment will, by its terms, not take effect so long as any Bonds so affected remain Outstanding, the consent of the holders of such Bonds shall not be required and such Bonds shall not be deemed to be Outstanding for the purpose of any calculation of Outstanding Bonds under this Section. Notwithstanding the foregoing, no modification or amendment contained in any such supplemental indenture shall permit any of the following, without the consent of each Bondholder whose rights are affected thereby: (a) a change in the terms of stated maturity or redemption of any Bond or of any installment of interest thereon; (b) a reduction in the principal amount of or redemption premium on any Bond or in the rate of interest thereon or a change in the coin or currency in which such Bond is payable; (c) the creation of a lien on or a pledge of any part of the Trust Estate, or the money or assets pledged under this Indenture or any part thereof; (d) the granting of a preference or priority of any Bond or Bonds over any other Bond or Bonds; (e) a reduction in the aggregate principal amount of Bonds of which the consent of the Bondholders is required to effect any such modification or amendment; or (f) a change in the provisions of Section 7.15. Notwithstanding the foregoing, the holder of any Bond may extend 46 CH12_650171.5 the time for payment of the principal of or interest on such Bond; provided, however, that upon the occurrence of an Event of Default, funds available hereunder for the payment of the principal of and interest on the Bonds shall not be applied to any payment so extended until all principal and interest payments which have not been extended have first been paid in full. Notice of any supplemental indenture executed pursuant to this Section shall be given to the Bondholders promptly following the execution thereof by the Issuer. Section 10.3 Consents of Bondholders and Opinions. Each supplemental indenture executed and delivered pursuant to the provisions of Section 10.2 shall take effect only when and as provided in this Section 10.3. A copy of such supplemental indenture (or brief summary thereof or reference thereto in form approved by the Trustee), together with a request to Bondholders for their consent thereto in form satisfactory to the Trustee, shall be sent by the Trustee to Bondholders, at the expense of the Issuer, by first class mail, postage prepaid, provided that a failure to mail such request shall not affect the validity of the supplemental indenture when consented to as provided hereinafter. Such supplemental indenture shall not be effective unless and until there shall have been filed with the Trustee (a) the written consents of Bondholders of the percentage of Bonds specified in Section 10.2 given as provided in Section 11. 11, and (b) the opinion of Counsel described in Section 10.5. Any such consent shall be binding upon the Bondholder giving such consent and upon any subsequent holder of such Bonds and of any Bonds issued in exchange therefore or in lieu thereof (whether or not such subsequent Bondholder has notice thereof), unless such consent is revoked in writing by the Bondholder giving such consent or a subsequent holder of such Bonds by filing such revocation with the Trustee prior to the date the Trustee receives the material required in subsections (a) and (b) of this Section. Section 10.4 Notation on Bonds. Bonds authenticated and delivered after the effective date of any action taken as provided in this Article may, and, if the Issuer so determines, shall bear a notation by endorsement or otherwise in form approved by the Trustee as to such action, and in that case upon demand of the holder of any Outstanding Bond at such effective date and presentation of such Bond for the purpose at the Office of the Trustee, or upon any transfer of any Bond Outstanding at such effective date, suitable notation shall be made on such Bond or upon any Bond issued upon any such transfer by the Trustee as to any such action. If the Issuer shall so determine, new Bonds so modified as in the opinion of the Trustee and the Issuer to conform to such action shall be prepared, authenticated and delivered, and upon demand of the holder of any Bond then Outstanding shall be exchanged, without cost to such Bondholder for Bonds then Outstanding, upon surrender of such Bonds for Bonds of an equal aggregate principal amount and of the same maturity and interest rate, in any Authorized Denomination. Section 10.5 Delivery of Counsel's Opinion with Respect to Supplemental Indentures. Subject to the provisions of Section 8.1, the Trustee in executing or accepting the additional trusts permitted by this Article or the modifications thereby of the trusts created by this Indenture may rely, and shall be fully protected in relying, on an opinion of Counsel acceptable to it stating that (a) the execution of such supplemental indenture is authorized or permitted by this Indenture and (b) all conditions precedent to the execution and delivery of such supplemental indenture have been complied with, and an opinion of Bond Counsel that the execution and performance of such supplemental indenture shall not, in and of itself, adversely affect the federal income tax status of the Bonds. The Trustee may accept and rely upon such opinion of Counsel as 47 CH12 650171.5 conclusive evidence that any supplemental indenture executed pursuant to the provisions of this Article complies with the requirements of this Article. Section 10.6 Effect of Supplemental Indentures. Upon the execution and delivery of any supplemental indenture under this Article, this Indenture shall be modified in accordance therewith, and such supplemental indenture shall form a part of this Indenture for all purposes; and every holder of any Bond theretofore or thereafter authenticated and delivered hereunder shall be bound thereby. ARTICLE XI MISCELLANEOUS PROVISIONS Section 11.1 Securitv Agreement; Financing Statements. In addition to the assignment by the Issuer of its rights in the Trust Estate to the Trustee, the Issuer hereby acknowledges that, in order to more fully protect, perfect and preserve the rights of the Trustee and the Bondholders in the Trust Estate, the Issuer grants to the Trustee a security interest in the Trust Estate and the proceeds thereof. The Issuer agrees to cooperate with the Trustee in filing financing statements, and continuations thereof, in such manner and in such places as may be required by law to perfect.such security interest; provided that the Trustee shall not be responsible for filing or for the sufficiency or accuracy of any financing statements initially filed to perfect security interests granted under this Indenture. At the time of the issuance of the Bonds and at the required intervals under applicable State law, the Trustee, at the expense of the Issuer, may obtain an opinion of Counsel setting forth what, if any, actions by the Issuer or Trustee should be taken in order to protect, perfect and preserve such security interest. The Trustee shall file continuation statement with respect to each UCC financing statement relating to the Bonds filed at the time of the issuance thereof, provided that a copy of the filed financing statement is timely delivered to the Trustee. The following information is supplied to facilitate filings under the Uniform Commercial Code of the State: The secured party is The Bank of New York Trust Company, N.A. Its address from which information concerning the security interest may be obtained and its mailing address is: 2 North LaSalle Street, Suite 1020, Chicago, Illinois 60602. The debtor is United City of Yorkville. Its mailing address is: 800 Game Farm Road, Yorkville, Illinois 60560. Section 11.2 Limitation of Rights. With the exception of rights herein expressly conferred, nothing expressed or mentioned in or to be implied from this Indenture or the Bonds is intended or shall be construed to give to any Person other than the parties hereto, and the Bondholders any legal or equitable right, remedy or claim under or in respect to this Indenture. This Indenture and all of the covenants, conditions and provisions hereof are intended to be and are for the sole and exclusive benefit of the parties hereto and the Bondholders as herein provided. Section 11.3 Severabilitv. If any term or provision of this Indenture or the Bonds shall be invalid, inoperative or unenforceable as applied in any particular case in any jurisdiction or 48 CH12_650171.5 jurisdictions or in all jurisdictions, or in all cases because it conflicts with any other provision or provisions hereof or any constitution or statute or rule of public policy, or for any other reason, such circumstances shall not have the effect of rendering the provision in question inoperative or unenforceable in any other case or circumstance, or of rendering any other provision or provisions herein contained invalid, inoperative, or unenforceable to any extent whatever, and such term and provision shall be valid and enforced to the fullest extent permitted by law. Section 11.4 Notices. Except as otherwise provided herein, all notices, certificates or other communications hereunder shall be in writing and shall be deemed given upon receipt, by hand delivery, mail, overnight delivery, telecopy or other electronic means addressed as follows: Issuer: United City of Yorkville 800 Game Farm Road Yorkville, Illinois 60560 Attention: Mayor Trustee: The Bank of New York Trust Company, N.A. 2 North LaSalle Street, Suite 1020 Chicago, Illinois 60602 Attention: Corporate Trust Department Business District The Bank of New York Trust Company, N.A. Sales Tax Trustee: 2 North LaSalle Street, Suite 1020 Chicago, Illinois 60602 Attention: Corporate Trust Department Sales Tax Revenue The Bank of New York Trust Company, N.A. Bond Trustee: 2 North LaSalle Street, Suite 1020 Chicago, Illinois 60602 Attention: Corporate Trust Department In case by reason of the suspension of regular mail service, it shall be impracticable to give notice by first class mail of any event to any Bondholder or the Issuer when such notice is required to be given pursuant to any provisions of this Indenture, then any manner of giving such notice as shall be satisfactory to the Trustee shall be deemed to be sufficient giving of such notice. The Issuer and the Trustee may, by notice pursuant to this Section, designate any different addresses to which subsequent notices, certificates or other communications shall be sent. A duplicate copy of each notice, approval, consent, request, complaint, demand or other communication given hereunder by the Issuer or the Trustee to any one of the others shall also be given to the others. For purposes of this Section and the definition of Immediate Notice, "electronic means" shall mean telecopy or facsimile transmission or other similar electronic means of communication which produces evidence of transmission. Notwithstanding the foregoing, notices to the Trustee shall be effective only upon receipt. Section 11.5 Holidays. If the date for making any payment or the last date for performance of any act or the exercising of any right, as provided in this Indenture, is not a 49 CH12_650171.5 Business Day, such payment may be made or act performed or right exercised on the next succeeding Business Day with the same force and effect as if done on the nominal date provided in this Indenture and no interest shall accrue on the payment so deferred during the intervening period. Section 11.6 Counterparts. This Indenture may be executed in any number of counterparts, each of which when so executed and delivered shall constitute an original, but all of which, when taken together, shall constitute but one and the same instrument, and shall become effective when copies hereof shall be delivered to each of the parties hereto, which copies, when taken together, bear the signatures of each of the parties hereto. Section 11.7 Applicable Law. This Indenture shall be governed in all respects including validity, interpretation and effect by, and shall be enforceable in accordance with, the laws of the United States of America and of the State. Section 11.8 Limitation of Liability of Officials of the Issuer. Notwithstanding anything to the contrary contained herein, for payment of the obligations of the Issuer under this Indenture and the Bonds, the Trustee, the Bondholders and any other party entitled to seek payment from the Issuer under or to enforce this Indenture and the Bonds will be entitled to look solely to amounts on deposit with and held by the Trustee for the benefit of the Bondholders, subject to the terms of this Indenture, and no other property or assets of the Issuer or any officer or director of the Issuer shall be subject to levy, execution or other enforcement procedure for the satisfaction of the remedies hereunder, or for any payment required to be made under this Indenture and the Bonds, or for the performance of any of the covenants or warranties contained herein. Section 11.9 Successors and Assil?'ns. All the covenants, promises and agreements in this Indenture contained by or on behalf of the Issuer, or by or on behalf of the Trustee, shall bind and inure to the benefit of their respective successors and assigns, whether so expressed or not. Section 11.10 Form of Documents Delivered to Trustee. In any case where several matters are required to be certified by, or covered by an opinion of any specified person, it is not necessary that all such matters be certified by, or covered by the opinion of, only one such person, or that they be so certified or covered by only one document, but one such person may certify or give an opinion with respect to some matters and one or more other such persons as to other matters, and any such person may certify or give an opinion as to such matters in one or several documents. Any Officer's Certificate of the Issuer may be based, insofar as it relates to legal matters, upon a certificate or opinion of, or representations by, Counsel, unless such official or officer knows, or in the exercise of reasonable care should know, that the certificate or opinion or representations with respect to the matters upon which his or her certificate or opinion is based are erroneous. Any opinion of Counsel may be based, insofar as it relates to factual matters, upon a certificate or opinion of, or representations by, an official or officials of the Issuer or an officer or officers of the Issuer stating that the information with respect to such factual matters is in the possession of the Issuer, unless such Counsel knows, or in the exercise of reasonable care 50 CH12 650171.5 should know, that the certificate or opinion or representations with respect to such matters are erroneous. Where any person is required to make, give or execute two or more applications, requests, consents, certificates, statements, opinions or other instruments under this Indenture, they may, but need not, be consolidated and form one instrument. Section 11.11 Consent of Holders. Any consent, request, direction, approval, objection or other instrument required by this Indenture to be signed and executed by the Bondholders may be in any number of concurrent writings of similar tenor and must be signed or executed by such Bondholders in person or by agent appointed in writing. Proof of the execution of any such consent, request, direction, approval, objection or other instrument or of the writing appointing any such agent and of the ownership of Bonds, if made in the following manner, shall be sufficient for any of the purposes of this Indenture, and shall be conclusive in favor of the Trustee with regard to any action taken by it under such request or other instrument, namely: (a) The fact and date of the execution by any person of any such writing may be proved by the certificate of any officer in any jurisdiction who by law has power to take acknowledgments within such jurisdiction that the person signing such writing acknowledged the execution thereof, or by an affidavit of any witness to such execution. (b) The Trustee may establish a Record Date for the purpose of identifying Bondholders entitled to issue any such consent, 'request, direction, approval or instrument. 51 CHI2_650171.5 IN WITNESS WHEREOF, the Issuer has caused this Indenture to be signed in its name by its Executive and attested by its Attesting Officer, and the Trustee, in acceptance of the trusts 1 created hereunder, has caused this Indenture to be signed in its corporate name by its officer thereunder duly authorized all as of the day and year first above written. UNITED CITY OF YORKVILLE, KENDALL COUNTY, ILLINOIS By: Its: (SEAL) ATTEST: By: Title: THE BANK OF NEW YORK TRUST COMPANY, N.A., as Trustee By: Its: (SEAL) ATTEST: By: Authorized Signatory 52 CH12_650171.5 APPENDIX A FORM OF BOND UNITED STATES OF AMERICA STATE OF ILLINOIS COUNTY OF KENDALL UNITED CITY OF YORKVILLE KENDALL COUNTY, ILLINOIS SPECIAL SERVICE AREA NUMBER 2006 -113 AD VALOREM TAX BOND SERIES 2007 (CANNONBALL/BEECHER ROAD PROJECT) Bond No. Principal Amount: $ Date of Bond: , 2006 Interest Rate: % CUSIP: Date of Maturity: Registered Owner: Cede & Co. The United City of Yorkville, Kendall County, Illinois (the "C "), for value received, promises to pay to the Registered Owner specified above or registered assigns, upon presentation and surrender of this bond at the office of The Bank of New York Trust Company, N.A., East Syracuse, New York, as Trustee (the "Trustee ") the Principal Amount of this bond specified above on the Date of Maturity specified above and to pay the Registered Owner of this bond interest on that sum at the Interest Rate per year specified above from the Date of Bond specified above to the Date of Maturity specified above, payable semiannually on March 1 and September 1, with the first interest payment date being March 1, 2008. Interest shall be computed on the basis of a 360 -day year of twelve 30 -days months. Interest on this bond shall be payable on each interest payment date by check or draft of the Trustee mailed to the person in whose name this bond is registered at the close of business on the 15th day of the month preceding such interest payment date. During such time as this bond is registered so as to participate in a securities depository system with The Depository Trust Company ( " DTC "), principal of and interest on this Bond shall be payable by wire transfer pursuant to instructions from DTC. The principal of, interest on and redemption premium on this bond are payable in lawful money of the United States of America. No interest shall accrue on this bond after its Date of Maturity unless this bond shall have been presented for payment at maturity and shall not then have been paid. This bond is one of an authorized issue of bonds in the aggregate principal amount of $ . This bond and the issue of which it is a part (together, the " Bonds ") are issued pursuant to the provisions of the "Special Service Area Tax Law," 35 ILCS §200/27 -5 et seq., as amended, and the provisions of the Local Government Debt Reform Act, 30 ILCS §350/1 et seq., A -1 CHI2_650171.5 as amended, and the principal of and interest on the Bonds are payable from ad valorem taxes (the "Ad Valorem Taxes ") levied on all taxable real property within the United City of Yorkville 3 Special Service Area Number 2006 -113 (the "Special Service Area "). The Bonds are being issued for the purpose of paying a portion of the costs of special services to be provided to the Special Service Area, all as more fully described in an ordinance adopted by the City Council of the City on March 27, 2007 (the "Bond Ordinance ") and a Trust Indenture dated as of April 1, 2007 between the City and the Trustee (the "Indenture "), to all the provisions of which the holder by the acceptance of this bond assents. Terms not otherwise defined herein shall have the meanings ascribed to such terms in the Indenture. The Bonds, together with the interest thereon, are limited obligations of the City, payable solely from the collection of the Ad Valorem Taxes and other r moneys deposited in certain Funds and Accounts established pursuant to the Indenture. For the prompt payment of the principal of and interest on this bond the Ad Valorem Taxes are hereby irrevocably pledged. THE BONDS DO NOT CONSTITUTE GENERAL OBLIGATIONS OF THE CITY AND NEITHER THE FULL FAITH AND CREDIT NOR THE UNLIMITED TAXING POWER OF THE CITY SHALL BE PLEDGED AS SECURITY FOR THE PAYMENT OF THE BONDS. The Bonds are subject to mandatory sinking fund redemption and final payment at a price of par plus accrued interest, without premium, on March 1, of the years and in the amounts as follows: Year Amount i 2012 $ 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 The Bonds are subject to optional redemption prior to maturity at the option of the City, in whole or in part, on any date on or after March 1, 2017, at a redemption price (expressed as a percentage of the principal amount of the Bonds to be redeemed), as set forth below, plus accrued and unpaid interest to the date of redemption: A -2 CH12_650171.5 I Redemption Dates Redemption Prices i March 1, 2017 through February 28, 2018 102% March 1, 2018 through February 28, 2019 101 March 1, 2019 and thereafter 100 The Bonds are subject to mandatory redemption on any Interest Payment Date, in part, at a redemption price equal to the principal amount to be redeemed, together with accrued interest to the date fixed for redemption, without premium, from amounts transferred from the Improvement Fund to the Bond and Interest Fund. If less than all the Bonds of any maturity are to be redeemed on any redemption date, they shall be redeemed in inverse order of maturity and in inverse order of sinking fund installments within any maturity, except as otherwise provided in the Indenture. Notice of the redemption of any Bonds, which by their terms shall have become subject to redemption, shall be given to the Notice Beneficial Owners, as defined in the Indenture, and the registered owner of each Bond called for redemption in whole or in part not less than 20 or more than 60 days before any date established for redemption of Bonds, by the Bond Registrar, on behalf of the City, by registered or certified mail sent to the registered owner's last address, if any, appearing on the registration books kept by the Bond Registrar. This bond is negotiable, subject to the following provisions for registration and registration of transfer. The City maintains books for the registration and registration of transfer of Bonds at the office of the Trustee, as Bond Registrar. This bond is fully registered on those books in the name of its owner, as to both principal and interest, and transfer of this bond may be registered on those books upon surrender of this bond to the Bond Registrar by the registered owner or his or her attorney duly authorized in writing together with a written instrument of transfer satisfactory to the Bond .Registrar duly executed by the registered owner or his or her duly authorized attorney. Upon surrender of this bond for registration of transfer, a new bond or bonds in the same aggregate principal amount and of the same maturity will be issued to the transferee as provided in the Indenture. This bond may be exchanged, at the option of the Registered Owner, for an equal aggregate principal amount of bonds of the same maturity of any other Authorized Denominations, upon surrender of this bond at the corporate trust office of the Bond Registrar in East Syracuse, New York with a written instrument of transfer satisfactory to the Bond Registrar duly executed by the Registered Owner or his or her duly authorized attorney. For every exchange or registration of transfer of this bond, the City or the Bond Registrar may make a charge sufficient to reimburse it for any tax, fee or other governmental charge, other than one imposed by the City, required to be paid with respect to that exchange or registration of transfer, and payment of that charge by the person requesting exchange or registration of transfer A -3 CH12_650171.5 shall be a condition precedent to that exchange or registration of transfer. No other charge may be made by the City or the Bond Registrar as a condition precedent to exchange or registration of transfer of this bond. The Bond Registrar shall not be required to exchange or register the transfer of any Bond following the close of business on the 15th day of the month preceding any interest payment date on such Bond, nor to transfer or exchange any Bond after notice calling such Bond for redemption has been mailed, nor during a period of 15 days next preceding mailing of a notice of redemption of any Bonds. The City, the Trustee and the Bond Registrar may deem and treat the registered owner of this bond as its absolute owner, whether or not this bond is overdue, for the purpose of receiving payment of the principal of or interest on this bond and for all other purposes, and neither the City, the Bond Registrar nor the Trustee shall be affected by any notice to the contrary. Payment of the principal of and interest on this bond shall be made only to its registered owner, and all such payments shall be valid and effective to satisfy the obligation of the City on this bond to the extent of the amount paid. All conditions which by law must have existed or must have been fulfilled in the issuance of this bond existed and were fulfilled in compliance with law. Provision has been made for the levy, collection and segregation of the Ad Valorem Taxes sufficient to pay and discharge the principal of this bond at maturity and to pay interest on this bond as it falls due. The issuance of the Bonds by the City will not cause the City to exceed or violate any applicable limitation or condition respecting the issuance of bonds imposed by the law of the State of Illinois or by any 1, indenture, ordinance or resolution of the City. The Bonds are issued for purposes for which the City is authorized by law to issue bonds including but not limited to the payment of a portion of the costs of the. special services to be provided to the Special Service Area making deposits to a p p p � g p reserve fund, administrative expense fund and a capitalized interest account, and paying costs of the City in connection with the issuance of the Bonds. This bond shall not be valid for any purpose unless and until the certificate of authentication on this bond shall have been duly executed by the Trustee. �I i �I A -4 CH12_650171.5 IN WITNESS WHEREOF, the United City of Yorkville, Kendall County, Illinois, by its City Council, has caused this bond to be executed by the manual or facsimile signature of its Mayor and attested by the manual or facsimile signature of its City Clerk and has caused its corporate seal to be affixed to this bond (or a facsimile of its seal to be printed on this bond), all as of the Date of Bond specified above. UNITED CITY OF YORKVILLE, ILLINOIS By: Mayor (SEAL) ATTEST: City Clerk Date of Authentication: i This bond is one of the bonds described in the Indenture authorizing the issuance of $ United City of Yorkville, Kendall County, Illinois Special Service Area Number 2006 -113 Ad Valorem Tax Bonds, Series 2007 (Cannonball/Beecher Road Project). THE BANK OF NEW YORK TRUST COMPANY, N.A., as Trustee By: Authorized Signatory For Value Received, the undersigned sells, assigns and transfers to this bond and all rights and title under this bond, and irrevocably constitutes and appoints attorney to transfer this bond on the books kept for registration of this bond. Dated: A -5 CHI2_650171.5 APPENDIX B DESCRIPTION OF SPECIAL SERVICE AREA NO. 2006-113 Legal Description of Property THAT PART OF THE SOUTHEAST QUARTER OF SECTION 19, PART OF THE SOUTH HALF OF SECTION 20 AND PART OF THE NORTHWEST QUARTER OF SECTION 29, TOWNSHIP 37 NORTH, RANGE 7 EAST OF THE THIRD PRINCIPAL MERIDIAN DESCRIBED AS FOLLOWS: BEGINNING AT THE SOUTHEAST CORNER OF THE SOUTHEAST QUARTER OF SAID SECTION 19; THENCE NORTH 01 DEGREES 13 MINUTES 53 SECONDS WEST, ALONG THE EAST LINE OF SAID SOUTHEAST QUARTER 310.20 FEET; THENCE WESTERLY PERPENDICULAR TO SAID EAST LINE 198.00 FEET; THENCE NORTH 16 DEGREES 23 MINUTES 58 SECONDS WEST, 862.81 FEET; THENCE NORTH 46 DEGREES 51 MINUTES 14 SECONDS EAST, 126.15 FEET; THENCE WESTERLY ALONG A NONTANGENTIAL CURVE TO THE RIGHT WITH A RADIUS OF 25.00 FEET AND A CHORD BEARING OF NORTH 86 DEGREES 29 MINUTES 53 SECONDS WEST, AN ARC LENGTH OF 40.71 FEET; THENCE NORTHWESTERLY ALONG A CURVE TO THE RIGHT WITH A RADIUS OF 950.00 FEET AND A CHORD BEARING OF NORTH 30 DEGREES 00 MINUTES 26 SECONDS WEST, AN ARC LENGTH OF 326.41 FEET; THENCE NORTH 67 DEGREES 35 MINUTES 57 SECONDS EAST, 243.73 FEET; THENCE SOUTHEASTERLY ALONG A NONTANGENTIAL CURVE TO THE LEFT WITH A RADIUS OF 500.00 FEET AND A CHORD BEARING OF SOUTH 31 DEGREES 07 MINUTES 50 SECONDS EAST, AN ARC ) LENGTH OF 209.70 FEET; THENCE SOUTH 43 DEGREES 08 MINUTES 45 SECONDS EAST, 52.80 FEET; THENCE NORTH 46 DEGREES 51 MINUTES 15 SECONDS EAST, 287.40 FEET; THENCE SOUTH 43 DEGREES 08 MINUTES 45 SECONDS EAST, 80.00 FEET; THENCE NORTH 46 DEGREES 51 MINUTES 15 SECONDS EAST, 162.29 FEET; THENCE NORTH 43 DEGREES 08 MINUTES 45 SECONDS WEST, 7.00 FEET; THENCE NORTH 46 DEGREES 51 MINUTES 15 SECONDS EAST, 60.76 FEET; THENCE NORTHEASTERLY ALONG A CURVE TO THE RIGHT WITH A RADIUS OF 367.00 FEET AND A CHORD BEARING OF NORTH 58 DEGREES 18 MINUTES 15 SECONDS EAST, AN ARC LENGTH OF 146.68 FEET; THENCE NORTH 69 DEGREES 45 MINUTES 15 SECONDS EAST, 121.97 FEET; THENCE NORTHEASTERLY ALONG A CURVE TO THE LEFT WITH A RADIUS OF 433.00 FEET AND A CHORD BEARING OF NORTH 37 DEGREES 51 MINUTES 31 SECONDS EAST, AN ARC LENGTH OF 482.09 FEET; THENCE NORTHEASTERLY ALONG A CURVE TO THE RIGHT WITH A RADIUS OF 25.00 FEET AND A CHORD BEARING OF NORTH 51 DEGREES 23 MINUTES 20 SECONDS EAST, AN ARC LENGTH OF 39.64 FEET; THENCE SOUTH 83 DEGREES 11 MINUTES 08 SECONDS EAST, 763.20 FEET; THENCE SOUTHEASTERLY ALONG A CURVE TO THE RIGHT WITH A RADIUS OF 367.00 FEET AND A CHORD BEARING OF SOUTH 57 DEGREES 07 MINUTES 07 SECONDS EAST, AN ARC LENGTH OF 333.94 FEET; THENCE SOUTH 31 DEGREES 03 MINUTES 05 SECONDS EAST, 123.11 FEET; THENCE SOUTH 58 DEGREES 56 MINUTES 55 SECONDS WEST, 7.00 FEET; THENCE SOUTHEASTERLY ALONG A NONTANGENTIAL CURVE TO THE LEFT WITH A RADIUS OF 440.00 FEET AND A CHORD BEARING OF SOUTH 42 DEGREES 20 MINUTES 40 SECONDS EAST, AN ARC LENGTH OF 173.45 FEET; THENCE NORTH 32 B -1 CHI2_650171.5 DEGREES 01 MINUTES 21 SECONDS EAST, 80.28 FEET; THENCE SOUTHEASTERLY ALONG A NONTANGENTIAL CURVE TO THE LEFT WITH A RADIUS OF 360.00 FEET AND A CHORD BEARING OF SOUTH 60 DEGREES 42 MINUTES 59 SECONDS EAST, AN ARC LENGTH OF 101.11 FEET; THENCE SOUTH 68 DEGREES 45 MINUTES 32 SECONDS EAST, 784.84 FEET TO THE CENTER LINE OF CANNONBALL TRAIL; THENCE SOUTH 21 DEGREES 40 MINUTES 31 SECONDS WEST, ALONG SAID CENTER LINE, 331.43 FEET; THENCE SOUTH 21 DEGREES 14 MINUTES 17 SECONDS WEST, ALONG SAID CENTER LINE, 1261.58 FEET; THENCE NORTH 68 DEGREES 45 MINUTES 43 SECONDS WEST, 48.00 FEET; THENCE SOUTH 21 DEGREES 14 MINUTES 17 WEST, 470.00 FEET; THENCE SOUTH 57 DEGREES 14 MINUTES 17 SECONDS WEST, 74.81 FEET TO THE NORTH LINE OF U.S. ROUTE 34; THENCE NORTH 85 DEGREES 32 MINUTES 10 SECONDS WEST ALONG SAID NORTH LINE, 1983.32 FEET TO THE WEST LINE OF THE NORTHWEST QUARTER OF SAID SECTION 29; THENCE NORTH 01 DEGREES 14 MINUTES 12 SECONDS WEST ALONG SAID WEST LINE, 378.99 FEET TO THE POINT OF BEGINNING, IN THE UNITED CITY OF YORKVILLE, KENDALL COUNTY, ILLINOIS, AND CONTAINING 143.40 ACRES OF LAND MORE OR LESS. PIN's 02 -19- 400 -003 02 -29- 100 -001 02-20-351-001 I B -2 CH 12_650171.5 APPENDIX C REQUEST FOR PAYMENT TO: The Bank of New York Trust Company, N.A., Trustee 2 North LaSalle Street, Suite 1020 Chicago, Illinois 60603 Attention: Corporate Trust Department i RE: $ United City of Yorkville Kendall County, Illinois Special Service Area Number 2006 -113 Ad Valorem Tax Bonds, Series 2007 (Cannonball/Beecher Road Project) Amount Requested: Total Disbursements to Date: 1. The United City of Yorkville, Kendall County, Illinois (the " Issuer " hereby requests that The Bank of New York Trust Company, N.A., as trustee (the "Trustee ") under the Trust Indenture for the above - referenced Ad Valorem Tax Bonds, Series 2007 dated as of April 1, 2007 (the "Indenture "), by and between the Issuer and the Trustee disburse on the Amount Requested above from the Improvement Fund (as such term is defined in the Indenture). All capitalized terms herein shall have the meanings assigned to them in the Indenture. 2. In connection with the requested disbursement, the Issuer hereby certifies as follows: (a) This written requisition is for payment of costs in connection with the issuance of the above - referenced Bonds or the construction of a Special Service or reimbursement for the costs of construction of Special Services. (b) The Issuer and the Developer have each complied with all requirements under the Development Agreement relating to the disbursement request. (c) The City Engineer has inspected the work for which payment is requested and has confirmed that the work for which payment is requested has been completed and payment therefore should be approved. (d) Payment instructions sufficient to make the requested payment are set forth in Exhibit A. (e) No portion of the amount being requested to be disbursed was set forth in any previous request for payment. By: Issuer Representative C -1 CH12_650171.5 EX44161T ccC UNITED CITY OF YORKVILLE KENDALL COUNTY, ILLINOIS Ad Valorem Tax Bonds, Series 2007 (Cannonball/Beecher Road Project) BOND PURCHASE AGREEMENT , 2007 United City of Yorkville, Illinois Cannonball LLC 800 Game Farm Road c/o The Harlem Irving Companies, Inc. Yorkville, Illinois 60560 4104 N. Harlem Avenue, Suite 220 Chicago, IL 60706 Ladies and Gentlemen: The undersigned, William Blair & Company L.L.C. (the "Original Purchaser "), offers to enter into the following agreement (this "Contract ") with the United City of Yorkville, Kendall County, Illinois (the "City "), which upon acceptance by the City of this offer, and approval of this Contract by the Developer (as defined below) will be binding upon each of the City, the Developer and the Original Purchaser. Capitalized terms used herein and not otherwise defined herein shall have the meanings set forth in the Indenture (as hereinafter defined) and the Limited Offering Memorandum (as hereinafter defined). This offer is made subject to your mutual acceptance on or before 3:00 P.M., Chicago time, on the date hereof, and, if not so accepted, will be subject to withdrawal by the Original Purchaser upon notice delivered to the City and the Developer at the addresses set forth above at any time prior to the acceptance hereof by the City and the Developer. This offer is also subject to the following provisions: 1. Definitions For purposes of this Contract, the following terms have the meanings specified in this section, unless another meaning is plainly intended: (A) "Act" means the Special Service Area Tax Law of the State of Illinois, 35 ILCS 200/27 -5 et seq., as amended. (B) "Ancillary Agreements" means the Bond Ordinance, the Indenture, the Tax Compliance Certificate and Agreement, the Limited Offering Memorandum, the Development Agreement, and all other agreements and certificates executed and delivered in connection with the issuance and sale of the Bonds. (C) "Area" means the City's Special Service Area Number 2006 -113 created pursuant to the Establishing Ordinance. (D) "Bond Ordinance" means Ordinance No. 2007- adopted by the corporate authorities of the City on March 27, 2007, authorizing the issuance of the Bonds. 1 14531726 \V -2 (E) "Bonds" means the United City of Yorkville Ad Valorem Tax Bonds, Series 2007 (Cannonball/Beecher Road Project). ,} (F) "Business Day" means any day other than a Saturday, Sunday, legal holiday or a day on which banking institutions are required or authorized by law to be closed in the City of Chicago or the State of Illinois or a day on which the New York Stock Exchange is closed. (G) "City" means the United City of Yorkville, Kendall County, Illinois. (H) "City Information" means the descriptions and information contained in the Limited Offering Memorandum under the captions "INTRODUCTORY STATEMENT "; "THE DEVELOPMENT AGREEMENT "; "THE CITY "; "THE SPECIAL SERVICE AREA AND AD VALOREM TAX "; "CONTINUING INFORMATION —The City "; "NO LITIGATION —The City "; "NO RATING ", "AUTHORIZATION" and "MISCELLANEOUS." (I) "Closing" means the Closing as defined in Section 2(B) herein held on the Closing Date. (J) "Closing Date" means April, 2007, or such earlier or later date as the City, the Developer and the Original Purchaser shall mutually agree upon and refers to the date on which the City causes the Trustee to deliver the Bonds to the Original Purchaser and the Bonds are paid for by the Original Purchaser pursuant to this Contract. (K) "Code" means the Internal Revenue Code of 1986, as amended. (L) "Contract" means this Bond Purchase Agreement. (NI) "Developer" means Cannonball LLC, an Illinois limited liability company. (N) "Development Agreement" means the Development Agreement dated April _, 2007 between the City and the Developer. (0) "Developer Information" means the descriptions and information in the Limited Offering Memorandum under the captions "INTRODUCTORY STATEMENT ", except the penultimate and ultimate paragraphs therein, "ESTIMATED SOURCES AND USES OF FUNDS"; "PLAN OF FINANCE"; "THE DEVELOPMENT AGREEMENT "; "SUMMARY OF THE PROJECT"; "THE DEVELOPER "; "RISK FACTORS;" "CONTINUING INFORMATION —The Developer "; and "NO LITIGATION —The Developer." (P) "Establishing Ordinance" means Ordinance No. 2007 - adopted by the corporate authorities of the City on March 13, 2007, establishing the Area. (Q) "Governmental Body" means any federal, state, municipal, or other governmental department, commission, board, bureau, agency or instrumentality, domestic or foreign. 2 14531726\V -2 (R) "Indenture" means the Trust Indenture dated as of April 1, 2007 between the City and the Trustee pursuant to which the Bonds will be issued. (S) "Notice Beneficial Holders" has the meaning given in the Indenture. (T) "Original Purchaser" means William Blair & Company, L.L.C. (CI) "Plans" means the plans and specifications pursuant to which the Project will be constructed. (V) "Preliminary Limited Offering Memorandum" means the Preliminary Limited Offering Memorandum of the City (including any Appendix thereto) relating to the Bonds dated March, 2007. (W) "Project" means the project development as defined in the Limited Offering Memorandum. (X) "Revenue" shall have the meaning set forth in the Indenture. (Y) "Limited Offering Memorandum" means the Limited Offering Memorandum of the City (including each Appendix thereto) relating to the Bonds dated April, 2007. (Z) "Special Services" means engineering, soil testing and appurtenant work, mass grading and demolition, storm water management facilities, potable water storm drainage systems and storm sewers, site clearing and tree removal, public water facilities, sanitary sewer facilities, erosion control measures, roads, streets, curbs, gutters, street lighting, signalization, bicycle paths, sidewalks and related street improvements, and equipment and materials necessary for the maintenance thereof, landscaping and tree installation, costs for land and easement acquisitions relating to any of the foregoing improvements and other eligible costs of improvements to serve the Area, as further described in the Limited Offering Memorandum. (AA) "Tax Compliance Certificate and Agreement" means the Tax Compliance Certificate and Agreement dated the Closing Date, executed by the City and the Trustee in connection with the Bonds. (BB) "Trustee" means The Bank of New York Trust Company, N.A., as Trustee under the Indenture. 2. Purchase and Sale of the Bonds. (A) Sale of Bonds. Upon the terms and conditions and upon the basis of the representations, warranties and agreements herein, the Original Purchaser hereby agrees to purchase from the City for a limited offering, and the City hereby agrees to sell to the Original Purchaser for such purpose, all, but not less than all, of the Bonds for a purchase price of $ , which reflects an underwriters' discount of $ . The Bonds shall be issued pursuant to the Bond Ordinance and the Indenture. The Bonds shall be dated, shall mature on such dates and in such amounts, shall bear interest at such rates, shall be offered 3 14531726 \V -2 at the initial offering prices and shall be subject to such other terms and conditions, all as described in the Limited Offering Memorandum, the Bond Ordinance and the Indenture. (B) Closing. The purchase and sale of the Bonds shall take place on or before 12:00 p.m. CST on the Closing Date at the offices of Foley & Lardner LLP, Chicago, Illinois. At the Closing, as defined below, the Original Purchaser will accept the delivery of the Bonds duly executed by the City, together with other documents herein mentioned, and will make payment therefor as provided herein by immediately available funds payable to the order of the Trustee for the account of the City. j The payment for the Bonds and delivery of the Bonds, as herein described, is herein called the "Closing." 3. Citv's Pre- Closinv- Deliveries. (A) Prior to the Closing Date, the City shall have delivered or caused to be delivered to the Original Purchaser an executed copy of the Limited Offering Memorandum, executed on behalf of the City by its Mayor. (B) Prior to the Closing Date, the City shall have delivered or caused to be delivered to the Original Purchaser a certified copy of the Bond Ordinance and such other ordinances of the City which shall include the authorization of the execution, delivery and performance of this Contract, the Bonds and the other Ancillary Agreements to which the City is a parry, among other things, together with such reasonable number of copies of each of the foregoing as the Original Purchaser shall request. (C) The City hereby authorizes any and all of the material described above in Subsections A and B of this Section 3 and the Ancillary Agreements, the information contained in the Limited Offering Memorandum (and the Preliminary Limited Offering Memorandum) and the Bond Ordinance and all other instruments, documents and agreements delivered pursuant to Section 8 of this Contract or in connection with the transactions contemplated hereby, for use in connection with the offering and sale of the Bonds. The City hereby ratifies, approves, and consents to the use and distribution by the Original Purchaser, prior to or after the date hereof, of the Limited Offering Memorandum (and the Preliminary Limited Offering Memorandum) in connection with the offering of the Bonds. The City hereby agrees to furnish such information, execute such instruments and take such other action at the expense of and in cooperation with the Original Purchaser as the Original Purchaser may deem reasonably necessary in order to qualify the Bonds for offering and sale under the "Blue Sky" or other securities laws and regulations of such states and other jurisdictions of the United States as the Original Purchaser may designate; provided, however, that the City shall not be required to execute a special or general consent to service of process or qualify as a foreign corporation in connection with any such qualification in any jurisdiction. 4. Representations and Warranties of the City. The City represents and warrants to and agrees with the Original Purchaser that: 4 14531726 \V -2 (A) Cit y. The City is a non -home rule unit and a municipal corporation duly organized, validly existing and in good standing under the laws and the Constitution of the State of Illinois. The City is authorized and empowered by the Act and the Bond Ordinance and such other ordinances of the City as have been duly adopted by the City, to enter into the transactions contemplated by this Contract, each of the Bond Ordinance and Establishing Ordinance, the Limited Offering Memorandum, and the Ancillary Agreements to which the City is or is to be a parry. The adoption of the Bond Ordinance and the execution, delivery and performance by the City of this Contract, the Ancillary Agreements to which the City is or is to be a party and the issuance of the Bonds are within the legal right, power and authority of the City, have been duly and validly authorized by all necessary proceedings of the City, and such execution, delivery and performance by the City as of the date of this Contract and as of the Closing Date do not and will not contravene, or constitute a breach of or default (with due notice or the passage of time or both) under, any provision of law, ordinance or regulation applicable to the City, or any provision of the municipal code or other rules and procedures of the City, or any judgment, order, decree, agreement or instrument binding on it or, except as described in the Limited Offering Memorandum, result in the creation of any lien or other encumbrance on any asset of the City. This Contract and the Bond Ordinance each constitutes, and the Ancillary Agreements to which the City is or is to be a party, when executed and delivered by the City and any other parties thereto, will constitute valid and binding agreements of the City enforceable against the City in accordance with their respective terms, except to the extent limited by bankruptcy, reorganization, or other similar laws affecting creditors' rights generally and by the availability of equitable remedies, and the Bonds, when issued and delivered by the City in accordance with this Contract and the Bond Ordinance will have been duly authorized and issued and will constitute valid and binding obligations of the City enforceable against the City in accordance with their terms, except to the extent limited by bankruptcy, reorganization, or other similar laws affecting the enforcement of creditors' rights generally and by the availability of equitable remedies. When delivered to and paid for by the Original Purchaser at the Closing in accordance with the provisions of this Contract, the Bonds will conform in all material respects to the description thereof contained in the Limited Offering Memorandum. (B) Use of Proceeds. The City will not take or omit to take any action which will in any way cause or result in the proceeds from the sale of the Bonds being applied other than as provided in the Bond Ordinance, the Indenture and as described in the Limited Offering Memorandum. Such proceeds will not be used by the City in a manner that would cause the Bonds to be "arbitrage bonds" within the meaning of the Code, or any successor thereto, and the applicable regulations promulgated or proposed thereunder. (C) Governmental Authorization. All authorizations, consents and approvals of any Governmental Body required in connection with the execution and delivery by the City of, or in connection with the performance by the City of its obligations under, the Bonds, the Bond Ordinance, this Contract, or the Ancillary Agreements to which the City is or is to be a party, have been obtained and are in full force and effect, or will be obtained prior to Closing and will be in full force and effect as of the Closing Date. To the best knowledge of the City, all authorizations, consents and approvals of any Governmental Body required in connection with the construction or operation of the Project by the City have been obtained and are in full force and effect as of the Closing Date. 5 145317261V -2 (D) Limited Offering Memorandum. The City Information is, and as of the - date of the Closing, will be, true and correct in all material respects and such descriptions and l information in the Limited Offering Memorandum, as of its date and as of the Closing Date will not contain an untrue, incorrect or misleading statement of a material fact; and such descriptions and information in the Limited Offering Memorandum do not, as of its date and as of the Closing Date will not omit to state a material fact necessary to make the statements made therein, in the light of the circumstances under which they were made, not misleading. (E) No Liens or Encumbrances. Other than as specifically set forth in the Limited Offering Memorandum, there are no existing liens, claims, charges or encumbrances on or rights to any funds, revenues or interests pledged pursuant to the Bond Ordinance which are senior to, or on a parity with, the claims of the holders of the Bonds. Other than as specifically disclosed in the Limited Offering Memorandum, the City has not entered into any contract or arrangement of any kind, and there is no existing, pending, threatened, or anticipated event or circumstance that might give rise to any lien, claim, charge or encumbrance on or right to the assets, properties, funds, or interests pledged pursuant to the Bond Ordinance which would be prior to, or on a parity with, the claims of the holders of the Bonds. The City is lawfully entitled to receive, pledge and assign all amounts or revenues which have been pledged or assigned as security for the payment of the principal of and interest on the Bonds. (F) No Litigation. Except as described in the Limited Offering Memorandum, as of the date of this Contract and as of the Closing Date (i) there is no action, suit, proceeding or investigation, at law or in equity, before or by any court or any governmental agency or public board or body, pending against the City or, to the knowledge of the City, threatened against the City, to restrain or enjoin, or threatening or seeking to restrain or enjoin, the issuance, sale or delivery of the Bonds or the delivery by the City of any of the Ancillary Agreements to which the City is a party, or the collection of the Revenue, or in any way contesting or affecting the validity of the Bonds, or any of the Ancillary Agreements to which the City is a party, or in any way questioning or affecting (w) the proceedings under which the Bonds are to be issued, (x) the validity or enforceability of any provision of the Bonds, the Bond Ordinance, the Establishing Ordinance or this Contract, (y) the authority of the City to collect the Revenue, or to perform its obligations hereunder or with respect to the Bonds, or to consummate any of the transactions set forth in the Ancillary Agreements to which it is or is to be a party as contemplated hereby or by the Bond Ordinance, or the Limited Offering Memorandum, (z) the legal existence of the City, or the title of its Board of Trustees or officers to their offices, and (ii) there is no action, suit, proceeding or investigation, at law or in equity, before or by any court or any governmental agency or public board or body, pending against the City or, to the knowledge of the City, threatened against the City, involving any of the property or assets within the City which may result in any material adverse change in the Revenue, assets or the financial condition of the City or the proposed construction or operation of the Project by the Developer pursuant to the Development Agreement. (G) Certificates. Any certificate signed by an authorized officer of the City and delivered to the Original Purchaser and/or the Trustee shall be deemed a representation and covenant by the City to the Original Purchaser and/or the Trustee as to the statements made therein. 6 145317261V -2 I (I� The Ordinances. Each of the Bond Ordinance and the Establishing Ordinance are in full force and effect, and have not been amended, modified, revoked or repealed. 5. Representations and Warranties of the Developer. The Developer represents and warrants to and agrees with the Original Purchaser and the City that: (A) Organization and Power. The Developer is a duly organized and validly existing limited liability company and is in good standing under the laws of the State of Illinois, and has all powers and authority and all governmental licenses, authorizations, consents and approvals required to carry on its business as now conducted and to enter into and perform its obligations under this Contract, and all Ancillary Agreements to which it is or is to be a parry. (B) Authorization of Agreements, Etc. This Contract and the Ancillary Agreements to which the Developer is a parry have each been duly authorized, executed and delivered by the Developer and constitute the legal, valid and binding agreement of the Developer enforceable against the Developer in accordance with their respective terms; provided that the enforceability of such Agreements may be limited by bankruptcy, reorganization, insolvency and similar laws affecting the enforcement of creditors' rights and remedies generally, as applied in the event of bankruptcy, reorganization or insolvency of the Developer and to equitable remedies. The Developer has duly authorized all necessary action to be taken by it for (i) approval of the Developer Information and (ii) the execution and delivery of this Contract and the Ancillary Agreements to which the Developer is or is to be a parry, and any and all other agreements and documents as may be required to be executed or delivered by the Developer in order to effectuate the transactions contemplated herein and therein. (C) Development Agreement. Any and all of the conditions precedent to the obligations of the Developer arising under the Development Agreement have been satisfied or waived by the City. i (D) No Material Change. Other than as disclosed in the Limited Offering Memorandum or except as previously disclosed to the Original Purchaser, (i) the Developer has not incurred any material liabilities or entered into any material transactions other than in the ordinary course of business and (ii) there has been no material adverse change in the business, financial position, prospects or results of operations of the Developer, which would affect the Developer's ability to perform its obligations pursuant to this Contract or the Ancillary Agreements, to the extent to which the Developer is or is to be a party to such agreement. (E) Noncontravention. The execution, delivery and performance by the Developer of its obligations under this Contract and the Ancillary Agreements to which the Developer is a parry do not, and to the Developer's knowledge, will not contravene, or constitute a default under, any provision of applicable law or regulation or organizational documents of the Developer or of any agreement, judgment, injunction, order, decree or other instrument binding upon the Developer, and will not result in the creation of any lien or other encumbrance upon any asset of the Developer except as set forth in the Limited Offering Memorandum. 7 14531726 \V -2 (F) Governmental or Corporate Consents. No consent or approval is required to be obtained from, and no action need be taken by, or document filed with, any Governmental Body or corporate entity in connection with the execution or delivery by the Developer of this Contract or any Ancillary Agreement to which the Developer is or is to be a party, or, if any such action is required, the same has been duly taken, is in full force and effect and constitutes valid and sufficient consent or approval therefor, except for those which are customarily obtained during construction of the Project. The Developer has no reason to believe any such consent or approval will not be obtained in due course. I (G) No Litigation. Except as described in the Limited Offering Memorandum, there is no action, suit, proceeding or investigation, at law or in equity, before or by any court or any governmental agency or public board or body, pending against the Developer, in which the Developer is a party or, to the knowledge of the Developer overtly threatened in writing against the Developer, (i) contesting or in any way relating to (a) the construction and development of the Project, (b) the generation of Revenue or the transactions contemplated by the issuance of the Bonds or as otherwise described in the Limited Offering Memorandum of (ii) which in any way contests the existence or power of the Developer or the validity or enforceability of the Bonds, the Ancillary Agreements, this Contract or the Limited Offering Memorandum or which if adversely determined could have a material adverse effect on the Developer. (H) Limited Offerina Memorandum. The Developer Information contained in the Limited Offering Memorandum is true and correct in all material respects as of the date hereof and as of the date hereof does not contain any untrue statements of a material fact or omit to state a material fact necessary to be stated therein in order to make the statements therein, in light of the circumstances under which they were made, not misleading. (I) Use of Proceeds. The Developer will not take or omit to take any action which will in any way cause or result in the proceeds of the sale of the Bonds being applied in a manner other than as provided in the Bond Ordinance and the Indenture and as described in the Limited Offering Memorandum. Such proceeds will not be used by the Developer in a manner that would cause the Bonds to be "arbitrage bonds" within the meaning of the Code, or any successor thereto, and the applicable regulations promulgated or proposed thereunder. (J) No Default. No default or event of default on the part of the Developer has occurred and is continuing, and no event has occurred and is continuing which with the lapse of time or the giving of notice, or both, would constitute a default or an event of default on the part of the Developer under this Contract, the Ancillary Agreements to which the Developer is a party, or any other material agreement or material instrument to which the Developer is a party or by which the Developer is or may be bound. (K) Approvals. The Developer has received and is in good standing with respect to any applicable certificates, licenses, inspections, franchises, consents, immunities, permits, authorizations and approvals, governmental or otherwise, necessary to conduct and to continue to conduct its business as heretofore conducted by it and to own or lease and operate its properties as now owned or leased by it. Except as set forth in the Limited Offering Memorandum, the Developer has obtained any applicable certificates, licenses, inspections, franchises, consents, immunities, permits, authorizations and approvals, governmental or 8 14531726\V -2 otherwise, necessary to construct the Project, except for final platting and engineering to be completed as part of the Special Services and those the nature of which cannot be given until construction of the Improvements are sufficiently underway. (L) Certificates. Any certificate signed by an authorized representative of the Developer and delivered to the City or the Original Purchaser shall be deemed a representation and warranty by the Developer to the City and the Original Purchaser as to the statements made by Developer therein. (M) Environmental Representation. To the best of the Developer's knowledge, no toxic or hazardous substances, including without limitation, asbestos, and the group of organic compounds known as polychlorinated biphenyls, have been generated, treated, stored or disposed of, or otherwise deposited in or located on the site which includes the Area and no activity has been undertaken at the site which includes the Area which could: (i) cause the Project or any part thereof to become a hazardous waste treatment, storage or disposal facility within the meaning of, or otherwise bring such property within the ambit of, the Resource Conservation and Recovery Act, 42 U.S.C. Section 6901 et seq. ( "RCRA "), or any other similar state law or local ordinance; (ii) cause a release or threatened release of hazardous materials, wastes or substances from the site or any part thereof within the meaning of, or otherwise bring such property or any part thereof within the ambit of, the Comprehensive Environmental Response, Compensation and Liability Act of 1980, 42 U.S.C., Sections 9601 -9657 ( "CERCLA "), or any similar state law or ordinance or any other environmental law; (iii) cause the discharge of pollutants or effluents into any water source or system, or the discharge into the air of any emissions, which would require a permit under the Federal Water Pollution Control Act, 33 U.S.C., Section 1251 et seq., or the Clean Air Act, 41 U.S.C., Section 7401 et seq., or any similar state law or local ordinance; or (iv) support a claim or cause of action under RCRA, CERCLA or any other federal, state or local environmental statutes, regulations, ordinances or other environmental regulatory requirements. (N) No Challenges. The Developer agrees that it will not bring any suit, action or proceeding which challenges the designation of the Area, the imposition and collection of the Local Sales Taxes, the validity of the Bonds or the proceedings relating to the Bonds. (0) Development Status. To Developer's knowledge, the legal description and boundaries of the Area have not changed from those reflected in the Establishing Ordinance. The Developer has obtained approval from the City for, and intends to develop or cause to be developed in the Area a shopping center with approximately 820,000 square feet of gross building area. (P) Completion of Construction. The Developer has sufficient financial resources together with the proceeds of the Bonds, including cash, marketable securities, outside 9 14531726\V -2 equity or bank loans, to complete the Special Services an the Project as proposed in the Limited - Offering Memorandum. (Q) Form of Bond and Indenture. The Developer approves the form and terms of the Bonds and the Indenture and agrees that the issuance of such Bonds satisfies the terms and conditions of the Development Agreement relating to the City's obligation to issue the Bonds. 6. Representations and Warranties and Agreements of the Original Purchaser. . (A) Limited Offering. The Original Purchaser agrees to make a limited offering of the Bonds to a limited number of institutional investors at a price or prices (or yield or yields) not in excess of the offering price or prices (or not lower than the yield or yields) set forth on the cover page of the Limited Offering Memorandum. (B) Limited Offering Memorandum. The descriptions and - information contained in the Limited Offering Memorandum under the captions "UNDERWRITING" and the first two grammatical sentences under the caption "LIMITED OFFERING" are, and as of the date of the Closing will be, true and correct in all material respects and such descriptions and information in the Limited Offering Memorandum, as of its date and as of the Closing Date will not contain an untrue, incorrect or misleading statement of a material fact; and such descriptions and information in the Limited Offering Memorandum do not, as of its date and as. of the Closing Date will not omit to state a material fact necessary to make the statements made therein, in the light of the circumstances under which they were made, not misleading. 7. Termination of the Purchase Contract. The Original Purchaser shall have the right to cancel its obligation to purchase the Bonds, if, between the date hereof and the date of Closing, (i) legislation shall be enacted, or actively considered for enactment, by the Congress or recommended by the President of the United States to the Congress for passage, or favorably reported for passage to either House of the Congress by any committee of such House to which such legislation has been referred for consideration, a decision by a court of the United States or the United States Tax Court shall be rendered, or a ruling, regulation or official statement by or on behalf of the Treasury Department of the United States, the Internal Revenue Service or other agency or department of the United States shall be made or proposed to be made which has the purpose or effect, directly or indirectly, of imposing federal income taxes upon interest on the Bonds; (ii) any other action or event shall have transpired which has the purpose or effect, directly or indirectly, of materially adversely affecting the federal income tax consequences of any of the transactions contemplated in connection herewith or contemplated by the Limited Offering Memorandum, or, in the reasonable opinion of the Original Purchaser, such action or event pertaining to the federal income tax consequences referenced above materially adversely affects the market for the Bonds or the sale, at the contemplated offering price or prices (or yield or yields), by the Original Purchaser of the Bonds; (iii) legislation shall be enacted, or actively considered for enactment by the Congress, with an effective date on or prior to the date of Closing, or a decision by a court of the United States shall be rendered, or a ruling or regulation by the Securities and Exchange Commission or other governmental agency having jurisdiction over the subject matter shall be made, the effect of which is that (A) the Bonds are not exempt from the registration, qualification 10 14531726 \V -2 or other requirements of the Securities Act of 1933, as amended and as then in effect, or the Securities Exchange Act of 1934, as amended and as then in effect, or (B) the Indenture is not exempt from the registration, qualification or other requirements of the Trust Indenture Act of 1939, as amended and as then in effect; (iv) a stop order, ruling or regulation by the Securities and Exchange Commission shall be issued or made, the effect of which is that the issuance, offering or sale of the Bonds, as contemplated herein and in the Limited Offering Memorandum, is in violation of any provision of the Securities Act of 1933, as amended and as then in effect, the Securities Exchange Act of 1934, as amended and as then in effect, or the Trust Indenture . Act of 1939, as amended and as then in effect; (v) there shall occur any event which in the reasonable judgment of the Original Purchaser either (A) makes untrue, incorrect or misleading in any material respect any statement or information contained in the Limited Offering Memorandum or (B) is not reflected in the Limited Offering Memorandum but should be reflected therein in order to make the statements and information contained therein not misleading in any material respect and, in either such event, the City or the Developer refuse to permit the Limited Offering Memorandum to be supplemented to correct or supply such statement or information, or the effect of the Limited Offering Memorandum as so corrected or supplemented is such as, in the reasonable judgment of the Original Purchaser, would materially adversely affect the market for the Bonds or the sale, at the contemplated offering price or prices (or yield or yields), by the Original Purchaser of the Bonds; (vi) there shall occur any outbreak of hostilities or any regional, national or international calamity or crisis or a financial crisis and the effect is such as, in the reasonable judgment of the Original Purchaser, would materially adversely affect the market for or the marketability of the Bonds or obligations of the general character of the Bonds; (vii) a general suspension of trading on the New York Stock Exchange is in force; (viii) a general banking moratorium is declared by federal or state authorities; (ix) there occurs any material adverse change in the affairs, operations or financial conditions of the City, except as set forth or contemplated in the Limited Offering Memorandum or in the affairs, operations or financial condition of the Developer; (x) the Limited Offering Memorandum is not executed, approved and delivered in accordance with Section 3 above; (xi) in the reasonable judgment of the Original Purchaser, the market price of the Bonds, or the market price generally of obligations of the general character of the Bonds, might be adversely affected because: (A) additional material restrictions not in force as of the date hereof shall have been imposed upon trading in securities generally by any governmental authority or by any national securities exchange, or (B) the New York Stock Exchange or other national securities exchange, or any governmental authority, shall impose, as to the Bonds or similar obligations, any material restrictions not now in force, or increase materially those now in force, with respect to the extension of credit by, or the charge to the net capital requirements of, underwriters; (xii) a war involving the United States of America shall have been declared, or any conflict involving the armed forces of any country shall have escalated, or any other international, national or regional emergency relating to or affecting the effective operation of government or the financial community shall have occurred, which, in the reasonable judgment of the Original Purchaser, materially adversely affects the market for the Bonds or of obligations of the general character of the Bonds; (xiii) any litigation shall be instituted, pending or threatened to restrain or enjoin the issuance, sale or delivery of the Bonds or in any way protesting or affecting any authority for or the validity of the Bonds, the Bond Ordinance, the existence or powers of the City, or any event described or contemplated by the Limited Offering Memorandum; (xiv) there shall have occurred a default with respect to the debt obligations of, or the institution of proceedings under 11 14531726 \V -2 any federal bankruptcy laws by or against, any state of the United States or any city or political subdivision of any state, the effect of which, in the reasonable judgment of the Original Purchaser, would materially adversely affect the ability of the Original Purchaser to market the Bonds. 8. Conditions of Closing. The Original Purchaser' obligation to purchase the Bonds under this Contract is subject to the performance by the City and the Developer of their respective obligations hereunder at and prior to the Closing Date, to the accuracy in all material respects of the representations and warranties of the City and the Developer contained herein as of the Closing Date, and to the following conditions, including the delivery of such documents as are enumerated herein in form and substance satisfactory to the Original Purchaser and its counsel as of the Closing Date: (A) Ordinances in Effect and Citv in Compliance Therewith. At the time of the Closing (i) each of the Bond Ordinance and the Establishing Ordinance shall be in full force and effect, and shall not have been amended, modified or supplemented since the date hereof, except as may have been agreed to in writing by the Original Purchaser, and the City shall have duly adopted and there shall be in full force and effect such additional ordinances or agreements as shall be, in the opinion of Bond Counsel, necessary in connection with the transactions contemplated hereby and (ii) the City shall perform or have performed all of its obligations required under or specified in this Contract with regard to the Bonds or the Bond Ordinance to be performed at, simultaneously with or prior to the Closing. (B) Opinion of Bond Counsel. The Original Purchaser shall have received an unqualified approving legal opinion dated the Closing Date as to the Bonds, addressed to the Original Purchaser, the Developer, the City and the Trustee, from Foley & Lardner LLP, Bond Counsel, satisfactory in form and substance to the Original Purchaser. (C) Opinion of Original Purchaser's Counsel. The Original Purchaser shall have received a favorable opinion dated the Closing Date, addressed to the Original Purchaser, from Sonnenschein Nath & Rosenthal LLP, satisfactory in form and substance to the Original Purchaser. (D) Opinion of Counsel to the City. The Original Purchaser shall have received a favorable opinion dated the Closing Date, addressed to the Original Purchaser, Bond Counsel, the Developer and the Trustee, from John Wyeth, Esq., counsel to the City, satisfactory in form and substance to the Original Purchaser. (E) Opinions of Counsel to the Developer. The Original Purchaser shall have received favorable opinions dated the Closing Date, addressed to the Original Purchaser, the City, the Trustee and Bond Counsel from the Developer's general counsel and/or from Polsky & Associates Ltd., special counsel to the Developer, satisfactory in form and substance to the Original Purchaser. (F) Performance; No Default. Each of the City and the Developer shall have performed and complied with all agreements and conditions herein required to be performed or 12 14531726 \V -2 complied with by each of them prior to or on the Closing Date, and at the time of the Closing no event of default or default shall have occurred and be continuing with respect to the Ancillary Agreements or the Bonds. (G) Ancillary Agreements. At the Closing Date, (i) all of the Ancillary Agreements shall be in full force and effect, shall have been duly executed and copies delivered to the Original Purchaser by, and shall constitute valid and binding agreements of, the parties thereto, shall not have been amended, modified or supplemented except as may have been agreed to in writing by the Original Purchaser and there shall be no defaults or events of default thereunder and (ii) the proceeds of the sale of the Bonds shall be applied or deposited with the Trustee for application as described in the Bond Ordinance and the Limited Offering Memorandum. (H) Closing Certificate of Mayor of the City. The City shall have delivered to the Original Purchaser a certificate dated the Closing Date, addressed to the Original Purchaser and the Trustee signed by the Mayor of the City in form, and substance reasonably satisfactory to the Original Purchaser. (I) Officer's Certificate of the Developer. The Developer shall have delivered to the Original Purchaser a certificate dated the Closing Date, addressed to the Original Purchaser signed by an authorized officer of the Developer and of the manager of the Developer in form and substance satisfactory to the Original Purchaser. (J) The Bonds. The Bonds shall have been duly authorized, executed, authenticated, delivered, and the proceeds from the sale thereof applied, in accordance with the provisions of the Bond Ordinance. (K) Trustee's Certificate. The Original Purchaser shall have received a certificate dated the Closing Date of an authorized officer of the Trustee, addressed to the Original Purchaser in form and substance satisfactory to the Original Purchaser. (L) Form 8038 -G. The Original Purchaser shall have received a copy of the completed Form 8038 -G of the Internal Revenue Service executed by the City. (M) Officers' Certificates. The Original Purchaser shall have received any and all certificates required to be furnished by the provisions of any Ancillary Agreement to be obtained or furnished by the City and the Developer at or prior to Closing. (N) Specimen Bonds. The Original Purchaser shall have received specimen Bonds. (0) Certified Conies of Ordinances. The Original Purchaser shall have received certified copies of the Bond Ordinance, the Establishing Ordinance. The Bond Ordinance shall include authorization for execution and delivery of this Contract. (P) Financing. The Developer shall have delivered evidence, upon the request of and satisfactory to the Original Purchaser, which may be in the form of financial statements, 13 145317261V -2 equity commitments, loan commitments, or loan agreements demonstrating that the Developer has cash, marketable securities, outside equity or bank financing to complete the Project. (Q) Title Insurance. The Original Purchaser shall have received copies of an Owner's title insurance policy or policies (or commitments) therefor) issued by a title insurance company with respect to the Area showing title to the Project in the name of the Developer, and which policies or commitment(s) and company shall be acceptable to the Original Purchaser in its reasonable discretion. (R) Land Sales and Leases. Developer shall have completed such land sales and entered into such tenant leases with retailers with respect to the Project as the Original Purchaser shall in its sole discretion require. (S) Additional Opinions, Certificates, etc. The Original Purchaser shall have received such additional legal opinions, certificates, proceedings, instruments and other documents as the Original Purchaser, the City or their respective counsel may deem reasonably necessary or desirable. All of the opinions, letters, certificates, instruments and other documents mentioned in this Contract shall be deemed to be in compliance with the provisions of this Contract only if they are satisfactory in form and substance to the Original Purchaser. If there shall be a failure to satisfy the conditions of the Original Purchaser' obligations contained in this Contract or if the Original Purchaser's obligations to purchase the Bonds shall be terminated for any reason permitted by this Contract, this Contract shall terminate, and the Original Purchaser, the City and the Developer shall not have any further obligations hereunder. 9. Chances Affecting the Limited Offerinsz Memorandum. At any time prior to the Closing, the City and the Developer agree to supplement or amend the Limited Offering Memorandum whenever requested by the Original Purchaser when, in the reasonable judgment of the Original Purchaser and the City, such supplement or amendment is required. No amendment or supplement to the Limited Offering Memorandum shall be made without the approval of the Original Purchaser. After the Closing and so long as the Original Purchaser or any participating dealer shall be offering Bonds, but not later than 90 days after the date of this Contract if any event shall occur as a result of which it is necessary to amend or supplement the Limited Offering Memorandum in order to make the statements therein, in light of the circumstances under which they are made, not misleading, the City will so advise the Original Purchaser. In any such case, the City and the Developer shall cooperate in the preparation, execution and delivery of either amendments to the Limited Offering Memorandum or supplemental information so that the statements in the Limited Offering Memorandum, as so amended or supplemented will not, in light of the circumstances under which such statements were made, be misleading. The cost of providing such amendments or supplements shall be paid by the City. II I 14 14531726 \V -2 i 10. Pavment of Expenses. The Original Purchaser shall be under no obligation to pay any expenses incident to the issuance of the Bonds. All fees, costs and expenses associated with the issuance of the Bonds, including without limitation, the fees and disbursements of legal counsel, professional fees, printing and the costs associated with the CUSIP number for the Bonds shall be disbursed and paid by the Trustee from the proceeds of the Bonds. 11. Notices. Except as otherwise provided in this Contract, whenever notice is required to be given pursuant to the provisions of this Contract, such notice shall be in writing and shall be mailed by first class mail postage prepaid. 12. Law Governing. This Contract shall be construed in accordance with and governed by the laws of the State of Illinois. 13. Headinas. The headings of the paragraphs and subparagraphs of this Contract are inserted for convenience only and shall not be deemed to constitute a part of this Contract. 14. Counterparts. This Contract may be signed in any number of counterparts, each of which shall be an original, with the same effect as if the signatures thereto and hereto were upon the same instrument. 15. Parties and Interests. This Contract is made solely for the benefit of the City, the Original Purchaser and the Developer, including the successors and assigns of the Original Purchaser, and no other person, partnership, association or corporation shall acquire or have any rights hereunder or by virtue hereof. 16. Indemnification. (a) The City agrees to indemnify and hold harmless the Original Purchaser, each director, trustee, member, officer, partner, employee or agent of the Original Purchaser and each person, if any, who has the power, directly or indirectly, to direct or cause the direction of the management and policies of the Original Purchaser, pursuant to the Original Purchaser's regulations or Bylaws, or who controls the Original Purchaser within the meaning of Section 20 of the Exchange Act or Section 15 of the Securities Act, from and against any and all losses, claims, damages, liabilities or expenses whatsoever caused by any untrue or misleading, or allegedly untrue or misleading, statement of a material fact contained in that portion of the Limited Offering Memorandum constituting the City Information, or in any amendment or 15 14531726 \V -2 supplement thereto with regard to that portion of the Limited Offering Memorandum, or caused by any omission or alleged omission to state in that portion of the Limited Offering 1; Memorandum constituting the City Information a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading; the City shall not be liable under this paragraph if the person asserting any such loss, claim, damage or liability purchased Bonds from the Original Purchaser, if delivery to such person of the Limited Offering Memorandum, or any amendment or supplement thereto, would have been a valid defense to the action from which such loss, claim, damage or liability arose and if the Limited Offering Memorandum, amendment of or supplement was not delivered to such person by or on behalf of the Original Purchaser. In case any proceeding (including any governmental investigation) shall be instituted involving any person in respect of which indemnity may be sought pursuant to the preceding paragraph, such person (the "indemnified party") shall promptly notify the City in writing, and the City shall promptly assume the defense thereof, including the employment of counsel chosen by the City and approved by the Original Purchaser and shall pay the reasonable fees and disbursements of such counsel related to such proceeding. If any of the indemnified parties is advised by counsel that there may be legal defenses available to such indemnified party which are adverse to or in conflict with those available to the City or another indemnified party, the City shall not have the right to assume the defense of such indemnified party, but the City shall be responsible for the reasonable fees and expenses of counsel retained by such indemnified parry in assuming its own defense, and provided also that if the City shall have failed to assume the defense of such action or to retain counsel satisfactory to the Original Purchaser within a reasonable time after notice of the commencement of such action, the reasonable fees and expenses of counsel retained by the indemnified parties shall be paid by the City. Notwithstanding, and in addition to, any of the foregoing, any one or more of the indemnified parties shall have the right to retain its own counsel, but the fees and expenses of such counsel shall be at the expense of such indemnified party unless the City and the indemnified party shall have mutually agreed to the retention of such counsel. Such firm shall be designated in writing by the indemnified parry. The City shall not be liable for any settlement of any proceeding effected without its written consent, but, if settled with such written consent of the City or if there shall be a final judgment for the plaintiff, the City agrees to indemnify the indemnified parry from and against any loss, damage, cost, expense or liability by reason of such settlement or judgment. (b) The Developer agrees to indemnify, defend and hold harmless (a) the Original Purchaser, each director, trustee, member, officer, agent or employee and each person, if any, who has the power, directly or indirectly, to direct or cause the direction of the management and policies of the Original Purchaser, pursuant to the Original Purchaser's regulations or Bylaws, or who controls the Original Purchaser within the meaning of Section 20 of the Exchange Act or Section 15 of the Securities Act, by contract or otherwise, and (b) the City, each director, trustee, member, officer, agent or employee and each person, if any, who has the power, directly or indirectly, to direct or cause the direction of the management and policies of the City (collectively called the "Section 16(b) Indemnified Parties "), from and against any and all losses, claims, damages, liabilities or expenses to the extent caused by or arising out of any untrue statement or misleading statement or alleged untrue statement or alleged misleading statement of a material fact (unless such allegation is (i) made by the Original Purchaser or the City, as the 16 145317261V -2 case may be, and (ii) such allegation is proven or otherwise determined to be false) contained in any of the Developer Information, or caused by any omission or alleged omission to state in the Developer Information a material fact required to be stated in the Developer Information or necessary to make the statements in the Developer Information, in the light of the circumstances under which they were made, not misleading. In case any claim shall be made or any action shall be brought against one or more of the Section 16(b) Indemnified Parties desiring to seek indemnification pursuant to this Section 16(b), the Section 16(b) Indemnified Parties seeking indemnity shall promptly notify the Developer in writing, and the Developer shall promptly assume the defense thereof, including the employment of counsel chosen by the Developer and approved by the Original Purchaser and the City, which approval will not be unreasonably withheld, and the payment of all expenses and disbursements of such counsel related to such defense. If any of the Section 16(b) Indemnified Parties is advised by counsel that there may be legal defenses available to it which are adverse to or in conflict with those available to the Developer or any other Section 16(b) Indemnified Party, or that the defense of such Section 16(b) Indemnified Party should be handled by separate counsel, the Developer shall not have the right to assume the defense of such Section 16(b) Indemnified Party, but shall be responsible for the reasonable fees and expenses of counsel retained by such Section 16(b) Indemnified Party in assuming its own defense, and provided also that if the Developer shall have failed to assume the defense of such action or to retain counsel satisfactory to the Original Purchaser and the City within a reasonable time after notice of the commencement of such action, the fees and expenses of counsel retained by the Section 16(b) Indemnified Parties shall be paid by the Developer. Notwithstanding, and in addition to, any of the foregoing, and subject to the approval of the Developer, which approval will not be unreasonably withheld, any one or more of the Section 16(b) Indemnified Parties shall have the right to employ separate counsel in any such action and to participate in the defense thereof, but the fees and expenses of such counsel shall be at the expense of such Section 16(b) Indemnified Parry or Parties unless the employment of such counsel has been specifically authorized, in writing, by the Developer, or unless such retention is specifically authorized herein. The Developer shall not be liable for any settlement of any proceeding effected without its written consent, but, if settled with such written consent or if there shall be a final judgment for the plaintiff, the Developer agree to indemnify the Section 16(b) Indemnified Parties from and against any loss, damage, cost, expense or liability by reason of such settlement or judgment. (c) In order to provide for just and equitable contribution in circumstances in which the indemnification provided for in this Section 16 is due in accordance with its terms but is for any reason held by a court to be unavailable to the Original Purchaser, the City or the Developer or unenforceable on grounds of policy or otherwise, the Developer and the Original Purchaser shall contribute to the aggregate losses, claims, damages, fines and liabilities (including any investigation, legal and other expenses reasonably incurred in connection with, and any amount paid in settlement of, any action, suit or proceeding or any claims asserted, but after deducting any contribution received by the Developer or the Original Purchaser from persons other than the Developer or the Original Purchaser who may be liable for contribution, such parties hereby agreeing to seek contribution from such persons) to which the Developer and the Original Purchaser may be subject in such proportion so that the Original Purchaser is responsible for that portion represented by the percentage that the underwriting fee bears to the offering price appearing on the cover page of the Limited Offering Memorandum, and the Developer is 17 14531726W -2 responsible for the balance; provided, however, in no case shall the Original Purchaser be responsible for any amount in excess of the amount of said underwriting fee received to such l,! date and provided, further, that no person found guilty of fraudulent misrepresentation, error or omission shall be entitled to contribution (or costs of defense) from any person who was not found guilty . of fraudulent misrepresentation, error or omission. For purposes of this Subsection 16(c), each partner, member, associate and employee of the Original Purchaser or the Developer 1 and each person who controls the Original Purchaser or the Developer shall have the same rights to contribution as the Original Purchaser or the Developer subject to the provisions in the preceding sentence relating to fraudulent misrepresentations. Any party entitled to contribution will promptly after receipt of notice of commencement of any action, threatened action, suit or proceeding against such party or parties under this Subsection 16(c), notify such party or parties from whom contribution may be sought, but the omission to so notify such party or parties shall not relieve the party or parties from whom contribution may be sought from any other obligation it or they may have otherwise under this Subsection 16(c). Any notice given pursuant to Subsections 16(a) or (b) hereof shall be deemed to include notice under this Subsection 16(c). 17. Further Reports. (a) The City agrees to provide the financial reports and information described in the Indenture and the Development Agreement which it has covenanted to provide to the Trustee, to the Original Purchaser and any Bondholder upon written request. (b) During construction of the Project, the Developer agrees to provide on a quarterly basis, an updated report showing all tenants within the portions of the Area owned by the Developer or an affiliate of the Developer that have signed leases. Such report shall include each tenant's name, the amount of square feet under lease, and the lease expiration date. In addition, such report shall provide the aggregate amount of square footage for which there are signed letters of intent and leases that have been sent out to tenants for execution, as well as a notification of any sale of any property within the Area that is owned by the Developer or its affiliates. (c) The Developer agrees that for so long as the Bonds are outstanding, it will include and incorporate into any agreement of conveyance or lease for any portion of the Area, the obligation of any purchaser or lessee thereunder to complete, execute and deliver to the City the Release Form (attached as Exhibit G to the Development Agreement). 18. Amendment or Assignment. This Contract may not be amended except through the written consent of all of the parties hereto and is not assignable. 19. Survival of Representations, Warranties, Agreements and Obligations. Each respective representation, warranty and agreement of the City, the Developer and the Original Purchaser shall remain operative and in full force and effect, regardless of any investigations made by or on behalf of the Original Purchaser, the Developer, and the City and shall survive the Closing. This Section 19, the obligations of the City under Sections 9, 10, 16 18 14531726 \V -2 and 17 hereof, the obligations of the Original Purchaser under Section 16 hereof and the obligations of the Developer under Sections 16 and 17 hereof shall survive any termination of this Contract pursuant to its terms. 20. Severabilitv. If any provision of this Contract shall be held or deemed to be or shall, in fact, be inoperative or unenforceable as applied in any particular case in any jurisdiction or jurisdictions, or in all cases because it conflicts with any other provision or provisions or any constitution or statute or rule of public policy, or for any other reason, such circumstances shall not have the effect of rendering the provision in question inoperative or unenforceable in any other case or circumstance, or of rendering any other provision or provisions herein contained invalid, inoperative, or unenforceable to any extent whatever. The invalidity of any one or more phrases, sentences, clauses or sections in this Contract shall not affect the validity of the remaining portions of this Contract, or any part hereof. [SIGNATURES FOLLOW] 19 14531726 \V -2 I [Signature Page to Bond Purchase Agreement] Very truly yours, WILLIAM BLAIR & COMPANY, L.L.C. By: Its: I Accepted and agreed to by the undersigned as of the date first above written. CANNONBALL, LLC an Illinois limited liability company By: THE HARLEM IRVING COMPANIES By: Its: UNITED CITY OF YORKVILLE By: Its: Mayor 20 14531726\V -2 Ex fl 16 1 - r i i �I i DEVELOPMENT AGREEMENT KENDALL MARKETPLACE Between the UNITED CITY OF YORKVILLE, IL OIS$` and CANNONBALLA,LC Dated as of 2007 CANNONBALL BEECH_ER ROM ROJECT A 14 W _._.. � s 4 S:\Chent Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc TABLE OF CONTENTS ARTICLE I - DEFINITIONS ........................................................ ............................... 2 ARTICLE II - DESIGNATION OF DEVELOPER .......................... ............................... 5 ARTICLE III - CONSTRUCTION OF DEVELOPMENT PROJECT ............................... 6 3.1 Construction Schedule .......................................................... ............................... 6 3.2 Developer to Construct the Project ........................................ ............................... 6 3.3 Cannonball Beecher Road Project ......... ............................... - 6 .. 3.4 Construction Contracts; Insurance ....... .............................40 ... :...................... 7 3.5 Governmental Approvals 3.6 Concept Site Plan .............................. 7 3.7 Construction Plans ..... .............................. .......... Certificate of Substantial Completion p _ .......... ....................... 7 3.8 3.9 Fees .......................................... ............................... 8 3.10 Quarterly /Annual Reporting ................... ... ................ 1: ;:......... . .... .. 8 � : ARTICLE IV - PAYMENT OF DEVELOPER CO SS ...... :-. ..................... ....:............... 8 �' g Y p er 4.1 City's Obligation to Pa Developer ., .... . ................. ................. 8 ... .. .: 4.2 Reimbursements Limited to Cannonball Beechesoa Proj °ect Costs; Developer's Right to Substitute ........... ............................... ._ ............ ............................... 8 ..... : > ` Via. ARTICLE V -SSA BONDS ...............a ..................".._........... ............................... 9 Mt , 5.1 Bond Ordinance: Pledged Taxes .. y.:, `" 9 �:: .. .............. ... ............................... 5.2 Application of Revenues /Abatemen Lam. = g � .............. 9 5.3 Issuance of Bonds ........................ _ �' .... ............................... 9 __ .. 5.4 Conditions of Issuance.,4%:.74_,............ f ............................... 9 - ............� r� ............. 5 .5 City's Bond Expens . ........ , .. ............. .............. ............................... 9 5.6 Disbursements to. Developer ".: ............ . 1 0 ............................ .............................. 5.6.1 Initial Certificate........ ........... ........... ............................... 10 5.6.2 Subsegrtificaof�Cannonall Beecher Road Project Costs........... 10 5.7 Maturity of Bonds ....' :: :.. _ ....... ............................... 10 .. 5.8 Cooperatio -n in the Issuance of Bonds ................................. ............................... 11 ARTICLE VI QLT ECTIO� . D USE OF REVENUE .............. ............................... 11 6.1 Crean of Furid ...... ........................... ............................... 11 6.2 C� eration in De e? ining R--venues ................................. ............................... 11 . ARTICLE, VII -GENE PROVISIONS ................................... ............................... 11 7.1 Successors and Assi s ...................................................... ............................... 11 7.1.1 Bii3ding Affect . ........................................................ ............................... 11 7.1.2 Ass anent rz ale .................................................... ............................... 11 7 .1.3 Targe�` ::............................................................. ............................... 12 7 .2 Remedies. .. ................................................................ ............................... 12 7.3 Force Majeu.. ................................................................... ............................... 13 7.4 Notices ............................................................................ ............................... 13 7.5 Insurance; Damage or Destruction of Project ....................... ............................... 15 7 .6 Inspection ........................................................................... ............................... 16 7 .7 Choice of Law ..................................................................... ............................... 16 7.8 Entire Agreement; Amendment ........................................... ............................... 16 7 .9 Counterparts ...................................................................... ............................... 16 7 .10 Severability ....................................................................... ............................... 17 7.11 Representatives Not Personally Liable ............................... ............................... 17 7 .12 Indemnification ................................................................. ............................... 17 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc I 7.12.1 Invalidity ................................................................. ............................... 17 I 7 .12.2 Damage or Injury ..................................................... ............................... 17 7.12.3 Personal Liability ..................................................... ............................... 17 7.13 Survival ............................................................................ ............................... 17 7 .14 Legal Opinion ................................................................... ............................... 17 7.15 Term 7.16 Conflict ............................................................................ ............................... 18 ARTICLE VIII - REPRESENTATIONS OF THE PARTIES ................ ......... 18 8.1 Representations of the City ........ _ .. 8.2 Representations of the Developer ......... ............................... .. . . .......... ............... 18 — ;AM . x a _ Ar { ' N F wN AA lot E� cf M g 2 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc EXHIBITS EXHIBIT A Legal Description of the Property EXHIBIT B Legal Description of the Special Service Area EXHIBIT C Cannonball Beecher Road Project Costs to be Paid with Special Service Area Bond Proceeds EXHIBIT D Form of Certificate of Substantial Completion EXHIBIT E Form of Certificate of Cannonball Beecher RAd Costs EXHIBIT F Concept Site Plan EXHIBIT G Target Tract AM , _= W . S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc l i DEVELOPMENT AGREEMENT THIS DEVELOPMENT AGREEMENT is made and entered into as of this day of . 2007, by and between the UNITED CITY OF YORKVILLE, Kendall County, Illinois, an Illinois Municipal Corporation duly organized and existing as a non -home rule unit of government under Section 7, Article VII of the 1970 Constitution of the State of Illinois, and CANNONBALL LLC, an Illinois limited liability company. Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in Article I of this Agreement. hwt- RECITALS A. As a non -home rule unit of government dulyrg -d under Section 7, Article VII of the 1970 Constitution of the State of Illina s, they has the power to regulate for the protection of the public health safetA morals and welfare of its inhabitants, and pursuant thereto, has the power,to encoixrage priva e evelopment in J� x r ,..4 order to enhance the local tax base, create employment ..opportunities &n ter into contractual agreements with private parties i der to achieve these goals ir 9 _ B. As a non -home rule unit of governmenCWi they Constitution of the State of Illinois, under the provisions of the Special Service_re Tax Law, 35 ILCS 200/27 -5 e sea ., and the Local Government D6bt Reform Act, 30 -1LCS 350/ 1 et sea., the City has the authority to provide special ery s. to an area wlrhln its boundaries and to levy a tax to pay for such services or the, pay ephn of debt i ccurred for that purpose. C. The Developerptaposes to col 4ct an 1 - proximately 800,000 square . foot mix of retail storesr fSta�� ants and spac and in support thereof and on behalf of the City to delicate cer'fain land t City and the Illinois Department of Transportation for fg is of way to construc€ 6nnonball Trail Road and Beecher Road including paving; � triping igx age, acc Yeration /deceleration lanes and other related improvements an ti'uthfi`es; anci other improvements at the intersection of_Cannonbal ail and Illiriois Route 34 in the City. I17In order to - n thy:=, loper to undertake the Project, the City desires to - ° ;. createa_a Special Servlce.rea pub uant to the Special Service Area Tax Law, to impose cerUdir axes within th _ Service Area, to issue the SSA Bonds, to use the proceed the sale of the SSA Bonds to pay for special services in the Special Service Area'asld to e the Special Service Area revenues to retire the SSA Bonds. E. On I3aaxier 12, 2006, the Corporate Authorities adopted Ordinance No. 2006- `An Ordinance Designating United City of Yorkville Kendall Marketplace Bus ess District and Imposing a Retailer's Occupation Tax and Service Occupation Tax Therein," making all of the findings required under the Business District Act to cause the creation of the Business District, and approving the District Plan, and on , 2006 in furtherance of the District Plan "An Ordinance of the United City of Yorkville Authorizing the Issuance of $ - Business District Revenue Bonds Series 2006 (Storm Water /Water Improvement Project) (collectively the `Business District Ordinances'l. F. On March 6, 2007, after giving all notices and holding all hearings required under the Special Service Area Law, the City adopted "Ordinance No. An S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc Ordinance Establishing United City of Yorkville Special Service Area Number _ , and ) on 2007 adopted Ordinance No. Authorizing The Issuance of $ Special Service Area Number Ad Valorem Tax Bonds of the United City of Yorkville, Illinois (collectively the "SSA Ordinances "). Now, therefore, in consideration of the premises and promises contained herein and other good and valuable consideration, the adequacy and sufficiency of which are hereby acknowledged, the parties hereto agree as follows: ARTICLE I DEFINITIONS _. As used in this Agreement, including the Recitals he_ hich, _; is reference are incorporated herein, the following words and terms , a1;ave the following meanings: "Agreement" means this Development i eement, as the same _ _ay be from time to time modified, amended or supplemex d_. writing by the partie!O ereto. ., "Bonds" means the SSA Bonds. "Bond Counser means Foley `T dner LLP, or >lattorney at law or a firm of attorneys acceptable to the City o i3' : pally recogrzd standing in matters pertaining to the tax- exempt nature of interes ion obliga#ons issued by states and their political subdivisions duly admitted -- " o the prarof law before the highest court of any state of the United a:fa L Americ�a-�.or`�the Distft of Columbia. "Bond Ordinance" me s Ordin - =,ce No. 2007- "An Ordinance Providing for Issu fq�ej of Unit City of YdWv - ille, Kendall County, Illinois Special Service Area Revenue _ o °ds -S -2.007 Cinonball Beecher Road Project). "Bonr�fPrviceeds" m " s the gross cash proceeds from the sale of the Bonds n. =. .. before pa77nent of�uance Cn s together with any interest earned thereon. A r s iness Dist me s a district within the City created pursuant to the BusinesDistrict Act °gse boundaries are coterminous with the Special Service Area. " Busnne-s Di_. met Act' means the Business District Development and Redevelopment A 3 =5 ILCS 5/11-74.3 et seq "Business District Ordinance" means Ordinance No. 2006- "An Ordinance Designating United City of Yorkville Kendall Marketplace Business District and Imposing a Retailer's Occupation Tax and Service Occupation Tax Therein," making all of the findings required under the Business District Act to cause the creation of the Business District, and approving the District Plan. "Business District Revenue Bonds" means the United City of Yorkville Business District Revenue Bonds Series 2007 (Storm Water /Water Improvement Project) . 2 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc "Business District Revenue Bond Indenture" means the Trust Indenture ted as of , 2007 by and between the City and the Business District -venue Bond Trustee pursuant to which the Business District Revenue Bonds were ;ued. "Business District Sales Tax" means the one half of one percent (.5 %) lsiness District Sales Tax levied by the City in the Business. District on sales by :ailers and servicemen operating in the Business District, anrl'a tax intended to dace the same as enacted by law or ordinance of the Citf" or any governmental thority during the Term of this Agreement. RO "Cannonball Beecher Road Project" means t os a impt v mens listed on :hibit C hereto constituting the improvements to T aid for fra n t ie proceeds of Bonds and benefiting the Special Service Are ` "Certificate of Cannonball Beecher4Road Project y Costs" mean - document bstantially in the form of Exhibit E attaced, he_'eioand incorporated herein )vided by the Developer to the City in ac with this Agreement and dencing Cannonball Beecher Road�Project Costs irl1ured or to be incurred by the F veloper and eligible for payment der the terms ofd =his Agreement and the SSA W. �.. a t "Certificate of Substantial Co letton m a document substantially in form of Exhibit D, atta c hereto and - ncorporat d herein by reference, issued by Developer to the City in "V ordance with this Agreement and evidencing the veloper's substanti satisfaction of al A- aterial obligations and covenants to l zstruct the Canno ball Beec1Road Project as set forth in the Concept Site Plan. ., "City" means the , U. J . i of orkville, Kendall County, Illinois, an Illinois lnicipal Q Qaton an � aeon -home rule unit of government duly organized and sting thed =l 0 Consfi_ Lion of the State of Illinois. n City AttornejV' means John Wyeth, or an attorney at law or a firm of attorneys septa to the City V recognized standing in matters of municipal law duly rlitted €Qrthe practice oYaw before the highest court of the State of Illinois. l CZosingDatek means 2007 or such earlier date as the City, the veloper and theFzderwriter of the Bonds shall mutually agree upon and refers to transaction ixlvhich the Bonds are delivered by the City to the Underwriter, the 1 ►ceeds are available to be paid to the Developer, and this Agreement is fully t - cuted. "Concept Site Plan" means, collectively, those documents set forth in Exhibit attached hereto and incorporated herein by reference, depicting the conceptual igram for construction of the Project, as modified by the Developer from time to ie. t 3 :lient Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc "Construction Plans" means plans, drawings, specifications and related ) documents, and construction schedules for the construction of the Project, together with all supplements, amendments or corrections, submitted by the Developer and approved by the City in accordance with and as required by this Agreement. "Corporate Authorities" means the City Council of the City. "Developer" means CANNONBALL LLC, an Illinois limited.. liability company, or its permitted successors or assigns in interest. "Governmental Approvals" means all plat approv zoning or other zoning changes, the PUD Ordinance, IDOT approvals, site p1 app prQ. ls, conditional use �P� permits, variances, building permits, or other subdivision ,�wzoning, similar approvals required for the implementation of the contemplatect and a ._ istent with the Concept Site Plan and this Agreement. , Indenture means the Special Service 1 -ea Tax Revenue Bond In - enture. "Issuance Costs" means all costs reasaxby incurred by the City in furtherance of the issuance of the Bonds, including'[W.* out limitation the fees and expenses of financial advisors and A it�ants, the City s ttorneys (including issuer's counsel and Bond Counsel), the City adin- i- nistrative fees and expenses (including fees and costs of planning consultants, under ter s' dise nts and fees, the costs of oz �: printing any Bonds and any official state . tents rekaO g thereto, the costs of credit enhancement, if any, ca _ ; _. rzd interes debt serve reserves and the fees of any rating agency rating a y Bonds:. "Local Gover7 tnent DeAW Reform " means the Local Government Debt Reform Act, 30 ILCS 35QY=1 "Net Pt oceeds" meAr - sthe proceeds derived from the issuance of the Bonds, . - d4� 4. net of a M9 R4sts. Project" means =e construction of approximately 800,000 square feet of retail space, 1 staurants, an office space and all work incidental thereto for the conteml Project as =described in this Agreement as approved or amended by the Concept SitFlan, and other work reasonably necessary to effectuate the intent of this Agreement "Propertt, j eans approximately One Hundred Ninety (190) acres of real property (including without limitation all options held by third parties, fee interests, leasehold interests, tenant -in- common interests and such other like or similar interests) and existing improvements necessary for the implementation of the contemplated Project as legally described on Exhibit A hereto by this reference incorporated herein. "PUD Ordinance" means Ordinance No. passed by the Corporate Authorities of the City granting a special use for planned unit development for the Property and related matters. 4 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc "Request For Payment" means the document attached to the Indenture as Exhibit by which the City shall request a payment of Bond Proceeds from the Trustee in order to reimburse the Developer for the Cannonball Beecher Road Project Costs. "Special Service Ared' means the district within the City created pursuant to the Special Service Area Tax Law and legally described on Exhibit B attached hereto and incorporated by reference herein. Special Service Area Tax Law" means the SpecialMe _v_ ice Area Tax Law 35 ILCS 20/27 et seq. also referred to as the "SSA Law." r "SSA Bonds" means the United City of Y,6&- �, Kendall County, Special Service Area Revenue Bonds, Series 2007 (Cannon all Beecher Road Pryect) "SSA Tax" means the ad valorem ta eYied a ally by the City against all real property in the Special Service Area at a ra�e suffid.' to pay the interest on the SSA Bonds as it falls due and to discharge the g p�ipal thereof at maturity, if not W otherwise abated. 5-. - � : "SSA Bonds" means any obl atldri secured by' A SA Tax and authorized and issued by the City to fund all or aportiothp Canniball Beecher Road Project costs in accordance with the SSA LaWr_ th_ oc ,W- rnment Reform Act and this Ap Agreement. - ' "SSA Tax Revenue Bo f %l dentIve means the Trust Indenture dated as of A 2007, by�&h eeg5 City a C- the SSA Tax Revenue Bond Trustee pursuant to which the =SSA Bgm g- re is su d. :£ "SS a�e�Revenuel t and Trustee" means The Bank of New York Trust Comp 1 1.`N: A:, —�ffiits succ ors and assigns, as trustee for the SSA Revenue Bonds. get Tract x1} ans that portion of the Property legally described on Exhibit G hereto. "Trust N X , can the SSA Tax Revenue Bond Trustee. "Underwriter" means William Blair & Company, L.L.C. or any firm of nationally recognized underwriters chosen by the City. ARTICLE II DESIGNATION OF DEVELOPER I The City hereby acknowledges the construction of the Project by the Developer and selects the Developer to construct or cause the construction of the Cannonball Beecher Road Project improvements in accordance with the Concept Site Plan, this Agreement and all Governmental Approvals. Provided that the Bonds have first been . 5 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc issued and sold, the Developer hereby accepts such designation and agrees to cause the completion of the Project and the Cannonball Beecher Road Project improvements in accordance with the terms and conditions hereof. ARTICLE III CONSTRUCTION OF DEVELOPMENT PROJECT 3.1 Construction Schedule. The Developer shall commence construction of the Project within One Hundred Twenty (120) days of the later t`d &�}r of (a) Developer obtaining all necessary permits and Governmental Approval;, or (b six (6) months after execution of this Agreement, and shall substantially o`_mMete construction of the following approximate square feet of retail, restaut.1 " commercial space _ comprising the Project as follows: �. ;:. ,,� November, 2007 90,000 square feet of an. hor space; August, 2008 475,000 square fe including approxima We 280,000 t_ square feet of anchor�space); October, 2008 45,000 square feet; `= March, 2009 160,000 square feet; and October, 2009 30,000 sq�u��ire feet, all suhjecto force majeure as set forth in Sectioii7 below. 3.2 Developer to Construct Sh e Project The�D'veloper shall commence or cause the commencement of the cons" c o ofd e roject in accordance with the terms of this Agreement arde_ -Concepf�,� Plan. T e extent of any inconsistency among the foregoing, .; ree th the Conc g g tl��' p artiesxa a.; t Site Plan shall overn so ton as performance in a4eordam erewith 8_es. not violate Governmental Approvals. The Developer shil_conplete cause the ; completion of the Protect in accordance with the terms of and scho- uI set forth rl Section 3.1 of this Agreement. 3.3 - Caftnonball her Road Project. The Developer, on behalf of the .; City, shat causae Can _x ball Beecher Road Project improvements to be construed for the bent of the pecial Service Area, in accordance with the terms of this The Ci ,acknoedges that by a supermajority vote of the Corporate Aufhorrts.� it does not tend to design, bid or construct the Cannonball Beecher Road Projet�mproveme ts. The City agrees that since the Cannonball Beecher Road Project improv� ments a -- * o be paid for by the Net Proceeds of the SSA Bonds, that the Developer shall ons_ti�t the Cannonball Beecher Road Project improvements on behalf of the Ci sing subcontractors and materialmen selected from time to time by the Developer, in s sole discretion, without advertising for bids as permitted by the provisions of 65 ILCS 5/8 -9 -1 of the Illinois Municipal Code. The City, by entering into this Agreement agrees to waive the requirement to bid any contracts entered into between the Developer and subcontractors for installation of the Cannonball Beecher Road Project improvements. All Cannonball Beecher Road Project improvements to be constructed hereunder shall be constructed in substantial accordance with any final plans approved by the City. Such Cannonball Beecher Road improvements shall be all as approved by the City and in accordance with all applicable laws, ordinances, rules and regulations. The Cannonball Beecher Road Project improvements shall be constructed in a good, workmanlike and commercially reasonable manner. 6 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc i I I 3.4 Construction Contracts; Insurance. The Developer may enter into or cause to be entered into one or more construction contracts to complete the Project and the Cannonball Beecher Road Project. Prior to the commencement of construction of any portion of either Project, the Developer shall obtain or shall require that any of its contractors obtains workers' compensation, comprehensive public liability and builder's risk insurance coverage in commercially reasonable amounts and shall deliver evidence of such insurance to the City. 3.5 Governmental Approvals. The "City agrees tc employ reasonable and good faith efforts to cooperate with the Developer and to P rZ . F' b g p p ss and timely consider ...- and respond to all applications for the Governmental. as received, all in accordance with the applicable City ordinances and la: A the Std e _of Illinois. ._ 3.6 Concept Site Plan. The Concept Site Plan is herel y approved in accordance with applicable City ordinances and hides. z 3.7 Construction Plans. The Constructaon Pj"aris, for the Project and the Cannonball Beecher Road Project shall be prepare � y a - professional engineer or architect licensed to practice in the State of Illinoisan he Construction Plans and all construction practices and procedu t" th respect to 4 ffl_U` roject and the Cannonball Beecher Road Project shall be in substa�ifialr- c onformity vii €th all applicable state and local laws, ordinances and regulations, Iri n� �conjunctio with obtaining a building permit for the commencement of construction cof Proj ect and the Cannonball Beecher Road Project, th.. tD per shat bmit Construction Plans for approval by En� the City in sufficient grpmplete ss and d tail to show that construction will be in conformance with thefOoncept Site Plan an%this Agreement. Ilk 3.8 Certifica& of SuS8tant al_ Completion. Promptly after substantial completion of the Cannor%- Beecher Zo Project, the Developer shall furnish to the City a Cer a �tn_a f Substai 'al Completion. The City shall, within thirty (30) days following frd.elivery ' tifi e C cate of Substantial Completion, carry out such inspections as it deems necessa o verify to its reasonable satisfaction the accuracy Of tl� Acertifications ccf�x�ained ?fin the Certificate of Substantial Completion. The Cer`.ific• of SubstantiCompletion shall be deemed accepted by the City unless, within thin -(30) days following delivery of the Certificate of Substantial Completion, _. - V the City furi Mhes the Developer with specific written objections to the status of the Cannonball B ether o d Project improvements, describing such objections and the :�- - measures require° c` correct such objections in reasonable detail. Upon acceptance of the Certificate of substantial Completion b the City or upon the lapse of thirty 30 ��. p Y tS' p P rtY ( ) days after delivery thereof to the City without any written objections thereto, the Developer may record the Certificate of Substantial Completion with the Kendall County Recorder of Deeds, and the same shall constitute evidence of the satisfaction of the Developer's agreements with regard to construction of the Cannonball Beecher Road Project. The Certificate of Substantial Completion shall be in substantially the form attached as Exhibit D, attached hereto and incorporated by reference herein. The City acknowledges and agrees that it shall not deliver the certificate referred to in Section 4.2(c) of the SSA Tax Revenue Bond Indenture certifying that the Cannonball 7 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc Beecher Road Project is completed until the Developer has delivered the Certificate of Substantial Completion and such Certificate has been accepted by the City. 3.9 Fees. Other than customary tap fees, no fee or charge of any description including, without limitation, building permits, plan review, inspection fees, or other regulatory fees or charges, shall be imposed on Developer or on the development and use of the Property unless, as of the date of this Agreement, such fee or charge is an existence and being collected by the City on a uniform basis from all owners, users, and petitioners of property within the City. The City shall not irqlease the amount of <� any fee or utility fees, application fees, or user fees during the -Term o this Agreement unless such increases are (i) made generally applicable tntl_..owners and users of property within the City and (ii) reasonably related to iri ea ecT osts incurred by the City in providing the services for which such fee is assessed.. 3.10 Quarterly /Annual Reporting. Du g construction of't �.PrJect, the Developer shall deliver quarterly construction ,piro`gress reports to the Tr ? - e and the Underwriter. After the Certificate of Substant 'G.ompletron is accepted, ie Developer -• : _� shall deliver to the Trustee and the Underwrite.- ules of tenants and lease expiration dates for the Project. �RICLE IV , PAYMENT 6 DVEV LOPER COS'T'S 4.1 City's Obligation to Pay b agrees to pay Developer for the verified Cannonbaloeeher Roadloject co_ s in the amount as set forth on Exhibit C, attached he to -Rl , y � rp y b this reference lnco orated herein as may be adjusted pursuant to is Artiel "AW. Subject tQthe terms of the Bond Ordinance, the Indenture and thi lgr ement he City ag� s to issue the Bonds and to pay the Developer for verifiednon13_ - eeekier� cad Project costs pursuant to Section 3.3 above, from Net Proceeds e orFC -in an amount equal to Eight Million Three Hundred N ne One Thousand Five Hundred Twenty Two Dollars ($8,391,522) for verified a:nnonBeecher aad Project costs as provided in Article V of this Agreement. Reimburse.... - ents Limited to Cannonball Beecher Road Project Costs; Develope - I 'ght to Su titute. Nothing in this Agreement shall obligate the City to issue Bonds to. pay Dev.� oiler for any Cannonball Beecher Road Project cost that does m not qualify for yer<i under the SSA Law. The Developer shall, at the City's request, provide itemize € _, truction loan draws, invoices, or receipts or, in the case of the acquisition of 1 1 evidence that the Developer has acquired fee title to such land and evidence of the total acquisition price of such land, reasonably requested by the City to confirm that any such cost is so incurred and does so qualify. Each such request shall be in the form of a Certificate of Cannonball Beecher Road Project Costs and accompanied by a certification by the Developer that such cost is eligible for payment or reimbursement under the SSA Law. The parties agree that each of the categories of costs set forth in Exhibit C shall constitute Cannonball Beecher Road Project costs which are eligible for payment or reimbursement in accordance with the SSA Law and this Agreement. If the City engineer determines that any cost identified as a Cannonball Beecher Road Project cost is not a reimbursable cost under the SSA Law, g S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc I the City shall so notify the Developer in writing within thirty (30) days as provided in Section 5.6 of this Agreement, identifying the ineligible cost and the basis for determining the cost to be ineligible, whereupon the Developer shall have the right to contest such determination and /or identify and substitute other Cannonball Beecher Road Project costs with a supplemental application for payment. ARTICLE V SSA BONDS 5.1 Bond Ordinance: Pledged Taxes. The City a opted the Bond Ordinance for the SSA Bonds, subject to the provisions, 5.3, and has provided for the designation of a Trustee. The SSA Be ds s 1 be retired over a period not to exceed thirty (30) years and be secured by - pledge =o_the SSA Tax. The Indenture provides for the segregation and deposit -PA Tax. 169 5.2 Application of Revenues /Abatement of Levy. The SSA :Tx shall be applied to the retirement of the SSA Bondsia, cord be with the Boid Ordinance and the Indenture. The City agrees that to th64 -TB tent ht re are revenues from the .'4T Business District that are not needed to pay annu . m debt service on the Business District Revenue Bonds, the City shall annually appR`! l such excess revenues to the -_ abatement of the SSA Tax levy in ans prit not to exceed the amount of the levy in that year in accordance with the Bus riess strict RevenukBdnd Indenture. 5.3 Issuance of Bonds. The City grees tussue the Bonds pursuant to the SSA Law and the Local Gov_nent DeUReform A5tA`in an amount to be determined by the Underwriter bas(:r on th rrlount o the Net Proceeds projected to be deposited in the various fundsAGd accounts as pro ded for in the Bond Ordinance and the Indenture; provided'owever, ir event salt the aggregate Net Proceeds of the SSA Bonds initially deposlted;ui the npmvemen Fund, as defined in the Indenture, equal an amount less than Eig I ndred Ninety One Thousand Five Hundred Twenty Tw2}lars (8,3'3522) from the SSA Bonds unless agreed to by the -� Developer "In ace#rfon to such Net Proceeds for Cannonball Beecher Road Project costs, 4ie amount of e Bonds hall be sufficient to pay for all Issuance Costs assoc_rated with issuing BoYi s as provided in the Bond Ordinance. The Bonds d_ shah ria -be general obligations of the City and shall be secured solely by the SSA Tax. Neither thj#, e ment rlo the Bonds shall constitute a full faith and credit obligation of the City. m 5.4 Coif0i s of Issuance. The City's obligation to issue the Bonds described in Section 5.3 is expressly contingent on a bond opinion from Bond Counsel opining that the Bonds are being issued in accordance with the SSA Law and the Local Government Debt Reform Act, and that the interest thereon is exempt from federal taxation. 5.5 City's Bond Expenses. The administration of the Bonds has resulted and will result in expenses for the City. Any Trustee's fees or legal fees for a legal opinion to be relied on by the bond holders, due and owing as of the Closing Date shall be paid from Bond proceeds. 9 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc 1 5.6 Disbursements to Developer. 5.6.1. Initial Certificate. Ten (10) days prior to the Closing Date, the Developer may deliver to the City a Certificate of Cannonball Beecher Road Project Costs covering eligible Cannonball Beecher Road Project improvement costs incurred by the Developer prior to the Closing Date and to be paid to the Developer on the Closing Date. The City shall accept or reject such Certificate within three (3) business days after receipt thereof ar1ti_a11 on the Closing Date, submit a Request For Payment to the Trustee for `the Bonds with instructions to reimburse the Developer, or the a 5aty designated by the Developer in the amount set forth therein upon .e eipt e City's acceptance or rejection of the initial Certificate shall be in .writing,clin the case of a rejection, shall specifically state the reason ° such rejec ion. If the City � rejects all or any portion of the initial Certificate of Cannonballl3eecher Road Project Costs, Developer shall have the pght to .i, d entify and subtti u e eligible Cannonball Beecher Road Project cosh C� fails to accepfor reject the Certificate of Cannonball Beecher Road Proect Costs?- within such three (3) day period after submission by Developer, the 1r1It Certificate shall be deemed to have been accepted by the Ci and payments;;_ all be made by the Trustee to the Developer. - Aa 5.6.2. Subsequent Certificates ECannonball Beecher Road Project Costs. Thereafter, the City shal% ; j . ays after acceptance by the City of each Cert Z CannoRa- I Beech_ . Road Project Costs, submit a Request For PaMhent v- the TA . ee for he Bonds with instructions to reimburse the feveloper, .; or the party designated by the Developer, for such construction-fa civances � the amONA set forth therein (a "Construction qM Payment'sTh.ity ce _ reject each Certificate of Cannonball Beecher Road Pra g' Costs su itn tted by Developer within fifteen (15) days after ,�submission by .Developer. Such acceptance or rejection by the City of each Certi e shall: in writing, and in the case of a rejection, shall A , ecifically t .the reaQ s for such rejection. If the City rejects any A , ertificate of Cannonball= eecher Road Project Costs submitted by Developer, ey�loper shall h ve the right to identify and substitute eligible Cannonball B e ebf ier Road Prcj t costs. If the City fails to accept or reject the Certificate of Cannofi all Beecher Road Project Costs within fifteen (15) days after submis by_Developer, the resulting Construction Payment(s) shall be deemed t ' ie been accepted by the City on the sixteenth (16th) day after submissiof the Certificate of Costs by the Developer. Construction Payments shall be issued no more than once every month until all such Construction Payments as are required by this Agreement have been paid. The City covenants to pay or cause to be paid to Developer, or its designee, all amounts received by the City from the Trustee pursuant to each Request For Payment relating to a Certificate of Cannonball Beecher Road Project Costs submitted by the Developer upon receipt thereof. 5.7 Maturity of Bonds. The final maturity of the Bonds shall not exceed the maximum term permissible under the Local Debt Reform Act. The Bonds shall bear 10 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc interest at such rates, shall be subject to redemption and shall have such terms as the City shall determine in its sole discretion. 5.8 Cooperation in the Issuance of Bonds. The Developer covenants to cooperate and take all reasonable actions necessary to assist the City and Bond Counsel, the Underwriter and the City's financial advisor in the preparation of offering statements, private placement memorandum or other disclosure documents and all other documents necessary to market and sell the Bonds. ARTICLE VI COLLECTION AND USE OF REVENUE=%?s 6.1 Creation of Funds. The City agrees to cause its I5reetor of Finance or other financial officer to maintain the funds require by Bond O ?4mance, the SSA NO Ordinances and the Indenture including such fur�thdr accounts or sub °accou lts as are required therein, by this Agreement or as the Mfector otFinance of the C1t may deem appropriate in connection with the admin f aeon of - th funds pursuant to this Agreement. Subject to the requirements of thASS L -aid the Local Government Debt Reform Act, the City will promptly upon recelp Hereof deposit all Bond Proceeds and SSA Tax in the funds or in suc other accouff s =as required under the Bond Ordinance and Indenture. 6.2 Cooperation in Determining Re enues. he City and the Developer ..�.. _ agree to cooperate and take all reasona'f le M5 ( s:' ecessary to cause the SSA Tax to R be paid into the fundsA' accounts ...._s' provide W in the Bond Ordinance and Indenture, including the City'• enforcerri -nt and collection of all such payments through all reasonab. and ordinary legal mans of enforcement. T _ _� 4 - ART LE VII _ GENERAL PROVISIONS = / 4 77­1 Successors_ and Assin s. MAI 7.1.1 Bind th Affect. This Agreement shall be binding on and shall inueAo the benefit of the parties named herein and their respective heirs, admlrlisi ators, executors, personal_ .representatives, successors and assigns. Assignment or Sale. All or any part of the Property or any interest th mein may be sold, transferred, encumbered, leased, or otherwise .,- disposed of at any time, and the rights of the Developer named herein or any successors in interest under this Agreement or any part hereof may be assigned at any time before, during or after redevelopment of the contemplated Project, whereupon the party disposing of its interest in the Property or assigning its interest under this Agreement shall be thereafter released from further obligation under this Agreement (although any such Property so disposed of or to which such interest pertains shall remain subject to the terms and conditions of this Agreement), provided that until substantial completion of the contemplated Project, the rights, duties and obligations of the Developer under 11 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc this Agreement shall not be assigned in whole or in part without the prior 1 written approval of the City, which approval shall not be unreasonably withheld, conditioned or delayed upon a reasonable demonstration by the Developer of the proposed transferee's or assignee's experience and financial capability to undertake and complete such portions of the Project and perform the Developer's obligations under this Agreement, all in accordance with this Agreement. Notwithstanding anything herein to the contrary, the City hereby approves, and no prior consent shall be required in connection with: (a) the right of the Developer to encumber or collaterally assi, ss interest in the Property or any portion thereof to secure loans, advancer extensions of credit to finance or from time to time refinance all or any ; ;t �of the Project costs, or the right of the holder of any such encumbrarnGt; or transferee of any such collateral assignment (or trustee or agent on its behalfl to trasfer such interest by foreclosure or transfer in lieu of foreclos re�g su6%acumbrance or O g p gn Ii Developer's collateral assignment; or b the right ofevelo er to assi rights, duties and obligations under thi %AA greer ent to any party re° ated to the Developer by one of the relationships ,,,described ink`-- Section 267(b�' f the United States Internal Revenue Code of 1986, as amende, rovided that in each such event (i) the Developer named herein (Cannball LLC) shall remain liable hereunder for the substantial _ mpletion of tli c ptemplated Project and shall be released from such liabili ereunder only uip substantial completion of the contemplated Project an d •' tii4eD.eveloper pr a _ 'des to the City thirty (30) days' advance written notice of p ro 'sed assigrim nt or transfer; or (c) the right of Developer to transfer urge xact to Target Corporation, a Minnesota corpor 7.1.3 T rget Trac bNotwiths and'ng anything to the contrary contained in this Agredffle`- t, the City acknowled es and agrees that Target Corporation, `? - - urc ser and owner of the Target Tract, shall its successors d ,as i °h not be liable for p6 of Developers obligations under this Agreem ��ncludin ., , ithout limitation, the obligation to complete any site work a--... -imprbverx>ents, po ng s f nancial security, or incurring any costs pursuant othis Agreemen Up0Developer's completion of its obligations under this G eement with ect tg the Project, the City agrees to promptly execute, at no:-charge to Targef a recordable Termination and Release of this Agreement for th 'get Tract frWm those obligations under this Agreement. Notwithstanding anyth to the c6 itrary contained in this Agreement, the City consents to the transfef ti tl from the Developer to Target of the Target Tract and acknowle ge : at Target may thereafter transfer or convey interests in the Target Tra in Target's sole and absolute discretion. 7.2 Remedies. Except as otherwise provided in this Agreement and subject _ to the Developer's and the City's respective rights of termination, in the event of any default in or breach of any term or conditions of this Agreement by either party, or any successor, the defaulting or breaching party (or successor) shall, upon written notice from the other party specifying such default or breach, proceed immediately to cure or remedy such default or breach, and shall, in any event, within thirty (30) days after receipt of notice, commence to cure or remedy such default or breach. In the event that the defaulting or breaching party (or successor) diligently and in good faith 12 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc commences to cure or remedy such default or breach but is unable to cure or remedy such default or breach within thirty (30) days after receipt of notice, the defaulting or breaching party (or successor) shall, prior to the end of such thirty (30) days, provide notice to the other party that it has in good faith commenced to cure or remedy such default or breach, whereupon the defaulting or breaching party (or successor) shall have an additional ninety (90) days to cure or remedy such default or breach. In case such cure or remedy is not taken or not diligently pursued, or the default or breach shall not be cured or remedied prior to the end of the additional ety (90) - day period, the remedy to the aggrieved party shall be as set forth below: z (i) If the Developer is in breach of this Agreemen City's remedy at law or in equity, shall be to suspend payments = the ­ loper under this Agreement until the Developer has cured or substantially ce such breach, at which time payments to the Developer under=.. , Agree men hall resume. If, however, the Developer is in breach for :fure to compl ete Cannonball Beecher Road Project and if the Develope -1. all not cure or remedy such breach within the time period stated abovq��nd suctime period lids not been extended or such breach excused due to =Brae maju:ere, then the City shall be entitled, upon written notice to the Developd'to complete, or to cause the completion of, the Cannonball Beecher Road Proeet. w - (ii) If the City is in breach af_ . 15� ree ment, the Developer may pursue any and all legal and equitable remedie a lable to it-4 as a result of such breach, including without limitation ter a on of: tLisAgreement or proceedings to compel specific perfortiaarnce. 7.3 Force Mai ure. Neither the City nor the Developer nor any successor in interest shall be cd isidered in lireach or deault of their respective obligations under 4 _�,N this Agreement, and times foeffarnancf obligations hereunder shall be extended in the event of any dela c se y horce majeure, including without limitation, damage or coon byfire or casualty; strike; lockout; civil disorder; war; restrictiv_ government. regul ti_ ns;- lack of issuance of any permits and /or legal 1 authorization by the - g,�o e�rnmen entity necessary for the Developer to proceed with kg con sction of the wor or any :portion thereof; delay in commencement or completion . :- s -a of any xi� all work tolbe performed by others that affects Developer s ability to commence 6g, complete tb:e Project; shortage or delay in shipment of material or fuel; acts of Godunusuallydverse weather or wet soil conditions; or other like causes beyond the pacts ea`sonable control, including without limitation any litigation, court order or t resulting from any litigation affecting the validity of the SSA Tax, the contem "I`ated Cannonball Beecher Road Project or the Bonds, the PUD Ordinance, this greement, or eminent domain actions; provided that such event of force majeure shall not be deemed to exist as to any matter initiated or sustained by either party to this Agreement in bad faith, and further provided that the party claiming the benefits of this Section 7.3 notifies the other in writing within thirty (30) days of the commencement of such claimed event of force majeure. 7.4 Notices. Any notice, demand or other communication required by this Agreement to be given by either party hereto to the other shall be in writing and shall be sufficiently given or delivered if (i) dispatched by certified United States first class 13 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc mail, postage prepaid, (ii) sent by a nationally recognized overnight courier, or (iii) ) delivered personally: (i) In the case of the Developer, to: Cannonball LLC c/o The Harlem Irving Companies, Inc. Attn: Managing Director of Real state 4104 North Harlem Avenue Norridge, IL 60706 With a copy to: Cannonball LLC a c/o The Harlem Irvin. Cdiinpanies Attn: General Coun 4104 North Harl . enue Norridge, IL 6Q 06 With a copy to: Polsky & Associates; `.'d 205 N. Michigan Ave�e 41 S?1�o'or �... Chic o; 1 '-601 (ii) In the case o;h'ty, to: nited Ci Mof Yorkville, Illinois office of thayor 006 Gamey arm Road 01Ilinois 60560 An- - nited City of Yorkville, Illinois affice of the Treasurer •_.00 Game Farm Road Yorkville, Illinois 60560 With a co y { ' Foley & Lardner LLP Attn: Christopher N. Knight 321 N. Clark Street Suite 2800 Chicago, Illinois 60610 or to such other address(es) with respect to either party as that party may, from time to time, designate in writing and forward to the other as provided in this paragraph. 14 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc 7.5 Insurance; Damage or Destruction of Project. The Developer shall provide and maintain, or cause to be provided and maintained, at the Developer's own expense, during the Term of the Agreement (or as otherwise specified below), the insurance coverages and requirements specified below, insuring all operations related to the Agreement. (a) Throughout the Term of the Agreement f_.,. (i) Commercial General Liability Insurance (Priliary� and Umbrella) Commercial General Liability Insurancat.equivalent with limits OW of not less than $1,000,000 per eEUrre for bodily injury, personal injury, and property damage liabiliCoverages shall include the following: emises d operations, products/ completed oper tans, lndependericotractors, separation of insureds, defe se, arxd contractual liabi`liiy (with no limitation endorsement). City is Q be named as�ran additional -A, insured on a primary, no basis for any liability arising directly or indirectly fro'ine word. (b) Construction _ - f W Commercial General. Liab�ik lrisuran ce ('Primary and Umbrella) v Comrneb a1AGenerYAL1. lity In ut ance or equivalent with limits of riot less than $2,0V0,000 per occurrence for bodily injury, , personal injy, and prperty damage liability. Coverages shall :._ g P P dude tk followin All remises and operations, PAod Ct�sole tedeations (for a minimum of two (2) years follovg; prolectcoxnpretion), explosion, collapse, underground, =_ depef da t contractors, separation of insureds, defense, and cl- itractu�l�liabi_lity (with no limitation endorsement). The City is U r . � � t e nam d� -;as an additional insured on a primary, non - � cob- butory asis for any liability arising directly or indirectly `- from2e work. w gr Builders Risk Insurance �.e-. xct. . hen the Developer or its contractor undertakes any E � construction, including improvements, betterments, and /or repairs, the Developer shall provide, or cause to be provided All Risk Builders Risk Insurance at replacement cost for materials, supplies, equipment, machinery and fixtures that are or will be part of the permanent facility. Coverages shall include but are not limited to the following: collapse, boiler and machinery if applicable. The City shall be named as an additional insured and loss payee. (c) Post - Construction 15 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc 1� (i) Post - construction, throughout the Term of the Agreement, All Risk Property Insurance, including improvements and betterments in the amount of full replacement value of the Property. Coverage extensions shall include business interruption /loss of rents, flood and boiler and machinery, if applicable. The City is to be named an additional insured on a primary, non - contributory basis. (d) Other Recauirements. The Develo will furnish the City original Certificattf Insurance evidencin the required coverage to be in force on the date of is Ag €rnent, and Renewal Certificates of Insurance, or such similar evidence, if the overag - .2 e an expiration or renewal date occurring during the Term of this.eement. receipt of any certificate does not constitute agreement by the F C that'the insuranequirements in the Agreement have been fully met or that the insurance policies ind2atied on the certificate are in compliance with all Agreeme The insurance shall provide for 60 days prior wrlttexz: rlotice fo be given to the City in the event coverage is substantially changed, canceled; T :anon- renewed. Any and all deductibles or self insur`edreten ons on refesced insurance coverages shall be borne by the Developer. The Developer shall requirPW _ e ,general d"b'SXactor, d all subcontractors to provide '` the insurance required E V 7.6 Inspection. The° 1ty may caduct such periodic inspections of the construction of the Pr Et aabegen fly provided in the building code of the N . City. The Developer shalot unreasnaly deny the City and its officers, employees, agents and. . � x ste_ endent ontractors the right to inspect, upon request, all :� �� architec rat, engi ng, e onion, construction and other contracts and docum its pertainingfMa, the c of the Project as the City determines is reasMoble and necessary to very the Developer's compliance with the terms of this AgrIement. _ 7.7 -Choice of� °aw. This Agreement shall be deemed to have been fully ; N . executed, madam by the:= parties in, and governed by the laws of the State of Illinois without regard t `tonflicts of laws provisions for all purposes and intents. 7.8 Entire Agreement; Amendment. The parties agree that this Agreement constitutes the entire agreement between the parties and that no other agreements or representations other than those contained in this Agreement have been made by the parties. This Agreement shall be amended only in writing and effective when signed by the authorized agents of the parties. 7.9 Counterparts. This Agreement is executed in multiple counterparts, each of which shall constitute one and the same instrument. 16 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc 7. 10 Severability. In the event any term or provision of this Agreement is held to be unenforceable by a court of competent jurisdiction, the remainder shall continue in full force and effect, to the extent the remainder can be given effect without the invalid provision. 7.11 Representatives Not Personally Liable. No elected or appointed official, agent, employee or representative of the City shall be personally liable to the Developer in the event of any default or breach by any party under , this Agreement, or for any amount which may become due to any party or on an 2% legations under the terms of this Agreement. This provision shall not apply to the opinion to be given by the City Attor ` tY Y• - 7.12 Indemnification. The indemnifications aria covenants; - contained in this Section shall survive termination or expiration of thi sAgre`ement. Wi 7.12.1 Invalidity. Except. the opinion of the CitKttorney as provided for in Section 7.14 of this Aeent, the :City and its governing body members, officers, agents, employees and iidependent contractors shall not be ,;- liable to the Developer for damages or otherwis' din the event that all or any part of the SSA Law, the Special Service Area; _ o any ordinance adopted in connection with the Law, theAe , or this Agreei went, is declared invalid or arf v unconstitutional in whole or iri e final (as -U v°hich all rights of appeal have expired or have been exhaust6 411 j xdgment Hof any court of competent ;3 ,�.r jurisdiction, and by reason theredkeither tlegir is prevented from performing any of the coven ts_.ta -`d agreeme fherein o F. e Developer is prevented from enjoying the right and p Mleges h8Teof. 74 2-21 Damage or Injury, The City and its governing body §' 4W� __ members, officers & - a_ e nployees arld independent contractors shall not be Y da liable for an m ` " or u oh P property P ersons or ro er tY of the Developer or its J rY` officer, Tag _,..,ts, emplo=,.ees, independent contractors or any other persons who mae`abo he Projid or the Project except for matters arising out of the g>•oss negligencaor wilIfUU- 4inisconduct of the City and its governing body embers, officer�gents,#a employees and independent contractors. 7.12.3 personal Liability. All covenants, stipulations, promises, agreements and o igations of the City contained herein shall be deemed to be the covei'zants,sflpulations, promises, agreements and obligations of the City and not 0 , : �i of its governing body members, officers, agents, employees or independe ,, ntractors in their individual capacities. 7.13 Survival. Notwithstanding the expiration or termination or breach of this Agreement by either party, the agreements contained in Sections 7.7, 7.8, 7.9, 7.10, 7.13, and 7.16 and Article VIII of this Agreement shall, except as otherwise expressly set forth herein, survive such expiration or early termination of this Agreement by either party. 7.14 Legal Opinion. As of the effective date of the City's ordinance authorizing the execution of this Agreement, the City Attorney shall provide the 17 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc Developer, Developer's Counsel and the City's Bond Counsel with an opinion in a form mutually agreeable to each of them. If the Special Service Area has not been formed as of the date of the City Attorney's opinion, then the City Attorney shall also issue one or more subsequent opinions, in a form acceptable to Developer's Counsel and the City's Bond Counsel regarding the Special Service Area. 7.15 Term. The term of this Agreement shall commence on the Closing Date and shall terminate upon the retirement of the Bonds, unless earlier terminated pursuant to the provisions of this Agreement. L Y 7.16 Conflict. In the event of any inconsistency ooriflict between the terms of this Agreement and the Bond Ordinance, the terms =_, the 1d Ordinance shall control. ja ARTICLE VIII REPRESENTATIONS, Olt iTHE PARRTIES 8.1 Representations of the City. The Cif): represents and warrants that (i) it has full constitutional and lawful right, pow _: d authority, under current a licable law to execute and delis .._: d perform the{erm and obligations of this pp . __ r Agreement, and the Indenture, lnclu �t out limitaMOn the right, power and authority to issue and sell the Bond (ii) °all -tithe foregoing have been or will be, =�. upon adoption of the ordinances au ' 'tlie =statance of the Bonds, duly and validly authorized and a ' d by al ecessary 'City proceedings, findings and actions, (iii) this Agre ent cons itutes IM legal, valid and binding obligation of the City, enforceable in ccordance Wth its terms, and (iv) it will pay to the Developer, or its designee, all aA nts rece ed from th 0.11Aastee pursuant to each Request For Payment in accorda&- the ate _ , 3 of t� Agreement. - - 8.2 R4gre_ ,entationsof the Developer. The Developer hereby represents _. _, and wawa s it �ha_ . full power to s execute and deliver and perform the terms and obliga o s of this geement all of the foregoing has been duly and validly authoed by all necessary prop edings. This Agreement constitutes the legal, valid an(Fb n' ng obligation o 2 _. , a Developer, enforceable in accordance with its terms. r(Th remainder of this page intentionally left blank.) 18 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc IN WITNESS WHEREOF, the City and the Developer have caused this Agreement to be executed in their respective names and the City has caused its seal to be affixed thereto, and attested as to the date first above written. "CITY" UNITED CITY OF YORKVILLE, ILLINOIS By: T Mayor ft (SEAL) Attest: City Clerk t6 .." W\ Aft "DEVELOPER" CANNONAAL an Illinois imtted liability company CY ' By: The HHarem ies, Inc. Harem I-. 1 -y itle: 1 6-m. J-Z V A— Q - [SIGNATURE PAGE TO DEVELOPMENT AGREEMENT] S: \Client Data\Harlern Irving Development\07005\Documents\07-03-15 Development Agreement SSA V4.doc STATE OF ILLINOIS ) %' )SS COUNTY OF KENDALL ) On this _ day of . 200_, before me appeared , to me personally known, who, being by me duly sworn, did say that he is the Mayor of the UNITED CITY OF YORKVILLE, ILLINOIS, a political subdivision of the State of Illinois, and that the seal affixed to the foregoing instrument is the seal of said City, and said instrument was signed and sealed in behalf of said City by authority of its City Council, and said acknowledged said instrument to be the free act and deed of said City. i IN TESTIMONY WHEREOF, I have hereunto set my hasY affixed my official V seal in the County and State aforesaid, the day and year-,il^st above written. No � ty Public hl (SEAL)` My Commission Expires: ME :�- u x. ' - S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc STATE OF ) )SS COUNTY OF ) On this _ day of , 200_, before me appeared , to me personally known, who, being by me duly sworn, did say that he is the of THE HARLEM IRVING COMPANIES, an Illinois corporation, and a of CANNONBALL LLC, an Illinois limited liability company and that he is authorized to sign the instrument on behalf of said company, and acknowledgd&to me that he executed the within instrument as said company's free act andP`cNed_'ka' IN TESTIMONY WHEREOF, I have hereunto set rry d affixed my official seal in the County and State aforesaid, the day and years ifst abav�ftritten. IVY - Notary PA' l ic (SEAL) ff My Commission Expires: Nil t° z r W . M . g R 't S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc EXHIBIT A 1 1 LEGAL DESCRIPTION OF THE PROPERTY THAT PART OF THE SOUTH EAST 1/4 OF SECTION 19, PART OF THE SOUTH 1/2 OF SECTION 20 AND PART OF THE NORTH WEST 1/4 OF SECTION 29, TOWNSHIP 37 NORTH, RANGE 7 EAST OF THE THIRD PRINCIPAL MERIDIAN DESCRIBED AS FOLLOWS: COMMENCING AT THE SOUTH EAST CORNER OF I�D SOUTH EAST 1/4 SECTION 19; THENCE NORTH ALONG THE EAST LINE O 71S ' D48OUTH EAST 1/4 310.20 FEET; THENCE WESTERLY PERPENDICULAR T EAST LINE 198.0 FEET FOR THE POINT OF BEGINNING; THENCE EASTE - =C? G THE LAST DESCRIBED COURSE 198.0 FEET; THENCE SOUTH AI; G S T BAST LINE 310.20 FEET TO SAID SOUTH EAST CORNER; THENCE SOLIT�i�ALONG TIEWEST LINE OF SAID NORTH WEST 1/4 OF SECTION 29, 429.15 Effi - H O THE CE N' f R OF U.S. ROUTE NO. 34; THENCE EASTERLY ALON AID CENTER T I CI NE, ]VHL H FORMS AN ANGLE OF 95 DEGREES, 41 MIN 25 SECONDS WITH ��E LAST DESCRIBED COURSE, MEASURED CLOCKI TH& HER OM, 2059.30 TO THE CENTER LINE EXTENDED SOUTHERLY OF Cif, DFF ROAD; THENCE NORTHERLY ALONG SAID CUT -OFF ROAD CENTEK LE EXTENDED AND SAID CENTER LINE WHICH FORMS AN ANGLE OF 106 DEGREES, 47 MINUTES, 23 SECONDS WITH THE LAST DESCRIB �GOURSE, MEAS72E CLOCKWISE .s - THEREFROM, 1816.44 FEET TO THE'ORI ST CORDER OF OAK KNOLLS SUBDIVISION; THENCE NORTHERLY AVON `," CIJT -OFF ROAD CENTER LINE WHICH FORMS AN ANGL&OFk_ -180 DEGREE , 26 MI(3TES, 14 SECONDS WITH THE LAST DESCRIBED COURSE; EY SURED LOCKWISE THEREFROM, 746.59 FEET; THENCE NORTHWES RLY ALZG G A LIN _4 WHICH FORMS AN ANGLE OF 86 DEGREES, 39 MINUTES, 00 SECONDS WII` ° -T E CENTER LINE OF CUT -OFF ROAD GOING NORTHEF : W T AST DESCRIBED POINT. MEASURED COUNTER CLOCKWISE THEREFR °HENCE NORTHWESTERLY ALONG A LINE FORMING N ANGL � ° =F 33 DEGREES, 20 MINUTES, 00 SECONDS WITH THE PROLON A I`ID :_.,O WE LA'T__ ESCRIBED COURSE, MEASURED CLOCKWISE THEREFROM, 65.90 € ET; THE NORTHERLY ALONG A LINE WHICH FORMS AN ANGL0OF 38 DEGREES . 44 MI UTES, 00 SECONDS WITH THE PROLONGATION OF THW_E DESCRIBED _ " 9, MEASURED CLOCKWISE THEREFROM, 138.82 FEET; TCE WESTEF ALONG A LINE WHICH FORMS AN ANGLE OF 271 DEGREES; ,- S MINUTESF SECONDS WITH THE LAST DESCRIBED COURSE, MEASURED ``ZJNTER,,CLOCKWISE THEREFROM, 2658.89 FEET TO A POINT ON THE EAST LINEQ : SAID SOUTH EAST 1/4 OF SECTION 12 WHICH IS 147.18 FEET SOUTH OF THE JCJ, 2 H EAST CORNER OF SAID SOUTH EAST 1/4; THENCE WESTERLY ALONG PROLONGATION OF THE LAST DESCRIBED COURSE 580.80 FEET; THENCE WESTERLY ALONG A LINE WHICH FORMS AN ANGLE OF 176 DEGREES, 11 MINUTES, 47 SECONDS WITH THE LAST DESCRIBED COURSE, MEASURED COUNTER CLOCKWISE THEREFROM, 258.97 FEET TO A POINT ON THE NORTH LINE OF SAID SOUTHEAST 1/4 WHICH IS 1826.22 FEET EASTERLY OF THE CENTER OF SAID SECTION 19; THENCE SOUTHEASTERLY ALONG A LINE WHICH FORMS AN ANGLE OF 62 DEGREES, 59 MINUTES, 10 SECONDS WITH THE LAST DESCRIBED COURSE, MEASURED CLOCKWISE THEREFROM, 2411.25 FEET TO THE POINT OF BEGINNING, (EXCEPT THAT PART OF THE NORTHWEST 1/4 OF SECTION 29, TOWNSHIP 37 NORTH, RANGE 7 EAST OF THE THIRD PRINCIPAL S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc MERIDIAN DESCRIBED AS FOLLOWS: COMMENCING AT THE INTERSECTION OF THE CENTERLINE OF U.S. ROUTE NO. 34 AND THE CENTERLINE OF CANNONBALL TRAIL; THENCE NORTH 21 DEGREES, 49 MINUTES, 35 SECONDS EAST ALONG THE CENTERLINE OF CANNONBALL TRAIL, 555.0 FEET FOR THE POINT OF BEGINNING; THENCE NORTH 68 DEGREES, 10 MINUTES, 25 SECONDS WEST, 48.0 FEET, THENCE SOUTH 21 DEGREES, 49 MINUTES, 35 SECONDS WEST, PARALLEL TO SAID CENTERLINE OF CANNONBALL TRAIL, 470.0 FEET; THENCE SOUTH 57 DEGREES, 49 MINUTES, 35 SECONDS WEST, 74.81 FEET TO THE NORTHERLY RIGHT OF WAY OF SAID U.S. ROUTE NO. 34; THENCE EASTERL,ALONG SAID NORTHERLY LINE, 96.06 FEET TO THE CENTERLINE OF CA1N:ON9kLL TRAIL; THENCE NORTH 21 DEGREES, 49 MINUTES, 35 SECOND§_= ST, ALONG SAID CENTERLINE, 502.78 FEET TO THE POINT OF BEGINN =IW A ! ;EXCEPT THAT PART OF THE SOUTH HALF OF SECTION 20, TOWNSHIP37 NOR' _ RANGE 7 EAST OF THE THIRD PRINCIPAL MERIDIAN DESCRIBED AS FsQLLOWS: �C3f IMENCING AT THE SOUTHEAST CORNER OF THE SOUTHEAST-QUARTER OF SECT 19 TOWNSHIP AND RANGE AFORESAID; THENCFf!36UT114ALONG THE WES' LINE OF THE NORTHWEST QUARTER OF SECTION 29TflWNSHIP =AND RANGEIFORESAID, 429.15 FEET TO THE CENTERLINE OF U.S. ROQ N0 34 _THENCE EASTERLY ALONG SAID CENTERLINE, WHICH FORMS AN A9dh OF 61 DEGREES 41 �.' :&`, MINUTES 25 SECONDS WITH THE LAST DESCRIBED'. MEASURED � . CLOCKWISE THEREFROM, 2059.30k_ n- TO THE CERthRLINE EXTENDED SOUTHERLY OF CANNONBALL TRAIL= % GE ,LONG THE CENTERLINE OF SAID CANNONBALL :I�AIL; ICH FORMS AN ANGLE OF 106 DEGREES 47 MINUTES 23 SECONDS � IT�TH ' '. 5T _,' ESCRIBED COURSE, MEASURED CLOCKWISE.3ftREFROM, ' :Si 6.44 FE 'I' TO THE NORTHWEST :_ g t-�. CORNER OF OAK KNOLL 'SUBL VISION; THENCE CONTINUING NORTHERLY ALONG SAID CENTERLINE, WHICH S H FOR AN_ANGLE OF 180 DEGREES 26 MINUTES 14 SECQNIWITH THE LAST DESCRIBED COURSE, MEASURED CLOCKWISE THEREFROM 74�s� F �ET�F�R THE POINT OF BEGINNING; THENCE NORTHWESTERLY ALOILIN i]VIIGIORMS AN ANGLE OF 94 DEGREES 29 MINUTES L,SEGONDS WIT !SAID CENTERLINE, MEASURED CLOCKWISE THEREFROM, 14f10;"EET; THENCE SOUTHERLY ALONG A LINE WHICH FORMS AN A1�IGE OF 85 DEEES 30`�TES 43 SECONDS WITH THE LAST DESCRIBED COURSE CLOCKWISE THEREFROM AND PARALLEL WITH SAID CENTERLINE, 10(:r0 FEET; THENCE EASTERLY ALONG A LINE WHICH FORMS A_ _ GLE OF 9EGREES 29 MINUTES 17 SECONDS WITH THE LAST DESCRIBE] COURSE,.., E ASURED CLOCKWISE THEREFROM, 140.00 FEET TO SAID CENTERLIINE; TIC =ENCE NORTHERLY ALONG SAID CENTERLINE, WHICH FORMS AN ANaLt' 85 DEGREES 30 MINUTES 43 SECONDS WITH THE LAST �R, - 9 DESCRIBED COVjZSE, 100.00 FEET TO THE POINT OF BEGINNING), IN BRISTOL TOWNSHIP, KENDALL COUNTY, ILLINOIS. Legal Description provided by: Smith Engineering Consultants, Inc. 2 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc EXHIBIT B i ) LEGAL DESCRIPTION OF THE SPECIAL SERVICE AREA THAT PART OF THE SOUTHEAST QUARTER OF SECTION 19, PART OF THE SOUTH HALF OF SECTION 20 AND PART OF THE NORTHWEST UARTER OF SECTION 29 TOWNSHIP 37 Q , NORTH, RANGE 7 EAST OF THE THIRD PRINCIPAL MERIDIAN DESCRIBED AS FOLLOWS: BEGINNING AT THE SOUTHEAST CORNER OF THE SOUTHEAST QUARTER OF SAID SECTION 19; THENCE NORTH 01 DEGREES 13 MINUTES 53 SECONDS&- • . ST, ALONG THE 1101, EAST LINE OF SAID SOUTHEAST QUARTER 310.20 FEET; THENCE STEI,Y PERPENDICULAR TO SAID EAST LINE 198.00 FEET; THENCE NOR- % 6 DEGREES 23 MINUTES 58 SECONDS WEST, 862.81 FEET; THENCE NORTH_ 4fi EtEES 51 MINUTES 14 SECONDS EAST, 126.15 FEET; THENCE WESTERLY ALONG < ONTGENTIAL CURVE TO THE RIGHT WITH A RADIUS OF 25.00 FEET AND A CHO G 033(QRTH 86 DEGREES 29 MINUTES 53 SECONDS WEST, AN ARC LET 40.71 FEE�'.HENCE NORTHWESTERLY ALONG A CURVE TO THE RIGH. - TH A RADIUS OF 95Q:00._FEET AND A A CHORD BEARING OF NORTH 30 DEGREES 00 _ ' TES 26,SECONDS WEST, A� ARC LENGTH OF 326.41 FEET; THENCE NORTH 67 DELI TS 35 Nf- , TES 57 SECONDS EAST, 243.73 FEET; THENCE SOUTHEASTERLY ALONG A . ..... 1 AL CURVE TO THE LEFT WITH A RADIUS OF 500.00 FEET AND A CHORD BE SOUTH 31 DEGREES 07 MINUTES 50 SECONDS EAST, AN ARC LENGTH OF 209.70�EE ,, THENCE SOUTH 43 DEGREES 08 MINUTES 45 SECONDS EAS-02 80 FEET; THENC Q TH 46 DEGREES 51 MINUTES 15 SECONDS EAST, 287.40 FEE TEF�,SOUTH 43 DEGREES 08 MINUTES 45 SECONDS EAST, 80.00 FEET; THENCE NORTH 46REES 51 NIINUTES 15 SECONDS EAST, 162.29 FEET; THENCE NORTH�43DEGREES0811UTES A SECONDS WEST, 7.00 FEET; THENCE NORTH 46 DEGRE S - TES 15 ECONDS AST, 60.76 FEET; THENCE NORTHEASTERLY ON G C . %TO THE GHT WITH A RADIUS OF 367.00 FEET AND A CHORD BEARING OF RTH 58 D REES 18 §� , ES 15 SECONDS EAST, AN ARC LENGTH OF 146.68 F = THENCEORTH 69 DE(xEES 45 MINUTES 15 SECONDS EAST, 121.97 FEET; THENCE O Kk CURVE TO THE LEFT WITH A RADIUS OF 433.00 FEET AND A CH F, °QbRTH 37 DEGREES 51 MINUTES 31 SECONDS EAST, ANA ,. - EN. TH OF 48 =Q_ FEET; THENCE NORTHEASTERLY ALONG A CURVE TO - THE RIG T! IUS O 0 FEET AND A CHORD BEARING OF NORTH 51 DEGRED'23 MINUTEST ry- ECOND ` - AST, AN ARC LENGTH OF 39.64 FEET; THENCE • SOU8DEGREES 11 TES Q `SECONDS EAST, 763.20 FEET , THENCE SOOT=BE- Y ALONG s,-.CURVE TO THE RIGHT WITH A RADIUS OF 367.00 FEET AND A CHORG OF SOU 3- 57 DEGREES 07 MINUTES 07 SECONDS EAST, AN ARC LENGTH OF 94 FEET; = NCE SOUTH 31 DEGREES 03 MINUTES 05 SECONDS EAST, 123.11 FEET; #-.. CEi3TH 58 DEGREES 56 MINUTES 55 SECONDS WEST, 7.00 FEET; THENCE SOU ` - RLY ALONG A NONTANGENTIAL CURVE TO THE LEFT WITH A RADIUS OF 440.00 )✓T AND A CHORD BEARING OF SOUTH 42 DEGREES 20 MINUTES 40 SECONDS EAST, A ARC LENGTH OF 173.45 FEET; THENCE NORTH 32 DEGREES 01 MINUTES 21 SECONDS EAST, 80.28 FEET; THENCE SOUTHEASTERLY ALONG A NONTANGENTIAL CURVE TO THE LEFT WITH A RADIUS OF 360.00 FEET AND A CHORD BEARING OF SOUTH 60 DEGREES 42 MINUTES 59 SECONDS EAST, AN ARC LENGTH OF 101.11 FEET; THENCE SOUTH 68 DEGREES 45 MINUTES 32 SECONDS EAST, 784.84 FEET TO THE CENTER LINE OF CANNONBALL TRAIL; THENCE SOUTH 21 DEGREES 40 MINUTES 31 SECONDS WEST, ALONG SAID CENTER LINE, 331.43 FEET; THENCE SOUTH 21 DEGREES 14 MINUTES 17 SECONDS WEST, ALONG SAID CENTER LINE, 1261.58 FEET; THENCE NORTH 68 DEGREES 45 MINUTES 43 SECONDS WEST, 48.00 FEET; THENCE SOUTH 21 DEGREES 14 MINUTES 17 WEST, 470.00 FEET; THENCE SOUTH 57 DEGREES 14 MINUTES 17 SECONDS S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc WEST, 74.81 FEET TO THE NORTH LINE OF U.S. ROUTE 34; THENCE NORTH 85 DEGREES 32 MINUTES 10 SECONDS WEST ALONG SAID NORTH LINE, 1983.32 FEET TO THE WEST LINE OF THE NORTHWEST QUARTER OF SAID SECTION 29; THENCE NORTH 01 DEGREES 14 MINUTES 12 SECONDS WEST ALONG SAID WEST LINE, 378.99 FEET TO THE POINT OF BEGINNING, IN THE UNITED CITY OF YORKVILLE, KENDALL COUNTY, ILLINOIS, AND CONTAINING 143.40 ACRES MORE OR LESS. Legal Description provided by: Smith Engineering Consultants, Inc. - a bi ' f Y k V T - 14 - 1 4 5 2 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc EXHIBIT C 1; CANNONBALL BEECHER ROAD PROJECT COSTS TO BE PAID FROM SSA BOND PROCEEDS Cannonball Beecher Road Project improvements include, but area'- not limited to: (i) land underlying dedicated rights of way for Ul _ City of Yorkville; (ii) land underlying dedicated rights of the Illinois Department of Transportation (IDOT) along Raute'3:4y. (iii) construction of Cannonball Trail road including pas ng, road : 4 striping, road signage, creation of acceleration /deceleration " lanes and curb installation; (iv) construction of B, r Road:' se including paving, road striping, road signage, creation }; acceleration /deceleration lanes, and curb installation; (v_ improvement of Route 34 including repaving the existing rah_ curb installation, construction of accelera -n� deceleration 1 'e , V ia' - road striping, and road signage; (vi) utilitresaannonball Tr ; road including water system, storm dr g �m g , y ai�iage system-,, sanitary Mx system, relocation of existing fire protectiorisyste 'eo of gas service utilities, and electrical lighting se� � such1 s�tieet lighting; (vii) utilities for Beecher R�oa__d include a water system, :, storm drainage system, sa�L7 sys tem, fire p ection system, electrical services suc as street liglit g, and theS installation of a traffic signal at the oe, of RouteA4 and Beecher -Road; (viii) utilities for Route 34 inch; " g Mten -nul lem orm drainage system, sanitary system, fireliy rarifsinstatton of street lighting, the n�stallation of arc signal at the South main entrance one= Ro#eand the enhancement of the existing traffic signal a e mtersectila Cannoxbrail and Route 34; and (ix) assMiated s general cori to fees• design fees, Alta survey fee; geo echnical, landsca ' =desiga land planner fees, architect and structure= es, and civil design fees; and (xi) builder's nsl surance. - Total Eligible Pr oj c Costs $9,851,232 Total Funded Project Costs $ 8,391,522 S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc EXHIBIT D CERTIFICATE OF SUBSTANTIAL COMPLETION The undersigned, CANNONBALL, LLC, an Illinois limited liability company (the "Developer"), pursuant to that certain Development Agreement dated as of . 2006, between the UNITED CITY OF YORKVILLE, Illinois (the "City's and the Developer (the "Agreement"), hereby certifies to the City as follows: 1. That as of the construction of the. - cannonball Beecher Road Project (as that term is defined in the Agreement) .,,,.as been substantially completed in accordance with the Agreement. 2. The work has been performed in accord the instruction Plans (as those terms are defined in the Agreemenj."'' =, $ ,, 3. The Developer is issuing this Certificate of txbstantial Compl6 ion to the City in accordance with the Agreement toedenc tk Developer's satisfaction of all material obligations and covenants wi eectto such Project. 4. The acceptance or the failure of the City 1 in writing to this Certificate within thirty (30) dayf' b "the date of delivery } of this Certificate to the City (which written objection, ifuny, ffMjsae delivery Ao the Developer prior to the end of such thirty (30) days) sallvx'e Qth satisfaction of the Developer's agreementspand covenants to peffiffifthe work and complete the Cannonball Beec e Ro PProject. _ Upon such acceptance byhe City, the Developer may record this Certificate in the office of the Ke d 11 CountyRe or der of D6eds. This Certificate is given without prejudice to any right cf�pe= which exist as of the date hereof or which may subsequently come intb�ing. Terms not otherwise defined herein shall have the meaning a stieil;a teris_in the Agreement. I I E 7 W� � 3 -s S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc IN WITNESS WHEREOF, the undersigned has hereunto set his /her hand this 1 II day of , CANNONBALL LLC, an Illinois limited liability company By: THE HARLEM IRVING COMPANIES BY: Title: I ACCEPTED: UNITED CITY OF YORKVILLE, ILLINOIS By: Name: Title: = y (Insert Notary Fm(s) and Legal D_ iption) s P_ ¢ VN S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc EXHIBIT E CERTIFICATE OF CANNONBALL BEECHER ROAD PROJECT COSTS TO: United City of Yorkville, Illinois Office of Treasurer Yorkville, Illinois Attention: - o- - Re: Terms not otherwise defined herein shall have<<erieaning ascribed to such terms in the Development Agreement dated as of _- y- % , 2006 (the == y`Agre�ement'j, between the City and CANNONBALL LLC, an Illinois limited liability conipanjy (the ;, "Developer'. In connection with said AgreemdM the undersigned hereb states and certifies that:'_. 1. Each item listed on Schedule 1 hereto isareimbursable Cannonball Beecher Road Project cost ands incurred in caiin with the construction of the Cannonball"Beeeher -,Road Proj6d 2. These the Cannonball Beec er fcosts have been paid by the Developer and are pqiiffbursable under the SSAaw, the Bond Ordinance and �3 the Agreement. �J �' AW VI NL 3. Each 3 e m; listed ora:'Schedule 1 I s not previously been paid or reimbursed �frorn one i e d from_tl e Fund or any money derived from any fund established piftsuant'16U.' rid Ordinance, and no part thereof has been�i ch ded in any� er certificate previously filed with the City. 4 There s'izot beenflecf with or served upon the Developer any notice of ,r1y lien, right of °Ten or ata hment upon or claim affecting the right of any person, firm or corQration to receive payment of the amounts stated in this re Est, except tole extent any such lien is being contested in good faith. se` 3 T_ 5. 11 ?vork .fd7which payment or reimbursement is requested has been performe r&: ordance with the Concept Site Plan and the Agreement. f3 -�S 6. If any cost item to be reimbursed under this Certificate is deemed not to constitute a reimbursable Cannonball Beecher Road Project cost within the meaning of the SSA Law, the Developer shall have the right to substitute other eligible Cannonball Beecher Road Project costs for payment hereunder as are eligible under the application statutory authority. 7. The Developer is not in default or breach of any material term or condition of the Agreement beyond the applicable cure period, if any. S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc Dated this - day of By: CANNONBALL LLC, an Illinois limited liability company By: THE HARLEM IRVING COMPANIES Name: Title: Approved for Payment this day of Ul- A UNITED CITY OF YORKVILLE, ILLINOIS 41 -.;-- N P, By: Name: Title: 2 S: \Client Data\Harlem Irving Development\07005\Documents\07-03-15 Development Agreement SSA V4.doc i I SCHEDULEI CANNONBALL BEECHER ROAD PROJECT COSTS + �_ . j__-. VM A A - � S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc EXHIBIT F CONCEPT SITE PLAN E-7 Y '� B® E '1 s _ LEM N ' e i ; � 4 ,��� milli I co OMER I)EVaOPER: PROJECT. _ $ O 4104 'ruw a ue � a CANNONBALL T — a+choo. tu�pY aoeaa - �' a YGRCVaLq uHo�s I $ S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc EXHIBIT G TARGET TRACT LEGAL DESCRIPTION THAT PART OF THE SOUTHWEST Q UARTER OF SECTION 20 AND THE NORTHWEST QUARTER OF SECTION 29, TOWNSHIP 37 NORTH, RANGE 7 EAST OF THE THIRD PRINCIPAL MERIDIAN, DESCRIBED AS FOLLOWS: COMMENCING AT THE SOUTHWEST CORNER OF THE SOUTHWEST QUARTER OF SAID SECTION 20; THENCE NORTH 01 DEGREES 13 MINUTES 53 "`SECONDS WEST ALONG THE WEST LINE OF SAID SOUTHWEST QUARTE20.80 FEET; THENCE NORTH 88 DEGREES 46 MINUTES 07 SECONDS EASTp4gf.811 EET FOR THE POINT OF BEGINNING; THENCE NORTH 70 DEGREES 57 MFG- UTESflSECONDS EAST, 68.07 FEET; THENCE ALONG A CURVE TO THE RIGHT, HAVING= A RADIUS OF 143.00 FEET AN ARC DISTANCE OF 58.66 FEET AND A CHOI 16 EARING OF NORTH 82 DEGREES 42 MINUTES 45 SEC ONDS: ..EAST; THENC -SOUTH 85 Te DEGREES 32 MINUTES 10 SECONDS EAST - 964.10 FEET; THENCEIP SOUTH 04 DEGREES 27 MINUTES 50 SECONDS WEST, S3§ 5 F TO THE SOUTH LINE OF THE SOUTHWEST QUARTER OF SAID SECTION 2(3ND THE NORTH LINE OF THE r NORTHWEST QUARTER OF SAID SECTION 29; THENCE CONTINUING SOUTH 04 DEGREES 27 MINUTES 50 SECONIYS NEST 198. FEE'S; THENCE NORTH 85 DEGREES 32 MINUTES 10 SECOIFlS4ES_T 483.10 FT; THENCE SOUTH 04 _,_.__ DEGREES 27 MINUTES 50 SECONDS_ WES °2$0 00 FEET; THENCE NORTH 85 c =x:8e; DEGREES 32 MINUTES 10 SECONDS WEST 4 0. -FEET; THENCE NORTH 04 � DEGREES 27 MINUTES O CONDS =BAST, 280 0 FEET; THENCE NORTH 85 DEGREES 32 MINU'I jV10 SECONDS 1Y ST, 442:70 FEET; THENCE NORTH 01 DEGREES 14 MINWES 12 SE ONDS WEST, 82.46 FEET; THENCE NORTH 01 DEGREES 13 MINUTES 53 SECONDS WEST; =1.77 FEET TO THE NORTH LINE OF THE NORTHWEST QUARTER ;SAID. SECTION 29 AND THE SOUTH LINE OF THE SOUTHWEST QUARTER- 40W�SMIT "- ECTION 20; THENCE CONTINUING NORTH 01 DEGREES = 1 , MINUTES 53 SECONDS WEST, 304.59 FEET; THENCE ALONG A CURVE T_CQTHE LEFD, HAVING A RADIUS OF 1050.00 FEET AN ARC DISTANCE OF 319.34 EET AND AV- HORD �BEAI7ING OF NORTH 09 DEGREES 56 MINUTES 39 SECONDS WEST TOLE POIi OF BEGINNING, ALL IN THE UNITED CITY OF YOiME KENDALL COUNTY, ILLINOIS. Legal Descrip 6&provided by: SEC Group, Inc.4r i i S: \Client Data \Harlem Irving Development \07005 \Documents \07 -03 -15 Development Agreement SSA V4.doc 1i i PRELBUNARY MUTED OFFERING MEMORANDUM DATED , 2007 s NEW ISSUE BOOK -ENTRY ONLY NOT RATED ° y ° In the opinion of Foley & Lardner LLP, Bond Counsel, based upon an analysis of existing laws, regulations, rulings and court decisions n j a and, assuming among other matters, compliance with certain covenants, interest on the Bonds is excluded from gross income for federal income tax Y b purposes under Section 103 of the Internal Revenue Code of 1986, as amended. In the opinion of Bond Counsel, interest on the Bonds is not a S specific preference item for purposes of the federal individual or corporate alternative minimum taxes, although such interest is included in 0.— adjusted current earnings when calculating corporate alternative minimum taxable income. Interest on the Bonds is not exempt from present State T w of Illinois income taxes. Bond Counsel expresses no opinion regarding any other tax consequences related to the ownership or disposition of, or the accrual or receipt of interest on, the Bonds. See the heading "TAX MATTERS " 0 0 � w y UNITED CITY OF YORKVILLE .: G o Kendall County, Illinois H Special Service Area Number 2006 -113 o Ad Valorem Tag Bonds, Series 2007 - (Cannonball/Beecher Road Project) o Dated: Date of Issuance % Due: March 1, 2028 This Limited Offering Memorandum is being furnished solely for consideration by prospective sophisticated purchasers of the United g A City of Yorkville, Kendall County, Special Service Area Number 2006 -113, Ad Valorem Tax Bonds, Series 2007 (Cannonball/Beecher Road °' Project) (the "Bonds ") with substantial financial resources and the experience and financial expertise to understand and evaluate the high degree of L o b c risk inherent in this investment. Purchase of the Bonds will constitute an investment secured solely by a pledge of the Revenues as defined herein) 8 ° and certain other amounts held in funds established pursuant to the Indenture (as defined herein). The purchase of the Bonds is an investment W E y subject to a high degree of risk, including the risk of non payment of principal and interest. See "RISK FACTORS" herein. ° d o The Bonds are issuable only as fully registered bonds without coupons and, when issued, will be registered in the name of Cede & Co., i~ as nominee of The Depository Trust Company, New Yor New York DTC . Individual purchases will be made in book en form only, in 4 , g P ry (" " ) P hY Y p Q principal amounts of $100,000 or integral multiples of $5,000 in excess thereof. Beneficial Owners of the Bonds will not receive physical c certificates representing their interest in the Bonds purchased. Principal of, premium, if any, and interest (payable on March 1 and September 1 of each year, commencing September 1, 2007) on the Bonds are payable by The Bank of New York Trust Company, N.A., as Trustee, to DTC, which y 5 will remit such principal, premium, if any, and interest to DTC's Participants, who in turn will be responsible for remitting such payments to the Beneficial Owners of the Bonds, as described herein. y 3 The Bonds are subject to optional, mandatory and special mandatory redemption prior to maturity as set forth herein. O U THE BONDS ARE BEING ISSUED PURSUANT TO THE SPECIAL SERVICE AREA TAX LAW OF THE STATE OF ILLINOIS, o AS AMENDED, AND IN THE OPINION OF FOLEY & LARDNER LLP, CHICAGO, ILLINOIS, BOND COUNSEL, THE BONDS WILL 3 .g CONSTITUTE VALID AND LEGALLY BINDING LIMITED OBLIGATIONS OF THE CITY PAYABLE SOLELY AND ONLY FROM THE . REVENUES (AS DEFINED HEREIN) AND AMOUNTS ON DEPOSIT IN CERTAIN OF THE FUNDS ESTABLISHED AND MAINTAINED '= a ° PURSUANT TO THE INDENTURE, AS SET FORTH HEREIN. THE BONDS ARE NOT GENERAL OBLIGATIONS OF THE CITY AND r- v ' NEITHER THE FULL FAITH AND CREDIT NOR THE GENERAL TAXING POWER OF THE CITY, KENDALL COUNTY, THE STATE OF ILLINOIS, OR ANY POLITICAL SUBDIVISION THEREOF IS PLEDGED TO THE PAYMENT OF THE BONDS. NO HOLDER OF ANY ° BOND SHALL HAVE THE RIGHT TO COMPEL THE EXERCISE OF ANY TAXING POWER OF THE CITY (OTHER THAN THE LEVY y N OF THE SPECIAL TAX) FOR PAYMENT OF THE PRINCIPAL AMOUNT OF, PREMIUM, IF ANY, OR INTEREST ON THE SERIES 2005 ° BONDS. o w 5 E .S . .0 o Price — % U U ; ,�f •O w o •'—, The Bonds are offered when, as and if issued, subject to prior sale, withdrawal or modification of the offer without notice, the approving E legal opinion of Foley & Lardner LLP, Chicago, Illinois, Bond Counsel, and certain other conditions. See "TAX MATTERS" herein. Certain legal 9 o matters will be passed upon for the Underwriter by Sonnenschein Nath & Rosenthal LLP, Chicago, Illinois, for the Developer by Polsky & ° 0 ; Associates Ltd., Chicago, Illinois, and or the City b John eth, Es Yorkville, Illinois. It is expected that the Bonds will be available ° g. f tY Y W Y 9, or P f delivery to DTC in New York, New York on or about 2007. 7 � U OA y �O o o The date of this Limited Offering Memorandum is 1 2007. n � y p v � F U Preliminary; subject to change. LD41TED OFFERING MEMORANDUM This Limited Offering Memorandum is being furnished by the United City of Yorkville, Kendall County, Illinois (the "City") to a limited number (35 or less) of sophisticated investors or registered investment companies under the Investment Company Act of 1940 solely for the purpose of each investor's consideration of the purchase of the Bonds described herein, and is not to be used for any other purpose or made available to anyone not directly concerned with the decision regarding such purchase. This Limited Offering Memorandum does not constitute an offer to sell or the solicitation of an offer to buy, nor shall there be any sale of the Bonds by any person, in any jurisdiction in which it is unlawful for such person to make such an offer, solicitation or sale. Interested investors are being provided the opportunity to ask such questions and examine such documents and records as they may desire, and are advised to contact the Underwriter to secure further information concerning the Bonds. No dealer, broker, salesman or other person has been authorized to give any information or to make an representation other than as contained in this Limited Offerin Memorandum in connection y M p g with the limited offering described herein, and, if given or made, such information or representation must not be relied upon as having been authorized. In accordance with, and as part of, its responsibilities to investors under the federal securities laws, as applied to the facts and circumstances of this transaction, the Underwriters have reviewed the information in this Limited Offering Memorandum, but does not guarantee the accuracy or completeness of such information. Neither the delivery of this Limited Offering Memorandum nor the sale of any of the Bonds shall imply that the information herein is correct as of any time subsequent to the date hereof. This Limited Offering Memorandum should be considered in its entirety and no one factor should be considered more or less important than any other by reason of its position in this Limited Offering Memorandum. Where statutes, reports, agreements or other documents are referred to herein, reference should be made to such statutes, reports, agreements or other documents for more complete information regarding the rights and obligations of parties thereto, facts and opinions contained therein and the subject matter thereof. The Bonds have not been registered under the Securities Act of 1933, as amended, in reliance upon exemptions contained in such act. The registration or qualification of the Bonds in accordance with the applicable provisions of securities laws of the states in which the Bonds have been registered or qualified and the exemption from registration or qualification in other states cannot be regarded as a recommendation thereof. Neither these states nor any of their agencies have passed upon the merits of the Bonds or the accuracy or completeness of this Limited Offering Memorandum. Any representation to the contrary may be a criminal offense. THE BONDS HAVE RISK CHARACTERISTICS WHICH REQUIRE CAREFUL ANALYSIS AND CONSIDERATION BEFORE A DECISION TO PURCHASE IS MADE. THE BONDS SHOULD BE PURCHASED BY INVESTORS WHO HAVE ADEQUATE EXPERIENCE TO EVALUATE THE MERITS AND RISKS OF THE BONDS. PROSPECTIVE INVESTORS ARE NOT TO CONSTRUE THE CONTENTS OF THIS LIMITED OFFERING MEMORANDUM OR ANY PRIOR OR SUBSEQUENT COMMUNICATION FROM THE UNDERWRITERS, THEIR AFFILIATES, OFFICERS AND EMPLOYEES OR ANY PROFESSIONAL ASSOCIATED WITH THIS OFFERING AS INVESTMENT OR LEGAL ADVICE. EACH PROSPECTIVE INVESTOR SHOULD CONSULT ITS OWN COUNSEL, ACCOUNTANT AND OTHER ADVISORS AS TO FINANCIAL, LEGAL AND RELATED MATTERS CONCERNING THE INVESTMENT DESCRIBED HEREIN. 14514220 \V -4 UNITED CITY OF YORKVILLE, ILLINOIS MAYOR Arthur F. Prochaska, Jr. CITY ALDERMEN Joseph Besco Jason Leslie Jim Bock Marty Munns Valerie Burd Rose Spears Paul James Dean Wolfer TREASURER William Powell CITY ADMINISTRATOR John Crois DIRECTOR OF PUBLIC WORKS Eric Dhuse FINANCE DIRECTOR Susan Mika CITY CLERK Jacquelyn Milschewski PROFESSIONAL SERVICES BOND COUNSEL FINANCIAL ADVISOR Foley & Lardner LLP Speer Financial, Inc. Chicago, Illinois Chicago, Illinois TRUSTEE The Bank of New York Trust Company, N.A. Chicago, Illinois CITY'S COUNSEL John Justin Wyeth, Esq. Yorkville, Illinois 14514220 \V -4 TABLE OF CONTENTS \ I | IN/m/�u'u`�/�/r�z u//�/EaoEa�/---------------------.---.-------.—.-----' � 7I]E BONDS ................................................................................................................................................. 2 General Description of the Bonds ............................................................................................................. 2 i ^----p-----------------------'-----------'-----------------'~ System .......................................................................................................................... 5 SOURCES AND USES OF FUNDS ..................................................................................... Q � PLAN OF FINANCE .................................................................................................................................... 8 DEBT SERVICE REQUIREMENTS --.----------.--.-----------.-----.----..9 � SECURITY AND SOURCE OF PAYMENT FOR ]]BE BONDS ............................................................... 9 General ...................................................................................................................................................... 9 � Ad Valorem Taxes .................................................................................................................................. lO � Excess Business District Sales Taxes ..................................................................................................... l0 Projected Excess Business District Sales Taxes ..................................................................................... ll Flow Funds ......................................................................................................................................... l3 Covenants City ............................................................................... l6 Tax Covenants _---------_---------.—.-------.----------------l7 Investment Funds ................................................................................................................................ l8 Enforcement of Payment of Ad Valorem Taxes ..................................................................................... lg Representative Property Tax Rates ......................................................................................................... 21 Appraisal ---------.------.-----.------.----.----_-----------..22 Value Lien Ratio ................................................................................................................................. 22 THE ---------------------.—__---------..23 General .................................................................................................................................................... 23 Fees ......................................................................................................................................................... 33 ) Annual and Quarterly Reporting ..----.---_---.---.--.------_------.-----. 24 Payment of Developer [out ---------.--------------------.—'_-------. 24 �ooduuod ��v�uo� � l4 � ^^~.�.. ---_-------------.—.—.---------.-------.-- Revenues ................................................................................................................................................. 24 Assignment ur Sale of Property .--------------.—.—.----------.---------25 8lJNRvLARY PROJECT ................................................................................................................ (]eoeral-------------.----.----------.--.----------.--.-----.—... 26 Site Improvements .-------_--------.---.--------.—.—.-----.-----.--26 Special 8ervicea------.-------------------.------.----------.--.. 26 Zoning ..................................................................................................................................................... ' Construction ............................................................................................................................................ 27 Meubuoival —.-----------.-----------------.--.------.---------... 27 Interior .................................................................................................................................................... 27 IletuilIoline Properties -------------------_—.-------.--------_—.--27 Land Sales ............................................................................................................................................... 20 LeaseTenants .......................................................................................................................................... 28 Small Boutique ]Boolovazd---------.—.------.-------------------. 29 Cuomtnzutioo -------.--------.—.-------.-------.---.------. 29 Property Management —.-----------.---.---.—.--.----.-------_--.---... 29 � Environmental Site Assessment .............................................................................................................. 3O Project Financing --.------------------------.------.--------.—.--30 Site Plan .................................................................................................................................................. 3l TBE —.------------------.---.---------------------.32 THE CITY ................................................................................................................................................... 34 City Government and Services ---------------------.---------------..34 Transportation............................................................................................................ .............................34 YorkvillePublic Library ........................................................................................... ..............................3 5 CommunityLife ......................................................................................................... .............................35 Education................................................................................................................... .............................35 SocioeconomicInformation ....................................................................................... .............................36 Housing..................................................................................................................... ..............................3 7 Income...................................................................................................................... ..............................3 8 Wealth Indicators . ............................... RetailActivity ............................................................................................................ .............................41 THE SPECIAL SERVICE AREA AND AD VALOREM TAX ................................... .............................41 TheAct ...................................................................................................................... .............................41 Establishment of the Special Service Area ................................................................ .............................42 Levy, Abatement and Collection of Ad Valorem Tax ............................................... .............................42 RISKFACTORS ............................................................................................................ .............................43 LimitedSource of Funds ............................................................................................ .............................43 Concentration of Ownership/Lease of Project ........................................................... .............................43 InformationNot Verified ........................................................................................... .............................44 Failureto Develop Project ......................................................................................... .............................44 Riskof Construction .................................................................................................. .............................44 Riskof Occupancy ..................................................................................................... .............................45 Risk of Changes in Market Conditions, Changes in General Economic Conditions and Future Competition................................................................................................................ .............................45 Riskof Natural Disaster ............................................................................................. .............................45 Risk of Anchor Lease Terminations or Discontinued Operations ............................. .............................45 Local, State and Federal Land Use Regulations ........................................................ .............................45 OverlappingIndebtedness .......................................................................................... .............................46 ZoningApprovals ...................................................................................................... .............................46 Permits....................................................................................................................... .............................46 TaxDelinquencies ..................................................................................................... .............................46 Potential Delay and Limitations in Foreclosure Proceedings .................................... .............................47 Bankruptcy................................................................................................................. .............................47 Limitation on Remedies; No Acceleration ................................................................. .............................48 LimitedSecondary Market ........................................................................................ .............................48 Secondary Market and Prices ..................................................................................... .............................48 Lossof Tax Exemption .............................................................................................. .............................48 Risk of Legislative and Judicial Changes 49 UNDERWRITING....................................................................................................... ............................... 49 LIMITEDOFFERING ................................................................................................... .............................49 LEGALOPINIONS ....................................................................................................... .............................49 _ TAX EXEMPTION ........................................................................................................ .............................49 CONTINUINGINFORMATION .................................................................................. .............................51 TheCity ..................................................................................................................... .............................51 TheDeveloper ............................................................................................................ .............................51 FINANCIALADVISOR ................................................................................................ .............................51 LIMITEDOFFERING ................................................................................................... .............................52 NOLITIGATION .......................................................................................................... .............................52 TheCity ..................................................................................................................... .............................52 TheDeveloper ............................................................................................................ .............................52 NORATING ................................................................................................................ ............................... 52 MISCELLANEOUS..................................................................................................... ............................... 53 AUTHORIZATION..................................................................................................... ............................... 54 ii APPENDICES i APPENDIX A - Trust Indenture APPENDIX B - Development Agreement APPENDIX C - Bond Opinion APPENDIX D - - Appraisal i iii $ UNITED CITY OF YORKVII.LLE Kendall County, Illinois Special Service Area Number 2006 -113 Ad Valorem Tax Bonds, Series 2007 (Cannonball/Beecher Road Project) INTRODUCTORY STATEMENT This Limited Offering Memorandum, which includes the cover page and Appendices attached hereto, is provided to furnish information in connection with the issuance and sale by the United City of Yorkville, Kendall County, Illinois (the "City ") of $ * aggregate principal amount of Special Service Area Number 2006 -113, Ad Valorem Tax Bonds, Series 2007 (Cannonball/Beecher Road Project) (the `Bonds "). The Bonds will be issued by the City pursuant to (i) the Special Service Area Tax Law of the State of Illinois 35 ILCS 200/27 -5 et seq. (the "Act "), (ii) Ordinance Number 2006 -_ of the City adopted on , 2007 (the "Bond Ordinance ") providing for the issuance of the Bonds; and (iii) the Indenture dated as of April 1, 2007 (the "Indenture ") between the City and The Bank of New York Trust Company, N.A., as trustee (the "Trustee "). The Bonds will be issued as fully registered bonds without coupons in book -entry only form in denominations of $100,000 or any integral multiple of $5,000 in excess thereof. Capitalized terms used but not defined herein shall have the meaning given such terms in the Indenture. See "APPENDIX A —Trust Indenture." The proceeds of the Bonds will be used by the City to (i) make a deposit to the Reserve Fund for the Bonds in the amount equal to 10% of the principal amount of the Bonds (the "Required Reserve "); (ii) fund certain costs of issuing the Bonds and certain administrative expenses of the City; (iii) pay capitalized interest on the Bonds through September 1, 2009, and (iv) make a deposit of the balance of proceeds of the Bonds to the Project Account of the Improvement Fund. See "THE BONDS." The amount deposited into the Project Account of the Improvement Fund, together with the interest earnings thereon, will be used to finance the cost of the Special Services (as defined herein) to be constructed by Cannonball, LLC, an Illinois limited liability company (the "Developer ") which will benefit the City's Special Service Area Number 2006 -113 ( "SSA "). The SSA is the area created pursuant to the Act within the City consisting of 143.4 acres located at the northwest corner of the intersection of Illinois Route 34 and Cannonball Trail. The Developer proposes to develop a mix of retail stores, restaurants and office space within the SSA with 800,000 square feet of gross leasable area (the "Project "). See "SUMMARY OF THE PROJECT" and "SPECIAL SERVICE AREA AND AD VALOREM TAX." The Bonds will be secured solely by (i) the ad valorem property tax or taxes levied by the City on all taxable property within the SSA to pay for the Special Services (the "Ad Valorem Taxes "), (ii) amounts deposited in the Debt Service Fund from Excess Business District Sales Taxes (as defined below), (iii) amounts held in the Reserve Fund under the Indenture, and (iv) the investment income interest, profits and other income derived from the investment thereof, as more fully described herein. The City intends to abate the Ad Valorem Taxes to the extend of the Excess Business District Sales Taxes deposited in the Debt Service Fund. See "SECURITY AND SOURCE OF PAYMENT FOR THE BONDS" and "SPECIAL SERVICE AREA AND AD VALOREM TAX." Contemporaneously with the issuance of the Bonds, the City will issue its Business District Revenue Bonds, Series 2007 (Storm Water/Water Improvement Project) (the "Business District Revenue Bonds ") in the aggregate principal amount of $ to fund all or a portion of certain municipal improvements in the Kendall Marketplace Business District created by the City pursuant to the Business * Preliminary; subject to change. 14514220 \V -4 District Act (the "Business District ") whose boundaries are coterminous with the SSA. The Business District Bonds are secured by the one -half of one percent (.5 %) Business District sales tax (the "Business ) } District Sales Tax") levied by the City in the Business District on sales by retailers and servicemen operating in the Business District. "Excess Business District Sales Taxes" means (i) while the Business District Revenue Bonds remain outstanding, the Business District Sales Taxes that remain after payment of debt service on the Business District Revenue Bonds, administrative expenses and the debt service reserve requirement relating to the Business District Revenue Bonds, and (ii) after the Business District Sales Bonds are retired and defeased, the Business District Sales Taxes. INVESTORS ARE CAUTIONED THAT THE BONDS ARE BEING MARKE AND SOLD ON THE BASIS OF THE AD VALOREM TAXES AND NOT ON THE BASIS OF THE EXCESS BUSINESS DISTRICT SALES TAXES. NO ATTEMPT IS MADE IN THIS LIMITED OFFERING MEMORANDUM TO ANALYZE THE ADEQUACY OF THE EXCESS BUSINESS DISTRICT SALES TAXES TO BE AVAILABLE FOR DEBT SERVICE ON THE BONDS. ACCORDINGLY, IN DECIDING WHETHER TO INVEST IN THE BONDS, POTENTIAL INVESTORS SHOULD NOT RELY UPON THE AVAILABILITY OF EXCESS BUSINESS DISTRICT SALES TAX. See "SECURITY AND SOURCE OF PAYMENT FOR THE BONDS ". THE BONDS ARE BEING ISSUED PURSUANT TO THE SPECIAL SERVICE AREA TAX LAW OF THE STATE OF ILLINOIS, AS AMENDED, AND IN THE OPINION OF FOLEY & LARDNER LLP, CHICAGO, ILLINOIS, BOND COUNSEL, THE BONDS WILL CONSTITUTE VALID AND LEGALLY BINDING LIMITED OBLIGATIONS OF THE CITY PAYABLE SOLELY AND ONLY FROM THE REVENUES (AS DEFINED HEREIN) AND AMOUNTS ON DEPOSIT IN CERTAIN OF THE FUNDS ESTABLISHED AND MAINTAINED PURSUANT TO THE INDENTURE, AS SET FORTH HEREIN. THE BONDS ARE NOT GENERAL OBLIGATIONS OF THE CITY AND NEITHER THE FULL FAITH AND CREDIT NOR THE GENERAL TAXIING POWER OF THE CITY, KENDALL COUNTY, THE STATE OF ILLINOIS, OR ANY POLITICAL SUBDIVISION THEREOF IS PLEDGED TO THE PAYMENT OF THE BONDS. NO HOLDER OF ANY BOND SHALL HAVE THE RIGHT TO COMPEL THE EXERCISE OF ANY TAXING POWER OF THE CITY (OTHER THAN THE LEVY OF THE SPECIAL TAX) FOR PAYMENT OF THE PRINCIPAL AMOUNT OF, PREMIUM, IF ANY, OR INTEREST ON THE SERIES 2005 BONDS. A copy of any document or agreement referred to herein may be obtained upon request from William Blair & Company, L.L.C. (the "Underwriter"). THE BONDS General Description of the Bonds The Bonds shall be issued in denominations of $100,000 and any integral multiple of $5,000 in excess thereof, shall be dated the date of delivery, and shall bear interest (calculated on the basis of a 360 - day year of twelve 30 -day months) payable on the first day of each March and September of each year beginning September 1, 2007 at the rate per annum set forth on the cover page hereof, and shall mature on March 1, 2028. The principal of, redemption premium, if any, and interest on the Bonds shall be payable in lawful money of the United States of America. Principal of and redemption premium, if any, on the Bonds shall be payable by the Trustee upon presentation and surrender of the Bonds as they become due at the corporate trust office of the Trustee. Interest on the Bonds shall be payable by the Trustee to the Bondholders by check or draft mailed to such Bondholders at their addresses as they appear on the Bond 2 I Register on the Record Date. Principal of, redemption premium, if any, and interest payable to any person holding Bonds in aggregate principal amount of $1,000,000 or more will be paid, upon the written request of any such Bondholder in form and substance satisfactory to the Trustee, by wire transfer of immediately available funds to an account within the United States of America designated by such Bondholder on or before the Record Date. If any principal of, redemption premium, if any, or interest on any Bond is not paid when due (whether at maturity, by acceleration or call for redemption or otherwise), then the overdue installments of principal and, to the extent permitted by law, interest and redemption premium, if any, shall bear interest until paid at the same rate set forth on the cover page hereof. The Depository Trust Company, New York, New York ( "DTC "), will act as securities depository for the Bonds. Principal of, premium, if any, and interest on the Bonds will be paid by the Trustee directly to DTC, which will remit such principal, premium, if any, and interest to DTC's Participants, who, in turn will be responsible for remitting such payments to the Beneficial Owners of the Bonds. See "THE BONDS — Book -Entry-Only System." Redemption Mandatory Sinking Fund Redemption. The Trustee shall redeem Bonds on March 1 in the years and in the principal amounts and at a price of 100% of the principal amount of the Bonds to be redeemed plus interest accrued to the redemption date, as follows: Year Maturity Amount *Maturity On or before the thirtieth (30th) day prior to each such sinking fund redemption date, the Trustee shall proceed to call the principal amount of the Bonds indicated above for redemption on the next March 1, and give notice of such call. At its option, to be exercised by delivery of an Officer's Certificate of the City to the Trustee not more than 360 days nor less than 65 days preceding the applicable sinking fund redemption date, the City may (a) deliver to the Trustee for cancellation, Bonds of the applicable maturity date subject to redemption pursuant to the terms of the mandatory sinking fund in an aggregate principal amount desired or (b) receive credit in respect of its sinking fund redemption obligation for any Bonds of the applicable maturity date subject to redemption pursuant to the terms of the mandatory sinking fund provided in the Indenture, which prior to said date have been canceled (otherwise than through the operation of the sinking fund redemption schedule) by the Trustee and not theretofore applied as a credit against such sinking fund redemption obligation. Each Initial Bond of the applicable maturity date so delivered or previously redeemed shall be credited by the Trustee at the principal amount thereof against the obligation of the City on such sinking fund redemption date, and the principal amount of Bonds to be redeemed by operation of such sinking fund redemption schedule on such date shall be accordingly reduced; and any excess over the principal amount of Bonds to be redeemed by operation of the sinking Rind redemption schedule on any sinking fund redemption date shall be credited as specified in a 3 certificate of the City or, in the absence of such certificate against the next scheduled sinking fund redemption. Optional Redemption. The Bonds are subject to redemption by the City on or after March 1, 2017, in whole or in part at any time from any moneys that may be available for such purpose, upon payment of the following redemption prices (expressed as a percentage of principal amount of Bonds to be redeemed) plus interest accrued to the redemption date: Redemption Dates Redemption Prices March 1, 2017 through February 28, 2018 102% March 1, 2018 through February 28, 2019 101% March 1, 2019 and thereafter 100% I Special Mandatory Redemption. To the extent that moneys are transferred from the Improvement Fund to the Debt Service Fund for purposes of redeeming the Bonds, the Bonds are subject to special mandatory redemption in part in Authorized Denominations on the next scheduled Interest Payment Date at a redemption price equal to 100% of the aggregate principal amount of the Bonds to be redeemed plus accrued interest to the redemption date. Selection of Bonds for Redemption. If less than all of the Bonds are called for redemption, they shall be redeemed in inverse order of maturity and in inverse order of sinking fund installments within any maturity (provided, however, that if an Event of Default has occurred and is continuing any Bonds called for redemption shall be redeemed in proportion by maturity and within maturities in inverse order of sinking fund installments), subject to selection by the Trustee as provided below. The portion of any Bond to be redeemed shall be an Authorized Denomination or any multiple thereof and in selecting Bonds for redemption, each Bond shall be considered as representing that number of Bonds which is obtained by dividing the principal amount of such Bond by the minimum Authorized Denomination. If a portion of a Bond shall be called for redemption, a new Bond in principal amount equal to the unredeemed portion thereof shall be issued to the Bondholder upon the surrender thereof. If for any reason the principal amount of Bonds called for redemption would result in a redemption of Bonds less than the Authorized Denomination, the Trustee, to the extent possible within the principal amount of Bonds to be redeemed, is hereby authorized to adjust the selection of Bonds for such purpose in order to minimize any such redemption. Notwithstanding the foregoing, the Securities Depository for Book Entry Bonds shall select the Bonds for redemption within particular maturities according to its stated procedures. Notice of Redemption. (a) When Bonds (or portions thereof) are to be optionally redeemed, the City shall give or cause to be given notice of the redemption of the Bonds to the Trustee no later than forty-five (45) days prior to the redemption date or such shorter time as may be acceptable to the Trustee. The notice may state (1) that it is conditioned upon the deposit of moneys, in an amount equal to the amount necessary to effect the redemption, with the Trustee no later than the date that is five (5) Business Days prior to the redemption date or (2) that the City retains the right to rescind such notice on or prior to the scheduled redemption date (in either case, a "Conditional Redemption "), and such notice and optional redemption shall be of no effect if such moneys are not so deposited or if the notice is rescinded as described in paragraph (d) below. The Trustee, at the expense of the City, shall send notice of any redemption, identifying the Bonds or portions thereof to be redeemed, the redemption date and the method and place of payment and the information required by paragraph (b), by first class mail to each holder of a Bond called for redemption to the holder's address listed on the Bond Register. Such notice shall be sent by the Trustee by first class mail between thirty (30) and sixty (60) days prior to the scheduled redemption date. With respect to Book Entry Bonds, if the Trustee sends notice of redemption to the Securities Depository pursuant to the Letter of Representations, the Trustee shall not be required to give the notice set forth in the immediately preceding sentence. If notice is given as stated in this 4 I paragraph (a), failure of any Bondholder to receive such notice, or any defect in the notice, .shall not affect the redemption or the validity of the proceedings for the redemption of the Bonds. (b) In addition to the foregoing, the redemption notice shall contain with respect to each Bond being redeemed, (1) the CUSIP number, (2) the date of issue, (3) the interest rate, (4) the maturity date, and (5) any other descriptive information determined by the Trustee to be needed to identify the Bonds. If a redemption is a Conditional Redemption, the notice shall so state. The Trustee shall also send each notice of redemption at least thirty (30) days before the redemption date to (A) any Rating Service then rating the Bonds to be redeemed; (B) all of the registered clearing agencies known to the Trustee to be in the business of holding substantial amounts of bonds of a type similar to the Bonds; and (C) one or more national information services that disseminate notices of redemption of bonds such as the Bonds such services to be identified by the Trustee. Each redemption notice shall also be sent to participants of the Securities Depository and to Beneficial Owners as provided in the Indenture. I (c) On or before the date fixed for redemption, subject to the provisions of paragraph (a) above and (d) below, moneys shall be deposited with the Trustee to pay the principal of, redemption premium, if any, and interest accrued to the redemption date on the Bonds called for redemption. Upon the deposit of such moneys, unless the City has given notice of rescission as described in paragraph (d) below, the Bonds shall cease to bear interest on the redemption date and shall no longer be entitled to the benefits of this Indenture (other than for payment and transfer and exchange) and shall no longer be considered Outstanding. (d) Any Conditional Redemption may be rescinded in whole or in part at any time prior to the fifth Business Day prior to the redemption date if the City delivers an Officer's Certificate to the Trustee instructing the Trustee to rescind the redemption notice. The Trustee shall give prompt notice of such rescission to the affected Bondholders. Any Bonds subject to Conditional Redemption where redemption has been rescinded shall remain Outstanding, and the rescission shall not constitute an Event of Default. Further, in the case of a Conditional Redemption, the failure of the City to make funds available in part or in whole on or before the redemption date shall not constitute an Event of Default, and the Trustee shall give Immediate Notice to the .Securities Depository or the affected Bondholders that the redemption did not occur and that the Bonds called for redemption and not so paid remain Outstanding. Purchase of Bonds. The Trustee, upon the written request of the City shall purchase Bonds as specified by the City in the open market at a price not exceeding a price set by the City. Such purchase of Bonds shall be made with funds provided by the City and not with any portion of the Trust Estate or any Defeasance Obligations. Upon purchase by the Trustee, such Bonds shall be treated as delivered for cancellation. Nothing in this Indenture shall prevent the City from purchasing Bonds on the open market without the involvement of the Trustee and delivering such Bonds to the Trustee for cancellation. Bonds purchased which are subject to the mandatory sinking fund redemption shall be credited against future mandatory sinking fund redemption payments. The principal amount of Bonds to be redeemed by optional redemption under this Indenture may be reduced by the principal amount of Bonds purchased by the City and delivered to the Trustee for cancellation at least forty-five (45) days prior to the redemption date. Book -Entry -Only System THE INFORMATION IN THIS SECTION HAS BEEN FURNISHED BY THE DEPOSITORY TRUST COMPANY. NO REPRESENTATION IS MADE BY THE UNDERWRITERS, THE CITY OR THE DEVELOPER AS TO THE COMPLETENESS OR ACCURACY OF SUCH INFORMATION OR AS TO THE ABSENCE OF MATERIAL ADVERSE CHANGES IN SUCH INFORMATION SUBSEQUENT TO THE DATE HEREOF. NO ATTEMPT HAS BEEN MADE BY THE 5 UNDERWRITERS, THE CITY OR THE DEVELOPER TO DETERMINE WHETHER DTC IS OR WILL BE FINANCIALLY OR OTHERWISE CAPABLE OF FULFILLING ITS OBLIGATIONS. )' NEITHER THE CITY NOR THE TRUSTEE WILL HAVE ANY RESPONSIBILITY OR OBLIGATION TO DTC PARTICIPANTS, INDIRECT PARTICIPANTS OR THE PERSONS FOR WHICH THEY ACT AS NOMINEES WITH RESPECT TO THE BONDS, OR FOR ANY PRINCIPAL, PREMIUM, IF ANY, OR INTEREST PAYMENT THEREOF. The Depository Trust Company ( "DTC "), New York, New York, will act as securities depository for the Bonds. The Bonds will be issued as fully- registered securities registered in the name of Cede & Co. (DTC's partnership nominee) or such other name as may be requested by an authorized representative of DTC. One fully- registered Bond certificate will be issued for the Bonds, in the aggregate principal amount of such issue, and will be deposited with DTC. DTC, the world's largest depository, is a limited - purpose trust company organized under the New York Banking Law, a "banking organization" within the meaning of the New York Banking Law, a member of the Federal Reserve System, a "clearing corporation" within the meaning of the New York Uniform Commercial Code, and a "clearing agency" registered pursuant to the provisions of Section 17A of the Securities Exchange Act of 1934. DTC holds and provides asset servicing for over 2.2 million issues of U.S. and non -U.S. equity issues, corporate and municipal debt issues, and money market instruments from over 100 countries that DTC's participants ( "Direct Participants ") deposit with DTC. DTC also facilitates the post -trade settlement among Direct Participants of sales and other securities transactions in deposited securities, through electronic computerized book -entry transfers and pledges between Direct Participants' accounts. This eliminates the need for physical movement of securities certificates. Direct Participants include both U.S. and non -U.S. securities brokers and dealers, banks, trust companies, clearing corporations, and certain other organizations. DTC is a wholly -owned subsidiary of The Depository Trust & Clearing Corporation ( "DTCC "). DTCC, in turn, is owned by a I number of Direct Participants of DTC and Members of the National Securities Clearing Corporation, Fixed Income Clearing Corporation, and Emerging Markets Clearing Corporation, (NSCC, FICC, and EMCC, also subsidiaries of DTCC), as well as by the New York Stock Exchange, Inc., the American Stock Exchange LLC, and the National Association of Securities Dealers, Inc. Access to the DTC system is also available to others such as both U.S. and non -U.S. securities brokers and dealers, banks, trust companies, and clearing corporations that clear through or maintain a custodial relationship with a Direct Participant, either directly or indirectly ( "Indirect Participants "). DTC has Standard & Poor's highest rating: AAA. The DTC Rules applicable to its Participants are on file with the Securities and Exchange Commission. More information about DTC can be found at www.dtcc.com. Purchases of Bonds under the DTC system must be made by or through Direct Participants, which will receive a credit for the Bonds on DTC's records. The ownership interest of each actual purchaser of each Bond (`Beneficial Owner ") is in turn to be recorded on the Direct and Indirect Participants' records. Beneficial Owners will not receive written confirmation from DTC of their- purchase. Beneficial Owners are, however, expected to receive written confirmations providing details of the transaction, as well as periodic statements of their holdings, from the Direct or Indirect Participant through which the Beneficial Owner entered into the transaction. Transfers of ownership interests in the Bonds are to be accomplished by entries made on the books of Direct and Indirect Participants acting on behalf of Beneficial Owners. Beneficial Owners will not receive certificates representing their ownership interests in Bonds, except in the event that use of the book -entry system for the Bonds is discontinued. To facilitate subsequent transfers, all Bonds deposited by Direct Participants with DTC are registered in the name of DTC's partnership nominee, Cede & Co., or such other name as may be requested by an authorized representative of DTC. The deposit of Bonds with DTC and their registration in the name of Cede & Co. or such other DTC nominee do not effect any change in beneficial ownership. 6 DTC has no knowledge of the actual Beneficial Owners of the Bonds; DTC's records reflect only the identity of the Direct Participants to whose accounts such Bonds are credited, which may or may not be the Beneficial Owners. The Direct and Indirect Participants will remain responsible for keeping account of their holdings on behalf of their customers. Conveyance of notices and other communications by DTC to Direct Participants, by Direct Participants to Indirect Participants, and by Direct Participants and Indirect Participants to Beneficial Owners will be governed by arrangements among them, subject to any statutory or regulatory requirements as may be in effect from time to time. Beneficial Owners of Bonds may wish to take certain steps to augment transmission to them of notices of significant events with respect to the Bonds, such as redemptions, tenders, defaults, and proposed amendments to the Bond documents. For example, Beneficial Owners of Bonds may wish to ascertain that the nominee holding the Bonds for their benefit has agreed to obtain and transmit notices to Beneficial Owners. In the alternative, Beneficial Owners may wish to provide their names and addresses to the registrar and request that copies of notices be provided directly to them. Redemption notices shall be sent to DTC. If less than all of the Bonds within issue are being redeemed, DTC's practice is to determine by lot the amount of the interest of each Direct Participant in such issue to be redeemed. Neither DTC nor Cede & Co. (nor any other DTC nominee) will consent or vote with respect to Bonds unless authorized by a Direct Participant in accordance with DTC's Procedures. Under its usual procedures, DTC mails an Omnibus Proxy to City as soon as possible after the record date. The Omnibus Proxy assigns Cede & Co.'s consenting or voting rights to those Direct Participants to whose accounts the Bonds are credited on the record date (identified in a listing attached to the Omnibus Proxy). Redemption proceeds, distributions, and dividend payments on the Bonds will be made to Cede & Co., or such other nominee as may be requested by an authorized representative of DTC. DTC's practice is to credit Direct Participants' accounts upon DTC's receipt of funds and corresponding detailed information from City or Trustee, on payable date in accordance with their respective holdings shown on DTC's records. Payments by Participants to Beneficial Owners will be governed by standing instructions and customary practices, as is the case with securities held for the accounts of customers in bearer form or registered in "street name," and will be the responsibility of such Participant and not of DTC nor its nominee, Trustee, or City, subject to any statutory or regulatory requirements as may be in effect from time to time. Payment of redemption proceeds, distributions, and dividend payments to Cede & Co. (or such other nominee as may be requested by an authorized representative of DTC) is the responsibility of the City or the Trustee, disbursement of such payments to Direct Participants will be the responsibility of DTC, and disbursement of such payments to Beneficial Owners will be the responsibility of Direct and Indirect Participants. DTC may discontinue providing its services as securities depository with respect to the Bonds at any time by giving reasonable notice to the City or the Trustee. Under such circumstances, in the event that a successor securities depository is not obtained, Bond certificates are required to be printed and delivered. The City may decide to discontinue use of the system of book -entry transfers through DTC (or a successor securities depository). In that event, Bond certificates will be printed and delivered. The information in this section concerning DTC and DTC's book -entry system has been obtained from sources that the City believes to be reliable, but City takes no responsibility for the accuracy thereof. 7 The City may decide to discontinue use of the system of book -entry transfers through DTC (or a successor securities depository). In that event, the Bond certificates will be printed and delivered. THE TRUSTEE, THE DEVELOPER AND THE CITY WILL NOT HAVE ANY i RESPONSIBILITY OR OBLIGATION TO ANY PARTICIPANT, ANY PERSON CLA 41NG A BENEFICIAL OWNERSHIP INTEREST IN ANY BOND UNDER OR THROUGH DTC OR ANY PARTICIPANT, OR ANY OTHER PERSON THAT IS NOT SHOWN ON THE REGISTRATION BOOKS OF THE TRUSTEE AS BEING A BONDOWNER, WITH RESPECT TO THE ACCURACY OF ANY RECORDS MAINTAINED BY DTC OR ANY PARTICIPANT, THE PAYMENT BY DTC OR ANY PARTICIPANT OF ANY AMOUNT IN RESPECT OF PRINCIPAL OF OR PREMIUM, IF ANY, OR INTEREST ON ANY BOND, ANY NOTICE THAT IS REQUIRED TO BE GIVEN TO BONDOWNERS UNDER THE BOND ORDINANCE (EXCEPT IN CONNECTION WITH CERTAIN NOTICES OF DEFAULT AND REDEMPTION AND ANY NOTICES REQUIRED IN CONNECTION WITH CONTINUING DISCLOSURE REQUIREMENTS, IF APPLICABLE), THE SELECTION BY DTC OR ANY PARTICIPANT OF ANY PERSON TO RECEIVE PAYMENT IN THE EVENT OF A PARTIAL REDEMPTION OF THE BONDS, OR ANY CONSENT GIVEN OR OTHER ACTION TAKEN BY DTC OR ITS NOMINEE AS THE REGISTERED OWNER OF THE BONDS. ESTIMATED SOURCES AND USES OF FUNDS Sources: Bond Proceeds Interest Earnings Total Uses: Special Services Capitalized Interest Required Reserve Administrative Expense Fund Costs of Issuance Total ( ' ) Interest earnings are calculated assuming earnings of 3% on the Reserve Fund and 1% on the Improvement Fund. PLAN OF FINANCE The proceeds of the Bonds will be used by the City to (i) make a deposit to the Reserve Fund for the Bonds in the amount of the Required Reserve; (ii) fund capitalized interest on the Bonds through September 1, 2009, (iii) fund certain costs of issuing the Bonds; and (iv) make a deposit of the balance of the proceeds of the Bonds to the Improvement Fund. The amount deposited into the Improvement Fund, together with the interest earnings thereon, will be used to finance the cost of constructing the Special Services. See "SUMMARY OF THE PROJECT— Special Services." 8 DEBT SERVICE REQUIREMENTS The following table sets forth the debt service schedule for the Bonds based on the maturity and interest rate set forth on the cover of this Limited Offering Memorandum, assuming no redemptions other than mandatory sinking fund redemptions are made: Debt Service Requirements Bond Year Ending Principal Interest Annual 2007 2008 2008 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 SECURITY AND SOURCE OF PAYMENT FOR THE BONDS General The Bonds and the interest thereon are limited obligations of the City secured and payable solely from the Revenues. "Revenues" include (i) the Ad Valorem Taxes as and when received by the City, (ii) Excess Business District Sales Tax, (iii) any other funds of the City deposited in the Debt Service Fund, and (iv) investment income with respect to any moneys held by the Trustee in the funds created pursuant to the Indenture. The term "Revenues" does not include any moneys or investments or investment income in the Rebate Fund. 9 Ad Valorem Taxes 11 Pursuant to the Bond Ordinance there has been levied an Ad Valorem Tax upon all taxable real property within the SSA sufficient to pay and discharge the principal of the Bonds at maturity or j mandatory sinking fund redemption dates and to pay interest on the Bonds for each year. The Clerk of the City has been directed to file a certified copy of the Bond Ordinance, and an accurate map of the SSA, with the County Clerk of the County. The Ad Valorem Tax shall be divided among all taxable real property within the SSA. On February 2 of each year, the Trustee shall determine the amounts on deposit in the Debt j Service Fund on such February 2, after application on each Accounting Date of moneys under the Indenture (the "Deposit "). On or before February _ of each year, the Trustee will provide notification containing the amount of the Deposit to the City and request that the City abate, no later than February 28 of each year, the Ad Valorem Taxes for the current year in an amount equal to the Deposit. By proper proceedings, the City shall direct the abatement of such Ad Valorem Taxes as evidenced by the notification provided by the Trustee. The City shall take all actions which shall be necessary to provide for the levy, extension, collection and application of the taxes levied by the Bond Ordinance, including enforcement of such taxes by institution of foreclosure procedures as provided by law. Excess Business District Sales Taxes I , The Business District Act, 65 ILCS 5/11- 74.3 -1 et seq. (the "Business District "), permits an Illinois municipality to create and maintain business districts to provide opportunities for development or redevelopment and to attract sound and stable commercial development. In carrying out a business district development or redevelopment plan, the corporate authorities of a municipality has the power, among other things, to borrow funds as it may be deemed necessary for the purpose of business district development and redevelopment, and issue such obligation or revenue bonds as it deems necessary, such to applicable statutory limitations. The corporate authorities of a municipality that has established a business district under the Business District Act may, by ordinance or resolution, impose a Business District Retailers' Occupation Tax upon all persons engaged in the business of selling tangible personal property, other than an item of tangible personal property titled or registered with an agency of this State's government, at retail in the business district at a rate not to exceed 1% of the gross receipts from the sales made in the course of such business, to be imposed only in 0.25% increments. If a Business District Retailers' Occupation Tax has been imposed, a Business District Service Occupation Tax shall also be imposed upon all persons engaged, in the business district, in the business of making sales of service, who, as an incident to making those sales of service, transfer tangible personal property within the business district, either in the form of tangible personal property or in the form of real estate as an incident to a sale of service. The tax shall be imposed at the same rate as the Business District Retailers' Occupation Tax and shall not exceed 1% of the selling price of tangible personal property so transferred within the business district, to be imposed only in 0.25% increments. The Business District Retailers' Occupation Tax and the Business District Service Occupation Tax may not be imposed on food for human consumption that is to be consumed off the premises where it 10 is sold (other than alcoholic beverages, soft drinks, and food that has been prepared for immediate consumption), prescription and nonprescription medicines, drugs, medical appliances, modifications to a motor vehicle for the purpose of rendering it usable by a disabled person, and insulin, urine testing materials, syringes, and needles used by diabetics, for human use. On , the City created the Kendall Marketplace Business District (the "Business District ") pursuant to the Business District Act. The boundaries of the Business District are coterminous with the SSA. On , 2007, the City issued its Business District Revenue Bonds to fund all or a portion of certain municipal improvements in the Business Distict. The Business District Revenue Bonds are secured by the one -half of one percent (.5 %) Business District sales tax (the "Business District Sales Tax ") levied by the City in the Business District on sales by retailers and servicemen operating in the Business District. Projected Excess Business District Sales Taxes The information set forth under the column entitled "Projected Business District Sales Taxes" in the following table is based upon the Estimate of Revenues (the "Report") prepared by Ehlers & Associates, Inc., Chicago, Illinois, a copy of which is available upon request from the Underwriter. THE REPORT DOES NOT PROVIDE ANY CONCLUSIONS AS TO THE ADEQUACY OF THE EXCESS BUSINESS DISTRICT SALES TAX TO PAY THE PRINCIPAL OF OR INTEREST ON THE BONDS. i I 11 Projected Excess Business District Sales Taxes Available for Bonds Projected Projected Projected Business Excess Business Revenue Bond Business District District Sales Year Year District Revenue Bond Administrative Taxes Available Ending 12/1 Ending 3/1 Sales Tax Debt Service Expenses (2) For Bonds 2006 2008 2007 2009 2008 2010 2009 2011 2010 2012 2011 2013 2012 2014 2013 2015 2014 2016 2015 2017 2016 2018 2017 2019 2018 2020 2019 2021 2020 2022 2021 2023 2022 2024 2023 2025 2024 2026 2025 2027 2026 2028 (1) Based on the projections as provided to the Developer by Ehlers & Associates, Inc. showing projected Business District Sales Taxes. (2) As required pursuant to the Indenture and the indenture for the Business District Revenue Bonds. INVESTORS ARE CAUTIONED THAT THE BONDS ARE BEING MARKE AND SOLD ON THE BASIS OF THE AD VALOREM TAXES AND NOT ON THE BASIS OF THE EXCESS BUSINESS DISTRICT SALES TAX. NO ATTEMPT IS MADE IN THIS LIMITED OFFERING MEMORANDUM TO ANALYZE THE AVAILABILITY OR ADEQUACY OF THE EXCESS BUSINESS DISTRICT SALES TAX TO BE AVAILABLE FOR DEBT SERVICE ON THE BONDS. ACCORDINGLY, IN DECIDING WHETHER TO INVEST IN THE BONDS, POTENTIAL INVESTORS SHOULD NOT RELY UPON THE AVAILABILITY OF EXCESS BUSINESS DISTRICT SALES TAX. Flow of Funds The Trustee will establish the following funds and accounts under the Indenture: Improvement Fund, consisting of a Project Account and an Issuance Expense Account; Debt Service Fund, including a Capitalized Interest Account; Reserve Fund; Administrative Expense Fund; Special Redemption Fund; and Rebate Fund. Until applied as provided in the Indenture and except where moneys have been deposited with or paid to the Trustee pursuant to an instrument restricting the application of such moneys to particular Bonds, the moneys and investments held in all Funds (other than amounts required to be on 12 deposit in the Rebate Fund) established under the Indenture and the proceeds of any remedies exercised under Article VII of the Indenture shall be held in trust pursuant to the terms of the Indenture for the equal and proportionate benefit of the holders of all Outstanding Bonds. Bond Proceeds. The proceeds of the sale of the Bonds shall be delivered to the Trustee who shall deposit $ of such proceeds in the Issuance Expense Account, $ representing capitalized interest in the Capitalized Interest Account of the Debt Service Fund, an amount equal to the Required Reserve in the Reserve Fund, $ in the Administrative Expense Fund, and the balance of such proceeds in the Project Account. Improvement Fund. Payments from the Improvement Fund shall be made by the Trustee as follows: (a) Payments from the Improvement Fund shall be made only upon receipt by the Trustee of a requisition executed by the City in the form of Request for Payment set forth as an appendix to the Indenture. (b) Upon the later of six months from the Issue Date or the payment of all Issuance Costs (as evidenced by a certificate of Issuer delivered to the Trustee), any moneys remaining in the Issuance Expense Account shall be transferred to the Project Account. (c) Upon completion of the Special Services (as evidenced by a certificate of the City delivered to the Trustee), any moneys remaining in the Improvement Fund shall be transferred to the Debt Service Fund to redeem Bonds pursuant to the Indenture, unless the City directs that such moneys be deposited into the Reserve Fund, or applied to any other use, accompanied in either case by an opinion of Bond Counsel to the effect that such application will not adversely affect any applicable exemption from federal income taxation of the interest on the Bonds. (d) To the extent an Event of Default due to the nonpayment of principal or interest on the Bonds shall have occurred and be continuing and no other moneys are available under the Indenture to cure such Event of Default, moneys on deposit in the Improvement Fund shall be applied by the Trustee in accordance with Article VII of the Indenture. Debt Service Fund. (a) The Trustee shall deposit into the Debt Service Fund (1) all Revenues, and (2) all other amounts required or permitted hereunder to be deposited in the Debt Service Fund. (b) Moneys on deposit in the Debt Service Fund shall be set aside and applied on each Accounting Date as follows in the following order of priority: (i) To the payment, when due on the next two succeeding Interest Payment Dates of interest, on all Outstanding Bonds, including any accrued interest due in connection with redemptions of Bonds; (ii) To the payment, when due on the next succeeding March 1 of the principal of or redemption premium on the Bonds then payable at maturity or upon redemption; (iii) To the payments of any deficiencies in the Reserve Fund in accordance with the requirements of the Indenture, including for reimbursement to the provider of any credit facility deposited in the Reserve Fund; 13 (iv) To the Administrative Expense Fund, an amount equal to the difference, if any, between the Administrative Expense Fund Requirement and the amount then on deposit in the Administrative Expense Fund; a (v) to the abatement of Ad Valorem Taxes pursuant to the Indenture; and (vi) To the Special Redemption Fund, any surplus remaining on March 2 of each year after application to the uses set forth in (i) -(v) above. Reserve Fund. (a) The Trustee initially shall deposit in the Reserve Fund an amount equal to the Required Reserve on the Bonds from the proceeds of the Bonds. The amount of any withdrawal for the purpose of described in paragraph (b)(i) below shall be restored by the City from available Revenues in the Debt Service Fund after satisfying the requirements of (b)(i) through (iii) under the caption " —Flow of Funds —Debt Service Fund" above. In addition, if the fair market value of the investments in the Reserve Fund is less than the Required Reserve on any valuation date, the difference between such Required Reserve and the value of the Reserve Fund shall be restored by the City but solely from the first available surplus Revenues in the Debt Service Fund. , (b) Moneys on deposit in the Reserve Fund shall be applied as follows: (i) On the date of each required payment from the Debt Service Fund, moneys in the Reserve Fund shall be applied to cure any deficiency in the Debt Service Fund with respect to payments of principal of and interest on the Bonds when due and payable; (ii) Upon delivery of an Officer's Certificate of the City delivered to the Trustee, any amount in the Reserve Fund in excess of the Required Reserve on any valuation date shall be transferred to the Debt Service Fund. (c) The City shall be permitted to substitute a letter of credit, surety bond or other credit enhancement (each, a "credit facility ") for funds on deposit in the Reserve Fund, provided that: (i) the credit facility (including any replacement credit facility) is issued by a bank, trust company, national banking association or insurance company whose unsecured long term debt obligations (in the case of a bank, trust company or national banking association) or whose claims paying abilities (in the case of an insurance company) are rated by a Rating Service, at the time the credit facility is issued and at the time of each extension or renewal thereof, in one of the two highest rating categories maintained by such Rating Service at the time of substitution; (ii) the issuer of the credit facility does not receive as security for any reimbursement obligation in respect of the credit facility any lien, security interest or other similar right or interest in any property within the Trust Estate which is superior to the rights of the Trustee in respect of such property; (iii) the credit facility (including any replacement credit facility, if provided by a different issuer) has an initial term of not less than three (3) years and any extension, renewal or replacement (if provided by the same issuer) thereof has a term of not less than one year; (iv) the Trustee is authorized and has the duty and right to draw on the credit facility to satisfy the purposes for which the Reserve Fund was established; and 14 (v) The Trustee shall receive an opinion of Counsel to the effect that all of the requirements set' forth above have been satisfied and an opinion of Bond Counsel to the effect that the substitution of the credit facility will not, in and of itself, adversely affect the tax- exempt status of the Bonds. Upon such substitution, funds on deposit in the Reserve Fund which, when added to the face amount of the credit facility, exceed the Required Reserve on all Outstanding Bonds shall be applied as provided in paragraph (b)(ii) above. Thereafter, the credit facility shall be considered a part of the Reserve Fund and the amount available thereunder shall be included in any calculation of the amount required to be retained in the Reserve Fund; provided that, (A) if the sum of the amount available under the credit facility and the amount of moneys on deposit in the Reserve Fund exceeds the amount required to be on deposit pursuant to paragraph (a) above, the City shall be permitted to (i) cause the amount available under the credit facility to be reduced by an amount equal to such excess, or (ii) direct that the excess moneys be applied as permitted under paragraph (b)(ii) above, and (B) if the credit facility is not extended, renewed or replaced at least three (3) months prior to its scheduled expiration or termination date, the Trustee shall, not later than five days prior to such date, draw on the credit facility for the full amount thereof. (d) If there are cash and Eligible Investments on deposit in the Reserve Fund in addition to a credit facility, such cash and Eligible Investments will be drawn on prior to any draws on such credit facility. Rebate Fund. The City has covenanted to calculate and pay directly to the government of the United States of America all amounts due for payment of "arbitrage rebate" under Section 148(f) of the Code with respect to the Bonds. Accordingly, no amounts are expected to be deposited in the Rebate Fund. The City may deposit with the Trustee or direct the Trustee to deposit in the Rebate Fund amounts held in any Fund hereunder for any or all Bonds (which direction shall specify the procedures for collection and payment of amounts due in respect of arbitrage rebate) if (a) required under to Section 148(f) of the Code, or (b) the City determines that the funding of the Rebate Fund prior to the due date of any payment to the United States of America is desirable and appropriate. The Rebate Fund is a trust fund, but amounts therein do not constitute part of the Trust Estate. Amounts on deposit in the Rebate Fund may be used solely to make payments to the United States of America under Section 148 of the Code and to pay costs related to the calculation of the amounts due. Upon satisfaction of the City's covenants described above, any amounts remaining in the Rebate Fund shall be applied as described under the caption " —Flow of Funds— Special Redemption Fund" below. Administrative Expense Fund. The Administrative Expense Fund shall be used to pay Administrative Expenses. Moneys on deposit in the Administrative Expense Fund shall be applied to the payment of any Administrative Expenses requested by the City to be paid. All amounts in the Administrative Expense Fund in excess of the Administrative Expense Fund Requirement shall be transferred to, and deposited in, the Debt Service Fund. Special Redemption Fund. (a) When the amount on deposit in the Special Redemption Fund on any date equals $5,000, such amount shall be used to optionally redeem the Bonds as described under "THE BONDS— Redemption— Optional Redemption" above. On each such date, the Trustee shall withdraw from the Special Redemption Fund and pay to the owners of the Bonds the amounts to redeem the Bonds. (b) Any amounts contained in the Special Redemption Fund on the final maturity date of the Bonds shall be used to pay outstanding debt service on the Bonds. 15 (c) Moneys on deposit in the Special Redemption Fund shall be invested at a yield equal to or less than the yield on the Bonds or in obligations the interest on which is exempt from inclusion in the gross income of the holder under Section 103 of the Code to the extent such moneys are on deposit or are expected to be on deposit in the Special Redemption Fund for greater than thirteen (13) months. Covenants of the City In addition to any other covenants and agreements of the City contained in the Indenture or the Bond Ordinance, the City further covenants and agrees with the Bondholders and the Trustee as follows: (a) To take all actions, if any which shall be necessary, in order further to provide for the levy, extension, collection and application of the Ad Valorem Tax including enforcement of the Ad Valorem Tax by institution of foreclosure proceedings as provided by law; (b) To not take any action which would adversely affect the levy, extension, collection and application of the Ad Valorem Tax levied pursuant to the Bond Ordinance and Indenture, except to abate the Ad Valorem Tax to the extent permitted by the Indenture; (c) To comply with all requirements of the Act, the Bond Ordinance and other applicable present and future laws concerning the levy extension and collection of the Ad Valorem Tax levied pursuant to the Bond Ordinance and Indenture, in each case so that the City shall be able to pay the principal of and interest on the Bonds as they come due and replenish the Reserve Fund to the Required Reserve and it will take all actions necessary to assure the timely collection of the Ad Valorem Tax, including without limitation, the enforcement of any delinquent Ad Valorem Tax by providing Kendall County with such information as is deemed necessary to enable the County to include any property subject to delinquent Ad Valorem Tax in the County Collector's annual tax sale and in the event the tax lien is forfeited at such tax sale, by the commencement and maintenance of an action to foreclose the lien of any delinquent Ad Valorem Tax, all in the manner provided by law; (d) To not encumber, pledge or place any charge or lien upon any of the Ad Valorem Tax or other amounts pledged to the Bonds superior to, or on a parity with, or junior to, the pledge and lien created in the Indenture for the benefit of the Bonds, except as permitted by, or specifically set forth in, the Indenture; (e) To take all actions which are necessary to be taken (and avoid any actions which it is necessary to avoid being taken) so that interest on the Bonds will not be or become included in gross income for federal income tax purposes under existing law; (f) To keep, or cause the Trustee to keep, proper books of record and accounts, separate from all other records and accounts of the City, in which complete and correct entries will be made of all transactions relating to the deposits to and expenditure of amounts disbursed from the Funds and Accounts created under the Indenture and the Ad Valorem Tax; (g) To take all actions which are necessary to be taken to enforce the City's rights under the Development Agreement; (h) To make the Bond Register available at reasonable times and under reasonable regulations established by the Bond Registrar, to be inspected and copied by or delivered to the City, the Trustee, the holders of 25% or more in principal amount of the Bonds then Outstanding, or a designated representative thereof; 16 (i) To furnish to the Trustee, the Original Purchaser and the Beneficial Owner of $500,000 or more in Bonds who so requests, within ten (10) days of receipt by the City, a copy of each annual audit of the City, the schedule of tenants and lease expiration dates for each tenant's lease provided to the City by the Developer, any publicly available information received from the Illinois Department of Revenue of the Business District Sales Taxes, and any abatement ordinance adopted by the Corporate Authorities abating any of the Ad Valorem Taxes; and (j) To provide or cause the Trustee to provide to the Original Purchaser and to the Beneficial Owner of $500,000 or more in Bonds who so requests, copies of any reports (including quarterly construction progress reports) or disclosure which the Developer provides to the City or the Trustee pursuant to the terms of the Development Agreement. Tax Covenants (a) The City covenants that it will neither make nor direct the Trustee to make any investment or other use of the proceeds of the Bonds that would cause such Bonds to be "arbitrage bonds" as that term is defined in Section 148(a) of the Code, and that it will comply with the requirements of the Code throughout the term of such Bonds. The Trustee covenants that in those instances where it exercises discretion over the investment of funds, it shall not knowingly make any investment inconsistent with the foregoing covenants. (b) The City covenants that it (i) will take, or use its best efforts to require to be taken, all actions that may be required of the City for the interest on the Bonds to be and remain not included in gross income for federal income tax purposes and (ii) will not take or authorize to be taken any actions within its control that would adversely affect that status under the provisions of the Code. (c) The City further covenants as follows with respect to the requirements of Section 148(f) of the Code, relating to the rebate of "excess arbitrage profits" (the "Rebate Requirement ") to the United States: (i) Unless an applicable exception to the Rebate Requirement is available to the City, the City will meet the Rebate Requirement. (ii) Relating to applicable exceptions, the City shall make such elections under the Code as it shall deem reasonable and in the best interests of the City. If such election may result in a "penalty in lieu of rebate" as provided in the Code, and such penalty is incurred (the "Penalty "), then the City shall pay such Penalty. (iii) The City shall, not less frequently than annually, cause to be transferred to the Rebate Fund the amount determined to be the accrued liability under the Rebate Requirement or Penalty. The City shall cause to be paid to the United States, without further order or direction from the Legislative Authority, from time to time as required, amounts sufficient to meet the Rebate Requirement or to pay the Penalty. (iv) Interest earnings in the Debt Service Fund and the Reserve Fund are hereby authorized to be transferred, without further order or direction from the Legislative Authority, from time to time as required, to the Rebate Fund for the purposes herein provided; and proceeds of the Bonds, investment earnings or amounts on deposit in any of the other funds and accounts created hereunder and any other funds of the City are also hereby authorized to be used to meet the Rebate Requirement or to pay the Penalty, but only if necessary after application of investment earnings as aforesaid and only as appropriated by the Legislative Authority. 17 Investment of Funds Moneys on deposit in the Funds established under the Indenture shall be invested and reinvested by the Trustee as follows: (a) All moneys on deposit in Funds shall be invested in Eligible Investments which shall mature, or be subject to repurchase, withdrawal without penalty or redemption at the option of the holder on or before the dates on which the amounts invested are reasonably expected to be needed for the purposes hereof. (b) All purchases or sales of Eligible Investments shall be made at the direction of the City (given in writing or orally, confirmed in writing). If the City elects to give the Trustee oral investment instructions and the Trustee in its discretion elects to act upon such oral investment instructions, the Trustee's understanding of such oral investment instructions shall be deemed controlling. The Trustee shall not be liable for any losses, costs or expenses arising directly or indirectly from the Trustee's reliance upon and compliance with such oral investment instructions notwithstanding such oral investment instructions conflict or are inconsistent with a subsequent written investment instruction. The Trustee may conclusively rely upon such instructions as to both the suitability and legality of the directed investments. The Trustee may make any and all such investments and such investments through its own investment department or that of its affiliates or subsidiaries, and may charge its ordinary and customary fees for such trades, including cash sweep account fees. (c) (1) Any securities or investments held by the Trustee may be transferred by the Trustee, if required in writing by the City, from any of the Funds or accounts mentioned in Article IV to any other Fund or account mentioned in Article IV at the then current market value thereof without having to be sold and purchased or repurchased; provided, however, that after any such transfer or transfers, the investments in each such Fund or account shall be in accordance with the provisions as stated in this Indenture; and (2) whenever any other transfer or payment is required to be made from any particular Fund, such transfer or payment shall be made from such combination of maturing principal, redemption premiums, liquidation proceeds and withdrawals of principal as the Trustee deems appropriate for such purpose. (d) Neither the City nor the Trustee shall be accountable for any depreciation in the value of Eligible Investments or for any losses incurred upon any authorized disposition thereof. (e) Subject to the foregoing, the Trustee is expressly authorized to invest moneys in two or more Funds in a single investment, provided that a portion of the investment allocable to each such Fund, and all payments received with respect to such allocable portion, shall be applied in accordance with the applicable provisions governing such Fund hereunder. (f) Prior to the completion of the Special Services, investment income on amounts on deposit in the Reserve Fund, the Debt Service Fund and the Administrative Expense Fund shall be transferred to the Improvement Fund to the extent that no deficiency will exist in the Reserve Fund or the Debt Service Fund after such transfer or shall be applied to such other purpose or purposes as directed by the City with an opinion of Bond Counsel addressed to the Trustee to the effect that such application will not cause interest on the Bonds to be includable in gross income for federal income tax purposes. After completion of the Special Services, investment income on amounts on deposit in the Reserve Fund shall be transferred to the Debt Service Fund to the extent that no deficiency will exist in the Reserve Fund after such transfer. In all other situations, earnings from investment shall remain in the respective Fund where earned. 18 (g) Although the City recognizes that it may obtain a broker confirmation or written statement containing comparable information at no additional cost, the City hereby agrees that confirmations of permitted investments are not required to be issued by the Trustee for each month in which a monthly statement is rendered.. No statement need be rendered for any fund or account if no activity occurred in such fund or account during such month. The Trustee shall determine the market value of the assets in each of the Funds established hereunder annually on a date not earlier than three days prior to December of each year. As soon as practicable after each such valuation date, the Trustee shall furnish to the City a report of the status of each Fund as of such date. The Trustee shall also advise the City at such time of the amount then available in the Debt Service Fund as a credit against the City's obligation to levy and collect the Ad Valorem Taxes for deposit to the Debt Service Fund prior to the next valuation date. In computing the value of assets in any Fund, investments shall be valued at the fair market value thereof and shall include .accrued but unpaid interest on each investment, and all investments (valued as aforesaid) and accrued interest thereon shall be deemed a part of such Funds. All Eligible Investments that mature within six (6) months of any valuation date or are payable on demand shall be valued at par plus any accrued and unpaid interest. Upon the request of the City, the Trustee shall also provide the City with monthly or other periodic statements showing amounts deposited into and withdrawn from each Fund, the investments made with amounts in each Fund and the investment income received from such investments. Enforcement of Payment of Ad Valorem Taxes The Kendall County Clerk intends to incorporate the Ad Valorem Tax into the regular ad valorem property tax bill of property owners in the SSA. In Illinois, general ad valorem property taxes are levied in one year and become payable during the following year. At the end of each collection year, the Kendall County Treasurer applies to the Circuit Court of Kendall County, for a judgment for all unpaid general ad valorem property taxes. The Circuit Court of Kendall County order resulting from that application for judgment provides for a sale of all property with unpaid general ad valorem property taxes. A public sale is held, at which time successful bidders pay the unpaid general ad valorem property taxes plus penalties. The annual tax sale is usually held during November of any given year in Kendall County. Unpaid general ad valorem property taxes accrue penalties at the rate of 1 -1/2% per month from their due date until the date of sale. Taxpayers can redeem their property by paying the purchaser of the delinquent taxes on the property at the general tax sale the amount paid at the sale, plus a penalty. If redemption does not occur within two and one half years, the purchaser of the property at the tax sale can receive a deed to the property which has been sold for delinquent taxes. Any delinquent Ad Valorem Tax for any given year would be included in this general tax sale. Alternatively, as indicated above, a municipality may seek enforcement of unpaid Ad Valorem Tax through foreclosure proceedings by seeking adjudication of the existence of a lien and a finding of a failure to pay Ad Valorem Tax when due. Upon making such a finding, a court having jurisdiction would enter a foreclosure decree authorizing the sale of the property subject to the lien of the Ad Valorem Tax. If a delinquency in the payment of the Ad Valorem Tax occurs, the City is authorized by the Act to order institution of an action pursuant to Article 9 of the Illinois Municipal Code (65 ILCS 5/9 1 1, et seq.) to foreclose any lien therefor securing the Ad Valorem Tax. In such action the real property subject to the lien of the Ad Valorem Tax may be sold at a judicial foreclosure sale. The ability of the City to foreclose the lien of delinquent unpaid Ad Valorem Tax may be limited in certain instances and may require prior consent of the property owner in the event that the property is owned by any receivership of the Federal Deposit Insurance Corporation (the "FDIC "). See "RISK FACTORS — Bankruptcy" and "RISK FACTORS —Tax Delinquencies." 19 Such judicial foreclosure proceedings are not mandatory under the Act. However, in the Indenture the City has covenanted with the holders of the Bonds to take all actions, all in the manner T ip provided by law, if any, which shall be necessary to provide for the levy and extension, collection and application of the Ad Valorem Tax, and to assure the timely collection of Ad Valorem Tax, by providing the County with such information as is deemed necessary to enable the County to include any property subject to delinquent Ad Valorem Tax in the County Collector's annual tax sale and in the event the tax lien is forfeited at such tax sale, by the commencement and maintenance of an action to foreclose the lien of any delinquent Ad Valorem Tax, all in the manner provided by law. For a description of this covenant, as well as other events of default and remedies under the Indenture, see "APPENDIX A —Trust Indenture." No assurances can be given that a judicial foreclosure action, once commenced, will be completed or that it will be completed in a timely manner. See "RISK FACTORS— Potential Delay and Limitation in Foreclosure Proceedings" below. Article 9 of the Illinois Municipal Code provides that the municipality or its assignee may file a complaint to foreclose a special service area tax lien in the same manner that foreclosures are permitted by law in case of delinquent general taxes. The "law in case of delinquent general taxes" to which the Illinois Municipal Code refers is the Illinois Revenue Code. Under such foreclosure proceedings, the court adjudicates the existence of a default in the payment obligation and authorizes a foreclosure sale; the sale is conducted and the proceeds distributed according to the respective priorities; the successful bidder is given a certificate of sale; and, if the redemption period expires without a redemption of the special service area taxes, the certificate of sale may be converted to a deed. Although the municipality holds the lien for the local improvement and is therefore the proper party to commence foreclosure procedures, bondholders with bonds secured by special service area taxes may compel the municipality to perform its duty and use all lawful means, including foreclosure, to collect the taxes out of which the bondholders are to be paid. Special service area taxes create a lien that is superior to other liens and encumbrances, and when general property taxes and Ad Valorem Tax are both delinquent, the proceeds of any foreclosure action, if insufficient to pay each in full, are divided between them on a pro rata basis. If special service area taxes are not paid in full at a foreclosure sale, and the lien amounts are bid in at such foreclosure sale, then unless the special service area taxes are then redeemed through payment of the amount of the special service area taxes plus interest, the certificate of sale can be converted into a deed to the property only after expiration of the applicable redemption period. The Illinois Constitution prescribes certain minimum redemption periods for unpaid taxes on property, including special service area taxes, but the Illinois General Assembly may create longer redemption periods. No assurances can be given that the real property subject to sale or foreclosure and sale will be sold or, if sold, that the proceeds of sale will be sufficient to pay any delinquent installment of special service area taxes. Neither the Act nor Article 9 of the Illinois Municipal Code requires the City to purchase or otherwise acquire any lot or parcel of property offered for sale or subject to foreclosure if there is no other purchaser at such sale. Article 9 of the Illinois Municipal Code does specify that the special service area taxes will have the same lien priority in the case of delinquency as the priority of the lien of ad valorem property taxes. If the Reserve Fund is depleted and delinquencies in the payment of Ad Valorem Tax exist, there could be a default or delay in payments to the Bondowners pending prosecution of foreclosure proceedings and receipt by the City of foreclosure sale proceeds, if any. The amounts of the Maximum Ad Valorem Tax are sufficient to pay the amounts required by the Indenture to be paid on the Bonds (except with respect to a Mandatory Prepayment); however, there are no assurances that the taxes levied will always be collected in their entirety. 20 Representative Property Tax Rates The following tables show the representative property tax rates for the City from 2001 through 2005 and the amount of tax extensions and collections for the levy year 1999 through 2005. Representative Tax Rates Per $100 Equalized Assessed Valuation Representative Tax Rates(1) (Per $100 EAV) Levy Year 2001 2002 2003 2004 2005 The City: Corporate $ 0.2205 $ 0.1990 $ 0.1012 $ 0.0239 $ 0.0120 MRF 0.0481 0.0480 0.0612 0.0796 0.0617 Police Protection 0.0750 0.0713 0.0750 0.0750 0.0750 Police Pension 0.1302 0.1083 0.1028 0.0973 0.0819 Garbage 0.1211 0.1151 0.1228 0.1332 0.1220 Audit 0.0119 0.0113 0.0098 0.0062 0.0077 Liability Insurance 0.0520 0.0613 0.0562 0.0525 0.0390 Social Security 0.0970 0.0982 0.1000 0.1069 0.1048 Social Cross Guard 0.0035 0.0034 0.0047 0.0042 0.0062 Unemployment Insurance 0.0093 0.0089 0.0058 0.0038 0.0033 Library 0.1500 0.1426 0.1500 0.1500 0.1500 MW - Library 0.0032 - - - - Social Security - Library 0.0068 - - - - Total City Rates (2) $ 0.9286 $ 0.8674 $ 0.7895 $ 0.7326 $ 0.6636 Kendall County 0.7433 0.6920 0.6481 0.6194 0.6156 Kendall County Forest Preserve 0.0243 0.0219 0:0403 0.0369 0.0335 Bristol Township 0.4436 0.4253 0.3886 0.3800 0.3500 Bristol - Kendall Fire District 0.4450 0.4231 0.4011 0.5940 0.5468 Yorkville- Bristol Sanitary District 0.0711 0.0631 0.0547 0.0486 0.0385 Unit School District Number 115 4.7168 4.4780 4.2383 4.0829 4.3156 Community College District Number 0.4239 0.4043 0.4105 0.4104 0.3968 518 Total Tax Rates (3) $ 7.7966 $ 7.3751 $ 6.9711 $ 6.9048 $ 6.9604 Notes: (1) Source: Kendall County Clerk. (2) Statutory tax rate limits for the City are as follows: Corporate ($0.3300); Police Protection ($0.0750); Garbage ($0.2000); School Crossing Guard ($0.0200); and Library (0.1500). (3) Representative tax rates for other government units are from Bristol Township tax code 005. 21 Tax Extensions and Collections(1) (Excludes Road and Bridge Levy) Levy Col Taxes Taxes Collected(3) Year Year Extended(2) Amount Percent i 1999 2000 1,083,917 1,087,444 100.33% j 2000 2001 1,142,869 1,144,706 100.16% 2001 2002 1,255,485 1,251,975 99.72% ! 2002 2003 1,429,114 1,424,626 99.69% 2003 2004 1,589,368 1,587,197 99.86% 2004 2005 1,388,670 1,386,431 99.84% J 2005 2006 2,027,918 1,565,055 77.18 %(4) Notes: (1) Source: Kendall County Treasurer. (2) Tax extensions have been adjusted for abatements. (3) Total collections include back taxes, taxpayer refunds, interest, etc. (4) At December 21, 2060. The City has no control over the amount of additional debt payable from taxes or assessments on all or a portion of the property within the SSA, that may be issued in the future by other governmental entities or districts. Nothing prevents the owners of land within the SSA from consenting to the issuance of additional debt by other public agencies which would be secured by taxes or assessments on the same property subject to the Ad Valorem Tax. To the extent such indebtedness is payable from assessments, and other Ad Valorem Taxes levied pursuant to the Act or other taxes, such assessments, Ad Valorem Taxes and other taxes may have a lien on the property within the SSA in addition to and on a parity with the lien of the Ad Valorem Tax. Accordingly, the liens on the property within the SSA could increase without any corresponding increase in the value of the property within the SSA and thereby reduce the ratio that exists at the time the Bonds are issued between the value of the property and the debt secured by the taxes and assessments thereon. The imposition of such additional indebtedness could also reduce the willingness and ability of the property owners within the SSA to pay the Ad Valorem Tax when due. See "RISK FACTORS — Overlapping Indebtedness." Moreover, in the event of a delinquency in the payment of a Ad Valorem Tax, no assurance can be given that the proceeds of any foreclosure sale would be sufficient to pay the delinquent Ad Valorem Tax and any other delinquent Ad Valorem Taxes, assessments or taxes. Appraisal A market value appraisal of the Project was performed by Holcer & Company Inc. (the "Appraiser ") as of November 1, 2006. It is the opinion of the Appraiser that the prospective market value of the Project to a single purchaser is $29,135,000 subject to the satisfactory completion of the requisite off and on -site improvements. Value to Lien Ratio The following table sets forth the appraised value -to -lien ratio with respect to the Project, based on $ aggregate principal amount of the Bonds: 22 Appraised Value of Project ........................:.................. ............................... $29.135,000 BondsOutstanding ........................................................ ............................... $ Value -to -Lien Ratio ...................................................... ............................... to I This value -to -lien ratio is based on the Appraisal. No assurance can be given that the foregoing ratio can or will be maintained during the period of time the Bonds are outstanding both because property values could drop and because other public entities, over which the City has no control, could issue additional indebtedness secured by a lien on a parity with the lien securing payment of the Ad Valorem Taxes or payable through the levy or imposition of a tax on a parity with the Ad Valorem Taxes. See APPENDIX D - Appraisal. THE DEVELOPMENT AGREEMENT Set forth below is a description of certain of the terms of Development Agreement between the City and the Developer. Such description of any such terms does not purport to be comprehensive or definitive and is qualified in its entirety by reference to the complete form of the Development Agreement included as APPENDIX B to this Limited Offering Memorandum. Capitalized terms that are used but not defined in this section "THE DEVELOPMENT AGREEMENT" have the meanings set forth in the Development Agreement included as APPENDIX B to this Limited Offering Memorandum. General The Developer is required to commence construction of the Project within 120 days of the later to occur of (a) Developer obtaining all necessary permits and Governmental Approvals; or (b) 6 months after execution of the Development Agreement, and is obligated to substantially complete construction of the following approximate square feet of retail, restaurant and commercial space comprising the Project as follows: November, 2007 90,000 square feet of anchor space August, 2008 475,000 square feet (including approximately 280,000 square feet of anchor space) October, 2008 45,000 square feet March, 2009 160,000 square feet October, 2009 30,000 square feet The Project is to be constructed in accordance with the terms of the Development Agreement and the Concept Site Plan included as part of the Development Agreement. The Developer may enter into or cause to be entered into one or more construction contracts to complete the Project. Fees Other than customary tap fees, no fee or charge of any description including, without limitation, building permits, plan review, inspection fees, or other regulatory fees or charges, will be imposed on the Developer or on the development and use of the Property unless, as of the date of the Development Agreement, such fee or charge is in existence and being collected by the City on a uniform basis from all owners, users, and petitioners of property within the City. The City will not increase the amount of any fee or utility fees, application fees, or user fees during the term of the Development Agreement unless such increases are (i) made generally applicable to all owners and users of property within the City and 23 (ii) reasonably related to increased costs incurred by the City in providing the services for which such fee is assessed. ) Annual and Quarterly Reporting The Developer agrees to deliver quarterly construction progress reports to the Trustee and the Underwriter. The Developer will also deliver to the Trustee and the Underwriter annual schedules of tenants and lease expiration dates for the Project. Payment of Developer Costs The City agrees to pay the Developer for the verified costs of the Special Services in the amount set forth in the Development Agreement. Subject to the terms of the Bond Ordinances, the Development Agreement and the Indenture, the City agrees to issue the Bonds and to pay the Developer net proceeds in an estimated amount equal to $8,391,522 (unless otherwise agreed to by the Developer) for verified costs of the Special Services as provided the Development Agreement. Nothing in the Development Agreement will obligate the City to issue Bonds to pay the Developer for any Special Services cost that does not qualify for payment under the Business District Act. The Developer will, at the City's request, provide itemized construction loan draws, invoices, or receipts or, in the case of the acquisition of land, evidence that the Developer has acquired fee title to such land and evidence of the total acquisition price of such land, reasonably requested by the City to confirm that any such cost is so incurred and does so qualify. Bonds and Ad Valorem Taxes The Bonds will be secured by a pledge of the Ad Valorem Taxes. The Indenture provides for the j segregation and deposit of the Ad Valorem Taxes. The Ad Valorem Taxes will be applied to the retirement of the Bonds in accordance with the Bond Ordinance and the Indenture. The City agrees that to the extent there are revenues from the Business District that are not needed to pay annual debt service on the Business District Revenue Bonds, the City shall annually apply all such excess revenues to the abatement of the Ad Valorem Taxes in accordance with the indenture for Business District Revenue Bonds. Revenues The City agrees to cause its Director of Finance or other financial officer to maintain the funds required by the Bond Ordinance and Indenture including such further accounts or sub - accounts as are required in the Development Agreement, by the Development Agreement or as the Director of Finance of the City may deem appropriate in connection with the administration of the fund pursuant to the Development Agreement. Subject to the requirements of the Act, the City will promptly upon receipt thereof deposit all Revenue in the fund or in such other accounts as required under the Bond Ordinances and Indenture. The City and the Developer agree to cooperate and take all reasonable actions necessary to cause the Special Taxes to be paid into the funds and accounts as provided in the Bond Ordinance, including the City's enforcement and collection of all such payments through all reasonable and ordinary legal means of enforcement. 24 � Assignment or Sale of Property All or any part of the Property or any interest in the Development Agreement may be sold, transferred, encumbered, leased, or otherwise disposed of at any time, and the rights of the Developer or any successors in interest under the Development Agreement may be assigned at any time before, during or after redevelopment of the Project, whereupon the parry disposing of its interest in the Property or assigning its interest under the Development Agreement will be released from further obligation under the Development Agreement (although any such Property so disposed of or to which such interest pertains will remain subject to the terms and conditions of the Development Agreement), provided that until substantial completion of the Project, the rights, duties and obligations of the Developer under the Development Agreement cannot be assigned in whole or in part without the prior written approval of the City, which approval will not be unreasonably withheld, conditioned or delayed upon a reasonable demonstration by the Developer of the proposed transferee's or assignee's experience and financial capability to undertake and complete such portions of the Project and perform the Developer's obligations under the Development Agreement, all in accordance with the Development Agreement. Notwithstanding anything above to the contrary, no prior consent will be required in connection with: (a) the right of the Developer to encumber or collaterally assign its interest in the Property or any portion thereof to secure loans, advances or extensions of credit to finance or from time to time refinance all or any part of the Project costs, or the right of the holder of any such encumbrance or transferee of any such collateral assignment (or trustee or agent on its behalf) to transfer such interest by foreclosure or transfer in lieu of foreclosure under such encumbrance or collateral assignment; (b) the right of Developer to assign the Developer's rights, duties and obligations under the Development Agreement to certain related parties; provided that in each such event (i) the Developer will remain liable for the substantial completion of the Project and will be released from such liability hereunder only upon substantial completion of the Project and (ii) the Developer provides to the City 30 days' advance written notice of the proposed assignment or transfer; or (c) the right of Developer to transfer a portion of the Property (the "Target Tract ") to Target Corporation, a Minnesota corporation ( "Target "). Notwithstanding anything to the contrary contained in the Development Agreement, the City agrees that Target, its successors and assigns, as purchaser and owner of the Target Tract, shall not be liable for the performance of Developer's obligations under the Development Agreement, including without limitation, the obligation to complete any site work improvements, posting financial security, or incurring any costs pursuant to the Development Agreement. Upon Developer's completion of its obligations under the Development Agreement with respect to the Project, the City agrees to promptly execute at no charge to Target, a recordable Termination and Release of the Development Agreement for the Target Tract from these obligations under the Development Agreement. Notwithstanding anything to the contrary contained in the Development Agreement, the City consents to the transfer of title from the Developer to Target of the Target Tract and acknowledges that Target may thereafter transfer or convey interests in the Target Tract in Target's sole and absolute discretion. SUNEVIARY OF THE PROJECT The information provided in this section "SUMMARY OF THE PROJECT" has been included because it may be considered relevant to an informed evaluation and analysis of the Bonds. No assurance can be given that the development of the Project will occur as described below. No assurance can be given that the development of the Project will be completed or that it will occur in a timely manner or in the configuration described herein. The Bonds and Revenues are not personal obligations of any land owners or the Developer. The Bonds are secured solely by the Revenues and certain other amounts on 25 deposit with the Trustee. See "SECURITY AND SOURCE OF PAYMENT FOR THE BONDS." The Bonds will finance a portion of the construction of the Special Services necessary for the Project. General The Project will be located at the northwest corner of Route 34 (Veterans Parkway) and Cannonball Trail in Yorkville, Illinois. The site is generally rectangular in shape and consists of approximately 190 acres or 8,276,400 square -feet. Kendall Marketplace is the commercial component of the Project that will contain an approximately 800,000 square -foot regional shopping center, which is part of the larger mixed -use commercial and residential site. The residential portion of the proposed development will consist of single family homes and town homes on approximately 33 acres of land. The residential portion of the proposed development is not included within the SSA. Overall, the topography of the subject property is level and at grade with the surrounding roadways. The soil is or will be of sufficient load bearing capacity to support the proposed structures. Existing drainage of the site is to the east and currently no public utilities are available to the site. The Illinois Department of Transportation has announced plans to construct the Prairie Parkway —a state highway connecting I -88 to I -80. The Prairie Parkway will have a future interchange west of the Marketplace at Route 34. Traffic patterns suggest that the intersection of Route 34 and Route 47 is the busiest intersection in Kendall County with 64,850 vehicles per day. As a result, access is considered good. Site Improvements Kendall Marketplace shopping center is expected to accommodate more than 60 commercial users including fashion retailers, specialty shops, a bookstore, an electronics store, and a sporting goods store, in addition to three national anchors. The shopping center will also offer a variety of fast -food and sit -down restaurants. Site improvements will include the re- construction and widening of Cannonball Trail to include turning lanes and deceleration lanes; the widening of Route US 34, new traffic signalization, the relocation of water and sanitary and storm sewers; the construction of Beecher Road, including grading, paving, striping, new traffic signalization and the relocation of water, storm and sanitary sewers and electrical service. Land will also be developed for civic and park use, water and fire protection services for the shopping center, and detention, including retaining walls and railings. Kendall Marketplace will also include approximately 3,650 parking spaces, excluding spaces included on the outlots, with a combination of in -line, lifestyle center and outlot retail properties. Outlot space will include both fast -food and sit -down restaurants located along Route 34 and Cannonball Trail and a variety of retail and service uses. The Developer is currently in negotiations with two sit -down restaurants for two of the outlots. Significant interest has been received from other restaurants and banks for the outlot space and from a number of retailers for the inline space. Special Services The Developer will be paid from the amounts deposited into the Improvement Fund under the Indenture from the proceeds of the Bonds for the construction of the Special Services. "Special Services" means the improvements benefiting the SSA consisting of engineering, soil testing and appurtenant work, 26 mass adin and demolition, storm water management facilities, storm drainage systems and storm �' g g g Y sewers, site clearing and tree removal, public water facilities, sanitary sewer facilities, erosion control measures, roads, streets, curbs, gutters, street lighting, signalization, bicycle paths, sidewalks and related street improvements, and equipment and materials necessary for the maintenance thereof, landscaping and tree installation, costs for land and easement acquisitions relating to any of the foregoing improvements, other eligible costs of improvements to serve the SSA and reimbursement of eligible costs incurred prior to the issuance of the Bonds.. Zoning On October 24, 2006, the Village adopted Ordinance No. 2006 -_ granting approval of the PUD Plan, special use, site plan, and appearance approval for the development of the Project and surrounding retail uses. The underlying new zoning is B -3, Business District. Construction Site development for the Kendall Marketplace began in October 2006. The Kohl's store is projected to open in November 2007. Most retailers project an opening in the spring or fall of 2008 and restaurant facilities anticipate openings between the spring 2008 and the fall of 2009. The fagade of the center will be constructed of masonry and exterior finish system. The average building height will be one story. The main center will have concrete footings and steel joist beams. The marketplace buildings will have steel columns. Floors will be concrete. The exterior walls will be masonry and exterior fmish system. The buildings that make up Kendall Marketplace will have a flat membrane roof system. The window system will be an aluminum window wall system. The Developer will sell and deliver anchor pads and some outlot pads. It is anticipated that outlot parcels will be both sold and/or leased. Mechanical The Kendall Marketplace will have a roof top air handling unit systems. Electrical service will be provided by Commonwealth Edison and is assumed to be adequate. There will be hardwired smoke detectors in the buildings. The Marketplace will be fully sprinklered. Emergency lighting will be located throughout the Project. Interior The Kendall Marketplace buildings will have concrete flooring. As proposed, the ceilings will be drywall or lay -in ceiling tiles. It is anticipated that there will be a combination of lighting throughout the Kendall Marketplace. Retail Inline Properties Kendall Marketplace will be anchored by Super Target, Home Depot, and a Kohl's store. These anchors will comprise approximately 370,000 square -feet. Several mid -size retailers, such as Michaels, Petsmart and T.J. Maxx, are expected to be tenants of the shopping center. Additional retail tenants are expected to include an office supply store, fashion retailers, specialty shops, a bookstore, an electronics store, a sporting goods store and several restaurants. Building plans have not yet been completed, but the facades will be more decorative than a typical community or neighborhood shopping center. Each retail building will be constructed to the anchor specifications. For in -line space, construction will range from 60 to 250 feet in depth and width, per end - users' needs. Beecher Road, 27 Route 34, and Cannonball Trail will provide access to Kendall Marketplace and the outlots. Land Sales Land sales will be made to the three large anchors: SuperTarget, Home Depot, and Kohl's. These land sales are expected to occur simultaneously with the issuance of the Bonds. These anchor stores are projected to open in the fall 2007 and spring or summer of 2008. The Developer has entered into a land purchase contract with Home Depot and has signed letters of intent with each of SuperTarget and Kohl's. The Developer is negotiating definitive land purchase agreements with each of SuperTarget and Kohl's. SuperTarget will occupy an approximately 178,000 square -foot store within Kendall Marketplace. Target Corporation operates more than 1,300 Target stores in 47 states, including over 140 SuperTarget stores that include an upscale grocery shopping experience. In addition to the photo processing, pharmacy and restaurants found in almost every Target, SuperTarget includes in -store bakery, deli, meat and produce sections. Home Depot will occupy an approximately 103,000 square -foot store within Kendall Marketplace. Today, on average, Home Depot offers 40,000 home and industrial improvement products and is a nationally recognized retailer with more than 2,000 stores throughout the United States, Canada and Mexico. Home Depot also owns EXPO Design Center, an upscale home remodeling supply and design store, and The Home Depot Supply, which provides services for commercial use. Kohl's will occupy an approximately 90,000 square -foot store within Kendall Marketplace. Kohl's is a retail department store that sells apparel, shoes & accessories for women, children and men, plus home products such as small appliances, bedding, luggage and more. Kohl's Department Stores operate over 800 stores throughout the United States. Lease Tenants The base lease term varies by tenant with mid -size retailers generally signing initial leases for ten years (typically with two -four 5 year extension options), smaller retailers generally signing leases for 5 years, and restaurant leases generally lasting between 15 and 20 years. The annual rent typically would remain the same for five to ten years and would escalate 5% to 10% every 5 years as extension options are exercised. The Developer has signed letters of intent with a number of prospective tenants for leased space. These include: Petsmart will occupy an approximately 20,000 square -foot store within Kendall Marketplace. PetSmart, Inc. is the largest specialty retailer of services and solutions for the lifetime needs of pets. The company operates more than 860 pet stores in the United States and Canada. Payless ShoeSource will occupy an approximately 3,000 square -foot store within Kendall Marketplace. Payless ShoeSource is the largest specialty family footwear retailer in the Western Hemisphere. The Company sold more than 182 million pairs of shoes in fiscal 2005, generating $2.7 billion in net sales. Payless ShoeSource operates stores in all 50 U.S. states and has stores in Asia and across South America. i I I 28 i I The Developer expects to attract a variety of other potential retailers to Kendall Marketplace, including craft supply stores, cosmetic stores, shoe stores, salons, fashion retailers, and fast food outlets. Potential retailers range in size from 1,200 square -feet to approximately 22,000 square -feet per store. Small-shop Boutique Boulevard The small -shop boutique boulevard portion of Kendall Marketplace will resemble a lifestyle center and include approximately 165,000 square -feet of retail, electronics, bookstore and restaurant space. The retail spaces range in size from 6,000 square -feet to 30,000 square -feet. Approximately three sit -down restaurants are expected to be located in the lifestyle portion with each approximately 6,000 square -feet in size. In addition, proposed stores include a sporting goods store of 15,000 square -feet, an electronics store of approximately 30,000 square -feet, a bookstore of approximately 20,000 square -feet, and various retail, cafe and spa vendors. The boutique boulevard will also include a water feature, grassy promenade, and an appropriate number of parking spaces. Potential tenants of Kendall Marketplace's lifestyle center include national electronic and media retailers as well as a coffee chain, spa, and jewelry store. Potential retailers range in size from 1,200 square -feet to approximately 30,000 square -feet per store. The lifestyle center will also include various fast food restaurants and casual, sit down dining restaurants, which will offer a variety of family oriented menus and atmospheres, and. Outlot Properties There are 17 outlots proposed for Kendall Marketplace totaling approximately 70,000 square -feet of developable building area. The lots range in size from 1 acre to 2.65 acres with proposed users developing 3,000 to 6,500 square foot buildings per lot. Up to three of the outlots will be developed into 5,000 square -foot sites for bank use. Approximately 50,000 square -feet will be developed for sit -down and fast food restaurants that will cater to retail shoppers and the surrounding community. Construction Manager The Developer will be the construction manager for the Project. The Developer expects to retain one or more qualified construction contractors to construct the Special Services. Additional construction contractors will be engaged to provide other construction services with respect to various aspects of the Project. Property Management The Harlem Irving Companies, Inc, will be the property manager for the Project. Harlem Irving currently manages 15 properties, encompassing more than 2.5 million square feet of retail space. In addition to Kendall Marketplace, the company is currently developing approximately 400,000 square feet of retail space, which it intends to manage upon completion of construction. The company consists of a seasoned team of professionals with more than 200 years of combined experience in developing, leasing, managing and marketing properties. See "THE DEVELOPER." 29 Environmental Site Assessment it A Phase I Environmental Site Assessment dated December 7, 2005 for the area comprising the Business District was prepared for The Harlem Irving Companies, Inc., by Pioneer Engineering & Environmental Services, Inc. No recognized environmental conditions were identified in the report in connection with the subject property. i Project Financing The total cost of the Project is estimated to be approximately $132 million. The Developer will enter in a three -year loan agreement with one or more lenders for up to approximately $69.1 million in loans to fund the construction and development of the Project. The construction and development loans will be used primarily to acquire land and construct the Project. The Developer will obtain additional funding for the Project from the sale of outlots, land sales to anchor tenants and the residential developer and site work reimbursement from anchor tenants and the residential developer. 1 30 Site Plan [TO BE INSERTED] i I 31 THE DEVELOPER Cannonball LLC ( "Cannonball ") is an Illinois limited liability company established for the purpose of developing and owning Kendall Marketplace. Cannonball has three managers: MidAm Yorkville LLC, which is managed by principals of Mid - America Development Partners, LLC; The Harlem Irving Companies, Inc., of which Michael Marchese is President; and NF6 LLC, which is managed by New Frontier Developments Co. Mid,4m Yorkville LLC managed by Mid America Development Partners LLC i MidAm Yorkville LLC, is managed by Mid - America Development Partners, LLC ("Mid - America"). Mid - America is a real estate development firm headquartered in Oak Brook, Illinois employing 25 real estate professionals. The furn was founded in 2001 by David P. Bossy and Michael D. The firm is committed to creating functional attractive developments that enhance their Fusel. Th g p communities and deliver an exceptional level of tangible value to both the partners and municipalities they serve. Currently, Mid -Am has more than 30 projects in various stages of development, including retail, hospitality and mixed -use projects that span more than seven million combined square -feet. Mid - Am generally is involved in the complete development of a project, beginning with the acquisition of land through the entitlement process and completion of construction. David Bossy was the President and co- founded Mid - America Real Estate Corporation in 1984. Since 1977, he has provided leadership and strategic direction for commercial/retail brokerage and asset management operations as well as the acquisition, development and construction of approximately 35 million square -feet of shopping centers throughout the Midwest. In 1997 The Chicago Sun -Times named Mr. Bossy its Retail Broker of the Year. He has also assisted third party retail clients in developing and executing expansion plans of several nation chains such as Office Max, Comp USA, Old Country Buffet, Famous Footwear and Golfsmith. Additionally, he has been involved in the marketing and property disposition for several national retail chains including the Home Depot, TJX and New York Carpet World. Michael Firsel was a practicing attorney from 1973 to 1999, having formed his own firm in 1982. During that time, he concentrated on all types of real estate transactions, representing numerous developers in varying capacities and becoming especially familiar with tax increment financing issues and other areas of municipal finance. He acted as special counsel to several municipalities including the Village of Palatine, and the Village of La Grange during their respective redevelopment projects. In 1999, he left the full time practice of law to become a developer, founding Firson Investment and Development Company, LLC with Gerald W. Fogelson. From 1999 to 2001, Firson worked on the development of several projects including the Central Station project in downtown Chicago, Illinois as well as co- developing the LaGrange Triangle redevelopment project. Additionally, Mr. Firsel previously acted as Special Consultant in Downtown Redevelopment for the Village of Palatine. In 2001, Mr. Firsel came together with David Bossy to form Mid - America Development Partners, LLC which is currently involved in numerous developments. The Harlem Irving Companies, Inc. The Harlem Irving Companies, Inc. ( "Harlem Irving ") brings more than 50 years of Chicago -area retail development, management and leasing experience to the proposed Kendall Marketplace. Harlem Irving is the 79 member of the International Council of Shopping Centers, established in 1957, which currently has over 61,000 members. Harlem Irving's experience in facility planning and market repositioning is best illustrated by its completed retail and residential projects including Harlem Irving Plaza shopping center, one of Chicago's first major shopping centers. 32 The Harlem Irving Companies' keen vision and effective management has enabled Harlem Irving Plaza to be developed into over 650,000 square -feet of gross leasable facilities consisting of approximately 125 tenants on its 21 -acre site. Other Chicago area developments Harlem Irving lists to its credit are as follows: Mixed Use Lincoln Park Commons Chicago, IL University Village * Chicago, IL The Emerald ** Chicago, IL Residential The Cascades Condominiums Norridge, IL Glenlake Condominiums Chicago, IL Merrimac Square Condominiums Chicago, IL River's Edge Condominiums Chicago, IL Retail — Shopping Centers Dunning Square Chicago, IL Ninth & North Avenue Melrose Park, IL Twin Ponds Crystal Lake, IL Northlake Commons Northlake, IL Washington Square Chicago, IL Patriot Marketplace Glenview, IL Sutton Park Streamwood, IL Charter Oaks Peoria, IL Deerfield Depot Deerfield, IL Hickory Creek Marketplace Frankfort, IL Willowbrook Town Center ** Willowbrook, IL 119 & Cicero ** Alsip, IL * In 2002, the Chicago Sun Times honored University Village with the "City Development of the Year" award. * * Currently being developed. Harlem Irving currently manages 15 properties, including stand -alone outparcels, that encompass approximately than 2.4 million square -feet of retail space. In addition to Kendall Marketplace, the Company is currently developing approximately 400,000 square -feet of retail space in several other shopping center developments, which it intends to manage upon completion of construction. Harlem Irving has forged relationships with national and regional retailers such as Home Depot, Jewel/Osco, Target, Kohl's, The Limited, Carson Pirie Scott, T.J. Maxx and Best Buy. Michael Marchese is the Chief Executive Officer and President of The Harlem Irving Companies, Inc., a company his father founded in 1954, which remains wholly owned by Mr. Marchese's family today. In Mr. Marchese's 36 years of dedication to Harlem Irving, he has been instrumental in formulating and implementing the company's growth and holdings. Current responsibilities as President include actively managing all financial, leasing, development, marketing and operations efforts. Mr. Marchese's involvement in various projects has been vital to the growth of Harlem Irving and the overall success of the company. Rick Filler is the Executive Vice President and Chief Operating Officer of the Harlem Irving Companies. In this role, Mr. Filler oversees the entire development process and its staff. His scope of 33 responsibility includes land purchase, negotiations of anchor tenant leases, financing and construction. Over the past 23 years, Mr. Filler has cultivated a solid real estate background through his involvement in + ) various aspects of development including office space, enclosed retail centers, strip shopping centers, high -end residential developments and golf course communities. Before arriving at The Harlem Irving Companies, Mr. Filler held the title of Property Manager for RKKK Management, Lowry Development Company and HSW Investments, Inc. NF6 LLC managed b New Frontier Developments Co. I g Y P NF6 LLC is managed by New Frontier Developments Co. ( "New Frontier "). New Frontier is a co- developer of retail centers in the Chicago area with The Harlem Irving Companies. Founded in 1975 by William F. Cellini and Lawrence Haddad, New Frontier plans and develops residential and commercial real estate projects. New Frontier - related companies have constructed and currently manage approximately two million square -feet of single and multi- tenant commercial properties for nationally recognized businesses, agencies and institutions, including Ameritech and PacificCorp. The New Frontier group of companies has twenty years of experience managing a portfolio of 17,500 residential units, such as multi - family developments, luxury high -rise condominiums, and conventionally financed housing, located throughout the United States. THE CITY The United City of Yorkville (the "City ") was established in 1834, and has been the county seat of Kendall County since 1859. It is located in northeastern Illinois on the Fox River approximately 45 miles southwest of Chicago. Nearby communities include Oswego, Bristol, Plano, Millbrook, Helmar, Newark, Plattville, Montgomery, Sugar Grove and Plainfield. According to the 2000 Census, the City had a population of 6,189. A special census in December of 2003 resulted in a population total of more than 8,500. Subsequently, a special census completed in May of 2006 showed an increase in that total of 31.8% when the population increased to 11,204. City Government and Services The City follows a Mayor /City Council form of government in which the Mayor, Aldermen, City Clerk and City Treasurer are each elected to a four -year term. The City Council is comprised of the Mayor and eight Alderman (two Alderman elected from each of the City's four wards). The City is served by the Bristol/Kendall Fire Protection District which carries a Protection Class 6. It maintains a 24 hour paramedics unit and is a member of the Mutual Aid Box Alarm System. The Police Department employs twenty full -time officers, and emergency medical service is available 24 hours a day. Transportation The City is approximately 15 miles west of Interstate 55 (I -55); almost 20 miles north of Interstate 80 (1 -80); and nearly 12 miles south of Interstate 88 (I -88). Illinois Routes 47 and 34 intersect the City. O'Hare International Airport is approximately 40 miles northeast of the City and Midway Airport is about 40 miles to the east in Chicago. Aurora Municipal Airport, approximately ten miles to the north provides lighted runways and aircraft tiedowns, hangar, power plant repair, air frame repair and navigator aids. Additionally it offers freight, charter and helicopter services. The Burlington Northern Sante Fe Railroad in nearby Aurora provides commuter rail service. 34 Yorkville Public Library Yorkville Public Library (the "Library ") serves the residents of the City and is a member of the Heritage Trail Library System. The Library began as a "Reading Room" in the 1800's and was actively used by the Yorkville Women's Club who in 1915 formally established it as a library. In 1965, the Library was turned over to the City of Yorkville. Over the years, it has occupied three locations and has had its growth funded through state programs, monetary gifts from businesses as well as individuals, and volunteer labor. It has recently undergone improvements with the addition of a CD -ROM full -text magazine index, and a referendum was passed in 2004 to authorize the sale of bonds to expand the facility. In addition to its extensive collection of books, Library resources include dial -a -story, local history, newspapers, sheet music, audio books, large print books, paperbacks, magazines, and videos and DVD's. Services available to the community are homebound service, interlibrary loan, kit for brothers and sisters of new babies, kits for sick kids, loft meeting area, photocopier, computers, tax forms, talking books, typewriter and voter registration. The Library offers the following online resources: animals and the environment; arts and crafts; children's book and screen characters; children's books and stories online; educational resources; exploration and museums; history and geography; holidays and celebrations; literature online; math and science; music and poetry; reference tools and homework help; space; and sports and recreation. Community Life The City contains approximately 60 acres of parks with picnic areas, a gazebo and recreational fields. Programs offered include aerobics, basketball, bus trips, bowling, Country/Western dance, crafts, dance, fishing, golf, soccer, sports club, street hockey, tee ball, tennis and tumbling. Residents also enjoy a golf course and forest preserves which are nearby but outside the City boundaries. Medical services are available at Rush/Copley Medical Center and Provena -Mercy Center, both located in Aurora. Additional facilities are provided by Sandwich Community Hospital in Sandwich, Illinois. These institutions are about fifteen miles from the City. Education Community Unit School District Number 115 (the "District ") meets the elementary and secondary educational requirements of the City with two elementary schools, one junior high school and one high school. The District has a staff of approximately 200 teachers and administrators and approximately 3,200 students. The District has implemented a new computer curriculum, innovative interdisciplinary projects and advanced team building and support programs for students and staff. Higher education opportunities are offered by Aurora University in nearby Aurora and Northern Illinois University in DeKalb. In addition, Waubonsee Community College District No. 516 (the "College ") offers a wide variety of transfer, vocational, continuing and community education, children's and corporate development and training classes. It has 24 programs designed for transfer to senior institutions, and also offers occupational- oriented programs ranging in length from one semester to two years. The College recently opened a state -of -the -art academic computing center that houses eight classrooms and a 120 personal computer work station open lab. 35 Socioeconomic Information Following are lists of large employers located in the City and in the surrounding area. Major City Employers(1) Approximate Name Product/Service Employment Wrigley Manufacturing Co., LLC Sugar Confections, Bubble Gum, & Candy 400 XPAC Tractor Radiators and Engines 150 Newly Weds Foods Food Seasonings, Cures and Binders 115 Brenart Eye Clinic Eyeglasses 50 Cascade Water Works Mfg. Co., Inc. Sewer & Piping Systems Repair Products 40 C.J. Insulation, Inc. Insulation Installation 40 G.H. Haws & Assocs. Plastic Molding Parts 25 Alpha Precision, Inc. Photographic Equipment & Supplies 20 Meadowvale, Inc. Ice Cream, Custard, Soft Serve and Shake Mixes 20 Alpha Precision, Inc. Photographic Equipment & Supplies 20 Note: (1) Source: 2007 Illinois Manufacturers Directory and 2007 Illinois Services Directory. Major Area Employers(1) Approximate Location Name Business or Product Emnlovment Sugar Grove Waubonsee Community College #516 Education 1,460 Oswego Coldwell Banker Primus Realty Residential Real Estate 550 Mopt Lyons Workspace Products, L C Steel Storage Equipment 400 Plaingeld CB &I Constructors, Inc. Elevated Water Storage Tanks, Pressure Vessels 400 Montgomery Eby -Brown Co. Wholesale Tobacco & Confectionery 400 Montgomery The Dial Corp. Soap, Glycerin, & Fatty Acids 400 Montgomery Fox River Foods Inc. Wholesale Food 340 Plainfield CB &I Constructors, Inc. Storage Tank Insulation Equipment 300 Montgomery Processed Plastic Co. Plastic Toys 300 Plainfield Diageo North America, Inc. Gin and Vodka Distilling 300 Plainfield Diageo North American, Inc. Gin & Vodka Distilling 300 Plainfield Van Drunen & Sons, Inc. R.J. Corporate Headquarter, Freeze -Dried Herbs 200 Plainfield R.A. Bright Construction, Inc. Concrete, Excavating, Underground Utilities 200 Plainfield Flexi -Mat Corp. Foam Rubber & Sponge Pillows 180 Plainfield Fox Valley Press Newspaper Printing 170 Plano Fox Valley Molding, Inc. Compression Transfer & Injection Molding 150 Plano Plano Molding Co. Plastic Injection Molding Headquarters 150 Oswego Radiac Abrasives, Inc. Diamond Grinding Wheels 150 Montgomery Weyerhaeuser Co. Corrugated Cartons 150 Note: (1) Source: 2007 Illinois Manufacturers Directory and 2007 Illinois Services Directory and a selective telephone survey. The following tables show employment by industry and by occupation for the City, Kendall County (the "County ") and the State of Illinois (the "State ") as reported by the 2000 Census. 36 Employment By Industry(]) The City The Countv The State Classification Number Percent Number Percent Number Percent Agriculture, Forestry, Fishing, Hunting, and Mining........... 47 1.45% 380 1.32% 66,481 1.14% Construction .......................................... ............................... 332 10.23% 2,586 8.97% 334,176 5.73% Manufacturing ....................................... ............................... 564 17.38% 5,337 18.50% 931,162 15.96% Wholesale Trade .................................... ............................... 145 4.47% 1,187 4.12% 222,990 3.82% Retail Trade ........................................... ............................... 434 13.37% 3,416 11.84% 643,472 11.03% Transportation and Warehousing, and Utilities .................... 201 6.19% 1,657 5.75% 352,193 6.04% Information ............................................ ............................... 67 2.06% 774 2.68% 172,629 2.96% Finance, Insurance, Real Estate, and Rental and Leasing .... 216 6.65% 2,463 8.54% 462,169 7.92% Professional, Scientific, Management, Administrative, and Waste Management Services ......... ............................... 287 8.84% 2,369 8.21% 590,913 10.13% Educational, Health and Social Services .............................. 443 13.65% 4,691 16.26% 1,131,987 19.41% Entertainment and Recreation Services, Accommodation and Food Services ................................ ............................... 244 7.52% 1,740 6.03% 417,406 7.16% Other Services (except Public Administration ) .................... 118 3.64% 1,246 4.32% 275,901 4.73% Public Administration ............................ ............................... 148 4.56% 996 3.45% 231.706 3.97% Total .......................... ............................... ..........................3,246 100.00% 28,842 100.00% 5,833,185 100.00% Note: (1) Source: U. S. Bureau of the Census. Employment By Occupation(]) The Citv The County The State Classification Number Percent Number Percent Number Percent Management and Professional .................... ..........................1,140 35.12% 9,817 34.04% 1,993,671 34.18% Service Occupations .............................. ............................... 416 12.82% 3,216 11.15% 813,479 13.95% Sales and Office Occupations ................ ............................... 858 26.43% 8,310 28.81% 1,609,939 27.60% P I Farming, Forestry and Fishing .............. ............................... 0 0.00% 66 0.23% 17,862 0.31% Construction, Extraction, and Maintenance .......................... 300 9.24% 2,997 10.39% 480,418 8.24% Production, Transportation, and Material Moving ............... 532 16.39% 4,436 15.38% 917.816 15.73% Total 3 100.00% 28 100.00% 5 100.00% Note: (1) Source: U.S. Bureau of the Census. Annual Average Unemployment Rates(]) Calendar The The The Year C� Coun State 1996 .....................5.9% 3.9% 5.3% 1997 ..................... 4.7% 3.1% 4.7% 1998 .....................4.3% 2.9% 4.5% 1999 .....................4.1% 2.8% 4.3% 2000 .....................2.1% 2.8% 4.4% 2001 2.8% 4.0% 5.4% 2002 ..................... 3.6% 5.6% 7.1% 2003 .....................3.6% 6.0% 6.7% 2004 .....................3.4% 5.0% 6.2% 2005 .....................3.2% 5.2% 5.7% 2006(2) ................N/A 3.6% 4.1% Notes: (1) Illinois Department of Employment Security. (2) Preliminary rates for the month of December 2006. Housing The 2000 Census reported that the median value of the City's owner- occupied homes was $157,700, which compares with $154,900 for the County and $130,800 for the State. The 2000 market I i 37 value of specified owner- occupied units for the City, the County and the State was ds follows: i j Specified Owner - Occupied Units(1) The Citv The Countv The State Value Number Percent Number Percent Number Percent j Less than $50,000 ............. 0 0.00% 93 0.65% 230,049 9.31% $50,000 to $99,999 ........... 150 9.35% 1,137 7.90% 651,605 26.38% $100,000 to $149,999 ....... 520 32.40% 5,485 38.12% 583,409 23.62% $150,000 to $199,999 ....... 657 40.93% 4,168 28.97% 429,311 17.38% $200,000 to $299,999 ....... 260 16.20% 2,873 19.97% 344,651 13.95% $300,000 to $499,999....... 18 1.12% 492 3.42% 163,254 6.61% $500,000 to $999,999 ....... 0 0.00% 128 0.89% 55,673 2.25% $1,000,000 or more........... 0 0.00% 12 0.08% 12386 0.50% Total ...... ..........................1,605 100.00% 14,388 100.00% 2,470,338 100.00% Note: (1) Source: U.S. Bureau of the Census. Income Per Capita Personal Income for the Ten Highest Income Counties in the State(1) Rank 2000 1 ........................ ...........................Lake County......................... $32,102 2 .......................... .........................DuPage County.................... 31,315 3 ........................... ........................McHenry County ................. 26,476 4 ........................... ........................Kendall County 25,188 5 .................... ............................... Will County .......................... 24,613 6 .................... ............................... Kane County ........................ 24,315 7 ........................ ...........................Cook County........................ 23,227 8 ............................ .......................Sangamon County................ 23,173 9 .......................... .........................Monroe County .................... 22,954 10 ........................ .........................Grundy County .................... 22,591 Note: (1) Source: U.S. Bureau of the Census. 38 The following shows a ranking of median family income for the Chicago metropolitan area among 102 Illinois counties from the 2000 Census. Ranking of Median Family Income(1) Ill. Family Ill. Coun Income Rank DuPage County ................ $79,314 1 Lake County ..................... 76,424 2 McHenry County .............. 71,553 3 Will County ...................... 69,608 4 Kendall County .............. 69,383 5 Kane County .................... 66,558 6 Cook County .................... 53,784 14 Note: (1) Source: U.S. Bureau of the Census. According to the 2000 Census, the City had a median family income of $67,521. This compares to $69,383 for the County and $55,545 for the State. The following table represents the distribution of family incomes for the City, the County and the State at the time of the 2000 Census. Median Family Income(1) The Citv The Countv The State Income Number Percent Number Percent Number Percent Under $10,000 .................. 7 0.42% 117 0.78% 156,205 5.00% $10,000 to $14,999 ........... 0 0.00% 169 1.13% 105,747 3.38% $15,000 to $24,999 ........... 79 4.79% 609 4.07% 273,712 8.76% $25,000 to $34,999 ........... 131 7.94% 966 6.45% 331,907 10.62% $35,000 to $49,999 ........... 284 17.21% 2,226 14.86% 506,429 16.20% $50,000 to $74,999 ........... 536 32.48% 4,492 29.99% 736,897 23.58% $75,000 to $99,999 ........... 328 19.88% 3,215 21.46% 445,390 14.25% $100,000 to $149,999 ....... 206 12.48% 2,372 15.84% 356,068 11.39% $150,000 to $199,999 ....... 35 2.12% 506 3.38% 101,955 3.26% $200,000 or more .............. 44 2.67% 306 2.04% 111.008 3.55% Total . ............................... 1,650 100.00% 14,978 100.00% 3,125,318 100.00% Note: (1) Source: U.S. Bureau of the Census. 39 According to the 2000 Census, the City had a median household income of $60,391. This compares to $64,625 for the County and $46,590 for the State. The following table represents the ) j distribution of household incomes for the City, the County and the State at the time of the 2000 Census. Median Household Income(1) The Citv The Countv The State Income Number Percent Number Percent Number Percent Under $10,000 .................. 70 3.10% 435 2.32% 383,299 8.35% $10,000 to $14,999 ........... 54 2.39% 378 2.01% 252,485 5.50% $15,000 to $24,999 ........... 175 7.76% 1,308 6.96% 517,812 11.27% $25,000 to $34,999 ........... 193 8.55% 1,553 8.27% 545,962 11.89% $35,000 to $49,999 ........... 405 17.95% 2,771 14.75% 745,180 16.23% $50,000 to $74,999 ........... 652 28.90% 5,234 27.86% 952,940 20.75% $75,000 to $99,999 ........... 382 16.93% 3,635 19.35% 531,760 11.58% $100,000 to $149,999 ....... 246 10.90% 2,567 13.66% 415,348 9.04% $150,000 to $199,999....... 35 1.55% 563 3.00% 119,056 2.59% $200,000 or more .............. 44 1.95% 345 1.84% 128.898 2.81% Total ...... ..........................2,256 100.00% 18,789 100.00% 4,592,740 100.00% Note: (1) Source: U.S. Bureau of the Census. Wealth Indicators The private publication "Sales & Marketing Management" has developed a wealth indicator termed "effective buying income" (EBI) defined as money income less personal tax and non -tax payments, which is considered by the publication to be a bulk measurement of market potential. At December 31, 2004 (the latest data available), the County reportedly had a total EBI of $1,603,723,000 and a median household EBI of $55,275. The trend in median household EBI relative to the State and Kendall County, is shown below. Data for the City is not available. Effective Buying Income(1) 2000 2001 2002 2003 2004 Kendall County $53,508 $52,516 $55,183 $55,290 $55,275 State of Illinois 45,381 41.976 40,780 41,216 42,182 County as Percent of State 117.91% 125.11% 135.32% 134.15% 131.04% Note: (1) Source: "Sales & Marketing Management'. 40 Retail Activity Following is a summary of the City's sales tax receipts as collected and disbursed by the State. Retailers' Occupation, Service Occupation and Use Tax(1) State Fiscal Year State Sales Tax Annual Percent Endina June 30 Distributions(2) Chance + ( -) 1997 453,818 (3.91 %)(3) 1998 850,072 87.32% 1999 936,217 10.13% 2000 1,024,813 9.46% 2001 1,003,021 (2.13 %) 2002 1,203,279 19.98% 2003 1,558,831 29.55% 2004 1,982,218 27.16% 2005 . 2,320,546 17.07% 2006 2,649,888 14.19% Growth from 1997 to 2006 483.91% Notes: (1) Source: Illinois Department of Revenue. (2) Tax distributions are based on records of the Illinois Department of Revenue relating to the 1% municipal portion of the Retailers' Occupation, Service Occupation and Use Tax, collected on behalf of the City, less a State administration fee. The municipal l% includes tax receipts from the sale of food and drugs which are not taxed by the State. (3) The 1997 percentage is based on a 1996 sales tax of $472,289. THE SPECIAL SERVICE AREA AND AD VALOREM TAX The Act Section 6 of Article VII of the Illinois Constitution of 1970 permits a home rule unit to levy or impose additional taxes upon areas within its boundaries to provide special services to those areas and to pay debt incurred in order to provide those special services in the manner provided by law. Such areas are established pursuant to the provisions of the Act. Under the Act, the corporate authorities of the municipality within which the special service area lies constitute the governing body of such special service area. The Act provides that bonds may be issued to provide for the special services. Such Bonds do not constitute indebtedness of the municipality in which the special service area is situated for the purpose of any limitation imposed by any law. Such Bonds shall be retired by a tax such as the Ad Valorem Tax. The Act further provides that the lien and foreclosure remedies provided in Article 9 of the Illinois Municipal Code shall apply on nonpayment of any Ad Valorem Tax. The Act contains a provision that allows residents of a special service area to petition the circuit court having jurisdiction to disconnect territory from the special service area if, among other things, such territory was not, is not, and is not intended by the corporate authorities which created the special service 41 area to be benefited or served by services then existing or authorized, and that such territory constitutes less than 1 1/2% of the special service area's total equalized assessed valuation. The Developer and the 1 1 City have represented that no parcel within the Area currently meets this test. Establishment of the Special Service Area Pursuant to the Act, the corporate authorities of the City adopted Ordinance No. - on 2007 proposing to establish the SSA. Pursuant to a notice published in on , 2007 and pursuant to notice by mail to each person in whose name general taxes for the last proceeding year were paid on each parcel of land within the SSA, a public hearing was held on March 13, 2007 to further consider establishment of the SSA. On _, 2007, the City Board adopted Ordinance No. (the "Establishing Ordinance "), which established the SSA to provide certain special services, and authorized the City to levy and collect Ad Valorem Taxes to pay principal of and interest on the bonds secured by the Ad Valorem Taxes in an aggregate principal amount not to exceed $12,500,000 with the maximum rate of taxes to be extended in any year for special services within the proposed SSA to not exceed the amount necessary to produce an annual tax levy of $1,865,000. Pursuant to the Act, if a petition signed by at least 51% of the electors residing within the SSA and by at least 51% of the owners of record of land included within the boundaries of the SSA was filed with the municipal clerk within 60 days following the final adjournment of the public hearing objecting to the creation of the SSA, the issuance of the Bonds or the provision of the Special Services, then the SSA could not be created. No such petition was filed objecting to the creation of the SSA. The City has caused the Establishing Ordinance to be recorded in the Office of the Recorder of Deeds of Kendall County. Levy, Abatement and Collection of Ad Valorem Tax In Illinois, property taxes levied in one year become payable during the following year as 1 provided in said levy. Pursuant to the Bond Ordinance the City has levied the Ad Valorem Tax upon all taxable real property within the SSA and will abate such tax each year to the extent it exceeds the Ad Valorem Tax Requirement. On November 1 of each year, the Trustee shall determine the amount of the Ad Valorem Tax Requirement for the next succeeding March 1, September 1 and March 1 (of the following year) less amounts already on deposit in the Bond Fund on such November 1 (the "Deficiency "). The Ad Valorem Tax authorized to be levied by the Bond Ordinance shall be abated each year to the extent the taxes levied pursuant to the Bond Ordinance exceed the Ad Valorem Tax Requirement as calculated by the Trustee. At the end of each collection year, the Kendall County Treasurer applies to the Circuit Court of Kendall County, for a judgment for all unpaid taxes. The Circuit Court of Kendall County order resulting from that application for judgment provides for a sale of all property with unpaid taxes. A public sale is held, at which time successful bidders pay the unpaid taxes plus penalties. The annual tax sale is usually held during November in Kendall County. Unpaid taxes accrue penalties at the rate of 1 1/2% per month from their due date until the date of sale. Taxpayers can redeem their property by paying the purchaser of the property at the tax sale the amount paid at the sale, plus a penalty. If redemption does not occur within two and one half years, the purchaser of the property at the tax sale can receive a deed to the property which has been sold for delinquent taxes. Alternatively, a municipality may seek enforcement of unpaid Ad Valorem Tax through foreclosure proceedings by seeking in a court an adjudication of the existence of a lien and a finding of a failure to pay Ad Valorem Tax when due. Upon making such a finding, a court having jurisdiction would enter a foreclosure decree authorizing the sale of the property subject to the lien of the Ad Valorem Tax. See "SECURITY AND SOURCE OF PAYMENT FOR THE BONDS — Foreclosure of Liens" herein. 42 The City has levied a Ad Valorem Tax upon all taxable real property within the SSA sufficient to pay and discharge the principal of the Bonds at maturity or mandatory sinking fund redemption dates and to pay interest on the Bonds for each year, to pay for the Administrative Expenses of the City for each year and to replenish the Reserve Fund to an amount equal to the Required Reserve. RISK FACTORS Investment in the Bonds involves risks which may not be appropriate for certain investors. The following is a discussion of certain risk factors which should be considered, in addition to other matters set forth in this Limited Offering Memorandum, in evaluating the Bonds which are not rated by a recognized rating agency. This discussion does not purport to be comprehensive or definitive. The occurrence of one or more of the events discussed herein could adversely affect the ability or willingness of property owners in the SSA to pay their Ad Valorem Tax when due. Such failures to pay Ad Valorem Tax could result in the inability of the SSA to make full and punctual payments of debt service on the Bonds. In addition, the occurrence of one or more of the events discussed herein could adversely affect the value of the property in the SSA. Limited Source of Funds The Bonds, together with the interest thereon, are limited obligations of the City, payable solely from the Revenues and the amounts on deposit in the various funds and accounts established and maintained under the Indenture, all as more fully set forth therein. The Bonds are not general obligations of the City and do not constitute an indebtedness of the City within the meaning of any constitutional or statutory limitation. No holder of the Bonds shall have the right to compel the exercise of any taxing power of the City for payment of principal thereof or interest or premium, if any, thereon (other than the levy of the Ad Valorem Tax or the pledge of the Business District Sales Taxes and as provided in the Bond Ordinance and the Indenture). See "SECURITY AND SOURCE OF PAYMENT FOR THE BONDS --- General' herein. Concentration of Ownership/Lease of Project All of the land within the SSA is expected to be owned by a limited number of owners including the Developer. The Developer currently intends to develop the land within the SSA as set forth in this Limited Offering Memorandum. There are expected to be leases entered into with several lessees of property within the SSA prior to completion of the Project: Because of the current concentration of ownership in the Developer, the timely payment of the Bonds depends upon the willingness and ability of the Developer to pay the Ad Valorem Tax levied even if the Project is not adequately leased. A slowdown or stoppage in the continued lease of the Project could reduce the willingness and ability of the property owners to make Ad Valorem Tax payments and could greatly reduce the value of such property in the event of any foreclosure proceedings against the Developer. The entities comprising the Developer are Illinois limited liability companies and an Illinois corporation and have a limited source of funds. A failure to make payments when due could result in the rapid, total depletion of the Reserve Fund and other pledged funds prior to replenishment from the resale of property upon a foreclosure or otherwise. In that event, there could be a default in payments of the principal of, and interest on, the Bonds. See "THE DEVELOPER" above and "RISK FACTORS — Potential Delay and Limitation in Foreclosure Proceedings" below. 43 Information Not Verified �i Information concerning the SSA and the proposed development has been obtained from the City, the Developer and other sources believed to be reliable, but much of that information involves predictions of future events, such as leasing ability of the Developer or other property owners to pay their share of the Ad Valorem Tax; such information is, by its nature, not subject to verification. Failure to Develop Project Development of land is subject to economic considerations affecting the Developer and prospective purchasers of developed property including interest rates and the general economic climate of the region surrounding the SSA. The failure to complete development of the required infrastructure or substantial delays in the completion of the Project due to litigation or the inability to obtain required funding by the Developer, such failure or delay may affect the willingness and ability of the owners of property within the SSA to pay the Ad Valorem Tax when due. There can be no assurance that the Special Services will be constructed or will be constructed in time for development to proceed as currently expected. See "SUMMARY OF THE PROJECT." The City may terminate the Development Agreement if the Developer does not comply with ,its terms and provisions. There can be no assurance that the Developer will comply with the terms of the Development Agreement or that the City will not terminate such agreement if the Developer fails to comply with its terms. See "SUMMARY OF THE DEVELOPMENT AGREEMENT ". Only a portion of all of the development costs are being provided by the Bonds. Private financing will be necessary in order to complete the Project. There is no guarantee that the Developer will obtain such financing. I The cost of the Special Services plus the public and private in tract, on site and off site improvements can be expected to increase the public and private debt encumbering the land within the SSA. The Ad Valorem Tax, on a parity with all other property taxes, has priority over all existing and future private liens, imposed on property in the SSA except, possibly, for liens or security interests held by the Federal Deposit Insurance Corporation. See "RISK FACTORS — Bankruptcy," and "— Potential Delay and Limitations in Foreclosure Proceedings." Although liens securing private debt are subordinate to the lien of the Ad Valorem Tax securing the Bonds, this increased private debt could reduce the ability or desire of the property owners to pay the Ad Valorem Tax imposed against their property. See "SECURITY AND SOURCE OF PAYMENT FOR THE BONDS —Ad Valorem Tax." If property owners in the SSA failed to pay the Ad Valorem Tax, and if the Reserve Fund is depleted prior to collection of such delinquent Ad Valorem Tax through foreclosure sale or otherwise, there could be a default in the payment of principal of, and interest on, the Bonds. See "RISK FACTORS — Bankruptcy" herein. Development within the SSA is contingent upon the construction and acquisition of the Special Services as well as the necessary on -site improvements. A slowdown or stoppage of the development process could adversely affect land values and reduce the ability or desire of property owners to pay the Ad Valorem Tax. In that event, there could be a default in the payment of principal of, and interest on, the Bonds. Risk of Construction The generation of Business District Sales Taxes is dependent upon the completion of Phase II as well as additional Phases within the Area. Delays in the construction of the retail stores and the delay in opening the retail stores could adversely affect the generation of Excess Business District Sales Tax. 44 Construction delays could occur for reasons outside the control of the Developer such as material or labor shortages. Risk of Occupancy There is no assurance that the leasing of the retail space within the SSA will achieve or maintain the projected occupancy to generate sales taxes as set forth under "Security and Source of Payment for the Bonds — Projected Excess Business District Sales Tax Available for Bonds Debt Service ". There are anticipated to be numerous small tenants in the Area with various lease terms and various provisions in their leases, and there can be no assurance that, when a lease expires or is terminated for any reason, the lease will be extended or that the tenant's space will be re-leased.' A failure to re -lease space could adversely affect the Excess Business District Sales Tax generated from the SSA. Risk of Changes in Market Conditions, Changes in General Economic Conditions and Future Competition Sales by the stores in the SSA, and the subsequent generation of Excess Business District Sales Tax, could be significantly impaired as a result of changes in market conditions, changes in general economic conditions and competition from existing facilities or facilities developed in the future. Risk of Natural Disaster In the event of a natural disaster severely damaging the facilities in the SSA, there can be no assurance that such facilities will be rebuilt. In such case, generation of Excess Business District Sales Tax would be adversely affected. Risk of Anchor Lease Terminations or Discontinued Operations The generation of Excess Business District Sales Tax could be significantly impaired if any one or more of the anchor tenants within the SSA terminates its lease of space and is not replaced by a comparable tenant. Certain leases grant certain anchor tenants the right to terminate their respective leases under a number of different conditions. In addition, tenants may have the right to terminate their respective leases in the event of fire or other casualty, condemnation, a breach by the landlord of its obligations under the lease, or the existence of hazardous wastes not caused by the tenant. The bankruptcy or insolvency of any tenant may also result in the termination of such tenant's lease. There can be no assurance that any of the circumstances under which any one or more of the leases w ill or may be terminated will not occur. No assurance can be given that Target, Home Depot or Kohl's or other owners of retail property within the SSA will continue to be viable businesses. In such case, the availability of Excess Business District Sales Tax could be negatively affected. Local, State and Federal Land Use Regulations There can be no assurance that land development operations within the SSA will not be adversely affected by future government policies, including, but not limited to, governmental policies which directly or indirectly restrict or control development. The Development Agreement cannot limit the application of state or federal laws and regulations which have preemptive effect on local land use regulations. During the past several years, state and federal regulatory agencies have significantly expanded their involvement in local land use matters through increased regulatory enforcement of various environmental laws, including the Endangered Species Act, the Clean Water Act and the Clean Air Act, among others. Such 45 regulations can substantially impair the rate and amount of development without requiring just compensation unless the effect of the regulation is to deny all economic use of the affected property. } Bondowners should assume that any event that significantly impairs the ability to develop land in the SSA could cause the land values within the SSA to decrease substantially and could affect the willingness and ability of the owners of land to pay the Ad Valorem Tax when due or to proceed with development of land in the SSA. See "RISK FACTORS Failure to Develop Properties" herein. Overlapping Indebtedness The Ad Valorem Tax and any penalties assessed for failure to pay such taxes will constitute a lien against the parcels of land on which they will be levied until such taxes are paid. Such lien will be on a parity with all Ad Valorem Taxes and special assessments which may be levied by other agencies and is co equal to and independent of the lien for general ad valorem real property taxes regardless of when they are imposed upon the same property. The City, however, has no control over the ability of other entities and districts to issue indebtedness secured by Ad Valorem Taxes or assessments payable from all or a portion of the property within the SSA. The ability of an owner of land within the SSA to pay the Ad Valorem Tax could be adversely affected if additional debt is issued or additional taxes or assessments are levied which are payable by the owners of land within the SSA. The imposition of additional liens, whether public or private, may reduce the ability or willingness of the landowners to pay the Ad Valorem Tax and increases the possibility that foreclosure proceeds will not be adequate to pay delinquent Ad Valorem Tax. Zoning Approvals Pursuant to the City Zoning Ordinance, any outstanding approvals involve, to a certain degree, the exercise of discretion on the part of the City. While the Development Agreement contains certain covenants regarding the SSA's zoning, such discretionary action may not always be exercised in amanner that is favorable to the Developer. Permits The Developer has not applied for all building permits necessary to construct the Special Services and the other improvements that make up the Project. Failure to obtain the necessary permits on a timely basis could adversely affect the completion of the Project. Tax Delinquencies, In order to pay debt service on the Bonds, it is necessary that the Ad Valorem Tax within the SSA be paid in a timely manner. Under provisions of the Act, the Ad Valorem Tax, from which funds necessary for the payment of principal of, and interest on, the Bonds are derived, are customarily billed to the property owners within the SSA on the regular general ad valorem property tax bills sent to owners of such properties. Such Ad Valorem Tax installments are due and payable, and bear the same penalties and interest for non payment, as do general ad valorem property tax installments. The unwillingness or inability of a property owner to pay ad valorem property tax bills as evidenced by general ad valorem tax delinquencies may also indicate an unwillingness or inability to make general ad valorem tax payments and Ad Valorem Tax installment payments in the future. If the Developer or future owners fail to pay the Ad Valorem Tax when due there could be significant Ad Valorem Tax delinquencies. See "RISK FACTORS— Concentration of Ownership/Lease of Project." 46 See "SECURITY AND SOURCE OF PAYMENT FOR THE BONDS Foreclosure of Liens" for a discussion of the provisions which apply, and procedures which the City is obligated to follow under the Indenture, in the event of delinquencies in the payment of Ad Valorem Tax. See "RISK FACTORS — Potential Delay and Limitation in Foreclosure Proceedings" and " Bankruptcy" below, for a discussion of limitations on the City's ability to foreclose the lien of delinquent unpaid Ad Valorem Tax in certain circumstances. Potential Delay and Limitations in Foreclosure Proceedings The payment of Ad Valorem Tax and the ability of the Kendall County on behalf of the City to foreclose the lien of a delinquent unpaid Ad Valorem Tax may be limited by bankruptcy, insolvency and other laws generally affecting creditors' rights or by the laws of the State relating to judicial foreclosure. See "RISK FACTORS — Bankruptcy." In addition, the prosecution of a foreclosure could be delayed due to many reasons, including crowded local court calendars or lengthy procedural delays. The ability of the City to foreclose the lien of a delinquent unpaid Ad Valorem Tax payment may be limited with regard to properties in which the Federal Deposit Insurance Corporation ( "FDIC ") or any successor to the FDIC may acquire an interest. The FDIC currently does not have an interest in the land within the SSA. However, if a lender takes a security interest in property in the SSA and becomes insolvent, such a lender could fall under the jurisdiction of the FDIC. The FDIC could assert federal preemptive power to challenge any prior taxes, Ad Valorem Taxes and assessments where it is in their interest to do so, including the requirement that local agencies obtain the consent of the FDIC in order to foreclose the lien of delinquent unpaid Ad Valorem Taxes. If the City is required to obtain the consent of the FDIC to foreclose on property located in the SSA, such consent could be denied and the City might be unable to pursue foreclosure proceedings. Additionally, obtaining such consent could delay the foreclosure proceedings. Any delay in foreclosure proceedings or the inability of the City to foreclose on property in the SSA in which the FDIC has an interest could result in a delay or default in payment of the Bonds. In addition, potential investors should be aware that judicial foreclosure proceedings are not summary remedies and can be subject to significant procedural and other delays caused by crowded court calendars and other factors beyond the control of the SSA or the City. In addition, the Illinois Constitution prescribes certain minimum redemption periods, which may be as long as three years, in the.. event of foreclosure. See "SECURITY AND SOURCE OF PAYMENT FOR THE BONDS — Foreclosure of Liens." It should be assumed that, under current conditions, it is estimated that a judicial foreclosure of the lien of the Ad Valorem Tax could take several years from initiation of litigation to the lien foreclosure sale. Delays and uncertainties in the Ad Valorem Tax lien foreclosure process create significant risks for Bondowners. High rates of Ad Valorem Tax payment delinquencies which continue during the pendency of protracted Ad Valorem Tax lien foreclosure proceedings, could result in the rapid, total depletion of the Reserve Fund prior to replenishment. In that event, there could be a default in payments of the principal of, and interest on, the Bonds. See "RISK FACTORS — Concentration of Ownership/Lease of Project" above. Bankruptcy The various legal opinions to be delivered concurrently with the delivery of the Bonds (including Bond Counsel's approving legal opinion) will be qualified, as to the enforceability of the various legal i 47 I I instruments, by moratorium, bankruptcy, reorganization, insolvency or other similar laws affecting the rights of creditors generally. Although a bankruptcy proceeding would not cause the Ad Valorem Tax to become extinguished, the amount and priority of any Ad Valorem Tax lien could be modified if the value of the property falls below the value of the lien. If the value of the property is less than the lien, such excess amount could be treated as an unsecured claim by a bankruptcy court having jurisdiction. In addition, bankruptcy of a property owner could result in a delay in commencement and completion of foreclosure proceedings. Such delay would increase the likelihood of a delay or default in payment of the principal of, and interest on, the Bonds and the possibility of delinquent tax Ad Valorem Tax installments not being paid in full. Limitation on Remedies; No Acceleration Remedies available to holders of the Bonds may be limited by a variety of factors and may be inadequate to assure the timely payment of principal of and interest on the Bonds, or to preserve the tax - exempt status of the Bonds. Bond Counsel has limited its opinions to the extent that enforceability may be limited by bankruptcy, insolvency, or similar laws affecting generally the enforcement of creditors' rights. Additionally, the Bonds are not subject to acceleration in the event of the breach of any covenant or duty under the Indenture, including payment default. Lack of remedies may entail risks of delay, limitation, or modification of the rights of the holders of the Bonds. Judicial remedies, such as foreclosure and enforcement of covenants, are subject to exercise of judicial discretion. Limited Secondary Market There can be no guarantee that there will be a secondary market for the Bonds or, if a secondary market exists, that such Bonds can be sold for any particular price. Neither the City nor the Developer has committed to provide any financial and/or operating information on a going forward basis. Occasionally, because of general market conditions, lack of current information, the absence of a credit rating for the Bonds or because of adverse history or economic prospects connected with a particular issue, secondary marketing practices in connection with a particular issue are suspended or terminated. In addition, prices of issues for which a market is being made will depend on then prevailing circumstances. Such prices could be substantially different from the original purchase price. Secondary Market and Prices The Underwriter presently does not intend to engage in secondary market trading of the Bonds. The Underwriter is not obligated to engage in secondary trading or to repurchase any of the Bonds at the request of the Owners thereof. No assurance can be given that a secondary market for any of the Bonds will be available and no assurance can be given that the initial offering prices for the Bonds will continue for any period of time. Loss of Tax Exemption Interest on the Bonds could become includible in gross income for federal income tax purposes retroactive to the date of issuance of the Bonds as a result of a failure of the City to comply with certain provisions of the Code. Should such an event of taxability occur, the Bonds are not subject to early redemption and will remain outstanding to maturity or until redeemed under the optional redemption or mandatory redemption provisions of the Indenture. 48 Risk of Legislative and Judicial Changes Future legislation, regulations, governmental or judicial interpretation of regulations or legislation or practices and procedures related to property tax assessment, levy, collections or distribution could have a material effect on the calculation or availability of the Ad Valorem Tax. There is no assurance that legislation will not be considered or enacted in the future, and unless provision is made in such legislation for special service areas generally in Illinois, the generation of the Ad Valorem Tax could be materially adversely affected. UNDERWRITING The Underwriter has agreed, subject to certain customary conditions precedent to closing, to use its best efforts to offer for sale and to sell at par all, but not less than all, of the Bonds. The Underwriter will receive an Underwriter's discount equal to _% of the issued amount of the Bonds ($ ) in consideration of their services. The Bonds may be offered and sold to certain dealers and others at prices lower than the initial public offering price, and such public offering price may be changed, from time to time, without notice by the Underwriters. LEMTED OFFERING The Bonds are being offered only to a limited number (35 or less) of sophisticated investors. Each prospective purchaser of the Bonds is being furnished a copy of this Limited Offering Memorandum, together with any supplements to this Limited Offering Memorandum. In addition, each prospective purchaser is hereby offered the opportunity, prior to purchasing any Bonds and at any time the Bonds are outstanding, to ask questions of, and receive answers from the Underwriter, the City and the Developer concerning the terms and conditions of the offering, and to obtain any additional relevant information, to the extent either possesses the same or can acquire it without unreasonable effort or expense. Inquiries concerning additional information should be directed in writing to the Underwriter at William Blair & Company, L.L.C., 222 W. Adams St., Chicago, Illinois 60606, Attention: Municipal Bond Department. LEGAL OPINIONS Legal matters incident to the authorization, issuance and sale of the Bonds are subject to the approving legal opinion of Foley & Lardner LLP, Chicago, Illinois, Bond Counsel. The proposed form of the opinion of Bond Counsel is included herein as "APPENDIX C Bond Opinion." Certain legal matters will be passed upon for the Underwriter by its counsel, Sonnenschein Nath & Rosenthal LLP, Chicago, Illinois; for the City, by its counsel, John Wyeth Esq., Yorkville, Illinois, and for the Developer by their counsel, Polsky & Associates Ltd., Chicago, Illinois. TAX EXEMPTION In the opinion of Foley & Lardner LLP, Bond Counsel, based upon an analysis of existing laws, regulations, rulings and court decisions, and assuming, among other matters, compliance with certain covenants, interest on the Bonds is excluded from gross income for federal income tax purposes under the Code and is not a specific preference item for purposes of determining an individual's or corporation's federal alternative minimum taxable income. However, Bond Counsel observes that interest on the Bonds 49 is included in adjusted current earnings in calculating federal corporate alternative minimum taxable income. Interest on the Bonds is not exempt from State of Illinois income taxes. ' I Bonds purchased, whether at original issuance or otherwise, for an amount greater than their principal amount payable at maturity (or, in some cases, at their earlier call date) ( "Premium Bonds ") will be treated as having amortizable bond premium. No deduction is allowable for the amortizable bond premium in the case of bonds, like the Premium Bonds, the interest on which is excluded from gross income for federal income tax purposes. However, the amount of tax exempt interest received, and a purchaser's basis in a Premium Bond, will be reduced by the amount of amortizable bond premium properly allocable to such purchaser. Thus, the amortization of Bond premium may have an effect on a Bondholder's recognition of gain or loss when a Premium Bond is sold or paid off. Beneficial Owners of Premium Bonds should consult their own tax advisors with respect to the proper treatment of amortizable bond premium in their particular circumstances. To the extent the issue price of any maturity of the Bonds is less than the amount to be paid at maturity of such Bonds (excluding amounts stated to be interest and payable at least annually over the term of such Bonds), the difference constitutes "original issue discount," the accrual of which, to the extent properly allocable to each Bondholder, is treated as interest on the Bonds which is excluded from gross income for federal income tax purposes. For this purpose, the issue price of a particular maturity of the Bonds is the first price at which a substantial amount of such maturity of the Bonds is sold to the public (excluding bond houses, brokers, or persons or organizations acting in the capacity of underwriters, placement agents or wholesalers). The original issue discount with respect to any maturity of the Bonds accrues daily over the term to maturity of such Bond on the basis of a constant interest rate compounded semiannually (with straight -line interpolations between compounding dates). The accruing original issue discount is added to the adjusted basis of such Bond to determine taxable gain or loss upon disposition (including sale, redemption, or payment on maturity) of Bonds. Beneficial Owners of the Bonds should consult their own tax advisors with respect to the tax consequence of ownership of Bonds with original issue discount, including the treatment of purchasers who do not purchase such Bonds in the original offering to the public at the first price at which a substantial amount of such Bond was sold to the public. Section 103 of the Code imposes various restrictions, conditions and requirements relating to exclusion from gross income for federal income tax purposes of interest on obligations such as the Bonds. The City has covenanted to comply with certain restrictions designed to insure that interest on the Bonds will not be included in a Bondholder's gross income for federal income tax purposes. Failure to comply with these covenants may result in interest on the Bonds being included in gross income for federal income tax purposes, possibly from the original issue date of the Bonds. The opinion of Foley & Lardner LLP assumes compliance with these covenants. Foley & Lardner LLP has not undertaken to determine (or to inform any person) whether any actions taken (or not taken) or events occurring (or not occurring) after the date of issuance of the Bonds may adversely affect the value of or the tax- exempt status of interest on the Bonds. Further, Foley & Lardner LLP does not give assurance that pending or further legislation or amendments to the Code, if enacted into law, will not adversely affect the value of or the tax exempt status of interest on the Bonds. Beneficial Owners are encouraged to consult their own tax advisors with respect to proposals to restructure the federal income tax. Certain requirements and procedures contained or referred to in the Indenture, the Bond Ordinance, the Tax Agreement and other relevant documents may be changed and certain actions (including, without limitation, defeasance of the Bonds) may be taken or omitted under the circumstance subject to the terms and conditions set forth in such documents. Foley & Lardner LLP expresses no opinion as to any Bond or the interest thereon if any such change occurs or action is taken or omitted upon advice or approval of bond counsel other than Foley & Lardner LLP. 50 Although Foley & Lardner LLP is of the opinion that interest on the Bonds is excluded from gross income for federal income tax purposes, the ownership or disposition of, or the accrual or receipt of interest on, the Bonds may otherwise affect a Beneficial Owner's federal or state tax liability. The nature and extent of these other tax consequences will depend upon the particular tax status of the Beneficial Owner or the Beneficial Owner's other items of income or deduction. Foley & Lardner LLP expresses no opinion regarding any such other tax consequences. No assurance can be given that any future legislation or clarifications or amendments to the Code, if enacted into law, will not cause the interest on the Bonds to be subject, directly or indirectly, to federal or state income taxation, or otherwise prevent the Bondholders from realizing the full current benefit of the tax status of the interest thereon. Further, no assurance can be given that any such future legislation, or any actions of the IRS, including, but not limited to, selection of the Bonds for audit examination, or the course or result of any examination of the Bonds, or other bonds which present similar tax issues, will not affect the market price for the Bonds. CONTINUING INFORMATION The Bonds are being initially issued in authorized denominations of $100,000 and integral multiples of $5,000 in excess thereof and are being offered to less than thirty-five (35) institutional investors. Accordingly, the Bonds will be exempt from the continuing disclosure requirements of Rule 15c2 12 adopted by the Securities and Exchange Commission under the Securities Exchange Act of 1934, as amended. Notwithstanding the City and the Developer have agreed to provide certain continuing information described below. The City The City has covenanted in the Indenture to furnish to the Trustee, the Underwriter and the Beneficial Owner of $500,000 or more in Bonds who so requests, within ten (10) days of receipt by the City, a copy of each annual audit of the City, the schedule of tenants and lease expiration dates therefor provided to the City by the Developer, any publicly available information received from the Illinois Department of Revenue of the Business District Sales Taxes and any abatement ordinance adopted by the City abating any of the Ad Valorem Taxes. The City will also provide to cause the Trustee to provide to the Underwriter or and to the Beneficial Owner of $500,000 or more in bonds who so requests, copies of any reports (including quarterly construction progress reports) or disclosure which the Developer provides to the City pursuant to the terms of the Development Agreement. The Developer Pursuant to the Development Agreement, the Developer obligated to provide certain information to the Trustee and the Underwriter. During construction of the Project, the Developer is required to deliver to the Trustee and the Underwriter quarterly construction progress reports. After construction of the Project has been completed, the Developer is required to furnish annually to the Trustee and the Underwriter a schedule of tenants and lease expiration dates for the Project properties. FINANCIAL ADVISOR Speer Financial, Inc., Chicago, Illinois ( "Speer Financial "), is serving as financial advisor to the City with respect to the sale of the Bonds. Speer Financial provides certain other financial and economic development consulting services to the City. 51 LIMITED OFFERING The Bonds are being offered only to sophisticated investors. Each prospective purchaser of the Bonds is being furnished a copy of this Limited Offering Memorandum, together with any supplements to this Limited Offering Memorandum. In addition, each prospective purchaser is hereby offered the opportunity, prior to purchasing any Bonds and at any time the Bonds are outstanding, to ask questions of, and receive answers from the Underwriter, the City and the Developer concerning the terms and conditions of the offering, and to obtain any additional relevant information, to the extent either possesses the same or can acquire it without unreasonable effort or expense. Inquiries concerning additional information should be directed in writing to the Underwriter at William Blair & Company, 222 West Adams Street, Chicago, Illinois 60606, Attention: Municipal Bond Department. NO LITIGATION The City At the time of delivery of and payment for the Bonds, the City will certify that there is no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, regulatory agency, public board or body, pending with respect to which the City has been served with process or is otherwise aware, or, to the knowledge of the officer of the City executing such certificate, threatened against the City affecting the existence of the City, the SSA or the titles of its officers to their respective offices or seeking to restrain or to enjoin the sale or delivery of the Bonds, the application of the proceeds thereof in accordance with the Bond Ordinance and/or the Indenture, or the collection or application of the Ad Valorem Tax, or in any way contesting or affecting the validity or enforceability of the Bonds, the Bond Ordinance, the Indenture, the Development Agreement, or any action of the City contemplated by any of the said documents, or the collection or application of the Ad Valorem Tax, or in any way contesting the completeness or accuracy of the Bond Ordinance, the Indenture or any amendments or supplements hereto, or contesting the powers of the City contemplated by any of said documents, nor, to the knowledge of the officer of the City executing such certificate, is there any basis therefor. The Developer At the time of delivery- of and payment for the Bonds, the Developer will certify that there is no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, government agency, public board or body, pending or threatened by or against the Developer: (i) in any way questioning the due formation and valid existence of the Developer; (ii) in any way questioning or affecting the validity of the Development Agreement or the consummation of the transactions contemplated thereby; (iii) in any way questioning or contesting the validity of any governmental approval of the Project or any aspect thereof, or (iv) which would have a material adverse effect upon the financial condition of the Developer or the ability of the Developer to develop the Project. NO RATING The City has not made, and does not currently contemplate making, an application to any rating agency for the assignment of a rating to the Bonds. 52 MISCELLANEOUS The references, excerpts, and summaries of documents and statutes contained in this Limited Offering Memorandum do not purport to be complete statements of the provisions of such documents and statutes, and reference is made to all such documents and statutes for full and complete statements of their terms and provisions. i The estimates, assumptions, statistical and financial information, and all other information contained in this Limited Offering Memorandum have been compiled from official and other sources believed by the underwriter to be reliable; however, none of such estimates, assumptions, or information is guaranteed by the City, the Developer, the Ad Valorem Tax Consultant, or the Underwriter as to completeness or accuracy. Any statement made in this Limited Offering Memorandum involving matters of opinion or of estimates, whether or not so expressly stated, is set forth as such and not as a representation of fact; no representation is made that any of the estimates contained herein will be realized. The information and expressions of opinion contained herein are subject to change without notice, and neither the delivery of this Limited Offering Memorandum nor any offer or sale made hereunder shall, under any circumstances, create any implication that there has been no change in the affairs of the City or the Project since the date hereof. I I I I II I I 53 AUTHORIZATION Both the City and the Developer have authorized the execution and distribution of this Limited Offering Memorandum. UNITED CITY OF YORKVILLE, an Illinois municipal corporation By: Arthur Prochaska, Mayor THE HARLEM IRVING COMPANIES, INC. By: Michael Marchese, President MID- AMERICAN INVESTMENT AND DEVELOPMENT BY: Michael Fersel, President 54 i APPENDIX A Trust Indenture 55 APPENDIX B i Development Agreement 14514220 \V -4 APPENDIX C Bond Opinion i i I 14514220 \V -4 APPENDIX D Appraisal i' 14514220 \V 4