Loading...
99-18 . . ; " ", " , ' ., . . ". . ,:, 'c :I' . , , , , . . . .~ ' , . , , (, . " . I,: .' . . .. . ., : , ~ , '. . " . , '~ ' ' . >.\... , L . . . t' . ' ..' RESOLUTIONS " ' >.. " ' ~" . , . , . . .. " ' , ' I' " ' . :. . '# ' ., I c',. , , o " ' , . . .' , " '.qq -Ii , i ! I I , I 1 , I ' CJ9 (1 ,.:) . '::J RESOLUTION NO. 99-18 A RESOLUTION AUTHORIZING THE ISSUANCE OF NOT TO EXCEED $35,000,000 AGGREGATE PRINCIPAL AMOUNT OF CITY OF CLEARWATER, FLORIDA REVENUE BONDS, SERIES 1999 (BEF, INC. PROJECT); PROVIDING FOR THE FORMS OF TRUST INDENTURE, LOAN AND SECURITY AGREEMENT, MORTGAGE AND SECURITY AGREEMENT AND ASSIGNMENT OF MORTGAGE; APPROVING AND AUTHORIZING EXECUTION OF TRUST INDENTURE AND LOAN AND SECURITY AGREEMENT AND ASSIGNMENT OF MORTGAGE AND SECURITY AGREEMENT; APPROVING BOND PURCHASE AGREEMENT RELATING TO THE NEGOTIATED SALE OF THE BONDS TO THE UNDERWRITERS; APPOINTING A TRUSTEE, REGISTRAR AND PAYING AGENT WITH RESPECT TO THE BONDS; AUTHORIZING THE DISTRIBUTION OF AN OFFICIAL 5T A TEMENT IN CONNECTION WITH THE ISSUANCE AND DELIVERY OF SUCH BONDS; PROVIDING FOR AND AUTHORIZING THE DELEGATED SALE OF SUCH BONDS; PROVIDING APPROVAL AS REQUIRED BY SECTION 147(F) OF THE INTERNAL REVENUE CODE OF 1986, AS AMENDED; AND PROVIDING AN EFFECTIVE DATE. WHEREAS, the City Commission of the City of Clearwater, Florida (the "Issuer") by this Res0lution (the uResolutionU) and as authorized by Ordinance No. 6370-99 (the "Ordinance"), expresses its agreement as to the issuance of the Issuers Revenue Bonds, Series 1999A, Series 1999B and Series 1999C (BEF, Inc. Project) (the "Bonds"), in the aggregate principal amount of not to exceed $35,000,000, for the purpose stated in the Ordinance for the benefit ofBEF, Inc., a Florida not for profit corporation (the UCompany") and providing for other matters consistent therewith; and WHEREAS, the Issuer desires to approve the forms ofTnist Indenture, Loan and Security Agreement, Mortgage and Security Agreement and Assignment of Mortgage and Security Agreement to be executed in connection with the issuance of the Bonds; and . WHEREAS, the Issuer wishes to approve the fonn of the Official Statement and to authorize distribution thereof in connection with the issuance and delivery of its Bonds; and Resolution 99-18 :') WHEREAS, the Issuer intends to negotiate the sale ofthe Bonds as hereinafter provided with B. C. Ziegler and Company (the "Underwriter") pursuant to a Bond Purchase Agreement; and WHEREAS, the Financial Services Administrator, as designee of the Deputy City Manager of the Issuer, conducted a public hearing on February 23, 1999, notice of which hearing was published on February 9, 1999, in the St. Petersburg Times (a copy of which notice is attached hereto as Exhibit UG" and incorporated herein), for the purpose of considering the issuance of the Bonds by the Issuer, in accordance with the requirements of Section 147(t) of the Internal Revenue Code of 1986, as amended (the "Code"), and said public hearing disclosed no reason why the Bonds should not be issued; and WHEREAS, Section 147(f) of the Code requires approv~ of the issuance of the Bonds by the City Commission of the Issuer as the uapplicable elected representative" under Section 147(f) ':) after a public hearing following reasonable public notice~ and WHEREAS, the Issuer now desires to provide for the form of the foregoing documents to facilitate the issuance and delivery of the Bonds. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COMMISSION OF THE CITY OF CLEARWATER, FLORIDA, as follows: SECTION 1. In accordance with the Ordinance, there is hereby authorized and directed to be issued the Issuer's Revenue Bonds, Series 1999A, Series 1999B and Series 1999C (BEF, Inc. Project) (the "Bonds"), in the aggregate principal amount of not to exceed $35,000,000. The Bonds shall be issued under and secured by the Indenture referred to below which by reference is hereby incorporated in this Resolution as if set forth in full herein. The Bonds shall mature in the amounts and at the times, shall bear interest at the rates, be redeemable at the redemption prices and upon the J 2 Resolution 99-18 _!lIIIo"l-oI....,...~....r....,~~ '~ terms as shall be set forth in the Indenture (as hereinafter defined) and in the Bond Purchase Agreement (as hereinafter approved). The Bonds shall be executed. authenticated and delivered by the officers of the Issuer authorized below in substantially the form set forth in the Indenture in fully registered form. SECTION 2. The Trust Indenture (the "Indenture"). in substantially the form attached hereto as Exhibit "AU. is hereby approved, and the Mayor-Commissiot).er, City Manager and Clerk of the Issuer are hereby authorized and directed to execute and deliver the Indenture upon the approval thereof as to form and legal suffici~ncy by the City Attorney, on behalf of and in the name of the Issuer with such additional changes, insertions and omissions therein including. but riot limited to. the insertion of rates, maturities and other details of the Bonds detennined as herein provided and as may be made prior to the delivery of the Bonds, and as may be otherwise made and approved by the said "') officers of the Issuer executing the same, such execution to be conclusive evidence of such approval. In connection with the delivery of the Indenture and the issuance of the Bonds, the Issuer hereby approves the delivery of a Mortgage and Security Agreement by the Company to the Issuer in substantially the form attached hereto as Exhibit "B". SECTION 3. The Loan and Security Agreement in substantially the form attached hereto as Exhibit "e" (the "AgreementU) and the Assignment of Mortgage And Security Agreement in sub- stantialIy the form attached hereto as Exhibit "Du (the "Assignment"), are hereby approved, confirmed and ratified and the Mayor-Commissioner. City Manager and Clerk are hereby authorized and directed to execute and deliver the Agreement and the Assignment upon the approval thereof as to form and legal sufficiency by the City Attorney, on behalf of and in the name of the Issuer with such additional changes, insertions and omissions therein as implement the provisions of the Bond .:) 3 Resolution 99-18 ~'L~";i"~-.#"'"' , ..~ Purchase Agreement (hereinafter mentioned), and as may be otherwise made and approved by the . said officers of the Issuer executing the same. such execution to be conclusive evidence of such approval. SECTION 4. It is hereby found and detennined that due to the complexity of the financing and the need to coordinate matters among the Issuer, the Company and Bond purchasers, it is in the best interest of the Issuer to negotiate the sale of the Bonds. The disclosure required by Section 2] 8.385, Florida Statutes, as amended, shaH be provided to the Issuer. as evidenced by a schedule attached to the Bond Purchase Agreement hereinafter described, wherein the Underwriter agrees to provide disclosure to the Issuer prior to execution by the Issuer of the Bond Purchase Agreement. The negotiated sale of not to exceed $35,000,000 City of Clearwater. Florida Revenue Bonds, Series 1999A, Series 1999B and Series 1999C (BEF. Inc. Project) is hereby approved to the Underwriter ':) upon the terms and conditions set forth in the Bond Purchase Agreement, which is hereby approved in substantially the form attached hereto as Exhibit "E". The Bond Purchase Agreement, with such changes. alterations and corrections as may be approved by the City Manager and Financial Services Administrator of the Issuer. such approval to be presumed by the Issuer's execution thereof: is hereby approved by the Issuer, and the Issuer hereby authorizes the Mayor~Cornmissioner and City Manager of the Issuer to execute and deliver (attested by ~he Clerk of the Issuer and approved as to form and ~ '~"', ,. 0 ... .., "c> legal sufficiency by the City Attorney), said Bond Purchase Agreement in the name of and on behalf of the Issuer. all of the provisions of which, when executed and delivered by the Issuer as authorized herein shall be deemed to be a part of this instrument as fully and to the same extent as if incorporated verbatim herein. The Bonds are hereby sold to the Undenvriter in the amount, at the price and upon .J 4 Resolution 99~ 18 :~...., ) J the final terms set forth in the Bond Purchase Agreement subject to the conditions set forth in the next paragraph. The City Manager and Financial Services Administrator are hereby authorized to award the sale ofthe Bonds to the Underwriter under the Bond Purchase Agreement so long as the net interest cost for the Bonds (detennined based on the initial interest rates at closing) does not exceed 7.50 % per annum, the Underwriter's discount is not in excess of 4.0%, and the final maturity date of the Bonds is not later than the year 2035, without need of further authorization of the Issuer. SECTION 5. The Issuer hereby approves the Preliminary Official Statement, relating to the Bonds in substantially the fonn attached hereto as Exhibit "Ft' and authorizes the use and distribution by the Underwriter of said Prelirninwy Official Statement and a Final Official Statement relating to the Bonds with such revisions as shall hereafter be approved by the Mayor-Commissioner, City Manager or Financial Services Administrator of the Issuer and, with such approval and authorization, the distribution of such Final Official Statement by said Underwriter in connection with the sale and issuance of the Bonds. The Financial Services Administrator of the Issuer is hereby authorized to deem the Preliminary Official Statement "nearly final" on behalf of the Issuer, as required by Rule 1 Sc2-l2 of the Securities Exchange Commission. SECTION 6. With respect to the Bonds, SunTrust Bank, Central Florida, National Association, is hereby appointed as Trustee, Registrar and Paying Agent pursuant to the Indenture. SECTION 7. The Issuer, pursuant to, and in accordance with, the requirements set forth in Section 147(f) of the Code, hereby approves the issuance of the Bonds. SECTION 8. All prior resolutions and motions of the Issuer inconsistent with the provisions of this Resolution are hereby modified, supplemented and amended to conform with the provisions 5 Resolution 99~18 "} herein contained and except as otherwise modified, supplemented and amended hereby shall remain in full force and effect. SECTION 9. To the extent that the Mayor-Commissioner, City Manager or the Clerk of the I, 1 Issuer are unable for any reason to execute or deliver the documents referred to above, such documents may be executed, attested andlor delivered by the Vice-Mayor or any other Commission Member of the Issuer or by an ~istant City Manager or an assistant or deputy Clerk, with the same effect as if executed andl or delivered by the Mayor-Commissioner, City Manager or Clerk. SECTION 10. The Mayor and the Clerk and all other Commission members of the Issuer and the staff of the Issuer are hereby authorized and directed to execute any and all certifications or other instruments, agreements or documents required by the Indenture, the Agreement, the Bond Purchase Agreement, Bond Counselor any other document referred to above as a prerequisite or precondition .) to the issuance of the Bonds and any representation made therein shall be deemed to be made on behalf of the Issuer. All action taken to date by the members of the Issuer and the staff of the Issuer in furtherance of the issuance of the Bonds is hereby approved, confirmed and ratified. SECTION 11. Notwithstanding anything in this Resolution to the contrary, if at any time subsequent to the adoption of this Resolution and prior to the date the Bond Purchase Agreement '. '. is executed by the City, the City Attorney determines, based on advice from the City's Financial , .,., ~I ~.,' . " Services Administrator, the City's Bond Counsel andlor the City's Financial Advisor, that financial, legal or tax issues related to the Bonds remain unresolved, then the Bond Purchase Agreement otherwise authorized by this Resolution shall not be executed without further action by the City Commission or unless the City Attorney determines based on advice from the Citis Financial 'J 6 Resolution 99-18 ~~::!- :~~::":':"':"':'_':'-""',"",_____'_ n'..'~ , I ' .',' , , . ',i.,:/ ' /. '.: . ',1 .,,' ,', ,1 ~.. ;. ~ ,-rl- c , , ,:.:,. ~.....->~ ..... c '/", "t'" C ''''"' , _. \., ,.v' }; , .,>, V ....,". . ~':A;: ~ :~...'-: I ' ," I:) ....~ r..;:.:" , c\:. , \'". ,., ~ 10", ., 'f/< ',' .;' .. }.J..,;~.,;~~~ l\:,~' ,> iv:~" " . t.\,; . . '. ~ i'~ ( , ,"i" ", '::, , ~~'!" . v . .t.;. ~'{ , :'.~.;>~, 'c" , : " " > ~ , "- :,' l"; :'. ;~~1~~. ':.~ j '," . .,';" , .,. ' ,c, I',. , '0 :: '/, > ',:.: ": i ' .,' , ,', :' '" [. ?;\' c(,', '.. (~...,\ ~"4 ~ , . ",.':T ' ", ' LA:,,'. C",: : ' ! ~ -' " . ,~':, " , ~,t ::'. ~ ',' , . , !. , :1 " . ,,' .,' ,. . Services ,Administrator, the City's ,~ond Counsel and/or the C~ty's Financial Advisor that such financial. legal or tax issues l1ave been resolved. i, SECTION 12. This Resolution shall become effective immediately upon its adoption. I, '.' ,; '. . ~ .....;"t, .' l ',.,~".... - 7, Resolution 99-18 '~' , ,. t~. ' ' f/:>:f':'{;':.~?;:><" ;,:.- ~ I... ., . ::. ,\..' 1 " , . ~ " , ,.0 ' ., , , "~" I ~ ". , .~' " .,..'.. ~ Passed and adopted by the'City Commission of the City ofClenrwater, Florida, thls11!ltlay of' June, 1999. , ' (SEAL) By: j,.C ~: ATTEST: V )., ~, ' , y . " . i'." " . ,(:: . ,Ii ~6'; City,C'ser r~, , ,/ . ~.. ' '. .:'\~ ' , ' '~C . Approved as to form and correctness: . ~ ',' ;,.,:,'. !!, ' I.J City Attorney '~ ,J' "i -:, ~,.<J' . , .'. ".J' , ,~ ... . .u '. ':'''',\ \..,..J 8 Resolution 99~ 18 ',;1 ~, . ,~, f ". .. 1,li,:';," ~ ,i ,:.~:.~,~\.,..t....:';..,\.'.:.'.<:~'~'::'I\ : . :".,:~.':..'< . ..t~ , j"', ...,. ,~ ' . ~.t... ," ':~.: ,....~,i:>.:,~, '.. ~ ;. )~~,'i.. '. f " ~'I ' ;. ,." , ,. , ~ ' 1::, ,. ? ': .~. ~ .~ ',> , ;;\' '.:.;~ ~ ~. ~~~;,~1' EXHIBIT A t> FORM OF TRUST INDENTURE J. , "I :.:.~: ' ~', ' fo:" ~' : :i>. ( j " i;',: ~", ~,:' ~L ~,,~i'" :,' n,;:.. ,"'" I~', ~; ... {., 't.'. ,', r'::~i""" " . \,/ ~P'" .- '1<' :, ~;' ' I,,::, ,. H ,..~ . 1.....;,1 :, .,::.:... . ~ .. l t.: , , i" i, .'. , ::> ..'.'a"- . . ~ <:. , '..l :,.j , ,. t".. .1-... ,Ie: ':' ~ .J,.' . tj;i; ~;;,;:,<;. "(J:~~"Li'{"~~'':f;::;i';,,;~,:</ ;~"~'i:.:':,.,:,../i: '.::' :.: :":..~;:'::, ":"".: ::"~" );,;,; ,'., . .::;!"; '/":;';:" .' ,:::,., " .,::', "" ,;,. ;,,,,,., ~,),~~fIt1EI':\.1l~fbl\~:" ,::b?,\.~0P""';jC;,.f,~ .!. " I ,.,,1:(:., . .1' \ ,','1"' " ",J" ,,,,:.., '. '" . .{, ~k'..r':"'" .'~ ".l\,~i' 'f~ ,',J",,: .,;;, d,.:~~~~~::'~"~.~':,.W~l!;..)If'.~(~;J",:':ii~f{,f'~I~o'::' .,c:."~',>"'~' ln" '". +': ,'.T';-+ ,'~,,":. .~. >'~~'"'' ;'~.,",' :;'.tY":;.',oV;"';,!', '/.; -'.~, ' . ,'" .~ " .. .~~,,:1 :~ ~';" ~~~: ~ ,':~ ',~ ~;~:' ~: I~'~ ~ ': . f..~, . :'"f :L , Res'olution 99~18 , t.4. ~>I::' I~:~L;~~~ ;::,:/',i."!~: ~.,: ,,"~ ~ ' . ' -:t" ">, ,c'c' '..., '1 ~'I ,"" I. ;: :) 'J " ~.. ~: ., Draft #4 OS/28/99 BMO #3195 TRUST INDENTURE' between CITY OF CLEARWATER, FLORIDA and SUNTRUST BANK, CENTRAL FLORIDA, NATIONAL ASSOCIATION, as trustee City of Clearwater, Florida Revenue Bonds . (8EF, Inc. Project) Dated as of July 1, 1999 %. 19-/~ :1 .1 j! 'J SECTION 1.01. SECTION 1.'02. SECTION 1.03. SECTION 2.01. SECTION 2.02. SECTION 2.03. SECTION 2.04. SECTION 2.05. SECTION 2.06. ,,M) .... . SECTION 3.01. SECTION 3.02. SECTION 3.03. SECTION 3.04. SECTION 3.05. SECTION 3.06. SECTION 3.07. SECTION 3.08. SECTION 3.09. TABLE OF CONTENTS ARTICLE I DEFINIT[ONS Definitions ..... t . . + , . . . + I . . . ... . . . II . .. . I . . " -II . . 5 Interpretation . . . . .. . . .. . . . . I' . . . . .. , . . . . . . . . . . . . 23 Captions and Headings . . . . . . . . . . . . . . . . . . . . . . . . . 23 ARTICLE II AUTHOR[ZA TION AND TERMS OF SERIES 1999 BONDS; ADDITIONAL BONDS Authorized Amount of Series 1999 Bonds . . . . . . . . . . . . . 24 Issuance of Series 1999 Bonds . . . . . . .'. . . . . . . . . . . . . 24 Terms o(Series 1999 Bonds ..................... 24 Delivery of Series 1999 Bonds; AlIc:>cation of Proceeds of the Series 1999 Bonds; Company Equity Contribution. . . . . . . . . . . . 26 Issuance and Delivery of Additional Bonds . . . . . . . . . . . . 27 Issuance and Delivery of Notes ................... 29 ARTICLE [II TERMS OF BONDS GENERALLY Fonn of Bonds , , I . . . . . . I . . . . . . . . . . ,.. . . . .. .. .. . . .. 30 Variable Terms ......'....................... 30 Execution and Authentication of Bonds .............. 30 Security for Payment of Bonds . . . . . . . . . . . . . . . . . . . . 31 Payment and Ownership of Bonds . . . . . . . . . . . . . . . . . . 31 Transfer and Exchange of Bonds .................. 32 Mutilated, Lost, Wrongfully Taken or Destroyed Bonds. . . . 33 Safekeeping and Cancellation of Bonds .............. 34 Temporary Bonds . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 ARTICLE IV REDEMPTION OF BONDS; TENDER PROVISIONS SECTION 4.01. SECTION 4.02. SECTION 4.03. SECTION 4.04. SECTION 4.05. ,::) ~ ",:,~""\\,,;\.,:;.~\,,,,', ,c~~.~:,' ". ".' '. Mandatory Sinking Fund Redemption of Series 1999 Bonds . 36 Extraordinary Redemption Without Premium. . . . . . . . . . . 37 Optional Redemption of Series 1999 Bonds . . . . . . . . . . . . 37 Partial Redemption ... . . . . . . . . . . . . . '. . . '. . . . . . . . 38 Company's Election to Redeem . . . . . . . . . . . . . . . . . . . 38 -:;res. '19-1 f , ' ~, . '. ,) , ,. SECTION 4.06. SECTION 4.07. 'SECTION 4.08. SECTION 4.09. SECTION 4.10. SECTION 4.11. SECTION 4.12. SECTION 4.13. SECTION 4.14. SECTION 4.15. SECTION 4.16. J SECTION 5.01. SECTION 5.02. SECTION 5.03. SECTION 5.04. SECTION 5.05. SECTION 5.06. SECTION 5.07. SECTION 5.08. SECTION 5.09. SECTION 5.10. SECTION 5.11. SECTION 5.12. Notice of Redemption ...................,..... 38 Payment of Redeemed Bonds . . . . . . . . . . . . . . . . . . . . . 40 Variation of Redemption Provisions ................ 40 Series 1999B Bond Holders Put Option .............. 40 Moneys to Purchase Series 1999B Bonds; Duties of Tender Agent . . . . . . . . :'. . . . . . . . . . . . . . . . . . . . . . . , . . . . . . 42 Failure to Remarket Tendered Series 1999B Bonds . . . . . . . 43 Remarketing of Series 1999B Bonds ........ . . . . . . . . 43 Delivery of Series 1999B Bonds and Proceeds of Sale . . . . . 43 No Purchases or Sales After Event of Default . . . . . . . . . . 44 Remarketing Agent . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 Resignation of Remarketing Agent ................. 45 ARTICLE V FUNDS AND PAYMENTS Creation of Funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 Application of Loan Payments and Additional Payments ... 46 Bond Fund ........,....................... 10 .. . . It . 48 Project Fund ... Ii .. . . . . . . .. . . . . . . . . ,. .. . . . _ . ,. , . . 48 Rebate Fund ...... II .. .. . . . . II ,. . , ... . .. .. ,. .. . . It .. .. . . . 49 Debt Service Reserve Fund . . . . . . . . . . . . . . . . . . . . . . 50 Moneys to be Held in Trust . . . . . . . . . . . . . . . . . . . . . ~ 51 Nonpresentment of Bonds. . . . . . . . . . . . . . . . . . . . . . . 51 Application of the Balances of the Special Funds ........ 51 Investments of Special Funds and the Rebate Fund . . . . . . . 51 Valuation .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 Repayment to the Company . . . . . . . . . . . . . . . . . . . . . . . 3 ARTICLE VI TRUSTEE, REGISTRAR, PA YING AGENTS, AUTHENTICATING AGENTS AND TENDER AGENTS SECTION 6.01. SECTION 6.02. SECTION 6.03. SECTION 6.04. SECTION 6.05. SECTION 6.06. SECTION 6.07. SECTION 6.08. SECTION 6.09. 'J Trustee's Acceptance and Responsibilities. . . . . . . . . . . . . 54 Certain Rights and Obligations of the Trustee .......... 55 Fees, Charges and Expenses of Trustee. Registrar, Tender Agents, Paying Agents, Remarketing Agent and Authenticating Agents 59 Intervention by Trustee ........................ 59 Successor Trustee . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 Appointment of Co-Trustee. . . . . . . . . . . . . . . . . . . . . . 60 Resignation by the Trustee ...................... 61 Removal of the Trustee ........................ 61 Appointment of Successor Trustee ................. 62 ii 'i?es. CJC{-/'l 1 " SECTION 6.10. SECTION 6.11. SECTION 6.12. SECTION 6.13. SECTION 6.14. SECTION 6.15. SECTION 6.16. SECTION 6.17. SECTION 6.18. .-) -' SECTION 7.01. SECTION 7.02. SECTION 7.03. SECTION 7.04. SECTION 7.05. SECTION 7.06. SECTION 7.07. SECTION 7.08. SECTION 7.09. SECTION 7.10. SECTION 7.11. Adoption of Authentication . . . . . . . . . . . . . . . . . . . . . . 63 Registrars t t , , . . . . . ... t- . 4 .. . , . . . . .. . ,. -t .. . . . . + .. . -t 63 Designation and Succession of Paying Agents .......... 65 Designation and Succession of Authenticating Agents ..... 65 Designation and Succession of Tender Agents . . . . . . . . . . 66 Dealing in Bonds ............................ 67 Representations, Warranties, Covenants and Agreements of Trustee . . .. . . III II . .. . I . , ., . , . . . . . t .. . ... It . . . . .. . t . . . . . . 67 Right of Trustee to Pay Taxes and Other Charges . . . . . . . . 68 Several Capacities. . . . . . . . . . . . . . . . . . . . . . . . . . . . 68 ARTICLE VII DEFAULT PROVISIONS AND REMEDIES OF TRUSTEE AND HOLDERS Defaults; Events of Default. . . . . . . . . . . . . . . . . . . . . . 69 Notice of Default .. . . . . . . . . . . . . . . '. . . . . . . . . . . . 69 Acceleration II............,........................ II . . . . 70 Matters Regarding Rights, Remedies and Powers . . . . . . . . 70 Right of Holders to Direct Proceedings .............. 71 Appointment of Receivers . . . . . . . . . . . . . . . . . . . . . . . 72 Application of Moneys . . . . . . . . . . . . . . . . . . . . . . . . . 72 Rights, Remedies and Powers Vested in Trustee. . . . . . . . . 74 Rights, Remedies and Powers of Holders . . . . . . . . . . . . . 74 Termination of Proceedings. . . . . . . . . . . . . . . . . . . . . . 75 Waivers It.. . It .. . .. . . ... . . .. .. I . . II . ill . . . .. . . . .. ... It. . 75 ARTICLE VIII SUPPLEMENTAL INDENTURES AND AMENDMENTS TO ISSUER DOCUMENTS SECTION 8.01. SECTION 8.02. SECTION 8.03. SECTION 8.04. SECTION 8.05. SECTION 8.06. SECTION 8.07. SECTION 8.08. SECTION 8.09. J Supplemental Indentures Generally . . . . . . . . . . . . . . . . . 77 Supplemental Indentures Not Requiring Consent of Holders . 77 Supplemental Indentures Requiring Consent of Holders . . . . 78 Consent of the Company ....................... 80 Authorization to Trustee; Effect of Supplement ......... 80 Opinion of Counsel . . . . . . . . . . . . . . . . . . . . . . . . . . . 81 Amendments to the Company Documents Not Requiring Consent of Holders ..,...... ~ It . , . II- . II- . . . . . .. . . . . . ;. Ii . . . I . 81 Amendments to the Company Documents Requiring Consent of Holders 1'................. Ii . . . + , . . . . . . ;. It . . . 82 Moditication by Unanimous Consent . . . . . . . . . . . . . . . . 82 Hi *es. 9q-/~ ,j . i SECTION 9.01. SECTION 9.02. SECTION 9.03. ARTICLE IX DEFEASANCE Release of Indenture .......... . . . . . . . . . . . . . . . . 83 Payment and Discharge of Bonds .. . . . . . . . . . . . . . . . . 84 Survival of Certain Provisions . . . . . . . . . . . . . . . . . . . . 86 ARTICLE X COVENANTS, AGREEMENTS, REPRESENTATIONS AND WARRANTIES OF THE ISSUER SECTION 10.01. Covenants and Agreements of the Issuer. . . ',' . . . . . . . . . 87 SECTION 10.02. Observance and Perfonnance; Representations and Warranties SECTION 10.03. Enforcement of Issuer's Obligations ................ 88 . . . . ... ... t I . . ... . .. ... . . '" . ... . . . .. . ... . .. . . . . ... . , ... .. ... .. .. 88 "') SECTION 11.01. SECTION 11.02. SECTION 11.03. SECTION 11.04. SECTION 11.05. SECTION 12.01. SECTION 12.02. SECTION 12.03. SECTION 12.04. SECTION 12.05. SECTION 12.06. SECTION 12.07. SECTION 12.08. SECTION 12.09. SECTION 12.10. SECTION 12.11. SECTION 12.12. SECTION 12.13. SECTION 12.14. " ~ ARTICLE XI MEETINGS OF HOLDERS Purposes of Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . 89 Call of Meetings; Place of Meetings ................ 89 Meetings; Regulations of the Trustee . . . . . . . . . . . . . . . . 89 Voting; Speaking at Meeting; Record of Meeting . . . . . . . . 90 Miscellaneous ...........................'... 90 ARTICLE XII MISCELLANEOUS Limitation of Rights .......................... 92 Severability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92 Nocices . . . . '" .. ~ , . . ... . ... . . . . . ... . . . .. .. .. ... . . . . ... . . . .. 92 Suspension of Mail ...... . . . . . . . . . . . . . . . . . . . . . 93 Payments Due on Saturdays, Sundays and Holidays ...... 94 Ihstruments of Holders . . . . . . . . . . . . . . . . . . . . . . . . . 94 Company to be Bound; Company's Actions ........... 95 Execution Counterparts ........................ 95 SurvivaJ of Representation and Warranties ............ 95 Validity of Assignments and Security Interest ....... " . . 95 Extent of Covenants; No Personal Liability. . . . . . . . . . . . 96 Binding Effect . . . . . . . . . . . . . . . . . . . . . . . .'. . . . . . 96 Captions ~ . Ii . Ii . . . . . . ... . . ;. . , . . t . . . . t . . . . Ii . . . . 96 Governing Law ............................. 96 iv &5. qq-/8' I , ~.. +t " !':, ;,t: . ~ l ' .' .' . l .' , , t : ',l.,". ~ijo 1I.ttl,~Z": " , . .,::~ ! ~ .' ~:~'fl.~J I':.. i'~ I' ....~. ' ~i ). " ~.~;. ~.:: ~ l ' !.I< : ,Co ',? c . .;', '. " ' ;<', ~ > ,~ c i:,-' ~.. " ',' ~., , . . ..,....". . ~ " ; '... ; ~. ' "2) . .fc' i, ~. .. ,~. ~ h. ~."" \,' ~\i~ (.<,'. ". '..~ II..;U'l.':~ ,~~ ....'~'.., . . .' ~ ... EXHIBIT A ,EXHIBIT B .'. " ' Bond Forin Form of Inv'estor Letter ~ ( v 7?es. 99- /f6 --<illl<I ~ TRUST INDENTURE THIS TRUST INDENTURE dated as of July I, 1999 (the "Indenture"), is made between the CITY OF CLEARWATER, FLORIDA, a municipal corporation, duly created and existing under the laws of the State of Florida (the "Issuer"), and SUNTRUST BANK, CENTRAL FLORIDA, NATIONAL ASSOCIATION, as trustee, located in Orlando, Florida, national banking association duly organized and validly existing under the laws of the United States of America, and authorized to exercise trust powers under the laws of the State of Florida (the "Trustee"), under the circumstances summarized in the following recitals (the capitalized tenns not defined in the recitals and granting clauses are defined in Article I hereof): "'-.") ,../ WHEREAS, pursuant to the Florida Constitution, the Charter of the Issuer and laws of the State of Florida, particularly Chapter 159, Part II and III, Chapter 166 and Chapter 154. Florida Statutes, and other applicable provisions of law, the Issuer is authorized to make and execute financing agreements, contracts and other instrum~nts necessary or convenient for the purpose of facilitating the financing of certain projects, including machinery, equipment, land, rights in land and other appurtenances and facilities related thereto, to the end that the Issuer may be able to promote the health and safety of the inhabitants of the Issuer or industrial development and the people of Pinellas County and the State of Florida by increasing their access to adequate medical care and health care facilities, and to provide such financing through the issuance of revenue bonds; and WHEREAS, BEF, Inc. (the IlCompany") is a not-far-profit corporation organized and existing under the laws of the State of Florida, licensed under Chapter 400 of the Florida Statutes, as amended, which is engaged in the operation of the skilled nursing facilities at the Project and which will be engaged in the operation of assisted living and independent.1iving facilities at the Project; and WHEREAS, the Issuer has determined to issue its $ aggregate principal amount of Revenue Bonds, Series 1999A (BEF, Inc. Project) (the "Series 1999A Bonds"), $ aggregate principal amount of Revenue Bonds, Series 1999B (BEF, Inc. Project), Extendable Rate Adjustable SecuritiesSM (EXTRASSM) (the 'tSeries 1999B Bonds") and $ aggregate principal amount of Taxable Revenue Bonds, Series 1999C (BEF, Inc. Project) (the "Series 1999C Bonds" and together with the Series 1999A Bonds and the Series 1999B Bonds, the ttSeries 1999 Bonds") for the principal purpose of financing the Project Costs, as more particularly described in the Agreement; and WHEREAS, the Series 1999 Bonds and any Additional Bonds (collectively, the "Bonds") to be issued under this Indenture do not constitute a debt or a pledge of the faith and credit of the Issuer, the State of Florida or any political subdivision or agency thereof and the holders or Holders of the Bonds shall have no right to have taxes levied by the Issuer, the State of Florida or any political subdivision or agency thereof for the payment of principal of or interest or any ,~ 1 ~5 . crt --I rs '} 'J ,~ .-~::"~.. .< premium on the Bonds (although the Issuer has taxing power. it is prohibited by Section 159.34. Florida Statutes, from using any funds of the Issuer to pay debt service or the Series 1999 Bonds); and WHEREAS, the proceeds of the sale of the Series 1999 Bonds will be loaned to the Company and the Company will be obligated pursuant to the Agreement and the Series 1999 Note to repay that loan, and the Company's repayment obligation will be secured by the Mortgage, which will be assigned (other than the Unassigned Rights thereunder) to the Trustee by the Assignment; and WHEREAS, the Issuer is authorized to execute and deliver this Indenture and to observe and perfonn all covenants, agreements and obligations to be observed or performed on its part hereunder; and WHEREAS, the execution and delivery of this Indenture has been duly authorized by the Issuer; and WHEREAS, all acts and conditions required to happen, exist and be performed precedent to and in the issuance of the Series 1999 Bonds and the execution and delivery of this Indenture have happened, exist and have been performed, or at the delivery of the Series 1999 Bonds will exist, will have happened and will have been observed or performed, (i) to make the Series 1999 Bonds, when issued, authenticated and delivered, legal, valid and binding special obligations of the Issuer in accordance with the terms of the Series 1999 Bonds and this Indenture, and (ii) to make this Indenture a legal and valid trust agreement for the protection of the Bonds and the Holders in accordance with its terms; and WHEREAS, the Trustee has accepted the trusts created under this Indenture, and the Registrar has accepted its obligations under this Indenture, and in evidence thereof, this Indenture has been executed and delivered thereby; NOW, THEREFORE, THIS INDENTURE WITNESSETH, that (a) to assure (i) the payment of the Debt Service Charges on the Bonds according to the true intent and meaning of the Bonds, and (ii) the observance and performance of all of the covenants, agreements, obligations, terms and conditions contained in the Bonds and herein; (b) to declare the terms and conditions upon and subject to which the Bonds are and are intended to be issued, held, protected and enforced; and (c) in consideration of the premises, the acceptance by the Trustee of the trusts created herein. the purchase and acceptance of the Series 1999 Bonds by the Holders. and other good and valuable consideration, the receipt of which is acknowledged hereby; 2 ~s. q9-/~ ) " , ", ._) \ 'J .........~ ~.. ..... .. the Issuer has executed and delivered this Indenture. and does hereby transfer and irrevocably and absolutely assign to the Trustee, and grant to the Trustee a security interest in, all right, title and interest of the Issuer in and to: (i) the funds and accounts created under this Indenture and all moneys and investments therein, except for amounts on deposit in the Rebate Fund and investment income thereon whkh are hereby pledged to the United States of America to secure the obligation of the Company and the Issuer to make payments of the Rebate Amount pursuant to Section 148(0 of the Code; (ii) the Agreement. other than "Unassigned Rights"; (Hi) the Loan Payments and the Additional Payments, excepting Additional Payments made pursuant to Section 4.2 (a) of the Agreement; (iv) the Series 1999 Note; (v) the Mortgage; and (vi) any and all other real or personal property of every name and nature from time to time hereafter by delivery or by writing of any kind assigned, pledged or transferred, as and for additional security hereunder by the Issuer or by anyone on its behalf, or with its written consent, to the Trustee, which is hereby authorized to receive any and all such property at any and all times and to hold and apply the same subject to the terms hereof. TO HAVE AND TO HOLD unto the Trustee and its successors in that trust and its and their assigns forever; BUT IN TRUST, NEVERTHELESS, and subject to the provisions hereof, (a) except as provided otherwise herein, for the equal and proportionate benefit and protection of all present and future Holders of the Bonds issued or to be issued under this Indenture; (b) for the enforcement of the payment of the Debt Service Charges on the Bonds, when payable, according to the true intent and meaning' thereof and of this Indenture; and (c) for the enforcement of the observance and performance of the covenants, agreements, obligations, terms and conditions of this Indenture, in each case, without preference, distinction or priority of any Bond over any other by reason of designation, number, date of the Bonds, date of authorization, issuance, sale, execution, 3 H e5. Cfl-;?5 :~ , I ') \ J ~.r.I-4<-.~" authentication. delivery or maturity thereof, or otherwise, so that each Bond and all Bonds have the same right, protection and privilege under this Indenture, and arc protected equally and ratably hereby. it being intended that this Indenture take effect from the date hereof, without regard to the date of actual issue, safe 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 if (i) the principal of the Bonds and the interest due or to become due thereon, together with any premium required for redemption of any of the Bonds prior to maturity, shall be paid well and truly, 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 Article IX hereof, and (ii) all of the covenants, agreements, obligations, terms and conditions of the Issuer under this Indenture shall have been observed and performed. and there shall have been paid to the Trustee, the Registrar, the Paying Agents and the Authenticating Agents all sums of money due or to become due to them in accordance with the terms and provisions hereof, then this Indenture and the rights assigned hereby shall cease, determine and be void, except as provided in Section 9.03 hereof with respect to the survival of certain provisions hereof; otherwise, this Indenture shall be and remain in full force and effect. IT IS DECLARED that all Bonds issued hereunder and protected hereby are to be issued, authenticated and delivered in accordance with the covenants, agreements, obligations, terms and conditions contained herein. The Issuer has covenanted and agreed, and agrees and covenants he~eby, with the Trustee and with each and all Holders, as follows: (Balance of page left intentionally blank) 4 r:Re5, 91- /g' ...-- ~"",--,.~~r",:~'~ '.", . .'.' / I,: c ..". I . +..... ..~. ~ .: I.. . tIT,. I ,~ ( ,} 'J , '\ ''''; ARTICLE I DEFINITIONS SECTION 1.01. Detinitions. In addition to the words and terms detined elsewhere in this Indenture or by specific reference to another document, unless the context or use clearly indicates another meaning or intent capitalized words and terms used in this Indenture shall have the following meanings: "Act" means the Florida Constitution, the Charter of the Issu~r and <;:hapter 154, Parts II and III of Chapter 159, and Chapter 166, Florida Statutes, as amended and other applicable provisions of law. "Additional Bonds" means the Additional Bonds issued under the provisions of Section 2.05 of the Indenture. "Additional Notes" means any non-negotiable promissory note or notes, in addition to the Series 1999 Notes, delivered by the Mortgagor to the Trustee in connection with the issuance of Additional Bonds as provided in the Agreement. "Additional Payments" means the payments required to be paid by the Mortgagor under Section 4.2 of the Agreement. "Adjusted Rate" means the interest rate borne by the Series 1999C Bonds detennined in the manner set forth in Section 2.03(b) of the Indenture. "Affiliate" means a Person which controls or is controlled by the Company or is under common control with the Company, as follows: (A) one Person shall be deemed to control another if it owns more than 50% of the outstanding voting stock of or other equity interest in the other, or it has the power to elect more than 50% of the governing body of the other; and (b) such control may be exercised by one Person over another directly, indirectly through control over a third party, or jointly with one or more controlled third parties. "Agreement" means the Loan and Security Agreement dated as of July 1, 1999 between the Issu~r and the Company, as amended or supplemented from time to time. "Annual Cash Operating Expense" means, as of any date of determination thereof, the expenses of operating the Project, other than depreciation, amortization and other non-cash items, for the preceding 365 days, all as determined in accordance with generally accepted accounting principles. "Appraiser" means a Person designated by the Aulhorized Company Representative, with written notice to the Trustee, who (i) is a member of the American Appraisal Institute, (ij) has no 5 Kes. CfI-/~ ) '~ u ';.~ .' ~..... ~_. interest. direct or indirect. in the Company other than payment for services and (iii) in the case of an individual, is not a member, director, trustee, officer or employee of the Company or, in the case of another Person, has no partner, member, director, trustee, officer or employee who is a member, director, trustee, ot"ticer or employee of the Company. In the event that the American Appraisal Institute should cease to exist, the term "Appraiser" shall mean a Person, designated by the Company with written notice to the Trustee and not objected to by the Trustee within 10 days after receipt of such notice, which objection shall not be unreasonably interposed, who is recognized as quafified to appraise the value of buildings, furnishings and equipment comparable to the Project and who does not have any relationship prohibited in the preceding sentence. "Arbitragc Rcbatc Agrccmcnt" means the Arbitrage Rebate Agreement dated as of July 1, 1999 among the Issuer, the Company and the Trustee. "ArcWtcct" means a Person, designated by the Authorized Company Representative, with written notice to the Trustee, who or which Architect (i) is licensed or permitted to practice architecture or engineering in the State, (ii) has no interest, direct or indirect, in the Company and (Hi) in the case of an individual, is not a member, director, trustee, officer or employee of the Company or, in the case of another Person, has no partner, member, director, trustee, officer or employee who is a member, director, trustee, officer or employee of the Company. "Assigmnent" means the Assignment of Mortgage of even date with the Mortgage, from the Issuer to the Trustee, as amended or supplemented from time to time. "Auditor" means a recognized firm of independent certified public accountants of good repute, designated by the Authorized Company Representative, which is licensed or permitted to practice as accountants and auditors in the State. "Authenticating Agent" means the Trustee, as Registrar for the Bonds and any bank, trust company or other person designated as an Authenticating Agent for the Bonds by or in accordance with Section 6.13 of the Indemure, each of which shall be a transfer agent registered in accordance with section 17A(c) of the Securities Exchange Act of 1934, as amended. "Authorized Company Representative" means the person at the time designated to act on behalf of the Company by its Chief Executive Officer by written certificate furnished to the Trustee and the Issuer, which certificate may designate an alternate or alternates. rn the event that all persons so designated become unavailable or unable to act and the Company fails to designate a replacement within ten (to) days after such unavailability or inability to act, the Trustee may appoint an interim Authorized Company Representative until such time as the Company designates that person. 6 rueS. CfI-;g J "Authorized Denominations" means (a) with respect to the Series 1999 Bonds. $100,000 or any integral multiple of $5,000 in excess thereof, and (b) with respect to Additional Bonds. the denominations authorized in the applicable Supplemental Indenture. "Authorized Official" means the' Mayor~Commissioner, Vice Mayor, City Manager or Assistant City ManaIjer of the Issuer, or such other officer of the Issuer as may be designated in writing to the Trustee and the Company by the Issuer. "Bond Cow1Sel" means Bryant, Miller and Olive, P.A., Tallahassee, Florida or such other firm of attorneys approved by the Issuer of nationally recognized standing in the field of municipal ,finance law whose opinions are generally accepted by underwriters and other purchasers of obligations issued by state and local governments. "Bond Fund" means the Bond Fund created by Section 5.01 of the Indenture. "Bond Purchase Agreement" or "Purchase Agreement" means, with respect to the Series 1999 Bonds, the Bond Purchase Agreement among the Issuer, the Company and the original purchaser of the Series 1999 Bonds; and as to any Additional Bonds, any bond purchase agreement for which provision is made to purchase such Bonds by the original purchaser thereof. "Bond Year" has the meaning set forth in the Arbitrage Rebate Agreement. '~ "Bonds" means the Series 1999 Bonds and any Additional Bonds. "Business Day" or "business day" means any day of the year on which banks in any of the cities in which the principal office of the Trustee or of the designated office of any Paying Agent are located are not required or authorized by law to remain closed and on which the Trustee and any Paying Agent and the New York Stock Exchange, Inc. are open for business. "Capitalized Interest" means accrued interest, if any. received upon the sale of the Bonds plus any imerest to become due and payable on the Bonds, which is included in the principal amount of the Bonds. and deposited in the Bond Fund and used to pay interest on the Bonds, until completion of a related project. "Chicago Time" means the time on any given day in the City of Chicago, IIlinois,"whether such time be Central Standard Time or Central Daylight Savings Time. "Code" means the Internal Revenue Code of 1986, as amended, the Treasury Regulations (whether proposed, temporary or final) under the Code or the Statutory predecessor of the Code, and any amendments of, or successor provisions to, the foregoing and any official rulings. announcements, notices, procedures and judicial determinations regarding any of the foregoing, all as and to the extent applicable. Unless otherwise indicated, reference to a Section means the o 7 Q1-/'6 --------I~ 'J Section of the Code, including such applicable Treasury Regulations, rulings. announcements, procedures, and determinations pertinent to that Section. "Commercial Code" means the Uniform Commercial Code as enacted in the State, as from time to time amended or supplemented. UCompany" means BEF, Inc. ~ Inc., a Florida notHfor-profit corporation and its lawful successors and assigns, to the extent permitted by the Agreement. UCompany Documents" mean the Agreement, the Notes, the Mortgage and the Bond Purchase Agreement. uCompletion Date" means the date of completion of the Project to be specitied in the certificate furnished by the Company pursuant to Section 3.6 of the Agreement. "Computation Date" shall have the meaning set forth in the Arbitrage Rebate Agreement. ) . "Consultant" means a firm of nationally-recognized consultants, designated by the Authorized Company representative with written notice to the Trustee and, so long as the Series 1999 Bonds are Outstanding, Ziegler Securities, which Consultant (i) is knowledgeable in both the operations and fiscal management of continuing care or similar health care facilities, (ii) has a good reputation for skill and experience in that work, (Hi) has no interest, direct or indirect, in the Company, and (iv) has no partner, principal, member, director, trustee, officer or employee who is a member, director, trustee, officer or employee of the Company. "Continuing Disclosure Certificate" means the Continuing Disclosure Certificate dated as of July 1, 1999 by the Company. "Days Cash on Hand" means, as of any date of detennination thereof~ the product of 365 times a fraction, the numerator of which is the sum of cash, readily marketable securities and other investments of the Company not held by the Trustee as of such date and the denominator of which is Annual Cash Operating Expense. "Debt" means all obligations for borrowed money and installment sale and capitalized lease obligations incurred or assumed by the Company and any guaranty by the Company of indebtedness of any other Person, but shall not be deemed to include (a) obligations under contracts for supplies, services and pensions allocable to current operating expenses during the current or future Fiscal Years in which the supplies are to be delivered, the services rendered or the pensions paid~ and (b) payments payable in the current or future Fiscal Years under leases not intended to evidence the acquisitions of capital assets. "Debt Service Charges" mean, for any period or date, the principal of and premium, if any. and interest on the Bonds accruing for that period or due and payable on that date. In ,~ 8 99"/~ J determining Debt Service Charges accruing for any period or due and payable on any date. mandatory sinking fund requirements accruing for that period or due on that date shall be included. "Debt Service Coverage Ratio" means the ratio of Net Income Available for Debt Service for the period in question to the maximum Principal and Interest Requirements of the Company on outstanding Long-Term Debt for the then current or any succeeding Fiscal year, determined as of the first day of such period. The calculation of the Debt Service Coverage Ratio shall be made in accordance with Section 5.3 of the Agreement, except as may be otherwise provided in other Sections of the Agreement. "Debt Service Reserve Fund" means the Debt Service Reserve Fund created in Section 5.01 of the Indenture. "Debt Service Reserve Requirement" means with respect to the Series 1999 Bonds, as of the date of any calculation, an amount equal to $ . In the event Additional Bonds are issued, the Debt Service Reserve Requirement, if any, with respect to those Additional Bonds shall be the lesser of (i) 10% of the proceeds of such Additional Bonds, (ii) the Maximum Principal and Interest Requirements on such Additional Bonds or (iii) 125% of the average Principal and Interest Requirements on such Additional Bonds. No such Additional Bonds shall be secured by the Debt Service Reserve Fund established for the Series 1999 Bonds. ", J "Default" means any circumstance which, with the passage of time or the giving of notice or both, would constitute an "Event of Default" as defined in Section 7.1 of the Agreement or 7.01 of the Indenture, respectively. "Defeasance Obligations" means: (a) direct obligations of the United States of America (including obligations issued or held in book-entry form on the books of the Department of the Treasury of the United States of America), or obligations the timely payment of the principal of and interest on which is unconditionally guaranteed by the United States of America, (b) certificates which evidence ownership of the right to the payments of the principal of and interest on obligations described in clause (a) or in specified portions thereof, including without limitation, portions consisting solely of the principal thereof or solely of the interest thereon, and (c) obligations of any state or any political subdivision of any state, other than the Issuer, which are rated by a Rating Service in the highest category for long-term debt, the interest on which is excluded from gross income for federal income tax purposes and the full and timely payment of the principal of and any premium and the interest on which is unconditionally payable from obligations of the character described in (a) or (b) above. <.J 9 q1- f6 ...-/.... rll.. '. ,~ "Disbursement Requestll means a written order to the Trustee for disbursement from the Project Fund substantially in the form of Exhibit E attached to the Agreement. "Eligible hlvestmcnts" mean (a) obligations issued or guaranteed as to full and timely payment by the United States of America or by any Person controlled or supervised by or acting as an instrumentality of the United States of America pursuant' to authority granted by Congress; (b) obligations issued or guaranteed by any state or political subdivision thereof, which obligations are rated in the highest category if rated as short therm obligations by a Rating Service; {c) commercial or finance paper which is rated in the highest rating category by a Rating Service; """"\ j (d) deposit accounts, bankers'. acceptances, certificates of deposit or bearer deposit notes in one or more banks or trust ~ompanies (including without limitation, the Trustee or any bank affiliated with the Trustee) organized under the laws of the United States of America or any state thereof, the senior debt obligations of which bank or trust company at the time of purchase of such instruments are rated in one of the three highest rating categories by a Rating Service or which instruments are secured by a security interest in obligations described in (a) above or which are fully insured by the FDIC; (e) any repurchase agreement: (i) with any bank, including the Trustee and its affiliates, or any broker-dealer with retail customers that falls under the protection of the Securities Investors Protection Corporation; (ii) which is secured by coJlateraJ of the type specified in (a) and (b) above which collateral (1) is in the possession of the Trustee or a third party acting solely as agent for the Trustee, (2) is not subject to any third party claims, and (3) has a market value (determined at least once every 14 days) at least equal to the amount invested in the repurchase agreement; and (Hi) which permits the Trustee to liquidate the collateral immediately upon failure to maintain the collateral at the required level; and (f) money market funds invested solely in securities listed in (a) above; provided that any investment or deposit described above is not prohibited by applicable law. "Entrance Fees" shall mean the fees, other than monthly service charges by the residents of the Mortgaged Property to the Company for the purpose of obtaining the right to reside in the Mortgaged Property, including any Refundable Resident Deposits described in Residency \) 10 19,-/<6 '~) ,:) u Agreements with respect to the Mortgaged Property, but shall not include any such amounts that are (i) escrowed pursuant to the requirements of Chapter 651, Florida Statutes or any simi lar law , unless and until such amounts are released from such escrow to the Company or (ti) escrows otherwise set aside pursuant to the requirements of any Residency Agreement prior to occupancy of the unit covered by such Residency Agreement (which amounts shall be included if and when such occupancy occurs). "Event of Default" means an Event of Default as defined in Section 7. 1 of the Agreement and in Section 7.01 of the Indenture. "Excess Earnings" means, as to lhe Tax-Exempt Bonds of any issue as of each Computation Date for that issue, an amount determined in accordance with Section 148(t) of the Code equal to the sum of (a) plus (b) where: (a) Is the excess of (i) the aggregate amount earned from the date the Tax-Exempt Bonds are invested (other than investments attributable to an excess described in this clause (a)), taking into account any gain or loss on the disposition of nonpurpose investments, over (ii) the amount that would have been earned if the amount of the gross proceeds of the Tax-Exempt Bonds of sllch issue invested in those nonpurpose investments (other than investments attributable to an excess described in this clause (a)) had been invested at a rate equal to the yield on the Bonds; and (b) any income attributable to the excess described in clause (a) above, taking into account any gain or loss on the disposition of investments. The foregoing sums shall be determined in accordance with Section 148(t) of the Code. As used herein, the tenns "gross proceeds, ff Itnonpurpose obligations" and Jlyieldll have the meanings assigned to them for purposes of Section 148 of the Code. "Excluded Property" means the property described in Exhibit F of the Agreement, if any. "Exempt Personlt means (i) any organization described in Section 50l(c)(3) of the Code and exempt from taxes under Section 501 (a) of the Code, and (ii) a "govenunent unit" as that tenn is used in Section 103 and 145 of the Code. "Existing Facilitiesll means the buildings, equipment and improvements located on the Project Site on the date of execution and delivery of the Agreement. 11 91- If{ ~1 , '-"x ,-.-1 ,~ ~:.r-...l!..::....:.....:.....;..:.:...:..:"""". "Extendables Purchase Fund" means the Extendables Purchase Fund created pursuant to Section 4.10 hereof. "FISCal Year" means. with respc..'Ct to the Company. the period commencing on I of each year and ending on the 30 of the following year or such other fiscal year as may hereafter be designated by the Company to the Trustee in writing. "Force Majeure" means any of the causes, circumstances or events described as constituting Force Majeure in Section 7.1 of the Agreement or Section 6.2 of the Mortgage. "Governmental Restrictions" means federal, State or other applicable govemmentallaws or regulations affecting the Company or its facilities and placing restrictions and limitations on the rates, fees and charges to be tixed, charged and collected by the Company or any other operator of the Company's facilities; provided, however, that no change in law or regulation shall be deemed applicable by reason of this definition if such change would in any way constitute an impairment of the rights of the Issuer, a Holder, the Company or any other operator of the Mortgaged Property or the Trustee under the Agreement or the Indenture. "Holderll or "Holder of a Bond" means the person in whose name a bond is registered on the Register. "hnmediate Notice" means notice by telephone. telegram, telex, telecopy or other telecommunication device, receipt of which has been confirmed by the recipient, promptly followed by written notice by overnight carrier or delivery service, expenses prepaid. to such addresses. "Indenture" means the Trust Indenture dated as of July 1, 1999 between the Issuer and the Trustee, as amended or supplemented from time to time. "Independent Counsel" means an attorney or firm of anorneys acceptable to the Company and duly admitted to practice law before the highest court of the State. "Initial Interest Ratell means, the interest rate applicable from the dated date of the Series 1999 Bonds to and including at the Initial Rate Change Date. "fuitial Rate Change Datell means the first date on which the Series 1999B Bonds change to another interest rate, which shall be 1 t 20_. "Insurance Consultant" means a Person designated by the Authorized Company Representative, with written notice to the Trustee, who or which Insurance Consultant is (i) qualified to survey risks and to recommend insurance coverage for facilities comparable to the Mortgaged Property and tor organizations engaged in operations similar to those of the Company, (ii) has a favorable reputation for skill and experience in making those surveys and 12 11-/6 . ~ . .. . c ,~ . .. ." . ,~ recommendations, (iii) has no interest, direct or indirect, in the Company other than payment for services and (iv) in the case of an individual, is not a member, director, trustee, ofticer or employee of the Company or, in the case of another Person, has no partner, member, director, trustee, ofticer or employee who is a member, director, trustee, officer or employee of the Company; provided that so long as the foregoing requirements are satisfied, the Insurance Consultant may be a broker or agent with whom the Company transacts business; and provided further that the collection of reasonable fees for services rendered does not constitute an interest in the Company for this purpose. "Insurance Requirements" means all requirements respecting the Mortgaged Property, or any part thereof, imposed by any policies of insurance in force at any time with respect to any of the buildings, improvements, machinery, furnishings or equipment constituting a part of the Mortgaged Property. , "Interest Payment Account" shall mean the Interest Payment Account within the Bond Fund created in Section 5.01 of this Indenture. .') --..-1 "Interest Payment Date" or "Interest Payment Dates" means, as to the Series 1999 Bonds, the date or dates set forth as such in the form of Series 1999 Bond attached as Exhibit B to the Indenture, and as to AdditionaJ Bonds, each date or dates designated as an "Interest Payment Date" or "Interest Payment Dates" in the form of Bond for which provision is made in the applicable Supplemental Indenture. "futercst Rate for Advances" means the lesser of (i) the Prime Rate or (ii) the maximum interest rate permitted by applicable law. "Investor Letter" means the Investment Letter to be delivered by the purchaser of the Series 1999 Bonds to the Issuer and the Trustee substantially in the form attached hereto as Exhibit B. "Issuance Expenses" means all costs and expenses payable by the Issuer which are incidental to the issuance of the Bonds and shall include, but not be limited to, fees and expenses of consultants, advisors, accountants, Bond Counsel and other legal counsel to the Issuer, costs and expenses of printing such Bonds and disclosure documents relating thereto, fees of bond rating services, charges for CUSIP numbers, charges of any clearing agent, charges of the Depository Trust Company CIDTCIr) and other securities depositories, charges payable to the Municipal Securities Rulemaking Board, Public Securities Association and wire services, charges for telephone, telegraph, telecopier, telex and fax services, postage and express charges, costs of federal funds, closing costs (including all legally permitted costs of travelt food and lodging of officials and employees of the Issuer incurred in connection with attending any closing or preclosing or any meeting relating to the issuance of the Bonds), any costs incurred in connection with the sale of the Bonds, including costs incurred in any public or negotiated sale thereof, and placement fees, costs of compliance with the securities laws of any state in which Bonds are to be J 13 '11-/f{ ') offered and sold, the initial fees of the Trustee. Registrar. Paying Agent and Authenticating Agent, and other similar expense; provided that the term shall not include any underwriter's discount which is taken into account in the sale price (or any costs and expenses paid by the underwriter which are not to be reimbursed by the Issuer). "Issuer" means City of Clearwater Florida. a municipal corporation duly created and validly existing under the laws of the State of Florida including, particularly, the Act, and its successor public bodies. "Issuer Documents" means the Agreement, the Assignment and the Indenture. "Loan" means a loan by the Issuer to the Company of the proceeds received from the sale of Bonds. "Loan Payment Date" means (i) the fifth Business Day immediately preceding the last day of each calendar month and (ii) the fifth Business Day immediately preceding the date on which any principal of or interest or any premium on the Bonds shall be due and payable, whether at maturity, upon acceleration, call for redemption or otherwise. "Loan Payments" means the amounts required to be paid by the Company in repayment of the Loan pursuant to Section 4.1 of the Agreement. "--)" ~- "LongMTerm Debt" means Debt having an original maturity greater than one year (including demand notes with alternative stated maturities of less than one year unless and until a demand for the payment thereof shall have been made) or renewable ~.t the option of the obligor for a period greater than one year from the date of original incurrence or issuance thereof, which shall not include the current portion of such Long-Term Debt as determined in accordance with generally accepted accounting principles. "Maximum Principal and Interest Requirement" means as to any Series of Bonds. the maximum Principal and Interest Requirement coming due on such Bonds in any Fiscal Year provided that the Maximum Principal and Interest Requirement for any Long Term Debt shall be disregarded for any period during which the interest on such Long Term Debt is funded from the proceeds thereof. "Mortgage" means the Mortgage and Security Agreement dated as of July 1, 1999, from the Company to the Issuer, as amended or supplemented from time to time. "Net Income Available for Debt Service" means, with respect to any period of time, the (a) the Company's excess/deficiency of revenue over/under expenses prepared in conformity with generally accepted accounting principles, ~ (b) depreciation. amortization of deferred expenses, and interest expense on Debt, plus (c) an amount equal to Entrance Fees collected (net of any refunds of Entrance Fees). m..in.u.s (d) lifetime lease income amortized into income, and (e) from I 'J 14 q9- /~ ~ioU-~":::"""":'....":'.....:..:..:..::.:.:"':""::"':':"-'-.......__~___ _ _ _ ~ -:J ", .', ',- :" 'I.'. r , ". .J which shall be excluded any extraordinary items, and any gain or loss resulting (rom either the extinguishment of debt or the saJet exchange or other disposition of assets not made in the ordinary course of business. Restricted gifts shall be included in the computation of Net Income Available for Debt Service to the extent that, and with respect to the period of time during which, the expenditure of such restricted gifts has been included in the computation of expenses. JlNet Proceeds,1I when used with respect to any insurance proceeds or condemnation award, means the gross proceeds thereof less the payment of all expenses. including attorneys' fees incurred in connection with the collection of such gross proceeds. "Notes" means the Series 1999 Notes and any Additional Notes. "Notice Address" means (a) As to the Issuer: Margaret L. Simmons, CPA Financial Services Administrator City of Clearwatert Florida 100 South Myrtle Avenue Clearwater, Florida 33758 copy to: Pamela Akin, Esq. City Attorney 112 South Osceola Avenue Clearwater, Florida . (b) As to the Company: BEF, Inc. 1601 Jack Street, Suite 200 Fort Myers, Florida 33901 Attention: Gerard A. McHale, Jr. (c) As to the Trustee: SunTrust Bank. Central Florida, National Association 225 East Robinson Street, Suite 250 Orlando, Florida 32801 Attention: Corporate Trust Department (d) As to the Remarkeling Agent: Ziegler Securities, a division of B. C. Ziegler and Company III Second Avenue, N.E., Suite 915 St. Petersburg, Florida 33701 Attention: Vice President 15 19-/8' _<~"~~_.",,,,_'h'~ ~". <-., ~~ ,,) J or such different address, notice of which is given under Section 8.4 of the Agreement or Section 12.03 of the Indenture. "Opinion of Bond COWlSCI" means an opinion in writing signed by a Bond Counsel satisfactory to the Trustee. "Opinion of COWlSel" means an opinion in writing signed by an attorney or firm of attorneys not unsatisfactory to the Trustee, who may be counsel to the Company. "Optional Tender Date" means, with respect to the Series 1999B Bonds, each Rate Change Date. "Outstanding Bonds," "Bonds Outstanding" or "Outstanding" as applied to Bonds, mean, as of the applicable date, all Bonds which have been authenticated and delivered, or which are being delivered by the Trustee under the Indenture, except: (a) Bonds cancelled upon surrender, exchange or transfer, or cancelled because of payment or redemption on or prior to that date; (b) Bonds, or the portion thereof, for the payment, redemption or purchase for cancellation of which sufficient moneys have been deposited and credited with the Trustee or any Paying Agents on or prior to that date for that purpose (whether upon or prior to the maturity or redemption date of those Bonds); provided, that if any of those Bonds are to be redeemed prior to their maturity. notice of that redemption shall have been given or arrangements satisfactory to the Trustee shall have been made for giving notice of that redemption, or waiver by the affected Holders of that notice satisfactory in form to the Trustee shall have been filed with the Trustee; (c) Bonds, or the portion thereof, which are deemed to have been paid and discharged or caused to have been paid and discharged pursuant to the provisions of the Indenture; (d) Bonds in lieu of which others have been authenticated under Section 3.07 of the Indenture; and (e) Any Bond as to which an election to tender has been duly submitted and not withdrawn and moneys are held in trust by the Tender Agent for the purpose of purchase of such Bond. "Parity Debt" means any obligation of the Company permitted to be incurred as Parity Debt in Section 5.5 of the Agreement. 16 11,r/f{ ~ "Payhlg Agent" means any bank or trust company designated as a Paying Agent by or in accordance with Section 6. 12 of the Indenture. "Pennitted Debt" means the liabilities, obligations and Debt permitted in Section 5.4 of the Agreement. "Permitted Encumbrances" shall have the meaning assigned such term in Section 5.7 of the Agreement. lIPerson" or words importing persons, means firms, associations. partnerships (including without limitation, general and limited partnerships); joint ventures, societies. estates. trusts, corporations, public or governmental bodies. other legal entities and natural persons. "Plans and Specifications" means the plans and specitications describing a project as prepared and on file with the Trustee, as they may be changed from time to time. "Prime Rate" means that interest rate announced from time to time by the Trustee in its lending capacity as a bank as its "prime rate" or "base rate. rt .'~) "Principal and Interest Requirements" means, for any period or date, as applied to any Debt means the sum of the principal of and premium, if any, and interest (determined for variable rate date at the highest rate payable on such date) on any Outstanding Debt accruing for that period or due and payable on that date; provided that for this purpose, the term Debt does not include indebtedness tor which provision tor payment has been made in accordance with the terms of the instruments evidencing or securing such indebtedness. In determining Principal and Interest Requirements accruing for any period or due and payable on any date, mandatory sinking fund requirements on any Debt for that period or on that date shall be included, and principal maturities and mandatory sinking fund requiremems for a prior period or on a prior date shall be excluded. "Principal Payment Account" means the Principal Payment Account within the Bond Fund created in Section 5.01 of the Indenture. "Private Busin~ Use" means use, directly or indirectly (i) in a trade or business carried on by any Private Person (other than a Tax-Exempt Organization) other than use as a member of, and on the same basis as, the general public, or (ii) in any activity carried on by a Tax-Exempt Organization (other than use as a member of, and on the same basis as, the general public) which is an "unrelated trade or business" activity within the meaning of Section 513 (a) of the Code. "Privute Person" means any person, firm, entity or individual, including a Tax-Exempt Organization other than a governmental unit as that term is used in Section 145 of the Code. "Project" means the capital improvements described in Exhibit B to the Agreement (and more particularly described in the Plans and Specifications related thereto), together with any \ J 17 19--;Cl ) ,~) 'J additions, modifications and substitutions to those facilities. including all furnishings, machinery. equipment and other tangible personal property. "Project Budget" means the budget and trade and materials, breakdown and scheduled values for the Project. "Project Costs" has the meaning assigned such tenn in Section 3.4 of the Agreement. "Project Food" means the Project Fund created in Section 5.01 of the Indenture. "Project Site" means the real estate described in Exhibit D to the Agreement, and any additions thereto, less any removals therefrom made in the manner permitted by the Agreement. "Property" means any and all rights, title and interest of the Company in and to property (including cash and cash equivalents) whether real or personal, tangible or intangible and wherever situated, but excluding Excluded Property. "Rate Change Date" means, with respect to the Series 1999B Bonds, the Initial Rate Change Date and any rate change date selected by the Company pursuant to Section 2.03(b) of the Indenture. "Rate Period" means, with respect to the Series 1999B Bonds, th~ period commencing on each Rate Change Date and ending on and including the date preceding the next Rate Change Date, or the maturity date thereof. "Rating Service" means Fitch Investors Service, Inc., Moody's Investors Service, Inc. or Standard & Poor's Corporation, each of New York, New York or their respective successors. "Rebate AmowIt" means the amount of Excess Earnings computed as of the most recent prior Computation Date which are required to be paid to the United States of America under Section 148(t) of the Code. "Rebate Fund" means the Rebate Fund created in Section 5.01 of the Indenture. "Refunding Debt" means Debt incurred for the purpose of refinancing or refunding all or any portion of any Outstanding Debt of the Company. "Registerll means the books kept and maintained for the registration and transfer of Bonds pursuant to Section 3.06 of the Indenture. "Registrar" means the Trustee or such other bank, trust company or person as may be designated from time to time by the Issuer with the approval of the Company. 18 1tI,-~ " ~) -. , ) .._~ ,~ ....-.,a... "Regular Record Date" or "Record Date" means, with respect to any Bond. the last day (whether or not a Business Day) of the calendar month next preceding an Interest Payment Date applicable to that Bond. "Regulatory Body" means any federal state or local government, department, agency, authority or instrumentality (other than the Issuer) and other public or private body, including accrediting organizations, having regulatory jurisdiction and authority over the Company or its facilities or operations. "Remarketing Agent" means the Remarketing Agent appointed and serving a such pursuant to Section 4.15 of the Indenture. ihitially Ziegler Securities, a division of B.C. Ziegler and Company. "Rell1arketiug Agreement" means the Remarketing Agreement between the Company and the Remarketing Agent then serving under the Indenture. "Renewal and Replacement Fund" shall mean the Renewal and Replacement Fund created under section 5.19 of the Agreement. UReset Rate" means, with respect to the Series 1999B Bonds, the adjusted rate of interest born on the Series 19998 Bonds determined as provided in Section 2.03(b) of the Indenture. "Revenues" means all present and future revenues received by or on behalf of the Company from whatever source derived, including without limitation, all (a) Entrance Fees, cash, accounts, deposits, chattel paper, instruments, documents, money and general intangibles, including without limitation, contract rights and rights to payment (i) for goods and properties sold or leased or for services rendered, (ii) under agreements respecting governmental and private insurance arrangements, and (iii) from any insurance, condemnation award or agreement in lieu of a condemnation award resulting from eminent domain proceedings, (b) income from, and revenues realized upon the liquidation or sale of, securities held by or on behalf of the Company, (c) proceeds of those items constituting Revenues to which reference is made in clauses (a) and (b) above, and (d) gifts, grants, bequests, contributions and donations, including without limitation, the unrestricted income and profits therefrom, provided that Revenues do not include 19 99~/~ c. . c _,. ~ ~ ~ . . ----~.~_......................__. - ~ ') , . . , J .....'". ~'..+ .,.:;.....L... . ~ .,' . (i) gifts. grants, bequests. contributions and donations to the extent restricted specitically to a particular purpose inconsistent with their use for the making of payments into any of the Special Funds, (ii) the procet.-ds of any borrowing to the extent that those proceeds are required to be excluded from Revenues by the terms of the borrowing, (Hi) the proceeds of non-recourse Debt secured by and payable solely from Property tinanced by such non-recourse Debt and all revenues derived from or attributable to Property financed with the proceeds of such non.recourse Debt, (iv) revenues derived from Excluded Property, or "Series 1999 Bonds" means collectively, the Series 1999A Bonds, the Series 1999B Bonds and the Series 1999C Bonds. "Series 1999A Bonds" means the $ Revenue Bonds, Series 1999A (BEF, Inc. Project). City of Clearwater, Florida "Series 1999B Bonds" means the $ City of Clearwater, Florida, Revenue Bonds, Series 1999B (BEF, Inc. Project), Extendable Rate Adjustable SecuritiesSM (EXTRASSM). "Series 1999C Bonds" means the $ Taxable Revenue Bonds, Series 1999C (BEF, Inc. Project). City of Clearwater, Florida "Series 1999 Note" means the non-negotiable promissory note of the Company in the aggregate principal amount of $ of even date with the Series 1999A Bonds, Series 1999B Bonds and the Series 1999C Bonds, substantially in the form attached to the Agreement as Exhibit" A," executed and delivered by the Company to the Trustee in connection with the issuance of the Series 1999 Bonds. "Special Funds" means the SpeciaJ Funds created pursuant to Section 5.01 of the Indenture, other than the Rebate Fund. "Special Interest Payment Date" means the Special Interest Payment Date created in Section 7 .07(d) of the Indenture. "Special Record Date" means, with respect to any Bond, the date established by the Trustee in connection with the payment of overdue interest on that Bond pursuant to Section 3.05 of the Indenture. "State" means the State of Florida. 20 19'-/~ ,~ " " -") _/ "~ "Supplemental Indenture" means any indenture supplemental to the Indenture entered into between the Issuer and the Trustee in accordance with Article VIII of the Indenture. "Taxable Bond" means any obligation, or issue of obligations which at the time of issuance under the Indenture is not intended to be a Tax-Exempt Bond. "Tax-Exempt Bond" means any obligation, or issue of obligations, the interest on which is, or is intended to be, excluded from gross income for federal income tax purposes within the meaning of Section 103 of the Code. "Tender Agent" means the Tender Agent referred to in Sections 4.10 and 6.14 of the Indenture, which Tender agent shall initially be the Trustee, serving as agent for Registered Owners of Put Option Bonds who shall have elected to tender such Bonds for purchase. "Tender Purchase Price" shall have the meaning assigned in Section 4.09(a) of the Indenture. "Tender Withdrawal" shall have the meaning assigned in Section 4.11 of the Indenture. "Term Bonds" means, with respect to the Series 1999 Bonds, those Series 1999 Bonds designated as Term Bonds in Section 2.03(a) of the Indenture. "Total Operating Revenues" means, for any period, the sum of the Companis (a) operating revenues, less provision for uncollectible accounts, charity cases and any contractual adjustments, plus (b) all other operating revenues. "Trustee" means SunTrust Bank, Central Florida, National Association, a national banking association, Orlando, Florida, untii a successor Trustee shall have become such pursuant to the applicable provisions of the Indenture, and thereafter "Trustee" shall mean the successor Trustee. "Unassigned Rights" means the rights of the Issuer under the Agreement to (a) receive Additional Payments as contemplated in Section 4.2 of the Agreement; (b) to purchase the Project as contemplated by Section 4.7 of the Agreement; (c) to be held harmless and indemnified under Section 5.12 of the Agreement; (d) to exercise with the consent, but not to the exclusion, of the Trustee any remedies which are authorized to be exercised by the Issuer under the Agreement in , connection with an Event of Default; (e) to be reimbursed, to the extent permitted by law. for attorney's fees and expenses under Section 7.4 of the Agreement; and (t) to execute amendments to the Agreement. "Ullremarketcd Bondsll shall have the meaning assigned in Section 4.10 of the Indenture. 21 11'-!~ -"'~MN."-':"'} ,.... .~.~ '" .....- . .. _._________...0..--.-........-_____ ,') 1<, ) .:J SECTION 1.02. Interpr~tation. Any reference herein to the Issuer, or to any member or officer thereof, includes entities or officials succeeding to their respective functions, duties or responsibilities pursuant to or by operation of law or lawfully performing their functions. Any reference to a section or provision of the Constitution of the State or the Act, or to a section, provision or chapter of the Florida Statutes or Laws of Florida, or to any statute of the United States of America, includes that section, provision or chapter as amended, modified, revised. supplemented or superseded from time to time; provided, that no amendment, moditication, revision, supplement or superseding section, provision or chapter shall be applicable solely by reason of this provision, if it constitutes in any way an impairment of the rights or obligations of the Issuer, the officers, employees and members of the Issuer, the Holders, the Trustee, the Registrar or the Company under this Indenture, the Bonds, the Agreement, the Notes, the Mortgage, or any other instrument or document entered imo in connection with any of the . foregoing, including without limitation, any alteration of the obligation to pay Debt Service Charges in the amount and manner, at the times, and from the sources provided in the Agreement and this Indenture, except as permitted herein. Unless the context indicates otherwise, words importing the singular number include the pluraJ number, and vice versa; the defined words and terms are equally applicable to the possessive forms of any such word or term; the terms "hereof, II "hereby," IIherein," II hereto , " "hereunderll and similar terms refer to this Indenture; and the term "hereafterll means after, and the term "heretofore" means before, the date of this Indenture. Words of any gender include the correlative words of the other genders, unless the sense indicates otherwise. SECTION 1.03. Captions and Headings. The captions and headings in this Indenture are solely for convenience of reference and in no way define, limit or describe the scope or intent of any Articles. Sections, subsections, paragraphs, subparagraphs or clauses hereof. 22 19~/r +-O;---......;':F/...)r....~.~~'"'u.... >~,~. ''''., ~ ARTICLE II A UTHORIZA TION AND TERMS OF SERIES 1999 BONDS~ ADDITIONAL BONDS SECTION 2.01. Authorized Amount of Series 1999 Bonds. No Bonds may be issued hereunder except in accordance with this Article. The total authorized principal amount of Series 1999A Bonds which shall be issued is $ , the total authorized principal amount of Series 1999B Bonds which shall be issued is $ and the total authorized principal amount of Series 1999C Bonds which shall be issued is $ . The Issuer may authorize (but shall not be required to), sell and deliver one or more series of Additional Bonds for the purposes provided herein upon satisfaction of the conditions and in the manner provided herein. SECTION 2.02. Issuance of Series 1999 Bonds. The Issuer shall sell and deliver the Series 1999 Bonds for the purpose of financing the Project Costs, including the payment of, and the reimbursement of moneys applied by the Company for, portions of the costs of acquiring, constructing, improving and equipping the Project as more particularly described in the Agreement. -) -,'" The Series 1999 Bonds (i) shall be issued in three series designated as "Revenue Bonds, Series 1999A (BEF, Inc. Project)", "Revenue Bonds, Series 1999B (BEF, Inc. Project), Extendable Rate Adjustable SecuritiessM (EXTRASSM)" and "Taxable Revenue Bonds. Series 1999C (BEF, Inc. Project)"; (ii) shall be issuable in Authorized Denominations and in fully registered form substantially as set forth in Exhibit, A hereto; (Hi) shall be transferable and exchangeable only for fully registered Bonds of Authorized Denominations and of the same maturity, as provided herein; (iv) shall be numbered in a manner determined by the Trustee; (v) shall bear interest as provided herein, payable on each Interest Payment Date and computed on the basis of a 360-day year consisting of twelve 3D-day months; and (vi) shall be subject to redemption prior to maturity as provided in Article IV hereof. SECTION 2.03. Terms of Series 1999 Bonds. (a) The Series 1999 Bonds shall be dated July 1, 1999, shall bear interest payable semi-annually on the 15th day of May and November of each year, commencing November 15, 1999, initially at the rate or rates per annum hereinafter set forth (and adjusted as provided below), until the principal or Redemption Price of the Series 1999 Bonds is paid and shall mature as follows: $ of the Series 1999A Bonds shall be and are hereby designated as Term Bonds bearing interest at the rates and maturing on the 15th day of November in the years and in the principal amounts as follows: Maturity November 15 Principal Amount Interest Rate .....) 23 Q1-/8' J ' ~ $ % (Plus accrued interest, if any) The Series 1999B Bonds shall be and are hereby designated as Extendable Rate Adjustable Bonds bearing interest at the rate of _ % per annum (subject to adjustment as hereinafter provided) and maturing on the 15th day of November, 20_, $ of the Series 1999C Bonds shaH be and are hereby designated Term Bonds bearing interest at the rate of % per annum and maturing on the 15th day of November, 20_. The Series 1999 Bonds shall bear interest from the Interest Payment Date next preceding the date of authentication unless such date of authentication is an Interest Payment Date. in which case from such date of authentication, or unless such date of authentication is prior to the first Interest Payment Date, in which case from July 1, 1999 as to the Series 1999A Bonds and the Series 1999C Bonds, and from , 1999 with respect to the Series 1999B Bonds, or unless interest is in default, in which case from the Imerest Payment Date as of which interest was last paid. ) (b) The Series 1999B Bonds shall initially bear interest at the Adjusted Rate equal to the Initial Interest Rate until but not including the Initial Rate Change Date and may continue to bear interest at an Adjusted Rate equal to the Reset Rate from and after the Initial Rate Change Date, or from any succeeding Rate Change Date, until the next succeeding Rate Change Date designated for such Series 1999B Bonds, Not less than 75 days prior to each Rate Change Date with respect to the Series 1999B Bonds, the Company shall deliver to the Trustee and the Remarketing Agent written notice of the Company's detennination of the next succeeding Rate Change Date, which Rate Change Date shall be a [November 15] unless the Company specifies in such notice that the Series 1999B Bonds are to bear an Adjusted Rate to maturity; provided, however, that if the Company fails to specify the next succeeding Rate Change Date, such date shall be a [November 15] in such year as will enable the term between the current Rate Change Date and such next succeeding Rate Change Date to equal the preceding term or the final maturity, whichever is earlier. The Adjusted Rate applicable to the Series 1999B Bonds shall be the Reset Rate determined by the Remarketing Agent on a date 65 days prior to the Rate Change Date. The Reset Rate applicable to the Series 1999B Bonds shall be the lowest rate that would, in the judgment of the Remarketing Agent (having due regard to the prevailing market conditions), be necessary to enable the Series 1999B Bonds to be sold at par on the Rate Change Dale, provided that the Reset Rate shall not exceed 15% per annum (the "Maximum Rate"), Upon such determination of the Reset Rate, the Remarketing Agent shall promptly notify the Trustee and the Company of the .::.J 24 Q1-/C( ~.,t.;..;. ~ ~-.,,~",~<"" . ". ' ~ ,f, ~ ..... , -\ Reset Rate. Not less than 60 days prior to the Rate Change Date. the Trustee shall promptly notify each Holder of Series 1999B Bonds in writing by first class mail. postage prepaid. of the Reset Rate that will be applicable to such Series 1999B Bonds on and after the Rate Change Date and provide instructions tor the procedure to be followed by any Holder wishing to tender Series 1999B Bonds for purchase as hereinafter provided. If for any reason the Reset Rate for the Series 1999B Bonds cannot be determined by the Remarketing Agent in the manner specified above. the Reset Rate will be equal to The Bond Buyer Revenue Bond Index (as published in The Bond Buyer or any successor publication thereto) for the most recent period for which such information is available prior to the giving of notice of the Reset Rate by the Trustee to the Holders of the Series 1999B Bonds, or if such index or its equivalent is no longer published. the interest rate currently in effect, provided that such rate may not exceed the Maximum Rate. '-) In addition, the interest rate on the Series 1999B Bonds will not be reset on any Rate Change Date unless (a) at least 75 days prior to such Rate Change Date and (b) on such Rate Change Date, the -Company shall cause to be delivered, at its expense, to the Trustee and the Remarketing Agent an Opinion of Bond Counsel, to the effect that such reset in interest rate and change in the Rate Period will not have an adverse effect on any exemption from Federal income taxation to which the interest on the Series 1999B Bonds would otherwise be entitled. The Company shall use its best efforts to cause such Opinion of Bond Counsel to be delivered to the Trustee by such dates. In the event such Opinion of Bond Counsel is not delivered, the interest rate on the Series 1999B Bonds currently in effect shall remain in effect as the Reset Rate for the next Rate Period, which shall be equal in duration to the preceding Rate Period but shaIJ not in any event extend beyond the date of tinal maturity of the Series 1999B Bonds. SECTION 2.04. Delivery of Series 1999 Bonds: Allocation of Proceeds of the Ser~~ 1999 Bolliis: Company EquitY Contribution. (a) Upon the execution and delivery of thh: Indenture, the Issuer shall cause the execution of the Series 1999 Bonds and their delivery to the Trustee. Thereupon, the Trustee shaH authenticate the Series] 999 Bonds and shall deliver them to, or on the order of, the original purchaser thereof, but only upon the receipt by the Issuer and the Trustee of the Investor Letter in the form attached hereto as Exhibit B. (b) Simultaneously with the delivery of the Series 1999 Bonds, the Trustee shall apply the proceeds of the Series 1999 Bonds as follows: (i) to th~ Interest Payment Account in the Bond Fund, any accrued interest; (ii) to the Debt Service Reserve Fund, $ (iii) to the Projt.>et Fund, the balance of the proceeds of the Seri~s 1999 Bonds. (c) [Simultaneously with the delivery of the Series 1999 Bonds the Company shall d~posit S in immediately available funds with the Trustee which shall be deposited in the Project Fund by the Trustee.] ---J 25 1?" ;r " (d) Prior to delivery by the Trustee of any Series 1999 Bonds. the Trustee must receive a request and authorization, for and in the name and on behalf of the Issuer, signed by an authorized official, to authenticate and deliver the Series 1999 Bonds to, or on the order of, the original purchaser upon payment to the Trustee of the purchase price for the Series 1999 Bonds as provided in the Bond Purchase Agreement related thereto. SECTION 2.05. Issuance and Delivery of Additional Bonds. At the request of the Authorized Company Representative and upon compliance by the Company with the requirements of the Agreement with respect to the issuance or incurrence of Parity Debt, the Issuer may (but shall not be required to) issue Additional Bonds from time to time for any purpose or combination of purposes permitted under the Act or other laws of the State. Those Additional Bonds shall be on a parity with the Series 1999 Bonds and any Additional Bonds issued and outstanding at the time or thereafter under this Indenture; provided that nothing herein shall prevent payment of Debt Service Charges on any series of Additional Bonds from (i) being otherwise secured and protected from sources or by property, instruments or documents not applicable to the Series 1999 Bonds or anyone or more series of Additional Bonds, or (ii) not being secured or protected from sources or by property, instruments or docume~)ts applicable to the Series 1999 Bonds or one or more series of Additional Bonds. ') '- In the event any series of Additional Bonds are issued, the Debt Service Reserve Requirement, if any, with respect to those Additional Bonds shall be as defined in the Supplemental Indenture providing for the issuance of such Additional Bonds; provided that such Additional Bonds shall not be secured by the Debt Service Reserve Fund established for the Series 1999 Bonds. Before the Trustee may authenticate and deliver any series of Additional Bonds, the following items shall have been received by the Trustee: (a) Original executed counterparts of any amenoments of or supplements to the Company Documents and to this Indenture which are necessary or advisable to provide that the Additional Bonds will be issued in compliance with the provisions of this Indenture; (b) One or more Additional Notes, as required by the Agreement, in an aggregate principal amount equal to the aggregate principal amount of the Additional Bonds; (c) Bonds. A copy of the resolution of the Issuer authorizing the issuance of the Additional (d) A request and authorization to the Trustee, for and in the name and on behalf of the Issuer. signed by an authorized ofticia!, to authenticate and deliver the Additional Bonds to, or 'on the order of, the original purchaser upon payment to the Trustee of the amount specified in ,~ 26 19-/~ -........,-"r~.I.. I.~'I-"'''.'.- /) the request and authorization. which amount shall be deposited as determined or designated in or pursuant to the Supplemental Indenture; (e) Original executed counterparts of a Notice of Future Advance under the Mortgage in recordable form; and (t) An opinion of Bond Counsel to the effect that: (i) all conditions precedent under this Indenture to the delivery of the Additional Bonds and any Supplemental Indenture have been fulfilled; (ii) when executed for and in the name and on behalf of the Issuer and when authenticated and delivered by the Trustee. those Additional Bonds will be legal. valid and binding special obligations of the Issuer, enforceablt: in accordance with their terms, subject to reasonable exceptions for bankruptcy t insolvency and similar laws and the application of equitable principles, and will be secured hereunder equally and on a parity with all other Outstanding Bonds (except as otherwise permitted hereunder)~ and , -_/ (Hi) the issuance of the Additional Bonds will not result in the interest on the Series 1999 Bonds to the extent such Series 1999 Bonds are Tax-Exempt Bonds (or other Tax-Exempt Bonds then Outstanding under this Indenture) becoming included in the gross income of the Holders for federal income tax purposes. When the conditions described above authorizing such Additional Bonds have been satisfied, and the Additional Bonds have been executed a'1d authenticatedt the Trustee shaH deliver the Additional Bonds to or on the order of the original purchaser thereof, but only upon payment to the Trustee of the amount specified in the request and authorization to which reference is made above and such amount shall be deposited by the Trustee as specified in such request and authorization, all in conformity with this Indenture. SECTION 2.06. Issuance and Delivery of Notes. At the request of the Authorized Company Representative, the Issuer may, to the extent permitted by law, including without limitation, the Act, issue bond anticipation notes from time to time in anticipation of Additional Bonds for any purpose or combination of purposes permitted under the Act or other laws of the State. The instrument or document providing for the issuance of those notes shall provide that in the event the Issuer or the Company defaults in the observance or performance of any of its covenants, agreements or obligations relating theretot the sole recourse of the holders of the notes shall be to any reserve fund containing proceeds of those notes and the proceeds derived from the issuance of Additional Bonds or renewal notes in anticipation of Additional Bonds issued pursuant to the Act for the same purpose as the original notes. None of those notes may be issued. however, unless there tirst shall have been received by the Trustee the items specified in Section 2.05(a) through (t); provided, that (i) any amendment <) 27 9f,-/r ~~. II"~:'~- ~.".">.~,- '..'.' '". ~'.~'..". ~. < " " IC,) " , ' I" ' "", ~""".I'If,1 '.. -I.: ." II ~" " " 3 " . :.. . ' ; , "." , " ~ ' ,'~"\' V " " , , . or supplement described in Section 2.05(a) shall be deemed to provide for this purpose that the oHigation of the Company to make any payment of principal of, and premium, if any, and interest cr~:the notes will be limited to taking the actions by the Company necessary to cause the issuance , of the Additional Bonds anticipated by the notes or of renewal notes in anticipation of Additional Bonds and specifically will not be secured by any assignment or security interest hereunder or under the Agreement: (ii) for this purpose, all references in those subparagraphs to Additional Bonds shall be deemed to constitute references to the notes; and (iii) the notes shall be payable only as provided above. . ~ , 28 19->16 - --- -..--.------------------------------- -- ----.----" ----------------- ~ ARTICLE III TERMS OF BONDS GENERALLY SECTION 3.01. Form of Bonds. The Series 1999 Bonds, the certificate of authentication thereon, and the form of assignment thereof shall be substantially in the respective form thereof set forth in Exhibit A hereto, with any omissions, insertions and variations which may be authorized or permitted in or pursuant to the Supplemental Indenture, in the case of Additional Bonds, and which are consistent with this Indenture. All Bonds shall be in fully registered form. Except as provided in Section 3.05 hereof, the Holder of a Bond shall be regarded as the absolute owner thereof for all purposes of this Indenture. The Bonds shall be negotiable instruments in accordance whh the Act, and shall express the purpose for which they are issued and any other statements or legends which may be required by law. - .,'\ , 'H/ SECTION 3.02. Variable Terms. Subject to the provisions of this Indenture, each series of Bonds shall be dated, shall mature in the years and the amounts, shall bear interest at the rate or rates per annum, shall be payable on the dates, shall have the Registrar, Paying Agents and Authenticating Agents, shall be of the denominations, shall be subject to redemption on the terms and conditions. and shall have any other terms which are set forth in or for which provision is made in this Indenture, including Exhibit A hereto, in the case of the Series 1999 Bonds, or in or pursuant to the applicable Supp1ementaJ Indenture, in the case of any issue of Additional Bonds. SECTION 3.03. Execution and Authentication of Bonds. Unless provided otherwise in the applicable Supplemental Indenture, each Bond shall be signed by at least two members of the Issuer in their official capacities (provided that those signatures may be facsimiles). In case any officer whose signature, or a facsimile of whose signature, shall appear on any Bond shall cease to be that officer before the issuance of the Bond, that officer's signature or the facsimile- thereof shall be valid and sufficient nevertheless for all purposes, the same as if that officer had remained in office until that time. Any Bond may be executed on behalf of the Issuer by an officer who is the proper officer on the date of execution, although on the date of the Bond that individual is not the proper officer. No Bond shall be valid or become obligatory for any purpose or shall be entitled to any benefit under this Indenture, unless the certificate of authentication thereon shall have been manually signed by the Trustee or by any Authenticating Agent on behalf of the Trustee, The authentication by the Trustee or by an Authenticating Agent upon any Bond shall be conclusive evidence that the Bond so authenticated has been duly authenticated and delivered hereunder and is entitled to the benetit hereof. The certiticate of the Trustee or an Authenticating Agent may be executed by any individual or agent authorized by the Trustee or the Authenticating Agent, but <J 29 99--;ft '1 - -') '.....c....... , 'J it shall not be necessary that the samc authorized individual or agent sign the certificates of authentication on all of the Bonds. SECTION 3.04. Set:urity tor Payment of Bonds. To the extent provided in and except as otherwise permitted by this Indenture. the Bonds shall be limited obligations of the Issuer and the Debt Service Charges thereon shall be (i) payablc equally and ratably from the Revenues and (ii) secured by the Agreement (except for the Unassigned Rights) thereunder, and by the Mortgage; provided, that payment of Debt Service Charges on any series of Additional Bonds may be otherwise sccured and payable from sources or by property or instruments not applicable to the Series 1999 Bonds or one or more series of Additional Bonds, or not secured and protected from sources or by property or instruments applicable to thc Series 1999 Bonds or one or more series of Additional Bonds. Nothing in the Bonds or this Indcnture shall represent or constitute a general obligation, a debt or a pledge of the faith and credit or taXing power of the Issuer and further, nothing therein or herein gives the Holders of any Bonds, and they do not have, the right to have levied ad valorem taxes or other taxes by the Issuer, or by the State or any other political subdivision or agency thereof, for the payment of Debt Service Charges on the Bonds. SECTION 3.05. Payment and Ownership of Bonds. (a) Debt Service Charges shall be payable in lawful money of the United States of America without deduction for the services of the Trustee or any Paying Agent. Subject to the provisions of paragraph (b) of this Section, (i) the principal of and any premium on any Bond shall be payable when due to a Holder upon presentation and surrender of such Bond at the designated corporate trust oftice of the Trustee or at the office, designated by the Trustee, of any Paying Agent, and (ii) interest on any Bond shall be paid on each Interest Payment Date by check or draft which the Trustee shall cause to be mailed on that date to the Holder in whose name the Bond (or one or more Predecessor Bonds) is registered at the close of business on the Regular Record Date applicable to that Interest Payment Date on the Register at the address appearing therein, provided that, at the written request by and expense of any Holder of $100,000 or more principal amount of Bonds, such Debt Service Charges may re paid by bank wire transfer or by direct deposit to the designated account of the Holder. If and to the extent, however, that the Issuer shall fail to make payment or provision for payment of interest on any Bond on any Interest Payment Date, that interest shall cease to be payable to the Person who was the Holder of that Bond (or of one or more Predecessor Bonds) as of the applicable Regular Record Date. Except as provided in paragraph (b) of this Section, whenever moneys become available for payment of the interest (1) the Trustee shall, pursuant to Section 7.07(d), establish a Special Interest Payment Date for the payment of that interest and a Special Record Date which shall be not more than 15 nor tewer than 10 days prior to the Special Interest Payment Date, and (2) the Trustee shall cause notice of the Special Interest Payment Date and of the Special Record Date to be mailed by first class mail, postage prepaid, to each Holder at its address as it appears on the Register not fewer than 10 days prior to the Special Record Date, and thereafter the interest shall be payable on such Special Interest Payment Date to the Person who was the Holder of said Bond (or Predecessor Bonds) at the close of 30 11 ~ !~ ~,",. '.c...:_,:~~.:....:...:....u_~._ I~ business on the Special Record Dare. If any Bond is redeemed on any date which is not an Interest Payment Date, accrued interest thereon shall be paid when the redemption price is paid. If any Bond is redeemed on any Interest Payment Date, the interest due shall be paid in the nonnal manner specified above. (b) Each Bond delivered under this Indenture upon transfer thereof, or in exchange for or in replacement of any other Bond, shall carry the rights to interest accrued and unpaid, and to accrue on that Bond. or which were carried by that Bond. (c) Except as provided in this Section 3.05 and in the first paragraph of Section 3.07 hereof, (i) the Holder of any Bond shall be deemed and regarded as the absolute owner thereof for all purposes of this Indenture, (ii) payment of or on account of the Debt Service Charges on any Bond shall be made only to or upon the order of that Holder or its duly authorized attorney in the manner permitted by this Indenture. and (iii) neither the Issuer, the Trustee, the Registrar nor any Paying Agent or Authenticating Agent shall, to the extent permitted by law, be affected by notice to the contrary. All of those payments shall be valid and effective to satisfy and discharge the liability upon that Bond, including without limitation, the interest thereon, to the extent of the amount or amounts so paid. ' -) SECTION 3.06. Transfer and Exchan2e of Bonds. So long as there are any Outstanding Bonds, the Issuer will cause books for the registration and transfer of Bonds, as provided i,n this Indenture, to be maintained and kept at the designated office of the Registrar. Unless provided otherwise in the applicable Supplcmental Indenture, at the option of the Holder, Bonds may be exchanged for Bonds of any authorized denomination or denominations in an aggregate principal amount equal to the unmatured and unredeemed principal amount of, and bearing interest at the same rate and maturing on the same date or dates as, the Bonds being exchanged. The exchange shall be made upon presentation and surrender of the Bonds being eXChanged at the designated office of the Registrar or at the designated office of any Authenticating Agent together with an assignment duly executed by the Holder or its duly authorized attorney in any form which is satisfactory to the Registrar or the Authenticating Agent, as the case may be. Any Bond may be transferred on the Register, upon presentation and surrender thereof at the designated office of the Registrar or the designated office of any Authenticating Agent together with an assignment duly executed by the Holder or its duly authorized attorney in any form which is satisfactory to the Registrar or the Authenticating Agent, as the case may be. Upon transfer of any Bond and upon the request of the Registrar or the Authenticating Agent, the Issuer shall execute and the Trustee or the Authenticating Agent, as the case may be. shall authenticate and deliver, a new Bond or Bonds in the name of the transferee. of any authorized denomination or denominations in an aggregatc principal amount equal to the unmatured and unredeemed principal amount of. and bearing interest at the same rate and maturing on the same date or dates as, the Bonds presented and surrendered for transfer. 'J 31 9'1, 1ft ) The Trustee shall not register the transfer of any Bond without the prior receipt of evidence acceptable to the Trustee that the transferce is an t1accrcditcd investor" I as defined in Regulation D, or any successor regulation, promulgated by the United State Securities and Exchange Commission, in accordance with the legend on the face of the Bond. Evidence acceptable to the Trustee shall include, but not be limited to, published lists of "institutional investors" maintained by one or more national bond rating services; provided, however, that such term shall not include a book entry depository, including, but not limited to, The Depository Trust Company. In all cases in which Bonds are exchanged or transferred hereunder, the Issuer shall execute, and the Trustee or any Authenticating Agent, as the case may be, shall authenticate and deliver, Bonds in accordance with the provisions hereof. Except as provided in Section 3.07 hereof, the exchange or transfer shall be made without charge; provided that the Issuer and the Registrar or the Authenticating Agent, as the case may be, may make a charge for every exchange or transfer of Bonds which is sufficient in amount to reimburse them for any tax or excise required to be paid with respect to the exchange or transter. The charge shall be paid by the Holder before a new Bond is delivered. '\ I All Bonds issued upon any exchange or transfer of Bonds shall be the valid obligations of the Issuer and shall evidence the same debt and shall be entitled to the same benefits under this Indenture as the Bonds surrendered upon exchange or transfer. Neither the Issuer, the Trustee, the Registrar nor any Authenticating Agent, as the case may be, shall be required to make any exchange or transfer of a Bond (i) during a period beginning at the opening of business 15 days before the day of the mailing of a notice of redemption of Bonds and ending at the close of business on the day of the mailing, or to transfer ~r exchange any Bonds selected for redemption, in whole or in part, following the mailing (ii) during a period beginning on the date the Holder of such Bond delivers to the Trustee a notice described in Section 4.10 hereof and ending on the Optional Tender Date. In case any Bond is redeemed in part only. on or after the redemption date and upon presentation and surrender of the Bond, subject to the provisions of Section 4.04 hereof, the Issuer shall cause execution of, and the Trustee or Authenticating Agent, as the case may be, shall authenticate and deliver, a new Bond or Bonds in authorized denominations in an aggregate principal amount equal to the unmatured and unredeemed portion of, and bearing interest at the same rate and maturing on the same date or dates as, the Bond redeemed in part. The designated office of the Registrar and the Authenticating Agent for purposes of this Section shall be established by the Trustee. SECTION 3.07. Mutilated. Lost. Wron~fully Taken or Destroyed Bonds. If any Bond is mutilated, lost, wrongfully taken, improperly cancelled or destroyed, in the absence of written notice to the Issuer, the Trustee. the Registrar or an Authenticating Agent that the lost, wrongfully taken or destroyed Bond has been acquired by a bona fide purchaser, the Issuer shall execute, and the Trustee or an Authenticating Agent, as the case may be, shall authenticate and '--J 32 '11-1'6 ~!Io.~'"' 'J deliver, a new Bond of like date. maturity. interest rale and denomination as the Bond mutilated. lost, wrongfully taken, improperly cancelled or destroyed; provided, that (a) in the case of any mutilated or improperly cancelled Bond, such Bond shall be surrendered first to the Registrar' or an Authenticating Agent; and (b) in the case of any lost, wrongfully taken or destroyed Bond, there shall be furnished first to the Issuer, the Company, the Trustee and the Registrar or an Authenticating Agent (if different persons) evidence of the loss. wrongful taking or destruction satisfactory to the Trustee and the Registf'dr or the Authenticating Agent, as the case may be, together with indemnification satisfactory to the Trustee and the Registrar or Authenticating Agent (if different persons) indemnifying the Company, the Trustee, the Registrar or Authenticating Agent (if different persons), and the Issuer. ) If any mutilated, lost, wrongfully taken or destroyed Bond shall have matured or been redeemed prior to maturity, instead of issuing a new Bond, the Authorized Company Representative may direct the Trustee to pay that Bond, without surrender thereof, upon the furnishing of satisfactory evidence and indemnification, as in the case of issuance of a new Bond. The Issuer, the Trustee and the Registrar or an Authenticating Agent may charge the Holder of a mutilated, lost, wrongfully taken or destroyed Bond their reasonable fees and expenses in connection with their actions pursuant to this Section, except for improper cancellation by the , Registrar. Every new Bond issued pursuant to this Section by reason of any Bond being mutilated, lost, wrongfully taken, improperly cancelled or destroyed (i) shall constitute a Bond, to the extent of the Outstanding principal amount of, and having the same terms as, the Bond lost, mutilated, laken, improperly cancelled or destroyed, regardless of whether the mutilated, lost, wrongfully taken, improperly cancelled or destroyed Bond shall be enforceable at any time by anyone; and (ii) shall be entitled to all of the benefits of this Indenture to the same extent as the Bond that was mutilated, lost, wrongfully taken or destroyed. All Bonds shall be held and owned on the express condition that the foregoing provisions of this Section are exclusive with respect to the replacement or payment of mutilated, lost. wrongfully taken, improperly cancelled or destroyed Bonds and, to the extent permitted by law. shall preclude all other rights, remedies and powers with respect to the replacement or payment of negotiable instruments or other investment securities without their surrender, notwithstanding any law or statute to the contrary now existing or enacted hereafter. SECTION 3.08. Safekt."eping and Cancellation of Bonds. Any Bond received by the Registrar for replacement pursuant to Section 3.07 hereof or exchanged pursuant to Section 3.06 J 33 qtI,/'K --""Ff.~.I.. i 1,.1< "t- _- b. .,~ ,.. ~ -..- 19- / ~ ~ hereof shall be promptly cancelled by the Registrar and evidence of such cancelIation wiff be delivered by the Registrar to the Issuer and the Authorized Company Representative upon request. The Issuer; or the Company on behalf of the Issuer; may deliver at any time for cancellation to the Registrar any Bonds authenticated and delivered previously hereunder; which the Issuer or the Company may have acquired in any manner whatsoever. All Bonds so delivered shall be cancelled promptly by the Registrar. Certification of such surrender and cancellation shall be made to the Issuer, the Company and the Trustee by the Registrar at least once in each calendar year during which any Bonds were surrendered; cancelled and destroyed. Except as provided in the first paragraph of this Section 3.08 and unless directed otherwise by the Authorized Company Representative, cancelled Bonds shall be retained and stored by the Registrar for a period of seven years after their cancellation. Those cancelled Bonds shall be destroyed by the Registrar by shredding or incineration seven years after their cancellation or at any earlier time directed by the Authorized Company Representative. The Trustee or Registrar; as appropriate, shall furnish counterparts of a certificate of destruction relating to any Bonds destroyed under this Section 3.08 evidencing such destruction to the Issuer and the Authorized Company Representative. ) ...../ SECTION 3.09. Temporary Bonds. Pending the preparation of definitive Bonds, interim receipts or certificates (herein referred to as "Temporary Bonds") may initially be issued, exchangeable for definitive Bonds of the same series when the latter are ready for delivery. Such Temporary Bonds may be primed; lithographed or typewritten, shall be of such denomination or denominations as may be determined by the Issuer, with the approval of the Company and the Registrar and Paying Agent, and may contain such references to any of the provisions of this Indenture as may be appropriate. If Temporary Bonds are issued, the Issuer will cause to be furnished duly executed definitive Bonds as soon as practicable, and thereupon the Temporary Bonds may be surrendered for cancellation at the Principal Office of the Registrar in exchange for definitive Bonds and without charge for such exchange, and the Issuer shall execute and the Trustee or the Authenticating Agent shall authenticate and deliver in exchange of such Temporary Bonds so surrendered an equal aggregate principal amount of definitive duly executed Bonds, of Authorized Denominations and of the same series, interest rate or rates and maturity or maturities. Until so exchanged, the Temporary Bonds shall be entitled to the same benefits under this Indenture as definitive Bonds of the same series delivered hereunder. -J 34 ~......' '!-..... ,~. . ,... 4....~~......T . ~ -.., , .J , :::; ARTICLE IV REDEMPTION OF BONDS; TENDER PROVISIONS SECTION 4.01. Mandatory Sinkin~ Fund Rt.>demplion of Series 1999 BQnds. (a) The Series 1999A Bonds maturing November 15, 20_ are subject to mandatory redemption prior to maturity in part, by lot, on November 15111 of each year, beginning November 15, 20_ at a redemption price equal to one hundred percent (100%) of the principal amount of such Series 1999 Bonds being redeemed plus accrued interest to the redemption dateJ without premiumJ in the following principal amounts and in the following years: ~ Amount *Maturity I (b) The Series 1999C Bonds maturing November 15, 20_ are subject to mandatory redemption prior to maturity in part, by lot, on November ISTII of each year, beginning November 15, 20_, at a redemption price equal to one hundred percent (100%) of the principal amount of such Series 1999 Bonds being redeemed plus accrued interest to the redemption date, without p~emium, in the following principal amounts and in the following years: fur Amount *Maturity (c) The Series 1999B Bonds are subject to mandatory redemption prior to maturity in part, by lot (except that Series 19998 Bonds that have been tendered for purchase on any Optional Tender Date but were not so purchased shall be redeemed prior to the redemption of any other Series 1999B Bonds), on November 15th of each year, beginning November 15, 20 ,at a redemption price equal to one hundred percent (100%) of the principal amount of Series 19998 Bonds being redeemed plus accrued interest to the redemption date, without premium, in the following principal amounts and in the following years: ~ A D10unt * M atu ri ty (d) The principal amount of Series 1999 Bonds required to be redeemed pursuant to the foregoing provisions shall be reduced prorata by amounts equal to such principal amount of 35 q9 - !6 I, "I /") the Series 1999 Bonds of such maturities which are purchased by the Tender Agent or Trustee for cancellation and retirement by the Trust~e with moneys provided by the Company. SECTION 4.02. Extraordinary Redemption Withou: I?remium. (a) At the direction of the Company on behalf of the Issuer, the Series 1999 Bonds are subject to extraordinary optional redemption in whole at anytime or in pan on any Interest Payment Date in Authorized Denominations from the proceeds of insurance or condemnation payments received in excess of $250,000 as a result of damage or destruction or taking under the power of eminent domain of all or a portion of the Mortgaged Property, in either case at a redemption price of 100 percent of the principal amount redeemed plus interest accrued to the redemption date. SECTION 4.03. Optional Redemption of Series 1999 Bonds. (a) The Series 1999A Bonds and the Series 1999C Bonds maturing on or prior to November 15, 20_ are not subject to rt..>demption prior to maturity at the option of the Company. The Series 1999A Bonds and the Series 1999C Bonds maturing on and after November 15, 20_ are subject to redemption prior to their maturity at the option of the Issuer at the written request of the Company on or after November 15,20_ at any time in whole or in part, in order of maturities as shall be determined by the Company and by lot within a maturity, on any Interest Payment Date, at the redemption prices (expressed as percentages of the principal amount thereof) set forth in the table below, plus accrued interest thereon to the date fixed for redemption: ,) Period of Redemption (All dates inclusive) Redemption Prices November 15, 20_ to November 14, 20_ 102% November 15,20_ to November 14, 20_ 101 % November 15, 20_ and thereafter 100% (b) The Series 1999B Bonds may be redeemed in whole or in part on any date occurring within the redemption periods, as set forth below, by the Issuer upon direction of the Company. The redemption price for any such redemption shall be at a redemption price equal to 100% of the principal amount of the Series 1999B Bonds or portion thereof so redeemed on the applicable redemption date, plus accrued interest to the redemption date. (i) During the period between the issuance of the Series 1999B Bonds and the Initial Rate Change Date, the Series 1999B Bonds are subject to optional redemption on or after November 15, 20_ (ii) During any Rate Period of three years in length, the Series 1999B Bonds are subject to optional redemption commencing on the 18-month anniversary of the first day for such Rate Period. () 36 q9-lfl ) (iii) During any Rate Period of five years in length, the Series 1999B Bonds are subjt.'Ct to optional redemption commencing on the 24-month anniversary of the first day of such Rate Period. (iv) During any Rate Period of seven years in length, the Series 1999B Bonds are subject to optional redemption commencing on the 30~month anniversary of the first day of such Rate Period. (v) During any Rate Period of ten or more years in length, the Series 1999B Bonds are subject to optional redemption commencing on the fifth anniversary of the first day of such Rate Period. The Series 1999B Bonds tendered for purchase on any Rate Change Date but not so purchased shall be given priority for redemption on each succeeding optional or extraordinary redemption date until redeemed prior to the optional or extraordinary redemption of any other Series 1999B Bonds. Bond so given priority shall be selected by the Trustee, by lot or in such other equitable manner as the Trustee shall deem appropriate, in the event of insufficient funds to redeem all such Bonds on any particular redemption date. ~,) SECTION 4.04. Partial Redemption. Subject to the provisions of Section 4.03 hereof, if less than all of the Series 1999 Bonds shall be called for redemption, the particular Series 1999 Bonds or portions thereof to be redeemed shall be designated by the Company and, if not designated. the Bonds to be redeemed shall be redeemed in inverse order of maturity; provided, that in any event Unremarketed Bonds shall be redeemed prior to any other Bonds. If less than all Outstanding Bonds of a single maturity are to be redeemed, the selection of Bonds within such maturity, or portions thereof in Authorized Denominations, to be redeemed shall be made by lot by the Trustee in any manner which the Trustee may determine. The Trustee shall. to the extent practicable, select Bonds for redemption as to avoid redeeming any particular Bond in part. SECTION 4.05. Company's Election to Redeem. Except in the case of mandatory redemption, Bonds shall be redeemed only after written notice from the Authorized Company Representative to the Trustee and the Issuer. That notice shall specify the place or places where the amounts due upon redemption are payable, the redemption date, and the principal amount and the maturity of Bonds of each series to be redeemed. The notice shall be given not less than 45 nor more than 60 days prior to the redemption date. SECTION 4.06. Notice of Redemption. (a) When redemption is authorized or required pursuant to the provisions hereof, the Trustee shall give to the Holders notice, at the expense of the Company. of the redemption of the Bonds. Such notice shall state: (i) the CUSIP numbers of all Bonds being redeemed. (ii) the original issue date of such Bonds. (iii) the maturity date and rate of interest borne by each Bond being redeemed, (iv) the redemption date, (v) the redemption price, (vi) the date on which such notice is mailed~ (vii) if less than all Outstanding J 37 11-/C! ') , ~) .. ,~ \;' Bonds are to be redeemed. the Bond number (and, in the case of a panial redcmption of any Bond. the principal amount) of each Bond to be redeemed, (viii) that on such redemption dale there shall become due and payable upon each Bond to be redeemed the redemption price thereof, or the redemption price of the specitied portions of the principal thereof in the case of Bonds to be redeemed in part only, together with interest accrued thereon to the redemption date, and that from and after such date interest thereon shall cease to accrue and be payable, and (ix) that the Bonds to be redeemed, whether as a whole or in part, are to be surrendered for payment of the redemption price at the designated corporate trust oftice of the Trustee at an address specified. (b) Notice of such redemption shall be given by mail, postage prepaid, not more than sixty (60) days or fewer than thirty (30) days prior to said date of redemption, to the Holders of any Bonds to be redeemed. Such mailing shall not be a condition precedent to such redemption, and failure to mail any such notice, or any defcct in such notice as mailed, shall not affect the validity of the proceedings for the redemption of the Bonds. Within sixty (60) days of date of redemption, the Trustee shall give a second notice of redemption by mailing another copy of the redemption notice to the registered Holders of Bonds called for redemption but which have not been presented for payment within thirty (30) days after the date set for redemption. (e) In addition to the forgoing notices, notice of the call for any redemption identifying the Bonds, or portions of Bonds (including CUSIP numbers), and the names of the Registered Holders thereof shall, concurrently with the redemption notices mailed to the Registered Holders of the Bonds to be redeemed, be mailed by registered or certified mail to Ziegler Securities, 215 North Main Street, West Bend, Wisconsin 53905, Attention: Bond Redemption Department, and shall meet the following requirement; provided, however, that failure to provide such further notice of redemption or to comply with the tenus of this paragraph shall not in any manner defeat the effectiveness of a call for redemption if notice thereof is given as prescribed above: Each further notice of redemption shall also be sent by certitied mail or overnight delivery service or telecopy to all registered securities depositories then in the business of holding substantial amounts of obligations of types comprising the Bonds (such depositories now being the Depository Trust Company, New York, New York, Midwest Securities Trust Company, Chicago, Illinois and Philadelphia Depository Trust Company, Philadelphia, Pennsylvania) and to four or more national information services which disseminate notices of prepayment or redemption of obligations such as the Bonds (such infonnation services now being Financiallnfonnation, Inc. 's "Daily Called Bond Service, " Jersey City, New Jersey, Kenny Infonnation Services" Called Bond Service," New York, New York, Moody's "Municipal and Government, II New York, New York and Standard & Poor's "Call Bond Record, It New York, New York). SECTION 4.07. fa)!..ment of Redeemed Bonds. Notice having been mailed in the manner provided herein, the Bonds and portions thercof duly called for redemption shall become due and payable on the redemption date, and upon presentation and surrender thereof at the place or places specified in that noticeJ shall be paid at the applicable redemption price. 38 19-/f6 ') ~~.) \J If moneys for the redemption of all of the Bonds and portions thereof to be redeemed, including without limitation. interest accrucd thcrcon to the redemption date, arc held by the Trustee or any Paying Agent on the redemption date, so as to be available therefor on that date, and if notice of redemption shall have been deposited in the mail as aforesaid, then from and after the redemption date, those Bonds and portions thereof duly called for redemption shall cease to bear interest and shall no longer be considered to be Outstanding. If those moneys shall not be so available on the redemption date, or that notice shall not have been deposited in the mail as aforesaid, those Bonds and portions thereof shall continue to bear interest, until they are paid, at the same rate as they would have borne had they not been called for redemption. All moneys deposited in the Special Funds and held by the Trustee or a Paying Agent for the redemption of particular Bonds shall be held in trust for the account of the Holders thereof and shall be paid te them, respectively, upon presentation and surrender of those Bonds. SECTION 4.08. Variation of Redemption Provisions. The provisions of this Article may be varied by the Supplemental Indenture providing for any serres of Additional Bonds, insofar as they apply to that series. SECTION 4.09. Series 1999B Bond Holders Put Option. (a) Provided that there then be no Event of Default under the Indenture, that the Series 1999B Bonds tendered for purchase shall not have otherwise been called for redemption, and that sufficient funds are available therefor, as hereinafter provided, the Holder of a Series 1999B Bond will have the right to cause such Series 1999B Bond to be purchased on any Optional Tender Date at a price equal to 100% of the principal thereof or any portion of integral multiples of $1,000 (the l'Tender Purchase Price"), upon written notice to the Tender Agent given not less than 30 days nor more than 60 days prior to the applicable Optional Tender Date. The notice required to be given pursuant to this paragraph (the "Tender Notice") (i) shall be irrevocable and binding upon the Holder making such election and any transferee thereof and Oi) shall state the principal amount of such Series 1999B Bonds to be tendered by the Holder to the Tender Agent, for purchase on such Optional Tender Date. The Tender Agent shall, prior to the close of business on the Business Day immediately succeeding the last day upon which a Tender Notice may be given to the Tender Agent, give Immediate Notice to the Trustee, the Company and the Remarketing Agent by telephone (promptly confirmed in writing) or by telecopy of all Tender Notices and the aggregate principal amount of Series 1999B Bonds to be tendered for purchase on such Optional Tender Date. The tendering of Series 19998 Bonds by any Holder shall be in accordance with the instructions delivered to such Holder by the Tender Agent, specifying the procedures to be followed in order to tender such Series 1999B Bonds for purchase on an Optional Tender Date. Failure of any Holder of Series 1999B Bonds to give a Tender Notice, or the failure of such Holder to comply with the procedures descrilx..>d in the immediately preceding sentence shall result in such Holder's loss of the right to tender Series 1999B Bonds for purchase on such Optional Tender Date. Interest for the six-month period immediately prior to the date of such purchase will 39 q9--1<6 ,') be mailed to the holder of such Series 1999B Bond as registered on the 15th day of the month . (whether or not a business day) of the month immediately preceding the date of such purchase. (b) Prior to 10:30 a.m.. Chkago Time, on each Optional Tender Date. the Holders of the Series 1999B Bonds to be tenden.>d for purchase on such date shall deliver to the Tender Agent the Series 1999B Bonds to be tendered for purchase on such date accompanied (if required by the Trustee) by a written instrument or instruments of assignment or transfer in the form satisfactory to the Trustee transferring such Bonds to such person or persons as the Remarketing Agent in its sole discretion shaH designate, or if the Remarkcting Agent shall not have made any such designation, then to the Tender Agent to be held and registered in accordance with the provisions of Section 4.13 hereof. If a Holder tiles the requisite Tender Notice but fails to deliver the Series 1999B Bonds so tendered, such Series 1999B Bonds, upon deposit with the Tender Agent on the Optional Tender Date of the Tender Purchase Price, shall be deemed purchased and no longer outstanding, and the Holder of such Series 1999B Bonds shall thereafter look solely to the Tender Purchase Price held by the Tender Agent without interest. (c) On the Optional Tender Date, the Tender Agent will pay the Tender Purchase Price of the Series 1999B Bonds to be so purchased from the following sources and in the order listed: .,..... 'l .,_"J' (i) proceeds of the remarketing of the Series 19998 Bonds deposited with the Tender Agent by the Remarketing Agent pursuant to the terms of the Remarketing Agreement; and (ii) moneys deposited by the Company pursuant to Section 5.20 of the Agreement with the Trustee, for the purpose of paying the Tender Purchase Price of the Series 1999B Bonds to be so purchased, which shall be transferred by the Trustee to the Tender Agent to pay such Tender Purchase Price. To the extent that Series 1999B Bonds for which the Remarketing Agent has written confi rmations of sale are not sold and cash proceeds made available to the Tender Agent as provided in Section 4.13 hereof, the Remarketing Agent promptly shall so notify in writing the Trusteet and the Trustee shall take action pursuant to Section 4.10 hereof to obtain the balance of the Tender Purchase Price from the Company, in accordance with Section 5.20 of the Agreement. In the event the Remarketing Agent sells additional Series 1999B Bonds between the date of the notitication required by the immediately preceding paragraph and the Optional Tender Date, the Remarketing Agent shall promptly h0tify in writing the Tender Agent that the moneys required to accomplish the purchase of all Series 1999B Bonds tendered for purchase is to be reduced in an amount equal to the sales price of any such additional Series 1999B Bonds which have been sold. In such case, any unused moneys derived from the Company shall be returned promptly to the Company in accordance with Section 4.1O(b) hereof. ' '., J 40 qtj-/~ ~"""-~~""::'~...:- --~_.:..:.:_...:.~--._.- -J (d) The Trustee has becn appointed Tcndcr Agcnt in ordcr to pcrfonn thc duties of such Tender Agent as required by this Indenture. Thc Company, with thc prior written approval of the Issuer, shall have the right. from time to time. to appoint anothcr Tender Agent by giving written notice to the pcrson thcn scrving as Tender Agent and to the Trustee of such appointment. The Tender Agent may at any time resign and be discharged of thc duties and obligations created by the Indenture by giving at least sixty (60) days written notice to the Issuer, the Company, the Remarketing Agent and the Trustee. The successor Tendcr Agent will be designated pursuant to Section 6.14 hereof. ~_.,-i SECTION 4.10. Moneys to Purchase Series 1999B Bonds: Duties of Tender &rnt. (a) Upon receipt of the notice described in Section 4.09(a). the Tcnder Agent shall give Immediate Notice to the Remarketing Agent, the Company and thc Trustee stating the aggregate principal amount of Series 1999B Bonds, if any, which have becn properly tendered and delivered to the Tender Agent for purchase on thc Optional Tender Date. At least three (3) business days preceding the Optional Tender Date, the Remarketing Agent shall give telephonic or telegraphic notice confinned in writing to the Trustee specifying (i) the principal amount of thc Series 1999B Bonds, if any, sold by it for which proceeds will be available on the Optional Tender Date and (ii) the principal amount of the Series 1999B Bonds required to be purchased which have not been remarketed (UUnremarketed Donds"). Immediately following the receipt of such notice the Trustee shaH give telephonic notice, confirmed by written notice, to the Company of the amount of Unremarketed Bonds and the amount of the aggregate Tender Purchase Price associated therewith. Upon receipt of such notice from the Trustee, the Company shall notify the Trustee of the amount of funds available pursuant to Section 5.20 of the Agreement to purchase any or all of the Unremarketed Bonds. The Tender Agent shall, sell to the Company, all or a portion of the Unremarketed Bonds on the Optional Tender Date, with payment to. be made directly by the Company to the Trustee in immediately available funds on such Optional Tender Date. (b) Any moneys received from or for the account of the Company pursuant to this Section in the form of immediately available funds paid by the Company shall be held by the Trustee or the Tender Agent as trust funds in a separate fund established for such purpose (the "Extendables Purchase Fund") to be used solely for the purpose of purchasing Unremarketed Bonds and shall be delivered, to the extent necessary, to the Tender Agcnt on the Optional Tender Date in the amount sufficient to effect the purchase of duly tendered Series 1999B Bonds on such date. In the event all of the moneys so received are not required to be used to purchase Series 1999B Bonds on such date, any excess moneys shall be returned by the Tender Agent to the Trustee and then by the Trustee to the Company or the appropriate Special Fund, whichever was the source of such excess moneys. SECTION 4.11. Failure to Rcmarket Tendered Series 1999B Bonds. In the event there are not sufficient moneys available from the sources provided in Section 4.10 hereof to pay the principal of the Series 1999B Bonds tendered for purchase on the Optional Tender Date, the Trustee, after notitication in writing from the Tender Agent, will determine by lot the Series 1999B Bonds to be purchased on such Optional Tender Date, and the remaining tendered Series ~ 41 CfI-I<t '" ~ 1999B Bonds shall be treated as tendered for purchase on each next succeeding Optional Tendcr Date unlcss the Trustee shall receive at least 45 days prior to any such succeeding Optional Tender Date a properly executed notice signed by the Registered Holder; or by its attorney-in-fact duly authorized in writing, stating thalthe tender of such Series 1999B Bonds has been withdrawn (the uTender WithdrawalU). Failure to purchase all Series 1999B Bonds tendered for purchase on a particular Optional Tender Date because of an insufficiency of money to effect such purchase shall not constitute an Event of Default under this Indenture. Unremarkcted Bonds tor which a Tender Withdrawal has not been received will be selected for redemption pursuant to any partial redemption of the Series 1999 Bonds as set forth in Section 4.04 hereof prior to the selection of other Bonds of the same maturity and type. SECTION 4.12. Remarkcting of Series 1999B Bonds. The Remarketing Agent shall offer tor sale and use its best efforts to sell all Series 1999B Bonds tendered to the Tender Agent tor purchase pursuant to the provisions of Section 4.09 hereof and the Remarketing Agreement, any such sale to be made on the Optional Tender Date on which such Series 1999B Bonds arc to be purchased. ", ,._,~j SECTION 4.13. Delivery of Series 1999B Bonds and Proceeds of Sale. (a) Series 1999B Bonds sold by the Remarketing Agent pursuant to Section 4.12 hereof shall be delivered by the Tender Agent to the Trustee for registration of transfer. The Trustee shall register the transfer of such Series 1999B Bonds in accordance with written instructions received by it from the Remarketing Agent prior to 10:30 a.m., Chicago Time. on the business day immediately preceding the Optional Tender Date and shall authenticate and deliver new Series 1999B Bonds in an equal aggregate principal amount to the Remarketing Agent for redelivery to the purchasers thereof. (b) Series 19998 Bonds purchased by the Tender Agent with moneys provided by the Company shall be cancelled. (c) Series 1999B Bonds delivered to the Tender Agent as provided in this Section 4.13 (and not cancelled pursuant to paragraph (b)) shall; subject to the Tender Withdrawal provisions of Section 4.11 hereof; be registered by the Trustee in the manner directed in writing by the Remarketing Agent. The Trustee shall have no liability or responsibility for the Remarketing Agent1s sale and disposition of Series 1999B Bonds. (d) The Remarketing Agent shall pay to the Tender Agent, on the Optional Tender Date, in immediately available funds, the purchase price for Series 1999B Bonds which have been remarketed by the Rcmarketing Agcnt. The moneys so received by the Tender Agent shall be distributed to Holders who shall have properly tendered and delivered Series 1999B Bonds for purchase and which have been rcmarketed or cancelled. J 42 Cj1-/~ I. ') (e) The Tender Agent agrees, and will cause each of its agents to agree. that it will (i) hold all Series 1999B Bonds delivered to it hereunder in trust solely for the benefit of the respective Bondholders that shall have so delivered such Series 1999B Bonds until moneys representing the purchase price of such Series 1999B Bonds shall have been delivered to or for the account of or to the order of such Bondholders; and (ii) deposit all moneys delivered to it hereunder for the purchase of Series 1999B Bonds in the Extcndables Purchase Fund and hold such moneys in trust solely for the benefit of the person or entity which shall have so delivered such moneys, until the Series 1999B Bonds purchased with such moneys shall have been delivered to or for the account of such person or entity. SECTION 4.14. No Purchases or Sales After Event of Default. Anything herein or in the Agreement to the contrary notwithstanding, there shall be no purchases or sales of Series 1999B Bonds pursuant to this Article IV at any time (i) during the continuance of an Event of Default that consists of the failure to pay, when due, any payment (of, premium or interest on. any Bond), or (ii) after the Trustee shall have received written notitication that an Event of Default (other than as described in the preceding clause (i)) has occurred under the Indenture and such Event of Default is continuing. ...~"\ I SECTION 4.15. Remarketin2 A2ent. B. C. Ziegler and Company, is hereby appointed as the Remarketing Agent'for the Series 1999B Bonds. The Company shall have the right, from time to time, to remove the Remarketing Agent and appoint a successor Remarketing Agent by giving wriuen notice to the person or persons then serving as Remarketing Agent, to the Issuer and to the Trustee of such appointment; provided. however, the Remarketing Agent may not be changed during the period commencing one hundred twenty (120) days prior to an Optional Tender Date and ending thirty (30) days after an Optional Tender Date. As a condition precedent to serving as ~emarketing Agent, the Remarketing Agent shall deliver to the Tru3-tee and the Company a written agreement signifying its acceptance of the duties and obligations imposed upon it hereunder pursuant to the provisions of which, in addition to any other provisions contained therein. the Remarketing Agent shall: (a) designate the office Of oftices at which it intends to conduct its activities as Remarketing Agent and to which Series 1999B Bonds, moneys, notices and communications are to be delivered and sent; and (b) use its best efforts in accordance with the Rcmarkcting Agreement to remarket Series 1999B Bonds delivered to it at a market percentage of par; and (c) keep such books and records as shall be consistent with prudent industry practice and make such books and' records available for inspection by the Issuer, and Trustee and the Company at all reasonable times. .~ 43 Cf9 ~ I~ ~'i~~ . . .. . -..li...-~. L a~~~.~ ", I, I', , ':7) .~..:..~~ J' :: ",,~) 2)' ,j' SECTION 4.-16. Resi2nation of Remarketin2 A2ent. Any Remarketing Agent may aL any Lime resign and be discharged of the duties and responsibilities created by this Indenture by giving at least ninety (90) days' written notice to the Issuer, the Trustee and the Company; ,provided, however, no such resignation shall be effective during 'the period commencing one hundred twenty (120) days prior to an Optional Tender Date and ending thirty (30) days after an Optional Tender Date. In the event of the resignation or removal of any Remarketing Agent. the Remarketing Agent shall pay over. assign and deliver any moneys and Series 19998 Bonds held by it in such capacity to its successor. In the event that the Company fails to appoint a successor Remarketing Agent" the interest rate in place prior to a Rate. Change Date shall remain the same after the Rate Change Date. ' 44 " Q1,- /~ . _l...~..... /~ ~-.... 'J ,...) ARTICLE V FUNDS AND PAYMENTS SECTION 5.01. Creation of Funds. In addition to th~ Ext~ndables Purchase Fund created pursuant to Section 4.10 hereof, the tunds and accounts described in this Section are created hereby and are designated as indicated. Each fund and account is to be maintained in the custody of the Trustee as a separate trust account (except when invested in Eligible Inv~stments), provided that separate subaccounts may be maintained in any such account and separate accounts may be maintained in the Bond Fund. The funds and accounts are: (a) the Bond Fund designated the "City of Clearwater, Florida (BEF, Inc. Project) -- Bond Fund" and the Principal Payment Account and the Interest Payment Account therein; (b) the Rebate Fund designated the "City of Clearwater, Florida (BEF, Inc. Project) -~ Rebate Fund"; (c) the Debt Service Reserve Fund designated the "City of Clearwater, Florida (BEF, Inc. Project) -- Debt Service Reserve Fund"; (d) the Project Fund designated the "City of Clearwater, Florida (BEF, Inc. Project) -- Project ~und. " The Bond Fund, the Debt Service Reserve Fund. the Project Fund and the Extendables Purchase Fund are hereby designated as the I1Special Funds". The proceeds of the sale of the Series 199;) Bonds (including without limitation, premium, if any, and interest accrued thereon) shall be allocated and deposited by the Trustee pursuant to Section 2.04 hereof. SECTION 5.02. Application of Loan Payments and Additional Payments. So long as there are any Series 1999 Bonds Outstanding, all Loan Payments and Additional Payments shall be paid monthly, not later than the 25th day of the next preceding month, by the Company directly to the Trustee, shall be in an amount sufficient to make the payments described below, and after payment of any fees due the Trustee, shall be deposited by the Trustee as follows: (a) To the Bond Fund (i) into the Interest Payment Account on each Loan Payment Date beginning November 15, 1999, not less than the approximate equal monthly amount necessary, together with the moneys on deposit in the Interest Payment Account and available for that purpose on that date, to pay in full the interest due on the Bonds on the next succeeding Interest Payment Date, and 45 11-/t /,"", r ......) t ..~ . J ....", l . ~ . -......... ~. T (ii) into the Principal Payment Account on each Loan Payment Date beginning November 15, 2001, not less than the approximate equal monthly amount necessary to pay in full the principal of the Bonds that will bccome due and payable on the next succeeding Principal Payment Date (whether by payment at stated maturity or by mandatory sink'ing fund red~rnption); less (1) in each case, the moncys on dcposit in the Principal Payment Account and available for that purpose on that date. and (2) in the case of redemption pursuant to the mandatory redemption requirements described in Section 4.01, the amount, jf any, of credit described in Section 4.01(c:) hereof; which amounts required to be deposited into the Bond Fund may be deposited in the form of either or both money or Eligible Investments of those maturities which will be sufficient without further investment or reinvestment to produce the amounts required to be on deposit tive days prior to the next succeeding Interest Payment Date or Principal Payment Dare. as applicable; and (b) To the Debt Service Reserve Fund (i) on or prior to each Loan Payment Date, beginning in the sixth months following any months in which the amount on deposit in the Debt Service Reserve Fund falls below the Debt Service Reserve Requirement because moneys are transferred from the Debt Service Reserve Fund to the Bond Fund to make up a deficiency in the Bond Fund (as permitted under the provisions of Section 5.06 hereot), not less than one-twelfth (1112th) of the amount so transferred until the balance in the Debt Service Reserve Fund equals the Debt Service Reserve Requirement, and (ii) on or prior to each Loan Payment Date~ beginning in the month foflowing the month in which the Company receives notice pursuant to Section 5.11 hereof that the balance in the Debt Service Reserve Fund is below an amount equal to ninety percent (90%) of the Debt Service Reserve Requirement, an amount not less than Ont~-fourth of the deticiency determined pursuant to Section 5.11 until the balance in the Debt Service Reserve Fund equals the Debt Service Reserve Requirement; provided, that in the event that it is determined pursuant to Section 5.11, subsequent to the occurrence of the events described in (i) and (ii) above, that the amount on deposit in the Debt Service Reserve Fund is not less than the Debt Service Reserve Requirement, the obligation to make payments under this paragraph shalf end; and (c) In each case and on each Loan Payment Date any amount which may be necessary to make up any previous deticiency in any of the paymcms described above and to make up any deticiency or loss in the respective funds or accounts to which payments are required to be made. The Loan has been made to the Company pursuant to the Agreement, and the Loan Payments required under the Agreement arc to be remitted directly to the Trustee in the manner described therein and in the amounts set forth in paragraphs (a) and (b) above.c 46 CJ9-(r '-) For purposes of this section, (i) a deficiency in the Interest Payment Account or the Principal Payment Account shall be the difference by which the respective amounts then held therein are less than the respective amounts then scheduled to be held therein pursuant to the applicable provisions of this Article V. and (ii) a deficiency in the Debt Service Reserve Fund shall be the difference by which the amount then held therein is less than the Debt Service Reserve Requirement. SECTION 5.03. Bond Fund. The Bond Fund (and the accounts therein for which provision is made in this Indenture) and the moneys and Eligible Investments therein shall be used solely and exclusively for the payment of Debt Service Charges as they become due at stated maturity, by redemption or pursuant to the mandatory sinking fund requirements under Section 4.01 hereof or for the payment of the purchase or redemption price of Bonds pursuant to Section 4.07 hereof, all as provided herein; provided, that no part thereof shall be used to redeem any Bonds prior to maturity, except as may be provided otherwise herein or in the Agreement. The Issuer shall have no interest in the moneys or Eligible Investments in the Bond Fund. For the purposes of transferring to any other Paying Agents moneys which are necessary to pay the Debt Service Charges on the Bonds on or before the date when they become due and payable, the Trustee shall withdraw from the Bond Fund moneys which are available for the purpose of paying, and which are sufficient to pay, Debt Service Charges as and when they become due and payable (whether at stated maturity or by redemption). ''\ " In addition to the deposits to be made in the Bond Fund as contemplated otherwise herein. there shall be deposited into the Interest Payment Account and the Principal Payment Account, as and when received, all moneys received by the Trustee which are to be deposited in the Interest Payment Account or the Principal Payment Account under the Agreement, or any other instrument or document. Amounts so deposited in the Bond Fund shall be applied by the Trustee on the next Interest Payment Date to pay Debt Service Charges on the Bonds. SECTION 5.04. Proiect Fund. Moneys in the Project Fund shall be disbursed in accordance with the prov!sions of the Agreement. The Trustee shall cause to be kept and maintained adequate records pertaining to the Project Fund and all disbursements therefrom. If requested by the Issuer or the Authorized Company Representative, after the Project has been completed and a certificate of payments of all costs is filed as provided in (a) below, the Trustee shall file with the Issuer and the Company, at the Company's expense, copies of the records pertaining to the Project Fund and disbursements therefrom. (a) The completion of the Projl.'Ct (or any addition thereto tinanced with any Additional Bonds) and payment of all costs and expenses incidelll thereto shall be evidenced by the tiling with the Trustee of (i) the certificate of the Authorized Company Representative required by Section 3.6 of the Agreement, and '"-'} 47 qq- If{ l .n, ,~/ J ~. '.-.......;... .~. ,.~..' ~, (ii) a certificate signed by the Authorized Company Representative stating that all obligations and costs in connection with the Project and payable out of the Project Fund have been paid and discharged, except for amounts retained by the Trustee as provided under the Agreement for the payment of costs of the Project not then due and payable. As soon as practicable after the tiling with the Trustee of the certificate to which reference is made in clause (ii) above, any balance remaining in the Project Fund (other than the amounts retained by the Trustee as described in the preceding sentence) shall be deposited or applied in accordanl.:e with the direction of the Authorized Company Representative pursuant to Section 3.4 of the Agreement. Unless otherwise provided in the applica~le Supplemental Indenture, this Section shall apply to any additional property linanced with the proceeds of any issue of Additional Bonds. SECTION 5.05. Rebate Fund. Money and investments in the Rebate Fund shall not be used for the payment of principal, premium. if any. or interest on the Bonds, and any provision hereof to the contrary notwithstanding, amounts credited to the Rebate Fund shall be free and clear of any lien hereunder. Moneys in the Rebate Fund shall be invested pursuant to the procedures and in the manner provided in Section 5.10 hereof. The Issuer, the Trustee and the Company have agreed to comply with the Arbitrage Rebate Agreement to which each is a party in order to comply with the requirements of Section 148 of the Code. Under Section 2.3(h)(G) of the Agreement, the Company is required to make the payments described in this Section. The Trustee shaH timely furnish investment and account information to and the Company shall engage (at the expense of the Company) a Rebate Analyst to calculate the amount of any Rebateable Arbitrage (as defined in the Arbitrage Rebate Agreement) as of the end of that Bond Year. Upon the occurrence of an Event of Default hereof, the Trustee shall calculate. or shall furnish infonnation to and engage (at the expense of the Company) a rebate Analyst to calculate the amount of any Rebateable Arbitrage (as defined in the Arbitrage Rebate Agreement) as of the date detennined by the Trustee pursuant to this Section or as of the, date of release of this Indenture under Article IX hereof. as applicable. After each such calculation, the Trustee thereafter shall notifY the Company in writing of the amount of such Rebateable Arbitrage and the amount then on deposit in the Rebate Fund. If the amount then on deposit in the Rebate Fund is in excess of the Rebateable Arbitrage, the Trustee shall forthwith pay that excess amount to the Company, after paying the cost of such calculation; provided that no such excess amount shall be paid to the Company if a Default or an Event of Default has occurred and is continuing hereunder. If the amount then on deposit in the Rebate Fund is less than the Rebateable Arbitrage. the Company shall, within seven days after receipt of the aforesaid nOEice from the Trustee. pay to the Trustee for deposit in the Rebate Fund an amount sufficient to cause the Rebate Fund to contain an amount equal to the Rcbateable Arbitrage and the cost of such calculation. Trustee shall be entitled to conclusively rely on any calculation or instruction furnished to the Trustee by the Company in accordance with this Section 5.05. 48 19--lft .~'\ ; " : . ..~/ ',..) SECTION 5.06. Debt Service Reserve Fund. In the event that moneys in the Interest Payment Account or moneys in the Principal Payment Account are insuft1cient on any date on which Debt Service Charges on the Outstanding Bonds secured by the Debt Service Reserve Fund are due (whether at stated maturity, by mandatory redemption or upon acceleration) to pay such interest or principal and any premiumt respectively, the Trustee shall withdraw from the Debt Service Reserve Fund the moneys necessary to make up the deficiency and shall transfer those moneys to the Interest Payment Account or the Principal Payment Account as the case may be. [Not less than ten (10) days prior to any withdrawal of moneys from the Debt Service Reserve Fund which would cause the amount in the Debt Service Reserve Fund to be less than amount required to fund the minimum liquid reserve under Section 651.035(1), Florida Statutes, as amended, notice of the withdrawal from the Debt Service Reserve Fund shall be given by the Trustee by telephone (904-487-3828) (promptly continned in writing) or facsimile (904-487-0313) to the Florida Department of Insurancet Bureau of Specialty Insurers, Room 637, Larson Building, 200 East Gaines Street, Tallahassee, Florida 32399-0300 (the "Department of Insurance"), provided that such notice by telephone, by facsimile or in writing may be given to the Department of Insurance at other telephone numbers or other addresses if required by the Department to be used in lieu of the foregoing.] When the amount on deposit in the Debt Service Reserve Fund is at least equal to the principal amount of the Outstanding Bonds secured by the Debt Service Reserve Fund, the Trustee shall transfer from the Debt Service Reserve Fund to the Principal Payment Account an amount equal to the principal of the Bonds secured by the Debt Service Reserve Fund due and payable on the next succeeding Principal Payment Date. Those moneys shall be used to pay the principal of Bonds due on such date. The reduction in the Debt Service Reserve Requirement resulting from that transfer need not be restored. When the amount on deposit in the Debt Service Reserve Fund is in excess of the Debt Service Reserve Requirement the Trustee shall transfer the excess to the Imerest Payment Account of the Bond Fund to be used by the Trustee to pay Debt Service Charges. SECTION 5.07. Moneys to be Held in Trust. All moneys required or permitted to be deposited with or paid to the Trustee or any Paying Agent under any provision of any Issuer Document including without limitation, any invesunents thereof and income thereon, shall be held by the Trustee 01' that Paying Agent in trust. Except for (i) moneys deposited with or paid to the Trustee or any Paying Agent for the redemption of Bonds, with respect to which notice has been duly given; and (ii) moneys held by the Trustee pursuant to Section 5.08 hereof; all moneys described in the preceding sentence held by the Trustee or any Paying Agent shall be subject hereto while so held. SECTION 5.08. Nonpresentment of Bonds. In the event that any Bond is not presented for payment when the principal thereof becomes due in whole or in part, either at stated marurity or by redemption, or in the event that a check or draft for interest is uncashed, if moneys sufticient to pay that principal or the check or draft shall have been made available to the Trustee 49 I" q9~ /g , .' for the benefit of the respective Holder. thereupon. (i) all liability of the Issucr to that Holder for payment of that principal, premium or of the interest rcpresented by the check or draft shall cease and be discharged completely; and (ii) it shall be the duty of the Trustee to hold those moneys. without liability for interest thereon. in a separate account of the Bond Fund for the exclusive benefit of that Holder, who shall be restricted thereafter exclusively to those moneys for any claim of whatever nature on its part hereunder or on, or with respect to, that principal, premium or interest or of such check or draft. Any of those moneys which shall be so held by the Trustee, and which remain unclaimed by the Holder of a Bond not presented for payment or check or draft not cashed for a period of four years after the due date thereof. shall be paid to the Company free of any trust or lien. upon a request in writing by the Company Representative and after the Company provides the Trustee with indemnification, satisfactory to the Tmstee, with respect to any claims to such moneys. Thereafter, the Holder of that Bond shall look only to the Company for payment and then only to the amounts so received by the Company without any inierest thereon, and the Trustee shall not have any responsibility with respect to those moneys. .-) '-, SECTION 5.09. Application of the Balances of the Special Funds. Except as provided in Sections 5.08 and 5.12 hereof, after all of the Outstanding Bonds have been deemed to have been paid and discharged under the provisions of this Indenture, and the fees, charges and expenses of the Trustee, any Paying Agent, the Registrar and any Tender Agent and all other amounts required to be paid hereunder and under the Agreement have been paid, any amounts remaining in the Special Funds shall be free of this Indenture and shall be paid, used and applied pursuant to the Agreement. SECTION 5.10. Investments of Special Funds and the Rebate Fund. Moneys held for the credit of all Special Funds and the Rebate Fund in the custody of the Trustee shall be continuously invested and reinvested to the extent practicable by the Trustee in Eligible Investments at the oral direction, confirmed in writing, or written direction of the Authorized Company Representative. Any investments of moneys held to the credit of the Special Funds and the Rebate Fund shall mature not later than the respective dates when the money held for the credit thereof or accounts therein will be required for the purposes intended; provided, that no Eligible Investments in any fund or account (other than the Rebate Fund) may mature beyond the latest maturity date of any Bonds Outstanding at the time such investments are deposited. No less than 50% of the Debt Service Reserve Requirement shall be invested in (a) Eligible Investments (i) rated by a Rating Service in one of the two highest raling categories and (ii) having maturities of one year or less, or (b) a mutual fund invested primarily in securities of that type. The balance of the Debt Service Reserve Requirement shaH be invested in Eligible Investments with an average maturity not exceeding five years. The Authorized Company Representative may at any time give to the Trustee written directions effective for a specified period respecting the investment of any money or certain , - ---I 50 19--/~ , _d'!' :1 \...... ?) moneys in the Special Funds and the Rebate Fund required to be invested hereunder, subject. however, to the provisions of this Section. and the Trustee shall invest such money under this Section as so directed by the Authorized Company Representative. The Trustee may request, in writing, direction or authorization of the Authorized Company Representative with respect to the proposed investment of money under the provisions of this Indenture. Upon receipt of such request, accompanied by a memorandum setting forth the details of any proposed investment, the Authorized Company Representative will either approve such proposed invcstment or will give written directions to the Trustee respecting the investment of such money and, in the case of such directions, the Trustee shall then, subject to the provisions of this Section. invest such money in accordance with such directions. Eligible lnvestments credited to any Special Fund or the Rebate Fund in the custody of the Trustee established under this Indenture shall be held by or under the control of the Trustee and while so held shall be deemed at all times to be pan of such fund or account in which such money was originally held. '-"\ -,/ Any profit or loss realized or interest earned from the investment of any Special Funds during the construction period shall be credited to the Project Fund and any profit or loss realized or interest earned from the investment of any Special Funds after the termination of the construction period shall be credited to the Intercst Payment Account of the Bond Fund. Any profit realized or interest earned from the investment of the Rebate Fund shall remain in the Rebate Fund to the extent of any deticiency in the amount required to be in the Rebate Fund; if adequate funds exist in the Rebate Fund, any such profit realized or interest earned, shall be deposited in the Bond Fund to be used to pay Debt Service Charges on the Bonds. The Trustee shall sell at the best price obtainable or present for redemption any obligations so purchased whenever it shall be necessary to do so in order to provide money to make any payment or transter of money from any such fund or account. The Trustee shall not be liable or responsible for any loss resulting from any such investment made at the direction of the Authorized Company Representative. The Trustee may make any investments permitted under this Indenture through its own bond department or the bond department of any bank or trust company which is an affiliate of the Trustee. The Trustee in its discretion may make any investments permitted under this Indenture through the Trustee in its capacity as a bank or through any bank or trust company which is an affiliate of the Trustee. SECTION 5.11. Valuation. For the purpose of dctcrmining the amount on deposit to the credit of any fund or account, the value of Eligible Investments in which money in such fund or account shall have been invested shall be computed at the market value or amortized cost, whichever is lower. ]n calculating the value of any Eligible Investment, the amount of accrued interest on that Eligible Investment shall be included. The Trustee shall value the Eligible Investments in the Debt Service Reserve Fund at least quarterly and at any time upon the request u 51 11-/~ II ~ .) .-j :) of the Authorized Company Representative or the Florida Department of Insurance on reasonable notice to the Trustee (which period of notice may be waived by the Trustee). A copy of ca~h such valuation shall be provided by the Trustee to the Company and the Florida Department of Insu~ance at the address set forth in Section 5.06 hereof. ]1' as a result of any valuation, it is determined that the balance in the Debt Service Reserve Fund is less than 90% of the Debt Service Reserve Requirement, the Trustee shalt compute the amount by which the Debt Service Reserve Requirement exceeds such balance and shall immediately give the Company notice of such deficiency and the amount, if any, necessary to cure the same in accordance with the provisions of Section 5.02(b)(ii) hereof. SECTION 5.12. Repayment to the Company. Any amounts remaining in the Special Funds after (i) all of the Outstanding Bonds shall be deemed to have been paid and discharged under the provisions of this Indenture, and (ii) after payment of all tees, charges and expenses of the Trustee~ the Registrar and any Tender Agent, Paying Agents, Remarketing Agent or Authenticating Agents and of all Rebate Amounts and other amount required to be paid under this Indenture, the Agreement, the Mortgage and the Notes or any other instrument or document , entered into in connection with any of the foregoing or otherwise to provide for the payment of Debt Service Charges, shall be paid to the Company to the extent that those moneys are in excess of the amounts necessary to effect the payment and discharge of the Outstanding Bonds. 52 ,q1~ I~ -~:..:......o..-.~~:'_":"-.':::'..,_._'___. ,. 'kg.... I' ~ . ~> ., + ~..~. . , ~) ARTICLE VI TRUSTEE. REGISTRAR, PAYING AGENTS, AUTHENTICATING AGENTS AND TENDER AGENTS SECTION 6.01. Trustee's Acceptance and Res.ponsibiliri~. The Trustee accepts the trusts imposed upon it by this Indenture. and agrees to observe and perform those trusts, but only upon and subject to the terms and conditions set forth in this Article. to all of which the parties hereto and the Holders, by their acceptance of Bonds, agree. (a) Prior to the occurrence of a Default or an Event of Default of which the Trustee has been notitied, as provided in Section 6.02(t) hereof, or of which by that subparagraph the Trustee is deemed to have notice, and afler the cure or waiver of all Defaults or Events of Default which may have occurred, (i) the Trustee undertakes to perform o'nly those duties which are described specifically in this Indenture, and no additional duties of the Trustee shall be implied; --." \ ...1 (ii) in the absence of bad faith on its partt the Trustee may rely conclusively, as to the truth of the statements and the accuracy of the opinions expressed therein, upon certificates or opinions furnished to the Trustee and which confonn to the requirements of this Indenture. The Trustee is under a duty to examine any certificates or opinions, which are required specitically hereunder to be furnished to it, to determine whether they conform to the requirements of this Indenture. (b) In case a Default or an Event of Default has occurred and is continuing hereunder (of which the Trustee has been notified or is deemed to have notice), the Trustee shall exercise those rights, remedies and powers vested in it under this Indenture and shall use the same degree of care and skill in their exercise as a prudent corporate trustee would exercise or use in the discharge of the trusts imposed by this Indenture. (c) No provision of this Indenture shall be construed to relieve the Trustee from liabiUty for its own negligent actiont its own negligent failure to act, or its own wilful misconduct, except that. (i) this subparagraph shall not be construed to affect the limitation of the Trustee's duties and obligations provided in subparagraph (a)(i) of this Section or the Trustee's right to rely on the truth of statements and the aCl:ural:Y of opinions ~s provided in subparagraph (a)(ii) of this Section; (ii) the Trustee shall not be liable with respect to any action taken or omitted to, be taken by it in good faith in aCl:ordance with the' direction of the Holders of not less than a majority in principal amount of the Outstanding Bonds relating to the time, method and place of ,J 53 CJq,-/&, ol-"'~h~ .~. ";... ~ r' -..) ,,) y conduct of any proceeding available to the Trustce. or cxercising any trust, right, remedy or power conterred upon the Trustee under this Indenture; and (jji) no provision of this Indenture shall rcquire the Trustee to expend its own moneys in the observance or performance of any of its covenants, agreements, obligations or duties hereunder or in the exercise of any of its rights, remedies or powers. (d) Regardless of whether it is provided expressly therein, 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. SECTION 6.02. Certain Ri~hts and Obligations of the Trustee. Except as provided otherwise in Section 6.01 hereof: (a) The Trustee (i) may execute any of the trusts, rights, remedies or powers hereunder and may observe or perform any of its covenants, agreements, obligations or duties by or through attorneys, agents, receivers or employees (but the Trustee shall be answerable therefor only in accordance with the standard specified above); (ii) shall be entitled to the advice of counsel concerning all matters of the trusts hereof and its rights, remedies, powers and duties hereunder; (Hi) may pay reasonable compensation to all of the attorneys, agents, receivers and employees designated or employed reasonably by it in connection with the trusts hereof and shall be reimbursed for such expenses by the Company; (iv) may act upon the opinion or advice of any attorney (who may be an attorney for the Issuer or the Company) approved by the Trustee in the exercise of reasonable care; and (v) shall not be responsible for any loss or damage resulting from any action taken or omitted to be taken in good faith in reliance upon that opinion or advice. (b) Except for its certificate of authentication on the Bonds, the Trustee shall not be responsible for: (i) any recital in this Indenture or in the Bonds; (H) the validity r priority, recording, rerecording, filing or refiling of this Indenture, any Supplemental Indenture. the Agreement, or any memorandum thereof. the Mortgage, the Assignment, or any amendmcnt of or supplement to the forcgoing; 54 1q--/~ ,,) .,") "J ....-............1...dIII. -.....~., (iii) any instrument or document of further assurance or collateral assignment: (iv) any financing statementst amendments thereto or continuation statements or the tiling thereof; (v) insurance of the Mortgaged Properly or collection of insurance moneys; (vi) the validity of the execution by the Issuer of this Indenture, any Supplemental Indentur~ or any instruments or documents of further assurance; (vii) the sufticien~y of the security for the Bonds issued hereunder; (viii) the value of or title to the Mortgaged Property; or (ix) the maintenance of the security hereof; except that, in the event that the Trustee enters into possession of a part or all of the Mortgaged Property pursuant to any provision of this Indenture, the Mortgage, or any other instrument or document collateral t11crelOt the Trustee shall use due dWgence in preserving that property. In no event shall the Trustee be required to take possession of a part or all of the Project unless it shall have been provided with satisfactory indemnification from the Company, the Issuer or the Holders tor the reimbursement of all expenses which it may incur and to protect it against all risk and liability related to or arising from the possession of the Mortgaged Property. The Trustee shall not be bound to ascertain or inquire as to the observance or performance of any covenants, agreements or obligations on the part of any operator of the Mortgaged Property under any lea:,e or agreement for operations of the Mortgaged Property except as set forth hereinafter; but the Trustee may require of such operator full information and advice as to the observance or performance of those covenants, agreements and obligations. Except as otherwise provided in Section 6.04 hereof, the Trustee shall not have any obligation to observe or perform any of the duties of any operator of the Project under any lease or agreement for operation of the Project. The Trustee shall not be bound to ascertain or inquire as to the observance or performance of any covenants, agreements or obligations on the part of the Issuer or the Company under the Agreement or under any lease, other instrument or document providing for the operation of the Mongaged Property, except as set forth below; but the Trustee may require of the Issuer or the Company full information and advice as to the observance or performance of those covenantst agreements and obligations. Except as provided otherwise in Article VII, the Trustee shall have no obligation to observe or perform any of, the duties of the Issuer under the Agreement. (c) The Trustee shall not be accountable for the application by the Company or any other Person of the proce~ds of any Bonds authenticated or delivered hereunder. 55 ' 11 -/~ ,,) (d) The Trustee shall be prolect~d. in the absence of bad faith on its part. in acting upon any notice, request. consent, certiticate, order, aftidavit, leller, telegram or other instrument or document believed reasonably by it to be gcnuine and correct and to have been signed or sent by the proper Person. Any action taken by the Trustee pursuant to this Indenture upon the request, authority or consent of any Person, who is the Holder of any Bonds at the time of making the request or giving the authority or consent, shall be conclusive and binding upon all future Holders of the same Bond and of Bonds issued in exchange therefor or in place thereof. (e) As to the existence or nonexistence of any fact tor which the Issuer or the Company may be responsible or as to the sufficiency or validity of any instrument, document or proceeding, in the absence of bad faith on the part of the Trustee, the Trustee shall be entitled to rely upon a certiticatet executed for and in the name and on behalf of the Issuer by an authorized ofticial or officer thereof or for and in the name and on behalf of the Company by the Authorized Company Representative, as sufficient evidencc of the facts recited therein. Prior to the occurrence of a Default or an Event of Default of which the Trustee has been notified, as provided in this Section, or of which by this Section the Trustee is deemed to have notice, the Trustee may accept a similar certificate to the effect that any particular transaction or action is necessary or desirable; provided that, in its discretion, the Trustee may require and obtain any further evidence which it deems to be necessary or advisable; and provided further that the Trustee shall not be bound to secure any further evidence. '-'j , ----I (t) The Trustee shall not be required to take notice, and shall not be deemed to have notice, of any Default or Event of Default, except Events of Default described in Section 7.01(a) and (b), unless the Trustee shall be notified specit1cally of the Default or Event of Default in a written instrument or document delivered to it by the Company or by the Holders of at least ten percent of the aggregate principal amount of the Outstanding Bonds. In the absence of delivery of a notice satisfying those requiremems, the Trustee may assume conclusively that there is no Default or Event of Default, except as noted above. (g) At any reasonable time, the Trustee and its duly authorized altorneys, agents, experts, engineers, accountants, receivers and employees may: (i) inspect the Mortgaged Property provided that such inspection shall be conducted in such a manner as not to interfere with the services provided by the Company to the residents of the Mortgaged Property; (ii) inspect and copy fully all books, papers and records of the Issucr pertaining to the Mortgagcd Property and the Bonds; and (ijj) respect thereto. make any memoranda which the Trustee may desire therefrom and with IJ 56 qq-I f{ .-.....) (h) The Trustee shall not be required to give any bond or surety with respect to the execution of the trusts, rights, remedies and powers hcreunder or othcrwise. (i) Notwithstanding anything contained elsewhere in this Indenture. the Trustee may demand any showings, certificates, reports. opinions, appraisals and other information, and any corporate action and evidence thereof, in addition to that requircd by the terms hereof, as a condition to the authentication of any Bonds or the taking of any action whatsoever within the purview of this lndenture, if the Trustee deems it to be desirable for the purpose of establishing the right of the Issuer to the authentication of any Bonds or the right of any Person to the taking of any other action by the Trustee; provided, that the Trustee shall not be required to make that demand. (j) Before taking action under Section 6.16 or Article VII hereof (with the exception of any action required to be taken under Section 7.02 hereot), the Trustee may require that a satisfactory indemnity bond be furnished to it for the reimbursement of all expenses which it may incur and to protect it against all risk and liability by reason of any action so taken, cxcept for any risk or liability which is adjudicated to have resulted from its gross negligence or willful default. The Trustee may take action without that indemnification, and in that case, the Company shall be required to reimburse the Trustee for all of the Trusteefs expenses pursuant to Section 6.03 hereof. , , ........v-' (k) Unless provided otherwise herein, all moneys received by the Trustee under this Indenture shaII be held in trust for the purposes tor which those moneys wcre received, until those moneys are used, applied or invested as provided herein; provided that those moneys need not be segregated from other moneys, except to the extent required by this Indenture or by law. (I) Any opinions. certificates, reportS and other instruments and documents for which provision is made in this Indenture, may be accepted by the Trustee, in the absence of bad faith on its part, as conclusive evidence of the facts and conclusions stated therein and shaH be full warrant. protection and authority to the Trustee for its actions taken hereunder. (m) The permissive right of the Trusree to rake actions described specifically herein shall not be construed as a duty. (n) In the event that the approval or satisfaction of the Trustee is required under the Indenture, the Agreement, or any other instrument or document relating to the Bonds, that approval or satisfaction shall not be withheld unreasonably and shall be given or withheld as the case may be, within 30 days after the receipt by the Trustee of the request for the approval or satisfaction. Co) The Trustee shall not assign, transfer or set over its rights under the Indenture so long as the Bonds arc outstanding other than to a successor Trustee appointed pursuant to Section 6.05 hereof. ~ 57 l1,,/f -) SECTION 6.03. FLoeS. Charecs and-Expenscs of To.lstcC. Registrar. Tender Agents. &ying Agents. RemaJ'ketin~ Agent and Authenticatin~ Agl,;illS. The Trustee, the Registrar and any Tender Agents, Paying Agents, Remarketing Agent or Authenticating Agents are entitled to payment or reimbursement by the Company, as provided in the Agreement. for rcasonable fees for services rendered hereunder and for all advances, counsel fees and other expenses reasonably and necessarily paid or incurred in connection with the provision of such services. In the event that it should become necessary for the Trustee, the Registrar or any Tender Agents, Paying Agent, Remarketing Agent or Authenticating Agent to perform extraordinary services, that party is entitled, upon prior written notification to the Company, to reasonable extra compensation therefor and to reimbursement for reasonable and necessary extraordinary cxpenses incurred in connection therewith; provided that such party is not entitled to compensation or reimbursement for extraordinary services or extraordinary expenses occasioned by its neglect or willful misconduct or the neglect or willful misconduct of its agents, officers or employees. Without creating a Default or an Event of Default hereunder, however, the Company may contest in good faith the necessity for any extraordinary service and extraordinary expense and the reasonableness of any fee, charge or expense. ,.._.J The fees, charges and expenses described above shall be paid and reimbursed only from (i) Additional Payments made by the Company, as contemplated in the Agreement; or (ii) from other moneys available therefor. Any amounts payable to the Trustee, the Registrar or any Tender Agent, Paying Agent, Remarketing Agent or Authenticating Agent pursuant to t.his Section, together wi th interest thereon at the Interest Rate for Advances from the date of receipt by the Company of a demand therefor, shall be payable upon demand. The initial or acceptance fees of the Trustee, and the fees, charges and expenses of the Trustee, the Registrar or any Tender Agent, Paying Agent, Remarketing Agent or Authenticating Agent to which reference is made above, may be paid by the Trustee as provided in Section 5.02. SECTION 6.04. Intervention by Trustee. The Trustee may intervene on behalf of the Holders, and shall intervene if requested to do so in writing by the Holders of at least 25 percent of the aggregate principal amount of Outstanding Bonds, in any judicial proceeding to which the Issuer or the Company is a party and which in the opinion of the Trustee and its counsel has a substantial bearing on the interests of Holders of the Bonds. The rights, remedies, powers and duties of the Trustee under this Section arc subject to the approval of that intervention by a court of competent jurisdiction. The Trustee may require that a satisfactory indemnity bond be provided to it in accordance with this Article before it takes action hereunder. SECTION 6.05. Successor Trustee. Anything hcrein to the contrary notwithstanding, (a) any corporation or association (i) into which the Trustce may be converted or merged, (ij) with which the Trustee may be consolidated, or (iii) to which it may sell or transfer I --./ 58 CfI-lft :) . all or substantially all of its assets or corporate trust business. or any corporation or association resulting from any such conversion, mcrger. consolidation. salc or transfcr. ipso facto, shall be the successor Trustee hercunder and shall be vestcd with all of the titlc to the whole property or trust estate hereunder; and (b) that corporation or association shall be vested further, as was its predecessor. with each and every trust, right, remedy, power, duty. discretion, privilege, claim, demand, cause of action, immunity, estate. title and interest expressed or intended under this Indenture to be exercised by, vested in or conveyed to the Trustee, without the execution or filing of any instrument or document or any further act on the part of any of the parties hereto, the Trustee or that corporation or association. Any successor Trustee, however. (i) shall be a trust company or a bank having the powers of a trust company. (ii) shall be in good standing in the State, (iii) shall be duly authorized to exercise corporate trust powers in the State, and (iv) shall have an aggregate unimpaired reported capital, surplus and retained earnings of not less than $75,000,000. SECTION 6.06. Appointment of Co-Trustee. It is the purpose of this Indenture that there shall be no violation of any law of any jurisdiction (including without limitation, the State) denying or restricting the right of banks or trust companies to transact business as trustees in that jurisdiction. It is recognized that, -) "'...-' (a) if there is litigation under this Indenture or other instruments or documents relating to the Bonds or the Project. and in parlieu lar, in the case of the enforcement hereof or thereof upon a Default or an Event of Default, or (b) if the Trustee should deem that. by reason of any present or future law. the Trustee may not (i) exercise any of its trusts, rights, remedies or powers hereunder, (ii) hold title to the properties, in trust, granted herein or hold the property assigned herein, or (Hi) take any action which may be necessary or desirable in connection therewith. it may be necessary that the Trustee appoint an individual or additional institution asa co-Trustee. The Trustee shall appoint a co-Trustee upon consent of the Company and the Issuer, except such consent shall not be required when appointment of a co-Trustee is neccc;sary for taking remedial action for the benetit of Holders. The following provisions of this Section are adapted to these ends. In the event that the Trustee appoints an individual or additional institution as a co-Trustee, each and every trust, right, remedy, power, duty, disl:relion. privilege, claim. demand, cause of action, immunity, estate, title and imerest expressed or intended under this lndemure to be exercised by, vested in or conveyed to the Trustee shall be exercisablc by, vested in and conveyed to that co-Trustee, but only to the extent necessary for it to be so vcsted and conveyed to enable that co-Trustee to excrcise it. Every covenant, agrl.-ement and obligation necessary to the eAercise thereof by that co-Trustee shall run to and be enforceable by it. . 1 ,.-, 59 C;9'-/~ . "~..,,,~.............' "." " Should any instrument or document from the Issuer be reasonably rcquired by the co~ Trustee for vesting and conveying more fully and certainly in and to that co-Trustee those trusts, rights, remedies, powers, duties. discretions. privileges. claims, demands, causes of action, immunities, estates, titles and interests, that instrument or documcnt shall bc executed. acknowledged and delivered, but not prepared, by the Issuer. ]n case any co-Trustee or a successor to it shall become incapable of acting, resign or be removed. all of the trusts, rights, remedies, powers, duties, discretions, privileges, claims, demands, causes of action, immunities, estates, titles and interests of the co~Trustee shall be exercised by, vested in and conveyed to the Trustee, to the extent permittcd by law, until the appointment of a successor to the co-Trustee. SECTION 6.07. Resignation by the Trustee. The Trustee may resign at any time as Trustee hereunder by giving written notice of its resignation to the Issuer, the Company, the Registrar, any Paying Agents and Authenticating Agents. and by mailing notice of the resignation to the Holders at the close of business 15 days prior to the mailing, as their names and addresses appear on the Register on that fifteenth day prior to mailing. The resignation shall take effect upon the appointment of a successor Trustee. ~ .,.~\ . ',--oJ SECTION 6.08. Removal of the Trustee. The Trustee may be removed at any time by an instrument or document or concurrent instruments or documents delivered to the Trustee and signed either by (i) the Issuer or (ii) on behalf of the Holders of not less than a majority in aggregate principal amount of the Outstanding Bonds. Copies of any instrument or document shall be mailed to the Issuer, the Company, the Registrar. any Paying Agents, Authenticating Agents and Remarketing Agent. The Trustee shall be removed if the Company sends a communication to the Holders of the Outstanding Bonds (a) proposing that the Trustee be removed, (b) stating the reasons for requesting such removal, and (c) specifying that the Trustee shall be removed by the Holders of a majority in aggregate principal amount of the Outstanding Bonds in an instrument or instruments signed by such Holders within 30 days that they desire the removal of the Trustee. The Trustee, at the Company's expense, shall provide the Company with the names and addresses of all Holders of Outstanding Bonds within ten days of receiving a request for that information from the Company for purposes of enabling the Company to send that communication, unless, in the opinion of counsel to the Trustee, to do so would be prohibited by law. In addition. the Trustee may be removed at any time for any breach of trust or for acting or proceeding in violation of, or for failing to act or proceed in accordance with, any of its duties, including without limitation, any of its covenants. agreements and obligations, hereunder. The removal may be made by any court of competent jurisdiction upon the application of the Issuer, the Company (if not then in Default) or the Holders of not less than a majority in aggregate principal amount of the Outstanding Bonds. For purposes of this Section. whenever actions are to be taken, or consents are to be given, by or at the direction of the Holders of Outstanding Bonds. Bonds registered in the name of the l-J 60 t;q~/<t .,) Company shall not be taken into account in determining whether the requisite number of Holders has authorized the action or conscnl. SEcrrON 6.09. Appoinrmcnr of Successor Truslec. If (i) the Trusree shall resign, shall be removed, shall be dissolved. or shall become incapablc otherwise of acting hercunder: (ii) the Trustee shall be taken under the control of any public ofticcr or ofticcrs; or (iii) a receivcr shall be appointed for the Trustee by a court; then a successor Trustee shall be appointed by the Issuer, with the written consent of the Authorized Company Rcpresentative; provided, that if a successor Trustee is not so appointed within twenty days after (a) a. notice or resignation or an instrument or document of removal is received by the Issuer, as provided in Sections 6.07 and 6.08 hereof, respectively; or (b) the Trustee is dissolved. becomcs incapable otherwise of acting. or is taken under control, or a receiver is appointed. in each case, as provided above; then the Issuer may designate a successor Trustee or jf the Issuer fails to designate a successor Trustee, the Holders of a majority in aggregate principal amount of OUlstanding Bonds, with the written consent of the Authorized Company Represcntative, may designate a successor Trustee by an instrument or document or concurrent instruments or documents in writing executed by or on behalf of those Holders. If, within 60 days after the events described in (a) and (b) above, no appointment of a successor Trustee shaH have been made pursuant to the foregoing provisions of this Section, the Holder of any Outstanding Bond. any retiring Trustee or the Company may apply to any court of competent jurisdiction for the appointment of a successor Trustee. After notice. if any, which the court may deem to be proper and may prescribe, the court may appoint a successor Trustee. "---\ For purposes of this Section, whenever actions are to be taken. or consents are to be given, by or at the direction of the Holders of Outstanding Bonds, Bonds registered in the name of the Company shall not be taken into account in determining whether the requisite number of Holders has authorized the action or consent. Every successor Trustee appointed pursuant to this Section shall (i) be a trust company or a bank having the powers of a trust company, (ii) be in good standing in the State, (Hi) be duly authorized to exercise trust powers in the State, (iv) have an aggregate unimpaired reponed c3.JJital. surplus and retained eanlings of not less than $75,000,000 and (v) be willing to accept the trusteeship under the terms and conditions of this Indenture. Every successor Trustee appointed hereunder shall execute and acknowledge, and shaH deliver to its predecessor. the Issuer and the Company. an inslrument or document in writing accepting the appointment. Thereupon, without any further 3t.:t, the successor shall become vested with all of the trusts, rights, remedies, powers, duties, discretions, privileges, claims, demands. causes of action, immunities, estates. titles and intcrcsts of its predccessor. Upon the written request of its successor, the Issuer or the Company, the predecessor Trustee (i) shall execute and deliver an instrument or doeumcnt transferring to ils SlH.'(.'essor all of the trusts. rights, remedies. powers, duties, discretions. privileges, claims, demands, causcs of action, immunities. estates, titles and interests of the prcdeccssor Trustec hcreunder; and Oi) shall take any other action u 61 11-/r :....:......-1....,.1.>;' , . c. ~. - ,...., necessary or advisable to duly assign, transfer and deliver to its successor all property and records (including without limitation, all moneys) held by it as Trustce. Should any instrument or document from the Issuer be reasonably requested by any successor Trustee for vesting and conveying marc fully and certainly in and to that successor the trusts, rights, remedies, powers, duties, discretions, privileges, claims, demands, causes of action, immunities, estates, titles and interests vested or conveyed or intended to be vested or conveyed h~reunder in or to the predecessor Trustee, the Issuer shall execute, acknowledge and deliver that i.lstrument or document. In the cvent of a change in the Trustee, the predecessor Trustee shall cease to be the custodian of any moneys, including without limitation, any investments, which it may hold pursuant to this Indenture and shall cease to be thc Registrar, the Tender Agent and Authenticating Agent and a Paying Agent for any of the Bonds, to the extcnt that it may have served in any of those capacities and shall have no further responsibility or liability therefore. The successor Trustee shall become that custodian and, if applicable, the Registrar, an Authenticating Agent and a Paying Agent to the same extent as the predecessor Trustee shall have served in those capacities. .'-....... SECTION 6.10. Adoption of Authentication. In case any of the Bonds shall have been authenticated, but shall not have been delivered, any successor Trustee, Registrar or Authenticating Agent may adopt the certificate of authentication of any predecessor Trustee, Registrar or Authenticating Agcnt and may deliver those Bonds so authcnticated as provided herein. In case any Bonds shall not have been authenticated, any successor Trustee, Registrar or Authenticating Agent may authenticate those Bonds either in the name of any predecessor or in its own name. In all cases, the certificate of authentication shall have the same force and effect as is provided in the Bonds or in this Indenture with re;.pect to the certificate of authentication of the predecessor Trustee, the Registrar or the Authenticating Agent. SECTION 6.11. Reeistrars. (a) Anything herein to the contrary notwithstanding, any corporation or association (i) into which a Registrar may be converted or merged, (ii) with which a Registrar may be consolidated, or (iii) to which it may sell or transfer all or substantially all of its assets, or any corporation or association resulting from any such conversion, merger. consolidation, sale or transfer, ipso facto, shall be the successor of that Registrar hereunder, if that corporation or association is eligible otherwise hereunder, and shall be vested with each and every right, power, duty, discretion and privilege expressed or intended to be exercised by or vested hereunder in the predecessor Registrar, without the exccution or filing of any instrument or document or any further act on the part of any of the parties hereto, the Registrar or that corporation or association. (b) A Registrar (other than the Trustee) may resign at any time by giving written notice of its resignation to the Issucr, the Company, the Trustee, any Paying Agents and Authenticating Agents, and the Original Purchaser of each series of Outstanding Bonds for which it is Registrar. The notice shall be given at least 60 days before the resignation is to take effect. The resignation ,...) 62 11~/g' '1 shall take effect immediately. howevcr. upon the appointment of a succcssor Rcgistrar, if the successor Registrar is appointed and accepts that appointment before thc date stated in the notice. (c) The Registrar may be removed at any time by an instrument or document or concurrent instruments or documents delivered to the Registrar and signed by or on behalf of the Holders of not less than a majority in aggrcgate principal amount of the Outstanding Bonds. Copies of any instrument Of document shall be mailed to the Issuer, the Company, the Trustee, any Paying Agents and Authenticating Agents for those series of Bonds and the Original Purchaser of each series of Outstanding Bonds for which the Registrar served as Registrar. ~~~ ;t.\ -., ~<~) (d) If (i) a Registrar shall resign. shaH be removed. shall be dissolved, or shall become incflpable otherwise of acting hereunder; (ii) a Registrar shall be taken under the control of any public officer or officers; (Hi) a receiver shall be appointed for a Registrar by a court; or (iv) a Registrar shall have an order for relief entered in any case commenced by or against it under the federal bankruptcy laws or commence a proceeding under any federal or state bankruptcy, insolvency. reorganization or similar law, or have such a proceeding commenced against it and either have an order of insolvency or reorganization entered against it or have the proceeding remain undismissed and unstayed for 90 days; then a successor Registrar shall be appointed by the Issuer, with the written consent of the Authorized Company Representative and the Trustee; provided that if a successor Registrar is not so appointed within ten days after (a) a notice of resignation or an instrument or document of removal is received by the Issuer, as provided above; or (b) the Registrar is dissolved, becomes incapable otherwise of acting, or is taken under control, or a receiver is appoimed, in each case, as provided above; the Issuer, with the consent of the Trustee or the Holders of a majority in aggregate principal amount of Outstanding Bonds may designate a successor Registrar, by an instrument or document or concurrent instruments or documents in writing signed by the Issuer, or in the case of the Holders, by or on behalf of those Holders. Every successor Registrar appointed hereunder shall execute and acknowledge, and shall deliver to its predecessor, the Issuer. the Trustee and the Company t an instrument or document accepting the appointment. Thereupon, without any further act, the successor shall become vested with all of the rights. powers, duties, discretions, privileges, claims, demands, causes of action, immunities, titles and interests of its predecessor. Upon the written request of its successor, the Issuer or the Authorized Company Representative, a predecessor Registrar (i) shall execute and deliver an instrument or document transferring to its successor all of the rights, powers, duties, discretions, privileges, claims, demands, causes of action, immunities, titles and interests of the predecessor Registrar hereunder; and (ii) shall tnke any other action necessary or advisable to duly assign, transfer and deliver to its successor all property and records (including without limitation, the Register and any cancelled Bonds) held by it as Registrar. Should any instrument or document from the Issuer be reasonably requested by any successor Registrar for vesting and conveying more fully and certainly in and to that successor the rights, powers, duties, discretions, privileges, claims, demands, causes of action, immunities, titles and interests vested or conveyed or intended .J 63 99,- / r --......___..l..I..W!'_...,L...:.......___........_____.___..: .".: "._. ____._._____ -, to be vested or conveyed hereunder in or to a predecessor Registrar, thc Issucr shall execute, acknowledge and deliver that instrument or document. SECTION 6.12. Desienation and Succession of Payine A~cnts. The Trustee shall be a Paying Agent for the Bonds and, with the consent of the Trustee. the Issuer may appoint additional Paying Agents with power to act on its behalf and subject to its direction in the payment of Debt Service Charges on any series of Bonds. Any corporation or association (i) into which a Paying Agelll may be converted or merged, (ii) with which a Paying Agent may be consolidated. or (iji) to which it may sell or transfer all or substantially all of its assets or corporate trust business. or any corporation or association resulting from any such conversion, merger, consolidation. sale or transfer, ipso facto. shall be the successor of that Paying Agent hereunder. if that corporation or association is eligible otherwise hereunder, without the execution or tiling of any instrument or document or any further act on the part of the parties hereto, the Paying Agent or that corporation or association. Any Paying Agent may resign at any time by giving 30 days written notice of its resignation to the Issuer, the Company, the Trustee, the Registrar, any Authenticating Agents and the Remarketing Agent. -') . .~...~~ At any time, the Issuer may tenninate the agency of any Paying Agent (except the Trustee) by giving written notice of termination (0 the Company. such Paying Agent. the Trustee. the Registrar, any Authenticating Agents and the Remarketing Agent. Upon receiving a notice of resignation or upon a tennination, or in case any Paying Agent shall cease to be eligible under this Section, the Issuer may appoint a successor Paying Agent with the consent of the Trustee. The Issuer shall give written notice of appointment of a successor Paying Agent to the Company, the Trustee, the Registrar, any Authenticating Agents and the Original Purchaser of the Outstanding Bonds for which that Paying Agent served as Paying Agent and, within ten days after that appointment, shall mail notice thereof to each Holder at the close of business on the dale of lhat appointment at its address as it appears on the Register on that date of appointment. Subject to Section 6.03. the Truslee shall be entitlt..'1:I to reimbursement from the Company for any compensation which the Trustee may pay to any Paying Agent. Section 6.02(d) is applicable to any Paying Agent to the same extent as if the Paying Agent were stated therein to be subject thereto. SECTION 6.13. Desi~nation and Succession of Authenlicatin2 Agents. With the consent of the Trustee, the Issuer may appoint Authenticating Agents. in addition to the Registrar, with power to act on the behalf and subjt.'C1 to the direction of the Trustee in the authentication and delivery of Bonds in connection with transfers and exchanges under Sections 3.06 and 3.07 hereof. For all purposes of this Indenture, the authentication and delivery of Bonds by an J 64 99-;r -......--__~__=:lIL;.~ ~~ ,- .-') Authenticating Agent pursuant to this Section shall be deemed to constitute authentication and delivery of those Bonds by the Trustee. Any corporation or association (i) into which an Authenticating Agent may be converted or merged, (ii) with which an Authenticating Agent may be consolidated, or (iii) to which it may sell or transfer all or substantially all of its assets or corporate trust business, or any corporation or association resulting from any such conversion, merger, consolidation, sale or transter, ipso facto, shall be the successor of that Authenticating Agent hereunder, if that corporation or association is eligible othcrwise hereunder. without the execution or tiling of any instrument or document or any further act on the part of the parties hereto, the Authenticating Agent or the corporation or association. Any Authenticating Agent may resign at any time by giving 30 days wriucn notice of its rcsignation to the Issuer, the Company. the Trustee. the Registrar and any Paying Agents. At any time, the Trustee may tenninate the agency of any Authenticating Agent by giving written notice of tennination to the Authenticating Agent, the Issuer, the Company, the Registrar and any Paying Agents. ....""4... "' I J ......J>. Upon receiving a notice of resignation or upon a tennination, or in case any Authenticating Agent shall cease at any time to be eligible under this Section, the Issuer may appoint a successor Authenticating Agent which shall be approved by the Trustee, such approval not to be unreasonably withheld. The Issuer shall give written notice of appointment of a successor Authenticating Agent to the Company, the Trustee, the Registrar, any Paying Agents, and the Original Purchaser of the Outstanding Bonds for which that Authenticating Agent served as Authenticating Agent and, within ten days after that appointment, the Trustee shall mail notice thereof to each Holder at the close of business on the date of that appointment at its address as it appears on the Register on that date of appointment. Subject to Section 6.03, the Trustee shall be entitled to reimbursement from the Company for any compensation which the .Trustee may pay to any Authenticating Agent. Section 6.02(b), (c), (d), (h) &nd (i) shall be applicable to any Authenticating Agent to the same extent as if the Authenticating Agent were stated therein to be subject thereto. SECTION 6.14. Designation and Succession of Tender Aeents. The Trustee shaH be the Tender Agent for the Series 1999B Bonds and, with the consent of the Trustee, the Issuer may appoint successor Tender Agents with power to act on behalf of Holders of Series 1999B Bonds and subject to their direction in the tendering of such Bonds for purchase. Any corporation or association (i) into which a Tender Agent may be converted or merged. (if) with which a Tender Agent may be consolidaced, or (iii) (0 which it may sell or transfer all or substantially all of its assets or corporate trust business, or any corporation or association resulting from any such conversion, merger, consolidatiuli, sale or transfer, ipso facto, shall be ',.J 65 CfI- If(; I, '~ the successor of that Tender Agent hereunder. if that corporation or association is eligible ,,' otherwise hereunder, without the execution or tiling of any instrument or document or any further act on the pan of the parties hereto, the Tender Agent or that corporation or association. Any Tender Agent (except the Trustee) may resign at any time by giving 30 days written notice of its resignation to the lssuer, the Company, the Trustee, the Remarketing Agent, the Paying Agent, the Registrar and any Authenticating Agents. At any time, the lssuer may terminate the agency of any Tender Agent by giving written notice of tennination to the Company, the Tender Agent, the Trustee, the Registrar and any Authenticating Agents. Upon receiving a notice of resignation or upon a tennination, or in case any Tender Agent shall cease to be eligible under this Section, the Issucr may appoint a successor Tender Agent with the consent of the Trustee. The Issuer shall give written notice of appointment of a successor Tender Agent to the Company, the Trustee, the Registrar, any Authenticating Agents and the Remarketing Agent and, within ten days after that appointment, shall mail notice thereof to each Holder of Series 1999B Bonds Outstanding at the close of business on the date of that appointment at its address as it appears on the Register on that date of appointment. '. Subject to Section 6.03, the Trustee shall be entitled to reimbursement from the Company for any compensation which the Trustee may pay to any Tender Agent. Section 6.02(d) is applicable to any Tender Agent to the same extent as if the Tender Agent were stated therein to be subject thereto. SECTION 6.15. Dealin~ in Bonds. The Trustee, any Registrar, any Paying Agent and any Authenticating Agent, their affiliates, and any directors, officers, employees or agents thereof, may become, in good faith, the Holders of Bonds secured hereby with the same rights, remedies and powers which it or they would have hereunder if the Trustee, the Registrar, the Paying Agent or the Authenticating Agent did not serve in those capacities. SECTION 6.16. Representations. Warranties. Covenants and A2reements of ~. The Trustee represents and warrants hereby that it: (a) is a national banking association duly organized and validly existing under the laws of the United States; (b) is in good standing and duly authorizcd to exercise trust powers in the State; and (c) has an aggregate unimpaired reported capital, surplus and retained earnings of not less than $75,000.000. ,~ 66 qq-/~ ,~ The Trustee covenants and agrees that it will take any action which is necessary to remain ..' in good standing and duly authOriZL~ to exercise trust powers in the State, and that it will maintain an aggregate unimpaired reported capital, surplus and retained earnings of not less than $75,000,000. The Trustee accepts and agrees to observe and perfonn the duties and obligations of the Trustee to which reference is made in the Mortgage and in any other instrument or document providing security for any of the Bonds. SECTION 6.17. Rieht of jntstee to Pay Taxes and Other Char~~s. Reference is made to the Mortgage whereby the Trustee is authorized to advance funds (a) to pay taxes, assessments and other charges with respect to the Mortgaged Property; (b) to maintain and keep in torce insurance for the Mortgaged Property; (c) to maintain required workers' compensation coverage; and (d) to payor discharge mechanics' or other liens relating to the Mortgaged Property; c.-',\ (e) to do so. generally, to make payments and incur expenses in the event that the Company fails The Trustee may make those advances only upon written notice to the Company and the Company's failure to make such payments within seven days of such notice. These advances are made without prejudice to any rights, remedies or powers of the Trustee or the Holders against the Company for the failure of the Company to do so. Any moneys so advanced, together with interest thereon at the Interest Rate for Advances from the date of advancement, (i) shall be an additional obligation hereunder, (ii) shall be given a preference in payment over any Debt Service Charges, but only following an Event of Default, and (iii) shall be paid from Additional Payments made by the Company as contemplated in the Agreement or, (iv) if not paid otherwise, but only following an Event of Default, shall be paid from the Loan Payments Fund. The Trustee shall make the advance, if it is requested to do so by the Holders of at least 25 percent of the aggregate principal amount of Outstanding Bonds and is provided with adequate moneys for the purpose thereof. SECTION 6.18. Several Capacities. Anything in this Indenture to the contrary notwithstanding, the same entity may serve hereunder as the Trustee, the Registrar, the Tender Agent, the Paying Agent and Authenticating Agent and in any other combination of such capacities, to the extent permitted by law. ~..;) 67 19-/c( /~) ',:) o ARTICLE VII DEFAULT PROVISIONS AND REMEDIES OF TRUSTEE AND HOLDERS SECTION 7.01. of Default hereunder: Defaults: Events of Default. The tollowing events constitute Events (a) The payment of any intcrcst on any Bond is not made when and as that interest becomes due and payable; (b) The payment of the principal of or any premium on any Bond is not made when and as that principal or premium becomes due and payable, whether at stated maturity I by redemption (including without limitation, redemption pursuant to the mandatory sinking fund requirements) or acceleration or otherwise; (c) The Issuer fails to observe or perform any other covenant, agreement or obligation on the part of the Issuer conrained in this Indenture or in any Bonds, which failure shaH have continued for a period of 60 days after written notice, by registered or certified mail, to the Issuer and the Company specifying the failure and requiring that it be remedied, which notice may be given by the Trustee in its discretion and shall be given by the Trustee at the written request of the Holders of not less than 25 percent in aggregate principal amount of Bonds then outstanding; provided, that the Trustee may agree in writing to a longer period prior to the expiration of the first 6D-day period; provided further, that if the Issuer or the Company shall proceed to take curative action which, if begun and prosecuted with due diligence, cannot be completed within the first period of 60 days, then upon written notice thereof to the Trustee such period shall be increased without such written extension until such curative action has been completed (as to which cffons the Trustee shall be advised from time to time) or umil 60 days after such curative action can be diligently completed; or (d) Mortgage. Any other event which constitutes an Event of Default under the Agreement or the The declaration of an Event of Default and the exercise of rights, remedies and powers upon the declaration of an Event of Default arc subject [0 any applicable limitations of federal bankruptcy law affecting or precluding the declaration or exercise during the pendency of or immediately following any bankruptcy, liquidation or reorganization proceedings. SECTION 7.02. Notice of Default. If an Event of Default occurs, within tive days after the Trustee has actual knowledge of the Event of Default, the Trustee shall give written notice of the Event of Default. by registered or certified mail, to the Issuer. the Company, the Regislrar, any Paying Agent, any Authenticating Agent, the Remarketing Agent, the Original Purchaser of the Outstanding Bonds and the Holders of the Bonds. 68 99-;<1 '1 -''''\ , - .. '-' ,~ -.... ,. ..'~ ':..:" . .. <" . SECTION 7.03. Acceleratipn. Upon the occurrence of any Event of Default. the Trustee may, and upon the written request of the Holders of not less than 25 percent in aggregate principal amount of the Outstanding Bonds. shall. declarc the principal of and premium. if any, on all of the Outstanding Bonds (if not then due and payable). and the interest accrued thereon, to be due and payable immediately; provided that, in addition to any indemnity bond required under Section 6.02(j), the Trustee shall have been provided with satisfactory indemnity for the reimbursement of all expenses which it may incur and to protect it against all risk and liability related to or arising from such acceleration. Any such declaration shall be by notice in writing delivered to the Issuer, the Company, the Registrar, any Paying Agent and any Authenticating Agent. Upon that declaration, that principal and premium, if any, and interest shall become and be due and payable immediately. Interest on the Bonds shall accrue to the dale determined by the Trustee for the tender of payment to the Holders; provided that interest on any unpaid principal amount of Outstanding Bonds shall continue to accrue after the date determined by the Trustee for the tendcr of payment to the Holders of those Bonds. The provisions of the preceding paragraphs are subject, however, 10 the condition that if, at any time after a declaration of acceleration and prior to the entry of a final judgement in a court for enforcement hereunder, (a) all sums payable hereunder (other than the principal of and interest on Bonds which shaH not have reached their stated maturity dates, but which are due and payable solely by reason of the declaration of acceleration), together with. to the extcnt permitted by law, interest on any overdue installments of interest at the rate borne by the Bonds in respect of which the Event of Default shall have occurred shall have been duly paid, or provision shall have been duly made therefor by deposit with the Trustee Of any Paying Agent; and (b) all existing Events of Default shall have been cured; then in every case, the Trustee shall waive the Event of Default and its consequences and shall rescind and annul the declaration of acceleration. No waiver Of rescission and annulment shall extend to or affect any subsequent Event of Default Of shall impair any rights, remedies or powers consequent thereon. SECTION 7.04. Matters Re2arding Rights. Remedies and Powers. Regardless of whether a declaration of acceleration is made hereunder, upon the occurrence and continuance of an Event of Default. thc Trustt..'e may pursue any available right, remedy or powcr to enforce the payment of Debt Service Charges and the observance and performance of any other covenant, agreement or obligation undcr this Indenture, the Agreement. the Mortgage or any of the ;'\otes or any other instrument providing security directly or indirectly, for the Bonds or any series thereof. Upon the occurrence and continuance of an Event of Default, if the Trustee is requested to do so by the Holders of at least 25 percent in aggregate principal amount of the Outstanding 69 CJc;-;t ~, Bonds, thc Trustee shall excrcise any rights, remedies and powers hereunder, subject to the provisions of Sections 6.01 and 6.02. Notwithstanding any other provision in the Indenture to the contrary, the Trustee is authorized [0 use any amounts held in the funds and accounts under the Indenturc to pay the cost. liabilities. fees and advances incurred by the Trustee (including legal counscl t"t.."Cs and expenses) to tinance remedial action under the Indenture upon the occurrence of an Event of Default. No right, remedy or power conferred upon or reserved to the Trustee or the Holders under this Indcnrun: is inlcnded to be exclusive of any other available right, remedy or power, but each right, remedy or power shall be cumulative and concurrent and shall be in addition to every other right, rcmf,.>dy or power available Ulider the Agreement or the Mortgage or hereunder or existing at law, in equity or by statute or otherwise now or hereafter. No exercise. beginning of the exercise, or partial exercise by the Trustee or the Holders of anyone or more rights, remedies or powers shall preclude the simultaneous or later exercise by the Trustc..'C or the Holders of any other right, remedy or power. No delay or omission in the exercise of any right, remedy or power accruing upon any Event of Default shall impair that or any other right, remedy or power or shaH be construed to constitute a waiver of any Event of Default, but every right, remedy or power may be exercised from time to time and as often as may be deemed to be necessary or desirable. , ,J To entitle the Trustee or the Holders to exercise any right, remedy or power hereunder, it shall not be necessary to give any notice, other than as may be required expressly herein. In exercising any right, remedy or power thereunder or hereunder, the Trustee shall take all actions which would best serve the interests of the Holders, in the judgmem of the Trustee, applying the standards described in Sections 6.01 and 6.02 hereof. , '.., Upon the occurrence of an Event of Default, neither the Issuer, the Company, nor anyone claiming through or under either of them. shall set up, claim or seek to take advantage of any appraisement, valuation, stay t extension or redemption laws in force from time to time, to prevent or hinder the enforcement of this Indenture, and the Issuer, for itself and all who may claim through or under it, waives hereby, to the extent that it may do so lawfully, the benefit of all of those laws and all rights of appraisement and redemption to which it may be entitledt and all rights of marshaling. SECTION 7.05. Right of Holders to Direct Proceedings. Notwithstanding anything to the contrary in chis Indenture, the Holders of a majority in aggregate principal amount of Outstanding Bonds have the right to direct at any time, pursuant to Article Xl or by an instrument Of document Of instruments or documents in writing executed and delivered to the Trustee, the method and place of conducting all proceedings to be taken in conncction with the enforccment of this Indenture or any other proceedings hereundcr; provided. that (a) no direction shall be other than in accordance with law and this Indenture; , 'J 70 q9//~ " f . ,.~ (b) the Trustee shall be indemnified as provided in Sections 6.01 and 6.02; and (c) the Trustee may take any other action which it deems to be proper and which is not inconsistent with the direction. SECTION 7.06. Appointment of Receivers. Upon the occurrence of an Event of Default and upon the filing of a suit or other commencement of judicial proceedings to enforce the rights of the Trustee and the Holders, as a matter of right, to the extent permitted by law, the Trustee is entitled to the appointment of a receiver or receivers of the Mortgaged Property pending those proceedings, with all powers which the court making the appointment shall confer. 0, 1 .~j SECTION 7.07. Application of Moneys. All moneys received by the Trustee pursuant to the exercise of any right. remedy or power or any action taken under this Article VII or under the Agreement and all other amounts held by the Trustee hereunder, subject to any provision made pursuant to Sections 5.07 or 5.08 hereof, shall be (i) first, used to pay the costs, expenses, liabilities, fees and advances incurred by the Trustee including legal counsel fees and expenses, (ii) second, used to pay any refunds to residents of the Mortgaged Property pursuant to applicable provisions of Chapter 651, Florida Statutes, as amended, and (iii) third, deposited in the Rebate Fund in an amount sufficient to cause the Rebate Fund to contain an amount equal to the Excess Earnings with respect to the Outstanding Bonds calculated as of a date determined by the Trustee subsequent to the Event of Default and in accordance with Section 5.05 hereof, and (iv) fourth, shall be applied by the Trustee as set forth below. (a) Unless the principal of all of the Bonds has become or has been declared to be due and payable, all of those moneys shall be applied: First -- To the payment of all installments of interest then due on the Bonds in the order of maturity of the installments of that interest, beginning with the earliest maturity, and if the amount available is not sufficient to pay in full a panicular installment, then to the payment thereof ratably, according to the amounts due on that installment, without any discrimination or privilege, except as to any difference in the respective rates of interest on the Bonds; and Second -- To' the payment of the unpaid principal of any Bonds which shall have become due (other than the Bonds called previously for redemption, for the payment of which. moneys are held hereunder), whether at maturity or by redemption, including without limitation, redemption pursuant to the mandatory redemption requirements, in the order of their due dates, beginning with the earliest due date, with interest on those Bonds from the respective dates upon which they shall have become due, and if the amount available is not sufficient to pay in full all unpaid principal on all Bonds due on any particular date, then to the payment thereof ratably, according to the amounts of principal due on that date, without any discrimination or privilege. Third-n Any additional amounts the Trustee receives shall be applied as follows in the following order of priority: ....J 71 99-/g ,~... .1, _"" I ~) " .'" , I J 'J .-.....~.-\....._,>..~.... ... -~~~.......~-~ (1) to the paymcnt of currcnt dcposits then required to be made to the Bond Fund for the payment of Debt Service Charges; (2) to the payment of current Operating Expenscs rcquisitioned by the Company and disbursed by the Trustee monthly in accordance with the annual budget for the Mortgaged Property, which budget may be modified from time to time if such moditication is approved by the Board of Directors of the Company and such approval, along with the modified budget is submitted to the Trustee; provided that during the continuation of an Event of Default the annual budget for the Mortgaged Property shall not be increased by any such modification unless such modi tication is recommended by the Consultant; (3) to remedy any deficiency in the Debt Service Reserve Fund; (4) to remedy any deficiency or make current payments into the Renewal and Replacement Fund, the moneys in which Fund shaH be disbursed by the Trustee only upon submission of a written request therefore signed by the Chief Financial Officer of the Company and accompanied by written evidence of approval of such expenditures by the Board of Directors of the Company. (5) to establish such additional reserves which the Trustee reasonably requires, with the advice of any Consultant engaged by the Trustee for such purpose, to ensure the prompt payment of Debt Service Charges and Operating Expenses; Any surplus funds remaining shall be held by the Trustee but may be paid to the Company for extraordinary operating or capital expenses which are approved by the Board of Directors of the Company, and such approval is submitted to the Trustee along with a request for disbursement signed by the Chief Financial Officer of the Company. For so long as the Trustee receives Revenues, the Trustee shall, and is hereby authorized to, establish and maintain such funds and accounts as the Trustee deems necessary or desirable in order to provide for the proper application of Revenues in accordance with the terms hereof. (b) If the principal of all of the Bonds has become or has been declared to be, due and payable, pursuant to this Article, all of those moneys shall be applied to the payment of the principal and premium, if any, and interest then due and unpaid upon the Bonds. without preference or priority of (i) principal or premium, if any, over interest. (ii) interest over principal or premium, if any, 72 11- /~ "J (iii) any installment of interest over any other installment of interest, or (iv) any Bond over any other Bond. ratably, according to the amounts due respectively for principal and premium, if any, and interest, without any discrimination or privilege, except as to any difference in the respective rates of intel'est on the Bonds. (c) If the principal of all of the Bonds has been declared to be due and payable pursuant to this Article, and if the declaration shall thereafter have been rescinded and annulled hereunder, then subject to the provisions of subparagraph (b) of this Section, in the event that the principal of all of the Bonds shall later become due or shall be declared to be due and payable. the moneys shall be applied in accordance with the provisions of subparagraph (a) above. .~') (d) Whenever moneys are to be applied pursuant to the provisions of this Section, those moneys shall be applied at those times, and from time to time, which the Trustee shall determine, having due regard to the amount of moneys available for application and the likelihood of additional moneys becoming available for application in the future. Whenever the Trustee shall direct the application of those moneys, it shall determine a Special Interest Payment Date upon which the application is to be made, and upon the date as detennined, interest shall cease to accrue on the amounts of principal, if any. to be paid on that date, if the moneys are available therefor. The Trustee shall give notice of the deposit with it of any moneys and of the detennination of that date, all in a manner which is consistent with the requirements hereof for the establishment of, and for giving notice with respect to, a Special Record Date for the payment of overdue interest, the Trustee shall not be required to make payment of principal of or premium, if any, on a Bond (0 the Holder thereof, until the Bond is presented to the Trustee for appropriate endorsement or, if it is to be paid fully, for cancellation. SECTION 7.08. Rights. Remedies and Powers Vested in Trustee. All rights. remedies and powers (including without limitation, the right to file proof of clain.~) under this Indenture or under any of the Bonds may be enforced by the Trustee without the possession of any of the Bonds or the production thereof in any trial or other proceeding relating thereto. Any suit or proceeding instituted by the Trustee shall be brought in its name as Trustee without the necessity of joining any Holders as plaintiffs or defendants. Any recovery of judgment shall be for the benefit of the Holders of the Outstanding Bonds, subject to the provisions hereof. SECTION 7.09. Ri~hts. Remedies and Powers of Holders. No Holder shall have any right, remedy or power to institute any suit, action or proceeding for the enforcement of this Indenture, for the execution of any trust hereof, or for the exercise of any other right, remedy or power hereunder, unless ' .J 73 19-;8' -.) (a) there has occurred and is continuing an Event of Default of which the Trustee has been notified, as provided in Section 6.02(t) hereof, or of which it is deemed to have noiice under that subparagraph; (b) the Holders of at least 25 percent in aggregate principal amount of the Outstanding Bonds shall have made written request to the Trustee and shall have afforded the Trustee a reasonable opportunity to proceed to exercise the rights, remedies and powers or to institute the suit, action or proceeding in its own name, and shall have offered indemnitication to the Trustee as provided in Sections 6.01 , 6.02 and 7.03 hereof; and (c) the Trustee shall have failed or refused thereaft~r to exercise the rights, remedies and powers or to institute the suit, action or proceeding in its own name. At the option of the Trustee, such notitication, request, opportunity and offer of indemnitication shall be conditions precedent in every case, to the institution of any suit, action or proceeding described above. -.... , ') , ----' No one or more Holders of the Bonds shall have any right, remedy or power to affect, disturb or prejudice this Indenture in any manner whatsoever by its or their action, or to enforce any right, remedy or power hereunder, except in the manner provided herein. Any suit, action or proceeding shall be instituted, had and maintained in the manner provided herein for the benefit of the Holders of all Outstanding Bonds. Nothing in this Indenture shall affect or impair, however, the right of any Holder to enforce the payment of principal and interest on any Bond owned by that Holder at and after the maturity thereof, at the place, from the sources, and in the manner expressed in that Bond. SECTION 7.10. Termination of Proceedings. If the Trustee shall have proceeded to enforce any right, remedy or power under this Indenture in any suit, action or proceeding, and the suit, action or proceeding shall have been discontinued or abandoned for any reason, or shall have been detemlined adversely to the Trustee, then the Issuer, the Company, the Trustee and the Holders shall be restored to their former positions and rights, remedies and powers hereunder, respectively, and all rights, remedies and powers of the Trustee and the Holders shall continue as if no suit, action or proceeding had been taken. SECTION 7.11. Waivers. Except as provided below, at any time, in its discretion, the Trustee may waive any Event of Default hereunder and its consequences and may rescind and annul any declaration of acceleration of the Bonds. The Trustee shall do so upon the written request of the Holders of (a) at least a majority in aggregate principal amoum of all Outstanding Bonds in respect of which an Event of Default exists in the payment of Debt Service Charges; or v 74 91-/'( r-'.' ... ~; _, '... ~ ~.' ~ . . ; , ~ '.J ,-) ._" ...,........T-:1.---,.......... ~ " (b) at least 25% in aggregate principal amount of all Outstanding Bonds. in the case of any other Event of Default. ' There shall not be so waived. however, any Event of Default described in Section 7.01(a} or (b) hereof. and no declaration of accelt:ration in connection therewith may be rescinded or annulled, unless at the time of the waiver, rescission or annulment. payments have been duly made, or provision has been duly made for the payment. of the amounts provided in Section 7.03 hereof for waiver. rescission and annulment in connection with a declaration of acceleration. In the event of the waiver, rescission or annulment, the Issuer, the Company, the Trustee and the Holders shall be restored to their former positions and rights, remedies and powers hereunder, respectively. No waiver, rescission or annulment shall extend to any subsequent or other Event of Default or impair any right, remedy or power consequent thereon. In the event that any covenant, agreement or obligation hereunder or under the Agreement, the Mortgage or the Bonds shall be breached by either the Company or the Issuer, and the breach shall have been waived thereafter, the waiver shall be limited to the .particular breach so waived and shall not be deemed to waive any other or any subsequent breach thereunder. No waiver shall be deemed to apply to any existing or subsequent right, remedy or power with respect to the breach, except to the extent provided expressly in the waiver. No failure by the Trustee or the Holders to insist upon the strict observance or performance by the Company or the Issuer of any covenant, agreement or obligation hereunder or under any Company Document, any Issuer Document or the Bonds, and no failure to exercise any right, remedy or power consequent upon a breach thereof, shall constitute a waiver of any right, remedy or power to enforce strict observance or performance or a waiver of such breach. 75 11~/e' 'J ARTICLE VIII SUPPLEMENTAL INDENTURES AND AMENDMENTS TO ISSUER DOCUMENTS ". SECTION 8.01. Supplemental Indentures Generally. The Issuer and the Trustee may not enter into indentures supplemental to or amending of this Indenture, except as provided in this Article and pursuant to the other provisions therefor in this Indenture. SECTION 8.02. Supplemental Indentures Not Requiring Consent of Holders. Without the consent of or notice to the Holders, the Issuer and the Trustee may enter into Supplemental Indentures, which shall not be inconsistent. in the opinion of the Issuer and the Trustee, with the tenns and provisions hereof, for anyone or more of the following purposes: (a) to cure any ambiguity, inconsistency or fonnal dett..'Ct or omission in this Indenture; (b) to grant to or confer upon the Trustee for the benefit of the Holders any additional rights, remedies, powers or authority which lawfully may be granted to or conferred upon the Trustee; (c) to assign additional revenues under this Indenture; . -, " .1 (d) to accept additional security and instruments and documents of further assurance with respect to the Mortgaged Property; (e) to add to the covenants, agreements and obligations of the Issuer or the Company under this Indenture, other covenants, agrccments and obligations to be observed for the protection of the Holders, or to surrender or limit any right. remedy, power or authority reserved to or conferred upon the Issuer or the Company under this Indenture; (0 to evidence any succession to the Issuer and the assumption by its successor of the covenants, agreements and obligations of the Issuer under the Issuer Documents and the Bonds; (g) to make necessary or advisable amendments or additions in connection with the issuance of Additional Bonds in accordance herewith, or with the incurrence of Parity Debt in accordance with the Agreement, which do not adversely affect the interests of Holders of Outstanding Bonds; (h) to pennit the use of a book-entry system to identify the Holder of an interest in an obligation issued by the Issuer under this Indenture, whether that obligation was formerly, or could be, evidenced by a physical security; (i) to facilitate (A) the transfer of Bonds or notes issued by the Issuer under this Indenture and held in book-entry form from one depository to another and the succession of . J 76 tfi, I C( -.......-- ~u !t..1ndIi.~....",--.. ;.........., depositories, or (B) the withdrawal of Bonds or notes issul'<i by the Issuer under this Indenture and ,. delivered to a depository for use in a book-entry system and the issuance of replacement Bonds or notes in fully registered form and in the form of physical certificates to others than a depository; (j) to permit the Trustee to comply with any duties imposed upon it by law; (k) to specify further the duties and responsibilities of, and to define further the relationships among, the Trustee, the Registrar, any Authenticating Agents, any Paying Agents and any Tender Agent; (I) to achieve compliance of this Indenture with any applicable federal or state securities or tax law; (m) to make any other change which is not prejudicial to the Trustee or the Holders, in the judgment of the Trustee; '-j '-'" (n) to make amendments to the provisions hereof relating to arbitrage matters under Section 148 of the Code, if, in the Opinion of Bond Counsel, those amendments would not cause the interest on Bonds outstanding to become included in gross income of Holders for federal income tax purposes which amendments may I among other things, change the responsibility for making the relevant calculations; or (0) to provide for Additional Bonds to the extent permitted by Section 2.05 hereof. The provisions of subparagraphs U) and (I) shall not be deemed to constitute a waiver by the Trustee, the Registrar, the Issuer or any Holder of any right, remedy or power which it may have in the absence of those provisions to contest the application to this Indenture or the Bonds of any change in law. SECTION 8.03. Supplemental Indentures ReQuirin~ Consent of Holders. Exclusive of Supplemental Indentures to which reference is made above, and subject to the terms, provisions and limitations contained in this Section, and not otherwise, with the consent of the Holders of not less than a majority in aggregate principal amount of the Outstanding Bonds, evidenced as provided herein, and with the prior written consent of the Company, if required below, the Issuer and the Trustee may execute and deliver Supplemcntal Indentures adding any provisions to, changing in any manner, or eliminating any of the provisions of this Indenture or any Supplemental Indenturc, or restricting in any manner the rights of the Holders. Nothing in this Section or the preceding Section shall permit, however, or be construed as permitting: (a) without the consent of the Holder of each Bond so affected, (i) an extension of the maturity of the principal of or the interest on any Bond, (ii) a reduction in the principal amount of any Bond or the rate of interest or premium thereon, or (iii) a reduction in the amount or '..J 77 11-1C( - ~ ..~.,.:.. --.. ........ . ....-" ~ extension of the time of payment of any mandatory redemption requirements, including without limitation, any mandatory r~emption pursuant to Section 4.02 hereof; or (b) without the consent of the Holders of all Outstanding Bonds, (i) the creation of a privilege or priority of any Bond or Bonds over any other Bond or Bonds, or (ii) a reduction in the aggregate principal amount of the Bonds required for consent to a Supplemental Indenture. If the Issuer shall request that the Trustee execute and deliver any Supplemental Indenture for any of the purposes of this Section, upon (i) being indemnified satisfactorily with icSpect to its expenses in connection therewith. and (ii) if required by Section 8.04, receipt of the Company's consent to the proposed execution and delivery of the Supplemental Indenture. the Trustee shall cause notice of the proposed execution and delivery of the Supplemental Indenture to be mailed to each Holder at the close of business on the fifteenth day preceding such mailing at its address as it appears on the Register on that fifteenth day preceding such mailing. The Trustee shall not be subject to any liability to any Holder by reason of the Trustee's failure to mail, or the failure of any Holder to receive. the notice required by this Section. Any failure of that nature shall not affect the validity of the Supplemental Indenture when there has been consent thereto as provided in this Section. The notice shall describe briefly the nature of the proposed Supplemental Indenture and shall state that copies thereof are' on tile at the office of the Trustee designated therein for inspection by all Holders. ", ) If the Trustee shall receive, within a period of not fewer than 60 days. but not exceeding one year, as prescribed by the Company, following the mailing of the notice, an instrument or document or instruments or documents', in a form or forms to which the Trustee does not object reasonably, purporting to be executed by the Holders of not less than a majority in aggregate principal amount of the Outstanding Bonds, but not otherwise, the Trustee shall execute and deliver the Supplemental Indenture in substantially the form to which reference is made in the notice, without liability or responsibility to any Holder, regardless of whether that Holder shall have consented thereto. The instrument or document or instruments or documents described in this paragraph shall refer to the proposed Supplemental Indenture in the form described in the notice arid shall consent specifically to the Supplemental Indenture in substantially that form. Any consent shall be binding upon the Holder of the Bond giving the consent and, anything herein to the contrary notwithstanding, upon any subsequent Holder of that Bond and of any Bond issued in exchange therefor (regardlcss of whether the subsequent Holder has notice of the consent to the Supplemental Indenture). If the Holders of the required percentage in aggregate principal amount of Outstanding Bonds shall have consented to the Supplemental Indenture, 35 provided in this Section, no Holdcr shall have any right (i) to object to the execution or delivery of the Supplemental Indenture, any of the terms and provisions contained therein. or the operation thereof; (ii) to question the -.) 78 99 - If( ..."'. ."'.......-. - ,~ propriety of the execution and delivery thereof; or (iii) to enjoin or restrain the Trustee or the , " Issuer from that execution or delivery or from taking any action pursuant to the provisions thereof. SECTION 8.04. Consent of the Company. Anything herein to the contrary notwithstanding, no Supplemental Indenture executed and delivered in accordance herewith which affects any rights, remedies or powers of the Company shall become effective, unless the Company shall have consented in writing to the execution and delivery of that Supplemental Indenture. Unless waived by the Company, the Trustee shall cause notice of the proposed execution and delivery of any Supplemental Indenture and a copy of the proposed Supplemental Indenture to be mailed to the Company, (a) at least 30 days before the date of the proposed execution and delivery in the case of a Supplemental Indenture to which reference is made in Section 8.02 hereof; and (b) at least 30 days before the giving of the nmice of the proposed execution and delivery in the case of a Supplemental Indenture for which provision is made in Section 8.03 hereof. :,""j ."...,'" SECTION 8.05. ' Authorization to Trustee: Effect of Supplement. The Trustee is authorized to join with the Issuer in the execution and delivery of any Supplemental Indenture in accordance with this Article and to make the further covenants, agreements and stipulations which may be contained therein. Thereafter, (a) that Supplemental Indenture shall form a pan of this Indenture; (b) all terms and conditions, contained in that Supplemental Indenture as to any provision authorized to be contained therein shall be deemed to constitute a part hereof for all purposes; (c) this Indenture shall be deemed to be modified, amended and supplemented in accordance with the Supplemental Indenture; and (d) the respective rights, remedies, powers, covenants, agreements and obligations under this Indenture of the Issuer, the Company, the Trustee. the Registrar, the Paying Agents, the Authenticating Agents, the Tender Agent, the Rem3rketing Agent and all Holders of Outstanding Bonds shall be determined, exercised and enforced hereunder in a manner which is subject in all respects to those modifications, amendments and supplements made by the Supplemental Indenture. Express reference to any executed and delivered Supplemental Indenture may be made in the text of any Bonds issued thereafter, if that reference is deemed necessary or desirable by the Trustee. A copy of any Supplemental Indenture for which provision is made in this Article, except 3 Supplemental Indenture described in Section 8.02(g) hereof, shall be mailed by the , ,~ 79 19,/C6 --) Trustee to the Registrar, each Authenticating Agent. each Paying Agent. each Tender Agent and the Original Purchaser of the Bonds affected thereby. SECTION 8.06. Opinion of Counsel. The Trustee shall be entitled to receive, and shall be protected fully in relying upon, the opinion of any counsel approved by it as conclusive evidence that (i) any proposed Supplemental Indenture complies with the provisions of this Indenture, and (ii) it is proper for the Trustee to join in the execution of that Supplemental Indenture under the provisions of this Article. That opinion may be an Opinion of Bond Counsel. SECTION 8.07. Amendments to the Company Documents Not Requirin~ Consent of Holders. The Issuer and the Trustee may not enter into amendments. changes or modifications of the Agreement or Mortgage except as provided in this Section and Section 8.08 hereof and pursuant to the other provisions of this Indenture. Without the consent of or notice to the Holders. the Issuer and the Trustee may consent to any amendment, change or modification of the Company Documents which may be required (a) to comply with the provisions of the Company Documents and this Indenture; ~~ <,~) (b) to make necessary or advisable amendments or additions in connection with the issuance of Additional Bonds in accordance herewith, or with the incurrence of Parity Debt in accordance with the Agreement, which do not affect adversely the interests of Holders of Outstanding Bonds; (c) to cure any ambiguity, inconsistency or formal defect or omission in the Company Documents; (d) to release any real estate in accordance with the Company Documents or to accept additional real estate or any interest therein which becomes hereafter a part of the real property included in the Mortgaged Property under the Company Documents; (e) to amend or to effect any purpose for which there could be a Supplemental Indenture pursuant hereto without the consent of or notice to the Holders; or (f) to make any other change which is not prejudicial to the Trustee, the Issuer or the Holders, in the judgment of the Trustee. Anything herein to the contrary notwithstanding, no Company Documents executed and delivered in accordance herewith which affect any rights, remedies or powers of the Company shall become effective, unless the Company shall have consented in writing to the execution and delivery of such Company Documents. Unless waived by the Company. the Trustee shall cause notice of the proposed execution and delivery of any amended or modi tied Company Documents and a copy of the proposed Company Document to be mailed to the Company, '~ ,_4 80 tf1r/~ .__.~-Ir,...:---w,.;,.~~..:z ~ ...- ,/-\ ! (i) at least 30 days before the date of the proposed execution and delivery in the case of a Company Document to which reference is made in this Section~ and (ji) at least 30 days before the giving of the notice of the proposed execution and delivery in the case of a Company Document for which provision is made in Section 8.08 hereof. SECTION 8.08. Amendml:nts to the Company Documents Requirin2 Consent of Holders. Exclusive of amendments, changes or moditications to which reference is made in Section 8.07 ~ and subject to the tenns, provisions and limitations contained in this Section, neither the Issuer nor the Trustee shall consent to, execute or deliver (a) any amendment, change or modification of the Company Documents which would change the amount of or the time as of which the Revenues are required to be paid. without giving notice as provided in this Section of the proposed amendment, change or modification and receipt of the approval or consent thereto of the Holders of all of the Outstanding Bonds; or (b) any other amendment, change or modification of the Company Documents without giving notice as provided in this Section of the proposed amendment, change or modification and receipt of the approval or consent thereto of the Holders of not less than a majority in aggregate principal amount of the Outstanding Bonds. -, ~.) The approval or consent of the Holders shall be obtained as provided herein with respect to Supplemental Indentures. If the Issuer and the Company request the consent, execution or delivery of the Trustee to any proposed amendment, change or modification of the Agreement or the Mortgage as contemplated in this Section, upon being indemnified satisfactorily with respect to expenses in connection therewith, the Trustee shall cause notice of the proposed amendment, change or modification to be given in the same manner as provided herein with respect to notice of Supplemental Indentures. The notice shall describe briefly the nature of the proposed amendment, change or modification' and shall state that copies of the instrument or document embodying it are on file at the designated corporate trust office of the Trustee tor inspection by all Holders. SECTION 8.09. Modification by Unanimous Consent. Notwithstanding anything contained elsewhere in this Indenture, the rights, remedies. powers, covenants, agreements and obligations of the Issuer and the Holders, and the terms and provisions of the Bonds, this Indenture or any Supplemental Indenture, may be modified or alteredf and any Company Documents may be amended, changed or modified, in any respect with the consent of (i) the Issuer, (ii) the Trustee. (Hi) the Holders of a1l of the Outstanding Bonds. and (iv) if required by Section 8.04 hereof, the Company. v 81 19-/'6 " ...., ARTICLE IX DEFEASANCE SECTION 9.01. Release of Indenture. If (a) the Issuer shall pay all of the Outstanding Bonds, or shall cause them to be paid and discharged, or if there shall be paid otherwise to the Holders of the Outstanding Bonds, all Debt Service Charges due or to become due thereon; (b) the Trustee shall receive an amount sufficient to cause the Rebate Fund to contain an amount equal to the Excess Earnings with respect to the Outstanding Bonds calculated as of the date of release of this Indenlure in accordance with Section 5.05 hereof and provision shaH be made for the payment to the United Stales of Excess Earnings with respect to the Outstanding Bonds accruing subsequent to the date of release of this Indenture; and (c) provision shall be made also for the payment of all other sums payable hereunder and under the Agreement, the Mortgage and the Notes; then \ I . ,,,,..." this Indenture shall cease, determine and become null and void (except for those provisions surviving by reason of Section 9.03 hereof in the event that the Bonds are deemed to be paid and discharged pursuant to Section 9.02 hereof), and the covenants, agreements and obligations of the Issuer and the Company hereunder shall be released, discharged and satisfied; provided that in addition to any other requirements set forth herein, within 15 days after that payment or discharge, the Trustee shall cause a notice to be mailed to each Holder at the close of business on the date on which the payment and discharge shall have occurred at its address as it appears on the Register on that date of payment and discharge, which notice shall set forth (i) the date or dates, if any, designated for the redemption of the Bonds and, if applicable, any reservation retained by the Issuer and the Company to designate one or more redemption date or dates or to replace any designated redemption date or dates with an earlier . redemption date or dates; (ii) a description of the method of payment or discharge and of any obligations held by the Trustee therefor; and (iii) a statement that, except for the provisions set forth in Section 9.03, this Indenture has ceased, detenninlXl and become null and void in accordance with the provisions of this Article. Thereupon, and subject to the provisions of Section 9.03 hereof if applicable, the Trustee shall release this Indenture and shall execute and deliver to the Company any instruments or documents which may be requisite to evidence that release and discharge or which may be requested reasonably by the Company; and the Trustee and any other Paying Agents shall assign and deliver to the Company any property subject to this Indenture which may be in their :~ 82 Cf/~ /~'. ,~) .~) " 'J ,..:<" ~ t.............' .... . possession at the time. except for moneys. including without limitation, investments. in the Special Funds required (i) to be paid to the Company under Section 5.09 hereof, or (ii) to be held by the Trustee and the Paying Agents for the payment of Debt Service Charges. SECTION 9.02. Payment and Discharge of Bonds. All or any part of the Bonds shall be deemed to have been paid and discharged within the meaning of this Indenture, including without limitation, Section 9.01 hereof, if (a) the Trustee and any Paying Agents shall have received, in trust for and committed irrevocably thereto, sufficient moneys; or (b) the Trustee shall have received, in trust for and committed irrevocably thereto, noncallable Deteasance Obligations which are certified by an independent certitied public accountant or firm of such accountants, acceptable to the Trustee, to be of those maturities or redemption dates, to have payment dates, and to bear interest at those rates, in each case which will be sufficient. together with any moneys [0 which reterence is made in subparagraph (a) above, without further investment or reinvestment of either the principal amount thereof or the interest earnings therefrom (which earnings arc to be held likewise in trust and so committed. except as provided herein); for the payment of (i) moneys into the Rebate Fund sufficient to make rebate payments to the United States of A llerica required by the Code, (ii) all Debt Service Charges on those Bonds, at their maturity or redemption dates, as the case may be, or if a default in payment shall have occurred on 'any maturity or redemption date, then for the payment of all Debt Service Charges thereon to the date of the tender of payment and (ii) all fees, charges and expenses provided for by Section 6.03 hereof. If any of those Bonds are to be redeemed prior to the maturity thereof, notice of that redemption shall have been duly given or irrevocable provision satisfactory to the Trustee shall have been duly made for the giving of that notice or notice that the Issuer and the Company have reserved the right to replace the designated redemption dates with earlier redemption dates should be given as provided below. Any moneys held by the Trustee in accordance with the provisions of this Section may be invested by the Trustee only in noncallable Defeasance Obligations having maturity dates or redemption dates not later than the date or dates at which moneys will be required for the purposes described above. To the extent that any income or interest earned by, or increment to, the investments held under this Section is determined from time to time by the Trustee to be in excess of the amount required to be held by the Trustee for the purposes of this Section, that income, interest or increment shall be transferred at the time of that determination in the manner provided herein for transfers of amounts remaining in the Special Funds. If any Bonds are deemed to be paid and discharged pursuant to (his S~ction, within 15 days after those Bonds are so deemed to be paid and discharged, the Trustee shall cause a written notice to be given to each Holder at the close of business on the date on which the Bonds are deemed to 83 1'/,/6 ') " .,_J 'J ........ ............ ." t... ; ." . . ,.~ be paid and discharged at its address as it appears on the Register on that dale on which the Bonds are deemed to be paid and discharged. The notice shall (i) state the numbers of the Bonds deemed to be paid and discharged. or shall state that all Bonds of a panicular series are deemed to be paid and discharged; (H) set fonh a description of the obligations held as described above; and (Hi) if any Bonds will be so called for redemption, specify the date or dates on which those Bonds are to be called for redemption pursuant to a notice of redemption given or irrevocable provision made for that notice pUisuant to this Section. If the Issuer and the Company have reserved the right at the time of release of this Indenture to designate one or more redemption date or dates or to replace any designated redemption date or dates with an earlier redemption date or dates, notice shall be mailed by the Trustee, within 15 days after that payment and discharge, stating that the Issuer and the Company expressly reserve the right to direct the Trustee to caJl the Outstanding Bonds, or any of them, for redemption on a date or dates earlier than those specified at the time of the release of this Indenture or to direct that the Outstanding Bonds, or any of them, be redeemed prior to their stated maturity, on a date or dates to be designated subsequent to the release of this Indenture. In the event that the Issuer and the Company reserve such rights at the time of release of this Indenture, any such direction to designate one or more redemption dates or to replace any designated redemption date or dales with an earlier redemption dale or dates shall be (i) delivered to the Trustee in writing by the Company not fewer than 60 days prior to the newly designated redemption date of the Outstanding Bonds. (ii) accompanied by a written repon of an independent certified public accountant or tirm of such accountants acceptable to the Trustee that the noncallable Defeasance Obligations held by the Trustee are of those maturities or redemption dates, have the payment dates and bear interest at those rates, in each case which will be sufficient, together with any moneys delivered to the Trustee, without further investment or reinvestment of either the principal amount thereof or the interest earnings therefrom, (which earnings are to be held likewise in tnIst and so committed, except as provided herein) for the payment of all Debt Service Charges on the Outstanding Bonds at their maturity or redemption dates as may then be designated by the Company, and (iii) accompanied by an opinion of Bond Counsel to the effect that such direction is authorized or permitted under the terms of this Indenture and will not adversely affect the exclusion of interest on the Outstanding Tax-Exempt Bonds from gross income for federal income tax purposes. Within 30 days of receipt of such directiont report and opinion. the Trustee shall give notice of such direction to each Holder of a Bond on which payment of Debt Service Charges is affected thereby, at the Holder's address then shown on the Register, stating (c) a description of the obligations held as described above; 84 crt-1ft '"1 , -" \ '._J ":.J _..~L~,.i,.,...:..' :~..' '. ,r ~ (d) whether any Bonds will be called for redemption prior to their scheduled maturity or their redemption pursuant to mandatory redemption, including without limitation, the mandatory sinking fund requirements Of prior to any previously designatcd redemption dates and, if applicable. whether thc Issuer and the Company have reserved the right to designate one or more redemption date or dates or to replace any designated redemption date or dates with an earlier redcmption date or dates, and ' (e) if any Bonds will be so called for redemption, specify the date or dates on which those Bonds arc to be called for redemption pursuant to a notice of redemption given or irrevocable provision made for that notice pursuant to this Section. SECTION 9.03. Survival of Certain Provisions. Notwithstanding the foregoing, any provisions hereof which relate to (i) the maturity of Bonds; (ii) the interest payments and dates thereof; (iii) the optional and mandatory redemption provisions; (iv) the credits against the mandatory sinking fund requirements; (v) the exchange, transfer and registration of Bonds; (vi) the replacement of mutilated, destroyeq, lost or stolen Bonds; (vii) the safekeeping and cancellation of Bonds; (viii) the non-prcsentment of Bonds; (ix) the holding of moneys in trust; .<x) the repayments to the Company from the Special Funds; (xi) the calculation of a payment of the Rebate Amounts to the United States; and (xii) the duties of the Trustee and the Registrar in connection with all of the foregoing; shall remain in effect and shall be binding upon the Issuer, the Company, the Trusteet the Registrar, the Authenticating Agents, the Paying Agents and the Holders, notwithstanding the release, discharge and satisfaction of this Indenture. The provisions of this Article shall survive the release, discharge and satisfaction of this Indenture. 85 q1~/'6 '. .. .".,. '. :/-'\ ARTICLE X COVENANTS, AGREEMENTS, REPRESENTATIONS AND WARRANTIES OF THE ISSUER SECTION 10.01. Covenants and A2reements of the Issue(. In addition to any other covenants and agreements of the Issuer contained in this Indenture, any other Issuer Documents or the Bonds, the Issuer covenants and agrees further with the Holders and the Trustee as follows: (a) The Issuer will pay all Debt Service Charges. or cause them to be paid, solely from the sources, on the dates, at the places, and in the manner provided in this Indenture and the Bonds. (b) The Issuer will not assign the Revenues or any of the funds and accounts or cause to be created any debt, lien or charge thereon, except as contemplated herein. (c) All books, instruments and documents in the Issuer's possession relating to the Project or the Revenues shall be open to inspection at all times during the Issuer's regular business hours by any attorneys, accountants or other agents or employees of the Trustee which the Trustee may designate from time to time. \ . .~_.".,/ (d) At reasonable times and under reasonable regulations established by the Registrar, the Register may be inspected and copied by the Company, the Trustee, the Holders of 25 percent or more in aggregate principal amount of the Outstanding Bonds, or a designated representative of any of those panies, provided that the Registrar may refuse to allow such inspection or copying if advised by counsel that such inspection or copying is prohibited by law. (e) The Trustee may enforce, in its name or in the name of the Issuer, aJl rights, remedies and powers of the Issuer for and in the name and on behalf of the Holders and may enforce all covenants, agreements and obligations of the Company hereunder and under the Agreement and Mortgage,' regardless of whether the Issuer is in default in the pursuit or enforcement of those rights, covenants, agreements or obligations. The Issuer will take, however, all actions on its part which are necessary or advisable to comply with all covenants, agreements and obligations to be observed or perfonned by it on its part under the Issuer Documents. and will take all actions within its authority to maintain the Issuer Documents in effect. (t) The Issuer will take, or cause to be taken, all actions necessary or advisable to qualify the interest paid on the Series 1999 Bonds as excludable from gross income of the Holders for federal income tax purposes and from treatment as an item of tax preference for purposes of the alternative minimum tax imposed on individuals and corporations under the Code. It will not take or authorize to be take'n any actions that would adversely affect that exclusion under the Code. :0 86 1C;-f( --.-:':~I'~-~ . 1 /'} " 1 t '~.../ (.) ,I SECTION 10.02. .observance and Performance: Representations and Warranties. The Issuer will observe and perform faithfully at all times all covenants, agreements and obligations on its pan under the Issuer Documents and the Bonds and under all of its proceedings pertaining thereto. The Issuer represents and warrants that (a) It is duly authorized under the laws of the State, including particularly and without limitation, the Act, to issue the Series 1999 Bonds, to execute, deliver, observe and perform the Issuer Documents and the Series 1999 Bonds and to pledge and assign the Revenues and the Special Funds in the manner and to the extent contemplated hereunder~ (b) All covenants, agreements and obligations required to be observed and performed by the Issuer for the issuance. sale and delivery of the Series 1999 Bonds and for the execution and delivery of the Issuer Documents have been observed and performed; and (c) The Issuer Documents and the Series 1999 Bonds are legal, valid and binding , special obligations of the Issuer, enforceab~e in accordance with their respective tenns, except that the binding effect and enforceability thereof are subject to applicable bankruptcy, insolvency, reorganization, moratorium and other laws in effect from time to time affecting the rights of creditors generallYt and except to the extent that the enforceability thereof may be limited by the application of general principles of equity. SECTION 10.03. Enforcement ofIssuer's Obli2ations. Each obligation of the Issuer required to be undertaken pursuant to this Indenture, the Agreement and the Bonds is binding upon the Issuer, and upon each ofticer or employee thereof as may have from time to time the authority under law to take any action on behalf of the Issuer which may be necessary to perform all or any part of that obligation, as a duty of the Issuer and of each of those officers and employees. 87 99 ~ 18' ,~ ARTICLE Xl ! , "' " .! ., MEETINGS OF HOLDERS SECTION 11.01. Pur:poses of Meetin2s. A meeting of Holders, or of the Holders of any series of the Bonds, may be called at any time and from time to time pursuant to the provisions of this Article XI, to the extent relevant to the Holders of all of the Bonds or of Bonds of that series to take any action (i) authorized to be taken by or on behal f of the Holders of any specified aggregate principal amount of the Bonds, (ii) under any provision of this Indenture or authorized or permitted by law. SECTION 11.02. Call of Meetin~s: Place of Meetin~s. The Trustee may call at any time a meeting of Holders pursuant to this Article to be held at any rcasonable time and place which the Trustee shall determine. Notice of that meeting, setting forth the time and the place of the meeting and, in general tcrms, the subject thereof and the action proposed to be taken, shall be mailed not fewer than 15 nor more than 90 days prior to the date detennincd for the meeting. That notice shall be mailed to the Company and to each Holder at the close of business on the fifteenth day preceding the mailing of the notice at its address as it appears on the Register on that tlfteenth day preceding the mailing. The date of determination of Holders for purposes of the mailing shall constitute the record date for the meeting. --'" ) At any time, the Issuer, the Company or the Holders of at least 25 percent in aggregate principal amount of the Outstanding Bonds may request the Trustee in writing to call a meeting of Holders. The request shall describe in general terms the subject of the meeting and the action proposed to be taken. If the Trustee shall not have mailed the notice of the meeting within 20 days after receipt of the request, the Issuer, the Company or the Holders of Bonds in the amount descrilx.>d above, as the case may be, may determine a reasonable time and place of the meeting and may caB the meeting to take any action authorized in this ArticJe, by mailing notice thereof as provided above. "'-"'/ Any meetings of Holders of the Bonds affected by a particular matter, shall be valid without notice, if (a) the Holders of Outstanding Bonds are present in person or by proxy; or notice is waived before or after the meeting by the Holders of all Outstanding Bonds who were not so present at the meeting; and (b) the Issuer, the Company and the Trustee are either present by duly authorized representatives or have waived notice, before or after the meeting. SECTION I 1.03. M.t:~tings: Regulations of the Tnlste~. Notwithstanding any other provisions of this Indenture, the Trustee may make any reasonable regulations which it may deem to be advisable for meetings of Holders, with regard to ) '-"'; 88 9?~(6 ~-_I...~----,,--........-.._-_.. -.. .'.~ (a) proof of the holding of Outstanding Bonds and of the appointment of proxies; (b) the appointment and duties of inspectors of votes; (c), recordation 'of the proceedings of those me~tings; (d) the execution, submission and examination of proxies and other evidence of the right to vote; and (e) any other matters concerning the conduct, adjournment or reconvening of meetings which it may consider to be necessary or desirable. The Trustee shall appoinl a temporary chair of the meeting by an instrument or document in writing, unless the meeting shall have been called by the Issuer. the Company or Holders, in which case, the Issuer, the Company or the Holders calling the meeting, as the case may be, shall appoint a temporary chair in like manner. A permanent chair and a permanent secretary of the meeting shall be elected by vote of the Holders of a majority in principal amount of the Outstanding Bonds represented at the meeting and entitled to vote. SECTION 11.04. Votine: Speaking at Meetin2: Record of Meeting. To be entitled to vote at any meeting of Holders, a Person shall ,".-) (a) be a Holder of one or more Outstanding Bonds as of the record dale for the meeting as determined above; or '. o ""........W.....4n"'~iIt. ".,............... (b) be a Person appointed in writing by an instrument or document as proxy by a Holder, as of the record date for the meeting, of one or more Outstanding Bonds. The only Persons who shall be entitled to be present or to speak at any meeting of Holders shall be the Persons entitled to vote at the meeting and their counsel, any representatives of the Trustee and its counsel, any representatives of the Issuer and its counsel, and any representatives of the Company and its counsel. Each Holder or proxy shall be emitled to one vote for each $1,000 principal amount of Outstanding Bonds held or represented by it; provided, however, that no vote shall be cast or counted at any meeting in respect of any Bonds challenged as not Out.standing and ruled by the chair of the meeting to be not Outstanding. The vote upon any resolution submitted to any meeting of Holders shall be by written ballots on which shall be'subscribed the signatures of the Holders of Outstanding Bonds or of their representatives by proxy and the identifying number or numbers of the Outstanding Bonds held or represented by them. SECTION 11.05. Miscellaneous. Nothing contained in this Article shall be deemed or construed to authorize or permit any hindrance or delay in the exercise of any right, remedy 89 99 -/~ >', " ' . ".:". I., >,. ,", , ' . ' ;. ~'. ~ <. . ..5, I,," " ,-' . .' ,,', , ' ~ . I .. " , ~t:,"'\+~'~~+J. " t', , , ' ~; ", ....-.. I, 'f __ , ~(:~;':' \:'~i:"'lt J .: I: .I. ~': . . ," ~.. . 'C' ~.\ . }:. .. >. t': . 1-/:l," ,". :., "." T'.,,> ~ ?:~ \ . '" ~\:=c: : ~, . . , , '/", . , .:~: " ", ...t. ' ,"" j;.. " c I., . , " .'. !:".;.c ,;. . ','I, , "-~, ;-. . ,i I !'~' "'-./ ~ ',' . " <. , ' ." , ~ ~ . ~ " !". ' .~ . . , , , " , 1:< : :, " ,.,\.:q " ," '~ .... 'W' , . , . i.< . , . c.", j t.,',,'." " ' "" " , .. " , . I or pow~r:conferre(fupon or reserved to the Trustee or to the Holders under any of the provisions of. this Indentu're or of the Bonds by reason of any call of a mceling of Holders or any right, remedy or power conferred expressly or impliedJy hereunder to make a caJl of such a meeting. , ' ,I r . .~ I . . , , ,,' , , ,,90 19,/8' ." . ARTICLE XII M ISCELLAN EOUS SECTION 12.01. Limitation of Riehts. With the exception of rights, remedies and powers conferred expressly in this Indenture, 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, the Registrar, the Paying Agents, the Authenticating Agents, the Tender Agent, the Company and the Holders of the Bonds any legal or equitable right, remedy, power " or claim under or with respeci to this Indenture or any covenants, agreements or obligations hereunder or conditions and provisions herein. This Indenture and all of those covenants. agreements, obligations. conditions and provisions are intended to be. and are, for the sole and exclusive benefit of the parties hereto. the Company t the Registrar, the PaYing Agents. the Authenticating Agents arid the Holders of the Bonds, as provided herein. ~) SECTION 12.02. Severability. In case any article, .section or provision of this Indenture, or any covenant, agreement, obligation, condition, provision, act or action, or part thereof, made, assumed, entered into or taken under this Indenture, or any application thereof. is held to be illegal or invalid for any reason, or is inoperable at any time, that illegality, invalidity or inoperability shall not affect the remainder thereof or any other article, section, provision, covenant, agreement, obligation, condition, provision, act. action, part or application, made, assumed, entered into or taken under this Indenture, all of which shall be construed and enforced ,at the time as if the illegal, invalid or inoperable portion were not contained therein or herein. No illegality, invalidity or inoperability shall affect any legal. valid and operable article, section, provision, covenant, agreement, obligation, condition, provision, act, action, part or application, all of which shall be deemed to be effective, operative, made, assumed, entered into or taken in the manner and to the full extent permitted by law from time to time. SECTION 12.03. Notices. Except as provided in Section 7.02 hereof, it shall be sufficient service or giving of any notice, request, complaint, demand or other instrument or document, if it is duly mailed by first class mail, postage prepaid. (a) if the notice. request, complaint, demand or other instrument or document is to be served upon or given to the Issuer, the Company or the Trustee as follows: (i) if to the Issuer, at City of Clearwater. Florida, c/o Margaret L. Simmons, CPA, Financial Services Administrator, 100 South Myrtle Avenue, Clearwater, Florida 33756- 5520, whh copy to: City of Clearwater, City Attorney, 112 South Osceola Avenue. Clearwater. Florida; i,,' .i ,. 91 i i i I i I qCj-/f( L.. . ~1 , .' ') <..J .....1 ~ ,. ~I 10_ . .~,... ,,' . (ii) if to the Company, at BEF, Inc., 1601 Jack Street, Suite 200, Fort Myers, Florida 33901, Attention: President: (iii) if to the Trustee. SunTrust Bank. Central Florida. National Association, 225 East Robinson Street, Suite 250. Orlando. Florida 32801, Attention: Corporate Trust Departmcnt; and (iv) if to the original purchaser of the Scries 1999 Bonds, Ziegler Securities, a division of B.C. Ziegler and Company, 111 Second Avcnuc. N.E., Suite 915, St. Petersburg, Florida, Attention: President. (b) if the notice, request, complaint, demand or other instrument or document is to be served upon or given to the Registrar, any Paying Agent. any Authenticating Agent or any Original Purchaser, to the respective parties at their addresses provided by them in writing to the Trustee, which shall provide those addresses promptly upon request to any party obligated or entitled to serve or give that notice, request, complaint, dcmand or other instrument or document. Duplicate copies of each notice, request, complaint, demand or other instrument or document given hereunder by the Issuer, the Company or the Trustee shall be given also to the others. By a notice given hereunder, the Issuer, the Trustee and the Company may designate any further or different addresses to which any subsequent notice, request, complaint, demand or other instrument or document shall be sent. By a notice to the Issuer and the Company, the Trustee shall designate the addresses to which notices or copies thereof shall be sent to the Registrar, the Authenticating Agents, the Tender Agent and the Paying Agents. In connection with any notice, request, complaint, demand or other instrument or document hereunder, a certificate of the Trustee, the Issuer, the Company, the Registrar, any Paying Agent, any Authenticating Agent, or the Holders of the Bonds, whichever or whoever mailed that notice, request. complaint, demand or other instrument or document, that the notice, request, complaint, demand or other instrument or document was so mailed shall be conclusive evidence of the proper mailing thereof. Whenever Holders are to be determined for purposes of any notice or mailing as of 'a particular date, and that date is a date on which the Trustee is closed in accordance with Section 12.05(a), the applicable date shall be instead the next succeeding business day on which the Trustee is open for business. SECTION 12.04. Suspension of Mail. If because of the suspension of delivery of first class mail or, for any other reason, the Trustee shall be unable to mail by the required class of mail any notice, request, complaint, demand or other instrument or document required to be mailed hereby, the Trustee shall give it in any other manner which shall approximate most effectively the mailing thereof in accordance herewith in the judgment of the Trustee. The giving of that notice, request, complaint, demand or other instrument or document in that manner shall 92 11-/9: I~ be deemed for all purposes of this Indenture to be in compliance with the requirement for the mailing thereof. Except as provided otherwise herein, the mailing of any notice, request, complaint, demand or other instrument or document shall be deemed to be complete upon deposit thereof in the mail. and the giving thereof by any othcr mcans of delivery shall be deemed to be complete upon receipt thereof by the delivery service. SECTION 12.05. Payments Due on Saturdays. Sundays and Holidays. If any date of maturity of the principal of any Bonds. date fixed for redemption of any Bonds, or Interest Payment Date is a Saturday, Sunday or a day on which (a) the Trustee is required, or authorized or not prohibited. by law (including without limitation, executive orders) to close and is closed, payment of principal, redemption premium, if any. and interest need not be made by the Trustee or any Paying Agent on that date, but that payment may be made instead on the next succeeding business day on which the Trustee and the Paying Agent are open for business with the same force and effect as if that payment were made on the date of maturity, the date fixed for redemption, or the Interest Payment Date, and no interest shall accrue for the period after that earlier date; or --) L.....,. (b) a Paying Agent is required, or authorized or not prohibited, by law (including without limitation, executive orders) to close and is closed, payment of principal, redemption premium, if any, and interest need not be made by that Paying Agent on that date, but that payment may be made instead on the next succeeding business day on which that Paying Agent is open for business with the same force and effect as if that payment were made on the date of maturity, the date tixed for redemption, or the Interest Payment Date, and no interest shall accrue for the period after that earlier date. SECTION 12.06. Instmments of Holders. Any writing, including without limitation, any consent, request, direction, approval, objection or other instrument or document, required under this Indenture to be executed by any Holder may be in any number of concurrent writings of similar tenor and may be executed by that Holder individually or by an agent or attorney appointed in writing. Proof of (i) the execution of any writing, including without limitation, any consent, request, direction, approval, objection or other instrument or document, (ii) the execution of any writing appointing any agent or attorney, and (iii) the Ownership of Bonds, shall be sufficient for any of the purposes of this Indenture, if made in the manner provided under this Section or under Article XII, and if so made, shall be conclusive in favor of the Trustee with regard to any action taken thereunder. Proof under this Section is as follows: (a) the fact and date of the execution by any individual of any writing may be proved (i) by the certificate of any notary public or other officer in any jurisdiction, who has power by law to take acknowledgments within that jurisdiction, that the individual signing the writing acknowledged that execution before that officer, .:..) 93 99 -/C? .-) (ii) by affidavit of any witness to that execution. or (iii) by a guarantee of the execution by any bank; and (b) Registrar. the fact of Ownership of Bonds shall be proved by the Register maintained by the Nothing contained herein shall be const'11ed to limit the Trustee to the foregoing proof. and the Trustee may accept any other evidence of the matters stated therein which it deems to be sufticient. Except as provided otherwise herein, any writing. including without limitation, any consent, request, direction, approval, objection or other instrument or document. of the Holder of any Bond shall bind every future Holder of the same Bond, with respect to anything done or suffered to be done by the Issuer. the Trustee. the Registrar or any Paying Agent or Authenticating Agent pursuant to that writing. .~... , '_../ SECTION 12.07. Company to be Bound: Company's Actions. The Issuer will require each Person having charge of the operation of the Project to covenant and agree in writing to be bound by the provisions of this Indenture applicable to the Company, including without limitation, the provisions of the Agreement incorporated herein by reference, except as modified with the written consent of the Trustee. The Issuer shall include in any lease or other instrument or document, or in appropriate rules or regulations adopted by the Issuer. regarding the operation of the Mortgaged Property sufficient requirements which make those provisions controlling and binding upon each Person having charge of the operation of the Mortgaged Property. , The Trustee covenants and agrees that, for purposes of compliance with this Indenture. if the Company observes or performs any of the covenants, agreements or obligations required to be observed or performed by the Issuer under this Indenture, that observance or performance will satisfy the requirements of this Indenture. SECTION 12.08. Execution Counterparts. This Indenture may be executed in several counterparts, each of which shall be regarded as an original and all of which shall constitute but one and the same document. It shall not be necessary in proving this Indenture to produce or account for more than one of those counterparts. SECTION 12.09. Survival of Representation and Warranties. All representations and warranties of the Issuer and the Trustee herein shall survive the execution and delivery hereof and the issuance and delivery of the Bonds. SECTION 12.10. permitted by law: Yiilldity of Assignments and Security Interest. To the extent (a) The Revenues and the funds and accounts created hereunder are subject to the assignments made herein and the security interests granted herein without any further act. ..J 94 qq~/'6 ,~) (b) The assignments and security interest arc valid and binding against all parties having claims of any kind against the Issuer. without regard to whether those parties have notice thereof. (c) The assignments are absolute and unconditional present assignments and Lhe security interest creates a perfected security interest for all purposes, without the necessity for separation or delivery of the Revenues or of the funds and accounts created hereunder, and the filing, recording or registration hereof or of any resolution, legislation, instrument or document by which . the assignments and security interest arc created, granted or made or the filing, recording or registration of any certificate, statement or other instrument or document with respect to the assignment and security interests. . (d) The assignments and the security interest arc eftective and the moneys, including without limitation, investments, Lherefrom, thereof and therein may be applied to the purposes for which the assignments and grant are made without the necessity of any further act of appropriation. ...... '~'c) SECTION 12.11. Extent of Covenants: No Personal Liability. All covenants, stipulations, obligations and agreements of the Issuer contained in this Indenture are and shaH be deemed to be covenants, stipulations, obligations and agreements of the Issuer to the full extent authorized by the Act and permitted by the .Constitution and laws of the State. No covenant, stipulation, obligation or agreement of the Issuer contained in this Indenture shall be deemed to be a covenant, stipulation, obligation or agreement of any present or future member, officer, agent or employee of the Issuer in other than that person t s official capacity. Neither the members of the Issuer nor any official executing the Bonds, this Indenture, the Agreement or any amendment or supplement hereto or thereto shall be liable personally on the Bonds or be subject to any personal liability or accountability by reason of the issuance or execution hereof or thereof. SECTION 12.12. Bindin2' Effect. This Indenture shall inure to the benefit of and shall be binding upon the Issuer and the Trustee and their respective successors and assigns, subject, howevert to the limitations contained hercin. SECTION 12.13. Captions. The captions and headings in this Indenture are for convenience only and in no way define, limit or describe the scope or intent of any provisions or sections hereof. SECTION 12.14. Governine Law. This Indenturc shall be governed by and construed in accordance with the laws of the State. , -...J 95 Cf/-If{ ......~.,t~.....~,.,......-'I;;......... ., : ".i \' < +,..l.:'. I,'. ,~ , '. .J .'rl'''. '" i" , 8, .c, , , ~. '. o . \ ,. t ' " IN WITNESS' WHEREOF, the Issuer has caused this Indenture to be executed and . delivered for it and in its name and on its behalf by its duly authorized officers; and in token of its acceptance of the trusts created hereunder, the Trustee has caused this Indenture to be executed and delivered for it and in its name and on its behalf by its duly authorized ofticers; all as of the day and year first above written. (SEAL) CITY OF CLEARWATER, FLORIDA By: Mayor-Commissioner By: 1 .1 I , ! I [Assistant] City Manager " ATTEST: . Clerk Approved as to form and , legal sufficiency City Attorney SUNTRUST BANK, CENTRAL FLORIDA, NATIONAL ASSOCIATION, as Trustee By: Vice- President , ' 96 99~/r ....-....,,-...... .. .......:..r..:....~~-......:.............:....:........---...:._.. - .................~.~...j'el.....t... ..~~ '," . .' :~ ~<'r'.'''' , .' :'1 . ......... " ~;) , i. ...r..J;I~, I..J' " ",0', Acceptance of Appointment as Registrar t Paying' Agent, Authenticating Agent and Tender Agent for tbe Series 1999 Bonds The undersigned, by its execution hereof, in its name and on its behalf by its duly , authorized officers, does hereby accept the appointment as Registrar, Paying Agent, '. A~thenticating Agent and Tender Agent for the Series 1999 Bonds and, hereby assumes all the . rights, powers and duties of such Registrar, Paying Agent, Authenticating Agent and Tender , " Age~t under the IndentUre. For all purposes of Section 12.03 of the Indenture. the foIlowing , shall be the notice address for the undersigned until further written notitication to the Issuer, the Trustee, the Registrar and the CompaflY: 'Attention: Corporate Trust Department SUNTRUST BANK, CENTRAL FLORIDA, NATIONAL ASSOCIATION. as Trustee ,- By: Title: 97 Cf1.-/~ a .~~) '-) ......_...;...;,..,...,~ r . '.,~. ~ . EXHIBIT A [FORM OF SERIES 1999 [A][C] BOND] THIS BOND MAY BE TRANSFERRED ONLY TO AN tlACCREDITED INVESTORtI, AS SUCH TERM IS DEFINED IN REGULATION 0, OR ANY SUCCESSOR PROVISION THERETO, OF THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION, AND OTHERWISE TN ACCORDANCE WITH APPLICABLE FEDERAL AND STATE SECURITIES LAWS. NO. R- $ UNITED STATES OF AMERICA STATE OF FLORIDA CITY OF CLEARW A'fER, FLORIDA [TAXABLE] REVENUE BOND, SERIES 1999[A][C] (BEF, INC. PROJECT) MATURITY DATE: CUSIP: DA TED DATE: INTEREST RATE: Registered Holder: Principal Amount: DOLLARS The City of Clearwater, Florida (the tllssuer"), a municipal corporation duly created under the laws of the State of Florida, for value received, promises to pay to the Registered Holder (named above) or registered assigns (the "Registered Holder't), but solely from the sources and in the manner referred to herein, the Principal Amount (stated above) on the Maturity Date (stated above), unless this Bond is called for earlier redemption, and to pay I from those sources, interest thereon as hereinafter provided until the principal amount is paid or duly provided for. This Bond will bear interest at the Interest Rate (stated above) from the most recent date to which interest has been paid or duly provided for Of, if no interest has been paid or duly provided for, from the Dated Date (stated above). Interest shall be computed on the basis of a 360-day year of twelve 30-day months and shall be payable semiannually on May 15 and November 15 of each yea!" ("Interest Payment Dates") commencing on November 15, 1999 until the principal of this Bond shall have been paid or provided for. A-I 19-/'6 , , , ' "\ The principal or redemption price of this Bond shall be payable upon presentation and surrender hereof at the designated corporate trust office of the Paying Agent, initially SunTrust Bank, Central Florida, National Association, 225 East Robinson Street, Suite 250. Orlando, Florida, 32801 (the "Paying Agent"). Interest on this Bond is payable on cach Interest Payment Date by check or draft mailed by the Paying Agent to the person in whose name this Bond (or one or more predecessor bonds) is registered (the "Holder") on the Register for this issue maintained by the Registrar, initially SunTrust Bank, Central Florida, 225 East Robinson Street, Suite 250, Orlando, Florida, 32801. at whose address appearing therein at the close of business on the 15th day (whethcr or not a business day) of the calendar month next preceding that Interest Payment Date (the "Regular RL'Cord Date"). Any interest installment which is not timely paid or duly provided for shall cease to be payable to the Registered Holder hereof as of the Regular Record Date, and shall be payable together with interest on such past due interest at the Interest Rate (stated above) to the date established by the Trustee for the payment thereof (a uSpecial Interest 'Payment Date") to the person in whose name this Bond (or one or more predecessor bonds) is registen.."<l on the Register at the close of business on a special record date (the "Special Record Date") to be fixed by the Trustee, initially SunTrust Bank, Central Florida, National Association, 225 East Robinson Street, Suite 250, Orlando, Florida, 32801 (the "Trustee"). Notice of the Special Record Date and Special Interest Payment Date shall be given to Holders not less than ten (10) days priOl~ to such Special Record Date. If this Bond is redeemed on any date which is not an interest payment date, accrued interest shall be paid when the redemption price is paid. If this Bond is redeemed on any Interest Payment Date, the interest due shall be paid in the normal manner described below. r, -,-/ The principal of, premium, if any. and interest (collectively called "Bond Service Charges") on this Bond are payable in lawful money of the United States of America, without deduction for the services of the Paying Agent. This Bond is one of a duly authorized issue of lTaxable] Revenue Bonds, Series 1999[A][C] (BEF, Inc. Project) (thc "Series 1999[AJ[C] Bonds") of the Issuer, issued under the Trust Indenture, dated as of July 1, 1999 (the "Indenture"), between the Issuer and the Trustee, in the aggregate principal amount of $ , the proceeds of which will be used to make a loan (the "Loan") to BEF, Inc., a Florida not-for-profit corporation (the "Company"), to assist in the financing of costs of (1) acquiring, constructing, installing, equipping and improving and renovating its assisted living facilities and skilled nursing Project (collectively, the "Project"), (2) funding a debt service reserve fund and (3) paying certain costs and expenses relating to the issuance of the Series 1999[A]l C] Bonds, as more particularly described in the Loan and Security Agrcement between the Issuer and the Company dated of even date with the Indenture (the "Agreement"). The Bonds are issued pursuant to the laws of the State of Florida, particularly Chapter 154, Chapter 159, Part II and Chapter 166, Florida Statutes, as amended, and other applicable provisions of law, and a resolution duly adopted by the Issuer on March 8, 1999, as supplemented (collectively, the "Resolution"). .--J A~2 99,;f{ / tl The Series 1999[A][C] Bonds. together with the Issuer's $ aggregate principal amount of lTaxableJ Revenue Bonds Series 1999lAJlCj(BEF, Inc. Project)(tlu~"Series 1999{AllCJ Bonds") and $ aggregate principal amount of Revenue Bonds. Series 1999B (BEF, Inc. Project) Extendable Rate Adjustable SecuriticsSM (EXTRASSM) (the "Series 1999B Bonds") being issued simultaneously with the issuance of the Series 1999lAJ [C] Bonds and any Additional Bonds which may be issued on a parity therewith under the Indenture (collectively, the "Bondst'), are limited obligations of the Issuer, issued under and secured and entitled equally and ratably to the protection given by the Indenture. The Issuer shall not be obligated to pay the Bond Service Charges on this Bond except from amounts payable under the Agreement in repayment of the Loan, moneys and investments in the Project Fund (being any unexpended proceeds of the Bonds), in the Bond Fund and in the Debt Service Reserve Fund. and investment income thereon and the Companyts Revenues. as more particularly detined in the Indenture. pledged therefor (collectively, the "Trust Estate"), and neither the faith and credit nor the taxing power of the Issuer. nor the Slate of Florida or any political subdivision thereof is pledged to the payment of the Bond Service Charges on this Bond. The Bond Service Charges on the Bonds are payable solely from the Trust Estate and are an obligation of the Issuer only to the extent of the Trust Estate. . \ , t .,__..1 Pursuant to the Agreement, the Company has executed and delivered to the Trustee a Series 1999 Note (the "Series 1999 Note"), dated as of [the date of issue] hereof in the priricipal amount of $ . The Company is required by the Agreement and the Series 1999 Note to make payments to the Trustee in the amounts and at the times necessary to pay the Bond Service Charges on the Series 1999 Bonds. In the Indenture. the Issuer has assigned to the Trustee. to provide for the payment of the Bond Service Charges on the Bonds, the Issuer's right, title and interest in and to the Agreement, except for "Unassigned Rights" as defined in the Agreement. The Company's obligations under the Agreement and Series 1999 Note are secured by the Mortgage and Security Agreement dated as of July 1, 1999, from the Company, as mortgagor, (0 the Issuer~ as mortgagee, which has been assigned by the Issuer to the Trustee pursuant to the Assignment of Mortgage dated as of July 1, 1999. If additional bonds are issued as permitted by the Indenture, to make additional loans to the Company, the Company will execute additional promissory notes which wHl also be secured by the Mortgage. Any such additional bonds will be secured by the Revenues on a parity with the Series 1999A Bonds, the Series 1999B Bonds and Series 1999C Bonds. Reference is made to the Indenture, the Agreement. the Series 1999 Note and the Mortgage for a more complete description of the Project. the provisions, among others, with respect to the nature and extent of the security for the Bonds. the rights, duties and obligations of the Issuer, the Trustee and the Holders of the Bonds, the terms and conditions upon which the Bonds are issued and secured and the conditions upon which Additional Bonds may be issued. Each registered owner assents. by its acceptance hereof, to all of the provisions of the Indenture, the Agreement, the Series 1999 Note and the Mortgage. copies of which are on tile in the designated corporate trust office of the Trustee. J A-3 91-!ff .'} The Bonds are issuable only as fully registered bonds in the denominations of $100.000 and any $5,000 multiple thereof (" Authorized Denominations"). Bonds are exchangeable for fully registered Bonds of Authorized Denominations in equal aggregate principal amounts and the same maturity at the office of the Registrar. but only in the manner and subject to the limitations provided in the Indenture. This Bond is transferable on the Register or at the office of the Registrar by the Registered Holder in person or by his attorney. duly authorized in writing, upon presentation and surrender hereof to the Registrar in the manner and subject to the limitations provided in the Indenture. The Registrar is not required to transfer or exchange (i) any Bond during a period beginning at the opening of business 15 days before the day of the mailing of a notice of redemption of Bonds and ending at the close of business on the day of such mailing, or (ii) any Bonds so selected for redemption in whole or in part within 90 days following such mailing. :~~) ""'" The Series 1999[A][C] Bonds are subject to redemption prior to their stated maturity pursuant to notice by mail, postage prepaid, sent to the Holders thereof not more than sixty (60) days or fewer than thirty (30) days prior to the redemption date, as follows: Extraordinary Redemption Without Premium. (a) The Series 1999[A][C] Bonds are subject to extraordinary redemption at the direction of the Company on behalf of the Issuer, in part on any Interest Payment Date in Authorized Denominations from the proceeds of insurance or condemnation payments received in excess of $250,000 as a result of partial damage or destruction or taking under the power of eminent domain of a portion of the Mortgaged Property, in either case at a redemption price of 100 percent of the principal amount redeemed plus interest accrued to the redemption date. ' (b) The Company shall be obligated to cause the Series 1999B Bonds to be redeemed. in full, within thiny (30) days following the closing of the sale of the Bluff Building portion of the Project, at a redemption price of 100 percent of the principal amount thereof plus interest accrued to the redemption date. Optional Redemption. The Series 1999[A][C] Bonus maturing on or prior to November 15, 20_, are not subject to redemption prior to maturity at the option of the Company. The Series 1999[A][C] Bonds maturing on or after November 1St 20_t are subject to redemption prior to their maturity, at the option of the Issuer at the written request of the Company, on or after November 15, 20 ,in whole at any time or in part. in order of maturities as shall be detennined by the Company and by lot within a maturity, on any Interest Payment Date, at the redemption prices (expressed as percentages of principal amount of Bonds to be redeemed) set forth in the table below, plus accrued interest thereon to the date fixed for redemption: .~ A-4 91 ~ I r f) Period of Redemption (All dates inclusive) Redemption Prices November 15. 20_ to November 14. 20_ November 15. 20_ to November 14. 20_ November 15. 20_ and thereafter 102% 101 % 100% Mandatory Redemption. The Series 1999[A][C] Bonds maturing November 15, _ are subject to mandatory redemption prior to maturity in part, by lot, on November 15111 of each year. beginning November 15, , at a redemption price equal to 100% of the principal amount of the Series 1999[A][C] Bonds being redeemed plus accrued interest to the redemption date, without premium. in the following principal amounts and in the following years: ~ Amount $ * , "~ *Maturity If less than all Series 1999[A][C] Bonds are to be redeemed in full at one time, then, for purposes of partial redemption, each $100,000 of principal shall be deemed to be a separate Series 1999[A][C]Bond having a $100,000 principal amount. If Series 1999[A][C] Bonds or portions thereof are called for redemption and if on the redemption date moneys for the redemption thereof are held by the Trustee or the Paying Agent, then from and after such redemption date those Series 1999[A][CJ Bonds or portions thereof to be redeemed shall cease to bear interest, and shall cease to be secured by, and shall not be deemed to be outstanding under. the Indenture. The Indenture permits certain amendments or supplements to the Indenture. the Agreement, the Series 1999 Note and the Mortgage to be made without the consent of or notice to the Holders, and other amendments or supplements thcreto (with ccrtain exceptions, as provided in the Indenture) to be made with the consent of the Holders of not less than a majority in aggregate principal amount of the Bonds (hen outstanding. The Holder of each Series 1999[A][C] Bond has only those remedies provided in the Indenture. ",0" "l. ;--J A-5 tt9-lr --w~~~:",:::,::",,"":':"'~':.._':""__.,' ........ --~.~"" .... ''J The Series 1999[A][C] Bonds shall not constitute the personal obligation, either jointly " .0J or sev~ralJy,'of the members of the governing body of the Issuer or of any officer of the Issuer. This Series I999[AJ[C] Bond shall not be entitled to any security or benetit under lhe Indenture or be valid or lx.>come obligatory tor any purpose until the Certiticate of Authentication hereon shall have been duly signed. It is certified and recited that there have been performed and have happened in regular and due ronn, as required by law, all acts and conditions and things necessary to be done by the Issuer or to have happened (i) precedent to and in the issuing of the Series I999[AJ(C] Bonds in order to make them legal. valid and binding limited obligations of the Issuer. and (ii) precedent to and in the execution and delivery of the Indenture and the Agreement; that payment in full for the Series I999(A][Cl Bonds has been received; and that the Series 1999[Al[Cj Bonds do nor exceed or violate any constitutional or statutory limitation. IN WITNESS OF THE ABOVE, the City of Clearwater. Florida has issued this Series 1999[A)[C] Bond and has caused the same to be executed in its name by its Mayor- Commissioner and its City Manager and attested by its City Clerk and approved as to form and legal sufficiency by its City Attorney either manually or with their facsimile signatures. and its corporate seal or a facsimile thereof to be affixed, impressed, imprinted. lithographed or reproduced hereon, all as of the dated date shown above. <:> CITY OF CLEARWATER, FLORIDA By: Mayor-Commissioner (SEAL) By: City Manager ATTEST: By: City Clerk Approved as to form and legal sufficiency By: City Attorney ,~ A-6 1'9 -IP: . -....WMK.......~i. ffIIt;.l.k............,............................... .., .. ~. " J:.... ,.,' ~~ c; ,. 'c' ,~,d ~ . L _ ..' .' ;'--) . r~J CERTIFlCATE OF AUTHENTICATION This Bond is one of the Bonds described in the within-mentioned Indenture. Date of Authentication: SUNTRUST BANK. CENTRAL FLORIDA, NATIONAL ASSOCIATION. as Trustee By: ~ l ., Authorized Signer , - ~.:-- ~egistrable at: Payable by: . <J (FORl\1 OF ASSIGNMENT) The following abbreviations, when used in the inscription on the face of the within Bonds, shall be construed as though they were written out in full according to applicable laws or regulations: TEN COM as tenants in common TEN ENT as tenants by the entireties 1T TEN as joint tenants with right of survivorship and not as tenants in common UNIF TRANSFERS MIN ACT - Custodian (Cust) (Minor) under Unifonn Transfers to Minors Act (State) Additional abbreviations may also be used though not in list above. .-....~..... <.J . A-7 q'q~/g: ,jI~~i';;"l,r.!.~""""'.~',"":~;-~~"~ ' ... . . . . '. ~ '. , . . "l' d ~, ., ~ '.' .:~,::. ~', ,'~,,,,,,';'.,.,~'I,.,.L, ~,.. ~., '.I.~. ~,~: .r]' . . ....c"..t"~ ': ' :',. . c, ' ;:":' ~ :' J. ." ! , ',. -': .r) :. "- <0. " ' ., . ~ < ", ~i 'J. ASSIGNMENT For, value received. the undersigned sells. assigns and transfers unto the within Bond and irrevocably constitutes and appoints attorney to transter thac Bond on the books kept for registration there9f, with full power of substitution in the premises. Dated: Signature Guaranreed: Notice: The assignort 5 signature to this assignment must correspond with the name as it appears upon the face of the within Bond in every particular. without alteration or any change whatever. A-8 11-1'l 1--, [FORM OF SERIES 19998 BOND] THIS BOND MAYBE TRANSFERRED ONLY TO AN ItACCREDITED INVESTOR'" AS SUCH TERM IS DEFINED IN REGULATION 0, OR ANY SUCCESSOR PROVISION THERETO, OF THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION, AND OTHERWISE IN ACCORDANCE WITH APPLICABLE FEDERAL AND STATE SECURITIES LAWS. NO. R- $ UNITED STATES OF AMERICA STATE OF FLORIDA CITY OF CLEARWATER, FLORIDA TAXABLE REVENUE BOND, SERIES 1999B (BEF, INC. PROJECT) EXTENDABLE RATE ADJUSTABLE SECURITillSSM (EXTRA SSM) ,')'~ " MATURITY DATE: ORIGINAL ISSUE DA TED DATE: INITIAL INTEREST RATE: CUSIP: Registered Holder: Principal Amount: DOLLARS The City of Clearwater, Florida (the "Issuer"). a municipal corporation duly organized and existing under the laws of the State of Florida. for value receivedt promises to pay to the Regislered Holder (named above) or registered assigns (the "Registered Holder"), but solely from the sources and in the manner referred to herein. the Principal Amount (slated above) on the Maturity Date (stated above), unless this Series 1999B Bond is called for earlier redemption, and to pay. from those sources, interest thereon as hereinafter provided until the principal amount is paid or duly provided for. This Series 1999B Bond will bear interest at the Interest Rate (stated above) from the most recent date to which interest has been paid or duly provided for or, if no interest has been paid or duly provided fort from the Dated Dale (stated above). Interest shall be computed on the basis of a 360-day year of twelve 30-day months and shall be payable semiannually on May 15 and November 15 of each year commencing on November 15. 1999 ("Interest Payment Dates") until the principal of this Series 1999B Bond shall have been paid or provided for. '~J A-I 91-lft .......,..~...'1-;"'....I+"'.....,...<~-'~ '..' c ",.. ~,~. ~~""'''"'~_'''''-'''''''''''''-'''k''----~___ - i ,~-~) The principal or redemption price of th,is Scrics 1999B Bonds shall be payable upon presentation and surrender hereof at the dcsignatcd corporate trust office of the Paying Agent, initially SunTrust Bank, Central Florida. National Association. 225 East Robinson Street, Suite 250. Orlando, Florida, 32801 ("Paying Agent"). Interest on this Series 1999B Bond is payable on cach Interest Paymcnt Datc by check or draft mailed by the Paying Agent to the person in whose name this Series 1999B Bond (or one or more predecessor Series 1999B Bonds) is registered (the "Holder") on the Register for this issue maintained by the Registrar. initially SunTrust Bank, Central Florida, National Association. 225 East Robinson Street, Suite 250. Orlando, Florida, 32801 at whose address appearing therein at the close of business on the 15th day (whether or not a business day) of the calendar month next preceding that Interest Payment Date (the "Regular Record Date"). Any interest installment which is not timely paid or duly provided for shall cease to be payable to the registered owner hereof as of the Regular Record Date, and shall be payable together with interest on such past due interest at the Interest Rate (stated above) to the datc established by the Trustee for the payment thercof (a "Spccial Interest Payment Date") to the person in whose name this Bond (or one or more predecessor bonds) is registered on the Register at the close of business on a special record date (the "Special Record Date") to be fixed by the Trustee, initially SunTrust Bank, Central Florida, National Association. 225 East Robinson Street, Suite 250, Orlando, Florida, 32801 (the "Trustee"). Notice of the Special Record Date and Special Interest Payment Date shall be given to Holders not less than ten (10) days prior to such Special Record Date. If this Series 1999B Bond is redeemed on any date which is not an Interest Payment Date. accrued interest shall be paid when the redemption price is paid: If this Series 1999B Bond is. redeemed on any Interest Payment Date. the interest due shall be paid in the nonnal manner described below. /) The principal of, premium, if any, and interest (collectively called "Bond Service Charges") on this Series 1999B Bond are payable in lawful money of the United States of America, without deduction for the services of the Paying Agent. This Series 1999B Bond is one of a duly authorized issue of Revenue Bonds. Series 1999B Bond (BEF, Inc. Project) Extendable Rate Adjustable SecuritiesSM (EXTRASSM) (the "Series 1999B Bondsll) of the Issuer, issued under the Trust Indenture, dated as of July 1, 1999 (the "Indenture"), between the Issuer and the Trustee, in the aggregate principal amount of $_ , the proceeds of which will be used to make a loan (the .'Loanll) to BEF, Inc., a Florida not-far-profit corporation (the "Company"). to assist in the financing of costs of (I) acquiring, constructing, installing, equipping, improving and renovating its assisted living facilities and a skilled nursing facility (collectively. the t'Project"),(2) funding a Debt Service ,Reserve Fund. and (3) paying certain costs and expenses relating to the issuance of the Series 1999B Bonds, as more particularly described in the Loan and Security Agreement between the Issuer and the Company dated of even date with the Indenture (the "AgreementU). The Series 19998 Bonds are issued pursuant to the laws of the State of Florida, particularly Chapter 154, Chapter 159, Part II, and Chapter 166, Florida Statutes, as amended. and other applicable provisions of law, and a resolution duly adopted by the Issuer on March 8, 1999, as supplemented (collectively, the" Resolution It). '-...) A-2 tttJ-/f( ._~-'.~"!:..:.....:.....;;::.:.....;,.:.;..:..~...:.,~..................................--~---_.: !~ Thc Bonds, together with the Issuer's $ aggregate principal amount of Housing Rcvcnuc Bonds, Series 1999A (BEF, Inc. Project) (the ItSeries 1999A Bonds") and thc Issuer1s $ aggregate principal amount of Taxable Revenue Bonds. Series 1999C (BEF. Inc. Project)(the "Series 1999C Bonds") being issued simultaneously with the issuance of the Scries 1999B Bonds and any Additional Bonds which may be issued on a parity thercwith under the Indenture (coJlectively, the IlBonds"), are limited obligations of the Issuer. issued under and secured and cntitled equally and ratably to the protection given by the Indenture. The Issucr shall not be obligated to pay the Bond Service Charges on this Bond except from amounts payable under the Agreement in repayment of the Loan, moneys and investments in the Project Fund (being any unexpendt.>u proceeds of the Bonds), in the Bond Fund and in the Debt Service Reserve Fund. and investment income thereon and the Company's Revenues. as more particularly dctined in the Indenture, pledged therefor (collectively, the uTrust Estate"). and neither the faith and credit nor the taxing power of the Issuer. nor the State of Florida or any political sulxlivision thereof is pledged to the payment of the Bond Service Charges on this Bond. The Bond Service Charges on the Series 1999B Bonds are payable solely from the Trust Estate and are an obligation of the Issuer only to the extent of the Trust Estate. ...) Pursuant to the Agreement. the Company has executed and delivered to the Trustee a Series 1999 Note (the "Series 1999 Note"). dated as of the date of issue hereof in the principal amount of $ . The Company is required by the Agreement and the Series 1999 Note to make payments to the Trustee in the amounts and at the times necessary to pay the Bond Service Charges on the Series 1999B Bonds. In the Indenture. the Issuer has assigned to the Trustee, to provide for the payment of the Bond Service Charges on the Series 1999B Bonds. the Issuer's right, title and interest in and to the Agreement. except for "Unassigned Rights" as defined in the Agreement. The Company's obligations under the Agreement and Series 1999 Note are secured by the Mortgage and Security Agreement dated as of July 1, 1999. from the Company. as mortgagor, to the Issuer. as mortgagee. which has been assigned by the Issuer to the Trustee pursuant to the Assignment of Mortgage dated as of July 1, 1999, and the Company has issued its Series 1999 Note securing the payment of the Series 1999A, the Series 1999B Bonds and the Series 1999C Bonds. If additional bonds are issued as permitted by the Indenture, to make additional (oans to the Company, the Company will execute additional promissory notes which will also be secured by the Mortgage. Any such additional bonds will be secured by the Revenues on a parity with the Series 1999A Bonds, the Series 1999B Bonds and the Series I999C Bonds. Reference is made to the Indenture, the Agreement, the S~ries 1999 Note and the Mortgage for a more complete description of the Project. the provisions, among others, with respect to the nature and extent of the security for the Series 1999B Bonds, the rights. duties and obligations of the Issuer. the Trustee and the Holders of the Series 1999B Bonds. the temlS and conditions upon which the Series 1999B Bonds are issued and secured and the conditions upon which Additional Bonds may be issued. Each registered owner assents, by its acceptance hereof, to all of the provisions of the Indenture, the Agreement, the Series 1999 Note and the Mortgage, copies of which are on file in the designated corporate trust office of the Trustce. ~ A-3 99,-1fJ' ..) The Series 1999B Bonds are issuable only as fully registered bonds in the denominations of $100,000 and any integral multiple of $5,000 in excess thereof ("Authorized Denominations"). Series 1999B Bonds arc exchangeable for fully registered Bonds of Authorized Denominations in equal aggregate principal amounts and the same maturity at the office of the Registrar. but only in the manner and subject to the limitations provided in the Indenture. This Series 1999B Bond is transferable on the Register at the oftice of the Registrar by the Registered Holder in person or by his attorney. duly authorized in writing, upon presentation and surrender hereof to the Registrar in the manner and subject to the limitations provided in the Indenture. The Registrar is not required to transfer or chl..hange (i) any Series 1999B Bond during a period beginning at the opening of business ] 5 days before the day of the mailing of a notice of n.>demption of Serics 1999B Bonds and ending at the closc of business on the day of such mailingt or (ii) any Series 1999B Bonds so selected for redemption in whole or in pan within 90 days following such mailing. The Series 1999B Bonds will bear interest from t 1999 to and including [November 15. 20~ (the "Initial Rate Change Date"), at the rates set fOftl1 and established in accordance with Section 2.03(a) of the Indenture. The interest rates (thc "Adjustable Rates") on the Series 1999B Bonds from and after the Initial Rate Change Date will be established by the Remarketing Agent under the Remarketing Agreement, between the Remarketing Agent and the Company t in the manner described therein. ,_W..) \""'\1':";: The Adjusted Rate applicable to the Series 1999B Bonds shaJl be the rate (the "Reset Rate") deternlined by the Remarketing Agent on a date not less than 65 days prior to the Initial Rate Change Date and any rate change date selected by the Company pursuant to Section 2.05(b) of the Indenture (the "Rate Change Dare"). The Reset Rate applicable to the Series 1999B Bonds shall be the lowest rate that would, in the judgment of the Remarketing Agent (having due regard to the prevailing market conditions), be necessary to enable the Series 1999B Bonds to be sold at par on the Rate Change Date, provided that the Reset Rate shall not exceed 15% per annum (the "Maximum Rate"). Upon such determination of the Reset Rate, the Remarketing Agent shall promptly notify the Trustee and the Company of the Reset Rate. Not less than 60 days prior to the Rate Change Date, the Trustee shall promptly notify each Holder of Series 1999B Bonds in writing by first class mail, postage prepaidt of the Reset Rate that will be applicable to such Series 1999B Bonds on and after the Rate Change Date and provide instructions for the procedure to be followed by any Holder wishing to tender Series 1999B Bonds for purchase as hereinafter provided. If for any reason the Reset Rate for the Series 1999B Bonds cannot be determined by the Remarketing Agcnt in the manner specitied above, the Reset Rate will be equal to The Bond Buyer Revenue Bond Index (as published in n,e BUild Buyer or any successor publication thereto) for the most recent period for which slH.:h information is available prior to the giving of notice of the Reset Rate by the Trustee to the Holders of the Series 1999B Bonds, or if such index or its equivalent is no longer published. the interest rate currently in effect. provided that such rate may not exceed the Maximum Rate. , '-~ A-4 91-/'6 ....... ,.-......,.~, '. ,,', 'J In addition, the interest rate on the Series 1999B Bonds will not be reset on any Rate Change Date unless (a) at least 75 days prior to such Rate Change Date and (b) on such Rate Change Date. the Company shall cause to be delivered. at its expenset to the Trustee and the Remarketing Agent an Opinion of Bond Counsel. to the effect that such reset in interest rate and change in the Rate Period will not have an adverse effect on any exemption from Federal income taxation to which the interest on the Series 1999B Bonds would otherwise be entitled. The Company shall use its best eflorts to cause such Opinion of Bond Counsel to be delivered to the Trustee by such dates. In the event such Opinion of Bond Counsel is not delivered. the interest rate on the Series 1999B Bonds currently in effect shall remain in effect as the Reset Rate for the next rate period. which shall be equal in duration to the preceding fate period but shall not in any event extend beyu'nd the date of tinal maturity of the Series 1999B Bonds. I The Series 1999B Bonds are subject to redemption prior to their stated maturity pursuant to notice by mail. postage prepaid. sent to the Holders thereof not more than sixty (GO) days or fewer than thirty (30) days prior to the redemption date. as follows: ~- ') ""tr'j Extraordinary Redemption Without Premium. (a) The Series 1999B Bonds are subject to extraordinary optional redemption at the direction of the Company on behalf of the Issuer, in part on any Interest Payment Date in Authorized Denominations from the proceeds of insurance or condemnation payments received as a result of partial damage or destruction or taking under the power of eminent domain of a portion of the Mortgaged Property in excess of $250,000, in either case at a redemption price of 100 percent of the principal amount redeemed plus interest accrued to the redemption date. Optional Redemption. The Series 1999B Bonds may be redeemed in whole or in part on any date occurring within the redemption periods. as set torth below, by the Issuer upon direction of the Company. The redemption price for any such redemption shall be at a redemption price equal to 100% of the principal amount of the Series 1999B Bonds or portion thereof so redeemed on the applicable redemption date. plus accrued interest to the redemption date. (i) During the period between the issuance of the Series 1999B Bonds and the Initial Rate Change Date, the Series 1999B Bonds are subject to optional redemption on or after 15. 20_, (ii) During any Rate Period of three years in length, the Series 1999B Bonds are subject to optional redemplion commencing on the IS-month anniversary of the first day for such Rate Period. (Hi) During any Rate Period of five years in length, [he Series 1999B Bonds are subject to optional redemption commencing on the 24-momh anniversary of the first day of such Rate Period. ) A-5 91-1<6 -,r~~>:'~;"t: .....c,~ ~ .~ ') ,.' ) ............ \~ ~.~I~..:-~~V"""'.' -. l. (iv) During any Rate Period of seven years in length, the Scries 1999B Bonds are subject to optional redemption commencing on the 30.month anniversary of the first day of such Rate Period. (v) During any Rate Period of ten or morc years in length. the Series 1999B Bonds are subject to optional redemption commencing on the fifth anniversary of the first day of such Rate Period. The Series 1999B Bonds tendered for purchase on any Rate Change Date but not so purchased shall be given priority for redemption on each succeeding optional or extraordinary redemption date until redeemed prior to the oplional or extraordinary redemption of any other Series 1999B Bonds. Series 1999B Bonds so given priority shall be selected by the Trustee, by lot or in such other equitable manner as the Trustee shall deem appropriate. in the event of insufficient funds to redeem all such Series 1999BBonds on any particular redemption date. Mandatory Sinking Fund Redemption. The Series 1999B Bonds are subject to mandatory redemption prior to maturity in part, by lot (except that Series 1999B Bonds that have been tendered for purchase on any Optional Tender Date but were not so purchased shall be redeemed prior to the redemption of any other Series 1999B Bonds), on November 15th of each year, beginning November 15. 20_, at a redemption price equal to one hundred percent (100%) of the principal amount of the Series 1999B Bonds being redeemed plus accrued interest to the redemption date, without premium, in the following principal amounts and in the following years: ~ Amount $ * *Maturity If less than all Series 1999B Bonds are to be redeemed in full at one time, then, for purposes of partial redemption. each $100.000 of principal shall be deemed to be a separate Series 1999B Bond having a $100,000 principal amount. If Series 1999B Bonds or portions thereof are called for redemption and if on .the redemption date moneys for the redemption thereof are held by the Trustee or the Paying Agent. then from and after such redemption date those Series 1999B Bonds or portions thereof to be redeemed shall cease to bear interest. and shall cease to be secured by, and shall not be deemed to be outstanding under. the Indenture. [TENDER OPTION - TO COME] A-6 q9 -/g () The Indcnture pcrmits certain amendments or supplements to the Indenture, the Agreement, the S~ries 1999 Note and the Mortgage to be made without the consent of or notice to the Holders, and other amendments or supplements thereto (with certain exceptions, as provided in the Indenture) to be made with the consent of the Holders of not less than a majority in aggregate principal amount of the Series 1999B Bonds then outstanding. The Holder of each Series 1999B Bond has only those remedies provided in the Indenture. The Series 1999B Bonds shall not constitute the personal obligation, either jointly or severally, of the members of the governing body of the Issuer or of any officer of the Issuer. This Series 1999B Bond shall not be entitled to any security or benefit under the Indenture or be valid or become obligatory for any purpose until the Certificate of Authentication hereon shall have been duly signed. ---) c. It . ,.... It is certified and recited that there have been perfonned and have happened in regular and . due foflTl, as required by law, all acts and conditions and things necessary to be done by the Issuer or to have happened (i) precedent to and in the issuing of the Series 1999B Bonds in order to make them legal. valid and binding limited obligations of the Issuer, and (ii) precedent to and in the ex~ution and delivery of the Indenture and the Agreement; that payment in full for the Series 1999B Bonds has been rt..-ceived; and that the Series 1999B Bonds do not exceed or violate any constitutional or statutory limitation. . I. <J A-7 1'9 - /'6 ~~~.4t'.:;~===-----__~_..__.:_:__., . . \. . ..IJ..., '''. ,;,.: ", ....' '.. " ' , c \:' t', . :> () ;.~ .'~'r" .~ ~ . . , . . ". ': . .',. ". ': , >.,. . c" " . " , . " : ',.,-. '. ~:",U '..... ';'0. , ' "" 'l' 'J , . .~;.'i ~ . , : ~:..'. ~'. .}. . I I IN WITNESS OF THE ABOVE, the City of Clearwater, Florida has issued this S~ries . 19998 Bond and has caused the same to be ex~uted in its name by its Chairman and attested by its Secretary ..either manually or with their facsimile signatures, and its corporate seal or a facsimile thereof to be aftixed. impressed. imprinted. lithographed or reproduced hereon. all as of the dated date shown above. (SEAL) " , . ATTEST: . By: City Clerk Approved as to fom and legal suft1ciency By: . City Attorney Jo ... .. '~ . \. 0'" [ ; .. .,' I I . ( i 1 CITY OF CLEARWATER. FLORIDA By: By: .' A-8 Mayor-Commissioner City Manager . ,.l tt1 ,-/~ I'. <~] . . J '-~1 .....J ". -) .I CERTIFICA TE OF AUTHENTIC A TION This Series 1999B Bond is one of the Series 1999B Bonds described in the within~ mentioned Indenture. Date of Authentication: SUNTRUST BANK, CENTRAL FLORIDA. NATIONAL ASSOCIATION. as Trustee By: Authorized Signer . Registrable at: Payable by: (FORl\'I OF ASSIGNMENT) The following abbreviations, when used in the inscription on the face of the within Series 1999B Bonds, shall be construed as though they were written out in full according to applicable laws or regulations: TEN COM as tenants in common TEN ENT as tenants by the entireties JT TEN as joint tenants with right of survivorship and not as tenants in common UN IF TRANSFERS MIN ACT ~ Custodian (Cust) under Uniform Transfers to Minors Act (State) Additional abbreviations may also be used though not in list above. A.9 .....~::'tIt~,~u......'"':""....._...,........... .". ".". ."/ . ..,." . (Minor) 1'9 -;r , , '"'" 'r') .' ASSIGNMENT For value received, the undersigned sells" assigns and transfers unto the within Series 1999B Bond and irrevocably constitutes and appoints ' attorney to transfer that Series 1999B Bond . on the books kept for registration thereof. with full power of substitution in the premises. Dated: ,! ";: Signature Guaranteed: ), (0 ,. Notice: The assignor's signature to this assignment must correspond with the name as it appears upon the face of the within Series 1999B Bond in every panicular. without alteration or any change whatever. ,. , , :.:) . A-IO 11" !~ ~~~~,~~f~"""~~~._~=-~~'_,;._ " . ~. . '.' .. <,.'.", ,';.::" ;..: . .~.,'. c, '....c.. ~ . .". , . ~ I, ..'. < ", "." ~ . . "," " .,-"\ , ') ..J . . ""> .J EXHIBIT 8 FORM OF INVESTOR LETTER City. Commission City of Clearwater Clearwater. Florida SunTrust Bank. Central Florida. National Association Orlando. Florida, 32801 Ladies and Gentlemen; This letter is being executed and delivered by the undersigned as purchaser (the llPurchaserll) to the City of Clearwater, Florida (the llIssuerll). and SunTrust Bank, Central Florida, National Association, as trustee, so that the Issuer will enter into a Trust Indenture (the llIndenturell). dated as ofJuly 1, 1999 between the Issuer and SunTrust Bank. Central Florida, National Association, a national banking association, as trustee (the llTrustee") and other related agreements and will issue, sell and deliver its Revenue Bonds, Series 1999 (BEF, Inc. Project) (the "Bonds") to the Purchaser to finance the acquisition and renovation of existing adult assisted living and skilled . nursing home facilities (the "Project") owned by BEF. Inc. (the lICompanyll). Terms defined in the Indenture are used in this letter with the meanings assigned to them iri the Indenture. The undersigned hereby represents, warrants and agrees to and with the Issuer that: 1. The Purchaser is an accredited investor as such tenn is defined in the Securities Act of 1933 and Regulation D issued pursuant thereto, a principal part of whose business consists of buying securities such as the Bonds and which is a bank, savings institution, trust company! insurance company, investment company as defined in the Investment Company Act of 1940. pension or profit-sharing trust or other financial institution or institutional buyer or a broker dealer. 2. The Purchaser has received copies of the Indenture, the Loan and Security Agreement, the Mortgage and Security Agreement and certain of the other documents or instruments being delivered in connection with the issuance of the Bonds, and said documents are in fonn and substance satisfactory to the Purchaser and its counsel. The Purchaser has received and reviewed a copy of the [Official Statement] from the Underwriter. B-1 ri'-Iff I i' I .~ 3. The Purchaser has conducted its own investigations, to the extent it deems satisfactory or sufficient into matters relating to the business. properties. management, and financial position and results of operations of the Company and the Project. 4. The Purchaser is aware that the operation of the Project involves certain economic variables that could etlect the security of its investment in the Bonds. 5. The Purchaser acknowledges that the Issuer is acting merely as a conduit issuer on behalf of the Company, and that no revenue or assets of the Issuer are or can be used to pay the principal ot: premium. if any, and interest 0 the Bonds except for payments to be made by the Company under the Notes and the Loan and Security Agreement. which have been assigned to the Trustee. 6. The Purchaser understands that the Bonds are not registered under the Securities Act of 1933, as amended. The Purchaser is purchasing the Bonds for its own account for invest~ ment and not with a view to, and with no present intention ot: distributing or reselling the Bonds or any portion thereof, providing that the Purchaser reserves the right to transfer any or all of the Bonds purchased or any interest therein at any time and in our sole discretion and, in the event that we so transfer Bonds, we assume the responsibility for complying with any applicable federal and state securities laws and the terms of the Indenture. . ,.' ) -,' The Purchaser understands and agrees that the foregoing representations will be relied upon by the Issuer in the issuance of the Bonds and by Bond Counsel to the Issuer [and counsel to the Underwriter] in rendering opinions on the exclusion of the Bonds from the registration requirements of the Securities Act of 193,3, as amended, 15 U.S. C, Section 77a. Very truly yours, as Purchaser .f . By: Name: Title: ~J B.2 91-/~ 'f," ., ; " .". ," .',' ~~:"P". ": Ir'~ ~.,' , ~ ~ . " o ...' < , ;. I If -: \ . '.' 'I, -i:::' '\' : Jo, " ,; 1 L>: ,.' '., \ '<, i~ Lt.. ..... , ~ . " . " f,:' I.,. '" ( G ,. , I ' .. /' \-.' 0" l.< " ...., "~ . , < ~:. .' 1:-" .:'"->, :'1, .' ".r .1."' EXHIBIT B FORM OF MORTGAGE AND SECURITY AGREEMENT ~ I, . ~ ',(. ~'\ .. . Resolution 99-18 I I', <) i . " j ., -j , , 1 l I , --...., ) '- ... .-.J ,'''l-I DRAFT 113 OS/28/99 BMO #3195 This instrument was prepared by or under the supervision of (and after recording should be returned to): Robert C. Reid. Esq. Bryant. Miller and Olive. P.A. 201 South Monroe Street Suite 500 Tallahassee, Florida 32301 (SpgCC ~",ed ror CierI:: or Coun) MORTGAGE AND SECURITY AGREEMENT from BEF, INC., a Florida not-for-profit corporation (Mortgagor) to CITY OF CLEARWATER, FLORIDA (Mortgagee) relating to CITY OF CLEARWATER, FLORIDA REVENUE BONDS (BEF, Inc. Project) Dated as of July I. 1999 THIS INSTRUMENT, THE NOTES AND THE MORTGAGOR'S OBLIGATIONS SECURED HEREBY ARE GIVEN TO SECURE THE BONDS DESCRIBED HEREIN WHICH ARE ISSUED PURSUANT TO THE PROVISIONS OF CHAPTER 159. PART 11, FLORIDA STATUTES, AS AMENDED, AND THIS INSTRUMENT, THE NOTE. THE MORTGAGORtS OBLIGATIONS AND THE BONDS ARE EXEMPT FROM FLORIDA DOCUMENTARY STAMP TAX AND FLORIDA INTANGIBLE PROPERTY TAX AS PROVIDED IN SECTIONS 159.27(1) AND 159.31, FLORIDA STATUTES, AS AMENDED. Cfl-/S ..,..... .....'..., ..jo".'- "". . ,". I. . L . I _ ..M. __,.....~...........-......__...o....-_,_..__. .,' .,. .,,.., ,.") INDEX (The Index is not a part of this Mortgage and is only for convenience of rcferc~ce.) ARTICLE I DEFINITIONS Section 1.1. JJse of Defined Terms ................................... 6 Section 1.2. Definitions........................................... 6 Section 1.3. Interpretation........................................ II . ARTICLE II PRESERVATION OF SECURITY . r<"~ Section 2.1. Representations and Warranties. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 12 Section 2.2. Recordation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 12 Section 2.3. After~AcQuired Property . . . . . . . . . '. . . . . . . . . . . . . . . . . . . . . . . . 12 Section 2.4. Liens and Encumbrances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Section 2.5. Security Aereement and Financing Statement . . . . . . . . . . . . . . . . . . .. 13 Section 2.6. No Claims Against Mon~agee .............................. 13 Section 2.7. Security for Future Advances . . . . . . . . . . . . . . . .'. . . . . . . . . . . . .. 13 Section 2.8. Hazardous WaSt: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .'. . . . .. 14 Section 2.9. In~ectjon ..........,.,..... II- .. .. . . .. . . . . . .. .. .. .. . .. .. .. . .. . .. . . . .. .. .... 16 ARTICLE III TAXES, MECHANICS' LIENS AND INSURANCE Section 3.1. Payment of Taxes and Other Governmental Charges ............... 17 Section 3.2. Mechanics' and Other Liens. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 17 Section 3.3. Insurance........................................... 17 Section 3.4. Workers' Compensation Coveragt: . . . . . . . . . . . . . . . . . . . . . . . . . .. 19 Section 3.5. Title InsurancG ............................. . . . . . . . . . . 19 ARTICLE IV MAINTENANCE AND USE OF MORTGAGED PROPERTY (J Section 4.1. Compliance with Leial and Insurance Requirements ............... 20 . Section 4.2. Maintenance and Use of Mortga~ed PropertY . . . . . . . . . . . . . . . . . . . . 20 Section 4.3. Additions. Modifications and Improvements ........:........... 21 Section 4.4. fulbstitutions and Removals ............................... 21 Section 4.5. IndemnificatioQ....................................... 22 ii 19" If{ () .:) o Section 5.1. Section 5.2. Section 5.3. Section 5.4. ARTICLE V DAMAGE, DESTRUCTION AND CONDEMNATION D D. f P' 1- '1" ama2-e to or estrucllon 0 roJect 'ael Illes ................... Use of Insurance Proceeds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Eminent Domain . .. , , . ... III III 01 . . . . ... . ... 01 ... ... . . . .. . ... .. 01 .. . .. .. . . 01 .. .. .. iI Investment and Disbursement of Net Proceeds ARTICLE VI REMEDIES 23 23 24 . 25 Section 6. 1. Ri2ht to Perform Covenants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 Section 6.2. Events of Default ...................................... 26 Section 6.3. Remedies........................................... 27 Section 6.4. Waiver of Appraisement: Valuation . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Section 6.5. Appointment of Receiver. . '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Section 6.6. Possession. Management and Income: Assignment: Application of Money& Received . ... ... . . . .. ... .. . .. ... .. .. ... . . of . .. .. ... ... ... .. ... ... .. .. .. 01 .. .. . . . .. .. .. .. ... ... .. 28 Section 6.7. Remedies Cumulative . .'. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Section 6.8. Provisions Subiect to Applicable Law. . . . . . . . . . . . . . . . . . . . . . . . . 29 Section 6.9. No Waiver by Mortgagee ................................ 29 Section 6.10. Discontinuance of Proceedings and Restoration of Status Quo ......... 29 Section 7. 1. . Section 7.2. Section 7.3. Section 7.4. Section 7.5. Section 7.6. Section 7.7. Section 7.8. Section 7.9. Section 7.10. Section 7.11. EXHIBIT A EXHIBIT B EXHIBIT C EXHIBIT D ARTICLE VII MISCELLANEOUS Additional Security .................................. .' . 30 Release of Mortgaged Property and Easements . . . . . . . . . . . . . . . . . . . 30 30 30 31 31 31 31 31 32 32 Expenres .. .. .. .. .. .. . .. ... .. . ... .. jI ... ... III ... .. .. III 01 ... ... .. .. ... -II ... .. ... .. .. .. III .. . .. III .. .. .. .. Books. Records and Accounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Estoppel A ftictavits ....................,.,............. Subrogation . . . . . . . . . . . , , , . . . . . . . . . . . . . . . . , . . . . . . . . . . No Mer~er .. . .. ... ... r I ... .. III .. .. . .. ... ... .. . ... .. ... .. .. .. .. . .. ... III .. . .. .. .. .. .. .. . .. . .. .. Oeneral Provisions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. " . . . . . . Amendments. Chang.es and Moditications . . . . . . . . . . . . . . . . . . . . . . D' ... ISposltlon .. iI .. . . . . . .. iI . . . . . . . .. . . , . . . . . .. .. . . . . .. . iI . . iI .. . Issuer's Right of Purchase , . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . PROJECT SITE LEGAL DESCRIPTION PERMITTED ENCUMBRANCES FORM OF PROMISSORY NOTE . ASSIGNMENT OF MORTGAGE AND SECURITY AGREEMENT jji qq ---I 'it r) MORTGAGE AND SECURITY AGREEJ\.'IENT Maxilllwll Indebtedness Not to Exceed $35tOOO,OOO TIllS MORTGAGE AND SECURITY AGREEl\IENT (the "Mortgage"), dated as of July 1. 1999. executed and delivered by BEF, INC., a Florida not-for-protit corporation (the ,. Mortgagor"). to the CITY OF CLEARWATER, FLORIDA. a municipal corporation duly created and existing under the laws of the State of Florida (the "Issuer" or the tlMortgagee"), under the circumstances summarized in the following recitals (the capitalized terms not defined in the recitals hereto are defined in Article I hereot): ,.~) A. Pursuant to the Act. the Issuer has issued. sold and delivered its Series 1999 Bonds in the aggregate principal amount of $ , consisting of $ aggregate principal amount of Revenue Bonds. Series 1999A (HEF, Inc. Project) (the "Series 1999A Bonds"). $ aggregate principal amount of Revenue Bonds, Series 1999B (HEF, Inc. Project), Extendable Rate Adjustable SecuritiesSM (EXTRASSM) (the "Series 1999B Bonds") and $ aggregate principal amount of Taxable Revenue Bond I Series 1999C (BEF, Inc. Project)(the "Series 1999C Bonds" and together with the Series 1999A Bonds and the Series 1999B Bonds, the "Series 1999 Bonds"). The Series 1999 Bonds have been issued pursuant to the Indenture between the Issuer and First Union National Bank of Florida. Jacksonville. Florida. as Trustee. Reference is hereby made to the Indenture. a counterpart of which is on tile and available for inspection at the Notice Address of the Trustee. B. Pursuant to the Agreement to which reference is hereby made and a counterpart of which is on file and available for inspection at the Notice Address 'of the Trustee, the Issuer has loaned to the Mortgagor the proceed; t:'cceived from the sale of the Series 1999 Bonds and, if Additional Bonds are issued under the Indenture, the Issuer shall loan to the Mortgagor the proceeds received from any such Additional Bonds. .. C. By the Agreement and as further evidenced by the Series 1999 Notes and any Additional Notes which hereafter may be executed to evidence loans made with proceeds of any Additional Bonds (collectively. the "Notes"), the Mortgagor is required to repay all amounts so loaned by Issuer to the Mortgagor (collectively. the ttLoan") by making Loan Payments. as defined in the Agreement. to the Trustee, at such times and in such amounts as shall be sufficient to pay the toral amounts due with respect to the principal of and premium. if any~ and interest on the Series 1999 Bonds and any Additional Bonds (collectively. the "Bonds") payable at any time for that period or payable at that time (the "Debt Service Charges"). The final principal payment on the Series ]999 Bonds. if not earlier redeemed. is due and payable on November 15, 20_. o D. By the Indenture, the Issuer has. with the consent of the Mortgagor, assigned to the Trustee. as security for the payment of the Debt Service Charges (i) all of its rights and interest qt;-(f{ ...- '~"I,~:.~':1a:.::"=:':':"'':''''':''''-",_",,~~~~__ '} under. in and to the Agreement except for the Unassigned Rights (as thcrein defincd). and (ii) the Revenues (as defined in the Indenture). NOW THEREFORE, as an inducement to and in consideration of the issuance of the Series 1999 Bonds by the Issuer, the loan of the proceeds of the sale of the Series 1999 Bonds by the Issuer to the Mortgagor pursuant to the Agreement, and for other valuable consideration, the receipt of which is hereby acknowledged. for the purpose of securing the Bonds and for the purpose of securing the following, whether now or hereafter owing: (i) All payments to be made by the Mortgagor under the Agreement. the Notes and this Mortgage. including. without limitation, all Loan Payments and Additional Payments, (ii) Any amounts advanced or costs incurred by the Mortgagee for the protection of the hereinaftcr described Mortgaged Property, as hereinafter defined, or in connection with the enforcement of this Mortgage, the Notes, the Indenture or the Agreement, together with interest thereon at the Interest Rate for Advances, (Hi) The perfonnance and observance of each covenant and agreement of the Mortgagor contained in this Mortgage. the Notes and the Agreement. and , ,,:) . (iv) all fees and expenses of the Trustee under the Indenture. the Mortgagor does hereby grant, bargain, sell, convey. mortgage, assign, grant a security interest in and transfer unto the Mortgagee, its successors and assigns, all of its respective right. title and interest in and to the following property, whether now owned or hereafter acquired (the "Mortgaged Propertyll): (a) All that certain piece, par..::el u.' tract (if land in which the Mortgagor has a fee simple interest situate in the County of Pinellas, State of Florida (hereinafter called the "Project Site"), more particularly described in Exhibit A attached hereto and made a part hereof; (b) All lands, buildings, structures and improvements of every nature whatsoever now or hereafter situated on the Project Site, and all fixtures. machinery, equipment, furniture and other personal property of every nature whatsoever now or hereafter owned by the Mortgagor and located in, on. or intended to be used in connection with the opcration of the Projl.>et Site. buildings, structures or other improvements, betterments, renewals and replacements to any of the foregoing; and all of the right, title and interest of the Mortgagor in any such personal propcrty or tixtures subject to a lease, conditional sales contract, chattel mortgage or similar lien or claim together with the benefit of any deposits or payments now or hereafter made by the Mortgagor or on Mortgagor's behalf (the "Project Facilities"); ...;) 2 19 -/~ ,,) ! ',~-,' .oJ (c) All easements. rights of way. strips and gores of land, streets, ways, alleys, passages, sewer rights, rights, titles. interest, privileges, liberties, tenements, hereditaments and appurtenances whatsoever, in any way belonging, relating or appertaining to any of the property hereinabove described. or which hereafter shall in any way belong, relate or be appurtenant thereto. whether now owned or hereafter acquired by Mortgagor and the reversion and reversions remainder and remainders, rents. issues, and profits resulting from or relating to the Mortgaged Property. and all the estate. right, title, interest, property, possession, claim and demand whatsoever. at law as well as in equity. of the Mongagor of, in and to thc same, including, but not limited to. all judgments. .awards of damages and settlements hereafter made resulting from condemnation proceedings or the taking of the Mortgaged Property or any part thereof under the power of emincnt domain, the alteration of the gradc of any street. or for any damage (whether caused by such taking or otherwise) to the Mortgaged Property or any part thereof, or to any rights appurtenant thereto. and all prOt:ecds of llilY sales or Olhcr dispositions of the Mortgaged Property or any part thereof; (d) All rents, royalties, issues, profits, revenue. income and other benefits from the Mortgaged Property to be applied against the indebtedness secured hereby, provided however, that pcrmission is hercby given to Mortgagor so long as no default has occurred hereunder, to collect. receive. take, use and enjoy such rents, royalties, issues, protits, revenue, income, licenses, foreclosures, com:essions and other benefits as they become due and payable, but not in advance thereof. The foregoing assignment shall be fully operative without any further action on the part of eith~r party and, specifically, Mortgagce shall be emitled, at its option upon the occurrence of a default hereunder, to all rents, royalties, issues. profits, revenue, income and other benefits from the Mortgaged Property. whether or not Mortgagee takes possession of the Mortgaged Property. Upon any such notice of default hereunder, the permission hereby givcn to Mortgagor to collect such rents, royalties, issues. profits, revenue, income and other benefits from the Mortgaged Property shall terminate and such permission shall not be reinstated upon a cure of the default without Mortgagee's specific written consent. Exercise of rights under this paragraph and the application of any such rents, royalties, issues, profits. revenue. income or other benefits to such indebtedness, shall not cure or waive any default or notice of default hereunder or invalidate any act done pursuant hereto, but shall be cumulative and in addition to all other rights and remedies of Mortgagee; (e) All right. title and interest of Mortgagor in and to any and all leases now or hereafter on or affecting the Mortgaged Propcrty (exccpting the portion of escrowed paymcnts due pursuant to any residency agrcemcncs which are excluded from the detinition of "Revenue" hereunder), togethcr with all security therefor and all monies payable thereunder, subject, however. to the conditional permission hereinabove given to Mortgagor to collect the rentals undcr any such lease and 3 q9~/fl .-iIt.....~...:..-____~~:..:..:...':~u.:'-_:.... _.. ~, c. . . (~) subject to any nondisturbance agreement executcd by the Mortgagee with respect thereto. The foregoing assigrunent of any Icase shall not be deemed to impose upon Mortgagee any of the obligations or duties of Mortgagor provided in any such lease, and Mortgagor agrees (0 fully perform all obligations of the lessor under all such leases. Upon Mortgagee's request, Mortgagor agrees to send to Mortgagee a list of all leases covered by the foregoing assignment and as any such lease shall expire or terminate or as any new lease shall be made. Mortgagor shall so notify Mortgagee in order that at all times Mortgagee shall have a current list of all leases affecting the Mortgaged Propeny, Mortgagee shall have the right, at any time and from time to time, to notify any lessee of the rights of the Mortgagee as provided by this paragraph. From time to time, upon request of Mortgagee. Mortgagor shall specitically assign to Mortgagee as additional security hereunder, by an assignment in writing in form approved by Mortgagee. all right, title and interest of Mortgagor in and to any and all leases now or hereafter on or affecting the Mortgaged Property, together with all security therefore and all monies payable hercunder. subject to the conditional pennission hereinabove given to Mortgagor to collect the rentals under any such lease. No such separate assignment instrument shall be necessary, however, to grant to Mortgagee rights in such leases as this instrument is intended to be a self-operative present assignment of such leases and all rights thereunder. Mortgagor shall also execute and deliver to Mortgagee any notification, financing statement. or other document reasonably required by Mortgagee to perfect the foregoing assignment as (0 any such lease. (This instrument constitutes an absolute and present assignment of the terms. royalties, issues. profits, revenue, income. and othcr benetits from the Mortgaged Property, subject, however, to the conditional pem1ission given to Mortgagor to collect. receive, take. use and enjoy the same as provided hereinabove; provided, further, that the existence or exercise of such right of Mortgagor shall not operate to subordinate this assignment to any subsequent assignment, in whole or in part, by Mortgagor and any such subsequent assignment by Mortgagor shall be subject to the rights of Mortgagee hereunder); and ~ ~ (t) A security interest in (i) all property, equipment, inventory and fixtures now or hereafter affixed to or located on the Mortgaged Property (except motor vehicles . subject to certificate of title), which, to the fullest extent permitted by law, are or shall be deemed fixtures and a part of the real property, (ii) all articles of per~ona1 property now or hereinafter acquired and all materials situated or hereinafter delivered to the Mortgaged Property for the use and operation of said property or for use in any construction being conducted thereon, and now or hereinafter owned by Mortgagor; (Hi) all contract rights. including construction contracts. architects contracts, service contracts, advertising contracts, payment or performance bonds, licenses and permits, purchase orders. equipment leases. all other contract rights now or hereinafter associated with the Mongaged Property, general intangibles, actions and rights of action, all deposits (to the extent such deposits constitute "Revenuest' as hereinafter defined). prepaid expenses, permits, licenses. including 4 qq-/fl .~\ f all rights to Net Proceeds now or hereinafter acquired or accruing to the Mortgagort (iv) all right. title and interest of the Mortgagor in all tradenames and trademarks now or hereinafter used in connection with the use of the Mortgaged Property, (v) all accounts receivable of the Mortgagor, general intangibles of the Mortgagor and all Revenues now or hereafter accruing to Mortgagor including any cash, securities or other assets of the Mortgagor held by the Trustee, and (vi) all proceeds, products, replacements, additions, substitutions. renewals and accessions of any of the toregoing. Mortgagor hereby grants to the Mortgagee, as a secured party, a security interest in all personal property described herein. This Mortgage is a self-operative security agreement with respect to such property, but Mortgagor agrees to execute and deliver on demand such other security agreements, financing statements and other instruments as Mortgagee may request in order to perfect its security interest or to impose the lien hereof marc specifically upon any of such property. In addition to those specitied herein Mortgagee shall have all the rights and remedies of a secured pany under the Uniform Commercial Code. PROVIDED, HOWEVER, that Mortgaged Property shall not include any amounts on deposit in the Operating Reserve; and '......../ PROVIDED, FURTHER, that these presents are upon the condition that, if the Mortgagor shall payor cause to be paid to the Mortgagee all amounts payable in respect to the Agreement, the Notes. this Mortgage, including. without limitation, aU Loan Payments and Additional Payments and any amounts advanced or costs incurred by the Mortgagee for the protection of the Mortgaged Property, or in connection with the enforcement of this Mortgage, the Notes or the Agreemem on the dares on the day or days when payment shall become due, aU without deduction or credit for taxes or other similar charges paid by the Mortgagor, and shall keep. perfonn and observe all and singular the covenants and promises in the Agreement, and the Notes, and any renewal, extension, consolidation or modification thereof, and in this Mortgage expressed to be kept, perfonned and observed by and on the part of the Mortgagor, all without fraud or delay'and Mortgagee shall have no commitment or obligation to advance funds to or for the benefit of the Mortgagor, then this MortgageJ and all the propenies, interest and rights granted, bargained, sold, remised, released, conveyed. assigned. transferred, mongaged, hypothecated, pledged, delivered, set over, warranted and confinned, shall cease, terminate and be void; but shall otherwise remain in full force and effect. TO HAVE AND TO HOLD the Mortgaged Property unto lhe Mortgagee, its successors and assigns, forever; AND, IT IS HEREBY COVENANTED that this Mortgage is given and the Mortgaged Property is to be held upon the terms herein set forth. I ,....,) 5 1tt~/fi f) ':) v ARTICLE I DEFINITIONS Section 1.1. Use of Defined Terms. In addition to the words and tenns elsewhere defined in this Mortgage or by reference to another documentt the words and tenns set forth in Section 1.2 hereof shall have the meanings therein set forth unless the context or use expressly indicates different meaning or intent. Such dctinitions shall be equally applicable to both the singular, possessive and plural forms of any of the words and tcrms thcrein defined. Section 1.2. Detinitions. As used herein: "Act" means the Florida Constitution, the Charter of the Issuer and Chapter 154, Parts II and III of Chapter 159 and Chapter 166, Florida Statutes, as amended and other applicable provisions of law. "Additional Bonds" means the Additional Bonds as defined in the Indenture. "Additional Notes" means any non-negotiable promissory note or notes, in addition to the Series 1999 Notes, delivered by the Mortgagor to the Issuer and assigned by the Issuer to the Trustee in connection with the issuance of Additional Bonds as provided in the Agreement. "Additional Payments" means the payments required to be paid by the Mortgagor under Section 4.2 of the Agreement. "Agrecmentli means the Loan Agreement dated as of even date with this Mortgage, between the Issuer and the Mortgagor, as amended or supplemented from time to time. "Bond Fundlt means the Bond Fund created by the Indenture. "Bond Resolutiont' means (a) when used with reference to the Series 1999 Bonds, the resolution providing for tl1eir issuance and approving the Agreement, the Indenture and related matters; (b) when used with reference to an issue of Additional Bonds, the resolution providing for the issuance of the Series 1999 Bonds. to the extent applicable. and the resolution providing for the issuance of the Additional Bonds and approving any amendment or supplements to the Agreement and the Indenture and related matters; and (c) when used with reterence to Bonds when Additional Bonds arc outstanding, the resolution providing for the issuance of the Series 1999 Bonds and the resolution providing for the issuance of the then outstanding Additional Bonds; in each case as amended or supplemented from time to time. "Bonds" means the Series 1999 Bonds and any Addilional Bonds. "Commercial Code" means the Unifonn Commercial Code as enacted in the State. as from time to time amended or supplemented. 6 19-/ft -"T-.J'."':,":.~~'~":~~........-........-....__~~-=-_'__._:.._________ ~.. -..) "Debt" means all obligations for borrowed money and installment sale and capitalized lease obligations incurred or assumed by the MOrlgagor and any guaranty by the Mortgagor of indebtedness of any other Person. "Debt Service Reserve Fund't means the Debt Service Reserve Fund created in Section 5.01 of the Indenture. "Engineer" means an individual or firm acceptable to the Mortgagee and qualified to practice the profcssion of engincering or architecture under the laws of the State. "Entrance Fees" shall mean the fees, other than monthly service charges by the residents of the Mortgaged Property to the Company for the purpose of obtaining the right to reside in the Mortgaged Property, including any refundable resident deposits described in Residency Agreements with respect to the Mongaged Property, but shall not include any such amounts that are (i) escrowed pursuant 10 thl! requirements of Chapter 651. Florida Statutes or any similar law unless and until such amounts are released from such escrow to the Company or (ii) escrows otherwise set aside pursuant to the requirements of any Residency Agreement prior to occupancy of the unit covered by such Residency Agreement (which amounts shall be included if and when such occupancy occurs). ItEvent of Default" means any of the events described as an Event of Default in Section 6.2 hereof. -,..~ ~) "Excluded Property" means the property described in Exhibit G of the Agreement "Force Majeure" means any of the causes, circumstances or events described as constituting Force Majeure in Section 6.2 hereof. "Holder" or "Holder of a Bondlt means the person in whose name a bond is registered on the Bond Register. "Indenture.t means the Trust Indenture dated as of even d~te with this Mortgage between the Issuer and the Trustee, as amended or supplemented from time to time. flIndependent Counsel" means an attorney or linn of attorneys acceptable to the Mortgagor and duly admitted to practice law before the highest court of the State. "Insurance Requirements" means those insurance requirements described in Section 4.1 hereof. "Interest Rale for Advances" means the lesser of (i) the Prime Rate or (ii) the maximum interest rate permitted by applicable law. ...)' 7 Cf!;,/fI ") r., .. :,,,..") I.....!'" -...J IIlssuer" means City of Clearwater. Florida, a public body corporate and politic duly crcated and validly existing under the laws of the State of Florida including, particularly, the Act, and its successor and assigns. "Legal Requirements" means those legal requirements described in Section 4.1 hereof. "Loan" means the loan by the Issuer to the Mortgagor of the proceeds received from the sale of Bonds. IlLoan Payments" means the amounts required to be paid by the Mongagor in repayment of the Loan pursuant to Section 4. 1 of the Agreement. IIMortgage" means this Mortgage and Security Agreement, as amended or supplemented from time to time. IINet Proceeds, II when used with respect to any insurance proceeds or condemnation award, means the gross proceeds thereof less the payment of all expenses, including attorneys' fees incurred in connection with the collection of such gross proceeds. tlNotes" means the Series 1999 Notes and any Additional Notes. "Notice Address" means as to the Mortgagor: BEF, Inc., 1601 Jack Street, Suite 200, Fort Myers, Florida 33901 Attention: Gerard A. McHale, Jr., as to the Issuer: City of Clearwater. Florida, c/o Margaret L. Simmons, CPA, Financial Services Administrator. 100 South Myrtle Avenue, Clearwater, Florida 33756-55209. copy to Pamela Akins. City Attorney, 112 South Osceola Avenue. Clearwater, Florida; and as to the Trustee. SunTrust Bank. Central Florida. National Association, 225 East Robinson Street, Suite 250, Orlando, Florida. 32801, Attention: Corporate Trust Department. ttOutstanding Bonds" means the Outstanding Bonds as defined in the (ndenture. "Permitted Encumbrances" means the exceptions, restrictions, easements and encumbrances set forth in Exhibit B hereto. IIPrime Rate" means that interest rate announced from time to time by the Trustee in its lending capacity as a bank as its "prime rate" or "base rate. " "Project Fund" means the Project Fund created by the Indenture. "Rebate FundI' mcans the Rebate Fund crcaled by the Indenture. "Required Propeny Insuram.:c Coverage" means (a) insurance insuring the Project Facilities against loss or damage by fire. lightning, windstorm, vandalism and malicious mischief and all other perils covered by standard "extended coverage" or "all risks.' policies in the State, business 8 11--1([ " interruption and against such other perits as the Mortgagee may require, in an amount equal to 100% of the rcplacement cost of the Project Facilities. presently estimated to be $ without deduction for depreciation, and containing a "rcplacement cost endorsement" (b) any sinkhole insurancc requircd by Section 3.3 hcreof and (c) any tlood insurance required by Section 3.3 hereof, all subject only to co-insurance and or deductibles as are customary in the industry. .......... l "Required Public Liability Insurance Coverage" means comprehensive general accident and public liability insurance in the minimum amounts of [$1.000.000J for death or bodily injury resulting from each occurrence in connection with the Project site or Project Facilities and other property and operations of the Mortgagor and [$3,OOQ,OOOJ for property damage for any such occurrence, with a loss deductible not to exceed [$1,000.] "Revenues" means all present and future revenues received by or on behal f of the Mortgagor from whatever sourcc derived. including withoullimitation. all . (a) cash, accounts, deposits, Entrance Fees. chattel paper, instruments, documents, money and general intangibles, including without limitation, contract rights and rights to payment (i) for goods and properties sold or leased or for services rendered, (ii) under agreements respecting governmental and private insurance arrangements. and (iii) from any insurance, condemnation award or agreement in lieu of a condemnation award resulting from eminent domain proceedings. ,"~-') .........;0..,,'" (b) income from. and revenues realized upon the liquidation or sale of, securities held by or on behalf of the Mortgagor, (c) proceeds of those items constituting Revenues to which reference is made in clauses (a) and (b) above, and (d) gifts, grants, bequests, contributions and donations. including without limitation, the unrestricted income and profits therefrom, provided that Revenues do not include (i) gifts, grants, bequests, contributions and donations to the extent restricted specifically to a particular purpose inconsistent with their use for the making of payments into any of the Special Funds, (ii) the procceds of any borrowing [0 the extent that those proceeds arc required to be excluded from Revenues by the terms of the borrowing. (iii) the proceeds of non-recourse Debt secured by and payable solely from property financed by such non-recourse Debt and all revenues derived from ---J 9 tfj--I}f :') '., , ; '-.." or attributable to property financed with the proceeds of such non.recourse Debt. (iv) revenues derived from Excluded Property, or ItSeries 1999A Bonds" means the $ Bonds, Series 1999A (BEF. Inc. Project). City of Clearwater, Florida Revenue uSeries 1999B Bonds" means the $ City of Clearwater. Florida Rcvenue Bonds, Series 1999B (BEF, Inc. Project), Extendable Rate Adjustable SecuritiessM (EXTRASSM). "Series 1999C Bonds" means the $ Revenue Bonds, Series 1999C (BEF, Inc. Project). City of Clearwater, Florida Taxable If Serics 1999 Bonds" means. collectively, the Series 1999A Bonds. the Series 1999B Bonds and the Series 1999C Bonds. uSeries 1999 Note" means the non-negotiable promissory note of the Mortgagor in the aggregate principal amount of $ , of even date with the Series 1999A Bonds, the Series 1999B Bonds and the Series 1999C Bonds, a copy of which note is attached hereto as Exhibit ltC," executed and delivered by the Mortgagor to the Issuer and assigned by the Issuer to the Trustee in connection with the issuance of the Series Bonds. "Special Funds" means the Special Funds created pursuant to Section 5.01 of the Indenwre, other than the Rebate Fund. ItStatelt means the State of Florida. "Unassigned Rights" means the rights of the Issuer under the Agreement to (a) receive Additional Payments as contemplated in Section 4.2 of the Agreement; (b) to be held harmless and indemnified under Section 5.12 of the Agreement; (c) to exercise with the consent, but not to the exclusion. of the Trustee any remedies which are authorized to be excrcised by the Issuer under the Agreement in connection with an Event of Default; (d) to be reimbursed, to the extent permitted by law. for attorney's fecs and expenses under Section 7.4 of the Agreement; and (e) to execute amendments to the Agreement. Section 1.3. lntelpretation. Any reference to a section or provision of the Constitution of the State, or to a section. provision or chapter of the Florida Statutes or Laws of Florida, includes that section, provision or chaplcr as amended, modified, revised, supplemcnt~d or superseded from time to time; provided. that no amendment. modification, revision, supplement, or superseding section, provision or chapter shall be applicable solely by reason.of this provision. if it cons[itutes in any way an impairment of the rights or obligations of the Issuer, [he Holders. the Mortgagee, the Trustee or the Mortgagor under thc Indenture, the Bond Resolution. the ~ Bonds, the Agreement, the Notcs, this Mortgage or any other instrument or document entered into 10 99;/f{ .' , i., ,'I ." f , ,(:-:. . '::)~:.I>!J \: , " .. j. .~ '" ;': . , f: . : . ~ ,.- f ~ . , ' ":"; L. ~ ""0 '." . I . 'j, :' , . ..i:) - ..' '. :. ,;",'.~. ':..' ,'.. in connection with any of the foregoing, including without limitation. any alteration of the obligation to pay Debt Service Charges, Loan Payments and Additional Payments in the amount . and manner, at the times,' and from the sources provided in the Bond Resolution and the Indenture, except as permitted in the Indenture and the Agreement. . . The tenns "hereof," "hereby," Ithereint It "hereto," tthercunder" and similar terms refer to this Mortgage; and the term tthereafter" means after, and the term "heretofore" means before, the date of delivery of this Mortgage. Words of the masculine gender include the feminine and neUler, and when the sense so indicates words of the n~uter gender may refer to any gender. . (End 'of Article I) . ,', , I . ,/ J' . . I1 f'9;- 1</ en..... 1 ARTICLE II PRESERV A TION OF SECURITY Section 2.1. Representations and Warranties. Mortgagor represents and warrants that (i) it is lawfully seized with good and marketable fee simplc title to the Project Site and has, or will acquirc upon the acquisition or construction thereof, good title to the other Mortgaged Property subject only to Pennitted Encumbrances. (ii) it has full right and authority to sell and convey the Mortgaged Property and (ijj) it will warrant and defend to the Mortgagee such title to the Mortgaged Property and the lien and interest of the Mortgagee therein and thereon against all claims and demands whatsoever and will. except as otherwise herein expressly provided. maintain the priority of the lien of, and the security interest granted by, this Mortgage upon the Mortgaged Propcrly until it shall be entitled to defeasance as provided herein. :' "".')' ":',,1 Section 2.2. Recordation. The Mongagor, at its expense, shall cause this Mortgage. any instruments supplemental hereto, financing statements, including all neccssary amendments, supplements and appropriate continuation statements to be timely recorded. registered and filed, and to be kept recorded, registered and' filed, in such manner and in such places as may be required in order to establish, preserve and protect the lien of this Mortgage as a valid, first mortgage lien on the Project Site and that portion of the Project Facilities which constitute real property and interests therein included in the Mortgaged Property and a valid, perfected first priority security interest in all personal property, fixtures and interests therein included in the Mortgaged Property (including in each such case. without limitation, any such properties acquired after the execution hereot). If requested by the Mortgagee but in each case not more than once in each calendar year, the Mortgagor, at its expense, will furnish to the Mortgagee an opinion of Independent Counsel, specifying the action required to be taken by the Mortgagor to comply with this Section 2.2 since the date of this Mortgage or the date of the most recent sllch opinion or stating that no such action is lIecessary. i' I i' I I Section 2.3. After-Acquired Property. All property of every kind acquired by the Mortgagor after the date hereof, which by the terms hereof is to be subject to the lien of this Mortgage, shall immediately upon the acquisition or construction thereof by the Mortgagor, and without further mongage, conveyance or assignment, become subject to the lien of this Mortgage as fully as though now owned by the Mortgagor and specifically described herein. Nevertheless. the Mortgagor shall take such actions and execute and deliver such additional instruments and opinions of counscl as the Mortgagee shall reasonably require to further evidence or confirm the subjection to the lien of this Mongage of any such property. Section 2.4. Liens and Encumbrances. Except as otherwise expressly permitted by this Mortgage or the Agreement. the Mortgagor shall not, without the prior written consent of the Trustee. directly or indireclly create or permit to remain. and will promptly discharge. any mortgage, lien, encumbrance or charge on. pledge of, security interest in or conditional sale or other title retention agreement with respect to the Mortgaged Property or any part thereof or the :~ interest of the Mortgagor or the Mortgagee therein or any revenues, income or profit or other 12 l1~/rt ....,.~.. ~-'~"'''''_~_''Ii.''''''''.''''-''''--''''''--__---':_ .. __ ____~____._,_____ / ....., . sums arising from the Mongaged Property or any part thereof (including. without limitation. any lien. encumbrance or charge arising by operation of law) other than: (a) the lien of lhis Mortgage; (b) liens for taxes, assessments and other governmental charges which are not at the time required to be paid pursuant to Section 3.1 hereof; (c) liens of mechanics. matcrialment suppliers or vendors or rights thercto to thc extent permitted by Section 3.2 hereof; and (d) Permitted Encumbrances. Section 2.5. Security Agreement and Financing Statement. This Mortgage constitutes a security agreement as to all or any part of the Mortgaged Property which is of a naturc that a security interest therein can be perfected under the Uniform Commercial Code of the State. This Mortgage also constitutes a financing statement with respect to any and all property included in the Mortgaged Property which is or may become fixtures. '-. ,.' "1 \....".4r~ Section 2.6. No Claims A2ainst Mort2a2ee. Nothing contained in this Mortgage shall constitute a request by the Mortgagee, expressed or implied, for the performance of any labor or services or the furnishing of any materials or other property in respect of the Mortgaged Property or any part thereof, or be construed to give the Mortgagor any right, power or authority to contract for or permit the performance of any labor or services or the furnishing of any materials or other property in such fashion as would provide the basis for any claim either against the Mortgagee or that any lien. induding, without limitation, liens described in Chapter 713, Florida Statutes, as amended. based on the performance of such labor or services or thc furnishing of any such materials or other property is prior to the lien of this Mortgage. ~ Section 2.7. Security for Future Advances. The Agreement and the Indenture permit the Mortgagee to advance additional sums under certain conditions set forth in the Agreement and the Indenture. This Mortgage is given to secure not only the existing indebtedness of $ of the Mortgagor to the Mortgagee evidenced by the Series 1999 Notes and Agreement secured hereby t but also such future advances up to an additional $ as are made within twenty (20) years from date hereoft plus interest thereon, and any disbursements made by the Mortgagee for the payment of laxes, insurance or other liens on the property encumbered by this Mortgage, with interest on such disbursements, which advances shall be secured hereby to the same extent as if such future advances were made this date. The total amount of indebtedness secured hereby may incrcase or decrcase from time to time. The provisions of this paragraph shall not be construed to imply any obligation on Mortgagee to make any furure advances, it being the intention of the partics that any future advances shall be solely at thc discretion and option of the Mortgagee. Any reference to "Series 1999 Notes" or 1JAgrecment" in this Mortgage shall be construed to refcrence any future advances made pursuant to this paragraph. 13 I 1f~/<t ! ' I :r) '''') " ..."'.....,., 'J . ........ ~.....~ .....,1- " ~ ,.r rU. ..' ..' . , Section 2.8. Hazardous Waste. (a) (b) Mortgagor warrants and represents to Mortgagee after thorough investigation that: (i) the Mortgaged Property described herein is now and at all times hereafter will continue to be in full compliance with all federal, state and local environmental laws and regulations, including but not limited to, the Comprehensive Environmental Response, Compensation and Liability Act of 1980 C.CERCLAOI), Public Law No. 96w510, 94 Stat. 2767, 42 USC 9601 et scq.. and the Superfund Amendments and Reauthorization Act of 1986 (SARA), Public Law No. 99-499. 100 Stat. 1613, and (ii) (aa) as of the date hereof there are no hazardous materials, substances, wastes or other environmentally regulated substances (including without limitation, any materials containing asbestos) located on, in or under the Mortgaged Property or used in connection therewith, or (bb) Mortgagor has fully disclosed to Mortgagee in writing thc existence, extent and nature of any such hazardous matl~rials. substances, wastes or othcr environmentally regulated substances. which Mortgagor is legally authorized and empowered to maintain on, in or under the Mortgaged Property or use in connection therewith, and Mortgagor has obtained and will maintain all licenses, permits and approvals required with respect thereto, and is in full compliance with all of the terms, conditions and requirements of such licenses, permits and approvals. Mortgagor further warrants and represents that it will promptly notify Mortgagee of any changes in the nature or extent of any hazardous materials, substances or wastes maintained on, in or under the Mortgaged Property or used in connection therewith. and will transmit to Mortgagee copies of any citation, orders, notices or other material governmental or other communication received with respect to any other hazardous materials, substances, wastes or other environmentally regulated substances affecting the Mortgaged Property. Mortgagor hereby agrees to indemnify Mortgagee and its successors and assigns and hold Mortgagee harmless from and against any and all liabilities, obligations. charges, losses, damages, injuries, penalties. claims actions, suits, costs of any settlement or judgment, costs, expenses and disbursements, including without limitation title insurance costs and premiums, engineers' and professional fees, soil tests and chemical analysis, court costs, including reasonable legal tees and expenses through all trial. appellate and administrative levels of whatsoever kind and nature imposed on, incurred by or'asserted against Mortgagee by any person or entity or governmental agency for, with respect to, or as a direct or indirect result of, the presence on or under, or the escape, seepage, leakage. spillage, discharge, emission, discharging or release from the premises of any Hazardous Substance (including, without limitation, any losses, liabilities, including strict liability, damages, injuries, expenses, including reasonable attorneys' fees, costs of any settlement or judgment or claims asserted or arising under CERCLA, any so called federal, state or local "Superfund" "Superlicn" laws, statutes, law. ordinance, code. rule, regulation. order or decree regulating with respect to or 14 19--('6 '-, . "~..... \ :...J (e) , ; (t) ~ imposing liability, including strict liability substances or standards of conduct concerning any Hazardous Substance), regardless of whether within the control of . Mortgagee. The foregoing indemnification shall survive repayment of the Note and satisfaction or assignment of this Mortgage. (c) For purposes of this Mortgage. "Hazardous Substances" shaH mean and include those elements or compounds which arc contained in the list of hazardous substances adopted by the United States Environmental Protection Agency (EPA) and the list of toxic pollutants designated by Congress or the EPA or detined by any other Federal, State or local statute, law. ordinance, code, rule. regulation. order or decree regulating, relating to. or imposing liability or standards of conduct concerning, any hazardous, toxic or dangerous waste, substance or material as now or at any time hereunder in effect and shall include asbestos-containing materials. (d) If Mortgagor receives any notice of (i) the happening of any material event involving the spill, release, leak, seepage, discharge or cleanup of any Hazardous Substance on the Mortg~ed Property or in connection with Mortgagor's operations thereon or (ii) any complaint, order, citation or material notice with regard to air emissions, water discharges, or any other environmental, health or safety matter affecting Mortgagor (an "Environmental Complaint") from any person or entity (including without limitation the EP A) then Mortgagor shall immediately notify Mortgagee' orally and in writing of said notice. Mortgagee shall have the right. but not the obligation, and without limitation of Mortgagee's rights under this Mortgage, to enter onto the Mortgaged Property or to take such other actions as it deem necessary or advisable to cleanup, remove, resolve or minimize the impact of, or otherwise deal with, any such Hazardous Substance or Environmental Complaint following receipt of any notice from any person or entity (including without limitation the EP A) asserting the existence of any Hazardous Substance or an Environmcntal Complainl pertaining to the Mortgaged Property or any' part thereof which, if true, could result in an order, suit or other action against Mortgagor and/or which, in the sole opinion of Mortgagee, could jeopardize its security ,under this Mortgage. All reasonable costs and expenses incurred by Mortgagee in the exercise of any such rights shall be secured by this Mortgage and shall be payable by Mortgagor upon demand. Mortgagee shall have thc right. in its sole discretion, to require Mortgagor to periodically (but not more frequently than annually unless an Environmental Complaint is then outstanding) pertbml (at Mortgagor)s expense) an environmental audit and, if deemed necessary by Mortgagee. an environmental risk assessment, each of which must be satisfactory to Mortgagee. of the Mortgaged Property, hazardous waste management practices and/or hazardous waste disposal sites used by Mortgagor. Said audit and/or risk assessment must be by an environmental 15 19,-/C( ,', ".Po"". "'\. ,,, "'" . ~~. ",) ........t.... '-, > i." I; 1'.: ". " , ,., . .' ~ I : , ' . . . ~ ~ . , ~ ,,' .- , l~ < . .,' , '. ... . l " I.' 1 '. '- -:.~ :;'I~J ", " " o :,4 , . , l' . .1 ,,: "'~ , consultant satisfactory to Mortgagee. Should Mortgagor fail to perform said environmental audit or risk assessment within 30 days of the Mortgagee's written request, Mortgagee shall have the right but not the obligation to retain an environmental consultant to perform said environmental audit or risk assessment. All costs and expenses incurred by Mortgagee in the exercise of such rights shull be secured by this Mortgage and shall be payable by Mortgagor upon demand or . charged to the Mortgagor's loan balance at the discretion of Mortgagee. (g) .' Any breach of any warranty, representation or agreement contained in this Section 2.8 shall be an Event of Default hereunder and shall entitle Mortgagee to exercise any and all remedies provided in this Mortgage, or otherwise permitted by law. Section 2.9. Inspection. The Mortgagee shall have the right, at all reasonable times, to enter upon and inspect the Mortgaged Property and to review the books' and records of the Mortgagor relating to the Mortgaged Property. (End of Article II) 16 91~ fer, ~~~Lt,:";,"'~-:;~~:':':'::"':"'~:::_"'..:.l,"'~.),,."'J~""'<'H...1....~.....,.' ... ,- .", ,...~;.t'1 ~.."-: , ~':". tL""~U ......u......I....'... ,.. l.. .. .. ~ ~ ~ .".. ,., ,'_ - . '} -: ~) --J ARTICLE III TAXES. MECHANICS' LIENS AND INSURANCE Section 3. I. P~ment of Taxes and Other Governmental Charges. The Mortgagor shall pay, promptly when due and before penalty or interest accrue thereon, all taxes, assessments, whether general or special, and other governmental charges of any kind whatsoever, foreseen or unforeseen. ordinary or extraordinary, that now or may at any time herearter be assessed or levied against or with respect to the Mortgaged Property or any part thereof (including, without limitation, any taxes levied upon or with respect to the revenues, income or profits of the Mortgagor from the Mortgaged Property) which, if not paid, may become or be made a lien on the Mortgaged Property, or any part thereof, or a charge on such revenues, income or profits. Notwithstanding the preceding paragraph. the Mortgagor may. at its expense and after prior notice [0 the Mortgagee, by appropriate proc~edings diligently prosecUled, ,contest in good faith the validity or amount of any such taxes, assessments or other charges and during the period of contest, need not pay the items so contested; provided, Mortgagor shall deliver to Mortgagee an opinion of Independent Counsel to the effect that by nonpayment of any such items, the lien or security interest created by this Mortgage as to any part of the Mortgaged Property will not be materially affected and the Mortgaged Property or any part tllereof will not be subject to imminent loss or forfeiture. During the period when the taxes, assessments or other charges so contested remain unpaid, tIle Mortgagor shall set aside on its books adequate reserves with respect thereto. Section 3.2. Mechanics' and Other Liens. The Mortgagor shall not permit any mechanics. or other liens to be filed or to exist against the Mortgaged Property by reason of work, labor, services or materials supplied or claimed to have been supplied to, for or in connection with the Mortgaged Property or to the Mortgagor or anyone holding the Mortgaged Property or any part thereof, through or under the Mortgagor. If any such lien shall at any time be tiled, the Mortgagor shall, within thirty days after notice of the filing thereof but subject to the right to contest as set fonh herein, cause the same to be discharged of record by payment, deposit, bond. order of a court of competent jurisdiction or otherwise. Notwithstanding the foregoing, the Mortgagor shall have the right, at iLl) own expense and after prior written notice to the Mortgagee, by appropriate proceedings duly instituted and diligently prosecuted, to contest in good faith the validity or the amount of any such lien; provided, Mortgagor shall deliver to Mortgagee an opinion of Independent Counsel to the effect that by nonpayment of any such items, the lien or security interests created by this Mortgage will not be materially affected and the Mortgaged Property or any part thereof will not be subject to imminent loss or forfeiture and, if requested by the Mortgagee, shall post adequate bond or other acceptable collateral to secure payment of all such amounts. including penalties and interest. Section 3.3. Insurance. The Mortgagor shall keep the Project Facililies continuously insured with Required Property Insurance Coverage. For purposes of establishing the amount of the Required Property Insurance Coverage. "replacement COSllI of the Project Facilities shall be 17 91- Ie;( "'"'') determined not less frcqucntly than at three year intcrvals by an Engineer or a competent appraiser. appraisal company or one of the insurers, in each instance, acceptable to the Trustee. During any period during which any building, structurc or improvcment is under construction, in lieu of the insurance provided for above, the Mortgagor shall maintain or cause to be maintained, with respect to such building. structure or improvement. builders' risk insurance (non-reporting fonn) with coverages and in an amount, detcrmined to be appropriate by an insurance consultant acceptable to the Trustee. If the Project Site is located in an area which is prone to the development of sinkholes, and if sinkhole insurance on the Project Site is available at reasonable cost. the Trustee shall require the Mongagor to maintain or cause to be maintained sinkhole insurance on the Project Site in an amount detennined to be appropriate by an insurance consultant acccptable to the Trustee. If the Project Site is located in an area that has been idenlilied by the United Statcs Department of Housing and Urban Development as an area having special flood hazards and if the sale of flood insurance has been made available under the National Flood Insurance Act of 1968, the Trustee shall require the Mortgagor to maintain or cause to be maintained flood insurance in an amount at least equal to the lesser of (i) the replacement cost of the Project Facilities or (ii) the maximum limit of coverage made available with respect to the particular type of property under the National Flood Insurance Act of 1968. or (iii) some lesser amount dctcnnined by an insurance consultant acceptable to the Trustee. "- ) " The Mongagor shall keep and mainlain Required Public Liability Insurance Coverage with reference to the Project Site and the Project Facilities provided that the Required Public Liability Insurance Coverage shall be increased to such larger amounts as shall be dctcnnincd by an insurance consultant acceptable to the Trustee to be appropriate in light of inflationary increases, the operations conducted by the Mortgagor and the insurance coverage carried by other entities conducting similar operations. All insurance shall be obtained and maintained either by mcans of policies with generally recognized. responsible insurance companies or in conjunction with other companies through an insurance trust or other arrangements satisfactory to an insurance consultant acceptable to the Trustee, and all such companies are to be qualified to do business in the State. The insurance to be provided may be by blanket policies. Each policy of insurance shall be written so as not to be subject to cancellation or substantial modification upon less than thirty (30) days' advance written notice to the Trustee or such shortcr period of notice as shall be satisfactory to the Trustee. The Mortgagor shaH deposit with the Trustee cenificates or other evidence, satisfactory to the Trustee. that (i) the insurance requircd hereby has been obtained and is in full force and effect and (ii) all ' premiums thereon have becn paid in full. Prior to the expiration of any such insurance, the Mongagor shall fumish the Trustce with evidence satisfactory to the Trustee that such insurance has been renewed or replaced and that all premiums thcreon have been paid in full and all insUrance policies required hereby are in full forcc and effect. The Morlgagor shall file with the (.) 18 91-/1 i '. .Q . "'J.~.. ". I. . ;.. .~ ,:',- '0 " I Trustee a copy of any claim in excess of [$100.000] it may make under the Required Property Insurance Coverage. AII' policies providing the Required Property Insurance Coverage shall contain standard mo'rtgagee clauses requiring all proceeds resulting from any claim for loss or damage in excess of [$100,000] to be paid to the Trustee. Any Net Proceeds of insurance providing such coverage shall be paid and applied as provided in Section 5.2 hereof. Any proceeds of policies providing Required Public Liability Insurance Coverage shall be applied toward the extinguishment or satisfaction of the liability with respect to which such insurance proceeds have been paid. Section 3.4. Workers' Compensation Coverage. The Mongagor shall maintain or cause to be maintained in connection with the Mortgaged Property workers' compensation coverage required by the applicable laws of the State. Section 3.5. Title Insurance, The Mongagor shall provide the' Mortgagee Wilh a standard Mortgagee's Title Insurance Policy in the amount of $ containing only such exceptions as constitute Permitted Encumbrances. (End of Article Ill) 19 99-- 10t . , '~_~~~~~~.........":'~:"....":-'''''''' .....;;....,~'..1.-'! ,,,,,,... .,,' .\ ,~,,"". , ~"... '. . -.-.---.--- -I .~) f........~. , , I , I ....--.,..., ~ ARTICLE IV MAINTENANCE AND USE OF MORTGAGED PROPERTY Section 4.1. Compliance with Legal and Insurance ReQuircments. The Mortgagor, at its expense, shall promptly comply with all Legal RequirementS and Insurance Requirements, and shall procure, maintain and comply with all permits, licenses and other authorizations required for any use of the Project Site or Project Facilities or any part thereof then being made or anticipated to be made. and for the proper construction. installation. operation and maintenance of the Mortgaged Property or any part thereof. and will comply with any instruments of record at the time in force burdcning the Morlgagcd Property or any part thereof. As used in lhis Section, "Legal Requirements" means all laws. statutes. codes. acts, ordinances, resolutions, orders, judgments, decrees. injunctions, rules, regulations. permits, licenses. authorizations. directions and requirements of aU govcrnmental entities. departments. commissions, boards. courts, authorities, agencies, officials and officers, foreseen or unforeseen, ordinary or ~xtraordinary, which now or at any time hereafter may be applicable to the Project Site or Project Facilities or any part thereof, any use, anticipated use or condition of the Project Site or Project Facilities or any part thereof. including, without limitation. Chapter 713. Florida Statutes. "Insurance Requirements" means all provisions of any insurance policy covering or applicable to the Project Site or Project Facilities or any part thereof, all requirements of the issuer of any such policy, and all orders. rules. regulations and other requirements of the National Board of Fire Underwriters (or any other body exercising similar functions) applicable to or affecting the Mortgaged Property or any pan thereof. The Mortgagor may. at its expense and afu:r prior notice to the Mortgagee, by any appropriate proceedings diligently prosecuted. contest in good faith any Legal Requirement and postpone compliance therewith pending the resolution or settlement of such contest provided that such postponement does not, in the opinion of Independent Counsel, materially affect the lien or security interests created by this Mortgage as to any part of the Mortgaged Property or subject the Mortgaged Property, or any part thereof, to imminent loss or forfeiture. Section 4.2. Maintenance and Use of Mortl:aeed Pro~. The Mortgagor, at its expense, will keep or cause to be kept the Project Site and Project Facilities in good order and condition (ordinary wear and tear excepted) and wilt make all necessary or appropriate repairs, rcplacements and rencwals thereof. interior, exterior. structural and non-structural, ordinary and extraordinary, foreseen and unforeseen. The Mortgagor will not do. or permit to be done, any act or thing which might materially impair the value or usefulness of the Project Site or Project Facilities or any part thcreof. will not commit or permit any materiaJ waste of the Project Site or Project Facilities or any part thereof. and will not permh any unlawful occupation. busincss or trade to be conducted on the Project Site or Project Facilities or any p3rl thereof. The Mortgagor shall also, at its expense. promptly comply with all rights of way or use. privileges. franchises, servitudes, licenses, easements, tenements. hcrediwments and appurtenances forming a part of the Project Site and all instruments creating or evidencing the same, in each case. to the eXlellt compliance therewith is required of the Mortgagor under the terms thereof. 20 crt; -/<6 .~ Section 4.3. Additions. Modifications and Improvements. The Mortgagor may, in its discretion and at its expense. make from time to time any additions, modifications or improvements to the Project Site or Project Facilities which it may deem dcsirable for its business purposes provided thal the Trustee shaH tirst have rCl.:cived a report from an Engincer staling that such additions, modifications or improvements will not, in the opinion of such Engineer. adversely affect the structural integrity or strength of any improvements constituting a part of the Project Site or Project Facilities or materially interfere with the use and operation, value or marketability thereof. All additions. modifications and improvements so made by the Mortgagor shall become or be deemed to constitute a part of the Mortgaged Property, except as may be provided herein. Section 4.4. Substitutions and Removals. In any instancc where the Mortgagor. in its reasonable discretion, determines that any'fixture or item of personal property constituting a part of the Projcct Facilities shaH have become inadequate. obsolete. worn-out. unsuitable. undesirable or unnecessary or should be replaced, the Mortgagor may remove slIch items provided that such removal (taking into account any substitutions) shall not impair the operating unity of the Project Site or Project Facilities and providing that the Mortgagor shall: (a) substitute and install as part of the Project Facilities property of equal or greater utility and value (but not necessarily fulfilling the same function) as the removed property, which such substituted property shall be free from 'all liens and cncumbrances (other than Penniued Encumbrances) and shall become part of the Project Site or Project Facilities; or '.,~) (b) in the case of removal of any Project Facilities from the Project Site without substitution. 'promptly pay to the Trustee for application as provided in Section 4.6 of the Agreement an amount equal to (i) if the removed property is sold or scrapped, the proceeds of such sale or the scrap value thereof, (ii) if the removed property is used as a trade-in for property not to be used at the Project Site as part of the Project Facilities, the trade-in credit received by the Mortgagor or (iii) in the case of the retention of such removed property by the Mortgagor for other purposes, the fair market value of such property, as determined by an Engineer or appraiser acceptable to the Trustee. If, prior to any such removal, the Mortgagor shall have acquired with its own funds personal property which is located on the Project Site and which has become or shall, by an amendment hereto, be made a part of the Project Facilities. the Mortgagor may take credit to the extent of the mnount so spent by them against the requirement that they either substitute other property or make payment under this Section on account of such removal, provided that such previously acquired and installed property meets the requirements for substituted property under Section 4.4(a) hereof. o The Mortgagor shall promptly report to the Mortgagee each such removal, substitution, sale or other disposition and shall pay to the Trustee such amounts as are required by the 21 19 -/C6 __"l"~~~~~~_---..-.....__-...........-.-_~._ _____ ,. /) . -" J '.~. " ~.J ---- ---~-~------ ------- ~- ---- ----- - ----------- provisions of the pn..-ceding subsection (b) of this Section promptly after thc sale, trade-in or other disposition requiring such payment; provided, however. that no such payment need be made until the amount to be paid to the Trustee on account of all such sales. trade-ins or other dispositions not previously paid aggregates to at least l$100,OOOJ in the calendar year. At the request of the Trustee, the Mortgagor shall deliver to the Mortgagce such instruments, including financing statements and amendments thereto, as may be necessary or advisable to perfect the Mortgagee's lien upon and security interest in any personal property installed in substitution for any property removL."d pursuant to this SI.'Ction; the Trustee may require the Mortgagor to provide, at the expense of the Mortgagor, an opinion of counsel as to the perfection of the Mortgagl.."e's lien and security interest. Upon the rcqucst of the Mortgagor. the Trustee shaH execute and deliver to the Mortgagor appropriale instruments releasing any property removed pursuant to this Section from the liens and security intcrests hereunder. Section 4.5. Ind~mnitication. The Mongagor shall protect, indemnify and save harmless the Mortgagee from and against all liabilities, obligations, claims, damages, penalties, causes of , action, costs and expenses (including, without limitation. reasonable attorneys' fees and expenses except as may be limited by law or judicial order or decision entered in any action brought to recover moneys under this Section) imposed upon, incurred by or asserted against the Mortgagee by reason of (a) ownership of any interest in the Mortgaged Propeny or any part thereof, (b) any accident. injury to or death of persons or loss of or damage to property occurring on or about the Project Site or any part thereof or the adjoining sidewalks, curbs. vaults and vault space, if any, streets or ways, (c) any use. disuse or condition of the Project Sitc or Project Facilities or any part thereof. or the adjoining sidewalks. curbs. vaults and vault space, if any, streets or ways, Cd) any failure on the part of the Mortgagor to perfonn or comply with any of the terms hereof. (e) any necessity to defend any of the rights, title or interests conveyed by this Mortgage, (t) the performance of any labor or services or the furnishing of any materials or other property in respect of the Project Site or Project Facilities or any part thereof or (g) any lease or contract relating to the Project Site. the Project Facilities, or any part thereof. In case any action, suit or proceeding is brought against the Mortgagee for any such reason, the Mortgagor, upon the request of the Mortgagee, will at the Mortgagor's expense. cause such action, suit or proceeding to be resisted and defended by Independent Counsel. Any amounts payable to the Mortgagee under this Section which are not paid within ten (10) days after written demand therefor shaH bear interest at the Interest Rate for Advances from the date of such demand, and such amounts, together with such interest, shall be considered a future advance hereunder and indebtedness secured by this Mortgage. The obligations of the Mortgagor under this Section shall survive any defeasance of the Bonds, any discharge of the Indenture. any termination of the Agreement or any satisfaction of this Mortgage. (End of Article IV) 22 19-18> J ARTICLE V DAMAGE. DESTRUCTION AND CONDEMNATION Section 5.1. Dama~e to or Destruction of Project Facilities. In case of any damage to or destruction of the Project Site or Project Facilities or any part thereof, the Mortgagor will promptly give or cause to be given written notice thereof to the Mortgagee generally describing the nature and extent of such damage or destruction. Unless in lieu thereof all Outstanding Bonds are to be redeemed pursuant to the Agreement, the Mortgagor shall. whether or not the Net Proceeds of insurance. if any, received on account of such damage or destruction shall be sufficient for such purpose, promptly commence and complete. or cause to be commenced and completed. the repair or restoration of the Project Site or Project Facilities as nearly as practicable to the value. condition and character thereof existing immediately prior (0 such damage or destruction, with such changes or alterations, however, as the Mortgagor may deem necessary for the proper conduct of its business 'activities conducted on the Project Site. --'\ --j Section 5.2. Jjse oflnsurance Proceed~. In connection with the repair or restoration of the Project Site or Project Facilities pursuant to Section 5.1 hereof. Net Proceeds of Required Property Insurance Coverage not in excess of [$100,000] shalJ b;.; paid to the Mortgagor for application of as much as may be necessary for such repair and restoration. Any such Net Proceeds in excess of [$100,000] shall be paid to and held by the Trustee in a separate insurance loss account within the Project Fund, for application of as much as may be necessary of the Net Proceeds to the payment of the costs of repair or restoration. either on completion thereof or as the work progresses, as directed by the Mortgagor. The Mortgagee may, prior to making payment from such Joss account, require the Mortgagor to provide evidence that, or deposit with the Trustee moneys to be placed in such account so that, there will be adequate moneys available for such repair and restoration, including a contingency reserve satisfactory to the Mortgagee. The Trustee shall not be obligated to make any payment from such account if there exists any Event of Default hereunder. Any balance of the Net Proceeds (together with any investment income therefrom) held by the Trustee remaining after payment of all costs of such repair or restoration shall be paid to the Trustee for deposit into the Bond Fund for application as provided in the Agreement. .~ As a condition to approval of any repair or restoration of the Project Facilities and the release of any Net Proceeds in excess of [$IQO.OOOJ held by the Trustee for such purpose. the Mortgagee may, at the Mortgagor! s expense, obtain the services of a construction consultant or consultants to advise the Mortgagee as to the adequacy of the plans and specifications, as-built value and utility of the proposed work. adequacy of funds available for such work and such other matters as the Trustee may require. The right of the Mongagor to repair or restore the Project Facilities shall be subjet:t to such terms and conditions as the Mortgagee or its construction consullants may reasonably impose. Without limiting the generality of the foregoing, the Mortgagee and its construction consultants shall have the right to approve all plans and specifications, contractors. subcontractors, architects, engineers and suppliers and all construction contracts (including retaining provisions) and may require a fixed price contract and/or payment 23 19-/~ .~ and performance bonds as deemed necessary or desirable by the Mortgagee or its construction consultants. The Mortgagee and. its construction consultants shall be entitled to such documentation. opinions, appraisals and other protections and assurances as may be customarily required by construction lenders or as they may otherwise reasonably require. Failure by the Mortgagor to fully satisfy all conditions and requirements for the rcpair or restoration of the Project Facilities within six months after occurrence of the casualty giving rise to the need therefor shall constitute an Event of Default hereunder. If, in lieu of repair or restoration. all Outstanding Bonds are to be redeemed pursuant to the Agreement, an amount equal to any Net Proceeds received by the Trustee prior to such prepayment shall (together with any investment income therefrom) be credited against the amount payable by rhe Mortgagor pursuant to the Agreement to effect such redemption. ' Section 5.3. Eminent Domain. If title to or the tcmporary use of the Projecl Sile or any . part thereof, shall be taken under the exercise of the power of eminent domain by any governmental body or by any person, firm or corporation acting under governmental authority, the Mortgagor will promptly give written notice thcreof to the Mortgagee describing the nature and extent of such taking. Any Net Proceeds received from any award made in such eminent domain proceedings (or from any sale made by the Mongagor and Trustee jointly under threat of condemnation) shall, if received prior to the release and discharge of this Mortgage, be paid to and held by the Trustee in a separate condemnation award account for application to one or ,.:.~) more of the following purposes: (a) The moditication of th~ Project Site and Project Facilities so that the Mortgagor may be able to conduct its busin~ss activities at the Project Site as nearly as practicable to the same manner as cxisted immediately prior to the exercise of the power of eminent domain with such changes or alterations, howevert as the Mortgagor may deem necessary for proper operation of said activities. (b) The acquisition of additional land which shall be made a pan of the Project Site or construction of other improvemcnts suitable for the Mortgagor's operations on the Project Site (which improvements shall be made a part of the Project Facilities); provided. that such land and improvements shall be subject to no liens or encumbrances (other than thc Iicn hereof and Permitted Encumbrances). (c) Payment into the Bond Fund to l~ uSt'<l for the rL>dernption of Bonds, in the manner and to the extcm permitted by the Indenture. ,~ Within ninety days from the dalc of clllry of a tlnal order in any cminent domain proceeding (or any sale under threat of (.:'ondemnation). the Mortgagor sh:11l advise the Mongagee in writing as to which purpose or combination of purposcs ahove specified the Net Proceeds of the condemnation award or sale (together with any invcstment income therefrom) shall be applied. Any balance of the Net Proceeds (togethcr with any investment income therefrom) not required 24 Cjtf- / ~ .---...._~t_....~ I I . I 'J . I '. -or ~ ! ' !>" i, i' . i. , , j, ~ . I: I. . i l'. . " i, . ) I .~- , ::J for the purpose or purposes so directed shall be applied by the Trustee as provided in Scction 4.6 of the Agreement. . Application of Net Proceeds of condemnation for the acquisition and/or rcslOfmion of Project Facilities shall be subject to the same terms and conditions as repair or rcstoration of Project Facilities following a casualty, as set forth in Section 5.2 hereof. Section 5.4. Investment and Disbursement of Net Proceeds. All moneys received by thc Trustee or its designee constituting Net Proceeds shall. pending application, be invested at the direction of the Mortgagor (tor the account of and at the risk of the Mortgagor) and shalJ (lOgclher with any investment income therefrom) be disbursed, to the extent to be uscd for rcpair. rebuilding, restoration, acquisition or construction, as provided herein and in the Agrccmcnt and the Indenture for the investment and disbursement of moneys in the Project Fund and. to the extent held in the Bond Fund for the redemption of Bonds. as provided in the Agrecment and Indenture for the investment and disbursement of moneys in the Bond Fund. Any balance of Net Proceeds (together with any investment income therefrom) held by the Trustee or its designee upon the release and satisfaction of this Mortgage pursuant to Section 7.3 hereof, or any Net Proceeds thereafter received by the Trustee shall, to the extent not retained by the Trustee to pay amounts then due or to become due under the Agreement or the Indenture (including amounts needed to pay fees and expenses of the Trustee, Paying Agent, Registrar and Authcnticating Agent, amounts due the Issuer with respect to the Issuer's Unassigned Rights and amounts required to be deposited in the Rebate Fund) be paid to the Mortgagor. (End of Article V) 25 91,If{ ~~~~~"'t ~ "-~h""=' ~--................"':'_...'.. 't.__ ..._ ~. ...,....\ ""I... .,1'" ARTICLE VI 'J REMEDIES Section 6.1. Ri.eht to Perform Covenants. If the Mortgagor fails to make any payment or perform any act required to be made or performed hereunder (including. without limitation, the payments described in Article III hereot) or under the Agreement or the Notes, the Mortgagce without demand upon the Mortgagor and without waiving or rcleasing any obligation or default. may (but shall be under no obligation to) make such payment or pertorm such act for the account and at the expense of the Mortgagor and may enter upon the Mortgaged Property or any part thereof tor such purpose and take all such action thereon as. in its opinion. may be necessary or appropriate therefor. All advances for payments so made by the Mortgagee and all advances tor costs, tees and expenses (including. without limitation, reasonable attorneys' fees and expenses) incurred in connection therewith or in connection with [he performance by the Mortgagee of any such act, together with interest thereon at the Interest Rate tor Advances from the date of payment or incurrence, shall. to the extent permitted by law, be additional indebtedness secured by this Mortgage, and shall be paid by the Mortgagor to the Mortgagee on demand. . In any action brought to collect such indebtedness, or to foreclose this Mortgage, the Mortgagee shall be entitled to the recovery of the reasonable legal fees and expenses and costs incurred by Mortgagee in such action, including fees and expenses on appeal or in insolvency proceedings. Section 6.2. Events of Default. Anyone or more of the following events shall be an '.:) Event of Default under this Mortgage: (a) Failure by the Mortgagor to pay when due any installment of principal, interest or premium under the Notes. (b) An Event of Default as defined in Section 7.1 of the Agreement. (c) Failure by the Mortgagor to pay to the Mortgagee (within 10 days of receipt of notice of the Mortgagee of the sum owing) any amounts due under Section 6. 1 hereof. (d) Failure by the Mortgagor to observe or perform any term, covenant or agreement on the Mortgagor's part to be observed or performed under this Mortgage, and continuation of such failure for 30 days after written notice thereof shall have been given to the Mortgagor by the Mortgagee, or for such longer period as the Mortgagee may agree to in writing; provided that if the failure is other than [he payment of money and is of such nature that it cannot be correcled within the applicable period, such failure shall not constitute an Event of Default so long as the Mortgagor institutes curative action and diligently pursues such action 10 completion unless, in the reasonable judgment of the Mortgagee, such failure would materially impair the value or marketability or title to the Mortgaged Property or Mortgagor's business or operations. J 26 ~'1-lt J ') (c) The Mortgagor shall: (i) admit in writing its inability to pay its debts generally as they become due; (ii) have an order for relief entered in any case commenced by or against it under the federal bankruptcy laws, as now or hereafter in effect; , , I ! (iv) I I i (v) I (iii) commence a proceeding under any other federal or state bankruptcy. insolvency. reorganization or similar law, or have such a proceeding commenced against them and either have an order of insolvency or reorganization entered against them or have the proceeding remain undismissed and unstayed for ninety days; make an assignment for the benefit of creditors; or have a receiver or trustee appointed for them or for the whole or any substantial part of its property. I~) J , Notwithstanding the foregoing, if, by reason of Force Majeure, the Mortgagor is unable to perform or observe any agreement. term or condition hereof. other than any obligation to make payments required hereunder, the Mortgagor shall not be deemed in default during the continuance of such inability. However, the Mortgagor shall promptly give notice to the Trustee of the existence of an event of Force Majeure and shall use its best efforts to remove the eftects thereof; provided that the settlement of strikes or other labor disturbances shall be entirely within its discretion. . The term Force Majeure shall mean, without limitation, the following: (i) strikes or other labor disturbances; acts of public enemies; orders or restraints of any kind of the government of the United States of America or of the State or any of their departments, agencies, political subdivisions or officials~ or any civil or military authority; insurrections; civil disturbances; riots; epidemics, landslides; lightning; earthquakes; tires; hurricanes; tornados; stonns; droughts; floods and other natural disasters; explosions; breakage, malfunction or accident to facilities, machinery, transmission lines or pipes; partial or entire failure of utilities; shortages of labor, materials, supplies or transportation; or (ii) any cause, circumstance or event not reasonably within the cOnlrol of the Mortgagor. Section 6.3. Remedies. If an Event of Default shall have occurred and be continuing, the Mortgagee, at any time, at its election. may exercise any or all or any combination of the , remedies conferred upon or reserved to it under this Mortgage, the Agreement, the Notes or any ,....) 27 99-lt .~ instrument collateral thereto. or now or hereafter existing at law. in equity or by statute. Without limitation, the Mortgagee may (a) declare the entire unpaid principal balance of the indebtedness secured hereby immediately due and payable, without notice or demand. the same being expressly waived by the Mortgagor; (b) proceed at law or in equity to collect all indebtedness secured by this Mortgage due hereunder, whether at maturity or by acceleration; (c) foreclose the lien of this Mortgage as against all or any part of the Mortgaged Property; and (d) exercise any rights, powers and remedies it may have as a secured party under the Uniform Commercial Code of the State, or other similar laws in effect including, without limitation, the option of proceeding as to both personal property and fixtures in accordance with the Mortgageets rights with respect to real property. Any moneys received by the Mortgagee pursuant to the exercise of remedies provided in this Mortgage or by law shall be applied as provided in Section 7.06 of the Indenture. Section 6.4. Waiver of Appraisement: Valuation. The Mortgagor does hereby waive to the full extent it may lawfully do so, the benefit of all appraisement, valuation, stay and extension laws now or hereatier in force and all rights of marshaling of assets in the event of any sale of the Mortgaged Property, any part thereof or any interest therein and any court having jUrisdiction to foreclose the lien hereof may sell the Mortgaged Property in part or as an entirety. .-. ') , / Section 6.5. t\ppointment of Receiver. If an Event of Default shaH have occurred and be continuing, the Mortgagee shall, as a matter of right and to the extent permitted by applicable law and without regard to the adequacy of the Mortgaged Property as security, be entitled to the appointment of a receiver for aU or any part of the Mortgaged Property. whether such receivership is incidental to a proposed sale of the Mortgaged Property or otherwise. and the Mortgagor hereby consents to the appointment of such a receiver and covenants not to oppose any such appointment. Section 6.6. Possession. Manae:emem and Income: Assi2nment: Application of Moneys Received. If an Event of Default shall have occurred and be continuing. the Mortgagee, to the extent permitted under applicable law, ex parte and without notice may notify all lessees and account debtors to make payment directly to the Mortgagee or its agents and may retain such amounts for application to the indebtedness secured hereby and enter upon and take possession of the Mortgaged Property or any part thereof by force, summary proceedings, ejectment or otherwise, and may remove the Mortgagor and all other persons and any and all property therefrom and may hold, operate and manage the same and receive all revenues, income or profits accruing with respect thereto or any part thereof. The Mortgagee shall be under no liability for or by reason of any such taking of possession, entry, removal, holding, operation or management. All amounts received by the Trustee pursuant to this Article shall be applied as provided in the Indenture. '~ Section 6.7. Remedies Cumulative. Each right. power and remedy of the Mortgagee, provided for in this Mortgage. in the Agreement. in the Notes or now or hereafter existing at law or in equity or by stature or otherwise. shall be cumulativc and concurreru and shall be in addition to every other right, power or remedy provided for in this Mortgage, in the Agreement, in the Notes or now or hereafter existing at law or in equity or by statute or otherwise, and the exercise or beginning of the exercise or partial exercise by the Mortgagee of anyone or more of such 28 99-/~ ~) <....... , I I I I, I " . .~) \......... . 0, " rights, powers or remedies shall not preclude the simultaneous or later exercise by the Mortgagee of any or all such other rights. powers or remedies. . Section 6.8. Provisions Subject to Applicable Law. All rights, powers and remedies provided herein may be exercised only to the extent that the exercise thereof does not violate any applicable law, and are intended to be limited to the extent necessary so that they will not render this Mortgage invalid, unenforceable or not entitled to be recorded, registered or filed under any applicable law. Section 6.9. I':iQWaiver by Mortga2ee. No failure by the Mortgagee to insist upon the strict perfonnance of any term hereof or to exercise any right, power or remedy consequent upon a breach thereof shall constitute a waiver of any such tenn or of any such breach. No waiver of any breach shall affect or alter this Mortgage, which shall continue in full force and effect with respect to any other then existing or subsequent breach. . , Section 6.10. Discontinuance of Proceedines and Restoration of Status QUQ. 1n case the Mortgagee shall have proceede;d to enforce any right, power or remedy under this Mortgage by foreclosure, entry or otherwise, and such proceedings shall have been discontinued or abandoned , for any reason, or shall have been detennined adversely to the Mortgagee, then and in every case the Mortgagor and the Mortgagee shall be restored to their former positions and rights hereunder. and all rights, powers and remedies of the Mortgagee shall continue as if no such proceeding had been taken. (End of Article VI) 29 19-1'6 ~L ARTICLE VII ~ MISCELLANEOUS Section 7.1. Additional Security-. Without notice to or consent of the Mortgagor and without impairment of the lien and rights created by this Mortgage, the Mortgagee may accept from the Mortgagor or from any other person or persons, additional security for the indebtedness secured by this Mortgage. Neither the giving of this Mortgage nor the acceptance of any such additional SL'Curity shall prevent the Mortgagee from resorting, tirst, to such additional security, or first, to the security created by this Mortgage, in either case without affecting the lien hereof and the rights conferred hereunder. ,~,,) Section 7.2. Release of Mortgaged Property and Easements. At the request of the Mortgagor, the Mortgagee may, at any time and from time to time, in its sole discretion. consent to, join in or permit a release of any part of the Mortgaged Property or the granting of any easements, licenses, party wall rights and rights of lateral support with respect to the Project Site or the Project Facilities. As a condition to the granting of such release, the Mortgagor will deposit any money received by the Mortgagor with respect to the released Mortgaged Property in the Bond Fund or in escrow for the payment of the Bonds. Such a release shaH be pennitted only if the Mortgagee shall have determined that any of the foregoing is not prejudicial to the Holders of the Bonds and does not impair the value or marketability of the Mortgaged Property (taking into account any amounts to be deposited in the Bond Fund or held in escrow, as aforesaid). as security under this Mortgage. None of the foregoing shall impair in any manner the validity. or except as spedtically provided therein the priority of this Mortgage. Section 7.3. Expen~s. The Mortgagor will, to the extent permitted by law, immediately upon demand payor reimburse the Mongagee for all auorneys' fees, costs and expenses incurred by the Mortgagee hi any proceedings involving an insolvent or a debtor under federal bankruptcy law, or in any action, proceeding or dispute of any kind in which the Mortgagee is made a party, or appears as an intervenor or party plaintiff or defendant, affecting or relating to the Series 1999 Notes or any other NOleS secured hereby, this Mortgage or the Agreement, the Mortgagor or any of the Mortgaged Property, including, but not limited to, the foreclosure of this Mortgage, any condemnation action involving the Mortgaged Property, or any action to protect the security hereof, and any such amounts paid by the Mortgagee shall be added to the indebtedness secured hereby and secured by the lien and security interest of this Mortgage and shall bear interest at the Interest Rate for Advances. , '..~ Section 7.4. Books. Reconls and Accounts. The Mortgagor will keep and maintain or will cause to be kept and maintained proper and accurate books, records and accounts reflecting all items of income and cxpense in conncction with the opcration of the Mortgaged Property or in connection with any services. equipment or furnishings provided in connection with the operation of the Mortgaged Property, whether such income or expenses be realized by the Mortgagor or by any other person or entity whatsoever cxcepting sublessors unrelated to and unaffiliated with the Mortgagor and who leased from the Mortgagor portions of the Mortgaged 30 f9-lr tl Property for the purposes of occupying same. Thc Mortgagee and ils dcsignee shall have the right from timc to time at all times during normal busincss hours to examine such books. records and accounts at the office of the Mortgagor or other person or entity maintaining such books. records and accounts and to make copies or extracts thereof as the Mortgagee shall desire. Section 7.5. Estoppel Affidavits. The Mortgagor. within ten days after written request from the Mortgagee, shall furnish a written statement, duly acknowledged. setting forth the unpaid principal of and interest on the indebtedness secured hereby and whether or not any offsets or defenses exist against such principal and interest. Section 7.6. Subrollation. The Mongagee shall be subrogated to the claims and liens of all parties whose claims or liens are discharged or paid by the Mortgagor with the proceeds of the indebtedness secured hereby. Section 7.7. No Merger. It being the desire and intention of the parties hereto that this Mortgage and the lien thereof do not merge in fee simple title to the Mortgaged Property, it is hereby understood and agreed that should the Mortgagee acquire any additional or other interests in or to the Mortgaged Property or the ownership thereof, then. unless a contrary intent is manifested by the Mortgagee as evidenced by an appropriate document duly recorded, this Mortgage and the lien thereof shall not merge in the fee simple title, toward the end that this Mortgage may be foreclosed as if owned by a stranger to the fee simple title. <:) Section 7.8. General Provisions. This Mortgage shall be deemed to be made under the laws of thc State and for all purposes shall be governed by and construed in accordance with the laws of the State and shall inure to the benetit of and be binding upon the Mortgagor, the Mortgagee and their respective pennitted successors and assigns. If any term or provision of this Mortgage shall be held to be invalid. illegal or unenforceable, the validity of the remaining provisions hereof shall in no way be affected thereby. The captions or headings herein shall be solely for convenience. Section 7.9. Amendments. Chan2es and Moditications. Except as otherwise provided herein. this Mortgage may not be effectively amended. changed. modified. altered or terminated without the prior written consent of the Mortgagee and the Trustee. In the event of the issuance of Additional Bonds, this Mortgage may not be effectively cancelled, changed, modified or altered without written title evidence that the Trustee. as holder of the Mortgage and of any amendments or supplements thereto relating to those Additional Bonds, will have a valid. direct first mortgage upon the Mortgaged Property constituting real property subject only to (i) taxes and assessments which are not delinquent, and (ii) liens and encumbrances permitted by the terms and provisions of this Mortgage. as so supplemented or amended. The title evidence shall consist of an American Land Title Association form of loan policy of title insurance. or a commitmcm therefor, in usual and customary form in a face amount acceptable to the Trustee. The policy or lhe commitment therefore shall be issued by a title . '1 \.~ 31 'If,- /~ ......~~~..~----.....-........_-_.~.: I :. , . ,t""r ,~ '" ""0 , . . .~....... ..:<.) . .J ..M....................~........--. "'.., _ ~....-- .lII. company authorized to transact business in the State. selected by the Mortgagor and approved by the Mortgagee. Section 7. I 1. Disposi tio(1. Except as permi ued by and subject to the provisions of the Agreement and Sections 3.1,3.2.4.3,4.4.. 5.1,5.2,5.3,5.4 and 7.2 hereof, the Mortgagor shall not sell, transfer, convey, lease or encumber (except Permitted Encumbrances) the Mortgaged Property without the prior written consent of Mortgagee. Section 7.11. Issuer's Rieht of Purch~. Notwithstanding the foregoing, the Mortgagee. during any period the Series 1999 Bonds are Outstanding, shall, have the right. but not the' . obligation. to purchase the Cove Building following an Event of Default hereunder by paying the Outstanding principal amount of the Series 1999 Bonds. In either such event. prior to such purchase the Issuer shall deliver written notice of its election to purchase the Cove Building. Upon such purchase this Mortgage shall terminate as to the purchased property and the 'Mortgagee shall take such steps as may be required or permitted to remove the lien of this Mortgage from such property. (End of Article VII) 32 99~!gr "." " ~. .. L .;.' . '.< _1.'.. . ._, ~ . . . '." .... , .' /:, r ',. ... ,".1 'r' -.. ' .~. .. '.> <", ":\.....; '.. ,..;: .. ' :.~! _.: .. ." 1 . .' . ".' '.i c, .,'.' , . (). I -" j .....~... ~ -, :..J IN WITNESS WHEREOF, the Mortgagor has executed this Mortgage as of the date hereof. . Signed and acknowledged in the presence of: BEF, INC., a Florida not-far-profit. corporation 1 , i . By: Title: President Attest: Title: Secretary Witnesses as to BEF. Inc., a Florida not-for- profit corporation STATE OF FLORIDA ) ) SS COUNTY OF PINELLAS ) The foregoing instrument was acknowledged before this I II day of May. 1999 by and the President and Secretary, respectively, of BEF, Inc. IN WITNESS WHEREOF, I have hereunto set my hand and seal as of this pi day of May, 1999. Name: Notary Public. State of Florida My Commission Expires: (SEAL) Personally Known 0 or Pro~uced Identification 0 Type of Identification Produced 33 rr-/~ ~"'~~~.~T""::::~_'~ . '., v.... . . r' , ~.. ~ ,,~..' . ,c ~d~.~. ... 'C.c'.C~.I.. ~ "~l. ' , ., ,~~ ~, '. . . ._.._---~~-~~------~~ i',. ioi!}~~ ~~~:,.: :~11>:".1 ~..c ,. ,~.,..... ,.... ,.... + fi f... I' '. !.~ . :".:,t,.'" \";>;' .', :~:' . ~ .. " . :;~ ',' . :,,t , ~~oj' " ~I .' " .. , , . ,; ?: ";>;~;' " ,. ~ '-'.,' . ," w', " "\' ~ . ' ' '~~ J. ~ . ~,o J . '(, ':~.7) --'" I ~H ~ ", ',. i: ~\, , t;: c:; r~:..::.:.=~~ '.:;t: 2.~.1. .c " I ::.~: \, \ ". .~~ -.......... ..,..,'" .t.:t.>,,..'~ ~,t';,,;.b.I..., "-~..,..:-,,,~' r . . . EXHIBIT A PROJECT SITE LEGAL DESCRIPTION Site I - Cove BUildini [to be provided] " . : + -"~'4.~,~V~W.j.,.I.."o/j;~lrt: ,,},',~l...~~4";.;';'i'''''''.ol-~fiI.y4H.''~"'- ':~... -- ,..' f9 ~ 1ft . . ',. . .:.' .l....: I' -?' . .', ~ . :~'''.~ ! I'" .:t, \ ' '~1.~~" ,:.' .': "'~\'~"~:':d~"i' - .~. , , > o I" ,," '..i .-(.":: . . ',.; :. ~. I . ~. '\:, .e. " , ~ \ ~ ~:. , ..,' ,I: , :,,:, ",/. :, . ." .\ . . ,~'. , :.\,.. .' . " '~: " . ~ , , ~. . ~ . , < ~ ~ . ~ f~ ..,<J '" 'j: ".' 0' " :' .\'~, . ,. I'..,. ."t', ,. '.\' ' ) . > e . , . . " ~~~'~~:'.' i:::~~~:~~~.~',_.j.~. ";~'."~T~...~..,.~~~,,,.I;~!I~\~~'<"'~~)~:~ .': :.c . EXHIBIT B PERMITTED ENCUMBRANCES :'\ , .1 ,I B.l 1'1-/8' ..... .....~,. WI"'~'~~""-',r.:~',"'"drrJY"'lJ;,~.~:;"~''''.'''''''.. ,..It; ,"-...,.'t~""'~1."'....f-l;';k;~ ~.':"':I.:.~'.:J~ i'~' ,.'.' ~. ,-,.~"."....I' ,..<' ~'B;~' .1,- . ........- .-'-.-rl'. ,'. .'/.' . ',' ~ ~ I .' l~:"';, ':, :. q >.." ',p . .. ... ,..... .,' . . <, .. \>" 'I' .. ....' c, ,. , ~~:", .,...., , -~.i~:<~\':' ,'; ~lr~{hr:\;' ~';' "" ""0":':" ", f 0 . :I " I," , ( , , ~"t :':.'.':iA .....~.:. .'....~Jo::'f~~ , }:::, . , , :,.,-. ~ /;: : . . " ..:. .;t: .~ 1 "~., ~ r 1 ~ , . :': ~ , ,.<< :'~>.'J :1. r~~: : ",' ,,' ~'1,: ~ ~ ~. ',,'.:. :,'/1,: : V.:" ~ .,~< " -:;:.~.. . I~' . .:-:.. .t' r".: , . d .... .~~ ~ ~ . t~'!'',' ~'~ l. : ,',. ( ~. <, ~ J' " fo,,',':.,. _ ,.,. .). ,;.;;i~ . .' '.' :.>1' . f , c I:': '1." , " 0" :~;\. .. , " i'.' . ,', };. .. , r..-:: , (. ,.'~.:,o ':',..' ~.'; , I' .. < , " " - .- . ,f" :~~~.JiIIoII"-''''''''''''''''''~::~'T"~,';'. :" ,. ';,.-......':"'...."h.1+I.."'~..:l~~...I..,... .~~),~::'~(I;:~':." 1,1,~.~:<.~,,~.;~:..~'t:./..... ',. '}, . _-.1____________.___' '~;- '. EXHIBIT C FORM OF PROMISSORY NOTES ,I I I i i , I i I B-2 ,99~/~, 'I T ~...... "'.~'>-"l~ :~...... Lj ..~:~~) "'>~l .~~:~ ~.i';:; ,.:'.'1..,;, I.' ~ ~.'. ., ,tot ''-''':"''of I. ',,!.. ....l+.~I..".? .(,..~...,.i :.".. ~"d.... '......., . ~ ;.r ! ' ~" .~ 4-~tt:,.'" ~ .,.. -' . t ...., ~ t. T .;". '.. '. "r . ~.- ;' t.:. .l. J ) ".<" , ~ . ':! ~..: :' :..!." ',". f',:/ ,~~ ,j l ~. . .; . ; ~~. '" : / .~':'" ',.": '. ", ;:'j,~' I.. ': ,i . :" c~.l: < , .( ~ .' ",.;,.<:-.' ~~' ~J ,. I .' .~~ .>'t .1. i' .> ~" ~;, . i ~ ' ". '1-',<. I ,!:':", " ',' , ' .' " . .', " ;'~-'l 1.;:J .- t,:. ~4.7:T:!;. ~~. ~ ,. \ " ' < . ._-= ._~ , EXHIBIT D ASSIGNMENT OF MORTGAGE AND SECURIT'( AGREEMENT .'. B~3 99~/~ .... . :..........,.,,~L ,.~"......\f,..".T j ~ l' .... ~.~'h,.:..u,~ ',~..:t, ~~j'".~,~;II;.~;il.(~~J.,..,~"",,,.,JJ.-J''''''''' ; ~ . '.1, , . "\ ~ .. :. :';;11 . ; ~ ,\ ~ ~. . ,.. J .'.". . , ~ .". . 'Ii".; ~. . . ~ ',.<0 . . "'~ .~. ,1 , t~"!J,...:""''' ~ ' j' " '- . 'i.~ :- :;}. I: i ,. n " . ~ i" '.' . , '.~ c" , I .:v ."i., ~ ' _.~ t .". ,~ { (.... ~ <~ .. . 0' p, " , .. '. . >, '. f.:' ,fl' " '.", '. ~, ,. , >' J.';' , .:j":' .. ,.- "'0'- . .. .' j::, .. , '0 '. .' ,"J :.;~ .'::. . ': . 'I.'.' ",' Y ;\;: ., -l_,___r ~ ~," ~ .-...t'TY"~~~~...4_.\.~t"'~"J.r....'O/--olo'"-''' ,! : ,,~~ t ~. EXHIBIT C FORM OF LOAN AND SECURITY AGREEMENT '0 < ' '. ~ ...-....-d~~~Lj:.>LI~... ;r.....~,...r. '''7 ,,1,-;:.,: ",~...-t. ~ t:."~",,,,, ~'l"i"'ll..'~,,~",' ,"., "~., ., , ., :1 'I ;1 Resolution 99-18 .',.~.', \.~......., O......~." .~.rU.."'f>_i.. <<0':""'_..' , ~ ',~ i.I'., , . -: .',.(~. . ..~> foil '. I, .. " r. l~: . , ;' "~ . ~ . j.. .' \). , . '" " ~ . ",~,,".' . ,.- ". ~ Draft #4 OS/28/99 BMO #3195 , ., LOAN AND SECURITY AGREEMENT between .' . CITY OF CLEARWATER, FLORIDA AND ' BEF, INC. ,. ' '. , City of Clearwater,' Florida. Housing Revenue Bonds (BEF, Inc. Project) , . Dated as of July 1, 1999 This Instrument Prepared by: " Raben C. Reid, Esq. Bryant, Miller and Olive. P.A. 201 South Monroe Street Suite 500 TaJJahassee, Florida 32301 qq ,- If.(' ';..y'''-~-'~~L~_:''''::::"_:::::_,"--.!.: -'.'_~~.?"".~'-'\~ n.-............ftrH.~'t~#II.....::. A rl... _.-".....,' . ,~. .>. .~. ~< ','.' ~~,,'.\oo~~~o.J~U''''''"''"''''''''''''''''''1.rt,.. i~.., , . . .', :r-) .' ~~'^...~ Section 1. 1. e' Section 1.2. Section 1.3. , Section 2.1. Section 2.2. Section 2.3 Section 2.4. '. , I TABLE OF CONTENTS ARTICLE I DEFINITIONS Use of Defined Terms .. . . t t . , . ,.. . .. .. . ~ ,.. , .. . . . . ~ . , . .. . . . . . 2 Intel:Pretation ,,"".............,....................,...... I . . . . . . ... 19 Captions and Headings ...........................'.. 20 ARTICLE II REPRESENTATIONS , Representations and Covenants of the Issue( . . . . . . . . . . . . . . . . 21 Representations and Covenants of the Company . . . . . . . . . . . . . . 21 Tax Covenants of the Company . . . . . . . . . . . . . . . . . . . . . . . . 22 Use of Project , . . . .. . ... . . . . : . . . ...'. . . . . , . + .. , . . . + , . ... ... ... 27 ARTICLE III COMPLETION OF THE PROJECT; ISSUANCE OF THE SERIES 1999 BONDS ~) Section 3.]. Acquisition. Conscnfction. Installation. Equipment and Improvement . Section 3.2. Section 3.3. Section 3.4. Section 3.5. Section 3.6. Section 3.7. , Section 3.8 Section 4.1. Section 4.2. Section 4.3. Section 4.4. Section 4.5. Section 4.6. Section 4.7 ::; . . . . ... . . ~ ~ . . . . . . . .. . . Ii . t . . . . .. . . . . . . . . . -to . . . Ii . . . 28 Plans and Specifications. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Issuance of the Series 1999 Bonds: Application of Proceeds: Company Equity' .. . . . . . ... . + , . . . . . . . .. .. .. , . . . . . . . . . , . . . "" . . + . .. 28 Disbursements from the Proiect Fund .................... 29 - Company Required to Pay Costs in Event Project Fund Insu~m . 31 Completion Date ........"...... . . ... . " . . , .. . . . ... . .. . . .. .. . . , 31 Investment of Fund MQ.O.ell . . . . . . . . . . . . . . . . . . . . . . . . . . 32 Additional Bonds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 ARTICLE IV LOAN BY ISSUER; REPAYMENT OF THE LOAN; LOAN PAYMENTS AND ADDITIONAL PA YMENTS Loan Repayment: Delivery of Notes and Mortgage. . . . . . . . . . . . 33 Additional Payments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 Place of Payments ................................ 36 Obligations Unconditional ........................... 36 Assi2nment of Aereement and Revenues . . . . . . . . . . . . . . . . . . 36 Application of Certain Moneys ................ . . . . . . . . 36 Issuer's Right of Purchase ........................... 37 11 r If{ j"'-') ARTICLE V ADDITIONAL AGREEMENTS AND COVENANTS Pledee of Revenues. Security Interest and Transfer of Intanl:ibles .. 38 Debt Service Coveraf:e Ratio ......................... 39 Calculation of Ptincipal and Interest Requirements . . . . . . . . . . . . 40 permitt~d Debt ...................,..........,... 41 Pari ty Debt . .. . . . . . .. .. . . 4 .. . . .. . . .. .. . .. . .. . .. , . of . . + . . .- . .- 44. Restrictions on Disposition of Property: Lease or Use of Project . . . 46 Permitted Encumbrances ......................,..... 48 Maintenance of Corporate Existence. . . . . . . . . , . . . . . . . . . . . 50 Annual Audit and Periodic Report ..,...........,.....,. 52 Perfection of Security Interest . . . . . . . . . . . . . . . . . . . . . . . . . 53 Riehl of Jn~ection . , , .. ~ , . , " . . + . , , I . . , . . . . . . , . .. . . .. , 53 Indemnification . . .. . . . . . . .. . . .. .. .. .. . . . .. .. . . . . .. . .. , , .- . . .. 54 Company Not to Adversely A ffeet the Exclusion From Gross Income of Interest on Tax~Exempt Bonds. . . . . . . . . . . . . . . . . .'. . . . . . . 56 Section 5.14. Litieation Notice ........,........................ 56 Section 5.15. Governmental Permits and Reeulations ... . . . . . . . . . . . . . . . . 57 Section 5.16. Annual Bud~ets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . 57 Section 5.17. Project as Public Facili~ ' , . . , , . . . . . . . , . . . . , . . . . . . . . . 57 Section 5.18. Restriction Aeainst Religious Activities. . . . . . . . . . . . . , . . . . . 58 Section 5.19. Application of Revenues: Renewal and Replacement Fund , . . . . . . 58 Section 5.20. Purchase of Tender Bonds by Company, . . . , . . . . . . . . . . . . . . 59 Section 5.21 Minimum Liquid Reserve and Operating Reserve Amount . . . . . . . 59 [Section 5.22 Special Covenants. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 Section 5.23. Liquidity Covenant. . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . 59 Section 5.24. Trade ~3.Yable Covenant ...,.......,................ 60 Section 5.25. Occupancy Covenant. . . . , . . . . . . . . . . . . . , . . . . . . . . . . . . 60 Section 5.1. Section 5.2. Section 5.3. Section 5.4. Section 5.5. Section 5.6. Section 5.7. Section 5.8. Section 5.9. Section 5.10. Section 5.11. Section 5. 12. Section 5.13. --, , , ; "..-- ARTICLE VI REDEMPTION OF BONDS Section 6.1. .QpJional Redemption ............,.............. .. . . 61 Section 6.2. Mandatory Redewption or Purcha~ . . . . . . . . . . . . . . . . . . . . . 61 ARTICLE VII EVENTS OF DEFAULT AND REMEDIES Section 7.1. Events of Default . . . . . , . . . . . . . , . . . . . . . . . . . . . . . . . . . 62 Section 7.2. Remedies on Default . . . . . . , . . . . . . . . . . . . . , . . . . . , , .. . 63 Section 7.3. No Remedy Exclusive. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 o _.....~~........----_:- ii 11-(~ n...(.~, .. , ',C) ~4: ,.fl' " ;;1- . ,< \ . , \:.' . <' " ~:' .: ' ~), 'I . : -"".\ . . "'-" : , , , . . , ' .'\ , " o d ....... Section 7.4. ' A2teement to Pay Attorneys' Fees and Expenses . . . , . . . . . . . , . 65 Section 7.5.' No Waive( . . . .. II ,.. . II . .. 01 .. . .. . , .. II .' .. .. .. . .. II , ..' II II . ... . II . iii II . 65 , Section 7.6. Notice of Default . . . . . , . . . , . . . . ~ . . . . . . . . . " . . . . . . . . 66 I 1 i I I I ARTICLE VIII MISCELLANEOUS Section 8.1. Term of Agreement ,........,.........,...,....... 67 , Section 8.2. ' Amounts Remainin& in Funds . . . . . , , . . . . . . , . . , . . . .. . . . 67 Section 8.3. Notices II II II . II .. ,.. II . . ,.. . 01- .. III . . . -II .. . . ... + . . .. II .. .. II . . .. . . .. .. . 67 Section 8.4, Extent Qf Covenants of the Issuer: No Personal Liability . . . . . , . , 67 Section 8.5. Bindin2 Effect. . . . . . , . . . . . . . . . . . , , . . . . , . . . . . . . . , , 68 Section 8.6. Amendments and Supplements ........................ 68 ,:Sectlon 8.7. Execution of Counterparts ... .'. . . . , . . . . . . , . . . . , . . . . . . 68 Section 8.8. Severability .................,.........,........ 68 Section 8..9.. Governing Law ... III .. . II . III .. .. -II II .. . II . 01 . . .. II : 01 ,.. ~ . . . ... . . . ,.. 69 . Exhibit A Exhibit B . Exhibit C . Exhibit D Exhibit E Exhibit F SERIES 1999 NOTES DESCRIPTION OF THE PROJECT PROJECT SITE FORM OF DISBURSEMENT REQUEST EXISTING PERMITTED LIENS EXCLUDED PROPERTY Hi 91-/~ . . . . .: . > i .'. . ~ , \ , ' . , ,:) ]" i ( I I I j \~~)' ,.~ LOAN AND SECURITY AGREEMENT . . THIS LOAN AND SECURITY AGREEMENT made and entered into as of July I. 1999, between'the CITY OF CLEARWATER. FLORIDA, a municipal corporation, duly created and validly existing under the laws of the State of Florida (the "Issuertt), and BEF. INC. ~ a Florida not-for-profit corporation duly organized and validly existing under the laws of the State of Florida (the "Company"); A. Pursuant to, the provisions of the Act. .the Issuer has determined to issue. sell and deli ver its Series 1999 Bonds and to loan the proceeds derived from the sale thereof to the Company to assist in the financing of the Project Costs. B. The Company and the Issuer each have lull right and lawful authority to enter into this Agreement and to perform and observe the provisions hereof on their rt:spective parts to be performed and observed. NOW THEREFORE, in consideration of. the premises and the mutual representations and agreements hereinafter contained. the parties hereto agree as follows (provided that any obligation of the Issuer created by or arising out of this Agreement shall never constitute a general debt of the Issuer nor give rise to any pecuniary liability of the Issuer but shall be payable solely out of the Revenues): 1 91'/r ~""'._~_~~L"""'+'~"-"~~. -.. ", . '. _"_:...-. --:--c... 1'11.-\1441......, .r....~. . ""J ARTICLE I DEFINITIONS Section 1.1. Use of Defined Tenns. Capitaliaxl tenns uSL'd in lhis Agreement shall have the meanings set forth below unless the context or use clearly indicates another meaning or intent. Such definitions shall be equally applicable to the singular, possessive and plural forms of any of the words and terms defined therein. ! . i "Act" means the Florida Constitution. the Charter of the Issuer and Chapter 154, Parts II and III of Chapter 159. and Chapter 166. Florida Statutes, as amcnded and other applicable provisions of law. "Additional Bonds" mcans the Additional Bonds issued under the provisions of Section 2.05 of the Indenture. "Additional Notes" means any non~negotiable promissory note or notes. in addition to the Series 1999 Notes, delivered by the Mortgagor to the Trustee in connection with the issuance of Additional Bonds as provided in this Agreement. "Additional Payments" means the payments required to be paid by the Mortgagor under Section 4.2 of this Agreement. ,."~ ~"""'.rf) "Adjusted Rate" means the interest rate borne by the Series 1999B Bonds determined in the manner set forth in Section 2.03(b) of the Indenture. "Affiliate" means a Person which controls or is controlled by the Company or is under common control with the Company. as follows: (A) one Person shall be deemed to control another if it owns more than 50% of the outstanding voting stock of or other equity interest in the other, or it has the power to elect more than 50% of the governing body of the other; and (B) such control may be exercised by one Person over another di rectly. indirectly through control over a third party. or jointly with one or more controlled third panies. "Agreement" means this Loan and Security Agreement dated as of July 1. 1999 between the Issuer and the Company. as amended or supplemented from time to time. "Annual Casb Operdting Expense" means, as of any date of determination thereof, the expenses of operating the Project. other than depreciation. amortization and other non-cash items, for the preceding 365 days, all as determined in accordance with generally accepted accounting principles. "Appraiser" means a Person designated by the Authorized Company Representative, with written notice to the Trustee. who (i) is a member of the American Appraisal Institute, (ii) has no '. ) '-' 2 19~ Ifl ~ ( ..' interest, direct or indirect. in the Company other than payment for services and (iii) in the case of an individual, is not a member, director. trustee. officer or employee of the Company or. in the case of another Person. has no partner. member, director. trustee. officer or employee who is a member, director, truslee. ofticer or employee of the Company. In the event that the American Appraisal Institute should cease to exist. the term "Appraiser" shall mean a Person, designated by the Company with written notice to the Trustee and not objected to by the Trustee within 10 days after receipt of such notice. which objection shall not be unreasonably interposed, who is recognized as qualified to appraise the value of buildings, furnishings and equipment comparable to the Project and who does not have any relationship prohibited in the preccding sentence. ,...-. . , ) "Arbitrage Rebate Agreement" means the Arbitrage Rebate Agreement dated as of May 1, 1999 among the Issuer, the Company and the Trustee. "Architect" means a Person, designated by the Authorized Company Representative, with written notice to the Trustee, who or which Architect (i) is licensed or permitted to practice architecture or engineering in the State, (ii) has no interest, direct or indirect, in the Company and (Hi) in the case of an individual, is not a member. director. trustee, officer or employee of the Company or. in the case of another Person, has no partner, member, director, trustee, officer or employee who is a member, director. trustee, officer or employee of the Company. "Assignment" means the Assignment of Mortgage and Security Agreement of even date with the Mongage. from the Issuer to the Trustee. as amended or supplemented from time to time. ......-.. "Auditor" means a recognized tirm of independent certified public accountants of good repute, designated by the Authorized Company Representative. which is licensed or permitted to practice as accountants and auditors in the State. "Authcnticating Agent" means the Trustee, as Registrar for the Bonds and any bank. trust company or other person designated as an Authenticating Agent for the Bonds by or in accordance with Section 6.13 of the Indenture. each of which shall be a transfer agent registered in accordance with section 17A(c) of the Securities Exchange Act of 1934, as amended. If Authorized Company Represcntative" means the person at the time designated to act on behalf of the Company by its Chief Executive Officer by written certiticare furnished to the Trustee and the Issuer, which certificate may designate an a1ternatc or alternates. In the event that all persons so designated become unavailable or unable to act and the Company fails to designate a replacement within ten (10) days after such unavailability or inability to act, the Trustee may appoint an interim Authorized Company Represcntalive until such time as the Company designates that person. \.J 3 19 -/~ .....~. .~..;"'. ,. ,,-' ;,') "Authorized Dcnombmtions" means (n) with respect to the Series 1999 Bonds. $100.000 or any integral multiple of $5,000 in excess lhcf<."Of, and (b) with rcspcct to Additional Bonds. the denominations authorized in the applicable Supplemental Indenture. "Authorized Official" means the MayorhCommissioner, Vice Mayor, City Manager. or Assistant City Manager of the Issuer, or such other officer of the Issuer as may be designated in writing to the Trustee and the Company by the lssuer. "Bond CowlSCl" means Bryant, Miller and Olive. P.A.. Tallahassc..->e, Florida or such other finn of attorneys approved by the Issuer of nationally recognized standing in the field of municipal finance law whose opinions are generally accepted by underwriters and other purchasers of obligations issued by state and local governments. "Baud Fund" means the Bond Fund created by the Scction 5.01 of the Indenture. "Bond Purchase Agreement" or "Purchase Agreement" means, with respect to the Series 1999 Bonds, the Bond Purchase Agreement among the Issuer, the Company and the original purchaser of the Series 1999 Bonds; and as to any Additional Bonds, any bond purr;hase agreement for which provision is made to purchase such Bonds by the original purchaser thereof. "Bond Year" has the meaning set forth in the Arbitrage Rebate Agreement. .-.. l "Bonds" means the Series 1999 Bonds and any Additional Bonds. "'t..........."..J "Business Day" or "business day" means any day of the year on which banks in any of the cities in which the principal office of the Trustee or of the designated office of any Paying Agent are located are not required or authorized by law to remain closed and on which the Trustee and any Paying Agent and the New York Stock Exchange, Inc. are open for business. "Capitalized Interest" means accrued interest, if any, received upon the sale of the Bonds plus any interest to become due and payable on the Bonds, which is included in the principal amount of the Bonds, and deposited in the Bond Fund and used to pay interest on the Bonds, until completion of a related project. "CWcngo Time" means the time on any given day in the City of Chicago. Illinois, whether such time be Central Standard Time or Central Daylight Savings Time. "Code" means the Internal Revenue Code of 1986, as amended, the Treasury Regulations (whether proposed. temporary or final) under the Code or the Statutory predecessor of the Code. and any amendments of, or successor provisions to, the foregoing and any ofticia1 rulings. announcements, notices. procedures and judicial determinations regarding any of the toregoing, all as and to the extent applicable. Unless otherwise indicated. reference to a Section means the \,~ 4 11-/g ') \,.....,/ <.J ...... '.. .':l'" ~ ... ~.. . . Section of the Code. including such applicable Treasury Regulalions. rulings. announcement.s, procedures. and determinations pertinent to that Section. "Commercia] Code" means the Uniform Commercial Code as enacted in the State, 3S from time to time amended or supplemented. "Company" means BEF, Inc., Inc., a Florida not-for-profit corporation and its lawful successors and assigns, to the extent permitted by the Agreement. "Company Documeutlill mean this Agreement, the Notes, the Mortgage and the Bond Purchase Agreement. "Completion Date" means the date of completion of the Project to be specified in the certificate furnished by the Company pursuant to Section 3.6 of this Agreement. "Computation Date" shall have the meaning set forth in the Arbitrage Rebate Agreement. "Consultant" means a firm of nationally-recognized consultants, designated by the Authorized Company representative with written notice to the Trustee and, so long as the Series 1999 Bonds are Outstanding. B.C. Ziegler and Company, which Consultant (i) is knowledgeable in both the operations and fiscal management of continuing care or similar health care facilities, (ii) has a good reputation for skill and experience in that work. (iii) has no interest, direCt or indirect, in the Company, and (iv) has no partner, principal. member, director, trustee. officer or employee who is a member, director, trustee. officer or employee of the Company. "Contilluing Disclosure Certificate" means the Continuing Disclosure Certificate dated as of July 1, 1999 of the Company. "Days Cash on Hand" means, as of any date of detennination t11ereof, the product of 365 times a fraction, the numerator of which is the sum of cash, readily marketable securities and other investments of the Company not held by the Trustee as of such date and the denominator of which is Annual Cash Operating Expense. "Debt" means all obligations for borrowed money and installment sale and capitalized lease obligations incurred or assumed by the Company and any guaranty by the Company of indebtedness of any other Person, but shall not be deemed to include (a) obligations under contracts for supplies, services and pensions allocable to current operating expenses during the currem or future Fiscal Years in which the supplies are to be delivered, the services rendered or the pensions paid. and (b) payments payable in the current or futun~ Fiscal Years under leases not intended to evidence the acquisitions of capital assets. "Debt Service Charges" mean, for any period or date, the principal of and premium. if any. and interest on the Bonds accruing for that period or due and payable on that date. In II I: \' i , 5 q1', I<? . ........................-.--...___'"''---'..M................................__... I~ ..-.... I ~._."'Jr .-.J determining Debt Service Charges accruing for any period or due and payable on any date. mandatory sinking fund requiremcnts accruing for that pcriod or duc on that date shall be included. IIDcbt Service Coverage Ratio" means the ratio of Net Income Available for Debt Service for the period in question to the maximum Principal and Interest Requirements of the Company on outstanding Long~ Tenn Debt for the then current or any succeeding Fiscal year, determined as of the first day of such period. The calculation of the Debt Service Coverage Ratio shall be made in accordance with Section 5.2 of this Agreement, except as may be otherwise provided in other Sections of this Agreement. "Debt Service Reserve Fundll means the Debt Service Reserve Fund created in Section 5.01 of the Indenture. "Debt Service Resen'e Requirement II means with respect to the Series 1999 Bonds. as of the date of any calculation. an amount equal to $ . In the event Additional Bonds are issued, the Debt Service Reserve Requirement, if any. with respect to those Additional Bonds shall be the lesser of (i) 10% of the proceeds of such Additional Bonds, (ii) the Maximum Principal and Interest Requirements on such Additional Bonds or (Hi) 125 % of the average Principal and Interest Requirements on such Additional Bonds. No such Additional Bonds shall be secured by the Debt Service Reserve Fund established for the Series 1999 Bonds. "Default" means any circumstance which. with the passage of time or the giving of notice or both. would constitute an "Evenr of Default" as detined in Section 7.1 of this Agreement or '7.01 of the Indenture, respectively. lIDefeasancc Obligations" means: (a) direct obligations of the United States of America (including obligations issued or held in book-entry form on the books of the Department of the Treasury of the United States of America). or obligations the timely payment of the principal of and interest on which is unconditionally guaranteed by the United States of America, (b) certificates which evidence ownership of the right to the payments of the principal of and interest on obligations described in clause (a) or in specified ponions thereof, including without limitation, portions consisting solely of the principal thereof or solely of the interest thereon, or (c) obligations of any state or any political subdivision of any state, otl1t~r lhan the Issuer, which are rated by a Rating Service in the highest category for long-term debt. the interest on which is excluded from gross income for federal income tax purposes and the full and timely payment of the principaJ of and any premium and the interest on which is unconditionally payable from obligations of the character described in (a) or (b) above. 6 91-lr ~ er, 1.':\'1:'1 , \ '. ....,.I "Disbursemcnt Rcquest" means a written order to the Trustee for disbursement from the Project Fund substantially in the form of Exhibit D attached to this Agreement. "Eligible Iuvestmcnts" mean (a) obligations issued or guaranteed as to full and timely payment by the United States of America or by any Person controJled or supervised by or acting as an instrumentality of the United States of America pursuant to authority granted by Congress; (b) obligations issued or guarantcc..>d by any state or political subdivision thereof, which obligations are rated in the highest category if rated as short therm obligations by a Rating Service; (c) commercial or finance paper which is rated in the highest fating category by a Rating Service; (d) deposit accounts, bankers' acceptances. certificates of deposit or bearer deposit notes in one or more banks or trust companies (including without limitation, the Trustee or any bank affiliated with the Trustee) organized under the laws of the United States of America or any state thereof. the senior debt obligations of which bank or trust company at the time of purchase of such instruments are rated in one of the three highest rating categories by a Rating Service or which instruments are secured by a security interest in obligations described in (a) above or which are fully insured by the FDIC; (e) any repurchase agreement: (i) with any bank, including the Trustee and its affiliates. or any broker-dealer with retail customers that falls under the protection of the Securities Investors Protection Corporation; (ii) which is secured by collateral of the type specified in (a) and (b) above which collateral (1) is in the possession of the Trustee or a third party acting solely as agent for the Trustee. (2) is not subject to any third party claims, and (3) has a market value (determined at least once every 14 days) at least equal to the amount invested in the repurchase agreement; and (iii) which permits the Trustee to liquidate the collateral immediately upon failure to maintain the collateral at the required level; or (f) money market funds invested solely in securities listed in (a) above; provided that any investment or deposit described above is not prohibited by applicable law. "Entrance Fees" shall mean the feesJ other than monthly service charges paid by the residents of the Mortgaged Property to the Company for the purpose of obtaining the right to reside in the Mortgaged Property, including any Refundable Resident Deposits described in. 7 9c/,,!'t ,r') Residency Agreements with respect to the Mortgaged Property t but shall not include any such amounts that are (i) escrowed pursuant to the requirements of Chapter 651 t Florida Statutes or any similar law unless and until such amounts are released from such escrow to the Company or (ii) escrows otherwise set aside pursuant to the requirements of any Residency Agreement prior to occupancy of the unit covered by such Residency Agreement (which amounts shall be included if and when such occupancy occurs). "Event of Default" means an Event of Default as defined in Section 7. 1 of this Agreement and in Section 7.01 of the Indenture. IIExcess Earc.ings" means, as to the Tax-Exempt Bonds of any issue as of each Computation Date for that issue. an amount determined in accordance with Section 148(t) of the Code equal to the sum of (a) plus (b) where: (a) Is the excess of (i) the aggregate amount earned from the date the Tax-Exempt Bonds are invested (other than investments attributable to an excess described in this Clause (a))~ taking into account any gain or loss on the disposition of nonpurpose investments. over -- . , (ii) the amount that would have been earned if the amount of the gross proceeds of the Tax-Exempt Bonds of such issue invested in those nonpurpose investments (other than investments attributable to an excess described in this clause (a)) had been invested at a rate equal to the yield on the Bonds; and .'..............' (b) any income attributable to the excess described in clause (a) above. taking into account any gain or loss on the disposition of investments. The foregoing sums shall be determined in accordance with Section 148(t) of the Code. As used herein, the terms "gross proceeds, to "nonpurpose obligationst. and "yield" have the meanings assigned to them for purposes of Section 148 of the Code. "Excluded Property" means the property described in Exhibit F of this Agreement, if any. "Exempt Person" means (i) any organization described in Section 501(c)(3) of the Code and exempt from taxes under Section 501(a) of the Code, and (ii) a "government unit" as that term is used in Sections 103 and 145 of the Code. "Existing Facilities" means the buildings. equipment and improvements located on the Project Site on the date of execution and delivery of this Agreement. " " <../ 8 99 -/?5 ~-) ,.'~""" '" ) ~_.,.s ~:.J "Extcndablcs Purchase Fund" means the Extendables Purchase Fund created pursuant to Section 4.10 of the Indenture. "FISCal Year" means, with rcspt.'Ct to the Company, the period commencing on 1 of each year and ending on the 30 of the following year or such other fiscal year as may hereafter be designated by the Company to the Trustee in writing. "Force Majeure" means any of the causes, circumstances or events described as constituting Force Majeure in Section 7.1 of this Agreement or Section 6.2 of the Mortgage. lIGoverlUllcntal Restrictions" means fl.-deral, State or other applicable governmental laws or regulations affecting the Company or its facilities and placing restrictions and limitations on the rates. fees and charges to be fixed, charged and collected by the Company or any other operator of the Companis facilities; provided. however. that no change in law or regulation shall be deemed applicable by reason of this detinition if such change would in any way constitute an impairment of the rights of the Issuer, a Holder. the Company or any other operator of the Mortgaged Property or the Trustee under this Agreement or the Indenture. "Holder" or "Holder of a Bond" means the person in whose name a bond is registered on the Register. "Immediate Notice" means notice by telephone, telegram. telex, telecopy or other telecommunication device, receipt of which has been contirmed by the recipient. promptly followed by written notice by overnight carrier or delivery service, expenses prepaid. to such addresses. "Indenture" means the Trust Indenture dated as of July 1. 1999 between the Issuer and the Trustee, as amended or supplemented from time to time. "Independent Counsel" means an attorney or finn of attorneys acceptable to the Company and duly admitted to practice law before the highest court of the State. "Initial Bondholders" "Initial Interest Rate" means, the interest rate applicable from the dated date of the Series 1999 Bonds to and including at the Initial Rate Change Date. "Initial Rate Change Date" means the fi rst date on which the Series 1999B Bonds change to another interest rate, which shall be [November 15. 20_].. "Insurance COllsultautll means a Person designated by the Authorized Company Representative. with written notice to the Trustee, who or which Insurance Consultant is (i) qualified to survey risks and to recommend insurance coverage for facilities comparable to the 9 11- It \ Mortgaged Property and for organizations engaged in operations similar to those of the Company, (ii) has a favorable reputation for skill and experience in making those surveys and recommendations, (Hi) has no interest, direct or indirect. in the Company other than payment for services' and (iv) in the case of an individual, is not a mcmbcr, director. trustee. ofticer or employee of the Company or, in the case of another Person, has no partner. member, director, trustee, officer or employee who is a member, director. trustee, officer or employee of the Company; provided that so long as the foregoing requirements are satisfied, the Insurance Consultant may be a broker or agent with whom the Company transacts business; and provided further that thc collection of reasonable fees for scrvices rendered docs not constitute an interest in the Company for this purpose. "Insurance Requirements" means all requirements respecting the Mortgaged Property, or any part thereof, imposed by any policies of insurance in force at any time wi~h respect to any of the buildings. improvements, machincry. furnishings or equipment constituting a pare of the Mortgaged Property. "Interest Payment ACCOWlt" shall mean the Interest Payment Account within the Bond Fund created in Section 5.01 of the Indenture. "Interest Payment Date" or "Interest PaJment Dates" means, as to the Series 1999 Bonds, the date or dates set forth as such in the form of Series 1999 Bond attached as Exhibit A to the Indenture, and as to Additional Bonds, each date or dates designated as an "Interest Payment Date" or "Interest Payment Dales" in the form of Bond for which provision is made in the applicable Supplemental Indenture. "Iuterest Rate for Advances" means the lesser of (i) the Prime Rate or (ii) the maximum interest rate permitted by applicable law. "Investor Letter" means the Investment Letter to be delivered by the purchaser of the Series 1999 Bonds to the Issuer and the Trustee substantially in the form attached as Exhibit B to the Indenture. "Issuance Expenses" means all costs and expenses payable by the Issuer which are incidental to the issuance of the Bonds and shall include. but not be limited to, fees and expenses of consultants, advisors. accountants, Bond Counsel and other legal counsel to the Issuer, costs and expenses of printing such Bonds and disclosure documents relating thereto, fees of bond rating services, charges for CUSIP numbers, charges of any clearing agent, charges of the Depository Trust Company C'DTC") and other securities depositories, charges payable to the Municipal Securities Rulemaking Board, Public Securities Association and wire services. charges for telephone, telegraph. telecopier, telex and fax services. postage and express charges. costs of federal funds, closing costs (including all legally permitted costs of travel, food and lodging of ofticials and employees of the Issuer incurred in connection with attending any closing or preclosing or any meeting relating to the issuance of the Bonds), any costs incurred in connection , I '--" 10 19 ~ I ~ '." . . .,.... ~ J: with the sale of the Bonds, including costs incurred in any public or negotiated sale thereof. and ) placement fees, costs of compliance with the St.'Curities laws of any state in which Bonds are to be offercd and sold, the initial fees of the Trustee. Registrar. Paying Agent and Authenticating Agent. and other similar expense: provided that the term shall not include any underwriter's discount which is takcn into account in the sale price (or any costs and expenses paid by the underwriter which are not to be reimbursed by the Issuer). "Issuer" means City of Clearwater Florida, a municipal corporation duly created and validly existing under the laws of the State of Florida including, particularly. the Act, and its successor public bodies. "Issuer Documents" means this Agreement, the Assignment and the Indenture. "Loan" means a loan by the Issuer to the Company of the proceeds received from the sale of Bonds. I "Loan Payment Date" means (i) the fifth Business Day immediately preceding the last day of each calendar month and (ii) the fifth Business Day immediately preceding the date on which any principal of or interest or any premium on the Bonds shall be due and payable, whether at maturity, upon acceleration. call for redemption or otherwise. "Loall Payments" means the amounts required to be paid by the Company in repayment ,~"-", of the Loan pursuant to Section 4. 1 of this Agreement. ,'"-"" "Long.Term Debt" means Debt having an original maturity greater than one year (including demand notes with alternative stated maturities of less than one year unless and until a demand for the payment thereof shaJI have been made) or renewable at the option of the obligor for a period greater than one year from the date of original incurrence or issuance thereof, which shall not include the current portion of such Long- Tenn Debt as detennined in accordance with generally accepted accounting principles. "Maximum Principal and Interest Requirement" means as to any Series of Bonds, the maximum Principal and Interest Requirement coming due on such Bonds in any Fiscal Year, provided that the Maximum Principal and Interest Requirement for any Long Term Debt shall be disregarded tor any period during which the interest on such Long Term Debt is funded from the proceeds thereof. "Net Proceeds," when used with respect to any insurance proceeds or condemnation award, means the gross proceeds thereof less the payment of all expenses. including attorneys' fees incurred in connection with the collection of such gross proceeds. UNotes" means the Scries 1999 Notes and any Additional Notcs. ',:.J 11 11j'lr J 8 "Notice Address" means (a) As to the Issuer: Margaret L. Simmons, CPA . Financial Services Administrator City of Clearwater, Florida I, 100 South Myrtle Avenue Clearwater, Florida 33758 copy to: Pamela Akin. Esq. . . City Attorney 112 South Osceola Avenue Clearwater. Florida , c (b) As to the Company: BEF, Inc. 1601 Jack Street, Suite 200 Fort Myers, Florida 33901 Attention: Gerard A. McHale, Jr. (c) As to the Trustee: SunTrust Bank. Central Florida, National Association 225 East Robinson Street, Suite 250 Orlando, Florida, 32801 ,~.... Attention: Corporate Trust Department '0 (d) As to the Remarketing Agent: B. C. Ziegler and Company 1 South Wacker Drive. Suite 3080 Chicago, Illinois 60606 Attention: President or such different address. notice of which is given under Section 8.3 of this Agreement or Section 12.03 of the Indenture. "Opinion of Bond Counsel" means an opinion in writing signed by a Bond Counsel satisfactory to the Trustee. "Opinion of CouIlSel" means an opinion in writing signed by an attorney or fion of attorneys not unsatisfactory to the Trustee, who may be counsel to the Company. "Optional Tender Date" means, with respect to the Series 1999B Bonds, each Rate Change Date. ::) 12 I'. Cj9-/~ ' -~-""-~-:"""""'-"'''''-'--- f.~-\ , .'-:--" \..) () "Outstanding Bonds, II "Bonds Outstanding" or "Outstanding" as applied to Bonds, mean, as of the applicable dale, all Bonds which have been authenticated and delivered. or which are being delivered by the Trustee under the Indenture, except: (a) Bonds cancelled upon surrender. exchange or transfer. or cancelled because of payment or redemption on or prior to that date; (b) Bonds, Of the portion thereof, for the payment, redemption or purchase for cancellation of which sufticient moneys have been deposited and credited with the Trustee or any Paying Agents on or prior to that date for that purpose (whether upon or prior to the maturity or redemption date of those Bonds); provided, that if any of those Bonds are to be redeemed prior to their maturity, notice of that redemption shall have been given or arrangements satisfactory to the Trustee shall have been made for giving notice of that redemption. or waiver by lhe affected Holders of that notice satisfactory in form to the Trustee shall have been tiled with the Trustee; (c) Bonds. or the portion thereof, which arc deemed to have been paid and discharged or caused to have been paid and discharged pursuant to the provisions of the Indenture; (d) Bonds in lieu of which others have been authenticated under Section 3.07 of the Indenture; and (e) Any Bond as to which an election to tender has been duly submitted and nol withdrawn and moneys are held in trust by the Tender Agent for the purpose of purchase of such Bond. "Parity Debt" means any obligation of the Company permitted to be incurred as Parity Debt in Section 5.5 of this Agreement. "Pa~tillg Agent" means any bank or trust company designated as a Paying Agent by or in accordance with Section 6.12 of the Indenture. "Pennitted Debt" means the liabilities, obligations and Debt penniued in Section 5.4 of this Agreement. "Pennitted Encumbrances" shall have the meaning assigned such term in Section 5.7 of this Agreement. . . "Person" or words importing persons, means firms, associations, partnerships (including without limitation. general and limited partnerships). joim vemures, societies. estates. trusts, corporations, public or governmental bodies, other legal entities and natural persons. 13 II I' I I i I i 19"1l( "Plans Hud Specifications" means the plans and specifications describing a project as prepared and on tile with the Trustee, as they may be changed from time to time. "Prime Rate" means that interest rate announced from time to time by the Trustee in its lending capacity as a bank as its tlprime rate" or IIbase rate. " . "Principal and Interest Requirements" means. for any period or date, as applied to any Debt means the sum of the principal of and premium, if any t and interest (determined for variable rate date at the highest rate payable on such date) on any Outstanding Debt accruing for that period or due and payable on that date; provided that for this purpose, the term Debt does not include indebtedness for which provision for payment has been made in accordance with the terms of the instruments evidencing or securing such indebtedness. In determining Principal and Interest Requirements accruing for any period or due and payable on any date. mandatory sinking fund requirements on any Debt for that period or on that date shall be included. and principal maturities and mandatory sinking fund requirements for a prior period Qr on a prior date shall be excluded. "Principal Payment Account" means the Principal Payment Account within the Bond Fund created in Section 5.01 of the Indenture. " "Private Business Use" means use, directly or indirectly (i) in a trade or business carried on by any Priva~e Person (other than a Tax-Exempt Organization) other than use as a member of, and on the same basis as. the general public. or (ij) in any activity carried on by a Tax-Exempt Organization (other than use as a member of. and on the same basis as. the general public) which is an "unrelated trade or business" activity within the meaning of Section 513 (a) of the Code. ~_..",,' "Private Person" means any person, firm, entity or individual, including a Tax-Exempt Organization other than a governmental unit as that term is used in Section 145 of the Code. "Project" means the capital improvements described in Exhibit B to this Agreement (and more particularly described in the Plans and Specifications related thereto), together with any additions. modifications and substitutions to those facilities, including all furnishings. machinery, equipment and other tangible personal property. "Project Budget" means the budget and trade and materials, breakdown and scheduled values for the Project. "Project Costsll has the meaning assigned such term in Section 3.4 of this Agreement. "Project Fund" means the Project Fund created in Section 5.01 of the Indenture. "Project Site" means [he real estate described in Exhibit C to this Agreemem. and any additions thereto, less any removals therefrom made in the manner permitted by this Agreement. --J 14 99' I ~ ...."'itt..~.':'~..:.~_:.::..:~~:~.~"_ ._, .._._u I) "Property" means any and all righls. title and interest of the Company in and to property (including cash and cash equivalents) whether real or personal, tangible or intangible and wherever situated. but excluding Excluded Property. "Rate Change Date" means, with respect to the Series 1999B Bonds, the Initial Rate Change Date and any rate change date selected by the Company pursuant to Section 2.03(b) of the Indenture. "Rate Period" means, with respect to the Series 1999B Bonds. the period commencing on each Rate Change Date and ending on and including the date preceding the next Rate Change Date. or the matu'rity date thereof. ' "Rating Service" means Fitch meA, Moody's Investors Service. Inc. or Standard & Poor's Ratings Services Group. each of New York, New York or their respective successors. "Rebate AmoWJt" means the amount of Excess Earnings computed as of the most recent prior Computation Date which are required to be paid to the United States of America under Section 148(f) of the Code. "Rebate Fund" means the Rebate Fund created in Section 5.01 of the Indenture. "Refunding Debt" means Debt incurred for the purpose of retinancing or refunding all o or any portion of any Outstanding Debt of the Company. "Register" means the books k~pt and maintained for the registration and transfer of Bonds pursuant (0 Section 3.06 of the Indenture. "Registrar" means the Trustee or such other bank, trust company or person as may be designated from time to time by the Issuer with the approval of the Company. "Regular Record Date" or "Record Date" means, with respect to any Bond. the last day (whether or not a Business Day) of the calendar month next preceding an Interest Payment Date applicable to that Bond. "Regulatory Body" means any federalm,state or local govenunent, department, agency, authority or instrumentality (other than the Issuer) and other public or private body, including accrediting organizations, having regulatory jurisdiction and authority over the Company or its facilities or operations. "Relllarketillg Agent" means the Remarkcting Agent appointed and serving a such pursuant to Section 4.15 of the Indenture, initially B.C. Ziegler and Company. \~ IS 19r-/'1 . " /~ ") ,~........ o "Remarkctillg Agreemcnt" means the Remarketing Agreement between the Company and the Remarketing Agent then serving under the Indenture. "Rcncwal and Rcplacement Fund" shall mean thc Rencwal and Replacemcnt Fund created under section 5.19 of this Agreement. "Reset Rate" means, with respect to the Series 1999 Bonds, the adjusted rate of interest born on the Series 1999B Bonds determined as provided in Section 2.03(b) of the Indenture. "Revenues" means all present and future revenues received by or on behalf of the Company from whatever source derived, including without limitation, all (a) Entrance Fees, cash, accounts, deposits, chattel paper, instruments, documents, money and general intangibles, including without limitation, contract rights and rights to payment (i) tor goods and properties sold or leased or tor services rendered. (ii) under agreements respecting governmental and private insurance arrangements, and (Hi) from any insurance. condemnation award or agreement in lieu of a condemnation award resulting from eminent domain proceedings. (b) income from, and revenues realized upon the liquidation or sale of, securities held by or on behalf of the Company. (c) proceeds of those items constituting Revcnues to which reference is made in clauses (a) and (b) above, and (d) gifts, grants, bequests, contributions and donations, including without limitation. the unrestricted income and profits therefrom, provided that Revenues do not include (i) gifts, grants, bequests, contributions and donations to the extent restricted specifically to a particular purpose inconsistent with their use for the making of payments into any of the Special Funds, (ii) the proceeds of any borrowing to the extent that those proceeds are required to be excluded from Revenues by the terms of the borrowing. . (Hi) the proceeds of non-recourse Debt secured by and payable solely from Property financed by such non-recourse Debt and all revenues derived from or attributable to Property financed with the proceeds of such non-recourse Debt, (iv) revenues derived from Excluded Property, or I I \ l J II I' I I i 16 11,/<6 .~'i~~~'~-~':~':""'-___... "1 ...,..:~ ,~....' ........ . < ..... o (v) amounts on deposit in the Operating Reserve. "Series 1999 Bonds" means collectively. the Series 1999A Bonds, the Series 1999B Bonds and the Series 1999C Bonds. "Series 1999A Bonds" means the $ Revenue Bonds, Series 1999A (BEF, Inc. Project). City of Clearwater, Florida "Series 1999B Bonds" means the $ City of Clearwater. Florida, Revenue Bonds. Series 1999B (BEF, Inc. Project), Extendable Rate Adjustable SecuritiesSM (EXTRASSM). "Series 1999C Bonds" means the $ Taxable Revenue Bonds, Series 1999C (BEF, Inc. Project). City of Clearwater. Florida "Series 1999 Note" means the non-negotiable promissory note of the Company in the aggregate principal amount of $ of even date with the Series 1999A Bonds, the Series 1999B Bonds and the Series 1999C Bonds, substantially in the form attached to this Agreement as Exhibit" A, tt executed and delivered by the Company to the Trustee in connection with the issuance of the Series 1999 Bonds. "Special Ftmds" means the Special Funds created pursuant to Section 5.01 of the Indenture. /.._\ other than the Rebate Fund. ........./ ,...) "Special Interest Payment Date" means the Special Interest Payment Dine created in Section 7.07(d) of the Indenture. "Special Record Date" means, with respect to any Bond, the date established by the Trustee in connection with the payment of overdue interest on that Bond pursuant to Section 3.05 of the Indenture. "State" means the State of Florida. "Supplemental Indenture" means any indenture supplemental to the Indenture entered into between the Issuer and the Trustee in accordance with Article VIII of the Indenture. "Taxable Bond" means any obligation, or issue of obligations which at the time of issuance under the Indenture is not intended to be a Tax-Exempt Bond. "Tax-Exempt Bond" means any obligation, or issue of obligations, the interest on which is, or is intended to be, excluded from gross income for federal income tax purposes within the meaning of Section 103 of the Code. 17 1C!'lr ...) "Tendcr Agcnt" means the Tender Agent referred to in Sections 4. to and 6.] 4 of the Indenture, which Tender agent shall initially be the Trustce, scrving as agcnt for Rcgistcred Owners of Put Option Bonds who shall have elected to tender such Bonds for purchase. "Tender Purcbase Price" shall have the meaning assigned in Section 4.09(a) of the Indenture. "Tcnder Withdrawal" shall have the meaning assigned in Section 4.11 of the Indenture. "Tenn Bonds" means~ with respect to the Series 1999 Bonds, those Series 1999 Bonds designated as Term Bonds in Section 2.03(a) of the Indenture. "Total Operating Revenucs" means, for any period. the sum of the Company's (a) operating revenues. less provision for uncollectible accounts, charity cases and any contractual adjustments, plus (b) all other operating revenues. "Trustee" means SunTrust Bank, Central Florida. National Association, a national banking association, Orlando. Florida, until a successor Trustee shall have become such pursuant to the applicable provisions of the Indenture, and thereafter "Trustee" shall mean the successor Trustee. '\ . ......J "Unassigned Rights" means the rights of the Issuer under this Agreement to (a) receive Additional Payments as contemplated in Section 4.2 of this Agreement; (b) to purchase the Project as contemplated by Section 4.7 of this Agreement; (c) to be held harmless and indemnitied under Scction 5.12 of this Agreement; (d) to exercise with the consent. but not to the exclusion, of the Trustee any remedies which are authorized to be exercised by the Issuer under this Agreement in connection with an Event of Default; (e) to be reimbursed, to the extent permitted by law, for attorney's fees and expenses under Section 7.4 of this Agreement; and (t) to execute amendments to this Agreement. "Ullremarl\:cted Bouds" shall have the meaning assigned in Section 4.10 of the Indenture. Section 1.2. Interpretation. Any reference herein to the Issuer, or to any member or officer of the Issuer, includes entities or officials succeeding to their respective functions, duties or responsibilities pursuant to or by operation of Jawor JawfuJJy performing their functions. Any reference to a section or provision of the Constitution of the State or the Act, or to a section, provision or chapter of the Florida StanJtes, as amended. or Laws of Florida~ includes that section, provision or chapter as amended, moditied. revised, supplemented or superseded from time to time; provided, that no amendment, modification. revision. supplement or superseding section, provision or chapter shall be applicable solely by reason of lhis provision, if it constitutes in any way an impairment of the rights or obligations of the Issuer, the Holders, the Trustee or the Company under this Agreement. , ' 'J 18 19 -- (~ ) I I I . " " .1....,.. , ,', ~ ':: r" I,' ." , } . ~ !". .......'I"j. :. . ::: . . .' ~. \,' ~ . . ,', .,~,' . , ,. " ;\.' ~: ':.1 ' u, . ',;".:".. . ,,' \., . : :. 'J '... ';: : " , '" . , ,-:) '. .".... .. l.~' j' ,..:;." : ,,~:~",} . " , \"-" . ,., . , '..'1-1. " . Unless the context indicates otherwise, the terms "hereof." "hereby," "herein,;' "hereto," "hereunder" and similar terms refer to this Agreement; and the term "hereafter" means after, and . . the term "heretoforet. means before. the date of delivery of the Series 1999 Bonds. Words of any gender include the correlative words of the other genders, unless the sense indicates otherwise. . Section 1.3.. Captions and Headine-s. The captions and headings in this Agreement are solely for convenience of reference and in no way define, limit or describe the scope or intent of any'articles. sections, subsections. paragraphs or subparagraphs or clauses hereof. (End of Article I) " 19 Cjtj,-/'r .. ~.~.~~.~~,.,lt;~'~;...,,,.t~\,,,:~'..t;...~.,~~..... .~. ~""'~-'4""'~jVi&,.~'J:.~.:~I'~.l' ~~-.i-{,.;..",." ,.". d., .......f".,..,~:.. '.I':i.~~,; , .';'.~,' I ~. ,< . > ..... "~~~r~~~~::::::.::~nd.:";'.', .,', " .~.-') ~...... , " l ~'-..-,,/ \ \.-J ARTICLE II REPRESENT A nONS Section 2.1. Representations ami Covenants of the Issuer. The Issuer represents that: (a) It is duly created and validly existing under the laws of the State; (b) It has duly accomplished all conditions necessary to be accomplished by it prior to the issuance and delivery of the Series 1999 Bonds and the execution and delivery of this Agreement and the Indenture; (c) It is not in violation of or in contliet with any provisions of the laws of the State which would impair its ability to carry out its obligations contained in this Agreement, the Mortgage or the Indenture; ~ ' (d) It is empowered (i) to enter into the transactions contemplated by this Agreement, the Mortgage and the Indenture and (ii) to issue, sell and deliver the Series 1999 Bonds as provided in the Indenture; (e) It has duly authorized the execution, delivery and performance of this Agreement, the Mortgage, the Assignment and the Indenture; and (t) Irwill do all things in its power in order to maintain its existence or assure lhe assumption of its obligations under this Agreement, the Mortgage and the Indenture by any successor public body. Section 2.2. and covenants that: Representations and Covenants of the Company. The Company represents (a) It is a not-for-protit corporation duly organized and validly existing under the laws of the State no part of the net earnings of which inure or may inure lawfully to the benefit of any member or private individual; (b) It has full power and authority to execute, deliver and perform this Agreement, the Mortgage, the Continuing Disclosure Certificate and the Series 1999 Note and to enter into and carry out the transactions contemplated by those documents. The execution, delivery and performance of said agreements do not, and will not, violate any provision of Jaw applicable to the Company or the Company t s Articles of Incorporation or Bylaws and do not. and will not, contlict with or result in a default under any agreement or instrument to which the Company is a party or by which it or any of its respective property is bound. This Agreement, the Mortgage. the Continuing Disclosure Certificate and the Series 1999 Note have, by proper action, been duly authorized, executed and delivered by the Company and all steps necessary have been taken to 20 99 ~ I~ '~ constitute this Agreement, the Mortgage. the Continuing Disclosure Certificate and the Series 1999 Note valid and binding obligations of the Company; (c) The Project will preserve existing employment and serve the health care needs of the , community; (d) The Project will be completed in accordance with the PJans and Specifications and the Project will be operated and maintained in such manner as to conform with all applicable zoning. planning. buildingt environmental and other applicable governmental regulations and as to be consistent with the Act~ . (e) It presently intends to use or operate the Project and the Existing Facilities of which it is a part as a continuing care retirement faciJity until the date on which the Bonds have been fully paid and knows of no reason why the Project and Existing Facilities will not be so operated. 1ft in the futuret there is a cessation of that operation. it will use its best efforts to resume that operation or accomplish an alternate use by the Company or others which will be consistent with the Act and the Code; ......-<+41fL.... (t) It is an organization described in Section 50l(c)(3) of the Code and has received a detennination letter from the Internal Revenue Service to such effect. which determination letter has not been adversely modified, Hmited or revoked. It has not been notitied by the Internal Revenue Service of, and has no knowledge of any facts or circumstances that would form the basis for the revocation of ilS status as an organization described in said Section of the Code. It has not taken and will not take any actions that would jeopardize its status as slIch organization; and I ........../ (g) It has obtained a certificate of need for all portions of the Project ror which a certificate of need is required under State law and has complied with all conditions and requirements of those certificates. Section 2.3 Tax Covenants of the Company. For so long as any Tax~Exempt Bonds (including, without Jimitation. the Series 1999 Bonds) remain outstanding the Company hereby covenants as follows: (a) It will comply with, and timely make or cause to be made all filings required by I all effective rules, rulings or ReguJations promulgated by the DeparUTIent of the Treasury or the Internal Revenue Service; (b) It wiff continue to conduct its operations in a manner that will result in its continuing to qualify as an organization described in Section 501(c)(3) of the Code including but not limited to the timely filing of all returns. reports and requests for determination with the Internal Revenue Service and the timely notitication of the Imernal Rcwnue Service of aU changes in its organization and putposes from the organization and purposes previously disclosed to the Internal Revenue Service; "'.) 21 1Cf--/~ -_..........-.. ~... -~. -. ~) (c) It will not divert any substantial part of its income for the purpose or purposes other than those for which it is organized and operated; (d) It will not use or invest the proceeds of the Series 1999 Bonds or any other amounts held by the Trustee under the Indenture or any investment earnings thereon in a manner that wiJI result in the Tax-Exempt Bonds becoming Itprivate activity bondslt (other than qualified 501(c)(3) bonds) within the meaning of Sections 141 and 145 of the Code; (e) It will not use or permit to be used more than five percent (5 %) of the proceeds of the Tax-Exempt Bonds (including any amounts used to pay costs associated with issuing such Tax- Exempt Bonds), including all investment income earned on such proceeds directly or indirectly. in any trade or business carried on by any person who is not an Exempt Person. For purposes of the preceding sentence, use of the proceeds by an organization described in Section 501(c)(3) of the Code with respect to an "unrelated trade or business." determined in accordance with Section 513(a) of the Code, does not constitute a use by an Exempt Person; (0 It will not use or permit the use of any portion of the proceeds of the Tax-Exempt Bonds. including all investment income earned on such proceeds prior to the Completion Date, directly or indirectly, to make or finance loans to persons, who are not a governmental unit or an organization described in Section 50l(c)(3) of the Code. For purposes of the preceding sentence. a loan to an organization described in Section 50l(c)(3) of the Code for use with respect to an "unrelated trade or business" , does not constitute a loan to such a unit or organization; ~:~) (g) It will not cause the Tax-Exempt Bonds to be treated as "federally guaranteedlt obligations for purpores of Section 149 of the Code. as may be modified in any applicable rules, rulings, policies, procedures. regulations or other official statements promulgated or proposed by the Department of the Treasury or the Internal Revenue Service with respect to "federally guaranteed" obligations described in Section 149 of the Code. For purposes of this paragraph, the Tax-Exempt Bonds shall be treated as "federally guaranteed" if (i) all or any portion of the principal or interest is or will be guaranteed directly or indirectly by the United States of America or any agency or instrumentality thereof, or (ii) 5% or more of the proceeds of the Tax-Exempt Bonds will be (A) used in making loans the payment of principal or interest with respect to which is to be guaranteed in whole or in part by the United States of America or any agency or instrumentality thereof, or (B) invested directly or indirectly in federally insured deposited or accounts, and (Hi) such guarantee is not described in Section 149(b) of the Code; (h) It shall do all things which are necessary in order to comply with the provisions of Section 148 of the Code, including but not limited to subsection (f) of said Section 148 of the Code, with respect to the Tax-Exempt Bonds. including but not limited to the following: (A) Consult with such counsel, cenitied public accounUmts and rebate compliance experts as shall be necessary to permit such compliance; ~ n C;Cf ; 1C6 >.......~'t.,"'_ :~.~:'_' ~.......:........._,-....................._._._.._ .._ .' (B) Keep such records of funds in its possession which constitute "gross proceeds" of the \ Tax~Exempt Bonds as detined in Section 1 48(t).ot' the Code and to direct the Trustee : to keep records of llmds and investments in the Trustee's possession which constitute such "gross proceeds" in order that int'ornlation Tll..-cessary for the calculation of rebate payments due to the United States of America may be calculated; (C) Make or cause certified public accountants or rebate compliance experts to make such calculations at the times and in the manner required by Section 148(f) of the Code and the Indenture and otherwise comply with Section 5.05, 5.06 and 5.07 of the Indenture; (0) File or cause to be tiled copies of all rebate calculations with the Trustee; (E) Prepare or cause to be prepan..>d such reports. retums or statements as may be required to be tiled from time to time with the Imernal Revenue Service or the United States of America pursuant to the provisions of Section 148(f) of the Code, and execute any such reports. returns or statements as it is required to execute, direct the Trustee to execute any such reports, returns or statements as the Trustee may be required to execute and direct the Issuer to execute such reports, returns or statements as the Issuer may be required to execute; I' (F) Timely file or cause to be filed such reports, returns and statements as are required :"-..) to be tiled with the [nlernal Revenue Service or the United States of America: '-l"r.t..v.J (G) Provide or cause to be provided to the Trustee for deposit in the Rebate Fund moneys which are sufficient to pay when due all rebate payments with respect to the Tax-Exempt Bonds required to be paid by Section 148(t) of the Code; , (H) Direct the Trustee to pay from the Rebate Fund all rebate payments due at the times required by Section .148(f) of the Code; (I) Payor cause to be paid to the Trustee, for deposit in the Rebate Fund, and direct the Trustee to pay from the Rebate Fund dircctly to the Internal Revenue Service or the . United States of America. as appropriate. any amounts required to be paid to correct any errors made in the calculation in payment of rebate, including any arrearages of rebate, interest thereon or penalties attributable thereto which are required to be paid in order to cause the Tax-Exempt Bonds to comply. to have complied, or to continue to comply with the provisions of Section 148(f) of the Code; and (1) Invest any funds in its possession which ~onstitute rtgross proceeds" of the Tax-Exempt Bonds (within the meaning of S~tion 148(0 of the Code) in such manner as will not cause the TaxwExempt Bonds to become "arbitrage bondstl within the meaning of Section 148 of the Code. As to funds held by the Trustee, it shall direct V 23 q1-/~ I~k~t.:.,;...,~"~_~ r--", l investments to be made by the Trustee in such manner as shall not cause the Tax-Exempt Bonds to become "arbitrage bonds." The Company shall keep records of the investment of "gross proceeds" of the Tax-Exempt Bonds and shall direct the Trustee as to the keeping of records of invcstmeI1ls of "gross proceeds~' of the Tax-Exempt held by the Trustee in a manner which reflects the information necessary in order to permit the Company or its accountants or other arbitrage and rebate compliance experts to make calculations as to the yield on such investments and as necessary to calculate the Issuer's rebate obligation with respect to the Tax-Exempt Bonds. The Company shall comply with its representations set forth in the Arbitrage Rebate Agreement which shall be included in the transcript for the Tax-Exempt Bonds and shall. as necessary, consult with Bond Counsel, its certified public accountants and arbitrage and rebate expertS to the extent necessary to assure compliance with the provisions of this Section of this Agreement. With respect to the invesuTIent of any "gross proceedsu of the Tax-Exempt Bonds, made by the Company or made by the Trustee at the direction of the Company, the Company will not make, or enter into any agreement to make or direct the Trustee to make, a "prohibited payment" (as that term is used for purposes of Section 148 of the Code). .....,.~. The Company through the Authorized Company Representative, may eject to make calculations and cause rebates to be paid more frequently than required under Section 148(0 of the Code. However, it shall only be required to make calculations and pay rebate at the times required to achieve such compliance. Whenever such calculations are made, the Company shall payor cause to be paid to the Trustee for deposit in the Rebate Fund an amount sufficient to cause the balance in the Rebate Fund to cquallhe Issuer's accrued but unpaid rebate liability as calculated through the most recent calculation date. If the Company's certified public accountants require its financial statements to reflect the estimated rebate obligation as an accrued liability, the Company shall cause to be deposited wjth the Trustee for deposit in the Rebate Fund an amount equal ,0 such estimated accrued rebate liability. Except for the Company's right under the Indenture to receive excess moneys in the Rebate Fund, the Company shalt have no right, title or interest in moneys in the Rebate Fund which are to be held under the Indenture for the benefit of the federal . government of the United States of America. (i) The net proceeds of the Tax-Exempt Bonds and any investment earnings thereon shall be applied solely for the purposes set torth in this Agreement and in the Indenture and no amount of net proceeds of the Tax-Exempt Bonds in excess of two percent (2 %) of the lesser of (A) the aggregate face amount of the Tax-Exempt Bonds or (B) the proceeds of the TaxwExempt Bonds will be expended to pay the costs of issuing such issue of the Tax-Exempt Bonds, as required by Section 147(g) of the Code. (j) It will not use or invest the proceeds of the Tax-Exempt Bonds or any other amounts held by the Trustee under the Indenture or any invcstmcnt earnings thereon in a manner that will violate the provisions of Section 149(d)(3) or (4) of the Code; , \ V 24 11''*'lrt' ') , , ''--'"' u (k) The average maturity of the Tax-Exempt Bonds will not exceed one hundred twenty percent (120%) of the reasonably expectcd economic life of any property the cost of which was financed or refinanced with the net proceeds of the Tax-Exempt Bonds. taking into account the respective cost of t:ach itcm comprising such property which was tinanced with the net proceeds of the Tax-Exempt Bonds. For purposes of the preceding sentence, the reasonably expected economic lite of each item of property shall be determined as of the later of (i) the date on which the Tax-Exempt Bonds are issued or (ii) the date(s) on which such item of Project property is placed in service (or expected to be placed in service). In addition, land shall not be taken into account in dett.mnining the reasonably expected economic life of such property, except that, in the event twenty-five percent (25%) or more of the proceeds of the Tax-Exempt Bonds have been expended for land, such land shall be treated as having an economic life of thirty (30) years and shall be taken into account for purposes of determining the reasonably expected economic life of such property; (I) No amount of the proceeds of the Tax-Exempt Bonds will be used, directly or indirectly, to provide any airplane, sky-box or other private luxury box, facility primarily used for gambling, store the principal business of which is the sale of alcoholic beverages for consumption off premises or health club facility (except a health club facility related to the Section 501(c)(3) exempt purposes of the Company); and (m) It will comply with the information reponing requirements of Section 149(e)(2) of the Code; (n) Proceeds of the Tax-Exempt Bonds not in excess of the lesser of: (A) 10% of the proceeds of the Tax-Exempt Bonds; or (8) 125% of average annual debt service on the Tax-Exempt Bonds; or (C) 100% of the maximum annual debt service on the Tax-Exempt Bonds, shall be used to fund a reasonably required rcserve or replacement fund described in Section 148(d) of the Code; for purposes of (B) and (C) of this subsection (0) average annual debt service and maximum annual debt service on any variable rate Tax-Exempt Bonds shall be determined as if such Series 1999 Bonds were issued bearing interest at a fixed rate equal to the fixed interest rate at which such Series 1999 Bonds could have been sold on the date of sale; (0) All of the property to be acquired with proceeds of the Tax-Exempt Bonds or investment income therein shall be owned by an Exempt Person, as requircd by Section 145(a) of the Code; (p) No other governmental obligalions shall be issued within fifteen (15) days of the Series 1999 Bonds pursuant to a common plan of financing or marketing with the Series 1999 Bonds that will be paid out of substantially the same source of funds (or will havc substantially the same claim to be paid out of substantially the same source of funds) as the Series 1999 Bonds; (q) At the time any issue of Tax~Exempt Bonds is issued. the principal amount of such. Tax-Exempt Bonds plus the principal amount of outstanding tax excmpt non-hospital bonds I I II I' Ii , 2S 1t(;,/~ ~.". ,'. ,..-~\ I ~ ........ . i ....-... o ..,.,t>i.:..;.v.,,,,,:",,,,"'-' ..,...~.. allocated to any Section 501(c)(3) organization which is or will be a test-period beneficiary (as such term is used in Section 145(b) of the Code) of the Tax-Exempt Bonds does not and will not exceed $150.000,000 for purposes of Section 145(b) of the Code; (r) The intonnation to be furnished by the Company and used by the Issuer in preparing the certification pursuant to Section 148 of the Code and information statement (Form 8038) pursuant to Section 149(e) of the Code. is accurate and complete as of the date of the issuance of the Tax-Exempt Bonds: and (s) It will requiret in connection with any lease or grant by the Company of the use of any portion of the Project, that the lessee. sublessee, manager or other user of any portion of the Project shall not violate the covenants set forth in this section and use that portion of the Project in any manner which would violate the covenants set forth in this section; The tenns "Bond Year." "debt service." "gross proceeds, II IIhigher yielding investments." "net proceeds," "proceeds," and "yield" have the meanings assigned to them for purposes of Section 148 of the Code. .Section 2.4. Use of Project. Except to the extent permitted by paragraph (e) of Section 2.3. the Company will not use the Project or suffer or permit the Project to be used (i) in an ttunrelated trade or business" as detined in Section 513(a) of the Code or (ii) directly or indirectly for a Private Business Use by any Private Person unless such arrangement is pursuant to a contract that satisfies the criteria of the Code. (End of Article II) 26 I t I I I I I, I. I qq~/~ ,. 'I. , .~. > '. , 'r. '. ~ ~ " . " ".H,' - ,"-" , .....-/ "\ <-' ARTICLE III COMPLETION OF THE PROJECT; ISSUANCE OF THE SERIES 1999 BONDS Section 3.1. Acquisition. Construction. Installation. Equipment and Improvement. The Company (a) is acquiring and/or refinancing the Project in conjunction with the issuance of the Series 1999 Bonds and shall improve and renovate that portion of the Project consisting of the Core Building on the Project Site with all reasonable dispatch and in accordance with the Plans and Specifications, (b) shall pay when due all fees, costs and expenses incurred in connection therewith from funds made available therefor in accordance with this Agreement or otherwise. and (c) shall ask, demand, sue tor, levy. recover and receive all those sums of money. debts and other demands whatsoever which may be due, owing and payable under the terms of any contract. order, receipt, writing and instruction in connection therewith and shall enforce the provisions of any contract, agreement, obligation. bond or other performance security wilh respect thereto. It is understood that the Project is that of the Company and any contracts made by the Company with respect thereto, whether acquisition contracts, construction contracts or otherwise, or any work to be done by the Company on the Project are made or done by the Company in its own behalf and not as agent or contractor for the Issuer. Section 3.2. Plans and SpeciticatioDs. The Company may revise the Plans and Specitications from time to time. provided that no revision shall be made which would cause the Project not to be a "project" as defined in the Act or which would cause interest on the Bonds to re or to become included in the gross income of the Holder for federal income tax purposes. The Company will provide revised Plans and Specitications to the Trustee, at its Notice Address, within 30 days of any such revisions. Section 3.3. Issuance of the Series 1999 Bonds: Application of Proceeds: Company EQuity. (a) To provide funds to make the Loan for purposes of assisting in paying the Project Costs, the Issuer wm issue, sell and deliver the Series] 999 Bonds. The Series 1999 Bonds will be issued pursuant to the Indenture in the aggregate principal amount, will bear interest, will mature and will be subject to redemption as set forth therein. The Company hereby approves the terms and conditions of the Indenture and the Series 1999 Bonds, and the terms and conditions under which the Series 1999 Bonds will be issued, sold and delivered. The proceeds from the sale of the Series 1999 Bonds shall be paid to the Trustee and deposited as follows: A sum equal to any accrued interest shall be deposited in the Interest Payment Account. A sum equal to $ shall be deposited in the Debt Service Reserve Fund. The balance of the proceeds shall be deposited in the Project Fund. 27 99~ I~ ....""". ! (b) Pending disbursement pursuant to S~ction 3.4 h~reof, the proceeds so deposited in the Project Fund. together with any invCslment earnings thereon, shall constitute a part of the Revenues assigned by the Issuer to the payment of Debt Service Charges as provided in the Indenture. I I I I , , , Section 3.4. Disbursement's from the Proiect Fund. Subject to the provisions of Sections 2.3 and 2.4 above, and subject to the provisions set forth below. disbursements from the Project Fund shall be made only to reimburse or pay the Company, or any person designatcd by the Company. for the tollowing costs (collectively, the "Proj~ct Costs") to th~ extent set forth in the Project Budget: (a) costs incurred directly or indirectly tor or in connection with the acquiring, renovating or improving of real and personal property comprising the Project, including costs incurred in respect of the Project tor preliminary planning and studies; architcctural, legal. engineering, accounting, consulting. supervisory and other services; labor, scrvices and matcrials; and recording of documents and title work; (b) premiums attributable to any surety bonds and insurance required to be taken out and maintained during the construction period with respect to the Project Site and the Project Facilities; " (c) taxes, assessments and other governmental charges in respect of the Project that may become due and payable during the construction period; 1 "--./' (d) costs incurred directly or indirectly in seeking to enforce any remedy against any contractor or subcontractor in respcct of any actual or claimed default under any contract relating to the Project; (e) financial, legal, accounting, printing and engraving fees. charges and expenses, and all other such fees, charges and expenses incurred in connection with the authorization. sale. issuance and delivery of the Series 1999 Bonds, including. without limitation, the fees and expenses of the Trustee. the Registrar, the Authenticating Agent and any paying agent properly incurred under the Indenture, provided that the costs of issuance of the Series 1999 Bonds financed by the Tax-Exempt Bonds shall not exceed two percent (2 %) of the proceeds of the Tax-Exempt Bonds within the meaning of Section 147(g) of the Code and Treasury Regulations Section 1. 150- 1: for purposes hereof, "proceeds" means the issue price of the Tax-Exempt Bonds less accrued interest; (t) any othcr costs, expenses, fees and charges properly chargeable, under the Act, to the cost of the Project; and (g) intcrest on the Series 1999 Bonds. () 28 ' tfI-;r ''J Providedt no funds shalt be disbursed for rehabilitation of the Project to be completed by th~ Company as part of the Project until th~ Company delivers to th~ Trustee (i) an executed construction contract in a form and contcnt acceptable to the Company and for a guaranteed maximum price acceptable to the Company; and (ii) a payment and performance bond in a form and content and issued by a company acceptable to the Company. Any disbursements from any account within the Project Fund for the payment of Project Costs shall be made by the Trustee only upon the written order of the Authorized Company Representative accompanied by a ccrtificate of the Architect on standard AlA Forms G702 or G703 contirmingt among other things. the percentage of completion of the Project. Each such written order shall be in substantially the form of the disbursement request attached hereto as Exhibit D and shall be consecutively numbered and accompanied by invoices or other appropriate documentation supporting the payments or reimbursements requested. The Authorized Company Representative also shall provide the Truslce with either appropriate mechanicst lien aftidavits or waivers from each payee under each such wriuen order or with evidence or documentation satisfactory to the Trustee that provision against the filing of any mechanics' or similar liens with respect to the payment being made has been taken by the Company by deposit or bonding. In case any contract or the mechanics lien law of the State provides for the retention by the Company of a portion of the contract price. there shall be paid from the Project Fund only the net amount remaining after deduction of any such portion. and only when that retained amount is due and payable may it be paid from the Project Fund. 'r_..' Any moneys in the Project Fund remaining after the Completion Date and payment. or provision for payment, in full of the Project Costst at the direction of the Authorized Company Representative, promptly shall be (i) used to acquiret constructt install, equip and improve such additional real or personal property in connection with the Project as is designated by the Authorized Company Representative and the acquisition, renovation and improvement of which will be such as is permitted under the Act and provided that any such direction shall be accompanied by a representation of the Company, by an Authorized Company Representative, and such other evidence deemed reasonably necessary and satisfactory to the Trustee that the average reasonably expected economic life of any such additional property, together with other properly theretofore acquired with the proceeds of the Series 1999 Bonds, will not be less than 5/6ths of the average maturity of the Series 1999 Bonds; (ii) used for the purchase of Series 1999 Bonds in the open market for the purpose of cancellation at prices not exceeding the face value thereof plus accrued interest thereon to the date of payment therefor; (iii) paid into the Bond Fund to bc applied to the redemption of the Series 1999 Bonds; or . '0 29 I I I 'I 9f~/e' ,'.-) (iv) a combination of the foregoing as is provided in such direction. In all such cases, any payments made pursuant to this paragraph shall be made only to the extent that such use or application will not. in the opinion of Bond Counsel. cause the interest on the Tax-Exempt Bonds to be includible in the gross income of the Holders for federal income tax purposes. Section 3.5. Compaoy Required to Pay Costs in Event Project Fund Insufficient. If moneys in the Project Fund are not sufticient to pay all Project Costs, the Company nonetheless will complete the Project in accordance with the Plans and Specifications and, unless Additional Bonds shall have been issued for that purpose, shall pay all such additional Project Costs from its own funds. The Company shall pay all costs of issuing the Series 1999 Bonds to the extent those costs exceed the limitation imposed by Section 147(g) of the Code. The Company shall not be entitled to any reimbursement for any such additional Project Costs or payment of issuance costs from the Issuer, the Trustee or any Holder; nor shall it be entitled to any abatement, diminution or postponement of the Loan Payments. Section 3.6. Completion Date. The Company shall notify the Issuer and the Trustee of the Completion Date by a cenificate signed by the Authorized Company Representative stating: (a) The date on which the rehabilitation of the Project was substantially completed. I , ......--/ (b) That all other facilities necessary in connection with the Project have been acquired, renovated and improved. (c) That the Project confonns with all applicable zoning, planning, building, environmental and other similar governmental regulations, (d) That all Project Costs then or theretofore due and payable have been paid, and (e) The amounts which the Trustee shall retain in the Project Fund for the payment of Project Costs not yet due or for liabilities which the Company is contesting or which otherwise should be retained and the reasons such amounts should be retained. Such Certificate shall be accompanied by a final certificate of the Architect. The certificate may state that it is given without prejudice to any rights against third parties which then exist or subsequently may come into being. The Authorized Company Representative shall include with such certificate a statement specifically describing all items of personal property comprising a part of the Project. The certificate shall be delivered as promptly as practicable after the occurrence of the events and conditions referred to in subsections (a) through (d) of this Section. (..J 30 c;r ~ /~ ~'II-~. ~ . ~...' i~ .,~. ..-:. '-, . '. ..~~~. I' j, I"' 4 ~ .:.~\ , ~ .'-....,/ .\, :':.'0 L. , ,. The Owner shall, as a condition to final disbursement from the Project Fund for Project Costs, deliver to the Trustee (a) final lien waivers, contractor aftidavits, and other documentation required by the construction lien laws of the State and an as-completed survey of the Project Section 3.7. Investment of Fund Moneys. At the oral request, promptly confirmed in writing, of the Authorized Company Representative. any moneys held as part of the Bond Fund. the Project Fund. the Reserve Fund or the Rebate Fund shall be invested or reinvested by the Trustee in Eligible Investments. Section 3.8 Additional Bonds. At the request of the Company and for the purposes and upon fulfillment of the conditions specified in the Indenture. the Issuer may (but shall not be required to) provide tor the issuance, sale and delivery of Additional Bonds and loan the proceeds from the sale thereof to the Company and the Company shall execute and deliver one or more Additional Notes and supplements hereto as provided in Section 4.1 hereof. (End of Article HI) 31 I I I , I I, .1 I' 99 ~ /g' ol~UA~'~II"--:-"""~~~ _.0..0 _. ._____......_.....____..______.. .'.. '.'1._. . h, I ,- . . .--..------- ARTICLE IV 1 , LOAN BY ISSUER; REPAYMENT OF THE LOAN; LOAN PAYMENTS AND ADDITIONAL PA YMENTS Section 4.1. Loan Repayment: Delivery of Notes and Mortiaie. Upon the terms and conditions of this Agreement. the Issuer will make Loans to the Company. In consideration of and in repayment of the Loans, the Company shall make. as Loan Payments. payments which correspond, as to amount, to the Debt Service Charges payable on each series of Bonds. All such Loan Payments shall be paid to the Trustee in accordance with the terms of the Series 1999 Note and any Additional Notes for the account of the Issuer and shall be hdd and disbursed in accordance with the provisions of the Indenture and this Agrt.'Cment for application to the payment of Debt Service Charges. I ! , The Company agrees to repay the Loans by paying to the Trustee on or before the twenty~fifth day of each calendar month afld such other day upon which other payments may be required under the tenns of this Agreement or the Indenture (a "Loan Payment Date"), in federal or other funds immediately available on such date, the sum which, together with any moneys on deposit in the Bond Fund available for such purpose. is sufficient to pay the following amounts: ....._~...4 (a) commencing November 15, 1999, not less than the approximate equal monthly amount necessary, together with the moneys on deposit in the Interest Payment Account (or the respective subaccount in the Project Fund with respect to Capitalized Interest) and available for that purpose on that date, to pay in full the interest due on the Bonds on the next succeeding Interest Payment Date; .""") (b) commencing twelve (12) months prior to the first calendar month in which any principal is due on the Bonds, not less than the approximate equal monthly amount necessary to pay in fuIl the principal of the Bonds that will become due and payable on the next succeeding principal payment date (whether by payment at stated maturity Of by mandatory sinking fund redemption); less (1) in each case, the moneys on deposit in the Principal Payment Account and available for that purpose on that date. and (2) in the case of redemption pursuant to the mandatory redemption requirements described in Section 4.02 of the Indenture, the amount, if any, of credit described in Section 4.02 of the Indenture; which amounts required to be deposited into the Bond Fund may be deposited in the form of either or both money or Eligible Investments of those maturities which will be sufticient without further investment or reinvestment to produce the amounts required to be on deposit at least five days prior to the first day of the succeeding month; and --.-" 32 99"'/~ "'-- '-) Additionally. the Company shall also pay the sum which, togcther with any moneys on deposit in the Bond Fund available for such purpose is sufticient to pay the following amounts: (w) any amount due in connection with a redemption of Series 1999 Bonds (other than a mandatory sinking fund redemption), such that the Trustee receives such funds not later than 45 days prior to the redemption date; (x) (i) in any month in which the amount on deposit in the Debt Service Reserve Fund falls below the Debt Service Reserve Requircment becausc moneys are transferred from the Debt Service Reserve Fund to the Bond Fund to make up a deticiency in the Bond Fund (as permitted under the provisions of Section 5.06 of the Indenture), not less than one-twelfth (l112th) of the amount so transferred until the balance in the Debt Service Reserve Fund equals the Debt Service Reserve Requirement. and (ii) on or prior to each Loan Payment Date. beginning in the month foHowing the month in which the Company receives notice pursuant to Section 5.11 of the Indenture that the balance in the Debt Service Reserve Fund is below an amount equal to ninety percent (90%) of the Debt Service Reserve Requirement. an amount not Jess than one-fourth of the deficiency detennined pursuant to Section 5.11 of the Indenture until the balance in the Debt Service Reserve Fund equals the Debt Service Reserve Requirement; ~"''') -.,..., (y) Any amount due the Trustee. the Paying Agent. the Registrar, the Authenticating Agent, or the Tender Agent which shalJ have then accrued and become payable; and (z) any other amounts which will become due and payable under this Agreement or the Indenture including any amount which may be necessary to make up any previous deficiency in any of the payments described above and to make up any deticiency or loss in the respective funds or accounts to which payments are required lO be made. The Company shall be entitled to a credit against the Loan Payments next required to be made to the extent that the balance of the Bond Fund is then in excess of amounts required (a) for the payment of Bonds theretofore matured (or principal thereof which has become due and payable) or theretofore caJled tor redemption, (b) for the payment of interest for which checks or drafts have been drawn and mailed by the Tmstee, and (c) to be deposited in the Bond Fund by the Indenture for use other than for the payment of Debt Service Charges on the Interest Payment Date next following the applicable Loan Payment Date. In any event, however, that if on one Business Day prior to any Interest Payment Date or any other date on which any Debt Service Charges shall be due and payable. the balance in the Bond Fund is insufticient to make required payments of Debt Service Charges, the Company 10rthwith will pay lO the Trustee, tor the account of the Issuer and for deposit into the Bond Fund, any such deficiency. ,.J 33 99,-lfI ') , The Company's obligations under the Notes and this Agreement shall be secured by the Mortgage. To secure the Company!:, performance of its obligation under this Agreement and the Series 1999 Note. concurrently with the issuance and del ivery of the Series 1999 Bonds and the Series 1999 Note. the Company shall execute the Mortgage and deliver the same to the Issuer. The Issuer shall, upon the Company's execution and delivery of the Mortgage, execute the Assignment and deliver same to the Trustee. In connection with the issuance of any Additional Bonds. the Company shall execute and deliver to the Trustee one or more Additional Notes in a form substantially similar to the form of the Series 1999 Note together with a supplement hereto. providing, among other things for the use of the proceeds of such Additional Bonds. All such Additional Notes shall: (a) Provide for payments of interest equal to the payments of interest on the corresponding Additional Bonds; (b) Require payments of principal and n..-demption payments and any premium equal to the payments of principal, prepayments and sinking fund payments and any premium on the corresponding Additional Bonds; (c) Require all payments on any such Additional Notes to be made no later than one business day prior to the due dates tor the corresponding payments of Debt Service Charges 10 be made on the corresponding Additional Bonds; and ''"; '......._r". (d) Contain by reference or otherwise optional and mandatory redemption provisions and provisions in respect cf the optional and mandatory acceleration or prepayment of principal and any premium corresponding with the redemption and acceleration provisions of the corresponding Additional Bonds. All Notes shall secure equally and ratably all Outstanding Bonds. except that, so long as no Event of Default has occurred and is subsisting hereunder, payments by the Company on any of the Notes shall be used by the Trustee to make a like payment of Debt Service Charges on the corresponding Bonds in connection with which those Notes were delivered and shall constitute Loan Payments 'made in respect of the related Bonds. Upon payment in full, in accordance with the Indenture. of the Debt Service Charges on any or all series of Bonds, whether at maturity or by redemption or otherwise. or upon provision for the payment thereof having been made in accordance with the provisions of the Indenture, (i) the Notes issued concurrently with such corresponding Bonds of the same maturity. bearing the same interest rate and in an amount equal to the aggregate principal amount of the Bonds so surrendered and cancelled or for the payment of which provision has been made. shall be deemed fully paid, the obligations of the Company thereunder shall be terminated, and any of those NQ[es shaH be surrendered by the Trustee to the Company, and shall be cancelled by the Company, or (ii) in the event there is only one Note, an appropriate notation shall be endorsed thereon evidencing the date 'J 34 f9-/~ r_____ I and amount of the principal paymcnt or prepaymcnt equal to the Bonds so paid. or with respect to which provision tor payment has I)(.~cn made, and that Note shaH be surrendered by the Trustee to the Company for cancellation if all Bonds shall have been paid (or provision made therefor) and canceflcd as aforesaid. Unless the Company is emirled to a credit under express terms of this Agreement or the Notes, all payments on each of the Notes shall be in the full amount required thereunder. Except for such interest of the Company as may hereafter arise pursuant to Section 8.2 hcreof or Section 5.09 of the Indenture, the Company and the Issuer each acknowledge that neither the Company nor the Issuer has any interest in the Bond Fund and any moneys deposited therein shall be in the cuslOdy of and held by the Trustee in trust for the benefit of the Holders. Section 4.2. Additional Payments. (a) The Company shall pay [Q the Issuer, as Additional Payments hereunder, any and all costs and expenses incurred or to be paid by the Issuer in connection with the issuance and delivery of the Series 1999 Bonds and Additional Bonds, any indemnification due from the Company to the Issuer or otherwise related to actions taken by the Issuer under this Agreement or the Indenture. < ......... \ I ""'.-/ (b) The Company shall pay to the Trustee. the Registrar. the Paying Agent, the Authenticating Agent and the Tender Agent, as Additional Payments their reasonable fees, charges and expenses for acting as such under the [tldenture and any indemnitication due the Trustee, the Registrar, the Paying Agent, the Authenticaling Agent and the Tender Agent from the Company. Section 4.3. Place of Payments. The Company shall make all Loan Payments directly to the Trustce at its corporate trust officc. Additional Payments shall be made directly to the person or entity to whom or to which they are due. Section 4.4. Obligations Unconditional. The obligations of the Company to make Loan Payments and Additional Payments shall be absolute and unconditional, and the Company shall make such payments without abatement, diminution or deduction regardless of any cause or circumstances whatsoever including, without limitation, any defense, set-off, recoupment or counterclaim which the Company may have or assert against the Issuer, the Trustee or any other Person. Section 4.5. Assi~nment of Agreement and Revenues. To secure the payment of Debt Service Charges, the Issuer shall assign. by [he lndemure, its rights under and interest in this Agrcement (except for the Unassigned Rights) and the Revenues to the Trustee. The Company hereby agrees and consents to those assignments. Section 4.6. Application of Cenain Moneys. Any amount deposited in the Bond Fund pursuant to Section 4.4, 5.2 or 5.3 of the Mortgage shall be used. to the cxtent practicable at the .J 35 Cf!-/8:' ; . '/ oI-~.', . .~ \ c ';.0 ,.. I , -':'(. " .,' , ..') .'~ I 1:. ,. , I !' . - .,~~ . 'direction of the Company. for the purchase of Bonds in the open market for purposes of cancellation or tor the n.-demption of Bonds within one year of rl.'Ccipt of that amount, jf permitted pursuant to the extraordinary optional redemption provisions in Section 4.03 of the Indenture. If, in the opinion of the Trustee. that is not practicable or there is any balance remaining after that appJication, the remaining amount shall be credited against the portion of the next succeeding Loan. Payment as represents the payment of principal of the Bonds to become due and payable on ..the applicable Interest Payment Date. Section 4.7 Issuer' s Riehl of Purchase. The Issuer I during any period the Series 1999 Bonds are Outstanding, shall have the right, but not the obligation, to purchase the Cove Building fol1owing an Event of Default hereunder by paying the Outstanding principal amount of the Series 1999 Bonds. In either such event, prior to such purchase, the Issuer shall deliver written notice. of its election to purchase the Cove Building. . (End of Article IV) 36 r'l~ I~ ARTICLE V ') ADDITIONAL AGREEMENTS AND COVENANTS Section 5.1. Pled2e of Revenues. Security Interest and Transfer of Intangibles. To secure the prompt payment of all Loan Payments, Additional Payments and other amounts payable, and the observance and performance by the Company of all of its covenants, agreemcnts and obligations under this Agreement, and to protect the prompt payment of any Parity Debt, the Company assigns hereby to the Issuer, grants hereby to the Issuer to the eXlent permitted by law or. the date hereof, and covenants, agrees and acknowledges that subject to Permitted Encumbrances thc Issuer has and shall continue to have an assignment of and a first lien security interest in all Revenues. That assignment and the grant of that security interest are and shall be on a parity with any assignment made or security imerest granted by the Company as contemplated in this SeGtion. subject to the provisions of Sections 5.4 and 5.5 hereof and Section 2.7 of the Mortgage. The Company will execute and cause to be delivered any instruments or documents which may be necessary or reasonably requested by the Trustee to perfect or maintain, to the extent pennitted by law on the date hereof, that assignment and security interest or to give public notice thereof. The Trustee may obtain and rely upon advise of Company counsel in determining what actions and instruments are necessary under this paragraph. " ......-. The foregoing provisions of this Section constitute an absolute and present assignment of th~ Revenues, subject however to the conditional permission given hereunder to the Company to collect and use Revenues during a period while no Event of Default shall have occurred and be continuing under this Agreement. Upon the occurrence and continuation of an Event of Default, that permission shall terminate, and the Revenues will be required to be immediately deposited with the Trustee. The existence or exercise of the permission herein granted to the Company shaH not be construed or operate to subordinate the assignment made or the security interest granted in this Section, in whole or in part, to any subsequent assignment made or security interest granted by the Company and shall not be construed or operate to affect in any way the Company's obligation to make the Loan Payments or the Additional Payments. Upon the occurrence of an Event of Default and during the continuation thereof, the Trustee shaH have, in addition to all other rights and remedies, the rights and remedies of a secured party under the Uniform Commercial Code of the State, including the right to request any Person having an obligation to the Company to make payment on such obligation directly to the Trustee, and any such Person is hereby authorized and directed, upon such request, to make such payment directly to the Trustee. Funher, upon the occurrence of an Event of Default and during lhe continuation thereof and subject to any non-disturbance and attornment agreement which may be in effect. the Trustee shall have the right to renegotiate. modi fy, cancel, waive any default with respect to I and Olherwise take all actions in lieu of the Company with respect to any agreement covering residential units in the Project. ,~.J 37 f9-/8" ~ . .......... " The Company hereby irrevocably designates and appoints the Trustee as the true and lawful attorney of the Company, for any period during which an Event of Default shall have occurred and be continuing. and authorizes the Trustee as such attorney. either in the name of the Trustee or in the name of the Company f (i) to take any and all actions with respect to this Agreements covering residential units in the Project which the Trustee may deem necessary or desirable and (ii) to demand, sue for, collect, compromise, compound. receive, give receipts for, and give acquittances for any and all Revenues and to take any and all actions to realize cash proceeds from the Revenues which the Trustee may deem necessary or desirable, including the power to open and dispose of mail addressed to the Company and to endorse in the name of the Company any checks, drafts, notes or other instruments received in payment of or on account of such Revenues. The Company represents and warrants that (i) it has full power and authority and has the lawful right to assign 'and grant a first lien security interest in the Revenues as provided herein, and (ii) the Revenues are free and clear of all encumbrances other than Permitted Encumbrances. The Company warrants fully the title lhereLO and to every part thereof, and covenants and agrees to defend that title against the claims of all Persons and to maintain, except for Permitted Encumbrances and to the extent provided otherwise herein, the priority of the assignment of and the security interest granted in the. Revenues. " In connection with the incurrence of Parity Debt pursuant to and as permitted by Section 5.5 hereof, the Company may assign or grant to the owner of that Parity Debt a security interest in all or any part of the Revenues on a parity with the assignment made and the security interest granted pursuant to the preceding provisions of this Section. Any assignment made or security interest granted pursuant to the immediately preceding sentence shall be made upon substantially the same terms as are used in this Section in making the assignment and granting the security interest in this Section. ~-.."..-/. Except for Permitted Encumbrances and as otherwise authorized expressly in this Agreement, tile Company covenants and agrees not to do or suffer anything to be done whereby any of the Revenues with respect to which an assignment is made or a security interest is granted in this Section may be encumbered by any lien, charge. security interest or assignment. The Company shall not pennit any of its Property (other than Excluded Property) to become subject to any security interest, lien, charge or encumbrance not constituting a Permitted Encumbrance and not otherwise pennhted under the tenns of this Agreement. Section 5.2. Debt Service Coverage Ratio. The Company shall tix, charge and collect, or cause to be fixed, charged and collected, fees, rentals, rates and charges for the use of the Mortgaged Property and services provided or to be provided in connection therewith, that shall be at least sufficient to produce in each full Fiscal Year following completion of the Project a Debt Service Coverage Ratio for such Fiscal Year that is nOl less than 1.30. On or before the one hundred and twentieth day following the end of each Fiscal Year, beginning with the tirst full Fiscal Year after completion of lhe Project, the Company shall notify the Trustee of the Debt . I ~-.,/ 38 99 -If{" .....~ ,'r.' > .:a.:.~ ~ J .,", . , Service Coverage Ratio for such Fiscal Year. If the Debt Service Coverage Ratio. as calculated tor any Fiscal Year, is less than 1.30, the Company (i) shall notify the Trustee of the Company's failure to achieve the Debt Service Coverage Ratio, (ii) take all action necessary to cause the fees, rentals. rates and charges imposed and collected by it in connection with its operation of the Mortgaged Property to produce the amount required by such paragraph. and (iii) employ a Consultant to submit to the Trustee a written report and recommendations with respect to the fees, rentals, rates and charges imposed and collected by the Company and other items of Revenues in connection with its operation of the Mortgaged Property and with respect to improvements or changes in the operations or management of or the services rendered by the Company. The Company shall follow any reasonable recommendation of the Consultant retained by or on behalf of the Company pursuant to this Section. If the Company revises or adjusts or causes to be revised or adjusted its fees, rentals, rates, charges and other Revenues,. operating costs, occupant mix, intensity or scope of service or marketing approach in conformity with the recommendations of the Consultant and otherwise follows such recommendmions of the Consultant, then the Company's failure to achieve the Debt Service Coverage Ratio of 1.30 ;n any Fiscal Year shall not constitute an Event of Default under this Agreement. Until such time as the Company shall achieve the Debt Service Coverage Ratio of 1.30, the Trustee may require the Consultant to update its report and to file such additional reports or recommendations as may reasonably be requested by the Trustee from time to time. \...._/. If approvals of any regulatory or supervisory authority are required in order to fix. charge. collect and olherwise implement any fees. rentals. rates, charges and olher Gross Revenues required by the operalion of this Secrion (including, without limitation, any fees~ rentals. rates, charges and other Revenues recommended by the Consultant), the Company shall take all action within its power to obtain such approvals in the most expeditious manner available to the Company. The Company :;ha11 maH a copy of any report of any Consultant filed with the Truslee in accordance with this Section to any Holder who has made written request therefor of the Company, and so long as the Series 1999 Bonds are Outstanding, B.C. Ziegler and Company. If the Company fails to retain a Consultant as required herein the Trustee may, at the expense of the Company t retain such Consultant and the Company shall pay such expense as an Additional Payment. Section 5.3. Calculation of Principal and Interest Requirements. For all purposes of this Agreement, the following shall apply to the calculation of the Principal and Interest Requi rements: (a) Principal and Interest Requirements on Outstanding Long-Term Debt, or portions thereof, shall not be included in the computation of the Principal and Interest Requirements until I. I I~ 39 91~ /~ ;) c ~." the Fiscal Ycar in which such principal or interest. or portions thereof, first become payable from sources other than amounts deposited in trust, escrowed or othcrwise set aside tor the payment thereof (including, without limitation. capitalized intcrest and accrued interest so deposited into trust, escrowed or otherwise set aside) with the Trustce or another Person approved by the Trustee. i' I (b) Principal and Interest Requirements on any Long-Term Debt having a single principal maturity and no sinking fund redemption requirements, or having a principal amount due in any Fiscal Year which exceeds 25% of the total principal amount of such Long-Term Debt may be recast, at the election of the Authorized Company Representative. on the assumption that the principal amount of such Debt is to be amortized on a level debt service basis over 20 years and bearing interest at its stated rate or rates. (c) The interest rate on any variable rate Long-Term Debt shall be assumed to be. in any future period tor which the calculation is being made, the rare per annum which was in effect as of the last day of the calendar month next preceding thc month in which the calculation of the Debt Service Coverage Ratio is being made or, if no rate was in effect on such day, then the rate per annum which was in effect on the date on which such variable rate Long-Term Debt was issued or incurred. . .....- ''', ... } '- (d) In the case of guarantees of debt which would constitute Long- TenTI Debt if such debt were Debt of the Company, 20% of the principal and interest due on the guaranteed debt (Calculated as provid~ in this Section) shall be deemed to be Principal and Interest Requirements of the Company. However, if the Company makes or has made a payment pursuant to a guaranty, 100% of the principal and interest due on the guaranteed debt shall be deemed to be Principal and Interest Requircments of the Company unless and until 24 months have elapsed from the last of such payments. at which time 20% of the principal and interest requirements on the guaranteed debt shall be counted. (e) No Debt shall be counted morc than once. (f) Principal and Interest Requirements on Debt secured by and payable solely from the revenues and/or property associated with a project financed with such Debt and with no recourse directly or indirectly to any other Property or revenues of the Company shall not be included in the Principal and Interest Requirements for purposes of calculating the Debt Service Coverage Ratio. Section 5.4. Permitted Debt. Effective as of the date of delivery of the Series 1999 Bonds. the Company will not incur or permit to remain outstanding any Debt other than its Debt. obligations with respect to the Series 1999 Bonds and any additional Permitted Debt described below (provided that at the time of incurrence of any additional Debl, no Event of Default or event which with notice or lapse of time, or both. would constitute an Event of Default shall have occurred and be continuing under this Agreement): .~ 40 r9'-/~ ..) (a) Long-Term Debt (variable or fixed rate). provided that the rcquirements' of [subparagraph (i) QJj subparagraph (ii) .or subparagraph (iii) are satisfied and~ if such Debt shall be Parity Debt. the requirements of Section 5.5 hereof shall be satisfied: I . I. I' [(i) the principal amount of the Long-Term Debt proposed to be incurred, together with the currently Outstanding principal amount of any other Long-Term Debt previously incurred pursuant to this subparagraph (a)(i) of Section 5.4, does not exceed 10% of the Total Operating Revenues as shown on or calculable from the audited financial statements of Lhe Company for the most recent Fiscal Year for which audited tinancial statements have been delivered to the Trustee, or] (ii) the Company shall have delivered to the Truslce a certificate of the Company's Auditor to the effect that (A) for each of the two most recent Fiscal Years for which audited tinancial statements have been delivered to the Trustee. the Debt Service Coverage Ratio, calculated as if the Long-Tenn Debt proposed to be incurred had been oUlstanding in those years, was not less than 1.35x; or (B) for the most recent FiscaJ Year for which audited financial statements have been delivered to the Trustee, the Debt Service Coverage Ratio, calculated as if the Long- Tenn Debt proposed to be incurred had been outstanding in such year, was not less than ] .SOx; m: (iii) the Company shall have delivered to the Trustee the following: ; ) ......... (A) a certificate of the Company's Auditor to the effect that for the most recent Fiscal Year tor which audited tinancial Slalemems have been delivered to the Trustee, the Debt Service Coverage Ratio, calculated without including the Long-Term Debt proposed to be incurred, was at least 1.25x ami (B) a repon or opinion of a Consultant or an Auditor to the effect that the forecasted Debt Service Coverage Ratio (including the Long-Term Debt proposed to be incurred) for each of the first two full Fiscal Years following the completion of the acquisition, construction, renovation or replacement being paid for with the proceeds of such additional Long-Term Debt, or following the incurrence of Long- Tenn Debt for refunding purposes, is not less than 1.25x; provided; however, that in the event that a Consultant shall deliver a report to the Trustee to the effect that Governmental Restrictions then in existence do not permit or by their 'application make it impracticable for the Company to produce the required ratios set forth above and the borrowing is necessary to maintain and preserve the Company's property, plant and equipment or to maintain or enhance the Company's market position, then such ratios shall be reduced to the highest practicable ratios then permitted by such laws or regulations but in no event less lhan 1.00 in case of subparagraphs (A) and (B). v 41 99 - /fb '., <,../ o (b) Refunding Debt (variable or fixed rate); provided that the reports or opinions set forth in paragraph (a) of this Section 5.4 shall be ddivcred unlcss at the time of issuance of such Refunding Debt and after giving effect thereto and to the application of the proceeds thcreof the aggregate maximum annual Principal and [nterCSl Rcquirements of the Company (delcrmincd in the same manner as if a calculation of the Debt Service Coverage Ratio were being made) on all Long-Term Debt then to be outstanding (Le., after issuance of the Refunding Debt) does not exceed the aggregate maximum annual Principal and Interest Requirements of the Company (determined as aforesaid) on all Long-Term Debt outstanding immediately prior to the issuance 01' such Rcfunding Debt by more than ten perccnt (10%). (c) Short-Term Debt (variable or fixed rate); provided that the combined Outslanding principal amount of Short-Term Debt incurred pursuant to this paragraph (c) of this Section, does not cxceed 10% of the Total Operating Revenues as shown on or calculable from the audited financial statements of the Company tor the most recent Fiscal Year for which financial statements have been delivered to the Trustee. For a period of 20 consecutive days during each Fiscal Year no Short- Tenn Debt shalJ be outstanding in excess of 5 % of such rotaJ Operating Revenues. (d) Nonrecourse Debt secured by and payable solely from property associated with the Project financed. by such nonrecourse Debt (which shall be property other than the Mortgaged Property) with no recourse directly or indirectly to any other property or assets of the Company. (e) Interim Debt incurred in anticipation of being retinanced with Long-Term Debt; provided that. at the time such Interim Debt is incurred or assumed. there shall be delivered to the Trustee: (i) a certificate of an Authorized Company Representative stating that the Company reasonably expects to retinance the Interim Debt by the issuance of Long-Term Debt within the next 60 months; (ii) reports or opinions of the type required by either subsection (a)(ii) or (a)(iii) of this Section 5.4 demonstrating that all requirements of either subsection would be met if such Interim Debt were then being issued as Long-Term Debt maturing as provided in Section 5.3(b); and (iii) either (x) evidence that such Interim Debt is secured by an irrevocable extension of credit, or an agreement to purchase such Interim Debt from the holder thereof or (y) a written statement of an investment banker, experienced in the underwriting of Long-Term Debt of the type in anticipation of which such Interim Debt is proposed to be incurred or assumed, to the eftect that Long-Term Debt maturing over the term and bearing interest at the rate referred to in the foregoing paragraph (ii) would, if then being offered, be marketable on reasonable and customary terms; 42 99-1 ~ ') provided that in no event shall the outstanding principal amount of Interim Debt outstanding at any time excecd 10% of Total Opcrating Revenues as shown on or calculable from the audited financial statements of the Company for the most recent Fiscal Year for which tinancial statements have been delivered to the Trustee. (t) Any continuing obligation of the Company to pay principal of and interest on Debt which is deemed to be discharged or defeased in accordance with the terms of th~ instrument or instruments creating or evidencing such Debt; provided, however. that there is delivered to the Trustee a letter from an Auditor veritying the adequacy of any escrow established in connection with the discharge or defeasance of such Debt. - , , (g) [Debt subordinate to the Bonds in right of payment if the written instruments evidencing the subordinated Debt include provisions to the effect that upon any acceleralion of amounts due Wilh respect to such subordinatcd Debt or upon any dissolution. liquidation or reorganization of the Company in bankruptcy. insolvency. rcceivership or other proceedings. no payment shall be made with respect to such subordinated Debt until after all payments due with respect to Bonds and Parity Debt have been made in full. The Company's compliance with the provisions of this subparagraph shall be evidenced by delivery to the Trustee, not less than ten days prior to the incurrence of such subordinated Debt, of (i) copies of all instrumenlc; relating to the subordinatcd Debt and (ii) an opinion. satisfactory in form and substance to the Trustee, of Independent Counsel to the effect that those instruments comply with the restrictions of this subparagraph and are legal, valid, binding and enforceable, with appropriate exceptions for bankruptcy, insolvency and similar laws and for equitable principles.) . ) ------ Except as provided otherwise herein, including, without limitation, Sections 5.5 and 5.7, the Debt, liability or obligation of the Company to pay principal, interest, rent, charges, guarantees and other amounts under any Debt, liability or obligation or any lease, promissory note or other instrument or document related thereto, shall be unsecured at all times; provided that the Company may grant a lien on its Revenues and a mortgage on or a security interest in the Project provided that such lien, mortgage and security interest shall specifically be made subordinate to the lien on Revenues and security interest on the Project herein created and the mortgage and security interest created in the Mortgage and there shall be no right to foreclose or otherwise enforce such lien or mortgage so long as the lien and security interest of this Agrecment and the mortgage and security interest of the Mortgage are not being foreclosed or enforced. Debt incurred under one paragraph of this Section may be reclassified to another paragraph of this Section if, following such reclassification, the Company will be in compliance with the provisions of this Section, calculated as if such Debt was incurred on the date of such rec lassi tication. Section 5.5. Parity Debt. So long as there does not exist an Event of Default and subject to the conditions provided herein, the Company has the right to incur Parity Debt, secured by the Mongaged Property (as dcfined in the Mortgage) on a parity with the Series 1999 Bonds, .J 43 1'1 - I~ .,-..\ , .J .. o ~ ~fl I.q.~.~. ..,.em. ..,- for paying costs of any improvements, completing any improvement, financing acquisitions or start-up costs of new programs and services and equity contributions in joint ventures or similar investment opportunities, or refunding or advance refunding all or any portion of any series of Bonds or any Parity Debt. or any combination of such purposes. The costs of any improvements for which Parity Debt may be incurred is not restricted by the definition of the term Ucosts of health care facilities" contained in the Act. Prior to the incurrence of any Parity Debt, the Company will provide evidence satisfactory to the Trustee that each of the following conditions has been satisfied and will deliver to the Trustee the following instruments and documents: (a) any certifications, reports or opinions required under Section 5.4 to evidence that the Parity Debt is Permiued Debt; (b) any instrument or document evidencing the Parity Debl, which shall include: (i) a cross default provision with respect to this Agreement, the Mortgage and the Indenture, (ii) provisions (which may be contained in a separate agreement to which the Trustee is a pany) to the effect that, prior to exercising any remedies upon a default or event of default by the Company under any instrument or document relating to the Parity Debt, the holde,rs of the panty Debt (or a trustee representing their interests) shall cooperate with the Trustee to the end that the intereSls of those holders and the Holders shall be proteclcd equally and ratably t and (iii) a provision that all Parity Debt and all indebtedness, liabilities and obligations of the Company under this Agreement and the Indenture shall be payable from the Revenues secured equally and ratably by all security provided for either or both. except that Parity Debt shall not be protected or secured by the Special Funds; (c) any instrument or document evidencing due authorization for the incurrence by the Company of the Parity Debt; (d) a certificate of the Authorized Company Representative that the Company is not in default under this Agreement~ the Mortgage or the Indenture; and (e) an opinion of Independent Counsel that the Parity Debt is legal, valid. binding and enforceable in accordance wilh its terms subject to usual exceptions for creditors' rights, equity and public policy. In conncclion with the incurrence of Parity Debt, there shall be delivered to the Trustee an opiniont satisfactory in form and substance to the Trustee, of Independent Counsel to the effect 44 9f-;r . . c. .', ~.', ": that each of the instruments and documents described in this Section complies with the requiremenls of this Section and is a legal, valid, binding and enforceable obligation of the parties signatory thereto and of the owners and holders of the Parity Debt, with appropriate exceptions for bankruptcy. insolvcm.:y and similar laws and for equitable principles. Thal opinion shall be delivered to the Trustf..'e at least ten (10) days prior to the incurrence of the Parity Debt or within any shorter period which shall be satisfactory to the Trustee. The Company will take aU actions (including without limitation, amending or supplementing the Indenture, this Agreement and any other collateral instrument or document) and will eXCCUle, deliver, file and record all instruments and documents of security which are required by this Agreement or the Indenture, which relate to the Parity Debt. which are required by law. or which the Company, the Issuer or the Trustee determines to be necessary or advisable, upon the advice of Independent Counsel, to make or grant lO the holders of the Parity Debt a right for payment from and an assignment of and a security intereSI in any properly. or to secure those holders otherwise, on a parity with that of all other holders of ParilY Debt and lhe Holders. , \,~ I,.. ~-rr~1 As a condition to the incurrence of the Parity Debt. the Company shall execute, deliver, file and record and cause to be executed, delivered, filed and recorded all instruments and documents which are required by this Agreement or the Indenture, which relate to the Parity Debt, which are required by law or which the Company, the Issuer or the Trustee determines to be necessary or advisable, upon the advice of Independent Counsel, to make or grant to the Trustee an assignment of and a security interest in any property which is the subject of an assignm~nt made or a security interest granted to the holders of the Parity Debt and not made or granted theretofore to the Trustee, or lO secure the Trustee otherwise, on a parity with those holders. The actions taken pursuant to this Section shall be taken to the end that all of the outstanding Parity Debt and all Outstanding Bonds !ihall be of equal rank and shall be entitled to share on a parity in 'all security granted under this Agreement in Revenues, except that Parity Debt shall not be protected or secured by the Special Funds or any Issuer Document. Within a reasonable period, not to exceed 180 days, following the issuance of any Parity Debt, the Company shall deliver to the Trustee conformed copies of all instruments and documents supporting or evidencing the Parity Debt. Section 5.6. Restrictions on Disposition of PropertY: Lease or Use of Proiect. The Company covenants that it wiff not self, lease or otherwise dispose of its Property except as permitted by this Section or by other provisions of this Agreement. (a) Subject to Article IV and Section 7.2 of the Mortgage, the Company may sell. transfer, lease, trade. conveyor otherwise dispose of any Property if: (i) the disposition is in the ordinary course of the Company's business, (ii) the disposition is in exchange for or results in the receipt of property of equal or greater value and usefulness, (Hi) the disposition of the Property is for its fair market value and on terms no less favorable than would be obtained in an armts .....,) 45 11, I~ \ I 1 I I :1 , i ._.~.~................. ~ _...........--.......-.-..~------ I J "~ length transaction and such disposition will not cause the Company to be in breach of any of its covenants under this Agreement, or (iv) all such dispositions in any consecutive twelve month pe,riod does not exceed five percent of the total revenue of the Company for the same period and such disposition will nO[ cause the Company to fail to be in complianct' with the rate covenant sel torth in Section 5.2 hereof or the liquidity covenant set forth in Section 5.23 hereof. (b) Subject to Article IV and Section 7.2 of the Mortgage, the Company may sell, transfer, lease, trade, conveyor otherwise dispose of any real or personal Property if in the reasonable judgment of the Company set forth in a certiticate delivered to the Trustce and signed by an Authorized Company Representative, the Property so disposed is, or is expected to become within the next 24 months, inadequate, obsolete, worn out. unsuitable. undesirable, unprofitable or unnecessary and the sate, lease, removal or other disposition of the Property will not impair the structural soundness, efficiency or economic value of the rcmai ning Property. This Section shall not be construed to limit the rights of the Company to transfer or otherwise dispose of its cash or investments in connection with arm I s length transactions which are undertaken for the purpose of investing or reinvesting cash or investments of the Company. The Issuer and the Trustee shall execute such documents as are necessary to release any security interest it may have in Property which the Company disposes of in accordance with and as penniued by this Agreement. .-......... (c) Additionally, with respect to the lease or grant of use of the Project, the folfowing additional conditions shall apply: I .......,,/' (i) No such grant or lease shall relieve the Company from its obligations under this Agreement, the Irlfjenture, the Mortgage or the Notes; (ii) In connection with any such grant or lease the Company shall retain such rights and interests as will permit it to comply with its obligations under this Agreement, the Indenture, the Mortgage and the Notes; (Hi) No such grant or lease shall impair materially the purposes of the Act to be accomplished by operation of the Project as herein provided; and (iv) Any such grant or tease (i) shall be subject to the terms and conditions of this Agreement~ including, without limitation, those provisions with respect to the maintenance, operation and insuring of the Project. (ii) shall expressly prohibit the lessee or user from assigning its interest to others or subleasing the Project or any part thereof or granting to others any use of the Project or any part thereof, and (iii) shall contain provisions deemed by Bond Counsel [0 be necessary to comply with the Act, the Code, and this Agreement. .J 46 c;q ,/ f{( l't1ll+ir~"'.i'I:''':~.' ". Section 5.7. Pennitted Encumbrances. Effective as of the date of delivery of the Series 1999 Bonds, the Company covenants that it will not create or suffer to be created or exist any mortgage, lien, security interest, charge or other encumbrance ("Lien") on any of its Property except for Permitted Encumbrances. which shall consist of the following: (a) the Mortgage, and the liens existing on the Project as of the date of delivery of this Agreement, as listed in Exhibit E hereof; (b) any liens securing all Bonds and Parity Debt; (c) liens arising by reason of good faith deposits by the Company in connection with tenders, leases of real estate, bids or contracts (other than contracts for the payment of money), deposits by the Company to secure public or statutory obligations. or to secure, or in lieu of, surety, stay or appeal bonds and deposits as security for the payment of taxes or assessments or other similar charges; . J .........,~ (d) any liens arising by reason of deposits with, or the giving of any form of security to, any governmental agency or any body created or approved by law or governmental regulation for any purpose at any time as required by law or governmental regulation (i) as a condition to the transaction of any business or the exercise of any privilege or license, or (ii) to enable the Company to maintain self-insurance or to participate in any funds established to cover any insurance 'risks or in connection with workers' compensation. unemployment insurance, old age pensions or other social security, or to share in the privileges or benetits required for companies participating in such arrangements; ~. \ (e) any judgment lien or mechanic lien against the Company, so long as the finality of such judgment is being contested and execution thereon is stayed or provision for payment of the judgment has been made in accordance with applicable law or by the deposit of cash or invesunents with the Trustee or a commercial bank or trust company acceptable to the Trustee or adequate insurance coverage is available to satisfy such judgment; (t) such defects, irregularities, encumbrances, patent reservations, utility easements, access and other easements and rights-of-way, restrictions, exceptions and clouds on title as do not, in the reasonable determination of the Company, as evidenced by a certificate of an Authorized Company Representative delivered to the Trustee, materially adversely affect the interest of the holders of Bonds and Parity Debt and as do not materially interfere with or impair the operations being conducted in connection with the Property affected thereby (or, if no operations are being conducted therein, the operations, if any, for which such Property was designed or last modified); (g) any mortgage, security interest, lien, charge or encumbrance securing nonrecourse Debt, as described and permiued under Section 5.4(d) of this Agreement (including a pledge of the revenues derived from the Property financed by such nonrecourse Debt which may be superior v 47 99-18" ..t'..f.....-...:..f(. t' I' ..' .-....... " \ , to the pledge of Revenues under Section 5.1 of this Agreement) and which do not extend to any Property other than that acquired with the proceeds of such nonrecourse Debt; I I. (h) any security interesl. lien. charge or encumbrance upon Revcnues or othcr current assets of the Company securing Short-Term Debt permitted under Section 5.4(c) of this Agreement; (i) any security interest in Property which may be granted to secure Parity Debt as permitted under Section 5.5 of this Agreement; U) liens on proceeds of Debt (and investment income on such proceeds) that secure payment of such Debt; (k) encumbrances arising from grants, charitable contributions or donations. loans and/or guarantees of Debt by federal. state and local governments or agencies thereof; . (I) liens for taxes, special assessments or other governmental charges not then delinquent or being contested in accordance with the provisions of this Agreement; (m) liens resulting from governmental regulations'on the use of property; .. .'\ '.J (n) purchase money licns securing permitted Debt incurred within 90 days of the date of acquisition of Property subject to such lien so long as such lien is limited to the Property so acquired and the Debt secured thereby does not exceed the lesser of the cost or the fair market vaJue of the Property so acquired; (0) mortgages, liens. charges and encumbrances existing on the date on which property which has not theretofore been owned by the Company is acquired by the Company, so long as on the date of such acquisition a certificate of an Authorized Company Representative is delivered to the Trustee contirming that the fair market value of such property, as certified by an Appraiser, is at least equal to the then outstanding principal balance of all Debt secured by such liens, charges and encumbrances; and (p) leases of real Property or agreements relating to the use of space within real Property for anyone or more of the following purposes (subject to applicable zoning requirements and restrictions) : (i) the provision of health care services such as, but not limited to, patient examinations, medical treatment, physical and occupational therapy. psychiatric or psychological or social counseling, (ii) resident or employee convenience activities such as, but not limited to, banking servicest travel agencies, gift shops, snack shops, barber or beauty shops, doctors. or I '.....,/ 48 19~tr ~) dentists' offices and accommodations. flower shops, counseling services. pharmacy and living accommodations for persons providing services within the Project, (iii) in connection with arrangemcllls with or for the bem:tit of physicians. nurses, paramedics, counselors, or other persons providing health and medical or health and medical support or rehabilitation services to the residents of the Company's facilities, so long as the Trustee shall have received a certificate of an Authorized Company Representative confirming that either (A) as of the date of attachment thereof such liens, charges, encumbrances and leases, both individually and in the aggregate, do not materially and adversely affect Net Income Available for Debt Service and the lessor has retained the right to increase the rents payable thereunder to satisfy any recommendations of a Consultant rendered pursuant to Section 5.2 of this Agreement, (B) the book value of the Property of the Company (other than that financed with the proceeds of nonrecourse Debt) encumbered by liens, charges, encumbrances or leases described in this clause (iii) does not exceed 3% o(the book value of all Property of lhe Company (other than thatlinanced with the proceeds of nonrecourse Debt) or (C) one of the tests for disposition of Property set forth in Section 5.6 of this Agreement would be satisfied if the attachment of such lien, charge or encumbrance or the execution of such lease were deemed a sale or other disposition of such Property, (iv) in connection Wilh leases to residents for residential purposes, .~~~) (v) other purposes so long as such lease (A) shall be, as of the date of the execution thereof. upon tern1S no less favorable to the lessor lhan "arm's length" and (B) shall permil the lessor to adjust the rents payable thereunder to satisfy the recommendations of a Consultant delivered pursuant to Section 5.2 of this Agreement. Section 5.8. Maintenance of COI:porate Existence. The Company covenants and agrees that during the term of this Agreement it will maintain its corporate existence as a nonprofit "health care agency" as defined in the Act with aU of its present rights and franchises, except as pern1itted otherwise hereunder. In particular, the Company will not: (i) dissolve, sell, transfer or otherwise dispose of all or substantially all of its assets (either in a single transaction or a series of related transactions); (ii) consolidate with or merge into another Person: or (Hi) permit one or morc other Persons to consolidate with or merge into it; provided that the Company may, without violating thc covenants, agreements and obligations containt..'<1 in this Section, consolidate with or mcrge into one or more other Persons, permit one or more other Persons to consolidate with or merge into it, or sell or lransfer to one or more other Persons all or substantially all of the Company's assets as an entirety and thereafter dissolve if ; '-...) 49 r1;" / r __ ____ __________.___..__..___..________1 /'., I.' 1 (a) such Person or Persons (the "Transferee") (i) is organized and existing under the laws of the Uniled States, one of the states or territories of the United States or the Dislrict of Columbia, (ii) is qualitied to transact business as now and as intended to be transacted by the Company and possesses all governmental powers and approvals necessary lO own or operate the Company's properties, (iii) is a governmental unit, as that term is used in Section 145 of the Code, or an organization described in Section 501(c)(3) of thc Code and (iv) expressly assumes in writing aU of the covenants, agreements and obligations of the Company under this Agreement, the Notes, the Mortgage, the Indenture and all other instruments and documents executed and delivered by the Company in connection with the then Outstanding Bonds by an instrument or document satisfactory in form and substance to the Trustee; and (b) the Company shall have furnished to the Trustee an opinion of Bond Counsel that the consolidation, merger. sale or other transfer does not affect adversely lhe validity of the Outstanding Tax-Exempt Bonds or the exclusion from gross income for federal income tax of the interest on Outstanding Bonds which have theretofore been deHvered accompanied by an Opinion of Bond Counsel that interest thereon is excludable from gross income for federal income tax purposes; and (c) the consolidation, merger, sale or other transfer does not affect adversely (i) the priority or the status of this Agreement as a legal, valid and binding agreement or its enforceability and Oi) the priority or the Slatus of the lien of the Mortgage; and \",/ (d) the Company causes to be delivcred to the Trustee (i) a written rcport of a Consultant, dated not more than 90 days prior to the consolidation, merger, sale or other transfer, to the effect that, based on audited financial statements of the Company and the Transferee for such Fiscal Year, assuming that such merger, consolidation, sale or other transfcr occurred as of the last day of the most recent Fiscal Year for which audited financial statements are available and with any adjustments for differing Fiscal Years, the Company would have been able to issue one dollar in Parity Debt in accordance with the provisions of Section 5.5 hereof and (ii) a written opinion of a Consultant stating that, aftcr giving effect to the consolidation, merger, sale or other transfer, the net worth of the Transferee will be at least 100% of the net worth of the Company immediately preceding the consolidation, merger, sale or other transfer; and (e) the Trustec shall have received an opinion of Independent Counsel, satisfactory . to the Trustee in form and substance, and based upon certifications and examinations satisfactory to the Trustee, to the effect that (i) immedialely after the consolidation, merger, sale or other transfer. the Transteree will not be in ddault in the observance or pertormance of any covenants, agreements or obligmions hereunder, including without limitation, Section 5.4 hereof, ~ 50 I 1 I I :1 I I I 11 - If( ..~ (ii) the assumption by the Transferee of the Company's covenants. agreements and obligations hereunder constitutes a legal, valid, binding and enforceable obligation of the Transferee, with appropriate exceptions for bankruptcy. insolvency and similar laws and for equitable principles. and (Hi) the Company and the Transfcree are authorized by the laws of the State (and other appropriate jurisdictions) to effect the consolidation, merger, sale or other transfer and the consolidation, merger. sale or other transfer is permitted hereby. If a consolidation, merger; sale or other transfer occurs as provided in this Scction. the provisions of this Section shall continue lO be in full force and effect, and no further consolidation. merger, sale or other transfer shall be made except in compliance with the provisions of this Section. Section 5.9. Annual Audit and Periodic Report. The Company covenants and agrees that it will keep true and proper books of records and accounts in which full and correct entries will be made of all of its business transactions, and that it will reflect in its financial statements the revenues subject to the assignment of Revenues made in Section 5.1 hereof, all in accordance with generally accepted accounting principles. The Company will have an annual audit made by the Auditor of its tinancial statements in accordance with generally accepted auditing standards. So long as any Bonds are outstanding, the '-) Company will deliver to the Truslee, such Holders as shall make written requests theretor to the \:~.~ Company and, so long as the Series 1999 Bonds are outstanding, B.C. Ziegler and Company, promptly within 120 days after thecnd of each Fiscal Year of the Company, (a) a copy of the Company's audited tinancial statemcnts. including without limitation, a balance sheet or statements of assets, liabilities and fund balances as of the end of that Fiscal Year, statements of revenues and expenses or margin, and statements of cash flows for that Fiscal Year, and (b) a certificate signed on behalf of the Company by the persons performing the functions of the administrator or chief financial officer of the Company t which shall state (i) to the best of the knowledge of each of the officers executing the certificate, based solely on an examination of the latest financial audits, review of the corporate minutes or record of proceedings of the Company's Board of Directors and its Finance, Exel.:utive, Building and Property Committees (or such other major standing committees then in exislence), there are no Defaults or Events of Default under this Agreement, lhe Indenture or the MOrlgage or defaults or events of default under the provisions of any Debt instrument or document and, without further examination or investigation, lO the best of that officer's knowledge, no Default or Event of Default exists on the part of the Issuer under the Indenture, or o 51 qq'lrI - ,-\ J (ii) if in any case. a Default, Event of Default, default or event of default described in or identitied pursuant to subparagraph (a) has occurred and is continuing, specifying the nature thereof and any action which the Company is taking or proposes to take with respect thereto. While the Series 1999 Bonds are outstanding, the Company will furnish quarterly unaudited financial statements and any other such information as may be reasonably requested to the Truslee, the Initial Bondholders and B.C. Ziegler and Company within 45 days of the end of each quaner. For purposes of this Section, the term "default" means a default as defined with respect to the relevant document or instrument or any circumstance which is a violation thereof or, wilh the passage of time or the giving of notice or both, would constitute an event of default thereunder. Section 5.10. . Perfection of Security Interest. At the Company's expense, the Company will cause any required or advisable tiling, registration, recording, refilingl reregistration or rerecording to be made on behalf of the Issuer at the timesl in the manner and in the places, and will pay all recording, registration, filing or other taxeSI fees and other charges, therefor, all in accordance with all applicable statutes and regulations. Promptly after any filing, registration, recording, refiJing, reregistration or rerecording, the Company will deliver to the Trustee a certificate of an Authorized Company Representative or an opinion of Independent Counsel addressed to the Trustee and acceptable to the Trustee, to the effect that the filing, registration, , recording, refiling, reregistration or rerecording has been duly accomplished and setting forth the ~") particulars thereof. "'~.....V' Section 5.11. Right of Inspection. Subject to reasonable security and safety regulations and upon reasonable notice, the Issuer, the Truslee, and, so long as the Series 1999 Bopds are outstanding, B.C. Ziegler and Company, and their respective agents, shall have the right during normal business hours to inspect the Mortgaged Property. Section 5.12. Indemnification. The Company (i) releases the Issuer, the members of the City Commission of the Issuer, its staff, agents, employees and consultants (collectively, the "Indemnified Parties") from, (ii) covenants and agrees that the Indemnified Parties will not be liable for, and (Hi) covenants and agrees to indemnify the Indemnified Parties for and to hold the Indemnified Panies harmless against, all liabilities, claims, costs, losses and expenses (including without limitation, to the extent pennitted by law, reasonable attorneys' tees and expenses), joint or several, imposed upon or asscrled against the Indemnified Parties on account of or resulting from the issuance of the Bonds, its execution, participation in or functioning under the Issuer Documents and will reimbursc any legal or other expenses incurred reasonably by the Indemnitied Parties in connection with investigating or defending any such liability, claim, cost, loss, expense, action or proceeding; provided, however, that indemnitication under this Section shall not extend to damages resulting from any maller not related to its capacilY hereunder or as issuer of the Bonds. .....) 52 1Cf~/~ '"} The Company covenants and agrees further, that to the extent permitted by applicable law. the Company shall assume liability for and indemnify. reimburse, protect. save and hold harmless the Trustee, acting in its capacity as Trustee under the Indenture or as AUlhenticating Agent. Paying Agent, Registrar or Tender Agent or in any olhcr capacity in connection with the Bonds (collectively. the "Indemnitied Fiduciaries") and the respective survivors, assigns, agents, employees, officers and directors from and against any and all liabilities. damages, penalties, claims, actions, suits, costs, expenses and disbursements, including legal fees and expenses, of whatsoever kind and nature (an "Indcmnitied Obligation") imposed on, asserted against or reasonably incurred by the Indemnitied Fiduciaries in any way relating to or arising out of the Issuer Documents or any of the transactions contemplated thereby, except that the Company shall not be required to indemnify the Indemniticd Fiduciaries for any Indemnified Obligations determined by a court of competent jurisdiction to have been the direct result of the gross negligence or willful misconduct of an Indemnified Fiduciary. ) .....-".... The Company covenants and agrees further. as to all representations, warranties, covenants, agreements and obligations of the Company under the Company Documents or in any other instrument or document delivered by the Company in connection with the authorization, issuance or sale of or performance under the Bonds and the provision of any infonnation concerning the Mortgaged Property, the Company. s properties, management, history, operations or financial status or forecasts, or any other matter, including without limitation, that information contained in the [Preliminary Ofticial Statement] and the [Ofticial Statement] relating to the Series 1999 Bonds. each as amended or supplemented from time to time. prepared in connection with the issuance and sale of the Bonds, '., (a) to assume the cost of, and to indemnify the Issuer and the Trustee and to hold them harmless against, all liabilities, claims, costs, losses and expenses, not paid from proceeds of the Bonds, to which the Issuer or the Trustee may become subject. and (b) to reimburse the Issuer and the Trustee for all out-of-pocket, legal and other expenses (including without limitation, to the extent permitted by law, reasonable attorneys. fees) incurred by the Issuer or the Trustee in connection therewith, with investigating any of those liabilities, claims, costs, losses or expenses, or with defending against any actions, claims or proceedings, except in each case to the extent related to information regarding the Issuer or the Trustee furnished solely by the Issuer or the Trustee, as the case may be, which was not provided by or in the name or on behalf of lhe Company or any other person. At the request and the expense of the Company I the Issuer and the Trustee shall cooperate in making any investigation and defense of any. action, claim or proceeding and shall assert appropriately the righls, privileges and defenses which arc available to the Issuer or the Trustee, as the case may be, in connection therewith; provided that the Company hereby indemnities the Issuer and the Truslce and agrees [0 hold lhe Issuer and the Trustee harmless with respect to any and all costs, losses or expenses in any way incurred or relative to such cooperation, defense or assertion. J S3 1CJ-/f( ..-.......~'(..~c '\ In case any action. claim or proceeding is brought or asserlcd against the Issuer or the Trustee with respect to which indemnification may be sought under this Section, the Issuer or the Trustee. as the case may be. shall give written notice thcreof promptly to the Company. No failure of the Issuer or the Trustee to give. and no dclay in giving. that notice shall relicve the Company to any extent from any of its covenants, agreements or obligations under this Section. unless that failure or delay is not reasonable and materially prejudices the defense by the Company of the action, claim or proca'ding, and only to the extent of the prejudice. The failure to give that notice shall not relieve the Company from any obligation which it may have to the Issuer or the Trustce, as lhe case may be, otherwise than under lhis Scction. In case any action, claim or proceeding is brought against the Issuer or the Trustee, and the Issuer or the Trustee, as the case may be, notifies the Company of the commencement thereof and of its right to indemnification, the Company may, or if so requested by the Issuer or the Trustee shall, participate therein or assume the detense thereof, with counsel approved by the Issuer or the Trustee (such approval not to be unreasonably withheld), as the case may be; provided that, except as provided below, the Company shall not be liable for the expenses of more than one separate counsel representing the Issuer and one separate counsel representing the Trustee, as the case may be, in the action, claim or proceeding. " After notice from the Company to the Issuer or the Trustee, as the case may be, of an election by the Company so to assume the defense thereof, the Company shall be liable to the Issuer or the Trustee, as the case may be. under this Section for any legal or other expenses incurred subsequently al the request of the Company by the Issuer or the Trustee in connection . with lhat defense. Notwithstanding any provision herein, the Issuer and the Trustee shall have the right to assert and prosecute any and all counterclaims or crossclaims in connection with any action in which either is named as a party. ' , If the Company shall not have employed counsel to have charge of the defense of the action. claim or proceeding, or if the Issuer or the Trustee, as the case may be, shall have concluded reasonably that there may be a defense available to it which is different from or in addition to those available to the Company (i) the Company shall not have the right to direct the defense of the action, claim or proceeding on behalf of the Issuer or the Trustee, as the case may be, if there is or reasonably appears to be a conflict of interest between the Company, on the one hand, and the Issuer or the Trustee, on the other hand, and (ii) reasonable legal and other expenses incurred by the Issuer or the Trustee (including without limitation, to the extent permitted by law, reasonable attorneys. fees and expenses) shall be borne by the Company. The release and indemniticalion pursuant to this Section arc intended to and shall include lhe release and indemnitication of atl affeclcd officials. directors, ofticers and employees of the Issuer and the Trustee, respectively. to the same extent and subject to the same terms as are lhe release and indemnitication of the Issuer and the Trustee, respectively. The release and indemnification are imended co and shall be enforceable by each indemnified Person to the full cxtent penniucd by law. All amounts payable under this Section, together with interest thereon .j 54 Cf1-/f{ /' ~....,\ at the Interest Rate for Advances from the date of any payment of any amount by the indemnified Person, shall constitute Additional Payments and shall be paid by the Company on demand by the indemnified Person. In any action brought to collect those Additional Payments. the indemnified Person shall be entitled to the recovery of the Additional Payments, except as limited by law or judicial order or decision. The covenants, agrccments and obligations of the Company under this Section shall survive the payment of the Series 1999 Bonds. , I: I. Section 5.13. Company Not to Adversely Affect the Exclusion From Gross Income of Intercst on Tax~Exempt Bonds. The Company hercby represents that it has taken and caused to be taken, and covenants that it will take and cause to be taken, all actions that may be required of it, alone or in conjunction with the Issuer, for the interest on the Tax~Exempt Bonds to be and remain excluded from gross income for federal income taX purposes, and represents that it has not taken or permitted lO be taken on its behalf, and covenants that it will not take or permit to be taken on its behalf, any actions that would adversely affect such exclusion under the provisions of the Code. "-/ Section 5.14. Litieation Notice. The Company shall give the Trustee prompt notice of any action, suit or proceeding by it or against it at law or in equity, or before any governmental instrumentality or agency, Of of any of the same which may be threatened, which, if adversely determined, would materially impair the right of the Company to carry on the business which is contemplated in connection with the Mongaged Property, or would malerially and adversely affecl its business, operations, properties, assets or condition. Section 5.15. Governmental Pennits and Re~ulations. The Company shall comply with all valid governmental regulations applicable to it and its operations and properties and shall obtain and keep in force all permits and licenses necessary therefof. Section 5.16. Annual Budgets. So long as any amount shall remain unpaid under the Notes, the Company will prepare and adopt an annual budget for each fiscal year covering the operation of the Project and all other operations of the Company. Each such annual budget shall be prepared and submitted to the Board of Directors of the Company at least thirty (30) days prior to the commencement of the fiscal year to which it applies, and such annual budget shall be approved and adopted by the Board of Directors prior to the commencement of such fiscal year. If an annual budget is not adopted for any new fiscal year prior [0 the commencement thereof, then the annual budget (if any) in effect as of the end of the next preceding fiscal year shall be used for such new fiscal year until replaced by an annual budget adopted therefor in accordance with the provisions of this Section. The annual budget for each fiscal year shall contain (i) a projection of all Revenues expected to be received by the Company during each such fiscal year, (ii) a projection of all expenses expected to be incurred by the Company during each calendar month of such fiscal year, reflecting o 5S f'1/lr -.......~~~....~.... .......~~.r.&.. I . .' '. .' ~ ------- ~.&... "') a reasonable breakdown of such projected expenses into separate accounts. (iii) a projection of the debt service payments and any addilions to or replenishments of reservcs required during each calendar month of such fiscal year with respect to the Bonds and any indeblcdness of the Company permitted by this Agreement, together with a corrcsponding projection of the Net Income Available for Debt Service during each such calendar month, (iv) a projected balance shect for the Company as of the end of each quarterly accounting period during such fiscal year, (v) a schedule of capital expenditures (including all installment purchases) proposed to be made by the Company during such fiscal year. including in the schedule of such capital expenditures. any proposed lease having a ternl in excess of one year, irrespective of whether such lease is required to be capitalized under generally accepted accounting principles. and (vi) such other statistical infonnation related to the projecled operalions of the Company as the Company may deem useful. ,; [Within 30 days of the adoption of its Annual Budget .or each fiscal year the Company shall provide a copy of the same to the Trustee, B.C. Ziegler and Company and lhe Florida Department of Insurance in accordance with Chapter 651, Florida Stalutes.] .~.') '..~./ Section 5.17. Proiect as Public Facility. The Company shall, during the term of this Agreement, operate the Project and any portion of the Existing Facilities of which it is a part without discrimination as to race, creed, color, sex or national origin, for the pubHc purpose of providing better health care for the inhabitants of Pinellas County and the State by enhancing the availability, efficiency and economy of continuing care retirement facilities for the elderly and the services rendered thereby. During the term of this Agrecment and so long as (here is no Event of Default under this Agreement, the Company shall have sole and exclusive charge of the operation of the Project and any portion of the Existing Facilities of which it is a part. Section 5.18. Restriction Al:ainst Relieious Activities. The Company will use the Project and any portion of the Existing Facilities of which it is a part only in furtherance of the lawful corporate purposes of the Company and will not use the Project and any portion of the Existing Facilities of which it is a part as a facility used primarily in connection with any part of the program of a school or department of divinity for any religious denomination or for the training of ministers, priests, rabbis or other similar persons in the field of religion. The foregoing restrictions, however, shall not be construed to prevent the Company from (i) maintaining a chapel, (ii) conducting education programs on any subject with one or more institutions, whether or not sectarian, or (Hi) implementing pastoral care programs of the kind permitted or provided by continuing care facilities for the elderly gcnerally. Section 5.19. Application of Revenues: Renewal and Replacement Fund. (a) The Company hereby covenants that all Revenues received shall be applied in each month in the following manner and in the following order of priority: (1) To the payment of all Loan Payments and any other payments required by this Agreement, the Notes, the Mortgage or the Indenture, including any deficiencies for such payments; -J 56 qq - I r( .--, \ (2) To the payment of Operating Expenses in accordance with the annual budget for the Mortgaged Propeny, as may be amended from time to time with the approval of its Board of Directors. (3) [To the Renewal and Replacement Fund in lhe amount of $ or such lesser amount as is necessary to cause the total amount on deposit in the Renewal and Replacement Fund to equal $ .J (4) To any other lawful purpose. (b) The Company shall creale and maintain a separate fund to defray the COSts of capital improvements to the Mortgaged Property (herein called the II Renewal and Replacement Fund"). Moneys in the Renewal and Replacement Fund may be applied by the Company for the purpose of paying the cost of making improvements, extensions and repairs to the Mortgaged Property that are of a capital nature and for the purpose of reimbursing the Company for the costs of any such improvementst extensions or repairs theretofore made and not previously reimbursed. In addition the moneys on deposit in the Renewal and Replacement Fund may be used by the Company to make Loan Payments or Rebate Payments to the Trustee in order to prevent the occurrence of an Event of Default when other funds of the Company are not sufficient. 'J Section 5.20. Purchase of Tender Bonds by Company. The Company covenants to purchase Unremarkcted Bonds from existing cash balances (excluding any funds held in Special Funds other than the Extendables Purchase Fund) to the extent of all unrestricted Cash on Hand in excess of 290 Days Cash on Hand. Section 5.21 [Reserved] [Section 5.22 Special Covenants. Insert any special covenants requested by the Issuer related to the Project.] Section 5.23. LiquiditY Covenant. The Company will deliver a certificate executed by an Authorized Company Representative within 120 days following the end of each Fiscal Year of the Company, commencing with the Fiscal Year ending _, 200_, stating that its Days Cash on Hand was [to be provided following receipt of the feasibility report]. In the event the Company is not in compliance with this Section 5.23 as of the end of any Fiscal Year, the Company shall (i) notify the Trustee of the Company's failure to achieve the required Days Cash on Hand, (ii) take all reasonable steps to cause the fees, rentals, rales and charges imposed and col1ected and the expenses incurred in the operation of the Project [0 produce the required Days Cash on Hand and (iii) employ a Consultant to submit to the Trustee and the Company a written report and recommendations with respect to such items of income and ---J 57 19" / r -) expenses collected or incurred by the Company to enable the Company lO obtain and maintain sufficient Days Cash on Hand. The Company agrees that it will, to the extent commcrcially feasibility and pl~rJ1lillCU by any applicable Government Restrictions, comply with and implemcm lhc recommendations of the Consultant. If the Company revises or adjusts its operation in conformity with the recommendations of the Consultant and otherwise follows such recommendations of the Consultant, the Company's failure to achieve the required Days Cash on Hand as of the end of any Fiscal Year shall not constitute an Event of Default under this Agrccmcnt. Until such time as the Company has come into compliance with the Days Cash on Hand requirement of this Section 5.23, the Company may require the Consultant to update its rcport and to file additional reports or recommendations as may be reasonably rcquired by the Trustee from time to time. If the Company fails to retain a Consultant as requircd hcrcin the Trustce may, at the expense of the Company, retain such Consultant and the Company shall pay such expenses as an Additional Payment. ) .- Section 5.24. Irade Payable Covenant. The Company shall maintain not less than 90% of its operating trade payables aged no more than 60 days and lhe remaining 10% of all operating trade payables aged no more than 90 days. commencing with the ,Fiscal Year ending _, 200 . Section 5.25. Occupancy Covenant. The Company will deliver to the Trustee a certificate of an Authorized Company Representative within 30 days of the end of each fiscal quarter, commencing _, 200_, stating that the Project has met the quarterly Occupancy Target. The Company hereby covenants to comply with the following quarterly Occupancy Targets [to be provided with the feasibility study]. Should the Project achieve 90% occupancy by _, 200_, the Company shall be required to maintain 90% occupancy, which occupancy level requirement shall be reviewed annually on each successive _, [provide the terms of such review]. Should the Company fail to meet the Occupancy Target on an annual basis, a report shall be filed with the Trustee setting forth the corrective actions to be taken by the Company. Failure to meet the Occupancy Target on an annual basis will result in lhe Company having to file quarterly occupancy reports with the Trustee. In the event the Company fails to meet the Occupancy Targets for any two consecutive fiscal quarters, the Company shall employ a Consultant to ~uhmit to the Trustee and the Company a written report and recommendations with respect to actions to be taken to increase occupancy of the Project. The Company agrees that it, will, to the extent commercially feasible and permitted by any applicable Government Restrictions, comply with and implement the recommendations of the , t ~ -../ S8 f}'j", I rt u~"';"""'..............___'_.: ...._,.. /7') . .. <.",-~l J' -', .', "J .-.~ ',) PM Consultant. If the Company revises or adjusts its operation in conformity with the recommendations of the' Consultant and otherwise follows such recommendations of the Consull.;'U1t. the Company's failure to achieve the required Occupancy Targets as of the end of any tiscal quarter shall. not constitute an Event of Default under this Agreement. Until such time as the Company has come into compliance with the Occupancy Target requirement of this Section 5.24, the Company may require the Consultant to update its report and to tile additional reports or recommendations as may be reasonably rcquired by the Trustee from time to time. I f the Company fails to retain a Consultant as requircd here~n the Trustee may, at the expense of the Company, retain \ such Consultant and the Company shall pay such expenses as an . Additional Payment. ,59 Cftf ~ I f( "" ."- ~ ~..... .'. i .~) I: ' ",.,; ! . . , <) ... ~ ,~ o A RTICLE VI REDEMPTION OF BONDS SeCtion 6.1. Qptionpl Redertlption. If, at any time under the Indenture or any of the Bonds, the Company may elect to cause thc Issuer or the Trustee to call any of the Bonds for redemption or may require .he Trustee 10 purchase Bonds. it may exercise such ejection, not less than forty~tivc (45) days prior to the dale of such redemption or purchase. by notifying the Trustee in writing of its exercisc of such clection and dclivcring to the TruSlCC therewith moneys sufficient for such purpose. Pcnding application for thosc purposes. any moneys so delivered shall be held by the Trustee in a spcdal account in the Bond Fund and delivery of those moneys shall not operate to abate or postpone Loan Payments or, Additional Payments otherwise becoming due or to alter or suspend any other obligalions of the Company under this Agreement. Section6.2. Ma.I1da~ory R~dcmplion or Pun:has~. If. at any time under any provision of the Indenturc or any of the Bonds, any Bonds are required to be redeemed or purchased or if the Issuer, the Trustt.."C, any Holdcr or any other person has exercised any election to require any of the Bonds to be cnJlcd for redemption or purchase, then the Company shall deliver to the Trustee, on or before one business day of the Trustee prior to the date on which such Bonds are lO be redeemed or purchased. thc moneys (in immediately available funds) needed to redeem or purchase such Bonds. In thc case of the Series 1999 Bonds, the Series 1999 Bonds are subject to mandatory and extraordinary redemption in accordance with Sections 4.01 and 4.02 of the Indenture. (End of Article VI) 60 ~1t."'::.~_~_~~'~::~~~~--:"~_~~ _ "_',,~~,.'~.,.~~ ~\'.l, , . . " . . ". . . ~ < . ... '... ., q1-/~ , \ i \ 1 II I I I ARTICLE VII <J EVENTS OF DEFAULT AND REMEDIES Section 7. 1. Events of Default. Each of the tollowing shall be an Event of Default: (a) The Company shall fail to pay any Loan Payment on or prior to the date on which that Loan Payment is due and payable. (b) The Company shall fail to deliver to the Trustee, or cause to be delivered on its behalf, the moneys needed to redeem any outstanding Bonds in the manner and at the time required as provided in Article VI of this Agreement. (c) The. Company shall fail to observe and perform any other agreement. term or condition contained in this Agreement, and that failure continues for a period of thirty (30) days after written notice of that failure is given to the Company by the Issuer or the Trustee or such longer period specified in the covenants set forth elsewhere herein, or for such longer period as the Trustee may agree to in writing; provided, that if the failure is other than the payment of money and is of such nature that it cannot be corrected within the applicable period, that failure shall not constitute an Event of Default so long as the Company institutes curative action within the applicable period and diligently pursues that action to completion. (d) The Company shall: , ,-",,' (i)' Admit in writing its inability to pay its debts generally as they become aue; (ii) Have an order for relief entered in any case commenced by or against it under the federal bankruptcy laws, as now or hereafter in effect; (Hi) Commence a proceeding under any other federal or state bankruptcy, insolvency, reorganization or similar law, or have such a proceeding commenced against it and either have an order of insolvency or reorganization entered against it or have the proceeding remain undismissed and unstayed for ninety (90) days; (iv) Make a general assignment for the benefit of creditors; or (v) Have a receiver or trustee appointed for it or for the whole or any substantial part of its property. (e) Any representation or warranty made by the Company herein or any statement in any report, certificate, tinancial statement or other instrument furnished in connection with this Agreement or with the purchase of the Bonds shall at any time prove to have been false or misleading in any material respect when made or given. w 61 91--1 ~ ,~'. (t) There shall have occurred an "Event of Default" as defined in Section 6.2(c) or (d) of the Mortgage. Notwithstanding the foregoing, if. by reason of Force Majeure. the Company is unable [Q perform or observe any agreement. term or condition hereof which would give rise to an Event of Default under subsection (c) hereof, the Company shall not be deemed in default during the continuance of such inability. However, the Company shall promptly give notice to the Trustee and the Issuer of the exislence of an event of Force Majeure and shall use its best efforts to remove the efft."Cts thereof; provided that the settlement of strikes or other industrial disturbances shall be entirely within hs discretion. The tenn Force Majeure shall mean. without limitation. the following: 0) Acts of God; strikes, lockouts or other jndustriaJ disturbances; acts of public enemies; orders or restraints of any kind of the government of the United SImes of America or of the State or any of their departments, agencies, political subdivisions or ofticials, or any civil OJ' miHtary authorhy; insurrections; civil disturbances; riots; epidemics; landslides; lightning; earthquakes; fires; hurricanes; tornados; storms; falling space debris; droughts; floods; killer bees; arrests; restraint of government and people; explosions; breakage, malfunction or accident to facilities, machinery, transmission pipes or canals; partial or entire failure of utilities; shortages of labor, malerials, supplies or transportation; or (ii) Any cause, circumstance or event not reasonably within the control of the Company. ! I - . ....--. The declaration of an Event of Default under subsection (d) above, and the exercise of remedies upon any such declaration, shall be subject to any applicable limitations of federal bankruptcy law affecting or precluding that declaration or exercise during the pendency of or immediately following any bankruptcy, liquidation or reorganization proceedings. Section 7.2. Remedies on Default. Whenever an Event of Default shall have happened and be subsisting, anyone or more of the following remedial steps may be taken: (a) If acceleration of the principal amount of the Bonds has been declared pursuant to Section 7.03 of the Indenture, the Trustee shall declare all Loan Payments to be immediately due and payable, whereupon the same shall become immedialely due and payable. (b) The Issuer or the Trustee may have access to, inspect, examine and make copies of the books, records, accounts and financial data of the Company pertaining to the Project. In accordance with applicable law, the Trustee or its designees, may (i) enter and take possession of the Project, or any part thereof, by summary proceedings or ejectment or otherwise, without terminating this Agreement, o 62 Cf9~ 1'1 ~.I~~~_~__"L"':___. - .,.' (ii) collect rentals and enforce all olhcr rcmedies of the Company under any leases of, or assignments or grants of rights to use or occupy, the Project, or any part thereof, but without being deemed to have affirmed the leases. assignments or grants. ,.) (Hi) elller into new leases, assignments and grants on any terms which the Trustee may deem to be suitable for the Project, or any part thereof, which leases, assignments and grants shall not be terminated or affected if the Company cures the Event of Default, (iv) remove the Company, all other Persons and all property from the Project, or any part thereof, (v) hold, operate and manage the Project, or any pan thereof, and (vi) receive all earnings. income. rents. fees. charges. issues. profits. proceeds or other sums accruing with respect thereto. ',-./ All amounts described in clauses (ii) or (vi) of the preceding sentence may be applied by the Trustee to any costs of administration, operation, repair or maintenance of the Project, or any part thereof, as the Trustee may deem reasonably useful, and the remaining balance shall be applied to the Loan Payments, Additional Payments and other amounts payable, or to become payable. under this Agreement, in the order of priority to be determined by the Trustee. Any balance of the rents and other amounts femaining thereafter shall be paid promptly to the Company by the Trustee, and the Trustee may hold the Company liable for the difference between those rems and other amounts and the Loan Payments, Additional Payments and other amounts payable under this Agreement. (c) In accordance with applicable law all Revenues shall become payable immediately directly to the Trustee, and the Trustee may take whatever steps it deems to be necessary or advisable to notify payors of the Revenues of the Trustee's right thereafter to receive payments of Revenues directly. (d) The Issuer Of the Trustee may pursue all remedies now or hereafter existing at law or in equity to collect all amounts then due and thereafter to become due under this Agreement, the Mortgage or the Notes Of to enforce the performance and observance of any other obligation or agreement of the Company under those instruments. (e) The Trustee may exercise any or all of any combination of remedies under the Mortgage, pursuant to the Assignment. --) Notwithstanding the foregoing, the Issuer and the Trustee shall not be obligated to take any step which in its opinion will Of might cause it to expend time or money or otherwise incur liability unless and until a satisfactory indemnity bond has been furnished to the Issuer and the Trustee at no cost or expense to the Issuer or the Trustee. Any amounts collected as Loan Payments or applicable to Loan Payments and any other amounts which would be applicable to payment of 63 91 ~ / '6'" __......IL'JIo__~----........~~~.."--L...a -. ..<I>. /-'..., I Debt Service Charges collected pursuant to action taken under this Section shall be paid into the Bond Fund and applied in accordance with the provisions of the Indcnture or, if the outstanding Bonds have been paid and dischargc..>d in accordance with the provisions of the Indenture. shall be paid as provided in Section 5.08 of the Indenture for transfers of remaining amounts in the Bond Fund. The provisions of this Section are subject to the further limitation that the rescission by the Trustee of its declaration that all of the Bonds are immediately due and payable also shall constitute an annulment of any corresponding declaration made 'pursuant to paragraph (a) of this Section and a waiver and rescission of the consequences of that declaration and of the Event of Default with respect to which that declaration has been made, provided that no such waiver or rescission shall extend to or affect any subsequent or other default or impair any right consequent thereon. ...._.I"j Section 7.3. No Remedy Exclusive. No remedy conferred upon or reserved to the Issuer or the Trustee by this Agreement is intended to be exclusive of any other available remedy or remedies, but each and every such remedy shall be cumulative and shall be in addition to every other remedy given under this Agreement, the Mortgage or the Notes, or now or hereafter existing at law, in equity or by statute. No delay or omission to exercise any right or power accruing upon any default shall impair that right or power or shall be construed to be a waiver thereof. but any such right and power may be exercised from time to time and as often as may be deemed expedient. In order to entitle the Issuer or the Trustee to exercise any remedy reserved to it in this Article, it shall not be necessary to give any notice. other than any notice required by law or for which express provision is made herein. Section 7.4. Aerccmcnt to Pay Attorneys. Fees and Expenses. If an Event of Default should occur and the Issuer or the Trustee should incur expenses, including attorneys. fees, in connection with the enforcement of this Agreement, the Indenture, the Mortgage, the Assignment or the Notes or the collection of sums due thereunder, the Company shall reimburse the Issuer and the Trustee, as applicable, for the expenses so incurred upon demand. If any such expenses are not so reimbursed, the amount thereof, together with interest thereon from the date of demand for payment at the Interest Rate for Advances, to the extem permitted by law, shall constitute indebtedness hereunder which is secured by the Mortgage and in any action brought to collect that indebtedness or to foreclose the Mortgage, the Trustee or the Issuer, as applicable, shall be entitled to seek the recovery of those expenses in such action except as limited by law or by judicia] order or decision entered in such proceedings. Section 7. 5. ~ Waiver. No failure by the Issuer or the Truslce to insist upon the strict performance by the Company of any provision hereof shall conslitute a waiver of their righl to strict performance and no express waiver shall be deemed to apply to any other existing or subsequent right to remedy the failure by the Company to observe or comply with any provision hereof. .J 64 91- I ~ '>(1/ . . , ~'.: " " .' . . . " ' ;~'!<(, .' '. ' - :.' . ". E". '/ .' :, .'1. ". .' ~~~~ '.Id .. H " ' '/. .: ".;, .... '. ;r.~ i. ;:...) ....;, ,~.._......; , ,.:i.' , ~,~-:.. r ': . .~ < ' . ", . ~ . <, .' .,.1:.,. . i';,.'. ~ f" . . f' ~ , ....... " ;-r~:'~'..' " . .\~,. ,". > . "{ " ;-.;' , ":1. '1('.. . ") \.' . .','1 ' , ,', ,. ,..... .; . , ",. . t:.:.,O"./' . . . , . . . .. . . , ,. ,I; .. , '.' .., .:. . , '.~) ',-, ,',' '"'c ,', . .Section 7.0. MoJice of Default. The Company shall notify the Trustee immediately if it becomes aware of the occurrence of any Event of Default hereunder or of any fact. condition or event which, with the giving of notice or passage of time or both~ would become an Event of . Default. . . (End of Article VII) , , .;, .." . , . . , ' 65, " .'fq-/~ ,r""', " .~ c.: . ...........,vJ~ o ARTICLE VIII MISCELLANEOUS Section 8.1. Tenn of A~reement. This Agreement shaH be and remain in full force and effect from the date of delivery of the Series 1999 Bonds to the original pu rchascrs until such time as all of the Bonds shall have been fully paid (or provision made for such payment) pursuant to the Indenture and all sums payable and any other documents execuled and delivered by the Company in connection with the execution and delivery of the Bonds by the Company under this Agreement. the Indenture, the Mortgage and the Notes shall have been paid; except for obligations of the Company under Sections 4.2, 5.5 and 5.12 hereof, which shall survivc thc terminalion and this Agreement. Section 8.2. Amounts Remaining in Funds. Any amounts in the Bond Fund remaining unclaimed by the Holders of Bonds for four (4) years (or such earlier date as such funds would be required by law to 'escheat to the State) after the due date thereof (whether at stated maturity, by redemption or pursuant to any mandatory sinking fund requirements or otherwise) at the option of the Company shall be deemed to belong to and shall be paid, at the written request of the Company, to the Company by the Trustee as overpayment of Loan Payments. With respect to that principal of and any premium and interest on the Bonds to be paid from moneys paid to the Company pursuant to the preceding sentence, the Holders of the Bonds entitled to those moneys shall look sojely to the Company for the payment of those moneys. Further ~ any amounts remaining in the Bond Fund. the Project Fund. lhe Reserve Fund. the Rebate Fund and any other special funds or accounts created under this Agreement, lhe Mortgage or the Indenture after all of the outstanding Bonds shall be deemed to have been paid and discharged under the provisions of the Indenture and all other amounts requircdto be paid under lhis Agreement~ the Notes, the Mortgage and the Indenture have been paid, shall be paid to the Company to the extent that those moneys are in excess of the amounts necessary to effect the payment and discharge of the outstanding Bonds and pay other amounts due under the Indenture. Section 8.3. Notices. All notices, certiticates, requests or other communications hereunder shall be in writing and shall be deemed to be sufficiently given when mailed by registered or certified mail, postage prepaid, and addressed to the appropriate Notice Address. A duplicate copy of each notice, certificate, request or other communication given hereunder to the Issuer, the Company or the Truslee shall also be given to the oUlers. The Company, the Issuer and the Trustee, by notice given hereunder. may designate any further or di fferent addresses to which subsequent notices, certificates, requests or other communications shall be sent. Section 8.4. Extent of Covenants of lhe Issuer~ No Personal Liability. All covenants, obligations and agreements of the Issuer contained in this Agreement or the Indenture shall be effective to the extent authorized and permitted by applicable law. No such covenant. obligation _ or agreement shall be deemed to be a covenant, obligation or agreement of any prcsent or future member, officer, agent or employee of the Issuer in other than his oftlcial capacity, and neither 66 11" / ~ .--) the members of the Issuer nor any official cxecuting the Bonds shall be liable pcrsonally on the Bonds or be subject to any personal liability or accountability by reason of the issuance thereof or by reason of the covenants. obligations or agreements of the Issuer contained in this Agreement or in the Indenture. Section 8.5. Bindin2 Effect. This Agreement shall inure to the benefit of and shall be binding in accordance with its terms upon the Issuer, the Company and its permitted successors and assigns provided that this Agreement may not be assigned by the Company and may not be assigned by the Issuer cxcept to the Trustce pursuant to the Indenture or as otherwise may be .necessary to enforce or secure payment of Debt Service Charges. Section 8.6. Amendments and Supplements. Except as otherwise expressly provided in this Agreement or the Indenture, subsequent to the issuance of the Series 1999 Bonds and prior to all conditions provided for in the Indenture for release of the Indenture having been met. this Agreement may not be effectively amended, changed, moditied, altered or terminated except in accordance with the provisions of Article VIII of the Indenture, as applicable. Section 8.7. Execution of Counterparts. This Agreement may be executed in any number of counterparts, each of which shall be regarded as an original and all of which shall constitute but one and the same instrument. Section 8.8. Severability. If any provision of this Agreement, or any covenant, '...........1 obligation or agreement contained herein is determined by a court to be invalid or unenforceable, _.J that determination shall not affect any other provision, covenant, obligation or agreement, each of which shall be construed and enforced as if the invalid or unenforceable portion were not contained herein. That invalidity or unenforceability'"shall not affect any valid and enforceable application thereof, and each such provision, covenant, obligation or agreement shall be deemed to be effective, operative; made, entered into or taken in the manner and to the full extent pennitted by law. ,~- '~ ) ;~ 67 , qq-/'t i1.lr..;I~ .....,:~<,.. ,..- . ..:.._-.........-...--~ r1r.Ml]--"~ ~.~ , ' " . ,);,/: " ". :) ", Ii " .' ~ . " .. :/'. . ,+. . . : .: -. "\ ":,.. . 1 . ',..../ .--''''', (.;) I. . /1 t' Section 8.9. Govemin~ Law. This Agreement shall be deemed to be a contract made under the laws of the State and for all purposes shall be governed by and construed in accordance with the laws of the State. IN WITNESS WHEREOF, the Issuer and the Company have caused this Agreement to be duly executed in their' respective names, all as of the date hereinbefore written. (SEAL) CITY OF CLEARWATER, FLORIDA Attest: By: City Clerk By: Mayor-Commissioner Approved as to fonn and . legal sufficiency' By: City Attorney' By: , , City Manager (SEAL) BEF, INC. Attest: , By: Secretary By; President 68 qq,. / ~ EXHIBIT A /) fu:ries 1999 Note $ [Date] FORM OF SERIES 1999 NOTE BEF. Inc, (the "Company"), a corporation duly organized and validly existing under the laws of the State of Florida (the "State") and qualified to transact business in the State. tor value received. promises to pay to the City of Clearwater, Florida, (lhe "]ssuert1). DOLLARS ($ ) and to pay interest (as hereinafter provided) on the unpaid balance of such principal sum from and after 1, 1999, until the payment of such principal sum has been made. This Note has been executed and delivered by the Company to the Trustee pursuant to a certain Loan and Security Agreement (the "Agreementl1) dated as of July 1, 1999. between the Issuer and the Company. Under the Agreement, the Issuer has loaned the Company the principal proceeds received from the sale of the Issuer's $ aggregate principal amount of Health ....\ Care Facilities Revenue Bonds, Series _ (BEF, Inc. Project), dated as of , 1999 (the 0,_.1 "Series _ Bonds"), to assist in the financing of (the "Project") and the Company has agreed to repay such Joan and interest thereon by making payments ("Loan Payments") in the amounts required to pay the principal of, premium, if any, and interest on the Series _ Bonds, collectively called the I1Debt Service Charges," as and when due. The Series _ Bonds have been issued, concurrently with the execution and delivery of this Note. pursuant to, and are secured by, the Trust Indenture (the "Indenture"). dated as of July I, 1999, between the Issuer and First Union National Bank of Florida. a national banking association, as Trustee (the "Trustee"). The principal hereof, prepayment premium, if any. and interest (including any Additional Amount) herein shall be payable from time to time in amounts equal to the Debt Service Charges becoming due and payable from time to time whether at scheduled payment dates or on account of redemption or acceleration of the Series 1999 Bonds, or otherwise and shall be payable by the Company to the Trustee on or before the twenty~fifth day of each calendar month and such other days upon which payments may be required under the terms of the Agreement or the Indenture. The unpaid principal amount of the Series 1999 Bonds outstanding from time to time shall bear interest from the most recent Interest Payment Dale to which interest has becn paid or duly provided for or, if no interest has becn paid or duly provided for. from their Dated Date. v ]n addition to the Loan Payments, the Company shaH pay to the Issuer and [0 the Trustee all Additional Payments which may become payable to them under Section 4.2 of the Agreement. 11- /C{ .' '') .' ""-/ o The covenants contained in this paragraph shall survive (a) the payment and cancellation of this Note. (b) the payment of the Series 1999 Bonds, (c) the termination of the Agreement and (d) the discharge of the Indenture and each person who shall be entitled to payment of any Additional Payments shall have a claim, enforceable against the Company. therefor. All Loan Payments shall be payable in lawful money of the United States of America in immediately available funds and shall be made to the Trustee at its designated corporate trust oftice for the account of the Issuer and will be deposited by the Trustee in the Bond Fund crealed by the Indenture. Except as otherwise provided in the Indenture, such Loan Payments shall be used by the Trustee to pay the Debt Service Charges as and when due. The obligation of the Company to make the Loan Payments and Additional Payments shall be absolute and unconditional and the Company shall make such payments without abatement. diminution or deduction regardless of any cause or circumstances whalsoever including, without limitation, any defense. set-off, recoupment or counterclaim which the Company may have or assert against the Issuer, the Trustee or any other person. ". This Note shall be prepaid, in whole or in part prior to stated maturity, as provided in the . Agreement if the Series 1999 Bonds are called for redemption. in whole or in part. as provided in the Indenture. The Company shall have no right to prepay this Note except (i) pursuant to the exercise by the Company of any right given in the Indenture to direct the redemption or purchase of Series 1999 Bonds, (ii) upon the occurrence of a Determination of Taxability and a redemption of the Series 1999 Bonds in accordance with Section 6.2 of the Agreement and (jji) to defease Bonds as provided in the Indenture; in the latter case. principal of this NOle shall be reduced by the principal amount of Bonds defeased. Whenever an event of default under Section 7.01 of the Indenture shall have occurred and. as a result thereof, the principal of all Bonds then Outstanding, and interest accrued thereon, shall have been declared to be immediately due and payable pursuant to Section 7.03 of the Indenture, the unpaid principal amount of and accrued interest on this Note shall also be due and payable on the date on which the Debt Service Charges on all of the Bonds shall have been declared due and payable; provided that the annulment of a declaration of acceleration with respect to the Bonds shall also constitute an annulment of any corresponding declaration of acceleration with respect to this Note. 11- Iff C1~~.Lt~r"\ ,..n~" . t. . "........-..... -.............. . '~ , <' "", ,~. . .'c J '. '"ZJ ' '.., < , . '....l,.. -;'. . _,i,"C,. 1::" . , . ~.' ' ~.,: : '. . .. '~""\ ....."J ,.. .,',0 . ~. . . . .[, . ~. . ~ . " I ' The Company's obligations under the Agreement and this Series _ Note are secured by the Mongage and Security Agreement (the "Mongagell) from the Company, as Mortgagor, to the Issuer, as Mortgagee, dated as of JuJy I, 1999, as assigned by the Issuer to the Trustee pursuant to an Assignment ot',Mortgage,'dated as of July 1.1999. The Company hereby waives presentmentt notice of dishonor and protest. IN WITNESS WHEREOF, the Company has caused this Note to be executed in its name by its ~uly authorized officers as of BEF, INC., a Florida not-for-protit corporation Attest: "By: . Title: . , By: Title: 19,/f. . ~. . --,._> ... ~ ;1' ~'." '. . " '-:"\, .. ~'.} ~ .: . . . 'l. ' . '"," , "..' ] . '. ...".....-/ l \"t ~ ..... , :'.~ . " it o ASSIGmfENT TO TRUSTEE . . . . . : For value received, the undersigned hereby sells. assigns and transfers without recourse unto SUNTRUST BANK, CENTRAL FLORIDA, NATIONAL ASSOCIATION, as Trustee, under the Indenture of Trust dated as of.luly 1, -1999, the within Note and all rights thereunder. . (SEAL) CITY OF CLEARWATER. FLORIDA . , By: Mayor~Commissioner ATTEST . By: . City Manager ., . Secretary . Approved as to form 'and legal sufticiency By: . City Attorney 19~ /~ I r , I 1 I '~f~~""~~~~'::'::':'::'~Uh-:' ~:_'.___._ .'.. ., ...~ ',......, .c..... '''h .l.. ...1' .. ~. . . . .. . <. ~ ~' , .' ,. -,,-:-- t.,' ': . , , ,~ .. .. , n, . ,.';.' - . :/, .~. / " ',. . ,.. I c~. ...." . ", , " EXHIBIT B ! ; ! I '(J "~""".t DESCRIPTION OF THE PROJECT r. .1 ,,' . " The Series 1999 Bonds will be issued for the principal purpose of tinancing the cost of acquisition. construction and.. rehabilitation of various capital improvements to the. Oaks of Clearwater retirement facility' consisting of 1 building, the Cove Building, located at 210 South Osceola, Clearw~tert Florida, including the following renovation projects to the Cove Building: ::. ' . ~, . -,' " . ;f'.. c~ .' ; . I:: . :~'';', .,.. .. .::,'1.." . . i' . I I j .1 I I . ' l ~ ~ , , ~~' t \~ ~, , ., , " If. :: .. " ' I.:: ' .'{.' , . {', : (' ~, ' ' . ~~ "l .>.-:.~~; . '\ :', . \..-/ I'" ,,", . ~', ,. I" .; . , , , . . , .' .:.. , , ':0 91~/r 1 II I . B-1 . ~~~':::-~":":'~'':::~._'~:_~~::::''.' .-;....,-.~........til.~f...I-,. .~,..~."......... ' . -,. ,. ,..........,. ~"w ...;s:~ ......n". ,.. " . ....,,~......~, ..t"" _ I... p' '_'I~~t~'" '... ..~ "'"",,,c~._. ----- "i. , "'", ~. . ~::.',;. , '~:~.',,">"', ~. , ,. ..... > ". .i.:. '. " ~~ !,. ,.~ - .... , , . i:- ,c ~'f .' '~I.t...""., . .:1:: 1 ;1 I,.' " " '. i:;., . I 1 ~. 11., o .:-.(. ."';1 ~. !' :,r .~-: '~ . ; . '..'; " : ': " I' . ~~, . . . .1." <'" (:--'.:. .'t.: :..,.,' ~:::.~ !L~-..' . " t::.:':," .~, c ,f::,I, r ,':,: I~l:',,::.' _. ;~? '; it>..: .,., .; ~ I . ~ {'r'~',::1 ,... .,. ;f,:": ~:-: :',;: ;,.' /"'(2)">' . ;':.' \. '., q. \': ~ .1 .' .. ". f,;~ , \.', I,. ,:.. ~ '. \ . y' :r ~, '.- .: ~ I~-: . ;1,_ ~~ ,-;: '. :;1 ',.. ,1.: '. j: 1-; , . . :.:J'''~'' , ' , \ . ,\ : ," , . \' .~'~ ~ ' ,~ '-l " .'1' " " , . EXHIBIT C PROJECT SITE LEGAL DESCRiPTION COVE BUILDING [TO BE PROVIDED] , ,t C-l I .J I r 'i I I j, il I; I I I '11/ If( EXHIBIT D ,'......, " ...,1 FORM OF DISBURSEMENT REQUEST STATEMENT NO. _ REQUESTING DISBURSEMENT OF FUNDS FROM PROJECT FUND PURSUANT TO SECTION 3.4 OF THE LOAN AGREEMENT (dated as of July 1, 1999, between City of Clearwater. Florida and BEF. Inc. a Florida not-for-profit corporation) ., . Pursuant to Section 3.4 of the above-referred to Loan Agrccment (the "Agreement") between the City of Clearwater. Florida (the "Issuer") and HEF, Inc, a Florida not-far-profit corporation (the "Company"), the undersigned Authorized Company Representative hereby requests and authorizes SunTrust Bank. Central Florida, National Association, a national banking association, as trustee (thc ttTruslee") and depository of the Project Fund created by the Indenture (as detined in the Agreement), to pay to the Company pr to the person(s) listed on the Disbursement Schedule hereto. from the moneys deposited in the Project Fund, the aggregate sum 0[$ to pay such person(s) or to reimburse the Company in full. as indicated in the Disbursement Schedule, for the advances, payments and expenditures made by it in connection with the items listed in the Disbursement Schedule. In connection with the foregoing request and authorization, the undersigned hereby certifies . -. "'. that: '.--~I (a) Each item for which disbursement is requested hereunder is properly payable out of the Project Fund in accordance with the terms and conditions of the Agreement and none of those items has formed the basis for any disbursement heretofore made from said . Project Fund. (b) Each such item is or was necessary in connection with the acquisition, construction, installation, equipment or improvement of the Project, as defined in the Agreement. (c) In the case of amounts requested hereunder for the payment of any item of labor or materials subject to the Mechanics Lien Law of the State, the Company has received, or will concurrently with payment receive and deliver to the Trustee. appropriate waivers of any mechanics' or other liens with respect to each hem for which disbursement is requested hereunder. '0 (d) Each item for which disbursement is requested hereunder and the cost for each such hem. is as described in the int'ommtion stalement tiled by the Issuer in connection with the issuance of the Series 1999 Bonds (as defined in the Agreement), as requi red by Section 149(e) of the Code; provided that if the foregoing statement is not true, attached hereto is a computation evidencing that the average reasonably expected economic life of the 0.1 11- /'6 ,<-" I "" 'I .,,J , ' o facilities which have been and will be paid for with money in the Project Fund is not less than 5/6ths of the average maturity of the Series 1999 Bonds. (e) This statement and all exhibits hereto. including the Disbursement Schedule. shall be conclusive evidence of the facts and statements set forth herein and shall constitute full warrant, protection and authority to the Trustee for its actions taken pursuant hereto. (t) This statement constitutes the approval of the Company of each disbursement hereby requested and authorized. In connection with any item on the Disbursement Schedule which relates to payment or reimbursement for labor, services. material, supplies and/or equipment rclating to the acquisition. construction and equipping of the Project, the undersigned further certifies as follows: (1) That each person signing this rcquest has no notice of any mcchanic's. materialmen's, suppliers', vendors' or other similar Iicn or right to lien, chattel mortgage or conditional sale contract, or other contract or obligation (other than those being contested in good faith as pennitted by Section 3.2 of the Mortgage, as defined in the Agreement), which should be satisfied or discharged before payment is made of the item or items set forth on the Disbursement Schedule opposite such person's name; (2) That this request contains no request for payment on account of any portion of anobJigation which, as of the date of this request, is entitled to be retained under any holdback or retainages provided for in any agreement; and (3) That such labor or services were actually perfomled in a satisfactory manner and such material, supplies, and/or equipment were actually used in the construction or installation of the Project or were delivered at the Project Site (as defined in the Agreement) and will be used for that purpose. This day of , 199_. Authorized Company Representative 0-2 Cf!-/S C"lio'''~'::'''';'';I~~'1o'. ~'''' .' '. -.- .-----....................-.-................-.-....---.- , . \':.,; .. ~~.. ''"'" , .~, , . I . '.' . .' ;', I ~~, !' I' I'.. , \. ., ,; ~:.j : .~ ',' . ~::'. : . .; ;" ~ '. . ~ 1 " '. .' / :-~", .. . \ .'. ~ . :....;..;/ " :' J '. I :,1. o i1J~~ii~,::~ :...T~..5'" ....,n........,. ~ :' L ~ , t. I..' .'. . ,< ,c . .~.I.:'~.:....... --~-~~-~-~-- I " ' ",,' c ...\ . ',J' c .' DISBURSEMENT SCHEDULE 'ro' STATEMENT NO.. REQUESTING AND AUTHORIZING DISBURSEMENT OF FUNDS FROM PROJECT FUND PURSUANT TO SECTION 3.4 OF THE LOAN AGREEMENT between the City of Clearwater, Florida and BEF, Inc~ a Florida . not~for~profit corporation.. . PAYEE , . , . . '~ '''.., '. I. M ....c. '. ~. ,.~, j. r' ~ ' .., . .. " . ", . . AMOUNT PURPOSE 0-3 qlj-/C{ II l : . IC L~' ;... l., " ~~. . c' ' ." ,.... c .'~ '" .... ..:. ,'" '" . f. " .~. , ~ . ~ " , , .. .' ' ':;;~~"~I ,:..., .....<.J..),';....ci.":...\.-...~:'.c :.' ~' , , , ' ..', . ( ,:. .' ,. , . " ,;, , , ....,> ;. ..It." " '. ;'\.', :: :{; ;" (t, .'_. ?~:. t'::: ,'~ .~'. ~. '~'.>. '1'. ~.. , . . , : " ,. , ". . .> ;::,~,:'<=}, :..' .i' , L' . ;iJ 'c ,', . >: ....: ' , '. ,.',',1, '.' , ':. ':)'." '\. . '.. ,\' . .~~~~..~~....::: " '~,r ',1' ;. -.,....--. EXH mlT E EXISTING PERMITTED LIENS E-I 1q -/'6 t~ ~ \.., ".j. "~~~l' > ~ '~I.~.'" u ., . .,... \.. ~ " .: ' ',~. : .. . ,', t' ~ i. .... .' . . .... 'f~"" . 1:1.~,.j, c_"", ~'n .. . . I i I ! I I I 11 Ii I I I I ~ ': "' ,': : . ",'1 :i \ ,. "3' . el. " ~ " ,., :,': . ' .,', 1.'- ,"'" .,. " .." j' . ~, -.. . r: "" ~/. ('. ..~' 'l :/:l .'/ .....0. : '. .'L , , , "',; :,I) :\' t:~ F ..... ,', ! ",c ~ I " .Ii ,'. "J' . . '~ . , . ~ '. .~ ' , ,:., .' , ' ,. , ' " , , -...-...............::.__.~ . EXHIBIT F EXCLUDED PROPERTY : \ .' .. .. "i.'f' :. ,: G~l 91'-lct '\ I::: ,,' \;'. ,".: ,~\.: ,,- ,~. ,. ;, .. ,~ ~ .' : j" I. J . ~.:.. ~~ I", I},.:, I"~> :...1: :". \.:, . !. ; ~ , , " ' ~ "l ,', . } .... ~,., , '" " . .' .'. 'u::- , ' " '., ~':; : :; '~ + \ r: ';., ..., 0""" . . ~\ ' '... . '{:.: .~. . {LI. ~ ~; > ; " . :..1': . ,. ';. . '. F " . ~ ..\ " ',.' . ", ," 0 . ~!, ~:>"!: I .~,. . .' . . .J ," ". " ~ ':'. . " ",,""""""":... EXHffilT D FORM OF ASSIGNMENT OF MORTGAGE AND SECURITY AGREEMENT Resolution 99~ 18 "I. . j . ! I . I ! , ~ . ~ ' - .~ !" J ~ .........". , \......~/ ~, .1 -J ..do.........)l... ~*..~ ~", . .. This Instrumcnt prepared by and rcturn to: Robert C. Reid, Esq. Bryant, Miller and Olive. P.A. 201 South Monroe Street Suite 500 Tallahassee, Florida 32301 ASSIGM\.fENT OF MORTGAGE AND SECURITY AGREEMENT GO CITY OF CLEARWATER, FLORIDA. a municipal corporation duly created and existing under the laws of the State of Florida (the" Assignorll), in consideration of the sum of Ten and NollOO Dollars ($10.(X}) and other good and valuable consideration received from SUNTRUST BANK, CENTRAL FLORIDA. NATIONAL ASSOCIATION, a national banking associalion, as Trustee (the" Assignee"), DOES HEREBY grant. bargain, sell, assign, transfer and set over unto the Assignee (i) all its right, titlc and interest in and to that certain Mortgage and Security Agreement, executed by BEF, Inc., a Florida not-tor-profit corporation duly organized and validly existing under the laws of the State of Florida. in favor of the Assignor. dated as of July 1, 1999, and recorded in Official Records Book _, Page _, of the Public Records of Pinellas County t Florida {the tt Mortgage") , said Mortgage encumbering the real property legally described as set forth on Exhibit A attached hereto and incorporated herein by this reference, except its right. title and interest in the Mortgage to the extent the Mortgage secures Company obligation with respect to the Unassigned Rights and (ii) all its right, title and interest in and to that certain Note described in and secured by the Mortgagc, and all monies and payments due and to become due . thcreon, togethcr with interest thereon from lhc date of this Assignment of Mortgage. IN WITNESS WHEREOF, this Assignment of Mortgage and Security Agreement has been duly executed by Assignor as of July 1, 1999. (SEAL) ATTEST CITY OF CLEARWATER, FLORIDA a municipal corporation, duly created and existing under the laws of the State of Florida By: City Clcrk Mayor-Commissioner Approved as to 1brm and legal sufticiency By: City Manager By: City Attorney CjCf-/r? .' ~. .". ~ . .) 4 -.... ..: ) ''....../ ;, ,. ,.' , \' , .,' ;:',: -. , ,:) STATE OF FLORIDA ) ) SS COUNTY OF PINELLAS ) I HEREBY CERTIFY that on this day, before me. an officer duly authorized in the state and county aforesaid to take acknowledgments, personally appeared and , the Mayor-Commissioner and City Manager, fespectively of the City of Clearwater, Aorida, a municipal corporation duly created and existing under' the laws of the Sate of Florida, respectively. to me known to be the persons described in and who executed the foregoing Assignment of Mortgage and acknowledged before me that they, as such ofticers and with full authority, executed same voluntarily for and as the act of the City of Clearwater t Florida. .. WITNESS my hand and official seal in the county arid state aforesaid this , 1999. (SEAL) day of Name: Notary Public, State of Florida My Commission Expires: Personally. Known 0 Of Produced Identification 0 Type of Identification Produced 2 '7.~~'a1l:"'~ .> ". . .. ',11' ' .,.: .. ~ . . _.'.. ."... K'" p'. . ~ 99-/~ c . .,,' .".,' " ,. . ~ ~ '-, . ,-.-J <~ CONSENT TO ASSIGNMENT OF MORTGAGE The undersigned hereby consents [0 the assignment of that certain Mongage and Security Agreement,' executed by the undersigned and dated as of July I, 1999, from the City of . Clearwater, Florida to First Union National Bank, as Trustee, by and pursuant to the Assignment of Mortgage to which the consent is attached. Signed and acknowledged in the presence of: - BEF INC.. a Florida not-for-profit corporation By: Tille: President Attest: Title: Secretary Witnesses as to BEF Inc., a Florida not-for- profit cO,rporation STATE OF FLORIDA ) ) 55 COUNTY OF PINELLAS ) The foregoing instrument was acknowledged before this 1999 by and Secretary respectively t of BEF Inc. day of the President, and IN WITNESS WHEREOF, I have hereunto set my hand and seal as of this , 1999. day of (SEAL) Name: Notary Public, State of Florida My Commission Expires: Personally Known 0 or Produced Identification 0 Type of Identi tication Produced 3 r9-1f?' _ ...of'I1_ ~ _~............. ~~ h.. ~.- ~__ LlI , " ./ .\ ' ", " .! . ,'. J ~ lr..,,: , , f~~~?i;:'\:~::?t~;;"", i: '; , ::: .~ .;'. ' ': .' ~ ~t. .> (:,:'; .~. : ')t:>. ." ..t,J:\~:' : ~>t<I.. 'r';;: t" .". d'l .. i I I / f ! j ! I I .,. EXHmIT A " l" ,. LEGAL DESCRIPTION ~>! {.',". ,'..'j: i:{':~;"",,: :~~?", 'y:'.~ ' I I" .>!..... '\:':"',"': , ~ ... . .. i"i.~\~> i ~~:,;(', ". '.' ", 1..1,,:: r.;' ~ ..... ", . ~ . " -' .i ( . ~: ..I~~:~ - ..'t .~ . , ,; :I.i., '..: . ::~. , '." ':.:J J(' " ';1. . .,' " ~ ," . . "." . ~ ~~i ?, ~.., ~ . " , .99-/~ ". <".. ..".... " ... "'\.>'~w~.r~ ....r"..~..~~, . ~ ' t ,'. " ~. '.h:.' ,'\;..' L. (j .c.-...... ''':i ,"'.'- . ~.~",: , . .,' ,/~ 'v 1 :.:.. ,. ((' , ik\; ,. . \':' \ .1 '1,' :, '0 !:": ,'. ..~ J'. , .. ~ ',/ , ! .', EXHIBIT E FORM OF BOND PURCHASE AGREEMENT '/ " ., '~ : . , '; y "~: , ,t U . , . ~, _ .1:' ~ ., . " '~... It:~i'j.~~.~~: '~... Resolution 99-18 .. ~ V;-' JllI.~~-..a.r..r...::-.......-.....-"':''''':'''__.:,~.' . T'_~~' <".. ~ <" '. DRAFI' ff[^) 3: 6/8199 07310.C[^] . ,/~ BOND PURCHASE AGREEMENT :1 I,' " I'.:' CITY OF CLEARWATER, FLORIDA REVENUE BONDS, SERIES 1999 (DEF, INC. PROJECT) . . S CITY OF CLEARWATER, FLORIDA REVENUE BONDS, SERIES 1999A (DEF, INC. PROJECT) S CITY OF CLEARWATER, FLORIDA (^] REVENUE DONDS, SERIES 1999B (^](BEF, INC. PROJECT), EXTENDABLE RATE ADJUSTABLE SECURITIESSM(EXTRASSM) .' .....\ '--./ . S CITY OF CLEARWATER. FLORIDA TAXABLE REVENUE BONDS. SERIES 1999C (DEF. INC. PROJECT) ,1999 Undenvritten By: B.C. Ziegler and Company , ~~'.\ J I. 49-/~ ~~~~~ ~L. ~;. ' ~ . ~ . d.. ,', "". . I, .., . . ..< ." .. . ), I BOND PURCHASE AGREEMENT '...) This Bond Purchase Agreement (this lIPurchasc Agrcementlt), dated , 1999, is made by and among the following parties (hereinafter collectively called the "Parties"), namely: City of Clearwater, Florida (the ItIssuer"); BEF, Inc., a Florida not-for-profit corporation (the UCompanyU); and B.C. Ziegler and Company (the "Underwriter"). , I ! '....~/ \ ,J ,,~..' ~\ ..~ rU. ~.+ .' ARTICLE I DEFINlTIONS SECTION 1.1. Participants. In addition to the Parties, various persons and firms will participate in the financing to which this Purchase Agreement relates. Among them are those identified below (hereinafter collectively called the "Participants"): Authorized Officers: In the case ofthe Company, its President or any Vice President and its Secretary or Treasurer. Bond Counsel: Bryant, Miller and Olive, P.A. Tallahassee, Florida. Moore Stephens LoveLace, P,A. Accountants: Company's Counsel: Baker & Hostetler LLP Orlando, Florida. The person at the time incumbent in the office of Mayor-Commissioner or Vice-Mayor-Commissioner of the Issuer, or in the event of the death, disability or absence of such person(s), then the person duly authorized and legally empowered to perform the duties of such office in such event. SunTrust Bank, Central Florida. National Association Mayor-Commissioner: Trustee: City Clerk: The person at the time incumbent in the office of City Clerk of the Issuer or any Deputy City Clerk, or in the event of the death, disability or absence of such perso", then the person duly authorized and legally empowered to perform the duties of such office in such event. Pamela K. Akin, Esquire, City Attorney Clearwater, Florida. The City Commission Issuer's Counsel: Issuer's Governing Body: Underwriter's Counsel: Nabors, Giblin & Nickerson, P.A. Tampa, Florida. 1 19' IV SECTION 1,2. Contracts. Instruments and Documents. Various contracts, contract provisions, . instruments and documents are involved in the financing to which this Purchase .Agreement relates. Among them are those identified below: Agreement: The Loan and Security Agreement, dated as of[^J ~ 1, 1999. to be entered into by and between the Issuer and the Company. Bonds: Co))ectively, City of Clearwater, Florida Revenue Bonds, Series 1999A (BEF, Inc. Project) (the IISeries 1999A Bondstl), City of Clearwater, Florida f ^ J Revenue Bonds, Series 1999B (BEF, Inc. Project) Fxtendable Rate Adiustable SecuritiesSM (EXTRAS~ (the "Series 1999B Bonds") and City of Clearwater, Florida Taxable Revenue Bonds, Series 1999C (BEF, Inc. Project) (^ J(the IISeries 1999C Bondsll) to be issued by the Issuer under the Indenture and pursuant to the Issuer's Authorizing Resolutions and the Act. This Purchase Agreement. the Agreement, the Notes, the Mortgage and the Continuing Disclosure Certificate. Collectively, the contracts, cenificates, opinions, instruments and other documents described in Section 4.2 of this Purchase Agreement. Manager; .,~ .~ ...J . ......,. Manager's Counsel: Bluffs Developer: Bluff's Developer Counsel: Bluff's Counsel: Financial Advisor to the City: Note Holder: Note Holderts Counsel: Financial Feasibility Consultant: "~') \~'J~ Company Documents: Closing Papers: ..~ Complete Care Services of Florida. Inc. Harsham, Pennsylvania Ehmann, Van Denbergh & Trainor Philadelphia, Pennsylvania Asset Development GrouP. LLC Clearwater. Florida Fieldstone Lester Shear & Denberg Miami, Florida MacFarlane Ferguson & McMullen Clearwater. Florida First Union Capital Markets Corp. St. Petersburg, Florida Bea) Bank Dallas, Texas Jenkens & Gilchrist DaJlas. Texas BDO Seidman. LLP Atlanta, Georgia 2 qt{'1 ~ .~ Continuing Disclosure Certificate: Final Official Statement: Indenture: Issuer Documents: Issuer Portions: '...., ) .-.....,.., Mortgage: Notes: Preliminary Official Statement: Title Insurance Binder; The Continuing Disclosure Certificate, dated as of the Closing Date, to be executed and delivered by the Company for the benefit of the holders and beneficial owners of the Bonds and in order to assist the Underwriter in complying with certain continuing disclosure requirements of Rule ISc2-12. The Final Official Statement (including the Appendices thereto), dated the date hereof: summarizing certain terms of the BondsJ the security therefor and certain financial and other information related to the Company and the Manager. The Trust Indenture, dated as of [^] July 1 J 1999 J to be entered into by and between the Issuer and the Trustee providing for the issuance of the Bonds. This Purchase AgreementJ the BondsJ the AgreementJ the Indenture and the assignment of the Mortgage. When referring to the Preliminary Official Statement or the Final Official Statement, the portions thereof under the captions "INTRODUCTION - The Issuer/' "THE ISSUER," "LITIGATION," "DISCLOSURE MATTERS - Disclosure Required by Florida Blue Sky Regulations" and "DISCLOSURE MA TIERS - Authorization of and Certification Concerning Official Statement. " The Mortgage and Security Agreement, dated as of [A] July I, 1999, to be entered into by and between the Company and the Issuer. The non-negotiable promissory notes of the Company to be issued by the Company in the principal amount of the Bonds pursuant to the Indenture. The Preliminary Official Statement (including the Appendices thereto)" dated . 1999, summarizing certain tenns of the Bonds and the security therefor and certain financial and other infonnation related to the Company and the Manager. The commitment of Title Insurance Company to issue a mortgagee's policy of title insurance in respect of the Mortgaged Real Estate as described in Section 4.2(b)(vi) of this Purchase Agreement. SECTION 1.3. Properties. Various properties are involved in the financing to which this Purchase Agreement relates. Among them are those identified below: '0 3 1e; -I ~ Mortgaged Equipment: The personal property of the Company to be subjected to the Uniform Commercial Code security interest of the Mortgage, '''j Mortgaged Real Estate: The real property of the Company to be subjected to the mongage lien of the Mortgage. Proiect: The Project of the Company to be financed with the proceeds of the Bonds as described in the Agreement and the Preliminary Official Statement. SECTION 1.4. Legal Authorities. Various legal authorities are involved in the financing to which this Purchase Agreement relates. Among them are those identified below: Issuer's Authorizing Resolutions: The Florida Constitution, the Charter of the Issuer, Chapter 154, Parts II and III of Chapter 159 and Chapter 166, Florida Statutes, as amended, and other applicable provisions oflaw. The Internal Revenue Code of 1986, as amended through and including the Closing Date and, to the extent applicable, the Internal Revenue Code of 1954, as amended, and, to the extent applicable, the Regulations issued or proposed pursuant thereto. Ordinance No. _w99 enacted by the Issuer's Governing Body adopted on April 15, 1999, and Resolution No. 99w_ adopted on t 1999, relating to the authorization, issuance and sale of the Bonds. Rule 15c2w 12 of the Securities and Exchange Commission promulgated pursuant to the Security and Exchange Act of 1934. Act: Code: :...) Rule 15c2-12: SECTION 1.5. Times. Dates and Places. Various times, dates and places are significant in the financing to which this Purchase Agreement relates. Among them are those identified below: Closing Date: , 1999, or such other date as the Parties may designate by written agreement. Closing Time: 11 :00 a.m. prevailing local time on the Cosing Date at the Place of Closing or such earlier or later time as the Parties may agree to. Offering Period: The period from and including the date of this Purchase Agreement through and including the 25th day ronowing the "end of the underwriting period" as such term is described in Rule 15c2w 12. Place of Closing: Offices of I t Florida or such other place as the Parties may designate by written agreement. ',J 4 1q , I ~ .~ ARTICLE II REPRESENTATIONS AND COVENANTS SECTION 2.1. Representations and Covenants of Issuer. As an inducement to the other Parties to enter into this Purchase Agreement, the Issuer represents, warrants and covenants as follows: (a) The Issuer is duly organized and validly existing as a municipal corporation of the State of Florida, with the powers and authority set forth in the Act. (b) The Issuer.s Authorizing Resolutions were duly adopted by the Issuer at meetings duly called and held in open session pursuant to the laws of the State of Florida and the ordinances, standing resolutions, bylaws and rules of procedure of the Issuer. The Issuer's Authorizing Resolutions have not been amended. repealed. rescinded or revoked. ,~. . ~ .' , l,,,,-,'ll) (c) The Issuer has full right, power and authority (i) to adopt the Issuer.s Authorizing Resolutions. (ii) to issue the Bonds and loan the proceeds thereof to the Company for the purposes set forth in the Preliminary Official Statement, (Hi) to secure the Bonds in the manner contemplated by the Indenture. the Agreement and the Mortgage, (iv) to enter into, execute and deliver this Purchase Agreement and the other Issuer Documents, and (v) to perfonn its obligations hereunder and thereunder. (d) When delivered to and paid for by the Undetwriter on the Closing Date in accordance with the provisions ofthis Purchase Agreement. the Bonds will have been duly authorized, executed. issued and delivered and, subject to bankruptcy, insolvency, reorganization, moratorium and other similar laws affecting creditors' rights heretofore or hereafter enacted to the extent constitutionally applicable and subject also to the exercise of judicial discretion in appropriate cases, will constitute valid and binding limited obligations of the Issuer in confonnity with. and entitled to !he benefit and security of, the Indenture, the Agreement and the Mortgage. (e) The Mayor-Commission~r and the City Clerk are authorized for and in the name of the Issuer to execute, deliver and perfonn the obligations of the Issuer under this Purchase Agreement and the other Issuer Documents and to execute, deliver. file or record such other incidental papers, documents and instruments as shall be necessary to carry out the intention and purposes of this Purchase Agreement and the Issuer's Authorizing Resolutions. (f) The adoption of the Issuer's Authorizing Resolutions and the execution. delivery and perfonnance of this Purchase Agreement and the other Issuer Documents will not conflict with or constitute a breach of or default under any commitment, agreement or instrument to which the Issuer is a party or by which it is bound. (g) Except as disclosed in the Preliminary Official Statement, there is no litigation, administrative proceeding or investigation pending (nor, to the knowledge of the Issuer, is any such v 5 qCj - / ~ action threatened) against the Issuer which in any way affects, contests, questions or seeks to restrain ') or enjoin any of the following: (i) the Act or the Issuer's Authorizing Resolutions; (ii) any of the proceedings had or actions taken leading up to the issuance of the Bonds or the execution, delivery or perfonnance of this Purchase Agreement; (iii) the delivery, validity or enforceability of the Bonds or any of the other Issuer Documents; (iv) the pledge or application of any money or security provided for the payment of the Bonds; (v) the corporate existence ofthe Issuer; (vi) the right of the Mayor-Commissioner, the City Clerk or any member of the Issuer to hold his or her office; (vii) the transactions on the part of the Issuer contemplated herein or in the Preliminary Official Statement; (viii) the Federal tax-exempt status of the interest on the Series 1999A Bonds; or (ix) the Federal, State or local tax-exempt status of amounts to be received by the Issuer from the Company pursuant to the Company's Documents. (h) The Issuer has not been advised by the Commissioner, any District Director or any other official of the Internal Revenue Service that certifications by the Issuer with respect to arbitrage may not be relied upon. (i) Prior to the execution hereof. the Issuer delivered to the Underwriter the Preliminary Official Statement that the Issuer, with respect solely to the Issuer Portions thereof. deemed final as ofits date for purposes of Rule 15c2-12, except for "pennitted omissions" as defined in such Rule; provided, however, that in making such representation, the Issuer shall not be deemed to have made any representation as to the truth, accuracy or completeness of the Preliminary Official Statement beyond the scope of the representations made elsewhere in this Section 2.1. -j (j) The Issuer authorizes the Final Official Statement to be used in connection with the offering of the Bonds, (k) If during the Offering Period the Issuer becomes aware of any fact or event which might or would cause the Final Official Statement, as then supplemented or amended, to contain any untrue statement of a material fact or to omit to state a material fact required to be stated therein or necessary to make the statements contained therein, in the light of the circumstances under which they were made, not misleading, it shall notify the Underwriter, and ifin the opinion of the Underwriter such fact or event requires the preparation and publication ofa supplement or amendment to the Final Official Statement, the Issuer shall, at the expense of the Company, cooperate with the Company to supplement or amend the Final Official Statement in a fonn and in a manner approved by the Underwriter and furnish to the Underwriter (i) a reasonable number of copies orthe supplement or amendment, and (ii) ifsuch notification shall be subsequent to the Closing Date, such legal opinions, certificates, instruments, and other documents as the Underwriter may deem necessary to evidence the truth, accuracy and completeness of such supplement or amendment to the Final Official Statement. The obligations of the Issuer set forth in this paragraph shall not require the Issuer to monitor the business affairs or financial condition of the Company. (I) The infonnation contained in the Issuer Portions of the Preliminary Official Statement and the Final Official Statement is true and correct in all material respects, in the case of the Preliminary Official Statement, on the date hereof, and will be true and correct in all material respects, in the case of the Final Official Statement, at all times during the Offering Period. The Issuer Portions J 6 11" I ~ ') of the Preliminary Official Statement do not contain on the date hereof and the Issuer Portions of the Final Official Statement will not contain during the Offering Period, any untrue statement of a material fact; and the Issuer Portions of the Preliminary Official Statement do not omit on the date hereof. and the Issuer Portions of the Final Official Statement will not omit during the Offering Period, a material fact required to be stated therein or necessary to make the statements made therein, in the light of the circumstances under which they were made, not misleading. The Issuer is not making any representations with respect to the accuracy' of the information contained in the Preliminary or Final Official Statement other than the Issuer Portions. (m) Except as disclosed in the Preliminary Official Statement, the Issuer is not in breach of or default under any existing law, court order or administrative regulation, decree or order, and the Issuer is not in payment default on any of its outstanding bonds, notes or other evidences of indebtedness which are payable from funds provided by the Company; and to the best ofthe Issuer's knowledge, no event has occurred which, with the passage of time or the giving of notice, or both, would constitute a material breach or default by the Issuer thereunder. (n) The Issuer, as a conduit issuer, issues its bonds as limited obligations of the Issuer payable solely from payments made to it from the respective non-governmental entities which use or own the facilities financed. Some bonds issued by the Issuer may have been,' and may continue to be, in default, but the borrowers under the related loan or lease agreements are unrelated to the Company. The Issuer has not been in default at any time after December 31, 1975, as to any debt obligations relating to the Company. . "\ SECTION 2.2. Representations of tile Underwriter. As an inducement to the other Parties "",) to enter into this Purchase Agreement, the Underwriter represents and warrants that, except for any violation of law arising out of any misrepresentation or breach of covenant by any other Party, the Bonds purchased by the Underwriter will be offered aryd sold by the Underwriter in accordance with all state and federal laws applicable to the Underwriter and the aggregate total of the initial offering prices of the Bonds is not more than $ plus accrued interest from . 1999 to the Closing Date. The Underwriter has this day filed with the Issuer a Disclosure Statement pursuant to Section 218.385(4), Florida Statutes, as amended, a copy of which is attached hereto as Exhibit H. The Underwriter shall notifY the Issuer and the Company when th~ "end of the underwriting period" for the Bonds has occurred for purposes of Rule 1 5c2-12 with respect to the unsold balances of Bonds that were originally sold to the Underwriter for resale to the public and which are held by the Underwriter for resale to the public. Such notice may be based upon representations made to it by the other underwriters that the "end of the underwriting period" for the Bonds for purposes of Rule 15c2-12 has occurred on a date which shall be set forth in such notification. The Issuer and the Company shall be entitled to treat as the tlend of the underwriting period" for the Bonds the date specified in the notice from the Undetwriter stating the date which is the uend of the underwriting period." The Underwriter is authorized to execute and deliver this Purchase Agreement on behalf of the Underwriter and to act for the Underwriter as contemplated hereby. SECTION 2.3. Representations and Covenants of the Company. As an inducement to the other Parties to enter into this Purchase Agreement, the Company representst warrants and covenants as follows: J 7 qq-/t 1 (0) The Company is a not-for-profit corporation duly organized and validly existing under the laws of the State of Florida. (b) The Company is licensed or qualified to do business in each state in which the ownership of property or the transaction of business by the Company requires that the Company be licensed or qualified and in which failure to qualify or be licensed could have a material adverse effect on the business or financial condition of the Company. (c) The Company has full right, power and authority to enter into, execute and deliver this Purchase Agreement and the other Company Documents and to perfonn its obligations hereunder and thereunder. (d) The Authorized Officers of the Company are authorized for and in the name of the Company to execute, deliver and perfonn the obligations of the Company under this Purchase Agreement and the other Company Documents and to execute, deliver, file or record such other incidental papers, documents and instruments as shall be necessary to carry out the intention and purposes of this Purchase Agreement. (e) No authorization, approval, consent or license of any governmental body or authority, not already obtained, is required for the valid and lawful execution and delivery by the Company of this Purchase Agreement and the other Company Documents and the assumption by the Company of its obligations hereunder and thereunder. .~. Cf) The Company has not received any notice of an alleged violation and, to the knowledge of the Company, the Company is not in violation of any zoning, land use, environmental or other similar law or regulation applicable to the Mortgaged Property or applicable to any of its other property which would have a material adverse affect on the operations or financial condition of the Company or the Project. (g) The execution and delivery by the Company of this Purchase Agreement and the other Company Documents and the performance by the Company hereunder and thereunder will not conflict with or constitute a breach of or default under the Company's Articles of Incorporation or Bylaws, or, to the extent they are material to the performance of this Purchase Agreement or any other of the Company Documents, any indenture, agreement or other instrument to which the Company is a party or by-which it or its properties are bound or are subject. (h) No event has occurred which, with the lapse of time or the giving of notice or both, would give any creditor of the Company the right to accelerate the maturity orany of the Company's outstanding indebtedness for money borrowed. (i) Except as described in the Preliminary Official Statement, there is no actio", suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, public board or body, pending or, to the knowledge ofthe Company, threatened against the Company (or, to the knowledge of the Company, any meritorious basis therefor) wherein an unfavorable decision. ruling or finding o 8 11-/~ "f.... .~.~.. . ~. . . :) would have a material adverse effect on (i) the financial condition ofthc Company, (ii) the acquisition, construction, installation or operation of the Project or the operation of the other properties referred to in Section 1.3 hereof, (iii) the transactions contemplated by this Purchase Agreement and the Preliminary Officiat Statement, (iv) the validity or enforceability of the Company Documents or (vi) the corporate existence or powers of the Company. (j) Except as described in the Preliminary Official Statement, the Company is in compliance, in all respects material to the financial condition of the Company, with all applicable federal, state and local laws, rules, regulations, orders and decrees relating to the conduct of their business as currently conducted~ and no order, decree, judgment, fine or penalty has been issued, assessed or threatened based upon any violation or alleged violation of any of the foregoing that could have a material adverse effect on the financial condition of the Company'. (k) The Company owns or possesses or is licensed under all the patents, patent applications, trademarks, service marks, trade names, trademark registrations, service mark registrations, copyrights, licenses, inventions, trade secrets and rights necessary for the present and planned future conduct of its business including, without limitation, the licenses from the State of Florida necessary to own and operate assisted living and skilled nursing facilities. (1) The Company is not in default in any material respect under any lease, contract or agreement to which the Company is a party and which is material to the business, properties or financial condition of the Company~ and no event has occurred which, with the passage of time or the giving of notice or both, would constituie a material default by the Company. , ......-~ (m) Except as described in the Preliminary Official Statement, the Company has good and marketable title to all real and personal property described as being owned by it, in each case free and clear of all liens, encumbrances and defects except Permitted Encumbrances (as defined in the Mortgage) and except such as are not material to the financial condition of the Company. (n) The Company will not take or omit to take any action which in any way cause or result in the proceeds of the sale of the Bonds being applied in a manner than as provided in the applicable Indenture or as described in the Preliminary Official Statement and the Final Official Statement. (0) Except as may be described in the Preliminary Official Statement, there are in force no Unifonn Commercial Code security interests conflicting with the security interest of the Mortgage in the Mortgaged Equipment~ and, the Company has signed no currently effective Unifonn Commercial Financing Statements affecting the Mortgaged Equipment other than as permitted by the Mortgage. o (p) Except as described in the Preliminary Official Statement, the Company has good and marketable title in fee simple to the Mortgaged Real Estate owned by the Company. There are no parties in possession of the Mortgaged Real Estate or any part thereof claiming rights thereto other than the Company. There are no claims or easements affecting the Mortgaged Real Estate which are not of public record. There are no judgments, tax liens, taxes or special assessments affecting the Mortgaged Real Estate and known to the Company which are presently unpaid other than current 9 qq -/~ ":'., ,.;'... ,..,- -............--.-............ ') taxes and the lien securing the same. The Company has received no notices of material violations of building or zoning laws, ordinances or regulations with respect to the Mortgaged Real Estate which have not been corrected. The Company knows of nothing affecting its title to the Mortgaged Real Estate which is not described in the Title Insurance Binder. None ofthe "special exceptions" set forth in the Title Insurance Binder materially interferes with or impairs the operations to be conducted on the Mongaged Real Estate and none of said special exceptions materially adversely affects the value of the Mortgaged Real Estate. (q) Except as set forth in the Preliminary Official Statement, (i) the Company has not sustained any loss or interference with its business from fire, explosion, flood or any labor dispute or court or governmental action. order or decree and (ii) there has been no increase in short-tenn debt or long-term debt. of the Company or any adverse change. or any development involving a prospective adverse change, in or affecting the general affairs, management, propenies. financial condition or results of operations of the Company, which in any such case described in clause (i) or (ii) is material to the financial condition of the Company. .._) (r) The information contained in the Preliminary Official Statement is true and correct in all material respects on the date hereof: and the information contained in the Final Official Statement will be true and correct in all material respects at all times during the Offering Period; and the Preliminary Official Statement does not contain on the date hereof, and the Final Official Statement will not contain during the Offering Period, any untrue statement of a material fact; and the Preliminary Official Statement does not omit on the date hereof. and the Final Official Statement will not omit during the Offering Period, a material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading; provided, however, that this representation and warranty shall not be deemed to cover or apply to the statements in or omissions from the Issuer Ponions of the Preliminary" Official Statement or the Final Official Statement. (s) Prior to the execution hereof. the Company delivered to the Underwriter the Preliminary Official Statement that the Company deemed final for purposes of Rule 15c2-12 as ofthe date thereof: except for (i) the omission of no more than the following information: the offering price, interest rate, underwriting discount, aggregate principal amount and other terms of the Bonds depending on such matters. and (ii) the Issuer Portions thereof; provided, however, that in making such representation, the Company shall not be deemed to have made any representation as to the truth, accuracy or completeness of the Preliminary Offici~ Statement beyond the scope of the representations made elsewhere in this Section 2.3. (t) As soon as practicable after the date hereof: and in any event within seven business days of the date hereof: the Company, assuming compliance by the Issuer with the applicable requirements of Section 2. 1 of this Purchase Agreement. shall deliver to the Underwriter executed copies of the Final Official Statement dated the date hereof, in substantially the form of the Preliminary Official Statement, with only such changes therein as shall have been approved by the Issuer, the Company and the Underwriter (the delivery of the Final Official Statement by the Company to the Underwriter and the acceptance thereof by the Underwriter to constitute the Company's approval). executed on behalf of the Company by Authorized Officers. The Final Official Statement shall be provided for distribution, at the expense ofthe Company, in such quantities as shall I '-/ 10 qq"lr 'I- 'n...'.... - __ --_....-0............................... ....... ,,) be requested by the Underwriter in order to permit the Underwriter to comply with the provisions of Rule 15c2-12 and the applicable rules of the Municipal Securities Rulemaking Board with respect to distribution ofa copy ofthe Final Official Statement to each potential customer upon request and, in any event. to each actual customer. (u) Ifduring the Offering Period the Company becomes aware ofany fact or event which might or would cause the Final Official Statement, as then supplemented or amended, to contain any untrue statement of a material fact or to omit to state a material fact required to be stated therein or necessary to make the statements contained therein, in the light of the circumstances under which they were made, not misleading, the Company shall notify the Underwriter, and ifin the opinion of the Underwriter such fact or event requircs the preparation and publication of a supplement' or amendment to the Final Official Statemcnt, the Company shall, at its expense, supplement or amend the Final Official Statement in a form and in a manner approved by the Underwriter and furnish to the Underwriter (i) a reasonable number of copies of the supplement or amendment, and (ii) if such notification shall be subsequent to the Closing Date, such legal opinions, certificates, instruments, and other documents as the Underwriter may deem necessary to evidence the truth, accuracy and completeness of such supplement or amendment to the Final Official Statement. I I , _../ (v) The Company's audited financial statements for the fiscal year ending December 31, 1998 compared to the audited financial statements of the Company for the fiscal years ending December 31, 1997, and the Company's unaudited financial statements for the three-month period ending March 31, 1999, contained in the Preliminary Official Statement present fairly the financial position of the Company as of the dates indicated and the results of its operations, changes in net worth and cash flows for the periods specified, and such financial statements have been prepared in conformity with generally accepted accounting principles consistently applied in all material respects to the peri9ds involved, except as stated in the notes thereto. To the best knowledge of the Company, the Accountants are independent public accountants as required by the Securities Act of 1933, as amended, and the rules and regulations of the Securities and Exchange Commission thereunder. (w) The Company has been detelmined to be and is an organization described in Section 501(c)(3) of the Internal Revenue Code, which is exempt from the payment offederal income taxes under Section 501 (a) of said Code and which is not a "private foundation" as defined in Section 509(a) of said Code. The Company does not have "unrelated business taxable income" as defined in Section 512 of the Internal Revenue Code which could have a material adverse effect on the Company's tax-exempt status or which, if such income were subject to federal income taxation, would have a material adverse effect on the condition, financial or otherwise, of the Company. The Company has (i) not impaired its status as an organization exempt from federal income taxes under the Code, (ii) is in compliance with the provisions of the Code and any applicable regulations thereunder necessary to maintain such respective status, (Hi) is organized and operated exclusively for charitable and religious purposes; and (iv) is organized and operated such that no part of the net earnings of the Company will inure to the benefit of any private shareholder or individual. (x) The Company is not engaged in termination proceedings as to its participation in third party reimbursement or payment arrangements, and the Company has not received notice that its .....J 11 99-/f! {~ ..,......' "-,, <J <"J current participation in any third party reimbursement or payment arrangements is subject to any termination or suspension as a result of alleged violations or any noncompliance with participation requirements, (y) The Company agrees to furnish the Underwriter monthly financial reports for the Facility and to the Issuer and the Underwriter such other information as the Underwriter or the Issuer may reasonably request from time to time regarding the Facility or the Company. (z) The Company will furnish such information, execute such instruments and take such other action in cooperation with the Underwriter as the Underwriter may reasonably request to qualify the Bonds for offer and sale under the Blue Sky or other securities laws or regulations of such states and other jurisdictions of the United States. as the Underwriter may designate and to provide for the contmuance of such qua1ification~ provided, however, that the Company will not be required to qualify as a foreign corporation or to file any general or special consents to service of process under the laws of any state. (aa) The Company does not have any actual knowledge that any of the facilities of the Company or their respective operations are not in compliance in all material respects with all state and federal environmental Jaws. 12 19,jrf ) ARTICLE III AGREEMENT TO PURCHASE BONDS SECTION 3. 1 Contemporaneous Delivery of Documents to Underwriter. Prior to or simultaneously with the execution and delivery of this Purchase Agreement, the Underwriter has received (i) onc copy each of the Preliminary Official Statement, the Issuer Documents and the Company Documents in substantially the respective forms thereof on record with the Issuer at the time of its consideration and adoption of the applicable Issuer's Authorizing Resolutions~ and (ii) one signed copy of a letter from the Accountants, dated within 10 days of the date hereof, substantially in the form set forth in Exhibit B hereto. , ) .~* if As soon as practicable after the date hereof. and in any event within seven (7) business days of the date hereof, or by such earlier date, as requested by the Underwriter, as required by paragraph (b)(3) of Rule lSc2~12 or the rules ofthe MSRB, the Issuer shall deliver or cause to be delivered to the Underwriter copies of the Official Statement, dated the date hereof, relating to the Bonds, in sufficient quantities to allow the Underwriter to comply with paragraph (b)(4) of Rule 15c2-12 and the rules of the MSRB, in substantially the form of the Preliminary Official Statement with only such changes therein as shall have been approved by the Issuer, the Company and the Underwriter. The Official Statement, including the cover pages and all exhibits, appendices, reports and statements included with or attached thereto and any amendments and supplements that may be authorized by the Issuer and the Company and to which the Underwriter does not reasonably object, and any amendments and supplements which may be reasonably required by the Underwriter for use with respect to the Bonds, are referred to herein as the 110fficial Statement." The Official Statement shall be executed on behalf of the Issuer and the Company by duly authorized officers of each. The Issuer authorized and the Company approves the Preliminary Official Statement, and the Issuer and the Company consent to the use of the Preliminary Official Statement and the Official Statement and the information contained therein by the Underwriter in connection with the offering and sale of the Bonds. The Issuer and the Company deem the Preliminary Official Statement, as of its date, final for purposes of Rule ISc2-12, except for certain omissions therein in connection with the pricing of the Bonds. SECTION 3.2 ~~eement to Sell and Purchase Bonds. The Bonds shall have the tenns specified in the Final Official Statement, including the maturities, interest rates and call provisions set forth in Exhibit A annexed hereto. Upon the basis of the representations and warranties and upon the terms and conditions set forth in this Purchase Agreement, the Underwriter agrees to purchase from the Issuer, and the Issuer agrees to seU to the Underwriter, aU (but not less than aU) of the Bonds for the purchase price specified in Exhibit A annexed hereto (the I1Purchase Price"), plus accrued interest through the day immediately preceding the Closing Date. Payment ofthe Purchase Price shall be made by the Underwriter to the order of the Trustee (for the account of the Issuer) at the Closing Time in immediately available funds at the principal office ofthe Trustee in [^] Orlando, Florida[^). The Bonds shall be made available to the Underwriter for inspection and packaging at least 24 hours prior to the Closing Date. Unless the Underwriter specifies otherwise at least five ~ 13 qq;, / r ! i () business days prior to the Closing Date, the Bonds shall be preexecuted, preauthenticated and delivered for safekeeping to The Depository Trust Company, New York, New York, at least 24 hours prior to the Closing Date under arrangements made by the Trustee. SECTION 3.3 Public Offering of Bonds. The Underwriter agrees to make a bona fide public offering of the Bonds, solely pursuant to the Preliminary Official Statement and the Official Statement at the initial offering prices set forth in the Official Statementt reservinSt hawevert the rights to (i) change such initial offering prices as the Underwriter shall deem necessary in connection with the marketing of the Bonds and (ii) offer and sell the Bonds to certain dealers (including dealers depositing the Bonds into investment trusts) at concessions to be determined by the Underwriter, The Underwriter also reserves the right to over-allot or effect transactions that stabilize or maintain the market prices ofthe Bonds at levels above that which might otherwise prevail in the open market and to discontinue such stabilizing, if commencedt at any time. SECTION 3.4 Condition to Purchase of Bonds. The Underwriter's obligation to purchase the Bonds shall be conditioned upon its receivingt at or prior to Closing, in form satisfactory to the Underwriter and its counsel evidence that the Company has made the continuing disclosure undertaking as set forth in the Continuing Disclosure Certificate for the benefit of the holders of the Bonds. SECTION 3.5 Approval of the Company. The Company approves the purchase and sale, described in Section 3.2 of this Purchase Agreement and agrees (to the extent within i'ts control) to . cause each of the conditions set forth in Article IV oftms Purchase Agreement to be satisfied at or " prior to the Closing Time. \'_.-J" . .....~ 14 qq ~ / g' f) '. :.."....~,) ~~) ARTICLE IV CLOSING CONDITIONS SECTION 4.1. Performance of Obligations. The obligations and agreements of the Underwriter under this Purchase Agreement are expressly made subject to the due performance by the Company and the Issuer at or prior to the Closing Time of their respective obligations and undertakings pursuant to this Purchase Agreement. SECTION 4.2. Delivery of Closing Papers. The obligations and agreements of the Underwriter under this Purchase Agreement are expressly made subject to the condition that, at or prior to the Closing Time, there shall have been delivered to the Underwnter each of the following: (a) Basic Documents: (i) One fully executed counterpart each of the Issuer Documents and the Company Documents in the respective forms thereof delivered to the Underwriter pursuant to Section 3.1 of this Purchase Agreement, with only such revisions therein, or deletions therefrom or additions thereto as shall have been required to incorporate terms specified in this Purchase Agreement or as shall have been approved by the Underwriter. (ii) Ten copies of the Final Official Statement executed by the Company. (b) Closing Papers to be Furnished by the Company: (i) One copy of the Company's Articles ofIncorporation, as amended or restated, certified not more than 30 days prior to the Closing Date by the appropriate certifying agency of the State ofFlorid~ together with a certificate of the Secretary or Treasurer of the Company, dated the Closing Date, to the effect that there has been no amendment or restatement of said Articles subsequent to the date of certification by said agency. (ii) One copy of a certificate of corporate existence and good standing issued by the State of Florida on a date as dose as reasonably practicable to the Closing Date. (iii) One copy ofthe resolutions or excerpts from minutes ofmectings of the Companyts Board of Directors (or the Executive Committee of such Board) which authorize this Purchase Agreement and the Company Documents and the transactions contemplated hereby and thereby, certified by the Secretary or Treasurer of the Company to be a true and correct copy thereof as adopted and as in full force and effect as of the Closing Date. IS 1q~/v "\il~.,),o.a'i. I." ..,. ,.. . .... --......-..._----.--......,..---.........:.._--~------- ........ .~, (iv) One copy of the Bylaws of the Company as in force on the date of the adoption of the resolutions referred to in Section 4.2(b)(iii) and one copy of all subsequent amendments, if any, thereto, in each case certified by the Secretary or Treasurer of the Company to be a true and correct copy thereof. (v) One original copy of a survey with respect to the Mortgaged Real Estate located in the City of Clearwatert Florida., certified to the Trusteet which survey shall be dated no earlier than a date agreed to by the Underwriter. Said survey shall show the location of all buildings on such land and the location of all easements and rights-of-way identified in the title insurance policy referred to in Section 4.2(b)(vi). (vi) One original copy of an form ofloan policy of title insurance, designating the Trustee as named insured, in the face amount of S I with respect to the Mortgaged Real Estate, insuring that good and marketable fee simple title to that part of the Mortgaged Real Estate located in the City of Clearwater, Florida., is vested in the Company, that the Mortgage is a first and paramount mortgage lien on the Mortgaged Real Estate subject to no prior liens or encumbrances other than Itpermitted Encumbrances" as defined in the Mortgage and other than liens or encumbrances acceptable to the UndeIWTiter and Underwriter's counsel. ~ (vii) One signed copy of a letter from the Accountants, dated within five days of the Closing Date, substantially in the form set forth in Exhibit C hereto. (viii) One signed copy of a legal opinion from Company's Counsel, dated the Closing Date, covering the matters set forth in Exhibit D hereto. (ix) . A certificate from the Company signed by Authorized Officers of the CompanYt dated the Closing Date (i) confirming that each of the representations of the Company contained in Section 2.3 of this Purchase Agreement was true and accurate on the date when made, has been true and accurate at all times since and continues to be true and accurate on the Closing Date and that each such representation with respect to the Preliminary Official Statement applies to the Final Official Statementt (ii) stating that there has been no material adverse change in the business, properties or financial condition of the Company from that shown in the Final Official Statement, and (Hi) stating that the information contained in the Final Official Statement (other than in the Issuer Portions thereof) is true and correct in all material respects and does not contain any untrue statement ofa material fact or omit to state a material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading. (x) Evidence that the Company has in force insurance meeting the requirements of the Company Documents. ,.; } \..; 16 qq, / f( :".l" , ,.~, ''-oJ ._...In:l:......~~..-...... (xi) Receipts or other evidence that financing statements have been filed for record with the appropriate governmentaJ authorities with respect to the security interests granted or assigned by the Indenture, the Agreement and the Mortgage. (xii) One executed copy of a customary "tax compliance cenificate," in form prepared by and acceptable to Bond Counsel, dated the Closing Date and signed by an Authorized Officer of the Company. (xiii) Copies of all certificates of authority, pennits and licenses which the Company is required to have in order to operate its facilities and all certificates of need, if any, permits, approvals and licenses obtained prior to the Closing Date in connection with the acquisition, construction and installation of the Project. (xiv) An acceptable environmental report on the Mortgaged Real Estate satisfactory to the Underwriter addressed to the Trustee and the Issuer or, if deficiencies are noted in such report, arrangements satisfactory in fonn and substance to the Underwriter to eliminate such deficiencies. (xv) One executed copy of an architect's certificate, signed by the Architect and dated within five days of the Closing Date, substantially in the form set forth in Exhibit I hereto. (xvi) Evidence satisfactory to Bond Counsel and Underwriter's Counsel that the Compai'Y is an organization described in Section SOl(c)(3) of the Code and is not a private foundation as described in Section 509(a) of the Code. (xvii) One signed copy ofa Letter from the Financial Feasibility Consultant consenting to the references to it in the Preliminary Official Statement, the Final Official Statement and to the inclusion of the Financial Feasibility Study in Appendix C thereto. (xviii) One signed copy each of Letters from the Accountants consenting to the references to them in the Preliminary Official Statement, the Final Official Statement and the inclusion of the Financial Statements in Appendix D thereto. (xix) One copy of a certificate or certificates, which may be included on the applicable surveyor surveys, or an independent registered Florida land surveyor stating whether or not any portion of the Properties is on a flood plain or designated as a flood plain by any governmental body and if so, evidence of appropriate flood insurance acceptable to the Underwriter. (xx) One copy of a Single Guaranteed Maximum Price Construction Contract for the Project executed by the Company and the General Contractor, which Contractor shall be required under the Construction Contract to include, among other 17 qq~/r .~ "'~' } (c) ) .....r__.' (J things, provision for 100% payment and performance bonds, and liquidated damages satisfactory to the Underwriter (which bonds shall be assigned to the Trustee). (xxi) One copy of the Financial Feasibility Study. (xxii) One copy of the Management Agreement between the Company and the Manager. (xxiii) One copy of the Development Agreement among the Company, the Manager and the Bluffs Developer. (xxiv) One copy of the Ground Lease for the Project. (xxv) A certificate from the Manager, dated the Closing Date, confinning that the information contained in the Preliminary Official Statement and Final Official Statement regarding the Manager is true and correct in all material respects. (xxvi) A certificate from the Manager, dated the Closing Date, certifying the enforceability of the Management Contract. Closing Papers to be Furnished by Issuer: (i) One copy each of the Issuer's Authorizing Resolutions certified by the Mayor-Commissioner or City Clerk to be a true and correct copy thereof as adopted and approved. (ii) One executed original of a customary incumbency and no-litigation certificate. in form prepared by and acceptable to Bond Counsel, dated the Closing Date and signed by the Mayor-Commissioner or the City Clerk. (iii) One executed copy ofa customary Itnonarbitrage certificate, tI in form prepared by and acceptable to Bond Counsel, dated the Closing Date and signed by the Mayor-Commissioner or the City Clerk, (iv) Evidence that the Issuer has complied with the "public approval requirements It of Section 147(f) of the Internal Revenue Code. (v) Evidence that the Issuer has complied with the reporting requirements ofSecti,on 149(e)(2) of the InternaJ Revenue Code in respect of the Bonds. (vi) One signed copy of a legal opinion from Issuers Counsel, dated the Closing Datel covering the matters set forth in Exhibit E hereto. (vii) One signed copy of the approving legal opinion of Bond Counsel, dated the Closing Date, in the fonn of Exhibit F hereto. 18 19 -' I c;( ,t) . '" ,1 (viii) One signed copy of the supplemental legal opinion of Bond Counsel. dated the Closing Date, covering the matters set forth in Exhibit G hereto. (ix) One copy of the State of Florida Division of Bond Finance Forms BF2003 and/or BF~004. as prepared by Bond Counsel. (d) Closing Papers to be Furnished by Trustee: (i) One executed copy of a customary authorization and incumbency closing certificate, dated the Closing Date and signed by authorized officers of the Trustee. . (ii) One executed copy of a customary certificate of receipt and . application of the proceeds of the Bonds in accordance with the Indenture. (Hi) One signed copy of the opinion of the Trustee's Counsel, dated the Closing Date, in the fonn as set forth in Exhibit J hereto. (e) Other Assurance~: Such additional legal opinions. certificates, proceedings, instruments and other documents as the Underwriter, Underwriter's Counselor Bond Counsel may reasonably request to verify or evidence (i) compliance by the Parties and Participants with applicable legal requirements, (ii) the truth and accuracy of the representations or opinions of the Parties and Participants contained in this Purchase Agreement or in any Closing Paper, or (Hi) the due ,~) performance of all agreements and the satisfaction of all conditions required to be performed or satisfied at or prior to the Closing Time. SECTION 4.3. Form ofClosinQ: Papers: Waiver of Conditions. The Closing Papers to be delivered to the Underwriter pursuant to this Purchase Agreement shall be deemed to be in compliance with the conditions of this Purchase Agreement if, but only if, in the reasonable judgment of the Underwriter. they are satisfactory in fonn and substance. Time is of the essence with regard to aU matters covered in this Article IV. The legal opinions and certificates described in Section 4.2 shall be addressed to the Underwriter. No condition hereofshalJ be deemed to have been waived by the Underwriter unless expressed specifically in a writing signed by the Underwriter. ,~ 19 C;q,. 1ft J;w........ri-~..r.~ ,..~~._.... ARTICLE V ", / :TERMINATION: PAYMENT OF EXPENSES SECTION 5.1. Termination. This Purchase Agreement may be terminated by the Underwriter on behalf of the Underwriter without liability on the part of the Underwriter, if. at or prior to the Closing Time: (a) Any representation of the Issuer or the Company contained in this Purchase Agreement or in any Closing Paper shall prove to be or to have been false in any material respect; (b) There shaH be a failure of any one or more of the conditions set forth in Sections 4.1, 4.2 or 4.3 oftbis Purchase Agreement; ..--., ",~~ (c) Litigation or an administrative proceeding or investigation shall be pending or threatened affecting, contesting, questioning or seeking to restrain or enjoin (i) the issuance or delivery of any of the Bonds or the payment, collection or application of the proceeds of the Bonds or of other moneys or securities pledged or to be pledged under the Indenture and the Mortgage, (ii) the validity or tax-exempt nature of the Bonds, (Hi) the validity of this Purchase Agreement, any of the Issuer Documents, any of the Company Documents or any proceedings taken by the Issuer or the Company with respect to any of the foregoing, (iv) the Issuer's creation, organization or existence or the titles to office of any of its officers or its power to engage in any of the transactions contemplated by the Issuer Documents, (v) the incorporation, organization or existence of the Company, or (vi) the legal power or authority of the Company to enter into and engage in any of the transactions contemplated by this Purchase Agreement; I I I . (d) Any legislative, executive or regulatory action or any court decision shall occur which, in the reasonable judgment of the Underwriter casts sufficient doubt on the legality of, or the tax-exempt status of interest on, obligations of the general kind and character as the Bonds so a~ to impair materially the marketability, or to reduce materially the market price of. the Bonds; (e) Any action by Congress, the Securities and Exchange Commission or a court shall occur which would require registration of any Bond under the Securities Act of 1933, as amended, or the qualification of the Indenture under the Trust Indenture Act of 1939, as amended; (f) Any material restriction not presently in force on trading in securities generally) or any banking moratorium, or the inception or escalation of any war or major military hostilities shall occur, whic~ in the reasonable judgment of the Underwriter, substantially impairs the marketability ofthe Bonds; (g) There shall occur any adverse change in the business, properties or financial condition of the Company from that described in the Preliminary Official Statement which) in the reasonable judgment of the Underwriter is material and makes it inadvisable to proceed with the sale of the Bonds; or " -.J 20 qq, I~ o ~,:~) ,-) ~ '. "T ,. ~ (h) Any event or condition shan occur which, in the reasonable judgment of the Underwriter, renders untrue or incorrect, in any material respect as of the time to which the same purports to relatc, the information contained in the Final Official Statement or which requires that information not reflected therein be included therein in order to make the statements and information contained therein not misleading in any material respect as of such time. SECTION 5.2, Payment of Expenses. The following costs and expenses relating to the transactions contemplated or described in this Purchase Agreement shall be borne and paid by the Company regardless of whether the transactions herein contemplated shall close: printing or photostating of Bonds; printing or photostating of Closing Papers (including the Preliminary Official Statement and the Final Official Statement) in such reasonable quantities as the Underwriter may request; fees paid to any state to register, exempt or otherwise qualify the Bonds for sale in such state; fees paid to any rating agency; fees and disbursements of Bond Counsel; fees and disbursements of Company's Counsel; fees and disbursements of Issuer's Counsel; fees and disbursements of the Financial Advisor; Trustee's fees and disbursements; out-of-pocket expenses and fees oflssuer. The Underwriter shall pay the fees and disbursements of Underwriter's Counsel. The Issuer shall bear no out-of-pocket expense in connection with the transactions contemplated by this Purchase Agreement. Except as otherwise provided above, the Company, the Issuer and the Underwriter shall each bear the costs and exp'enses incident to the performance of their respective obligations under this Purchase Agreement. SECTION 5.3. Indemnification bv the Company: Contribution. The Company agrees to indemnify the Issuer and the UndelVlriter, their respective executive officers, directors and officials and each person, ifany, who controls the Issuer or the Underwriter or any of them within the meaning of the Securities Act of 1933, as amended, or the Securities Exchange Act of 1934, as amended, against claims asserted against them if such claims arise out of or are based on (i) the assertion that the Preliminary Official Statement or the Final Official Statement (except for Issuer Portions thereof and for information relating to the Underwriter to the extent such information has been provided in writing by the Underwriter expressly for use in the Preliminary Official Statement and the Final Official Statement) contains an alleged untrue statement of a material fact or an alleged omission to state any material fact necessary to make the statements therein not misleading in light of the circumstances under which they were made, or (ii) the failure to register the Bonds under the Securities Act of 1933, as amended, or to qualify the Indenture under the Trust Indenture Act of ] 939, as amended. This indemnity includes reimbursement for expenses reasonably incurred by an indemnified party in investigating the claim and in defending it if the Company declines to assume the defense. Within 60 days after the commencement ofany action against any party indemnified hereunder in respect of which indemnity is to be sought against the Company, such indemnified party will notify the Company in writing of such action and the Company may assume the defense thereof, including the employment of counsel and the payment of all expenses. If the Company shall assume the defense of any such action, an indemnified party may retain its own counsel for such action and still be indemnified for the costs and expenses of such counsel despite an assumption of the defense by the Company. The Company shall not be Hable for any settlement of any such action effected without 21 Cf1 ' / gt ~ . , ) ,~...-/ l ',~J .' its consent, but if settled with the consent of the Company or if there is a final judgment for the plaintiff in any such actionl the Company agrees to indemnify and hold harmless any indemnified person from and against any loss or liability by reason of such settlement or judgment. The indemnification contained in this Section 5.3 shall survive delivery of the Bonds and shall survive any investigation made by or on behalf of an indemnified pany. Ifthe indemnification provided for in this Section 5.3 is unenforceable (as determined by final judgment of a court of competent jurisdiction) or otherwise unavailable to an indemnified party in respect of any losses, claims, damages or liabilities (or actions in respect thereot) referred to herein, the Company agrees, in lieu ofindemnifying the indemnified party. to contribute to the amount paid or payable by such indemnified party as a result of such losses, claims, damages or liabilities (or actions in respect thereof) in such proportion as is appropriate to reflect the relative benefits received by the Company on the one hand and the indemnified party on the other from the offering of the Bonds. If, however, the allocation provided by the immediately preceding sentence is not permitte.'d by applicable law or if the indemnified party faited to give the notice required herein, then the Company agrees to contribute to such amount paid or payable by such indemnified party in such proportion as is appropriate to reflect not only such relative benefits but also the relative fault of the Company on the one hand and the indemnified party on the other in connection with the statements or omissions which resulted in such losses. claims, damages or liabilities (or actions in respect thereof), as well as any other relevant equitable considerations. The relative benefits received by the Company on the one hand and the Underwriter on the other shall be deemed to be in the same proportion as the total net proceeds from the offering (before deducting expenses) received by the Company bear to the total underwriting fees and commissions received by the Underwriter in connection with this transaction. The relative fault shall be determined by reference to, among other things. whether the untrue or alleged untrue statement of a material fact or the omission or alleged omission to state a material fact relates to information supplied by the Company or the Underwriter and the parties' relative intent, knowledge, access to information and opportunity to correct or prevent such untrue statement or omission. The Company and the Underwriter agree that it would not be just and equitable if contribution pursuant to this subsection were determined by pro rata allocation or by any other method of allocation which does not take account of the equitable considerations referred to above in this paragraph. The amount paid or payable by an indemnified party as a result of the losses, claims. damages or liabilities (or actions in respect thereof) referred to above in this subsection shall be deemed to include any legal or other expenses reasonably incurred by such indemnified party in connection with investigating or defending any such action or claim. No person guilty offraudulent misrepresentation (within the meaning of Section ll(f) of the Securities Act of 1933, as amended) shall be entitled to contribution from any person who was not guilty of such fraudulent misrepresentation. 22 9Q, /~ ,~ ,..... C'l) ,~ ARTICLE VI MISCELLANEOUS SECTION 6.1. Parties and Interests: Survival of Representations. This Purchase Agreement is made solely for the benefit of the Issuer, the Company, the Underwriter and the persons entitled to indemnification or contribution under Section 5.3, and no other person, partnership, association or corporation shall acquire or have any rights hereunder or by virtue hereof. All representations and agreements in this Purchase Agreement shall remain operative and in full force and effect regardless of any investigation made by or on behalf of any Party and shall survive the delivery of and payment for the Bonds. SECTION 6.2. Notices. All notices, demands, certificates or other communications (other than the Closing Papers) under this Purchase Agreement shall be sufficiently given and shall be deemed given when hand delivered or when mailed by certified or registered mail, postage prepaid, or by. prepaid telegram, with proper address as indicated below: To the Issuer: City of Clearwater. Florida 112 South Osceola Avenue, Third Floor Clearwater, Florida 33756 Attention: Mayor~Commissioner Copy to: City Attorney 112 South Osceola Avenue, Third Floor Clearwater, Florida 33756 To the Companv: BEF, Inc. 1601 Jack Street, Suite 200 Fort Myers, florida 33901 Attention: President To' the Underwriter: B.C. Ziegler and Company III Second Avenue, N.E., Suite 915 81. Petersbuf& Florida 33701~3411 Attention: Richard J. ScanIo", Vice President SECTION 6.3. Amendment. No modification, alteration or amendment to this Purchase Agreement shall be binding upon any Party until such modification, alteration or amendment is reduced to writing and executed by all Parties. SECTION 6.4. Governing Law. The laws of the State of Florida shall govern this Purchase Agreement. 23 19- /r .L:lt o > ..... ". \ '''-) , ) "-... """"'..> I:,. ~~.... . ~ SECTION 6.5. Captions. The captions or headings in this Purchase Agreement are for convenience only and in no way define, limit or describe the scope or intent of any of the provisions of this Purchase Agreement. SECTION 6.6. Counterparts. This Purchase Agreement may be signed in any number of counterparts with the same effect as if the signatures thereto and hereto were upon the same instrument. SECTION 6.7. Severabilitv. If any provisions of this Purchase Agreement 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 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 reaso", such circumstance 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 Purchase Agreement contained, shall not affect the remaining portions of this Purchase Agreement, or any part thereof. SECTION 6.8. Effective Time of this Agreement. This Purchase Agreement shall be effective and binding upon its execution and delivery. [SEAL] ATTEST: CITY OF CLEARWATER, FLORIDA By: City Clerk By: Mayor~Commissioner Approved as to Fonn and Legal Sufficiency By: City Manager By: City Attorney DEF, INC. By: President D.C. ZIEGLER AND COMPANY By: Title; 24 tJ"/f ..---) . . .~~ " 'J <J ~.' .-t'h~)..r.r"".'~"''''''.~''' :1 EXHIBIT A Pricinf;t Data I. Purchase Price: The Purchase Price for the Series 1999A Bonds is $ which reflects an underwriting discount ofS L-% of principal amount) and an original issue discount of $_ L-% of principal amount). The Purchase Price for the Series 1999B Bonds is $ which reflects an underwriting discount of$ '--% of principal amount) and an original issue discount of$_ L-% of principal amount). The Purchase Price for the Series 1999C Bonds is $ which reflects an underwriting discount of$ L-% of principal amount) and an original issue discount . of $_ L-% of principal amount). The Underwriting fee is S L-% of principal amount). II. Maturities and Interest Rates: SERIES 1999A BONDS Due ( .1) Principal Amount lnterest Rate [To Come) SERIES 19998 (^J EXTRASSM Due ( .]) Principal Amount Interest Rate [To Come) SERIES 1999C [A) BONDS A-I 19'1ft . . - ~~..-~ .' .. ~ ) '-..,../ o '. ..ooI_......,........AaIMl;'-..- Due . ( . 1) Principal Amount Interest Rate [To Come] . From and after . --J the interest rate is subject to adjustment in accordance with ,the terms of the Indenture. III. Call Provisio~: SERIES 1999A BONDS Mandatory Sinking Fund Redemption. The Series ! 999A Bonds maturing November! 5. 20_ are subject to mandatory redemption prior to maturity in paltt by lot, on November 15 of each year, beginning November 15, 20 -J at a redemption price equal to 100% of the principal amount of such Series ) 999A Bonds being redeemed plus accrued interest to the redemption date~ without premium, in the foUowing principal amounts and in the following years: Year Amount · ~lalunty The principal amount of Series 1999 A Bonds required to he redeemed as set forth above shall be reduced pro rata by 8Il1ounts equal to such principal amount of the Series 1999A Bonds of such maturities which are purchased by the Tender Agent or Trustee for cancellation and retirement with moneys provided by the Company. Optional Redemption. The Series 1999A Bonds maturing on or prior to November 15,20_ are not subject to redemption prior to maturity at the option of the Company. The Series 1999A Bonds maturing on or after November 15, 20)) are subject to redemption prior to their maturity, at the option of the Issuer, at the written request of the Company on or after November 15,20-, at any time in whole or in part, in order of maturities as shall be determined by the Company and by rot within a maturity, on any Interest Payment Date, at the redemption prices (expressed as percentages A-2 1 I 11-/C( -" ~ ..-..) 0'11..,,,, .-.J of principal amount of Series 1999A Bonds to be redeemed) set forth in the table below, plus accrued interest thereon to the date fixed for redemption: Period of Redemption (All dates inclusive) November 15,20_ to November 14,20_ November 15,20_ to November 14,20_ November 15, 20 and thereafter Redemption Prices 102% 101 100 SERIFS 19998 EXTRASSM - Mandatory Sinkinfl Fund Redemption. The Series 19998 EXTRASSM are subiect t~ mandatory redemption prior to maturity in Dart. by lot (except that Series 1999B EXTRASSM that have been tendered for purchase on any Ootional Purchase Date but were no so purchased shaH be redeemed orior to anv other Series 1999B EXTRASSM). on November 15 of each year. bel2;inning November 1 S. 20 . at a redemotion price of 100% of the princioal amount thereof. plus accrued interest thereon to the redemotion date. without oremium. in the followin~ principal amounts in the roHowina years: Year -- Amount · MaturitY The princioal amount of Series 1999B EXTRASSM reauired to be redeemed as set forth above shall be reduced ora rata by amounts eQual to such orincipal amount ofthe Series 1999B EXTRAssM 2,f such maturities which are purchased by the Tender A~ent or Trustee for ~cellation and retirement with monevs provided by the Como any. Optional Redemption. The Series 1999B EXTRASSM may be redeemed in whole or in part on any date occurring within the redemotion oeriods. as set forth below. by the Issuer uoon the direction of the Comoany. The redemption price for any such redemotion shall be at a redemption price eQual to 100% of the principal amount of the Series 1999B EXTRASSM or portion thereof so redeemed on the applicable redemption date. plus accrued interest to the redemption date. A~3 CfI-/~ . "":"-:~~_:'::':"'~"""".L':"""_"';''''''"'''''-__' ~ . . ; "-,1 .~) ".C. H'. 'i'" ~~, . ----~------~~--~------_._-----------------------------~---_. I i (i) Durim~ the oeriod between the issuance of the Series 1999B EXTRASSM and the initial Rate Change. the Series 1999B EXTRASSM are subiect to ootional redemotion on or after November 1 5.20 . .(ii) Durin~ any Rate Period of three years in lenlrth. the Series 1999B EXTRASSM arc subiect to ootional redemption commencinR on the 18~month anniversary of the first d~X of such Rate Period~ (iii) Durin~ any Rate Period offive vears in lemzth. the Series 1 999B EXTRASSM are subiect to oPtional redemPtion comrnencin~ on the 24-month anniversary of the first daX of such Rate Period. (iv) During any Rate Period of seven vears in length. the Series 19998 EXTRASSM are sublect to oPtional redemption commencin~ on the 30-month anniversary of the first day of such Rate Period. (v) DurinR any Rate Period of ten or more vears in lensrth) the Series 1999B EXTRASSM are subiect to oPtional redemption commencinR on the fifth anniversary of the first day of such Rate Period. The Series 1999B EXTRASSM tendered for purchase on any Rate Change Date but not so ~~rchased shall be wven orioritv for red emotion on each succeedinR ootional or extraordinary redemption date until redeemed orior to the oPtional or extraordinary redemPtion ofanv other Series 1999B EXTRASSM Series 1999 Bonds 50 given prioritv shall be selected by the Trustee. by lot or in such other equitable mann~r as the Trustee shall deem aoprooriate. in the event ofin5ufficient funds 10 redeem all such Series 1999 Bonds on any particular red emotion date, SERIES [^ ) 1999C BONDS . Mandatory Sinking Fund Redemption. The Series [^) 1999C Bonds maturing November 15. 20_ are subject to mandatory redemption prior to maturity in part. by lot, on November 15 of each year, beginning November 15t 20-, at a redemption price equal to 100% of the principal amount of A4 Cf1-,/r . " "' . such Series (^ ) 1999C Bonds being redeemed plus accrued interest to the redemption date; without ~ premium, in the following principal amounts and in the following years; / Year Amount · Maturity The principal amount of Series (^] 1999C Bonds required to be redeemed as set forth above shall be reduced pro rata by amounts equal to such principal amount of the Series (^] 1999C Bonds of such maturities which are purchased by the Tender Agent or Trustee for cancellation and retirement with moneys provided by the Company. <~) Optional Redemption. The Series (^) 1999C Bonds maturing on or prior to November 15, 20_ are not subject to redemption prior to maturity at the option of the Company. The Series [^] 1999C Bonds maturing on or after November' IS, 20)) are subject to redemption prior to their maturity, at the option of the Issuer, at the written request of the Company on or after November 15, 20-, at any time in whole or in part, in order of maturities as shall be determined by the Company and by lot-within a maturity, on any Interest Payment Date, at the redemption prices (expressed as percentages of principal amount of Series (^] 1999C Bonds to be redeemed) set forth in the table below, plus accrued interest thereon to the date fixed for redemption: Period of Redemption (All dates inclusive) November 15,20_ to November 14, 20_ November 15,20_ to November 14, 20_ November 15, 20 and thereafter Redemption Prices 102% 101 100 (^][^)[^] A-S I I I I I 1 1 il 1 ~~ qq~/ff ......-...""",... . : I __n...............~ .:.. _ nO : _no .,.~..... ........,,. ..,-.. . .. t " . ',. ',. '::1', .. . " '~: ". ...: ~:Ic ,', , , . ~.'" . " '';..J,~ 'I',,,.,... ,'" _ _ " I I' .' ,; , .:~.~ ~. " ,~ , . ; J ........4..... . ." ~. ," . 'I Cy.';;'-.., .,' " >I'~ v' ,:1." .~< I ," ~.~I"~: ~:\.:. . \~ : ..',." . " Ii . ~ . ;'1" . .'~: I' ..; '-t"'. ./' " " . ~.. 'p ~;: .'. . r<:;',: , , , ' ., 1"'1 ....,~ ;::::. '; .i :'. ~.~ .'. .:1 ~" . "" .' ~... ://"~,) (;',:\..:..:;,1. , \. :~", . I . .: ;',) 'I : " : :: '. ,): .;. .\ ,. ,,' ~" . ~'..~'\ :,'. ~.' .' }. ... o ,I;.. , ' '.' .,e. ~l.ol'>."'!"""-:",",~-.' C"" '~I!'1L:~. ,':1<: '~!'<'~l~:"~ '~:.~:~ ~ . . -----_-..-.::...~~- .. ," .,"> ',1 ,. .....-...U\.".'l'W"~ ....'.......l.,....'.)..~.,. ~.. , ' '. EXHIBIT B Accountant's Comfort Letter ... . , ... B-1 .............~.t.....L~r.;;.~ .::;-'. .-:.", ~.".A ,~..... .. ... -. . ,;. .......~", ...1, , ~ .. ~ *" .; \.,' /.;.~ I I 19' let :~..., ~.;"". '~_~tI.\~..(........ :.,........ ~; ':" ::. " . " ,f. .' ........ '~".~ . , . '" " ~', - , .' . , , ,,' " .. "\,~, , ~';': ~~: ~ "'0 '. ,:".... '. ;, .~ ~' ':- ':, :0-." .1....: \: .' ,. i~'~~ '~:,~ . .. ' "': -:", . t:'..1 ) ~ ,. \,. o ,'1', ., .~. , '~l l . ~ ~ L r:...;. ! ..J I: ' ',., . '. ;.' \ ~ '<. . r ..,'. " ,..,j, ;..: \ ", ,. ! i ~ ,'. l :,~.' .~ ., . ';~.:.~\ . . , '-" ,~?-:,:: ; :'~>+~>,:..:.. <." ... ~t:;~>.::""" ; ~ .' . < C C ~ . ~ .' ". " li: i !,:~>::;:;,',:,;~: ';' ,~'~:' '/ 'I' , , ,) . ~ c '" " '" ". I I .~, ~;, ":;'(. EXHIBIT C Accountant's Bring Down Le:tter .. '\.>.:,").1\:' .' C-l q9~ / r. ;' EXHIBIT 0 ) Opinion of Company's Counsel (Terms defined in the Purchase Agreement are used here with the same meanings) I. The Company is a not~for~profit corporation duly organized and validly existing under the laws of the State of Florida. 2. The Company is duly licensed or qualified to do business in the State of Florida (including, without limitatio~ operating the Mortgaged Property as an independent living, assisted living and skilled nursing facility) and each other state in which the ownership of property or the transaction of business by the Company requires that the Company be licensed or qualified and in which the failure to qualify would have a material adverse effect on the Company or the transactions contemplated by the Final Official Statement. 3. The Company has full right, power and authority to enter into, execute and deliver the Company Documents, to perform its obligations thereunder and to execute and deliver the Final Official Statement. ~ 4. The execution, delivery and performance of the Company Documents and the execution and delivery of the Final Official Statement, for and in the name of the Company, have been duly authorized by all necessary corporate action on the pan of the Company. 5. The Company Documents and the Final Official Statement have been duly executed and delivered on behalf of the Company, and the Company Documents constitute valid and binding instruments and obligations of the Company enforceable in accordance with their respective terms. 6. The Company is private not-for-profit corporation ofwhich no part of the net earnings inures to the benefit of any private shareholder or individual and has the authority to own and operate the facilities owned and operated by it (including, without limitation, the Project), and the Company will not, to our knowledge, as a result of any transactions contemplated by the Company Doaunents or the Final Official Statement, be engaged in an unrelated trade or business detennined by applying Section 513(a) of the Internal Revenue Code of 1986, as amended (the "Code"), nor is the Bond financed property proposed to be used to our knowledge, in the trade or business of any non-exempt person so as to jeopardize the Section 501(c)(3) status of the Company or to render the interest on the Bonds subject to federal income taxation. 7. The Company has received a letter from the Internal Revenue Service determining it to be an organization described in Section SOl{c)(3) of the Code, the Internal Revenue Sef\;ce determination letter is in full force and effect, and, to the best of our knowledge, after due inquiry, no facts and circumstances have occurred which could cause the determination letter to be revoked; ,~ D-l 11" I~ ~'~~":::~::~...s___~____._ '~-"'\ .~_.... \ -........I the Company is exempt from federal income tax under Section 501 (a) of the Code; and the Company is not a "private foundation" as defined in Section 509(a) of the Code. 8(^J. The current and anticipated use by the Company of the Mortgaged Property is in compliance applicable zoning, land use and similar laws, ordinances and regulations, the violation of which would have a material and adverse effect on the use of the Mortgaged Property. (^J 2. The form of the Mortgage, the assignment thereof, and the financing statement executed in cOMection with the Mortgage comply with all applicable recording and filing laws ofthe State of Florida. The property descriptions of the real properties contained in the Mortgage are in proper form for the purposes of all applicable recording, filing, and registration laws. [^J J,g. The fuUy executed counterpart of the Mortgage has been recorded in the offices ofthe Clerk of the Circuit Court of Pine lias County, Florida, and a fully executed counterpart of the financing statement executed in connection with the Mortgage has been filed in the real estate records of such County and in the office of the Secretary of State of the State of Florida, To perfect a security interest in the Mortgaged Equipment, including the Revenues (as defined in the Mortgage), and other personal property which is intended to be subject to the Mortgage and which can be perfected by filing a financing statement under the Florida Uniform Commercial Code, it is necessary to file a financing statement in the office of the Secretary of State of the State of Florida. A fully executed counterpart of the financing statement executed in connection with the Mortgaged Equipment has been filed in the office ofthe Se~retary of State of the State of Florida. We note that continuation statements under the Florida Unifonn Commercial Code can be properly and timely filed in each office in which a financing statement is filed within the six~month period preceding the expiration of each five year period after the date of filing of each such financing statement in order to extend the perfection of the security interest beyond five years from the date of filing of such financing statements. No other filings are necessary for the purpose of creating and perfecting a mortgage lien and security interest, other than an extension or other similar agreement with respect to any renewal or extension ofthc obligations under the Agreement and continuation statements as required by the Uniform Commercial Code of the State. With such filings, the Mortgage will constitute as security for the Bonds and the other obligations referenced in the Mortgage, (i) a valid mortgage Hen on all real property and interests in the real property described in the Mortgage as being mortgaged thereby, and (ii) a perfected prior security interest in all tangible personal property (except for property in which a security interest cannot be perfected by filing or recording), fixtures and Revenues described in the Mortgage as being mortgaged thereby to the extent the Uniform Commercial Code of the State of Florida is applicable thereto, The Uniform Commercial Code filing search performed by , dated . 1999, shows no other filings by the Company. Title Insurance Company has issued a standard form AL T A title insurance potiey (policy No. , effective . 1999) to the Issuer and the Trustee in the amount of $ insuring in effect (subject to standard exclusions from the coverage of mortgagee's title insurance policies) that the mortgage lien of the Mortgage will be superior to any other liens and encumbrances on the real property covered thereby, except for certain designated encumbrances which, in our opinion, are permitted under the Mortgage. The Mortgage and financing statements create a lien upon and security interest in the real property and personalty described therein, subject only to Permitted Encumbrances (as defined in the Mortgage). D-2 q7~/r --- (^Ill. No c~rtificate of need or other Florida health planning agency approval or . consent is required for the transactions contemplated by the Company Documents, inc1uding the ~ acquisition, construction and installation of the Project, unless such certificate or other approval has been obtained. .~.'c ~ :,-) o (^IJZ. No authorization, approval, consent, pennit or license of any regulatory body or governmental authority, not already obtained, is required on the part of the Company for the valid and lawful authorization, execution and delivery of the Company Documents and the assumption by the Company of the obligations represented thereby or for the acquisition, construction and installation of the Project. (^Ill. The execution and delivery of the Company Documents and the assumption , by the Company of the obligations represented thereby will not conflict with, violate or constitute a breach of or default under the Company's Articles of Incorporation or bylaws or any commitment, mortgage, indenture, agreement or instrument known to us (after having made due inquiry with respect thereto) to which the Company is a party or by which the Company is bound or, to the best of our knowledge, any applicable law, administrative regulation or court decree. (^Ill. To the best of our knowledge after having made due inquiry with respect thereto, except as described in the Final Official Statement, there is not pending or threatened any actio", suit, proceeding, inquiry or investigation at law or in equity or before or by any court, public board or regulatory agency, against or affecting the Company wherein an unfavorable decision, ruling or finding would have a material adverse effect on the business, properties or financial condition of the Company or would adversely affect the Company's powers or existence or the validity or enforceability of the Bonds. the Company Documents or the Indenture, or which might adversely affect the Company's ability to perform its obligations under the Company Documents. [^] ll. Nothing has come to our attention that would lead us to believe that the Final Official Statement (other than the Issuer Portions. the Feasibility Studies appearing in Appendices A and B thereto or the financial statements appearing in Appendix D thereto, as to which we express no opinion) contains any untrue statement of a material fact or omits to state any material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading. It is to be understood that the enforceability of the Company Documents is subject to bankruptcy, insolvency, reorganization, fraudulent conveyance, moratorium and other similar laws affecting creditors' rights heretofore or hereafter enacted, to the extent constitutionally applicable, and that their enforcement may be subject to the exercise of judicial discretion in accordance with general principles of equity. 0-3 11, /i -l..~..ai..-I" ......'... .... , ... I.'''' ...............--~.....................__. - r-.... EXHIBIT E Opinion of Counsel to the Issuer (Terms defined in Purchase Agreement are used here with the same meanings) 1. The Issuer is duly organized and validly existing as a municipal corporation of the State of Florida, with the powers and authority set forth in the Act, including the authority to issue and sell the Bonds and execute, deliver and perfonn its obligations under the Issuer Documents: 2. The officials of the Issuer identified in the certificates of the Issuer delivered on the Closing Date have been duly elected or appointed and are legally qualified to serve as such. 3. To the best of my knowledge, the Issuer Documents do not violate or conflict with the provisions of any indenture, mortgage, agreement or other instrument to which the Issuer is a party or by which it or its properties may be bound. 4. No additional or further approval, consent or authorization of any governmental or public agency or authority not already obtained is required by the Issuer in order to issue or sell the Bonds or enter into and perform the obligations of the Issuer under the Issuer Documents. " -'-., ,......./ 5. There is, to the best of my knowledge and infonnation, no action, suit, proceeding or investigation at law or in equity before or by any court, public board or body, pending or, to the best of my knowledge and information, threatened against or affecting the Issuer, wherein an unfavorable decision, finding or ruling would adversely affect the transactions contemplated by the Final Official Statement and the Issuer Documents. 6. The Issuer's Authorizing Resolutions have been duly adopted by the Issuer, comply in aU respects with the procedural rules of the Issuer and the requirements of Florida law and remain in full force and effect on the date hereof 7. To the best army knowledge, the information contained in the Issuer Portions of the Preliminary Official Statement and the Final Official Statement is true and correct in all material respects and such documents do not contain any untrue statements of material fact and do not omit to state any material fact required to be stated therein or necessary to make the statements therein, in light of the circumstances under which they were made, not misleading~ it being understood that no opinion is being rendered with respect to the information contained in the Preliminary Official Statement or the Final Official Statement other than the Issuer Portions. \.J E-l '11" I f'/ ':L"l;~~r...,~..::_..~'ltl'.' :~~..............o.a...-________. ~'\. ....-.----~--- .--.. ~ +' c' .: ' . , ' . ", , , " ~ <!c. " ':. ., ;.. . .:,' '. 11 ~ -. ~ t~.: :~~., ~.., . . " . I', In., ;:.n. .'. , '~tb-n'" ' (0'. ' . .,' 'lY': ~ f"'.' . .," <',' .,- ~ " ~" .~ ~ ,,' o. J. ,,' . . ,': L. J. '. ,;. ,. . :}L.' : ;/. , ".\" .. .> .,....' . .... ."' :. ,I .' ::,;'!.>~~ :,,:V . , " :'.' , " :.' , ' '. ' , :' .' ~ " I .' :;';: . . " ::('0 ,. ' ,"j . . . . \. "' < ---------- EXl-UBIT F Form of Bond Counsel Opinior} :The Form of Bond Counsel Opinion is attached as Appendix G to the Preliminary Official Statement. F - 1 ; t j j II I, I ! 1'1~/~ EXHIBIT G .") ", ~. Supplemental Opinion of Bond Counsel I (Terms defined in Purchase Agreement are used here with the same meanings) 1. No registration with the Securities and Exchange Commission under the Securities Act of 1933, as amended, need be made in connection with the offering and sale of the Bonds by the Underwriter, and the Indenture is not required to be qualified under the Trust Indenture Act of 1933, as amended. 2. ,With respect to the information in the Final Official Statement;and based on our review of said Final Official Statement as bond counsel, and without having undertaken to determine independently the accuracy or completeness of the contents of the final Official Statement. the information in the Final Official Statement under the headings uINTRODUCTION" (other than the information contained under the subheadings uThe Company and the Facility," "Historical and Selected Financial Information" and "Bondholders' Risks" as to which no opinion is expressed), "THE SERIES 1999A BONDS," liTHE SERIES 1999B [^) EXTRASSM3I" UTIIE SERIES 1999C [^) BONDS," liTHE SERIES 1999 BONDS - ADDITIONAL INFORMATION," "TAX MATTERS It and "APPENDIXE - Definitions and Summary ofPrincipal Documents," insofar as the same pUiports to describe or summarize the provision of the Bonds, the Agreement, the Notes, the Indenture, the , . '. Mortgage. the Act and the Code. are accurate and fair summaries of the information purported 10 be \.,..,J summarized therein. 3. AU conditions precedent in the Indenture relating to the authentication and delivery of the Bonds have been satisfied. 4. The Underwriter may rely on our bond opinion dated even herewith, with respect to the Bonds to the same extent as if such opinion were addressed to the Underwriter. ," '..J G w 1 Cf'l-/fI IA./'[..JTU. ..~-II-"'" ,,""," ~. , , r"'" ..... t-...-.6iUlIt.........-......ou....-.__ - ~ ,',J .~ I r\'l. ' '. ~...' ~I. z._.,. ~ . EXffiBIT H Disclosure Statement . 1999 City of Clearwater, Florida 112 South Osceola Avenue, 3td Floor Clearwater, Florida 33756 BEF, Inc. 1601 Jack Street, Suite 200 Fort Myers, Florida 33901 Re: City of Clearwater, Florida Revenue Bonds, Series 1999A (BEf, Inc. Project), [^) Revenue Bonds, Series 1999B (BEF, Inc. Project) ~xtendable Rate Adiustable SecuritiesSM CEXTRASSM) and Taxable Revenue Bonds, Series 1999C (BEF, Inc. Project) [^) Ladies and Gentlemen: , In connection with the proposed issuance by the City of Clearwater. Florida (the "Issuer") of $ aggregate principal amount of the above- referenced bonds (the "Bondstl), B, C. Ziegler & Company (the "Underwriter") is underwriting a public offering of the Bonds. The purpose of tros letter is to furnish, pursuant to the provisions of Section 218,385(6), Florida Statutes, as amended, certain information in respect of the arrangements contemplated for the underwriting of the Bonds as follows: 1. The nature and estimated amount of expenses to be incurred by the Underwriter in connection with the purchase and offering of the Bonds are set forth in Schedule I attached hereto. 2. No person has entered into an understanding with the Underwriter, or to the knowledge of the Underwriter, with the Issuer for any paid or promised compensation or valuable consideration, directly or indirectly, expressly or implied, to act solely as an intermediary between the Issuer and the UndelVlTiter or to exercise or attempt to exercise any influence to effect any transaction in the purchase of the Bonds. 3. The underwriting spread (the difference between the price at which the Bonds will be initially offered to the public by the Underwriter and the purchase price to be paid to the Issuer for the Bonds, exclusive of accrued interest) will be $ . 4. As part of the estimated underwriting spread set forth in paragraph (3) above, the Underwriter will charge a management fee of $ H - 1 1f~/~ ._..,._-.......---_.....,-~_......._,- .~ " \ I '~J )~~,. >.. u ra:.r..~.;i.Wh.t,.,'I,..,"'_:".~' ...... . S. No other fee, bonus or other compensation is estimated to be paid by the Underwriter in connection with the issuance of the Bonds to any person not regularly employed or retained by the . Underwriter (including any "finder" as defined in Section 218.386(1)(a), Florida Statutes, as am~nded), except as specifically enumerated as expenses to be incurred by the Underwriter, as set forth in paragraph (1) above, (1) The name and address of the Underwriter is: B.C. Ziegler and Company III Second Avenue, N.E., Suite 915 St. Petersburg, Florida 33701-3411 Attention: Richard 1. Scanlon, Vice President We understand that you do not require any further disclosure from the Underwriter pursuant to Section 218.385(6), Florida Statutes, as amended. Truth-in-bonding Statement The Issuer is proposing to issue the Bonds for the purpose of providing funds sufficient, together with other available moneys, to (i) finance or refinance the cost of the acquisition and construction of various capital improvements to certain continuing care retirement facilities owned by BEF, Inc. and located in the City of Clearwater~ Florida. (ii) fund a debt service reserve fund with respect to the Bonds and (Hi) pay certain costs with respect to the issuance of the Bonds. The Bonds are expected to be repaid over a period of30 years, At interest rates shown on the back of the cover page of the Final Official Statement, dated , 1999, relating to the Bonds, and assuming an interest rate of _ for the variable rate portion of the Bonds, total interest paid over the life of the Bonds will be $ The source of repayment or security for the Bonds consists of loan payments to be made by BEF, Inc., as repayment for the Joan of the proceeds of the Bonds, and certain other revenues and proceeds as provided in the Indenture relating to the Bonds. Authorizing the Bonds will not result in any adverse change in the amount of Issuer moneys available to finance other H - 2 99" /C{ , , " . ~. . \ .. . . : " ...~ > \.' c .. , '. ." ,'- "r"~ J.. " .. " . i. I... ;,'h ~"... I.... ,"' '(," . " '; " ::' . H.-"," I:' .: ," ,', , :,\' , J-~ ;., /' . . ;0" ~ ., . , . }: ".' ' :. ": "I: ~ ': . . ("'... . 'U t(._. services of the Issuer. The foregoing statements are intended to comply with Section 218.385(2) and (3); Florida Statutes, as amended. and shall not affect .or control the actual terms and conditions of the Bonds. . , , . . , H - 3 Very truly yours, B.C. ZIEGLER AND COMPANY By: . Richard J. Scanlon Vice President , , .1 I ,/ 99-/f( . . ~nWJI"''''''''''''''''''''' ~ . '''::''~':'':'-'~__:...::'__t__~~:~.' . ...~_~__'~__~~::~.~~~_.__~~+~" 1".~~<~'" .""' u.,.~'... L~~L"-;~~ '/'L 1~. ; .'. J' ~~. I. "," " ~ . h:c ,~,.,.""u".........._.. ...,~ " d, ~ .../ . , c.:' ""/ ,"J. ",' >: :. ? . '.l~..-:"~ ."'; c \:i: '., . , '::'0 '. " . ::~ " :. . r. . ~ ; ~.: c ;. . , . ~ \: ' '. .r"1 " !.' . . (: . ~ ': () '.. r . }:" '0 ': . . . '. . . .. 1<'. ' ,'. . , . . ,11 . . . '." . : I . SCHEDULE I UNDERWRITER'S ESTIMATED EXPENSES Underwriter's Counsel (fee and expenses) Travel and Out~f.Pocket(l); Federal Funds; Data Processing and Communir.ations; MSRB, CUSIP, dalnet, PSA and DTe .Total (1) . Includes computer, travel, telephone and telecopy and internal advertising: .. . 'H - 4 .1 C(9" /'1 I j .1 . . . . -----""--------- 1 I I 1 . I "'l , I t I '. l ......,/ ,~) EXHIBIT I Form of Architect's Certificate The undersigned, (the "Architect")1 hereby certifies to . as Trustee (the "Trustee"), as follo'ws: 1. The Architect is a licensed architect in the State of Florida and has been engaged by BEF, Inc. (the uCompanyU) to design and supervise construction ofthe improvements described on Exhibit A hereto (the "Projectll). In such capacity, the Architect has prepared plans, specifications and working drawings for the Project (collectively, the nplanslt). 2. In addition, the Architect has been engaged by the Company to advise the Company as to necessary pennits and the applicability of governmental regulations to the construction of the Project. 3. The Architect acknowledges that the Company is obtaining a portion of the funds for construction of the Project from the proceeds ofCily of Clearwater, Florida Revenue Bonds (BEF, Inc. Project) (the "Bonds") and that the Trustee is indenture trustee for holders of the Bonds. 4. All necessary permits for construction of the Project, including a building permit and any required stormwater drainage pennits, have been received by the Company and are in effect. 5. The Project, as constructed in accordance with the Plans, will satisfy all federall state and local building codes and other regulations, including, without limitation, all requirements of the Americans with Disabilities Act and with all zoning, setback and other land use regulations. 6. The Architect has satisfied itself that the soils beneath the Project will provide adequate, stable support for the Project as completed. 7. Adequate water, sewer and electrical lines are available at the Project site to adequately serve the needs of the Project and adequate utility capacity has been reserved, if applicable. Water is provided by and sewer service is provided by 8. The Project budget, trade and materials breakdown and schedule of values, as previously provided to the Trustee, are sufficient to complete the project in accordance with the Plans. 9. The certificate ofinsurance attached hereto as Exhibit B accurately reflects the errors and omissions coverage of the Architect and such coverage has not been terminated or reduced. I - 1 f'r,/CZ( ;!': ~ ' ,.~ '0 ('~"') ~J .,' '.........~,/;..........>104._......:..c >. ,\'c \. ,~.. .; ~ ., '. . ~) > -' > -~ 10. ' The Project will have adequate parking. including handicapped parking and curb cuts. to meet aU governmentaJ requirements and for the practical and efficient use of the Project as intended. > J J. The Architect has reviewed applicable zoning, concurrency and other applicable land use regulations and such regulations permit the construction and use of the Project for its intended purpose without the necessity of a variance or exception. 12. The Architect has reviewed a current survey of the Project site and construction of the Project will not encroach upon any property lines, easements. rights-of-way or setback lines. This certificate is given with the understanding that it win be relied upon by the Trustee on behalf ofho!ders of the Bonds. [NAME OF ARCHITECT] By: Its: :1 . .1 - 2 . ,9'1 ~ /8 . . i . ~.. ..', L '. "... ~ "', .... T""" , . " .., ...;~. ,'-'. ,~,. . ...' . . ,~.. . ~ ... .' ..' ..." I . " .... , r . , .1 ''7J " ' . '~..\ ", .'~." J " ' ......; .;'"'~"'''t t.....j ~'~:..:,(.!....~"~~t..L-TI.tn' ._, EXHIBIT J Fonnor Opinion of Counsel to the Trustee 1. The Trustee is a national banking association with trust powers, and is duly organized, validly existing and in good standing under the laws of the United States of America. 2., The Trustee has the corporate power and authority to carry out the duties and obligations of the Trustee under the Indenture. ~. The execution, delivery and perfonnance by the Trustee ofthe Indenture has been duly authorized by all necessary corporate action on the part of the Trustee. 4', The Indenture constitutes a legal, valid and binding obligation of the Trustee, enforceable against the Trustee in accordance with its teons, except as such enforceability may be limited by applicable bankruptCYt moratorium. insolvency or other similar laws affecting the rights of creditors generally and by general principles of equity. 5. The Bonds have been duly authenticated by the Trustee. J - 1 1r-/rr '......-....... I.",' ;. ~ ;' . .._.~.....:.........-----"-.:.'~~:~~_.,--_. .', . . \ ~ ' ~'.I ,I .,., :~ ;:"::. { . ~ } ,I." .. . :. ~. 'j"., >/. . , '. "-'I . ,. " ~' .. ~ _. ,. r'.. ~ 1'1 . > .... ~ I' 'n '"':1-....,..,. . j~' . , ":, ..:n,< .. ".' il ':"'2)" . I ~ '. ,~, . ". I'" . " 'l ;>I,,' ~:. "", .. ,,v. " ....1 ~:, i~\:,. :' ~<.~. t' .., '.1 .. ". ~ ~:. ',' ,. . ~~ . I, I"., ';'l ,.~F~ 1, ""j'~' , . .....:. 1 ';{:ji\ " :".'\..... " . .t;~.:.r~;:;:,~.~.~~~~.~~ '-~.~.~'. ;. ,; i" .... ., , j ':, .\ " . ( , I ,.1 ,\ EXHIBIT F FORM OF PRELIMINARY OFFICIAL STATEMENT " .' , '. . ..~ ......, .., "if. '.... ._ .'.. :~\ < '1" :- ~ c~~...'" ~ ~'. . '.";~;' :~ C.,/ !;-;=+,1;C::,,~..~~~~'"..."'-~.t ...,..;.. t ,'.~,,..~ ~ .tl-....i;,.} ~ "..t -cJ ~ c . ~"'" .' Resolution 99~ 18 ...... '. ..... ...,.~. .., ~. ..... .....,....""-41...... -'" "'"'-". .'1 OFFICIAL STATEMENT CITY OF CLEARWATER, FLORIDA (^J REVENUE BONDS, SERIES 1999 (DEF, INC. PROJECT) Consisting or $ . CITY OF CLEARWATER, FLORIDA [^) REVENUE BONDS, SERIES 1999A (DEF, INC. PROJECT) $. . CITY OF CLEARWATER, FLORIDA [^] REVENUE BONDS, SERIES 1999B [^)(BEF, INC. PROJECT), EXTENDABLE RATE ADJUSTABLE SECURITIESSM(EXTRASSM) $ l\' CITY OF CLEARWATER. FLORIDA TAXABLE REVENUE BONDS. SERIES 1999C tUEF. INC. PROJEC:;!) \ .._.J INTRODUCTION The following introductory statement is subject in all respects to more complete information contained elsewhere in this Official Statement. The order and placement ofmatenals in this Official Statement, including the appendices, are not to be deemed to be a determination of relevance, materiality or relative importance, and this Official Statement, including the cover page and appendices, must be considered in its entirety. All capitalized terms used in this Official Statement that are not othenNise defined herein shall have the meanings ascribed to them in APPENDIX D hereto. See APPENDIX D - "Definitions and Summary of Principal Documents." Purpose of the Omcial Statement The purpose of this Official Statement, including the cover page hereof and the appendices hereto, is to furnish certain information relating to (1) the City of Clearwater, Florida (the "Issuer"). (2) the Issuer's Revenue Bonds, Series 1999A (BEF, Inc. Project), in the aggregate principal amount of$ · (the IlSeries 1999A Bondslt), (3) the Issuer1s (^) Revenue Bonds. Series 1999B (BEF, Inc. Project) Extendable Rate Adiustable SecuritiesSM (EXTRASSM), in the aggregate principal. amount of$ " (the "Series 1999B (^J EXTRASSMU). (4) the Issuer's Taxable Revenue Bonds, Series 1999C (BEF, Inc. Project) (^), in the aggregate principal amount of$ · o .Preliminary, subject to change 19-fC? ~..Io ~.,oA'~~'..'" ~ ... I, ,~ I (the "Series 1999C [^) Bonds"}, and (5) BEF, Inc., a Florida not-for-profit corporation (the "Company"). The Series 1999A Bonds, the Series 1999B [^ J EXTRAS SM, and the Series 1999C [^] IJonds are collectively referred to herein as the "Series 1999 Bonds. II The Issuer' The Issuer is a municipal corporation duly organized and existing under and pursuant to the Florida Constitution, the Charter of the Issuer and laws of the State of Florida. The Issuer is authorized pursuant to the provisions of the Florida Constitution, the Charter of the Issuer and Chapter IS4, Parts II and III of Chapter 159, and Chapter 166, Florida Statutes, as amended and other applicable provisions oflaw (the "Actlt) to make and execute financing agreements, contracts and other instruments necessary or convenient for the purpose of facilitating the financing of certain projects, including machinery, equipment, land, rights in land and other appurtenances and facilities related thereto, to the end that the Issuer may be able to promote the health and. safety of the inhabitants of the Issuer, the people of PinelIas County and the State of Florida by increasing their access to adequate medical care and health care faciHties, and to accomplish such financings through the issuance of revenue bonds. The Company and the Facility The Company was incorporated as a Florida not-for-profit corporation in 1975, as American Baptist Estates of Clearwater, Inc. The Company changed its name to BEF, Inc. in March of 1999. ..-.. The Internal Revenue Service has detennined that the Company is an organization described in '~'w) Section 501(c)(3) of the Internal Code of 1986, as amended (the "Code"), and is therefore exempt from federal income taxation under the provisions of Section 50 I (a) of the Code. The Company received its Determination Letter from the Internal Revenue Service in May, 1976. The Company and The Oaks of Clearwaterl Inc. (the "Oaks") own and operate retirement facilities located in the City of Clearwater, PinelIas County, Florid~ known as The Oaks of Clearwater Retirement Community (collectively, the "Facility"). The Facility is currently comprised of two high-rise buildings, Oak Bluffs, a IS-story building (the "Bluffs Building"), and Oak Cove, a 13-story building (the "Cove Building"), and four low-rise villa buildings (the ItViHasn) which contain skilled nursing facilities owned and operated by the Company (the "Nursing Centers") and independent and assisted living facilities which are owned and operated by the Oaks. The Company provides three different levels of care to residents of the Facility: independent living, assisted living and nursing care. Residential areas within the Facility include 12 one-bedroom garden apartments located in the Villas, 8 two-bedroom garden apartments and 391 one-room and two-room high-rise apartments (213 of which are currently unoccupied ane located in the Cove Building and the remainder are located in the Bluffs Building) (collectively, the (^J"lndependent Living Unitsn)~ [^] ~ assisted living units (^] located in [^J the Bluffs BuildinJ;t (the "Assisted Living Units")~ and the Nursing Centers, which o 2 19,.( f/ } ') , are comprised of a 60~bed skilled nursing facility located in the Bluffs Building (the "Bluffs Nursing Centerll) and a 56~bed skilled nursing facility located in the Cove Building (the "Cove Nursing Center"), The Facility is located on approximately 7 acres ofland on the Intercoastal Waterway, with views of the Gulf of Mexico, Clearwater and 81. Petersburg, Florida. The Project The Facility was refinanced through a secondary loan from the City of Clearwater, Florida, from certain proceeds ofa loan from the City of Gulf Breeze, Florida (the HSponsor"), through the Sponsor's Local Government Loan Program to the City of Clearwater, Florida, funded through the proceeds of 5ponsorts Local Government Loan Program Floating Rate Demand Revenue Bonds, Series 1985C-l. The loan to the Company and Oaks was secured by two mortgage notes (the "Company's 1989 Note" and the "Oaks 1989 Note" and collectively, the If 1989 Notes") guaranteed as to payment by the Government National Mortgage Association, or GNMA, which is a part of the United States Department of Housing and Urban Development ("HUO"). In 1996, each of the Company and Oaks declared bankruptcy and defaulted on the 1989 Notes. In connection with the plan of reorganization in bankruptcy and pursuant to their guarantee of the ' Notes. HUn purchased the 1989 Notes and the outstanding bonds were extinguished. HUn then sold the defaulted 1989 Notes at auction to Beal Bank, 5,S.B. ("Beal"). Immediately prior to the closing of the offering of the Series 1999 Bonds, the outstanding principal and interest on the 1989 Notes was $ . _/ Beal has agreed to sell the 1989 Notes for Twenty Million Dollars ($20,000,000). Pursuant to the tenns of a Note Purchase Agreement between the Company and Beal, the Company will use a portion of the proceeds of the Series 1999 Bonds to (i) purchase its 1989 Note from Beal for $ , with the Company thereby receiving clear title to the Company portions ofthe Facility (including the Nursing Centers and its portion of the common areas of the Facility), and (ii) purchase the Oaks 1989 Note from Beal for $ . with the Company acquiring the remaining portions of the Facility previously owned by Oaks by accepting a deed in lieu offoreclosure from Oaks with respect to the remaining portions of the Facility. Accordingly, upon the completion of the offering of the Series 1999 Bonds and the purchase of the 1989 Notes by the Company, the ownership of the Facility will be consolidated in the Company. The Company will use a portion of the proceeds from the Series 1999 Bonds to renovate the Cove Building (the "ProjectU), Currently, the Cove Building j!j vacant except for the Cove Nursing Center. The third floor of the Cove Building will be renovated into modem, skilled nursing units. The residents of the Cove Nursing Center wil! be transferred to the new third~floor nursing facility upon completion. The old Cove Nursing Center wilt then be renovated and rehabilitated to meet current standards and the residents of the Bluffs Nursing Center wilt be transferred into such renovated space upon completion. At the same time the remaining floors of the Cove Building will be completely rehabilitated to provide for senior independent and assisted living units in order to \..J 3 19" (~ ,..-... . , replace the facilities at the Bluffs Building. Upon completion of such living space, the residents in the Bluffs Building who have consented to move will transfer to the Cove Building. [^] The Facility will be renovated and redeveloped pursuant to the terms of a Development Services Agreement (the "Development Agreement") by and between the Company and Complete Care Services of Florida, Inc. ("CCSFL") a Pennsylvania corporation and a subsidiary of Complete Care Services, Inc. ("CeS"), which through its subsidiaries manages over 200 nursing homes and assisted living facilities throughout the United States. primarily on the East Coast and in Ohio, Illinois and Texas. and provides development services to owners of senior housing. assisted living and long-term care facilities. The Development Agreement provides for the payment to CCSFL of three percent (3%) of the (^) renovation costs of the Project. Seventy-five percent (75%) of such fee is due upon the issuance of the Series 1999 Bonds, with the remaining twenty-five percent (25%) payable over the six-month projected construction period. Under the Development Agreement, CCSFL is required to create a detailed development plan and time schedule, prepare development budgets, oversee architectural and engineering planning. obtain all necessary regulatory consents and approvals, identify contractors and coordinate the construction bid process, oversee the construction, and oversee the transition of the renovated Cove Building until opening. The Management Company ') ....Jrl.~...... Simultaneous with the issuance of the Series 1999 Bonds, the Company is terminating its e,Qsting management contracts and is entering into a new management agreement with CCSFL. See ~ description of CCSFL in the Section entitled "THE MANAGEMENT COMP ANY It and the section entitled "THE PROJECT - The Management Companyll in APPENDIX A herein. The Series 1999 Bonds The Series 1999 Bonds will be issued pursuant to a Trust Indenture, dated as of[^] Julv 1, 1999 (the "Indenturen), between the Issuer and SunTrust Bank, Central Florida, National Association. as trustee (the nTrustee"). Pursuant to a Loan and Security Agreement. dated as of(^] ~ 1999 (the "Agreement"). between the Issuer and the Company, the Issuer willlaan the proceeds of the Series 1999 Bonds to the Company which, together with certain other funds available therefor. win be used to (i) acquire the assets of the Oaks which primarily consist ofindependent and assisted living facilities, (ii) finance the cost of renovations to the Facility, (iii) provide for working capital andlor capitalized interest, (iv) fund a debt service reserve fund with respect to the Series 1999 Bonds and (v) pay certain costs with respect to the issuance of the Series 1999 Bonds. Pursuant to the Agreement. the Company is obligated to make payments which, together with other available funds, will be sufficient to pay the principal of, redemption premium. if any, and interest on the Series 1999 Bonds as the same becomes due and payable. ....J 4 19-; C6 ~ . . Security for the Series 1999 Bonds The Series 1999 Bonds and the redemption premium, ifany. and interest payable thereon, are special and limited obligations payable solely from (i) payments to be made by the Company under the Agreement and the Series 1999 (^] Note hereinafter described and other income. revenues and proceeds derived by the Issuer (or the Trustee acting on behalf of the Issuer) pursuant to the Agreement or by reason of the disposition of the Mortgaged Property (defined below), (ii) certain other moneys pledged under the Indenture, including certain proceeds of the Series 1999 Bonds, moneys held in the Debt Service Reserve Fund, certain insurance proceeds and condemnation awards, and income from the investment of certain funds held in trust under the Indenture, and (Hi) net amounts derived by recourse to a Mortgage and Security Agreement, dated as of(^] Julv 1,1999 (the "Mortgage"), from the Company to the Issuer. Pursuant to the Agreement and as evidence of the borrowing thereunder, the Company will execute ~ promissory [^) note in the principal (^J amount equal to the aggregate principal amount of the Series 1999 Bonds (the "Series 1999 [^] Note"). The payment of the Series 1999 [^] Note and the perfonnance by the Company of its obligations under the Agreement will be secured by the Mortgage. Pursuant to the Mortgage, the Company win grant a mortgage lien upon and security interest in the Facility, including the land on which it is located (the "Mortgaged Propertytl), to the Issuer, subject to Permitted Encumbrances (as such tenn is defined in the Mortgage). \ 1 .......,? Pursuant(^) to the Agreement and the Mortgage. in order to secure the loan payments and other payments due thereunder and the perfonnance and observance of each covenant and agreement of the Company contained in the Agreement, the Series 1999 [^] Note and the Mortgage, the Company will grant a security interest in its Revenues (as defined in the Indenture and in APPENDIX D hereto) and certain of its other property to the Issuer, to the extent such security interest can be perfected under the Florida Uniform Commercial Code and. subject to the provisions of cenain accounts receivable financing loans. Pursuant to the Indenture, the Issuer wiH assign its rights (except cenain unassigned rights related to receipt of notices, granting of consents and rights of indemnification) in and to the Agreement, the Series 1999 (^]~, the Mortgage and the payments to be made thereunder to the Trustee as security for the Series 1999 Bonds. ~ rL . At the time of the issuance of the Series 1999 Bonds, the Debt Service Reserve Fund will be funded with proceeds of the Series 1999 Bonds in an amount equal to the Debt Service Reserve Requirement. In addition, the Agreement requires the Compa.ny to fix, charge and collect, or cause to be fixed. charged and collected, fees. rentals, rates and charges for the use of the Mortgaged Property and services provided or to be provided in connection therewith, that shaH be at least sufficient to produce in each fuU Fiscal Year following completion of the Project a Debt Service Coverage Ratio for such Fiscal Year that is not less than 1.20. See "SECURITY FOR THE SERIES 1999 BONDSIt and APPENDIX D herein. THE SERIES 1999 BONDS ARE LIMITED OBLIGATIONS AND WILL NOT CONSTITUTE A DEBT, LIABILITY OR OBLlGATION OF THE ISSUER, THE STATE OF , '-.) 5 1?;-/~ " .~ FLORID~ OR ANY POLITICAL SUBDIVISION OR AGENCY THEREOF. NEITHER THE FAITH AND CREDIT NOR THE TAXING POWER OF THE ISSUER. THE STATE OF FLORIDA, OR ANY POLITICAL SUBDIVISION OR AGENCY THEREOF Wll..L BE PLEDGED TO THE PAYMENT OF THE PRINCIPAL OFt REDEMPTION PREMIUM. IF ANY. OR INTEREST ON THE SERIES 1999 BONDS, AND THE SERIES 1999 BONDS WrLL NOT DlRECTL Y, INDIRECTLY OR CONTINGENTL Y OBLIGATE THE ISSUER, THE STATE OF FLORIDA, OR ANY POLITICAL SUBDIVISION OR AGENCY THEREOF TO LEVY ANY T AXES WHATEVER TIlEREFOR OR MAKE ANY APPROPRIATION FOR TIlElR PAYMENT. Historical and Selected Financial Information Historical and selected financial infonnation regarding the Company and the Facility is included in APPENDIX C to tlUs Official Statement. Audited financial statements of the Company for the fiscal years ended December 31, 1998 and 1997 are included in APPENDIX C - Part (i) herein, and unaudited financial statements of the Company for the three-month periods ending March 31, 1999 and ] 998 in APPENDIX C - Part (ii) herein. Historical Statement of Activities and Historical Pro Forma Debt Service Coverage and Cash Investments and Related Ratios [TO COME (^)) Financial Feasibility Study ....._E. Feasibility Study. See APPENDIX B herein for a financial Feasibility Study dated , 1999t prepared by BDO Seidman, LLP, independent certified public accountants (the IIFinancial Feasibility Studyll). The Financial Feasibility Study includes management's financial forecast of the Company for the four (4) years ending December 31, 2002. As stated in the Financial Feasibility Study, there will be differences between the forecasted data and actual results because events and circumstances frequently do not occur as expected, and those differences may be material. The achievement of any financial forecast is dependent upon future events, many of which are beyond the Company's control and the occurrence ofwhicb cannot be assured. See "BONDHOLDERS' RISKS" herein. The Financial Feasibility Study should be read in its entirety, including all notes and assumptions set forth therein. Forecasted Financial Information for the Company. The table set forth below reflects the forecasted debt service coverage ratio calculations for the Company and has been extracted from management's fiJlancial forecast included in the Financial Feasibility Study. See APPENDIX B - "Financial Feasibility Study It attached hereto. Forecasted Schedule of Coverage Ratios (TO COME FROM FINAL DRAFT OF FINANCIAL FEASffiILITY STUDY] ~Jl :! r ".J 6 99" / ~ ....,,- ": -......: . ......... _B. ~ ') The Series (^] 1999B EXTRASSM ) ......-", The Series r"J ] 999B EXTRASSM will bear interest at the rate of _% per annum to November 1St 20_t the initial Optional Tender Date. From and after the initial Optional Tender Date and to, but not including. each subsequent Optional Tender Date for the Series (^) ]999B EXTRASSM, the Series (^] 1999B EXTRASSM wilJ bear interest at a rate and for a period (a "Rate Period'.) determined in accordance with the Indenture. The applicable interest rate on the Series ("] ] 999B EXTRASSM (the 'lReset Rate") will be established for each Rate Period by the Remarketing Agent in accordance with the Indenture and the Remarketing Agreement. Pursuant to the Remarketing Agreement, the Company has named B. C. Ziegler and Company, as Remarketing Agent. The Company has the right to terminate Ziegler Securities as Remarketing Agent on 30 days' written notice, which tennination will not be effective until a successor Remarketing Agent has accepted the appointment as such. On each Optional Tender Date, any registered holder ofthe Series (^] 1999B EXTRASSM then outstanding will have the right to tender such Series [^] 19998 EXTRASSM to the Trustee for purchase at a price equal to the principal amount thereof. THERE CAN BE NO ASSURANCE THAT SUFFICIENT FUNDS WILL BE A V AILABLE TO PURCHASE ANY OR ALL SERIES (^) 1999~ EXTRASSM TENDERED FOR PURCHASE ON ANY OPTIONAL TENDER DATE. In the event sufficient funds are not available to purchase any or all Series (^) 1999B EXTRASSM tendered for purchase on any Optional Tender Datet the registered holders ofthe tendered but unpurchased Series ["] 1999B EXTRASSM will be required to retain their Series (^]1999B EXTRAssM at the new interest rate determined by the Remarketing Agent. See "BONDHOLDERS. RISKS - Purchase of Series (^] ]999B EXTRAssMu and 'ITHE SERIES [^J 19998 EXTRASSM - General Description." The maximum rate payable on the Series (^] 19998 EXTRAssM is 15% per annum. Bondholders' Risks AN INVESTMENT IN THE SERlES ] 999 BONDS INVOL YES RISK. A BONDHOLDER IS ADVISED TO READ "BONDHOLDERS' RISKS" HEREIN FOR A DISCUSSION OF CERTAIN RISK FACTORS WHICH WOULD BE CONSIDERED IN CONNECTION WITH AN INVESTrvlliNT IN THE SERIES J 999 BONDS. Careful consideration should be given to these risks and other risks described elsewhere in this Official Statement. Among other things, since the Series 1999 Bonds are payable solely from the revenues ofo the Company and other moneys pledged to such payment, careful evaluation should be made of certain factors that may adversely affect the ability of the Company to generate sufficient revenues to pay expenses of operation, and the principal of. premium, if any. and interest on the Series 1999 Bonds. Definitions and Summaries of Legal Documents This Official Statement contains descriptions of (among other matters) the Project, the Facility. the Series 1999 Bonds, the Indenture. the Agreement, the Mortgage and the Company. Such descriptions and infonnation do not purport to be comprehensive or definitive. All references herein ....) 7 11~/Y ~ to the Indenture. the Mortgage and the Agreement are qualified in their entirety by reference to the complete text of such documents and all references herein to the Series 1999 Bonds aTe qualified in their entirety by the forms thereof included in the Indenture. Summaries of the Indenture, the Agreement and the Mortgage referred to in this paragraph are attached hereto as APPENDIX D. Complete copies of such documents are available from the Trustee. BONDHOLDERS' RISKS General . The paragraphs set forth below discuss certain risks associated with investment in the Series 1999 Bonds. but are not intended to be a complete enumeration of all risks associated with the Project or the purchase of any of the Series 1999 Bonds. Other investment risks arc discussed in other sections of this Official Statement. Except as otherwise noted herein. the Series 1999 Bonds win be payable solely from the payments to be made by the Company under the Agreement and the Series 1999 (^] ~ and from certain other available moneys pledged therefor under the Agreement, the Indenture and the Mortgage. No entity or person other than the Company is. or shall be, in any way liable or responsible for any payments to be made under the Agreement. Except for certain restricted assets. the eompany will have no significant assets other than the Mortgaged Property and win have no significant sources ofincome other than the Monthly Rental Fees, per diem charges from use of the health care services and other moneys received from the operation of the Facility. Accordingly, registered owners of the Series 1999 Bonds must look solely to the Sp.curity provided under the Indenture, the Agreement and the Mortgage for payment of the principal. redemption premium, if any, and interest due on the Series 1999 Bonds. General Uncertainty of Revenues Certain risks are inherent in the successful operation of facilities such as the Facility. The ability of the Company to generate sufficient revenues from the operation of the FaciHty to pay the required amounts under the Agreement and the Series 1999 [^) Note will be dependent on the achievement and maintenance of high future residency levels and turnover thercofat the Facility by eligible residents who will be able to pay the Monthly Rental Fees which are expected to increase on a regular basis in subsequent years. the maintenance of occupancy in the Facility and receipt of adequate per diem charges from the use thereof and the hiring and retention of competent administrative and operating persoMel to conduct the day to day operations of the Facility. No representation or assurance can be made that revenues win be realized by the Company in amounts sufficient to make the required payments with respect to debt service on the Series 1999 Bonds. The realization of future revenues and control of expenses is dependent upon, among other things. successful marketing by the Company's personnel, future state and federal funding of certain health \...J 8 CfI ~ let ~."'tY."." ') care programs. and future economic and other conditions that are unpredictable. Any ofthese factors may affect revenues and payment of debt service on the Series 1999 Bonds. Failure to Achieve or to Maintain Occupancy The successful operation of the Facility depends in large part upon the ability ofthe Company to attract sufficient numbers of residents to the Facility and to maintain substantial occupancy at the Facility throughout the tenn ofthe Series 1999 Bonds. The Company's ability to maintain high levels of occupancy depends to some extent on factors outside their control, such as the residents' right to tenninate their Residency Agreements and to receive a refund as provided in the Residency Agreements. If the Facility fails to achieve and maintain a high level of occupancy. there may be insufficient funds to pay debt service on the Series 1999 Bonds. Moreover. if a substantial number of residents live beyond their anticipated life expectancies or if their admissions or transfers to the assisted living area or the skilled care nursing area are substantially less than anticipated by the Company, or ifmarket changes prevent an increase in the amount ofthe Monthly Rental Fees payable by new residents of the Facility, the receipt of additional Monthly Rental Fees could be curtailed or limited, with a consequent impairment of the Company's revenues, Such impairment would also result if the Company is unable to remarket units becoming available when residents die, withdraw. or are transferred to another facility. No Assurance Forecasted Results Will Be Obtained " 1 " -'. The financial forecast contained in the Financial Feasibility Study included in APPENDIX B hereto is based upon assumptions made by the management (I1Management") of the Company. As stated in such financial forecast, there will be differences between the forecasted data and actual results because events and circumstances frequently do not occur as expected, and those differences may be material. In addition, the financial forecast is only for the four years ending December 31. 2002 and consequently does not cover the entire period during which the Series 1999 Bonds may be outstanding.(^] Because there is no assurance that actual events will correspond to the assumptions of Management, 1:10 guarantee can be made that the financial forecast contained in the Financial feasibility Study will correspond with the results actually achieved in the future. Actual operating results may be affected by many uncontrollable factors, including but not limited to increased costs, lower than anticipated revenues, employee relations, taxes, governmental controls, changes in applicable governmental regulations, changes in demographic trends, changes in the retirement living and health care industries, failure by Management to execute its plans as reflected in the Financial Feasibility Study and general economic conditions. See the risk factors described in this section and the Financial Feasibility Study attached hereto as APPENDIX Bt all of which should be read in their entirety. Malpractice Claims and Losses The operations ofthe Company, and thereby of the Facility. may also be affected by increases in the incidence of malpractice lawsuits against physicians and facilities such as the Facility. in general, co" ) ".....,.,. 9 99~/'6 ) and increases in the dollar amount of patient damages and recoveries, resulting in increased insurance premiums and an increased difficulty in obtaining malpractice insurance. The Company covenants to maintain malpractice insurance with private insurance carriers. It is not possible at this time to detennine either the extent to which such malpractice coverage will continue to be availabJe to the Company, and thereby to the Facility. or the premiums at which such coverage can be obtained. Regulation Recent Legislation. On March 25, 1999. President Clinton signed into law the Nursing Home Resident Protection Amendments of 1999 (the It 1999 Nursing Home Act"). Generally) a nursing facility that participates in the Medicaid program may only transfer or discharge a resident under the following circumstances: the transfer or discharge is necessary for the resident's welfare; the resident's health has improved enough to leave the faci1ity~ the safety or health of others in the nursing facility is endangered~ for non-payment of services; or if the nursing facility ceases to operate. Prior law did not extend any transfer or discharge protections to Medicaid residents if the nursing facility withdrew from the Medicaid program. The 1999 Nursing Home Act sets forth the rights of residents in a nursing facility in a case where the facility voluntarily withdraws from participation in the medicaid program, but continues to provide nursing care services. The nursing facility may not transfer or discharge any resident. whether or not Medicaid recipients. solely because of its withdrawal from the Medicaid program. All medicaid participation agreement requirements continue to apply to all individuals who were residents of the nursing facility on the day before the day the facility withdrew from the Medicaid program, until such individuals no longer require care. ,....) Proposed Legislation. During 1998, the Clinton Administration announced a number of administrative and legislative steps designed to increase the oversight of the nation's nursing homes. Many of the steps were aimed directly at the survey enforcement process and nursing homes that fail to provide quality care to their residents. These actions included: ensuring swift and strong penalties for nursing homes failing to comply with standards; strengthening the oversight of state enforcement mechanisms~ developing a registry to track and identifY individuals with a history of abusing residents; and the implementing of efforts to improve nutrition and prevention of bed sores. While most of these legislative initiatives failed in Congress in 1998. the Clinton Administration has advanced a number of Executive-branch administrative actions including assessing immediate civil monetary penalties; tougher nursing home inspections~ stronger federal oversight of state enforcement mechanisms; publishing regulatory survey results on the Internet and the implementation of new efforts to measure and m~nitor nursing home quality. A number of other bills proposing to regulate or control, in some manner. health care costs and revenues and a number of proposals for a national health insurance program have been submitted to Congress. There are wide variations among these proposals and the effect on the health care industry and the Company cannot be determined. There can be no assurance that the implementation of any such bill or proposal or any future bill or proposal) or the implementation by the federal or state administrative bodies of nursing care cost containment or revenue control programs. would not o 10 19 - I~ ---I adversery affect the revenues of the Facility, and thus the revenues ofthe Company. See "PavorlMix ~ ;' Nursim~ Center" in APPENDIX A for information reRarding the Company's current oavor mix [^] While management of the Company believes that any changes to the Medicare and Medicaid programs will not have a significant adverse effect upon the Facility combined resident service revenue and net patient service revenue, circumstances could change in the future and changes in the Medicare and Medicaid programs could have an adverse impact upon the combined resident service revenue and net patient service revenue in the future. Medicare. The federal Balanced Budget Act of 1997 (the UBudget Act"). enacted in August 1997, contains extensive changes to the Medicare and Medicaid programs intended to reduce payments under those programs by over $100 billion over a five-year period. Virtually all spending reductions will come from providers and changes in program components. The Budget Act affects reimbursement systems relating to the Company. The Budget Act changed Medicare cost reimbursement from a retrospective system to a prospective payment system ("PPS"). There is a four-year phase-in period for implementing the new system. During the first year (federal fiscal year 1998), a facility's reimbursement rate comprised 75% of such facility.s specific 1995 Medicare costs (the ufacility specific 1995 rate") and 25% of the national Medicare per-diem costs, adjusted for acuity. During the second year of the phase-in (federal fiscal year 1999), the rate will comprise 50% of the facility specific 1995 rate and 50% of the national average. During the third year, the rate will consist of25% of the facility specific 1995 rate and 75% of the national average. In year four and thereafter, 100% of the rate will be based on the national average. These amounts willce inflated forward at a nursing home inflation rate (health care market basket rate. less 1 %). ~. ) , -_? The Federal Health Care Financing Administration C'HCF A") will collect data from skilled nursing facilities ("SNFs") on each patient and assign the patient to a case-mix category based on an algorithm employing the data. The system calls for assessing patients on days 5, 14, 30. 60 and 90 of their staysl using a multi-disciplinary form. The data collection tool is called the minimum data set, or MDS 2.0 rMDS"). The patient classification methodology is called Resource Utilization Group Version III and the patient classifications and categories are referred to as RUG-III or simply RUGs. Case-mix reimbursement systems systematically link the amount paid to the types of patients treated: the more extensive the services and the greater the need, the higher the case-mix index incorporated in the payment rate. The RUG-III system divides nursing home residents into 44 groups using two major classification structures: A clinical (medical and mental) topology and a measure of functionality represented by the Activities of Daily Living. The case-mix index will be used to adjust patient care costs. PPS is not a single rate that SNFs receive for the length ofa patient's stay. Periodically, SNFs must resubmit the MDS data set to re-qualifY the patient for a given level of reimbursement. Thus. as a patient's condition improves during a SNF stay. the SNFs PPS reimbursement drops. PPS is a rolling prospective system with data submitted at the milestones affecting going-forward reimbursement. By linking case-mix measures, which identify and categorize nursing home patients 'oJ 11 99-lt ') by assessed need, to facility reimbursement, the Medicare payment system is expected to become more responsive to both facility costs and patient care needs. Florida Medicaid Program. The State of Florida Agency for Health Care Administration ("AHCA"). which administers the State ofFlorida Medicaid program, reimburses operators of nursing facilities on a per diem rate set by the Medicaid eost Reimbursement Office. The policies and procedures for reimbursement under the Florida Medicaid program are set forth in Florida Title XIX Long-Term Reimbursement Plan Version XIV (effective November 6, 1997) (the "Plan"). The per diem rate is detennined based on the sizet locationt an allowable costs of the nursing facility. The federal government requires the state Medicaid rates be reasonable and adequate to meet costs incurred by efficiently and economically operated nursing facilities to provide service in confomUty with state and federal laws. regulations, and quality and safety standards. i Under the current Medicaid reimbursement plan, rates in Florida are prospectivet facility specific. cost-based subject to ceilings and set for six-month periods beginning in January and July of each year (the rate semesters). There are six peer groups (based on location and size) that are used to detennine the ceilings for reimbursement rates. There are three geographical regions: The northern counties. the central counties and the southern counties. Size categories include smaIl nursing homes (100 or fewer beds) and large nursing homes (greater than 100 beds). The reimbursement rate has three components: patient care, operating costs and property costs. An additional reimbursement is available in the form ofan incentive. called a Medicaid Adjustment Rate. which can equal 4- ] /2% of the patient care component. Patient care costs include those costs directly attributable to nursing services, dietary costs. activity costs. social services costs and all medically ordered therapies. All other costs, exclusive of property costs, are considered operating costs. Each provider panicipating in the Florida Medicaid Nursing Home Program is required to submit a uniform cost report and related documents no later than three calendar months after the close afits cost reponing year The cost report is used to determine the nursing home's allowable Medicaid costs. The Medicaid program pays a single level of payment rate for all levels of nursing care. The single per diem rate is based upon each provider's allowable Medicaid costs divided by the Medicaid patient days from the most recent cost report - subject to the rate setting methodology in the Plan. Reimbursement of patient care and operating costs are limited to class ceilings set forth in the Plan, while property costs are paid under the Fair Rental Value System ("FRVS"). FRVS is based on the indexed allowable asset cost and the provider specific interest rate plus actual costs of insurance and real estate taxes. A new provider is required to submit a budgeted cost report with Medicaid officer in order to establish an interim rate for reimbursement during the initiaf period foHowing a change of ownership (the 1I1nitial Periodl1). At the election of the new provider. the term of the Initial Period can range from six months to eighteen months. At the conclusion of the Initial Period. an initial cost report is filed by the new provider and a settlement will be made for the difference between actual costs and the initial interim rate. After the Initial Period, Medicaid rates are set prospectively, based on actual costs incurred in the prior period. adjusted for inflation. \...) 12 Cjq". I ~ -\ Related Regulation. There also is an expanding and increasingly complex body of law. regulation and policy (both federal and state) relating to the Medicare and Medicaid programs. which is not directly related to payments under such programs. This includes reporting and other technical rules as well as broadly stated prohibitions regarding improper inducements for referrals and payment of kickbacks in connection with the purchase of goods and services. Violations of prohibitions against improper inducements and payments may result in civil and criminal sanctions and penalties. Civil penalties range from monetary fines which may be levied on a per-violation basis to exclusion from the Medicaid and Medicare programs. In addition, Congress. in an act commonly known as Stark II. has restricted the ability of SNFs and other entities to bill Medicare for designated health services ordered by physicians with whom the SNFs have a financial relationship. While SNF care is not itself a designated health service, many ancillary services required by SNF patients are. There are many types offinnncial relationships which are exempt from Stark II; however, failure to comply strictly with the terms of these exemptions will make the SNF ineligible to receive Medicare payment for designated health services ordered by the physician. To the extent residents may utilize the Medicaid or Medicare programs for reimbursement of payments made to the Company. changes to the Medicaid and Medicare programs may indirectly affect the Company's revenues by affecting the ability of current residents to make payments to the Company and the ability of the Company to market the Facility to prospective residents. ., d , ..........,~,.; Florida Licensure and Certificate of Need Nursing Home Facilities. Florida nursing home facilities are regulated and inspected by AHCA. All nursing home facility licensees are subject to various requirements, including requirements regarding a safe and sanitary physical plant, minimum dietary standards, record maintenance and residency contracts. AReA may take action against a nursing home facility licensee for a number of reasons such as: (a) intentional or negligent act materially affecting a facility patient's health or safety; (b) misappropriation or conversion of patient property; or (c) violation of any application statute or regulation with respect to nursing home facilities. In addition, AHCA, as an alternative to or in conjunction with an injunctive proceeding against a nursing home facility licensee. may petition a court of competent jurisdiction for the appointment ofa receiver it: among other things: (a) AHCA determines that there exist in the facility conditions which present an imminent danger to facility patients' health. safety or welfare or a substantial probability that death or serious physical harm would result; or (b) the facility cannot meet its financial obligations to provide food. shelter, care and utilities. Assisted Living Facilities. Assisted living facilities are licensed facilities which undertake through their ownership or management to provide, for a period exceeding 24 hours. housing, food service. and one or more personal services for four or more adults, not related to the owner or the ...._-,) 13 19- /r .~'...I,,,,,"1,.l . .', ' . ~- .~ administrator by blood or marriage, who require such services. In addition, assisted Jiving facilities may provide extended congregate care, limited nursing services or limited mental health services when specifically licensed to do so. Assisted living facilities are subject to various licensure requirements, including requirements regarding maintenance of facilaies, preparation and annual updating of a comprehensive emergency maintenance plan, number and qualification of personnel, sanitary conditions and care and maintenance of patients. AHCA may revoke or suspend an assisted living facility license for a number of reasons, including (a) an intentional or negligent act seriously affecting a facility residenCs health, safety or welfare~ (b) misappropriation or conversion of resident property; (c) a determination by AHCA that the facility owner lacks the financial ability to provide continuing adequate care to residents; or (d) a licensee's failure during relicensure to meet minimum licensing standards or applicable rules. Also. AHCA may seek the appointment of a receiver in the same circumstances as indicated above with respect to nursing home facilities. Certificate of Need. The Health Facilities and Health Services Planning Act of the State of Florida provides for a certificate of need ("CONU) program which applies to the offering or development of new institutional health services, including skilled nursing facilities. The CON program. administered by ARCA, requires AReA's review and approval of proposed capital ex.penditures in: excess of threshold amounts, of the initiation ofsubstantiaJ changes in services or any change in licensed bed capacity, including skilled nursing facility beds. -"\ I In Florida. nursing home beds are divided into two categories: sheltered beds and community beds. Sheltered nursing home beds are located within a continuing care facility and usually are utilized only by residents who live within the continuing care facility, as certified under Chapter 651, Florida Statutes. Community nursing home beds are usually located outside of a continuing care facility. For health planning purposes. sheltered beds are not considered when calculating bed inventories of a district and are not considered when reviewing CONs for new or additional community nursing home beds. .......,. The current Florida nursing home bed need methodology is based on utilization patterns at the local level. Bed need allocations are made on a subdistrict basis and are derived by established utilization statistics. Proposed increases in nursing home beds are reviewed relative to the area's population growth and the rate of occupancy experienced by existing nursing homes. Relaxation in the standards or elimination of the CON program could be implemented in the future, which could result in increased competition for the Company's Facility. Management ofthe Facility believes that the Facility is, and will continue to be, in compliance with Florida licensure and CON requirements. Any failure to maintain compliance with Florida licensure and CON requirements could have a material adverse effect on the operations of the Facility. ., -../ 14 crCf~/g; ,..-., The Company ;s licensed by the State of Florida to operate the Cove Nursing Center and the Bluffs Nursing Cel'l.ter. The Company has received approval to transfer the beds from the Bluffs Nursing Center to the Cove Nursing Center and to operate under a single license. The licenses consist of both the Oaks Nursing Center license and the Assisted Living Facility license. The independent living units are exempt from State licensure. (^ J Possible Changes in Tal. Status The possible modification or repeal of certain existing federal income or state tax laws or other loss by the Company ofthe present advantages of certain provisions of the federal income tax or state tax laws could materially and adversely affect the status of the Company. and thereby the revenues of the Facility. See ItEXEMPTIONn herein. The eompany has obtained a letter from the Internal Revenue Service detennining that it is an exempt organization as defined under Section SOI(c)(3) of the Code. As an exempt organization, the Company is subject to a number of requirements affecting its operation. The failure of the Company to remain qualified as an exempt organization would affect the funds available to the Company for payments under the Agreement. The tax-exempt status of the Series 1999A Bonds also is based on the continued compliance by the Company with certain covenants contained in the Indenture and the Agreement. These covenants relate generally to ownership. use and operation of the Facilityt arbitrage limitations. rebate of certain excess investment earnings to the federal govemrnentt and restrictions on the amount of issuance costs financed with the proceeds of the Series 1999 Bonds. Failure to comply with any of these covenants may result in the treatment of interest on the Series 1999 Bonds as taxable retroactive to the date of issuance. '. , ) ....... ~L'~ Limited Use of Facility The Facility is or will be constructed and equipped to provide residential retirement, assisted care and healthcare services. As a result. in the event of default, the Issuer's and the Trustee's remedies and the number of entities which would be interested in purchasing or leasing the Facility might be limitedt and the sales price or rentals generated by the Facility might thus be adversely affected. Possible Effect of Adverse Conditions in Housing Market It is anticipated that a substantial number of prospective residents of the Facility will be required to sell their current homes to pay the Monthly Rental Fees or to meet other financiaJ obligations relating to the Facility. If prospective residents encounter difficulties in selling their current homes dueto local or national economic conditions affecting the sale of residential real estatet such prospective residents may not have sufficient funds to pay the fees and rents or to meet other obligations relating to the Facility, thereby causing a delay in scheduled occupancy of the Facility or remarketing of vacated units. which would have an adverse impact on the revenues ofthe Company. \ '... ...../ 15 c;q-/r Construction Risks ~ The ability ofthe Company to make payments of the principal of. redemption premium, if any. and interest on the Series 1999 Bonds. when due, is in part dependent upon completion of the construction ofthe Project within available resources and without delays due to strikes, shortages of materials, adverse weather conditions as well as other factors. The Company wiJl attempt to protect itself against a portio'n of those risks by requiring the contractors for the Project to furnish performance and material payment bonds prior to commencement of construction work on certain portions of the Project. However. attempts to seek recourse against contractors or their sureties for cost overruns may involve costly and time-consuming litigation. Further. the timely completion of construction is dependent upon promptly obtaining approvals and permits from various regulatory and governmental agencies. There can be no assurance that such approvals and permits will be promptly obtained. It is anticipated that the proceeds from the sale of the Series 1999 Bonds will be sufficient to complete the acquisition and construction of the Project; however, cost overruns are not uncommon. If the Project cannot be completed for its anticipated costs, the Company is obligated to complete the same at its own expense, with available moneys, through the issuance of additional bonds. parity or otherwise. or with financing obtained from other sources. The Company's financial resources are limited. Accordingly, there can be no guarantee, if costs overruns are experienced. that the Project will be completed. although the Company does not at this time have any reason to believe that substantial cost overruns will be incurred. _ /' A substantial portion of the Project involves the renovation of the Facility. Obtaining accurate estimates of the renovation costs of buildings can be difficult, and often, the extent of the renovations required to meet current codes is not known until that phase of the Project has begun. Therefore, some costs may exceed, and some may be below, the original estimates. Additionally, the Company may reduce in scope, or eliminate. cenain phases of the Project and take on other renovation activities not envisioned at the outset. Enforceability of Remedies In the event of a Default by the Company under the Agreement) the Trustee may not be able to compel Medicare, Medicaid. Blue Cross. Blue Shield. or other third parties to make payments directly to the Trustee. Under CUlTent law, such pledge may be further limited by the following: (i) statutory liens~ (ii) rights arising in favor of the United States of America or any agency thereat (iii) present or future prohibitions against assignment contained in any state or federal statutes or regulations~ (iv) constructive trusts, equitable liens, or other rights impressed or conferred by any state or federal court in the exercise of its equitable jurisdiction~ (v) federal bankruptcy laws affecting assignments of revenues earned after any institution of bankruptcy proceedings by or against the Issuer; and (vi) the requirement that appropriate continuation statements be filed pursuant to the UCC as from time to time in effect. ,-.-J 16 99-/~ Uncertainty of Investment Income ~ I The investment earnings of, and accumulations in. certain funds established pursuant to the Indenture have been estimated and are based on assumed earnings rates. White these assumptions are believed to be reasonable in view of the rates ofretum presently and previously available on the types of securities in which the Trustee is pennitted to invest under the Indenture. there can be no assurance that similar interest rates will be available on such securities in the future. nor can there be any assurance that the estimated funds will actually be realized. Bankruptcy The ability of the Issuer and the Trustee to exercise certain rights and remedies under the Agreement. the Indenture and the Mortgage may be limited by bankruptcy. insolvency, reorganization. or other' similar laws or equitable principles relating to or affecting the enforcement of creditors. rights generally. Rigbts of Residents Although the Residence Agreement gives to each Resident a contractual right to use space and not any ownership rights in the Company's propertyt in the event that the Trustee or the registered holders of the Series 1999 Bonds seek to enforce any of the remedies provided by the Indenture, the Agreement or the Mortgage upon the occurrence ofa default under any or all of such documents, it is impossible to predict the resolution that a court might make of competing claims between the Trustee or the registered holders of the Series 1999 Bonds and a Resident of the Facility who has fully complied with all the tenns and conditions of the Residence Agreement. Competition The Company currently faces competition from other providers of existing retirement living facilitiest nursing facilities, and comparable facilities servicing the housing and health care needs of the elderly in its primary market area. The Company may face additional competition in the future from other providers of new, expanded, or renovated retirement living and nursing facilities servicing the housing and health care needs of the elderly. See APPENDIX A - THE COi\4PANY AND THE OAKS - Organization and Operations - Competition. Investment Risks; Lack of Rating! No application has been made for a credit rating for the Series 1999 Bonds. The absence of such a rating could adversely affect the marketability of the Series .1999 Bonds. Although the Underwriter expects to engage in the purchase and sale of the Series 1999 Bonds in the secondary mark~ there can be no assurance that there will always be a secondary market for purchase or sale of the Series 1999 Bonds. and from time to time there may be no market for them depending upon prevailing market conditions, the financial condition or market position of finns who may make the "-.) 17 91,/rr .....~~..::'".':"'~~::~.::. .~_~~______._ u._ c"'T ...... ......., \ secondary market, and the financial condition and results of operations of the Company and the Facility. The Series 1999 Bonds should therefore be considered long-term investments in which funds are committed to'maturity. Purchase or Series (^] 1999B EXTRASSM '-....'/ The registered holders of Series [^) 1999B EXTRAssM have the option to tender their Series (^) 1999B EXTRASSM to the Trustee for purchase on each Optional Tender Date. The only sources of moneys available to make payments ofthe purchase price of the Series [^)1999B EXTRASSM on each Optional Tender Date are (i) the proceeds of the remarketing thereof, (ii) moneys required to be deposited in the Extendables Purchase Fund by the Company pursuant to the Agreement in an amount not greater than the amount of cash held by the Company on such Optional Tender Date in excess of (^)_ Days Cash on Hand. and (Hi) any additional amounts deposited into the Extendables Purchase Fund by the Company, at its sole option, from any available moneys of the Company. Therefore. ifany of the Series [^] 1999B EXTRAssM tendered on any Optional Tender Date are not remarketed at par, the Tender Agent may not have available funds with which to purchase such Series [^J ] 999B EXTRASSM. In the event sufficient funds are not available. the registered holders of the tendered but unpurchased Series [^) 1999B EXTRAssM will be required to retain their Series [^) 19998 EXTRASSM at the new interest rate detennined by the Remarketing Agent. THERE CAN BE NO ASSURANCE THAT SUFFICIENT FUNDS WILL BE A V AILABLE TO PURCHASE ANY OR ALL SERIES (^] 1999B EXTRAssM TENDERED FOR PURCHASE ON ANY OPTIONAL TENDER DATE. Failure to purchase Series (^) 19998 EXTRAssM tendered for purchase on any Optional Tender Date does not constitute an event of default under the Indenture or the Agreement. See liTHE SERIES I ^) ] 999B EXTRAssM - General Description - Purchase on Optional Tender Datesll herein. In addition. the~e can be no assurance that any interest rate reset with respect to the Series I ^ ) 1999B EXTRAssM will not cause a material burden on the financial condition ofthe Company. Amendments to Documents Certain amendments to the Indenture and the Agreement may be made without the consent of the registered holders of the Series 1999 Bonds and other amendments may be made with the consent of the registered holders of not less than 51% in aggregate principal amount of all outstanding Bonds including the Series 1999 Bonds and any Additional Bonds issued hereafter. Such amendments could affect the security for the Series 1999 Bonds. Year 2000 Compliance Date sensitive computer applications that currently record years in two-digit. rather than four-digit, format may be unable to properly categorize and process dates occurring after December 31. 1999 (the IIYear 2000" problem). If Year 2000 related failures were to occur in the Company's computer and infonnation systems. the Company could incur significant, unanticipated liabilities and expenses which could adversely affect its creditworthiness. and could adversely affect J 18 19-1r ~ , the timely payment of its indebtedness. including the payment of debt service on the Series 1999 Bonds. In addition, the Company may be adversely affected by the extent to which other companies and governmental bodies with whom the Company does business are Year 2000 compliant. For example, the Company's ability to be reimbursed by Medicaid or Medicare for skJUed nursing facj]jty services may be affected by the extent to which the federal government is Year 2000 compliant. The failure of any such company or governmental body to be Year 2000 compliant could have a'material adverse effect on the Company. The Comoany ~cted an internal assessment Q.f the Dotentia1 . imoact of the Year 2000 orobtem on its internal ooerations and svstems between Janua{}' and Mav. 1999. For a discussion of the Company's assessment and approach to Year 2000 compliance, see ==== , APPENDIX A - (^]"ORGANIZATION AND OPERATIONS - Year 2000 Issues,~ Transfer of Residents from the Bluffs Buildine: to the Cove HuUdinl! Upon Completion of Renovations . =~ ) The olan offinance anticipates that the Company will gain title to both the Bluffs bui1din~ and the Cove BuildinR. During the period of renovation of the Cove Building. the current residents of Jhe Cove Nursing Center win be transferred to the Bluffs Nursing Center. Uoon comoletion of the renovation ofthe Cove Bui1din~. residents of the Independent UvinR and Assisted LivinR units of the Bluffs BuildinR will have the oooortunity to move to the newlv renovated Cove BuildinR. ManaRement has estimated the number ofoersons who may take advantage of such an oooortunity and has reflected that assumotion in the financial forecast. Should the number of oeeole who ultimately decide to move from the Bluffs BuildinR to the Cove BuildinlZ. uoon the comoletion of renovations at the Cove BuildinlZ. be less than has been assumed bv Mana2ement then this could materiallv imoact the revenues available for debt service. Other Risk Factors The occurrence ofany of the following events, or other unanticipated events, could adversely affect the operations of the Company: (1) establishment of mandatory governmental wage. rent, or price controls; (2) inability of the Company to control increases in operating costs, including salaries, wages and fringe benefits, supplies, and other expenses, without being able to obtain corresponding increases in revenues from residents of the Facility whose incomes will largely be fixed; (3) unionization. employee strikes. and other adverse labor actions which could result in a substantial increase in expenditures without a corresponding increase in revenues; (4) the occurrence of any natural disasters or other disruptions that impair the operations of the Facility; .J 19 91 - I~ i~ I . . ~ i (5) adoption of federal. state or local legislation or regulations having an adverse effect on the future operating or financial performance of the Company; (6) a decline in the population, a change in the age composition of the population or a decline in the economic conditions of the Company's market area other than those assumed by the Company; and (7) the ability of, and cost to, the Company to continue to insure or otherwise protect itself against malpractice claims. FLORIDA REGULA nON OF CONTINUING CARE FACILITIES Continuing care facilities in Florida are regulated by the Department ofInsurance ofthe State of Florida (the "DOr') under the provisions of Chapter 651. Florida Statutes, as amended ("Chapter 65 I"). The Facility is exempt from regulation under Chapter 6S 1 pursuant to certain agreements between the DOl and the Company. /-) \','>)1" The Company voluntarily surrendered its continuing care retirement community ("CCRCtI) certificate of authority for (Oak Bluffs] and (Oak Cove] pursuant to a consent order dated April 22. 1996 between the DOl and the Company. The consent order required the Company to give all CeRe Residents notice ofcanceUation of their continuing care contracts by April 29, ] 996 with an effective cancellation date of May 31, 1996. unless such contracts were tenninated earlier by the parties. As part of the plan of cancellation, the Company was required to offer the following options to each CeRC Resident regarding living choices: to remain at the Facility as a non-CCRC Resident: or to relocate to another residence of their choosinR. or another CeRe. [^] In addition, the Company was required to refund $5,000 from its minimum liquid reserve to each non-bond holding or non-Medicaid Resident opting to relocate. The Company was also required to immediately redeem any bond held by a CCRC Resident. The balance of the minimum liquid reserve held by the State of Florida was to be placed into a trust account pursuant to a trust agreement. In accordance with the consent order and trust agreement, the trust funds are to be disbursed by the trustee to the provider, whether it is the Company or a new provider. in equal monthly installments together with accrued interest over a tenn offive years beginning July IS, 1996. The balance of the funds in the trust account are to be turned over to the provider as of the date the last fonner CCRC Resident either moves out of the Facility or expires. On July ) 8, 1996. a notice of voluntary dismissal without prejudice was filed by the 001 pursuant to the Company's compliance with the consent order. According to the voluntary dismissal, on or about June 12. 1996. the Company surrendered the certificate ofo authority to the DOl pursuant to the terms of the consent order and the certificate of authority. the Company is no longer an entity regulated by the 001 as defined in Chapter 651. Florida Statutes, and the 001 has no further jurisdiction over the Company. ......) 20 9tj-ff ~ Approximately $361,542.40. representing the amount of the minimum liquid reserves held by the State of Florida, was released by the DOl Bureau of Collateral Securities on January 23, 1998 to Douglas A. Wright of Holland & Knight LLP as the designated trustee under the trust agreement. I. THE ISSUER The City ofClearwatert Florida is a municipal corporation. duly organized and existing under and pursuant to the Constitution and laws of the State of Florida. The Act authorizes the Issuer to promote the health and safety of the inhabitants of the Issuert the people ofPineJ1as County and the State of Florida by increasing their access to adequate medical care and health care facilitiest and to accomplish such financings through the issuance of revenue bonds. The Issuer is located in the middle of the west coast of Florida on the Gulf of Mexico and has a population of as of 1998. Its city limits comprise approximately 26.4 square miles of land and 8.5 square miles of waterways and lakes. The Issuer is governed by a City Commission and operates under a Commission-Manager form of government. The City Commission appoints a full-time City Manager and a filll.time City Attorney. A fuJ1.time Director of Finance has the responsibility for all financial operations of the City, and is appointed by the City manager. Also, an internal audit director is appointed by the City Manager and serves full time. The Issuer is primarily a resort and residential community. The Issuer has many recreational facilities including tennis. golf, boating, fishing, water sports, and recreational paths. During the winter months, the hotelst motels. and restaurants fill with visiting tourists and winter residents. The Issuer offers over 42 acres of public beach front. THE COMPANY AND THE FACILITY The Company was incorporated as a Florida not-for-profit corporation in 1975, as American Baptist Estates ofClearwatert Inc. The Company changed its name to HEFt Inc. in March of 1999. The Internal Revenue Service has determined that the Company is an organization described in Section 501(c)(3) of the Code, and is therefore exempt from federal income taxation under the provisions of Section 501 (a) of the Code. The Company received its Determination Letter from the Internal Revenue Service in MaYt 1976. The Company and the Oaks own and operate the Facility in the City of Clearwater, PineJ1as CountYt Florida. The Facility is currently comprised of two high-rise buildings and four low-rise buildings. These buildings contain the Nursing Centers. independent and assisted living facilities which are owned and operated by the Company. Jinsert mer~er descriPtionl ..~ 21 l1,./r ,.-'\ The Company provides three different levels of care to residents of the Facility: independent living, assisted living and nursing care. Residential areas within the Facility include 12 one.bedroom garden apartments located in the Villas. 8 two-bedroom garden apartments and 391 one.room and two.room high.rise apartments (of which 213 are currently unoccupied and located in the eove Building and the remainder are located in the Bluffs Building)~ [^] II assisted living units [^) located in [^] the Bluffs Buildim~; and the Nursing Centers, which are comprised of a 60.bed skilled nursing facility located in the Bluffs Building and a 56.bed skilled nursing facility located in the Cove Building. The Facility is located on approximately 7 acres of land in the City of Clearwater. Pinellas County, Florida, next to Tampa, Florida, and directly on the coastline on the Intercoastal Waterway, with views of the Gulf of Mexico, Clearwater and St. Petersburg, Florida Residence Agreements The Company requires each resident of the FaciJity (ItResidentlt) to execute a Residency Agreement. The Company currently utilizes a single form of Residency Agreement (the "Residency Agreement"), which agreement provides for selection of the level of care and type of accommodations to be provided at the Facility. ...... ... \ ...~,/ All Residency Agreements require Residents to pay monthly rental fees (the "Monthly Rental Feesll) which differ based on the housing type, as well as the last month Monthly Rental Fee in advar.ce, and a security deposit (the "Security DepositU) which is held against the cost of any damages to the unit. other than reasonable wear and tear, with the remainder of such Security Deposit to be refunded. without interest, to the Resident or Resident's estate 45 days after receiving notice that such Resident is not returning to their unit. Health assessments are performed with respect to all prospective Residents. With respect to potential independent living Residents, each applicant meets with the Facility's in-house nurse to determine whether such applicant is capable of functioning in the independent living section of the Facility. Additionally. all Residents must meet the Company's financial requirements, which require that each applicant have a monthly income that is at least thirty percent (30%) greater than the applicable Monthly Rental Fee, or have a family member or other individual wiJJing to cosign for the Monthly Rental Fee. which individual meets such financial requirements. The Monthly Rental Fees are reviewed annually by the Company and, if deemed necessary, are increased. See the section entitled "RESIDENCY AGREEMENTS" in APPENDIX A-herein. (^] PLAN OF FINANCING The proceeds from the sale of the Series 1999 Bonds, together with certain other available funds. will be used to provide funds to (i) acquire the assets of the Oaks which primarily consist of independent and assisted Jiving facilities, (ii) finance the cost of renovations to the Facility, (iii) , ) ......../ 22 11-1 r h'; ..,' ,"', ' , . provide for working capital and/or capitalized interest, (iv) fund a debt service reserve fund with respect to the Series 1999 Bonds and (v) pay certain costs with respect to the issuance of the Series 1999 Bonds. See uESTIMA TED SOURCES AND USES OF FUNDS," THE PROJECT In 1989~ the Facility was refinanced through a secondary loan from the City of Clearwater, Florida, from certain proceeds ofa loan from the Sponsor, through the Sponsor's Local Government Loan Program to the City of Clearwater, Florida, funded through the proceeds of Sponsor's Local Government Loan Program Floating Rate Demand Revenue Bonds, Series 1985C-l. The loan to the Company and Oaks was secured by the 1989 Notes guaranteed as to payment by GNl\1A, which is a part ofHUD. In 1996, each of the Company and Oaks declared bankruptcy and defaulted on the 1989 Notes. In connection with the plan of reorganization in bankruptcy and pursuant to their guarantee of the Notes. HUn purchased the 1989 Notes and the outstanding bonds were extinguished. HUD then sold the defaulted 1989 Notes at auction to Beal. Immediately prior to the closing of the offering of the Series 1999 Bonds~ the outstanding principal and interest on the 1989 Notes was $ ,."ll'. , : J ....{~., ~ t Beal has agreed to sell the 1989 Notes for Twenty Million Dollars ($20~OOO,OOO). Pursuant to the terms ofa Note Purchase Agreement between the Company and Beal. the Company will use a portion of the proceeds of the Series 1999 Bonds to (i) purchase its ] 989 Note from Beal for $ , with the Company thereby receiving clear title to the Company portions ofthe Facility (including the Nursing Centers and its portion of the common areas of the Facility). and (ii) purchase the Oaks ] 989 Note from BeaJ for $ . with the Company acquiring the remaining portions of the Facility previously owned by Oaks by accepting a deed in lieu of foreclosure from Oaks with respect to the remaining portions of the Facility. Accordingly, upon the completion of the offering of the Series 1999 Bonds and the purchase ofthe 1989 Notes by the Company. the ownership of the Facility will be consolidated in the Company. The Company will use a portion of the proceeds from the Series 1999 Bonds to renovate the Cove Building. Currently, the Cove Building is vacant except for the Cove Nursing Center. The third floor of the Cove Building will be renovated into modern, skilled nursing units. The residents of the Cove Nursing Center will be transferred to the new third-floor nursing facility upon completion. The old Cove Nursing Center will then be renovated and rehabilitated to meet current standards and the residents of the Bluffs Nursing Center will be transferred into such renovated space upon completion. At the same time. the remaining floors of the Cove Building will be completely rehabilitated to provide for senior independent and assisted living units in order to replace the facilities at the Bluffs Building. Upon completion of such living space, the residents in the Bluffs Building who have consented to move will transfer to the Cove Building. [^] The Facility will be renovated and redeveloped pursuant to the terms of a Development Agreement by and between the Company and CCSFL, which through its subsidiaries '-) 23 CJ/f,,/r manages over 200 nursing homes and assisted living facilities throughout the United States, primarily :r") on the East Coast and in Ohio. l11inois and Texas, and provides development services to owners of senior housing, assisted living and long- tenn care facilities. The Development Agreement provides for the payment to CCSFL of three percent (3%) of the (^) renovation costs of the Project. Seventy-five percent (75%) of such fee is due upon the issuance of the Series 1999 Bonds, with the remaining twenty-five percent {2S%} payable over the six-month projected construction period. Under the Development Agreement. CCSFL is required to create a detailed development plan and time schedule. prepare development budgets, oversee architectural and engineering planning, obtain aU necessary regulatory consents and approvals, identify contractors and coordinate the construction bid process, oversee the construction, and oversee the transition of the renovated Cove Building until opening. THE MANAGEMENT COMPANY Simultaneous with the issuance of the Series 1999 Bonds, the Company is terminating its existing management contracts and is entering into a new management agreement with CCSFL. (Additional CCS and CCSFL information to come] See the section entitled ItTHE PROJECT - The Management Companylt in APPENDIX A herein. FINANCIAL FEASIBILITY STUDY .............. I ,_/ Feasibility Study See APPENDIX B herein for a Financial Feasibility Study dated . 1999, prepared by BDO Seidman, LLP, independent certified public accountants (the ItFinancial Feasibility Study"). The Financial Feasibility Study includes managementts financial forecast of the Company for the four (4) years ending December 31,2002. As stated in the Financial Feasibility Study, there will be . differences between the forecasted data and actual results because events and circumstances frequently do not occur as espected, and those differences may be material. The achievement of any financial forecast is dependent upon future events, many of which are beyond the Company's control and the occurrence ofwbich cannot be assured. See "BONDHOLDERS' RISKS" herein. The Financial Feasibility Study should be read in its entirety, including all Dotes and assumptions set forth therein. Forecasted Financial Information for the Company The table set forth below reflects the forecasted debt service coverage ratio calculations for the Company and has been extracted from management's financial forecast included in the Financial Feasibility Study. See APPENDIX B - t1FinanciaI Feasibility Study'f attached hereto. .J 24 19 - /8" .~ "~ ,{ .. ' ~ \J (TO COME FROM FINAL DRAFT OF FINANCIAL FEASmn..ITY STUDY} THE SERIES 1999A BONDS . Mandatory and Optional Redemption For information with respect to extraordinary redemption, notices of redemption and exchanges in transfers of Series 1999A Bonds, see "THE SERIES 1999 BONDS - ADDITIONAL INFORMATION. " . .~ . Mandatory Sinking Fund Redemption. The Series 1999A Bond's maturing November 15, 20_ are subject to mandatory redemption prior to maturity in part, by lot, on November IS of each year, beginning November 15,20_, at a redemption price equal to 100% of the principal amount of such Series 1999A Bonds being redeemed plus accrued interest to the redemption date; without premium, in the following principal amounts and in the following years: Year Amoun\ · M aruri!)' The principal amount of Series 1999A Bonds required to be redeemed as set forth above shall be reduced pro rata by amounts equal to such principal amount of the Series 1999A Bonds of such maturities which are purchased by the Tender Agent or Trustee for cancellation and retirement with moneys provided by the Company. Optional Redemption. The Series 1999A Bonds maturing on or prior to November 15,20_ are not subject to redemption prior to maturity at the option of the Company. The Series 1999A Bonds maturing on or after November 1 S. 20_ aTe subject to redemption prior to their maturity. at the option of the Issuer, at the written request of the Company on or after November 15.20--, at any time in whole or in partt in order of maturities as shall be determined by the Company and by lot within a maturity, on any Interest Payment Date. at the redemption prices (expressed as percentages 2S 7'1-;r of principal amount of Series 1999A Bonds to be redeemed) set forth in the table below, plus accrued ..--...., interest thereon to the date fixed for redemption: (^] (^Il^](^] Period of Redemption (All dates inclusive) November 15, 20_ to November 14. 20_ November 15, 20_ to November 14, 20_ November 15, 20_ and thereafter Redemption Prices 102% 101 100 mE SERIES [^) 1999B EXTRASSM General Description '\ . ,.-> Interest. The Series [^J J 999B EXTRASSM will initially bear interest at the rate set forth on the inside cover page hereofuntiJ. but not including, the initial Optional Tender Date and will mature at the maturity date set forth on the inside cover page hereof. Thereafter, the applicable interest rate on the Series I^) 1999B EXTRAssM (the "Reset Rate") will be estabHshed for each Rate Period (the period commencing with an Optional Tender Date and ending on and including the day immediately preceding the next Optional Tender Date or, if none. the maturity date of the Series [^] 1999B EXTRASSM) by the Remarketing Agent under the Remarketing Agreement. The Remarketing Agreement provides for the appointment of a successor Remarketing Agent by and at the option of the Company. Not less than seventy-five (75) days prior to each Optional Tender Date, the Company shall deliver to the Trustee and the Remarketing Agent written notice of the Company's detennination of the next succeeding Optional Tender Date, which Optional Tender Date shall be a November 15, or shall specify that the Series (^)1999B EXTRASSM are to bear a Reset Rate to maturity. provided. however, that if the Company fails to specify the next succeeding Optional Tender Date, such date shall be a November 15 in such year as will enable the term between the current Optional Tender Date and such next succeeding Optional Tender Date to equal the preceding term or the final maturity, whichever is earlier. Not less than sixty-five (65) days prior to the Optional Tender Date at the commencement of each Rate Period for the Series (^] 1999B EXTRASSM, the Remarketing Agent shall detennine the Reset Rate for such Series [^] 1999B EXTRASSM which shall be the lowest rate that would, in the judgment of the Remarketing Agent having due regard to the prevailing market conditions. enable the registered holder of the Series [^] 1999B EXTRAssM, as of such Optional Tender Date, to sell such EXTRAssM at a price equal to the principal amount of the Series [^) 1999B EXTRASSM, provided that such rate may not exceed ] 5% per annum (the IIMaximum Rate"). Upon such determination of the Reset Rate, the Remarketing Agent shall promptly notify the Trustee and the :....J 26 qq-/~ ...."'. ,;,... ),....,' .. -, p~ -"'._-~ .I. . '\ Company of the Reset Rate. Not less than sixty (60) days prior to the Optional Tender Date, the Trustee shall promptly notify each registered holder ofthe Series (^) 1999B EXTRASSM in writing by first class mail, postage prepaid. of the Reset Rate which will be applicable on and after the Optional Tender Date and instructions for the procedure to be followed by any registered holder wishing to tender Series (^) 1999B EXTRASSM for purchase. If for any reason the Reset Rate caMot be determined by the Remarketing Agent in the manner specified above. the Reset Rate for such period shall be equal to The Bond Buyer Revenue Bond Index (as published in The Bond Buyer or any successor publication thereto) for the most recent period for which such information is available prior to the giving of notice of the Reset Rate by the Trustee to the registered holders of the Series (^) 1999B EXTRASSM, or ifsuch index or its equivalent is no longer published. the interest rate currently in effect. provided that such rate may not exceed the Maximum Rate. The interest rate on the Series (^) 1999B EXTRASSM win not be reset on any Optional Tender Date unless (a) at least seventy-five (75) days prior to such Optional Tender Date and (b) on such Optional Tender Date. the Company shall cause to be delivered, at its expense, to the Trustee and the Remarketing Agent an Opinion of Bond Counsel, to the effect that such reset in interest rate and change in the Rate Period will not have an adverse effect on any exemption from federal income taxation to which the interest on the Series (^) 1999B EXTRAssM would otherwise be entitled. In the event such Opinion of Bond Counsel is not delivered, the interest rate on the Series I ^ ) 1999B EXTRASSM currently in effect shall remain in effect as the Reset Rate for the next Rate Period, which shall be equal in duration to the preceding Rate Period but not shall not in any event extend beyond the date affinal maturity of the Series (^]1999B EXTRAssM. Optional Tender. The Series [^] 19998 EXTRAssM are subject to optional tender for purchase by the Trustee on behalfofthe Company on each applicable Optional Tender Date. THERE CAN BE NO ASSURANCE THAT SUFFICIENT FUNDS Wll.L BE AVAILABLE TO PURCHASE ANY OR ALL SERIES [^) 19998 EXTRAssM TENDERED FOR PURCHASE ON ANY OPTIONAL TENDER DATE. SEE "BONDHOLDERS' RISKS--Purchase of Series [^] 1999B EXTRAS SM. It The Trustee shan give written notice of the next applicable Optional Tender Date to each registered holder of Series (^] 1999B EXTRASSM when delivering notice of the new Reset Rate. The registered holder of such Series [^] 1999B EXTRAssM may exercise such option. and such Series f^) 1999B EXTRAssM shall be purchased by the Tender Agent in accordance with and subject to the terms of the Indenture. In order to exercise this option, the registered holder shall deliver a notice (the "Tender Notice'l) to the Trustee. as Tender Agent, not less than thirty (30) and not more than sixty (60) calendar days prior to the applicable Optional Tender Date. The Tender Notice must state the principal amount of the tendered Series [^] 1999B EXTRAssM (which amount shall be $5,000 or an integral multiple thereof). The delivery of the Tender Notice by the registered holder in connection with an Optional Tender Date shall be irrevocable and binding on the registered holder and cannot be withdrawn. Purchase on Optional Tender Dates. The Remarketing Agent shall offer for sale and use its best efforts to remarket the tendered Series [^] 1999B EXTRAssM to third parties for purchase at par on each Optional Tender Date. In the event that any tendered Series [^) 1999B EXTRASSM ......J 27 11- /~ _ ---.J ., cannot be remarketed, amounts on deposit in the Extendables Purchase Fund. ifany, will be applied to purchase such Series (^] 1999B EXTRASSM. The only sources of moneys available to make payments of the purchase price of the Series (^) 1999B EXTRAssM on each Optional Tender Date will be (i) the proceeds of the remarketing thereof (ii) moneys required to be deposited in the Extendables Purchase Fund by the Company pursuant to the Agreement in an amount not greater than the amount of cash held by the Company on such Optional Tender Date in excess of290 Days Cash on Hand, and (iii) any additional amounts deposited into the Extendables Purchase Fund by the Company. at its sole option, from any available moneys of the Company. Prior to 10:30 A.M.. Chicago Time, on each Optional Tender Date, the registered holders of the Series (^] 1999B EXTRASSM to be tendered for purchase on such date must deliver to the Tender Agent the Series (^) 1999B EXTRASSM to be tendered for purchase on such date accompanied by a written instrument or instruments of assignment or transfer in the fonn satisfactory to the Trustee transferring such Series (^] 1999B EXTRASSM to such person or persons as the Remarketing Agent in its sole discretion shall designate, or if the Remarketing Agent shall not have made any such designation, then to the Tender Agent to be held and registered in accordance with the provisions of the Indenture. If a registered holder files the requisite Tendcr Notice but fails to deliver the Series [^] 1999B EXTRASSM so tendered. such Series (^) 1999ij, EXTRASSM, upon deposit with the Tender Agent on the Optional Tender Date of the Tender Purchase Pricc, shall be deemed purchased and no longer outstanding, and the registered holder of such Series [^] 1999B EXTRASSM shall thereafter look solely to the Tender Purchase Price held by the Tender Agent without interest. I . .' In the event there are not sufficient moneys available to pay the principal of the Series (^] 1999B EXTRA SSM tendered for purchase on the Optional Tender Date, the Trustee, after notification in writing from the Tender Agent, will determine by lot the Series [^ ] 1999B EXTRAssM or portions thereof to be purchased on such Optional Tender Date. The registered holders of tendered but unpurchased Series [^ ) 1999B EXTRAssM shall continue to hold such Series I ^] 1999B EXTRAssM from and after the Optional Tender Date; however, such Series (^] 1999B EXTRAssM shall be given priority for redemption on each succeeding redemption date including mandatory sinking fund redemption dates, over any untendered Series [^ ] 1999B EXTRAS SM. Series [^] 1999B EXTRASSM that are not purchased on an Optional Tender Date shall bear interest from and after the Optional Tender Da.te at the Reset Rate determined by the Remarketing Agent as described above. Failure to purchase all Series [^] 1999B EXTRAssM tendered for purchase on a particular Optional Tender Date because of an insufficiency of money to effect such purpose shall not constitute an Event of Default under the Indenture. THERE CAN BE NO ASSURANCE THAT SUFFICIENT FUNDS WILL BE AVAILABLE TO PURCHASE ANY OR ALL SERIES [^] 1999B EXTRAssM TENDERED FOR PURCHASE ON ANY OPTIONAL TENDER DATE. THE F All..URE OF TIlE COMPANY TO PURCHASE ALL SERIES [^] 1999B EXTRASSM TENDERED FOR PURCHASE ON AN OPTIONAL TENDER DATE BECAUSE OF THE UNAVAll..ABILITY OF SUFFICIENT FUNDS IN THE .,~ 28 1CJ-/r( .") EXTENDABLES PURCHASE FUND SHALL NOT eONSTITUTE AN EVENT OF DEFAULT UNDER THE AGREEMENT OR THE INDENTURE. Preceding each Optional Tender Date, the Remarketing Agent wiJl attempt to remarket the Series (^J 1999B EXTRASSM duly tendered for purchase. On or before each Optional Tender Date, the Remarketing Agent shall deliver to the Trustee the proceeds of the remarketing of such Series (^] 1999B EXTRASSM. Based on information supplied by the Remarketing Agent and otherwise available to it, the Trustee shan authenticate and deliver new Series (^J 1999B EXTRASSM to the registered holders thereof. The Remarketing Agent, as a condition of serving in that capacity, win contract with the Company to. among other things, use its best efforts to remarket an Series [^] I 999B EXTRASSM tendered for purchase at a price equal to 100% of the principal amount thereof. in accordance with the provisions of the Indenture. mERE CAN BE NO ASSURANCE THAT THE REMARKETING AGENT Wll..L BE ABLE TO SUCCESSFULLY RE1\1ARKET ANY TENDERED SERIES [^] 19998 EXTRASSM. Mandatory and Optional Redemption For information with respect to extraordinary redemption, notices of redemption, partial redemption and exchanges and transfers of Series (^] 1999B EXTRAssM Bonds, see liTHE SERIES 1999 BONDS - ADDITIONAL INFORMATION ." .:) Mandatory Sinking Fund Redemption. The Series [^] 1999B EXTRASSM are subject to mandatory redemption prior to maturity in part, by lot (except that Series [^] ) 9998 EXTRASSM that have been tendered for purchase on any Optional Purchase Date but were no so purchased shall be redeemed prior to any other Series [^] ) 999B EXTRASSM), on November 15 of each year, beginning November 1 S, 20-, at a redemption price of 100% of the principal amount thereof. plus accrued interest thereon to the redemption date. without premium, in the following principal amounts in the following years: . I^] Year Amount · ~bturllY The principal amount of Series [^] 1999~ EXTRASSM required to be redeemed as set fonh above shan be reduced pro rata by amounts equal to such principal amount of the Series (^J 1999B o 29 11--lrI ~ftt~~~:':':'''::':':~~____..,. "'........ , ! EXTRASSM of such maturities which are purchased by the Tender Agent or Trustee for cancellation and retirement with moneys provided by the Company. Optional Redemption. The Series (^119998 EXTRASSM may be redeemed in whole or in part on any date occurring within the redemption periods. as set forth below, by the Issuer upon the direction of the Company. The redemption price for any such redemption shall be at a redemption price equal to 100% of the principal amount of the Series (^11999B EXTRAssM or portion thereof so redeemed on the applicable redemption date. plus accrued- interest to the redemption date. , I I (i) During the period between the issuance of the Series (^)1999B EXTRAssM and the initial Rate Change. the Series (^) 1999B EXTRASSM are subject to optional . redemption on or after November 15,20_. (ii) During any Rate Period of three years in length, the Series f^] 1999B EXTRASSM are subject to optional redemption commencing on the IS-month anniversaI)' of the first day of such Rate Period. (Hi) During any Rate Period or' five years in length, the Series (^) 1999B EXTRASSM are subject to optional redemption commencing on the 24-month anniversary of the first day of such Rate Period. ...~~ (iv) During any Rate Period of seven years in length, the Series [^) 1999B EXTRAssM are subject to optional redemption commencing on the 30Mmonth anniversary of the first ~ay of such Rate Period. (v) During any Rate Period of ten or more years in length) the Series [^) 1999B EXTRASSM are subject to optional redemption commencing on the fifth anniversary of the first day of such Rate Period. The Series (^11999B EXTRASSM tendered for purchase on any Rate Change Date but not so purchased shall be given priority for redemption on each succeeding optional or extraordinary redemption date until redeemed prior to the optional or extraordinary redemption of any other Series (^] 1999f! EXTRAS SM. Series 1999 Bonds so given priority shall be selected by the Trustee. by lot or in such other equitable manner as the Trustee shall deem appropriate, in the event of insufficient funds to redeem all such Series 1999 Bonds on any particular redemption date. Remarketing Agent B.C. Ziegler and Company has been appointed the initial IIRemarketing Agent" for the Series [^ I 1999B EXTRASSM. As a condition precedent to serving as Remarketing Agent, the Remarketing Agent will deliver to the Trustee and the Company a written agreement signitying its acceptance of the duties and obligations imposed upon it under the Indenture pursuant to the provisions of which, the Remarketing Agent will: (a) designate the office or offices in which it intends to conduct ,-.J 30 91-;CI .. ...-.... \ I . f . ~\ l '. , "',,""-1: "'~) activities as Remarketing Agent and to which Series [^ I 1999B EXTRAS SM. moneys, notices and communications are to be delivered and sent~ and (b) use its best efforts in accordance with the Remarketing Agreement to remarket Series (^ I 1999B EXTRA.SSM delivered to it at par~ and keep such books and records as shall be consistent with the prudent industry practice and make such books and records available for inspection by the Issuer, the Trustee and the Company at all reasonable times. The Remarketing Agent must be a member of the National Association of Securities Dealers. Inc. and will be authorized by law to perform all duties imposed upon it by the Indenture. The Remarketing Agent may at any time resign and be discharged of the duties and obligations crea.ted by the Indenture by giving at least thirty (30) days' written notice to the Issuer. the Trustee aud the Company; providedt however, no such resignation shall be effective duting the period commencing one hundred twenty (120) days prior to an Optional Tender Date and ending thirty (30) days after an Optional Tender Date. In no event shall the resignation or I~moval of the Remarketing Agent be effective until a qualified successor has accepted appointment as such. In the event of the resignation or removal of the Remarketing Agent, the Remarketing Agent win pay over, assign and deJiver any moneys and Series f^) I 999B EXTRASSM held by it in such capacity to its successor. The Company has the right, from time to timet to remove the Remarketing Agent and appoint a successor Remarketing Agent by giving written notice to the person or persons then serving as Remarketing Agent, to the Issuer and to the Trustee of such appointment; provided, howevert the Remarketing Agent may not be changed during the period commencing one hundred twenty (120) days prior to an Optional Tender Date and ending thirty (30) days after an Optional Tender Date. THE SERIES 1999C BONDS Mandatory and Ootional RedemPtiol! For information with respect to extraordinarv redemption. notices of redemption and exchanp;es in transfers of Series 1999C Bonds. see tiTHE SERIES 1999 BONDS - ADDITIONAL ~ORMATIQN." Mandatorv Sinkim! Fund Redemvtion. The Series 1999C Bonds maturinlZ November 15. 20 are subiect to mandatorv redemPtion prior to maturity in part. by lot. on November IS of each year. beginnin~ November] S. 20 . at a redemotion orice equal to ] 00% of the orincioal amount of 31 Cf/; !~ ,~ luch Series 199ge Bonds beinA: rc@emed 'plus accrued interest to the redemption date: without premium. in the following principal amounts and in the followimz years: Year Amount '" Maturity The principal amount of Series 1999C Bonds required to be redeemed as set forth above shall be reducedj)TO rata by amounts equal to such princioal amount of the Series 1999C Bonds of such maturities which are purchased bv the Tender Allent or Trustee for cancellation and retirement with monevs provided bv the Comoanv. . i '--.-' Omional Redemption. The Series 1999C Bonds maturinA: on or Driorto November 15.20 are not subject to redemption prior to maturity at the option of the Comoany. The Series 1999C Bonds maturing on or after November 15. 20)) are subiect to redemption orior to their maturity. at the option of the Issuer. at the written request of the Comoany on or after November 15.20 . at any time in whole or in part. in order of maturities as shall be determined by the Company and bv lot within a maturitv. on any Interest Payment Date. at the redemotion prices (exoressed as oercentaRes ofprinciosl amount of Series 1999C Bonds to be redeemed) set forth in the table below. plus accrued interest thereon to the date fixed for redemotion: Period of Red emotion (All dates inc1usive1 November 15. 20 to November 14. 20 November 15. 20 to November 14. 20 November 15. 20 and thereafter Redemotion Prices 102% 10] 100 THE SERIES 1999 BONDS - ADDITIONAL INFORMATION Extraordinary Redemption The Series 1999 Bonds are subject to extraordinary optional redemption at the direction of the Company on behalf of the Issuer, in whole at any time or in part on any Interest Payment Date o 32 91- If;' ........... , \ in Authorized Denominations from the proceeds of insurance or condemnation payments received in excess of $250,000 as a result of damage or destruction or taking under the powel' of eminent domain of all or a portion of the Mortgaged Property, in either case at a redemption price of 100 percent of the principal amount redeemed plus interest accrued to the redemption date. (^) Partial Redemption If less than all of the Series 1999 Bonds shall be called for redemption, the particular Series 1999 Bonds or portions thereof to be redeemed shall be designated by the Company and, if not designated, the Series 1999 Bonds to be redeemed shall be redeemed in the inverse order of maturity; provided. that Unremarketed Bonds shall be redeemed prior to any other Bonds. If less than an Outstanding Series 1999 Bonds of a single maturity are to be redeemed, the selection of Series 1999 Bonds within such maturity. or portions thereofin Authorized Denominations, to be redeemed shall be made by lot by the Trustee in any manner which the Trustee may determine. The Trustee shall, to the extent practicable, select Series 1999 Bonds for redemption as to avoid redeeming any particular Series 1999 Bond in part. Notice of Redemption ! .../' The notice of any redemption of Series 1999 Bonds shall be given by mailing, postage prepaid, a copy of the redemption notice at least 30 days and not more than 60 days prior to the date fixed for redemption to the registered holder of each such Series 1999 Bond to be redeemed at the address shown on the registration books; provided. however, that failure to mail any such notice to any such registered holders shall not affect the validity of the proceedings for the redemption of Series 1999 Bonds. Such notice shan state: (i) the CUSIP numbers of all Series 1999 Bonds being redeemed, (ii) the original issue date of such Series 1999 Bonds. (iii) the maturity date and rate ofinterest borne by each Series 1999 Bond being redeemed, (iv) the redemption date. (v) the redemption price. (vi) the date on which such notice is mailed, (vii) ifless than all Outstanding Series 1999 Bonds are to be redeemed, the Series 1999 Bond number (and, in the case ofa partial redemption of any Series J999 Bond, the principal amount) of each Series 1999 Bond to be redeemed, (viii) that on such redemption date there shall become due and payable upon each Series 1999 Bond to be redeemed the redemption price thereof, or the redemption price of the specified portions of the principal thereofin the case of Series 1999 Bonds to be redeemed in part only, together with interest accrued thereof shall cease to accrue and be payable and (ix) that the Series 1999 Bonds to be redeemed. whether as a whole or in part, are to be surrendered for payment of the redemption price at the designated corporate trust office of the Trustee at an address specified. ) 33 99 -/~ SECURITY FOR THE SERIES 1999 BONDS I' .----.. I THE SERIES 1999 BONDS SHALL NOT BE DEEMED TO CONSTITUTE A DEBT, LIABll..ITY OR OBLIGATION OF THE ISSUER THE STATE OF FLORIDA. OR ANY POLITICAL SUBDIVISION OR AGENCY THEREOF, AND NEITHER THE FAITH AND CREDIT NOR THE TAXING POWER OF THE ISSUER, TIlE ST ATE OF FLORIDA, OR ANY POLITICAL SUBDMSION OR AGENCY THEREOF IS PLEDGED TO TIlE PAYMENT OF THE PRINCIPAL OF, REDEMPTION PREMIUM, IF ANY, OR THE INTEREST ON THE SERIES 1999 BONDS. THE ISSUANCE OF THE SERIES 1999 BONDS SHALL NOT DIRECTL Y.INDIRECTL Y, OR CONTINGENTLY OBLIGATE THE ISSUER, THE STATE OF FLORIDA, OR ANY POLITICAL SUBDIVISION OR AGENCY THEREOF TO LEVY OR TO PLEDGE ANY FORM OF TAXATION WHATEVER THEREFOR OR TO MAKE ANY APPROPRIATION FOR THEPA YMENTOF THE PRINCIPAL OF, REDEMPTION PREMIUM, IF ANY, OR INTEREST ON THE SERIES 1999 BONDS. The Agreement provides, among other things, for the payment by the Company directly to the Trustee on behalf of the Issuer of payments in amounts sufficient to pay the principal of, redemption premium, ifany. and interest on the Series 1999 Bonds as the same shall become due and payable. Payments under the Agreement, when deposited with the Trustee, shall be deposited in a special fund designated the "Bond Fund," which is pledged under the Indenture to the payment of the principal of, redemption premium, if any, and interest on the Series 1999 Bonds. The Indenture provides, among other things, for a pledge and assignment by the Issuer to the Trustee of (i) all of the Issuer's rights and interests under the Agreement and the Mortgage (except for certain rights of the Issuer to indemnification and to reimbursement for its expenses), (ii) all of the Issuer's right, title, and interest in and to the funds and property held by the Trustee under the Indenture (other than the Rebate Fund). The Series 1999 Bonds and the redemption premium, ifany, and interest payable thereon. are special and limited obligations payable solely from (i) payments to be made by the Company under the Agreement and the Series 1999[^) ~ hereinafter described and other income, revenues and proceeds derived by the Issuer (or Trustee acting on behalf of the Issuer) pursuant to the Agreement or by reason of the disposition of the Mortgaged Property (defined below), (ii) certain other moneys pledged under the Indenture, including certain proceeds of the Series 1999 Bonds, moneys held in the Debt Service Reserve Fund, certain insurance proceeds and condemnation awards, and income from the investment of certain funds held in trust under the Indenture, and (iii) net amounts derived by recourse to the Mortgage. Pursuant to the Agreement and as evidence of the borrowing thereunder, the Company will execute! promissory [^ J ~ in ~ principal[^] amount equal to the aggregate principal amount ofthe Series 1999 Bonds. The payment of the Series 1999 [^] ~ and the performance by the Company of its obligations under the Agreement will be secured by the Mortgage. Pursuant to the Mortgage. the Company will grant a mortgage lien upon and security interest in the Facility, including the land on which it is located, to the Issuer, subject to Permitted Encumbrances (as defined in the Mortgage). ',..J 34 99-, /~ "\ Pursuant[^) to the Agreement and the Mortgage, in order to secure the loan payments and other payments due thereunder and the performance and observance of each covenant and agreement of the Company contained in the Agreement, the Series 1999 I ^ J ~ and the Mortgage, the Company will grant a security interest in its Revenues (as defined in the Indenture and in APPENDIX D hereto) and certain of its other property to the Issuer. to the extent such security interest can be perfected under the Florida Uniform Commercial Code and, subject to the provisions of certain accounts receivable financing loans. Pursuant to the Indenture, the Issuer will assign its rights (except certain unassigned rights related to receipt of notices. granting of consents and rights of indemnification) in and to the Agreement. the Series 1999 [^] ~, the Mortgage and the payments to be made thereunder to the Trustee as security for the Series 1999 Bonds. ) The Agreement requires the Company to fix, charge and collect, or cause to be fixed, charged and co]]ected, fees, rentals, rates and charges for the use of the Mortgaged Property and services provided or to be provided in connection therewith. that shall be at least sufficient to produce in each full Fiscal Year following completion of the Project a Debt Service Coverage Ratio for such Fiscal Year that is not less than 1.20. If the Debt Service Coverage Ratio. as calculated for any Fiscal Year, is less than 1.20. the Company (i) shall notify the Trustee of the Company's failure to achieve the Debt Service Coverage Ratio, (ii) take all action necessary to cause the fees, rentals, rates and charges imposed and collected by it in connection with its operations of the Mortgaged Property to produce the amount required by such paragraph and (iii) employ a Consultant to submit to the Trustee a written report and recommendation with respect to the fees, rentals. rates and charges imposed and coUected by the Company and other items of Revenues in connection with its operation of the Mortgaged Property and with respect to improvements or changes in the operations or management of or the services rendered by the Company. See APPENDIX D - ItDefinitions and Summary of Principal Documents - Loan Agreement" herein for a further description, including such further actions as are required to be taken if this covenant is not met. At the time of the issuance of the Series 1999 Bonds. the Debt Service Reserve Fund securing the Series 1999 Bonds will be funded from proceeds of the Series 1999 Bonds in an amount equal to the Debt Service Reserve Requirement. "Debt Service Reserve Requirement" means with respect to the Series 1999 Bonds, as of the date of any calculation, an amount equal to $ . In the event Additional Bonds are issued, the Debt Service Reserve Requirement, if any, with respect to such Additional Bonds shall be the lesser of (i) 10% of the proceeds of such Additional Bonds, (ii) the Maximum Principal and Interest Requirements on such Additional Bonds or (iii) 125% of the average Principal and Interest Requirements on such Additional Bonds. No such Additional Bonds shall be secured by the Debt Service Reserve Fund established for the Series 1999 Bonds. See the section entitled 'The Indenturelt in APPENDIX D herein. Additional Bonds may be issued under the Indenture and the Company may incur Parity Debt in accordance with and subject to the conditions set forth in the Indenture and the Agreement. Any Additional Bonds and any Parity Debt, ifissued, will be secured by the Mortgaged Property and the Revenues equally, ratably and on a parity with the Series 1999 Bonds. See the sections entitled "The ~ 3S 19-/r ; I" I .' , ~ ." . ~ " -:J' o ~#...-~...... . , .......dlI!Ii!~ , . .Indenture-Issuance and Delivery of Additional Bonds" and "The Agreement - Pennitted Debt" in APPENDIX D herein. HISTORICAL AND SELECTED FINANCIAL INFORMA nON Historical and selected financial information regarding the Company and the Facility is included in APPENDIX A to this Official Statement. Audited financial statements of the Company for the fiscal years ended December 31, 1998 and 1997 are included in APPENDIX C - Part (i) herein. and unaudited financial statements of the Company for the three-month periods ending March 31. 1999 and 1998 in APPENDIX C - Part (ii) herein. 36 qr~ If{ ..., '1~"1'\....~... ....~...~...~. '. .,...... I........l.;~' .....~. ,....." -. '.' ... ... . '> '-' . .. . ~I ~ '. i. .., _ l . . . . . ,'-:.'\ . \ ""'-.- } , I'''' !<', ... I. I' }.'. l:,' ,. '" ::, . ". ~ ~). .', .\ d .'\: .. . ; '~".~ t-:'~\ V ./ . ;: . o I ESTIMATED SOURCES AND USES OF FUNDS The total costs estimated to be incurred in connection with the financing of the Project and the issuance of the Series 1999 Bonds. and the anticipated sources of funds to pay such costs, are. summarl:ied in the following table. The footnotes following the table are an integra! part of the table and should be read in conjunction therewith. , SOURCES OF FUNDS: USES OF FUNDS: (To Come) ..1 37 ~--"'''<'.':,'~.:~'' . .. Jlod1l;l .... I....? ..: ~'"*' .'. c,', .' .~..' h....... ,'i -,j , . I" .;. I /; f II .. , . ,'.' ~ . .,.. -" ,- 99-/r I i I I I I I , , I ! I '-"C'"O ~l i tEf;:a U_1r\ :c a.- cu._ >-. ~ g~ >'C cU e. c u u 0 li5.!! Uui1 III .c"CCU 11 OCe. -0.8 ~ 5~= I U 1 0- 1 >. 0\ ';t g: ..c: 0\ I u__ - ti Ii e rl 'C "B'C U ~ cue: 1 ...... CIJ __ '5 u"'O go ..c ,C - ru . 'C .~ '- c .. Q" .:!l' 0 ~ :z c_ = ,~ '- ~ o '. '=- .8 ::E' e U e ~ cu C u cu.- > "="Co - -::aZ ~ i 0' Ir\ rIJ C .~ 7:=0 ~ 1 u U U l:C ) .c 8:s I ~ 8 U S; 0\ j 0\ 0 U u .... 0\ > .- ru - o 6- c. ~ > Z U 4) == .....c 'C r.5:I EPc_ ~ 1 rI.l .- o~ "'0 .= t; C 0. rIJ US"O .C '- u C Q" , ~ cu '"0 0 Q ~~CQ ..J "C t':' 0\ < 600-. ~ .c_0\ cu - Z "fi-g~ :z 5 as'e -< ,-E~ '2 ..s"iu ~ .c"3-5 < 15-gco 0\ 0\ &.i:iofirIJ 0\ I - .:!lrIJc fl 11 u ~= rIJ "ii3 0 'C U c. e ~ 1 j :E 'u ru ru c c I - 'C 0 .. e.o 0..- 'c I c _ .~ u Co Q.. o ..s 5 ! - c... '"0 . ~1I'l 'OOulr\ I c.;:; _ '"" _ c- U c t':' '"" .- "" ..c: u u ;fi~ Eo- ~ S -e "" u \ cu as cu ij !i , 0.1 > 19~ /~ i 1,,.oOE....., U 0 >-;z; V ..c: Z - ~ \' '. ~-' .., . ,r') I : '>t. ~"f~.:".~_=':'.~:~__'_..' _. . 38 ." 'r.. ~"'.~ ~;L~."" ~ . I" ~, .. >~. '" I . .1 . .... '..~ :: c ."f': ". t .~.:~- .-,~ ~ ..... . c. . I' ~ . . -. --," ~., I . LITIGA TION '.-.... , Upon delivery of the Series 1999 Bonds to the Underwriter, a certificate of no litigation will be provided by the Issuer and will state that there is no litigation pending against the Issuer, nor. to the knowledge of the official executing such certificate. threatened, to restrain or enjoin the issuance or delivery of the Series 1999 Bonds, to contest the authority for. or validity of, the Series 1999 Bonds. or to contest the corporate existence or powers of the Issuer. Th(^) ere is no litigation pending or. to the knowledge of the Company, threatened against the Company which is not adequately covered by the Company's insurance policies, or which, in the opinion ofthe Company. could have a material adverse effect on the Company's business or financial position. UN[^) DERWRITING / B.(^) C. Ziegler and Company (the "Underwriter"), has agreed to be the underwriter of the Series 1999 Bonds under a Bond Purchase Agreement entered into by and among the Issuer, the Company and said Underwriter. The price and other tenns regarding underwriting of the Series 1999 Bonds were established through negotiations rather than through a public bidding process. The Underwriter has agreed to purchase the Series 1999 Bonds at an aggregate discount of$ or _% of the proceeds thereof.[^) The Bond Purchase Agreement provides that the Underwriter will purchase all of the Series 1999 Bonds if any are purchased. the obligation to make such purchase being subject to certain terms and conditions set forth in the Bond Purchase Agreement. the approval of certain legal matters by counsel and certain other conditions. The Underwriter intends to offer the Series 1999 Bonds to the public initially at the offering prices shown on the inside cover page hereof, which prices may subsequently change without any requirement of prior notice, The Underwriter reserves the right to join with other dealers and underwriters in offering the Series 1999 Bonds to the public. The Underwriter may offer and sell the Series 1999 Bonds to certain dealers at prices lower than the public offering prices. LEGAL MATTERS Legal matters incident to the issuance of the Series 1999 Bonds and with regard to the tax.exempt status ofthe interest on the Series 1999A Bonds and the Series (^) 1999B EXTRASSM (see "TAX EXEMPTIONIt) arc subject to the legal opinion of Bryant. Miller and Olive, P.A.. Tallahassee, Florida, whose legal services as Bond Counsel have been retained by the Issuer and the Company. The signed legal opinion. dated and premised on law in effect as of the date of original delivery of the Series 1999 Bonds, will be delivered to the Issuer and the Underwriter at the time of original delivery, and the text of the opinion will be printed on the Series 1999 Bonds, .-J 39 119-/ ~ ~ \ The proposed text of the legaJ opinion is set forth in APPENDIX F. The actual legal opinion to be delivered may vary ITom that text if necessary to reflect facts and law on the date of delivery. The opinion will speak only as of its date, and subsequent distribution of it by recirculation of the Official Statement or otherwise shall create no implication that Bond Counsel has reviewed or expresses any opinion concerning any of the matters referenced in the opinion subsequent to its date. Bond Counsel has not been engaged tat nor has it undertaken to, review the accuracy. completeness or sufficiency of this Official Statement or any other offering material relating to the Series 1999 Bonds~ provided, however) that Bond Counsel shan render an opinion to the Underwriter of the Series 1999 Bonds (upon which opinion onJy the Undenvriter may rely) relating to the accuracy of certain statements contained herein. Certain other legal matters are subject to approval by Pamela K. Akin, City Attorney) by Baker & Hostetler LLP, Orlando. Florida, as counsel to the Company. and by Nabors, Giblin & Nickerson, P.A., Tampa. Florida, as counsel to the Underwriter. First Union Capital Markets Corp.. St. Petersburg, Florida has acted as Financial Advisor to the Issuer in connection with the issuance of the Series 1999 Bonds. TAX EXEMPTION . --', ',~~J The Code establishes certain requirements which must be met subsequent to the issuance and delivery of the Series 1999A Bonds in order that interest on the Series 1999A Bonds be and remain excluded from gross income for purposes of federal income taxation. Non-compliance may cause interest on the Series 1999A Bonds to be included in federal gross income retroactive to the date of issuance of the Series 1999A Bonds, regardless of the date on which such non-compliance occurs or is ascertained. These requirements include, but are not limited to, provisions which prescribe yield and other limits within which the proceeds of the Series 1999A Bonds and the other amounts are to be invested and require that certain investment earnings on the foregoing must be rebated on a periodic basis to the Treasury Department of the United States. The Issuer and the Company have covenanted in the Trust Indenture and the Agreement to comply with such requirements in order to maintain the exclusion from federal gross income of the interest on the Series 1999A Bonds. In the opinion of bond counselt assuming compliance with the aforementioned covenants, under existing lawst regulations, judicial decisions and rulingst interest on the Series 1999A Bonds is excluded from gross income for purposes offederal income taxation. Interest on the Series 1999A Bonds is not an item of tax preference for purposes of the federal alternative minimum tax imposed on individuals or corporations~ however) interest on the Series 1999A Bonds may be subject to the alternative minimum tax when any Series 1999A Bond is held by a corporation. The alternative minimum taxable income of a corporation must be increased by 75% of the excess of such . corporationts adjusted current earnings over its alternative minimum taxable income (before this adjustment and the alternative tax net operating loss deduction). "Adjusted Current Earning'. will , ' ".-..1' 40 c;9~ I r ') include interest on the Series 1999A Bonds. The Bonds are exempt from all present intangible personal property taxes imposed pursuant to Chapter 199, Florida Statutes. Except as described above, Bond Counsel will express no opinion regarding the federal income tax consequences resulting from the ownership of: receipt or accrual of interest on, or disposition of Series 1999A Bonds. Prospective purchasers or Series 1999A Bonds should be aware that the ownership of Series 1999A Bonds may result in collateral federal income tax consequences. including (i) the denial ofa deduction for interest on indebtedness incurred or continued to purchase or carry Series 1999A Bonds. (ii) the reduction of the loss reserve deduction for property and casualty insurance companies by 15% of certain items. including interest on the Series 1999 A Bonds, (iii) the inclusion of interest on the Series 1999A Bonds in earning of certain foreign corporatipns doing business in the United States for purposes ora branch profits tax. (iv) the inclusion of interest on Series 1999A Bonds in passive income subject to federal income taxation of certain Subchapter S corporations with Subchapter C earnings and profits at the close of the taxable yeart and (v) the inclusion of interest on the Series 1999A Bonds in "modified adjusted gross income" by recipients of certain Social Security and Railroad Retirement benefits for purposes of determining whether such benefits arc included in gross income for federal income tax purposes. PURCHASE, OWNERSHIP, SALE OR DISPOSITION OF THE SERIES 1999ABONDS AND THE RECEIPT OR ACCRUAL OF THE INTEREST THEREON MA Y HAVE ADVERSE FEDERAL TAX CONSEQUENCES FOR CERTAIN INDIVIDUAL AND CORPORATE BONDHOLDERS. PROSPECTIVE SERIES 1999A BONDHOLDERS SHOULD CONSULT WITH THEIR TAX SPECIALISTS FOR INFORIvlATION IN THAT REGARD. ,:) During recent years legislative proposals have been introduced in Congress, and in some cases enacted, that altered certain federal tax consequences resulting from the ownership of obligations that are similar to the Series 1999A Bonds. In some cases these proposals have contained provisions that altered these consequences on a retroactive basis. Such alteration of federal tax consequences may have affected the market value of obligations similar to the Series 199'9A Bonds. From time to time. legislative proposals are pending which could have an effect on both the federal tax consequences resulting from ownership of Series 1999A Bonds and their market value. No assurance can be given that legislative proposals will not be introduced or enacted that would or might apply tOt or have an adverse effect upon, the Series 1999A Bonds. Tax Treatment of Original Issue Discount Under the Code, the difference between the maturity amounts of the Series 1999A Bonds maturing in ~[the years _ through ~ and the initial offering price to the public, excluding bond houses, brokers or similar persons or organizations acting in the capacity of underwriters or wholesalers, at which price a substantial amount of Series 1999 A Bonds of the same maturity was sold is "original issue discount.1t Original issue discount will accrue over the term of the such Series 1999A Bonds at a constant interest rate compounded periodically. A purchaser who acquires such Series 1999A Bonds in the initial offering at a price equal to the initial offering price thereof to the ,...) 41 99-' It ') public win be treated as receiving an amount of interest excludabJe from gross income for federal income tax purposes equal to the original issue discount accruing during the period he holds such Series I 999A Bonds. and will increase his adjusted basis in such Series 1999A Bonds by the amount of such accruing discount for purposes of determining taxable gain or loss on the sale or other disposition of such Series 1999A Bonds. The federal income tax consequences of the purchase, ownership and redemption, sale or other disposition of Series 1999A Bonds which are not purchased in the initial offering at the initial offering price may be determined according to rules which differ from those above. Owners of such Series 1999A Bonds should consult their own tax advisors with respect to the precise determination for federal income tax purposes of interest accrued upon sale. redemption or other disposition of Series 1999A Bonds and with respect to the state and local tax consequences of owning and disposing of Series 1999A Bonds, !VDdate to include B EXTRAS Series 1999\' FINANCIAL ADVISOR the Issuer has retained First Union Capital Markets Corp., St. Petersburg. Florida, as financial advisor in connection with the issuance of the Series 1999 Bonds. Although First Union Capital Markets Corp. has assisted in the preparation of the Official Statement, First Union Capital Markets Corp. is not obligated to undertake, and has not undertaken to make, an independent verification or to assume responsibility for the accuracy, completeness or fairness of the information contained in the Official Statement. ,'J DISCLOSURE MA TIERS Disclosure Required by Florida Blue Sky Regulations Section 517.051, Florida Statutes. as amended, provides for the exemption from registration of certain governmental securities, provided that. if an issuer of governmental securities has been in default any time after December 31, 1975 as to principal and interest on any obligation, its securities may not be offered or sold in Florida pursuant to the exemption, except by means of an offering document containing full and fair disclosure, as prescribed by rules of the Florida Department of Banking and Finance (the "Departmenf'), Under the rules of the Departmen~ the prescribed disclosure is not fequired if the information is not an appropriate disclosure because the information would not be considered material by a reasonable investor. The Issuer has the power to and has issued bonds for the purpose of financing projects fOf other facilities which are payable from the revenues of the applicable loan. Revenue bonds issued by the Issuer for other projects may have been, or may be. in default as to principal and interest. The source of payment, however, for any. such defaulted bonds is separate and distinct from the source of payment for the Series 1999 Bonds. and therefore. any default on such bonds is not considered a material fact with respect to the payment of the Series 1999 Bonds offered hereby. .J 42 19;, I g' - ----... '1 The Company has not been in default as to principal or interest at any time after December 31, 1975 on bonds; notes or other debt obligations issued or guaranteed by the Company. Continuing Disclosure No financial or operating data concerning the Issuer is material for an evaluation of the offering of the Series 1999 Bonds or to any decision to purchase. hold or sell the Series 1999 Bonds and,. therefore. the Issuer will not provide any such infonnation. The Company has undertaken all responsibility for any continuing disclosure to the registered or beneficial owners of the Series 1999 Bonds as described below, and the Issuer shall have no liability to the registered and beneficial owners of the Series 1999 Bonds or any other person With respect to Securities and Exchange Commission Rule 15c2.12 (the 11Rulelt). The Company has covenanted for the benefit of the registered and beneficial owners of the Series 1999 Bonds to provide certain annual financial information and operating data relating to the Company by not later than 120 days following the end of the Company's fiscal year (the ttArmual Report"); commencing with the report for the fiscal year ending , 1999. and to provide notice of certain enumerated events, ifmaterial. The Annual Report will be filed with each nationally recognized municipal securities infonnation repository, the applicable state repository, ifany, and the Trustee. See APPENDIX E - uFonn of Continuing Disclosure Certificate" herein. The covenants set forth in the Continuing Disclosure Certificate have been made in order to assist the Underwriter in complying with the Rule. '., \ . ,j' Authorization of and Certification Concerning Official Statement This Official Statement has been authorized by the Issuer and the Company. Concurrently with the delivery of the Series 1999 Bonds, the Company and, to a limited extent described below, the Issuer, win furnish their certificates to the effect that, to the best of their knowledge, this Official Statement did not as ofits date, and does not as of the date of the delivery of the Series 1999 Bonds, contain any untrue statement of a material fact or omit to state a material fact which should be included therein for the purposes for which this Official statement is to be used~ or which is necessary in order to make the statements contained herein, in the light of the circumstances in which they were made, not misleading. Any such representation by the Issuer will address only the statements contained herein under the heading uTIlE ISSUER" and statements relating to the Issuer included above under "Disclosure Required by Florida Blue Sky Regulationtl under this heading. MISCELLANEOUS This Official Statement does not constitute an offer to sell the Series 1999 Bonds ~n any jurisdiction to any person to whom it is unJawfuJ to make such offer in such jurisdiction. No dealer, salesman or other person has been authorized to give any information other than that contained in this Official Statement or to make any other representations concerning the Series 1999 Bonds and, if ~ 43 99~ It - . . ~ .. .. . . . " 1 , ............ I:. . ". '. ' ,'. .",- ......, ~J o #'"......t tV'.;J:./JI. v,...- ...' ,- ./ given or made, such other information or representations must not be relied upon as having been authorized by the Issuer, the Company or any other person mentioned herein. Certain information contained in this Official Statement has been obtained from the Issuer, the Company and other sources which are believed to be reliable. but it is not guaranteed as to accuracy or completeness, and nothing in this Official Statement (except the matters under the caption "UNDERWRITING") is to be construed as a representation of the Underwriter. The information and expressions of opinion herein are subject to change without notice, and neither the delivery of this Official Statement nor any sale made hereunder shall, under any circumstances. create any implication that there has been no change in the affairs of the Issuer or any other person mentioned herein, or in the other matters described in the Official Statement, since the date hereof. Neither this Official Statement, nor any statements which may have been made orally or in writing, are to be construed as a contract with the registered holders of any ofthe Series 1999 Bonds. All estimates, whether or not so stated, are not to be construed as representations that they will be realized. Any statements in this Official Statement involving matters of opinion. whether or not expressly so stated. arc intended as such and not as representation,s of facts. . This Official Statement was approved, and the execution and delivery of this Official Statement authorized, by the Company. DEFt INC. By: . President 44 ; I , I I I I I l, I, I ! , CfI//r ..... . ~ c ~., . .;;. ~! ... .~ ~ ' , :'. c" ;c ~: '., ~ ,C"'. " ".' . . ." > .ti.:' . y; ~. - ...~.. o;~: ~. :.. ~ . ",: .'0'1:. "~ .:... ,t;' '" :..1 /.;. '., '~ . ""(3) .'.{ \ ')1 ',:.' . ~ "t '" ... ~ : ~,'~ ' . t,~;. '. . ":~~':' ~~ l. . { ,~ - ~ ./-::.,,> .f, ~ ~.; .:- j.." . ::};...., t......' . ~;.. :; '. ,. I". I ~ '.' ' . (~., . ; :~" .: . I.,:,;'" I~f.::':'; ;~. /. ;:..... ':, ~ , J~i;>:. " .', ~:" ):' ," ... . ....... '. ~" .; ", :,"'-::;", . r...;0.. ;r:. >. ;,. ," , " . I',: ". r.~ . <. ' ': !', ....,<., Ir . '\ IV . 1,1 , '. 'j:',.\,(,:.: "..-...-- . "'., ..' . .-.::............ .,". " " . :. ~ " 'f :. j. '" ~ . ,,,. ". . ,. ~ , >... APPENDIX A (^) ~~F ~ ~ - Organization and Operations . " ! ! i I \ , i '1:(9., 1>1. __~~r -, . .;. ,.T t.' :..,. .:' : ~ " ~! ~. c J ~' ~ ~"L , ,: ., . ,..' ~ . .l~_~.... , '. ,., .,~ . I,: ." n. " , \~,.,,",,", > ;;":,' '!::':..l " '.' cl',.c"" ;.';;'. ':;'/-'. , , ;'~:..~,:. '~ ; ,/.' , ~" :~ I.' " > .... " I' ::... .,:. . ..-.. ... ; ":. .~y..I".1 t~.":.... ' c '~." ;' , '., , . ~ : ~ .' , . , 9~ ,. ,'. . .r,'. .' , ':' ,j ';. ,. .' 'r>.." " i.: .:) ,'; !. . .' . " - , ". '. ':! ..('" APPENDIX B Financial Feasibility Study : ~ " . . CfI- I.r " " ..... + , ., '. I. '. .,'r >'1-" l" ,: '0' . ;_:. ~', ' ,'y ,~ l', 'i" ": ~.\ ,; . ' ::>,>.:,' .",- . ,n . ~,~ ,J.1 ."r: ',t, , I ~ .' ~ " , I ,~1 ~>", , ,c ~. .' /:~.'" ' ~~ ~:. " ~}".' ,~ . ~ -, C,"." .i.'~ ...: '~ d::'. ~ ~i~~:c - , /.., '.,\ ,. J;. ~ +:" \" . 1:'.. ~.; d~ , ~)!>'" 1\.<'.> '~' I I,' I ::; , .'~':~~-:) 'V ,,( ~, ;,' .i " ,. ,~ ~: ,;", "J. 'I :.'{ ., ' C.........t:.1t, (oi.) ... ,.J CI" :' APPENDIX C Fin'ancial Statements ) ". "I ':1 ;1 I' \. '1 i , i , I I I 19~/l( .' .. t ~:i ,/ "' .' ',: j, }.{., . , , "ft"l:""-"~ ....l'~' .'~c. . I';'. . .... . . ~ :~ " "'/ .~,."" J _ , . "' ". (:-. ~'. \ , " t.. .-t.... -.j' > {.:' ..' 'i ~ ; ~ .' '...:' , ,I \,' . ',j'. ". . '.'i': "fJ1:; ~ .:.'... . ~ ~ . .": ;\ .'. ~ . : ~';.. :',..' ~U.~'; .' '." . " ; ~ . .0 :' ...': .P~-'~~::':::_~-'.:'-~-~;-~ ,_.,:_:~. APPENDIX D Definitions and Summary of Principal Documents \' .1 I I t i I 'I 1 'I 99.-1ft' .,-. "c~' ~ ~.l....~ : l ~'..J I\..!:;.......~ '........I.h..... '. .~.-<"~..:.,~l.!\:.....~):\,;., ,. '.: .:::~ ~ ~ J ~',~{~ is, 3-,-:':'Lr,. ~ ~P"'''' ...-~ .... .~"'" ,H~. t.. .,~_~ ..:..~-~ '-;, , '. " .' lb- :., " , '. ',." . i / II' ',~ /~. ......."". ...' ~. ::'" " :<.' /.. ',. ,. .' , , )'. C .' ::'; /.. ,. ~J, ". . ~." .' " ;:1".:., .( "i~ : 1:1 ,~'" ~~;" ~~ : . I ~.~.: ., : '; .f . t:.':: ~ . ~ ....:.. i >i' /~\' o (; : ~ . ~ . " , ,. '. ~. . l.,. ", :.' :',\ ,t.'~-':} ~0 .. \. < . : ~. !. . L' r~ . '=h~y:='~~~~~:~~_~~_ " APPENDIX E Form of Continuing Disclosure Certificate ., ~...: '';~, ~"'.'. "~T:'t' C\' ",:I..,~ \' ~ '~.f,:~:.:, .:~~.":";)~....~~\r'.~.'t<:'" .4~,9-.TI>~' ..,.~. ....1-<-.. '... ~ ~'t' t ,....:.., 'r'" ! , if II " 'I I: '19-/~ - .\,:. , ' .~ 'J .'/ ., L . ., ~ ~ ,'. ','y C":" ,. .. 0, \ . ~~:...~, '....,. .~.. ..... <.: \. : '. ., II ...~' +' .... \ ., . '. ..'~ ,,' '. .' ~... U IS 1,\ .' ~ '~<. '.; ;L" ~~" '. ~~ "r.t' " ' .. " " I ; ~. . . ,"' ~ . .... !T., ". '. ~.' I, :.', <~ .f" .j: ':" , " 'ij ~ . .,,;.".. , .':t. "" , .-':.; '1 ?". .:;.. .- lj I. 'r~'':. k. ~ It.', I ~ .~ . . 5.;;'. ,:;---" 4...:::;.,1 \~ , < ~.:: . . .1.... ., .'. .~ ," . ". . " ;~ .' ....,,'\ L. ., .',1 I:. I. , " . ~ .: . " . J.':, i,': i ~. " ~:: 'i ':Jo' f :;~ : ','. .1',',< t,; \'. . '. ~ " .: :' o \. . '." ~); :~-;::~""'7:~'-:,~:;:,~::: .~, .:;. . .' I, .". ~. " . r '....~. ~ ' r. J.. . ~"i ....:...i l . ~. .I'.' APPENDIX F Form of Bond Counsel Opinion . I j l il i! Ii CfI~/~ ,; ...~.~. \"~;H9"i.~~:;~<'t~.I.,~~(~ "'~'''.lfi1'~ I. t ht'... ~.. '\ NEW ISSUES DRAIT #[^) 4: 6/8/99 07310.B["') UNRATED In the opinion of Bond Counsel, assuming compliance with certain covenants in the Indenture and the Agreement (as hereinafter defined). interest on the Series 1999A Bonds and the Series 1999 Bonds is excluded from gross income for purposes of federal income taxation and the Series 1999 A ~onds ane! the Series 1999 Bonds are exempt from all present intangible personal property taxes imposed pursuant to Chapter 199, Florida Statutes. See. however liT AX EXEMPTIONn herein for a description of certain federal minimum and other special taxes that may affect the tax treatment ofinterest on the Series 1999A Bonds and the Series 1999 Bonds. - CIlY OF CLEARWATER, FLORIDA (^) REVENUE BONDS. SERIES 1999 (BEF, INC. PROJECT) Consisting of S ", CITY OF CLEARWATER, FLORIDA [A] REVENUE DONDS, SE.RIES 1999A (DEF, INC. PROJECT) , S ", CITY OF CLEARWATER, FLORIDA IA] REVENUE BONDS, SERIES 19998 I^J(BEF, INC. PROJECT), EXTENDABLE RA TE ADJUSTABLE SECURITIES5M(EXTRASSM) I -.--... S ", CITY OF CLEARWATER. FLORIDA TAXABLE REVENUE BONDS. SERIES 1999C CBEF, INC. PROJECT) Dates, Interest Rates, Prices and Yields and Maturities as Shown on Inside Front Cover and the Initial Facing Page The Series 1999A Bonds, the Series 1999B Bonds and the Series 1999C Bonds (collectively. the "Series 1999 Bonds") win be issued by the City ofCleaJWater, Florida (the "Issuer") pursuant to a Trust Indenture, dated as of[^]~, 1999 (the "Indenture"). between the Issuer and SunTrust Bank. Central Florida. National Association, [Orlando, Florida], as trustee (the "Trusteen). The Series 1999 Bonds are issuable as fully registered bonds in the denominations of $100,000 and multiples of $5,000 above $100,000. Interest on the Series 1999 Bonds will be payable semiaMua11y on May 15 and November 15 of each year. commencing November 15, 1999. by check or draft mailed to the registered holder thereof as of the Regular Record Date~ provided that, at the written request by and expense of any registered holder of$1 ,000,000 or more in aggregate principal amount of Series 1999 Bonds, by bank wire transfer or direct deposit to the designated account of such registered holder. Principal of all Series 1999 Bonds J 19,/~ ........... - ''"""'\ , ..~) ,~ will be payable at the designated corporate trust office of the Trustee, presently located in (Orlando, Florida) upon surrender of the Series 1999 Bonds. The Series 1999 Bonds are being issued to provide funds which. together with certain other funds available therefor. will be used to (i) finance or refinance the cost of [^J aCQuirinlZ the tndeoendenllivinR. and assi~ted living units of the Oaks (as further described herein) and construction of various capital improvements to certain independent, assisted Ih.;ng and skilled nursing facilities (collectively. the "Facility") owned or to be owned by BEF, Inc., a Florida not-for-profit corporation (the "Company") and located in the City of Clearwater, Florida, (ii) provide for working capital and/or capitalized interestt (Hi) fund a debt service reserve fund with respect to the Series 1999 Bonds, and (iv) pay certain costs with respect to the issuance of the Series 1999 Bonds. In connection with the issuance of the Series 1999 Bonds. the Issuer and the Company wi)) entednto a Loan and Security Agreement, dated as of [^) Julv 1, 1999 (the "Agreement") and the Company wi)) execute and deliver to the Issuer ~ non-negotiable promissory [^] note of the Company in the aggregate principal amount of the Series 1999 Bonds (^ l(the U Series 1999 (^ J Noten). The Company will be obligated under the Agreement and the Series 1999 [^] Note to make payments sufficient, together with other available funds, to pay the principal of, redemption premium, if any, and interest on the Series 1999 Bonds as the same becomes due and payable. The Series 1999 Bonds and the redemption premium. ifany. and interest payable thereon, are special and limited obligations payable solely from (i) payments to be made by the Company under the Agreement and the Series 1999 [^) Note and other income, revenues and proceeds derived by the Issuer (or the Trustee acting on behalf of the Issuer) pursuant to the Agreement or by reason of the disposition of the Mortgaged Property (defined below), (ii) certain other moneys pledged under the Indenture, including certain proceeds of the Series 1999 Bonds. moneys held in a Debt Service ReselVe Fund, certain insurance proceeds and condemnation awards. and income from the investment of certain funds held in trust under the Indenture, and (Hi) net amounts derived by recourse to a Mortgage and Security Agreement. dated as off ^]~, 1999 (the "Mortgage"), from the Company to the Issuer. The payment of the Series 1999 [^) ~ and the performance by the Company of its obligations under the Agreement will be secured by the Mortgage. Pursuant to the Mortgage. the Company will grant a mortgage lien upon and security interest in the Facility. including the land on which it is located (the "Mortgaged PropertyU), to the Issuer. subject to Permitted Encumbrances (as such tenn is defined in the Mortgage). [^] In addition, pursuant to the Agreement and the Mortgage, in order to secure the loan payments and other payments due thereunder and the performance and observance of each covenant and agreement of the Company contained in the Agreement, the Series 1999 (^J ~ and the Mortgage. the Company will grant a security interest in its Revenues (as defined in the Indenture and in APPENDIX D hereto) and certain of its other property to the Issuer, to the extent such security interest can be perfected under the Florida Uniform Commercial Code. Pursuant to the Indenture, the Issuer will assign its rights (except certain unassigned rights related to receipt of notices, granting of consents and rights ofindemnification) in and to the Agreement. the Series 1999 [^] ~. the Mortgage and the payments to be made thereunder to the Trustee as security for the Series 1999 Bonds. fti-ICl ~...... , l TIlE SERIES 1999 BONDS WILL BE LIMlTED OBLIGATIONS PAYABLE SOLELY FROM THE REVENUES PROVIDED AND PLEDGED THEREFOR IN ACCORDANCE WITH THE INDENTURE, THE AGREEMENT AND THE MORTGAGE, THE SERIES 1999 BONDS Wll.L NOT CONSTITUTE A DEBT. LIABll...ITY OR OBLIGATION OF THE ISSUER, THE STATE OF FLORIDA, OR ANY POLITIeAL SUBDIVISION OR AGENCY THEREOF. AND NEITHER THE FAITH AND CREDIT NOR THE TAXING POWER OF THE ISSUER. THE STATE OF FLORIDA, OR ANY POLITICAL SUBDIVISION OR AGENCY THEREOF. IS PLEDGED TO THE PAYMENT OF TIlE PRINCIP AL OF, REDEMPTION PREMIUM, IF ANY, OR INTEREST ON THE SERIES 1996 BONDS. I.. The Series 1999A Bonds and the Series (^) 1999C Bonds are subject to mandatory. extraordinary and optional redemption as more fully described herein. The Series (^) 1999B . EXTRAssM are subject to optional tender on November IS, 2004, and thereafter at various dates deoendin~ on the lenlrth of the Rate Period as described herein. [^] Prospective investon should be aware of certain risks. anyone of which, if it materialized to a sufficient degree, could delay or prevent payment of debt service on the Series 1999 Bonds. This Official Statement, including all Appendices. 5hould be read in its entirety. See "BONDHOLDERS. RISKS" herein for a summary of certain of these risks. ,.J The Underwriter intends to engage in secondary market trading in the Series 1999 Bonds, subject to applicable securities laws. However. the Underwriter is not obligated to repurchase any of the Series 1999 Bonds at the request of any registered holder thereof. For details of the Underwriter's compensation, see "UNDERWRITING" herein. The Series 1999 Bonds are offered, subject to prior sale, when, as. and ifissued and received by the Underwriter, and subject to the approving legal opinion of Bryant. Miller and Olive, P.A., Tallahassee, Florida, as Bond Counsel. Certain other legal matters are subject to approval by Pamela K. Akin, City Attorney, by Baker & Hostetler LLP, Orlando) Florida. as counsel to the Company, and by Nabors, Giblin & Nickerson, P.A., Tampa. Florida. as counsel to the Underwriter. First Union Capital Markets Corp., 51. Petersburg, Florida has acted as Financial Advisor to the Issuer in connection with the issuance of the Series 1999 Bonds. It is expected that the Series 1999 Bonds will be available for delivery on or about , 1999. in . Florida. B.C. ZIEGLER AND COMPANY The date of thi! Official Statement is . 1999. "'Preliminary. subject to change. ~.) Legend for Cover Page: 99 -/~ ~:;. ::' . ,....... . , . .' c.' ~ .' \. ., ~.. .' , c, , , .' , I' I ~ ; .". " ~~'r, ..<~.. f ~ ~,.- i .. . . :....0. .' . . . . ", . .,.' " . I. _. ...: ? . .,.,' j,l'i., ;~:'.c .,~'.., . . , . , ' ,.i .. ., ',' fj<: ' . . I," " , 'c' ;. ' . , '"3 " . ," . " I :~ :: " I, ., . I. ,. ,;.. o > : . This Preliminary Official Statement and the information contained herein are subject to completion or amendment. These securities may not be sold, nor may. an offer to buy be accepted prior to the time the Official Statement is delivered in final form. Under no circumstances shall this Preliminary Officiat Statement constitute an offer. to sell or the solicitation of an offer to buy nor shall there be any sale of these securities in any jurisdiction in which said offer. solicitation or sale would be unlaWful prior to registration or qualification under the securities laws 'of such jurisdiction. .' . J .1 . I ..J;~, . I. .' :\ 99~/~ ') " " ') ~"""-~.. I , --..,) Dated: . 1999 Maturity November 15 Principal Amount Dated: . 1999 MATURITY SCHEDULE s * CITY OF CLEARWATER, FLORIDA [^) REVENUE BONDS, SERIES 1999A (HEF, INC. PROJEC'!) . Due: November IS, as shO\\n below Interest Rate Maturity November 15 Principal Amount Interest ~ Price Price Due: November 15. 20 Dated: , 1999 Maturity November 15 Principal Amount [To Come) (plus accrued interest. if any) s * CITY OF CLEARW A l'ER. FLORIDA [^J REVENUE BONDS, SERIES 19998 (BEF. INC. PROJECn. EXTENUAHLt; KA I ~ AUJUSTABLE ~t.:CU~11'lt.:S:>M(eX rKAS-~ CITY OF CL~ARW ATER FLORIDA TAXX8Lt.: JQ;VJ!;NU~ HUNUS~S~Rlf.:S 1999C (H~", INL. I'KOJe i) Due: November IS, as shown below Interest Rate Maturity November IS Principal Amount Price (To Come) (plus accrued interest. if any) Interest .~ Price ?fj,/f6 ') ._) ,J (^] THE SERIES 1999 BONDS HAVE NOT BEEN REGISTERED WlTH THE UNITED ST ATES SECURITIES AND EXeHANGE COM1vlISSION UNDER THE SECURITIES ACT OF 1993, AS AMENDEDt NOR HAS THE INDENTURE BEEN QUALIFIED UNDER THE TRUST INDENTURE ACT OF 1939, AS AMENDED. IN RELIANCE UPON EXEMPTIONS CONTAINED IN SUCH ACTS. IN MAKING AN INVESTMENT DECISION INVESTORS MUST RELY ON THEIR OWN EXAMlNA TION OF THE COMPANY AND THE TERMS OF THE OFFERING INCLUDING TIlE MERITS AND RISKS INVOLVED. THE SERIES 1999 BONDS HAVE NOT BEEN RECOM:MENDED BY ANY FEDERAL OR STATE SECURITIES COMMISSION OR REGULATORY AUTHORITY. FURTHERMORE. THE FOREGOING AUTHORITIES HAVE NOT CONFIRMED THE ACCURACY OR DETERl\1INED THE ADEQUACY OF TInS DOCUMENT. ANY REPRESENTATION TO THE CONTRARY MAY BE A CRIMINAL OFFENSE. Ifand when a registered holder of Series 1999 Bonds elects to sell a Series 1999 Bond prior to its maturity, there can be no assurance that a market will have been established, maintained, and in existence for the purchase and sale of the Series 1999 Bonds. The Underwriter of the Series 1999 Bonds assumes no obligation to establish or maintain such a market and is not obligated to repurchase any of the Series 1999 Bonds at the request of the holder thereof. See t1UNDERWRITING." No dealer, salesman, or any other person has been authorized to give any information or to make any representation other than those contained in this Official Statement, in connection with the alTering of the Series 1999 Bonds and, if given or made, such other information or representation must not be relied upon. This Official Statement does not constitute an alTer to sell or a solicitation of an alTer to buy any securities, other than the securities oITered hereby, or an offer or a solicitation of an oITer of the securities oITered hereby to any person in any jurisdiction where such oITer or solicitation of such offer would be unlawful. The information set forth herein has been obtained from the Issuer and the Company and other sources which are believed to be reliable, but is not guaranteed as to accuracy or completeness by, and is not to be construed as a representation of, the Underwriter. The information and expressions of opinion stated herein are subject to change without notice, and neither the delivery of this Official Statement nor any sale made hereunder shall, under any circumstances, create any implication that there has been no change in the affairs of the Company since the date hereof. IN CONNECTION WITH TIllS OFFERING. THE UNDERWRlTERMA Y OVER-ALLOT OR EFFECT TRANSACTIONS WHICH 5T ABILIZE ORMAINT AIN THE MARKET PRICE OF THE SERIES 1999 BONDS OFFERED HEREBY AT A LEVEL ABOVE THAT WlflCHMlGHT OTHERWISE PREVAIL IN THE OPEN MARKET. SUCH STABILIZING, IF COMMENCED, MAY BE DISCONTINUED AT ANY TTh1E. qq"/~ ',~ ~ s.' <. \....: . .'.:>";' " :i".' .- , .~...: . ,~ ' ", /7'" <~~w.-) >. ,., :, ~.' :.'\ ,., . I .~l .... ,., ,. .,...,' /...... .(r. ~ .,' .. ~;>. J~. _. \ ,.. ./.. ", :,0 I. r. 1,;;.'0 .Jl'". i'~ " \ J' . ~, . .... 'I " . '. : :'o:t~,. J.I" ,<.!, ., '. .', lINSERT A~RIAL PHOTO OF FACILITY! ',. q9-/~ 'j SUMMARY STATEMENT The information set forth in this Summary Statement is subject in all respects to more complete information set forth elsewhere in this Official Statement, which should be read in its entirety. The offering of the Series 1999 Bonds to potential investors is made only be means of this entire Official Statement. No person is authorized to detach this Summary Statement from this Official Statement or otherwise to use it without this entire Official Statement. For the definitions of certain words and terms used in this Summary Statement, see APPENDIX D - "Definitions and Summary of Principal Documents" herein. The Issuer The City of Clearwater.' Florida (the "Issuerll) is a municipal corporation duly organized and existing under and pursuant to the Florida Constitution, the Charter of the Issuer and laws of the State of Florida. The Issuer is authorized to make and execute financing agreements, contracts and other instruments necessary or convenient for the purpose of facilitating the financing of certain projects, including machinery. equipment, land, rights in land and other appurtenances and facilities r"elated thereto, to the end that the Issuer may be able to promote the health and safety of the inhabitants of the Issuer, the people of Pin ell as County and the State of Florida by increasing their access to adequate medical care and health care facilities, and to accomplish such financings through the issuance of revenue bonds. ..,~':r) The Series 1999 Bonds The Issuer proposes to issue its [^J Revenue Bonds, Series 1999A (HEF, Inc. Project), in the aggregate principal amount of $ (the 'I Series 1999A Bonds"). the Issuers [^) Revenue Bonds, Series 1999B (BEF, Inc. Project){^) Extendable Rate Adiustable Securitie~~ (EXTRASSMl in the aggregate principal amount of {^J $ (the "Series 1999B Bondstl) and the Issuer's Taxable [^) Revenue Bonds, Series 1999C (BEF. Inc. Project) [^)" in the aggregate principal amount of [^) $ (the "Series 1999C Bonds"). The Series 1999A Bonds. the Series 1999B Bonds and the Series 1999C Bonds are collectively referred to as the" Series] 999 Bonds. " Proceeds derived from the sale of the Series 1999 Bonds will be loaned to BEF, Inc., a Florida not-for-profit corporation (the "Company"), and applied to (1) acquire the assets of The Oaks of Clearwater, Inc. (the !tOaks") which primarily consist ofindependent and assisted living facilities; (2) finW"ce the cost of renovations to the Facility (defined below); (3) provide for working capital and/or capitalized interest; (4) fund a debt service reserve equivalent to the maximum annual debt service on the Series 1999 Bonds; and (5) pay costs of issuance associated with the transaction. THE SERIES ] 999 BONDS Wll.L BE LIMITED OBUGA TIONS PAY ABLE SOLELY FROM THE REVENUES PROVIDED AND PLEDGED THEREFOR IN ACCORDANCE WITH .....J 99-/~ .--, \ ! THE INDENTURE, THE AGREEt-.1ENT AND THE MORTGAGE. THE SERIES 1999 BONDS WILL NOT CONSTITUTE A DEBT, LIABILITY OR OBLIGATION OF THE ISSUER, THE STATE OF FLORIDA, OR ANY POLITICAL SUBDIVISION OR AGENCY THEREOF. AND NEITHER THE F AlTH ANI.' CREDIT NOR THE TAXING POWER OF THE ISSUER, THE ST ATE OF FLORIDA, OR ANY POLITICAL SUBDIVISION OR AGENCY THEREOF, IS PLEDGED TO THE PAYMENT OF THE PRINelP AL OF, REDEMPTION PREMIUM, IF ANY, OR INTEREST ON THE SERIES 1999 BONDS. The Company and the Facility The Company was incorporated as a Florida not-for-profit corporation in 1975. as American Baptist Estates of Clearwater, Inc. The Company changed its name to BEF~ Inc. in March of 1999. The Internal Revenue Service has detennined that the Company is an organization described in Section 501(c)(3) of the Internal eode of 1986, as amended (the "Code"). and is therefore exempt from federal income taxation under the provisions of Section 501 (a) of the Code. The Company received its Determination Letter from the Internal Revenue Service in May, 1976. The Company and the Oaks own and operate retirement facilities located in the City of Clearwater, PineUas County~ Florida, known as The Oaks of Clearwater Retirement Community (collectively, the "Facility"). The Facility is currently comprised of two high-rise buildings, Oak Bluffs, a IS-story building (the liB luffs Buildinglt), and Oak Cove, a l3-story building (the "Cove Building"), and four low-rise villa buildings (the "ViIlas") which contain skilled nursing facilities owned and operated by the Company (the tlNursing Centers"), and independent and assisted Hving facilities which are owned and operated by the Oaks. ) ---,-.. Iinsert mer~er descriPtionl The Company provides three different levels of care to residents of the Facility: independent living, assisted Jiving and nursing care. Residential areas within the Facility include 12 one-bedroom garden apartments located in the Villas, 8 two-bedroom garden apartments and 391 one-room and two.room higla.rise apartments (213 of which are currently unoccupied and located in the Cove Building and the remainder are located in the Bluffs Building) (collectively, the (^)ItIndeDendent Living Unitst1); (^] ~ assisted living units (the" Assisted Living Units") (^] located in (^] the Bluffs BuildinR; and the Nursing Centers, which are comprised ora 60.bed skilled nursing facility located in the Bluffs Building (the "Bluffs Nursing Center") and a 56-bed skilled nursing facility located in the Cove Building (the ttCove Nursing Center"). The Facility is located on approximately 7 acres ofland on the Intercoastal WatelWay, with views of the Gulf of Mexico, Clearwater and St. Petersburg, Florida. ii I---J 11f-/~ .......I...,.~.........;_~-._.-........-....--"-'------,.- The Project ..--..... The Facility was refinanced through a secondary loan from the City of Clearwater, Florida, from certain proceeds of a loan from the City of Gulf Breeze, Florida (the .'Sponsorll), through the Sponsors Local Government Loan Program to the City of Clearwater, Florida, funded through the proceeds of Sponsors Local Government Loan Program Floating Rate Demand Revenue Bonds, Series I98SC-1. The loan to the Company and Oaks was secured by two mortgage notes (the "Company's 1989 Note" and the "Oaks 1989 Note" and collectively, the" 1989 Notes") guaranteed as to payment by the Government National Mortgage Association, or GNMA, which is a part of the United States Department of Housing and Urban Development ("HUD"). In 1996. each of the Company and Oaks declared bankruptcy and defaulted on the 1989 Notes. In connection with the plan of reorganization in bankruptcy and pursuant to their guarantee of the Notes, HUD purchased the 1989 Notes and the outstanding bonds were extinguished. HVD then sold the defaulted ] 989 Notes at auction to Beat Bank, 5.S.B. ("Beal"). Immediately prior to the closing of the offering of the Series 1999 Bonds. the outstanding principal and interest on the 1989 Notes was $ Beal has agreed to sell the 1989 Notes for Twenty Million Dollars ($20.000.000). Pursuant to the tenns ofa Note Purchase Agreement between the Company and Beal, the Company will use a portion of the proceeds of the Series 1999 Bonds to (i) purchase its 1989 Note from Beal for $ , with the Company thereby receiving clear title to the Company portions ofthe Facility (including the Nursing Centers and its portion of the common areas ofthe Facility). and (ii) purchase the Oaks 1989 Note from Beal for $ , with the Company acquiring the remaining portions of the Facility previously owned by Oaks by accepting a deed in lieu offoreclosure from Oaks with respect to the remaining portions of the Facility. Accordingly, upon the completion of the offering of the Series 1999 Bonds and the purchase of the 1989 Notes by the Company, the ownership of the Facility will be consolidated in the Company. The Company will use a portion of the proceeds from the Series 1999 Bonds to renovate the Cove Building (the "Project"). Currently. the Cove Building is vacant except for the Cove Nursing Center. The third floor of the Cove Building will be renovated into modem, skilled nursing units. The residents of the Cove Nursing Center will be transferred to the new third-floor nursing facility upon completion. The old Cove Nursing Center wjJJ then be renovated and rehabilitated to current standards and the residents of the Bluffs Nursing Center will be transferred into such renovated space upon completion. At the same time. the remaining floors of the Cove Building will be completely rehabilitated to provide for senior independent and assisted Jiving units in order to replace the facilities at the Bluffs Building. Upon completion of such living space. the residents in the Bluffs Building who have consented to move will transfer to the Cove Building. [^J The Facility will be renovated and redeveloped pursuant to the terms of a Development Services Agreement (the "Development Agreement") by and between the Company and Complete Care Services of Florida, Inc. ("CCSFL") a Pennsylvania corporation and a subsidiary of Complete Care Services. Inc. C1CCS"). which through its subsidiaries manages over 200 nursing homes and assisted Jiving facilities throughout the United States, primarily on the East Coast and in Ohio. Illinois ..J Hi 99-{6 .,-.., and Texas. and provides development services to owncrs of senior housing, assisted living and long-term care facilities, The Development Agreemcnt provides for the payment to CCSFL of three percent (3%) of the (^) renovation costs of the Project. Seventy-five percent (75%) of such fee is due upon the issuance of the Series 1999 Bonds. with the remaining twenty-five percent (25%) payable over the six-month projected construction period. Under the Development Agreementt CCSFL is required to create a detailed development plan and time schedule, prepare development budgets, oversee architectural and engineering planning. obtain all necessary regulatory consents and approvals. identify contractors and coordinate the construction bid process, oversee the construction, and oversee the transition of the renovated Cove Building until opening. The Management Company Simultaneous with the issuance of the Series 1999 Bonds, the Company is terminating its existing management contracts and is entering into a new management agreement with CCSFL. See ~ description of CCSFL in the section entitled liTHE MANAGEMENT COMPANY" and the section entitled liTHE PROJECT - The Management Company" in APPENDIX A herein. Security for the Series 1999 Bonds In connection with the issuance of the Series 1999 Bonds, the Issuer and the Company will enter into a Loan and Security Agreement, dated as of [^] ~, 1999 (the "Agreement") and the ,__~~J Company will execute and deliver to the Issuer ~ non-negotiable promissory [^] note of the Company in the aggregate principal amount of the Series 1999 Bonds (the "Series 1999 [^] Noten) The Company will be obligated under the Agreement and the Series 1999 (^] Note to make payments sufficient, together with other available funds, to pay the principal of, redemption premium, if any, and interest on the Series 1999 Bonds as the same becomes due and payable. The Series 1999 Bonds and the redemption premium, if any. and interest payable thereon, are special and limited obligations payable solely from (i) payments to be made by the Company under the Agreement and the Series 1999 I ^) ~ and other income, revenues and proceeds derived by the Issuer (or the Trustee acting on behalf of the Issuer) pursuant to the Agreement or by reason of the disposition of the Mortgaged Property (defined below), (ii) certain other moneys pledged under the Indenture, including certain proceeds of the Series 1999 Bonds, moneys held in a Debt Service Reserve Fund, certain insurance proceeds and condemnation awards. and income from the investment of certain funds held in trust under the Indenturet and (Hi) net amounts derived by recourse to a Mortgage and Security Agreement, dated as of(^ ] July 1, 1999 (the "Mortgage"). from the Company to the Issuer. The payment of the Series 1999 [^] Note and the performance by the Company orits obligations under the Agreement win be secured by the Mortgage. Pursuant to the Mortgage, the Company will grant a mortgage lien upon and security interest in the Facility, including the land on which it is located (the "Mortgaged Property"). to the Issuert subject to Permitted Encumbrances (as such term is defined in the Mortgage). .....J iv 1q--/fr .._....-P"'-or..:.....~,.......~~...._________________~_. ..___ ... ._., ,._________ ,~ , J ~ "... .~.<t! 1 -..,.; Pursuant(^) to the Agreement and the Mortgage. in order to secure the loan payments and other payments due thereunder and the performance and observance of each covenant and agreement of the Company contained in the Agreement, the Series 1999 (^) ~ and the Mortgage, the Company will grant a security interest in its Revenues (as defined in the Indenture and in APPENDIX D hereto) and certain of its other property to the Issuer, to the extent such security interest can be perfected under the Florida Unifonn Commercial Code and, subject to the provisions of certain accounts receivable financing loans. Pursuant to the Indenture, the Issuer win assign its rights (except certain unassigned rights related to receipt of notices, granting of consents and rights of indemnification) in and to the Agreement. the Series 1999 (^] Note, the Mortgage and the payments to be made thereunder to the Trustee as security for the Series 1999 Bonds. For more information, see "SECURlTY FOR THE SERIES 1999 BONDS" herein. Certain Covenants of the Company Debt Service Coverage Ratio. The Agreement requires the Company to fix, charge and collect, or cause to be fixed, charged and collected. fees, rentals, rates and charges for the use of the Mortgaged Property and services provided or to be provided in connection therewith. that shall be ,at least sufficient to produce in each full Fiscal Year following completion of the Project a Debt Service Coverage Ratio for such Fiscal Year that is not less than 1.20. If the Debt Service Coverage Ratio, as calculated for any Fiscal Year. is less than 1.20, the Company (i) shall notify the Trustee of the Company's failure to achieve the Debt Service Coverage Ratio, (ii) take aU action necessary to cause the fees, rentals, rates and charges imposed and coUected by it in connection with its operations of the Mortgaged Property to produce the amount required by such paragraph. and (Hi) employ a Consultant to submit to the Trustee a written report and recommendation with respect to the fees, rentals, rates and charges imposed and collected by the Company and other items of Revenues in connection with its operation of the Mortgaged Property and with respect to improvements or changes in the operations or management of or the services rendered by the Company. See APPENDIX D - I1Definitions and Summary of Principal Document - Loan Agreement" herein for a further description, including such further actions as are required to be taken if this covenant is not met. Other Covenants. The Agreement also contains covenants which impose limitations on the issuance of additional debt. on transfers of assets and transfers of cash and investments, and on consolidation, merger, sale or conveyance. For more information, see APPENDIX D - "Definitions and Summary of the Principal Documents - Loan Agreement" herein. . Purchase or Series [^J 1999B EXTRASSM The registered holders of Series [^) 19998 EXTRASSM have the option to tender their Series f^J19991! EXTRAssM to the Trustee for purchase on each Optional Tender Date. The only sources of moneys available to make payments ofthe purchase price ofthe Series [^) 1999B EXTRASSM on each Optional Tender Date are (i) the proceeds of the remarketing thereof, (ii) moneys required to be deposited in the Extendables Purchase Fund by the Company pursuant to the Agreement in an v CfI-lft ') amount not greater than the amount of cash held by the Company on such Optional Tender Date in excess of (^ J_ Days Cash on Hand, and (Hi) any additional amounts deposited into the,Extendables Purchase Fund by the Company, at its sole option. from any available moneys of the Company. Therefore, ifany of the Series (^] 1999B EXTRAssM tendered on any Optional Tender Date are not remarketed at par. the Tender Agent may not have available funds with which to purchase such Series [^) 1999B EXTRASSM. In the event sufficient funds are not available. the registered holders of the tendered but unpurchased Series (^] 1999B EXTRASSM will be required to retain their Series [^] 1999B EXTRAssM at the new interest rate determined by the Remarketing Agent. THERE CAN BE NO ASSURANCE THAT SUFFICIENT FUNDS WILL BE A V AIT..ABLE TO PURCHASE ANY OR ALL SERIES (^] 1999B EXTRASSM TENDERED FOR PURCHASE ON ANY OPTIONAL TENDER DATE. Failure to purchase Series (^ ) 1999B 'EXTRASSM tendered for purchase on any Optional Tender Date does not constitute an event of default under the Indenture orthe Agreement. See liTHE SERIES [^] I 999I! EXTRASSM [^];; General Description . Purchase on Optional Tender Dates" herein. In addition, there can be no assurance that any interest rate adjustment with respect to the Series (^) 1999B EXTRAssM will not cause a material burden on the financial condition ofthe Company. See ttBONDHOLDERS' RISKS - Purchase of Series [^] 1999B ExtrasSM" herein. Historical and Selected Financial Information .,) Historical and selected financial information regarding the Company and the Facility is included in APPENDIX A to this Official Statement. Audited financial statements of the Company for the fiscal years ended December 31, 1998 and 1997 are included in APPENDIX C - Part (i) herein, and unaudited financial statements of the Company for the three-month periods ending March 31, 1999 and 1998 in APPENDIX C - Part (ii) herein. Historical Statement of Activities and Historical Pro Forma Debt Service Coverage and Cash Investments and Related Ratios [TO COME (^ J] Financial Feasibility Study Feasibility Study. See APPENDIX B herein for a Financial Feasibility Study dated , 1999, prepared by BDO Seidman, LLP. independent certified public accountants (the "Financial Feasibility Studyll). The financial Feasibility Study includes management's financial forecast of the Company for the four (4) years ending December 31, 2002. As stated in the Financial Feasibility Study, there will be differences between the forecasted datu and actual '0 vi qq-/g; c. L. r") " . , I . --'" 'J ) results because events and circumstances frequently do not occur as elpec'ted, and those differences may be material. The achievement of any financial forecast is dependent upon future events, many of which are beyond the Company's control and the occurrence ofwhich cannot be assured. See "BONDHOLDERS' RISKS" herein. The Financial Feasibility Study should be read in its entirety, including all notes and assumptions set forth therein. Forecasted Financial Information for the Company. The table set forth below reflects the forecasted debt service coverage ratio calculations for the Company and has been extracted from management's financial forecast included in the financial Feasibility Study. See APPENDIX B - t1Financial feasibility Study" attached hereto. Forecasted Schedule of Coverage Ratios . I I (TO COME FROM FINAL DRAFT OF FINANCIAL FEASffiILITY STUDY] vii 9q-/~ ----<l!b..1 ,~ ,,~ ~.) ::; . .' . '. ~ Bondholders. Risks AN INVESTMENT IN THE SERIES 1999 BONDS INVOLVES RISK. A BONDHOLDER IS ADVISED TO READ "BONDHOLDERS' RISKS" HEREIN FOR A DISCUSSION OF CERTAIN RISK FACTORS wmCH WOULD BE CONSIDERED IN CONNECTION WITH AN INVESTMENT IN THE SERIES 1999 BONDS. Careful consideration should be given to these risks and other risks described elsewhere in this Official Statement. Among other things. since the Series 1999 Bonds are payable solely from the revenues of the Company and other moneys pledged to such payment, careful evaluation should be made of certain factors that may adversely affect the ability of the Company to generate sufficient revenues to pay expenses of operation, and the principal of. premium, if any, and interest on the Series 1999 Bonds, The Principal Documents Definitions of cenain words and terms used in this Official Statement and summaries of the Indenture) the Agreement) the Mongage and other principal documents are included in this Official Statement in APPENDIX D hereto. Such definitions and summaries do not purport to be comprehensive or definitive. All references herein to the specified documents are qualified in their entirety by reference to the definitive forms of such documents. copies of which may be viewed at the offices of B.C. Ziegler and Company, 1 South Wacker Drive, Chicago, Illinois, or will be provided to any prospective purchaser requesting the same, upon payment by such prospective purchaser of the costs of complying with such request. . viii q'l-/~ "',<: > TABLE OF CONTENTS o PaKe INTRODUCTION... . ..... . . . . . . .. . .. ., ..... . , ,. . , . , . . . ,. . , . '. . . . ... . . . ,. .... ,.. . .. I Purpose of the Official Statement , . . . . . . , . . . . . . . . . . , . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . .. 1 The Is:sucr . .. . . . . . . . a , .. a I . t . I . . t . . . t I . , . . . . . . . .. , .. . I . .. . . . . .I- , I . . + a .. . .. + . I . I . I . . . .. . 2 TIle Comp.any.and the Facility. . . . . I , . + .. . . . , , .. . I , . .. . 4- . .. . . t . I . I . .. I I . . . t I + I . , + , . . , . . I 2 'TIle Project .......... I . . . .. , . . I . . . .. . I . . . I . I . . . . I I , .. . 4- _ I . .. I . .. . + I , I . + . . . . . , . .. . . . . . I . . 3 The Management Company .. . . . . . , . . . , . , . . . . . , . . . . . . . . . . . , . , . . , . . . . , . , . . . . . . , , . . . 4 The Series 1999 .Boncls .... _ .. . . . . . . .. . . . t . . . . .. .. . I . + , . . .. , .. , . . , . . . . . . . . . . 4- . . . . t .. ... . of . . 4 '" Security for the Series 1999 Bonds .............,..................... I . . . . . . . . .. [^] 4 . = Historical and Selected Financiallnfonnation . . . . , . . . . . . . . . . , . . , . . . . , . . . . . . . . . . . . . . . . . . 6 Historical Statement of Activities and Historical Pro Fonna Debt Service Coverage and [^] Cash. InvestInents and Related Ratios .,....,............... , . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Financial Feasibility Study. . . . . , . . , . . . . . . . . . . , , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . 6 The Series [^].!222!! EXTRAssM ..............,.............,.................... 7 Bondl1olderst Risks "..'..'................,...... t . .. I . t I I , I . . . . + , . .. . . I . + , . .. . , . . .. . . . . 7 " Definitions and Summaries of Legal Documents . . . . . . . . . . . . . . . . . , . . . . . . . . . , . . . . . . . .. [^] Z BONDHOLDERS' RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . , . . 8 G-en.eral ............. . . I- t . . . , .. . .. I . , . .. I , , . . , . .. . . . . . . . . . 4- a I I . .. . . 4- . .. .. 01 . . . . .. . , t . . , . . 8 General Uncertainty of Revenues , . . . . . . , , . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Failure to Achieve or to Maintain Occupancy. . . . . . . . . . . . . . , . . . . . . . , . . , . . . . . . . . . . , . . . . . 9 No Assurance Forecasted Results Will Be Obtained . , , . . , . . . . . , ... . . . , . . , . . . . . . . . . . . . . . . . 9 Malpractice Claims and Losses .,..,..."......,...,...,.,.....,..,.......,..... [^ J 2 Regulation . . . . , . . . . . . . . . . . . . . . , . . . . , . . . . . . , . . . , . , . , . . . . . . , , . . , . . . . . . . . . . . . . .. 10 Florida Licensure and Certificate of Need ..............,....,..................'. [^} 13 Possible Changes in Tax Status ..... . . . . . . . . . . . . . . . , . , . . . . " . . . . . . . . . . . . . . . . . . . . . .. IS Limited Use of Facilit)' .........."................,........,....,..,.,...,.,. [^] II Possible Effect of Adverse Conditions in Housing Market ..... .'. , . . , . . . . . . . . . , . . . , . .. [^] 15 Construction Risks ...........,...................,...............,..,...... [^] ll. Enforceability of Remedies ................................................... [^J ~ Uncertainty of Investment Income ...,................................,......... [^ ] ,!g Ban.kr'uptcy ....,.... I I . I , .. ... , . . , . . . . , , . . .. . I . t . . .. . , I . , . . . of . . I . .. I . . , . . . . . . . I . . . . ;. I . t 17 Rights of Residents ............................................................ 1 7 COI1lpctition I . , . . .. + I . . I . .. . . . . .. . . of . , . . . . I . . . . . .. , . . . .. . . , . . . . I I . . . . .. . . . .. . a , . .. [^] II Investment Risks; Lack of Ratings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. I ^ ] J2 Purchase of Series [^] 19998 EXTRASSM . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 18 . Amendments to Documents '........,...........".....,................,..,., I ^ J 18 Year 2000 Compliance ...................................................... [^] l! Transfer of Residents from the Bluffs Buildinll to the Cove Buildinp. Uoon Comoletion of Renovations ..,..,..,.....,.."...",.....,.,. - . . . . . . . . . . . . . . . . . . . . . . . . . ., 19 == Other Risk Factors ..............,.....,........................ .' . . . . . . . . . . . . .. 19 FLORIDA REGULA nON OF CONTINUING CARE FACILITIES ......,.......,...,...... 20 TliE ISSUER. . . . . . .. . . . .. .. . . . . , . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 .--J ix 99~ I~ ,~ 1 THE COMPANY AND THE FACILITY ,....,.,.,..,......,..........,...,.."....,.,. 21 Residence Agreements .. , , . . , . . , . . , , . , . , . . . . . . . , . , . . . . , . . , . , . , . , . . . . , . . , , . . . , . , . 22 PLAN OF FINANCING.... ,.. ., ., .. . . . . .. . . . . . . . . ., . . . . , . . , . . . .. . . . , .. . . , . . . .. (^) 22 . - THE PROJECT. . . . . . . . . . . , . . , . . , , . . . . , . . . . , . , . . . . , . . , . , . . , . , . , . . , , , . . . . . , . . . . , . , 23 (^) TIiE MANAGEMENT COMPANY ....,....,.,..,..............................., 24 . FINANCIAL FEASIBILITY STUDY .. . . . . . . . . . . . . . . , . . . . . . . , . . , . . . , . . . . . . . . . . . . . . . . . 24 Fea.sibilit:}' Shldy t'. + I . . I + It. . . ~ . . . If. f t , . . . t . I , . t ~ . . . . , . . . .. '" . . . .. . . . ~ , . . . . . . . . , 24 Forecasted Financiallnfonnation for the Company . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . .. (^ J ~ THE SERIES 1999A BONDS . . . . . . . . , . . . . . . . . . . . , . . . . . , . . . . . . . . . . . , . . . . . . . , . . . . . . , . 2S Mandatory and Optional Redemption . . . , . . . . . . . . , . . . . . . . . . . . , . , . , . . . . . . . . . . . . . . . . . . 25 THE SERIES 1999B ~XTRASSM ..,.' , . . , . , . . , . , . , , . . , . . . . , . . , . , . , . . , . , . . , . . , . , , . ,f,g (^) General Description . . . , . . . . . . . . . . . . . . . . . . . I . . . . . . . . . . , . . . . . . . . . . . , . . . . . . . . ,. [^ I ~ Mandatory and Optional Redemption . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . .. (^ J t.2 Rernarketing Agent ...........................,....,..,..................... [^) ~ THE SERIES 1999C BONDS . . . , . , , . . , . . , . . . . . . . . , . . . , . . , . . . . . . , . . , . . . , . . . , , . , . , . . . .li Mandator\' and Optional Redemption . , . . , . , . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ...... 3T lHE SERIES 1999 BONDS -ADDITIONAL INFORMATION .,..,......,............. [^) II Extraordinary Redemption . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . .. [^) II Partial.Redemption ..,..........." t , . . . + , . . . . . , + , . , . . t * . I . + , . . . t . . . . . . . . .. . . . . . . 33 ( .--..... Notice of Redemption .......................................................... 33 SECURITY FOR TI-IE SERJES 1999 BONDS .. . . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . . 34 HISTORICAL AND SELECTED FINANCIAL INFORMATION ........................... 36 ESTIMATED SOURCES AND USES OF FUNDS-. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . , . 37 ANNUAL DEBT SERVICE REQUIREMENTS. . , . . . . . , . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . 38 LITIGATION .....................,...............,..,..,....,.,..,.,...,....,.. 39 UNDERWRITING .......,......,..,....,..,........,..,..,..,....,.,............. 39 LEGAL MA TIERS ........................,.,...,........,...................... 39 TAX EXEMPTION. . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . , . . . . . , . . . . . . . . . . . . . . . . . . , . , . . . . 40 Tax Treatment of Original Issue Discount ...,....,............,.,.................., . 41 FINANCIAL ADVISOR . . . . . . . . . . . , . . . . . . . . . . , . . . . . , . . , . . . . . , . . . , , . . . , . . , . . . . . . . , . 42 DISCLOSURE MAITERS .......................,..,.............................. 42 Disclosure Required by Florida Blue Sky Regulations ..........................,....... 42 Continuing Disclosure . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . , . . . . . . . . . . . . . . . . . . . . , . . 43 Authorization of and Certification Concerning Official Statement . . . , . . . . . . . . . . . . . . . . . . . , . . 43 MISCELLANEOUS ... c' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . 43 APPENDIX A- APPENDIX B - APPENDIX C - [^) BEF. INC..: - Organization and Operations Financial Feasibility Study Financial Statements: (i) Audited financial statements of the Company for the fiscal year ending December 31. 1998 compared to the audited fmancial statements of the Company for the fiscal year ending December 31. 1997; and (ii) Unaudited financial statements of the Company for the three-month periods ending March 31, 1999 and 1998. Definitions and Summary of Principal Documents Fonn of Continuing Disclosure Cenificate Fonn of Bond Counsel Opinion APPENDIX D- APPENDIX E- APPENDIX F- x , I I II .. ...., '-.J 91-/~ " .. ,\ . : .~. ", l.' ~: :,~. "" 0': .,. ,. ; ~~>~:i:~t!~;O .' . '.. I,. ,,' ';:'. ~ : ."=. A '1~~'4."" " .~: 1<: ...~. .~. ! '; . I~: > :!.': i- I ../:~ . ..:(~". .:.< ",I ;. 1"" ',"T .:';r"J. .'. ,'I: " " ... >: L~" . ~ ",' P. . ,'+u . '" ~ . . .~:: . ,> , 1/- ..,..... '?~~" .... . .' c .'~ , cL {l t. .' ", ", <~ : , I" v . . ....-- . ~ + ~ 'I Q .~ . " ". .,; ~ ' ~. ; ~< .~..,. . f. .1 ....., . ) " , ::: ~ ~ t r. , ",' . ~ . , " , . "C. . (;I .' ~~.,... '?;:.-.' 7?;;f::<; ~\l(.'~:,j:, "'IA. -' . ',:: ~V'I:~f '\ \\~,;" :: ~, '~~..I~ ,~.~... ' '; '. 1.'~ .~'.. I .~,' >,~'. .~ ",' EXHIBIT G NOTICE OF PUBLIC HEARING ..' \ Resolution 99-18 " --- ST. PETERSBURG TIMES STATE OF FLORIDA } 8.S. hll h d Pu s c Dally COUNTY OF PINELLAS St. Petersburg, Plnellas County. Florida J~efore the undersigned authority personally appeared P:H11 ~ T.~ne who on onth says that he Is Legal Clerk of the St. Petersburg Times Nnrth Pi np 11 ~!'l. Eel i H nn D daUy newspaper published at St. Petersburg, In PineHas County, Florida: that the attached copy of ad,'ertlsement, being n Legal Notice In the matter RE: NnH (':r-o nf Pllhl i r Hp~T'ing Adll QQOOfiQ40h in the Court was published in said newspaper in the Issues of F'phr"~ry 9 J 199Q Affiant further says the sold St. Petersburg Times is a newspaper published at St. Petersburg, in said Pinellas County, Florida, and that the sold newspnper has heretofore been continuously published In sold Pinellas County, Florida, each day and has been entered as second class mail matter at the post office In St. Petersburg, in said PlneUas County, Florida, for a period of one year next preceding the first publication of the attached copy of advertisement., and affinnt further says that he has neither paid nor promised any person. firm, or corporation any discount, rcbnte, commission or refund for the purpose of ~Ing this. ad~ise~lnt for publication in the said newspaper. ~, ~ Sworn to and subscribed before J ,""'" me this 11 th day of .~'Ai\'l\"~' BEnY M. TAYLOR Fe ruar A. 19 9 9 N i.\ MY COMMISSION' CC 588664 ~~ .,j!.l EXPIRES: October 14, 2001 , :L.z..... ~ ..,w,..';i,'" 80nded ThI\J Hotuy Public Iblerwrtlll1 Public ....---' /J PwatJl1 ban J fJfI ~ j.;kutil1ctdo1l_ ~ of ~~ procblo4 . '. . .' ~.. '" + "...) ~;..-"'. I...... NOTICE OF PUBLIC HeARINO PLEASE TAKE NOTICE thallhe S.ll1fv1jt)).u;;:o,:.- ~~~VJ'~t~~ ~tU.f Clearwater, "'oriiki {,~<o;Cr',yT'~ fhe hmlna/ler descrl~~~Z~hr::l ~~! ,Iht elf... rega rdlng pOsed bonds bv Ihe ClI... at Ihe Clfv C'''' 'fuance or Ihe pro. llE..,S. OKl!ola Avenut, Cleorwalet Fro~WaSSIO~be~, .n at 2:00 a.m., at Whrch time a ' on rY OOrdlng Ihe arOPOJl!d llluance a ny person mayll& &al'd, . ThhtEI.!'" Commlssron of Iht CI~th(f"'eu~.hcbo'l ncdsand,orOled. as """,n requesfed to Is II R y omm ulan") hlllowlnll capttal ara,eJfe s evenue Bonds to Ifnance lhe n requesled bv BEF I " t Clly Commlulon IIDf for oroUt col'PDratlon ,nc. (the Owner"l. a FlorIda tton pursuanl fo SectIon m~)1~r:n:'1I rlltemat organlza. Code of 19'~. as amended fIe n una' Revenut .$JS,OOQ,OOO Revenue Bonds serres 'IsM ('!~I~tBto UCted OIIe or more 'orin at OIl ' ... ands"), In 1 m Bond' will bear mo,.. limes. The proceeds ollhe lion and eqUIPPI:gu~e~g ~~fl~f~Jr1:c~~Slllon. rl!boblllla. ", ue betwten Ihe Clly at Clearwater Clla... HaOll'1 Ondlcleoh la Ave- os Counly Courthouse d a e PInel. Blull build/nil. located' an presently known as fhll Oak da and 'he Oak Calle ~11~n~~~~:f~u~hCJfg~ater, FIori. ~ lJ~=:f' Florida (colledrVely. ltle "Prol~}.tAi'h'; senior I)ouslng, :::jl~~~cTrl~~t~~~~ltl'hon, We/nlll consist of a faclllly. The Oak BI I' bulldl 'V car urslng care renovation ar lhe Oa~ Cove ~fdl~~lolwlnll the completion of a tar prollt owner wh II w, 'l!koeded fa be IOld to and convert It Inlo a Of IN I renovate the oak Bluff bulldln lIet II currenltv oPl!rar.gr::~a~ J',o~r'ng focllllY. The pror. Owner. and will be owned earwater. Inc. and rhe once of 'ht 1999 Bonds sorer;g:~~J:'~~~lowrnll the Iuu. Any oerlOll who decides t I' City CommISSIon with r~:~: :~: d~ilslon made by the It, meeltnll or h&arlnv will nlled a ~ormad of "hr conlldered at Sech person may ...... f ' n . proceedings, the ProceedIngs li;,.- 0 ~Urt thot a verbatim record of dence UPOI'I which the O::~'f,~~~~ tesltmony and evl. ..!!XlO69406l February 9, 1999 sed. ~ ~:\\.., CL402.\V 111(,..,,1)\. ~'t i"lff\' '1...[ 111:,11 .1 ~l1IC anJ corrl.~ll:i ;,', ~: \"1:1 t.:j.,'Lti.I)'}-I ii ;l;~pt'iLt ~;'I i;Jt: ~~i~ I u} tLI~ C:Hy nf Cl'.:.~,' ,',:.~, \\ ,n/:,~ lilY ];.1::,( M.d or dl.~.d :-l,;~J (If :hc {~H~. (jf <..;h..lr..:r:\IJ~:~i.. This a .... U!iY pi .~~S 19:>li' ,If . S"".~ . ".' "- -~- -- Clty Clerk , '\ -; 1q-lf6 ~~--oII!l b.-