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HomeMy WebLinkAbout05/20/2008 MMPC Agenda Packet1VIARANA 1VIUNICIPAL PROPERTY CORPORATION (1VIMPC) 1VIEETING NOTICE AND AGENDA COUNCIL CIIAIVIBERS 11555 W. CIVIC CENTER DRIVE,IVIARANA~ ARIZONA 85653 NIAY 20, 2008 at or after 7:00 P.NI. Board Members: Chairperson Vice Chair Secretary A. CALL TO ORDER B. BOARD ACTION Carol McGoxray Herb Kai Hurvie Davis Roger Forrester Dan Sullivan 1. MMPC Resolution No. 2008-O1: resolution of the board of directors of Town of Marana Municipal Property Corporation authorizing the issuance of its not to exceed $40,000,000 aggregate principal amount of municipal facilities revenue bonds, Series 2008, for the purpose of refinancing certain bonds of the corporation and financing certain projects for the Town of Marana, Arizona; delegating to the manager of the Town of Marana, Arizona, and, in his absence, the finance director of the Town of Marana, Arizona, the authority to determine various terms with respect to the bonds and certain matters with respect to the bonds being refunded; providing for the application of the proceeds from the sale of the bonds; approving the form of and authorizing the execution and delivery by the corporation of a series 2008 supplemental trust indenture appro- priate for the protection and disposition of revenues and further securing the payment of the bonds, a Combined Cortaro Silverbell District Park Ground Lease and Fourth Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, an escrow trust agreement, any financial guaranty or related agreement necessary with respect to credit enhancement and a bond purchase contract and approving an official statement relating to the bonds (Erik Montague) C. ADJOURNMENT. 1 TOWN COUNCIL MEETING INFORMATION MARANA MUNICIPAL PROPERTY CORPORATION (MMPC) MEETING DATE: May 20, 2008 AGENDA ITEM: B. 1 TO: MAYOR AND COUNCIL FROM: Erik Montague, Finance Director SUBJECT: MMPC Resolution No. 2008-01: Resolution of the board of directors of Town of Marana Municipal Property Corporation authorizing the issuance of its not to exceed $40,000,000 aggregate principal amount of municipal facili- ties revenue bonds, Series 2008, for the purpose of refinancing certain bonds of the corporation and financing certain projects for the Town of Marana, Arizona; delegating to the manager of the town of Marana, Arizona, and, in his absence, the finance director of the Town of Marana, Arizona, the authority to determine various terms with respect to the bonds and certain matters with respect to the bonds being refunded; providing for the application of the proceeds from the sale of the bonds; approving the form of and authorizing the execution and delivery by the corporation of a series 2008 supplemental trust indenture appropriate for the protection and disposition of revenues and further securing the payment of the bonds, a Combined Cortaro Silverbell District Park Ground Lease and Fourth Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, an escrow trust agreement, any financial guaranty or related agreement necessary with respect to credit enhancement and a bond purchase contract and approving an official statement relating to the bonds. DISCUSSION Town has determined that it will be beneficial to its citizens to design, acquire, construct and equip, as the case may be, extensions and additions to the sewer lines and interceptors in Silverbell Road and to the Town's Airport, extensions and improvements to Camino de Marana and Dove Mountain Roads and improvements to Cortaro Silverbell District Park as well as other sewer, transportation and park projects. Adoption of MMPC Resolution No. 2008-01 by the Board authorizes staff to proceed with the sale of bonds in an amount to exceed $40,000,000 in Municipal Facilities Revenue Bonds. MMPC Resolution No. 2008-01 also authorizes staff to execute any and all documents necessary to complete the sale of bonds. MMPC Series 2008 Authorization 5/ 14/08 12: 30 pm EM If approved, the bonds will be issued in two series. The Municipal Facilities Revenue Bonds, Series 2008A (the "Series 2008A Bonds") and the Municipal Facilities Revenue Bonds, Series 2008B (the "Series 2008B Bonds") would be issued for the purpose of providing funds to: (i) Acquire, construct, improve and extend, as applicable, sewer facilities, streets and parks of the Town of Marana, Arizona (the "Town"); (ii) To refund and redeem the Bonds Being Refunded (as defined herein); (iii) Fund a debt service reserve fund for the Series 2008 Bonds (or pay the premium associated with a debt service reserve fund insurance policy or surety bond); and (iv) Pay costs in connection with the issuance of the Series 2008 Bonds. Of this authorization, approximately $35,000,000 will be deposited in a construction fund and $3,500,000 will be deposited in an escrow account to refund the outstanding portion of the Series 1997 Bonds at a savings of approximately $120,000. The Series 2008B Bonds will be subject to optional and to extraordinary optional redemption prior to maturity. As such, the Series 2008B Bonds are subject to redemption, in whole or in part on any interest payment date. Staff anticipates calling portions of debt as future funds become available. Principal of and premium, if any, and interest on the Series 2008 Bonds will be payable from rental payments to be paid by the Town to the Town of Marana Municipal Property Corporation (the "Corporation") pursuant to a Combined Cortaro Silverbell District Park Ground Lease and Fourth Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, to be dated as of June 1, 2008 FINANCIAL IMPACT The issuance of debt/lease payment was incorporated in the annual budget. ATTACHMENTS MMPC Resolution No. 2008-01; Sources and Uses of Funds. Available for viewing in the Clerk's Office are the Preliminary Official Statement, Bond Purchase Agreement, Escrow Trust Agreement, Series 2008 Supplemental Trust Indenture and Fourth Supplement to Base Town Lease. RECOMMENDATION Staff recommends approval of MMPC Resolution No. 2008-01. SUGGESTED MOTION I move to approve MMPC Resolution No. 2008-01. -2- MARANA MUNICIPAL PROPERTY CORPORATION MMPC RESOLUTION N0.2008-01 RESOLUTION OF THE BOARD OF DIRECTORS OF TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION AUTHORIZING THE ISSUANCE OF ITS NOT TO EXCEED $40,000,000 AGGREGATE PRINCIPAL AMOUNT OF MUNICIPAL FACILITIES REVENUE BONDS, SERIES 2008, FOR THE PURPOSE OF REFINANCING CERTAIN BONDS OF THE CORPORATION AND FINANCING CERTAIN PROJECTS FOR THE TOWN OF MARANA, ARIZONA; DELEGATING TO THE MANAGER OF THE TOWN OF MARANA, ARIZONA, AND, IN HIS ABSENCE, THE FINANCE DIRECTOR OF THE TOWN OF MARANA, ARIZONA, THE AUTHORITY TO DETERMINE VARIOUS TERMS WITH RESPECT TO THE BONDS AND CERTAIN MATTERS WITH RESPECT TO THE BONDS BEING REFUNDED; PROVIDING FOR THE APPLICATION OF THE PROCEEDS FROM THE SALE OF THE BONDS; APPROVING THE FORM OF AND AUTHORIZING THE EXECUTION AND DELIVERY BY THE CORPORATION OF A SERIES 2008 SUPPLEMENTAL TRUST INDENTURE APPROPRIATE FOR THE PROTECTION AND DISPOSITION OF REVENUES AND FURTHER SECURING THE PAYMENT OF THE BONDS, A COMBINED CORTARO SILVERBELL DISTRICT PARK GROUND LEASE AND FOURTH SUPPLEMENT TO AMENDED AND RESTATED TOWN LEASE AND SERIES 1992 TOWN LEASE, AN ESCROW TRUST AGREEMENT, ANY FINANCIAL GUARANTY OR RELATED AGREEMENT NECESSARY WITH RESPECT TO CREDIT ENHANCEMENT AND A BOND PURCHASE CONTRACT AND APPROVING AN OFFICIAL STATEMENT RELATING TO THE BONDS WHEREAS, the Town of Marana Municipal Property Corporation (the "Corporation") was formed to transact any or all lawful business for which nonprofit corporations may be incorporated under the laws of the State of Arizona, including, without limiting the generality of the foregoing, any civic or charitable purpose such as financing the cost of acquiring, constructing, reconstructing or improving buildings, equipment or other real and personal properties suitable for use by and for leasing to the Town of Marana, Arizona (the "Town"), or its agencies or instrumentalities; and WHEREAS, the Town heretofore determined that it was beneficial to its citizens (i) to acquire the water system owned by Clifford Ray Honea and Ethel Wynema Honea, husband and wife, doing business as Honea Water Company (the "First Water System"), consisting of certain real property and certain personal property (the "Initial First Water System Improvements") with respect to the First Water System and (ii) to acquire the facility then being used as the municipal complex for the Town (the "Municipal Complex"), consisting of certain other real property and to make certain necessary improvements to the First Water System (the "New First Water System Improvements" and collectively, with the Initial First Water System Improvements, the "First Water System Improvements" and the acquisition of the First Water System, the acquisition of the Municipal Complex and the making of the New First Water System Improvements, collectively, the "First Project"); and WHEREAS, the Corporation assisted the Town in financing the First Project; and WHEREAS, in order to finance the costs of the First Project, the Corporation issued its $280,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 1990, dated as of March 1, 1990, and its $315,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 1992, dated as of June 1, 1992 (collectively, the "Outstanding Bonds"); and WHEREAS, the Town further heretofore determined that it was beneficial to its citizens (i) to refinance the Outstanding Bonds and (ii)(A) to acquire the water systems known as "Cortaro Marana" and "Marana Water Service" (collectively, the "Second Water Systems"), consisting of certain real property and certain personal property (the "Second Water Systems Improvements" and collectively, with the First Water System Improvements, the "Water System Improvements") with respect to the Second Water Systems and (B) to (I) make certain improve- ments to the Water System Improvements, (II) make certain road and related improvements and construct improvements to increase traffic capacity on certain other roads, (III) acquire certain real property upon which to construct a new municipal complex (the "Town Hall Property") and (IV) make tenant improvements to certain office space leased to the Town, the property described in clauses (B)(I), (II) and (IV) being as described on Exhibit E attached to the hereinafter described Base Town Lease and collectively, with the acquisition of the Second Water Systems and the project described in clause (B)(II), being referred to herein as the "Second Project"; and WHEREAS, the Corporation assisted the Town in refinancing the Outstanding Bonds and in financing the Second Project; and WHEREAS, in order to refinance the Outstanding Bonds and to finance the costs of the Second Project, the Corporation issued its $8,175,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 1997, dated as of October 1, 1997 (the "Series 1997 Bonds"); and WHEREAS, the Series 1997 Bonds and certain additional bonds on a parity therewith have been as hereinafter described and shall be secured by a Trust Indenture, dated as of October 1, 1997 (as supplemented, the "Indenture"), from the Corporation to Wells Fargo Bank, National Association (formerly Norwest Bank Arizona, N.A. and Wells Fargo Bank Arizona, N.A.), as trustee (the "Trustee"), pursuant to which is pledged, among other things, rental payments made pursuant to an Amended and Restated Town Lease and Series 1992 Town Lease, dated as of October 1, 1997 (as amended and supplemented, the "Base Town Lease"), by and between the Corporation, as lessor, and the Town, as lessee; and WHEREAS, the Town also heretofore determined that it was beneficial to its citizens to design, acquire, construct and equip the new municipal complex on the Town Hall Property (the "Third Project"); provided, however, that pursuant to the Second Amendment to 328191164v 1 4/23/2008 2 Amended and Restated Town Lease and Series 1992 Town Lease, dated as of April 1, 2002, by and between the Corporation, as lessor, and the Town, as lessee, certain additional property (the "Operations Center Property") has been ground leased by the Town to the Corporation and leased back by the Corporation to the Town, the Operations Center Property thereafter being considered part of the Town Hall Property for all purposes of the First Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of February 1, 2000 (the "First Supplement to Base Town Lease"), by and between the Corporation and the Town and certain changes have been made to the description of the Town Hall Improvements to include a town operations center to house public works, police, water, vehicle asset management and information systems; and WHEREAS, the Corporation assisted the Town in financing the Third Project; and WHEREAS, in order to finance the costs of the Third Project, the Corporation issued its $10,000,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2000, dated as of February 1, 2000 (the "Series 2000 Bonds"), which are secured by the First Supplement to Base Town Lease; and WHEREAS, pursuant to a Third Amendment to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of September 1, 2003, by and between the Corporation, as lessor, and the Town, as lessee, a portion of the Operations Center Property has been released from the provisions of the First Supplement to Base Town Lease and certain other changes made for all purposes of the First Supplement to Base Town Lease; and WHEREAS, the Town also heretofore determined that it was beneficial to its citizens to design, acquire, construct and equip, as the case may be, additional parts of the new municipal complex on the Town Hall Property (the "Fourth Project"); and WHEREAS, the Corporation assisted the Town in financing the Fourth Project; and WHEREAS, in order to finance the costs of the Fourth Project, the Corporation issued its $19,700,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2003, dated as of September 1, 2003 (the "Series 2003 Bonds"); and WHEREAS, the Town also heretofore determined that it was beneficial to its citizens to design, acquire, construct and equip, as the case may be, final parts of the new municipal complex on the Town Hall Property (the "Fifth Project") and to refinance a portion of the bonds heretofore issued by the Corporation; and WHEREAS, the Corporation assisted the Town in financing the Fifth Project and refinancing such bonds being refunded (the "Second Refunding"); and WHEREAS, in order to finance the costs of the Fifth Project and the Second Refunding, the Corporation issued its $8,675,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2004, dated as of August 1, 2004 (the "Series 2004 Bonds"); and WHEREAS, the Town has now determined that it will be beneficial to its citizens to design, acquire, construct and equip, as the case maybe, extensions and additions to the sewer lines and interceptors in Silverbell Road and to the Town's Airport, extensions and 328191164v 1 4/23/2008 improvements to Camino de Marana and Dove Mountain Roads and improvements to Cortaro Silverbell District Park as well as other sewer, transportation and park projects as described in Exhibit B attached to the hereinafter described Series 2008 Town Lease (the "Sixth Project") and to refinance a portion of the bonds heretofore issued by the Corporation (the "Bonds Being Refunded"); and WHEREAS, the Corporation desires to assist the Town in financing the Sixth Project and refinancing the Bonds Being Refunded (the "Third Refunding"); and WHEREAS, in order to finance the costs of the Sixth Project and the Third Refunding, the Corporation and the Town deem it necessary and desirable for the Corporation to sell and issue its not to exceed $40,000,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2008, to be dated as of the date established as the dated date for such bonds as provided herein and consisting of the Municipal Facilities Revenue Bonds, Series 2008A (the "Series 2008A Bonds") and the Municipal Facilities Revenue Bonds, Series 2008B (the "Series 2008B Bonds" and together with the Series 2008A Bonds, the "Series 2008 Bonds"); and WHEREAS, in connection with the sale and issuance of the Series 2008 Bonds, the Corporation shall enter into a Combined Cortaro Silverbell District Park Ground Lease and Fourth Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, to be dated as of the first day of the month established as the dated date of the Series 2008 Bonds as provided herein (the "Fourth Supplement to Base Town Lease"), with the Town pursuant to which, among other things (i) the Corporation will extend the lease of the Existing Leased Property (as such term is defined in the Fourth Supplement to Base Town Lease) to the Town, lease back certain real property (the "Cortaro Silverbell Park Property") ground leased by the Town pursuant thereto and lease the Sixth Project to the Town and (ii) the Town shall (A) ground lease the Cortaro Silverbell Park Property to the Corporation and lease the same back from the Corporation, extend the lease of the Existing Leased Property from the Corporation and lease the Sixth Project from the Corporation and (B) as agent for the Corporation, agree to design, acquire, construct and equip, as the case may be, the Sixth Project and provide for matters related to the Third Refunding; and WHEREAS, the Series 2008 Bonds shall be secured by the Indenture, as supplemented by a Series 2008 Supplemental Trust Indenture, to be dated as of the first day of the month established as the dated date of the Series 2008 Bonds as provided herein (the "Series 2008 Supplemental Indenture"), from the Corporation to the Trustee; and WHEREAS, the Corporation has not made and does not intend to make any profit by reason of any business or venture in which it may engage or by reason of the assistance it renders the Town in financing the Sixth Project and the Third Refunding, and no part of the net earnings of the Corporation, if any, shall ever inure to the benefit of any person, firm or corporation except the Town; and WHEREAS, the Corporation is authorized and empowered, among other things (1) to issue its special obligation bonds for the purposes of assisting the Town in acquiring, constructing and equipping municipal improvements and otherwise incurring expenses to improve the use of municipal facilities, or the refinancing thereof, (2) to enter into leases and other necessary documents and to provide for rental payments sufficient to pay the principal of, premium, if any, and interest on such bonds, (3) to secure such bonds as provided for herein and (4) to adopt this Resolution and enter into the Fourth Supplement to Base Town Lease and the Series 2008 Supplemental Indenture upon the terms and conditions provided herein and therein; and 328191164x1 4/23/2008 WHEREAS, there have been placed on file with the Secretary of the Corporation and presented at the meeting at which this Resolution was adopted (1) the proposed form of the Series 2008 Supplemental Indenture, (2) the proposed form of the Fourth Supplement to Base Town Lease, (3) the proposed form of the Escrow Trust Agreement, to be dated as of the first day of the month established as the dated date of the Series 2008 Bonds as provided herein (the "Escrow Trust Agreement" and with the Series 2008 Supplemental Trust Indenture and the Fourth Supplement to Base Town Lease the "Basic Documents"), by and between the Corporation and Wells Fargo Bank, National Association, as escrow trustee (the "Escrow Trustee"), (4) the proposed form of the Bond Purchase Contract, to be dated the date of the sale of the Series 2008 Bonds (the "Purchase Contract"), by and between the Corporation and Stone & Youngberg LLC (the "Purchaser") for the purchase of the Series 2008 Bonds and (5) the pro- posed form of the Preliminary Official Statement, to be dated the date of the mailing thereof (the "Preliminary Official Statement"), relating to the Series 2008 Bonds, which, with certain additions thereto, shall constitute the Official Statement, to be dated the date of the sale of the Series 2008 Bonds (the "Official Statement"), relating to the Series 2008 Bonds; NOW, THEREFORE, BE IT RESOLVED BY THE BOARD OF DIRECTORS OF TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION THAT: Section 1. All actions (not inconsistent with the provisions of this Resolution) heretofore taken by or at the direction of the Corporation and its officers directed toward the approval and authorization of the sale and issuance of the Series 2008 Bonds are hereby approved and ratified. Section 2. It is hereby determined that (i) the Corporation was formed to assist the Town in financing its capital improvement projects at no profit to the Corporation; (ii) the Town desires to finance the Sixth Project and to refinance the Bonds Being Refunded by the issuance of the Series 2008 Bonds; (iii) the Town shall extend the lease from the Corporation of the Existing Leased Property and lease from the Corporation the Cortaro Silverbell Park Property and the Sixth Project pursuant to the Fourth Supplement to Base Town Lease; (iv) the Corporation has not and shall not make any profit by reason of the assistance it renders the Town in connection with the issuance of the Series 2008 Bonds and (v) the Corporation is authorized by law and .deems it necessary to borrow money for purposes of carrying out its obligations pursuant to the Fourth Supplement to Base Town Lease by issuing the Series 2008 Bonds and to secure the payment of the principal of and premium, if any, and interest on the Series 2008 Bonds and the performance of the covenants and conditions contained in the Basic Documents. Section 3. (A) The Series 2008 Bonds are hereby authorized to be sold and issued as an issue of special obligation bonds to be designated "Town of Marana Municipal Property Corporation Municipal Facilities Revenue fonds, Series 2008" and composed of two series: the Series 2008A Bonds to be designated "Municipal Facilities Revenue Bonds, Series 2008A" and the Series 2008B Bonds to be designated "Municipal Facilities Revenue Bonds, Series 2008B"; shall be issued in the aggregate principal amount of not to exceed $40,000,000; shall be in the denomination of $5,000 of principal amount or any integral multiple thereof and shall be fully registered bonds without coupons as provided in the Series 2008 Supplemental Indenture. (B) The Manager of the Town and, in his absence, the Finance Director of the Town are hereby authorized to determine on behalf of the Town and the Corporation the date the Series 2008 Bonds are to be sold to the Purchaser; the total aggregate principal amount of the Series 2008 Bonds which are to be issued (but not in excess of the amount indicated hereinabove) and how much will be the Series 2008A Bonds and be the Series 2008B Bonds; the date the Series 2008 Bonds are to be dated; the dates on which interest on the Series 2008 Bonds is to be payable; the rates per annum the Series 2008 Bonds are to bear; the 3 28191164v 1 4/23 /2008 5 dates the Series 2008 Bonds are to mature, the principal amounts to mature on such dates and the provisions for redemption of the Series 2008 Bonds in advance of such dates; the series designations, maturity dates and principal amounts of the Bonds Being Refunded and the determination of exercise of redemption provisions with respect to the Bonds Being Refunded; the terms upon which the Series 2008 Bonds are to be sold to the Purchaser (including determin- ations of price, original issue discount and premium and underwriting compensation); and the provisions pursuant to which the Series 2008 Bonds are to be credit enhanced (including determinations with respect to bond insurance and any surety bond or other instrument replacing the need for depositing cash to the reserve fund for the Series 2008 Bonds); provided, however, that the foregoing determinations shall not result in the yield on the Series 2008 Bonds, calculated for federal income tax purposes, exceeding six and one half percent (6.5%). (C) The form, terms and provisions of the Series 2008 Bonds and the provisions for the signatures, authentication, payment, registration, transfer, exchange and number shall be as set forth in the Series 2008 Supplemental Indenture and are hereby approved. Section 4. The form, terms and provisions of the Series 2008 Bonds, in the form contained in the Series 2008 Supplemental Indenture, be and they hereby are approved, with only such changes therein as are not inconsistent herewith and as are approved by the officers authorized to execute the Series 2008 Bonds, and each is hereby authorized to deliver the Series 2008 Bonds. The signatures of the President and the Secretary on the Series 2008 Bonds maybe by facsimile. Section 5. The forms, terms and provisions of the Basic Documents and the Purchase Contract, in substantially the forms of such documents (including the exhibits thereto) presented at the meeting at which this Resolution was adopted, are hereby approved, with such insertions, deletions and changes as are not inconsistent herewith and as are approved by the officers authorized to execute the documents (which approval will be conclusively demonstrated by their execution thereof), and the President or, in the absence thereof, Vice President and Secretary are hereby authorized to execute and deliver the Basic Documents and the Purchase Contract as well as any other documents necessary in connection therewith to provide for the issuance of the Series 2008 Bonds including any financial guaranty or related agreement necessary with respect to credit enhancement for the Series 2008 Bonds. Section 6. The Series 2008 Bonds shall be sold to the Purchaser in accordance with the terms of the Purchase Contract as such terms are to be determined as provided herein. Section 7. The President or, in the absence thereof, Vice President or Secretary is authorized to execute and deliver to the Trustee the written order of the Corporation for the authentication and delivery of the Series 2008 Bonds by the Trustee. Section 8. Upon the delivery of the Series 2008 Bonds, the proceeds of the Series 2008 Bonds shall be deposited as provided in the Series 2008 Supplemental Indenture. Section 9. The officers. of the Corporation shall take all action necessary or reasonably required to carry out, give effect to and consummate the transactions contemplated thereby, including without limitation the execution and delivery of the closing and other documents required to be delivered in connection with the sale and delivery of the Series 2008 Bonds. Section 10. The Preliminary Official Statement is hereby approved and confirmed, and the use of the Preliminary Official Statement and the Official Statement in 328191164v 1 4/23/2008 6 connection with the sale of the Bonds is hereby approved. The President or, in the absence thereof, Vice President is hereby authorized to execute the Official Statement. Section 11. The Series 2008 Bonds shall be special obligations of the Corporation payable solely from rental payments to be made by the Town pursuant to the Fourth Supplement to Base Town Lease. Nothing contained in this Resolution, the Basic Documents or any other instrument shall be construed as obligating the Town except to the extent provided therein or as incurring a charge upon the general credit of the Town nor shall the breach of any agreement contained in this Resolution, the Basic Documents or any other documents or instruments executed in connection therewith impose any charge upon the general credit of the Town. Section 12. Wells Fargo Bank, National Association, Phoenix, Arizona, is hereby confirmed as the Trustee as well as the Registrar and the Paying Agent (as such terms are defined in the Series 2008 Supplemental Indenture) pursuant to and for purposes of the Series 2008 Supplemental Indenture and as the Escrow Trustee pursuant to and for the purposes of the Escrow Trust Agreement. Section 13. After any of the Series 2008 Bonds are delivered by the Trustee to the Purchaser upon receipt of payment therefor, this Resolution shall be and remain irrepealable until the Series 1997 Bonds, the Series 2000 Bonds and the Series 2008 Bonds and the interest thereon shall have been fully paid, cancelled and discharged. Section 14. If any section, paragraph, clause or provision of this Resolution shall for any reason be held to be invalid or unenforceable, the invalidity or unenforceability of such section, paragraph, clause or provision shall not affect any of the remaining provisions of this Resolution. Section 15. Any provisions of any bylaws, orders, procedural pamphlets and resolutions inconsistent herewith are hereby waived to the extent only of such inconsistency. This waiver shall not be construed as reviving any bylaw, order, procedural pamphlet or resolu- tion or any part thereof. Section 16. It is hereby found and determined that all formal actions of the Corporation and its Board of Directors concerning and relating to the adoption of this Resolution were adopted in an open meeting and that all deliberations that resulted in those formal actions were in meetings open to the public, in compliance with all legal requirements of the State of Arizona and the Corporation. Section 17. This Resolution shall be effective immediately. ADOPTED AND APPROVED this 20th day of May, 2008. By President, Town of Marana Municipal Property Corporation ATTEST: Secretary, Town of Marana Municipal Property Corporation 328191164v 1 4/23/2008 SOURCES AND USES OF FUNDS Town of Marana, Arizona MPC Excise Tax Rev. & Refunding Bonds, Series 2008 Dated Date 07/01 /2008 Delivery Date 07/01/2008 Municipal Fac. MPC Excise Tax Rev. Refunding Revenue Bonds, Bonds, Series Sources: Series 2008 2008 Total Bond Proceeds: Par Amount 34,925,000.00 3,405,000.00 38,330,000.00 Premium 1,036,768.80 125,069.70 1,161,838.50 35,961,768.80 3,530,069.70 39,491,838.50 Municipal Fac. MPC Excise Tax Rev. Refunding Revenue Bonds, Bonds, Series Uses: Series 2008 2008 Total Project Fund Deposits: Construction Fund Refunding Escrow Deposits: Cash Deposit Delivery Date Expenses: Cost of Issuance Underwriter's Discount Bond Insurance @ 60 bps Other Uses of Funds: Additional Proceeds 1,408.10 2,033.60 3,441.70 35,961,768.80 3,530,069.70 39,491,838.50 35,000,000.00 35,000,000.00 3,439,050.00 3,439,050.00 273,349.85 26,650.15 300,000.00 349,250.00 34,050.00 383,300.00 337,760.85 28,285.95 366,046.80 960,360.70 88,986.10 1,049,346.80 May 13, 2008 11:53 am Prepared by Stone & Youngberg LLC Page 1 BOND DEBT SERVICE eriod Ending Town of Marana, Arizona MPC Excise Tax Rev. & Refunding Bonds, Series 2008 Dated Date 07/01/2008 Delivery Date 07/01/2008 Debt Principal Coupon Interest Service nnual Debt Service 01/01/2009 35,000 4.000% 906,925 941,925 07/01/2009 906,225 906,225 1,848,150 01/01/2010 110,000 4.000% 906,225 1,016,225 07/01/2010 110,000 4.000% 904,025 1,014,025 2,030,250 01/01/2011 760,000 4.000% 901,825 1,661,825 07/01/2011 765,000 4.000% 886,625 1,651,625 3,313,450 01/01/2012 795,000 4.000% 871,325 1,666,325 07/01/2012 790,000 4.000% 855,425 1,645,425 3,311,750 01/01/2013 815,000 4.000% 839,625 1,654,625 07/01/2013 810,000 4.000% 823,325 1,633,325 3,287,950 01/01/2014 840,000 4.000% 807,125 1,647,125 07/01/2014 850,000 4.000% 790,325 1,640,325 3,287,450 01/01/2015 880,000 4.000% 773,325 1,653,325 07/01/2015 875,000 4.000% 755,725 1,630,725 3,284,050 01/01/2016 910,000 4.000% 738,225 1,648,225 07/01/2016 920,000 4.000% 720,025 1,640,025 3,288,250 01/01/2017 950,000 5.000% 701,625 1,651,625 07/01/2017 950,000 5.000% 677,875 1,627,875 3,279,500 01/01/2018 1,000,000 5.000% 654,125 1,654,125 07/01/2018 1,000,000 5.000% 629,125 1,629,125 3,283,250 01/01/2019 1,055,000 5.000% 604,125 1,659,125 07/01/2019 1,050,000 5.000% 577,750 1,627,750 3,286,875 01/01/2020 1,105,000 5.000% 551,500 1,656,500 07/01/2020 1,100,000 5.000% 523,875 1,623,875 3,280,375 01/01/2021 1,160,000 5.000% 496,375 1,656,375 07/01/2021 1,160,000 5.000% 467,375 1,627,375 3,283,750 01/01/2022 1,220,000 5.000% 438,375 1,658,375 07/01/2022 1,220,000 5.000% 407,875 1,627,875 3,286,250 01/01/2023 1,105,000 5.000% 377,375 1,482,375 07/01/2023 1,110,000 5.000% 349,750 1,459,750 2,942,125 01/01/2024 1,165,000 5.000% 322,000 1,487,000 07/01/2024 1,165,000 5.000% 292,875 1,457,875 2,944,875 01/01/2025 1,220,000 5.000% 263,750 1,483,750 07/01/2025 1,225,000 5.000% 233,250 1,458,250 2,942,000 01/01/2026 1,285,000 5.000% 202,625 1,487,625 07/01/2026 1,285,000 5.000% 170,500 1,455,500 2,943,125 01/01/2027 1,350,000 5.000% 138,375 1,488,375 07/01/2027 1,350,000 5.000% 104,625 1,454,625 2,943,000 01/01/2028 1,415,000 5.000% 70,875 1,485,875 07/01/2028 1,420,000 5.000% 35,500 1,455,500 2,941,375 38,330,000 22,677,800 61,007,800 61,007,800 May 13, 2008 11:53 am Prepared by Stone & Youngberg LLC Page 2 eriod Ending BOND DEBT SERVICE Town of Marana, Arizona MPC Excise Tax Revenue Bonds, Series 2008 Dated Date 07/01/2008 Delivery Date 07/01/2008 Debt Principal Coupon Interest Service nnual Debt Service 01/01/2009 830,075 830,075 07/01/2009 830,075 830,075 1,660,150 01/01/2010 830,075 830,075 07/01/2010 830,075 830,075 1,660,150 01/01/2011 645,000 4.000% 830,075 1,475,075 07/01/2011 650,000 4.000% 817,175 1,467,175 2,942,250 01/01/2012 675,000 4.000% 804,175 1,479,175 07/01/2012 675,000 4.000% 790,675 1,465,675 2,944,850 01/01/2013 705,000 4.000% 777,175 1,482,175 07/01/2013 700,000 4.000% 763,075 1,463,075 2,945,250 01/01/2014 725,000 4.000% 749,075 1,474,075 07/01/2014 735,000 4.000% 734,575 1,469,575 2,943,650 01/01/2015 760,000 4.000% 719,875 1,479,875 07/01/2015 760,000 4.000% 704,675 1,464,675 2,944,550 01/01/2016 785,000 4.000% 689,475 1,474,475 07/01/2016 795,000 4.000% 673,775 1,468,775 2,943,250 01/01/2017 820,000 5.000% 657,875 1,477,875 07/01/2017 825,000 5.000% 637,375 1,462,375 2,940,250 01/01/2018 865,000 5.000% 616,750 1,481,750 07/01/2018 865,000 5.000% 595,125 1,460,125 2,941,875 01/01/2019 910,000 5.000% 573,500 1,483,500 07/01/2019 910,000 5.000% 550,750 1,460,750 2,944,250 01/01/2020 955,000 5.000% 528,000 1,483,000 07/01/2020 955,000 5.000% 504,125 1,459,125 2,942,125 01/01/2021 1,000,000 5.000% 480,250 1,480,250 07/01/2021 1,005,000 5.000% 455,250 1,460,250 2,940,500 01/01/2022 1,055,000 5.000% 430,125 1,485,125 07/01/2022 1,055,000 5.000% 403,750 1,458,750 2,943,875 01/01/2023 1,105,000 5.000% 377,375 1,482,375 07/01/2023 1,110,000 5.000% 349,750 1,459,750 2,942,125 01/01/2024 1,165,000 5.000% 322,000 1,487,000 07/01/2024 1,165,000 5.000% 292,875 1,457,875 2,944,875 01/01/2025 1,220,000 5.000% 263,750 1,483,750 07/01/2025 1,225,000 5.000% 233,250 1,458,250 2,942,000 01/01/2026 1,285,000 5.000% 202,625 1,487,625 07/01/2026 1,285,000 5.000% 170,500 1,455,500 2,943,125 01/01/2027 1,350,000 5.000% 138,375 1,488,375 07/01/2027 1,350,000 5.000% 104,625 1,454,625 2,943,000 01/01/2028 1,415,000 5.000% 70,875 1,485,875 07/01/2028 1,420,000 5.000% 35,500 1,455,500 2,941,375 34,925,000 21,368,475 56,293,475 56,293,475 May 13, 2008 11:53 am Prepared by Stone & Youngberg LLC Page 3 BOND DEBT SERVICE Town of Marana, Arizona Municipal Fac. Rev. Refunding Bonds, Series 2008 Dated Date 07/01/2008 Delivery Date 07/01/2008 Annual Period Debt Debt Ending Principal Coupon Interest Service Service 01/01/2009 35,000 4.000% 76,850 111,850 07/01/2009 76,150 76,150 188,000 01/01/2010 110,000 4.000% 76,150 186,150 07/01/2010 110,000 4.000% 73,950 183,950 370,100 01/01/2011 115,000 4.000% 71,750 186,750 07/01/2011 115,000 4.000% 69,450 184,450 371,200 01/01/2012 120,000 4.000% 67,150 187,150 07/01/2012 115,000 4.000% 64,750 179,750 366,900 01/01/2013 110,000 4.000% 62,450 172,450 07/01/2013 110,000 4.000% 60,250 170,250 342,700 01/01/2014 115,000 4.000% 58,050 173,050 07/01/2014 115,000 4.000% 55,750 170,750 343,800 01/01/2015 120,000 4.000% 53,450 173,450 07/01/2015 115,000 4.000% 51,050 166,050 339,500 01/01/2016 125,000 4.000% 48,750 173,750 07/01/2016 125,000 4.000% 46,250 171,250 345,000 01/01/2017 130,000 5.000°/a 43,750 173,750 07/01/2017 125,000 5.000°/a 40,500 165,500 339,250 01/01/2018 135,000 5.000°/a 37,375 172,375 07/01/2018 135,000 5.000% 34,000 169,000 341,375 01/01/2019 145,000 5.000°/a 30,625 175,625 07/01/2019 140,000 5.000°/a 27,000 167,000 342,625 01/01/2020 150,000 5.000% 23,500 173,500 07/01/2020 145,000 5.000% 19,750 164,750 338,250 01/01/2021 160,000 5.000% 16,125 176,125 07/01/2021 155,000 5.000% 12,125 167,125 343,250 01/01/2022 165,000 5.000% 8,250 173,250 07/01/2022 165,000 5.000% 4,125 169,125 342,375 3,405,000 1,309,325 4,714,325 4,714,325 May 13, 2008 11:53 am Prepared by Stone & Youngberg LLC Page 4 BOND SUMMARY STATISTICS Town of Marana, Arizona MPC Excise Tax Rev. & Refunding Bonds, Series 2008 Dated Date 07/01/2008 Delivery Date 07/01/2008 Last Maturity 07/01/2028 Arbitrage Yield 4.605963% True Interest Cost (TIC) 4.738555% Net Interest Cost (NIC) 4.716035% All-In TIC 4.827146% Average Coupon 4.883694% Average Life (years) 12.115 Duration of Issue (years) 8.913 Par Amount 38,330,000.00 Bond Proceeds 39,491,838.50 Total Interest 22,677,800.00 Net Interest 21,899,261.50 Total Debt Service 61,007,800.00 Maximum Annual Debt Service 3,313,450.00 Average Annual Debt Service 3,050,390.00 Underwriter's Fees (per $1000) Average Takedown Other Fee 10.000000 Total Underwriter's Discount 10.000000 Bid Price 102.031147 Par Average Average PV of 1 by Bond Component Value Price Coupon Life change Serial Bond 38,330,000.00 103.031 4.884% 12.115 27,466.55 38,330,000.00 12.115 27,466.55 All-In Arbitrage TIC TIC Yield Par Value 38,330,000.00 38,330,000.00 38,330,000.00 + Accrued Interest + Premium (Discount) 1,161,838.50 1,161,838.50 1,161,838.50 - Underwriter's Discount -383,300.00 -383,300.00 - Cost of Issuance Expense -300,000.00 - Other Amounts -366,046.80 -366,046.80 -366,046.80 Target Value 38,742,491.70 38,442,491.70 39,125,791.70 Target Date 07/01/2008 07/01/2008 07/01/2008 Yield 4.738555% 4.827146% 4.605963% May 13, 2008 11:53 am Prepazed by Stone & Youngberg LLC Page 5 BOND PRICING Bond Component Serial Bond: Town of Marana, Arizona MPC Excise Tax Rev. & Refunding Bonds, Series 2008 Maturity Yield to Premium Date Amount Rate Yield Price Maturity (-Discount) 01/01/2009 35,000 4.000% 2.550% 100.715 250.25 07/01/2009 4.000% 2.550% .101.422 01/01/2010 110,000 4.000% 2.800% 101.750 1,925.00 07/01/2010 110,000 4.000% 2.800% 102.318 2,549.80 01/01/2011 760,000 4.000% 3.100% 102.149 16,332.40 07/01/2011 765,000 4.000% 3.100% 102.559 19,576.35 01/01/2012 795,000 4.000% 3.320% 102.229 17,720.55 07/01/2012 790,000 4.000% 3.320% 102.527 19,963.30 01/01/2013 815,000 4.000% 3.470% 102.190 17,848.50 07/01/2013 810,000 4.000% 3.470% 102.413 19,545.30 01/01/2014 840,000 4.000% 3.570% 102.130 17,892.00 07/01/2014 850,000 4.000% 3.570% 102.304 19,584.00 01/01/2015 880,000 4.000% 3.730% 101.545 13,596.00 07/01/2015 875,000 4.000% 3.730% 101.649 14,428.75 01/01/2016 910,000 4.000% 3.870% 100.839 7,634.90 07/01/2016 920,000 4.000% 3.870% 100.887 8,160.40 01/01/2017 950,000 5.000% 4.010% 107.071 67,174.50 07/01/2017 950,000 5.000% 4.010% 107.417 70,461.50 01/01/2018 1,000,000 5.000% 4.140% 106.698 66,980.00 07/01/2018 1,000,000 5.000% 4.140% 106.983 69,830.00 01/01/2019 1,055,000 5.000% 4.260% 105.974 C 4.287% 63,025.70 07/01/2019 1,050,000 5.000% 4.260% 105.974 C 4.312% 62,727.00 01/01/2020 1,105,000 5.000% 4.380% 104.977 C 4.443% 54,995.85 07/01/2020 1,100,000 5.000% 4.380% 104.977 C 4.460% 54,747.00 01/01/2021 1,160,000 5.000% 4.480% 104.154 C 4.560% 48,186.40 07/01/2021 1,160,000 5.000% 4.480% 104.154 C 4.573% 48,186.40 01/01/2022 1,220,000 5.000% 4.560% 103.501 C 4.648% 42,712.20 07/01/2022 1,220,000 5.000% 4.560% 103.501 C 4.657% 42,712.20 01/01/2023 1,105,000 5.000% 4.630% 102.935 C 4.718% 32,431.75 07/01/2023 1,110,000 5.000% 4.630% 102.935 C 4.725% 32,578.50 01/01/2024 1,t65,000 5.000% 4.690% 102.452 C 4.774% 28,565.80 07/01/2024 1,165,000 5.000% 4.690% 102.452 C 4.779% 28,565.80 01/01/2025 1,220,000 5.000% 4.740% 102.051 C 4.818% 25,022.20 07/01/2025 1,225,000 5.000% 4.740% 102.051 C 4.822% 25,124.75 01/01/2026 1,285,000 5.000% 4.790% 101.653 C 4.859% 21,241.05 07/01/2026 1,285,000 5.000% 4.790% 101.653 C 4.861% 21,241.05 01/01/2027 1,350,000 5.000% 4.840% 101.256 C 4.896% 16,956.00 07/01/2027 1,350,000 5.000% 4.840% 101.256 C 4.898% 16,956.00 01/01/2028 1,415,000 5.000% 4.890% 100.861 C 4.931% 12,183.15 07/01/2028 1,420,000 5.000% 4.890% 100.861 C 4.932% 12,226.20 38,330,000 1,161,838.50 May 13, 2008 11:53 am Prepared by Stone & Youngberg LLC Page 6 BOND PRICING Town of Marana, Arizona MPC Excise Tax Rev. & Refunding Bonds, Series 2008 Dated Date Delivery Date First Coupon Par Amount Premium 07/01/2008 07/01/2008 O 1 /01 /2009 38,330,000.00 1,161,838.50 Production 39,491,838.50 103.031147% Underwriter's Discount -383,300.00 -1.000000% Purchase Price Accmed Interest Net Proceeds 39,108,538.50 102.031147% 39,108,538.50 May 13, 2008 11:53 am Prepared by Stone & Youngberg LLC Page 7 SUMMARY OF BONDS REFUNDED Town of Marana, Arizona MPC Excise Tax Rev. & Refunding Bonds, Series 2008 Maturity Interest Par Call Bond Date Rate Amount Date Call Price Municipal Facilities Revenue Bonds, Series 1997: CALL_SER 07/01/2009 4.800% 110,000.00 07/01/2008 101.000 01/01/2010 4.900% 100,000.00 07/01/2008 101.000 07/01/2010 4.900% 105,000.00 07/01/2008 101.000 01/01/2011 5.000% 105,000.00 07/01/2008 101.000 07/01/2011 5.000% 110,000.00 07/01/2008 101.000 01/01/2012 5.100% 105,000.00 07/01/2008 101.000 07/01/2012 5.100% 115,000.00 07/01/2008 101.000 01/01/2013 5.100% 105,000.00 07/01/2008 101.000 07/01/2013 5.100% 105,000.00 07/01/2008 101.000 CALLTERM 07/01/2022 5.250% 2,445,000.00 07/01/2008 101.000 3,405,000.00 May 13, 2008 11:53 am Prepared by Stone & Youngberg LLC Page 8 SUMMARY OF REFUNDING RESULTS Town of Marana, Arizona MPC Excise Tax Rev. & Refunding Bonds, Series 2008 Dated Date 07/01/2008 Delivery Date 07/01/2008 Arbitrage yield 4.605963% Escrow yield Bond Par Amount 3,405,000.00 True Interest Cost 4.412146% Net Interest Cost 4.390685% Average Coupon 4.718713% Average Life 8.149 Par amount of refunded bonds 3,405,000.00 Average coupon of refunded bonds 5.228323% Average life of refunded bonds 8.093 PV of prior debt to 07/01/2008 @ 4.605963% 3,540,910.40 Net PV Savings 118,884.11 Percentage savings of refunded bonds 3.491457% May 13, 2008 11:53 am Prepared by Stone & Youngberg LLC Page 9 SAVINGS ate Town of Marana, Arizona MPC Excise Tax Rev. & Refunding Bonds, Series 2008 Prior Refunding Annual Debt Service Debt Service Savings Savings Present Value to 07/01/2008 @ 4.6059629°/a 01/01/2009 88,183.75 111,850.00 -23,666.25 -23,133.49 07/01/2009 198,183.75 76,150.00 122,033.75 98,367.50 116,601.30 01/01/2010 185,543.75 186,150.00 -606.25 -566.22 07/01/2010 188,093.75 183,950.00 4,143.75 3,537.50 3,783.04 01/01/2011 185,521.25 186,750.00 -1,228.75 -1,096.53 07/01/2011 187,896.25 184,450.00 3,446.25 2,217.50 3,006.19 01/01/2012 180,146.25 187,150.00 -7,003.75 -5,971.90 07/01/2012 187,468.75 179,750.00 7,718.75 715.00 6,433.40 01/01/2013 174,536.25 172,450.00 2,086.25 1,699.70 07/01/2013 171,858.75 170,250.00 1,608.75 3,695.00 1,281.17 O1 /01 /2014 174,181.25 173,050.00 1,131.25 880.62 07/01/2014 171,293.75 170,750.00 543.75 1,675.00 413.75 01/01/2015 173,406.25 173,450.00 -43.75 -32.54 07/01/2015 170,387.50 166,050.00 4,337.50 4,293.75 3,153.58 01/01/2016 172,368.75 173,750.00 -1,381.25 -981.63 07/01/2016 174,218.75 171,250.00 2,968.75 1,587.50 2,062.34 01/01/2017 170,937.50 173,750.00 -2,812.50 -1,909.82 07/01/2017 172,656.25 165,500.00 7,156.25 4,343.75 4,750.03 01 /O1 /2018 174,243.75 172,375.00 1,868.75 1,212.48 07/01/2018 170,700.00 169,000.00 1,700.00 3,568.75 1,078.16 01/01/2019 172,156.25 175,625.00 -3,468.75 -2,150.40 07/01/2019 173,481.25 167,000.00 6,481.25 3,012.50 3,927.50 01/01/2020 169,675.00 173,500.00 -3,825.00 -2,265.69 07/01/2020 170,868.75 164,750.00 6,118.75 2,293.75 3,542.78 01/01/2021 171,931.25 176,125.00 -4,193.75 -2,373.53 07/01/2021 172,862.50 167,125.00 5,737.50 1,543.75 3,174.15 01/01/2022 173,662.50 173,250.00 412.50 223.07 07/01/2022 169,331.25 169,125.00 206.25 618.75 109.02 4,845,795.00 4,714,325.00 131,470.00 131,470.00 116,850.51 Savings Summary PV of savings from cash flow Plus: Refunding funds on hand Net PV Savings 116,850.51 2,033.60 118,884.11 May 13, 2008 11:53 am Prepared by Stone & Youngberg LLC Page 10 DRAFT 04/24/08 05/13/08 After recordation, please return to: Michael Cafiso, Esq. Suite 700 2375 East Camelback Road Phoenix, Arizona 85016 COMBINED CORTARO SILVERBELL DISTRICT PARK GROUND LEASE AND FOURTH SUPPLEMENT TO AMENDED AND RESTATED TOWN LEASE AND SERIES 1992 TOWN LEASE TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION, as Lessor, TO TOWN OF MARANA, ARIZONA, as Lessee This COMBINED CORTARO SILVERBELL DISTRICT PARK GROUND LEASE AND FOURTH SUPPLEMENT TO AMENDED AND RESTATED TOWN LEASE AND SERIES 1992 TOWN LEASE, dated as of 1, 2008 (this "Series 2008 Town Lease), by and between TOWN OF MARANA MUNICIPAL PROPERTY CORPORA- TION, a nonprofit corporation incorporated and existing under the laws of the State of Arizona (the "Corporation"), and the TOWN OF MARANA, ARIZONA, a municipal corporation of the State of Arizona (the "Town"); W I T N E S S E T H: WHEREAS, the Corporation was formed to transact any or all lawful business for which nonprofit corporations may be incorporated under the laws of the State of Arizona, including, without limiting the generality of the foregoing, any civic or charitable purpose such as financing the cost of acquiring, constructing, reconstructing or improving buildings, equipment or 'other real and personal properties suitable for use by and for leasing to the Town or its agencies or instrumentalities; and WHEREAS, the Town heretofore determined that it was benefi- cial to its citizens (i) to acquire the water system owned by Clifford Ray Honea and Ethel Wynema Honea, husband and wife, doing business as Honea Water Company (the "First Water System"), consisting of the real property described on Exhibit A attached to the Amended and Restated Town Lease and Series 1992 Town Lease, dated as of October 1, 1997, as amended by the First Amendment to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of January 1, 2000, the Combined Operations Center Property Ground Lease and Second Amendment to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of April 1, 2002 (the "Second Amendment to Base Town Lease"), and the Third Amendment to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of September 1, 2003 (the "Third Amendment to Base Town Lease") and supplemented by the First Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of February 1, 2000 (the "First Supplement to Base Town Lease"), the Second Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of September 1, 2003, and the Third Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of 1, 2008 (such Amended and Restated Town Lease and Series 1992 Town Lease as so amended and supplemented, the "Base Town Lease"), by and between the Town and the Corporation (the "First Water System Real Property") and certain personal property (the "Initial First Water System Improvements") with respect to the First Water System and (ii) to acquire the facility then being used as the municipal complex for the Town (the "Municipal Complex"), consisting of the real property described on Exhibit B attached to the Base Town Lease (the "Municipal Complex Real Property") and to make certain necessary improvements to the First Water System (the "New First Water System Improvements" and collectively, with the Initial First Water System Improvements, the "First Water System Improvements" and the acquisition of the First Water System, the acquisition of the Municipal Complex and the making of the New First Water System Improvements, collectively, the "First Project"); and WHEREAS, the Corporation assisted the Town in financing the First Project; and WHEREAS, in order to finance the costs of the First Project, the Corporation issued its $280,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 1990, dated as of March 1, 1990, and its $315,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 1992, dated as of June 1, 1992 (collectively, the "Outstanding Bonds"); and WHEREAS, the Town further heretofore determined that it was beneficial to its citizens (i) to refinance the Outstanding Bonds and (ii) (A) to acquire the water systems known as "Cortaro Marana" and 2 "Marana -Water Service" (collectively, the "Second Water Systems"), consisting of the real property described in Exhibit C to the Base Town Lease (the "Second Water Systems Real Property") and certain personal property (the "Second Water Systems Improvements" and collectively, with the First Water System Improvements, the "Water System Improvements") with respect to the Second Water Systems and (B) to (I) make certain improvements to the Water System Improvements, (II) make certain road and related improvements and construct improvements to increase traffic capacity on certain other roads, (III) acquire the real property upon which to construct a new municipal complex described in Exhibit D to the Base Town Lease (the "Town Hall Property") and (IV) make tenant improvements to certain office space leased to the Town (the "Tenant Improvements"), the property described in clauses (B)(I), (II) and (IV) being as described on Exhibit E attached to the Base Town Lease and collectively with the acquisition of the Second Water Systems, the Town Hall Property, the Tenant Improvement and the project described in clause (B)(II) being referred to herein as the "Second Project"; and WHEREAS, the Corporation assisted the Town in refinancing the Outstanding Bonds and in financing the Second Project; and WHEREAS, in order to refinance the Outstanding Bonds and to finance the costs of the Second Project, the Corporation issued its $8,175,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 1997, dated as of October 1, 1997 (the "Series 1997 Bonds"); and WHEREAS, the Town also heretofore determined that it was beneficial to its citizens to design, acquire, construct and equip the new municipal complex on the Town Hall Property (the "Third Project"); provided, however, that pursuant to (i) the Second Amendment to Base Town Lease certain additional property (the "Operations Center Prop- erty") has been ground leased by the Town to the Corporation and leased back by the Corporation to the Town, the Operations Center Property thereafter being considered part of the Town Hall Property for all purposes of the First Supplement to the Base Town Lease, and certain changes have been made to the description of the "Town Hall Improvements" to include a town operations center to house public works, police, water, vehicle asset management and information systems and (ii) the Third Amendment to Base Town Lease a portion of the Operations Center Property has been released from the provisions of the First Supplement to Base Town Lease and another parcel of property donated to the Corporation added as part of the Town Hall Property for all purposes of the First Supplement to Base Town Lease; and WHEREAS, the Corporation assisted the Town in financing the Third Project; and WHEREAS, in order to finance the costs of the Third Project, the Corporation issued its $10,000,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal 3 Facilities Revenue Bonds, Series 2000, dated as of February 1, 2000, all of which have been now paid or defeased; and WHEREAS, the Town also heretofore determined that it was beneficial to its citizens to design, acquire, construct and equip, as the case may be, additional parts (the "Additional Town Hall Improvements") of the new municipal complex on the Town Hall Property (the "Fourth Project"); and WHEREAS, the Corporation assisted the Town in financing the Fourth Project; and WHEREAS, in order to finance the costs of the Fourth Proj- ect, the Corporation issued its $19,700,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2003, dated as of September 1, 2003 (the "Series 2003 Bonds"); and WHEREAS, the Town also heretofore determined that it was beneficial to its citizens to design, acquire, construct and equip, as the case may be, final parts of the new municipal complex (the "Final Town Hall Improvements") on the Town Hall Property (the "Fifth Project") and to refinance a portion of the bonds heretofore issued by the Corporation (the "Bonds Being Refunded"); and WHEREAS, the Corporation assisted the Town in financing the Fifth Project and refinancing the Bonds Being Refunded (the "Second Refunding"); and WHEREAS, in order to finance the costs of the Fifth Project and the Second Refunding, the Corporation issued its $8,675,000 aggre- gate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2004, dated as of August 1, 2004 (the "Series 2004 Bonds"); and WHEREAS, the Town has now determined that it will be beneficial to its citizens to design, acquire, construct and equip, as the case may be, extensions and additions to the sewer lines and interceptors in Silverbell Road and to the Town's Airport, extensions and improvements to Camino de Marana and Dove Mountain Roads and improvements to Cortaro Silverbell District Park as well as other sewer, .transportation and park projects as described in Exhibit B attached hereto (the "Sixth Project") and to refinance a portion of the bonds heretofore issued by the Corporation (the "Bonds Being Refunded"); and WHEREAS, the Corporation desires to assist the Town in financing the Sixth Project and refinancing the Bonds Being Refunded (the "Third Refinancing"); and WHEREAS, in order to finance the costs of the Sixth Project and the Third Refunding, the Corporation and the Town deem it neces- sary and desirable for the Corporation to sell and issue its $ ,000 4 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2008, dated 1, 2008 (the "Series 2008 Bonds"); and WHEREAS, in connection with the issuance of the Series 2008 Bonds, the Corporation shall enter into this Series 2008 Town Lease with the Town pursuant to which (A) the Corporation will extend the lease of the First Water System Real Property, the Municipal Complex Real Property, the First Water System Improvements, the Second Water System Real Property, the Second Water System Improvements, the Town Hall Property, the Town Hall Improvements, the Additional Town Hall Improvements and the Final Town Hall Improvements described on Exhibit A hereto and the Operations Center Property described in the Second Amendment to Base Town Lease (collectively, the "Existing Leased Property") to the Town, lease back the real property described in Exhibit A hereto as "Cortaro Silverbell Park Property" ground leased by the Town to the Corporation pursuant hereto and lease the Sixth Project to the Town and (B) the Town shall (I) ground lease the Cortaro Silverbell Park Property to the Corporation and lease the same back from the Corporation, extend the lease of the Existing Leased Property from the Corporation and lease the Sixth Project from the Corporation (collectively with the Existing Leased Property and the Cortaro Silverbell Park Property, the "Leased Property") and (II) as agent for the Corporation, agree to design, acquire, construct and equip, as the case may be, the Sixth Project and provide for matters related to the Third Refunding; and WHEREAS, the Series 1997 Bonds, the Series 2003 Bonds, the Series 2004 Bonds, the Series 2008 Bonds and any additional obligations issued on a parity of lien therewith shall be secured by a Trust Indenture, dated as of October 1, 1997 (as supplemented, the "Indenture"), from the Corporation to Wells Fargo Bank, National Association (formerly Norwest Bank Arizona, N.A. and Wells Fargo Bank Arizona, N.A.), as trustee (the "Trustee"), as supplemented by the Series 2000 Supplemental Trust Indenture, dated as of February 1, 2000, a Series 2003 Supplemental Trust Indenture, dated as of September 1, 2003, a Series 2004 Supplemental Trust Indenture, dated as of August 1, 2004, and a Series 2008 Supplemental Trust Indenture, dated as of 1, 2008 (the "Series 2008 Supplemental Indenture"), from the Corporation to the Trustee; and WHEREAS, the Series 2008 Bonds shall be secured by this Series 2008 Town Lease pursuant to which the Town shall pledge Town sales tax, state-shared revenues, license and permit fees and fines and forfeitures as security for the payment of rentals coming due hereunder; and WHEREAS, pursuant to a Guaranty Agreement, dated as of 1, 2008 (the "Series 2008 Guaranty Agreement"), by and between the Corporation and (the "Series 2008 Insurer"), the Series 2008 Insurer has agreed to provide a "Surety Bond"[???] with respect to the Series 2008 Bonds in lieu of depositing amounts to a reserve fund. for the Series 2008 Bonds; and 5 WHEREAS, the Corporation has not made and does not intend to make any profit by reason of any business or venture in which it may engage or by reason of the assistance it renders the Town in financing the Fifth Project and the Second Refunding, and no part of the net earnings of the Corporation, if any, shall ever inure to the benefit of any person, firm or corporation, except the Town; NOW THEREFORE, PURSUANT TO LAW AND FOR AND IN CONSIDERATION OF THE MUTUAL COVENANTS HEREINAFTER CONTAINED, IT IS HEREBY AGREED AS FOLLOWS AS A SUPPLEMENT TO THE BASE TOWN LEASE: ARTICLE I GROUND LEASE; TERMS; RENT; DESIGN, ACQUISITION, CONSTRUCTION AND EQUIPPING OF THE SIXTH PROJECT Section 1.01. (A) The following shall be referred to herein as the "Ground Lease Provisions": (1) For the term commencing with the date hereof and continuing until July 2, 20 or such earlier or later date as of which this Series 2008 Town Lease shall be terminated, the Town hereby leases to the Corporation, and the Corporation hereby leases from the Town, the Cortaro Silverbell Park Property. (2) The Corporation has paid to the Town as rental for the Cortaro Silverbell Park Property $100 for the entire term, together with other good and valuable consideration as provided herein, and said rental was paid upon the execution and delivery of this Series 2008 City Lease. (3) The Corporation, as of the date hereof, assigns all rights and benefits arising from the Ground Lease Provisions to the Trustee and shall grant the Trustee a lien on its interest in the Ground Lease Provisions for the benefit of the holders of the Series 2008 Bonds. The Town hereby consents to such assignment and grant of lien. The Trustee shall have no obligations hereunder except as otherwise provided in the Indenture. (4) Notwithstanding this Series 2008 Town Lease, the Town, so long as no event of default by the Town under this Series 2008 Town Lease shall have occurred and be continuing, shall at all times have and retain such rights of access 6 and control of the Cortaro Silverbell Park Property. (5) The Town shall have the right to terminate the Ground Lease Provisions upon written notice to the Corporation given concurrently with or subsequent to the date the lien granted to the Trustee is released of record as a result of the payment of or provision for the entire indebtedness secured by said lien, as provided in the Indenture. The Corporation shall not at any time increase the amount of its indebtedness secured by the said lien except (1) to the extent it may be necessary in connection with any refinancing or refunding which, by reason of a default by the Town in the payment of lease payments due under this Series 2008 Town Lease, may then be required for the Corporation to meet its obligations to the then holders of indebtedness secured by the said lien, or (2) in accordance with this Series 2008 Town Lease, relating to additional financing or for refunding bonds issued for such purposes. So long as this Series 2008 Town Lease has not been terminated, the Town shall have no right to terminate the Ground Lease Provisions for any reason except the nonpayment of the lease payments required to be paid under the provisions of Section 2 hereof. (6) Upon the expiration or termination of the Ground Lease Provisions, the Corporation shall surrender to the Town the Cortaro Silverbell Park Property together with any improvements thereon. At the time of such surrender, the Cortaro Silverbell Park Property shall be free and clear of all liens and encumbrances other than (a) conditions, reservations, exceptions, rights of way and easements of record on the date of the commencement of the term of this Series 2008 Town Lease, or (b) liens or encumbrances imposed as a result of an act or failure to act by the Town. (B) For the term commencing with the date hereof and continuing until July 2, 20 or such later date as of which the Series 2008 Bonds are deemed paid and discharged pursuant to the Indenture, the Town hereby extends the lease to the Corporation, and the Corporation hereby continues the lease from the Corporation, of the Existing Leased Property, and the Corporation hereby leases to the Town, and the Town hereby leases from the Corporation, the Cortaro Silverbell Park Property and the Sixth Project. No merger of title or estates is intended by the Ground Lease Provisions and this Subsection. 7 Section 1.02. The Town shall have the right to terminate this Series 2008 Town Lease on written notice to the Corporation given concurrently with, or subsequent to, the date the Series 2008 Supplemental Indenture is released of record as a result of the payment or provision for payment of the entire indebtedness secured hereby as provided in the Indenture and any supplements thereto. Upon such termination, all rights of the Corporation in and to the Leased Property shall cease, and the Corporation, by appropriate instruments of conveyance, shall, without further consideration, convey the Leased Property to the Town. Section 1.03. As rental payments, the Town shall pay to the Corporation (i) on July 1 and January 1 of each year commencing on 1, 200 an amount equal to the amount which when added to the balance then in the Interest Fund established pursuant to the Indenture shall be equal to interest due on the Series 2008 Bonds on the next interest payment date; (ii) on July 1 and January 1 of each year commencing on 1, 200_, an amount equal to the amount which when added to the balance then in the Bond Retirement Fund established pursuant to the Indenture shall be equal to the principal due on the Series 2008 Bonds on the next principal payment date; (iii) monthly, commencing on the first (1st) day of the month following a payment made from the Reserve Fund established pursuant to the Indenture, an amount equal to the amount required to restore the Reserve Fund established pursuant to the Indenture to an amount equal to the amount equal to the Reserve Requirement (as defined in the Indenture) with respect to the Series 2008 Bonds or, if the Series 2008 Guaranty Agreement is in effect and the Series 2008 Insurer is not in default thereunder, instead for payment of one-twelfth (1/12th) of the amount required to reimburse the Series 2008 Insurer for any interest owed by the Corporation to the Series 2008 Insurer for payments made by the Series 2008 Insurer pursuant to the Series 2008 Surety Bond (as defined in the Series 2008 Supplemental Indenture) and for any other money owed by the Corporation to the Series 2008 Insurer pursuant to the Series 2008 Guaranty Agreement and (iv) when due, all other amounts required to be paid by the Corporation or the Town to the Trustee pursuant to the Indenture. Such rental payments shall be paid for and in consideration of the use and occupancy of the Leased Property which the Town receives and in consideration of the continued quiet use and enjoyment thereof as provided in Section 4.01 hereof. The obligation of the Town for such rental payments shall be co- extensive with the debt service with respect to the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds and the Series 2008 Bonds as well as the payments to MBIA Insurance Corporation (the "Series 1997 Insurer") pursuant to the Guaranty Agreement, dated as of October 1, 1997 (the "Series 1997 Guaranty Agreement"), by and between the Corporation and the Series 1997 Insurer, to Ambac Assurance Corporation (the "Series 2000 Insurer") pursuant to the Guaranty Agreement, dated as of February 1, 2000 (the "Series 2000 Guaranty Agreement"), by and between the Corporation and the Series 2000 Insurer, to Ambac Assurance Corporation (the "Series 2003 Insurer") pursuant to the Guaranty Agreement, dated as of September 1, 2003 (the "Series 2003 Guaranty Agreement"), to Ambac 8 Assurance Corporation (the "Series 2004 Insurer") pursuant to the Guaranty Agreement, dated as of August 1, 2004 (the "Series 2004 Guaranty Agreement"), and the Series 2008 Insurer pursuant to the Series 2008 Guaranty Agreement and, when the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds, the Series 2008 Bonds and other obligations secured under the Indenture as well as the payments to the Series 1997 Insurer pursuant to the Series 1997 Guaranty Agreement, the Series 2000 Insurer pursuant to the Series 2000 Guaranty Agreement, the Series 2003 Insurer pursuant to the Series 2003 Guaranty Agreement, the Series 2004 Insurer pursuant to the Series 2004 Guaranty Agreement and the Series 2008 Insurer pur- suant to the Series 2008 Guaranty Agreement have been fully paid or provided for, the Town shall, except for the obligation of the Town to make payments to the Trustee pursuant to provisions of the Indenture, have no further obligation to make rental payments hereunder. Section 1.04. As additional rental payments, the Town shall pay (i) all amounts required to be paid to the United States of America pursuant to Section 148 (f) of the Internal Revenue Code of 1986, as amended (the "Code"), with respect to the Series 2008 Bonds and the investment of the proceeds thereof as provided in Section 10.01 hereof, (ii) all fees and expenses of the Trustee and the registrars and paying agents under the Series 2008 Supplemental Indenture, (iii) the reasonable expenses of the Corporation necessary with respect to clause (i) or approved by the Town and not otherwise required to be paid by the Town under the terms hereof, (iv) losses on investments made by the Trustee at the direction of the Town under the terms of the Indenture, but only to the extent necessary to meet the debt service on the Series 2008 Bonds and to pay any other amounts required to be paid by the Corporation or the Town under the Indenture, (v) fees for maintaining the corporate existence of the Corporation and all costs, expenses, losses or damages, including reasonable attorneys' fees, pertaining to any claim or legal action brought against the Trustee or the Corporation with respect to the legality of any defect in this Series 2008 Town Lease, the Indenture, the Series 2008 Guaranty Agreement or the Series 2008 Bonds, or questioning the legality of any action taken or to be taken pursuant thereto and (vi) all other expenses of the Corporation incurred at the written request of the Town or the Trustee in accordance with the provisions of this Series 2008 Town Lease, the Indenture or the Series 2008 Guaranty Agreement. The Town shall pay the amounts specified in clause (i) directly to the United States as required by the Code, in clause (ii) directly to the Trustee as they become due and within twenty (20) days after receipt by the Town of invoice therefor, except as otherwise provided in the Indenture, in clause (iii) to either the Corporation or its creditors, upon evidence that the expenses or fees have been incurred by it, and within twenty (20) days after receipt by the Town of invoice therefor, in clause (iv) to the Trustee, in clause (v) to the Trustee or the Corporation, as appropriate, upon evidence that such costs, expenses, losses or damages have been incurred and in clause (vi) to the Corporation, upon evidence that such expenses have been incurred. 9 Section 1.05. Such rental payments, as well as any other money required to be expended by the Town pursuant to the provisions of this Series 2008 Town Lease, shall be payable solely from sources referred to in Article III hereof and shall under no circumstances constitute a general obligation of the Town or be payable from the proceeds of ad valorem taxes. Section 1.06. Amounts payable hereunder shall be paid in lawful money of the United States of America to or upon the order of the Corporation and at such place as the Corporation may designate in writing. Any rental payments accruing hereunder which shall not be paid within five (5) days after its due date shall bear interest at the highest rate permitted by law, but not exceeding twelve percent (12%) per annum, from the date when the same is due hereunder until the same shall be paid. Section 1.07. Notwithstanding the provisions of Section 1.06 hereof, all rental payments for debt service on the Series 2008 Bonds and for payments to the Series 2008 Insurer pursuant to the Series 2008 Guaranty Agreement as well as additional rental payments payable to the Trustee under Section 1.04 hereof shall be paid at the principal corporate trust office of the Trustee. The Corporation shall cause the Trustee to apply such rental payments made in the manner and for the purposes expressed in the Indenture. Section 1.08. Unless otherwise requested by the Town pursuant to Section 7.02 hereof, any money in the Revenue Fund established pursuant to the Indenture which, in the opinion of the Trustee, exceeds the amounts necessary for the current debt service on the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds and the Series 2008 Bonds then outstanding (including administrative costs and expenses) and for payments to the Series 1997 Insurer pursuant to the Series 1997 Guaranty Agreement, the Series 2000 Insurer pursuant to the Series 2000 Guaranty Agreement, the Series 2003 Insurer pursuant to the Series 2003 Guaranty Agreement, the Series 2004 Insurer pursuant to the Series 2004 Guaranty Agreement and the Series 2008 Insurer pursuant to the Series 2008 Guaranty Agreement shall, at least annually, so long as the Town is not in default hereunder, constitute a credit to the Town on the next succeeding rental payment or payments due or coming due hereunder and under the Base Town Lease. Likewise, earnings on the Revenue Fund established pursuant to the Indenture shall, at least annually, so long as the Town is not in default hereunder, constitute a credit to the Town on the next succeeding rental payment or payments due or coming due hereunder. Section 1.09. The Town, as agent to the Corporation, shall provide the Sixth Project pursuant to the plans and specifications of the Town prior to 1, 2010, with, and only with, proceeds of the sale of the Series 2008 Bonds available for such purpose. Other than such proceeds, the Corporation shall have no further obligation or additional duty to provide any other amounts for such purpose. 10 Section 1.10. [???] For purposes of Section 1.03(iii), the Series 2008 Insurer shall be reimbursed from legally available funds within the Series 2008 Reimbursement Period (as defined in the Series 2008 Guaranty Agreement) without demand or notice by the Series 2008 Insurer to the Corporation or any other person to the extent of each Series 2008 Surety Bond Payment (as defined in the Series 2008 Guaranty Agreement) with interest on each Series 2008 Surety Bond Payment from and including the date made to the date of the reimbursement by the Corporation at the lesser of the Series 2008 Reimbursement Rate (as defined in the Series 2008 Guaranty Agreement) or the maximum rate of interest permitted by then applicable law. The Corporation hereby acknowledges its obligation to make all payments required pursuant to the Series 2008 Guaranty Agreement to the Series 2008 Insurer. ARTICLE II TAXES, LIENS, UTILITIES, INSURANCE AND OTHER CHARGES Section 2.01. The rental payments payable pursuant to this Series 2008 Town Lease shall be an absolute net return to the Corporation, free from any expenses and charges with respect to the Leased Property or the income therefrom. Section 2.02. The Town shall pay or cause to be paid, punctually when due and payable all property taxes, income taxes, gross receipts taxes, business and occupation taxes, occupational license taxes, water charges, sewer charges, assessments (including, but not limited to, assessments for public improvements or benefits) and all other governmental taxes and charges of every kind and nature which at any time prior to the expiration or termination of this Series 2008 Town Lease shall be or become due and payable by the Corporation or the Town and which shall be levied, charged, assessed or imposed: (i) upon or with respect to the Corporation or which shall be or become liens upon the Leased Property or any interest of the Corporation or the Town therein or pursuant to this Series 2008 Town Lease; (ii) upon or with respect to the possession, opera- tion, management, maintenance, alteration, repair, rebuilding, use or occupancy by the Town of the Leased Property or any portion thereof or (iii) upon any transaction or any document to which the Town is a party creating or transferring an interest or an estate in or to the Leased Property. The Town shall furnish to the Corporation promptly, upon request, proof of the payment of any such tax, assessment or charge which is payable by the Town pursuant to this Section. It shall not be a 11 breach of this Section if the Town fails to pay any such tax, assessment or charge during any period or periods in which the Town, in good faith, or the Corporation, shall be contesting the amount or validity of such tax, assessment or charge. The Corporation shall, if requested by the Town, contest the amount or validity of any such tax, assessment or charge, and the Town shall pay the costs of the Corporation therefor. Section 2.03. The Town shall pay, when due, all sums of money that may become due for or purporting to be for, any labor, services, materials, supplies or equipment alleged to have been furnished or to be furnished to or for the Town in, upon or about the Leased Property and which may be secured by any mechanics', materialmen's or other lien against the Leased Property or the interest of the Corporation therein and shall cause each such lien to be fully discharged and released at the time of performance of any obligation secured by any such lien as such obligation matures or becomes due, provided, however, that if the Town desires to contest any such lien the Town may do so, but notwithstanding any such contest, if any such lien shall be reduced to final judgment and such judgment or such process as may be issued for the enforcement thereof is not promptly stayed, or if so stayed and such stay thereafter expires, then and in any such event the Town shall forthwith pay and discharge such judgment. Section 2.04. The Town shall pay or cause to be paid all charges for gas, water, steam, electricity, light, heat, power, tele- phone or other utility service furnished to or used in connection with the Leased Property. The Corporation shall not be required to furnish to the Town any gas, water, sewer, electricity, light, heat, power, telephone or other utility service of any kind nor shall the Corpora- tion be required to pay for any such charges or services. Section 2.05. The Town shall, at its own cost and expense, keep the Leased Property in good repair and condition, ordinary wear and tear excepted and shall repair, renew or replace any portion thereof that shall have lost its usefulness due to damage, destruction, deterioration or obsolescence. In exchange for the rental payments herein provided, the Corporation shall provide nothing more than the Leased Property. Failure of the Town to faithfully observe this covenant shall constitute a breach of this Series 2008 Town Lease, and the Corporation shall have reasonable rights of inspection for the purpose of determining the performance by the Town of the obligations of the Town pursuant to this Section. Section 2.06. The Town shall cause the Leased Property to be insured against loss or damage by fire, explosion and other hazards customarily insured under extended coverage in an amount not less than the full insurable value of such property and maintain other insurance on the business and properties of the Town with respect to loss, dam- age, liability and other claims of the kind customarily insured against by similarly situated municipal corporations. All such insurance shall be of such types and in such amounts and with such 12 deductible provisions as are customarily carried under similar circumstances by such other municipal corporations. All such insurance shall be carried with financially sound and reputable insurance companies authorized to issue such policy or insure such risk in the State of Arizona. Each policy shall contain provisions, if available, that written notice of cancellation or substantial modification thereof shall be given to the Corporation and the Trustee at least thirty (30) days, or the greatest available period shorter than thirty (30), days prior to such cancellation or modification. The Town may obtain blanket policies covering one or more risks if the minimum coverages required herein are met and all buildings located on the Leased Property are covered to their full insurable value. respect to sources from Section 2.07. All amounts payable the purposes of this Article are which the rental payments hereunder ARTICLE III pursuant to or with payable from the same are payable. SOURCES OF PAYMENT AND PLEDGE Section 3.01. All rental payments and other payments made in accordance herewith shall be made from Town sales taxes, State shared revenues, license and permit fees and fines and forfeitures which the Town now collects, which the Town may collect in the future or which are allocated or apportioned to the Town by the State of Arizona, any political subdivision thereof or any other governmental unit or agency EXCEPT the share of the Town of any taxes which by State of Arizona law, rule or regulation must be expended for other purposes, such as the motor vehicle fuel tax (collectively, the "Excise Taxes"). The Town shall first make all rental payments required by Sections 1.03 and 1.04(i) hereof and then any other rental payments accruing pursuant to this Series 2008 Town Lease from the Excise Taxes and thereafter may use the remaining Excise Taxes for any other lawful purpose, but only to the extent that, taking into account the reasonably anticipated amounts, the Excise Taxes will not be reduced to such a level that the Town will be unable to make the next rental payment hereunder or under the Base Town Lease. Section 3.02. The Town may, at the sole option of the Town, make rental payments and any other payments required hereunder from its other funds as permitted by law and as the Town shall determine from time to time, but the Corporation acknowledges that it has no claim hereunder to such other funds. No part of the rental payments and other amounts payable pursuant to this Series 2008 Town Lease shall be payable out of any ad valorem taxes imposed by the Town, from bonds or other obligations, for the payment of which the general taxing authority of the Town is liable or pledged or from the general funds of the Town, unless (i) the same shall have been duly budgeted by the Town according to law, (ii) such payment or payments shall be within the budget or expenditure limitations of the Constitution and laws of the State of Arizona and (iii) such payment 13 is not in conflict with the Constitution and laws of the State of Arizona. Section 3.03. The Town hereby pledges for the payment of the rental payments required by Sections 1.03 and 1.04(1) hereof and then any other rental payments required hereunder the Excise Taxes. The Town intends that this pledge shall be a first lien upon the Excise Taxes as will be sufficient to make the rental payments pursuant hereto. Section 3.04. To the extent permitted by law, the Excise Taxes shall be retained and maintained so that the amounts received from the Excise Taxes all within and for the next preceding fiscal year shall be equal to at least two (2) times the total of rental payments payable hereunder in any current fiscal year of the Town. The Town further covenants and agrees that if at any time the Excise Taxes will not be sufficient to pay all current rental payments required pursuant to this Series 2008 Town Lease or if such amounts will not equal two (2) times the rental payments in any current fiscal year, the Town shall impose new exactions of the type of the Excise Taxes which shall be part of the Excise Taxes or increase the rates for the Excise Taxes currently imposed in order that (i) the Excise Taxes will be sufficient to pay all current rental payments hereunder and (ii) such amounts will be reasonably calculated to attain the level as required by the first sentence of this Section. Section 3.05. So long as any of the Series 2008 Bonds remain outstanding and the principal and interest thereon shall be unpaid or unprovided for, the Town shall not further encumber the Excise Taxes pledged pursuant to this Article on a basis equal to this first lien pledge unless the Excise Taxes in the next preceding fiscal year shall have amounted to at least three (3) times the highest combined interest and principal requirements for any succeeding twelve (12) months' period for all of the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds and the Series 2008 Bonds then outstanding and any obligations issued on a parity of lien therewith (hereinafter referred to as the "Additional Obligations") which may include any Additional Bonds (as such term is defined in the Indenture) proposed to be secured by a pledge of the Excise Taxes. Section 3.06. In the event of any default by the Town under this Series 2008 Town Lease, the remedies of the Corporation with respect to the enforcement of the liens and pledges set forth in this Article and with respect to the covenants and agreements contained in this Article shall be as provided in Article V hereof. The Trustee, on behalf of the registered owners of the Series 2008 Bonds and the Series 2008 Insurer, may enforce these liens and pledges and the aforesaid covenants and agreements in place of the Corporation in accordance with the terms and conditions of the Indenture. 14 Section 3.07 and 3.05 hereof is, at the at the time of the issuance The conditions set forth in Sections 3.04 time of the execution hereof, and shall be, of the Series 2008 Bonds, satisfied. Section 3.08. In order to secure payment of the amounts due pursuant to the Base Town Lease and this Series 2008 Town Lease as well as any agreement or amendment described in Section 7.03 (v) hereof and to create a separate and special fund which shall contain only the revenues from the Excise Taxes and shall not contain any other moneys of the Town, the Town shall continue to provide for the utilization of a special fund to be known as the "Town of Marana Excise Tax Revenue Fund" (the "Excise Tax Revenue Fund"). Upon receipt by the Town, the revenues from the Excise Taxes shall be deposited in and to the Excise Tax Revenue Fund. The Excise Tax Revenue Fund shall be funded only from the revenues from the Excise Taxes received by the Town and from no other source. After paying therefrom amounts of the revenues from the Excise Taxes for the purposes described herein, the Excise Tax Revenue Fund may be reduced to zero each January 2 and July 2 after the amount required to be deposited to the Interest Fund, the Bond Retirement Fund and Reserve Fund as described hereinabove has been deposited, including by transferring any such balance to the "General Fund" of the Town. ARTTCT,F. TV UIET ENJOYMENT; EXPIRATION OR TERMINATION OF LEASE; SURRENDER OF LEASED PROPERTY Section 4.01. The Town, by keeping and performing the covenants and agreements herein contained, shall at all times during the term hereof, peaceably and quietly, have, hold and enjoy the Leased Property, without suit, trouble or hindrance from the Corporation. Section 4.02. Except as is otherwise provided hereinafter, the Town shall upon the expiration or termination of this Series 2008 Town Lease surrender to the Corporation the Leased Property in good order and condition and in a state of repair that is consistent with prudent use and conscientious maintenance, except for reasonable wear and tear. Section 4.03. In consideration of the timely payment of all rental payments provided herein and provided that (i) the Town has performed all the covenants and agreements required to be performed by the Town and (ii) the Series 2008 Bonds, as to principal, interest and any premium, together with any remaining fees or expenses of the Trustee and the registrars and the paying agents under the Series 2008 Supplemental Indenture as well as payments to the Series 2008 Insurer pursuant to the Series 2008 Guaranty Agreement, have been paid or provided for, the Corporation shall cause the Trustee to release the Leased Property from the lien of the Indenture for purposes of Section 1.02. Upon such termination, all rights of the Corporation or any 15 other person or entity, except the Town, in and to the Leased Property shall cease and the Corporation shall, without further consideration, execute and deliver to the Town appropriate instruments of conveyance conveying title to the Leased Property to the Town. The Corporation shall take any and all steps and shall execute and record any and all documents reasonably required by the Town to consummate the transfer of title to the Leased Property to the Town. ARTTCT,F. V REMEDIES UPON DEFAULT, NO ABATEMENT OF RENTALS Section 5.01. Upon the nonpayment of the whole or any part of the rental payments when the same are to be paid as herein provided or violation by the Town of any other covenant or provision of this Series 2008 Town Lease and if such default has not been cured (i) in the case of nonpayment of rental payments, within five (5) days and (ii) in the case of the breach of any other covenant or provision hereof, within thirty (30) days after notice in writing from the Corporation specifying such default, the Corporation may bring an action for the recovery of any of the rental payments due (but not for rental payments accruing) or for damages for breach of this Series 2008 Town Lease, and the Corporation may pursue any other remedy which the law affords, except that the remedy of specific performance shall also be available. Section 5.02. The Corporation, upon the bringing of a suit to collect the rental payments in default, may request enforcement of the pledges and foreclosure of the liens set forth in Article III hereof, in which event the Corporation, as a matter of right, without notice and without giving any bond or surety to the Town or anyone claiming under the Town, may have a receiver appointed of the Excise Taxes with such powers as the court making such appointment shall confer and the Town does hereby irrevocably consent to such appoint- ment. Section 5.03. In any suit to enforce the terms of this Series 2008 Town Lease, the Corporation shall recover its costs therein, as well as reasonable attorneys' fees, as the Court shall approve. Section 5.04. The Corporation shall in no event be in default in the performance of any of the obligations of the Corporation pursuant to this Series 2008 Town Lease (other than the obligation to make the rental payments required by Sections 1.03 and 1.04(i) hereof) unless the Corporation shall have failed to perform such obligations within thirty (30) days or such additional time as is reasonably required to correct any such default after notice by the Town to the Corporation and to the Trustee properly specifying wherein the Corporation has failed to perform any such obligation. So long as any of the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds or the Series 2008 Bonds are outstanding 16 or payments to the Series 1997 Insurer pursuant to the Series 1997 Guaranty Agreement, the Series 2000 Insurer pursuant to the Series 2000 Guaranty Agreement, the Series 2003 Insurer pursuant to the Series 2003 Guaranty Agreement, the Series 2004 Insurer pursuant to the Series 2004 Guaranty Agreement or the Series 2008 Insurer pursuant to the Series 2008 Guaranty Agreement are unpaid, the Town shall have no right to abate or offset the payments of rental payments to be made by the Town hereunder as a result of a default by the Corporation. In the event of default by the Corporation, the Corporation agrees that specific performance may be had and that the Town shall not be limited to a remedy for damages. Section 5.05. Except as in this Series 2008 Town Lease expressly provided, this Series 2008 Town Lease shall not terminate or be affected in any manner by reason of the condemnation, destruction or damage, in whole or in part, or by reason of the unusability, commercial frustration of purpose or abandonment of, the Leased Property or the Sixth Project or failure to complete provision of the Sixth Project, and, except as in this Series 2008 Town Lease expressly provided, the rental payments shall be absolute and unconditional, shall not be subject to any defense, counterclaim or recoupment and shall be paid by the Town in accordance with the terms, covenants and conditions of this Series 2008 Town Lease without abatement, diminution or reduction. Section 5.06. Each right, power and remedy of the Corpora- tion or the Town provided for in this Series 2008 Town Lease shall be cumulative and concurrent and shall be in addition to every other right, power or remedy provided for herein, or, unless prohibited by the terms hereof, now or hereafter existing at law or in equity or by statute or otherwise, in any jurisdiction where such rights, powers and remedies are sought to be enforced, and the exercise or beginning of the exercise by the Corporation or the Town of any one or more of the rights, powers or remedies provided for herein or now or hereafter existing at law or in equity or by statute or otherwise shall not preclude the simultaneous or later exercise by either party of any or all of such other rights, powers or remedies. Section 5.07. The failure to insist upon a strict perform- ance of any of the covenants or agreements herein set forth shall not be considered or taken as a waiver or relinquishment for the future of the Corporation's or the Town's rights to insist upon a strict compli- ance by the Town or the Corporation with all the covenants and condi- tions hereof. ARTTC'T,F. VT Section 6.01. less than ten (10) days' tee, the Town shall ESTOPPEL CERTIFICATE At any time and from time-to-time, upon not prior request by the Corporation or the Trus- execute, acknowledge and deliver to the 17 Corporation and the Trustee a statement in writing certifying that this Series 2008 Town Lease is unmodified and in full force and effect (or, if this Series 2008 Town Lease has been modified, that it is in full force and effect except as modified, and stating the modification), and the dates to which the rental payments hereunder have been paid in advance, if any. ARTICLE VII REFINANCING; REFUNDING; REDEMPTION; PURCHASE OF BONDS; ADDITIONAL BONDS Section 7.01. Upon notice to the Corporation, the Town may request that the Corporation refinance or prepay, as the case may be, the Series 2008 Bonds by refinancing or prepaying the Series 2008 Bonds, subject to the provisions of the Indenture. The Corporation shall use its best efforts to so refinance or prepay the Series 2008 Bonds. Section 7.02. The Town shall have the right to pay installment rental payments in advance and may specify that such payments be placed in the Bond Retirement Fund established pursuant to the Indenture. In addition, if at any time the money in the Revenue Fund established pursuant to the Indenture exceeds, in the opinion of the Trustee, the amounts necessary for the current debt service on the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds and the Series 2008 Bonds then outstanding and the fees, charges and expenses of the Trustee and the registrars and paying agents under the Indenture as well as payments to the Series 1997 Insurer pursuant to the Series 1997 Guaranty Agreement, the Series 2000 Insurer pursuant to the Series 2000 Guaranty Agreement, the Series 2003 Insurer pursuant to the Series 2003 Guaranty Agreement, the Series 2004 Insurer pursuant to the Series 2004 Guaranty Agreement and the Series 2008 Insurer pursuant to the Series 2008 Guaranty Agreement which are unpaid, such excess shall, at the request of the Town, be transferred to and paid over into the Bond Retirement Fund established pursuant to the Indenture. At the request of the Town, the Corporation shall cause the amount of money contained in the Bond Retirement Fund established pursuant to the Indenture from time to time to be used on any redemption date authorized in the Indenture to retire all or any portion of the outstanding Series 2008 Bonds, or if, before the Series 2008 Bonds are subject to redemption, the Series 2008 Bonds may be obtained in the open market at a cost equal to or below par, or, after the Series 2008 Bonds are subject to redemption, the Series 2008 Bonds may be so obtained at a price below the cost of redemption, then, upon the request of the Town, the Corpo- ration shall cause money contained in the Bond Retirement Fund estab- lished pursuant to the Indenture to be used to purchase Series 2008 Bonds in the open market for the purpose of cancellation. At such time or times as Series 2008 Bonds are redeemed or purchased pursuant hereto, the rental payments to be paid by the Town hereunder shall be adjusted in such manner as to provide for the debt service on the 18 remaining Series 2008 Bonds. There shall be no accumulation of funds, or earnings thereon, in the Bond Retirement Fund established pursuant to the Indenture as would cause the Series 2008 Bonds to be deemed "arbitrage bonds" under the Code. Section 7.03. The Corporation may establish one or more issues of Additional Obligations on a parity with the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds and the Series 2008 Bonds with respect to the Excise Taxes in such principal amount as may be determined by the Corporation, subject to the following specific conditions which are hereby made conditions precedent to the issuance of such Additional Obligations: (i) such Additional Obligations shall have been authorized to finance or refinance the cost of acquiring, con- structing, reconstructing or improving buildings, equipment and other real and personal properties suitable for use by and for leasing to the Town or its agencies or instrumentalities, or to refinance or refund any bonds or other obligations which have been issued for such purposes, and the issuance thereof shall have been determined and declared by the Corporation, by appropriate resolution, to be necessary for that purpose; (ii) the Corporation shall be in compliance with all covenants and undertakings set forth in this Series 2008 Town Lease and in the Indenture, as either or both may have been sup- plemented; (iii) the resolution authorizing issuance of such Addi- tional Obligations shall require that the proceeds of the sale of such Additional Obligations shall be applied solely for one or more of the purposes set forth in (i) above and expenses and costs incidental thereto, including costs and expenses incident to the issuance and sale of such Additional Obligations and the costs of any premium relating to insurance on the Additional Obligations or on any debt service reserve fund therefor, and for funding a debt service reserve fund for the protection of the owners of the Additional Obligations (which shall be in an amount equal to the Reserve Requirement as such term is defined in the Indenture) for such Additional Obligations and, if desired, interest on such Additional Obligations during the actual period of any acquisition and construction of such facilities and for a reasonable period of time thereafter; (iv) such Additional Obligations shall be equally and ratably secured with the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds and the Series 2008 Bonds, without preference or priority of any of the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds, the Series 2008 Bonds or Additional Obligations over any other Series 1997 Bonds, Series 2000 Bonds, Series 2003 Bonds, Series 2004 Bonds, Series 2008 Bonds or 19 Additional Obligations, except as expressly provided in the Indenture, as supplemented; (v) the Corporation shall have entered into an agree- ment with the Town, or shall have amended this Series 2008 Town Lease, in and by which the Town obligates itself in the manner therein provided to increase or decrease the rental payments or to make such payments to the Corporation at the times and in amounts sufficient to provide for the payment of principal of and interest on such Additional Obligations as such principal and interest become due and (vi) the conditions set forth in Section 3.05 hereof shall then be satisfied. ARTICLE VIII OFFICIAL STATEMENT DISCLOSURES; INDEMNIFICATION Section 8.01. The Town hereby recognizes that in the sale of the Series 2008 Bonds the Corporation shall have issued an Official Statement describing the Series 2008 Bonds and the security for the payment thereof and containing certain information about the Town (the "Official Statement") which has been furnished to the Corporation by the Town. Recognizing that the Corporation and its officers, direc- tors, agents and employees have no practicable independent means of verifying such information, the Town hereby represents and warrants to the Corporation that all material contained in the Official Statement, insofar as it relates to the Town and the sources of funds or as it otherwise describes the security of this Series 2008 Town Lease and the rights of the owners of the Series 2008 Bonds with respect thereto, is accurate, contains no material misrepresentation of fact and does not omit any statement of fact which, in the light of the circumstances under which the Official Statement is issued, would be misleading. Section 8.02. To the extent permitted by applicable law, the Town shall pay, indemnify and save the Corporation and the Trustee harmless, from the same sources from which the rental payments here- under are payable, for, from and against any and all claims by or on behalf of any person, firm, corporation or governmental authority arising from the occupation, use or possession of the Leased Property, including any liability for any violation of conditions, restrictions, laws, ordinances or regulations affecting the said property or the occupancy or use thereof. Section 8.03. The Corporation, its incorporators, members, directors, officers, agents and employees shall not be liable to the Town or to any other person whomsoever for any death, injury or damage that may result to any person or property by or from any cause whatsoever in or on the Leased Property or any part thereof, unless caused by the willful misconduct of the Corporation, its 20 incorporators, members, directors, officers, agents or employees. To the extent permitted by applicable law, the Town shall indemnify and hold such persons harmless, from the same sources from which the rental payments hereunder are payable, for, from and against and defend them and each of them against any and all claims, losses or judgments for death of, or injury to, any person, or for damage to any property whatsoever incurred in or on the adjoining streets, roads, sidewalks and passageways, unless caused by the willful misconduct of the Corporation, its incorporators, members, directors, officers, agents or employees. In the event any action or proceeding is brought against any of the persons referred to in this Section by reason of any such claim, the Town, upon notice from the Corporation, shall resist or defend such action or proceeding. Section 8.04. To the extend permitted by applicable law, the Town shall pay and indemnify the Corporation, from the same sources from which the rental payments hereunder are payable, for, from and against all lawful and reasonable costs and charges, including reasonable counsel fees, in enforcing any covenant or agreement of the Town contained in this Series 2008 Town Lease. Section 8.05. In clarification and extension of the provisions of the other sections of this Article VIII, and not in substitution therefor and to the extent permitted by applicable law, the Town, subject to the provisions of Section 1.04 hereof, shall indemnify and hold the Corporation and the Trustee, their respective incorporators, members, directors, officers, agents and employees, harmless, from the same sources from which the rental payments hereunder are payable, for, from and against any and all claims, expenses, liens, judgments, liability or loss whatever, including reasonable legal fees and expenses relating to or in any way arising out of (i) this Series 2008 Town Lease, the Indenture, the Series 2008 Guaranty Agreement and security agreements, financing statements, supplements, amendments or additions thereto or the enforcement of any of the terms thereof; (ii) the Series 2008 Bonds; (iii) any offering statement or official statement, either preliminary or final, pertaining to the Series 2008 Bonds and (iv) the issuance and sale of the Series 2008 Bonds or the transactions contemplated in any of the aforementioned acts, agreements or documents; provided, however, that such indemnity shall not extend to any actions of (A) the Corporation deliberately taken by them over the objections of the Town or otherwise involving the wilful misconduct or gross negligence of the Corporation, its directors, incorporators, members, officers or agents or (B) the Trustee involving the wilful misconduct or negligence of the Trustee, its directors, officers or agents. The Corporation and the Trustee shall give notice to the Town of any event or condition which requires indemnification by the Town hereunder, or any allegation of such event or condition, promptly upon obtaining knowledge thereof, and, to the extent that the Town makes or provides for payment to the satisfaction of the Corporation or the Trustee under the indemnity provisions hereof, the Town shall be subrogated to the rights of the Corporation or the Trustee with respect to such event or condition and shall have the right to determine the 21 settlement of claims thereon. The Town shall pay all amounts due hereunder promptly upon notice thereof from the Corporation or the Trustee. In case any action, suit or proceeding is brought against the Corporation or the Trustee by reason of any act or condition which requires indemnification by the Town hereunder, the Corporation and the Trustee shall notify the Town promptly of such action, suit or proceeding, and the Town may (and will upon the request of the Corporation or the Trustee), at the Town's expense, resist and defend such action, suit or proceeding, or cause the same to be resisted and defended, by counsel for the Series 2008 Insurer of the liability or by counsel designated by the Town and approved by the Corporation and the Trustee. If the Corporation or the Trustee desire to participate in the defense of such action, suit or proceeding through their own counsel, they may do so at their own expense. ARTTC'T,F TX ACCESS AND CONTROL OF TOWN AND BOND SERIES 2008 INSURER Section 9.01. The Corporation, incident to the issuance and sale of the Series 2008 Bonds and the provisions of the Series 2008 Surety Bond pursuant to the Series 2008 Guaranty Agreement, shall assign [(except for the Unassigned Corporation's Rights (as such term is defined in the Indenture)] all rights and benefits hereunder to the Trustee and shall grant the Trustee a lien on its interest in this Series 2008 Town Lease for the benefit of the owners of the Series 2008 Bonds and the Series 2008 Insurer. The Town hereby consents to such assignment and grant of lien. Section 9.02. The Town, so long as no event of default by the Town under this Series 2008 Town Lease shall have occurred and be continuing, shall at all times have and retain all rights of access and control of the Leased Property. The rights and interests of the Corporation assigned, granted and set over to the Trustee pursuant to the Indenture shall, so long as no event of default by the Town pursuant to this Series 2008 Town Lease shall have occurred and be continuing, be subject and subordinate to the rights of the Town under this Section. ARTT("T.F. X FEDERAL LAW PROVISIONS Section 10.01. (A) The Town and the Corporation covenant to the holders of the Series 2008 Bonds that they will not make or direct the making of any investment or other use of the proceeds of any Series 2008 Bonds which would cause such Series 2008 Bonds to be "arbitrage bonds" as that term is defined in section 148 (or any successor provision thereto) of the Internal Revenue Code of 1986, as amended, or "private activity bonds" as that term is defined in section 141 (or any successor provision thereto) of such Code, and 22 that they will comply with the requirements of such Code sections and related regulations throughout the term of the Series 2008 Bonds. The Town and the Corporation hereby further covenant and agree to comply with the procedures and covenants contained in any arbitrage rebate provision or separate agreement executed in connection with the issu- ance of the Series 2008 Bonds for so long as compliance is necessary in order to maintain the exclusion from gross income for federal income tax purposes of interest on the Series 2008 Bonds. In consid- eration of the purchase and acceptance of the Series 2008 Bonds by such holders from time to time and of retaining such exclusion and as authorized by Title 35, Chapter 3, Article 7, Arizona Revised Stat- utes, as amended, the Town and the Corporation covenant, and the appropriate officials of the Town and the Corporation are hereby directed, to take all action required to retain such exclusion or to refrain from taking any action prohibited by such Code which would adversely affect in any respect such exclusion. (B) The Town shall take all necessary and desirable steps, as determined by the Town, to comply with the requirements hereunder in order to ensure that interest on the Series 2008 Bonds is excluded from gross income for federal income tax purposes under such Code; provided, however, compliance with any such requirement shall not be required in the event the Town receives a Bond Counsel's Opin- ion (as such term is hereinafter defined) that either (i) compliance with such requirement is not required to maintain the exclusion from gross income of interest on the Series 2008 Bonds, or (ii) compliance with some other requirement will meet the requirements of such Code. In the event the Town receives such a Bond Counsel's Opinion, the parties agree to amend this Series 2008 Town Lease to conform to the requirements set forth in such opinion. (C) If for any reason any requirement hereunder is not complied with, the Town shall take all necessary and desirable steps, as determined by the Town, to correct such noncompliance within a reasonable period of time after such noncompliance is discovered or should have been discovered with the exercise of reasonable diligence and the Town shall pay any required interest or penalty under Regula- tions section 1.148-3(h) with respect to such Code. Section 10.02. (A) Terms not otherwise defined in Subsec- tion (B) hereof shall have the meanings given to them in the arbitrage certificate of the Town delivered in connection with the issuance of the Series 2008 Bonds. meanings: (B) The following terms shall have the following Bond Counsel's Opinion shall mean an opinion signed by an attorney or firm of attorneys of nationally recognized standing in the field of law relating to municipal bonds selected by the Town. Bond Year shall mean each one-year period beginning on the day after the expiration of the preceding Bond Year. The first 23 Bond Year shall begin on the date of issue of the Series 2008 Bonds and shall end on the date selected by the Town, provided that the first Bond Year shall not exceed one calendar year. The last Bond Year shall end on the date of retirement of the last Series 2008 Bond. Bond Yield is as indicated in such arbitrage certifi- cate. Bond Yield shall be recomputed if required by Regulations section 1.148-4 (b) (4) or 4 (h) (3) . Bond Yield shall mean the discount rate that produces a present value equal to the Issue Price of all unconditionally payable payments of principal, interest and fees for qualified guarantees within the meaning of Regulations section 1.148-4 (f) and amounts reasonably expected to be paid as fees for qualified guarantees in connection with the Series 2008 Bonds as determined under Regulations section 1.148-4(b). The present value of all such payments shall be computed as of the date of issue of the Series 2008 Bonds and using semiannual compounding on the basis of a 360-day year. Code shall mean the Internal Revenue Code of 1986, as amended, and any successor provisions thereto. Gross Proceeds shall mean: (i) any amounts actually or constructively received by the Town or the Corporation from the sale of the Series 2008 Bonds but excluding amounts used to pay accrued interest on the Series 2008 Bonds within one year of the date of issuance of the Series 2008 Bonds; (ii) transferred proceeds of the Series 2008 Bonds under Regulations section 1.148-9; (iii) any amounts actually or constructively received from investing amounts described in (i), (ii) or this (iii); and (iv) replacement proceeds of the Series 2008 Bonds within the meaning of Regulations section 1.148-1(c). Replace- ment proceeds include amounts reasonably expected to be used directly or indirectly to pay debt service on the Series 2008 Bonds, pledged amounts where there is reasonable assurance that such amounts will be available to pay principal or interest on the Series 2008 Bonds in the event the Town or the Corporation encounters financial difficulties and other replacement proceeds within the meaning of Regulations section 1.148-1(c)(4). Whether an amount is Gross Proceeds is deter- mined without regard to whether the amount is held in any fund or account established under the Indenture. Investment Property shall mean any security, obliga- tion (other than a tax-exempt bond within the meaning of Code section 148(b)(3)(A)), annuity contract or investment-type property within the meaning of Regulations section 1.148-1(b). 24 Issue Price is as indicated in such arbitrage certifi- cate, which is the initial offering price to the public (not including bond houses and brokers, or similar persons or organizations acting in the capacity of underwriters of wholesalers) at which price a substan- tial amount of the Series 2008 Bonds was sold, less any bond insurance premium and reserve surety bond premium. Issue price shall be deter- mined as provided in Regulations section 1.148-1(b). Nonpurpose Investment shall mean any Investment Prop- erty acquired with Gross Proceeds, and which is not acquired to carry out the governmental purposes of the Series 2008 Bonds. Payment shall mean any payment within the meaning of Regulations section 1.148-3(d)(1) with respect to a Nonpurpose Invest- ment. Rebate Requirement shall mean at any time the excess of the future value of all Receipts over the future value of all Payments. For purposes of calculating the Rebate Requirement the Bond Yield shall be used to determine the future value of Receipts and Pay- ments in accordance with Regulations section 1.148-3(c). The Rebate Requirement is zero for any Nonpurpose Investment meeting the require- ments of a rebate exception under section 148(f)(4) of the Code or Regulations section 1.148-7. Receipt shall mean any receipt within the meaning of Regulations section 1.148-3(d)(2) with respect to a Nonpurpose Invest- ment. Regulations shall mean the sections 1.148-1 through 1.48-11 and section 1.150-1 of the regulations of the United States Department of the Treasury promulgated under the Code, including and any amendments thereto or successor regulations. (C) Within 60 days after the end of each Bond Year, the Town shall cause the Rebate Requirement to be calculated and shall pay to the United States of America: (1) not later than 60 days after the end of the fifth Bond Year and every fifth Bond Year thereafter, an amount which, when added to the future value of all previ- ous rebate payments with respect to the Series 2008 Bonds (determined as of such Computation Date), is equal to at least 900 of the sum of the Rebate Requirement (determined as of the last day of such Bond Year) plus the future value of all previous rebate payments with respect to the Series 2008 Bonds (determined as of the last day of such Bond Year); and (2) not later than 60 days after the retirement of the last Series 2008 Bond, an amount equal to 100% of the Rebate Requirement (determined as of the date of retirement of the last Series 2008 Bond). 25 Each payment required to be made under this Section shall be filed with the Internal Revenue Service Center, Ogden, Utah 84201, on or before the date such payment is due, and shall be accompanied by IRS Form 8038-T. (D) No Nonpurpose Investment shall be acquired for an amount in excess of its fair market value. No Nonpurpose Investment shall be sold or otherwise disposed of for an amount less than its fair market value. (E) For purposes of Subsection (D), whether a Nonpur- pose Investment has been purchased or sold or disposed of for its fair market value shall be determined as follows: (1) The fair market value of a Nonpurpose Investment generally shall be the price at which a willing buyer would purchase the Nonpurpose Investment from a will- ing seller in a bona fide arm's length transaction. Fair market value shall be determined on the date on which a contract to purchase or sell the Nonpurpose Investment becomes binding. (2) Except as provided in Subsection (F) or (G), a Nonpurpose Investment that is not of a type traded on an established securities market, within the meaning of Code section 1273, is rebuttably presumed to be acquired or disposed of for a price that is not equal to its fair market value. (3) If a United States Treasury obligation is acquired directly from or sold or disposed of directly to the United States Treasury, such acquisition or sale or disposition shall be treated as establishing the fair market value of the obligation. (F) The purchase price of a certificate of deposit that has a fixed interest rate, a fixed payment schedule and a substantial penalty for early withdrawal is considered to be its fair market value if the yield on the certificate of deposit is not less than: (1) the yield on reasonably comparable direct obligations of the United States; and (2) the highest yield that is published or posted by the provider to be currently available from the provider on reasonably comparable certificates of deposit offered to the public. (G) A guaranteed investment contract shall be consid- ered acquired and disposed of for an amount equal to its fair market value if: 26 (1) A bona fide solicitation in writing for a specified guaranteed investment contract, including all material terms, is timely forwarded to all potential pro- viders. The solicitation must include a statement that the submission of a bid is a representation that the potential provider did not consult with any other potential provider about its bid, that the bid was determined without regard to any other formal or informal agreement that the poten- tial provider has with the Issuer or any other person (whether or not in connection with the Series 2008 Bonds), and that the bid is not being submitted solely as a cour- tesy to the Town or the Corporation or any other person for purposes of satisfying the requirements in the Regulations that the Town or the Corporation receive bids from at least one reasonably competitive provider and at least three providers that do not have a material financial interest in the Series 2008 Bonds. (2) All potential providers have an equal opportunity to bid, with no potential provider having the opportunity to review other bids before providing a bid. (3) At least three reasonably competitive pro- viders (i.e. having an established industry reputation as a competitive provider of the type of investments being pur- chased) are solicited for bids. At least three bids must be received from providers that have no material financial interest in the Series 2008 Bonds (e.g., a lead underwriter within 15 days of the issue date of the Series 2008 Bonds or a financial advisor with respect to the investment) and at least one of such three bids must be from a reasonably competitive provider. If the Town or the Corporation uses an agent to conduct the bidding, the agent may not bid. (4) The highest-yielding guaranteed investment contract for which a qualifying bid is made (determined net of broker's fees) is purchased. (5) The determination of the terms of the guar- anteed investment contract takes into account as a signifi- cant factor the reasonably expected deposit and drawdown schedule for the amounts to be invested. (6) The terms for the guaranteed investment contract are commercially reasonable (i.e. have a legiti- mate business purpose other than to increase the purchase price or reduce the yield of the guaranteed investment contract). (7) The provider of the investment contract certifies the administrative costs (as defined in Regula- tions section 1 .148-5 (e) ) that it pays (or expects to pay) 27 to third parties in connection with the guaranteed invest- ment contract. (8) The Town retains until three years after the last outstanding Series 2008 Bond is retired, (i) a copy of the guaranteed investment contract, (ii) a receipt or other record of the amount actually paid for the guar- anteed investment contract, including any administrative costs paid by the Town or the Corporation and a copy of the provider's certification described in (7) above, (iii) the name of the person and entity submitting each bid, the time and date of the bid, and the bid results and (iv) the bid solicitation form and, if the terms of the guaranteed investment contract deviates from the bid solicitation form or a submitted bid is modified, a brief statement explain- ing the deviation and stating the purpose of the deviation. Section 10.03. [???] The Series 2008 Bonds shall be "qualified tax-exempt obligations" within the meaning of and pursuant to the provisions of Section 265 (b) of the Code. The Town hereby represents and warrants that the reasonably anticipated amount of qualified tax-exempt obligations (other than private activity bonds) which will be issued by or on behalf of the Town during the calendar year 2004 shall not exceed $10,000,000. Section 10.04. Such employed to make, as necessary, an to be made to the United States of 148 (f) of the Code with respect to experts and consultants shall be y calculations in respect of rebates America in accordance with section the Series 2008 Bonds. Section 10.05. Subject to annual appropriation to cover the costs of preparing and mailing thereof, the Town hereby covenants and agrees that it will comply with and carry out all of the provisions of the Series 2008 Continuing Disclosure Agreement, dated 2008 (the "Continuing Disclosure Agreement"). Notwithstanding any other provision of this Series 2008 Town Lease, failure of the Town to comply with the Continuing Disclosure Agreement shall not be considered an event of default; however, the Trustee may (and, at the request of any Participating Underwriter (as such term is defined in the Continuing Disclosure Agreement) or the owners of at least 25o aggregate principal amount in outstanding Series 2008 Bonds and receipt of indemnity to its satisfaction, shall) or any Beneficial Owner (as such term is defined in the Continuing Disclosure Agreement) may take such actions as may be necessary and appropriate, including seeking specific performance by court order, to cause the Town to comply with its obligations under this Section. 28 ARTICLE XI GENERAL PROVISIONS Section 11.01. This Series 2008 Town Lease supplements the Base Town Lease for all purposes, the Corporation remaining as lessor and the Town as lessee with respect to the First Water System Real Property, the Municipal Complex Real Property, the First Water System Improvements, the Second Water System Real Property, the Second Water System Improvements, the Town Hall Property, the Town Hall Improve- ments, the Additional Town Hall Improvements and the Final Town Hall Improvements, without any merger of interests as a result thereof. Section 11.02. The Town may not sell or assign its interest in this Series 2008 Town Lease while any of the Series 2008 Bonds are outstanding, but may sell, lease or otherwise dispose of all or any part of the Leased Property with the consent of the Corporation; provided, however, that prior to any such sale, lease or other disposition, the Town shall provide to the Corporation and the Trustee an opinion of nationally recognized bond counsel to the effect that such sale, lease or other disposition, shall not cause the interest on the Series 2008 Bonds to be includable in the gross income of the owners thereof for federal income tax purposes. Notwithstanding any such sale, lease or other disposition, the Town shall nevertheless remain liable for the rentals provided herein and for the performance of the other obligations of the Town hereunder. Section 11.03. All rights of the Corporation hereunder [(except for the Corporation's Unassigned Rights (as such term is defined in the Indenture))) are to be assigned, pledged, mortgaged and transferred to the Trustee as security for the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds and the Series 2008 Bonds and payments to the Series 1997 Insurer pursuant to the Series 1997 Guaranty Agreement, the Series 2000 Insurer pursuant to the Series 2000 Guaranty Agreement, the Series 2003 Insurer pursuant to the Series 2003 Guaranty Agreement, the Series 2004 Insurer pursuant to the Series 2004 Guaranty Agreement and the Series 2008 Insurer pursuant to the Series 2008 Guaranty Agreement, but subject to the rights under this Series 2008 Town Lease of the Town. The rights of the Trustee or any party or parties on behalf of whom the Trustee is acting (including, specifically, but without limitation, the right to receive the. rentals to be paid hereunder) shall not be subject to any defense, setoff, counterclaim or recoupment whatsoever, whether arising out of any breach of any obligation of the Corporation hereunder or by reason of any other indebtedness or liability at any time owing by the Corporation to the Town. Section 11.04. All notices, consents or other communi- cations required or permitted hereunder shall be deemed sufficient if given in writing addressed and mailed by registered or certified mail, or delivered to the party for whom the same is intended, as follows: 29 To the Corporation: Town of Marana Municipal Property Corporation c/o Town of Marana, Arizona 11555 West Civic Center Drive Marana, Arizona 85653-7007 Attention: President To the Town: Town of Marana, Arizona 11555 West Civic Center Drive Marana, Arizona 85653-7007 Attention: Town Manager To Trustee: Wells Fargo Bank, National Association (formerly Norwest Bank Arizona and Wells Fargo Bank Arizona, N.A.) Wells Fargo Plaza, MAC 54101-080 100 West Washington Street, 8th Floor Phoenix, Arizona 85003 Attention: Corporate Trust Services or to such other address as such party may hereafter designate by notice in writing addressed and mailed or delivered to the other party hereto. Section 11.05. This Series 2008 Town Lease shall be gov- erned exclusively by the provisions hereof and by the applicable laws of the State of Arizona. Section 11.06. If any term or provision of this Series 2008 Town Lease or the application thereof to any person or circumstance shall to any extent be invalid or unenforceable, the remainder of this Series 2008 Town Lease or the application of such term or provision to persons or circumstances other than those as to which it is invalid or unenforceable shall not be affected thereby and each term and provision of this Series 2008 Town Lease shall be valid and enforceable to the fullest extent permitted by law. Section 11.07. For all purposes of Section 38-511, Arizona Revised Statutes, as amended, the provisions of which are hereby incorporated by this reference, the Town may, within three (3) years after its execution, cancel, this Series 2008 Town Lease, without penalty(s) or further obligation, if any person significantly involved in initiating, negotiating, securing, drafting or creating this Series 2008 Town Lease on behalf of the Town is, at any time while this Series 2008 Town Lease is in effect, an employee or agent of the Corporation in any capacity or a consultant to any other party of this Series 2008 Town Lease with respect to the subject matter of this Series 2008 Town Lease and may recoup any fee or commission paid or due any person significantly involved in initiating, negotiating, securing, drafting or creating this Series 2008 Town Lease on behalf of the Town arising as the result of this Series 2008 Town Lease. The Corporation has not taken and shall not take any action which would cause any person described in the preceding sentence to be an 30 employee or agent of the Corporation in any capacity or a consultant to any party to this Series 2008 Town Lease with respect to the subject matter of this Series 2008 Town Lease. Section 11.08. This Series 2008 Town Lease may be executed in several counterparts, each of which shall be an original, but all of which shall constitute but one instrument. 31 IN WITNESS WHEREOF, the Corporation and the Town have caused their respective names to be signed hereto by their respective officers thereunto duly authorized, all as of the day and year first above written. TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION, an Arizona nonprofit corporation ATTEST: ................................ Secretary ATTEST: ................................ Jocelyn C. Bronson, Town Clerk APPROVED AS TO FORM: ................................ Frank Cassidy, Town Attorney By ............................ ....... President TOWN OF MARANA, ARIZONA, a Municipal corporation By.... .............................. Edward Honea, Mayor 32 STATE OF ARIZONA ) ss. COUNTY OF PIMA ) On this, the ..... day of ................ 2008, before me, the undersigned Notary Public, personally appeared and who acknowledged themselves to be the President and Secretary, respectively, of the TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION, an Arizona nonprofit corporation, and that they, as such officers, being authorized so to do, executed the foregoing Series 2008 Town Lease for the purposes therein contained by signing the name of the corporation by themselves as such officers. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ...................................... Notary Public My Commission Expires: STATE OF ARIZONA ) ss. COUNTY OF PIMA ) On this, the ..... day of ................ 2008, before me, the undersigned Notary Public, personally appeared Edward Honea and Jocelyn C. Bronson, who acknowledged themselves to be the Mayor and Town Clerk, respectively, of the TOWN OF MARANA, ARIZONA, a municipal corporation, and that they, as such officers, being authorized so to do, executed the foregoing Series 2008 Town Lease for the purposes therein contained by signing the name of the municipal corporation by themselves as such officers. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. My Commission Expires: 328191526v 1 4/23/2008 ...................................... Notary Public 33 EXHIBIT A DESCRIPTION OF LEASED PROPERTY DESCRIPTION OF FIRST WATER SYSTEM REAL PROPERTY The real property situate in Pima County, State of Arizona, more particularly described as follows: Pump Station No. 1 comb is located approximately 140 feet THENCE 95 feet East, THENCE 150 THENCE 150 feet South to the specifically legally described by to closing. prising a lot whose Southwest corner East of the existing property line, feet North, THENCE 95 feet West, Southwest corner, as to be more survey performed by purchaser prior Pump Station No. 2 comprising all of Lot 51, Honea Heights Subdivision, being a subdivision of part of the N1/2 of the NW Section 33, T 11 S, R 11 E, G&SRB&M, Pima County, Arizona. DESCRIPTION OF MUNICIPAL COMPLEX REAL PROPERTY All that certain real property, situate in the County of Pima, State of Arizona, being a part of the Southeast quarter of the Northwest quarter of Section 27, Township 11 South, Range 11 East, G.&S.R.B.&M., more particularly described as follows: Beginning at the survey monument marking the North quarter of said section 27; THENCE South 00 deg. 14 min. 15 sec. East, a distance of 2629.68 feet to the East quarter corner of said section 27; THENCE South 89 deg. 41 min. 25 sec. West, a distance of 30 feet to a point; THENCE North 00 deg. 14 min. 15 sec. West, a distance of 25 feet to a point, said point being the True Point of Beginning; THENCE South 89 deg. 41 min. 25 sec. West along a line parallel to the centerline of Barnett Road for a distance of 100.00 feet, to a point; THENCE North 00 deg. 14 min. 15 sec. West along a line parallel to the centerline of Lon Adams Road for a distance of 466.69 feet to a point; THENCE North 89 deg. 41 min. 25 sec. East along a line parallel to the centerline of Barnett Road for a distance of 100.00 feet to a point on the West right-of-way line of Lon Adams Road; A-1 THENCE South 00 deg. 14 min. 15 sec. East along a line parallel to the centerline of Lon Adams Road a distance of 466.69 feet to the True Point of Beginning, BUT NOT INCLUDING all of that portion of Northwest quarter (NW ~) of Section 27, Township 11 South, Range 11 East, Gila and Salt River Meridian, Pima County, Arizona, described as follows: COMMENCING at the Southeast corner of said Northwest Quarter (NW ~) of Section; THENCE S 89°18'55" W, (S 89°52'08"W recorded in Docket 11081, Page 1230), along the South line of said Northwest Quarter (NW ~) a distance of 496.69 feet; THENCE N 00°36'55"W, (N 00°03,43"W recorded in Docket 11081, Page 1230), a distance of 25.00 feet to a point on a line parallel with and 25.00 feet North of said South line, also being the North right-of-way line of Barnett Road; THENCE S 89°18'55" W, (S 89°52'08"W recorded in Docket 11081, Page 1230), along said right-of-way line a distance of 479.02 feet to the point of beginning; THENCE N 00036'55"W, (N 00°03'43"W recorded in Docket 11081, Page 1230), 272.81 feet; THENCE N 44°26'48" E, 51.48 feet; THENCE N 45°33'12" W, 58.64 feet to the West line of the parcel recorded in Docket 11081, Page 1230, said point herein referred to as Point "A"; THENCE S 00°36'55" E, (S 00°03'43" E recorded in Docket 11081, Page 1230), along said West line a distance of 350.69 feet to a point on said right-of-way line; THENCE N 89°18'55" E, (N 89°52'08" E recorded in Docket 11081, Page 1230), along said right-of-way line a distance of 4.98 feet to the POINT OF BEGINNING, containing 3,062 square feet, more or less, COMMENCING at the above referenced Point "A"; THENCE N 00°36'55" W, (N 00°03'43" W recorded in Docket 11081, Page 1230), along the West line of that Parcel recorded in Docket 11081, Page 1230, a distance 567.71 feet to the POINT OF BEGINNING; THENCE continue N 00°36'55"W, (N 00°03'43"W recorded in Docket 11081, page 1230), along said West parcel line, a distance of 114.74 feet; A-2 THENCE N 44°18'55,. E, 20.80 feet; THENCE along a non-tangent curve to the left, having a radius of 50.00 feet, a central angle of 81°52'12", a radial line through said point bears S 44°18'55" W, for an arc length of 71.44 feet to a point of reverse curvature; THENCE along said reverse curve to the right, having a radius of 50.00 feet, a central angle of 36°52'12", for an arc length of 32.18 feet to a point; THENCE N 89°18'55" E, 148.10 feet; THENCE along a non-tangent curve to the left, having a radius of 495.00 feet, a central angle of 12°54'58" a radial line through said point bears N 32 ° 38' 15' . W, for an arc length of 111.59 feet to a point of tangency; THENCE S 44°26'48" W, 102.23 feet; THENCE along a non-tangent curve to the left, having a radius of 85.00 feet, a central angle of 65°49'44", a radial line through said point bears N 32°23'18" E, for an arc length of 97.66 feet to a point of non-tangent line; THENCE N 45°33'12" W, 8.81 feet to the POINT OF BEGINNING, Containing 0.51 acres, more or less, AND INSTEAD INCLUDING all of that portion of Northwest Quarter (NW ~) of Section 27, Township 11 South, Range 11 East, Gila and Salt River Meridian, Pima County, Arizona, described as follows: COMMENCING at the Southeast corner of said Northwest Quarter (NW ~) of Section; THENCE S 89°18'55" W, (S 89°52'08" W recorded in Docket 11081, Page 1230), along the South line of said Northwest Quarter (NW ~) a distance of 496.69 feet; THENCE N 00°36'55" W, (N 00°03'43"W recorded in Docket 11081, Page 1230), a distance of 25.00 feet to a point on a line parallel with and 25.00 feet North of said South line, also being the North right-of-way line of Barnett Road; THENCE S 89°18'55" W, (S 89°52'08" W recorded in Docket 11081, Page 1230), along said right-of-way line a distance of 479.02 feet; THENCE N 00°36'55" W, (N 00°03'43"W recorded in Docket 11081, Page 1230), a distance of 272.81 feet; THENCE N 44°26'48" E, 51.48 feet; A-3 THENCE N 45°33'12" W, 58.64 feet to the West line of the Parcel recorded in Docket 11081, page 1230, being the point of beginning; THENCE continue N 45°33'12" W, 237.71 feet; THENCE N 44 °26' 48" E, a distance of 237.19 feet to a point on the West line of said parcel; THENCE S 00°36'55" E, along said line a distance of 380 feet to the POINT OF BEGINNING, containing 28,191 square feet, more less. DESCRIPTION OF SECOND WATER SYSTEMS REAL PROPERTY Picture Rocks Well Site: That portion of the NE4 of the NW4 of Section 34, T 12 S, R 12 E: G&SRB&M, Pima County, Arizona, more particularly described as follows: Beginning at a 2" open iron pipe set in concrete at the N Corner of said Section 34; THENCE South 0 degrees 30 minutes 03 seconds East along the midsection line of Section 34, 152.90 feet to the True Point of Beginning; THENCE continuing South 0 degrees 30 minutes 03 seconds East 50.00 feet; feet; feet; THENCE South 89 degrees 57 minutes 00 seconds West 50.00 THENCE North 0 degrees 30 minutes 03 seconds West 50.00 THENCE North 89 degrees 57 minutes 00 seconds East 50.00 feet to the True Point of Beginning. Picture Rocks Reservoir Site: That portion of the SE4 of Section 4, T 13 S, R 12 E, G&SRB&M, Pima County, Arizona, more particularly described as follows: Beginning at the East ~ corner of said Section 4, T 13 S, R 12 E, G&SRB&M, Pima County, Arizona: feet; THENCE South along the East line of section 4, 1,069.05 THENCE West at right angles 300.0 feet; THENCE North at right angles, 85.0 feet to the True Point of Beginning; A-4 THENCE continuing North 134.03 feet to the Southerly line of Picture Rocks Road; Beginning. THENCE North 56 degrees 50 minutes 00 seconds, 89.60 feet; THENCE South 183.05 feet; THENCE West at right angles 75.0 feet to the True Point of Happy Acres Well Site (Airline): That certain parcel of land designated and marked "WELLSITE" located and lying adjacent to the Southwesterly portion of Lot 28 as shown on the Map or Plat of "HAPPY ACRES" a subdivision of Pima County, Arizona, in Book 14 of Maps and Plats at Page 45 thereof. Happy Acres Well Site (Lambert): All of that parcel of land designated and marked "WELLSITE" and known as Lot 29, of "HAPPY ACRES SOUTH," a subdivision of Pima County, Arizona, as shown on the recorded plat in the office of the Recorder of Pima County, Arizona, in Book 20 of Maps and Plats at Page 14 thereof. Palo Verde Well Site (JM Water Company) East 100 feet of West 116 feet of South 100 feet of NE4 SW4, Section 17, T 12 S, R 11 E., G&SRB&M, Pima County, Arizona. Honea East Well Site: That portion of the Northeast Quarter of Section 33, Township 11 South, Range 11 East of the G.&S.R.B.&M., Pima County, Arizona, being more particularly described as follows: COMMENCING at the Southwest Corner of the Northeast Quarter of the Southwest Quarter of the Northeast of said Section 33; THENCE North 89 deg. 24 min. 26 sec. East along the South line of said Northeast Quarter of the Southwest Quarter of Northeast Quarter of said Section 33, a distance of 140.00 feet to the Southwest corner of Cactus Country Racing Pigeon Club Parcel, Tucson, Arizona, Inc. Docket 1975 Page 3, Pima County Recorders, ALSO BEING THE TRUE POINT OF BEGINNING; THENCE North 00 deg. 29 min. 07 sec. West along the East line of said Cactus Country Racing Pigeon Club Parcel, also being parallel with the West line of the said Northeast Quarter of the Southwest Quarter of Northeast Quarter of Section 33, a distance of 150.00 feet; THENCE North 89 deg. 24 min. 26. Sec. East along a line parallel with the South line of the said Northeast Quarter of the Southwest Quarter of Northeast Quarter of Section 33, a distance of 93.80 feet; THENCE South 00 deg. 29 min. 07 sec. East, along a line parallel with the said Cactus County Racing Pigeon Club Parcel, a A-5 distance of 150.00 feet to a point on the said South line of the Northeast Quarter of the Southwest Quarter of the Northeast Quarter; THENCE South 89 deg. 24 min. 26 sec. West 93.80 feet to the TRUE POINT OF BEGINNING. Honea West Wellsite: Lot 51 of Honea Heights, a subdivision of Pima County, Arizona, according to the map or plat thereof of record in the Office of the County Recorder of Pima County, Arizona, in Book 12 at Page 58 thereof. CMID Well 22.1: That certain parcel or tract of land lying in the Northeast Quarter of the Southwest Quarter of Section 22, Township 11 South, Range 11 East, Gila and Salt River Base and Meridian, Pima County, Arizona, more particularly described as follows: COMMENCING at the Northwest corner of said Northeast Quarter of the Southwest Quarter of Section 22; RUN THENCE North 89 degrees 38 minutes 30 seconds East, along the interior quarter line of said Section 22, a distance of 689.03 feet to a point on a line parallel to and 420 feet from the center line of the Southern Pacific Railroad right-of way; RUN THENCE South 49 degrees 50 minutes East, along said line parallel to the Southern Pacific Railroad right-of-way, a distance of 505.50 feet to the TRUE POINT OF BEGINNING of the parcel herein described; RUN THENCE South 49 degrees 50 minutes East, a distance of 120 feet to a point; RUN THENCE South 40 degrees 10 minutes West, a distance of 60 feet to a point; RUN THENCE North 49 degrees 50 minutes West, a distance of 120 feet to a point; RUN THENCE North 40 degrees 10 minutes East, a distance of 60 feet to the TRUE POINT OF BEGINNING; EXCEPTING therefrom any part lying within Avra Street as such street is shown on the plat of Marana Estates Subdivision No. 1 as recorded in Book 9 at page 85 of Maps and Plats in the Office of the County Recorder of Pima County, Arizona. CMID Well 28.2: The South 50 feet of the North 355 feet of the East 110 feet of the Northeast Quarter of the Northeast Quarter, Section 28, Township 11 South, Range 11 East, Gila and Salt River Base and Meridian, Pima County, Arizona. A-6 EXCEPT that portion lying within Sandario Road and as shown on Book 2 of Road Maps at Page 173. CMID Well 17P2: The West 100 feet of the North 100 feet of Lot 147, of LA PUERTA DEL NORTE SUBDIVISION, according to the plat of record in the Office of the County Recorder of Pima County, Arizona, recorded in Book 15 of Maps, Page 76 thereof. CMID Well 8.1: That portion of the Southwest Quarter of the Northeast Quarter of the Southeast Quarter of Section 8, Township 12 South, Range 12 East, Gila and Salt River Base and Meridian, Pima County, Arizona, more particularly described as follows: COMMENCING at a point on the North right-of-way line of Avra Valley Road (as established by Proceedings No. 760-A of the Board of Supervisors of Pima County, State of Arizona) the map of which is filed in the Office of the County Recorder of Pima County, State of Arizona, in Book 6 of Roads at Page 43 thereof, which point is 383.5 feet Westerly (South 89 degrees 48 minutes 14 seconds West) from the intersection of said North right-of -way line of Avra Valley Road with the East line of said Section 8 and which point is the most Easterly corner of that property described in Docket Book 1799 at Page 227 thereof; THENCE North 39 degrees 11 minutes 15 seconds West along the Northeasterly line of said property described in Book 1799 at Page 227, a distance of 56.3 feet to a point; THENCE North 54 degrees 02 minutes 30 seconds West along the Northeasterly line of the property described in Book 1799 at Page 227, a distance of 450.00 feet to the TRUE POINT OF BEGINNING; THENCE South 35 degrees 57 minutes 30 seconds West, a distance of 70.0 feet to a point; THENCE North 54 degrees 02 minutes 30 seconds West, a distance of 60.0 feet to a point; THENCE North 35 degrees 57 minutes 30 seconds East, a distance of 70.00 feet to a point on the Northeasterly property line of said property described in Book 1799 at Page 227; THENCE South 54 degrees 02 minutes 30 seconds East, along said Northeasterly property line a distance of 60.0 feet to the TRUE POINT OF BEGINNING. DESCRIPTION OF TOWN HALL PROPERTY All of that portion of Northwest Quarter (NW 1/4) of Section 27, Township 11 South, Range 11 East, Gila and Salt River Meridian, Pima County, Arizona, described as follows: A-7 COMMENCING at the Southeast corner of said Northwest Quarter (NW 1/4) of Section; THENCE S 89°18'55" W, along the South line of said Northwest Quarter (NW 1/4) a distance of 496.69 feet; THENCE N 00°36'55"W, a distance of 25.00 feet to a point on a line parallel with and 25.00 feet North of said South line, also being the North right-of-way line of Barnett Road, being the POINT OF BEGINNING; THENCE S 89°18'55" W, along said right-of-way line a distance of 479.02 feet; THENCE N 00°36'55" W, 272.81 feet; THENCE N 44°26'48" E, 51.48 feet; THENCE N 45°33'12" W, 296.35 feet; THENCE continue N 45°33'12" W, 237.71 feet; THENCE N 44°26'48" E, 255.83 feet; THENCE along a tangent curve to the right, having a radius of 44.00 feet, a central angle of 48°22'50", for an arc length of 37.15 feet to a point of reverse curvature; THENCE along said reverse curve to the left, having a radius of 90.00 feet, a central angle of 96°45'40", for an arc length of 151.99 feet to a point of reverse curvature; THENCE along said reverse curve to the right, having a radius of 44.00 feet, a central angle of 48 °22' 50", for an arc length of 37.15 feet to a point of reverse curvature; THENCE N 44°26'48" E, 133.60 feet; THENCE along a tangent curve to the right, having a radius of 405.00 feet, a central angle of 44°52'08", for an arc length of 317.16 feet to a point of tangency; THENCE N 89°18'55" E, 160.53 feet to the Northwest corner of Parcel recorded in Docket 9348, Page 1408; THENCE S 00°36'55" E, along the West line of said parcel a distance of 160.00 feet to the Southwest corner thereof; THENCE S 89°18'55" E, along the South line of said parcel a distance of 255.00 feet to the West right-of-way line of Lon Adams Road; A-8 THENCE S 00°36'55" E, along said right-of-way line a distance of 426.51 feet to the Northeast corner of a parcel recorded in Docket 9325, Page 709; THENCE S 89°18'55" W, along the North line of said parcel a distance of 466.69 feet to the Northwest corner thereof; THENCE S 00°36'55" E, along West line of said parcel a distance of 466.69 feet to the Southwest corner thereof, being the POINT OF BEGINNING, Containing 15.88 acres, more or less. THENCE S 00°36'55" E, along said line a distance of 3 80 feet to the POINT OF BEGINNING, Containing 28,191 square feet, more or less. DESCRIPTION OF CORTARO SILVERBELL DISTRICT PARK PROPERTY (Add legal description) A-9 EXHIBIT B DESCRIPTION OF SIXTH PROJECT as well as, to the extent of amounts remaining in the Series 2008 Acquisition and Construction Fund created pursuant to the Series 2008 Supplemental Indenture after provision for all of the foregoing and prior to such amounts being the subject of the certificate provided in Section 4.03(b)(ii) of the Series 2008 Supplemental Indenture, to provide for any other sewer, transportation and park projects indicated in a requisition required by Section 4.03(b)(i) of the Series 2008 Supplemental Indenture. B-1 DRAFT 04/24/08 05/13/08 SERIES 2008 SUPPLEMENTAL TRUST INDENTURE FROM TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION TO WELLS FARGO BANK, NATIONAL ASSOCIATION (FORMERLY NORWEST BANK ARIZONA, N.A. AND WELLS FARGO BANK ARIZONA, N.A.), as Trustee TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION $ ,000 MUNICIPAL FACILITIES REVENUE BONDS, SERIES 2008 Consisting of $ ,000 $ ,000 Municipal Facilities Municipal Facilities Revenue Bonds, Revenue Bonds, Series 2008A Series 2008B Dated as of 1, 2008 TABLE OF CONTENTS Page ARTICLE I DEFINITIONS .............................................8 SECTION 1.01. Definitions .....................................8 SECTION 1.02. Interpretation .................................11 SECTION 1.03. Captions and Headings ..........................12 ARTICLE II AUTHORIZATION AND TERMS OF SERIES 2008 BONDS...........12 SECTION 2.01. Nonapplicable Provisions of the Indenture...... 12 SECTION 2.02. Authorized Amount of Series 2008 Bonds......... 12 SECTION 2.03. Issuance of Series 2008 Bonds ... ............... 13 SECTION 2.04. Delivery of Series 2008 Bonds ... ............... 14 SECTION 2.05. Form of Series 2008 Bonds ....... ............... 15 SECTION 2.06. Execution and Authentication of Series 2008 Bonds ........................... ............... 15 SECTION 2.07. Source of Payment of Series 2008 Bonds......... 15 SECTION 2.08. Additional Provisions Regarding Payment and Ownership ....................... ............... 15 ARTICLE III REDEMPTION OR PURCHASE OF SERIES 2008 BONDS............16 SECTION 3.01. Redemption of Series 2008 Bonds ................16 SECTION 3.02. Nonapplicable Provisions of the Indenture......16 SECTION 3.03. Terms of Redemption of Series 2008 Bonds.......16 ARTICLE IV PROVISIONS AS TO FUNDS AND PAYMENTS ....................18 SECTION 4.01. Expansion of Funds and Establishment of Costs of Issuance Fund, Series 2008 Acquisition and Construction Fund, and Series 2008 Insurer Reimbursement Fund.........18 SECTION 4.02. Application of Series 2008 Bond Proceeds.......18 SECTION 4.03. Disbursements From Costs of Issuance Fund and Series 2008 Acquisition and Construction Fund ..............................19 SECTION 4.04. Receipt of Revenues ............................19 SECTION 4.05. Flow of Funds ..................................20 SECTION 4.06. Investment of Funds ............................23 ARTICLE V ENFORCEMENT OF REVENUE PLEDGE; EXCLUSIVE PLEDGE; RECORD OF SURETY BOND PAYMENTS .........................24 SECTION 5.01. Enforcement of Revenue Pledge ..................24 SECTION 5.02. Exclusive Pledge ...............................24 ARTICLE VI PARITY OF PLEDGE OF REVENUES ...........................25 SECTION 6.01. Parity of Pledge of Revenues ...................25 i Page ARTICLE VII MISCELLANEOUS PROVISIONS ...............................25 SECTION 7.01. Cancellation ................................... 25 SECTION 7.02. Certain References ............................. 25 SECTION 7.03. Consent of Insurer ............................. 26 SECTION 7.04. Notices and Other Information .................. 26 SECTION 7.05. Matters Relating to Defeasance ................. 27 SECTION 7.06. Certain Limitations on Refundings and Purchases of Series 2008 Bonds and Distribution of Funds to Corporation or Town ........................................... 27 SECTION 7.07. Payment Procedure Pursuant to Series 2008 Bond Insurance Policy .......................... 28 SECTION 7.08. Provisions Relating to Trustee ................. 30 SECTION 7.09. Series 2008 Insurer as Third Party Beneficiary .................................... 30 SECTION 7.10. Benefitted Parties ............................. 31 ARTICLE VIII INTEGRATION OF DOCUMENTS ...............................31 SECTION 8.01. The Indenture and the Series 2008 Supplemental Indenture .........................31 SECTION 8.02. Indenture to Remain in Effect, Except as Modified .......................................31 SECTION 8.03. References to Town Lease .......................31 EXHIBIT A Form of Series 2008 Bond ...........................A-1 ii SERIES 2008 SUPPLEMENTAL TRUST INDENTURE THIS SERIES 2008 SUPPLEMENTAL TRUST INDENTURE, dated as of 1, 2008 (this "Supplemental Indenture"), by and between TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION, a nonprofit corporation organized and existing under the laws of the State of Arizona (the "Corporation"), and WELLS FARGO BANK, NATIONAL ASSOCIATION (formerly NORWEST BANK ARIZONA, N.A. and WELLS FARGO BANK ARIZONA, N.A.), a national banking association organized and existing under the laws of the United States of America and authorized to exercise corporate trust powers in the State of Arizona, having a designated corporate trust office located in the City of Phoenix, Arizona, as trustee (the "Trustee"): W I T N E S S E T H: WHEREAS, the Corporation was formed to transact any or all lawful business for which nonprofit corporations may be incorporated under the laws of the State of Arizona, including, without limiting the generality of the foregoing, any civic or charitable purpose such as financing the cost of acquiring, constructing, reconstructing or improving buildings, equipment or other real and personal properties suitable for use by and for leasing to the Town of Marana, Arizona (the "Town"), or its agencies or instrumentalities; and WHEREAS, the Town heretofore determined that it was beneficial to its citizens (i) to acquire the water system owned by Clifford Ray Honea and Ethel Wynema Honea, husband and wife, doing business as Honea Water Company (the "First Water System"), consisting of certain real property and certain personal property (the "Initial First Water System Improvements") with respect to the First Water System and (ii) to acquire the facility then being used as the municipal complex for the Town (the "Municipal Complex"), consisting of certain other real property and to make certain necessary improve- ments to the First Water System (the "New First Water System Improve- ments" and collectively, with the Initial First Water System Improve- ments, the "First Water System Improvements" and the acquisition of the First Water System, the acquisition of the Municipal Complex and the making of the New First Water System Improvements, collectively, the "First Project"); and WHEREAS, the Corporation assisted the Town in financing the First Project; and WHEREAS, in order to finance the costs of the First Proj- ect, the Corporation issued its $280,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 1990, dated as of March 1, 1990, and its $315,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 1992, dated as of June 1, 1992 (collectively, the "Prior Bonds"); and WHEREAS, the Town further heretofore determined that it was beneficial to its citizens (i) to refinance the Prior Bonds and (ii)(A) to acquire the water systems known as "Cortaro Marana" and "Marana Water Service" (the "Second Water Systems"), consisting of certain real property and certain personal property (the "Second Water Systems Improvements" and collectively, with the First Water System Improvements, the "Water System Improvements") with respect to the Second Water Systems and (B) to (I) make certain improvements to the Water System Improvements, (II) make certain road and related improve- ments and construct improvements to increase traffic capacity on certain other roads, (III) acquire certain real property upon which to construct a new municipal complex (the "Town Hall Property") and (IV) make tenant improvements to certain office space leased to the Town, the projects described in clauses (B)(I), (II) and (IV) collectively, with the acquisition of the Second Water Systems and the project described in clause (B)(II), being referred to herein as the "Second Project"; and WHEREAS, the Corporation assisted the Town in refinancing the Prior Bonds and in financing the Second Project; and WHEREAS, in order to refinance the Prior Bonds and to finance the Second Project, the Corporation issued its $8,175,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 1997, dated as of October 1, 1997 (the "Series 1997 Bonds"), pursuant to a Trust Indenture, dated as of October 1, 1997 (as supplemented, the "Inden- ture"), from the Corporation to the Trustee; and WHEREAS, the Town also heretofore determined that it was beneficial to its citizens to design, acquire, construct and equip the new municipal complex on the Town Hall Property (the "Third Project"); provided however that pursuant to (i) the Second Amendment to Base Town Lease referred to in the definition of "Base Town Lease" certain addi- tional property (the "Operations Center Property") has been ground leased by the Town to the Corporation and leased back by the Corpora- tion to the Town, the Operations Center Property thereafter being considered part of the Town Hall Property for all purposes of the First Supplement to the Base Town Lease referred to in the definition of "Base Town Lease," and certain changes have been made to the descrip- tion of the Town Hall Improvements to include a town operations center to house public works, police, water, vehicle asset management and information system and (ii) the Third Amendment to Base Town Lease referred to in the definition of "Base Town Lease" a portion of the Operations Center Property has been released from the provisions of the First Supplement to Base Town Lease and another parcel of property donated to the Corporation added as part of the Town Hall Property for all purposes of such First Supplement to Base Town Lease; and WHEREAS, the Corporation assisted the Town in financing the Third Project; and 2 WHEREAS, in order to finance the costs of the Third Project, the Corporation issued its $10,000,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2000, dated as of February 1, 2000, all of which have now been paid or defeased; and WHEREAS, the Town also heretofore determined that it was beneficial to its citizens to design, acquire, construct and equip, as the case may be, additional parts of the new municipal complex on the Town Hall Property (the "Fourth Project"); and WHEREAS, the Corporation assisted the Town in financing the Fourth Project; and WHEREAS, in order to finance the costs of the Fourth Proj- ect, the Corporation issued its $19,700,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2003, dated as of September 1, 2003 (the "Series 2003 Bonds"); and WHEREAS, the Town also heretofore determined that it was beneficial to its citizens to design, acquire, construct and equip, as the case may be, final parts of the new municipal complex on the Town Hall Property (the "Fifth Project") and to refinance a portion of the bonds heretofore issued by the Corporation (the "Bonds Being Refunded"); and WHEREAS, the Corporation assisted the Town in financing the Fifth Project and refinancing the Bonds Being Refunded (the "Second Refunding"); and WHEREAS, in order to finance the costs of the Fifth Project and the Second Refunding, the Corporation issued its $8,675,000 aggre- gate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2004, dated as of August 1, 2004 (the "Series 2004 Bonds"); and WHEREAS, the Town has now determined that it will be bene- ficial to its citizens to design, acquire, construct and equip, as the case may be, extensions and additions to the sewer lines and interceptors in Silverbell Road and to the Town's Airport, extensions and improvements to Camino de Marana and Dove Mountain Roads and improvements to Cortaro Silverbell District Park as well as other sewer, transportation and park projects as described in Exhibit B attached to the hereinafter described Series 2008 Town Lease (the "Sixth Project") and to refinance a portion of the bonds heretofore issued by the Corporation (the "Bonds Being Refunded"); and WHEREAS, the Corporation desires to assist the Town in financing the Sixth Project and refinancing the Bonds Being Refunded (the "Third Refunding"); and 3 WHEREAS, in order to finance the costs of the Sixth Project and the Third Refunding, the Corporation and the Town deem it necessary and desirable for the Corporation to issue its $ ,000 aggregate principal amount of Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2008, dated as of 1, 2008, and consisting of its $ ,000 principal amount of Municipal Facilities Revenue Bonds, Series 2008A (the "Series 2008A Bonds") and $ ,000 principal amount of Municipal Facilities Revenue Bonds, Series 2008B (the "Series 2008B Bonds" and, together with the Series 2008A Bonds, the "Series 2008 Bonds"); and WHEREAS, in connection with the sale and issuance of the Series 2008 Bonds, the Corporation shall enter into a Combined Cortaro Silverbell District Park Ground Lease and Fourth Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, to be dated as of the first day of the month established as the dated date of the Series 2008 Bonds as provided herein (the "Fourth Supplement to Base Town Lease"), with the Town pursuant to which, among other things (i) the Corporation will extend the lease of the Existing Leased Property (as such term is defined in the Fourth Supplement to Base Town Lease) to the Town, lease back certain real property (the "Cortaro Silverbell Park Property") ground leased by the Town pursuant thereto and lease the Sixth Project to the Town and (ii) the Town shall (A) ground lease the Cortaro Silverbell Park Property to the Corporation and lease the same back from the Corporation, extend the lease of the Existing Leased Property from the Corporation and lease the Sixth Project from the Corporation and (B) as agent for the Corporation, agree to design, acquire, construct and equip, as the case may be, the Sixth Project and provide for matters related to the Third Refunding; and WHEREAS, the Series 2008 Bonds shall be secured by the Indenture, as supplemented by this Supplemental Indenture; and WHEREAS, the Corporation has not made and does not intend to make any profit by reason of any business or venture in which it may engage or by reason of the assistance it renders the Town in financing the Sixth Project and the Third Refunding and no part of the net earnings of the Corporation, if any, will ever inure to the benefit of any person, firm or corporation except the Town; and WHEREAS, the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds, the Series 2008 Bonds and any Additional Bonds (as such term and all other capitalized terms hereinafter used are defined in Section 1.01 of this Supplemental Indenture) shall be secured by the Indenture as supplemented by this Supplemental Indenture, and the Corporation is authorized to execute and deliver this Supplemental Indenture and to do, or cause to be done, all acts provided or required herein to be performed on its part; and WHEREAS, all acts and conditions required to happen, exist and be performed precedent to and in the issuance of the Series 2008 Bonds and the execution and delivery of this Supplemental Indenture 4 have happened, exist and have been performed, or at the delivery of the Series 2008 Bonds shall exist, shall have happened and shall have been performed (i) to make the Series 2008 Bonds, when issued, deliv- ered and authenticated, valid obligations of the Corporation in accor- dance with the terms thereof and hereof and (ii) to make this Supple- mental Indenture a valid, binding and legal trust agreement for the security of the Series 2008 Bonds in accordance with its terms; and WHEREAS, the Trustee has accepted the trusts created by this Supplemental Indenture and in evidence thereof has joined in the execution hereof; NOW, THEREFORE, THIS SUPPLEMENTAL INDENTURE WITNESSETH, that to secure, first, the payment of Bond Service Charges on the Bonds and, second, pro-rata, payments to the Series 1997 Insurer pur- suant to the Series 1997 Guaranty Agreement, the Series 2000 Insurer pursuant to the Series 2000 Guaranty Agreement, the Series 2003 Insur- er pursuant to the Series 2003 Guaranty Agreement, the Series 2004 Insurer pursuant to the Series 2004 Guaranty Agreement and the Series 2008 Insurer pursuant to the Series 2008 Guaranty Agreement according to their true intent and meaning, to secure the performance and observance of all of the covenants, agreements, obligations and conditions contained therein and herein, and to declare the terms and conditions upon and subject to which the Series 2008 Bonds are and are intended to be issued, held, secured and enforced, and in consideration of the premises and the acceptance by the Trustee of the trusts created herein and of the purchase and acceptance of the Series 2008 Bonds by the Owners and the provision of the Series 2008 Surety Bond pursuant to the Series 2008 Guaranty Agreement, and for other good and valuable consideration, the receipt of which is acknowledged, the Corporation has executed and delivered this Supplemental Indenture and absolutely assigns hereby to the Trustee, and to its successors in trust, and its and their assigns, all right, title and interest of the Corporation in and to (i) the right, title and interest of the Corporation in and to the Series 2008 Town Lease, the Corporation, however, to remain liable to observe and perform all of the conditions and covenants in the Town Lease provided to be observed and performed by it; (ii) all of the rents, issues and profits payable to or received by the Corporation from the property described in paragraph (i) above, including without limitation, all of the rents and the amounts to be paid to the Corporation or the Trus- tee under the terms of the Series 2008 Town Lease, except pay- ments with respect to the Corporation's Unassigned Rights and (iii) all property which is by the express provisions of this Supplemental Indenture required to be subjected to the lien hereof and any additional property that may, from time to time hereafter, by delivery or by writing of any kind, be subjected to the lien hereof, by the Corporation or by anyone in 5 its behalf, and the Trustee is hereby authorized to receive the same at any time as additional security hereunder, SUBJECT, HOWEVER, to the rights of access and control in the Town as reserved and granted in Section 9.02 of the Series 2008 Town Lease; TO HAVE AND TO HOLD unto the Trustee and its successors in that trust and its and their assigns forever; hereof, BUT IN TRUST, NEVERTHELESS, and subject to the provisions (a) except as otherwise provided herein, first, for the equal and proportionate benefit, security and protection of all present and future Owners of the Bonds issued or to be issued under and secured by the Indenture and this Supplemental Inden- ture, and second, pro-rata, for the benefit of the provider of any Qualified Surety Bond, including, with respect to the Series 1997 Bonds, the Series 1997 Insurer, with respect to the Series 2000 Bonds, the Series 2000 Insurer, with respect to the Series 2003 Bonds, the Series 2003 Insurer, with respect to the Series 2004 Bonds, the Series 2004 Insurer and, with respect to the Series 2008 Bonds, the Series 2008 Insurer with respect to pay- ments to the Series 1997 Insurer pursuant to the Series 1997 Guaranty Agreement, to the Series 2000 Insurer pursuant to the Series 2000 Guaranty Agreement, to the Series 2003 Insurer pursuant to the Series 2003 Guaranty Agreement, to the Series 2004 Insurer pursuant to the Series 2004 Guaranty Agreement and to the Series 2008 Insurer pursuant to the Series 2008 Guaranty Agreement, (b) for the enforcement of the payment of the princi- pal of and interest and any premium on the Bonds, when payable, according to the true intent and meaning thereof and of this Supplemental Indenture, and for the enforcement of payments to any such provider, including the Series 1997 Insurer pursuant to the Series 1997 Guaranty Agreement, the Series 2000 Insurer pur- suant to the Series 2000 Guaranty Agreement, the Series 2003 Insurer pursuant to the Series 2003 Guaranty Agreement, the Series 2004 Insurer pursuant to the Series 2004 Guaranty Agreement and the Series 2008 Insurer pursuant to the Series 2008 Guaranty Agreement and (c) to secure the performance and observance of and compliance with the covenants, agreements, obligations, terms and conditions of this Supplemental Indenture, in each case, without preference, priority or distinction, as to lien or otherwise, except as otherwise provided herein, of any one Bond over any other by reason of series, designation, number, date of the Bonds or of authorization, issuance, sale, execution, authentication, delivery or maturity thereof, or otherwise, so that, except as other- 6 wise provided herein, each Bond of a series and all Bonds of a series shall have the same right, lien and privilege under the Indenture, and, except as otherwise provided herein, shall be secured equally and ratably hereby and thereby, it being intended that the lien and security of this Supplemental Indenture shall take effect from the date hereof, without regard to the date of actual issue, sale or dis- position of the Series 2008 Bonds, as though upon that date all of the Series 2008 Bonds were actually issued, sold and delivered to pur- chasers 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 by redemption of any of the Bonds prior to maturity, shall be well and truly paid, at all 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 dis- charged in accordance with Article X of the Indenture, and (ii) all of the covenants, agreements, obligations, terms and conditions of the Corporation under this Supplemental Indenture shall have been kept, performed and observed, and there shall have been paid to the Trustee, the Registrar and the Paying Agents, as well as the provider of any Qualified Surety Bond, including, with respect to the Series 1997 Bonds, the Series 1997 Insurer, with respect to the Series 2000 Bonds, the Series 2000 Insurer, with respect to the Series 2003 Bonds, the Series 2003 Insurer, with respect to the Series 2004 Bonds, the Series 2004 Insurer and, with respect to the Series 2008 Bonds, the Series 2008 Insurer, all sums of money due or to become due to them in accordance with the terms and provisions hereof, then, this Supplemental Indenture and the rights assigned hereby shall cease, determine and be void, except as provided in Section 10.03 of the Indenture with respect to the survival of certain provisions hereof; otherwise, this Supplemental Indenture shall be and remain in full force and effect. It is declared that all Series 2008 Bonds issued hereunder and secured hereby are to be issued, authenticated and delivered, and that all Revenues assigned hereby are to be dealt with and disposed of under, upon and subject to, the terms, conditions, stipulations, cove- nants, agreements, obligations, trusts, uses and purposes provided in the Indenture. The Corporation has agreed and covenanted, and agrees and covenants with the Trustee and with each and all Owners as well as the provider of any Qualified Surety Bond, including, with respect to the Series 1997 Bonds, the Series 1997 Insurer, with respect to the Series 2000 Bonds, the Series 2000 Insurer, with respect to the Series 2003 Bonds, the Series 2003 Insurer and, with respect to the Series 2008 Bonds, the Series 2008 Insurer, as follows: 7 ARTICLE I SECTION 1.01. herein shall have the same the Indenture, except as hereinafter: DEFINITIONS Definitions. meanings as provided All words and terms used set forth in Section 1.01 of in the Recitals hereto and "Base Town Lease" means the Amended and Restated Town Lease and Series 1992 Town Lease, dated as of October 1, 1997, by and between the Town and the Corporation, as amended by the First Amend- ment to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of February 1, 2000, the Combined Operations Center Property Ground Lease and Second Amendment to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of April 1, 2002 (the "Second Amendment to Base Town Lease") and the Third Amendment to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of September 1, 2003 (the "Third Amendment to Base Town Lease"), and supplemented by the First Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of February 1, 2000 (the "First Supplement to Base Town Lease"), the Second Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of September 1, 2003 (the "Second Supplement to Base Town Lease") and the Third Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of August 1, 2004 (the "Third Supplement to Base Town Lease"). "Bond Resolution" means when used with reference to the Series 2008 Bonds, the resolution providing for their issuance and the approving of the Series 2008 Town Lease, the Series 2008 Supplemental Indenture and related matters. "Bonds" means the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2008 Bonds and any Additional Bonds. "Corporation's Unassigned Ri hts" means all of the rights of the Corporation to receive additional payments under Section 1.04 (iii), (iv) and (vi) of the Town Leases, to be held harmless and indemnified under Article VIII thereof, to be reimbursed for attor- neys' fees and expenses under Sections 8.04 and 8.05 thereof, to receive notice thereunder and to give or withhold consent to amend- ments, changes, modifications and alterations of the Town Leases and its right to enforce such rights. "Costs of Issuance" means all items of expense directly relating to the cost of issuing the Series 2008 Bonds. "Costs of Issuance Fund" means the Costs of Issuance Fund created in Section 4.01 hereof. "DTC" means The Depository Trust Company, a limited purpose trust company organized under the laws of the State of New York, and its successors and assigns. 8 "Debt Service Payments" means those payments required to be made by or on behalf of the Corporation which will be applied to payment of principal of and interest on the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds and the Series 2008 Bonds. "Escrow Trust Agreement" means the Escrow Trust Agreement, dated as of 1, 2008, from the Corporation to the Escrow Trustee, as amended or supplemented from time to time. "Escrow Trustee" means Wells Fargo Bank, National Associa- tion, a banking entity organized under the laws of the United States of America and authorized to exercise trust powers under the laws of the State, as escrow trustee, and its successors and assigns. "Interest Payment Date" or "Interest Payment Dates" means, as to the Series 2008 Bonds, the date or dates set forth as such in the form of bond attached hereto as Exhibit A. "Original Purchaser" means, as to the Series 2008 Bonds, Stone & Youngberg LLC. "Paying Agent" means, as to the Series 2008 Bonds, the Trustee. "Principal Payment Date" or "Principal Payment Dates" means, as to the Series 2008 Bonds, January 1 and July 1 in the years specified in Section 2.03 of this Supplemental Indenture for the stated amount of principal to be retired at maturity, or any other date on which the principal of the Series 2008 Bonds is payable as a result of redemption, optional or mandatory. "Registrar" means, as to the Series 2008 Bonds, the Trus- tee, until a successor Registrar shall have become such pursuant to applicable provisions of the Indenture. "Revenues" means (a) the rental payments due under the Town Leases, (b) all other moneys received or to be received by the Corporation or the Trustee in respect of the Town Leases, including without limitation, moneys and investments in the Bond Retirement Fund and (c) all income and profit from. the investment of the foregoing moneys. "Securities Depository" means a "clearing agency" (securi- ties depository) registered under Section 17A of the Securities Exchange Act of 1934, as amended, which is the owner of the Series 2008 Bonds. "Series 1997 Guaranty A reement" means the Financial Guar- anty Agreement, dated as of October 1, 1997, by and between the Town, the Corporation and the Series 1997 Insurer. 9 "Series 1997 Insurer" means MBIA Insurance Corporation, a corporation organized under the laws of the State of New York. "Series 2000 Guaranty Agreement" means the Guaranty Agree- ment, dated as of February 1, 2000, by and between the Corporation and the Series 2000 Insurer. "Series 2000 Insurer" means Ambac Assurance Corporation, a Wisconsin-domiciled stock insurance company. "Series 2003 Guaranty Agreement" means the Guaranty Agree- ment, dated as of September 1, 2003, by and between the Corporation and the Series 2003 Insurer. "Series 2003 Insurer" means Ambac Assurance Corporation, a Wisconsin-domiciled stock insurance company. "Series 2004 Guaranty A reement" means the Guaranty Agree- ment, dated as of September 1, 2003, by and between the Corporation and the Series 2003 Insurer. "Series 2004 Insurer" means Ambac Assurance Corporation, a Wisconsin-domiciled stock insurance company. "Series 2008 Acquisition and Construction Fund" means the Acquisition and Construction Fund created in Section 4.01 hereof. "Series 2008 Costs of Acquisition and Construction" means all items of expense directly or indirectly relating to the cost of designing, acquiring, constructing and equipping the Fourth Project, including, but not limited to, the following: (a) Costs previously or hereafter incurred by the Town in connection with designing, acquiring, constructing and equipping of the Sixth Project. (b) Expenses incurred by the Town for labor, serv- ices, materials and supplies used or furnished in acquiring, constructing and equipping of the Sixth Project. (c) Fees paid by the Town for legal, design, archi- tectural, engineering, construction, management, consulting and supervisory services with respect to the Sixth Project, includ- ing, without limitation, the cost of preparing or obtaining plans and specifications, working drawings, bids, appraisals, approv- als, permits and inspections. (d) Expenses incurred by the Town in seeking to en- force any remedy against any contractor, subcontractor, materi- alman, vendor, supplier or surety in respect of any default under a contract relating to constructing and equipping the Sixth Project. 10 (e) Any sums required to reimburse the Town for advances made by it for any of the above items. "Series 2008 Demand for Payment"[???] means the certificate to be submitted by the Trustee to the Series 2008 Insurer for payment under the Series 2008 Surety Bond substantially in the form attached to the Series 2008 Surety Bond as Attachment 1. "Series 2008 Guaranty Agreement"[???] means the Guaranty Agreement, dated as of 1, 2008, by and between the Corporation and the Series 2008 Insurer. "Series 2008 Insurer"[???] means Ambac Assurance Corporation, a Wisconsin-domiciled stock insurance company. "Series 2008 Insurer Reimbursement Fund" means the Series 2008 Insurer Reimbursement Fund established pursuant to Section 4.01 hereof. "Series 2008 Municipal Bond Insurance Policy" means the municipal bond insurance policy issued by the Series 2008 Insurer insuring the payment when due of the principal of and interest on the Series 2008 Bonds as provided therein. "Series 2008 Surety Bond"[???] means that surety bond, attached as Annex A to the Series 2008 Guaranty Agreement, issued by the Series 2008 Insurer guaranteeing, subject to the terms and limitations thereof, Debt Service Payments with respect to the Series 2008 Bonds required to be made by the Corporation under this Supplemental Indenture. "Series 2008 Surety Bond Coverage"[???] means the amount available at any particular time to be paid under the terms of the Series 2008 Surety Bond, which amount shall never exceed the Series 2008 Surety Bond Limit. "Series 2008 Surety Bond Limit"[???] means $830,807.96. "Town Leases" means, collectively, the Base Town Lease and the Series 2008 Town Lease. SECTION 1.02. Interpretation. (a) Any reference herein to the Corporation, to the Board of Directors or to any member or officer of either, includes entities or officials succeeding to their respective functions, duties or responsibilities pursuant to or by operation of law or lawfully performing their functions. (b) 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 Arizona Revised Statutes, or to any statute of the United States of America, includes that section, provision or chapter 11 as amended, modified, 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 this provision, if it constitutes in any way an impairment of the rights or obligations of the Corporation, the Own- ers, the Trustee, the Registrar or the Corporation under this Supple- mental Indenture, the Bond Resolution, the Series 2008 Bonds, the Series 2008 Town Lease, the Series 2008 Guaranty Agreement or any other instrument or document entered into in connection with any of the foregoing, including without limitation, any alteration of the obligation to pay Bond Service Charges in the amount and manner, at the times, and from the sources provided in the Bond Resolution and this Supplemental Indenture, except as permitted herein. (c) Unless the context indicates otherwise, words importing the singular number include the plural number, and vice versa; the terms "hereof," "hereby," "herein," "hereto," "hereunder" and similar terms refer to this Supplemental Indenture; and the term "hereafter" means after, and the term "heretofore" means before, the date of this Supplemental 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 Supplemental 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. ARTICLE II AUTHORIZATION AND TERMS OF SERIES 2008 BONDS SECTION 2.01. Nonapplicable Provisions of the Indenture. The provisions of Sections 2.02 and 2.03 of the Indenture shall not apply to the Series 2008 Bonds. SECTION 2.02. Authorized Amount of Series 2008 Bonds. No Series 2008 Bonds may be issued under the provisions of this Sup- plemental Indenture except in accordance with this Article. The Series 2008 Bonds authorized to be issued under this Supplemental Indenture shall be designated as the "Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2008A" and the "Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2008B." The total authorized aggregate principal amount of the Series 2008 Bonds which shall be issued under the provisions of this Supplemental Indenture is $ ,000, consisting of $ ,000 principal amount of the Series 2008A Bonds and $ ,000 principal amount of the Series 2008B Bonds. The Corporation may issue, sell and deliver one or more series of 12 Additional Bonds for the purposes, upon satisfaction of the conditions and in the manner provided in Section 2.04 of the Indenture. SECTION 2.03. Issuance of Series 2008 Bonds. (a) (i) It is determined to be necessary to, and the Corporation shall, sell, issue and deliver $ ,000 principal amount of the Series 2008A Bonds. The Series 2008A Bonds shall be issuable only in fully registered form, substantially as set forth in Exhibit A-1 to this Supplemental Indenture; shall be numbered in such manner as determined by the Trustee in order to distinguish each Series 2008A Bond from any other Bond; shall be in the denominations of $5,000 of principal amount and any integral multiple thereof; shall be dated [as of???] 1, 2008; and shall bear interest 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 for, from their date, payable semiannually on July 1 and January 1 of each year, commencing on 1, 200 (ii) The Series 2008A Bonds shall bear interest at the rates, and mature in the principal amounts on the dates, as follows: Maturity Principal Dates Amount January 1, 2009 $ ,000 July 1, 2009 ,000 January 1, 2010 ,000 July 1, 2010 ,000 January 1, 2011 ,000 July 1, 2011 ,000 January 1, 2012 ,000 July 1, 2012 ,000 January 1, 2013 ,000 July 1, 2013 ,000 January 1, 2014 ,000 July 1, 2014 ,000 January 1, 2015 ,000 July 1, 2015 ,000 January 1, 2016 ,000 July 1, 2016 ,000 January 1, 2017 ,000 July 1, 2017 ,000 January 1, 2018 ,000 July 1, 2018 ,000 January 1, 2019 ,000 July 1, 2019 ,000 July 1, 2020 ,000 July 1, 2025 ,000 Interest Rate 13 (b) (i) It is determined to be necessary to, and the Corporation shall, sell, issue and deliver $ ,000 principal amount of Series 2008B Bonds. The Series 2008B Bonds shall be issuable only in fully registered form, substantially as set forth in Exhibit A-2 to this Supplemental Indenture; shall be numbered in such manner as determined by the Trustee in order to distinguish each Series 2008B Bond from any other Bond; shall be in the denominations of $5,000 and any integral multiple thereof; shall be dated [as of???] 1, 2008; and shall bear interest 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 for, from their date, payable semiannually on July 1 and January 1 of each year commencing 1, 200 (ii) The Series 2008B Bonds shall bear interest at the rates, and mature in the principal amounts on the dates, as follows: Maturity Dates Principal Dmr~iint Interest RatA January 1, 2009 July 1, 2009 January 1, 2010 July 1, 2010 January 1, 2011 July 1, 2011 January 1, 2012 July 1, 2012 January 1, 2013 July 1, 2013 January 1, 2014 July 1, 2014 January 1, 2015 July 1, 2015 January 1, 2016 July 1, 2016 January 1, 2017 July 1, 2017 January 1, 2018 July 1, 2018 January 1, 2019 July 1, 2019 July 1, 2020 July 1, 20 SECTION 2.04 $ ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 0 Delivery of Series 2008 Bonds. (a) Upon the execution and delivery of this Supple- mental Indenture, and satisfaction of the conditions established by the Corporation for delivery of the Series 2008 Bonds, the Corporation 14 shall execute the Series 2008 Bonds and deliver them to the Trustee. Thereupon, the Trustee shall authenticate the Series 2008 Bonds and deliver them to, or on the order of, the Original Purchaser thereof, as directed by the Corporation in accordance with this Section 2.04. (b) Prior to delivery by the Trustee of any Series 2008 Bonds, there shall have been received by the Trustee a request and authorization to the Trustee on behalf of the Corporation, signed by the President or the Secretary, to authenticate and deliver the Series 2008 Bonds to, or on the order of, the Original Purchaser upon payment to the Trustee of the amounts specified therein (including without limitation, any accrued interest), which amounts shall be deposited as provided in Article IV hereof. SECTION 2.05. Form of Series 2008 Bonds. The Series 2008A Bonds and the Series 2008B Bonds shall be substantially in the forms set forth in Exhibit A-1 and Exhibit A-2, respectively, to this Supplemental Indenture, with any omissions, insertions and variations which may be authorized or permitted by the Bond Resolution or this Supplemental Indenture. SECTION 2.06. Execution and Authentication of Series 2008 Bonds. No Series 2008 Bond shall be valid or become obligatory for any purpose or shall be entitled to any security or benefit under the Indenture or this Supplemental Indenture unless and until a certificate of authentication, substantially in the form set forth in Exhibit A to this Supplemental Indenture, shall have been signed by an authorized representative of the Trustee on behalf of the Trustee. SECTION 2.07. Source of Payment of Series 2008 Bonds. To the extent provided in and except as otherwise permitted by the Indenture and this Supplemental Indenture, the Series 2008 Bonds shall be special obligations of the Corporation and the Bond Service Charges thereon shall be payable equally and ratably solely from the Revenues; provided, that payment of Bond Service Charges on any series of Additional Bonds may be otherwise secured and protected from sources or by property or instruments not applicable to the Series 2008 Bonds and any one or more series of Additional Bonds. Notwithstanding anything to the contrary in the Bond Resolution, the Series 2008 Bonds or this Supplemental Indenture, the Series 2008 Bonds do not and shall not represent or constitute a debt or pledge of the faith and credit of the Corporation or the taxing power of the Town or of the State or of any political subdivision, municipality or other local agency thereof. SECTION 2.08. Additional Provisions Regardin Payment and Ownership. The Trustee and the Corporation may from time to time enter into, and discontinue, an agreement with a Securities Depository to establish procedures with respect to the Series 2008 Bonds not inconsistent with the provisions of the Indenture; provided, that, notwithstanding any other provisions of the Indenture, any such agree- ment may provide that different provisions for notice to the Securi- ties Depository may be set forth therein and that a legend shall 15 appear on each Series 2008 Bond so long as the Series 2008 Bonds are subject to such agreement. With respect to Series 2008 Bonds regis- tered in the name of a Securities Depository (or its nominee), neither the Trustee nor the Corporation shall have any obligation to any of its members or participants or to any person on behalf of whom an interest is held in the Series 2008 Bonds . It is hereby acknowledged that the Corporation and the Trustee intend to enter into an agreement with DTC in connection with the issuance of the Series 2008 Bonds, and while such agreement is in effect, the procedures established therein shall apply to the Series 2008 Bonds notwithstanding any other provi- sions of this Supplemental Indenture to the contrary. As long as DTC is the Securities Depository with respect to the Series 2008 Bonds, the Trustee shall be a "DTC Direct Participant." ARTICLE III REDEMPTION OR PURCHASE OF SERIES 2008 BONDS SECTION 3.01. Redemption of Series 2008 Bonds. Under the terms of the Series 2008 Town Lease money may be paid or credited for the purpose of redeeming Series 2008 Bonds when redeemable or pur- chasing Series 2008 Bonds when permitted hereunder. The Corporation covenants that any and all money received by it which, pursuant to the Town Lease, is to be used to redeem or purchase Series 2008 Bonds shall be paid to the Trustee under this Supplemental Indenture, and in such event, the Trustee shall deposit the same in the Bond Retirement Fund and shall use any and all such money to prepay and redeem or purchase Series 2008 Bonds in accordance with their terms and the provisions of this Article III. SECTION 3.02. Nonapplicable Provisions of the Indenture. The provisions of Section 4.02 of the Indenture shall not apply to the Series 2008 Bonds. SECTION 3.03. Terms of Redemption of Series 2008 Bonds. (a) (i) Optional Redemption - Series 2008A Bonds. The Series 2008A Bonds maturing on or after 1, 20 are subject to redemption, at the option of the Corporation, in whole at any time, or in part on any Interest Payment Date, in any order of maturity and by lot within a maturity, on or after 1, 20 , or any Interest Payment Date thereafter at the redemption price of the principal amount to be redeemed, plus accrued interest to the date fixed for redemption, without premium. (ii) Mandatory Redemption - Series 2008A Bonds. (A) The Series 2008A Bonds maturing on 1, 20 , are subject to mandatory redemption on the dates and in the amounts set forth below, at a redemption price equal to the principal amount thereof plus interest accrued to the date of redemption: 16 Date Principal Amount 1, 20 $ ,000 Not more than forty-five (45) days nor less than thirty (30) days prior to the mandatory redemption payment date for the Series 2008A Bonds maturing on 1, 20_, the Trustee shall proceed to select for redemption (by lot in such manner as the Trustee may determine) from all of the Series 2008A Bonds maturing on 1, 20 a principal amount of the Series 2008A Bonds equal to the aggregate principal amount of the Series 2008A Bonds redeemable with the required mandatory redemption payment, and shall call such Series 2008A Bonds for redemption on the next 1 and give notice of such call. (B) The 1, 20_, are subject to 1, on the dates and in the amounts price equal to the principal amoun the date of redemption: Series 2008A Bonds .maturing on mandatory redemption on set forth below, at a redemption t thereof plus interest accrued to Date Principal Amount 1, 20 $ ,000 1, 20 ,000 1, 20 ,000 1, 20 ,000 1, 20 ,000 1, 20 ,000 1, 20 ,000 1, 20 ,000 1, 20 ,000 Not more than forty-five (45) days nor less than thirty (30) days prior to the mandatory redemption payment date for the Series 2008A Bonds maturing on 1, 20_, the Trustee shall proceed to select for redemption (by lot in such manner as the Trustee may determine) from all of the Series 2008A Bonds maturing on 1, 20 a principal amount of the Series 2008A Bonds equal to the aggregate principal amount of the Series 2008A Bonds redeemable with the required mandatory redemption payment, and shall call such Series 2008A Bonds for redemption on the next 1 and give notice of such call. (b) (i) Optional Redemption - Series 2008B Bonds. The Series 2008B Bonds maturing on or after 1, 20 are subject to redemption, at the option of the Corporation, in whole at any time, or in part on any Interest Payment Date, in any order of maturity and by lot within a maturity, on or after 1, 20 , or any Interest Payment Date thereafter at the redemption price of the principal amount to be redeemed, plus accrued interest to the date fixed for redemption, without premium. 17 (ii) Extraordinary Optional Redemption - Series 2008E Bonds. The Series 20088 Bonds are subject to redemption, at the option of the Corporation, in whole at any time, or in part on any Interest Payment Date, in any order of maturity and by lot within a maturity, on or after 1, 20 or any Interest Payment Date thereafter at the redemption price of the principal amount to be redeemed, plus accrued interest to the date fixed for redemption, without premium, but only from ARTICLE IV PROVISIONS AS TO FUNDS AND PAYMENTS SECTION 4.01. Expansion of Funds and Establishment of Costs of Issuance Fund, Series 2008 Accuisition and Construction Fund, and Series 2008 Insurer Reimbursement Fund. The several accounts established under Section 5.01 of the Indenture, that is, (i) the Revenue Fund, (ii) the Interest Fund, (iii) the Bond Retirement Fund and (iv) the Reserve Fund, shall remain in full force and effect and hereby are expanded to fully service the Series 2008 Bonds issued under this Supplemental Indenture from the installments of rental payments to be paid by the Town pursuant to the terms of the Series 2008 Town Lease. Additionally, there is hereby ordered created by the Corporation and maintained as separate deposit accounts (except when invested as hereinafter set forth) in the custody of the Trustee, the following trust funds: the Costs of Issuance Fund, the Series 2008 Acquisition and Construction Fund and the Series 2008 Insurer Reim- bursement Fund. SECTION 4.02. Application of Series 2008 Bond Proceeds. The Corporation shall deposit with the Trustee all of the proceeds of the Series 2008 Bonds and upon receipt of such proceeds the Trustee shall: (i) deposit to the credit of the Interest Fund, the accrued interest on the Series 2008A Bonds from their date to the date of their delivery to the Original Purchaser in the amount of $ ; (ii) deposit to the credit of the Costs of Issu- ance Fund, $ of the proceeds of the sale of the Series 2008A Bonds and $ of the proceeds of the sale of the Series 20088 Bonds; (iii) deposit with the Escrow Trustee $ of the proceeds of the sale of the Series 2008A Bonds for the credit of the "Trust Fund" established pursuant to the Escrow Trust Agreement; and 18 (iv) deposit to the credit of the Series 2008 Acquisition and Construction Fund, the balance of the proceeds of the sale of the Series 2008 Bonds. (The Series 2008 Surety Bond shall be deposited to the credit of the Reserve Fund.) SECTION 4.03. Disbursements From Costs of Issuance Fund and Series 2008 Acquisition and Construction Fund. (a) (i) The Trustee shall hold the amounts in the Costs of Issuance Fund for the benefit of the Corporation to be used to pay the Costs of Issuance, upon written order executed and deliv- ered to the Trustee directing such disbursements and shall disburse moneys in the Costs of Issuance Fund only upon a requisition signed by a Town Representative setting forth the amounts to be disbursed for payment or reimbursement of Costs of Issuance and the person or persons to whom said amounts are to be disbursed. (ii) The Trustee shall be responsible for the safekeeping of the amounts held in the Costs of Issuance Fund and the payment thereof in accordance with this Section. On 1, 2008, the Trustee shall transfer to the Bond Retirement Fund the balance of moneys remaining in the Costs of Issuance Fund. (b) (i) The Trustee shall hold the amounts in the Series 2008 Acquisition and Construction Fund for the benefit of the Corporation to be used to pay the Series 2008 Costs of Acquisition and Construction, upon written order executed and delivered to the Trustee directing such disbursements and shall disburse moneys in the Series 2008 Acquisition and Construction Fund only upon a requisition signed by a Town Representative for each requested disbursement stating that (1) not more than five percent (50) of the amount of the requested disbursement is or was used for any private business use within the meaning of section 141(b)(2) of the 1986 Code and (2) the amount to be disbursed are Series 2008 Costs of Acquisition and Construction prop- erly chargeable to the Series 2008 Acquisition and Construction Fund. (ii) The Trustee shall be responsible for the safekeeping of the amounts held in the Series 2008 Acquisition and Construction Fund and .the payment thereof in accordance with this Section. Upon the filing with the Trustee of a certificate of a Town Representative stating that all of the Series 2008 Costs of Acqui- sition and Construction have been paid, the Trustee shall transfer to the Bond Retirement Fund the balance of moneys remaining in the Series 2008 Acquisition and Construction Fund. SECTION 4.04. Receipt of Revenues. The rental payments to be paid by the Town pursuant to the terms of the Series 2008 Town Lease have been assigned by the Corporation to the Trustee so that such amounts shall be paid by the Town directly to the Trustee, and the Trustee shall credit such moneys to the Revenue Fund. If at any time the amount in the Revenue Fund exceeds, in the sole opinion of 19 the Trustee, the amount necessary for the current debt service on all Bonds then outstanding, including administration costs and expenses and the Town is not then in default under the Town Leases, such excess shall constitute a credit to the Town on the next succeeding install- ments of rent due or to become due under the Town Leases; provided, however, that the Town may exercise its rights under Article VII of the Town Leases, in which event such excess funds shall be transferred to and paid over into the Bond Retirement Fund. The aforesaid credit or transfer shall be made by the Trustee no less frequently than annually. SECTION 4.05. Flow of Funds. The Trustee shall transfer from the Revenue Fund the following amounts at the time and in the manner hereinafter provided for, applying amounts in the Revenue Fund, to the extent available, in the following order of priority, to-wit: (i) Interest Fund: On each Interest Payment Date, the Trustee shall deposit in the Interest Fund an amount equal to the amount of the interest becoming due and payable on the outstanding Bonds on the next Interest Payment Date, and each such deposit shall be made so that adequate moneys for the payment of interest will be available in such fund on each date that interest payments are to be made hereunder. Money in the Interest Fund shall be used and withdrawn by the Trustee solely for the purpose of paying the interest on the Bonds as it shall become due and payable. (ii) Bond Retirement Fund: On each Principal Payment Date, the Trustee shall deposit in the Bond Retirement Fund solely for the purpose of paying the principal of the Bonds as each amount shall become due and payable, on or before the following dates, the amounts specified opposite each such date: Maturity Principal Dates Amount January 1, 2008 $ ,000 July 1, 2008 ,000 January 1, 2009 ,000 July 1, 2009 ,000 January 1, 2010 ,000 July 1, 2010 ,000 January 1, 2011 ,000 July 1, 2011 ,000 January 1, 2012 ,000 July 1, 2012 ,000 January 1, 2013 ,000 July 1, 2013 ,000 January 1, 2014 ,000 July 1, 2014 ,000 January 1, 2015 ,000 July 1, 2015 ,000 January 1, 2016 ,000 July 1, 2016 ,000 20 Maturity natPs Principal Amnnnt January 1, 2017 ,000 July 1, 2017 ,000 January 1, 2018 ,000 July 1, 2018 ,000 January 1, 2019 ,000 July 1, 2019 ,000 January 1, 2020 ,000 July 1, 2020 ,000 January 1, 2021 ,000 July 1, 2021 ,000 January 1, 2022 ,000 July 1, 2022 ,000 January 1, 2023 ,000 July 1, 2023 ,000 January 1, 2024 ,000 July 1, 2024 ,000 January 1, 2025 ,000 July 1, 2025 ,000 (iii) Reserve Fund: (A) Monthly, commencing on the first (1st) day of the month following a payment made from the Reserve Fund with respect to the Series 2008 Bonds as hereinafter described, the Trustee shall, to the extent of legally available funds therefor, deposit into the Reserve Fund an amount equal to the amount required to restore the Reserve Fund to an amount equal to the Reserve Requirement for the Series 2008 Bonds. No deposit need be made into the Reserve Fund if the amount of money and the Series 1997 Surety Bond Limit of the Series 1997 Surety Bond, the Series 2000 Surety Bond Limit of the Series 2000 Surety Bond, the Series 2003 Surety Bond Limit of the Series 2003 Surety Bond, the Series 2004 Surety Bond Limit of the Series 2004 Surety Bond and the Series 2008 Surety Bond Limit of the Series 2008 Surety Bond contained therein is at least equal to an amount equal to the Reserve Requirement for the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds and the Series 2008 Bonds. If and to the extent that money has also been deposited in the Reserve Fund, all such money shall be used (or investments purchased with such money shall be liquidated and the proceeds applied as required) prior to any drawing under a Qualified Surety Bond. If and to the extent that more than one Qualified Surety Bond is credited to the Reserve Fund in lieu of money, drawings under such Qualified Surety Bonds (and repayments or reimbursement of amounts with respect to such Qualified Surety Bonds as hereinafter described) shall be made on a pro rata basis (calculated by reference to the policy 21 limits or maximum amounts available thereunder) after applying all available money in the Reserve Fund. (B) Except for the hereinafter described with- drawals, amounts in the Reserve Fund shall be used and withdrawn solely for the purpose of paying the principal of or interest on the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds and the Series 2008 Bonds in the event that no other money of the Corporation is available therefor, or, subject to the provisions of Section 7.07 hereof, for the retirement of all of the Bonds then outstanding. In the event and to the extent that moneys on deposit in the Interest Fund and the Bond Retirement Fund available for payment of principal of and interest on the Series 2008 Bonds, plus all amounts on deposit in and credited to the Reserve Fund in excess of the amount of the Series 2008 Surety Bond, are insufficient to pay the amount of principal and interest coming due on the Series 2008 Bonds, then upon the later of: (i) one (1) day after receipt by the General Counsel of the Series 2008 Insurer of a Series 2008 Demand for Payment, duly executed by the Trustee certifying that payment due under the Indenture has not been made to the Trustee; or (ii) the payment date of the Series 2008 Bonds as specified in the Series 2008 Demand for Payment presented by the Trustee to the General Counsel of the Series 2008 Insurer, the Series 2008 Insurer will make a deposit of funds in an account with the Trustee or its successor, in New York, New York, sufficient for the payment to the Trustee, of amounts which are then due to the Trustee under the Indenture (as specified in the Series 2008 Demand for Payment) up to but not in excess of the Series 2008 Surety Bond Coverage. The Trustee, or Paying Agent, if appropriate, shall, upon receipt of moneys received from the draw on the Series 2008 Surety Bond, as specified in the Series 2008 Demand for Payment, credit the Reserve Fund to the extent of moneys received pursuant to such Series 2008 Demand for Payment. (C) If on July 15 of any year the amount in the Reserve Fund exceeds an amount equal to the Reserve Requirement for the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds and the Series 2008 Bonds and if the Corporation is not then in default under the Indenture, the Trustee shall withdraw the amount of any such excess from such fund and shall apply such amount first, on a pro rata basis, to pay amounts due with respect to any Qualified Surety Bond, including by depositing the applicable pro rata amount in the MBIA Reimbursement Fund to reimburse the Series 1997 Insurer for any payments made by the Series 1997 Insurer under the Series 1997 Surety Bond until the Series 1997 Surety Bond Coverage equals the Series 1997 Surety Bond Limit, the applicable pro rata amount in the Series 2000 Insurer 22 Reimbursement Fund to reimburse the Series 2000 Insurer for any payments made by the Series 2000 Insurer under the Series 2000 Surety Bond until the Series 2000 Surety Bond Coverage equals the Series 2000 Surety Bond Limit, the applicable pro rata amount in the Series 2003 Insurer Reimbursement Fund to reimburse the Series 2003 Insurer for any payments made by the Series 2003 Insurer under the Series 2003 Surety Bond until the Series 2003 Surety Bond Coverage equals the Series 2003 Surety Bond Limit, the applicable pro rata amount in the Series 2004 Insurer Reimbursement Fund to reimburse the Series 2004 Insurer for any payments made by the Series 2004 Insurer under the Series 2004 Surety Bond until the Series 2004 Surety Bond Coverage equals the Series 2004 Surety Bond Limit and the applicable pro rata amount in the Series 2008 Insurer Reimbursement Fund to reimburse the Series 2008 Insurer for any payments made by the Series 2008 Insurer under the Series 2008 Surety Bond until the Series 2008 Surety Bond Coverage equals the Series 2008 Surety Bond Limit, and second, as a deposit to the Revenue Fund. (D) Monthly, commencing on the first (lst) day of the month following a payment made from the Series 2008 Surety Bond, the Trustee shall deposit in the Series 2008 Insurer Reimbursement Fund an amount of money equal to the amount paid for that purpose pursuant to the Series 2008 Town Lease to reimburse the Series 2008 Insurer for any interest owed by the Corporation to the Series 2008 Insurer for payments made by the Series 2008 Insurer pursuant to the Series 2008 Surety Bond or for any other moneys owed by the Corporation to the Series 2008 Insurer pursuant to the Series 2008 Guaranty Agreement. No deposit need be made into the Series 2008 Insurer Reimbursement Fund until such time as the Series 2008 Insurer has made a payment under the Series 2008 Surety Bond. All moneys in the Series 2008 Insurer Reimbursement Fund shall be used and withdrawn by the Trustee solely for the purpose of reimbursing the Series 2008 Insurer for any interest owed by the Corpora- tion to the Series 2008 Insurer for payments made by the Series 2008 Insurer pursuant to the Series 2008 Surety Bond or other moneys owed by the Corporation to the Series 2008 Insurer pursuant to the Series 2008 Guaranty Agreement. SECTION 4.06. Investment of Funds. Substantially all money in any of the funds to be established by the Trustee pursuant to Article V of the Indenture and this Article IV of this Supplemental Indenture shall, at the direction of the Town, so long as the Town is not in default under the Town Leases, be invested and reinvested by the Trustee in Eligible Investments, or if the Town fails to so direct or instruct the Trustee, the Trustee may invest and reinvest such moneys in Eligible Investments described in paragraph (B) in the definition of Eligible Investments. (Amounts deposited to the Inter- est Fund pursuant to Section 4.05(i) shall, however, only under any 23 circumstances be invested in direct obligations of the Department of the Treasury of the United States of America or cash insured at all times by the Federal Deposit Insurance Company or otherwise collater- alized with such obligations.) Such investments shall mature or be redeemable at the option of the Trustee at the times and in the amounts necessary to provide moneys to pay Bond Service Charges as they become due at stated maturity, by redemption or pursuant to any mandatory sinking fund requirements. The value of Eligible Invest- ments shall be determined at the end of each month. Except as other- wise provided in this Article IV, any interest, profit or loss on investments made pursuant to this Section 4.06 shall be credited or charged to the Fund to which such interest, profit or loss relates. It is understood, pursuant to Section 1.04(iv) of the Series 2008 Town Lease, that any losses on such investments are to be made up by the Town to the extent necessary to meet the Bond Service Charges, and to pay the Trustee's and the Registrar and Paying Agent's fees and. expenses under this Supplemental Indenture as well as payments to the Series 2008 Insurer pursuant to the Series 2008 Guaranty Agreement, and any money paid to the Trustee by the Town for such purpose shall be deposited in the Fund or Funds with respect to which, and to the extent that, such losses were incurred. At any time that the Town is in default under the Town Leases, substantially all money in any of the funds established by the Trustee pursuant to Article V of the Indenture or to be established by the Trustee pursuant to Article IV of this Supplemental Indenture shall be invested and reinvested by the Trustee at the direction of the Corporation in Eligible Investments. ARTICLE V ENFORCEMENT OF REVENUE PLEDGE; EXCLUSIVE PLEDGE; RECORD OF SURETY BOND PAYMENTS SECTION 5.01. Enforcement of Revenue Pled e. As pro- vided in the Series 2008 Town Lease, the Trustee shall have the right of specific performance of the covenants of the Town as to Revenues by appropriate court action in the name of the Trustee on behalf of the Owners of the Bonds and the provider of any Qualified Surety Bond, including, with respect to the Series 1997 Bonds, the Series 1997 Insurer, with respect to the Series 2000 Bonds, the Series 2000 Insur- er, with respect to the Series 2003 Bonds, the Series 2003 Insurer, with respect to the Series 2004 Bonds, the Series 2004 Insurer and, with respect to the Series 2008 Bonds, the Series 2008 Insurer, in the name of the Corporation or in the names of both. Nothing contained in this Section or in the Series 2008 Town Lease shall be deemed to create a lien of any kind upon the Leased Property or upon any other assets or facilities of the Town. SECTION 5.02. Exclusive Pledge. As further provided in Section 3.05 of the Town Lease, the pledge of Revenues referred to in this Article shall be for the benefit of the Owners of the Series 1997 Bonds, the Series 2000 Bonds, the Series 2003 Bonds, the Series 2004 Bonds, the Series 2008 Bonds and the Owners of any other Additional 24 Bonds issued by the Corporation as well as the provider of any Qualified Surety Bond, including, with respect to the Series 1997 Bonds, the Series 1997 Insurer, with respect to the Series 2000 Bonds, the Series 2000 Insurer, with respect to the Series 2003 Bonds, the Series 2003 Insurer and, with respect to the Series 2008 Bonds, the Series 2008 Insurer, and no other creditor of the Corporation shall have any claim thereto. ARTICLE VI PARITY OF PLEDGE OF REVENUES SECTION 6.01. Parity of Pledge of Revenues. To the extent that the installments of rental payments required to be paid by the Town to the Trustee (as assignee of the Corporation) pursuant to the Town Leases, are not paid, the pledge and lien pursuant to Article III of the Town Leases shall accrue equally and ratably by means of the Indenture to the Owners of the Bonds. Any default under this Supplemental Indenture shall constitute a default under the Indenture, and any default under the Town Lease shall constitute a default under the Town Leases. ARTICLE VII MISCELLANEOUS PROVISIONS SECTION 7.01. Cancellation. To the extent applicable by provision of law, the parties hereto acknowledge that this Supple- mental Indenture is subject to cancellation pursuant to Section 38-511, Arizona Revised Statutes, as amended, the provisions of which are incorporated herein. SECTION 7.02. Certain References. (a) References to "MBIA" and to "Financial Guaranty Agreement" in Sections 8.05 and 10.01 of the Indenture shall be deemed to also be to the Series 2008 Insurer and the Series 2008 Guaranty Agreement, respectively, with respect to the Series 2008 Bonds. (b) References to "MBIA," to "Financial Guaranty Agreement" and to "Municipal Bond Insurance Policy" in Sections 7.05(b), 7.09(b) and 11.08 (b) of the Indenture shall be deemed to also be to the Series 2008 Insurer, the Series 2008 Guaranty Agreement and the Series 2008 Municipal Bond Insurance Policy, respectively. (c) References to "Continuing Disclosure Undertaking" and "Financial Guaranty Agreement" in Section 8.01(a)(iv) of the Indenture shall be deemed to also be to the Series 2008 Continuing Disclosure Agreement, dated the date of delivery of the Series 2008 Bonds, by and between the Town and the Trustee, and the Series 2008 Guaranty Agreement, respectively. 25 ~~?~~ SECTION 7.03. Consent of Insurer. (a) Any provision of the Indenture expressly recog- nizing or granting rights in or to the Series 2008 Insurer may not be amended in any manner which affects the rights of the Series 2008 Insurer without the prior written consent of the Series 2008 Insurer. (b) The consent of the Series 2008 Insurer shall be required in addition to the consent of the Owners of the Series 2008 Bonds, when required, for the following purposes: (i) execution and delivery of any Supplemental Indenture or any amendment, supplement or change to or modification of the Town Leases; (ii) removal of the Trustee or Paying Agent or selection and appointment of any successor trustee or paying agent; and (iii) initiation or approval of any action not described in (i) or (ii) above which requires the consent of the Owners. (c) Any reorganization or liquidation plan with respect to the Corporation must be acceptable to the Series 2008 In- surer. In the event of any reorganization or liquidation, the Series 2008 Insurer shall have the right to vote on behalf of the Owners of the Series 2008 Bonds. (d) Anything in the Indenture to the contrary not- withstanding, upon the occurrence and continuance of an event of default as defined in the Indenture, the Series 2008 Insurer shall be entitled to control and direct the enforcement of all rights and remedies granted to the Owners of the Series 2008 Bonds or the Trustee for the benefit of the Owners of the Series 2008 Bonds under the Indenture. ~?~?~ SECTION 7.04. Notices and Other Information. (a) The Corporation shall furnish to the Series 2008 Insurer (to the attention of the Surveillance Department, unless otherwise indicated) as soon as practicable after the filing thereof, a copy of any financial statement of the Corporation and a copy of any audit and annual report of the Corporation, a copy of any notice to be given to the Owners of the Series 2008 Bonds, including, without limi- tation, notice of any redemption of or defeasance of the Series 2008 Bonds, any certificate rendered pursuant to the Indenture relating to the security for the Bonds and such additional information as the Series 2008 Insurer may reasonably request, including, after submis- sion to the Series 2008 Insurer of a Series 2008 Demand for Payment, all records relating to funds and accounts maintained under the Indenture. (b) The Corporation shall notify the Series 2008 Insurer (to the attention of the General Counsel Office) of any 26 failure of the Corporation to provide relevant notices, certificates, etc. Notwithstanding any other provision of the Indenture, the Corpo- ration shall immediately notify the Series 2008 Insurer (to the attention of the General Counsel Office) if at any time there are insufficient moneys to make any payments of principal and/or interest as required and immediately upon the occurrence of any event of default under the Indenture. (c) The Corporation shall permit the Series 2008 Insurer to discuss the affairs, finances and accounts of the Corpora- tion or any information the Series 2008 Insurer may reasonably request regarding the security for the Series 2008 Bonds with appropriate officers of the Corporation. The Corporation shall permit the Series 2008 Insurer to have access to and to make copies of all books and records relating to the Series 2008 Bonds at any reasonable time. (d) The Series 2008 Insurer shall have the right to direct an accounting at the expense of the Corporation, and the failure by the Corporation to comply with such direction within thirty (30) days after receipt of written notice of the direction from the Series 2008 Insurer shall be deemed a default hereunder; provided, however, that if compliance cannot occur within such period, then such period will be extended so long as compliance is begun within such period and diligently pursued, but only if such extension would not materially adversely affect the interests of any Owner of the Series 2008 Bonds. ~??~~ SECTION 7.05. Matters Relating to Defeasance. Notwith- standing anything herein to the contrary, in the event that the principal and/or interest due on the Series 2008 Bonds shall be paid by the Series 2008 Insurer pursuant to the Series 2008 Municipal Bond Insurance Policy, the Series 2008 Bonds shall remain Outstanding for all purposes, not be defeased or otherwise satisfied and not be considered paid by the Corporation, and the assignment and pledge of the trust estate of the Indenture and all covenants, agreements and other obligations of the Corporation to the Owners of the Series 2008 Bonds shall continue to exist and shall run to the benefit of the Series 2008 Insurer, and the Series 2008 Insurer shall be subrogated to the rights of such Owners. ~?~?~ SECTION 7.06. Certain Limitations on Refundin s and Pur- chases of Series 2008 Bonds and Distribution of Funds to Cor oration or Town. Notwithstanding anything to the contrary in the Indenture, there shall be no refunding of the Series 2008 Bonds, purchase of the Series 2008 Bonds or distribution of funds to the Corporation or the Town unless all amounts owed to the Series 2008 Insurer under the terms of the Series 2008 Guaranty Agreement, the Indenture and the Town Leases have been paid in full. 27 ~~?~~ SECTION 7.07. Payment Procedure Pursuant to Series 2008 Bond Insurance Policy. The Trustee and any Paying Agent shall comply with the following provisions: (a) On each of the Interest Payment Dates the Trustee or Paying Agent, if any, shall determine whether there will be sufficient funds in the funds and accounts under the Indenture to pay the principal of or interest on the Series 2008 Bonds on such Interest Payment Date. If the Trustee or Paying Agent, if any, determines that there will be insufficient funds in such funds or accounts, the Trustee or Paying Agent, if any, shall so notify the Series 2008 Insurer. Such notice shall specify the amount of the anticipated deficiency, the Series 2008 Bonds to which such deficiency is applicable and whether such Series 2008 Bonds will be deficient as to principal or interest, or both. The Series 2008 Insurer will make payments of principal or interest due on the Series 2008 Bonds on or before the first (lst) day next following the date on which the Series 2008 Insurer shall have received notice of nonpayment from the Trustee or Paying Agent, if any. (b) The Trustee or Paying Agent, if any, shall, after giving notice to the Series 2008 Insurer as provided in (a) above, make available to the Series 2008 Insurer and, at the direction of the Series 2008 Insurer, to the United States Trust Company of New York, as insurance trustee for the Series 2008 Insurer or any successor insurance trustee (the "Insurance Trustee"), the registration books of the Corporation maintained by the Trustee or Paying Agent, if any, and all records relating to such funds and accounts maintained under this Supplemental Indenture. (c) The Trustee or Paying Agent, if any, shall pro- vide the Series 2008 Insurer and the Insurance Trustee with a list of registered owners of Series 2008 Bonds entitled to receive principal or interest payments from the Series 2008 Insurer under the terms of the Series 2008 Municipal Bond Insurance Policy, and shall make arrangements with the Insurance Trustee (i) to mail checks or drafts to the Owners of the Series 2008 Bonds entitled to receive full or partial interest payments from the Series 2008 Insurer and (ii) to pay principal upon Series 2008 Bonds surrendered to the Insurance Trustee by the Owners of the Series 2008 Bonds entitled to receive full or partial principal payments from the Series 2008 Insurer. . (d) The Trustee or Paying Agent, if any, shall, at the time it provides notice to the Series 2008 Insurer pursuant to (a) above, notify Owners of Series 2008 Bonds entitled to receive the payment of principal or interest thereon from the Series 2008 Insurer (i) as to the fact of such entitlement, (ii) that the Series 2008 Insurer shall remit to them all or a part of the interest payments next coming due upon proof of Bondowner entitlement to interest pay- ments and delivery to the Insurance Trustee, in form satisfactory to the Insurance Trustee, of an appropriate assignment of the registered 28 owner's right to payment, (iii) that should they be entitled to receive full payment of principal from the Series 2008 Insurer, they must surrender their Series 2008 Bonds (along with an appropriate instrument of assignment in form satisfactory to the Insurance Trustee to permit ownership of such Series 2008 Bonds to be registered in the name of the Series 2008 Insurer) for payment to the Insurance Trustee, and not the Trustee or Paying Agent, if any, and (iv) that should they be entitled to receive partial payment of principal from the Series 2008 Insurer, they must surrender their Series 2008 Bonds for payment thereon first to the Trustee or Paying Agent, if any, who shall note on such Series 2008 Bonds the portion of the principal paid by the Trustee or Paying Agent, if any, and then, along with an appropriate instrument of assignment in form satisfactory to the Insurance Trus- tee, to the Insurance Trustee, which shall then pay the unpaid portion of principal. (e) In the event that the Trustee or Paying Agent, if any, has notice that any payment of principal of or interest on a Series 2008 Bond which has become "Due for Payment" (as such term is defined in the Series 2008 Municipal Bond Insurance Policy) and which is made to a Bondowner by or on behalf of the Corporation has been deemed a preferential transfer and theretofore recovered from its Owner pursuant to the United States Bankruptcy Code by a trustee in bankruptcy in accordance with the final, nonapplicable order of a court having competent jurisdiction, the Trustee or Paying Agent, if any, shall, at the time the Series 2008 Insurer is notified pursuant to (a) above, notify all Owners that in the event that any Owner's payment is so recovered, such registered owner will be entitled to payment from the Series 2008 Insurer to the extent of such recovery if sufficient funds are not otherwise available, and the Trustee or Paying Agent, if any, shall furnish to the Series 2008 Insurer its records evidencing the payments of principal of and interest on the Series 2008 Bonds which have been made by the Trustee or Paying Agent, if any, and subsequently recovered from registered owners and the dates on which such payments were made. (f) In addition to those rights granted the Series 2008 Insurer under this Supplemental Indenture, the Series 2008 Insurer shall, to the extent it makes payment of principal of or interest on the Series 2008 Bonds, become subrogated to the rights of the recipients of such payments in accordance with the terms of the Series 2008 Municipal Bond Insurance Policy, and to evidence such subrogation (i) in the case of subrogation as to claims for past due interest, the Trustee or Paying Agent, if any, shall note the rights of the Series 2008 Insurer as subrogee on the registration books of the Issuer maintained by the Trustee or Paying Agent, if any, upon receipt from the Series 2008 Insurer of proof of the payment of interest thereon to the registered owners of the Series 2008 Bonds, and (ii) in the case of subrogation as to claims for past due principal, the Trustee or Paying Agent, if any, shall note the rights of the Series 2008 Insurer as subrogee on the registration books of the Corporation maintained by the Trustee or Paying Agent, if any, 29 upon surrender of the Series 2008 Bonds by the Owners thereof together with proof of the payment of principal thereof. ~~??~ SECTION 7.08. Provisions Relating to Trustee. The fol- lowing shall be applicable and, to the extent that any such provision conflicts with any provision of the Indenture applicable to the Series 2008 Insurer, the following provisions shall supersede such other provisions herein: (a) The Trustee (or any Paying Agent) may be removed at any time, at the request of the Series 2008 Insurer, for any breach of the trust set forth herein. (b) The Series 2008 Insurer shall receive prior written notice of any Trustee (or any Paying Agent) resignation. (c) Every successor Trustee appointed pursuant to this Supplemental Indenture shall be a trust company or bank in good standing located in or incorporated under the laws of the State, duly authorized to exercise trust powers and subject to examination by federal or state authority, having a reported capital and surplus of not less than $75,000,000 and acceptable to the Series 2008 Insurer. Any successor Paying Agent, if applicable, shall not be appointed unless the Series 2008 Insurer approves such successor in writing. (d) In determining whether the rights of the Bondown- ers will be adversely affected by any action taken pursuant to the terms and provisions of this Supplemental Indenture, the Trustee (or any Paying Agent) shall consider the effect on the Owners of the Series 2008 Bonds as if there were no Series 2008 Municipal Bond Insurance Policy. (e) Notwithstanding any other provision of this Sup- plemental Indenture, no removal, resignation or termination of the Trustee (or any Paying Agent) shall take effect until a successor, acceptable to the Series 2008 Insurer, shall be appointed, unless such successor has been so appointed by a court of competent jurisdiction. ~???~ SECTION 7.09. Series 2008 Insurer as Third Party Bene- ficiary. To the extent that this Supplemental Indenture confers upon or gives or grants to the Series 2008 Insurer any right, remedy or claim under or by reason of this Supplemental Indenture, the Series 2008 Insurer is hereby explicitly recognized as being a third-party beneficiary hereunder and may enforce any such right, remedy or claim conferred, given or granted hereunder. Notwithstanding the foregoing or anything in the Indenture to the contrary, the rights and benefits of, and the duties and obligations owed by the Corporation to, the Series 2008 Insurer shall be effective only so long as the Series 2008 30 Municipal Bond Insurance Policy and the Series 2008 Surety Bond are in effect and the Series 2008 Insurer is not in default under either. ~???~ SECTION 7.10. Benefitted Parties. Nothing in this Sup- plemental Indenture expressed or implied is intended or shall be construed to confer upon, or to give or grant to, any person or entity, other than the Corporation, the Trustee, the Series 2008 Insurer, any Paying Agent and the Owners of the Series 2008 Bonds, any right, remedy or claim under or by reason of this Supplemental Indenture or any covenant, condition or stipulation hereof, and all covenants, stipulations, promises and agreements in this Supplemental Indenture contained by and on behalf of the Corporation shall be for the sole and exclusive benefit of the Issuer, the Trustee, the Series 2008 Insurer, any Paying Agent, and the Owners of the Series 2008 Bonds. ARTICLE VIII INTEGRATION OF DOCUMENTS SECTION 8.01. The Indenture and the Series 2008 Supple- mental Indenture. The Indenture and this Supplemental Indenture shall be deemed and considered as a single document, and the covenants, agreements, terms, conditions, rights, privileges, duties and liabil- ities contained in the Indenture and this Supplemental Indenture and arising thereunder and hereunder shall apply concurrently, except as specifically set forth herein, and except when the context or circum- stances otherwise require. SECTION 8.02. Indenture to Remain in Effect, Exce t as Modified. Except as otherwise modified, amended or supplemented by this Supplemental Indenture, the Indenture shall remain in full force and effect for and until the defeasance clause of the preamble of this Supplemental Indenture is satisfied. this Lease Town SECTION 8.03. Supplemental Indenture are to the Base Town Lease. References to Town Lease. For references in the Indenture Lease as supplemented by the purposes of to the Town Series 2008 31 IN WITNESS WHEREOF, the Corporation has caused this Supple- mental Indenture to be executed and delivered for it and in its name and on its behalf by its duly authorized officers; in token of its acceptance of the trusts created hereunder, the Trustee has caused this Supplemental Indenture to be executed and delivered for it and in its name and on its behalf by its duly authorized officer; and in token of its acceptance of the duties and obligations of the Registrar hereunder, the Registrar has caused this Supplemental Indenture to be executed and delivered for it and in its name and on its behalf by its duly authorized officer, all as of the day and year first above written. TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION By .................................... President ATTEST: ................................ Secretary WELLS FARGO BANK, NATIONAL ASSOCIATION (FORMERLY NORWEST BANK ARIZONA, N.A. AND WELLS FARGO BANK ARIZONA, N.A.), as Trustee By .................................... Authorized Officer 328191608v 1 4/23/2008 32 EXHIBIT A-1 [FORM OF SERIES 2008A BOND] REGISTERED NO. R-.......... REGISTERED UNLESS THIS BOND IS PRESENTED BY AN AUTHORIZED REPRESENTATIVE OF THE DEPOSITORY TRUST COMPANY ("DTC") TO THE CORPORATION OR ITS AGENT FOR REGISTRATION OF TRANSFER, EXCHANGE OR PAYMENT, AND ANY BOND ISSUED IS REGISTERED IN THE NAME OF CEDE & CO. OR IN SUCH OTHER NAME AS IS REQUESTED BY AN AUTHORIZED REPRESENTATIVE OF DTC (AND ANY PAYMENT IS MADE TO CEDE & CO. OR TO SUCH OTHER ENTITY AS IS REQUESTED BY AN AUTHORIZED REPRESENTATIVE OF DTC), ANY TRANSFER, PLEDGE OR OTHER USE HEREOF FOR VALUE OR OTHERWISE BY OR TO ANY PERSON IS WRONGFUL INASMUCH AS THE REGISTERED OWNER HEREOF, CEDE & CO., HAS AN INTEREST HEREIN.* UNITED STATES OF AMERICA STATE OF ARIZONA TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION MUNICIPAL FACILITIES REVENUE BOND, SERIES 2008A Interest Rate: ..% per annum Maturity Date: ........ 1, 20.. REGISTERED OWNER: CEDE & CO.* Original Issue Date: CUSIP: 1, 2008 ........... PRINCIPAL AMOUNT: ........................................... DOLLARS Town of Marana Municipal Property Corporation, a nonprofit corporation incorporated and existing under and by virtue of the laws of the State of Arizona (hereinafter referred to as the "Corpora- tion"), for value received, hereby promises to pay to the Registered Owner (named above), or registered assigns, the Principal Amount (stated above) on the Maturity Date (stated above), unless this Bond is called for redemption prior to the Maturity Date and payment provided therefor, and to pay interest on the Principal Amount at the Interest Rate (stated above) on January 1 and July 1 of each year, commencing 1, 200_ (hereinafter referred to as the "inter- est payment dates"), from the Original Issue Date (stated above) to the maturity of the Bond, or until redeemed if redeemed prior to maturity. The principal of and premium, if any, on this Bond (and any interest due as of the principal maturity or redemption date) are payable upon presentation and surrender hereof at the designated principal corporate trust office of .................................. Phoenix, Arizona, as trustee (hereinafter referred to as the "Trus- *Insert so long as DTC is the Securities Depository. A-1-1 tee"). Interest on this Bond (other than that due on a principal maturity or redemption date) is payable by check or draft mailed by the Trustee to the registered owner hereof, as shown on the registra- tion books for the series of the bonds of which this Bond is one maintained by the Trustee, at the address appearing therein at the close of business on the 15th day of the calendar month next preceding that interest payment date (hereinafter referred to as the "regular record date"). Any interest which is not timely paid or duly provided for shall cease to be payable to the registered owner hereof (or of one or more predecessor Bonds) as of the regular record date, but shall be payable to the registered owner hereof (or of one or more predecessor Bonds) at the close of business on a special record date to be fixed by the Trustee for the payment of that overdue interest. The special record date shall be fixed by the Trustee whenever moneys become available for payment of the overdue interest, and notice of the special record date shall be given to registered owners of the Bonds not less than 10 days prior thereto. The principal of and premium, if any, and interest on this Bond are payable in lawful money of the United States of America, without deduction for the services of the Trustee. This Bond is one of a duly authorized issue of bonds of the Corporation known as its Municipal Facilities Revenue Bonds, Series 2008, consisting of its $ ,000 principal amount of Municipal Facilities Revenue Bonds, Series 2008A (the "Series 2008A Bonds") and $ ,000 principal amount of Municipal Facilities Revenue Bonds, Series 2008B (together with the Series 2008A Bonds, the "Series 2008 Bonds"), issued in an aggregate principal amount of $ ,000 for the purpose of providing funds for the Town of Marana, Arizona (hereinafter referred to as the "Town"), to construct, design, acquire and equip, as the case may be and among others, extensions and additions to the sewer lines and interceptors in Silverbell Road and to the Town's Airport, extensions and improvements to Camino de Marana and Dove Mountain Roads and improvements to Cortaro Silverbell District Park and to refinance certain bonds heretofore issued by the Corporation for the benefit of the Town. (This Bond is one of the Series 2008A Bonds.) The Series 2008 Bonds are special obligations of the Corporation issued under and equally and ratably secured, both as to principal and interest, by a Trust Indenture, dated as of October 1, 1997 (hereinafter referred to as the "Original Indenture"), as supplemented by a Series 2008 Supplemental Trust Indenture, dated as of 1, 2008 (hereinafter referred to as the "Series 2008 Supplemental Indenture"), from the Corporation to the Trustee. The Original Indenture and the Series 2008 Supplemental Indenture are hereinafter collectively referred to as the "Indenture." Reference is hereby made to the Indenture for the nature and extent of the security, a statement of the terms and conditions upon which the Series 2008 Bonds are issued and secured, the rights of the registered owner hereof and the terms under which bonds on a parity with the Series 2008 Bonds have been and may be issued. Pursuant to a Combined Cortaro Silverbell District Park Ground Lease and Fourth Supplement to Amended and Restated Town Lease A-1-2 and Series 1992 Town Lease, dated as of 1, 2008 (hereinafter referred to as the "Town Lease"), by and between the Corporation and the Town, the Corporation has extended the lease of certain real property and leased certain improvements to the Town. The rental payments to be paid by the Town to the Corporation pursuant to the Town Lease have been assigned to the Trustee as security for the payment of the Series 2008 Bonds. Under the terms of the Town Lease, the Town has agreed to pay as rental payments sums sufficient to pay, among other things, the principal of and interest on the Series 2008 Bonds as the same come due and all charges and expenses of the Trustee. In order to secure the payment of the rental payments, the Town has pledged Town sales tax, state-shared revenues, license and permit fees and fines and forfeitures collected by or on behalf of the Town (except those taxes required by State law to be expended for specific purposes, such as the motor vehicle fuel tax) and other amounts provided for in the Town Lease. The Town Lease does not constitute a general obligation of the Town nor any indebtedness of the Town within the meaning of the Constitution or laws of the State of Arizona. This Bond and all the Series 2008 Bonds are payable solely from amounts received by the Corporation under the Town Lease and all supplements thereto. This Bond is not a general obligation of the Corporation and no incorporator, member, director, officer or agent, as such, past, present or future, of the Corporation shall be personally liable for the payment hereof. As provided in, and to the extent permitted by the Inden- ture, or any indenture supplemental thereto, the rights and obliga- tions of the Corporation and the registered owners of the Series 2008 Bonds may be modified by the Corporation with the written consent of the registered owners of a majority of the principal amount of the Series 2008 Bonds outstanding and/or under certain circumstances the insurer of the Series 2008 Bonds as hereinafter identified, provided, however, that no such modification shall effect the reduction of, or the extension of the stated time of payment of the principal hereof, or of the interest hereon, or permit the creation of any lien on the trust estate prior to or on a parity with the lien of the Indenture (except parity bonds or other obligations issued under the conditions set forth in the Indenture) or deprive the registered owner hereof of the lien created by the Indenture. The Town has covenanted and agreed with the registered owners of the Series 2008 Bonds that, so long as any of the Bonds remain outstanding and any of the principal and interest thereon shall be unpaid or unprovided for, the Town will not further encumber the amounts pledged under the Town Lease on a basis equal to its first lien pledge thereof unless the amounts collected in the next preceding fiscal year shall have amounted to at least three (3) times the high- est combined interest and principal requirements for any succeeding 12 months' period for all Series 2008 Bonds then outstanding and all other outstanding parity obligations so proposed to be secured by a pledge of those amounts. A-1-3 The Series 2008A Bonds maturing on or after 1, 20 are subject to redemption prior to maturity in whole at any time, or in part on any interest payment date, in any order of maturity and by lot within a maturity, on or after 1, 20 or any interest payment date thereafter, at the redemption price of the principal amount to be redeemed, plus accrued interest to the date fixed for redemption, without premium. The Series 2008A Bonds maturing on 1, 20 are subject to mandatory redemption on the dates and in the amounts set forth below, at a redemption price equal to the principal amount thereof plus interest accrued to the date of redemption: Date 1, 20 A remaining principal amount of $ mature on 1, 20 Principal Amount S ,000 ,000 of Series 2008A Bonds will The Series 2008A Bonds maturing on 1, 20 are subject to mandatory redemption on the dates and in the amounts set forth below, at a redemption price equal to the principal amount thereof plus interest accrued to the date of redemption: Date January 1, 20 July 1, 20 January 1, 20 July 1, 20 January 1, 20 July 1, 20 January 1, 20 July 1, 20 January 1, 20 Principal Amount $ ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 ,000 A remaining principal amount of $ mature on 1, 20 ,000 of Series 2008A Bonds will Notice of redemption of the Series 2008 Bonds shall be mailed by first class mail, postage prepaid, not more than 45 nor less than 30 days prior to the date fixed for redemption, to the registered owner of each Bond to be redeemed in whole or in part at the regis- tered owner's address shown on the registration books for the Series 2008 Bonds on the 15th day preceding that mailing. Failure to mail notice to any registered owner of Series 2008 Bonds shall not affect the validity of the proceeding for the redemption of Bonds with respect to registered owners of other Series 2008 Bonds. The Registrar, initially the Trustee, will maintain the books of the Corporation for the registration of ownership of each Series 2008 Bond as provided in the Indenture. A-1-4 This Bond may be transferred on the registration books upon delivery hereof to the Registrar at its designated corporate trust office, accompanied by a written instrument of transfer in form and with guaranty of signature satisfactory to the Registrar, duly exe- cuted by the registered owner of this Bond, or his or her attorney-in- fact or legal representative, containing written instructions as to the details of the transfer. No transfer of this Bond shall be effective until entered on the registration books. In all cases upon the transfer of a Series 2008 Bond, the Registrar will enter the transfer of ownership in the registration books and will authenticate and deliver, in the name of the transferee or transferees, a new fully registered Series 2008 Bond or Series 2008 Bonds of the denominations of $5,000 of principal amount or any whole multiple thereof (except that no Series 2008 Bond shall be issued which relates to more than a single principal maturity) for the aggregate principal amount which the registered owner is entitled to receive at the earliest practicable time in accordance with the provisions of the Indenture. The registered owner upon request, and upon the sup exchange such Series 2008 Bonds ized denomination of the same together aggregating the same Bonds so surrendered. of one or more Series 2008 Bonds may, -render to the Trustee of such Bonds, for Series 2008 Bonds of other author- maturity, series, and interest rate principal amount as the Series 2008 The Corporation or the Registrar will charge the registered owner of such Series 2008 Bond, for every such transfer or exchange of a Series 2008 Bond, an amount sufficient to reimburse them for their expenses and any transfer fee, tax or other charge required to be paid with respect to such transfer and may require that such charge be paid before any such new Series 2008 Bond shall be delivered. The regis- tered owner of any Series 2008 Bond will be required to pay any expenses incurred in connection with the replacement of a mutilated, lost, stolen or destroyed Series 2008 Bond. The Corporation and the Registrar will not be required (a) to issue or transfer any Series 2008 Bonds during a period begin- ning with the opening of business on the 15th business day next pre- ceding the date of mailing of notice of Series 2008 Bonds to be redeemed and ending with the close of business on the day on which the applicable notice of redemption is mailed or (b) to transfer any Series 2008 Bonds which have been selected or called for redemption in whole or in part. This 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 signed by the Registrar. It is hereby certified and recited that all conditions, acts and things required by the Constitution and laws of the State of A-1-5 Arizona to exist, to occur and to be performed precedent to and in the issuance of this Bond do exist, have occurred and have been performed. Neither this Bond nor the series of Bonds of which this is one is a general obligation of the Corporation or the Town, but is payable solely from the sources and in the manner set forth herein. IN WITNESS WHEREOF, the President and the Secretary of the Corporation have caused this Bond to be executed in the name of the Corporation by the facsimile signature of said President and by the facsimile signature of said Secretary, all as of the date written above. TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION (Facsimile) ...................................... President ATTEST: (Facsimile) ................................. Secretary CERTIFICATE OF AUTHENTICATION This Bond is one of the Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2008A, issued pursuant to the within-mentioned Indenture. Date of Authentication: ....................... as Registrar By .................................... Authorized Signatory A-1-6 ~~~~~ STATEMENT OF INSURANCE Financial Guaranty Insurance Policy No. .......... (the "Policy") with respect to payments due for principal of and interest on this Bond has been issued by Ambac Assurance Corporation ("Ambac Assurance"). The Policy has been delivered to The Bank of New York, New York, New York, as the Insurance Trustee under said Policy and will be held by such Insurance Trustee or any successor insurance trustee. The Policy is on file and available for inspection at the principal office of the Insurance Trustee and a copy thereof may be secured from Ambac Assur- ance or the Insurance Trustee. All payments required to be made under the Policy shall be made in accordance with the provisions thereof. The owner of this Bond acknowledges and consents to the subrogation rights of Ambac Assurance as more fully set forth in the Policy. A-1-7 ASSIGNMENT For value received, the undersigned hereby sells, assigns and transfers unto ..................................... the within bond and irrevocably constitutes and appoints ..................... ................. attorney to transfer that bond on the books kept for registration thereof, with full power of substitution in the premises. Dated :....................... Signature Guaranteed: ............................. (Insert Proper Legend] ................................... Notice: The assignor's 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 whatsoever. TRANSFEROR SHALL PAY ALL TRANSFER OR GOVERNMENTAL FEES, TAXES OR CHARGES. (Insert Appropriate Legend Re: Abbreviations] A-1-8 EXHIBIT A-2 [FORM OF SERIES 2008B BOND] REGISTERED NO. R-.......... REGISTERED UNLESS THIS BOND"IS PRESENTED BY AN AUTHORIZED REPRESENTATIVE OF THE DEPOSITORY TRUST COMPANY ("DTC") TO THE CORPORATION OR ITS AGENT FOR REGISTRATION OF TRANSFER, EXCHANGE OR PAYMENT, AND ANY BOND ISSUED IS REGISTERED IN THE NAME OF CEDE & CO. OR IN SUCH OTHER NAME AS IS REQUESTED BY AN AUTHORIZED REPRESENTATIVE OF DTC (AND ANY PAYMENT IS MADE TO CEDE & CO. OR TO SUCH OTHER ENTITY AS IS REQUESTED BY AN AUTHORIZED REPRESENTATIVE OF DTC), ANY TRANSFER, PLEDGE OR OTHER USE HEREOF FOR VALUE OR OTHERWISE BY OR TO ANY PERSON IS WRONGFUL INASMUCH AS THE REGISTERED OWNER HEREOF, CEDE & CO., HAS AN INTEREST HEREIN.* UNITED STATES OF AMERICA STATE OF ARIZONA TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION MUNICIPAL FACILITIES REVENUE BOND, SERIES 2008B Interest Rate: ...o per annum Maturity Date: ........ 1, 20.. REGISTERED OWNER: CEDE & CO.* Original Issue Date: CUSIP: 1, 2008 ........... PRINCIPAL AMOUNT: ........................................... DOLLARS Town of Marana Municipal Property Corporation, a nonprofit corporation incorporated and existing under and by virtue of the laws of the State of Arizona (hereinafter referred to as the "Corpora- tion"), for value received, hereby promises to pay to the Registered Owner (named above), or registered assigns, the Principal Amount (stated above) on the Maturity Date (stated above), unless this Bond is called for redemption prior to the Maturity Date, and payment provided therefor, and to pay interest on the Principal Amount at the Interest Rate (stated above) on January 1 and July 1 of each year, commencing 1, 200_ (hereinafter referred to as the "inter- est payment dates"), from the Original Issue Date (stated above) to the maturity of the Bond, or until redeemed if redeemed prior to maturity. The principal of and premium, if any, on this Bond (and any interest due as of the principal maturity or redemption date) are payable upon presentation and surrender hereof at the designated principal corporate trust office of .................................. Phoenix, Arizona, as trustee (hereinafter referred to as the "Trus- *Insert so long as DTC is the Securities Depository. A-2-1 tee"). Interest on this Bond (other than that due on a principal maturity or redemption date) is payable by check or draft mailed by the Trustee to the registered owner hereof, as shown on the registra- tion books for the series of the bonds of which this Bond is one maintained by the Trustee, at the address appearing therein at the close of business on the 15th day of the calendar month next preceding that interest payment date (hereinafter referred to as the "regular record date"). Any interest which is not timely paid or duly provided for shall cease to be payable to the registered owner hereof (or of one or more predecessor Bonds) as of the regular record date, but shall be payable to the registered owner hereof (or of one or more predecessor Bonds) at the close of business on a special record date to be fixed by the Trustee for the payment of that overdue interest. The special record date shall be fixed by the Trustee whenever moneys become available for payment of the overdue interest, and notice of the special record date shall be given to registered owners of the Bonds not less than 10 days prior thereto. The principal of and premium, if any, and interest on this Bond are payable in lawful money of the United States of America, without deduction for the services of the Trustee. This Bond is one of a duly authorized issue of bonds of the Corporation known as its Municipal Facilities Revenue Bonds, Series 2008, consisting of its $ ,000 principal amount of Municipal Facilities Revenue Bonds, Series 2008A (the "Series 2008A Bonds") and $ ,000 principal amount of Municipal Facilities Revenue Bonds, Series 2008B (the "Series 2008B Bonds" and, together with the Series 2008A Bonds, the "Series 2008 Bonds"), issued in an aggregate principal amount of $ ,000 for the purpose of providing funds for the Town of Marana, Arizona (hereinafter referred to as the "Town"), to construct, design, acquire and equip, as the case may be and among others, extensions and additions to the sewer lines and interceptors in Silverbell Road and to the Town's Airport, extensions and improvements to Camino de Marana and Dove Mountain Roads and improvements to Cortaro Silverbell District Park and to refinance certain bonds heretofore issued by the Corporation for the Town. (This Bond is one of the Series 2008B Bonds.) The Series 2008 Bonds are special obligations of the Corporation issued under and equally and ratably secured, both as to principal and interest, by a Trust Indenture, dated as of October 1, 1997 (hereinafter referred to as the "Original Indenture"), as supplemented by a Series 2008 Supplemental Trust Indenture, dated as of 1, 2008 (hereinafter referred to as the "Series 2008 Supplemental Indenture"), from the Corporation to the Trustee. The Original Indenture and the Series 2008 Supplemental Indenture are hereinafter collectively referred to as the "Indenture." Reference is hereby made to the Indenture for the nature and extent of the security, a statement of the terms and conditions upon which the Series 2008 Bonds are issued and secured, the rights of the registered owner hereof and the terms under which bonds on a parity with the Series 2008 Bonds have been and may be issued. Pursuant to a Combined Cortaro Silverbell District Park Ground Lease and Fourth Supplement to Amended and Restated Town Lease A-2-2 and Series 1992 Town Lease, dated as of 1, 2008 (hereinafter referred to as the "Town Lease"), by and between the Corporation and the Town, the Corporation has extended the lease of certain real property and leased certain improvements to the Town. The rental payments to be paid by the Town to the Corporation pursuant to the Town Lease have been assigned to the Trustee as security for the payment of the Series 2008 Bonds. Under the terms of the Town Lease, the Town has agreed to pay as rental payments sums sufficient to pay, among other things, the principal of and interest on the Series 2008 Bonds as the same come due and all charges and expenses of the Trustee. In order to secure the payment of the rental payments, the Town has pledged Town sales tax, state-shared revenues, license and permit fees and fines and forfeitures collected by or on behalf of the Town (except those taxes required by State law to be expended for specific purposes, such as the motor vehicle fuel tax) and other amounts provided for in the Town Lease. The Town Lease does not constitute a general obligation of the Town nor any indebtedness of the Town within the meaning of the Constitution or laws of the State of Arizona. This Bond and all the Series 2008 Bonds are payable solely from amounts received by the Corporation under the Town Lease and all supplements thereto. This Bond is not a general obligation of the Corporation and no incorporator, member, director, officer or agent, as such, past, present or future, of the Corporation shall be personally liable for the payment hereof. As provided in, and to the extent permitted by the Inden- ture, or any indenture supplemental thereto, the rights and obliga- tions of the Corporation and the registered owners of the Series 2008 Bonds may be modified by the Corporation with the written consent of the registered owners of a majority of the principal amount of the Series 2008 Bonds outstanding and/or under certain circumstances the insurer of the Series 2008 Bonds as hereinafter identified, provided, however, that no such modification shall effect the reduction of, or the extension of the stated time of payment of the principal hereof, or of the interest hereon, or permit the creation of any lien on the trust estate prior to or on a parity with the lien of the Indenture (except parity bonds or other obligations issued under the conditions set forth in the Indenture) or deprive the registered owner hereof of the lien created by the Indenture. The Town has covenanted and agreed with the registered owners of the Series 2008 Bonds that, so long as any of the Bonds remain outstanding and any of the principal and interest thereon shall be unpaid or unprovided for, the Town will not further encumber the amounts pledged under the Town Lease on a basis equal to its first lien pledge thereof unless the amounts collected in the next preceding fiscal year shall have amounted to at least three (3) times the high- est combined interest and principal requirements for any succeeding 12 months' period for all Series 2008 Bonds then outstanding and all other outstanding parity obligations so proposed to be secured by a pledge of those amounts. A-2-3 The Series 2008B Bonds maturing on or after 1, 20 are subject to redemption prior to maturity in whole at any time, or in part on any interest payment date, in any order of maturity and by lot within a maturity, on or after 1, 20 or any interest payment date thereafter, at the redemption price of the principal amount to be redeemed, plus accrued interest to the date fixed for redemption, without premium. The Series 2008B Bonds are also subject to redemption prior to maturity in whole at any time, or in part on any interest payment date, in any order of maturity and by lot within a maturity, on or after 1, 20 or any interest payment date thereafter, at the redemption price of the principal amount to be redeemed, plus accrued interest to the date fixed for redemption, without premium, but only from Notice of redemption of the Series 2008 Bonds shall be mailed by first class mail, postage prepaid, not more than 45 nor less than 30 days prior to the date fixed for redemption, to the registered owner of each Bond to be redeemed in whole or in part at the regis- tered owner's address shown on the registration books for the Series 2008 Bonds on the 15th day preceding that mailing. Failure to mail notice to any registered owner of Series 2008 Bonds shall not affect the validity of the proceeding for the redemption of Bonds with respect to registered owners of other Series 2008 Bonds. The Registrar, initially the Trustee, will maintain the books of the Corporation for the registration of ownership of each Series 2008 Bond as provided in the Indenture. This Bond may be transferred on the registration books upon delivery hereof to the Registrar at its designated corporate trust office, accompanied by a written instrument of transfer in form and with guaranty of signature satisfactory to the Registrar, duly exe- cuted by the registered owner of this Bond, or his or her attorney-in- fact or legal representative, containing written instructions as to the details of the transfer. No transfer of this Bond shall be effective until entered on the registration books. In all cases upon the transfer of a Series 2008 Bond, the Registrar will enter the transfer of ownership in the registration books and will authenticate and deliver, in the name of the transferee or transferees, a new fully registered Series 2008 Bond or Series 2008 Bonds of the denominations of $5,000 of principal amount or any whole multiple thereof (except that no Series 2008 Bond shall be issued which relates to more than a single principal maturity) for the aggregate principal amount which the registered owner is entitled to receive at the earliest practicable time in accordance with the provisions of the Indenture. The registered owner of one or more Series 2008 Bonds may, upon request, and upon the surrender to the Trustee of such Bonds, A-2-4 exchange such Series 2008 Bonds for Series 2008 Bonds of other author- ized denomination of the same maturity, series, and interest rate together aggregating the same principal amount as the Series 2008 Bonds so surrendered. The Corporation or the Registrar will charge the registered owner of such Series 2008 Bond, for every such transfer or exchange of a Series 2008 Bond, an amount sufficient to reimburse them for their expenses and any transfer fee, tax or other charge required to be paid with respect to such transfer and may require that such charge be paid before any such new Series 2008 Bond shall be delivered. The regis- tered owner of any Series 2008 Bond will be required to pay any expenses incurred in connection with the replacement of a mutilated, lost, stolen or destroyed Series 2008 Bond. The Corporation and the Registrar will not be required (a) to issue or transfer any Series 2008 Bonds during a period begin- ning with the opening of business on the 15th business day next pre- ceding the date of mailing of notice of Series 2008 Bonds to be redeemed and ending with the close of business on the day on which the applicable notice of redemption is mailed or (b) to transfer any Series 2008 Bonds which have been selected or called for redemption in whole or in part. This 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 signed by the Registrar. It is hereby certified and recited that all conditions, acts and things required by the Constitution and laws of the State of Arizona to exist, to occur and to be performed precedent to and in the issuance of this Bond do exist, have occurred and have been performed. Neither this Bond nor the series of Bonds of which this is one is a general obligation of the Corporation or the Town, but is payable solely from the sources and in the manner set forth herein. IN WITNESS WHEREOF, the President and the Secretary of the Corporation have caused this Bond to be executed in the name of the Corporation by the facsimile signature of said President and by the facsimile signature of said Secretary, all as of the date written above. TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION (Facsimile) ...................................... President A-2-5 ATTEST: (Facsimile) ................................. Secretary CERTIFICATE OF AUTHENTICATION This Bond is one of the Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2008B, issued pursuant to the within-mentioned Indenture. Date of Authentication: ....................... as Registrar By .................................... Authorized Signatory A-2-6 ~???~ STATEMENT OF INSURANCE Financial Guaranty Insurance Policy No. .......... (the "Policy") with respect to payments due for principal of and interest on this Bond has been issued by Ambac Assurance Corporation ("Ambac Assurance"). The Policy has been delivered to The Bank of New York, New York, New York, as the Insurance Trustee under said Policy and will be held by such Insurance Trustee or any successor insurance trustee. The Policy is on file and available for inspection at the principal office of the Insurance Trustee and a copy thereof may be secured from Ambac Assur- ance or the Insurance Trustee. All payments required to be made under the Policy shall be made in accordance with the provisions thereof. The owner of this Bond acknowledges and consents to the subrogation rights of Ambac Assurance as more fully set forth in the Policy. A-2-7 ASSIGNMENT For value received, the undersigned hereby sells, assigns and transfers unto ..................................... the within bond and irrevocably constitutes and appoints ..................... ................. attorney to transfer that bond on the books kept for registration thereof, with full power of substitution in the premises. Dated :....................... Signature Guaranteed: ............................ (Insert Proper Legend] ................................... Notice: The assignor's 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 whatsoever. TRANSFEROR SHALL PAY ALL TRANSFER OR GOVERNMENTAL FEES, TAXES OR CHARGES. (Insert Appropriate Legend Re: Abbreviations] A-2-8 DRAFT 04/24/08 05/13/08 ESCROW TRUST AGREEMENT by and between TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION and WELLS FARGO BANK, NATIONAL ASSOCIATION, as Escrow Trustee DATED AS OF 1, 2008 ESCROW TRUST AGREEMENT This ESCROW TRUST AGREEMENT, dated as of 1, 2008, by and between TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION, a nonprofit corporation incorporated and existing pursuant to the laws of the State of Arizona (the "Corporation"), and WELLS FARGO BANK, NATIONAL ASSOCIATION, a banking entity organized and existing under the laws of the United States of America and authorized to exercise trust powers under the laws of the State of Arizona, as escrow trustee (the "Trustee"), W I T N E S S E T H: WHEREAS, all but $220,000 of the remaining, outstanding Municipal Facilities Revenue Bonds, Series 1997 of the Corporation maturing on July 1, 2008, and January 1, 2009 (the "Bonds Being Refunded" or the "Refunded Bonds"), are being refunded and redeemed pursuant to the terms of this Escrow Trust Agreement; and WHEREAS, the Board of Directors of the Corporation, by resolution adopted on May 20, 2008 (the "Bond Resolution"), and a Trust Indenture, dated as of October 1, 1997 (the "Original Inden- ture"), as supplemented by a Series 2008 Supplemental Trust Indenture, dated as of 1, 2008 (the "Supplemental Indenture"), from the Corporation to Wells Fargo Bank, National Association, as trustee (the "Indenture Trustee"), authorized the issuance of $ ,000 aggregate principal amount of Municipal Facilities Revenue Bonds, Series 2008A (the "Refunding Bonds"), of the Corporation, a portion of the proceeds of which were used to refund the Bonds Being Refunded; and WHEREAS, the Bond Resolution authorized and directed the Corporation to enter into this Escrow Trust Agreement with the Trustee with respect to the safekeeping and handling of the moneys and securi- ties to be held in trust for the payment of the Bonds Being Refunded; and WHEREAS, the Trustee agreed to accept and administer the trust created hereby; NOW, THEREFORE, PURSUANT TO LAW AND FOR AND IN CONSIDERA- TION OF THE MUTUAL COVENANTS HEREINAFTER CONTAINED, IT IS HEREBY AGREED AS FOLLOWS: Section 1. On 2008 (the "Delivery Date"), the Corporation deposited, or caused to be deposited, cash in the amount of $ (the "Initial Cash Deposit") and the securities described in Exhibit "B" attached hereto (or additional funds sufficient to permit the Trustee to purchase such securities on the Delivery Date), all of which are direct obligations of the United States (the "Securities"), to be held by the Trustee in a special and separate trust fund, desig- nated as the "Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds (2008) Trust Fund" (the "Trust Fund"). As determined in the Verification Report of Grant Thornton LLP regarding the Refunding Bonds (the "Report"), the principal amount of the Secu- rities, together with the scheduled interest thereon and the Initial Cash Deposit, are sufficient to assure that the funds available in the Trust Fund shall be sufficient to pay promptly the principal of and redemption premiums, if any, and interest on the Bonds Being Refunded as the same are redeemed. Section 2. (A) The Trustee shall, at all times, hold the Securities and the Initial Cash Deposit in the Trust Fund for the account of the Corporation and for the- benefit of the registered own- ers of the Bonds Being Refunded and shall maintain the Trust Fund wholly segregated from other funds and securities on deposit with the Trustee, shall never commingle the Securities and other moneys with other funds or securities of the Trust Fund and shall never at any time use, loan or borrow the same in any way, so that sufficient funds always shall be available to pay the interest and principal requirements of the Refunded Bonds as the same accrue and become due and payable from time to time as set forth in Exhibits "A" and "C" hereto (collectively, the "Payment Schedules") which conform with similar schedules included in the Report. (B) The Trustee shall reinvest cash balances held in the Trust Fund on each January 1 and July 1, to the extent not required for the payment of the principal of and redemption premium and interest on the Refunded Bonds on such date, in United States Treasury Certificates of Indebtedness, State and Local Government Series ("SLGs"), at a zero percent (0.0%) interest rate, maturing on the semiannual debt service payment date for the Refunded Bonds (the "Restricted Reinvestment Obligations"), provided that amounts which may not be so invested shall be held in cash and shall not be invested. (The Initial Cash Deposit shall be held in the Trust Fund in cash and shall not be invested.) Such investments shall be made only to the extent permitted by, and shall be made in accordance with, the applicable statutes, rules and regulations governing such invest- ments issued by the Bureau of Public Debt. Such rules and regulations currently require that a subscription for purchase of the investment be submitted at least fifteen (15) (or, for subscriptions of less than $10,000,000 five (5)) but no more than sixty (60) days prior to the date of investment. If the Department of the Treasury (or the Bureau of Public Debt) of the United States suspends the sale of SLGs causing the Trustee to be unable to purchase SLGs, then the Trustee will take the following actions: On the date the Trustee would have purchased SLGs had the Trustee been able to do so, the Trustee shall purchase non-callable and non-prepayable obligations issued or guaranteed as to full and timely payment by the United States of America ("Government Obligations") maturing no more than ninety (90) days after the date of purchase ("Alternate Investments"). The purchase price of the Alter- nate Investment shall be as close as possible to the principal amount of the SLGs that would have been purchased on such date if they had been available for purchase and shall in no event be more than the amount payable at such maturity on such investment. The Trustee shall 2 purchase each Alternate Investment at a price no higher than the fair market value of the Alternate Investment and shall maintain records demonstrating compliance with this requirement. On the maturity of each Alternate Investment, the Trustee shall pay the difference between the total of the receipts on the Alternate Investment and the purchase price of the Alternate Investment to the Corporation with a notice to the Corporation that such amount must be paid to the Internal Revenue Service pursuant to Internal Revenue Service Revenue Procedure 95-47. If the Alternate Investment matures more than twenty-nine (29) days prior to the next succeeding interest payment date on the Refunded Bonds on which such proceeds will be needed to pay principal of and premium, if any, and interest on the Refunded Bonds, the Trustee shall treat such amounts as an invested balance available for reinvestment and shall take all reasonable steps to invest such amounts in SLGs (or additional Alternate Investments as provided in this Section). The Trustee shall hold balances not so invested in accordance with Section 4 hereof. (C) The Trustee may sell or redeem the Securities in advance of their maturity dates and invest the proceeds of such sale or redemption or other moneys credited to the Trust Fund in connection with such sale or redemption in other non-callable obligations issued or guaranteed by the United States of America (the "Substitute Securi- ties") only upon receipt of written instructions from the Corporation to do so and receipt by the parties hereto and the Corporation of (1) an opinion in form and substance satisfactory to them from a nationally recognized bond counsel to the effect that such action will not affect adversely the status of the interest on the Bonds Being Refunded or the Refunding Bonds for federal income tax purposes and will not affect adversely the right of the Corporation to issue obli- gations the interest on which is excludable from gross income for federal income tax purposes and (2) a report from a nationally recog- nized accountant or firm of accountants verifying the accuracy of the arithmetic computations of the adequacy of the proceeds from the liquidation together with any other moneys and the maturing principal of and interest on the Substitute Securities to be credited to the Trust Fund, to pay when due the interest on the Bonds Being Refunded and the principal of the Bonds Being Refunded as they become due at maturity. Upon any such sale or redemption of investments and reinvestment, any amounts not needed in the Trust Fund to provide for payments on the Bonds Being Refunded, as shown by such accountant's report, may be withdrawn from the Trust Fund at the direction of the Corporation, returned to the Treasurer and applied for the benefit of the Corporation in accordance with applicable law. Section 3. The debt service on the Bonds Being Refunded shall be paid from the Trust Fund from the following sources in the order listed below: (A) The Initial Cash Deposit. 3 (B) Cash receipts from the Securities, Restricted Reinvestment Obligations, Alternate Investments or Substitute Securi- ties. Moneys shall be applied consistently with the Payment Schedules. Section 4. Any moneys credited to the Trust Fund which are not invested in the Securities, Restricted Reinvestment Obligations, Alternate Investments or Substitute Securities as provided herein shall be held as a demand deposit and shall be secured in the same manner as deposits of public moneys. Section 5. (A) The Trustee shall make timely payments from the Trust Fund to the Indenture Trustee, as the trustee and paying agent for the Bonds Being Refunded, in the amounts and on the dates necessary to permit the payment when due of the principal of and interest on the Bonds Being Refunded as the same become due and payable as set forth in the Payment Schedules. (B) The Corporation hereby irrevocably instructs the Trustee to, and the Trustee shall, as soon as possible, cause notice of the defeasance and refunding of the Bonds Being Refunded, in the form as shown substantially in the form in Exhibit "D" attached here- to, to be mailed, by first class mail, postage prepaid, to each regis- tered owner of the Bonds Being Refunded, at the address shown on the register maintained by the Indenture Trustee and as required by the Original Indenture. (C) The Corporation also hereby irrevocably instructs the Trustee, in its capacity as the Indenture Trustee, to, and the Trustee shall, in the name and at the expense of the Corporation, not more than forty-five (45) nor less than thirty (30) days prior to the redemption date, give notice of redemption to each owner of the Refunded Bonds at the address thereof appearing in the bond register maintained by the Indenture Trustee on the fifteenth day preceding such mailing in the form in Exhibit "E" attached hereto, to be mailed, by first class mail, postage prepaid. Section 6. If at any time or funds on hand in the Trust Fund for the and redemption premiums interest on the same become due or are to be redeemed, notify the Corporation of such. deficienc tered or overnight mail, postage prepaid. times .there are insufficient payment of the principal of Bonds Being Refunded as the the Trustee shall promptly y by telephone and by regis- Section 7. On or before January 15 and July 15, the Trustee shall submit to the Corporation and the Town of Marana, Arizona (the "Town") a report covering all moneys the Trustee has received and all payments the Trustee has made under the provisions hereof during the six-month period ending on the preceding July 1 or January 1. Each such report also shall list all investments and moneys on deposit with the Trustee as of the date of the report. 4 Section 8. (A) The Trustee shall be entitled to a fee of $ per year for the services provided hereunder by it. (B) The Trustee hereby waives and releases any claim which it otherwise would have, as a lien or otherwise, against the Trust Fund for any payment and shall seek such amounts from the Corporation only for the payment of fees of the Trustee for all other services in connection with services of the Trustee hereunder and in connection with the Refunding Bonds. Section 9. When all amounts payable on the Bonds Being Refunded have become due and the Trustee has on deposit all moneys necessary for the payment of such amounts, and in any event on the business day succeeding the date the last of the Bonds Being Refunded is redeemed or paid, the Trustee shall transfer to the Corporation all moneys and investments credited to the Trust Fund in excess of the amounts payable on the Bonds Being Refunded. Section 10. The registered owners of the Bonds Being Refunded have a beneficial interest in the moneys and investments held in the Trust Fund. This Escrow Trust Agreement shall not be revoked and shall not be amended in any manner which may adversely affect the rights herein sought to be protected until the provisions of this Escrow Trust Agreement have been fully carried out. Section 11. The Trustee shall be under no obligation to inquire into or be otherwise responsible for the performance or nonperformance by the Corporation of any of its obligations or to protect any of the rights of the Corporation under any of the proceedings with respect to the Bonds Being Refunded or the Refunding Bonds. The Trustee shall not be liable for any act done or step taken or omitted by it or for any mistake of fact or law or for anything which it may do or refrain from doing except for its gross negligence or its default in the performance of any obligation imposed upon it under the terms of this Escrow Trust Agreement. The Trustee shall not be liable or responsible for any loss resulting from any investment made pursuant to this Escrow Trust Agreement in compliance with the provisions hereof. Section 12. The Corporation and the Town shall have the right to audit the records and accounts of the Trustee insofar as they pertain to the trust created hereunder. Section 13. (A) Except as provided elsewhere herein, neither this Escrow Trust Agreement nor the Trust Fund may be assigned by the Trustee without the prior written consent of the Corporation, which consent, however, shall not be unreasonably withheld. If the Trustee is required by law to divest itself of its interest in its trust department or if the Trustee sells or otherwise assigns all or substantially all of its trust or corporate trust business, then the trust established by this Escrow Trust Agreement shall be continued by the Trustee's successor in interest without further consent of the Corporation being required. 5 (B) Notwithstanding the foregoing subsection, any trust company or national banking association into which the Trustee or its successor may be converted, merged or with which it may be consolidated, or to which it may sell or transfer all or substantially all of its corporate trust business as a whole shall be the successor of the Trustee with the same rights, powers, duties and obligations and subject to the same restrictions, limitations and liabilities as its predecessor, all without the execution or filing of any paper or any further act on the part of any of the parties hereto, anything herein to the contrary notwithstanding. Section 14. If any section, paragraph, subdivision, sen- tence, clause or phrase hereof shall for any reason be held illegal or unenforceable, such decision shall not affect the validity of the remaining portions hereof. The parties hereby declare that they would have executed this Escrow Trust Agreement and each and every other section, paragraph, subdivision, sentence, clause and phrase hereof, irrespective of the fact that any one or more sections, paragraphs, subdivisions, sentences, clauses or phrases hereof may be held to be illegal, invalid or unenforceable. If any provision hereof contains any ambiguity which may be construed as either valid or invalid, the valid construction shall be adopted. In construing this Escrow Trust Agreement, it should be noted that the parties intend that the Refunding Bonds, the Bonds Being Refunded are to be obligations the interest on which is excludable from gross income under Section 103 (a) of the Internal Revenue Code of 1986, as amended, and the provisions hereof should be construed to permit that result. Section 15. To the extent applicable by provision of law, all parties acknowledge that this Escrow Trust Agreement is subject to cancellation pursuant to Section 38-511, Arizona Revised Statutes, as amended, the provisions of which are incorporated herein. Section 16. This Escrow Trust Agreement shall be governed exclusively by the provisions hereof and by the applicable laws of the State of Arizona. This Escrow Trust Agreement expresses the entire understanding and all agreements of the parties hereto with each other with respect to the subject matter hereof and no party hereto has made or shall be bound by any agreement or any representation to any other party which is not expressly set forth in this Escrow Trust Agreement. Section 17. Notice shall be sufficient hereunder, if it is contained in a writing sent to the Corporation at c/o Town of Marana, Arizona, 11555 West Civic Center Drive, Marana, Arizona 85653, Attention: President, to the Town at 11555 West Civic Center Drive, Marana, Arizona 85653, Attention: Town Manager, and to the Trustee at Wells Fargo Plaza, MAC S4101-22E, 100 West Washington Street, 22nd Floor, Phoenix, Arizona 85003, Attention: Corporate Trust Services, or any other address which may be designated from time to time by any party in writing delivered to the Corporation or the Trustee, as applicable. 6 Section 18. This Escrow Trust Agreement may be executed in several counterparts, each of which shall be an original, but all of which together shall constitute but one instrument. IN WITNESS WHEREOF, the parties hereto have caused this Escrow Trust Agreement to be executed as of the day and year first above written. TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION, an Arizona nonprofit corporation By ..................................... President ATTEST ............................... Secretary WELLS FARGO BANK, NATIONAL ASSOCIATION, as Trustee By ..................................... Authorized Officer ACKNOWLEDGED BY WELLS FARGO BANK, NATIONAL ASSOCIATION, as Indenture Trustee By ............................. Authorized Representative 328191653v 1 4/23/2008 8 F.XHTRTT A REMAINING DEBT SERVICE OF BONDS BEING REFUNDED Original Redemption Date Interest Principal Price Debt Service * The Bonds Being upon payment of principal amount if any, on the payment date to principal amount Refunded shall be redeemed on July 1, 2008[???], the redemption price which shall consist of the of the Bonds Being Refunded plus accrued interest, Bonds Being Refunded from the most recent interest January 1, 2009, plus a premium of 1.00% of the of the Bonds Being Refunded. A-1 EXHIBIT B TRUST FUND SECURITIES Maturity Par Typee Date Amount/Cost Coupon SLG-Cert B-1 EXHIBIT C SCHEDULE OF TOTAL ESCROW RECEIPTS AND PAYMENTS Trust Fund Date Requirements Receipts Cash Balance C-1 F.XHTRTT ll NOTICE OF REFUNDING of TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION MUNICIPAL FACILITIES REVENUE BONDS, SERIES 1997 DATED AS OF OCTOBER 1, 1997 MATURING ON JULY 1, 2009 THROUGH AND INCLUDING JULY 1, 2013, AND ON JULY 1, 2022 Notice is hereby given to the registered owners of the above-referenced Bonds (the "Bonds") that the Bonds have been refunded in advance of their stated maturity dates by the establishment of an irrevocable trust with Wells Fargo Bank, National Association, as trustee. According to a report by Grant Thornton LLP certified public accountants, the moneys and obligations issued or guaranteed by the United States of America, which have been deposited in the irrevocable trust, are scheduled to provide funds in amounts sufficient to redeem all of the Bonds on July 1, 2008. DATED: ...., 2008 WELLS FARGO BANK, NATIONAL ASSOCIATION, as Trustee D-1 F.XHTRTT F. NOTICE OF REDEMPTION of TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION MUNICIPAL FACILITIES REVENUE BONDS, SERIES 1997 DATED AS OF OCTOBER 1, 1997 MATURING ON JULY 1, 2009 THROUGH AND INCLUDING JULY 1, 2013, AND ON JULY 1, 2022 Notice is hereby given that the above-referenced Bonds (the "Bonds") shall be redeemed prior to their stated maturity dates on July 1, 2008. Registered owners of the Bonds are notified to present the same at the office of Wells Fargo Bank, National Association, as trustee on July 1, 2008, the date set for redemption, where redemption will be made by payment of the principal amount of each of the Bonds plus accrued interest to the date of redemption plus a premium of 1.000 of the principal amount of the Bonds. From and after July 1, 2008, no interest will be paid on the Bonds. DATED: ................ 2008 WELLS FARGO BANK, BANK NATIONAL ASSOCIATION, as Trustee E-1 w a <, :~ a:.~ ;~ :. '~ .~ ~.: c ~ .~ ~~ t :~ '~ °` ~G r ~~ <, ~«- c c ~* c -. c ,~ ~ L ~ ,~ ~ °^ ~ ~; :~ :c u o ~~ a v J ;. ;~ ,- ~ . :tl ~ ;,j .~ -o ~;, ~ ~. i~•~ ~s .. '~ ~. c c' ~c -, y. ~ d .~: w.« .~ ... ~ ~ ~" .» V .~ a ~, c ~, 4 s c ~' ~ ., :.. .~~ :~ r .f . c m ~ -v~. PRELIMINARY OFFICIAL STATEMENT DATED MAY _, 2008 NEW ISSUE -BOOK-ENTRY-ONLY SYSTEM RATINGS: See "RATINGS" herein. In the opinion of Bond Counsel, assuming compliance with certain tax covenants, interest on the Series 2008 Bonds will be excluded from gross income for federal income tax purposes under existing statutes, regulations, rulings and court decisions. Interest on the Series 2008 Bonds will not be an item of tax preference for purposes of the federal alternative minimum tax imposed on individuals and corporations. However, see "TAX MATTERS" herein for a description of the federal alternative minimum tax on corporations and certain other federal tax consequences of ownership of the Series 2008 Bonds. Bond Counsel is further of the opinion that, assuming interest will be so excludable for federal income tax purposes, the interest on the Series 2008 Bonds will be exempt from income taxation under the laws of the State of Arizona. See also "ORIGINAL ISSUE DISCOUNT" and "BOND PREMIUM. " $38,330,000* DRAFT II TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION 5/13/08 MUNICIPAL FACILITIES REVENUE BONDS, SERIES 2008 Consisting of $29,630,000* $8,700,000* Municipal Facilities Revenue Bonds, Municipal Facilities Revenue Bonds, Series 2008A Series 2008B Dated: Date of Initial Authentication and Delivery Due: January 1 and July 1, as shown on inside front cover The Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2008, consisting of the Municipal Facilities Revenue Bonds, Series 2008A (the "Series 2008A Bonds") and the Municipal Facilities Revenue Bonds, Series 2008B (the "Series 2008B Bonds" and together with the Series 2008A Bonds, the "Series 2008 Bonds"), are issued for the purpose of providing funds to (i) acquire, construct, improve and extend, as applicable, sewer facilities, streets and parks of the Town of Marana, Arizona (the "Town"); (ii) to refund and redeem the Bonds Being Refunded (as defined herein); (iii) fund a debt service reserve fund for the Series 2008 Bonds (or pay the premium associated with a debt service reserve fund insurance policy or surety bond); and (iv) pay costs in connection with the issuance of the Series 2008 Bonds. Interest on the Series 2008 Bonds will be payable on January 1 and July 1 of each year, commencing on January 1, 2009*. The Series 2008 Bonds will be issued only as fully registered bonds without coupons in the denomination of $5,000 of principal amount or any integral multiple thereof, will initially be registered in the name of Cede & Co., as nominee of The Depository Trust Company, New York, New York ("DTC"), and will be available to ultimate purchasers in amounts of $5,000 of principal or any integral multiple thereof due on a specific maturity date pursuant to the book-entry-only system maintained by DTC. Payments of principal of and premium, if any, and interest with respect to the Bonds will be paid by, Wells Fargo Bank, National Association, as trustee (the "Trustee") to DTC for subsequent disbursements to DTC participants who will remit such payments to the beneficial owners of the Series 2008 Bonds. See APPENDIX H - "BOOK-ENTRY-ONLY SYSTEM." SEE MATURITY SCHEDULE ON INSIDE FRONT COVER The Series 2008A Bonds will be subject to optional and mandatory redemption prior to maturity*. The Series 2008B Bonds will be subject to optional and to extraordinary optional redemption prior to maturity*. See "THE SERIES 2008 BONDS -Redemption Provisions" herein. Principal of and premium, if any, and interest on the Series 2008 Bonds will be payable from rental payments to be paid by the Town to the Town of Marana Municipal Property Corporation (the "Corporation") pursuant to a Combined Cortaro Silverbell District Park Ground Lease and Fourth Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, to be dated as of June 1, 2008* (the "Town Lease"), between the Town and the Corporation. The payment of the rental payments will be made from, and secured by, a pledge of Excise Taxes (as defined herein), such pledge and lien being a first lien and pledge upon such Excise Taxes on a parity with $220,000* aggregate principal amount of currently outstanding obligations payable from such source and Additional Excise Tax Obligations (as defined herein) that may hereafter be issued or incurred. See "THE SERIES 2008 BONDS -Security and Source of Payments" herein. The Series 2008 Bonds will be special obligations of the Corporation payable solely from the sources herein described. The Series 2008 Bonds are not general obligations of the Corporation, the Town, the State of Arizona or any political subdivision thereof, and the full faith and credit of the Corporation, the Town, the State of Arizona or any political subdivision thereof is not pledged for the payment of the Series 2008 Bonds. The Corporation has no taxing power. Payment of the principal of and interest on the Series 2008 Bonds when due will be insured by a insurance policy issued simultaneously with the delivery of the Series 2008 Bonds by [Insert insurance logo) The Series 2008 Bonds are offered when, as and if issued and received by the underwriter identified below (the "Underwriter"), and subject to the approving opinion of Greenberg Traurig, LLP, Bond Counsel, as to validity and tax exemption. In addition, certain legal matters will be passed upon for the benefit of the Underwriter by Squire, Sanders & Dempsey L.L.P. It is expected that the Series 2008 Bonds will be available for delivery through the facilities of DTC on or about June 26, 2008*. This cover page contains certain information with respect to the Series 2008 Bonds for convenience of reference only. It is not a summary of material information with respect to the Series 2008 Bonds. Investors must read the entire official statement to obtain information essential to the making of an informed investment decision with respect to the Series 2008 Bonds. * Subject to change. ~ T ~ ~ ~. ~~ ~ ~ ~ $ ~ R. {-.r MATURITY SCHEDULE* $29,630,000 Municipal Facilities Revenue Bonds, Series 2008A Maturity Principal Interest Price or Date Amount Rate Yield [To come/ $8,700,000 Municipal Facilities Revenue Bonds, Series 2008B Maturity Principal Interest Price or Date Amount Rate Yield [To come) * Subject to change. REGARDING THIS OFFICIAL STATEMENT No dealer, broker, salesperson or other person has been authorized by the Corporation, the Town or the Underwriter to give any information or to make any representations other than those contained in this Official Statement, and, if given or made, such information or representations must not be relied upon as having been authorized by the foregoing. This Official Statement does not constitute an offer to sell or the solicitation of an offer to buy nor shall there be any sale of the Series 2008 Bonds by any person in any jurisdiction in which it is unlawful for such person to make such offer, solicitation or sale. The information set forth herein has been obtained from the Town, the Pima County Assessor's Office and Treasurer's Offices and other sources which are considered to be reliable and customarily relied upon in the preparation of similar official statements. The presentation of information, including tables of receipts from taxes and other sources, is intended to show recent historical information and is not intended to indicate future or continuing trends in the fmancial position or other affairs of the Town. The Underwriter has reviewed the information in this Official Statement in accordance with, and as part of, its responsibilities to investors under the federal securities laws as applied to the facts and circumstances of this transaction, but the Underwriter does not guarantee the accuracy or completeness of such information. All information, estimates and assumptions contained herein have been based on past experience and on the latest information available and are believed to be reliable, but no representations are made that such information, estimates and assumptions are correct, will continue, will be realized or will be repeated in the future. To the extent that any statements made in this Official Statement involve matters of opinion or estimates, whether or not expressly stated to be such, they are made as such and not as representations of fact or certainty, and no representation is made that any of these statements have been or will be realized. All forecasts, projections, assumptions, opinions or estimates are "forward looking statements" which must be read with an abundance of caution and which may not be realized or may not occur in the future. Information other than that obtained from official records of the Town has been identified by source and has not been independently confirmed or verified by the Town. 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 Town or any of the other parties or matters described herein since the date hereof. The Series 2008 Bonds will not be registered under the Securities Act of 1933, as amended, or any state securities law, and will not be listed on any stock or other securities exchange. Neither the Securities and Exchange Commission nor any other federal, state or other governmental entity or agency will have passed upon the accuracy or adequacy of this Official Statement or approved the Series 2008 Bonds for sale. As the "obligated person" with respect to the Series 2008 Bonds, the Town will undertake to provide continuing disclosure as described in this Official Statement under "CONTINUING DISCLOSURE" and in APPENDIX F - "FORM OF CONTINUING DISCLOSURE AGREEMENT," all pursuant to Rule 15c2-12 of the Securities and Exchange Commission. IN CONNECTION WITH THE OFFERING OF THE SERIES 2008 BONDS, THE UNDERWRITER MAY OVERALLOT OR EFFECT TRANSACTIONS WHICH STABILIZE OR MAINTAIN THE MARKET PRICE OF THE SERIES 2008 BONDS AT A LEVEL ABOVE THAT WHICH MIGHT OTHERWISE PREVAIL IN THE OPEN MARKET. SUCH STABILIZING, IF COMMENCED, MAY BE DISCONTINUED AT ANY TIME. THE UNDERWRITER MAY OFFER AND SELL THE SERIES 2008 BONDS TO CERTAIN DEALERS, INSTITUTIONAL INVESTORS AND OTHERS AT PRICES LOWER THAN THE PUBLIC OFFERING PRICES STATED ON THE INSIDE FRONT COVER PAGE HEREOF AND SUCH PUBLIC OFFERING PRICES MAY BE CHANGED FROM TIME TO TIME BY THE UNDERWRITER. TABLE OF CONTENTS Page INTRODUCTION .........................................................................................................................................................1 TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION ....................................................................... ..1 THE SERIES 2008 BONDS ........................................................................................................................................ ..2 Authorization and Purpose ...................................................................................................................................... ..2 General Description ................................................................................................................................................. ..2 Redemption Provisions ............................................................................................................................................ ..2 Security and Sources of Payment ............................................................................................................................ ..3 Town Covenant Regarding Maintenance of Excise Taxes ...................................................................................... ..4 Town's Right to Further Encumber Excise Taxes ................................................................................................... ..4 Additional Bonds of the Corporation ....................................................................................................................... ..4 PLAN OF FINANCE .................................................................................................................................................. ..5 THE PROJECTS ......................................................................................................................................................... ..5 DEBT SERVICE RESERVE FUND SURETY BOND AND BOND INSURANCE ................................................ ..6 Debt Service Reserve Fund Surety Bond ................................................................................................................. ..6 Payment Pursuant to Insurance Policy ................................................................................. ..6 EXCISE TAXES ......................................................................................................................................................... ..7 Town Sales Taxes .................................................................................................................................................... ..7 State-Shared Revenues ............................................................................................................................................ ..9 Licenses and Permits; Fines and Forfeitures ........................................................................................................... 10 Excise Tax Collections ............................................................................................................................................ 10 POSSIBLE LEGISLATIVE OR INITIATIVE MEASURES ..................................................................................... 11 ESTIMATED DEBT SERVICE REQUIREMENTS AND COVERAGE* ................................................................ 12 TOWN GENERAL FUND .......................................................................................................................................... 14 SOURCES AND USES OF FUNDS ........................................................................................................................... 15 LITIGATION .............................................................................................................................................................. 15 TAX MATTERS ......................................................................................................................................................... 16 ORIGINAL ISSUE DISCOUNT ................................................................................................................................. 16 BOND PREMIUM ...................................................................................................................................................... 17 RATINGS .................................................................................................................................................................... 17 LEGAL MATTERS .................................................................................................................................................... 17 UNDERWRITING ...................................................................................................................................................... 18 POLITICAL CONTRIBUTIONS ............................................................................................................................... 18 RELATIONSHIP AMOUNG PARTIES ..................................................................................................................... 18 CONTINUING DISCLOSURE ................................................................................................................................... 18 FINANCIAL STATEMENTS ..................................................................................................................................... 19 CERTIFICATION CONCERNING OFFICIAL STATEMENT ................................................................................. 19 CONCLUDING STATEMENT .................................................................................................................................. 20 APPENDIX A: Town of Marana, Arizona -General Economic and Demographic Information APPENDIX B: Town of Marana, Arizona -Financial Data APPENDIX C: Town of Marana, Arizona -Excerpts from the Audited General Purpose Financial Statements for the Fiscal Year Ended June 30, 2007 APPENDIX D: Summary of Certain Provisions of Legal Documents APPENDIX E: Form of Approving Legal Opinion APPENDIX F: Form of Continuing Disclosure Agreement APPENDIX G: Specimen Insurance Policy APPENDIX H: Book-Entry-Only System OFFICIAL STATEMENT $38,330,000* TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION MUNICIPAL FACILITIES REVENUE BONDS, SERIES 2008 Consisting of $29,630,000* Municipal Facilities Revenue Bonds, Series 2008A $8,700,000* Municipal Facilities Revenue Bonds, Series 2008B INTRODUCTION This Official Statement, which includes the cover page and the appendices attached hereto, sets forth certain information concerning Town of Marana Municipal Property Corporation (the "Corporation") and its Municipal Facilities Revenue Bonds, Series 2008 consisting of the Municipal Facilities Revenue Bonds, Series 2008A (the "Series 2008A Bonds") and the Municipal Facilities Revenue Bonds, Series 2008B (the "Series 2008B Bonds" and together with the Series 2008A Bonds, the "Series 2008 Bonds"), as such information is know at the time of the original issuance and sale of the Series 2008 Bonds. The offering of the Series 2008 Bonds is made only by way of this Official Statement, which supersedes any other information or materials used in connection with the offering or sale of the Series 2008 Bonds. Accordingly, purchasers of the Series 2008 Bonds should read this entire Official Statement before making their investment decision. For definitions of certain words used in this Official Statement and not otherwise defined in the text prior to such section, see APPENDIX D - "SUMMARY OF CERTAIN PROVISIONS OF LEGAL DOCUMENTS -DEFINITIONS OF CERTAIN TERMS. " TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION The Corporation is a nonprofit corporation existing pursuant to the laws of the State of Arizona (the "State" or "Arizona") and incorporated on March 11, 1989. The Corporation is permitted, pursuant to its Articles of Incorporation, to conduct all lawful affairs for which nonprofit corporations may be incorporated pursuant to the laws of the State, subject to the express limitation and condition that the Corporation will always be operated solely and exclusively in the interest of the general public. The Corporation exists and acts as a separate entity. The Board of Directors of the Corporation presently consists of five members who were appointed by the Mayor and Council of the Town of Marana, Arizona (the "Town"). The Corporation has the power to incur indebtedness and issue bonds, to own real property, to provide for the acquisition and construction of municipal facilities, to lease such facilities to the Town and to exercise any and all rights and powers which a nonprofit corporation organized under the laws of the State may now or hereafter exercise. Upon the dissolution of the Corporation, all of its assets remaining after payment of or provision for payment of all debts and liabilities will be distributed to the Town. The Corporation has no stockholders or members. Vacancies occurring on the Board of Directors of the Corporation are filled by appointment of the Mayor and Council of the Town. Members of the Board of Directors may be removed, with or without cause, by the Mayor and Council of the Town. All amendments to the Articles of Incorporation or Bylaws of the Corporation require approval by the Mayor and Council of the Town. No compensation is paid to any officer or director of the Corporation. * Subject to change. THE SERIES 2008 BONDS Authorization and Purpose The Series 2008 Bonds will be issued by the Corporation pursuant to a Trust Indenture, dated as of October 1, 1997 (the "Indenture"), as supplemented by the prior Supplemental Indentures and a Series 2008 Supplemental Trust Indenture, to be dated as of June 1, 2008* (the "Series 2008 Supplemental Indenture" and, collectively with the Indenture and the prior Supplemental Indentures, the "Indentures"), from the Corporation to Wells Fargo Bank, National Association (formerly Norwest Bank Arizona, N.A. and Wells Fargo Bank Arizona, N.A.), as trustee (the "Trustee"), to provide funds to (i) acquire, construct, improve and extend, as applicable, sewer facilities, streets and parks of the Town (collectively, the "Projects"); (ii) refund and redeem the Bonds Being Refunded (as defined herein); (iii) fund a debt service reserve fund for the Series 2008 Bonds (or pay the premium associated with a debt service reserve fund insurance policy or surety bond); and (iv) pay costs in connection with the issuance of the Series 2008 Bonds. See "THE PROJECTS" and "PLAN OF FINANCE" herein. General Description The Series 2008 Bonds will be dated as of the date of initial delivery, bear interest payable commencing January 1, 2009* and semiannually thereafter on July 1 and January I, each year until maturity or redemption (the "Interest Payment Dates") and mature on the dates and in the amounts and beaz interest from their date at the rates set forth on the inside front cover page of this Official Statement. The Series 2008 Bonds initially will be registered only in the name of Cede & Co., as nominee of The Depository Trust Company, New York, New York ("DTC"), for purposes of a book-entry-only system. Beneficial ownership interests in the Series 2008 Bonds may be purchased through direct and indirect participants of DTC in amounts of $5,000 of principal due on a specific maturity date or integral multiples thereof. See APPENDIX H - "BOOK-ENTRY-ONLY SYSTEM." Redemption Provisions* Optional Redemption of Series 2008A Bonds. The Series 2008A Bonds maturing on or after 1, 20 ,will be subject to redemption, at the option of the Corporation, acting at the request of the Town, in whole at any time, or in part on any Interest Payment Date, in any order of maturity and by lot within a maturity, on or after 1, 20_, or any Interest Payment Date thereafter at the redemption price of the principal amount to be redeemed, plus accrued interest to the date fixed for redemption, without premium. Mandatory Redemption of Series 2008A Bonds. The Series 2008A Bonds maturing on 1, 20 * will be subject to mandatory redemption on the following dates and in the following amounts, at a redemption price equal to the principal amount thereof plus interest accrued to the date of redemption: Redemption Principal Date Amount* (maturity) Not more than forty-five (45) days nor less than thirty (30) days prior to the mandatory redemption payment date for the Series 2008A Bonds maturing on 1, 20 *, the Trustee shall proceed to select for redemption (by lot in such manner as the Trustee may determine) from all of the Series 2008A Bonds maturing on 1, 20 *, a principal amount of the Series 2008A Bonds equal to the aggregate principal amount of the Series 2008A Bonds redeemable with the required mandatory redemption payment, and shall call such Series 2008A Bonds for redemption on the next 1 and give notice of such call. * Subject to change. Optional Redemption of Series 2008E Bonds. The Series 2008B Bonds maturing on or after 1, 20_, are subject to redemption, at the option of the Corporation, acting at the request of the Town, in whole at any time, or in part on any Interest Payment Date, in any order of maturity and by lot within a maturity, on or after 1, 20_, or any Interest Payment Date thereafter at the redemption price of the principal amount to be redeemed, plus accrued interest to the date fixed for redemption, without premium. Extraordinary Optional Redemption of Series 2008E Bonds. The Series 2008B Bonds maturing on or after 1, 20 ,are subject to redemption, at the option of the Corporation, acting at the request of the Town, in whole at any time, or in part on any Interest Payment Date, in any order of maturity and by lot within a maturity, on or after 1, 20 , or any Interest Payment Date thereafter at the redemption price of the principal amount to be redeemed, plus accrued interest to the date fixed for redemption, without premium, but only from Method for and Notice of Redemption. Those Series 2008 Bonds which are to be redeemed will be redeemed in any order of the maturities of the Series 2008 Bonds requested by the Town. The selection of amounts to be redeemed will be made as described in APPENDIX G - "BOOK-ENTRY-ONLY SYSTEM." A notice of redemption of Series 2008 Bonds will identify (i) the portions of the Series 2008 Bonds to be redeemed, (ii) the redemption price to be paid and (iii) the date fixed for redemption. The notice will be given by the Trustee on behalf of the Corporation by providing the redemption notice to DTC not more than forty-five (45) nor less than thirty (30) days prior to the date fixed for redemption. See APPENDIX H - "BOOK-ENTRY-ONLY SYSTEM." Security and Sources of Payment Pursuant to a Combined Cortaro Silverbell District Park Ground Lease and Fourth Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, to be dated as of June 1, 2008* (the "Series 2008 Town Lease"), the Corporation will supplement and extend its lease of certain real property and improvements and ground lease from the Town other real property (collectively, the "Leased Property") to the Town. The Leased Property will include the site of the Cortaro Silverbell District Park. See "THE PROJECTS" herein. The remaining Leased Property was fmanced or refinanced with portions of the proceeds of the sale of the Corporation's Municipal Facilities Revenue Bonds, Series 1997, dated as of October 1, 1997 (the "Series 1997 Bonds"), Municipal Facilities Revenue Bonds, Series 2003, dated as of September 1, 2003 (the "Series 2003 Bonds"), Municipal Facilities Revenue Bonds, Series 2004, dated as of August 1, 2004 (the "Series 2004 Bonds" and collectively with the Series 1997 Bonds, the Series 2003 Bonds and the Series 2008 Bonds and any "Additional Bonds" which may be issued pursuant to the Indentures, the "Bonds"). (The Series 1997 Bonds are currently outstanding in the aggregate principal amount of $ ,000*, the Series 2003 Bonds are currently outstanding in the aggregate principal amount of $17,845,000 and the Series 2004 Bonds are currently outstanding in the aggregate principal amount of $7,770,000.) Pursuant to the Series 2008 Town Lease, the Town will lease the Leased Property, and the Town, as agent for the Corporation, will acquire, design, construct, improve and extend the Projects and assist in refinancing the Bonds Being Refunded. Pursuant to the Series 2008 Town Lease, the Town will pay directly to the Trustee, as assignee of the Corporation, rental payments ("Rental Payments") which will be sufficient to meet the principal and interest requirements with respect to the Series 2008 Bonds as well as pay all taxes, charges and expenses imposed upon the Corporation and its property, operations or income, with respect to the Leased Property. The Town will pledge, on a first lien basis, for the payment of the Rental Payments pursuant to the Series 2008 Town Lease, Town transaction privilege (sales) taxes, State-shared revenues, license and permit fees and fines and forfeitures (collectively, the "Excise Taxes"). Such pledge will be on a parity with the pledge and lien of the Town granted pursuant to the Amended and Restated Town Lease and Series 1992 Town Lease, dated as October 1, 1997, entered into with respect to the Series 1997 Bonds; as supplemented by a Second Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of September 1, 2003, entered into with the respect to the Series 2003 Bonds and as supplemented by a Third Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of August 1, * Subject to change. Includes the Bonds Being Refunded. 2004, entered into with respect to the Series 2004 Bonds collectively with the Series 2008 Town Lease and certain amendments not related to the issuance of the Bonds, the "Town Leases"), by and between the Corporation, as lessor, and the Town, as lessee. See "HISTORICAL AND PROJECTED EXCISE TAX COLLECTIONS." The Town will first make all rental payments accruing under the Town Leases out of the Excise Taxes and thereafter may use the remaining of the Excise Taxes for any other lawful purpose, but only to the extent that, taking into account the reasonably anticipated receipts, the Excise Taxes will not be reduced to such a level that the Town will be unable to make such payments under the Town Leases. (The Town is not obligated to pay rental payments from any source other than the Excise Taxes. The Town may, at the sole option of the Town, make rental payments from other funds as permitted by law and as the Town may determine from time to time.) Town Covenant Regarding Maintenance of Excise Taxes Pursuant to the Town Leases, the Excise Taxes will be retained and maintained so that the amounts received from the Excise Taxes all within and for the next preceding fiscal year will be equal to at least two (2.0) times the total of rental payments payable pursuant to the Town Leases in any current fiscal year of the Town. If at any time the Excise Taxes will not be sufficient to pay all current rental payments required pursuant to the Town Leases or if such amounts will not be equal to at least two (2.0) times the rental payments in any current fiscal year, the Town will impose new exactions of the type of the Excise Taxes which will be part of the Excise Taxes or increase the rates of the Excise Taxes currently imposed in order that (i) the Excise Taxes will be sufficient to pay all current rental payments pursuant to the Town Leases and (ii) such amounts will be reasonably calculated to attain the level as required in the first sentence of this paragraph. Town's Right to Further Encumber Excise Taxes Pursuant to the Town Leases, so long as the Series 2008 Bonds remain outstanding and the principal and interest thereon shall be unpaid or unprovided for, the Town will not further encumber the Excise Taxes on a basis equal to the first lien pledge contained therein ("Additional Excise Tax Obligations") unless, among other things, the Excise Taxes collected in the immediately preceding fiscal year shall have amounted to at least three (3.0) times the highest combined interest and principal requirements for any succeeding twelve (12) months' period for all of the Bonds then outstanding and any additional obligations permitted by the Town Leases including any Additional Bonds so proposed to be secured by a pledge of the Excise Taxes. THE SERIES 1997 BONDS, THE SERIES 2003 BONDS, THE SERIES 2004 BONDS AND THE SERIES 2008 BONDS AND THE RENTAL PAYMENTS PURSUANT TO THE TOWN LEASES DO NOT CONSTITUTE AN INDEBTEDNESS OR GENERAL OBLIGATION OF THE TOWN NOR SHALL THE TOWN BE LIABLE FOR THE PAYMENT FROM AD VALOREM TAXES OF PRINCIPAL OF AND INTEREST ON THE SERIES 1997 BONDS, THE SERIES 2003 BONDS, THE SERIES 2004 BONDS, THE SERIES 2008 BONDS OR SUCH RENTAL PAYMENTS. PURSUANT TO THE INDENTURES, THE SERIES 2008 BONDS WILL BE SPECIAL OBLIGATIONS OF THE CORPORATION, AND THE BOND SERVICE CHARGES THEREON, SHALL BE PAYABLE SOLELY FROM THE RENTAL PAYMENTS MADE PURSUANT TO THE TOWN LEASES AND NOT FROM ANY OTHER REVENUES OF THE TOWN. THE SERIES 2008 BONDS DO NOT AND SHALL NOT REPRESENT OR CONSTITUTE A DEBT OR A DIRECT OR INDIRECT PLEDGE OF THE FULL FAITH AND CREDIT OF THE TOWN OR OF THE STATE OR OF ANY POLITICAL SUBDIVISION, MUNICIPALITY OR OTHER AGENCY THEREOF. THE CORPORATION HAS NO TAXING POWER. SEE APPENDICES A, B AND C HERETO FOR CERTAIN INFORMATION ABOUT THE TOWN. Additional Bonds of the Corporation The Corporation may issue Additional Bonds from time to time for any purpose permitted in the Indentures. Such Additional Bonds may be on a parity with the Series 1997 Bonds, the Series 2003 Bonds, the Series 2004 Bonds, the Series 2008 Bonds and any additional obligations permitted by the Town Leases including any Additional Bonds hereafter issued and outstanding as to the assignment to the Trustee of the Corporation's right, title and interest in the Town Leases and moneys in the accounts of the funds created in the Indentures; provided, that nothing shall prevent payment of Bond Service Charges on any series of Additional Bonds from (i) being otherwise secured and protected from sources or by property or instruments not applicable to the Bonds and any one or more series of Additional Bonds or (ii) not being secured or protected from sources or by property or instruments applicable to the Bonds or one or more series of Additional Bonds. The issuance of such Additional Bonds is subject to certain specific conditions which are set forth in the Indentures. For further information relating to the issuance of Additional Bonds, see APPENDIX D - "SUMMARY OF CERTAIN PROVISIONS OF LEGAL DOCUMENTS -SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURES -- Additional Bonds" herein. PLAN OF FINANCE* A portion of the net proceeds received from the sale of the Series 2008 Bonds will be (a) deposited into the Series 2008 Acquisition and Construction Fund and used to acquire, construct, improve and extend the Projects, and (b) deposited into the Costs of Issuance Fund and used to pay costs associated with the issuance of the Series 2008 Bonds, including the premium for the debt service reserve fund insurance policy or surety bond. See "THE PROJECTS" and "SOURCES AND USES OF FUNDS" herein. The remaining proceeds of the sale of the Series 2008 Bonds will be deposited with Wells Fargo Bank, National Association, pursuant to an escrow trust agreement (the "Escrow Trust Agreement") and used to acquire obligations issued by or guaranteed by the United States of America (the "Securities"), the maturing principal of and interest income with respect to which are calculated to be sufficient to pay, upon redemption, along with cash held pursuant to the Escrow Trust Agreement, the principal of and premium and interest on the following Bonds Being Refunded which were issued by the Corporation pursuant to the Indentures and the Town Leases and are secured by the hereinafter described Excise Taxes (such transaction herein referred to as the "Refunding"). Principal Principal Redemption Issue Maturity Amount Amount Date Redemption Series Date Coupon Outstanding Outstanding (July 1) Premium CUSIP 1997 7/1/2009 4.800% $ 110,000 $ 110,000 2008 1.00% 567548CA6 1/1/2010 4.900 100,000 100,000 2008 1.00 567548CB4 7/1/2010 4.900 105,000 105,000 2008 1.00 567548CC2 1/1/2011 5.000 105,000 105,000 2008 1.00 567548CD0 7/1/2011 5.000 110,000 110,000 2008 1.00 567548CE8 1/1/2012 5.100 105,000 105,000 2008 1.00 567548CF5 7/1/2012 5.100 115,000 115,000 2008 1.00 567548CG3 1/1/2013 5.100 105,000 105,000 2008 1.00 567548CH1 7/1/2013 5.100 105,000 105,000 2008 1.00 567548CJ7 7/1/2022 5.250 2,445,000 2,445,000 2008 1.00 567548CC2 $ 3,405,000 $ 3,405,000 THE PROJECTS The Projects consist of the design, acquisition, construction and equipment, as applicable, of extensions and additions to the sewer lines and interceptors in Silverbell Road and to the Town's Airport; the design, acquisition, construction and equipment of extensions and improvements to Camino de Marana and Dove Mountain Roads and improvements to Cortaro Silverbell District Park. The project budget for the Project is $50.4 million. Construction of the Project is expected to be completed by Upon completion, * Subject to change. DEBT SERVICE RESERVE FUND SURETY BOND AND BOND INSURANCE Debt Service Reserve Fund Surety Bond [To be updated) The Indentures require the funding of the Reserve Fund in an amount equal to the Reserve Requirement as a result of the issuance of the Series 2008 Bonds. The Indentures authorizes the Corporation to obtain a debt service reserve fund surety bond (the "Series 2008 Surety Bond") upon delivery of the Series 2008 Bonds for the purpose of funding the Reserve Fund as required by the issuance of the Series 2008 Bonds. (See APPENDIX D - "SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURES -Flow of Funds" herein). The Series 2008 Bonds will only be delivered upon the issuance of the Series 2008 Surety Bond. The premium for the Series 2008 Surety Bond is to be fully paid at or prior to the issuance and delivery of the Series 2008 Bonds by the Corporation from proceeds of the sale of the Series 2008 Bonds. The Series 2008 Surety Bond provides that upon the later of (i) one (1) day after receipt by of a Demand for Payment (a "Series 2008 Demand for Payment") executed by the Trustee certifying that provision for the payment of principal of or interest on the Series 2008 Bonds when due has not been made or (ii) the interest payment date specified in the Series 2008 Demand for Payment submitted to will promptly deposit funds with the Trustee sufficient to enable the Trustee to make such payments due on the Series 2008 Bonds, but in no event exceeding the "Surety Bond Coverage" as defined in the Series 2008 Surety Bond. Pursuant to the terms of the Series 2008 Surety Bond, the Surety Bond Coverage is automatically reduced to the extent of each payment made by under the terms of the Series 2008 Surety Bond and the Corporation is required to reimburse for any draws under the Series 2008 Surety Bond with interest at a market rate. Upon such reimbursement, the Series 2008 Surety Bond is reinstated to the extent of each principal reimbursement up to but not exceeding the Series 2008 Surety Bond Coverage. The reimbursement obligation of the Corporation is subordinate to the Corporation's obligations with respect to the Series 2008 Bonds. In the event the amount on deposit, or credited to the Reserve Fund, exceeds the amount of the Series 2008 Surety Bond, any draw on the Series 2008 Surety Bond shall be made only after all the funds in the Reserve Fund have been expended. In the event that the amount on deposit in, or credited to, the Reserve Fund, in addition to the amount available under the Series 2008 Surety Bond, includes amounts available under a letter of credit, insurance policy, surety bond or other such funding instrument (the "Additional Funding Instrument"), draws on the Series 2008 Surety Bond and the Additional Funding Instrument shall be made on a pro rata basis to fund the insufficiency. The Indentures provide that the Reserve Fund shall be replenished in the following priority: (i) principal and interest on the Series 2008 Surety Bond and on the Additional Funding Instrument shall be paid from first available Revenues on a pro rata basis; (ii) after all such amounts are paid in full, amounts necessary to fund the Reserve Fund to the required level, after taking into account the amounts available under the Series 2008 Surety Bond and the Additional Funding Instrument shall be deposited from next available Revenues. The Series 2008 Surety Bond does not insure against nonpayment caused by the insolvency or negligence of the Trustee. Payment Pursuant to Insurance Policy (To come) EXCISE TAXES The Excise Taxes pledged to the payment of the rental payments due under the Series 2008 Town Lease currently include the unrestricted portion of the Town transaction privilege (sales) taxes ("Town Sales Taxes"), State-shared revenue (being "State-shared Sales Taxes" and "State Revenue Sharing" and, collectively, "State-shared Revenues"), fees for licenses and permits by the Town ("Licenses and Permits"), and the fines and forfeitures of the Town ("Fines and Forfeitures"). NO ASSURANCES CAN BE GIVEN THAT THE AMOUNT OF STATE- SHARED REVENUES SHARING PROVIDED TO THE TOWN WILL NOT BE REDUCED OR ELIMINATED BY THE ARIZONA LEGISLATURE IN THE FUTURE. SEE "POSSIBLE LEGISLATIVE OR INITIATIVE MEASURES." Major categories of the Excise Taxes are discussed more fully below. Town Sales Taxes The Town Sales Taxes are levied by the Town upon persons and business on account of their business activities within the Town. The amount of taxes due are calculated by applying the tax rate against the gross proceeds of sales or gross income derived from the business activities transacted within the Town. The revenues from Town Sales Taxes are collected by the Arizona Department of Revenue and remitted to the Town on a weekly basis. TABLE 1 TOWN TRANSACTION PRIVILEGE (SALES) TAX RATE BY CATEGORY Effective January 1, 2008 Business Activity Category Rate Mining 2.00% Construction 4.00 Manufacturing 2.00 Transportation, communications and utilities 4.00 Wholesale trade 2.00 Retail trade 2.00 Restaurants and bars 2.00 Fire, insurance and real estate 2.00 Hotels and other lodging 3.00 Services 2.00 All others 2.00 Source: Finance Department of the Town. The following table shows the amounts of the Town Sales Taxes by industry classification for fiscal years 2002/03 through and including 2006/07 and the budgeted amounts of Town Sales Taxes by industry classification for the fiscal year 2007/08. TABLE 2 TOWN TRANSACTION PRIVILEGE (SALES) TAX COLLECTIONS BY INDUSTRY CLASSIFICATION (a)(b) Audited Budgeted (c) Fiscal Year Fiscal Year Fiscal Year Fiscal Year Fiscal Year Fiscal Year Classification 2002/03 2003/04 2004/05 (d) 2005/06 (d) 2006/07 (d) 2007/08 Mining $ 19,446 $ 15,886 $ 20,235 $ 13,592 $ ]36 $ 1],466 Construction (e) 6,818,267 7,637,372 10,029,087 16,026,041 12,010,339 12,570,080 Manufacturing 27,463 40,866 46,352 91,393 898,768 158,861 Transportation, communication and utilities 1,339,125 1,632,955 2,025,216 2,440,989 2,617,876 2,542,829 Wholesale trade 117,525 88,038 78,711 187,311 482,350 ] 82,612 Retail trade 6,447,144 7,230,986 9,091,413 11,020,868 8,849,138 9,480,284 Restaurants and bars 857,812 967,250 1,236,507 1,567,128 1,288,922 1,345,588 Fire, insurance and real estate 393,885 617,768 971,626 1,119,414 3,111,424 834,544 Hotels and other lodging 483,512 517,601 651,868 771,172 742,502 629,075 Services 570,815 664,411 733,605 712,776 559,951 561,321 All others 10,849 32,731 (5,079) 215,965 112,668 93,601 TOTAL $ 17,085,843 $ 19,445,864 $ 24,879,541 $ 34,166,649 $ 30,674,074 $ 28,410,261 (a) Due to the Town's participation in the Arizona Department of Revenue ("ADOR') sales tax collection program and ADOR's reporting of collections on a cash basis, the totals represented here differ from the amounts shown for Town Sales Tax Collections in TABLE 4. (b) The transaction privilege (sales) tax totals in this table do not include nonrecurring sales tax audit revenues resulting from audits performed on behalf of the Town. (c) These amounts are `forward looking" statements which may not be realized and should be considered with an abundance of caution. (d) The transaction privilege (sales) tax totals for fiscal year 2004/05 through and including fiscal year 2006/07 include the one-half cent dedicated sales taz which funded capital projects which was subsequently repealed in fiscal year 2006/07. (e) For the past five fiscal years, approximately 40-50% of the Town's transaction privilege (sales) tax collections were generated from "Construction. " Therefore, a decline in construction and related activity could result in a material decrease of the total transaction privilege (sales) tax collections of the Town. As has been widely reported, there has been a slow down in the single family housing sector area (including in the Town) over the past three years. See APPENDIX A - "TOWN OF MARANA, ARIZONA -GENERAL ECONOMIC AND DEMOGRAPHIC INFORMATION -Value of Building Permits" and "- New Housing Permits " as they relate to building permits and housing starts in the Town. Although the decrease in sales tax revenues from residential development slowdown has been largely offset by an increase in commercial development in the Town, the Town anticipates a continued residential slowdown and therefore projects an increase of approximately 4.7% over the amount budgeted jor fiscal year 2006/07. Any significant changes in development-related activity may significantly impact actual results. Source: Finance Department of the Town and Fiscal year 2007-08 Annual Budget and Financial Plan of the Town. State-Shared Revenues State-Shared Sales Taxes. Pursuant to a statutory formula, cities and towns in Arizona receive a portion of the State- levied sales taxes. As indicated in TABLE 3 -TAXABLE ACTIVITIES, TAX RATES AND DISTRIBUTION SHARE," the rate of taxation varies among the different types of business activities taxed, with the most common rate being 5.600% of the amount or volume of business transacted. The allocation to each city and town from the revenues available to all cities and towns is based on the respective city's or town's population relative to the aggregate population of all cities and towns in the State, as shown on the latest decennial or special census. State-shared Sales Taxes are collected by the State and distributed monthly to cities and towns. TABLE 3 TAXABLE ACTIVITIES, TAX RATES AND DISTRIBUTION SHARE Tax Distribution Business Activity Category Rate (a) Share Transportation and towing 5.000 20.00 Nonmetalliferous mining, oil and gas production 3.125 32.00 Utilities 5.000 20.00 Communications 5.000 20.00 Railroads and aircraft 5.000 20.00 Private car/pipelines 5.000 20.00 Publishing 5.000 20.00 Printing 5.000 20.00 Restaurants and bars 5.000 40.00 Amusements 5.000 40.00 Personal property rental 5.000 40.00 Contracting (b) 5.000 20.00 Retail (excluding food sales) 5.000 40.00 Mining severance 2.500 80.00 Timbering severance 0.000 0.00 Hotel/motel 5.500 50.00 Use and use inventory tax 5.000 0.00 Jet fuel (c) 40.00 Jet fuel use tax (c) 0.00 (a) On November 7, 2000, Arizona voters passed Proposition 301, which increased the state sales taz rate on certain of the categories of business activity from 5.000% to 5.600%. The additiona10.600% is being used to fund certain educational programs by the State. Such portion of the sales tax which is attributable to Proposition 301 will not be subject to distribution; therefore, the additional 0.600% is not reflected in this TABLE 3. (b) Most contract activity is at a 5.600% total tax rate but other classes at lower rates exist. (c) The amount of severance tax levied on a securer engaged in jet fuel or jet fuel use shall be $0.0305 per gallon. Source: Arizona Department of Revenue. State-Shared Income Taxes. Also, under current State law, Arizona cities and towns are preempted from imposing a local income tax. Cities and towns are, however, entitled by statutory formula to receive typically 15.0% of the net revenues of the State's personal and corporate income tax collections for the two fiscal years prior to the current fiscal year. Distribution of such funds is made monthly based on the proportion of each city's or town's population to the total population of all incorporated cities and towns in the State as determined by the latest census. In addressing State budgetary deficiencies, the Governor and members of the State Legislature have occasionally proposed certain adjustments that would reduce the distribution of State-shared Revenues to cities and towns. The Town cannot predict whether such measures will be proposed in the future, whether they will become law or how they might affect the town's receipt of State-shared Sales Taxes. See "POSSIBLE LEGISLATION OR INITIATIVE MEASURES" below. Licenses and Permits; Fines and Forfeitures The Town imposes a business license tax on the right to engage in business within the Town, an occupational license tax on certain occupations and various permit fees. The Town also imposes and collects fines and forfeitures for violation of State laws and Town ordinances relating to, among other things, traffic and parking offenses. Excise Tax Collections The following table sets forth a breakdown by source of the Excise Taxes for fiscal years 2002/03 through and including 2006/07 and budgeted for fiscal year 2007/08. See APPENDICES A and B for certain information with respect to the Town. Also, see APPENDIX C for excerpts from the most recent audited financial statements of the Town. TABLE 4 (a) HISTORICAL AND BUDGETED EXCISE TAX COLLECTIONS Audited Budgeted (b) Fiscal Year Fiscal Year Fiscal Year Fiscal Year Fiscal Year Fiscal Year Industry Classification 2002/03 2003/04 2004/05 (c) 2005/06 (c) 2006/07 (c) 2007/08 Town Sales Tax (d) $ 17,335,588 $ 20,058,983 $ 25,126,418 $ 34,166,649 $ 30,899,549 $ 28,635,996 (e) State-shared Sales Taxes 1,060,185 1,043,049 1,242,480 1,435,175 2,540,072 2,721,756 State-shared Income Taxes 1,442,781 1,222,336 1,246,196 1,419,305 3,034,241 3,763,935 (e) Licenses and permits 6,065,231 6,264,206 7,914,041 6,201,448 7,270,311 4,897,994 Fines and forfeitures and penalties 313,040 365,435 481,234 627,739 766,809 731,475 TOTAL $ 26,216,825 $ 28,954,009 $ 36,010,369 $ 43,850,316 $ 44,510,982 $ 40,751,156 (a) Prepared on a modified accrual basis. (b) These amounts are forward looking statements which may not be realized and should be considered with an abundance of caution. (c) The transaction privilege (sales) tax totals for fiscal year 2004/05 through and including fiscal year 2006/07 include the one-half cent dedicated sales tax which funded capital projects which was subsequently repealed in fiscal year 2006/07. (d) Neither the Town, the Corporation nor the Underwriter has made an independent determination of the financial position of any of the Town's sales taxpayers. The transaction privilege (sales) tax totals in this table include nonrecurring sales tax audit revenues resulting from audits performed on behalf of the Town. 10 (e) For the past five fiscal years, approximately 40-50% of the Town's transaction privilege (sales) tax collections were generated from "Construction. " Therefore, a decline in construction and related activity could result in the total transaction privilege (sales) tax collections of the Town to material decrease. As has been widely reported, there has been a slow down in the single family housing sector area (including in the Town) over the past three years. See APPENDIX A - "TOWN OF MARANA, ARIZONA -GENERAL ECONOMIC AND DEMOGRAPHIC INFORMATION -Value of Building Permits" and "- New Housing Permits " as they relate to building permits and housing starts in the Town. Although the decrease in sales tax revenues from residential development slowdown has been largely offset by an increase in commercial development in the Town, the Town anticipates a continued residential slowdown and therefore projects only an approximately 4.7% increase over the amount budgeted for fiscal year 2006/07. For fiscal year 2007/08, the reduction in licenses and permits reflects the Town's adjusted expectations regarding development- related activities. Source: Finance Department of the Town. POSSIBLE LEGISLATIVE OR INITIATIVE MEASURES From time to time, bills are introduced in, and legislation effected by, the Arizona Legislature to change the formula used to allot State-shared sales taxes and State-shared income taxes. (See as an example the second paragraph in the subheading "EXCISE TAXES -State-shared Revenues -- State-shared Income Taxes.") The possibility of changes in this respect are more likely to be adverse to the Town when the State is experiencing financial difficulties. The Town cannot determine whether any such measures will become law or how they might affect the revenues which comprise the Excise Taxes. In addition, initiative measures are circulated from time to time seeking to place on the ballot changes in Arizona law which repeal or modify State-shared sales taxes or State-shared income taxes. Further, initiative measures are circulated from time to time seeking to place on the ballot changes to the Town Code which would repeal or modify the Town's sales taxes. The Town cannot predict if any such initiative measures will ever actually be submitted to the electors, what form the measures might take or the outcome of any such election. Effective September 21, 2006, the State Legislature approved legislation that will gradually reduce the State personal income tax rate by ten percent (10%) over a two (2) year period. The corresponding reduction in State income tax revenues will decrease the available moneys that otherwise would have been available for State revenue sharing purposes, which is a component of the Town's Excise Taxes. To mitigate the impact on cities and towns in fiscal year 2008/09, the State Legislature adopted legislation that will appropriate money from the State's general fund in lieu of State income tax revenues in the respective amounts that individual cities and towns would have received from State revenue sharing prior to the tax rate reduction. After fiscal year 2008/09, cities and towns will return to sharing fifteen percent (15%) of personal and corporate income taxes collected by the State in the fiscal year two years preceding the then current fiscal year. 11 ESTIMATED DEBT SERVICE REQUIREMENTS AND COVERAGE* The following table sets forth the amounts required to pay semi-annual debt service on the Bonds, net of Bonds Being Refunded, the estimated debt service for the Series 2008 Bonds and the projected debt service coverage available with respect thereto from the Excise Taxes for the fiscal year ended as indicated. TABLE 5 (a) Fiscal Year 2006/07 Outstanding Bonds (b) The Series 2008 Bonds Combined Projected Maturity Net Pledged Estimated Debt Service Debt Service Dates Excise Taxes (c) Principal Interest Principal Interest Requirements Coverage (d) January 1, 2009 $ 44,510,982 $ 530,000 $ 589,279 $ 35,000 $ 906,925 (e) $ 2,061,204 4.63x July 1, 2009 430,000 580,164 906,225 1,916,389 4.31x January 1, 2010 435,000 573,539 110,000 906,225 2,024,764 4.SSx July 1, 2010 435,000 565,189 110,000 904,025 2,014,214 4.53x January 1, 2011 565,000 556,839 760,000 901,825 2,783,664 6.25x July 1, 2011 570,000 546,189 765,000 886,625 2,767,814 6.22x January 1, 2012 485,000 535,452 795,000 871,325 2,686,777 6.04x July 1, 2012 490,000 525,964 790,000 855,425 2,661,389 5.98x January 1, 2013 510,000 516,377 815,000 839,625 2,681,002 6.02x July 1, 2013 505,000 506,177 810,000 823,325 2,644,502 5.94x January 1, 2014 525,000 496,077 840,000 807,125 2,668,202 5.99x July 1, 2014 530,000 485,361 850,000 790,325 2,655,686 5.97x January 1, 2015 555,000 474,546 880,000 773,325 2,682,871 6.03x July 1, 2015 550,000 462,021 875,000 755,725 2,642,746 5.94x January 1, 2016 580,000 449,621 910,000 738,225 2,677,846 6.02x July 1, 2016 575,000 436,293 920,000 720,025 2,651,318 5.96x January 1, 2017 605,000 423,089 950,000 701,625 2,679,714 6.02x July 1, 2017 600,000 408,939 950,000 677,875 2,636,814 5.92x January 1, 2018 630,000 394,914 1,000,000 654,125 2,679,039 6.02x July 1,2018 635,000 380,189 1,000,000 629,125 2,644,314 5.94x January 1, 2019 655,000 365,339 1,055,000 604,125 2,679,464 6.02x July 1, 2019 665,000 349,761 1,050,000 577,750 2,642,511 5.94x January 1, 2020 690,000 333,943 1,105,000 551,500 2,680,443 6.02x July 1,2020 695,000 317,138 1,100,000 523,875 2,636,013 5.92x January 1, 2021 720,000 300,213 1,160,000 496,375 2,676,588 6.Olx July 1, 2021 735,000 281,894 1,160,000 467,375 2,644,269 5.94x January 1, 2022 765,000 263,194 1,220,000 438,375 2,686,569 6.04x July 1, 2022 765,000 243,725 1,220,000 407,875 2,636,600 5.92x January 1, 2023 800,000 224,263 1,105,000 377,375 2,506,638 5.63x July 1, 2023 805,000 203,906 1,110,000 349,750 2,468,656 S.SSx January 1, 2024 845,000 183,425 1,165,000 322,000 2,515,425 5.65x July 1, 2024 850,000 161,919 1,165,000 292,875 2,469,794 S.SSx January 1, 2025 885,000 140,294 1,220,000 263,750 2,509,044 5.64x July 1, 2025 895,000 117,775 1,225,000 233,250 2,471,025 S.SSx January 1, 2026 605,000 95,000 1,285,000 202,625 2,187,625 4.91x July 1, 2026 600,000 79,875 1,285,000 170,500 2,135,375 4.80x January 1, 2027 635,000 64,875 1,350,000 138,375 2,188,250 4.92x July 1, 2027 630,000 49,000 1,350,000 104,625 2,133,625 4.79x January 1, 2028 665,000 33,250 1,415,000 70,875 2,184,125 4.91x July 1, 2028 665,000 16,625 1,420,000 35,500 2,137,125 4.80x $ 25,310,000 $ 38,330,000 * Subject to change. 12 (a) Prepared by Stone & Youngberg LLC, the Underwriter. (b) Represents outstanding debt service on the Series 1997 Bonds, the Series 2003 Bonds and the Series 2004 Bonds, net of the Bonds Being Refunded. (c) The Excise Taxes shown for the fiscal year 2006/07 are figures based on data provided from the Town. See TABLE 4 - "HISTORICAL AND BUDGETED EXCISE TAX COLLECTIONS" herein. (d) Pursuant to the Town Leases, the Town covenants that the Excise Taxes presently imposed will be maintained so that the amount of the Excise Taxes for the next preceding fiscal year will be equal to at least two (2.0) times the rental payments payable under the Town Leases. (e) Interest is estimated at 4.75%. The ftrst interest payment on the Series 2008 Bonds will be due on January 1, 2009*. Thereafter, interest payments will be made semiannually on July 1 and January 1 until the stated maturity or prior redemption of the Series 2008 Bonds. * Subject to change. 13 TOWN GENERAL FUND Set forth on the following page is a record of Town general fund revenues, expenditures and changes in fund balance for the most recent five fiscal years. This information is not intended to indicate future or continuing trends in the financial affairs of the Town. The most recent audited financial statements for the Town are included in APPENDIX C attached hereto. It is possible that the Town may experience significant ending fund balance fluctuations in its general fund in future fiscal years. Pursuant to the Indentures the Series 2008 Bonds will be special obligations of the Corporation, and the debt service on the Series 2008 Bonds along with Bond Service Charges thereon shall be payable solely from the rental payments made pursuant to the Town Leases and not from any other revenues of the Town. TABLE 6 COMBINED STATEMENT OF REVENUES, EXPENDITURES, AND CHANGES IN GENERAL FUND BALANCE Budgeted (a) Audited 2007/08 2006/07 2005/06 2004/05 2003/04 2002/03 BEGINNING FUND BALANCE $ 19,247,857 $ 14,041,657 $ 13,139,757 $ 19,173,489 $ 16,867,493 $ 20,447,968 REVENUES Town sales tax $ 19,098,627 (b) $ 2Q,645,824 $ 18,533,882 $ 16,732,336 $ 20,058,983 $ 17,335,588 Intergovernmental 7,395,691 6,961,564 3,603,093 2,103,738 2,938,350 3,099,803 Licenses, fees and permits 4,947,994 (b) 4,865,395 6,201,448 7,914,041 6,264,206 6,065,231 Fines, forfeitures and penalties 654,275 676,838 573,242 465,586 365,435 313,040 Chazgesforservices 517,322 379,953 2(9,519 113,374 115,625 148,055 Lease income 493,300 19,500 497,800 438,050 442,266 456,249 Investment income 564,250 775,687 775,780 562,185 403,750 (322,078) Other 1,728,728 1,145,044 460,083 437,887 547,531 111,036 TOTAL REVENUES $ 35,400,187 $ 35,469,805 $ 30,864,847 $ 28,767,197 $ 31,136,146 $ 27,206,924 ADJUSTMENTS Transfers out $ (2,423,560) $ (2,355,161) $ (4,661,566) $ (14,416,341) $ (7,771,380) $ (14,342,236) Prior period adjustment 323,388 (3,015,842) TOTAL FUNDS AVAILABLE FOR EXPENDITURES $ 52,224,484 $ 47,156,301 $ 39,666,426 $ 33,524,345 $ 37,216,417 $ 33,312,656 EXPENDITURES Current - Generalgovernment $ 10,419,168 $ 7,515,954 $ 5,278,199 $ 5,625,638 $ 5,307,044 $ 3,959,510 Development and planning services 3,256,928 3,344,894 5,151,903 4,049,659 3,101,058 2,577,942 Town attorney (c) - - 426,647 364,674 207,771 353,703 Police 9,167,658 7,639,775 6,552,733 4,753,230 4,665,939 4,087,905 Magistrate court - - 704,136 556,927 480,160 44Q,564 Highways and streets 4,548,197 3,524,925 3,151,584 2,832,775 2,365,193 3,102,413 Culture and recreaction 3,512,014 2,893,751 2,573,820 2,044,822 1,705,112 1,672,913 Community development 429,841 243,516 - - - - Capital outlay 3,622,603 2,745,629 1,785,747 - - - Debt service - Principal retirement - - - 154,005 198,833 232,706 Interest and fiscal chazges 2,858 11,818 17,507 TOTAL EXPENDITURES $ 34,956,409 $ 27,908,444 $ 25,624,769 $ 20,384,588 $ 18,042,928 $ 16,445,163 ENDING FUND BALANCE $ 17,268,075 $ 19,247,857 $ 14,041,657 $ 13,139,757 $ 19,173,489 $ 16,867,493 (a) These amounts are `forward looking" and should be reviewed with an abundance of caution. (b) For the past five fiscal years, approximately 40-50% of the Town's transaction privilege (sales) tax collections were generated from "Construction. " Therefore, a decline in construction and related activity could result in the total transaction privilege (sales) tax collections of the Town to material decrease. As has been widely reported, there has been a slow down in the single family housing sector area (including in the Town) over the past three years. See APPENDIX A - "TOWN OF MARANA, ARIZONA -GENERAL ECONOMIC AND DEMOGRAPHIC INFORMATION -Value of Building Permits " and "- New Housing 14 Permits" as they relate to building permits and housing starts in the Town. Although the decrease in sales tax revenues from residential development slowdown has been largely offset by an increase in commercial development in the Town, the Town anticipates a continued residential slowdown and therefore projects only an approximately 4.7% increase over the amount budgeted for fiscal year 2006/07. For fiscal year 2007/08, the reduction in licenses and permits reflects the Town's adjusted expectations regarding development- related activities. (c) Beginning with ftscal year 2006/07, the functions of the Town Attorney and Magistrate Court have been consolidated as part of the General Government function, as per General Accounting and Financial Reporting standards. Source: The audited financial statements for each of the fiscal years ending as indicated above and the Finance Department of the Town. SOURCES AND USES OF FUNDS Sources Principal Amount of the Series 2008 Bonds Net Original Issue Discount/Premium Total Sources of Funds Uses Deposit Pursuant to Escrow Trust Agreement Deposit to the Series 2008 Acquisition and Construction Fund Deposit to Reserve Fund Deposit to Costs of Issuance Fund (a) Deposit to the Interest Fund $28,330,000.00* Total Uses of Funds $ * Subject to change. (a) Includes payment of underwriting compensation, municipal bond insurance premium, if any, and debt service reserve fund surety policy premium, if any. LITIGATION Certificates will be provided by authorized officials of the Corporation and the Town in connection with the delivery of the Series 2008 Bonds that, to the knowledge of such officials, no litigation or administrative action or proceeding is pending or threatened restraining or enjoining, or seeking to restrain or enjoin, the issuance and delivery of the Series 2008 Bonds, or the execution and delivery of the Series 2008 Town Lease or the Series 2008 Supplemental Indenture or contesting or questioning the proceedings and authority tinder which the Series 2008 Bonds have been authorized and are to be issued, sold, executed or delivered, or the validity of the Series 2008 Bonds. 15 TAX MATTERS The Internal Revenue Code of 1996, as amended (the "Code"), includes requirements which the Town and the Corporation must continue to meet with respect to the Series 2008 Bonds after the issuance thereof in order that interest on the Series 2008 Bonds not be included in gross income for federal income tax purposes. The failure by the Town or the Corporation to meet these requirements may cause interest on the Series 2008 Bonds to be included in gross income for federal income tax purposes retroactive to their date of issuance. The Town and the Corporation have covenanted in the Town Lease to take the actions required by the Code in order to maintain the exclusion from federal gross income of interest on the Series 2008 Bonds. In the opinion of Bond Counsel rendered with respect to the Series 2008 Bonds on the date of issuance of the Series 2008 Bonds, assuming continuing compliance by the Town and the Corporation with the tax covenants referred to above, under existing statutes, regulations, rulings and court decisions, interest on the Series 2008 Bonds will be excluded from gross income for federal income tax purposes. Interest on the Series 2008 Bonds will not be an item of tax preference for purposes of the federal alternative minimum tax imposed on individuals and corporations; however, interest on the Series 2008 Bonds will be taken into account in determining adjusted current earnings for purposes of computing the alternative minimum tax imposed on corporations. Bond Counsel is further of the opinion upon the date of issuance of the Series 2008 Bonds that, assuming interest on the Series 2008 Bonds will be so excludable from gross revenue for federal income tax purposes, interest thereon will be exempt from income taxation under the laws of the State. 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 the Series 2008 Bonds. Prospective purchasers of the Series 2008 Bonds should be aware that the ownership of the Series 2008 Bonds may result in other collateral federal tax consequences, including (i) the denial of a deduction for interest on indebtedness incurred or continued to purchase or carry the Series 2008 Bonds or, in the case of a financial institution, that portion of an owner's interest expense allocable to interest on a Series 2008 Bond; (ii) the reduction of the loss reserve deduction for property and casualty insurance companies by fifteen percent (15%) of certain items, including the interest on the Series 2008 Bonds; (iii) the inclusion of interest on the Series 2008 Bonds in the earnings of certain foreign corporations doing business in the United States for purposes of the branch profits tax; (iv) the inclusion of interest on the Series 2008 Bonds in passive investment income subject to federal income taxation of certain Subchapter S corporations with Subchapter C earnings and profits at the close of the taxable year; and (v) the inclusion in gross income of interest of the Series 2008 Bonds by recipients of certain Social Security and Railroad Retirement benefits. Bond Counsel's opinions are based on existing law, which is subject to change. Such opinions are further based on factual representations made to Bond Counsel as of the date thereof. Bond Counsel assumes no duty to update or supplement its opinions to reflect any facts or circumstances that may thereafter come to Bond Counsel's attention, or to reflect any changes in law that may thereafter occur or become effective. Moreover, Bond Counsel's opinions are not a guarantee of a particular result, and are not binding on the Internal Revenue Service or the courts; rather, such opinions represent Bond Counsel's professional judgment based on its review of existing law, and in reliance on the representations and covenants that it deems relevant to such opinion. ORIGINAL ISSUE DISCOUNT The initial offering prices of the Series 2008 Bonds maturing on January 1, 20_ through and including January 1, 20_ (referred to in this section as the "Discount Bonds") are less than the stated principal amounts. Under the Code, the difference between the principal of the Discount Bonds and the initial offering price to the public (excluding bond houses, brokers and similar persons or organizations acting in the capacity of underwriters or wholesalers), at which price a substantial amount of the Discount Bonds of the same maturity was sold, constitutes to an initial purchaser "original issue discount." Original issue discount represents interest that is excluded from gross income; however, such interest is taken into account for purposes of determining the alternative minimum tax imposed on corporations and may result in the collateral federal tax consequences described above under "TAX MATTERS." Original issue discount will accrue actuarially over the term of a Discount Bond at a constant interest 16 rate. A purchaser who acquires a Discount Bond in the initial offering to the public at an initial offering price thereof as set forth on the inside front cover page of this Official Statement will be treated as receiving an amount of interest excludable from gross income for federal income tax purposes equal to the original issue discount accruing during the period such purchaser holds such Discount Bond and will increase its adjusted basis in such Discount Bond by the amount of such accruing discount for purposes of determining taxable gain or loss on the sale or other disposition of such Discount Bond. The federal income tax consequences of the purchase, ownership and redemption, sale or other disposition of the Discount Bonds that are not purchased in the initial offering at the initial offering price may be determined according to rules that differ from those described above. Prospective purchasers of the Discount 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 the Discount Bonds and with respect to the state and local tax consequences of owning and disposing of the Discount Bonds. BOND PREMIUM The difference between the stated principal amounts of the Series 2008 Bonds maturing on January 1, 20_ through and including January 1, 20_ (referred to in this section as the "Premium Bonds"), 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 the Premium Bonds of the same maturity was sold constitutes to an initial purchaser amortizable "bond premium" that is not deductible from gross income for federal income tax purposes. The amount of amortizable bond premium for a taxable year is determined actuarially on a constant interest rate basis over the term of each Premium Bond. For purposes of determining gain or loss on the sale or other disposition of a Premium Bond, a purchaser who acquires such Premium Bond in the initial offering to the public at the initial offering price thereof as set forth on the inside front cover page of this Official Statement is required to decrease such purchaser's adjusted basis in such Premium Bond annually by the amount of amortizable bond premium for the taxable year. The amortization of bond premium may be taken into account as a reduction in the amount of tax-exempt income for purposes of determining various other tax consequences of owning the Premium Bonds. Prospective purchasers of the Premium Bonds should consult their own tax advisors with respect to the tax consequences of owning and disposing of the Premium Bonds. RATINGS Standard & Poor's Ratings Services, a division of The McGraw-Hill Companies, Inc. ("S&P") and Fitch Ratings Inc. ("Fitch") have assigned the ratings of "_" and "," respectively, to the Series 2008 Bonds with the understanding that the bond insurance policy will be issued by concurrently with the issuance of the Series 2008 Bonds. S&P and Fitch have also assigned the underlying ratings of " and "," respectively, to the Series 2008 Bonds. Such ratings will reflect only the view of S&P and Fitch. An explanation of the significance of the rating assigned by S&P may be obtained from S&P at 55 Water Street, New York, New York 10004. An explanation of a rating assigned by Fitch may be obtained from Fitch at One State Street Plaza, New York, New York 10004. Such ratings may be revised downward or withdrawn entirely by S&P and Fitch if, in their respective judgment, circumstances so warrant. Any downward revision or withdrawal of such rating may have an adverse effect on the market price of the Series 2008 Bonds. The Town has covenanted in its continuing disclosure undertaking that it will file notice of any formal change in any such rating relating to the Series 2008 Bonds. See "CONTINUING DISCLOUSURE." LEGAL MATTERS The Series 2008 Bonds are sold with the understanding that the Town and the Corporation will furnish the Underwriter with the approving opinion of Greenberg Traurig, LLP, Phoenix, Bond Counsel. The proposed form of such opinion is included in this Official Statement as APPENDIX E. Bond Counsel is to render such opinion upon the validity and enforceability of the Series 2008 Bonds under Arizona law and on the exclusion of the interest income on the Series 2008 Bonds from gross income for purposes of calculating federal income taxes and of the exemption of the interest income on the Series 2008 Bonds from State income taxes. (See "TAX MATTERS" 17 herein.) Fees of Bond Counsel, the Underwriter and Underwriter's counsel are contingent upon the delivery of the Series 2008 Bonds and Bond Counsel and Underwriter's counsel will be paid from proceeds of the sale of the Series 2008 Bonds. Bond Counsel will opine to the Underwriter upon certain information in the caption paragraph on the cover, in APPENDIX E and F under the headings "THE BONDS," "PLAN OF REFUNDING," "SECURITY AND SOURCE OF PAYMENT" "TAX MATTERS," "BOND PREMIUM" and "CONTINUING DISCLOSURE" (except with respect to the status of the Town's compliance with existing undertakings) but otherwise has not participated in the preparation of this Official Statement and will not opine upon its accuracy, completeness or sufficiency. Bond Counsel has not examined nor attempted to examine or verify any of the financial or statistical statements or data contained in this Official Statement and will also express no opinion with respect thereto. Certain legal matters will be passed upon solely for the benefit of the Underwriter by Squire, Sanders & Dempsey L.L.P., counsel to the Underwriter. The various legal opinions to be delivered concurrently with the delivery of the Series 2008 Bonds express the professional judgment of the attorneys rendering the opinions as to the legal issues explicitly addressed therein. By rendering a legal opinion, the opinion giver does not become an insurer or guarantor of that expression of professional judgment, of the transaction opined upon, or of the future performance of parties to the transaction. Nor does the rendering of an opinion guarantee the outcome of any legal dispute that may arise out of the transaction. UNDERWRITING The Series 2008 Bonds are being purchased for reoffering by Stone & Youngberg LLC (the "Underwriter"). The Underwriter has agreed to purchase the Series 2008 Bonds, subject to certain conditions, at a purchase price of $ ,plus accrued interest on the Series 2008 Bonds. If the Series 2008 Bonds are sold to produce the yields shown on the inside front cover page hereof, the Underwriter's compensation will be $ The Underwriter is committed to purchase all of the Series 2008 Bonds if any are purchased. The Series 2008 Bonds are offered for sale initially at the approximate yields set forth on the inside front cover page of this Official Statement, which yields may be changed from time to time by the Underwriter. The Series 2008 Bonds may be sold to certain dealers (including underwriters and dealers depositing the Series 2008 Bonds into investment trusts) at prices lower than the public offering price. POLITICAL CONTRIBUTIONS The Underwriter has not made political contributions to any person who sought a seat on the Town Council at its last election or, to the best of its knowledge, the election prior to the last election. RELATIONSHIP AMOUNG PARTIES Bond Counsel has and continues to represent the Underwriter with respect to financings other than for the Town and will continue to do so if requested in the future. Bond Counsel has also previously acted as bond counsel or special counsel with respect to other obligations underwritten by the Underwriter and will continue to do so if requested in the future. CONTINUING DISCLOSURE The Town will enter into a Continuing Disclosure Agreement (the "Undertaking") with respect to the Series 2008 Bonds for the benefit of beneficial owners of the Series 2008 Bonds to send certain information annually and to provide notice of certain events to certain information repositories pursuant to the requirements of Section (b)(5) of 18 Rule 15c2-12 (the "Rule") adopted by the Securities and Exchange Commission under the Securities Exchange Act of 1934. The specific nature of the information to be provided on an annual basis, the events which will be noticed on an occurrence basis and other terms of the Undertaking are set forth in APPENDIX F - "FORM OF CONTINUING DISCLOSURE AGREEMENT." A failure by the Town to comply with the Undertaking will not constitute a default under the Town Leases or the Indentures, and beneficial owners of the Series 2008 Bonds will be limited to the remedies described in the Undertaking. See APPENDIX F - "FORM OF CONTINUING DISCLOSURE AGREEMENT." A failure by the Town to comply with the Undertaking must be reported in accordance with the Rule and must be considered by any broker, dealer or municipal securities dealer before recommending the purchase or sale of the Series 2008 Bonds in the secondary market. Consequently, such a failure may adversely affect the transferability and liquidity of the Series 2008 Bonds and their market price. The Town failed to file the annual reports for the fiscal years ending June 30, 2003, 2004 and 2005 with the Nationally Recognized Municipal Securities Information Repositories ("NRMSIRs") by February 1 of each of the following years. Such reports were filed from one to two months late. Otherwise, the Town has been and is in material compliance with its prior continuing disclosure undertakings pursuant to the Rule. Absence of continuing disclosure due to a breach of any of such covenants could affect adversely the Series 2008 Bonds and specifically their market price and transferability. FINANCIAL STATEMENTS The annual financial statements of the Town for the fiscal year ended June 30, 2007, a copy of which are included in APPENDIX C - "TOWN OF MARANA, ARIZONA -AUDITED FINANCIAL STATEMENTS FOR THE FISCAL YEAR ENDED JUNE 30, 2007," have been audited by Heinfeld, Meech & Co., P.C., Certified Public Accountants, to the extent and for the period indicated in their report thereon. The Town has not requested the consent of Heinfeld, Meech & Co., P.C. to include their report and Heinfeld, Meech & Co., P.C. has performed no procedures subsequent to rendering their opinion on the financial statements. CERTIFICATION CONCERNING OFFICIAL STATEMENT The documents delivered in connection with the issuance of the Series 2008 Bonds will include a certificate to the affect that, to the knowledge of appropriate representatives of the Town after appropriate review, the statements contained in this Official Statement relating to the Town were at the time of the sale, and at the time of delivery of the Series 2008 Bonds, true, correct and complete in all material respects and were not misleading and did not omit matters which, in light of the circumstances under which they are made, would make such statements not misleading. 19 CONCLUDING STATEMENT To the extent that any statements made in this Official Statement involve matters of opinion or estimates, whether or not expressly stated to be such, they are made as such and not as representations of fact or certainty and no representation is made that any of these statements have been or will be realized. All financial and other information in this Official Statement has been derived from official records and other sources and is believed by the Town to be accurate and reliable. The presentation of information, including tables of receipts from taxes and other sources, is intended to show recent historic information, and is not intended to indicate future or continuing trends in the financial position or other affairs of the Town. No representation is made that past experience, as is shown by that financial and other information, will necessarily continue or be repeated in the future. TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION By: President 20 APPENDIX A TOWN OF MARANA, ARIZONA GENERAL ECONOMIC AND DEMOGRAPHIC INFORMATION General The Town is located one mile north of the border of City of Tucson, Arizona ("Tucson"), and just south of the northern border of Pima County, Arizona (the "County"). The Town encompasses an approximate area of 300 square miles and sits at an elevation of 2,055 feet above sea level. The Town was incorporated in 1977. TABLE 7 POPULATION STATISTICS Town of Pima State of Years Marana County Arizona 2007 Estimate (a) 32,274 1,003,235 6,500,194 2000 Census 13,556 843,746 5,130,632 1990 Census 2,187 666,880 3,665,305 1980 Census 1,674 531,443 2,718,425 1970 Census 1,154 351,667 1,775,399 (a) Estimate as ojJuly 2007. Source: Arizona Department of Economic Security, Population and Statistical Unit. Municipal Government and Organization The Town operates under the Council-Manager form of government. The Mayor and six council members are elected at large for staggered four-year terms. The Town Council appoints a Town Manager who has full responsibility for carrying out council policies and administering Town operations. Functions of government and operation are provided by a staff of approximately 365 full-time employees. The Town provides police services and water to its residents. Tucson Electric Power Corporation and Trico Electric Cooperative provide electricity to the Town's residents. Southwest Gas Corporation provides natural gas. Water is provided by the Town, as well as certain public and private providers. Sewer services are provided by the County. Telephone services are provided by Qwest Communications. Waste disposal and sanitation services are provided by various private disposal companies. Economy The economy of the Town and the area surrounding the Town has historically been dominated by agricultural activities. Though agriculture is still a large part of the economy, commercial, retail and industrial elements are becoming large contributors. The Town's agricultural elements include a variety of irrigated crops. The commercial elements of the economy have developed due to the growth of the Town and the growth of Tucson. The Town has become a retail trade center for suburban northern Tucson and the rural outlying areas surrounding the Town. Also, the Town's proximity between the City of Phoenix, Arizona, and Tucson has attracted business. Many residents commute from the Town to the Tucson metropolitan area for employment as well. A-1 The following table is a partial list of major employers within the Town. TABLE 8 MAJOR EMPLOYERS Town of Marana, Arizona Employer Marana Unified School District Army Reserve/National Guard Training Center Evergreen Air Center, Inc. Wal-Mart Town of Marana Costco Wholesale Sargent Controls & Aerospace Target Comcast Marana Health Center Arizona Portland Cement Coca-Cola FLSmidth Krebs Trico Electric Cooperative Inc. Asarco LLC CPC Southwest Materials Gallery Golf Club LLC Lowe's Home Depot Fry's Food & Drug Approximate Number of Description Employees Education 1,775 Government 635 Air center 605 Retail department store 450 Government 365 Retail warehouse 275 Aerospace manufacturing 250 Retail department store 225 Utilities services 200 Healthcare 195 Rock product manufacturing 190 Food and beverage distribution 180 Separation equipment manufacturing 125 Electric utility 120 Copper refining and smelting 115 Rock product manufacturing 105 Golf club 90 Retail home improvement [To come) Retail home improvement [To come/ Retail grocery (To come) Source: The Arizona Daily Star: Star 200, 2007 Arizona Industrial Directory and 2007 Arizona Services Directory, publications of Harris InfoSource, the Economic Development department of the Town and an individual employer survey. A-2 The following table illustrates unemployment averages for the Town, the County, the State and the United States. TABLE 8 UNEMPLOYMENT AVERAGES Calendar Town of Pima State of United States Year Marana County Arizona of America 2008 (a) 3.7% 4.1% 4.1% 5.0% 2007 3.4 3.7 3.8 4.6 2006 3.6 3.9 4.1 4.6 2005 4.1 4.4 4.6 5.1 2004 4.2 4.6 4.9 5.5 2003 4.8 5.3 5.7 6.0 (a) Data as of March 2008. Source: Arizona Department of Economic Security, Bureau of Statistical Information and Research Analysis, Labor Force Statistical Unit. Construction The following charts illustrate a building permit summary for residential and non-residential construction and new housing permits for the Town. TABLE 10 VALUE OF BUILDING PERMITS Town of Marana, Arizona ($OOOs omitted) Commercial Calendar and Year Residential Industrial Other Total 2007 (a) $ 99,474 $ 54,787 $ 6,978 $161,239 2006 158,867 35,322 17,325 211,514 2005 309,465 23,886 12,885 346,236 2004 219,336 14,005 8,888 242,229 2003 178,628 13,076 18,175 209,879 (a) Data incomplete -one or more months missing Source: Arizona Real Estate Center, Arizona State University Polytechnic campus. Note that the data is obtained from County and municipal divisions which issue such permits. Construction is valued on the basis of estimated cost, not on market price or value of construction at the time the permit is issued. The issuance of a building permit does not necessarily mean that construction will commence immediately or at all. A-3 TABLE 11 NEW SINGLE FAMILY HOUSING PERMITS Town of Marana, Arizona Calendar Total New Year Housing Permits 2007 (a) 528 2006 glg 2005 1,781 2004 1,403 2003 1,225 2002 528 (a) Data incomplete - one or more months missing. Source: Arizona Real Estate Center, Arizona State University Polytechnic campus. Note that data is obtained from County and municipal divisions which issue such permits. The issuance of a building permit does not necessarily mean that construction will commence immediately or at all. Commerce The Town is home to numerous retail establishments that accommodate the needs of the Town's growing population. See "EXCISE TAXES" in this Official Statement. TABLE 12 The following table illustrates the past five years of municipal privilege tax collections. MUNICIPAL PRIVILEGE TAX COLLECTIONS (a) Town of Marana, Arizona ($OOOs omitted) Fiscal Year Amount 2006/07 $30,674 2005/06 33,592 2004/05 24,879 2003/04 19,445 2002/03 17,086 (a) The municipal privilege tax collections fiscal years 2004/05 through and including ftscal year 2006/07 include the Town's one-half cent dedicated sales tax which funded capital projects which was subsequently repealed in fiscal year 2006/07. Source: Arizona Department of Revenue. A-4 Education Primary education in the Town is provided by 11 public elementary schools, two junior high schools and two high schools. Student achievement scores are consistently above county, state and national norms. Pima Community College and The University of Arizona offer undergraduate education and graduate programs. Transportation Industry, business and residents benefit from the transportation provided by Interstate 10, linking the Town with Tucson and the City of Phoenix, Arizona. The Marana Northwest Regional Airport and the Pinal Air Park each have two runways and are within close proximity to the Town. Residents have access to the Tucson International Airport located in Tucson for international, national, regional and local air service. Within Tucson are also passenger bus lines traveling national, regional and local routes. Tourism Many recreational opportunities are within an hour's drive of the Town. Picacho Peak State Park, site of Arizona's only Civil War battle, is 15 miles north. Its camping, picnic areas and nature trails are noted for colorful spring wildflowers. In the Santa Catalina Mountains is Catalina State Park, 20 miles east. Saguaro National Monument (west portion) is a few miles south. Within the monument is the world famous Arizona Sonora Desert Museum with native wildlife exhibits and Old Tucson Studios. Other attractions include Biosphere II, Kitt Peak, Pima Air Museum, and the San Xavier Mission. A-5 APPENDIX B TOWN OF MARANA, ARIZONA FINANCIAL DATA TABLE 13 Current Year Statistics (For Fiscal Year 2007/08) (a) Town of Marana, Arizona Total General Obligation Bonds Outstanding None Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds Outstanding and to be Outstanding $ 64,165,000 * (a) Improvement District Bonds Outstanding 25,774,000 Primary Assessed Valuation 357,767,607 (b) Secondary Assessed Valuation 413,365,306 (b) Estimated Net Full Cash Value 3,217,504,986 (c) The Town's preliminary fiscal year 2008/09 secondary assessed valuation is estimated at $528,295,440; its preliminary fiscal year 2008/09 primary assessed valuation is estimated at $434,729,840 and its preliminary fiscal year 2008/09 estimated net full cash value is estimated at $4,184,198,308. * Subject to change. (a) Includes the Bonds, net of the Bonds Being Refunded. (b) Arizona legislation divides property taxes into two categories, primary and secondary. Secondary property taxes are those taxes and assessments imposed to pay principal and interest on bonded indebtedness and certain other obligations, those imposed for special districts other than school districts and those imposed to exceed a budget, expenditure or tax limitation pursuant to voter approval. Primary property taxes are all ad valorem property taxes other than secondary property taxes. Annual increases in the valuation of certain types of property for primary property tax purposes and the amount of primary property taxes which may be levied in any year are subject to certain limitations. These limitations do not apply with respect to secondary property taxes. (c) Estimated full cash value is the total market value of the property less unsecured personal property and less estimated exempt property within the Town. Source: State and County Abstract of the Assessment Roll, Arizona Department of Revenue and Property Tax Rates and Assessed Values, Arizona Tax Research Foundation. STATEMENTS OF BONDED INDEBTEDNESS TABLE 14 Direct General Obligation Bonded Debt Outstanding Town of Marana, Arizona Total Direct General Obligation Bonded Debt Outstanding None B-1 TABLE 15 Municipal Facilities Revenue Bonds Outstanding and to be Outstanding Town of Marana Municipal Property Corporation Balance Bonds Outstanding Issue Original Maturity Balance Being and to be Series Amount Dates Outstanding Refunded* Outstanding 1997 $ 8,175,000 7-1-98/22 $ 3,625,000 $ (3,405,000) $ 220,000 2003 19,700,000 7-1-00/10 17,845,000 - 17,845,000 2004 8,675,000 7-1-05/28 7,770,000 - 7,770,000 Total Municipal Property Corporation Municipal Facilities Revenue Bonds Outstanding $ 25,835,000 Plus: The Series 2008 Bonds 38,330,000 Total Municipal Property Corporation Municipal Facilities Revenue Bonds Outstanding and to be Outstanding $ 64,165,000 * * Subject to change. TABLE 16 Improvement District Bonded Debt Outstanding (a) Town of Marana, Arizona Issue Original Maturity Balance Series Amount Description Dates Outstanding 2006 $ 25,774,000 Tangerine Farms Road 1/1/2026 $ 25,774,000 Total Improvement Bonds Outstanding $ 25,774,000 (a) Improvement district bonded debt is payable from special assessments levied on the property benefited by the ftnanced improvements. Such bonds are a contingent liability of the Town to the extent of any delinquent assessments. B-2 TABLE 16 Constitutional Direct Bonded Debt, Limitation and Unused Borrowing Capacity Town of Marana, Arizona The Arizona Constitution provides that the general obligation bonded indebtedness for a municipality for general municipal purposes may not exceed six percent of the secondary assessed valuation of the taxable property in that municipality. In addition to the six percent limitation for general municipal purpose bonds, municipalities may issue general obligation bonds up to an additional twenty percent of the secondary assessed valuation for supplying water, artificial light, or sewers, and for the acquisition and development of land for open space preserves, parks, playgrounds and recreational facilities and public safety, law enforcement, transportation and fire and emergency services facilities. General Municipal Purpose Bonds 6% Limitation $ 24,801,918 Water, Light, Sewer, Open Space, Park and Public Safety, Law Enforcement, Transportation and Fire and Emergency Services Facilities Bonds 20% Limitation Direct General Obligation Bonds Outstanding None Unused 6% Borrowing Capacity $ 24,801,918 B-3 Direct General Obligation Bonds Outstanding Unused 20% Borrowing Capacity $ 82,673,061 None $ 82,673,061 TABLE 17 Direct and Overlapping General Obligation Bonded Debt Town of Marana, Arizona Overlapping Jurisdiction State of Arizona Pima County (c) Pima County Community College District (d) Pima County Flood Control District Northwest Fire District Marana Unified School District No. 6 Flowing Wells Unified School District No. 8 Red Hawk Canyon Community Facilities District No. 1 (~ Red Hawk Canyon Community Facilities District No. 2 (~ Gladden Farms Community Facilities District Dove Mountain Community Facilities District (h) Town of Marana (i) Net Direct and Overlapping General Obligation Bonded Debt General Proportion Applicable Obligation to the Town (a) Bonded Approximate Net Debt Debt (b) Percent Amount None 0.58 % None $ 389,590,000 5.03 $ 19,596,377 51,155,000 5.03 2,573,097 1,470,000 5.58 82,026 26,575,000 41.48 11,023,310 61,085,000 55.08 33,645,618 9,590,000 100.00 18,786, 810 None 100.00 None None 100.00 None 7,780,000 100.00 7,780,000 None 100.00 None None 100.00 None $ 93,487,238 (a) Proportion applicable to the Town is computed on the ratio of secondary assessed valuation for the overlapping entity to the amount of such valuation which is within the Town in fiscal year 2007/08. (b) Includes total amount of general obligation bonds outstanding. Does not include presently authorized but unissued general obligation bonds of such jurisdictions shown in the following table which may be issued in the future. Additional bonds may be authorized by such entities pursuant to future elections. General Obligation Bonds Overlapping Jurisdiction Authorized but Unissued Pima County $378,681,000 Northwest Fire District 10,950,000 Gladden Farms Community Facilities District 60,570,000 Also does not include the obligation of the Central Arizona Water Conservation District ("CAWCD') to the United States Department of the Interior (the "Department of the Interior'), for repayment of capital costs for construction of the Central Arizona Project ("CAP'), a major reclamation project that has been substantially completed by the Department of the Interior. The obligation is evidenced by a master contract between CAWCD and the Department of the Interior. In April of 2003, the United States of America and CAWCD agreed to settle litigation over the amount of the construction cost repayment obligation, the amount of the respective obligations for payment of the operation, maintenance and replacement costs and the application of certain revenues and credits against such obligations and costs. Under the agreement, B-4 CAWCD's obligation for substantially all of the CAP features that have been constructed so far will beset at $1.646 billion, which amount assumes (but does not mandate) that the United States of America will acquire a total of 667, 724 acre feet of CAP water for federal purposes. The United States of America will complete unfinished CAP construction work related to the water supply system and regulatory storage stages of CAP at no additional cost to CAWCD. Of the $1.646 billion repayment obligation, 73% will be interest bearing and the remaining 27% will be non-interest bearing. These percentages will be fixed for the entire SO year repayment period, which commenced October 1, 1993. Effectiveness of the agreement is subject to a number of conditions including settlement of certain Indian community water claims and other water claims and will require certain Arizona legislation. Federal enabling legislation was passed in 2004. If the conditions are not met by May 9, 2012, and the parties do not amend the agreement, the agreement will terminate and litigation will resume. If it appears prior to May 9, 2012, that the conditions will not be met by the deadline, the parties can amend the agreement or either party may petition the United States District Court to terminate the agreement and resume litigation. CAWCD is a water conservation district having boundaries coterminous with the exterior boundaries of Arizona's Maricopa, Pima and Pinal Counties. It was formed for the express purpose of paying administrative costs and expenses of the CAP and to assist in the repayment to the United States of America of the CAP capital costs. Repayment will be made from a combination of power revenues, subcontract revenues (i.e., agreements with municipal, industrial and agricultural water users for delivery of CAP water) and a tax levy against all taxable property within CAWCD's boundaries. At the date of this Official Statement, the tax levy is limited to 14 cents per $100 of secondary assessed valuation, of which ten cents is being currently levied. (See Arizona Revised Statutes, Sections 45-3715 and 48-3715.02.) There can be no assurance that such levy limit will not be increased or removed at any time during the life of the contract. (c) Does not include certificates of participation outstanding in the aggregate principal amount of $53, 755, 000. Does not include street and highway user revenue bonds outstanding in the aggregate principal amount of $161,400,000. Does not include Pima County, Arizona sewer revenue bonds outstanding in the aggregate principal amount of $165,990, 667. (d) Does not include revenue bonds outstanding in the aggregate principal amount of $300, 000. (e) Does not include water revenue bonds and loans outstanding in the aggregate principal amount of $65, 075, 000. (n Does not include special assessment revenue bonds outstanding in the aggregate principal amount of $5, 075, 000. (~ Does not include special assessment revenue bonds outstanding in the aggregate principal amount of $4,230, 000. (h) Does not include special assessment lien bonds outstanding in the aggregate principal amount of $8,405,000. (i) Does not include municipal facilities revenue bonds to be outstanding in the aggregate principal amount of $64,165,000*. Does not include improvement bonds outstanding in the aggregate principal amount of $25,774,000 payable from special assessments on property within the Tangerine Farms Road Improvement District (the "Improvement District') and contingently payable, up to 20% of debt service, from an ad valorem property tax levy within the Improvement District. Source: The various entities. * Subject to change. B-5 TABLE 18 Direct and Overlapping General Obligation Bonded Debt Ratios Town of Marana, Arizona As % of As % of Per Capita Town's Town's Bonded Debt 2007/08 2007/08 Population Secondary Estimated Estimated Assessed Net Full at 32,274 (a) Valuation Cash Value Net Direct General Obligation Bonded Debt None None None Net Direct and Overlapping General Obligation Bonded Debt $2,896.67 22.62% 2.91% (a) Estimate provided by the Arizona Department of Economic Security, Population and Statistical Unit as of July 1, 2007. TABLE 19 Other Indebtedness Town of Marana, Arizona The Town has the following lease-purchase agreement outstanding. Item Payment [To be provided by Town) Source: The Town. RETIREMENT SYSTEM Retirement Benefits Periods Due Prior to July 1, 2007. The Town participated in a Money Purchase Plan and Trust known as the Town of Marana Retirement Plan (the "Plan") in the form of the International City Management Association Retirement Corporation Prototype Money Purchase Plan and Trust. The Plan is qualified under Section 401 of the Internal Revenue Code. The Plan is a defined contribution plan that provides pension benefits for all full-time employees and permanent part-time employees, except for commissioned police personnel who are covered under the Arizona Public Safety Personnel Retirement System (the "APSPRS"). In a defined contribution plan, benefits depend solely on amounts contributed to the plan plus investment earnings. Employees are eligible to participate from the date of employment. The Plan requires that the employee and the Town contribute an amount equal to 4% and 8%, respectively, of the employee's biweekly earnings, which includes overtime and bonuses. The Town's contributions for each employee (and interest allocated to the employee's account) are fully vested after five years of continuous service. Town contributions for, and interest forfeited by, employees who leave employment before five years of service are used to reduce the Town's current-period contribution requirement. B-6 The Town's total payroll in fiscal year 2006/07 was $15,214,958. The Town's contributions were calculated using the earnings amount of $10,579,181. For fisca12006/07, the covered employees made the required 4% contribution, amounting to $423,167, with the Town making a contribution of 8%, amounting to $846,334 for a total of $1,269,501. See Note 9 in APPENDLY C - "TOWN OF MARANA, ARIZONA -AUDITED ANNUAL FINANCIAL STATEMENTS FOR THE FISCAL YEAR ENDED JUNE 30, 2007" for further discussion of the Plan. Subsequent to July 1, 2007. The Town moved from the Plan and Trust to the Arizona State Retirement System (the "ASRS") defined benefit plan. ASRS administers acost-sharing multiple-employer defined benefit pension plan. The ASRS is governed by the Arizona State Retirement System Board according to the provisions of Arizona Revised Statute Title 38, Chapter 5, Article 2. Benefits are established by State statute and generally provide retirement, death, long-term disability, survivor and health insurance premium benefits. All regular employees not in the APSPRS, Correctional Officers Retirement System or Elected Officials Retirement System are eligible to participate. See Note 14 in APPENDD{ C - "TOWN OF MARANA, ARIZONA -AUDITED ANNUAL FINANCIAL STATEMENTS FOR THE FISCAL YEAR ENDED JUNE 30, 2007" for further discussion of the ASRS plan. All of the Town's full-time police officers are covered by the Marana Police Arizona Public Safety Personnel Retirement System, which is an agent/multiple-employer administered by the fund manager of the ASPRS, defined benefit public employee retirement system ("PERS"). These plans act as common investments and administrative agents to provide pension benefits, deferred allowances, death and disability benefits and limited health insurance benefits for public safety and corrections personnel who are regularly assigned hazardous duty in the employment of the State or a political subdivision thereof. All benefit provisions and other requirements are established by State statute. Covered employees are required to contribute 7.65% and 8.50% of their annual salary to the ASPSPRS. The Town is required to contribute the remaining amounts necessary to fund the ASPSPRS, as determined by the actuarial basis specified by statute. The current rate is 9.23% of annual covered payroll for ASPSPRS. Total contributions made during fiscal year 2006/07 were $692,833, of which $378,842 was made by the Town and $313,991 was made by police officers. The pension contributions represent funding for normal cost and the amortization of the unfunded actuarial accrued liability. Other Post-Employment Retirement Benefits Beginning with the fiscal year that commences on July 1, 2008, the Town was required to implement Government Accounting Standards Board Statement Number 45, Accounting by Employers for Post-Employment Benefits Other than Pensions ("GASB 45"), which requires reporting the actuarially accrued cost of post-employment benefits, other than pension benefits ("OPEB"), such as health and life insurance for current and future retirees. GASB 45 requires that such benefits be recognized as current costs over the working lifetime of employees, and to the extent such costs are not pre-funded, GASB 45 will require the reporting of such costs as a financial statement liability. The Town currently does not offer any OPEB. The Town's employees, their spouses and survivors may be eligible for certain retiree health care benefits under health care programs provided by the State. Employees on long-term disability and their spouses may also qualify for retiree health care benefits through the State. It is expected that substantially all of the Town's employees that reach normal or early retirement age while working for the Town will become eligible for such benefits. Currently such retirees may obtain the health care benefits offered by the State by paying 100% of the applicable health care insurance premium, net of any subsidy provided by the State. The benefits are available to all retired participants in the State's health care program. The Town does not currently make payments for OPEB costs for such retirees. The Town has learned that the State may commission an actuarial valuation of the OPEB costs associated with the health care benefits available to retirees through the State in order to meet the requirements of GASB 45. It is presently undetermined what impact, if any, such valuation may have on the Town's future financial reporting as required by GASB 45, or, because the health care programs are administered at the State level, whether there will be any financial reporting impact at the Town's level. B-7 TABLE 20 Secondary Assessed Valuation by Property Classification Town of Marana, Arizona For the last five years, a breakdown of the secondary assessed valuation by property classification for the Town is shown below: Class Commercial, Industrial, Utilities & Mines Agricultural and Vacant Residential (owner occupied) (a) Residential (rental) (a) Railroad Commercial Historical Property Certain Government Property Improvements 2007/08 2006/07 2005/06 2004/05 2003/04 Secondary Secondary Secondary Secondary Secondary Assessed Assessed Assessed Assessed Assessed Valuation Valuation Valuation Valuation Valuation $ 99,169,949 $ 88,596,806 $ 80,522,439 $ 74,941,704 $ 71,677,207 89,659,263 56,493,615 40,572,553 34,553,404 30,376,580 206,200,279 151,505,231 117,314,659 96,593,415 75,049,923 17,056,995 12,154,868 8,316,872 6,214,275 4,646,346 1,249,262 1,545,853 1,508,553 1,098,779 1,128,342 29,558 22,640 22,101 - _ - - - 18,434 - Totals* $413,365,306 $310,319,014 $248,257,176 $213,420,010 $182,878,398 * Totals may not add due to rounding. (a) As has been widely reported, there has been a slow down in the single family housing sector area (including in the Town) over the past three years. See APPENDIX A - "TOWN OF MARANA, ARIZONA -GENERAL ECONOMIC AND DEMOGRAPHIC INFORMATION -Value of Building Permits" and "- New Housing Permits " as they relate to building permits and housing starts in the Town. Source: State and County Abstract of the Assessment Roll, State of Arizona, Department of Revenue and Property Tax Rates and Assessed Values, Arizona Tax Research Foundation. TABLE 21 Estimated Net Full Cash Value History (a) Town of Marana, Arizona Estimated Fiscal Net Full Cash Years Value (a) 2006/07 $3,217,504,986 2005/06 2,345,384,859 2004/05 1,825,078,964 2003/04 1,556,111,117 2002/03 1,271,347,434 (a) Estimated full cash value is the total market value of the property less unsecured personal property and less estimated exempt property within the Town.Net full cash value is the total market value of the property within the Town less exempt property as provided by the Arizona Department of Revenue, Division of Properly and Special Taxes. Source: State and County Abstract of the Assessment Roll, State of Arizona, Department of Revenue. B-8 APPENDIX C TOWN OF MARANA, ARIZONA AUDITED ANNUAL FINANCIAL STATEMENTS FOR THE FISCAL YEAR ENDED JUNE 30, 2007 The following audited annual financial statements are for the fiscal year ended June 30, 2007. These are the most recent financial statements available to the Town. These financial statements are not current and may not represent the current financial condition of the Town. The Town has not requested the consent of Heinfeld, Meech & Co., P.C. to include their report and Heinfeld, Meech & Co., P.C. has performed no procedures subsequent to rendering their opinion on the financial statements. APPENDIX D SUMMARY OF CERTAIN PROVISIONS OF LEGAL DOCUMENTS DEFINITIONS OF CERTAIN TERMS The following are certain terms used in this Official Statement and the Indentures and not elsewhere defined in this Official Statement. "Additional Bonds "means bonds in addition to the Series 1997 Bonds, the Series 2003 Bonds, the Series 2004 and the Series 2008 Bonds which may be issued pursuant to the Indentures. "Annual Debt Service Requirements" means for any fiscal year the amount to be paid in such year with respect to the Bonds for payment of principal of (whether at maturity or because of mandatory redemption) and interest on the Bonds during such year. "Bondowner"shall have the same meaning as Owner herein. "Bond Retirement Fund" means the Bond Retirement Fund created in the Indentures. "Bond Service Charges "means, for any period of time, the principal of and interest and any premium due on the Bonds for that period or payable at that time, as the case may be. "Costs of Issuance" means all items of expense directly relating to the cost of issuing the Series 2008 Bonds. "Costs of Issuance Fund" means the Costs of Issuance Fund created in the Series 2008 Supplemental Indenture. "Defeasance Obligations "means: A. Cash B. U.S. Treasury Certificates, Notes and Bonds (including State and Local Government Series -- "SLGs") C. Direct obligations of the Treasury which have been stripped by the Treasury itself, CATS, TIGRS and similar securities D. Resolution Funding Corp. (REFCORP) Only the interest component of REFCORP strips which have been stripped by request to the Federal Reserve Bank of New York in book entry form are acceptable. E. Pre-refunded municipal bonds rated "Aaa" by Moody's and "AAA" by S&P. If, however, the issue is only rated by S&P (i.e., there is no Moody's rating), then the pre-refunded bonds must have been prerefunded with cash, direct U.S. or U.S. guaranteed obligations, or AAA rated pre-refunded municipals to satisfy this condition. F. Obligations issued by the following agencies which are backed by the full faith and credit of the U.S.: (1) U. S. Export-Import Bank (Eximbank] Direct obligations or fully-guaranteed certificates of beneficial ownership (2) Farmers Home Administration (FmHA~ Certificates of beneficial ownership (3) Federal Financing Bank (4) General Services Administration Participation Certificates D-1 (5) U.S. Maritime Administration Guaranteed Title XI financing (6) U.S. Department of Housing and Urban Development (HUD) Project Notes Local Authority Bonds New Communities Debentures - U.S. government guaranteed debentures U.S. Public Housing Notes and Bonds - U.S. government guaranteed public housing notes and bonds "Eligible Investments" 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, and CATS and TIGRS) or obligations the principal of and interest On which are unconditionally guaranteed by the United States of America. B. Bonds, debentures, notes or other evidence of indebtedness issued or guaranteed by any of the following federal agencies and provided such obligations are backed by the full faith and credit of the United States of America (stripped securities are only permitted if they have been stripped by the agency itself): 1. U.S. Export-Import Bank (Eximbank) Direct obligations or fully guaranteed certificates of beneficial ownership 2. Farmers Home Administration (FmIIA) Certificates of beneficial ownership 3. Federal Financing Bank 4. Federal Housing Administration Debentures (FHA) 5. General Services Administration Participation certificates 6. Government National Mortgage Association (GNMA or "Ginnie Mae") GNMA -guaranteed mortgage-backed bonds GNMA -guaranteed pass-through obligations (not acceptable for certain cash-flow sensitive issues) 7. U.S. Maritime Administration Guaranteed Title XI financing 8. U.S. Department of Housing and Urban Development (HUD) Project Notes Local Authority Bonds New Communities Debentures - U.S. government guaranteed debentures U.S. Public Housing Notes and Bonds - U.S. government guaranteed public housing notes and bonds C. Bonds, debentures, notes or other evidence of indebtedness issued or guaranteed by any of the following non-full faith and credit U.S. government agencies (stripped securities are only permitted if they have been stripped by the agency itself): Federal Home Loan Bank System Senior debt obligations 2. Federal Home Loan Mortgage Corporation (FHLMC or "Freddie Mac") D-2 Participation Certificates Senior debt obligations 3. Federal National Mortgage Association (FNMA or "Fannie Mae") Mortgage-backed securities and senior debt obligations 4. Student Loan Marketing Association (SLMA or "Sallie Mae") Senior debt obligations 5. Resolution Funding Corp. (REFCORP) obligations 6. Farm Credit System Consolidated systemwide bonds and notes D. Money market funds registered under the Federal Investment Company Act of 1940, whose shares are registered under the Federal Securities Act of 1933, and having a rating by S&P, of AAAm-G; AAA-m; or AA- m and if rated by Moody's rated Aaa, Aal or Aa2. E. Certificates of deposit secured at all times by collateral described in (A) and/or (B) above. Such certificates must be issued by commercial banks, savings and loan associations or mutual savings banks. The collateral must be held by a third part and the bondholders must have a perfected first security interest in the collateral. F. Certificates of deposit, savings accounts, deposit accounts or money market deposits which are fully insured by FDIC, including BIF and SAIF. G. Investment Agreements, including GIC's, acceptable to MBIA (refer to Investment Agreement criteria). H. Commercial paper rated, at the time of purchase, "Prime-1" by Moody's and "A-I" or better by S&P. I. Bonds or notes issued by any state or municipality which are rated by Moody's and S&P in one of the two highest rating categories assigned by such agencies. J. Federal funds or bankers acceptances with a maximum term of one year of any bank which has an unsecured, uninsured and unguaranteed obligation rating of "Prime-1" or "A3" or better by Moody's and "A-I" or "A" or better by S&P. K. Repurchase agreements provide for the transfer of Securities from a dealer bank or securities firm (seller/borrower) to a municipal entity (buyer/lender), and the transfer of cash from a municipal entity to the dealer bank or securities firm with an agreement that the dealer bank or securities firm will repay the cash plus a yield to the municipal entity in exchange for the securities at a specified date. Repurchase Agreements must satisfy the following criteria or be approved by MBIA. 1. Repos must be between the municipal entity and a dealer bank or securities firm a. Primary dealers on the Federal Reserve reporting dealer list which are rated A or better by S&P and Moody's, or b. Banks rated "A" or above by S&P and Moody's. 2. The written repo contract must include the following: a. Securities which are acceptable for transfer are: D-3 (1) Direct U.S. governments, or (2) Federal agencies backed by the full faith and credit of the U.S. government (and FNMA and FHLMC) b. The term of the repo may be up to 30 days c. The collateral must be delivered to the trustee (if Trustee is not supplying the collateral) or third party acting as agent for the Trustee (if the Trustee is supplying the collateral) before/simultaneous with payment (perfection by possession of certificated securities). d. Valuation of Collateral: (1) The securities must be valued weekly, marked-to market at current market price plus accrued interest (2) The value of collateral must be equal to 104% of the amount of cash transferred by the municipal entity to the dealer bank or security firm under the repo plus accrued interest. If the value of securities held as collateral slips below 104% of the value of the cash transferred by municipality, then additional cash and/or acceptable securities must be transferred. If, however, the securities used as collateral are FNMA or FHLMC, then the value of collateral must equal 105%. 3. Legal opinion which must be delivered to the municipal entity: a. Repo meets guidelines under State law for legal investment of public funds. L. Investments with the state treasurer in the pooled investment fund for the collective investment of public funds in the State authorized to be Created by Title 35, Chapter 2, Article 2, Section 35-326, Arizona Revised Statutes as amended. "Event of Bankruptcy" means the filing of a petition in bankruptcy by or against the specified Person under the United States Bankruptcy Code. "Interest Fund" means the Interest Fund created in the Indentures. "Maximum Annual Debt Service" means, at the time of computation, the greatest Annual Debt Service Requirement for the then-current or any succeeding fiscal year. "Moody's"means Moody's Investors Service. "Outstanding Bonds, " "Bonds outstanding" or "outstanding" as applied to the Bonds, means, as of the applicable date, all Bonds which have been authenticated and delivered, or which are being delivered by the Trustee under the Indentures, 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 Owners 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 Indentures; and (d) Bonds in lieu of which others have been authenticated under the Indentures. "Owner" or "Bondowner" or "Owner of a Bond" means the Person in whose name a Bond is registered on the Bond register. D-4 "Paying Agent" means the Trustee, until a successor Paying Agent shall have become such in accordance with the Indentures. "Person " or words importing persons mean 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. "Principal Payment Date" or "Principal Payment Dates" means, as to the Series 2008 Bonds, January 1 and July 1 in the years specified in the Series 2008 Supplemental Indenture for the stated amount of principal to be retired at maturity, or any other date on which the principal of the Series 2008 Bonds is payable as a result of redemption, optional or mandatory. "Qualified Surety Bond" means a surety bond issued by an insurance company rated in the highest rating category by Standard & Poor's Corporation, a division of The McGraw-Hill Companies, or Moody's Investors Service and if rated by A.M. Best & Company, rated in the highest rating category by A.M. Best & Company. "Registrar" means the Trustee, until a successor Registrar shall have become such pursuant to applicable provisions of the Indentures. "Record date" means, with respect to any Bond, the 15th day of the calendar month next preceding an Interest Payment Date applicable to that Bond. "Reserve Fund" means the Reserve Fund created pursuant to the Indentures. "Reserve Requirement" means as to the Series 2008 Bonds, the least of (i) an amount equal to 10% of the stated principal amount thereof, (ii) the Maximum Annual Debt Service for the Series 2008 Bonds for any fiscal year and (iii) 125% of the average Annual Debt Service for the Series 2008 Bonds for any fiscal year. The Reserve Requirement may be satisfied by cash, a Qualified Surety Bond, or a combination of these two. "Revenue Fund" means the Revenue Fund created pursuant to the Indentures. "Revenues" means (a) the rental payments due pursuant to the Town Leases, (b) all other moneys received or to be received by the Corporation or the Trustee in respect of the Town Leases, including without limitation, moneys and investments in the Bond Retirement Fund, and (c) all income and profit from the investment of the foregoing moneys. "Series 2008 Acquisition and Construction Fund" means the Acquisition and Construction Fund created in the Series 2008 Supplemental Indenture. "Series 2008 Costs of Acquisition and Construction " means all items of expense directly or indirectly relating to the cost of designing, acquiring, constructing and equipping the Project, including, but not limited to, the following: (a) Costs previously or hereafter incurred by the Corporation in connection with the designing, acquiring, constructing and equipping of the Projects. (b) Expenses incurred by the Town for labor, services, materials and supplies used or furnished in acquiring, constructing and equipping the Projects. (c) Fees paid by the Town for legal, design, architectural, engineering, construction management, consulting and supervisory services with respect to the Projects, including, without limitation, the cost of preparing or obtaining plans and specifications, working drawings, bids, appraisals, approvals, permits and inspections. (d) Expenses incurred by the Town in seeking to enforce any remedy against any contractor, subcontractor, materialman, vendor, supplier or surety in respect of any default under a contract relating to constructing and equipping the Projects. D-5 (e) Any sums required to reimburse the Town for advances made by it for any of the above items. "S&P"means Standard & Poor's Ratings Group, a division of The McGraw-Hill Companies, Inc. "Special Record Date" means, with respect to any Series 2008 Bond, the date established by the Trustee in connection with the payment of overdue interest on that Bond pursuant to the Indentures. "Supplemental Indentures" means the Series 2008 Supplemental Indenture and any other indenture supplemental to the Indentures entered into between the Corporation and the Trustee in accordance with the provisions of the Indentures. SUMMARY OF CERTAIN PROVISIONS OF THE SERIES 2008 TOWN LEASE The following, along with the information included under the heading "THE SERIES 2008 BONDS - Securiry and Sources of Payment, " is a summary of certain provisions of the Series 2008 Town Lease, to which reference is hereby made for a more complete description of its terms. General The Series 2008 Town Lease is between the Corporation, as lessor, and the Town, as lessee, and provides for the ground lease and leaseback or extension of lease of the Leased Property to the Town for a term commencing as of June 1, 2008* and continuing until July 1, 20_*, or such later date as of which the Series 2008 Bonds are deemed paid and discharged pursuant to the Indentures. The Series 2008 Town Lease may be terminated by the Town upon payment or provision for payment and discharge of all the Series 2008 Bonds. Rent As rental payments, the Town will pay to the Corporation the amounts necessary to permit the Corporation to make timely payment of the debt service on the Series 2008 Bonds, to restore the Reserve Fund to an amount equal to the Reserve Requirement with respect to the Series 2008 Bonds or, if the Series 2008 Agreement is in effect and the Series 2008 Insurer is not in default thereunder [???J, instead to pay amounts due pursuant to the Series 2008 Agreement with respect to the Series 2008 Debt Service Reserve Fund Surety Bond [???J and to pay all other amounts required to be paid by the Corporation to the Trustee pursuant to the Indentures with respect to the Series 2008 Bonds. Such rental payments will be paid directly to the Trustee for and on behalf of the Corporation. When the Series 2008 Bonds and other obligations pursuant to the Indentures have been fully paid or provided for, the Town will have no further obligation to make such payments pursuant to the Series 2008 Town Lease. The rental payments payable pursuant to the Series 2008 Town Lease will be an absolute net return to the Corporation, free from any expenses and charges with respect to the Leased Property or the income therefrom. Other Payments The Town will pay or cause to be paid punctually when due and payable all property taxes, income taxes, gross receipts taxes, business and occupation taxes, occupational license taxes, water charges, sewer charges, assessments (including, but not limited to assessments for public improvements or benefits) and all other governmental taxes and charges of every kind and nature which at any time prior to the expiration or termination of the Series 2008 Town Lease will be or become due and payable by the Corporation or the Town and which will be levied, charged, assessed or imposed: (i) upon or with respect to the Corporation, or which will be or become liens upon the Leased Property or any interest of the Corporation or the Town therein or under the Series 2008 Town Lease; * Subject to change. D-6 (ii) upon or with respect to the possession, operation, management, maintenance, alteration, repair, rebuilding, use or occupancy by the Town of the Leased Property, or any portion thereof; or (iii) upon any transaction or any document to which the Town is a party creating or transferring an interest or an estate in or to the Leased Property. The Town will furnish to the Corporation promptly, upon request, proof of the payment of any such tax, charge or assessment which is payable by the Town pursuant to the Series 2008 Town Lease. It will not be a breach of the Series 2008 Town Lease if the Town fails to pay any such tax, charge or assessment during any period or periods in which the Town, in good faith, or the Corporation, will be contesting the amount or validity of such tax, charge or assessment. The Corporation will, if requested by the Town, contest the amount or validity of any such tax, charge or assessment, and the Town will pay the costs of the Corporation therefor. The Town will pay, when due, all sums of money that may become due for or purporting to be for, any labor, services, materials, supplies or equipment alleged to have been furnished or to be furnished to or for the Town in, upon or about the Leased Property and which may be secured by any mechanics', materialmen's or other lien against the Leased Property or the interest of the Corporation therein, and will cause each such lien to be fully discharged and released at the time of performance of any obligation secured by any such lien as such obligation matures or becomes due, provided, however, that if the Town desires to contest any such lien the Town may do so, but notwithstanding any such contest, if any such lien shall be reduced to final judgment and such judgment or such process as may be issued for the enforcement thereof is not promptly stayed, or if so stayed and such stay thereafter expires, then and in any such event the Town will forthwith pay and discharge such judgment. The Town will pay or cause to be paid all charges for gas, water, steam, electricity, light, heat, power, telephone or other utility service furnished to or used in connection with the Leased Property. The Corporation will not be required to furnish to the Town any gas, water, sewer, electricity, light, heat, power, telephone or other utility service of any kind nor will the Corporation be required to pay for any such charges or services. The Town will, at its own cost and expense, during the term of the Series 2008 Town Lease, keep the Leased Property in good repair and condition, ordinary wear and tear excepted and will repair, renew or replace any portion of such improvements that shall have lost its usefulness due to damage, destruction, deterioration, or obsolescence. Failure of the Town to faithfully observe this covenant will constitute a breach of the Series 2008 Town Lease, and the Corporation will have reasonable rights of inspection for the purpose of determining the performance by the Town of the obligations of the Town pursuant to the Series 2008 Town Lease. The Town will cause the Leased Property to be insured against loss or damage by fire, explosion and other hazards customarily insured under extended coverage, in an amount not less than the full insurable value of such property, and maintain other insurance on the business and properties of the Town with respect to loss, damage, liability and other claims of the kind customarily insured against by similarly situated municipal corporations. All such insurance will be carried with financially sound and reputable insurance companies authorized to issue such policy or insure such risk in the State. Each policy will contain provisions, if available, that written notice of cancellation or substantial modification thereof will be given to the Corporation and the Trustee at least thirty (30) days, or the greatest available period shorter than thirty (30) days prior to such cancellation or modification. The Town may obtain blanket policies covering one or more risks of the minimum coverages required herein are met and all buildings located on the Leased Property are covered to their full insurable value. All the amounts payable pursuant to or with respect to the purposes of the foregoing paragraphs are payable from the same sources from which the rental payments are payable pursuant to the Series 2008 Town Lease. Remedies Upon Default Upon the nonpayment of the whole or any part of the rental payments when the same are to be paid or upon violation by the Town of any other covenant or provision of the Series 2008 Town Lease, and if such default has not been cured (i) in the case of nonpayment of rental payments due thereunder, within five (5) days, and (ii) in the case of the breach of any other covenant or provision thereof within thirty (30) days, after notice in writing from the Corporation specifying such default, then the Corporation may bring an action for the recovery of any of such rental D-7 payments due (but not for rental payments accruing) or for damages for breach and may pursue any other remedy which taw affords, except that the remedy of specific performance shall also be available. The Corporation, upon the bringing of a suit to collect the payments in default, may have a receiver appointed of the Excise Taxes, with such powers as the court making such appointment confers. (The Town consents irrevocably to such appointment pursuant to the Series 2008 Town Lease.) The Corporation will in no event be in default in the performance of any of the obligations of the Corporation pursuant to the Series 2008 Town Lease (other than the obligation to make the rental payments required thereby) unless the Corporation has failed to perform such obligations within thirty (30) days or such additional time as is reasonably required to correct any such default after notice by the Town to the Corporation and to the Trustee properly specifying wherein the Corporation has failed to perform any such obligation. So long as any of the Series 2008 Bonds are outstanding the Town will have no right to abate or offset the payments of rental payments to be made by the Town as a result of a default by the Corporation. In the event of default by the Corporation, the Corporation agrees that specific performance may be had and that the Town will not be limited to a remedy for damages. Except as expressly provided in the Series 2008 Town Lease, the Series 2008 Town Lease will not terminate or be affected in any manner by reason of the condemnation, destruction or damage, in whole or in part, or by reason of the unusability, commercial frustration of purpose or abandonment of, the Leased Property or the Project or failure to complete provision of the Project, and, except as expressly provided in the Series 2008 Town Lease, the rental payments will be absolute and unconditional, will not be subject to any defense, counterclaim or repayment and will be paid by the Town in accordance with the terms, covenants and conditions of the Series 2008 Town Lease without abatement, diminution or reduction. Refinancing, Refunding, Redemption and Purchase of Bonds Upon notice to the Corporation, the Town may request that the Corporation refinance or prepay, as the case may be, the Series 2008 Bonds by refinancing or prepaying the Series 2008 Bonds, subject to the provisions of the Indentures. The Corporation will use its best efforts to so refinance or prepay the Series 2008 Bonds. The Town will have the right to pay rental payments in advance and may specify that such payments be placed in the Bond Retirement Fund. In addition, if at any time the amount in the Revenue Fund exceeds, in the opinion of the Trustee, the amount necessary for the current debt service on the Series 1997 Bonds, the Series 2003 Bonds, the Series 2004 Bonds and the Series 2008 Bonds then outstanding and the fees, charges and expenses of the Trustee and the Registrars and Paying Agents pursuant to the Indentures, such excess will, at the request of the Town, be transferred to and paid over into the Bond Retirement Fund. At the request of the Town, the Corporation will cause the amount contained in the Bond Retirement' Fund from time to time to be used on any redemption date authorized in the Indentures to retire all or any portion of the Series 2008 Bonds, or if, before Series 2008 Bonds are subject to redemption, the Series 2008 Bonds may be obtained in the open market at a cost equal to or below par, or, after Series 2008 Bonds are subject to redemption, the Series 2008 Bonds may be so obtained at a price below the cost of redemption, then, upon the request of the Town, the Corporation will cause amounts contained in the Bond Retirement Fund to be used to purchase Series 2008 Bonds in the open market for the purpose of cancellation. At such time or times as Series 2008 Bonds are redeemed or purchased pursuant to the Series 2008 Town Lease, the rental payments to be paid by the Town will be adjusted in such manner as to provide for the debt service on the remaining Series 2008 Bonds. SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURES The following, along with the information included under the heading "THE SERIES 2008 BONDS" is a summary of certain provisions in the Indentures, to which reference is hereby made for a more complete description of its terms. D-8 Pledge and Assignment Pursuant to the Series 2008 Supplemental Indenture, the Corporation pledges and assigns to the Trustee alt its right, title and interest in and to the Series 2008 Town Lease and all payments to be made thereunder except for certain rights to payment of expenses, indemnification, reimbursement, receiving notices and giving and withholding consent. Such rights of the Corporation are assigned to the Trustee to secure the payment of the debt service on the Series 2008 Bonds. Establishment of Funds The following are established under the Indentures as separate deposit accounts (except when invested as hereinafter set forth) in the custody of the Trustee: (i) Revenue Fund, (ii) Interest Fund, (iii) Bond Retirement Fund, (iv) Reserve Fund, (v) Series 2008 Acquisition and Construction Fund and (vi) Costs of Issuance Fund. Receipt of Revenues The rental payments to be paid by the Town pursuant to the terms of the Series 2008 Town Lease are assigned by the Corporation to the Trustee so that such amounts will be paid by the Town directly to the Trustee, and the Trustee will credit such amounts to the Revenue Fund. If at any time the amounts in the Revenue Fund exceed, in the sole opinion of the Trustee, the amount necessary for the current debt service on all Bonds then outstanding, including administration costs and expenses, and the Town is not then in default under the Town Leases such excess will constitute a credit to the Town on the next succeeding installments of amount due or to become due under the Town Leases, provided, however, that the Town may exercise its prepayment rights under the Town Leases, in which event such excess funds will be transferred to and paid over into the Bond Retirement Fund. The aforesaid credit or transfer will be made by the Trustee no less frequently than annually. Flow of Funds Revenue Fund. The Trustee will transfer from the Revenue Fund the following amounts at the time and in the manner hereinafter provided, applying amounts in the Revenue Fund to the setting aside of money for the foregoing funds to the extent available in the following order or priority, to-wit: (1) Interest Fund: On each Interest Payment Date, the Trustee shall deposit in the Interest Fund an amount equal to the amount of the interest becoming due and payable on the outstanding Bonds on the next Interest Payment Date, and each such deposit shall be made so that adequate moneys for the payment of interest will be available in such fund on each date that interest payments are to be made under the Indentures. Money in the Interest Fund shall be used and withdrawn by the Trustee solely for the purpose of paying the interest on the Bonds as it shall become due and payable. (2) Bond Retirement Fund: On each Principal Payment Date, the Trustee shall deposit in the Bond Retirement Fund solely for the purpose of paying the principal of the Bonds as each amount shall become due and payable, on or before the dates when such amounts will become due and payable, the amounts due to mature on such date whether because of stated maturity or mandatory redemption. (3) Reserve Fund: Monthly, commencing on the 1st day of the month following a payment made from the Reserve Fund with respect to the Series 2008 Bonds, the Trustee will, to the extent of legally available funds therefor, deposit into the Reserve Fund as hereafter described an amount equal to the amount required to restore the Reserve Fund to an amount equal to the Reserve Requirement for the Series 2008 Bonds. No deposit need be made into the Reserve Fund with respect to the Series 2008 Bonds if the amount of money and the amount available pursuant to the Series 2008 Debt Service Reserve Fund Surety Bond contained therein is at least equal to an amount equal to the Reserve Requirement for the Series 2008 Bonds. If and to the extent that money has also been deposited in the Reserve Fund, all such money shall be used (or investments purchased with such money shall be liquidated and the proceeds applied as required) prior to any drawing under a Qualified Surety Bond. If and to the extent that more than one Qualified Surety Bond is credited to the Reserve Fund in lieu of money, drawings under such Qualified Surety Bonds (and repayment or reimbursement of amounts with respect to such Qualified Surety Bonds as hereinafter described) shall be made on a pro rata basis (calculated by reference to the policy limits or D-9 maximum amounts available thereunder) after applying all available cash in the Reserve Fund. Except for the hereinafter described withdrawals, amounts in the Reserve Fund will be used and withdrawn solely for the purpose of paying the interest on or principal of the Series 2008 Bonds in the event that no other money of the Corporation is available therefor or for the retirement of all the Bonds then outstanding. In the event that there is insufficient money in the Reserve Fund available for the payment of the principal of and interest on the Series 2008 Bonds, then in that event the Trustee is authorized and directed to deliver to the Series 2008 Insurer, at least three (3) days prior to the date on which the funds are required, a Series 2008 Demand For Payment in order to effect payment of the principal of and interest on the Series 2008 Bonds pursuant to the terms of the Series 2008 Debt Service Reserve Fund Surety Bond. If on July 15 of any year the amount in the Reserve Fund exceeds an amount equal to the Reserve Requirement for the Series 2008 Bonds and if the Corporation is not then in default under the Indentures, the Trustee will withdraw the amount of any such excess from such fund and will apply such amount, first and on a pro rata basis, to pay amounts due with respect to any Qualified Surety Bond, including by paying the applicable pro rata amount to reimburse the Series 2008 Insurer for any payments made by the Series 2008 Insurer under the Series 2008 Debt Service Reserve Fund Surety Bond until the Series 2008 Surety Bond Coverage equals the Series 2008 Surety Bond Limit, and second, as a deposit to the Revenue Fund. Application of Bond Proceeds The Corporation will deposit with the Trustee all of the proceeds of the sale of the Series 2008 Bonds and upon receipt of such proceeds and after depositing amounts necessary pursuant to the Escrow Trust Agreement to refund the Bonds Being Refunded the Trustee will: (a) deposit to the credit of the Interest Fund the accrued interest on the Series 2008 Bonds from their date to the date of their delivery to the Original Purchaser plus an amount of capitalized interest; (b) deposit to the credit of the Costs of Issuance Fund an amount sufficient to pay the Costs of Issuance and (c) deposit to the credit of the Series 2008 Acquisition and Construction Fund the balance of the proceeds of the sale of the Series 2008 Bonds. See "SOURCES AND USES OF FUNDS." Disbursements from Acquisition and Construction Fund and Costs of Issuance Fund The Trustee will hold the amounts in the Series 2008 Acquisition and Construction Fund for the benefit of the Corporation to be used to pay the Series 2008 Costs of Acquisition and Construction and amounts in the Costs of Issuance Fund for the benefit of the Corporation to be used to pay the Costs of Issuance, in each case upon the written requisition of the Town. Investment of Funds Substantially all money in any of the funds established by the Trustee will be invested and reinvested by the Trustee, at the direction of the Town, so long as the Town is not in default under the Town Leases, in Eligible Investments. Such investments will mature or be redeemable at the option of the Trustee at the times and in the amounts necessary to provide moneys to pay Bond Service Charges as they become due. Any losses on such investments are to be made up by the Town to the extent necessary to meet the Bond Service Charges and to pay the Trustee's and any Paying Agent's fees and expenses; and any money paid to the Trustee by the Town for such purpose will be deposited in the fund or funds with respect to which, and to the extent that, such losses were incurred. Additional Bonds The Corporation may establish one or more issues of Additional Bonds on a parity with the Bonds and may issue and deliver such Additional Bonds, in such principal amount as may be determined by the Corporation, subject to the following specific conditions which are made conditions precedent to the issuance of such Additional Bonds: (a) such Additional Bonds shall have been authorized to finance or refinance the cost of acquiring, constructing, reconstructing or improving buildings, equipment and other real and personal properties suitable for use by and for leasing to the Town or its agencies or instrumentalities, or for refinancing or advance refunding of Bonds and the issuance thereof shall have been determined and declared by the Corporation, by appropriate resolution, to be necessary for that purpose; D-10 (b) the Corporation shall be in compliance with all covenants and undertakings set forth in the Town Leases and in the Indentures, as either or both may have been supplemented; (c) the resolution authorizing issuance of such Additional Bonds requires that the proceeds of the sale of such Additional Bonds shall be applied solely for one or more of the purposes set forth in (a) above and expenses and costs incidental thereto, including costs and expenses incident to the issuance and sale of such Additional Bonds and the costs of any premium relating to insurance on the Additional Bonds or on any debt service reserve fund therefor, and, if desired, a reasonable debt service reserve fund for the protection of the owners of the Additional Bonds and interest on said Additional Bonds during the actual period of any acquisition and construction of such facilities, and for a period of not to exceed six (6) months thereafter; (d) such Additional Bonds shall be equally and ratably secured with the Series 1997 Bonds, the Series 2003 Bonds, the Series 2004 Bonds and the Series 2008 Bonds, without preference or priority of any of the Bonds over any other Bonds, except as expressly provided in the Indentures, as supplemented; (e) the Corporation shall have entered into a revised agreement with the Town, or shall have amended the Base Town Lease, in and by which the Town obligates itself in the manner therein provided to increase the payments or to make such payments to the Corporation at the times and in amounts sufficient to provide for the payment of principal and interest on such Additional Bonds as such principal and interest become due and (f) the Excise Taxes collected in the next preceding fiscal year shall have amounted to at least three (3.0) times the highest combined interest and principal requirements for any succeeding twelve (12) months' period for all of the Bonds then outstanding and any obligations issued on parity of lien therewith as provided in the Town Leases which may include any Additional Bonds so proposed to be secured by a pledge of the Excise Taxes. Events of Default and Remedies The following events constitute events of default under the Indentures: (a) Payment of any interest on any Bond shall not be made when and as that interest shall become due and payable; (b) Payment of the principal of or any premium on any Bond shall not be made when and as that principal or premium shall become due and payable, whether at stated maturity, by redemption, or otherwise; (c) Failure by the Corporation to observe or perform any other covenant, agreement or obligation on its part to be observed or performed contained in the Indentures or in the Bonds, which failure shall have continued for a period of sixty (60) days after written notice of such failure, by registered or certified mail, shall have been given to the Corporation and the Town, 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 Owners of not less than twenty-five (25%) in aggregate principal amount of any series of Bonds then outstanding; (d) The occurrence and continuance of any.default as defined in the Series 2008 Town Lease or the Series 2008 Agreement, and (e) The occurrence of an Event of Bankruptcy as to the Corporation or the Corporation shall: (i) commence a proceeding under any federal or state 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 or (ii) have a receiver, conservator, liquidator or trustee appointed for it or for the whole or any substantial part of its property. (The declaration of an event of default under the Indentures and the exercise of remedies upon any such declaration shall be subject to any applicable limitations of federal or State law affecting or precluding such declaration or exercise during the pendency of or immediately following any liquidation or reorganization proceedings.) The Trustee, on the occurrence and continuance of any Event of Default, may, and upon the written request of the Owners of at least twenty-five (25%) in principal amount of each series of the Bonds outstanding shall, D-11 exercise any available remedies to enforce the payment of Bond Service Charges or the observance and performance of any other covenant, agreement or obligation under the Indentures, the Town Leases or any other instrument providing security, directly or indirectly, for the Bonds. Anything to the contrary in the Indentures notwithstanding, the Owners of a majority in aggregate principal amount of each series of the Bonds then outstanding will have the right at any time to direct, by an instrument or document or instruments or documents in writing executed and delivered to the Trustee, the method and place of conducting all proceedings to be taken in connection with the enforcement of the terms and conditions of the Indentures or any other proceedings thereunder: provided, that (i) any direction shall not be other than in accordance with the provisions of law and of the Indentures, (ii) the Trustee will be indemnified as provided in the Indentures and (iii) the Trustee may take any other action which it deems to be proper and which is not inconsistent with the direction. An Owner will not have any right to institute any suit, action or proceeding for the enforcement of the Indentures, for the execution of any trust thereof or for the exercise of any other remedy thereunder, unless: (i) there has occurred and is continuing an event of default of which the Trustee has been notified, as provided in the Indentures or of which it is deemed to have notice thereunder; (ii) the Owners of at least 25% in aggregate principal amount of a series of Bonds then outstanding shall have made written request to the Trustee and shall have afforded the Trustee reasonable opportunity to proceed to exercise the remedies, rights and power granted in the Indentures or to institute the suit, action or proceeding in its own name, and shall have offered indemnity to the Trustee as provided in the Indentures and (iii) the Trustee thereafter shall have failed or refused to exercise the remedies, rights and powers granted in the Indentures or to institute the suit, action or proceeding in its own name. At the option of the Trustee, that notification (or notice), request, opportunity and offer of indemnity are conditions precedent, in every case, to the institution of any suit, action or proceeding described above. No one or more Owners of the Bonds will have any right to affect, disturb or prejudice in any manner whatsoever the security or benefit of the Indentures by its or their action or to enforce, except in the manner provided in the Indentures, any remedy, right or power pursuant to the Indentures. Any suit, action or proceedings will be instituted, had and maintained in the manner provided in the Indentures for the benefit of the Owners of all Bonds then outstanding. Nothing in the Indentures will affect or impair, however, the right of any Owner to enforce the payment of the Bond Service Charges on any Bond owned by that Owner at and after the maturity thereof, at the place, from the sources and in the manner expressed in that Bond. Application of Moneys After payment of any costs of collection, any moneys received by the Trustee pursuant to any right given or action taken under the Indentures or the Town Leases will be applied by the Trustee as follows: First - to the payment to the Owners entitled thereto of all installments of interest then due on the Bonds, in the order of the dates of maturity of the installments of that interest, beginning with the earliest date of maturity and, if the amount available is not sufficient to pay in full any particular installment, then to the payment thereof ratably, according to the amounts due on that installment, to the Owners entitled thereto, without any discrimination or privilege, except as to any difference in the respective rates of interest specified in the Bonds; and Second - to the payment to the Owners entitled thereto of the unpaid principal of any of the Bonds which shall have become due (other than Bonds previously called for redemption for the payment of which moneys are held pursuant to the provisions of the Indentures), whether at stated maturity, by redemption or pursuant to any mandatory sinking fund 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 became due at the rates specified in those Bonds, and if the amount available is not sufficient to pay in full all Bonds due on any particular date, together with that D-12 interest, then to the payment thereof ratably, according to the amounts of principal due on that date, to the Owners entitled thereto, without any discrimination or privilege, except as to any difference in the respective rates of interest specified in the Bonds. Whenever moneys are to be applied pursuant to the provisions of the Indentures, those moneys will be applied at such times, and from time to time, as the Trustee will 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 will fix the date upon which the application is to be made, and upon that date, interest will cease to accrue on the amounts of principal, if any, to be paid on that date, provided the moneys are available therefor. The Trustee will give notice of the deposit with it of any moneys and of the fixing of that date, all consistent with the requirements of the Indentures for the establishment of, and for giving notice with respect to, a Special Record Date for the payment of overdue interest. The Trustee will not be required to make payment of principal of and any premium on a Bond to the Owner thereof until the Bond shall be presented to the Trustee for appropriate endorsement or for cancellation if it is paid fully. Termination of Proceedings In case the Trustee will have proceeded to enforce any remedy, right or power under the Indentures in any suit, action or proceedings and the suit, action or proceedings will have been discontinued or abandoned for any reason or will have been determined adversely to the Trustee, the Corporation, the Trustee and the Owners will be restored to their former positions and rights under the Indentures, respectively, and all rights, remedies and powers of the Trustee will continue as if no suit, action or proceedings had been taken. Waivers of Events of Default Except as hereinafter provided, at any time, in its discretion, the Trustee may waive any event of default pursuant to the Indentures and its consequences. The Trustee will do so upon the written request of the Owners of: (i) at least a majority in aggregate principal amount of all Bonds then outstanding in respect of which an Event of Default in the payment of Bond Service Charges exists or (ii) at least 25% in aggregate principal amount of each series of Bonds then outstanding in the case of any other event of default. There shall not be so waived, however, any Event of Default described in paragraphs (a), (b) or (e) under the heading "Events of Default and Remedies." In the case of the waiver or in case any suit, action or proceedings taken by the Trustee on account of any event or default has been discontinued, abandoned or determined adversely to it, the Corporation, the Trustee, and the Owners will be restored to their former positions and rights under the Indentures, respectively. No waiver will extend to any subsequent or other event of default or impair any right consequent thereon. Trustee Before taking certain actions pursuant to the Indentures, the Trustee may require that a satisfactory indemnity bond or other assurances be furnished to it for the reimbursement of all expenses which it may incur and to protect it against all liability (including, without limitation, any and all environmental liability) by reason of any action so taken, except liability which is adjudicated to have resulted from its gross negligence or willful misconduct Such other assurances may include evidence satisfactory to the trustee that it will not incur liability by reason of any action taken pursuant to the Indentures. Unless otherwise provided, all moneys received by the Trustee under the Indentures will be held in trust for the purposes for which those moneys were received, until those moneys are used, applied or invested; provided, that those moneys need not be segregated from other moneys, except to the extent required by the Indentures or by law. The Trustee may intervene on behalf of the Owners, and shall intervene if requested to do so in writing by the Owners of at least twenty-five percent (25%) of the aggregate principal amount of a series of Bonds then outstanding, in any judicial proceeding to which the Corporation or the Town is a party and which in the opinion of D-13 the Trustee and its counsel has a substantial bearing on the interests of Owners of the Bonds. The rights and obligations of the Trustee are 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 the Indentures before it takes action thereunder. The Trustee may resign at any time by giving written notice of the resignation to the Corporation, the Town, the Registrar, any Paying Agents and the original purchaser of each series of Bonds then outstanding, by mailing written notice of the resignation to such parties and to the Owners as their names and addresses appear on the register for the Bonds at the close of business fifteen (15) days prior to the mailing. The resignation shall take effect upon the appointment of a successor Trustee. The Trustee may be removed at any time by an instrument or document or concurrent instruments or documents in writing delivered to the Trustee, with copies thereof mailed to the Corporation, the Registrar and any Paying Agents, and signed by or on behalf of the Owners of not less than a majority in aggregate principal amount of the Bonds then outstanding. The Trustee also 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 provision of the Indentures with respect to the duties and obligations of the Trustee by a court of competent jurisdiction upon the application of the Corporation or the Owners of not less than twenty percent (20%) in aggregate principal amount of the Bonds then outstanding under the Indentures. If the Trustee resigns, is removed, is dissolved or becomes otherwise incapable of acting, the Trustee is taken under control of any public officer or officers, or a receiver is appointed for the Trustee by a court, then a successor Trustee will be appointed by the Corporation; provided, that if a successor Trustee is not so appointed within ten (10) days after a notice of resignation or an instrument or document of removal is received by the Corporation, or the Trustee is dissolved, taken under control, becomes otherwise incapable of acting or a receiver is appointed, in each case, as provided above, then, so long as the Corporation has not appointed a successor Trustee, the Owners of a majority in aggregate principal amount of each series of Bonds then outstanding may designate a successor Trustee by an instrument or document or concurrent instruments or documents in writing signed by or on behalf of those Owners. If no appointment of a successor Trustee is made pursuant to the foregoing provisions, the Owner of any Bond outstanding or any retiring Trustee may apply to any court of competent jurisdiction to appoint a successor Trustee. Such court may thereupon, after such notice, if any, as such court may deem proper and prescribe, appoint a successor Trustee. Every successor Trustee (i) must be a trust company or a bank having the powers of a trust company, (ii) must be in good standing within the State, (iii) must be duly authorized to exercise trust powers within the State, (iv) must have a reported capital and surplus of not less than $75,000,000, (v) must be willing to accept the trusteeship under the terms and conditions of the Indentures, and (vi) must be acceptable to the insurer of the Series 1997 Bonds, the insurer of the Series 2003 Bonds, the insurer of the Series 2004 Bonds and the Series 2008 Insurer. Every successor Trustee appointed must execute and acknowledge, and will deliver to its predecessor and the Corporation, an instrument in writing accepting the appointment. Thereupon, without any further act, the successor will become vested with all of the trusts, properties, remedies, powers, rights, duties, obligations, discretions, privileges, claims, demands, causes of action, immunities, estates, titles, interests and liens of its predecessor. Upon the written request of its successor or the Corporation, the predecessor Trustee (i) will execute and deliver an instrument or document transferring to its successor all of the trusts, properties, remedies, powers, rights, duties, obligations, discretions, privileges, claims, demands, cause of action, immunities, estates, titles, interests and liens of the predecessor Trustee and (ii) will take any other action necessary to duly assign, transfer and deliver to its successor all property (including without limitation, all securities and moneys) held by it as Trustee. Notwithstanding the foregoing, the predecessor Trustee will not be required to transfer to its successor any rights of indemnity to the predecessor Trustee for acts during the time the predecessor Trustee was acting as Trustee under the Indentures. Should any instrument or document in writing from the Corporation be requested by any successor Trustee for vesting and conveying more fully and certainly in and to that successor the trusts, properties, remedies, rights, duties, obligations, discretions, privileges, claims, demands, causes of action, immunities, estates, titles, interests and liens vested or conveyed or intended to be vested or conveyed hereby in or to the predecessor Trustee, the Corporation will execute, acknowledge and deliver that instrument or document. In the event of a change in the Trustee, the predecessor Trustee will cease to be custodian of any moneys which it may hold pursuant to the D-14 Indentures and will cease to be Registrar and Paying Agent for any of the Bonds, to the extent it served in any of those capacities, and the successor Trustee will become custodian and, if applicable, Registrar and Paying Agent. Supplemental Indentures The Corporation and the Trustee, subject to the conditions and restrictions in the Indentures, may enter into Supplemental Indentures for any one or more or all of the following purposes, without the consent of or notice to the Owners of any Bonds: (a) to cure any ambiguity, inconsistency or formal defect or omission in the Indentures; (b) to grant to or confer upon the Trustee for the benefit of the Owners any additional rights, remedies, powers or authority that lawfully may be granted to or conferred upon the Owners or the Trustee; (c) to assign additional revenues under the Indentures; (d) to accept additional security and instruments and documents of further assurance with respect to the Bonds; (e) to add to the covenants, agreements and obligations of the Corporation under the Indentures, other covenants, agreements and obligations to be observed for the protection of the Owners, or to surrender or limit any right, power or authority reserved to or conferred upon the Corporation in the Indentures, including without limitation, the limitation of rights of redemption so that in certain instances Bonds of different series will be redeemed in some prescribed relationship to one another for the protection of the owners of a particular series of Bonds; (f) to evidence any succession to the Corporation and the assumption by its successor of the covenants, agreements and obligations of the Corporation under the Indentures, the Town Leases and the Bonds; (g) to make necessary or advisable amendments or additions in connection with the issuance of Additional Bonds in accordance with the provisions of the Indentures as do not adversely affect the interest of Owners of outstanding Bonds; (h) to permit the use of a book entry system to identify the owner of an interest in an obligation issued by the Corporation under the Indentures, whether that obligation was formerly, or could be, evidenced by a tangible security; (i) to permit the Trustee to comply with any obligations imposed upon it by law; (j) to specify further the duties and responsibilities of, and to define further the relationship among, the Trustee, the Registrar and any Paying Agents; (k) to achieve compliance of the Indentures with any applicable federal securities or tax law; (1) to permit the use of a Qualified Surety Bond to satisfy all or a portion of the Reserve Requirement and (m) to permit any other amendment which, in the judgment of the Trustee, is not to the prejudice of the Trustee or the Owners. (The provisions listed above as subsections (i) and (k) will not be deemed to constitute a waiver by the Trustee, the Registrar, the Corporation or any Owner of any right which it may have in the absence of those provisions to contest the application of any change in law to the Indentures or the Bonds.) With the consent of the insurer of the Series 1997 Bonds, the insurer of the Series 2003 Bonds, the insurer of the Series 2004 Bonds, the Series 2008 Insurer and the Owners of not less than a majority in aggregate principal amount of each series of the Bonds at the time outstanding, the Corporation and the Trustee may enter into Supplemental Indentures for the purpose of adding any provisions to or changing in any manner or eliminating any of the provisions of the Indentures or of any Supplemental Indenture; provided, however, that no such Supplemental Indenture will permit: (a) without the consent of the owner 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 extension of the time of payment of any mandatory sinking fund requirements, or (b) without the consent of the Owners of all Bonds then outstanding, (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 Corporation requests that the Trustee execute and deliver any Supplemental Indenture upon being satisfactorily indemnified with respect to its expenses in connection therewith, the Trustee will cause notice of the proposed execution and delivery of the Supplemental Indenture to be mailed by first class mail, postage prepaid, to all Owners of Bonds then outstanding at the close of business on the fifteenth (15th) day preceding that mailing. The Trustee will not be subject to any liability to any Owner by reason of the Trustee's failure to mail, or the failure of any Owner to receive, such notice. Any failure of that nature will not affect the validity of the Supplemental Indenture when there has been consent thereto as so provided. The notice will set forth briefly the nature of the proposed Supplemental Indenture and will state that copies thereof are on file at the principal corporate trust office of the Trustee for inspection by all Owners. D-15 If the Trustee shall receive, within a period prescribed by the Corporation, of not less than sixty (60) days, but not exceeding one (1) year, following the mailing of the notice, an instrument or document or instruments or documents, in form to which the Trustee does not reasonably object, purporting to be executed by the Owners of not less than a majority in aggregate principal amount of each series of Bonds then outstanding (which instrument or document or instruments or documents shall refer to the proposed Supplemental Indenture in the form described in the notice and specifically shall consent to the Supplemental Indenture in substantially that form), the Trustee will execute and deliver the Supplemental Indenture in substantially the form to which reference is made in the notice as being on file with the Trustee, without liability or responsibility to any Owner, regardless of whether that Owner shall have consented thereto. Any consent will be binding upon the Owner of the Bond giving the consent and, anything herein to the contrary notwithstanding, upon any subsequent Owner of that Bond and of any Bond issued in exchange therefor (regardless of whether the subsequent Owner has notice of the consent to the Supplemental Indenture). A consent may be revoked in writing, however, by the Owner who gave the consent or by a subsequent Owner of the Bond by a revocation of such consent received by the Trustee prior to the execution and delivery by the Trustee of the Supplemental Indenture. At any time after the Owners of the required percentage of Bonds have filed their consents to the Supplemental Indenture, the Trustee will make and file with the Corporation a written statement that the Owners of the required percentage of Bonds have filed those consents. That written statement will be conclusive evidence that the consents have been so filed. If the Owners of the required percentage in aggregate principal amount of the bonds outstanding shall have consented to the Supplemental Indenture, no Owner shall have any right (a) to object to (i) the execution or delivery of the Supplemental Indenture, (ii) any of the terms and provisions contained therein, or (iii) the operation thereof, (b) to question the propriety of the execution and delivery thereof, or (c) to enjoin or restrain the Trustee or the Corporation from that execution or delivery or from taking any action pursuant to the provisions thereof. Defeasance Release of Indenture. If (i) the Corporation shall pay all of the outstanding Bonds, or shall cause them to be paid and discharged, or if there otherwise shall be paid to the Owners of the outstanding Bonds all Bond Service Charges due or to become due thereon, and (ii) provision also shall have been made for the payment of all other sums payable under the Indentures or under the Town Leases, then the Indentures shall cease, determine and become null and void and the covenants, agreements and obligations of the Corporation under the Indentures will be released, discharged and satisfied. Payment and Discharge of Bonds. All or any part of the Bonds will be deemed to have been paid and discharged within the meaning of the Indentures, including without limitation, the above paragraph, if: (a) the Trustee and any paying agents shall have received, in trust for and irrevocably committed thereto, sufficient moneys, or (b) the Trustee shall have received, in trust for and irrevocably committed thereto, Defeasance Obligations which are certified by an independent public accounting firm of national reputation to be of such maturities Or redemption dates and interest payment dates, and to bear such interest, as will be sufficient, together with any moneys to which reference is made in subparagraph (a) above, without further investment or reinvestment of either the principal amount thereof or the interest earnings therefrom (which earnings are to be held likewise in trust and so committed, except as provided in the Indentures), for the payment of all Bond 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 Bond Service Charges thereon to the date of the tender of payment; provided, that 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. Any moneys held by the Trustee in accordance with the foregoing provisions of the Indentures may be invested by the Trustee only in noncallable direct obligations of the United States of America having maturity dates, or having redemption dates which, at the option of the owners of those obligations, will be 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 the Indentures 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 the Indentures, that D-16 income, interest or increment will be transferred at the time of that determination in the manner provided in the Indenture for transfers of amounts remaining in the Bond Retirement Fund. Control by the Series 2008 Insurer Anything in the Indentures to the contrary notwithstanding but only if the Series 2008 Agreement or the Series 2008 Insurer's policy is in effect and the Series 2008 Insurer is not in default thereunder, upon the occurrence and continuance of an event of default as defined therein, the Insurer will be entitled to control and direct the enforcement of all rights and remedies granted to the Owners of the Series 2008 Bonds or the Trustee for the benefit of the Owners of the Series 2008 Bonds under the Indentures, including, without limitation, approval of all waivers of events of default. [???J D-17 APPENDIX E FORM OF APPROVING LEGAL OPINION [Closing Date] Town of Marana Municipal Property Corporation c/o Town of Marana, Arizona 13251 North Lon Adams Road Marana, Arizona 85653 Re: Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2008 We have examined the transcript of proceedings (the "Transcript") relating to the issuance of $ ,000* principal amount of Municipal Facilities Revenue Bonds, Series 2008 of Town of Marana Municipal Property Corporation (the "Corporation"), dated the date of initial authentication and delivery (the "Series 2008 Bonds"). The Series 2008 Bonds are issued to finance the design, acquisition, construction and equipping, as the case may be, of extensions and additions to the sewer lines and interceptors in or to Silverbell Road and the Town Airport, extensions and improvements to Camino de Marana and Dove Mountain Roads and improvements to Cortaro Silverbell District Park and to refinance certain lease obligations for, the Town of Marana, Arizona (the "Town"). The documents examined included an executed counterpart of each of the following: (i) the Amended and Restated Town Lease and Series 1992 Town Lease, dated as of October 1, 1997, as amended by the First Amendment to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of February 1, 2000, the Operations Center Property Ground Lease and Second Amendment to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of April 1, 2002, and the Third Amendment to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of September, 1, 2003, and supplemented by the First Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of February 1, 2000, the Second Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of September 1, 2003, and the Third Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of August 1, 2004 (as so amended and supplemented, the "Base Town Lease"),by and between the Corporation and the Town; (ii) the Combined Cortaro Silverbell District Park Ground Lease and Fourth Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of 1, 2008 (the "Series 2008 Town Lease"), by and between the Corporation and the Town; (iii) the Trust Indenture, dated as of October 1, 1997, from the Corporation to Wells Fargo Bank, National Association (formerly Norwest Bank Arizona, N.A. and Wells Fargo Bank Arizona, N.A.), as trustee (the "Trustee"); (iv) the Series 2000 Supplemental Trust Indenture, dated as of February 1, 2000, from the Corporation to the Trustee, (v) the Series 2003 Supplemental Trust Indenture, dated as of September 1, 2003, from the Corporation to the Trustee, (vi) the Series 2004 Supplemental Trust Indenture, dated as of August 1, 2004, from the Corporation to the Trustee, and (vii) the Series 2008 Supplemental Trust Indenture, dated as of 1, 2008 (the "Series 2008 Supplemental Indenture"), from the Corporation to the Trustee. In addition, we have examined such other proceedings, proofs, instruments, certificates and other documents as well as such other materials and such matters of law as we have deemed necessary or appropriate for the purposes of the opinions rendered herein below. * Subject to change. E-1 Town of Marana Municipal Property Corporation Page 2 Irt such examination, we have examined originals (or copies certified or otherwise identified to our satisfaction) of the foregoing and have assumed the genuineness of all signatures, the authenticity of all documents submitted to us as originals, the conformity to the original documents of all documents submitted to us as copies and the accuracy of the statements contained in such documents. As to any facts material to our opinion, we have, when relevant facts were not independently established, relied upon the aforesaid documents contained in the Transcript. Based upon such examination and upon the law existing on the date of this opinion, we are of the opinion that: 1. The Series 2008 Bonds, the Series 2008 Town Lease and the Series 2008 Supplemental Indenture are legal, valid, binding and enforceable in accordance with their respective terms, except that the binding effect and enforceability thereof and the rights thereunder are subject to applicable bankruptcy, insolvency, reorganization, moratorium and other laws in effect from time to time affecting the rights of creditors generally, except to the extent that the enforceability thereof and rights thereunder may be subject to the exercise of judicial discretion in accordance with general principles of equity and, as to the Series 2008 Town Lease, except to the extent that the enforceability of the indemnification provisions thereof may be affected by applicable securities laws. 2. The Series 2008 Bonds constitute special obligations of the Corporation, and the principal of and interest and any premium on the Series 2008 Bonds (collectively, "debt service"), unless paid from other sources, are payable solely from the revenues and other moneys pledged and assigned pursuant to the Series 2008 Supplemental Indenture to secure that payment. Those revenues and other moneys include payments required to be made by the Town pursuant to the Series 2008 Town Lease, and the obligation of the Town to make those payments is secured by a pledge of Town sales tax, State shared revenues, license and permit fees and fines and forfeitures, on a parity of lien on such pledged sources with the obligations of the Town pursuant to the Base Town Lease, as provided by the Series 2008 Town Lease. The Series 2008 Bonds and the payment of debt service are not secured by an obligation or pledge of any moneys raised by taxation other than the specified taxes; the Series 2008 Bonds do not represent or constitute a debt or pledge of the general credit of the Corporation or the Town and the Series 2008 Town Lease, including the obligation of the Town to make the payments required thereunder, does not represent or constitute a debt or pledge of the general credit of the Town. 3. Subject to the assumption stated in the last sentence of this paragraph, interest on the Series 2008 Bonds is excludible from the gross income of the owners thereof for federal income tax purposes. Furthermore, interest on the Series 2008 Bonds is not an item of tax preference for purposes of the federal alternative minimum tax imposed on individuals and corporations; however, interest on the Series 2008 Bonds is taken into account in determining adjusted current earnings for purposes of computing the alternative minimum tax imposed on certain corporations. (We express no opinion, however, regarding other federal tax consequences resulting from the ownership, receipt or accrual of interest on, or disposition of, the Series 2008 Bonds.) The Internal Revenue Code of 1986, as amended (the "Code"), includes requirements which the Town and the Corporation must continue to meet after the issuance of the Series 2008 Bonds in order that interest on the Series 2008 Bonds not be included in gross income for federal income tax purposes. The failure of the Town or the Cor- poration to meet these requirements may cause interest on the Series 2008 Bonds to be included in gross income for federal income tax purposes retroactive to their date of issuance. The Town and the Corporation have covenanted in the Series 2008 Town Lease to take the actions required by the Code in order to maintain the exclusion from gross income for federal income tax purposes of interest on the Series 2008 Bonds. In rendering the opinion expressed above, we have assumed continuing compliance with the tax covenants referred to above that must be met after the issuance of the Series 2008 Bonds in order that interest on the Series 2008 Bonds not be included in gross income for federal tax purposes. 4. Assuming that such interest is so excludible from gross income for federal income tax purposes, interest on the Series 2008 Bonds is exempt from income taxation under the laws of the State of Arizona. (We express no opinion, however, regarding other State tax consequences resulting from the ownership, receipt or accrual of interest on, or disposition of, the Series 2008 Bonds.) Respectfully submitted, E-2 APPENDIX F FORM OF CONTINUING DISCLOSURE AGREEMENT DRAFT SERIES 2008 CONTINiJING DISCLOSURE AGREEMENT $ ,000* TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION MUNICIPAL FACILITIES REVENUE BONDS, SERIES 2008 (CUSII' BASE NUMBER 565748) This Series 2008 Continuing Disclosure Agreement (this "Disclosure Agreement") is executed and delivered by the Town of Marana, Arizona (the "Obligor"), and Wells Fargo Bank, National Association, as trustee (the "Trustee"), in connection with the issuance of $ ,000* Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2008 (the "Bonds"). The Bonds are being issued pursuant to a Series 2008 Supplemental Trust Indenture, dated as of 1, 2008, which supplements a Trust Indenture, dated as of October 1, 1997, from Town of Marana Municipal Property Corporation to the Trustee (collectively, the "Indenture"). The Obligor and the Trustee covenant and agree as follows: SECTION 1. Purpose of the Disclosure Agreement. This Disclosure Agreement is being executed and delivered by the Obligor and the Trustee to provide information required in Section 10.05 of the Combined Cortaro Silverbell District Park Ground Lease and Fourth Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, dated as of 1, 2008 (the "Lease"), by and between the Issuer, as lessor, and the Obligor, as lessee, in order to comply with the requirements of Rule 15c2-12(b)(5) promulgated under the Securities Exchange Act of 1934 (the "Rule"), and is for the benefit of the holders and beneficial owners of the Bonds. SECTION 2. Definitions. In addition to the definitions set forth in the Indenture, which apply to any capitalized term used in this Disclosure Agreement unless otherwise defined in this Section, the following capitalized terms shall have the following meanings: "Annual Report" shall mean any Annual Report provided by the Obligor or other Obligated Person pursuant to, and as described in, Sections 3 and 4 of this Disclosure Agreement. "Beneficial Owner" shall mean any person who (a) has the power, directly or indirectly, to vote or consent with respect to, or to dispose of ownership of, any Bonds (including persons holding Bonds through nominees, depositories or other intermediaries), or (b) is treated as the owner of any Bonds for federal income tax purposes. "Central Post Office" shall mean an entity then recognized by the Securities and Exchange Commission as eligible to receive filings and submit such filings to the Repositories for purposes of the Rule. As of the date of this Disclosure Agreement, the Central Post Office is: DisclosureUSA P.O. Box 684667 Austin, Texas 78768-4667 Fax: (512) 476-6403 http://www.disclosureUSA.org "Disclosure Representative" shall mean the Town Manager of the Obligor or his or her designee, or such other officer or employee as~the Obligor shall designate in writing to the Trustee from time to time. * Subject to change. F-1 "Dissemination Agent" shall mean the Obligor, acting in its capacity as Dissemination Agent hereunder, or any successor Dissemination Agent designated in writing by the Obligor and which has filed with the Obligor and the Trustee a written acceptance of such designation. "Fiscal Year" shall mean the period commencing on July 1 and ending on June 30 of the next succeeding year, or such other period of time provided by applicable law. "Listed Events" shall mean any of the events listed in Section 5(a) of this Disclosure Agreement. "MSRB" shall mean Municipal Securities Rulemaking Board. "National Repository" shall mean any Nationally Recognized Municipal Securities Information Repository for purposes of the Rule. Currently, the following are National Repository: Bloomberg Municipal Repository 100 Business Park Drive Skillman, New Jersey 08558 Phone: (609) 279-3225 Fax: (609) 279-5962 E-mail: munis@bloomberg.com Interactive Data Pricing and Reference Data, Inc. Attn: NRMSIIZ 100 William Street New York, New York 10038 Phone: (212) 771-6999 Fax: (212) 771-7390 E-mail: nrmsir@ftid.com Standard & Poor's Securities Evaluations, Inc. 55 Water Street 45th Floor New York, New York 10041 Phone: (212) 438-4595 Fax: (212) 438-3975 E-mail: nrmsir repository@sandp.com DPC Data Inc. One Executive Drive Fort Lee, New Jersey 07024 Phone: (201) 346-0701 Fax: (201) 947-0107 E-mail: nrmsir@dpcdata.com The names and addresses of the then-current National Repositories should be verified each time information is delivered pursuant to this Disclosure Agreement (A current listing of the National Repositories can be found at http://www.sec.govAnfo/municipaU nrmsir. htm.) "Obligated Person(s)" shall mean, with respect to the Bonds, those person(s), other than the Series 2008 Insurer, who either generally or through an enterprise fund or account of such persons are committed by contract or other arrangement to support payment of all or a part of the obligations of the Bonds, which person(s) shall include the Obligor, and who are identified as such herein. F-2 "Official Statement" shall mean the final Official Statement, dated , 2008, relating to the Bonds, and any amendments or supplements thereto, as filed with the MSRB. "Participating Underwriter" shall mean any of the original underwriters of the Bonds required to comply with the Rule in connection with the offering of the Bonds. Repository. "Repository" shall mean each National Repository or the MSRB and each State "SEC" shall mean the Securities and Exchange Commission. "State Repository" shall mean any public or private repository or entity designated by the State of Arizona as a state repository for the purpose of the Rule and recognized as such by the SEC. As of the date of this Disclosure Agreement, there is no State Repository. "Tax-exempt" shall mean that interest on the Bonds is excluded from Boss income for federal income tax purposes, whether or not such interest is includable as an item of tax preference or otherwise includable directly or indirectly for purposes of calculating any other tax liability, including any alternative minimum tax. SECTION 3. Provision of ObligOr's Annual Reports. (a) Subject to annual appropriation to cover the costs of preparation and mailing thereof, the Obligor shall, or shall cause the Dissemination Agent to, not later than February 1 of each year commencing February 1, 2009, provide to each Repository an Annual Report which satisfies the requirements of Section 4 of this Disclosure Agreement. The Obligor shall provide the Annual Report to the Dissemination Agent and the Trustee (if the Trustee is not the Dissemination Agent) no later than two hundred ten (210) days after the close of the Obligor's fiscal year, commencing with the fiscal year ending June 30, 2008. In each case, the Annual Report may be submitted as a single document or as separate documents comprising a package, and may cross- reference other information as provided in Section 4 of this Disclosure Agreement; provided that the audited financial statements of the Obligor may be submitted separately from the balance of the Annual Report. (b) If by the 210th day after the close of the Obligor's fiscal year the Trustee has not received a copy of the Annual Report, the Trustee shall notify the Obligor and the Dissemination Agent in writing that the Obligor has not complied with its obligations under subsection (a) above. (c) If the Trustee is unable to verify in writing from the Obligor that the Obligor has filed or caused the Dissemination Agent to file an Annual Report with the Repositories by the date required in subsection (a) above, the Trustee shall send a notice to each Repository in substantially the form attached as Exhibit A. (d) The Dissemination Agent shall: (i) determine each year prior to the date for providing the Annual Report the name and address of each National Repository and each State Repository, if any; and (ii) promptly upon fulfilling its obligations under subsection (a) above, file a report with the Disclosure Representative and (if the Dissemination Agent is not the Trustee) the Trustee certifying that the Annual Report has been provided pursuant to this Disclosure Agreement, stating the date it was provided and listing all the Repositories to which it was provided, and send a copy of such report to the Series 2008 Insurer. SECTION 4. Contents of Annual Reports. The Obligor's Annual Report shall contain or incorporate by reference the following: F-3 (i) the audited financial statements of the Obligor for the immediately preceding Fiscal Year, prepared in accordance with generally accepted accounting principles applicable to operations of the Obligor, as same may be modified from time to time by statutory requirements of the State of Arizona and the governmental accounting standards promulgated by the Government Accounting Standards Board; and (ii) an update, as of the end of the immediately preceding Fiscal Year for which audited financial statements are available or, to the extent applicable, as reflected in the Obligor's then- current budget, of the financial information and operating data contained in the Official Statement in TABLE 4. The Obligor is not committing to update any other information in the Official Statement. The Obligor reserves the right to modify from time to time the specific types of information provided or the format of the presentation of such information, to the extent necessary or appropriate in the judgment of the Obligor; provided, however, that the Obligor agrees that any such modification will be accomplished in a manner consistent with the Rule. Any or all of the foregoing items may be incorporated by specific reference to other documents, including offering statements of debt issues or audited financial statements of the Obligor or related public entities, which have previously been submitted to each Repository, the MSRB or the SEC. If the document incorporated by reference is a final official statement, it must be available from the MSRB. The Obligor shall clearly identify each such other document so incorporated by reference. SECTION 5. The Obligor's Obligation to Report Significant Events. (a) This Section 5 shall govern the giving of notices of the occurrence of any of the following events ("Listed Event"): 1. Delinquency in payment when due of any principal or interest on the Bonds. 2. Occurrence of any event of default under and as defined in the Indenture or the Lease (other than as described in clause (I) above). 3. Amendment to or supplement of the Indenture, the Lease or this Disclosure Agreement modifying the rights of the owners of the Bonds. 4. Optional or unscheduled extraordinary mandatory redemption of any Bonds. 5. Defeasance of the Bonds or any portion thereof. 6. Any change in any rating of the Bonds. 7. (A) Receipt of an opinion of nationally recognized bond counsel to the effect that interest on the Bonds is not Tax-exempt; or (B) Any event adversely affecting the Tax-exempt status of the Bonds, including but not limited to: (i) Any non-random audit, investigation or other challenge of the Tax-exempt status of the Bonds by the Internal Revenue Service or in any administrative or judicial proceeding; or F-4 (ii) The issuance of any regulation, decision or other official pronouncement by the Internal Revenue Service or other official tax authority or by any court adversely affecting the Tax-exempt status of the Bonds or bonds of the same type as the Bonds or financing structures of the same type as financed by the Bonds. Any unscheduled draw on the Reserve Fund reflecting financial difficulties. 9. Any unscheduled draw on credit enhancements including without limitation the Series 2008 Municipal Bond Insurance Policy or the Series 2008 Surety Bond reflecting financial difficulties. 10. The release, substitution or sale of property not securing repayment of the Bonds (including property leased, mortgaged or pledged as such security). 11. The substitution of credit or liquidity providers including without limitation the Series 2008 Insurer or their failure to perform. 12. Notice of any failure on the part of the Obligor to meet the requirements of Section 3 hereof, including any non-appropriation to cover applicable costs. (b) Whenever the Obligor obtains knowledge of the occurrence of a Listed Event, the Obligor shall, as soon as possible, determine if such event would be material under applicable federal securities laws. (c) If the Obligor has determined that knowledge of the occurrence of a Listed Event would be material under applicable federal securities laws but subject to annual appropriation to cover the costs of preparing and mailing thereof, the Obligor shall promptly report the occurrence pursuant to subsection (d) below. (d) If the Obligor determines that the Listed Event would be material under applicable federal securities laws, the Obligor shall file a notice of such occurrence with the MSRB or each National Repository and the State Repository, and send a copy thereof to the Series 2008 Insurer. Each such notice shall be captioned "Material Event Notice" and shall prominently state the date, title and CUSIP numbers of the Bonds to which it relates. Notwithstanding the foregoing, notice of the occurrence of a Listed Event described in clauses (4.) or (5.) of subsection (a) above need not be given under this subsection any earlier than the notice (if any) of the underlying event is given to Owners of affected Bonds pursuant to the Indenture. If the Series 2008 Municipal Bond Insurance Policy is in effect and the Series 2008 Insurer is not in default thereunder, such notices shall also be provided to the Series 2008 Insurer at the address provided in the Indenture. SECTION 6. Alternate Means of Disclosure. Notwithstanding the provisions hereof requiring that the Obligor file the Annual Reports, the notices of any Listed Event and certain other notices with each of the Repositories, for so long as there is a Central Post Office, the Obligor may instead comply with the provisions of this Disclosure Agreement by filing the required Annual Reports and such notices with a Central Post Office. SECTION 7. Termination of Reporting Obli ations. The obligations of the Obligor hereunder shall terminate upon the legal defeasance, prior prepayment or payment in full of all Outstanding Bonds or upon the termination of the continuing disclosure requirements of the Rule by legislative, judicial or administrative action. If F-5 such termination occurs prior to the final maturity of the Bonds, the Obligor shall give notice of such termination in the same manner as for a Listed Event under Section 5(d) above. SECTION 8. Identity of Obligated Persons. The Obligor represents and warrants that no person (other than the Obligor), whether generally or through an enterprise fund or account of such person, is committed by contract or other arrangement to support payment of all, or part, of the obligations on the Bonds. SECTION 9. Dissemination A ent. The Obligor may, from time to time, appoint or engage a Dissemination Agent to assist it in carrying out its obligations under this Disclosure Agreement, and may discharge any such Agent, with or without appointing a successor Dissemination Agent. If at any time there is not any other designated Dissemination Agent, the Obligor shall be the Dissemination Agent. The initial Dissemination Agent shall be the Obligor. SECTION 10. Amendment; Waiver. Notwithstanding any other provision hereof, the Obligor and the Trustee may amend the provisions of this Disclosure Agreement without consent of the Owners of the Bonds (or the Trustee under the Indenture), and any provision of this Disclosure Agreement may be waived provided that the following conditions are satisfied: (a) If the amendment or waiver relates to the provisions of Sections 3(a), 4, or 5(a), it may only be made in connection with a change in circumstances that arises from a change in legal requirements, change in law, or change in the identity, nature or status of an obligated person with respect to the Bonds, or the type of business conducted; and (b) The undertaking, as amended or taking into account such waiver, would, in the opinion of nationally recognized bond counsel, have complied with the requirements of the Rule at the time of the original issuance of the Bonds, after taking into account any amendments or interpretations of the Rule, as well as any change in circumstances. In the event of any amendment or waiver of a provision of this Disclosure Agreement, the Obligor shall describe such amendment in the next Annual Report, and shall include, as applicable, a narrative explanation of the reason for the amendment or waiver and its impact on the type (or, in the case of a change of accounting principles, on the presentation) of financial information or operating data being presented by the Obligor. In addition, if the amendment relates to the accounting principles to be followed in preparing financial statements: (i) notice of such change shall be given in the same manner as for a Listed Event under Section 5(d), and (ii) the Annual Report for the year in which the change is made shall present a comparison (in narrative form and also, if feasible, in quantitative form) between the financial statements as prepared on the basis of the new accounting principles and those prepared on the basis of the former accounting principles. SECTION 11. Additional Information. Nothing in this Disclosure Agreement shall be deemed to prevent the Obligor from disseminating any other information, using the means of dissemination set forth in this Disclosure Agreement or any other means of communication, or including any other information in any Annual Report or notice of occurrence of a Listed Event, in addition to that which is required by this Disclosure Agreement. If the Obligor chooses to include any information in any Annual Report or notice of occurrence of a Listed Event in addition to that which is specifically required by this Disclosure Agreement, the Obligor shall have no obligation under this Disclosure Agreement to update such information or include it in any future Annual Report or notice of occurrence of a Listed Event. SECTION 12. Default. In the event of a failure of the Obligor or the Dissemination Agent to comply with any provision of this Disclosure Agreement, the Trustee may (and, at the request of any Participating Underwriter or the Owners of at least 25% aggregate principal amount of Outstanding Bonds, shall), or any holder or beneficial owner of a Bond may take such actions as may be necessary and appropriate, including seeking mandate or specific performance by court order, to cause the Obligor or the Dissemination Agent, as the case may be, to comply with its obligations under this Disclosure Agreement. A default under this Disclosure Agreement shall not be deemed an event of default under the Indenture or the Lease, and the sole remedy under this Disclosure F-6 Agreement in the event of any failure of the Obligor or the Dissemination Agent to comply with this Disclosure Agreement shall be an action to compel performance. SECTION 13. Duties, Immunities and Liabilities of Trustee and Dissemination A ent. Article VII of the Indenture is hereby made applicable to this Disclosure Agreement as if this Disclosure Agreement were (solely for this purpose) contained in the Indenture. The Dissemination Agent (if other than the Trustee) and the Trustee shall have only such duties as are specifically set forth in this Disclosure Agreement. SECTION 14. Beneficiaries. This Disclosure Agreement shall inure solely to the benefit of the Obligor, the Trustee, the Dissemination Agent, the Participating Underwriters and Beneficial Owners of the Bonds, and shall create no rights in any other person or entity. SECTION 15. Counterparts. This Disclosure Agreement may be executed in several counterparts, each of which shall be an original and all of which shall constitute but one and the same instrument. SECTION 16. Cancellation. For all purposes of Section 38-511, Arizona Revised Statutes, as amended, the provisions of which are hereby incorporated by this reference, the Obligor may, within three (3) years after its execution, cancel this Disclosure Agreement, without penalty(s) or further obligation, if any person significantly involved in initiating, negotiating, securing, drafting or creating this Disclosure Agreement on behalf of the Obligor is, at any time while this Disclosure Agreement is in effect, an employee or agent of the Trustee in any capacity or a consultant to any other party of this Disclosure Agreement with respect to the subject matter of this Disclosure Agreement and may recoup any fee or commission paid or due any person significantly involved in initiating, negotiating, securing, drafting or creating this Disclosure Agreement on behalf of the Obligor arising as the result of this Disclosure Agreement. The Trustee has not taken and shall not take any action which would cause any person described in the preceding sentence to be an employee or agent of the Trustee in any capacity or a consultant to any party to this Disclosure Agreement with respect to the subject matter of this Disclosure Agreement. F-7 Date: [Closing Date] TOWN OF MARANA, ARIZONA By .................................... Edward Honea, Mayor ATTEST: ................................ Jocelyn C. Bronson, Town Clerk APPROVED AS TO FORM: By .............................. Frank Cassidy, Town Attorney WELLS FARGO BANK, NATIONAL ASSOCIATION By .................................... Nancy Eatros, Authorized Representative F-8 EXHIBIT A NOTICE TO REPOSITORIES OF FAILURE TO FILE ANNUAL REPORT Name of Obligor: Town of Marana, Arizona Name of Issue: $ ,000 Town of Marana Municipal Property Corporation Municipal Facilities Revenue Bonds, Series 2008 Date of Issuance: [Closing Date] NOTICE IS HEREBY GIVEN that the Obligor has not provided an Annual Report with respect to the above-named Bonds as required by Sections 3 and 4 of the Continuing Disclosure Agreement, dated [Closing Date], of the Obligor. The Obligor anticipates that the Annual Report will be filed by .............................. Dated :.................... TOWN OF MARANA, ARIZONA By .................................... Town Manager cc: Wells Fargo Bank, National Association A-1 APPENDIX G SPECIMEN INSURANCE POLICY APPENDIX H BOOK-ENTRY-ONLY SYSTEM BOOK-ENTRY-ONLY SYSTEM The Depository Trust Company ("DTC"), New York, NY, will act as securities depository for the Series 2008 Bonds. The Series 2008 Bonds will be issued as fully-registered securities registered in the name of Cede & Co. (DTC's partnership nominee) or such other name as may be requested by an authorized representative of DTC. One fully-registered Series 2008 Bond will be issued for each maturity of the Series 2008 Bonds, each in the aggregate principal amount of such maturity, and will be deposited with DTC. DTC, the world's largest securities depository, is alimited-purpose trust company organized under the New York Banking Law, a "banking organization" within the meaning of the New York Banking Law, a member of the Federal Reserve System, a "clearing corporation" within the meaning of the New York Uniform Commercial Code, and a "clearing agency" registered pursuant to the provisions of Section 17A of the Securities Exchange Act of 1934. DTC holds and provides asset servicing for over 3.5 million issues of U.S. and non-U.S. equity issues, corporate and municipal debt issues, and money market instruments from over 100 countries that DTC's participants ("Direct Participants") deposit with DTC. DTC also facilitates the post-trade settlement among Direct Participants of sales and other securities transactions in deposited securities, through electronic computerized book-entry transfers and pledges between Direct Participants' accounts. This eliminates the need for physical movement of securities certificates. Direct Participants include both U.S. and non-U.S. securities brokers and dealers, banks, trust companies, clearing corporations, and certain other organizations. DTC is a wholly-owned subsidiary of The Depository Trust & Clearing Corporation ("DTCC"). DTCC is the holding company for DTC, National Securities Clearing Corporation and Fixed Income Securities Clearing Corporation, all of which are registered clearing agents. DTC is owned by the users of its regulated subsidiaries. Access to the DTC system is also available to others such as both U.S. and non-U.S. securities brokers and dealers, banks, trust companies, and clearing corporations that clear through or maintain a custodial relationship with a Direct Participant, either directly or indirectly ("Indirect Participants"). DTC has Standard & Poor's highest rating: "AAA." The DTC Rules applicable to its Participants are on file with the Securities and Exchange Commission. More information about DTC can be found at www.dtcc.com and www.dtc.org. Purchases of Series 2008 Bonds under the DTC system must be made by or through Direct Participants, which will receive a credit for the Series 2008 Bonds on DTC's records. The ownership interest of each actual purchaser of each Series 2008 Bond ("Beneficial Owner") is in turn to be recorded on the Direct and Indirect Participants' records. Beneficial Owners will not receive written confirmation from DTC of their purchase. Beneficial Owners are, however, expected to receive written confirmations providing details of the transaction, as well as periodic statements of their holdings, from the Direct or Indirect Participant through which the Beneficial Owner entered into the transaction. Transfers of ownership interests in the Series 2008 Bonds are to be accomplished by entries made on the books of Direct and Indirect Participants acting on behalf of Beneficial Owners. Beneficial Owners will not receive certificates representing their ownership interests in Series 2008 Bonds, except in the event that use of the book-entry system for the Series 2008 Bonds is discontinued. To facilitate subsequent transfers, all Series 2008 Bonds deposited by Direct Participants with DTC are registered in the name of DTC's partnership nominee, Cede & Co., or such other name as may be requested by an authorized representative of DTC. The deposit of Series 2008 Bonds with DTC and their registration in the name of Cede & Co. or such other DTC nominee do not effect any change in beneficial ownership. DTC has no knowledge of the actual Beneficial Owners of the Series 2008 Bonds; DTC's records reflect only the identity of the Direct Participants to whose accounts such Series 2008 Bonds are credited, which may or may not be the Beneficial Owners. The Direct and Indirect Participants will remain responsible for keeping account of their holdings on behalf of their customers. Conveyance of notices and other communications by DTC to Direct Participants, by Direct Participants to Indirect Participants, and by Direct Participants and Indirect Participants to Beneficial Owners will be governed by arrangements among them, subject to any statutory or regulatory requirements as may be in effect from time to time. Beneficial Owners of the Series 2008 Bonds may wish to take certain steps to augment the transmission to them of notices of significant events with respect to the Series 2008 Bonds, such as redemptions, tenders, defaults, and proposed amendments to the Series 2008 Bond documents. For example, Beneficial Owners of Series 2008 Bonds may wish to ascertain that the nominee holding the Series 2008 Bonds for their benefit has agreed to obtain and transmit notices to Beneficial Owners. In the alternative, Beneficial Owners may wish tb provide their names and addresses to the Trustee and request that copies of notices be provided directly to them. H-1 Redemption notices shall be sent to DTC. If less than all of the Series 2008 Bonds within a maturity are being redeemed, DTC's practice is to determine by lot the amount of the interest of each Direct Participant in such maturity to be redeemed. Neither DTC nor Cede & Co. (nor any other DTC nominee) will consent or vote with respect to Series 2008 Bonds unless authorized by a Direct Participant in accordance with DTC's NII~II Procedures. Under its usual procedures, DTC mails an Omnibus Proxy to the Trustee as soon as possible after the record date. The Omnibus Proxy assigns Cede & Co.'s consenting or voting rights to those Direct Participants to whose accounts Series 2008 Bonds are credited on the record date (identified in a listing attached to the Omnibus Proxy). Payment of principal of and interest on the Series 2008 Bonds and the redemption price of any Series 2008 Bond will be made to Cede & Co., or such other nominee as may be requested by an authorized representative of DTC. DTC's practice is to credit Direct Participants' accounts upon DTC's receipt of funds and corresponding detail information from the Corporation or the Trustee, on payable date in accordance with their respective holdings shown on DTC's records. Payments by Participants to Beneficial Owners will be governed by standing instructions and customary practices, as is the case with securities held for the accounts of customers in bearer form or registered in "street name," and will be the responsibility of such Participant and not of DTC, the Trustee or the Corporation, subject to any statutory or regulatory requirements as may be in effect from time to time. Payment of principal of and interest on the Series 2008 Bonds and the redemption price of any Series 2008 Bonds will be made to Cede & Co. (or such other nominee as may be requested by an authorized representative of DTC) is the responsibility of the Corporation or Trustee, disbursement of such payments to Direct Participants will be the responsibility of DTC, and disbursement of such payments to the Beneficial Owners will be the responsibility of Direct and Indirect Participants. DTC may discontinue providing its services as depository with respect to the Series 2008 Bonds at any time by giving reasonable notice to the Corporation or the Trustee. Under such circumstances, in the event that a successor depository is not obtained, certificates are required to be printed and delivered. The Corporation may decide to discontinue use of the system of book-entry-only transfers through DTC (or a successor securities depository). In that event, certificates will be printed and delivered to DTC. The information in this section concerning DTC and DTC's book-entry system has been obtained from sources that the Corporation believes to be reliable, but the Corporation takes no responsibility for the accuracy thereof. H-2 TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION MUNICIPAL FACILITIES REVENUE BONDS, SERIES 2008 $ $ Municipal Facilities Revenue Bonds, Municipal Facilities Revenue Bonds, Series 2008A Series 2008B BOND PURCHASE AGREEMENT 2008 Town of Marana Municipal Property Corporation Marana, Arizona Ladies and Gentlemen: On the basis of the representations, warranties and covenants contained in this Bond Purchase Agreement and upon the terms and conditions contained herein, the undersigned, Stone & Youngberg LLC (the "Underwriter"), hereby offers to enter into the following agreement with the Town of Marana Municipal Property Corporation (the "Corporation"). Upon the Corporation's written acceptance of this offer, and the execution and delivery by the Town of Marana, Arizona (the "Town") of the Letter of Representation, dated the date hereof and in the form of Exhibit A hereto (the "Letter of Representation"), this Bond Purchase Agreement will be binding upon the Corporation and upon the Underwriter. This offer is made subject to the Corporation's written acceptance hereof and subject to the execution and delivery of the Letter of Representation on or before 11:59 p.m., M.S.T. time, on , 2008, and, if not so accepted or if the Letter of Representation is not so executed and delivered, this offer will be subject to withdrawal by the Underwriter upon notice delivered to the Corporation at any time prior to the acceptance hereof by the Corporation and execution and delivery of the Letter of Representation. Terms not otherwise defined in this Bond Purchase Agreement shall have the same meanings set forth in the Indentures (as defined herein) or in the Official Statement (as defined herein). The Bonds (as defined herein) shall be as described in, and shall be issued and secured under and pursuant to the provisions of a Trust Indenture, dated as of October 1, 1997 (the "Indenture"), as supplemented by (a) a Series 2003 Supplemental Trust Indenture, dated as of September 1, 2003 (the "Series 2003 Supplementallndenture "), (b) a Series 2004 Supplemental Trust Indenture, dated as of Julyl, 2004 (the "Series 2004 Supplementallndenture"), and (c) a Series 2008 Supplemental Trust Indenture, dated as of , 2008 (the "Series 2008 Supplementallndenture") (the Indenture, the Series 2003 Supplemental Indenture, the Series 2004 Supplemental Indenture, and Series 2008 437619.2 Supplemental Indenture are collectively referred to herein as the "Indentures"), between the Corporation and Wells Fargo Bank, National Association (successor to Norwest Bank Arizona, N.A.), as trustee (together with its successors, if any, as trustee under the Indentures, the "Trustee. "). Concurrently, with the execution of the Series 2008 Supplemental Indenture, the Corporation and the Town will enter into a Fourth Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, to be dated as of , 2008 (the "Fourth Supplemental Town Lease"), which supplements the Amended and Restated Town Lease and Series 1992 Town Lease dated as of October 1, 1997 (the "Base Town Lease"), as supplemented by the Second Supplemental Town Lease dated as of September 1, 2003 (the "Second Supplemental Town Lease"), and as further supplemented by the Third Supplement to Amended and Restated Town Lease and Series 1992 Town Lease, to be dated as of July 1, 2004 (the "Third Supplemental Town Lease") (collectively, the Base Town Lease, the Second Supplemental Town Lease, the Third Supplemental Town Lease and the Fourth Supplemental Town Lease are referred to herein as the "Town Lease") between the Corporation and the Town. The rental payments made by the Town pursuant to the Fourth Supplemental Town Lease will be used to pay the principal of and premium, if any, and interest requirements on the Bonds. The payment of principal and interest on the Bonds when due will be supported by a financial guaranty insurance policy (the "Bond Insurance Policy") and a reserve fund surety bond (the "Surety Bond"), to be issued by (the "Bond Insurer"). The obligation of the Corporation to reimburse the Bond Insurer for drawing under the Surety Bond is reflected in a [Financial Guaranty Agreement] (the "[Financial Guaranty Agreement)"). The Bonds will be offered by means of the Preliminary Official Statement of the Corporation, dated , 2008, relating to the Bonds (including the cover page and all appendices, the "Preliminary Official Statement") and the final Official Statement of the Corporation, dated the date of this Bond Purchase Agreement, relating to the Bonds (including the cover page and all appendices, the "Official Statement"). The Town will enter into and deliver a written undertaking (the "Continuing Disclosure Undertaking") to provide, or cause to be provided, ongoing disclosure for the benefit of the owners of the Bonds as described in the Continuing Disclosure Undertaking for purposes of Rule 15c2-12 promulgated under the Securities Exchange Act of 1934 (the "Disclosure Rule"). The Corporation will enter into an Escrow Trust Agreement, to be dated as of , 2008, (the "Escrow Trust Agreement ") with Wells Fargo Bank, National Association, (the "Escrow Trustee "), pursuant to which a portion of the proceeds of the Bonds will be deposited with the Escrow Trustee to be held in trust to provide for the payment of certain bonds being refunded with a portion of the proceeds of the Bonds. The Corporation and the Town will both execute and deliver tax certificates (together, the "Tax Agreement") regarding exclusion of interest on the Bonds from gross income for income tax purposes. This Bond Purchase Agreement, the Series 2008 Supplemental Indenture, the Fourth Supplemental Town Lease, the Escrow Trust Agreement, the [Financial Guaranty Agreement] and the Tax Agreement are referred to as the "Corporation Documents". 437619.2 The Letter of Representation, the Fourth Supplemental Town Lease, the Tax Agreement and the Continuing Disclosure Undertaking are referred to as the "Town Documents". Purchase and Sale of the Bonds. (a) Subject to the terms and conditions and in reliance upon the representations warranties and agreements set forth herein, the Underwriter hereby agrees to purchase from the Corporation, and the Corporation hereby agrees to sell and deliver to the Underwriter, all, but not less than all, of the Corporation's Municipal Facilities Revenue Bonds, Series 2008A (the "Series 2008A Bonds") and the Corporation's Municipal Facilities Revenue Bonds, Series 2008B (the "Series 2008E Bonds," and together with the Series 2008A Bonds, the "Bonds"). Inasmuch as this purchase and sale represents a negotiated transaction, the Corporation understands, and hereby confirms, that the Underwriter is not acting as a fiduciary or agent of the Corporation, but rather is acting solely in its capacity as Underwriter for its own account. The Underwriter has been duly authorized to execute this contract and to act hereunder. (b) The principal amount of the Bonds to be issued, the dated date of the Bonds, the maturities and optional redemption provisions and interest rates per annum and resulting prices or yields are set forth in Schedule I hereto. (c) The purchase price for the Bonds shall be $ , (the "Purchase Price")plus interest accrued on the Bonds from the dated date of the Bonds to the Closing Date (as hereinafter defined). The Purchase Price represents: Par amount of Bonds $ Plus [net] original issue premium on Bonds Less Underwriter's compensation ~ ) Purchase Price $ For the convenience of the Corporation, the Underwriter, will, at or before the time of Closing, pay on behalf of the Corporation $ to the Bond Insurer as payment of (i) the bond insurance premium for the Bond Insurance Policy on the Bonds and (ii) the reserve fund surety bond premium for the Surety Bond, resulting in a net amount to be paid by the Underwriter to the Corporation at the time of Closing of $ ,plus accrued interest. 2. Public Offering. The Underwriter intends to make a bona fide public offering of the Bonds at the offering prices or yields set forth in Schedule I, and based upon those initial offering prices or yields, the Underwriter would receive compensation of $ ;however, the Underwriter may offer a portion of the Bonds for sale to selected dealers who are members of the Financial Industry Regulatory Authority and who agree to resell the Bonds to the public on terms consistent with this Bond Purchase Agreement and the Underwriter reserves the right to change such offering prices or yields as the Underwriter shall deem necessary in connection with the marketing of the Bonds and to offer and sell the Bonds to certain dealers (including dealers depositing the Bonds into investment trusts) and others at prices lower than the initial offering prices or at yields higher 437619.2 than the initial yields set forth in Schedule I. The Underwriter also reserves the right to over-allot or effect transactions that stabilize or maintain the market price of the Bonds at a level above that which might otherwise prevail in the open market and to discontinue such stabilizing, if commenced, at any time. None of such activities shall affect the principal amount, maturity dates, interest rates, redemption or other provision of the Bonds or the amount to be paid by the Underwriter to the Corporation for the Bonds. 3. The Official Statement. (a) The Preliminary Official Statement has been prepared for use in connection with the public offering, sale and distribution of the Bonds by the Underwriter. The Corporation hereby deems the Preliminary Official Statement final by the Corporation as of its date, except for the omission of such information which is dependent upon the final pricing of the Bonds for completion, all as permitted to be excluded by Section (b)(1) of the Disclosure Rule. (b) The Corporation hereby authorizes the Official Statement and the information therein contained to be used by the Underwriter in connection with the public offering and the sale of the Bonds. The Corporation consents to the use by the Underwriter prior to the date hereof of the Preliminary Official Statement in connection with the public offering of the Bonds. The Corporation shall provide, or cause to be provided, to the Underwriter as soon as practicable after the date of the Corporation's acceptance of this Bond Purchase Agreement (but, in any event, not later than within seven (7) business days after the Corporation's acceptance of this Bond Purchase Agreement and in sufficient time to accompany any confirmation that requests payment from any customer) copies of the Official Statement which is complete as of the date of its delivery to the Underwriter in such quantity as the Underwriter shall request in order for the Underwriter to comply with Section (b)(4) of the Disclosure Rule and the rules of the Municipal Securities Rulemaking Board. (c) If, after the date of this Bond Purchase Agreement to and including the date the Underwriter is no longer required to provide the Official Statement to potential customers who request the same pursuant to the Disclosure Rule (the earlier of (i) 90 days from the "end of the underwriting period" (as defined in Rule) and (ii) the time when the Official Statement is available to any person from a nationally recognized municipal securities repository, but in no case less than 25 days after the "end of the underwriting period" for the Bonds), the Corporation becomes aware of any fact or event which might or would cause the 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 therein, not misleading, or if it is necessary to amend or supplement the Official Statement to comply with law, the Corporation will notify the Underwriter (and for the purposes of this clause provide the Underwriter with such information as it may from time to time request), and if, in the opinion of the Corporation or the Underwriter, such fact or event requires preparation and publication of a supplement or amendment to the Official Statement, the Corporation will forthwith prepare and furnish, at the Corporation's own expense (in a form and manner approved by the Underwriter), a reasonable number of copies of either amendments or supplements to the Official Statement so that the statements in the Official Statement as so amended and supplemented will not contain any untrue statement of a material fact or omit to 437619.2 state a material fact required to be stated therein or necessary to make the statements therein not misleading or so that the Official Statement will comply with law. If such notification shall be subsequent to the Closing, the Corporation shall furnish such legal opinions, certificates, instruments and other documents as the Underwriter may deem necessary to evidence the truth and accuracy of such supplement or amendment to the Official Statement. (d) The Underwriter hereby agrees to file the Official Statement with a nationally recognized municipal securities information repository. Unless otherwise notified in writing by the Underwriter, the Corporation can assume that the "end of the underwriting period" for purposes of the Rule is the date of the Closing. 4. Reuresentations, Warranties and Covenants of the Corporation. The undersigned, on behalf of the Corporation (but not individually), hereby represents and warrants to and covenants with the Underwriter that: (a) The Corporation is a nonprofit corporation duly created, organized and existing under the laws of the State of Arizona (the "State") and has full legal right, power and authority, and at the date of the Closing will have full legal right, power and authority (i) to enter into, execute and deliver the Corporation Documents, (ii) to sell, issue and deliver the Bonds to the Underwriter as provided herein, and (iii) to carry out and consummate the transactions contemplated by the Corporation Documents, and the Official Statement and the Corporation has complied, and will at the Closing be in compliance in all respects, with the terms of the Corporation Documents as they pertain to such transactions; (b) By all necessary official action of the Corporation prior to or concurrently with the acceptance hereof, the Corporation has duly authorized all necessary action to be taken by it for (i) the execution of the Series 2008 Supplemental Indenture and the issuance and sale of the Bonds, (ii) the approval, execution and delivery of, and the performance by the Corporation of the obligations on its part, contained in the Bonds and the Corporation Documents and (iii) the consummation by it of all other transactions contemplated by the Preliminary Official Statement, the Corporation Documents, and any and all such other agreements and documents as may be required to be executed, delivered and/or received by the Corporation in order to carry out, give effect to, and consummate the transactions contemplated herein and in the Preliminary Official Statement; (c) The Corporation Documents constitute legal, valid and binding obligations of the Corporation, enforceable in accordance with their respective terms, subject to bankruptcy, insolvency, reorganization, moratorium and other similar laws and principles of equity relating to or affecting the enforcement of creditors' rights; the Bonds, when issued, delivered and paid for, in accordance with the Indentures and this Bond Purchase Agreement, will constitute legal, valid and binding obligations of the Corporation entitled to the benefits of the Indentures and enforceable in accordance with their terms, subject to bankruptcy, insolvency, reorganization, moratorium and other similar laws and principles of equity relating to or affecting the enforcement of creditors' rights; upon the issuance, authentication and delivery of the Bonds as aforesaid, the Indentures will provide, 437619.2 for the benefit of the owners, from time to time, of the Bonds, the legally valid and binding pledge of and lien it purports to create as set forth in the Indentures; (d) The Corporation is not in breach of or default in any material respect under any applicable constitutional provision, law or administrative regulation of the State or the United States or any applicable judgment or decree or any loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the Corporation is a party or to which the Corporation is or any of its property or assets are otherwise subject; and no event has occurred and is continuing which constitutes or with the passage of time or the giving of notice, or both, would constitute a material default or event of default by the Corporation under any of the foregoing; and the execution and delivery of the Bonds and the Corporation Documents and compliance with the provisions on the Corporation's part contained therein, will not conflict with or constitute a breach of or default under any material constitutional provision, administrative regulation, judgment, decree, loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the Corporation is a party or to which the Corporation is or to which any of its property or assets are otherwise subj ect nor will any such execution, delivery, adoption or compliance result in the creation or imposition of any lien, charge or other security interest or encumbrance of any nature whatsoever upon any of the property or assets of the Corporation to be pledged to secure the Bonds or under the terms of any such law, regulation or instrument, except as provided by the Bonds and the Indentures; (e) All authorizations, approvals, licenses, permits, consents and orders of any governmental authority, legislative body, board, agency or Commission having jurisdiction of the matter which are required for the due authorization of, which would constitute a condition precedent to, or the absence of which would materially adversely affect the due performance by the Corporation of its obligations under the Corporation Documents, and the Bonds have been duly obtained, except for such approvals, consents and orders as may be required under the Blue Sky or securities laws of any jurisdiction in connection with the offering and sale of the Bonds; (f) Other than conforming date changes, the Bonds conform to the descriptions thereof contained in the Preliminary Official Statement under the captions "THE SERIES 2008 BONDS," the Indentures conform to the description thereof contained in the Preliminary Official Statement under the captions "THE SERIES 2008 BONDS," and "SUMMARY OF CERTAIN PROVISIONS OF LEGAL DOCUMENTS," the Corporation conforms to the description thereof contained in the Preliminary Official Statement under the caption "TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION," and the proceeds of the sale of the Bonds will be applied generally as described in the Preliminary Official Statement under the captions "PLAN OF REFUNDING," "SOURCES AND USES OF FUNDS" and "THE PROJECT"; (g) There is no legislation, action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, government agency, public board or body, pending or overtly threatened, against the Corporation, affecting the existence of the Corporation or the titles of its officers to their respective offices, or affecting or seeking to prohibit, restrain or enjoin the sale, issuance or delivery of the Bonds or the collection of lease payments promised for the payment of principal of and interest on the Bonds pursuant to the Indentures or in any way contesting or affecting 437619.2 the validity or enforceability of the Bonds, the Corporation Documents, or contesting the exclusion from gross income of interest on the Bonds for federal income tax purposes or State income tax purposes, or contesting in any way the completeness or accuracy of the Preliminary Official Statement or the Official Statement or any supplement or amendment thereto, or contesting the powers of the Corporation or any authority for the issuance of the Bonds, the execution and delivery of the Indentures or the execution and delivery of the Corporation Documents, nor, to the best knowledge of the Corporation, is there any basis therefore, wherein an unfavorable decision, ruling or finding would materially adversely affect the validity or enforceability of the Bonds or the Corporation Documents; (h) As of the date thereof, the Preliminary Official Statement did not contain any untrue statement of a material fact or omit to state a material fact required to be stated therein or necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading; (i) At the time of the Corporation=s acceptance hereof and (unless the Official Statement is amended or supplemented pursuant to paragraph (c) of Section 3 of this Bond Purchase Agreement) at all times subsequent thereto during the period up to and including the date of Closing, the Official Statement does not and will not contain any untrue statement of a material fact or 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; (j) If the Official Statement is supplemented or amended pursuant to paragraph (c) of Section 3 of this Bond Purchase Agreement, at the time of each supplement or amendment thereto and (unless subsequently again supplemented or amended pursuant to such paragraph) at all times subsequent thereto during the period up to and including the date of Closing the Official Statement as so supplemented or amended will not contain any untrue statement of a material factor 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 made, not misleading; (k) The Corporation will apply, or cause to be applied, the proceeds from the sale of the Bonds as provided in and subject to all of the terms and provisions of the Indentures and will not take or omit to take any action which action or omission will adversely affect the exclusion from gross income for federal income tax purposes or State income tax purposes of the interest on the Bonds; (1) The Corporation will furnish such information and execute such instruments and take such action in cooperation with the Underwriter as the Underwriter may reasonably request (A) to (1) qualify the Bonds for offer and sale under the Blue Sky or other securities laws and regulations of such states and other jurisdictions in the United States as the Underwriter may designate and (2) determine the eligibility of the Bonds for investment under the laws of such states and other jurisdictions and (B) to continue such qualifications in effect so long as required for the distribution of the Bonds (provided, however, that the Corporation 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 437619.2 any jurisdiction) and will advise the Underwriter immediately of receipt by the Corporation of any notification with respect to the suspension of the qualification of the Bonds for sale in any jurisdiction or the initiation or threat of any proceeding for that purpose; (m) Prior to the Closing the Corporation will not offer or issue any bonds, notes or other obligations for borrowed money or incur any material liabilities, direct or contingent, payable from or secured by any of the revenues or assets which will secure the Bonds without the prior approval of the Underwriter; and (n) Any certificate, signed by any official of the Corporation authorized to do so in connection with the transactions contemplated by this Bond Purchase Agreement, shall be deemed a representation and warranty by the Corporation to the Underwriter as to the statements made therein. [(o) The Corporation has designated the Bonds as "qualified tax-exempt obligations" for purposes of Section 265(b)(3) of the Code.] Closing. (a) At 8:00 a.m. MST time, on , 2008, or at such other time and date as shall have been mutually agreed upon by the Corporation and the Underwriter (the "Closing"), the Corporation will, subject to the terms and conditions hereof, deliver the Bonds to the Underwriter in the aggregate principal amount of each such maturity duly executed and authenticated, together with the other documents hereinafter mentioned, and, subject to the terms and conditions hereof, the Underwriter will accept such delivery and pay the purchase price of the Bonds asset forth in Section 1 of this Bond Purchase Agreement by a certified or bank cashier's check or checks or wire transfer payable in immediately available funds to the order of the Corporation. Payment for the Bonds as aforesaid shall be made at the offices of Bond Counsel, or such other place as shall have been mutually agreed upon by the Corporation and the Underwriter. (b) Delivery of the Bonds shall be made in New York City or at such other place to be mutually agreed upon by the Corporation and the Underwriter. The Bonds shall be delivered in definitive fully registered form, bearing CUSIP numbers without coupons, with one Bond for each maturity of the Bonds, all as provided in the Series 2008 Supplemental Indenture, and shall be made available to the Underwriter at least one business day before the Closing for purposes of inspection. 6. Closing Conditions. The Underwriter has entered into this Bond Purchase Agreement in reliance upon the representations, warranties and agreements of the Corporation contained herein, and in reliance upon the representations, warranties and agreements to be contained in the documents and instruments to be delivered at the Closing and upon the performance by the Corporation of its obligations hereunder, both as of the date hereof and as of the date of the Closing. Accordingly, the Underwriter's obligations under this Bond Purchase Agreement to purchase, to accept delivery of and to pay for the Bonds shall be conditioned upon the performance by the Corporation of its obligations to be performed hereunder and under such documents and instruments, 437619.2 and the performance by the Town of its obligations to be performed hereunder and under such documents and instruments, at or prior to the Closing, and shall also be subject to the following additional conditions, including the delivery by the Corporation and the Town of such documents as are enumerated herein, in form and substance reasonably satisfactory to the Underwriter: (a) The representations and warranties of the Corporation contained herein and of the Town in the Letter of Representation shall be true, complete and correct on the date hereof and on and as of the date of the Closing, as if made on the date of the Closing; (b) The Corporation and the Town each shall have performed and complied with all agreements and conditions required by this Bond Purchase Agreement to be performed or complied with by it prior to or at the Closing; (c) At the time of the Closing, (i) the Corporation Documents, the Town Documents and the Bonds shall be in full force and effect in the form heretofore approved by the Underwriter and shall not have been amended, modified or supplemented, and the Official Statement shall not have been supplemented or amended, except in any such case as may have been agreed to by the Underwriter; and (ii) all actions of the Corporation and of the Town required to be taken by the Corporation shall be performed in order for Bond Counsel and Underwriter's Counsel to deliver their respective opinions referred to hereafter; (d) At the time of the Closing, all official action of the Corporation relating to the Bonds and the Corporation Documents and all official action of the Town relating to the Town Documents shall be in full force and effect and shall not have been amended, modified or supplemented; (e) At or prior to the Closing, the Series 2008 Supplemental Indenture shall have been duly executed and delivered by the Corporation, the Town Documents shall have been duly executed by the Town, and the Corporation shall have duly executed and delivered and the Trustee shall have duly authenticated the Bonds; (f) At or prior to the Closing, the Bond Insurance Policy, the Reserve Fund Surety Bond and the [Financial Guaranty Agreement] shall have been duly executed, issued and delivered by the Bond Insurer; (g) At the time of the Closing, there shall not have occurred any change or any development involving a prospective change in the condition, financial or otherwise, or in the revenues or operations of the Town; from that set forth in the Official Statement that in the judgment of the Underwriter, is material and adverse and that makes it, in the judgment of the Underwriter, impracticable to market the Bonds on the terms and in the manner contemplated in the Official Statement; (h) Neither the Corporation nor the Town shall have failed to pay principal or interest when due on any of its outstanding obligations for borrowed money; 437619.2 (i) All steps to be taken and all instruments and other documents to be executed, and all other legal matters in connection with the transactions contemplated by this Bond Purchase Agreement shall be reasonably satisfactory in legal form and effect to the Underwriter; (j) At or prior to the Closing, the Underwriter shall have received copies of each of the following documents: (1) The Official Statement, and each supplement amendment thereto, if any, executed on behalf of the Corporation by its President and on behalf of the Town by its Mayor, or such other officials as may have been agreed to by the Underwriter, and the reports and audits referred to or appearing in the Official Statement; (2) The Corporation Documents and the Town Documents with such supplements or amendments as may have been agreed to by the Underwriter; (3) The approving opinion of Bond Counsel with respect to the Bonds, in substantially the form attached to the Official Statement; (4) A supplemental opinion of Bond Counsel addressed to the Underwriter, substantially to the effect that: (i) the Bonds are exempted securities under the Securities Act of 1933, as amended (the "1933 Act"), and the Trust Indenture Act of 1939, as amended (the "Trust Indenture Act") and it is not necessary, in connection with the offering and sale of the Bonds, to register the Bonds under the 1933 Act or to qualify the Indentures under the Trust Indenture Act; and (ii) the statements and information contained in the Official Statement under the captions "THE SERIES 2008 BONDS," ["QUALIFIED TAX-EXEMPT OBLIGATIONS,"] "TAX MATTERS," "ORIGINAL ISSUE DISCOUNT," "BOND PREMIUM," and Appendices D, E and F fairly and accurately summarized the matters purported to be summarized therein. (5) An opinion, dated the date of the Closing and addressed to the Underwriter, of counsel for the Underwriter; to the effect that: (i) the Bonds are exempt securities under the 1933 Act and the Trust Indenture Act and it is not necessary, in connection with the offering and sale of the Bonds, to register the Bonds under the 1933 Act and the Series 2008 Supplemental Indenture need not be qualified under the Trust Indenture Act; and (ii) based upon their participation in the preparation of the Official Statement, as counsel for the Underwriter, and their participation at conferences at which the Official Statement was discussed, but without having undertaken to determine independently the accuracy, 437619.2 completeness or fairness of the statements contained in the Official Statement, such counsel has no reason to believe that the Official Statement contains any untrue statement of a material fact or omits to state a material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading (except for any financial, forecast, technical and statistical statements and data included in the Official Statement and the information regarding the Bond Insurer, in each case as to which no view need be expressed); (6) An opinion of Counsel to the Corporation, addressed to the Underwriter, to the effect that: (i) The Corporation is a nonprofit corporation, duly created, organized and existing under the laws of the State, and has full legal right, power and authority (A) to enter into, execute and deliver the Corporation Documents, (B) to sell, issue and deliver the Bonds to the Underwriter as provided herein, and (C) to carry out and consummate the transactions contemplated by the Corporation Documents, and the Official Statement, and to the best of our knowledge, the Corporation has complied, and will at the Closing be in compliance in all material respects, with the terms of the Corporation Documents as they pertain to such transactions; (ii) By all necessary official action of the Corporation prior to or concurrently with the acceptance hereof, the Corporation has duly authorized all necessary action to be taken by it for (A) the adoption of the Series 2008 Supplemental Indenture and the issuance and sale of the Bonds, (B) the approval, execution and delivery of, and the performance by the Corporation of the obligations on its part, contained in the Bonds and the Corporation Documents, and (C) the consummation by it of all other transactions contemplated by the Official Statement and the Corporation Documents; (iii) The Bond Purchase Agreement has been duly authorized, executed and delivered by the Corporation and constitutes a legal, valid and binding obligation of the Corporation enforceable against the Corporation in accordance with its terms, except to the extent limited by bankruptcy, insolvency, reorganization, moratorium or other similar laws and equitable principles of general application relating to or affecting the enforcement of creditors' rights; (iv) The distribution of the Preliminary Official Statement and the Official Statement has been duly authorized by the Corporation; (v) All authorizations, approvals, licenses, permits, consents and orders of any governmental authority, legislative body, board, agency or commission having jurisdiction of the matter which are required for the due authorization of, which would constitute a condition precedent to, or the absence of which would materially adversely affect the due performance by the Corporation of its obligations under the Corporation Documents and the Bonds have been obtained; (vi) To the best of knowledge of the signer, there is no legislation, action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, 437619.2 government agency, public board or body, pending or affecting the corporate existence of the Corporation or the titles of its officers to their respective offices, or affecting or seeking to prohibit, restrain or enjoin the sale, issuance or delivery of the Bonds or the collection of taxes securing the payment of principal of and interest on the Bonds pursuant to the indentures or in any way contesting or affecting the validity or enforceability of the Bonds, the Corporation Documents, or contesting the exclusion from gross income of interest on the Bonds for federal income tax purposes or State income tax purposes, or contesting in any way the completeness or accuracy of the Preliminary Official Statement or the Official Statement or any supplement or amendment thereto, or contesting the powers of the Corporation or any authority for the issuance of the Bonds, the adoption of the Supplemental Indenture or the execution and delivery of the Corporation Documents, wherein an unfavorable decision, ruling or finding would materially adversely affect the validity or enforceability of the Bonds or the Corporation Documents; (vii) To the best of knowledge of the signer, the statements and information contained in the Official Statement under the caption "TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION" fairly and accurately summarized the matters purported to be summarized therein; and (viii) To the best of the knowledge of the signer, the execution and delivery of the Corporation Documents and compliance by the Corporation with the provisions hereof and thereof, under the circumstances contemplated herein and therein, will not conflict with or constitute on the part of the Corporation a material breach of or a default under any agreement or instrument to which the Corporation is a party, or violate any existing law, administrative regulation, court order, or consent decree to which the Corporation is subject. (7) An opinion of Counsel to the Town, addressed to the Underwriter, to the effect that: (i) The Town is a municipal corporation, duly created, organized and existing under the laws of the State, and has full legal right; power and authority (A) to enter into, execute and deliver the Town Documents and (B) to carry out and consummate the transactions contemplated by the Town Documents, and the Official Statement, and the Town has complied, and will at Closing be in compliance in all respects, with the terms of the Town Documents as they pertain to such transactions; (ii) By all necessary official action of the Town prior to or concurrently with the acceptance hereof, the Town has duly authorized all necessary action to be taken by it for (A) the approval execution and delivery of, and performance by the Town of the obligations on its part contained in the Town Documents, and (B) the consummation by it of all of the transactions contemplated by the Town Documents, the Official Statement and any and all such other agreements and documents as maybe required to be executed, delivered and/or received by the Town in order to carry out, give effect to, and consummate the transactions contemplated herein and in the Official Statement; 437619.2 (iii) All actions necessary to levy and collect taxes securing the payment of principal and interest on the Bonds have been duly and validly adopted or undertaken in compliance with all applicable. procedural requirements of the Town and in compliance with the Constitution and laws of the State; (iv) The Town Documents have been duly authorized, executed and delivered by the Town and constitute legal, valid and binding obligations of the Town enforceable against the Town in accordance with their respective terms, except to the extent limited by bankruptcy, insolvency, reorganization, moratorium or other similar laws and equitable principles of general application relating to or affecting the enforcement of creditors' rights; (v) The distribution of the Preliminary Official Statement and the Official Statement has been duly authorized by the Town; (vi) All authorizations, approvals, licenses, permits, consents and orders of any governmental authority, legislative body, board, agency or commission having jurisdiction of the matter which are required for the due authorization of, which would constitute a condition precedent to, or the absence of which would materially adversely affect the due performance by the Town of its obligations under the Town Documents have been obtained; (vii) There is no legislation, action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, government agency, public board or body, pending or, to the best knowledge of the signer, after due inquiry threatened, against the Town or affecting the titles of its officers to their respective offices, or affecting or seeking to prohibit, restrain or enjoin the sale, issuance or delivery of the Bonds or the collection of taxes securing the payment of principal of and interest on the Bonds pursuant to the Indentures or in any way contesting or affecting the validity or enforceability of the Bonds, the Town Documents, or contesting the exclusion from gross income of interest on the Bonds for federal income tax purposes or State income tax purposes, or contesting in any way the completeness or accuracy of the Preliminary Official Statement or the Official Statement or any supplement or amendment thereto, or contesting the power of the Town to execute and deliver the Town Documents, nor, to the best knowledge of the signer, is there any basis therefore, wherein an unfavorable decision, raking or finding would materially adversely affect the validity or enforceability of the Town Documents; and (viii) The execution and delivery of the Town Documents and compliance by the Town with the provisions thereof, under the circumstances contemplated therein, will not conflict with or constitute on the part of the Town a material breach or a default under any agreement or instrument to which the Town is a party, or violate any existing law, administrative regulation, court order, or consent decree to which the Town is subject. (8) A certificate, dated the date of Closing, of the appropriate officers of the Corporation to the effect that to the best of their knowledge (i) the representations and warranties of the Corporation contained herein are true and correct in all material respects on and as of the date of Closing as if made on the date of Closing; (ii) no litigation or proceeding or tax challenge against 437619.2 it is pending or overtly threatened in any court or administrative body nor is there a basis for litigation which would (a) contest the right of the directors or officers of the Corporation to hold and exercise their respective positions, (b) contest the due organization and valid existence of the Corporation, (c) contest the validity, due authorization and execution of the Bonds or the Corporation Documents or (d) attempt to limit, enjoin or otherwise restrict or prevent the Corporation from functioning and collecting payments under the Fourth Supplemental Town Lease, and other income; (iii) the resolutions of the Corporation authorizing the execution, delivery and/or performance of the Official Statement, the Bonds and Corporation Documents have been duly adopted by the Corporation, are in full force and effect-and have not been modified, amended or repealed, and (iv) no event affecting the Corporation has occurred since the date of the Official Statement which should be disclosed in the Official Statement for the purpose for which it is to be used or which it is necessary to disclose therein in order to make the statements and information therein, in light of the circumstances under which made, not misleading in any respect as of the time of Closing, and the information contained in the Official Statement is correct in all material respects and, as of the date of the Official Statement did not, and as of the date of the Closing does not, contain any untrue statement of a material fact or omit to state 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; (9) A certificate, dated the date of Closing, of the appropriate official of the Town to the effect that to the best of their knowledge (i) no litigation or proceeding against it is pending or overtly threatened in any court or administrative body nor is there a basis for litigation which would (a) contest the right of the officials of the Town to hold and exercise their respective positions, (b) contes the due organization and valid existence of the Town, (c) contest the validity, due authorization and execution of the Town Documents, or (d) attempt to limit, enjoin or otherwise restrict or prevent the Town from functioning and collecting revenues, including the collection of the taxes securing the payment of the principal of and interest on the Bonds; (ii) the resolutions of the Town authorizing the execution, delivery and/or performance of the Town Documents have been duly adopted by the Town, are in full force and effect and have not been modified, amended or repealed, and (iii) no event affecting the Town has occurred since the date of the Official Statement which should be disclosed in the Official Statement for the purposes for which it is to be used or which is necessary to disclose therein in order to make the statements and information therein, in light of the circumstances under which they were made, not misleading in any respect as of the time of Closing, and the information contained in the Official Statement is correct in all material respects and, as of the date of the Official Statement did not, and as of the date of the Closing does not, contain any untrue statement of a material fact or omit to state 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; (10) A certificate of the Trustee/Escrow Trustee to the effect that (i) the Bonds have been duly authenticated by an authorized officer of the Trustee; (ii) the Series 2008 Supplemental Indenture and the Escrow Trust Agreement have been duly executed and delivered by an authorized officer of the Trustee and the Escrow Trustee, respectively; and (iii) the resolutions of the Trustee/Escrow Trustee authorizing the execution and delivery and/or performance of the 437619.2 Supplemental Indenture and the Escrow Trust Agreement by the Trustee and the Escrow Trustee, respectively, have been duly adopted by the Trustee and the Escrow Trustee, respectively, are in full force and effect and have not been modified, amended or repealed; (11) Any other certificates and opinions required by the Indentures for the issuance thereunder of the Bonds; (12) Such additional legal opinions, certificates, instruments and other documents as the Underwriter or counsel to the Underwriter may reasonably request to evidence the truth and accuracy, as of the date hereof and as of the date of the Closing, of the Corporation's representations and warranties contained herein and of the Town's representationsand warranties in the Letter of Representation and of the statements and information contained in the Official Statement and the due performance or satisfaction by the Corporation and the Town on or prior to the date of the Closing of all the respective agreements then to be performed and conditions then to be satisfied by the Corporation and the Town, respectively; (13) A copy of the Bond Insurance Policy and the Surety Bond, together with an opinion of counsel to the Bond Insurer in form and substance satisfactory to the Underwriter; and (14) A certificate of Bond Insurer with respect to the accuracy of statements contained in the Official Statement regarding the Surety Bond, the Bond Insurance Policy and Bond Insurer and the due authorization, execution, issuance and delivery of the Surety Bond and the Bond Insurance Policy. All of the opinions, letters, certificates, instruments and other documents mentioned above or elsewhere in this Bond Purchase Agreement shall be deemed to be in compliance with the provisions hereof if, but only if, they are in form and substance satisfactory to the Underwriter. If the Corporation shall be unable to satisfy the conditions to the obligations of the Underwriter to purchase, to accept delivery of and to pay for the Bonds contained in this Bond Purchase Agreement, or if the obligations of the Underwriter to purchase, to accept delivery of and to pay for the Bonds shall be terminated for any reason permitted by this Bond Purchase Agreement, this Bond Purchase Agreement shall terminate and neither the Underwriter or the Corporation, shall be under any further obligation hereunder. 7. Termination. The Underwriter shall have the right to cancel its obligation to purchase the Bonds if, between the date of this Bond Purchase Agreement and the Closing, the market price or marketability of the Bonds shall be materially adversely affected, in the sole judgment of the Underwriter, by the occurrence of any of the following: (a) legislation shall be enacted by or introduced in the Congress of the United States or recommended to the Congress for passage by the President of the United States, or the Treasury Department of the United States or the Internal Revenue Service or any member of the 437619.2 Congress or the Arizona Legislature or favorably reported for passage to either House of the Congress by any committee of such House to which such legislation has been referred for consideration, a decision by a court of the United States or of the State or the United States Tax Court shall be rendered, or an order, ruling, regulation (final, temporary or proposed), press release, statement or other form of notice by or on behalf of the Treasury Department of the United States, the Internal Revenue Service or other governmental agency shall be made or proposed, the effect of any or all of which would be to impose, directly or indirectly, federal income taxation or State income taxation upon interest received on obligations of the general character of the Bonds or, with respect to State taxation, of the interest on the Bonds as described in the Official Statement, or other action or events shall have transpired which may have the purpose or effect, directly or indirectly, of changing the federal income tax consequences or State income tax consequences of any of the transactions contemplated herein; (b) legislation introduced in or enacted (or resolution passed) by the Congress or an order, decree, or injunction issued by any court of competent jurisdiction, or an order, ruling, regulation (final, temporary, or proposed), press release or other form of notice issued or made by or on behalf of the Securities and Exchange Commission, or any other governmental agency having jurisdiction of the subject matter, to the effect that obligations of the general character of the Bonds, including any or all underlying arrangements, are not exempt from registration under or other requirements of the 1933 Act, or that the Indentures are not exempt from qualification under or other requirements of the Trust Indenture Act, or that the issuance, offering, or sale of obligations of the general character of the Bonds, including any or all underlying arrangements, as contemplated hereby or by the Official Statement or otherwise, is or would be in violation of the federal securities law as amended and then in effect; (c) any state blue sky or securities commission or other governmental agency or body shall have withheld registration, exemption or clearance of the offering of the Bonds as described herein, or issued a stop order or similar ruling relating thereto; (d) a general suspension of trading in securities on the New York Stock Exchange or the American Stock Exchange, the establishment of minimum prices on either such exchange, the establishment of material restriction (not in force as of the date hereof) upon trading securities generally by any governmental authority or any national securities exchange, a general banking moratorium declared by federal, State of New York, or State officials authorized to do so; (e) the New York Stock Exchange or other national securities exchange or any governmental authority, shall impose, as to the Bonds or as to obligations of the general character of the Bonds, any material restrictions not now in force, or increase materially those now in force, with respect to the extension of credit by, or the charge to the net capital requirements of, underwriters; (f) any amendment to the federal or state Constitution or action by any federal or state court, legislative body, regulatory body, or other authority materially adversely affecting the tax status of the Corporation; its property, income securities (or interest thereon), or the validity or enforceability of the assessments or the levy of taxes to pay principal of and interest on the Bonds; 437619.2 (g) any event occurring, or information becoming known which, in the judgment of the Underwriter, makes untrue in any material respect any statement or information contained in the Official Statement, or has the effect that the Official Statement contains any untrue statement of material fact or omits to state a material fact required to be stated therein or necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading; (h) there shall have occurred since the date of this Bond Purchase Agreement any materially adverse change in the affairs or financial condition of the Corporation or the Town; (i) the United States shall have become engaged in hostilities which have resulted in a declaration of war or a national emergency or there shall have occurred any other outbreak or escalation of hostilities or a national or international calamity or crisis, financial or otherwise; (j) any fact or event shall exist or have existed that, in the Underwriter's judgment, requires or has required an amendment of or supplement to the Official Statement; (k) there shall have occurred any downgrading, or any notice shall have been given of (A) any intended or potential downgrading or (B) any review or possible change that does not indicate a possible upgrade, in the rating accorded any of the Corporation's obligations; or (1) the purchase of and payment for the Bonds by the Underwriter, or the resale of the Bonds by the Underwriter, on the terms and conditions herein provided shall be prohibited by any applicable law, governmental authority, board, agency or commission. 8. Expenses. (a) The Underwriter shall be under no obligation to pay, and the Corporation shall pay, but solely from the proceeds of the sale of the Bonds, any expenses incident to the performance of the Corporation's obligations hereunder, including, but not limited to (i) the cost of preparation and printing of the Bonds, the Preliminary Official Statement and the Official Statement, (ii) the fees and disbursements of Bond Counsel, counsel to the Corporation, Underwriter's Counsel, counsel to the Town, the Trustee and the Escrow Trustee; (iii) the fees and disbursements of any other engineers, accountants, and other experts, consultants or advisers retained by the Corporation; and (iv) the fees associated with obtaining or receiving the bond ratings and any and all credit enhancement fees or premiums. (b) The Underwriter shall pay (i) all advertising expenses in connection with the public offering of the Bonds; and (ii) all other expenses incurred by them in connection with the public offering of the Bonds. (c) If this Bond Purchase Agreement shall be terminated by the Underwriter because of any failure or refusal on the part of the Corporation to comply with the terms of this Bond Purchase Agreement, the Corporation will reimburse the Underwriter for all out-of-pocket expenses 437619.2 (including the fees and disbursements of counsel to the Underwriter) reasonably incurred by the Underwriter in connection with this Bond Purchase Agreement or the offering contemplated hereunder from funds legally available to it for such purpose. 9. Notices. Any notice or other communication to be given to the Corporation under this Bond Purchase Agreement maybe given by delivering the same in writing to: Town of Marana Municipal Property Corporation 11555 W. Civic Center Drive Marana, Arizona 85653 Attention: and any notice or other communication to be given to the Underwriter under this Bond Purchase Agreement maybe given by delivering the same in writing to: Stone & Youngberg LLC 2555 East Camelback Road, Suite 280 Phoenix, Arizona 85016 Attention: Mr. B. Mark Reader 10. Parties in Interest. This Bond Purchase Agreement as heretofore specified shall constitute the entire agreement between us and is made solely for the benefit of the Corporation, the Town and the Underwriter (including successors or assigns of the Underwriter) and no other person shall acquire or have any right hereunder or by virtue hereof this Bond Purchase Agreement may not be assigned by the Corporation. All of the Corporation's representations, warranties and agreements contained in this Bond Purchase Agreement shall remain operative and in full force and effect, regardless of (i) any investigations made by or on behalf of any of the Underwriter; (ii) delivery of and payment for the Bonds pursuant to this Bond Purchase Agreement; and (iii) any termination of this Bond Purchase Agreement. 11. Effectiveness. This Bond Purchase Agreement shall become effective upon the acceptance hereof by the Corporation and shall be valid and enforceable at the time of such acceptance. 12. Choice of Law. This Bond Purchase Agreement shall be governed by and construed in accordance with the law of the State. 13. Severability. If any provision of this Bond Purchase Agreement shall be held or deemed to be or shall, in fact, be invalid, inoperative or unenforceable as applied in any particular casein any jurisdiction or jurisdictions, or in all jurisdictions because it conflicts with any provisions of any Constitution, statute, rule of public policy or any other reason, such circumstances shall not have the effect of rendering the provision in question invalid, inoperative or unenforceable in any 437619.2 other case or circumstance, or of rendering any other provision or provisions of this Bond Purchase Agreement invalid, inoperative or unenforceable to any extent whatever. 14. Business Day. For purposes of this Bond Purchase Agreement, "business day" means any day on which the New York Stock Exchange is open for trading. 15. Section Headings. Section headings have been inserted in this Bond Purchase Agreement as a matter of convenience of reference only and it is agreed that such section headings are not a part of this Bond Purchase Agreement and will not be used in the interpretation of any provisions of this Bond Purchase Agreement. 16. Counterparts. This Bond Purchase Agreement may be executed in several counterparts each of which shall be regarded as an original (with the same effect as if the signatures thereto and hereto were upon the same document) and all. of which shall constitute one and the same document. 17. Cancellation of Bond Purchase Agreements. As required by the provisions of Arizona Revised Statutes Section 38-511, as amended, notice is hereby given that the State, its political subdivisions (including the Corporation) or any department or agency of either may, within three years after its execution, cancel any contract, without penalty or further obligation, made by the State, its political subdivisions, or any of the departments or agencies of either if any person significantly involved in initiating, negotiating, securing, drafting or creating the contract on behalf of the State, its political subdivisions, or any of the departments or agencies of either is, at any time while the contract or any extension of the contract is in effect, an employee or agent of any other party to the contract in any capacity or a consultant to any other party of the contract with respect to the subject matter of the contract. The cancellation shall be effective when written notice from the Governor or the chief executive officer or governing body of the political subdivision is received by all other parties to the contract unless the notice specifies a later time. The State, its political subdivisions or any department or agency of either may recoup any fee or commission paid or due to any person significantly involved in initiating negotiating, securing, drafting or creating the contract on behalf of the State, its political subdivisions or any department or agency of either from any other party to the contract arising as the result of the contract. This section is not intended to expand or enlarge the rights of the Corporation hereunder except as required by such Section 38-511. Each of the parties hereto hereby certifies that it is not presently aware of any violation of Section 38-511 which would adversely affect the enforceability of this Bond Purchase Agreement and covenants that it shall take no action which would result in a violation of such Section. [Signature Pages to Follow] 437619.2 If you agree with the foregoing, please sign the enclosed counterpart of this Bond Purchase Agreement and return it to the Underwriter. This Bond Purchase Agreement shall become a binding agreement between you and the Underwriter when at least the counterpart of this letter shall have been signed by or on behalf of each of the parties hereto and the Letter of Representation shall have been signed on behalf of the Town. Very truly yours, STONE & YOUNGBERG LLC By Mark Reader Managing Director Accepted and confirmed as of the date first above written. TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION By Name: Title: 437619.2 SCHEDULE I TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION MUNICIPAL FACILITIES REVENUE BONDS, SERIES 2008 MATURITY SCHEDULE Municipal Facilities Revenue Bonds, Series 2008A The Series 2008A Bonds mature on January 1 and July 1 in the years and amounts and bear interest at the following per annum rates: Principal Interest Maturity Date Amount Rate Yield Optional Redemption of Series 2008A Bonds: The Series 2008A Bonds maturing on or after 1, 20_, will be subject to redemption, at the option of the Corporation, acting at the request of the Town, in whole at any time, or in part, on any interest Payment Date, in any order of maturity requested by the Town and by lot within a maturity, on 1, 20_, or on any interest payment date thereafter by the payment of a redemption price equal to the principal amount of each Series 2008A Bond called for redemption plus accrued interest to the date fixed for redemption but without premium. Mandatory Redemption of Series 2008A Bonds: The Series 2008A Bonds maturing on 1, 20_, are subject to mandatory sinking fund redemption on the following dates and in the following amounts at a price equal to the principal amount thereof plus interest accrued to the date of redemption, but without premium: Principal Redemption Date Amount 437619.2 Municipal Facilities Revenue Bonds, Series 2008B The Series 2008B Bonds mature on January 1 and July 1 in the years and amounts and bear interest at the following per annum rates: Principal Interest Maturi . Date Amount Rate Yield Optional Redemption of Series 2008B Bonds: The Series 2008B Bonds maturing on or after 1, 20_, will be subject to redemption, at the option of the Corporation, acting at the request of the Town, in whole at any time, or in part, on any interest Payment Date, in any order of maturity requested by the Town and by lot within a maturity, on I, 20_, or on any interest payment date thereafter by the payment of a redemption price equal to the principal amount of each Series 2008B Bond called for redemption plus accrued interest to the date fixed for redemption but without premium. 43'7619.2 EXHIBIT A TOWN OF MARANA MUNICIPAL PROPERTY CORPORATION MUNICIPAL FACILITIES REVENUE BONDS, SERIES 2008 Municipal Facilities Revenue Bonds, Series 2008A Municipal Facilities Revenue Bonds, Series 2008B Letter of Representation of the Town of Marana, Arizona 2008 Town of Marana Municipal Property Corporation Marana, Arizona Stone & Youngberg LLC Phoenix, Arizona Ladies and Gentlemen; The Town of Marana Municipal Property Corporation (the "Corporation") and the Town of Marana, Arizona (the "Town") propose to enter into a Fourth Supplement to Amended and Restated Town Lease and Series 1992 Town Lease (the "Fourth Supplemental Town Lease"), to be dated as of 2008. Pursuant to a Bond Purchase Agreement, dated , 2008 (the "Bond Purchase Agreement"),between Stone & Youngberg LLC (the "Underwriter") and the Corporation, the Corporation proposes to issue $ aggregate principal amount of its Municipal Facilities Revenue Bonds, Series 2008A (the "Series 2008A Bonds") and the Corporation's Municipal Facilities Revenue Bonds, Series 2008B (the "Series 2008E Bonds," and together with the Series 2008A Bonds, the "Bonds"). The Bonds will be issued and secured pursuant to a Trust Indenture, dated as of October 1, 1997 (the "Indenture"), as supplemented by (1) a Series 2003 Supplemental Trust Indenture, dated as of September 1, 2003 (the "Series 2003 Supplemental Indenture "), (2) a Series 2004 Supplemental Trust Indenture, dated as of Julyl, 2004 (the "Series 2004 Supplemental Indenture"), and (3) a Series 2008 Supplemental Trust Indenture, dated as of 2008 (the "Series 2008 Supplemental Indenture") (the Indenture, the Series 2003 Supplemental Indenture, the Series 2004 Supplemental Indenture, and Series 2008 Supplemental Indenture are collectively referred to herein as the "Indentures"),between the Corporation and Wells Fargo Bank, National Association (successor to Norwest Bank Arizona, N.A.), as trustee (together with its successors, if any, as trustee under the Indentures, the "Trustee. "), pursuant to which certain of the Corporation's rights under the Fourth Supplemental Town Lease will be assigned to the 437619.2 Trustee to pay, when due, the principal of and interest on the Bonds. The Bonds and the security therefore are more fully described in the Official Statement of the Corporation, dated the date of this Letter of Representation (the "Official Statement"). The Corporation and the Town will execute and deliver tax certificates (together, the "Tax Agreement") regarding exclusion of interest on the Bonds from gross income for income tax purposes. The Town will enter into and deliver a written undertaking (the "Continuing Disclosure Undertaking") to provide, or cause to be provided, ongoing disclosure for the benefit of the owners of the Bonds as described in the Continuing Disclosure Undertaking for purposes of Rule 15c2-12 promulgated under the Securities Exchange Act of 1934 (the "Disclosure Rule"). This Letter of Representation, the Fourth Supplemental Town Lease, the Tax Agreement and the Continuing, Disclosure undertaking are referred to as the "Town Documents." All capitalized terms used herein and not otherwise defined herein shall have the meanings ascribed to such words and terms in the Bond Purchase Agreement. In order to induce the Corporation and the Underwriter to enter into the Bond Purchase Agreement and to make the offering and sale of the Bonds therein contemplated, the undersigned, on behalf of the Town but not individually, hereby represents, warrants and agrees with the Corporation and Underwriter as follows: 1 . The Town is a political subdivision of the State of Arizona (the "State"), and is validly existing as a municipal corporation duly created, organized and existing under the laws of the State, specifically Title 9, Chapter 1, Article 1, of the Arizona Revised Statutes, as amended and supplemented, and has full legal right, power and authority, and at the date of the Closing will have full legal right, power and authority (i) to enter into, execute and deliver the Town Documents, and (ii) to carry out and consummate the transactions contemplated by the Town Documents and the Preliminary Official Statement, and the Town has complied, and will at the Closing be in compliance in all respects, with the terms of the Town Documents as they pertain to such transactions. 2. By all necessary official action of the Town prior to or concurrently with the acceptance hereof, the Town has duly authorized all necessary action to be taken by it for (i) the approval, execution and delivery of, and the performance by the Town of the obligations on its part, contained in the Town Documents and (ii) the consummation by it of all other transactions contemplated by the Preliminary Official Statement, the Town Documents, and any and all such other agreements and documents as may be required to be executed, delivered and/or received by the Town in order to carry out, give effect to, and consummate the transactions contemplated herein and in the Official Statement. 3. The Town Documents constitute legal, valid and binding obligations of the Town, enforceable in accordance with their respective terms, subject to bankruptcy, insolvency, reorganization, moratorium and other similar laws and principles of equity relating to or affecting the enforcement of creditors' rights. 4. The Town is not in breach of or default in any material respect under any applicable constitutional provision, law or administrative regulation of the State or the United States or any applicable judgment or decree or any loan agreement, indenture, bond, note, resolution, agreement or 437619.2 other instrument to which the Town is a party or to which the Town is or any of its property or assets are otherwise subject, and no event has occurred and is continuing which constitutes or with the passage of time or the giving of notice, or both, would constitute a material default or event of default by the Town under any of the foregoing; and the execution and delivery of the Town Documents and compliance with the provisions on the Town's part contained therein, will not conflict with or constitute a breach of or default under any material constitutional provision, administrative regulation, judgment, decree, loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the Town is a party or to which the Town is or to which any of its property or assets are otherwise subject nor will any such execution, delivery, adoption or compliance result in the creation or imposition of any lien, charge or other security interest or encumbrance of any nature whatsoever upon any of the property or assets of the Town securing the Bonds or under the terms of any such law, regulation or instrument. 5. All authorizations, approvals, licenses, permits, consents and orders of any governmental authority, legislative body, board, agency or commission having jurisdiction of the matter which are required for the due authorization of, which would constitute a condition precedent to, or the absence of which would materially adversely affect the due performance by the Town of its obligations under the Town Documents have been duly obtained. 6. There is no legislation, action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, government agency, public board or body, pending or overtly threatened, against the Town, affecting the existence of the Town or the titles of its officers to their respective offices, or affecting or seeking to prohibit, restrain or enjoin the collection of excise taxes (or other fees, fines and forfeitures) securing the payment of principal of and interest on the Bonds pursuant to the Indentures or in any way contesting or affecting the validity or enforceability of the Town Documents, or contesting in any way the completeness or accuracy of the Preliminary Official Statement or the Official Statement or any supplement or amendment thereto, or contesting the powers of the Town or any authority for the execution and delivery of the Town Documents, nor, to the best knowledge of the Town, is there any basis therefore, wherein an unfavorable decision, ruling or finding would materially adversely affect the validity or enforceability of the Town Documents. 7. As of the date thereof, the Preliminary Official Statement did not contain any untrue statement of a material fact or omit to state a material fact required to be stated therein or necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading. 8. At the time of the Underwriter's acceptance hereof and (unless the Official Statement is amended or supplemented pursuant to paragraph (c) of Section 3 of the Bond Purchase Agreement) at all times subsequent thereto during the period up to and including the date of Closing, the Official Statement does not and will not contain any untrue statement of a material fact or omit to start 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. 9. If the Official Statement is supplemented or amended pursuant to paragraph (c) of 437619.2 Section 3 of the Bond Purchase Agreement, at the time of each supplement or amendment thereto and (unless subsequently again supplemented or amended pursuant to such paragraph) at all times subsequent thereto during the period up to and including the date of Closing the Official Statement as so supplemented or amended will not contain any untrue statement of a material fact or 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 made, not misleading. 10. The financial statements of, and other financial information regarding the Town, in the Official Statement fairly present the financial position and results of the Town as of the dates and for the periods therein set forth. Prior to the Closing, there will be no adverse change of a material nature in such financial position, results of operations or condition, financial or otherwise, of the Town, and the Town is not a party to any litigation or other proceeding pending or threatened which, if decided adversely to the Town, would have a materially adverse effect on the financial condition of the Town. 11. The statements and information contained in the Official Statement under the captions "EXCISE TAXES" and "TOWN GENERAL FUND" as well as Exhibits A, B and C fairly and accurately, summarized the matters purported to be summarized therein. 12. Any certificate, signed by any official of the Town authorized to do so in connection with the transactions contemplated by this Letter of Representation, shall be deemed a representation and warranty by the Town to the Underwriter as to the statements made therein. 13. The Town hereby authorizes the use of the Official Statement, including all amendments and supplements thereto, by the Underwriter in connection with the public offering and sale of the Bonds, ratifies and consents to the use by the Underwriter prior to the date hereof of the Preliminary Official Statement in connection with the public offering and sale of the Bonds and agrees to cause reasonable quantities of the Official Statement to be delivered to the Underwriter, without, charge, within seven (7) business days of the date hereof, provided that at least one copy of the Official Statement will be materially executed on behalf of the Town by. an authorized officer. 14. By its execution hereof, the Town hereby deems the Preliminary Official Statement final for the purposes and within the meaning of the Disclosure Rule, except for information permitted to be omitted therefrom by the Disclosure Rule, provided, however, that the foregoing does not include a representation as to the finality of the statements and information contained in such form of the Preliminary Official Statement concerning the Corporation. 15. As required by the provisions of A.R.S. § 38-511, as amended, notice is hereby given of that statute. [ 16. The Town has designated the Bonds as "qualified tax-exempt obligations" for purposes of Section 265(b)(3) of the Code and has certified that it reasonably anticipates that the aggregate amount of qualified tax-exempt obligations (as defined in Section 265(b)(3) of the Code) that will be issued by or on behalf of the Town in calendar year 2008 will not exceed $10,000,000.] 437619.2 The representations, warranties and agreements contained herein shall survive the Closing Date under the Bond Purchase Agreement and any investigation made by or on behalf of the Underwriter or any person who controls (as aforesaid) the Underwriter of any matters described in or related to the transactions contemplated hereby and by the Bond Purchase Agreement and the Official Statement. This Letter of Representation shall be binding upon and inure solely to the benefit of the Corporation, the Underwriter, and the Town and, to the extent set forth herein, persons controlling the Corporation, the Underwriter, or the Town, and their respective personal representatives, successors, assigns, and no other person or firm shall acquire or have any right under or by virtue of this Letter of Representation. No recourse under or upon any obligation, covenant or agreement contained in This Letter of Representation shall be had against any officer of the Town as an individual. If the foregoing is in accordance with your understanding of the agreement between us kindly sign and deliver this Letter of Representation whereupon this will constitute a binding agreement among the Town, the Corporation and the Underwriter in accordance with the terms hereof. Very truly yours, ATTEST: Title Accepted and confirmed as of the date first above written. STONE & YOUNGBERG LLC By Name Title TOWN OF MARANA, ARIZONA By: _ Name: Title: 437619.2