HomeMy WebLinkAboutPZ - Operating Agreement (Franklin Mile Managers) - executed (1) DocuSign Envelope ID: BBE03710-2564-432C-B4C6-8DCED24D51D8
THE SECURITIES REPRESENTED BY THIS AGREEMENT HAVE NOT BEEN
REGISTERED UNDER THE SECURITIES ACT OF 1933 NOR REGISTERED NOR
QUALIFIED UNDER ANY STATE SECURITIES LAWS. SUCH SECURITIES MAY
NOT BE OFFERED FOR SALE, SOLD, DELIVERED AFTER SALE, TRANSFERRED,
PLEDGED, OR HYPOTHECATED UNLESS QUALIFIED AND REGISTERED UNDER
APPLICABLE STATE AND FEDERAL SECURITIES LAWS OR UNLESS, IN THE
OPINION OF COUNSEL SATISFACTORY TO THE COMPANY, SUCH
QUALIFICATION AND REGISTRATION IS NOT REQUIRED. ANY TRANSFER OF
THE SECURITIES REPRESENTED BY THIS AGREEMENT IS FURTHER SUBJECT
TO OTHER RESTRICTIONS, TERMS AND CONDITIONS WHICH ARE SET FORTH
HEREIN.
THE SECURITIES REPRESENTED HEREBY HAVE BEEN ISSUED PURSUANT TO
AN EXEMPTION FROM REGISTRATION UNDER THE SECURITIES ACT OF 1933
AND ARE NOT REGISTERED THEREUNDER. IT IS UNLAWFUL TO CONSUMMATE
A SALE OR TRANSFER OF THESE SECURITIES, OR ANY INTEREST THEREIN, OR
TO RECEIVE ANY CONSIDERATION THEREFOR, EXCEPT PURSUANT TO A
REGISTRATION STATEMENT DULY FILED WITH THE UNITED STATES
SECURITIES AND EXCHANGE COMMISSION, UNLESS AN APPLICABLE
EXEMPTION FROM SUCH REGISTRATION IS AVAILABLE.
OPERATING AGREEMENT
Franklin Mile Managers, LLC
This OPERATING AGREEMENT ("Agreement") effective as of March 8th, 2021 ,
is by and among Sunny Cove, LLC, a California limited liability company ("Manager")
and each of the signatories hereto (collectively, the "Members.")
RECITALS
A. On March 8th, 2021, Articles of Organization ("Articles") for Franklin Mile
Managers, LLC (the "Company"), a limited liability company under the laws of the State
of Idaho, were filed with the Idaho Secretary of State.
B. The parties now desire to adopt and approve an operating agreement for
the Company.
AGREEMENT
NOW, THEREFORE, by this Agreement, the Members set forth the operating
agreement for the Company under the laws of the State of Idaho upon the terms and
subject to the conditions of this Agreement.
1. DEFINITIONS. When used in this Agreement, the following terms shall have the
meanings set forth below (all terms used in this Agreement that are not defined in this
Section 1 shall have the meanings set forth elsewhere in this Agreement):
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1.1 "Act" means the California Revised Uniform Limited Liability Company
Act, Title 30, Chapter 25 et seq., as the same may be amended from time to time.
1.2 "Affiliate" means any individual, partnership, corporation, trust or other
entity or association, directly or indirectly, through one or more intermediaries,
controlling, controlled by, or under common control with the Member. The term
"control," as used in the immediately preceding sentence, means, with respect to a
corporation or limited liability company the right to exercise, directly or indirectly, more
than fifty percent (50%) of the voting rights attributable to the controlled corporation or
limited liability company, and, with respect to any individual, partnership, trust, other
entity or association, the possession, directly or indirectly, of the power to direct or
cause the direction of the management or policies of the controlled entity.
1.3 "Agreement" means this Operating Agreement, as originally executed
and as amended from time to time.
1.4 "Assignee" means a person who has acquired a Member's Economic
Transferable Interest in the Company, by way of a Transfer in accordance with the
terms of this Agreement, but who has not become a Member.
1.5 "Articles" means the Articles of Organization for the Company originally
filed with the Idaho Secretary of State and as amended from time to time.
1.6 "Bankruptcy" means: (a) the filing of an application by a Member for, or
such Member's consent to, the appointment of a trustee, receiver, or custodian of such
Member's other assets; (b) the entry of an order for relief with respect to a Member in
proceedings under the United States Bankruptcy Code, as amended or superseded
from time to time; (c) the making by a Member of a general assignment for the benefit of
creditors; (d) the entry of an order, judgment, or decree by any court of competent
jurisdiction appointing a trustee, receiver, or custodian of the assets of a Member unless
the proceedings and the person appointed are dismissed within ninety (90) days; or (e)
the failure by a Member generally to pay such Member's debts as the debts become
due within the meaning of Section 303(h)(1) of the United States Bankruptcy Code, as
determined by the Bankruptcy Court, or the admission in writing of such Member's
inability to pay such Member's debts as they become due.
1.7 "Capital Account" means with respect to any Member the capital
account that the Company establishes and maintains for such Member pursuant to
Section 3.5 below.
1.8 "Capital Contribution" means the total value of cash and fair market
value of property (including promissory notes or other obligation to contribute cash or
property) contributed and/or services rendered or to be rendered to the Company by
Members.
1.9 "Code" means the Internal Revenue Code of 1986, as amended from
time to time, the provisions of succeeding law, and to the extent applicable, the
Regulations.
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1.10 "Company" means Franklin Mile Managers, LLC, a California limited
liability company.
1.11 "Company Minimum Gain" shall have the meaning ascribed to the term
"Partnership Minimum Gain" in the Regulations Section 1.704-2(d).
1.12 [Intentionally Omitted].
1.13 "Dissolution Event" means the termination, Bankruptcy, dissolution or
occurrence of any other event that terminates the continued membership of any
Member unless the other Members consent to continue the business of the Company
pursuant to Section 10.1 below.
1.14 "Distributable Cash" means the amount of cash that the Manager
deems available for distribution to the Members, taking into account all Company debts,
liabilities, and obligations of the Company then due and amounts which the Manager
deems necessary to place into Reserves.
1.15 "Fiscal Year" means the Company's fiscal year, which shall be the
calendar year.
1.16 "Financial Difficulty" means the institution of any proceeding under
federal or state laws for relief of debtors, including filing of a voluntary or involuntary
petition in bankruptcy or the adjudication as insolvent or bankrupt, the assignment of a
Member's property for the benefit of creditors, the appointment of a receiver of a
substantial portion of a Member's assets or the seizure by a sheriff or receiver of a
substantial portion of a Member's assets, and the failure, in the case of any of these
events, to obtain the dismissal of the proceeding or removal of the receiver within ninety
(90) days of the event. If any or all of the Percentage Interest of any Member is
disposed of under an encumbrance, lien or attachment, such an occurrence shall also
be treated as an event of "Financial Difficulty."
1.17 "Invested Capital" means, with respect to any Member, the amount of
Capital Contributions such Member has made to the Company, reduced by any
distributions received by such Member to return such Capital Contributions.
1.18 "Majority Interest" means more than fifty percent (50%) of the
Percentage Interests of Members.
1.19 "Manager" means Sunny Cove LLC, a California limited liability company
("Sunny Cove"), until it resigns or is replaced in accordance with Section 5.2 below.
1.20 "Member" means each Person who is an initial signatory to this
Agreement, has been admitted to the Company as a Member in accordance with this
Agreement or is an assignee who has become a Member in accordance with Section 7
of this Agreement.
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1.21 "Member & Manager Schedule" means the schedule attached hereto as
Exhibit A, and incorporated herein by this reference, as such schedule may be
amended from time to time pursuant to the terms of this Agreement.
1.22 "Member Nonrecourse Debt" shall have the meaning ascribed to the
term "Partner Nonrecourse Debt" in Regulations Section 1.704-2(b)(4).
1.23 "Member Nonrecourse Deductions" means items of Company loss,
deduction, or Code Section 705(a)(2)(b) expenditures which are attributable to Member
Nonrecourse Debt.
1.24 "Membership Interest" means a Member's entire interest in the
Company and all rights, benefits and privileges pertaining thereto.
1.25 "Net Profits" and "Net Losses" means the income, gain, loss,
deductions, and credits of the Company in the aggregate or separately stated, as
appropriate, determined in accordance with generally accepted accounting principles
employed under the method of accounting at the close of each fiscal year on the
Company's information tax return filed for federal income tax purposes.
1.26 "Nonrecourse Liability" shall have the meaning set forth in Regulations
Section 1.752-1(a)(2).
1.27 "Percentage Interest" means the percentage interest of a Member set
forth opposite the name of such Member in the Member & Manager Schedule, as such
percentage may be adjusted from time to time pursuant to the terms of this Agreement.
1.28 "Person" means an individual, general partnership, limited partnership,
limited liability company, corporation, trust, estate, real estate investment trust
association or any other entity.
1.29 "Projects" means those certain projects on real property to be acquired
by the Company for value add retail development opportunities in Idaho and any
compatible adjacent uses.
1.30 Regulations" shall, unless the context clearly indicates otherwise, mean
the regulations currently in force as final or temporary that have been issued by the U.S.
Department of Treasury pursuant to its authority under the Code.
1.31 "Reserves" means the amount set aside at a particular time as a
reasonable allowance for the Company's contingencies and anticipated obligations
(including working capital reserves, tenant improvements, leasing costs, lender
requirements and reasonable reserves for replacement of Company capital assets), as
reasonably determined by the Manager from time to time.
1.32 "Transferable Interest" means the right, as originally associated with a
Person's capacity as a Member, to receive distributions from the Company in
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accordance with this Agreement, whether or not the Person remains a Member or
continues to own any part of the right.
1.33 "Transferee" means a Person who has acquired a Member's
Transferable Interest in the Company, by way of a Transfer in accordance with the
terms of this Agreement, but who has not become a Member.
1.34 "Transferring Member" means a Member who by means of a Transfer
has transferred a Transferable Interest in the Company to a Transferee.
1.35 "Voting Interest" means, with respect to a Member, the right to Vote or
participate in management and any right to information concerning the business and
affairs of the Company provided under the Act, except as limited by the provisions of
this Agreement. A Member's Voting Interest shall be directly proportional to that
Member's Percentage Interest.
1.36 "Written" or "in writing" includes facsimile and other electronic
communication authorized by the Act.
2. ORGANIZATIONAL MATTERS
2.1 Name. The name of the Company shall be Franklin Mile Managers, LLC.
2.2 Term. The term of the Company commenced on the date the Articles
were filed, as listed in Recital A of this Agreement, and shall continue until terminated
by the provisions of this Agreement or as provided by law.
2.3 Office and Agent. The Company shall continuously maintain an office
and registered agent in the State of California as required by the Act. The principal
office of the Company shall be located at 250 Bobwhite Court, Suite 240, Boise, Idaho
83706 or at such other location as the Manager may determine. The registered agent
shall be as stated in the Articles or as otherwise determined by the Manager.
2.4 Addresses of the Members and the Manager. The respective
addresses of the Members and the Manager are set forth in the Member & Manager
Schedule. The Manager is hereby authorized and empowered to amend the Member &
Manager Schedule from time to time as necessary or appropriate to reflect any change
in the addresses of the Members and/or the Manager as provided in this Agreement.
2.5 Purpose of Company. The purpose of the Company is to engage in any
lawful activity for which a limited liability company may be organized under the Act.
Notwithstanding the foregoing, the Company shall not engage in any business other
than the following without the consent of all Members:
(a) to act as a Manager for entities in the business of acquiring,
owning, managing, developing, leasing, and holding for investment ownership interests,
whether directly or indirectly, in Projects;
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(b) such other activities directly related to the foregoing business as
may be necessary, advisable, or appropriate, in the reasonable opinion of the Manager
to further the foregoing business.
3. CAPITAL CONTRIBUTIONS
3.1 Initial Capital Contributions. Upon the full execution of this Agreement,
each of the Members shall make the capital contribution(s) to the Company as specified
in the Member & Manager Schedule.
3.2 Additional Capital Contributions.
(a) All Members acknowledge and agree that the Manager may
determine from time to time that additional capital contributions or loans are required to
enable the Company to conduct its business, including without limitation, to fund any
costs that are not funded by the Members' initial Capital Contributions and/or any third-
party bank or institutional financing ("Additional Capital Contributions").
(b) The Manager's right to exercise its discretion and authority under
this Section 3.2 is personal to the Manager. Nothing in this Section 3.2 (whether
express or implied), shall be construed to entitle any third party (including, without
limitation, a creditor of the Company) to substitute its own judgment for the judgment of
the Manager in determining if and when the Company requires additional capital or
borrowed funds.
(c) Upon making such a determination, the Manager may deliver a
notice to the Members (hereinafter referred to as a "Call Notice"), specifying in
reasonable detail the debts, obligations, and expenses then due and the amount of
Additional Capital Contributions requested to be contributed. Each Member shall have
the option, not the obligation, to contribute its pro rata share of the Additional Capital
Contributions based on its Percentage Interest.
(d) Each Member may make its Additional Capital Contribution within
fifteen (15) business days after delivery of each Call Notice. For such Additional Capital
Contributions, the Members shall each receive a credit to its Capital Account in the
amount of its contribution.
(e) If a Member chooses not to contribute any capital contribution after
the Call Notice, then such party acknowledges and agrees that its Percentage Interest
will be diluted by the contributions that are made by all other contributing members,
based on the Fair Market Value of the Property and Project at the time (as determined
in Section 7.8(b)(ii)(B)).
3.3 Loans by a Member.
(a) Loans by an Affiliate. If at any time, or from time to time, the
Manager determines, in its commercially reasonable discretion, that the Company
requires additional funds to conduct its business, the Manager may obtain an unsecured
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loan from any of Mark Engstrom, James Engstrom or Kent Calfee (or an entity
controlled by one of such individuals). Any such loan shall bear interest at 8% per
annum and otherwise be based on commercially reasonable and market terms.
(b) Loans by a Member. If at any time, or from time to time, the
Manager determines, in its commercially reasonable discretion, that the Company
requires additional funds to conduct its business and the Manager elects not to obtain a
loan pursuant to Section 3.3(a) above, the Manager may permit the Members to make
one or more unsecured loans to the Company (collectively "Member Loans" and
separately, a "Member Loan") in accordance with the following provisions:
(i) Each Member shall have the right, but not the obligation, to
loan to the Company that portion of the required additional funds that is in the same
proportion as the Percentage Interest of such Member is to the aggregate Percentage
Interests of all Members;
(ii) The Manager shall give written notice to each Member of (i)
the total amount of required additional funds, and (ii) such Member's proportionate
share thereof. Each Member shall have ten (10) business days from the date such
notice is given to loan its proportionate share of the required additional funds to the
Company;
(iii) If any Member loans less than its proportionate share of the
required additional funds, then the other Member may loan the resulting deficiency. If
at that time there are then more than two Members, then the other Members may loan
the resulting deficiency in such proportion as they may agree. If the other Members are
unable to so agree, then each such other Member shall have the right, but not the
obligation, to contribute that portion of the resulting deficiency which is in the same
proportion as the Percentage Interest of such other Member is to the aggregate
Percentage Interest of all Members who desire to contribute such deficiency;
(iv) Each Member Loan shall be evidenced by the Company's
unsecured promissory note. The principal balance of a Member Loan, outstanding from
time to time, shall bear interest at the rate of eight percent (8%) per annum,
compounded annually;
(v) The Company shall repay the entire principal balance of
each Member Loan, together with interest thereon, prior to making distributions to
Members under Section 6.5. If there are two or more Member Loans, then such loans
shall be repaid to the extent of available of Company funds, pro rata, in accordance with
their respective outstanding balances; and
(vi) All payments which the Company makes on a Member Loan
shall be treated as payments made to a partner not acting in its capacity such under
Code Section 707(a).
3.4 Return of Contributions. Except as provided in this Agreement, no
Member or Interest Holder shall have the right to receive any distribution or the return of
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any Contribution upon any withdrawal from the Company, except upon dissolution of the
Company where the existence of the Company is not continued as provided herein. No
Member or Interest Holder shall have the right to receive any Distribution in any form
other than money. Except as specifically set forth in this Agreement, and/or except as
specifically provided in any written agreements between the Members that are approved
in writing by the Company, no Member shall have priority over any other Member with
respect to the return of a Capital Contribution or distributions or allocations of income,
gain, losses, deductions, credits, or items thereof.
3.5 Capital Accounts. The Company shall establish an individual Capital
Account for each Member, which shall be credited with the amount or agreed value of
the initial Capital Contribution for such Member set forth in the Member & Manager
Schedule. Thereafter, the Company shall determine and maintain each Capital Account
in accordance with Regulations Section 1.704-1(b)(2)(iv). If a Member transfers all or a
part of such Member's Membership Interest in accordance with this Agreement, such
Member's Capital Account attributable to the transferred Membership Interest shall
carry over to the new owner of such Membership Interest pursuant to Regulations
Section 1.704-1(b)(2)(iv)(1).
3.6 No Interest. Except as otherwise provided in this Agreement, no Member
shall be entitled to receive any interest on such Member's Capital Contributions.
3.7 Warranties. The Members acknowledge that the Manager or its Affiliates
may be requested to guaranty debt for an entity under management, and agree that
such decision is within the sole discretion of the Manager and its Affiliates. If such
guaranties are requested and given, each Member agrees that it will join with the
Manager (whether joint and several or several only).
4. MEMBERS
4.1 Limited Liability. Except as required under the Act or as expressly set
forth in this Agreement, no Member (including without limitation, the Manager) shall be
personally liable for any debt, obligation or liability of the Company, whether that liability
or obligation arises in contract, tort or otherwise.
4.2 Transactions with the Company. Subject to any limitations set forth in
this Agreement and with the prior approval of the Manager after full disclosure of the
Member's involvement, a Member or an Affiliate may lend money to and transact other
business with the Company. Subject to other applicable law, such Member has the
same rights and obligations with respect thereto as a Person who is not a Member.
4.3 Remuneration To Managers or Members. Except as set forth in this
Section 4.3, or except as otherwise authorized in or pursuant to this Agreement, no
Manager, Member or an Affiliate is entitled to remuneration for acting in the Company
business, subject to (i) the entitlement of the Manager and Members to reimbursement
of reasonable expenses incurred on behalf of the Company, and (ii) the entitlement of
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Manager or Members winding up the affairs of the Company to reasonable
compensation pursuant to Section 10.3.
4.4 Members Cannot Bind the Company; Consent Rights. Pursuant to
Section 5.1 and the Articles, the management and direction of the Company is vested in
the Manager. The Members shall have no power to participate in or direct the
management of the Company except as expressly authorized by this Agreement or the
Articles and except as expressly required by the Act. Unless expressly and duly
authorized in writing to do so by the Manager, no Member shall have any power or
authority to bind or act on behalf of the Company in any way, to pledge its credit, or to
render it liable for any purpose. Except as expressly provided in this Agreement,
Members shall have no voting, approval or consent rights.
5. MANAGEMENT AND CONTROL OF THE COMPANY
5.1 Management of the Company bV Manager. Subject to any provisions of
the Articles and this Agreement relating to actions required to be approved by the
Members, if any, the business, property and affairs of the Company shall be managed
and all powers of the Company shall be exercised by or under the direction of the
Manager.
5.2 Election of Manager.
(a) Number, Term, Elections and Qualifications. The Company shall
have one (1) Manager, and the initial Manager of the Company shall be Sunny Cove.
The Manager shall hold such office until such Manager resigns, or a Majority Interest of
the Members elects to remove such Manager which election can only be made if the
Manager commits fraud, gross negligence, reckless or intentional misconduct, or a
knowing violation of law in connection with carrying out its duties as the Manager of the
Company.
(b) Resignation. A Manager may resign at any time by giving written
notice to the Members. The resignation of a Manager shall take effect thirty (30) days
after the receipt of that notice or at such later time as shall be specified in the notice;
and, unless otherwise specified in the notice, the acceptance of the resignation shall not
be necessary to make it effective. If a Manager is also a Member of the Company, the
resignation of such Manager shall not affect the Manager's rights as a Member and
shall not constitute a withdrawal of the Manager as a Member. In such event, a
replacement Manager may be elected by the affirmative vote or written consent of
Members holding a Majority Interest.
5.3 Control and Management. Subject to the Members' rights to approve
"Major Decisions" under Section 5.5, (i) the Manager shall have the exclusive authority
to control, manage and direct the Company's business, (ii) all Company matters shall be
decided by the Manager, and (iii) the Manager shall be responsible for the day-to-day
management of the Company's business. Without limiting the generality of the
foregoing, and subject to those limitations set forth elsewhere in this Agreement, the
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Manager shall have the right, without the consent of any Member, to cause the
Company to do any of the following upon such terms and conditions as the Manager
deems, in its sole and absolute discretion, to be in the Company's best interests:
(a) Negotiate and execute all purchase and sale agreements, loan
agreements, contracts, leases, option agreements, promissory notes, deeds of trust,
grant deeds, agreements for sale, escrow instructions, releases, easements, maps,
construction contracts, security agreements, fixture filings, financing statements,
indemnities, management agreements, guarantees, partnership agreements, operating
agreements, limited liability company agreements, resolutions, certificates and other
documents and instruments, including, without limitation, the purchase agreement and
all documents related to the acquisition of a Project, and all documentation relating to
the acquisition financing and/or construction financing for a Project, including any
amendments and/or modifications thereto;
(b) Acquire assets, including, without limitation, a Project;
(c) Amend, modify or terminate the purchase agreement that provides
for the acquisition of a Project;
(d) Enter into, amend, modify or terminate any tenancy in common
agreement to which the Company is a party;
(e) Lease all or any part of a Project;
(f) Sell, exchange, or otherwise dispose of all or any part of any
Company assets, including, without limitation, a Project;
(g) Borrow money (including extending guarantees of same by the
Manager or its members), finance, refinance, mortgage, prepay, in whole or in part,
increase, modify or extend any obligation, including, without limitation, the Company's
acquisition financing for a Project;
(h) Expend the funds of the Company in furtherance of the Company's
business in accordance with the provisions of this Agreement;
(i) Engage, at the expense of the Company, such professional
services as may be required, including legal and accounting services;
0) Acquire and enter into any contract of liability and other insurance
which the Manager deems reasonably necessary and proper for the protection of the
Members and the Company for the conservation of its assets or for any purpose
convenient or beneficial to the Company;
(k) Settle any insurance claims in favor of or against the Company as
the Manager may deem advisable;
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(1) Hire and fire employees of the Company and to set compensation
and benefits for such employees;
(m) Enter into and execute agreements or contracts on behalf of the
Company;
(n) Cause the Company's accountant to determine the Net Profits and
Net Losses of the Company as well as the Members pursuant to the terms of this
Agreement and in accordance with tax accounting principles as applied to the
Company;
(o) Open accounts and deposit and maintain funds, in the name of the
Company, in banks, savings and loan associations, or other financial institutions;
(p) Compromise, resolve disputes or otherwise adjust claims in favor
of, or against, the Company and to commence or defend litigation with respect to the
Company or any assets of the Company, as the Manager may deem advisable, all or
any of the above matters being at the expense of the Company;
(q) Make elections under the tax laws of the United States or any State
as to the treatment of Company income, gains, losses, deductions and credits and as to
all other relevant matters; and
(r) Perform any and all other acts or activities customary or incidental
to the Company purposes and the foregoing powers; and to execute any and all
instruments to effectuate the Company purposes and foregoing powers, so long as such
act or activities may be lawfully carried on or performed by a limited liability company
under the laws of the State of California.
5.4 Management Duties and Obligations of the Manager. Subject to the
Members' rights to approve "Major Decisions" under Section 5.5 or elsewhere in this
Agreement, the Manager shall be responsible for the day-to-day management of the
Company and the daily operation of the subject business. The Manager shall, in
addition to fulfilling any other obligations imposed by this Agreement, perform the
following duties:
(a) All purchase orders, deeds, notes, leases, contracts, and other
documents shall be signed on behalf of the Company only by the Manager or its duly
authorized agents.
(b) The Manager shall open and thereafter maintain one or more
separate bank accounts in the name of the Company in which there shall be deposited
all of the funds of the Company. The funds in said account shall be used solely for the
business of the Company and all withdrawals therefrom are to be made upon checks
signed by the Manager or such other person or persons as the Manager may designate.
(c) Except as otherwise provided in this Agreement, the Manager shall
have all rights and powers subject to all restrictions and liabilities of a member in a
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limited liability company without other members and shall have all rights and powers
subject to all restrictions imposed on managers by the Act. Thus, the Manager shall not
have authority to do any act in contravention of this Agreement, or do any act that would
make it impossible to carry on the ordinary business of the Company.
5.5 Voting Rights of Members. Notwithstanding any other provision of this
Agreement, the following actions constitute "Major Decisions" and the Manager is not
authorized to cause the Company to do any of the following without the written consent
of a Majority Interest of the Members:
(i) A merger or conversion of the Company;
(ii) Other than as disclosed and agreed in Section 4.4, enter into
agreements or contracts on behalf of the Company with Affiliates of the Manager and/or
with the Manager;
(iii) Payment of any compensation to the Manager, except as
expressly set forth in this Agreement;
(iv) Any amendment to this Agreement or the Articles;
(v) The admission of a Manager or the election to continue the
business of the Company after the immediately preceding manager has ceased to be
the Manager pursuant to the Act, where there is no remaining or surviving Manager;
(vi) The dissolution of the Company;
(vii) A change in the nature of the Company's business, or
undertaking any action outside the ordinary course of the Company's business.
(viii) Admission of a new member via direct capital contribution to
the Company; or
(ix) The release of a Member's obligations to make Additional
Capital Contributions.
Each Member shall respond to a request for its written consent under this
Section 5.5 in a reasonably timely manner in light of the circumstances of the request.
5.6 Performance of Duties; Liability of Manager. The Manager shall not be
liable to the Company or to any Member for any loss or damage sustained by the
Company or any Member, unless the loss or damage shall have been the result of
fraud, gross negligence, reckless or intentional misconduct, or a knowing violation of
law by such Manager in connection with carrying out its duties as the Manager of the
Company.
5.7 Devotion of Time. The Manager is not obligated to devote all of such
Manager's time or business efforts to the affairs of the Company, but the Manager shall
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devote all time and efforts necessary and work diligently to cause the Projects to be
completed, and will spend a reasonable amount of time, effort, and skill as reasonably
necessary for the operation of the Company.
5.8 Limitations on Liability and Duties of Officers and Members.
(a) Each Member and Officer must discharge his duties in accordance
with good faith business judgment in what he believes is in the best interests of the
Company. Each Member and Officer is entitled to rely on information, opinions, reports
and statements or other data prepared or presented by any Person to the Member or
Officer that the Member or Officer reasonably believes in good faith to be reliable and
competent in the matters presented. Reliance on such information, opinions, reports or
statements shall be conclusive evidence that the Member or Officer acted reasonably
and in good faith in the exercise of his business judgment.
(b) THE MEMBERS ACKNOWLEDGE AND REPRESENT THAT
EACH OF THEM HAS HAD THE OPPORTUNITY TO REVIEW SECTION 30-25-304
OF THE ACT AND CONSULT WITH INDEPENDENT COUNSEL AND/OR OTHER
ADVISORS AND FULLY UNDERSTAND THE SCOPE OF RESPONSIBILITIES AND
DUTIES OWED UNDER SECTION 30-25-304 THE ACT.
(c) Pursuant to Sections 17701.10 and 17704.09 of the Act, the
Members hereby agree as follows:
(i) Business Opportunities. The Members and Officers
recognize that each of them and their Affiliates, and the shareholders, members,
Officers, directors, employees, agents, and representatives of each of them have or
may have other business interests, activities and investments, some of which may be in
conflict or competition with the business of the Company. Except as provided herein, it
is the Members' express intent and desire that:
(1) Each Member and Officer and his Affiliates: (i) are and shall
continue to be entitled to carry on such other business interests, activities and
investments; (ii) may engage in or possess an interest in any other business or venture
of any kind, independently or with others; and (iii) may engage in such activities,
whether or not competitive with the Company, without any obligation to offer any
interest in such activities to the Company or the other Members;
(2) Neither the Company nor any Member or Officer shall have
any right, by virtue of this Agreement, in and to such activities, or the income or profits
derived therefrom; and
(3) The pursuit of such activities, even if competitive with the
business of the Company, shall not be deemed wrongful or improper.
(ii) Notwithstanding this Section, the Company and the
Members hereby agree that the Members shall not compete in any of the following
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activities: as set forth in the governing documents for any entity and Project managed
by the Company.
(d) Limitation on Liability. Pursuant to Section 30-25-304, no Member
or Officer shall be liable to the Company or to any Member for any monetary damages
sustained by the Company or any Member, unless the loss or damage shall have been
the result of:
(i) a breach of the duty of loyalty as modified herein;
(i i) a financial benefit received by the Member or Officer to
which the Member or Officer is not entitled;
(iii) an intentional infliction of harm on the Company or another
Member; or
(iv) an intentional violation of criminal law.
5.9 Business with Related Entities. Subject to Section 30-25-304, no
Company funds, assets, credits or other resources of any kind or description shall be
paid to, or used for, the benefit of any Member or Officer or any Affiliate of any Member
or Officer except as specifically provided in this Agreement or as approved by all the
Members and so long as the amounts paid to any Member or Officer or any Affiliate is
equal to the amount which would be paid to an independent third (3rd) party. Without
limiting the foregoing, if the Members by Majority Vote approve of any transactions after
full disclosure to all Members, such transaction shall not be a violation of Section
17704.09 of the Act.
5.10 Right to Repurchase Membership Interests. In the event that (i) the
employment of Jason Jaques is terminated for any reason by Engstrom Properties, Inc.,
(ii) James Teare is unable or unwilling to provide brokerage services consistent with
those historically provided to Engstrom Properties, Inc. (and its affiliates), or (iii) John
Monley is unable or unwilling to provide development services consistent with those
historically provided to Engstrom Properties, Inc. (and its affiliates), then the Company
shall have the right to repurchase the applicable Member's Membership Interest at Fair
Market Value pursuant to Section 7.8 of this Agreement.
6. ALLOCATIONS OF NET PROFITS AND NET LOSSES AND DISTRIBUTIONS
6.1 Allocations of Net Profit and Net Loss.
(a) Net Loss. Net Loss shall be allocated to the Members in proportion
to their Percentage Interests. Notwithstanding the previous sentence, loss allocations
to a Member shall be made only to the extent that such loss allocations will not create a
deficit Capital Account balance for that Member in excess of an amount, if any, equal to
such Member's share of Company Minimum Gain that would be realized on a
foreclosure of the Company's property. Any loss not allocated to a Member because of
the foregoing provision shall be allocated to the other Members (to the extent the other
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Members are not limited in respect of the allocation of losses under this Section 6.1(a)).
Any loss reallocated under this Section 6.1(a) shall be taken into account in computing
subsequent allocations of income and losses pursuant to this Section 6, so that the net
amount of any item so allocated and the income and losses allocated to each Member
pursuant to this Section 6, to the extent possible, shall be equal to the net amount that
would have been allocated to each such Member pursuant to this Section 6 if no
reallocation of losses had occurred under this Section 6.1(a).
(b) Net Profit. Except as otherwise provided in this Agreement, Net
Profit shall first be allocated to the Members in proportion to their Percentage Interests.
6.2 Special Allocations.
(a) Minimum Gain Chargeback. Notwithstanding Section 6.1, if there is
a net decrease in Company Minimum Gain during any Fiscal Year, each Member shall
be specially allocated items of Company income and gain for such Fiscal Year (and, if
necessary, in subsequent fiscal years) in an amount equal to the portion of such
Member's share of the net decrease in Company Minimum Gain that is allocable to the
disposition of Company property subject to a Nonrecourse Liability, which share of such
net decrease shall be determined in accordance with Regulations Section 1.704-2(g)(2).
Allocations pursuant to this Section 6.2(a) shall be made in proportion to the amounts
required to be allocated to each Member under this Section 6.2(a). The items to be so
allocated shall be determined in accordance with Regulations Section 1.704-2(f). This
Section 6.2(a) is intended to comply with the minimum gain chargeback requirement
contained in Regulations Section 1.704-2(f) and shall be interpreted consistently
therewith.
(b) Chargeback of Minimum Gain Attributable to Member Nonrecourse
Debt. Notwithstanding Section 6.1 of this Agreement, if there is a net decrease in
Company Minimum Gain attributable to a Member Nonrecourse Debt during any Fiscal
Year, each member who has a share of the Company Minimum Gain attributable to
such Member Nonrecourse Debt (which share shall be determined in accordance with
Regulations Section 1.704-2(i)(5)) shall be specially allocated items of Company income
and gain for such Fiscal Year (and, if necessary, in subsequent Fiscal Years) in an
amount equal to that portion of such Member's share of the net decrease in Company
Minimum Gain attributable to such Member Nonrecourse Debt that is allocable to the
disposition of Company property subject to such Member Nonrecourse Debt (which
share of such net decrease shall be determined in accordance with Regulations Section
1.704-2(i)(5)). Allocations pursuant to this Section 6.2(b) shall be made in proportion to
the amounts required to be allocated to each Member under this Section 6.2(b). The
items to be so allocated shall be determined in accordance with Regulations Section
1.704-2(i)(4). This Section 6.2(b) is intended to comply with the minimum gain
chargeback requirement contained in Regulations Section 1.704-2(i)(4) and shall be
interpreted consistently therewith.
(c) Nonrecourse Deductions. Notwithstanding Section 6.1, any
nonrecourse deductions (as defined in Regulations Section 1.704-2(b)(1)) for any Fiscal
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Year or other period shall be specially allocated to the Members in proportion to their
Percentage Interests.
(d) Member Nonrecourse Deductions. Notwithstanding Section 6.1,
those items of Company loss, deduction, or Code Section 705(a)(2)(b) expenditures
which are attributable to Member Nonrecourse Debt for any Fiscal Year or other period
shall be specially allocated to the Member who bears the economic risk of loss with
respect to the Member Nonrecourse Debt to which such items are attributable in
accordance with Regulations Section 1.704-2(i).
(e) Qualified Income Offset. Notwithstanding Section 6.1, if a Member
unexpectedly receives any adjustments, allocations, or distributions described in
Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) or (6), or any other event creates a deficit
balance in such Member's Capital Account in excess of such Member's share of
Company Minimum Gain, items of Company income and gain shall be specially
allocated to such Member in an amount and manner sufficient to eliminate such excess
deficit balance as quickly as possible. Any special allocations of items of income and
gain pursuant to this Section 6.2(e) shall be taken into account in computing
subsequent allocations of income and gain pursuant to this Section 6 so that the net
amount of any item so allocated and the income, gain, and losses allocated to each
Member pursuant to this Section 6 to the extent possible, shall be equal to the net
amount that would have been allocated to each such Member pursuant to the
provisions of this Section 6.2(e) if such unexpected adjustments, allocations, or
distributions had not occurred.
6.3 Section 704(c) Allocations. Notwithstanding any other provision in this
Section 6, in accordance with Code Section 704(c) and the Regulations promulgated
thereunder, income, gain, loss, and deduction with respect to any property contributed
to the capital of the Company shall, solely for tax purposes, be allocated among the
Members so as to take account of any variation between the adjusted basis of such
property to the Company for federal income tax purposes and its fair market value on
the date of contribution. Allocations pursuant to this Section 6.3 are solely for purposes
of federal, state and local taxes. As such, they shall not affect or in any way be taken
into account in computing a Member's Capital Account or share of profits, losses, or
other items of distributions pursuant to any provision of this Agreement.
6.4 Allocations. If any Membership Interest is transferred, or is increased or
decreased by reason of the admission of a new Member or otherwise, during any Fiscal
Year of the Company, each item of income, gain, loss, deduction, or credit of the
Company for such Fiscal Year shall be assigned pro rata to each day in the particular
period of such Fiscal Year to which such item is attributable (i.e., the day on or during
which it is accrued or otherwise incurred) and the amount of each such item so
assigned to any such day shall be allocated to the Member based upon such Member's
respective Membership Interest at the close of such day. Notwithstanding any provision
above to the contrary, gain or loss of the Company realized in connection with a sale or
other disposition of any of the assets of the Company shall be allocated solely to the
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parties owning Membership Interests as of the date such sale or other disposition
occurs.
6.5 Distributions. Subject to applicable law and any limitations contained
elsewhere in this Agreement, the Manager in proportion to their Percentage Interests.
6.6 Obligations of Members to Report Allocations. The Members are
aware of the income tax consequences of the allocations made by this Section 6 and
hereby agree to be bound by the provisions of this Section 6 in reporting their shares of
Company income and loss for income tax purposes.
7. TRANSFER AND ASSIGNMENT OF INTERESTS
7.1 Transfer and Assignment of Interests. No Member shall be entitled to
withdraw, transfer, assign, convey, sell, encumber or in any way alienate all or any part
of such Member's Membership Interest except with the prior written consent of a
Majority Interest of the Members, which consent may be given or withheld, conditioned
or delayed (as allowed by this Agreement or the Act), as the other Members may
determine in their sole discretion. Any sale or transfer of membership interests in the
Manager which causes Mark Engstrom or his Affiliate(s) to no longer have ownership in
the Manager shall not constitute a transfer under this Section 7. After the
consummation of any transfer of any part of a Membership Interest, the Membership
Interest so transferred shall continue to be subject to the terms and provisions of this
Agreement and any further transfers shall be required to comply with all the terms and
provisions of this Agreement.
7.2 Further Restrictions on Transfer of Interests. In addition to other
restrictions found in this Agreement, no Member shall transfer, assign, convey, sell,
encumber or in any way alienate all or any part of such Member's Membership Interest:
(a) without compliance with all applicable federal and state securities laws; or (b) if the
Membership Interest to be transferred, assigned, sold or exchanged, when added to the
total of all other Membership Interests sold or exchanged in the preceding twelve (12)
consecutive months prior thereto, would cause the termination of the Company under
the Code, as reasonably determined by the Manager.
7.3 Substitution of Members. A transferee of a Membership Interest shall
have the right to become a substitute Member only if (a) the requirements of Sections
7.1 and 7.2 relating to consent of Members, securities and tax requirements hereof are
met, (b) such Person executes an instrument satisfactory to the Manager accepting and
adopting the terms and provisions of this Agreement, and (c) such person pays any
reasonable expenses in connection with such Member's admission as a new Member.
The admission of a substitute Member shall not result in the release of the Member who
assigned the Membership Interest from any liability that such Member may have to the
Company.
7.4 Permitted Transfers. The Membership Interest of any Member may be
transferred under the following circumstances without the prior written consent of other
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Members as required by Section 7.1 and without following the requirements of Section
7.8, but only with the prior approval of the Manager, which shall not be unreasonably
withheld, and subject to compliance with Section 7.2 and 7.3 above:
(a) Any transfer of the membership interests may be made only by
inter-vivos gift or by testamentary transfer to any spouse, parent, sibling, in-law, child or
grandchild, or other lineal descendant of such Member, or to a trust for the benefit of
such Member or such spouse, parent, sibling, in-law, child, grandchild, or other lineal
descendant of the Member; or
(b) To any Affiliate of the Member.
The Manager is hereby authorized and empowered to amend the Member &
Manager Schedule from time to time as necessary or appropriate to reflect such
transfers.
7.5 Effective Date of Permitted Transfers. Any permitted transfer of all or
any portion of a Membership Interest shall be effective as of the date upon which the
requirements of Sections 7.1, 7.2, and 7.3 have been met. The Manager shall provide
the Members with written notice of such transfer as promptly as possible after the
requirements of Sections 7.1, 7.2, and 7.3 have been met. Any transferee of a
Membership Interest shall take subject to the restrictions on transfer imposed by this
Agreement.
7.6 Rights of Legal Representatives. If a Member who is an individual, or
an individual who acts on behalf of a Member, dies or is adjudged by a court of
competent jurisdiction to be incompetent to manage the Member's person or property,
such party's executor, administrator, guardian, conservator, or other legal representative
may exercise all of the Member's rights for the purpose of settling the Member's estate
or administering the Member's property, including any power the Member has under the
Articles or this Agreement to give an assignee the right to become a Member. If a
Member is a corporation, trust, or other entity and is dissolved or terminated, the powers
of that Member may be exercised by such Member's legal representative or successor.
7.7 No Effect to Transfers in Violation of Agreement. Any transfer in
violation of this Section 7 shall be null and void, and the transferee shall have no right
to vote or participate in the management of the business, property and affairs of the
Company, to exercise any rights of a Member, or to receive the share of the Company's
Net Profits, Net Losses and distributions to which the transferor would otherwise be
entitled.
7.8 Right of First Refusal.
(a) Right of First Refusal. Except for a transfer of a Membership
Interest permitted under Section 7.4 above, each time that a Member (the "Transferring
Member") proposes to transfer such Member's Membership Interest, or upon receipt by
the Transferring Member of a bona fide offer to purchase such Transferring Member's
Membership Interest, in writing from any third party that has the financial ability to
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complete the purchase, that the Transferring Partner wishes to accept (a "Third Party
Offer"), the Transferring Member shall first offer to sell its Membership Interest to the
other Members in accordance with the provisions of this Section 7.8.
(i) The Transferring Member shall promptly offer in writing (an
"Offer") to sell its Membership Interest to the other Member(s) upon the terms and
conditions contained in the Third Party Offer. When the Transferring Member submits
the Offer to the other Member(s), the Transferring Member shall attach a copy of the
Third Party Offer to the notice, together with documentation that reasonably
demonstrates the third party's financial ability to complete the purchase.
(ii) The Offer may be accepted by any Member by delivering
written notice of its acceptance to the Transferring Member within thirty (30) days
following the accepting Member's receipt of the Offer. The failure of any Member to
submit a written acceptance notice to the Transferring Member within the thirty (30) day
period shall constitute an election on the part of that Member to not purchase the
Transferring Member's Membership Interest. If there are more than two Members in the
Company, and more than two Members accept the Offer, then the accepting Members
shall be entitled to purchase a portion of the Transferring Member's Membership
Interest in the same proportion that each of such Member's Membership Interest bears
to the aggregate of the Membership Interests of all the Members electing to purchase
such interest.
(iii) The aggregate purchase price to be paid for the Membership
Interest being offered by the Transferring Member shall be, at the sole option of the
purchaser(s), the price determined in Section 7.8(b)(ii) or equal to the sum of the
following amounts: (i) the purchase price set forth in the Third Party Offer, less (ii) the
amount of any commission, finder's fee or other brokerage or agent's compensation that
would be payable as part of the Third Party Offer. If the Third Party Offer provides for
the payment of non-cash consideration, then the purchasing Members each may elect
to pay the consideration in cash equal to the good faith estimate of the present fair
market value of the non-cash consideration offered as reasonably agreed upon by the
Transferring Member and the Member(s) electing to purchase the Membership Interest
being transferred. The purchase price for the Membership Interest of the Transferring
Member shall be payable by the accepting Member(s) within ninety (90) days after the
Offer is accepted. At the closing of the sale, the Transferring Member shall deliver an
assignment of its Membership Interest to the accepting Member. The accepting
Member shall be entitled to take title to the Transferring Member's Membership Interest
in such entity or structure that it deems desirable or appropriate.
(iv) If no Members accept the Offer within the thirty (30) day
period, then the Transferring Member shall be free to accept the Third Party Offer, and if
it is accepted, to sell the Membership Interest substantially in accordance with the terms
of the Third Party Offer, provided that: (i) such transfer is completed no more than sixty
(60) days after the closing date specified in the Offer, (ii) is made on terms no less
favorable to the Transferring Member than as designated in the Offer notice, (iii) the
requirements of Sections 7.1, 7.2 and 7.3 relating to consent by the other Members,
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securities and tax requirements hereof are met, and (iv) unless the non-transferring
Member(s) approve of the transferee as a Member of the Company, then the transferee
shall obtain the Transferring Member's Economic Interest and shall be a Non-Voting
Member. If such Membership Interest is not so transferred, the Transferring Member
must give notice in accordance with this Section prior to any other or subsequent
transfer of such Membership Interest.
(v) Except as otherwise provided in this Agreement, no Member
shall transfer less than all of its Membership Interest without the written consent of all
Members.
(b) Option to Purchase. This Section 7.8(b) shall not apply to any
transfer of a Membership Interest permitted under Section 7.4 above. From time to
time, if a Transferring Member desires to sell its Membership Interest but has not
received a Third Party Offer that it desires to accept, then, prior to listing the
Membership Interest on the open market, or hiring a broker to find a buyer for the
Membership Interest, the Transferring Member shall deliver notice to the other Members
of the Transferring Member's desire to sell its Membership Interest, and such notice
shall include the purchase price for the Membership Interest that the Transferring
Member would accept (an "Option Notice").
(i) Option Exercise and Terms. On the receipt of an Option
Notice, the receiving Member(s) shall have the option to exercise its right to purchase
the Transferring Member's Membership Interest described in the Option Notice, at the
price determined as set forth in Section 7.8(b)(ii) below, by delivering written notice of
such exercise to the Transferring Member not later than thirty (30) days after the
receiving Member's receipt of the Option Notice. Any Member that timely exercises its
option shall be referred to as a "Purchasing Member." Once a Purchasing Member has
exercised its option under this Section, then the Transferring Member shall not have any
right to sell its Membership Interest pursuant to a Third Party Offer under Section 7.8(a).
The failure of any Member to submit a written exercise notice to the Transferring
Member within the thirty (30) day period shall constitute an election on the part of that
Member to not exercise its option to purchase the Transferring Member's Membership
Interest. If there are more than two Members in the Company, and more than two
Members exercise their rights to exercise their options to purchase the Membership
Interest described in the Option Notice, then the Purchasing Members shall be entitled
to purchase a portion of the Transferring Member's Membership Interest in the same
proportion that each of such Purchasing Member's Membership Interest bears to the
aggregate of the Membership Interests of all the Members exercising their rights to
purchase such interest, and such parties together shall be collectively referred to herein
as the "Purchasing Member." The purchase of the Membership Interest described in
the Offer Notice shall close not more than ninety (90) days after the purchase price is
established for the Membership Interest in accordance with Section 7.8(b)(ii) below.
The purchase price for the Membership Interest of the Transferring Member shall be
payable ten percent (10%) down, in immediately available funds, at the closing of the
sale, and the balance pursuant to an unsecured promissory note at four percent (4%)
annual interest, fully amortized over one hundred twenty (120) monthly payments. The
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note shall contain customary provisions, including prepayment without penalty and ten
(10) day grace period. At the closing of the sale, the Transferring Member shall execute
and deliver to the Purchasing Member all duly executed conveyances, assignments and
other instruments which shall include standard and customary representations and
warranties, as necessary to transfer the Transferring Member's Membership Interest to
the Purchasing Member. The Purchasing Member shall be entitled to take title to the
Transferring Member's Membership Interest in such entity or structure that the
Purchasing Member determines.
(ii) Purchase Price. The purchase price of the Membership
Interest (the "Purchase Price") shall be equal to the fair market value of the Membership
Interest as determined under this Section 7.8(b)(ii) ("Fair Market Value").
(A) The Transferring Member and the Purchasing
Member shall confer and use their commercially reasonable efforts to agree in writing
on the Fair Market Value within ten (10) business days after the Purchasing Member
delivers its exercise notice to the Transferring Member (the "Trigger Date").
(B) If such Members are unable to agree on the Fair
Market Value in writing on or before the Trigger Date, then the Fair Market Value shall
be determined by the procedure set forth in this Section 7.8(b)(ii)(B). Within ten (10)
business days after the Trigger Date, each of the Transferring Member and the
Purchasing Member, at its cost and by giving written notice to the other, shall appoint an
appraiser with at least five (5) years' full-time appraisal experience, to appraise the fair
market value in accordance with this Section. Each selected appraiser shall, within
sixty (60) days after the Trigger Date (the "Appraisal Date"), alone determine the fair
market value of the Membership Interest in writing and prepare and submit its complete
self-contained narrative appraisal report reasonably setting forth the fair market value to
the Transferring Member and the Purchasing Member. The selected appraiser shall
take into account minority, lack of marketability, or any other discounts as deemed
appropriate in his or her professional judgment. If a party does not appoint an appraiser
as provided in the preceding sentence, then the appraiser appointed by the other party
shall be the sole appraiser and shall prepare a written appraisal report reasonably
setting forth the fair market value of the Membership Interest.
(C) The Transferring Member's and the Purchasing
Member's appraisers shall each provide a copy of its appraisal simultaneously to each
other, the Transferring Member and the Purchasing Member, not later than the
Appraisal Date. If either of the two appraisers fails to so deliver copies of its appraisal
on or before the Appraisal Date, then the fair market value of the Membership Interest
as described in the appraisal of the other appraiser shall be the Fair Market Value.
(D) If both appraisers so submit their appraisals by the
Appraisal Date, and the higher appraisal is not more than one hundred five percent
(105%) of the lower appraisal, the Fair Market Value of the Membership Interest shall
be established as the average of the two appraisals. If not, then the two (2) appraisers
shall confer and agree upon a third appraiser who also meets the requirements
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described in Section 7.8(b)(ii)(B) above, within five (5) business days after the Appraisal
Date. If the two (2) appraisers are unable to agree on a third appraiser as provided in
the preceding sentence, then either the Transferring Member or the Purchasing
Member may, in accordance with Section 12.5 below, seek to have an arbitrator appoint
a third appraiser. If a third appraiser is agreed upon and/or appointed in accordance
with this Section 7.8(b)(ii)(D), such appraiser must be a person who has not previously
acted in any capacity for either the Transferring Member or the Purchasing Member,
and has no interest, whether financial or otherwise, in this Agreement or the
transactions contemplated hereby. The third appraiser shall, within five (5) business
days after receipt of the Transferring Member's and the Purchasing Member's appraisal
reports, ONLY select one of the two appraisal reports that it determines best describes
the fair market value of the Membership Interest, and the fair market value as set forth
in such report shall be the Fair Market Value.
(E) The Transferring Member and the Purchasing
Member shall each bear the cost of its respective appraiser, and the cost of the third
appraiser (if any) shall be shared equally by the Transferring Member and the
Purchasing Member.
7.9 Financial Difficulty. Upon the Financial Difficulty of a Member, the
Company shall have the option, for a period ending fifteen (15) calendar days following
the determination of the purchase price as provided in Section 7.8(b), and the other
Members, pro rata in accordance with their Percentage Interest in the Company, shall
then have the option, for a period of fifteen (15) days thereafter, to purchase the
Percentage Interest in the Company not purchased by the Company, on the same
terms and conditions as apply to the Company. If neither the Company nor all other
Members elect to purchase the entire Interest, then the Members electing to purchase
shall have the right, pro rata in accordance with their Percentage Interest in the
Company, to purchase the additional Percentage Interest in the Company available for
purchase. The transferee of the Percentage Interest in the Company that is not
purchased shall hold such Interest in the Company subject to all of the provisions of this
Agreement.
8. ACCOUNTING, RECORDS, REPORTING BY MEMBERS
8.1 Books and Records. The books and records of the Company shall be
kept, and the financial position and the results of its operations recorded, in accordance
with the accounting methods followed for federal income tax purposes. The books and
records of the Company shall reflect all the Company transactions and shall be
appropriate and adequate for the Company's business. The Company shall maintain at
its principal office in California all of the following:
(a) A current list of the full name and last known business or residence
address of each Member set forth in alphabetical order, together with the Capital
Contributions, Capital Account and Percentage Interest of each Member;
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(b) A current list of the full name and business or residence address of
the Manager;
(c) A copy of the Articles and any and all amendments thereto together
with executed copies of any powers of attorney pursuant to which the Articles or any
amendments thereto have been executed;
(d) Copies of the Company's federal, state, and local income tax or
information returns and reports, if any, for the six most recent taxable years;
(e) A copy of this Agreement and any and all amendments thereto
together with executed copies of any powers of attorney pursuant to which this
Agreement or any amendments thereto have been executed;
(f) Copies of the financial statements of the Company, if any, for the
six most recent Fiscal Years; and
(g) The Company's books and records as they relate to the internal
affairs of the Company for at least the current and past four Fiscal Years.
8.2 Annual Reports. The Manager shall cause to be prepared at least
annually, at Company expense, information necessary for the preparation of the
Members' federal and state income tax returns. The Manager shall send or cause to be
sent to each Member within ninety (90) days after the end of each taxable year such
information as is necessary to complete federal and state income tax or information
returns.
8.3 Bank Accounts. The Manager shall maintain the funds of the Company in
one or more separate bank accounts in the name of the Company, and shall not permit
the funds of the Company to be commingled in any fashion with the funds of any other
Person.
8.4 Tax Matters for the Company. The Manager shall act as Partnership
Representative of the Company under Internal Revenue Code Section 6223(a) and is
authorized to do the following:
(a) For purposes of this Section 8.4, all references to sections of the
Internal Revenue Code are to the Internal Revenue Code provisions enacted by the
Bipartisan Budget Act of 2015 (Pub L 114-74, 129 Stat 584), as such provisions may
subsequently be amended.
(b) The obligations of each Member or former Member under this
Section 8.4 shall survive the transfer or redemption by a Member of its Membership
Interest and the termination of this Agreement or the dissolution of the Company.
(c) If any adjustment in the amount of any item of income, gain, loss,
deduction, or credit of a partnership, or any partner's distributive share thereof, is
determined with respect to the Company, the Partnership Representative shall promptly
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notify the Members on receipt of the notice of final adjustment and shall take all actions
directed by a majority of the Members in writing within 10 business days after receipt of
such notice, including, without limitation, filing a petition in Tax Court, or, if applicable,
causing the Company either to pay the amount of such adjustment under Internal
Revenue Code Section 6225 or to make the election under Internal Revenue Code
Section 6226(a).
(d) No later than 10 business days after the Partnership
Representative has knowledge of any audit or proceeding concerning the Company, the
Partnership Representative shall notify the Members of the existence of such audit or
proceeding. Each Member shall have the right to have a tax advisor of its own choosing
participate in, but not direct, the prosecution or defense of such audit or proceeding at
such Member's sole expense. The Partnership Representative shall make
commercially reasonable efforts to facilitate such tax advisor's participation.
(e) If any adjustment in the amount of any item of income, gain, loss,
deduction, or credit of a partnership, or any partner's distributive share thereof, is finally
determined with respect to the Company, and the Partnership Representative has not
yet caused the Company to make the election under Internal Revenue Code
Section 6226(a): (i) the Members shall take all actions requested by the Partnership
Representative, including, without limitation, filing amended tax returns and paying any
tax or adjustment due; (ii) if applicable, the Partnership Representative shall use
commercially reasonable efforts to make any modifications available under Internal
Revenue Code Section 6225(c)(3), (4), and (5); and (iii) any imputed underpayment (as
determined in accordance with Internal Revenue Code Section 6225) or adjustment that
does not give rise to an imputed underpayment shall be apportioned among the
Members, for the taxable year in which the adjustment is finalized, in such manner as
may be necessary (as determined by the Partnership Representative in good faith) so
that, to the maximum extent possible, the tax and economic consequences of the
partnership adjustment and any associated interest and penalties are borne by the
Members based on their interests in the Company for the reviewed year.
(f) Expense items attributable to the audit and final determination of
any imputed adjustment amount of the Company shall be specially allocated to each
Member in proportion to which each Member bears the cost of such imputed adjustment
amount.
(g) To the extent that a portion of the tax liabilities imposed under
Internal Revenue Code Section 6225 relates to a former Member, the Company may
require that former Member to indemnify the Company for its allocable portion of such
tax. Each Member acknowledges and agrees that, notwithstanding the transfer or
redemption of all or any portion of its interest in the Company, it will remain liable for all
tax liabilities with respect to its allocable share of income and gain of the Company for
the Company's taxable years (or portions thereof) prior to such transfer or redemption.
The obligations of each Member or former Member under this Section 8.4 shall survive
the transfer or redemption by such Member of its Membership Interest and the
termination of this Agreement or the dissolution of the Company.
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DocuSign Envelope ID:BBE03710-2564-432C-B4C6-8DCED24D51D8
9. INDEMNIFICATION.
9.1 Indemnification of Agents.
(a) An "Agent" is any Person who was or is a party or is threatened to
be made a party to any threatened, pending or completed action, suit or proceeding by
reason of the fact that such Person is or was a Member, Manager, officer, employee or
other agent of the Company on Company business, or such Person is or was a
manager, member, director, officer, employee or other agent of the Manager or a
Member of the Company and acting in connection with or on behalf of the Company on
Company business.
(b) To the fullest extent permitted by applicable law in effect on the
date hereof and to such greater extent as applicable law may hereafter from time to
time permit, and to the extent of its assets, the Company shall indemnify, defend and
hold harmless each Agent, and each from and against any and all liabilities of every
kind (including, without limitation, attorneys' fees), arising in any manner out of or in
connection with the operation of the Company's business, except as to those matters
arising by reason of such Agent's fraud, gross negligence, reckless or intentional
misconduct, or a knowing violation of law. The Manager shall be authorized, on behalf
of the Company, to enter into indemnity agreements from time to time with any Agent
entitled to be indemnified by the Company hereunder, upon such terms and conditions
as the Manager deems appropriate in its business judgment. If any action, suit or
proceeding is instituted against the Company and/or the Manager and/or an Agent with
respect to the Company's business, assets, liabilities or activities, the Manager may
obtain legal counsel to defend or assist in defending such action, suit or proceeding.
The Company shall (i) advance to the Manager funds necessary to pay for all expenses
and costs reasonably incurred in connection therewith, and (ii) reimburse the Manager
for, and indemnify, defend and hold harmless the Manager from and against, any and
all liabilities, costs and expenses which were not advanced by the Company but which
were incurred in connection with the defense of any such action, suit or proceeding,
including, without limitation, liabilities, costs and expenses paid in settlement or
compromise of the action, suit or proceeding. If, following the Company's advance of
funds to the Manager pursuant to this subsection (b), a court of competent jurisdiction
determines that the Manager is not entitled to indemnification under this Agreement,
then the Manager shall return all advanced funds to the Company without interest.
(c) The Manager shall not be liable to the Company for any loss
suffered by it in connection with its activities, provided that if such loss or liability arises
out of any action or inaction of the Manager, the Manager must have determined in
good faith that such course of conduct was in the best interest of the Company, and
such course of conduct must not have constituted fraud, gross negligence, reckless or
intentional misconduct, or a knowing violation of law by such Manager in connection
with carrying out its duties as the Manager of the Company.
25
DocuSign Envelope ID: BBE03710-2564-432C-B4C6-8DCED24D51D8
10. DISSOCIATION
10.1 No Right to Dissociate. No Member has the right to dissociate from the
Company without receiving the consent of all other Members.
10.2 Events Causing Wrongful Dissociation. A Person shall be wrongfully
dissociated as a Member from the Company when any of the following occur:
(a) The Company receives notice of the Member's express will to
withdraw as a Member;
(b) The Member expelled as a Member by the unanimous consent of
the other Members because any of the following applies:
(i) It is unlawful to carry on the Company's activities with the
Person as a Member.
(ii) There has been a Transfer of all of the Member's
Transferable Interest in the Company, other than the following:
(1) A Transfer for security purposes.
(2) A Permitted Transfer under Section 7.4.
(iii) The Member is a corporation and, within ninety (90) days
after the Company notifies the Member that it will be expelled as a Member because the
Member has filed a certificate of dissolution or the equivalent, its charter has been
revoked, or its right to conduct business has been suspended by the jurisdiction of its
incorporation and the certificate of dissolution has not been revoked or its charter or
right to conduct business has not been reinstated.
(iv) The Member is a limited liability company or partnership that
has been dissolved and whose business is being wound up.
(c) In the case of a member that is a trust, the trust's entire
Transferable Interest in the Company is distributed other than as allowed under Section
7.4.
(d) In the case of a Member that is an estate, the estate's entire
Transferable Interest in the Company is transferred other than as allowed under Section
7.4.
10.3 Death. The death of an individual Member shall not cause the Member to
be dissociated unless the recipient of the Membership Interest is other than by a
Permitted Transfer.
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DocuSign Envelope ID: BBE03710-2564-432C-B4C6-8DCED24D51D8
10.4 Effect of Disassociation.
(a) When a Person is dissociated as a Member of the Company, all of
the following apply:
(i) The person's right to participate as a Member in the
management and conduct of the Company's activities terminates.
(ii) Subject to Section 30-25-304 of the Act, any Transferable
Interest owned by the Person immediately before dissociation in the person's capacity
as a Member is owned by the Person solely as a Transferee.
(b) Dissociation as a Member does not discharge the former Member
from any debt, obligation, or other liability to the Company or the other Members that
was incurred while the Person was a Member nor does it release the former Member
from any obligation to contribute Additional Capital.
(c) If a Person is wrongfully dissociated from the Company, that
Person shall be liable for all damages and injuries caused by the wrongful dissociation.
10.5 [Intentionally Omittedl.
10.6 Savings Clause. Notwithstanding anything in this Article IX to the
contrary, if a dissociation arising from a Permitted Transfer, this Article IX shall not
apply.
11. DISSOLUTION AND WINDING UP
11.1 Dissolution. The Company shall be dissolved, its assets shall be
disposed of, and its affairs wound up on the first to occur of the following:
(a) Upon the entry of a decree of judicial dissolution pursuant to the
Act;
(b) Upon the affirmative vote or written consent of a Majority Interest of
the Members;
(c) The occurrence of a Dissolution Event unless within ninety (90)
days after the occurrence of such event Members holding a Majority Interest consent to
continue the business of the Company; or
(d) The sale of all or substantially all of the assets of Company.
11.2 Certificate of Dissolution. As soon as possible following the occurrence
of any of the events specified in Section 10.1, the Manager or, if none, the Members,
shall execute a Certificate of Dissolution and/or Certificate of Cancellation, as
applicable, in such form as shall be prescribed by the Idaho Secretary of State and file
the Certificate(s) as required by the Act.
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DocuSign Envelope ID: BBE03710-2564-432C-B4C6-8DCED24D51D8
11.3 Winding Up. Upon the occurrence of any event specified in Section 10.1 ,
the Company shall continue solely for the purpose of winding up its affairs in an orderly
manner, liquidating its assets, and satisfying the claims of its creditors. The Manager
or, if none, the Members, shall be responsible for overseeing the winding up and
liquidation of Company, shall take full account of the liabilities of Company and assets,
shall either cause its assets to be sold as promptly as is consistent with obtaining the
fair market value thereof and shall cause the proceeds therefrom, to the extent sufficient
therefor, to be applied and distributed as provided in Section 10.5. The Persons
winding up the affairs of the Company shall give written notice of the commencement of
winding up by mail to all known creditors and claimants whose addresses appear on the
records of the Company. The Manager or Members winding up the affairs of the
Company shall be entitled to reasonable compensation for such services.
11.4 Distributions in Kind. Any non-cash asset distributed to one or more
Members shall first be valued at its fair market value to determine the Net Profit or Net
Loss that would have resulted if such asset were sold for such value, such Net Profit or
Net Loss shall then be allocated pursuant to Section 6, and the Members' Capital
Accounts shall be adjusted to reflect such allocations. The amount distributed and
charged to the Capital Account of each Member receiving an interest in such distributed
asset shall be the fair market value of such interest (net of any liability secured by such
asset that such Member assumes or takes subject to). The fair market value of such
asset shall be determined by the Manager or by the Members or if any Member objects
by an independent appraiser (any such appraiser must be recognized as an expert in
valuing the type of asset involved) selected by the Manager (or liquidating trustee), and
approved by the Members.
11.5 Order of Payment of Liabilities Upon Dissolution. After determining
that all known debts and liabilities of the Company in the process of winding-up,
including, without limitation, debts and liabilities to Members who are creditors of the
Company, have been paid or adequately provided for, the remaining assets shall be
distributed to the Members in accordance with Section 6.5.
11.6 Limitations on Payments Made in Dissolution. Except as otherwise
specifically provided in this Agreement, each Member shall only be entitled to look
solely to the assets of the Company for the return of such Member's positive Capital
Account balance and shall have no recourse for such Member's Capital Contribution
and/or share of Net Profits (upon dissolution or otherwise) against the Manager or any
other Member.
11.7 No Deficit Restoration. Upon the liquidation of the Company within the
meaning of Section 1.704-1(b)(2)(ii)(g) of the Regulations, each Member's Capital
Account shall be adjusted for all contributions, distributions and allocations for all
taxable years including the year during which such liquidation occurs. If a Member has
a deficit in its Capital Account, such Member shall not be obligated to contribute any
amount to the Company. The allocation provisions of this Agreement are intended to
produce final Capital Account balances which reflect the aggregate cumulative
distribution priorities described in Section 6.5.
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DocuSign Envelope ID: BBE03710-2564-432C-B4C6-8DCED24D51D8
12. INVESTMENT REPRESENTATIONS
Each Member hereby represents and warrants to, and agrees with, the Manager,
the other Members, and the Company as follows:
12.1 Preexisting Relationship or Experience. (a) Such Member has a
preexisting personal or business relationship with the Manager and one or more of the
Company's officers, or control persons or (b) by reason of such Member's business or
financial experience, or by reason of the business or financial experience of such
Member's financial advisor who is unaffiliated with and who is not compensated, directly
or indirectly, by the Company or any affiliate or selling agent of the Company, such
Member is capable of evaluating the risks and merits of an investment in the
Membership Interest and of protecting such Member's own interests in connection with
this investment.
12.2 No Advertising. Such Member has not seen, received, been presented
with, or been solicited by any leaflet, public promotional meeting, newspaper or
magazine article or advertisement, radio or television advertisement, or any other form
of advertising or general solicitation with respect to the sale of the Membership Interest.
12.3 Investment Intent. Such Member is acquiring the Membership Interest
for investment purposes for such Member's own account only and not with a view to or
for sale in connection with any distribution of all or any part of the Membership Interest.
No other person will have any direct or indirect beneficial interest in or right to the
Membership Interest.
13. MISCELLANEOUS
13.1 Counsel to the Company. This Agreement has been prepared by legal
counsel to the Company ("Company Counsel"), which may also be counsel to the
Manager or any Affiliate of a Manager or any Member or any Affiliate of a Member. The
Manager may execute on behalf of the Company and the Members any consent to the
representation of the Company that Company Counsel may request pursuant to the
Idaho Rules of Professional Conduct or similar rules in any other jurisdiction ("Rules").
Each Member acknowledges that Company Counsel does not represent any Member in
the absence of a clear and explicit agreement to such effect between the Member and
Company Counsel, including without limitation in the preparation and negotiation of this
Agreement, and that in the absence of any such agreement Company Counsel shall
owe no duties directly to a Member. In the event any dispute or controversy arises
between any Members and the Company, or between any Members or the Company,
on the one hand, and a Manager (or Affiliate of a Manager) that Company Counsel
represents, on the other hand, then Company Counsel may not represent either the
Company or any such Member or Manager (or such Member's or Manager's Affiliate) in
connection with such dispute or controversy unless then agreed to in writing by all
Members, provided that Company Counsel may continue to represent any of the
Members (or their Affiliates) and/or the Manager (or its Affiliates) in matters unrelated to
29
DocuSign Envelope ID: BBE03710-2564-432C-B4C6-8DCED24D51D8
the Company and the Property, and each Member hereby consents to such
representation.
13.2 Complete Agreement. This Agreement and the Articles constitute the
complete and exclusive statement of agreement among the Members and Manager with
respect to the subject matter herein and therein and replace and supersede all prior
written and oral agreements or statements by and among the Members and Manager or
any of them. No representation, statement, condition or warranty not contained in this
Agreement or the Articles will be binding on the Members or Manager or have any force
or effect whatsoever. To the extent that any provision of the Articles conflict with any
provision of this Agreement, the Articles shall control.
13.3 Binding Effect. Subject to the provisions of this Agreement relating to
transferability, this Agreement will be binding upon and inure to the benefit of the
Members, and their respective successors and assigns.
13.4 Interpretation. In the event any claim is made by any Member relating to
any conflict, omission or ambiguity in this Agreement, no presumption or burden of proof
or persuasion shall be implied by virtue of the fact that this Agreement was prepared by
or at the request of a particular Member or such Member's counsel.
13.5 Arbitration and Mediation.
(a) Mediation of Disputes. If Members cannot resolve a dispute or
controversy regarding this Operating Agreement or the operation of the Company, they
shall submit their dispute or controversy to mediation. The parties to the dispute or
controversy shall arrange the procedure and terms of the mediation.
(b) Arbitration of Disputes. If, following mediation, the parties to a
dispute or controversy cannot resolve their dispute or controversy, they shall submit
their dispute or controversy to arbitration in accordance with the then current
Commercial Arbitration Rules of the American Arbitration Association. Any award
rendered by arbitrators shall be final, binding, and conclusive on the parties to the
arbitration, and judgment on the award may be entered in any court having jurisdiction.
Any party may commence arbitration by sending the other parties to the dispute a
written request for arbitration. The prevailing party or parties may be awarded attorney
fees, costs, and other expenses of the arbitration.
13.6 Severability. If any provision of this Agreement or the application of such
provision to any person or circumstance shall be held invalid, the remainder of this
Agreement or the application of such provision to persons or circumstances other than
those to which it is held invalid shall not be affected thereby.
13.7 Notices. Any notice, demand, approval, consent, or other communication
required or desired to be given under this Agreement shall be given in writing in the
manner set forth below, addressed to the Member or Manager at the address specified
30
DocuSign Envelope ID:BBE03710-2564-432C-B4C6-8DCED24D51D8
in the Member & Manager Schedule, or at such other address for which that party may
have given not less than five (5) business days' prior written notice to the other parties
notice under the provisions of this Section. Any notice, demand, approval, consent, or
other communication given by (a) mail shall be deemed to have been given on the
second (2nd) business day immediately following the date it was deposited in the United
States mail, first class and postage prepaid; (b) overnight common carrier courier
service shall be deemed to be given on the business day (not including Saturday)
immediately following the date it was deposited with such common carrier; (c) delivery
in person or by messenger shall be deemed to have been given upon delivery in person
or by messenger; or (d) electronic transmission shall be deemed to have been given on
the date of transmission of the entire communication, provided that (i) such transmission
occurs prior to 5:00 p.m. Pacific Time, on a business day, otherwise on the succeeding
business day, and (ii) the sending party deposits a hard copy of the original transmitted
document(s) in the United States mail, addressed to the receiving party, first class
postage prepaid, not later than the first (1 st) business day following such transmission.
13.8 Reliance on Authority of Person Signing Agreement. If a Member is
not a natural person, neither the Company nor any Member will (a) be required to
determine the authority of the individual signing this Agreement to make any
commitment or undertaking on behalf of such entity or to determine any fact or
circumstance bearing upon the existence of the authority of such individual or (b) be
responsible for the application or distribution of proceeds paid or credited to individuals
signing this Agreement on behalf of such entity.
13.9 No Interest in Company Property; Waiver of Action for Partition. No
Member has any interest in specific property of the Company. Without limiting the
foregoing, each Member irrevocably waives during the term of the Company any right
that such Member may have to maintain any action for partition with respect to the
property of the Company.
13.10 Legal Costs. If any party to this Agreement shall take any action to
enforce this Agreement or bring any action or commence any proceeding for any relief
against any other party, declaratory or otherwise, arising out of this Agreement, the
losing party shall pay to the prevailing party a reasonable sum for attorneys' fees
incurred in bringing such suit or proceeding and/or enforcing any judgment granted
therein, all of which shall be deemed to have accrued upon the commencement of such
action or proceeding and shall be paid whether or not such action or proceeding is
prosecuted to judgment. Any judgment or order entered in such action or proceeding
shall contain a specific provision providing for the recovery of attorneys' fees and costs
incurred in enforcing such judgment. For purposes of this section, attorneys' fees shall
include, without limitation, fees incurred in the following: (a) post-judgment motions;
(b) contempt proceedings; (c) garnishment, levy, and debtor and third party
examinations; (d) discovery; (e) bankruptcy litigation; and (f) appeals.
13.11 Remedies Cumulative. The remedies under this Agreement are
cumulative and shall not exclude any other remedies to which any person may be
lawfully entitled.
31
DocuSign Envelope ID:BBE03710-2564-432C-B4C6-8DCED24D51D8
13.12 Governing Law; Venue. This Agreement shall be governed by and
construed in accordance with the laws of the State of Idaho, without regard to principles
of conflict of laws.
13.13 Time of the Essence; Dates. Time is of the essence of this Agreement.
A "business day" as used in this Agreement shall mean any day other than a Saturday,
Sunday, a day on which the Federal Reserve System is closed, or a day on which
commercial banks in Idaho are authorized to close. In the event that any date specified
in this Agreement falls on a date other than a business day, it shall be deemed to fall on
the succeeding business day.
13.14 Attorney-In-Fact and Agent. Each Member, by execution of this
Agreement, irrevocably constitutes and appoints the Manager as the Member's true and
lawful attorney-in-fact and agent, with full power and authority in the Member's name,
place, and stead to execute, acknowledge, and deliver, and to file or record in any
appropriate public office: (a) any certificate or other instrument that may be necessary,
desirable, or appropriate to qualify the Company as a limited liability company or to
transact business as one in any jurisdiction in which the Company conducts business;
(b) any certificate or amendment to the Company's articles of organization or to any
certificate or other instrument that may be necessary, desirable, or appropriate to reflect
an amendment approved by the Members in accordance with the provisions of this
Agreement; (c) any certificates or instruments that may be necessary, desirable, or
appropriate to reflect the dissolution and winding up of the Company; (d) a statement
from any Idaho non-resident member stating that the Member consents to file a Idaho
tax return, to make timely payment of all taxes imposed on the Member with respect to
the income of the Company, and to be subject to personal jurisdiction in Idaho for
purposes of the collection related to the Company's income; and (e) any certificates
necessary to comply with the provisions of this Agreement. This power of attorney will
be deemed to be coupled with an interest and will survive the transfer of the Member's
Economic Interest. Notwithstanding the existence of this power of attorney, each
Member agrees to join in the execution, acknowledgment, and delivery of the
instruments referred to above if requested to do so by the Manager. This power of
attorney is a limited power of attorney and does not authorize any Manager to act on
behalf of a Member except as described in this Section.
13.15 Counterparts. This Agreement may be executed in counterparts, each of
which shall be deemed an original (including copies sent to a party by electronic
transmission) as against the party signing such counterpart, but which together shall
constitute one and the same instrument.
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
32
DocuSign Envelope ID:BBE03710-2564-432C-B4C6-8DCED24D51D8
IN WITNESS WHEREOF, the undersigned have executed this Agreement as set
forth below.
Manager: Members:
Sunny Cove, LLC, Wildwood Family LTD, a California limited
a California limited liability company partnership
DocuSigned by:
E 91�oµ Sunny Cove, LLC,
By: a California limited liability company,
Mark Engstrom, its Manager its, general partner
DocuSigned by:
Y
Mark Engstrom, its Manager
5DocuSigned by:
aS ul ' �GIo m-s
Jason Jaques, individually
DocuSigned by:
,�aw�t,S fit,avt,
James Teare, individually
FDocuSigned by:
jb(at w%bKL"
9o-3s14.()F ^
John Monley, individually
33
5474.001-2545915.1
DocuSign Envelope ID:BBE03710-2564-432C-B4C6-8DCED24D51D8
ACKNOWLEDGMENT AND ACCEPTANCE BY MANAGER
The undersigned hereby accepts appointment as a Manager of the Company as
provided in Section 5.2 above, and agrees to serve as a Manager of the Company in
accordance with Article 5 of this Agreement.
Sunny Cove, LLC,
a Californba�Umij9d liability company
Y
Mark Engstrom, its Manager
EXHIBIT:
A - Member & Manager Schedule
B — Spousal Consent
34
5474.001-2545915.1
DocuSign Envelope ID:BBE03710-2564-432C-B4C6-8DCED24D51D8
Exhibit A to
Operating Agreement for
Franklin Mile Managers, LLC
MEMBER & MANAGER SCHEDULE
MEMBERS
Name and Address of Members Capital Contribution Percentage
Interest
Wildwood Family LTD, a California $5,500.00 55%
limited partnership
837 Jefferson Boulevard
West Sacramento, CA 95691
Phone: (916) 617-4244
Email:
mark.engstrom@cushwake.com
James Teare $1,500.00 15%
Jason Jaques $1,500.00 15%
2217 Shenandoah Place
Davis, CA 95616
Phone: (916) 617-4277
Email: mason.jagues cushwake.com
John Monley $1,500 15%
265 Mercedes Court
Davis, CA 95616
Phone: (916) 754-7400
Email: johnmlepropinc.com
Total: $10,000.00 100%
A-1
5474.001-2545915.1
DocuSign Envelope ID:BBE03710-2564-432C-B4C6-8DCED24D51D8
MANAGER
Name and Address of Manager
Sunny Cove, LLC,
a California limited liability company
Attn: Mark Engstrom
837 Jefferson Boulevard
West Sacramento, CA 95691
Phone: (916) 617-4244
Email: mark.engstrom@cushwake.com
2
5474.001-2545915.1
DocuSign Envelope ID:BBE03710-2564-432C-B4C6-8DCED24D51D8
Exhibit B to
Operating Agreement for
Franklin Mile Managers, LLC
COMMUNITY PROPERTY SPOUSAL CONSENT
OPERATING AGREEMENT OF
Franklin Mile Managers, LLC
I, certify and declare that:
1. 1 am the spouse or registered domestic partner of
("Spouse"), one of the persons who has executed or otherwise agreed to be bound by all of the
terms and conditions set forth in the foregoing Operating Agreement of Franklin Mile Managers,
LLC, dated 2020, as such agreement may be amended from time to time
("Agreement").
2. My Spouse has acquired an ownership interest in Franklin Mile
Managers, LLC, an Idaho limited liability company ("LLC").
3. 1 agree to be bound by and accept my rights under the provisions of the
Agreement in lieu of all community property or other interests I may have in property subject to
the terms of the Agreement;
4. 1 grant my Spouse an irrevocable special power of attorney, which is
coupled with the interest of my spouse and myself under the Agreement, to deal with the subject
matter of the Agreement and to modify, amend, and add to the Agreement without further
signature, acknowledgment, agreement, or consent on my part.
5. 1 agree not to take any action at any time which might interfere with or
hinder the operation of the Agreement and any interest or rights now or later acquired by me or
my Spouse arising from or related to the Agreement, and any modifications, amendments, or
additions to the Agreement.
6. 1 have been afforded the opportunity to seek independent legal and tax
counsel of my own choosing to (i) help me in evaluating the character of my interest in the LLC
as community property or separate property, and (ii) advise me regarding my position with
respect to the Agreement, this Community Property Spousal Consent, the LLC, and the
interests of myself and my Spouse from a legal, economic and tax standpoint.
7. My Spouse and I have fully discussed the character of our respective
interests in the LLC (e.g., as community property or separate property) between ourselves and
have had the opportunity to seek independent legal counsel with respect to the characterization
of our respective interests in the LLC as community property or separate property.
8. 1 have read, understand, and agree to have my legal rights determined by
the Agreement.
Dated:
DocuSign Envelope ID:BBE03710-2564-432C-B4C6-8DCED24D51D8