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Blooming on Project. refinancing the costs of acquisition of the high school facility at <br />8201 Park Avenue South,, Bloomington and financing certain improvements to such facility; <br />Bond Counsel: the firm of Briggs and Morgan, Prol"essionial Asp ociati,0111, Of <br />1. "K <br />Minneapous, Minnesota or another nationally recognized bond counsiel selected by the City; any <br />4 <br />opinion of Bond Counsel shall be a written opinion on signed by Bond Counsel; <br />Borrower: Concordia Academy Association of Schools, a Minnesota nonprofit <br />corporation its successors and assigns, and any surviving, resulting or transferee business entity <br />t�l <br />which ma assum.e its obligations in accordance with the provisions of this Agreement', <br />y �1 <br />Closing: the date of physical delivery of the Note to the Len der <br />-1 <br />Code: the Internal Revenue Code of 1986, as amended, and the temporary, final or <br />proposed regulations promufRated thereunder; <br />Counsel., an attorney designated by or acceptable to the Lender, duly admitted to practice <br />I T <br />law before the highest court of any state,, an attorney for the Borrower or the City maybe eligiol e <br />for appointment as Counsel; <br />the City of Roseville, Minnesota-, its successors and assigns; <br />Date of Taxabilily: shall have the meaning ascribed to it in Section 4.5(2), hereof; <br />Determination of "a ahilit : shall have the meaning ascribed to, it in Section 4.5(2) <br />Eciuipment: any and all machinery, equipment, furniture and other tangible personal <br />property purchased or to be purchased by the Borrower with the proceeds of the Loan and all <br />replacements and substitutions therefore, <br />Event of Default: any of the events described in Section 6.1 hierelof; <br />Improvements-, *improvements and additions to existing buildings, 'including any <br />Equipment and tangible personal property, to be constructed or instal led by the Borrower on the <br />Land. The Project specifically does not 'Include any facilities that may be used as a chapel or <br />primarily used for religious instruction or worship, which sectarian facilities have been financed <br />with other funds available to the Borrower and not from Note proiceeds- <br />Issuance Expenses: shall mean any and all costs and expenses relating to the issuance, <br />sale and delivery of the Note, including, but not limited to, any fees of the Lendier, all fees and <br />expenses of legal counsel, financial consultants, feasibility consultants and accountants, any fee <br />to be paid to the City, Bloomington, the cost of preparation and printing of this Agreement, the <br />Mortgage, the Security Agreement,, the Resolution, the Pledge Agreement, the Note and all other <br />related documents, and all other expenses relating to the issuance, sale and delivery of the Note <br />and any other costs which are treated as "issuance costs" within the meaning of Section 147(g) of <br />the Code; <br />2144817v1 2, <br />