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1985-88 Approving The Negotiated Settlement In The Case Of Loin Capital Group.1 3 KODIAK ISLAND BOROUGH RESOLUTION NO. 85 -88 -R A RESOLUTION OF THE ASSEMBLY OF THE KODIAK ISLAND BOROUGH APPROVING THE NEGOTIATED SETTLEMENT IN THE CASE OF LION CAPITAL GROUP. WHEREAS, on May 10, 1985 a meeting was held of the Official committee of School District and Municipal Creditors as well as all members of its constituency (collectively the "Committee ") in In re Lion Capital Group, et al. 84 -8 -10668 through 84 -B -10672 (HCB), matters pending in the United States Bankruptcy Court for the Southern District of New York; and WHEREAS, throughout the course of said meeting, held at the office of Anderson Russell Kill 6 Click, P.C. ( "ARKO "), 666 Third Avenue, New York, New York, a representative of Kodiak Island Borough, a member of the Committee was in attendance; and WHEREAS, at said meeting a vote was taken concerning the revised compromise and settlement of the combined claims of members of the Committee in an adversary proceeding entitled Bradford Trust Company v. Lesser, et al., 85- 5608A, in which Kodiak Island Borough is named defendant; and WHEREAS, under the terms of the proposed revised compromise and settlement, and pursuant to the calculation of all known existing assets and liabilities of the Estate of Lion Capital Group, the Committee, plus two additional parties (collectively called the "Repo Creditors ") are likely to receive pursuant to a Plan of Reorganization, $29.8 million; and WHEREAS, under the terms of the proposed revised compromise and settlement the projected $29.8 million cash proceeds or so much thereof as the Trustee can promptly distribute, less (from the Committee's portion) remaining legal fees and expenses due to ARKO as fixed by Court Order, will be distributed among the Repo Creditors on a RER rata basis, and WHEREAS, under the terms of an inter- creditor agreement reached between and among the Repo Creditors on November 9, 1984 the $29.8 will be distributed among the Repo Creditors on a pro rata basis until all Repo Creditors have recovered 70% of their claims; thereafter all the next proceeds I of the $29.8 million shall be distributed pro rata to those Repo Creditors who would have been in a position to benefit if the preference claims asserted by the Trustee on Schedule B in his Amended Answer, Counterclaim and Crossclaims had proceeded until such Repo Creditors had recovered 74% of their claims, at which time distributions would return to a pro rata distribution among all Repo Creditors; and WHEREAS, action is required to authorize our participation in and approval of the compromise and settlement as summarized hereinabove; and WHEREAS, adoption of this resolution has been this date formally moved, seconded, voted upon by us and approved, it is hereby RESOLVED, that the Assembly of the Kodiak Island Borough does hereby adopt and approve the terms of the foregoing compromise and settlement; and it is further authorized and directed, as our representative and agent, to vote, acknowledge or execute documents and instruments, and otherwise do all things necessary, convenient or proper in our name and on our behalf as is necessary to effectuate our participation in the aforesaid compromise and settlement. BE IT FURTHER RESOLVED, this resolution supersedes Resolution No. 85 -9 -R, approved February 7, 1985. Adopted this Ird day of October, 1985. KODIAK ISLAND BOROUGH ATTEST: Recommended by: Finance Director RESOLVED, that Bryce S. Weeks, Finance Director /Treasurer is hereby By/%.i A. get Borough Clerk Drafted by: Anderson, Russell, Kill & Olick, Attorneys of New York Resolution 85 -88 -9 Page 2