Sheldon R. and Phyllis Milenbach, et al. - Page 16

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          this law precluded Irwindale from complying with the terms of the           
          Irwindale MOA.                                                              
               The Raiders continued to discuss various options with                  
          Irwindale through 1990.  Because general obligation bonds were no           
          longer an option, the later Irwindale proposals dealt mainly with           
          financing options.  Financing alternatives included an employee             
          stock option plan, which was problematic due to the numerous                
          members of the Raiders’ front office staff who were covered by              
          the NFL retirement plan, and junk bonds, which the Raiders                  
          rejected.  A larger development plan that would have included a             
          stadium and other Raiders' facilities was also rejected by the              
          Raiders.  One of the problems facing the Raiders in many of the             
          proposals was the NFL debt limitation that prevented the pledge             
          of the Raiders' franchise as security.                                      
               The Irwindale staff that worked on the negotiations with the           
          Raiders changed throughout the negotiations.  On November 6,                
          1989, the Raiders notified Irwindale that Irwindale had not                 
          fulfilled its commitments under the Irwindale MOA.  By mid- to              
          late December 1989, one of the Irwindale lead negotiators                   
          declared that the parties were back where they had started                  
          2 years earlier.  At that point, the Raiders were anticipating              
          approximately 4 to 6 months before a transaction could be                   
          completed.  As part of this new transaction, the Raiders would              
          have been expected to ensure a greater stream of revenue,                   
          approximately $19 million per year, to repay the loan.  During              




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