Santa Monica Pictures, LLC, Perry Lerner, Tax Matters Partner - Page 279

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          the draft term sheet and refining the terms and provisions in the           
          draft term sheet.  The memorandum stated that the letter                    
          agreement “would require Generale Bank and CLIS simply to                   
          transfer their respective assets to a Newco in exchange for                 
          preferred interests which will be monetized.”25  Rockport Capital           
          would form a Delaware limited liability company (“Newco”) and               
          contribute assets (cash and securities) to Newco in an amount               
          mutually agreed by Rockport, CLIS, and Generale Bank, in exchange           
          for all the common interests in Newco; CLIS would contribute all            
          the stock of MGM Group Holdings to Newco in exchange for                    
          preferred membership interests in Newco; and Generale Bank would            
          contribute to Newco, in exchange for preferred membership                   
          interests, some $1.050 billion of obligations that MGM Group                
          Holdings owed to Generale Bank.  Regarding documentation, the               
          first draft letter agreement provided:                                      
                    3.  Documentation.  The Transactions will be                      
               documented in the form of an Exchange and Contribution                 
               Agreement * * * among Newco, CLIS and * * * [Generale                  
               Bank] which will contain customary representations,                    
               warranties and indemnification provisions, including,                  
               without limitation, (i) representations and warranties                 
               by CLIS concerning Group’s assets and the absence of                   
               any undisclosed liabilities, (ii) representations and                  
               warranties by CLIS as to its basis in the stock of                     
               Group, (iii) representations and warranties by * * *                   
               [Generale Bank] as to the original amount of the loans                 

               25 Mr. Geary explained that “by this time [the time of the             
          draft letter agreement] clearly there was going to be a second              
          letter, a put letter.  That’s what I understood to be monetized.            
          There was a put available.  We didn’t have to wait, you know, for           
          the time of the deal.”                                                      





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