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R-21-11VILLAGE OF DEERFIELD RESOLUTION NO. 2021- R-21-11 A RESOLUTION APPROVING AN ECONOMIC INCENTIVE AND REPAYMENT AGREEMENT WITH WALGREENS NATIONAL CORPORATION WHEREAS, the Village of Deerfield ( "Irillage') is a home rule municipality in accordance with Article VII, Section 6 of the Constitution of the State of Illinois of 1970; and WHEREAS, Walgreens National Corporation ("Walgreens') owns the parcel commonly known as 200 Wilmot Road, Deerfield, Illinois 60015 (`Property'); and WHEREAS, Walgreens currently uses the Property as its corporate headquarters; and WHEREAS, Walgreens has retail, office, and warehousing facilities throughout Illinois and the country, and sells equipment and other materials primarily to its affiliated corporations; and WHEREAS, the Village and Walgreens previously entered into that certain December 17, 2001 Agreement ( `Trion Agreement') to, among other things, obligate Walgreens to use the Property for a single order- acceptance point for sales and, in return, for Walgreens to receive a rebate from the Village of a portion of the retailers' occupation tax collected pursuant to the Illinois Retailers' Occupation Tax Act, 35 ILCS 120/1 et seq., and the Village's Home Rule Sales Tax Ordinance (Section 9-7 of the Village Code) (collectively, `Sales Tax'); and WHEREAS, the term of the Prior Agreement ends on December 31, 2021; and WHEREAS, Walgreens discovered that it had overpaid to the Illinois Department of Revenue MDOR') the Sales Tax generated from the Property, which overpayment was returned to Walgreens by IDOR; however, prior to discovering the error, the Village had, pursuant to the terms of the Prior Agreement, rebated to Walgreens a percentage of the overpayment; and WHEREAS, the Village and Walgreens desire to enter into an Economic Incentive and Repayment Agreement (`Agreement') to: (i) govern the amount and the terms of the repayment of the rebate by Walgreens to the Village; and (iii) continue to provide for a partial rebate of the Sales Tax to Walgreens in return for Owner's continued use of the Property as a single order- acceptance point for sales after the Prior Agreement terminates; and WHEREAS, the Village Board has determined that it will serve and be in the best interests of the Village and its residents to enter into the Agreement with Walgreens; NOW, THEREFORE, BE IT RESOLVED BY THE VILLAGE OF DEERFIELD, LAKE AND COOK COUNTIES, ILLINOIS, as follows: SECTION ONE: RECITALS. The foregoing recitals are incorporated into, and made a part of, this Resolution as findings of the Village Board. {00119978.1) SECTION TWO: APPROVAL OF AGREEMENT. The Agreement by and between the Village and Walgreens is hereby approved in substantially the form attached as Ex&hitA and in a final form approved by the Village Attorney. SECTION THREE: AUTHORIZATION AND EXECUTION OF THE AGREEMENT. The Village President and the Village Clerk are authorized and directed to execute and seal, on behalf of the Village, the Agreement with Walgreens in the final form approved by the Village Attorney SECTION FOUR: EFFECTIVE DATE. This Resolution will be in full force and effect from and after its passage, approval, and publication in the manner provided by law. AYES: Benton, Jester, Oppenheim, Seiden, Shapiro, Struthers NAYS: None ABSTAIN: None ABSENT: None PASSED: April 19, 2021 APPROVED: April 20, 2021 RESOLUTION NO: R-21-11 w�c.t.0 Harriet'Rosenthal, Mayor ATTEST* L � Ke -it S. Street, Village Clerk t (00119978.11 EXHIBIT A Agreement 100119978.1) ECONOMIC INCENTIVE AND REPAYMENT AGREEMENT BY AND BETWEEN THE VILLAGE OF DEERFIELD AND WALGREEN NATIONAL CORPORATION DATED AS OFN�-` 20 2021 100116954.121 ECONOMIC INCENTIVE AND REPAYMENT AGREEMENT THIS ECONOMIC INCENTIVE AND REPAYMENT AGREEMENT ("Agreemeni') is made and entered into as of this `2.04day of AP61 , 2021 (`Wffective Date'), by and between the VILLAGE OF DEERFIELD, an I inois home rule municipal corporation (" Village'), and WALGREEN NATIONAL CORPORATION, an Illinois corporation ("Owner). IN CONSIDERATION OF the recitals and mutual covenants and agreements set forth herein, the receipt and sufficiency of which are hereby acknowledged, Owner and the Village hereby agree as follows: SECTION 1. RECITALS. A. In recognition of the importance of a successful business environment to the Village's tax base, the Village desires to enhance the long-term viability of the Village's tax base and strengthen business within the Village by providing assistance and incentives to owners of local businesses. B. Owner is the record title owner of the parcel more commonly known as 200 Wilmot Road, Deerfield, Illinois 60015 (`Property'). C. Owner currently uses the Property as its corporate headquarters. D. Owner has retail, office, and warehousing facilities throughout Illinois and the country, and sells equipment and other materials primarily to its affiliated corporations. E. The Village and Owner entered into that certain December 17, 2001 Agreement to, among other things, obligate Owner to use the Property for a single order - acceptance point for Sales (as defined below) and, in return, for Owner to receive a rebate from the Village of a portion of the Municipal Sales Tax (as defined below) generated from the Property (as amended from time to time, "Prior Agreement'). F. The term of the Prior Agreement (`Prior Agreement Term') ends on December 31, 2021 (`Prior Agreement Termination Date'). G. During the Prior Agreement Term, Owner discovered that it had overpaid to the Illinois Department of Revenue (`TDOR') the Municipal Sales Tax, which overpayment was returned to Owner by IDOR. Prior to discovering the error, the Village had, pursuant to the terms of the Prior Agreement, rebated to Owner a percentage of the overpayment. H. The Village and Owner acknowledge that the Village is entitled to receive from Owner a repayment of that portion of the rebate for which Owner received a refund from IDOR ('Repayment'). I. The Village and Owner desire to enter into this Agreement to (1) govern the amount and the terms of the Repayment, and (2) continue to provide for a partial rebate of the Municipal Sales Tax to Owner in return for Owner's continued use of the Property as a (00116954.121 2 single order- acceptance point for Sales after the Prior Agreement Termination Date in a manner that will continue to enhance the business environment of the Village. SECTION 2. DEFINITIONS. Whenever used in this Agreement, the following terms have the following meanings unless a different meaning is required by the context. A. "Commencement Date" means January 1, 2022. B. "Corporate Authorities" means the President and Village Board of the Village of Deerfield. C. "Force Majeure" means a strike, lockout, act of God, or other factor beyond a party's reasonable control and reasonable ability to remedy; provided, however, that Force Majeure does not include (i) delays caused by weather conditions, unless those conditions are unusually severe or abnormal considering the time of year and the particular location of the subject property; and (ii) economic hardship, impracticability of performance, or commercial, economic, or market conditions. D. "Gross Receipts" has the meaning ascribed to it in the Retailers' Occupation Tax Act. E. "Home Rule Sales Tax" means the sales tax imposed in the Village pursuant to Village's Home Rule Sales Tax Ordinance (Section 9-7 of the Village Code) under the Home Rule Municipal Retailers' Occupation Tax Act, 65 ILCS 5/8-11-1, and the Home Rule Municipal Service Occupation Tax Act, 65 ILCS 5/8-11-5. As of the Effective Date, the Home Rule Sales Tax is one percent. F. "Municipal Sales Tax" means that portion or component of the Sales Taxes generated by Owner from sales on any portion of the Property that the Village actually receives from the State of Illinois. G. "Retailers' Occupation Tax Act" means the Illinois Retailers' Occupation Tax Act, 35 ILCS 120/1 et seq., as the same has been, and may, from time to time hereafter be, amended. H. "Sales" means any transfer or disposition of ownership of or title to tangible personal property, materials or products by Owner. I. "Sales Taxes" means only those taxes imposed and collected by the State of Illinois pursuant to the Retailer's Occupation Tax Act, the Service Use Tax Act, 35 ILCS 110/1 et seq., the Service Occupation Tax Act, 35 ILCS 115/1 et seq., the Use Tax Act, 35 ILCS 105/1 et seq., and the Home Rule Sales Tax. J. "Sales Tax Rebate" means the rebate payment to Owner of a portion of the Municipal Sales Taxes that the Village receives and that it is required to make pursuant to this Agreement. (00116954.121 K. "Sales Tax Year" means the 12-month period of time commencing on the Commencement Date, and each of the succeeding Sales Tax Years thereafter during the Term. L. "Term" shall have the meaning set forth in Section 8.13 of this Agreement. SECTION 3. REPAYMENT AND PRIOR AGREEMENT. A. Repayment. Owner acknowledges and agrees that, as of the Effective Date, Owner owes to the Village $13,162,245.98, with such amount owed reduced to a total of $8,828,652.11 by amounts previously withheld by Village ("Repayment Amount'). Owner further acknowledges and agrees that, except as provided in Sections 3.13 and 5.0 of this Agreement, its obligation to pay the Repayment Amount to the Village is independent of, and not dependent upon, Owner receiving a rebate of any Sales Taxes. B. Rea went Schedule. Owner shall pay to the Village the entire Repayment Amount pursuant to, and in strict accordance with, the schedule attached to and, by this reference, incorporated herein as Exhibit A (`Schedule'). In the event that Owner does not repay the Repayment Amount in strict accordance with the Schedule and such failure continues beyond all applicable cure and notice periods provided under this Agreement, in addition to any other remedies available to the Village, the Village, with five business days prior written notice to Owner, may deduct and retain such unpaid amount from any amounts owed to Owner under Section 5 of this Agreement and in such event, all appropriate adjustments to the Schedule shall be made to reflect such amounts deducted or retained by the Village in accordance with this Section 3.13. C. Prior A eement. Except as specifically modified by this Agreement, the Prior Agreement shall remain unmodified and in full force and effect until the Prior Agreement Termination Date. SECTION 4. MAINTENANCE OF SINGLE ORDER POINT OF SALE. A. Single Order Point of Sale. As of the Effective Date, Owner has taken, and will take, the internal corporate measures necessary to establish and maintain the Property as the single order -acceptance point for all Sales during the Term of this Agreement, and will request a General Information Letter (the WIM from the Illinois Department of Revenue seeking its concurrence with Owner's analysis that single order -acceptance takes place within the Village. Owner shall not enter into any other municipal sales tax sharing agreements with other municipalities during the Term of this Agreement. B. Closure; Notice. 1. In addition to any and all other remedies available to the Village, in the event that, at any time during the Term of this Agreement, Owner abandons, closes, or terminates the use of the Property as its single point for all Sales with shipping locations within the State of Illinois, or the Illinois Department of Revenue determines that the Property is not the point of all Sales with shipping locations in Illinois (collectively, "Closure'), then the provisions of Section 5 of this Agreement with regard to Municipal Sales Tax generated from the Property will, as of the date of the Closure, automatically terminate {00116954.12) 4 and become null and void and be of no further force or effect, and the Village will have no obligation whatsoever to perform any of the Municipal Sales Tax Rebate obligations in Section 5 of this Agreement. 2. Owner must provide the Village with no less than 60 days written notice prior to any Closure provided that such Closure is within Owner's control. SECTION 5. SALES TAX REBATE. A. Village Payment. Beginning with the Commencement Date, the Village shall distribute on a monthly basis 80 percent of the Municipal Sales Tax received by the Village and generated from the Property. If, for any reason, the State of Illinois fails to distribute the Municipal Sales Tax revenue to the Village in sufficient time for the Village to make the monthly payments, the Village must provide notice of that fact to Owner as soon as possible, but in no event no later than 15 business days after discovery of such failure. In that event, the Village must make the required Sales Tax Rebate payment within 30 days after the date on which the Village actually receives the Municipal Sales Tax revenue due the Village for the applicable monthly payment period. The parties agree that the Village may require Owner to submit copies of applicable State of Illinois sales tax returns (ST-1 Sales and Use Tax and E911 Surcharge Returns or equivalent tax return if an ST-1 form is no longer required) to verify the amount of Sales Tax generated from the Property. If the Village is unable to verify the amount of Sales Tax generated by Owner from the State of Illinois sales tax returns, Owner shall reasonably cooperate with the Village to enable the Village to verify the amount of Sales Tax generated from the Property. In no event shall the Village have an obligation to make any required Sales Tax Rebate payment to Owner if the Village does not actually receive the Municipal Sales Tax revenue from the State of Illinois. B. Errors by Owner or Village. In the event that Owner or Village discovers that it has made an error in calculating or remitting Sales Taxes to IDOR or any payments to be made under this Agreement: (i) Owner or Village shall notify the other party in writing within 10 business days after discovery of the error and the parties shall work in good faith to reconcile, adjust, recalculate, and/or payback the other party within 30 days of receipt of a written demand from either party; and GO provide all reasonably necessary cooperation between the parties in resolving any disputes with IDOR. C. Owner Offset Rights. In the event the Village fails to make the payments in strict accordance with Section 5 above and such failure continues beyond all applicable notice and cure periods provided under this Agreement, in addition to any other remedies available to Owner, Owner, with five business days prior written notice to the Village, may deduct and retain such unpaid amount from any amounts owed to the Village under Section 3 of this Agreement and in such event, all appropriate adjustments to the Schedule shall be made to reflect such amounts deducted or retained by Owner in accordance with Section 3.B. D. Change in the Law. 1. The Village and Owner acknowledge and agree that the Village's obligation to pay the Sales Tax Rebate to Owner is predicated on existing State law governing the distribution of Sales Taxes to the Village, including, without limitation, the Retailers' Occupation Tax Act. The Village and Owner further acknowledge that the General Assembly 100116954.121 5 of the State has, from time to time, considered proposals to modify or eliminate the distribution of Sales Taxes to Illinois municipalities. The Village and Owner make express provision for the effect of any change upon the operation of this Agreement in Section 5.C.2 of this Agreement. 2. In the event that the State of Illinois amends or repeals the Retailers' Occupation Tax Act or makes any other promulgation, enactment, or change in law ( "Change In Law') that eliminates the distribution of Sales Taxes to the Village, or otherwise alters the distribution formula in a manner that prevents the Village and Owner from determining with a reasonable degree of certainty the precise amount of the Municipal Sales Tax, then in such case, the parties agree to exercise their respective commercially reasonable efforts to make the appropriate equitable changes to this Agreement to carry out the intent of this Agreement. If Owner and Village fail to agree after good faith negotiations within 30 days, then this Agreement shall be mutually terminated, and become null and void and be of no further force or effect, and the Village will have no obligation whatsoever to pay to Owner any of the Municipal Sales Tax generated on or after the effective date of the Change in Law. However, if a Change in Law results in replacement taxes for the Sales Taxes directly resulting from Gross Receipts of Owner as contemplated pursuant to this Agreement, then, for purposes of this Agreement, the replacement taxes will be defined as Sales Taxes, subject in all respects to the Village's actual receipt of its portion of the replacement taxes as well as the Village's authority under state law to provide for rebate of the replacement taxes, as contemplated in this Agreement. E. Increase in Sales Tax Rate. 1. In the event that the Village increases its current Home Rule Sales Tax during the Term by 0.25% or less, then Owner shall receive the entire incremental increase in the Home Rule Sales Tax. 2. In the event that the Village increases its current Home Rule Sales Tax during the Term by more than 0.25%, including increases that combined are more than 0.25%, Owner has the right to select one of the following options at its sole discretion: (i) Terminate this Agreement by written notice to the Village within one hundred eighty (180) days after implementation of said increase; or (ii) Receive 80% of the incremental increase in the Home Rule Sales Tax. 3. In the event that Lake County's current Sales Tax of 0.25% is increased during the Term, Owner shall have the right to terminate this Agreement by written notice to the Village within one -hundred eighty (180) days after implementation of said increase. 4. In the event that the Regional Transportation Agency's ("RTA") current Sales Tax of 0.75% is increased during the Term, and said increase applies exclusively to Lake County, Owner shall have the right to terminate this Agreement by written notice to the Village within one hundred and eighty (180) days after the 100116954.121 6 implementation of said increase. F. Limited Liability. Notwithstanding any other provision of this Agreement to the contrary, the Village's obligation to pay the Sales Tax Rebate payments is not and will not be a general debt of the Village or a charge against its general credit or taxing powers, but is and will be a special limited obligation payable solely out of the Municipal Sales Tax actually received by the Village, as specifically defined in Section 2 of this Agreement. Owner has and will have no right to, and agrees that it may not, compel any exercise of the taxing power of the Village to pay the Sales Tax Rebate payments, and no execution of any claim, demand, cause of action or judgment may be levied upon or collected from the general credit, general funds or other property of the Village. No recourse may be had for any payment pursuant to this Agreement against any past, present, or future director, member, elected or appointed officer, official, agent, representative, employee, or attorney of the Village in his or her individual capacity. The limitations on liability set forth in this Section shall not apply to the acts or omissions of the Village that constitute gross negligence or willful misconduct in connection with the Village's performance of its obligation under this Agreement. SECTION 6. FORCE MAJEURE. Whenever a period of time is provided for in this Agreement for either Owner or the Village to perform any act or obligation, and Owner or the Village, as the case may be, is unable to perform or complete the act or obligation because of a Force Majeure, then upon the occurrence of the Force Majeure, the time period for the performance and completion of the acts or obligations will be extended automatically for a reasonable time to accommodate the delay caused by the Force Majeure. SECTION 7. LITIGATION AND DEFENSE OF AGREEMENT. A. Litigation. If, during the term of this Agreement, any lawsuits or proceedings are filed or initiated against either party before any court, commission, board, bureau, agency, unit of government or subunit thereof, arbitrator, or other instrumentality, that may materially affect or inhibit the ability of either party to perform its obligations under, or otherwise to comply with, this Agreement (`litigation'), the party against which the Litigation is filed or initiated, to the extent legally permissible, must promptly deliver a copy of the complaint or charge to the party and must thereafter keep the other party fully informed concerning all aspects of the Litigation. B. Defense. The Village and Owner must use their respective commercially reasonable efforts to defend the validity of this Agreement, and all ordinances and resolutions adopted and agreements executed pursuant to this Agreement, including every portion thereof and every approval given, and every action taken, pursuant thereto. Each party has the right to retain its own independent legal counsel, at its own expense, for any matter. The Village and Owner agree to reasonably cooperate with each other to carry out the purpose and intent of this Agreement. SECTION 8. TERM. (00116954.12) 7 A. Initial Term. This Agreement will be in full force and effect from the Effective Date through December 31, 2031 ("Initial Term'). B. Renewal. This Agreement shall be automatically renewed for two additional terms of five years each (each a 'Renewal Term') (the Initial Term and any Renewal Terms shall be referred to collectively as the "Term') unless either party provides the other party written notice not to renew not less than 180 days prior to the expiration of the Initial Term or any Renewal Term. C. Termination for Cause. Subject to Section 8.E of this Agreement, the Village or Owner may terminate this Agreement with 30 business days' written notice to the other party in the event of a material breach of this Agreement, which remains uncured pursuant to the terms and conditions contained in Section 11.13 of this Agreement. D. Termination by Owner. Subject to Section 8.E of this Agreement, Owner may terminate this Agreement with 180 days' prior written notice to the Village, without regard to default or breach under this Agreement. E. Survival. The Village's obligation to make Sales Tax Rebate payments, to the extent that the Village has not at that time received from the State the Municipal Sales Taxes from which the Sales Tax Rebate payments for any part of a Sales tax Year during the term will be made, shall survive the termination of this Agreement. Owner's obligation to pay the Repayment Amount, to the extent outstanding, shall survive the termination of this Agreement in accordance with the Schedule. SECTION 9. RELEASE OF INFORMATION. A. Release for Illinois Department of Revenue. Each party agrees to execute and provide all reasonable documentation necessary to cause the Illinois Department of Revenue to release to the Village the Sales Tax generated by Owner from the Property, including copies of State of Illinois Sales Tax Reports, during each of the Sales Tax Years pursuant to applicable State law. B. Confidentiality. In connection with this Agreement, each of the parties has disclosed and may continue to disclose to the other party information that relates to the disclosing party's business operations, financial condition, customers, products, services or other confidential information. Except as may be otherwise specifically agreed in writing by the parties, Village and Owner each agree that (i) all information communicated to it by the other and identified as confidential or proprietary, whether before or after the Effective Date, (ii) all information communicated to it that should have been understood by the receiving party, because of confidentiality or similar legends, the circumstances of disclosure or the nature of the information itself, to be proprietary and confidential to the disclosing party, and (Ili) the terms and conditions of this Agreement (collectively, the "Confidential Information"), shall be and shall be deemed to have been received in confidence and shall be used only for purposes of this Agreement in compliance with applicable law. C. Confidential Information. Confidential Information shall not include information that either party can demonstrate (i) was, at the time of disclosure to it, in the public domain; (ii) after disclosure to it, is published or otherwise becomes part of the public {00116954.12) 8 domain through no fault of the receiving party; (iii) was in the possession of the receiving party at the time of disclosure to it and was not the subject of a pre-existing confidentiality obligation; or (iv) was received after disclosure to it from a third party who had a lawful right to disclose such information to it. In addition, a party shall not be considered to have breached its obligations under this Section for disclosing Confidential Information of the other party to the extent required to satisfy any legal requirement of a competent governmental authority, including, without limitation, disclosure of this Agreement and other documents and information required to be disclosed, as determined by the Village, pursuant to the Illinois Open Meetings Act, 5 ILCS 120/1 et seq., and the Freedom of Information Act, 5 ILCS 140/1 et seq., provided that promptly upon receiving any such request and to the extent that it may legally do so, such party advises the other party prior to making such disclosure in order that the other party may object to such disclosure, take action to ensure confidential treatment of the Confidential Information, including without limitation cooperating with such other party acquiring a protective order with respect to such Confidential Information, or take such other action as it considers appropriate to protect the Confidential Information. SECTION 10. LIABILITY AND INDEMNITY OF VILLAGE. A. Village Procedures. The Village acknowledges that notices, meetings, and hearings have been properly given and held by the Village with respect to the approval of this Agreement, and Owner agrees not to challenge any of those actions on the grounds of any procedural infirmity or of any denial of any procedural right. B. Indemnity. To the extent not arising due to the gross negligence or intentional misconduct of the Indemnified Parties, Owner agrees to, and does hereby, hold harmless and indemnify the Village, the Corporate Authorities, all Village elected and appointed officials, officers, employees, agents, representatives, and attorneys (collectively, "Indemnified Parties"), from any and all third -party claims that may, at any time, be asserted against any of those parties in connection with W the establishment of a single order- acceptance point within the Village; and (ii) the performance by Owner of its obligations under this Agreement. C. Indemnification Procedures. Village shall promptly notify the Owner in writing of any pending or threatened third party claim, demand or circumstance that the Village has determined or would reasonably be expected to give rise to a right of indemnification under this Agreement, describing in reasonable detail the facts and circumstances with respect to the subject matter of such claim, demand or circumstance. Upon receipt of a notice of a claim for indemnity from Village, Owner shall have the right (but not the obligation) to assume the defense of any such claim and, in the event that the Owner assumes the defense and control of such claim, it shall allow the Village a reasonable opportunity to participate in the defense with its own counsel at its sole cost and expense. D. Defense Expenses. To the extent that the Owner does not assume the defense of any third party claim the Village retains its own counsel to participate in the defense under this Section 10, Owner agrees to pay, without protest, all reasonable expenses incurred by the Village in defending itself with regard to any and all of the claims identified in Section 10.13 of this Agreement. These expenses may include, without limitation, all reasonable out of pocket expenses, including reasonable attorneys' fees and experts' fees. {00116954.121 9 SECTION 11. ENFORCEMENT. A. Enforcement. The parties to this Agreement may, in law or in equity, by suit, action, mandamus, or any other proceeding, including without limitation specific performance (including, without limitation, payment by the Village to Owner of payments due to Owner under this Agreement), enforce or compel the performance of this Agreement. In the event of a judicial proceeding brought by one party to this Agreement against the other party to this Agreement pursuant to this Section, the prevailing party will be entitled to reimbursement from the unsuccessful party of all costs and expenses, including without limitation reasonable attorneys' fees, incurred in connection with the judicial proceeding. B. Notice and Cure. Neither party may exercise the right to bring any suit, action, mandamus, or any other proceeding pursuant to Section I LA of this Agreement, without first providing written notice to the other party of the breach or alleged breach and allowing 30 days to cure the breach or alleged breach. If the breach cannot be cured within the 15-day period ( "Time for Cure'), then the Time for Cure will be extended accordingly, provided that the notified party has promptly commenced to cure the breach within the Time for Cure and continued to prosecute the cure of the breach with diligence. SECTION 12. NATURE, SURVIVAL. AND TRANSFER OF OBLIGATIONS. A. Obligations. The parties agree that all charges payable pursuant to this Agreement, together with interest and costs of collection, including attorneys' fees, constitutes both the personal obligation of the party liable for its payment, and the successors of that party. B. Binding Effect. Owner acknowledges and agrees that this Agreement is binding upon Owner, and any and all of its heirs, successors, and assigns. C. Assignment. Except to any of its affiliates or subsidiaries, Owner shall not (1) assign this Agreement in whole or in part, (2) assign any of Owner's rights or obligations under this Agreement, or (3) assign any payment due or to become due under this Agreement without the prior express written approval of Village, which approval may not be unreasonably withheld, conditioned or delayed. In the event that Owner assigns this Agreement or any of its rights or obligations under this Agreement to an affiliate or subsidiary, and if such assignment results in reducing the amount of sales tax received by the Village by more than 50% per month as compared to the monthly average amount of sales tax received by the Village for any 6 consecutive monthly period within the year immediately prior to such assignment, the Village may terminate this Agreement, with 30 days' prior written notice to Owner, at any time within 425 days from the date of such assignment. SECTION 13. REPRESENTATIONS AND WARRANTIES. A. In order to induce the Village to enter into this agreement and to adopt the ordinances and grant the rights herein provided for, Owner hereby warrants and represents to the Village as follows: (i) Owner is a duly organized, validly existing corporation in good standing under the laws of the State of Illinois. (00116954.12) 10 GO Owner has the authority and the legal right to make, deliver, execute, and perform this Agreement and has taken all necessary corporate, partnership, and venture actions to authorize the execution, delivery, and performance of this Agreement. (iii) All necessary consents of any board of directors, shareholders, creditors, investors, partners, judicial, or administrative bodies, governmental authorities, or other parties regarding the execution and delivery of this Agreement have been obtained. (iv) The individuals executing this Agreement on behalf of Owner have the power and authority to execute and deliver this Agreement on behalf of Owner. (v) The execution, delivery, and performance of this Agreement: (a) is not prohibited by any requirement of law or under any contractual obligation of Owner; (b) will not result in a breach or default under any agreement to which Owner is a party or to which Owner, in whole or in part, is bound; and (c) will not violate any restriction, court order, or agreement to which Owner or Property, in whole or in part, is or are subject. B. In order to induce the Owner to enter into this Agreement, Village hereby warrants and represents to the Owner as follows: (i) Village has the authority and the legal right to make, deliver, execute, and perform this Agreement and has taken all necessary actions, including all required notices, meetings and hearings to authorize the execution, delivery, and performance of this Agreement. (ii) The individuals executing this Agreement on behalf of Village have the power and authority to execute and deliver this Agreement on behalf of Village. (iii) The execution, delivery, and performance of this Agreement: (a) is not prohibited by any requirement of law or under any contractual obligation of Village; (b) will not result in a breach or default under any agreement to which Village is a party or to which Village, in whole or in part, is bound; and (c) will not violate any restriction, court order, or agreement to which Village, in whole or in part, is or are subject. SECTION 14. GENERAL PROVISIONS. A. Entire Agreement. Except for the Prior Agreement, this Agreement constitutes the entire agreement between the parties relating to the subject matter of this Agreement. B. Amendments and Modifications. No amendment or modification to this Agreement will be effective until it is reduced to writing and approved and executed by all parties to this Agreement in accordance with all applicable statutory procedures. C. Notices. Any notice, communication, or demand required or permitted to be given under this Agreement must be in writing and must be delivered: (i) personally, (ii) by a reputable overnight courier, or (iii) by certified mail, return receipt requested, and deposited in the U.S. Mail, postage prepaid. Unless otherwise provided in this Agreement, notices will be deemed received after the first to occur of: (a) the date of actual receipt; or (b) the date that is one business day after deposit with an overnight courier as evidenced by a 100116954.12) 11 receipt of deposit; or (b) the date that is three business days after deposit in the U.S. mail, as evidenced by a return receipt. By notice complying with the requirements of this Section, each party to this Agreement has the right to change the address or the addressee, or both, for all future notices and communications to them, but no notice of a change of addressee or address will be effective until actually received. Notices and communications to the Village must be addressed to, and delivered at, the following address: With a copy to'. Village of Deerfield Village Hall 850 Waukegan Road Deerfield, Illinois 60015 Attention: Village Manager Elrod Friedman, LLP 325 N. LaSalle, Suite 450 Chicago, Illinois 60654 Attention: Steven M. Elrod Notices and communications to Owner must be addressed to, and delivered at, the following address' With a copy to: Walgreen Co. Tax Department 300 Wilmot Road Deerfield, Illinois 60015 Attn*. Greg Shirey Walgreen Co. 104 Wilmot Road, MS No. 1434 Deerfield, Illinois 60015 Attn: Director, Contracts Legal D. Governing Law. This Agreement is to be governed by, and enforced in accordance with, the internal laws, but not the conflict of laws rules, of the State of Illinois. E. Interpretation. This Agreement is to be construed without regard to the identity of the party who drafted the various provisions of this Agreement. Moreover, each and every provision of this Agreement is to be construed as though all parties to this Agreement participated equally in the drafting of this Agreement. As a result of the foregoing, any rule or construction that a document is to be construed against the drafting party is not applicable to this Agreement. M0116954.12) 12 F. Change in Laws. Except as otherwise explicitly provided in this Agreement, any reference to laws, ordinances, rules, or regulations of any kind includes the laws, ordinances, rules, or regulations of any kind as they may be amended or modified from time to time hereafter. G. Headings. The headings, titles, and captions in this Agreement have been inserted only for convenience and in no way define, limit, extend, or describe the scope or intent of this Agreement. H. Time of Essence. Time is of the essence in the performance of this Agreement. I. No Third Party Beneficiaries. Except as expressly provided in this Agreement, no claim as a third party beneficiary under this Agreement by any person, firm, or corporation may be made or will be valid against the Village. J. Severability. If any term, covenant, condition, or provision of this Agreement is held by a court of competent jurisdiction to be invalid, void, or unenforceable, the remainder of the provisions will remain in full force and effect and will in no way be affected, impaired, or invalidated. K. Calendar Days and Time. Unless otherwise provided in this Agreement, any reference in this Agreement to "day" or "days" means calendar days and not business days. If the date for giving of any notice required to be given, or the performance of any obligation, under this Agreement falls on a Saturday, Sunday, or federal holiday, then the notice or obligation may be given or performed on the next business day after that Saturday, Sunday, or federal holiday. L. Exhibits. Exhibits A through C are attached to this Agreement, and by this reference incorporated in and made a part of, this Agreement. In the event of a conflict between an Exhibit and the text of this Agreement, the text of this Agreement will control. M. Counterparts. This Agreement may be executed in several counterparts, each of which, when executed, is to be deemed to be an original, but all of which together constitute one and the same instrument. N. Waiver. Neither the Village nor Owner are or will be under any obligation to exercise any of the rights granted to them in this Agreement except as it determines to be in its best interest from time to time. The failure of the Village or Owner to exercise at any time any of those rights is not to be deemed or construed as a waiver of that right, nor will the failure void or affect the Village's or Owner's right, as the case may be, to enforce those rights or any other rights. O. Rights Cumulative. Unless expressly provided to the contrary in this Agreement, each and every one of the rights, remedies, and benefits provided by this Agreement are cumulative and are not exclusive of any other rights, remedies, and benefits allowed by law. P. Consents. Unless otherwise provided in this Agreement, whenever the consent, permission, authorization, approval, acknowledgement, or similar indication of assent of any (00116954.121 13 party to this Agreement, or of any duly authorized officer, employee, agent, or representative of any party to this Agreement, is required in this Agreement, the consent, permission, authorization, approval, acknowledgement, or similar indication of assent must be in writing and shall not be unreasonably withheld, conditioned or delayed. Q. Grammatical Usage and Construction. In construing this Agreement, pronouns include all genders and the plural includes the singular and vice versa. R. Village Authority to Execute. The Village hereby warrants and represents to Owner that the persons executing this Agreement on its behalf have been properly authorized to do so by the Corporate Authorities. [EXECUTION PAGE FOLLOWS] 100116954.12) 14 IN WITNESS WHEREOF, the parties have caused this Agreement to be executed by their duly authorized representatives as of the date first above written. ATTEST: Village herk ATTEST: M. Its: (00116954.12) 15 VILLAGE OF DEERFIELD Village President WALGREEN NATIONAL CORPORATION Its: IN WITNESS WHEREOF, the parties have caused this Agreement to be executed by their duly authorized representatives as of the date first above written. ATTEST: Village Clerk ATTEST: By: Its, 100116954.121 15 VILLAGE OF DEERFIELD Village President WALGREEN NATIONAL CORPORATION By: Its: ApproveApprovelt by artment TAX By: LAW By: PSL ACKNOWLEDGEMENTS STATE OF ILLINOIS ) SS COUNTY OF LAKE ) This instrument was acknowledged before me on lk;\ 2-0 2021 by t'66 gothe Village President of the VILLAGE OF DEERFIELD, an Illinois home rule municipal corporation, and by IoGAk S. 5� ftQA- the Village Clerk of said municipal corporation. Notary Public &I- J a. . My Commission Expires: �Z ) 40 17-024 (SEAL) STATE OF ILLINOIS ) SS COUNTY OF ) ��1RIA�AM NOTARY PLOX, STATE OF ILLINOIS WIY COMMUM Ei: NS:12/10!207d I, , a Notary Public in and for said County, in the State aforesaid, do hereby certify that personally known to me to be the of WALGREEN NATIONAL CORPORATION, an Illinois corporation, and , personally known to me to be the of said limited liability company, appeared before me this day in person and acknowledged that as such and , they signed and delivered said instrument as their free and voluntary act and as the free and voluntary act of WALGREEN NATIONAL CORPORATION, for the uses and purposes therein set forth. Given under my hand and notarial seal this day of , 2021. Notary Public My Commission Expires: (SEAL) (00116954.12) 16 ACKNOWLEDGEMENTS STATE OF ILLINOIS SS COUNTY OF LAKE This instrument was acknowledged before me on 72021 by , the Village President of the VILLAGE OF DEERFIELD, an Illinois home rule municipal corporation, and by , the Village Clerk of said municipal corporation. Notary Public My Commission Expires: (SEAL) STATE OF ILLINOIS SS COUNTY OF ti&6-OtA-0 Z "!!�s-�otary Py�bl' in and for said County, in the State aforesaid, do hereby certify that 1 ��OAi � L A -- ,personally known to me to be the v of WALGREEN NATIONAL CORPORATION, an Illinois corpora 'on, and 5YI'40-1 , personally known to me to be the llX° of said cor oratiA n, ap eared before me this days in person and acknowledged that as such c E Y,� and N `4 , , they signed and delivered said instrument as their free and voluntary act and as the free and voluntary act of WALGREEN NATIONAL CORPORATION, for the uses and purposes therein set forth. Given under my hand and notarial seal this Q(n day of �-' , 2021. My Commission Expires: Ol�a 3�oZ0o2 DZ (SEAL) OFFICIAL SEAL DEBORAH A CZEKALA NOTARY PUBLIC - STATE OF ILLINOIS MY COMMISSION EXPIRES:01123/22 Notar ublic (00116954.121 16 EXHIBIT A Repayment Schedule Sales Receipt Month Date Payment Jun-19 9/1/2019 $ 192,849.30 Jul-19 10/1/2019 122,127.33 Aug-19 11/1/2019 275,755.60 Sep-19 12/1/2019 189,137.15 Oct-19 1/1/2020 111,905.90 Nov-19 2/1/2020 158,105.84 Dec-19 3/1/2020 190,414.27 Jan-20 4/1/2020 148,149.61 Feb-20 5/1/2020 221,166.01 Mar-20 6/1/2020 167,570.10 Apr-20 7/1/2020 128,060.58 May-20 8/1/2020 208,225.50 Jun-20 9/1/2020 261,437.99 Jul-20 10/1/2020 477,303.10 Aug-20 11/1/2020 216,634.96 Sep-20 12/1/2020 283,546.13 Oct-20 1/1/2021 113,227.15 Nov-20 2/1/2021 247,069.17 Dec-20 3/1/2021 221,725.66 Jan-21 4/1/2021 399,182.52 Feb-21 5/1/2021 133,767.46 Mar-21 6/1/2021 133,767.46 Apr-21 7/1/2021 133,767.46 May-21 8/1/2021 133,767.46 Jun-21 9/1/2021 133,767.46 Jul-21 10/1/2021 133,767.46 Aug-21 11/1/2021 133,767.46 Sep-21 12/1/2021 133,767.46 Oct-21 1/1/2022 133,767.46 Nov-21 2/1/2022 133,767.46 Dec-21 3/1/2022 133,767.46 Jan-22 4/1/2022 133,767.46 Feb-22 5/1/2022 133,767.46 Mar-22 6/1/2022 133,767.46 Apr-22 7/1/2022 133,767.46 May-22 8/1/2022 133,767.46 Jun-22 9/1/2022 133,767.46 W0116954.12) 17 Jul-22 10/1/2022 133,767.46 Aug-22 11/1/2022 133,767.46 Sep-22 12/1/2022 133,767.46 Oct-22 1/1/2023 133,767.46 Nov-22 2/1/2023 133,767.46 Dec-22 3/1/2023 133,767.46 Jan-23 4/1/2023 133,767.46 Feb-23 5/1/2023 133,767.46 Mar-23 6/1/2023 133,767.46 Apr-23 7/1/2023 133,767.46 May-23 8/1/2023 133,767.46 Jun-23 9/1/2023 133, 767.46 Jul-23 10/1/2023 133,767.46 Aug-23 11/1/2023 133,767.46 Sep-23 12/1/2023 133,767.46 Oct-23 1/1/2024 133,767.46 Nov-23 2/1/2024 133,767.46 Dec-23 3/1/2024 133,767.46 Jan-24 4/ 1/2024 133, 767.46 Feb-24 5/ 1/2024 133,767.46 Mar-24 6/ 1/2024 133, 767.46 Apr-24 7/1/2024 133,767.46 May-24 8/ 1/2024 133, 767.46 Jun-24 9/1/2024 133,767.46 Jul-24 10/1/2024 133,767.46 Aug-24 11/1/2024 133,767.46 Sep-24 12/1/2024 133,767.46 Oct-24 1/1/2025 133,767.46 Nov-24 2/1/2025 133,767.46 Dec-24 3/1/2025 133,767.46 Jan-25 4/1/2025 133,767.46 Feb-25 5/1/2025 133,767.46 Mar-25 6/1/2025 133,767.46 Apr-25 7/1/2025 133,767.46 May-25 8/1/2025 133,767.46 Jun-25 9/1/2025 133,767.46 Jul-25 10/1/2025 133,767.46 Aug-25 11/1/2025 133,767.46 Sep-25 12/1/2025 133,767.46 Oct-25 1/1/2026 133,767.46 Nov-25 2/1/2026 133,767.46 Dec-25 3/1/2026 133,767.46 (00116954.12) 18 Jan-26 4/1/2026 133,767.46 Feb-26 5/1/2026 133,767.46 Mar-26 6/1/2026 133,767.46 Apr-26 7/1/2026 133,767.46 May-26 8/1/2026 133,767.46 Jun-26 9/1/2026 133,767.46 Jul-26 10/1/2026 133,767.21 $ 13,162,245.98 Repayment received prior to Effective Date, and shall be retained by the Village as * part of the repayment obligation. (00116954.12) 19