writ of mandamus or other injunctive relief; and (e) take whatever action at law or in equity may appear

necessary or desirable to enforce its rights in and to the Leased Property subject to the applicable Lease,
subject, however, to certain limitations on the obligations of the District and the Corporation set forth in
the applicable Lease. For a discussion of the Events of Default and Remedies under each Lease, see
Appendix B - Summary of Certain Provisions of the Indentures and the Leases--2008A LEASE - Events
of Default and Remedies. All property, funds and rights acquired by the Trustee following the
termination of a Lease resulting from the occurrence of an Event of Nonappropriation, an Event of
Default or any other event upon which such Lease will terminate (see Appendix B - Summary of Certain
Provisions of the Indentures and the Leases--2008A LEASE - Effect of Termination of the Lease Term),
along with other moneys then held by the Trustee under the related Indenture and available to pay the
related 2008 Certificates, are required to be used to redeem those 2008 Certificates, if and to the extent
any such moneys are realized.

If either series of 2008 Certificates is redeemed subsequent to a termination of the related

Lease Term for an amount less than the aggregate principal amount thereof and accrued interest
thereon, such partial payment will be deemed to constitute a redemption in full of such 2008
Certificates pursuant to the applicable Indenture; and upon such a partial payment, no owner of
any 2008 Certificate of the applicable series will have any further claims for payment upon the
Corporation, the Trustee or the District.

Factors Affecting Value of Leased Property. Owners of the 2008 Certificates should not assume
that it will be possible to repossess, liquidate or otherwise dispose of the Trustee’s interest in the
applicable Leased Property, or any portion thereof, for an amount equal to the aggregate principal amount
of the related 2008 Certificates then outstanding plus accrued interest thereon.

Information about the valuation of the land and buildings comprising the 2008A Leased Property
and the 2008B Leased Property is set forth in “SECURITY FOR THE CERTIFICATES--The Leased
Property.” Because the Leased Property will consist primarily of school buildings and related
improvements of particular design and use for school purposes, the Leased Property may not be easily
converted to alternate uses. The Leased Property is subject to applicable zoning and building codes and
in some cases also is subject to subdivision plat limitations. Hill Middle School and Abraham Lincoln
High School are subject to certain residential area restrictions that may limit the commercial uses of the
properties. With respect to East High School, West High School and the Fox Street Administration
Building, the height of any structures on the land is limited by Denver’s mountain view preservation
ordinances. Most of the parcels comprising the Leased Property also are subject to various utility and
ingress/egress easements and several are subject to reserved coal or other mineral rights. With respect to
West High School, buildings existing on wastewater easements are allowed, but no new structures or
improvements which encroach on the easements may be added. In addition, certain of the school
buildings comprising the Leased Property (Hill, Merrill, Grant and Skinner Middle Schools and West
High School) have been designated as historic preservation sites and East High School is subject to an
agreement requiring preservation of the building’s architecture and structural integrity through 2028; it
may be difficult or impossible to acquire building permits in order to convert those schools to other uses.

The District’s property and casualty insurer currently values all District properties at least every
three years. The value of each building comprising each piece of Leased Property (set forth in
“SECURITY FOR THE CERTIFICATES--The Leased Property”) represents the insurance replacement
valuation of the buildings in spring 2007. The value of the land comprising the Leased Property
represents estimates of the market value in 2007 by District Facilities Management staff based on recent
offers for school district property, taking into account the fact that middle schools exist in areas on or near
to more highly-traveled roadways and are large enough for business type use and high schools are located
on highly-traveled streets with large tracts of contiguous property which could be used for major housing
expansion, business or commercial use considerations. Other than the valuations of the school buildings
for insurance purposes, no appraisals of the Leased Property have been completed. The value of the
2008A Leased Property using these estimates currently is approximately $38.6 million less than the
15
principal amount of the 2008A Certificates and the value of the 2008B Leased Property using these
estimates currently is approximately $20.4 million less than the principal amount of the 2008B
Certificates. The Leased Property may depreciate in value each year. It is not possible to predict whether
the depreciated value of the applicable Leased Property will be equal to the aggregate principal amount of
the related 2008 Certificates outstanding, plus accrued interest thereon, at any particular future point in
time. There is no guarantee that the Trustee will be able to repossess, liquidate or otherwise dispose of
its interest in the applicable Leased Property in an amount equal to the amount of the respective
outstanding 2008 Certificates secured by such Leased Property or to pay such 2008 Certificates as
originally scheduled.

Environmental Factors. The District is not aware of any significant environmental or hazardous
substance conditions with respect to any of the Leased Property. Nonetheless, the value of the Leased
Property could be adversely affected by the presence, or even by the alleged presence, of hazardous
substances. In general, the owner of property may be required by law to remedy conditions on the
property relating to releases or threatened releases of hazardous substances. The federal Comprehensive
Environmental Response, Compensation and Liability Act of 1980, sometimes referred to as “CERCLA”
or the “Superfund Act,” is the most well-known and widely applicable of these laws, but other federal,
state and local provisions pertain to hazardous substances as well. Under many of these laws, the owner
of property is obligated to investigate and remediate a hazardous substance on such property whether or
not the owner had anything to do with the generation or disposal of the hazardous substance.

In the event of foreclosure, if any of the Leased Property is determined to contain an

environmental hazard, any remediation costs would be paid from the Trust Estate prior to the payment of
2008 Certificates; in that event, the proceeds of the foreclosure may not be sufficient to pay the principal
and interest due on the applicable 2008 Certificates. The Trustee may require that it receive a Phase I or
other environmental report in form and substance satisfactory to it upon the occurrence of an Event of
Default under the applicable Indenture.

Enforceability of Remedies; Liquidation Delays

Under each Lease, the Tru r stee has th

Trustee tthee right to take possession of and dispose of its leasehold
interest in the related Leased Propert r y up
Property uupon
on an Event of Nonap a propriation or an
Nonappropriation a Event of Defa f ult under
Default
such Lease. H However, the enforceability of each Lease is subject to applicable bankruptcy laws, equitable
principles affecting the enforcement of creditors’ rights generally and liens securing such rights, and the
police powers of the District. Because the Leased Propert Propertyr y likely will be used by the Distr
t ict to provide
District
fforr the welfa
fo f re and safe
welfare f ty of school childr
safety d en (or fo
children fforr other school-related purp r oses), a cour
purposes), u t in an
court aanyy action
brought to enfo f rce the remedy of the Tru
enforce r stee to take possession of Leased Propert
Trustee r y may delay
Property
repossession fo fforr an indefi
f nite period, even th
indefinite tthough
ough th tthee District may be in defafault under the ap
default aapplicable
plicable
Lease. A As long as the Trustee is unable to take possession of the related Leased Property, it will be
unable to sell or lease such Leased Property as permitted under the Leases or to redeem or pay the related
2008 Certificates except from funds otherwise available to the Trustee under the related Indenture. See
“SECURITY FOR THE CERTIFICATES.”

Risk of Redemption or Purchase At Par Prior to Maturity

In considering whether the 2008 Certificates might be redeemed or purchased prior to maturity,
owners of the 2008 Certificates should consider the information included in this Official Statement under
the headings “THE 2008 CERTIFICATES--Redemption of 2008 Certificates” and “THE 2008
CERTIFICATES--Mandatory Tenders for Purchase.” The effect on Owners of such mandatory
purchases would be the same as an early redemption at par.

16