AGREEMENT AND PLAN OF REORGANIZATION THIS AGREEMENT AND PLAN OF REORGANIZATION (the "Agreement") is made as of the 29th day of October, 2004, by and between Pioneer Small Cap Value Fund, a Delaware statutory trust (the "Acquiring Trust"), on behalf of...Agreement and Plan of Reorganization • March 28th, 2005 • Pioneer Small Cap Value Fund • Delaware
Pioneer Small Cap Value Fund Amendment to the Agreement and Declaration of TrustPioneer Small Cap Value Fund • March 28th, 2005
The undersigned, being at least a majority of the Trustees of Pioneer Small Cap Value Fund, a Delaware statutory trust (the "Trust"), do hereby amend the Agreement and Declaration of Trust, dated December 3, 1996, as amended (the "Declaration"), as follows, such amendment to be effective on the date hereof:
GRAPHIC OMITTED][GRAPHIC OMITTED] December 10, 2004 Pioneer Small Cap Value Fund 60 State Street Boston, MA 02109 Safeco Common Stock Trust 5069 154th Place N.E. Redmond, Washington 98052 Ladies and Gentlemen: This opinion is being delivered to you in...Pioneer Small Cap Value Fund • March 28th, 2005
This opinion is being delivered to you in connection with the Agreement and Plan of Reorganization (the "Agreement") made as of October 29, 2004 by and between Pioneer Small Cap Value Fund, a Delaware statutory trust, on behalf of its sole series, Pioneer Small Cap Value Fund ("Acquiring Fund"), and Safeco Common Stock Trust, a Delaware statutory trust, on behalf of its series, Safeco Small-Cap Value Fund ("Acquired Fund"). Pursuant to the Agreement, Acquiring Fund will acquire all of the assets of Acquired Fund in exchange solely for (i) the assumption by Acquiring Fund of all of the Assumed Liabilities, as defined in the Agreement (the "Acquired Fund Liabilities"), and (ii) the issuance of Investor Class shares of beneficial interest of Acquiring Fund (the "Acquiring Fund Shares") to Acquired Fund, followed by the distribution by Acquired Fund, in liquidation of Acquired Fund, of the Acquiring Fund Shares to the shareholders of Acquired Fund and the termination of Acquired Fund (the
