EXHIBIT 4.20 AMENDMENT TO THE BYLAWS OF GRUBB & ELLIS COMPANY The following amendment to Section 2.06(c)of the Bylaws of the Grubb & Ellis Company (the "Company") was adopted and approved by the Company's Board of Directors effective June 1, 1994. The following text was added to Section 2.06(c) of the Company's Bylaws: "Shares represented by proxies that reflect, with respect to a proposal, abstentions or limited voting authority, including "broker non-votes" (i.e., shares held by a broker or nominee which are represented at the meeting, but with respect to which such broker or nominee is not empowered to vote on a particular proposal or proposals), shall be counted as shares that are present and entitled to vote for purposes of determining the presence of a quorum. For purposes of determining the outcome of any proposal, shares represented by such proxies will be treated as not present and not entitled to vote with respect to the proposal."