HomeMy WebLinkAboutReso 114-1991RESOLUTION NO. 114-91
CITY COUNCIL, CITY OF SOUTH SAN FRANCISCO, STATE OF CALIFORNIA
A RESOLUTION PROVIDING FOR ANNUAL INSTALLMENT ASSESSMENTS
AND AUTHORIZING ISSUANCE OF BONDS FOR
THE WEST PARK 1, 2 AND 3 PARKS AND
PARKWAYS ASSESSMENT DISTRICTS
I hereby certify that the within Resolution was regularly
introduced and adopted by the City Council of the City of South
San Francisco at a re§u]ar meeting held on the
llth day of September , 1991, by the following vote:
AYES:
NO~S:
ABSTAIN:
ABSENT:
Councilmembers Richard A. Haffey, Gus Nicolopulos, John R.
Penna, Roberta Cerri Teglia, and Mayor Jack Drago
None
None
None
ATTEST:
RESOLUTION NO. 114-91
CITY COUNCIL, CITY OF SOUTH SAN FRANCISCO, STATE OF CALIFORNIA
A RESOLUTION PROVIDING FOR ANNUAL INSTALLMENT ASSESSMENTS
AND AUTHORIZING ISSUANCE OF BONDS FOR
THE WEST PARK 1, 2 AND 3 PARKS AND
PARKWAYS ASSESSMENT DISTRICTS
Adopted September 1~, 1991
TABLE OF CONTENTS
Page
Section 1.01.
Section 1.02.
Section 1.03.
Section 1.04.
ARTICLE I
GENERAL; DEFINITIONS
Determination To Issue Bonds
Rules Of Construction
Equal Security
Definitions
Section 2 01.
Section 2 02
Section 2 03
Section 2 04
Section 2 05
Section 2 06
Section 2 07
Section 2 08
Section 2 09
Section 2 10
Section 2 11
Section 2 12
Section 2 13
Section 2.14.
Section 2.15.
ARTICLE II
ISSUANCE OF BONDS
Bonds Authorized
Special Assessments
Issuance Of Bonds
Maturities Of Bonds
Interest On Bonds
Designation Of Agent
Form Of Bonds
Preparation And Delivery Of Bonds
Execution Of Bonds
Transfer And Exchange Of Bonds
Temporary Bonds
Bond Registration Books
Bonds Mutilated, Lost, Destroyed
Or Stolen
Redemption Prior To Maturity
Refunding Of Bonds ·
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Section 3.01.
Section 3.02.
ARTICLE III
SALE AND DELIVERY OF BONDS
Sale Of Bonds
Further Authority
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ARTICLE IV
APPLICATION OF PROCEEDS OF BONDS; ESTABLISHMENT OF FUNDS
Section 4.01.
Section 4.02.
Section 4.03.
Section 4.04.
Section 4.05.
Section 4.06.
Application Of Proceeds Of
Sale Of Bonds
Improvement Fund
Reserve Fund
Redemption Fund
Cost Of Issuance Account
Investment Of Funds
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ARTICLE V
COVENANTS OF THE CITY; TAX COVENANTS
Section 5.01.
Section 5.02.
Section 5.03.
Section 5.04.
Section 5.05.
Section 5 06.
Section 5 07.
Section 5 08.
Section 5 09.
Section 5 10.
Section 5 11.
Section 5 12.
Section 5 13.
Levy And Collection Of Assessments
Covenant To Foreclose
No Advances From Available Surplus
Funds
Punctual Payment; Compliance
With Documents
No Priority For Additional Obligations
No Arbitrage
Compliance With Rebate Requirements
Information Report
Private Business Use Limitation
Private Loan Limitation
Federal Guarantee Prohibition
Further Assurances
Amendment
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Section 6 01
Section 6 02
Section 6 03
Section 6 04
Section 6 05
Section 6 06
Section 6 07
ARTICLE VI
MISCELLANEOUS
Funds And Accounts
Partial Invalidity
Defeasance
Repeal Of Inconsistent Resolutions
Authority Of Treasurer
Certified Copies
Effective Date Of The Resolution
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EXHIBIT A Form Of Bond
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RESOLUTION NO.
CITY COUNCIL, CITY OF SOUTH SAN 'FRANCISCO, STATE OF CALIFORNIA
A RESOLUTION PROVIDING FOR ANNUAL INSTALLMENT ASSESSMENTS
AND AUTHORIZING ISSUANCE OF BONDS FOR
THE WEST PARK 1, 2 AND 3 PARKS AND
PARKWAYS ASSESSMENT DISTRICTS
WHEREAS, this Council has heretofore duly levied special
assessments against the real property within the boundaries of
West Park 1 Parks and Parkways Maintenance District, West Park 2
Parks and Parkways Maintenance District, and West Park 3 Parks and
Parkways Maintenance District, all of which are hereinafter
collectively referred to as the "Assessment District," pursuant to
the Improvement Act of 1911;
NOW, THEREFORE, BE IT RESOLVED by the City Council of the
City of South San Francisco as follows:
ARTICLE I
GENERAL: DEFINITIONS
Section 1.01. DETERMINATION TO ISSUE BONDS. The City
Council hereby determines that the estimated cost of the Project
is grea'ter than can be conveniently raised from a single annual
assessment and that the estimated cost of the Project be raised by
an assessment levied and collected in installments over a period
of not to exceed thirty (30) years. The City Council further
determines that bonds shall be issued pursuant to the Improvement
Bond Act of 1915 to represent and be secured by the Assessment (as
herein defined).
Section 1.02. RULES OF CONSTRUCTION. Ail references in this
Resolution to "Articles", "Sections", and other subdivisions are
to the corresponding Articles, Sections or subdivisions of this
Resolution; and the words "herein", "hereof", "hereunder" and
other words of similar import refer to this Resolution as a whole
and not to any particular Article, Section or subdivision hereof.
Words of the masculine gender shall be deemed and construed
to include correlative words of the feminine and neuter genders.
Unless the context shall otherwise indicate, words importing the
singular number shall include the plural number and vice versa,
and words importing persons shall include corporations and
associanions, including public bodies, as well as natural persons.
Section 1.03. EQUAL SECURITY. In consideration of the
acceptance of the Bonds by the Owners thereof, this Resolution
shall be deemed to be and shall constitute a contract between the
City and the Owners from time to time of the Bonds; and the
covenants and agreements herein set forth to be performed on
behalf of the City shall be for the equal and proportionate
benefit, security and protection of all Owners of the Bonds
without preference, priority or distinction as to security or
otherwise of any of the Bonds over any of the others by reason of
the number or date thereof or the time of sale, execution or
delivery thereof, or otherwise for any cause whatsoever, except as
expressly provided therein or herein.
Section 1.04. DEFINITIONS. Unless the context otherwise
requires, the terms defined in this Section shall, for all
purposes of this Resolution and of any Supplemental Resolution and
of the Bonds and of any certificate, opinion, request or other
document herein mentioned, have the meanings herein specified.
"Act" means the Improvement Act of 1911 and Sections 22500 to
22679, inclusive, of the Streets and Highways Code of California.
"Agent" means the entity to be hereafter appointed by the
Council to perform the duties of authentication, registration,
transfer and payment of the Bonds and the Agent's assigns or any
other corporation or association which may at any time be
substituted in its place.
"Assessment" means the special assessments levied annually
against the real property within the boundaries of the Assessment
District pursuant to the Act to pay the cost of the Project and to
pay Debt Service on the Bonds.
"Assessment District" means that portion of the City included
within the boundaries of West Park 1 and 2 Parks and Parkways
Maintenance District and West Park 3 Parks and Parkways
Maintenance District.
"Authorized Investments" means any securities (other than
those identified in paragraphs (~) and (d) of Section 53601 of the
Government Code of the State) in which the City may legally invest
funds subject to its control, pursuant to Article 1, commencing
with Section 53600, of Chapter 4 of Part 1 of Division 2 of Title
5 of the Government Code of the State, as now or hereafter
amended.
"Available Surplus Funds" means any surplus moneys held by
the City at the end of each Fiscal Year in excess of the amounts
required to pay lawful municipal obligations incurred in that
Fiscal Year.
"Bond Date" means the date upon which the Bonds are issued.
"Bond Denomination" means the amount of $5,000 or any
integral multiple thereof, which is the minimum amount in which
the Bonds may be issued, except that one Bond may contain any odd
amount.
"Bond Law" means the Improvement Bond Act of 1915, Division
10 of the Streets and Highways Code of California.
"Bond Purchase Agreement" means the agreement applicable to
the portion of the Bonds being sold between the City and the
Original Purchaser whereby the City agrees to sell and the
Original Purchaser agrees to buy all or a designated portion of
the Bonds.
"Bond Registration Books" means the books maintained by the
Agent pursuant to Section 2.12 for the registration and transfer
of ownership of the Bonds.
"Bond Year" means the twelve-month period beginning on the
anniversary of the Closing Date in each year and ending on the day
prior to the anniversary date of the Closing Date in the following
year except that (i) the first Bond Year shall begin on the
Closing Date, and (ii) the last Bond Year may end on a prior
redemption date.
"Bonds" or "Bonds of this Issue" means Limited Obligation
Improvement Bonds, City of South San Francisco, West Park 1, 2 and
3 Parks and Parkways Assessment Districts, issued and at any time
Outstaniing.
"Certificate of the City" means a written certificate,
statement, request, order or requisition signed by the Treasurer
or by any other officer of the City duly authorized by the Council
for that purpose.
"City" means the City of South San Francisco, a municipal
corporation and general law city of the State of California duly
organized and validly existing under and by virtue of the
Constitution and the laws of the State of California.
"City Manager" means the City Manager of the City.
"Clerk" means the City Clerk of the City.
"Closing Date" means the date upon which there is an exchange
of any of the Bonds for the proceeds representing the purchase
price of such Bonds by the Original Purchaser thereof.
"Costs of Issuance" means all expenses incurred in connection
with the authorization, issuance, sale and delivery of the Bonds,
including but not limited to compensation, fees and expenses of
the City and the Agent and their respective counsel, compensation
to any financial consultants and underwriters (other than those
taken as discount on the Closing Date), legal fees and expenses,
filing and recording costs, costs of preparation and reproduction
of documents, costs of compliance with Tax Regulations relating to
rebate to the United States under Section 5.07 and costs of
printing, mailing and publication of notices with respect to the
City and the Project.
"Cost of Issuance Account" means the account of that name
established and held by the Treasurer pursuant of Section 4.05
hereof.
"Council" means the City Council of the City.
"Debt Service" means the scheduled amount of interest and
amortization of principal payable on the Bonds during the period
of computation, excluding amounts scheduled during such period
which relate to principal which has been retired before the
beginning of such period.
"Excess Investment Earnings" means and includes the following
amounts with respect to the Bonds:
(al the excess of
(i) the aggregate amount earned from the Closing
Date on all Nonpurpose Investments in which Gross
Proceeds are invested (other than amounts attributable
to an excess described in this paragraph (a)), over
(ii) the amount which would haVe been earned if
the Yield on such Nonpurpose Investments (other than
amounts attributable to an excess described in this
paragraph (a)) had been equal to the Yield on the Bonds,
plus
(b) any income attributable to the excess described in the
preceding paragraph (a).
"Federal Securities" means any of the following which at the
time of investment are legal investments under the laws of the
State for the moneys proposed to be invested therein:
(a) direct general obligations of the United States of
America (including obligations issued or held in book entry form
on the books of the Department of the Treasury of the United
States of America); and
(b) obligations of any department, agency or instrumentality
of the United States of America the timely payment of principal of
and interest on which are unconditionally and fully guaranteed by
the UniLed States of America.
"Fiscal Year" means the period commencing on July 1 of each
year and terminating on the next succeeding June 30.
"Gross Proceeds" means and includes, with respect to any
Bonds, all of the following amounts:
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(a) original proceeds, namely, the net amounts remaining
from the sale of the Bonds after payment of all Costs of Issuance,
including accrued interest but excluding underwriter's and~
original issue discount, and excluding any such proceeds which
become transferred proceeds (determined in accordance with
applicable Tax Regulations) of obligations issued to refund the
Bonds in whole or in part;
(b~ investment proceeds, namely, amounts received at any
time from the investment of any proceeds described in the
preceding clause (a), or from the investment of amounts described
in this clause (b), in Nonpurpose Investments, increased by the
amount of any profits and decreased (if necessary, below zero) by
the amount of any losses on such investments, excluding such
amounts which become transferred proceeds (determined in
accordance with applicable Tax Regulations) of obligations issued
to refund the Bonds in whole or in part;
(cl sinking fund proceeds, namely, amounts, other than
amounts described in the preceding clauses (a) and (b), which are
held in the Redemption Fund and any other Fund or Account which is
reasonably expected to be used to pay Debt Service;
(dI Investment Property pledged as security for payment of
Debt Service by the City;
(e) any amounts, other than amounts described elsewhere in
this definition, used to pay Debt Service; and
(f) amounts received as a result of the investment of
amounts described in this definition.
"Improvement Fund" means the fund of that name established
and held by the Treasurer pursuant 'to Section 4.02 hereof.
"Interest Payment Date" means each date upon which interest
on the Bonds is payable, beginning March 2, 1992, and semiannually
on each March 2 and September 2 thereafter until maturity.
"Investment Property" means any security (as said term is
defined in section 165(g)(2)(A) or (B) of the Tax Code),
obligation, annuity or investment-type property, excluding,
however, obligations (other than specified private activity bonds
defined in section 57(e)(5) and (6) of the Tax Code) the interest
on which is exempt from income tax under section 103 of the Tax
Code.
"Nonpurpose Investment" means any Investment Property which
is acquired with the Gross Proceeds and is not acquired in order
to carry out the governmental purpose of the Bonds.
"Original Purchaser" means the first purchaser of the Bonds
from the City.
"Outstanding", when used as of any particular time with
reference to Bonds, means all Bonds therefore executed, issued and
delivered by the City under this Resolution except:
(a) Bonds theretofore cancelled by the Agent or surrendered
to the Agent for cancellation;
(bi~ Bonds paid or deemed to have been paid within the
meaning of Section 2.14; and
(c) Bonds in lieu of or in substitution for which other
Bonds shall have been executed, issued and delivered by the City
pursuant to this Resolution or any Supplemental Resolution.
"Owner" or "Registered Owner", when used with respect to any
Outstanding Bond, means the person in whose name the ownership of
such Bond shall be registered on the Bond Registration Books.
"Principal Office" means the main or principal office of the
Agent handling its corporate trust business.
"Private Business Use" means use directly or indirectly in a
trade or business carried on by a natural person or in any
activity carried on by a person other than a natural person,
excluding use by a governmental unit and use by any person as a
member of the general public.
"Proceeds", when used with reference to the Bonds, means the
face amount of the Bonds, plus accrued interest and premium, if
any, less original issue discount, if any.
"Project" means lighting improvements, irrigation facilities,
handrails, play and playground equipment, gazebo, sidewalks,
steps, tree planting and appurtenant work and improvement in and
for the Assessment District.
"P'archase Price", for the purpose of computation of the Yield
of the Bonds, has the same meaning as the term "is.sue price" in
sections 1273(b) and 1274 of the Tax Code, and, in general, means
the initial offering price to the public (not including bond
houses and brokers, or similar persons or organizations acting in
the capacity of underwriters or wholesalers) at which price a
substantial amount of the Bonds are sold or, if the Bonds are
privately placed, the price paid by the Original Purchaser of the
Bonds or the acquisition cost of such original purchaser. The
term "Purchase Price", for the purpose of computation of the Yield
of Nonpurpose Investments, means the fair market value of the
Nonpurpose Investments on the date of use of Gross Proceeds for
acquisition thereof, or if later, on the date that Investment
Property constituting a Nonpurpose Investment becomes a Nonpurpose
Investment of the Bonds.
"Record Date" means, with respect to the Bonds, the fifteenth
(15th) ~ay immediately preceding an Interest Payment Date.
"Redemption Fund" means the fund of that name established and
held by the Treasurer pursuant to Section 4.04 hereof.
"Redemption Price" means, with respect to any Bond, the
principal amount thereof, plus the applicable premium, if any,
payable upon redemption thereof pursuant to the Resolution.
"Redemption Premium" means 3% of the principal amount of the
Bonds.
"Reserve Fund" means the fund of that name established and
held by the Treasurer pursuant to Section 4.03 hereof.
"Reserve Requirement" means the least of ten percent (10%) of
the ininial offering price of the Bonds to the public or 125% of
average annual debt service or the maximum annual debt service on
the Bonds. For purposes of Reserve Requirement, "initial offering
price to the public" means the principal amount of the Bonds plus
any accrued interest and any original issue premium and less any
original issue discounts.
"Resolution" or "Resolution of Issuance" means this
Resolution, as originally adopted or as it may from time to time
be supplemented, modified or amended by any Supplemental
Resolution pursuant to the provisions hereof.
"Sale Documents" means the Official Statement and the Bond
Purchase Agreement with respect to the sale of the Bonds to the
Original Purchaser.
"S~ate" means the State of California.
"Supplemental Resolution" means any resolution, agreement,
resolution or other instrument hereafter duly adopted or executed
by the City in accordance with the provisions of this Resolution.
"Tax Code" means the Internal Revenue Code of 1986, as
amended. Any reference to a provision of the Tax Code shall
include the applicable Tax Regulations with respect to such
provision.
"Tax Regulations" means temporary and permanent regulations
promulgated under the Tax Code.
"Treasurer" means, for all purposes hereof, including the
execution of the Bonds pursuant to Section 2.09 hereof, the
Treasurer or designee thereof of the City.
"Yield" means that yield which, when used in computing the
present worth of all payments of principal and interest (or other
payments in the case of Nonpurpose Investments which require
payments in a form not characterized as principal and interest) on
a Nonpurpose Investment or on the Bonds produces an amount equal
to the Purchase Price of such Nonpurpose Investment or the Bonds,
as the case may be, all computed as prescribed in the applicable
Tax Regulations.
ARTICLE II
ISSUANCE OF BONDS
Section 2.01. BONDS AUTHORIZED. Ail acts, conditions and
things required by law to exist, happen and be performed precedent
to and in the issuance of the Bonds have existed, happened and
been performed in due time, form and manner as required by law,
and the Council is now authorized pursuant to each and every
requirement of law to issue the Bonds in the manner and form as in
this Resolution provided.
Section 2.02. SPECIAL ASSESSMENTS. The special assessments
comprising the initial Assessment are specifically set forth in
two reports prepared by the Director of Parks, Recreation and
Community Services, one for West Park 1 and 2 Parks and Parkways
Maintenance Districts and the other for West Park 3 Parks and
Parkways Maintenance District, approved by the Council on July 24,
1991 and[ July 10, 1991, respectively, and on file in the office of
the City Clerk, and said assessments and accompanying diagram are
confirmed. The special assessments set forth in said reports
shall be deemed to be the first or initial assessment for the
fiscal year 1991-92 pursuant to Sections 22585 to 22595,
inclusive, of the Act. The balance of the Assessment is comprised
of annual special assessments to be hereafter levied and collected
in the manner set forth in Section 22500 to 22679, inclusive, of
the Act. The improvements comprising the Project are hereby
ordered. The estimated cost of the Project is $1,400,000, and the
number of annual installments and fiscal years during which they
are to be collected is not to exceed thirty (30) years, namely,
the fiscal years 1991-92 to 2020-21, inclusive. The adoption of
this Resolution shall constitute the levy of the Assessment for a
total aggregate amount which may be collected in annual
installments. Assessments levied to pay the principal of, and
interest on, any Bond issued pursuant to this Resolution shall not
be reduced or terminated if doing so would interfere with the
timely retirement of the debt.
The City Clerk shall forthwith:
(a) deliver the initial Assessment to the Superintendent of
Streets, together with a diagram of the Assessment District, as
approved and confirmed by this Council, with a certificate of such
confirmation and of the date thereof, executed by the Clerk,
attached thereto. Said Superintendent of Streets shall record
said assessment and diagram in his office in a suitable book to be
kept for that purpose, and append thereto his certificate of the
date of such recording, and such recordation shall be and
constitLte the assessment roll herein.
(b) cause a copy of said assessment diagram and a notice of
assessment, executed by the Clerk, to be filed and recorded,
respectively, in the office of the County Recorder of the County
of San Mateo, such notice to be in substantially the form provided
in Section 3114 of the Streets and Highways Code.
From the date of recording of said notice of assessment, all
persons shall be deemed to have notice of the contents of such
assessment. The appropriate officer or officers are hereby
authorized to pay any and all fees required by law in connection
with the above.
The boundaries of the Assessment District are described as
shown on a map of the Assessment District filed in the office of
the City Clerk, which indicates by a boundary line the extent of
the territory included in the proposed assessment district. The
map contains the name of the City and a distinctive designation in
words or by number of the district shown on it. The City Clerk
shall endorse certificates on the original and at least one copy
of this map evidencing the above filing and the date and adoption
of this resolution, and shall forthwith file a copy of the map
with the County Recorder of the County of San Mateo, in which
County all of the Assessment District is located. The County
Recorder shall endorse on the copy of the map the time and date of
filing and shall fasten the same securely in a book of maps of
assessment districts which he shall keep in his office, and index
the map by the name of the City and by the distinctive designation
of the district as shown on such map.
Section 2.03. ISSUANCE OF BONDS. The Bonds, in the
aggregaLe principal amount of not to exceed the principal amount,
the Debt Service on which shall not exceed the amount of revenue
estimated to be raised from the special assessments comprising the
Assessment over thirty (30) years, and shall be issued as
hereinafter provided upon the security of the Assessment. The
Bonds shall be known as "Limited Obligation Improvement Bonds,
City of South San Francisco, West Park 1, 2 and 3 Parks and
Parkways Assessment Districts." This Resolution is intended and
shall be deemed to be the resolution of intention to do the work
within Lhe meaning of the Bond Law.
Section 2.04. MATURITIES OF BONDS. The Bonds shall be
issued in only fully registered form, without coupons, in the Bond
Denomination or any integral multiple thereof, so long as no Bond
shall have more than one maturity date. The Bonds shall be dated
and mature on September 2 in each of the years and in the amounts
set forth in the Sale Documents. The Bonds shall be numbered or
otherwise identified as determined by the Agent.
Section 2.05. INTEREST ON BONDS. The Bonds shall bear
interest at the rate or rates set forth in the Sale Documents.
Interest on the Bonds shall be payable on each Interest
Payment Date to the person whose name appears on the Bond
Registration Books as the Owner thereof as of the Record Date
immediamely preceding each such Interest Payment Date, such
interest to be paid by check or draft of the Agent mailed to the
Owner, at the address of such Owner as it appears on the Bond
Registration Books. Principal of and premium (if any) on any Bond
shall be paid upon presentation and surrender thereof at the
Principal Office of the Agent. Both the principal of and interest
and prenium (if any) on the Bonds shall be payable in lawful money
of the United States of America.
The Bonds shall bear interest from the Interest Payment Date
next preceding the date of authentication of the Bonds (except for
any Bond which is authenticated on an Interest Payment Date, in
which event such Bond shall bear interest from such date of
authentication, and except for any Bond which is authenticated
prior to the first Interest Payment Date, in which'event such Bond
shall bear interest from the Bond Date); provided, however, that
if, as of the date of authentication of any Bond, interest thereon
is in default, such Bond shall bear interest from the date to
which interest has previously been paid or made available for
payment in full.
Section 2.06. DESIGNATION OF AGENT. The entity to be
hereafter appointed by the Council, is hereby designated as the
Agent to perform the actions and duties required under this
Resolution for the authentication, transfer, registration, and
payment of the Bonds. The Treasurer is hereby authorized and
directed to enter into agreements with the Agent in furtherance of
the actions and duties of the Agent under this Resolution.·
Section 2.07. FORM OF BONDS. The Bonds, the form of Agent's
certificate of authentication, and the form of assignment to
appear thereon, shall be substantially in the respective form set
forth in Exhibit "A" attached hereto and by this reference
incorporated herein, with necessary or appropriate variations,
omissions and insertions, as permitted or required by this
Resolution.
Section 2.08. PREPARATION AND DELIVERY OF BONDS. Upon the
award of sale of the Bonds pursuant to the Sale Documents, the
Treasurer is hereby directed to cause the Bonds to be prepared in
accordance with this Resolution and to cause their delivery upon
their completion and execution to the Agent who shall authenticate
and deliver the Bonds to the Original Purchaser, upon receipt of
the puzchase price therefor, and upon receipt of the request of
the City.
Section 2.09. EXECUTION OF BONDS. The Bonds shall be signed
in the name and on behalf of the City with the manual or facsimile
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signatures of the Treasurer and attested by the manual or
facsimile signature of the Clerk. The Bonds shall then be
delivered to the Agent for authentication by it. In case any
officer who shall have signed any of the Bonds shall cease to be
such officer before the Bonds so signed shall have been
authentScated or delivered by the Agent or issued by the City,
such Bonds may nevertheless be authenticated, delivered and issued
and, upon such authentication, delivery and issue, shall be as
binding upon the City as though the individual who signed the same
had continued to be such officer of the City. Also, any Bond may
be signed on behalf of the City by any individual who on the
actual date of the execution of such Bond shall be the proper
officer although on the nominal date of such Bond such individual
shall not have been such officer.
OnLy such of the Bonds as shall bear thereon a certificate of
authentScation in substantially the form set forth in Exhibit "A",
manually executed by the Agent, shall be valid or obligatory for
any purpose or entitled to the benefits of this Resolution, and
such certificate of the Agent shall be conclusive evidence that
the Bonds so authenticated have been duly authenticated and
delivered hereunder and are entitled to the benefits of this
Resolution. The Agent's certificate of authentication on any
Bonds shall be deemed to be executed by it if signed by an
authorized officer or signatory of the Agent, but it shall not be
necessary that the same officer or signatory sign the certificate
of authentication on all of the Bonds issued hereunder.
Section 2.10. TRANSFER AND EXCHANGE OF BONDS. Any Bond may,
in accordance with its terms, be transferred upon the Bond
Registration Books by the person in whose name it is registered,
in person or by his duly authorized attorney, upon surrender of
such Bond for cancellation, accompanied by delivery of a written
instrument of transfer in a form· approved by the Agent, duly
executed. Whenever any Bond shall be surrendered for transfer,
the Agent shall thereupon authenticate and deliver to the
transferee a new Bond or Bonds of like tenor, maturity and
aggregate principal amount. Bonds may be exchanged at the
Principal Office of the Agent, for Bonds of the same tenor and
maturity and of other authorized denominations. No Bonds the
notice of redemption of which has been given pursuant to Section
2.14 shall be subject to transfer or exchange pursuant to this
Section. Neither the City nor the Agent shall be required to make
such exchange or registration or transfer of Bonds during the
fifteen (15) days immediately preceding any Interest Payment Date.
Section 2.11. TEMPORARY BONDS. The Bonds may be issued
initially in temporary form exchangeable for definitive Bonds when
ready for delivery. The temporary Bonds may be printed,
lithographed or typewritten, shall be of such denominations as may
be determined by the Council and may contain such reference to any
of the provisions of this Resolution as may be appropriate. Every
temporary Bond shall be executed by the officers designated and in
the manner provided in Section 2.09 hereof and be registered and
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authentScated by the Agent upon the same conditions and in
substantially the same manner as the definitive Bonds. If the
Council issues temporary Bonds, it will execute and 'furnish
definitive Bonds without delay, and thereupon the temporary Bonds
may be surrendered, for cancellation, in exchange therefor at the
Principal Office of the Agent, and the Agent shall authenticate
and deliver in exchange for such temporary Bonds an equal
aggregase principal amount of definitive Bonds of authorized
denominations. Until so exchanged, the temporary Bonds shall be
entitle~ to the same benefits under this Resolution as definitive
Bonds authenticated and delivered hereunder.
Section 2.12. BOND REGISTRATION BOOKS. The Agent will keep
or cause to be kept at its Principal Office sufficient Bond
Registration Books for the registration and transfer of the Bonds,
which shall at all times during regular business hours be open to
inspect£on by the City; and, upon presentation for such purpose,
the Agent shall, under such reasonable regulations as it may
prescribe, register or transfer or cause to be registered or
transferred, on said books, Bonds as hereinbefore provided.
Section 2.13. BONDS MUTILATED, LOST, DESTROYED OR STOLEN.
If any Bond shall become mutilated, the Agent shall thereupon
authenticate and deliver, a new Bond of like maturity and
principal amount in exchange and substitution for the Bond so
mutilated, but only upon surrender to the Agent of the Bond so
mutilated. Every mutilated Bond so surrendered to the Agent shall
be cancelled by it and delivered to, or upon the order of, the
City. If any Bond issued hereunder shall be lost, destroyed or
stolen, evidence of such loss, destruction or theft may be
submitted to the City and the Agent and, if such evidence be
satisfactory to them and indemnity satisfactory to them shall be
given, ~the Agent shall thereupon authenticate and deliver, a new
Bond of like maturity and principal amount in lieu of and in
substitution for the Bond so lost, destroyed or stolen (or if any
such Bond shall have matured or shall have been called for
redemptLon, instead of issuing a substitute Bond the Agent may pay
the same without surrender thereof upon receipt of indemnity
satisfactory to the Agent). The City may require payment of a
reasonable fee for each new Bond issued under this Section and of
the expenses which may be incurred by the City and the Agent. Any
Bond issued under the provisions of this Section in lieu of any
Bond alleged to be lost, destroyed or stolen shall constitute an
original contractual obligation on the part of the City whether or
not the Bond alleged to be lost, destroyed or stolen be at any
time enforceable by anyone, and shall be equally and
proportionately entitled to the benefits of this Resolution with
all other Bonds secured by this Resolution.
Section 2.14. REDEMPTION PRIOR TO MATURITY. Each Bond, or
any portion thereof in the amount of the Bond Denomination or any
integral multiple thereof, outstanding may be redeemed and paid in
advance of maturity upon any Interest Payment Date in any year by
giving 30-day's notice by registered or certified mail or personal
12
service to the Registered Owner as required by applicable
provisions of the Bond Law and by paying the principal amount
thereof together with the Redemption Premium plus interest to the
date of advanced maturity, unless sooner surrendered, in which
event said interest will be paid to the date of payment, all in
the manner and as provided in the Bond Law.
The Treasurer shall cause to be called for redemption and
retire Bonds upon prepayment of assessments in amounts sufficient
therefor, or whenever sufficient surplus funds are available
therefor in the Redemption Fund.
The provisions of Part 11.1 of the Bond Law are applicable to
the advance payment of assessments and to the calling of the
Bonds.
Section 2.15. REFUNDING OF BONDS. The Bonds may be refunded
by the City pursuant to Divisions 11 or 11.5 of the Streets and
Highways Code of California upon the conditions as set forth in
appropriate proceedings therefor, all as determined by the'
Council.
ARTICLE III
SALE AND DELIVERY OF BONDS
Section 3.01. SALE OF BONDS. The Bonds shall be sold by
negotiation to Stone & Youngberg, as Original Purchaser.
Section 3.02. FURTHER AUTHORITY. The officers of the City
are hereby authorized and directed to negotiate the terms and
conditions of such sale within parameters to be hereafter
established by this Council and to execute all documents and take
such acLions as they may deem necessary or advisable in order to
carry out and perform the purposes of this Resolution, and the
execution or taking of such action shall be conclusive evidence of
such necessity or advisability.
The City Manager and the Clerk are authorized to complete and
to approve changes in any provisions of this Resolution in order
to accomplish the delivery of any of the Bonds on schedule; such
changes may be accomplished by attachment of a certificate
executed by both such officers to this Resolution on file in the
office of the Clerk.
13
ARTICLE IV
APPLICATION OF PROCEEDS OF BONDS:
ESTABLISHMENT OF FUNDS
Section 4.01. APPLICATION OF PROCEEDS OF SALE OF BONDS.
Upon receipt of the proceeds of sale of the Bonds on the Closing
Date, the proceeds thereof shall be forthwith set aside, paid over
and deposited by the Treasurer, as set forth in the Sale Documents
and Certificate of the City and this Article IV.
Section 4.02. IMPROVEMENT FUND. There is hereby created a
separate fund to be known as the "City of South San Francisco,
West Park 1, 2 and 3 Parks and Parkways Assessment Districts,
Improve~.ent Fund" (the "Improvement Fund"), which shall be held in
trust by the Treasurer. The Treasurer shall disburse moneys in
the Improvement Fund for the purpose of paying or reimbursing the
costs of acquiring and constructing the Project, including but not
limited to all costs incidental to or connected with such
acquisition and construction: Disbursements from the Improvement
Fund shall be subject to the provisions of Sections 5.09 and 5.10
hereof. Any surplus remaining after payment of all said costs and
expenses shall be used for maintenance of facilities of the
Assessment District.
Section 4.03. RESERVE FUND. There is hereby created a
special fund known as the "City of South San Francisco, West Park
1, 2 and 3 Parks and Parkways Assessment Districts, Reserve Fund"
(the "Reserve Fund"). The amount of the Reserve Fund shall not
exceed the Reserve Requirement. The moneys in the Reserve Fund
shall constitute a trust fund for the benefit of the Registered
Owners of the Bonds and shall be administered by the Treasurer of
the City in accordance with and pursuant to the provisions of Part
16 of the Bond Law; provided that proceeds from redemption or sale
of the properties with respect to which payment of delinquent
assessments and interest thereon was paid from the Reserve Fund,
shall be credited to the Reserve Fund; and provided further that
for the purposes of maintaining the Reserve Requirement and
providing for any required reduction of the amount of money in the
Reserve Fund during the term of the Bonds pursuant to section 8887
of the Bond Law, and applicable provisions of the Tax Code, all
proceeds from investment of moneys in the Reserve Fund in excess
of the Reserve Requirement shall be credited upon the assessments,
except as otherwise provided in Section 5.07 hereof.
Section 4.04. REDEMPTION FUND. There is hereby created a
special fund known as the "City of South San Francisco, West Park
1, 2 and 3 Parks and Parkways Assessment Districts, Redemption
Fund" (the "Redemption Fund"). The Treasurer shall place in the
Redemption Fund any amounts of accrued interest upon the Bonds
from the Bond Date to the Closing Date and premium (if any)
received upon the sale of the Bonds, together with any capitalized
interest funded as a part of the purchase price of the Bonds and
14
all sums received from the collection of unpaid assessments
provided in Section 5.01 hereof, and of the interest and penalties
thereon.
Section 4.05. COST OF ISSUANCE ACCOUNT. There is hereby
created within the Improvement Fund, a special account to be known
ag the "City of South San Francisco, West Park 1, 2 and 3 Parks
and Parkways Assessment Districts, Cost of Issuance Account" (the
"Cost of Issuance Account"), which the City hereby covenants and
agrees to cause to be maintained and which shall be held in trust
by the Treasurer. The moneys in the Cost of Issuance Account
shall be used in the manner provided by law solely for the purpose
of the payment of Costs of Issuance, on or after the Closing Date.
Any funds remaining in the Cost of Issuance Fund on the date that
is six nonths after the Closing Date, shall be transferred to the
Improve~.ent Fund.
Section 4.06. INVESTMENT OF FUNDS. Moneys in the
Improvenent Fund, Redemption Fund, and the Reserve Fund shall,
whenever practicable, be invested in Authorized Investments,
maturinc on a date prior to which such moneys are expected to be
required. Any income therefrom or interest thereon shall accrue
to and be deposited in the fund from which said moneys were
invested, subject to the provisions of Section 5.07 hereof.
ARTICLE V
COVENANTS OF THE CITY: TAX COVENANTS
Section 5.01. LEVY AND COLLECTION OF ASSESSMENTS. The City
hereby covenants to take all actions legally required by the Act
or otherwise to levy annual special assessments against the real
property iL the Assessment District subject to assessment pursuant
to law in at least the amounts required to pay Debt Service on the
Bonds in each year during which they are Outstanding and to cause
said assessments to be collected annually in the time and manner
provided by law. The annual assessments comprising the
Assessment, shall be payable in the same manner and at the same
time an~ in the same installments as the general taxes on real
property are payable, and become delinquent at the same times and
in the same proportionate amounts and bear the same proportionate
penalties and interests after delinquency as do the general taxes
on real property. All sums received from the collection of said
assessments and of the interest and penalties thereon shall be
placed in the Redemption Fund.
Section 5.02. COVENANT TO FORECLOSE. The City hereby
covenants with and for the benefit of the Owners of the Bonds that
it will order, and cause to be commenced within 150 days following
the tax-default date, and thereafter diligently prosecuted, an
action in the superior court in and for the County of San Mateo to
foreclose the lien of any assessment or installment thereof not
15
paid when due, pursuant to and as provided in Sections 8830
through 8835, inclusive, of the Bond Law.
Section 5.03. NO ADVANCES FROM AVAILABLE SURPLUS FUNDS. The
City shall not be obligated to advance available surplus funds of
the City to cure any deficiency which may occur in the Redemption
Fund; provided, however, that said determination shall not prevent
the City, in its sole discretion, from so-advancing funds.
Section 5.04. PUNCTUAL PAYMENT; COMPLIANCE WITH DOCUMENTS.
The City shall punctually pay or cause to'be paid the interest and
principal to become due with respect to all of the Bonds in strict
conformity with the terms of the Bonds and of this Resolution, and
will faithfully observe and perform all of the conditions,
covenants and requirements of this Resolution and all Supplemental
Resolutions.
Section 5.05. NO PRIORITY FOR ADDITIONAL OBLIGATIONS. The
City covenants that no additional bonds or other obligations shall
be issued or incurred having any priority over the Bonds in
payment of principal or interest out of the-Assessment. Nothing
in this Resolution shall prohibit or impair the authority of the
City to issue bonds or other obligations secured by and payable
from Assessments which are on a parity with the Bonds, upon such
terms and in such principal amounts as the City may determine.
Section 5.06. NO ARBITRAGE. The City shall not take, nor
permit nor suffer to be taken, any action with respect to the
proceeds of any of the Bonds which would cause any of the Bonds to
be "arbitrage bonds" within the meaning of the Tax Code.
Section 5.07. COMPLIANCE WITH REBATE REQUIREMENTS. The City
shall assure compliance with applicable requirements contained in
the Tax Code and Tax Regulations for rebate of Excess Investment
Earnings, if any, to the federal government.
Section 5.08. INFORMATION REPORT. The Treasurer is hereby
directed to assure the filing of an information report for the
Bonds in compliance with section 149(e) of the Tax Code.
Section 5.09. PRIVATE BUSINESS USE LIMITATION. Not more
than ten percent (10%) of the Proceeds of the Bonds shall be used
in a manner which would cause the Bonds to become "private
activity bonds" under and within the meaning of section 141(a) of
the Tax Code.
Section 5.10. PRIVATE LOAN LIMITATION. Not more than five
percent (5%) of the Proceeds of the Bonds shall be used, directly
or indirectly, to make or finance a loan (other than loans
constituting Nonpurpose Obligations or assessments) to persons
other than state or local government units.
16
Section 5.11. FEDERAL GUARANTEE PROHIBITION. The City shall
not take any action or permit or suffer any action to be taken if
the result of the same would be to cause any of the Bonds to be
"federally guaranteed" within the meaning of section 149(b) of the
Tax Code.
Section 5.12. FURTHER ASSURANCES. The City will adopt,
make, execute and deliver any and all such further resolutions,
instruments and assurances as may be reasonably necessary or
proper to carry out the intention or to facilitate the performance
of this Resolution, and for the better assuring and confirming
unto the Owners of the Bonds the rights and benefits provided in
this Resolution.
Section 5.13. AMENDMENT.. Without the consent of the Owners
of the Bonds, the City hereafter may amend this Resolution to add,
modify or delete provisions if the same is necessary or desirable
to assure compliance with section 148(f) of the Tax Code relating
to rebane of Excess Investment Earnings or as otherwise required,
to assure the exemption from federal income taxation of interest
on the Bonds.
ARTICLE VI
MISCELLANEOUS
Section 6.01. FUNDS AND ACCOUNTS. Any fund or account
required by this Resolution to be established by the Treasurer and
held and maintained by the Treasurer or the Agent may be
established and maintained in the accounting records of the
Treasurer or the Agent either as a fund or an account, and may,
for the purposes of such records, any audits thereof and any
reports or statements with respect thereto, be treated either as a
fund or an account; but all such records with respect to all such
funds and accounts shall at all times be maintained in accordance
with sound accounting practices and with due regard for the
protection of the security of the Bonds and the rights of every
Owner thereof. ~
Section 6.02. PARTIAL INVALIDITY. If any one or more of the
covenants or agreements, or portions thereof, provided in this
Resolution to be performed on the part of the City, the Council or
the Agent should be contrary to law, then such covenant or
covenanLs, such agreement or agreements, or such portions thereof,
shall be null and void and shall be deemed separable from the
remaining covenants and agreements or portions thereof and shall
in no way affect the validity of this Resolution or of the Bonds;
but the Owner shall retain all the rights and benefits accorded to
them under applicable provisions of law. The Council hereby
declares that it would have adopted this Resolution and each and
every other section, paragraph, subdivision, sentence, clause and
phrase hereof, and would have authorized the issuance of the Bonds
17
pursuant hereto, irrespective of the fact that any one or more
sections, paragraphs, subdivisions, sentences, clauses or phrases
of this Resolution or the application thereof, to any person or
circumstances may he held to be unconstitutional, unenforceable or
invalid.
Section 6.03. DEFEASANCE. The Bonds shall no longer be
deemed to be outstanding and unpaid if the City shall have made
adequate provision for the payment, in accordance with the Bonds
and this Resolution, of the principal, interest and premiums, if
any, to'become due thereon at maturity or upon call and redemption
prior to maturity. Such provision shall be deemed to be adequate
if the Council shall, on behalf of the Assessment District, have
irrevocably set aside, in a special trust fund or account, cash
or Federal Securities which when added to the interest earned or
to be earned thereon shall be sufficient to make said payments as
they become due and to redeem any Bonds Outstanding on the
earliest possible redemption date.
Section 6.04. REPEAL OF INCONSISTENT RESOLUTIONS. Any
resolution of the Council, and any part of such resolution,
inconsistent with this Resolution, is hereby repealed to the
extent of such inconsistency.
Section 6.05. AUTHORITY OF TREASURER. Ail actions mandated
by this Resolution to be performed by the Treasurer may be
performed by the designee thereof or such other official of the
City or independent contractor, consultant or trustee duly
authorized by the City to perform such action or actions in
furtherance of all or a specific portion of the requirements
hereof.
Section 6.06. CERTIFIED COPIES. The Clerk shall furnish a
certified copy of this resolution to the Treasurer, to the Agent
and to the Auditor of the County of San Mateo.
Section 6.07. EFFECTIVE DATE OF THE RESOLUTION. This
Resolution shall become effective upon the date of its adoption.
18
EXHIBIT A
[FORM OF BOND]
Registered
Number A-
United States of America
State of California
County of San Mateo
Registered
$
Limited Obligation Improvement Bond
City of South San Francisco
West Park 1, 2 and 3 Parks and Parkways
Assessment Districts
Interest Rate
Maturity Date
REGISTERED OWNER:
PRINCIPAL AMOUNT:DOLLARS
Bond Date CUSIP
, 1991
Under and by virtue of the Improvement Bond Act of 1915,
Division 10 (commencing with Section 8500) of the Streets and
Highways Code of California (the "Act"), the City of South San
Francisco (the "City"), County of San Mateo, State of California,
will, out of the redemption fund for the payment of the bonds
issued to represent special assessments made for the acquisition,
work and improvements more fully described in Resolution No.
A Resolution Providing for Annual Installment Assessments and
Authorizing Issuance of Bonds for the West Park 1, 2 and 3 Parks
and Parkways Assessment Districts (the "Resolution of Issuance")
adopted by the City Council of the City on , 1991, pay to
the registered owner named above or registered assigns, on the
maturity date stated above, the principal amount stated above, in
lawful money of the United States of America and in like manner
will pay interest from the interest payment date next preceding
the date on which this bond is authenticated, unless this bond is
authenticated and registered as of an interest payment date, in
which event it shall bear interest from such interest payment
date, or unless this bond is authenticated and registered prior to
March 2, 1992, in which event it shall bear interest from its
date until payment of the principal amount shall have been
discharged, at the rate per annum stated above, payable
semiannually on March 2 and September 2 in each year commencing on
March 2, 1992. Both the principal hereof and redemption premium
Exhibit A-1
hereon are payable at the Corporate Trust Department of
, as Authentication Agent, Transfer
Agent, Registrar and Paying Agent (the "Agent"), in
, and the interest
hereon is payable by check or draft mailed to the registered owner
hereof at the owner's address as it appears on the records of the
Agent, or at such address as may have been filed with the Agent,
for tha~ purpose, as of the 15th day immediately preceding each
interest payment date.
ThSs bond will continue to bear interest after maturity at
the rate above stated; provided, it is presented at maturity and
payment thereof is refused upon the sole ground that there are not
sufficient moneys in said redemption fund with which to pay same.
If it is not presented at maturity, interest thereon will run
until maturity.
ThSs bond shall not be entitled to any benefit under the Act
or the Resolution of Issuance, or become valid or obligatory for
any purpose, until the certificate of authentication and
registration hereon endorsed shall have been dated and signed by
the Agent.
IN WITNESS WHEREOF, said City of South San Francisco has
caused ~his bond to be signed by manual or facsimile signature by
the Treasurer of the City and by the manual or facsimile signature
of its City Clerk, and has caused its corporate seal to be
reproduced in facsimile hereon all as of the day of
, 1991.
CITY OF SOUTH SAN FRANCISCO
Treasurer
City Clerk
[SEAL]
Exhibit A-2
-- CERTIFICATE OF AUTHENTICATION AND REGISTRATION
This is one of the bonds described in the within mentioned
Resolution of Issuance, which has been authenticated and
registered on
, Agent
By
Authorized Officer
Exhibit A-3
This bond is one of several annual series of bonds of like
date, tenor, and effect, but differing in amounts, maturities and
interest rates, issued by the City of South San Francisco under
the Act and the Resolution of Issuance, for the purpose of
providing means for paying for the improvements described in the
Resolution of Issuance, and is secured by the moneys in said
redemption fund and by the special assessments made for the
payment of said improvements, and, including principal and
interest, is payable exclusively out of said fund.
This bond is transferable by the registered owner hereof, in
person or by the owner's attorney duly authorized in writing, at
the office of the Agent, subject to the terms and conditions
providei in the Resolution of Issuance, including the payment of
certain charges, if any, upon surrender and cancellation of this
bond. Upon such transfer, a new registered bond or bonds, of any
authorized denomination or denominations, of the same maturity,
and for the same aggregate principal amount, will be issued to the
transferee in exchange therefor.
Bonds shall be registered only in the name of an individual
(including joint owners), a corporation, a partnership, or a
trust.
Neither the City nor the Agent shall be required to make such
exchange or registration of transfer of bonds during the 15 days
immediately preceding any interest payment date.
The City and the Agent may treat the registered owner hereof
as the absolute owner for all purposes, and the City and the Agent
shall not be affected by any notice to the contrary.
This bond or any portion of it in the amount of five thousand
dollars ($5,000), or any integral multiple thereof,' may be
redeemed and paid in advance of maturity upon the second day of
March or September in any year by giving at least 30 days' notice
by registered or certified mail or by personal service to the
registered owner hereof at the registered owner's address as it
appears on the registration books of the Agent and by paying
principal and accrued interest together with a premium equal to 3
percentum of the principal.
This bond is a limited obligation improvement bond because,
under the Resolution of Issuance, the City is not obligated to
advance funds from the City treasury to cover any deficiency which
may occur in the Redemption Fund for the Bonds; however, the City
is not prevented, in its sole discretion, from so advancing funds.
Exhibit A-4
I hereby certify that the 'kollowing is a correct copy of the
signed Legal opinion of Jones Hall Hill & White, A Professional
Law Corporation, San Francisco, California, addressed to the City
of Soutk San Francisco and on file in my office, dated the date of
delivery of and payment for the bond therein described.
City Clerk
City of South San Francisco
OPINION:
$ Limited Obligation Improvement Bonds,
City of South San Francisco,
West Park 1, 2 and 3 Parks and
Parkways Assessment Districts
We have acted as Bond Counsel in connection with the issuance
by the City of South San Francisco (the "City") of $
Limited Obligation Improvement Bonds, West Park 1, 2 and 3 Parks
and Parkways Assessment Districts, dated , 1991 (the
"Bonds"), pursuant to Division 10 of the Streets and Highways Code
of California (the "Act") and Resolution No. (the
"Resolution") of the City adopted , 1991. We have
examined the law and such certified proceedings and other papers
as we deem necessary to render this opinion.
As to questions of fact material to our opinion, we have
relied upon representations of the City contained in the
Resolution and in the certified proceedings and other
certifications of public officials furnished to us, without
undertaking to verify such facts by independent investigation.
Based upon our examination, we are of the opinion, under
existing law, that:
1. The City is a municipal corporation and general law city
of the State of California duly organized and validly existing
under and by virtue of the Constitution and the laws of the State
of California with power to adopt the Resolution, perform the
agreements on its part contained therein, and issue the Bonds.
2. The Resolution has been duly adopted by the City and
constitutes a valid and binding obligation of the City enforceable
upon the City.
3. Pursuant to the Act, the Resolution creates a valid lien
on the funds pledged by the Resolution for the security of the
Bonds on a parity with other bonds (if any) issued or to be issued
under the Resolution, subject to no prior lien granted under the
Act.
Exhibit A-5
4. The Bonds have been duly authorized, executed and
delivered by the City and are valid and binding special
obligations of the City, payable solely from the sources provided
therefor in the Resolution.
5. The interest on the Bonds is excluded from gross income
for federal income tax purposes and is not an item of tax
preference for purposes of the federal alternative minimum tax
imposed on individuals and corporations; it should be noted,
however, that, for the purpose of computing the alternative
minimum tax imposed on such corporations (as defined for federal
income tax purposes), such interest is taken into account in
determining certain income. The opinions set forth in the
preceding sentence are subject to the condition that the City
comply with all requirements of the Internal Revenue Code of 1986
that must be satisfied subsequent to the issuance of the Bonds in
order that interest thereon be, or continue to be, excluded from
gross income for federal income tax purposes. The City has
covenanLed to comply with each such requirement. Failure to
comply with certain of such requirements may cause the inclusion
of interest on the Bonds in gross income for federal income tax
purposes to be retroactive to the date of issuance of the Bonds.
We express no opinion regarding other federal tax consequences
arising with respect to the Bonds.
6. The interest on the Bonds is exempt from personal income
taxation imposed by the State of California.
The rights of the owners of the Bonds and the enforceability
of the Bonds and the Resolution may be subject to bankruptcy,
insolvency, reorganization, moratorium and other similar laws
affecting creditors' rights heretofore or hereafter enacted and
may also be subject to the exercise of judicial discretion in
appropriate cases.
Respectfully submitted,
A Professional Law Corporation
Exhibit A-6
ABBREVIATIONS
The following abbreviations, when used in the inscription on
the face of this Note, shall be construed as though they were
written out in full according to applicable laws or regulations:
TEN CO_M -- as tenants in common
UNIF GIFT MIN ACT
Custodian
TEN ENT -- as tenants by the
entireties
JT TEN -- as joint tenants with
right of survivorship
and not as tenants in
common
(Cust) (Minor)
under Uniform Gifts to Minors
Act
(State)
ADDITIONAL ABBREVIATIONS MAY ALSO BE USED
THOUGH NOT IN THE LIST ABOVE
Exhibit A-7
(FORM OF ASSIGNMENT)
For value received, the undersigned do(es) hereby sell,
assign and transfer unto
(Name, Address and Tax Identification or Social Security
Number of Assignee)
the within Bond and do(es) hereby irrevocably constitute and
appoint , attorney, to transfer the same on
the registration books of the Trustee, with full power of
substitution in the premises.
Dated:
Signature Guaranteed:
NOTICE: Signature(s) must
guaranteed by a member firm of
the New York Stock Exchange or
a commercial bank of trust
company
be NOTICE: The signature on this
assignment must correspond
with the name(s) as written on
the face of the within Bond in
every particular without
alteration or enlargement or
any change whatsoever.
Exhibit A-8