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Tax Exemption The legal opinion of Bryant, Miller and Olive, P.A., Bond Counsel, will include an opinion to the effect that assuming compliance with certain covenants, under existing laws, regulations, judicial decisions and rulings, (i) interest on the Bonds is excluded from gross income for purposes of federal income taxation and (ii) the Bonds are exempt from taxation under the laws of the State of Florida, except as to Florida estate taxes and taxes imposed by Chapter 220, Florida Statutes, as amended, on interest, income or profits on debt obligations owned by corporations, banks and savings associations. Interest on the Bonds is not an item of tax preference for purposes of the federal alternative minirrnun tax imposed on individuals or corporations; however, interest on the Bonds may be subject to the alternative minimum tax when any Bond is held by a corporation. For a more complete discussion of tax aspects, see "TAX EXEMPTION," herein. Authority for Issuance The Bonds are being issued, executed and delivered pursuant to Chapter 125, Florida Statutes, Resolution No. 92-146 adopted by the Board of County Commissioners of the County (the"Board") on August 18, 1992, as supplemented and other applicable provisions of law (collectively, the "Act") and pursuant to Resolution No. 95-63, of the Board, adopted May 16, 1995, and as further supplemented by Resolution No. 95-83, adopted by the Board July 11, 1995, as supplemented (the "Resolution"). Offering and Delivery of the Bonds The Bonds are offered when, as and if issued, subject to the opinionon certain legalmatters relating to their issuance by Bryant, Miller and Olive, P.A., Tallahassee, Florida, Bond Counsel, and the satisfaction of certain other conditions. It is anticipated that the Bonds in definitive form will be available for delivery to the Underwriter at DTC in New York, New York, on or about July , 2003. End of Summary Statement iii