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The Resolution contains covenants of the County to comply with provisions <br />of the Internal Revenue Code of 1986, as amended (the "Code"), and applicable <br />regulations promulgated thereunder, inter alia, to preserve the exclusion of <br />interest on the Series 1993 Bonds from gross income for federal income tax <br />purposes. <br />The principal of and interest on the Bonds are payable solely from and <br />secured by a lien on and pledge of the Pledged Funds, as defined in the <br />Resolution, which include the Net Revenues, as that phrase is defined in the <br />Resolution, of the System. Reference is made to the Resolution for terms and <br />conditions upon which certain receipts and revenues pledged under the Resolution <br />may be released from such pledge, and for terms and conditions upon which <br />additional bonds having a lien upon and right to payment from such Net Revenues <br />on a parity with the Series 1993 Bonds may be issued from time to time. <br />The Series 1993 Bonds shall not constitute a general obligation or <br />indebtedness of the County, and the holders thereof shall never have the right <br />to require or compel the exercise of the power of the County to levy ad valorem <br />taxes for the payment of the principal of and interest on the Series 1993 Bonds. <br />As Bond Counsel, we have examined, among other things: certified copies <br />of certain proceedings of the Board with respect to the Series 1993 Bonds and <br />other proofs submitted to us that are relevant to the issuance and sale of the <br />Series 1993 Bonds; a certified copy of the Resolution; certain documents required <br />by the Resolution to be furnished as conditions precedent to issuance and <br />delivery of the Series 1993 Bonds; a no -litigation certificate; a non -arbitrage <br />certificate of the County; a rebate compliance certificate of the County; and <br />MM <br />