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HomeMy WebLinkAboutDocumentation_Special Meeting_Tab 03_06/23/1994 � � � � LAW OFF�CES MOYLE, FLANIC3�AN� KATZ. FITZGE$ALD $C SHEEHAN. P.A. 625 NORTH FL/1GLER ORIVE • 9T� FL70R N'E:.tiT f'AL�! HEAC:H. FLORIUA 33401 TELEPMONE (4071 g�9-7SOO r t ��� FACSIM�LE 14071 659-1 7 69 � � j \ i > MARK E RAYMOND DIRECT LINE. c407� 659-5490 `rSt GF ��\ � S��UES ,� ' � t�?�y rv _� S� t'�1 � V1l.tRG ` M pFF CE �v' June 15, 1994 9 �� 1gI To Parties on the Attached Distribution List RE: Village of Tequesta, Florida Liz and Gentlemen: Enclosed please find revised, black-lined closing documents. Liz, I have only sent you the Escrow Agreement. Be advised that we have clecided to proceed on a gross defeasance basis, so that Liz will be receiving the full amount of cash necessary to defease the Outstanding Bonds, without regard to any investment earnings. Liz will invest the escrow in Barnett's Emerald Fund and will, after making provision for payment of the Refunded Bonds, return the balance to the village., The Resolution is scheduled for adoption by the Village at a special meeting beginning at 7:00 P.M. on June 23, 1994. Immediately following the meetinq, I would like to have all documents executed to be held by me in escrow until the closing on June 24, 1994. This means that I will need John Lyons, Ron Mackail, Toro Bradford and the Village Clerk available for 10 to 15 minutes following the meeting. � On June 24, 1994, the Bank will wire to the Village $1,365,000.00. The Village will then immediately wire to The Bank of New York $613,640.00. Bill Rascavelis, please contact Liz Feezor and obtain wiring instructions from her. Also, Bill and John, please discuss the mechanics of transfer of funds from the Bank to the Village, bearing in mind that the money will need to 9227Z o , To Parties on the Attached Distribution List June 15, 1994 FaqF� �. be imme�3iately available on June 24 so that *_he Villag� can wire it f�� Tt�e Bank of New York. Upori receipt by the Village ��f t}ie proceeds of the Bond, �ncl receipt by The Bank of New York of the Vilage's wire, the transaction will be closed, and I will release the original Bond to John Lyons. Please contact me as soon as possible with any final revisions tc� these documents, as I will be generally unavailable June 21, 22 and 23, except to attend the meeting the night of the 23rd. Finally, Liz, I have�included eaecution pages to the Escrow Agreement in your package, and would ask that you please return all six executed copies to me. Very truly yours, ^ �'��� � � . Mark E. Raymond � MER/ash 9227Z , � VILLAGE OF TEQUESTA IMFROVEMENT REVENUE REFUNDING BONI) SERIES 1994 Distributian List ISSU�R Thomas G. Bradford 407-575-6200 Village Manager Fax: 407-575-6203 8i11 Kascavelis 407-575-6207 Director of Finance Fax:�407-575-6203 Village of Tequesta 357 Tequesta Drive Tequesta, FL 33969-07.73 ISSUER'S COUNSEL • John C. Randolph 407-659-3000 Jones, Foster, Johnston & Stubbs, P.A. Fax: 407-832-1454 Flaqler Center Tower, llth Floor , 505 South Flagler Drive West Palm Beach, FL 33401 �INANCIAL ADVISOR Clark Bennett 407-626-4760 Florida Municipal Advisors, Inc. Fax: 626-4781 9121 North Military Trail, Suite 200 Palm Beach Gardens, FL 33410 � John J. Lyons � 407-575-1300 Jupiter Tequesta National Bank FAR: 407-575-1324 250 Tequesta Drive Tequesta, FL 33469 � 7164M t � VILLAGE OF TEQUESTA IMPROVEI�NT REVENUE REFUNDING BOND SERIES 1994 � p�� t�it�u��n_L i s t BANR COUNSEL Roger Friedbauer 305-379-9104 Slnutts & Bowen FAX: 305-381-9982 201 South Biscayne Blvd. Miami, FL 33131 BOND COUNSEL . Mark E. Raymond 407-659-7500 Moyle, Flanigan; Katz, Fax: 4�7-659-1789 FitzGerald & Sheehan, P.A. 625 N. Flagler Drive, 9th Floor West Palm Beach, FL 33401 �SCROW AGENT Liz Feezor 904-645-1906 Assistant Treasurer FAX: 904-645-1930 The Bank of New York Trust Company of Florida, N.A. Towermarc Plaza, 3rd Floor 10161 Centurion Parkway Jacksonville, FL 32256 7164Ai � a '.,...„ . r � �i.� '� (� � , . .- ., ��r��l���• `���� -r•• ���• _ ` ' I , . ` or ver�ic4� � '� ��ne �nGiCc}��� ��C:.�ii�4!'�, TRANSGRIPT OF PROCEEDINGS . �1, 65 000 VILLAGE OF TEQUESTA, FLORIDA IMPROVEMENT REVENUE REFUNDING BOND � SERIES 1994 DATED JUNE 24, 1994 MOYLE, FLANIGAN, KATZ, FITZGERALD & SHEEHAN, P.A. HOND COUNSEL TTM� AND PLACE OF GLO�ING The closing was held at the Village Hall June 29, 1999 (the "Closing Date"). T.T�T OF CLOSING DOCUMENTS 1. Certified copy of resolution adopted by the Village Council on � June 23, 1994 authorizing the issuance of the Bond. 2. Certif ei d copy of Village Charter. 3. Certified copies of Ordinances No. 331 385, 463, of Article II of Chapter 11 of the Code of Ordinances, and o t e FranchYSe for Recycling Collection Services, as amended, with Nichols Sanitation, Inc. 4. Escrow Deposit Agreement. � 5. General Certificate of the Issuer. 6. Notice of Sale sent to Division of Bond Finance. 7. Receipt for the Bond. 8. State of Florida Division of Bond Finance Forms BF-2003 and BF-2009-B and Letter of Transmittal. 9. Certificate as to Arbitrage and Other Taa Matters. 10. Form 8038-G and Transmittal Letter. 11. Disclosure Statement of Bank. � 12. Opinion of Counsel to the Issuer. 13. Opinion of Bond Counsel. 'Transcripts. Nine (9) complete transcripts are to be prepared for distribution as follows: 2 - Village of Tequesta 1- Jones, Foster, Johnston & Stubbs, P.A. 2- Jupiter Tequesta National Bank 1 - Shutts & Bowen 2- Moyle, Flanigan, Ratz, FitzGerald & Sheehan, P.A. 1 - Florida Municipal Advisors 7127M [ � 1• �RTIFICATE OF TRUE COPY I, the undersigned Village Clerk of the Village of Tequesta, Florida, DO HEREBY CERTIFY that attached hereto is a true and correct copy of that certain resolution duly adopted June 23, 1994, authorizing the issuance of the Village's Improvement Revenue Refunding Bond, Series 1994, and that such resolution remains in force and has not been amended. IN WITNESS WHEREOF, I have hereunto set my hand as of the 24th day of June, 1994. By: Village Clerk 7128M RF60LUTION NQ. 16-9.3/4_4 A RESOLUTION OF THE VILLAGE COUNCIL OF THE VILLAGE OF TEQUESTA, P'LURIDA, AUTHURIZZNG THL ISSUANCE OF THE VILLAG�'� IMPROVEMENT K�VENUE REFUNbING BONU, SERIES 1994 IN. THE AGGREGATE PRINCIPA� AMUUNT OF $1,365,000; PRESCRIHING THE FORI+I, TEFtMS ANU UETAII.S OF 6UCH BOND; 1rlAKING CER7'AIN OTHFR CnVENANTS ANU AGREEMENTS IN CONNECTION WITH THE ISSUANCE OF RUCH bOND; SpECIFXiNG 'iHE USE OF 1'HE PR�EEUS UF BUCH BONU AND THE SECURI3'Y Fplt Z'HE PAYMENT THEREOF; AWARDING SUCH BOND TO JUPITER TEQUESTA NATIONAL HANK SY NEGOTIATEO SALE; PL�DGING ALL FRANCHISE FEES ANp OCCUPAT�ONAL LICENSE FEES OF THE VILLAGE AS S�CURITY FOR SU.CH BODTI); DESIGNATING THE �OND AS A "QUALIFIED TAX-EXEMPT OHLIGI�TION" WITHIH THE� MEANING OF SECTION Z55(b) (3) OF THE INTERNAL REVENUE CODE OF 1986, AS 11MENDED; MAKYNG CERTAIN OTHER C4VENANTS AND CaNTAINING CERTAIN . C�TIiER PROVISIONS; PROVIDING AN EFFECTIVE DATE; AND FOR pTHFR �'URPOSES WHEREAS, the vILLAGE OF TEQLIESTA, FLORIDA (the "Issuer") is authvrized by the Constitution and laws of the State of Florida to borrow money and issue revenue bonds for municipal purpases; and WxEREAS, the Issuer has heretofore issuEd its improvemant Revenue Bvnds, Series 1979 in the ori9inal principal amount of 5910,000 now outstanaing in the amount of �580,000, which outstanding amvuat finally metures on Octobec 1, Z004 (the "Refunded Honds" ) ; an� WHEREAS the Issuer has determined to issue its Improvement R�venue R�funding Bond, Series �994 in the aggregate �rincipal amaunl: of �1,365,000 (the "�ond"), to provide for the repayment of the Refunded 8vnds and to provide funds for certain recreaLional facili�.y and roadway improveme�ts (the "Project~) to be unclertaken by the Issuer; ana WHEREAS, the Hond will be secured by an irrevoCable first lien vr� and pledge of the Fsanchise Fe�s and Occupationa2 Licen�te Fees (as hezeinafter defined) of the Issuer; and WI3EREAS the lssuer deems that it is in its best financial interest that the $ond be sold at neqotiated sale; and ; WfIFREAS, the Issuer does not anticipate issuing in escess of �10,000,000 in taz-exempt obligativns in 1999. NUW, THEREFORE, HE IT ItESOLVEU BY THE VILLAGE COUNCIL OF THF VILLAGE OF TEQUESTA, FLORIDA: SECT�oN l. pF•FI�iTIUNS Capitalized terms used herein and nol. atherwise defined herei�n shail have the foilowing mear►ings: "Dank" shall mean Jupiter Teqt�esta Nativnal Rank and its succ:essors and assigns. "Pesiyriated Revenue�" shall mean any addilional nUn-ad v�lortm rt�veriues whi.cli th� Issuer has designated as such pur ,L�ant to S�ction 6. �Escrow Depasit Agreement" shall mean the Escrow veposit Ayi�e�nent in substantiall�y the form set forth as Exhibit 8 hereto, between the Isstter and The Bank of New Xork Trust C:ompany of Florida, N.A. ^Franchise Fees" shall mean all sums accruing to the Issuer pursuant t� the followings franchises: (i) the franchise granted Florida Public Utilities Company pursuant to Ordinance No. 19, er�ac:ted July S, 19S8; (ii) the t�caachise granted Pelm Beach Cable Tel.�:vision Company pursuant to ordinance No. 155, enacted Octob�r 23, 1�b9; as transferrec� to Adelpbia Communi.cations Corporati�n purs��ant to ResplutioA No. 1-86/87 end Resolution No. 11-f�8/89; (iii) the franchise granted Florida Pow�r & Ligh� Com�iany pursuant to Urdinance No. 331, enacted S�ptember 11, 1984,; (iv) the fzanchise granted Southern Bell Telephone and Telegraph Company pursuant to Ordin2�nce No. 385, enacted July 13, 1989; (v) the €�anchise granted Niehols Sanitation, Inc. pursuant to Osdinance Ho. 4G3, �rsacted actober 14, 1993 as impiemented by the "Franchise For Recyc:ling Collection Service" among the Issuer and Nichols Sanii:ation, Inr:., dated August 25, 1989, as amended by "Amendment to Franchise for Residential Curbside Recycling Collection Services" dated October 21, 1993 and "t�mendraerit to Garbaqe, Yard ar�d Uther Trasb Collectioa Franchise," dated October 21, 1993; anc� (v;) all extensions and modifications of said franchises and rencwals ttiereaf, and all similar franchi�es granted by the Issuer to o�hexs upon the ezpiration or termination of said franGhises; �nd (vii) all other franchises granted by Issuer until the principal o�, premium, if any, and interest on th� Bond fiave been fu) ly paic�. °improvernent Revenue Band Fund" shall mean�the fund created pursuant to Sectxon 6 hereof. "]�csuer" sriall mean the Village ot Tequ�sta, a municipal cotpoxation ciuly organized, eaisting and in gaod sEancling under the laws of the State of Florida. "(�ccupational I�icense Fees� sball mean alZ sums accruing •to the 7ssuer pursua�t to Ar.ticle 17 of Chapter 11 of the Cvde of Urdinances of the issuer, relating generally to occupationa�. licerjse fe�s, including all amendments thereof and suCCessvr Cod� provi�ions Ehereto. "Pledged Revenues" shall mean the Franchise irees, thr� Occupational Li�ense F�es, any Designated RevEnues and all amounts on depvsit iri the Improvement Reveaue Hvnd Func3. ; -2- 7129M � . "ResVlutio��" shall mean this resoluti�r�, authorizing the i�suance of the Bond. SEC1'lUN Z. Au��URSZAT�9N OF FiONU. 7'he lssuc�r is herehy authorized to issue its $1,365,000 aqgregate pci.ncipal amount Imprav��n�nt Revenue Refunding Bond, Se�ies 199A having the in�;erest rate, maturity Gate, aad other proviaions as set fortA in t1,� f�rm of bond attached heret� as Ezhibiti "A." The Bonci shall bc dated June Z4, 1999 and•shell mature July 1, LUU9. S�C.T7QN 3. AwARU OF,�,.HONll. The Issuer hereby determine5 that a ney�tiated sale of the aond is in the best interest of the Issu�r by reason of the specialized market tor revenue bonds simi.laz to the Band. The sale of the Bond to th� Ba�nk is hereby . avthvrized. The Hond shall be sold to khe $enk at a piice of par, said �iric:C t� be payabie ta the lssuer in immediately avsilab�e fuc�ds on the dete of �ssuance a� the Bond. SJ�:CTZON� � �JgE OF PROCE�uS. Proceeds of the Bond in the am�unk of �,434.00 shall be used by the Issuer, together with �183,7.06.00 of money held ir� the accounts established in connection with the Refunded Aonds and , . of other available monies �f the Issuer, to repap the Kefunded Hondss pursuani, 1,0 .the �'scro� Depos�t AgreemenL and proceeds of the Bo�d i n the amout�t of �1, OZ4 , 566. 00 shall be used by the Iss�le�= to p�y � costs af issuance of the Bond and to finance the cost of the Projecl in accor�ance with plans and specifications on file with � - 41�C lssuer . � . . , , � , S�:C?iON 5. ESCROW DFppSIT AGREE�IT. The form Of Escrow � Deposi.t Agreement attached hereto as Eahibit B is•hereby approved, anc� the Mayor is hexeby autharized and directed for and i.n the �� name of the Issuer to eaecute, and the Village Clerk is authorized Lo �lL��t and apply the seal of the Issuer to, the EsCrow Depasit AgLeement, with suc:h changes, alter�tions or corrections thereto as shall be approved bp the officials egecuting the same, such ezecutian to consti.tute conclusive evidence of such approval. �'he issuer hereby appoints The Bank of New York Trust Gompany of Flo.rida, N.A. (�he "Escrow Ag�nt") as Escrvw Agent pursuant to the Escrow ne�osit Agreement. � '�•hc Issue= hereby irrevocablp elects, effective upon and onty upvn the issuance of the Bbnd that the issuer�s Improvement R�ve»ue Honds, Series 1979, rnaturing on Uctober 1, Z004 shall be call�c� tor redemption on Augnst �, 1994 at a price of 103� of par, plus aCr,ru�d interest to the redemption date. S�CTION 6. $FCURITY F��_ BOND. The princi�al of, premium, i.f any, and intesest vn the Hond shall be payable frvm the Fledged Revenues, ana until speet by the Issuer, proceeds receivecl by the issuer f �:�ni the sale of the l3ond {the °proceeds" ). The papments shall � secuxed by an irzevocable lien on the Pledged Revenues, anc7 until �pent by the lssuer, the Proceeds, and tbe �ssuer do�s -3- 717.9M Y • hereby i rrevocably plcclyr such F�1 edged Revenue� and, ut�ti 1 sper�t by thF Issuer, thd Pzoceeds, to the payment of the principal of, pr�mium, iL any, er�d interest on the Bond. The �ien of the holder of tt:� Dvnd on the Pledqed Etevenues shall be senior anc] prior to tt�� 1 iens oE the holders of any and al l other obliqati.uns of the lssuec whir.h are payal�le, in whole or in part, from tl�e pledged ItFVCnues, reyardless of whether such other obliyations are issuPd c�i incurred simultaneous with or subsequent to the issuance o� tAe Bonc� . In the ev�zit that the Franchise Fees and vc:cupationaA LicensE F�e� ace reduCeci or eliminated by reason of a change in F7.orida law, I��ct�rioloqical obsolescence, or for any other reason the amoui�i, uf the Franchise Fees and Occupatianal License Fees c�]]ected hy the Issuer in any pear should b� less than 120� of thL amount of principal and interest payable on the Aorid in such ycar pius 100� of the principai and interest payable on any Juni�r Gebl (ay hereinaftNr defined) in such. yeaz, the lssaer shall designate one vr more ather lawfully and conLractually available non ad-valorem sources, if such eaists, in an amount at leaut sufficie�t (such source{s) in such amount, the "Designatpd Rev�nues") to cause the aggregate of the amount of such Designated R�vEnues a�id the Franchise Fees and Uccupational License Fees colle�teti in each y�ar to equal 120� of the principal and interest �ayable ar� the Bond in such year plus 100$ of the principal and �nterpst payable on any debt payable therefrom in such year, and such r�esiynated Revenues shall witbout further action be deemed plc:dc�ed to the payment ot pr3nCi�a1 and inter�st on the Band the same as th� otber Pledged Revenues. Th� Iusuer further represents and warrants that it h3s, as of t1�r_ date af adopti.on hereo�, made no pledge of the Franchise Fees ancl C)ccupalional License Fees, except to the extent pledged t� the Refunded Bonds, and that it has not entered into any agreement ar mad� any commitmen� to pledge the Francbise Fees and 4ccupational License Fe�s. The Issuer covenants that it shall not pledge the F]�.dged Revenues to the repayment o� any o�ligations ather than the� Aond, nor shall it subject the Fledged Revenues to any iien otl��r than the lien hereby created to secure repayrnent of the eond, w3thout the prior written consent of �he owner of the Hond. Any Ubligations of the lssuer hereafter incurred and �ayable �ram thr: Pledged Revenues, if applicable, shall cantain an Express �rovisiun to the effect that the right of such obligations to payment f.rom svch sources is fully subordinate to the lien and pledqe h�rebY c:r�ated in favor of the principal of, premium, if any, a�nd int�er�st on the Bond. The Issuer hereby creates and establishes an :Imprbvement Revenue �ond Fund (herein, the "�und"). Subject to the provisions of this Resolutibn, the Fund is hereby pledqed as security'for the p�ymcnt oL the Hond. 1'he Issuer �ovenants that it sha11, no later lha:i the secor�d business day afte[ receipt, deposit all of the procecd� of the Franchise Fees, Occupationa2 License Fees ant� , -4- 7129M � • UetiignaLed H�veriues into the �ut�d. Moneys on deposit i» the rund may l�c inve�ted ir� any legal]y permitted investment. Except as � �ic�vided in the �ezt succeeding sentence, as long as the Issuex is eiut ir� default in its payment obligations of the $ond, so long as there is on deposit in the Fund a�� amount sufficient to pay the remaininq prir�cipal and interest scheduled to become due and payable on the Sond duriny the nezt twelve months, the Issuer ma�y withdraw amounts for any lawful purpose. The issuec shall not rrithdraw any moneyb fi�cn the Fund if such witbdrawal wauld adver�ely affect the Issuer�� abilitx to pey debt serviCe on the eond as the same becames payable, untii the Bond has been paid in full. lf the Bank holds the Fund, upon the occurrenCe of e�n event of default under this Resolution or the Bond, tne Bank sha�� have a righ! of set-off Without notice or consent against amounts in the rund ta pay amounts due on tbe 8ond. S�CT7UN 7. @(Ip�ET. Subject tb and not in limitation of the pravisions of Secti�n 6 hereof, the Issuer shall budget and apprapriatc such sum fzom thE Pledged Revenues in the Issuer's bud�et each year as may be n�cessary to pay the principa� af and interest on the Bond becomang due in that year. SRCTIbN 8. NO LEV7r pF !w VALUREM._TAI�S REOVIRLD. The Bond Shall be payable solely fXOm the sources and in the rnanner aescrit�c� herein. No holder of the Bond shall ever have �he right te aompel the exercise of the ad valorem taaing power of the Issusr to pay the Bond or the in�etest thereon ar be entitl�c7 to payment of such principal and interest from �ny funds di the Issuer ezcepl. as pivvicied herein. SECTION 9. �SOLUTION .TQ CONSTZT�F_ CONTRACT. In corisiderati.on of the acceptiance of the Aond by th�se wh� shall riald thc same from time ta time, this Resolution shall be deemed to be and shall cvnstitute a contsact between the Issuer and such holders. The ��venants and aqreements herein set forth to be peLtorm�c3 by lh� Issuer shall be for the benefiti, ptot�ctivn and security of the legal holders �f �he Bond. 3�CTI�N 10 �2L�CUTION .Q�_ HONDS The Bond shall bc� eaeCUted in �hp name of t�ie issuer by the Mayor or vice Mayor of the issuer ancl cauntersigned and attested by the Village Clerk or �eputy Villay� Clerk, and the corporate seal of the �ssuer shall be affixeci thereto. 5ECT70N 11. BOND MUT��,A�ED. DF�,STROYED. STOI,��1 OR LOST. In cass thc Hond shall become mutilated, or be destroyed, stolen or lest., lhe Issuer shall issue an� deliver a new Bond of like tenor es the t�ond so mutilated, Qestroyecl, stolen or lost, in exchanqe and in substitution for such mutilated bond, or in lieu of anc3 in substitutian for the Bond destroyed, stolen or lost and upon the holder furnishing tfle issuer proof of owt�ership thereaf and indemnity reasonably satisfactory to the Issuer and complying with such other reasonable regulations and conditions as the Issuer may -S- 7129M � � �i�-5c-r ib� and paying such expenses as the Issi�er �nay i ncur . Th� Bond �o surrendered shall be cancelled. if the Bond shall� have Li.nally matured or be ebout to finaily meture, instead pf issuing a substitutc Hond, the Issuer may pay the same, upar, being ir�d�rnnified as aforesaid, and if suCh �ond is lost, stOler� or destroyed, without surrender thereof. SECTION �,2. �,S$IGNAg�y1�y, 7�he Village C2erk shall maintain a wrii,te�� record of pwnership of the Bond. Ownerst,ip vf the gond may bc transferred only upon such written xecord snd with the wiitten approval of the Issuer, which epproval shall not be unze�sonab]y withheld. SEGTION 13. �M AIRME�_9F COHTR.ACT. The 7ssuer covenant;s with the holders of tbe Bond that �t wiil not, without the written consent of the holcler of the Bo�d, enact any ordinance oz resolutfon which xepeals, impairs or amends in any manner adver.^,e ta the holder of the Bond the right or ability of the Issuer to callect the Franchi:se Fees or Occupatianal License Fees, ar any ri�hts of such holders or the securzty of the fund5 which may be pledged to the payment of the pri.nci�al of and interest on the B�nd. SF,CTIOH 19. I _.C��'URTHER A�gBNC.E. The officers, emp].oyees anc� agents of the Issuer are hereby authorized and dir.ectec� to do all acts and things required for the fu21, punctual anrl complete performanc� of all the terms, covenants, provisi�ns ar�rl agreements of the Bond. ShCTION 15. �1�C�,UALiFiEn The Issuer herebY d�signates the Hpnd tv be a"qualified tax--eaempt obliqation" within the meaning of Sectian 26S(b) of the Internal Revenue Co�e of 1986, as ament�ed (the 'Code"). Th� reasonably anticipeted am�unt o# tax-eYempt obligations (other than obl3gations described in S�ction 265(b)(3)(C)(ii) of the Code) which will be issued by the Issi,er during 1994 does not eaceed $10,00Q,000. SfiCTIOrt I5. ���.�p�ION, The Issuer hereby cov�nants anc� agrees, for the benefit of the owner f rom time to time of th� F�ond, to comp�y with the requirements applxcable to i� contained in Secti.on 103 and Part iV of Subchapter B of Chapfier i of the Cocie !o the eztent necessary to prese�ve the exclusiar� vf interest on the Bond �rom qross income for Federal income tax purposes. S�Pcifically, without intending to Iimit in any way the generality of the f�reqoinq, the I�suer covenants and aqrees to refrain frorn using proceeds of th� Hond in a mann�r that woulcl causP th� sond to bc� classifierl as a"private activity bond" under Section 141(a) of the Code �na to t�ke or refrain from takxng any action necessary in order that the Hond shall not become an arbitrage band under Section 103(b) and Section 148 of the Code. The Issuer is a governmental unit with general ta:ing powers, the Bond is not a"pr�vate activity bond" Within the meaninq of the Code, 9S% or mare of tbe net proceeds of the Bond are to be usea for locai -6- T129M 1 1 y�vcrnmenLal o�tivities of the Issuer, and the aggregate face amc�unl oL all tax-ezempt bonds, other than private activity bonds and l�a�ecls issued to refunA (other than to a�vance-retund (within thc- mcaniny uf Section 149 0£ ttie Code) ) any bond to th� Exter�t � tt��: amount of the refunding bond does not exceed the out�tending amuunt of the refunded bond, issued by the Issu�r durir�g 1944 is not reasonebly ezpecL to exCeed $5,000,000. SECTION 17. � ,FyExAgrLt� OF,__INVAL29 PROVISIONS. ��L�ZS'�T� gEP�A��R. If any one or. more of the covenants, a4reements or pruvisions of law conteined herein shall be held contrary ta any expregs provisio�l uf. law or cantr�r.y to the policy of eapress ]aw, thvugh not ezpressly prohibited, ar against public policy, oi shall for any re�son whatsoever be held invalid, then such covenants, agreements or provisions shall be null and void and shall t�e deemed sepai'able from the remaining covenants, agreements or prvvisions and shall in no way affeCt the valid'ity of any oE the other ptovisions hereof or of the vbliqation of the .ISSUer tv makc Lhe payneents requ3red h�reunder. All oth�r resolutions or parts uf resolutions in canflict or inconsistenk herewith ar.e herehy repealed. Upon payinent of the Refunded bonds, Resplution No. �0-78/79, adu�tad July 24, 19'79, Resolution N�. 6-79/SQ, ac�optecl F�bruary 26, 1980 and Resolutions Nos. 8-74/Af� and 9-79/80, adopted March 10, i98Q, are, without further action, hereby repealed. � SECTxON 17. �NFORCEMENT OF .�OLLECTIONS. The Issuez will clil�gently enforce and collect the Franchise F'ees, Oecupational License Fees and besignated Revenues, xill take steps, actxons and praceedings for the enforcement and collection v� such Franchise Fe�s, OccupationaZ Licens� Fees and Gesignated ltevenues as shall become d�linquent to the full extent pe�mitted or autl�orized by law, and�will maintain aCCUrate records with respect thereto. SECTION 19. flUbGET AAp.FINANCIAL INFORMA �he IstSUer sha�ll aemonstrate ia each annual budget that there are sufiicient proceeds of the Franchise Fees, Uccupatiana7. Fees and Designated Revenu�s, if any, to pay the principal of, pr�mium, if any, and intprest on the Bond as the same becomes due and payab�e. The Issuer shall provide the owner of the Hond with a copy of its annual budy�t and suCh bther financial iniormation regarding the Issuer as th� owner o€ the Bond may reasonably request wxthin a reasanable period of �ime after the request is made. Tt�e Issuc�r shal.l maintain b�oks of account in accorda�ce with g�nerally �CC:epted aLCOUnting principles, and shall cause the same to be audited by a certified public accountant within 1�0 days after the end of each fiscal pear of the Issuer. The Issuer shall send the owner �f the Aond a copy of its autiited annual rinancia]. staternents within 20 days after acceptance of the same by the Issuer. In addition, when the issuer provides the owner a copy of ity audit, tho Issuer shall provide the vwner a certificate of the a�cvunlank �+uditing such financial statements stating whether in ..�_ 7129M t.he course of the accauntant's pceparatipn of such financial sk�tpments the eccountant became aware of information whiCh lead t1�c• ac:c;ountant to believe that the issue= aias in default hereunder or under ttie Bond, and if so, pr�vidinq de�ai ]s of the nature end exter�t ot such mattecs giving zise to such beliei. The Issuer herPby covenants that it shall Qrom�tly give�written notice to the awner of thc E�ond of any event constituting a default undez the Bor�cl, this Resolution, or any of �he other documents p�lrsuant tv which the 8ond was issued, or oE any event, which, with the pas�age of time or the giviny of notice, ar both, wou1Q become s�ic:h an event of default, or of any litigati.on or pcoeeeding which ii dete�mi.a�ed adversely to th� Issuer would adversely affect the sec:urity for the payment of the Bond. SECTION 20. REMEDIES�,__,OF HONDHp�p�R ShOtild the ISSU�+z default in any obliqation created by this Resolution or the tiond, the ownez of the B�nd rnay, in addili.on to any other remeaies set forth in this Resolut�on or the bond, either at law or in equity, !ry suit, action, ma�damus oi vther prUCeeding in any coutt of competent jurisdi.Ction, p�r�tect and enforce any and all rights under L laws of the State of Florida, or granted or contained in tt,i.�; Rc:solution, and may enforce and com�el the pezformanGe oi ail clvtics required by this R�solution, or by any applicabl� statutes to be p�riormed by the Issuer or by any officer thereof. The is.^,uer hereby agrees with Lhe owner of the Hond that tbe fiiing vf ar�.y bankru�tcy ur insolvenc:y i�rocee3inq under any federal or state 2aw by or �gainst the Issuer which is not d7�smissed with prejudice within 30 days of such fi�ing shall give the owner of the eond the rig3�t. tv �aercise anp of Che remedies provided to them under th�s Sec:ti.vn. SECTION 27,. MQUIFICATION OR AMENDME.j�.�. Except as provi�ed in l.he n�xt sentence, no modification or amendment of this Kesolution or of any resolution amendatory hereof or supplemental her�ta may be mac�e without the consent in writinq of the oWner of the Hond. �t�is Resolution may be amended, changea, moditied and a�tered without the consent of the owner of the bond, (i) to cure any ambiquity, correct �r supplement any provision contained herein wha.ch may be defec�ive or inc�nsistent with any other provisians containpd hcrPin, (ii) to provide other changes which will not adverse]y affect the interests of the owners of the Bpnd, or (iii) tc, mai.ntain the exclusion of interest an Che Band trom gross iuc:usne for �ederal income taa purposes. SF.CTION 22. �DDITIq�,_,��1'iHORIZATIUN. The Mayor, - the Vi2laye Manayer, the Finance birector and any other proper official of the lssuer are herebp authorized and directecl to eaecute and de2ivcr any and all do�uments ant� instruments and to do and to cause to be c�uue any and a�l acts and thinqs necessary or proper for carrying out tlze t��ribaetipns contemplated by this ResOlution. � SECTION 23. EFFECTIVE.. UAZ'�:. This ReSOlution shall take -8- 7]29M cEtect inunediately upon its adoi�txon. THF. FOREGOING RESOLUTION Has otfered by Councilmemb�r _, Who moved xts adoption. The motion was securided by Councilmember and tipon veiny put to a vote, the vote was as follows: � �S?R�p9P �S''A�SZ �bQP.�'�QL Tri� Mayoc therevpon declared the Resolution duly ��assed and adopted tY�is 24th Day of June, 1994. Mayor of 'requesta ( SEAI, ] ATTEST: � Village Clerk ' 7129M , , EXHIBIT "A" UNITED STATES OF AMER'ICA STATE OF FLORIDA VILLAGE OF TEQUESTA IMPROVEMENT REVENUE REFUNDING BOND, SERIES 1994 June 24, 1994 �1,365,000.00 - THE VILLAGE OF TEQUESTA, a municipal corporation organized and existing under the laws of the State of Florida (the "Issuer"), for value received, hereby promises to pay, but only from the � source and in the manner specified herein, to JUPITER TEQUESTA NATIONAL BANK, Tequesta, Florida (the "Bank"), or to the registered assignee or successor-in-interest thereof as herein provided, the principal sum of ONE MILLION THREE HUNDRED Y SIXTY-FIVE THOUSAND AND NO/100 DOLLARS ($1,365,000) and in like manner to pay interest on the principal amount hereof remaining unpaid from time to time from June 24, 1994 as provided below. The outstanding principal amount of this Bond shall bear interest at the rate of 6.15� per annum, calculated on the basis of a 360-day year, consisting of twelve 30-day months, payable on �[ January 1, 1995, on which date the interest accruing from and in� cl� ng June �_ 1994, to but not including�LJanuary l, 1995 shall �be due and payable, and on each vJan_ 1 and J� u y thereafter (each, an "Interest Payment Date"), on which date the interest accruing from and including the preceding Interest Payment Date and to but not including such Interest Payment Date shall be due and payable. The principal hereof shall be payable in annual installments due on J_u_l� 1, 1995 and the first day of each J� u�_thereafter, to and including Jul�l, 2009, on which date all unpaid principal and interest shall be payable in full, in the amounts and on the dates �set�forth in the following table: Ju y 1 Principal Due 1995 $ 55,000.00 1996 60,000.00 1997 65,000.00 1998 70,000.00 1999 75,000.00 2000 80,0OO.OQ 2001 80,000.00 200Z 90,000.00 2003 95,000.00 2004 � 100,000.00 2005 105,000.00 2006 110,000.00 Z007 120,000.00 2008 125,000.00 2009 135,000.00 , . This Bond is � special obligation of the Issuer secured by a lien upon and pledge of and payable from, (i) until spent by the Issuer, the Proceeds (as defined in the hereafter described Resolution , and ii the Franchise Fees and Occupational License Taxes as e ine in the hereafter described Resolution). This Bond is also secured by a lien upon and pledge of and is payable from the Designated Revenues in the manner and to the extent provided in the Resolution (as defined hereafter). The Bond does not constitute a general obligation or a pledge of the faith, credit or taaing power of the Issuer, the State of Florida or any political subdivision thereof, within the meaning of any constitutional or statutory provision or limitation. Neither the Issuer, the State of Florida nor any political subdivision thereof shall be obligated or may be required or compelled to (1) exercise its ad valorem taaing power to pay the principal of this Bond, the interest hereon or other costs incident hereto, or �2) to pay the same from any source of revenue of the Issuer other than the Franchise Fees and Occupational License Taxes or Designated Revenues. The acceptance of this Bond by the holders from time to time hereof is deemed an agreement between the Issuer and such holders that this Bond and the indebtedness evidenced hereby shall not constitute a lien upon any real or personal property of the Issuer, but shall constitute a lien only upon the Franchise Fees and Occupational License Tases and any Designated Revenues, in the manner provided herein and in the Resolution. If any date for the payment of principal and interest hereon shall fall on a Saturday, Sunday or day which is a legal holiday, � the payment due on such date shall be due on the negt succeeding day which is not a Saturday, Sunday or legal holiday, but the Issuer shall not receive credit for the payment until it is actually made. For purposes of this Bond, "Prime Rate" shall mean the annual interest rate announced by Jupiter Tequesta National Bank from time to time as its "Prime Rate" (which interest rate is only a benchmark, is purely discretionary and is not necessarily the best or lowest interest rate charged borrowing customers of Jupiter Tequesta National Bank). In the event Jupiter Tequesta National Bank ceases to announce its "Prime Rate," "Prime Rate" shall mean �the prime rate designatecl by �he Chase Manhattan Bank, N.A. The rate of interest on this Bond shall be subject to adjustment, as set forth below: As used in this Bond, (1) "Code" means the Internal Revenue Code of 1986, as amended; �2) "Maaimum Corporate Taa Rate" means, as of any date of cletermination, the highest marginal tag rate (eapressed as a _2_ ?13QM ' . . decimal) applicable to the taaable income of corporations (as currently set forth in Section 11 of the Code) without regard to any increase in tax designated to normalize the rate for all income at the highest marginal tax rate or to phase out the benefit of graduated taa rates and impose a flat-tax at a specified rate (for example, the tax imposed by the last two sentence of Section 11(b)(1) of the Code as in effect on the date hereof), which rate on the date hereof is .35; (3) "Fully Taxable Equivalent" means the Prime Rate eapressed as a number and not as a percentage (for eaample, if the "Prime Rate" is nine percent (9$), the Fully Taxable Equivalent is nine (9)); .(4) "TEFRA Adjustment" means an adjustment equal to the product of Cost of Funds multiplied by the Maximum Corporate Tax Rate multiplied by the Preference Reduction Rate; (5) "Cost of Funds" means the lesser of (i) one hundred (100) multiplied by a fraction, the numerator of which is equal to the total interest expense of Jupiter Tequesta National Bank for the immediately preceding taa year and the denominator of which is equal to the average total assets of Jupiter Tequesta National 8ank for the immediately preceding taa year, as each are reflected in the year-end financial statements for Jupiter Tequesta National Bank and (ii) the Federal Funds rate as reported in The Wall Street Journal or, if it is no longer published, another financial publication of national circulation selected by the holder hereof; and (6) "Preference Reduction Rate" means (i) so long as tk�is Bond is a"qualified taa-eaempt obligation" within the meaning of Section 265(b}(3) of the Code, the percentage reduction to be applied to the amount allowable as a deduction under Chapter I of the Code with respect to any financial institution preference item (as such term is defined in Section 291(e) of the Code) (currently. 20�), and (ii) if t�is Bond is not a qualified taa-eaempt obligation under the Code, the percentage of the otherwise deductible interest eapense of • the holder hereof which is allocable to taa-exempt interest which is nondeductible pursuant to Section 265(b)(1) of the Code (currently, 100�). If the Maximum Corporate Taa Rate chanqes from thirty-fi�__ percent (35$), or if this Bond ceases to be a qualified tax-egempt obligation within the meaning of Section Z55(b)(3) of the Code, or if the Preference Reduction Rate changes from twenty percent (20%), the interest rate otherwise borne by this Bond shall be adjusted to the product obtained by multiplying the interest rate otherwise borne by this Bond by a fraction, (i) the numerator of which is equal to the sum of (a) the product of (a) the Fully Taaable Equivalent multiplied by (y) one (1) minus the Magimum _3_ 7130M . . Corporate Taa Rate in effect as of the date of adjustrnent, plus (b) the TEFRA Adjustment in effect as of the date of adjustment, and (ii) the denominator of which is equal to the sum of (a) the product of the Fully Taxable Equivalent multiplied by (y) one (1) minus .35, plus (b) 2.03 the TEFRA Adjustment in effect as of the date of this Bond). The interest rate otherwise borne by this Bond shall be adjusted automatically as of the effective date of each change in the Maaimum Corporate Tax Rate or in the Preference Reduction Rate based upon the foregoing calculations; provided, however, if this Hond is not a qualified tax-eaempt obligation within the meaning of Section 265(b)(3) of the Code on the date of its execution, or if this Bond at any time subsequent to eaecution no longer qualifies as such a qualified taa-eaempt obligation, then the Preference Reduction Rate shall be adjusted as of the date of eaecution of this Bond or as of such subsequent date, as the case may be, and any additional interest due as a result of such retroactive adjustment shall be paid on the next Interest Payment Date after the holder shall have notified the Issuer in writing of the eaistence of the liability and the amount thereof, and shall be in addition to all other interest payable on such date. If for any reason the interest on this Bond becomes includable in the gross income of the holder for Federal income taa purposes (an "Event of Taaability"), the interest rate otherwise borne by this Bond shall be revised to a rate equal to the Prime Rate adjusted daily on the date changes in the Prime Rate are announced, effective from the earliest date as of which the interest on this Hond was included in the gross income of the holder for Federal income taa purposes. In addition to the foregoing, the Issuer shall pay any additions to taa, penalties and interest, and any arrears in interest imposed upon the holder on account of an Event of Taaability. All such additional interest, additions to taa and penalties� shall be paid on the next Interest Payment Date after the holder shall have notified the Issuer in writing of the eaistence of the liability and the amount thereof, and shall be in addition to all other interest payable on such date. � Any payment of principal of or interest hereon not paid when due shall bear interest from the due date until paid at the lesser •of 1$% per annum or the highest rate of interest allowed by applicable law. This Bona represents the entire issue of bonds of�the Issuer designated as "Village of Tequesta, Florida, Improvement Revenue Refunding Bond, Series 1994", issued in the aggreqate principal amount of $1,365,000 under and pursuant to the Constitution and laws of the St of Florida, particularly Chapter 166, Florida Statutes, Article VIII, Section 2,-Florida Constitution and a ' resolution of the Issuer adopted on June 23, 1994 (the -4- 713QM � . "Resolution"). A copy of the Resolution is on file at the office of the,Village Clerk of the Issuer and reference is made to the� Resolution for a more complete description of, among other things, the te�ms and security for this Bond, the rights and remedies of the holders of this Bond and the rights, duties and obligations of �the Issuer, and the holder hereof by the acceptance of this Bond, consents and accepts that this Bond shal� be subject to all provisions of the resolution. The payment of the principal of, premium, if any, and interest on this Bond is secured solely by and payable from an irrevocable lien on and pledge of the Pledged Revenues and the Proceeds, all as more particularly described in the Resolution. The ien o the holder of this Bond on the Pledged Revenues shall be senior and prior to the liens of the holders of any and all other obligations of the Issuer which are payable, in whole or in part, from the Pledged Revenues, regardless of whether such other obligations are issued or incurred simultaneous with or subsequent to the issuance of this eond. The principal of, interest on and any other payments due hereunder shall be payable in any coin or currency of the United States of America which, at the time of payment, is legal tender for the payment of public and private debts and shall be made by bank wire, bank transfer, check or draft tp the holder hereof at 250 Tequesta Drive, Tequesta Florida 33469 or such other address as the holder hereof provides to the Village Clerk in writing. This Bond is and shall have all the qualities and incidents of a negotiable instrument under the laws of the State of Florida. The ownership of this Bond is transferable only upon the written record of ownership maintained by the Issuer, and only upon the consent of the Issuer, which consent will not be unreasonably withheld. Upon �thirtv (30) days prior written notice to the holder hereof, this Bond is subject to prepayment in whole or in part (in mu2tiples of $50,000) at any time prior to maturity, upon paymen� in each case of an amount equal to the principal amount of this .Bond to be prepaid, together with interest accrued on such �principal amount to such date. In the event of any partial prepayment of this Bond, each partial payment shall be applied first to accruea interest hereon, and then to the principal installments' due hereon in the inverse order of their due dates. In addition, in the event that the prepayment is made prior to June 2, 2008, the prepayment price shall include a premium calculated in accordance with the following formula: Premium = The resent value as of the re a ent date of .0731 - A a B a C but not less t an zero , aiscounted from June l, 2009 to the prepayment date usinq A as e iscoun ra e an assuming semi-annual compounding on the basis of a 360-aay year consisting of twelve thirty-day months, where A, B and C have the following meanings: _5_ 7130M � + � � The Y bid-side yield of the U. S. Treasury Note with a maturity closest to June 1, 2009, as quoted by ThP Wa ree Journal (or if The Wall Street Journal is no longer published, another financial journal of national circulation selected by the Holder) on the date thirtv days (or the next day on which quoted) befare the payment date, expressed as a decimal. � B = Principal amount prepaid. � C- Number of days from the date of pre-payment to June 1, 2009, divided by 360 days. The prepayment penalty shall be calculated by the holder of this Bond, and a certificate of the holder of this Bond setting forth the amount and calculation of such premium shall be delivered to the Issuer, and in the absence of manifest error, shall be conclusive and binding as to the amount of the prepayment premium. If the Issuer (i) fails to pay any installment of principal of or interest on this Bond when due, or (ii) if an Event of Hankruptcy (as defined below) shall have occurred, then an event of default shall be deemed to have occurred, and all unpaid principal hereof and accrued interest hereon shall thereupon or thereafter, at the option of the holder hereof, upon written notice to the Village Clerk of the Issuer, become and be immediately due and payable. An "Event of Bankruptcy" shall mean the dissolution or liquidation of the Issuer, or the filing by the Issuer of a voluntary petition in bankruptcy, or the commission by the Issuer of any act of bankruptcy, or adjudication of the Issuer as a bankrupt, or assignment by the Issuer for the benefit of its creditors, or appointment of a receiver for the Issuer, or the entry by the Issuer into an agreement of composition with its creditors, or the approval by a court of competent jurisdiction or a petition applicable to the Issuer in any proceeding for its reorganization instituted under the provisions of the United States Bankruptcy Code, as amended, or under any similar act in ;any jurisdiction wh?ch may now be in effect or hereafter enacted. No covenant or agreement contained in this Bond or the Resolution shall be deemed to be a covenant or,agreement of any officer, member, agent or employee of the Issuer in his or her individual capacity, ana no such officer, member, agent or employee shall be liable personally on this Bond or be subject to any personal liability or accountability by reason of the issuance of this Bond. It is hereby certified ana recited that all acts, conditions and prerequisites required to eaist, to happen and to be performed precedent to and in connection with the issuance of this Bond, eaist, have happened and have been performed in regular and due _6_ 7130M , , form and time as required by the laws and Constitution of the State of Florida applicable hereto, and that the issuance of this 8ond does not violate any constitutional or statutory limitations or grovisions. IN WITNESS WHEREOF, the Issuer has issued this Bond and caused this Bond to be signed in its name and on its behalf by the manual signature of its Mayor and its seal impressed hereon and attested by the manual signature of the Village Clerk, as of the 2_9th day of June, 1994. , VILLAGE OF TEQUESTA, FLORIDA [SEAL] By: Mayor Attest: Village Clerk -7- 7130M , , FORM OF ASSIGNMENT FOR VALUE RECEIVED, the undersigned hereby sells, assigns and transfers unto the within Bond and all rights thereunder, and hereby irrevocably constitutes and appoints attorney to transfer the within Bond in the books kept by the Issuer for the registration thereof, with full power of substitution in the premises. Registered Owner Dated: SOCIAL SECURITY NUMBER OR FEDERAL IDENTIFICATION NUMBER OF ASSIGNEE _g_ 7130M , � 2. CFRTIFIGAT'E OF TRUE COPY I, the undersiqned Village Clerk of Village of Tequesta, Florida, DO HEREBY CERTIFY that attached hereto is a true and correct copy of the Village Chnrter as in effect this date. IN WITNESS WHEREOF, I have hereunto set my hand as of the 24th ..—_ day of June, 1994. By: Village Clerk ` 7128M . , ' 3. C�RTIFTC-ATE OF TRUE COPY I, the undersigned Village Clerk of Village of Tequesta, Florida, DO HEREBY CERTIFY that attached hereto are true and correct copies of Ordinances No. 14 155, 331, 385 and 463, of Article II of Chapter 11 of the Code of Ordinances, an o e Franchise Foz Recycling Collection Services, as amended, with Nichols Sanitation, Inc., as in effect on the date hereof. IN WITNESS WHEREOF, I have hereunto set my hand as of the 24th _ day of June, 1994. By: Village CZerk 7128M Y • $1,3.�000 VILLAGE OF TEQUESTA, FLORIDA, IMPROVEMENT REVENUE REFUNDING BOND, 5ERIES 1999 ESCROW DEPOSIT A . _FMFNT THIS ESCROW DEPOSIT AGREEMENT (this "Agreement"), is dated as of June 24,_.1994, and is by and between VILLAGE OF TEQUESTR, FL�RIDA, a political subdivision of the State of Florida, and its successors and assigns (the "Issuer"), and The Bank of New York Trust Company of Florida, N.A., having its primary corporate trust office in Jacksonville, Florida, a national banking association, as escrow agent, and its successors and assigns (the "Escrow Agent"). �TITNESSETH: WHEREAS, the Issuer has heretofore issued $910,000 aqgregate principal amount of its Improvement Revenue Bonds, Series 1979, dated October 1, 1979, af which �580,OOQ are currently outstanding (the "Refunded Bonds"); and WHEREAS, the Issuer has determined to pr�vide for the payment of the Refunded Bonds by issuing its $1,3fZ5, aggregate principal amount Improvement Revenue Refunding Bond, Series 1994 (the "Refunding Bonds"�; and WHEREAS, a portion of the proceeds derived from the sale of ;the Refunding Bonds will, together with certain moneys currently held by the Issuer in the Sinking Fund �for the Refunded Bonds, be d with the Escrow A ent hereunder, which amount, without — —�— re ard to investment earnin s thereon, has been �etermined y e Issuer to be sufficient to pay when ue the principal, redemption ' premium, and interest on the Refunded Bonds; and WHEREAS, in order to provide for the proper and timely application of the moneys deposited in the trust createcl herein to the payment of the Refunded Bonds, it is necessary for the Issuer to enter into this Escrow Deposit Agreement with the Escrow Agent on behalf af the holders from time to time of the Refunded Bonds; � HOW, THEREFORE, in consideration of the foregoing and the mutual covenants herein set forth and in order to secure the payment of the principal of, premium, and interest on the Refunded B.onds, according to their tenor and effect, the Issuer does by these presents hereby deliver to and give, grant, assign and pledge to the Escrow Agent and to its,successors in the trust hereby created, and to it and its assigns fozever, all and singular the property hereinafter described, to wit: � I. All right, title, and interest of the Issuer in and to �613,640.00 deposited by or on behalf of the Issuer with the Escrow Agent hereunder. II. All right, title, and interest of the Issuer in and to the �j'i.nvestments purchased w�ith the moneys described in Clause I above. III. All right, title, and interest of the Issuer in and to all cash balances held from time �to time hereunder and all incocne and earnings derived from or accruing to the investments described in Clause II above. ' IV. All (i) property which is by the eapress provisions of this Agreement required to be subject to the pledge hereof and (ii) additional property of every kind and nature that may, from time to time hereafter, by delivery or by writing of any kind, be conveyed, pledged, assigned, or transferrecl as and for additional security hereunder or to be subject to the pledge hereof, by the Issuer or by anyone in its behalf, and the Escrow Agent is hereby authorized to receive the same at any time as additional security hereunder, provided that no property described in (ii) shall be '•accepted b� the Escrow Agent unless the Escrow Agent shall receive an opinion of nationally recognized bond counsel to the effect that such acceptance will not cause the interest on the Refunded Bonds and Refunding Bonds to be included in thg gross income of the holders thereof for federal income tas purposes. ?O HAVE AND TO H4LD, all ancl the same, forever;� in trust nevertheless, upon the terms•and trusts herein set forth, for the equal and proportionate benefit,� security and protection, as herein described, of the holders or owners from time to time of the Refunded Bonds in the �manner herein provided; but if the Refunded Bonds shall be fullp and promptly paid when due or redeemed in accoraance with the terms thereof and hereof, then this Agreement shall be and become void and of no further force _2_ 7163M . . and effect, otherwise the same shall remain in full force and effect, and upon the trusts and subject to the covenants and conditions hereinafter set forth. ARTICLE I DEFINITIONS Section 1.01. Definitions. All terms used in capitalized form herein and not otherwise defined herein shall have the meanings ascribed to them in the Bond Resolution. In addition to words and terms elsewhere defined in this Agreement, as used herein, unless some other meaning is plainly intended, the following terms and phrases shall have the following meanings: "Bond Resolution" means Resolution No. 16-93/94 of the Issuer adopted June 23.__1994, authorizing the issuance of the Refunding Bonds. "Escrow Depo.sit Trust Fund" means the fund so designated and established under Section 2.01 of this Agreement. "Emerald Fund" means the money market fund sponsored by Barnett Banks Trust Company, N.A., and known as its "Emerald Fund." "Paying Agent" means The Bank of New York Trust Company of Florida, N.A. as agent for Barnett Hanks Trust Company, N.A. or such other paying agent for the Refunded Bonds as may be appointed by the Issuer from time to time. "Refunded Bond Resolution" means Resolution No. 10-78/79, adopted by the Issuer July 24, 1979, as amended and supplemented by Resolution No. 6-79/80, adopted February 26, 1980, Resolution No. 5-79/80, adopted March 10, 1980 and Resolution No. 9-79/80, adopted March 10, 1980. Section 1.02. Uses of Phrases. Words af the masculine •gender shall be deemed and construed to include correlative words 'of the feminine and neuter genders. Unless the conteat shall otherwise indicate, words importing the singular number shall include the plural number and vice versa. ARTICLE II FST�qj,T $F�j�j'p Qg g�jDS : FLOW OF FUNDS Section 2.01. Creation of Escrow Deposit Trust �'und. There is hereby created and established with the Escrow Agent a special and irrevocable trust fund designated the "Escrow Deposit Trust Fund" to be held in the custody of the Escrow Agent separate and _3_ 7163M apart from other funds of the Issuer or the Escrow Agent. The Escrow Deposit Trust Fund shall be the same fund r.equired to be established by the Issuer pursuant to the Refunded Bond Resolution and referred to therein as the "Sinking Fund." Section 2.02�. Deposit to Escrow Deposit Trust Fund. Concurrently with the eaecution of this Agreement the Issuer has deposited or caused to be deposited with the Escrow Agent and the Escrow Agent acknowledges receipt of immediately available moneys in the amount of 613 640.00 consisting of $390,434.00 proceeds of the Refunding Bonds, 90,000.00 of available un s of the Issuer and $183,206.00 transferred from the Sinking Fund for the Refunded Bonds, for deposit in the Escrow Deposit Trust Fund. The funds deposited in the Escrow Deposit Trust Fund pursuant to the preceding sentence shallYbe immediately invested by the Escrow Agent in the Emerald Fund. Section 2.03. Application of Escrow Deposit Trust Fund. The Escrow Agent shall apply theYmoneys deposited in the Escrow Deposit Trust Fund, together with all income and earnings thereon, in accordance with the provisions hereof. The Escrow Agent shall not invest any moneys held hereunder�eacept as provided in this Agreement. Section Z.04. Irrevocable Trust Cr�ated. Ea�ept as eapressly provided herein, the deposit ofymoneys in the Escrow Deposit Trust Fund shall constitute an irrevocable deposit for the benefit of the holders of the Refunded Bonds and the holders of the Refunded Bonds s�all have an eapress lien on the principal of and earnings on the moneys held in the Escrow Deposit Trust Fund hereunder until applied in accordance with this Agreement. The �inoneys shall be held in trust by the Escrow Agent and used only for the purposes and in the manner provided in this Agreement. Suchvtnoneys in the Escrow Deposit Trust Fund have been calculated on behalf of the Issuer to provide sufficient moneys to pay the principal of, redemption premium, and interest on the Refunded Bonds, as more particularly described on Schedule �_ : Section 2.05. Reaemption of Refunded Bonds. The Issuer has irrevocably called the Refunded Bonds maturing on October l, 2004 fot redemption on August� 1994. Section 2.06. Use of Moneys in Escrow Deposit Trust Fund. �The Escrow Agent shallyon August 1, 1994 transfer from the Escrow �Beposit Trust Fund to hthe Paying Agent amounts sufficient to pay the principal of, premium, if any, and interest due on such Refunded Honds on each such date, as the case may be, as shown on Schedule� Such amounts shall be applied by the Paying Agent to the payment of all principal of, interest on, �nd redemption premium, if any, when due with respect to the Refunded Bonds for the equal and ratable benefit of the holders and registered owners � of the Refunded Bonds. _q_ 7163M >� Section 2.07. Transfer of Funds After All Payments Required by This Agreement Are Made. After all the principa� of, interest on, and redemption premium, if any, with respect to the Refunded Bonds has been paid in full, all remaining moneys�ogether with any income and interest thereon, in the Escrow Dep�sit Trust Fund shall fi=st be applied to the payment of any outstanding and unpaid fees and expenses of the Paying Agent and the Escrow Agent, pro rata if necessary, and then shall be transferred to the Issuer by the Escrow Agent and shall be used by the Issuer in the following order of priority (i),if any Refunding Honds shall be outstanding, to pay principal and interest on such Refunding Bonds, and (ii) otherwise, for any lawful purpose of the Issuer authorized by a written opinion of nationally recognized bond counsel. The Escrow Agent shall have no responsibility for the application of amounts transferred by it to the Issuer as provided above. Section 2.08. Deficiencies. If at any time it shall appear to the Escrow Agent that the available proceeds in the Escrow Deposit Trust Fund will not be sufficient to make any payment when due to the holders of any of the Refunded Bonds, the Escrow Agent shall immediately notify the Issuer by telephone or other telecommunication device, promptly confirmed in writing, and the Issuer agrees that it will make available to the Escrow Agent, from legally available funds, if any, amounts sufficient to eliminate the anticipated deficit so that the Escrow Agent will have sufficient funas to make such payment on the Refunded Bonds. The Escrow Agent shall not be required to determine the sufficiency of amounts on deposit in the Escrow Deposit Trust Fund to make any required payments. Section 2.09. Escrow Agent and Payinq Aqent Fees. The Escrow Agent is receiving a fee from the Issuer of 350.00 for performing its obligations hereunder. The Issuer hereby agrees to provide for the payment from available funds of the Issuer of the compensation due the Paying Agent, which compensation shall be paid at such times and in such amounts as agreed between the Issuer and the Paying Agent. Prior to payment in full of the �Refunded Bonds, in no event shall the Paying Agent or Escrow Agent have any lien, security interest or right of set-off whatsoever upon any of the moneys or investments in the Escrow Deposit Trust Fund for the payment of such compensation, or f or the reimbursement of any eapenses incurred by the Paying Agent or Escrow Aqent in connection with this Agreement. Section 2.10. Notice of Refunding. The Issuer hereby directs the scrow Agent to, on or before July 1, 1994, (i) cause to be published, on behalf of the Issuer, on in a financial journal published in the Horough of Manhattan, City and State of New York a notice of redemption of the Refunded Bonds, which notice shall be in substantially the form attached hereto as Eahibit "1", (ii) mail a copy of the notice to the 1984 Paying _S_ 7163M f T Agent, (iii) mail a copy of the notice, first class mail postage prepaid, to all registered owners of the Refunded Bonds. The Issuer hereby agrees to pay all costs of the Escrow Agent incurred in connection with this Section 2.10. The Issuer hereby directs the Pa�•ing Agent to make availa e o the Escrow Agent the name and addresses of all registered owners of the Refunded Bonds to be redeemed to enable the Escrow Agent to comply with the foregoing notification requirements. Section 2.11. Paying Agent. The Escrow Agent shall cooperate with the Paying Agent to cause necessary arrangements to be made and thereafter continued whereby funds shall be made available by the Escrow Agent to the Paying Agent for the payment of the Refunded Bonds as the same shall become due and payable. ARTICLE III CONCERNING THE ESCROW AGENT Section 3.01. Appointment of Escrow Agent. The Issuer hereby appoints The Bank .of New York Trust Company of Florida, N.A., Jacksonville, Florida as Escrow Agent under this Agreement. Section 3.02. Acceptance by Escrow Agent. By execution of this Agreement, the Escrow Agent accepts its duties and obligations hereunder. Section 3.03. Liability of Escrow Agent. The Escrow Agent shall not be liable in connection with the performance of its duties hereunder eacept for its own gross negligence or willful misconduct. The Escrow Aqent shall not be liable for any loss resulting from any investment made pursuant to the terms and provisions of this Agreement. The Escrow Aqent shall not be liable for the accuracy of the calculations as to the sufficiency of moneysyto pay the Refunded Bonc3s. The Escrow Agent shall not be liable for any deficiencies in the amounts necessary to pay the Refunaed Bonds caused by such '•calculations. The Escrow Agent shall not be liable for any insufficiency of amounts held in the Escrow Deposit Trust Fund to pay principal, premium and interest on the Refunded Bonds�so long as the Escrow Agent complies with the terms and provisions of this Agreement.� The Escrow Agent shall keep such books and records as shall be consistent with prudent industry practice and shall make such books and records available� for inspection by the Issuer at all reasonable times. In he event of the Escrow Agent's failure to account for any of the�moneys received by it, said�moneys shall be and remain the propertp of the Issuer in trust for�the holders of the Refunded Bonds, as herein provided, and if for any reason such ^moneys are not properly applied by the Escrow Agent� as herein �� _6_ 7163M o , ' provided, the Escrow Agent shall be liable to the holders of the Refunded Bonds for the ambunt thereof, and only the amount thereof, until the required application shall be made. Section 3.04. Permitted Acts. The Escrow Agent and its affiliates may become the owner of or may deal in any obligations of the Issuer described herein as fully and with the same rights as if it were not khe Escrow Agent. Section 3.05. Resignation of Escrow Agent. The Escrow Agent at the time acting hereunder may at any time resign and be discharged from the trusts hereby created by giving not less than siaty (60� days' written notice to the Issuer, but the Escrow Agent shall remain in office until the appointment and takinq office of a successor Escrow Agent in accordance with the provisions of this Agreement. Section 3.06. Removal of Escrow Agent. (a) The Escrow Agent may be removed at any time if the holders of a majority in aggregate principal amount of the Refunded Bonds then outstanding file a request for removal in writing with the Issuer, but the Escrow Agent shall remain in office until the appointment and taking office of a successor Escrow Aqent in accoraance with the provisions of this Agreement. A copy of any such Bondholders' request shall be delivered by the Issuer to the Escrow Agent. (b) The Escrow Agent map also be removed at any time for any breach of trust or for any violation of this Agreement by a court of competent jurisaiction upon the application of the Issuer or the holders of not less than fifty percent (50�) in aggregate principal amount of the Refunded Honds then outstanding. (c) The Escrow Agent shall be deemed to have been removed if it is dissolved, becomes incapable of eaercising the powers of Escrow Agent hereunder or is taken over by any governmental action. : Section 3.07. Successor Escrow Agent. (a) When the position of the Escrow Agent becomes or is about to becorne vacant, the Issuer shall appoint a successor Escrow Agent to fill such vacancy, and shall notify the •1984 Paying Agent of the successor. (b) If no appointment of a successor Escrow Agent shall be ma8e pursuant to the foregoing provisions of this Section, the holder of any Refunded Bond then outstanding may, or any Escrow Agent retiring or being removed from office shall, apply to any court of competent jurisdiction to appoint a successor Escrow Agent. Upon the deposit by the retiring Escrow Agent of all funds and securities held bp it under the provisions hereof into the -7- 7163M Q , registry�of such court, such Escrow Agent shall be relieved of all future duties hereunder. Section 3.08. Receipt of Proceedings. Receipt of true and correct copies of the Refunded Bond Resolution and the Bond Resolution is hereby acknowledged by the Escrow Agent, and reference herein to or citation herein of any provision of said document shall be deemed to incorporate the same es a part hereof in the same manner and with the same effect as if.it were fully set forth herein. ARTICLE IV MISCELLANEOUS Section 4.01. Amendments to this Agreement. This Agreement is made for the benefit of the Issuer and the holders from time to time of the Refunded Bonds and it shall not be repealed, revoked, altered or amended without the written consent of all such holders, the Escrow Agent and the Issuer; provided, however, that the Issuer and the Escrow Agent, may, without the consent of, or notice to, such holders, enter into such agreements supplemental to this Agreement as shall not adversely affect the exclusion from gross income for federal income taa purposes of the interest on the Refunded Boncls and the Refunding Bonds and the rights _of such holders and as shall not be inconsistent with the terms and provisions of this Agreement, for any.one or more of the following purposes: (a) to cure any ambiguity or formal defect or omission in this Agreement; (b) to grant to, or confer upon, the Escrow Agent for the benefit of the holders of the holders of the Refunded Bonds, any additional rights, remedies, powers or authority that may lawfully be granted to, or conferred upon, such . holders or the Escrow Agent; and (c) to subject to this Agreement additional funds, securities or properties. The Escrow Agent shall be entitlea to rely eaclusively upon an unqualified opinion of Moyle, Flanigan, Ratz, FitzGerald & Sheehan, P.A. or other nationally recognized bond counsel with respect to compliance with this Section, including the extent, if any, to which any change, modification, addition or •elimination affects the riqhts of the holders of the Refunded Honds, or that any instrument eaecuted hereunder complies with the conditions and . provisions of this Section. - _g- 7163M , , Section 4.OZ. Severability. If any one or more of the covenants or agreements provided in this Agreement should be determined by a court of competent jurisdiction to be contrary to law, such covenant or agreement shall be deemed to be separate and shall in no way affect the validity of the remaining provisi�ns of this Agreement. Section 4.03. Agreement einding. All the covenants, promises and agreements in this Agreement contained by or on ' behalf of the Issuer or by or on behalf of the Escrow Agent shall bind and inure to the benefit o-f their respective successors and assigns, and to the benefit of the holders of the Refunded Bonds, whether so expressed or not. Any corporation or association into which the Escrow Agent may be converted or merged, or with which it may be consolidated, or to which it may sell or transfer its trust business and assets as a whole or substantially as a whole, or any corporation or association resulting from any such conversion, sale, merger, consolidation or transfer to which it is a party, shall be and become successor Escrow Agent hereunder and vested with all the trusts, powers, discretions, immunities, privileges and all other matters as was its predecessor, without the eaecution or filing of any instrument or any further act, deed or conveyance on the part of any of the parties hereto, anything herein to the contrary notwithstanding. Section 4.04. Termination. This Agreement shall terminate when all transfers and payments required to be made by the Escrow Agent under the provisions hereof shall have been made. Section 1�4-` Governing Law. This Agreement shall be governed by the applicable laws of the State of Florida. Section �4.06. E=ecutian by Counterparts. This Agreement may be eaecute d� several counterparts, each of which shall be regarcled for all purposes as an original, end all of which, together, shall constitute ana be but one and the same instrument. Section 4.07. Potices. Any notice, demand, direction, 'request or other instrument authorized or required by this Agreement to be given shall be deemed sufficiently given on the day sent by registered mail, return receipt requested, addressed as follows or to such other address furnished in writinq by any of the following to all of the following: If to the Issuer: Village of Tequesta, Florida 357 Tequesta Drive Tequesta, Florida 33469 _9_ 7163M ! Y If to the Escrow Agent: The Bank of New York Trust Company of Florida, N.A. Towermarc Plaza 10161 Centurion Parkway Jacksonville, Florida 32256 IN WITNESS WHEREOF, the Issuer and the Escrow Agent have duly eaecuted this Agreement as of June 29, 1994. VILLAGE OF TEQUESTA, FLORIDA (SEAL) ATTEST: By; Mayor Village Clerk THE HANK OF NEW YORK TRUST COMPANY OF FLORIDA, N.A. By: Its -10- 71b3M . r 7163M/11 SCHEDULE A . �_ REFUNDED BONDS DEBT SERVICE SCHEDULE Redemption Date Interest Price* Total 8/O1/94 � 16,240.00 �597,400.00 $613,640.00 * Principal amount $580,000 plus premium (103%) of $17,400. s f 7163M/12 EXHIBIT 1 NOTICE OF REDEMPTION VILLAGE OF TEQUESTA, FLORIDA, IMPROVEMENT RE'JENUE BONDS, SERIES 1979 DATED , 1994 NOTICE IS HEREBY GIVEN that all $580,000 principal amount of the Bonds of the above issue currently outstanding and maturing on October 1, 2004 are hereby called for payment and redemption on August 1, 1994 (the "Redemption Date") at a redemption price of l�f the face value thereof, plus accrued interest thereon to the Redemption Date. The Bonds to be redeemed have the following maturities, CUSIP Numbers, and interest rates: Maturity tOctober 1) CUSIP* Interest Rate 2004 8.40$ The Bonds so called for redemption should be presented for payment and redemption at the principal office of The Bank of New York Trust Company of Florida, N.A., (insert address) on or after August_,3„�1994, and will cease to bear interest after that date, whether or not so presented. 4 � 7163M/13 [withholding of 31� of gross redemption proceeds of anX payment made within the United States may be required by the Interest and Dividend Taa Compliance Act of 1983 unless the Paying Agent has the correct taapayer identification number (social security or employer identification number) or e�emption certificate of the payee. Please furnish a properly completed IRS Form W or exemption certificate or equivalent when presenting your securities for redemption.] Dated this day of , 1994. Hy: THE BANK OF NEW YORK TRUST COMPANY OF FLORIDA, N.A., escrow ageat * CUSIP numbers are included solely far the convenience of the Owners. Neither the Issuer nor the Escrow Agent shall be responsible for the selection or use of the CUSIP numbers nor is any representation made as to the correctness of the CUSIP numbers indicated in this Redemption Notice. TNSTRUGTIONS TO ESCROW AGENT This Notice must be published by the Escrow Agent on behalf of the Issuer and filed with the Paying Agent, all as provided in Section 2.11 of the Escrow Deposit Agreement. '. � 7131M 4. �1, 36_ 00 VILLAG.E OF TEQUESTA, FLORIDA IMPROVEMENT REVENUE REFUNDING BOND SERIES 1994 GEN$RAL CERTIFICATE OF THE ISSUER We, the undersigned Mayor (the "Mayor") and Village Clerk ("Clerk") of the.Village of Tequesta, Florida (the "Issuer"), DO HEREBY CERTIFY as follows: 1. We are the qualified and acting Mayor and Village Clerk of the Issuer. 2. The following is a correct listing of the names of the members of the Village Council of the Issuer, and the dates of eapiration of their respective terms of office: Eapiration . Name and Position of Term Ron T. Mackail March, 1996 Mayor William E. Burckart March, 1996 Vice-Mayor Earl L. Collings March, 1995 Joseph Capretta March, 1996 Elizabeth A. Schauer March, 1995 3. Al1 of the above members of the Village Council have duly filed their oaths of office and such of them as are required by law to file bonds or undertakings have duly filed such bonds or undertakings in the amount and manner required by law. 4. Jones, Foster, Johnston & Stubbs, P.A. are the duly appointed Attorneys for the Issuer and accordingly are entitled to sign opinions anti other documents pertaining to the Village Council, the Issuer, and the Issuer's �1,365 Improvement Revenue Refundinq Bond, Series 1994 (the "Bond"). The law firm of Moyle, Flanigan, Ratz, FitzGerald ��Sheehan, P.A., is bond counsel for the Issuer, and accordingly is entitled to sign opinions and other documents as bond counsel. . , 5. The Mayor has signed the Bond by his manual signature, and the manual signature appearing on the Bond and the manual signature at the end of this certificate are each the true and lawful signature of the Mayor. 6. The seal of the Issuer was impressed upon the Bond, and attested by the manual signature of the Clerk. Such seal and signature appearing on the Bond and the manual signature of the Clerk and the impression of the seal of the Issuer at the end of this certificate constitute the true and lawful seal of the Issuer and the signature of the Clerk, respectively. 7. The Bond, as eaecuted and delivered, is in the form approved by the Village Council in Resolution No. 16-93/94 (the "Resolution"). � 8. The Issuer has authorized by all necessary action the adoption and due performance of the Resolution and the execution, delivery and due performance of the Bond and, to the best of our knowledge, any and all such other agreements and documents as may be requirea to be eaecuted, delivered and received by the Issuer to carry out, give effect to and consummate the transactions contemplated by the Resolution. 9. No litigation is pending or, to our knowledge, threatened, in or before any agency, court or tribunal, state or federal (i) to restrain or enjoin the issuance, delivery or validity of the Bond or (ii) in any way contesting or affec�ing the validity of the Hond or the Resolution or the application of the proceeds of the Bond, or the levy or collection or distribution of the Franchise Fees or Occupational License Fees and any other amounts pledged to repayment of the Bond, or the pledge thereof as security for the Bond, or (iii) contesting the power of the Issuer or any authority for the issuance of the Bond or the adoption of the Resolution or the approval, eaecution, validity, or. enforceability of any agreements with respect - thereto, or (iv) contesting the tax-eaempt status of interest on the Bond. •� 10. No litigation is pending or, to our knowledge, threatened, (i) against the Issuer or involving any of the property, assets or operations under the control of the Issuer which involves the possibility that a judgment or liability, not fully covered by insurance ,or adequate estab�ished reserves, may be entered or imposed against the Issuer or which may result in any material adverse change in the business, properties, assets or in the condition, financial or otherwise, of the Issuer, and (ii) which would reasonably be anticipated to have a material and adverse effect upon the security provided for the Bond pursuant to the Resolution. _2_ 7131M , . , 11. No litigation is pending or, to our.knowledge, threatened to contest the creation, organization, existence or corporate powers of the Issuer, or of the Village Council, or the title to office of its present members, or the members at any time material to the issuance of the Bond, or of any other officer of the Issuer. 12. The eaecution, delivery, receipt and due performance of the Hond and the other agreements contemplated by the Resolution, under the circumstances contemplated thereby and the Issuer's compliance with the provisions thereof (i) to the best of our knowledge will not conflict with or constitute on the Issuer's part a breach of or a default under any eaisting constitutional provision, law, court or administrative regulation,. decree or order or (ii) will not conflict with or constitute on the Issuer's part a breach of or a default under any agreement, indenture, bond, note, lease or other instrument to which the Issuer is subject or by which the Issuer is or may be bound, and to the best of our knowledge no event has occuzred and is contintiing which with the passage of time or the giving of notice, or both, would constitute a default or event of default under any such instrument, nor will such eaecution, delivery, adoption, or compliance result in the creation or imposition of any lien, charge oz other security interest or encumbrance of any nature whatsoever upon any of the property or assets of the Issuer except as provided by the Bond and the Resolution. 13. The undersigned have not, and to the best of their knowledge no members of the Village Council have, while meeting together with any other member or members of the Village Council other than at public meetings of the Village Council, reached any conclusion as to the actions taken by the Village Council with respect to the Hond, the security therefor, or the application of the proceeds therefrom, or any other material matters with respect to the Bond. 14. The undersigned do not, and to the best of their knowledge and belief no member of the Village Council does, have or hold any employment or contractual relationship with any •.business entity which is purchasing the Bond f rom the Issuer eacept as fully and fairly disclosed in compliance with the provisions of Section 112.3143, Florida Statutes. 15. The Issuer has not been in default at any time after December 31, 1975 as.to principal or interest with respect to any obligations issued or guaranteed by the Issuer or a predecessor of the Issuer. 16. All financial information provided by the Issuer to Jupiter Tequesta National Bank was and is accurate and complete. The Village has the requisite power and authority to adopt the Resolution, issue the Bond and pledge and assign the Pledged Revenues to the payment of the Bond. The Issuer has now and _3_ 7131M , . eapects that it will have in the future sufficient lawfully and contractually available non-ad valorem revenues ta pay debt service on the Bond in the event the Issuer does not collect the amount of Franchise Fees and Occupational License Fees required under the Resolution. The ordinances relating to the levy and collection of the Franchise Fees and Occupational License Fees (collectively, the "Ordinances") have been duly enacted by the Issuer, remain in full force and effect and are legal, valid and binding ordinances of the Issuer. There is no pledge of the Franchise Fees or Occupationel License Fees, or any o er amoun_s pledged for repayment of the Bonds e�cept fo the pledge with respect to the Issuer's �910,000 aggregate principal amount of Improvement Revenue Bonds, Seri,es 1979, dated October 1, 1979, of which $580,000 are currently outstanding, which are to be paid with a portion of the proceeds derived from the sale of the Bond. 17. The issuer hereby certifies that the interest rate on the Bond does not eaceed the maximum rate permitted pursuant to Section 215.84, Florida Statutes. IN WITNESS WHEREOF, we have hereunto set our hands and the official seal of the Issuer, and have indicated our respective official titles, all as of the 24th day of June, 1994. Signature offic�a� Title Mayor Ron T. Mackail Village Clerk Joann Manganiello (Official Seal) ' The undersigned John C. Randolph, Village Attorney to the Village of Tequesta, Florida, does hereby certify that Ron T. Mackail is the duly qualified and acting Mayor of the Issuer and that Joann Manganiello is the duly appointed and acting Village Clerk of the Issuer, and that the signatures set forth above are those of the Mayor and Village Clerk of the Issuer. DATED June 24, 1994 John C. Randolph, Village Attorney _q_ 7131M D � June Z3, 1994 SERTIFIED MAIL Division of Bond Finance RETURN RECEIPT REOUESTED State Board of Administration P.O. Drawer 5318 Tallahassee, Florida 32314 RE: $1,36_5�.000, VILLAGE OF TEQUESTA, FLORIDA IMPROVEMENT REVENUE REFUNDING BOND, SERIES 1994 Ladies and Gentlemen: This firm is serving as bond counsel for the above-referenced bond issue. This notice is provided to you in accordance with the requirements of Section 218.38(1)(a), Florida Statutes, as implemented by Rule 19A-1.0041, Florida Administrative Code. Notice is hereby given of the impending sale by Village of Tequesta, Florida (the "Issuer") of the abave-referenced Bond (the "Bond") in the estimated principal amount set forth above. The Issuer eapects to deliver the Bond on or a�bout June 2�1994. Copies of Forms BF-2003 and BF-2004-B will be forwarded to you as soon as they are available. . Sincerely, • MOYLE, FLANIGAN, KATZ, FITZGERALD & SHEEHAN, P.A. Mark E. Raymond MER/ash 7132M $1,365'000 VILLAGE OF TEQUESTA, FLORIDA IMPROVEMENT REVENUE REFUNDING BOND SERIES 1994 I3ECEIPT FOR BOND Jupiter Tequesta National Bank (the "Bank"), DOES HEREBY ACKNOWLEDGE receipt from Village of Tequesta, Florida of (i.) the Village's Improvement Revenue Refunding Bond, Series 1994, dated June 24, 1994, in the aggregate principal amount of $1,355,000. D the 24th day of June, 1994. JUPITER/TEQUESTA NATIONAL BANK By: Its Authorized Representative � 7133M i / June 24, 1994 CERT�'IED MAIL RETURN RECEIPT REnUESTED Division of Bond Finance 5tate Board of Administration P.O. Drawer 5318 . Tallahassee, Florida 32314 RE: �1,3�008, VILLAGE OF TEQUESTA, FLORIDA IMPROVEMENT REVENUE REFUNDING BOND SERIES 1994 . Ladies and Gentlemen: � Enclosed herewith please find Forms HF-20Q3 and BF-2004-B for the above-referenced financinq. No Official Statement was prepared for this issue. If you would like any further information in regard to this matter, please do not hesitate to call. Sincerely, � Mark E. Raymond � 7134M , 713 5y S?l►TE OF f LOR I D� DIVISIQ�1 OF SOi�iD FIH7INCE LOCAL 8()ND MQ�1I?ORING SECTION BOT7D INFOFMATIC�N FORM Part I. Issuez Infcrmation l. Name of Go•�eramental Unit Village of Tequesta, Florida ' 2. Mailinq Address __ 357 Tequesta Drive 3. City Tequesta 4. County Palm Beach 5. Zip Code 33469 6. Type of IBSUer: County Depe�dent Special District _� City Independent Special District Authority Other � Part II. Bond Issue Information 1. Name of Issue Imgrovement Revenue Refundina Bond. Series 1994 2. Amount Iss�ed �1, 3. Amount Authorized E 1,365,000 4. Dated Date 6/24/94 5. Sale Date 6/23/94 6. Delivery Date 24/94 7. Legal Authority fo ance . Florida Statutes Chavter 166 Special Act Other Fla. Const. Art. VIII. Sec. Z 8. ?ype of Issue . ' General Obli�ation _$_ Revenue Special Assessment Special Obligation 9. Specific xevenue(s) Pledged (1) Primarp Franchise Fees (2) Secondary Occupational License Fees (3) Tertiarp (4) Other 10. Purposeis) ot the issue (l� 8efundinq (2) Capital Improv�nents (3) (4) (BF2003) . , 10a. If purpose is refundinq, complete the following: (1) For each issue•refunded, list name of issue, dated date, original par value of issue, and amount of par value retunded. (a) Improvement Re �n�e Bond Series 1979 inin�i79: 5910,0�;; — (b� (c) (2) Refuaded debt hes been: retired, or _� defeased 11. Type of Sale Competitive Bid Private Placement . �_ Negotiated 12. Basis of Interest Rate Calculation Rate Net Interest Cost (NIC) 6.15� True Interest Cost (TIC) Canadian Intereot Cost (CIC) Other 13. Insurance • AMBAC (MGIC) MBIAC �_ Noae 14. Rating(s) Moody's . Standard � Poor's Other �_ lione 15. Finaacial Advisor or Consultant , Florida Munic�i�l Ad��; �^T� _ Tnc 16. �Boad Counsel ldovle Flaniqan 1Catz FitzGerald � Sheehan P A 17. Lead Manaqinq Unders+riter(s) 18. Papinq Aqent 19. Heqistrar _ 7135M 20. Maturity Schedule (Fill in following schedule showing annual amounts for boad years or attach completed maturity schedule.) Maturity Coupon Anaual Principal Mandatory Date i Interest (Par Value) Term Amoztiza±io: SEE EXHI A _3_ 7135M � t . 21. Optio�al Redemption Provisions M�,y be;,�revaid at an�*;me in whole or in part et flnr vlus nccrued interest rlus a va-iable ozem+t±m - Z2. Comments Non - Part IIi. Respoadent Information: 1. Name Mark E R� ^^a Title Bond Counsel Phone (407) - 659-7500 Date Report Submitted 6/24/94 ' Part IV. 2. Please return completed form alang with Final Official Statement, if any, to: Division of 8oa8 Finance State Board of 1ldministration P.O. Drawer 5318 Tailahasee, Florida 32314 ' (904) 488-7482 -4- 7135M 7136M STATE OF FLOP.IDA DIVISIOi7 OF BOND FINAtJrE LOCAL BOND MONITORING SECTIC}N BOZID DISCLOSURE FORM - NEGOTIATED SALE Disclosure form for units of local government for bonds sold by aegotiated sale, as required by Section 218.38(1)tc)(1), Florida Statutes, as amended in 1982. This form must be completed and returned to the Division within 120 days efter the delivery of the bonds. l. Title of unit of local qovernmeat: Village of Teq��esta Florida 2. Mailing Address: 357 Tecuesta Drive -- Teqgesta Florida 33469 3. Name of bond issue: I�nprovemeat Revenue Refundina Bond Series 1994 4. Amount issued: �� 365 000 5. Dated date: June 2 994 6. Delivery Date: June 24, 1994 .� 7. Name and address of the manaqing underWriters connected with boad issue: None �. Name aad nddress of aay attorney or financial consultant rho advised the unit of local governmeat with respect to the bond issue: (1) MQyle Flaniaxn 1Catz F3tzGerald � Sheehan P A Post Office Boa 3888 -- West Palm Beach Floridn 3�402 — (2) Jones Foster Jo�a�`on & Stubbs P A - P O Boa 3475 West Palm Beach Flo�ida 3340� (3) (4) � BF2004-8 (3190) � t 9. Management fee charqed by underWriters N/A 10. Underwriter's ezpected qross cpread: N/A 11. Any fee, bonus, or qratuity paid in connection wit�. the bond issue, by any underxriter or financiel coasultent to any person not regularly employed or engaqed by such underxriter or consultant: (1) Name Amount � (2) Neme Amount a (3) Name Amouat S (If ndditional space is needed, continue on separate sheet.) 12. Any other fee paid by the unit of local qovernment Mith respect to the bond issue, includinq any fee paid to attorneys or financial coasultants: (1) Name �S.Qy��e Flaniqan Ratz et al. Amount 51�000.00 ( 2) Name -T^^�� �'^°reT _ et al Amount S i3) Name r�^*';�A � Advisors Inc. Amount � 8.000.00 (4) Name �*••~*s & BoW n _ Amount $ 7.500.00 iIf additional space is needed, contiaue on separate sheet.) 13. The signature of either the chief eaecutive officer of the governing body of the Unit of Local Government or the governmental officer. primarily responsible for coordinating the issuance of the bonds must be affized hereto. Signature Title 1K�yor Date June 24 1994 14. For further informatioa zeqardinq this form, the Division sh d contact: Name Mark E Rarmond Phone No. (407) 659-7500 15. Completed form should be returned to: Division of Boad Finance State Board of Administration of Florida P.O. Drarer 5318 Tallahassee, Florida 3Z314 (904) 488-4782 � _Z_ 7136M d f 7137M �1,365,000 VILLAGE OF TEQUESTA, FLORIDA IMPROVEMENT REVENUE REFUNDING BOND, SERIES 1994 CERTIFICATE AS TO ARBITRAGE AND OTHER TAX MATTERS Ron T. Mackail, the undersigned Mayor of Yillaqe of Tequesta, Florida (the "Issuer"), being duly authorized and deleqated, with others, to perform such requirements as are necessary and proper for the issuance and sale of the Issuer's $1,365 000 Improvement Revenue Refunding Bond, Series 1994 ("the Bond" , does hereby certify and declare as follows: I. IN GENERAL. 1.1. The Bond is being issued pursuant to and uncler Chapter 166, Florida Statutes, Article VIII, Section 2, Florida Constitution, and other applicable provisions of law, and a resolution adopted by the Issuer on June 23, 1994 (the "Bond Resolution"), in order to provide funds t ndertake certain improvements to the Issuer's recreational facilities and roadways (the "Project") ancl to current-refund� all of the Issuer's Improvement Revenue Bonds, Series 1979 that remain outstanding. 1.2. The Issuer will issue and deliver the Bond on June 24, 1994 at a price of par. 1.3. I have reviewed and am familiar with the Bond Resolution and all other proceedings taken preliminary to .and in connection with the issuance of the Hond. I am an officer of the Issuer who is duly charged, with others, with the responsibility ., of issuing the Bond. 1.4. No obligations other than the Bond are being_issued within 15 days of the Bond pursuant to a same plan of financing that are reasonably expected to be paid from substantially the same source of funds as the Bond. . 1.5. The facts, estimates, and circumstances set forth herein are representations made by the Issuer, and to the best of my knowledge, information, and belief, such facts, estimates, and circumstances are true, correct, and complete as of the date hereof, and the Issuer is not aware of any facts or circumstances that would cause it to question the accuracy of the representations made herein; the eapectations as to future events, w . are in all respects reasonable; and there are no other facts, estimates, or circumstances that would materially change such eapectations. On the basis of such facts, estimates, and circumstances, it is not expected that the proceeds of the Bond will be used in a manner that would cause the Hond to be an arbitrage bond under Section 148 of the Code and the applicable regulations thereunder. II. THE GOVERNMENTAL PURPOSE OF THE BON�• THE REFUNDED BONDS. 2.1 The Bond is being issued to provide for the current-refunding of the Refunded Bonds and to provide funds for the Project. � 2.2 40 934.00 of proceeds of the Hond will be used, �$3 , together wit 183 206.00 proceeds of the Refunded Bonds and 90 000.00 of available fun s of the Issuer, to make a deposit to a fun es ablished pursuant to an escrow deposit agreement, and will be used to pay principal of, premium, and interest on the Refunded �onds to and including August 1, 1994, on which date the Refunded Bonds have been called for redemption. � On August 1� 1994, there shall remain no unspent proceeds of the efunded Bonds. �2.3. $1,024,566.00 of proceeds of the Bonds will be used to pay th o t e Pro�ec and costs of issuance of the Bonds. , III. SOtn?GE AND DISTRIBUTION OF FUNDS. 3.1. The Bond is being sold to Jupiter Tequesta National Bank at a purchase price of �1,365,000.00 �representing the par amount of the Bond). 3.2. The proceeds derived from the sale of the Bond will be applied as follows: Project Costs and Costs of Issuance $ 1,024,566.00 Refunding 390.434.00 Total $ 1,365,000.00 3.3. Amounts to be used to pay the cost of the Project, �ogether with investment earnings thereon, will be expended by the end of the three (3� year period beginning on the date of this Certificate. The Issuer has incurre8 or will within 6 months incur a binding obligation in an amount qreater than _�51,228.30 relating to the acquisition, construction and equipping of the Project. Work on the Project has commenced and will proceed with due diligence to completion. Proceeds of the Bond to be used to pay the cost of the Project may be invested at an unrestricted Yield for a period not to � eaceed three (3) pears from the date of this Certificate. . -2- 7137M x s Investment earnings on proceeds of the Bond to be used to pay the cost of the Project may be invested at an unrestricted Yield for a period ending on the date three years from the date hereof. Any proceeds of the Bond and earnings thereon which cannot be invested at an unrestricted Yield pursuant to this Section 3.3 shall be invested, if at all, in obligations that bear a yield equal to or less than the yield on the Bond Qlus one-eighth of one gercent (1/8$). 3.4. The amount of 390,434.00 of proceeds of the Bond being used to discharge the Refun e on s and all amounts being used to pay costs of issuance will be spent within 90 days of this Certificate and may thus be invested at an unrestricted yield. 3.5. Pursuant to the Bond Resolution the Issuer is obligated to use Franchise Fees and Occupational License Fees to pay the principal of, remium, if an , and interest on the Bond. Amounts expected to be use to pay principal and interest on the Bond are referred to herein as the "Bona Fide Debt Service Fund". The Bona Fide Debt Service Fund is a fund that will be used primarily to achieve a proper matching of revenues and debt service on the Bond within each bond year. The Bona Fide Debt Service Fund will be depleted at least once each bond year except for a reasonable carryover amount which will not eaceed the greater of (A) the earnings on the Hona Fide Debt Service Fund for the preceding bond year or �H) one-twelfth of the annual debt service on the Bond for the preceding bond year. Amounts in the Bona Fide Debt Service Fund thus qualify for the temporary period described in Treas. Reg. Section 1.148-2(g)(5)(ii). Such amounts may thus be invested without regard to any yield restrictions for a period ending not later than thirteen (13) months from the date of receipt of such amounts. " Any amounts eapected to be used to pay the debt service on the Bond which cannot be invested at an unrestricted yield pursuant to the preceding paragraph shall be invested, if at all, in obligations that bear a yield not more than one-thousandth of one percent higher than the yield on the Bond. , 3.6. Pursuant to Section 198 of the Code, notwithstanding any provision of this Article III to the contrary, to the eztent permitted by the Bond Resolution amounts may be invested in obligations ("taa-eaempt bonds") the interest on which is eacluded from gross income pursuant to Section 103(a) of the Code, and which are not specified private activity bonds (as defined in Section 57(a)(5)(c) of the Code), and/or in investments that constitute "taa-eaempt bonds" pursuant to Treas. Reg. §1.150-1(b), without regard to any yield restriction. IV. �rbitr�ge Rebate • 4.1. The Bond is eaempt from the rebate requirement of Section 148{f) of the Code by virtue of Section 148(f)(4)(D). -3- • ?137M a r V. Hedae Bonds 5.1. The Issuer reasonably eapects that at least 85% of the spendable proceeds of the Bond will be used to carry cut the governmental purposes for which the Hond is being issued within �he three year period beginning on the date the Bond is issued. Not more than 50� of the proceeds of the Bond are being int�ested in non-purpose investments (as defined in Section 198(f)(6)(A) of the Code) having a substantially guaranteed yield for four years or more. The Issuer reasonably expected that at least 85� of the spendable proceeds of the Refunded Bonds would be used to carry out the governmental purposes for which the Refunded Bonds were issued within the three-year� period beginning on the date the Refunded Bonds were issued. Not more than 50% of the proceeds of the Refunded Bonds were invested in non-purpose investments having a substantially guaranteed yield for four years or more. VI. Miscellaneous 6.1. Terms used herein in capitalized form and not otherwise defined herein shall have the same meaning as ascribed thereto in the Bond Resolution and in the Arbitrage Regulations. 6.2. Anything in this Certificate to the contrary notwithstanding, if the Code or Arbitrage Regulations should be modified or interpreted by the Treasury Department or by a court of competent jurisdiction or held invalid by a court of competent jurisdiction and the affect of the modification, interpretation, or invalidation is to make unnecessary to any eatent the limitations on yield on acquired obligations stipulated in this Certificate as a requirement of the exclusion of the interest on the Bond from gross income of the owners thereof for Federal income taa purposes, then to that eatent such stipulation shall be ineffective. The Issuer, however, shall not take any action pursuant to this paragraph without a prior written opinion of counsel that such action would not advessely affect the taa-exempt status of interest on the bonds. � 6.3. The amount of original proceeds and eapected investment proceeds of the Bond does not eaceed the amount necessary for the Project and the refunding of the Refunded Bonds and no portion of the Bond is being issued for the purpose of investing the proceeds at a yield that is higher than the yield on the Bond. 6.4. The proceeds of the Bond are not being used as a substitute for any other funds which were designated to be used to pay the cost of the Project or the refunding of t'he Refunded Bonds and which have been or will be invested at a yield higher than the. Yield on the Bond. _q_ 7137M � , 6.5. The Bond is not being issued in conner.tion with any transaction or series of transactions that attempts to circumvent the provisions of the Code or Arbitrage Regulations by (a) enabling the Issuer to exploit the difference between taa-eaempt and taxable interest rates to gain a material financial advantage, and {b) overburdening the market for tax-exempt obligations including, without limitation, the selling of bonds that would not otherwise be sold, the selling of more than would otherwise be necessary, or the issuing of bonds sooner, or allowing them to remain outstanding longer, than would otherwise be necessary. 6.6. No portion of the payment of principal or interest with respect to the Bond is guaranteed (in whole or in part) by the United States (or any agency or instrumentality thereof). No portion of the proceeds of the Bond will be used in making loans the payment of principal or interest with respect to which are to be guaranteed (in whole or in part) by the United States (or any agency or instrumentality thereof). No portion of the proceeds of the Bond will be invested (directly or indirectly) in federally insured deposits or accounts. The foregoing restrictions shall not apply to amounts that may be invested at an unrestricted Yield pursuant to this Certificate. In addition, the foregoing shall not prohibit investments in obligations of the United States issuea by the United States Treasury. IN WITNESS WHEREOF, the undersigned, being the Mayor of the Village of Tequesta, Florida, and being thereunto authorized, has eaecuted and delivered this Certificate as to Arbitrage and Other Taa Matters on behalf of the Issuer this Z� th day of June, 1994. VILLAGE OF TEQUESTA, FLORIDA By: Mayor -5- 7137M a . June 24, 1994 Internal Revenue Service Center CERTIFIED MAIL Philadelphia, PA 19255 RETURN RECEIPT REOUESTED RE: �1,3b5 000, VILLAGE OF TEQUESTA, FLORIDA IMPROVEMENT REVENUE REFUNDING BOND, SERIES 1994 Dear Sir/Madam: Enclosed please find Form 8038-G which relates to the..above- referenced bond. Please acknowledge your receipt of the enclosed by stamping the copy of the form included herewith, and return the stamped copy to us in the enclosed envelope. MOYLE, FLP,NIGAN, KATZ, FITZGERALD & SHEEHAN, P.A. By: ;MER/ah Enclosure � 7138M � . �„ 8�38.G Intormatio� Return for Taxfxempt GovernmeMal Obit@ations ► Und�r Int�msl R�v�nu� Cod� s�etbn 11pN) 0�8 No ts�s-o�2o �v. May 1993) ► � Mp�rst� InstrucUons. pp��r+re d uw Tw�wy FORT1 ��-(,�C �( 1tN I�U� M«�u' W+��w srv�ri NM P�C� Y u►1dN =100.000.) Re ortin Autfior' H Am�ndsd R�turn, check hers ► 1 Issuors nart� 2 I��r'� �rnployr �OantA�cat�on numtwr Village of Z�equesta, Florida 59 i 6044081 i Numbr ard sVwt (or P.O. Dox M maii is not dolN.r.� to strw� ador.ss} Roomhuh• s i1.pon nurro.r 357 esta Drive . G19 94 _ 1 s C�tr. sown. stat., .r,a na ooa. t oae. 01 n.ua sta FL 33469 June 24, 1994 7 Narr� ot ipw � CUSIP Numb�r mvPSnent Revenue Refundin Bond, Series 1994 None T e ot Issue check a licable box es and ente� tl�e issue rice �w D� Y ❑ Education (attach schsdub-see instructions) . . . . . . . . . . t !0 ❑ Heattt► and hospftat (attach schsduls-sse hstructions). . . . . . . . . . . . � 11 ❑ Transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 ❑ Pubtic safety . . . . . . . . . . . . . . . . . . . . . � � . . . . . 13 ❑ Environrnent (includinp sewape bonds) . . . . . . . . . . . . . . 14 ❑ HousinD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 ❑ lJtilities . . . . . . . . . . . . . . . . . . . . . . 10 (� Other. Desaibe (sse hstructions) ►_ Re�reation and Road�v � 1 365 000.00 17 H obliDations ane tax a other revenue anticipatio� bonds, cfiack box ►❑ 18 H obli ations aro in ths form of � kase or instatknent sale, eheck box ►❑ Descri ion oi Obli ations • ldl N1 Mawr'�it�r dst� Int�i nu Iwu pria Su»d naemption W�ip�t�d . Y'w�id Net �inast ' • �t matur ev�r� m� eost 1� F�na1 maturity. 7 1 2009 6. 5% 135 000 135 000 20 Entire issue , 1, 65, 0 0 1 365 000 9 ears !6 b.1S 9G Uses of Ori inal Proceeds of Bond Issue mcludin underwriters' discount Z1 Proceeds used for accrusd interost . . . . . . . . . . . . . . . . . . . . Z1 22 Issue price oi enti�e is.ws (snter �mount irom Ine 20, column (c)) ...�.�. .�. 22 1 365 000 23 Proceeds used tor bo�d l�uarice costs (inctudnp underwriters' dscou� .� 2� Prxeeds used tor credd �nhancem�t . . . . . . . . . . . 24 25 Procseds allocated to rsasoneby roquired reservs or �eplacement fund .� Z5 Z6 Proceeds used to reiund pria issues . . . . . . . . . . . . Z6 37 7ota1(add 6nes 23 ttuou�h 267 . . . . . . . . . . . . . . . . . . 27 6 0 28 Nonrefundn oceeds ot Ihe issue subtract I'ne 27 irom Gne 22 �nd snter amount here ., 28 4 8 00 Gescri tion ef Refunded Bonds com lete this a�t onl for retundin bonds 29 Enter the remau�inp weiDhted �verape maturity ot the bonds to be rotunded ......► 5.77 Years SO Enter ths Iast date on which 1fie rofundsd bonds v�n'II be called .....�.�,.�► 8/1/94 31 Enter the date(s) the rei�►ded bonds were issued ► ����p� �� M�soellaneous 32 Enter fhe amount oT ths state volume cap allocated to !hs issue ,....•. ...,► 33 E�er the alrtotmt ot the bonds desJpna�ted by the issuer under section 265(b)(3)(8�(I�R (smmall issuer �xceptior� . . , . , , , , , , , , , , . � 580, 000.00 . . . . . . . . . . . . . . � Pooled financfips: a EN�r 1he �mauM of the procaeds a� this issue that are � be used to make loans to oMer paemmental nnits ► b ft fhis issus is a ban m�de 1Fom the proceeds of �nothx tax-sxempt issue, d�ack box ► 0 and enter the name of ttu Mrsu� ► and the dats of the 1ssu� ► �S If �e tssuer has elected ta � a in lieu ot rebate, chsek box ....,,► t�a� P� � P�►'NY. I e�da� uut � tww wnr'rrd this ntum and +eoomPrnYinp sen�r�s and wanrr�. ane m Ih� b�st or m�r tawwl�dp� �nd b�t. ttiY aR en+�. aawel. and oompbt�. Please Sign H@f'@ ` 6/24/94 , Ron T. Mackail. Mavor' SipnaN� oi o1hoM D�t� Typ� p► peie� �nN �ny tiqe Far Psperwortc iteductjon Ad Nol�w� s� pa�� 1 of th� Instruclions. caL No. a3�r�s Fom, 803&G �. s-x�1 , , �1,3 Village of Tequesta, Florida Improvement Revenue Refunding Bond Series 1999 DISGLOSURE STATEMENT OF . •TUPITER TEOUESTA NATIONAL BANK June 24, 1994 Village of Tequesta, Florida Tequesta, FL Moyle, Flanigan, Ratz FitzGerald & Sheshan, P.A. West Palm Beach, FL . Laaies and Gentlemen: In connection with the purchase of the $1,3�000 aggregate principal amount Village of Tequesta, Florida (the "Issuer"), Improvement Revenue Refunding Bond, Series 1994 (the "Bona") authorized to be issued by a resolution of the Issuer adopted June 2_3 _1994 (the "Resolution"�, the undersigned purchaser of the Bond (the "Original Purchaser"), hereby acknowledges and represents that: (i) the Original Purchaser is familiar with Village of Tequesta, Florida (the "Issuer"); (ii) the Original Purchaser has been furnished certain business and financial information about the Issuer; (iii) the Issuer has made available to the Original Purchaser the opportunity to obtain additional .information to verify the accuracy of the information supplied and to evaluate the merits and risks of an investment in�the Bond; and (iv) the Original Purchaser has had the opportunity to ask questions of and receive answers from representatives of the Issuer concerning the terms and conditions of the offering and the information supplied to the Original Purchaser. The undersigned acknowledges and represents that it has been advised that the Hona has not been registered under the Securities 71b7M , . Village of Tequesta, Florida Moyle, Flanigan, Ratz � FitzGera2d & Sheehan, P.A. June 29, 1999 Page 2 Act of 1933, as amended, in reliance upon the ezemption contained in Section 3(a)(Z) thereof, and that the Issuer is not presently registered under Section 12 of the Securitie's and Eachange Act of 1939, as amended. The Original Purchaser, therefore, realizes that if and when the Original Purchaser wishes to resell the Hond there may not be available current business and financia� . information about the Issuer. Further, no trading market now eaists for the Bond. Accordingly, the Original Purchaser understands that it may need to bear the risks of this investment for an indefinite time, since any sale prior to the maturity of the Sond may not be possible or may be at a price below that which the Original Purchaser is paying for the Bond. It is understood that the Original Purchaser has undertaken to verify the accuracy, completeness and truth of any statements made concerning any of the material facts relating to this transaction, including information regarding the business and financial condition of the Issuer. The Original Purchaser has conducted its own investigation to the eztent it deemed necessary. The Original. Purchaser has been offerea an opportunity to have�made available to it any and all such information it might request from the Issuer. On_ this basis, it is agreed by acknowledgment of this letter that the Original Purchaser hereto is not relying on any party or person other than the Issuer to undertake the furnishing or verification of information relating to this transaction. � Pursuant to the provisions of subsection (6) of Section 218.385, Florida Statutes, as amended, the Original Purchaser is providing the following information with respect to the arrangements made for the purchase of the Hond. We represent to you as follows: � (a} The nature and estimated amounts of eapenses to be � � incurred by the Original Purchaser in connection with the issuance and sale of the Bond is $7,500.00, which is the fee of the Original Purchaser's lega counse . (b) There were no "finders," as defined in Section 218.386, Florida Statutes, as amended, in connection with the issuance of the Bond. (c) No discount or fee is eapected to be realized by the Original Purchaser. (d) No management fee will be charged by the Original Purchaser. 7167M s a Village of Tequesta, Florida Moyle, Flanigan, Ratz FitzGerald & Sheehan, P.A. June 24, 1994 Page 3 (e) No fee, bonus or other compensation will be paid by the Original Purchaser in connection with the issuance of the Hond to any person not regularly employed or retained by the Original Purchaser. (f) The name and address of the Original Purchaser is: Jupiter Tequesta National Bank 250 Tequesta Drive Tequesta, Florida (g) The Village is proposing to issue �1,3�,, of debt for the purpose of refinancing the village's Improvement Revenue Bonds, Series 1979 and financing the cost of certain capital improvements. This debt is expected to be repaid over a period of 15 years. At a forecasted interest rate of 6.15�, total interest paid over the life of the debt will be a�proaimately �765,675.00. The source of repayment or securit�o— e Bond• is franchise fees and occupational license fees of the Village. � Authorizing this debt will result in _avproaimately .$2,130,675.00 of franchise fees and occupational license , ees no eing available to finance other services of the villaqe each year for 15 years. � Very truly yours, JUPITER TEQUESTA NATIONAL BANR By: Authorized Officer 7167M � [TO.BE PLACED ON JONES, FOSTER, ET AL. LETTERHEAD] June 24, 1999 Jupiter Tequesta National Bank Tequesta, Florida � Moyle, Flanigan, Katz, FitzGerald & Sheehan, P.A. West Palm Beach, Florida RE: Village of Tequesta, Florida, Improvement Revenue Refunding Hond, Series 1994 Ladies and Gentlemen: We are Village attorneys to the Village of Tequesta, Florida (the "Village") and as such we have participated in various proceedings in connection with the issuance by the Village of its above-referenced bond, dated June .J�..� 1994 (the "Bond"). All terms not otherwise defined herein shall have the meanings ascribed thereto in Resolution No. 16-93/94 adopted by the Village June 23, 1994 (the "Resolution"). we are of the opinion that: � (A) The Village is a municipality of the State o£ Flori,da, duly organized and validly eaisting under the Constitution and laws of the State of Florida; (B) The Village has full power and authority to enact Ordinances No. 14 155 331 385 and 463, and Article II of Cha ter 11 of the Villa e Code of Ordinances co ec ive y, e •Ordinances"), to adopt the Resolution, to issue e on , an o eaecute e Escrow Deposit Agreement, dated June 24, 1994, between the Village and The Bank of New York Trust Company of Florida, N.A. (the "Hank") (the "Agreement"�, and to perform all obligations of the Village thereunder; � 7166M � e Jupiter Tequesta National Bank Moyle, Flanigan, Katz, �itzGerald & Sheehan, P.A. June 24, 1994 � Page 2 (C) The Resolution and the Ordinances�were lawfully adopted and enacted, respectively, by the Village and remain in full force and effect; � (D) The Pledged Revenues are not subject to any pledge, lien or encumbrance except pursuant to the Resolution; and (F) The Bond and, assuming the Agreement is a valid and binding obligation of the Hank, the Agreement, are valid and binding obligations of the Village, enforceable aqainst the Village in accordance with their terms. No opinion is eapressed herein as to the eaclusion from gross income for Federal income taa purposes of the interest on the Bond. 7166M � A June 24, 1994 Village of Tequesta, Florida Jupiter Tequesta National Bank RE�: �1,365,000, VILLAGE OF TEQUESTA, FLORIDA IMPROV'MENT REVENUE REFUNDING BOND, SERIES 1994 Ladies and Gentlemen: We have acted as bond counsel in connection with the issuance and sale by Village of Tequesta, Florida (the "Issuer") •of its �1,36�000 aggregate principal amount Improvement Revenue Refunding Bond, Series 1994 (the "Bond"). The Bond is issued pursuant to the Constitution and laws of the State- of Florida, particularly Chapter 166, Florida Statutes and Article VIII, Section 2 of the Florida Constitution, and a Resolution adopted by the Issuer June 2� 1994 (the "Resolution"). All terms used herein in capitalized form and not otherwise defined herein shall have the meanings ascribed thereto in the Resolution. In rendering the opinions set forth herein, we have eaamined a certified copy of the Resolution and are relying on the representations, covenants and agreements of the Issuer contained :therein, including, without limitation, the covenant of the Issuer contained in the Resolution to comply with the applicable requirements contained in Section 103 and Part IV of Subchapter B of Chapter 1 of the Internal Revenue Code of 1986, as amended, and all temporary, proposed or permanent implementing regulations promulqated thereunder or applicable thereto (the "Code") that� must be satisfied subsequent to the issuance o� the Bond to the eatent necessary to preserve e egclusion of interest on t e Bond from gross income for federal income taa purposes. We have 7139M f � village of Tequesta, Florida Jupiter Tequesta National Bank June 24, 1994 Page 2 assumed application of all funds deposited with The Bank of New York Trust Company of Florida, N.A., as escrow agent pursuant to the Escrow Deposit Agreement in accordance therewith. As to questions of fact material to our opinion we have relied upon representations of the Issuer contained in the Resolution and upon other certifications, agreements, documents, and opinions of public officials and other officers and representatives of the vazious parties participating in this transaction, furnished to us, without undertaking to verify the same by independent investigation. We have assumed the genuineness of all signatures on all documents and instruments, the authenticity of documents submitted as originals and the conformity to originals of documents submitted as copies. We have not been engaged to or undertaken to review the accuracy, completeness or sufficiency of any disclosure materials relating to the Bond, and we eapress no opinion relating thereto herein. This opinion shall not be deemed or treated as an offering circular, prospectus or official statement, and is not intended in any way to be a disclosure document used in connection with the sale or delivery of the Bond. We have not been engaged to and therefore eapress no opinion as to the compliance by the Issuer with any federal or state statute, regulation or ruling with respect to the sale or distribution of the Bond. The opinions set forth below are eapressly limited to, and we opine only with respect to, the laws of the State of Florida and the federal income taa laws of the United States of America. Based upon and subject to the foregoing, we are of the opinion as of the date hereof and under eaisting law, as follows: l. The Resolution, including the lien on and pledge of the : Franchise Fees and Occupational License Fees�therein, constitutes a valid and binding obligation of the Issuer, enforceable in accordance with its terms. 2. The Bond has been duly authorized, eaecuted and delivered by the Issuer and is a valid and binding special obligation of the Issuer, payable solely from the sourc�s provided therefor in the Resolution. 3. The interest on the Bond is acluded from gross income �/for federal income taa purposes and is not an item of taa preference described in Section 57 of the Code for purposes of the federal alternative minimum taa imposed on individuals and corporations. It is to be noted that with respect to certain � 7139M � � Village of Tequesta, Florida Jupiter Tequesta National Bank June 24, 1999 Page 3 corporations such interest may be required to be taken into account in determining adjusted current earnings for purposes of calculating the alternative minimum taaable income of such corporations. The opinions expressed in the first sentence of this paragraph are conditioned upon continuing, compliance by �the Issuer with various covenants contained in the Resolution, including, without limitation, its covenant to comply with applicable requirements of the Code necessazy in order to preserve the eaclusion of interest on the Bond from gross income for federal income tax purposes. Failure by the Issuer to comply with such requirements could cause the interest on the Bond to be includable in gross income for federal income taa purposes retroactive to the date of issuance of the Bond. Other provisions of the Code may give rise to collateral federal income tax consequences (which may be adverse) to particular owners. This opinion is limited to matters eapressly addressed above and no opinion is eapressed herein regarding other federal tax consequences that may arise due to ownership of the Bond. 4. The Bond is eaempt from all present intangible personal property taaes imposed by the State of Florida. 5. The Bond is a"qualified taa-eaempt obligation" as defined in Section 265(b)(3)(B)(i) of the Code. Our opinions e=pressed herein are predicated upon present laws and interpretations thereof. We assume no affirmative obligation with respect to any change of circumstances or law (including laws that may result from legislation pending before Congress) that may adversely affect the taa-eaempt status of interest on the Bond after the date hereof. It� is to be understood that the rights of owners of the Bond and the enforceability of the Bond and the Resolution may be •.subject to the provisions of the bankruptcy laws of the United States of America and to other applicable bankruptcy, insolvency, reorganization, moratorium or similar laws relating to or affecting creditors• rights, heretofore or hereinafter enacted, to the eatent constitutionally applicable, and that their enforcement may also be subject to equitable principles that may affect remedies or other equitable relief, or to the eaercise of judicial discretion in appropriate cases. � Very truly yours, 7139M