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HomeMy WebLinkAboutRESOLUTIONS - 01012002 - 2002-388 RESOLUTION NO.2wz43a& A RESOLUTION OF THE BOARD OF SUPERVISORS OF THE COUNTY OF CONTRA COSTA AUTHORIZING THE ISSUANCE AND SALE OF JOHN SWETT UNIFIED SCHOOL DISTRICT, GENERAL OBLIGATION BONDS,ELECTION OF 2002, SERIES A IN THE AGGREGATE PRINCIPAL AMOUNT OF NOT TO EXCEED$10,000,000 TABLE OF CONTENTS ARTICLE I DEFINITIONS;AUTHORITY Section1.01. Definitions...................................................................................... Section 1.02. Authority for this Resolution................................ ARTICLE II THE BONDS Section 2.01. Authorization..................... 6 ................................................... Section 2.02. Terms of Bonds............................. 6 Section 2.03. Redemption............................................................................................ Section 2.04. Book-Entry System.......". ystem...........................................+.............................................7 Section 2.05. Form of Bonds................... Section 2.06. Execution of Bonds....................`.............,.................................,..........,....,...10 Section 2.07. Transfer of Bonds....................... .................................................................. 11 Section 2.08. Exchange of Bonds........................................................................................11 Section 2.09. Bond Register...................... ......................................... 11 Section 2.10. Temporary Bonds..... Section 2.11. Bonds Mutilated,Lost, Destroyed or Stolen................................................... 12 ARTICLE III ISSUE OF BONDS; APPLICATION OF BOND PROCEEDS; SECURITY FOR THE BONDS;INVESTMENT Section 3.01. Issuance and Delivery of Bonds..................... ...........13 ..................................... tion 3.02. Application of Proceeds of Sale of Bonds;Building Fund................................ 13 Section 3.03. Security for the Bonds............ .... 13 Section 3.04. Investments........................ ...... 13 ARTICLE IV SALE OF THE BONDS; DEBT SERVICE FUND Section 4.01. Sale of the Bonds......................................................................................... 14 Section 4.02. Debt Service Fund................... . .... ........................................................14 Section 4.03. Disbursements From Series A Debt Section 4.04. C7ffi Service Fund............................................ 14 tial Action. ARTICLE V OTHER COVENANTS OF THE BOARD Section 5.01. Punctual Payment................................ Section 5.02. Extension of Time for Payment............ ......15 ARTICLE VI THE PAYING AGENT Section 6.01. Appointment of Paying Agent............ ........................................................... 16 Section 6.02. Paying Agent May Hold Bonds......................................,....,.........,...............16 Section 6A3. Liability of Agents.........................,...,......................................................... 16 Section 6.04. Notice to Agents............. ......................................................... .. 17 Section 6.05. Compensation, Indemnification. ................` i ARTICLE VII EVENTS OF DEFAULT AND REMEDIES OF BONDOWNERS Section 7.01. Events ofDefault ........................................................................................ 18 Section 7.02. Application mfFunds Upon Default............................................................... lQ Section 7.03. Remedies of Bondmnonera...............................................................................l9 Section7.04. Non-Waiver................................................................................................19 Section 7.05. Remedies Not Exclusive...............................................................................19 ARTICLE VIII SUPPLEMENTAL RESOLUTIONS Section 8.01. Supplemental Resolutions Effective Without Consent mfthe Owners..............2O Section 8.D2' Supplemental Resolutions Effective With Consent to the Owners. ................20 ARTTCLE D( MISCELLANEOUS Section 9.01. Benefits ofResolution Limited boParties'.....................................................21 Section9.02. Defeasance..................................................................................................2I Section 9.03. Execution of Documents and Proof of Ownership by Bondowners......................22 Section 9.04. Waiver of Personal Liability ----------_--.--.--_--_--.--.-23 Section 9.05. Destruction of Canceled Bonds......................................................................23 Section 9.06. Partial Invalidity ooy-.-.--.---------_.~--.-----_.-..--.------.-23 Section 9.07. Effective Date of Resolution.........................................................................23 ' �� RESOLUTION NO, 2002 385 A RESOLUTION OF THE BOARD OF SUPERVISORS OF THE COUNTY OF CONTRA COSTA AUTHORIZING THE ISSUANCE AND SALE OF JOHN SWETT UNIFIED SCHOOL DISTRICT, GENERAL OBLIGATION BONDS, ELECTION OF 2002, SERIES A RESOLVED, by the Board of Supervisors of Contra Costa County (the "Board"), as follows: WHEREAS, an election was duly and regularly held in the John Swett Unified School District (the "District") on March 5,2002 for the purpose of submitting to the qualified electors of the District the question whether general obligation bonds should be issued in the aggregate principal amount of $10,000,000 (the "Bonds"), at which election fifty-five percent or more of the votes cast were in favor of the issuance of the Bonds;and WHEREAS, Section 15140 of the Education Code of the State of California (the "Education Code")requires that general obligation bonds of a school district shall be offered for sale by the board of supervisors of the county, the county superintendent of which has jurisdiction over such school district, as soon as possible following receipt of a resolution adopted by the governing board of such district;and WHEREAS, at this time the Board has received the resolution of the Board of Trustees of the District requesting the issuance of the Bonds (the "Series A Bonds") in the aggregate principal amount of not to exceed Ten Million Dollars ($10,000,000); and WHEREAS, in its resolution, the District found and informed this Board that all acts, conditions and things required by law to be done or performed have been done and performed in strict conformity with the laws authorizing the issuance of general obligation bonds of the District, and the indebtedness of the District, including the proposed issue of the Series A Bonds, is within all limits prescribed by law;and WHEREAS, the Board intends to issue and sell general obligation bonds, in a principal amount not to exceed $10,000,000, pursuant to this resolution and in conformity with the Act (as hereafter defined);and NOW, THEREFORE, BE IT RESOLVED BY THE BOARD OF SUPERVISORS OF THE COUNTY OF CONTRA COSTA AS FOLLOWS: ARTICLE I DEFINITIONS;AUTHORITY Section 1.01 Definitions. The terms defined in this Section 1.01, as used and capitalized herein, shall, for all purposes of this Resolution, have the meanings ascribed to them below, unless the context clearly requires some other meaning. "Act" means Chapter 1.5 of Part 10 of Division 1 of Title 1 of the California Education Code, as in effect on the date of adoption hereof,and as amended hereafter. "Accreted Interest" means, with respect to any Capital Appreciation Bond, Accreted Value as of the date of its calculation, less the original principal amount of such Capital Appreciation Bond. "Accreted Value" meads (a) on any Compounding Date, the amount set forth opposite such Compounding Date on the Table of Accreted Values which is included in Exhibit B hereto as part of the form of Capital Appreciation Bond, (b) on any date between the Closing Date and the first Compounding Date, the amount determined on the basis of straight-line interpolation between the Closing Date and such Compounding Date (based on a 360-day year and twelve 30-day months), and (c) on any date which is between two Compounding Dates (based on a 360-day year and twelve 30-day months), the amount determined on the basis of straight-line interpolation between such date and such Compounding Date. "Articles,", "Sections" and other subdivisions are to the corresponding Articles, Sections or subdivisions of this Resolution, and the words "herein", ""hereof", "hereunder" and other words of similar import refer to this Resolution as a whole and not to any particular Article, Section or subdivision hereof. "Board" means the Board of Supervisors of Contra Costa County, California. "Bond Counsel" means any attorney or firm of attorneys nationally recognized for expertise in rendering opinions as to the legality and tax exempt status of securities issued by public entities. "Bond Payment Date" means February 1 and August 1 of each year, commencing February 1, 2003 with respect to interest on the Current Interest Bonds (unless otherwise specified in the Purchase Contract) and August 1 of each year, commencing August 1, 2003, with respect to the principal payments on the Current Interest Bonds (unless otherwise specified in the Purchase Contract), and, with respect to the Capital Appreciation Bonds, the stated maturity dates thereof, as applicable. "Bonds" or "'Series A Bonds" means the Current Interest Bonds and the Capital Appreciation Bonds at any time Outstanding pursuant to this Resolution. "Bond Register"has the meaning given to such term in Section 2.09. "Capital Appreciation Bond" means Series A Bonds, the interest component of which is compounded semiannually on each Bond Payment Date to maturity, as shown in the table of Accreted Value for such Series A Bonds in the Purchase Contract and/or the Official Statement for the Series A Bonds. 2 "Capital Appreciation Term Bonds" means those Capital Appreciation Bonds for which mandatory redemption dates have been established in accordance with Section 2.03(ii). "Closing Date" means the date upon which there is an exchange of Series A Bonds for the proceeds representing the purchase price of the Series A Bonds by the Original Purchaser. „Code" means the Internal Revenue Code of 1986 as in effect on the Closing Date or (except as otherwise referenced herein.)as it may be amended to apply to obligations issued on the Closing Date, together with applicable temporary and final regulations promulgated under the Code. "Compounding Date"means,with respect to any Capital Appreciation Bond, August 1, 2002 (unless otherwise specified in the Purchase Contract) and each February 1 and August 1 thereafter,to and including the date of maturity of such Bond. "County"means the County of Contra Costa,California. "County Treasurer"means the Tax Collector-Treasurer of the County. "Current Interest Bonds" means the Series A Bonds the interest on which is payable on each Bond Payment Date specified for each such Series A Bond as designated and maturing in the years and in the amounts set forth in the Purchase Contract. "Current Interest Term Bonds" means those Current Interest Bonds for which mandatory redemption dates have been established pursuant to Section 2.03(ii). "Debt Service" means the scheduled amount of interest and amortization of principal payable on the Series A Bonds during the period of computation, excluding amounts scheduled during such period which relate to principal which has been retired before the beginning of such period. "Denominational Amount" means, with respect to any Capital Appreciation Bond, the initial principal amount thereof. "Depository"means (a) initially, DTC, and (b) any other Securities Depository acting as Depository pursuant to Section 2.04. system."Depository System Participant" means any participant in the Depository's book-entry "DTC"means The Depository Trust Company,New York,New York,and its successors and assigns. "District Representative" means the Superintendent of the District, or any other person authorized by resolution of the Board of Trustees of the District to act on behalf of the District with respect to this Resolution and the Series A Bonds. "Federal Securities"means direct and general obligations of the United States of America, or obligations that are unconditionally guaranteed as to principal and interest by the United States of America,including(in the case of direct and general obligations of the United States of America)evidences of direct ownership of proportionate interests in future interest or principal payments of such obligations. Investments in such proportionate interest must be limited to circumstances wherein(a)a bank or trust company acts as custodian and holds the underlying United States obligations, (b) the owner of the investment is the real party in interest and has the right to proceed directly and individually against the obligor of the underlying United States 3 obligations; and (c) the underlying United States obligations are held in a special account, segregated from the custodian's general assets,and are not available to satisfy any claim of the custodian, any person claiming through the custodian, or any person to whom the custodian maybe obligated;provided that such obligations are rated or assessed "AAA" by Standard & Poor's if the Bonds are then rated by Standard&Poor's and "Aaa"by Moody's if the Bonds are then rated by Moody's. "Information Services" means Financial Information, Inc.`s Financial Daily Called Bond Service;Interactive Data Corporation's Bond Service; Kenny Information Service's Called Bond Service;Moody's Municipal and Government;or Standard&Poor's Called Bond Record. „Issuance Expenses"means all items of expense directly or indirectly reimbursable to the District relating to the issuance, execution and delivery of the Bonds including,but not limited to, filing and recording costs, settlement costs, printing costs, reproduction and binding costs, legal fees and charges,fees and expenses of the Paying Agent, financial and other professional consultant fees, costs of obtaining credit ratings, municipal bond insurance premiums, fees for execution,transportation and safekeeping of the Bonds and charges and fees in connection with the foregoing. "Maturity Value"means the Accreted Value of a Capital Appreciation Bond on the date such Bond matures. "Original Purchaser"means Stone & Youngberg LLC, as the first purchaser of the Series A Bonds pursuant to the Purchase Contract. "Outstanding",when used as of any particular time with reference to Bonds, means all Bonds except: (a) Bonds theretofore canceled by the Paying Agent or surrendered to the Paying Agent for cancellation; (b) Bonds paid or deemed to have been paid within the meaning of Section 9.02 hereof; and (e) Bonds in lieu of or in substitution for which other Bonds shall have been authorized, executed,issued and delivered by the District pursuant to the Resolution. "Owner" or "Bondowner" mean any person who shall be the registered owner of any Outstanding Bond. "Paying Agent" means BNY Western Toast Company, the Paying Agent appointed by the District and acting as paying agent, registrar and authenticating agent for,the Bonds, its successors and assigns, and any other corporation or association which may at any time be substituted in its place,as provided in Section 6.01 hereof. "Principal Office"means the office of the Paying Agent in San Francisco,California. "Purchase Contract" means the Purchase Contract, dated the date of sale of the Bonds, by and among the Original Purchaser, the District and the Board of Supervisors, pursuant to which the Original Purchaser agrees to purchase all of the Bonds, subject to the conditions contained in Section 4.01 hereof. "Regulations"means temporary and permanent regulations promulgated under the Code. 4 "Resolution"means this Resolution. "Securities Depositories" means The Depository Trust Company, 711 Stewart Avenue, Garden City, New York 11530, Facsimile transmission: (516) 227-4039, (516) 227-5190 with Cede&Co.as its nominee. "Supplemental Resolution" means any resolution supplemental to or amendatory of this Resolution,adopted by the Board in accordance with Article VIII hereof. "Written Request of the District" means an instrument in writing signed by the District Representative or by any other officer of the District duly authorized by the District and listed on a Written Request of the District for that purpose. Section 1.02. Authority for this Resolution. This Resolution is entered into pursuant to the provisions of the Act. ARTICLE 11 THE BONDS Section 2.01. Authorization. The Bonds, comprised of Current Interest Bonds and Capital Appreciation Bonds, are hereby authorized to be issued by the Board of Supervisors in the name of the District under and subject to the terms of the Act and this Resolution; provided, that the aggregate principal amount of the Current Interest Bonds and the Capital Appreciation Bonds shall not exceed $10,000,000. This Resolution constitutes a continuing agreement with the Owners of all of the Bonds issued or to be issued hereunder and then Outstanding to secure the full and final payment of principal of, interest on, and Accreted Value of all Bonds which may from time to time be issued hereunder, subject to the covenants, agreements, provisions and conditions herein contained. The Bonds shall be designated the "Jahn Swett Unified School District (Contra Costa County, California), General Obligation Bonds, Election of 2002, Series A". Section 2.02. Terms of Bonds. (a) Form; Numbering. The Bonds shall be issued as fully registered Bonds, without coupons. Bonds shall be lettered and numbered as the Paying Agent shall prescribe. The Current Interest Bonds shall be issued in the denomination of $5,000 each or any integral multiple thereof, but in an amount not to exceed the aggregate principal amount of Current Interest Bonds maturing in the year of maturity of the Current Interest Bond for which the denomination is specified. The Capital Appreciation Bonds shall be issued in the Maturity Value of$5,000 each or any integral multiple thereof except for one Capital Appreciation Bond which may be issued in a Maturity Value less than $5,000, but in an amount not to exceed the aggregate Maturity Value of Capital Appreciation Bonds maturing in the year of maturity for the Capital Appreciation Bonds for which the denomination is specified. (b) Date of Bonds. The Current Interest Bonds shall be dated the Closing Date, or such other date as shall be specified in the Purchase Contract. The Capital Appreciation Bonds shall be dated the Closing Date. (c) CUSIP Identification Numbers. "CUSIP" identification numbers shall be imprinted on the Bonds, but such numbers shall not constitute a part of the contract evidenced by the Bonds and any error or omission with respect thereto shall not constitute cause for refusal of any purchaser to accept delivery of and pay for the Bonds. In addition, failure on the part of the District to use such CUSIP numbers in any notice to Owners of the Bonds shall not constitute an event of default or any violation of the District's contract with such Owners and shall not impair the effectiveness of any such notice. (d) Maturities.; Intm t. The Series A Bonds shall mature on August 1 or July 1 (or on such other dates as specified in the Purchase Contract)in the years and amounts set forth in the Official Statement for the Series A Bonds. The Maturity Value of any Capital Appreciation Bond shall be payable only upon the maturity of such Capital Appreciation Bond. The total amount of principal of and interest payable on the Capital Appreciation Bonds as of any date other than its maturity date shall be the Accreted Value thereof determined as of such date. The Current Interest Bonds shall bear interest at such rate as shall be determined upon the sale thereof in accordance with Section 4.01 hereof, payable semi-annually on each Bond 6 Payment Dates, commencing February 1, 2003 (unless otherwise specified in the Purchase Contract). The Capital Appreciation Bonds shall bear interest at such rate or rates as shall be determined upon the sale thereof in accordance with Section 4.01 hereof. Each Current Interest Bond shall bear interest from the Bond Payment Date next preceding the date of registration and authentication thereof unless (i) it is registered and authenticated as of an Bond Payment Date,in which event it shall bear interest from such date, or (ii) it is registered and authenticated prior to a Bond Payment Date and after the close of business on the fifteenth(15th)day of the month preceding such Bond Payment Date, in which event it shall bear interest from such Bond Payment Date, or (iii) it is registered and authenticated prior to January 15, 2003, in which event it shall bear interest from the date described in paragraph (b) of this Section 2.02; provided, however, that if at the time of authentication of a Bond, interest is in default thereon, such Bond shall bear interest from the Bond Payment Date to which interest has previously been paid or made available for payment thereon. Interest on the Bonds shall be calculated on the basis of a 360-day year comprised of twelve 30-day months. (e) Ea)mnt. Interest on the Current Interest Bonds including the final interest payment upon maturity is payable by check of the Paying Agent mailed on the Bond Payment Date via first-class mail to the Owner thereof at such Owner's address as it appears on the bond register maintained by the Paying Agent at the close of business on the fifteenth(15th) day of the month preceding the Bond Payment Date (the "Record Date"), or at such other address as the Owner may have filed with the Paying Agent for that purpose, or upon written request filed with the Paying Agent as of the Record Date by an Owner of at least $1,000,000 in aggregate principal amount of Current Interest Bonds,by wire transfer. The interest portion of the Accreted Value of any Capital Appreciation Bond which is payable on the date of maturity shall represent interest accrued and corning due on such date. The Accreted Value of any Capital Appreciation Bond at maturity shall be payable, except as provided below, by check mailed by first-class mail, in lawful money of the United State of America upon presentation and surrender of such Bond at the Office of the Paying Agent. Section 2.03. Redemption. (i) Optional Redemption. The Bonds may be redeemed before maturity, at the option of the bistrict, on the dates specified in the final Official Statement for the Bonds, as a whole or in part, by lot within a maturity. The Current Interest Bonds called prior to maturity will be redeemed at the redemption prices specified in the final Official Statement for the Bonds. The Capital Appreciation Bonds which are not Capital Appreciation Term Bunds are not subject to optional redemption prior to their stated maturity date,unless so specified in the final Official Statement for the Bonds. (ii) Mandatory Redemption. The Capital Appreciation Term Bonds maturing on the dates specified in the final Official Statement for the Bonds are subject to mandatory redemption from monies in the Series A Debt Service Fund established in Section 4.02 hereof prior to their stated maturity date, at the Accreted Value thereof, without premium, on the dates specified in the final Official Statement for the Bonds. The Current Interest Term Bonds are subject to redemption as provided in the final Official Statement for the Bonds. (iii) Selection of Bonds for Redemption. Whenever provision is made in this Resolution for the redemption of Bonds and less than all Outstanding Bonds are to be redeemed, the Paying Agent, upon written instruction from the District received at least 50 days prior to the 7 specified redemption date (unless a shorter notice is consented to by the Paying Agent), shall select Bonds for redemption. Within a maturity, the Paying Agent shall select Bonds for redemption by lot. Redemption by lot shall be in such a manner as the Paying Agent shall determine;provided hg_wg_y_er, that the portion of any Current Interest Bond to be redeemed in part shall be in the Principal Amount of$5,000 or any integral multiple thereof and the portion of any Capital Appreciation Bond to be redeemed in part shall be in integral multiples of the Accreted Value per$5,000 Maturity Value of such Capital Appreciation Bond. (iv) Notice of Redemption. When redemption is authorized or required pursuant to Section 2.03(i) hereof, the Paying Agent, upon written instruction from the District received at least 50 days prior to the specified redemption date (unless a shorter notice is consented to by the Paying Agent), shall give notice (a "Redemption Notice") of the redemption of the Bonds. Such Redemption Notice shall specify: (a) the Bonds or designated portions thereof (in the case of redemption of the Bonds in part but not in whole) which are to be redeemed, (b) the date of redemption, (c) the place or places where the redemption will be made, including the name and address of the Paying Agent, (d) the redemption price, (e) the CUSIP numbers (if any)assigned to the Bonds to be redeemed, (f) the Bond numbers of the Bonds to be redeemed in whole or in part and, in the case of any Bond to be redeemed in part only, the Principal Amount of such Bond to be redeemed, and (g) the original issue date, interest rate and stated maturity date of each Bond to be redeemed in whole or in part. Such Redemption Notice shall further state that on the specified date there shall become due and payable upon each Bond or portion thereof being redeemed the Redemption Price thereof, together with the interest accrued to the redemption date in the case of the Capital Appreciation Bonds, and that from and after such date,interest with respect thereto shall cease to accrete in value. The Paying Agent shall take the following actions with respect to such Redemption Notice: (a) At least thirty (30) but not more than forty-five (45) days prior to the redemption date, such Redemption Notice shall be given to the respective Owners of Bonds designated for redemption by registered or certified mail, postage prepaid, at their addresses appearing on the Bond Register maintained pursuant to Section 2.09. (b) At Ieast thirty (30) days before the redemption date, such Redemption Notice shall be given b7 (i) registered or certified mail, postage prepaid, (ii) telephonically confirmed acsimile transmission, or (iii) overnight delivery service, to each of the Securities Depositories. (c) At least thirty (30) days before the redemption date, such Redemption Notice shall be given by(i)registered or certified mail,postage prepaid, (or (ii) overnight delivery service,to one of the Information Services. Neither failure to receive or failure to send any notice of redemption nor any defect in any such Redemption Notice so given shall affect the sufficiency of the proceedings for the redemption of the affected Bonds. Each check issued or other transfer of funds made by the Paying Agent for the purpose of redeeming Bonds shall bear or include the CUSIP number identifying,by issue and maturity,the Bonds being redeemed with the proceeds of such check or other transfer. (v) Partial Redemption of Bonds. Upon the surrender of any Bond redeemed in part only,the Paying Agent shall execute and deliver to the Owner thereof a new Bond or Bonds of like tenor and maturity and of authorized denominations equal in Transfer Amounts to the unredeemed portionof the Bond surrendered. Such partial redemption shall be valid upon 8 payment of the amount required to be paid to such Owner, and the County and the District shall be released and discharged thereupon from all liability to the extent of such payment. (vi) Effect of Notice of Redemption. Notice having been given as aforesaid, and the moneys for the redemption(including the interest to the applicable date of redemption) having been set aside in the District's Series A Debt Service Fund created in Section 4.02 hereof, the Bonds to be redeemed shall become due and payable on such date of redemption. If on such redemption date, money for the redemption of all the Bonds to be redeemed as provided in Section 2.03(i) hereof, together with interest to such redemption date, shall be held by the Paying Agent so as to be available therefor shall have been given as aforesaid, then from and after such redemption date, interest with respect to the Bonds to be redeemed shall cease to accrue and become payable. All money held by or on behalf of the Paying Agent for the redemption of Bonds shall be held in trust for the account of the Owners of the Bonds so to be redeemed. All Bonds paid at maturity or redeemed prior to maturity pursuant to the provisions of this Section 2.03 shall be cancelled upon surrender thereof and be delivered to or upon the order of the County and the District. All or any portion of a Bond purchased by the County or the District shall be cancelled by the Paying Agent. (vii) Bonds No Longer Outstanding. When any Bonds (or portions thereof), which have been duly called for redemption prior to maturity under the provisions of this Resolution, or with respect to which irrevocable instructions to call for redemption prior to maturity at the earliest redemption date have been given to the Paying Agent, in form satisfactory to it, and sufficient moneys shall be held by the Paying Agent irrevocably in trust for the payment of the redemption price of such Bonds or portions thereof, and, in the case of Current Interest Bonds, accrued interest with respect thereto to the date fixed for redemption, all as provided in this Resolution,then such Bonds shall no longer be deemed Outstanding and shall be surrendered to the Paying Agent for cancellation. Section 2.04. Book-Entry System. (a) Original Delivery. The Bonds shall be initially delivered in the form of a separate single fully registered Bond (which may be typewritten) for each maturity of the Bonds. Upon initial delivery,the ownership of each such Bond shall be registered on the Bond Register in the name of Cede&Co. (the"Nominee"). Except as provided in subsection(c), the ownership of all of the Outstanding Bonds shall be registered in the name of the Nominee on the Bond Register. With respect to Bonds the ownership of which shall be registered in the name of the Nominee, the District and the Paying Agent shall have no responsibility or obligation to any Depository System Participant or to any person on behalf of which the Depository holds an interest in the Bonds. Without limiting the generality of the immediately preceding sentence, the District and the Paying Agent shall have no responsibility or obligation with respect to (i) the accuracy of the records of the Depository, the Nominee or any Depository System Participant with respect to any ownership interest in the Bonds, (ii) the delivery to any Depository System Participant or any other person, other than an Owner as shown in the Bond Register, of any notice with respect to the Bonds, including any notice of redemption, (iii) the selection by the Depository of the beneficial interests in the Bonds to be redeemed in the event the District elects to redeem the Bonds in part, (iv) the payment to any Depository System Participant or any other person,other than an Owner as shown in the Bond Register, of any amount with respect to principal,premium,if any, or interest on the Bonds or (v) any consent given or other action taken by the Depositary as Owner of the Bonds. The District and the Paying Agent may treat and consider the person in whose namg each Bond is registered as the absolute owner of such 9 Bond for the purpose of payment of principal, premium and interest on such Bond, for the purpose of giving notices of redemption and other matters with respect to such Bond, for the purpose of registering transfers of ownership of such Bond, and for all other purposes whatsoever. The Paying Agent shall pay the principal of and interest and premium, if any, on the Bonds only to the respective Owners or their respective attorneys duly authorized in writing, and all such payments shall be valid and effective to fully satisfy and discharge all obligations with respect to payment of principal of and interest and premium, if any, on the Bonds to the extentof the sum or sums so paid. No person other than an Omer shall receive a Band evidencing the obligation of the District to make payments of principal, interest and premium,if any,pursuant to this Resolution. Upon delivery by the Depository to the Nominee of written notice to the effect that the Depository has determined to substitute a new nominee in its place, and subject to the provisions herein with respect to Record Dates, such new nominee shall become the Nominee hereunder for all purposes;and upon receipt of such a notice the District shall promptly deliver a copy of the same to the Paying Agent. (b) Representation fetter. In order to qualify the Bonds for the Depository's book-entry system, the District and the Paying Agent shall execute and deliver to such Depository a letter representing such matters as shall be necessary to so qualify the Bonds. The execution and delivery of such letter shall not in any way limit the provisions of subsection(a)above or in any other way impose upon the District or the Paying Agent any obligation whatsoever with respect to,persons having interests in the Bonds other than the Owners. The Paying Agent agrees to comply with all provisions in such letter with respect to the giving of notices thereunder by the Paying Agent. In addition to the execution and delivery of such letter,the District may take any other actions, not inconsistent with this Resolution, to qualify the Bonds for the Depository's book-entry program. (c) Transfers Outside Book-Entry S sv tem. In the event that either (i) the Depository determines not to continue to act as Depository for the Bonds, or (ii) the County Treasurer determines to terminate the Depository as such, then the County Treasurer shall thereupon discontinue the book-entry system with such Depository. In such event, the Depository shall cooperate with the District and the Paying Agent in the issuance of replacement Bonds by providing the Paying Agent with a list showing the interests of the Depository System Participants in the Bonds, and by surrendering the Bonds, registered in the name of the Nominee, to the Paying Agent on or before the date such replacement Bonds are to be issued. The Depository,by accepting delivery of the Bonds,agrees to be bound by the provisions of this subsection (c). If, prior to the termination of the Depository acting as such, the County Treasurer fails to identify another Securities Depository to replace the Depository, then the Bonds shall no longer be required to be registered in the Bond Register in the name of the Nominee, but shall be registered in whatever name or names the Owners transferring or exchanging Bonds shall designate, in accordance with the provisions of this Article 2. Prior to its termination,the Depository shall furnish the Paying Agent with the names and addresses of the Participants and respective ownership interests thereof. (d) Payments to the Nominee. Notwithstanding any other provision of this Indenture to the contrary,so long as any Bond is registered in the name of the Nominee, all payments with respect to principal of and interest and premium, if any, on such Bond and all notices with respect to such Bond shall be made and given, respectively, as provided in the letter described in subsection(b)of this Section or as otherwise instructed by the Depository. Section 2.05. Form of Bonds. The Bonds, the form of the Paying Agent's certificate of authentication and 'registration, and the form of assignment to appear thereon, shall be substantially in the 'forms, respectively, with necessary or appropriate variations, omissions and insertions, as permitted or required by this Resolution, as are set forth in Exhibits A (Current Interest Bond) and Exhibit B (Capital Appreciation Bond) attached hereto. 10 Section 2.06. Execution of Bonds. The Bonds shall be executed on behalf of the Board by the facsimile signatures of the County Treasurer and Chair of the Board of Supervisors, and countersigned by manual or facsimile signature by the Clerk of the Board of Supervisors who are in office on the date of adoption of this Resolution or at any time thereafter, and the seal of the Board shall be impressed, imprinted or reproduced by facsimile thereon. If any officer whose signature appears on any Bond ceases to be such officer before delivery of the Bonds to the purchaser, such signature shall nevertheless be as effective as if the officer had remained in office until the delivery of the Bonds to the purchaser.Any Bond may be signed and attested on behalf of the Board by such persons as at the actual date of the execution of such Bond shall be the proper officers of the County although at the nominal date of such Bond any such person shall not have been such officer of the County. Only such Bonds as shall bear thereon a certificate of authentication and registration in the form set forth in Exhibits A and B attached hereto, executed and dated by the Paying Agent,shall be valid or obligatory for any purpose or entitled to the benefits of this Resolution, and such certificate of the Paying Agent shall be conclusive evidence that the Bonds so registered have been duly authenticated, registered and delivered hereunder and are entitled to the benefits of this Resolution. Section 2.07. Transfer of Bonds. Any Bond may, in accordance with its terms, be transferred, upon the books required to be kept pursuant to the provisions of Section 2.09 hereof, by the person in whose name it is registered, in person or by his duly authorized attorney, upon surrender of such Bond for cancellation at the Principal Office at the Paying Agent,accompanied by delivery of a written instrument of transfer in a form approved by the Paying Agent, duly executed. The Paying Agent shall require the payment by the Owner requesting such transfer of any tax or other governmental charge required to be paid with respect to such transfer. Whenever any Bond or Bonds shall be surrendered for transfer,the District shall execute and the Paying Agent shall authenticate and deliver a new Bond or Bonds, for like aggregate principal amount. No transfers of Bonds shall be required to be made (a) fifteen days prior to the date established by the Paymig Agent for selection of Bonds for redemption or (b) with respect to a Bond after such Bond has been selected for redemption. Section 2.08. Exchange of Bonds. Bonds may be exchanged at the Principal Office of the Paying Agent for a like aggregate principal amount of Bonds of authorized denominations and of the same maturity;provided that Current Interest Bonds may only be exchanged for Current Interest Bonds, and Capital Appreciation Bonds may only be exchanged for Capital Appreciation Bonds.The Paying Agent shall require the payment by the Owner requesting such exchange of any tax or other governmental charge required to be paid with respect to such exchange. No exchanges of Bonds shall be required to be made (a) fifteen days prior to the date established by the Pa g Agent for selection of Bonds for redemption or (b) with respect to a Bond after such Bond has been selected for redemption. Section 2.09. 'Bond Remoter. The Paying Agent'shall keep or cause to be kept sufficient books for the registration and transfer of the Bond (the "Bond Register"),which shall at all times be open to inspection by the District upon reasonable notice; and, upon presentation for such purpose, the Paying Agent shall,under such reasonable regulations as it may prescribe, register 11 or transfer or cause to be registered or transferred, on said books, Bonds as herein before provided. Section 2.10. Temporary Bonds. The Bonds may be initially issued in temporary form exchangeable for definitive Bonds when ready for delivery. The temporary Bonds may be printed,lithographed or typewritten, shall be of such denominations as may be determined by the District,and may contain such reference to any of the provisions of this Resolution as may be appropriate. Every temporary Bond shall be executed by the District upon the same conditions and in substantially the same manner as the definitive Bonds. If the District issues temporary Bonds it will execute and furnish definitive Bonds without delay, and thereupon the temporary Bonds may be surrendered, for cancellation, in exchange therefor at the Principal Office of the Paying Agent and the Paying Agent shall deliver in exchange for such temporary Bonds an equal aggregate principal amount of definitive Bonds of authorized denominations. Until so exchanged, the temporary Bonds shall be entitled to the same benefits pursuant to this Resolution as definitive Bonds executed and delivered hereunder. Section 2.11. Bonds Mutilated. Lost. Destroved or Stolen. If any Bond shall become mutilated the District,at the expense of the Owner of said Bond, shall execute, and the Paying Agent shall thereupon authenticate and deliver, a new Bond of like maturity and principal amount in exchange and substitution for the Bond so mutilated, but only upon surrender to the Paying Agent of the Bond so mutilated. Every mutilated Bond so surrendered to the Paying Agent shall be canceled by it and delivered to, or upon the order of, the District. If any Bond shall be lost, destroyed or stolen, evidence of such loss, destruction or theft may be submitted to the District and,if such evidence be satisfactory to the District and indemnity satisfactory to it shall be given, the District,at the expense of the Owner, shall execute, and the Paying Agent shall thereupon authenticate and deliver, a new Bond of like maturity and principal amount in lieu of and in substitution for the Bond so lost, destroyed or stolen. The District may require payment of a sum not exceeding the actual cost of preparing each new Bond issued under this Section and of the expenses which may be incurred by the District and the Paying Agent in the premises. Any Bond issued under the provisions of this Section 2.11 in lieu of any Bond alleged to be lost, destroyed or stolen shall constitute an original additional contractual obligation on the part of the District whether or not the Bond so alleged to be lost, destroyed or stolen be at any time enforceable by anyone, and shall be equally and proportionately entitled to the benefits of this Resolution with all other Bonds issued pursuant to this Resolution. 12 ARTICLE III ISSUE OF BONDS;APPLICATION OF BOND PROCEEDS; SECURITY FOR THE BONDS;IN"VESTIVIENT Section 3.01. Issuance and Delivery of Bonds. At any time after the execution of this Resolution the Board of Supervisors may issue and deliver Current Interest Bonds and Capital Appreciation Bonds which in aggregate principal amount shall not exceed$10,000,000. The District Representative shall be, and is hereby, directed to cause the Bonds to be printed,signed and sealed,and to be delivered to the successful bidder for the Bonds on receipt of the purchase price therefor and upon performance of the conditions contained in the Purchase Contract relating to the Bonds. The Paying Agent is hereby authorized to deliver the Bonds to the Original Purchaser, upon receipt of a Written Request of the District. Section 3.02. Application of Proceeds of Sale of Bonds; Building Fund. The proceeds of the Bonds shall be deposited as follows: (a) There shall be deposited with the County Treasurer in the Series A Debt Service Fund,an amount equal to the accrued interest and any premium received by the District on the Current Interest Bonds paid by the Original Purchaser on the Closing Date;and (b) The proceeds from the sale of the Bonds not consisting of accrued interest or premium shall be paid to the County Treasurer to the credit of the fund hereby created and established and to be known as the "Election of 2002, Series A John Swett Unified School District Building Fund" (the"Series A Building Fund") of the District, which shall be accounted for separate and distinct from all other District and County funds, and those proceeds shall be used solely for the purpose for which the Bonds are being issued. The interest earned on the monies deposited to said Building Fund shall be deposited in said Building Fund and used for the purposes for which the Series A Bonds have been authorized. Any excess proceeds of the Series A Bonds not needed for the authorized purposes set forth herein for which the Bonds are being issued shall be transferred to the Series A Debt Service Fund andapplied to the payment of principal and interest on the Series A Bonds. If, after payment in full of the Series A Bonds there remain excess proceeds,any such excess amounts shall be transferred to the general fund of the District. Section 3.03. Security for the Bonds. The Bonds are general obligations of the District, and the Board of Supervisors has the power, is obligated and hereby covenants to levy ad valorem taxes uponall property within the District subject to taxation, without limitation of rate or amount, for the payment of the Bonds and the interest thereon, in accordance with Sections 15250 and Section 15252 of the Act. Section 3.04. Investments. All funds held by the County Treasurer hereunder shall be invested by the County 'Treasurer in the County Investment Pool, the Local Agency Investment Fund, any investment authorized pursuant to Section 53601 of the Government Code, or in investment agreements,including guaranteed investment contracts,or other investment products (provided that such agreements comply with the requirements of Section 148 of the Internal Revenue Code of 1986, as amended (the "Code")). 13 ARTICLE IV SALE OF THE BONDS;DEBT SERVICE FUND Section 4.01. Sale of the Bonds. The Bonds shall be sold to the Original Purchaser pursuant to the terms of a Purchase Contract, between the Original Purchaser, the Board of Supervisors and the District, and dated the date of sale of the Bonds (the "Purchase Contract"),so long as the net interest cost on the Bonds does not exceed 1.7°la, and so long as the Original Purchaser's discount on the Bonds (without regard to an original issue discount, if any) does not exceed 6.5%. The County Treasurer is hereby authorized and directed to execute the Purchase Contract,with such changes therein,deletions therefrom and modifications thereto as the County Treasurer, or designated deputy thereof, may approve, such approval to be conclusively evidenced by his or her execution and delivery thereof. Section 4:02. Debt Service Fund. The County Treasurer shall create and maintain, while the Bonds are outstanding, an interest and sinking fund for the Bonds (the "Series A Debt Service Fund"), which shall be maintained by the County Treasurer as a separate account, distinct from all other funds of the District, into which shall be paid on receipt thereof, (i) the portion of the Bond proceeds designated in Section 3.02(a) of this Resolution, and (ii) the proceeds of any taxes levied pursuant to Section 3.03. The Series A Debt Service Fund shall be administered and disbursements made in the manner set forth in Section 4.03 hereof. Section 4.03. Disbursements FromSeries A Debt Service Fund. The moneys in the Series A Debt Service Fund, to the extent necessary to pay the principal of, interest on, and Accreted Value of the Bonds as the same become due and payable, shall be transferred by the County Treasurer to the Paying Agent in immediately available funds at least one (1)business day prior to each Bond Payment Date,which,in turn,shall pay such moneys to the Owners of the Series A Bonds in accordance with Section 2.02(e). Interest earnings on funds in the Series A Debt Service Fund shall remain therein.Any moneys remaining in the Series A Debt Service Fund after the Bonds and the interest thereon have been paid, or provision for such payment has been made,shall be transferred to the general fund of the District. Section 4.04.Official Action. All actions heretofore taken by the officers and agents of the County with respect to the sale and issuance of the Bonds are hereby approved, and the County Treasurer, and all other officers of the County are hereby authorized and directed for and in the name and on behalf of the Board, to do any and all things and take any and all actions relating to the execution and delivery of any and all certificates, requisitions, agreements and other documents,which they,or any of them,may deem necessary or advisable in order to consummate the lawful issuance and delivery of the Bonds in accordance with this resolution. 14 ARTICLE V OTHER COVENANTS OF THE BOARD Section 5.01. Punctual Payment. The Board willlevy ad valorem taxes, as provided in Section 3.03,so as to enable the District to punctually pay,or cause to be paid, the principal of, interest on,and Accreted Value of the Bonds, in strict conformity with the terms of the Bonds and of this Resolution, and it will faithfully observe and perform all of the conditions, covenants and requirements of this Resolution and of the Bonds. Nothing herein contained shall prevent the District from making advances of its own moneys,howsoever derived,to any of the uses or purposes permitted by law. Section 5.02. Extension of Time for Payment. In order to prevent any accumulation of claims for interest after maturity, the Board will not, directly or indirectly, extend or consent to the extension of the time for the payment of any claim for interest on any of the Bonds and will not,directly or indirectly, approve any such arrangement by purchasing or funding said claims for interest or in any other manner. In case any such claim for interest shall be extended or funded,whether or not with the consent of the District, such claim for interest so extended or funded shall not be entitled, in case of default hereunder, to the benefits of this Resolution, except subject to the prior payment in full of the principal of all of the Bonds then Outstanding and of all claims for interest which shall not have so extended or funded. 15 ARTICLE VI THE PAYING AGENT Section 6.01. Appointmen# of Paving Agent. BNY Western Trust Company is hereby appointed Paying Agent for the Bonds. The Paying Agent undertakes to perform such duties, and only such duties, as are specifically set forth in this Resolution, and, even during the continuance of an Event of Default, no implied covenants or obligations shall be read into this Resolution against the Paying Agent. The Paying Agent shall signify its acceptance of the duties and obligations imposed upon it by this Resolution by executing and delivering to the District a certificate to that effect. The Paying Agent may at any time resign by giving written notice to the County Treasurer(but only if the County Treasurer is not then acting as Paying Agent), the District and the Bondowners of such resignation. Upon receiving notice of such resignation,the District shall promptly appoint a successor Paying Agent by an instrument in writing. Any resignation or removal of the Paying Agent and appointment of a successor Paying Agent shall become effective upon acceptance of appointment by the successor Paying Agent. Any such successor Paying Agent shall be a bank or trust company doing business in the State of California, having a combined capital(exclusive of borrowed capital) and surplus of at least fifty million dollars ($50,000,000), and subject to supervision or examination by federal or state authority. If such bank or trust company publishes a report of condition at least annually,pursuant to law or to the requirements of any supervising or examining authority above referred to, then for the purposes of this Section 6.01 the combined capital and surplus of such bank or trust company shall be deemed to be its combined capital and surplus as set forth in its most recent report of condition so published. Section 6.02. Payer Agent i1d y Hold Bonds. The Paying Agent may become the owner of any of the Bonds in its own or any other capacity with the same rights it would have if it were not Paying Agent. Section 6.03. Lia]2ilitv of Agents. The recitals of facts, covenants and agreements herein and in the Bonds contained shall be taken as statements, covenants and agreements of the District, and the Paying Agent assumes no responsibility for the correctness of the same, nor makes any representations as to the validity or sufficiency of this Resolution or of the Bonds, nor shall incur any responsibility in respect thereof, other than as set forth in this Resolution. The Paying Agent shall not be liable in connection with the performance of its duties hereunder, except for its own negligence or willful default. In the absence of bad faith,the Paying Agent may conclusively rely,as to the truth of the statements and the correctness of the opinions expressed therein, upon certificates or opinions furnished to the Paying Agent and conforming to the requirements of this Resolution;but in the case of any such certificates or opinions by which any provision hereof are specifically required to be furnished to the Paying Agent, the Paying Agent shall be under a duty to examine the same to determine whether or not they conform to the requirements of this Resolution. The Paying Agent shall not be liable for any error of judgment made in good faith by a responsible officer unless it shall be proved that the Paying Agent was negligent in ascertaining the pertinent facts. No provision of this Resolution shall require the Paying Agent to expend or risk its own funds or otherwise incur any financial liability in the performance of any of its duties hereunder, or in the exercise of any of its rights or powers, if it shall have reasonable grounds for believing 16 that repayment of such funds or adequate indemnity against such risk or liability is not reasonably assured to it. The Paying Agent may execute any of the powers hereunder or perform any duties hereunder either directly or by or through agents or attorneys and the Paying Agent shall not be responsible for any misconduct or negligence on the part of any agent or attorney appointed with due care by it hereunder. Section 6.04. Nice to Agents. The Paying Agent may rely and shall be protected in acting or refraining',from acting upon any notice, resolution, request, consent, order, certificate, report,warrant,bond or other paper or document believed by it to be genuine and to have been signed or presented by the proper party or proper parties. The Paying Agent may consult with counsel,who may be of counsel to the District, with regard to legal questions, and the opinion of such counsel shall be full and complete authorization and protection in respect of any action taken or suffered by it hereunder in good faith and in accordance therewith. Whenever in the administration of its duties under this Resolution the Paying Agent shall deem it necessary or desirable that a matter be proved or established prior to taking or suffering any action hereunder,such matter(unless other evidence in respect thereof be herein specifically prescribed)may,in the absence of bad faith on the part of the Paying Agent, be deemed to be conclusively proved and established by a certificate of the District, and such certificate shall be frill warrant to the Paying Agent for any action taken or suffered under the provisions of this Resolution upon the faith thereof,but in its discretion the Paying Agent may, in lieu thereof, accept other evidence of such matter or may require such additional evidence as to it may seem reasonable. Section 6.05.Compensation,Indemnification. The District shall pay to the Paying Agent from time to time reasonable compensation for all services rendered under this Resolution, and also all reasonable expenses, charges, counsel fees and other disbursements, including those of their attorneys, agents and employees, incurred in and about the performance of their powers and duties under this Resolution as described in a fee schedule submitted to the District by the Paying Agent. The fees and expenses of the Paying Agent not paid from the proceeds of the sale of the Bonds shall be paid in each year from the interest and sinking fund of the District, insofar as permitted by law, including specifically by Section 15232 of the Education Code of the State of California. The District further agrees to indemnify and save the Paying Agent harmless against any liabilities which it may incur in the exercise and performance of its powers and duties hereunder which are not due to its negligence or bad faith. 17 ARTICLE VII EVENTS OF DEFAULT AND REMEDIES OF BONDOWNERS Section 7.01. Events of Default. The following events shall constitute Events of Default: (a) if default shall be made in the due and punctual payment of the principal of or redemption premium,if any,on any Bond when and as the same shall become due and payable, whether at maturity as therein expressed,by declaration or otherwise; (b) if default shall be made in the due and punctual payment of any installment of interest on any Bond when and as such interest installment shall become due and payable; (c) if default shall be made by the District in the observance of any of the covenants, agreements or conditions on its part in this Resolution or in the Bonds contained, and such default shall have continued for a period of thirty (30) days after written notice thereof to the District Representative;or (d) if the District shall file a petition seeking reorganization or arrangement under the federal bankruptcy laws or any other applicable law of the United States of America, or if a court of competent jurisdiction shall approve a petition, seeking reorganization of the District under the federal bankruptcy laws or any other applicable law of the United States of America, or if, under the previsions of any other law for the relief or aid of debtors, any court of competent jurisdiction shall assume custody or control of the District or of the whole or any substantial part of its property. Section 7.02. Application of Funds Upon Default. All of the sums in the Series A Debt Service Fund and accounts provided for in Section 4.02 hereof upon the occurrence of an Event of Default as provided in Section 7.01 hereof, and all sums thereafter received by the Paying Agent hereunder,shall be applied by the Paying Agent in the following order upon presentation of the Bonds, and the stamping thereon of the payment if only partially paid, or upon the surrender thereof if fully paid: First, to the payment of the costs and expenses of the Paying Agent hereunder and of the costs and expenses of Bondowners in declaring such event of default, including reasonable compensation to their agents,attorneys and counsel; Second, in case the principal of the Bonds shall not have become due and payable, to the payment of the interest in default in the order of the maturity of the installments of such interest, with interest on the overdue installments at the rate of twelve percent (12%) per annum (to the extent that such interest on overdue installments shall have been collected), such payments to be made ratably to the persons entitled thereto without discrimination or preference; Third, in case any principal of the Bonds shall have become and shall be then due and payable, all such sums shall be applied to the payment of the whole amount then owing and unpaid upon the Bonds for principal and interest, with interest on the overdue principal and installments of interest at the rate of twelve percent (12%d) per annum (to the extent that such interest on overdue installments of interest shall have been collected), and in case such moneys shall be insufficient to pay in full the whole amount so owing and unpaid upon the Bonds, then to the payment of such principal and interest without preference or priority of principal over interest, or interest over 18 principal,or of any installment of interest over any other installment of interest, ratably to the aggregate of such principal and interest. Section 7.03. R medies of Bondowners. Any Bondowner shall have the right, for the equal benefit and protection of all Bondowners similarly situated: (a) by mandamus, suit, action or proceeding, to compel the District and its members, officers,agents or employees to perform each and every term,provision and covenant contained in this Resolution and in the Bonds,and to require the carrying out of any or all such covenants and agreements of the District and the fulfillment of all duties imposed upon it; (b) by suit, action or proceeding in equity, to enjoin any acts or things which are unlawful,or the violation of any of the Bondowners'rights;or (c) upon the happening of any event of default (as defined in Section 7.01 hereof), by suit, action or proceeding in any court of competent jurisdiction, to require the District and its members and employees to account as if it and they were the trustees of an express trust. Section 7.04. Non-Waiver. Nothing in this Article 'VII or in any other provision of this Resolution, or in the Bonds, shall affect or impair the obligation of the District, which is absolute and unconditional,to pay the principal of and interest on the Bonds to the respective Owners of the Bonds at the respective dates of maturity,as herein provided,or affect or impair the right of action,which is also absolute and unconditional,of such Owners to institute suit to enforce such payment by virtue of the contract embodied in the Bonds. A waiver of any default by any Bondowner shall not affect any subsequent default or impair any rights or remedies on the subsequent default. No delay or omission of any Owner of any of the Bonds to exercise any right or power accruing upon any default shall impair any such right or power or shall be construed to be a waiver of any such default or an acquiescence therein,and every power and remedy conferred upon the Bondowners by this Article VI may be enforced and exercised from time to time and as often as shall be deemed expedient by the Owners of the Bonds. If a suit,action or proceeding to enforce any right or exercise any remedy be abandoned or determined adversely to the Bondowners, the District and the Bondowners shall be restored to'their former positions,rights and remedies as if such suit, action or proceeding had not been brought or taken. Section 7.05. Remedies Not Exclusive. No remedy herein conferred upon the Owners of Bonds shall be exclusive of any other remedy and that each and every remedy shall be cumulative and shall be in addition to every other remedy given hereunder or thereafter conferred on the Bondowners. 19 ARTICLE VIII SUPPLEMENTAL RESOLUTIONS Section 8.01. Sumlernental Resolutiom Effective f the Owner . For any one or more of the 161lowing purposes and at any time or from time to time, a Supplemental Resolution of the Board may be adopted, which, without the requirement of consent of the Owners of the Bonds,shall be fully effective in accordance with its terms: (a) To add to the covenants and agreements of the Board in this Resolution, other covenants and agreements to be observed by the District which are not contrary to or inconsistent with this Resolution as theretofore in effect; (b) To add to the limitations and restrictions in this Resolution, other limitations and restrictions to be observed by the Board which are not contrary to or inconsistent with this Resolution as theretofore in effect; (c)To confirm,as further assurance,any pledge under, and the subjection to any lien or pledge created or to be created by, this Resolution, of any moneys, securities or funds, or to establish any additional funds or accounts to be held under this Resolution, (d) To cure any ambiguity, supply and omission, or cure or correct any defect or inconsistent provision in this Resolution;or (e) To make such additions, deletions or modifications as may be necessary to assure exclusion from gross income for purposes of federal income taxation of interest on the Bonds. Section 8.02. SuMleniental Resolutions Effective With Consent to the Owners. Any modification or amendment of this Resolution and of the rights and obligations of the District and of the Owners of the Bonds,in any particular,may be made by a Supplemental Resolution, with the written consent of the Owners of at least two-thirds in aggregate principal amount of the Bonds Outstanding at the time such consent is given. No such modification or amendment shall permit a change in the terms of maturity of the principal of any Outstanding Bonds or of any interest payable thereon or a reduction in the principal amount thereof or in the rate of interest thereon,or shall reduce the percentage of Bonds the consent of the Owners of which is required to effect any such modification or amendment,or shall change any of the provisions in Section 7.01 hereof relating to Events of Default, or shall reduce the amount of moneys pledged for the repayment of the Bonds without the consent of all the Owners of such Bonds, or shall change or modify any of the rights or obligations of any Paying Agent without its written assent thereto. 20 ARTICLE IX MISCELLANEOUS Section 9.01. Benefits of Resolution Limited to Parties. Nothing in this Resolution, expressed or implied, is intended to give to any person other than the Board, the District, the Paying Agent and the Owners of the Bonds,any right,remedy, claim under or by reason of this Resolution.Any covenants,stipulations,promises or agreements in this Resolution contained by and on behalf of the District shall be for the sole and exclusive benefit of the Owners of the Bands. Section 9.02. Defeasance. (a) Discharge of Resolution. Any or all Bonds may be paid by the District in any of the fallowing ways, provided that the District also pays or causes to be paid any other sums payable hereunder by the District: (i) by paying or causing to be paid the principal of and interest on any Bonds Outstanding,as and when the same become due and payable; (ii) by depositing, in trust, at or before maturity, money or securities in the necessary amount(as provided in Section 9.02(e) to pay any Bonds Outstanding;or (iii) by delivering to the Paying Agent, for cancellation by it, any Bonds Outstanding. If the District shall pay all Bonds Outstanding and shall also pay or cause to be paid all other sums payable hereunder by the District, then and in that case, at the election of the District (evidenced by a certificate of a District Representative, filed with the Paying Agent, signifying the intention of the District to discharge all such indebtedness and this Resolution), and notwithstanding that any Bonds shall not have been surrendered for payment, this Resolution and other assets made under this Resolution and all covenants, agreements and other obligations of the District under this Resolution shall cease,terminate,become void and be completely discharged and satisfied,except only as provided in Section 9.02(b). In such event, upon request of the District, the Paying Agent shall cause an accounting for such period or periods as may be requested by the District to be prepared and filed with the District and shall execute and deliver to the District all such instruments as may be necessary to evidence such discharge and satisfaction, and the Paying Agent shall pay over, transfer, assign or deliver to the District all moneys or securities or other property held by it pursuant to this Resolution which are not required for the payment of Bonds not theretofore surrendered for such payment. (b) Discharge of Liability on Bonds. Upon the deposit, in trust, at or before maturity, of money or securities in the necessary amount (as provided in Section 9.02(c) to pay any Outstanding Bond(whether upon or prior to its maturity date), then all liability of the District in respect of such Bond shall cease and be completely discharged, except only that thereafter the Owner thereof shall be entitled only to payment of the principal of and interest on such Bond by the District,and the District shall remain liable for such payment, but only out of such money or securities deposited with the Paying Agent or an escrow agent (in either case, the "Escrow Agent") as aforesaid for such payment, provided further, however, that the provisions of Section 9.02(d) shall apply in all events. The District may at any time surrender to the Paying Agent for cancellation by it any Bonds previously issued and delivered, which the District may have acquired in any manner 21 whatsoever,and such Bonds,upon such surrender and cancellation,shall be deemed to be paid and retired. (c) Deposit of Money or Securities with Escrow Agent. Whenever in this Resolution it is provided or permitted that there be deposited with or held in trust by the Escrow Agent money or securities in the necessary amount to pay any Bonds, the money or securities so to be deposited or held may include money or securities held by the Escrow Agent in the funds and accounts established pursuant to this Resolution and shall be: (i) lawful money of the United States of America in an amount equal to the principal amount of such Bonds and all unpaid interest thereon to maturity;or (ii) Federal Securities (not callable by the issuer thereof prior to maturity) the principal of and interest on which when due, in the opinion of a certified public accountant delivered to the District, will provide money sufficient to pay the principal of and all unpaid interest to maturity, on the Bonds to be paid, as such principal and interest become due; provided, in each case, that the Escrow Agent shall have been irrevocably instructed (by the terms of this Resolution or by request of the District) to apply such money to the payment of such principal and interest with respect to such Bonds. (d) Payment of Bonds After Discharge of Resolution. Notwithstanding any provisions of this Resolution,any moneys held by the Paying Agent in trust for the payment of the principal of,or interest on,any Bonds and remaining unclaimed for two years after the principal of all of the Bonds has become due and payable,if such moneys were so held at such date, or two years after the date of deposit of such moneys if deposited after said date when all of the Bonds became due and payable,shall,upon request of the District, be repaid to the District free from the trusts created by this Resolution, and all liability of the Paying Agent with respect to such moneys shall thereupon cease; provided, however, that before the repayment of such moneys to the District as aforesaid, the Paying Agent may (at the cost of the District) first mail to the Owners of all Bonds which have not been paid at the addresses shown on the bond register maintained by the Paying Agent a notice in such form as may be deemed appropriate by the Paying Agent,with respect to the Bonds so payable and not presented and with respect to the provisions relating to the repayment to the District of the moneys held for the payment thereof. Section 9.03. Execution of Documents and Proof ofi,v rshig by Bondowners. Any request, declaration or other instrument which this Resolution may require or permit to be executed by Bondowners may be in one or more instruments of similar tenor, and shall be executed by Bondowners in person or by their attorneys appointed in writing. Except as otherwise herein expressly provided, the fact and date of the execution by any Bondowner or his attorney of such request, declaration or other instrument, or of such wrating appointing such attorney,may be proved by the certificate of any notary public or other officer authorized to take acknowledgments of deeds to be recorded in the state in which he purports to act, that'the person signing such request, declaration or other instrument or writing acknowledged to him the execution thereof, or by an affidavit of a witness of such execution, duly sworn to before such notary public or other officer. Except as otherwise herein expressly provided, the ownership of registered Bonds and the amount, maturity, number and date of holding the same shall be proved by the registry books. 22 Any request,declaration or other instrument or writing of the Owner of any Bond shall bind all future Owners of such Bond in respect of anything done or suffered to be done by the District, the Paying Agent or the District Representative in good faith and in accordance therewith. Section 9.04. Waiver of Personal Liability. No board member, officer, agent or employee of the Board or the District shall be individually or personally liable for the payment of the principal of or interest on the Bonds; but nothing herein contained shall relieve any such board member,officer,agent or employee from the performance of any official duly provided by law. Section 9.05. Destruction of Canceled Bonds. Whenever in this Resolution provision is made for the surrender to the District of any Bonds which have been paid or canceled pursuant to the provisions of this Resolution, a certificate of destruction duly executed by the Paying Agent shall be deemed to be the equivalent of the surrender of such canceled Bonds and the District shall be entitled to rely upon any statement of fact contained in any certificate with respect to the destruction of any such Bonds therein referred to. Section 9.06. Partial Invalidity. If any Section, paragraph, sentence, clause or phrase of this Resolution shall for any reason be held illegal or unenforceable,such holding shall not affect the validity of the remaining portions of this Resolution. The Board hereby declares that it would have adopted this Resolution and each and every other Section, paragraph, sentence, clause or phrase hereof and authorized the issue of the Bonds pursuant thereto irrespective of the fact that any one or more Sections, paragraphs, sentences, clauses, or phrases of this Resolution may be held illegal, invalid or unenforceable. If, by reason of the judgment of any court,the District is rendered unable to perform its duties hereunder, all such duties and all of the rights and powers of the District hereunder shall be assumed by and vest in the District Representative in trust for the benefit of the Bondowners. Section 9.07. Effective Date of Resolution. This Resolution shall take effect from and after the date of its passage and adoption. 23 PASSED AND ADOPTED at a regular meeting of the Board of Supervisors of the COUNTY OF CONTRA COSTA on the 18th day of June 2002,by the following vote: AYES,Supervisor: UILKEMA, GERBER, DeSAULNIER, GLOVER AND GIOIA NOES,Supervisor: NONE ABSENT,Supervisor: NONE ABSTAIN: NONE BOARD OF SUPERVISORS OF CONTRA C TA COUNTY By: erson of the Board By: Clerk of the Board of Supervisors 24 EXHIBIT A FORM OF CURRENT INTEREST BOND UNITED STATES OF AMERICA STATE OF CALIFORNIA COUNTY OF CONTRA COSTA JOHN SWETT UNIFIED SCHOOL DISTRICT ELECTION OF 2002 GENERAL OBLIGATION BOND, SERIES A INTEREST RATE: MATURITY DATE: ISSUE DATE: CUSIP: 2002 REGISTERED OWNER: PRINCIPAL SUM: DOLLARS The JOHN SWETT UNIFIED SCHOOL DISTRICT, a unified school district duly organized and existing under and by virtue of the Constitution and laws of the State of California (the "District"), for value received, hereby promises to pay to the Registered Owner stated above, or registered assigns (the "Owner"), on the Maturity Date stated above, the Principal Sum stated above, in lawful money of the United States of America, and to pay interest thereon in like lawful money from the interest payment date next preceding the date of authentication of this Bond (unless (i) this Bond is authenticated on an interest payment date, in which event it shall bear interest from such date of authentication, or (ii) this Bond is authenticated prior to an interest payment date and after the close of business on the fifteenth day of the month preceding such interest payment date, in which event it shall bear interest from such interest payment date, or (iii) this Bond is authenticated on or prior to in which event it shall bear interest from the Issue Date stated above; provided however, that if at the time of authentication of this Bond,interest is in default on this Bored, this Bond shall bear interest from the interest payment date to which interest has previously been paid or made available for payment on this Bond) until payment of such Principal Sum in full,at the rate per annum stated above, payable on February 1 and August 1 in each year, commencing February 1, 2003, calculated on the basis of a 360-day year comprised of twelve 30-day months. Principal hereof is payable at the corporate trust office of BNY Western Trust Company the"Paying Agent"),in San Francisco, California. Interest hereon (including the final interest payment upon maturity) is payable by check of the Paying Agent mailed by first-class mail to the Owner at the Owner's address as it appears on the bond register maintained by the Paying Agent as of the close of business on the fifteenth day of the month next preceding such interest payment date (the "Record Date""),or at such other address as the Owner may have filed with the Paying Agent for that purpose. This Bond is one of a duly authorized issue of bonds of the District designated as "John Swett Unified School District, Election of 2002 General Obligation Bonds, Series A" (the "Bonds"), in an aggregate principal amount of Ten Million dollars ($10,000,000), all of like Exhibit A Page 1 tenor and date (except for such variation, if any, as may be required to designate varying numbers,maturities,interest rates or redemption and other provisions) and all issued pursuant to the provisions of Chapter 1.5 of Part 10 (coking with section 15264) of the California Education Code (the "Act"), and pursuant to Resolution No. of the Board of Supervisors of Contra Costa County adopted June 18, 2002 (the "Resolution"), authorizing the issuance of the Bonds. Reference is hereby made to the Resolution(copies of which are on file at the office of the Superintendent of the District) and the Act for a description of the terms on which the Bonds are issued and the rights thereunder of the owners of the Bonds and the rights, duties and immunities of the Paying Agent and the rights and obligations of the District thereunder,to all of the provisions of which Resolution the Owner of this Bond, by acceptance hereof,assents and agrees. The Bonds have been issued by the District to build, equip and furnish and elementary school. This Bond and the interest hereon and on all other Bonds and the interest thereon (to the extent set forth in the Resolution) are general obligations of the District, and the Board of Supervisors of Contra Costa County has the power and is obligated to levy ad valorem taxes for the payment of the Bonds and the interest thereon upon all property within. the District subject to taxation by the District. ' The County of Contra Costa, including its Board, officers, officials, agents and employees: (i)are not liable for the payment of the Bonds,including the interest hereon; and (ii) shall retain all their respective constitutional and statutory privileges, immunities, rights and defenses in carrying out their duties under the Resolution. The Current Interest Bonds may be redeemed before maturity, at the option of the District, on the dates provided herein (or on such other dates provided in the Purchase Contract). The Current Interest Bonds maturing on or before August 1, 2011, are not subject to redemption prior to their fixed maturity dates. The Current Interest Bonds maturing on or after August 1,2012,may be redeemed before maturity at the option of the District, from any source of funds, on August 1,2011, or on any Bond Payment Date thereafter as a whole, or in part in inverse order of maturity and by lot within a maturity. For the purpose of such selection, Current Interest Bonds will be deemed to consist of$5,000 portions, and any such portion may be separately redeemed. The Current Interest Bonds called prior to maturity will be redeemed at the following redemption prices, expressed as a percentage of par value, together with accrued interest to the date of redemption. Redemption Dates Redemption Prices August 1,2011 through July 31,2012 101% August 1,2012 and thereafter 100% The Current Interest Bonds are issuable as fully registered Bonds, without coupons, in denominations of $5,000 and any integral multiple thereof. Subject to the limitations and conditions and upon payment of the charges,if any, as provided in the Resolution. Bonds may be exchanged for a like aggregate principal amount of Bonds of other authorized denominations and of the same maturity. This Bond is transferable by the Owner hereof, in person or by his attorney duly authorized in writing,at said office of the Paying Agent in San Francisco,California,but only in the manner and subject to the limitations provided in the Resolution, and upon surrender and cancellation of this Bond. Upon registration of such transfer a new Bond or Bonds, of Exhibit A Page 2 authorized denomination or denominations,for the sante aggregate principal amount and of the same maturity will be issued to the transferee in exchange herefor. The District',and the Paying Agent may treat the Owner hereof as the absolute owner hereof for all purposes, and the District and the Paying Agent shall not be affected by any notice to the contrary. The Resolution may be amended without the consent of the Owners of the Bonds to the extent set forth in the Resolution. It is hereby certified that all of the things, conditions and acts required to exist, to have happened or to have been performed precedent to and in the issuance of this Bond do exist, have happened or have been performed in due and regular time and manner as required by the laws of the State of California, and that the amount of this Bond, together with all other indebtedness of the District, does not exceed any limit prescribed by any laws of the State of California, and is not in excess of the amount of Bonds permitted to be issued under the Resolution. This Bond shall not be entitled to any benefit under the Resolution or become valid or obligatory for any purpose until the Certificate of Authentication hereon shall have been signed manually by the Paying Agent. Exhibit A Page 3 IN WITNESS'WHEREOF,the John Swett Unified School District, Contra Costa County, California has caused this Election of 2002 General Obligation Bond,Series A to be executed on behalf of the District and in their official capacities by the manual or facsimile signature of the Chairperson of the Board of Supervisors and County Tax Collector-Treasurer, and to be countersigned by the manual or facsimile signature of the Clerk of the Board, and its seal to be reproduced hereon, all as of the Issue Date stated above. BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA By: Ch ' rson,Board of Supervisors By: County x ector-Treasurer (SEAL) ATT T: t Clerk of the Board Exhibit A Page 4 [FORM OF PAYING AGENTS CERTIFICATE OF AUTHENTICATION] CERTIFICATE OF AUTHENTICATION This is one of the John Swett Unified School District Election of 2002 General Obligation Bonds, Series A described in the within-mentioned Resolution. Authentication Date: as Paying Agent Authorized Signatory Exhibit A Page 5 ABBREVIATIONS The following abbreviations, when used in the inscription on the face of this Bond, shall be construed as though they were written out in full according to applicable laws or regulations: TEN COM-- as tenants in common UNIF GIFT U N ACT TEN ENT -- as tenants by the entireties Custodian JT TEN -- as joint tenants with Minor right of survivorship and not Under Uniform Gifts to Minors as tenants in common Act (State) ADDITIONAL ABBREVIATIONS MAY ALSO BE USED THOUGH NOT IN THE LIST ABOVE Exhibit A Page 6 (FORM OF ASSIGNMENT) For value received,the undersigned do(es)hereby sell,assign and transfer unto (Name,Address and Tax Identification or Social Security Number of Assignee) the within Bond and do(es)hereby irrevocably constitute and appoint attorney,to transfer the same on the bond register of the Paying Agent, with full power of substitution in the premises. Dated: Signature Guaranteed: NOTICE: Signature(s) must be guaranteed by NOTICE: The signature on this assignment must a qualified guarantor correspond with the name(s) as written on the face of the within Bond in every particular without alteration or enlargement or any change whatsoever. Exhibit A Page 7 EXHIBIT B FORM OF CAPITAL APPRECIATION BOND UNITED STATES OF AMERICA STATE OF CALIFORNIA COUNTY OF CONTRA COSTA JOHN SWETT UNIFIED SCHOOL DISTRICT ELECTION OF 2002 GENERAL OBLIGATION BOND, SERIES A YIELD TO MATURITY. MATURITY DATE. ISSUE DATE: CUSIP: 2002 REGISTERED OWNER: DENOMINATIONAL AMOUNT: DOLLARS MATURITY VALUE: DOLLARS The JOHN SWETT UNIFIED SCHOOL DISTRICT, a unified school district duly organized and existing under and by virtue of the Constitution and laws of the State of California (the "District"), for value received hereby promises to pay to the Registered Owner stated above, or registered assigns (the "Owner"), on the Maturity Date stated above, the Maturity Value stated above,constituting the Denominational Amount stated above, in lawful money of the United States of America, and interest on said Denominational Amount from until payment of such Denominational Amount at the Yield to Maturity stated above per annum, compounded semiannually on each February 1 and August 1, commencing August 1,2002, and payable on the Maturity Date specified above,provided,however, that the amount of principal and interest payable on any date shall be determined solely by reference to the Table of Compounded Amounts on Page[[51 hereof. Principal hereof and interest herein is payable at the corporate trust office of the BNY Western Trust Company (the "Paying Agent"), in San Francisco, California. Payment of the principal of and interest on the Bonds shall be payable by check representing the coin or currency of the United States of America as, at the times of payment,shall be legal tender for the payment of public or private debts. This Bond is one of a duly authorized issue of bonds of the District designated as "John Swett Unified School District, Election of 2002 General Obligation Bonds, Series A" (the "Bonds"), in an aggregate principal amount of Dollars ($ ), all of like tenor and date (except for such variation, if any, as may be required to designate varying numbers, maturities, interest rates or redemption and other provisions) and all issued pursuant to the provisions of Chapter 1.5 of Part 10 (commencing with section 15264)of the California Education Code (the "Act"), and pursuant to Resolution No. of the Burd of Supervisors of Contra Costa County adopted June 18, 2002 (the "Resolution"),authorizing the issuance of the Bonds.Reference is hereby made to the Resolution Exhibit B Page 1 (copies of which are on file at the office of the Superintendent of the District) and the Act for a description of the terms on which the Bonds are issued and the rights thereunder of the owners of the Bonds and the rights, duties and immunities of the Paying Agent and the rights and obligations of the District thereunder,to all of the provisions of which Resolution the Owner of this Bond,by acceptance hereof,assents and agrees. The Bonds have been issued by the District to build, equip and furnish an elementary school. This Bond and the interest hereon and on all other Bonds and the interest thereon (to the extent set forth in the Resolution) are general obligations of the District, and the Board of Supervisors of Contra Costa County has the power and is obligated to levy ad valorem taxes for the payment of the Bonds and the interest thereon upon all property within the District subject to taxation by the District. The County of Contra Costa, including its Board, officers, officials, agents and employees: (i)are not liable for the payment of the Bonds,including the interest hereon, and (ii) shall retain all their respective constitutional and statutory privileges, immunities, rights and defenses in carrying out their duties under the Resolution. Bonds maturing on are subject to mandatory redemption from monies in the Series A Debt Service Fund prior to their stated maturity date, at the Accreted Value thereof without premium on each on and after yo in the Accreted Value as set forth in the following table: Redemption Dates Accreted Values TOTAL $— The Bonds are issuable as fully registered Bonds, without coupons, in denominations of $5,000 Maturity Value and any integral multiple thereof. Subject to the limitations and conditions and upon payment of the charges,if any, as provided in the Resolution. Bonds may be lexchanged for a like aggregate Maturity Value of Bonds of other authorized denominations and of the same maturity. This Bond is transferable by the Owner hereof, in person or by his attorney duly authorized in writing,at said office of the Paying Agent in San Francisco,California,but only in the manner and subject to the limitations provided in the Resolution, and upon surrender and cancellation of this Bond. Upon registration of such transfer a new Bond or Bonds, of authorized denomination or denominations,for the same aggregate principal amount and of the same maturity will be issued to the transferee in exchange herefor. The District and the Paying Agent may treat the Owner hereof as the absolute owner hereof for all purposes, and the District and the Paying Agent shall not be affected by any notice to the contrary. The Resolution may be amended without the consent of the Owners of the Bonds to the extent set forth in the Resolution. It is hereby certified that all of the things, conditions and acts required to exist, to have happened or to have been performed precedent to and in the issuance of this Bond do exist, have happened or have been performed in due and regular time and manner as required by the laws of-the State of California, and that the amount of this Bond, together with all other Exhibit B Page 2 indebtedness of the District, does not exceed any limit prescribed by any laws of the State of California, and is not in excess of the amount of Bonds permitted to be issued under the Resolution This Bond shall not be entitled to any benefit under the Resolution or become valid or obligatory for any purpose until the Certificate of Authentication hereon shall have been signed manually by the Baying Agent. Exhibit B Page 3 IN WITNESS WHEREOF,the John Swett Unified School District, Contra Costa County, California has caused this Election of 2002 General Obligation Bond,Series A to be executed on behalf of the District and in their official capacities by the manual or facsimile signature of the Chairperson of the Board of Supervisors and County Tax Collector-Treasurer, and to be countersigned by the manual or facsimile signature of the Clerk of the Board, and its seal to be reproduced hereon,all as of the Issue Date stated above. BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA By: Ch4a' Irson,Board of Supervisors By: County Tax (16'r--Treasurer (SEAL) ATTEST: �U Clerk of the Board Exhibit B Page 4 TABLE OF COMPOUNDED AMOUNTS [To Come] Exhibit B Page 5 [FORM OF PAYING AGENT'S CERTIFICATE OF AUTHENTICATION] ON] CERTIFICATE OF AUTHENTICATION This is one of the Jahn Swett Unified School District Electron of 2002 General Obligation Bonds, Series A described in the within-mentioned Resolution. Authentication Date: as Paying Agent Authorized Signatory Exhibit B Page 6 ABBREVIATIONS The following abbreviations, when used in the inscription on the face of this Bond, shall be construed as though they were written out in full according to applicable laws or regulations: TEN COM— as tenants in common UNIF GIFT MILT ACT TEN ENT -- as tenants by the entireties Custodian JT TEN -- as joint tenants with Minor right of survivorship and not Under Uniform Gifts to Minors as tenants in common Act (State) ADDITIONAL ABBREVIATIONS MAY ALSO BE USED THOUGH NOT IN THE LIST ABOVE Exhibit B Page 7 (FORM OF ASSIGNMENT) For value received,the undersigned do(es)hereby sell,assign and transfer unto (Name,Address and Tax Identification or Social Security Number of Assignee) the within Bond and do(es)hereby irrevocably constitute and appoint attorney,to transfer the same on the bond register of the Paying Agent, with full power of substitution in the premises. Dated: Signature Guaranteed: NOTICE: Signature(s) must be guaranteed by NOTICE: The signature on this assignment must a qualified guarantor correspond with the name(s) as written cn the face of the within Bond in every particular without alteration or enlargement or any change whatsoever. Exhibit B Page 8 RESOLUTION NO. RESOLUTION OF THE BOARD OF TRUSTEES OF THE JOHN SWETT UNIFIED SCHOOL DISTRICT REQUESTING THE BOARD OF SUPERVISORS OF THE COUNTY OF CONTRA COSTA TO ISSUE AND SELL GENERAL OBLIGATION BONDS OF THE DISTRICT IN THE AGGREGATE PRINCIPAL AMOUNT OF NOT TO EXCEED$10,000,000 WHEREAS, an election was duly and regularly held in the John Swett Unified School District (the "District") on March 5, 2002, in accordance with Section 1(b)(3) of Article XIIIA of the California Constitution, for the purpose of submitting to the qualified electors of the District the question whether general obligation bonds should be issued in the aggregate principal amount of $10,000,000 (the "Bonds"), at which election 55% or more of the votes cast were in favor of the issuance of the Bonds;and WHEREAS, the District is authorized to issue the Bonds under Chapter 1.5 of Part 10, Division 1, Title 1 of the Education Code of the State of California (the "Bond Law"), commencing with Section 15264 of the Education Code, which requires that general obligation bonds of the District be offered for sale by the Board of Supervisors of County of Contra Costa, as soon as possible following receipt of a resolution adopted by the Board of Trustees of the District; and WHEREAS, Section 15266(b) of the Education Code provides that where not inconsistent, the provisions of Chapter 1 (commencing with Section 15100) of the Education Code shall apply to the Bond Law; and WHEREAS, the Board of Trustees of the District wishes to adopt this Resolution for the purpose of requesting the Board of Supervisors of Contra Costa County to authorize and sell the Bonds in the principal amount of not to exceed $10,000,000; NOW, THEREFORE, BE IT RESOLVED, by the Board of Trustees of the John Swett Unified School District the following. Section to Authorization of Series A Bonds; Request to County. The Board of Trustees (the "Board") of the District hereby authorizes the issuance of the Bonds, to be designated the "John Swett Unified School District (Centra Costa County, California) General Obligation Bonds, Election of 2002, Series A" (the "Series A Bonds") in the aggregate principal amount of not to exceed $10,000,000 for the purpose of raising money to finance the construction, and equipping of school facilities as set forth in the proposition authorizing the issuance of the Bonds (the "Bond Proposition"). The Board hereby requests the Board of Supervisors of the County of Contra Costa to issue and sell the Series A Bonds in the name and on behalf of the District under the Bond Law. Section 2. Interest. The Series A Bonds shall bear interest at the rate of not to exceed 7.00% per annum, payable on such dates as set forth in the agreement awarding the sale of the Series A Bonds as hereinafter set forth. Section 3. Maturity. The Series A Bonds shall mature on each of the dates and in the respective amounts as set forth in the agreement awarding the sale of the Series A Bonds as hereinafter set forth. The term of the Series A Bonds shall not exceed 25 years from the date of the Series A Bonds. Section 4. Approval of County Resolution. The resolution of the Board of Supervisors authorizing the sale of the Series A Bonds is hereby approved in substantially the form presented to the Board at this meeting (the "County Resolution"). The provisions of the County Resolution relating to payment of principal of and interest on the Series A Bonds are set forth in the County Resolution solely at the request of the District for the convenience of the District in the administration of the Series A Bonds, and do not create any responsibilities for the Board of Supervisors of the County beyond the express statutory requirements contained in Sections 15140, 15146 and 15250 of the Education Code. The District agrees to carry out and perform all of its obligations under the County Resolution. Section 5. Building Fund. The District hereby directs the Treasurer-Tax Collector of the County of Contra Costa to establish, hold and maintain a fund to be known as the "John Swett Unified School District Series A General Obligation Bond Building Fund", as a separate account, distinct from all other funds of the County and the District. The proceeds from the sale of the Series A Bonds, to the extent required under the County Resolution, shall be deposited in and credited to the Building Fund, and shall be expended by the District solely for the acquisition, improvement and equipping of school facilities for which the Series A Bond proceeds are authorized to be expended under the Bond Proposition, including payment of the costs of issuing the Series A Bonds. All interest and other gain arising from the investment of amounts deposited to the Building Fund shall be retained in the Building Fund and used for the purposes thereof. Section 6. Debt Service Fund. The District hereby directs the Treasurer-Tax Collector of the County (the "County Treasurer") to establish, hold and maintain a fund to be known as the "John Swett Unified School District Series A General Obligation Bond Debt Service Fund", which shall be maintained by the County Treasurer-Tax Collector as a separate account, distinct from all other funds of the County and the District. All taxes levied by the County,at the request of the District,for the payment of the principal of and interest and premium (if any) on the Series A Bonds in accordance with the County Resolution shall be deposited in the Debt Service Fund by the County promptly upon apportionment of said levy. The Debt Service Fund shall be pledged for the payment of the principal of and interest on the Series A Bonds when and as the same become due, including the principal of any term Series A Bonds required to be paid upon the mandatory sinking fund redemption thereof. The moneys in the Debt Service Fund, to the extent necessary to pay the principal of and interest and redemption premium(if any) on the Series A Bonds as the same become due and payable, shall be transferred by the County to the Paying Agent upon the written request of the District filed with the -2- County, as required to pay the principal of and interest and redemption premium(if any)on the Series A Bonds. If, after payment in full of the Series A Bonds, any amounts remain on deposit in the Debt Service Fund,such amounts shall be transferred to the General Fund of the District, as provided in Section 15234 of the Bond Law. Section 7. Sale of Series A Bonds. The Board hereby requests that the Board of Supervisors of the County sell the Series A Bonds on a negotiated basis to Stone & Youngberg LLC (the "Underwriter") under a Bond Purchase Agreement among the District,the Underwriter and the County Treasurer in substantially the form on file with the District, together with any changes thereto which are approved by the Superintendent or his designee (each, a "District Representative"). The Board hereby authorizes and directs a District Representative to execute and deliver the final form of the Bond Purchase Agreement in the name and on behalf of the District. The County Treasurer, or any designee thereof, is hereby authorized to execute and deliver the Bond Purchase Agreement, with such changes therein, deletions therefrom and modifications thereto as the County Treasurer, or designee thereof, may approve, such approval to be conclusively evidenced by the execution and delivery thereof. The true interest cost of the Series A Bonds shall not exceed 6.5% per annum and the Underwriter's discount may not exceed 1.710 of the aggregate principal amount of the Series A Bonds sold thereunder. Section 8. Tax Covenants. (a) Private Activity Bond Limitation. The District shall'assure that the proceeds of the Series A Bonds are not so used as to cause the Series A Bonds to satisfy the private business tests of Section 141(b) of the Internal Revenue Code of 1986, as amended (the "Tax Code"), or the private loan financing test of Section 141(c) of the Tax Code. (b) Federal Guarantee Prohibition. The District shall not take any action or permit or suffer any action to be taken if the result of the same would be to cause any of the Series A Bonds to be "federally guaranteed" within the meaning of Section 149(b) of the Tax Code. (c) Rebate Requirement. The District shall take any and all actions necessary to assure compliance with Section 148(f) of the Tax Code, relating to the rebate of excess investment earnings, if any, to the federal government, to the extent that such section is applicable to the Series A Bonds. (d)' No Arbitrate The District shall not take, or permit or suffer to be taken by the Paying Agent or otherwise, any action with respect to the proceeds of the Series A Bonds which,if such action had been reasonably expected to have been taken, or had been deliberately and intentionally taken,on the date of issuance of the Series A Bonds would have caused the Series A Bonds to be"arbitrage bonds" within the meaning of Section 148:of the Tax Code. -3- Ike) Maintenance of Tax-Exemp i n. The District shall take all actions necessary to assure the exclusion of interest on the Series A Bonds from the gross income of the owners of the Series A Bonds to the same extent as such interest is permitted to be excluded from gross income under the `Fax Code as in effect on the date of issuance of the Series A Bonds. (f) Exertion from Rebate HgQm cement. The District is a governmental unit with the power to impose taxes of general applicability which, when collected,may be used for general purposes of the District; the Bonds are not private activity bonds within the meaning of section 141 of the Internal Revenue Code of 1986 (the "Code"); and ninety-five percent (95%) of the Net Sale Proceeds of the Bonds are to be used for local governmental activities of the District. The aggregate face amount (or, issue prices,in the case of issues with a net original issue discount or net original issue premium in excess of two percent (2%) of the principal amount of the issue,excluding original issue premium used for reasonable underwriter's compensation) of all tax-exempt obligations (other than private activity bonds as defined in section 141 of the Code) issued by the District, including all subordinate entities of the District and all entities which may issue obligations on behalf of the District, during the calendar year during which the Bonds are being issued, is not reasonably expected to exceed $15,00,000, of which no more than $5,000,000 is for other than the construction of public school facilities, excluding, however, that portion of current refunding obligations having a principal amount not in excess of the principal amount of the refunded obligation. By reason of the statements set forth in this subparagraph, the District will not rebate excess investment earnings,if any,to the federal government. Section 9. Preparation of Official Statement. The Board hereby approves, and hereby deems nearly final within the meaning of Rule 15c2-12 of the Securities Exchange Act of 1934, the Preliminary Official Statement describing the Series A Bonds in substantially the form on file with the Secretary of the District. The Board hereby approves and authorizes the distribution by the Underwriter of the Preliminary Official Statement to prospective purchasers of the Series A Bonds, and authorizes and directs a District Representative on behalf of the District to deem the Preliminary Official Statement "final" under Rule 15c2-12 under the Securities : Exchange Act of 1934 (the "Rule") prior to its distribution by the Underwriter. A District Representative is hereby authorized and directed to approve any changes in or additions to a final form of said Official Statement,and the execution thereof by a District Representative shall be conclusive evidence of his approval of any such changes and additions. The Board hereby authorizes the distribution of the final Official Statement by the Underwriter. The final Official Statement shall be executed in the name and on behalf of the District by a District Representative. Section 10. Continuing Disclosure. The Board hereby covenants and agrees that it will comply with and carry out all of the provisions of the Continuing Disclosure Certificate in substantially the form attached to the Preliminary Official Statement. A District Representative is hereby authorized and directed to assist the Underwriter and Bond Counsel in completing the Continuing Disclosure Certificate, and to execute said Certificate on or prior to the closing of the Series A Bonds. -4- Section 11. Appointment of Paying Agent. The Board hereby appoints the BNY Western Trust Company to act as the authenticating agent, Bond registrar, transfer agent and paying agent (collectively, the '°Paying Agent") for the Series A Bonds. The Paying Agent shall perform such functions as are imposed upon it under the County Resolution. All fees and expenses incurred for services of the Paying Agent shall be the sole responsibility of the District. The District shall pay to the Paying Agent from time to time reasonable compensation for all services rendered under this resolution and the County Resolution, and also all reasonable expenses, charges, counsel fees and other disbursements, including those of their attorneys, agents and employees, incurred in and about the performance of their powers and duties under this Resolution and the County Resolution. The District further a to indemnify and save the Paying Agent harmless against any liabilities which it may incur in the exercise and performance of its powers and duties hereunder which are not due to its negligence or bad faith. Section 12. Actions to Close the Issue. All actions heretofore taken by the officers and agents of the District with respect to the sale and issuance of the Series A Bonds are hereby approved, and each District Representative and all other officers of the District are hereby authorized and directed for and in the name and on behalf of the District, to do any and all things and take any and all actions relating to the execution and delivery of any and all certificates, requisitions, agreements and other documents, which they, or any of them, may deem necessary or advisable in order to consummate the lawful issuance and delivery of the Series A Bonds in accordance with this Resolution and the County Resolution. Section 13. Effective Date. This resolution shall take effect on and after its adoption. PASSED AND ADOPTED by the Board of Trustees of the John Swett Unified School District the 6th day of June, 2002. Signed: President of the Board of Trustees John Swett Unified School District County of Contra Costa, State of California Signed: Clerk of the Board of Trustees John Swett Unified School District County of Contra Costa, State of California -5- CLERK'S CERTIFICATE I, , Clerk of the Board of Trustees of the JOHN SWETT UNIFIED SCHOOL DISTRICT, hereby certify that the foregoing is a full, true, and correct copy of Resolution No. adopted at a regular meeting place thereof on the 6th day of June,2002, of which meeting all the members of said Board of Trustees had due notice and at which a majority thereof were present, and that at said meeting said resolution was adopted by the following vote: AYES: NOES: ABSENT: An agenda of said meeting was posted at least 72 hours before said meeting at California, a location freely accessible to members of the public, and a brief general description of said resolution appeared on said agenda. I further certify that I have carefully compared the same with the original minutes of said meeting on file and of record in my office; that the foregoing resolution is a full, true and correct copy of the original resolution adopted at said board meeting and entered in said minutes; and that said resolution has not been amended, modified or rescinded since the date of its adoption, and the same is now in full force and effect. Dated:June 2002 Clerk of the Board of Trustees of the JOHN SWETT UNIFIED SCHOOL DISTRICT -6- JOHN SWETT UNIFIED SCHOOL DISTRICT General Obligation Bonds, Erection of 2002, Series A CONTRACT OF PURCHASE June 2002 County of Contra Costa Treasurer-Tax Collector 625 Court Street, Room 102 Martinez, CA 94553 Board of Trustees John Swett Unified School District 341 B Street Crockett, CA 94525 Ladies and Gentlemen: The undersigned (the "Underwriter") offers to enter into this Contract of Purchase (the "Purchase Contract") with the County of Contra Costa, California (the "County), and the John Swett Unified School District (the "District") which, upon your acceptance hereof,will be binding upon the County and the District and the Underwriter. This offer is made subject to the written acceptance of the Purchase Contract by the County and the District and delivery of such acceptance to the Underwriter at or prior to 11.59 P.M., California Time,on the date hereof. 1. Purchase and Sale of the Bonds. Upon the terms and conditions and in reliance upon the representations, warranties and agreements herein set forth, the Underwriter hereby agrees to purchase from the County for reoffering to the public, and the County hereby agrees to sell in the name and on behalf of the District to the Underwriter for such purpose, all (but not less than all) of $ aggregate principal amount of the District's General Obligation Bonds, Election of 2002, Series A (the "Series A Bonds"). The Series A Bonds shall bear or accrete interest at the rates, shall mature in the years, and shall be subject to redemption as,shown on Appendix A hereto, which is incorporated herein by this reference. The Current Interest Series A Bonds (as defined in the County Resolution described below) shall bear interest payable from the date thereof as specified in Section 2 herein on each February 1 and August 1 commencing February 1, 2003. The Capital Appreciation Series A Bonds maturing August 1, to August 1, (as defined in the Resolution described below) shall accrete interest, from their date, as specified in Section 2 herein, compounded semiannually on February 1 and August 1 commencing on August 1, 2002, and shall be paid at maturity as shown in Appendix A hereto. The Capital Appreciation Series A Bonds maturing,July 1,2027(as defined in the Resolution described below), shall accrete interest from their date, as specified in Section 2 herein, compounded semiannually on January 1 and July 1, commencing on January 1, 2003, and shall be paid at maturity as shown in Appendix A hereto. The Underwriter shall purchase the Series A Bonds at a price of$ , which is equal to the aggregate principal amount of the Series A Bonds, plus accrued interest with respect to the Current Interest Series A Bonds. 2. The Bonds. The Current Interest Series A Bonds shall be dated July 1, 2002. The Capital Appreciation Series A Bonds shall be dated the date of delivery. The Series A Bonds shall be issued and secured pursuant to the provisions of the Resolution of the District adopted on June 5, 2002 (the "District Resolution"), the Resolution of the Board of Supervisors of the County adopted on June 18 (the "County Resolution"), and collectively with the District Resolution, the "Resolutions"), and Section 15100 et seq. of the California Education Code(the "Act") and other applicable law. Certain provisions for the optional and mandatory redemption of the Series A Bonds not otherwise specified in the Resolutions are shown in Appendix A hereto, all as provided in the County Resolution. The Series A Bonds shall be executed and delivered under and in accordance with the provisions of the Purchase Contract and the Resolutions. 3. Use of Documents. The District hereby authorizes the Underwriter to use, in connection with the offer and sale of the Series A Bonds, the Purchase Contract, the Official Statement (defined below), and the District Resolution, and the County hereby authorizes the Underwriter to use the Purchase Contract and the County Resolution, and all information contained herein and therein and all of the documents, certificates or statements furnished by the District or the County to the Underwriter in connection with the issuance and offering of the Series A Bonds (except as such documents otherwise provide). 4. Public Offering of the Bonds. The Underwriter agrees to make a bona fide public offering of all the Series A Bonds at the initial public offering prices or yields to be set forth on the cover page of the Official Statement and Appendix A hereto. Subsequent to such initial public offering, the Underwriter reserves the right to change -2- such public offering prices or yields as it deems necessary in connection with the marketing of the Series A Bonds. The Underwriter hereby certifies to the District (i) that as of the date of sale, all of the Series A Bonds purchased were expected to be reoffered in a bona fide public offering; (ii) that as of the date of the certification, all of the Series A Bonds purchased had actually been offered to the general public at the offering prices shown in Appendix A; and(iii)that the prices given in Appendix A are the maximum initial bona fide offering prices at which a substantial amount (at least 10%) of each maturity of the Series A Bonds purchased was sold to the general public. 5. Review of Official Statement. The Underwriter hereby represents that it has received and reviewed the Preliminary Official Statement with respect to the Series A Bonds, dated June _, 2002 (the Preliminary Official Statement"). The District represents that it deemed the Preliminary Official Statement to be final as of its date, except for either revision or addition of the offering price(s), yield(s) to maturity, selling compensation, aggregate denominational amount and maturity value, denominational amount and maturity value per maturity, delivery date, rating(s) and other terms of the Series A Bonds which depend upon the foregoing as provided in and pursuant to Rule 15c2-12 of the Securities and Exchange Commission under the Securities Exchange Act of 1934, as amended(the "Rule"). The Underwriter agrees that prior to the time the final Official Statement (the "Official Statement") relating to the Series A Bonds is available, the Underwriter will send to any potential purchaser of the Series A Bonds, upon the request of such potential purchaser, a copy of the most recent Preliminary Official Statement. Such Preliminary Official Statement shall be sent by first class mail (or other equally prompt means) not later than the first business day following the date upon which each such request is received. „ The Underwriter hereby represents that it will provide, consistent with the requirements of Municipal Securities Rulemaking Board ("MSRB") Rule G-32, for the delivery of a copy of the Official Statement to each customer who purchases any Series A Bonds during the underwriting period (as such term is defined in MSRB Rule G-11), and deliver a copy of the Official Statement to a national repository on or before the Closing Date, and that it will otherwise comply with all applicable statutes and regulations in connection with the offering and sale of the Series A Bonds, including, without limitation, MSRB Rule G-32 and 17 CFR Section 240.15c2-12, promulgated by the Securities and Exchange Commission("Rule 15c2-12"). -3- References herein to the Preliminary Official Statement and the final Official Statement include the cover page and all appendices, exhibits, maps, reports and statements included therein or attached thereto. 6. Closing. At 8:00 A.M., California Time, on July 2002, or at such other time or on such other date as shall have been mutually agreed upon among the District, the County, and the Underwriter (the "Closing"), the District will cause to be delivered to the 'Underwriter (except as otherwise provided in the Resolutions), at the offices of The Depository Trust Company ("DTC") in New York, New York, or at such other place as may be mutually agreed upon,the Series A Bonds in fully registered book- entry form,duly executed and registered in the name of Cede&Co., as nominee of DTC, and in San Francisco, California, the other documents listed in Section 11 (e) to be delivered by the District or the County; and we will accept such delivery and pay the purchase price thereof in immediately available funds by check, draft or wire transfer to or upon the order of the District, and deliver the other documents listed in Section 11 (e) to be delivered by the Underwriter. 7. Representations, Warranties and Agreements of the District. The District hereby represents, warrants and agrees with the Underwriter that: (a) Due Organization. The District is a school district duly organized and validly existing under the laws of the State of California, with the power to request the issuance of the Series A Bonds pursuant to the Act. (b) Due Authorization. (i) At or prior to the Closing, the District will have taken all action required to be taken by it to authorize the issuance and delivery of the Series A Bonds; (ii) the District has full legal right, power and authority to enter into the Purchase Contract, to adopt the District Resolution, to perform its obligations under the District Resolution and the County Resolution; and(iii)the Purchase Contract constitutes a valid and legally binding obligation of the District. (c) CDjlaoLs. Except for the actions of the parties hereto, no consent, approval, authorization, order, fling, registration, qualification, election or referendum of or by any court or governmental agency or public body whatsoever is required in connection with the issuance, delivery or sale of the Series A Bonds, except for such actions as may be necessary to qualify the Series A Bonds for offer and sale under the Blue Sky or other securities laws and regulations of such states and jurisdictions of the United States as the Underwriter may reasonably request, or which have not been taken or obtained. (d)' lntemal Revenue Code. The District has complied with the Internal Revenue Code of 1986, as amended,with respect to the Series A Bonds. (e)'; No Conflicts. To the best knowledge of the District, the issuance of the Series A Bonds, and the execution, delivery and performance of the -5- Purchase Contract, the Resolutions, and the Series A Bonds, and the compliance with the provisions thereof, do not conflict with or constitute on the part of the District a violation of or default under, the Constitution of the State of California or any existing law, charter, ordinance, regulation, decree, order or resolution and do not conflict with or result in a violation or breach of, or constitute a default under,any agreement, indenture,mortgage, lease or other instrument to which the District is a party or by which it is bound or to which it is subject. (f) ti ti . As of the time of acceptance hereof and based on the advice of Miller, Brown & Dannis ("District Counsel'), no action, suit, proceeding, hearing or investigation is pending or, to the best knowledge of the District, threatened against the District: (i) in any way affecting the existence of the District or in any way challenging the titles of the officials of the District who are required to execute any contracts, certiflcates, or official statements in connection with the delivery of the Series A Bonds to their respective offices, or the powers of those offices; or (ii) seeking to restrain or enjoin the sale, issuance or delivery of any of the Series A Bonds, or the levy or collection of taxes by the County on behalf of the District required to be collected and applied to pay the principal of and interest and compounded interest on the Series A Bonds, or the application thereof, or in any way contesting or affecting the validity or enforceability of the Series A Bonds, the Purchase Contract or the Resolutions or contesting the powers of the District or its authority with respect to the Series A Bonds, the Resolutions or the Purchase Contract; or (iii) in which a final adverse decision could(a)materially adversely affect the operations of the District, or (b) adverselyaffect the exclusion of the interest paid on the Series A Bonds from gross income for federal income tax purposes and the exemption of such interest from California personal income taxation. (g) No Other Debt. Between the date hereof and the Closing, without the prior written consent of the Underwriter, neither the District directly, nor any other governmental agency or other body on behalf of the District, will have issued in the name and on behalf of the District any bonds, notes, or other obligations for borrowed money except for such borrowings as may be described in or contemplated by the Official Statement. (h) Arbitrage Certificate. The District has not been notified of any listing or proposed listing by the Internal Revenue Service to the effect that the District is a bond issuer whose arbitrage certificates may not be relied upon. (i) Continuing Disclosure. To assist the Underwriter in complying with S.E.C. Rule I5c2-12(b)(5), the District will undertake, pursuant to the Resolutions and a Continuing Disclosure Certificate, to provide annual reports -6- and notices of certain events. A description of this undertaking is set forth in the Preliminary Official Statement and will also be set forth in the final Official Statement. 6) Certificates. Any certificates signed by any officer of the District and delivered to the Underwriter shall be deemed a representation by the District to the Underwriter, but not necessarily by the person signing the same, as to the statements made therein. 8. Representations, Warranties and ,Agreements of the County. The County hereby represents, warrants and agrees with the Underwriter that. (a) Due Organization. The County is a political subdivision duly organized and validly existing under the laws of the State of California, with the power to issue the Series A Bonds pursuant to the Act. (b) Due Authorization. (i)At or prior to the Closing, the County will have taken all action required to be taken by it to authorize the issuance and delivery of the Series A Bonds; (ii) the County has full legal right, power and authority to enter into the Purchase Contract, to adopt the County Resolution, to issue and deliver the Series A Bonds to the Underwriter on behalf of the District and to perform its obligations under each such document or instrument; and (iii) the Purchase Contract constitutes a valid and legally binding obligation of the County. (c) No Conflicts. To the best knowledge of the County, the issuance of the Series A Bonds, the execution, delivery and performance of the Purchase Contract, the County Resolution, and the Series A Bonds, and the compliance with the provisions thereof, do not conflict with or constitute on the part of the County a violation of or default under any existing charter, ordinance, or resolution and do not conflict with or result in a violation or breach of, or constitute a default under, any agreement, indenture, mortgage, lease or other instrument to which the County is a party. (d) Lftiggm. As of the time of acceptance hereof, based on the advice of County Counsel, no action, suit, proceeding, hearing or investigation is pending or,to the best knowledge of the County, threatened against the County: (i) in any way affecting the existence of the County, or in any way challenging the respective powers of the several offices whose holder is required to execute the Series A Bonds, or any other contracts, or certificates,required to be executed in connection with the delivery of the Series A Bonds, or of the titles of the officials of the County to such offices; or(ii) seeking to restrain or enjoin the sale, -7- issuance or delivery of any of the Series A Bonds, or the levy or collection of taxes of the District required to be collected and applied to pay the principal of and interest on the Series A Bonds, or the application thereof or, in any way contesting or affecting the validity or enforceability of the Series A Bonds, the Purchase Contract or the County Resolution or contesting the powers of the County or its authority with respect to the Series A Bonds, the County Resolution, or the Purchase Contract, or (iii) in which a final adverse decision could materially adversely affect the operations of the County with respect to the levy and collection of property taxes, the timely payment of debt service on the Series A Bonds. (e) Taxation. Pursuant to the County Resolution and the laws of the State, the County is authorized and required to levy ad valorem property taxes in sufficient amounts for the punctual payment of principal of and interest and compounded interest on the Series A Bonds. (f) No Other Debt. Between the date hereof and the Closing, without the prior written consent of the Underwriter, the County will not have issued in the nameand on behalf of the District any bonds, notes or other obligations for borrowed money except for such borrowings as may be described in or contemplated by the Official Statement. (g) Certificates. Any certificates signed by any officer of the County and delivered to the Underwriter shall be deemed a representation by the County to the Underwriter, but not by the person signing the same, as to the statements made therein. 9. Representations and Agreements of the Underwriter. The Underwriter represents to and agrees with the County and the District that, as of the date hereof and as of the date of the Closing: (a) The Underwriter is duly authorized to execute this Purchase Contract and to take any action under the Purchase Contract required to be taken by it. (b) The Underwriter is in compliance with MSRB Rule G-37 with respect to the County and the District, and is not prohibited thereby from acting as underwriter with respect to securities of the District. (c)' The Underwriter has, and has had, no financial advisory relationship with the District or the County with respect to the Series A Bonds, -8- and no investment firm controlling, controlled by or under common control with the Underwriter has or has had any such financial advisory relationship. (d) The Underwriter has reasonably determined that the District's undertaking to provide continuing disclosure with respect to the Series A Bonds pursuantto Section 11(e)(12) hereof is sufficient to effect compliance with Rule 15c2-12. 10. Covenants of the District. The District covenants and agrees with the Underwriter that. (a) Securiti s Laws. The District will furnish such information, execute such instruments, and take such other action in cooperation with the Underwriter if and as the Underwriter may reasonably request in order to qualify the Series A Bonds for offer and sale under the Blue Sky or other securities laws and regulations of such states and jurisdictions, provided, however, that the District shall not be required to consent to service of process in any jurisdiction in which it is not so subject as of the date hereof; (b) Official Statement. The District hereby agrees to deliver or cause to be delivered to the Underwriter, not later than the seventh (7th) business day following the date the Purchase Contract is signed, copies of a final Official Statement substantially in the form of the Preliminary Official Statement, with only such changes therein as shall have been accepted by the Underwriter and the District in such quantities (including a representative number of originally executed copies)as may be reasonably requested by the Underwriter in order to permit the Underwriter to comply with paragraph (b)(4) of the Rule and with the rules of the Municipal Securities Rulemaking Board. (c) Subsequent Events. The District hereby agrees to notify the Underwriter of any event or occurrence that may affect in any material respect the accuracy or completeness of any information set forth in the Official Statement relating to the District, until the date which is ninety (90) days following the Closing or until such time (if earlier) as the Underwriter shall no longer hold any of the Series A Bonds for sale; (d) Amendments to Off tial Statement. For a period of ninety (90) days after the Closing or until such time (if earlier) as the Underwriter shall no longer hold any of the Series A Bonds for sale, the District will not adopt any amendment of or supplement to the Official Statement to which, after having been furnished with a copy,the Underwriter shall object in writing or which shall be disapproved by the Underwriter, provided that the Underwriter may not -9- unreasonably withhold such approval and that the Underwriter may not object to such amendments or supplements if they result in a correction of the Official Statement; and if any event relating to or affecting the District shall occur as a result of lwhich it is necessary, in the opinion of the Underwriter, to amend or supplement the Official Statement in order to make the Official Statement not misleading in light of the circumstances existing at the time it is delivered to a purchaser, the District shall forthwith prepare and furnish (at the expense of the District) a reasonable number of copies of such amendment or supplement (inform and substance satisfactory to the Underwriter). 11. Conditions to Closing. The Underwriter has entered into the Purchase Contract in reliance upon the representations and warranties of the County and the District contained herein and the performance by the District of its obligations hereunder, both as of the date hereof and as of the date of Closing. The Underwriter's obligations under the Purchase Contract are and shall be subject at the option of the Underwriter,to the following further conditions at the Closing: (a) Representations True. The representations and warranties of the County and the District contained herein shall be true, complete and correct in all material respects at the date hereof and at and as of the Closing as if made at and as of the dosing,and the statements made in all certificates and other documents delivered to the Underwriter at the Closing pursuant hereto shall be true, complete and correct in all material respects on the date of the Closing; and each of the County and the District shall be in compliance with each of the agreements made by it in the Purchase Contract; (b) ObligationsPerformed. At the time of the Closing, (i) the Official Statement, the District Resolution, and the County Resolution shall not have been amended,modified or supplemented except in accordance with Section 10(d) hereof, and (ii) all actions under the Act which, in the opinion of Jones Hall, a Professional Law Corporation, and .Miller Brown & Dannis ("Co-Bond Counsel") shall be necessary in connection with the transactions contemplated hereby,shall have been duly taken and shall be in full force and effect; (c) Adverse Rulings. No decision, ruling or finding shall have been entered by any court or governmental authority since the date of the Purchase Contract (and not reversed on appeal or otherwise set aside), or to the best knowledge of the County or the District,be pending or threatened which has any of the effects described in Section 7(f)or$(d)hereof or contesting in any way the completeness or accuracy of the Official Statement; - 10- (d) -Marketability. Between the date hereof and the Closing, the market price or marketability of the Series A Bonds, or the ability of the Underwriter to enforce contracts for the sale of the Series A Bonds at the initial offering prices set forth in the Official Statement, shall not have been materially adversely affected in the reasonable judgment of the Underwriter (evidenced by a written notice to the County and the District terminating the obligation of the Underwriter to accept delivery of and pay for the Series A Bonds) by reason of any of the following; (1) legislation enacted by or introduced in the Congress or recommended for passage by the President of the United States, or a decision rendered by a court established under Article III of the Constitution of the United States or by the United States Tax Court, or an order, ruling, regulation (final, temporary or proposed) or official statement issued or made: (i) by or on behalf of the United States "Treasury Department, or by or on behalf of the Internal Revenue Service, with the purpose or effect, directly or indirectly, of causing inclusion in gross income for purposes of federal income taxation of the interest received by the owners of the Series A Bonds; or (ii) by or on behalf of the Securities and Exchange Commission,or any other governmental agency having jurisdiction over the subject matter thereof, to the effect that the Series A Bonds, or obligations of the general character of the Series A Bonds, including any and all underlying arrangements, are not exempt from registration under the Securities Act of 1933, as amended; (2) legislation enacted by the legislature of the State of California(the "State"),or a decision rendered by a court of the State, or a ruling, order, or regulation (final or temporary) made by State authority, which would have the.effect of changing, directly or indirectly, the State tax consequences of interest on obligations of the general character of the Series A Bonds in the hands of the holders thereof, or (3) the formal declaration of war by Congress or a new major engagement in or escalation of military hostilities by order of the President of the United States, or the occurrence of any other declared national emergency that interrupts or causes disorder to the operation of - 11 - the financial markets in the United States for a period of more than 30 days; (4) the declaration of a general banking moratorium by federal, New York or California authorities, or the general suspension of trading on any national securities exchange for a period of more than 30 days; (5) the imposition by the New York Stock Exchange, other national securities exchange, or any governmental authority, of any material restrictions not now in force with respect to the Series A Bonds, or obligations of the general character of the Series A Bonds, or securities generally, or the material increase of any such restrictions now in force, including those relating to the extension of credit by, or the charge to the net capital requirements of, the Underwriter; (6) an order, decree or injunction of any court of competent jurisdiction, or order, filing, regulation or official statement by the Securities and Exchange Commission, or any other governmental agency having jurisdiction over the subject matter thereof, issued or made to the effect that the issuance, offering or sale of obligations of the general character of the Series A Bonds, or the issuance, offering or sale of the Series A Bonds, as contemplated hereby or by the Official Statement, is or would be in violation of the federal securities laws, as amended and then in effect; or (7) the withdrawal or downgrading of any rating of the District's outstanding indebtedness by any national rating agency then rating the Series A Bonds. (e) Delivery of Documents. At or prior to the date of the Closing, Co-Bond Counsel shall deliver sufficient copies of the documents listed as items 1-12 below, in each case dated as of the Closing Date and satisfactory in form and substanceto the Underwriter, and the Underwriter shall deliver the documents listed as item 13 below: (1) Bond d inion. An approving opinion of Co-Bond Counsel, as to the validity and tax-exempt status of the Series A Bonds, dated the date of the Closing, addressed to the District; (2) Reliance Letter. A reliance letter from Co-Bond Counsel to the effect that the Underwriter can rely upon the approving opinion described in(e)(1)above; - 12- (3) Certificates of the County. Certificates signed by appropriate officials of the County to the effect that (i) such officials are authorized to execute the Purchase Contract, (ii) the representations and warranties of the County herein are true and correct in all material respects as of the date of Closing, (iii) the County has complied with all the terms of the County Resolution and the Purchase Contract, which are necessary to be complied with prior to or concurrently with the Closing and such documents are in full force and effect, and (iv) the Series A Bonds being delivered on the date of the Closing to the Underwriter under the Purchase Contract substantially conform to the descriptions thereof contained in the County Resolution; The County will provide to the Underwriter a certificate dated as of the Closing stating that it has reviewed "APPL,ICATION OF PROCEEDS OF SERIES A BONDS - Investment of Proceeds of Series A Bonds" and "TAX BASE FOR REPAYMENT OF SERIES A BONDS -- Alternative Method of Tax Apportionment" in the Official Statement and in the Preliminary Official Statement and to the best of its knowledge, as of the Closing,the information set forth therein contains no untrue statement of a material fact or omits to state a material fact required to be stated therein or necessary to make the statements made therein, in the light of the circumstances under which they were made, not misleading in any material respect. (4) Certificates of the District. Certificates signed by appropriate officials of the District to the effect that (i) such officials are authorized to execute the Purchase Contract, (ii) the representations and warranties of the District herein are true and correct in all material respects as of the date of Closing, (iii) the District has complied with all the terms of the District Resolution and the Purchase Contract,. which are necessary to be complied with prior to or concurrently with the Closing and such documents are in full force and effect, and (iv) the District has reviewed the Official Statement and on such basis certifies that the Official Statement(excluding therefrom information regarding DTC and its book-entry only system, information regarding a policy of municipal bond insurance and the provider thereof, information regarding the initial offering of the Series A Bonds and accreted values of the Series A Bonds (if applicable), and information regarding the investment portfolio, policies,practices and valuation procedures of the County Treasurer-Tax Collector, as to which no view is expressed) does not contain any untrue statement of a material fact required to be stated therein or necessary to - 13- make the statements therein, in light of the circumstances in which they were made,not misleading. (5) Arbitrage. A non-arbitrage certificate of the District in a form satisfactory to Co-Bond Counsel; (6) Municipal Bond Insurance. Evidence satisfactory to the Underwriter that the timely payments of all debt service on the Series A Bonds shall have been unconditionally guaranteed by a policy of municipal bond insurance issued by (11 ") (7) Ratings. Evidence satisfactory to the Underwriter that the Series A Bonds shall have been rated "�"by Standard & Poor's Ratings Services and "�" by Fitch Ratings as a result of municipal bond insurance provided by and that any such ratings have not been revoked or downgraded; (8) District Resolution. A certificate, together with copies of the District Resolution, of the Clerk of the District Board of Trustees to the effect that. (i) such copies are true and correct copies of the District Resolution; and (ii) that the District Resolution was duly adopted and has not been amended or rescinded and is in full force and effect on the date of the Closing. (9) District Counsel Opinion. An opinion of Counsel to the District in substantially the form attached as Appendix B; (10) !Qounjy Resolution. A certificate, together with copies of the County Resolution, of the Clerk of the County Board of Supervisors to the effect that: (i) such copies are true and correct copies of the County Resolution; and (ii) the County Resolution was duly adopted and has not been amended or rescinded and is in full force and effect on the date of the Closing; - 14- (11) County Counsel Opinion. An opinion of Counsel to the County in substantially the form attached hereto as Appendix C; (12) Continuing Disclosure Certificate. A Continuing Disclosure Certificate of the District in substantially the form given in the Preliminary Official Statement. (13) Underwriter's Certifications. At or before Closing, and contemporaneously with the acceptance of delivery of the Series A Bonds and the payment of the Purchase Price thereof, the Underwriter will provide to the District: (i) the receipt of the Underwriter, in form satisfactory to the District and the County and signed by an authorized officer of the Underwriter, accepting delivery of the Series A Bonds to the Underwriter and confirming receipt of all documents required by the Underwriter, and the satisfaction of all conditions and terms of this Purchase Contract by the District and the County, respectively, and confirming to the District and the County that as of the Closing Date all of the representations of the Underwriter contained in this Purchase Contract are true, complete and correct in all material respects. (ii) the certification of the Underwriter, in form satisfactory to Co-Bond Counsel, regarding the prices at which the Series A Bonds have been reoffered to the public, as described in Section 3 hereof. (iii) the certification of the Underwriter, in form satisfactory to Co-Bond Counsel, that the present value of the interest saved as a result of the policy of municipal bond insurance with respect to the Series A Bonds issued by exceeds the premium paid for said insurance, and said premium is not unreasonable. (14) Other Documents. Such additional legal opinions, certificates, proceedings, instruments and other documents as the Underwriter or Co-Bond Counsel may reasonably request to evidence (i) compliance by the County and the District with legal requirements, (ii) the truth and accuracy, as of the time of Closing, of the representations of the County and the District herein contained, and (iii) the due performance or satisfaction by the County and the District at or prior to - 15 - such time of all agreements then to be performed and all conditions then to be satisfied by the District; and (f) Termination. Notwithstanding anything to the contrary herein contained, if for any reason whatsoever the Series A Bonds shall not have been delivered by the District to the Underwriter prior to the close of business, Californias Time, on July _, 2002, then the obligation to purchase Series A Bonds hereunder shall terminate and be of no further force or effect. If the County and/or the District shall be unable to satisfy the conditions to the Underwriter's obligations contained in the Purchase Contract or if the Underwriter's obligations shallbe terminated for any reason permitted by the Purchase Contract, the Purchase Contract may be canceled by the Underwriter at, or at any time prior to, the time of Closing.Notice of such cancellation shall be given to the County and the District in writing, or by telephone or telegraph, confirmed in writing. Notwithstanding any provision herein to the contrary, the performance of any and all obligations of the County and the District hereunder and the performance of any and all conditions contained herein for the benefit of the Underwriter may be waived by the Underwriter in writing at its sole discretion. 11. Conditions to Obligations of the County and the District. The performance by the County and the District of their obligations is conditioned upon (i) the performance by the Underwriter of its obligations hereunder; and (ii) receipt by the District of opinions and certificates being delivered at the Closing by persons and entities other than the County and the District. 12. Expenses. The Underwriter shall pay costs of issuance of the Series A Bonds on behalf of the District in the amount of$ , which may be applied to any such costs of issuance at the District's direction, including but not limited to the following: (i) the Underwriter's discount; (ii) the premium for any policy of municipal bond insurance insuring payment of the Series A Bonds; (iii) the cost of the preparation and reproduction of the Resolutions; (iv) the fees and disbursements of Co-Bond Counsel and District Counsel; (v)the cost of the preparation and delivery of the Series A Bonds; (vi)the fees, if any, for bond ratings, including all necessary travel expenses; (vii) the cost of the printing and distribution of the Official Statement; (viii) the initial fees, if any, of the Paying Agent; (ix) the fees and expenses of the County with respect to its participation in the issuance of the Series A Bonds. Any such expenses which exceed in the aggregate$ shall be paid by the District and may be paid from the proceeds of the Series A Bonds. All out-of-pocket expenses of the Underwriter, including the California Debt and Investment Advisory Commission fee, travel and other expenses (except as provided above), shall be paid by the Underwriter. - 16- 13. Indemnification. The Underwriter agrees to indemnify and hold harmless the County and its supervisors, officers, employees and agents, and the District and its directors, officers, employees and agents, from and against any and all losses, claims,damages, liabilities, attorneys' fees and other expenses of every conceivable kind, character or nature whatsoever (including the reasonable costs of investigation) arising out of,resulting from or in any way connected with: (a)any violation or alleged violation in the offering or sale of the Series A Bonds, by the Underwriter, of the Blue Sky, securities or any other laws of any jurisdiction in which any such offering or sale is made; (b) any untrue statement or alleged untrue statement of a material fact or any omission or alleged omission to state a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading, in any text hereafter provided by the Underwriter, without the knowledge and consent of the District, for use in the Official Statement or any supplement or amendment thereto, and which is included therein. (c) the failure of the Underwriter to send or give to any purchaser of any Series A Bonds a copy of the Preliminary Official Statement pursuant to Section 5 of this Purchase Contract and, concurrently with the written confirmation of the sale of such Series A Bonds, the Official Statement (to the extent supplemented or amended, as so supplemented or amended). 14. Notices. Any notice or other communication to be given under the Purchase Contract(other than the acceptance hereof as specified in the first paragraph hereof)may be given by delivering the same in writing if to the County, to the Treasurer- Tax Collector, County of Contra Costa, 625 Court Street, Room 102, Martinez, CA 94553; or if to the District, to the Superintendent,John Swett Unified School District, 341 B Street,Crockett, CA 94525; or if to the Underwriter, to Stone &Youngberg LLC, 50 California Street, San Francisco, California 94111. 15. Parties in Interest; Survival of Representations and Warranties. The Purchase Contract is made solely for the benefit of the County, the District and the Underwriter (including the successors or assigns of the Underwriter). No person shall acquire or have any rights hereunder or by virtue hereof. All representations and warranties of the County and the District in the Purchase Contract shall survive regardless of(a) any investigation or any statement in respect thereof made by or on behalf of the Underwriter, and (b) delivery of and payment by the Underwriter for the Series A Bonds hereunder. - 17- 16. Severability. In the event any provision of this purchase Contract shall be held invalid or unenforceable by any court of competent jurisdiction, such holding shall not invalidate or render unenforceable any other provision thereof. 17. Nonassignment. Notwithstanding anything stated to the contrary herein, neither party hereto may assign or transfer its interest herein, or delegate or transfer any of its obligations hereunder, without the prior consent of the other party hereto. 18. Entire Agreement. This Purchase Contract, when executed by the parties hereto, shall constitute the entire agreement of the parties hereto, including their permitted successors and assigns, respectively. - 18- 19. Execution in Counterparts. The Purchase Contract may be executed in several counterparts each of which shall be regarded as an original and all of which shall constitute but one and the same document. 20. Applicable Lay. The Purchase Contract shall be interpreted, governed and enforced in accordance with the laws of the State of California applicable to contracts made and performed in such State. Very truly yours, Stone & Youngberg LLC By: The foregoing is hereby agreed to and accepted as of the date first above written: County of Contra Costa By: Treasure` Collector John Swett Unified School District By: Superintendent #18159 - 19- APPENDIX A INTEREST RATES, REOFFERING PRICES, MATURITIES, DEBT SERVICE,AND OPTIONAL AND MANDATORY REDEMPTION PROVISIONS JOHN SWETT UNIFIED SCHOOL DISTRICT General Obligation Bonds,Election of 2002, Series A [DEBT SERVICE PAYMENT SCHEDULE] [TO COME] A-5 REDEMPTION PROVISIONS Optional Redemption The Current Interest Series A Bonds maturing on or before August 1, 2011, are not subject to redemption prior to their fixed maturity dates. The Current Interest Series A Bonds maturing on or after August 1, 2012, may be redeemed before maturity at the option of the District, from any source of funds, on August 1, 2011, or on any date thereafter as a whole, or in part on any Bond Payment Date in inverse order of maturity and by lot within a maturity. For the purposes of such selection, Current Interest Series A Bonds will be deemed to consist of$5,000 portions, and any such portion may be separately redeemed. The Current Interest Series A Bonds called prior to maturity will be redeemed at the following redemption prices, expressed as a percentage of par value, together with accrued interest to the date of redemption: Redemption bates (Bates Inclusive) Redemption Price August 1, 2011 through July 31, 2012 101.0% August 1, 2012 and thereafter 100.0% The Capital Appreciation Series A Bonds are not subject to optional redemption prior to their fixed maturity dates. A-5 APPENDIX B FORM OF DISTRICT COUNSEL OPINION JOHN SWETT UNIFIED SCHOOL DISTRICT General Obligation Bonds, Election of 2002, Series A Ladies and Gentlemen: As counsel to the John Swett Unified School District (the "District"), I have reviewed the proceedings relating to the special election of the District held on March 5,2002 (the "Election'), at which the above-described bonds (the "Series A Bonds") were authorized, the Official Statement (the "Official Statement") for the Series A Bonds, the Resolution of the Board of Trustees of the District adopted on June 5, 2002, authorizing the issuance of the Series A Bonds (the "District Resolution"), and the Contract of Purchase relating thereto, dated as of June 2002, by and among the District, County of Contra Costa, and Stone & Youngberg LLC (the "Purchase Contract"). Having reviewed these documents, it is-my opinion that: 1. The District is a school district duly organized and existing under the Constitution and the laws of the State of California. 2. The District Resolution was duly adopted at a meeting of the governing body of the District which was called and held pursuant to law and with all public notice required by law and at which a quorum was present and acting throughout. 3. To the best of my knowledge, there is no action, suit, proceeding or investigation at law or in equity before or by any court, public board or body pending or threatened against or affecting the District which would adversely impact the District's ability to restrain or enjoin the sale, issuance,or delivery of any of the Series A Bonds, or the levy or collection of tax revenues pledged for the Series A Bonds or in any way contesting or affecting the validity of the Election, the Purchase Contract, the District Resolution or the Series A Bonds wherein an unfavorable decision, ruling or finding would adversely affect the validity and enforceability of the Election, the Purchase Contract, the District Resolution or the Series A Bonds or in which a final adverse decision could materially adversely affect the operations of the District. B-1 4. To the best of my knowledge, the obligations of the District under the Series A Bonds, and compliance with the provisions thereof, and the approval of the Official Statement and the execution of and performance of the provisions of the Purchase Contract, under the circumstances contemplated thereby,do not and will not in any material respect conflict with or constitute on the part of the District a breach of or default under any agreement or other instrument to which the District is a party or by which it is bound or any existing law, regulation court order or consent decree to which the District is subject. 5. The Election was validly ordered and the proceedings relating thereto were conducted in compliance with all requirements of the Constitution and the laws of the State of California. 6. Other than the official actions of the District and the County, no authorization, approval, consent, or other order of the State of California, or other governmental authority or agency within the State of California, is required for the valid authorization of the Series A Bonds,the execution of the Purchase Contract or the approval of the Official Statement. Very truly yours, B-2 APPENDIX C OPINION OF COUNTY COUNSEL JOHN S'WETT UNIFIED SCHOOL DISTRICT General Obligation Bonds,Election of 2402,Series A Ladies and Gentlemen: As counsel to the Board of Supervisors (the "Board") of County of Contra Costa,California (the "County"), I have reviewed the Resolution of the Board adopted on June 18, 2002, with respect to the above-described bonds (the "Series A Bonds") (the "County Resolution"), and the Contract of Purchase relating thereto, dated as of June 2402, by and among the John Swett Unified School District (the "District"), the County and Stone & Youngberg LLC, as underwriter(the "Purchase Contract"). Having reviewed these documents, it is my opinion that: 1. The County is a political subdivision duly organized and existing pursuant to the Constitution and the laws of the State of California. 2. The County Resolution was duly adopted at a meeting of the governing body of the County which was called and held pursuant to law and with all public notice required by law and at which a quorum was present and acting throughout. 3. To best of my knowledge, there is no action, suit, proceeding or investigation at law or in equity before or by any court, public board or body pending or threatened against the County wherein an unfavorable decision, ruling or finding would restrain or enjoin the levy or collection of tax revenues pledged for the Series A Bonds or the application of such tax revenues for payment of the Series A Bonds, or adversely affect the validity and enforceability of the County Resolution, the Purchase Contract or the Series A Bonds . 4. To best of my knowledge,the issuance of the Series A Bonds and the execution of and performance by the County of the acts of the County (or its officers) required by the Purchase Contract, under the circumstances contemplated thereby, do not and will not in any material respect conflict with or constitute on the part of the County a breach of or default under any agreement to which the County is a party. C-1 Very truly yours, C-2