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HomeMy WebLinkAboutMINUTES - 02062001 - SD.4 BOARD OF SUPERVISORS OF THE COUNTY OF CONTRA COSTA RESOLUTION NO. 2001 149 RESOLUTION AUTHORIZING THE ISSUANCE OF COUNTY OF CONTRA COSTA TAXABLE PENSION OBLIGATION BONDS, REFUNDING SERIES 20015 APPROVING THE FORM OF AND AUTHORIZING THE EXECUTION AND DELIVERY OF A FIRST SUPPLEMENTAL TRUST AGREEMENT, A BOND PURCHASE CONTRACT, AN ESCROW AGREEMENT, A REMARKETING AGREEMENT, A STANDBY BOND PURCHASE AGREEMENT, A DEALER MANAGER AGREEMENT AND APPROVING AN OFFICIAL STATEMENT FOR SAID BONDS AND AUTHORIZING A TENDER OFFER OF THE COUNTY'S TAXABLE PENSION OBLIGATION BONDS, 1994 SERIES A AND OTHER ACTIONS RELATING THERETO WHEREAS, the COUNTY OF CONTRA COSTA-(the"County") adopted a retirement plan under the County Employees Retirement Law of 1937, being Division 4 of Title 3 of the Government Code of the State of California, Sections 31450 through 31898, inclusive, as amended (the "Retirement Law"); and WHEREAS, the Retirement Law obligates the County to (1)make annual contributions to the Contra Costa County Employees.Retirement Association(the "Association"), to fund pension benefits for its employees, (2) amortize the unfunded accrued actuarial liability with respect to such pension benefits over a period not exceeding 30 years, and (3) appropriate funds for the purposes described in(1) and(2); and WHEREAS, the County in 1994 evidenced its obligations to the Association to pay the then-current unfunded accrued actuarial liability("UAAL") of the County,by issuing a debenture (the "1994 Debenture") to the Association and authorized the issuance of additional debentures in the future from time to time; and WHEREAS, the County issued its Taxable Pension Obligations, 1994 Series A (the 1994 Series A Bonds") in an aggregate principal amount of$337,365,000 for the purpose of refunding the 1994 Debenture, thereby providing a lower interest rate on the County's outstanding obligations than charged to the County's then-current UAAL, and authorized the issuance of additional bonds in the future from time to time; and WHEREAS, the County has determined it is in its best interest to refund a portion of the 1994 Series A Bonds by the issuance of refunding bonds(the"Bonds") on a parity with the 1994 Series A Bonds; and DOCSSFI:468618.4 WHEREAS, the 1994 Series A Bonds are not subject to optional redemption so the County has determined to extend a tender offer to the owners of the 1994 Series A Bonds and to defease a portion of the 1994 Series A Bonds if insufficient tenders are received; and. WHEREAS, there are on file with the Clerk of the Board of Supervisors the proposed forms of the following documents: (i) a First Supplemental Trust Agreement (the"Supplemental Trust Agreement") to be entered into between the County and BNY Western Trust Company, successor to First Interstate Bank of California, as trustee (the "Trustee"), which Supplemental Trust Agreement supplements and amends the Trust Agreement, dated as of February 1, 1994 (collectively, the"Trust Agreement"), under which the 1994 Series A Bonds were issued; (ii) a Remarketing Agreement (the"Remarketing Agreement") to be entered into between the County and Bear, Stearns & Co. Inc., as remarketing agent; (iii) an Escrow Agreement to be entered into between the County and the Trustee; (iv) a Preliminary Official Statement; (v) a Bond Purchase Contract to be entered into between the County and Bear, Stearns & Co. Inc. (the "Underwriter"); (vi) a Standby Bond Purchase Agreement to be entered into between the County and Westdeutsche Landesbank Girozentrale, acting through its New York Branch. (vii) a Dealer Manager Agreement to be entered into between the County and Bear, Stearns & Co. Inc.; and (viii) an Invitation to Tender Bonds; NOW, THEREFORE, IT IS RESOLVED, DETERMINED AND ORDERED by the Board of Supervisors of the County of Contra Costa(the"Board"), as follows: Section 1. All of the above recitals are true and correct and the Board hereby so finds and determines: Section 2. The Board hereby authorizes and approves the issuance of the Bonds and hereby authorizes and directs the Chair of the Board and the Treasurer-Tax Collector to execute the Bonds, and the Clerk of the Board to affix and attest the seal of the County and to cause the Bonds to be authenticated and delivered in accordance with the Trust Agreement. The Bonds shall be in substantially the form set forth in Exhibit A to the Supplemental Trust Agreement, with such changes therein, deletions therefrom and additions thereto as the Chair of the Board and the Treasurer-Tax Collector shall approve, such approval to be conclusively evidenced by the execution and delivery of the Bonds; the Bonds may be issued in a single series or in two or DOCSSF1:468618.4 2 more series and as fixed or variable rate Bonds, provided, however, that the aggregate principal amount of the Bonds shall not exceed $125,000,000, the Bonds shall bear interest at a fixed or variable rate, not to exceed the Maximum Rate(as defined in the Supplemental Trust Agreement), the Bonds shall be dated their date of issuance or such other date specified in the Supplemental Trust Agreement and the Bonds shall mature not later than June 1, 2014. The Bonds shall constitute an obligation imposed by law, pursuant to the Constitution of the State of California and the Retirement Law and an obligation of the County not limited as to payment from any special source of funds. The Bonds shall not, however, constitute an obligation of the County for which the County is obligated or permitted to levy or pledge any form of taxation or for which the County has levied or pledged or will levy or pledge any form of taxation. Section 3. The Board hereby authorizes and approves the execution and delivery of the proposed form of Supplemental Trust Agreement between the County and the Trustee, on file with the Clerk of the Board. The Chair of the Board is hereby authorized and directed to execute and deliver the Supplemental Trust Agreement on behalf of the County, substantially in the form on file with the Clerk of the Board, with such changes therein, deletions therefrom and additions thereto as the Chair shall approve, such approval to be conclusively evidenced by the execution and delivery of the Supplemental Trust Agreement, and the Clerk of the Board is authorized and directed to affix and attest the seal of the County thereto. Section 4. The Board hereby authorizes and approves the Preliminary Official Statement, relating to the Bonds, on file with the Clerk of the Board, and approves the distribution of the Preliminary Official Statement by the Underwriter to potential purchasers of the Bonds. The County Administrator or his designee is hereby authorized and directed to execute the final Official Statement with such changes therein, deletions therefrom and additions thereto as the County Administrator or his designee shall approve, such approval to be conclusively evidenced by the execution and delivery of the final Official Statement. Distribution of the final Official Statement by the Underwriters to actual purchasers of Bonds is hereby authorized and approved. Section 5. The Board hereby authorizes and approves the execution and delivery of the proposed form of Bond Purchase Contract, to be dated the date of sale of the Bonds (the "Purchase Contract"), between the County and the Underwriter, on file with the Clerk of the Board. The County Administrator or his designee is hereby authorized and directed to execute and deliver the Bond Purchase Contract, substantially in the form on file with the Clerk of the Board, with such changes therein, deletions therefrom and additions thereto as the County Administrator or his designee shall approve, such approval to be conclusively evidenced by the execution and delivery of the Bond Purchase Contract; provided that the underwriters' discount on the Bonds (exclusive of any original issue.discount) shall not exceed two percent (2%) of the principal amount of the Bonds. Section 6. The Board hereby authorizes and approves the execution and delivery of the proposed form of Remarketing Agreement,between the County and Bear, Stearns & Co. Inc., as remarketing agent for the Bonds, on file with the Clerk of the Board. If the Bonds are issued as variable rate Bonds, the County Administrator or his designee is hereby authorized and directed to execute and deliver the Remarketing Agreement on behalf of the County, substantially in the form on file with the Clerk of the Board,with such changes therein, deletions therefrom and DOCSSF1:468618.4 3 additions thereto as the County Administrator or his designee shall approve, such approval to be conclusively evidenced by the execution and delivery of the Remarketing Agreement. Section 7. The Board hereby authorizes and approves the execution and delivery of the proposed form of Dealer Manager Agreement, between the County and Bear, Stearns & Co. Inc., as dealer manager of the tender offer for the 1994 Series A Bonds, on file with the Clerk of the Board. The County Administrator or his designee is hereby authorized and directed to execute and deliver the Dealer Manager Agreement on behalf of the County, substantially in the form on file with the Clerk of the Board, with such changes therein, deletions therefrom and additions thereto as the County Administrator or his designee shall approve, such approval to be conclusively evidenced by the execution and delivery of the Dealer Manager Agreement. Section 8. The Board hereby authorizes and approves the execution and delivery of the proposed form of Standby Bond Purchase Agreement,between the County and Westdeutsche Landesbank Girozentrale, in order to provide liquidity for the Bonds, on file with the Clerk of the Board. If the Bonds are issued as variable rate Bonds, the County Administrator or his designee is hereby authorized and directed to execute and deliver the Standby Bond Purchase Agreement on behalf of the County, substantially in the form on file with the Clerk of the Board, with such changes therein, deletions therefrom and additions thereto as the County Administrator or his designee shall approve, such approval to be conclusively evidenced by the execution and delivery of the Standby Bond Purchase Agreement. Section 9. The Board hereby authorizes and approves the execution and delivery of the proposed form of an Invitation to Tender Bonds on file with the Clerk of the Board. The County Administrator or his designee is hereby authorized and directed to execute and deliver the Invitation to Tender Bonds on behalf of the County, substantially in the form on file with the Clerk of the Board, with such changes therein, deletions therefrom and additions thereto as the County Administrator or his designee shall approve, such approval to be conclusively evidenced by the execution and delivery of the Invitation to Tender Bonds. Such officers are hereby further authorized to take such actions and execute such contracts and certificates as are necessary to extend the Invitation to Tender as contemplated therein, including, but not limited to, contracts with Bondholder Communications Group, as information agent for such tender. Section 10. The Board hereby authorizes and approves the execution and delivery of the proposed form of Escrow Agreement, between the County and the Trustee, on file with the Clerk of the Board. In the event the County Administrator determines that portions of the 1994 Series A Bonds need to be defeased to accommodate the restructuring of the County's debt in connection with or in lieu of the tender, the County Administrator or his designee is hereby authorized and directed to execute and deliver the Escrow Agreement on behalf of the County, substantially in the form on file with the Clerk of the Board,with such changes therein, deletions therefrom and additions thereto as the County Administrator or his designee shall approve, such approval to be conclusively evidenced by the execution and delivery of the Escrow Agreement and in connection thereafter to execute or authorize the Trustee to execute escrow float agreements and purchase securities for such escrow (the "Escrow Investments"). Section 11. The County Administrator or his designee is hereby authorized to execute and deliver on behalf of the County an interest rate swap agreement and/or a hedging agreement DOCSSF1:46861 R.4 4 and/or any other form of derivative agreement or arrangement with an institutional party; provided, however, that the institutional party or its guarantor shall have a long-term credit rating by at least one national credit agency equal to AA, the term of the swap agreement, derivative agreement or hedging agreement shall not exceed the term of the Bonds, the County's obligations shall be contingent upon certain performance by the counterparty to the agreement or arrangement and that the County will have the right to terminate the agreement or arrangement upon the occurrence of certain circumstances. The Board hereby finds and determines that such agreements or arrangements will result in a lower cost of borrowing to the County. Section 12. The Board hereby authorizes the County Administrator or his designee to enter into one or more investment agreements on behalf of the County providing for the investment of moneys in the funds and accounts created under the.Trust Agreement, as the County Administrator or his designee deems appropriate, including the amendment, termination or revision of the Debt Service Forward Delivery Agreement among the County, the Trustee and Credit Suisse Financial Products, dated as of March 1, 1994 (collectively, the "Investment Agreement"). The Board hereby finds and determines pursuant to Government Code section 5922, that the Investment Agreement and Escrow Investments will reduce the amount and duration of interest rate risk with respect to amounts invested pursuant to such agreements. The County Administrator or his designee is hereby authorized and directed to execute and deliver the Investment Agreement and any other related agreement or agreements on behalf of the County as may be approved by the County Administrator or his designee, such approval to be conclusively evidenced by the execution and delivery of such agreement or agreements. Any termination amounts required to be paid by the County with respect to the Investment Agreement shall be paid from proceeds of the Bonds or amounts invested pursuant thereto. Any termination amounts or up front payments received with respect to the Investment Agreement will be applied as provided in the Trust Agreement. Section 13. The supervisors, officers and employees of the County are hereby authorized and directed,jointly and severally, to do any and all things which they may deem necessary or advisable in order to consummate the transactions herein authorized and otherwise to carry out, give effect to and comply with the terms and intent of this Resolution. The Chair of the Board of Supervisors, the Clerk of the Board, the County Administrator and the Director, Capital Facilities and Debt Management, in her official capacity and as designee of the County Administrator(the "Director"), and the other officers and employees of the County are hereby authorized and directed to execute and deliver any and all documents, certificates and representations, including, but not limited to, signature certificates, no-litigation certificates and certificates concerning the official statement describing the Bonds, necessary or desirable to accomplish the transactions set forth above. If either the Chair of the Board or the Clerk of the Board and County Administrator is unavailable at the time the documents authorized herein are to be executed and attested, such documents may be executed by the'Vice-Chair of the Board, a Deputy Clerk or the Director, respectively, with the same effect as if executed by the Chair of the Board or the Clerk of the Board and the County Administrator. Section 14. All actions heretofore taken by the supervisors, officers and agents of the County with respect to the execution and delivery of the Bonds and the other transactions authorized and contemplated herein are hereby approved, confirmed and ratified. 1)OCSSF1:468618.4 5 I CLERK'S CERTIFICATE Deputy Clerk of the Board of Supervisors of the County of Contra Costa(the"County"),hereby certify as follows: The foregoing is a full, true and correct copy of a resolution duly adopted at a regular meeting of the Board of Supervisors of said County duly and regularly held at the regular meeting place thereof on the day of , 2001, of which meeting all of the members of said Board of Supervisors had due notice and at which a majority thereof was present; and at said meeting said resolution was adopted by the following vote: AYES: NOES: ABSTENTIONS: An agenda of said meeting was posted at least 96 hours before said meeting in Martinez, California, at a location freely accessible to members of the public, and a brief general description of said resolution appeared on said agenda. I have carefully compared the same with the original minutes of said meeting on file and of record in my office; the foregoing resolution is a full, true and correct copy of the original resolution adopted at said meeting and entered in said minutes; and 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. WITNESS my hand and the seal of the County of Contra Costa this day of 12001. Deputy Clerk of the Board of Supervisors of the County of Contra Costa, State of California [Seal] DOCSSF1:468618.4 7 Section 15. This Resolution shall take effect from and after its date of adoption. PASSED AND ADOPTED this 6th day of February , 2001 by the following vote: AYES: SUPERVISORS GIOIA, GERBER, DESAULNIER, GLOVER and UILKEMA NOES: NONE ABSENT: NONE ABSTAIN: NONE Chair oft oard of Supervisors, County of Contra Costa, California A 1.TES ;.Philip J. Batchelor, Clerk 'of the Board of Supervisors and County Administrator By Deputy Clerk of the Board of Supervisors of the County of Contra Costa, State of California DOCSSF1-468618.4 6 Resolution 2001/49 CLERK'S CERTIFICATE I, June L. McHuen , Deputy Clerk of the Board of Supervisors of the County of Contra Costa(the"County"), hereby certify as follows: The foregoing is a full, true and correct copy of a resolution duly adopted at a regular meeting of the Board of Supervisors of said County duly and regularly held at the regular meeting place thereof on the 6th day of February , 2001, of which meeting all of the members of said Board of Supervisors had due notice and at which a majority thereof was present; and at said meeting said resolution was adopted by the following vote: AYES: SUPERVISORS GIOIA, GERBER, DESAULNIER, GLOVER and.'.:UILKEMA NOES: NONE ABSTENTIONS: NONE An agenda of said meeting was posted at least 96 hours before said meeting in Martinez, California, at a location freely accessible to members of the public, and a brief general description of said resolution appeared on said agenda. I have carefully compared the same with the original minutes of said meeting on file and of record in my office; the foregoing resolution is a full, true and correct copy of the original resolution adopted at said meeting and entered in said minutes; and 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. WITNESS my hand and the seal of the County of Contra Costa this 6th day of FPh� r„aT, 2001. _Deputy Clerk of the Board of Supervisors of the County of Contra Costa, State of California [Seal] DOCSSF1:468618.4 7 RESOLUTION NO. 2001/49 BOARD OF SUPERVISORS OF THE COUNTY OF CONTRA COSTA RESOLUTION NO. 20011/49 RESOLUTION AUTHORIZING THE ISSUANCE OF COUNTY OF CONTRA COSTA TAXABLE PENSION OBLIGATION BONDS, REFUNDING SERIES 2001, APPROVING THE FORM OF AND AUTHORIZING THE EXECUTION AND DELIVERY OF A FIRST SUPPLEMENTAL TRUST AGREEMENT, A BOND PURCHASE CONTRACT, AN ESCROW AGREEMENT, A REMARKETING AGREEMENT, A STANDBY BOND PURCHASE AGREEMENT, A DEALER MANAGER AGREEMENT AND APPROVING AN OFFICIAL STATEMENT FOR SAID BONDS AND AUTHORIZING A TENDER OFFER OF THE COUNTY'S TAXABLE PENSION OBLIGATION BONDS, 1994 SERIES A AND OTHER ACTIONS RELATING THERETO WHEREAS, the COUNTY OF CONTRA COSTA (the "County") adopted a retirement plan under the County Employees Retirement Law of 1937, being Division 4 of Title 3 of the Government Code of the State of California, Sections 31450 through 31898, inclusive, as amended (the "Retirement Law"); and WHEREAS, the Retirement Law obligates the County to (1)make annual contributions to the Contra Costa County Employees Retirement Association(the"Association"), to fund pension benefits for its employees, (2) amortize the unfunded accrued actuarial liability with respect to such pension benefits over a period not exceeding 30 years, and (3) appropriate funds for the purposes described in (1) and (2); and WHEREAS, the County in 1994 evidenced its obligations to the Association to pay the then-current unfunded accrued actuarial liability("UAAL") of the County, by issuing a debenture (the"1994 Debenture") to the Association and authorized the issuance of additional debentures in the future from time to time; and WHEREAS, the County issued its Taxable Pension Obligations, 1994 Series A (the "1994 Series A Bonds") in an aggregate principal amount of$337,365,000 for the purpose of refunding the 1994 Debenture, thereby providing a lower interest rate on the County's outstanding obligations than charged to the County's then-current UAAL, and authorized the issuance of additional bonds in the future from time to time; and WHEREAS, the County has determined it is in its best interest to refund a portion of the 1994 Series A Bonds by the issuance of refunding bonds (the"Bonds") on a parity with the 1994 Series A Bonds; and DOCSSF1:468618.4 WHEREAS, the 1994 Series A Bonds are not subject to optional redemption so the County has determined to extend a tender offer to the owners of the 1994 Series A Bonds and to defease a portion of the 1994 Series A Bonds if insufficient tenders are received; and. WHEREAS, there are on file with the Clerk of the Board of Supervisors the proposed forms of the following documents: (i) a First Supplemental Trust Agreement(the "Supplemental Trust Agreement") to be entered into between the County and BNY Western Trust Company, successor to First Interstate Bank of California, as trustee (the"Trustee"), which Supplemental Trust Agreement supplements and amends the Trust Agreement, dated as of February 1, 1994 (collectively, the "Trust Agreement"), under which the 1994 Series A Bonds were issued; (ii) a Remarketing Agreement (the"Remarketing Agreement") to be entered into between the County and Bear, Stearns & Co. Inc., as remarketing agent; (iii) an Escrow Agreement to be entered into between the County and the Trustee; (iv) a Preliminary Official Statement; (v) a Bond Purchase Contract to be entered into between the County and Bear, Stearns & Co. Inc. (the "Underwriter"); (vi) a Standby Bond Purchase Agreement to be entered into between the County and Westdeutsche Landesbank Girozentrale, acting through its New York Branch. (vii) a Dealer Manager Agreement to be entered into between the County and Bear, Stearns & Co. Inc.; and (viii) an Invitation to Tender Bonds; NOW, THEREFORE, IT IS RESOLVED, DETERMINED AND ORDERED by the Board of Supervisors of the County of Contra Costa(the "Board"), as follows: Section 1. All of the above recitals are true and correct and the Board hereby so finds and determines: Section 2. The Board hereby authorizes and approves the issuance of the Bonds and hereby authorizes and directs the Chair of the Board and the Treasurer-Tax Collector to execute the Bonds, and the Clerk of the Board to affix and attest the seal of the County and to cause the Bonds to be authenticated and delivered in accordance with the Trust Agreement. The Bonds shall be in substantially the form set forth in Exhibit A to the Supplemental Trust Agreement, with such changes therein, deletions therefrom and additions thereto as the Chair of the Board and the Treasurer-Tax Collector shall approve, such approval to be conclusively evidenced by the execution and delivery of the Bonds; the Bonds may be issued in a single series or in two or DOC:SSF1.468618.4 2 more series and as fixed or variable rate Bonds, provided, however, that the aggregate principal amount of the Bonds shall not exceed $125,000,000, the Bonds shall bear interest at a fixed or variable rate, not to exceed the Maximum Rate (as defined in the Supplemental Trust Agreement), the Bonds shall be dated their date of issuance or such other date specified in the Supplemental Trust Agreement and the Bonds shall mature not later than June 1, 2014. The Bonds shall constitute an obligation imposed by law, pursuant to the Constitution of the State of California and the Retirement Law and an obligation of the County not limited as to payment from any special source of funds. The Bonds shall not, however, constitute an obligation of the County for which the County is obligated or permitted to levy or pledge any form of taxation or for which the County has levied or pledged or will levy or pledge any form of taxation. Section 3. The Board hereby authorizes and approves the execution and delivery of the proposed form of Supplemental Trust Agreement between the County and the Trustee, on file with the Clerk of the Board. The Chair of the Board is hereby authorized and directed to execute and deliver the Supplemental Trust Agreement on behalf of the County, substantially in the form on file with the Clerk of the Board, with such changes therein, deletions therefrom and additions thereto as the Chair shall approve, such approval to be conclusively evidenced by the execution and delivery of the Supplemental Trust Agreement, and the Clerk of the Board is authorized and directed to affix and attest the seal of the County thereto. Section 4. The Board hereby authorizes and approves the Preliminary Official Statement, relating to the Bonds, on file with the Clerk of the Board, and approves the distribution of the Preliminary Official Statement by the Underwriter to potential purchasers of the Bonds. The County Administrator or his designee is hereby authorized and directed to execute the final Official Statement with such changes therein, deletions therefrom and additions thereto as the County Administrator or his designee shall approve, such approval to be conclusively evidenced by the execution and delivery of the final Official Statement. Distribution of the final Official Statement by the Underwriters to actual purchasers of Bonds is hereby authorized and approved. Section 5. The Board hereby authorizes and approves the execution and delivery of the proposed form of Bond Purchase Contract, to be dated the date of sale of the Bonds (the "Purchase Contract"), between the County and the Underwriter, on file with the Clerk of the Board. The County Administrator or his designee is hereby authorized and directed to execute and deliver the Bond Purchase Contract; substantially in the form on file with the Clerk of the Board, with such changes therein, deletions therefrom and additions thereto as the County Administrator or his designee shall approve, such approval to be conclusively evidenced by the execution and delivery of the Bond Purchase Contract; provided that the underwriters' discount on the Bonds (exclusive of any original issue discount) shall not exceed two percent(2%) of the principal amount of the Bonds. Section 6. The Board hereby authorizes and approves the execution and delivery of the proposed form of Remarketing Agreement, between the County and Bear, Stearns & Co. Inc., as remarketing agent for the Bonds, on file with the Clerk of the Board. If the Bonds are issued as variable rate Bonds, the County Administrator or his designee is hereby authorized and directed to execute and deliver the Remarketing Agreement on behalf of the County, substantially in the form on file with the Clerk of the Board,with such changes therein, deletions therefrom and UOCSSF1:468618.4 3 additions thereto as the County Administrator or his designee shall approve, such approval to be conclusively evidenced by the execution and delivery of the Remarketing Agreement. Section 7. The Board hereby authorizes and approves the execution and delivery of the proposed form of Dealer Manager Agreement,between the County and Bear, Stearns & Co. Inc., as dealer manager of the tender offer for the 1994 Series A Bonds, on file with the Clerk of the Board. The County Administrator or his designee is hereby authorized and directed to execute and deliver the Dealer Manager Agreement on behalf of the County, substantially in the form on file with the Clerk of the Board, with such changes therein, deletions therefrom and additions thereto as the County Administrator or his designee shall approve, such approval to be conclusively evidenced by the execution and delivery of the Dealer Manager Agreement. . Section 8. The Board hereby authorizes and approves the execution and delivery of the proposed form of Standby Bond Purchase Agreement, between the County and Westdeutsche Landesbank Girozentrale, in order to provide liquidity for the Bonds, on file with the Clerk of the Board. If the Bonds are issued as variable rate Bonds, the County Administrator or his designee is hereby authorized and directed to execute and deliver the Standby Bond Purchase Agreement on behalf of the County, substantially in the form on file with the Clerk of the Board, with such changes therein, deletions therefrom and additions thereto as the County Administrator or his designee shall approve, such approval to be conclusively evidenced by the execution and delivery of the Standby Bond Purchase Agreement. Section 9. The Board hereby authorizes and approves the execution and delivery of the proposed form of an Invitation to Tender Bonds on file with the Clerk of the Board. The County Administrator or his designee is hereby authorized and directed to execute and deliver the Invitation to Tender Bonds on behalf of the County, substantially in the form on file with the Clerk of the Board, with such changes therein, deletions therefrom and additions thereto as the County Administrator or his designee shall approve, such approval to be conclusively evidenced by the execution and delivery of the Invitation to Tender Bonds. Such officers are hereby further authorized to take such actions and execute such contracts and certificates as are necessary to extend the Invitation to Tender as contemplated therein, including, but not limited to, contracts with Bondholder Communications Group, as information agent for such tender. Section 10. The Board hereby authorizes and approves the execution and delivery of the proposed form of Escrow Agreement,between the County and the Trustee, on file with the Clerk of the Board. In the event the County Administrator determines that portions of the 1994 Series A Bonds need to be defeased to accommodate the restructuring of the County's debt in connection with or in lieu of the tender, the County Administrator or his designee is hereby authorized and directed to execute and deliver the Escrow Agreement on behalf of the County, substantially in the form on file with the Clerk of the Board, with such changes therein, deletions therefrom and additions thereto as the County Administrator or his designee shall approve, such approval to be conclusively evidenced by the execution and delivery of the Escrow Agreement and in connection thereafter to execute or authorize the Trustee to execute escrow float agreements and purchase securities for such escrow(the"Escrow Investments"). Section 11. The County Administrator or his designee is hereby authorized to execute and deliver on behalf of the County an interest rate swap agreement and/or a hedging agreement UOCSSF1:468618.4 4 and/or any other form of derivative agreement or arrangement with an institutional party; provided, however, that the institutional party or its guarantor shall have a long-term credit rating by at least one national credit agency equal to AA, the term of the swap agreement, derivative agreement or hedging agreement shall not exceed the term of the Bonds, the County's obligations shall be contingent upon certain performance by the counterparty to the agreement or arrangement and that the County will have the right to terminate the agreement or arrangement upon the occurrence of certain circumstances. The Board hereby finds and determines that such agreements or arrangements will result in a lower cost of borrowing to the County. Section 12. The Board hereby authorizes the County Administrator or his designee to enter into one or more investment agreements on behalf of the County providing for the investment of moneys in the funds and accounts created under the Trust Agreement, as the County Administrator or his designee deems appropriate, including the amendment, termination or revision of the Debt Service Forward Delivery Agreement among the County, the Trustee and Credit Suisse Financial Products, dated as of March 1, 1994 (collectively, the"Investment Agreement"). The Board hereby finds and determines pursuant to Government Code section 5922, that the Investment Agreement and Escrow Investments will reduce the amount and duration of interest rate risk with respect to amounts invested pursuant to such agreements. The County Administrator or his designee is hereby authorized and directed to execute and deliver the Investment Agreement and any other related agreement or agreements on behalf of the County as may be approved by the County Administrator or his designee, such approval to be conclusively evidenced by the execution and delivery of such agreement or agreements. Any termination amounts required to be paid by the County with respect to the Investment Agreement shall be paid from proceeds of the Bonds or amounts invested pursuant thereto. Any termination amounts or up front payments received with respect to the Investment Agreement will be applied as provided in the Trust Agreement. Section 13. The supervisors, officers and employees of the County are hereby authorized and directed,jointly and severally, to do any and all things which they may deem necessary or advisable in order to consummate the transactions herein authorized and otherwise to carry out, give effect to and comply with the terms and intent of this Resolution. The Chair of the Board of Supervisors, the Clerk of the Board, the County Administrator and the Director, Capital Facilities and Debt Management, in her official capacity and as designee of the County Administrator(the "Director"), and the other officers and employees of the County are hereby authorized and directed to execute and deliver any and all documents, certificates and representations, including, but not limited to, signature certificates, no-litigation certificates and certificates concerning the official statement describing the Bonds, necessary or desirable to accomplish the transactions set forth above. If either the Chair of the Board or the Clerk of the Board and County Administrator is unavailable at the time the documents authorized herein are to be executed and attested, such documents may be executed by the Vice-Chair of the Board, a Deputy Clerk or the Director, respectively, with the same effect as if executed by the Chair of the Board or the Clerk of the Board and the County Administrator. Section 14. All actions heretofore taken by the supervisors, officers and agents of the County with respect to the execution and delivery of the Bonds and the other transactions authorized and contemplated herein are hereby approved, confirmed and ratified. DOC:SSF1:468618.4 5 Section 15. This Resolution shall take effect from and after its date of adoption. PASSED AND ADOPTED this 6th day of February , 2001 by the following vote: AYES: SUPERVISORS GIOIA, GERBER, DESAULNIER, GLOVER and UILKEMA NOES: NONE ABSENT: NONE ABSTAIN: NONE Chair oft oard of Supervisors, County of Contra Costa, California I Seal] ATTEST: Philip J. Batchelor, Clerk of the Board of Supervisors and County Administrator B)Deputy Clerk of the Board of Supervisors of the County of Contra Costa, State of California DOCSSF1:468618.4 6 Resolution 2001/49 CLERK'S CERTIFICATE 1, June L. McHuen , Deputy Clerk of the Board of Supervisors of the County of Contra Costa(the"County"), hereby certify as follows: The foregoing is a full, true and correct copy of a resolution duly adopted at a regular meeting of the Board of Supervisors of said County duly and regularly held at the regular meeting place thereof on the 6th day of February , 2001, of which meeting all of the members of said Board of Supervisors had due notice and at which a majority thereof was present; and at said meeting said resolution was adopted by the following vote: AYES: SUPERVISORS GIOIA, GERBER, DESAULNIER, GLOVER and'UILKEMA NOES: NONE ABSTENTIONS: NONE An agenda of said meeting was posted at least 96 hours before said meeting in Martinez, California, at a location freely accessible to members of the public, and a brief general description of said resolution appeared on said agenda. I have carefully compared the same with the original minutes of said meeting on file and of record in my office; the foregoing resolution is a full, true and correct copy of the original resolution adopted at said meeting and entered in said minutes; and 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. WITNESS my hand and the seal of the County of Contra Costa this 6th day of FPbr„�v_, 2001. 61 Deputy Clerk of the Board of Supervisors - of the County of Contra Costa, State of California [Seal]_ -- DOCSSF1:468618.4 7 RESOLUTION NO. 2001/49 S!7 V a -('11610/ COUNTY OF CONTRA COSTA, CALIFORNIA Taxable Pension Obligation Bonds, - - Refunding Series 2001 BOND PURCHASE CONTRACT 2001 Board of Supervisors County of Contra Costa, California County Administrator's Office 651 Pine Street, 11th Floor Martinez, California 94553-0063 Ladies and Gentlemen: The undersigned, Bear, Stearns & Co. Inc., as underwriter (the "Underwriter"), hereby offers to enter into this Bond Purchase Contract (the "Purchase Contract') with you, the County of Contra Costa, California (the "County"), for the purchase by the Underwriter of the Bonds (as hereinafter defined) which will be issued and delivered under the Trust Agreement, dated as of February 1, 1994, as supplemented by the First Supplemental Trust Agreement, dated as of 1, 2001 (collectively, the "Trust Agreement"), by and between the County and BNY Western Trust Company, as trustee (the "Trustee"). [Please note: if transaction includes the defeasance to maturity of any of the 1994 Bonds and/or the issuance of fixed rate bonds instead of variable rate bonds, then this Purchase Contract will be revised accordingly.] This offer is made subject to acceptance by the County prior to 11:59 p.m., California time, on the date hereof. If this offer is not so accepted, this offer will be subject to withdrawal by the Underwriter upon notice delivered to you at any time prior to acceptance. Upon acceptance, this Purchase Contract shall be in full force and effect in accordance with its terms and shall be binding upon the County and the Underwriter. 1. Purchase, Sale and Delivery of the Bonds. (a) Subject to the terms and conditions and in reliance upon the representations, warranties and agreements set forth herein, the Underwriter hereby agrees to purchase and the County agrees to sell to the Underwriter all (but not less than all) of the County of Contra Costa, California, Taxable Pension Obligation Bonds, Refunding Series 2001 (the "Bonds") in the aggregate principal amount of $ The Bonds are absolute and unconditional obligations of the County imposed upon the County by law and are not limited as to payment to any special source of County funds. The Bonds shall mature on June 1, 2014 and shall initially 10021499/594046.4 1 SD-V bear interest at a weekly rate of interest of_% per annum until Wednesday, , 2001 and thereafter at a weekly rate of interest as provided in the Trust Agreement. The Bonds are being issued-(i) to purchase and cancel-(pursuant to-a tender offer program being conducted by the County) a portion of the County's outstanding 1994 Taxable Pension Obligation Bonds, 1994 Series A (the "1994 Bonds"), which were originally executed and delivered in the aggregate principal amount of$337,365,000 and (ii) to pay costs of issuance. In comlection with such tender offer program, the County and Bear, Stearns & Co. Inc., as Dealer Manager, have heretofore entered into a Dealer Manager Agreement, dated , (the "Dealer Manager Agreement"). The Bonds shall be substantially in the form described in, and shall be executed, delivered and secured under and pursuant to, and shall be payable and subject to redemption as provided in, the Trust Agreement. The Bonds shall be subject to tender and purchase in accordance with the terms of the Trust Agreement and the Standby Bond Purchase Agreement (the "Liquidity Facility"), dated as of January 1, 2001, by and between the County and Westdeutsche Landesbank Girozentrale, acting through its New York Branch (the "Liquidity Provider"). The Bonds shall be remarketed as provided in the Remarketing Agreement (the "Remarketing Agreement"), dated as of 1, 2001, by and between the County and Bear, Stearns & Co. Inc., as Remarketing Agent (the "Remarketing Agent"). (b) The County has heretofore delivered to the Underwriter copies of the Preliminary Official Statement, dated , 2001, relating to the Bonds (as amended or supplemented, the "Preliminary Official Statement"). The County hereby ratifies, confirms and approves the use and distribution by the Underwriter prior to the date hereof of the Preliminary Official Statement and the final Official Statement, dated , 2001 (the "Official Statement") and all other documents, certificates and statements furnished by the County to the Underwriter in connection with the transactions contemplated by this Purchase Contract, in connection with the offer and sale of the Bonds. The Trust Agreement, the Remarketing Agreement, the Liquidity Facility, the Dealer Manager Agreement and the Bonds shall be collectively referred to herein as. the "Legal Documents." (c) The purchase price for the Bonds shall be $ (which reflects an underwriting discount of $ and fees and expenses of the Liquidity Provider to be paid by the Underwriter, on behalf of the County, in the amount of$ ). (d) At a.m., California time, on , 2001, or at such other time or on such other date as we mutually agree upon (the "Closing Date"), the Trustee will deliver or cause to be delivered to the Underwriter, through the book-entry system of The Depository Trust Company in New York, New York ("DTC"), the Bonds in the form of a separate single fully registered Bond (which may be typewritten) and which shall bear a CUSIP number (timely provided by the Underwriter), duly executed, together with the other documents mentioned herein. The Underwriter will accept such delivery and pay the purchase price of the Bonds as set forth in paragraph (c) above in immediately available finds (such delivery and payment being 10021499/594046.4 2 herein referred to as the "Closing") payable to the order of the Trustee in an amount equal to the purchase price. ---..--.- - (e) The-Underwriter agrees to snake a bona fide public offering of the--Bonds at the initial offering price set forth in the Official Statement, which price may be changed from time to time by the Underwriter after such offering. 2. Representations, Warranties and Agreements of the County. The County hereby represents, warrants and agrees with the Underwriter as follows: (a) The County is and will be on the Closing Date a political subdivision of the State of California duly organized and operating pursuant to the Constitution and laws of the State of California with full power and authority to execute and deliver the Official Statement, and to enter into this Purchase Contract and the Legal Documents; (b) By official action of the County prior to or concurrently with the acceptance hereof, the County has duly authorized and approved the execution and delivery of, and the performance by the County of the obligations on its part contained in, the Legal Documents and this Purchase Contract and the consummation by it of all other transactions contemplated by the Official Statement, the Legal Documents and this Purchase Contract; (c) To the best knowledge of the County atter reasonable investigation, the execution and delivery of the Legal Documents, this Purchase Contract and the Official Statement, and compliance with the provisions on the County's part contained herein and therein, will not in any material respect conflict with or constitute a breach of or default under any law, administrative regulation, judgment, decree, loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the County is a party or is otherwise subject, nor will any such execution, delivery or compliance result in the creation or imposition of any lien, charge or other security interest or encumbrance of any nature whatsoever upon any of the properties or assets of the County under the terms of any such law, administrative regulation, judgment, decree, loan agreement, indenture, bond, note, resolution, agreement or other instrument, except as provided in the Legal Documents; (d) To the best knowledge of the County atter reasonable investigation, the County is not in any material respect in breach of or default under any applicable law or administrative regulation of the State of California or the United States of America or any applicable judgment or decree or any loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the County is a party or is otherwise subject, and no event has occurred and is continuing which, with the passage of time or the giving of notice or both, would constitute a default or an event of default under any such instrument; (e) To the best knowledge of the County atter reasonable investigation, there is no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, governmental agency, public board or body, pending or threatened against the County in any material respect affecting the existence,of the County or the titles of its officers and officials to their respective offices or seeking to prohibit, restrain or enjoin the sale, execution or delivery of 10021499/594046.4 J _T12 V the Bonds or in any way contesting or affecting the validity or enforceability of the Legal Documents or this Purchase Contract or contesting the powers of the County or its authority to enter into or perform its obligations under any of the foregoing, or contesting in any way the — completeness-or accuracy of the Official Statement, or any amendment or supplement thereto, wherein an unfavorable decision, ruling or finding would materially adversely affect the validity or enforceability of the Legal Documents or this Purchase Contract; (f) The County will furnish such information, execute such instruments and take such other action in cooperation with the Underwriter as the Underwriter may reasonably request in order (i) to qualify the Bonds for offer and sale under the Blue Sky or other securities laws and regulations of such states and other jurisdictions of the United States as the Underwriter may designate and (ii) to determine the eligibility of the Bonds for investment under the laws of such states and other jurisdictions, and will use its best efforts to continue such qualification in effect so long as required for distribution of the Bonds (at the sole expense of the Underwriter); provided, however, that in no event shall the County be required to take any action which would subject it to general or unlimited service of process in any jurisdiction in which it is not now so subj ect; (g) As of the date hereof, and except for statements regarding DTC and the Liquidity Provider and certain pricing information determined on the date hereof, as to which the County does not make any representation or warranty,'the Preliminary Official Statement does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements therein, in light of the circumstances under which they are made, not misleading in any material respect; n (h) As of the date thereof, and except for statements regarding DTC and the Liquidity Provider, as to which the County does not make any representation or warranty, the Official Statement does not contain any untrue statement of a material fact or omit to state a material fact required to be stated therein or necessary to make the statements therein, in light of the circumstances under which they were made, not misleading in any material respect; (i) If between the date hereof and the date which is the End of the Underwriting Period (as hereinafter defined) for the Bonds, an event occurs which would cause the information contained in the Official Statement, as then supplemented or amended, to contain an untrue statement of a material fact or to omit to state a material fact required to be stated therein or necessary to make such information therein, in the light of the circumstances under which it was presented, not misleading in any material respect, the County will notify the Underwriter, and, if in the opinion of the County or the Underwriter or their respective counsel, such event requires the preparation and publication of a supplement or amendment to the Official Statement, the County will forthwith prepare and furnish to the Underwriter (at the expense of the County) a reasonable number of copies of an amendment of or supplement to the Official Statement (in form and substance satisfactory to the Underwriter and counsel for the Underwriter) which will amend or supplement the Official Statement so that it will not contain an untrue statement of a material fact or omit to state a material fact necessary in order to make the statements therein, in the light of the circumstances existing at the time the Official Statement is delivered to purchasers or prospective purchasers, not misleading in any material respect. For the purposes of this paragraph (i), between the date hereof and the date which is the End of the Underwriting 10021499/594046.4 4 Sa � e7 ell Period Period for the Bonds, the County will furnish such information with respect to itself as the Underwriter may from time to time reasonably request; - - --- - - - - 0) if the information contained in the Official Statement is amended or supplemented pursuant to paragraph (i) above, at the time of each supplement or amendment thereto and (unless subsequently again supplemented or amended pursuant to such paragraph) at all times subsequent thereto up to and including the date which is the End of the Underwriting Period for the Bonds, the portions of the Official Statement so supplemented or amended (including any financial and statistical data contained therein), except for statements regarding DTC and the Liquidity Provider, as to which the County does not make any representation or warranty, will not contain any untrue statement of a material fact or omit to state a material fact required to be stated therein or necessary to make such information therein, in the light of the circumstances under which it was presented, not misleading in any material respect; (k) As used herein and for the purposes of the foregoing, the term "End of the Underwriting Period" for the Bonds shall mean the Closing Date unless the County shall have been notified in writing to the contrary by the Underwriter on or prior to the Closing Date; and (1) To the extent permitted by law, the County agrees to indemnify and hold harmless the Underwriter and each person, if any, who controls (within the meaning of Section 15 of the Securities Act of 1933, as amended, or of Section 20 of the Securities Act of 1934, as amended) the Underwriter, and the officers, directors, agents and employees of the County against any and all losses, claims, damages, liabilities and expenses, including fees and expenses of legal counsel (i) arising out of any statement or information in the Preliminary Official Statement or the Official Statement, relating to the County, that is or is. alleged to be untrue or incorrect in any material respect or the omission or alleged omission therefrom of any statement or information that should be stated therein or that is necessary to make the statements therein relating to the County not misleading in any material respect and (ii) with respect to the settlement of any litigation commenced or threatened arising from a claim based upon any such untrue statement or omission or alleged untrue statement or omission, then the aggregate amount paid in settlement if such settlement is effected with the written consent of the County; provided, however, that in no event shall this indemnification agreement inure to the benefit of the Underwriter (or any person controlling the Underwriter) on account of any losses, claims, damages., liabilities or actions arising from the sale of the Bonds upon the public offering to any person by the Underwriter if such losses, claims, damages, liabilities or actions arise out of, or are based upon, (i) an untrue statement or omission or alleged untrue statement or omission in the Preliminary Official Statement and if the Official Statement shall correct the untrue statement or omission or the alleged untrue statement or omission which is the basis of the loss, claim, damage, liability or action for which indemnification is sought and a copy of the Official Statement had not been sent or given to such person at or prior to confirmation of such sale to such person or (ii) the negligence or wilfull misconduct of the Underwriter. In case any claim shall.be made or action brought against the Underwriter or any controlling person based upon the Preliminary Official Statement or the Official .Statement for which indemnity may be sought against the County, as provided above, the Underwriter shall promptly notify the County in writing setting forth the particulars of such claim or action and the County shall assume the payment of all expenses (including fees and expenses of legal counsel) and the defense thereof, including at its option the retaining of counsel acceptable to the Underwriter. The Underwriter 10021499/594046.4 5 A or any such controlling person shall have the right to retain separate counsel in any such action but shall bear the fees and expenses of such counsel unless the County shall have specifically authorized the retaining of such counsel. If the parties to such suit include both the Underwriter ---or such controlling person or persons and the County, and the Underwriter or controlling person or persons have been advised by such counsel that one or more legal defenses may be available to it or them which may not be available to the County, the County shall not be entitled to assume the defense of the suit. 3. Conditions'to the Obligations of the Underwriter. The Underwriter hereby enters into this Purchase Contract in reliance upon the representations and warranties of the County contained herein and the representations and warranties to be contained in the documents and instruments to be delivered at the Closing and upon the performance by the County of its obligations both on and as of the date hereof and as of the Closing.Date. Accordingly, the Underwriter's obligations under this Purchase Contract to purchase, to accept delivery of and to pay for the Bonds shall be subject, at the option of the Underwriter, to the accuracy in all material respects of the representations and warranties of the County contained herein as of the date hereof and as of the Closing Date, to the accuracy in all material respects of the statements of the officers and other officials of the County made in any certificate or other document furnished pursuant to the provisions hereof, to the performance by the County of its obligations to be performed hereunder and under the Legal Documents at or prior to the Closing Date, and also shall be subject to the following additional conditions: (a) At the Closing, the Legal Documents shall have been duly authorized, executed and delivered by the respective parties thereto, and the Official Statement shall have been duly authorized, executed and delivered by the County,. all in substantially the forms heretofore submitted to the Underwriter, with only such changes as shall have been agreed to by the Underwriter, and shall be in full force and effect; and there shall be in full force and effect such resolutions of the Board of Supervisors of the County as, in the opinion of Orrick, Herrington & Sutcliffe LLP ("Bond Counsel"), shall be necessary or appropriate in connection with the transactions contemplated hereby; (b) Between the date hereof and the Closing Date, the market price or marketability, at the initial offering price set forth in the Official Statement, of the Bonds shall not have been materially adversely affected, in the reasonable judgment of the Underwriter (evidenced by. a written notice from the Underwriter to the County terminating the obligation of the Underwriter to accept delivery of and make any payment for the Bonds), by reason of any of the following: (1) legislation enacted (or resolution passed) by or introduced or pending legislation amended in the Congress or recommended for passage by the President of the United States, the Speaker of the House of Representatives, the President Pro Tempore of the Senate, the Chairperson or ranking minority member of the Committee of Ways and Means of the House of Representatives or the Chairperson or ranking minority member of the Committee on Finance of the Senate, or a decision rendered by a court established under Article III of the Constitution of the United States or by the Tax Court of the United States, or an order, ruling, regulation (final, temporary or proposed) or press release issued or made by or on behalf of the Treasury Department of the United States or the Internal Revenue Service, with the purpose or effect, 10021499/594046.4 6 directly or indirectly, of imposing federal income taxation upon moneys that would be received by the County; - - - (2) -the declaration of war or engagement in major military hostilities -by the United States or the occurrences of any other national emergency or calamity relating to the effective operation of the government of or the financial community in the United States; (3) 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; (4) the imposition by the New York Stock Exchange or other national securities exchange, or any governmental authority, of any material restrictions not now in force with respect to the Bonds or obligations of the general character of the 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; (5) legislation enacted (or resolution passed) by or introduced or pending legislation amended in the Congress or recommended for passage by the President of the United States, or an order, decree or injunction issued by any court of competent jurisdiction, or an order, ruling, regulation (final, temporary or proposed) or press release issued or made by or on behalf of the Securities and Exchange Commission, or any other governmental agency having jurisdiction of the subject matter, to the effect that obligations of the general character of the Bonds, including any or all underlying arrangements, are not exempt from registration under the Securities Act of 1933, as amended, or that the Trust Agreement is not exempt from qualification under the Trust Indenture Act of 1939, as amended, or that the execution, offering or sale of obligations of the general character of the Bonds, including any or all underlying arrangements, as contemplated hereby or by the Official Statement, otherwise is or would be in violation of the federal securities laws as amended and then in effect; (6) the withdrawal or downgrading of any rating of the Bonds by a national rating agency; or (7) any event occurring, or information becoming known which, in the judgment of the Underwriter, makes untrue in any material respect any statement or information contained in the Official Statement, or has the effect that the Official Statement contains any untrue statement of a material fact or omits to state a material fact required to be stated therein or necessary in order to make the statements therein, in the light of the circumstances under which they were made, not misleading in any material respect; (c) At or prior to the Closing Date, the Underwriter shall have received the following documents, in each case satisfactory in form and substance to the Underwriter: (1) Two copies of the Legal Documents (excluding the Bonds) and this Purchase Contract,each duly executed and delivered by the respective parties thereto; (2) The approving opinion, dated the Closing Date and addressed to the County, of Bond Counsel in substantially the form attached to the Official Statement as 10021499/594046.4 7 Appendix E, and a letter of such counsel, dated the Closing Date and addressed to the Underwriter, to the effect that such opinion may be relied upon by the Underwriter to the same extent as if such opinion were addressed to it; (3) The supplemental opinion, dated the Closing Date and addressed to the Underwriter, of Bond Counsel, substantially to the effect that (i) each of the Trust Agreement and the Purchase Contract has been duly executed and delivered by the County and (assuming due authorization, execution and delivery by and validity with respect to the other parties thereto) constitutes a valid and binding obligation of the County, subject to laws relating to bankruptcy or other, laws affecting creditors' rights generally, to the application of equitable principles if equitable remedies are sought, to the'exercise of judicial discretion in appropriate cases and to the limitations on legal remedies against public bodies in the State of California and that no opinion is expressed with respect to the indemnification, contribution, choice of law, choice of forum or waiver provisions therein; (ii) the Bonds are not subject to the registration requirements of the Securities Act of 1933, as amended, and the Trust Agreement is exempt from qualification under the Trust Indenture Act of 1939, as amended; and (iii) the statements contained in the Official Statement under the captions "THE 2001 BONDS," "SECURITY AND SOURCES OF PAYMENT FOR THE 2001 BONDS," "TAX MATTERS," "APPROVAL OF LEGALITY=Validation Proceedings," and in Appendix D - "SUMMARY OF CERTAIN PROVISIONS OF THE TRUST AGREEMENT" and in Appendix E - "PROPOSED FORM OF BOND COUNSEL OPINION" (excluding therefrom all information contained in debt service schedules and financial or statistical information as to which no view is expressed) insofar as such statements purport to summarize certain provisions of the Trust Agreement and Bond Counsel's opinion concerning certain tax matters relating to the Bonds, are accurate in all material respects; (4) The opinion of the County Counsel, dated the Closing Date and addressed to the Underwriter, to the effect that (i) the County is a political subdivision of the State of California duly organized and operating pursuant to the Constitution and laws of the State of California; (ii) the resolution or resolutions of the County approving and authorizing the execution and delivery by the County of the Legal Documents, the Purchase Contract and the Official, Statement (the "County Resolution") were duly adopted at meetings of the Board of Supervisors of the County which were called and held pursuant to law and with all public notice required by law and at which a quorum was present and acting throughout; (iii) to the best knowledge of such counsel after reasonable investigation, 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 County, to restrain or enjoin the payment of the amounts with respect to the Trust Agreement, or in any way contesting or affecting the validity of the Legal Documents or the Purchase Contract; (iv) the execution and delivery of the Legal Documents, the Purchase Contract and the Official Statement, the adoption of the County Resolution, and compliance by the County with the provisions of the foregoing, 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 or default under any agreement or other instrument to which the County is a party (and of which such counsel is aware after reasonable investigation) or by which it is bound (and of which such counsel is aware after reasonable investigation) or any existing law, regulation, court order or consent decree to which the County is subject; (v) the Official 10021499/594046.4 8 Statement, the Legal Documents and the Purchase Contract have been duly authorized, executed and delivered by the County and, assuming due authorization, execution and delivery by and validity against the other parties thereto, constitute legal, valid and binding agreements of the -- County- enforceable in -accordance with their respective terms, subject to laws relating to bankruptcy, insolvency or other laws affecting the enforcement of creditors' rights generally and the application of equitable principles if equitable remedies are sought, the exercise of judicial discretion and the limitation on legal remedies against public entities in California; and (vi) except as described in the Official Statement, no authorization, approval, consent, or other order of the State of California or any other governmental authority or agency within the State of California having jurisdiction over the County is required for the valid authorization, execution, delivery and performance by the County of the Legal Documents, the Official Statement and the Purchase Contract or for the adoption of the County Resolution which has not been obtained; (5) The opinion, dated the Closing Date and addressed to the Underwriter and the County, of Counsel to the Trustee, to the effect that (i) the Trustee is a banking corporation duly organized and validly existing under the laws of the State of California, duly qualified to do business and to exercise trust powers therein, having full power and authority to enter into and to perform its duties as Trustee under the Trust Agreement, (ii) the Trustee has duly authorized, executed and delivered the Trust Agreement, (iii) the Trust Agreement constitutes a legally valid and binding agreement of the Trustee, enforceable against the Trustee in accordance with its terms, (iv) the Bonds have been duly authenticated and delivered by the Trustee, (v) no authorization, approval, consent, or other order of the State of California or any other governmental authority or agency within the State of California having jurisdiction over the Trustee is required for the valid authorization, execution, delivery and performance by the Trustee of the Trust Agreement, and (vi) the execution and delivery of the Trust Agreement and compliance by the Trustee with the provisions of the Trust Agreement, under the circumstances contemplated thereby, do not and will not in any material respect conflict with or constitute on the part of the Trustee a breach or default under any agreement or other instrument to which the Trustee is a party (and of which such counsel is aware after reasonable investigation) or by which it is bound (and of which such counsel is aware after reasonable investigation) or any existing law, regulation, court order or consent decree to which the Trustee is subject; (6) The opinion, dated the Closing Date and addressed to the Underwriter, of Fulbright & Jaworski L.L.P., Los Angeles, California, counsel for the Underwriter ("Underwriter's Counsel") to the effect that (a) the Bonds are not subject to the registration requirements of the Securities Act of 1933, as amended, and the Trust Agreement is exempt from qualification under the Trust Indenture Act of 1939, as amended, and (b) without passing upon or assuming any responsibility for the accuracy, completeness or fairness of the statements contained in the Official Statement and making no representation that they have independently verified the accuracy, completeness or fairness of any such statements, based upon the information made available to personnel in their firm in the course of their participation in the preparation of the Official Statement as Underwriter's Counsel, nothing has come to their attention which would lead them to believe that the Official Statement as of its date (excluding therefrom any information in the Official Statement relating to DTC or the operation of the book-entry system, the information relating to the Liquidity Provider, any information in the appendices of the Official Statement (other than Appendix D of the Official Statement), or any 10021499/594046.4 9 other financial or statistical data included in the Official Statement, as to which no opinion need be expressed) contains an untrue statement of a material fact or omits to state a material fact required to be stated therein or necessary to.make the statements therein, in the light of.the ...circum stances under which they were made, not misleading in any material respect; (7) An opinion of Bond Counsel, dated the Closing Date and addressed to the County and the Underwriter, substantially to the effect that upon the issuance of the Bonds and the application of the proceeds thereof in accordance with the Trust Agreement, all liability of the County in respect of the 1994 Bonds defeased to maturity with proceeds of the Bonds has ceased, terminated and been discharged pursuant to the terms of the Trust Agreement; (8) An opinion of counsel to the Liquidity Provider, dated the Closing Date and addressed to the County, the Underwriter and the Trustee, to the effect that (i) the Liquidity Facility has been duly authorized, executed and delivered by the Liquidity Provider and, assuming due authorization, execution and delivery of the other parties thereto, the Liquidity Facility constitutes the legal, valid and binding obligation of the Liquidity Provider enforceable in accordance with its terms, subject to laws relating to bankruptcy, insolvency or other laws affecting the enforcement of creditors' rights generally and the application of equitable principles if equitable remedies are sought, and (ii) the statements in the Official Statement under the caption "THE LIQUIDITY FACILITY," to the extent such statements purport to summarize certain provisions of the Liquidity Facility, present a fair and accurate summary of such provisions; (9) A certificate or certificates, dated the Closing Date, signed by a duly authorized official of the County satisfactory to the Underwriter, in form and substance satisfactory to the Underwriter, to the effect that, to the best of such official's knowledge after reasonable investigation, (a) the representations and warranties of the County contained in the Purchase Contract are true and correct in all material respects on and as of the Closing Date with the same effect as if made on the Closing Date; (b) no litigation is pending or threatened (i) to restrain or enjoin the execution, sale or delivery of any of the Bonds or any payments with respect to the Bonds, (ii) in any way contesting or affecting the validity or enforceability of the Purchase Contract or the Legal Documents, or (iii) in any way contesting the existence or powers of the County material to the issuance of the Bonds and the execution and delivery of the Purchase Contract, the Legal Documents and the Official Statement; and (c) no event affecting the County has occurred since the date of the Official Statement which either makes'untrue or incorrect in any material respect as of the Closing Date any statement or information contained in the Official Statement relating to the County or is not reflected in the Official Statement but should be reflected therein in order to make the statements and information therein relating to the County not misleading in any material'respect; (10) A certificate, dated the date of Closing, signed by a duly authorized official of the Trustee, satisfactory in form and substance to the Underwriter, to the effect that: (i) the Trustee is a banking corporation duly organized and validly existing under the laws of the State of California, having the full power and being qualified to enter into and perform its duties under the "Trust Agreement and to execute and deliver the Bonds 10021499/594046.4 10 sem,.y to the Underwriter, and the Trust Agreement constitutes the legal, valid and binding obligation of the Trustee, enforceable in accordance with its terms; ...=-- - ---.-- -- (ii) the Trustee is duly authorized to enter into the Trust Agreement-and to execute and deliver the Bonds to the Underwriter pursuant to the Trust Agreement; (iii) the execution and delivery of the Trust Agreement and compliance with the provisions on the Trustee's part contained therein, will not conflict with or constitute a breach of or default under any law, administrative regulation,judgment, decree, loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the Trustee is a party or is otherwise subject (except that no representation, warranty or agreement is made with respect to any federal or state securities or blue sky laws or regulations), nor will any such execution, delivery, adoption or compliance result in the creation or imposition of any lien, charge or other security interest or encumbrance of any nature whatsoever upon any of the properties or assets held by the Trustee pursuant to the lien created by the Trust Agreement under the terms of any such law, administrative regulation, judgment, decree, loan agreement, indenture, bond, note, resolution, agreement or other instrument, except as provided by the Trust Agreement; (iv) the 1994 Bonds purchased with proceeds of the Bonds have been cancelled by the Trustee in accordance with the Trust Agreement; and (v) to the best of the knowledge of the Trustee, it has not been served with any action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, governmental agency, public board or body, nor is any such action or other proceeding threatened against the Trustee, affecting the existence of the Trustee, or the titles of its officers to their respective offices or seeking to prohibit, restrain or enjoin the execution and delivery of the Bonds or the collection of revenues to be applied to pay the principal and interest with respect to the Bonds, or the pledge thereof, or in any way contesting or affecting the validity or enforceability of the Legal Documents or the Purchase Contract, or contesting the powers of the Trustee or its authority to enter into or.perform its obligations under the Trust Agreement, wherein an unfavorable decision, ruling or finding would materially adversely affect the validity or enforceability of the Legal Documents or the Purchase Contract; (11) A certificate, signed by a duly authorized officer of the Liquidity Provider, in form and substance satisfactory to the County and the Underwriter, dated the Closing Date, to the effect that the statements and financial information in the Official Statement under the caption "THE LIQUIDITY PROVIDER" are true and accurate; (12) Two copies of the Official Statement, executed on behalf of the County by an authorized representative of the County; (13) Two certified copies of the general resolution of the Trustee authorizing the execution and delivery of the Trust Agreement; (14) Two certified copies of the County Resolution; 10021499/594046.4 11 sZ). y a -G-ol (15) Evidence that the ratings regarding the Bonds described in the Official Statement are in frill force and effect as of the Closing Date; and - -- -- - (16) Such-additional legal opinions, certificates, proceedings, instruments or - evidences thereof and other documents as the Underwriter, Underwriter's Counsel or Bond Counsel may reasonably request to evidence the truth and accuracy, as of the date hereof and as of the Closing Date, of the representations and warranties of the County herein and of the statements and information contained in the Official Statement, 'and the due performance or satisfaction by the Trustee and the County at or prior to the Closing of all agreements then to be performed and all conditions then to be satisfied by either of them in connection with the transactions contemplated hereby and by the Legal Documents, this Purchase Contract and the Official Statement. 4. Expenses. All expenses and costs incident to the authorization, execution, delivery and sale of the Bonds to the Underwriter, including the costs of printing of the Bonds, the Preliminary Official Statement, the Official Statement, the cost of duplicating the Legal Documents and this Purchase Contract, the fees and expenses of the Liquidity Provider, Bondholder Communications Group, C.M. de Crinis & Co., Inc., accountants, other consultants and rating agencies, the initial fee of the Trustee (including in its capacity as tender agent for the Bonds) and its counsel in connection with the execution and delivery of the Bonds and the fees and expenses of Orrick, Herrington & Sutcliffe LLP and counsel to the Liquidity Provider shall be paid from the proceeds of the Bonds or by the County. All out-of-pocket expenses of the Underwriter, including traveling and other expenses, including those associated with the California Debt and Investment Advisory Commission, the production of the County's presentations to rating agencies and the preparation of any Blue Sky Memorandum and Legal Investment Survey, and the fees and expenses of Underwriter's Counsel, shall be paid by the Underwriter. 5. Notices. Any notice or other co>nmunication to be given to the other party to this Purchase Contract may be given by delivering the same in writing to such other party at the following address: Underwriter: Bear, Stearns & Co. Inc. 1999 Avenue of the Stars, 32nd Floor Los Angeles, California 90067-6100 Attention: Michelle Issa County: County of Contra Costa County Administrator's Office 651 Pine Street, 6th Floor Martinez, California 94553-0063 Attention: Director, Capital Facilities and Debt Management 10021499/594046.4 12 6. Survival of Representations and Warranties. - - --- -The representations and--warranties of the County set forth in or-made pursuant to this Purchase Contract shall not be deemed to have been discharged, satisfied or otherwise rendered void by reason of the Closing or termination of this Purchase Contract and regardless of any investigations or statements as to the results thereof made by or on behalf of the Underwriter and regardless of delivery of and payment for the Bonds. This Purchase Contract may be executed in any number of counterparts and each of such counterparts shall for all purposes be deemed to be an original. 10021499/594046.4 13 S D. y a 7. Effectiveness. This Purchase Contract shall become effective and binding upon the respective parties hereto-upon the execution-of-the acceptance hereof by a duly-authorized officer of the-County and shall be valid and enforceable as of the time of such acceptance. Very truly yours, BEAR, STEARNS & CO. INC., as Underwriter By: Michelle Issa Managing Director, ACCEPTED: COUNTY OF CONTRA COSTA, CALIFORNIA By: Laura W. Lockwood Director, Capital Facilities and Debt Manager APPROVED AS TO FORM: COUNTY COUNSEL By: County Counsel 10021499/594046.4 14 DEALER MANAGER AGREEMENT [date] Bear, Stearns & Co. Inc. as Dealer Manager 1999 Avenue of the Stars 31"Floor Los Angeles, California 90067 Ladies and Gentlemen: The County of Contra Costa, California (the "County") plans to invite the beneficial owners (the "Bondowners") of its outstanding Taxable Pension Obligation Bonds, 1994 Series A (the "Bonds") to offer to sell such Bonds to the County for cash upon the terms and subject to the conditions set forth in the County's "Invitation to. Tender Bonds" dated , 2001 (the "Invitation"). The Bonds are listed in the Invitation. In addition to the Invitation, the County has also prepared for use in connection with the Invitation the following documents: • "Letter from the County to Bondowners", including "Answers To Frequently Asked Questions" • "Request to Transmit To Your Clients and Their Brokers" • "Notice To Our Clients" • "Bondowner's Instructions" • "Solicitation Fee Payment Request Form" • Press Release dated 32001 • Preliminary Official Statement relating to the County's Taxable Pension Obligation Bonds, Refunding Series 2001. These seven documents are referred to in this Dealer Manager Agreement (this "Agreement") as the "Ancillary Documents." The Invitation and the Ancillary Documents are referred to in this Agreement as the "Invitation Material." Any other material relating to the Invitation prepared by the County or that is approved by the County in writing subsequent to the execution of this Agreement that is intended to be used by the Dealer Manager in connection with the Invitation is referred to as the"Additional Material." 1. Appointment of the Dealer Manager The County hereby appoints Bear, Stearns & Co. Inc. as the Dealer Manager in connection with the Invitation (the "Dealer Manager"). The County and the Dealer Manager 593515.4 w97 � t7• � agree that institutional investors with questions about the Invitation should contact the .Dealer Manager. The County and the Dealer Manager agree that individual investors and their brokers and account executives with questions about the Invitation should contact the Information Agent described below. The County authorizes the Dealer Manager to act on its behalf in accordance with this Agreement and the terms of the Invitation Material and Additional Material. The County has approved the Invitation Material and authorizes the Dealer Manager to use the Invitation Material and Additional Material in connection with the solicitation of offers to sell Bonds to the County (subject to the third and fourth sentences of this Section 1). The Dealer Manager agrees not to furnish written materials to holders or beneficial owners of Bonds in connection with the Invitation other than the Invitation Material and Additional Material. In performing its obligations under this Agreement, the Dealer Manager shall act as an independent contractor and shall not be deemed to act as an agent of the County, and the County shall not be deemed to act as the agent of the Dealer Manager. 2. The Information Agent The County.has previously appointed Bondholder Communications Group of New York City as the Information Agent for the Invitation. 3. Furnishing Material to. Information Services The County shall provide or cause to be provided to the Information Services (as defined in the Invitation) in the manner set forth in the Invitation the Invitation Material and any Additional Material. 4. Solicitation of Offers to.Sell Bonds (a) The Dealer Manager agrees to use its best efforts to solicit offers to sell Bonds to the County pursuant to the Invitation (subject to the third and fourth sentences of Section 1). (b) The County agrees to furnish to the Dealer Manager a reasonable number of copies of the Invitation Material and Additional Material for use in connection with the Invitation. The County agrees to furnish to the Dealer Manager as promptly as practicable prior to. the effective date thereof copies of any written amendments 'or supplements to the Invitation Material and any Additional Material. The County also agrees to notify the Dealer Manager as promptly as practicable prior to the effective date thereof of any extension or termination of the Invitation or of the Settlement Date (as defined in the Invitation). (c) The County agrees to advise the Dealer Manager promptly of the occurrence of any event which would cause the County to extend, terminate, modify, amend, supplement or waive any condition of the Invitation, or to amend or supplement the Invitation Material or Additional Material. 593515.4 w97 -2- S'D• `r (d) The County will not use or publish any material in connection with the Invitation, or refer to the Dealer Manager in any such material, without first consulting with the Dealer Manager. The County will promptly inform the Dealer Manager of any litigation or administrative action with respect to the Invitation. (e) The County agrees to.use its best efforts to cause the Information Agent to cooperate with the Dealer Manager as reasonably requested by the Dealer Manager. The County will promptly furnish to the Dealer Manager copies of all Bondowner lists furnished to the County by the Information Agent. The Dealer Manager agrees to use the information furnished to it by the County or the Information Agent only in connection with the Invitation and not to furnish such information to any other person except in connection with the Invitation. 5. Compensation and Expenses (a) The County shall pay to the Dealer Manager, as compensation for its services as the Dealer Manager hereunder, a fee of$ for each $1,000 principal amount of Bonds purchased by the County pursuant to the Invitation, payable on the Settlement Date. (b) Whether or not any Bonds are offered or purchased pursuant to the Invitation, the County shall pay all expenses for the preparation, printing, mailing and publishing of the Invitation Material and Additional Material. If Bonds are purchased pursuant to the Invitation, the County shall pay all of the Dealer Manager's reasonable out-of-pocket expenses incurred in connection with its serving as Dealer Manager hereunder. In the event no Bonds are offered or purchased pursuant to the Invitation, the County shall negotiate in good faith with the Dealer Manager to determine the amount of expenses to be reimbursed by the County to the Dealer Manager. (c) The County will pay the solicitation fees and the reimbursements specified in the Invitation. 6. Representations and Warranties by the County The County represents and warrants to, and agrees with, the Dealer Manager that: (a) The County has been duly created and is validly existing under the laws of the State of California. (b) The Invitation Material and any Additional Material, and the execution, delivery and performance of this Agreement, have been duly authorized by proper proceedings of the County, and this Agreement has been duly executed and delivered by the County and constitutes the legal, valid and binding agreement of the County, enforceable in accordance with its terms, except that enforcement of this Agreement may be subject to 593515.4 w97 -3- ,SID bankruptcy, insolvency, reorganization and other laws of general applicability relating to or affecting creditors' rights and to general principles of equity. (c) The Invitation Material and Additional Material do not and (as amended or supplemented, if amended or supplemented) will not contain any untrue statement of material fact relating to the terms of the Invitation or omit to state any material fact necessary in order to make the statements made relating to the terms of the Invitation, in the light of the circumstances under which they were made, not misleading. If, during the period commencing with the date of the Invitation to and including the Settlement Date, any event shall occur which might or would cause the Invitation Material or the Additional Material, as then amended or supplemented, to contain any untrue statement of a material fact or to omit to state a material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading, the County shall notify the Dealer Manager thereof, and if in the opinion of the Dealer Manager such event requires the preparation and publication of a supplement or amendment to the Invitation Material or the Additional Material, the County at its expense will prepare and furnish, or cause to be prepared and furnished, to the Dealer Manager a reasonable number of copies of the supplement or amendment to the Invitation Material or the Additional Material in a form and in a manner approved by the Dealer Manager. (d) The making and consummation of the Invitation and the execution, delivery and performance by the County of this Agreement do not and will not conflict with, or result in the acceleration of any obligation under, or in a breach of or constitute a default under, any of the provisions of any material resolution, indenture, loan agreement or mortgage to which the County is a party or by which it is bound or to which any material part of its property or assets is subject, and do not and will not contravene in any material respect any Federal, state or local law, rule or regulation to which the County is subject, or any order applicable to the County of any court or of any other governmental agency or instrumentality having jurisdiction over it or any material part of its property. (e) The County will apply proceeds from the sale of its Taxable Pension Obligation Bonds, Refunding Series 2001, to the timely payment of the aggregate purchase prices of the Bonds that it decides to purchase pursuant to the Invitation, and all related fees and expenses payable by the County. Such proceeds also may be used to establish a defeasance escrow for a portion of the Bonds. (f) As of the date hereof, there is no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, government 593515.4 w97 -4- Y a-6 -oi agency, public board or body, pending or, to the knowledge of the County, threatened against the County, affecting the legal existence of the County or the titles of its officers or officials to their respective offices, or affecting or seeking to prohibit, restrain or enjoin the transactions contemplated by this Agreement and the Invitation, or questioning, contesting or affecting as to the County the validity or enforceability of this Agreement, or contesting powers of the County to carry out the transactions contemplated hereunder or under the Invitation Material or the execution and delivery by the County of this Agreement, and nothing has come to the attention of the County that there is any basis for any such action, suit, proceeding, inquiry or investigation, wherein an unfavorable decision, ruling or finding would materially adversely affect the authorization, execution, delivery or performance by the County of this Agreement. 7. Representations and Warranties by the Dealer Manager The Dealer Manager represents and warrants to, and agrees with, the County that: (a) This Agreement has been duly authorized, executed and delivered by the Dealer Manager and constitutes its legal; valid and binding obligation, enforceable in accordance with its terms, except as enforcement may be limited by bankruptcy, insolvency, reorganization and similar laws affecting creditors' rights and by general principles of equity. (b) The execution, delivery and perfonmance of this Agreement by the Dealer Manager does not and will not violate, in any material respect, any law, regulation or rule to which the Dealer Manager is subject. (c) During the period of the Invitation, the Dealer Manager shall not effect any transactions in the Bonds for the purpose of raising or depressing the price of the Bonds. 8. Conditions of Obligation The Dealer Manager's obligations under this Agreement shall at all times be subject, in the Dealer Manager's discretion, to the conditions that: (a) All representations, warranties and other statements of the County contained herein are now, and at all times during the Invitation will be, true and correct in all material respects. (b) The County at all times during the Invitation shall have performed all of its obligations hereunder theretofore required to have been performed. 593515.4 w97 -5- 9. Indemnity and Survival of Certain Provisions (a) To the extent permitted by applicable law, the County agrees to indemnify and hold the Dealer Manager harmless against any and all losses, damages, liabilities or claims (or actions in respect thereof)that arise out of or are based upon any untrue statement or alleged untrue statement of a material fact contained in the Invitation Material or any Additional Material or in any amendment or supplement to any of the foregoing or that arise out of or are based upon the omission or alleged omission to state therein a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading; provided, however, the Dealer Manager shall not be indemnified for any claims, damages, losses, liabilities, costs or expenses relating to an untrue statement of a material fact or omission to state a material fact by, or based on written information provided by, the Dealer Manager or any controlling person of the Dealer Manager or to the extent that any loss, damage, expense, liability or claim incurred results from the negligence, bad faith or willful misconduct of the Dealer Manager or any of its affiliates, partners, directors, agents, employees or controlling persons (if any) in performing the services that are the subject of this Agreement. (b) Subject to the limitations contained in this Section, in the event that the Dealer. Manager becomes involved in any capacity in any action, proceeding or investigation brought by or against any person (other than a dispute between the Dealer Manager and the County arising out of this Agreement), including Bondowners, in connection with any matter referred to in subsection (a) of this Section for which the County has agreed to indemnify and hold harmless the Dealer Manager, the County also agrees periodically to reimburse the Dealer Manager for the Dealer Manager's legal and other reasonable expenses (including the cost of any investigation and preparation) incurred in connection therewith. (c) Neither the Dealer Manager nor any of its affiliates, nor any partners, directors, agents, employees or controlling persons (if any), as the case may be, of the Dealer Manager or any such affiliates, shall have any liability to the County or any person asserting claims on behalf of the County for or in connection with any matter referred to in this Agreement except to the extent that any loss, damage, expense, liability or claim incurred by the County results from the negligence, bad faith or willful misconduct of the Dealer Manager or any of its affiliates, partners, directors, agents, employees or controlling persons (if any) in performing the services that are the subject of this Agreement. (d) Promptly after receipt by the Dealer Manager of notice of the Dealer Manager's involvement in any action, proceeding or investigation described in subsection (a) of this Section, the Dealer Manager shall, if a 593515.4 w97 -6- claim in respect thereof is to be made against the County under subsection (a) of this Section, notify the County in writing of such involvement, but the failure so to notify the County shall not relieve the County from any liability which it may otherwise have to the Dealer Manager under subsection (a) of this Section except,to the extent that the County suffers actual prejudice as a result of such failure. In case any such action, proceeding or investigation shall be brought against or otherwise involve the Dealer Manager and the Dealer Manager shall notify the County of the commencement thereof or the Dealer Manager's involvement therein, the County shall be entitled to participate therein, but the defense of any such action, proceeding or investigation shall be conducted by the Dealer Manager's counsel unless the Dealer Manager shall consent to a request by the County to assume the defense thereof with counsel satisfactory to the Dealer Manager. Upon any such assumption by the County of the defense of such action, proceeding or investigation, the Dealer Manager shall have the right to participate in such action, proceeding or investigation and to retain the Dealer Manager's own counsel, but the County shall not be liable to the Dealer Manager under this subsection for any legal fees and expenses of other counsel subsequently incurred by the Dealer Manager in connection with the defense thereof unless (i) the County has agreed to pay such fees and expenses, (ii) the County shall have failed to employ counsel satisfactory to the Dealer Manager in a timely manner, or (iii) the Dealer Manager shall have been advised by counsel that there are actual or potential conflicting interests between the County and the Dealer Manager, including, but not limited to, situations in which there are one or more legal defenses available to. the Dealer Manager that are different from or additional to those available to the County. . The Dealer Manager shall not consent to any compromise or settlement of any such action, proceeding or investigation without the County's prior written consent, unless such compromise or settlement does not result in any liability to the County hereunder. (e) If as a matter of law the indemnification provided for in subsection (a) of this Section is unavailable to hold the Dealer Manager harmless, then the County shall, to the extent permitted by applicable law, contribute to the amount paid or payable by the Dealer Manager as a result of such loss, damage, expense, liability or claim (or action in respect thereof) referred to therein in such proportion as is appropriate to -reflect the relative benefits of the County on the one hand and the Dealer Manager on the other hand in the matters contemplated by this Agreement (taking into account (i) the estimated reduction in debt service to be paid by the County on and prior to the June 1, 2011 final maturity of the Bonds (assuming that the variable rate bonds to be issued to provide moneys for the purchase of Bonds bear an interest rate, taking into consideration liquidity and remarketing fees, of 6.50% per annum) and (ii) the fees paid or anticipated to be paid to the Dealer Manager pursuant to Section 5 of this Agreement), as well as the relative fault of the County and the Dealer 593515.4 w97 -7- Manager with respect to such loss, damage, expense, liability or claim (or action in respect thereof) and any other relevant equitable considerations. The County and the Dealer Manager agree that it would not be just and equitable if contribution pursuant to this subsection were determined by pro rata allocation or by any other method of allocation which does not take account of the equitable considerations referred to in this subsection. (f) The agreements contained in Section 5 and in this Section and the representations and warranties set forth in Sections 6 and 7 hereof shall survive any termination or cancellation of this Agreement, any completion of the engagement provided by this Agreement, any investigation made by or on behalf of the Dealer Manager, any of the Dealer Manager's officers or partners, any person controlling the Dealer Manager or any other person and any termination or expiration of the Invitation. (g) The reimbursement, indemnity and contribution obligations of the County under this Section shall be in addition to any liability that the County may otherwise have, shall apply upon the same terms and conditions to the Dealer Manager's affiliates and the partners, directors, officers, agents, employees and controlling persons (if any), as the case may be, of the Dealer Manager and any such affiliate, and shall be binding upon and inure to the benefit of, as applicable, any successors, assigns, heirs and personal representatives of the County, the Dealer Manager, any such affiliate and any of such other person referred to above but there shall be no double recovery with respect to any losses, damages, liabilities, claims, costs or expenses. 10. Miscellaneous (a) This Agreement is made solely for the benefit of the Dealer Manager, the County and any partner, director, officer, agent, employee, controlling person or affiliate referred to in Section 9 hereof, and their respective successors, assigns, and legal representatives, and no other person or entity shall acquire or have any right under or by virtue of this Agreement. (b) In the event that any provision of this Agreement shall be determined to be invalid or unenforceable in any respect, such determination shall not affect any other provision hereof, which shall remain in full force and effect. (c) Except as otherwise expressly provided in this Agreement, whenever notice is required by the provisions of this Agreement to be given to (i) the County, such notice shall be in writing addressed to the County, at the Office of the County Administrator, 651 Pine Street, 6th Floor, Martinez, California 94553, Attention: Director, Capital Facilities and Debt Management; telephone (925) 335-1086, facsimile (925) 335-1093, and (ii) the Dealer Manager, such notice shall be in writing addressed to Bear, Stearns & Co. Inc., 1999 Avenue of the Stars, 3151 Floor, Los Angeles, 593515.4 w97 -8- California 90067, Attention: Michelle Issa, telephone (310) 201-7883, facsimile (3 10) 201-2754. (d) This Agreement contains the entire understanding of the parties with respect to the Dealer Manager acting as Dealer Manager of the Invitation, superseding any and all prior agreements, understandings and negotiations with respect to such activities by the Dealer Manager. This Agreement shall be governed by and construed in accordance with the laws of the State of California without regard to principles of conflict of laws. This Agreement may be executed in any number of counterparts, each of which shall be an original, but all such counterparts shall together constitute one and the same agreement. Please sign and return to us a duplicate of this letter, whereupon it will become a binding agreement between us. Very truly yours, CONTRA COSTA COUNTY, CALIFORNIA By: County Administrator and Clerk of the Board of Supervisors The undersigned hereby confirms that the foregoing letter, as of the date thereof, correctly sets forth the agreement between the County and the undersigned. BEAR, STEARNS & CO. INC. By: Michelle Issa Managing Director 593515.4 w97 -9- J V. ESCROW AGREEMENT by and between COUNTY OF CONTRA COSTA and BNY WESTERN TRUST COMPANY Dated as of January 1, 2001 relating to the COUNTY OF CONTRA COSTA TAXABLE PENSION OBLIGATION BONDS, 1994 SERIES A Docssrl:371G18.3 ESCROW AGREEMENT THIS ESCROW AGREEMENT, dated as of January 1, 2001, is entered into by and between COUNTY OF CONTRA COSTA, a political subdivision duly organized and existing under the Constitution and Laws of the State of California (the "County"), and BNY WESTERN TRUST COMPANY, duly organized and existing under and by virtue of the laws of the State of California, as trustee and as escrow bank (the "Escrow Agent"). WITNESSETH: WHEREAS, the Escrow Agent, as trustee and the County have heretofore executed the Trust Agreement, dated as of February 1, 1994, (the "Original Trust Agreement") . (as supplemented by a First Supplemental Trust Agreement dated as of January 1, 2001 (the "First Supplemental Trust Agreement", and collectively with the Original Trust Agreement the "Trust Agreement"); WHEREAS, the County has heretofore issued $337,3655,000 County of Contra Costa Taxable Pension Obligation Bonds, 1994 Series A (the"Refunded Bonds") pursuant to the Original Trust Agreement; WHEREAS, pursuant to Article III of the Original Trust Agreement, the County may issue Additional Bonds for, among other purposes, the refunding of any Bonds then Outstanding, provided that the conditions to the issuance of Additional Bonds as set forth in Article III of the Original Trust Agreement are satisfied; WHEREAS, the County has determined that it is in the County's best interests to purchase pursuant to a tender a portion of the Refunded Bonds and/or to advance refund a portion of the Refunded Bonds to their final maturity date and to issue its County of Contra Costa, California Taxable Pension Obligation Bonds, Refunding Series 2001 in the aggregate principal amount of$ (the "Refunding Bonds"); WHEREAS, Section 14.01 of the First Supplemental Trust Agreement provides for the transfer and deposit of certainproceeds of the Refunding Bonds to the Escrow Fund created hereunder to advance refund and defease the Refunded Bonds, and such proceeds shall be in such amount and shall be invested in Permitted Investments under the Trust Agreement so as to insure the full and timely payment of the Refunding Requirements (as hereinafter defined); and, WHEREAS, in order to further insure the full and timely payment of the Refunding Requirements, the Escrow Agent is also being authorized and directed by the County to enter into the Escrow Fund Forward Sale Agreement (herein, the "Forward Sale Agreement") dated as of January 1, 2001 with (the"Provider"), which Forward Sale Agreement is attached hereto as Exhibit D; DOCSSF1:471618.3 jD, �/ a -b-al TABLE OF CONTENTS Page Section1. Definitions.......................................................................................................................................2 Section 2. Creation and Purpose of Escrow.....................................................................................................3 Section3. Bondholder Notices.........................................................................................................................4 Section 4. Accounting for Escrow; Substitutions.............................................................................................4 Section 5. Investments and Reinvestments......................................................................................................5 Section 6. Sufficiency of Escrow.....................................................................................................................5 Section 7. Transfers for Payment of Refunded Bonds.....................................................................................5 Section 8. Termination of Escrow Agreement; Written Request of County....................................................5 Section9. Fees and Costs.................................................................................................................................5 Section10. Reports............................................................................................................................................6 Section 11. Character of Deposit. ......................................................................................................................6 Section 12. Exculpatory Provisions........................................................................................... Section13. Time of Essence..............................................................................................................................8 Section14. Amendments. ..................................................................................................................................8 Section15. Successors.......................................................................................................................................8 Section16. Notices. ...........................................................................................................................................8 Section17. Severability. ....................................................................................................................................9 Section18. Law Governing. .............................................................................................:................................9 Section19. Counterparts.....................................................................................................................................9 EXHIBIT A REFUNDING REQUIREMENTS..............................................................................................A-1 EXHIBIT B ESCROWED SECURITIES.......................................................................................................B-1 EXHIBITC NOTICE OF DEFEASANCE.....................................................................................................C-1 EXHIBIT D ESCROW FUND FORWARD SALE AGREEMENT...............................................................D-1 EXHIBITE ELIGIBLE SECURITIES........................................................................................................... E-1 DOCSSF 1:471618.3 i s a. a -6-01 NOW, THEREFORE, in of the mutual agreements.herein contained, in order to secure the payment of the Refunding Requirements as heretofore provided, the parties hereto mutually undertake, promise and agree for themselves, their respective representatives, successors and assigns, as follows: Section 1. Definitions. As used in this Escrow Agreement the following terms have the following meanings: "Eligible Securities" means noncallable, nonprepayable, obligations listed in Exhibit B attached hereto. "Escrow Agent" means BNY Western Trust Company, or any successor thereto appointed under this Escrow Agreement. "Escrow Fund" means the fund by that name created pursuant to Section 2 hereof. "Escrowed Securities" means (i) any of those certain Eligible Securities listed in Exhibit B to this Escrow Agreement, and (ii) any Eligible Security sold to the Escrow Agent pursuant to the terms of the Forward Sale Agreement. "Forward Sale Agreement"means the Escrow Fund Forward Sale Agreement dated as of January 1, 2001 between the Escrow Agent and the Provider, in the form attached hereto as Exhibit D. "Provider" means "Rating Agency(ies)" means, collectively and severally, Standard & Poor's, a division of the McGraw-Hill Companies, Inc. and Moody's Investors Service, Inc. "Rating Confirmation" means written confirmation from each Rating Agency to the effect that the action or amendment proposed to be taken in connection with such Rating Confirmation will not result in a downgrading or withdrawal of the rating on the Refunded Bonds. "Refunded Bonds" means a portion of the Outstanding County of Contra Costa Taxable Pension Obligation Bonds, Series 1994. "Refunding Bonds"means the County's Taxable Pension Obligation Bonds Refunding Series 2001, issued pursuant to the Trust Agreement. "Refunding Requirements" means all installments of principal and interest on the Refunded Bonds, to and including the final date of Refunded Bonds which is June 1, 2011, as such payments become due, as shown in Exhibit A to this Escrow Agreement. DOCSSF1:471618.3 2 sad "State" means the State of California. All other capitalized terms used but not defined herein shall have the respective meanings given to such terms in the Trust Agreement. Section 2. Creation and Purpose of Escrow. A. There is hereby created and established with the Escrow Agent a special and irrevocable trust fund designated as the "County of Contra Costa Taxable Pension Obligation Bonds, 1994 Series A Escrow Fund" (the"Escrow Fund"). The Escrow Agent shall keep the Escrow Fund separate and apart from all other funds and moneys held by it and shall hold the Escrow Fund in trust for the purposes described herein. B'. On the date of the delivery of the Refunding Bonds to the initial purchasers thereof, the Trustee, pursuant to Section 14.01 of the Supplemental Trust Agreement, will deposit with the Escrow Agent in escrow, to be held and accounted for in the Escrow Fund and paid out as provided in this Escrow Agreement and in the Trust Agreement, moneys representing a portion of the proceeds from the sale of the Refunding Bonds, in the amount of$ Such moneys, together with the Fee Amount of$ delivered under the Forward Sale Agreement, shall be sufficient for the purchase of the Escrowed Securities and to make the cash deposit to the Escrow Fund.and shall be used by the Escrow Agent (i) to purchase the Escrowed Securities and make such cash deposit on such date, and (ii) to comply with the purchase, sale, delivery and payment requirements of the Forward Sale Agreement. The Escrow Agent is hereby authorized and directed to enter into the Forward Sale Agreement and to take all actions required thereunder by the Escrow Agent. The amount of initial cash deposit and amount of funds allocated to the purchase of the Escrowed Securities for the Escrow Fund are as follows: Escrow Fund: Beginning Cash: $ Purchase of Escrowed Securities: $ The principal of and interest on the Escrowed Securities and any uninvested cash held hereunder in each Escrow Fund shall be applied by the Escrow Agent to the payment of the Refunding Requirements related to such Escrow Fund. C. Except as provided in the Forward Sale Agreement, the funds held in the Escrow Fund shall not be subject to withdrawal other than to satisfy the Refunding Requirements. D. The County has determined, as verified by the report of an Independent Certified Public Accountant, dated January_, 200.1 (the "Verification Report"), that the Escrowed Securities are such that, if interest thereon and principal thereof are paid when due, the Docssru:471618.3 3 proceeds from the collection of such interest and principal, together with any uninvested cash held hereunder, will be sufficient to meet the Refunding Requirements. E. The Escrow Agent shall hold all Escrowed Securities, whether acquired as initial investments, subsequent investments or reinvestments hereunder, and the money received from time to time as principal and interest thereon, in trust, to secure and for the payment of the Refunding Requirements and shall collect the principal of and interest on the Escrowed Securities held by it hereunder promptly as such principal and interest become due, subject only to compliance with the requirements of the Forward Sale Agreement. Section 3. Bondholder Notices. The Escrow Agent is hereby irrevocably instructed to mail, as soon as practicable, a notice of the defeasance of the Refunded Bonds in the form attached hereto as Exhibit C in accordance with Section 9.01(b) of the Original Trust Agreement. Section 4. Accounting for Escrow: Substitutions. A. The moneys and the Escrowed Securities from time to time accounted for in the Escrow Fund shall not be subject to withdrawal by the County nor otherwise subject to their order except as otherwise provided in Sections 2 and 8 hereof and in order to comply with the requirements of the Forward Sale Agreement. B. the County may from time to time direct the.Escrow Agent to sell, exchange or substitute Escrowed Securities; provided that there shall be no sale, exchange or substitution .of the Escrowed Securities, unless the following are received:.(i) the written direction of the County, (ii) receipt by the County and the Escrow Agent of a new Verification Report, prepared by an Independent Certified Public Accountant, verifying the sufficiency of the escrow to pay all current interest when due on the outstandirig Refunded Bonds in full to and including their respective maturity dates and to pay when due all maturing principal on the Refunded Bonds in full on their respective maturity dates (taking into account the cancellation of Refunded Bonds purchased by the County for cancellation, including Refunded Bonds placed in escrow with the Trustee for purchase from the proceeds of the sale of Escrowed Securities), (iii) receipt of an opinion of nationally recognized.bond counsel that such investment will not adversely affect the validity of the Refunding Bonds or the Refunded Bonds under State law and (iv) a Rating Confirmation. The requirements of this Section 4 shall not apply with respect to the sales from time to time to the Escrow Agent of Qualified Eligible Securities under and pursuant to the terms of the Forward Sale Agreement. Section 5. Investments and Reinvestments. Except in order to comply with the requirements of the Forward Sale Agreement, the Escrow Agent shall have no other obligation by virtue.of this Escrow Agreement, general trust law or otherwise, to make any investment or reinvestment of any moneys in escrow at any time except as expressly provided in the Forward Sale Agreement or except as expressly directed oocssrI:471618.3 4 r sa y a-G-ai by the County and upon receipt,but only in case of such County direction, of(i) the written direction of the County, (ii) receipt by the County and the Escrow Agent of a new Verification Report, prepared by an Independent Certified Public. Accountant, verifying.the sufficiency of the escrow to pay all current interest when due on the outstanding Refunded Bonds in full to and including their respective maturity dates and to pay when due all maturing principal on the Refunded Bonds in frill on their respective maturity dates (taking into account the cancellation of Refunded Bonds purchased by the County for cancellation, including Refunded Bonds placed in escrow with the Trustee for purchase from the proceeds of the sale of Escrowed Securities), (iii) receipt of an opinion of nationally recognized bond counsel that such investment will not adversely affect the validity of the Refunding Bonds or the Refunded Bonds under State law and (IV) a Rating Confirmation. Section 6. Sufficiency of Escrow. Moneys deposited in the Escrow Fund, including the investment earnings thereon and any uninvested cash, shall be in.an amount, as determined by the County, which at all times shall be sufficient to meet the Refunding Requirements not theretofore met. Section 7. Transfers for Payment of Refunded Bonds. The Escrow Agent shall make from time to time such transfers to the Trustee for the Refunded Bonds as will assure, to the extent of moneys in the Escrow Fund, the payment of the Refunding Requirements when due, as provided herein and in the Trust Agreement. Section 8. Termination of Escrow Agreement; Written Request of County. When the Escrow Agent shall have transferred, pursuant to Section 7 hereof, such moneys as are required to pay in full and discharge all of the Refunded Bonds,the Escrow Agent, after payment of all fees and expenses of the Escrow Agent,.shall immediately pay over to the County or its order the moneys, if any, then remaining in the Escrow Fund and shall make forthwith a final report to the County, and this Escrow Agreement shall terminate. The Prior Trustee shall pay to the County any and all unclaimed moneys as provided in Section 9.02 of the Original Trust Agreement and this shall constitute the Written Request.of the County for such purpose. Section 9. Fees and Costs. A. The Escrow Agent's fees, expenses and reimbursement for costs incurred for and in carrying out the provisions of this Escrow Agreement have been fixed by separate agreement. The Escrow Agent shall also be entitled to additional fees, expenses and reimbursement for costs incurred, including but not limited to, legal and accounting services in connection with any litigation or other proceedings which may at any time be instituted involving this Escrow Agreement not due to the negligence or willful misconduct of the Escrow Agent. Under no circumstances shall any fees, expenses or reimbursement of costs of the DocSSF1:471618.3 5 5"D. Escrow Agent or any other party (including without limitation, the cost of any required Verification Report) be paid out of amounts held in the Escrow Fund. B. Payments to the Escrow Agent pursuant to this Section 9 shall not be for deposit in the Escrow Fund, and the fees of and the costs incurred by the Escrow Agent shall not be a charge on and in no event shall be deducted from the Escrow Fund. Section 10. Reports. A. On January 1, 2002 and on July 1 and January 1 of each year thereafter until the termination of this Escrow Agreement, the Escrow Agent shall submit to the County a report covering all money it shall have received and all payments it shall have made or caused to be made hereunder during the preceding six-month period, including all purchases under the Forward Sale Agreement. Such report shall be subject to audit by the County or by such Independent Certified Public Accountant, as may be designated by the County. B. The last report shall be made at the time provided in'Section 8 hereof. C. Each such report shall also list all Escrowed Securities and Qualified Eligible Securities and the amount of money accounted for in the Escrow Fund on the day preceding the date of such report,:except for the last report. Section 11. Character of Deposit. A. It is recognized that title to the Escrowed Securities and moneys accounted for in the Escrow Fund from time to time be vested in the Escrow Agent but subject always to the prior trust, charge and lien thereon of this Escrow Agreement in favor of the owners of the Refunded Bonds and the use thereof required to be made by the provisions hereof. B. The Escrow Agent shall hold all such securities and moneys in the Escrow Fund as special trust funds separate and wholly segregated from all other securities and funds of the Escrow Agent or deposited therein, and shall never commingle such securities or moneys with other securities or moneys. C. No money paid into and accounted for in the Escrow Fund shall ever be considered as a banking deposit and the Escrow Agent shall have no right or title with respect thereto except in its capacity as Escrow Agent hereunder. Section 12. Exculpatory Provisions. A. The duties and responsibilities of the Escrow Agent are limited to those expressly and specifically stated in this Escrow Agreement. B: The Escrow Agent shall not be liable or responsible for any loss resulting from any investment or reinvestment made pursuant to this Escrow Agreement and made in DOCSSFI:471618.3 6 D. y compliance with the provisions hereof. The Escrow Agent shall not be liable or responsible for the accuracy of any calculations or the sufficiency of any Escrowed Securities, the Escrow Fund or any moneys held by it to meet the Refunding Requirements. C. No provision of this Escrow Agreement shall be construed to relieve the Escrow Agent from liability for its own negligent failure to act or its own willful misconduct. D. The Escrow Agent shall be. under no obligation to inquire.into or be in any way responsible for the performance or nonperformance by the County of any of its obligations, nor shall it be responsible in any manner for the recitals or statements contained herein or in the Refunded Bonds or any proceedings taken in connection therewith, such recitals and statements being made solely by the County. The Escrow Agent may conclusively rely on any opinion, written request, certificate, written direction or report of the County, any certified public accountant, financial advisor or investment bank delivered to it and received in good faith in connection with the transactions contemplated hereby and by the Forward Sale .Agreement. E. Nothing in this agreement shall be construed to create any obligations or liabilities on the part of the Escrow Agent to anyone other than the County, the holders of the Refunded Bonds and the Provider. F. The Escrow Agent may at any time resign by giving thirty (30) days written notice to the County of such resignation. .The County shall promptly appoint a successor Escrow Agent by the resignation.date. Resignation of the Escrow Agent will be effective only upon acceptance of appointment by a successor Escrow Agent. If the County does not appoint a successor, the Escrow Agent may petition any court of competent jurisdiction for the appointment of a successor Escrow Agent, which court may thereupon, after such notice, if any, as it may deem proper and prescribe and as may be required by law, appoint a successor Escrow Agent. After receiving a notice of resignation of an Escrow Agent, the County may appoint a temporary Escrow Agent to replace the resigning Escrow Agent until the County appoints a successor Escrow Agent. Any such temporary Escrow Agent so appointed by the County shall immediately and without further act be superseded by the successor Escrow Agent so appointed.. G. The County, to the extent permitted by law, agrees to indemnify the Escrow Agent, its agents and its officers or employees for and hold the Escrow Agent, its agents, officers or employees harmless from and against any and all liabilities, obligations, losses, damages, penalties, actions,judgments, suits, claims, costs, expenses and disbursements of any kind or nature whatsoever(including, without limitation, reasonable fees and disbursements of counsel for the Escrow Agent) which may be imposed on, incurred by, or asserted against the Escrow . Agent at any time by reason of the performance of its duties as Escrow Agent hereunder, in any transaction.arising out of this Escrow Agreement, the Forward Sale Agreement or the Trust Agreement or any of the transactions contemplated herein or in the Trust Agreement, unless due .to the Escrow Agent's or its officers' or employees' or agents' negligence or willful misconduct. Such indemnity shall survive the termination of this Escrow Agreement or resignation of the Escrow Agent. DOCSSr1:471618.3 7 H. The Escrow Agent may consult with counsel, who may be counsel of or to the County, with regard to legal questions and the opinion of such counsel shall be full and complete. authorization in respect of any action taken or suffered by it hereunder in good faith and in accordance therewith. Section 13. Time of Essence. Time shall be of the essence in the performance of the obligations from time to time imposed upon the Escrow Agent by this Escrow Agreement. Section 14. Amendments. This Escrow Agreement may not be revoked or amended by the parties hereto unless there.shall first have been filed with the County and the Escrow Agent (i) a written opinion of nationally recognized bond counsel stating that such amendment will not adversely affect the validity of the Refunded Bonds or the Refunding Bonds under State law, (ii) a Rating Confirmation and (iii) unless such amendment is not materially adverse to the interests of the registered owners of the Refunded Bonds, the written consent of all the owners of the Refunded Bonds then outstanding. Notice of any amendment to this Escrow Agreement shall be delivered by the Escrow Agent to the Rating Agencies. Section 15. Successors. A. Whenever herein the County or the Escrow Agent is named or is referred to, such provision shall be deemed to include any successor of the County or the Escrow Agent, respectively, immediate or intermediate, whether so expressed or not. The Rating Agencies shall be provided with notice of any change to the Escrow Agent. B. All of the stipulations, obligations and agreements by or on behalf of, and other provisions for the benefit of, the County or the Escrow Agent contained herein: (1) Shall bind and inure to the benefit of any such successor; and (2) Shall bind and shall inure to the benefit of any officer, board, authority, agent or instrumentality to whom or to which there shall be transferred by or in accordance with law any right, power or duty of the County or the Escrow Agent, respectively, or of its successor. Section 16. Notices.. All notices and communications hereunder shall be in writing and shall be deemed to be duly given if received or sent by first class mail to the following addresses or to such other.address as the recipient thereof shall request in.writing to the other party hereto: Docssl;1:471618.3 8 If to the County: County of Contra Costa County Administrator's Office 651 Pine Street Martinez, California 94553-0063 If to the Escrow Agent: BNY Western Trust Company 700 S. Flower St, Suite 500 Los Angeles, CA 90017 Attn: Corporate Trust If to the Rating Agencies: Standard&Poor's 55 Water Street, 38th Floor New York, NY 10041 Attn: Municipal Structured Group Moody's Investors Service 99 Church Street, 9th Floor New York,NY 10007 Attn: Anthony Plank Section 17. Severability. If any section, paragraph, clause or provision of this Escrow Agreement shall for any reason be held to be invalid or unenforceable, the invalidity or unenforceability of such section, paragraph, clause or provision shall not affect any of the remaining provisions of this Escrow Agreement. The Rating Agencies shall be notified of any determination of unenforceability or invalidity of any portion of this Escrow Agreement. Section 18. Law Governing. This Escrow Agreement is made in the State of California and is to be construed under the Constitution and laws of such State. Section 19. Counterparts. This Escrow Agreement may be executed in several counterparts, each of which shall be an original and all of which shall constitute but one and the same instrument. DOCSSF1:471618.3 9 IN WITNESS WHEREOF, the COUNTY OF CONTRA COSTA has caused this Escrow Agreement to be signed in its name by its duly authorized officer, and BNY WESTERN COMPANY, has caused this Escrow Agreement to be signed in its name by its duly authorized officer, all as of the day and year first above written. COUNTY OF.CONTRA COSTA By: Chair of the Board of Supervisors ATTEST: Clerk of the Board of Supervisors BNY WESTERN TRUST COMPANY, as Escrow Agent By: Authorized Officer DOCSSPI: 7.1618.3 EXHIBIT A REFUNDING REQUIREMENTS Period Interest Principal Ending Due Due Total Total DOCSSF1:471618.3 A-1 • Sa.'/ EXHIBIT B ESCROWED SECURITIES The following securities will be deposited into the Escrow Fund on January 2001: Initial Cash Deposit: $ Issue Maturity Coupon Par Price Total Money CLSIP Docssr1:471618.3 B-1 s�,y no/ EXHIBIT C NOTICE OF DEFEASANCE Notice to the Holders of Outstanding County of Contra Costa Taxable Pension Obligation Bonds, 1994 Series A CUSIP# NOTICE IS HEREBY GIVEN that the COUNTY OF CONTRA COSTA (the "County") has on January_, 2001, from the proceeds of the sale of pension obligation general fund bonds [and other sources], irrevocably set aside in an Escrow Fund created for such purpose and held by BNY Western Trust Company, moneys which the County has determined, when added to the investment earnings therefrom, shall be sufficient to pay the principal of and interest on the outstanding bonds referenced above (the "Bonds"), as such payments become due up to and including June 1, 2011, the final maturity for the Bonds. The moneys so deposited in escrow (including the earnings derived from the investment thereof) are irrevocably pledged to the payment of principal, premium and interest on the outstanding Bonds. Said moneys have been invested in permitted investments pursuant to the Trust Agreement defined in the next paragraph, which result in.the assignment of"AAA" and "Aaa" ratings to the Bonds by Standard & Poor's, a division of the McGraw-Hill Companies, Inc. and Moody's Investors Service Inc., respectively,and the first supplement thereto dated as of January 1, 2001 (the "First Supplement").and which bear interest and mature on such dates as to insure the payment of interest on the outstanding Bonds as such interest becomes due and to pay the principal on the Bonds on each maturity date therefor, to and including the final maturity date of June 1, 2011. As a consequence of the foregoing actions and in accordance with the Trust Agreement;dated as of February 1, 1994 as amended by the First Supplement (collectively the "Trust Agreement"), between the County and BNY Western Trust Company, as trustee (the "Trustee"), providing for the Bonds, the Bonds are deemed paid in accordance with Section 9.01 of the Trust Agreement. Additional information regarding the foregoing actions may be obtained from BNY Western Company. DOCSSF1:471 6 u s.3 C-I f sD, EXHIBIT D ESCROW FUND FORWARD SALE AGREEMENT DOCSS F 1:471 G 18.3 D-1 spy EXHIBIT E ELIGIBLE SECURITIES [insert revised list of permitted defeasance securities asset forth in Exhibit B to the First Supplemental Trust Agreement] No other securities or investments not specifically described above (including without limitation unit investment trusts and mutual funds) may be considered "Eligible Securities" hereunder. DOCSSFI-471618.3 PRELIMINARY OFFICIAL STATEMENT DATED ;' ,2001 NEW ISSUE—BOOK-ENTRY ONLY RATINGS: TAXABLE(FEDERAL),TAX-EXEMPT(CALIFORNIA) See"RATINGS" herein In the opinion of Orrick, Herrington & Sutcliffe LLP, Bond Counsel, based upon existing laws, regulations, rulings and court decisions, interest on the 2001 Bonds is exempt from State of California personal income taxes. Interest on the 2001 Bonds is not excludable front gross income for federal income tax purposes. Bond Counsel expresses no opinion regarding any other tax consequences related to the ownership or disposition of, or the accrual or receipt of interest on, the 2001 Bonds. See "TAX MATTERS" herein. COUNTY OF CONTRA COSTA, CALIFORNIA [SEAL] TAXABLE PENSION OBLIGATION BONDS, REFUNDING SERIES 2001 Dated: Date of Delivery Price: 100% Due: June 1, 2014 The County of Contra Costa, California Taxable Pension Obligation Bonds, Refunding Series 2001 (the "2001 Bonds") are being issued to purchase and cancel, pursuant to a tender offer program, and/or refunding, a portion of the County of Contra Costa, California Taxable Pension Obligation Bonds, 1994 Series A (the "1994 Bonds") and to pay the costs of issuance relating to the 2001 Bonds. See"PLAN OF REFUNDING"and"ESTIMATED SOURCES AND USES OF FUNDS"herein. The 2001 Bonds will be issued pursuant to the Trust Agreement, dated as of February 1, 1994, between the County of Contra Costa, California(the "County") and BNY Western Trust Company, as successor trustee (the "Trustee"), as supplemented by the First Supplemental Trust Agreement, dated as of December 1,2000,between the County and the Trustee(together,the"Trust Agreement"). The 2001 Bonds will be absolute and unconditional obligations imposed upon the County by law. The 2001 Bonds will be payable on a parity basis with the 1994 Bonds and will not be limited as to payment to any special source of funds of the County. The 2001 Bonds will be issued as fully registered bonds and, when issued, will be registered in the name of Cede & Co., as nominee of The Depository Trust Company,New York, New York("DTC"). DTC will act as securities depository of the 2001 Bonds. Individual purchases of 2001 Bonds will be made in book-entry form only. Payments of principal of, premium, if any, and interest on the 2001 Bonds are to be made to purchasers by DTC through DTC Participants. Purchasers will not receive physical delivery of the 2001 Bonds purchased by them. See"DESCRIPTION OF THE 2001 BONDS—Book-Entry System"herein. The 2001 Bonds will be issued initially in denominations of$100,000 and any integral multiple of$5,000 in excess thereof. The 2001 Bonds will be dated the date of initial issuance and delivery, and interest thereon will accrue initially at a Weekly Rate. The first interest payment date for the 2001 Bonds will be _,2001*. The 2001 Bonds are subject to redemption prior to maturity as described herein. The 2001 Bonds are subject to mandatory tender upon certain events as described herein. While in certain interest rate modes, the 2001 Bonds may be purchased upon the demand of the beneficial owner thereof at a price equal to the principal amount thereof plus accrued interest. The purchase price of the 2001 Bonds is payable from the proceeds of remarketing of such 2001 Bonds, and, to the extent remarketing proceeds are unavailable, from amounts available under a Standby Bond Purchase Agreement,dated as of January 1, 2001 (the "Liquidity Facility"), between the County and.Westdeutsche Landesbank Girozentrale, acting through its New York Branch (the "Bank"). The obligation of the Bank to purchase tendered but unremarketed 2001 Bonds is subject to suspension or termination upon the occurrence of certain events. Unless extended or terminated, the Liquidity Facility will expire on See "DESCRIPTION OF THE 2001 BONDS,""THE LIQUIDITY FACILITY"and"THE BANK"herein. THE 2001 BONDS DO NOT CONSTITUTE AN OBLIGATION OF THE COUNTY FOR WHICH THE COUNTY IS OBLIGATED TO LEVY OR PLEDGE ANY FORM OF TAXATION. NEITHER THE 2001 BONDS NOR THE OBLIGATION OF THE COUNTY TO MAKE PAYMENTS WITH RESPECT TO THE 2001 BONDS CONSTITUTES A DEBT OR AN INDEBTEDNESS OF THE COUNTY, THE STATE OF CALIFORNIA, OR ANY OF ITS POLITICAL SUBDIVISIONS WITHIN THE MEANING OF ANY CONSTITUTIONAL OR STATUTORY DEBT LIMITATION OR RESTRICTION. The 2001 Bonds are offered-when, as and if issued and received by the Underwriter, and subject to the approval of validity by Orrick, Herrington & Sutcliffe LLP, Bond Counsel, and certain other conditions. C.M. de Crinis &Co., Inc. is serving as Financial Advisor to the County in connection with the issuance of the 2001 Bonds. Certain legal matters will be passed upon for the County by County Counsel,.for the Underwriter by its counsel, Fulbright & Jaworski L.L.P., Los Angeles, California, and for.the Bank by its counsel, Winston & Strawn,New York,New York. It is expected that the 2001 Bonds will be available for delivery through the DTC book-entry system on or about February_,2001. BEAR, STEARNS & CO. INC. THIS COVER PAGE CONTAINS INFORMATION FOR REFERENCE ONLY. IT IS NOT A SUMMARY OF THIS TRANSACTION. INVESTORS MUST READ THE ENTIRE OFFICIAL STATEMENT TO OBTAIN INFORMATION ESSENTIAL TO MAKE AN INFORMED INVESTMENT DECISION. Dated: February,_,2001 *Preliminary,subject to change 10021499/594236.4 w97 No dealer, broker, •salesperson or other person has been authorized by the County of Contra Costa, California (the "County") or the Underwriter to give any information or to make any representations, other than as contained in this Official Statement, and if given or.made such other information or representations must not be relied upon'as having been authorized by the County or the Underwriter. This Official Statement does not constitute an offer to sell or the solicitationof an offer to buy, nor shall there be any sale of the 2001 Bonds by any person in any jurisdiction in which it is unlawful for such persons to make such offer, solicitation or sale. This Official Statement is not to be construed as a contract with the purchasers of the 2001 Bonds. Statements contained in this Official Statement which involve estimates, forecasts or matters of opinion, whether or not expressly described herein, are intended solely as such and are not to be construed as representations of fact. The information set forth herein has been furnished by the County, and includes information obtained from other sources which are believed to be reliable. The information and expressions of opinion contained herein are subject to change without notice and neither the delivery of this Official Statement nor any sale made hereunder shall, under any circumstances, create any implication that there has been no change in the affairs of the County since the date hereof. The Underwriter has provided the following sentence for inclusion in this Official Statement: The Underwriter has reviewed the information in this Official Statement in accordance with, and as part of, its responsibilities to investors under the federal securities laws as applied to the facts and circumstances of this transaction,but the Underwriter does not guarantee the accuracy or completeness of such information. IN MAKING AN INVESTMENT DECISION, INVESTORS MUST RELY ON THEIR OWN EXAMINATION OF THE COUNTY AND THE TERMS OF THE OFFERING, INCLUDING THE MERITS AND RISKS INVOLVED. THE 2001 BONDS HAVE NOT BEEN APPROVED OR DISAPPROVED BY THE SECURITIES AND EXCHANGE COMMISSION OR ANY STATE SECURITIES COMMISSION NOR HAS THE SECURITIES AND EXCHANGE COMMISSION OR ANY STATE SECURITIES COMMISSION PASSED UPON THE ACCURACY OR ADEQUACY OF THIS OFFICIAL STATEMENT. IN CONNECTION WITH THE OFFERING OF THE 2001 BONDS, THE UNDERWRITER MAY OVERALLOT OR EFFECT TRANSACTIONS WHICH STABILIZE OR MAINTAIN THE. MARKET PRICE OF THE 2001 BONDS AT LEVELS ABOVE THAT WHICH MIGHT OTHERWISE PREVAIL IN THE OPEN MARKET.. SUCH STABILIZING, IF COMMENCED, MAY BE DISCONTINUED AT ANY TIME. Certain statements included or incorporated by reference in this Official Statement constitute "forward-looking statements." Such statements are generally identifiable by the terminology used such as "Plan," "project;" "expect," "anticipate," "intend," "believe," "estimate," "budget" or other similar words. The achievement of certain results or other expectations contained in such forward-looking statements involve known and unknown risks, uncertainties and other factors that may cause actual results, performance or achievements described to be materially different from any future results, performance or achievements expressed or implied by such forward-looking statements. The County does not plan to issue any updates or revisions to those forward-looking statements if or when its expectations are met or events, conditions or circumstances on which such statements are based occur. 10021499/594236.4 w97 COUNTY OF CONTRA COSTA, CALIFORNIA BOARD OF SUPERVISORS . Donna Gerber (District 3) Chair John Gioia Gayle B. Uilkema (District 1) (District 2) (Vice-Chair) Mark DeSaulmer Joe Canciamilla (District 4) (District 5) COUNTY OFFICIALS Philip J. Batchelor Clerk of the Board and County.Administrator Laura W. Lockwood Director, Capital Facilities and Debt Management Kenneth J. Corcoran William J. Pollacek Auditor-Controller Treasurer-Tax Collector Victor J. Westman Stephen L. Weir County Counsel County Clerk-Recorder BOND COUNSEL FINANCIAL ADVISOR Orrick, Herrington & Sutcliffe LLP C.M. de Crinis & Co., Inc. San Francisco, California Sausalito, California .UNDERWRITER'S COUNSEL Fulbright &Jaworski L.L.P. Los Angeles, California 10021499/594236.4 w97 TABLE OF CONTENTS Page SUMMARYSTATEMENT......................................................................................................................I The County of Contra Costa, California........................................................................................i The 2001 Bonds; Purpose of the Issue...........................................................................................i Security and Source of Payment for the 2001 Bonds...........................................'........................ii Bond Registration and Book-Entry System..................................................................................ii Redemption of 2001 Bonds; Mandatory Tender of 2001 Bonds..................................................ii INTRODUCTORY STATEMENT.......................................................................................................... 1 DESCRIPTION OF THE 2001 BONDS..................................................................................................2 General..........................................................................................................................................2 Intereston the 2001 Bonds ...........................................................................................................3 Optional Tender for Purchase of 2001 Bonds...............................................................................5 Mandatory Purchase of 2001 Bonds.............................................................................................6 Payment of Purchase Price............................................................................................................6 Redemption of the 2001 Bonds..............:.......................................................................................8 Book-Entry.System........................................................................................................................9 PLAN OF REFUNDING........................................................................................................................ 1.1 THE LIQUIDITY FACILITY................................................................................................................ 1.1 THEBANK ............................................................................................................................................ 12 Background Information.............................................................................................................. 1.2 TheNew York Branch................................................................................................................ 13 Summary of Results of Operations and Financial Condition fore the Fiscal Year Ended December31, 1999.........................................................................................................13 United States and German Exchange Rates, and Generally Accepted Accounting Principles.........................................................................................................................13 SECURITY AND SOURCE OF PAYMENT FOR THE 2001 BONDS............................................... 14 Obligation Imposed by Law; Deposits to Trustee ......................................................................14 Interest Reserve Account............................................................................................................ 15 ESTIMATED SOURCES.AND USES OF FUNDS ..............................................................................15 ,DEBT SERVICE REQUIREMENTS.....................................................................................................16 COUNTY INFORMATION................................................................................................................... 17 CONSTITUTIONAL AND STATUTORY LIMITATIONS ON TAXES, REVENUES AND APPROPRIATIONS................................................................................................................... 17 Article XIII A of the California Constitution ............................................................................. 17 Legislation Implementing Article XIII A................................................................................... 17 Article XIII B of the California Constitution.............................................................................. 18 Article XIII C and Article XIII D of the California Constitution............................................... 18 Proposition62............................................................................................................................. 19 Proposition187...........................................................................................................................20 Future Initiatives and Changes of Law.......................................................................................21 Limitations on Remedies ............................................................................................................21 TAXMATTERS.....................................................................................................................................22 APPROVAL OF LEGALITY.................................................................................................................22 ValidationProceedings................................................................................................................22 Opinionsof Counsel ...................................................................................................................22 LITIGATION..........................................................................................................................................23 RATINGS...............................................................................................................................................23 UNDERWRITING .................................................................................................................................23 VERIFICATION OF MATHEMATICAL COMPUTATIONS.............................................................23 ADDITIONAL INFORMATION...........................................................................................................24 10021499/594236.4 w97 Si7. G Table of Contents - Contimled Page APPENDIX A-GENERAL COUNTY ECONOMIC AND DEMOGRAPHIC INFORMATION...........................................................................................................................A-1 APPENDIX B -COUNTY FINANCIAL INFORMATION....................................................................B-1 APPENDIX C -AUDITED FINANCIAL STATEMENTS OF THE COUNTY FOR THE FISCAL YEAR ENDED JUNE 30, 2000 ..................................................................0-1 APPENDIX D- SUMMARY OF CERTAIN PROVISIONS OF THE TRUST AGREEMENT.............................................................................................................................D-1 APPENDIX E -PROPOSED FORM OF BOND COUNSEL OPINION.................................................E-1 10021499/594236.4 w97 SID. y SUMMARY STATEMENT This Summary Statement is subject in all respects to the more complete information contained in this Official Statement, and the offering of the County of Contra Costa, California Taxable Pension Obligation Bonds, Refunding Series 2001 to potential purchasers is made only by means of the entire Official Statement. The County of Contra Costa, California The County of Contra Costa, California (the "County") was incorporated in 1850 as one of the original 27 counties of the State of California. The County lies northeast of San Francisco and is the ninth most populous county in California. The County seat is in the City. of Martinez. Major industries in the County include petroleum refining, telecommunications, financial and retail services, steel manufacturing, prefabricated metals, chemicals, electronic equipment, paper products and food processing. For the fiscal year ended June 30, 2000, the County's General Fund budget totaled approximately$888.2 million. The 2001 Bonds; Purpose of the Issue The County Employees Retirement Law of 1937, California Government Code Sections 31450 et seq. (the "Retirement Law") obligates the County (i) to appropriate, annual contributions' to the Contra Costa County Employees' Retirement Association (the "Association") to fund pension benefits for its employees and (ii) to amortize the then current unfunded accrued actuarial liability with respect to such pension benefits. In 1994, the County issued a debenture (the "Debenture") to the Association as evidence of the County's obligations to the Association. Also in 1994, the County issued $337,365,000. of its Taxable Pension Obligation Bonds, 1994 Series A (the "1994 Bonds") pursuant to a trust agreement, dated as of February 1, 1994 (the "Original Trust Agreement"), to refund the Debenture and to provide a payment obligation with an effective interest rate lower than the rate charged to the County on its then current unfunded accrued actuarial liability. The County of Contra Costa, California Taxable Pension Obligation Bonds, Refunding Series 2001 (the "2001 Bonds," and together with the'1994 Bonds, the "Bonds") are being issued to purchase and cancel, pursuant to a tender offer program, and/or refund, a portion of the 1994 Bonds and to pay the costs of issuance relating to the 2001 Bonds. .The County believes that by purchasing and/or refunding a portion of the 1994 Bonds, it may be able to reduce its debt service costs prior to the final maturity of the 1994 Bonds on June 1, 2011. In addition, the County intends to restructure the amortization schedule of the Bonds (including the 2001 Bonds) so that the final maturity of the Bonds occurs on June 1, 2014. The 2001 Bonds are being issued pursuant to the Original Trust Agreement and the First Supplemental Trust Agreement thereto, dated as of December 1, 2000.(together with the Original Trust Agreement, the "Trust Agreement"), between the County and BNY Western Trust Company, as trustee (the "Trustee"). The 2001 Bonds will be payable on a parity with the 1994 Bonds and any Additional Bonds (as defined in Appendix D attached hereto) hereafter issued by the County. Issuance of the 2001 Bonds was approved by a resolution of the Board of Supervisors of the County (the "Board of Supervisors") adopted on November 14, 2000. 10021499/594236.4 w97 The 2001 Bonds will be issued initially in denominations of $100,000 and any integral multiple of$5,000 in excess thereof. The 2001 Bonds will be dated the date of initial issuance and delivery,,and interest thereon will accrue initially at a Weekly Rate. Security and Source of Payment for the 2001 Bonds The obligation of the County to make payments with respect to the 2001 Bonds is an absolute and unconditional obligation of the County imposed upon the County by law and enforceable against the County pursuant to the Retirement Law. Payment of principal of, premium, if any, and interest on the 2001 Bonds is not limited to any special source of finds. The Trust Agreement provides that the County is obligated to deposit or cause to be deposited with the Trustee the amount which, together with any amounts transferred from the Surplus Account, will be sufficient to.pay the County's obligations on the Bonds for each fiscal year within 30 days of the commencement of such fiscal year. Pursuant to. the Retirement Law, the Board of Supervisors is obligated to make appropriations to pay the unfunded accrued actuarial liability which is evidenced by the Bonds. In the event the Board of Supervisors fails or neglects to make appropriations and transfers in respect of its obligation to. pay the Bonds, the Retirement Law requires that the County Auditor transfer from any money available in any fund in the County treasury amounts necessary to.make such payments, with such transfer having the same force and effect as an appropriation by the Board of Supervisors. No assurance can be given as to the amount and source of funds available in the County treasury for such transfer at any particular time. THE 2001 BONDS DO NOT CONSTITUTE AN OBLIGATION OF THE COUNTY FOR WHICH THE COUNTY IS OBLIGATED. TO LEVY OR PLEDGE ANY FORM OF TAXATION. NEITHER THE 2001 BONDS NOR THE OBLIGATION OF THE COUNTY TO MAKE PAYMENTS WITH RESPECT. TO THE 2001 BONDS CONSTITUTES A DEBT OR AN INDEBTEDNESS OF THE COUNTY, THE STATE OF CALIFORNIA, OR ANY OF ITS POLITICAL SUBDIVISIONS. WITHIN THE MEANING OF ANY CONSTITUTIONAL OR STATUTORY DEBT LIMITATION OR RESTRICTION. Bond Registration and Book-Entry.System The 2001 Bonds will be issued as fully registered bonds and, when issued, will be registered in the name of Cede & Co., as nominee of The Depository Trust Company, New York, New York ("DTC"), DTC will act as securities depository of the 2001 Bonds. Individual purchases of 2001 Bonds will be made in book-entry form only. Payments of principal of, premium, if any, and interest on the 2001 Bonds are to be made to purchasers by DTC through DTC participants. Purchasers will not receive physical delivery of the 2001 Bonds purchased by r them. Redemption of 2001.Bonds; Mandatory Tender of 2001 Bonds The 2001 Bonds are subject to optional redemption and mandatory sinking fund redemption prior to maturity as described herein. 10021499/594236.4 w97 11 S 1J• Z-6-ol The 2001 Bonds are subject to mandatory tender upon certain events as described herein. While in certain interest rate modes, the 2001 Bonds may be purchased upon the demand of the beneficial owner thereof at a price equal to the principal amount thereof plus accrued interest. The purchase price of the 2001 Bonds is payable from the proceeds of remarketing of such 2001 Bonds and, to the extent remarketing proceeds are unavailable, from amounts available under the Standby Bond Purchase Agreement, dated as of January 1, 2001 (the "Liquidity Facility"), between the County and Westdeutsche Landesbank Girozentrale, acting through its New York Branch (the "Bank"). The obligation of the Bank to purchase tendered but unremarketed 2001 Bonds is subject to suspension or termination upon the occurrence of certain events. 10021499/594236.4 w97 in