Cancelled Bonds 812105 011184 1\i/; (P/c4
REGISTERED REGISTERED
NUMBER R-1 $250,000.00
Unless this certificate is presented by an authorized representative of The
Depository Trust Company, a New York Corporation ("DTC"), to the Issuer or its
agent for registration of transfer, exchange or payment, and any certificate issued is
registered in the name of Cede & Co. or in such other name as is requested by an
authorized representative of DTC (and any payment is made to Cede & Co. or to•
•��•• uch other entity as is requested by an authorized representative of DTC), ANY
,TRANSFER, PLEDGE OR OTHER USE HEREOF FOR VALUE OR
' °°°bTH1rR'WISE BY OR TO ANY PERSON IS WRONGFUL inasmuch as the
• registecec>,ewner hereof, Cede& Co., has an interest herein.
.r
••.•i •••. Ate
• • ,• UNITED STATES OF AMERICA•
•• • • • STATE OF KANSAS
• • ••
• .'CITY OF SALINA
• GENERAL OBLIGATION INTERNAL IMPROVEMENT BOND
••• SERIES 2011-A
0
Interest Maturity Dated CUSIP:
Rate: 5.000% Date: October 1,2012 Date: July 15, 2011 794743 Y81 O
00
REGISTERED OWNER: CEDE & CO.
PRINCIPAL AMOUNT: TWO HUNDRED FIFTY THOUSAND DOLLARS
U
KNOW ALL PERSONS BY THESE PRESENTS: That the City of Salina, in the County of Z W
Saline, State of Kansas (the "Issuer"), for value received, hereby acknowledges itself to be indebted and Q Co
promises to pay to the Registered Owner shown above, or registered assigns, but solely from the source' }` �.
and in the manner herein specified, the Principal Amount shown above on the Maturity Date shown
above, unless called for redemption prior to said Maturity Date, and to pay interest thereon at the Interest a
Rate per annum shown above (computed on the basis of a 360-day year of twelve 30-day months), from Z
the Dated Date shown above, or from the most recent date to which interest has been paid or duly --- W
provided for, payable semiannually on April 1 and October 1 of each year, commencing April 1, 201: 0
(the"Interest Payment Dates"),until the Principal Amount has been paid. O
Method and Place of Payment. The principal or redemption price of this Bond shall be paid a CO
maturity or upon earlier redemption to the person in whose name this Bond is registered at the maturity o 0
redemption date thereof, upon presentation and surrender of this Bond at the principal office of thi Z
Treasurer of the State of Kansas, Topeka, Kansas (the "Paying Agent" and "Bond Registrar"). Th p
interest payable on this Bond on any Interest Payment Date shall be paid to the person in whose name thi CO
Bond is registered on the registration books maintained by the Bond Registrar at the close of business oir
the Record Date(s) for such interest, which shall be the 15th day (whether or not a business day) of the
calendar month next preceding the Interest Payment Date. Such interest shall be payable (a)by check or
draft mailed by the Paying Agent to the address of such Registered Owner shown on the Bond Register or
at such other address as is furnished to the Paying Agent in writing by such Registered Owner; or, (b) in
the case of an interest payment to Cede & Co. or any Owner of$500,000 or more in aggregate principal
• B12105 011185
amount of Bonds, by electronic transfer to such Owner upon written notice given to the Bond Registrar
by such Registered Owner,not less than 15 days prior to the Record Date for such interest, containing the
electronic transfer instructions including the bank, ABA routing number and account number to which j
such Registered Owner wishes to have such transfer directed. The principal or redemption price of and 1
interest on the Bonds shall be payable in any coin or currency that, on the respective dates of payment
thereof, is legal tender for the payment of public and private debts. Interest not punctually paid will be
paid in the manner established in the within defined Bond Resolution.
•••••Definitions. Capitalized terms used herein and not otherwise defined herein shall have the
meanings assigned to such terms in the hereinafter defined Bond Resolution.
••••
•.•• • Authdrizaiion of Bonds. This Bond is one of an authorized series of Bonds of the Issuer
deSat$d "General Obligation Internal Improvement Bonds, Series 2011-A," aggregating the principal
�;�,- amdunt'of $6 65!�t70 (the "Bonds") issued for the purposes set forth in the Ordinance of the Issuer
• • au4ojlying the issuance of the Bonds and the Resolution of the Issuer prescribing the form and details of
the Bonds (cogeotively, the "Bond Resolution"). The Bonds are issued by the authority of and in full
....• .
•• complienge wile the provisions, restrictions and limitations of the Constitution and laws of the State of
Kanaas,9ncluding K.S.A. 10-101 to 10-125, inclusive, K.S.A. 10-620 et seq. and K.S.A. 12-6a01 et seq.,
K.S.E1..12-685 et seg., K.S.A. 65-163u, Charter Ordinance No. 34 and Article 12, Section 5 of the
Constitution of the State of Kansas, as amended, and all other provisions of the laws of the State of
Kansas applicable thereto.
General Obligations. The Bonds constitute general obligations of the Issuer payable as to both
principal and interest in part from special assessments levied upon the property benefited by the
construction of certain Improvements (as said term is described in the Bond Resolution) and, if not so
paid, from ad valorem taxes which may be levied without limitation as to rate or amount upon all the
taxable tangible property, real and personal, within the territorial limits of the Issuer, the balance being
payable from ad valorem taxes which may be levied without limitation as to rate or amount upon all the
taxable tangible property,real and personal, within the territorial limits of the Issuer. The full faith, credit
and resources of the Issuer are hereby pledged for the payment of the principal of and interest on this
Bond and the issue of which it is a part as the same respectively become due.
Redemption Prior to Maturity. The Bonds are subject to redemption prior to maturity, as
follows:
Optional Redemption. At the option of the Issuer, Bonds maturing on October 1 in the years
2019, and thereafter, will be subject to redemption and payment prior to maturity on October 1, 2018, and
thereafter, as a whole or in part (selection of maturities and the amount of Bonds of each maturity to be
redeemed to be determined by the Issuer in such equitable manner as it may determine) at any time, at the
redemption price of 100% (expressed as a percentage of the principal amount),plus accrued interest to the
date of redemption.
Mandatory Redemption. Each of the Bonds maturing on October 1, 2031 shall also be subject to
mandatory redemption and payment prior to maturity pursuant to the redemption schedule set forth in the
Bond Resolution at the Redemption Price of 100% (expressed as a percentage of the principal amount),
plus accrued interest thereon to the Redemption Date.
Redemption Denominations. Whenever the Bond Registrar is to select Bonds for the purpose of
redemption, it shall, in the case of Bonds in denominations greater than a minimum Authorized
Denomination, if less than all of the Bonds then Outstanding are to be called for redemption, treat each
2
B12105 011186
minimum Authorized Denomination of face value of each such Bond as though it were a separate Bond in
the denomination of a minimum Authorized Denomination.
Notice of Redemption. Notice of redemption, unless waived, shall be given by the Issuer to the
State Treasurer of Kansas, the Purchaser of the Bonds and to the Bond Registrar in accordance with the
Bond Resolution. The Issuer shall cause the Bond Registrar to notify each Registered Owner at the
address maintained on the Bond Register, such notice to be given by mailing an official notice of
redemption by first class mail at least 30 days prior to the redemption date. Notice of redemption having
bo En tten as aforesaid, the Bonds or portions of Bonds to be redeemed shall, on the redemption date,
become.due and payable at the redemption price therein specified, and from and after such date (unless
thnIssuer defatltSIn the payment of the redemption price), such Bonds or portions of Bonds shall cease
to bear interes{.....
......
took-LMtVSystem. The Bonds are being issued by means of a book-entry system with no
phyiria•distribiution of bond certificates to be made except as provided in the Bond Resolution. One
•• Bond•certificati vzithrespect to each date on which the Bonds are stated to mature or with respect to each
form o€.11onds, ftgis'tered in the nominee name of the Securities Depository, is being issued and required
to be deposited with the Securities Depository and immobilized in its custody. The book-entry system
will,evid&ce positions held in the Bonds by the Securities Depository's participants,beneficial ownership
of the Bonds in authorized denominations being evidenced in the records of such participants. Transfers
of ownership shall be effected on the records of the Securities Depository and its participants pursuant to
rules and procedures established by the Securities Depository and its participants. The Issuer and the
Bond Registrar will recognize the Securities Depository nominee, while the Registered Owner of this
Bond, as the owner of this Bond for all purposes, including (i) payments of principal of, and redemption
premium, if any, and interest on, this Bond, (ii)notices and (iii)voting. Transfer of principal, interest and
any redemption premium payments to participants of the Securities Depository, and transfer of principal,
interest and any redemption premium payments to beneficial owners of the Bonds by participants of the
Securities Depository will be the responsibility of such participants and other nominees of such beneficial
•
owners. The Issuer and the Bond Registrar will not be responsible or liable for such transfers of
payments or for maintaining, supervising or reviewing the records maintained by the Securities
Depository, the Securities Depository nominee, its participants or persons acting through such
participants. While the Securities Depository nominee is the owner of this Bond, notwithstanding the
provision hereinabove contained, payments of principal of, redemption premium, if any, and interest on
this Bond shall be made in accordance with existing arrangements among the Issuer, the Bond Registrar
and the Securities Depository.
Transfer and Exchange. EXCEPT AS OTHERWISE PROVIDED IN THE BOND
RESOLUTION, THIS GLOBAL BOND MAY BE TRANSFERRED, IN WHOLE BUT NOT IN
PART, ONLY TO ANOTHER NOMINEE OF THE SECURITIES DEPOSITORY OR TO A
SUCCESSOR SECURITIES DEPOSITORY OR TO A NOMINEE OF A SUCCESSOR
SECURITIES DEPOSITORY. This Bond may be transferred or exchanged, as provided in the Bond
Resolution, only on the Bond Register kept for that purpose at the principal office of the Bond Registrar,
upon surrender of this Bond, together with a written instrument of transfer or authorization for exchange
satisfactory to the Bond Registrar duly executed by the Registered Owner or the Registered Owner's duly
authorized agent, and thereupon a new Bond or Bonds in any Authorized Denomination of the same
maturity and in the same aggregate principal amount shall be issued to the transferee in exchange therefor
as provided in the Bond Resolution and upon payment of the charges therein prescribed. The Issuer shall
pay all costs incurred in connection with the issuance, payment and initial registration of the Bonds and
the cost of a reasonable supply of bond blanks. The Issuer and the Paying Agent may deem and treat the
person in whose name this Bond is registered on the Bond Register as the absolute owner hereof for the
• purpose of receiving payment of, or on account of, the principal or redemption price hereof and interest
3
•
B12105011187 •
•
due hereon and for all other purposes. The Bonds are issued in fully registered form in Authorized
Denominations.
Authentication. This Bond shall not be valid or become obligatory for any purpose or be
entitled to any security or benefit under the hereinafter defined Bond Resolution until the Certificate of
_ _ Authentication_and Registration hereon shall have been lawfully_executed by_the Bond Registrar. _ _-
IT IS HEREBY DECLARED AND CERTIFIED that all acts, conditions, and things required
to.te•tgne and to exist precedent to and in the issuance of this Bond have been properly done and
performed and do exist in due and regular form and manner as required by the Constitution and laws of
th2 Stare:of KytSaY,and that the total indebtedness of the Issuer, including this series of bonds, does not
exceed any cortstitaii•onal or statutory limitation.
.�,,,. • IN WIN�SS WHEREOF, the Issuer has caused this Bond to be executed by the manual or
••.:.. facsa signature of its Mayor and attested by the manual or facsimile signature of its Clerk, and its seal
•• to be affixed heeetp oCimprinted hereon.
• •
• •
CITY OF SALINA,KANSAS
iaso
:frt
cs
By: 4 $
Mayor
ATTEST:
By:
yutacigatAL4i
Clerk •
•
•
•
•
4•
B12105 011188
CERTIFICATE OF CLERK
STATE OF KANSAS
)-SS.
COUNTY OF SALINE )•
•�••jhe undersigned, Clerk of the City of Salina, Kansas, does hereby certify that the within Bond
has been.duly registered in my office according to law as of July 15, 2011.
•
•••• • WITNESS•my hand and official seal.: •
. may' `' •.....
.. .. ;< •.
• • •Y
•. Clerk
•••••• CERTIFICATE OF STATE TREASURER
OFFICE OF THE TREASURER, STATE OF KANSAS
RON ESTES, Treasurer of the State of Kansas, does hereby certify that a transcript of the
proceedings leading up to the issuance of this Bond has been,filed in,the office of the State Treasurer, and
that this Bond was registered in such office according to.law on JUL 2.8 2011 . •
WITNESS my hand and official seal.
(Seal) By: / 9 'Z
Treasurer of the State of Kansas
CERTIFICATE OF AUTHENTICATION AND REGISTRATION
This Bond is one of a series of General Obligation Internal Improvement Bonds, Series 2011-A,
of the City of Salina, Kansas, described in the within-mentioned Bond Resolution.
Registration Date JUL 2,8 2011
Office of the State Treasurer,
Topeka, Kansas,
as Bond Registrar and Paying Agent
By go71/
Registration Number 0322-085-071511-028
5
B12105 011189
•
BOND ASSIGNMENT
FOR VALUE RECEIVED,the undersigned do(es) hereby sell, assign and transfer to
.. •
'• '.•• (Name and Address)
•
• ••••' (Social Security or Taxpayer Identification No.)
•..•..
..•... •
•.... the JQad to whist this assignment is affixed in the outstanding principal amount of $
•.. stafhdirsg in the,name of the undersigned on the books of the Bond Registrar. The undersigned do(es)
hereby irrevocably constitute and appoint as agent to transfer said Bond on the
bogkSdf said Bond Registrar with full power of substitution in the premises.
Dated•••
Name
Social Security or
Taxpayer Identification No.
Signature (Sign here exactly as name(s)
appear on the face of Certificate)
Signature guarantee:
By
6
B12105 011190
• LEGAL OPINION
The following is a true and correct copy of the approving legal opinion of Gilmore & Bell, P.C.,
Bond Counsel, which was dated and issued as of the date of original issuance and delivery of such Bonds:
.. •
• • • GILMORE & BELL,P.C.
• Attorneys at Law
• 2405 Grand Boulevard
""• •0.00• Suite 1100
.000.•
Kansas City, Missouri 64108
.... •
• • •
•
.•••• 0000 • ..
•0 • • •
•
• • •
•000.0 •• •
.••••
GovBMinl Body
City of$aiina,Kansas
Hutchinson, Shockey, Erley&Co.
Chicago, Illinois
Re: $6,565,000 General Obligation Internal Improvement Bonds, Series 2011-A, of
the City of Salina,Kansas,Dated July 15, 2011
We have acted as Bond Counsel in connection with the issuance by the City of Salina, Kansas
(the "Issuer"), of the above-captioned bonds (the `Bonds"). In this capacity, we have examined the law
and the certified proceedings, certifications and other documents that we deem necessary to render this
opinion. Capitalized terms not otherwise defined herein shall have the meanings ascribed thereto in the
resolution adopted by the governing body of the Issuer prescribing the details of the Bonds.
Regarding questions of fact material to our opinion, we have relied on the certified proceedings
and other certifications of public officials and others furnished to us without undertaking to verify them
by independent investigation.
Based upon the foregoing, we are of the opinion, under existing law, as follows:
1. The Bonds have been duly authorized, executed and delivered by the Issuer and are valid
and legally binding general obligations of the Issuer.
2. The Bonds are payable as to both principal and interest in part from special assessments
levied upon the property benefited by the construction of certain improvements and, if not so paid, from
ad valorem taxes which may be levied without limitation as to rate or amount upon all the taxable tangible
property, real and personal, within the territorial limits of the Issuer. The balance of the principal and
interest on the Bonds is payable from ad valorem taxes which may be levied without limitation as to rate
or amount upon all the taxable tangible property, real and personal, within the territorial limits of the
Issuer. The Issuer is required by law to include in its annual tax levy the principal and interest coming
due on the Bonds to the extent that necessary funds are not provided from other sources.
7
B12105 011191 •
3. The interest on the Bonds (including any original issue discount properly allocable to an
owner of a Bond) is: (a) excluded from gross income for federal income tax purposes; and(b)not an item
of tax preference for purposes of the federal alternative minimum tax imposed on individuals and
corporations, but is taken into account in determining adjusted current earnings for the purpose of
computing the alternative minimum tax imposed on certain corporations. The opinions set forth in this
paragraph are subject to the condition that the Issuer comply with all requirements of the Internal
Revenue Code of 1986, as amended (the"Code"), that must be satisfied subsequent to the issuance of the
Bonds in order to preserve the exclusion of the interest on the Bonds from gross income for federal
interne:tax purposes. The Issuer has covenanted to comply with all of these requirements. Failure to
•
complywith certain of these requirements may cause interest on the Bonds to be included in gross income
fdt;Mft-al inwitR•t,ax purposes retroactive to the date of issuance of the Bonds. The Bonds have not -
•••• beendesignattdas.'qualified tax-exempt obligations" for purposes of Section 265(b) of the Code. We
•••••• exprgsAyo opinion regarding other federal tax consequences arising with respect to the Bonds.
•••••• • •
••••• •
•
• • 4. • The interest on the Bonds is exempt from income taxation by the State of Kansas.
•• • •• •••I•• :•• ....We express ' no opinion regarding the accuracy, completeness or sufficiency of the Official
Sta1ament or other offering material relating to the Bonds (except to the extent, if any, stated in the
Offic,i4,3tatement). Further, we express no opinion regarding tax consequences arising with respect to
the Bonds other than as expressly set forth in this opinion.
The rights of the owners of the Bonds and the enforceability thereof may be limited by
bankruptcy, insolvency, reorganization, moratorium and other similar laws affecting creditors' rights
generally and by equitable principles,whether considered at law or in equity.
This opinion is given as of its date, and we assume no obligation to revise or supplement this
opinion to reflect any facts or circumstances that may come to our attention or any changes in law that
may occur after the date of this opinion.
GILMORE &BELL, P.C.
8
a '
B12105 011192
p28
REGISTERED REGISTERED
NUMBER R-2 $300,000.00
Unless this certificate is presented by an authorized representative of The
Depository Trust Company, a New York Corporation ("DTC"), to the Issuer or its
agent for registration of transfer, exchange or payment, and any certificate issued is
registered in the name of Cede & Co. or in such other name as is requested by an
authorized representative of DTC (and any payment is made to Cede & Co. or to
such other entity as is requested by an authorized representative of DTC), ANY
TRANSFER, PLEDGE OR OTHER USE HEREOF FOR VALUE OR
OTHERWISE BY OR TO ANY PERSON IS WRONGFUL inasmuch as the
registered owner hereof, Cede& Co., has an interest herein.
UNITED STATES OFAMERICA
STATE OF KANSAS
CITY OF SALINA
GENERAL OBLIGATION INTERNAL IMPROVEMENT BOND
SERIES 2011-A
Z ....
0 Interest Maturity Dated CUSW:...
m Rate: 5.000% Date: October 1,2013 Date: July 15, 2011 ••;7947431:99
H REGISTERED OWNER: CEDE & CO. ��•••� s ..:. ••••••
PRINCIPAL AMOUNT: THREE HUNDRED THOUSAND DOLLARS
HU :...:.
Z W KNOW ALL PERSONS BY THESE PRESENTS: That the City of Salina, in the Countx of
Saline, State of Kansas (the "Issuer"), for value received, hereby acknowledges itself to be indeb?e&&nd
promises to pay to the Registered Owner shown above, or registered assigns, but solely from the source
and in the manner herein specified, the Principal Amount shown above on the Maturity Date shown
d Z above, unless called for redemption prior to said Maturity Date, and to pay interest thereon at the Interest
W I Rate per annum shown above (computed on the basis of a 360-day year of twelve 30-day months), from
Y the Dated Date shown above, or from the most recent date to which interest has been paid or duly
0 provided for, payable semiannually on April 1 and October 1 of each year, commencing April 1, 2012
0 (the"Interest Payment Dates"), until the Principal Amount has been paid.
m
Method and Place of Payment. The principal or redemption price of this Bond shall be paid at
p _ maturity or upon earlier redemption to the person in whose name this Bond is registered at the maturity or
ZO redemption date thereof, upon presentation and surrender of this Bond at the principal office of the
m Treasurer of the State of Kansas, Topeka, Kansas (the "Paying Agent' and "Bond Registrar"). The
interest payable on this Bond on any Interest Payment Date shall be paid to the person in whose name this
Bond is registered on the registration books maintained by the Bond Registrar at the close of business on
the Record Date(s) for such interest, which shall be the 15th day (whether or not a business day) of the
calendar month next preceding the Interest Payment Date. Such interest shall be payable (a) by check or
draft mailed by the Paying Agent to the address of such Registered Owner shown on the Bond Register or
at such other address as is furnished to the Paying Agent in writing by such Registered Owner; or, (b) in
the case of an interest payment to Cede & Co. or any Owner of$500,000 or more in aggregate principal
b
B12105 011193
amount of Bonds, by electronic transfer to such Owner upon written notice given to the Bond Registrar
by such Registered Owner, not less than 15 days prior to the Record Date for such interest, containing the
electronic transfer instructions including the bank, ABA routing number and account number to which
such Registered Owner wishes to have such transfer directed. The principal or redemption price of and
interest on the Bonds shall be payable in any coin or currency that, on the respective dates of payment
thereof, is_legal_tender_for_the payment of public and,private_debts. Interest not-punctually paid will be_
paid in the manner established in the within defined Bond Resolution.
Definitions. Capitalized terms used herein and not otherwise defined herein shall have the
meanings assigned to such terms in the hereinafter defined Bond Resolution.
Authorization of Bonds. This Bond is one of an authorized series of Bonds of the Issuer
designated "General Obligation Internal Improvement Bonds, Series 2011-A," aggregating the principal
amount of $6,565,000 (the "Bonds") issued for the purposes set forth in the Ordinance of the Issuer
1 authorizing the issuance of the Bonds and the Resolution of the Issuer prescribing the form and details of
the Bonds (collectively, the "Bond Resolution"). The Bonds are issued by the authority of and in full
iI compliance with the provisions, restrictions and limitations of the Constitution and laws of the State of
Kansas, including K.S.A. 10-101 to 10-125,'inclusive, K.S.A. 10-620 et seq. and K.S.A. 12-6a01 et seq.,
K.S.A. 12-685 et seq., K.S.A. 65-163u, Charter Ordinance No. 34 and Article 12, Section 5 of the
Constitution of the State of Kansas, as amended, and all other provisions of the laws of thg State of
Kansas applicable thereto. ;""•
General Obligations. The Bonds constitute general obligations of the Issuor payable aato40th •.....
principal and interest in part from special assessments levied upon the prop4V.-b,nefited by the ••••
construction of certain Improvements (as said term is described in the Bond Resolutionn,�g,and,. not-so ••;••,
paid, from ad valorem taxes which may be levied without limitation as to rate or.aula'aIt up n all the •""
taxable tangible property, real and personal, within the territorial limits of the Issuer, the bala e%Ing '•��•
payable from ad valorem taxes which may be levied without limitation as to rate or tMdunt upon all the ••„••
taxable tangible property, real and personal, within the territorial limits of the Issuer.'T&-full fatb., �it
and resources of the Issuer are hereby pledged for the payment of the principal of and interest on this
Bond and the issue of which it is a part as the same respectively become due.
Redemption Prior to Maturity. The Bonds are subject to redemption prior to maturity, as
follows:
Optional Redemption. At the option of the Issuer, Bonds maturing on October 1 in the years
2019, and thereafter, will be subject to redemption and payment prior to maturity on October I, 2018, and
thereafter, as a whole or in part (selection of maturities and the amount of Bonds of each maturity to be
redeemed to be determined by the Issuer in such equitable manner as it may determine) at any time, at the
redemption price of 100% (expressed as a percentage of the principal amount),plus accrued interest to the
date of redemption.
Mandatory Redemption. Each of the Bonds maturing on October 1, 2031 shall also be subject to
mandatory redemption and payment prior to maturity pursuant to the redemption schedule set forth in the
Bond Resolution at the Redemption Price of 100% (expressed as a percentage of the principal amount),
plus accrued interest thereon to the Redemption Date.
Redemption Denominations. Whenever the Bond Registrar is to select Bonds for the purpose of
redemption, it shall, in the case of Bonds in denominations greater than a minimum Authorized
Denomination, if less than all of the Bonds then Outstanding are to be called for redemption, treat each
2
812105 011194
minimum Authorized Denomination of face value of each such Bond as though it were a separate Bond in
the denomination of a minimum Authorized Denomination.
Notice of Redemption. Notice of redemption, unless waived, shall be given by the Issuer to the
State Treasurer of Kansas, the Purchaser of the Bonds and to the Bond Registrar in accordance with the
Bond Resolution— The_Issuer shall cause the Bond-Registrar to.notify_each Registered_Owner at the
address maintained on the Bond Register, such notice to be given by mailing an official notice of
redemption by first class mail at least 30 days prior to the redemption date. Notice of redemption having
been given as aforesaid, the Bonds or portions of Bonds to be redeemed shall, on the redemption date,
become due and payable at the redemption price therein specified, and from and after such date (unless
the Issuer defaults in the payment of the redemption price), such Bonds or portions of Bonds shall cease
to bear interest.
Book-Entry System. The Bonds are being issued by means of a book-entry system with no
physical distribution of bond certificates to be made except as provided in the Bond Resolution. One
Bond certificate with respect to each date on which the Bonds are stated to mature or with respect to each
form of Bonds, registered in the nominee name of the Securities Depository, is being issued and required
to be deposited with the Securities Depository and immobilized in its custody. The book-entry system
will evidence positions held in the Bonds by the Securities Depository's participants,beneficial ownership
of the Bonds in authorized denominations being evidenced in the records of such participants. ,Tran.9fers
of ownership shall be effected on the records of the Securities Depository and its participants pu?suaat to
rules and procedures established by the Securities Depository and its participants. The Issueraed,the
Bond Registrar will recognize the Securities Depository nominee, while the Register, OwneYdf this
Bond, as the owner of this Bond for all purposes, including (i) payments of principj0k, 'nd redemption ••
premium, if any, and interest on, this Bond, (ii) notices and (iii)voting. Transfer of principal, intelg5tand •':".
an redemption premium payments to participants of the Securities Depository, and• ans' r of rind al,
Y P P P Y P P P D', � � � P
interest and any redemption premium payments to beneficial owners of the Bonds by paiticipa 1s bf the
Securities Depository will be the responsibility of such participants and other nomineV Zit-such beneficial ',...'
owners. The Issuer and the Bond Registrar will not be responsible or liable for•sach traysiAr:.of
payments or for maintaining, supervising or reviewing the records maintained by the Securities
Depository, the Securities Depository nominee, its participants or persons acting throujt,'g$h
participants. While the Securities Depository nominee is the owner of this Bond, notwithstanding the
provision hereinabove contained, payments of principal of, redemption premium, if any, and interest on
i this Bond shall be made in accordance with existing arrangements among the Issuer, the Bond Registrar
and the Securities Depository.
Transfer and Exchange. EXCEPT AS OTHERWISE PROVIDED IN THE BOND
RESOLUTION, THIS GLOBAL BOND MAY BE TRANSFERRED, IN WHOLE BUT NOT IN
PART, ONLY TO ANOTHER NOMINEE OF THE SECURITIES DEPOSITORY OR TO A
SUCCESSOR SECURITIES DEPOSITORY OR TO A NOMINEE OF A SUCCESSOR
SECURITIES DEPOSITORY. This Bond may be transferred or exchanged, as provided in the Bond
Resolution, only on the Bond Register kept for that purpose at the principal office of the Bond Registrar,
upon surrender of this Bond, together with a written instrument of transfer or authorization for exchange
satisfactory to the Bond Registrar duly executed by the Registered Owner or the Registered Owner's duly
authorized agent, and thereupon a new Bond or Bonds in any Authorized Denomination of the same
maturity and in the same aggregate principal amount shall be issued to the transferee in exchange therefor
as provided in the Bond Resolution and upon payment of the charges therein prescribed. The Issuer shall
pay all costs incurred in connection with the issuance, payment and initial registration of the Bonds and
the cost of a reasonable supply of bond blanks. The Issuer and the Paying Agent may deem and treat the
person in whose name this Bond is registered on the Bond Register as the absolute owner hereof for the
purpose of receiving payment of, or on account of, the principal or redemption price hereof and interest
3
b ' ,
B12105 011195
due hereon and for all other purposes. The Bonds are issued in fully registered form in Authorized
Denominations.
Authentication. This Bond shall not be valid or become obligatory for any purpose or be
entitled to any security or benefit under the hereinafter defined Bond Resolution until the Certificate of
_ ---Authentication-and-Registration hereon shall have,been lawfully executed.by_the Bond Registrar.._..
IT IS HEREBY DECLARED AND CERTIFIED that all acts, conditions, and things required
to be done and to exist precedent to and in the issuance of this Bond have been properly done and
performed and do exist in due and regular form and manner as required by the Constitution and laws of
the State of Kansas, and that the total indebtedness of the Issuer, including this series of bonds, does not
exceed any constitutional or statutory limitation.
IN WITNESS WHEREOF, the Issuer has caused this Bond to be executed by the manual or
facsimile signature of its Mayor and attested by the manual or facsimile signature of its Clerk, and its seal
to be affixed hereto or imprinted hereon.
�I
CITY OF SALINA,KANSAS
o
zero �.....
By:
....
ATTEST:
Mayor
/ ......
BY: ....
Clerk :...:.
4
e '
B12105 011196
CERTIFICATE OF CLERK
STATE OF KANSAS )
)_SS.
COUNTY OF SALINE )
The undersigned, Clerk of the City of Salina, Kansas, does hereby certify that the within Bond
has been duly registered in my office according to law as of July 15, 2011.
WITNESS my hand and official seal.
W ��
B y: i
I
ss=°
i Clerk J
CERTIFICATE OF STATE TREASURER
°
000000
OFFICE OF THE TREASURER, STATE OF KANSAS
:10000 ,JJJ=J
RON ESTES, Treasurer of the State of Kansas, does hereby certify that°a •transcript of the
proceedings leading up to the issuance of this Bond has been filed in the office of the SZate`Treasu-er;,and °°„°°
that this Bond was registered in such office according to law on JUL 2, 8 2011 YJ°° ° o
000OJ 00000
0
. 0. .1. ..° 00.100.1
WITNESS my hand and official seal. 0000
0 '1000°a
0
J '
(Seal) By:
J
Treasurer of the State of Kansas 00 00
CERTIFICATE OF AUTHENTICATION AND REGISTRATION
r This Bond is one of a series of General Obligation Internal Improvement Bonds, Series 2011-A,
of the City of Salina, Kansas, described in the within-mentioned Bond Resolution.
Registration Date JILL Z 8 2011
Office of the State Treasurer,
Topeka, Kansas,
as Bond Registrar and Paying Agent
By
Registration Number 0322-085-071511-028
B12105 011199
3. The interest on the Bonds (including any original issue discount properly allocable to an
owner of a Bond) is: (a) excluded from gross income for federal income tax purposes; and (b) not an item
of tax preference for purposes of the federal alternative minimum tax imposed on individuals and
corporations, but is taken into account in determining adjusted current earnings for the purpose of
computing the alternative minimum tax imposed on certain corporations. The opinions set forth in this
paragraph are subject to the condition that the Issuer comply with-all_require_ments.of the Internal
Revenue Code of 1986, as amended (the "Code"), that must be satisfied subsequent to the issuance of the
Bonds in order to preserve the exclusion of the interest on the Bonds from gross income for federal
income tax purposes. The Issuer has covenanted to comply with all of these requirements. Failure to
comply with certain of these requirements may cause interest on the Bonds to be included in gross income
for federal income tax purposes retroactive to the date of issuance of the Bonds. The Bonds have not
been designated as "qualified tax-exempt obligations" for purposes of Section 265(b) of the Code. We
express no opinion regarding other federal tax consequences arising with respect to the Bonds.
4. The interest on the Bonds is exempt from income taxation by the State of Kansas.
We express no opinion regarding the accuracy, completeness or sufficiency of the Official
Statement or other offering material relating to the Bonds (except to the extent, if any, stated in the
Official Statement). Further, we express no opinion regarding tax consequences arising with respect to
the Bonds other than as expressly set forth in this opinion.
The rights of the owners of the Bonds and the enforceability thereof may be limited by
bankruptcy, insolvency, reorganization, moratorium and other similar laws affectinj•creditors,ttghts •.....
generally and by equitable principles, whether considered at law or in equity. '
This opinion is given as of its date, and we assume no obligation to revise,sx•supplepient,this
• ......
opinion to reflect any facts or circumstances That may come to our attention or any changes iryfa'�L'that
may occur after the date of this opinion.
GILMORE & BELL, P.C. '
i
8
812105 011200
• t022
REGISTERED REGISTERED
NUMBER R-3
Unless this certificate is presented by an authorized representative of The
Depository Trust Company, a New York Corporation ("DTC"), to the Issuer or its
agent for registration of transfer, exchange or payment, and any certificate issued is
registered in the name of Cede & Co. or in such other name as is requested by an
authorized representative of DTC (and any payment is made to Cede & Co. or to
such other entity as is requested by an authorized representative of DTC), ANY
TRANSFER, PLEDGE OR OTHER USE HEREOF FOR VALUE OR
OTHERWISE BY OR TO ANY PERSON IS WRONGFUL inasmuch as the
registered owner hereof, Cede & Co., has an interest herein.
. .
......
UNITED STATES OF AMERICA •
STATE OF KANSAS ••••
cCITY OFS-ALINA= \ •••• .• ,
GENERAL OBLIGATION INTERNAL IMPROVEMENT BOND •••• •`
O SERIES 2011-A t._ 'db...
.....•
Z ••0_ -
m ......
Interest Maturity Dated •••• CUSI . ••••
Rate: 5.000% Date: October 1, 2014 Date: July 15, 2011 G7947 • =Z23n
I— ....
1Y
REGISTERED OWNER: CEDE & CO. •
HU
Z W PRINCIPAL AMOUNT: THREE HUNDRED TEN THOUSAND DOLLARS
H CO
cc KNOW ALL PERSONS BY THESE PRESENTS: That the City of Salina,.in the County of
Q H Saline, State of Kansas (the "Issuer"). for value received, hereby acknowledges itself to be indeb et d'and
Cl- z promises to pay to the Registered Owner shown above, or registered assigns, but solely from the source -
E W and in the manner herein specified, the Principal Amount shown above on the Maturity Date shown
• above, unless called for redemption prior to said Maturity Date, and to pay interest thereon at the Interest
O Rate per annum shown above (computed on the basis of a 360-day year of twelve 30-day months), from
O the Dated Date shown above, or from the most recent date to which interest has been paid or duly
m provided for, payable semiannually on April 1 and October 1 of each year, commencing April 1, 2012
(the `Interest Payment Dates"), until the Principal Amount has been paid.
0
1 Z Method and Place of Payment. The principal or redemption price of this Bond shall be paid at
O maturity or upon earlier redemption to the person in whose name this Bond is registered at the maturity or
m redemption date thereof, upon presentation and surrender of this Bond at the principal office of the
Treasurer of the State of Kansas, Topeka, Kansas (the "Paying Agent" and "Bond Registrar"). The
interest payable on this Bond on any Interest Payment Date shall be paid to the person in whose name this
Bond is registered on the registration books maintained by the Bond Registrar at the close of business on
the Record Date(s) for such interest, which shall be the 15th day (whether or not a business day) of the
calendar month next preceding the Interest Payment Date. Such interest shall be payable (a) by check or
draft mailed by the Paying Agent to the address of such Registered Owner shown on the Bond Register or
at such other address as is furnished to the Paying Agent in writing by such Registered Owner; or, (b) in
the case of an interest payment to Cede & Co. or any Owner of$500,000 or more in aggregate principal
B12105 011201 1
amount of Bonds, by electronic transfer to such Owner upon written notice given to the Bond Registrar
by such Registered Owner, not less than 15 days prior to the Record Date for such interest, containing the
electronic transfer instructions including the bank, ABA routing number and account number to which
such Registered Owner wishes to have such transfer directed. The principal or redemption price of and
interest on the Bonds shall be payable in any coin or currency that, on the respective dates of payment
-_thereof, is_legal tender for the payment of public and_priyate_debts. Interest not_punctually.paid will be
paid in the manner established in the within defined Bond Resolution.
Definitions. Capitalized terms used herein and not otherwise defined herein shall have the
meanings assigned to such terms in the hereinafter defined Bond Resolution.
Authorization of Bonds. This Bond is one of an authorized series of Bonds of the Issuer
designated "General Obligation Internal Improvement Bonds, Series 2011-A," aggregating the principal
amount of S6,565,000 (the "Bonds") issued for the purposes set forth in the Ordinance of the Issuer
authorizing the issuance of the Bonds and the Resolution of the Issuer prescribing the form and details of
the Bonds (collectively, the "Bond Resolution"). The Bonds are issued by the authority of and'Mfull
compliance with the provisions, restrictions and limitations of the Constitution and;la'ts pf the gist! of
Kansas, including K.S.A. 10-101 to 10-125, inclusive, K.S.A. 10-620 et seq. and K.St:1. 12-6a01ej„g., ' '
K.S.A. 12-685 et seq., K.S.A. 65-163u, Charter Ordinance No. 34 and Article isb Setion 5go1•the
Constitution of the State of Kansas, as amended, and all other provisions of the laws pf thettate of -":•••
...
Kansas applicable thereto.
• •
General Obligations. The Bonds constitute general obligations of the Issuer payable as eo both
principal and interest in part from special assessments levied upon the property benefited j he
construction of certain Improvements (as said term is described in the Bond Resolution) and.i1 of so
paid, from ad valorem taxes which may be levied without limitation as to rate or amount upon all the
taxable tangible property, real and personal, within the territorial limits of the Issuer, the balance being
• payable from ad valorem taxes which may be levied without limitation as to rate or amount upon all the
taxable tangible property, real and personal, within the territorial limits of the Issuer. The full faith, credit
and resources of the Issuer are hereby pledged for the payment of the principal of and interest on this
Bond and the issue of which it is a part as the same respectively become due.
Redemption Prior to Maturity. The Bonds are subject to redemption prior to maturity, as
follows:
Optional Redemption. At the option of the Issuer, Bonds maturing on October 1 in the years
• 2019, and thereafter, will be subject to redemption and payment prior to maturity on October 1, 2918, and
thereafter, as a whole or in part (selection of maturities and the amount of Bonds of each maturity to be
redeemed to be determined by the Issuer in such equitable manner as it may determine) at any time, at the
redemption price of 100% (expressed as a percentage of the principal amount), plus accrued interest to the
date of redemption.
Mandatory Redemption. Each of the Bonds maturing on October 1, 2031 shall also be subject to
mandatory redemption and payment prior to maturity pursuant to the redemption schedule set forth in the
Bond Resolution at the Redemption Price of 100% (expressed as a percentage of the principal amount),
plus accrued interest thereon to the Redemption Date.
Redemption Denominations. Whenever the Bond Registrar is to select Bonds for the purpose of
redemption, it shall, in the case of Bonds in denominations greater than a minimum Authorized
Denomination, if less than all of the Bonds then Outstanding are to be called for redemption, treat each
7
•
IIMaNIMIlhaelowe
B12105 011202
minimum Authorized Denomination of face value of each such Bond as though it were a separate Bond in
the denomination of a minimum Authorized Denomination.
Notice of Redemption. Notice of redemption, unless waived, shall be given by the Issuer to the
State Treasurer of Kansas, the Purchaser of the Bonds and to the Bond Registrar in accordance with the
Bond_Resolution.. The Issuer_ shall_cause_the Bond_Registrar to notify_ each.Registered_Owner at the
address maintained on the Bond Register, such notice to be given by mailing an official notice of
redemption by first class mail at least 30 days prior to the redemption date. Notice of redemption having
been given as aforesaid, the Bonds or portions of Bonds to be redeemed shall, on the redemption date,
become due and payable at the redemption price therein specified, and from and after such date (unless
the Issuer defaults in the payment of the redemption price), such Bonds or portions of Bonds shall cease
to bear interest.
Book-Entry System. The Bonds are being issued by means of a book-entry system with•no
physical distribution of bond certificates to. be made except as provided in the Bond Resolution. One
Bond certificate with respect to each date on which the Bonds are stated to mature or'yith respec:fdg'a;h
form of Bonds, registered in the nominee name of the Securities Depository, is being isshejl and regaired
to be deposited with the Securities Depository and immobilized in its custody. The book-entry,sv5jem
will evidence positions held in the Bonds by the Securities Depository's participants,bcpgfjial ou's nsHip ••;
of the Bonds in authorized denominations being evidenced in'the records of such participants. 'Tfi rs •••••
-of ownership shall be effected on the records of the Securities Depository and its participants putTiant to -
rules and procedures established by the Securities Depository and its participants'•ftI•Issue. and the
Bond Registrar will recognize the Securities Depository nominee, while the Registered Owner of:u»s
Bond, as the owner of this Bond for all purposes, including (i) payments of principal of and redetrg2tion
premium, if any, and interest on, this Bond, (ii) notices and (iii) voting. Transfer of principal, intaht and
any redemption premium payments to participants of the Securities Depository, and transfer of principal, .
interest and any redemption premium payments to beneficial owners of the Bonds by participants of the
Securities Depository will be the responsibility of such participants and other nominees of such beneficial
owners. The Issuer and the Bond Registrar will not be responsible or liable for such transfers of
payments or for maintaining, supervising or reviewing the records maintained by the Securities
Depository, the Securities Depository nominee, its participants or persons acting through such
participants. While the Securities Depository nominee is the owner of this Bond, notwithstanding the
provision hereinabove contained, payments of principal of, redemption premium, if any, and interest on
this Bond shall be made in accordance with existing arrangements among the Issuer, the Bond Registrar
and the Securities Depository.
Transfer and Exchange. EXCEPT AS OTHERWISE PROVIDED LN THE .BOND
RESOLUTION, THIS GLOBAL BOND MAY BE TRANSFERRED, IN WHOLE BUT NOT IN
PART, ONLY TO ANOTHER NOMINEE OF THE SECURITIES DEPOSITORY OR TO A
SUCCESSOR SECURITIES DEPOSITORY OR TO A NOMINEE OF A SUCCESSOR
SECURITIES DEPOSITORY. This Bond may be transferred or exchanged, as provided in the Bond
Resolution, only on the Bond Register kept for that purpose at the principal office of the Bond Registrar,
upon surrender of this Bond, together with a written instrument of transfer or authorization for exchange
satisfactory to the Bond Registrar duly executed by the Registered Owner or the Registered Owner's duly
authorized agent, and thereupon a new Bond or Bonds in any Authorized Denomination of the same
maturity and in the same aggregate principal amount shall be issued to the transferee in exchange therefor
as provided in the Bond Resolution and upon payment of the charges therein prescribed. The Issuer shall
pay all costs incurred in connection with the issuance, payment and initial registration of the Bonds and
the cost of a reasonable supply of bond blanks. The Issuer and the Paying Agent may deem and treat the
person in whose name this Bond is registered on the Bond Register as the absolute owner hereof for the
purpose of receiving payment of, or on account of, the principal or redemption price hereof and interest
3
B12105 011203
due hereon and for all other purposes. The Bonds are issued in fully registered form in Authorized
Denominations.
Authentication. This Bond shall not be valid or become obligatory for any purpose or be
entitled to any security or benefit under the hereinafter defined Bond Resolution until the Certificate of
_ ____.Authentication_and_Registration hereon.shall.have been.lawfully.executedbythe Bond Registrar.__
IT IS HEREBY DECLARED AND CERTIFIED that all acts, conditions, and things required
to be done and to exist precedent to and in the issuance of this Bond have been properly done and
performed and do exist in due and regular form and manner as required by the Constitution and laws of
the State of Kansas, and that the total indebtedness of the Issuer, including this series of bonds, does not
exceed any constitutional or statutory limitation.
LN WITNESS WHEREOF, the Issuer has caused this Bond to be executed by the m galor
facsimile signature of its Mayor and attested by the manual or facsimile signature of its Clerk, andits seal
to be affixed •hereto or imprinted hereon. ""•
,.....
". • CITY OF S.ahINA, KA_\SAS •• ...
• I
•
ATTEST: Mayor
„ ,) , •...
By:
SO .- 4 J., •
Clerk
4
812105 011204 ° • 1
CERTIFICATE OF CLERK
STATE OF KANSAS
_. _ )_SS. • -
COUNTY OF SALINE )
The undersigned. Clerk of the City of Salina. Kansas, does hereby certify that the within Bond
has been duly registered in my office according to law as of July 15, 2011.
WI I NESS my hand and official seal. •
„n By:
Clerk `� ••••
• • •
_
•._
CERTIFICATE OF STATE TREASURER ! • •
• „•.,
OFFICE OF THE TREASURER, STATE OF KANSAS •••••
RON ESTES. Treasurer of the State of Kansas. does hereby certify that a transcript of the
proceedings leading up to the issuance of this Bond has been filed in the office of the State Treasuri:f•aitd
that this Bond was registered in such office according to law on
JUL 2 S 2f11
WITNESS my hand and official seal.
(Seal) By:
Treasurer of the State of Kansas
CERTIFICATE OF AUTHENTICATION AND REGISTRATION
This Bond is one of a series of General Obligation Internal Improvement Bonds, Series 2011-A,
of the City of Salina. Kansas, described in the within-mentioned Bond Resolution.
Registration Date JUL Yr 8 2011
Office of the State Treasurer,
Topeka. Kansas,
as Bond Registrar and Paying Agent
•
By
Registration Number 0322-085-071511-028
5
•
1
B12105 011205
BOND ASSIGNMENT
-FOR VALUE RECEIVED:the undersigned do(es)hereby sell, assign-and transfer to
(Name and Address)
(Social Security or Taxpayer Identification No.)-
the Bond to which this assignment is affixed in the outstanding principal amount of S ..:.,
standing in the name of the undersigned on the books of the Bond Registrar. The undersigned does)
hereby irrevocably constitute and appoint as agent to transfer said Bondqtt,jhe
books of said Bond Registrar with full power of substitution in the premises. • • .
Dated .....J
Name •
••••
• ...•..
•
• •
Social Security or •
Taxpayer Identification No.
••••
Signature (Sign here exactly as name(s) •
appear on the face of Certificate)
Signature guarantee:
By
n
6
B12105 011206 ' •
LEGAL OPINION
The following is a true and correct copy of the approving legal opinion of Gilmore & Bell, P.C..
- Bond.Counsel-whichwas.dated.and issued as of-the date of original-issuance and delivery of--such Bonds:
GILMORE & BELL,-P.C.
Attorneys at Law
2405 Grand Boulevard
Suite 1100
Kansas City, Missouri 64108
. •
•
. • •
••••
• ••••••
•• • . ......
Governing Body •• •
•
City of Salina, Kansas
.....
• ......
Hutchinson, Shockey, Erley& Co. ......•
Chicago, Illinois
......
Re: S6,565,000 General Obligation Internal Improvement Bonds, Series 2011-A, of
the City of Salina, Kansas, Dated July 15. 2011 ••
•
We have acted as Bond Counsel in connection with the issuance by the City of Salina. Kansas
(the "Issuer"), of the above-captioned bonds (the "Bonds"). In this capacity, we have examined the law
and the certified proceedings, certifications and other documents that we deem necessary to render this
opinion. Capitalized terms not otherwise defined herein shall have the meanings ascribed thereto in the
resolution adopted by the governing body of the Issuer prescribing the details of the Bonds.
Regarding questions of fact material to our opinion, we have relied on the certified proceedings
and other certifications of public officials and others furnished to us without undertaking to verify them
by independent investigation.
Based upon the foregoing, we are of the opinion, under existing law; as follows:
I. The Bonds have been duly authorized, executed and delivered by the Issuer and are valid
and legally binding general obligations of the Issuer.
2. The Bonds are payable as to both principal and interest in part from special assessments
levied upon the property benefited by the construction of certain improvements and, if not so paid, from
ad valorem taxes which may be levied without limitation as to rate or amount upon all the taxable tangible
property, real and personal, within the territorial limits of the Issuer. The balance of the principal and
interest on the Bonds is payable from ad valorem taxes which may be levied without limitation as to rate
or amount upon all the taxable tangible property, real and personal, within the territorial limits of the
Issuer. The Issuer is required by law to include in its annual tax levy the principal and interest coming
due on the Bonds to the extent that necessary funds are not provided from other sources.
B12105011207 '
3. The interest on the Bonds (including any original issue discount properly allocable to an
• owner of a Bond) is: (a)excluded from gross income for federal income tax purposes; and (b)not an item
of tax preference for purposes of the federal alternative minimum tax imposed on individuals and
corporations, but is taken into account in determining adjusted current earnings for the purpose of
• computing the alternative minimum tax imposed on certain corporations. The opinions set forth in this
- paragraph are_subject to the condition that the Issuer-comply with_all requirements of the _Internal
• Revenue Code of 1956, as amended (the "Code"), that must be satisfied subsequent to the issuance of the
Bonds in order to preserve the exclusion of the interest on the Bonds from gross income for federal
income tax purposes. The Issuer has covenanted to comply with all of these requirements. Failure to
comply with certain of these requirements may cause interest on the Bonds to be included in gross income
for federal income tax purposes retroactive to the date of issuance of the Bonds. The Bonds have not
been designated as "qualified tax-exempt obligations" for purposes of Section 265(b) of the Code. We
express no opinion regarding other federal tax consequences arising with respect to the Bonds.
4. The interest on the Bonds is exempt from income taxation by the State of Kansas. :''''.
We express no opinion regarding the accuracy, completeness or sufficiency-0L the Offit4l
Statement or other offering material relating to the Bonds (except to the extent, if•any,.stated in'the
•
Official Statement). Further, we express no opinion regarding tax consequences arising .'th respi"• t
the Bonds other than as expressly set forth in this opinion. .....'
The rights of the owners of the Bonds and the enforceability thereof }nay De limited by ;"•••
bankruptcy, insolvency, reorganization, moratorium and other similar laws affectin_'creditoX.rj;l}ts ••••
generally and by equitable principles, whether considered at law or in equity.
•
•...
This opinion is given as of its date, and we assume no obligation to revise or supplement this
opinion to reflect any facts or circumstances that may come to our attention or any changes in law that
may occur after the date of this opinion.
GILMORE & BELL, P.C.
s