RES 87418 - Laserfiche WebLink

October , 1987 Page 2 from the Corporation to the City, a Facility Lease (Capital Projects I and II), dated as of October 1, 1987 (the "Facility Lease"), by and between the Corporation and the City, an Assignment Agreement, dated as of October 1, 1987 (the "Assignment Agreement"), by and between the Corporation and Bank of America National Trust and Savings Association, as trustee (the "Trustee"), a Trust Agreement, dated as of October 1, 1987 (the "Trust Agreement"), by and between the Trustee, the Corporation and the City, opinions of counsel with respect to the City, the Corporation, the Trustee and the foregoing documents, and certifications of the City, the Trustee, the Corporation and others as to certain factual matters. Certain requirements and procedures contained or referred to in the Trust Agreement, the Facility Lease and other relevant documents may be changed under the circumstances and subject to the terms and conditions set forth in such documents, upon the advice or with an approving opinion of nationally recognized bond counsel. No opinion is expressed herein as to the interest portion of any Base Rental Payment if any such change occurs or action is taken upon the advice or approval of special counsel other than ourselves. The opinions expressed herein are based on an analysis of existing laws, regulations, rulings and court decisions and cover certain matters not directly addressed by such authorities. Such opinions may be affected by actions taken or events occurring after the date hereof. We have not undertaken to determine, or to inform any person, whether any such actions or events occur. Also, in examining the record of proceedings referred to above, we have assumed the genuiness of all signatures thereto and have not undertaken to verify independently the accuracy of the factual matters represented, warranted or certified therein. Furthermore, we have assumed compliance with all covenants contained in the Site Lease, the Deed of Gift, the Facility Lease, the Assignment Agreement and the Trust Agreement, including (without limitation) covenants compliance with which is necessary to assure that future actions or events will not cause the interest portion of each Base Rental Payment to be includable in gross income for federal income tax purposes. In addition, we call attention to the fact that the rights and obligations under the 1606S