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HomeMy WebLinkAbout4673_CCv0001.pdf RESOLUTION NO. 4573 A RESOLU"T"ION OF THE CITY COUNCIL OF THE CITY OF REDLANDS APPROVING DOCUMENTS RELATING TO THE EXECUTION AND DELIVERY OF ITS INSURED CERTIFICATES OF PARTICI- PATION (REDLANDS COMMUNITY HOSPITAL 1990 _SERIES A WHEREAS, Redlands Community Hospital- __ ( the "Cor- poration" ) Cr-poration" ) has requested the assistance of the City of Redlands ( the "City" ) in financing certain additions, exten- sions, alterations and improvements to the general acute care health facility owned and operated by the Corporation in Redlands, California ( the "Project") through: a proposed installment sale financing arrangement between the Corpora- tion and: the City and the execution and delivery of the City's Insured Certificates of Participation (Redlands Com- munity Hospital Project) , 1990 Series A (the "Certifi- cates" ) ; Certifi-cater" ) ; and WHEREAS, the payments represented by the Certifi- cates are to be insured by the Office of Statewide Health Planning and Development ( the "Office" ) ; and WHEREAS, the City has determined that assisting the Corporation in the financing of the Project is in the best interests of the Citic and of benefit to the residents of the City; and WHEREAS, notice of a public ,hearing to be con- ducted by this City Council with respect to the proposed financing of the Project by the City was duly published at least 14 days prior to July 3, 1990, in a newspaper of gen- eral circulation in the City, which notice set 7:05 p.m. on July 3, 1990 and the City Council chambers as the time and place for said hearing;- and WHEREAS, this City Council is the applicable gov- ernmental v-ernmental unit to conduct said; public hearing for purposes of Section 147{f} of the Internal Revenue Cade of 1955, as amended (the "Code" ) ; and ;REAS, this City Council has duly held said public meeting and hearing with respect to the Project and its proposed financing, all in accordance with Section 147( f) of the Code, at which public hearing interested indi- viduals were riven a reasonable opportunity to express their views on the Project and its proposed financing by the City; and WHEREAS, there has been presented to this City Council a proposed farm of Installment Sale Agreement to b entered into between the City, as purchaser, and the Corpo- ration, as seller ; an Installment Purchase Agreement to be entered into between the Corporation, as purchaser, and the City, as seller ; a Trust Agreement to be entered into among the City, the Corporation and Security Pacific national Bank , as trustee (the "Trustee" ) ; a; Second Assignment Agree- ment 'to be entered; into between the City and the Trustee, Tax Agreement among the City, the Corporation and the Trustee a Contract of Insurance to be entered, into among the City, the Corporation and the Office'; a Regulatory Agreement to be entered .into among the City, the Corporation and the suffice; a Certificate Purchase Contract to be entered into among the City, the Corporation and Goldman, Sachs & Co. ; and a form of Preliminary official. Statement relating to the Certificates NOW, THEREFORE, BE IT RESOLVED, DETERMINED AND ORDERED By THE CITY COUNCIL OF THE CITY OF REDLAND AS FOL- LOWS: L-LOWS Section; 1. Recitals, Ap2roval of Project and Financing} That the above recitals, and each of them, are true and correct and that this City Council hereby approves the Project and its financing by means of an installment sale financing through the execution and delivery of certif- icates of participation subject to the condition that the Corporation will reimburse the City for any expenses incurred in connection with this transaction in the event certificates of participation are not issued. This approval is intended to satisfy the requirements of Section 147(f ) of the Code.. Section 2. Installment Sale Agreement. That the proposed form of Installment Sale Agreement presented at this meeting is hereby approved and the Mayor or Mayor Pro Tem or other appropriate officer and the City Clerk of the City are hereby authorized and directed to execute such Installment Sale Agreement for and in the name of the City, in substantially the form hereby approved with such changes therein as the officers executing the same may approve, such approval to be conclusively evidenced by the execution and delivery thereof. Section 3 . Installment Purchase Agreement. That the proposed form of Installment Purchase Agreement pre- sented at this meeting is hereby approved and the Mayor or Mayor Pro Tem or other appropriate officer and the City Clerk of the City are hereby authorizer and directed, for and in the name of the City, to execute such Installment Purchase Agreement and; the City Bill of Sale ( in substan•- - tially the form attached thereto as Exhibit A) in substan- tially the form hereby approved with such changes therein as the officers executing the same may approve, such approval to be conclusively evidenced by the execution and delivery thereof. Section 4. Trust Agreement . That the proposed form of Trust Agreement presented at this meeting is hereby approved and the Mayor or Mayor Pro Tem or other appropriate officer and the City Clerk of the City are hereby authorized and directed, for and in the name of the City, to execute such Trust Agreement in substantially the form hereby approved with such changes therein ( including any changes necessary or desirable to reflect the fact that the Certifi- cates may be issued as capital appreciation certificates) as the officers executing the same may approve, such approval to be conclusively evidenced by the execution and delivery thereof, provided that such Trust Agreement shall be consis- tent with the provisions of Section 9 hereof. Section 5. Appointment of Trustee. That Security Pacific National Bank, Los Angeles, California, is hereby appointed as Trustee under the Trust Agreement for the City, the Corporation and the owners of the Certificates, with the duties and powers of such trustee as are set forth in the Trust Agreement. Section 6. Second Assignment Agreement . That the proposed form of Second Assignment Agreement is hereby approved and the Mayor or Mayor Pro Tem or other appropriate officer and the City Clerk are hereby authorized and directed, for and in the name of the City, to execute such Second Assignment Agreement in substantially the form hereby approved with such changes therein as the officers executing the same may approve, such approval to be conclusively evi- denced by the execution and delivery thereof . Section 7. Contract of Insurance. That the pro- posed form of Contract of Insurance is hereby approved and the Mayor or Mayor Pro Tem or other appropriate officer and the City Clerk are hereby authorized and directed, for and in the name of the City, to execute such Contract of Insur- ance in substantially the form hereby approved with such changes therein as the officers executing the same may approve, such approval to be conclusively evidenced by the execution and delivery thereof. Section 8. Regulatory Agreement . That the pro- posed form of Regulatory Agreement is hereby approved and the Mayor or Mayor Pro Tem, or other appropriate officer and the City Clerk are hereby authorized and directed, for and -3- in the name of the City, to execute such Regulatory Agree- ment in substantially the form hereby approved with ,uch changes therein as the officers executing the same may approve, such approval to be conclusively evidenced by the execution and delivery thereof.; Section 9 . Certificate Purchase Contract . That the farm of Certificate Purchase Contract and Letter of Representation of the Corporation .attached thereto as Exhibit A presented at this meeting is hereby approved and the Mayor, payor Pro Tem, City _Manager or other appropriate officer and the City Clerk of the City are hereby authorized to accept, for and in the name of the City, such Certificate Purchase Contract and the Letter of Representation of the Corporation in substantially the forms hereby approved with such changes therein as the officers executing the same may approve, such approval to be conclusively evidenced by the execution- and delivery thereof, provided that the principal amount of Certificates to be sold pursuant to the Certifi- cate Purchase Contract shall not exceed $4, 500,000, the final maturity of the Certificates shall not extend beyond. November 15, 2005, the interest component with respect to the Certificates shall not result in a yield greater than eight percent (5 .00 ) per annum and the Underwriter ' s dis- count shall not exceed two percent ( 2 . 0%) of the principal amount of Certificates sold.: Section 10 , Official_ Statement. That the draft of the Preliminary official Statement relating to the Cer- tificates presented at this meeting is hereby approved with such changes therein as may be approved by the City manager of the City or his designee, and the Mayor, Mayor Pro Teri or any other Councilmember is hereby authorized and directed .for and in the name and on behalf of the City to execute the Preliminary Official Statement and Final Official Statement (collectively the "Official Statement" ) and the distribution of such official Statement in connection with the sale of the Certificates is authorized. Section ll. Form of Certificate. That the farm of the Certificates as set forth in the Trust Agreement as presented to this meeting is hereby approved, provided that the Mayor, Mayor Pro Tem, City Manager or other appropriate officer of the City may approve any changes thereto (includ- ing nclud-ing any changes necessary or desirable to reflect the fact that the Certificates may be issued as capital appreciation certificates) such approval to be evidenced by the execu- tion of xecu-tion, + f the Trust Agreement as aforesaid, and the Trustee is hereby authorized and directed, upon order of the City, to execute by manual signature such Certificates in the aggre- gate principal amount set forth hereinabove and all, in 4- accordance with the terms and provisions of the Trust Agree- ment. Section 12. Tax Agreement . That the proposed form of Tax Agreement is hereby approved and the mayor , Mayor Pro Tem, City Manager or other appropriate officer are hereby authorized and directed, for and in the name of the City, to execute such Tax Agreement in substantially the form hereby approved with such changes therein as the offi- cers executing the same may approve, such approval to be conclusively evidenced by the execution and delivery thereof . Section 13 . Reguisitions., The City Manager, or his designee, is hereby authorized and directed to execute one or more requisitions authorizing Security Pacific National Bank, as Trustee under the Trust Agreement, to pay the costs of issuing the Certificates from the proceeds of the Certificates or moneys contributed by the Corporation pursuant to the Trust Agreement. Section 14. Special Counsel . The law firm of Best, Best & Krieger is hereby appointed to act as Special Counsel in this financing on the terms set forth in the proposal letter of said firm presented to this meeting and the Mayor, Mayor Pro Tem or City Manager is authorized and directed to execute and cause said proposal letter to be delivered on behalf of the City. Section 15 . Other Acts. The officers of the City are hereby authorized and directed, jointly and severally, to do any and all things and to execute and deliver any and all documents which they may deem necessary or advisable in order to consummate the execution, sale and delivery of the Certificates or otherwise to effectuate the purpose of this Resolution, and such actions previously taken by such offi- cers are hereby ratified and confirmed. Section 16 . Effective Date. This Resolution shall take effect upon adoption. ADOPTED this rd day of July, 1990 . r. Mayor ,,of '�he""' It /df Redlands, ATTEST: C'rt"y Clerk of they,)aity of Redland Cali ofn -5- I , LORRIE POYZER, City Clerk of the City of Redlands, California, do hereby certify that the foregoing Resolution No. 4673 was regularly introduced and adopted by the City Council of the City of Redlands, California, at a regular meeting thereof held on the 3rd day of July, 1990, by the following vote of the City Council : AYES: Councilmembers Larson, Milson; Mayor DeMirjyn NOES, None ABSENT: Councilmember Beswick ABSTAINED: Councilmember Cunningham and that said resolution has not been amended, superseded or repealed, and is in full force and effect . IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the City of Redlands, Cali- fornia, this 3rd day of July 1990. MyClerk of !�he',,`C tv of Redlan,ds, Calii-d'i-Inia -6- 2JRRO637 I , Lorrie Poyzer , City Clerk of the City Of Redlands , California, do hereby certify that the foregoing Resolution No. 4673 was regularly introduced and adopted by the City Council Of the City of Redlands , California, at a regular meeting thereof held on the 3rd day of July , 1990 , by the following vote of the city Council: AYES : Councilmembers Larson, Milson ; Mayor DeMirjyn NOES: None ABSENT: Councilmember Beswick ABSTAINED: Councilmember Cunningham and that said resolution has not been amended, superceded or repealed , and is in full force and effect . IN WITNESS WHERE P, I have hereunto set my hand and affixed the official seal of the city of Redlands, California, this 23rd day of July , 1990 . City Clerk of the City of Redlands , California -6- THIS AGREEMENT is made and entered into this aXd_ day of Julv r 1990, by and between the CITY OF REDLANDS, hereinafter referred to as "CITY, " A N D SEIDLER-FITZGERALDS PUBLIC FINANCE, a, division of (SEIDLER AMDEC SECURITIES INC. ) , hereinafter referred to as "CONSULTANT. " W I T N E S S E T H: WHEREAS, CITY has been approached by the Redlands Community Hospital to obtain funds to fund a co-generation project and data processing equipment through the issuance of Certificates of Participation by the City; and WHEREAS, CITY has determined it is in its best interest to assist the Hospital finance the project; and WHEREAS, Hospital has retained a managing underwriter to underwrite the financing; and WHEREAS, CITY has the need of a financial consultant to advise the CITY on the structuring of the financing and pricing by the underwriter so as not to impact the City' s credit standing or expose the City to any financial risks; and WHEREAS, CONSULTANT is qualified to serve as financial consultant to assist CITY with the proposed issuance of certificates; and WHEREAS, it is in the best interest of CITY to hire CONSULTANT. NOW, THEREFORE, FOR AND IN CONSIDERATION OF THE MUTUAL PROMISES, COVENANTS AND CONDITIONS HEREIN CONTAINED, THE PARTIES HERETO AGREE AS FOLLOWS: A. SERVICES_ The services of CONSULTANT shall consist of the following: 1. Together with the CITY, managing underwriter, bond counsel, trustee, outside auditor, technical consultants and advisory groups, develop a financing plan consistent with the goals and objectives established by the CITY. 2 . Review managing underwriter's sizing of the issue. 3 . Review selection of the trustee bank for the financing. 4 . In cooperation with bond counsel and managing underwriter, review all documents necessary to implement the proposed financing plan including the supportive documents providing security to the individual financing form. 5. Assist managing underwriter to structure those terms and conditions such as maturities, coupon rates, call features and security features for the bond issue which most advantageously meet demands of current market conditions and meet the objectives of the CITY and ensure the lowest possible net interest cost. 6. Provide technical support in defining disclosure issues necessary to meet GFOA and SEC guidelines. 7 . Assist in the development of an official statement for the negotiated sale of necessary certificates of participation. 8 . Explore possibility and benefits of insuring the issue. 9. Assist managing underwriter with marketing the CITY's issue, including obtaining the best rating possible from the rating agencies and arranging rating agency trips, if necessary. 10. Advise CITY on whether co-managing underwriters are needed and assist with their selection. 11. Assist with the printing of the preliminary and final official statements. 12. Advise the CITY on the timing of the sale in relation to the market conditions and financing needs. -2- I3 . Participate in information meetings, if needed, to create investor interest in the bond issue. 14 . Review and advise CITY on coupon rates and spread proposed by the managing underwriter. 15. During the financing, Mr. John C. Fitzgerald shall be available to advise CITY. B. FEES CONSULTANT would be compensated contingent upon the CITY's issue being sold and delivered. The total fee for providing these financial advisor services is $5,000. IN WITNESS WHEREOF, the parties hereof have executed this Agreement on the day and year first herein above written. CITY OF REDLANDS a political subdivision of the State of California I,By7 SEIDLER-FITZGERALD PUBLIC FINANCE a division of (SEIDLER AMLEC' SECURITIES INC. ) 7 By John"" . FJ ge _Ma� aging Dire r "CONSULTANT" -3- BEST, BEST & KRIEGER LAWYERS AU JRT�4UR L, TTLEAVORTH' CLARK 14,ALSC� TPF JEANNETE A. TrRSON PATP�CK W,PEARCE 400 MISSION SQUARE G LEN E.STEPHENS* DAV,DJ CRWIN rEIP L,VOLLNO*L-r NIOPRA E.UMrMOM 3750 UNIVERSITY AVENUE WILIJAM P.DEWOLFr NRCKAtl,J,ANDELSON' SWAN M LFWIS CLLEN C.SPLELMAN POST OFFICE BOX toza SARTON C.,GAUT' OOUGLAS S.PHILLIPS* BRADLEY E_NEUFE LO GLENN WALLACE PAUL.'r,SELZER, ANTOWA GRAPH05 GEOFFREY K Wit-US KAA W.SMITH RIVERSIDE,CALIFORNIA 92502 GALLAS HO'-MCS' GREGORY K.WtLKINSON KANO'LtC.ALLEN ',VLYSTA, POWEL.L TELEPHONE(744)6a6-t450 r _HPISTOPMER L_CARPENTER' WYNNE S.FURTH EL4$KK,LrRAYNUM JASON D.DAISARFtNER WCt*,ARE'T.ANDERSON* DAVID L.BARCIN WILLIAM D HAYDN WWSTD14 TELFOOPMRS JOHN 0,WA ALIN' VIRGINIA A,ETTINGFA TERESAJ PW TO,.KOV4C DAVID A,PRENTICE MuCHAEL 0 A ,HARRIS* EUGENE7ANKA WCTORIA N.NING KYLE A,SNOW (714)6$6-3083-ISSA-AS12 W,CURT EALY' BASIL T CHAPMAN £S TTI SNlAUTON MA14K A.CASTEN THOMAS S,SLOVAK TBmo-rHy M.LoNNok MATT W.MORRIS DIANE L_FWLCV OFOOUNSEL JOHN E.DROWN A VICTOR L.WOLF jrFPRFY V..;'Q NN MFCHCLLCOUCLLETTF MICHAEL T.RIDDEL DAN wLL E.OtNTR STEVEN C,C)VWkuN TiT�MTHY W_SESLER -_IAMES IS COWSON MEREDITH A Juw, DANtEL a,MCHUGH SRANT H,OVEIRJN PAUL C.ANDERSON RICHARDA,OSHINS* MCKAFLI,RANT* MARES CMPL� ERIC L DARNER PETER M.S&ARMACK STEPHEN P,OEITSCH F,NAN�_,S J BAUM. JOHN A RorTSCHAFPER DENNIS M,CCTA ANNE,TOO"'AS. MARTIN A-MUF LS_ER HARCNQ W,HOPP RUSSELL,),THOMAS,JR, D MARTIN NETHFRY ,MICHAEL SUMMEROUR JUL IF HAYWARD 01C�GS 'AORITTCONNOWYOA,NEVADA, GFOAGE M,REYES HOWARD e,GOLDS RACHELLC 0,NiOOLJE WASWNGfON,0 C COURT OF CLAWS WILLIAM W.FILOYO.JR MARGARET r.7ANAKA W HARG PEAVF S MXCHAt;_A,C METE' JErFERY S.CRANDALL JANICE L WEIS RAYMOND SPST P368 9571 (,REGORY`L HAROXE SCOT`r C,SMU'M CIWSTIAN E,PEARN JAMES 114 KRIEGER t,9?3_"3757OFFICES fN KENDALL H,MACVEY JACK S.CLARKE SHAqYLWALKCR EUIGENr SEST(1893.898I) PALM SPAINE S(699)3Z5,7L64 RANCHO MRAGE(MS)568-26fl ONTARIO i714I 989-$584 June 27, 1990 Mayor and City Council of the City of Redlands City Hall 30 Cajon Street Redlands, California 92373 Re: Proposal Regarding Legal Services in Connection with the Issuance of Certificates of Participation (Redlands Community Hospital Project) Ladies and Gentlemen: This letter will serve as a proposal on the part of Best, Best & Krieger to serve as special counsel in con- nection with the authorization, issuance and sale of Insured Certificates of Participation (Redlands Community Hospital Project) 1990 Series A ( the "Certificates") pursuant to an installment sale financing arrangement between the City and Redlands Community Hospital (the "Corporation" ) to refinance the acquisition, construction and installation of a general acute care health facility operated by the Corporation. We propose to perform the following services on the basis here- inafter set forth. We will consult with and advise City officials and the City' s financial consultant as to the best legal methods of accomplishing the objectives of the City inn, connection with> the financing and the proceedings for the execution, sale and delivery of the Certificates. }4 BEST, BEST & KRIEGER LAWYIERS- ARTHUR L LMTLCW9oTH" CLARK H ALSCIP JEANNETTE.A PETERSON PA.TRrCA W.PEARCE 400 MISSION SODARE GL£N f STEPHENS DAVID)epwN.* TrW L VOLL.NOGLE. MOS RA E.UME'MOAi 3750 UNIVERSITY AVENUE k: WILLIAM R DtWOt_FE:' MICHAE6.J.ANDEL.SON* EPR;IAN M,LEWTS ELLEN C.SPIC04ACN POST OFFICE SOX.$028 BARTONC G*Ul DOUGLAS PHILLIPS` SRAELCYE NEUP'ELD GL,ENH WALLACE: M'�IVERSIC3E,CAL)FC3i�N4AD�"9C7 F. T.SELZ£#R AIaTC}NFAGRAPMOS GEQrrAE:xK WILUS KIRK W.SMITH DALLAS HOLMES' GREGORY N,WILK04SON KANDY LEE ALLEN KLY STA J,ROWELL TELEPHONE(?#p)686.1+450 CHRISTOPHER CARPENTER' WYNNE S FURTH ELwSE is TRAY NUM: -_+ASDN D.OAFIARf I#BER RICHOkpo T mor PSON' DAVID L.6APON 'WaLLIAW D DAHLING,JR HAYON WIN.STON T'ELECO PIER JOHN 0 WANLW N* VIRGINIA A ETTINGER TER'tSA:9 PRiSTL#JK VIt OAVFC1 A PRENTICE (`M)686.3083*66ZN461 MaCHAELO HARMS*... EUGENE T'ANAKA.. Vd CTCPMA N@ KaNG. KYLE A,SHOW W.CURT£ALY* 6ASQ.,T.CHAPMAN 8ET'TY S:N AUYO N MAPK A EASTER THOMAS S„SLOVAK* TIMOTHY M,CONNOR MATT H MORRIS DIANE L rINLE1 OF COUNSEL JCHN E SROWN* ViCTCSR b WULR' IEFrpirY V DUNN Mtt t( ,Lt OVELLFT'TP..: dAb€Ea.8.COWSON wCMAELT RiODELL* DAN6CL E.t7WVIERz STEV.NC D4SAUN TiAaVT' yV,r,SESLE.R MEREDfTH A JURY.*. DANEL J.MC14UG" BRANT H,OVEIPU4 GALL C.ANDERSON RICHARD CISHAN5•. PAICNAE&.i`s RANT*. MARC E_E,MPET. ERICL GARNERPETER Mr BARMACK STEPHENF DErrSCH g f-HANCtSS SAUW JDIiNR ROTrSCHACFCR DENNISM C01A RUSSELL)T140MA'S.dA ANNE T-THOMAS* MARTIN A,MUELLE IS HAROLD W.HOOP D MARTIN N£TI^RERY* J MICHAEL ICHAE.S.SUMM£R€UR .JUL€E HAYWARD SiGGS 'A6PcaT7ZDRN wCW°+rpR§t.IC'I/AWi.. GEORGE M.REYE5 HOWARD P,i`,OLDS RACnELL.C.J^NICOLLE WASHINGTON.0 C VOWIT Or CLA—t W3 LLSAM W I'LCIY CG JR. MARGARET F TARNAKA POSE RT i^t HAPG REAVIES MaCHACL A CIPSTE' JIC<FCPY J CAANDALL, JAN CE L..WETS RAYMOND BEST{a86 a,r9icT) 1 G8'COO YY E„H+AROAE. SCOTT C.SM:TH CHRISTIAN E.HEARN JAMES#N,KREG3ER(ISI OFFICES IN i KENDALL H MiA:CVCY JACK IS,CLARKS SWAR'.'L WWAA.KER EUGENE BEST(1803,tS8OQ PALM SPRINGS JeIlg)3E5,7M4 RANCH{, MIRAGE(619):5.68,ai5H R7NT#BRCS(Tuck 089ti058+4 Pune 27, 1990 Mayor and City Council of the City of Redlands City dial. Q Cajon Street Redlands, California 92373 ReProposal Regarding Legal Services in Connection with the Issuance of Certificates of Participation (Redlands Community Hospital Project) Ladies and Gentlemen: ; This letter will serve as s proposal on the part of Lest, Best & Krieger to serve as special counsel in con- nection with the authorization, issuance and sale of Insured Certificates of Participation (Redlands Community Hospital Project ) 1990 Series A (the "Certificates" ) pursuant to an installment sale financing arrangement between the City and Redlands Community Hospital (the "Corporation") to refinance the: acquisition, construction and installation of a general acute care health facility operated by the Corporation, We propose to perform the following services on the basis here- inafter set forth. We will consult with and advise City officials and the City's financial consultant as to the hest legal methods of accomplishing the: objectives of the City in connection with the financing and the proceedings for the execution, sale and delivery of the Certificates. q.Xr t,A W S'}&`..F I C E S CSR S` BEST, BEST & KRIEGER Mayor and City Council: of the City of Redlands June 27, 1990 Page We will prepare and draft all agreements, resolu- tions, notices, certificate forms and all other legal docu- ments required by California law for the execution, sale and delivery of the Certificates. We will provide such assis- tance nsa -tance to the City and Goldman, Sachs & Co. the underwriter for the issue,, as may be required in preparing and reviewing any official statement to be used in connection with the offer and sale of the Certificates. We will also examine all proceedings for the issu- ance and sale of the Certificates, step by step as taken, and when the Certificates are sola, will issue our opinion or opinions upon the validity of the Certificates and on the exemption of the intereston the Certificates from State of California taxation and the exclusion of interest on the Certificates from gross income for purposes of federal income taxation to the original purchaser of the Certifi- cates. We will also attend all hearings and all meetings in connection with the proceedings where attendance is requested,. For the services to be rendered pursuant to this proposal, including the preparation and supervision of pro- ceedings, ro-ceed ngs, examination of each step as taken, and the issu- ance of Baur unqualified legal opinion or opinions attesting to the validity of the proceedings and the issuance of the Certificates, the City will pay to us a fee, exclusive of out--of-packet costs and expenses, which is equal to $25,000. Our fee as special counsel will be payable upon execution and delivery of the Certificates from the proceeds of the financing. In the event we are requested to perform additional work outside of our services as special counsel, e will be paid additional compensation therefor at the hourly rates of the attorneys performing such services, provided, however, there shall be no such additional compen- sation omp n-sation daze us without the prior approval of the City of the performance of such services. In addition to the foregoing, we shall be reim- bursed by the City .for any out-of-pocket expenses incurred by us in the course of our employment, such as printing costs, long distance telephone calls, reproduction of docu- ments, travel at the; request of the City, and similar items.. LAW OFrICES OF BEST, BEST & KRIEGER Mayor and City Council of the City of Redlands June 27, 1990 Page 3 Should the contemplated proceedings be abandoned or discontinued at any time and the Certificates not issued, we shall be paid a reasonable fee, based on the time expended and the hourly rates of the attorneys performing services, for all services rendered to that time and to be paid or reimbursed to the City by the Corporation. If this arrangement is satisfactory to you, please authorize our employment according to the terms of this letter and return to us a copy of this letter executed by an authorized officer of the City. Respectfully submitted, ehn.R. Rottsch�aefe r est, Best & Krieger TERMS OF EMPLOYMENT APPROVED THIS 3rd DAY'OIF JULY, 1990. 7 A uth,b "Ilr of the' Cit" , ori I:C f"':/ke' land 2JRRO639 11",. 7 O'MELVENY & MYER O, -Y00 Sc193TH H"r"xs S—EET 'a'1CCl kf e r1TEf: {j EMa:.nRc,n,lERO CENTER WEST L-OS AF GELE _ALW'RWA 9t7L77r-g$4S! M3 'CAST 53— ST-EE- R ?_7S BATTERY STREET Y04K NEW 'Opy, 10022al Fi{s' }# "E_EX S,.144L.I FAESMILE 4ZT31 �5150-5407 TELEPI4ON£;2[2!376X' ' 00 i SAN FRANCISCO, CALIFORNIA 9#111.3.3015 TELEX +29{65 eArstM{ a2a21 32€•2013t � 1eoo £`i UAf r>ARx EAST CIS A*.GEk ES, ,.Li. ORN 900E7-,S89 TELEPHONE 14,51 984-6700 20 �'l to>HGCYV 5{J�f.CRE {�# 'S.r.Ei sf tJ1+E 2 i '�63^67�i0 LONDON ECZA ILA 12�f TELEX ty?+i'�4t F3:L:r MtrE f?€1t Bk"9 Gfi:79 FACS&M}LE 1478} 98-970, TE',Lk.PhiGNF C.t7i-2°iFx F.�4gt TELEX 9,BOw9- FACS Mn,L° 071-63e 1FWPOPr CEN TER 0-11E "`�"y� AAASAKA TSM'N TGw FP,EA5` Ie1 FLOOR TF__FRNO.E Y.,s+§3 71;0-&{o -lZt.;r Fie%_6900 July 0-17-2;� AAASA%.A. MsNATO-v. 2� TELEX 472�*,•3F9 -FRC.S.M�LF S7A}CPW4-69'94 ,}•.ry t}� YQ Yr^s {,L}7 J'S P.A^# ...... .1 +S FSK E3Tw 4`,'FEET,NW- 'S � � X'1. TP' FA J2173S GMMTGKYO FAC.S,MvLE.'',031 S87-07aB S wAS14 NGTO , 0 c 2000 .09 '� V l4 TEr;.:EPNt7fsE, fl2 t 38a-530n AVEI—E LOU 5E "G+3 t 8ELGY(,{M TEc F?£69622 • FAC5,M-E t202P 383-5414 =C15U C34?`JS SELS. }&, y y `FLEPHt'r71E 32 Q1 "7 Oe 50 k: A R.L.EX:OMSSaA 20317 FACSfMILE 32 i2S "6 47 29 YM Bi¢TEq'S C{R'E .T i38 a't. NUMBER (4 15) 984-582 5 OUR F'l-E N;IMSER 1 317,785-005 F A }} 5 iT1A FEEEDERAL EX-PRESS John E. Holmes i City Manager �` � �_`_r N11�= F The City of Redlands ! ' 30 Cajon Street ., p w Post Office Box 30015 Redlands, California 92373 - JUL 17 1990OF F1 CE OF Res City of Redlands, Insured caycLERI certificates of Participation (Redlands Community Hospital r ...� Project) 19903 Series A Dear John: The next step in the above-referenced financing is the execution of the Certificate Purchase Contract (the "Contract") by Redlands Community Hospital;, the City of Redlands and Goldman, ,Sachs & Co. on Thursday, July 12 , 1990. Towards that end, 1 have enclosed herein the fallowing documents 1. one (1) copy of the Contract, 2. ten (1.0) copies of the execution page of the Contract; and 3. ten (10) copies of the execution page of the Letter p of Representation, which appears in the Contract as Exhibit Ar Please have an authorized individual of the City of Redlands execute each copy of the enclosed execution page of theContractand each copy of the "enclosed execution page of the Letter of Representation. Upon such execution, please forward these executed copies to my attention, and 1 will iSEF.�i�i'r£`kSshTa}zni }}rt�i � �tt,{�4�i�itfztff �11'�7 o- Y Page y - John E. Holmes - July ll 1990 ate the same with the executed copies l receive from coltShortly Hospital and Goldman Sachs CO.Go. artier a Redlands community Hasp' thereafter, will forward to each ofthe relevant p complete copy of the Contract with original signatures ri included therein. �z questions regarding this Should you have any lease do not procedure car the document Jan Brockmanto be eon the undersigned. hesitate to contact either Thank? you V ry truly y urs, is or L, Castillo for 0,melveny & 14yers Enclosures cc: Jan Brockman, Esq. 962ZO09L 5£ I? iiyzt E 37tt,t 3,y x� �JS ,'JS���Pt% � f�F}"���¢?�..�,��t}t ..� Ss�{�r`r���i���ie��Y�91111w�4��`r1�)'�YY���,ItX�P��s�ti€���3�ti�r�, $3,997, 148 . 14 Insured Certificates of Participation (Redlands Community Hospital Project) # 1990 Series A i� CERTIFICATE PURCHASE CONTRACT ;duly 12 , 1990 k{ The City of Redlands City Hall 0 Cajon Street Redlands, California 92373 Ladies and Gentlemen: The undersigned (the "Underwriter") , offers to enter into this Purchase Contract (the "Purchase Contract"`) with you, the City of Redlands (the "City") , for the purchase by the Underwriter and execution and delivery of the above-captioned Certificates of Participation by Security Pacific National Bank, as trustee (the "Trustee") under that certain Trust Agreement, dated as of July 1, 1990 (the "Trust Agreement")" among the City, the Trustee and Redlands Community Hospital (the "Corporation") This offer is made subject to acceptance by you and approval by the Corporation and delivery to the Underwriter of the executed Corporation L tter.of Representation substantially in the form of Exhibit A hereto (;the 'Tetter of Representation") , all prior to 11:59 o'clock 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, with copies to the Corporation, 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 City ,and the Underwriter. The Underwriter has been duly authorized to execute this Purchase Contract and to take any action hereunder. 1 Pu ch se Sale d Deliyery, of the _Certificates. (a) Subject to the terms and conditions and in reliance upon the representations, warranties and agreements set forth herein and in the. Letter of Representation, the 6129/90 � zrxas 1 t ,,fir ydr ls>it�hss Underwriter hereby agrees to purchase and the City agrees to instruct the Trustee to execute and delivery to the Underwriter all (hut not less than all) of the $3,997, 148.14 aggregate principal amount Insured: Certificates of 4 Participation (Redlands Community Hospital Project) 1990 � 7 Series A (the "Certificates") , each evidencing proportionate, interests of the owners thereof in Installment Payments to be made by the City pursuant to, and as defined in, the Installment Sale Agreement, dated as of July 1, 1995 , between the City and the Corporation (the "Installment Sale Agreement") as the payment for certain equipment and; facilities of the Corporation located within the boundaries of the City (the "Project") . Pursuant to the Installment Purchase Agreement, dated as sof July 1, 1990, between the Corporation and the City (the "Installment Purchase Agreement") ,; the City will sell the Project to the Corporation and the Corporation will make Purchase Payments therefor. The Corporation, pursuant to the Assignment Agreement dated as of July 1 1990 (the "Assignment Agreement") , will assign its interest in the Installment Sale Agreement to the Trustee for the `benefit of the owners of the Certificates. The City, pursuant to the Second Assignment Agreement dated as of July 1., 1990 (the "Second; Assignment Agreement") , will assign to the Trustee for the benefit of the owners of the Certificates, substantially all of the Cray"s rights under the Installment Purchase Agreement* The aggregate purchase price for the Certificates shall be $3,917, 205.18 plus accrued interest to the Closing Slate (as hereinafter defined) . The Certificates shall be substantially in the farm 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 Certificates will represent the payment of the initial principal amount thereof (the "Initial Amount") plus interest accreted thereon at the yields to maturity set forth in the schedule attached as Exhibit B hereto, compounded semiannually can each May 15 ,aand, November 15, commencing November 15, 1990. The Certificates shall be payable: solely from Revenues (as that term is defined in the Installment Purchase Agreement) , which consist primarily of Purchase Payments to he made by the Corporation to the City pursuant to the Installment Purchase Agreement. A Preliminary Official Statement dated. July 6, 1990, (the "Preliminary Offi,ci.al, Statement" which, with such changes as are accepted by the Underwriter, and including the cover page and all appendices thereto, is herein called the Official Statement.) has been delivered to us in connection with the Certificates. Y' , x3`?S a.aYa,-'' 5r�tab 2r n,: t�4 (b) ;At 10:00 o'clock ,A.M. , California time, on July 26, �r 1990, or at such ether time or on such other date as we j mutually agree upon (the "Closing Date") .. .the Trustee will deliver or cause to be delivered to the Underwriter, ata ` location or locations to be designated by the Underwriter in New York, New York, the Certificates in definitive form (all of the Certificates to be lithographed with steel engraved borders and to bear CSIF numbers) , duly executed, together: with the other documents mentioned herein. The Underwriter will accept such delivery and pay the purchase price of the certificates as set Barth in subparagraph ,a) above by clearing house funds (such delivery and payment being herein referred to as the "Closing") to the order of the Trustee in an amount equal to the purchase price. The Certificates will be made available to the Underwriter for inspection and packaging, at an office which we may mutually agree upon, not less than one business day prior to the Closing. The Certificates shall be delivered as fully registered Certificates in such denominations and; registered in such names as the Underwriter shall request by written notice. {c} The Underwriter's obligations under this purchase Contract shall be subject, in addition to the conditions described in Section 3 below, to the receipt, on or prior to the date hereof, of a letter of Ernst & Young, dated the date 'hereof, with work extending to a date not more than five days prior to the date hereof, addressed to the Corporation and the Underwriter, in substantially the farm set forth in gxhibit C hereto. (d) The Underwriter agrees to make a public offering of the Certificates at the initial offering price '.set forth in the Official Statement, which price may be changed from -time to time by the Underwriter, 2;= Regyresentations. Warranties nd AgreMntg; thg City. The City` hereby represents, warrants and agrees with the Underwriter that: (a) as of the date of the official Statement, the statements and information contained in the Official Statement relating to the City, its functions, duties and responsibilities will be true, correct and complete in all material respects, and; the Official Statement will not omit any statements or information necessary to makethe statements and information therein, in the light of the circumstances under which they were made, not misleading in any material respect; it being further understood that the foregoing representation shall not apply to statements or 1'f^xr ,�`,��ts; 't�a'?,� +,`hX771; OR ,`,, }4s;''!�Is ��7�, INj{ f pit information in or omissions from the Official Statement 1$ �4 relating to the Certificates with respect to which the ft Corporation agrees to indemnify the Underwriter pursuantto t the Letter of Representations < (b) the City is and will be at the date of Closing a z municipal corporation p P general :law City duly organised and existing; under the Constitution and laws of the Stats of California with the full power and authority to enter into the Legal Documents (as defined in Section 3 (b) below) to l� which the City is a party (c) by official action of the City prior to or concurrently with the acceptance hereof, the City has duly approved the distribution of the Preliminary official Statement and the distribution of the Official statement, and has duly authorized and approved the execution and delivery of, and the performance by the City of the obligations on its part contained in, the Legal Documents to which the. City is a party and the consummation by it of all other transactions contemplated by the Official Statement and this Purchase Contract; (d) the execution and delivery of this Purchase Contract and the Legal Documents to which the City is a party and approval of the Official Statement and acceptance of the Utter of Representation and compliance with the provisions on the City's part contained herein and 'therein, will not conflict with or constitute ai breach of or default under any law, administrative regulation, judgment decree, loan agreement, indenture, band, note, resolution, agreement or other instrument to which the City is a party or is otherwise subject, nor will any such execution, delivery, adaption 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 City under the terms of any such law, administrative regulation, judgment, decree, loan agreement, indenture, bond, nate, resolution, agreement or other instrument, except as provided in the Legal Documents; (e) the City is not in breach of or default under any applicable law or administrative regulation of the State of California or the United States or any applicable judgment or decree or any loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the City is a party or is otherwise subject which affects the agreements mentioned above, 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; azaoa 4 s�zs Mr (f) 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, or to the best knowledge of the City, pending or threatened against the ,t City affecting the existence of the City or the titles of its officers to their respective offices or seeking to prohibit, restrain or enjoin the sale, execution or delivery of the Certificates or the collection of revenues pledged or to be pledged to pay the principal of, and premium, if any, and interest on the Certificates, or the pledge thereof, or in any way contesting or affecting the {validity or enforceability of the Certificates or the Legal Documents or contesting the powers of the City or its authority to enter into, adopt or perform its obligations under any of the foregoing,; or contesting in any way the completeness or accuracy of the Preliminary official Statement or the Official Statement, or any amendment or supplement thereto, wherein an unfavorable decision, ruling or finding would materially and adversely affect the validity or enforceability of the Certificates, the Legal Documents o this Purchase Contract; (g) the City will furnish such information, execute such instruments and take such other action in cooperation with the Underwriter as it may reasonably request., in order (a) to qualify the Certificates 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 b) to determine the eligibility of the Certificates for investment under the laws of such states and ether jurisdictions, and will use its best efforts to continue such qualification in effect so long as required for distribution of the Certificates; provided, however, that in no event shall the City be required to tape any action which would subject it to general or unlimited service of process in any jurisdiction in which it is notnowso subject, (h) if between the date hereof and the date of the Closing an event occurs, of which the City has knowledge, which might or would cause the information relating to the City, its functions, duties and responsibilities 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, the City will notify the Trustee, the Corporation and the Underwriter, and if in the opinion of the City, the Trustee, the Corporation or the Underwriter, 9Gl Z009J 6/24190 v V x or their respective counsel, such event requires the preparation and publication of a supplement or amendment to the official Statement, the City will cooperate in the preparation of an amendment or supplement to the official �a Statement in a farm and manner approved by the Underwriter, provided all expenses thereby incurred will be paid by the corporation; (i) the Preliminary official Statement heretofore delivered to the Underwriter is deemed final by the City as of the date thereof, except for the omission of such information as is permitted to be omitted in accordance with paragraph (b) (1) of Rule '15c2-12 of the. Securities Exchange Commission. Within seven (7) business days from the date hereof and within sufficient time to accompany any confirmation requesting payment from any customers of the Underwriter, the City shall cause a final printed farm of the Official Statement to be delivered to the Underwriter in sufficient quantity to comply with paragraph (b) (- ) of Rule 15c2-12 and; the rules of the Municipal Securities Rulemaking Board. If, after the date of this Contract of Purchase and until 25 days after the end of the "underwriting period" (as defined in Rule 15c2-12) the City acquiresknowledge of any event that might cause the Official Statement to contain any untrue statement of a material fact or to omit to state a material: fact necessary to make the statements therein, in the light of the circumstances under which they were wade, not misleading, the City shall notify the Underwriter (and' for the purposes of this clause shall provide the Underwriter with such information as they may from time to time request)` , and, if in the opinion sof the Underwriter such event requires the preparation and publication of a supplement or amendment to the official Statement, at the expense of the Corporation to supplement or amend the Official Statement in a form and manner approved by the Underwriter and furnish to the Underwriter a reasonable number of copies of such supplement or amendmentl and. ( ) if the information relating to the City, its functions, duties and responsibilities contained in the Official Statement is amended or supplemented pursuant to paragraph (h) hereof, at the time of each supplement or amendment thereto and (unless subsequently again supplemented or amended pursuant to such subparagraph) at all times subsequent thereto up to and including the date of the Closing, the portions of the official Statement so supplemented or amended (including any financial, and statistical data contained therein) will not contain any z 6 tt�fy4 y rad untrue statement of a material fact or omit to state a material fact- required to be stated therein or necessary to �u make such information therein, in the light of the 4J circumstances under which it was presented,, not misleading. 1. conditions to the Ob i ations of the Ude to The Underwriter hereby enters into this Purchase 1 Contract in reliance upon the representations and warrantiesof the City contained herein and the representations and warranties t of the Corporation contained in the Letter of Representation and in reliance upon the representations and warranties to be contained in the documents and instruments to be delivered at the 7 Closing and upon the performance by the City and the Corporation of their respective obligations hereunder, and under the Letter of Representation, both on andasof the date hereof and as of the closing pate. Accordingly, the Underwriter's obligations f under this Purchase Contract to purchase, to accept delivery of <' and to pay for the Certificates shall be subject, at the option of the Underwriter, to the accuracy in all material respects of the representations and warranties of the City contained herein and of the representations and 'warranties of the Corporation contained in the Letter of Representation, all as of the date hereof and as of the Closing Tate, to the accuracy in all material respectsofthe statements of the officers and other officials of the City and the Corporation made in any certificate or other document furnished pursuant to the provisions hereof, to the performance by the City and the Corporation of their respective obligations to be performed hereunder and under the applicable document named herein, at or prier to the Closing Late, and also shall be subject to the following additional conditions (a) The representations and warranties of the City contained herein and the representations and warranties of the Corporation contained in the Letter of Representation shall: be 'true, complete and correct in all material respects on the date hereof and on the Closing Late, as if made on and at the Closing; (b) At the Closing, the Trust Agreement, the Installment Sale Agreement, the Installment Purchase Agreement, the Assignment Agreement, the Second Assignment Agreement, the Regulatory Agreement, dated as of July 1, 1990, among the City, the Corporation and the Office of Statewide Health Planning and Development of the State of California (the "Office") (the "Regulatory Agreement") , the Deed of Trust, dated as of February 1, 1987, between the Corporation, as trustor, and Security :Pacific National flank, as trustee, for the benefit of the City and the Office (the "Deed of Trust") , the Contract of Insurance, dated as of July 1, 1990, among the City, the Corporation and the Office (the ItContract of Insurance" ) and the Depository Agreement, IF dated as of February 1, 1987, among the Corporation,, the Trustee and Bank of America National Trust and Savings Association (the "Depository Agreement") (collectively, the "LegalDocuments") shall have been duly authorized, executed and delivered by the respective parties thereto, and the official Statement shall have been duly approved, ' authorized, executed and delivered by the City and the ti Corporation, as the case may be, all in substantially the �. forms heretofore submitted to the Underwriter, with only such changes as shall have been agreed to in writings by the t Underwriter, and shall be in full force and effect; and there shall be in full force and effect such resolution or resolutions of the City Council of the City as, in the opinion of Best, Best & Krieger ("Special Counsel") shall be necessary or appropriate in connection; with the transactions contemplated ;hereby (c) Between the date hereof and the Closing Bate., the market price or marketability, at the initial offering prices set forth in the official Statement, of the Certificates shall not have .been materially adversely affected, in the judgment of the underwriter (evidenced by a written notice to the Trustee and the City' terminating the obligation of the Underwriters to ;accept delivery of and make any payment for the Certificates) 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, 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) , press release or other form of communication 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, directly or indirectly, of imposing federal income taxation upon moneys as would be received by the City or the Trustee under the Trust Agreement or the Installment 'Purchase Agreement or upon such interest as would be received by the owners of the Certificates; (2) the declaration of war or engagement in major military hostilities by the United States or the occurrence of any other national emergency or calamity relating to the effective operation of the government of or the financial community in the. United States 9GtZ X19 8 6/20190 { (3) the declaration of a general banking moratorium by federal.., New York or California IR authorities, or the general suspension of trading can any national securities exchange, { (4) the imposition by the New York Stock Exchange i or other national securities exchange, or any governmental authority, of any material restrictions not now in force with respect to the Certificates or obligations of the general character of the �r Certificates or securities generally, or the material increase of any such restrictions now in force, including these relating to the extension of credit by, or the charge tothenet capital requirements of, underwriters; (5) legislation enacted or resolution passed) b or introduced or pending legislation amended in the Congress or recommended for passage by the President o t, 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) , press release or other form of communication issued or made by or on behalf of the Securities and: Exchange Commission, or any other goernmental agency having jurisdiction of the subject matter, to the effect that obligations of the general character of the Certificates or of the Certificates, including, any or all underlying arrangements, are not exempt from registration under or other requirements from which they are now exempt under the Securities Act of 1933, as amended, or that the Trust Agreement is not exempt from qualification under or other requirements of the Trust Indenture Act of 1939, as amended, or that the issuance, offering or sale of obligations of the general character of the Certificates, or the Certificates, 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 Certificates 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 aza a�xs t� 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 tYr, made, not misleading and 4� (d) 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) All of the Legal Documents, each duly executed and delivered by the respective parties; (2) The unqualified approving opinion, dated the Closing Date and addressed to the City, of special Counsel., in substantially the form attached hereto as Exhibit. 4, and an unqualified opinion of such counsel, dated the Closing Date and addressed to the Underwriter and to the Trustee, to the effect that such opinion may be relied upon by the 'Underwriter and the Trustee to the same extent as if such opinion were addressed to them; ( ) The unqualified supplemental opinion, dated. the Closing Date and addressed to the Underwriter, of Special Counsel, substantially to the effect that (i) the Official Statement has been duly approved, executed and delivered by the City and this Purchase Contract has been duly authorized, executed and delivered by the City; (ii) the Contract of Insurance and Regulatory Agreement have been duly authorized, executed and delivered by the Office and, assuming due authorization by the other parties thereto, constitute binding and enforceable agreements of the Office in accordance with their terms, subject to laws relating to bankruptcy, insolvency, reorganization or creditors' rights and the application of equitable principles of equitable remedies are sought, (iii) the statements contained in the Official Statement under the captions "Introductory Statement", "Security and Source of Payment", "The Certificates", and "Tax Exemption", and in Appendix B to the Official Statement, "Summary of Principal: Documents", ;insofar as such statements purport to summarize certain provisions of the Certificates and the Legal Documents, present an accurate summary of such provisions, (iv) based upon information made available to such counsel in the course of such counsel's participation in the transaction as Special Counsel and without having undertaken to determine independently or assuming any responsibility for the accuracy, completeness or fairness of the statements contained in the Official Statement, nothing came to IZ009a 10 ry':t yt 5 such counsel's attention that would lead them to believe that the Official Statement, as of the date thereof or the Closing Tate, contains any untrue statement of a material fact, or omits to state a material fact necessary .in order to make the statements made, in the light of the circumstances under which they were made, not misleading (except that such> counsel need express no view as to the financial statements or the statistical data contained in the Official Statement) , and (v) the Certificates are exempt from registration under the Securities Act of 1933, as amended, and the Trust Agreement is exempt from qualification under the Trust Indenture Act of 1939, as amended, together with an unqualified opinion of such counsel, dated the Closing Date and addressed to the Trustee, to the effect that such opinion may be j relied upon by the Trustee to the same extent as if such opinion were addressed to the Trustee; (4) The opinion- of Best, Best & Krieger, in their , capacity as City Attorney for the City, dated the Closing tate and addressed to the Underwriter to the effect that the City is a general lair' city duly organized and validly existing under the Constitution: and laws of the state of California; nothing has come to the attention of such counsel which; would lead them to believe that the official Statement (excluding therefrom financial statements and the 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 in order to make the- statements therein, in the light of the circumstances under which they were made, not misleading, the resolution or resolutions of the City approving and authorizing the execution and delivery by the City of the Trust Agreement, the Regulatory Agreement, the Installment Sale Agreement, the Installment Purchase Agreement, the Second Assignment Agreement and the Contract of Insurance (collectively, the "City Documents") , the Purchase Contract and the Official Statement (the "Resolutions") were duly adopted at meetings of the governing body of the City 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; 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 City, to restrain or enjoin the collection of Revenues or of 9SIZ005 6/29/00 3n Purchase Payments under the Installment Purchase Agreement, or to restrain or enjoin the payment by the City of the Instillment Payments or the pledge by the City of its interest in Revenues to the Trustee pursuant to the 'gust Agreement, or in any way s contesting or affecting the validity of the Resolutions, the City Documents or this Purchase Contract,* the approval, execution and delivery of the Official Statement, the adoption of the Resolutions, and compliance by the City with the provisions of the: foregoing, under the circumstances contemplated thereby, to the best of their knowledge after reasonable investigation, do not and will not in any material: respect conflict with or constitute on the part of the City a breach or default under any agreement or other instrument to which the City is a party or by which it is hound or any existing law, regulation, court order or consent decree to which the City* is subject, the City Documents, this Purchase Contract and the official ,Statement have been duly authorized, executed and delivered by the City and, assuming due authorization, execution and delivery by the other parties thereto, constitute legal, valid and binding agreements of the City 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* 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 City is required for the valid authorization, execution and delivery by the City of the City Documents, this Purchase Contract or the: Official Statement or for the adoption of the Resolutions; and the Assignment Agreement and the Second Assignment Agreement have been duly recorded, and,; the Trust Agreement, the Depository Agreement and all financing statements (including any financing statements required to be fired under the provisions o the California Uniform commercial Code) have been duly recorded and filed in such manner and, in such place a s required by law to establish, preserve and protect the security interests thereby created on all collateral specifically or generally described in such documents as subject to such security interest and under the laws in force, and it will not be necessary to rerecord any such documents except that it will be necessary to file continuation statements at the end of each five (S) year period as required by the California xa lxf s#�1 f Uniform commercial Code, together with an unqualified opinion of such counsel, dated the closing Date and addressed to the Trustee, to the effect that such opinion may be relied upon by the Trustee to the same t i extent as if such opinion were addressed to the }{ Trustee (5) The opinion, dated the closing date and i` addressed to the City and the Underwriter, of counsel to the Trustee, to the effect that (i) the Trustee is and will be as of the date thereof a national banking corporation duly organized and validly existing under the laws of the United States of America having full power and being qualified to enter, accent and administer the trust created under the Trust Agreement and to execute and deliver the certificates; ( ii ) Trust Agreement, the Assignment Agreement and the Second Assignment Agreement have been duly authorized, executed and delivered by the Trustee and, assuming due authorization, execution and delivery by the other parties thereto, constitute legal, valid and binding agreements of the Trustee enforceable in accordance with their' respective terms, subject to laws relating to bankruptcy, insolvency or other laws or equitable principles affecting the enforcement of creditors' rights, generally and the application of equitable principles if equitable remedies are sought,. (iii) to the best knowledge of ,such counsel after: reasonable le or investigation, there s no action, suit, pasona investigation at law or in equity before or by any court, public board or` body, pending or, to the best , knowledge of such counsel, threatened against or affecting the Trustee to restrain or enjoin or in any way contesting the existence or powers of the e trustee with respect o theexecution and delivery Certificates or the security therefor or the execution and delivery by the Trustee of the Trust Agreement, the Assignment Agreement or the Second Assignment Agreement wherein an unfavorable decision, ruling or finding would adversely affect the transactions contemplated by the Legal Documents or the validity of the ,Certificates;' and (iv) the execution and delivery b the Trustee of the Certificates and the Frust Agreement, the Assignment agreement and theseconustoe Assignment Agreement and the compliance by t with the provisions thereof, 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 of or default under any agreement or other instrument to which the Trustee is a party or by which it is bound +or any existing law, 13 4rIZOO9J l iJ k �y regulation, court order or consent decree to which the �< Trustee is subject; provided, however, that no opinion' need be expressed with respect to compliance with federal and state securities laws,- (6) aws(6) The opinion, dated the Closing Date and addressed to the underwriter, of O'Melveny & Myers, counsel for the Underwriter ("Underwriter's Counsel") , , to the effect that (a) the Certificates are exempt from registration under 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) based upon the information made available to them in the course of their participation in the preparation of the official Statement as counsel for the Underwriter and without having undertaken to determine independently, and acknowledging that the limitations inherent in their examination andinthe knowledge available to them renders them unable to assume, and therefore without assuming, any responsibility for the accuracy, completeness or fairness of the statements contained in the Official Statement, nothing has come to thein attention which would lead them to believe that the Official Statement (excluding therefrom financial statements and the statistical data included in the official Statement) 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 circumstances under which they were made, not misleading, (7) An opinion, dated the Closing Date and addressed to the Underwriter, of counsel to the Corporation, in substantially the form attached hereto as =Jbit .E with such assumptions and qualifications as are customary, (8) A certificate or certificates dated the Closing Date, signed by a: duly authorized official of e City satisfactory to the Underwriter, in form and substance satisfactory to the Underwriter, to the effect that, to the best of his knowledge, (a) the representations and warranties contained in this Purchase Contract are true and correct in all material respects on and as of the Closing mate with the same effect as if made on the closing Tate, (b) no litigation is pending or threatened (i) to restrain; or enjoin i.n the execution, sale or delivery of any of the Certificates or the collection of Revenues or the Purchase: Payments under the Installment Purchase 9 IZ009J 14 /xs so e t Agreement, or the pledge thereof by the City to the Trustee pursuant to the Trust Agreement, or the payment by the City of Installment Payments under the Installment Sale Agreement, (ii) in any way contesting or affecting the validity of the Certificates, this Purchase Contract or the Citic Documents, or (iii) in any gray contesting the existence or powers of the City; and (c) no event affecting the City 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 or is not reflected in the official Statement, but should be reflected: therein in carder to make the statements and information therein not misleading in any material respect, ( ) A certificate of an authorized officer of the Corporation, dated the Closing Date, to the effect that: (i) since September 30, 1959, no material and adverse change has occurred in the financial position or results of operation of the Corporation which is not described in the official Statement, (ii) the Corporation has not, since September 0, 1989, incurred any material liabilities other than in the ordinary course of business which are not described in or contemplated by the official Statement, (iii) no litigation is pending or, to the knowledge of; such officer after reasonable investigation, threatened (a) to restrain or enjoin the execution or delivery of the. Certificates or the payment by the Corporation of the Purchase Payments under the Installment Purchase Agreement or the assignment by the Corporation to the Trustee of its right to receive Installment Payments to be paid by the City pursuant to the Installment Sale Agreement, (b) in any way contesting or affecting the authority for the sale, execution and delivery of the Certificates or the validity of the Certificates, the Legal Documents, the Letter of Representation or the Purchase Contract, or (c) in any way contesting the corporate existence or powers of the Corporation (i ) no proceedings are pending or, to the knowledge of such officer after reasonable investigation, threatened in any way contesting or affecting the Corporation's status as an organization described in Section 501(e) (3) of the Internal Revenue 9G ZOO93 1 �j / t, L Yz Cade of 1986, as amended, or which would subject any income of the Corporation to federal income taxation; (v) no event affecting the Corporation 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 or is not reflected in the official Statement, but should be reflected therein in order to make the statements and information therein not misleading in any material respect and (vi) the representations and warranties made by the Corporation in the Legal Documents and in the Letter of Representation are true and correct as of the Closing Date (10) Copies of the Corporation's articles of incorporation and a good standing certificate of recent date, both certified by the secretary of State of the State of California® and certified copies of the Corporation's bylaws and resolutions of its Board of Directors authorizing, the execution and delivery of the Legal Documents to which the Corporation is a party and the Letter of Representation, and the official Statement (and distribution thereof) and ratifying the distribution of the Preliminary official Statement and approving this Purchase Contract; (1.1) Evidence that the Corporation is an organization described in Section 501(c) (3) of the Internal Revenue Code of 1.986, as amended; and <a copy of a letter from the California Franchise Tax Board' stating that the Corporation is exempt from California- franchise and; income taxation under section 3701(d Revenue and Taxation Code, together with an exempt letter of good standing of recent date from the California Franchise Tax Board, (12) A letter of Ernst & Young, certified public accountants, dated the Closing Date, to the effect that such accountants reaffirm, as of the Closing Date and as though made at the Closing Date, the statements made in the letter furnished to the Underwriter by such accountants pursuant to section 1(c) hereof., except that the specified procedures referredtoin such letter will be to a clave not more than five (5) days prior to the Closing Date, rt e (l ) A certificate of the Trustee, dated as of the Closing Date, to the effect that; (a) the Trustee is a national banking association organized and existing under the laws of the United States of America, having the full power and being qualified to enter into, accept and administer the trust created, under the Trust Agreement and to execute and deliver the Certificates, (b) the Trustee is duly authorized to enter into the Trust Agreement, the Assignment Agreement and the Second Assignment Agreement and. to execute and deliver the Certificates to the Underwriter pursuant to the 'gust Agreement, (c) when delivered to and ;paid for by the Underwriter at the Closing, the Certificates will have been duly executed and delivered by the Trustee; (d) the execution and delivery of the Certificates and the Frust Agreement, the Assignment Agreement and the Second Assignment Agreement and compliance with the provisions on the Trustee's pert contained: therein, will not conflict with or constitute a breach of or default under any law, administrative regulation, judgment, decree, lean agreement, indenture, bond, note, resolution, agreement or other instrument to which the Trustee is a party or is otherwise subject, 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, nate, resolution, agreement or other instrument, except as provided by the Trust g're+ement# (e) to the best knowledge of the Trustee, 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 Trustee affecting the +existence of the Trustee, or the titles of its officers to theirrespective offices or seeking to prohibit, restrain or enjoin the execution and delivery of the Certificates or the collection of revenues pledged or to be pledged to pay the principal of, premium, if any, and interest with respect to the Certificates, or the pledge thereof, or in any way contesting or affecting the, validity or enforceability of the Certificates or the Trust Agreement, the Assignment Agreement or the Second Assignment Agreement, or contesting the powers of the Trustee or its authority to enter into, adopt or perform its obligations under any of the Certificates or the Trust Agreement, the Assignment Agreement or the Second Assignment Agreement wherein an unfavorable 9 IZO09i 17 decision, ruling or finding would materially adversely affect the validity or enforceability of the Certificates or the Trust Agreement, the Assignment Agreement or the Second Assignment Agreement; and (f) within the scope of its trust obligations imposed by the Trust Agreement, the Assignment Agreement or the Second Assignment Agreement, the Trustee will furnish such information as it has in its possession, execute such applications and take such other action in cooperation with the Underwriter as the Underwriter may reasonably request in writing in order to enable (1) the qualification of the Certificates for offer and sale under the Blue Sky or other securities laws and regulations of such states and other jurisdictions of the United States of America as the Underwriter may designate, and (2) the determination of the eligibility of the Certificates for investment under the laws of such states and other jurisdictions, or to enable the continuation of such qualification in effect so long as required for distribution of the Certificates; provided, however, that in no event shall the Trustee be required to take any action which would (i) subject it to general or unlimited service of process in any jurisdiction in which it is not now so subject or (ii) subject it to income or franchise tax in any jurisdiction in which it is not now so subject. (14) Two signed copies of the Financial Statements included in Appendix A to the Official Statement; (1 5) A nonarbitrage certificate in form satisfactory to Special Counsel; (16) Two copies of the Official Statement, executed on behalf of the City by its duly authorized official and on behalf of the Corporation by its duly authorized officer,* (17) Two certified copies of the general resolution of the Trustee authorizing the execution and delivery of the Certificates, Trust Agreement, the Assignment Agreement and the Second Assignment Agreement; (18) Two certified copies of the resolutions of the City authorizing the execution and delivery of the Legal Documents, the Official Statement and the Purchase Contract and ratifying the distribution of the Preliminary Official Statement; 9G1Z009J 18 6/29190 (19) Evidence that the rating of "AAA" by Standard Poor's Corporation is in full force and effect with respect to the Certificates; (20) Two copies of the Blue Sky Memorandum and Memorandum as to Legality for Investment with respect to the Certificates, prepared by Underwriter's Counsel ; and (22) Such additional legal opinions, certificates, proceedings, instruments, title insurance, other insurance policies or evidences thereof and other documents as the Underwriter, underwriter's Counsel or Special Counsel may reasonably request to evidence the truth and accuracy, as of the date hereof and as of the Closing Date, of the representations of the City and the Corporation herein and in the Letter of Representation and of the statements and information contained in the Official Statement, and the due performance or satisfaction by the Trustee, the City and the Corporation at or prior to the Closing of all agreements then to be performed and all conditions then to be satisfied by the Trustee, the City and the Corporation, respectively, in connection with the transactions contemplated hereby and by the Legal Documents. If any of the conditions to the Underwriter's obligations contained in this Purchase Contract shall not have been satisfied when and as required herein or if the Underwriter's obligations shall be terminated for any reason permitted herein, all obligations of the Underwriter hereunder may be terminated by the Underwriter at, or at any time prior to, the Closing Date by written notice to the City and the corporation. 4. pnse All expenses and costs of the Trustee and the City incident to the performance of its obligations in connection with the authorization, execution, delivery and sale of the Certificates to the Underwriter, including the costs of printing of the Certificates, printing and mailing of the Preliminary Official Statement and the Official Statement, CUSIP Service Bureau charges, the cost of duplicating the documents named therein, the fees and expenses of consultants retained by the Corporation and rating agencies, the California Health Facility Construction Loan Insurance Program application and inspection fees, the fees and expenses of the Trustee and its counsel in connection with the execution and delivery of the Certificates and the fees 9GIZO09i 19 and expenses of Special Counsel, the City Attorney and counsel for the Trustee, fees and expenses in connection with qualification of the Certificates for sale under the Blue Sky or other securities laws and regulations of various jurisdictions and printing and preparation of the Blue Sky Memorandum and the Memorandum as to Legality for Investment, shall be paid by the Corporation. All such fees and expenses paid by the Corporation may be paid from Certificate proceeds to the extent permitted under the Trust Agreement and the Internal Revenue Code of 1986, as amended. In the event that the Certificates for any reason, other than by reason of default by the Underwriter, are not executed and delivered, or to the extent proceeds of the Certificates are insufficient or unavailable therefor, any fees, costs and expenses owed by the City or the Trustee, which otherwise would have been paid from the proceeds of the certificates, shall be paid by the Corporation. All out-of-pocket- expenses of the Underwriter, including travel, California Debt Advisory Commission fee and other expenses, and the fees and expenses of Underwriter's Counsel shall be paid by the Underwriter. 5. Notices. Any notice or other communication to be given to the City under this Purchase Contract may be given by delivering the same in writing at the address set forth above. Any notice or other communication to be given to the following parties may be given by delivering the same in writing to the respective party at the following address: To the Underwriter: Goldman, Sachs & Co. 555 California Street Suite 3120 San Francisco, California 94104 Attention: Vincent F. Forte Vice President To the Corporation: Redlands Community Hospital 350 Terracina Boulevard P.O. Box 3391 Redlands, California 92373 Attention: James R. Holmes Senior Vice President and Chief Financial officer 6. Eart igg in InterestL* Counterpazts,* . gove=ing ,14 This Purchase Contract is made solely for the benefit of the City, the Corporation and the Underwriter (including successors or assigns of the Underwriter) and no other 9GIZOO94 2 0 6/29/90 person shall acquire or have any right 'hereunder or by virtue hereof.. This Purchase Contract may be executed in several counterparts, each of which shall be an original and all of which shall constitute one and the same agreement. This Purchase Contract shall be governed by the laws of the State of California. 7 . survival ;of Re resents ions and_warrantiegs. The representations and warranties of the City set forth in or made pursuant to this Purchase Contract and the representations and warranties of the Corporation set fort in the Letter of Representation or otherwise made pursuant C to this Purchase Contract, shall not be deemed to have been discharged, satisfied or otherwise rendered void by reason of this 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 Certificates. . Effective. This Purchase Contract shall become effective and binding upon the respective parties hereto upon the execution of the acceptance hereof by the duly authorized officials of the City and shall: be valid and, enforceable as of the time of such. acceptance. GOLDMAN, SACHS & CO. ACCEPTED: THE CITY OF DISH By: Its: Attest: City Clerk APPROVED: RED LH COMMUNITY HOSPITAL H . Its: 9GIZ009i 21 EXHIBIT A LETTER OF REPRESENTATION July 12, 1990 GOLDMAN, SACHS & CO. 555 California Street San Francisco, California 94104 THE CITY OF REDLANDS City Hall 30 Cajon Street Redlands, California 92373 Ladies and Gentlemen: The City of Redlands (the "City") and the undersigned Redlands Community Hospital (the "Corporation") propose to execute and enter into an Installment Sale Agreement dated as of July 1, 1990 (the "Installment Sale Agreement") pursuant to which the Corporation sells to the City certain equipment and facilities as more fully described therein (the "Project") and the City agrees to pay therefor Installment Payments, and an Installment Purchase Agreement dated as of July 1, 1990 (the "Installment Purchase Agreement") pursuant to which the City sells the Project to the Corporation and the Corporation agrees to pay therefor Purchase Payments in an amount equal to the Installment Payments payable by the City under the Installment Sale Agreement. The Corporation proposes to assign to security Pacific National Bank (the "Trustee") , its right to receive Installment Payments from the City pursuant to an Assignment Agreement, dated as of July 1, 1990 (the "Assignment Agreement") . The City proposes to assign to the Trustee its right to receive Purchase Payments from the Corporation pursuant to a Second Assignment Agreeiftent,, dated as of July 1, 1990 (the '$Second Assignment Agreement") . In consideration for such assignment, the Trustee proposes to enter into a Trust Agreement with the City and the corporation, dated as of July 1, 1990 (the "Trust Agreement") , pursuant to which the Trustee proposes to execute and deliver $3,997,148. 14 aggregate principal amount of Insured certificates of Participation (Redlands Community Hospital Project) 1990 Series A (the "Certificates") ,, evidencing proportionate interests of the owners thereof in Installment Payments to be made by the City pursuant to the Installment Sale Agreement. The Certificates shall be limited obligations of the 9612009i A-1 $129/90 City payable solely from Revenues (as defined in the Trust Agreement) , consisting primarily of Purchase Payments received by the City pursuant to the Installment Purchase Agreement. The Certificates are secured by a Deed of Trust, dated as of February 1, 1987 (the #!Heed of Trust,#) , between the Corporation, as trustor, and Security Pacific National Bank, as trustee, for the benefit of the City and the Office of Statewide Health Planning and Development. The offering of the Certificates is described in a preliminary official statement dated June 6, 1990 (the "Preliminary official Statement,,) which, together with such changes, if any, as are: accepted by the Underwriter and including the cover page andallappendices, exhibits, maps, reports and statements included therein or attached thereto, is herein called: the "Official Statement's. Pursuant to the Trust Agreement and the Installment Purchase Agreement, the Cross Revenues (as defined in the Installment Purchase Agreement) of the Corporation are pledged to the Trustee to secure payment of the Certificates, including the interest thereon, and to secure the obligations: of the Corporation under the Installment Purchase Agreement, including its obligation to make the Purchase Payments. In order to induce. the City and, Goldman, Sachs & Co (the "Underwriter") to enter into a certificate purchase contract with respect to the Certificates (the "Purchase Contract") , and to consummate the transactions therein contemplated, the Corporation hereby represents, warrants and agrees with each of you as follows.- (1) ollows.(1) The Corporation is a nonprofit public benefit corporation, validly existing and in goad standing under the laws of the State of California, has full legal right, power and authority to enter into this Letter of Representation and the Legal Documents (as defined in the Purchase Contract) to which it is a party, to approve the Purchase Contract, the Preliminary official Statement and the Official statement and to carry out and consummate all transactions contemplated by the Purchase Contract, the Legal Documents, the Official Statement, and this Letter of Representation to be carried out and consummated by the Corporation, and by proper corporate action has duly authorized the execution and delivery of this Letter of Representation and the Legal Documents to which the Corporation is a party, the approval of the Purchase Contract and the Official. Statement and distribution of the Official statement and has ratified the distribution of the Preliminary official Statement. (2) The officers of the Corporation executing this Letter of Representation and the Legal Documents to which the Corporation is a party and approving the Purchase Contract and the Official Statement are duly and properly in office and fully` authorized, to execute the same. (3) The Purchase Contract and the Official Statement have been duly approved by the Corporation- this Letter of Representation has been duly authorized, executed and delivered by the Corporation; the Legal Documents to which the Corporation is a party have been duly authorized and at the Closing (as that term is defined in the Purchase Contract) will have been duly executed and delivered by the Corporation; and the performance by the Corporation of its obligations thereunder and the consummation of the transactions contemplated thereby have been duly authorized and approved; and this Letter of Representation and the Legal Documents to which the Corporation is a party will, when so executed and delivered, constitute valid, binding and enforceable obligations of the Corporation in accordance with their respective terms except as the same may be limited b bankruptcy, insolvency and ether laws affecting creditors' rights generally and except as the enforceability of indemnification provisions in this ;Letter of Representation may be limited by applicable law. (4) The Corporation is not in any material gray in breach of or default under (i) to the best of its knowledge, any applicable 'law or administrative regulation of the Mate o California or the United States material to the business of the Corporation or any applicable judgment or decree or (ii) any loan agreement, indenture, bond, nate, resolution, material agreement or other instrument to which the Corporation 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 an event of default under any such instrument, except as expressly 'set forth in the official Statement; and neither the execution and delivery of this Letter of Representation, the approval of the Purchase Contract or the Official Statement, the execution and delivery of the Legal Documents to which the Corporation is a party, the consummation of the transactions therein contemplated, or the fulfillment of or compliance with the terms and: conditions thereof will conflict with or constitute a violation or breach of or default (with due notice or the passage of time or both) under the articles of incorporation of the Corporation, its bylaws or, to the knowledge of the Corporation, any applicable law or administrative rule or regulation, or any applicable court or administrative decree or order, or any indenture, mortgage, deed of trust, loan agreement, lease, contract or other agreement or instrument to which the Corporation is a party or by which it or its properties are otherwise subject or bound, or result in the creation or imposition of any prohibited lien, charge or encumbrance of any nature whatsoever upon any of the property or assets of the Corporation, which conflict, violation, breach, default, lien, charge or encumbrance might have consequences that would materially and adversely affect the consummation of the transactions contemplated by the Purchase Contract, this Letter 9G1ZG 9J - 6/2919 of Representation, the Official Statement or the other Legal Documents or the financial condition, assets, properties or operations of the Corporation or its properties. (5) No consent or approval of any trustee or holder of any indebtedness of the Corporation, and no consent, permission, authorization, order or license of, or filing or registration with, any governmental authority is necessary in connection with the execution and delivery of this Letter of Representation, the execution and delivery of the Legal Documents by the Corporation; the approval of the Purchase Contract or the Official Statement; or the consummation of any transaction therein contemplated, except as have been obtained or made and as are in full force and effect. (6) There is no action, suit, proceeding, inquiry or investigation before or by any court of federal, state, municipal or other government authority pending or, to the knowledge of the Corporation, threatened against or affecting, the existence of the Corporation or the titles of its officers to their respective offices or seeking to prohibit, restrain or enjoin the sale, execution and delivery of the Certificates or the execution and delivery of the Legal Documents or the payment by the Corporation of moneys owed by it under the Installment Purchase Agreement or the pledge by the Corporation of its Gross Revenues to secure payment of the principal of, and premium, if any, and interest on the Certificates, or in any way contesting or affecting the validity or enforceability of the Certificates, the Legal Documents or this Letter of Representation or contesting the powers of the Corporation or its authority to enter into, adopt or perform its obligations under any of the foregoing, or contesting in any way the completeness or accuracy of the Preliminary Official Statement or the Official Statement, or any amendment or supplement thereto, or otherwise affecting the corporation or the assets, properties or operations of the Corporation which, if determined adversely to the Corporation or its interests, would have a material and adverse effect upon the consummation of the transactions contemplated by or the validity of the Purchase Contract, this Letter of Representation, the official Statement or the other Legal Documents or upon the Corporation, and the Corporation is not in default with respect to any order or decree of any court or any order, regulation or demand of any federal, state, municipal or other governmental authority, which default might have consequences that would materially and adversely affect the consummation of the transactions contemplated by the Purchase Contract, this Letter of Representation, the Official Statement or the other Legal Documents or the financial condition, assets, properties or operations of the Corporation care its properties. 9GIZ009i A-4 61241" ( ) The Corporation is an organization described in Section 541(c) ( ) of the Internal Revenue Code of 1986, as amended, or corresponding provisions of prior law, based on a determination from the Internal Revenue Service; said determination has not been modified, limited or revoked as to the Corporation; there is no action, suit, proceeding, inquiry or investigation before or by any court or other governmental authority or agency pending or, to the knowledge of the Corporation, threatened which could affect the Corporation's status as an organization described in Section 501 (c) (3) of said Code; the Corporation is in compliance with the terms, conditions and limitations in said determination; the facts and circumstances that form the basis of such determination as represented to the Internal Revenue Service continue substantially to exist and based upon such determination the Corporation is exempt from federal income taxes under Section 501(a) of the Internal Revenue Code of 1986, as amended, except .for unrelated business income subject to taxation under Section 511 of the Internal, Revenue Code of 1986, as amended. (8) The Corporation is a corporation organized and operated exclusively for charitable purposes within the meaning of Section 501 (a) of the Internal Revenue Code. of 1986, as amended, not for pecuniary profit, no part of the net earnings of which inure to the benefit of any private shareholder or individual. (9) The proceeds of the Certificates will not be used inconnectionwith any unrelated trade or business of the Corporation as defined in Section 513 of the Internal Revenue Code of 1986, as amended. (10) The-Corporation has all necessary power and authority to conduct the business now being conducted by it and as contemplated by the Legal Documents. The Corporation has complied in all material respects with all applicable requirements of the' United States of America and the State of California, and of their respective agencies and instrumentalities, to operate the Health Facilities substantially as they are being operated and is fully qualified by all necessary permits, licenses, certifications, accreditations and qualifications, including, without limitation, accreditation of its existing facilities, to conduct its business as it is presently being conducted and to enter into this Letter of Representation and the Legal Documents to which it is a party, to approve the Purchase Contract and: the official Statement, and to be reimbursed (to the extent such reimbursement is available under existing applicable statutes, regulations and administrative practices) for its costs and expenses under all third party payor programs accounting for a significant portion 9G1ZOtl9J A 6/29190 of the Corporation's gross revenues in its fiscal year ended September 30, 1989 including, without limitation, Medicare. (11) At the Closing, the Corporation will have good and marketable title to the Health Facilities free and clear from all encumbrances other than Permitted Encumbrances, as that to is defined in the Installment Purchase Agreement. (12) The Corporation has not incurred any material liabilities, direct or contingent, nor has there been any material adverse change in the financial position, results of operation or condition, financial or otherwise, of the corporation since September 30, 1989 which is not described in the Official Statement, whether or not arising from transactions in the ordinary course of business. (13) Between the date hereof and the date of the Closing, the Corporation will not, without the prior written consent of the Underwriter, except as described in or contemplated by the Official Statement, incur any material liabilities, direct or contingent, other than in the ordinary course of business. (14) As of the date hereof, the Official Statement (including the financial statement, and other financial and statistical data contained elsewhere in the official Statement) , as amended or supplemented pursuant to the Purchase contract or this Letter of Representation, if applicable, does not and will note 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. (15) Preliminary Official Statement heretofore delivered to the Underwriter is deemed final by the Corporation as of the date thereof, except for the omission of such information as is permitted to be omitted in accordance with paragraph (b) (1) of Rule l5c2-12 of the Securities Exchange Commission. Within seven (7) business days from the date hereof and within sufficient time to accompany any confirmation requesting payment from any customers of the Underwriter, the Corporation shall cause a final printed form of the Official Statement to be delivered to the Underwriter in sufficient quantity to comply with paragraph (b) (4) of Rule 15c2-12 and the rules of the Municipal Securities Rulemaking Board. If, after the date hereof and until 25 days after the end of the "underwriting period" (as defined in Rule 15c2-13) the Corporation acquires knowledge of any event that might cause the 9GIZO09i A-6 IS/z9/90 Official Statement to contain any untrue statement of a material fact or to omit to state a material fact necessary to 'make the statements therein, in the light of the circumstances under which they were made, not misleading, the Corporation shall notify the Underwriter (and for the purpose of this clause shall provide the Underwriter with such information as they may from time to time request) , and, if in the opinion of the Underwriter such event requires the preparation and publication of a supplement or amendment to the Official Statement, at its expense to supplement or amend the official Statement in a form and manner approved by the Underwriter and furnish to the Underwriter a reasonable number of copies of such supplement or amendment. (16) If between the date hereof and the date of the Closing any event shall occur which might or would cause 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 the statements therein, in light of the circumstances under which they were made, not misleading, the Corporation shall notify the City, the Trustee and the Underwriter and, if, in the opinion of the Corporation, the City, the Trustee or the Underwriter or their respective counsel such event requires the preparation and publication of a supplement or amendment to the Official Statement, the Corporation will request the City at the Corporation's expense, to cause the official Statement to be amended or supplemented in a form and manner approved by the Underwriter. (17) After the Closing, the Corporation will (a) not participate in the issuance of any amendment of or supplement to the Official Statement to which, after being furnished with a copy, you shall reasonably object in writing or which shall be disapproved by your counsel and (b) if any event relating to or affecting the City, the Trustee or the Corporation, or the Health Facilities shall occur as a result of which it is necessary, in the opinion of counsel for the Underwriter or the City, to amend or supplement the Official Statement in order to make the Official Statement not misleading in light of the circumstances existing at the time it is delivered to a purchaser, forthwith prepare and furnish to the Underwriter, the Trustee and the City (at the expense of the Corporation) a reasonable number of copies of an amendment of or supplement to the Official Statement (in form and substance satisfactory to counsel for the Underwriter and counsel to the City) 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 light of the circumstances existing at the time the official Statement is delivered to a purchaser, not misleading. For the purposes of this subsection, the Corporation 9GIZ004i A-7 612$190 will furnish such information with respect to itself, its present and proposed Health Facilities as any of you may from time to time reasonably request. (18) The Corporation 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 certificates 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 Certificates for investment under the laws of such states and other jurisdictions, and will use its best efforts to continue such qualifications in effect so long as required for the distribution of the Certificates; provided, however, that in no event shall the Corporation 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 subject. (19) The Corporation hereby authorizes the use of the Official Statement, including all amendments and supplements thereto, by the Underwriter in connection with the public offering and sale of the Certificates and consents to thea use by the Underwriter prior to the date hereof of the Preliminary Official Statement in connection with the public offering and sale of the Certificates. (20) To the extent permitted by law, the Corporation agrees to indemnify and hold you harmless and each person, if any, who controls (as such term is defined in Section 15 of the Securities Act of 1933, as amended) you and your officers, agents and employees against any and all losses, claims, damages, liabilities and expenses (i) arising out of any statement or information in the Preliminary Official Statement or in the Official Statement relating to the Corporation and the Health Facilities, all as defined in the Official Statement, 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 Corporation and the Health Facilities not misleading in any material respect and (ii) to the extent of the aggregate amount paid in settlement of any litigation commenced or threatened arising from a claim based upon any such untrue statement or omission if such settlement is effected with the written consent of the Corporation. In case any claim shall be made or action brought against any of you or any controlling person based upon the Official Statement for which indemnity may be sought against the Corporation, as provided above, you shall promptly notify the Corporation in writing setting forth the particulars of such claim or action and 9GIZ009J A-8 6/29/90 the corporation shall assume the defense thereof, including the retaining of counsel acceptable to you and the payment of all expenses. You 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 (i) the Corporation shall have specifically authorized the retaining of such counsel or (ii) the parties to such suit include the Underwriter or controlling person or persons, and the Corporation 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 corporation, in which case the Corporation shall not be entitled to assume the defense of such suit but you shall bear the fees and expenses of such counsel. (21) The Corporation hereby agrees to pay the expenses described in Paragraph 4 of the Purchase Contract, and to pay any expenses incurred in amending or supplementing the Official Statement pursuant to the Purchase Contract or this Letter of Representation. The representations, warranties, agreements and indemnities herein shall survive the Closing under the Purchase Contract and any investigation made by or on behalf of any of you or any person who controls any of you of any matters described in or related to the transactions contemplated hereby and by the Purchase Contract, the official Statement, and the other Legal Documents. This Letter of Representation shall be binding upon and inure solely to the benefit of each of you and the Corporation and, to the extent set forth herein, persons controlling any of you, and their respective officers, employees, agents and personal representatives, successors and assigns, and no other person or firm shall acquire or have any right under or by virtue of this Letter of Representation. This Letter of Representation may be executed in several counterparts, each of which shall be an original and all of which shall constitute one and the same agreement. If the foregoing is in accordance with your understanding of the agreement between us, please sign and return 94120091 A-9 6129/90 to the Corporation a duplicate of this Letter of Representation whereupon this will constitute a binding agreement between us in accordance with the terms hereof. Very truly yours, REDLANDS COMMUNITY HOSPITAL By: Its: Accepted and confirmed as of the date first above written GOLDMAN, SACHS & Co. THE CITY OF REDLANDS By: Its: - Mayor ATTEST: City Clerk, City of- Redlands 9GIZ009i A-10 spa fs EXHIBIT B THE CERTIFICATES Aggregate Initial Amount Due Initial per$5,000 Yield to {November 151 Amount Final Com pQand ed Amount aturity 2000 $ 561,756-90 $2,485.65 6.900% 2001 667,455.33 2,297.39 7.000% 2002 573,489.17 2,131.93 7,050% 2003 573,179.20 1,976.48 7.100% 2004 571,147.20 1,830.60 7.150% 2005 1,160,120.34 1,706.41 7.150% $3,227,148.14 94SIZO09-J B-1 6/29/90 EXHIBIT Letterhead of Ernst & Young Redlands Community Hospital 350 Terracina Boulevard P.O. Box 3391 Redlands, California 92373-0742 Goldman, Sachs & Co SS California Street Suite 3120 San Francisco, California 94104 Ladies and Gentlemen: We have audited the balance sheets of Redlands Community Hospital (the "Corporation") as of September 30, 1989 and 1988, and the related statements of revenues and expenses, changes in fund balances and cash flows for the years then ended, included in Appendix B to the official Statement dated July 12, 1990 (the "Official Statement") , relating to the offering of $3 ,997, 148. 14 Insured Certificates of Participation (Redlands` Community Hospital Project) 1990 Series A (the "Certificates") evidencing proportionate interests of the owners thereof in installment payments to be paid by the City of Redlands as the purchase price of certain property pursuant to the Installment Sale Agreement with the Corporation. Our report with respect thereto, dated December 20, 1989, is also included in Appendix B to the official Statement. In connection with. the +Official. Statement. 1 e are independent auditors with respect to the Corporation within the meaning of that terminology as defined in Rule 1.01 of the Code of Professional Ethics of the American Institute of Certified Public Accountants. 2. We have not audited any financial statements of the Corporation as of any date or for any period subsequent to September 30, 1989. The purpose (and therefore the scope.) 9GIZODI3 -1: 6/29/90 of the audit was to enable us to express our opinion on the; financial, statements as of September 30, 1989, and for the year then ended, but not on the financial statements for any interim period within such year. Therefore, we are unable to and do not express an opinion on the unaudited balance sleets as of May 31, 1990 and the unaudited statements o revenues and expenses and cash flows for the eight-month periods ended May 31, 1990 and May 31, 1989 or on the financial position, results of operations or cash flows as of any date or for any period subsequent to September 30, 1989.` 3 . For purposes of this letter we have read the minutes of the meetings of the Board of Directors and the; finance Committee) of the Corporation as set forth in the minute beaks at July 11, 1990, officials of the corporation having advised us that the minutes ofallsuch meetings through; thatdatewere set forth therein and have carried out other procedures to July 11, 1990, (our work did not extend to include July 12, 1990) asfollows: i) read the unaudited balance sheet as of May 31., 1990 and the unaudited statements of revenues and expenses for the eight-month periods ended May 31, 1990 and 1989 furnished by the Corporation (see copy attached which does not include all the disclosures required by generally accepted accounting principles) . and ii) made inquiries of certain officials of the, Corporation who have responsibility for financial and accounting' matters as to whether the unaudited statements of revenues and expenses referred to under 3 (i) above are in conformity with generally accepted accounting principles applied, on a basis substantially consistent with that of the audited financial statements included in Appendix B to the Official Statement. The foregoing procedures old not constitute an audit made in accordance with generally accepted auditing standards. Also, they would not necessarily reveal matters of significance with respect to the comments in the following paragraph. Accordingly, we made no representations regarding the sufficiency of the foregoing procedures for your purposes. 4. Nothing came to our attention as a result of the foregoing procedures, however, that caused us to believe that: (a) The unaudited statements of revenues and expenses of the Corporation described in 3i) above are not in conformity with generally accepted accounting a a ao ;i C- /29/1;0 principles applied on a basis substantially consistent with the audited financial statements included in Appendix B to the official Statement; or ( i) at May 31, 1990, there was any change in the long- term debt (other than scheduled payments) of the Corporation, or any decreases in net current assets or net assets as compared with amounts shown on the September 30, 1983 audited balance sheet included in Appendix S to the official Statement, or (ii) for the period from October 1, 1989 to May 31, 1990, as compared with the corresponding period in the preceding year, there were any decreases in operating income or increase in the total amounts of excess of expenses over revenues., except in all instances for changes, increases or decreases which the official Statement discloses have occurred or may occur. a. Corporation officials have advised 'us that no financial statements as of any date or for any period subsequent to May 31, 1990, are available; accordingly, the procedures carried out by us with .respect to changes in financial- statement items after May 31, 1990, have, of necessity, been even more 'limited than those with respect to the periods referred to above. we have made inquiries of certain officials of the Corporation who have responsibility for financialandaccounting matters regarding (i) whether there was any increase at duly 11, 1990, in the long-term debt of the Corporation or any decrease in net current assets or net assets as compared with amounts shown can the September 30, 1989, statement of financial position included in Appendix B to the Official Statement, or (ii) for the period from, June 1, 1994, to July 11, 199th, there were any decreases, as compared with °the corresponding period in the preceding year, in operating income or the excess of revenues over expenses. on the basis of these inquiries and our reading of the minutes as described in Paragraph 3, nothing came to our attention that caused us to believe: that there was any such change or decrease, except in all instances for changes or decreases that the Official. Statement discloses have occurred or may occur. 6. For the purposes of this letter, we have also read the following information appearing in Official Statement on the; indicated pages. 9 1 ZO09J - 6/29/90 ITEC PAGE DESCRIPTION A 22 Under the table "Summary of Revenues and Expenses, " the dollar amounts under the columns for the years ended Septem- ber 30, 1989, and 1988, and the eight months. ended May 31, 1990, and, 1989 (unaudited) .. H 18 The three percentage= amounts under the caption "Historical Utilization of Corporation's Facility" under the line item "Occupancy (Percent) " . 17 Under the caption entitled "Medical Staff" the four numbers in the 11total'f line relating to physician specialty and the percentage amount in the columns headed "Percent: of Total" relating to medical staff age distribution. our audits of the financial statements for the periods referred to in the introductory paragraph of this letter comprises audit tests and procedures deemed necessary for the purpose of expressing an opinion on such financial statements taken as a whole. For neither of the periods referred to therein nor for any tither period did we perform audit tests for the purpose of expressing an opinion on individual balances of accounts or summaries of selected transactions such as those referred to in Paragraph 6 and,, accordingly, we express no opinion thereon 7 For the purposes of this letter, we have performed the following additional procedures, which were applied as indicated with respect to the items enumerated in Paragraph 6 above. 9 1ZO09J C-4 6/29/90 ITEMS IN PARA- GRA G PM 6 ADQVE PROCEDURES 2 FINDINGS A We compared the dollar amounts under the columns for the years ended Septem- ber 30, 1990, and 1989, to the corre- sponding amounts included in the audited financial statements included in Appen- dix B to the official Statement-. We compared the dollar amounts under the columns ;for the eight-month periods ended May 31,, 1990, and 1989, to the un- audited statements of revenues and ex- penses prepared by the Corporation and found them to be in agreement. We recomputed the mathematical percent- age calculations under the. caption "Historical Utilization of Corporation's Facility" for the "Occupancy (Percent) " amounts for each of the three periods shown and found them to be in agreement. C We recomputed the total under the col- umns in the table relating to physician specialty and in the table relating to medical staff age distribution and found them to be in agreement. 8. It should he understood that we make no representations regarding questions of legal interpretation or regarding the sufficiency for your purposes of the procedures enumerated in the preceding paragraph; also;, such procedures would not necessarily reveal any material misstatement of the amounts listed above. Further,; we have addressed ourselves solely to the foregoing date as set forth in the official Statement and make no representationsasto the adequacy of disclosure or as to Whether any material facts have: been omitted 9. This letter is solely for the information of the addressees and to assist the underwriter in conducting and documenting its investigation of the affairs of the Corporation in connection with the offering of the Certificates and is not to be used, circulated., quoted or otherwise referred to for any other purpose, including, but not limited to, the purchase or sale of securities, nor is it to be filed with or referred to in whole or in part in the Official Statement or in any ether document, except that reference may be made to it in the Purchase Contract related to the Certificates or in any list of closing documents pertaining to the offering of said Certificates by the Official Statement. 9G1Z0 9J C 6129/90 EXHIBIT D FORM OF OPINION OF SPECIAL COUNSEL City Council of the City of Redlands Re: $3,997, 148 . 14 Insured Certificates of Participation (Redlands Community Hospital Project) 1990 Series A Evidencing Proportionate Interests of the Owner Thereof in an Installment Sale Agreement, including the Right to Receive Installment Payments Thereunder to be made by the City of Redlands, California Ladies and Gentlemen: We have reviewed the Constitution and the laws of the State of California and certain proceedings taken by the City of Redlands, California (the "City") in connection with the authorization, execution and delivery by the City of the Installment Sale Agreement dated as of July 1, 1990 by and between Redlands Community Hospital, a California nonprofit benefit corporation (the "Corporation") and the City (the "Sale Agreement") , and the Installment Purchase Agreement dated as of July 1, 1990 by and between the City and the Corporation (the "Purchase Agreement") . We have also reviewed the executed Sale Agreement, the executed Purchase Agreement, the executed Trust Agreement dated as of July 1, 1990 (the "Trust Agreement") by and among the City, the Corporation and Security Pacific National Bank, as trustee (the "Trustee") , the executed Second Assignment Agreement between the City and the Trustee dated as of July 1, 1990 (the "Second Assignment Agreement") and such other documents and information as we consider necessary to render this opinion. Pursuant to the Trust Agreement, the Trustee has agreed to execute and deliver certificates of participation (the "Certificates of Participation") evidencing a proportionate interest in installment payments to be made by the City pursuant to the Sale Agreement ("Installment Payments") . Based upon the foregoing we are of the opinion that the Sale Agreement, the Purchase Agreement, the Trust Agreement and the other agreements mentioned above have been duly authorized, executed and delivered by the City and constitute legally valid and binding obligations of the City enforceable against the City in accordance with their respective terms, except <as the same may be limited by bankruptcy, insolvency, reorganization, moratorium 9GIZ009i D-1 6/29/90 or other laws relating to or affecting generally the enforcement of creditors' rights, and except as their enforcement may be subject to the exercise of judicial discretion in accordance with general principles of equity. The Certificates of Participation have been duly executed and delivered by the Trustee pursuant to the Trust Agreement and are entitled to the benefits of the Trust• Agreement. The obligations of the City under the Sale Agreement to make Installment Payments constitute a limited obligation payable from and secured solely by payments to be received under the Purchase Agreement and certain other fund held as a part of the trust estate created under the Trust Agreement. The obligation to pay the principal of and interest with respect to the Certificates of Participation is not an indebtedness of the City, the State of California or any political subdivision thereof or a loan of the credit thereof within the meaning of any constitutional or statutory provision. We are further of the opinion that, under existing laws, regulations, rulings and judicial decisions, the portion of each Installment Payment due under the Sale Agreement designated as and comprising interest and received by the owners of the Certificates of Participation ("interest paid with respect to the Certificates") is exempt from personal income taxation imposed by the State of California. The Internal Revenue Code of 1986, as amended (the "Code") , sets forth certain investment, rebate and related requirements which must be met subsequent to the execution and delivery of the Certificates of Participation for the interest paid with respect to the Certificates to be and remain excluded from gross income for purposes of federal income taxation. Noncompliance with such requirements could cause the interest paid with respect to the Certificates to be subject to federal income taxation retroactive to the date of execution and delivery of the Certificates of Participation. Pursuant to the Trust Agreement, the City has covenanted to comply with the requirements of the Code. We are of the opinion that, assuming compliance with the aforementioned covenant, the interest paid with respect to the Certificates is excluded from gross income for purposes of federal income taxation under existing statutes, regulations, rulings and court decisions. We are further of the opinion that interest paid with respect to the Certificates is not a specific preference item for purpose of the alternative minimum tax provisions of the Code. However, interest paid with respect to the Certificates received by corporations will be included in corporate adjusted net book income and adjusted current earnings, a portion of which may increase the alternative minimum taxable income of such corporations. 961 Z009J D-2 6/29/90 Although interest paid with respect to the Certificates is excluded from gross income for federal tax purposes, the accrual or receipt of interest paid with respect to the Certificates may otherwise affect the federal income tax liability of the recipient. The extent of these other tax consequences will depend on the recipient's particular tax status or other items of income or deduction. We express no opinion regarding any such consequences. Respectfully submitted, 9G1ZOO9J D-3 6/29/90 EXHIBIT E FORM OF OPINION OF HANSON, BRIDGETT, MARCUS, VLAHOS AND RUQ?Y PURSUANT TO SECTION 3 (d) (7) OF THE PURCHASE CONTRACT July 26, 1990 GOLDMAN, SACHS & CO. 555 California Street San Francisco, California 94104 Re: $ 3 ,997, 148 .14 Insured Certificates of Participation (Redlands Community Hospital Project) 1990 Serjes ,A Ladies and Gentle-men: We have acted as counsel to Redlands Community Hospital, a California nonprofit public benefit corporation (the "Corporation") in connection with the execution and delivery by the City of Redlands (the "City") and Security Pacific National Bank (the "Trustee") , as Trustee, of that certain Trust Agreement dated as of July 1, 1990 (the "Trust Agreement") among the Corporation, the Trustee and the City and the purchase by you, of $3 ,997, 148. 14 aggregate principal amount of City of Redlands Insured Certificates of Participation (Redlands Community Hospital Project) 1.990 Series A (the "Certificates") as provided in the Certificate Purchase Contract dated as of July 12, 1990 (the '*Purchase Contract") by and between you and the City, as approved by the Corporation. In this connection, we have examined the following: (a) A certified copy of the Articles of Incorporation of the Corporation, as amended to date. (b) A Certificate of Good Standing of the Corporation issued by the Secretary of State of the State of California on , 1990. (c) The Bylaws of the corporation, as amended to date. (d) Resolution No, of the City, adopted by the City on July 10, 1990 authorizing the execution and delivery of the Certificates. (e) Resolutions relating to the transactions herein referred to, adopted by the Board of Directors of the 9GIZ009i E-1 6/29/90 Corporation at a meeting heed on ,, 1990 and b the Board of Directors of RHS Corp. , as the sole member of the Corporation, at a meeting held on 1990. (f) The Installment Sale Agreement, dated as of July 1,, 1990 between the City and the Corporation ("Installment Sale Agreement") . (g) The Installment Purchase Agreement, dated as of July 1, 1990, between the. City and the Corporation (the °"Installment Purchase Agreement") . (h) The 'Frust Agreement. (i) The Assignment Agreement dated as of July 1, 1990, between the Corporation and: the Trustee (the "Assignment Agreement") . (j) The Second Assignment Agreement dated as of July 1, 1990 between the. City and the Trustee (the "Second Assignment Agreement") . (k) The Depository Agreement dated as of February 1, 1987, among the Trustee, the Corporation and. Bank of America National Trust and Savings Association, as depository (the "Depository Agreement") (1) The Purchase Contract. (m) The Letter of Representation from the Corporation to the Underwriter, dated July 12, 1989 (the "Letter of Representation") (n) The Official Statement, dated. July 12, 1990, relating to the Certificates (the "Official Statement,,) . (o) The Regulatory Agreement, dated as of July 1, 199 (the "Regulatory Agreement") , and, the Contract of Insurance, dated as of July 1, 1990 (the "Contract o " Insurance") , both among the Office of Statewide Health Planning and Development of the State of California (the "Office") , the City and the Corporation. (p) The meed of Trust, dated. February 1, 1987, by and between the Corporation, as trustor, and Security Pacific National Ban} , as trustee, for the joint and several benefit of the City and the Office. We have also made such ether investigations of fact and law, examined such documents, obtained such certificates from 9=009JE-2 15/29190 ;public officials and officers of the Corporation, and done such other things as we have determined necessary to render this opinion. In rendering the opinions expressed in paragraphs ) (4) , ) (6) (7) and (9) , we have relied, to the extent of the factual matters expressed therein, on certificates of officers o the Corporation satisfactory to us and have made reasonable inquiries relative thereto. Based wren the foregoing, it is our opinion that: (1) The Corporation is a. nonprofit public benefit corporation duly formed and in good standing under the laws of the State of California, has full legal right, power and authority to approve the Purchase Contract and.. the Official Statement and to enter into the Letter of Representation, the Installment Sale Agreement, the Installment Purchase Agreement, the Trust Agreement, the Assignment Agreement, the Regulatory Agreement, the Contract of Insurance, the deed of Trust and the Repository Agreement (hereinafter collectively referred to as the "Corporation o s Agreements"') (2) The Corporation's Agreements have been duly authorized, executed and delivered by the Corporation, and the Purchase contract and the official Statement have been early approved by the Corporation; the Corporation's Agreements constitute the Legal,, valid and binding agreements of the Corporation enforceable against the Corporation in accordance with their respective terms, except as enforcement of each may be limited by bankruptcy, insolvency or other laws affecting the enforcement of creditors' rights generally and by the application of equitable principles if equitable remedies are sought. ( The approval: of the Purchase Contractandthe Official Statement and the execution and delivery of the Corporation's Agreements, the consummation of the transactions therein contemplated and the fulfillment of or compliance with the terms and conditions thereof, will not conflict with or constitute a violation or breach of or default (with due notice or the passage of time or bath) under the Articles o' Incorporation of the Corporation, its Bylaws or, to the best of our knowledge after reasonable investigation, any applicable law or administrative rule or regulation (except for state Blue Sky or federal securities laws, as to which we express no opinion) , or, to the best of our knowledge after reasonable investigation, any applicable court or administrative decree or order, necessary` to accommodate this certificate of participation financing or any indenture,, mortgage, deed of trust, loan agreement, lease, or other material contract, agreement or instrument to which the Corporation is a party or by which it or its properties i otherwise subject or bound of which we are aware after reasonable investigation, or result in the creation or imposition of any prohibited lien, charge or encumbrance of any nature whatsoever upon any of the property or assets of the Corporation, which conflict, violation, breach, default, lien, charge or encumbrance might have consequences that would materially and adversely affect the consummation of the transactions contemplated by the Corporation's Agreements or the financial condition, assets, properties or operations of the Corporation. (4) To the best of our knowledge, after reasonable investigation, no consent or approval of any trustee or bolder of any indebtedness of the Corporation, and no consent, permission, authorization, order or license of, or filing or registration with, any governmental authority is necessary in connection with the approval of the Purchase Contract or the Official Statement or the execution and delivery of the Corporation's Agreements or the consummation of any transaction therein contemplated, except as have been obtained or made and as are in full force and effect. We express no opinion as to any approvals, obligations or consents as may, be required under any state Blue Sky or federal securities laws. (5) To the best of our knowledge after reasonable investigation: (a) there is no action, suit, proceeding, inquiry or investigation before or by any court or federal, state, municipal or other governmental authority pending or threatened against or affecting the Corporation or the assets, properties or operations of the Corporation which, if determined adversely to the Corporation or its interests, would have a material and adverse effect upon the consummation of the transactions contemplated by or the validity of the Purchase Contract, the corporation's Agreements, or upon the financial condition, assets, properties or operations of the Corporation, and (b) the Corporation is not in default with respect to any order or decree of any court or any order, regulation or demand of any federal, state, municipal or other governmental authority, which default 'might have consequences that would materially and adversely affect the consummation of the transactions contemplated by the Purchase Contract, the Corporation's Agreements, or the financial condition, assets, properties or operations of the Corporation. (6) The Corporation is an organization described in Section 501(c) (3) of the Internal Revenue Code of 1986, as amended, and the Corporation is exempt from federal income taxes under Section 501(a) of the Internal Revenue Code of 1986, as amended, except for unrelated business income subject to taxation under Section 511 of the Internal Revenue Code of 1986, as amended. (7) The Corporation has all necessary power and authority to conduct the business now being conducted by it, and to be reimbursed (to the extent that such reimbursement is 9GIZO0913 E-4 6/29/90 available under existing applicable statutes, regulations and administrative practices) for its costs and expenses under Medicare. 8) Based upon the information mads available to us in the course of our participation in the preparation of the Official. Statement as counsel for the Corporation, and without having undertaken to determine independently or assuming any responsibility for the accuracy, completeness or fairness of the statements contained in the official: Statement, nothing has come to our attention which would lead us to believe that the statements and information contained in the official Statement (excluding therefrom the financial statements and the statistical data included in the Official statement, as to which we express no opinion) as of the date of the. Official, statement or as of the date hereof, contain an 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 the light of the circumstances under which they were made, not misleading.; 'very truly yours, 9GU0091)