HomeMy WebLinkAboutAD 01-1 Memo RE Disclosure Council Opinion725 SOUTH FIGUEROA STREET SUITE 2800 LOS ANGELES, CA 90017-5406 213.488.7100 F: 213.629.1033
July 19, 2001
Sutro & Co. Incorporated
201 California Street
San Francisco, CA 94111
City of Bakersfield
1501 Truxtun Avenue
Bakersfield, CA 93301
Re: DISCLOSURE COUNSEL OPINION
City of Bakersfield Assessment District No. O l -1
(Ming at Allen/Mountain Vista Drive/Hampton Place)
Limited Obligation Improvement Bonds
Ladies and Gentlemen:
We have acted as disclosure counsel to the City of Bakersfield (the "City") in connection
with the purchase by Sutro & Co. Incorporated (the "Underwriter"), from the City of its
"City of Bakersfield Assessment District No. O l -1 (Ming at Allen/Mountain Vista
Drive/Hampton Place), Limited Obligation Improvement Bonds" in the aggregate
principal amount of $2,460,000 (the "Bonds"), pursuant to a Bond Purchase Contract,
dated July 12, 2001(the "Purchase Contract"), by and between the Underwriter and the
City. The Bonds are being issued pursuant to the Improvement Bond Act of 1915, being
Division 10 of the California Streets and Highways Code (the "1915 Act"), the Charter
and Municipal Code of the City, and Resolution No.088=01, adopted by the City Council
of the City on June 13, 2001(the "Bond Resolution"). Capitalized terms not otherwise
defined herein shall have the meanings ascribed thereto in the Purchase Contract.
In that connection, we have reviewed certain portions of the Bond Resolution, the 1915
Act, the Official Statement of the City, dated July 12, 2001, with respect to the Bonds
(the "Official Statement"), the Purchase Contract, certificates of the City, Wilson &
Associates (the "Assessment Engineer"), Launer & Associates (the "Appraiser"),
Communities at River Oaks, LLC, a California limited liability company ("Communities
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at River Oaks"), Campus Park, LLC, a California limited liability company ("Campus
Park"), Hampton Place LLC, a California limited liability company ("Hampton Place"),
U.S. Bank Trust National Association, as paying agent, registrar, and transfer agent, and
others, the opinions referred to in Section 3(d) of the Purchase Contract, and such other
records, opinions and documents, and we have made such investigations of law, as we
have deemed appropriate as a basis for the conclusions hereinafter expressed.
In arriving at the conclusions hereinafter expressed, we are not expressing any opinion or
view on, and, with the permission of the Underwriter and the City, are assuming and
relying on, the validity, accuracy, and sufficiency of the records, documents, certificates
and opinions referred to above (including the accuracy of all factual matters represented
and legal conclusions contained therein, including (without limitation) representations
and legal conclusions regarding the due authorization, issuance, delivery, validity and
enforceability of the Bonds and the exclusion of interest on the Bonds from gross income
for federal income tax purposes). We have assumed that all records, documents,
certificates and opinions that we have reviewed, and the signatures thereto, are genuine.
Based on and subject to the foregoing, and in reliance thereon, we are of the opinion that
the Bonds are not subject to the registration requirements of the Securities Act of 1933, as
amended, and the Bond Resolution is exempt from qualification pursuant to the Trust
Indenture Act of 1939, as amended.
We are not passing upon and do not assume any responsibility for the accuracy,
completeness, or fairness of any of the statements contained in the Official Statement and
make no representation that we have independently verified the accuracy, completeness,
or fairness of any such statements. However, in our capacity as disclosure counsel, we
met in conferences with representatives of the Underwriter, the City, the Assessment
Engineer, the Appraiser, Communities at River Oaks, Campus Park, Hampton Place, their
respective counsel, as applicable, Orrick, Herrington & Sutcliffe LLP, as bond counsel,
and others, during which conferences the contents of the Official Statement and related
matters were discussed. Based on our participation in the above-mentioned conferences,
and in reliance thereon and on the records, documents, certificates, and opinions herein
mentioned (as set forth above), we advise you that, during the course of our serving as
disclosure counsel on this matter, no information came to the attention of the attorneys in
our firm rendering disclosure counsel services in connection with such representation,
which caused us to believe that the Official Statement as of July 12, 2001, and as of the
date of this opinion (except for any financial statements and other financial, statistical, or
engineering data or forecasts, numbers, charts, estimates, projections, assumptions, or
expressions of opinion, any information about valuation, appraisals, absorption, or
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environmental matters, any information about The Depository Trust Company or the
book-entry-only system, or Appendices B, C, D, and E included therein, as to which we
express no opinion or view) contained or contains any untrue statement of a material fact
or omitted or omits to state any 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. Please be advised that only Bruce J. Graham has rendered such
disclosure counsel services in connection with such representation.
We are furnishing this letter to you pursuant to Section 3(d)(5) of the Purchase Contract.
This letter, and the legal opinions herein, are intended for the information solely of the
addressees hereof and solely for the purposes of the transactions contemplated by the
Official Statement and may not be relied upon by any other person or entity, or for any
other purpose, or quoted in whole or in part, or otherwise referred to, in any document, or
be filed with any governmental or other administrative agency or other person or entity
for any purpose, without the prior written consent of this firm. This letter is not intended
to, and may not, be relied upon by any owners of the Bonds.
We bring to your attention the fact that our legal opinions are an expression of
professional judgment and are not a guarantee of a result. Our engagement with respect to
this matter has terminated as of the date hereof, and we do not undertake to advise you of
any matters that may come to our attention subsequent to the date hereof that may affect
our legal opinions expressed herein.
Respectfully submitted,
PILLSBURY WINTHROP LLP
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