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8.A. - Page 28
<br /> be contained in the Annual Report and any notices of enumerated events is summarized below
<br /> under the caption "CONTINUING DISCLOSURE." The form of the Continuing Disclosure
<br /> Certificate is set forth in APPENDIX F—FORM OF CONTINUING DISCLOSURE
<br /> CERTIFICATE. The covenants of the City in the Continuing Disclosure Certificate have been
<br /> made in order to assist the Underwriter in complying with S.E.C. Rule 15c2-12(b)(5).
<br /> Tax Matters
<br /> In the opinion of Jones Hall, a Professional Law Corporation, San Francisco, California,
<br /> Bond Counsel, based on existing statutes, regulations, rulings and court decisions and
<br /> assuming, among other matters, compliance with certain covenants, interest on the Bonds is
<br /> excludable from gross income for federal income tax purposes, and is not a specific preference
<br /> item for purposes of the federal individual or corporate alternative minimum taxes, although
<br /> Bond Counsel observes that it is included in adjusted current earnings in calculating corporate
<br /> alternative minimum taxable income. In the further opinion of Bond Counsel, interest on the
<br /> Bonds is, under existing law, exempt from State of California personal income taxes. Bond
<br /> Counsel expresses no opinion regarding other federal or State tax consequences relating to the
<br /> ownership or disposition of, or the accrual or receipt of interest on, the Bonds. See "TAX
<br /> MATTERS."
<br /> Professionals Involved in the Offering
<br /> The proceedings of the Authority and the City in connection with the issuance of the
<br /> Bonds are subject to the approval as to their legality of Jones Hall, a Professional Law
<br /> Corporation, San Francisco, California,Bond Counsel. Certain legal matters will be passed upon
<br /> for the Authority and the City by Quint & Thimmig LLP, Larkspur, California, as Disclosure
<br /> Counsel, and by Pamela Thompson, Esq., the City Attorney. U.S. Bank National Association,
<br /> San Francisco, California, will act as the Trustee under the Indenture. The fees of Bond Counsel
<br /> and Disclosure Counsel and the Trustee are contingent upon the sale and delivery of the Bonds.
<br /> Forward-Looking Statements
<br /> This Official Statement, and particularly the information contained under the headings
<br /> entitled "PROJECT," "THE ENTERPRISE," "RISK FACTORS RELATING TO THE BONDS"
<br /> and APPENDIX A—GENERAL INFORMATION ABOUT THE CITY OF REDWOOD CITY
<br /> AND SAN MATEO COUNTY, contains statements relating to future results that are "forward-
<br /> looking statements" as defined in the Private Securities Litigation Reform Act of 2000. When
<br /> used in this Official Statement, the words "estimate," "forecast," "intend," "expect" and similar
<br /> expressions identify forward-looking statements. Such statements are subject to risks and
<br /> uncertainties that could cause actual results to differ materially from those contemplated in
<br /> such forward-looking statements. Any forecast is subject to such uncertainties. Inevitably, some
<br /> assumptions used to develop the forecasts will not be realized and unanticipated events and
<br /> circumstances may occur. Therefore, there are likely to be differences between forecasts and
<br /> actual results, and those differences may be material. The City is not obligated to issue any
<br /> updates or revisions to the forward-looking statements if or when its expectations, or events,
<br /> conditions or circumstances on which such statements are based occur. See "RISK FACTORS
<br /> RELATING TO THE BONDS" and "LIMITATIONS ON TAX REVENUES."
<br /> Other Matters
<br /> There follows in this Official Statement brief descriptions of the Bonds, the security for
<br /> the Bonds, the Indenture, the 2015 Installment Purchase Contract, the Authority, the City, the
<br /> Enterprise, and certain other information relevant to the issuance of the Bonds. The descriptions
<br /> and summaries of documents herein do not purport to be comprehensive or definitive, and
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