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S.A -2o <br />Pursuant to the Act, all lands owned by a public entity are omitted from the levy of the Special <br />Tax, unless the public entity acquires the property after the levy of the Special Tax, in which case the <br />public entity will be obligated to pay the Special Tax, subject to certain limitations. The Rate and <br />Method exempts from the S,-edar Tax all publicly owned parcels which are normally exempt from ad <br />valorem taxes under Califorida la including public streets, schools, school district administrative <br />offices, police and fire facilities, parks, and public drainage ways, rights -of -way, landscaping, <br />greenbelts and open space ( "Public Parcels "), as well as any parcel zoned for single or multi- family <br />residential use ( "Residential Parcels "). See "SECURITY FOR THE BONDS - Rate and Method" and <br />"BONDOWNERS' RISKS -Exempt Properties! The Special Taxes prepaid by Oracle are not pledged <br />for payment of the Bonds and the Oracle Parcels are not security for the Bonds. <br />The District has also covenanted in the Fiscal Agent Agreement to cause foreclosure proceedings <br />to be commenced and prosecuted under certain conditions against parcels with certain delinquent <br />installments of the Special Tax. For a more detailed description of the foreclosure covenant see <br />"SECURITY FOR THE BONDS - Proceeds of Foreclosure Sales." <br />THE BONDS DO NOT CONSTITUTE OBLIGATIONS OF THE CITY OR OF THE DISTRICT <br />FOR WHICH THE CITY OR THE DISTRICT LS OBLIGATED TO LEVY OR PLEDGE, OR HAS <br />LEVIED OR PLEDGED, GENERAL OR SPECIAL TAXES, OTHER THAN THE SPECIAL TAXES <br />REFEREN HEREIN. THE BONDS ARE LIMITED OBLIGATIONS OF THE DISTRICT PAYABLE <br />FROM PROCEEDS OF THE SPECIAL TAXES AND OTHER AMOUNTS PLEDGED UNDER THE <br />FISCAL AGENT AGREEMENT BUT ARE NOT A DEBT OF THE CITY, THE STATE OF <br />CALIFORNIA OR ANY OF ITS POLITICAL SUBDIVISIONS IN CONTRAVENTION OF ANY <br />CONSTITUTIONAL OR STATUTORY LIMITATION OR RESTRICTION. <br />2001 Parity Bonds. Under the Resolution of Formation, the District is authorized to issue <br />bonds in an aggregate principal amount of not -to- exceed $13,535,000. In February 2001, the District <br />issued its 5,045,000 principal amount of Special Tax Bonds, Series 2001A (the 2001 Bonds ") to <br />finance a portion of the Phase I improvements. The 2001 Bonds are secured by and payable from a <br />first pledge of Net Taxes on a parity with the 2003 Bonds. After issuance of the 2003 Bonds, no <br />additional bonds will be issued pursuant to the authorization. The 2001 Bonds and the 2003 Bonds <br />are collectively referred to herein as the "Bonds." <br />Risk Factors Associated with PwdmsfiV the 2003 Bonds. Investment in the 2003 Bonds <br />involves risks that may not be appropriate for some investors. See the section of this Official <br />Statement entitled "BONDOWNERS' RISKS" for a discussion of certain risk factors which should be <br />considered, in addition to the other matters set forth herein, in considering the investment quality of the <br />2003 Bonds. <br />-3- <br />