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HomeMy WebLinkAboutTranscript + 081517. 302P At a regular meeting of the Board of Park Commissioners of the Mattituck Park District in the Town of Southold, Suffolk County, New York, held at Mattituck, in said Town, on the 4th day of Aurust, 1980, at 7:30 o'clock P .M. , Prevailing Time. The meeting was called to order by Commissioner Francis J. Murphy and the roll being called, there were PRESENT:' Francis J. Murphy, Chairman Lawrence P. Reeve Gerard P. Goehringer ABSENT: The following resolution was offered by Commissioner Murphy who moved its adoption, seconded by Comaissioner Reeve to-wit: RESOLUTION DATED AUGUST 4, 1980 A RESOLUTION AUITORIZING THE ACQUISITION OF CERT M REAL PROPERTY IN AND FOR THE MATrITUCK PARK DISTRICT IN THE MM CF SOUTH=, Summ OOUNTY, NEW YORK, AT A M UGHM ESTI MATED COST, MIMING INCIDENTAL EX )MSES, of $22,000. BE IT RESOLVED, by tete Board of Park Commissioners of the Mattituck Park District in the Town of Southold, Suffolk County, New York, as follows: Section 1. Pursuant to the provisions of Section 3 of Chapter 924 of the Laws of 1941, as ameryded, the acquisition of the following described property for the Mattituck Park District in the Town of Southold, Suffolk County, New York, is hereby authorized at a maximum estimated cost, including expenses, of $22,000. Said property is bounded and described as follows: ALL that certain plot, piece or parcel of land, situAtte, lying and being in the Town of Southold, County of Suffolk and State of New York, more particularly bounded and described as follows: BEGINNIbG at a point on the easterly side of Aldrich Lane at the southwest corner of the hereindescribed premises where the same is intersected by the northerly side of land now cr formerly of Laurel Commn School District, said point or place of beginning being also distant the following 3 courses and distances as measured along the easterly side of Aldrich Lane from the corner formed by the intersection of the northerly side of Main Road with the easterly side of Aldrich Lane: (1) North 20 degrees 07 minutes 20 seconds West 354.20 feet; (2) North 21 degrees 22 minutes 50 seconds West 303.33 feet; (3) North 20 degrees 31 minutes 20 seconds West 54.89 feet to the true point or place of beginning; uming mance frau said true point or place of beginning along the easterly side of Aldrich Lane North 20 degrees 31 minutes 20 seconds West 452.87 feet; thence North 69 degrees 28 minutes 40 seconds East 578.10 feet; thence South 20 degrees 16 minutes 30 seconds East 452.87 feet to land now or formerly of Laurel Cannon School District, first above men- tioned; and thence along said last mentioned land, South 69 degrees 28 minutes 40 seconds West 576.14 feet to the easterly side of Aldrich Lane at the point or place of BEGINNIM. Section 2. The Town Board of the Town of Southold, Suffolk County, New York, is hereby requested to authorize the issuance of $15,000 serial bonds of said Town pursuant to the provisions of the Local Finance Law to pay part of the maximum estimated cost of such object or purpose. Section 3. A certified copy of this resolution shall be filed with the Tawn Board of said Town. Section 4. This resolution shall take effect im ediately. -T STATE OF NEW YORK ) ) ss. . COUNTY OF SUFFOLK ) I, the undersigned Secretary of the Board of Commissioners of Mattituck Park District, Suffolk County, New York, DO HEREBY CERTIFY: That I have compared the annexed extract of the minutes of the meeting of the members of said Board, including the resolution contained herein, held on the 4th day of August,1980, with the original thereof on file in my office, and that the same is a true and correct transcript therefrom and of the whole of said original so far as the same relates to the subject matters therein referred to. I FURTHER CERTIFY that all members of said Board had due notice of said meeting and that, pursuant to Section 99 of the Public Officers Law (Open Meetings Law) , said meeting was open to the general public and that I duly caused a public notice of the time and place of said meeting to be given to the following newspapers and/or other news media as follows: Newspapers and/or other news media Date given Suffolk Times, Inc. Thursday, July 31, 1980 and that I further duly caused public notice of the time and place of said meeting to be conspicuously posted in the following designated public location (s) on the following dates : Designated Location (s) of posted notice Date of Posting iHatttituck High School Main load, Mattituck, New York July 29, 1980 The North Fork Bank & Trust Cc). 245 Love Lane, Mattituck, New York July 29, 1980 IN WITNESS WHEREOF, I have hereunto set my hand this 4th day of ' August , 1980. District Se retary Madeline Haas STATE OF NEW YORK ) ) ss. . COUNTY OF SUFFOLK ) I, the undersigned Town Clerk of the Town of Southold, Suffolk County, New York, DO HEREBY CERTIFY: That I have compared the foregoing copy of the resolution of the Board of Park Commissioners of the Mattituck Park District dated August 4 , 1980, with the original thereof which was filed in my office on the day .of august, 1980, and that the same is a true and correct copy of said original and of the whole of said original so far as the same relates to the subject matters therein referred to. IN WITNESS WHEREOF, I have hereunto set my hand and affixed the seal of said Town this -1s) "J. day of �, 1980. Town Clerk (S E A L ) 815713 .302P At a regular meeting of the Town Board of the Town of Southold, Suffolk County, New York , held at Southold, New York , in said Town, on the 12th day of August, 1980 , at 7: 30 o'clock P.M. , Prevailing Time. The meeting was called to order by Supervisor Pell , and upon roll being called, the following were: PRESENT: Supervisor William R. Pell III Councilman Henry W. Drum Councilman John J. Nickles Councilman Lawrence Murdock, Jr. Councilman George R. Sullivan Town Clerk Judith T. Terry ABSENT: Justice Francis T. Doyen The following resolution was offered by Councilman Drum , who moved its adoption, seconded by Councilman Murdoclx to-wit: BOND RESOLUTION DATED AUuUST 12, 1980. A RESOLUTION AUTHORIZING THE ISSUANCE OF $15, 000 SERIAL BONDS OF THE TOWN OF SOUTHOLD, SUFFOLK COUNTY, NEW YORK, TO PAY PART OF THE COST OF THE ACQUISITION OF CERTAIN REAL PROPERTY IN AND FOR THE MATTITUCK PARK DISTRICT IN SAID TOWN. WHEREAS, the Board of Park Commissioners of the Mattituck Park District in the Town of Southold, Suffolk County, New York, duly adopted a resolution on 'the" ' 4th day of Aligust, 1980 , authorizing the acquisition of certain real property, as therein described, in and for said Park District, at a maximum estimated cost, including incidental expenses, of $22 , 000, which resolution requests this Town Board to authorize the issuance of $15, 000 serial bonds of said Town to pay part of said maximum estimated cost; NOW, THEREFORE BE IT RESOLVED, by the Town Board of the Town of Southold, Suffolk County, New York, as follows: Section 1. For the specific object or purpose of paying part of the cost of the acquisition of the real property referred to in the preambles hereof in and for the Mattituck Park District in the Town of Southold, Suffolk Countv, New York, there are hereby authorized to be issued $15 , 000 serial bonds of said Town pursuant to the Local Finance Law. Section '2. The maximum estimated cost of such specific object or purpose, including incidental expenses , is $22, 000 , and the plan for the financing of such maximum estimated cost consists of the issuance and sale of $15, 000 serial bonds of said Town herein authorized, and the appropria- tion and expenditure of $5 , 000 current funds of said Town heretofore authorized therefor. 2 tie • • Section 3. It is hereby determined that the period of probable usefulness -of such object or purpose, pursuant to subdivision 21 of paragraph a of Section 11. 00 of the Local Finance Law, is thirty years, and that the maximum maturity of the bonds herein authorized will exceed five years. Section 4. The faith and credit of the Town of Southold, Suffolk County, New York, are hereby irrevocably pledged for the payment of said bonds and the interest thereon. To pay said bonds and the interest thereon, there shall annually be levied and assessed against the taxable real property of said Park District, and collected in the same manner, at the same time, and by the same officers as the taxes of said Town are levied, assessed and collected, an amount sufficient to pay such principal and interest as the same respectively become due and payable, but if not paid from such source, all the taxable real property within the Town will be subject to the levy of ad valorem taxes to pay said bonds and interest thereon without limitation as to rate or amount. Section 5. Subject to the provisions of the Local Finance Law, the power to authorize the issuance of and to sell bond anticipation notes in anticipation of the issuance and sale of the serial bonds herein authorized, including renewals of such notes, is hereby delegated to the Supervisor, the chief fiscal officer. Such notes shall be of such terms, form and contents , and shall be sold in such manner, as may - 3 - be prescribed by said Supervisor, consistent with the provisions of the Local Finance Law. Section 6. The validity of such bonds and bond anticipation notes may be contested only if: 1) Such obligations are authorized for an object or purpose for which said Town of Southold is not authorized to expend money, or 2) The provisions of law which should be complied with at the date of publication of this resolution are not substantially complied with, and an action, suit or proceeding contesting such validity is commenced within twenty days after the date of such publication, or 3) Such obligations are authorized in violation of the provisions of the Constitution. Section 7 . This resolution, which takes effect immediately, shall be published in full in the Long Island Traveler - Mattituck Watchman, a newspaper published at Southold, Town of Southold, New York, and in the Suffolk / Times , published at Greenport, Town of Southold, New York, both papers having a general circulation within the Town of Southold , together with a notice of the Town Clerk in substantially the form provided in Section 81. 00 of the Local Finance Law. t - 4 - t STATE OF NEW YORK COUNTY OF SUFFOLK ss: This is to certify that I, Judith T. Terry, Clerk of the Town of Southold, in Office of the Clerk of the TOWN OF SOUTHOLD the said County of Suffolk, have compared the foregoing copy of resolution with the original resolution now on file in this office, and which was passed by the Town Board of the town of Southold in said County of Suffolk, on ( SEAL ) 12th Au ust 80 the ................ day of ..............�.................... 19........, and that the some is a correct and true transcript of such original resolution and the whole thereof. In Witness Whereof, I have hereunto set my hand and affixed the seal of said Town this ...13th... day of ..........August............... 19.80.. ..........rNy - Clerk of the Town Board, own�of Southold, County of Suffl The question of the adoption of the foregoing resolution was duly put to a vote on roll call, which resulted as follows: Supervisor William R. Pell, III VOTING aye Councilman Henry W. Drum VOTING aye Councilman John J. Nickles VOTING aye Councilman Lawrence Murdock,Jr. VOTING aye Councilman George R. Sullivan VOTING aye The resolution was thereupon declared duly adopted. STATE OF NEW YORK ) } ss. • COUNTY OF SUFFOLK ) I , the undersigned Clerk of the Town of Southold, Suffolk County, New York, DO HEREBY CERTIFY: That I have compared the annexed extract of the minutes of the meeting of the Town Board of said Town, including the resolution contained therein, held on the 12th day of August, 1980, with the orig-inal thereof on file in my office , and that the same is a true and correct transcript therefrom and of the whole of said original so far as the same relates to the subject matters therein referred to. I FURTHER CERTIFY that all members of said Board had due notice of said meeting , and that, pursuant to Section 99 of the Public Officers Law (Open Meetings Law) , said meeting was open to the general public, and that I duly caused a public notice of the time and place of said meeting to be given to the following newspapers and/or other news media as follows : Newspaper and/or other news media Date given The Suffolk Times August 5, 1980 The Long Island Traveler-Watchman, Inc. August 5, 1980 Newsday, Inc. August 5, 1980 and that I further duly caused public notice of the time and place of said meeting to be conspicuously posted in the following designated public location (s) on the following dates: Town Clerk Bulletin Board, Town Hall, Main Road, Southold, New York August 5, 1980-August 12, 1980 Designated Location(s) of posted notice Date of Posting Town Clerk's Bulletin Board August 5, 1980-August 12, 1980 Town Hall, Main Road Southold, New York 11971 IN WITNESS WHEREOF, I have hereunto set my hand and affixed the seal of said Town this 9th day of October, 1980. Town Clerk (CORPORATE Judith T. Terry SEAL) LEGAIA TICE, ` COUNTY OF SUFFOLK NOVICE ' >IS HEREBY STATE OF NEW YORK ss: GIVFN= 4a't the resolution publi 44fibipiVfthk,has been adopted'by the''1rovn Board of thq Town of,Southold, Suffolk 'County,New Vbik„on the 12th Patricia Wood, being duly sworn, says that she is the day of August, Y980, and the Editor, of THE LONG ISLAND TRAVELER-WATCHMAN, validity of the obligations authorized by such resolution a public newspaper printed at Southold, in Suffolk County; may be here !,contested only if such o' ons were and that the notice of which the annexed is a printed copy, authorized fo ;';. ::'object or purpose for wh :laid Town is hos been published in said Long Island Traveler-Watch- not authorized to expend man once each week for ........................................ weeks money, or if the, provisions of law which shed have been successively, commencing on the ... ................................. complied with as`of the date of ��,,1l publication of this notice were ............. .... .................... 19.x.`!.... not substantially complied with, and an action, suit or proceeding contesting such .. ....... ............................................................. ........ validity isy$coYm��.ymme,.n;�{cie��d�lwa`Li^tthin L�IC-3 1110 ��iLnu oy jf�e � same officers as the taxes of said Town are levied, assessed And collected, an amount Sworn to before me. this .. day of sufficient to pay such principal and interest as the same 19 respectively become due and """ ""'• payable, but if not paid from such source, all the taxable real property within the Town - will be subject to the levy of ad C valorem taxes to pay said 3 r bonds and interest thereon f Nota blit without limitation as to rate or S_ amount. Section 5. Subject to the �r i1j.4y'; nLa� uk,t��6 ,� and an acl.—, _- ;F; 0( proceeding contesting such ass lir idwcNilRu ii,>?I Pill validity is commenced within ane+a i1�Si,i7 ExV'W mw A ioq twenty days after the date of Z— Suc such publication, or 281 3) Such obligations are 3o authorized in violation of the provisions of the Constitution. 111 Section 7. This resolution, which takes effect immediate- ly,shall be published in full in 111A "the Long Island Traveler- sod Mattituck Watchman, a news- IM paper published at Southold, Town of Southold, New York, a8 and in 'the Suffolk Times, isu.1 published at Greenport, Town Gama of Southold, New York, both IgWa papers having a general sus circulation within the Town of Iuisq Southold, together with a ;usi. notice of the Town Clerk in Is AVI substantially the form pro- duisH vided in Section 81.00 of the Local Finance Law.8/21/80(19) ;uautsssjsq q;1en pa8isq?ssen s,', El -8utuap dspunS ialPW Pia E a iaarjo of a8sn8usi ae►sngs -q' sn pus asuao►l sill enogs ao3 9ulsn;as .to; palsaasa seen 43 us enam Jo'9£'3100, � $l_'1J Pasgol11 --- 7611 IlAAn T._.nI1IIi�tiinac q 81517. 302P BOND ANTICIPATION NOTE CERTIFICATE DATED NOVEMBER 6 , 1980. CERTIFICATE OF THE SUPERVISOR OF THE TOWN OF SOUTHOLD, SUFFOLK COUNTY, NEW YORK, AUTHORIZING THE ISSUANCE OF A $15, 000 BOND ANTICIPATION NOTE OF SAID TOWN TO PAY PART OF THE COST OF THE ACQUISITION OF CERTAIN REAL PROPERTY IN AND FOR THE MATTITUCK PARK DISTRICT IN SAID TOWN. I , the undersigned Supervisor of the Town of Southold, Suffolk County, New York, DO HEREBY CERTIFY: 1. Pursuant to a bond resolution dated August 12 , 1980 , duly adopted by the Town Board of said Town on said date, authorizing the issuance of $15 , 000 serial bonds of said Town to pay part of the cost of the acquisition of certain real property, as therein described , in and for said Park District in said Town, which is an assessable improvement, and delegating to me, as chief fiscal officer , power to authorize the issuance of and to sell bond anticipation notes, including renewals thereof, in anticipation of the issuance and sale of said bonds, which power is in full force and effect and has not been modified, amended or revoked, I HEREBY AUTHORIZE the issuance of a bond anticipation note of said Town in the principal amount of $15, 000 in anticipation of the sale of said bonds. Said note shall be dated November 6 , 1980 , shall be numbered 1, shall bear interest at the rate of six and forty-five hundredths per centum (6 .45$) per annum, payable at maturity, shall mature on November 5, 1981, with prepayment reserved, and both principal of and interest on said note shall be payable in lawful money of the -2- • United States of America at The Bank of New York, Valley-Long Island Region, in Greenport , New York. Such note is not a renewal note. 2 . The specific object or purpose for which said note is hereby authorized to be issued is to pay part of the cost of the aforesaid specific object or purpose. The amount of serial bonds to be issued therefor is $15,000. 3. No other bond anticipation notes are presently outstanding in anticipation of the sale of such bonds. 4 . Such note shall be executed in the name of said Town of Southold, Suffolk County, New York, by its Supervisor , sealed with its corporate seal, attested by its Town Clerk, and the same shall be in substantially the form attached hereto. Such note is hereby sold at private sale to The Bank of New York, Valley-Long Island Region, in Greenport, New York, at a price of not less than par and accrued interest, if any. To the best of my knowledge and belief, no officer or employee of said Town has an interest in the sale of said note prohibited by Article 18 of the General Municipal Law, as amended. Dated: Southold, New York, November 6 , 1980. cam; ,, Supervisor • -3- • An executed counterpart of the foregoing certificate, with form of note attached was filed with the Town Board of said Town of Southold, New York, this 6th day of November, 1980 . Town Clerk (CORPORATE SEAL) i i i ,i i i a _ UNITED' STATES OF AMERICA STATE OF NEW YORK • COUNTY OF SUFFOLK • TOWN OF SOUTHOLD BOND ANTICIPATION NOTE, 1980 No. 1 $15,000 The Town of Southold, in the County of Suffolk, a municipality of the . State of New York (herein called the "Obligor" ) , hereby acknowledges itself indebted and for value received promises to pay to the bearer of this note the sum of FIFTEEN THOUSAND DOLLARS ($15,000) on the 5th day of November , 1981, together with interest thereon from the date hereof at the rate of six and forty-five hundredths per centum (6.45%) per annum, payable at maturity. Both principal of and interest on this note will be paid in lawful money of the United States of America at The Bank of New York, Valley-Long Island Region, - in Greenport , New York. This note may be redeemed at any time prior to maturity by said Obligor, upon giving written notice to the holder, and interest shall cease as of the date fixed for redemption. This note may not be converted into registered form. This note is one of a total authorized issue of $15, 000 issued pursuant to proceedings duly adopted by the Finance Board of the Obligor, on August 12, 1980 , and also pursuant to: , "BOND ANTICIPATION NOTE CERTIFICATE DATED NOVEMBER 6 , 1980 . CERTIFICATE OF THE SUPERVISOR OF THE TOWN OF SOUTHOLD, SUFFOLK COUNTY, NEW YORK, AUTHORIZING THE ISSUANCE OF A $15,000 BOND ANTICIPATION NOTE OF SAID TOWN TO PAY PART OF THE COST OF THE ACQUISITION OF CERTAIN REAL PROPERTY IN AND FOR THE MATTITUCK PARK DISTSICT IN SAID TOWN. " The faith and credit of the Obligor are hereby irrevocably pledged for the punctual payment of the principal of and interest on this note according to its terms. It is certified and recited that all conditions, acts and things required by the Constitution and statutes of the State of New York to exist, to have happened and to have been performed precedent to and in the issuance of this note, exist, have happened and have been performed, and that this note, together with all other indebtedness of the Obligor is within every debt and other limit prescribed by the Constitution and laws of such State. IN WITNESS WHEREOF, the Obligor, in accordance with the proceedings authorizing this note, has caused this note- to be signed and its corporate seal to be hereunto affixed and attested as appears below, and this note to be dated as the 6th day of November, 1980 . TOWN OF SOUTHOLD, SUFFOLK COUNTY, NEW YORK (SEAL) ATTEST: By Town Clerk r i r CLOSING CERTIFICATE We, the undersigned do hereby certify: That we are the officers of the Town of Southold, Suffolk County, New York, (hereinafter called the "Obligor" ) indicated by the official title set opposite our respective signatures to this certificate. That we did officially execute a $15, 000 Bond Anticipation Note, 1980 , of said Obligor, dated November 6 , 1980 , numbered 1, of the denomination of $15 , 000 , bearing interest at the rate of (6 . 45$) per annum, payable at maturity and maturing November 5, 1981, with prepayment reserved. That no litigation of any nature is now pending or , to our knowledge, threatened (a) to restrain or enjoin the issuance or delivery of said obligations or the levy and collection of taxes or assessments to pay the same , (b) in any manner questioning or affecting , directly or indirectly, the validity of said obligations or the proceedings or authority for the issuance thereof, or (c) contesting the corporate existence or boundaries of the Obligor or the title of the undersigned officers to their respective offices; that no authority or proceedings for the issuance of said obligations has been repealed, revoked or rescinded , that the corporate seal of the Obligor, or a facsimile thereof, has been impressed or imprinted on all of said obligations; and that on the date of the execution of said obligations and on the date set forth below, we were and are the duly chosen, qualified and acting officers indicated therein and on this certificate and duly authorized to execute said obligations. That on the date of this certificate, said obligations were actually delivered to the purchaser thereof against receipt of the purchase price as follows : Official Check #VA 109991 of The Bank of New York in the sum of $15,000.00 dated November 6, 1980 to the order of Mattituck Park District. • -2- • Principal (par value) : $15,000 .00 Premium: $ -0- Accrued interest from date of said obligations to date of delivery : $ -0- TOTAL: $15,000 .00 WITNESS our official signatures the '6th day of November , 1980 , being the date of the actual delivery of said obligations, as aforesaid. Official Term of Office Signature Title Expires Supervisor bee.ems►k'/e �. , Town Clerk I hereby certify that the signatures of the officers above subscribed are true and genuine. (Name of Bank) SIGNATURE GUARANTEED 14ORTH FORK BANK AND TR661 "0. (Signature and Title By N.Y.Corr.Manufacturers Hanover . 81517. 302P Arbitrage Certificate $15 , 000 Bond Anticipation Note, 1980 The undersigned certified that he is the chief fiscal officer of the Town of Southold, Suffolk County, New York, (the "Issuer") and that, in his capacity as such, he, among others, is charged with the responsibility for issuing the above-mentioned obligation of the Issuer (the "Obligation" ) being issued on the date hereof, and further certifies as follows: 1. The facts and circumstances set forth below are in existence on the date hereof. The Issuer ' s expectations as to future events are also set forth below and include the expectation that the proceeds of the Obligation will not be used in a manner that would cause the Obligation to be an "arbitrage bond" within the meaning of Section 103 of the Internal Revenue Code of 1954 , as amended, (the "Code" ) and the applicable regulations promulgated by the Department of the Treasury thereunder. To the best of my knowledge and belief, the Issuer ' s expectations are reasonable. 2. $15,000 of the proceeds of the Obligation will be used to pay the cost' of the project set forth in the bond anticipation note certificate of the Supervisor , dated November E, 1980 , which is incorporated herein by reference. Such proceeds will be expended prior to November 6 , 1983 , and the issuer expects that binding contracts or commitments obligating the expenditure, for work on the • • -2- project, of not less than 2-1/2% of the cost of the project, have been or will be entered into prior to May 7 , 1981. After a contract or commitment has been entered into for the project, work thereon will proceed with due diligence to full completion. 3 . $15, 000 of the Obligation proceeds will be invested without restriction as to yield. 4 . Within one year of receipt all amounts earned from investment of proceeds of the Obligation will be expended to pay debt service on the Obligation or on obligations issued to refund the Obligation. 5. There is not expected to be any fund not described above that will (a) be needed to pay principal or interest on the Obligation, (b) replace funds that will be used to pay principal or interest on the Obligation, or (c) be pledged to secure the Obligation. 6. This arbitrage certificate describes the issuer ' s expectations with regard to all governmental obligations (a) issued at substantially the same time as the Obligation, (b) sold pursuant to a common plan of financing with the Obligation, and (c) to be paid out of substantially the same source of funds (or that will have substantially the same claim to be paid out of substantially the same source of funds) as will be used to pay the Obligation. 7 . The Issuer has not received notice that it,s certificate as to arbitrage may not be relied upon with respect to its issues, nor has it been advised that any such adverse action is contemplated by the Commissioner of Internal Revenue. To the best of my knowledge and belief , there are no other t r • facts, estimates or circumstances that would change the foregoing matters. IN WITNESS WHEREOF, I have hereunto set my hand this 6th day of November , 1980 . Supervisor THE BANK OF NEW YORK NEW YORK'S FIRST BANK-FOUNDED 1784 BY ALEXANDER HAMILTON 238 MAIN STREET, GREENPORT,N.Y. 11944 VALLEY-LONG ISLAND REGION October 30y 1980 Abigail A, Wickham Attorney at Law Main Road Poo, Box 1+24 Mattituck, New York 11952 Re: MATTITUCK PARK DISTRICT t 159000 - B/ALN Dear Gail:- On behalf of The Bank of New York, I would like to offer a bid of 6.45 % on the above Note. I would appreciate your response as to tha results of the bidding, when convenient, for our records, Very truly yours, WJK:mw3 WALTER J. PSKI, J R, Assistant Treasurer X77-/7�� VA 109991 . OFFICIAL. ITHE : 0 0 = , i CHECK NEW YORK.DT Y_ NOVeMber 6. 1980 1-1' - - - 5 - "� 210 �: ;� $15,000.00PaY 11 �� 8 ,15 - Fox: One. Year B/A/a _ � C A; - - - - TO THE MA.TTITUCK PARK DISTRICT""� - n a7 -of - IZED IGNAT E / w. u' &0999 Lu'- 1:0 2 LO-000 LI: 99 5 2900 P WI LLKI E FARR 8, GALLAGHER ONE CITICORP CENTER ROBERT S.AMDURSKY PETER H.JAKES 153 EAST 53RD STREET ETHAN ALLEN KENNETH J.SIALKIN PETER J.KENNY WALSTON S.BROWN JOSEPHL.BROADWIN ROBERT J.KHEEL NEW YORK N. Y 10022 JAMES S.BROWN,JR. CHARLES I.KINGSON WALTER H.BROWN,JR. THOMAS L.BRYAN ARTHUR D.KOWALOFF HAROLD J. GALLAGHER HOWARD C.BUSCHMAN III JAY F.LEARY MARK F. HUGHES DALE S.COLLINSON IRA H.LUSTGARTEN (212) 935-8000 ALLAN F.CONWILL MICHAEL G.MARKS HELMER R.JOHNSON PHILIP D.CORSI ROBERT W.MARSHLOW SIDNEY L.SMITH LOUIS A.CRACO RAYMOND W.MERRITT JOHN S.D'ALIMONTE THOMAS S.MONFRIED CHARLES S.SYKES ROSWELL C.DIKEMAN JACK H.NUSBAUM THOMAS N.TARLEAU JAMES N.EDGAR BRIAN M.O'BRIEN .. COUNSEL THORNTON G.EDWARDS ANTHONY F. PHILLIPS _ DWIGHT W.ELLIS]I[ DAVID B. F. STEPHEN S.FLOOD THOMAS M.ROTHMAN p CABLE"CONVEYANCE NEW YORK" DAVID L.FOSTER PATRICIA S.SKIGEN November 14, 1980 TELEX:233780 (RCA) ALEXANDER T.GALLOWAY U HARVEY L.SPERRY WILLIAM J.GRANT,JR. DUNCAN J.STEWART 12-7679(WU) STEPHEN W.GREINER CHESTER J.STRAUB - ROBERT B.HODES WILLIAM T.SULLIVAN LOUIS L.HOYNES,JR. C.SCOTT SYKES,JR. EUROPEAN OFFICE RANDALL A.HUFFMAN ALLAN TRUMBULL 16,AVENUE PIERRE IC-..SERBIE 75116 PARIS,FRANCE TELEPHONE 723•5156 Town of Southold, CABLE"CONVEYANCE PARIS" TELEX:842-620080 County of Suffolk, State of New York Town of Southold, Suffolk County, New York $15,000 Bond Anticipation Note, 1980 Dear Sirs: We have been requested to render our opinion as to the validity of a $15,000 Bond Anticipation Note, 1980 (the "Note") , of the Town of Southold, County of Suffolk, New York_ (the "Issuer") , dated November 6, 1980 , numbered 1, of the denomination of $15 ,000, bearing interest at the rate of 6. 45% per annum, payable at maturity, and maturing November 5 , 1981, with prepayment reserved. We have examined the Constitution and statutes of the State of New York and the Internal Revenue Code of 1954 , as amended, including particularly Section 103 thereof , and the regulations of the United States Treasury Department thereunder. We have also examined a certified copy of proceedings of the finance board of the Issuer and other proofs authorizing and relating to the issuance of the Note, including the form of the Note. In rendering the opinions expressed herein we have assumed the accuracy and truthfulness of all public records, documents and proceedings examined by us which have been executed or certified by public officials acting within the scope of their official capacities, and have not verified the accuracy or truthfulness thereof. We also have assumed the genuineness of the signatures appearing upon such public records , documents and proceedings and the certifications thereof. In our opinion: (a) The Note has been authorized and issued in accordance with the Constitution and statutes of the State of New York and . • Town of Southold • -2- *d'ovember 14 , 1980 constitutes a valid and legally binding general obligation of the Issuer , all the taxable real property within which is subject to the levy of ad valorem taxes to pay the Note and interest thereon, without limitation as to rate or amount; provided, however , that the enforceability (but not the validity) of the Note may be limited by any applicable bankruptcy, insolvency or other law now existing or hereafter enacted by said State or the Federal government affecting the enforcement of creditors' rights; and (b) The Note is not an "arbitrage bond" and interest on the Note is exempt under existing statutes and court decisions from Federal income taxes, from New York State income taxes, and from the New York City "personal income tax on residents" and "earnings tax on nonresidents" . The scope of our engagement in relation to the issuance of the Note has extended solely to the examination of the facts and law incident to rendering the opinions expressed herein. Such opinions are not intended and should not be construed to express or imply any conclusion that the amount of real property subject to taxation within the boundaries of the Issuer , together with other legally available sources of revenue, if any, will be sufficient to enable the Issuer to pay the principal of or interest on the Note as the same respectively become due and payable. We have not examined, reviewed or passed upon the accuracy, completeness or fairness of any factual information which may have been furnished to any purchaser of the Note by or on behalf of the Issuer and, accordingly, we express no opinion as to whether the Issuer, in connection with the sale of the Note, has made any untrue statement of a material fact or omitted to state a material fact necessary in order to make any statements made, in the light of the circumstances under which they were made, not misleading. Very truly yours, dpc � q V � 81517. 302P BOND ANTICIPATION RENEWAL NOTE CERTIFICATE DATED NOVEMBER 5, 1981. CERTIFICATE OF THE SUPERVISOR OF THE TOWN OF SOUTHOLD, SUFFOLK COUNTY, NEW YORK, AUTHORIZING THE ISSUANCE OF A $15,000 BOND ANTICIPATION RENEWAL NOTE OF SAID TOWN TO PAY PART OF THE COST OF THE ACQUISITION OF CERTAIN REAL PROPERTY IN AND FOR THE MATTITUCK PARK DISTRICT IN SAID TOWN. I, the undersigned Supervisor of the Town of Southold, Suffolk County , New York, DO HEREBY CERTIFY: i 1. Pursuant to a bond resolution dated August 12, 1980, duly adopted by the Town Board of said Town on said date, authorizing the issuance of $15, 000 serial bonds of said Town to pay part of the cost of the acquisition of certain real property , as therein described, in and for said Park District in said Town, which is an assessable improvement, and delegating to me, as chief fiscal officer, power to authorize the issuance of and to sell bond = anticipation notes, including renewals thereof , in anticipation of the issuance and sale of said bonds, which power is in full force and effect and has not been modified, amended or revoked, I HEREBY AUTHORIZE the issuance of a bond anticipation renewal note of said Town in the principal amount of $15, 000 in anticipation of the sale of said bonds. Said renewal note shall be dated November 5, 1981, shall be numbered 1-R, shall be of the denomination of $15,000, a -2- i shall bear interest at the rate of Ten and one-quarter per centum (10-1/4 %) per annum, payable at maturity, shall mature on November 4, 1982, with prepayment reserved, and both principal of and interest on said note shall be payable in lawful money of the United States of America at The North Fork Bank & Trust Company , in Mattituck , New York. Such note is a renewal note. 2. The specific object or purpose for which said note is hereby authorized to be issued is to pay part of the cost of the aforesaid specific object or purpose. The amount of serial bonds now remaining to be issued therefor is $15,000. 3. The note herein authorized is issued for the purpose of renewing the outstanding $15,000 Bond Anticipation Nate, 1980, of said Town, dated November 6, 1980, numbered 1, and maturing November 5, 1981, which is the only bond anticipation note presently outstanding in anticipation of the sale of said bonds. The date of the first bond anticipation note issued in anticipation of the sale of said bonds was November 6, 1980. 4. Such renewal note shall be executed in the name of said Town of Southold, Suffolk County , New York, by its Supervisor, sealed with its corporate seal, attested by its Town Clerk, and the same shall be in substantially the form attached hereto. Such note is hereby sold at private sale to The North Fork Bank & Trust Company in Mattituck , New York, at a price of not less than par and accrued interest, if any. To the best of my knowledge and belief, no officer or employee of said Town has an interest in the sale of said note prohibited by Article 18 of the General Municipal Law, as- .amended. 4 ~ -3- . Dated: Southold, New York November 5, 1981. Supervisor - William R. Pell, III An executed counterpart of the foregoing certificate, with form of note attached, was filed with the Town Board of said Town of Southold, this 5th day of November, 1981. Town Clerk - Judith Teay CORPORATE SEAL UNITED STATES OF AMERICA STATE OF NEW YORK .COUNTY OF SUFFOLK S TOWN OF SOUTHOLD I� BOND ANTICIPATION NOTE, 1981 (RENEWAL) f No. 1-R $15,000 The Town of Southold, in the County of Suffolk, a t municipality of the State of New York (herein called the "Obligor" ) , hereby acknowledges itself indebted and for value received promises to pay to the bearer of this note the sum of FIFTEEN THOUSAND DOLLARS ($15, 000) on the 4th day of November, 1982, together with interest thereon from the date hereof at the rate of Ten per centum ( 10-1/4%) per annum, payabie at maturity . Both principal of and interest on this note will be paid in lawful money of the United States of America at The North Fork Bank & Trust Company in Mattituck , New York. This note may be redeemed at any time prior to maturity by said Obligor upon giving written notice to the holder and interest shall cease as of the date fixed for redemption. This note may not be converted into registered form. This note is one of a total authorized issue -of $15,000 issued pursuant to proceedings duly adopted by the Finance Board of the Obligor, on August 12, 1980, and also pursuant to: "BOND ANTICIPATION RENEWAL NOTE CERTIFICATE DATED NOVEMBER 5, 1981. CERTIFICATE OF THE SUPERVISOR OF THE TOWN OF SOUTHOLD, SUFFOLK COUNTY, NEW YORK, AUTHORIZING THE ISSUANCE OF A $15, 000 BOND ANTICIPATION RENEWAL NOTE OF SAID TOWN TO PAY PART OF THE COST OF THE ACQUISITION OF CERTAIN REAL PROPERTY IN AND FOR THE MATTITUCK PARK DISTRICT IN SAID TOWN. " The faith and credit of the Obligor are hereby irrevocably pledged for the punctual payment of the principal of and interest on this note according to its terms. It is certified and recited that all conditions, acts and things required by the Constitution and statutes of the State of New York to exist, to have happened and to have been performed precedent to and in the issuance of this note, exist, have happened and have been performed, and that this note, together with all other indebtedness of the Obligor is within every debt and other limit prescribed by the Constitution and laws of such State. IN WITNESS WHEREOF, the Obligor, in accordance with the proceedings authorizing this note, has caused this note to be signed and its corporate seal to be hereunto affixed and attested as appears below, and this note to be dated as the 5th day of November, 1981. TOWN OF SOUTHOLD, . SUFFOLK COU YORK (SEAL) ATTEST: , ] B Town Clerk - Judith Terry Supervisor - William R. Pell, III CLOSING CERTIFICATE We, the undersigned do hereby certify : That we are the officers of the Town of Southold, Suffolk County, New York, (hereinafter called the "Obligor") indicated by the official title set opposite our respective signatures to this certificate. That we did officially execute a $15, 000 Bond Anticipation Note, 1981 (Renewal) , of said Obligor , dated November 5, 1981, numbered 1-R, of the denomination of $15, 000, bearing interest at the rate of 10-1/4 % per annum, payable at maturity and maturing November 4, 1982;with prepayment reserved. That no litigation of any nature is now pending or, to our knowledge, threatened (a) to restrain or enjoin the issuance or delivery of said obligations or the levy and collection of taxes or assessments to pay the same, (b) in any manner questioning or affecting, directly or indirectly, the validity of said obligations or the proceedings or authority for the issuance thereof, or (c) contesting the corporate existence or boundaries of the Obligor or the title of the undersigned officers to their respective offices; that no authority or proceedings for the issuance of said obligations has been repealed, revoked or rescinded, that the corporate seal of . the Obligor, or a facsimile thereof, has been impressed or imprinted on all of said obligations; and that on the date of the execution of said obligations and on the date set forth below, we were and are the duly chosen, qualified and acting officers indicated therein and on this certificate and duly authorized to execute said obligations. That on the date of this certificate, said obligations were actually delivered to the purchaser thereof against receipt of the purchase-price as follows: Principal (par value) : $15,000.00 t Premium: $ -0- ! Accrued interest from date of said obligations to date of delivery : $ -0- TOTAL: $15,000. 00 WITNESS our official signatures the 5th day of November, 1981, being the date of the actual delivery of said obligations, as aforesaid. Official Term of Office Signature Title Expires Supervisor Town Clerk I hereby certify that the signatures of the officers above subscribed are true and genuine. tu WI '. BAJVa IV TRUST CO. ( P and- Title) N.Y.Corr. Manufacturers Hanover 81517. 302P Arbitrage Certificate $15,000 Bond Anticipation Note, 1981 (Renewal) I certify that I am the Supervisor of the Town of Southold, Suffolk County , New York (the "Issuer") ; that as such officer I am responsible, with others, for issuing the above-mentioned Note of . the Issuer; and that: 1. Set forth below are the Issuer' s expectations on the date of issue of the Note regarding the amount and use of the proceeds of the Note and the facts and estimates on which they are based. To the best of my knowledge and belief, the Issuer ' s expectations are reasonable. Based on these expectations, the proceeds of the Note will not be used in a manner that would cause them to be an "arbitrage bond" under Section 103 (c) of the Internal Revenue Code of 1954, as amended (the "Code") and the Treasury Regulations thereunder (the "Regulations") . 2. $15,000 of the proceeds of the Note will be used to redeem, at its maturity, the Issuer ' s outstanding bond anticipation note j (the "Prior Issue") which were issued to finance, or to refund obligations issued to finance, the project set forth in the bond anticipation note certificate of the Supervisor , dated November 5, 1981, which is incorporated herein by reference. Such project is hereinafter referred to as the "Refunded Project" . -2- 3. All of such $15, 000 proceeds will be expended to discharge the Prior Issues on or prior to November 5, 1981 and until that time will not be invested. } 4. All proceeds of all obligations originally issued to finance the "Refunded Project" and directly or indirectly refunded by the Note, have been or will be expended within three years of their respective date of issue. Such expenditures have been or will be recorded in the Issuer ' s financial records. 1 5. Within one year of receipt all amounts earned from investment of proceeds of the Note will be expended to pay debt service on the Note or on obligations issued to refund the Note. 6. There is not expected to be any fund not described above that will (a) be needed to pay principal or interest on the Note, (b) replace funds that will be used to pay principal or interest on the Note, or (c) be pledged to secure the Note. 7. This arbitrage certificate describes the issuer ' s expectations with regard to all governmental obligations (a) issued at substantially the same time as the Note, (b) sold pursuant to a common plan of financing with the Note, and (c) to be paid out of substantially the same source of funds (or that will have substantially the same claim to be paid out of substantially the same source of funds) as will be used to pay the Note. 8. The Issuer has not received notice that its certificate as to arbitrage may not be relied upon with respect to its issues, nor has it been advised that - any such adverse action is contemplated by the Commissioner of Internal Revenue. -3 v To the best of my knowledge and belief, there are no other i facts, estimates or circumstances that would change the foregoing I matters. IN WITNESS WHEREOF, I have hereunto set my hand this 5th day of November, 1981. Supervisor - Willem R. poll, III i LAW OFFICES WICKHAM, WICKHAM & BRESSLER, P.c. MAIN ROAD, P.O. BOX 1424 MATTITUCK LONG ISLAND NEW YORK 11952 WILLIAM WICKHAM ERIC J. BRES5LER 516-298-8353 ABIGAIL A.WICKHAM ALIX T.EHLERS November 5, 1981 Mrs. Judith Terry, Town Clerk Town of Southold Main Road Southold, New York 11971 Re: $15,000 Bond Anticipation Note 1981 - Renewal Mattituck Park District Dear Mrs. Terry: This is to confirm the execution by Supervisor Pell and you of the following documents, and of your retention of executed copies of those documents today: 1) Bond Anticipation Renewal Note - the original will be forwarded to North Fork Bank & Trust Co. , a copy of the executed note was retained by you. 2) Bond Anticipation Renewal Note Certificate of the Supervisor, with form of note attached. 3) Closing Certificate. 4) Arbitrage Certificate. We are forwarding executed counterparts of the above Bond Anticipation Renewal Note Certificate, Closing Certificate and Arbitrage Certificate to our New York Bond Counsel and will forward an approving opinion from them upon receipt. This is also to confirm that the Mattituck Park District forwarded its check to the Town of Southold today in payment of the 1980 Bond Anticipation Note in the amount of $15,000.00 to Bank of New York, together with interest. I understand that the Town of Southold then forwarded its check in payment of the principal and interest to the Bank of New York. This is also to confirm that the Mattituck Park District, in its budget for 1982, included items for the payment of interest on the Bond Anticipation Renewal Note and for the payment of a $5,000.00 reduction in 1982. Cont'd. . . . . . . . . . . . . . . . . . . Mrs. Judith Terry, Town Clerk Re: Mattituck Park District November 5, 1981 Page #2 If there is any additional information which you require, please feel free to contact me. Sincerely yours, Abigail A. Wickham AAW:ab / cc: Willkie Farr & Gallagher is Frank Murphy, Park Commissioner Robert Tasker, Esq. WI LLKI E FARR & GALLAGHER ONE CITICORP CENTER ROBERT S.AMDURSKY** PETER H.JAKES 153 EAST 53RD STREET ETHAN ALLEN ARMANDO T.BELLY PETER J.KENNY WALSTON S.BROWN KENNETH J.BIALKIN ROBERT J.KHEEL JOSEPH L.BROADWIN CHARLES I.KINGSON NEW/ YORK, N. Y. 10022 WALTER H.BROWN,JR. JAMES S.BROWN,JR. ARTHUR O.KOWALOFF HAROLD J.GALLAGHER THOMAS L.BRYAN JAY F.LEARY MARK F.HUGHES HOWARD C.BUSCHMAN III BURTON M.LEIBERT** (212) 935-8000 SIDNEY L.SMITH DALE S.COLLINSON IRA H.LUSTGARTEN COUNSEL ALLAN F.CONWILL MICHAEL G.MARKS PHILIP D.CORSI RAYMOND W.MERRITT LOUIS A.CRACO THOMAS S.MONFRIED CABLE"CONVEYANCE NEW YORK" JOHN S.D'ALIM O NTE JACK H.NUSBAUM TELEX:233780(RCA) STEPHEN I.DANZANSKY* BRIAN M.O'BRIEN 12-7879(WU) ROSWELL C.DIKE MAN** ANTHONY F.PHILLIPS - 1 JAM ES N.EDGAR DAVID B.REA 818 CONNECTICUT AVENUE,N.W. THORNTON G.EDWARDS ROBERT F.ROLNICK* DWIGHT W.ELLIB III THOMAS M.ROTHMAN WASHINGTON,D.C.20006 CORNELI US T.FINNEGAN III DAVID H.SCHWARTZ** TELEPHONE:(202) 328-8000 STEPHEN B.FLOOD PATRICIA S.SKIGEN - DAVID L.FOSTER HARVEY L.SPERRY 16,AVENUE PIERRE I--OE SERBIE ALEXANDER T.GALLOWAY 11 OUNCAN J.STEWART 75116 PARIS,FRANCE WILLIAM J.GRANT,JR. CHESTER J.STRAUB STEPHEN W.GREINER WILLIAM T.SULLIVAN p TELEPHONE:PARIS 723-5156 ROBERT B.HODES C.SCOTT SYKES,JR. November r 17, 19 81 CABLE"CONVEYANCE PARIS" LOUIS L.HOYNES,JR. ALLAN TRUMBULL TELEX:842-620080 RANDALLA.HUFFMAN *MEMBER OF DISTRICT Of COLUMBIA BAR *-MEMBER OF NEW YORK AND D.C.BARS OTHERS ADMITTED IN NEW YORK Town of Southold County of Suffolk State of New York Town of Southold, Suffolk County , New York $15, 000 Bond Anticipation Note , 1981 (Renewal) Dear Sirs: We have been requested to render our opinion as to the validity of a $15 , 000 Bond Anticipation Note, 1981 (Renewal) (the "Note" ) , of the Town of Southold, County of Suffolk, New York (the "Issuer" ) , dated November 5, 1981, of the denomination of $15,000, numbered 1-R, bearing interest at the rate of 10-1/4% per annum, payable at maturity , and maturing November 4, 1982, with prepayment reserved. We have examined the Constitution and statutes of the State of New York and the Internal Revenue Code of 1954 , as amended, including particularly Section 103 thereof, and the regulations of the United States Treasury Department thereunder. We have also examined a certified copy of proceedings of the finance board of the Issuer and other proofs authorizing and relating to the issuance of the Note, including the form of the Note. In rendering the opinions expressed herein we have assumed the accuracy and truthfulness of all public records, documents and proceedings examined by us which have been executed or certified by public officials acting within the scope of their official capacities, and have not verified the accuracy or truthfulness thereof. We also have assumed the genuineness of the signatures appearing upon such public records, documents and proceedings and the certifications thereof . In our opinion: Town of Southold -2- November 17, 1981 (a) The Note has been authorized and issued in accordance with the Constitution and statutes of the State of New York and constitutes a valid and legally binding general obligation of the Issuer, all the taxable real property within which is subject to the levy of ad valorem taxes to pay the Note and interest thereon, without limitation as to rate or amount; provided, however , that the enforceability (but not the validity) of the Note may be limited by any applicable bankruptcy , insolvency or other law now existing or hereafter enacted by said State or the Federal government affecting the enforcement of creditors ' rights; and (b) The Note is not an "arbitrage bond" and interest on the Note is exempt under existing statutes and court decisions from Federal income taxes, from New York State income taxes, and from the New York City "personal income tax on residents" and "earnings tax on nonresidents" . The scope of our engagement in relation to the issuance of the Note has extended solely to the examination of the facts and law incident to rendering the opinions expressed herein. Such opinions are not intended and should not be construed to express or imply any conclusion that the amount of real property subject to taxation within the boundaries of the Issuer , together with other legally available sources of revenue, if any, will be sufficient to enable the Issuer to pay the principal of or interest on the Note as the same respectively become due and payable. We have not examined, reviewed or passed upon the accuracy, completeness or fairness of any factual information which may have been furnished to any purchaser of the Note by or on behalf of the Issuer and, accordingly , we express no opinion as to whether the Issuer, in connection with the sale of the Note, has made any untrue statement of a material fact or omitted to state a material fact necessary in order to make any statements made, in the light of the circumstances under which they were made, not misleading . Very truly yours, dpc a9,l� 81517.3O2P POND ANTICIPATION RENEWAL NOTE CERTIFICATE DATED NOVEMBER 4 , 1982. CERTIFICATE OF THE SUPERVISOR OF THE TOWN OF SOUTHOLD, SUFFOLK COUNTY, NEW YORK , AUTHORIZING TETE ISSUANCE OF A $10 ,000 BCND ANTICIPATION RENE-WAL NOTE OF SAID TOWN TO PAY FART OF THE COST OF THE ACQUISITION OF CERTAIN REAL rROPERTY IN AND FOR THE MATTITUCK PARK DISTRICT IN SAID TOWN. I , the urdersigned Supervisor of the Town of Southold, Suffolk County, New Ycrk, LO HEREBY CERTIFY: 1 . Pursuant tc a bond resolution dated August 12, 1980, duly adcpted by the Town Board of said Town on said date, authorizing the issuance of 515 ,000 serial bonds of said Town to pay part of the cost of the acquisition of certain real property, as therein described , in and for said Park District in said Town , which is an assessable imrrcvement, and delegating to me, as chief fiscal officer , power to authorize the issuance of and to sell bond anticipaticn notes, including renewals thereof, in anticipation of the issuance and sale of said bonds, which pcwer is in full force and effect ar.d has not been modified , amended or revoked, I HEREBY AUTHORIZE the issuance of a bond anticipation renewal note of said Town in the Principal amount of $10 ,000 in anticipation of the sale of said bonds. Said renewal note shall be dated November 4, 1982, shall be numbered 2-R , shall be of the denomination of $10,000, It t 0 -2- 0 shall tear interest at the rate of __Seven and 00 _____ hundredths per centum (_� �) per annum, payable at maturity, shall mature on Novenber 4, 1583 , With prepayment reserved and both principal of and interest on said note shall be payable in lawful money of the United States of America at The North Fork Bank & Trust Company , in Mattituck, New York. Such note is a renewal note. 2 . The specific object or purpose for which said note is hereby authorized tc to issued is to pay part of the cost of the aforesaid specific object or purpose. The amount of serial bonds now remaining -to be issued therefor is $10,000. 3 . The note herein authorized is issued for the purpose of renewing in part the outstanding $15,000 Bond Anticipation Note, 1981 (Renewal ) , of said Town, dated November 5, 1981, numbered 1-R, and maturing November 4, 1982 , which is the only bond anticipation note presently outstanding in anticipation of the sale of said bonds . The balance of said outstanding note in the amount of .$5 ,000, will be paid from available current funds appropriated therefor, and shall constitute the second installment of the principal arcunt of such indebtedness. The date of the first bond anticipation note issued in anticipation of the sale of said bonds was November 6 , 1980. 4 . Such renewal note shill be executed in the name of said Town of Southold , Suffolk County, New York, by its Supervisor, sealed with its corporate seal, attested by its Town Clerk, and the same shall - be in substantially the form attached hereto. Such note is hereby sold at private sale to The North Fork Bank S Trust Company, x t ! -3- • in Mattituck , New York, at a price of not less than par and accrued interest, if any. To the best of my knowledge and belief , nc cfficer or earlcyee of said Town has an interest in the sale of said note prohibited by Article 18 of the General Municipal Law, as amended . rated : Scuthcld , New York Ncvemrer 4, 1982. Supervisor An executed counterpart of the foregoing certificate, with form cf ncte attached, was filed with the Town Board of said Town of Southold on hcvember 4 , 1982 . Town Clerk CORPCRATF SEAI UNITED STATES OF AMERICA STATE OF NEW YORK • COUNTY OF SUFFOLK TOWN OF SOUTHOLD POND ANTICIPATION NOTE, 1982 (RENEWAL) No . 2-R $10,000 The Tcwn of Southold , in the County of Suffolk, a municipality of the State of New York (herein called the "Otligor") , hereby acknowledges itself indebted and for value received promises to pay to the bearer of this note the sum of TEN THOUSAND DOLLARS ($10,000) on November 4, 1983, together with interest thereon from the ' date hereof at the rate Cf Seven and 00 hundredths per centum (__2. ) per annum , payable at maturity. Both principal of and interest on this note will be paid in lawful money of the United States of America at The North Fork Bank & Trust Company, in Mattituck , New York . This note say be redeemed at any time prior to maturity by said Obligor upon giving written notice to the holder and interest shall cease as of the date fixed for redemption. This note may not be converted into registered form. This note is one of a total authorized issue of $10,000 issued pursuant to proceedings duly adopted by the Finance Board cf the Obligcr , en August 12, 1980 , and also pursuant to: "BOND ANTICIPATICN RENEWAL NOTE CERTIFICATE DATED NOVEMBER 4, 1982. CERTIFICATE CF THE SUPERVISOR OF THE TOWN OF SOUTHOLD, SUFFOLK COUNTY, NEW YORK, AUTHORIZING THE ISSUANCE OF A $10,000 BOND ANTICIPATICN RENEWAL NOTE OF SAID TOWN TO PAY PART OF THE COST OF THE ACQUISITICN OF CERTAIN REAL PRCPERTY IN AND FOR THE MATTITUCK PARK DISTRICT IK SAID TOWN . " The faith and credit of the Obligor are hereby irrevocably pledged fcr the punctual payment of the principal of and interest cn this note according to its terms . It is certified and recited that all conditions, acts and things required by the Constitution and statutes of the State of New York to exist, to have happened and to have been performed precedent tc and in the issuance of this note, exist, have happened and have been performed, and that this note, together with all other indebtedness of the Obligor is within every debt and other limit prescribed by the Constitution and laws of such State . IN WITNESS WHEREOF, the Obligor , in accordance with the proceedings authorizing this note, has caused this note to be signed and its corporate seal to be hereunto affixed and attested as appears below , and this note to be dated as of November 4 , 1982. TOWN OF SOUTHOLD, SUFFOLK COUNTY, NEW YORK (SEAL ) ATTEST : _. Lj --- -- ---------- By ---------------------- Clerk Supervisor CLOSING CERTIFICATE We, the undersigned do hereby certify : That we are the officers of the Tcwn of Southold, Suffolk County, New Ycrk , (hereinafter called the "Obligor") indicated by the official title set opposite our respective signatures to this certificate . That we did officially execute a $10,000 Bond Anticipation Note, 1982 (Renewal ) , of said Obligor, dated November 4, 1982, numbered 2-R , of the denomination of $10 ,000, bearing interest at the rate cf 7 R Fer annum, payable at maturity and maturing November 4, 1983 , with prerayment reserved. That no litigation of any nature is new pending or, to our knowledge, threatened (a) to restrain or enjoin the issuance cr delivery of said obligations or the levy and collection of taxes or assessments tc pay the same, (b) in any manner questioning or affecting, directly or indi-rectly, the validity of said obligations cr the proceedings or authority for the issuance thereof , or (c) contesting the corporate existence or boundaries of the Obligor or the title cf the undersigned officers to their respective offices; that nc authority or proceedings for the issuance of said obligations has been repealed, revoked or rescinded , that the corporate seal of the Obligor, or a facsimile thereof, has been impressed or imprinted on all of said obligations; and that on the date of the execution of said obligations and on the date set forth below , we were and are the duly chosen, qualified and acting officers indicated therein and on this certificate and duly authcr12ed tc execute said obligations. That cn the date of this certificate, said obligations were actually delivered to the purchaser thereof against receipt of the purchase price as follows: _2- Principal (par value) : $10,000.00 zremium : $ -0- Accrued interest from date of said cbligaticns to date of delivery : $ -0- TOTAL: 0-TOTAL: $10,000.00 NITNESS cur cfficial signatures on November 4, 1982, being the date of the actual delivery of said obligations, as aforesaid. Official Term of Office �3gnaare Title Egpires__ Supervisor Town Clerk I hereby certify that the signatures of the officers above subscrired are true and genuine . IRS. C�U;,u 2L?W v i.LI'���yy t1T B1'�► _ � a frg lQ• l�fr£�°L iMM � ti 1 e)- 81517.302P Arbitrage Certificate $1C ,000 Bond Anticipation Note, 1982 (Renewal) I certify that I am the Supervisor of the Town of Southold, Suffclk County, Nen York (the "Issuer") ; that as such officer I am responsible, with others, for issuing the above-mentioned Note of the Issuer; and that: 1 . Set forth below are the Issuer 's expectations on the date of issue of the Ncte regarding the amount and use of the proceeds of the Note and the facts and estimates on which they are based. To the rest of my knowledge and belief, the Issuer 's expectations are reascnahle. Eased on these expectations, the proceeds of the Note will not be used in a manner that would cause them to be an "arbitrage bond" under Section 103 (c ) of the Internal Revenue Code cf 1954 , as amended ( the "Code") and the Treasury Regulations thereunder (the "Regulations" ) . 2 . $10,C00 cf the proceeds of the Note will be used to redeem, at its maturity, the Issuer 's outstanding bond anticipation rote (the "Prior Issue") which were issued to finance, or to refund obligations issued to finance, the project set forth in the bond anticipation note certificate of the Supervisor , dated November 4, 1982 , which is incorporated herein by reference. Such project is hereinafter referred to as the "Refunded Project". • -2- • 3 . All cf such $10,000 proceeds will be expended to discharge the Prior Issues cn or prior to November 4, 1982 and until that time will not be invested. 4 . All proceeds of all obligaticns originally issued to finance the "Refunded Frcject" and directly or indirectly refunded by the Note , have been or will be expended within three years of their respective date of issue. Such expenditures have been or will be recorded in the Issuer's financial records. 5 . Within one year of receipt all amounts earned from investment cf proceeds of the Note will be expended to pay debt service cn the Ncte or on obligations issued to refund the Note. 60 It is reasonably expected that all payments of principal or interest on the Note (other than those described in paragraph 5 and other than those made from refunding obligations) shall be made from the current annual revenues of the Issuer. 7 . The Issuer has not received notice that its certificate as to arbitrage may not be relied upon with respect to its issues, nor has it been advised that any such adverse action is contemplated by the Commissioner of Internal Revenue . F . There is not expected to be any fund not described above that will (a ) be needed to pay principal or interest on the Note, (b ) replace funds that will be used to pay principal or interest on the Note, or (c) be pledged to secure the Note. 9 . This arbitrage certificate describes the Issuer 's expectations with regard to all governmental obligations (a) issued at substantially the same time as the Note, (b) sold pursuant to a common plan cf financing with the Note, and (c) to be paid out of 0 suhstantially the same source of funds (or that Will bave substantially the same claim to be paid out of substantially the same source cf funds) as will be used to pay the Note. To the best of my knowledge and belief, there are no ether facts, estimates or circumstances that would change the foregoing hatters . IN WITNESS WHEREOF, I have hereunto set my hand on November 4, 1982. Supervisor WILLKIE FARR a GALLAGHER ONE CITICORP CENTER ROBERT S.AMDU RSKY*• CHARLES I.KING5ON 153 EAST 53RD STREET ETHAN ALLEN ARMANDO T.BELLY ARTHUR D.KOWALOFF WALSTON S.BROWN JOSEPH L.BROADROADWIN BURTON EM...EIBERT KENNETHJ. N BUTENEW YORK, N.Y. 10022 WALTER H.BROWN,JR. S �• JAMES S.BROWN,JR. IRA H.LUSTGARTEN ROSWELL C.DIKEMAN THOMAS L.BRYAN MICHAEL O.MARKSMARK F.HUGHES HOWARD C.BUSCHMAN III RAYMOND W.MERRITT (212) 935-8000 MI LLARD L.MIDONICK DALE S.COLLINSON THOMAS S.MONFRIED - SIDNEY L.SMITH ALLAN F.CONWILL PAULA J.MUELLER COUNSEL PH ILIP D.CORSI JACK H.NUSBAUM _ LOUIS A.CRACO BRIAN M.O'BRIEN CABLE"CONVEYANCE NEW YORK" JOHN S.D'ALIMONTE ANTHONY F.PHILLIPS STEPHEN I.DANZANSKYDAVID B.REA TELEX:233780(RCA) JAMES N.EDGAR ROBERT F.ROLNICK• 12-7679(W U) THORNTON G.EDWARDS THOMAS M.ROTHMAN - DWIGHT W.ELLIS III DANIEL SCHLOENDORN 818 CONNECTICUT AVENUE,N.W. CORNELIUST.FINNEGAN III PETER W.SCHMIDT WASHINGTON,D.C.20006 STEPHEN B.FLOOD DAVID H.SCHWARTZ A• TELEPHONE:(202) 328-8000 DAVID L.FOSTER IVAN SHAPI RO TELEX:89-2762 ALEXANDER T.GALLOWAY 11 PATRICIA S.SKIGEN WILLIAM J.GRANT,JR. HARVEY L.SPERRY (]p STEPHEN W.GREINER DUNCAN J.STEWART November 1 !^7, 19 s 2 16,AVENUE PIERRE1KR DE SERBIE PHILLIP H.HARRIS CHESTER J.STRAUB 75116 PARIS,FRANCE ROBERT B.HODES WILLIAM T.SULLIVAN TELEPHONE:PARIS 723-5156 LOUIS L.HOYNES,JR. C.SCOTT SYKES,JR. CABLE"CONVEYANCE PARIS" RANDALL A.HUFFMAN SUSAN P.THOMASES TELEX:842-620080 PETER H.JAKES ALLAN TRUMBULL PETER J.KENNY BRENT W.WHITE ROBERT J.KNEEL •MEMBER OF DISTRICT OF COLUMBIA BAR •�MEMBER OF NEW YORKAND D.C.BARS OTHERS ADMITTED IN NEW YORK Town of Southold County of Suffolk State of New York Town of Southold, Suffolk County, New York $10, 000 Bond Anticipation Note, 1982 (Renewal) Dear Sirs: We have been requested to render our opinion as to the validity of a $10, 000 Bond Anticipation Note, 1982 (Renewal) ( the "Note" ) , of the Town of Southold, County of Suffolk, New York (the "Issuer") , dated November 4, 1982, numbered 2-R, of the denomination of $10, 000, bearing interest at the rate of 7% per annum, payable at maturity , and maturing November 4, 1983, with prepayment reserved. We have examined the Constitution and statutes of the State of New York and the Internal Revenue Code of 1954, as amended, including particularly Section 103 thereof , and the regulations of the United States Treasury Department thereunder. We have a'-so examined a certified copy of proceedings of the finance board of the Issuer and other proofs authorizing and relating to the issuance of the Note, including the form of the Note. In rendering the opinions expressed herein we have assumed the accuracy and truthfulness of all public records, documents and proceedings examined by us which have been executed or cezti-ied by public officials acting within the scope of their official capacities, and have not verified the accuracy or truthfulness thereof. we also have assumed the genuineness ct the sicnat..res appearing upon such public records, documents and proceedings and the certifications thereof . • • Town of Southold, Suffolk County , New York November 17, :9c2 In our opinion: (a) The Note has been authorized and issued in accordance wit-h t:.e Constitution and statutes of the State of New York and constitutes a valid and legally binding general obligation of the Issuer , all the taxable real property within which is subject to the levy of ad valorem taxes to pay the Note and interest thereon, without limitation as to rate or amount; provided, however , that the enforceability (but not the validity) of the Note may be limited by any applicable bankruptcy, insolvency or other law now existing or herea:te: enacted by said State or the Federal government affecting —e enforcement of creditors' rights ; and (b) The Note is not an "arbitrage bond" and interest on the Lote is exempt under existing statutes and court decisions frcr, Federal income taxes, from New York State income taxes, and from the New York City "personal income tax on residents' ant "earnings tax on nonresidents" . The scope of our engagement in relation to the issuance cf t.;-Le Note has extended solely to the examination of the facts and law incident to rendering the opinions expressed herein. Such opinions are not intended and should not be construed to express or imply any conclusion that the amount of real property subect to taxation within the boundaries of the Issuer, together with other legally available sources of revenue, if any, will be sufficient to enable the Issuer to pay the principal of or interest on the Note as the same respectively become due and payable. We have not examined , reviewed or passed upon the accuracy, completeness or fairness of any factual information which may have been furnished to any purchaser of the Note by cr on behalf of the Issuer and, accordingly, we express no opinion as to whether the Issuer , in connection with the sale of the Note, has made any untrue statement of a material tact or omitted to state a material fact necessary in order to make any statements made, in the light of the circumstances under which they we_e nave, not misleading . Very truly yours, nr �� ;� 81517 .302P BOND ANTICIPATION RENEWAL NOTE CERTIFICATE DATED NOVEMBER 4 , 1983 . CERTIFICATE OF THE SUPERVISOR OF THE TOWN OF SOUTHOLD, SUFFOLK COUNTY, NEW YORK, AUTHORIZING THE ISSUANCE OF A $5 , 000 BOND ANTICIPATION RENEWAL NOTE OF SAID TOWN TO PAY PART OF THE COST OF THE ACQUISITION OF CERTAIN REAL PROPERTY IN AND FOR THE MATTITUCK PARK DISTRICT IN SAID TOWN. I , the undersigned Supervisor of the Town of Southold, Suffolk County, New York, DO HEREBY CERTIFY: 1 . Pursuant to a bond resolution dated August 12, 1980 , duly adopted by the Town Board of said Town on said date, authorizing the issuance of $15, 000 serial bonds of said Town to pay part of the cost of the acquisition of certain real property, as therein described, in and for said Park District in said Town, which is an assessable improvement, and delegating to me, as chief fiscal officer , power to authorize the issuance of and to sell bond anticipation notes , including renewals thereof, in anticipation of the issuance and sale of said bonds , which power is in full force and effect and has not been modified, amended or revoked, I HEREBY AUTHORIZE the issuance of a bond anticipation renewal note of said Town in the principal amount of $5, 000 in anticipation of the sale of said bonds . Said renewal note shall be dated November 4 , 1983 , shall be numbered 3-R, shall be of the denomination of $5, 000, shall bear interest at the rate of six and 00 per centum ( 6 %) per annum, payable at maturity, shall mature on November 2, 198-4 , with prepayment reserved, and both principal of and interest on said note • -2- • shall be payable in lawful money of the United States of America at The North Fork Bank & Trust Company . Mattituck in New York . Such note , is a renewal note . 2 . The specific object or purpose for which said note is hereby authorized to be issued is to pay part of the cost of the aforesaid specific object or purpose . The amount of serial bonds now remaining to be issued therefor is $5 , 000 . 3 . The note herein authorized is issued for the purpose of renewing, in part , the outstanding $10 , 000 Bond Anticipation Note, 1982 (Renewal) , numbered 2-R, dated November 4 , 1982 and maturing November 4 , 1983 , which is the only bond anticipation note presently outstanding in anticipation of the sale of said bonds . The balance of said outstanding note, in the amount of $5 , 000 , will be paid from available current funds appropriated therefor , and shall constitute the second installment of the principal amount of such indebtedness , the sum of $5 , 000 has heretofore been paid from a source other than the proceeds of bonds or bond anticipation notes on November 4 , 1982 , which amount constituted the first installment of the principal amount of such indedtedness . The date of the first bond anticipation note issued in anticipation of the sale of said bonds was November 6 , 1980 . 4 . Such note shall be executed in the name of said * Town of Southold, Suffolk County, New York, by its Supervisor , sealed with its corporate seal , attested by its Town Clerk, and the same shall be in substantially the form attached hereto . Such note is hereby sold at private sale t o The North Fork Bank & Trust Compainy i n Mattituck , New York, at a price of not less than par and accrued interest , if any. To the best of my knowledge and belief, no officer or employee of said Town has an interest in the sale of said note prohibited by Article 18 of the General Municipal Law, as amended. Dated: Southold, New York November 4 , 1983 . Supervisor An executed counterpart of the foregoing certificate, with form of note attached, was filed with the Town Board of said Town of Southold, New York on November 4 , 1983 . wn Clerk (CORPORATE SEAL) UNITED-STATES-OF AMERICA • STATE OF NEW YORK . COUNTY OF SUFFOLK TOWN OF SOUTHOLD BOND ANTICIPATION NOTE, 1983 (RENEWAL) No . 3-R $5 , 000 The Town of Southold, in the County of Suffolk, a municipality of the State of New York (herein called the' "Obligor" ) , hereby acknowledges itself indebted and for the value received promises to pay to the bearer of this note the sum. of FIVE THOUSAND DOLLARS ($5, 000) on November 2 , 1984 , together with interest t�ereon from the date hereof at the rate of six an 0 per centum ( 6 %) per annum, payable at - - maturity. Both principal of and interest on this note will be paid in lawful money of the United States of America at The North Fork Bank & Trus t Company in Mattituck New York. This note may be redeemed at any time prior to maturity by said Obligor upon giving written notice to the holder , and interest shall cease as of the date fixed for redemption. This note may not be converted into registered form. This note is one of a total authorized issue of $5 , 000 , issued pursuant to proceedings duly adopted by the Finance Board of-the Obligor , on August 12, _ 1980 , and also pursuant. to "BOND, _ _ ANTICIPATION RENEWAL NOTE CERTIFICATE DATED NOVEMBER 4 , 1983 : CERTIFICATE OF THE SUPERVISOR OF THE TOWN OF SOUTHOLD, SUFFOLK - COUNTY, NEW YORK, AUTHORIZING THE ISSUANCE OF A $5 , 000 BOND ANTICIPATION RENEWAL NOTE OF SAID TOWN TO PAY PART OF THE COST OF THE ACQUISITION OF CERTAIN REAL PROPERTY IN AND FOR THE MATTITUCK PARK DISTRICT IN SAID TOWN. " The faith and credit of the Obligor are hereby irrevocably pledged for the punctual payment of the principal of and interest on this note according to its terms . It is certified and recited that all conditions, acts and things required by the Constitution and statutes of the State of New York to exist, to have happened and to have been. performed precedent to and in the issuance of this note, exist , have happened and have been performed, and that this note, together. with all other indebtedness of the Obligor is within every debt and other limit prescribed by the Constitution and laws of such State. IN WITNESS WHEREOF, the Obligor, in accordance with the proceedings authorizing this note, has caused this note to be signed and its corporate seal to be hereunto affixed and attested as appears below, and this note to be dated as of November 4 , 1983 . TOWN OF SOUTHOLD, SUFFOLK COUNTY, NEW YORK (SEAL) ATTEST: By Town Clerk Supervisor CLOSING CERTIFICATE We the undersigned do hereby certify: That we are the officers of Town of Southold, Suffolk County, New York, (hereinafter . called the ''Obligor" ) indicated by the official title set opposite our respective signatures to this certificate . That we did officially execute a $5 , 000 Bond Anticipation Note, 1983 (Renewal ) , of said Obligor , dated November 4 , 1983 , numbered 3-R, of the denomination of $5 , 000 , bearing interest at the rate of 6 % per annum, payable at maturity and maturing November 2 , 1984 , with prepayment reserved. That no' litigation of any nature is now pending or , to our knowledge, threatened (a) to restrain or enjoin the issuance or delivery of said obligations or the levy and collection of taxes or assessments to pay the same, (b) in any manner questioning or affecting, directly or -indirectly, the validity of said obligations or the proceedings or authority for the issuance thereof , or (c) contesting the corporate existence or boundaries of the Obligor or the title of the undersigned officers to their respective offices ; that no authority or proceedings for the issuance of said obligations has been repealed, revoked or rescinded, that the corporate seal of the Obligor , or a facsimile thereof , has been impressed or imprinted on all of said obligations; and that on the date of the execution of said obligations and on the date set forth below, we were and are the duly chosen, qualified and acting officers indicated therein and on this certificate and duly authorized to execute said obligations . That on the date of this certificate , said obligations were actually delivered to the purchaser thereof against receipt of the purchase price as follows : -2- Principal (par value) : $5, 000 . 00 Premium: $ -0- Accrued interest from date of said obligations to date of delivery: $ -0- TOTAL: $5 , 000 . 00 WITNESS our official signatures on November 4 , 1983 , being the date of the actual delivery of said obligations , as aforesaid. Official Term of Office Signature Title Expires Supervisor kee-em,0e2 03/, 1C/ J' Town Clerk I hereby certify that the signatures of the officers above subscribed are true and genuine . �y NORfi IZIL 8T CO. 6y (S i nat H.Y.Cort.Manufacturers Hanov 81517 . 302P Arbitrage Certificate $5 , 000 Bond Anticipation Note, 1983 (Renewal) I certify that I am the Supervisor of the Town of Southold, Suffolk County, New York (the " Issuer" ) ; that as such officer I am responsible, with others , for issuing the above-mentioned Note of the Issuer; and that : 1 . Set forth below are the Issuer ' s expectations on the date of issue of the Note regarding the amount and use of the proceeds of the . Note and the facts and estimates on which they are based. To the best of my knowledge and ' belief, the Issuer ' s expectations are reasonable. Based on these expectations , the proceeds of the Note will . not be used in a manner that would cause them to be an "arbitrage bond" under Section 103(c) of the Internal Revenue Code of 1954 , as amended (the "Code" ) and the Treasury Regulations thereunder (the "Regulations" ) . 2 . $5 , 000 of the proceeds of the Note will be used to redeem, at its maturity, the Issuer ' s outstanding bond anticipation note (the "Prior Issue" ) which was issued to finance, or t:.) refund obligations issued to finance, the project set forth in the bond anticipation renewal note certificate of the Supervisor , dated November 4 , 1983 , which is incorporated herein by reference. Such project is hereinafter referred to as the "Refunded Project" . -2- _ 3 . All of such $5 , 000 proceeds will be expended to discharge the Prior Issue on or prior to November 4 , 1983 and until that time will not be invested. 4 . All proceeds of all obligations originally issued to finance the "Refunded Project" and directly or indirectly refunded by the Note, have been or will be expended within three years of their respective date of issue . Such expenditures have been or will be recorded in the Issuer ' s financial records . 5 . Within one year of receipt all amounts earned from investment of proceeds of the Note will be expended to pay debt service on the Note or on obligations issued to refund the Note. 6 . It is reasonably expected that all payments of principal or interest on the Note (other than those described in paragraph 5 and other than those made from refunding obligations) shall be made from the current annual revenues of the Issuer . 7 . The Issuer has not received notice that its certificate as to arbitrage may not be relied upon with respect to its issues , nor has it been advised that any such adverse action is contemplated by the Commissioner of Internal Revenue. 8 . There is not expected to be any fund not described above that will (a) be needed to pay principal or interest on the Note, (b) replace funds that will be used to pay principal or interest on the Note, or (c) be pledged to secure the Note. 9 . This arbitrage certificate describes the Issuer ' s expectations with regard to all governmental obligations (a) issued at substantially the same time as the Note, (b) sold pursuant to a common plan of financing with the Note, and (c) to be paid out of -3- substantially the same source of funds (or that will have substantially the same claim to be paid out of substantially the same source of funds) as will be used to pay the Note. To the best of my knowledge and belief , there are no other facts , estimates or circumstances that would change the foregoing matters . IN WITNESS WHEREOF, I have hereunto set my hand on November 4 , 1983 . rT Supervisor WILLKIE FARR a GALLAGHER ONE CITICORP CENTER ROBERT S.AMDURSKY*' CHARLES I.KINGSON 153 EAST 53RD STREET ETHAN ALLEN AR MANDO T.BELLY ARTHUR D.KOWALOFF WALSTON S.BROWN KENNETH J.BIALKIN JAY F.LEARY ' NEW YORK, N. Y. 10022 WALTER H.BROW N,JR. ROGER D.BLANC BURTON M.LEISERT• ROSWELL C.DIKEMAN JOSEPH L.BROADWIN IRA H.LUSTGARTEN MARK F.HUGHES JAM ES S.BROWN,JR. MICHAEL G.MARKS (212) 935-8000 MILLARD L.MIDONICK THOMAS L.BRYAN RAYMOND W.MERRITT COUNSEL DALE S.COLLINSON THOMAS S.MONFRIED ALLAN F.CONWILL BRUCE M.MONTGOMERIE CABLE"CONVEYANCE NEW YORK" PHILIP D.CORSI PAULA J.MUELLER LOUIS A.CRACO JACK H.NUSBAUM TELEX:233780-7679(RCA) JOHN S.D'ALIMONTE BRIAN M.O'BRI EN 12-7879 (W U) STEPHEN I.DANZANSKY• ANTHONY F.PHILLIPS JAMES N.EDGAR DAVID B.RFA BIB CONNECTICUT AVENUE,N.W. DWIGHT W.ELLIS M ROBERT F.ROLNICK• WASHINGTON,D.C.20006 CORNELIUS T.FINNEGAN III THOMAS M.ROTHMAN TELEPHONE:(202)328-8000 JOHN D.FITZSIMMONS PHILIPPE M.SALOMON TELEX:89-2762 STEPHEN B.FLOOD DANIEL SCHLOENDORN - DAVID L.FOSTER PETER W.SCHMIDT 16,AVENUE PIERRE 1-DE SERBIE ALEXANDER T.GALLOWAY U DAVID H.SCHWARTZ# WILLIAM J.GRANT,JR. IVAN SHAPIRO p 75118 PARIS,FRANCE STEPHEN W.GREINER PATRICIA S.SKIGEN November 21 , 19 8 3 TELEPHONE:PARI5 723-5158 R PHILLIP H.HARRIS* HARVEY L.SPERRY CABLE"CONVEYANCE PARIS" ROBERT B.HODES DUNCAN J.STEWART TELEX:842-620080 LOUIS L.HOYN ES,JR. CHESTER J.STRAUB - RANDALLA.HUFFMAN SUSAN P.THOMASES PETER H.JAKES ALLAN TRUMBULL PETERJ.KENNY PHILIP L.VERVEER• ROBERT J.KNEEL*' BRENT W.WHITE •MEMBER OF DISTRICT OF COLUMBIA BAR ••MEMBER OF NEW YORK AND D.C.BARS OTHERS ADMITTED IN NEW YORK Town of Southold County of Suffolk State of New York Town of Southold , Suffolk County, New York $5,000 Bond Anticipation Note , 1983 (Renewal) Dear Sirs: We have been requested to render our opinion as to the validity of a $5 ,000 Bond Anticipation Note, 1983 (Renewal) (the "Note" ) , of the Town of Southold, County of Suffolk, New York (the "Issuer" ) , dated November 4 , 1983, numbered 3-R, of the denomination of $5 ,000, bearing interest at the rate of 6 .00% per annum, payable at maturity , and maturing November 2 , 1984 , with prepayment reserved. We have examined the Constitution and statutes of the State of New York and the Internal Revenue Code of 1954, as amended, including particularly Section 103 thereof , and the regulations of the United States Treasury Department thereunder. We have also examined a certified copy of proceedings of the finance board of the Issuer and other proofs authorizing and relating to the issuance of the Note, including the form of the Note. In rendering the opinions expressed herein we have aasumed the accuracy and truthfulness of all public records, documents and proceedings examined by us which have been executed or certified by public officials acting within the scope of their official capacities, and have not verified the accuracy or truthfulness thereof. We also have assumed the genuineness of the signatures appearing upon such public records, documents and proceedings and the certifications thereof . Town of Southold , Suffolk County, New York -2- November 21 , 1983 In our opinion: (a) The Note has been authorized and issued in accordance with the Constitution and statutes of the State of New York and constitutes a valid and legally binding general obligation of the Issuer , all the taxable real property within which is subject to the levy of ad valorem taxes to pay the Note and interest thereon, without limitation as to rate or amount; provided, however , that the enforceability (but not the validity) of the Note may be limited by any applicable bankruptcy, insolvency or other law now existing or hereafter enacted by said State or the Federal government affecting the enforcement of creditors' rights; and (b) The Note is not an "arbitrage bond" and interest on the Note is exempt under existing statutes and court decisions from Federal income taxes, from New York State income taxes, and from the New York City "personal income tax on residents" and "earnings tax on nonresidents" . The scope of our engagement in relation to the issuance of the Note has extended solely to the examination -of the facts and law incident to rendering the opinions expressed herein. Such opinions are not intended and should not be construed to express or imply any conclusion that the amount of real property subject to taxation within the boundaries of the Issuer , together with other legally available sources of revenue , if any, will be sufficient to enable the Issuer to pay the principal of or interest on the Note as the same respectively become due and payable. We have not examined , reviewed or passed upon the accuracy, completeness or fairness of any factual information which may have been furnished to any purchaser of the dote by or on behalf of the Issuer and, accordingly, we express no opinion as to whether the Issuer, in connection with the sale of the Note, has made any untrue statement of a material fact or omitted to state a material- fact necessary in order to make any statements made, in the light of the circumstances under which they were made, not misleading. Very truly yours, hm c