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HomeMy WebLinkAboutExhibit BEXHIBIT B FORM OF BOND PURCHASE AGREEMENT B-1 1097142993\9\ 023084.00028 BOND PURCHASE AGREEMENT $[PAR AMOUNT A] CITY OF MIAMI, FLORIDA SPECIAL OBLIGATION NON -AD VALOREM REVENUE BONDS, SERIES 2023A (NEW ADMINISTRATIVE BUILDING) City of Miami, Florida 444 S.W. 2nd Avenue Miami, Florida 33130 Ladies and Gentlemen: $[PAR AMOUNT B] CITY OF MIAMI, FLORIDA SPECIAL OBLIGATION NON -AD VALOREM REVENUE BONDS, SERIES 2023B (NEW ADMINISTRATIVE BUILDING) $[PAR AMOUNT C] CITY OF MIAMI, FLORIDA TAXABLE SPECIAL OBLIGATION NON -AD VALOREM BONDS, SERIES 2023C [SALE DATE], 2023 The undersigned, Jefferies LLC (the "Representative"), acting on its own behalf and on behalf of BofA Securities, Inc., Estrada Hinojosa & Company, Inc., Siebert Williams Shank & Co., LLC, and Wells Fargo Bank, N.A. (collectively with the Representative, the "Underwriters"), offers to enter into the following bond purchase agreement (this "Agreement") with the City of Miami, a municipal corporation of the State of Florida (the "City") which, upon the City's written acceptance of this offer, will be binding upon the City and upon the Underwriters. This offer is made subject to the City's written acceptance hereof on or before 11:59 p.m., Eastern Daylight Time, on [SALE DATE], 2023, and, if not so accepted, will be subject to withdrawal by the Underwriters upon written notice delivered to the City at any time prior to the acceptance hereof by the City. Terms not otherwise defined in this Agreement shall have the same meanings as set forth in the Resolution (as defined herein) or in the Official Statement of the City dated the date hereof, relating to the Series 2023 Bonds (as defined below), together with all appendices or exhibits, any materials incorporated by reference therein and any amendments or supplements thereto (collectively, the "Official Statement"). 1. Purchase and Sale of the Series 2023 Bonds. Subject to the terms and conditions and in reliance upon the representations, warranties and agreements set forth herein, the Underwriters hereby agree to purchase from the City, and the City hereby agrees to sell and deliver to the Underwriters, all, but not less than all, of the City's $[PAR AMOUNT A] Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023A (New Administrative Building) (the "Series 2023A Bonds"), $[PAR AMOUNT B] Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023B (New Administrative Building) (the "Series 2023B Bonds" and, together with the Series 2023A Bonds, the "Tax -Exempt Bonds") and $[PAR AMOUNT C] Taxable Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023C (the "Series 2023C Bonds" and, together with the Tax -Exempt Bonds, the "Series 2023 Bonds"). The City acknowledges and agrees that: (i) the primary role of the Underwriters, as underwriters, is to purchase the Series 2023 Bonds, in an arm's-length commercial transaction between the City and the Underwriters and that the Underwriters have financial and other interests that differ from those of the City; (ii) the Underwriters are not acting as a municipal advisor, financial advisor, or fiduciary to the City and have not assumed any advisory or fiduciary responsibility to the City with respect to the transaction contemplated hereby and the discussions, undertakings and procedures leading thereto (irrespective of whether the Underwriters have provided other services or are currently providing other services to the City on other matters); (iii) the only obligations the Underwriters have to the City with respect to the transaction contemplated hereby expressly are set forth in this Agreement and the other City Documents (defined herein); (iv) the Underwriters have financial and other interests that differ from the City; and (v) the City has consulted its own financial and/or municipal, legal, accounting, tax and other advisors, as applicable, to the extent it deems appropriate. The principal amount of the Series 2023 Bonds to be issued, the dated date therefor, the maturities, interest rates per annum, prices and/or yields, sinking fund provisions (if any), optional redemption provisions, and other terms of the Series 2023 Bonds are set forth in Schedule I hereto. The Series 2023 Bonds shall be issued and secured under and pursuant to Resolution No. R-23- [ ], adopted by the City Commission of the City (the "City Commission") on September [28], 2023 (the "Resolution"). The Series 2023A Bonds are being issued for the purpose of providing funds, together with other available moneys, to (i) pay the costs of developing, constructing and equipping a new City administration building, along with related parking and other related improvements (including the payment of interest on the Series 2023A Bonds during construction) (the "Series 2023A Project"), (ii) [fund a deposit to the Debt Service Reserve Account or pay the premium for a Reserve Account Insurance Policy], and (iii) pay certain costs of issuance of the Series 2023A Bonds[, including payment of a municipal bond insurance policy premium to [ ] (the "Bond Insurer")]. The Series 2023B Bonds are being issued for the purpose of providing funds, together with other available moneys, to (i) pay the costs of developing, constructing and equipping a new City administration building, along with related parking and other related improvements (including the payment of interest on the Series 2023B Bonds during construction) (the "Series 2023B Project" and, together with the Series 2023A Project, the "Project"), (ii) [fund a deposit to the Debt Service Reserve Account or pay the premium for a Reserve Account Insurance Policy], and (iii) pay certain costs of issuance of the Series 2023B Bonds[, including payment of a municipal bond insurance policy premium to the Bond Insurer]. The Series 2023C Bonds are being issued for the purpose of providing funds, together with other available moneys, to (i) pay a portion of the cost of the acquisition and implementation of the Oracle Enterprise Resource Planning Cloud System; (ii) fund a deposit to the Debt Service Reserve Account or pay the premium for a Reserve Account Insurance Policy]; and (iii) pay certain costs of issuance of the Series 2023C Bonds[, including payment of a municipal bond insurance policy premium to the Bond Insurer.] 2 The aggregate purchase price for the Series 2023A Bonds shall be $[ ] (representing the $[ ] aggregate par amount of the Series 2023A Bonds, [plus/less/net] an original issue [premium/discount] of $[ ], and less an underwriting discount of $[ ])- The aggregate purchase price for the Series 2023B Bonds shall be $[ ] (representing the $[ ] aggregate par amount of the Series 2023B Bonds, [plus/less/net] an original issue [premium/discount] of $[ ], and less an underwriting discount of $[ ])- The aggregate purchase price for the Series 2023C Bonds shall be $[ ] (representing the $[ ] aggregate par amount of the Series 2023C Bonds, less an underwriting discount of $[ ]). Delivered to the City herewith as a good faith deposit is a check payable to the order of the City in clearing house funds in the amount of $[ ] (the "Good Faith Check"). In the event that the City accepts this Agreement, the Good Faith Check shall be held uncashed by the City until the time of Closing, at which time the Good Faith Check shall be returned uncashed to the Representative. In the event that the City does not accept this Agreement, the Good Faith Check will be immediately returned to the Representative. Should the City fail to deliver the Series 2023 Bonds at the Closing, or should the City be unable to satisfy the conditions of the obligations of the Underwriters to purchase, accept delivery of and pay for the Series 2023 Bonds, as set forth in this Agreement (unless waived by the Underwriters), or should such obligations of the Underwriters be terminated for any reason permitted by this Agreement, the City shall immediately return the Good Faith Check to the Representative. In the event that the Underwriters fail (other than for a reason permitted under Section 8 hereof) to purchase, accept delivery of and pay for the Series 2023 Bonds at the Closing as herein provided, such Good Faith Check shall be cashed and the amount thereof retained by the City as and for fully liquidated damages for such failure of the Underwriters (because the amount of such damages cannot be calculated by the parties hereto), and, except as set forth in Sections 9 and 11 hereof, no party shall have any further rights against the other hereunder. The Underwriters and the City understand that in such event the City's actual damages may be greater or may be less than the amount of the Good Faith Check. Accordingly, the Underwriters hereby waive any right to claim that the City's actual damages are less than such amount, and the City's acceptance of this offer shall constitute a waiver of any right the City may have to additional damages from the Underwriters. In accordance with Section 218.385, Florida Statutes, as amended, the Underwriters hereby disclose the information required by such Section, including a truth -in -bonding statement, as provided in Schedule II attached hereto. The Representative hereby agrees and makes the following representations and warranties to the City: (a) each of the Underwriters is an entity duly organized, validly existing and in good standing under the laws of the jurisdiction of its organization and qualified to conduct business in the State of Florida, (b) this Agreement has been duly authorized, executed and delivered by the Representative on behalf of the Underwriters and, assuming the due authorization, execution and delivery by the City, is the legal, valid and binding obligation of the Underwriters enforceable in accordance with its terms, except as the enforceability of this Agreement may be limited by 3 bankruptcy or other laws affecting creditors' rights generally and except that equitable remedies lie in the discretion of the court and may not be available, (c) each Underwriter is licensed by and registered with the Financial Industry Regulatory Authority as a broker dealer and the Municipal Securities Rulemaking Board (the "MSRB") as a municipal securities dealer, (d) neither the Underwriters nor any "person" or "affiliate" thereof has been on the "convicted vendor list" during the past 36 months as all such terms are defined in Section 287.133, Florida Statutes, as amended. The Representative represents that it has been duly authorized to execute this Agreement on behalf of itself and the other Underwriters named herein. 2. Public Offering. The Underwriters agree to make a bona fide public offering of all of the Tax -Exempt Bonds at prices not to exceed the public offering prices set forth on the inside front cover of the Official Statement (the "Offering Prices") and may subsequently change such Offering Prices without any requirement of prior notice. The Underwriters may offer and sell Series 2023 Bonds to certain dealers and others at prices lower than the Offering Prices to the extent allowed by the Code (defined herein). 3. Establishment of Issue Price. (a) The Representative, on behalf of the Underwriters, agrees to assist the City in establishing the issue price of the Tax -Exempt Bonds and shall execute and deliver to the City at Closing an "issue price" or similar certificate, together with the supporting pricing wires or equivalent communications, [substantially in the form attached hereto as Exhibit A], with such modifications as may be appropriate or necessary, in the reasonable judgment of the Representative, the City, the City's Financial Advisor, and Bond Counsel, to accurately reflect, as applicable, the sales price or prices or the initial offering price or prices to the public of the Tax - Exempt Bonds. (b) Except as otherwise set forth in Schedule I to Exhibit A attached hereto, the City will treat the first price at which 10% of each maturity of the Tax -Exempt Bonds (the "10% test") is sold to the public as the issue price of that maturity. At or promptly after the execution of this Agreement, the Representative shall report to the City the price or prices at which the Underwriters have sold to the public each maturity of Tax -Exempt Bonds. For purposes of this Section, if Tax - Exempt Bonds mature on the same date but have different interest rates, each separate CUSIP number within that maturity will be treated as a separate maturity of the Tax -Exempt Bonds. (c) If Exhibit A includes Schedule I, the Representative confirms that the Underwriters have offered the Tax -Exempt Bonds to the public on or before the date of this Agreement at the offering price or prices (the "initial offering price"), or at the corresponding yield or yields, set forth in Schedule I to Exhibit A attached hereto, except as otherwise set forth therein. Schedule I, should it exist, also sets forth, as of the date of this Agreement, the maturities, if any, of the Tax - Exempt Bonds for which the 10% test has not been satisfied and for which the City and the Representative, on behalf of the Underwriters, agree that the restrictions set forth in the next sentence shall apply, which will allow the City to treat the initial offering price to the public of each such maturity as of the sale date as the issue price of that maturity (the "hold -the -offering - price rule"). So long as the hold -the -offering -price rule remains applicable to any maturity of the Tax -Exempt Bonds, the Underwriters will neither offer nor sell unsold Tax -Exempt Bonds of that 4 maturity to any person at a price that is higher than the initial offering price to the public during the period starting on the sale date and ending on the earlier of the following: (1) the close of the fifth (5th) business day after the sale date; or (2) the date on which the Underwriters have sold at least 10% of that maturity of the Tax -Exempt Bonds to the public at a price that is no higher than the initial offering price to the public. The Representative will advise the City promptly after the close of the fifth (5th) business day after the sale date whether it has sold 10% of that maturity of the Tax -Exempt Bonds to the public at a price that is no higher than the initial offering price to the public. (d) The Representative confirms that: (1) any agreement among underwriters, any selling group agreement and each third -party distribution agreement (to which the Representative is a party) relating to the initial sale of the Tax -Exempt Bonds to the public, together with the related pricing wires, contains or will contain language obligating each Underwriter, each dealer who is a member of the selling group and each broker -dealer that is a party to such third -party distribution agreement, as applicable: (A)(i) to report the prices at which it sells to the public the unsold Tax -Exempt Bonds of each maturity allocated to it, whether or not the Closing Date has occurred, until either all Tax -Exempt Bonds of that maturity allocated to it have been sold or it is notified by the Representative that the 10% test has been satisfied as to the Tax -Exempt Bonds of that maturity, provided that, the reporting obligation after the Closing Date may be at reasonable periodic intervals or otherwise upon request of the Representative, and (ii) to comply with the hold -the -offering -price rule, if applicable, if and for so long as directed by the Representative and as set forth in the related pricing wires, and (B) to promptly notify the Representative of any sales of Tax -Exempt Bonds that, to its knowledge, are made to a purchaser who is a related party to an underwriter participating in the initial sale of the Tax -Exempt Bonds to the public (each such term being used as defined below), (C) to acknowledge that, unless otherwise advised by the Underwriter, dealer or broker -dealer, the Representative shall assume that each order submitted by the Underwriter, dealer or broker -dealer is a sale to the public. (2) any agreement among underwriters or selling group agreement relating to the initial sale of the Tax -Exempt Bonds to the public, together with the related pricing wires, contains or will contain language obligating each Underwriter or dealer that is a party to a third -party distribution agreement to be employed in connection with the initial sale of the Tax -Exempt Bonds to the public to require each broker -dealer that is a party to such third -party distribution agreement to (A) report the prices at which it sells to the public the unsold Tax -Exempt Bonds of each maturity allocated to it, whether or not the Closing Date has occurred, until either all Series 2023 Bonds of that maturity allocated to it have been sold or it is notified by the Representative or such Underwriter or dealer that the 10% test has been satisfied as to the Tax -Exempt Bonds of that maturity, provided that, the reporting obligation after the Closing Date may be at reasonable periodic intervals or otherwise upon request of the Representative or such Underwriter or dealer, and (B) 5 comply with the hold -the -offering -price rule, if applicable, if and for so long as directed by the Representative or the Underwriter or the dealer and as set forth in the related pricing wires. (e) The City acknowledges that, in making the representations set forth in this section, the Representative will rely on (i) the agreement of each Underwriter to comply with the requirements for establishing issue price of the Tax -Exempt Bonds, including, but not limited to, its agreement to comply with the hold -the -offering -price rule, if applicable to the Tax -Exempt Bonds, as set forth in an agreement among underwriters and the related pricing wires, (ii) in the event a selling group has been created in connection with the initial sale of the Tax -Exempt Bonds to the public, the agreement of each dealer who is a member of the selling group to comply with the requirements for establishing issue price of the Tax -Exempt Bonds, including, but not limited to, its agreement to comply with the hold -the -offering -price rule, if applicable to the Tax -Exempt Bonds, as set forth in a selling group agreement and the related pricing wires, and (iii) in the event that an Underwriter or dealer who is a member of the selling group is a party to a third -party distribution agreement that was employed in connection with the initial sale of the Tax -Exempt Bonds to the public, the agreement of each broker -dealer that is a party to such agreement to comply with the requirements for establishing issue price of the Tax -Exempt Bonds, including, but not limited to, its agreement to comply with the hold -the -offering -price rule, if applicable to the Tax -Exempt Bonds, as set forth in the third -party distribution agreement and the related pricing wires. The City further acknowledges that each Underwriter shall be solely liable for its failure to comply with its agreement regarding the requirements for establishing issue price of the Tax - Exempt Bonds, including, but not limited to, its agreement to comply with the hold -the -offering - price rule, if applicable to the Tax -Exempt Bonds, and that no Underwriter shall be liable for the failure of any other Underwriter, or of any dealer who is a member of a selling group, or of any broker -dealer that is a party to a third -party distribution agreement, to comply with its corresponding agreement to comply with the requirements for establishing issue price of the Tax - Exempt Bonds, including, but not limited to, its agreement to comply with the hold -the -offering - price rule, if applicable to the Tax -Exempt Bonds. (f) The Underwriters acknowledge that sales of any Tax -Exempt Bonds to any person that is a related party to an underwriter participating in the initial sale of the Tax -Exempt Bonds to the public (each such term being used as defined below) shall not constitute sales to the public for purposes of this section. Further, for purposes of this Section 3: (1) "public" means any person (including an individual, trust, estate, partnership, association, company or corporation) other than an underwriter or a related party to an underwriter; (2) "underwriter" means (A) any person that agrees pursuant to a written contract with the City (or with the lead underwriter to form an underwriting syndicate) to participate in the initial sale of the Tax -Exempt Bonds to the public and (B) any person that agrees pursuant to a written contract directly or indirectly with a person described in clause (A) to participate in the initial sale of the Tax -Exempt Bonds to the public (including a member of a selling group or a party to a third -party distribution agreement participating in the initial sale of the Tax -Exempt Bonds to the public); 6 (3) a purchaser of any of the Tax -Exempt Bonds is a "related party" to an underwriter if the underwriter and the purchaser are subject, directly or indirectly, to (A) more than 50% common ownership of the voting power or the total value of their stock, if both entities are corporations (including direct ownership by one corporation of another), (B) more than 50% common ownership of their capital interests or profits interests, if both entities are partnerships (including direct ownership by one partnership of another), or (C) more than 50% common ownership of the value of the outstanding stock of the corporation or the capital interests or profit interests of the partnership, as applicable, if one entity is a corporation and the other entity is a partnership (including direct ownership of the applicable stock or interests by one entity of the other); and (4) "sale date" means the date of execution of this Agreement by all parties. 4. The Official Statement. (a) The Preliminary Official Statement of the City dated [POS DATE], 2023 relating to the Series 2023 Bonds together with all appendices or exhibits, any materials incorporated by reference therein and any amendments or supplements thereto (collectively, the "Preliminary Official Statement") has been prepared by the City for use and distribution by the Underwriters in connection with the public offering, sale and distribution of the Series 2023 Bonds. The City hereby consents to and ratifies the use and distribution by the Underwriters of the Preliminary Official Statement in connection with the public offering of the Series 2023 Bonds. The City hereby represents and warrants that the Preliminary Official Statement is "deemed final" by the City as of its date, except for the omission of such information which is dependent upon the final pricing of the Series 2023 Bonds for completion, all as permitted to be excluded by Section (b)(1) of Rule 15c2-12 under the Securities Exchange Act of 1934, as amended (the "Rule"). (b) The City hereby authorizes and consents to the use of the Official Statement, including any amendments or supplements thereto, by the Underwriters in connection with the public offering and the sale of the Series 2023 Bonds. The City shall provide, or cause to be provided, to the Underwriters as soon as practicable after the date of the City's acceptance of this Agreement (but, in any event, not later than within seven business days after the City's acceptance of this Agreement and in sufficient time to accompany any confirmation that requests payment from any customer) copies of the Official Statement, including any amendments or supplements thereto, which are complete as of the date of its delivery to the Underwriters in such quantity as the Representative shall reasonably request in order for the Underwriters to comply with Section (b)(4) of the Rule and the rules of the MSRB. The City hereby confirms that it agrees to the distribution of the Official Statement in electronic form, including any amendments or supplements thereto. (c) If, after the date of this Agreement to and including the date the Underwriters are no longer required to provide an Official Statement to potential customers and request the same pursuant to the Rule (the earlier of (i) ninety (90) days from the "end of the underwriting period" (as defined in the Rule) and (ii) the time when the Official Statement is available to any person from the MSRB, but in no case less than twenty-five (25) days after the "end of the underwriting period" for the Series 2023 Bonds), the City or the Representative becomes aware of any fact or event which would cause the Official Statement, as then supplemented or amended, to contain any 7 untrue statement of a material fact or to omit to state a material fact required to be stated therein or necessary to make the statements therein, in light of the circumstances under which they were made, not misleading, or if it is necessary to amend or supplement the Official Statement to comply with law, the City or the Representative, as applicable, will notify the other party (and for the purposes of this clause provide the City or the Representative, as applicable, with such information as it may from time to time request), and if, in the opinion of the City or reasonable opinion of the Representative, such fact or event requires preparation and publication of a supplement or amendment to the Official Statement, the City will forthwith prepare and furnish (in a form and manner approved by the Representative, the City, Bond Counsel, and Disclosure Counsel), at the City's own expense (unless such misstatement or omission was contained in information provided by the Underwriters, then at the Underwriters' expense), a reasonable number of copies of either amendments or supplements to the Official Statement so that the statements in the Official Statement as so amended and supplemented will comply with law or not contain any untrue statement of a material fact or omit to state a material fact required to be stated therein or necessary to make the statements therein, in light of the circumstances under which they were made, not misleading. Unless otherwise notified in writing by the Representative on or prior to the Closing Date, the City can assume that the "end of the underwriting period" for purposes of the Rule and this Section is the Closing Date. (d) The Representative hereby agrees to file, and the City authorizes the Representative to file, the Official Statement, including any amendments or supplements thereto, as required by the MSRB. 5. Representations, Warranties, and Covenants of the City. The City hereby represents and warrants to and covenants with the Underwriters as follows; provided that with respect to clauses (e)-(k), (n) and (r) below, such representations and warranties are made to the best knowledge, information and belief of the City: (a) The City is a municipal corporation of the State of Florida (the "State") duly created, organized and existing under the Constitution of the State and applicable laws of the State including, in particular Chapter 166, as amended, the City's Charter and other applicable provisions of law (the "Act"), and has full legal right, power and authority under the Act, and at the Closing Date will have full legal right, power and authority under the Act and the Resolution (i) to adopt the Resolution and to enter into, execute and deliver this Agreement, the Paying Agent and Bond Registrar Agreement (the "Paying Agent Agreement") by and between the City and [ ], as the paying agent and bond registrar (the `Bank"), and the Disclosure Dissemination Agent Agreement relating to the Series 2023 Bonds (the "Undertaking") by and between the City and Digital Assurance Certification, L.L.C., as the disclosure dissemination agent, and all documents required hereunder and thereunder to be executed and delivered by the City (this Agreement, the Resolution, the Paying Agent Agreement, the Undertaking, and the other documents referred to in this clause are hereinafter referred to as the "City Documents"), (ii) to sell, issue and deliver the Series 2023 Bonds to the Underwriters as provided herein, and (iii) to carry out and consummate the transactions contemplated by the City Documents and the Official Statement, and as of the date hereof, the City has complied in all material respects with the terms of the Act and the City Documents as they pertain to such transactions; 8 (b) By all necessary official action of the City, prior to or concurrently with the acceptance hereof, the City has duly authorized and approved (i) the issuance and sale of the Series 2023 Bonds, (ii) the distribution of the Preliminary Official Statement, and the execution, delivery, and distribution of the Official Statement, including any amendments or supplements thereto, for use by the Underwriters in connection with the public offering of the Series 2023 Bonds, (iii) the approval, execution and delivery of, and the performance by the City of the obligations on its part, contained in the Series 2023 Bonds and the City Documents, and (iv) the consummation by it of all other transactions contemplated by the Official Statement, and the City Documents and any and all such other agreements and documents as may be required to be executed, delivered and/or received by the City in order to carry out, give effect to, and consummate the transactions contemplated herein and in the Official Statement, in each case excepting any authorization that cannot be obtained prior to or concurrently with the date of this Agreement; (c) This Agreement constitutes a legal, valid and binding obligation of the City enforceable in accordance with its terms, subject to bankruptcy, insolvency, reorganization, moratorium and other similar laws and principles of equity relating to or affecting the enforcement of creditors' rights and subject to judicial discretion; the other City Documents, when executed by the respective parties thereto, will constitute legal, valid and binding obligations of the City , enforceable in accordance with their respective terms, subject to bankruptcy, insolvency, reorganization, moratorium and other similar laws and principles of equity relating to or affecting the enforcement of creditors' rights and subject to judicial discretion; the Series 2023 Bonds, when issued, delivered and paid for, in accordance with the Resolution and this Agreement, will constitute legal, valid and binding obligations of the City entitled to the benefits of the Resolution and enforceable in accordance with their terms, subject to bankruptcy, insolvency, reorganization, moratorium and other similar laws and principles of equity relating to or affecting the enforcement of creditors' rights and subject to judicial discretion; upon the issuance, authentication and delivery of the Series 2023 Bonds as aforesaid, the Resolution will provide, for the benefit of the holders, from time to time, of the Series 2023 Bonds, the legally valid and binding pledge of and lien it purports to create as set forth in the Resolution; (d) The City is lawfully empowered to pledge and grant a lien upon the Pledged Funds (as defined in the Resolution) and, to covenant to budget and appropriate in its annual budget, by amendment, if necessary, from Non -Ad Valorem Revenues (as defined in the Resolution) lawfully available in each Fiscal Year, to the extent provided in the Resolution, amounts sufficient for the payment of the principal of, redemption premium, if any, and interest on the Series 2023 Bonds pursuant to the Resolution, as described in the Official Statement for the Series 2023 Bonds; (e) Except as expressly disclosed in the Preliminary Official Statement and the Official Statement, including any amendments or supplements thereto, the City is not in breach of or default in any material respect under any applicable constitutional provision, law or administrative regulation of the State or the United States or any applicable judgment or decree or any loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the City is a party or to which the City is or any of its property or assets are otherwise subject, and no event has occurred and is continuing which constitutes or with the passage of time or the giving of notice, or both, would constitute a default or event of default by the City under any of the foregoing; and when executed by the respective parties hereto and thereto, the City reasonably expects as of the date hereof that execution and delivery of the Series 2023 Bonds, the City Documents and the 9 adoption of the Resolution and compliance with the provisions on the City's part contained therein, will not conflict with or constitute a breach of or default under any constitutional provision, administrative regulation, judgment, decree, loan agreement, indenture, bond, note, resolution, agreement or other instrument to which the City is a party or to which the City is or to which any of its property or assets are otherwise subject nor will any such execution, delivery, adoption or compliance result in the creation or imposition of any lien, charge or other security interest or encumbrance of any nature whatsoever upon any of the property or assets of the City to be pledged to secure the Series 2023 Bonds or under the terms of any such law, regulation or instrument, except as provided by the Series 2023 Bonds and the Resolution; (f) Except as expressly disclosed in the Preliminary Official Statement and the Official Statement, including any amendments or supplements thereto, the City has not in the prior five (5) years failed to comply in any material respect with any prior continuing disclosure obligation for any of its outstanding debt that was subject to the Rule at the time of issuance; (g) All authorizations, approvals, licenses, permits, consents and orders of any governmental authority, legislative body, board, agency or commission having jurisdiction of the matter which are required for the due authorization of, which would constitute a condition precedent to, or the absence of which would materially adversely affect the due performance by the City of its obligations under the City Documents, and the Series 2023 Bonds have been duly obtained, except for such approvals, consents and orders that may not be obtained until after the date of this Agreement or as may be required under the Blue Sky or securities laws of any jurisdiction in connection with the offering and sale of the Series 2023 Bonds; (h) Except as expressly disclosed in the Preliminary Official Statement and the Official Statement, including any amendments or supplements thereto, there is no, action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, government agency, public board or body, pending or, to the best knowledge of the City , threatened against the City, contesting the right of the members or officials of the City to hold and exercise their respective positions, the due organization and valid existence of the City, or affecting or seeking to prohibit, restrain, limit, or enjoin the sale, issuance or delivery of the Series 2023 Bonds or the pledge of the Pledged Funds or the financing of the Project pursuant to the Resolution or in any way contesting or affecting the validity or enforceability of the Series 2023 Bonds, the City Documents, or contesting in any way the completeness or accuracy of the Preliminary Official Statement or the Official Statement, including any amendments or supplements thereto, or contesting the powers of the City or the financing of the Project, the issuance of the Series 2023 Bonds, the adoption of the Resolution or the execution and delivery of the City Documents, nor, to the best knowledge of the City, is there any basis therefor, where in each such action, suit, proceeding, inquiry or investigation an unfavorable decision, ruling or finding would materially adversely affect the validity or enforceability of the Series 2023 Bonds, the City Documents, or the excludability from gross income of interest on the Tax -Exempt Series 2023 Bonds for federal income tax purposes; (i) The Preliminary Official Statement (other than the information concerning DTC or its book -entry system of registration, information provided by the Underwriters in the Section entitled "UNDERWRITING" [and any information regarding the Bond Insurer or Bond Insurance Policy (as such term is hereinafter defined]) does not as of its date contain any untrue statement of 10 a material fact or omit to state a material fact required to be stated therein or necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading, except for "permitted omissions" as described in the Rule; (j) At the time of the City's acceptance hereof and (unless the Official Statement is amended or supplemented pursuant to paragraph (c) of Section 4 of this Agreement) at all times subsequent thereto during the period up to and including the Closing Date, the Official Statement (other than the information concerning DTC or its book -entry system of registration, information provided by the Underwriters in the Section entitled "UNDERWRITING") will not contain any untrue statement of a material fact or omit to state any material fact required to be stated therein or necessary to make the statements therein, in light of the circumstances under which they were made, not misleading; (k) If the Official Statement is supplemented or amended pursuant to paragraph (c) of Section 4 of this Agreement, at the time of each supplement or amendment thereto and (unless subsequently again supplemented or amended pursuant to such paragraph) at all times subsequent thereto during the period up to and including the Closing Date, the Official Statement as so supplemented or amended (other than the information concerning DTC or its book -entry system of registration and information provided by the Underwriters in the Section entitled "UNDERWRITING") will not contain any untrue statement of a material fact or omit to state any material fact required to be stated therein or necessary to make the statements therein, in light of the circumstances under which made, not misleading; (1) The City will apply, or cause to be applied, the proceeds from the sale of the Series 2023 Bonds as described in the Official Statement, subject to all of the terms and provisions of the Resolution, and shall not knowingly take or omit to take any action that, under existing law, may adversely affect the exclusion from gross income for federal income tax purposes, or the exemption from any applicable state tax, of the interest on the Tax -Exempt Series 2023 Bonds; (m) The City will furnish such information and execute such instruments and take such action in cooperation with the Underwriters as the Representative may reasonably request: (i) to (A) qualify the Series 2023 Bonds for offer and sale under the Blue Sky or other securities laws and regulations of such states and other jurisdictions in the United States as the Representative may designate, and (B) determine the eligibility of the Series 2023 Bonds for investment under the laws of such states and other jurisdictions; and (ii) to continue such qualifications in effect so long as required for the distribution of the Series 2023 Bonds (provided, however, that the City will not be required to qualify as a foreign corporation or to file any general or special consents to service of process under the laws of any jurisdiction, or comply with any other requirements reasonably deemed by it to be unduly burdensome) and will advise the Representative promptly upon receipt by the City of any notification with respect to the suspension of the qualification of the Series 2023 Bonds for sale in any jurisdiction or the initiation or threat of any proceeding for that purpose; (n) The financial statements of the City for the Fiscal Year ended September 30, 2022 and other financial information regarding the City in the Preliminary Official Statement and the Official Statement, including any amendments or supplements thereto, fairly present the financial position and results of the City as of the dates and for the periods therein set forth in accordance with generally accepted accounting principles as promulgated by the Governmental Accounting 11 Standards Board consistently applied, and since the dates thereof, there has been no material adverse change in the financial position or results of operations of the City except as may be expressly disclosed in the Preliminary Official Statement or the Official Statement, including any amendments or supplements thereto; (o) Prior to the Closing, the City will not offer or issue any bonds, notes or other obligations for borrowed money or incur any material liabilities, direct or contingent, payable from or secured by any of the Non -Ad Valorem Revenues without the prior written approval of the Representative; (p) Any certificate, signed by any official of the City authorized to do so in connection with the transactions contemplated by this Agreement, shall be deemed a representation and warranty by the City to the Underwriters as to the statements made therein; (q) Except as expressly disclosed in the Official Statement, including any amendments or supplements thereto, the City has not been in default as to principal or interest with respect to an obligation issued or guaranteed by the City since December 31, 1975; (r) Subsequent to the respective dates as of which information is given in the Preliminary Official Statement and the Official Statement, including any amendments or supplements thereto, and prior to the Closing Date, except as expressly set forth in or contemplated by the Preliminary Official Statement and the Official Statement, including any amendments or supplements thereto, unless consented to in writing by the Underwriters, (i) the City has not incurred any material liabilities or obligations, direct or contingent, except in the ordinary course of business and as budgeted, and has not entered into and will not have entered into any material transaction not in the ordinary course of business and as budgeted, (ii) there has not been and will not have been any material adverse change in the business or financial position or results of operations of the City, (iii) no loss or damage (whether or not insured) to the property of the City has been or will have been sustained which materially and adversely affects the operations of the City, and (iv) no legal or governmental proceedings affecting the City or the transactions contemplated by this Agreement have been or will have been instituted or threatened which is material. 6. Closing. (a) At 10:00 a.m. Eastern Daylight Time, on [CLOSING DATE], 2023, or at such other time and date as shall have been mutually agreed upon by the City and the Representative (the "Closing" or the "Closing Date"), the City will, subject to the terms and conditions hereof, deliver the Series 2023 Bonds to the Underwriters as provided in (b) below, duly executed and authenticated, together with the other documents hereinafter mentioned, and the Underwriters will, subject to the terms and conditions hereof, accept such delivery and pay the purchase price of the Series 2023 Bonds as set forth in Section 1 of this Agreement by a wire transfer payable in immediately available funds to the order of the City. Payment for the Series 2023 Bonds as aforesaid shall be made at the offices of City, or such other place as shall have been mutually agreed upon by the City and the Representative. 12 (b) Delivery of the Series 2023 Bonds shall be made to DTC, New York, New York through its FAST system of registration. The Series 2023 Bonds shall be delivered in definitive fully registered form, bearing CUSIP numbers, with one Bond for each maturity of the Series 2023 Bonds, registered in the name of Cede & Co., all as provided in the Resolution, and shall be made available to the Representative at least one (1) business day before the Closing for purposes of inspection. 7. Closing Conditions. The Underwriters have entered into this Agreement in reliance upon the representations, warranties and agreements of the City contained herein, and in reliance upon the representations, warranties and agreements to be contained in the documents and instruments to be delivered at the Closing and upon the performance by the City of its obligations hereunder, both as of the date hereof and as of the date of the Closing. Accordingly, the Underwriters' obligations under this Agreement to purchase, to accept delivery of and to pay for the Series 2023 Bonds shall be conditioned upon the performance by the City of its obligations to be performed hereunder and under such documents and instruments at or prior to the Closing, and shall also be subject to the following additional conditions, including the delivery by the City of such documents as are enumerated herein, in form and substance reasonably satisfactory to the Representative: (a) The representations and warranties of the City contained herein shall be true, complete and correct on the date hereof and on and as of the date of the Closing, as if made on the Closing Date; (b) The City shall have performed and complied with all agreements and conditions required by this Agreement to be performed or complied with by it prior to or at the Closing; (c) At the time of the Closing, (i) the City Documents and the Series 2023 Bonds shall be in full force and effect in the form heretofore approved by the Representative and shall not have been amended, modified or supplemented, and the Official Statement shall not have been supplemented or amended, except in any such case as may have been agreed to by the Representative; (ii) all actions of the City required to be taken by the City shall be performed in order for Bond Counsel and other counsel to deliver their respective opinions referred to hereafter; (d) At or prior to the Closing, the Resolution shall have been duly adopted and in full force and effect by the City and the City shall have duly executed and delivered the Series 2023 Bonds to the Registrar, and the Registrar shall have duly authenticated the Series 2023 Bonds; (e) The City shall not have failed to pay principal or interest when due on any of its outstanding obligations for borrowed money; (f) All instruments and other documents to be executed, and all other legal matters in connection with the transactions contemplated by this Agreement shall be reasonably satisfactory in legal form and effect to the Representative; and (g) At or prior to the Closing, the Underwriters shall have received copies of each of the following documents: 13 (1) The Official Statement, and each supplement or amendment thereto, if any, executed on behalf of the City by its City Manager, Chief Financial Officer, and the Finance Director, or such other official as may have been authorized by the Resolution and agreed to by the Representative, and the reports and audits referred to or appearing in the Official Statement; (2) The Resolution; (3) Fully executed counterparts of the City Documents; (4) A final approving opinion of Squire Patton Boggs (US) LLP ("Bond Counsel"), with respect to the Series 2023 Bonds, dated the Closing Date, in substantially the form attached to the Official Statement as Appendix D; (5) A letter of Bond Counsel, addressed to the Underwriters and dated the Closing Date, to the effect that their final approving opinion referred to in Section 7(g)(4) hereof may be relied upon by the Underwriters to the same extent as if such opinion were addressed to the Underwriters; (6) A supplemental opinion of Bond Counsel, addressed to the Underwriters, dated the Closing Date, substantially to the effect that: (i) the statements contained in the Preliminary Official Statement and the Official Statement under the sections "INTRODUCTION" (paragraphs three through seven thereof), "DESCRIPTION OF THE SERIES 2023 BONDS" (except for "Book -Entry Only System") and "SECURITY AND SOURCES OF PAYMENT FOR THE SERIES 2023 BONDS" are accurate and insofar as such statements purport to summarize certain provisions of the Resolution and the Series 2023 Bonds, such statements are accurate summaries of the provisions purported to be summarized, and the information contained in the Official Statement under the section captioned "TAX MATTERS" is accurate; and (ii) the Series 2023 Bonds are not subject to the registration requirements of the Securities Act of 1933, as amended, and the Resolution is exempt from qualification under the Trust Indenture Act of 1939, as amended; (7) An opinion of Bryant Miller Olive P.A., as Disclosure Counsel, dated the Closing Date and addressed to the City, in substantially the form attached hereto as Exhibit B, together with a reliance letter thereon addressed to the Underwriters; (8) An opinion of the City Attorney, addressed to the City, Bond Counsel, Disclosure Counsel and the Underwriters and dated the Closing Date, in substantially the form attached hereto as Exhibit C; (9) A certificate, dated the Closing Date, signed by the City Manager, the Chief Financial Officer, the Finance Director of the City, or such other officials as authorized by the Resolution and satisfactory to the Underwriters, and in form and substance satisfactory to the Underwriters, to the effect that the information contained in the Preliminary Official 14 Statement and the Official Statement, including any amendments or supplements thereto (other than the information concerning DTC or its book -entry system of registration and information provided by the Underwriters in the Section entitled "UNDERWRITING") do not contain any untrue statement of a material fact or omit to state any material fact required to be stated therein or necessary to make the statements therein, in light of the circumstances under which made, not misleading, and the representations and warranties of the City contained herein are true and correct in all material respects on and as of the Closing Date as if made on the Closing Date; (10) A certificate of the City in form and substance satisfactory to Bond Counsel and counsel to the Underwriters (i) setting forth the facts, estimates and circumstances in existence on the Closing Date, which establish that the proceeds of the Tax -Exempt Series 2023 Bonds will not be used in a manner that would cause the Tax -Exempt Series 2023 Bonds to be "arbitrage bonds" within the meaning of Section 148 of the Internal Revenue Code of 1986, as amended (the "Code"), and any applicable regulations (whether final, temporary or proposed), issued pursuant to the Code, and (ii) certifying that there are no other facts, estimates or circumstances that would materially change the conclusions, representations and expectations contained in such certificate; (11) A certificate of an authorized representative of the Bank to the effect that (i) the Bank is a national banking association duly organized, validly existing and in good standing under the law of the United States of America and is duly authorized to exercise trust powers in the State of Florida, (ii) the Bank has all requisite authority, power, licenses, permits and franchises, and has full corporate power and legal authority to execute and perform its functions under the Resolution and the Paying Agent Agreement, (iii) the performance by the Bank of its functions under the Resolution and the Paying Agent Agreement will not result in any violation of the Articles of Association or Bylaws of the Bank, any court order to which the Bank is subject or any agreement, indenture or other obligation or instrument to which the Bank is a party or by which the Bank is bound, and no approval or other action by any governmental authority or agency having supervisory authority over the Bank is required to be obtained by the Bank in order to perform its functions under the Resolution and the Paying Agent Agreement, (iv) the Paying Agent Agreement constitutes a valid and binding obligation of the Bank in accordance with its terms, subject to applicable bankruptcy, insolvency, reorganization, moratorium and other similar laws affecting creditors' rights generally and subject, as to enforceability, to general principles of equity and (v) to the best of such authorized representative's knowledge, there is no action, suit, proceeding or investigation at law or in equity before any court, public board or body pending or, to his or her knowledge, threatened against or affecting the Bank wherein an unfavorable decision, ruling or finding on an issue raised by any party thereto is likely to materially and adversely affect the ability of the Bank to perform its obligations under the Resolution and the Paying Agent Agreement; (12) A letter of Greenberg Traurig, P.A., counsel to the Underwriters dated the Closing Date, in substantially the form attached hereto as Exhibit D; (13) A copy of the signed letter of representations from the City to DTC; 15 (14) A certificate of the City Manager, the Chief Financial Officer, or the Finance Director of the City deeming the Preliminary Official Statement and any supplement or amendment thereto "final" as of its date for the purposes of the Rule; (15) A letter of [Moody's Investor's Service] that the Series 2023 Bonds have [an underlying] rating of "[ ]," and a letter of [Fitch Ratings] that the Series 2023 Bonds have [an underlying] rating of "[ ]" and that all such ratings are in effect as of the Closing Date [and a letter of the Insurer that the Series 2023 Bonds (maturing in the years 201 ]-20[ ]) (the "Insured Bonds") have an insured rating of "[ ]" by [S&P Global Ratings] and that such rating is in effect as of the Closing Date]; (16) [A bond insurance policy issued by the Bond Insurer guaranteeing the payment of principal of and interest on the Insured Bonds (the "Bond Insurance Policy"), when due, in substantially the form attached to the Official Statement]; (17) [An opinion of counsel to the Bond Insurer addressed to the City and the Underwriters, as to the enforceability of the Bond Insurance Policy]; (18) [A closing certificate of the Bond Insurer, satisfactory in form and substance to the Representative, executed by an authorized officer of the Bond Insurer]; and (19) Such additional legal opinions, certificates, instruments and other documents as the Representative or counsel to the Underwriters, the City, Bond Counsel, Disclosure Counsel, or the City's Financial Advisor may reasonably request to evidence the truth and accuracy, as of the date hereof and as of the Closing Date, of the City's representations and warranties contained herein and of the statements and information contained in the Preliminary Official Statement and the Official Statement, including any amendments or supplements thereto, and the due performance or satisfaction by the City on or prior to the Closing Date of all the respective agreements then to be performed and conditions then to be satisfied by the City. [Additional closing deliverables may be added based on a more detailed review of the Resolution and POS.] If the City shall be unable to satisfy the conditions to the obligations of the Underwriters to purchase, to accept delivery of and to pay for the Series 2023 Bonds contained in this Agreement, or if the obligations of the Underwriters to purchase, to accept delivery of and to pay for the Series 2023 Bonds shall not be satisfied or shall be terminated for any reason permitted by this Agreement, this Agreement shall terminate and neither the Underwriters, nor the City shall be under any further obligation hereunder, except that the respective obligations of the City and the Underwriters set forth in Section 1 (with respect to the return of the Good Faith Check only) and 8 hereof shall continue in full force and effect. 8. Termination. The Underwriters shall have the right to cancel their obligation to purchase the Series 2023 Bonds if, between the date of this Agreement and the Closing by written notice to the City if, in the sole and reasonable judgment of the Representative, any of the following events shall occur on or after the date of this Agreement: 16 (a) the market price or marketability of the Series 2023 Bonds, or the ability of the Underwriters to enforce contracts for the sale of the Series 2023 Bonds, shall be materially adversely affected by any of the following events: (i) legislation shall have been enacted by the Congress of the United States or the legislature of the State or shall have been favorably reported out of committee of either body or be pending in committee of either body, or shall have been recommended to the Congress for passage by the President of the United States or a member of the President's Cabinet, or a decision shall have been rendered by a court of the United States or the State or the Tax Court of the United States, or a ruling, resolution, regulation or temporary regulation, release or announcement shall have been made or shall have been proposed to be made by the Treasury Department of the United States or the Internal Revenue Service, or other federal or state authority with appropriate jurisdiction, with respect to federal or state taxation upon interest received on obligations of the general character of the Securities; or (ii) there shall have occurred (1) an outbreak or escalation of hostilities or the declaration by the United States of a national emergency or war, (2) any other calamity or crisis in the financial markets of the United States or elsewhere, (3) the sovereign debt rating of the United States is downgraded by any major credit rating agency or a payment default occurs on United States Treasury obligations, or (4) a default with respect to the debt obligations of, or the institution of proceedings under any federal bankruptcy laws by or against, the State of Florida or the City; or (iii) a general suspension of trading on the New York Stock Exchange or other major exchange shall be in force, or minimum or maximum prices for trading shall have been fixed and be in force, or maximum ranges for prices for securities shall have been required and be in force on any such exchange, whether by virtue of determination by that exchange or by order of the Securities and Exchange Commission ("SEC") or any other governmental authority having jurisdiction; or (iv) legislation shall have been enacted by the Congress of the United States or shall have been favorably reported out of committee or be pending in committee, or shall have been recommended to the Congress for passage by the President of the United States or a member of the President's Cabinet, or a decision by a court of the United States shall be rendered, or a ruling, regulation, proposed regulation or statement by or on behalf of the SEC or other governmental agency having jurisdiction of the subject matter shall be made, to the effect that any obligations of the general character of the Series 2023 Bonds, the Resolution or the City Documents, or any comparable securities of the City, are not exempt from the registration, qualification or other requirements of the Securities Act or the Trust Indenture Act or otherwise, or would be in violation of any provision of the federal securities laws; or (v) except as disclosed in or contemplated by the Official Statement, as amended or supplemented, any material adverse change in the financial affairs of the City shall have occurred; or 17 (vi) any downward rating on securities of the City which are secured by a pledge or application of the Non -Ad Valorem Revenues; or (b) any event or circumstance shall exist that either makes untrue or incorrect any statement of a material fact or information in the Official Statement (other than any statement provided by the Underwriters in the section entitled, "UNDERWRITING") or is not reflected in the Official Statement but should be reflected therein in order to make the statements therein, in the light of the circumstances under which they were made, not misleading and, in either such event, the City refuses to permit the Official Statement to be supplemented to supply such statement or information, or the effect of the Official Statement as so supplemented is to materially adversely affect the market price or marketability of the Series 2023 Bonds or the ability of the Underwriters to enforce contracts for the sale of the Series 2023 Bonds; or (c) a general banking moratorium shall have been declared by federal or State authorities having jurisdiction and be in force; or (d) a material disruption in securities settlement, payment or clearance services affecting the Series 2023 Bonds shall have occurred; or (c) any new restriction on transactions in securities materially affecting the market for securities (including the imposition of any limitation on interest rates) or the extension of credit by, or a charge to the net capital requirements of, underwriters shall have been established by the New York Stock Exchange, the SEC, any other federal or State agency or the Congress of the United States, or by Executive Order; or (e) a decision by a court of the United States shall be rendered, or a stop order, release, regulation or no -action letter by or on behalf of the SEC or any other governmental agency having jurisdiction of the subject matter shall have been issued or made, to the effect that the issuance, offering or sale of the Series 2023 Bonds, including the underlying obligations as contemplated by this Agreement or by the Official Statement, as amended or supplemented, or any document relating to the issuance, offering or sale of the Series 2023 Bonds, is or would be in violation of any provision of the federal securities laws at the Closing Date, including the Securities Act, the Exchange Act and the Trust Indenture Act; or (f) any state Blue Sky or securities commission or other governmental agency or body shall have withheld registration, exemption or clearance of the offering of the Series 2023 Bonds as described herein, or issued a stop order or similar ruling relating thereto; or (g) the purchase of and payment for the Series 2023 Bonds by the Underwriters, or the resale of the Series 2023 Bonds by the Underwriters, on the terms and conditions herein provided shall be prohibited by any applicable law, governmental authority, board, agency or commission, other than with respect to state Blue Sky laws. Upon the occurrence of a Termination Event and the termination of this Agreement by the Underwriters, all obligations of the City and the Underwriters under this Agreement shall terminate, without further liability, except that: (i) the City, promptly shall return the Good Faith Deposit to the Representative, in accordance with Section 1 of this Agreement, and (ii) the City and the Underwriters shall pay their respective expenses as set forth in Section 9 below. 18 9. Expenses. (a) The Underwriters shall be under no obligation to pay, and the City shall pay all expenses incident to the performance of the City's obligations hereunder, including, but not limited to (i) the cost of preparation and printing of the Series 2023 Bonds, the Preliminary Official Statement and the Official Statement, including any amendments or supplements thereto, (ii) the fees and disbursements of Bond Counsel, City Attorney, and Disclosure Counsel, if any; (iii) the fees and disbursements of PFM Financial Advisors LLC (the "Financial Advisor"); (iv) the fees and disbursements of any Registrar, Paying Agent or engineers, accountants, and other experts, consultants or advisers retained by the City, if any; (v) all fees, [premiums] and expenses in connection with obtaining bond ratings [and bond insurance]; and (vi) any expenses (included in the expense component of the Underwriters' discount) incurred by the Underwriters on behalf of the City's employees and representatives for: (a) normal travel costs, including reasonable transportation and lodging; and (b) ordinary and reasonable meals hosted by the Underwriters that are, in both cases, directly related to the offering contemplated by this Agreement. (b) Except as provided for above, the Underwriters shall pay (i) the cost of preparation and printing of this Agreement, or any Blue Sky Surveys; (ii) all advertising expenses in connection with the public offering of the Series 2023 Bonds; and (iii) all other expenses incurred by them in connection with the public offering of the Series 2023 Bonds, including the fees and disbursements of counsel retained by the Underwriters. In the event that either party shall have paid obligations of the other as set forth in this Section 9, adjustment shall be made at the time of the Closing. 10. Notices. Any notice or other communication to be given to the City under this Agreement may be given by delivering the same in writing to City of Miami, Florida, 444 S.W. 2nd Avenue, Miami, Florida 33130, to the attention of the Finance Director of the City, and any notice or other communication to be given to the Underwriters under this Agreement may be given by delivering the same in writing to Jefferies LLC, 200 S. Orange Avenue, Suite 1440, Orlando, Florida 32801, Attention: Mr. Rawn N. Williams. 11. Parties in Interest. This Agreement may not be assigned by the City or the Underwriters unless the City has provided prior written consent and only if legally permitted by the City's procurement rules. This Agreement as heretofore specified shall constitute the entire agreement between us and is made solely for the benefit of the City and the Underwriters (including successors or assigns of the Underwriters, if any, as if prior written consent has been provided in writing by the City and if legally permitted by the City's procurement rules) and no other person shall acquire or have any right hereunder or by virtue hereof. All of the City's and Underwriters' representations, warranties and agreements contained in this Agreement shall remain operative and in full force and effect, regardless of (i) delivery of and payment for the Series 2023 Bonds pursuant to this Agreement; and (ii) any termination of this Agreement. 12. Effectiveness. This Agreement shall become effective upon the acceptance hereof by the City and shall be valid and enforceable at the time of such acceptance. 13. Choice of Law. This Agreement shall be governed by and construed in accordance with the law of the State of Florida. 19 14. Severability. If any provision of this Agreement shall be held or deemed to be or shall, in fact, be invalid, inoperative or unenforceable as applied in any particular case in any jurisdiction or jurisdictions, or in all jurisdictions because it conflicts with any provisions of any Constitution, statute, rule of public policy, or any other reason, such circumstances shall not have the effect of rendering the provision in question invalid, inoperative or unenforceable in any other case or circumstance, or of rendering any other provision or provisions of this Agreement invalid, inoperative or unenforceable to any extent whatever. 15. Business Day. For purposes of this Agreement, "business day" means any day on which the New York Stock Exchange is open for trading. 16. Section Headings. Section headings have been inserted in this Agreement as a matter of convenience of reference only, and it is agreed that such section headings are not a part of this Agreement and will not be used in the interpretation of any provisions of this Agreement. 17. Counterparts. This Agreement may be executed in several counterparts each of which shall be regarded as an original (with the same effect as if the signatures thereto and hereto were upon the same document) and all of which shall constitute one and the same document. [Signature page to this Agreement immediately follows this page] 20 If you agree with the foregoing, please sign the Agreement and return it to the Underwriters. This Agreement shall become a binding agreement between you and the Underwriters when at least the counterpart of this letter shall have been signed by or on behalf of each of the parties hereto. Respectfully submitted, JEFFERIES LLC, as Representative of the Underwriters By: Rawn N. Williams, Managing Director S-2 ACCEPTANCE ACCEPTED at [a.m./p.m.] Eastern Daylight Time this day of , 2023. CITY OF NIIANII, FLORIDA (SEAL) By: Art Noriega V, City Manager By: Larry M. Spring, Jr., Chief Financial Officer By: Erica Paschal -Darling, Finance Director ATTEST: APPROVED as to Insurance Requirements: By: By: Todd H. Hannon, City Clerk Anne -Marie Sharp, Risk Management Director Signature Page — Bond Purchase Agreement S-2 SCHEDULE I SPAR AMOUNT A] CITY OF MIAMI, FLORIDA SPECIAL OBLIGATION NON -AD VALOREM REVENUE BONDS, SERIES 2023A (NEW ADMINISTRATIVE BUILDING) Maturity Initial Rate Rate Determination Interest Rate Determination Initial Interest Date Mode Date Generally Payment Date Optional Redemption ITo Be Confirmed] The Series 2023A Bonds maturing on or prior to March 1, 201 ] are not redeemable prior to their respective dates of maturity. The Series 2023A Bonds maturing on March 1, 201 ] are subject to redemption at the option of the City on or after March 1, 201 ], in whole or in part at any time, and if part, only in amounts such that the unredeemed portion of the Series 2023A Bonds are in an Authorized Denomination, in such manner as shall be determined by the Bond Registrar, at a redemption price equal to the par amount thereof plus accrued interest to the date fixed for redemption. Mandatory Sinking Fund Redemption iTo Be Confirmed] Schedule I-1 $[PAR AMOUNT B] CITY OF MIAMI, FLORIDA SPECIAL OBLIGATION NON -AD VALOREM REVENUE BONDS, SERIES 2023B (NEW ADMINISTRATIVE BUILDING) MATURITIES, PRINCIPAL AMOUNTS, INTEREST RATES, YIELDS, AND PRICES Maturity Principal (March 1) Amount Interest Rate Yield Price *Callable premium bonds. Yield calculated to first optional redemption date of March 1, 201 ]. Optional Redemption [To Be Confirmed] The Series 2023B Bonds maturing on or prior to March 1, 201 ] are not redeemable prior to their respective dates of maturity. The Series 2023B Bonds maturing on March 1, 20F ] are subject to redemption at the option of the City on or after March 1, 201 ], in whole or in part at any time, and if part, only in amounts such that the unredeemed portion of the Series 2023B Bonds are in an Authorized Denomination, in such manner as shall be determined by the Bond Registrar, at a redemption price equal to the par amount thereof plus accrued interest to the date fixed for redemption. Schedule I-2 Mandatory Sinking Fund Redemption [To Be Confirmed] The Series 2023B Bonds maturing on March 1, 20i 1 will be subject to mandatory redemption prior to maturity, by lot, in such manner as the Bond Registrar may deem appropriate, at a redemption price equal to par plus accrued interest to the redemption date, on March 1, 201 1 and on each March 1 thereafter, from moneys deposited in the Debt Service Account, in the following Amortization Requirements in the years specified. Due (March 1) * *Final Maturity Amortization Requirements Schedule I-3 WAR AMOUNT Cl CITY OF MIAMI, FLORIDA TAXABLE SPECIAL OBLIGATION NON -AD VALOREM REVENUE BONDS, SERIES 2023C MATURITIES, PRINCIPAL AMOUNTS, INTEREST RATES, YIELDS, AND PRICES Maturity Principal March 1) Amount Interest Rate Yield Price *Callable premium bonds. Yield calculated to first optional redemption date of March 1, 201 ]. Optional Redemption/Make Whole Optional Redemption [To Be Confirmed] The Series 2023C Bonds maturing on or prior to March 1, 20[] are not redeemable prior to their respective dates of maturity. The Series 2023C Bonds maturing on March 1, 201 ] are subject to redemption at the option of the City on or after March 1, 201 ], in whole or in part at any time, and if part, only in amounts such that the unredeemed portion of the Series 2023C Bonds are in an Authorized Denomination, in such manner as shall be determined by the Bond Registrar, at a redemption price equal to the par amount thereof plus accrued interest to the date fixed for redemption. Schedule I-4 Mandatory Sinking Fund Redemption [To Be Confirmed] The Series 2023C Bonds maturing on March 1, 201 ] will be subject to mandatory redemption prior to maturity, by lot, in such manner as the Bond Registrar may deem appropriate, at a redemption price equal to par plus accrued interest to the redemption date, on March 1, 201 ] and on each March 1 thereafter, from moneys deposited in the Debt Service Account, in the following Amortization Requirements in the years specified. Due (March 1) *Final Maturity Amortization Requirements Reserve Account Requirement for the Series 2023 Bonds [To Be Confirmed] The Resolution requires the City to maintain on deposit in the Debt Service Reserve Account an amount equal to the Reserve Account Requirement. [The Reserve Account Requirement means, with respect to each series of Series 2023 Bonds, the amount to be determined by the City Manager as the Reserve Account Requirement for such series of the Series 2023 Bonds and set forth in the Bond Purchase Contract, which amount may be $0, subject to any restrictions set forth in the Tax Compliance Certificate with respect to any Tax -Exempt Bonds.] The Resolution requires the establishment of a Debt Service Reserve Account to be funded in an amount equal to the Reserve Account Requirement. After the issuance of the Series 2023 Bonds the Debt Service Reserve Account will be fully funded in the amount of $[ ]. [Signature Page Follows] Schedule I-5 Certification of the Pricing Provisions and Other Determinations I, Art Noriega V, City Manager of the City of Miami, Florida do hereby certify that the pricing provisions and other determinations contained in the Bond Purchase Agreement and in this Schedule I have been approved in accordance with and in satisfaction of the provisions of the Resolution. CITY OF MIAMI, FLORIDA a municipal corporation of the State of Florida By: Art Noriega V, City Manager Signature Page — Schedule I Schedule I-6 SCHEDULE II DISCLOSURE STATEMENT AND TRUTH -IN -BONDING STATEMENT [SALE DATE], 2023 Mayor and City Commission of the City of Miami, Florida Miami, Florida Re: $[PAR AMOUNT A] Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023A (New Administrative Building) $[PAR AMOUNT B] Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023B (New Administrative Building) $[PAR AMOUNT C] Taxable Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023B (New Administrative Building) Dear Mayor and Commission Members: In connection with the proposed issuance by the City of Miami, Florida (the "City") of $[PAR AMOUNT A] in aggregate principal amount of its Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023A (New Administrative Building) (the "Series 2023A Bonds"), $[PAR AMOUNT B] in aggregate principal amount of its Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023B (New Administrative Building) (the "Series 2023B Bonds") and $[PAR AMOUNT C] in aggregate principal amount of its Taxable Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023B (the "Series 2023C Bonds" and, together with the Series 2023A Bonds and the Series 2023B Bonds, the "Series 2023 Bonds"), Jefferies LLC, on behalf of itself, BofA Securities, Inc., Estrada Hinojosa & Company, Inc., Siebert Williams Shank & Co., LLC and Wells Fargo Bank, N.A. (collectively, the "Underwriters") is underwriting a public offering of the Series 2023 Bonds. The purpose of the following six paragraphs of this letter is to furnish, pursuant to the provisions of Section 218.385(6), Florida Statutes, as amended, certain information in respect of the arrangements contemplated for the purchase and sale of the Series 2023 Bonds, as follows: (a) The nature and estimated amount of expenses to be incurred by the Underwriters in connection with the purchase and re -offering of the Series 2023 Bonds are set forth in Attachment 1 attached hereto. (b) There are no "finders," as defined in Section 218.386, Florida Statutes, as amended, connected with the sale and purchase of the Series 2023 Bonds. Schedule II-1 (c) The underwriting spread, the difference between the price at which the Series 2023 Bonds will be initially offered by the Underwriters and the price to be paid to the City will be $[ ] per $1,000 of Series 2023A Bonds issued, $[ ] per $1,000 of Series 2023B Bonds issued and $[ ] per $1,000 of Series 2023C Bonds issued. (d) As part of the estimated underwriting spread set forth in paragraph (c) above, the Underwriters will charge a management fee of $0.00 per $1,000 of Series 2023 Bonds issued. (e) No other fee, bonus or other compensation is estimated to be paid by the Underwriters in connection with the issuance of the Series 2023 Bonds to any person not regularly employed or retained by the Underwriters (including any "finder" as defined in Section 218.386(1)(a), Florida Statutes), except as specifically enumerated as expenses to be incurred by the Underwriters, as set forth in paragraph (a) above. The fees and expenses of Greenberg Traurig, P.A., Underwriter's counsel, and all other expenses are being paid by the Underwriters. (f) The names and addresses of the Underwriters are: Jefferies LLC 200 S. Orange Avenue, Suite 1440 Orlando, Florida 32801 BofA Securities, Inc. 250 S. Park Avenue, Suite 400 Winter Park, Florida 32789 Estrada Hinojosa & Company, Inc. 55 Merrick Way, Suite 216 Coral Gables, Florida 33134 Siebert Williams Shank & Co., LLC 1025 Connecticut Ave, NW, Suite 509 Washington, DC 20036 Wells Fargo Bank, N.A. 100 South Ashley Drive loth Floor Tampa, FL 33602 The purpose of the following paragraphs is to furnish, pursuant to the provisions of Sections 218.385(2) and (3), Florida Statutes, as amended, the truth -in -bonding statement required thereby, as follows: (a) The City is proposing to issue $[PAR AMOUNT A] of the Series 2023A Bonds for the purpose of, together with other available moneys, (i) paying the costs of developing, constructing and equipping a new City administration building, along with related parking and other related improvements (including the payment of interest on the Series 2023 Bonds during construction), (ii) [funding a deposit to the Debt Service Reserve Account or pay the premium for a Reserve Account Insurance Policy], and (iii) paying certain costs of issuance of the Series 2023 Schedule II-2 Bonds[, including payment of a municipal bond insurance policy premium to [INSURER]. The Series 2023A Bonds are expected to be repaid over a period of approximately [ ] years. At a true interest cost of approximately [ ]%, total interest paid over the life of the Series 2023A Bonds will be $[ ]. (b) The City is proposing to issue $[PAR AMOUNT B] of the Series 2023B Bonds for the purpose of, together with other available moneys, (i) paying the costs of developing, constructing and equipping a new City administration building, along with related parking and other related improvements (including the payment of interest on the Series 2023B Bonds during construction), (ii) [funding a deposit to the Debt Service Reserve Account or pay the premium for a Reserve Account Insurance Policy], and (iii) paying certain costs of issuance of the Series 2023B Bonds[, including payment of a municipal bond insurance policy premium to [INSURER]. The Series 2023B Bonds are expected to be repaid over a period of approximately [ ] years and [ ] months. At a true interest cost of approximately [ ]%, total interest paid over the life of the Series 2023B Bonds will be [ ]. (c) The City is proposing to issue $[PAR AMOUNT C] of the Series 2023C Bonds for the purpose of, together with other available moneys, (i) paying the costs of the acquisition and implementation of the Oracle Enterprise Resource Planning Cloud System, (ii) [funding a deposit to the Debt Service Reserve Account or pay the premium for a Reserve Account Insurance Policy], and (iii) paying certain costs of issuance of the Series 2023C Bonds[, including payment of a municipal bond insurance policy premium to [INSURER]. The Series 2023C Bonds are expected to be repaid over a period of approximately [ ] years and [ ] months. At a true interest cost of approximately [ ]%, total interest paid over the life of the Series 2023C Bonds will be [ ]. (d) The source of repayment or security of the Series 2023 Bonds is the Pledged Funds, consisting of all moneys, securities and instruments held in the Funds and Accounts created and established under the Resolution for the Series 2023 Bonds, including, solely to the extent provided in the Resolution for the Series 2023 Bonds, the Non -Ad Valorem Revenues budgeted and appropriated by the City in its annual budget and deposited into the Sinking Fund, as described in the Official Statement for the Series 2023 Bonds. Authorizing this debt will result in an average of $[ ] (average annual debt service) for the Series 2023A Bonds of such Non -Ad Valorem Revenues not being available to finance other services of the City each year for approximately [ ] years and [ ] months, an average of $[ ] (average annual debt service) for the Series 2023B Bonds of such Non -Ad Valorem Revenues not being available to finance other services of the City each year for approximately [ ] years and [ ] months and an average of $[ ] (average annual debt service) for the Series 2023C Bonds of such Non - Ad Valorem Revenues not being available to finance other services of the City each year for approximately [ ] years and [ ] months. [Signature Page Follows] Schedule II-3 The foregoing is provided for information purposes only and shall not affect or control the actual terms and conditions of the Series 2023 Bonds. Very truly yours, JEFFERIES LLC as Representative of the Underwriters Rawn N. Williams Managing Director Signature Page — Schedule II Schedule II-4 ATTACHMENT 1 Underwriters' Estimated Expenses Series 2023A Bonds Amount $/1,000 Average Takedown Underwriters' Counsel CUSIP Fee Day Loan iPreo iPreo Electronic Order Viewing DTC Out -of -Pocket Expenses $ Total $ Series 2023B Bonds Amount $/1,000 Average Takedown Underwriters' Counsel CUSIP Fee Day Loan iPreo iPreo Electronic Order Viewing DTC Out -of -Pocket Expenses $ Total $ Series 2023C Bonds Amount $/1,000 Average Takedown Underwriters' Counsel CUSIP Fee Day Loan iPreo iPreo Electronic Order Viewing DTC Out -of -Pocket Expenses $ Total $ Schedule II-5 EXHIBIT A FORM OF ISSUE PRICE CERTIFICATE $[PAR AMOUNT A] CITY OF MIAMI, FLORIDA SPECIAL OBLIGATION NON -AD VALOREM REVENUE BONDS, SERIES 2023A (NEW ADMINISTRATIVE BUILDING) $[PAR AMOUNT B] CITY OF MIAMI, FLORIDA SPECIAL OBLIGATION NON -AD VALOREM REVENUE BONDS, SERIES 2023B (NEW ADMINISTRATIVE BUILDING) The undersigned, on behalf of Jefferies LLC (the "Representative"), on behalf of itself and BofA Securities, Inc., Estrada Hinojosa & Company, Inc., Siebert Williams Shank & Co., LLC and Wells Fargo Bank, N.A. (collectively, with the Representative, the "Underwriting Group") for the bonds identified above (the "Issue"), issued by City of Miami, Florida (the "Issuer"), based on its knowledge regarding the sale of the Issue, certifies as of this date as follows. (1) Issue Price. [If the issue price is determined using only the general rule (actual sales of at least 10%) in Regulations § 1.148-1(f)(2)(i): (A) As of the date of this Certificate, for each Maturity of the Issue, the first price at which at least 10% of such Maturity of the Issue was sold to the Public is the respective price listed in the final Official Statement, dated [SALE DATE], 2023, for the Issue (the "Sale Price" as applicable to respective Maturities). The aggregate of the Sale Prices of each Maturity is $ (the "Issue Price").] [If the issue price is determined using a combination of actual sales (Regulations § 1.148- 1(f)(2)(i)) and hold -the -offering -price (Regulations § 1.148-1(f)(2)(ii)): (A) As of the date of this Certificate, for each Maturity listed on Schedule I as the "General Rule Maturities," the first price at which at least 10% of such Maturity was sold to the Public is the respective price listed in Schedule I (the "Sale Price" as applicable to each Maturity of the General Rule Maturities). (B) On or before the Sale Date, the Underwriting Group offered the Maturities listed on Schedule I as the "Hold -the -Offering -Price Maturities" to the Public for purchase at the respective initial offering prices listed in Schedule I (the "Initial Offering Prices" as applicable to each Maturity of the Hold -the -Offering -Price Maturities). A copy of the pricing wire or equivalent communication for the Issue is attached to this Certificate as Schedule II. (C) As set forth in the Bond Purchase Agreement, dated [SALE DATE], 2023, between the Issuer and the members of the Underwriting Group, the members of the Underwriting Group have agreed in writing that, (i) for each Maturity of the Hold -the -Offering - Price Maturities, they would neither offer nor sell any portion of such Maturity to any person at a price that is higher than the Initial Offering Price for such Maturity during the Holding Period for such Maturity (the "hold -the -offering -price rule"), and (ii) any selling group agreement shall contain the agreement of each dealer who is a member of the selling group, and any third -party distribution agreement shall contain the agreement of each broker -dealer who is a party to the third -party distribution agreement, to comply with the hold -the -offering -price rule. Pursuant to A-1 such agreement, no Underwriter has offered or sold any Maturity of the Hold -the -Offering -Price Maturities at a price that is higher than the respective Initial Offering Price for that Maturity of the Issue during the Holding Period. (D) The aggregate of the Sale Prices of the General Rule Maturities and the Initial Offering Prices of the Hold -the -Offering -Price Maturities is $ (the "Issue Price").] [If the issue price is determined using only the hold -the -offering -price rule in Regulations § 1.148-1(f)(2)(ii): (A) The Underwriting Group offered, on or before the Sale Date, each Maturity of the Issue to the Public for purchase at the respective initial offering prices listed in the final Official Statement, dated [SALE DATE], 2023, for the Issue (the "Initial Offering Prices"). A copy of the pricing wire or equivalent communication for the Issue is attached to this Certificate as Schedule I. The aggregate of the Initial Offering Prices of each Maturity is $ (the "Issue Price"). (B) As set forth in the Bond Purchase Agreement, dated [SALE DATE], 2023, between the Issuer and the members of the Underwriting Group, the members of the Underwriting Group have agreed in writing that, (i) for each Maturity of the Issue, they would neither offer nor sell any portion of such Maturity to any person at a price that is higher than the Initial Offering Price for such Maturity during the Holding Period for such Maturity (the "hold - the -offering -price rule"), and (ii) any selling group agreement shall contain the agreement of each dealer who is a member of the selling group, and any third -party distribution agreement shall contain the agreement of each broker -dealer who is a party to the third -party distribution agreement, to comply with the hold -the -offering -price rule. Pursuant to such agreement, no Underwriter has offered or sold any Maturity of the Issue at a price that is higher than the respective Initial Offering Price for that Maturity of the Issue during the Holding Period.] [(B), (E), or (C)] Definitions. [NOTE: If issue price is determined using only the general rule (actual sales of 10%), delete the definitions of "Holding Period" and "Sale Date."] ["Holding Period" means, for each Hold -the -Offering -Price Maturity of the Issue, the period starting on the Sale Date and ending on the earlier of (i) the close of the fifth business day after the Sale Date ([SALE DATE], 2023), or (ii) the date on which the Underwriting Group has sold at least 10% of such Maturity of the Issue to the Public at a price that is no higher than the Initial Offering Price for such Maturity.] "Maturity" means bonds of the Issue with the same credit and payment terms. Bonds of the Issue with different maturity dates, or bonds of the Issue with the same maturity date but different stated interest rates, are treated as separate Maturities. "Public" means any person (including an individual, trust, estate, partnership, association, company, or corporation) other than an Underwriter or a related party to an Underwriter. The term "related party" for purposes of this Certificate generally means any two or more persons who have greater than 50 percent common ownership, directly or indirectly. ["Sale Date" means the first day on which there is a binding contract in writing for the sale of a Maturity of the Issue. The Sale Date of the Issue is [SALE DATE], 2023.] A-2 "Underwriter" means (i) any person that agrees pursuant to a written contract with the Issuer (or with the lead underwriter to form an underwriting syndicate) to participate in the initial sale of the Issue to the Public, and (ii) any person that agrees pursuant to a written contract directly or indirectly with a person described in clause (i) of this paragraph to participate in the initial sale of the Issue to the Public (including a member of a selling group or a party to a third - party distribution agreement participating in the initial sale of the Issue to the Public). All other capitalized terms not defined in this Certificate have the meaning set forth in the Issuer's Tax Compliance Certificate or in Attachment A to it. (2) Yield. The Yield on the Issue is %, being the discount rate that, when used in computing the present worth of all payments of principal and interest to be paid on the Issue, computed on the basis of a 360-day year and semi-annual compounding, produces an amount equal to the Issue Price of the Issue as stated in paragraph (1) [and computed with the adjustments stated in paragraphs (5) and (6)]. (3) Weighted Average Maturity. The weighted average maturity (defined below) of the Issue is years. The weighted average maturity of an issue is equal to the sum of the products of the issue price of each maturity of the issue and the number of years to the maturity date of the respective maturity (taking into account mandatory but not optional redemptions), divided by the issue price of the entire issue. (4) Underwriter's Discount. The Underwriter's discount is $ , being the amount by which the aggregate Issue Price (as set forth in paragraph (1)) exceeds the price paid by Underwriting Group to the Issuer for the Issue. [(5) Discount Maturities Subject to Mandatory Early Redemption. No Maturity that is subject to mandatory early redemption has a stated redemption price that exceeds the Sale Price or Initial Offering Price, as applicable, of such Maturity by more than one-fourth of 1% multiplied by the product of its stated redemption price at maturity and the number of years to its weighted average maturity date.] [Or] [(5) Discount Maturities Subject to Mandatory Early Redemption. The stated redemption price at maturity of the Maturities that mature in the year[s] 20 , which Maturities are the only Maturities of the Issue that are subject to mandatory early redemption [revise as appropriate], exceeds the Sale Price or Initial Offering Price, as applicable, of such Maturities by more than one-fourth of 1% multiplied by the product of the stated redemption price at maturity and the number of years to the weighted average maturity date of such Maturities. Accordingly, in computing the Yield on the Issue stated in paragraph (2), those Maturities were treated as redeemed on each mandatory early redemption date at their present value rather than at their stated principal amount.] [(6) Premium Maturities Subject to Optional Redemption. No Maturity: ❑ Is subject to optional redemption within five years of the Issuance Date of the Issue. ❑ That is subject to optional redemption has an Initial Offering Price or Sale Price, as applicable, that exceeds its stated redemption price at maturity by more than one-fourth of 1% multiplied by the product of its stated redemption price at maturity and the number of complete years to its first optional redemption date.] A-3 [Or] [(6) Premium Maturities Subject to Optional Redemption. The Maturities that mature in the year[s] 20 are the only Maturities that are subject to optional redemption before maturity and have an Initial Offering Price or Sale Price, as applicable, that exceeds their stated redemption price at maturity by more than one fourth of 1% multiplied by the product of their stated redemption price at maturity and the number of complete years to their first optional redemption date. Accordingly, in computing the Yield on the Issue stated in paragraph (2), each such Maturity was treated as retired on its optional redemption date or at maturity to result in the lowest yield on that Maturity. No Maturity is subject to optional redemption within five years of the Issuance Date of the Issue.] [Or] [(5) No Discount or Premium Maturities. No Maturity was sold at an original issue discount or premium.] [(6 or 7) No Stepped Coupon Maturities. No Maturity bears interest at an increasing interest rate.] A-4 The signer is an officer of the Representative and duly authorized to execute and deliver this Certificate for itself and as representative of the Underwriting Group. The representations set forth in this Certificate are limited to factual matters only. Nothing in this Certificate represents the Representative's interpretation of any laws, including specifically Sections 103 and 148 of the Internal Revenue Code of 1986, as amended, and the Treasury Regulations thereunder. The undersigned understands that the foregoing information will be relied upon by the Issuer with respect to certain of the representations set forth in the Tax Compliance Certificate and with respect to compliance with the federal income tax rules affecting the Issue, and by Squire Patton Boggs (US) LLP, as bond counsel, in connection with rendering its opinion that the interest on the Issue is excluded from gross income for federal income tax purposes, the preparation of the Internal Revenue Service Form 8038-G, and other federal income tax advice that it may give to the Issuer from time to time relating to the Issue. Except as expressly set forth above, the certifications set forth herein may not be relied upon or used by any third party or for any other purpose Dated: [CLOSING DATE], 2023 JEFFERIES LLC, for itself and as representative of BOFA SECURITIES, INC., ESTRADA HINOJOSA & COMPANY, INC., SIEBERT WILLIAMS SHANK & CO., LLC, and WELLS FARGO BANK, N.A. By: Rawn N. Williams Managing Director By: Roy Carlberg Title: A-5 [NOTE: If the general rule is used for each Maturity (i.e., actual sales of at least 10% of each Maturity), there is no schedule to attach if the initial offering prices set forth in the Official Statement for the Issue are the first prices at which at least 10% of each Maturity is sold. Otherwise, attach a schedule that shows the first price at which at least 10% of each Maturity was sold.] [EITHER] [If the issue price is determined using a combination of the general rule (actual sales) and hold -the -offering -price rule: SCHEDULE I SALE PRICES OF THE GENERAL RULE MATURITIES AND INITIAL OFFERING PRICES OF THE HOLD -THE -OFFERING -PRICE MATURITIES (Attached) [NOTE: With respect to each General Rule Maturity of the Issue whose Sale Price is not the Initial Offering Price, Schedule I should include each such Maturity's (i) maturity date, (ii) principal amount, (iii) coupon, and (iv) sale price (either as a stated amount, a percentage of a par, or as based on the yield of the Maturity). With respect to each Hold -the -Offering -Price Maturity of the Issue, each such Maturity should be referred to in Schedule I with reference to the final official statement for the Issue. For example, "The Hold -the -Offering Price Maturities are those Maturities of the Issue set forth on the [inside] cover of the final Official Statement, dated [SALE DATE], 2023, for the Issue that mature in the year[s] [ , , and ].,,i SCHEDULE II PRICING WIRE OR EQUIVALENT COMMUNICATION (Attached)] [OR] [If the issue price is determined using only the hold -the -offering -price rule in Regulations § 1.148-1(f)(2)(ii): SCHEDULE I PRICING WIRE OR EQUIVALENT COMMUNICATION (Attached) A-3 EXHIBIT B Form of Disclosure Counsel Opinion , 2023 City Commission of the City of Miami, Florida Miami, Florida RE: $ City of Miami, Florida Special Obligation Non -Ad Valorem Bonds, Series 2023A (New Administrative Building) $ City of Miami, Florida Special Obligation Non -Ad Valorem Bonds, Series 2023B (New Administrative Building) $ City of Miami, Florida Taxable Special Obligation Non -Ad Valorem Bonds, Series 2023C Ladies and Gentlemen: We have acted as Disclosure Counsel to the City of Miami, Florida (the "Issuer"), and not to any other person, in connection with the issuance of the above -referenced bonds (the "Series 2023 Bonds"). In providing the statement of belief set forth in the third succeeding paragraph, reference is made to the Official Statement, dated [SALE DATE], 2023 (the "Official Statement"). As Disclosure Counsel, we have reviewed the Official Statement and certain other documents and have participated in conferences in which the contents of the Official Statement and other matters were discussed. The purpose of our professional engagement was not to establish or to confirm factual matters set forth in the Official Statement, and we have not undertaken to verify independently any of such factual matters. To the extent our statement of belief set forth in the second succeeding paragraph relates to or is dependent upon the determination that (i) the proceedings and actions relating to the authorization, execution, issuance, delivery, and sale of the Series 2023 Bonds are lawful and valid under the Constitution and laws of the State of Florida Chapter 166, Part II, Florida Statutes and the Charter of the Issuer, and other applicable provisions of law, and pursuant to Resolution No. R- adopted by the City Commission of the Issuer on September [28], 2023 (the "Resolution"), (ii) the Series 2023 Bonds are valid and legally binding obligations of the Issuer enforceable in accordance with their terms, or (iii) interest on the Series 2023A Bonds and 2023B Bonds is excluded from the gross income of the owners of the Series 2023 Bonds for federal income tax purposes, or other tax consequences of owning the Series 2023 Bonds, we understand that you are relying upon the opinions delivered to you on the date hereof of Victoria Mendez, Esq., as Issuer's Counsel, and Squire Patton Boggs (US) LLP, as Bond Counsel, and, with B-1 your permission, we have assumed the accuracy of such opinions, have made no independent determination thereof, and no opinion is expressed herein as to such matters. In requesting and accepting this letter, you recognize and acknowledge that: (i) the scope of the activities performed by us described above were inherently limited and do not encompass all activities that you may be responsible for undertaking in preparing the Official Statement; (ii) such activities relied substantially on representations, warranties, certifications, and opinions made by your representatives and others, and are otherwise subject to the matters set forth in this letter; and (iii) while statements of negative assurance are customarily given to underwriters of municipal securities to assist them in discharging their responsibilities under the federal securities laws, the responsibilities of the issuer of such securities under those laws may differ from those of underwriters in material respects, and this letter may not serve the same purpose or provide the same utility to you as it would to an underwriter of the Series 2023 Bonds. Subject to the foregoing and on the basis of the information we gained in the course of performing the services referred to above, we confirm to you that no facts have come to the attention of the attorneys in our firm rendering legal services in connection with this matter that cause them to believe that the Official Statement as of its date or as of the date hereof, contains any untrue statement of a material fact or omits to state any material fact necessary to make the statements made therein, in the light of the circumstances under which they were made, not misleading; provided, however, we do not assume responsibility for the accuracy, completeness, or fairness of the statements contained in the Official Statement (including any appendices, schedules, and exhibits thereto), nor do we express any belief with respect to any demographic, financial, statistical and operating data, and forecasts, projections, numbers, estimates, assumptions, and expressions of opinion, and information concerning The Depository Trust Company and the book -entry system for the Series 2023 Bonds contained or incorporated by reference in the Official Statement (including any appendices, schedules, and exhibits thereto), which we expressly exclude from the scope of this paragraph. This letter is furnished by us solely for your benefit and may not be relied upon by any other person or entity. We disclaim any obligation to supplement this letter to reflect any facts or circumstances that may hereafter come to our attention or any changes in the law that may hereafter occur. Respectfully submitted, BRYANT MILLER OLIVE P.A. B-2 EXHIBIT C Form of Opinion of Counsel to the City [CLOSING DATE], 2023 The Honorable Mayor and City Commissioners of the City of Miami, Florida Squire Patton Boggs (US) LLP Tampa, Florida Jefferies LLC, as the Representative Orlando, Florida [Insurer New York, New York] Re: $[PAR AMOUNT A] Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023A (New Administrative Building) $[PAR AMOUNT B] Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023B (New Administrative Building) $[PAR AMOUNT C] Taxable Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023C Ladies and Gentlemen: I am the City Attorney for the City of Miami, Florida (the "City") and have served in such capacity since September, 2013. We are furnishing this opinion of Counsel to the City in connection with the issuance by the City of its aggregate principal amount of $[PAR AMOUNT A] Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023 (New Administrative Building), $[PAR AMOUNT B] Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023 (New Administrative Building) and $[PAR AMOUNT C] Taxable Special Obligation Non - Ad Valorem Revenue Bonds, Series 2023C (collectively, the "Series 2023 Bonds"). The Series 2023 Bonds are being issued by the City pursuant to and under the authority of the Constitution of the State of Florida (the "State"); Chapter 166, Part II. Florida Statutes, as amended; the Laws of the State, Ch. 30997 (1955) (the "Act"), the Charter of the City, as amended (the "Charter"); the Code of the City, as amended (the "City Code"), and applicable City resolutions, including (a) Resolution No. R-23-[ ], adopted by the City Commission of the City (the "City Commission") on September [ ], 2023 (the "Resolution"). The City is issuing the Series 2023A Bonds for the purpose of (i) paying the cost of developing, constructing and equipping a new City administration building, along with related parking and other related improvements (including the payment of interest on the Series 2023A Bonds during construction), (ii) [funding a deposit to the Debt Service Reserve Account or paying the premium for a Reserve Account Insurance Policy], and (iii) paying C-1 certain costs of issuance of the Series 2023 Bonds[, including payment of a municipal bond insurance policy premium to [ ] (the "Bond Insurer")]. The City is issuing the Series 2023B Bonds for the purpose of (i) paying the cost of developing, constructing and equipping a new City administration building, along with related parking and other related improvements (including the payment of interest on the Series 2023B Bonds during construction), (ii) [funding a deposit to the Debt Service Reserve Account or paying the premium for a Reserve Account Insurance Policy], and (iii) paying certain costs of issuance of the Series 2023B Bonds[, including payment of a municipal bond insurance policy premium to [ ] (the "Bond Insurer")]. The City is issuing the Series 2023C Bonds for the purpose of (i) paying the cost of the acquisition and implementation of the Oracle Enterprise Resource Planning Cloud System, (ii) [funding a deposit to the Debt Service Reserve Account or paying the premium for a Reserve Account Insurance Policy], and (iii) paying certain costs of issuance of the Series 2023 Bonds[, including payment of a municipal bond insurance policy premium to [ ] (the "Bond Insurer")], (b) the executing and delivering by the City of (t) a Bond Purchase Agreement, dated as of [SALE DATE], 2023 (the "Bond Purchase Agreement") with Jefferies LLC, as the representative (the "Representative") acting on its own behalf and on behalf of BofA Securities, Inc., Estrada Hinojosa & Company, Inc., Siebert Williams Shank & Co., LLC and Wells Fargo Bank, N.A. (collectively, the "Underwriters"), (r) a Paying Agent and Bond Registrar Agreement, by and between the City and U.S. Bank Trust Company, National Association for registrations and payments in connection with the Series 2023 Bonds ("Paying Agent Agreement"), (w) a Disclosure Dissemination Agent Agreement, by and between the City and Digital Assurance Certification, L.L.C., relating to the Series 2023 Bonds (the "Continuing Disclosure Agreement"), (x) a Preliminary Official Statement of the City dated [POS DATE], 2023 (the "Preliminary Official Statement"), (y) a final Official Statement of the City dated [SALE DATE], 2023 (the "Official Statement") [, and (z) an agreement with the Bond Insurer related to the bond insurance for certain designated maturities of the Series 2023 Bonds ("Bond Insurance Agreement")]. All terms used herein in capitalized form and not otherwise defined herein shall have the meanings ascribed thereto in the Resolution or the Bond Purchase Agreement. In connection with this opinion, the Office of the City Attorney has examined such documents, instruments, proceedings and public records of the City and made such inquiry of officials of the City as deemed necessary to render the requested opinion. In such examination, we have assumed the genuineness of all signatures on all documents (other than those of City officials), the authenticity of all documents submitted to us as originals, and the legal capacity of all natural persons executing documents, resolutions, certifications, reports and other items related to the issuance of the Series 2023 Bonds and the financing of the Project. Based on such participation, examination and matters of law as the Office of the City Attorney has determined relevant for the purposes of rendering this opinion, in reliance upon the advice and Opinions of Bond Counsel regarding federal and State tax matters, Disclosure Counsel regarding federal and State securities laws, and in reliance upon the certificates of the Representative, the Paying Agent's representatives, the Financial Advisor to the City, the Tax Certificate, the Continuing Disclosure Agreement, [the Bond Insurer's representatives,] and other certifications by City officials, and subject to the reservations set forth herein, I am of the opinion that: C-2 1. The City is a municipal corporation, duly created and validly existing under the Constitution and laws of the State and has full legal right, power and authority to adopt, authorize, execute, deliver and perform its obligations under the Series 2023 Bonds, the Bond Purchase Agreement, [the Bond Insurance Agreement,] the Paying Agent Agreement, the Preliminary Official Statement, the Official Statement, and the Continuing Disclosure Agreement. 2. The City has duly adopted the Resolution and the City has duly authorized, executed and delivered the Series 2023 Bonds, the Bond Purchase Agreement, [the Bond Insurance Agreement,] the Paying Agent Agreement, the Preliminary Official Statement, the Official Statement, and the Continuing Disclosure Agreement. The Series 2023 Bonds, the Bond Purchase Agreement, [the Bond Insurance Agreement,] the Paying Agent Agreement, the Continuing Disclosure Agreement, and the Resolution each constitute legal, binding and valid obligations of the City, enforceable in accordance with their respective terms; provided, however, that the enforceability thereof may be subject to bankruptcy, insolvency, reorganization, moratorium and other similar laws affecting creditors' rights generally, and subject, as to enforceability, to general principles of equity. 3. To the best of my knowledge, the adoption of the Resolution, and the authorization, execution and delivery of the Series 2023 Bonds, the Bond Purchase Agreement, [the Bond Insurance Agreement,] the Paying Agent Agreement, the Preliminary Official Statement, the Official Statement, and the Continuing Disclosure Agreement, and compliance with the provisions thereof, will not conflict with, or constitute a breach of or default under, any law, administrative regulation, consent decree, ordinance, resolution, or any other agreement or other instrument as the case may be, to which the City was or is subject in connection with the Series 2023 Bonds and the Project, nor will such enactment, adoption, execution, delivery, authorization, or compliance result in the creation or imposition of any lien, charge of other security interest, or encumbrance of any nature whatsoever upon any of the property or assets of the City pledged to the repayment of the Series 2023 Bonds, or under the terms of any law, administrative regulation, ordinance, resolution or instrument to which the Series 2023 Bonds are subject, except as expressly provided by the Resolution. 4. To the best of my knowledge, all approvals, consents, authorizations and orders of any governmental authority or agency having jurisdiction in any matter which would constitute a condition precedent to the respective performances by the City of its obligations under the Resolution, the Series 2023 Bonds, the Bond Purchase Agreement, [the Bond Insurance Agreement,] the Paying Agent Agreement, the Preliminary Official Statement, the Official Statement, and the Continuing Disclosure Agreement have been obtained and are in full force and effect, and the City has complied with all conditions precedent to the issuance of the Series 2023 Bonds in resolutions and the Resolution of the City. 5. The City is lawfully empowered to pledge the Pledged Funds for payment of the principal of and interest on the Series 2023 Bonds in the manner and to the extent provided in the Resolution, the Bond Purchase Agreement[, and the Bond Insurance Agreement]. 6. To the best of my knowledge, there is no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, government agency, public board or body, C-3 pending or threatened against the City officials involved with the sale and issuance of the Series 2023 Bonds, affecting or seeking to prohibit, restrain or enjoin the sale, issuance or delivery of the Series 2023 Bonds, the pledge of the Pledged Funds, or contesting or affecting as to the City, the validity or enforceability in any respect of the Series 2023 Bonds, the Bond Purchase Agreement, [the Bond Insurance Agreement], the Paying Agent Agreement, the Preliminary Official Statement, the Official Statement, the Continuing Disclosure Agreement, and the Resolution, or contesting the powers of the City and the City Commission, or any authority for the issuance of the Series 2023 Bonds, the financing of the Project, the power to pledge the Pledged Funds, the adoption of the Resolution, and the execution of the Bond Purchase Agreement, [the Bond Insurance Agreement,] the Paying Agent Agreement, the Preliminary Official Statement, the Official Statement, the Continuing Disclosure Agreement, or any other matter which may result in any material adverse change in the business, properties, assets or financial condition of the City, when taken as a whole, that would affect the City's ability to make payments under the Series 2023 Bonds and to finance the Project. 7. Based on the examination which I have caused to be made and the participation of the City Attorney's Office at conferences at which the contents of the Preliminary Official Statement and the Official Statement were discussed, I have no reason to believe that the Preliminary Official Statement as of its date and the Official Statement as of its date and as of the date hereof (other than the information concerning DTC or its book -entry system of registration[ information provided by the Insurer in the section entitled "BOND INSURANCE"] and information provided by the Underwriters in the section entitled "UNDERWRITING") contain any untrue statements of a material fact or omit to state any material fact required to be stated therein or necessary to make the statements therein, in light of the circumstances under which they were made, not misleading. I am an attorney qualified to practice law only in the State of Florida and express no opinion as to the laws of any other state (including any laws which may be applicable by virtue of the application of the choice of law provisions under State law). No opinion is expressed herein as to compliance with State or federal tax or securities laws. The foregoing opinions are subject to the effect of, and restrictions and limitations imposed by or resulting from bankruptcy, insolvency, debt adjustment, moratorium, reorganization or other similar laws affecting creditors' rights and judicial discretion and the valid exercise of the sovereign police powers of the State and of the constitutional power of the United States of America. This opinion should not be construed as offering materials or an offering circular, prospectus, or official statement and is not intended in any way to be a disclosure statement used in connection with the sale or delivery of the Series 2023 Bonds. My opinions expressed herein are predicated upon present law (and interpretations thereof), facts, and circumstances, and I assume no affirmative obligation to update the opinions expressed herein if such laws (and interpretations thereof), facts, and circumstances change after the date hereof. No one, other than the specific addressees named above, is entitled to rely upon the statements made and the conclusions expressed within this opinion. C-4 Very truly yours, Victoria Mendez, Esq. XEA EXHIBIT D Form of Opinion of Counsel to the Underwriters [CLOSING DATE], 2023 Jefferies LLC BofA Securities, Inc. Estrada Hinojosa & Company, Inc. Siebert Williams Shank & Co., LLC Wells Fargo Bank, N.A. c/o Jefferies LLC 200 S. Orange Ave., Suite 1440 Orlando, Florida 32801 Re: $[PAR AMOUNT A] Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023A (New Administrative Building) (the "Series 2023A Bonds") $[PAR AMOUNT B] Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023B (New Administrative Building) (the "Series 2023B Bonds") $[PAR AMOUNT C] Taxable Special Obligation Non -Ad Valorem Revenue Bonds, Series 2023C Ladies and Gentlemen: We have served as underwriters' counsel in connection with the purchase for a bona fide offering to the public of the above -captioned bonds (the "Bonds") from the City of Miami, Florida (the "City"), pursuant to the terms of a Bond Purchase Agreement dated [SALE DATE], 2023 (the "Purchase Contract"), between the City and Jefferies LLC, acting for itself and on behalf of BofA Securities, Inc., Estrada Hinojosa & Company, Inc., Siebert Williams Shank & Co., LLC, and Wells Fargo Bank, N.A. (collectively, the "Underwriters"). The Bonds are being issued and secured pursuant to Resolution No. R-23-[ ], adopted by the City Commission of the City on September [28], 2023 (the "Resolution"). Capitalized terms used herein and not otherwise defined shall have the meanings given them in the Purchase Contract. As your counsel, we have reviewed such proceedings, resolutions, documents, certificates and questions of law as we have considered necessary to enable us to render this opinion. To the extent that the opinions expressed herein relate to or are dependent upon the determination that the proceedings and actions relating to the authorization, issuance and sale of the Bonds are lawful and valid under the Laws of the State of Florida, and that the Bonds and the Resolution are valid and legally binding obligations of the City or that interest on the Series 2023A Bonds and the Series 2023B Bonds is excluded from gross income of the owners thereof for federal income tax purposes, we understand that you are relying upon the opinion delivered on the date hereof of D-1 Squire Patton Boggs (US) LLP, as bond counsel, and the opinion of Victoria Mendez, Esq., as City Attorney, and no opinion is expressed herein as to such matters. Based upon the foregoing, and specifically subject to the qualifications set forth herein, we are of the opinion that: 1. The Bonds are exempt from registration under the Securities Act of 1933, as amended, and the Resolution is exempt from qualification under the Trust Indenture Act of 1939, as amended. 2. The undertaking of the City under the Disclosure Dissemination Agent Agreement dated the date hereof relating to the Bonds (the "Disclosure Agreement"), complies in all material respects with the applicable requirements of SEC Rule 15c2-12(b)(5); provided, however, no view is expressed regarding the items comprising annual financial information and operating data for purposes of [Section 3(i)] of the Disclosure Agreement. Because the primary purpose of our professional engagement as your counsel was not to independently establish factual matters and because of the wholly or partially nonlegal character of many determinations involved in our review of the Preliminary Official Statement dated [POS DATE], 2023 (the "Preliminary Official Statement") and the final Official Statement dated [SALE DATE], 2023 (the "Official Statement"), each relating to the Bonds, we have not verified, are not passing upon and do not assume any responsibility for the accuracy, completeness or fairness of the statements contained in the Preliminary Official Statement or the Official Statement (including the Appendices to each such document). However, based upon the information made available to us in the course of our participation in the preparation of the Preliminary Official Statement and the Official Statement, and without having undertaken to determine independently the accuracy, completeness or fairness of the statements contained in the Preliminary Official Statement or the Official Statement, nothing has come to our attention that would cause us to believe that the Preliminary Official Statement, as of its date (other than omissions therefrom permitted by SEC Rule 15c2-12, as to which we express no view) or the Official Statement, as of its date and as of this date, contained or contains any untrue statement of a material fact or omitted or omits to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading. In rendering this opinion, we express no opinion with respect to the information under the heading "TAX MATTERS," the information concerning The Depository Trust Company, the book -entry -only system of registration or global clearance procedures for the Bonds, or the financial, demographic or statistical data or projections or estimates included in the Preliminary Official Statement or the Official Statement or in the Appendices to each such document. In rendering the foregoing opinions we have assumed the accuracy and truthfulness of all public records and of all certifications, documents and other proceedings examined by us that 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 have also assumed the genuineness of the signatures appearing upon such public records, certifications, documents and proceedings. D-2 Our opinions expressed herein are predicated upon present laws, facts and circumstances, and we assume no affirmative obligation to update the opinions expressed herein if such laws, facts or circumstances change after the date hereof. This opinion and the statements contained herein are solely for your information and are not to be quoted in whole or in part or otherwise referred to, nor are they to be given to any governmental agency or any other person without our prior written consent, except that a copy of this opinion may be included in a transcript of the closing documents relating to the Bonds. No one other than the Underwriters is entitled to rely upon the statements made or the conclusions expressed within this opinion. ACTIVE 688370445v4 Respectfully submitted, D-3