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I <br /> <br />I <br />I <br />I <br />I <br />i <br />I <br />i <br />I <br />I <br />I <br />I <br /> <br />I <br />I <br />I <br />I <br /> <br />2000 First Bank P}ace West <br />Minneapolis <br />Minnesola 55402 <br /> <br />Telephone 612-333-0543 <br /> <br />Clayton L. LeFevere <br />Herbert P. Lefler <br />J. Denms O'Bnen <br />John E. Drawz <br />David J, Kennedy <br />John 8. Dean <br />Glenn E. Purdue <br />Richard J. Schieffer <br />Charles L. LeFevere <br />Herbert P. Lefler Iii <br />Jeffrey J. Strand <br />Ma~ J. Bjorklund <br />John G. Kressel <br />Dayle Nolan <br />Cindy L. Lavorato <br />Michael A. Nash <br />Luke R. Komafek <br />Br~an F. R~ce <br />Lorraine S. CluG§ <br />James J. Thomson. Jr. <br />James M. Strommen <br />Mere' C. N~elsen <br /> <br />! ,(' F('~'er(' <br />LH'h,r <br /> <br />( )'lh'i(.u ~L. <br />I <br /> <br />$2,045,000 General Obligation <br />Improvement Bonds of 1984, Series II <br /> City of Ramsey <br /> Anoka County, Minnesota <br /> <br /> We have acted as bond counsel in connection with <br />the issuance by the City of Ramsey, Anoka County, <br />Minnesota, of its General Obligation Improvement Bonds <br />of 1984, Series II originally dated as of October 1, <br />1984, in the total principal amount of $2,045,000. For <br />the purpose of rendering this opinion we have examined <br />certified copies of certain proceedings taken by the <br />City in the authorization, sale and issuance of the <br />Bonds, including the form of the Bonds, and certain <br />other proceedings and documents furnished by the City. <br />From our examination of such proceedings and other doc- <br />uments, assuming the genuineness of the signatures <br />thereon and the accuracy of the facts stated therein, <br />and based upon laws, regulations, rulings and decisions <br />in effect on the date hereof, it is our opinion that: <br /> <br /> 1. The Bonds are in due-form, have been duly <br />executed and delivered, and are valid and binding <br />general obligations of the City, enforceable'-in accord- <br />ance with their terms, except as such enforcement may <br />be limited by Minnesota or United States laws relating <br />to bankruptcy, reorganization, moratorium or creditors' <br />rights. <br /> <br /> 2. The principal of and interest on the Bonds <br />are payable primarily from special assessments levied <br />or to be levied on property specially benefited by <br />local improvements, but if necessary for the payment <br />thereof ad valorem taxes are required by law to be <br />levied on all taxable property in the City, which taxes <br />are not subject to any limitation as to rate or amount. <br /> <br /> 3. The interest to be paid on the Bonds is not <br />includable in gross income of the recipient for United <br />States or Minnesota income tax purposes, but is subject <br />to Minnesota taxes on banks and corporations measured <br />by income. <br /> <br /> <br />