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<br />-1 <br />2 <br />I <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />123 <br />24 <br />25 <br />28 <br />27 <br />28 <br />29 <br />30 <br />31 <br />32 <br />33 <br />34 <br />35 <br />36 <br />37 <br />38 <br />39 <br />40 <br />41 <br />42 <br />43 <br />.44 <br />45 <br />46 <br />47 <br />48 <br />49 <br />50 <br />51 <br />52 <br />53 <br />54 <br />55 <br />56 <br />57 <br />58 <br />59 <br />60 <br />81 <br />62 <br />63 <br />64 <br />.65 <br />66 <br />67 <br />68 <br />69 <br />70 <br />71 <br />72 <br />73 <br />74 <br />76 <br /> <br />'I <br /> <br />Proof of Fobr.ary 16. 1978 <br /> <br />SANTA ANA-7923 <br /> <br />Bowne of San Francisco, Inc., 981-7882 <br /> <br />GALLEY 8-- <br /> <br />The statements of law and legal conclusions set <br />forth in this official statement under the heading <br />"The Bonds" have been reviewed by Bond Counsel. <br />Bond Counsel's employment is limited to a review <br />of the legal proceedings required for the authoriza- <br />tion of the Bonds and to rendering an opinion as to <br />the validity of the Bonds and the exemption of inter- <br />est on the Bonds from income taxation (see section <br />hereof entitled "Tax Exempt Status"). The opinion <br />of Bond Counsel will not consider or extend to any <br />documents, agreements, representations, offering cir- <br />culars or other material of any kind concerning the <br />Bonds, including this official statement, not men- <br />tioned in this paragraph" <br /> <br />Tax Exempt Status <br /> <br />In the opinion of Bond Counsel, interest on the <br />Bonds is exempt from present federal income taxes <br />and from State of California personal income taxes <br />under existing statutes, regulations and court deci- <br />sions. <br /> <br />Legality for Investment in California <br />The California Community Redevelopment Law <br />provides that bonds authorized and issued in the <br />same manner and for the same purposes as the <br />City of Santa Ana Community Redevelopment Proj- <br />ect Area, 1978 Tax Allocation Bonds shall be legal <br />investments for all banks, including trust companies, <br />and various other financial institutions, as well as for <br />trust funds and other public bodies. The Community <br />Redevelopment Law also provides that such bonds <br />are authorized security for public deposits. <br />The Superintendent of Banks of the State of Cali- <br />fornia has previously ruled that bonds of a redevel- <br />opment agency are, by said statute, legal investments <br />in California for savings banks. As such, the Bonds <br />would also be legal investments for all trust funds, <br />and for the funds of all insurance companies, com- <br />mercial banks, trust companies, and any public or <br />private funds which may be invesled in county, <br />municipal, or school district bonds. The Bonds may <br />be deposited as security for the performance of any <br />act whenever the bonds of any county or munici- <br />pality may be so deposited, and may also be used as <br />security for the deposit of public moneys in banks <br />in the state. A separate ruling from the Superintend- <br />ent of Banks has not been requested for these Bonds" <br />