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n <br /> DORSEY & WHITNEY <br /> • A Peers—Se xa I —e Pmsae.­"Coaso— <br /> H . <br /> 510 NORTH CENTRAL LIFE TOWER <br /> Y• - <br /> 445 MINNESOTA STREET <br /> ST. PAUL, MINNESOTA 55101 <br /> (612)227-8017 `J <br /> $1, 21.0, 000 Liquor Store Revenue Bonds <br /> Series 1986 <br /> City of St. Anthony <br /> Hennepin. and Ramsey Counties, Minnesota <br /> We have acted as Bond Counsel in connection with the <br /> issuance by the City of St. Anthony, Hennepin and Ramsey . ' <br /> Counties, Minnesota, of its Liquor Store Revenue Bonds, Series, . r... <br /> 1986, dated as of December 1, 1986, in the total principal amount <br /> of $1, 210,000 . <br /> For thepurpose of giving this opinion .we have examined <br /> certified copies of certain proceedings ;taken by the City in the <br /> authorization, sale and issuance of the .Bonds, including the form <br /> of the Bonds, and certain other .' .proceedings and documents <br /> furnished by the City. From our examination of such proceedings <br /> and other documents, assuming the.- genuineness of the signatures <br /> thereon and the accuracy of the facts stated therein, and based <br /> • upon laws, regulations, rulings and decisions in effect on the <br /> date hereof, it is- our opinion that : <br /> 1. The Bonds are in due form, have been duly executed <br /> and delivered, and are valid and binding special obligations of <br /> the.-City enforceable in accordance with their terms except to the <br /> extent limited by Minnesota or United States laws- relating to <br /> bankruptcy, reorganization, moratorium or creditors ' rights. <br /> 2. The principal of and interest on the Bonds are <br /> payable solely from Net Revenues to be derived by the City from <br /> the operation of its municipal liquor store, which have been <br /> pledged and appropriated to the Revenue Bond Account in its <br /> Liquor Store Fund; and such pledge and. appropriation constitutes <br /> a first and prior lien on such Net Revenues . <br /> 3 . . The Bonds are issued under and pursuant to an <br /> Authorizing Resolution adopted by the City Council on November <br /> 10, 1986, which defines such Net Revenues and contains all <br /> covenants and provisions made by the City with respect to its <br /> municipal liquor store for the payment and security of the Bonds . <br /> 4 . The interest to be paid on the Bonds is not <br /> includible in gross income of the recipient for United States or <br /> Minnesota income tax purposes, but is subject to Minnesota bank. <br /> and corporate excise taxes measured by income. <br />