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K Opinion of the City AttorneyOFFICE OF THE CITY ATTORNEY F L 0 R 1 0 A MURRAY H. DUBBIN City Attorney Florida Power & Light Company Juno Beach, Florida Squire, Sanders & Dempsey L.L.P. Miami, Florida June 28, 1999 Telephone: (305) 673-7470 Telecopy: (305) 673-7002 Re: $3,941,059 City of Miami Beach, Florida Non -Ad Valorem Revenue Note, Series 1999 Ladies and Gentlemen: I am the City Attorney for the City of Miami Beach, Florida (the "Issuer"), a municipality of the State of Florida (the "State"), established pursuant to the Constitution and laws of the State, in connection with the Issuer's $3,941,059 Non -Ad Valorem Revenue Note, Series 1999 (the "Note"). The Note is authorized to be issued pursuant to the City Charter of the Issuer, Chapter 166, Florida Statutes, and other applicable provisions of law (the "Act") and Resolution No. 98-22891 of the Issuer adopted on September 9, 1998, as amended by Resolution No. 99-23220 of the Issuer adopted on June 23, 1999 (collectively, the "Resolution"), for the purpose of paying the additional cost attributable to the underground construction of an electric transmission line between 40th Street and the Venetian Substation of Florida Power & Light Company.(the "Project"). The terms used herein in capitalized form and not otherwise defined herein have the meaning ascribed to them in the Resolution. I have examined the law and such certified proceedings and other papers as I deem necessary to render this opinion. Based upon the foregoing, I am of the opinion that: 1. The Issuer is duly created and validly existing as a body corporate and politic and a municipal corporation of the State of Florida. The Issuer has such powers as set forth in the Act with good, right and lawful authority to, among other things, acquire the Project and to provide funds therefor through the issuance of the Note, to charge and collect the Non -Ad Valorem Revenues (as defined in the Resolution), to secure the Note as provided in the Resolution, to adopt the Resolution and to perform its obligations under the Resolution. 2. The Resolution is a valid resolution of the Issuer, duly adopted by the Issuer at a meeting duly noticed and held in accordance with the Constitution and laws of the State of Florida and the Charter of the City of Miami Beach, Florida (the "Charter"), and the Code of the City of Miami Beach, Florida (the "Code"), and the Resolution remains in full force and effect as of the date hereof, has not been modified after its date of adoption and, to the best of my knowledge after due inquiry, no event has occurred that constitutes or would, with the passage of time or the giving of notice, constitute a default by the Issuer under the terms thereof. The Resolution constitutes a valid FMTrO'LEVLBONDSIFESL LOANCI OIIING2WPD 1700 Convention Center Drive -- Fourth Floor -- Miami Beach, Florida 33139 Florida Power & Light Company Squire, Sanders & Dempsey L.L.P. June 28, 1999 Page 2 and binding instrument, enforceable against the Issuer in accordance with its terms. The Note has been duly authorized, executed and delivered by the Issuer, and constitutes the legal, valid and binding obligation of the Issuer enforceable in accordance with its terms, but payable from and secured solely by the sources and in the manner provided in the Resolution. 3. To the best of my knowledge after due inquiry, neither the adoption of the Resolution, compliance by the Issuer with the terms and conditions thereof, nor the execution or the performance by the Issuer of the Note, will conflict with or result in a breach of any of the terms or provisions of the Issuer's Charter or Code or of any law in force on the date hereof, or any regulation, order, writ, injunction or decree of any court or governmental authority, or will result in a breach of any of the terms or provisions of any agreement or instrument to which the Issuer is a party or by which it is bound, or in any such case constitutes or will constitute a default thereunder or results or will result in the creation or imposition of any encumbrance upon any of the properties or assets of the Issuer. 4. The Issuer has the lawful authority to covenant to budget and appropriate the Non -Ad Valorem Revenues in the manner provided in the Resolution. 5. There is no litigation pending or, to the best of my knowledge, threatened against the Issuer (i) seeking to restrain or enjoin the issuance or delivery of the Note or the application of the proceeds thereof, or the charge or collection of the Non -Ad Valorem Revenues; (ii) contesting or affecting the authority for the issuance of the Note or the validity, enforceability, or the performance by the Issuer of the Note, the Resolution, or the transactions contemplated thereunder; (iii) contesting or affecting the establishment or existence of the Issuer or any of its officers, its ability to charge or collect revenues, its assets, property or conditions, financial or otherwise, or contesting or affecting any of the powers of the Issuer, including its power to levy and collect taxes, fees and other charges; (iv) contesting or affecting the exclusion from gross income of interest on the Note for federal income tax purposes; or (v) which would have a materially adverse effect upon the matters provided for or contemplated by the Resolution. 6. No further authorization, approval, consent or other order of any governmental authority or agency is required on the part of the Issuer for the valid adoption of the Resolution, the authorization, issuance, sale, execution, delivery and performance of the Note and the consummation of the transactions contemplated thereby. The foregoing opinion is qualified to the extent that the rights of the holder of the Note and the enforceability of the Note and the Resolution may be limited by any bankruptcy, insolvency, reorganization, moratorium or other laws affecting creditors' rights generally heretofore or hereafter enacted to the extent constitutionally applicable and their enforcement may also be subject to the exercise of judicial discretion in appropriate cases. Very truly yours, y W."Dubbin Cit Attorney F:ATf04.EVUBONDSW UADA'CIA®sI34VND OFFICE OF THE CITY ATTORNEY - 1700 CONVENTION CENTER DRIVE - MIAMI BEACH, FLORIDA 33139