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3. 06/09/1999 Payment Agreement TAX EXEMPT DOCUMENTS - CONFIDENTIAL AND PROPRIETARY PAYMENT AGREEMENT JlJN~ This PAYMENT AGREEMENT is made as of~.:t, 1999 by and between MONROE COUNTY a political subdivision, with its principal offices at 10600 Aviation Blvd., Marathon, FL 33050 ("Customer"), and BSFS, with its principal offices at 501 Corporate Centre Drive, Suite 600, Franklin, TN 37067 ("Funder"); WITNESSETH WHEREAS, Customer and Service Contractor (such term and all other capitalized terms used in these recitals being defined in Article I hereof) have entered into the Service Document pursuant to which Service Contractor has agreed to provide the Service to Customer on the terms and conditions stated therein; and WHEREAS, the Service Document provides Customer with the option to make the Service Payment to Service Contractor with respect to the Service; and WHEREAS, Customer intends to exercise such option; and WHEREAS, Funder is willing to make the Service Payment to Service Contractor on behalf of Customer, on the terms and conditions provided herein. NOW, THEREFORE, Customer and Funder, intending to be legally bound hereby, agree as follows: ARTICLE I DEFINITIONS AND EXHIBITS Section 1.1. Definitions. Unless the context otherwise requires, the terms defined in this action shall, for all purposes of this Agreement, have the meanings herein specified. Agreement: This Payment Agreement, as amended or supplemented in accordance with the terms hereof. Code: The Internal Revenue Code of 1986, as now or hereafter amended, any successor thereto, and the Treasury regulations and revenue rulings and procedures applicable thereunder. Commencement Date: The date upon which Customer's obligation to make Payments accrues, which date shall be the date that Funder makes the Service Payment to Service Contractor on behalf of Customer, as evidenced by the insertion by Funder on Exhibit A of the Payment Dates of the Payments coming due therein. Incumbency Certificate: The certificate of Customer attached hereto as Exhibit D. IRS: Internal Revenue Service. Nonappropriation: The failure of Customer or Customer's governing body to appropriate money for any fiscal year of Customer sufficient for the continued performance by Customer of all of Customer's obligations under this Agreement, as evidenced by the passage of an ordinance or resolution specifically prohibiting Customer from performing its obligations under this Agreement and from using any moneys to pay any Payments for a designated fiscal year and all subsequent fiscal years. Payment: The payment due from Customer to Funder on each Payment Date during the Term, as shown on Exhibit A. Payment Date: The date upon which any Payment is due and payable as provided in Exhibit A. Private Business Use: Use described in section 141(b)(6) of the Code. Service: The telephone service to be provided by Service Contractor to Customer pursuant to the Service Document. Service Certificate: The certificate of Customer attached hereto as Exhibit B. Service Contractor: BellSouth Telecommunications, Inc. Service Contractor Acknowledgment: The acknowledgment by Service Contractor in form and substance satisfactory to Funder. Service Document: Special Service Arrangement Agreement dated tv - CJ - <1 9 between Service Contractor and Customer. Service Payment: The one-time up-front payment to Service Contractor with respect to the Service, to be paid pursuant to the Service Document. State: The state or commonwealth in which Customer is situated. Tariff: The tariff and any other rules or regulations applicable to Service Contractor, Service Document, the Service, this Agreement, the Acknowledgment or any of the transactions contemplated thereby or hereby. 2 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 Tax: Any and each fee (including, without limitation, license, documentation and registration fee), tax (including, without limitation, federal, state, local or foreign income, gross receipts, capital stock, franchise, profits, withholding, social security, unemployment, disability, real property, personal property (tangible or intangible), stamp, excise, occupation, sales, rental, use, transfer, turnover, value added, alternative minimum and estimated tax), license, levy, impost, duty, charge, assessment or withholding of any nature whatsoever, and any and all interest, penalties, fines or additions with respect thereto, whether disputed or not. Term: The period during which this Agreement is in effect as specified in Section 3.1. Section 1.2. Exhibits. The following exhibits are attached to and by reference made a part of this Agreement: Exhibit A: A schedule indicating the date and amount of each Payment coming due during the Term and the portions of each Payment comprising principal and interest. Exhibit B: Service Certificate. Exhibit C: Form of opinion of counsel to Customer as to the powers of Customer, the validity, execution and delivery of this Agreement and various related documents; and related matters. Exhibit D: Incumbency Certificate. ARTICLE II REPRESENTATIONS, WARRANTIES AND COVENANTS OF CUSTOMER Section 2.1. Representations and Warranties of Customer. Customer hereby represents, warrants and covenants to Funder that: (a) Customer has full power and authority under the Constitution and laws of the State to enter into this Agreement and the transactions contemplated hereby, and to perform all of its obligations hereunder. (b) The officer of Customer executing this Agreement has been duly authorized to execute and deliver this Agreement under the terms and provisions of a resolution of Customer's governing body or by other appropriate official action. (c) The execution, delivery and performance of this Agreement has been duly authorized and approved by all persons, governmental bodies and agencies necessary to authorize and approve this Agreement. 3 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 (d) This Agreement has been duly executed and delivered by and constitutes the valid and binding obligation of Customer, enforceable against Customer in accordance with its terms (except as enforceability may be limited by applicable bankruptcy, insolvency, moratorium or similar laws affecting creditors' rights generally or by the principles governing the availability of equitable remedies). (e) The execution, delivery and performance of this Agreement by Customer shall not (i) violate any federal, state or local or other governmental law or ordinance, or any order, writ, injunction, decree, rule or regulation of any court or other governmental agency or body applicable to Customer; or (ii) conflict with or result in the breach or violation of any term or provision of or constitute a default under, any note, bond, mortgage, indenture, agreement, deed of trust, lease or other obligation to which Customer is bound, if such conflict, breach or violation would give rise to any right of termination, cancellation or acceleration under any of the terms, conditions or provisions of such instrument. (f) In authorizing and executing this Agreement, Customer has complied with all laws applicable to this Agreement and the acquisition by Customer of the Service, including any applicable public bidding laws. (g) No lease, rental agreement, lease-purchase agreement, payment agreement or contract for purchase, to which Customer has been a party at any time during the past ten years, has been terminated by Customer as a result of insufficient funds being appropriated in any fiscal year. No event has occurred which would constitute an event of monetary default under any debt, revenue bond or obligation which Customer has issued during the past ten years. (h) There is no change pending in the structure, powers, boundaries or affairs of Customer (including, without limitation, any consolidation or incorporation into another entity) which could affect the requirements or need of Customer for the Service, and Customer is neither (i) engaged in or contemplating any such change nor (ii) aware that any other governmental unit, agency or other body with jurisdiction or control over the affairs of Customer plans or contemplates any such change. (i) Customer has appropriated and/or taken other lawful actions necessary to provide moneys sufficient to pay all Payments required to be paid under the Agreement during the current fiscal year of Customer, and such moneys will be applied in payment of all Payments due and payable during such current fiscal year. (j) There is no litigation, action, suit or proceeding pending or before any court, administrative agency, arbitrator or governmental body that challenges the authority of Customer or its officers or employees to enter into this Agreement, the proper authorization, 4 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 approval and execution of this Agreement and other documents contemplated thereby, the appropriations of moneys, or any other action taken by Customer to provide moneys sufficient to make Payments corning due under this Agreement in Customer's current fiscal year, or the ability of Customer otherwise to perform its obligations under the Agreement and the transactions contemplated thereby. (k) During the Term, the Service will be used solely by employees, officers and officials of Customer to perform only governmental functions and will not be used for any Private Business Use. (1) The money which will be utilized to make the Payments shall consist of funds appropriated by Customer for such purpose. The obligations of Customer under this Agreement, including its obligation to make Payments, shall constitute a current expense of Customer and shall not constitute an indebtedness of Customer within the meaning of the Constitution and laws of the State. Nothing herein shall constitute a pledge by Customer of any taxes or other moneys (other than moneys lawfully appropriated from time to time by or for the benefit of Customer for this Agreement) to the payment of any Payment or other amount corning due hereunder. (m) Customer has not been notified of (i) any listing or proposed listing of it by the IRS as an issuer whose certification may not be relied upon by holders of obligations of Customer or (ii) any disqualification of Customer by the IRS because a certification made by Customer contains a material misrepresentation. (n) Customer does not expect to receive any refund of the Service Payment under the Service Document. (0) The terms of the Service Document were negotiated at ann's length. (P) Customer determined to enter into a multiple-year, fixed-fee telephone service contract independent of the decision to prepay such contract. Section 2.2. Covenants of Customer. Customer hereby covenants and agrees that it will: (a) Assure that its obligation to pay Payments is not directly or indirectly secured by any interest in property. (b) Not take any action or permit or suffer any action to be taken or condition to exist if the result of such action or condition would be to cause its obligation to make Payments to be guaranteed, directly or indirectly, in whole or in part, by the United States of America or by any agency or instrumentality thereof. 5 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 (c) Neither take any action nor omit to take any action if the result of such action or omission would be to cause the interest component of the Payments to become includable in the income of Funder for purposes of federal, state or local income tax. (d) Provide (or cause to be provided) to Funder such other information as Funder may reasonably request from Customer (including budgets, proof of appropriation and financial statements). (e) On or prior to the Commencement Date, provide to Funder completed and executed copies of each of the following: (i) The Service Certificate. (ii) An opinion of Customer's legal counsel in substantially the form attached hereto as Exhibit C. (iii) Financing statements executed by Customer and describing as collateral all of Customer's rights under the Service Document, including (without limitation) the right to any amounts due from Service Contractor under the Service Document. (iv) The Incumbency Certificate. (v) The Service Contractor Acknowledgment. (vi) A copy of executed Form 8038-G for filing with the IRS. (vii) A copy of the Service Document executed by Customer and Service Contractor. (viii) A copy of any authorization for Service Document required by the applicable Public Utilities Commission. (ix) Funder shall have reached agreement with Service Contractor. 6 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 ARTICLE III TERM Section 3.1. Term. This Agreement shall be in effect for a Term commencing upon the Commencement Date and ending on the earliest of (a) the date that Customer has paid all amounts due hereunder, (b) termination hereof by Funder upon the occurrence of an event of default under Section 9.1 hereof and (c) termination hereof pursuant to Section 3.2 hereof; provided, however, that any rights or obligations of the parties accruing during the Term shall survive the termination of this Agreement. Upon determination of the Commencement Date, Funder shall insert on Exhibit A the Payment Dates of the Payments coming due therein. Section 3.2. Termination Following Nonappropriation. In the event of Non appropriation, this Agreement shall terminate, in whole but not in part, at the end of any fiscal year of Customer for which funds were appropriated, in the manner and subject to the terms specified in this Section and Sections 3.3 and 3.4 hereof. Customer may effect such termination of this Agreement by giving Funder a written notice of termination and by paying to Funder any Payments which are due and have not been paid at or before the end of its then current fiscal year. Customer shall endeavor to give notice of termination not less than 60 days prior to the end of such fiscal year and shall promptly notify Funder of any anticipated termination. Section 3.3. Intent To Continue Term; Appropriations. Customer presently intends to continue this Agreement for the entire Term and to pay all Payments specified in Exhibit A. Customer will include in its budget request for each fiscal year during the Term the Payments to become due in such fiscal year, and will use all reasonable and lawful means at its disposal to secure the appropriation of moneys for such fiscal year sufficient to pay the Payments coming due therein. Customer reasonably believes that moneys in an amount sufficient to make all such Payments can and will lawfully be appropriated and made available for this purpose. Section 3.4. Nonsubstitution. If this Agreement is terminated by Customer in accordance with Section 3.2, Customer agrees not to purchase, lease or rent personal property or services to perform substantially similar functions as, or functions substantially taking the place of those performed by the Service, and agrees not to permit such functions to be performed by its own employees or by any agency or entity affiliated with or hired by Customer, for a period of 12 months; provided, however, that these restrictions shall not be applicable if or to the extent that the application of these restrictions would affect the validity of this Agreement. ARTICLE IV PAYMENTS Section 4.1. Service Payment. Funder hereby agrees, subject to the terms and conditions of this Agreement, to advance funds on behalf of Customer in the amount set forth in Exhibit A; and Customer hereby agrees to repay such amount to Funder. Upon fulfillment of the 7 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 conditions set forth in Section 2.2(e) hereof, Funder shall pay such amount to Service Contractor. Customer's obligation to repay amounts advanced hereunder shall commence, and charges shall begin to accrue, on the Commencement Date. Section 4.2. Payments. Customer agrees to pay the Payments during the Term, in the amounts and on the Payment Dates specified in Exhibit A. All Payments shall be paid to Funder at the address specified in the first paragraph of this Agreement, or to such other person or entity to which Funder has assigned such Payments as specified in Article VIII, at such place as such assignee may from time to time designate by written notice to Customer. Customer shall pay the Payments exclusively from moneys legally available therefor, in lawful money of the United States of America and neither the full faith and credit of Customer, the State of Florida or any political subdivision or agency thereof is pledged for payments hereunder. Section 4.3. Current Expense. Customer and Funder understand and intend that the obligation of Customer to pay Payments hereunder shall constitute a current expense of Customer, shall be subject to duly authorized appropriation by Customer, and shall not in any way be construed to be a debt of Customer in contravention of any applicable constitutional or statutory limitation or requirement concerning the creation of indebtedness by Customer, nor shall anything contained herein constitute a pledge of the full faith and credit or of the general tax revenues, funds or moneys of Customer. Funder further acknowledges that, under applicable law, certain other monetary obligations of Customer contained in this Agreement are subject to duly authorized appropriation by Customer and it is the intention of the parties hereto that this Agreement not be interpreted to purport to create any obligation on Customer in this regard contrary to applicable law. Section 4.4. Interest Component. A portion of each Payment is paid as and represents the payment of interest. Exhibit A sets forth the interest component of each Payment. Section 4.5. Payments To Be Unconditional. Except as provided in Section 3.2, the obligation of Customer to make Payments or any other payments required hereunder shall be absolute and unconditional in all events and not subject to any abatement, setoff, defense or counterclaim. Notwithstanding any dispute between Customer and Funder, Service Contractor or any other person, Customer shall make all Payments and other payments required hereunder when due and shall not withhold any Payment or other payment pending final resolution of such dispute, nor shall Customer assert any right of setoff or counterclaim against its obligation to make such Payments or other payments required under this Agreement. Customer's obligation to make Payments or other payments during the Term shall not be abated by reason of failure or nonperformance of the Service, accident or unforeseen circumstances. 8 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 ARTICLE V OTHER OBLIGATIONS OF CUSTOMER Section 5.1. Use Permits. Customer shall not use the Service improperly, carelessly, in violation of any local, State or federal law or for a pmpose or in a manner contrary to that contemplated by this Agreement. Section 5.2. Taxes, Other Governmental Charges and Utility Charges. (a) Except as expressly limited by this Section, Customer shall pay all Taxes and other charges of any kind whatsoever, including, without limitation, Federal excise tax and utility charges, which are at any time assessed or levied against or with respect to, the Service or any part thereof, or which become due during the Term with respect to the Service or the Payments, assessed against Customer or Funder; provided, however, except as set forth in subsection (c), Customer shall not be required to pay any federal, State or local income, inheritance, estate, succession, transfer, franchise, gift, gross receipts, profit, excess profit, capital stock, corporate or other similar tax payable by Funder, its successors or assigns, unless such tax is made in lieu of or as a substitute for any tax, assessment or charge which is the obligation of Customer. Funder shall give Customer prompt notice of the imposition or assessment of any such Tax or charge and Customer shall be permitted to contest, at its expense, the imposition or assessment of such Tax or charge, provided that Customer shall be permitted to contest the imposition or assessment of such Tax or charge only if the following condition is met, complied with and satisfied to the complete satisfaction in all respects of Funder. Customer shall, on demand, immediately reimburse Funder for any and all administrative expenses that may be incurred by Funder in connection with any such contest. (b) Notwithstanding subsection (a) of this Section, Customer's obligation to pay any sales, use or personal property tax shall not apply if such tax results from Funder's failure to file returns and reports required by any federal, State or local statute, rule or regulation or to provide a proper resale certificate. (c) If Customer breaches a covenant in this Agreement or if a representation or warranty made by Customer in this Agreement is wrong, then Customer shall hold Funder harmless on an after-tax basis from any IRS assessment of interest paid or payable pursuant to this Agreement as includable in the gross income of Funder for federal income tax pmposes, if such assessment results from such breach or misrepresentation. Section 5.3. Advances. If Customer shall fail to perform any of its obligations under this Article, Funder may, but shall not be obligated to, take such action as may be necessary to cure such failure, including the advancement of money, and Customer shall be obligated to repay all such advances on demand, with interest at an annual rate equal to 18%, or the maximum rate permitted by law, whichever is less, from the date of the advance to the date of repayment. 9 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 ARTICLE VI SECURITY Section 6.1. Security Interest.. To secure its obligations hereunder, Customer hereby irrevocably assigns to Funder and grants to Funder a security interest in the Service Document and any amounts payable by Service Contractor thereunder. ARTICLE VII WARRANTIES Section 7.1. Selection of Service and Disclaimer of Warranties. The Service and Service Contractor have been selected by Customer, and Funder shall have no responsibility in connection with such selection, the suitability of the Service for the uses intended by Customer, the acceptance of any order submitted with respect to the Service, or any delay or failure by Service Contractor or any sales representatives thereof to manufacture, deliver or install the Service for use by Customer. THE SERVICE IS PROVIDED AS IS, AND FUNDER MAKES NO WARRANTY OR REPRESENTATION, EITHER EXPRESS OR IMPLIED, AS TO THE VALUE, DESIGN, CONDITION, MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OR FITNESS FOR THE USE CONTEMPLATED BY CUSTOMER OF THE SERVICE, OR ANY OTHER REPRESENTATION OR WARRANTY WITH RESPECT TO THE SERVICE. Section 7.2. Installation and Maintenance of Service. Funder shall have no obligation to install, erect, test, inspect, serve or maintain the Service under any circumstances, and such actions shall be the obligation of Customer. Section 7.3. Warranties. Funder hereby assigns to Customer for and during the Term all of its interests in all Service Contractor's warranties, express or implied, issued on or applicable to the service, and Funder hereby authorizes Customer to obtain the customary services furnished in connection with such warranties at Customer's expense. ARTICLE VIII ASSIGNMENT, MORTGAGING AND SELLING All ofFunder's rights, title and/or interest in and to this Agreement, the Payments and other amounts due hereunder may be assigned and reassigned in whole or in part to one or more assignees or sub assignees by Funder at any time. Customer shall cooperate with Funder or its assignee either now or hereafter by acknowledging any agreement relating thereto which in no way will alter or affect the terms and conditions of this Agreement and the assignment of the Agreement by Funder. No such assignment shall be effective as against Customer unless and until the assignor shall have filed with Customer or its agent a copy or written notice thereof identifying the assignee. Customer agrees unconditionally, if so requested by Funder, to pay directly to such assignee all sums which may be or become due hereunder. The receipt by assignee of such payments shall discharge the obligations of Customer to Funder hereunder to the extent of the payments. Any such 10 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 assignee shall have all the rights, privileges and powers of Funder hereunder, as fully as though such assignee were Funder hereunder. Customer shall keep a written record of all such assignments in form necessary to comply with section 149(a) of the Code. ARTICLE IX EVENTS OF DEFAULT AND REMEDIES Section 9.1. Events of Default Defined. The following shall be "events of default" under this Agreement and the terms "events of default" and "default" shall mean, whenever they are used in this Agreement, anyone or more of the following events: (a) Failure by Customer to pay any Payment or other payment required to be paid under this Agreement at the time specified herein and the continuation of said failure for a period of 10 days. (b) Failure by Customer to observe and perform any covenant, condition or agreement on its part to be observed or performed, other than as referred to in subsection (a) of this Section, for a period of 30 days after written notice specifying such failure has been given to Customer by Funder. (c) The determination by Funder that any representation or warranty made by Customer in this Agreement or any other document executed in connection herewith was untrue in any material respect when made. (d) The filing by Customer of a voluntary petition in bankruptcy, or failure by Customer promptly to lift any execution, garnishment or attachment of such consequence as would impair the ability of Customer to carry on its governmental or proprietary function or adjudication of Customer as a bankrupt, or assignment by Customer for the benefit of creditors, or the entry by Customer into an agreement of composition with creditors or the approval by a court of competent jurisdiction of a petition applicable to Customer in any proceedings instituted under the provisions of the federal Bankruptcy Code, as amended, or under any similar acts which may hereafter be enacted. (e) Customer shall become insolvent or shall fail or be unable generally to pay its debts as they become due. Section 9.2. Remedies on Default. Whenever any event of default referred to in Section 9.1 hereof shall have happened and be continuing, Funder shall have the right, at its option and without any further demand or notice, to take one or any combination of the following remedial steps: 11 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 (a) Funder, with or without terminating this Agreement, may declare to be immediately due and payable by Customer all amounts hereunder for which funds have been appropriated, whereupon such amounts shall be immediately due and payable. (b) Funder may take any other remedy available at law or in equity to require Customer to perform any of its obligations hereunder. Section 9.3. No Remedy Exclusive. No remedy conferred upon or reserved to Funder by this Article is intended to be exclusive and every such remedy shall be cumulative and shall be in addition to every other remedy given under this Agreement. No delay or omission to exercise any right or power accruing upon any default shall impair any such right or power or shall be construed to be a waiver thereof but any such right and power may be exercised from time to time and as often as may be deemed expedient by Funder. Section 9.4. Late . Any Payment not paid by Customer on the due date thereof shall, to the extent permissible by a, ar a late charge equal to the lesser of ten cents ($.10) per dollar of the delinquent amount or the la aximum, and Customer shall be obligated to pay the same immediately upon receipt ofFunder's inVO~06~ ARTICLE X ADMINISTRATIVE PROVISIONS Section 10.1. Notices. All notices hereunder shall be sufficiently given and shall be deemed given when delivered or deposited in the United States mail in certified or registered form with postage fully prepaid to the address specified on the first page hereof, provided that Funder and Customer, by notice given hereunder, may designate different addresses to which subsequent notices will be sent. Section 10.2. Financial Information. During the Term, Customer, upon Funder's written request, will provide Funder with Customer's financial statements, proof of appropriation for the ensuing fiscal year and such other financial information relating to the ability of Customer to continue this Agreement as may be requested by Funder. Section 10.3. Severability. If any of the provisions of this Agreement shall be invalid or unenforceable, such invalidity or unenforceability shall not invalidate or render unenforceable the entire agreement, but rather the entire agreement shall be construed as if not containing the particular invalid or unenforceable provision or provisions, and the rights and obligations of Customer and Funder shall be construed and enforced accordingly. Section 10.4. No Waiver. Any party's failure at any time to enforce any provisions of this Agreement or any right or remedy available hereunder or at law or equity, or to exercise any option 12 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 herein provided, will in no way be construed to be a waiver of such provisions, rights, remedies or options provided hereunder or at law or equity and shall not preclude or prejudice the exercising thereafter of the same or any other rights, remedies or options. Section 10.5. Entirety of Agreement. The terms and conditions of any and all exhibits, schedules and attachments to this Agreement are incorporated herein by this reference and shall constitute part of this Agreement as if fully set forth herein at length. This Agreement, together with all exhibits, schedules and attachments hereto, constitutes the entire agreement between the parties and supersedes all previous agreements, promises and representations, whether written or oral, between the parties with respect to the subject matter contained herein. Section 10.6. Invoicing. Any invoices for Payments or other amounts due shall be directed to Customer at the following address: Monroe County 1 0600 Aviation Blvd. Marathon, FL 33050 Section 10.7. Miscellaneous. This Agreement shall inure to the benefit of and shall be binding upon Funder and Customer and their respective successors and assigns. This Agreement may be amended or any of its terms modified only by a written document duly authorized, executed and delivered by Funder and Customer. Funder and Customer agree that they will, from time to time, execute, acknowledge and deliver, or cause to be executed, acknowledged and delivered, such supplements hereto and such further instruments as may reasonably be required for carrying out the expressed intentions of this Agreement. This Agreement shall be governed by and construed in accordance with the laws of the State. Section headings appearing in this Agreement are inserted merely for the convenience of reference and they are not to be considered part of, or be used in interpreting, this Agreement. Section 10.8. Usury. It is the intention of the parties hereto to comply with any applicable usury laws; accordingly, it is agreed that, notwithstanding any provisions to the contrary herein, in no event shall this Agreement require the payment or permit the collection of interest or any amount in the nature of interest or fees in excess of the maximum amount permitted by applicable law. Any such excess interest or fees shall first be applied to reduce principal and when no principal remains, refunded to Customer. In determining whether the interest paid or payable exceeds the highest lawful rate, the total amount of interest shall be spread through the term hereof so that the interest is uniform through such term. Section 10.9. Waiver of Jury Trial. Customer and Funder hereby waive any right to trial by jury in any action or proceeding with respect to, in connection with or arising out of this Agreement. 13 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 [REMAINDER OF PAGE INTENTIONALLY BLANK; EXECUTION PAGE FOLLOWS.] 14 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 IN WITNESS WHEREOF, the parties hereto have executed this Agreement as of the date first above written. MONROE COUNTY Customer BSFS Funder By: ~ '>,..1..-v ~ . .......;\~~ Title: ~R-. {; -9- 99 By: d~~ Vl~ Pr~SI~ Title: (SEAL) ATTEST: DANn L KClLHAGE CLE;::K ~C.~)(J~ [ .:.L', ,',:u:.. .:< 15 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 EXHIBIT A TO PAYMENT AGREEMENT PAYMENT SCHEDULE See Attached Schedule Exhibit A - Page 1 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 FOR ACCTG. PURPOSES ONLY. DOES NOT REPRESENT A BUY OUT, CASUALTY OR TERMINATION VALUE. CUSTOMER MONROE COUNTY AMOUNT $1,618,620.00 TERM 84 Payments to commence November 1, 1999 ADV or ARR ARR PAYMENT BEGINNING INTEREST PRINCIPAL TOTAL ENDING NUMBER BALANCE EXPENSE PAYMENT PAYMENT BALANCE 0 1,618,620.00 0.00 0.00 0.00 1,618,620.00 1 1,618,620.00 8,001.17 15,591.68 23,592.85 1,603,028.32 2 1,603,028.32 7,924.09 15,668.75 23,592.85 1,587,359.57 3 1,587,359.57 7,846.64 15,746.21 23,592.85 1,571,613.36 4 1,571,613.36 7,768.80 15,824.04 23,592.85 1,555,789.31 5 1,555,789.31 7,690.58 15,902.27 23,592.85 1,539,887.05 6 1,539,887.05 7,611.97 15,980.87 23,592.85 1,523,906.17 7 1,523,906.17 7,532.98 16,059.87 23,592.85 1,507,846.30 8 1,507,846.30 7,453.59 16,139.26 23,592.85 1,491,707.05 9 1,491,707.05 7,373.81 16,219.04 23,592.85 1,475,488.01 10 1,475,488.01 7,293.64 16,299.21 23,592.85 1,459,188.80 11 1,459,188.80 7,213.06 16,379.78 23,592.85 1,442,809.02 12 1,442,809.02 7,132.10 16,460.75 23,592.85 1,426,348.27 13 1,426,348.27 7,050.73 16,542.12 23,592.85 1,409,806.15 14 1,409,806.15 6,968.96 16,623.89 23,592.85 1,393,182.26 15 1,393,182.26 6,886.78 16,706.07 23,592.85 1,376,476.19 16 1,376,476.19 6,804.20 16,788.65 23,592.85 1,359,687.54 17 1,359,687.54 6,721.21 16,871.64 23,592.85 1,342,815.91 18 1,342,815.91 6,637.81 16,955.04 23,592.85 1,325,860.87 19 1,325,860.87 6,554.00 17,038.85 23,592.85 1,308,822.02 20 1,308,822.02 6,469.77 17,123.07 23,592.85 1,291,698.95 21 1,291,698.95 6,385.13 17,207.72 23,592.85 1,274,491.23 22 1,274,491.23 6,300.07 17,292.78 23,592.85 1,257,198.45 23 1,257,198.45 6,214.59 17,378.26 23,592.85 1,239,820.19 24 1,239,820.19 6,128.68 17,464.16 23,592.85 1,222,356.03 25 1,222,356.03 6,042.35 17,550.49 23,592.85 1,204,805.53 26 1,204,805.53 5,955.60 17,637.25 23,592.85 1,187,168.28 27 1,187,168.28 5,868.41 17,724.43 23,592.85 1,169,443.85 28 1,169,443.85 5,780.80 17,812.05 23,592.85 1,151,631.80 29 1,151,631.80 5,692.75 17,900.10 23,592.85 1,133,731. 70 30 1,133,731. 70 5,604.26 17,988.58 23,592.85 1,115,743.12 31 1,115,743.12 5,515.34 18,077.50 23,592.85 1,097,665.62 32 1,097,665.62 5,425.98 18,166.86 23,592.85 1,079,498.75 33 1,079,498.75 5,336.18 18,256.67 23,592.85 1,061,242.09 34 1,061,242.09 5,245.93 18,346.91 23,592.85 1,042,895.18 35 1,042,895.18 5,155.24 18,437.60 23,592.85 1,024,457.57 36 1,024,457.57 5,064.10 18,528.75 23,592.85 1,005,928.82 37 1,005,928.82 4,972.51 18,620.34 23,592.85 987,308.49 38 987,308.49 4,880.47 18,712.38 23,592.85 968,596.11 39 968,596.11 4,787.97 18,804.88 23,592.85 949,791.23 40 949,791.23 4,695.01 18,897.84 23,592.85 930,893.39 CUSTOMER MONROE COUNTY AMOUNT $1,618,620.00 TERM 84 Payments to commence November 1, 1999 ADVorARR ARR PAYMENT BEGINNING INTEREST PRINCIPAL TOTAL ENDING NUMBER BALANCE EXPENSE PAYMENT PAYMENT BALANCE 41 930,893.39 4,601.59 18,991.25 23,592.85 911,902.14 42 911,902.14 4,507.72 19,085.13 23,592.85 892,817.01 43 892,817.01 4,413.37 19,179.47 23,592.85 873,637.54 44 873,637.54 4,318.57 19,274.28 23,592.85 854,363.26 45 854,363.26 4,223.29 19,369.56 23,592.85 834,993.70 46 834,993.70 4,127.54 19,465.30 23,592.85 815,528.40 47 815,528.40 4,031.32 19,561.52 23,592.85 795,966.87 48 795,966.87 3,934.62 19,658.22 23,592.85 776,308.65 49 776,308.65 3,837.45 19,755.40 23,592.85 756,553.25 50 756,553.25 3,739.80 19,853.05 23,592.85 736,700.20 51 736,700.20 3,641.66 19,951.19 23,592.85 716,749.01 52 716,749.01 3,543.04 20,049.81 23,592.85 696,699.20 53 696,699.20 3,443.92 20,148.92 23,592.85 676,550.28 54 676,550.28 3,344.32 20,248.52 23,592.85 656,301. 76 55 656,301. 76 3,244.23 20,348.61 23,592.85 635,953.14 56 635,953.14 3,143.64 20,449.20 23,592.85 615,503.94 57 615,503.94 3,042.56 20,550.29 23,592.85 594,953.66 58 594,953.66 2,940.98 20,651.87 23,592.85 574,301.79 59 574,301.79 2,838.89 20,753.96 23,592.85 553,547.83 60 553,547.83 2,736.30 20,856.55 23,592.85 532,691.28 61 532,691.28 2,633.20 20,959.65 23,592.85 511,731.64 62 511,731.64 2,529.59 21,063.25 23,592.85 490,668.38 63 490,668.38 2,425.47 21,167.37 23,592.85 469,501.01 64 469,501.01 2,320.84 21,272.01 23,592.85 448,229.00 65 448,229.00 2,215.69 21,377.16 23,592.85 426,851.84 66 426,851.84 2,110.01 21,482.83 23,592.85 405,369.01 67 405,369.01 2,003.82 21,589.03 23,592.85 383,779.98 68 383,779.98 1,897.10 21,695.74 23,592.85 362,084.24 69 362,084.24 1,789.86 21,802.99 23,592.85 340,281.25 70 340,281.25 1,682.08 21,910.77 23,592.85 318,370.48 71 318,370.48 1,573.77 22,019.08 23,592.85 296,351.41 72 296,351.41 1,464.92 22,127.92 23,592.85 274,223.48 73 274,223.48 1,355.54 22,237.30 23,592.85 251,986.18 74 251,986.18 1,245.62 22,347.23 23,592.85 229,638.95 75 229,638.95 1,135.15 22,457.69 23,592.85 207,181.26 76 207,181.26 1,024.14 22,568.71 23,592.85 184,612.55 77 184,612.55 912.58 22,680.27 23,592.85 161,932.28 78 161,932.28 800.46 22,792.38 23,592.85 139,139.90 79 139,139.90 687.80 22,905.05 23,592.85 116,234.85 80 116,234.85 574.57 23,018.27 23,592.85 93,216.57 81 93,216.57 460.79 23,132.06 23,592.85 70,084.52 82 70,084.52 346.44 23,246.40 23,592.85 46,838.11 83 46,838.11 231.53 23,361.32 23,592.85 23,476.80 84 23,476.80 116.05 23,476.80 23,592.85 0.00 TOTALS 363,179.09 1,618,620.00 1981799.09 CUSTOMER AMOUNT TERM ADV or ARR MONROE COUNTY $1,618,620.00 84 Payments to commence November I, 1999 ARR PAYMENT NUMBER BEGINNING BALANCE INTEREST EXPENSE PRINCIPAL PAYMENT TOTAL PAYMENT ENDING BALANCE Payments in Schedule A are based on a payment factor ("Payment Factor") of .014575 on May 24, 1999 ("Quote Date") based upon the seven year Treasury Constant Maturities yield (''Yield'') as reported by the Federal Reserve Statistical Release (H. 15 Report) on the Quote Date. For each 25 basis point increase in the Yield up to the Commencement Date, the Payment Factor and the Payments shall be increased by .000118. EXHIBIT C TO PAYMENT AGREEMENT FORM OF OPINION OF COUNSEL (TO BE PREPARED ON COUNSEL'S LETTERHEAD) BSFS 501 Corporate Centre Dr., Suite 600 Franklin, TN 37067 Re: Payment Agreement dated as of May _, 1999 (the "Agreement") by and between BSFS ("Funder") and Monroe County ("Customer") I have acted as counsel to Customer with respect to the above-captioned Agreement and various related matters, and in this capacity have reviewed a duplicate original of the Agreement. Capitalized terms used in this opinion without definition have the meanings ascribed thereto in the Agreement. Based upon my examination of these and such other documents as I deem relevant, it is my opinion that: 1. Customer is a body corporate and politic and public instrumentality of the State, duly organized, existing and operating under the Constitution and laws of the State and has the attributes of a "state or political subdivision thereof' within the meaning of section 103( c)(1) of the Internal Revenue Code of 1986 which are necessary to permit the issuance of obligations bearing interest which is exempt from federal income taxation. 2. Customer has full power and authority under the Constitution and laws of the State to enter into the Agreement and the transactions contemplated thereby, to perform all of its obligations thereunder and the transactions contemplated thereby. 3. The officer of Customer executing the Agreement has been duly authorized to execute and deliver the Agreement. 4. The execution, delivery and performance of the Agreement has been duly authorized and approved by all persons, governmental bodies and agencies necessary to authorize and approve the agreement. 5. The Agreement and the other documents described above have been duly authorized, approved and executed by and on behalf of Customer, and the Agreement is a valid and binding contract of Customer enforceable in accordance with its terms, except to the extent limited Exhibit C- Page 1 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 by State laws affecting remedies and by bankruptcy, reorganization or other laws of general application relating to or affecting the enforcement of creditors' rights. 6. The execution, delivery and performance of the Agreement and the appropriation of moneys to pay the Payments coming due thereunder do not violate any federal, State or local or other governmental law or ordinance, or any order, writ, injunction, decree, rule or regulation of any court or other governmental agency or body applicable to Customer, including, without limitation, any constitutional, statutory or other limitation relating to the manner, form or amount of indebtedness which may be incurred by Customer. 7. There is no limitation, action, suit or proceeding pending or before any court, administrative agency, arbitrator or governmental body that challenges the authority of Customer or its officers or its employees to enter into the Agreement, the proper authorization, approval and execution of the Agreement and the other documents described above, the appropriation of moneys to make Payments under the Agreement for the current fiscal year of Customer or the ability of Customer otherwise to perform its obligations under the Agreement and the transactions contemplated thereby. 8. Any assignee or subassignee of all or part of Funder's right, title and/or interest in and to the Agreement shall be entitled to rely on this opinion as though it were addressed directly to any such assignee or sub assignee. Very truly yours, Exhibit C- Page 2 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 EXHIBIT D TO PAYMENT AGREEMENT INCUMBENCY CERTIFICATE NAME, SIGNATURE AND TITLE OF PERSON OR PERSONS WHO SIGNED PAYMENT AGREEMENT: Name Signature Title I, the undersigned, hereby certify that I am the duly qualified and acting ,;11 a Va Y of-Monroe County ("Customer"), and, with respect to the Payment Agreement dated as o~e...3.., 1999 (the "Agreement") by and between Customer and BSFS ("Funder"), that I am well acquainted with the persons listed above and with their signatures, that said persons hold the respective offices or positions set forth opposite their signatures above, that the signatures above written are true and correct signatures of said persons, and that as of the date of execution of the Agreement or other documents relating thereto by and of said persons, such persons were duly qualified and acting as the officers or position holders indicated above and duly authorized to execute the same: (A PERSON WHO DID NOT SIGN THE PAYMENT AGREEMENT) MONROE COUNTY r.:.._L.........~ . ~b.oQ.c .~/) IJEPUTY a.ERK \~~-,,\~ By: \. Print Name: /L) I I he,l ~ . t) CL H O-rV~'y Title: mQ'1 0 r / eh a. If rY) a. n / Date: (p - 9 - 9 9 Exhibit 0 - Page 1 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 TAX-EXEMPT DOCUMENTS - CONFIDENTIAL AND PROPRIETARY ACKNOWLEDGMENT JU.ne. To induce BSFS ("Funder") to enter into the Payment Agreement dated as of May 3-, 1999 (the "Payment Agreement") between MONROE COUNTY ("Customer") and Funder and to make the Service Payment (as defined in the Payment Agreement) on behalf of Customer and for other good and valuable consideration, BellSouth Telecommunications, Inc. ("Service Contractor") hereby acknowledges and agrees as follows: 1. Service Contractor understands that Funder is entering into the Payment Agreement and making the Service Payment on behalf of Customer in reliance on the terms hereof. 2. The amount of the Service Payment is $1,618,620.. 3. Service Contractor has entered into an agreement to provide service (the "Service") to Customer in accordance with Special Service Arrangement Agreement (the "Service Document"). 4. The Service Document is in full force and effect; there has been no default in performance of any obligation thereunder or breach of any term therein by either party thereto; and Customer has asserted no set-off, counterclaim or defense with respect to its obligations to perform in accordance with the terms of the Service Document or to pay the Service Payment due thereunder. 5 The Service Document and any amendments thereto, copies of which have been provided to Funder herewith, constitute the entire writing, obligation and agreement between Service Contractor and Customer respecting the Service. 6. Customer has accepted the Service, as evidenced by the Service Certificate (as defined in the Payment Agreement). 7. Service Contractor shall fully and timely perform each of its obligations in the Service Document. 8. Service Contractor may be required in certain instances to pay to Customer certain amounts due under the Service Document (for example, if the Service is terminated as a result of Service Contractor's breach of the Service Document, regulatory action or nonappropriation). Any such amounts will be paid directly to Funder. 9. Up-front payments (or prepayments) on substantially the same terms are made by a substantial percentage of persons similarly situated to Customer but who are not beneficiaries of tax -exempt financing. TAX-EXEMPT DOCUMENTS - CONFIDENTIAL AND PROPRIETARY 10. Up-front payments for service such as the Service is customary and available to all of Service Contractor's large customers. 11. The individual cost-based pricing reflected in the Service Document was done in a manner similar to that used for individual cost-based pricing for other customers of Service Contractor pursuant to applicable regulatory requirements or considerations and was computed without regard to the availability or unavailability of tax-exempt financing to Customer to provide for payment of the Service Payment. 11. The terms of the Service Document were negotiated at arm's length and constitute a customary range of services and terms for similar contracts entered into by Service Contractor and entities other than Customer, including a significant number of entities that are not state or local governmental units. 12. The Service Document and all such contracts (including the pricing and other terms and conditions thereof) are in compliance with all laws and regulations. 13. Service Contractor is not treating and will not treat the prepayment of the Service Payment as a loan to Service Contractor for federal income tax purposes. ..:::::Ju....()e Dated:-May l, 1999 BSFS By: AGREED: Title: BELLSOUTH TELECOMMUNICATIONS, INC. By: Date: 2 L:\Clients A-M\Clients M\Monroe County\BSFSMUAKl.DOC 5/24/99 EXHIBIT B TO PAYMENT AGREEMENT SERVICE CERTIFICATE I, the undersigned, hereby certify that I am the duly qualified and acting /11 ay 0 ( .J ~ of Monroe County ("Customer"), and, with respect to the Payment Agreement dated as of-May ~, 1999 (the "Agreement") by and between Customer and BSFS ("Funder") that (capitalized terms used herein without definition having the meanings ascribed thereto in the Agreement): 1. The Service (a) has been implemented to the satisfaction of Customer, (b) has been thoroughly examined and inspected to the complete satisfaction of Customer, (c) has been found to be and is suitable for Customer's purposes and (d) is hereby accepted by Customer, in the condition received, for all purposes. 2. Customer has appropriated and/or taken other lawful actions necessary to provide moneys sufficient to pay all Payments required to be paid under the Agreement during the current fiscal year of Customer, and such moneys will be applied in payment of all Payments due and payable during such current fiscal year. 3. There is no litigation, action, suit or proceeding pending or before any court, administrative agency, arbitrator or governmental body, that challenges the authority of Customer or its officers or employees to enter into the Agreement, the proper authorization, approval and execution of the Agreement and other documents contemplated thereby, the appropriations of moneys, or any other action taken by Customer to provide moneys sufficient to make Payments coming due under the Agreement in Customer's current fiscal year, or the ability of Customer otherwise to perform its obligations under the Agreement and the transactions contemplated thereby. MONROE COUNTY ~ ATTES-r. DANNYL KOUiAGE ClERK ~c.~ DEPUTY CLERK' .. ... ~.'L ,.....~ B. ~):I.1\..6......AA- ~... \ '\ ~--, ~"~ y. ~ Title: f1 A Y ~ f2- Date: fe/flry Exhibit B - Page 1 L:\Clients A-M\Clients M\Monroe County\BSFSMUAG2.DOC 5/24/99 CONFIDENTIAL AND PROPRIETARY INFORMATION To: BSFS ("Funder") The undersigned hereby acknowledges that the forms of Payment Agreement and Acknowledgment ("Documents") being provided to the undersigned are confidential and proprietary information of Funder and are being provided to the undersigned solely to permit the undersigned to evaluate entering into a transaction with Funder. The undersigned shall hold the Documents in confidence~nd shall not disclose the Documents to others without Funder's written consent. The Documents shall remain the property of Funder and shall be returned to Funder when the undersigned's need for them have expired or upon request of Funder. MONROE COUNTY ~fd: ~ /J;bl,c ~ I~ . ~\1Y\.L- ;i.""";" - ~ ...;.....:r".-."'1 ",'" ,~~\~:.., ,_' ,,-_11 By: .!.",....)..~~....'l;,;c".,...."''^,'~.....~,..,' \ ~ ',."" 1-....'i ..".......y-. \." Title: m 4 VI III G~ Q,~ (tY\(A 1\ -, / Date: Lo-q-~q .~~ '-:,I;~t~13t ., J' .,.)~ ..:.A,' " .:.:'C '~;- . '. ; '~" t:,)~'" ",l"J .., \ .~Z . ",'1 ;"9 i. :~; '. :~~./.\...:.'~.(~ \.;, --16\1/,'",'";. . , ~~ ~)' , '..~ .:.. ~~. """. ~~ ", j,'____ ..''If,... fC:..,. 1-- ."- 'l ~~~Er~ r r <...... L:\Clients A,MIClients MIMonroe CountyICONF.DOC 5/24/99 ATTACHMENT A TO DCC FINANCING STATEMENT Secured Party: BSFS 501 Corporate Centre Dr., Suite 600 Franklin, TN 37067 Debtor: Monroe County 1 0600 Aviation Blvd. Marathon, FL 33050 Description of property: ALL OF DEBTOR'S RIGHT, TITLE AND INTEREST IN, TO AND UNDER THE SPECIAL SERVICE ARRANGEMENT AGREEMENT DATED AS OF &;- q - 9 9 ("SERVICE DOCUMENT") BETWEEN DEBTOR AND BELLSOUTH TELECOMMUNICATIONS, INe. ("SERVICE CONTRACTOR") AND ALL AMOUNTS DUE TO DEBTOR THEREUNDER OR OTHERWISE FROM SERVICE CONTRACTOR AND ALL PROCEEDS OF THE FOREGOING. L:\Clients A-MlClients MlMonroe CountyIBSFSUCC.DOC 5/24/99