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9. In the event the Lessee does not expend all Lease Proceeds <br />within six months of the date hereof Lessee will comply with the <br />arbitrage rebate provisions under Section 148 of the Code with respect <br />to timeliness and amounts that may be required for remittance to the <br />United States Treasury. To the extent the Lessee is exempt from the <br />arbitrage rebate provisions referred to above, this paragraph does not <br />apply. <br />10. To the best of the knowledge and belief of the undersigned, <br />the expectations of the Lessee, as set forth above, are reasonable, <br />and there are no present facts, estimates and circumstances which <br />would change the foregoing expectations. <br />IN WITNESS WHEREOF, the party hereto has caused its authorized <br />agent to execute this Arbitrage and Tax Certificate on the date <br />specified below. <br />CITY OF SANT4 ANA <br />(lessee <br />By 1 <br />"/ I-EXECUTW DIRECTOR, <br />Title FTNAM A MAMAC+'GMVM <br />2 <br />