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HomeMy WebLinkAboutWallack Somers & Haas - RE: Revolving Line of Credit - 11/8/2011 WALLACK BARRY Z.WALLACK MICHAEL S.WALLACK SOMERS KARL R HAAS HAAS„ JENNIFER R.SHOUP HARRY F.TODD Attorneys at Law RYAN R.WILMERING November fi, 2011 The City of Carmel Redevelopment Commission Fowler State Bank 300 East 5th Street P.O. Box 511 Fowler, Indiana 47944 Hall, Render, Killian, Heath & Lyman, P.C. Suite 2000, Box 82064 One American Square Indianapolis, IN 46282 Re: Revolving Line of Credit from Fowler State Bank (the "Lender"). Ladies and Gentlemen: We have acted as counsel to Carmel City Center Community Development Corporation, an Indiana community development corporation(the"Borrower")for purposes of rendering this opinion in connection with that certain $2,500,000.00 revolving line of credit to be made available by Lender to Borrower (the "Loan"). In connection therewith, we have reviewed the following documents and instruments relating to the Loan, each dated as of the date of this opinion, unless otherwise indicated: A. Promissory Note in the original amount of$2,500,000.00 from Borrower, as maker, to Lender; B. Collateral Assignment and Security Agreement by and among The City of Carmel Redevelopment Commission("CRC"), Borrower,and Lender(the"Collateral Assignment"); C. Tri-Party Agreement by and among CRC, Borrower, and Lender; D. Grant Agreement by and between CRC and Borrower (the "Grant Agreement"), E. An unfiled form of UCC Financing Statement to be filed in the Office of the Secretary of State of Indiana, naming Borrower as the Debtor and naming Lender as the Secured Party (the "Financing Statement"); F. Certificate of Existence for Borrower issued by the Secretary of State of Indiana under date of September 26, 2011 (the "Public Authority Document"); and One Indiana Square, Suite 2300 Indianapolis, Indiana 46204 Tel: 317.231.9000 www.WSHLaw.com Fax: 3 1 7.23 I.9900 G. Resolution of Borrower dated October 11, 2011; Items A through D, collectively, are the"Loan Documents". Items A through G, collectively, are the "Documents". Our examination of documents has been confined solely to the Documents, and our opinions hereinafter set forth are based solely upon this information. We have not been requested to perform,we have been under no obligation to perform, and we have not performed, any independent review or examination of any other documents. We have made such examination of the laws of the State of Indiana(the"State")as we have deemed necessary for the purposes of rendering the opinions set forth below, but we advise you that we express no opinion as to the laws of any state or jurisdiction other than the State. Assumptions In rendering this opinion, we have assumed that: (a) All facts set forth in all certificates and other statements, documents, records, financial statements, and papers reviewed by us, are accurate and complete, and all factual representations, warranties, schedules, and exhibits contained in the Documents are accurate and complete with respect to the factual matters set forth therein. (b) The Documents submitted to us for review are accurate and complete; the Documents submitted to us as originals are authentic, true, accurate, and complete; the Documents submitted to us as copies conform to the originals of such Documents which are themselves authentic,true,accurate,and complete;and all signatures on the Documents are genuine. (c) The Public Authority Document is accurate, complete, and authentic and all official public records (including their proper indexing and filing) are accurate and complete. (d) Each Loan Document which is to be notarized has been acknowledged before a notary public who has completed, signed, and sealed the acknowledgment on the form attached to such Loan Document. (e) The Loan Documents will be appropriately completed by due and sufficient completion of all blanks and schedules; the legal description of any real property therein or attached thereto will be accurate, complete, and legally sufficient; all exhibits to the Loan Documents will be so attached thereto before execution, recording, and filing; all cross-references therein to recorded documents (if any) are complete and accurate; and all numerical data included in the Loan Documents is correct and reflects the intent of the parties thereto. (f) The Financing Statement contains the correct legal name and organizational number of Borrower and the current address of Borrower, as debtor, and the correct legal name and the current address of Lender, as secured party. (g) The Financing Statement has been or will be duly filed, indexed, and recorded among the appropriate official records, with all fees, charges, and taxes having been paid. Z:\Documents\Shoup,.fenny\City or Carmel\Fowler Slate 13ank\4CDC Ill Nay I 1 Opinion\4CDC Opinion.wpd -2- (h) The Loan Documents, as and when executed on a proximate date, will conform in all material respects to the form submitted to, and reviewed, by us. (i) The Loan Documents are valid and enforceable against all parties thereto(other than Borrower). (j) Borrower has the requisite rights, titles,and interests in and to all collateral described in the Loan Documents (the"Collateral") in order to grant a valid security interest therein. (k) The terms and conditions of any permits, licenses, leases, subleases, contracts, agreements,concessions,franchises,warranties,entitlements,authorizations, instruments, documents, or other properties granted, conveyed, or assigned to Lender pursuant to the Collateral Assignment do not: (i) contain any restrictions or limitations on Borrower's grant, conveyance, or assignment thereof; (ii) require any consent or authorization to such grant, conveyance, or assignment; or (iii) conflict with the terms of the Loan Documents. (I) All consents, approvals, or authorizations necessary for the consummation of the terms of the Loan by Lender, the execution and delivery of the Loan Documents to which it is a party by Lender, and the performance thereof by Lender have been obtained by such parties; and Lender has satisfied those legal requirements that are applicable to it to the extent necessary to make the Loan Documents enforceable against it. (m) Lender is qualified to do business in the State, or is not required to so qualify; and Lender: (i) is duly incorporated, validly existing, and in good standing under the laws of its respective jurisdiction; and (ii) has all necessary powers under its organizational documents and all appropriate laws to engage in the transactions contemplated by the Loan Documents. (n) There has not been any mutual mistake of fact or misunderstanding, fraud, duress, or undue influence; and the conduct of the parties has complied with any requirement of good faith, fair dealing, and conscionability. (0) Lender and Borrower each have acted and will act in good faith and without notice of any defense against the enforcement of any rights created by, or adverse claim to any property or security interest transferred or created as part of, the transaction. (p) There are no agreements or understandings among the parties, written or oral, and there is no usage of trade or course of prior dealing among the parties that would, in either case, define, supplement, or qualify the terms of the Loan Documents. (q) Each of the Loan Documents has been delivered by all parties thereto for valuable consideration actually received; and the proceeds of the Loan will be disbursed as provided in the Loan Documents. (r) Routine procedural requirements, such as service of process,will be satisfied by any party seeking to enforce the Loan Documents. (s) The Loan is not a consumer loan; and the proceeds thereof will not be used for consumer, household, or agricultural-related purposes. (t) We have assumed that the obligations and agreements of Borrower secured by the Z:\Documents\Shoup,Jenny\City of Carmel\I owler Slate Bank VtCDC ,, (I I NovI Opinion\4CDC Opinion.wpd -J- Loan Documents and any documents or instruments now or hereafter evidencing or governing the same do not or will not contain, and will not be modified to contain, a cognovit provision or a confession of judgment. (u) The Loan Documents will be enforced in circumstances and in a manner which are commercially reasonable. Opinions Based upon the foregoing,we are of the opinion that, under applicable State law in effect on the date of this opinion: 1. Borrower is a community development corporation duly organized and validly existing under the laws of the State of Indiana; 2. Borrower has taken the necessary action to authorize the execution and delivery of the Loan Documents to which it is a party; and none of the provisions thereof contravenes or is in conflict with the documents pursuant to which Borrower: (a)was incorporated; and/or (b) is governed; and 3. Each of the Loan Documents to which it is a party constitutes a legal, valid, and binding obligation of Borrower and is enforceable against Borrower in accordance with its terms, except as the same may be limited as provided herein. Qualifications The opinions expressed above are subject to the following qualifications: A. With respect to certain factual determinations underlying the legal conclusions set forth herein, we have relied upon the factual representations and statements of fact of Borrower contained in the Loan Documents. We have not undertaken any independent investigation of the matters addressed in such representations and statements,we have not made any independent review or investigation of any agreements, instruments, orders, judgments, or decrees by which Borrower, or any of its properties may be bound, nor have we made any independent investigation as to the existence of actions, suits, investigations, or proceedings, if any, pending or threatened against Borrower; however, nothing has come to our attention which would cause us to question the accuracy and completeness of such representations and statements, and we have no basis to believe that it is unreasonable to rely thereon. Further, opinions given"to the knowledge of counsel"are based solely on, and are limited to, the current conscious awareness of the individual attorneys who participated in the preparation of this letter, and no investigation or due diligence was undertaken by us in connection with, or is to be inferred from, such opinions. Except as expressly and specifically noted, we have not undertaken any independent investigation to determine the existence or absence of such facts, and we accept no responsibility to make such investigation. No inferences to this firm's knowledge of the existence or the absence of such facts, regarding Borrower should be drawn from the fact of our representation of Borrower. B. The enforceability of the Loan Documents and each of them, and all rights and remedies thereunder, may be limited by: (i) applicable bankruptcy, fraudulent transfer, fraudulent conveyance, liquidation, conservatorship, suretyship, insolvency, reorganization, 7.:\I)ocumems\Shoup,Jenny\City of Carmel\fowler Stale Bank\4CDC 01 Nov I I Opinion\4CDC Opin loll.wpd -4- moratorium, equitable subordination, and other similar laws now or hereafter in effect governing the rights of debtors and creditors and sureties generally; (ii)general principles of equity, including,without limitation, concepts of materiality, reasonableness, good faith, and fair dealing and the possible unavailability of specific performance or injunctive relief, regardless of whether considered in a proceeding in equity or at law; and(iii)applicable laws, statutes, ordinances, rules, regulations,constitutional principles,public policy, and equitable principles that may limit the enforceability of,or render unenforceable: (A)any provision that purports to confer, waive, or consent to the jurisdiction of any court, (B) any waiver by Borrower of remedial and other rights (whether granted by common law or statutorily), including, but not limited to, any rights to appraisement, valuation, stay, extension, or exemption, any so-called moratorium laws, any right of redemption from a foreclosure sale, and any right to a judicial hearing or notice of any action or process to enforce Lender's rights under the Loan Documents, and (C) certain rights, remedies, waivers, and other provisions afforded under the Loan Documents, including, without limitation, "self help"or extrajudicial remedies, the unconditional right of a secured party to the appointment of a receiver without notice or a hearing, the right of a secured party to enter into possession or control, or the operation and management, of property, except by the judicial appointment of a receiver in accordance with applicable law, or the right of a party acting as a receiver of property to exercise any powers granted to a receiver pursuant to the Loan Documents which are in excess of that authorized by an authorizing court or by applicable law. C. The enforceability of the Loan Documents is subject to the effect of generally applicable rules of law that: (i) limit the availability of a remedy under certain circumstances where another remedy has been elected; (ii) that limit the right of a creditor to use force or cause a breach of the peace in enforcing rights; or (iii) relate to the sale or disposition of collateral or the requirements of a commercially reasonable sale. D. We have not made an independent examination of the title to any collateral, and, consequently, we express no opinion with respect thereto or the ownership thereof or with respect to the perfection or the priority of the lien and security interests created thereby. E. We express no opinion as to the enforceability of any prepayment charge secured by the Loan Documents if and to the extent such charge is to become payable: (i) as the result of the acceleration of the indebtedness secured by the Loan Documents; (ii) upon application against such indebtedness of the proceeds of insurance paid as a consequence of damage or destruction of any collateral for the Loan; (iii) upon application against such indebtedness of the proceeds of the exercise, or threat of exercise, of the power of eminent domain; or(iv)as a result of any tax law changes or new taxes becoming due or payable with respect to the Loan Documents. F. We express no opinion as to the validity, binding effect, or enforceability of any provision in the Loan Documents which purports to: (i) permit Lender to sell or otherwise dispose of any collateral except in compliance with the State UCC, applicable laws of the United States of America, and other applicable State and local laws; (ii) provide for a security interest in the proceeds of the personal property other than pursuant to Section 9.1-315 of the State UCC; (iii) impose on Lender standards for the care of personal property in the possession of Lender other than as provided in Section 9.1-207 of the State UCC; or (iv) grant a security interest in collateral which may not be the subject of a security interest therein pursuant to Article 9 of the State UCC. Z:\Documents\Shoup.Jenny\City or Carmel\Fowler Stale[3ank\4CDC 01 Nov l I Opinion\4CDC Opinion.wpd -5- G. We express no opinion as to: (i)the validity or enforceability of any power of attorney purportedly granted by the Loan Documents; (ii)the right to any interest in excess of statutory interest on any amount to which Lender is entitled once a judgment of foreclosure has been rendered; or (iii) any provision intending to secure future loan advances which is not in compliance with IND. CODE § 32-29-1-10. H. The enforceability of the Loan Documents is subject to the effect of generally applicable rules of law that limit the enforceability of provisions which purport to release, exculpate, or exempt any person from,or to require indemnification of, or contribution to, any person for, liability: (i) for such person's own action or inaction, to the extent such action or inaction involves negligence, gross negligence, recklessness,willful misconduct,or unlawful conduct; (ii) under any federal or State securities laws or regulations; or (iii) to the extent otherwise contrary to public policy. The enforceability of the Loan Documents is subject to the effect of laws that govern and afford judicial discretion regarding the determination of damages and entitlement to attorneys' fees and other costs. J. We express no opinion as to the enforceability of any provision in any Loan Document which purports to: (i)change or waive the right to ajury trial, any rules of evidence, trial rules, or statutory or constitutional rights; (ii)waive or fix any statute of limitations or the method or quantum of proof to be applied in litigation or similar proceedings; or(iii) provide for the enforcement of the Loan Documents in any court other than a State court in the county in which the real estate encumbered thereby is located. K. We express no opinion whatsoever as to any document, instrument, agreement, or matter,or the content thereof,which is referenced or incorporated by reference into the Loan Documents, except as necessary to define terms used in the Loan Documents. L. The enforceability of the Loan Documents is subject to the effect of generally applicable rules of law that may,where less than all of a contract may be unenforceable, limit the enforceability of the balance of the contract to circumstances in which the unenforceable portion is not an essential part of the agreed exchange. M. The enforceability of the Loan Documents is subject to the effect of generally applicable rules of law that may permit a party that has materially failed to render or offer performance required by the contract to cure that failure, unless: (i) permitting a cure would unreasonably hinder the aggrieved party from making substitute arrangements for performance; or (ii) it was important in the circumstances to the aggrieved party that performance occur by the date stated in the contract. N. We express no opinion as to the enforceability of any provision of the Loan Documents which purports to require that a waiver or modification of a provision of an instrument or agreement be in writing or, in the absence of express language, to the controlling document in the event of a conflict between or among Loan Documents. 0. We express only those opinions directly stated herein, and any opinions by implication or inference are expressly disclaimed. P. We have not reviewed and do not opine as to: (i) compliance of any property with Z:\Documents\Shoup,Jenny\City or Cannel\Fowler State Bank\4CDC 01Nost I I Opinion\CI)C Opinion.wpd -6- applicable zoning, health, safety, building, environmental, land use, or subdivision laws, ordinances, codes, rules, or regulations; (ii) ERISA laws, rules, or regulations; (iii)federal or State taxation, banking, securities, or "blue sky laws", rules, or regulations; or (iv) zoning, land use, subdivision, or other local, municipal, or county laws, regulations, or ordinances. Q. We express no opinion as to the enforceability of any provision in any of the Loan Documents that assigns or transfers any governmental permit or license. In addition, we express no opinion as to whether Borrower has obtained the necessary governmental permits or licenses necessary to construct and/or operate any property. R. Any provision of the Loan Documents which purports to cover property to be acquired in the future may not be valid as against the rights of intervening third parties. S. We further advise you that, under IND. CODE §§ 34-54-3-1 through 34-54-3-3, any Loan Document ("Additional Debt Instrument") that secures or includes a contract, provision, agreement, or stipulation that gives to Lender the right or the power of attorney on behalf of Borrower or any other party to an Additional Debt Instrument to: (i) appear in any court and waive service of process in an action to enforce the payment of money claimed to be due on the instrument; (ii)confess judgment for any portion of the indebtedness due under the instrument other than by action by the court upon a hearing after due notice; or (iii) release errors and rights of appeal from a judgment rendered for the matters described above or consent to the issue of execution on the judgment for the matters described above; is void. Further, under IND. CODE § 34-54-3-4, a State court will not issue an execution or other process to aid or enforce the collection of any judgment or final decree rendered in another jurisdiction, which judgment or final decree would be unenforceable by a State court applying the above cited statutes, and,consequently,we render no opinion as to whether any instrument which: (i) may now or hereafter be secured by the Loan Documents; and (ii) includes any such provision will allow the Lender to enforce in the State any foregoing judgment or decree rendered thereon. T. To the extent the Loan Documents and/or any document or instrument evidencing or governing the indebtedness and obligations secured thereby contain both: (i) a clause limiting transfer; and (ii)a clause prohibiting prepaying indebtedness for certain periods; the two clauses,taken together, may constitute an unreasonable restraint on alienation such that a court in the State may find one or both of such clauses unenforceable. The foregoing opinions are limited to the laws of the State. This opinion is given solely for the benefit of Lender and may not be referred to, used for any other purpose, or relied upon by any party other than Lender and its respective successors and/or assigns. This opinion is issued only with respect to the present status of the law in the State, and we assume no obligation to update or supplement this opinion in respect to subsequent changes in the law or future events. The opinions that are expressed herein are solely for your benefit and your successors and assigns and may not be relied upon in any manner for any purpose by any other party. Very truly yours, 1- ' 'a.V S 4. \ JJ ( . Wallack Somers & Haas, P.C. Z:\Docurncnts\Shoup,Jenny\City or Carmel\l owlcr State liank\4CDC u I N,' I I Opinion\4CDC Opinion.wpd -7-