MURIEL BOWSER
MAYOR
March 20, 2023
The Honorable Phil Mendelson
Chairman, Council of the District of Columbia
John A. Wilson Building
1350 Pennsylvania Avenue, NW
Suite 504
Washington, DC 20004
Dear Chairman Mendelson:
Enclosed for consideration and approval by the Council of the District of Columbia is a proposed
resolution titled, “D.C. Hebrew Language Charter School d/b/a Sela Public Charter School
Revenue Bonds Project Approval Resolution of 2023” (the “Resolution”).
The Resolution authorizes the issuance, sale, and delivery in an aggregate principal amount not
to exceed $15,000,000 of District of Columbia revenue bonds in one or more series and
authorizes the loan of the proceeds of the bonds to assist Sela in the financing, refinancing, or
reimbursing of costs incurred by Sela for their project located at 6015-17 Chillum Place, NE, in
Ward 4. The project consists of refinancing the bridge loan used to purchase the existing school
property and approximately $4 million in renovations.
Opened in 2013, Sela Public Charter School has a diverse student body and faculty that reflects
the multicultural and vibrant dynamics of the nation’s capital. “Global citizenship” education is a
key school focus. It includes the development of student skills in communication (including
learning a foreign language), collaboration, critical thinking, and creativity. It also includes an
emphasis on building empathy and emotional intelligence, perspective taking, and learning about
other cultures.
The bonds, when, as, and if issued, shall be without recourse to the District. In accordance with
Section 490 of the Home Rule Act, the bonds shall not be general obligations of the District;
shall not be a pledge of or involve the full faith and credit or the taxing power of the District;
shall not constitute a debt of the District; and shall not constitute a lending of public credit for
private undertakings as prohibited in section 602(a)(2) of the Home Rule Act. The bonds shall
not give rise to any pecuniary liability of the District and the District shall have no obligation
with respect to the purchase of the bonds.
I find that the proposed financing will assist in furthering the efforts of SELA in providing
education and employment opportunities to the citizens of the District of Columbia. I urge the Council to take prompt and favorable action on the Resolution. MURIEL BOWSER
MAYOR
March 20, 2023
The Honorable Phil Mendelson
Chairman, Council
of the District of Columbia
John A. Wilson Building
1350 Pennsylvania Avenue,
NW
Suite 504
Washington, DC 20004
Dear Chairman Mendelson:
Enclosed for consideration and approval
by the Council of the District of Columbia is a proposed
resolution titled, "D.C. Hebrew Language Charter School d/b/a Sela Public Charter School
Revenue Bonds Project Approval Resolution
of 2023" (the "Resolution").
The Resolution authorizes the issuance, sale, and delivery in an aggregate principal amount not
to exceed $15,000,000
of District of Columbia revenue bonds in one or more series and
authorizes the loan
of the proceeds of the bonds to assist Sela in the financing, refinancing, or
reimbursing
of costs incurred by Sela for their project located at 6015-1 7 Chill um Place, NE, in
Ward
4. The project consists ofrefinancing the bridge loan used to purchase the existing school
property and approximately $4 million in renovations.
Opened in 2013, Sela Public Charter School has a diverse student body and faculty that reflects
the multicultural and vibrant dynamics
of the nation's capital. "Global citizenship" education is a
key school focus.
It includes the development of student skills in communication (including
learning a foreign language), collaboration, critical thinking, and creativity.
It also includes an
emphasis on building empathy and emotional intelligence, perspective taking, and learning about
other cultures.
The bonds, when, as, and
if issued, shall be without recourse to the District. In accordance with
Section 490
of the Home Rule Act, the bonds shall not be general obligations of the District;
shall not be a pledge of or involve the full faith and credit or the taxing power of the District;
shall not constitute a debt of the District; and shall not constitute a lending of public credit for
private undertakings as prohibited in section 602(a)(2)
of the Home Rule Act. The bonds shall
not give rise to any pecuniary liability
of the District and the District shall have no obligation
with respect to the purchase
of the bonds.
I find that the proposed financing will assist in furthering the efforts
of SELA in providing
education and employment opportunities to the citizens
of the District of Columbia. I urge the Council to take prompt and favorable action on the Resolution. hairman Phil Mendelson
at the request
of the Mayor
1
2
3
4
5
6
7 A PROPOSED RESOLUTION
8
9
10
11
IN THE COUNCIL OF THE DISTRICT OF COLUMBIA
12 To authorize and provide for the issuance, sale, and delivery in an aggregate principal amount not to
13 exceed $15 million of District of Columbia revenue bonds in one or more series and to
14 authorize and provide for the loan of the proceeds of such bonds to assist D.C. Hebrew
15 Language Charter School d/b/a Sela Public Charter School in the financing, refinancing,
16 or reimbursing of costs associated with an authorized project pursuant to section 490 of the
1 7 District
of Columbia Home Rule Act.
18
19 RESOLVED, BY THE COUNCIL OF THE DISTRICT OF COLUMBIA, that this
20 resolution may be cited
as the "D.C. Hebrew Language Charter School d/b/a Sela Public Charter
21 School Revenue Bonds Project Approval Resolution of 2023 ".
22
23 Sec. 2. Definitions.
24 For the purpose
of this resolution, the term:
25
(1) "Authorized Delegate" means the Mayor or the Deputy Mayor for Planning and
26 Economic Development, or any officer or employee
of the Executive Office of the Mayor to whom
2 7 the Mayor has delegated or to whom the foregoing individuals have subdelegated any
of the
28 Mayor's functions under this resolution pursuant
to section 422( 6) of the Home Rule Act.
29 (2) "Bond Counsel" means a firm or firms of attorneys designated as bond counsel
30 from time to time by the Mayor. 31 (3) "Bonds" means the District of Columbia revenue bonds, notes, or other
32 obligations (including refunding bonds, notes, and other obligations),
in one or more series,
33 authorized to be issued pursuant to this resolution.
34 (4) "Borrower" means the owner, operator, manager and user
of the assets
35 financed, refinanced, or reimbursed with proceeds from the Bonds, which shall be D.C. Hebrew
36 Language Charter School d/b/a Sela Public Charter School, Inc., a corporation organized under
37 the laws
of the District of Columbia, which is exempt from federal income taxes under 26 U.S.C
38 § 501(a)
as an organization described in 26 U.S.C. § 501(c)(3), and which is liable for the
39 repayment
of the Bonds.
40 (5) "Closing Documents" means all documents and agreements other than
41 Financing Documents that may be necessary and appropriate to issue, sell, and deliver the Bonds
42 and to make the Loan contemplated thereby, and includes agreements, certificates, letters, opinions,
43 forms, receipts, and other similar instruments.
44 ( 6) "District" means the District
of Columbia.
45 (7) "Financing Documents" means the documents other than Closing Documents
46 that relate to the financing or refinancing
of transactions to be effected through the issuance, sale,
4 7 and delivery
of the Bonds and the making of the Loan, including any offering document, and any
48 required supplements to any such documents.
49 (8) "Home Rule Act" means the District
of Columbia Home Rule Act, approved
50 December 24, 1973 (87 Stat. 774; D.C. Official
Code§ 1-201.01 et seq.).
51 (9) "Issuance Costs" means all fees, costs, charges, and expenses paid or incurred
52 in connection with the authorization, preparation, printing, issuance, sale, and delivery
of the Bonds
53 and the making of the Loan, including, but not limited to, underwriting, legal, accounting, rating
2 54 agency, and all other fees, costs, charges, and expenses incurred in connection with the development
5 5 and implementation
of the Financing Documents, the Closing Documents, and those other
56 documents necessary or appropriate in connection with the authorization, preparation, printing,
57 issuance, sale, marketing, and delivery
of the Bonds and the making of the Loan contemplated
5 8 thereby, together with financing fees, costs, and expenses, including program fees and
5 9 administrative fees charged by the District, fees paid to financial institutions and insurance
60 companies, initial letter
of credit fees (if any), compensation to financial advisors and other persons
61 ( other than full-time employees of the District) and entities performing services on behalf of or as
62 agents for the District.
63 ( 10) "Loan" means the District's lending of proceeds from the sale, in one or more
64 series,
of the Bonds to the Borrower.
65 (11) "Project" means the financing, refinancing or reimbursing of all or a portion of
66 the Borrower's costs of:
67 (A) refinancing of certain existing indebtedness, the proceeds of which were
68 used to finance or refinance the costs of the acquisition of the Borrower's approximately 12,269
69 square foot public charter school facility located 6015-17 Chillum Place, N.E., Washington, D.C.,
70 together with associated parking facilities and other property, real and personal, associated
71 therewith (the "Facility");
72 (B) funding the renovation, fit-out, equipping and development
of the
73 Facility;
74 (C) funding certain working capital costs, to the extent financeable relating
75 to the Bonds;
3 76 (D) funding any credit enhancement costs, liquidity costs, capitalized
77 interest, or debt service reserve fund relating
to the Bonds; and
78 (E) paying allowable Issuance Costs.
79 Sec.
3. Findings.
80 The Council finds that:
81 ( 1) Section 490 of the Home Rule Act provides that the Council may by resolution
82 authorize the issuance
of District revenue bonds, notes, or other obligations (including refunding
83 bonds, notes, or other obligations) to borrow money to finance, refinance, or reimburse and to assist
84 in the financing, refinancing, or reimbursing
of undertakings in certain areas designated in section
85 490 and may effect the financing, refinancing, or reimbursement by loans made directly or
86 indirectly to any individual or legal entity, by the purchase
of any mortgage, note, or other security,
87 or by the purchase, lease, or sale
of any property.
88 (2) The Borrower has requested the District to issue, sell, and deliver revenue
89 bonds, in one or more series, in an aggregate principal amount not to exceed $15 million, and
to
90 make the Loan for the purpose of financing, refinancing, or reimbursing costs of the Project.
91 (3) The Project is located in the District and will contribute to the health, education,
92 safety, or welfare of, or the creation or preservation
of jobs for, residents of the District, or to
93 economic development of the District.
94 ( 4) The Project
is an undertaking in the area of elementary, secondary and college
95 and university facilities within the meaning of section 490 of the Home Rule Act.
96 ( 5) The authorization, issuance, sale, and delivery of the Bonds and the Loan to the
97 Borrower are desirable, are in the public interest, will promote the purpose and intent of section 490
98 of the Home Rule Act, and will assist the Project.
4 99 Sec. 4. Bond authorization.
100 (a) The Mayor
is authorized pursuant to the Home Rule Act and this resolution to assist in
101 financing, refinancing, or reimbursing the costs of the Project by:
102 (
1) The issuance, sale, and delivery of the Bonds, in one or more series, in an
103 aggregate principal amount not to exceed $15 million; and
104 (2) The making
of the Loan.
105 (b) The Mayor
is authorized to make the Loan to the Borrower for the purpose of financing,
106 refinancing, or reimbursing the costs
of the Project and establishing any fund with respect to the
107 Bonds
as required by the Financing Documents.
108 (
c) The Mayor may charge a program fee to the Borrower, including, but not limited to, an
109 amount sufficient to cover costs and expenses incurred by the District in connection with the
110 issuance, sale, and delivery
of each series of the Bonds, the District's participation in the monitoring
111 of the use of the Bond proceeds and compliance with any public benefit agreements with the
112 District, and maintaining official records
of each bond transaction and assisting in the redemption,
113 repurchase, and remarketing of the Bonds.
114 ( d) The Bond authorization set forth in this resolution includes the authorization to issue
115 refunding Bonds to refinance any Bonds previously issued under this resolution to finance the
116 Project; provided, that the maximum principal amount
of Bonds outstanding at any time does not
11 7 exceed the maximum principal amount of Bonds authorized hereunder.
118 Sec.
5. Bond details.
119 (a) The Mayor and each Authorized Delegate is authorized to take any action reasonably
120 necessary or appropriate in accordance with this resolution in connection with the preparation,
121 execution, issuance, sale, delivery, security for, and payment of the Bonds of each series, including,
5 122 but not limited to, determinations of:
123 ( 1) The final form, content, designation, and terms of the Bonds, including a
124 determination that the Bonds may be issued in certificated or book-entry form;
125 (2) The principal amount of the Bonds to be issued and denominations of the
126 Bonds;
127 (3) The rate or rates
of interest or the method for determining the rate or rates of
128 interest on the Bonds;
129 . ( 4) The date or dates
of issuance, sale, and delivery of, and the payment of interest
130 on the Bonds, and the maturity date or dates
of the Bonds;
131 ( 5) The terms under which the Bonds may be paid, optionally or mandatorily
132 redeemed, accelerated, tendered, called, or put for redemption, repurchase, or remarketing before
133 their respective stated maturities;
134 ( 6) Provisions for the registration, transfer, and exchange
of the Bonds and the
13 5 replacement of mutilated, lost, stolen, or destroyed Bonds;
136 (7) The creation
of any reserve fund, sinking fund, or other fund with respect to the
137 Bonds;
13 8 (8) The time and place of payment of the Bonds;
139 (9) Procedures for monitoring the use
of the proceeds received from the sale of the
140 Bonds to ensure that the proceeds are properly applied to the Project and used to accomplish the
141 purposes of the Home Rule Act and this resolution;
142 (10) Actions necessary to qualify the Bonds under blue sky laws
of any jurisdiction
143 where the Bonds are marketed; and
6 144 (11) The terms and types of credit enhancement under which the Bonds may be
145 secured.
146 (b)
The Bonds shall contain a legend, which shall provide that the Bonds are special
14 7 obligations
of the District, are without recourse to the District, are not a pledge of, and do not
148 involve the faith
and credit or the taxing power of the District, do not constitute a debt of the
149 District, and do
not constitute lending of the public credit for private undertakings as prohibited in
150 section 602(a)(2)
of the Home Rule Act.
151 ( c) The Bonds shall
be executed in the name of the District and on its behalf by the manual
15 2 or facsimile signature of the Mayor, and attested by the Secretary of the District of Columbia by the
153 Secretary
of the District of Columbia's manual or facsimile signature. The Mayor's execution and
154 delivery
of the Bonds shall constitute conclusive evidence of the Mayor's approval, on behalf of the
15 5 District, of the final form and content of the Bonds.
156 ( d)
The official seal of the District, or a facsimile of it, shall be impressed, printed, or
157 otherwise reproduced on the Bonds.
15 8 ( e) The Bonds of any series may be issued in accordance with the terms of a trust instrument
159 to
be entered into by the District and a trustee to be selected by the Borrower subject to the approval
160
of the Mayor, and may be subject to the terms of one or more agreements entered into by the Mayor
161 pursuant to section 490(a)(4) of the Home Rule Act.
162 (f) The Bonds
may be issued at any time or from time to time in one or more issues and in
163
one or more senes.
164 Sec. 6. Sale
of the Bonds.
7 165 (a) The Bonds of any series may be sold at negotiated or competitive sale at, above, or
166 below par,
to one or more persons or entities, and upon terms that the Mayor considers to be in the
167 best interest
of the District.
168 (b) The Mayor or an Authorized Delegate may execute, in connection with each sale
of the
169 Bonds, offering documents on behalf
of the District, may deem final any such offering document on
170 behalf
of the District for purposes of compliance with federal laws and regulations governing such
171 matters and may authorize the distribution of the documents in connection with the sale of the
172 Bonds.
1
73 ( c) The Mayor is authorized to deliver the executed and sealed Bonds, on behalf of the
174 District, for authentication, and, after the Bonds have been authenticated, to deliver the Bonds to the
175 original purchasers
of the Bonds upon payment of the purchase price.
176 (
d) The Bonds shall not be issued until the Mayor receives an approving opinion from Bond
177 Counsel
as to the validity of the Bonds of such series and, if the interest on the Bonds is expected to
178 be exempt from federal income taxation, the treatment of the interest on the Bonds for purposes of
1 79 federal income taxation.
180 Sec.
7. Payment and security.
181 (a) The principal of, premium, if any, and interest on, the Bonds shall be payable solely from
182 proceeds received from the sale
of the Bonds, income realized from the temporary investment of
183 those proceeds, receipts and revenues realized by the District from the Loan, income realized from
184 the temporary investment
of those receipts and revenues prior to payment to the Bond owners, other
185 moneys that,
as provided in the Financing Documents, may be made available to the District for the
8 186 payment of the Bonds, and other sources of payment (other than from the District), all as provided
187 for in the Financing Documents.
188 (b) Payment
of the Bonds shall be secured as provided in the Financing Documents and by
189 an assignment by the District for the benefit of the Bond owners of certain of its rights under the
190 Financing Documents and Closing Documents, including a security interest in certain collateral,
if
191 any, to the trustee for the Bonds pursuant to the Financing Documents.
192 ( c) The trustee is authorized to deposit, invest, and disburse the proceeds received from the
193 sale
of the Bonds pursuant to the Financing Documents.
194 Sec.
8. Financing and Closing Documents.
195 (a) The
Mayor is authorized to prescribe the final form and content of all Financing
196 Documents and all Closing Documents that
may be necessary or appropriate to issue, sell, and
197 deliver the Bonds and to make the
Loan to the Borrower.
198 (b) The Mayor is authorized to execute, in the name
of the District and on its behalf, the
199 Financing Documents and any Closing Documents to which the District is a party
by the Mayor's
200 manual or facsimile signature.
201 ( c)
If required, the official seal of the District, or a facsimile of it, shall be impressed,
202 printed,
or otherwise reproduced on the Financing Documents and the Closing Documents to which
203 the District is a party.
204 (d) The
Mayor's execution and delivery of the Financing Documents and the Closing
205 Documents to which the District is a party shall constitute conclusive evidence
of the Mayor's
206 approval, on behalf of the District, of the final form and content of the executed Financing
207 Documents and the executed Closing Documents.
9 208 ( e) The Mayor is authorized to deliver the executed and sealed Financing Documents and
209 Closing Documents, on behalf
of the District, prior to or simultaneously with the issuance, sale, and
210 delivery
of the Bonds, and to ensure the due performance of the obligations of the District contained
211 in the executed, sealed, and delivered Financing Documents and Closing Documents.
212 Sec.
9. Authorized delegation of authority.
213 To the extent permitted by District and federal laws, the Mayor may delegate to any
214 Authorized Delegate the performance
of any function authorized to be performed by the Mayor
215 under this resolution.
216 Sec.
10. Limited liability.
21 7 (a) The Bonds shall be special obligations of the District. The Bonds shall be without
218 recourse to the District. The Bonds shall not be general obligations
of the District, shall not be a
219 pledge
of or involve the faith and credit or the taxing power of the District, shall l}.Ot constitute a
220 debt
of the District, and shall not constitute lending of the public credit for private undertakings as
221 prohibited in section 602(a)(2) of the Home Rule Act.
222 (b) The Bonds shall not give rise to any pecuniary liability
of the District and the District
223 shall have no obligation with respect to the purchase
of the Bonds.
224 (c) Nothing contained in the Bonds, in the Financing Documents, or in the Closing
225 Documents shall create an obligation on the part
of the District to make payments with respect to
226 the Bonds from sources other than those listed for that purpose in section 7.
227 ( d) The District shall have no liability for the payment of any Issuance Costs or for any
228 transaction or event to be effected by the Financing Documents.
229 (
e) All covenants, obligations, and agreements of the District contained in this resolution,
230 the Bonds, and the executed, sealed, and delivered Financing Documents and Closing Documents
to
10 231 which the District is a party, shall be considered to be the covenants, obligations, and agreements of
232 the District to the fullest extent authorized by law, and each of those covenants, obligations, and
233 agreements shall be binding upon the District, subject to the limitations set forth in this resolution.
234 (f) No person, including, but not limited to, the Borrower and any Bond owner, shall have
23 5 any claims against the District or any of its elected or appointed officials, officers, employees, or
236 agents for monetary damages suffered
as a result of the failure of the District or any of its elected or
23 7 appointed officials, officers, employees or agents to perform any covenant, undertaking, or
23 8 obligation under this resolution, the Bonds, the Financing Documents, or the Closing Documents,
239 nor
as a result of the incorrectness of any representation in or omission from the Financing
240 Documents or the Closing Documents, unless the District or its elected or appointed officials,
241 officers, employees, or agents have acted in a willful and fraudulent manner.
242 Sec.
11. District officials.
243 (a) Except
as otherwise provided in section l0(f), the elected or appointed officials, officers,
244 employees, or agents
of the District shall not be liable personally for the payment of the Bonds or be
245 subject to any personal liability by reason
of the issuance, sale or delivery of the Bonds, or for any
246 representations, warranties, covenants, obligations, or agreements
of the District contained in this
24 7 resolution, the Bonds, the Financing Documents, or the Closing Documents.
248 (b) The signature, countersignature, facsimile signature, or facsimile countersignature
of
249 any official appearing on the Bonds, the Financing Documents, or the Closing J?ocuments shall
250 be valid and sufficient for all purposes notwithstanding the fact that the individual signatory
251 ceases to hold that office before delivery of the Bonds, the Financing Documents, or the Closing
252 Documents.
253 Sec.
12. Maintenance of documents.
11 254 Copies of the specimen Bonds and of the final Financing Documents and Closing
25 5 Documents shall be filed in the Office of the Secretary of the District of Columbia.
256 Sec.
13. Informatio'n reporting.
257 Within three (3) days after the Mayor's receipt
of the transcript of proceedings relating to
25 8 the issuance of the Bonds, the Mayor shall transmit a copy of the transcript to the Secretary to the
25 9 Council.
260 Sec.
14. Disclaimer.
261 (a) The issuance of Bonds is in the discretion of the District. Nothing contained in this
262 resolution, the Bonds, the Financing Documents, or the Closing Documents shall be construed
as
263 obligating the District to issue any Bonds for the benefit of the Borrower or to participate in or assist
264 the Borrower in any way with financing, refinancing, or reimbursing the costs
of the Project. The
265 Borrower shall have no claims for damages or for any other legal or equitable relief against the
266 District, its elected or appointed officials, officers, employees, or agents
as a consequence of any
267 failure
to issue any Bonds for the benefit of the Borrower.
268 (b) The District reserves the right
to issue the Bonds in the order or priority it determines in
269 its sole and absolute discretion. The District gives no assurance and makes no representations that
270 any portion
of any limited amount of bonds or other obligations, the interest on which is excludable
2
71 from gross income for federal income tax purposes, will be reserved or will be available at the time
2 72
of the proposed issuance of the Bonds.
2
73 ( c) The District, by adopting this resolution or by taking any other action in connection with
274 financing, refinancing, or reimbursing costs
of the Project, does not provide any assurance that the
275 Project
is viable or sound, that the Borrower is financially sound, or that amounts owing on the
12 276 Bonds or pursuant to the Loan will be paid. Neither the Borrower, any purchaser of the Bonds, nor
277 any other person shall rely upon the District with respect
to these matters.
278 Sec.
15. Expiration.
279
If any Bonds are not issued, sold, and delivered to the original purchaser within three (3)
280 years
of the date of this resolution, the authorization provided in this resolution with respect to the
281 issuance, sale, and delivery of the Bonds shall expire.
282 Sec.
16. Severability.
283
If any particular provision of this resolution, or the application thereof to any person or
284 circumstance
is held invalid, the remainder of this resolution and the application of such provision
285 to other persons or circumstances shall not be affected thereby.
If any action or inaction
286 contemplated under this resolution
is determined to be contrary to the requirements of applicable
287 law, such action or inaction shall not be necessary for the purpose
of issuing the Bonds, and the
288 validity
of the Bonds shall not be adversely affected.
289 Sec.
17. Compliance with public approval requirement.
290 This approval shall constitute the approval
of the Council as required in section 147(f) of the
291 Internal Revenue Code of 1986, as amended, and section 490(k) of the Home Rule Act, for the
292 Project to be financed, refinanced, or reimbursed with the proceeds
of the Bonds. This resolution
293 approving the issuance
of the Bonds for the Project has been adopted by the Council after a public
294 hearing held
at least seven (7) days after publication of notice in a newspaper of general circulation
295 in the District.
296 Sec.
18. Transmittal.
297 The Council shall transmit a copy
of this resolution, upon its adoption, to the Mayor.
298 Sec.
19. Fiscal impact statement.
13 299 The Council adopts the fiscal impact statement of the Chief Financial Officer as
300 the fiscal impact statement required by section 4a of the General Legislative Procedures Act of
301 1975, approved October 16, 2006 (120 Stat. 2038; D.C. Official Code § 1-301.4 7a).
302 · Sec.
20. Effective date.
303 This resolution shall take effect immediately.
14 DC Hebrew Language Charter School
(Sela) Revenue Bond Project
FACT SHEET
DC Hebrew Language Charter School Inc (Sela) has requested that the District of Columbia
issue up to $15,000,000
of 501(c)(3) revenue bonds, refinancing, and renovations to support
construction projects at 6015-17 Chillum Place NE Washington, DC in Ward
4.
The Applicant
Opened in 2013 in DC's Ward 4, Sela Public Charter School has a diverse student body and
faculty that reflects the multicultural and vibrant dynamics
of the nation's capital.
"Global citizenship" education
is a key school focus. It includes the development of student
skills in communication (including learning a foreign language), collaboration, critical thinking,
and creativity.
It also includes an emphasis on building empathy and emotional intelligence,
perspective taking, and learning about other cultures.
Sela has been recognized
as a high-performing school by the DC Public Charter School Board.
The school offers an academically rigorous curriculum, including daily Modem Hebrew studies,
that lead to a high level
of language proficiency.
Proposed Proiect
DC Hebrew Language Public Charter School (Sela) project consists of refinancing the bridge
loan used to purchase the existing school property and approximately $4 million in renovations. DC Hebrew Language Public Charter School (Sela)
Fact Sheet
February 2023
Financing Plan
A summary of the proposed sources and uses of funds is attached (see Table 1 ).
Total Cost Tax-exempt Taxable Loan Equity
Bond Proceeds
Refinancing/Refunding $7,825,000
Building Renovation $6,000,000
Up-frontfees/Other $220,000 $280,000
Issuance costs
Contingency $955,000
TOTAL $15,000,000 $280,000
Feasibility/Structure/Security of the Bonds
A commitment letter to provide a direct pay letter of credit was included in the application from
ConnectOne, who will also serve
as underwriter. The bonds will be repaid at a synthetically
fixed interest rate (to be determined based on market conditions) over 25 years (with payments
beginning one year after closing). A Bond Trustee has not been selected.
Bonds will be a general obligation
of DC Hebrew Language Public Charter School (Sela) and
will be repaid primarily
by revenues from tuition.
Legal and Regulatory Affairs
The law firm of Orrick, Herrington, & Sutcliffe bond counsel to the Revenue Bond Program, has
preliminarily determined that DC Hebrew Language Public Charter School is a 501 ( c )(3)
organization and that the project constitutes a permissible undertaking within the meaning
of
Section 490( a)( 1) of the District of Columbia Home Rule Act.
The Office
of Planning, Office of Tax and Revenue and Department of Employment Services,
Department
of Consumer and Regulatory Affairs have all approved the application.
Based upon the information set forth in the application, the Revenue Bond Program staff has
determined that the proposed project complies with criteria for approval
of a proposed financing
transaction through the District's Revenue Bond Program and will assist the Borrower in
furthering its organizational mission.
2 GOVERNMENT OF THE DISTRICT OF COLUMBIA
OFFICE OF THE ATTORNEY GENERAL
Commercial Division
Tax
& Finance Section
*** --
MEMORANDUM
TO:
FROM:
William Liggins
Director, Revenue Bond Program
Office
of the Deputy Mayor for Planning and Economic Development
Patrick Allen
Senior Assistant Attorney General
Commercial Division
DATE: February 23, 2023
SUBJECT: Legal Sufficiency Certification
of the "D.C. Hebrew Language Charter
School d/b/a Sela Public Charter School Revenue Bonds Project Approval
Resolution
of 2023 ".
This is to certify that the Office
of the Attorney General has reviewed the above
referenced resolution and found it to be legally sufficient.
If you have any questions in
this regard, please do not hesitate to call me at (202) 724-7754.
Patrick Allen
Senior Assistant Attorney General 2
(3) “Bonds” means the District of Columbia revenue bonds, notes, or other 31
obligations (including refunding bonds, notes, and other obligations), in one or more series, 32
authorized to be issued pursuant to this resolution. 33
(4) “Borrower” means the owner, operator, manager and user of the assets 34
financed, refinanced, or reimbursed with proceeds from the Bonds, which shall be D.C. Hebrew 35
Language Charter School d/b/a Sela Public Charter School, Inc., a corporation organized under 36
the laws of the District of Columbia, which is exempt from federal income taxes under 26 U.S.C 37
§ 501(a) as an organization described in 26 U.S.C. § 501(c)(3), and which is liable for the 38
repayment of the Bonds. 39
(5) “Closing Documents” means all documents and agreements other than 40
Financing Documents that may be necessary and appropriate to issue, sell, and deliver the Bonds 41
and to make the Loan contemplated thereby, and includes agreements, certificates, letters, opinions, 42
forms, receipts, and other similar instruments. 43
(6) "District" means the District of Columbia. 44
(7) “Financing Documents” means the documents other than Closing Documents 45
that relate to the financing or refinancing of transactions to be effected through the issuance, sale, 46
and delivery of the Bonds and the making of the Loan, including any offering document, and any 47
required supplements to any such documents. 48
(8) “Home Rule Act” means the District of Columbia Home Rule Act, approved 49
December 24, 1973 (87 Stat. 774; D.C. Official Code § 1- 201.01 et seq.). 50
(9) “Issuance Costs” means all fees, costs, charges, and expenses paid or incurred 51
in connection with the authorization, preparation, printing, issuance, sale, and delivery of the Bonds 52
and the making of the Loan, including, but not limited to, underwriting, legal, accounting, rating 53 3
agency, and all other fees, costs, charges, and expenses incurred in connection with the development 54
and implementation of the Financing Documents, the Closing Documents, and those other 55
documents necessary or appropriate in connection with the authorization, preparation, printing, 56
issuance, sale, marketing, and delivery of the Bonds and the making of the Loan contemplated 57
thereby, together with financing fees, costs, and expenses, including program fees and 58
administrative fees charged by the District, fees paid to financial institutions and insurance 59
companies, initial letter of credit fees (if any), compensation to financial advisors and other persons 60
(other than full-time employees of the District) and entities performing services on behalf of or as 61
agents for the District. 62
(10) “Loan” means the District’s lending of proceeds from the sale, in one or more 63
series, of the Bonds to the Borrower. 64
(11) “Project” means the financing, refinancing or reimbursing of all or a portion of 65
the Borrower's costs of: 66
(A) refinancing of certain existing indebtedness, the proceeds of which were 67
used to finance or refinance the costs of the acquisition of the Borrower’s approximately 12,269 68
square foot public charter school facility located 6015-17 Chillum Place, N.E., Washington, D.C., 69
together with associated parking facilities and other property, real and personal, associated 70
therewith (the “Facility”); 71
(B) funding the renovation, fit -out, equipping and development of the 72
Facility; 73
(C) funding certain working capital costs, to the extent financeable relating 74
to the Bonds; 75 4
(D) funding any credit enhancement costs, liquidity costs, capitalized 76
interest, or debt service reserve fund relating to the Bonds; and 77
(E) paying allowable Issuance Costs. 78
Sec. 3. Findings. 79
The Council finds that: 80
(1) Section 490 of the Home Rule Act provides that the Council may by resolution 81
authorize the issuance of District revenue bonds, notes, or other obligations (including refunding 82
bonds, notes, or other obligations) to borrow money to finance, refinance, or reimburse and to assist 83
in the financing, refinancing, or reimbursing of undertakings in certain areas designated in section 84
490 and may effect the financing, refinancing, or reimbursement by loans made directly or 85
indirectly to any individual or legal entity, by the purchase of any mortgage, note, or other security, 86
or by the purchase, lease, or sale of any property. 87
(2) The Borrower has requested the District to issue, sell, and deliver revenue 88
bonds, in one or more series, in an aggregate principal amount not to exceed $15 million, and to 89
make the Loan for the purpose of financing, refinancing, or reimbursing costs of the Project. 90
(3) The Project is located in the District and will contribute to the health, education, 91
safety, or welfare of, or the creation or preservation of jobs for, residents of the District, or to 92
economic development of the District. 93
(4) The Project is an undertaking in the area of elementary, secondary and college 94
and university facilities within the meaning of section 490 of the Home Rule Act. 95
(5) The authorization, issuance, sale, and delivery of the Bonds and the Loan to the 96
Borrower are desirable, are in the public interest, will promote the purpose and intent of section 490 97
of the Home Rule Act, and will assist the Project. 98 5
Sec. 4. Bond authorization. 99
(a) The Mayor is authorized pursuant to the Home Rule Act and this resolution to assist in 100
financing, refinancing, or reimbursing the costs of the Project by: 101
(1) The issuance, sale, and delivery of the Bonds, in one or more series, in an 102
aggregate principal amount not to exceed $15 million; and 103
(2) The making of the Loan. 104
(b) The Mayor is authorized to make the Loan to the Borrower for the purpose of financing, 105
refinancing, or reimbursing the costs of the Project and establishing any fund with respect to the 106
Bonds as required by the Financing Documents. 107
(c) The Mayor may charge a program fee to the Borrower, including, but not limited to, an 108
amount sufficient to cover costs and expenses incurred by the District in connection with the 109
issuance, sale, and delivery of each series of the Bonds, the District’s participation in the monitoring 110
of the use of the Bond proceeds and compliance with any public benefit agreements with the 111
District, and maintaining official records of each bond transaction and assisting in the redemption, 112
repurchase, and remarketing of the Bonds. 113
(d) The Bond authorization set forth in this r esolution includes the authorization to issue 114
refunding Bonds to refinance any Bonds previously issued under this r esolution to finance the 115
Project; provided, that the maximum principal amount of Bonds outstanding at any time does not 116
exceed the maximum principal amount of Bonds authorized hereunder. 117
Sec. 5. Bond details. 118
(a) The Mayor and each Authorized Delegate is authorized to take any action reasonably 119
necessary or appropriate in accordance with this resolution in connection with the preparation, 120
execution, issuance, sale, delivery, security for, and payment of the Bonds of each series, including, 121 6
but not limited to, determinations of: 122
(1) The final form, content, designation, and terms of the Bonds, including a 123
determination that the Bonds may be issued in certificated or book- entry form; 124
(2) The principal amount of the Bonds to be issued and denominations of the 125
Bonds; 126
(3) The rate or rates of interest or the method for determining the rate or rates of 127
interest on the Bonds; 128
(4) The date or dates of issuance, sale, and delivery of, and the payment of interest 129
on the Bonds, and the maturity date or dates of the Bonds; 130
(5) The terms under which the Bonds may be paid, optionally or mandatorily 131
redeemed, accelerated, tendered, called, or put for redemption, repurchase, or remarketing before 132
their respective stated maturities; 133
(6) Provisions for the registration, transfer, and exchange of the Bonds and the 134
replacement of mutilated, lost, stolen, or destroyed Bonds; 135
(7) The creation of any reserve fund, sinking fund, or other fund with respect to the 136
Bonds; 137
(8) The time and place of payment of the Bonds; 138
(9) Procedures for monitoring the use of the proceeds received from the sale of the 139
Bonds to ensure that the proceeds are properly applied to the Project and used to accomplish the 140
purposes of the Home Rule Act and this resolution; 141
(10) Actions necessary to qualify the Bonds under blue sky laws of any jurisdiction 142
where the Bonds are marketed; and 143 7
(11) The terms and types of credit enhancement under which the Bonds may be 144
secured. 145
(b) The Bonds shall contain a legend, which shall provide that the Bonds are special 146
obligations of the District, are without recourse to the District, are not a pledge of, and do not 147
involve the faith and credit or the taxing power of the District, do not constitute a debt of the 148
District, and do not constitute lending of the public credit for private undertakings as prohibited in 149
section 602(a)(2) of the Home Rule Act. 150
(c) The Bonds shall be executed in the name of the District and on its behalf by the manual 151
or facsimile signature of the Mayor, and attested by the Secretary of the District of Columbia by the 152
Secretary of the District of Columbia’s manual or facsimile signature. The Mayor’s execution and 153
delivery of the Bonds shall constitute conclusive evidence of the Mayor’s approval, on behalf of the 154
District, of the final form and content of the Bonds. 155
(d) The official seal of the District, or a facsimile of it, shall be impressed, printed, or 156
otherwise reproduced on the Bonds. 157
(e) The Bonds of any series may be issued in accordance with the terms of a trust instrument 158
to be entered into by the District and a trustee to be selected by the Borrower subject to the approval 159
of the Mayor, and may be subject to the terms of one or more agreements entered into by the Mayor 160
pursuant to section 490(a)(4) of the Home Rule Act. 161
(f) The Bonds may be issued at any time or from time to time in one or more issues and in 162
one or more series. 163
Sec. 6. Sale of the Bonds. 164 8
(a) The Bonds of any series may be sold at negotiated or competitive sale at, above, or 165
below par, to one or more persons or entities, and upon terms that the Mayor considers to be in the 166
best interest of the District. 167
(b) The Mayor or an Authorized Delegate may execute, in connection with each sale of the 168
Bonds, offering documents on behalf of the District, may deem final any such offering document on 169
behalf of the District for purposes of compliance with federal laws and regulations governing such 170
matters and may authorize the distribution of the documents in connection with the sale of the 171
Bonds. 172
(c) The Mayor is authorized to deliver the executed and sealed Bonds, on behalf of the 173
District, for authentication, and, after the Bonds have been authenticated, to deliver the Bonds to the 174
original purchasers of the Bonds upon payment of the purchase price. 175
(d) The Bonds shall not be issued until the Mayor receives an approving opinion from Bond 176
Counsel as to the validity of the Bonds of such series and, if the interest on the Bonds is expected to 177
be exempt from federal income taxation, the treatment of the interest on the Bonds for purposes of 178
federal income taxation. 179
Sec. 7. Payment and security. 180
(a) The principal of, premium, if any, and interest on, the Bonds shall be payable solely from 181
proceeds received from the sale of the Bonds, income realized from the temporary investment of 182
those proceeds, receipts and revenues realized by the District from the Loan, income realized from 183
the temporary investment of those receipts and revenues prior to payment to the Bond owners, other 184
moneys that, as provided in the Financing Documents, may be made available to the District for the 185 9
payment of the Bonds, and other sources of payment (other than from the District), all as provided 186
for in the Financing Documents. 187
(b) Payment of the Bonds shall be secured as provided in the Financing Documents and by 188
an assignment by the District for the benefit of the Bond owners of certain of its rights under the 189
Financing Documents and Closing Documents, including a security interest in certain collateral, if 190
any, to the trustee for the Bonds pursuant to the Financing Documents. 191
(c) The trustee is authorized to deposit, invest, and disburse the proceeds received from the 192
sale of the Bonds pursuant to the Financing Documents. 193
Sec. 8. Financing and Closing Documents. 194
(a) The Mayor is authorized to prescribe the final form and content of all Financing 195
Documents and all Closing Documents that may be necessary or appropriate to issue, sell, and 196
deliver the Bonds and to make the Loan to the Borrower. 197
(b) The Mayor is authorized to execute, in the name of the District and on its behalf, the 198
Financing Documents and any Closing Documents to which the District is a party by the Mayor’s 199
manual or facsimile signature. 200
(c) If required, the official seal of the District, or a facsimile of it, shall be impressed, 201
printed, or otherwise reproduced on the Financing Documents and the Closing Documents to which 202
the District is a party. 203
(d) The Mayor’s execution and delivery of the Financing Documents and the Closing 204
Documents to which the District is a party shall constitute conclusive evidence of the Mayor’s 205
approval, on behalf of the District, of the final form and content of the executed Financing 206
Documents and the executed Closing Documents. 207 10
(e) The Mayor is authorized to deliver the executed and sealed Financing Documents and 208
Closing Documents, on behalf of the District, prior to or simultaneously with the issuance, sale, and 209
delivery of the Bonds, and to ensure the due performance of the obligations of the District contained 210
in the executed, sealed, and delivered Financing Documents and Closing Documents. 211
Sec. 9. Authorized delegation of authority. 212
To the extent permitted by District and federal laws, the Mayor may delegate to any 213
Authorized Delegate the performance of any function authorized to be performed by the Mayor 214
under this resolution. 215
Sec. 10. Limited liability. 216
(a) The Bonds shall be special obligations of the District. The Bonds shall be without 217
recourse to the District. The Bonds shall not be general obligations of the District, shall not be a 218
pledge of or involve the faith and credit or the taxing power of the District, shall not constitute a 219
debt of the District, and shall not constitute lending of the public credit for private undertakings as 220
prohibited in section 602(a)(2) of the Home Rule Act. 221
(b) The Bonds shall not give rise to any pecuniary liability of the District and the District 222
shall have no obligation with respect to the purchase of the Bonds. 223
(c) Nothing contained in the Bonds, in the Financing Documents, or in the Closing 224
Documents shall create an obligation on the part of the District to make payments with respect to 225
the Bonds from sources other than those listed for that purpose in section 7. 226
(d) The District shall have no liability for the payment of any Issuance Costs or for any 227
transaction or event to be effected by the Financing Documents. 228
(e) All covenants, obligations, and agreements of the District contained in this resolution, 229
the Bonds, and the executed, sealed, and delivered Financing Documents and Closing Documents to 230 11
which the District is a party, shall be considered to be the covenants, obligations, and agreements of 231
the District to the fullest extent authorized by law, and each of those covenants, obligations, and 232
agreements shall be binding upon the District, subject to the limitations set forth in this resolution. 233
(f) No person, including, but not limited to, the Borrower and any Bond owner, shall have 234
any claims against the District or any of its elected or appointed officials, officers, employees, or 235
agents for monetary damages suffered as a result of the failure of the District or any of its elected or 236
appointed officials, officers, employees or agents to perform any covenant, undertaking, or 237
obligation under this resolution, the Bonds, the Financing Documents, or the Closing Documents, 238
nor as a result of the incorrectness of any representation in or omission from the Financing 239
Documents or the Closing Documents, unless the District or its elected or appointed officials, 240
officers, employees, or agents have acted in a willful and fraudulent manner. 241
Sec. 11. District officials. 242
(a) Except as otherwise provided in section 10(f), the elected or appointed officials, officers, 243
employees, or agents of the District shall not be liable personally for the payment of the Bonds or be 244
subject to any personal liability by reason of the issuance, sale or delivery of the Bonds, or for any 245
representations, warranties, covenants, obligations, or agreements of the District contained in this 246
resolution, the Bonds, the Financing Documents, or the Closing Documents. 247
(b) The signature, countersignature, facsimile signature, or facsimile countersignature of 248
any official appearing on the Bonds, the Financing Documents, or the Closing Documents shall 249
be valid and sufficient for all purposes notwithstanding the fact that the individual signatory 250
ceases to hold that office before delivery of the Bonds, the Financing Documents, or the Closing 251
Documents. 252
Sec. 12. Maintenance of documents. 253 12
Copies of the specimen Bonds and of the final Financing Documents and Closing 254
Documents shall be filed in the Office of the Secretary of the District of Columbia. 255
Sec. 13. Information reporting. 256
Within three (3) days after the Mayor’s receipt of the transcript of proceedings relating to 257
the issuance of the Bonds, the Mayor shall transmit a copy of the transcript to the Secretary to the 258
Council. 259
Sec. 14. Disclaimer. 260
(a) The issuance of Bonds is in the discretion of the District. Nothing contained in this 261
resolution, the Bonds, the Financing Documents, or the Closing Documents shall be construed as 262
obligating the District to issue any Bonds for the benefit of the Borrower or to participate in or assist 263
the Borrower in any way with financing, refinancing, or reimbursing the costs of the Project. The 264
Borrower shall have no claims for damages or for any other legal or equitable relief against the 265
District, its elected or appointed officials, officers, employees, or agents as a consequence of any 266
failure to issue any Bonds for the benefit of the Borrower. 267
(b) The District reserves the right to issue the Bonds in the order or priority it determines in 268
its sole and absolute discretion. The District gives no assurance and makes no representations that 269
any portion of any limited amount of bonds or other obligations, the interest on which is excludable 270
from gross income for federal income tax purposes, will be reserved or will be available at the time 271
of the proposed issuance of the Bonds. 272
(c) The District, by adopting this resolution or by taking any other action in connection with 273
financing, refinancing, or reimbursing costs of the Project, does not provide any assurance that the 274
Project is viable or sound, that the Borrower is financially sound, or that amounts owing on the 275 13
Bonds or pursuant to the Loan will be paid. Neither the Borrower, any purchaser of the Bonds, nor 276
any other person shall rely upon the District with respect to these matters. 277
Sec. 15. Expiration. 278
If any Bonds are not issued, sold, and delivered to the original purchaser within three (3) 279
years of the date of this resolution, the authorization provided in this resolution with respect to the 280
issuance, sale, and delivery of the Bonds shall expire. 281
Sec. 16. Severability. 282
If any particular provision of this resolution, or the application thereof to any person or 283
circumstance is held invalid, the remainder of this resolution and the application of such provision 284
to other persons or circumstances shall not be affected thereby. If any action or inaction 285
contemplated under this resolution is determined to be contrary to the requirements of applicable 286
law, such action or inaction shall not be necessary for the purpose of issuing the Bonds, and the 287
validity of the Bonds shall not be adversely affected. 288
Sec. 17. Compliance with public approval requirement. 289
This approval shall constitute the approval of the Council as required in section 147(f) of the 290
Internal Revenue Code of 1986, as amended, and section 490(k) of the Home Rule Act, for the 291
Project to be financed, refinanced, or reimbursed with the proceeds of the Bonds. This resolution 292
approving the issuance of the Bonds for the Project has been adopted by the Council after a public 293
hearing held at least seven (7) days after publication of notice in a newspaper of general circulation 294
in the District. 295
Sec. 18. Transmittal. 296
The Council shall transmit a copy of this resolution, upon its adoption, to the Mayor. 297
Sec. 19. Fiscal impact statement. 298 14
The Council adopts the fiscal impact statement of the Chief Financial Officer as 299
the fiscal impact statement required by section 4a of the General Legislative Procedures Act of 300
1975, approved October 16, 2006 (120 Stat. 2038; D.C. Official Code § 1- 301.47a).
301
Sec. 20. Effective date. 302
This resolution shall take effect immediately. 303 DC Hebrew Language Charter School
(Sela) Revenue Bond Project
FACT SHEET
DC Hebrew Language Charter School Inc (Sela) has requested that the District of Colum bia
issue up to $15,000,000 of 501(c)(3) revenue bonds, refinancing, and renovations to support
construction projects at 6 015-17 Chillum Place NE Washington, DC in Ward 4.
The Applicant
Opened in 2013 in DC’s Ward 4, Sela Public Charter School has a diverse student body and
faculty that reflects the multicultural and vibrant dynamics of the nation’s capital.
"Global citizenship" education is a key school focus. It includes the development of student
skills in communication (including learning a foreign language), collaboration, critical thinking,
and creativity. It also includes an emphasis on building empathy and emotional intelligence,
perspective taking, and learning about other cultures.
Sela has been recognized as a high-performing school by the DC Public Charter School Board.
The school offers an academically rigorous curriculum, including daily Modern Hebrew studies,
that lead to a high level of language proficiency.
Proposed Project
DC Hebrew Language Public Charter School (Sela) project consists of refinancing the bridge
loan used to purchase the existing school property and approximately $ 4 million in renovations.
DC Hebrew Language Public Charter School (Sela)
Fact Sheet
February 2023
2
Financing Plan
A summary of the pro posed sources and uses of funds is attached (see Table 1).
Total Cost Tax-exempt
Bond Proceeds
Taxable Loan Equity
Refinancing/Refunding $7,825,000
Building Renovation $6,000,000
Up-frontfees/Other
Issuance costs
$220,000 $280,000
Contingency $955,000
TOTAL $15,000,000 $280,000
Feasibility/Structure/Security of the Bonds
A commitment letter to provide a direct pay letter of credit was included in the application from
ConnectOne, who will also serve as underwriter. The bonds will be repaid at a synthetically
fixed interest rate (to be determined based on market conditions) over 25 years (with payments
beginning one year after closing). A Bond Trustee has not been selected.
Bonds will be a general obligation of DC He brew Language Public Charter School (Sela) and
will be repaid primarily by revenues from tuition .
Legal and Regulatory Affairs
The law firm of Orrick , Herrington, & Sutcliffe bond counsel to the Revenue Bond Progra m, has
preliminarily determined that DC He brew Language Public Charter School is a 501(c)(3)
organization and that the project constitutes a permissible undertaking within the meaning of
Section 490(a)(1) of the District of Columbia Home Rule Act.
The Office of Planning, Office of Tax and Revenue and Department of Employment Services,
Department of Consumer and Regulatory Aff airs have all approved the application.
Based upon the information set forth in the application, the Reve nue Bond Program staff has
determined that the proposed project complies with criteria for approval of a proposed financing
transaction through the District’s Revenue Bond Program and will assist the Borrower in
furthering its organizational mission.
GOVERNMENT OF THE DISTRICT OF COLUMBIA
OFFICE OF THE ATTORNEY GENERAL
Commercial Division
Tax & Finance Section
MEMORANDUM
TO: William Liggins
Director, Revenue Bond Program
Office of the Deputy Mayor for Planning and Economic Development FROM: Patrick Allen
Senior Assistant Attorney General
Commercial Division
DATE: Fe bruary 23, 2023
SUBJECT: Legal Sufficiency Certification of the “D.C. Hebrew Language Charter
School d/b/a Sela Public Charter School Revenue Bonds Project Approval Resolution of 2023”.
This is to certify that
the Office of the Attorney General has reviewed the above-
referenced resolution and found it to be legally sufficient . If you have any questions in
this regard, please do not hesitate to call me at (202 ) 724-7754.
_________________________________ Patrick Allen
Senior Assistant A ttorney General