5.
Capital
Listed below are all of the issued and outstanding shares in the capital of the Corporation and the
registered owner(s) of such shares:
ISSUED SHARES
Attached hereto as Schedule “E” are true copies of all certificates in respect of such issued and
securities convertible or exchangeable into shares and/or securities in respect of debt, other than
such issued and outstanding shares as are listed above.
DATED this _____ day of ____________________, 2010.
FORM OF PROJECT CO/PROJECT CO PARTY OPINION
[INSERT DATE]
Her Majesty The Queen in Right of Ontario
c/o Ontario Infrastructure Projects Corporation
777 Bay Street, 9 th Floor
Toronto, Ontario
M5G 2E5
Ontario Infrastructure Projects Corporation
777 Bay Street, 9 th Floor
Toronto, Ontario
M5G 2E5
Stikeman Elliott LLP
5300 Commerce Court West
199 Bay Street
Toronto, Ontario
M5L 1B9
Dear Sirs/Mesdames:
Re:
[]
Windsor Essex Parkway
“Construction Contractor”) in connection with the alternative financing and procurement
transaction whereby Project Co has agreed to enter into a design, build, finance and maintain
agreement for a new parkway in the City of Windsor, the Town of LaSalle, the Town of
Tecumseh and the County of Essex, Ontario.
[NTD: Additional parties to be added
depending on consortium structure and/or the financing package. Add each partner of
Project Co and each member of the Construction Contractor.]
This opinion is being delivered to Her Majesty The Queen in Right of Ontario (“HMQ”),
Ontario Infrastructure Projects Corporation (“IO”) and their counsel pursuant to Section 1.21 of
Schedule 2 to the project agreement made as of December 15, 2010 between IO as agent for
HMQ, as represented by the Minister of Infrastructure, and Project Co (as the same may be
amended, supplemented, restated or otherwise modified from time to time, the “Project
Agreement”).
All capitalized terms used but not otherwise defined in this opinion shall have the respective
meanings ascribed thereto in the Project Agreement.
In our capacity as counsel to [Project Co, the Construction Contractor], we have participated
in the preparation and negotiation, and have examined an executed copy, of each of the
following documents (unless otherwise indicated, all documents are dated as of December 15,
2010):
2.
the following project documents (collectively, the “Implementation Documents”):
(a)
the Construction Contract;
(b)
the Lenders' Direct Agreement;
(c)
the Construction Contractor's Direct Agreement;
(d)
the Lending Agreements;
(e)
the General Partnership Agreement; and
(f)
the Performance Guarantees.
The Project Agreement and the Implementation Documents are hereinafter collectively referred
to as the “Documents”, and each is individually referred to as a “Document”. [NTD:
Additional documents to be added depending on consortium structure and/or the financing
package.]
We are qualified to practise law in the Province of Ontario. We have made no investigation of
the laws of any jurisdiction other than Ontario, and the opinions expressed below are confined to
the laws of Ontario and the federal laws of Canada applicable therein as at the date hereof.
We do not act as corporate counsel to [Project
Co, the Construction Contractor], nor have we
participated in the general maintenance of their corporate records and corporate proceedings.
Therefore, in expressing certain of the opinions below, we have, where indicated, relied
exclusively, and without any independent investigation or enquiry, on certificates of public
officials and a certificate of an officer of each partner of Project Co and each member of the
Construction Contractor dated as of the date hereof (the “Officer's Certificates”) as to certain
factual matters.
Searches and Reliance
We have conducted, or have caused to be conducted, the searches identified in Schedule “A” (the
“Searches”) for filings or registrations made in those offices of public record listed in Schedule
“A”. The Searches were conducted against the current name and all former names of [Project
Co, the Construction Contractor] (including, in each case, both the English and French
versions, if any). The results of the Searches are set out in Schedule “A”.
We have also made such investigations and examined originals or copies, certified or otherwise
identified to our satisfaction, of such certificates of public officials and of such other certificates,
documents and records as we have considered necessary or relevant for purposes of the opinions
expressed below, including, without limitation, the Officer's Certificates.
We have relied exclusively, and without any independent investigation or enquiry, on the
Officer's Certificates and the certificates of public officials with respect to certain factual matters.
In connection with the opinions set forth in paragraphs 1 and 2 below, we have relied exclusively
on Certificates of Status issued by the [Ministry of Government Services (Ontario)] of even
date, copies of which are attached as Schedule “B”.
In connection with the opinions set forth in paragraphs 4, 6, 8, 12, and 14 below, we have relied
exclusively, and without any independent investigation or enquiry, upon the opinion of [] dated
[], 2010 (the “CC Opinion”), a copy of which has been delivered to you. To the extent that
the CC Opinion contains assumptions, qualifications, limitations or definitions, or is expressed as
relying on any certificate(s) or other documents identified therein, the opinions herein expressed
in reliance on the CC Opinion should be read as incorporating the identical assumptions,
qualifications, limitations, definitions and reliances.
Assumptions
For the purposes of the opinions expressed herein, we have assumed:
1.
The genuineness of all signatures, the authenticity of all documents submitted to us as
originals, the conformity to originals of all documents submitted to us as certified, true,
conformed, photostatic or notarial copies or facsimiles thereof and the authenticity of the
originals of such certified, true, conformed, photostatic or notarial copies or facsimiles.
2.
Each of the parties (other than [Project Co, the Construction Contractor]) to each of
the Documents is and was, at all relevant times, a subsisting corporation, partnership,
limited partnership, limited liability company or trust, as applicable, under the laws of its
jurisdiction of formation.
3.
Each of the parties (other than [Project Co, the Construction Contractor]) has (and
had) the corporate power, authority and capacity to own its property and assets and to
carry on its business as such business is now (or as was then) being carried on by it, has
(or had) all requisite corporate power, authority and capacity to execute and deliver each
Document to which it is party and to perform its obligations thereunder, has taken all
necessary corporate action, as applicable, to authorize the execution and delivery of each
Document to which it is a party and the performance of its obligations thereunder, and
has duly executed and delivered each Document to which it is a party and each Document
to which it is a party is a legal, valid and binding obligation of such party enforceable
against it in accordance with its terms.
4.
The completeness, truth and accuracy of all facts set forth in the Officer's Certificates.
5.
The completeness, truth and accuracy of all facts set forth in official public records and
certificates and other documents supplied by public officials.
6.
Value has been given by each of the parties (other than [Project Co, the Construction
Contractor]) to Project Co and the Construction Contractor.
Opinions
Based upon and subject to the foregoing, and to the qualifications, exceptions and limitations
hereinafter expressed, we are of the opinion that, as of the date hereof:
Incorporation and Existence
1.
Project Co is a corporation incorporated under the laws of [the Province of Ontario] and
has not been dissolved.
2.
The Construction Contractor is a corporation incorporated under the laws of
[the
Province of Ontario] and has not been dissolved.
Corporate Power and Capacity
3.
Project Co has the corporate power and capacity to own or lease its properties and assets,
to carry on its business as it is currently being conducted and as it is contemplated to be
conducted under the Project Agreement, and to enter into and perform its obligations
under each of the Documents to which it is a party.
4.
The Construction Contractor has the corporate power and capacity to own or lease its
properties and assets, to carry on its business as it is currently being conducted and as it is
contemplated to be conducted under the Documents, and to enter into and perform its
obligations under each of the Documents to which it is a party.
Corporate Authorization
5.
Project Co has taken all necessary corporate action to authorize the execution and
delivery of, and the performance of its obligations under, each of the Documents to which
it is a party.
6.
The Construction Contractor has taken all necessary corporate action to authorize the
execution and delivery of, and the performance of its obligations under, each of the
Documents to which it is a party.
Execution and Delivery
7.
Project Co has duly executed and delivered each of the Documents to which it is a party.
8.
The Construction Contractor has duly executed and delivered each of the Documents to
which it is a party.
Enforceability
9.
Each of the Documents to which Project Co is a party constitutes a legal, valid and
binding obligation of Project Co, enforceable against it in accordance with its terms.
10.
Each of the Documents to which the Construction Contractor is a party constitutes a
legal, valid and binding obligation of the Construction Contractor, enforceable against it
in accordance with its terms.
No Breach or Default
11.
The execution and delivery by Project Co of the Documents to which it is a party does
not, and the performance by Project Co of its obligations under each such Document in
accordance with its terms will not, breach or constitute a default under (i) any provisions
of the General Partnership Agreement, or (ii) the provisions of any law, statute, rule or
regulation to which Project Co is subject.
12.
The execution and delivery by the Construction Contractor of the Documents to which it
is a party does not, and the performance by the Construction Contractor of its obligations
under each such Document in accordance with its terms will not, breach or constitute a
default under (i) its articles, by-laws or unanimous shareholders' agreement, or (ii) the
provisions of any law, statute, rule or regulation to which the Construction Contractor is
subject.
Regulatory Approvals
13.
No authorization, consent, permit or approval of, or other action by, or filing with or
notice to, any governmental agency or authority, regulatory body, court, tribunal or other
similar entity having jurisdiction is required in connection with the execution and
delivery by Project Co of the Documents to which it is a party and the performance of its
obligations thereunder.
14.
No authorization, consent, permit or approval of, or other action by, or filing with or
notice to, any governmental agency or authority, regulatory body, court, tribunal or other
similar entity having jurisdiction is required in connection with the execution and
delivery by the Construction Contractor of the Documents to which it is a party and the
performance of its obligations thereunder.
Qualifications
Our opinions herein are subject to the following qualifications and reservations, namely:
1.
The enforceability of any Document and the rights and remedies set out therein or any
judgment arising out of or in connection therewith is subject to and may be limited by
any applicable bankruptcy, reorganization, winding-up, insolvency, moratorium or other
laws of general application affecting creditors' rights from time to time in effect.
2.
The enforceability of each of the Documents and the rights and remedies set out therein is
subject to and may be limited by general principles of equity, and no opinion is given as
to any specific remedy that may be granted, imposed or rendered, including equitable
remedies such as those of specific performance and injunction, or the availability of
equitable defences.
3.
The enforceability of any Document will be subject to the limitations contained in the
Limitations Act, 2002 (Ontario), and we express no opinion as to whether a court may
find any provision of any Document to be unenforceable as an attempt to vary or exclude
a limitation period under that Act.
4.
Pursuant to the Currency Act (Canada), a judgment in money rendered by a court in the
Province of Ontario must be awarded in Canadian currency and such judgment may be
based on a rate of exchange in effect other than the day of payment of the judgment.
5.
To the extent that a particular contractual provision is characterized by a court as a
penalty and not as a genuine pre-estimate of damages, it will not be enforceable.
6.
A court may not treat as conclusive those certificates and determinations which the
Documents state are to be so treated.
7.
A receiver or receiver and manager appointed pursuant to the provisions of any
Document, for certain purposes, may not be treated by a court as being solely the agent of
Project Co notwithstanding any agreement to the contrary.
8.
The ability to recover or claim for certain costs or expenses may be subject to judicial
discretion.
9.
With respect to any provisions of the Documents pursuant to which the parties to such
Documents are permitted or required to submit a dispute arising out of such Documents
to arbitration, we express no opinion as to the enforceability of such arbitration
provisions in all circumstances since under the Arbitration Act, 1991 (Ontario) a court of
competent jurisdiction in Ontario may, in its discretion and upon certain grounds, refuse
to stay judicial proceedings in which event an arbitration under such arbitration
provisions may not be commenced or continued. In addition, the Arbitration Act, 1991
(Ontario) provides that a court may hear an appeal of an arbitration award on a question
of law, or set aside an arbitration award or declare it invalid, in each case on certain
prescribed grounds.
10.
Any requirement in any of the Documents that interest be paid at a higher rate after than
before default may not be enforceable.
11.
The effectiveness of provisions which purport to relieve a person from a liability or duty
otherwise owed may be limited by law, and provisions requiring indemnification or
reimbursement may not be enforced by a court, to the extent that they relate to the failure
of such person to perform such duty or liability.
12.
No opinion is expressed as to the enforceability of any provision contained in any
Document which purports to sever from the Document any provision therein which is
prohibited or unenforceable under applicable law without affecting the enforceability or
validity of the remainder of the Document.
13.
No opinion is expressed regarding any waiver of service of process, presentment,
demand, protest or notice of dishonour which may be contained in any of the Documents.
14.
Any award of costs is in the discretion of a court of competent jurisdiction.
15.
The enforceability of rights of indemnity set out in the Documents may be limited under
applicable law to the extent that they directly or indirectly relate to liabilities imposed by
law on HMQ for which it would be contrary to public policy to require Project Co to
indemnify HMQ or to the extent that they constitute the indirect enforcement of a foreign
revenue or penal law.
This opinion is being delivered solely in connection with the transaction addressed herein and
may not be relied upon by any person other than the addressees, and their successors and
permitted assigns, or for any purpose other than the transaction addressed herein.
Yours very truly,
[INSERT NAME OF LAW FIRM]
CERTIFICATE OF AN OFFICER OF
ONTARIO INFRASTRUCTURE PROJECTS CORPORATION
(the “Corporation”)
TO:
AND TO:
AND TO:
AND TO:
AND TO:
RE:
I, [], the [] of the Corporation and an authorized signatory of the Corporation and being duly
STIKEMAN ELLIOTT LLP
WINDSOR ESSEX MOBILITY GROUP GP (“Project Co”)
TORYS LLP
CITI TRUST COMPANY CANADA (the “Collateral Trustee”)
FASKEN MARTINEAU DuMOULIN LLP
Project agreement (as amended, supplemented or modified from time to time, the
“Project Agreement”) dated the 15 th day of December, 2010 between the
Corporation, as agent for Her Majesty The Queen in Right of Ontario, as
represented by the Minister of Infrastructure, and Project Co
and confirmations for and on behalf of the Corporation and without incurring personal liability
and that the same may be relied upon by you without further inquiry:
1.
Attached hereto as Schedule “A” is a true and complete copy of (i) the resolutions of the
directors of the Corporation regarding the execution of public works projects assigned to
the Corporation and certain other matters set forth therein; and (ii) an excerpt of the
resolutions of the directors of the Corporation relating to delegation of signing authority
(collectively, the “Execution Resolutions”), which have been duly and validly passed in
accordance with applicable law. The Execution Resolutions are the only resolutions of
the Corporation pertaining to the subject matter thereof and the same is in full force and
effect, unamended as of the date hereof.
2.
Attached hereto as Schedule “B” is a true and complete copy of the resolutions of the
directors the Corporation approving the selection of Project Co as the successful bidder
for the Windsor Essex Parkway Project (the “Project Resolutions”). The Project
Resolutions are the only resolutions of the Corporation pertaining to the subject matter
thereof and the same is in full force and effect, unamended as of the date hereof.
3.
The following named persons, on or as of the date hereof, are duly elected or appointed
officers of the Corporation, as evidenced by the holding of the office or offices set forth
opposite their names, are proper signing officers of the Corporation and are authorized to
execute and deliver Project Documents (as such a term is defined in the Execution
Resolutions referenced in Item 1(i) above) relating to the Windsor Essex Parkway Project
on behalf of the Corporation. The signatures set forth opposite their respective names are
the true signatures of those persons.
Name: []
Title: Secretary
FORM OF DECLARATION OF MANAGEMENT
ONTARIO INFRASTRUCTURE PROJECTS CORPORATION
DECLARATION OF MANAGEMENT
WHEREAS the Corporation as agent for Her Majesty The Queen in Right of Ontario, as
represented by the Minister of Infrastructure, and Windsor Essex Mobility Group GP propose to
enter into a Project Agreement relating to the Windsor Essex Parkway Project in the City of
Windsor, the Town of LaSalle, the Town of Tecumseh and the County of Essex, Ontario (the
“WEP Project”);
AND WHEREAS the Corporation will from time to time enter into agreements for the
design, construction and/or facilities management of the WEP Project assigned to the
Corporation by the Minister of Infrastructure and as well as ancillary agreements, instruments,
certificates and other documents required to give effect to, or contemplated to be delivered in
accordance with the WEP Project (collectively, “Project Documents”);
NOW THEREFORE THE CORPORATION’S MANAGEMENT HEREBY
DECLARES THAT:
1.
by resolution of the board of directors of the Corporation passed on [], 20, the board
of directors of the Corporation has authorized the Corporation’s management (for and in
the name of and on behalf of the Corporation) to execute and deliver the Project
Documents and do all such other acts and things as the Corporation’s management may
determine to be necessary or advisable to carry out the transactions contemplated by the
applicable Project Documents;
2.
the Corporation’s management may execute and deliver the Project Documents to which
the Corporation may become a party and any other documents, instruments or agreements
delivered in connection with the Project Documents from time to time (collectively,
together with the Project Documents, the “Documents”) all in such form and on such
terms as the management of the Corporation executing such Documents in accordance
with this declaration may approve, such approval to be evidenced conclusively by the
execution of such Documents by the Corporation’s management; and
3.
the Project Documents to be executed and delivered by the Corporation in connection
with the WEP Project and the transactions and obligations contemplated thereunder are
for the purpose of carrying out the objects of the Corporation and the Corporation shall
not and will not assert the contrary against any person dealing with the Corporation or
any person who has acquired an interest in the WEP Project from the Corporation.
THIS DECLARATION may be signed in counterparts, and all such counterparts, when
taken together, shall constitute one and the same declaration, effective on this date.
DATED this ______ day of _______________, 2010.
Name: []
Title: Secretary