10
u
n
3
4
Is
16
”
18
19
20
au
23
4
a
‘SUPERIOR COURT OF WASHINGTON FOR KITSAP COUNTY
BAINBRIDGE RATEPAYERS ALLIANCE, a|
‘non-piofit corporation,
CITY OF BAINBRIDGE ISLAND, a
‘munie-pal corporation,
‘No. 09-2-01023-6
Plaintst
CITY'S MOTION FOR SUMMARY
JUDGMENT ON THIS SUIT'S CLAM
REGARDING THE VALIDITY OF THE
CITY'S PROPOSED BOND ISSUE
Ccrv's Momow For Susouany Jurca ON Ths Sur's Crane Fosren Feren PLLC
-REGARLING THE VALIDITY OF Tie CHTY's PROPOSED BONDISSUE i sumtin aves Sune
a10
n
B
1“
15
6
"7
18
»
20
a
2B
24
2s
26
<
Crv's Mono For Suvaany JUDGMENT ON Tis SU's CLAM
[REGARDING THE VALIDITY OF THE CITY'S PROPOSED BOND ISSUE - i
‘TABLE OF CONTENTS
INTRODUCTION.
RELIEF REQUESTED.
BACKGROUND CHRONOLOGY OF EVENTS,
‘A. Milestones Before Plaintiff Filed Suit
B. Plaintiff's Assertion Of This Suit’s Two Bond Claims Prevents The
City’s Bond Financing From Closing
(QUESTIONS OF LAW PRESENTED BY THIS MOTION.
LEGAL DISCUSSION.
‘A. The City’s Proposed Bond Issue Is Valid Under Washington Law’s
‘Threo-Part Test For Bond Validity fl
1. The City’s proposed bond issue is for a public purpose...
2. Th Sat sane ersng he iy pnpeed ban nme were
constitutionally enacted
bar ae anda sony to the = Gy for this
proposed bond issue. "
(a) The State Lepsatue’s delegation othe City.
(0) The proposed bond issue complied withthe State Legare