St. Patrick’s Episcopal Day School Revenue Bonds Project Approval Resolution of 2026

MURIELBOWSERMAYOR
April24,2026
‘TheHonorablePhilMendelson
‘Chairman
‘Councilof theDistrictofColumbia
John A. Wilson Building
1350PennsylvaniaAvenue,NW, Suite504
Washington,DC 20004
Dear Chairman Mendelson:
EnclosedforconsiderationandadoptionbytheCounciloftheDistrictofColumbiaisaproposed
resolutiontitled“St.Patrick’sEpiscopalDaySchoolRevenueBondsProjectApproval
Resolutionof2026”.
‘Theresolutionauthorizesthe issuance,sale,and deliveryof tax-exempt revenue bonds, notes,or
otherobligationsinanaggregateprincipalamountnottoexceed$30,500,000.Thebondswillbeused to financeand refinanceactivitiesrelatedto St.Patrick’sEpiscopalDay School's
educationalfacilitieslocatedat4700/4701 Whitehaven Parkway, NW, and 1801 FoxhallRoad,
NW.
Inaccordancewithsection490oftheHomeRuleAct,ithasbeendeterminedthatthebonds,
when,as,andifissued,shallbewithoutrecoursetotheDistrict.ThebondsshallnotbegeneralobligationsoftheDistrict;shallnotbeapledgeoforinvolvethefullfaithandcreditorthetaxingpoweroftheDistrict;shallnotconstituteadebtoftheDistrict;andshallnotconstitutea
lendingofpubliccreditforaprivateundertakingasprohibitedinsection602(a)(2)oftheHomeRuleAct.ThebondsshallnotgiverisetoanypecuniaryliabilityoftheDistrict,andtheDistrict
shallhavenoobligationwithrespecttothepurchaseofthebonds.
TurgetheCounciltotakepromptandfavorableactionontheenclosedmeasure.
Sincerely,
irielBowser
Enclosure
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7 A PROPOSED RESOLUTION
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a£:?.~
at the request of the Mayor
11 IN THE COUNCIL OF THE DISTRICT OF COLUMBIA
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15 To authorize and provide for the issuance, sale, and delivery in an aggregate principal amount not to
16 exceed $30.5 million of District of Columbia revenue bonds in one or more series
17 pursuant to a plan of finance and to authorize and provide for the loan of the proceeds of
18 such bonds to assist St. Patrick's Episcopal Day School in the financing, refinancing, or
19 reimbursing of costs associated with an authorized project pursuant to section 490 of the
20 District of Columbia Home Rule Act.
21
22 RESOLVED, BY THE COUNCIL OF THE DISTRICT OF COLUMBIA, That this
23 resolution may be cited as the "St. Patrick's Episcopal Day School Revenue Bonds Project Approval
24 Resolution of 2026".
25 Sec. 2. Definitions.
26 For the purposes of this resolution, the term:
27 (1) "Authorized Delegate" means the Mayor or the Deputy Mayor for Planning and
28 Economic Development, or any officer or employee of the Executive Office of the Mayor to whom
29 the Mayor has delegated or to whom the foregoing individuals have subdelegated any of the
30 Mayor's functions under this resolution pursuant to section 422(6) of the Home Rule Act.
31 (2) "Bond Counsel" means a firm or firms of attorneys designated as bond counsel
32 from time to time by the Mayor.

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(3) “Bonds” means the District of Columbia revenue bonds, notes, or other 33
obligations (including refunding bonds, notes, and other obligations), in one or more series, 34
authorized to be issued pursuant to this resolution. 35
(4) “Borrower” means the owner of the assets financed, refinanced, or reimbursed 36
with proceeds from the Bonds, which shall be Vestry of St. Patrick’s Parish a/k/a The Vestry of St. 37
Patrick’s Parish in the District of Columbia, a corporation organized and existing under the laws of 38
the District of Columbia, qualified to do business in the District of Columbia, and which is exempt 39
from federal income taxes under 26 U.S.C. § 501(a) as an organization described in 26 U.S.C. § 40
501(c)(3). 41
(5) “Closing Documents” means all documents and agreements other than Financing 42
Documents that may be necessary and appropriate to issue, sell, and deliver the Bonds and to make 43
the Loan, and includes agreements, certificates, letters, opinions, forms, receipts, and other similar 44
instruments. 45
(6) “District” means the District of Columbia. 46
(7) “Financing Documents” means the documents other than Closing Documents that 47
relate to the financing, refinancing or reimbursement of transactions to be effected through the 48
issuance, sale, and delivery of the Bonds and the making of the Loan, including any offering 49
document, and any required supplements to any such documents. 50
(8) “Home Rule Act” means the District of Columbia Home Rule Act, approved 51
December 24, 1973 (87 Stat. 774; D.C. Official Code § 1-201.01 et seq.). 52
(9) “Issuance Costs” means all fees, costs, charges, and expenses paid or incurred in 53
connection with the authorization, preparation, printing, issuance, sale, and delivery of the Bonds 54
and the making of the Loan, including, but not limited to, underwriting, legal, accounting, rating 55

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agency, and all other fees, costs, charges, and expenses incurred in connection with the development 56
and implementation of the Financing Documents, the Closing Documents, and those other 57
documents necessary or appropriate in connection with the authorization, preparation, printing, 58
issuance, sale, marketing, and delivery of the Bonds and the making of the Loan, together with 59
financing fees, costs, and expenses, including program fees and administrative fees charged by the 60
District, fees paid to financial institutions and insurance companies, initial letter of credit fees (if 61
any), compensation to financial advisors and other persons (other than full-time employees of the 62
District) and entities performing services on behalf of or as 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 the Borrower for 66
all or a portion of the Borrower’s costs incurred in connection with: 67
(A) The refunding of the District of Columbia Revenue Bonds (St. Patrick’s 68
Episcopal Day School Issue), Series 2016, issued in the original principal amount of $17,995,000, 69
the proceeds of which were used to finance and refinance improvements to the Borrower’s campuses 70
located at 4700 and 4701 Whitehaven Parkway NW, Washington, DC 20007 (the “Main Campus”) 71
and 1801 Foxhall Road NW, Washington, DC 20007 (the “Foxhall Campus,” and together with the 72
Main Campus, the “Borrower’s Campuses”); 73
(B) The financing and refinancing of the acquisition, construction, 74
improvement, expansion and development of an approximately 33,000 square foot middle school 75
facility to be located on the Main Campus (the “Middle School Facility”), together with parking and 76
other facilities functionally related and subordinate to the Middle School Facility (collectively, the 77
“Middle School Project”); 78

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(C) The purchase of certain furniture, fixtures and equipment for the 79
Middle School Project; 80
(D) The purchase of certain other property, real and personal, functionally 81
related and subordinate to the Borrower’s Campuses; 82
(E) Funding of capitalized interest; 83
(F) Funding of certain reserves; 84
(G) Funding of certain Issuance Costs; 85
(H) Funding of interest rate swap termination costs; 86
(I) Funding of lease termination costs; and 87
(J) Funding of working capital. 88
Sec. 3. Findings. 89
The Council finds that: 90
(1) Section 490 of the Home Rule Act provides that the Council may by resolution 91
authorize the issuance of District revenue bonds, notes, or other obligations (including refunding 92
bonds, notes, or other obligations) to borrow money to finance, refinance, or reimburse costs, and to 93
assist in the financing, refinancing, or reimbursing of the costs of undertakings in certain areas 94
designated in section 490 and may effect the financing, refinancing, or reimbursement by loans 95
made directly or indirectly to any individual or legal entity, by the purchase of any mortgage, note, 96
or other security, or by the purchase, lease, or sale of any property. 97
(2) The Borrower has requested the District to issue, sell, and deliver revenue bonds, 98
in one or more series, in an aggregate principal amount not to exceed $30.5 million and to make the 99
Loan for the purpose of financing, refinancing, or reimbursing costs of the Project. 100

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(3) The Project is located in the District and will contribute to the health, education, 101
safety, or welfare of, or the creation or preservation of jobs for, residents of the District, or to 102
economic development of the District. 103
(4) The Project is an undertaking in the area of elementary, secondary and college 104
and university facilities, within the meaning of section 490 of the Home Rule Act. 105
(5) The authorization, issuance, sale, and delivery of the Bonds and the Loan to 106
the Borrower are desirable, are in the public interest, will promote the purpose and intent of 107
section 490 of the Home Rule Act, and will assist the Project. 108
Sec. 4. Bond authorization. 109
(a) The Mayor is authorized pursuant to the Home Rule Act and this resolution to assist in 110
financing, refinancing, or reimbursing the costs of the Project by: 111
(1) The issuance, sale, and delivery of the Bonds, in one or more series, in an 112
aggregate principal amount not to exceed $30.5 million; and 113
(2) The making of the Loan. 114
(b) The Mayor is authorized to make the Loan to the Borrower for the purpose of financing, 115
refinancing, or reimbursing the costs of the Project and establishing any fund with respect to the 116
Bonds as required by the Financing Documents. 117
(c) The Mayor may charge a program fee to the Borrower, including, but not limited to, an 118
amount sufficient to cover costs and expenses incurred by the District in connection with the 119
issuance, sale, and delivery of each series of the Bonds, the District’s participation in the monitoring 120
of the use of the Bond proceeds and compliance with any public benefit agreements with the 121
District, and maintaining official records of each bond transaction and assisting in the redemption, 122
repurchase, and remarketing of the Bonds. 123

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(d) The Bond authorization set forth in this resolution includes the authorization to issue 124
refunding Bonds to refinance any Bonds previously issued under this resolution to finance the 125
Project; provided, that the maximum principal amount of Bonds outstanding at any time does not 126
exceed the maximum principal amount of Bonds authorized hereunder. 127
Sec. 5. Bond details. 128
(a) The Mayor and each Authorized Delegate is authorized to take any action reasonably 129
necessary or appropriate in accordance with this resolution in connection with the preparation, 130
execution, issuance, sale, delivery, security for, and payment of the Bonds of each series, including, 131
but not limited to, determinations of: 132
(1) The final form, content, designation, and terms of the Bonds, including a 133
determination that the Bonds may be issued in certificated or book-entry form; 134
(2) The principal amount of the Bonds to be issued and denominations of the Bonds; 135
(3) The rate or rates of interest or the method for determining the rate or rates of 136
interest on the Bonds; 137
(4) The date or dates of issuance, sale, and delivery of, and the payment of interest on 138
the Bonds, and the maturity date or dates of the Bonds; 139
(5) The terms under which the Bonds may be paid, optionally or mandatorily 140
redeemed, accelerated, tendered, called, or put for redemption, repurchase, or remarketing before 141
their respective stated maturities; 142
(6) Provisions for the registration, transfer, and exchange of the Bonds and the 143
replacement of mutilated, lost, stolen, or destroyed Bonds; 144
(7) The creation of any reserve fund, sinking fund, or other fund with respect to the 145
Bonds; 146

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(8) The time and place of payment of the Bonds; 147
(9) Procedures for monitoring the use of the proceeds received from the sale of the 148
Bonds to ensure that the proceeds are properly applied to the Project and used to accomplish the 149
purposes of the Home Rule Act and this resolution; 150
(10) Actions necessary to qualify the Bonds under blue sky laws of any jurisdiction 151
where the Bonds are marketed; and 152
(11) The terms and types of credit enhancement, if any, under which the Bonds may 153
be secured. 154
(b) The Bonds shall contain a legend, which shall provide that the Bonds are special 155
obligations of the District, are without recourse to the District, are not a pledge of, and do not 156
involve the faith and credit or the taxing power of the District, do not constitute a debt of the District, 157
and do not constitute lending of the public credit for private undertakings as prohibited in section 158
602(a)(2) of the Home Rule Act. 159
(c) The Bonds shall be executed in the name of the District and on its behalf by the manual 160
or facsimile signature of the Mayor, and attested by the Secretary of the District of Columbia by the 161
Secretary of the District of Columbia’s manual or facsimile signature. The Mayor’s execution and 162
delivery of the Bonds shall constitute conclusive evidence of the Mayor’s approval, on behalf of the 163
District, of the final form and content of the Bonds. 164
(d) The official seal of the District, or a facsimile of it, shall be impressed, printed, or 165
otherwise reproduced on the Bonds. 166
(e) The Bonds of any series may be issued in accordance with the terms of a trust instrument 167
to be entered into by the District and a trustee to be selected by the Borrower subject to the approval 168

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of the Mayor, and may be subject to the terms of one or more agreements entered into by the Mayor 169
pursuant to section 490(a)(4) of the Home Rule Act. 170
(f) The Bonds may be issued at any time or from time to time in one or more issues and in 171
one or more series. 172
Sec. 6. Sale of the Bonds. 173
(a) The Bonds of any series may be sold at negotiated or competitive sale at, above, or below 174
par, to one or more persons or entities, and upon terms that the Mayor considers to be in the best 175
interest of the District. 176
(b) The Mayor or an Authorized Delegate may execute, in connection with each sale of the 177
Bonds, offering documents on behalf of the District, may deem final any such offering document on 178
behalf of the District for purposes of compliance with federal laws and regulations governing such 179
matters and may authorize the distribution of the documents in connection with the sale of the 180
Bonds. 181
(c) The Mayor is authorized to deliver the executed and sealed Bonds, on behalf of the 182
District, for authentication, and, after the Bonds have been authenticated, to deliver the Bonds to the 183
original purchasers of the Bonds upon payment of the purchase price. 184
(d) The Bonds of any series shall not be issued until the Mayor receives an approving 185
opinion from Bond Counsel as to the validity of the Bonds of such series and, if the interest on the 186
Bonds of such series is expected to be exempt from federal income taxation, the treatment of the 187
interest on the Bonds of such series for purposes of federal income taxation. 188
Sec. 7. Payment and security. 189
(a) The principal of, premium, if any, and interest on, the Bonds shall be payable 190
solely from proceeds received from the sale of the Bonds, income realized from the temporary 191

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investment of those proceeds, receipts and revenues realized by the District from the Loan, income 192
realized from the temporary investment of those receipts and revenues prior to payment to the Bond 193
owners, other moneys that, as provided in the Financing Documents, may be made available to the 194
District for the payment of the Bonds, and other sources of payment (other than from the District), 195
all as provided for in the Financing Documents. 196
(b) Payment of the Bonds shall be secured as provided in the Financing Documents and by 197
an assignment by the District for the benefit of the Bond owners of certain of its rights under the 198
Financing Documents and Closing Documents, including a security interest in certain collateral, if 199
any, to the trustee for the Bonds pursuant to the Financing Documents. 200
(c) The trustee is authorized to deposit, invest, and disburse the proceeds received from the 201
sale of the Bonds pursuant to the Financing Documents. 202
Sec. 8. Financing and Closing Documents. 203
(a) The Mayor is authorized to prescribe the final form and content of all Financing 204
Documents and all Closing Documents to which the District is a party that may be necessary or 205
appropriate to issue, sell, and deliver the Bonds and to make the Loan to the Borrower. Each of the 206
Financing Documents and each of the Closing Documents to which the District is not a party shall 207
be approved, as to form and content, by the Mayor. 208
(b) The Mayor is authorized to execute, in the name of the District and on its behalf, the 209
Financing Documents and any Closing Documents to which the District is a party by the Mayor’s 210
manual or facsimile signature. 211
(c) If required, the official seal of the District, or a facsimile of it, shall be impressed, printed, 212
or otherwise reproduced on the Financing Documents and the Closing Documents to which the 213
District is a party. 214

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(d) The Mayor’s execution and delivery of the Financing Documents and the Closing 215
Documents to which the District is a party shall constitute conclusive evidence of the Mayor’s 216
approval, on behalf of the District, of the final form and content of the executed Financing 217
Documents and the executed Closing Documents. 218
(e) The Mayor is authorized to deliver the executed and sealed Financing Documents and 219
Closing Documents, on behalf of the District, prior to or simultaneously with the issuance, sale, and 220
delivery of the Bonds, and to ensure the due performance of the obligations of the District contained 221
in the executed, sealed, and delivered Financing Documents and Closing Documents. 222
Sec. 9. Authorized delegation of authority. 223
To the extent permitted by District and federal laws, the Mayor may delegate to any 224
Authorized Delegate the performance of any function authorized to be performed by the Mayor 225
under this resolution. 226
Sec. 10. Limited liability. 227
(a) The Bonds shall be special obligations of the District. The Bonds shall be without 228
recourse to the District. The Bonds shall not be general obligations of the District, shall not be a 229
pledge of, or involve the faith and credit or the taxing power of, the District, shall not constitute a 230
debt of the District, and shall not constitute lending of the public credit for private undertakings as 231
prohibited in section 602(a)(2) of the Home Rule Act. 232
(b) The Bonds shall not give rise to any pecuniary liability of the District and the District 233
shall have no obligation with respect to the purchase of the Bonds. 234
(c) Nothing contained in the Bonds, in the Financing Documents, or in the Closing 235
Documents shall create an obligation on the part of the District to make payments with respect to the 236
Bonds from sources other than those listed for that purpose in section 7. 237

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(d) The District shall have no liability for the payment of any Issuance Costs or for any 238
transaction or event to be effected by the Financing Documents. 239
(e) All covenants, obligations, and agreements of the District contained in this resolution, the 240
Bonds, and the executed, sealed, and delivered Financing Documents and Closing Documents to 241
which the District is a party, shall be considered to be the covenants, obligations, and agreements of 242
the District to the fullest extent authorized by law, and each of those covenants, obligations, and 243
agreements shall be binding upon the District, subject to the limitations set forth in this resolution. 244
(f) No person, including, but not limited to, the Borrower and any Bond owner, shall have 245
any claims against the District or any of its elected or appointed officials, officers, employees, or 246
agents for monetary damages suffered as a result of the failure of the District or any of its elected or 247
appointed officials, officers, employees, or agents to perform any covenant, undertaking, or 248
obligation under this resolution, the Bonds, the Financing Documents, or the Closing Documents, as 249
a result of the incorrectness of any representation in or omission from the Financing Documents or 250
the Closing Documents, unless the District or its elected or appointed officials, officers, employees, 251
or agents have acted in a willful and fraudulent manner. 252
Sec. 11. District officials. 253
(a) Except as otherwise provided in section 10(f), the elected or appointed officials, officers, 254
employees, or agents of the District shall not be liable personally for the payment of the Bonds or be 255
subject to any personal liability by reason of the issuance, sale or delivery of the Bonds, or for any 256
representations, warranties, covenants, obligations, or agreements of the District contained in this 257
resolution, the Bonds, the Financing Documents, or the Closing Documents. 258
(b) The signature, countersignature, facsimile signature, or facsimile countersignature of 259
any official appearing on the Bonds, the Financing Documents, or the Closing Documents shall 260

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be valid and sufficient for all purposes notwithstanding the fact that the individual signatory 261
ceases to hold that office before delivery of the Bonds, the Financing Documents, or the Closing 262
Documents. 263
Sec.12. Maintenance of documents. 264
Copies of the specimen Bonds and of the final Financing Documents and Closing 265
Documents shall be filed in the Office of the Secretary of the District of Columbia. 266
Sec. 13. Information reporting. 267
Within 3 days after the Mayor’s receipt of the transcript of proceedings relating to the 268
issuance of the Bonds, the Mayor shall transmit a copy of the transcript to the Secretary to the 269
Council. 270
Sec. 14. Disclaimer. 271
(a) The issuance of Bonds is in the discretion of the District. Nothing contained in this 272
resolution, the Bonds, the Financing Documents, or the Closing Documents shall be construed as 273
obligating the District to issue any Bonds for the benefit of the Borrower or to participate in or assist 274
the Borrower in any way with financing, refinancing, or reimbursing the costs of the Project. The 275
Borrower shall have no claims for damages or for any other legal or equitable relief against the 276
District, its elected or appointed officials, officers, employees, or agents as a consequence of any 277
failure to issue any Bonds for the benefit of the Borrower. 278
(b) The District reserves the right to issue the Bonds in the order or priority it determines in 279
its sole and absolute discretion. The District gives no assurance and makes no representations that 280
any portion of any limited amount of bonds or other obligations, the interest on which is excludable 281
from gross income for federal income tax purposes, will be reserved or will be available at the time 282
of the proposed issuance of the Bonds. 283

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(c) The District, by adopting this resolution or by taking any other action in connection with 284
financing, refinancing, or reimbursing costs of the Project, does not provide any assurance that the 285
Project is viable or sound, that the Borrower is financially sound, or that amounts owing on the 286
Bonds or pursuant to the Loan will be paid. Neither the Borrower, any purchaser of the Bonds, nor 287
any other person shall rely upon the District with respect to these matters. 288
Sec. 15. Expiration. 289
If any Bonds are not issued, sold, and delivered to the original purchaser within 3 years of 290
the date of this resolution, the authorization provided in this resolution with respect to the issuance, 291
sale, and delivery of the Bonds shall expire. 292
Sec. 16. Severability. 293
If any particular provision of this resolution or the application thereof to any person or 294
circumstance is held invalid, the remainder of this resolution and the application of such provision to 295
other persons or circumstances shall not be affected thereby. If any action or inaction contemplated 296
under this resolution is determined to be contrary to the requirements of applicable law, such action 297
or inaction shall not be necessary for the purpose of issuing of the Bonds, and the validity of the 298
Bonds shall not be adversely affected. 299
Sec. 17. Compliance with public approval requirement. 300
This approval shall constitute the approval of the Council as required in section 147 (f) of the 301
Internal Revenue Code of 1986, as amended (the “Code”), and section 490(k) of the Home Rule Act, 302
for the Project to be financed, refinanced, or reimbursed with the proceeds of the Bonds. This 303
resolution approving the issuance of the Bonds for the Project has been adopted by the Council after 304
a public hearing held in accordance with section 147(f) of the Code, as such section may be 305

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amended, and the corresponding regulations promulgated by the United States Department of the 306
Treasury. 307
Sec. 18. Transmittal. 308
The Council shall transmit a copy of this resolution, upon its adoption, to the Mayor. 309
Sec. 19. Fiscal impact statement. 310
The Council adopts the fiscal impact statement of the committee report as the fiscal impact 311
statement required by section 4a of the General Legislative Procedures Act of 1975, approved 312
October 16, 2006 (120 Stat. 2038; D.C. Official Code § 1-301.47a). 313
Sec. 20. Effective date. 314
This resolution shall take effect immediately. 315
St. Patrick’s Episcopal Day School
Revenue Bond

FACT SHEET

St. Patrick’s Episcopal Day School has requested that the District issue up to $30,500,000 of tax-
exempt revenue bonds to finance, refinance, and refund costs associated with, renovations to
properties located at 4700/4701 Whitehaven Parkway, NW, and 1801 Foxhall Road, NW,
located in Ward 3.

The Applicant

Founded in 1956 by St. Patrick’s Church as a parish nursery school in the basement of a
townhouse, the St. Patrick’s Episcopal Day School has grown into an institution serving more
than 500 students, with separate elementary and middle school campuses in Washington, DC,
and plans are underway for a new combined high and middle school campus.

St. Patrick’s Episcopal Day School is an independent, coeducational, Episcopal day school for
students from nursery ages to the eighth grade. The school currently enrolls 507 students on two
campuses located on approximately 15 acres of land in the Georgetown area of DC. St. Patrick’s
is administered by a Headmaster and the board of Trustees.

The school has expanded several times over the decades, including in 2001 with the introduction
of a seventh- and eighth-grade program. Initially small and operating within another school’s
facilities, the middle school has since grown to near capacity and is now housed in a renovated
residence on MacArthur Boulevard. This campus includes a dedicated library and separate
humanities classrooms for each grade, while students travel to the main campus for math,
science, and STEM instruction. In 2002, the school completed a significant construction and
renovation project that transformed the outdoor play court at 4700/4701 Whitehaven Parkway,
NW, into a three-story academic wing with classrooms and a large, light-filled library.
Additional improvements included a new gymnasium and stage across the street, repurposing the
former gym into an art studio and multipurpose spaces, and the addition of a glass-enclosed foyer
and reception area. Further expansion followed in 2004 when The Friends of Saint Patrick’s
Episcopal Day School successfully acquired the Casey Mansion property at 1801 Foxhall Road,
NW.

The two campuses consist of several independent facilities that include over 110,000 square feet
of buildings. These facilities include three science labs, three libraries, three art studios, four
music rooms, a full gymnasium and performance stage, a mini gym for the nursery classes, three
playgrounds, and an athletic playing field.

Proposed Project

This financing is intended to provide financing or refinancing, on either a tax-exempt or taxable
basis, of all costs associated with two primary initiatives.

St. Patrick’s Episcopal Day School in the District of Columbia

2
First, the bonds will refinance the St. Patrick’s Episcopal Day School’s Series 2016 Bonds, the
proceeds of which were originally used to finance and refinance improvements to the school’s
campus located at 4700/4701 Whitehaven Parkway, NW, and 1801 Foxhall Road, NW.

Second, the bonds will support the financing and refinancing of the acquisition, improvement,
expansion, equipping, furnishing, and development of a new middle school facility of
approximately 33,000 square feet, to be constructed on the school’s main campus at 4700/4701
Whitehaven Parkway, NW.

This project also includes associated parking facilities and related real and personal property. In
addition, the financing will cover various related costs, including costs of issuance, reserve
funds, capitalized interest, interest rate swap termination costs, lease termination costs, credit
costs, and working capital.

Financing Plan

A summary of the proposed sources and uses of funds is attached (see Table 1).

Feasibility/Structure/Security of the Bonds

Davidson has reviewed the financial feasibil ity of the St. Patrick’s Episcopal Day School in
connection with the proposed approximately $30,500,000 revenue bond application. Based on
the assessment of the organization’s financial position and financing needs, Davidson believes
such financing is feasible. Bonds will be a general obligation of the school.

Legal and Regulatory Affairs

The law office of Bryant, Miller, Olive is assigned as bond counsel to the Revenue Bond
Program and has preliminarily determined that St. Patrick’s Episcopal Day School is a 501(c)(3)
organization, and the project constitutes a permissible undertaking in Section 490(a)(1) of the
District of Columbia Home Rule Act.

Based upon the information outlined in the application, the Revenue Bond Program staff has
determined that the proposed project complies with the criteria for approval of a proposed
financing transaction through the District’s Revenue Bond Program and will assist St. Patrick’s
Episcopal Day School in furthering its organizational mission.
St. Patrick’s Episcopal Day School in the District of Columbia

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TABLE 1
PROPOSED SOURCES AND USES OF FUNDS

SOURCES OF FUNDS
Bond Proceeds $30,500,000

Total Sources of Funds $30,500,000

USE OF FUNDS
New Construction $18,725,000
Refinancing/Refunding $11,500,000
Issuance Cost $275,000

Total Uses of Funds $30,500,000
GOVERNMENT OF THE DISTRICTOF COLUMBIA

OfficeoftheAttorneyGeneral
xk
alCommercialDivision‘TaxandFinanceSection ==
MEMORANDUM
To: WilliamLiggins,DirectorD.C.RevenueBond-EnterpriseZoneProgramOfficeoftheDeputyMayorforPlanningandEconomicDevelopment
FROM: AndreaR.Littlejif’&‘SeniorAssistantAttorney General
DATE: April15,2026
SUBJECT:LegalSufficiencyReview:St.Patrick’sEpiscopalDaySchoolRevenueBonds
ProjectApprovalResolutionof2026

‘Thisrespondstoarequestfromyourofficetoreviewforlegalsufficiencytheattacheddraftofthe
above-referencedproposedresolution.Forpurposesofthisreview,thisOfficepremisesits
conclusionontheassumptionthatyourofficehasdeterminedthattheBorrowerasdefinedinthe
aforementionedresolutionisa“qualifiedapplicant”withinthemeaningofSection490ofthe
DistrictofColumbiaHomeRuleAct.
A reviewoftheattacheddraftoftheabove-referencedproposedresolutionindicatesthatthedraft
proposedresolutionconformswiththeModelRevenueBondResolutionjointlydraftedand
determinedtobelegallysufficientbytheGeneralCounseloftheCouncil,theOfficeoftheAttomey
General,andtheDistrict'sbondcounsel.Accordingly,wefindtheattacheddraftoftheabove-
referencedproposedresolutionlegallysufficient.
Pleasecontactmeat724-7761ifyouhavefurtherquestionsorconcerns.
Attachments:St.Patrick'sEpiscopalDaySchoolRevenueBondsProjectApprovalResolution
of 2026
ARLart

“400SixthStreet,N.W.,Suite10100,Washington,DC20001Tel.:(202)724-7761Fax:(202)730-0486