14-20 Cedar Glen Bond Ordinance Addendums

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The Bonds have been duly authorized, executed and issued by the Issuer and constitute valid and binding special and limited obligations of the Issuer enforceable in accordance with their terms. The interest on the Bonds is excludable from the gross income for federal income tax purposes under Section 103 of the Internal Revenue Code of 1986, as amended and in effect on the date hereof(the "Code"). Under Section 147(a) of the Code, interest on a Bond will not be excludable from gross income for federal income tax purposes during the time such Bond is held by a person who is a "substantial user" of the facilities financed by the Bond or a "related person" thereto within the meaning of Section 147(a) of the Code and the regulations promulgated pursuant thereto. Interest on the Bonds is not an item of tax preference for purposes of the federal alternative minimum tax imposed on individuals under the Code. The opinions set forth in this paragraph 3 are subject to the condition that the Issuer and the Borrower comply with all requirements of the Code that must be satisfied subsequent to the issuance of the Bonds in order that interest thereon be, or continue to be, excludable from gross income for federal income tax purposes. Failure to comply with certain of such requirements may cause the interest on the Bonds to cease to be excludable from gross income for federal income tax purposes retroactive to the date of issuance of the Bonds. The Issuer and the Borrower have covenanted to comply with all such requirements. We express no opinion regarding any other federal tax consequences arising with respect to the Bonds. The interest on the Bonds is exempt from taxation in the State of Indiana for all purposes except the Indiana financial institutions tax. It is to be understood that the enforcement of certain rights and remedies provided in the Bonds, the Trust Indenture, the Loan Agreement and the Regulatory Agreement may be limited by the laws of the State of Indiana, but such laws of the State of Indiana do not prevent the practical realization of the principal benefits or the security provided by the Bonds, the Trust Indenture, the Loan Agreement and the Regulatory Agreement. It is further understood that the rights of the holders of the Bonds, the Issuer and the Borrower and the enforceability of the Bonds, the Trust Indenture, the Loan Agreement and the Regulatory Agreement may be subject to bankruptcy, insolvency, reorganization, rearrangement, receivership, moratorium and other laws and matters of public policy affecting creditors' rights heretofore or hereafter enacted and that their enforcement may also be subject to the exercise of judicial discretion and general principles of equity in appropriate cases. Very truly yours, FAEGRE DRINKER BIDDLE&REATH LLP -2-