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<br />-2- 1988 <br />As to questions of fact material to our opinion, we have <br />relied, without undertaking to verify the same by independent <br />investigation, upon representations of the Issuer and .public <br />officials contained in the Trust Agreement and in the certified. <br />transcript of proceedings and other certificates furnished to ws. <br />We have not been engaged or undertaken to review the accuracy, <br />completeness or sufficiency of .any offering materials relating to <br />the Bonds, and we express no opinion relating thereto. <br />Based on the foregoing, we are of the opinion, under <br />existing law, as follows: <br />1. The Issuer is duly created and validly existing as <br />a separate body corporate and politic and as an instrumentality <br />of the City of South Bend, Indiana, with the power to enter into <br />the Trust Agreement and the Lease, perform the agreements on its <br />part contained therein and issue the Bonds. <br />2. The Lease has been duly entered into in accordance <br />with the provisions of Indiana Code 36-7-14 (the "Act") and is a <br />valid and binding Lease. All taxable property in the City of <br />South Bend Redevelopment District (the "District") is subject to <br />ad valorem taxation without limitation as to rate or amount to <br />_;: pay the lease rental. The District is required by the Act and <br />the Lease annually to levy and appropriate an amount sufficient <br />to pay the lease rentals. <br />3. The Issuer has duly authorized, sold, executed and <br />delivered the .Bonds and has duly authorized and executed the <br />Trust Agreement... The Bonds are the valid and binding. obligations <br />of the Issuer secured by the Trust Agreement and payable solely <br />from the Pledged Funds, as such term is defined in the Trust <br />Agreement, subject to the qualification that the enforcement of <br />certain rights and remedies provided in the Trust Agreement may <br />be limited by the laws of the State of Indiana, but such laws of <br />the State of Indiana do not prevent the practical realization of <br />the benefits or the security provided by the Trust Agreement. <br />4. The Bonds and the interest thereon are exempt from <br />all present Indiana taxes, except the Indiana .inheritance tax. <br />Yours very truly, <br /> <br />