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• <br />1991 <br />Re: South Bend Redevelopment Authority Taxable Lease <br />.Rental Revenue Bonds (Coveleski Stadium Refundingt) <br />Gentlemen: <br />We have acted as bond counsel in connection with the <br />issuance by the South Bend Redevelopment Authority (the "Issuer"), <br />of Four Million Two Hundred Ninety Thousand Dollars ($4,290,000) <br />aggregate principal .amount of South Bend Redevelopment Authority <br />Taxable Lease Rental Revenue Bonds (Coveleski Stadium Refunding) <br />originally dated December 1, 1991 (the "Bonds"), pursuant to a <br />Trust Agreement (the °Trust Agreement") between .the Issuer and <br />Norwest Bank Indiana, N.A., as Trustee (the "Trustee"), dated as <br />of November 1, 1991. We have examined a certified transcript of <br />proceedings and such other certificates and documents and have <br />reviewed such other proceedings and such questions of law as we <br />have deemed necessary as a basis for this opinion. <br />It is understood that the rights. of the holders of the <br />Bonds, the Issuer and the Trustee and the enforceability of the <br />Bonds, the Trust Agreement and the Lease (as defined below), may <br />be subject to bankruptcy, insolvency, reorganization, moratorium <br />and other similar laws affecting creditors' rights .heretofore or <br />hereafter enacted to the extent constitutionally applicable, and <br />that their enforcement may also be subject to the exercise of <br />judicial discretion in appropriate cases. <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, covenants and certifications <br />of the Issuer and public officials contained in the Trust Agreement <br />and in the certified transcript of proceedings and other <br />certificates furnished to us. We have not been engaged or <br />undertaken to review the accuracy, completeness or sufficiency of <br />U <br />