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Legal Opinion <br />The Successful Bidder will be furnished, without cost, with the approving opinion of Bryant <br />Miller Olive, Tallahassee, Florida, to the effect that based on existing law, and assuming compliance <br />by the County with certain covenants and requirements of the Internal Revenue Code of 1986, as <br />amended (the "Code"), regarding use, expenditures, investment of proceeds and the timely payment <br />of certain investment earnings to the United States Treasury, the interest on the Series 2006 Bonds is <br />not includable in the gross income of individuals, however, interest on the Series 2006 Bonds will be <br />included in the calculation of the alternative minimum tax liabilities of corporations. The Code <br />contains other provisions that could result in tax consequences, upon which Bond Counsel renders <br />no opinion, as a result of ownership of the Series 2006 Bonds or the inclusion in certain <br />computations (including, without limitation, those related to the corporate alternative minimum tax <br />and environmental tax) of interest that is excluded from gross income. <br />Official Statement <br />The Preliminary Official Statement, copies of which may be obtained as described below, is <br />in a form "deemed final" by the County for purposes of SEC Rule 15c2 -12(b)(1) (except for certain <br />permitted omissions as described in such rule) but is subject to revision, amendment and <br />completion in a final Official Statement. Upon the sale of the Series 2006 Bonds, the County will <br />publish a final Official Statement in substantially the same form _ as the Preliminary Official <br />Statement. Copies of the final Official Statement will be provided, at the County's expense, on a <br />timely basis in such quantities as may be necessary for the Successful Bidder's regulatory <br />compliance. <br />It is not the intention or the expectation of the County to print the name(s) of the Successful <br />Bidder as to the Series 2006 Bonds on the cover of the Official Statement. <br />Continuing Disclosure <br />The County has covenanted to provide ongoing disclosure in accordance with Rule 15c2-12 <br />of the Securities and Exchange Commission. <br />CUSIP Number <br />It is anticipated that CUSIP identification numbers will be printed on the Series 2006 Bonds, <br />but neither the failure to print such number on any Series 2006 Bonds nor any error with respect <br />thereto shall constitute cause for failure or refusal by the Successful Bidder to accept delivery of and <br />pay for the Series 2006 Bonds in accordance with its agreement to purchase the Series 2006 Bonds. <br />All expenses in relation to the printing of CUSIP numbers on the Series 2006 Bonds shall be paid for <br />by the County; provided, however, that the CUSIP Service Bureau charge for the assignment of said <br />number shall be the responsibility of and shall be paid for by the Successful Bidder. <br />9 <br />