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.__ ___. .... .._........... Legal Opinion The Successful Bidder will be furnished,without cost,with the approving opinion of Bryant, Miller and Olive, P.A., Tallahassee, Florida, to the effect that based on existing law, and assuming compliance by the County with certain covenants and requirements of the Internal Revenue Code of 1986, as amended (the "Code"), regarding use, expenditures, investment of proceeds and the timely payment of certain investment earnings to the United States Treasury, the interest on the Series 2001 Bonds is not includable in the gross income of individuals, however, interest on the Series 2001 Bonds will be included in the calculation of the alternative minimum tax liabilities of corporations. The Code contains other provisions that could result in tax consequences, upon which Bond Counsel renders no opinion, as a result of ownership of the Series 2001 Bonds or the inclusion in certain computations (including, without limitation, those related to the corporate alternative minimum tax and environmental tax) of interest that is excluded from gross income. Official Statement The Preliminary Official Statement, copies of which may be obtained as described below, is in a form "deemed final" by the County for purposes of SEC Rule 15c2-12(b)(1) (except for certain permitted omissions as described in such rule) but is subject to revision, amendment and completion in a final Official Statement. Upon the sale of the Series 2001 Bonds, the County will publish a final Official Statement in substantially the same form as the Preliminary Official Statement. Copies of the final Official Statement will be provided, at the County's expense, on a timely basis in such quantities as may be necessary for the Successful Bidder's regulatory compliance. It is not the intention or the expectation of the County to print the name(s) of the Successful Bidder as to the Series 2001 Bonds on the cover of the Official Statement. Continuing Disclosure The County has covenanted to provide ongoing disclosure in accordance with Rule 15c2-12 of the Securities and Exchange Commission. See "Appendix_--Form of Continuing Disclosure Certificate" attached to the Preliminary Official Statement. CUSIP Number It is anticipated that CUSIP identification numbers will be printed on the Series 2001 Bonds, but neither the failure to print such number on any Series 2001 Bonds nor any error with respect thereto shall constitute cause for failure or refusal by the Successful Bidder to accept delivery of and pay for the Series 2001 Bonds in accordance with its agreement to purchase the Series 2001 Bonds. All expenses in relation to the printing of CUSIP numbers on the Series 2001 Bonds shall be paid for by the County;provided,however,that the CUSIP Service Bureau charge for the assignment of said number shall be the responsibility of and shall be paid for by the Successful Bidder. Copies of Documents Page 8 of 9