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usual and required closing affidavits, certificates and documents. We also have <br />examined a specimen of an executed Series 1993 Bond and assume that, as required <br />by the Resolution, all of the Series 1993 Bonds have been similarly executed, <br />will be issued in registered form and will be authenticated by the Paying Agent, <br />acting as bond registrar. <br />As to questions of fact material to our opinion, we have relied upon the <br />certified proceedings and other certifications of public officials furnished to <br />us without undertaking to verify such facts by independent investigation. <br />Based on the foregoing, we are of the opinion that: <br />1, The County is apolitical subdivision of the State of Florida and has <br />the power to issue the Series 1993 Bonds, to acquire, construct, furnish, equip, <br />own-, operate and maintain the 1993 Project, and to own, operate and maintain the <br />System. <br />2. The Resolution has been duly adopted by the County and is a valid and <br />enforceable instrument. <br />3. The Series 1993 Bonds are valid and legally binding special <br />obligations of the County and are payable from and secured by a lien upon and <br />pledge of the Pledged Funds, as and to the extent provided in the Resolution, <br />4. The Series 1993 Bonds and the income therefrom are exempt from <br />taxation under the laws of the State of Florida, except estate taxes and taxes <br />imposed by Chapter 220, Florida Statutes, on interest, income or profits on debt <br />obligations owned by corporations, banks and savings associations. <br />5. Assuming investment and application of the proceeds of the Series <br />1993 Bonds as set forth in the Resolution and in the aforementioned non -arbitrage <br />- 4 - <br />