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litigation pending against the Board that the Board either (1) has meritorious defenses <br />against claims asserted in such litigation, (2) is immune from liability under principles of <br />sovereign immunity, or (3) has adequate insurance coverage or reserves against liability <br />with respect to such claims. As such, there is no assurance that the Board will not now or <br />in the future incur liability and damages for which adequate reserves do not exist, as a result <br />of such litigation. In the event of such liability, the Board could be required, among other <br />responses, to expend reserves, reduce the level of services, or borrow money in order to <br />satisfy such liability. It is not expected that any such liability would affect the obligation <br />of the Board to apply the Non -Ad Valorem Revenues budgeted and appropriated in <br />accordance with the provisions of the Resolution. <br />The Series 2025 Bonds. There is no pending or, to the knowledge of the County, <br />threatened litigation against the County which in any way questions or affects (1) the <br />Project, (2) the validity of the Series 2025 Bonds, or any proceedings or transactions <br />relating to their sale, issuance, or delivery, or (3) the covenant to budget and appropriate <br />Non -Ad Valorem Revenues sufficient to repay the Series 2025 Bonds. <br />LEGAL MATTERS <br />Certain legal matters in connection with the authorization and issuance of the Series <br />2025 Bonds are subject to the approval of Nabors, Giblin & Nickerson, P.A., Tampa, <br />Florida, Bond Counsel and Jennifer W. Shuler, Esq. County Attorney. Certain disclosure <br />matters will be passed upon by Nabors, Giblin & Nickerson, P.A., Tampa, Florida, as <br />Disclosure Counsel to the County. <br />The proposed text of the legal opinion of Bond Counsel is set forth in APPENDIX <br />D. The actual legal opinion may vary from that text if necessary to reflect facts and law <br />on the date of delivery. The opinion will speak only as of its date, and subsequent <br />distribution of it by recirculation of this Official Statement or otherwise shall create no <br />implication that subsequent to the date of the opinion Bond Counsel has reviewed or <br />expresses any opinion concerning any matters referenced in the opinion. Bond Counsel's <br />opinion is based on existing law, which is subject to change. Such opinion is further based <br />on factual representations made to Bond Counsel as of the date thereof. Bond Counsel <br />assumes no duty to update or supplement the opinion to reflect any facts or circumstances, <br />including changes in law, that may thereafter occur or become effective. <br />The legal opinions to be delivered concurrently with the delivery of the Series 2025 <br />Bonds express the professional judgment of the attorneys rendering the opinions regarding <br />the legal issues expressly addressed therein. By rendering a legal opinion, the opinion <br />giver does not become an insurer or guarantor of the result indicated by that expression of <br />professional judgment, of the transaction on which the opinion is rendered, or of the future <br />performance of the parties to the transaction, nor does the rendering of an opinion guarantee <br />the outcome of any legal dispute that may arise out of the transaction. <br />