|
TALLAHASSEE
<br />1500 Mahan Drive
<br />Suite 200
<br />Tallahassee, Florida 32308
<br />(850) 224-4070 Tel
<br />(850) 224-4073 Fax
<br />FORT LAUDERDALE
<br />110 East Broward Boulevard
<br />Suite 1700
<br />Fort Lauderdale, Florida 33301
<br />(954) 315-3852 Tel
<br />Nabors
<br />Giblin &
<br />Nickers onPA
<br />Regions Capital Advantage, Inc.
<br />Birmingham, Alabama
<br />Re: $20,369,000 Indian River County, Florida
<br />Limited General Obligation Refunding Note, Series 2015
<br />Dear Sir or Madam:
<br />14
<br />FORT MYERS
<br />12731 World Plaza Lane
<br />Suite 2
<br />Fort Myers, Florida 33907
<br />(239) 288-4027 Tel
<br />(239) 288-4057 Fax
<br />TAMPA
<br />2502 Rocky Point Drive
<br />Suite 1060
<br />Tampa, Florida 33607
<br />(813) 281-2222 Tel
<br />(813) 281-0179 Fax
<br />April 9, 2015
<br />We have acted as Bond Counsel for Indian River County, Florida (the "County"), in
<br />connection with the issuance of the County's $20,369,000 Limited General Obligation Refunding
<br />Note, Series 2015 (the "Note"), issued pursuant to Resolution No. 2005-059 of the County, adopted
<br />May 17, 2005, as amended and supplemented, and particularly as supplemented by Resolution No.
<br />2015-047 of the County, adopted April 7, 2015 (collectively, the "Resolution"), and we have
<br />participated in various proceedings relating thereto. All terms not otherwise defined herein shall
<br />have the meanings ascribed thereto in the Escrow Deposit Agreement, dated as of April 1, 2015 (the
<br />"Escrow Deposit Agreement"), between the County and The Bank of New York Mellon Trust
<br />Company, N.A.
<br />As to questions of fact material to our opinion, we have relied upon representations of the
<br />County contained in the Resolution, the Escrow Deposit Agreement, the certified proceedings and
<br />other certifications furnished to us by or on behalf of the County without undertaking to verify the
<br />same by independent investigation. In addition, the opinions set forth below are subject to the same
<br />limitations, reliance, assumptions and caveats as are set forth in our approving opinion addressed to
<br />the County of even date relating to the Note.
<br />Based on the foregoing, we are of the opinion, as of the date hereof and under existing law,
<br />that, assuming the deposit and application of cash in accordance with the provisions of the Escrow
<br />Deposit Agreement, such deposit and application will cause the pledge of the full faith and taxing
<br />authority of the County to the Refunded Bonds (as defined in the Bond Resolution) to cease,
<br />terminate and become void and discharged.
<br />In rendering the opinion set forth above, we are relying upon the arithmetical accuracy of
<br />certain computations included in schedules provided by First Southwest Company regarding amounts
<br />necessary to pay the principal of, redemption premium, if any, and interest on the Refunded Bonds
<br />through and including July 1, 2016, the date of redemption thereof
<br />
|