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<br />132047861v2 <br /> <br /> <br /> <br />Taft Stettinius & Hollister LLP / Taftlaw.com / The Modern Law Firm <br />Catherine J. Courtney <br />612.977.8765 <br />CCourtney@taftlaw.com <br />2200 IDS Center, 80 South 8th Street <br />Minneapolis, MN 55402-2210 <br />Tel: 612.977.8400 | Fax: 612.977.8650 <br />taftlaw.com <br />Affirmative Action, Equal Opportunity Employer <br /> <br />April 24, 2024 <br />Kevin McKinnon <br />Minnesota Department of Employment and Economic Development <br />180 E 5th Street <br />Suite 1200 <br />St. Paul, MN 55101 <br />Re: City of Little Canada, Minnesota - Capital Campaign Financing Note, Series <br />2024 (Saint Paul Academy and Summit School Project) <br />Dear Mr. McKinnon: <br /> Our firm has been engaged to act as Bond Counsel in connection with the issuance of the <br />Note named above. This is to advise you that our firm has reviewed the attached resolution, the <br />letter of intent of Bremer Bank, National Association, the application of the City of Little Canada, <br />Minnesota (the "City"), the hiring plan of Saint Paul Academy and Summit School, and the letter <br />of transmittal from the City. Based upon a review of that material it is our opinion that the Project <br />referred to therein constitutes a project within the meaning of Minnesota Statutes, Section 469.153, <br />Subdivision 2(b) and that the proposed financing thereof as set forth in the attached resolution is <br />authorized by law. <br />Please do not hesitate to give me a call if there are any questions. <br /> <br /> Very truly yours, <br />Taft Stettinius & Hollister LLP <br />Catherine J. Courtney <br /> <br />CJC:ck <br />