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City of Little Canada, Minnesota <br />BankCherokee <br />St. John's Church <br />of Little Canada, Minnesota <br />March , 2013 <br />Page 2 <br />Based upon such examinations, and assuming the authenticity of all documents submitted <br />to us as originals, the conformity to original documents of all documents submitted to us as <br />certified or photostatic copies and the authenticity of the originals of such documents, and the <br />accuracy of the statements of fact contained in such documents, and based upon present <br />Minnesota and federal laws (which excludes any pending legislation which may have a <br />retroactive effect on or before the date hereof), regulations, rulings, and decisions, it is our <br />opinion that: <br />The Note Amendment will not adversely impact the tax - exempt status of the Note as set <br />forth in our approving legal opinion issued on December 20, 2007 relating to the exclusion from <br />gross income of interest on, and the validity and enforceability of, the Note. <br />We express no opinion regarding other state or federal tax consequences caused by the <br />receipt or accrual of interest on the Note or arising with respect to ownership of the Note. <br />In rendering this opinion, we have relied upon representations of the Borrower and its <br />officers as to the application of the proceeds of the Note and the nature, use, cost, and economic <br />life of the facilities financed by the Note. <br />5216662v1 <br />28 <br />Professional Association <br />