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Page 2 <br />BEST & FLANAGAN <br />of the Regulatory Agreement. Montreal Courts, LLP (the "Owner "), as the Owner of the Project and <br />the successor to the Company with respect to certain obligations under the Regulatory Agreement, <br />has requested that the Trustee and the City execute and deliver a Certificate of Termination of <br />Regulatory Agreement (which certifies that the Regulatory Agreement is null and void and of no <br />further force or effect) to provide for the termination of the Regulatory Agreement. In connection <br />with the proposed termination of the Regulatory Agreement, we have reviewed the Regulatory <br />Agreement, the Certificate of Termination of Regulatory Agreement, the applicable provisions of the <br />Internal Revenue Code of 1986, as amended, and such other matters as we have deemed relevant. <br />Based on such review, we are of the opinion that the termination of the Regulatory Agreement will <br />not adversely affect the exemption from federal income taxation of interest already received or to be <br />received on the Bonds. <br />Best & Flanagan, LLP <br />8 <br />