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<br />172809057v1 <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 />May 12, 2025 <br />VIA E-MAIL <br />City of Hugo <br />14669 Fitzgerald Avenue N <br />Hugo, MN 55038 <br />Legacy Christian Academy <br />3037 Bunker Lake Boulevard NW <br />Andover, MN 55304 <br />Re: Legacy Christian Academy 2025 Financing <br />Dear Ladies and Gentlemen: <br /> <br />We have been asked to serve as Bond Counsel in connection with the proposed issuance by the City of Hugo, <br />Minnesota (the “Issuer”) of an educational facility revenue note (the “Note”) to be purchased by a bank yet-to-be- <br />identified (the “Lender”). The proceeds of the Note will be loaned by the Issuer to Legacy Christian Academy (the <br />“Borrower”), and will be used to finance the acquisition of an educational facility located in the City of Andover (the <br />“Project”). Northland Securities (the “Placement Agent”) is acting as placement agent in this transaction. <br />In performing our services as Bond Counsel, our client will be the Issuer. Our principal responsibility as <br />Bond Counsel is to provide the Issuer, the Borrower and the Lender an expert opinion (the “Bond Opinion”), upon <br />which each of them and the holder of the Note may rely, as to (i) the validity and enforceability of the Note and the <br />Issuer’s obligations under the financing documents, and (ii) exemption of interest on the Note from federal income <br />taxes. We will also assume principal responsibility for drafting the financing documents and any security documents <br />agreed to by the parties. You are also in agreement that we will not be acting as a municipal advisor in regards to this <br />transaction. <br />The Bond Opinion will be executed and delivered by us in written form on the date the Note is purchased <br />and will be based on facts and law existing as of that date. Upon delivery of the Bond Opinion, our responsibilities as <br />Bond Counsel will be concluded with respect to this financing. <br />In rendering the Bond Opinion, we will rely upon representations of the Issuer, the Borrower, and the Lender <br />set forth in the financing documents, the certified proceedings, and other certifications of public officials, officials of <br />the Borrower and other persons (including certifications as to the use of Note proceeds and various tax matters) without <br />undertaking to verify the same by independent investigation. As Bond Counsel, we do not review the financial <br />condition of the Borrower or the financial feasibility of the financing, and we will express no opinion relating to the <br />foregoing. We do not expect to give any opinion with respect to the Borrower’s participation in the financing or the <br />status of title or the priority of any mortgage lien or security interest securing the Note. As to these and other matters <br />the parties will be relying upon the opinion to be given by counsel for the Borrower or upon a policy of title insurance. <br />Because the Lender has not yet been specifically identified, we are unable to run a complete conflicts check <br />at this time. We wish to point out to the parties that, while it is assumed that the Lender will engage separate counsel