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8.A. - Page 94 <br /> 6. The Bonds have been duly authorized and executed by the Authority, and are valid and <br /> binding limited obligations of the Authority,payable solely from the Revenues and other funds provided <br /> therefor in the Indenture. <br /> 7. Interest on the Bonds is excludable from gross income for federal income tax purposes <br /> and is not an item of tax preference for purposes of the federal alternative minimum tax imposed on <br /> individuals and corporations; it should be noted, however, that for the purpose of computing the <br /> alternative minimum tax imposed on corporations (as defined for federal income tax purposes), such <br /> interest is taken into account in determining certain income and earnings. The opinions set forth in the <br /> preceding sentence are subject to the condition that the Authority and the City comply with all <br /> requirements of the Internal Revenue Code of 1986 that must be satisfied subsequent to the delivery of <br /> the Bonds in order that such interest be,or continue to be,excluded from gross income for federal income <br /> tax purposes. The Authority and the City have covenanted to comply with each such requirement. <br /> Failure to comply with certain of such requirements may cause the inclusion of interest on the Bonds in <br /> gross income for federal income tax purposes to be retroactive to the date of issuance of the Bonds. We <br /> express no opinion regarding other federal tax consequences arising with respect to the Bonds. <br /> 8. Interest on the Bonds is exempt from personal income taxation imposed by the State of <br /> California. <br /> The rights of the owners of the Bonds and the enforceability of the Bonds and the Indenture are <br /> limited by bankruptcy,insolvency,reorganization,moratorium and other similar laws affecting creditors' <br /> rights generally, and by equitable principles,whether considered at law or in equity. <br /> This opinion is given as of the date hereof, and we assume no obligation to revise or supplement <br /> this opinion to reflect any facts or circumstances that may hereafter come to our attention, or any changes <br /> in law that may hereafter occur.Our engagement with respect to this matter has terminated as of the date <br /> hereof. <br /> Respectfully submitted, <br /> A Professional Law Corporation <br /> Appendix E <br /> Page 2 <br />