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ONE WORLD TRADE CENTER BROWN & WOOD BIS CONNECTICUT AVENUE,N.W. NEW YORK, N.Y. 10048-0557 WASHINGTON,D.C. 20006-4004 TELEPHONE: 212-839-5300 TELEPHONE: 202-973-0600 FACSIMILE: 212-S39-5599 10900 WI LSHI RE BOULEVARD FACSIMILE: 202-223-0465 Los ANGELES, CALIFORNIA 9002 4-39 5 9 S55 CALIFORNIA STREET 172 WEST STATE STREET SAN FRANCISCO, CA. 94104-171S TELEPHONE:310-443-0200 TRENTON, N.J. OB60E1-1104 TELEPHONE: 415-772-1200 FACSIMILE: 310-20B-5740 TELEPHONE: 609- 393-0303 FACSIMILE: 415-397-4521 FACSIMILE: 609-393-1990 SHIROYAMA JT MORI BUILDING, 15TH FLOOR BLACKWELL HOUSE 3-I, TORANOMON 4-CHOME, MINATO-KU GUILDHALL YARD TOKYO 105, JAPAN LONDON EC2V BAB TELEPHONE: 03-647 2-5380 TELEPHONE: 071-606-1888 FACSIMILE: 03-S472-5050 FACSIMILE: O>I-)BB-1 BO> March 23, 1994 Smith Barney Shearson Inc. , as representative 1345 Avenue of the Americas New York, New York 10105 $107, 399,438 . 50 Santa Ana Financing Authority Police Administration and Holding Facility Lease Revenue Bonds Series 1994A Ladies and Gentlemen: We have acted as counsel for you, Smith Barney Shearson Inc . in your capacity as representative (the "Representative" ) of the underwriters listed on the execution page of the Purchase Contract (the "Purchase Contract") , dated March 8, 1994, by and among Smith Barney Shearson Inc . , as Representative, the Santa Ana Financing Authority (the "Authority" ) and the City of Santa Ana (the "City" ) , in connection with the sale of the Santa Ana Financing Authority Police Administration and Holding Facility Lease Revenue Bonds, Series 1994A in the aggregate principal amount of $107, 399, 438 . 50 (the "Bonds") . We have as such counsel examined originals, or copies certified or otherwise identified to our satisfaction, of such documents, records and other instruments as we deemed necessary or appropriate for the purpose of this opinion. In rendering our opinion herein, we are not expressing any opinion or view on the validity, accuracy or sufficiency of documents, certificates or opinions that we have examined or on the authorization, issuance, delivery or validity of the Bonds nor the exclusion from gross income for Federal income tax purposes or the exemption from taxation in the State of California of interest on the Bonds . Further, we have assumed, but not independently verified, that the signatures of all documents, certificates and opinions that we have reviewed are genuine.