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Qlllllt ?, Th11111111g LLP <br />Attorneys at Law <br />August 11, 2009 <br />City of Santa Ana <br />20 Civic Center Plaza <br />Santa Ana, California 92701 <br />Santa Ana Financing Authority <br />20 Civic Center Plaza <br />Santa Ana, California 92701 <br />The Bank of New York Mellon Trust Company, N.A. <br />700 South Flower Street, Suite 500 <br />Los Angeles, California 90017 <br />Financial Security Assurance, Inc. <br />31 West 52 Street <br />New York, New York 10019 <br />575 Market Street, Suite 3600 <br />San Francisco, CA 94105-2874 <br />Phone: 415/765-1550 <br />Fax: 415/765-1555 <br />OPINION: $12,450,000 Certificates of Participation (1998 City Hall Hxpansion Project) <br />Evidencing Direct, Undivided Fractional Interests of the Owners Thereof i?t <br />Lease Payments to be Made by the City of Santa Ana (Orange County, <br />California), as the Rental for Certain Property Pursuant to a Lease Agreement <br />with the Santa Ana Finaa?cing Authority <br />Ladies and Gentlemen: <br />We have been informed that the City of Santa Ana (the "City") desires to sublease a <br />small portion of the pa•operty (the "Property") that is the subject of that certain Lease <br />Agreement, dated as of jantaary 1, 1998, by and between the Santa Ana Financing Authority and <br />the City (the "Lease Agreement"), to a wireless phone coanpany so that a small piece of wireless <br />telephone equipment can be located thereon. <br />As to questions of fact material to our opinion, we have relied upon representations of <br />the City contained in the Lease Agreement and in the certified proceedings and certifications of <br />public officials and others furnished to us without undertaking to verify the same by <br />independent investigation. <br />Based upon otar examination, we are of the opinion, under existing law, that such <br />sublease does not cause the interest components of the Lease Payments (as defined in the Lease <br />Agreement) to become subject to federal income taxes or State personal income taxes. <br />Respectively submitted, <br />J/