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Quid & Thl'iniflig LzP Attorneys at Law August 11, 2009 City of Santa Ana 20 Civic Center Plaza Santa Ana, California 92701 Santa Ana Financing Authority 20 Civic Center Plaza Santa Ana, California 92701 The Bank of New York Mellon Trust Company, N.A, 700 South Flower Street, Suite 500 Los Angeles, California 90017 Financial Security Assurance, Inc. 31 West 52 Street New York, New York 10019 Phone: 415/7654550 Fax: 415/765.1555 OPINION: $12,150,000 Certificates of Participation (1998 City Hall Expansion Project) Evidencing Direct, Undivided Fractional Interests of the Owners Thereof in Tease Payments to be Made by the City of Santa Ana (Orange County, California), as the Rental for Certain Property Pursuant to a Lease Agreement with the Santa Ana Financing Authority Ladies and Gentlemen: We have been informed that the City of Santa Ana (the "City") desires to sublease a small portion of the property (the "Property") that is the subject of that certain Lease Agreement, dated as of January 1, 1998, by and between the Santa Anna Financing Authority and the City (the "Lease Agreement"), to a wireless phone company so that a small piece of wireless telephone equipment can be located thereon. As to questions of fact material to our opinion, we have relied upon representations of the City contained in the Lease Agreement and in the certified proceedings and certifications of public officials and others furnished to us without undertaking to verify the same by independent investigation. Based upon our examination, we are of the opinion, under existing law, that such sublease does not cause the interest components of the Lease Payments (as defined in the Lease Agreement) to become subject to federal income taxes or State personal income taxes. Respectively submitted, I - 1- rlio-t (;,`? 575 Market Street, Suite 3600 San Francisco, CA 94105-2874 4-6