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4. The Bonds have been duly authorized, executed and delivered by the Agency and <br />are valid and binding special obligations of the Agency, payable solely from the sources <br />provided therefor in the Indenture. <br />5. Interest on the Bonds is excluded from gross income for federal income tax <br />purposes and is not an item of tax preference for purposes of the federal alternative minimum <br />tax imposed on individuals and corporations; it should be noted, however, that, for the <br />purpose of computing the alternative minimum tax imposed on corporations (as defined for <br />federal income tax purposes), such interest is taken into account in determining certain income <br />and earnings. The opinions set forth in the preceding sentences are subject to the condition that <br />the Agency comply with all requirements of the Code which must be satisfied subsequent to the <br />issuance of the Bonds in order that interest thereon be, or continue to be, excluded from gross <br />income for federal income tax purposes. The Agency has covenanted to comply with each such <br />requirement. Failure to comply with certain of such requirements may cause the inclusion of <br />interest on the Bonds in gross income for federal income tax purposes to be retroactive to the <br />date of issuance of the Bonds. We express no opinion regarding other federal tax consequences <br />arising with respect to the Bonds. <br />6. The interest on the Bonds is exempt from personal income taxation imposed by the <br />State of California. <br />The rights of the owners of the Bonds and the enforceability of the Bonds and the <br />Indenture may be subject to bankruptcy, insolvency, reorganization, moratorium and other <br />similar laws affecting creditors' rights heretofore or hereafter enacted and may also be subject to <br />the exercise of judicial discretion in appropriate cases. <br />Respectfully submitted, <br />A Professional Law Corporation <br />E-2 <br />