CT2018-1616 Amendement No. 1 AOL

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NORTON & SMITH, P.C. Castle Pines North Metropolitan District Kutak Rock LLP June 21, 2018 Page 3 Except as specifically stated in paragraph 1 hereof, we express no opinion hereunder. Unless and except as specifically provided herein, we express no opinion as to any of the documents prepared by Bond Counsel, the CWCB, or any other parties to the transactions contemplated herein or therein, including warranties and/or representations contained therein,nor except as specifically provided above, do we express any opinion as to the effect of their execution by members of the Board or others. We express no opinion to any of the following: (a)the Client's financial condition and/or the sufficiency of the security provided for payment of debt service on the Amendment Documents, including whether the Client will be financially able to perform its obligations under the Amendment Documents; (b)the use of the proceeds of the Loan Amendment as contemplated by the Amendment Resolution, the Amendment Documents or any other document connected to the closing on the Loan Amendment; (c) the treatment for federal, state or local income tax purposes of interest payable with respect to the Amendment or the federal or state tax consequences of the issuance of the Amendment or execution and delivery of any of the documents referred to herein; or(d)the validity or enforceability of any provision which purports to require the Client to indemnify or hold any person harmless. This opinion letter is solely for the addressee's information in connection with the approval of the Amendment Resolution and execution and delivery of the Amendment Documents, and is not to be quoted in whole or in part or otherwise referred to (except in closing documents), nor is it to be delivered to any other person (except as a part of a closing transcript connected to the closing of the Loan Amendment), without our prior written consent. Other than the addressee hereof, no one is entitled to use or rely on this opinion letter without the written consent of our firm. Our firm represents only the Client in the transactions contemplated by the Amendment Resolution; delivery of this letter does not establish an attorney-client relationship with any other party. We expressly undertake no responsibility or duty to inform any party, whether addressees hereof or not, as to any change in fact, circumstance or law occurring after the date hereof which may affect or alter any of the opinions, statements or information set forth above. Norton& Smith, P.C. 1/Ott 69t— " /)e. JMF1624FINAL