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Tab 16 Reliance OpinionTAMPA 2502 Rocky Point Drive Suite 1060 Tampa, Florida 33607 (813) 281 -2222 Tel (813) 281 -0129 Fax FORTIAUDERDALE 110 East Broward Boulevard Suite 1700 Fort Lauderdale, Florida 33301 (954) 315 -3852 Tel Pinnacle Public Finance, Inc. Scottsdale, Arizona FORT MYERS 16 12731 World Plaza Lane Suite 2 Fort Myers, Florida 33907 (239) 288 -4027 Tel (239) 288 -4057 Fax TALLAHASSEE 1500 Mahan Drive Suite 200 Tallahassee, Florida 32308 (850) 224 -4070 Tel (850) 224.4073 Fax October 21, 2014 Re: $31,885,000 Monroe County, Florida Infrastructure Sales Surtax Improvement and Refunding Revenue Bond, Series 2014 Dear Sir or Madam: We have acted as Bond Counsel to the Monroe County, Florida (the "County ") in connection with the issuance by the County of $31,885,000 principal amount of Monroe County, Florida Infrastructure Sales Surtax Improvement and Refunding Revenue Bond, Series 2014 (the "Series 2014 Bond ") pursuant to Resolution No. 077 -2003 adopted by the Board of County Commissioners of the County on February 19, 2003, as amended and supplemented, and we have participated in various proceedings relating thereto. Of even date herewith we have also delivered to the County our approving opinion as Bond Counsel with respect to the Series 2014 Bond. This letter will confirm that you may rely on such opinion as if it were addressed to you; provided, however, no attorney - client relationship has existed or exists between our firm and yours in connection with the Series 2014 Bond and by virtue of this letter or our approving opinion. This letter is delivered to you solely for your benefit as the initial purchaser of the Series 2014 Bond and may not be used, circulated, quoted or otherwise referred to or relied upon for any other purpose or by any other person. This letter is furnished by us in our capacity as Bond Counsel for the County and not as counsel to any other person. Very truly yours, V / it/,4 /�