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EXHIBIT A-2 <br />TO THE <br />BOND PURCHASE AGREEMENT <br />Form of Supplemental Opinion of Bond Counsel <br />Dougherty & Company LLC <br />90 South Seventh Street, Suite 4300 <br />Minneapolis, MN 55402-4115 <br />, 2013 <br />Best & Flanagan LLP <br />225 South Sixth Street, Suite 4000 <br />Minneapolis, Minnesota 55402 <br />Re: $ City of Ramsey, Minnesota Charter School Lease Revenue Bonds <br />(PACT Charter School Project), Series 2013A and $ City of Ramsey, <br />Minnesota Taxable Charter School Lease Revenue Bonds (PACT Charter School <br />Project), Series 2013B (collectively, the "Bonds") <br />Ladies and Gentlemen: <br />We have delivered this day our approving legal opinion relating to the above -referenced <br />bonds (the "Bonds"), which you may rely upon as though addressed to you. We have also <br />examined a copy of the Official Statement dated , 2013 relating to the Bonds (the <br />"Official Statement") and such other documents relating to the Bonds as are referred to in our <br />approving opinion. Terms used herein shall have the meaning assigned in our other opinion, or <br />if not defined therein, as defined in the Official Statement. Based upon such examinations and <br />present laws, regulations, rulings and decisions, it is our opinion that: <br />1. The offer and sale of the Bonds and the underlying securities, if any, are exempt <br />from registration under the Securities Act of 1933, as amended, and the Indenture is not required <br />to be qualified under the Trust Indenture Act of 1939, as amended. <br />2. I'hc description of the Bonds, the Indenture, the Loan Agreement, the Mortgage <br />and the Tax Regulatory Agreement (collectively, the "Bond Documents") under the captions <br />"SUMMARY INFORMATION," "INTRODUCTORY STATEMENT," "THE SERIES 2013 <br />BONDS," "SECURITY FOR THE BONDS," and "TAX MATTERS" in the Official Statement <br />and in Appendix C: "THE LOAN AGREEMENT," "THE INDENTURE," "THE <br />MORTGAGE" and "THE PLEDGE AND COVENANT AGREEMENT" to the Official <br />Statement are fair and accurate and conform in all material respects to the provisions of the Bond <br />Documents purported to be summarized therein, and the applicable statements contained in the <br />Official Statement under the caption "TAX MATTERS" accurately reflect the applicable <br />portions of our approving legal opinion referenced above in all material respects. <br />you. <br />You may rely on our approving legal opinion referenced above as if it were addressed to <br />Very truly yours, <br />A-2-1 <br />