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EXHIBIT A
SUPPLEMENTAL OPINION OF BOND COUNSEL
July __, 2026
Colliers Securities LLC
90 South 7th Street, Suite 4300
Minneapolis, MN 55402-4108
$24,000,000
Newport News Redevelopment and Housing Authority
Multifamily Housing Revenue Bonds
(Stuart Gardens II Apartments)
Series 2026
Ladies and Gentlemen:
This opinion is being rendered to you pursuant to the Bond Purchase Agreement (the “Bond
Purchase Agreement”), dated July __, 2026, among the Newport News Redevelopment and Housing
Authority (the “Issuer”), the Underwriter named therein (the “Underwriter”) and Stuart Gardens II Housing
Partners, LP, a Virginia limited partnership (the “Borrower”), relating to the sale by the Issuer of the above-
captioned bonds (the “Bonds”) which are being issued pursuant to the Indenture of Trust (the “Indenture”),
dated as of July __, 2026, by and between the Issuer and U.S. Bank Trust Company, National Association,
as trustee.
We have acted as Bond Counsel in connection with the issuance and sale of the Bonds, and in that
capacity we have participated in various conferences with representatives of and counsel for the
Underwriter, representatives of and counsel for the Borrower, and representatives of and counsel for the
Issuer relating to the preparation of the Official Statement, dated July __, 2026 (the “Official Statement”).
In addition, we have participated in the preparation of the Indenture. We have also examined the documents
and other items referred to in our opinion of even date herewith relating to the Bonds.
Based on and subject to the foregoing, and in reliance thereon, we are of the opinion that:
1. The Bonds are not subject to the registration requirements of the Securities Act of 1933,
as amended, and the Indenture is exempt from qualification under the Trust Indenture Act of 1939, as
amended.
2. The statements contained in the Official Statement (except as to any statistical and financial
data included in the Official Statement and except for the information relating to The Depository Trust
Company, its Participants and its book-entry only system, as to which we do not express an opinion) under
the captions “THE BONDS,” “TAX MATTERS,” “APPENDIX A – DEFINITIONS OF CERTAIN
TERMS,” “APPENDIX C – SUMMARY OF CERTAIN PROVISIONS OF THE INDENTURE,”
“APPENDIX D – SUMMARY OF CERTAIN PROVISIONS OF THE LOAN AGREEMENT” and
“APPENDIX E – SUMMARY OF CERTAIN PROVISIONS OF THE REGULATORY
AGREEMENT,” insofar as such statements contained under such captions purport to summarize certain
provisions of the Bonds, the Indenture, the Loan Agreement, the Tax Regulatory Agreement, and certain
aspects of our firm's opinion relating to the federal and Commonwealth of Virginia tax implications of certain
aspects of the Bonds, present an accurate summary of such matters.Jump to an indexed page (744 of 744)