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Tab 37 L A W O F F I C E S O F Law Offices of Steve E.Bullock,P.A. 6800 Bird Road 8910 Miramar Parkway Suite STEVE E. BULLOCK e 209 Miami FloridaMiramar Miami,F 33155 Miramar,Florida 33025 (305)829-0084 (954)438-3795 FAX: (305)829-6324 FAX:(954)437-0450 sbullock@sebullocklaw.com Please Reply To: Miami August 7, 2025 Chairperson and Board of Commissioners Miami Beach Redevelopment Agency 1700 Convention Center Drive Miami Beach, Florida 33139 $240,910,000 MIAMI BEACH REDEVELOPMENT AGENCY Tax Increment Revenue Refunding Bonds Series 2025 (City Center/Historic Convention Village) Ladies and Gentlemen: We have served as Disclosure Counsel to our client, the Miami Beach Redevelopment Agency (the "Agency") in connection with the issuance by the Agency of its $240,910,000 in aggregate principal amount of Tax Increment Revenue Refunding Bonds, Series 2025 (City Center/Historic Convention Village)(the"Series 2025 Bonds"). The Series 2025 Bonds are being issued with the terms, for the purposes and subject to the conditions set forth in Resolution No. 619-2015 adopted by the Chairperson and members of the Agency (collectively, the "Commission") on October 14, 2015, as supplemented by Resolution No. 708-2025 adopted by the Commission on May 21, 2025, and by Resolution No. 2025-33681 adopted by the Mayor and City Commission of the City of Miami Beach, Florida on May 21, 2025, as described in the Preliminary Official Statement dated June 27, 2025 relating to the Series 2025 Bonds (the "Preliminary Official Statement") and in the Official Statement dated July 9, 2025 relating to the Series 2025 Bonds (the "Official Statement"). All capitalized terms used in this opinion that are not defined herein and not normally capitalized shall have the meaning ascribed to such terms in the Official Statement. In connection with the issuance and delivery of this opinion, we have considered such matters of law and fact and have relied upon such certificates and other information furnished to us as we have deemed appropriate. We are not expressing any opinion or views herein on the authorization, issuance, delivery or validity of the Series 2025 Bonds. To the extent that the opinions expressed herein relate to or are dependent upon the determination that the proceedings and actions related to the authorization, issuance and sale of the Series 2025 Bonds are lawful and valid under the laws of the State of Florida, or that the Series 2025 Bonds are valid and binding obligations of the Agency enforceable in accordance with their terms, or that interest on the Series Chairperson and Board of Commissioners Miami Beach Redevelopment Agency August 7, 2025 Page 2 2025 Bonds is excluded from the gross income of the owners thereof for federal income tax purposes, or that the Series 2025 Bonds and the interest thereon are exempt from taxation under the laws of the State of Florida, we understand that you are relying upon the opinions delivered on the date hereof of Squire Patton Boggs(US)LLP and no opinion is expressed herein as to such matters. The scope of our engagement with respect to the issuance of the Series 2025 Bonds was not to establish factual matters and, because of the wholly or partially non-legal character of many of the determinations involved in the preparation of the Preliminary Official Statement and the Official Statement, we are not passing on and do not assume any responsibility for, except as set forth in the immediately succeeding paragraph, the accuracy or completeness of the contents of the Preliminary Official Statement and the Official Statement (including, without limitation, its appendices) and we make no representation that we have independently verified the accuracy, completeness or fairness of such contents. As Disclosure Counsel to the Agency, we have participated in the preparation of the Preliminary Official Statement and the Official Statement and in discussions and conferences with officials of the Agency, Bond Counsel for the Agency, the Financial Advisor for the Agency, the Underwriters and Greenberg Traurig, P.A., Counsel to the Underwriters, in which the contents of the Preliminary Official Statement and the Official Statement and related matters were discussed. Solely on the basis of our participation in the preparation of the Preliminary Official Statement and the Official Statement,our examination of certificates, documents, instruments and records relating to the Agency and the issuance of the Series 2025 Bonds and the above- mentioned discussions, nothing has come to our attention which would lead us to believe that the Preliminary Official Statement (other than permitted omissions, as described in Rule 15c2-12 promulgated under the Securities Exchange Act of 1934, as amended), as of its date, and the Official Statement, as of its date and as of the date hereof(except for the financial, statistical and demographic data and information in the Preliminary Official Statement and the Official Statement, including, without limitation, the appendices thereto, the information relating to DTC, its operations and the book-entry only system, the Insurer and the Policy, and the information under the caption "UNDERWRITING," as to which no opinion is expressed), contains an untrue statement of a material fact or omits to state a material fact that is necessary to make the statements therein, in light of the circumstances under which they were made, not misleading. In reaching the conclusions expressed herein we have,with your concurrence,assumed and relied on, without independent verification, the genuineness and authenticity of all signatures not witnessed by us, the authenticity of all documents, records, instruments and letters submitted to us as originals, the conformity to originals of all items submitted to us as certified or photostatic copies, the legal capacity and authority of the persons who executed such items, the accuracy of all warranties, representations and statements of fact contained in the documents and instruments LAW OFFICES OF STEVE E.BULLOCK,P.A. Chairperson and Board of Commissioners Miami Beach Redevelopment Agency August 7, 2025 Page 3 submitted to us, and the continuing accuracy on this date of any certificates or other items supplied to us regarding the matters addressed herein. As to questions of fact material to our opinions, we have relied upon and assumed the correctness of the public records and certificates by, and representations of, public officials and other officers, and representatives of the parties to this transaction. We have no actual knowledge of any factual information that would lead us to form a legal opinion that the public records or certificates which we have relied upon contain any untrue statement of a material fact. The opinions expressed herein are based upon existing law as of the date hereof and we express no opinion herein as of any subsequent date or with respect to any pending legislation. We assume no obligation to supplement this opinion if any applicable laws change after the date hereof or if we become aware of any facts that might change the opinions expressed herein after the date hereof. The opinions expressed herein represent our professional judgment, are not a guarantee of result, and are limited to the laws of the State of Florida and the United States of America. The opinions expressed herein are furnished by us as Disclosure Counsel to our client, the Agency, solely for the use of the addressee named above and only in connection with the transaction to which reference is made above. Such opinions shall not extend to, and may not be used or relied upon by, any other person, firm, or corporation for any purpose whatsoever without our express prior written consent. The opinions expressed herein are limited to the matters set forth herein, and to the documents referred to herein, and do not extend to any other agreements, documents or instruments executed by the Agency. No other opinion should be inferred beyond the matters expressly stated herein. Respectfully submitted, l 1,T. LAW OFFICES OF STEVE E.BULLOCK,P.A.