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Tab 38 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 STEVE E. BULLOCK Suite200 Suite 209 Miami,Florida 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 BofA Securities, Inc. TRB Capital Markets, LLC d/b/a Estrada Hinojosa Jefferies LLC PNC Capital Markets LLC Raymond James & Associates, Inc. c/o BofA Securities, Inc. As Representative of the Underwriters 101 East Kennedy Boulevard, Suite 200 Tampa, Florida 33602 $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"). On the date hereof we have delivered to the Agency our opinion as Disclosure Counsel relating to the Series 2025 Bonds (the "Opinion"). We hereby advise that you may rely on the Opinion as if it were addressed to you. We are furnishing this letter to you solely for your benefit. The delivery of this letter to you does not create an attorney-client relationship. Very truly yours, data *:e7o