HomeMy WebLinkAboutexhibit3EXHIBIT A-1
FORM OF OPINION OF OUTSIDE COUNSEL
FOR PARTY A
[LETTERHEAD OF CADWALADER, WICKERSHAM & TAFT]
[Date]
[Name]
[Address]
Ladies and Gentlemen:
We act as a counsel to Morgan Stanley Capital Services Inc. ("MSCS") in connection
with certain matters. We have been requested by MSCS to review the documents referred to herein and
to render the opinion expressed herein. In such connection, we have reviewed, (i) an ISDA Master
Agreement dated as of , 200_ (including the Schedule thereto) and (ii) a Confirmation
dated , 200_ , (collectively, the "Agreement") between MSCS and
(the "Counterparty"). In these regards, we have reviewed original, conformed, reproduction, or specimen
copies, identified to our satisfaction, of the Agreement and other relevant documents, and have made such
examination of applicable law as we have deemed necessary for the purpose of rendering the opinion
expressed herein.
Based upon the foregoing, we are of the opinion, subject to the qualifications expressed
herein, that the Agreement constitutes the legal and binding agreement of MSCS and is enforceable
against MSCS in accordance with its terms.
The opinion expressed herein is subject to the following qualifications:
(A) We are licensed to practice law in the State of New York, for purposes of the
opinion expressed herein we do not purport to be experts on any law other than the law of the State of
New York and the federal law of the United States of America, and we do not express any opinion herein
concerning any law other than the substantive law of the State of New York and of the United States of
America (as applicable, without regard to conflict of law principles).
(B) In our review of the documents referred to in the first paragraph of this letter, we
have assumed and have not independently verified that all signatures are genuine, that all documents
submitted to or obtained by us as originals are authentic, and that all documents submitted to or obtained
by us as conformed, reproduction, or specimen copies conform to the original documents and all such
originals are authentic.
(C) As to certain matters of fact, we have relied upon and have not independently
verified statements, representations, and warranties of MSCS and its representatives, including
statements, representations, and warranties contained in the Agreement, and have assumed and have not
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independently verified that all such statements, representations, and warranties are true, accurate, and
complete.
(D) In rendering the opinions expressed herein, we have assumed and have not
independently verified under the law of any jurisdiction that the opinions expressed in the letter dated the
date hereof of Mark Steffensen, Esq., Counsel to MSCS, addressed to the Counterparty in connection
with the Agreement are valid, reasonable, true, accurate, and complete.
(E) We have assumed and have not independently verified under the law of any
jurisdiction the legal capacity, power, and authority of the Counterparty to execute, deliver, and perform
its obligations under the Agreement, and of the individuals who executed and delivered the Agreement on
behalf of the Counterparty to do so. We have also assumed and have not independently verified. under the
law of any jurisdiction that the Agreement constitutes the legal, valid, and binding agreement of the
Counterparty and is enforceable against the Counterparty in accordance with its terms. In addition, we
have relied upon and have not independently verified statements, representations, and warranties of the
Counterparty and its representatives, including statements, representations, and warranties contained in
the Agreement, and have assumed and have not independently verified that all such statements,
representations, and warranties are true, accurate, and complete.
(F) The enforceability of each of the Agreement and the rights and remedies
thereunder are subject to, and may be limited by: (i) applicable bankruptcy, insolvency, reorganization,
moratorium, receivership, conservatorship, or other similar laws from time to time in effect relating to or
affecting generally the enforcement of creditors' rights; (ii) general principles of equity, including without
limitation concepts of materiality, reasonableness, good faith, and fair dealing (regardless of whether
considered in a proceeding at law or in equity); (iii) the availability of equitable remedies; (iv) the
discretion of a court or other authority or body to grant, impose, or render remedies under specific
circumstances; (v) Sections 9-406 and 9-408 of the New York Uniform Commercial Code to the extent
the Agreement purports to prohibit, restrict, or require the consent of the other party for, the transfer of, or
the creation, attachment or perfection of a security interest in, the Agreement or an interest therein; (vi)
limitations imposed by public policy, although we are not aware of any such limitations that would be
relevant to the enforceability of the Agreement; (vii) each party to the Agreement acting in a
commercially reasonable manner and in good faith in performing its obligations and exercising its rights
and remedies thereunder; and (viii) the discretion of a court or other authority or body to invalidate or
decline to enforce any right, remedy, or provision of the Agreement (including without limitation the
termination payment provisions of the Agreement) determined by it to be a penalty.
(G) We express no opinion herein as to (i) whether a court or other authority or body
located outside of the State of New York would enforce the governing law and submission to jurisdiction
provisions of the Agreement and (ii) the creation, legality, validity, perfection, enforceability, or priority
of any lien, security interest, or other encumbrance created or purported to be created pursuant to the
agreement.
We are furnishing this letter to you solely for your benefit in connection with the
transactions referred to herein. Without our prior written consent, this letter is not to be relied upon, used,
circulated, quoted or otherwise referred to by, or assigned to, any other person (including any person that
seeks to assert your rights in respect of this letter (other than your successor in interest by means of
merger, consolidation, transfer of a business or other similar transaction)) or for any other purpose. In
addition, we disclaim any obligation to update this letter for changes in fact or law, or otherwise.
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Very truly yours,