HOLLYER BRADY SMITH TROXELL
BARRETT ROCKETT HINES & MONE LLP
551 Fifth Avenue
New York, NY 10176
Tel: (212) 818-1110
FAX: (212) 818-0494
e-mail: [email protected]
July 12, 2000
Aquila Cascadia Equity Fund
380 Madison Avenue, Suite 2300
New York, New York 10017
Ladies and Gentlemen:
You have requested that we render an opinion to
Aquila Cascadia Equity Fund (the "Fund"), which was
formerly named Short Term Asset Reserves, with respect
post-effective amendment No. 16 (the "Amendment") to
the Registration Statement of the Fund under the
Securities Act of 1933 (the "1933 Act") and No. 20
under the Investment Company Act of 1940 (the "1940
Act") which you propose to file with the Securities and
Exchange Commission (the "Commission"). The purpose of
the Amendment is to add a new Financial intermediaries
Class Shares ("Class I Shares" to the currently
existing shares of the Fund, Front-Payment Class Shares
("Class A Shares"), Level-Payment Class Shares ("Class
C Shares") and Institutional Class Shares ("Class Y
Shares").
We have examined originals or copies, identified
to our satisfaction as being true copies, of those
corporate records of the Fund, certificates of public
officials, and other documents and matters as we have
deemed necessary for the purpose of this opinion. We
have assumed without independent verification the
authenticity of the documents submitted to us as
originals and the conformity to the original documents
of all documents submitted to us as copies.
Upon the basis of the foregoing and in reliance
upon such other matters as we deem relevant under the
circumstances, it is our opinion that the Class A
Shares, Class C Shares, Class Y Shares and Class I
Shares of the Fund as described in the Amendment, when
issued and paid for in accordance with the terms set
forth in the prospectus and statement of additional
information of the Fund forming a part of its then
effective Registration Statement as heretofore,
herewith and hereafter amended, will be duly issued,
fully-paid and non-assessable to the extent set forth
therein.
This letter is furnished to you pursuant to your
request and to the requirements imposed upon you under
the 1933 Act and 1940 Act and is intended solely for
your use for the purpose of completing the filing of
the Amendment with the Commission. This letter may not
be used for any other purpose or furnished to or relied
upon by any other persons, or included in any filing
made with any other regulatory authority, without our
prior written consent.
We hereby consent to the filing of this opinion
with the Amendment.
Very truly yours,
HOLLYER BRADY SMITH TROXELL
BARRETT ROCKETT HINES & MONE LLP
/s/ W.L.D. Barrett
by: W.L.D. Barrett
