1 617 526 6000 (t) +1 617 526 5000 (f) wilmerhale.com November 9, 2007 Pioneer Variable Contracts Trust 60 State Street Boston, Massachusetts 02109 Ladies and Gentlemen: This opinion is being delivered to you in connection with the Agreement and Plan...Agreement and Plan of Reorganization • November 27th, 2007 • Pioneer Variable Contracts Trust /Ma/
Contract Type FiledNovember 27th, 2007 CompanyThis opinion is being delivered to you in connection with the Agreement and Plan of Reorganization (the "Agreement") made as of November 5, 2007 by and between Pioneer Variable Contracts Trust, a Delaware statutory trust (the "Trust"), on behalf of its series, Pioneer Fund VCT Portfolio ("Acquiring Portfolio"), and the Trust on behalf of its series, Pioneer Value VCT Portfolio ("Acquired Portfolio"). Pursuant to the Agreement, Acquiring Portfolio will acquire all of the assets of Acquired Portfolio in exchange solely for (i) the assumption by Acquiring Portfolio of all of the Assumed Liabilities of Acquired Portfolio as defined in the Agreement (the "Acquired Portfolio Liabilities"), and (ii) the issuance of shares of beneficial interest of Acquiring Portfolio (the "Acquiring Portfolio Shares") to Acquired Portfolio, followed by the distribution by Acquired Portfolio, in liquidation of Acquired Portfolio, of the Acquiring Portfolio Shares to the shareholders of Acquired Portfolio and t
Harbor Small Cap Growth Fund Harbor Growth Fund One SeaGate Toledo, Ohio 43666 Ladies and Gentlemen: This opinion is being delivered to you in connection with the Agreement and Plan of Reorganization (the "Agreement"), made as of ___________, 2002...Agreement and Plan of Reorganization • August 1st, 2002 • Harbor Fund
Contract Type FiledAugust 1st, 2002 CompanyThis opinion is being delivered to you in connection with the Agreement and Plan of Reorganization (the "Agreement"), made as of ___________, 2002 between Harbor Growth Fund ("Acquiring Fund") and Harbor Small Cap Growth Fund ("Acquired Fund"), each a series of Harbor Fund, a Delaware business trust. Pursuant to the Agreement, Acquiring Fund acquired all of the assets of Acquired Fund in exchange solely for (i) the assumption by Acquiring Fund of all of the liabilities of Acquired Fund (the "Acquired Fund Liabilities") and (ii) the issuance of shares of beneficial interest of the Institutional Class of the Acquiring Fund (the "Acquiring Fund Shares") to Acquired Fund, followed by the distribution by Acquired Fund, in liquidation of Acquired Fund, of the Acquiring Fund Shares to the shareholders of Acquired Fund and the termination of Acquired Fund (the foregoing together constituting the "Transaction"). All section references, unless otherwise indicated, are to the United States Intern
Harbor International Fund Harbor International Fund II One SeaGate Toledo, Ohio 43666 Ladies and Gentlemen: This opinion is being delivered to you in connection with the Agreement and Plan of Reorganization (the "Agreement"), made as of ___________,...Agreement and Plan of Reorganization • August 1st, 2002 • Harbor Fund
Contract Type FiledAugust 1st, 2002 CompanyThis opinion is being delivered to you in connection with the Agreement and Plan of Reorganization (the "Agreement"), made as of ___________, 2002 between Harbor International Fund ("Acquiring Fund") and Harbor International Fund II ("Acquired Fund"), each a series of Harbor Fund, a Delaware business trust. Pursuant to the Agreement, Acquiring Fund acquired all of the assets of Acquired Fund in exchange solely for (i) the assumption by Acquiring Fund of all of the liabilities of Acquired Fund (the "Acquired Fund Liabilities") and (ii) the issuance of shares of beneficial interest of the Institutional Class of the Acquiring Fund (the "Acquiring Fund Shares") to Acquired Fund, followed by the distribution by Acquired Fund, in liquidation of Acquired Fund, of the Acquiring Fund Shares to the shareholders of Acquired Fund and the termination of Acquired Fund (the foregoing together constituting the "Transaction"). All section references, unless otherwise indicated, are to the United States