WINTHROP, STIMSON, PUTNAM & ROBERTS ONE BATTERY PARK PLAZA NEW YORK, NY 10004-1490 TELEPHONE: 212-858-1000 TELEFAX: 212-858-1500 September 22, 2000Agreement and Plan of Merger • September 22nd, 2000 • Firstenergy Corp • Electric services
Contract Type FiledSeptember 22nd, 2000 Company IndustryThis opinion is limited to the federal income tax laws of the United States and does not consider the effects of any foreign, state or local laws or any United States federal laws other than those pertaining to income tax.