Bingham letterhead]Agreement and Plan of Reorganization • July 19th, 2010 • Pioneer Series Trust I
This opinion is furnished to you pursuant to paragraph 8.5 of the Agreement and Plan of Reorganization (the “Agreement”), dated as of September 18, 2009, by and between Pioneer Series Trust I, a Delaware statutory trust (the “Acquiring Trust”), on behalf of Pioneer Oak Ridge Small Cap Growth Fund, a series thereof (the “Acquiring Fund”), and Pioneer Series Trust II, a Delaware statutory trust (the “Acquired Trust”), on behalf of Pioneer Small and Mid Cap Growth Fund, a series thereof (the “Acquired Fund”). All capitalized terms not otherwise defined herein have the meanings ascribed to them in the Agreement. The Agreement contemplates the acquisition of all of the assets of the Acquired Fund by the Acquiring Fund in exchange for (a) the assumption by the Acquiring Fund of the liabilities of the Acquired Fund and (b) the issuance and delivery by the Acquiring Fund to the Acquired Fund, for distribution, in accordance with paragraph 1.4 of the Agreement, pro rata to the Acquired Fund Sha
