EXECUTION VERSION AGREEMENT AND PLAN OF MERGER*Agreement and Plan of Merger • November 13th, 1997 • National Data Corp • Services-business services, nec • Delaware
TABLE OF CONTENTSAgreement • November 13th, 1997 • National Data Corp • Services-business services, nec • Delaware
EXHIBIT 8.1 [LETTERHEAD OF ALSTON & BIRD LLP APPEARS HERE] November 13, 1997 National Data Corporation National Data Corporation Plaza 1564 N.E. Expressway Atlanta, Georgia 30329-2010 Re: Agreement and Plan of Merger by and Between National Data...National Data Corp • November 13th, 1997 • Services-business services, nec
We have acted as counsel to National Data Corporation ("NDC"), a corporation organized and existing under the laws of the State of Delaware, in connection with the proposed merger of Dunkirk, Inc., a wholly-owned subsidiary of NDC ("Sub"), with and into Source Informatics Inc. ("Source"), a corporation organized and existing under the laws of the State of Delaware, with Source as the surviving corporation (the "Merger"). The Merger will be effected pursuant to the Agreement and Plan of Merger by and between NDC, Sub, and Source dated as of August 20, 1997, as amended as of November 7, 1997 (the "Agreement"). In our capacity as counsel to NDC, our opinion has been requested with respect to the accuracy of the material under the heading "Certain Federal Income Tax Consequences" in the registration statement on Form S-4 filed by NDC with the Securities and Exchange Commission under the Securities Act of 1933, as amended on September 19, 1997, amended on October 29, 1997, and further amend
IN WITNESS WHEREOF, each of the Parties has caused this Agreement to be executed on its behalf and its corporate seal to be hereunto affixed and attested by officers thereunto as of the day and year first above written. National Data Corporation By:...Agreement and Plan of Merger • November 13th, 1997 • National Data Corp • Services-business services, nec
