Exhibit 8.3




                               September 22, 2003




To Each of the Persons
  Listed on Schedule A Hereto

         Re:     PHH Vehicle Management Services, LLC; Raven Funding LLC;
                 Chesapeake Funding LLC and D.L. Peterson Trust

Ladies and Gentlemen:

          We have acted as special Delaware counsel for PHH Vehicle Management
Services, LLC, a Delaware limited liability company ("VMS"), Raven Funding LLC,
a Delaware limited liability company (the "SPV"), Chesapeake Funding LLC
(formerly known as Greyhound Funding LLC), a Delaware limited liability company
(the "Issuer"), and D.L. Peterson Trust, a Delaware statutory trust (the
"Trust"), in connection with the matters set forth herein. At your request, this
opinion is being furnished to you.

          For purposes of giving the opinions hereinafter set forth, our
examination of documents has been limited to the examination of executed or
conformed counterparts or copies of the following:

          (a) The Certificate of Formation of VMS, dated April 1, 1999, as filed
in the office of the Secretary of State of the State of Delaware (the "Secretary
of State") on April 1, 1999, as amended by the Certificate of Amendment thereto,
dated June 24, 2002, as filed in the office of the Secretary of State on June
24, 2002;

          (b) The Limited Liability Company Agreement of VMS, dated as of April
1, 1999, agreed to by Avis Fleet Leasing and Management Corporation as successor
by merger to PHH Holdings Corporation, as the sole member of VMS, as amended by
the First Amendment thereto, dated as of August 14, 2003;

          (c) The Certificate of Formation of the SPV, dated June 23, 1999, as
filed in the office of the Secretary of State on June 24, 1999, as amended by
the Certificate of Amendment thereto, dated June 24, 2002, as filed in the
office of the Secretary of State on June 24, 2002;

          (d) The Limited Liability Company Agreement of the SPV, dated as of
June 30, 1999, and effective as of June 24, 1999, executed by VMS, as the sole
economic member of

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To Each of the Persons
Listed on Schedule A hereto
September 22, 2003
Page 2

the SPV (the "SPV Member"), and Lisa B. Hunt, Bernard J. Angelo and the other
Managers (as defined therein);

          (e) The Amended and Restated Limited Liability Company Agreement of
the SPV, dated and effective as of October 28, 1999, executed by the SPV Member,
and David O. Taylor, Bernard J. Angelo and the other Managers (as defined
therein), as amended by the First Amendment thereto, dated as of October 25,
2001, and further executed by Christopher T. Burt, as Independent Manager and
Special Member (each, as defined therein), and as amended by the Second
Amendment thereto, dated as of June 18, 2003;

          (f) The Certificate of Formation of the Issuer, dated June 23, 1999,
as filed in the office of the Secretary of State on June 24, 1999, as amended by
the Certificate of Amendment thereto, dated April 25, 2002, as filed in the
office of the Secretary of State on April 25, 2002, and as amended by the
Certificate of Amendment thereto, dated June 24, 2002, as filed in the office of
the Secretary of State on June 24, 2002;

          (g) The Limited Liability Company Agreement of the Issuer, dated as of
June 30, 1999, and effective as of June 24, 1999, executed by the SPV, as the
sole common member of the Issuer, and Tony Wong;

          (h) The Amended and Restated Limited Liability Company Agreement of
the Issuer, dated as of October 28, 1999, and effective on October 28, 1999,
executed by the SPV, as the sole common member of the Issuer, and Tony Wong, as
amended by the First Amendment thereto, dated as of April 25, 2002, the Second
Amendment thereto, dated as of June 18, 2003, and the Third Amendment thereto,
dated as of August 14, 2003;

          (i) The Certificate of Trust of the Trust, as filed in the office of
the Secretary of State of the State on June 29, 1999; and

          (j) The Amended and Restated Origination Trust Agreement of the Trust,
dated as of June 30, 1999, among the SPV, as successor settlor and initial
beneficiary, VMS, as existing settlor and initial beneficiary, VMS, as UTI
trustee, and Wilmington Trust Company, as Delaware Trustee, as amended by
Amendment No. 1 thereto, dated as of June 18, 2003, among the SPV, VMS and
Wilmington Trust Company, and agreed to by JPMorgan Chase Bank, as indenture
trustee, and the Issuer, as issuer.

          For the purposes of this opinion, we have not reviewed any documents
other than the documents listed in paragraphs (a) through (j) above, which we
believe are all the documents reasonably necessary for us to have considered for
purposes of rendering the opinions stated herein. In particular, we have not
reviewed any document (other than the documents listed in paragraphs (a) through
(j) above) that is referred to in or incorporated by reference into any document
reviewed by us. We have assumed that there exists no provision in any document
not listed above that is inconsistent with the opinions stated herein. We have
conducted no independent factual investigation of our own but rather have relied
solely upon the foregoing documents, the statements and information set forth
therein and the additional matters recited or assumed

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To Each of the Persons
Listed on Schedule A hereto
September 22, 2003
Page 3

herein, all of which we have assumed to be true, complete and accurate in all
material respects.

          With respect to all documents examined by us, we have assumed that (i)
all signatures on documents examined by us are genuine, (ii) all documents
submitted to us as originals are authentic, and (iii) all documents submitted to
us as copies conform with the original copies of those documents.

          For purposes of this opinion, we have assumed (i) the due organization
or due formation, as the case may be, and valid existence in good standing of
the Issuer, the Trust and each party to the documents examined by us under the
laws of the jurisdiction governing its organization or formation and the legal
capacity of natural persons who are signatories to the documents examined by us,
(ii) that each of the parties to the documents examined by us has the power and
authority to execute and deliver, and to perform its obligations under, such
documents, (iii) the due authorization, execution and delivery by all parties
thereto of all documents examined by us, (iv) that the documents listed in
paragraphs (a) through (j) above have not been amended and are in full force and
effect, (v) that there are no proceedings pending or contemplated for the
merger, consolidation, liquidation, dissolution or termination of the VMS, the
SPV, the Issuer or the Trust, and (vi) that none of VMS, the SPV, the Issuer or
the Trust will be treated as an association or publicly traded partnership
taxable as a corporation for U.S. federal income tax purposes. We have not
participated in the preparation of any offering material (other than this
opinion) relating to VMS, the SPV, the Issuer or the Trust and assume no
responsibility for the contents of any such material.

          This opinion is limited to the laws of the State of Delaware
(excluding the securities laws of the State of Delaware), and we have not
considered and express no opinion on the laws of any other jurisdiction,
including federal laws (including federal tax law) and rules and regulations
relating thereto. Our opinions are rendered only with respect to Delaware laws
and rules, regulations and orders thereunder which are currently in effect.

          Based upon the foregoing, and upon our examination of such questions
of law and statutes of the State of Delaware as we have considered necessary or
appropriate, and subject to the assumptions, qualifications, limitations and
exceptions set forth herein, we are of the opinion that none of VMS, the SPV,
the Issuer or the Trust will be treated as an association taxable as a
corporation for Delaware state income tax purposes.

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To Each of the Persons
Listed on Schedule A hereto
September 22, 2003
Page 4

          We consent to the filing of this opinion with the Securities and
Exchange Commission as an exhibit to the Registration Statement on Forms S-1 and
S-3 filed by the Issuer and the Trust with the Securities and Exchange
Commission under the Securities Act of 1933, for the registration of up to
$500,000,000 principal amount of the Issuer's Series 2003-2 Floating Rate
Callable Asset Backed Notes and the reference to us under the caption "Material
Federal and Certain State Income Tax Consequences" and under the caption "Legal
Matters" in such Registration Statement. In giving the foregoing consents, we do
not thereby admit that we come within the category of persons whose consent is
required under Section 7 of the Securities Act of 1933, as amended, or the rules
and regulations of the Securities and Exchange Commission thereunder.

                                             Very truly yours,

                                             /s/ Richards, Layton & Finger, P.A.



JHB/EAM/GWL


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                                   SCHEDULE A



D. L. Peterson Trust

Raven Funding LLC

Chesapeake Funding LLC

PHH Vehicle Management Services, LLC