Exhibit 8.1
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                        [Letterhead of White & Case LLP]



May 3, 2002


Chesapeake Funding LLC
307 International Circle
Hunt Valley, MD 21030

Re:    Federal and New York State Tax Classification of the Origination Trust,
       Raven Funding LLC, and Chesapeake Funding LLC
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Ladies and Gentlemen:

     We have acted as special counsel to Chesapeake Funding LLC (formerly known
as Greyhound Funding LLC), a Delaware limited liability company (the "Issuer"),
in connection with the transactions contemplated by (i) the Amended and Restated
Origination Trust Agreement, dated as of June 30, 1999 (the "Origination Trust
Agreement") by and among Raven Funding LLC, a Delaware limited liability company
("SPV"), as successor settlor and initial beneficiary, PHH Vehicle Management
Services, LLC, a Delaware limited liability company ("VMS"), as existing settlor
and initial beneficiary and the successor UTI Trustee, and Wilmington Trust
Company, a Delaware banking association (the "Delaware Trustee"), which created
a Delaware business trust known as the "D.L. Peterson Trust" (the "Trust"); (ii)
the Amended and Restated Limited Liability Company Agreement of Raven Funding
LLC, dated as of the 28th day of October, 1999, as amended (the "Raven LLC
Agreement"); and (iii) the Amended and Restated Limited Liability Company
Agreement of the Issuer, dated as of October 28, 1999, as amended (the
"Chesapeake LLC Agreement"). Capitalized terms used herein and not otherwise
defined shall have the respective meanings set forth in the Transaction
Documents.

        In connection with the transactions contemplated by the Registration
Statement on Forms S-1 and S-3 (the "Registration Statement") filed by the
Issuer and the Trust with the Securities and Exchange Commission under the
Securities Act of 1933, for the registration of $650,000,000 principal amount of
the Issuer's Series 2002-1 Floating Rate Callable Asset Backed Notes (the
"Series 2002-1 Investor Notes"), you have requested our advice as to the U.S.
federal income tax and New York State income and franchise tax classifications
applicable to the Trust, the SPV, and the Issuer (each, a "Pass-Through
Entity").

         In rendering the opinions set forth herein, we have examined and relied
on originals or copies, certified to our satisfaction, of the Origination Trust
Agreement, the Raven LLC Agreement, the Chesapeake LLC Agreement and other
documents prepared in connection



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therewith as we have deemed necessary or appropriate as a basis for the opinions
set forth below. We have also examined and relied upon the representations and
warranties made in or pursuant to, and we have assumed compliance with the
covenants and agreements set forth in, the Transaction Documents, and have made
such other investigations, as in our judgment are necessary or appropriate to
enable us to render the opinions expressed below. Our opinions are also based on
our understanding of certain assumptions related to each of the Pass-Through
Entities as set forth herein.

         In rendering our opinions, we have also considered and relied upon the
U.S. Internal Revenue Code of 1986, as amended (the "Code"), administrative
rulings, judicial decisions, U.S. Treasury Regulations, and such other
authorities as we have deemed appropriate, in each case as in effect on the date
hereof. The statutory provisions, U.S. Treasury Regulations, interpretations,
and other authorities upon which our opinions are based are subject to change,
and such changes could apply retroactively. In addition, there can be no
assurance that positions contrary to those stated in our opinions will not be
taken by the Internal Revenue Service.

         Under final Treasury Regulations under the Code, none of the
Pass-Through Entities will be classified as an association taxable as a
corporation for U.S. federal income tax purposes, absent an affirmative election
to the contrary. Treas. Reg. ss. 301.7701-3(b)(1). The Treasury Regulations
provide that such an election must be made by either each member of the electing
entity who is an owner at the time the election is filed or any officer,
manager, or member of the electing entity who is authorized to make the
election. Treas. Reg. ss. 301.7701-3(c)(2)(i). Section 5.8 of the Origination
Trust Agreement provides that neither the Trust nor any Trustee shall make or
authorize any Person to make an election to have the Trust classified or taxed
as a corporation for federal income tax purposes or any applicable state or
local income or franchise tax purposes. Section 14 of the Raven LLC Agreement
provides that neither the SPV nor any Manager or Member shall make or authorize
any Person to make an election to have the SPV classified or taxed as a
corporation for federal income tax purposes or any applicable state or local
income or franchise tax purposes. Section 11.2 of the Chesapeake LLC Agreement
provides that neither the Issuer nor any Manager or Member shall make or
authorize any Person to make an election for the Issuer to be classified or
taxed as a corporation for federal income tax purposes or any applicable state
or local income or franchise tax purposes. We assume that no election will be
made by any of the Pass-Through Entities, any Trustee, Manager, Member or any
other Person to treat any of the Pass-Through Entities as an association taxable
as a corporation for U.S. federal income tax purposes. Based upon the foregoing
and subject to the discussion of publicly traded partnership status below, it is
our opinion that none of the Pass-Through Entities will be treated as an
association taxable as a corporation for U.S. federal income tax purposes.

         One or more of the Pass-Through Entities may be classified as a
partnership for federal income tax purposes. Notwithstanding classification as a
partnership, however, a partnership will generally be taxed as a corporation for
U.S. federal income tax purposes if it is a "publicly



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traded partnership" as defined in Section 7704 of the Code. A publicly traded
partnership is a partnership the interests in which either are traded on an
established securities market or are readily tradable on a secondary market or
the substantial equivalent thereof.

         For purposes of the publicly traded partnership provisions, an
established securities market includes a national securities exchange registered
under the Securities Exchange Act of 1934 (the "Exchange Act"), a foreign
securities exchange that satisfies regulatory requirements that are analogous to
the regulatory requirements under the Exchange Act, a regional or local
exchange, and an interdealer quotation system that regularly disseminates firm
buy or sell quotations by identified brokers or dealers by electronic means or
otherwise. Treas. Reg. ss. 1.7704-1(b). Section 9.7 of the Origination Trust
Agreement provides that (i) each of the Initial Beneficiary and each Trustee
covenants and agrees that it will not transfer, assign, participate, pledge or
otherwise dispose of its interest in the Trust, or cause its interest to be
marketed, on or through an established securities market and (ii) any transferee
of a beneficial interest in the Trust will be required to make a similar
representation. Section 15 of the Raven LLC Agreement provides that (i) each
Member covenants and agrees that it will not transfer, assign, participate,
pledge or otherwise dispose of its interest in the SPV, or cause its interest to
be marketed, on or through an established securities market and (ii) any
transferee of an interest in the SPV will be required to make a similar
representation. Section 12.6 of the Chesapeake LLC Agreement provides that (i)
each of the Members covenants and agrees that it will not transfer, assign,
participate, pledge or otherwise dispose of its interest in the Issuer, or cause
its interest to be marketed, on or through an established securities market and
(ii) any transferee of an interest in the Issuer will be required to make a
similar representation.

         In order to avoid publicly traded partnership status, no interest in
any of the Pass-Through Entities should be traded on a secondary market or the
substantial equivalent of a secondary market. Under a "private placement" safe
harbor in the Treasury Regulations, interests in a partnership are not readily
tradable on a secondary market or the substantial equivalent thereof if (i) all
interests in the partnership were issued in a transaction that was not required
to be registered under the Securities Act of 1933, as amended (the "Securities
Act") and (ii) the partnership has no more than 100 partners. Treas. Reg. ss.
1.7704-1(h)(1). For purposes of determining the number of partners in a
partnership, a person (the "beneficial owner") indirectly owning an interest in
the partnership through a partnership, grantor trust or S corporation (the
"flow-through entity") shall be considered a partner, but only if (i)
substantially all of the value of the beneficial owner's interest in the
flow-through entity is attributable to the flow-through entity's interest
(direct or indirect) in the partnership and (ii) a principal purpose of the use
of the tiered arrangement is to satisfy the 100-partner limitation (the
"look-through rule of the Treasury Regulations"). Treas. Reg. ss.
1.7704-1(h)(3). The interests in each of the Pass-Through Entities have been and
will be issued in transactions that are exempt from the registration
requirements of the Securities Act, and therefore the first requirement of the
private placement safe harbor would be satisfied for each of the Pass-Through
Entities. Clause 4.2(e) of the Origination Trust Agreement provides that no
interest in any SUBI, SUBI



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Certificate or SUBI Portfolio shall be transferred, assigned, sold or conveyed
if, as the result of such transfer, assignment, sale or conveyance, the Trust
would become a publicly traded partnership. Sections 10 and 12 of the Raven LLC
Agreement provide, respectively, that a Member may not transfer its interest in
the SPV, and the SPV may not admit any additional member, if such transfer or
admission would cause there to be more than 100 members or otherwise cause the
Trust, the Issuer or the SPV to be classified as a publicly traded partnership
taxable as a corporation. Clauses 9.1(e), 10.1(e) and 12.3(b) of the Chesapeake
LLC Agreement provide, respectively, that the Issuer may not issue any Senior
Preferred Membership Interest or Junior Preferred Membership Interest, and no
transfer of a Preferred Membership Certificate shall be made, if such issuance
or transfer would cause there to be more than 50 members or otherwise cause the
Trust or the Issuer to be classified as a publicly traded partnership taxable as
a corporation. Based on the foregoing, it is our opinion that none of the
Pass-Through Entities will be treated as a publicly traded partnership taxable
as a corporation under Section 7704 of the Code.

         The classification of business entities for New York State income and
franchise tax purposes generally follows the classification for federal income
tax purposes. The New York State Department of Taxation and Finance has advised
that it has been established that the classification of a limited liability
company for New York State tax purposes will follow the classification accorded
the limited liability company for federal income tax purposes. State of New York
Commissioner of Taxation and Finance, Advisory Opinion, July 24, 1996, Petition
No. C960402B. Furthermore, where a business trust is treated as a partnership
rather than an association taxable as a corporation for federal income tax
purposes, such business trust is not considered a corporation for New York State
tax purposes. State of New York Commissioner of Taxation and Finance, Advisory
Opinion, October 14, 1994, Petition No. C940607A. We assume that no election
will be made by any of the Pass-Through Entities, any Trustee, Manager, Member
or any other Person to treat any of the Pass-Through Entities as an association
taxable as a corporation for New York State income or franchise tax purposes.
Based on the foregoing and our assumptions and opinions above that none of the
Pass-Through Entities will be treated as an association or publicly traded
partnership taxable as a corporation for U.S. federal income tax purposes, it is
our opinion that none of the Pass-Through Entities will be treated as an
association taxable as a corporation for New York State income or franchise tax
purposes.

         Our opinions contained herein are limited solely to the question of
whether any of the Pass-Through Entities will be treated as an association or
publicly traded partnership taxable as a corporation for U.S. federal income tax
or New York State income or franchise tax purposes. Except for the opinions set
forth above, we express no opinion herein as to any other tax consequences of
the Pass-Through Entities to any party under U.S. federal, state, local or
foreign laws.

         We are furnishing this opinion to you solely for the benefit of you,
your members and the holders of the Series 2002-1 Investor Notes, and this
opinion may not be used, circulated,



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quoted, or otherwise referred to for any purpose without our express written
consent in each instance.

         We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the reference to our firm under the captions
"Material Federal and Certain State Income Tax Consequences" and "Legal Matters"
therein.

                                                     Very truly yours,




                                                     /s/ WHITE & CASE LLP

JFH:JN:CMO