EXHIBIT 8.1

                         LETTERHEAD of WHITE & CASE LLP

March 7, 2003

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 statutory 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-3 and S-1 (the "Registration Statement") filed by the
Issuer and the Trust with the Securities and Exchange Commission under the
Securities Act of 1933, as amended (the "Securities Act"), for the registration
of $500,000,000 principal amount of the Issuer's Series 2003-1 Floating Rate
Callable Asset Backed Notes (the "Series 2003-1 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").
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Chesapeake Funding LLC
Page 2

     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 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.
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Chesapeake Funding LLC
Page 3

     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 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 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,
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Chesapeake Funding LLC
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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
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.
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Chesapeake Funding LLC
Page 5

     We are furnishing this opinion to you solely for the benefit of you, your
members and the holders of the Series 2003-1 Investor Notes, and this opinion
may not be used, circulated, 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