Contract analysis

I. Introduction Calderwood & Harkness LLP has acted as counsel to Redstone Gaming Corp., a Delaware corporation ("RGC" or the "Company"), in connection with the Company's registered public offering of 6,557,377 shares of common stock, par value $0.001 per share (the "Common Stock"), with a 15% over-allotment option granted to the underwriters covering up to 983,606 additional shares, for a maximum aggregate offering

II. Documents and Materials Reviewed In connection with rendering this opinion, we have examined originals, or copies certified or otherwise identified to our satisfaction, of the following documents and materials:

1. The Registration Statement on Form S-3 (File No. 333-278401), as originally filed with the SEC on March 14, 2024, including all exhibits thereto and all amendments and supplements filed through the date hereof;

2. The Prospectus Supplement (in the form of the most recent draft provided to us, dated October 25, 2025, and expected to be filed with the SEC pursuant to Rule 424(b)(5) on or about the date hereof), including the Tax Disclosure set forth therein;

3. The base prospectus dated March 28, 2024, forming a part of the Registration Statement;

4. The Company's Annual Report on Form 10-K for the fiscal year ended December 31, 2024, as filed with the SEC on February 28, 2025, and as subsequently amended by the Company's Form 10-K/A filed with the SEC on July 15, 2025;

5. The Company's Certificate of Incorporation, as amended and restated (Delaware Charter File No. 7291845), together with all certificates of amendment and certificates of designation filed therewith;

6. Resolutions of the Board of Directors of the Company adopted on September 30, 2025, authorizing the Offering and related transactions, as certified to us by the Secretary of the Company;

7. The underwriting agreement (the "Underwriting Agreement"), in the form of the most recent draft provided to us, among the Company and Pinnacle Zanthor & Co., Hargrove Williams Securities LLC, and Clearwater Capital Markets Inc., as representatives of the several underwriters named therein (collectively, the "Underwriters");

8. Officer's certificates of Marcus Hale, Chief Executive Officer, and Lena Okafor, Chief Financial Officer, of the Company, each dated on or about the date hereof, containing certain factual representations and statements relevant to the opinions expressed herein, including representations regarding the Company's operations, assets, capitalization, earnings and profits, and status as a United States real property ho

9. The Company's Quarterly Reports on Form 10-Q for the quarters ended March 31, 2025, and June 30, 2025, respectively;

10. The Company's Current Reports on Form 8-K filed during the twelve-month period preceding the date hereof; and

11. Such other documents, records, certificates, instruments, and matters of law as we have deemed necessary or advisable for purposes of rendering this opinion. We have not independently verified the accuracy or completeness of the factual matters set forth in the documents listed above or otherwise brought to our attention in connection with this engagement, and we have relied upon such documents and the factual re

III. Assumptions For purposes of this opinion, we have assumed, with the Company's consent, the following:

1. The Offering will be consummated in all material respects in accordance with the terms and conditions described in the Prospectus Supplement and the Underwriting Agreement, without waiver or modification of any material provision thereof, and that all conditions to closing set forth therein will be satisfied or duly waived.

2. The accuracy and completeness of all factual representations, warranties, and statements made to us by the Company and its officers, directors, and employees, whether contained in the officer's certificates, the Registration Statement, the Prospectus Supplement, or otherwise communicated to us, including without limitation all information regarding the Company's operations, assets, liabilities, capitalization, ear

3. The Company has been, is, and will continue to be classified as a corporation for U.S. federal income tax purposes within the meaning of Section 7701(a)(3) of the Internal Revenue Code of 1986, as amended (the "Code"), and the Treasury regulations promulgated thereunder, and is not and will not become classified as a passive foreign investment company within the meaning of Section 1297 of the Code, a personal hold

4. The shares of Common Stock to be issued and sold in the Offering constitute equity for U.S. federal income tax purposes and are not and will not be treated as indebtedness, a partnership interest, or any instrument other than stock of a domestic corporation for such purposes.

5. There will be no change in applicable law — whether statutory, judicial, or administrative — from the date hereof through and including the closing date of the Offering that would affect the conclusions stated in this opinion, and that all applicable provisions of the Code, the Treasury regulations, published rulings and administrative pronouncements of the Internal Revenue Service (the "IRS"), and reported judici

6. That the Company's employer identification number is 88-1034572, that the Company is duly incorporated and validly existing under the laws of the State of Delaware, that the Company's principal executive offices are located in Las Vegas, Nevada, and that all filings and registrations required to be made by the Company with respect to the matters discussed herein have been duly and timely made.

7. All documents submitted to us as originals are authentic, complete, and accurate; all documents submitted to us as copies conform to the originals thereof; all signatures on such documents are genuine; and all natural persons who have executed any such documents have had the legal capacity to do so.

8. Each party to the Underwriting Agreement and each other agreement relevant to the Offering has complied and will comply in all material respects with all of its obligations under such agreements.

IV. Scope of Opinion This opinion addresses only the material U.S. federal income tax consequences of the acquisition, ownership, and disposition of shares of Common Stock acquired by holders in the Offering, as such consequences are described in the Tax Disclosure contained in the Prospectus Supplement. Specifically, this opinion covers the Tax Disclosure as it pertains to the U.S. federal income tax treatment of bo

V. Opinion A. General Statement Based upon and subject to the foregoing, and subject to the qualifications, limitations, assumptions, and caveats set forth in this opinion letter and in the Tax Disclosure itself, it is our opinion that the Tax Disclosure, as set forth in the Prospectus Supplement under the heading "Material U.S. Federal Income Tax Considerations," constitutes, in all material respects, an accurate an

VI. Qualifications and Limitations The opinion set forth herein is subject to the following qualifications and limitations:

1. Change in Law. This opinion is based upon the Code, Treasury regulations (including final, temporary, and proposed regulations), published rulings and administrative pronouncements of the IRS, and reported judicial decisions, in each case as in effect and available on the date hereof. The statutory, regulatory, and judicial authorities upon which this opinion is based are subject to change at any time, which chang

2. Non-Binding Nature. This opinion represents our legal judgment based on existing authorities and is not binding on the IRS or any court. No assurance can be given that the IRS will not take a position contrary to one or more of the conclusions stated herein, or that such a contrary position would not be sustained by a court upon judicial review. We note that the Tax Disclosure contains appropriate cautionary langu

3. No IRS Ruling. No ruling has been requested from, or issued by, the IRS with respect to any of the tax matters addressed in this opinion or in the Tax Disclosure, and no such ruling will be sought. The receipt of a private letter ruling from the IRS could provide greater certainty regarding one or more of the tax consequences described in the Tax Disclosure, but we have not been asked to, and have not, sought any

4. Limited Scope. This opinion is limited in its scope to the specific U.S. federal income tax matters discussed in the Tax Disclosure and does not address any other U.S. federal, state, local, or non-U.S. tax consequences of the Offering, the ownership of shares of Common Stock, or any other transaction or arrangement involving the Company or any holder of Common Stock.

5. Reliance on Factual Representations. Our opinion is expressly conditioned upon, and subject to, the accuracy of all factual representations made to us by the Company, its officers, and its agents, including, without limitation, those representations set forth in the officer's certificates provided by Marcus Hale, Chief Executive Officer, and Lena Okafor, Chief Financial Officer, of the Company. We have not indepen

6. Excluded Holders and Matters. No opinion is expressed herein regarding the tax treatment of holders that are subject to special rules under the Code, as described in Section IV above, or regarding any state, local, or non-U.S. tax consequences of the acquisition, ownership, or disposition of shares of Common Stock. 7. "More Likely Than Not" Standard. Unless otherwise specifically indicated in this opinion, each st

VII. Reliance and Use This opinion is rendered solely for the benefit of Redstone Gaming Corp. in connection with the Offering described herein and in the Prospectus Supplement. This opinion is not intended to, and may not, be relied upon by any other person or entity, or for any purpose other than as described herein, without our prior written consent. We hereby consent to the filing of this opinion as an exhibit to