Epstein Secrets

independent counsel has been retained to represent Limited Partners of the Partnership. INDEPENDENT AUDITORS The General Partner has designated Ernst & Young, LLP as the independent auditors of the Partnership. 49905521 -29- EFTA00310650 CERTAIN RISK FACTORS Prospective Limited Partners should carefu

the Partnership and its Limited Partners which should be considered by a prospective Limited Partner. The Partnership has not sought a ruling from the Internal Revenue Service (the "Service") or any other Federal, state or local agency with respect to any of the tax issues affecting the Partnership, nor has it obtained an

New Leaf at the time of the spin- out. Prior to joining Sprout, he spent over seven years in the audit and assurance practices of Arthur Andersen and Ernst & Young in New York, attaining the position of Senior Manager. While at Andersen and Ernst & Young, clientele included various multi-strategy private equity

CONFIDENTIAL HOUSE_OVERSIGHT_024083 X. CERTAIN TAX AND ERISA CONSIDERATIONS IN ACCORDANCE WITH U.S. TREASURY REGULATIONS GOVERNING PRACTICE BEFORE THE INTERNAL REVENUE SERVICE (CIRCULAR 230), LEGAL COUNSEL TO THE FUND HEREBY INFORMS INVESTORS THAT (A) THE INFORMATION BELOW (OR OTHERWISE CONTAINED IN THIS DOCUMENT) IS NOT IN

will not represent any Limited Partner) in connection with the organization of the Fund and the preparation of the Partnership Agreement Auditors Ernst & Young will be the auditor of the Fund. Trident Trust Company (Cayman) Limited will be the Fund Administrator. STRICTLY CONFIDENTIAL 29 EFTA00586885 V

hat, although the Partnership intends to adopt positions it believes are in accord with current interpretations of the U.S. federal income tax laws, the Internal Revenue Service ("IRS") may not agree with the tax positions taken by the Partnership and that, if challenged by the IRS, the Partnership's tax positions might not