Epstein Secrets

at, 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 STRICTLY CONFIDENTIAL 54 DRAFT - Jeffery Epstein EFTA00617693 positions taken by the Partnership and that, i

ners, and there is a potential for additional conflicts of interest between the Fund and such co-investors since they may have diverging interests. Long-Term Investment An investment in the Fund requires a long-term commitment. The Fund may choose to hold its investments for longer than the anticipated five (5)- to

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

cation of investment opportunities by the General Partner will not give rise to conflicts of interest between the investors of the respective funds. Long-Term Investment An investment in the Fund is a long-term commitment, and there is no assurance of any distribution to the Limited Partners prior to or upon liquidati

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

the Fund's Partnership Agreement could be disruptive to the smooth operation of the Fund or otherwise frustrate the expectations of the Partners. Long-Term Investment An investment in the Fund is a long-term commitment and there is no assurance of any distribution to the Limited Partners. Limited Transferability