Epstein Secrets

05511 -49- EFTA00310670 Qualified Retirement Plans. Employee benefit plans subject to the provisions of ERISA, Individual Retirement Accounts and Keogh Plans should consult their counsel as to the implications of such an investment under ERISA. (See "ERISA Considerations.") Endowment Funds. Investm

o report on its own annual tax return such Limited Partner's distributive share of the Partnership's taxable income or loss. (See "Tax Aspects.") Schulte Roth & Zabel LLP, 919 Third Avenue, New York, New York 10022, acts as legal counsel to the Partnership in connection with the offering of the Interests and with re

r affiliates. In connection with the offering and ongoing advice to the Partnership, Schulte Roth & Zabel LLP does not represent Limited Partners. Schulte Roth & Zabel LLP will not be representing Limited Partners of the Partnership. No independent counsel has been retained to represent Limited Partners of the Partn

611 et seq. of the Internal Revenue Code; (iv) amounts contributed to an Individual Retirement Account (as defined in the Internal Revenue Code) or Keogh retirement plan: (v) alimony paid; and (vi) any elective contributions to a cash or deferred arrangement under Section 401(k) of the Internal Revenu

ion 2(a)(51)(C) of the Company Act and the rules promulgated thereunder. DOC ID - 26358443.8 3 EFTA00803562 (K) The Investor acknowledges that Schulte Roth & Zabel LLP ("SRZ") has been engaged by the General Partner and the Manager to represent them and the Partnership as U.S. legal counsel in connection with the

611 et seq. of the Internal Revenue Code; (iv) amounts contributed to an Individual Retirement Account (as defined in the Internal Revenue Code) or Keogh retirement plan: (v) alimony paid; and (vi) any elective contributions to a cash or deferred arrangement under Section 401(k) of the Internal Revenu

ion 2(a)(51)(C) of the Company Act and the rules promulgated thereunder. DOC ID - 26358443.8 3 EFTA00604470 (K) The Investor acknowledges that Schulte Roth & Zabel LLP ("SRZ") has been engaged by the General Partner and the Manager to represent them and the Partnership as U.S. legal counsel in connection with the

ir net investment income. Qualified Retirement Plans. Employee benefit plans subject to the provisions of ERISA, Individual Retirement Accounts and Keogh Plans should consult their counsel as to the implications of such an investment under ERISA and the Code. (See "ERISA Considerations.") Endowment F

perations Classification of Millennium USA and the Master Partnership. Each of Millennium USA and the Master Partnership has received an opinion of Schulte Roth & Zabel LLP, its counsel, that under the provisions of the Code and the Regulations, as in effect on the date of the opinion, as well as under the relevant aut

Plan Investor" (as defined in the Plan Assets Rules and described below and including, without limitation, an individual retirement account and a "Keogh" plan) who has investment discretion (a "Fiduciary") should consider before deciding to invest such Benefit Plan Investor's assets in the Alpha Key

Administrator also provides services in connection with the issuance, transfer and withdrawal of interests. (See "The Administrator.") Taxation: Schulte Roth & Zabel LLP has rendered an opinion that Millennium USA and the Master Partnership will each be classified as a partnership and not as an association taxable a

Plan Investor" (as defined in the Plan Assets Rules and described below and including, without limitation, an individual retirement account and a "Keogh" plan) who has investment discretion (a "Fiduciary") should consider before deciding to invest such Benefit Plan Investor's assets in the Alpha Key

Administrator also provides services in connection with the issuance, transfer and withdrawal of interests. (See "The Administrator.") Taxation: Schulte Roth & Zabel LLP has rendered an opinion that Millennium USA and the Master Partnership will each be classified as a partnership and not as an association taxable a