Epstein Secrets

AGP LP 519 Alpha Group Capital Paul Barrett 14. ERISA AND RETIREMENT PLAN MATTERS The following is a summary of certain aspects of laws and regulations applicable to retirement plan investme

e indirect compensation' on Schedule C of Form 5500. The above statements are based on advice received by the Partnership as to ERISA matters from Seward & Kissel LLP, New York, New York. CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0068652 CONFIDENTIAL SDNY_GM_00214836 EFTA01374113

AGP LP 519 Alpha Group Capital Paul Barrett Partnership will not hold "plan assets" subject to Title I of ERISA or Section 4975 of the Code (i.e., less than 25% of each class of the Partnersh

Memorandum under the heading "Risk Factors - No Separate Counsel; No Responsibility or Independent Verification" and specifically acknowledges that Seward & Kissel LLP is not responsible for any acts or omissions of the Partnership, the General Partner, the Investment Manager or any administrator, accountant, cust

AGP LP 519 Alpha Group Capital Paul Barrett 12. ADMINISTRATOR The Partnership has entered into an agreement (the "Administration Agreement") with The Bank of New York Mellon, a corporation o

State of New York without regard to principles of conflict of law. 13. TAXATION Federal Taxation The Partnership has been advised by its counsel, Seward & Kissel LLP, that, under present law, the Partnership will be treated as a partnership and will not be a taxable entity for Federal income tax purposes. Instea

AGP LP 519 Alpha Group Capital Paul Barrett 14. ERISA AND RETIREMENT PLAN MATTERS The following is a summary of certain aspects of laws and regulations applicable to retirement plan investme

e indirect compensation' on Schedule C of Form 5500. The above statements are based on advice received by the Partnership as to ERISA matters from Seward & Kissel LLP, New York, New York. CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0087790 CONFIDENTIAL SDNY_GM_00233974 EFTA01386204

AGP LP 519 Alpha Group Capital Paul Barrett Cayman Islands Taxation The Master Fund has been advised by its Cayman Islands counsel, Ogier, that neither the Partnership nor the Master Fund wi

their interest in the Partnership nor will they be subject to any estate duty or inheritance taxes in the Cayman Islands. General The advice from Seward & Kissel LLP on Federal, New York State and New York City tax matters is based on the assumption that the Partnership will be organized and operated in the manne