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ce the Access Fund and its Partners' rights and obligations, or as otherwise may be required by applicable law, rule or regulation. Legal Counsel Cleary Gottlieb Steen & Hamilton LLP ("Cleary Gottlieb") serves as U.S. legal counsel to the General Partner, the Investment Manager and certain of their affiliates. Maples and Calder
es for three years and may carry forward such losses for five years; non-corporate taxpayers may carry forward unused capital losses indefinitely. Tax Treatment of Investments. In general and except as discussed below, the Access Fund expects that its gains will be treated as capital gain for U.S. federal income tax purpo
ce the Access Fund and its Partners' rights and obligations, or as otherwise may be required by applicable law, rule or regulation. Legal Counsel Cleary Gottlieb Steen & Hamilton LLP ("Cleary Gottlieb") serves as U.S. legal counsel to the General Partner, the Investment Manager and certain of their affiliates. Maples and Calder
es for three years and may carry forward such losses for five years; non-corporate taxpayers may carry forward unused capital losses indefinitely. Tax Treatment of Investments. In general and except as discussed below, the Access Fund expects that its gains will be treated as capital gain for U.S. federal income tax purpo
ce the Access Fund and its Partners' rights and obligations, or as otherwise may be required by applicable law, rule or regulation. Legal Counsel Cleary Gottlieb Steen & Hamilton LLP ("Cleary Gottlieb") serves as U.S. legal counsel to the General Partner, the Investment Manager and certain of their affiliates. Maples and Calder
es for three years and may carry forward such losses for five years; non-corporate taxpayers may carry forward unused capital losses indefinitely. Tax Treatment of Investments. In general and except as discussed below, the Access Fund expects that its gains will be treated as capital gain for U.S. federal income tax purpo
ce the Access Fund and its Partners' rights and obligations, or as otherwise may be required by applicable law, rule or regulation. Legal Counsel Cleary Gottlieb Steen & Hamilton LLP ("Cleary Gottlieb") serves as U.S. legal counsel to the General Partner, the Investment Manager and certain of their affiliates. Maples and Calder
es for three years and may carry forward such losses for five years; non-corporate taxpayers may carry forward unused capital losses indefinitely. Tax Treatment of Investments. In general and except as discussed below, the Access Fund expects that its gains will be treated as capital gain for U.S. federal income tax purpo
ce the Access Fund and its Partners' rights and obligations, or as otherwise may be required by applicable law, rule or regulation. Legal Counsel Cleary Gottlieb Steen & Hamilton LLP ("Cleary Gottlieb") serves as U.S. legal counsel to the General Partner, the Investment Manager and certain of their affiliates. Maples and Calder
es for three years and may carry forward such losses for five years; non-corporate taxpayers may carry forward unused capital losses indefinitely. Tax Treatment of Investments. In general and except as discussed below, the Access Fund expects that its gains will be treated as capital gain for U.S. federal income tax purpo
Entities connected to both Cleary Gottlieb Steen & Hamilton LLP and Tax Treatment of Investments

Cayman Islands
LOCATION
Marla Maples
PERSONCalder
ORGANIZATIONGlendower
LOCATIONCleary Gottlieb
ORGANIZATION
United States
LOCATIONGlendower Capital
ORGANIZATION
Bulgaria
LOCATIONKeogh
ORGANIZATIONThe Placement Fee
ORGANIZATIONU.S. Internal Revenue Service
ORGANIZATION
United Kingdom
LOCATIONiCapital
ORGANIZATIONInstitutional Capital Network, Inc.
ORGANIZATIONiCapital Advisors
ORGANIZATIONthe District of Columbia
LOCATION
Puerto Rico
LOCATION
Czech Republic
LOCATION
Malta
LOCATION
Luxembourg
LOCATION