olding and disposing of Interests. For purposes of this summary, a "U.S. Holder" is a beneficial owner of an interest in the Onshore Feeder Fund or Offshore Feeder Fund that is, for U.S. federal income tax purposes, a citizen or resident of the United States, a U.S. domestic corporation or otherwise subject to U.S.

olding and disposing of Interests. For purposes of this summary, a "U.S. Holder" is a beneficial owner of an interest in the Onshore Feeder Fund or Offshore Feeder Fund that is, for U.S. federal income tax purposes, a citizen or resident of the United States, a U.S. domestic corporation or otherwise subject to U.S.

n & Hamilton LLP or Stuarts Walker Hersant and any other person solely by virtue of such person making an investment in the Onshore Feeder Fund or Offshore Feeder Fund. 33 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0108728 CONFIDENTIAL SONY GM_00254912 EFTA01451885

Feeder Fund or the interests of the investors therein. The Cayman Islands currently imposes annual fees on certain entities. At current rates the Offshore Feeder Fund expects to pay an annual fee as an exempted limited partnership of approximately US$1,220 per annum and the General Partner of the Onshore Feeder Fu