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EFTA01374099
tnership may, however, avail 'itself of a "de minimis" exemption pursuant to which a portion of any New Issue profits and losses may be allocated to Restricted Persons and/or Covered Investors. The Partnership Agreement provides that the General Partner is authorized to determine, among other things: (i) the manner in which New Issues are
EFTA01386185
tnership may, however, avail 'itself of a "de minimis" exemption pursuant to which a portion of any New Issue profits and losses may be allocated to Restricted Persons and/or Covered Investors. The Partnership Agreement provides that the General Partner is authorized to determine, among other things: (i) the manner in which New Issues are

Paul Barrett
PersonAmerican investment banker and fund manager, founder of Alpha Group Capital, former JPMorgan private banker who managed Jeffrey Epstein's assets (2017-2019)
the "FINRA Rules
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