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THE WITHIN IS FOR DISCUSSION PURPOSES ONLY, MAY NOT BE USED IN CONNECTION WITH LITIGATION OR BANKRUPTCY PROCEEDINGS, AND IS WITHOUT PREJUDICE TO THE RIGHTS AND REMEDIES OF OUR CLIENT, ALL OF WHICH ARE HEREIN EXPRESSLY RESERVED DISCLOSURE UNDER TREASURY CIRCULAR 230: The United States Federal tax advice, if any, contained in this document and its attachments may not be used or referred to in the promoting, marketing or recommending of any entity, investment plan or arrangement, nor is such advice intended or written to be used, and may not be used, by a taxpayer for the purpose of avoiding Federal tax penalties.

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