EFTA01384947Set 10
2012-12-311p783w
REIT does not guarantee our ability to qualify as a
Our tax counsel, Goodwin Procter LLP, has rendered an opinion to us to the effect that
(i) commencing with ... shares and our prior and intended or expected manner of operation. Goodwin
Procter LLP has not verified and will not verify those representations, and their opinion assumes that
such representations ... share ownership, the various qualification tests imposed
under the Code discussed below. Goodwin Procter LLP has not reviewed and will not review our
compliance with these tests on a continuing
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01384947.pdf
EFTA01384993Set 10
2012-12-311p748w
connection with this offering, we have received an opinion of our tax counsel, Goodwin
Procter LLP, to the effect that (i) commencing with our taxable year ended December ... shares
and our prior and intended and expected manner of operation. Goodwin Procter LLP has not verified
and will not verify those representations, and their opinion assumes that such representations ... share ownership and
various other qualification tests imposed under the Code discussed below. Goodwin Procter LLP has
not reviewed and will not review our compliance with these tests
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01384993.pdf
EFTA00587845Set 9
2013-09-2310p5,227w
GOODWIN I PROCTER
MEMORANDUM
To Private Investment Fund Clients
From Goodwin Procter LLP
Re Pitfalls in Conducting a Private Placement
Date September 23, 2013
Preparation and planning (especially with regard ... should not
be regarded as legal advice. For more information, please contact your Goodwin Procter LLP attorney.
8
LIBC/3630167.24
EFTA00587852
GOODW IN ',ROOTER
PRIVATE PLACEMENT PITFALLS
1. Involving "Bad Actors
https://www.justice.gov/epstein/files/DataSet%209/EFTA00587845.pdf
EFTA00587007Set 9
2014-03-122p241w
OFFICER'S CERTIFICATE
STATE NIENT FOR THIRD PARTY DESIGNEE
March 12, 2014
To: Goodwin Procter LLP
901 New York Avenue, N.W.
Washington, DC 20001
The undersigned, being the duly authorized ... Form SS-4,
which executed form is attached hereto as Exhibit A.
2. Goodwin Procter LLP is hereby authorized as the Company's third party designee
("Designee") to apply
https://www.justice.gov/epstein/files/DataSet%209/EFTA00587007.pdf
EFTA01930994Set 10
2014-04-030p739w
review it.
Thank you.
PN
EFTA_R1_00381880
EFTA01930995
Paul J. Verbesey
Goodwin Procter LLP
901 New York Avenue, N.W.
Washington, D.C. 20001
T:
F:
www.goodwinprocter.com
From: Preysman, Daniel ... look forward to discussing further with you.
Best,
Daniel
Daniel B. Preysman
Goodwin Procter LLP
Exchange Place
53 State Street
Boston, MA 02109
T:
www.000dwinprocter.com
IRS CIRCULAR 230 DISCLOSURE
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01930994.pdf
EFTA01143367Set 9
2012-09-1051p8,591w
shall have furnished to the
Investors and the Founders, with a copy to Goodwin Procter LLP, Exchange Place,
Boston, MA 02109, Attn: Kingsley L. Taft, Esq., facsimile
https://www.justice.gov/epstein/files/DataSet%209/EFTA01143367.pdf
EFTA01143418Set 9
2012-09-1056p15,098w
Company shall have furnished to the Investors, with a copy to
Goodwin Procter LLP, Exchange Place, Boston, MA 02109, Attn: Kingsley L. Taft, Esq.,
facsimile: (617) 523-1231.
Each such
https://www.justice.gov/epstein/files/DataSet%209/EFTA01143418.pdf
EFTA01143255Set 9
2012-09-1050p8,579w
shall have furnished to the Investors, with a copy to Kingsley Taft,
Esq., Goodwin Procter LLP, 53 State Street, Boston, MA 02109, facsimile: (617) 523-1231.
9
EFTA01143265
(d) Each
https://www.justice.gov/epstein/files/DataSet%209/EFTA01143255.pdf