REIT Ability to Sell Underlying Properties Compared to Single Asset Partnership REIT Structure Form 1099 Tax Filing Ability to sell each individual asset during two-year liquidation plan Single Asset Partnership Structure Multiple Kls Exit each asset through sale of entire partnership with its liabilities 34 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) CONFIDENTIAL DB-SDNY-0071226 SDNY_GM_00217410 EFTA01375670