Contract analysis

Section 1. Identification of Grantor and Trust The following identifying information is provided for reference purposes in connection with the contribution described in this Schedule A: Grantor: Jonathan Robert Caldwell, an individual residing at 418 East 72nd Street, Apt. 14A, New York, New York 10021 (Social Security Number: XXX-XX-4781). Trust: Caldwell 2023 Carried Interest GRAT, an irrevocable grantor retained a

Section 2. Description of Contributed Property The Grantor has contributed the following limited partnership interests and carried-interest position to the Trust as of the date set forth above. Each interest is described in detail below. The Grantor has transferred all right, title, and interest in and to each of the following described interests, effective as of June 1, 2023, to the Trustee to be held, administered,

Section 3. Summary Valuation Table The following table consolidates the fair market value determinations for all contributed interests constituting the initial trust corpus of the Trust: The blended post-discount fair market value of $25,300,000 is computed as follows: the aggregate discounted value of the limited partnership interests is ($12,000,000 + $14,000,000) × 0.65 = $16,900,000, plus the discounted value of

Section 4. Valuation and Appraisal Information All fair market value determinations set forth in this Schedule A have been made as of June 1, 2023, the date of contribution, in accordance with the standard of fair market value under Section 2512 of the Code and the applicable Treasury Regulations promulgated thereunder. For purposes of this Schedule A, "fair market value" means the price at which the property would c

Section 5. Discount Methodology Summary The valuation discounts applied to the contributed interests are summarized below and are supported in full by the detailed analysis contained in the Ashford Valuation Group LLC appraisal reports referenced in Section 4 above. LP Interests (Fund IV and Fund V). The 35% combined discount applied to the limited partnership interests in Caldwell Ridgeline Fund IV LP and Caldwell R

Section 6. Transfer Restrictions and Consents The Grantor hereby represents and warrants that he has reviewed and complied with all applicable transfer restriction provisions contained in the governing limited partnership agreements for each of Caldwell Ridgeline Fund IV LP, Caldwell Ridgeline Fund V LP, and Caldwell Ridgeline Fund VI LP, and has obtained or is in the process of obtaining all necessary consents, appr

Section 7. Annuity Calculation Reference The contributed property described in this Schedule A constitutes the entire initial trust corpus for purposes of computing the annuity amount payable to the Grantor under Article III of the Trust Agreement. The annuity amount has been determined based on the aggregate post-discount fair market value of the contributed property of $25,300,000, as set forth in Section 3 above.

Section 8. Remainder Beneficiary Upon termination of the annuity term and full and complete satisfaction of all annuity payments due to the Grantor (or the Grantor's estate, as applicable) under the Trust Agreement, the remainder of the Trust property, including all appreciation, accumulated income, and undistributed assets, shall be distributed to the Caldwell Family Dynasty Trust, an irrevocable trust established u