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Disclosure Controls and Procedures (October 2002)

10.21.02
This memorandum, regarding disclosure controls and procedures, supplements the Firm's memoranda dated September 6, 2002 entitled "SEC Adopts New CEO / CFO Certifications, Corporate Responsibility and Accounting Reform", dated August 8, 2002 entitled "Sarbanes-Oxley Act of 2002: Supplemental Memorandum No. 1" and dated August 9, 2002 entitled "Sarbanes-Oxley Act of 2002 Supplemental Memorandum No. 3 - Registered Investment Companies.