This is a summary of the Business Continuity Plan (the "Plan") of Newforth Partners LLC (hereafter the "Company"). The Plan is designed to address a significant business disruption affecting the Company's business operations conducted at its San Mateo location and sets forth the Company's objectives of safeguarding employees, recovering and resuming operations, protecting books and records, and enabling communications with employees, investors, key service providers, and regulators. The Company is headquartered in San Mateo and all of its mission critical systems and processes are conducted or located in Virginia.

The Plan addresses both disruptions that may be caused by a local incident such as a fire in the Company's headquarters building at 101 S. Ellsworth Avenue, Suite 201 in San Mateo or by a regional or market-related disruption that applies to many companies. The Plan covers the Company's Critical Business Processes and related employees that are essential for the Company to continue to conduct business for an interim or temporary period during a business interruption. The Company's goal is to recover its Critical Business Processes with minimal interruption, on the same day, if possible, depending on the nature of the disruption.

The steps being taken pursuant to the Plan are designed to ensure that critical information is captured on a daily basis in a manner that can be accessed by employees from alternate locations. The Plan also provides that the Company will maintain contacts with regulators during any business interruption and continue to make any necessary regulatory filings.

The Company's Information Technology operations form a critical part of the Company's business and each of its Critical Business Processes. The Plan includes a IT Contingency Plan which identifies the functions, operations and resources necessary to support the restoration and resumption of business processes performed by the Company's San Mateo location.

This summary plan is subject to modification from time to time as the Company reviews the Plan and its business operations. Clients may alternatively obtain a written copy of this summary plan by contacting Newforth Partners LLC at 101 S. Ellsworth Avenue, Suite 201 in San Mateo, CA 94401

In conclusion, the Company's Plan addresses the steps the Company will take to address a temporary business disruption in a systematic and organized fashion. Of course, the effects of a disaster are difficult to predict and the disruption of systems and processes on an industry wide basis will pose great challenges for any business continuity plan. There can be no assurance that any plan can address such unforeseen contingencies.