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`IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
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`C.A. No. 9685‒VCL
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`IMO Daniel Kloiber Dynasty Trust
`U/A/D December 20, 2002
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`QUARTERLY DISCLOSURE OF TRUST’S LIQUID
`AND “NON-SPECIAL HOLDING” ASSETS
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`Pursuant to the Stipulation and Proposed Order Regarding Disclosure of
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`Trust Information entered on January 8, 2015 (the “Disclosure Order”), the Special
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`Trustee hereby files as Exhibit A the Summary (as defined in the Disclosure Order)
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`for the quarter ended December 31, 2014. Attached as Exhibit B hereto is a
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`compilation of the account statements stating the account values listed in the
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`Summary, which were provided by PNC Delaware Trust Company (“PNC”),
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`Trustee of the Daniel Kloiber Dynasty Trust (the “Trust”), and Dean Dornton
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`Allen & Ford PLLC, accountant for the Trust’s affiliates (“DDAF”).
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`The Special Trustee and his Delaware counsel have relied without
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`independent verification on information provided by PNC; DDAF; David Kloiber,
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`manager of Kloiber Management Services, LLC, which serves as manager of
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`certain entities wholly or partially owned by the Trust; and Daniel Kloiber’s
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`Delaware counsel—all of whom have reviewed and approved this disclosure and
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`Exhibit A attached hereto.
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`The Summary generally presents values for the “Non-Special Holdings” of
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`the Trust, as that term is used in the divorce proceeding before the Kentucky
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`{A&B-00335100}
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`EFiled: Feb 25 2015 01:10PM EST
`Transaction ID 56826038
`Case No. 9685-VCL
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`Fayette Family Circuit Court, Fifth Division (“Kentucky Family Court”) and
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`generally in the form disclosures of such “Non-Special Holdings” previously were
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`made in that proceeding. The category of “pledged assets” in the Summary was
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`not used in the disclosures of the Trust’s “Non-Special Holdings” in the Kentucky
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`divorce proceeding but received attention in connection with the compilation filed
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`on December 12, 2014 in the Kentucky Family Court by David Kloiber (the
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`“Compilation”). The Special Trustee and his Delaware counsel understand that the
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`Summary line item “Liquid & Brokerage Assets Pledged as Collateral” was
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`derived using the same methodology to identify “pledged assets” in the
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`Compilation. However, the Compilation accounted for only those pledged assets
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`tied to the “liquid assets” (as that term was defined in the Compilation) of Kloiber
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`Holdings, LLC, while the attached Summary accounts for pledged assets
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`associated with the broader universe of brokerage assets, even if those assets were
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`not “liquid assets” within the meaning of the Compilation.
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`Dated: February 25, 2015
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`{A&B-00335100}
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`2
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`/s/ Kevin G. Abrams
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`Kevin G. Abrams (#2375)
`J. Peter Shindel, Jr. (#5825)
`Matthew L. Miller (#5837)
`ABRAMS & BAYLISS LLP
`20 Montchanin Road, Suite 200
`Wilmington, Delaware 19807
`(302) 778-1000
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`Attorneys for the Special Trustee
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