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Securities Trading Policy

Board of Directors

William J. Turner
Co-Manager
Signature Capital, Inc.
New York, NY
and Chairman & Chief Executive Officer
Turner & Partners, Inc.
New York, NY

An explanation of the transaction codes used in the reports posted below.

Initial Statement Statement of Changes
April 26, 2002 May 02, 2002
May 10, 2002
March 31, 2004
November 4, 2004
July 15, 2005

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