EFTA01386105

AGP LP 519 Alpha Group Capital Paul Barren RAYMOND JAM S`° September 20, 2013 Re: Disclosures by Compensated Solicitors Under Rule 506(d) of Regulation D under the Securities Mt of 1933, as amended Dear Issuer: Raymond James & Associates, Inc. and Raymond James Financial Services, Inc. (collectively "Solicitors"), confirm that other than as described on Schedule A attached to this letter, they are unaware of any matters that would subject them or any of the persons associated with Solicitors to any of the disqualifying events specified in Section 506(d) of Regulation O, as adopted effective September 23, 2013, under the Securities Act of 1933, as amended, (the "Bad Actor Provisions"). Solicitors agree to inform you promptly should any additional disqualifying events specified in the Bad Actor Provisions apply to Solicitors or any directors, executive officers or any other officers participating in the offerings of the Issuer as specified in the Bad Actor Provisions. RAYMOND JAMES & ASSOCIATES, INC. RAYMOND JAMES FINANCIAL SERVICES, INC. aP &ALL" — ark P. Barracca Vice President Managing Attorney .• 660 Carillon Parkway Si Peiciaburg. FL 33716 J7T 800.2113.9863 raymoadiames Com Wilieea Direct Deal 727 567 5179 U Far 5641.205.1639i/ Cram]: Mark.BarraccartgRawnontUantes cam nay,. ..... MoetImet.Inc outman/ Nen Yort etaa lowisounSOC CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) CONFIDENTIAL DB-SDNY-0087652 SDNY GM_00233836 EFTA01386105