A California Nonprofit Public Benefit Corporation 501(c)(3)
(the "Foundation") (Federal Tax ID: 55 0794474)


The Tax Status Of The Joyful Child Foundation -
In Memory Of Samantha Runnion

Under date of October 25, 2002 the Internal Revenue Service determined that The Joyful Child Foundation - In Memory Of Samantha Runnion is exempt from federal income tax under Section 501(a) of the Internal Revenue Code of 1986, as amended (the "Code") as an organization described in Section 501(c)(3) of the Code. Accordingly, contributions to The Joyful Child Foundation - In Memory Of Samantha Runnion, which may be in the form of cash, checks, securities, books, works of art, other personal property, real property, gifts in kind (e.g., office space), et cetera, are deductible for United States of America income tax purposes as is provided for in Section 170 of the Code. In addition, bequests, legacies, devises, transfers, and gifts to or for the benefit of The Joyful Child Foundation - In Memory Of Samantha Runnion are deductible for estate and gift tax purposes if such meet the applicable provisions of Sections 2055, 2106, and 2522 of the Code.

Under date of November 5, 2002 the Franchise Tax Board of the State of California determined that The Joyful Child Foundation - In Memory Of Samantha Runnion is exempt from state franchise or income tax under Section 23701 of the Revenue and Taxation Code of the State of California.

The Nature Of The Foundation:
The Foundation is a nonprofit public benefit corporation formed and organized under the Nonprofit Public Benefit Corporation Law of the State of California (Sections 5110 et seq. of the Corporations Code of the State of California).

Disposition Of Contributions To The Foundation:
The Board of Directors of the Foundation has complete discretion in the disposition of contributions received that were not directed to a specific purpose.