THE CHARITABLE TRUST WAS ORGANIZED AND IS OPERATED EXCLUSIVELY FOR THE BENEFIT OF THREE NAMED CHARITIES. THESE CHARITIES ARE: SISTERS OF MERCY OF THE AMERICAS SOUTH CENTRAL COMMUNITY, INC., THE DISCALCED CARMELITE NUNS, AND THE ALLEN MEMORIAL HOME. ALL THREE OF THESE CHARITIES ARE EXEMPT FROM FEDERAL INCOME TAX UNDER SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE.