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1 ATTORNEY BIOGRAPHY Eric S. Tresh Partner Atlanta P: E: Education J.D., University of South Carolina School of Law, Associate Editor, South Carolina Environmental Law Review B.A., State University of New York at Stony Brook Bar Admissions New York Georgia Background Eric Tresh represents national and international companies in their state and local tax matters, including planning and policy, controversies and litigation, and mergers and acquisitions. He has represented many of the country s largest companies in state and local tax controversies in administrative and judicial forums throughout the United States and resolved hundreds of non-public record cases. Eric has been recommended as a leading lawyer by Chambers USA, the Legal 500 US and has written extensively in the area of state and local taxation. His articles have appeared in several publications, including State Tax Notes, the Journal of State Taxation Practical U.S./Domestic Tax Strategies, and the Interstate Tax Report. A frequent lecturer on state and local taxes, Eric speaks before such organizations as the Council on State Taxation, the Tax Executives Institute, the Broadband Tax Institute, the State Tax Roundtable for Utilities and Power (STARTUP), the Wireless Tax Group, TeleStrategies, New York University's Institute on State and Local Taxation, Georgetown University Law Center's Advanced State and Local Tax Institute. He has also taught several classes on state and local taxation serving as an adjunct professor of law at Georgia State University and lecturing at the Tax Executive Institute and Counsel on State Taxation s annual schools on state taxation. Experience Sutherland represents major utility in multimillion dollar state income tax refunds. Represents the Florida Cable Telecommunications Association in defending a constitutional challenge to Florida's equalization of cable and satellite taxes. Awards Recognized by Chambers USA: Guide to Leading Business Lawyers in the area of tax ( , ) Recognized by The Legal 500 United States in the area of tax controversy (2011) and U.S. taxes: contentious ( ) Professional Activities General Counsel, Georgia Cable Association

2 PAGE 2 Adjunct Professor, state and local taxation, Georgia State University School of Law and Georgia State University School of Business ( ) Member, Georgia Governor s Mentor-Protégé Program (assisting Georgia businesses in strategic development) Member, Advisory Board for Tax Law and Policy, Stafford Publications Inc. Articles A Pinch of SALT: Primary Confusion: Primary Use Test for State Tax Purposes (February 4, 2014) State Tax Notes A Pinch of SALT: Applying False Claims Acts in State Taxation (May 7, 2012) Reprinted with permission from State Tax Notes A Pinch of SALT: State Audit Guessing Games: When Can States Issue Estimated Assessments? (March 5, 2012) Reprinted with permission from State Tax Notes Be Ready to Pounce on a Texas Margins Tax Challenge (September 9, 2011) Reprinted with permission Practical U.S./Domestic Tax Strategies A Pinch of SALT: Setting the Record Straight Evidentiary Pitfalls in SALT Litigation (August 1, 2011) A Pinch of SALT: The 'Unusual' Application of UDITPA Section 18 (June 7, 2010) A Pinch of SALT: Hard Times and Hired Guns in Local Tax Audits (December 7, 2009) 'Heads You Win, Tails I Lose' - The California Court of Appeal Denies the City of Los Angeles the Opportunity to Skirt Challenges to the City's Telephone Users Tax (December 2009) Reprinted with permission from IPT December Tax Report A Pinch of SALT: Bad Deal on Bad Debt (September 7, 2009) Seeking the Holy Grail Federal Jurisdiction in State Tax Cases (December 1, 2008) State Tax Notes - Tax Analysts Cable Service Providers Comments on MTC Proposed Uniform Regulation for Apportionment of Income From Sales of Telecommunications and Similar Services (August 15, 2005) State Tax Notes The Taxation of Cyberspace (1999) Andersen Publications

3 PAGE 3 The Taxation of the Utility Industry (1999) Andersen Publications Presentations State Tax Controversy Updates (June 23, 2016) TEI Region VIII Meeting The Unusual Suspects: When Third Parties Sue on Behalf of the State (April 26, 2016) 2016 ACC Value Challenge The Next Chapter in Transfer Pricing (April 20, 2016) COST Spring Audit Session/Income Tax Conference Attacks from the Flanks: When Third Parties Sue on Behalf of the State (April 20, 2016) ACC Energy Committee Legal Quick Hit Tax Executives Institute (TEI) 66th Midyear Conference (March 13, March 16, 2016) The Top 10 Transaction Tax Cases of 2016 (February 23, 2016) COST Sales Tax Conference National Update (December 3, 2015) COST Southeast Regional State Tax Seminar Open Internet Order - Tax Impacts and Legal Challenges (September 21, 2015) BTI Annual Conference MTC Task Force & Transfer Pricing Adjustments (July 20, 2015) SEATA Annual Conference Emerging State and Local Tax Issues for Electrics (June 9, 2015) EEI Taxation Committee Meeting State Tax Controversy Update (June 4, 2015) TEI Region VII Annual Conference Alternative Apportionment: Can Two Play That Game? (May 20, 2015) STARTUP Spring Conference A Look Ahead - Forecasting Trends in State Tax Litigation for Communications Companies (May 14, 2015) TeleStrategies Communications Taxation 2015 National State and Local Tax Developments (February 17, 2015) TEI Atlanta

4 PAGE 4 Jurisdiction to Tax (January 27, 2015) COST 2015 SALT Basics School State Tax Cases, Issues and Policy Matters to Watch (December 4, 2014) COST Southeast State Tax Seminar COST Southeast State Tax Seminar (December 4, 2014) State Tax Litigation Update (June 26, 2014) TEI Region VII Annual Conference State Tax Litigation and Legislation Update (June 25, 2014) TEI Fort Worth Chapter Meeting An Assessment of Last Year s Most Significant Litigation and its Impact on Your Balance Sheet (May 15, 2014) TeleStrategies Communications Taxation 2014 State Tax Roundtable - Planning and Techniques (June 26-30, 2013) TEI Region VII Conference Telecommunications Tax Controversies the Good, the Bad and the Ugly (May 21-23, 2013) Telestrategies Communications Taxation 2013 State and Local Tax Watch List (May 16-17, 2013) Media Industry Tax Conference Class Action Lawsuits and False Claims Act Suits: Protecting Your Company (March 17-20, 2013) 63rd TEI Midyear Conference Property Tax Meeting (January 21-23, 2013) Wireless Tax Group 2012 TeleStrategies' Telecommunications Taxation Conference (May 16, 2012) TeleStrategies SALT Roundtable - Houston (May 10, 2012) Sutherland SALT Roundtable Digital Media Sales and Use (May 2, 2012) Media Industry Tax Conference TEI Atlanta Chapter Meeting (March 2, 2012) Tax Executives Institute (TEI) 2012 Council on State Taxation (COST) SALT Basics School (January 22, January 27, 2012) Council on State Taxation

5 PAGE 5 Transfer Pricing - Appropriate Strategies for Utilities (November 2, 2011) Arizona Public Service Company 2011 State Tax Roundtable for Utilities and Power (STARTUP) Broadband Tax Institute 2011 Annual Conference (October 23, October 26, 2011) Broadband Tax Institute (BTI) Wireless Tax Group Meeting - Seattle (September 21, 2011) Wireless Tax Group Send Lawyers, Guns and Money - A Review of This Year's Significant State and Local Tax Controversies and What Telcos Can Do to Fight Back (May 24, May 26, 2011) TeleStrategies' Communication Taxation 2011 Jurisdiction to Tax (November 2, November 3, 2010) STARTUP State Tax Roundtable for Utilities and Power Dangers of Unreliable Intercompany Accounting Issues in State Taxes (October 24, October 27, 2010) Tax Executives Institute 65th Annual Conference Broadband Tax Institute s 2010 Annual Conference (September 19-22, 2010) Managing Protests (July 15, 2010) Tax Executives Institute State & Local Tax Course TeleStrategies Communications Taxation 2010 (May 18, May 19, 2010) Tax Executives Institute s 64th Annual Conference (October 25, October 28, 2009) The Only Thing We Have to Fear is : A State Legislative and Judicial Update (June 10, June 12, 2009) TeleStrategies Communications Taxation 2009 Tax Executives Institute (TEI) National Conference (2009) Council on State Taxation (COST) Southwest/West Regional State Tax Seminar (November 3, 2008) Southwest/West Regional Meeting of the Council on State Taxation (COST) (November 29, 2007) Tax Executives Institute (TEI) Atlanta Chapter (January 10, 2006) Telecommunications (2004) Institute for Professionals in Taxation, Sales and Use Taxation 19th Annual Ohio Tax Conference (January 28-29, 2010) Communications Taxation 2008 Conference (June 3-4, 2008)

6 PAGE 6 Council on State Taxation (COST) 2010 SALT Basics School (January 24-29, 2010) Council on State Taxation (COST) 42nd Annual Meeting (October 18-21, 2011) Institute for Professionals in Taxation (IPT) 34th Annual Conference (June 27-30, 2010) IPT Sales & Use Tax Symposium (September 25-28, 2011) Court Admissions U.S. Court of Appeals for the Second Circuit U.S. Supreme Court