The Fund has been formed to invest in a diversified portfolio of real estate properties, real estate-related equity investments and other real estate-related assets, each of which the Managing Member believes are compelling from a risk-return perspective. The Fund is offering two separate classes of limited liability company units in accordance with the terms set forth herein. The Fund will be operated by the Managing Member in a manner intended to comply with the Opportunity Zone Provisions (and any corresponding regulations and guidance).