WELLS FARGO
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            Wells
      Fargo
              Commercial Mortgage
              34100 Woodward Avenue, Suite 300
              Birmingham, MI 48009-0920
              248 723-3101
              248 723-3135 Fax






Management’s
Assessment
 
 
 Management
of the Commercial Mortgage Servicing Group (“CMS”), a division of Wells Fargo
Bank, N.A. (the “Company”), is responsible for assessing compliance, as of and
for the year ended December 31, 2008, with the servicing criteria set forth in
Item 1122(d) of Regulation AB of the Securities and Exchange Commission (“SEC”)
relating to the servicing of commercial mortgage loans (excluding any loans
serviced by Wells Fargo Multifamily Capital Group, a subdivision of CMS) (the
“Platform”), except for the servicing criteria set forth in subparagraphs
(d)(1)(iii), (d)(3)(i)(B-D), (d)(3)(ii-iv), (d)(4)(ii), and (d)(4)(xv), which
the Company has determined are not applicable to the servicing activities it
performs with respect to the Platform.
 
 With
respect to servicing criterion 1122(d)(3)(i)(A), the Company has engaged various
vendors to perform certain activities covered by this servicing criterion. The
Company has determined that none of these vendors is a “servicer” as defined in
Item 1101(j) of Regulation AB, and the Company’s management has elected to take
responsibility for assessing compliance with this servicing criterion to the
extent it applies to these vendors as permitted by Interpretation 17.06 of the
SEC Division of Corporation Finance Manual of Publicly Available Telephone
Interpretations (“Interpretation 17.06”).  As permitted by Interpretation
17.06, management has policies and procedures in place designed to provide
reasonable assurance that such vendors’ activities comply in all material
respects with servicing criterion 1122(d)(3)(i)(A) to the extent it applies. The
Company’s management is solely responsible for determining that it meets the SEC
requirements to apply Interpretation 17.06 for these vendors and servicing
criterion 1122(d)(3)(i)(A).
 
 The
Company’s management has assessed the Company’s compliance with the applicable
servicing criteria using the criteria set forth by the SEC in paragraph (d) of
Item 1122 of Regulation AB.  Based on such assessment, management
believes that, as of and for the year ended December 31, 2008, the Company has
complied in all material respects with the applicable servicing criteria except
as follows:
  Our
assessment of compliance disclosed the following material noncompliance with
servicing criterion 1122(d)(4)(i):
 
 With
respect to certain commercial mortgage loans, the Company either (i) made
disbursements to the applicable obligor from reserve accounts that the obligor
had no right to receive under the pool asset documents or (ii) allocated monthly
cash flow from the mortgaged property among reserve accounts in an order that
differed from that provided in the applicable pool asset
documents.  These actions resulted in shortfalls in certain reserve
accounts.
 
 
 
 Management’s Discussion and
Remediation Actions:
 With
respect to a cross-collateralized group of these commercial mortgage loans, the
Company’s actions were due in part to an error in the mortgage loan documents,
and with respect to another one of these commercial mortgage loans, the
Company’s actions followed the practices ofthe interim
servicer.
  The
Company has tightened its procedures for managing reserve accounts in order to
reduce the possibility of similar occurrences in the future.
 
 KPMG LLP,
a registered public accounting firm, has issued an attestation report with
respect to the Company’s compliance with the applicable servicing criteria as of
and for the year ended December 31, 2008.
 
 
 
 /s/ Daniel E. Bober
 Daniel E.
Bober
 Executive
Vice President
 Wells
Fargo Bank, N.A.
 March 4,
2009
 
 
 
 /s/ Briggs Hawley
 Briggs
Hawley
 Vice
President
 Wells
Fargo Bank, N.A.
 March 4,
2009