0000894579-02-000116 Sample Contracts

Accepted By: /s/ Donald G. Allison ------------------------ Donald G. Allison Secretary and Treasurer
Expense Subsidy Agreement • October 29th, 2002 • Bramwell Funds Inc

This letter will confirm our binding commitment to you that Bramwell Capital Management, Inc., the investment adviser to the Bramwell Growth Fund (the "Fund"), has agreed to subsidize the Fund such that the total expenses of the Fund (excluding interest, taxes, brokerage and extraordinary expenses) do not exceed an annual rate of 1.75% of the Fund's average net assets for the fiscal years 2003 and 2004.

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