EFTA00872257.pdf

From: Jeffrey Epstein <[email protected]> To: Melanie Spinella Subject: Fwd: Personal Rep/GRAT Date: Wed, 16 Oct 2013 16:05:27 +0000 please give to leon Forwarded message From: Ada Clapp czli Date: Wed, Oct 16, 2013 at 11:45 AM Subject: Personal Rep/GRAT To: Jeffrey Epstein <[email protected]> Cc: Eileen Alexanderson Hi Jeffrey, We need to do two things to accomplish the nomination of a personal representative for the Agreement Among Principals: I. For the lifetime appointment: Alan will draft a new limited power of attorney giving John Hannan the power to act if Leon becomes disabled. He can name John Suydam ( and Scott Kleinman) as the backup if there is no conflict. 2. On the event of Leon's death: Only Leon's Executors are his legal representatives after he dies. We don't want there to be any challenge to the personal representatives authority to name someone to the Executive Committee so this person needs to be an Executor. Alan can prepare a Codicil to Leon's Will to name one of Leon's named Executors as the personal representative. The problem is that John Hannan is not currently named as an Executor. Neither of the back-ups to John Hannan (John Suydam or Scott Kleinman) are likely choices to serve as Leon's Executors. One choice is to make John Hannan a fourth Executor with Barry Cohen as his backup. For purposes of Leon's surgery tomorrow, a more practical choice may be to name Barry Cohen as the Executor who is the personal representative. Either of these things can be done in a quick Codicil to Leon's Will. Which would you prefer? Regarding the GRAT: Even if Leon signs the GRAT today, I am not sure we are ready to fund it. There is an issue about funding a GRAT with encumbered property that we are still trying to resolve. I will forward you a more detailed discussion that I have had with Alan on the subject. As you know, the GRAT term does not commence until the GRAT is actually funded. Best regards, Ada Clapp Black Family Partners do Apollo Management IRS Circular 230 Disclosure: EFTA00872257 Pursuant to IRS regulations, I inform you that any tax advice contained in this communication (including attachments) is not intended or written to be used, and cannot be used by any person or entity for the purpose of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) promoting, marketing or recommending to another party any transaction or matter discussed herein. I advise you to consult with an independent tax advisor on your particular tax circumstances. This communication, and any attachment, is for the intended recipient(s) only and may contain information that is privileged, confidential and/or proprietary If you are not the intended recipient, you are hereby notified that further dissemination of this communication and its attachments is prohibited. Please delete all copies of this communication and its attachments and notify me immediately that you have received them in error. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00872258