EFTA02520819.pdf

From: Jeffrey Epstein <[email protected]> Sent: Tuesday, May 21, 2013 11:02 AM To: Fenn, Patrick Subject: Re: FW: Early Termination Calculation understood, I was trying to get to a place where we rep=ace and repay the amh distribution, the new "borrower" would=be supported by the TRA payments or executed but held terminiaton payme=t,y not necesssarily inside apollo, that entity would then eventua=ly be also distributed , ending up with the borrower itself being owned=by the boys. On Mon, May 2=, 2013 at 11:59 PM, Fenn, Patrick mailto: wro=e: Would likely mean liquidating AP Prof and BRH. Theoretically could do so wi=hout triggering Tufts gain. Might be some non-tax hoops to jump through bu= presumably could be mastered. Would need to consider additional implicati=ns and discuss with Paul Weiss (company counsel). Not sure about holding in "different pockets"= AMH is one many entities that comprise the AOGs. Exchanges for Class A Sh=res only work if exchange an AOG Unit. Something to consider. From: Jeffrey Epstein (mailto:[email protected] <mailto:[email protected]> Sent: Monday, May 20, 2013 09:21 AM To: Fenn, Patrick Subject: Re: FW: Early Termination Calculation can we distribute out amh? I want to end up owning t=e holder and the debt. in different pockets. On Mon, May 20, 2013 at 9:08 AM, Fenn, Patrick <=pan dir="ltr"> <mailto: > wrote: Ok. Yes, thinking through possibilities. From: Jeffrey Epstein (mailto:[email protected] <mailto:[email protected]> J Sent: Monday, May 20, 2013 08:19 AM To: Fenn, Patrick Subject: Re: FW: Early Termination Calculation EFTA_R1_01657782 EFTA02520819  could they run the calcuations at a 30 and 35 dollar price=for apo , thanks, also have you given tought to refreshing the=basis in amh.? new loan,? partnership, guaranteed either payments=or assignment of tra in whole? On Mon, May 20, 2013 at 7:46 AM, Fenn, Patrick <=pan dir="Ite <mailto > wrote: Jeffrey, <=p> Calculation from Brian Kn=dson at E&Y. Note that this relates only to the unexchanged unit=, and does not include the existing TRA payments. <=p> Regards <=p> Hi Patrick, Attached is the calculation that we put together for Leon. As we=discussed, this only calculates the estimated early termination payment wi=h respect to the APP units held by Leon - it does not yet calculate the estimated early termination payment with respect to rema=ning TRA benefits related to the 2007 exchange. I have added an assumption= tab to the workbook outlining many of the items that we discussed. Thanks= Brian Brian Knudson=span style="font-size:10.0ptfont-family:"Arial","sans-se=if""> I Partner I National Tax - Partnership and Joint Ventures Ernst & Young LLP 200 South Sixth Street, Suit= 1400, Minneapolis, Minnesota 55402, United States of America Office: tel Mobile: <tel <mailt Website: www.ey.com=/span> <http://www.ey.com> 2 EFTA_R1_01657783 EFTA02520820 Thank you for considering th= environmental impact of printing emails. 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The information contained in this e-mail message is intended only for the p=rsonal and confidential use of the recipient(s) named above. If you have r=ceived this communication in error, please notify us immediately by e-mail= and delete the original message. 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] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 3 EFTA_R1_01657784 EFTA02520821  IRS Circular 230 Notice Requirement: This communication is not given in the=form of a covered opinion, within the meaning of Circular 230 issued by th= United States Secretary of the Treasury. Thus, we are required to inform =ou that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding Uni=ed States federal tax penalties. In addition, any tax advice contained in =his communication may not be used to promote, market or recommend a transa=tion to another party. The information contained in this e-mail message is intended only for the p=rsonal and confidential use of the recipient(s) named above. If you have r=ceived this communication in error, please notify us immediately by e- mail= and delete the original message. ******** **• ** ***** **• ** ***** *****•*** *********** * ****** *• ** 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] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved IRS Circular 230 Notice Requirement: This communication is not given in the=form of a covered opinion, within the meaning of Circular 230 issued by th= United States Secretary of the Treasury. Thus, we are required to inform =ou that you cannot rely upon any tax advice contained in this communicatio= for the purpose of avoiding United States federal tax penalties. In addit=on, any tax advice contained in this communication may not be used to prom=te, market or recommend a transaction to another party. The information contained in this e-mail message is intended only for the p=rsonal and confidential use of the recipient(s) named above. If you have r=ceived this communication in error, please notify us immediately by e-mail= and delete the original message. The information containe= in this communication is confidential, may be attorney-client privileg=d, may constitute inside information, and is intended only for the use of the a=dressee. It is the property of Jeffrey Epstein Unauthorized 4 EFTA_R1_01657785 EFTA02520822 use, di=closure or copying of this communication or any part thereof is strictl= prohibited and may be unlawful. If you have received this communication in error, p=ease notify us immediately by return e-mail or by e-mail to [email protected], =nd destroy this communication and all copies thereof, including all attachm=nts. copyright -all rights reserved 5 EFTA_R1_01657786 EFTA02520823