EFTA00669992.pdf

From: Brad Wechsler <1 To: Ada Clapp <1 Richard Joslin CC: Joe Avantario , John Castrucci <1 , Jeffrey Epstein [email protected]> Subject: Re: S-Corp Election Date: Thu, 10 Dec 2015 23:16:23 +0000 Guys-even on the small stuff can start copying jeffrey. Thx Sent from my Verizon Wireless BlackBerry From: Ada Clapp Date: Thu, 10 Dec 2015 22:45:25 +0000 To: Richard Joslin Cc: Joe Avantario ; Brad Wechsler >; John Castrucci Subject: S-Corp Election Hi Rich, As part of the year-end planning, we will create a new S-Corp the stock of which will be sold to the APO1 Trust. As long as it is a grantor trust, APO1 is eligible to hold Sub S Stock. However, Alan and I think we should make a protective Sub S election just in case an unexpected event should cause grantor trust status to cease. Paul Weiss tells me the election can be made any time before March 15th. Kindly put this item on your "to do" list. Thanks! Ada Clapp Chief Legal Officer Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 Direct Dial: Fax: Email: 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. Thank you. From: Orol, Zoey F [mailto Sent: Thursday, December 10, 2015 5:26 PM To: Ada Clapp < > Cc: Halperin, Alan 5 Subject: RE: Transaction Documents Hi Ada, EFTA00669992 The election can be made any time before March 15th. Zoey Zoey F. Orol I Associate Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York NY 10019-6064 Direct Phone) I (Direct Fax) I EFTA00669993