EFTA00871770.pdf

From: Jeffrey Epstein <[email protected]> To: Ada Clapp Subject: Re: 2006 Trust Decanting Date: Mon, 16 Dec 2013 16:09:31 +0000 it will be favoroable , but i am uncertain of time , jumping the line for the rich is not recied well since de blasio was elected On Mon, Dec 16, 2013 at 10:55 AM, Ada Clapp < wrote: OK—this is your call. That means that any note/art substitution will end up being done in the APOI Trust and be part of its history (so there will be a trail of bread crumbs back to the note). Seemed like a better idea to give it a clean slate and undo the note in the old trust. Did you get any feedback on the petition from NYS (as I understand it, they usually give you an opportunity to withdraw the petition if it will not be favorable)? Ada Clapp Black Family Partners do olio Management phone: email: IRS Circular 230 Disclosure: 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. On Dec 16, 2013, at 10:46 AM, Jeffrey Epstein <[email protected]> wrote: i prefer to do all now. On Mon, Dec 16, 2013 at 10:41 AM, Ada Clapp < wrote: Good morning Alan and Jeffrey, EFTA00871770 At our last meeting, we discussed completing the 2006 Trust decanting by year-end. However, given that we will likely hear back from NYS on the Advisory Opinion Petition in early January, I suggest we hold off on decanting the Note (and preparing the assignment form) from the 2006 Trust to the APO I Trust. That way, if Jeffrey's client gets a favorable opinion, we can do the substitution in the 2006 Trust and then simply decant the substituted art to the APO' Trust. Agree? Ada Clapp Black Family Partners cio lo Management phone: email: IRS Circular 230 Disclosure: 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. On Dec 13, 2013, at 2:19 PM, Alan S Halperin < wrote: Thanks, Ada. Timing will not be an issue. I hope you will be going somewhere fun. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. Click Here for More Information Alan S. Halperin I Partner Paul. Weiss. Rifltind Wharton & Garrison LLP Direct Phone (Direct Fax) EFTA00871771 From: 'Ada Clapp To: Alan S Hainan Cc: "Eileen Alexanderson" Date: 12/13/2013 01:01 PM Subject: Re: 2006 Trust Decanting Hi Alan, Hope you are having a good day. I wanted to remind you that I will be out of the office from December 20th until after the first of the year. Do you think you will have drafts of the below documents for me to review early next week? I know Jeffrey wants this completed in 2013. Also wanted to make sure you have my cell number: Thanks! Ada Clapp Black Family Partners do Apollo Management phone: email: IRS Circular 230 Disclosure: 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. On Dec 9, 2013, at 5:15 PM, Ada Clapp > wrote: Hi Alan, To complete the decanting of the 2006 Trust I believe we will need the following documents: 1. Assignment by the 2006 Trust to the APO I Trust of the Note dated August 15, 2013 issued by Leon as Maker. EFTA00871772  2. Assignment by the 2006 Trust of its interest in LBF Holdings, LLC. 3. Assignment of the Art Held in the 2006 Trust. We have a list of art (about 13 pieces) held in the 2006 Trust which we can attach to the assignment. Attached below is the Operating Agreement for LBF. Please let me know if you need anything else to prepare the assignments. Thanks! Ada Clapp BlackFadlyftiners do loMemagoned ohmic email: IRS Circular 230 Disclosure: 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. <LBF Holdings LLC Operating Agt.pdf, This message is intended only for the use of the Addressee and may contain information that is privileged and confidential. If you are not the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, please erase all copies of the message and its attachments and notify us immediately. 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 EFTA00871773  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 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 EFTA00871774