EFTA02583992.pdf

From: Ada Clapp Sent: Wednesday, May 21, 2014 7:29 PM To: Jeffrey Epstein Cc: Eileen Alexanderson; Eileen Alexanderson; Richard D'Agostino CPA Richard Joslin Subject: LDB Foundation/FTLOA Foundation Hi Jeffrey I spoke with Diana Wierbicki at Withers today to request that she prepare th= documentation to remove Ralph as a Director of the LDB Foundation. On our call she noted that Withers had not yet filed the IRS Form 1023 (Appl=cation for Recognition of Exemption under IRC Section 501(c)(3)) for the FT=OA Foundation. She noted that FTLOA has 27 months from formation to file fo= recognition as an exempt organization and that we will reach the 24 month m=rk this December. She has not yet filed because she understood there was some question as to w=ether the application should list the FTLOA as a private operating foundati=n or as a simple grant-making private foundation. If she files as a privat= operating foundation, she would like to be comfortable that Leon has ident=fied art he wishes to gift to the foundation as well as museums who wish to=borrow it within the next three years and that we have arranged for outside=storage of the art (i.e. not on Leon's walls) or a gallery space in which t= exhibit the works to ensure that FTLOA can qualify as an operating foundat=on. If she files as a private operating foundation and Leon later changes h=s mind about giving up possession of the art or FTLOA sells the art within 3=years, Leon would have to amend his income tax returns to adjust any fair m=rket value deduction he may have taken in his gift of the art to FTLOA. How would you like Withers to proceed regarding the Form 1023. Would you lik= to meet to discuss more of the logistics? Please note that we have no office email or phone service today so I am send=ng via gmail. My cell is 347.304.0508 should you wish to speak. Sent from my iPad=?xml version=.0" encoding=TF-8"?> <IDOCTYPE plist PUBLIC "-//Apple//DTD PLIST 1.0//EN" "http://www.apple.com/DTDs/PropertyList-1.0.dtd"> <plist version=.0"> <dict> <key>conversation-idgkey> <integer>291147</integer> <key>date-last-viewed</key> <integer>0</integer> <key>date-received</key> <integer>1400700547</integer> <key>flags</key> <integer>8590195713</integer> <key>gmail-label-ids</key> <array> <integer>2</integer> </array> <key>remote-id</key> EFTA_R1_01762486 EFTA02583992  <string>411352</string> </dict> </plist> 2 EFTA_R1_01762487 EFTA02583993