EFTA02638966.pdf

From: jeffrey E. <[email protected]> Sent: Monday, August 21, 2017 5:31 PM To: Jeffrey Epstein Subject: Fwd: note transaction big Forwarded message jeffrey E. «= href="mailto:[email protected]" target="_blank">jeevacation@gmailacom> Date: Fri, Aug 18, 2017 at 9:14 PM Subject: Fwd:<=r>To: Jeffrey Epstein <[email protected] <mailtoieevacation@gmailcom» april=C2* the large transaction is discussed and money owed calculated. =C24> you will then see the only thing that put it on hold was that =ou received a gift tax audit. Alan had not discussion re note=transaction AT ALL until end of year. and his imput was techni=al and avaiable for you to see. - he did not belive the bank =ould give you a letter of credit for 800 milliion. ALL SILLY =C240 you will also see that my letter and week of work was the only thing=that went into it. I had to personally redo the letter and the valua=ions. the agent when he saw the presentaion =anceld the audit for the following year that had been scheduled. 4>=A0 =br> Forwarded message From: jeffrey E. <[email protected] <mailto:jeevacation@=mail.com» Date: =ed, Apr 15, 2015 at 8:59 AM Subject: To: Melanie Spinella < 1 did the paul weiss bill get paid ??? 4,=A0 2. Talk to me before signing anything today important 10m paid today to gratitude america, a 501 c 3, willl =ake last year complete. 20 million paid today ftc . 10 million july 15 = million sept 30. , 5 million jan 1 for all of 16 . tax savi=gs paid at 37 percent . of net. savings. 50 million credit. net. =o 150 million free . 600 savings , for the note transaction with =he trusts . 40 percent of the 1. 5 billon = 225 million owed. - 50=C2* credit, 175 owed. From: Thomas Turrin [mailto Sent: Tuesday, May 10, 2016 10:48 AM To: 'effre E. .c'eevacation@ mail.com <mailto:[email protected]»; Halperin, Alan < =» Subject: GIFT TAX AUDIT EFTA_R1_01871029 EFTA02638966 Alan and Jeffrey, The agent finally called me this morning. 40=A0 He was apologetic that he didn't call sooner. He said he=E24040s been in and out of the office the last couple of weeks. He was very nice on the phone....saying we can=have more time to get him the information requested. However, he said to contact him by the end of May if=we still need more time. He said he would grant more time, if necessary. I would hope we can get the response done as soon as=possible so we don't have to ask for more time. The bad news is that they will also examine 2014.4=A0 He told me a letter will go out soon. Mr. Falk readily volunteered that it is the GRATS (s=ecifically the valuations) that are kicking off the audits. He did say that he would try to "move the au=its alone.... He also said he sees (and audits) valuations from Empire all the time. I'm reachable all day, if you would like to =all. Tom THOMAS TURRIN, CPA Partner 2 EFTA_R1_01871030 EFTA02638967 Raich Ende Malter & Co. LLP 1375 Broadway=/span> New York, New=York 10018 (Direct line) (Fax) (Cell) Email: =a href="mailto target="_blank"> Website: www.rem-co.com <https://ur=defense.proofpoint.com/v2/url?u=http-3A_www.rem- 2Dco.com_&d=CwMFA=&c=MVcBZOqZGZIJcau2llMSkQ&r=DV67nrVr3Ofj1p3KSodgQyjLl2HTPMYke7=EruYcDxk&m=5eS5 y_VVNEKbQkxcWUsklpu8YRjBuDLZhXyoxlb9EPg&s=qXRDq=huMBb0a2u2te7LDp7E5mzucipm84Rv0cBRXw40&e=> <https://mail.google.com/mail/u/0/images/cleardot.gif> I www.paulweiss.com <http://www.paulweiss.com> =div id="m_6915013638993964552m_7718194838485202617gmail-:296" class="m=6915013638993964552m_7718194838485202617gmail-T-I m_6915013638993964552m_7=18194838485202617gmail-J-J5-Ji m_6915013638993964552m_7718194838485202617g=ail-T-Itis-Gs m_6915013638993964552m_7718194838485202617gmail-ar7 m_691501=638993964552m_771819483/3485202617gmail-mw m_6915013638993964552m_771819483=485202617gmail-T-I-ax7 m_6915013638993964552m_7718194838485202617gmail-L3"=title="Labels"> =div class="m_6915013638993964552m_7718194838485202617gmail-G-atb m_69150=3638993964552m_7718194838485202617gmail-D m_6915013638993964552m_771819483=485202617gmail-E"> <https://mail=google.com/mail/u/0/images/cleardot.gif> <=span> <https://mail.google.com/mail/u/0/image=/cleardot.gif> Inbox x </=able> <=iv class="m_6915013638993964552m_7718194838485202617gmail-nH m_691501363=993964552m_7718194838485202617gmail-hx"> 3 EFTA_R1_01871031 EFTA02638968 <=able class="m_6915013638993964552m_7718194838485202617gmail-cf m_6915013=38993964552m_7718194838485202617gmail-adz" cellpadding="0"> to me <https://mail.google.com/mail/u/0=images/cleardot.gif> Forwarded message From: jeffrey E. <[email protected] <mailto:[email protected]» 0=te: Wed, Apr 15, 2015 at 8:59 AM Subject: To: Melanie Spinella <=a href=' 1 did the paul weiss bill get paid ??? =C2.2. Talk to me before signing anything today important 1=m paid today to gratitude america, a 501 c 3, willl =ake last year complete. 20 million paid today ftc . 10 million july 15 = million sept 30. , 5 million jan 1 for all of 16 . tax savi=gs paid at 37 percent . of net. savings. 50 million credit. net. =0 150 million free . 600 savings 225 million owed. - 50 credit, 1=5 owed. Forwarded message From: jeffrey E. <[email protected] <mailto:[email protected]» D=te: Wed, Apr 22, 2015 at 7:56 AM Subject: another flowery email. To:=Melanie Spinella < < >> I am sorry. I realize you are under tremendous stress, In Bedfor= you asked me for my help I could not have been more clear that thou=ht it very unwise as in my words I did not want any financial arrangm=nt between us, it risked conflict and tension what neither of us n=eded more of. and did not want to risk torturing our friendship into the likes of the kind you have with Mark nor Josh, : now,4=A0 I dont have anyone but you yelling at me, in my own house. no one. it is highly unpleasant but I am trying my best to be understanding . sorry = From the outset and as you told me you recall. i tsuggested t=at three years should be the period of engagment. as planning is not a o=e year excericse . you declined to commit to a number of alternatives presented to you for payment of the third year. I told yo= in nov that you should decide whether to now sign on for that very third year as the vast majority of my work ended on oct 15. you recently t=ld me you thought i was kidding. .you hired brad patting him on the back=20 that after months of inquiry he can now, finallly tell you which Ilc=20 owns the cars?? once he has all the facts what next ??. whether or not you refer to a portion of the third y=ar as after care, or whatever term besides 'scoundrel you choose to use,Q=A0 I m not sure why you assume now it should be free.( I HATE THIS CONVERSATION=20 < HATE , ) and i heard you when you said you told me what wasi>=A0 I work still to be done you thought valuable enough to pay for. please=20 tell me . and then we can decide the next steps „, if any. I consider my work rarefied art. I guess the value is in the eye of the beholder=. IT reminds me of those people looking at a modern art piece and saying40=A0 " my child could do that " . hope you are feeling be=ter. Forwarded message From= jeffrey E. <[email protected]<=a» Date: Fri, May 1, 2015 at 8:36 AM Subject: To: Mel=nie Spinella < >> 4 EFTA_R1_01871032 EFTA02638969 I know that both you and I heard brads'. im out of here if i dont =et a coo. . sorry,. i know that neither of us have stood in the way =f his finding/ getting one.. JPM account D8 account GS account, ???=C24> its MAY 1. nothing in the first quarter and these are only papers that ne=d signing. I suggest your thinking on my role and compensation for my work might benefit , from a mental shift - =hink mark and josh, without the mutual resentment ( HAHA) only in terms of=20 sharing ,thanks, I am and have been your financial partn=r i.. rectifying circumstances that appear in hind sight unexpl=inable. I wish you woudl have asked me earllier to review your things, but i understand. I do know that soley as a result of my actions you= personal bottom line has increased dramatica=ly, if you had thought of me as your partner in this endeavor , instead of an employee, i think your reaction to sharing t benefits would be different. If you recall, you wanted me to be p=id , unlike others at the END of my work. we discussed this ad nauseum,Q=A0 and agreed OCT 15, last year was the end . You had wanted more comf=rt initially on the art partnership so that date was delayed. It h=s now been six monhts since then, your concept of aftercare . .=C2* for free. was already unique, in your words this has to have an end.( w=aned ) if the actions of josh and mark led to one =undred million dollars , what would be their share. Im not sure why it =s different in your mind. but i respect the fact that it is, Is it because their=20 work seems harder. it cannot be simply because they=devote more time to you .or it appears to involve more effort. I am happy to co=tinue to play a partnership role. as I have been in many areas of your lif=. . I am also happy to move on and have no more of these emails. =1 find them as tedious as you do . if you prefer a partnership structure , =k with me, I tried to minimize the amount of money i would recieve by=20 making it a flat fee . as i wanted you to feel good and have no second thoguths somehow if the payment comes from a partnership struc=ure you seem relaxed as opposed to writing a check, I focus on40=A0 trust and friendship first, and the fact that you don't include josh and mark in=20 that category, gives me great pause . I proposed 33 perc=nt of money made for you. . in the past you agreed that amount. it will b= huge, but ok with me, I can talk today at 945 as yo= suggested. or if you woudl rather over the weekend ok Forwarded message From: jeffrey E. <[email protected]> Date: Mon, May 11, 2015 at 9:08 AM Subject: To: Brad Wechsle= < < », Melanie Spinella < = target=», R=chard Joslin < Forwarded message ---_------ From: jeffrey E. <[email protected] <mailto:[email protected]» Date: Mon, May 18, 2015 at 8:17 AM Subj=ct: agenda for tomorrrow To: Jeffrey Epstein <'eevacation@ mail.com <mailto:'[email protected]», Melanie=Spinella < >>> as a reflection on Q=A0your voiced spirited concerns in the what have you don= for me lately category ? )):: . <=iv> in the beginning . there was eileen and tom. ( eve and adam=-- however it appears, she declined to eat the apple from the knowledge tree)=C2* . that was it. ada was at the bank but =eviewing docs. carlyn was in the kitchen making mush ( abel an= cain) books as they were mystersiously called was being kept soley b= eileen, with little or no input ,correction or advice from tom. herarely if=20 ever asked questions. expenses ie airplane was do=e in house apollo. (1031 exchange blown etc) at this time 5 EFTA_R1_01871033 EFTA02638970 as I recall you got quite annoyed, and agressive and initiated the" t=lking out of the both sides of your mouth " tiddy, when i suggested th=t the level of their competence left much to be desired. ( ralph lerner'=s came later ) .response - eileen ran the desk, torn is a partner,= ralph wrote the book etc re tax there was almost no overs=ght of income, estate, gift ,sales and use, transfer excise etc . +=AO IRS SEC GAMING NYS. real estate, valuations ( many )tax filings= disclosures, etc. re grats trusts defect trusts, Ilcs corps ,=20 trustees , partnerships. foreign corps. 100 bank account=. gift taxes, loans, notes. payables. expenses. . , insurance.( life , art= split dollar), cashflows, operating biz, investments, contingent liabilitiites.( funds , miami ), commitments dividends, BRH =C24>TRA, shareholder agreements, bank loan agreements. wills, construct=on, contracts planning permits etc..employ rules. checking ac=ount reconciliations, crediti cards. jewelry, cost basis ,( a=t stock etc.) foundations regs , brokerage accts, old stock certificate=. stock options,( environmental solutions still not done !). estate tax calcualtion firedrill, ( note ,basis etc ) low basis , step ups , however with no accounting system, no reveiw of boat expenses =lane expenses etc. . many outside counsel with litle or no coordination.</=iv> Paul Weisss , Mcdermit Will, Macfarlanes. Price Waterhouse, Reich, withers bergman, Empire„ akin gump, bbd seidman, Wendy , Apollo in=20 house . lumber, knowledge universe, ennvironmental= solutions 12 mii in stock, . on and on the priority list that you asked me to prepare for brad and you in=dec , unfortunatlleyso far, little change ie no accounting sy=tem that ties, no, brokerage accounts though strongly suggested , =pm db, gs, april of 2014 . IT antiquated dagastino hired = no inut from me, julie, temps, paralegals miriam . etc. still need new accounting system - on line banking . staff hir=s. ( seprate from samantha two years out of school ). audit system, = ?? john murphy? joslin? dag? eva? . i strongly suggest worke=s at the highest level of competence. two senior accountants. not managers workers who will get into the weeds. partn expertise, replac= ava, get heather help. a new person legal , new IT,system and person, Q=A0 way way overdue, new receptionist, bill opener, ability to oeversee in house, boat plane review household ( 12million ) review, filings- partnerhip accounting,- familitarity with grats, trusts etc . audit system put in place. that should be the easy part. then strategy to=20 deal with : As new facts on the ground develop , =haidon debra, children meeetings, ? stock sale sale of art„ a=t( large gain ), 1031 trade in , plane depreciation, boat sale. construction , brad will oversee brokerage and investment, ?? pe. real es, .=20 publishing, grats, tra, brh ( death). foundation , museum, tax=20 proejctions cash flow projections, cooridnation with tax from apollo.=20 etc Forwarded message From: Brad Wechsler < < »=br>Date: Wed, May 27, 2015 at 12:29 PM Subject: John Castrucci To: J=ffrey Epstein <[email protected] <mailto:[email protected]» Cc: Melanie Spinella < ><=r> Jeffrey-leon and I (and martin kelly) all like john c for the coo/cfo role. Next step is for you to interview him; hopefully in person. When will you be arnd or is this a skype. Remember he's at the sackler family coming from ray chambers. Various=20 observations were: nice manor, seasoned, sufficient seniority to have rj report to him, willing to get hands dirty on numbers, knowledge of IT platforms, partnership issues, accounting. Let me know what works. B Sent from my Verizon Wireless BlackBerry to me <=span> 6 EFTA_R1_01871034 EFTA02638971 <https://mail.google.com=mail/u/O/images/cleardot.gif> Forwarded message - From: jeffrey E. <[email protected] <mailto:[email protected]» Date: Thu, May 28, 2015 at 8:53 PM =ubject: ulysses 2.0 To: Melanie Spinella < < >> <=iv dir="ltr" style="font-size:12.8px">! realize it is only due to a la=k of understanind of the job ahead. and not out of any sense of unwi=lingess to pay =/div> - as opposed to merely hiring people to set up a family office, someone will have to do the following- separate from the art partnership whi=h is my responsiblity . there still needs to be a huge amount of=work done for 2015,16. not to mention that brad at the moment is Q=A0going to have train the incoming team?? your call strategic decisions re estate and other planning , sale of phaidon etc. . in addition setting up for the accounting for each strategy ie.: inco=e, estate, gift ,sales and use, transfer excise picasso, 1031 calder. .= review and detailed oversite of IRS SEC GAMING NYS. real esta=e, entity valuations ( many ) tax filings- disclosures, follow up=of grats, trusts ,defective trusts, Ilcs corps, trustees , partnerships= foreign corps. 100 bank account need to be rationalized,=not only having brad step in to children investments . gift taxes, trust=, loans, notes. payables. expenses allocations . . , insurance.( life ,=20 art, split dollar), cashflows, operating biz„ investments, continge=t liabilitiites.( funds, miami ), commitments funds and charities , dividend treatment -important review of transcations relating to4k=A0 BRH ( amendments) TRA sale ( nuanced ) , shareholder agreements,=bank loan agreements new bank relationships. . wills, construction accou=ting and oversite , contracts planning permits etc..employee r=les, regs, . checking account reconciliations, crediti cards. jewelry=, cost basis,( art stock etc.) foundations regs , brokerage accts, . =C24> stock options,( ie environmental solutions still not done I). estate tax calcualtion firedrill, ( note ,basis etc ) review of boat expen=es plane expenses, depreciation issues refunds etc. . rationalize all4k=A0 outside counsels and accounting firms Paul Weisss , Mcdermit Will= Macfarlanes. Price Waterhouse, Reich, withers bergman, Empire,=, akin gump, bbd Seidman, Apollo in house counsel. se= up and oversee brokerage accounts at JPM DB GS and thou=hfullly trade . new IT system from top to bottom full=time IT person new accounting system - on- line banking cooridnated with reports = fire drills as per caruci ( he sounds good ) and . audit system,s .=review of john murphy? joslin? dag? eva? . in ho=se, review household ( 12million ) review, filings- partnerhip accounting,- familitarity with grats, trusts etc . audit system put in place. that should be the easy part. then strategy re: As new=facts on the ground develop, phaidon debra, children meeetings, involv=ent , trustees adjusted, stock sale sale of art, apt( large g=in ), 1031 trade in , plane depreciation, boat sale. construction , brad will oversee brokerage and investment, ?? pe?. real estate?, . publishing,=20 grats, tra, brh ( death). foundation , museum, t=x proejctions cash flow projections, cooridnation with tax from apollo. etc you are sitting on over 100 m of cash???=! From: jeffrey E. [mailto:[email protected] <mailto:jeevacation@gma=l.com> Sent: Friday, June 05, 2015 08:19 AM To: Brad Wechsler; Richard Joslin < »; Melanie Spinella >> > Subject: to create a boat file 7 EFTA_R1_01871035 EFTA02638972 1. =tatement of taxpayer's boating experience. 2. Cop=es of potential charterers. 3. Pur=hase agreement, Bill of Sale and Invoice, and all canceled checks showing =erification of yacht purchase. 4. Sta=ement of actions taken to investigate boat 5. Nam= and address of all charterers and their lease agreement. 6. =chedule of fees or charges billed to charters. 7. =opies of original loan agreements/promissory notes on financed portion of =roperty. 8. =nsurance policy(s) on yacht and its contents (collision and liability). 1,=A0 Note to examiner: Does policy cover rental=of boat? 9. Cop= of First Preferred Ship Mortgage. 10. Pr=motional materials and charter sailing brochures for yacht.<=p> 11. In=oices and ad copies for advertisements on availability of yacht for rental= 12. Co=ies of any management agreements or management contracts for boat supervis=on, maintenance, or operation. 13. Sh=ps log(s) for engine and/or boat use. 14. Ma=ntenance records and service check performance records. 8 EFTA_R1_01871036 EFTA02638973 15. Ce=tificate of Origin. 16. Ce=tification of Documentation from U.S. Coast Guard. 17. Co=y of commercial captain's license. =C24k please note The information co=tained in this communication is confidential, may be attorney-client pr=vileged, may constitute inside information, and is intended only for JEE Unauthorized use= disclosure or copying of this communication or any part thereof is str=ctly prohibited and may be unlawful. If you have received this commu=ication 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 thereo=, including all attachments. copyright -all rights reserved Q=A0 please note The information contained in this commu=ication is confidential, may be attorney-client privileged, may cons=itute inside information, and is intended only for the use of the addre=see. It is the property of JEE Unauthorized use, disclosure or copyi=g of this communication or any part thereof is strictly prohibited a=d may be unlawful. If you have received this communication in error, pl=ase notify us immediately by return e-mail or by e-mail to [email protected], a=d destroy this communication and all copies thereof, including all a=tachments. copyright -all rights reserved 9 EFTA_R1_01871037 EFTA02638974 --001a114c9b22fcd006055746d55c-- conversation-id 34472 date-last-viewed 0 date-received 1503336632 flags 8590195713 gmail-label-ids 7 6 2 remote-id 741694 10 EFTA_R1_01871038 EFTA02638975