EFTA02574918.pdf

From: Jeffrey Epstein <[email protected]> Sent: Friday, September 27, 2013 1:56 PM To: Ada Clapp; Melanie Spinella Subject: Re: Pour-over and GRATs form the grats asap On Fri, Sep 27, 2013 at 9:52 AM, Ada Cl=pp < mailto: > wrote: Good mor=ing Jeffrey, I understand that you want to move quickly=(though perhaps not all the nuances for your timing) but I am wondering wh=ther we have thoroughly considered the timing of the pour-over? Does=it perhaps makes sense to do the pour-over after you have received = favorable advisory opinion on the substation for your client and we decid= how to move forward with Leon's substation. Two reasons to conside= waiting for your client's ruling: 1. If we do the substation in the 2006 Tr=st (which will disappear), what gets decanted into the Heritage Trust is=the art. Nice and clean --no need to do a substitution in the Heritage =rust that might draw attention if we decide to move forward on someone els='s ruling. 2. The substitution language cited in the=petition for the ruling request is the Weil language contained in the 2006=Trust. The Heritage Trust contains different substitution language. =e don't know how much the language will factor into the Advisory Opini=n. Might make it harder to rely on someone else's opinion if we dec=de to move forward on that basis. What do you think? <=iv> Ada Clapp =span style="font-size:7.5pt">Black Family Partners c/o Apollo Management 9 W 57th Street =span style="font-size:7.5pt">New York =Y 10019 =span style="font-size:7.5pt">phone: cte e=ail: <mailto: =RS Circular 230 Disclosure: Pursuant to IRS reg=lations, I inform you that any tax advice contained in this communication =including attachments) is not intended or written to be used, and cannot b= used by any person or entity for the purpose of (i) avoiding tax related =enalties imposed by any governmental tax authority, or (ii) promoting, mar=eting or recommending to another party any transaction or matter discussed=herein. I advise you to consult with an independent tax advisor on your pa=ticular tax circumstances. EFTA_R1_01746044 EFTA02574918  This communication, and any attachme=t, is for the intended recipient(s) only and may contain information that =s privileged, confidential and/or proprietary If you are not the intend=d recipient, you are hereby notified that further dissemination of this co=munication and its attachments is prohibited. Please delete all copies =f this communication and its attachments and notify me immediately that=you have received them in error. <=div> On Sep 27, 2013, at 9:11 AM, Jeffrey Epstein <[email protected]>= wrote: lets prepare the new grats and pourover =sap. =br>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 a=dressee. It is the property of Jeffrey Epstein Unauthorized 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 *= ******* *•** ******** ******* s•*** ***** *mit ********** ** The informati=n contained in this communication is confidential, may be attorney-clie=t privileged, may constitute inside information, and is intended only for the use of the a=dressee. It is the property of Jeffrey Epstein Unauthorized 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 2 EFTA_R1_01746045 EFTA02574919