EFTA01900498.pdf

To: jeevacation©gmail.com[jeevacation©gmail.corn] From: Eileen Alexanderson Sent Sun 3/31/2013 5:08:41 PM Subject: Re: follow up August 2013 and pours into the 1997 Trust From: Jeffrey Epstein [mailto:[email protected] Sent: Sunday, March 31, 2013 06:12 AM Eastern Standard Time To: Eileen Alexanderson Subject: Re: follow up when does the 2009 judah trust terminate. and what does it pour into On Thu, Jul 5, 2012 at 9:02 PM, Eileen Alexanderson wrote: See Article II on pgs 1-2 of the 2006 Trust Doc attached to my last email for language related to distribution of 'trust accounting income' from operating profits of 'relevant companies' which you will see detailed in II(A)3. The 'relevant companies' arc the Apollo entities Leon had ownership interests in that he contributed into the GRATs that poured into the 2006 Trust. There isn't specific language surrounding the principal. The trusts owns the interests in Black Family Partners and the monetization of the value of the BRH interests would not constitute 'trust accounting income' from 'operating profits' and would therefore remain in the trust. I will next forward a summary entitled 'History/Structure' that I wrote for myself early on as I was trying to come up to speed on what had been put in place. I believe I left you a hard copy which was behind the org chart of Black Family Partners. There is a section on the first page with comments on FLPs-I was in an education mode and, with hindsight, did not fully understand the control issues but I think otherwise this will help you understand where we came from. Importantly, you will see there were 2 sets of GRATs. The termination of GRATs A-K went as planned. But the second set, GRATs L-O lacked sufficient cash to make the final annuity payment to Leon so we did an inkind transfer of the Black Family Partners these GRATs owned to Leon and then he contributed these into a new GRAT, the Judah 2009 Trust. We made that a 4 year GRAT instead of 2 years like the original ones we did because I felt we would not have generated enough cash in 2 years to make the annuity payments to Leon. Original Message From: Jeffrey [mailto:jeevacationaginail.com] Sent: Thursday, July 05, 2012 1:46 PM To: Eileen Alexanderson Subject: Re: follow up Send me vat does that separate income from capital appreciation EFTA_R1_00329363 EFTA01900498 Sorry for all the typos .Sent from my iPhone On Jul 5, 2012, at 12:09 PM, Eileen Alexanderson wrote: > Jeffrey, thinking back through dialogs with Carlyn & Elyse and looking at some of my old notes from those dialogs that relate to our conversation this morning I offer the following: > Regarding the issue of why turning off the income right now works is that it would be the independent trustees turning off the income right, not Leon, and that the 2006 Trust was drafted purposely in anticipation of this. I believe this relates to the language on page 30 in the attached. > Also, Ada (from US Trust) at one point had suggested to Carlyn that we consider having the trustees turn of the income right in the 2006 Trust and then decant the assets from the 2006 Trust into a new trust before proceeding with the Art Partnership to insure a cleaner transaction. > Also, on the subject of the 2006 Trust and other trust paying their own taxes-important implication for Black Family Partners would be that we no longer have a single taxpayer. > Best, > Eileen > Original Message > From: NY 730_11_XRX COPYROOM [mailto: > Sent: Thu y, u y , > To: Eileen Alexanderson > Subject: Scan from a Xerox Color > Please open the attached document. 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If you have received this email in > error please contact the sender and delete the material from > any computer. > Apollo Global Management, LLC > <img-705120530-0001.pdf> This email and any files transmitted with it are confidential and intended solely for the person or entity to whom they are addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you have received this email in error please contact the sender and delete the material from any computer. Apollo Global Management, LLC * ************************************** ******************** 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 EFTA_R1_00329365 EFTA01900500 This email and any files transmitted with it are confidential and intended solely for the person or entity to whom they are addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you have received this email in error please contact the sender and delete the material from any computer. Apollo Global Management, LLC EFTA_R1_00329366 EFTA01900501