EFTA00872701.pdf

From: Jeffrey Epstein <jeevacation®gmail.com> To: Melanie Spinella Subject: Fwd: Sales Tax Call Date: Thu, 19 Sep 2013 15:19:37 +0000 Attachments: DRAFT--Avisory_Opinion_Petition.pdf please forward this to lean i don't get it Forwarded message From: Ada Clapp <I Date: Thu, Sep 19, 2013 at 11:10 AM Subject: Re: Sales Tax Call To: Alan S Halperin Cc: Jeffre E stein <jeevacation@gntn> "Ms. Eileen Alexanderson" , Richard J Bronstein Christopher L Hurtado Thank you for organizing the call. I have attached a first draft for discussion purposes of a prosed Petition for Advisory Opinion with the following caveats: My in-house research resources are very limited and accordingly, I am unable to confirm that the cases cited in the attached draft are still "good law" or whether there are more pertinent or recent cases out there. I also do not have access to recent editions of secondary sources such as the Calamari & Perillo, Corbin or Williston hornbooks on contracts or Black's Law Dictionary, each of which likely has a helpful definition of "consideration" that could be incorporated into the Petition. Paul Weiss can perhaps fill these gaps. Ideally, more time should be spent to develop a stronger argument in support of the conclusion we are seeking in such an important case of first impression. I am hoping we can discuss this on our call later. Best regards, Ada Clapp Black Family Partners do Apollo Management 9 W 57th Street New York NY 10019 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. EFTA00872701 On Sep 19, 2013, at 8:51 AM, "Alan S Halperin" > wrote: Let's speak today, at 5:15. Let's use the following call in details: ; from an international location dial • Enter the Conference ID then press #. 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, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York. NY 10019-6064 (Direct Phone (Direct Fax) 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 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 EFTA00872702 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 EFTA00872703