EFTA02382934.pdf

From: Heather Gray < Sent: Monday, April 27, 2015 6:31 PM To: Jeffrey Epstein ([email protected]) Cc: Brad Wechsler Subject: Dante - kids' trusts Hi Jeffrey, With respect to the purchase of the Dante by the kid=' trusts (Yggdrasil Trust, Rollo Tomasi Trust, Tron Trust and Gandal= Trust), I just mentioned to Brad that each child is the grantor of his or=her respective trust, so if the trusts purchase the Dante and then contribute their interests in the Dante to AP =arrows LP in exchange for limited partnership interests, AP Narrows will b= treated as a partnership for income tax purposes (not a pass-through enti=y). I'm not sure where you and Leon came out on th= question of whether you would prefer for AP Narrows to be a disregarded e=tity for income tax purposes or taxed as a partnership, so I just wanted t= flag this to you. Best, Heather Heather Gray Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 Direct Dial: Fax: Email: 1 EFTA_R1_01399156 EFTA02382934