EFTA01968117

To: Jeffrey [email protected]] From: Ada Clapp Sent Mon 7/8/2013 7:24:40 PM Subject Re: Leon's Will and Rev. Trust. Hi Jeffrey, If Debra survives Leon, my notes indicate that Leon wanted Debra to give Judy about $1 million per year for living expenses. The trust for Judy only gets created on the death of the survivor of Leon and Debra (when neither of them is there to take care of her). Leon does not own Phaidon (it is owned indirectly by the 1997 Trust) so it would not pass under his Will or Revocable Trust. I had Paul Weiss define "Art Entity" as an entity formed for the primary business purpose of holding art. That way, the term would not indadvertedly capture a closely held entity that happens to own art but has some other purposes as its primary business. Should Leon every own a part of Phaidon directly, that should not fall into the definition of Art Entity as it was formed for purposes of publishing books, etc., as its primary business. Ada Clapp Black Family Partners cto Apollo Pianagoment 9 W 571h Street New York NY 10019 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. On Jul 8, 2013, at 2:46 PM, Jeffrey Epstein leevacation@gmail,com> wrote: EFTA_R1_00447613 EFTA01968117 I thought we shold merely pay Judy 500k per year, . from trust, is phaidon an art holding co? On Mon, Jul 8, 2013 at 1:56 PM, Ada Clapp <ada.clavvagniail.com> wrote: Hi Jeffrey, I hope that you arc well. Attached for your review are (i) a detailed summary of the draft 2013 Will and Revocable Trust prepared by Paul Weiss, (ii) a bullet point summary of the documents and (iii) a schematic illustrating the flow of assets under the proposed documents. I will send you the Paul Weiss drafts by separate email. Please let me know which of the summaries you would like for me to send to Leon. I think he will want to have a meeting so I can walk him through the drafts and help him focus on the open decisions. Best regards, Ada Clapp Black Family Partners Co Apollo Management 9 W 57th Street New York NY 10019 phone: 9_17-054515 email: aclatlapp@emaacom 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. EFTA_R1_00447614 EFTA01968118 *********************************************************** 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_00447815 EFTA01968119