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To: jeeyacation©gmail.com[[email protected]]; Jeffrey Epstein[[email protected]] Cc: Eileen Alexanderson Fran: Ada Clapp Sent: Wed 4/10/2013 9:17:44 PM Subject: Fwd: Apollo Fund IV Jeffrey, FYI--we are still hunting this Jabberwocky, lest you think we had given up. :-) Ada Clapp Black Family Partners Go 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. Begin forwarded message: From: "Vine, Stephen" Subject: RE: Apollo Fund IV Date: April 10, 201/ISMIS To: "'Ada Clappm < Cc: "Eileen Alexanderson" < >, "Fenn, Patrick" EFTA_R1_00499434 EFTA02002240 Dear Ada, Sorry for the delay. As I think you probably know, the limited partnership agreement of Management IV (as amended from time to time) has always included provisions that require the general partner (or, when there were two GPs, the managing general partner): 1) to make a capital contribution equal to the lesser of 1% of total capital contributions or $500,000, and 2) to receive allocations of at least 1% of net income or net loss. Both of these provisions ceased to be applicable to AIF IV Inc. when it ceased to be the sole general partner of Management IV. At that point, its contribution obligations and profit-sharing interests became fully discretionary. We do not have any records indicating whether AIF IV Inc. in fact made any capital contribution to Management IV, nor do we have any records indicating what allocations is actually received from Management IV. Stephen M. Vine Direct: +1 Internal: From: Ada Clapp [mailto Sent: Wednesday, April 10, 2013 1:29 PM To: Vine, Stephen Cc: Eileen Alexanderson; Fenn, Patrick Subject: Re: Apollo Fund IV Hi Steve, So sorry to be a nudge but there is some urgency to getting this pinned down. Would Patrick be better positioned to help us with this? Best regards, Ada Clapp Slack Family Partners do Apollo Management 9 W 57th Street New York NY 10019 r a maiel:MIE 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 EFTA_R1_00499435 EFTA02002241 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 Apr 8, 2013, at 8:41 AM, Ada Clapp < wrote: Hi Steve, Just checking in to see if you were able to find any documents or information for us on this question. Thanks and best regards. Ada Clapp Black Family Pacifiers cio 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 EFTA_R1_00499436 EFTA02002242 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 Apr 1, 2013, at 4:55 PM, "Vine, Stephen" < wrote: Hi, Ada. (It's nice to hear from you!) Sorry for not responding sooner. Would it be possible to speak tomorrow rather than today? Steve Stephen M. Vine Direct: Internal: From: Ada Clapp [mailto Sent: Monday, April 01, 2013 4:03 PM To: Vine, Stephen Cc: Eileen Alexanderson Subject: Re: Apollo Fund IV Hi Steve, Are you free to discuss this today? Ada Clapp Black Family Partners era Apollo Management 9 W 57th Street Nov York NY 10019 phon email. IRS Circular 230 Disclosure: EFTA_R1_00499437 EFTA02002243 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 Mar 29, 2013, at 2:39 PM, Ada Clapp < Hi Steve, > wrote: I hope that you arc well and remember me (I was your Trusts & Estates partner for all of 2007!). I am now with Lcon Black's family office. I understand that you were involved in the formation of Fund IV and may be able to help me piece together certain information needed in connection with Leon's personal planning. As you may know, back in 2007, simultaneously with Project Strong, Leon created Black Family Partners ("BFP" ). As part of the roll-up, all of Leon's family trusts and entities transferred their interests in all Apollo entities to BFP. One such entity was AIF Management Inc. ("Alf IV Inc."). What we arc trying to piece together is the economic value of what AIF IV Inc. contributed to BFP. As we understand it, AIF IV Inc. was originally the General Partner of Apollo Mangement IV LP ("Management IV") but on May 30, 2007, its GP interest was converted to a limited partnership interest (at which point, Apollo Management LP became the sole general partner of Mangement IV). AIF IV Inc. later transferred its LP interest in Mangement IV to BFP. EFTA_R1_00499438 EFTA02002244 What we don't know is what, if any, capital AIF IV Inc. contributed to Management IV in exchange for the originally issued GP interest (or what its economic interest in Mangement IV is). We also don't know whether AIF IV Inc.'s economic interest in Mangement IV changed upon conversion of its GP interest to an LP interest. I am assuming AIF IV Inc. either contributed capital to Management IV, or is allocated a pro rota portion of the management fees received by Mangement IV in respect of services, as it did receive distributions from Management IV. We need to sort out so we can pin down exactly what percentage of BFP is owned by AIF IV Inc. I would love to speak with you about this when you have a moment and to obtain from you the underlying documents indicating AIF IV Inc.'s economic interest in Mangement IV. I can be reached at the number below or at 347-304-0508 or you can email me a convenient time to call you. Best regards, Ada Clapp Black Family Partners cto 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. EFTA_R1_00499439 EFTA02002245 IRS Circular 230 Notice Requirement: This communication is not given in the form of a covered opinion, within the meaning of Circular 230 issued by the United States Secretary of the Treasury. Thus, we are required to inform you that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding United States federal tax penalties. In addition, any tax advice contained in this communication may not be used to promote, market or recommend a transaction to another party. The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e- mail, and delete the original message. IRS Circular 230 Notice Requirement: This communication is not given in the form of a covered opinion, within the meaning of Circular 230 issued by the United States Secretary of the Treasury. Thus, we are required to inform you that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding United States federal tax penalties. In addition, any tax advice contained in this communication may not be used to promote, market or recommend a transaction to another party. The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. EFTA_R1_00499440 EFTA02002246