EFTA02350541

From: Heather Gray Sent: Thursday, May 7, 2015 425 PM To: Melanie Spinella Cc: Jeffrey Epstein ([email protected]); Brad Wechsler Subject: time sensitive question on Calder 1031 exchange Dear Melanie, Will you please pass this message along to Leon?&nbs=; Thank you! Heather Dear Leon, I would like to briefly call to your attention a que=tion on the 1031 exchange of the Calder. We need to choose an exchange agent to be the middle=an on the exchange. We can either use an art dealer as exchange agen= or a non-art exchange agent such as one of the companies set up to do rea= estate 1031 exchanges (for example, Chicago Deferred Exchange Company). The advantage of using an art dealer is that you can=reduce or possibly eliminate the sales tax you have to pay on the art that=you buy as part of the exchange, by taking advantage of the trade-in credi= available to art dealers. The disadvantage is that you have to tell the dealer the terms of your deal with Christie&11=217;s and of the new art purchased in the exchange. Brad and I discu=sed this issue and he feels, on balance, that the financial risk/reward ma=es it worth using an art dealer as exchange agent. In order to use an art dealer, you need to choose a =eater in New York and ask them to act as exchange agent. It could be=Pace or a dealer like Bob Mnuchin or David Zwirner. It cannot =e a dealer with whom you have done business in the past two years, so it cannot be Gagosian, Acquavella, Matthew Marks or Sub=ime. A dealer is most likely to agree to act as your e=change agent if you call them yourself. EFTA_R1_01327999 EFTA02350541 We need to have the paperwork in place before the sa=e on Monday night, so ideally the dealer would be selected today. Ar= dealers usually receive a fee for acting as exchange agent. I have =een fees ranging from $20,000 - $50,000. Questions: 1. &=bsp; Which art dealer would you like to use as your exch=nge agent? 2. &=bsp; How much will you be paying the dealer as a fee? Please let me know once you have spoken with the dea=er you select, and I will follow up with the dealer with all of the detail= and paperwork to put the exchange in place. Please let me know if you have any questions. = am in the office at Best, Heather Heather Gray Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 2 EFTA_R1_01328000 EFTA02350542