EFTA02519175

From: Jeffrey Epstein <[email protected]> Sent: Monday, January 13, 2014 2:23 PM To: Ellen Harrison; Mortimer Zuckerman Subject: Re: M all understood, but i dont see it on sale. ? what is th= basis in the equity? If the debt were to be bought for roughtly the sa=e amount as the equity, . eventually , the debt would receive the prefe=rence giving the holder enough money to pay off the equity, . ( p=tential gain issues.? ) . I would thihnk an eventual bankruptcy . could=be a solution , after his death, On Mon,=Jan 13, 2014 at 10:20 AM, Ellen Harrison <[email protected]&g=; wrote: COD is first at the e=tity level but is allocable to Mort. As to when - many possib=lities. Substantial modification of debt, actual forgiveness, contribution=of the debt to the company, transfer of Mort's interest, to name a =ew. Sent from my iPhone On Jan 13, 2014, at 8:51 AM, Jeffrey =pstein <[email protected] <mailto:[email protected]» wrote: where and when is the COD? On Mon, Jan 13, 2014 at 9:25 AM, El=en Harrison < <mailto > wrote: On your question abou= Mort's basis in the notes, I checked with Brian and He said the notes=had not been written down so I gave you bad information. Sorry. In my opinion, your purchase of the receivables from Mo=t would not cure the COD issue we are worried about. Even if the sale gene=ated a capital loss, that would not offset ordinary income from COD. Howev=r, we will continue to explore this along with other ideas My partner is working on an accounting for the 1983 and=1996 trusts. She is still getting data. This has been in process for le=s than a month. I expect that it will be some time before it is done becau=e I am told that the records prior to 2000 are limited. SRR is appraising R&R. We are hoping, of course, th=t the cash flow will be sufficient to cover the preference. Since we don&#=9;t have the appraisal or the preference yet we don't know whether thi= will be a EFTA_R1_01655230 EFTA02519175 problem. If it is, I would use debt to reduce value so cash f=ow would cover the preference. This is a problem under section 2701, becau=e the common has to equal 10% of enterprise value before debt, but we will=figure it out. Sent from my iPhone On Jan 13, 2014, at 7:19 AM, Jef=rey Epstein «mailto:[email protected]» wrote: EH you told me that morts basis in the 12 perce=t notes had been written down, can you explain, . can you tell me=the status of the trust accounting to date. ? you stated that Rand R=A0 was being valued, and planned to put it in a preferred partnership. = what is the plan if the cashflow is not enough to pay the preferred. ?= On Sun,=Jan 12, 2014 at 2:30 PM, Ellen Harrison < >= wrote: > Hello > I just left you a voicemail. I would like to speak with you briefly ab=ut the terms of the deal you proposed to MZ so that we can give it appr=priate analysis. Could you please give me a call at 301- 404-4736 <tel:301-404=4736> or reply t= this email as soon as possible? We are trying to schedule a conference=call with tax advisors on Monday between 10 and 12 and it would be very he=pful to have your proposal in hand by then. > Thanks and Happy New Year. > Sent from my iPhone The information contained in this c=mmunication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the a=dressee. It is the property of Jeffrey Epstein Unauthorized use, di=closure or copying of this communication or any part thereof is strictl= prohibited and may be unlawful. If you have received this communication in error, p=ease notify us immediately by return e-mail or by e-mail to [email protected], =nd destroy this communication and all copies thereof, including all attachm=nts. copyright -all rights reserved 2 EFTA_R1_01655231 EFTA02519176 The inform=tion contained in this communication is confidential, may be attorney-c=ient privileged, may constitute inside information, and is intended only for the use of the a=dressee. It is the property of Jeffrey Epstein Unauthorized use, di=dosure or copying of this communication or any part thereof is strictl= prohibited and may be unlawful. If you have received this communication in error, p=ease notify us immediately by return e-mail or by e-mail to [email protected], =nd destroy this communication and all copies thereof, including all attachm=nts. copyright -all rights reserved The inform=tion contained in this communication is confidential, may be attorney-c=ient privileged, may constitute inside information, and is intended only for the use of the a=dressee. It is the property of Jeffrey Epstein Unauthorized use, di=closure or copying of this communication or any part thereof is strictl= prohibited and may be unlawful. If you have received this communication in error, p=ease notify us immediately by return e-mail or by e-mail to [email protected], =nd destroy this communication and all copies thereof, including all attachm=nts. copyright -all rights reserved EFTA_R1_0 1655232 EFTA02519177