EFTA02661310

From: jeffrey E. <[email protected]> Sent: Wednesday, February 8, 2017 12:22 AM To: Leon Black Subject: Fwd: Privileged and Confidential as you can see form paul weiss explanation - not min= . the numbers are NOT the same , nor is the reporting.. =A0 you are filing amended returns . different set of instructi=ns and rules.. Apollo never filed you are filing delinquent return=. different rules. appollo never filed. you are filing =or constructive, ownership. or indirect. . black family=partners for ex. apollo never filed. After seeing the =irst 40 pages. the facts and info are new to me Il=. the filings by torn are flawed. sorry. =A0 Forwarded me=sa:e From: Grieve, Brian S= Date: Tue, Feb 7, 2017 at 8:07 PM Subject: =E: Privileged and Confidential To: Brad Wechsler href="mailtoieevacation mail.com">'eevacation mail.com> Cc= "Okun, Brad R' >, Jeffrey Epstein c<= Brad as previously mentioned, we don't feel that statement is tech=ically accurate. The numbers on the forms filed by Apollo entities would b= different than the numbers on the forms filed by Leon because they own di=ferent percentages of the various underlying foreign entities. Also we know Apollo did not themselves file all required=forms, e.g. 5471s, for certain years so there would need to be a carveback=for that. I think the sentence I proposed earlier today is probably the be=t we can do on this particular point given the facts that exist. Or perhaps we can say "substantiall= similar to" rather than "essentially the same" if Apollo i= comfortable with that statement. Brian S. Grieve I Associate Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York. NY 10019-6064 From: =Brad Wechsler Sent: Tuesday, February 7, 2017 6:31:35 PM To: Grieve, Brian 5; Jeffrey Epstein Cc: Okun, Brad R Subject: Privileged and Confidential > Brianneffrey-cld both of you =ive with the following language at the end of the second paragraph of the =ackground Section: EFTA_R1_01909514 EFTA02661310 "Finally, the information in the International Information Returns pre=iously filed by the Apollo entities is essentially the same as the informa=ion included in the applicable International Information Returns being fil=d today by the Taxpayers." If the two of you sign-off I will run by Apollo legal and tax for final con=irmation. Sent from my Verizon Wireless BlackBerry This message is intended only fo= the use of the Addressee and may contain information that is privileged a=d confidential. If you are not the intended recipient, you are hereby not=fied that any dissemination of this communication is strictly prohibited. =If you have received this communication in error, please erase all copies =f the message and its attachments and notify us immediately.=/p> =AO please note The information contained in this commu=ication is confidential, may be attorney-client privileged, may cons=itute inside information, and is intended only for the use of the addre=see. It is the property of JEE Unauthorized use, disclosure or copyi=g of this communication or any part thereof is strictly prohibited a=d may be unlawful. If you have received this communication in error, pl=ase notify us immediately by return e-mail or by e-mail to [email protected], a=d destroy this communication and all copies thereof, including all a=tachments. copyright -all rights reserved 2 EFTA_R1_01909515 EFTA02661311