DS9 Document EFTA00651634

From: To: Subject: Date: Attachments: Eileen Alexanderson "Jeffrey Epstein ([email protected])" <[email protected]> FW: APO2 Trust Fri, 25 Oct 2013 20:40:41 +0000 8 86490I-v5- BLACK,LEON APO2 Trust_for_1997_Trust decanting_(NY,_AH„spouse as a_benefici ary,_pot trust_an—d_cont;uing_trusts).doc; ATTZ0001..htm; Change-Pro_Redcine—_- 88649fil -v4- TILACK,LEON APO2 Trust_for_1997 Trust decanting_(NY,AH,spouse_as_a_benefici ary,_pot_trust_an—d_cont;uing_trusts)_anTdoc; ATT00002..htm From: Ma Clapp Nab:, Sent: Friday, October 25, 2013 4:39 PM To: Eileen Alexanderson Subject: Fwd: APO2 Trust This is the kind of stuff that made it amateur hour. Begin forwarded message: From: "Jessica Soojian" Subject: Fw: APO2 Trust Date: October 22, 2013 8:36:25 PM EDT To: Cc: "Alan S Halperin" Hi Ada—Apologies for the confusion. Please review these attached drafts, not what I sent at 7:51 (please ignore). Alan and I discussed, and decided that we could include the exoneration provision since it fell within the confines of 10-6.6. Thanks very much. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. Click Here for More Information Jessica D. Soojian I Associate Paul, Weiss. Rificind, Wharton & Garrison LLP the Americas I 019-6064 Direct Phone) (Direct Fax) I WIAV Forwarded by Jessica Soojian/PaulWeiss on 10/22/2013 08:32 PM -- From: Jessica Soojian/PaulWeiss EFTA00651634 To: Cc: Alan S Hatpenn/PautWeiss@PaulWeiss Date: 10122/2013 07:51 PM Subject: APO2 Trust Hi Ada—I am attaching another revised draft of the APO2 Trust which incorporates one mare revision. Specifically, in preparing the decanting documents for the 1997 Trust, it occurred to me that, in light of the Trust's silence with regard to liability/exoneration, any inclusion of this language in the APO2 Trust would violate 10-6.6. Accordingly, the relevant Clause has been removed. Thanks very much, Jess IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. Click Here for More Information Jessica D. Soojian I Associate Paul, Weiss, Rifkind, Wharton 8. Garrison LLP the Americas I 19-6064 (Direct Phone) irect Fax) This message is intended only for the use of the Addressee and may contain information that is privileged and confidential. If you are not the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, please erase all copies of the message and its attachments and notify us immediately. This email and any files transmitted with it are confidential and intended solely for the person or entity to whom they are addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you have received this email in error please contact the sender and delete the material from any computer. Apollo Global Management, LLC EFTA00651635