From: "jeffrey E." <[email protected]>

From: "jeffrey E." <[email protected]> To: Richard Joslin , Brad Wechsler Bcc: Melanie Spinella Subject: Re: we're calling the sales tax guy at 6:30 pm - I'll come to your office Date: Wed, 03 Jun 2015 10:05:03 +0000 >, Heather Gray sorry but this is emblematic of the silliness that appears to continue. 1. How can we ask for a legal opinion when it is crystal clear that we don't yet have accurate facts or numbers , f. 2 Invoices have not been reviewed! corporate structure is convoluted and unexplored in detail. ( was the boat captain on the call?) 3 Paul weiss is the attny , and should be charged with getting us info. . 4. Bringing in yet another outside lawyer without full vetting and consideration, a waste of time energy and money. . 5. ex. what is the location of charters shown on the invoice? do you know. . ? if th invoices are incorrect, does that give us any comfort in trying to defend an audit. . I saw three invoices only, and each had a different owner or address .. On Tue, Jun 2, 2015 at 9:15 PM, Richard Joslin wrote: Begin forwarded message: From: Brad Wechsler Date: June 2, 2015 at 7:49:41 PM EDT To: Heather Gray Cc: Richard Joslin Subject: Re: we're calling the sales tax guy at 6:30 pm - I'll conic to your office Reply-To: Brad Wechsler Excellent; rich you will let Jeffrey know, I assume. See u tomorrow. Sent from my Verizon Wireless BlackBerry From: Heather Gray < Date: Tue, 2 Jun 2015 23:17:26 +0000 To: Brad Wechsle Cc: Richard Joslin Subject: FW: we're calling the sales tax guy at 6:30 pm - I'll come to your office Just an FYI, Brad, the lawyer we spoke with is Richard Leavy at Sidley — he's he guy that Rick Bronstein recommended to us. I had spoken with him last week about sales tax on art and he seems very qualified. I spoke with him earlier today to have him send us an engagement letter and he mentioned that he also had experience with yachts and planes, so he seemed like the right person to speak with on the BJAV question. From: Richard Joslin Sent: Tuesday, June 02, 2015 7:07 PM EFTA00855330 To: Brad Wechsler Cc: Heather Gray Subject: RE: we're calling the sales tax guy at 6:30 pm - I'll come to your office We consulted state and local tax attorney re sales tax and NYS/C income tax re BJAV. Conclusion: zero risk of NYS sales tax on charter or transportation services conducted outside the US despite the NYC presence, eg bill pay personnel, NY address on invoices, director (EA). Conclusion: income from charter/ transportation services would not be sourced to US, nor sourced to NYS or NYC despite the NYC presence, eg bill pay personnel, NY address on invoices, director (EA) . From: Heather Gray Sent: Tuesday, June 02, 2015 6:14 PM To: Richard Joslin Subject: we're calling the sales tax guy at 6:30 pm - I'll come to your office Heather Gray Elysium Management LLC 445 Park Avenue Suite 14o1 New York, New York 10022 Direct Dial: Fax: Email: please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE EFTA00855331 Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation®gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00855332