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

From: "jeffrey E." <[email protected]> To: Ada Clapp <1 Subject: Re: FW: Split Interest Purchase Date: Fri, 06 Jun 2014 16:28:59 +0000 he can send On Fri, Jun 6, 2014 at 10:23 AM, Ada Clapp • > wrote: Hi Jeffrey, Attached are the slides Alan prepared to describe the townhouse purchase to Leon. Do you want him to send this directly to Leon or shall you or I simply forward to Leon? Ada Clapp Elysium Management LLC IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax advice contained in this communication (including attachments) is not intended or written to be used, and cannot be used, by any person or entity for the purposes of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) proposing, marketing or recommending to another party any transaction or matter discussed herein. I advise you to consult with an independent tax advisor on your particular tax circumstances. This communication and any attachment is for the intended recipient(s) only and may contain information that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemination of this communication and its attachments is prohibited. Please delete all copies of this communication and its attachments and notify me immediately that you have received them in error. Thank you. EFTA00990883 From: Halperin, Alan S [mailto Sent: Friday, June 06, 2014 10:24 AM To: Ada Clapp Cc: Hurtado, Christopher L Subject: Split Interest Purchase Here is a brief summary of the planning strategy. Best. Alan 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 Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 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. 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 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 [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00990884