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

From: "Jeffrey E." <[email protected]> To: Eileen Alexanderson Subject: Re: Distribution to Ben Date: Tue, 22 Jul 2014 14:39:18 +0000 Ok On Tuesday, July 22, 2014, Eileen Alexanderson Just fyi we are going to pay interest instead of principal on the note. From: Ada Clapp Sent: Tuesday, July 22, 2014 9:41 AM To: Eileen Alexanderson Subject: FW: Distribution to Ben So—even the part about Ben getting the money outright?? Ada Clapp Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 Direct Dial: Fax: Email: wrote: 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. EFTA00994127 From: Jeffrey E. [mailto:[email protected] Sent: Tuesday, July 22, 2014 9:37 AM To: Ada Clapp Subject: Re: Distribution to Ben do it, no need to run by leon On Tue, Jul 22, 2014 at 9:35 AM, Ada Clapp =Ia. wrote: Jeffrey, Alan had a suggestion regarding the $10 million distribution. It works like this: • Leon would pay off $10 million of the APOI Note. • The APO1 Trust would then pay off $10 million of the Note it just gave to the BEB 2011 Trust to purchase a 25% interest in the LDB 2011 LLC (we can safely assume that the purchase price will exceed $10 million). • The BEB 2011 Trust would then distribute $10 million to Ben. • Ben would contribute the $10 million to his 2010 Trust and his 2010 Trust will use part of it to buy the apartment. • We do the same for each child's 2011 Trust as he or she turns age 30. If you think the above makes sense (takes care of 3 birds with one stone, really), I will run it by Leon. Also, will check with Leon that he is fine with Ben getting the $10 million outright, understanding that it will be Ben's decision to put the funds in Ben's 2010 Trust (of which Leon is a Trustee and Debra makes distribution decisions). Ben must get the distribution directly in order to avoid the possibility that Leon is treated as a grantor of Ben's 2010 trust (and risk estate inclusion) which might occur if the funds come directly from the APO I Trust to Ben's 2010 Trust. Ada Clapp Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 Direct Dial: EFTA00994128 Fax: Email: 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. 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 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 EFTA00994129