EFTA Document EFTA01759855

From: Kirschner, Elyse Sent: Friday, April 26, 2013 6:17 PM To: Jeffrey Epstein Subject: RE: Re: We drafte= the partnership agreement, but Akin Gump was heavily involved as well.&nb=p; They prepared that transfer instrument I just sent you. Interestingly, AIF IV Management, Inc. was added as a=partner at the last minute. The unsigned Word version of the partner=hip agreement I have on my firm's network does not have AIF IV Management =isted as a partner. But the signed copy does. I tried to reach out to Wendy Dulman, who was at Akin Gump a= the time this partnership was formed, to see if she has any recollection =f this issue with AIF IV Management. She said she didn't remember. If AIF IV Management had an economic interest =n the underlying fund at the time the partnership was created, it may have=been decided to add AIF IV as a partner at the last minute to avoid sectio= 2701 concerns. That's why I want to see a copy of the partnership a=reement of Apollo IV Management LP. Ada and Eileen are trying to loc=te it for me. =/o:p> Elyse G. Kirschner = Partner McDermott Will & Emery LLP I 340 Madison Avenue, Ne= York, NY 10173 +www.mwe.com From: </=pan> Sent: Friday, A=ril 26, 2013 2:07 PM To: Kirschner, Elyse Subject: Re:=Re: <=iv> did it have value„ a capital account =tc, did you set up the partnership? &=bsp; On Fri, Apr 26, 2013 at 2:03 PM, K=rschner, Elyse «mailto > wrote: EFTA_R1_00063851 EFTA01759855 I =on't think that the 1988 trusts were grantor trusts. =p class=MsoNormal style='mso-margin-top-alt:auto;mso-margin-bottom-alt=auto'> Elyse G. Kirschner I Partner McDermott Will & Emery LLP I 340 Madison=Avenue, New York, NY 10173 +<mailto: <=span>www.mwe.com</=> +<http://www.mwe.com> =p class=MsoNormal style='mso-margin-top-alt:auto;mso-margin-bottom-alt=auto'> Jeffrey Epstein [mailto:[email protected] <mailto:[email protected]> Sent: Friday, Apri= 26, 2013 2:01 PM To: Kirschner, Elyse Subject: Re: Am i corre=t to think that all other partners would be lean for income tax purposes a=d therefore not a true partnership? On Fri, Apr 26, 2013 at 1:56 PM Kirschner, Elyse <=a href="mailto target="_blank' <=a» wrote: I don't recall that be=ng the reason. I found the attached document (page A-3). It=shows that AIF IV Management, Inc. transferred an interest in Apollo Manag=ment IV, LP to BFP when BFP was formed. I've asked Ada to see a copy=of the LP agreement for Apollo Management IV. We'd like to see who t=e other partners of Apollo Management IV were. =/o:p> Elyse G. =irschner I Partner McDermott Will & Emery LLP 1=340 Madison Avenue, New York, NY 10173 =pan +style=lont-size:10.0pt;font-family:"Arial","sans-serif";colortlue1= I +www.mwe.com<=span> <http://www.mwe.com> <=iv style='border:none;border-top:solid #B5C4DF 1.0pt;padding:3.0pt 0in 0=n 0in'> 2 EFTA_R1_00063852 EFTA01759856 From: Jeffrey Epstein (mailto:[email protected] <mailto:jeevacation@gm=il.com> Sent: Frid=y, April 26, 2013 1:28 PM To: Kirschner, Elyse Subject: is it=possible that the only reason that ap iv ltd was added as an Ip. was to ma=e sure that all entities were not disregarded for tax purposes, and =hat a partnership requires at least two entites,? ? even thoug= it is a sub s, for Ip purposes i believe it qualfires as a non disregard=d entity, any memories? r•rr The information contained in this communication is confidential= may be attorney-client privileged, may constitute inside information, =nd is intended only for the use of the addressee. It is the property of=br>Jeffrey Epstein Unauthorized use, disclosure or copying of this =ommunication or any part thereof is strictly prohibited and may be unla=ful. If you have received this communication in error, please notify us=immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy =his communication and all copies thereof, including all attachments. co=yright -all rights reserved IRS Circular 230 Disclosure: To comply with requirements imp=sed by the IRS, we inform you that any U.S. federal tax advice contained h=rein (including any attachments), unless specifically stated otherwise, is=not intended or written to be used, and cannot be used, for the purposes o= (i) avoiding penalties under the Internal Revenue Code or (ii) promoting,=marketing or recommending to another party any transaction or matter herei=. This message is a PRIVILEGED AND CONFIDENTIAL communicat=on. This message and all attachments are a private communication sent by a=law firm and may be confidential or protected by privilege. If you are not=the intended recipient, you are hereby notified that any disclosure, copyi=g, distribution or use of the information contained in or attached to this=message is strictly prohibited. Please notify the sender of the delivery e=ror by replying to this message, and then delete it from your system. Than= you. Please visit http://www.mwe.com/ for m=re information about our Firm. The information contained in this communication is con=idential, may be attorney-client privileged, may constitute inside info=mation, and is intended only for the use of the addressee. It is the pr=perty of Jeffrey Epstein Unauthorized use, disclosure or copying of=this communication or any part thereof is strictly prohibited and ma= be unlawful. If you have received this communication in error, please =otify us immediately by return e-mail or by e-mail to [email protected], and 3 EFTA_R1_00063853 EFTA01759857 including all attach=ents. copyright -all rights reserved The information contained in this =ommunication is confidential, may be attorney-client privileged, may the use of the =ddressee. It is the property of Jeffrey Epstein Unauthorized use, d=sclosure or copying of this communication or any part thereof is strict=y prohibited and may be unlawful. If you have received this communic=tion in error, please notify us immediately by return e-mail or by e-ma=l to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof,<=r>including all attachments. copyright -all rights reserved =/div> 4 EFTA_R1_00063854 EFTA01759858