EFTA Document EFTA01895935

To: Jeffrey Epsteinueeyacation mail.com Cc: Eileen Alexanderso From: Ada Clapp Sent: Mon 4/1/2013 2:14:50 PM Subject: Re: Yes--my understanding is that BFP has always been owned by (i) Lcon, (ii) entities wholly owned by Leon (or by Leon and trusts that arc grantor trusts as to Leon) and (iii) trusts which arc grantor trust for income tax purposes as to Leon. Ada Clapp Black Family Partners phone email 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 purpose of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) promoting, 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. On Apr I, 2013, at 9:59 AM, Jeffrey Epstein lecvacationagmail.com> wrote: does this mean that bfp is a disregarded entity for income tax purposes. On Mon, Apr I, 2013 at 9:56 AM, Ada Clapp Hi Jeffrey, wrote: PROT4 PROT0 I confirmed with Eileen this morning t that the children do not own any shares of Black Family Partners other than through their interests as beneficiaries of trusts that own BFP. Best regards, Ada Clapp Black Family Partners t phone email: 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 purpose of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) promoting, 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. On Mar 31, 2013, at 6:04 AM, Jeffrey Epstein <[email protected]> wrote: 4Q2012 Income LBF Holdings#1 Account 2006 Black COF distCOF* LBF #1 Interest Income s- s- PROT5 PROT1 FamilyTrust Black Family Partners Apollo 4Q BFP %Interest CoInv Interest VI Apollo CoInv BRH n piv SWF addl BRH pay 4Q10 Total 12/31/12 2006 Trust/LBF Holdings 70.3330% S- [repeated 4 times] 2006 Trust 1.8390% S- [repeated 3 times] Judah 2009 Trust 9.0310% S- [repeated 3 times] Black Family '97 Trust 4.5500% S- LDB 2011 LLC 7.0010% S- [repeated 4 times] Leon Black Individual 7.2460% S- S- 100.0000% S- how many shares do the kids currently own S- The information contained in this communication is confidential, may be attorney-client privileged, may PROT6 PROT2 constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein 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 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 Jeffrey Epstein 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 jeevacationAgmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved PROT7 PROT3