EFTA Document EFTA01915116

To: Eileen Alexanderson Cc: Jeffrey Epstein[[email protected]] From: Clapp, Ada Sent: Thur 12/6/2012 4:53:57 PM Subject: RE: Private Operating Foundation Memorandum Attached Thank you! Ada Clapp Managing Director, Wealth Strategist U.S. Trust Bank of America Private Wealth Management 114 West 47th Street New York, New York 10036 Phone: Fax: Email: IRS CircWar 230 Disclosure: Pursuant to IRS regulations, we inform you that any tax advice contained in this communication (including any 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 agency, or (ii) promoting, marketing or recommending to another party any transaction or matter discussed herein. We advise you to consult with an independent tax advisor on your particular tax circumstances. From: Eileen Alexanderson [mailto Sent: Thursday, December 06, 2012 11:52 AM To: 'Jeffrey Epstein'; Clapp, Ada Subject: FW: Private Operating Foundation Memorandum Attached From: Wierbicki, Diana [mailto: Sent: Wednesday, December 05, 2012 5:38 PM To: Eileen Alexanderson; Melanie Spinella Cc: Lerner, Ralph Subject: Private Operating Foundation Memorandum Attached EFTA_R1_00354100 EFTA01915116 Dear Eileen and Melanie, Attached please find the private operating foundation memorandum that was requested. Please let us know if you have any questions. Kind regards, Diana Diana Wierbicki Withers Bergman LLP Phone: Fax: Withers Bergman LLP 430 Park Avenue, 10th Floor New York NY 10022-3505 Ti ' F: www.withersworldwide. corn New York, Greenwich, New Haven, London, Geneva, Zurich, Milan, Hong Kong, British Virgin Islands, Singapore IRS Required Statement: This document (and any attachments) was not intended or written to be used, and it cannot be used by the recipient, for the purpose of avoiding penalties that may be imposed on any taxpayer This email (and any attachments) is confidential and may also be legally privileged. If you are not the intended recipient please immediately notify the sender then delete it from your system. You should not copy it or use it for any purpose nor disclose its contents to any other person. EFTA_R1_00354101 EFTA01915117 This email and any files transmitted with it are confidential and intended solely for the person or entity to whom they are addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you have received this email in error please contact the sender and delete the material from any computer. Apollo Global Management, LLC This message, and any attachments, is %r the intended recipient(s) only, may contain information that is privileged, confidential and/or proprietary and subject to important terms and conditions available at http://www.bankofamerica.contfemaildisclaimer. If you are not the intended recipient, please delete this message. EFTA_R1_00354102 EFTA01915118