EFTA Document EFTA01919995

To: Ada Clapp From: Jeffrey E. Sent Wed 7/2/2014 7:16:09 PM Subject: Re: Yes ask Leon On Wednesday, July 2, 2014, Ada Clapp sc > wrote: Herrick will begin working on the joint purchase agreement (they have to get RL to waive the conflict first but they did not anticipate that being a problem). They need answers on the first two questions (noted below) and 2 more questions: 1. Did LOB purchase the painting at the Christie's Auction so that he is the buyer of record and RL is purchasing the 50% interst from LOB—or will they have Christie's change the buyer of record so that each of LDB and RL is purchasing a 50% interest in the painting directly from Christie's? 2. When does the work have to be paid for (as in—when do you need the contract signed)? Is it 30 days from auction date? Do you want me to address these questions to Melanie/Leon? From: Ada Clapp Sent: Wednesday, July 02, 2014 12:11 PM To: Jeffrey E. Cc: Eileen Alexanderson Subject: RE: Re: Two questions: 1. Who gets to the Schwitters for first two year holding period—Ronald or Leon? 2. Who will be the purchaser-Leon or Narrows? I assume Leon as he is giving the right to purchase on his death. Correct? Ada Clapp EFTA_R1_00362868 EFTA01919995 Elysium Management LLC Direct Dial: 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. From: jeffrey E. [email protected]] Sent: Wednesday, July 02, 2014 11:09 AM To: Ada Clapp Subject: Re: Good idea On Wednesday, July 2, 2014, Ada Clapp < > wrote: Regarding the joint purchase agreement: Diana W. at Withers is on vacation but said that her associate could draft the agreement in her absence and that she would look it over. To be honest, I am not impressed with Diana and imagine I will be even less impressed with her associate. As you may know, Barry and I interviewed Frank Lord and Herrick Feinstein's Art Law group. We were impressed with them and they have done work for Leon in the past (isolated provenance issues I am told). The concept would be that Herrick represents Leon and the Trusts as a group so long as there are no conflicts. This would be a good project to give them to "kick their tires". Leon agreed to meet them but wanted to speak to Diana H. first (Diana H. made the original Herrick introduction to Charles Goldstein of that firm—I understand that Charles has done some work for Ronald by the way). What do you think? EFTA_R1_00362869 EFTA01919996 Ada Clapp Elysium Management LLC Direct Dial: 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. From: jeffrey E. (mailto:[email protected]] Sent: Wednesday, July 02, 2014 8:15 AM To: Ada Clapp; Richard Joslin; Eileen Alexanderson; Melanie Spinella Subject: Re: its a third party, not related, we can discuss, after 5 months ( look back ) the painting is gone and valued at sale price , or not. -- more importantly I want to form a new narrows partnership. narrows. Icon and children trust . trust should have own counsel. paintings will be deliniated . leon can use art without rent. no distribuiton as there is no income to partnership , partnership discount on death. . commitces inside general partner, make decisions . fully negotiated with trustees and carefully drafted agreement. also sets up sucessor etc. very elegant . insurance will be in name of partnership. paintings can be carefully exchanged inside and or distributed out . etc. On Wed, Jul 2, 2014 at 8:00 AM, Ada Clapp wrote: EFTA_R1_00362870 EFTA01919997 I don't think it is so simple have the contract price set the estate tax value. As with buy sell agreements there are a few hoops to jump through before the Service recognizes the contract price as the estate tax value of the asset being acquired Sent from my iPad On Jul 2, 2014, at 6:44 AM, "jeffrey E." [email protected]> wrote: single life. for house. , painting woudl be valued by contract price, as fair market is third party buyer with all the info 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 EFTA_R1_00362871 EFTA01919998 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 ice\ acat ion ;)gnisfl&om, 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 EFTA_R1_00362872 EFTA01919999