From: Jeffrey Epstein <jeevacation@gmail.com>

From: Jeffrey Epstein <jeevacation@gmail.com> To: Melanie Spinella Subject: Re: FW: Leon Black Children-use of Gift and GST tax exemptions Date: Fri, 14 Dec 2012 18:58:25 +0000 Yes please On Friday, December 14, 2012, Melanie Spinella wrote: Jeffrey - do you want me to print this for Leon -r? From: Jeffrey Epstein [mailtoleevacationegmail.com] Sent: Friday, December 14, 2012 1:23 PM To: Melanie Spinella Subject: Fwd: FW: Leon Black Children-use of Gift and GST tax exemptions Forwarded message From: Eileen Alexanderson Date: Fri, Dec 14, 2012 at 1:21 PM Subject: FW: Leon Black Children-use of Gift and GST tax exemptions To: Jeffrey Epstein <jeevacation@gmail.com> Are you good with this as a plan? From: Clapp, Ada [mailto: Sent: Friday, December 14, 2012 1:09 PM To: Kirschner, Elyse; Eileen Alexanderson Subject: RE: Leon Black Children-use of Gift and GST tax exemptions Hi Eileen and Elyse, Thanks for the email, Elyse. I know how pressed you are with year end planning. Eileen should confirm but my understanding is that the children do not have $5 million of assets in their own names (Ben has the IOU from the 1992 Trust and Josh could get one too I suppose). Given that fact, it sounds like McDermott is not recommending the LLC (so we do not need to discuss it). Please correct me if I am wrong but it sounds like you EFTA00949944 are advising that distributions be made from existing non-GST exempt trusts so that the children can re-gift and allocate GST exemption to new trusts this year. Does it make sense to have the 2011 Trust give Josh a note for the payment it was planning to make before the decanting and to have Ben and Josh transfer their notes (up to the exemption amount) to new trusts? The other two children could receive a $5 million distribution from their 2011 Trusts (which are not GST exempt-correct?) so they can transfer to new trusts and allocate GST exemption. That treats the children somewhat equally and uses the smallest portion of assets that are already estate tax exempt. What do you think? Time is getting a bit tight. Would it make sense for the three of us to have a cal 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 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 jea@gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00949945