EFTA Document EFTA01970107

To: Fenn, Patrick From: Jeffrey Epstein Sent Mon 5/27/2013 1:13:50 AM Subject: Re: yes, but they were unaware of the size of the termination payment. they didn;t want to be on the hook, but a guarantee to them by virute of the tra payments might have traction. On Sun, May 26, 2013 at 7:45 PM, Fcnn, Patrick wrote: We had proposed and vetted a fresh loan and personal guarantees from the boys as a means of deferring the recognition of the Tufts gain on exchanges and extending amortization of the existing loan. That does have an impact on TRA which would require amending the TRA (which should be addressed in any event). There is deferral in that approach for TRA payments on the Tufts gain (but not the economic gain on exchanges). The boys had determined that the benefits of deferring Tufts gain (as modelled in the spreadsheets I sent you sometime ago) were not sufficient to put them at risk on the personal guarantees. Of course that does not address the negative basis problem. From: Jeffrey Epstein [mailto:ieevacationOomail.com] Sent: Wednesday, May 22, 2013 06:08 AM To: Fenn, Patrick Subject: why not have a new entity borrow the billion, secured by some form of guarantee , letter of credit, in turn supported by the tra payments or termination agreement. py off the amh loan, somehow let the tra payments build without creating a taxable event for the boys, ten year later a billion dollars set aside, would be nice to keep it all in apollo or have them be the lender and the borrower. Why would you have to liquidate ? I know you are tied up . so no urgency. 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 jecvacation@gmail,com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA_R1_00451928 EFTA01970107 IRS Circular 230 Notice Requirement: This communication is not given in the form of a covered opinion, within the meaning of Circular 230 issued by the United States Secretary of the Treasury. Thus, we are required to inform you that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding United States federal tax penalties. In addition, any tax advice contained in this communication may not be used to promote, market or recommend a transaction to another party. The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. 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 pan 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 jeevacation@gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA_R1_00451929 EFTA01970108