EFTA00646198.pdf

From: Melanie Spinella To: 'Jeffrey Epstein' <jeeyacation@gmail.com> Subject: FW: FW: Ownership of the plane Date: Tue, 28 May 2013 20:04:12 +0000 From: Mandel, Michael [mailto Sent: Tuesday, May 28, 2013 4:03 PM To: Lisa Graziano Cc: Melanie Spinella Subject: RE: FW: Ownership of the plane The short answer is Leon (and Debra). In order to attempt a tax-free exchange of the new aircraft for the old aircraft, an attempt that was unsuccessful because a buyer for the old aircraft could not be located in time, additional organizational layers were required. But as a result of various indemnities and guarantees, the Blacks are ultimately responsible for the financing, maintenance and operational costs of the aircraft. In situations where Apollo charters the aircraft for Leon's business use, Apollo pays charter fees that should more than offset the overall operating costs (fuel, pilots, landing fees, catering costs, etc.). The hourly costs of personal travel are passed back to Leon (as one of the two members of the "operator" of the aircraft, Avioneta Holdings). Hope that answers Jeffrey's question. If not, happy to talk through these issues with him. Michael S. Mandel DI eCt : From: Lisa Graziano [mallto: Sent: Tuesday, May 28, 2013 3:11 PM To: Mandel, Michael Cc: Melanie Spinella Subject: FW: FW: Ownership of the plane Michael, Could you get back to Melanie regarding Jeffrey's question? Thanks, Lisa Lisa Graziano I Apollo Investment Corporation Executive Assistant to John Hannan and Andy Africk EFTA00646198 From: Jeffrey Epstein [mailtoleevacSg i mail com Sent: Tuesday, May 28, 2013 2:42 PM To: Melanie Spinella Subject: Re: FW: Ownership of the plane ask them what and why leon pays for On Tue, May 28, 2013 at 2:03 PM, Melanie Spinella > wrote: Ownership of the plane From: Lisa Graziano Sent: Tuesday, May 28, 2013 2:02 PM To: Melanie Spinella Subject: Ownership of the plane Ok, straight from Michael Mandel, here is the not-so-straightforward ownership breakdown: Owner - Rance Acquisitions, LLC Sole Member of the Owner - Wells Fargo Bank Northwest, Owner Trustee of the N624N Trust Beneficiary of the Thust — Avioneta Holdings LLC Members ofAvioneta Holdings LLC - Leon (5o.z%) & Debra Black(49.9%) Operator ofAircraft - Avioneta Holdings LLC Hope this helps Lisa Graziano I Apollo Investment Corporation Executive Assistant to John Hannan and Andy Africk 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. 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 EFTA00646199 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 EFTA00646200