EFTA00668555.pdf

From: To: "Jeffrey Epstein" <jeevacationggmail.com> Subject: Fw: Heidi Holterbosch Date: Thu, 27 Dec 2012 20:39:37 +0000 Importance: Normal Sent via BlackBerry by AT&T From: "Zafirova, Elena" Date: Thu, 27 Dec 2012 21:26:01 +0100 To: West Phili Cc: ; Michaels, Mamin • Varma Amanda Pedvin Marnin Michaels< Subject: RE: Heid Dear Philip, Mr. Buck just called me back and to discuss the document attached in your email. ; Emailfiling, Pursuant to my conversation with Mr. Buck, it is my understanding that Heidi and Mr. Buck, during a number of calls, had the entire account liquidated today, meaning all gold was sold and it is ready to be "delivered" in cash tomorrow, on December 31. Further, the majority of the cash is now in US dollars. Due to Bank Frey's balance sheet and the administrative documentation involved in this process, Mr. Buck explained to me that Bank Frey is not be willing to have a 50+ million cash transfer in on December 31, which is why they would like to deposit the cash at another bank on the basis of the attached fiduciary agreement with Heidi. In other words, this is an "internal" transaction, there is no account in Heidi's name opened at any other bank. The cash is simply "deposited" at another bank until it is transferred to Bank Frey next week when there is more time for the administrative paperwork involved. To complete the transaction tomorrow, Mr. Buck informed me that he would need an executed copy of the fiduciary agreement by email scan or fax by tomorrow. Should you wish to discuss this with Mr. Buck tomorrow, he is available at io am Zurich time (5 am New York). If you do have the call, I will try to dial in as well, however, as I am driving to the mountains, it may be that I get cut off. Thank you and best regards, Elena Elena Zafirova Baker & McKenzie Zurich Direct: Tel: Fax: Mobile: Admitted to practice in New York (USA) and England & Wales - - - - - - - - - - - - - - - - Pursuant to requirements relating to practice before the Internal Revenue Service, any tax advice in this communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of (i) avoiding penalties imposed under the United States Internal Revenue Code. or (ii) promoting, marketing. or recommending to another person any tax-related matter. Baker & McKenzie Zurich is a member of Baker & McKenzie International. a Swiss verein. EFTA00668555 NOTICE: This e-mail may contain privileged and confidential information. It is intended (or the named recipients only. If you are not an intended recipient. please notify us immediately (by reply e-mail) and delete this e-mail from your system. My use or retransmission without proper authorisation is prohibited. You are cautioned that any communication over the Internet is not secure and may be intercepted by third parties. Please note that all incoming e-mails will be automatically scanned by an external service provider to eliminate unsolicited promotional e-mails. This could result in deletion of a legitimate e-mail before it is read by its intended recipient at our Finn. From: West, Philip [mailto: Sent: Donnersta 27. Dez_moer Luiz /.4IJ To: Cc: Heidi Holterbosch Elena; Varma, Amanda Pedvin Subject: Heidi Holterbosch ; Michaels, Marnin; Alan S. Halperin 1 ); Zafirova, Heidi sent me the attached form for review. It appears to be an authorization for Frey to open a time deposit account for Heidi's benefit outside Switzerland. You discussed with her a "Fiduciary Call Deposit," which perhaps is a demand deposit account, but the form describes time deposits. Is there another form that relates to a demand deposit account instead of a time deposit account? More fundamentally, do you need to open such an account to facilitate the currency conversion because Frey itself cannot open a dollar account for its customers? If so, I assume you can still sell the gold irrespective of whether this account is opened (or already have done so)? Finally, would it not eliminate the need for this Fiduciary account if you simply wired the proceeds to a dollar account of Heidi's here in the U.S. (less $1 million, which she would keep in a Swiss franc account at Frey)? It may be helpful to discuss this on a conference call. If you can do so, Heidi and I would join a call with you at 9 am your time to discuss this. Please dial in using the following information. Thank you. Dial-in: International dial-in: Participant pass code: Security Code: 9856 Philip R. West Partner Steptoe Steptoe & Johnson LLP nimem This message and any attached documents contain information from the law firm Steptoe & Johnson LLP that may be confidential andfor privileged. If you are not the intended recipient, please do not read. copy, distribute, or use this information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. EFTA00668556