EFTA00689499.pdf

From: Ada Clapp To: Jeffrey Epstein <jeevacation®gmail.com> Cc: Eileen Alexanderson Subject: Re: Personal Representatives for Agreement Among Principals. Date: Thu, 10 Oct 2013 13:49:05 +0000 What if the Designation named all the executors (Debra, Barry and Richard) and the Memorandum of Intention specified that in the event of disagreement among them as to who should fill the vacancy on the Executive Committee, Barry's decision shall control. It would not be binding but only an indication of Leon's intention that we hope Debra and Richard would respect. That would require no amendment to the Will. By the way--if we are doing the GRAT--I believe we will need to do a Codicil or Revised Will in any event (to make sure there is language included that permits any annuity payment made to Leon's estate to qualify for the marital deduction if Debra survives Leon) so we might as well add language for a tie-breaker that would be binding. Ada Clapp Black Family Partners do Apollo Management 9 W 57th Street New Y phone email: IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax advice contained in this communication (including attachments) is not intended or written to be used, and cannot be used by any person or entity for the purpose of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) promoting, marketing or recommending to another party any transaction or matter discussed herein. I advise you to consult with an independent tax advisor on your particular tax circumstances. 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. On Oct 10, 2013, at 9:24 AM, Ada Clapp < > wrote: Hi Jeffrey, Alan and I agree that even though the term is singular in the Agreement Among Principals, Leon's executors, acting by majority, could act as his personal representative for purposes of the Agreement. Unless you think Leon wants to name only executor to have this power there is no need to amend the Will--the Designation should be sufficient. If however, you think Leon wants only one of his executors to act, we would need a codicil or a revised Will. I have revised the designation to name just one executor. Please let me know if that is the route we are going and I will coordinate documents with Alan. EFTA00689499 Best regards, Ada Clapp Black Family Padnu's do Apollo Manii:jertik:ri: 9 W 57th Streul phone email: IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax advice contained in this communication (including attachments) is not intended or written to be used, and cannot be used by any person or entity for the purpose of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) promoting, marketing or recommending to another party any transaction or matter discussed herein. I advise you to consult with an independent tax advisor on your particular tax circumstances. 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. On Oct 10, 2013, at 8:42 AM, Ada Clapp < > wrote: I think we may need to revise the Will for that so that there is no legal issue as to who gets to make the decision among Leon's executors. Will discuss with Alan. Ada Clapp Black Family Partners do Apollo Management 9 W 57th Street New Y phone: email: IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax advice contained in this communication (including attachments) is not intended or written to be used, and cannot be used by any person or entity for the purpose of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) promoting, marketing or recommending to another party any transaction or matter discussed herein. I advise you to consult with an independent tax advisor on your particular tax circumstances. 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. On Oct 10, 2013, at 4:43 AM, Jeffrey Epstein leevacation®gmail.com> wrote: the relevant agreement does not use the plural . representaive (s). have leon choose only one .. with a successor. EFTA00689500 On Thu, Oct 10, 2013 at 12:39 AM, Ada Clapp < > wrote: Attached are the revised agreements pursuant to our discussion this morning. Ada Clapp Black Family Partners do Apollo Management 9 W 57th Street New Y phone: email: IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax advice contained in this communication (including attachments) is not intended or written to be used, and cannot be used by any person or entity for the purpose of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) promoting, marketing or recommending to another party any transaction or matter discussed herein. I advise you to consult with an independent tax advisor on your particular tax circumstances. 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. On Oct 8, 2013, at 7:41 PM, Ada Clapp < Jeffrey, Alan and Eileen, > wrote: Attached is the proposed Memorandum of Intention for Leon. It is my understanding that Paul Weiss is preparing a special limited power of attorney to name Leon's personal representatives for purposes of the Agreement Among Principals in the event Leon is Disabled under the Agreement. If yo wish, I can also prepare a memorandum of intention to his agents under that document. Your comments are appreciated. Ada Clapp Black Family Partners do Apollo Management 9 W 57th Street New Y phone email: IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax advice contained in this communication (including attachments) is not intended or written to be used, and cannot be used by any person or entity for the purpose of (i) avoiding tax related penalties imposed by any governmental tax authority, EFTA00689501 or (ii) promoting, marketing or recommending to another party any transaction or matter discussed herein. I advise you to consult with an independent tax advisor on your particular tax circumstances. 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. <Memo of Intent-Agreement Among Principals.docx> 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 jeevacation@gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00689502