EFTA00713141.pdf

From: Eileen Alexanderson < To: mjeevacationggmail.comw <,icevacation“ginztil.com> Subject: Fyi re meeting last Thursday Date: Sat, 06 Oct 2012 13:41:20 +0000 Attachments: Pressrelease.docx From: Alan S Halperin [mailto: Sent: Thursday, October 04, 2012 03:33 PM To: Eileen Alexanderson Subject: Re: please review the attached Thanks, Eileen. I am fine with the press release. As for the meeting, I could sense Leon's (understandable) frustration. I keep coming back to two fundamental facts: we have a serious problem if we do nothing; and there are risks in fixing the problem. I therefore am striving for the alternative that presents the least amount of risk given the amounts involved, the unusual nature of the current structure and the concern that, given the person and industry, the grantor could be an unfair target. I am concerned about a purchase of the remainder interest because: (i) if we are wrong as to the value, it exposes Leon to gift tax; 00 it is very complicated; and (iii) the statute of limitations never runs. 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. Click Here for More Information Alan S. Halperin I Partner Paul, Weiss. Rifkind, Wharton S Garrison LLP '^" • ki "'I^ 19-6064 Direct Fax) From: 'Eileen Alexanderson" ••: > To: Man S Halperin/PaufWeiss®PaulWeiss Dale: 1O/0412012 02:40 PM Subject: please review the attached Three of the trusts for the benefit of Leon's children funded the acquisition through a newly formed LLC. Leon has a .001% interest through the GP that is the LLC. Since this will be released to the public, please read and tell me if the language is acceptable given that ownership structure. Thanks. Good meeting, though, obviously still a work in progress. Best, Eileen EFTA00713141 Eileen Alexanderson Black Family Partners, L.P. do Apollo Management 9 W 57th Street Newt pho email: 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 This message is intended only for the use of the Addressee and may contain information that is privileged and confidential. If you are not the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, please erase all copies of the message and its attachments and notify us immediately. 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 EFTA00713142