From: Boris Nikolic
To: "Jeffrey Epstein (jeevacation@gmail.com)" <jeevacation@gmail.com>
Subject: FW: DST - Marketing Guidelines
Date: Fri, 28 Mar 2014 07:01:39 +0000
Attachments: PitfalltinSonducting_a_Private_Placementn General_Solicitation_-_BD_-_Gifts.DOC
I had a long talk with Saurabh.
He went through details where we are.
He claims that there is no problem and is very apologetic.
Goodwin is organizing a call for next week to go over rules of PPM and solicitation.
Goodwin is polishing PPM right now and it should be ready next week.
Goodwin requested that a memo they wrote is not yet shared with anyone outside DST right now — but he will request it
tmr if possible to make an exception.
I am very confused...
I am also writing an email to Yuri as soon as I am done with this email.
Thank you!
B
From: Saurabh Gupta [mailto:
Sent: Thursday, March 27, 2014 6:20 PM
To: Boris Nikolic
Subject: FW: DST - Marketing Guidelines
From: Preysman, Daniel Bimallto:
Sent: Friday, March 28, 2014 6:47 AM
To: Saurabh Gupta
Cc: Verbesey, Paul 1; Thomas Stafford; Svetlana Pavlova ( ; Hutchinson, lames A
Subject: DST - Marketing Guidelines
Hi Saurabh,
Per our discussion yesterday, please find attached a copy of the Goodwin Memorandum regarding private placements in
the United States. Much of the Memorandum focuses on issues that are not necessarily relevant to DST because DST will
not be using the new rules allowing for general solicitation. Therefore, I suspect that the most useful materials are likely
to be on Pages 5-6.
EFTA00717164
Also, here is a link to a Goodwin client alert on marketing of fund interests in the UK and EU:
Investment-Fund-Managers-Directive.aspx?artide=1
We have reached out to colleagues in Hong Kong and London to see if we can arrange a call to get you educated on the
marketing rules in those jurisdictions.
Please let us know if you would like to discuss.
Best,
Daniel
Daniel B. Preysman
Goodwin Procter LLP
Exchange Place
53 State Street
Boston MA02109
F
IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the IRS, we inform
you that any U.S. 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.
This message is intended only for the designated recipient(s). It may contain confidential or proprietary
information and may be subject to the attorney-client privilege or other confidentiality protections. If you are not
a designated recipient, you may not review, copy or distribute this message. If you receive this in error, please
notify the sender by reply e-mail and delete this message. Thank you.
EFTA00717165