From: Ada Clapp
To: J <jeevacation®gmail.com>
Subject: Re: APO 1 Agreement
Date: Mon, 21 Oct 2013 17:10:52 +0000
Heard you were getting on a plane. If you have a minute to talk, please call. If not, I am going to tell Alan to
revise the Trustee provisions slightly. As drafted, the children become Trustees of the big pot trust (for the
benefit of Debra and Leon's descendants) at Leon's death but not Debra. I don't think Leon would want to put
Debra in that position.
I suggest that Debra become a Trustee of the Pot trust at Leon's death, instead of the children (they can always be
added by the other Trustees). The children would become Trustees of the pot trust on Debra's later death and
would be trustees of any separate trusts created for them at any time. Agree?
Ada Clapp
Black Family Partners
do Apollo Management
9 W 57th Street
New York NY 10019
phone:
email:
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On Oct 21, 2013, at 10:03 AM, Ada Clapp < > wrote:
Hi Jeffrey,
Paul Weiss will change the substitution language to address my concerns. Can you please confirm October
funding as opposed to November (with lower rate).
Also, the Trustees listed in the APOI and APO2 trusts are the same as in the Heritage Trust: that is, Barry
Cohen, John Hannan and Richard Ressler. Just want to confirm that this is what Leon wants (and not Paul
Weiss's assumption when drafting the document). As a reminder: (i) the 2006 Trust Trustees are Leon, John and
Richard and (ii) the Trustees of the 1997 Trust are Barry, John, Richard and Debra. Does Leon want to add
Debra as a co-Trustee of the the APOI and APO2 trusts after his death (she is only added as a Trustee of
the Marital Trust, if any)?
EFTA00973901
Ada Clapp
Black Family Partners
do Apollo Management
9 W 57th Street
New York NY 10019
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
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On Oct 21, 2013, at 9:11 AM, J <jeevacation@gmail.com> wrote:
Is there. A need for the word " trust"
Sent from my iPad
On Oct 21, 2013, at 9:05 AM, Ada Clapp < > wrote:
Good morning Jeffrey,
Do you have any other comments on the documents I sent to you on Friday (the date in the title was removed
in the last round of drafts)?
I will review them this morning. Even if there are additional tweaks I think we should be ready to fund in the
next day or two. Please remember, that we have to get the 3 Trustees to sign the APOI Trust (I assume Leon
approved naming Barry, Richard and John as Trustees?).
Also, you should know that the Section 7520 rate for November is lower than the rate for October (2.0% vs
2.4%). Ordinarily I would suggest waiting and funding in November but I understand that Leon is concerned
that the stock price will continue to rise in the next two weeks so I assume you both prefer to fund in October.
Please confirm.
If we use the APOI Trust as the decanting vehicle for the 1997 Trust, we can discuss the other issues I raised in
my email on Friday after we finish the GRAT(that is, timing for decanting 1997 Trust into APOI Trust,
substitution language for APO2 trust into which 2006 Trust will be decanted, Leon's comfort with the
intermediary trust provisions, etc).
I will touch base after I review the documents.
Best regards,
Ada Clapp
Black Family Partners
EFTA00973902
do Apollo Management
9 W 57th Street
New York NY 10019
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 consuft 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
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On Oct 21, 2013, at 7:48 AM, Jeffrey Epstein leevacation@gmail.com> wrote:
are we ready to gnat
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EFTA00973903