To: Fenn, Patrick
From: Jeffrey Epstein
Sent Mon 5/27/2013 1:13:50 AM
Subject: Re:
yes, but they were unaware of the size of the termination payment. they didn;t want to be on the
hook, but a guarantee to them by virute of the tra payments might have traction.
On Sun, May 26, 2013 at 7:45 PM, Fcnn, Patrick wrote:
We had proposed and vetted a fresh loan and personal guarantees from the boys as a means of
deferring the recognition of the Tufts gain on exchanges and extending amortization of the existing
loan. That does have an impact on TRA which would require amending the TRA (which should be
addressed in any event). There is deferral in that approach for TRA payments on the Tufts gain (but
not the economic gain on exchanges). The boys had determined that the benefits of deferring Tufts
gain (as modelled in the spreadsheets I sent you sometime ago) were not sufficient to put them at
risk on the personal guarantees. Of course that does not address the negative basis problem.
From: Jeffrey Epstein [mailto:ieevacationOomail.com]
Sent: Wednesday, May 22, 2013 06:08 AM
To: Fenn, Patrick
Subject:
why not have a new entity borrow the billion, secured by some form of guarantee , letter of
credit, in turn supported by the tra payments or termination agreement. py off the amh loan,
somehow let the tra payments build without creating a taxable event for the boys, ten year
later a billion dollars set aside, would be nice to keep it all in apollo or have them be the
lender and the borrower.
Why would you have to liquidate ? I know you are tied up . so no urgency.
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