EFTA01196093Set 9
2014-07-089p825w
Partnership would be formed ("BFAP") between Narrows Holdings LLC I & II (collectively,
"Narrows"), the APO1 Trust Agreement (the "APO1 Trust") and the APO2 Declaration (the "APO2
Trust") as limited partners ... control and direction of the GP.
The GP could be owned by Narrows, the APO1 Trust and the APO2 Trust, as non-Managing
members. Investment decisions for BFAP would ... other percentage) general partner of BFAP. Each of Narrows, the APO1
Trust and the APO2 Trust would contribute fine art to BFAP and receive in exchange a pro rata limited
https://www.justice.gov/epstein/files/DataSet%209/EFTA01196093.pdf
EFTA00973854Set 9
2013-10-214p1,499w
jeevacation@gmail.com>
Cc: Eileen Alexanderson
Hi Jeffrey,
Attached are the latest drafts of the GRAT, APO1 Trust and the assignment form. I got them today and will look
them over ... once we resolve some decanting issues (as our decision may change the APO1 Trust
slightly). I was hoping to get your thoughts. Here is the broad brush (more detail ... phone, if you wish).
We could use the APO1 Trust as the decanting receptacle for the 2006 Trust and the 1997 Trust while Leon is
deciding on the terms
https://www.justice.gov/epstein/files/DataSet%209/EFTA00973854.pdf
EFTA00973691Set 9
2013-10-194p1,489w
Clapp < > wrote:
Hi Jeffrey,
Attached are the latest drafts of the GRAT, APO1 Trust and the assignment form. I got them today and will
look them over on Monday ... once we resolve some decanting issues (as our decision may change the APO1 Trust
slightly). I was hoping to get your thoughts. Here is the broad brush (more detail ... language Alan likes, it is a temporary
problem for him.
If we use the APO1 Trust to decant both trusts, there are two additional issues to address.
Issue 1. Because
https://www.justice.gov/epstein/files/DataSet%209/EFTA00973691.pdf
EFTA00617010Set 9
2014-04-165p1,279w
Liquid assets in GST Ex Marital Trust 1,840,000
Note payable - to APO1 Trust (1.694.738,000) Note payable - to APO1 Trust (1,694,738,000) Note payable - to APO1 ... Expenses $ 3,625,426,927 Total Taxes and Expenses $3,680,474,495
APO1 Trust reduced on Leon's death by 34% capital gains tax (and tax on NII) with
https://www.justice.gov/epstein/files/DataSet%209/EFTA00617010.pdf
EFTA01204270Set 9
2014-05-2026p5,996w
Trust Residue 1 035 111
Total Marital Trust Assets 5 3.188.370.111
Note payable to APO1 Trust 1.894.738000
Net Marital Trust Assets $ 1.493.832.111
Page 5 of 26
EFTA01204274
Leon ... Liquid assets in GST Ex Marital Trust 1.840.000
Note payable - to APO1 Trust (1.694.738.000)
Total Marital Trust Assets: S 1,493,632,111
Debra's Probate Assets:
U.S. Trust Cash ... bequest (1.166.404)
Sold To pay taxes (16.317.707)
Balance of BFP S
Note Payable APO1 Trust
BFP Interests Distributed S 1.694.738.000 1,694.738.000
Art and Collectibles Sold and Distributed
https://www.justice.gov/epstein/files/DataSet%209/EFTA01204270.pdf
EFTA00602612Set 9
2014-04-1626p5,904w
Liquid assets in GST Ex Marital Trust 1.840.000
Loan payable - to APO1 Trust (1.694.738.000)
Total Marital Trust Assets: 1,495,151,952
Debra's Probate Assets:
U.S. Trust Cash Account ... Marital Trust on Debra's Death for Bequest, Debts, Expenses and Taxes
Loan Payable- APO1 Trust 1,694.738.000
Annuity For Jon 8,484.000
Bequeste of Debra's GST Amount ... Sold To pay Taxes -17,050.548
Balance of BFP 0
Loan Payable APO1 Trust
BFP Interests Distributed 1.694,738.000 1.694,738.000
Art and Collectibles Sold and Distributed
Art and Collectibles
https://www.justice.gov/epstein/files/DataSet%209/EFTA00602612.pdf
EFTA00617015Set 9
2014-04-1626p6,024w
Liquid assets in GST Ex Marital Trust 1.840.000
Note payable - to APO1 Trust (1.694.738.000)
Total Marital Trust Assets: $ 1,341,321,111
Debra's Probate Assets:
U.S. Trust Cash Account ... Distributed BFP (balance of 8% from LDB) (101.936.111)
Balance of BFP 5
Note Payable APO1 Trust
BFP Interests Distributed $ 1,567.608.111
Art Sale Proceeds $ 127.129.889 1,694.738.000
Art Sold
https://www.justice.gov/epstein/files/DataSet%209/EFTA00617015.pdf
EFTA01088415Set 9
2014-04-1626p5,990w
Liquid assets in GST Ex Marital Trust 1.840.000
Note payable - to APO1 Trust (1.694.738.000)
Si. Total Marital Trust Assets: S 1,601,871,111
.1 -Debra's Probate Assets ... bequest (1.166.404)
Sold To pay taxes (124.556.707)
Balance of BFP S
Note Payable APO1 Trust
BFP Interests Distributed 5 1,694.738.000 1,694.738.000
Art Sold and Distributed
Art in Marital
https://www.justice.gov/epstein/files/DataSet%209/EFTA01088415.pdf
EFTA00599525Set 9
2015-03-231p291w
from 1997 GST-Exempt Trust to PLB
• $149,000 from APO1 Trust to PLB
• $1 million from PLB to Phaidon Global LLC ("Global")
In fact, the November, 2014 bank statement ... APO2 Trust to Global
• $140,925 from APOI Trust to Global
• $8,325 from APO1 Trust to Global
It was intended that the APO2 Trust would lend
https://www.justice.gov/epstein/files/DataSet%209/EFTA00599525.pdf
EFTA00987334Set 9
2014-04-033p1,174w
insurance on
the joint lives of you and Debra. The Trustees of the APO1 Trust (John Hannan, Richard Ressler and Barry Cohen) agreed
to distribute $12.5 million to Trust ... children's trusts will then sell their interests in the 2011 LLC to the APO1 Trust in exchange for a
promissory note.
Because the 2011 LLC will be 100% owned ... APO1 Trust and Debra is a beneficiary of such Trust, the Trustees will
have discretion to let her use the art held in the LLC, rent-free.
We reviewed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00987334.pdf
EFTA01197643Set 9
2014-10-072p812w
loaning three Schieles Self-Portrait, Two Nudes and Violet Stockings to Neue Galerie
• APO1 trust is loaning the Schiele Self-portrait as St. Sebastian to Neue Galerie
• APO2 trust ... government indemnity insurance.
Also attached are summaries of the loan agreements between the APO1 trust and Neue, and between the APO2 trust and
MoMA for Barry Cohen, John Hannan
https://www.justice.gov/epstein/files/DataSet%209/EFTA01197643.pdf
EFTA00676139Set 9
2013-10-212p719w
Please remember, that we have to get the 3 Trustees to sign the APO1 Trust (I assume Leon
approved naming Barry, Richard and John as Trustees?).
Also, you should know ... both prefer to fund in October.
Please confirm.
EFTA00676139
If we use the APO1 Trust as the decanting vehicle for the 1997 Trust, we can discuss the other issues
https://www.justice.gov/epstein/files/DataSet%209/EFTA00676139.pdf