From: Ada Clapp <1 To: Jeffrey Epstein <[email protected]> Subject: Re: Funding a GRAT with encumbered property Date: Wed, 16 Oct 2013 18:29:01 +0000 As I understand it, the 2006 Trust has a security interest in it as collateral for the loan. That is what I mean by encumbered. It is pledged as collateral. Ada Clapp Black Family Partners do Apollo Management 9 W 57th Street 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 notify me immediately that you have received them in error. On Oct 16, 2013, at 2:15 PM, Jeffrey Epstein <[email protected]> wrote: the prperoty is not enbcumbered, On Wed, Oct 16, 2013 at 2:06 PM, Ada Clapp < > wrote: Jeffrey, Regarding the GRAT, to summarize my discussions with Alan, as I understand it, there is still an issue to resolve regarding the BFP interests as it is currently collateral for the 2006 Trust loan. Funding a GRAT with assets pledged for Leon's personal obligation is not so clear cut. In short: I. There is some concern that the gift to the GRAT would be incomplete given that there is a risk (albeit slight) of forfeiture of the assets if Leon defau