From: Ada Clapp To: Jeffrey Epstein <[email protected]> Subject: Re: BFP Distributions to the LDB 2011 LLC Date: Wed, 30 Oct 2013 18:05:17 +0000 That would work for and because their trusts would not have to distribute out the funds to them (they are under age 25) and could be used to pay back the 2006 Trust for the money it loaned to them. With respect to Josh and Ben, if the funds were paid out to them—their 2011 Trusts would not have money to repay the notes held in their descendants trusts. Remember it is the 2011 Trusts that owe the descendants trusts $5.12 million (in respect of .iincipal distribution Ben/Josh should have received). If the descendants trusts held cash (like the trusts and set up for their descendants), it could be reinvested to earn more than interest on the notes. Thus, better leveraging the use of Josh and Ben's gift tax exemptions—which they used in 2012 to get that $5.12 million out of their estate. Making the distribution from the 2011 Trusts to them now would put $5.12 million back n their taxable estates. The goal is to put the descendants trusts on par with each other from an asset standpoint and to restructure the notes in the self-settled trusts so you only have "Leon borrowing from Leon" so to speak. 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