From: Jeffrey Epstein <jeevacation®gmail.com> To: Melanie Spinella Subject: Fwd: Sales Tax Call Date: Thu, 19 Sep 2013 15:19:37 +0000 Attachments: DRAFT--Avisory_Opinion_Petition.pdf please forward this to lean i don't get it Forwarded message From: Ada Clapp <I Date: Thu, Sep 19, 2013 at 11:10 AM Subject: Re: Sales Tax Call To: Alan S Halperin Cc: Jeffre E stein <jeevacation@gntn> "Ms. Eileen Alexanderson" , Richard J Bronstein Christopher L Hurtado Thank you for organizing the call. I have attached a first draft for discussion purposes of a prosed Petition for Advisory Opinion with the following caveats: My in-house research resources are very limited and accordingly, I am unable to confirm that the cases cited in the attached draft are still "good law" or whether there are more pertinent or recent cases out there. I also do not have access to recent editions of secondary sources such as the Calamari & Perillo, Corbin or Williston hornbooks on contracts or Black's Law Dictionary, each of which likely has a helpful definition of "consideration" that could be incorporated into the Petition. Paul Weiss can perhaps fill these gaps. Ideally, more time should be spent to develop a stronger argument in support of the conclusion we are seeking in such an important case of first impression. I am hoping we can discuss this on our call later. Best regards, 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