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EFTA00981191

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From: Jeffrey Epstein <[email protected]> To: Melanie Spinella Subject: Fwd: Planning Meeting Date: Thu, 09 Jan 2014 02:28:51 +0000 Forwarded message From: Ada Clapp <1 Date: Wed, Jan 8, 2014 at 5:13 PM Subject: Planning Meeting To: [email protected] Cc: Richard Joslin < >, Eileen Alexanderson Hi Jeffrey, Rich mentioned that you might want to have a meeting next week to discuss various issues (including estate tax issues) relating to art owned by the various trusts and entities. Unfortunately, I am in Orlando at an estate planning conference all next week. Eileen and I are both free on Friday of this week. Would anytime on Friday work for you? Also, I would like to add to the agenda a quick discussion of the APO2 Trust and the sub-trust you and I briefly discussed. To refresh your recollection, the sub-trust would need to be added to the APO2 Trust (not yet signed) to enable it to hold the joint life policies currently held in the split-dollar insurance trusts, once we roll out the split dollar agreements. Including the sub-trust gives us the flexibility to retain the insurance (and perhaps convert it to a more favorable policy), which Leon indicated to Eileen that he may wish to do. We need to make a decision on the sub-trust before we can move forward with the decanting of the 1997 Trust. Also, we need to factor this into the plan to upwind the split dollar arrangements when we speak with Norman Brownstein regarding phase 2 of the roll-out (i.e., what to do with the policies once the trusts own them). Please let me know if Friday works for you. Best regards, Ada Clapp Black Family Partners 445 Park Avenue New York, New York 10022 EFTA00981191

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