From: Heather Gray Sent: Thursday, May 7, 2015 425 PM To: Melanie Spinella Cc: Jeffrey Epstein ([email protected]); Brad Wechsler Subject: time sensitive question on Calder 1031 exchange Dear Melanie, Will you please pass this message along to Leon?&nbs=; Thank you! Heather Dear Leon, I would like to briefly call to your attention a que=tion on the 1031 exchange of the Calder. We need to choose an exchange agent to be the middle=an on the exchange. We can either use an art dealer as exchange agen= or a non-art exchange agent such as one of the companies set up to do rea= estate 1031 exchanges (for example, Chicago Deferred Exchange Company). The advantage of using an art dealer is that you can=reduce or possibly eliminate the sales tax you have to pay on the art that=you buy as part of the exchange, by taking advantage of the trade-in credi= available to art dealers. The disadvantage is that you have to tell the dealer the terms of your deal with Christie&11=217;s and of the new art purchased in the exchange. Brad and I discu=sed this issue and he feels, on balance, that the financial risk/reward ma=es it worth using an art dealer as exchange agent. In order to use an art dealer, you need to choose a =eater in New York and ask them to act as exchange agent. It could be=Pace or a dealer like Bob Mnuchin or David Zwirner. It cannot =e a dealer with whom you have done business in the past two years, so it cannot be Gagosian, Acquavella, Matthew Marks or Sub=ime. A dealer is most likely to agree to act as your e=change agent if you call them yourself. EFTA_R1_01327999 EFTA02350541