From: Ada Clapp Sent: Wednesday, February 26, 2014 3:18 PM To: [email protected]; Christopher L Hurtado Cc: Eileen Alexanderson; [email protected]; Richard Joslin Subject: GRATs Hi Alan and Chris, As you know, Leon is due to receive his first annuit= payment form the APO1 GRAT No. 2 (dated December 4, 2013) on March =, 2014. Please prepare the assignment form. We w=ll let you know the cash portion of the annuity after the dividend is paid= At Rich 1's request, we would like the APO1 G=AT No. 3 to be dated March 4, 2014 ( this will align the annuity payments =or GRATs No 2 and 3). Would you please prepare a new GRAT agreement =nd assignment form. I am assuming that Leon wishes to re-GRAT the BFP interests he received from the APO1 GRAT on Janu=ry 24th and the BFP interest he will receive from the GRAT No. = on March 3rd. Jeffrey-can you confirm that my understanding is correct?=/p> Regarding valuations, Leon will require a full valua=ion report for his gift to GRAT No. 3. Since Empire does not prepare=its valuations showing the value of a 1% interest in BFP but rather the va=ue of the entire interest transferred, if Leon re-GRATs BFP interests received on both January 24th and March 3rd, GRAT No. 2 will need a separate restric=ed use valuation report (RUVR) for its in-kind distribution of the annuity=payment to Leon on March 3rd. Likewise, the APO1 GRAT will need a RUVR for the January 24th in-kind distribution. Do you agree? Thanks in advance! Ada Clapp Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 Direct Dia Fax: 646-589-0330 1 EFTA_R1_01428395 EFTA02396316