From: Eileen Alexanderson Sent: Thursday, July 5, 2012 7:02 PM To: 'Jeffrey Subject: RE: follow up See Article II on pgs 1-2 of the 2006 Trust Doc attached to my last email f=r language related to distribution of 'trust accounting income' from opera=ing profits of 'relevant companies' which you will see detailed in II(A)3.=The 'relevant companies' are the Apollo entities Leon had ownership intere=ts in that he contributed into the GRATs that poured into the 2006 Trust. =here isn't specific language surrounding the principal. The trusts owns th= interests in Black Family Partners and the monetization of the value of t=e BRH interests would not constitute 'trust accounting income' from 'opera=ing profits' and would therefore remain in the trust. I will next forward a summary entitled 'History/Structure' that I wrote for=myself early on as I was trying to come up to speed on what had been put i= place. I believe I left you a hard copy which was behind the org chart of=Black Family Partners. There is a section on the first page with comments =n FLPs-I was in an education mode and, with hindsight, did not fully under=tand the control issues but I think otherwise this will help you understan= where we came from. Importantly, you will see there were 2 sets of GRATs. The termination of GR=Ts A-K went as planned. But the second set, GRATs L-O lacked sufficient ca=h to make the final annuity payment to Leon so we did an inkind transfer o= the Black Family Partners these GRATs owned to Leon and then he contribut=d these into a new GRAT, the Judah 2009 Trust. We made that a 4 year GRAT =nstead of 2 years like the original ones we did because I felt we would no= have generated enough cash in 2 years to make the annuity payments to Leo=. Original Message From: Jeffrey (mailto:[email protected] Sent: Thursday, July 05, 2012 1:46 PM To: Eileen Alexanderson Subject: Re: follow up Send me grat docs that separate income from capital appreciation Sor