From: Ada Clapp Sent: Friday, September 27, 2013 1:52 PM To: Jeffrey Epstein Cc: Melanie Spinella; Eileen Alexanderson; Alan S. Halperin Subject: Re: Pour-over and GRATs Good =orning Jeffrey, I understand that you want to move =uickly (though perhaps not all the nuances for your timing) but I am =ondering whether we have thoroughly considered the timing of the =our-over? Does it perhaps makes sense to do the pour-over =u>after you have received a favorable advisory opinion on the =ubstation for your client and we decide how to move forward with Leon's =ubstation. Two reasons to consider waiting for your client's =uling: 1. If we do the substation in the =006 Trust (which will disappear), what gets decanted into the =eritage Trust is the art. Nice and clean --no need to do a =ubstitution in the Heritage Trust that might draw attention if we =ecide to move forward on someone else's =uling. 2. The substitution language cited =n the petition for the ruling request is the Weil language contained in =he 2006 Trust. The Heritage Trust contains different substitution =anguage. We don't know how much the language will factor into the =dvisory Opinion. Might make it harder to rely on someone else's =pinion if we decide to move forward on that =asis. What do you =hink? New York NY 10019 phone: IRS Circular 230 =isclosure: Pursuant to IRS =egulations, I inform you that any tax advice contained in this =ommunication (including attachments) is not intended or written to be =sed, and cannot be used by any person or entity for the purpose of (i) =voiding tax related penalties imposed by any governmental tax =uthority, or (ii) promoting, marketing or recommending to another party =ny transaction or matter discussed herein. I advise you to consult with =n independent tax advisor on your particular tax =ircumstances. This communication, =nd any attachment, is for the intended recipient(s) only and may =ontain information that is privileged, confidential