From: Jeffrey Epstein <[email protected]> Sent: Friday, September 27, 2013 1:56 PM To: Ada Clapp; Melanie Spinella Subject: Re: Pour-over and GRATs form the grats asap On Fri, Sep 27, 2013 at 9:52 AM, Ada Cl=pp < Good mor=ing Jeffrey, mailto: > wrote: I understand that you want to move quickly=(though perhaps not all the nuances for your timing) but I am wondering wh=ther we have thoroughly considered the timing of the pour-over? Does=it perhaps makes sense to do the pour-over after you have received = favorable advisory opinion on the substation for your client and we decid= how to move forward with Leon's substation. Two reasons to conside= waiting for your client's ruling: 1. If we do the substation in the 2006 Tr=st (which will disappear), what gets decanted into the Heritage Trust is=the art. Nice and clean --no need to do a substitution in the Heritage =rust that might draw attention if we decide to move forward on someone els='s ruling. 2. The substitution language cited in the=petition for the ruling request is the Weil language contained in the 2006=Trust. The Heritage Trust contains different substitution language. =e don't know how much the language will factor into the Advisory Opini=n. Might make it harder to rely on someone else's opinion if we dec=de to move forward on that basis. What do you think? <=iv> Ada Clapp =span style="font-size:7.5pt">Black Family Partners c/o Apollo Management 9 W 57th Street =span style="font-size:7.5pt">New York =Y 10019 =span style="font-size:7.5pt">phone: cte e=ail: <mailto: =RS Circular 230 Disclosure: Pursuant to IRS reg=lations, I inform you that any tax advice contained in this communication =including attachments) is not intended or written to be used, and cannot b= used by any person or entity for the purpose of (i) avoiding tax related =enalties imposed by any governmental tax authority, or (ii) promoting, mar=eting or recommending to another party any transaction or mat