From: Grieve, Brian Sent: Wednesday, February , : To: Brad Wechsler; Jeffrey Epstein Cc: Okun, Brad R Subject: RE: Privileged and Confidential Brad as previously mentioned, we don't feel that statement is technica=ly accurate. The numbers on the forms filed by Apollo entities would be di=ferent than the numbers on the forms filed by Leon because they own differ=nt percentages of the various underlying foreign entities. Also we know Apollo did not themselves file all required=forms, e.g. 5471s, for certain years so there would need to be a carveback=for that. I think the sentence I proposed earlier today is probably the be=t we can do on this particular point given the facts that exist. Or perhaps we can say "substantiall= similar to" rather than "essentially the same" if Apollo i= comfortable with that statement. Brian S. Grieve I Associate Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 www.paulweiss.com From: Brad Wechsler Sent: Tuesday, February 7, 2017 6:31:35 PM To: Grieve, Brian 5; Jeffrey Epstein Cc: Okun, Brad R Subject: Privileged and Confidential Brian/jeffrey-cld both of you live with the follow=ng language at the end of the second paragraph of the Background Section:<=r> "Finally, the information in the International Information Returns pre=iously filed by the Apollo entities is essentially the same as the informa=ion included in the applicable International Information Returns being fil=d today by the Taxpayers." If the two of you sign-off I will run by Apollo legal and tax for final con=irmation. Sent from my Verizon Wireless BlackBerry This message is intended only fo= the use of the Addressee and may contain information that is privileged a=d confidential. If you are not the intended recipient, you are hereby not=fied that any dissemination of this communication is strictly prohibited. =If you have received this communication in error, please erase all copies =f the