To: Melanie Spinella I have mixed emotions about what transpired today. really, You saw first hand in nauseating detail what i have been saying to you for quite a while now. Joslins answers were totally incomprehensible, the charts he prepared unreadable. Brads defensive posture was at a minum very surprising . He and I have recently gotten along quite well, I thought. Neither Joslin or Brad understood a 180 million dollar number. no cash flow after weeks of requesting? odd. when you suggested that heathers behavior was emblematic of a sloppy office , brad said lets not talk about emblems??! bill pay, admittedly no change for the year. . plane not done. though it was the only thing i suggested doing first in july . . I sent you a list of 10 consultantts. brad said three, . i didnt want to push it. I was shocked that brad was opining on things he knows little or nothing about. tax issues. 1031. neg basis, note payoffs ( the same idea he said he had had from the beggining??!!) . answers re LBF holdings that can be corrected ( they cant) . valuations that have never been read. . When we met in your lobby he seems surprised that i was there. I dont know if he felt somewhat sandbagged. . . the savings on the note payoff is aprrox 33 % of 1.8 billion, real money if you do phaidon which i see no reason not to . if later josh and ben want to buy it back with you or without you they can. i will walk you through the structure one on one. . the losses will offeset the calder gain as well as apollo gain. Im aware that seeing what you saw frustrated you. I felt badly for you. You wanted a contingent deal. real value. etc. I will not of course hold you to your deal . . its silly. its not how i work or a reflection of our friendship, my proposal is as follows. I want away from your buisiness , but at the same time leaving you in good shape. I think you should pay the 25m that you did not for this year. for next year its the same 40 m as always, paid 20 in jan and 20 in july, and then we are done. I will give you advice and counsel but new people will be running your operating machine. I will oversee all the work HOUSE OVERSIGHT 023337 that needs to be done you and I will hire new people , and it will be self running. ( it was may in my house when you told brad it had been 5 months and you were getting fed up ) I will set up a parallel. office, somenoe like wendy dolman or her quality is paramount. two accountants two bookeepers and two office admins. . alan and zoe will handle trusts and grats. heatehr diana george will be incolved in art partnership. if you want brad, analysts etc. and kids to do investments I have little to add in that regard ,except to be able to account for things properly. I suggest that the kids must have skin in any deal. Alternatively , we can continue to focus on fun and let someone else do the things that you want done. and you and I can kibbitz about it all. structures outcomes risk, museums. charity, ( joslins answer by the way was I had asked how much charity was leon planining to give this year , ( the 2 m ) he didnt include your foundation or the payment to me, or from debra and you??!! Date: Mon, Nov 30, 2015 at 11:21 AM Subject: agenda To: Melanie Spinella - 1 fees, amount and to what entities when and responsiblitis. 2. gagosian idea to save a minimum of 10 mill and maybe more. 3. i can walk you through carlyns screw up, 50 % would have made little difference and maybe made it worse. 4. we should have an all hands meeting with your family to talk about art distribution on death. . 5. phaidon, decantings ( already firmly in progress ) loans. ( alan ) pent. ( with follow up ) all part of same elegant transaction, 6 asymetric risk worth at least 50- 60 no matter how you calculate. I can explain. 7 lets get the money issue out of the way once and for all. I have my team set to start. Date: Fri, Feb 20, 2015 at 5:52 AM Subject: To: Melanie Spinella 1) pg 1 A" unequal shares" . pg 23 "removal of trustees" absolute. dont be confused with abiltiy to set up seperate trusts„ 2) I am reachable this afternoon in europe. on cell. 3. on another note. -our financial agreement ended months ago . seperate from the art partnership (which i was told yesterday to my amazement is still not funded) . i am obligated to complete ? the time i have dedicated since oct/ dec has been spent mainly as your friend. tom, brad though i am fully cognizant of my responsiblities. I will try to help find people. I am not good at human resources. howevr If I don;t think they are good enough for you. I will continue to say so , and you obviously decide. but I will reiterrate even in the face of your "nobody is good enough argument." keeping foremost in my mind that you and I have only beeen shown a very tiny handful of people. 4. I find the friction over fees , counterproductive, in an attempt to avoid it I had suggested a multi year deal early on. you rejected it. I then suggested, and urged you to have an option at a fixed fee , you also rejected that .you wanted the fee payment only at the end I argued but ,conceded. I suggested a structure that tom didn't like, you rejected it. 5 I suggest you make a fair proposal.- that i can either accept or reject. some payment up front this time is a requirement. I am willing to modify any outstanding obligations. - there are creative ways to assure you of your desired characterization of those payments. 6 you should open accts at Deutsh. and goldman. I am told that eilleen has set up over one hundred bank acccts for you???!!. few relevant 7 you should immediatly demand a list of all her acct authorites , exec poistions . director etc. bank authorizsations. etc. talk later or over the weekend if you like Date: Tue, Jan 5, 2016 at 9:32 PM Subject: To: Jeffrey Epstein Mark was here this morning , the proposed transactions are extremely complex . and would take a great deal of detailed time. I do not know how, and if ,to move forward - our last transaction. a transaction which you saved 600 million in tax. even if 20 years away, ( i hope longer) even discounted is a 300 million savings . for that you ignored our agreements , verbal written and emailed -and decided that it was only HOUSE OVERSIGHT 023338 worth 8 million dollars. ( assuming phaidon srichard happens. 24 m savings not including artspace and debt benefits certain to come later ) FYI the phaidon transaction cannot happen as currently comtemplated IT will not work . NOT When we had our meeting in your home in Bedford. You asked me for my help. I told you multiple times that i thought it was a very bad idea, in that I preferred to have no financial interactions. I dont have many friends and didnt want money in any way to interfere with our unique relationship. Reminder, For five years you had the kind but goofy Eileen Alexandersson as the sole manager of your accounting, legal, investments. reporting, trusts etc. When I first told you in no uncertain terms that I firmly believed she was incompetent you admonished me for" speaking out of both sides of my mouth" . With regard Brad Wechsler, there has never been a " both sides. ". I have consistantly maintained since day one that he was highly unsuited for the job. When you initially asked me to help convince him to take the role , promising him a position to manage mirage investments I sent you a note saying that instead of hiring him you should pay up and get first class people. I have reiterated the same message for over a year now. . Brad, not me ,was tasked with hiring new people , according to his org chart.(nauseating ) and as you wanted him to take ownership of the staff,he conducted many interviews alone. . you may recall that as late as may, you told him in my presence that though six months had passed he had not hired anyone. since then I have rectified errors in sales tax, use tax, income tax, fbar reporting, 1031 reporting, 8 million of deductions missed errors of millions on the returns. ,( april ) Oversight on new grats- first at 22 and then at 19 that were done without my consultation and needed to be resolved soley as a result of my last minute intervention. . 600 million in after tax savings was just accomplished, though you left the 30 million outstanding that I had said should only be done" if" that was my additional fee. not used for non biz purposes and not art. in June and then again Sept, we both agreed to a 50% of phaidon payout first projected at 20 . but less when artspace and debt taken out, - then only after weeks, when you delayed any detailed discussion of money wanting to give the issue a thoughtful response ( which I fully understand ) . you unilaterally changed our agreement. . 5m would be reserved for the future ? . and out of the remaining 15m,? i would receive only a third. ( note : I'm confident that both the debt, and the art space investment will also lead to a write- off of another 30 m. plus ) In my dining room ,you were surprised when I said that i require most people to pay their advisory fee up front so that I am assured that I will be properly compensated for my work when strategies are implemented. you may recall that you appeared offended and said " are you suggesting that i would go back on my word" I said no , of course not! you are my closest of friends ,but my experience is that when amounts get large, people tend to get unhappy when it actually comes time for them to pay. I include below the email i sent to you on April 15, the day i was examining your returns It laid out my understanding of the compensation agreed for a transaction of the magnitude to the penny of the one just completed.ie 600m When it appeared that the transcation would and could go foward I was the first to point out that our agreement would cost you too much money, therefore From day one I proposed to discount our agreement to a 50 - 60 million range. An extremely fair price for all the transactions just completed. including Phaidon. - I was never told that this was out of range. in fact, alternative methods of payment. ie my plane, or an -in-kind payment were discussed ( ie including keeping the 30m portion of the fee outstanding till March ) ,I provided, only because you specifically requested a detailed step by step execution plan and reviewed all documents that i was given access to. ( Phaidon was never forthcoming ) in order to make my many corrections. ( as i said more needed on phaidon ) . I was then told that Alans involvement warranted a discount. Even in the best of light , though it is beyond question that not one time in the three years of his retainer has he ever proposed a unique idea. (including any way to deal with the use issue on debras death ,or even the most basic review of your largest asset by far , the BRH agreement. ) O.K. - lets say he made a contribution to the plan and stretch reality beyond the pale and say it was 50 %. though no one could posit such a large amount unless they were wearing a clown suit. , the payment and our formula of 37 percent associated with the deal was known . It had both sent in writing and spoken about on the phone numerous times, a detailed execution plan was provided. then and only then, after the entire transaction was laid out for the group to follow You told me that after a number of conversations with brad karp that a total of only 20m would be paid, (and even that was more than you originally contemplated ) for both transactions . Leon I feel It was remarkably unfair. Did brad even knew of our prior agreements.? ?, I would ask that you I and Brad karp sit together if you think it HOUSE OVERSIGHT 023339 would be helpful. . I would like to send him this email, with your consent of course. If the transactions were never consummated, i would not be owed a dime, however , the expected fee was known up front. , the detailed step by step plan was followed and overseen by me, the amount that I had requested before the transaction had even begun, had already been heavily discounted, out of friendship, . I believe the decision re only paying 20 m has frankly, left me felling quite uneasy. and colors the view about the Athene or Rothschild transaction. Date: Sun, Mar 20, 2016 at 11:17 PM Subject: To: Melanie Spinella glad to see you are personally on the mend - as well as the fence. -- As you know i dread money discussions with you-- however -we should address the issue of what you would like to do moving forward. re- do family office, accounting trusts , estate and apollo agreements . Along with your " payment " last year we agreed. no further obligations on each side. yes, i continued to moan. I realize that though I ve done quite a lot this year already , it is not your responsibility. . As you often like to remind me- you've paid a great deal of money to date. that being said - If you want my involvement moving foward, I suggest you pay my regular 1 fee of 40 m. 20 now. 20 on completion or as per the invoice issues at the end of last year pay 30 all at once. - To help out . im keenly aware of your current cash position. so I will consider an in-kind payment - real estate ( Miami )„art , financing of my new plane (allows you to spread over years or of course the preferred cash. Get rid of Castrucci,it is over a year since the same story of findign the right guy at the top. you entire accounting needs to be re done. , office downsized, reporting re done. meetings to recitify, categlorize , the various docs re appollo, rowen, suydam, alan etc. Brad can direct investment guys, ( hopefully) my people will be in your office for a few months . reorganizing IF you decide not to pay I fully understand, as I m sure you will re my no longer spending any serious time on these things. Of course re any non financial issues, I am always there for you and will continue to be the best friend I can be Steve jobs said that everyday he woke up , and asked himself, if he knew he was going to die tomorow , would he do the same thing that he had planned for the day- he wanted to check that he was doing things that he really wanted to. after three days of getting back an answer of no, he would change what he was going to do. . he also did not believe in LONG term plans. I dont think either one of us will figure out what we want to do long term so my thinking is that we should try to have fun everyday, and welcome serendipity. I think another trust and estate lawyer should be brought in to deal with the issues of how not to allow your family to get screwed by your partners on death. Alan, for years told me that paul weiss had drawn the docs so no issue but when recently pushed by my new fire drill he asked akin to draft.?! PLease ask brad about why he keeps talking about flow. I dont know what he means, its so silly. . this is only about money control and protection. I am leaving monday night now. free to speak in the afternoon Date: Tue, Apr 12, 2016 at 11:49 AM Subject: To: Melanie Spinella use tax questions. ? california question state returns? as you know wendy did not play a role here. . her involvment moving foward would help alot. . sign your gift tax return today if possible . I will be finished tomorw with this year. crazy on april 13th. !! . last minute to say the least. . brad told you the tra can be separated with approvals, which should be simple. . alan alwys just says no , . unless he is asked , well what if we amend what is there. . moving foward , i ask you to decide if you want me and my team involved or not. . I want to be weaned. I agree the past, apart from phaidon and artspace. this year of course is done. . for me to allow bad reporting to negaitvely impact you, by keeping joslin, would be irresponsible on my part. . letting him do harm, or stopping him and having to listen to his leaving is my fault. is awkward. . I will call at 3 HOUSE OVERSIGHT 023340 Date: Tue, Feb 9, 2016 at 7:56 PM Subject: Fwd: To: Melanie SpineIla this was sent four months ago, nothing has changed sent oct 15. before big transaction. Office, - ada goes. , hire heather a paralegal. Joslin goes or is closely managed by new cfo with tax experience. . castrucii goes asap.as he merely adds to mess.( too many people, ex 7 people or more to pay a bill ) eva goes. outsource as much as possible. . bookkeeping systems built from scratch, airplane restructure, boat. same, new grats. phaidon sale , decide on artspace survivability, regan,. do the kids really want these? , children accounting ie bens house.etc. re do estate for new facts. redo loans, trading accounts activity, . gaming -foreign- disclosures. . BRH TRA re thinks. household and construction architects. . redone. art partnership , choice of paintings. . re do structure of consultants. tax re family office. . decide if investments are a realistic option in the next three years.. insurance, operations. airplane, etc. . art foundation , private. max charity contributions, financial reports. still waiting. ? on line banking, . tax planning, family office deductions ( profit center ) . airplane certificate, redone jet aviation redo. . paper gigi ( E )trust to avoid gift tax.. Date: Tue, Nov 15, 2016 at 6:13 AM Subject: Fwd: To: Melanie Spinella Leon, Congragulations on biting the bullet. at least 18 months late , but I m encouraged and glad for you. When you interviewed Brad two years ago you asked that i not tell him what a disaster lay before him. what would you like me to tell Barry? There is a HUGE amount of work to be done in the next 9 -12 months. mostly the exact same work that i outlined in my email of 2 years ago. now complicated by years of mess on top. ( you can send it again if you like ) . Brad wechsler was never up to the task. sorry, I realize I have been saying the very same thing for a long time. he was a not a step up from Eileen but a step sideways. in the beginning there was Eileen and Tom and Ralph Lerner. all your hand picks. then brad. john, Joe. . joslin was chosen from a pool of 2 people. each that would be limited by a salary of 250k. ( yes i personally augmented his comp in order to get him ) I did say hire both Lisa to do the bookkeeping and joslin tax, He complained for over a year, re his direction by eileen and ada, and then brad. His breakdown was not a surprise after months and moths of warnings. Though disabled, he ran your office this year. with john and joe. He ran amok, and as i told you he rarely failed to remind me in our conversations that you told him that he works for you and not for me and that brad needs to pays him . . Asking me who to hire , estate attny tax people etc. : I have taken heat for years over the fact that i gave you no more than carlyns name, . no follow up questions no interactions , not even one single question asked of me re her work. ( that was Eileen ) but somehow carlyns fuck up was my doing. . when i told you that i thought Eileen wasn't up to the task, you bellowed that i was talking out of both sides of my mouth. . You told me this year , that by trying to protect you from crazy joslin, I had in essence fired him and it was my responsibility to do his work. it then turns out that he didn't consider himself fired at all he just received less money. and continued to make a really dangerous mess. . Joshn castrucci, in your eyes, was also my doing , though email after email said, I take no responsibility for him,and iYOU SHOULD NOT HIRE HIM .!!! „ your response was that was my opinion was only because i didn't trust him. then to add insult to injury last jan you told me he was gone. however he too is still there, and a waste of money and space. My time is complicated by Donald's potentially eviscerating any reason for anyone to use the foreign funds repatriation plan that i had put together. . however as you are aware I have some decisions to make re my time allocation in the next year or two. so at least for a few weeks I am unable to commit much time and make any future plans to guide you in the redoing of your procrastination produced mess. That being said, the tasks at hand are the following. HOUSE OVERSIGHT 023341 You have a bomb of colored string that your retarded children have formed , It has to be very carefully unwound , even the substitution of Barry for your next trustee, needs a careful focus on procedure.s It would be much preferable if Wechsler was not his replacement. do you have any person you trust ??! . I am concerned re brad taking barrys place re )(XXX. In the beginning Barry will need to find and learn ACCURATE . org charts. books , balance sheets. trust valuations, are all a part. Barry will need 2 months to just get his arm around what is there, this is before any needed modifications., a way overdue re- fresh of your estate plan. . clats , trust. partnerships. grats. Ilcs. bank accounts, filing requirements. etc. the long awaited review of the brh tra and shareholders agreement to see how they fit into new plan. . "" planning. art partnership engagement.. , airplane re-do. , buying another. . ? boat sale , Miami sale. . TRADING ACCOUNTS. . three years over due. . an accounting system. fire john .. joslin stays for a year. or so. so does tom and. except for heather everyone should be replaced with new. . Sell Artspace and shut down regan arts. . rationalize, cash flow reporting. cash mgmt. stock sales. sec irs. gaming. foreign reporting. the 8865 mess will take months to review now. . you CANNOT file unreviewed audited documents. . CANNOT!!! this will be very detailed work. . a self inflicted wound - all avoidable if professionals had been in place to limit. or contain it. . . you will need 3 new hires .a s there is no one in your office that is truly an A player. I have great hope in Barry as you know. He will need to be trained. note ; One year is my guesstimate After 4 years of telling you , that you could do better than Halperin,: im glad that you now are willing to follow barrys advice . I take no offense, in fact I take comfort in the fact that after only one conversation with Barry you are now convinced to make that change . will take a year or more. I expect as a friend you will understand that I will no longer, not even for one day , work on your affairs . without the compensation that is long overdue. . your unilateral idea of after care , not imposed on any other professional , except me, not paul weiss ,( caesars alone , a direct screw up on their part ) tom, akin„ no one. needs to end. . you and I had previously agreed no more of that, and this after you decided not to pay me per our agreement. to be fair I can not say im surprised as you have email after email , stating that , if you save a great deal of money, you wont want to pay, so limit it to 40m per year. - water under the bridge If I can find the time to work, on your project , which is not by any means certain as I have said, I hope you understand that it now will have to be under my standard terms and conditions. and well documented so as to avoid any more of the he said she said. I never want to have any more uncomfortable money moments with you , I find it very distasteful. . so to be clear , my terms are as follows . I will only work for the usual 40 million per year. It needs to be paid, 25 million upon signing an agreement. 5 million every 2 months thereafter for 6 months ie march may june . this can begin if i am able in January. I will immediately stop work, if the payment is not received. If you want me to work this year until Jan 15 , it will be 10 million, paid upfront. after one year you will be left with a new estate plan a running office. staffed with professionals overseen by Barry. ( hallelujah ) a tax plan . and an investment that returns more than any painting you could possible own. . no agreement - no work. however - I of course will talk to Barry for the hour that i promised , and take your guidance as to what I should say. her the last two places. ? To: Melanie Spinella Leon please read the attached proposed response to the IRS , see if you can understand it !!!. lye asked for a re-do. and given prelimiary directions to Alan to have it edited over the weekend . If you are quarterbacking ,ok with me. just please let everyone know. you must deal with the outrageous incompetence in your family office.. Alans words " but I was told that.. , but I was told by the office (sic) that ... , BUT i was told by joslin,. , but I was told by. " why is leon blaming me for .." . I ve have always given you my best advice, If you reflect on your financial life, you have been kept safe , had remarkable results and no disasters. I have repeatedly urged you to get rid of the people in your office. , you have repeatedly chosen to ignore my advice , you told me last week that the emotional reason was in order to be weaned off my group and not have to pay my high fees. ( though ignoring the benefit of between 1.5 HOUSE OVERSIGHT 023342 and 2b to the better. ) . and no explosions. You have email after email ,where i remind you that I am not your bookkeeper or accountant ( in brads corporate speak his" finance dept ??!!) that it should be redone .I have reviewed a multitude of the silly reports given to you and have pointed out the continued numerous inaccuracies . your question" so what if the numbers are off, so what if the categories are off whats the big deal??. I suggest you de risk you finances and make the tough decisions necessary - pay the right amounts ( high) to get the work done properly or , you are, Im afraid, certain to get an unhappy answer.. tom will be back from vacation, this week. ----------Forwarded message---------- From: Halperin, Alan S _ _ Date: Thu, Apr 28, 2016 at 5:16 PM Subject: Valuation Discount To: "jeffrey E." I am attaching a draft response from Empire Valuation as to why it arrived at a valuation discount on the low end. Let's discuss the response and next steps. Thanks. Alan Js Date: Tue, Feb 24, 2015 at 8:20 AM Subject: To: Melanie Spinella <111111= Leon, Yesterday, I again spent hours upon hours of my time with your office. ,( speak to brad to get flavor) and you and i will discuss the results in gory gruesome detail on Friday. it mirrored many other weeks spent doing the things that I don;t have the time to do. In order to keep things in perspective, maybe reviewing an analogy I have used before with you, might be helpful. You and your family are a 6 billion dollar corp. with an income between 250 -500 million dollars per year. It contains a few operating biz's , a large wide array of existing investments, in various categories, a desire to enter into others. A panoply of loans, notes. purchases, wide range of all types of taxes. , planes. boats homes. . trusts ,grats. a crazy number of bank accts. ( with no oversight ) . law firms, acct firms, 800 page tax returns, foreign firms. art consultants. construction consultants bill payers, home mgmt.,vast multitude ofllc's , including foreign, and with all that you only have a combined overhead of less that 3 million dollars. I have previously sent you the very same note that i have enclosed again below ,this time with highlights . I wrote it to you over a year ago. As my acute disability ( selective memory) seems to have been raised as one of your concerns , as a rule I try to memorialize things in writing in an attempt to lay out issues that I fear may later turn out to be a problem. ie what i would and wouldn't do , - my responsibilities. etc and those things that are not. below you will find details of things that I thought needed to be done, so that you wouldn't find yourself in the very place where you currently find yourself however ,you chose to defer many of my suggestions- see below -,until only weeks ago. ! you chose to defer the jpm acct. the art partnership on and on - into this year. and though the 60- 50 40 timber emails all carried with it a clear warning that you needed to do something re personnel if it were to stabilize,- you chose to wait. ONE YEAR AGO Feb 17 2014 i wrote : With regard the more pressing issue I am uncertain of just how to proceed. I am torn, as my very strong inclination is not to be involved at all. It is extremely time consuming, delicate, fraught with many pitfall many that will make you very upset and a major pain in the ass. I wrote you months ago that the quality of the people involved need to be upgraded. ( lucky for me these last issues arose way before the beginning of my involvement ) I am also aware however of my overarching friendship obligations of ok, -given all the complexities who else can do it? problem. Your family office needs a daddy. children with good intentions are running around, sniping , nitpicking with HOUSE OVERSIGHT 023343 little direction. As a stopgap measure I am suggesting , we put in Larry Delson to take charge Everyone would report to him. Eileen included. He would however work for me. this is not, by a long shot my first choice as I prefer only being responsible and standing behind my own personal work ( ie the word DONE will no longer be transmitted to reflect status stated by others ) With no commitment on my part whatsoever, to do it. So far as I have failed in my attempt in trying to think through the problem creatively. My organizations handling of the more complex issues I believe you might find very costly, very ! ( however many structures available some risk sharing, maybe risk caps ,etc ) but would require my teams doing the work , not yours. Ada should be only a trust, grat administrator, not sure what role you prefer for Eileen as you hired her initially to oversee investments. whether Rich your controller stays or not, is not urgent. having Tom report to a new person,- is. coordination with Suydam Kathy Gregory, I would suggest limiting to one person. The increasing public profile needs to be taken into consideration. TODAY With your acquiesence , Eileen did not report to Delson ( he acting as a conduit directly to me) , she continued to provide bad info to both you ( cash flows , stock accts, structures. sales Etc) and me. and each time with my many annoying calls to you made immediately afterwards that she was g.....y!! No one was hired to run YOUR office until two months ago , no one was even interviewed and even now , Brad, a very nice man, is not even full time,(crazy ) Hours upon hours of time need to be spent training him. and his new staff. Eileen followed your instructions, not mine, in fact she continued to ignore mine saying " but Leon said " or" its on Leon's desk etc" , You would become frustrated when i pointed out each instance, of her obfuscation. originally you were given the clear choice, but to save money ,you chose not to hire my team. I was hired to do the architecture, you kept your own team. with Eileen at the head. instructions were given by me„ detailed but ignored by her. ( except in the instances where I inserted myself and personally had to do the weeks of grunt work ),ex. jpm morgan acct still not in use? That being said, If you do the cold calculation ,starting from where you were, to where you are currently . you have made a hell of a deal. -- negotiating down my original amount requested, calling upon our friendship and suggesting that the Carlyn mess was partially my fault. ( though in that specific example, I had never been asked to do more than merely provide you the name of the most highly recognized atty in the field, not consulted,nor even asked again for my guidance along the way. ). I accepted the discount as your friend. ( by the way „suggesting now, that your Tom is now that last word on tax characterization, frankly is a bit much,-). however - that is all in the past. In order to move forward I would ask that you realize that very unlike yours, My business is only comprised of my personal attention and my personal time . Time that I was forced to grossly overspend on your various issues last year. . As you are my very close friend I will not have you participate in a bidding process that I have decided i will have this year for my time. (hopefully a more fair way to allocate ) I would also ask that you keep in mind that though our deal expired months ago. (also keeping in mind , that your understanding of the final payment terms neither reflected the emails or my memory, we finished it up your way. ) I have answered every call Brad , joslin, Ada or you, have made . reviewed docs over and over/ until once again, I was forced to insert myself strongly as I thought it dangerous not to. I made serious dollar and time concessions last year.very serious I am wiling to continue to accommodate some of your concerns , but I am, under no circumstances , none, willing to spend my time for free. its not fair. After cleaning up Carlyn's mess , which was a few weeks and 30 million dollars . We were both highly aware of the dire circumstances in which you found yourself last year, and in fact due predominately to its seriousness, and those very circumstances I took extra care in our negotiations . (you had claimed I had you over a barrel, ( a horrible position to be in with my very close friend.), unfortunately I fear that if you are not cautious ,in the near future, another barrel will appear of your own design ) I heard you when you said you believed i had already been paid for the work that is now required. The art partnership has fully answered all your concerns and discharged all my obligations and more so. . ( FYI Carlyns art partnership that you referenced is similar in only its title. ) You will also recall that you HOUSE OVERSIGHT 023344 required that my payments be at the end of my work not at the beginning as everyone else's .( my work was never to include hours upon hours of training your staff). I eventually agreed, this of course should make clear that the 2014 tax year that will close Oct 2015 is not covered by our past agreement at all. I pointed this very fact out to you when I initially proposed a multi year agreement right out of the box. you said you preferred not. As you said ,I have produced results to date, far in excess of even my own exalted opinion of my projections. I have devoted a monumental amount of my limited amount of time-- way, way in excess of our agreement. I will be fair, I am willing to roll in the amount still outstanding from last year if that helps .. However, As my best student , and my only one, you are now capable of doing most, if not all, of the required work yourself I can put my whiteboard away when you come to eat and just have fun, trade stories,. share moments ideas etc. . I am of course always available to guide you as a friend if you choose that route . always. It will take a great deal of your time , but you will not have to spend any more money on mine. We are scheduled to meet fri at 430 , I leave at 5 am sat morning. Date: Tue, Feb 24, 2015 at 8:20 AM Subject: To: Melanie Spinella Leon, Yesterday, I again spent hours upon hours of my time with your office. ,( speak to brad to get flavor) and you and i will discuss the results in gory gruesome detail on Friday. it mirrored many other weeks spent doing the things that I don;t have the time to do. In order to keep things in perspective, maybe reviewing an analogy I have used before with you, might be helpful. You and your family are a 6 billion dollar corp. with an income between 250 -500 million dollars per year. It contains a few operating biz's , a large wide array of existing investments, in various categories, a desire to enter into others. A panoply of loans, notes. purchases, wide range of all types of taxes. , planes. boats homes. . trusts ,grats. a crazy number of bank accts. ( with no oversight ) . law firms, acct firms, 800 page tax returns, foreign firms. art consultants. construction consultants bill payers, home mgmt.,vast multitude ofllc's , including foreign, and with all that you only have a combined overhead of less that 3 million dollars. I have previously sent you the very same note that i have enclosed again below ,this time with highlights . I wrote it to you over a year ago. As my acute disability ( selective memory) seems to have been raised as one of your concerns , as a rule I try to memorialize things in writing in an attempt to lay out issues that I fear may later turn out to be a problem. ie what i would and wouldn't do , - my responsibilities. etc and those things that are not. below you will find details of things that I thought needed to be done, so that you wouldn't find yourself in the very place where you currently find yourself however ,you chose to defer many of my suggestions- see below -,until only weeks ago. ! you chose to defer the jpm acct. the art partnership on and on - into this year. and though the 60- 50 40 timber emails all carried with it a clear warning that you needed to do something re personnel if it were to stabilize,- you chose to wait. ONE YEAR AGO Feb 17 2014 i wrote : With regard the more pressing issue I am uncertain of just how to proceed. I am torn, as my very strong inclination is not to be involved at all. It is extremely time consuming, delicate, fraught with many pitfall many that will make you very upset and a major pain in the ass. I wrote you months ago that the quality of the people involved need to be upgraded. ( lucky for me these last issues arose way before the beginning of my involvement ) I am also aware however of my overarching friendship obligations of ok, -given all the complexities who else can do it? problem. Your family office needs a daddy. children with good intentions are running around, sniping , nitpicking with little direction. As a stopgap measure I am suggesting , we put in Larry Delson to take charge Everyone would report to him. Eileen included. He would however work for me. this is not, by a long shot my first choice as I prefer only being responsible and standing behind my own personal work ( ie the word DONE will no longer be transmitted to reflect status stated by others ) With no commitment on my part whatsoever, to do it. So far as I have failed in my attempt in trying to think through the problem creatively. My organizations handling of the more complex issues I believe you HOUSE OVERSIGHT 023345 might find very costly, very ! ( however many structures available some risk sharing, maybe risk caps ,etc ) but would require my teams doing the work , not yours. Ada should be only a trust, grat administrator, not sure what role you prefer for Eileen as you hired her initially to oversee investments. whether Rich your controller stays or not, is not urgent. having Tom report to a new person,- is. coordination with Suydam Kathy Gregory, I would suggest limiting to one person. The increasing public profile needs to be taken into consideration. TODAY With your acquiesence , Eileen did not report to Delson ( he acting as a conduit directly to me) , she continued to provide bad info to both you ( cash flows , stock accts, structures. sales Etc) and me. and each time with my many annoying calls to you made immediately afterwards that she was g.....y!! No one was hired to run YOUR office until two months ago , no one was even interviewed and even now , Brad, a very nice man, is not even full time,(crazy ) Hours upon hours of time need to be spent training him. and his new staff. Eileen followed your instructions, not mine, in fact she continued to ignore mine saying " but Leon said " or" its on Leon's desk etc" , You would become frustrated when i pointed out each instance, of her obfuscation. originally you were given the clear choice, but to save money ,you chose not to hire my team. I was hired to do the architecture, you kept your own team. with Eileen at the head. instructions were given by me„ detailed but ignored by her. ( except in the instances where I inserted myself and personally had to do the weeks of grunt work ),ex. jpm morgan acct still not in use? That being said, If you do the cold calculation ,starting from where you were, to where you are currently . you have made a hell of a deal. -- negotiating down my original amount requested, calling upon our friendship and suggesting that the Carlyn mess was partially my fault. ( though in that specific example, I had never been asked to do more than merely provide you the name of the most highly recognized atty in the field, not consulted,nor even asked again for my guidance along the way. ). I accepted the discount as your friend. ( by the way „suggesting now, that your Tom is now that last word on tax characterization, frankly is a bit much,-). however - that is all in the past. In order to move forward I would ask that you realize that very unlike yours, My business is only comprised of my personal attention and my personal time . Time that I was forced to grossly overspend on your various issues last year. . As you are my very close friend I will not have you participate in a bidding process that I have decided i will have this year for my time. (hopefully a more fair way to allocate ) I would also ask that you keep in mind that though our deal expired months ago. (also keeping in mind , that your understanding of the final payment terms neither reflected the emails or my memory, we finished it up your way. ) I have answered every call Brad , joslin, Ada or you, have made . reviewed docs over and over/ until once again, I was forced to insert myself strongly as I thought it dangerous not to. I made serious dollar and time concessions last year.very serious I am wiling to continue to accommodate some of your concerns , but I am, under no circumstances , none, willing to spend my time for free. its not fair. After cleaning up Carlyn's mess , which was a few weeks and 30 million dollars . We were both highly aware of the dire circumstances in which you found yourself last year, and in fact due predominately to its seriousness, and those very circumstances I took extra care in our negotiations . (you had claimed I had you over a barrel, ( a horrible position to be in with my very close friend.), unfortunately I fear that if you are not cautious ,in the near future, another barrel will appear of your own design ) I heard you when you said you believed i had already been paid for the work that is now required. The art partnership has fully answered all your concerns and discharged all my obligations and more so. . ( FYI Carlyns art partnership that you referenced is similar in only its title. ) You will also recall that you required that my payments be at the end of my work not at the beginning as everyone else's .( my work was never to include hours upon hours of training your staff). I eventually agreed, this of course should make clear that the 2014 tax year that will close Oct 2015 is not covered by our past agreement at all. I pointed this very fact out to you when I initially proposed a multi year agreement right out of the box. you said you preferred not. As you said ,I have produced results to date, far in excess of even my own exalted opinion of my projections. I have devoted a monumental amount of my limited amount of time-- way, way in excess of our agreement. I will be fair, I am willing to roll in the amount still outstanding from last year if that helps .. However, As my best student , and my only one, you are now capable of doing most, if not all, of the required work yourself I can put my whiteboard away when you come to eat and just have fun, trade stories,. HOUSE OVERSIGHT 023346 share moments ideas etc. . I am of course always available to guide you as a friend if you choose that route . always. It will take a great deal of your time , but you will not have to spend any more money on mine. We are scheduled to meet fri at 430 , I leave at 5 am sat morning. Date: Mon, Apr 21, 2014 at 11:39 AM Subject: trying to bridge the gap. To: Melanie Spinella_____________________________ you were at 30 30/ me at 60 40. . / proposal 50 /25 and in additon I would be allowed to recommend 15 from directly from your own foundation. All payments to be made in addtion to currently owed. so $40 on april 25 , $30 june 15 ,and the alreadly owed $10 as planned on oct 15. I would direct the 15 charity in the next 12 months, and the last 25 to be paid on conclusion. leon 10 am - Arrival at White Plains / Westchester Airport FBO and US customs is "Jet Systems Aviation" Adress: 85 Tower Road Hanger E, White Plains, NY, 10604 Telephone Date: Wed, Mar 25, 2015 at 11:52 PM Subject: previously sent To: Melanie Spinella I heard you when you said you believed i had already been paid for the work that is now required. The art partnership has fully answered all your concerns and discharged all my obligations and more so. . ( FYI Carlyns art partnership that you referenced is similar in only its title. ) You will also recall that you required that my payments be at the end of my work not at the beginning as everyone else's .( my work was never to include hours upon hours of training your staff). I eventually agreed, this of course should make clear that the 2014 tax year that will close Oct 2015 is not covered by our past agreement at all. I pointed this very fact out to you when I initially proposed a multi year agreement right out of the box. you said you preferred not. As you said ,I have produced results to date, far in excess of even my own exalted opinion of my projections. I have devoted a monumental amount of my limited amount of time-- way, way in excess of our agreement. I will be fair, I am willing to roll in the amount still outstanding from last year if that helps .. However, As my best student , and my only one, you are now capable of doing most, if not all, of the required work yourself I can put my whiteboard away when you come to eat and just have fun, trade stories,. share moments ideas etc. . I am of course always available to guide you as a friend if you choose that route . always. It will take a great deal of your time , but you will not have to spend any more money on mine . We are scheduled to meet fri at 430 , I leave at 5 am sat morning.So there are no surprises 50m for the year. . or 30m for until 7/ 15. you can roll the balance for last year as a concession. half up front. no more all at the end. ive spoken to brad every day. more questions than answers. joslyn cannot be left unsupervised, his answers are knee jerk . eillenn told me this , that the other Date: Thu, Mar 26, 2015 at 12:07 AM Subject: To: Melanie Spinella H you need to build an entire office from scratch. no question that was never my obigation, - systems , personel. finance tax, bookeeping„office. complinace. investment, monitoring, banking loans coming due, review. gs jpm gs, . . plane boat houses construction, new will,. phaidon sale. you are no further ahead today than my nov memo layed out = no real candidates. etc.. Ill redo the art partnership under new restrictions of course at HOUSE OVERSIGHT 023347 no charge, and review the work done by tom/ joslin. joslin you and I should sit. you won't like it. AT ALL> he is afraid of telling you the story, as he belives brad is your guy and does not want to get fired. ada still refusing to share income tax opinions based on privilege , not under control at all. ? ? joslin said that murphy is not the cfo, as you told me but the coo. and the cfo is the same guy that reported to andrew, mistakes after mistakes not picked up by murphy who joslin described as a kind buffoon . he suggested a new ceo or coo who can make decisions. someone with some financail experience, he asked for a chief decision maker. 50 for year roll in money owed. 30 till july, most up front needed Date: Tue, Mar 31, 2015 at 3:25 PM Subject: To: Melanie Spinella Nov of 13 : I told you tom Eileen and Ralph were not up to the job, you disagreed very vocally and strongly, " Ralph wrote the book, Tom has been doing it for 15 years and Eileen ran the trading desk at Morgan Stanley. " Ada who had been working on all your documents for years while at the bank had been brought in- house but created more issues that didn't exist. and phaidon was its own animal Dec 13. you were again annoyed that i said that they needed to be replaced and said "i was talking out of both sides of my mouth." first time ( email available) Jan 14, you decided that no third year was necessary for my help. and i told you i thought that unwise and even suggested giving you an option at 40 m so there would be no tension Mar 14, I told you that to do the job right, my team would need to do it. not yours it would not be inexpensive, but it would get done properly, you chose not to do itand said lets wait and see April 14. We agreed to clean up various past mess.with the end of my work OCT 15th only then would i get paid.. urged JPM ( first of 14 reminders) GS and db accounts to be set up in order to bring your financial structure into the 21 century July 26 , I came to bens party, said new people needed to be hired, keep Eileen till end of year, and Ada till march, you suggested getting ada out earlier oct structured the art partnership , but you wanted to wait until you fully understood ramifications formed the doc in dec to have it in 14, nov/ dec 14 I told you I considered my work complete separate from art partnership. gave list of things to do. three months of you and your high school friend , trying to build a house with little of the relenavt experience, its silly . still no accurate numbers accounting , charts, etc jan 15, I told you joslin cannot hire people, has not so for more than 5 years, former job in a public accounting firm. april 15 . no senior accountant even in the wings. joslin talking about reaching out to hire the only person he knew( worked in the past with dagazsitno ) and i interviewed 15 months ago. and rejected. low level. He does not want to hire himself out of a job, spoke to brad last night he wants a coo so that he does not feel demoted your choice!, ( brad maybe does have insight - to your credit, might have been right when he said- jeffrey you should realize this is only about leon not wanting to pay more money, ( i ignored his summary, along with his comments on the risk of fracturing HOUSE OVERSIGHT 023348 summary I can either do it for you or not. if i do it it means finding hiring organizeing, structuring reviewing re negotiating, bring in my team under my control not brads. . stop -gap accounting - my people getting the books software and procedure in shape. setting up the various brokerage and bank accounts and rationalizing them, organizing Melanie, TPS , house, and all the intra family notes outstanding, overseeing the phaidon mess.maybe sale re do some of estate given the new circumstances. etc. I 've responded to every brad question , given him first lessons, not a good use of my time or his. he should administrate, follow up, have signing authority instead of eileen, ( AFTER rationalized accounts ). holding a position of trust. ONLY talk whenever you like, NO STRESS, Mort had a skiing accident and sultan not fully comp es mentes. no stress please for either of us . both of our reserves which are not insubstantial , can use a break Date: Tue, Apr 7, 2015 at 4:29 PM Subject: To: Melanie Spinella agenda for tomorrow. 1 building an office from scratch. who does it. ? so far little or no progress in real terms. . brad should remain and can administrate, follow up methodically, . has no idea of corrrect questions to ask. or understanding of family office issues. procedures checlks and balances. etc .. consultants , diana goldner foundtaion woman?. office. focus. 2. without strong , very stroung direction, joslin will not make it. does not know where to focus. who to respond to. and how. unfortunately now getting more and more answers like the powers that be , want it that way.?? 3. the priority list is still virtually the same , since dec. . accounting system. redone from scratch. etc. 4 . it will take 9 months. at a minimum now. . an outsider brought in when everything is clean, including phaidon, notes. eileen. banks, jpm db, bam, etc. 5 disposition, of Phaidon. art space regan etc.( ressler??) . sale of boat. plane . art, stock, investments, athene? etc, tra, brh. 6 . new IT . complex. household . payroll insurance . recurring bills. 7 estate modification given new circunstances and altered probablities. ( use etc ) 8 charity, new trusts,!!d IPI< harvard. fees, I spoke to brad and made him aware of all my concerns and propsals to move forward. he is desperate for help Date: Tue, Apr 14, 2015 at 11:53 PM Subject: To: Melanie Spinella saved you 500k at the last minute, . brad has had the same chart since march 16th, its his job to review NOT MINE .appears he is one of those living in the dark leiwe. I found 8 million dollars today, missed deductions. . not yet in the numbers,.? Date: Tue, Apr 21, 2015 at 1:10 PM Subject: To: Melanie Spinella emblematic of my frustration and ,in the end what I believe is a waste of our time energy money and resources. is the very simple question of bidco bank accounts. 4 months ago I asked the question, does it have a bank account and if so , who has authority, where is it located and what transacations ran through it. it is only one question out of hundreds that need to be answered. hundreds. . you asked that i not behave like Zeus and try to explain why I want need certain things. since i said to placate Brad's inquisitive ness and his desire to learn I said a filing might be required. instead of merely getting me the answer. he has talked to joslin paul weiss , you, you wanted to ask brad karp. ( maybe a filing that reopened things, ) none of this as a practical matter has any influence upon the ultimate action taken . I merely needed to HOUSE OVERSIGHT 023349 know a simple answer. and today after asking at least every week since then do not have an answer. I have been trying not to add stress to your day. i try to explain things and take the time to do so gently, ( not my forte . this is one question out of hundreds. the fact that a 21 year old was in the office only xeroxing for a month, was obvious to everyone in the office. having a 26 year old xeroxing instead doesnt move us forward, answers first. copying old files. can wait. Date: Wed, Apr 22, 2015 at 1:56 PM Subject: another flowery email. To: Melanie Spinella I am sorry. I realize you are under tremendous stress, In Bedford you asked me for my help I could not have been more clear that thought it very unwise as in my words I did not want any financial arrangment between us, it risked conflict and tension what neither of us needed more of and did not want to risk torturing our friendship into the likes of the kind you have with Mark nor Josh, : now,- I dont have anyone but you yelling at me, in my own house. no one. it is highly unpleasant but I am trying my best to be understanding. sorry . From the outset and as you told me you recall. i tsuggested that three years should be the period of engagment. as planning is not a one year excericse . you declined to commit to a number of alternatives presented to you for payment of the third year. I told you in nov that you should decide whether to now sign on for that very third year as the vast majority of my work ended on oct 15. you recently told me you thought i was kidding. .you hired brad patting him on the back that after months of inquiry he can now, finallly tell you which Ilc owns the cars?? once he has all the facts what next ??. whether or not you refer to a portion of the third year as after care, or whatever term besides 'scoundrel you choose to use, I m not sure why you assume now it should be free.( I HATE THIS CONVERSATION < HATE , ) and i heard you when you said you told me what was I work still to be done you thought valuable enough to pay for. please tell me. and then we can decide the next steps if any. I consider my work rarefied art. I guess the value is in the eye of the beholder. IT reminds me of those people looking at a modern art piece and saying " my child could do that" . hope you are feeling better. Date: Fri, May 1, 2015 at 12:50 AM Subject: To: Melanie Spinella ada and brad are respondlnle for the loan,. docs, at a minimum, leon he hasn't read the financial statements SINCE DEC. !!. impossible ,had he done so the silly numbers jump off the page . ( sent in another email ). it is a financial office., 190 million sitting unused in CASH , budget and planning person for what , its not a publice co. ? townhouse construciton , household operations, boat, plane, taxes, we went through this with the cash flow, you and i know approx how much each will cost. its a week job not a full' time one- ada has no lien copies. none. ?! impossible not to know, ask, quesiton? two senior accountants CPA s. not the 75k girl that they hired, . IT professional backed by a firm. high quality,can we tap apollo resources? new lawyer , heather level . new receptionist, and bookeeper. get rid of ava. next could be new office ,new furniture „ the whole place reeks of cheap. IT IS MAY< I have not been asked to interview one person to date. not one. having cpas in there tomrrow woudl go a long way. i dont understand the time line, coo first. ? in by july?? cpas in by sept. tax return due oct 15. ? Date: Fri, May 1, 2015 at 2:36 PM Subject: To: Melanie Spinella________________________________ I know that both you and I heard brads'. im out of here if i dont get a coo. . sorry,. i know that neither of us have stood in the way of his finding/ gettting one.. JPM account DB account GS account, ??? its MAY 1. nothing in the first quarter and these are only papers that need signing. I suggest your thinking on my role and compensation for my work might benefit, from a mental shift - think mark and josh, without the mutual resentment ( HAHA) only in terms of sharing ,thanks, I am and have been your financial partner i.. rectifying circumstances that appear in hind sight unexplainable. I wish you woudl have asked me earllier to review your things , but i understand. I do know that soley as a result of my actions HOUSE OVERSIGHT 023350 your personal bottom line has increased dramatically, if you had thought of me as your partner in this endeavor , instead of an employee, i think your reaction to sharing t benefits would be different. If you recall, you wanted me to be paid , unlike others at the END of my work. we discussed this ad nauseum, and agreed OCT 15, last year was the end. You had wanted more comfort initially on the art partnership so that date was delayed. It has now been six monhts since then, your concept of aftercare. . for free. was already unique, in your words this has to have an end.( weaned ) if the actions of josh and mark led to one hundred million dollars , what would be their share. Im not sure why it is different in your mind, but i respect the fact that it is, Is it because their work seems harder. it cannot be simply because they devote more time to you .or it appears to involve more effort. I am happy to continue to play a partnership role. as I have been in many areas of your life.. I am also happy to move on and have no more of these emails. I find them as tedious as you do. if you prefer a partnership structure, ok with me, I tried to minimize the amount of money i would recieve by making it a flat fee . as i wanted you to feel good and have no second thoguths somehow if the payment comes from a partnership structure you seem relaxed as opposed to writing a check, I focus on trust and friendship first, and the fact that you don't include josh and mark in that category, gives me great pause . I proposed 33 percent of money made for you.. in the past you agreed that amount. it will be huge, but ok with me, I can talk today at 945 as you suggested. or if you woudl rather over the weekend ok Date: Fri, May 1, 2015 at 7:08 PM Subject: Fwd: Picasso agreement - question To: Melanie Spinella silly Date: Fri, May 1, 2015 at 12:27 PM Subject: Picasso agreement - question To: Brad Wechsler L _ 1>, "Jeffrey Epstein cjeevacation@gmail.com)" Brad and Jeffrey, Gagosian has one final change to the Picasso agreement. As you know, we have structured this agreement with the Buyer as either Narrows Holdings LLC or AP Narrows LP, and given both of those entities the right to assign the agreement to any one among Leon, Debra, the kids, or family trusts including AP01 and AP02. Gagosian wants us to agree that, if Narrows/AP Narrows assigns the agreement to someone else, Narrows/AP Narrows "shall not be discharged from its liabilities under this Agreement and shall remain primarily liable to Seller." Larry is concerned that we might assign to the Black kids or to a trust that has no assets, and then when he has to sue us because we don't make the final payment of the purchase price but have possession of the art, the entity/person to which we have assigned the agreement has no money. I think this is a valid concern and that we should agree to it. However, Ada just reminded me that it is possible that Narrows/AP Narrows (really, Leon's) agreeing to effectively guarantee payment by the assignee might be considered a gift to the assignee. In the discussions with Alan about rearranging the bank loan once AP Narrows is operational, Alan agreed that there could be deemed to be a potential gift from Leon to AP01/AP02 if Leon provides a guarantee to the bank that is for the benefit of the trusts as partners in AP Narrows. Alan suggested mitigating this risk by having the trusts sign side agreements with Leon which say that if AP Narrows defaults on the loan and the bank goes after Leon on his guarantee, the trusts will make him whole. This issue only arises if we assign the agreement. The risk is also limited in time because it would run from the moment we assigned the agreement until the final payment is made, which even if we assigned immediately after signing, would only be 11 1/2 months. Shall I agree to Gagosian's request that Narrows/AP Narrows remain liable even if they assign the agreement? I'm in the office if you would like to discuss this, but I would love to get back to Gagosian ASAP so we can have this agreement signed today. Thanks, HOUSE OVERSIGHT 023351 Heather Date: Mon, May 11, 2015 at 3:08 PM Subject: To: Brad Wechsler Richard Joslin lets look at funding the art partnership begin with 100 m of unencumbered art. plus 20 inveestment. and the same amoiunt of value from trust. leon should choose b trustee and begin to use mechanics. . later we can amend and add. 2 hire an IT person asap 3.1 would hire jerry the woman. gittis. person 4 .I will find a subpart k person to handle partnership acct 5 , accounting software upgrade, onlilne banking needs to be seamless 6. not sure status of bringing plane boat acct inhouse? 7 prepare fbar report for june. draft next week 8 pahidon actuals vs projections. . new valuation 9. new valuation of tra contract? jpm db goldman sachs acct? new Ilc? review of dec 31 books for all entities? bfp . etc Melanie S inella , Ada Clapp Date: Wed, May 13, 2015 at 3:04 PM Subject: Fwd: jobs ahead To: Melanie Spinella the list that we discussed.. i spent time with brad again. re the candidates filing due, this week, next month,. Date: Sun, Dec 28, 2014 at 5:18 AM Subject: jobs ahead To: Brad Wechsler Melanie Spinella , Ada Clapp 1. review accounting system. Book keeping softaware. staff, ( senior accountant ) methods on line banking, brokerage. cash mgmt. airplane reimbursement. boat sale. art purchases sales use and sales tax. tax filings FBAR FATCA, gaming commsion, pfics, insurance . uk co law. 2. review docs for TRA BRH grats, trusts, heritage will, insurance, art lending. medical, springing powers. two fire drill books. one needed for injury, other for death 3 review bills. boats , planes, legal, ( PW, McFarlands all outside. legal and accounting. Toms bills over 400k. house projects. south ny ben 4 cashflow projections tax projections , interaction with Apollo accounting tax, Phaidon ,art space ,and Regan. legal accounting. audit 5. children meetings, review to date and allocations 6 review all role in payables. files scanned, no paper 7 review invesmtents for tax basis and unrecognized gain 8 schedule of all hedge funds . redeemables commitments etc. 9 charities pledges strucutre, staff, Date: Mon, May 18, 2015 at 2:17 PM Subject: agenda for tomorrrow To: Jeffrey Epstein , Melanie Spinella as a reflection on your voiced spirited concerns in the what have you done for me lately category ? in the beginning . there was eileen and tom. ( eve and adam,-- however it appears, she declined to HOUSE OVERSIGHT 023352 eat the apple from the knowledge tree) . that was it. ada was at the bank but reviewing does. carlyn was in the kitchen making mush ( abel and cain) books as they were mystersiously called was being kept soley by eileen, with little or no input ,correction or advice from tom. herarely if ever asked questions. expenses ie airplane was done in house apollo. (1031 exchange blown etc) at this time as I recall you got quite annoyed, and agressive and initiated the" talking out of the both sides of your mouth" tiddy, when i suggested that the level of their competence left much to be desired. ( ralph lerner's came later ) .response - eileen ran the desk, tom is a partner, ralph wrote the book etc re tax there was almost no oversight of income, estate, gift ,sales and use, transfer excise etc . IRS SEC GAMING NYS. real estate, valuations ( many )tax filings- disclosures, etc. re grats trusts defect trusts, Ilcs corps , trustees , partnerships. foreign corps. 100 bank accounts. gift taxes„ loans, notes. payables. expenses. . , insurance.( life, art, split dollar), cashflows, operating biz„ investments, contingent liabilitiites.( funds, miami ) , commitments dividends, BRH TRA, shareholder agreements, bank loan agreements. wills, construction„ contracts planning permits etc. .employ rules. checking account reconciliations, crediti cards. jewelry, cost basis ,( art stock etc.) foundations regs , brokerage accts, old stock certificates. stock options,( environmental solutions still not done !). estate tax calcualtion firedrill, ( note ,basis etc ) low basis , step ups , however with no accounting system, no reveiw of boat expenses plane expenses etc. . many outside counsel with litle or no coordination. Paul Weisss , Mcdermit Will, Macfarlanes. Price Waterhouse , Reich, withers bergman, Empire„ akin gump, bbd seidman, Wendy , Apollo in house. lumber, knowledge universe, ennvironmental, solutions 12 mu i in stock, . on and on the priority list that you asked me to prepare for brad and you in dec , unfortunatlleyso far, little change ie no accounting system that ties, no, brokerage accounts though strongly suggested, jpm db, gs, april of 2014 . IT antiquated dagastino hired, no inut from me, julie, temps, paralegals miriam. etc. still need new accounting system - on line banking. staff hires. ( seprate from samantha two years out of school ). audit system, . ?? john murphy? joslin? dag? eva?. i strongly suggest workers at the highest level of competence. two senior accountants. not managers workers who will get into the weeds. partn expertise„ replace ava, get heather help. a new person legal , new IT,system and person, way way overdue, new receptionist, bill opener, ability to oeversee in house, boat plane review household ( 12million ) review, filings- partnerhip accounting,- familitarity with grats, trusts etc . audit system put in place. that should be the easy part. then strategy to deal with: As new facts on the ground develop , phaidon debra, children meeetings, ? stock sale sale of art„ apt( large gain ), 1031 trade in , plane depreciation, boat sale. construction, brad will oversee brokerage and investment, ?? pe. real es, . publishing, grats, tra, brh ( death). foundation , museum, tax proejctions cash flow projections, cooridnation with tax from apollo. etc Date: Fri, May 29, 2015 at 2:53 AM Subject: ulysses 2.0 _________________________________ To: Melanie Spinella___________________________________ I realize it is only due to a lack of understanind of the job ahead. and not out of any sense of unwillingess to pay - as opposed to merely hiring people to set up a family office, someone will have to do the following- separate from the art partnership which is my responsiblity. there still needs to be a huge amount of work done for 2015,16. not to mention that brad at the moment is going to have train the incoming team?? your call strategic decisions re estate and other planning, sale of phaidon etc. . in addition setting up for the accounting for each strategy ie.: income, estate, gift ,sales and use, transfer excise picasso, 1031 calder. . review and detailed oversite of IRS SEC GAMING NYS. real estate, entity valuations ( many ) tax filings- disclosures, follow up of grats, trusts ,defective trusts, Ilcs corps , trustees , partnerships. foreign corps. 100 bank account need to be HOUSE OVERSIGHT 023353 rationalized, not only having brad step in to children investments. gift taxes, trust, loans, notes. payables. expenses allocations . . , insurance.( life, art, split dollar), cashflows, operating biz„ investments, contingent liabilitiites.( funds , miami ) , commitments funds and charities, dividend treatment -important review of transcations relating to BRH ( amendments) TRA sale ( nuanced ) , shareholder agreements, bank loan agreements new bank relationships. . wills, construction accounting and oversite , contracts planning permits etc. .employee rules, regs, . checking account reconciliations, crediti cards. jewelry, cost basis ,( art stock etc.) foundations regs , brokerage accts, . stock options,( ie environmental solutions still not done !). estate tax calcualtion firedrill, ( note ,basis etc ) review of boat expenses plane expenses, depreciation issues refunds etc. . rationalize all outside counsels and accounting firms Paul Weisss , Mcdermit Will, Macfarlanes. Price Waterhouse , Reich, withers bergman, Empire„ akin gump, bbd seidman„ Apollo in house counsel. set up and oversee brokerage accounts at JPM DB GS and thoughfullly trade . new IT system from top to bottom full time IT person new accounting system - on- line banking cooridnated with reports . fire drills as per caruci ( he sounds good ) and. audit system,s . review of john murphy? joslin? dag? eva?. in house, review household ( 12million ) review, filings- partnerhip accounting,- familitarity with grats, trusts etc . audit system put in place. that should be the easy part. then strategy re: As new facts on the ground develop, phaidon debra, children meeetings, involvment, trustees adjusted, stock sale sale of art„ apt( large gain ), 1031 trade in, plane depreciation, boat sale. construction, brad will oversee brokerage and investment, ?? pe?. real estate?, . publishing, grats, tra, brh ( death). foundation, museum, tax proejctions cash flow projections, cooridnation with tax from apollo. etc you are sitting on over 100 m of cash???!! Subject: Re: we're calling the sales tax guy at 6:30 pm - I'll come to your office To: Richard Joslin Brad Wechsler , Heather Gray sorry but this is emblematic of the silliness that appears to continue. ..... 1. How can we ask for a legal opinion when it is crystal clear that we don't yet have accurate facts or numbers , f. 2 Invoices have not been reviewed! corporate structure is convoluted and unexplored in detail. ( was the boat captain on the call?) 3 Paul weiss is the attny, and should be charged with getting us info. . 4. Bringing in yet another outside lawyer without full vetting and consideration, a waste of time energy and money. . 5. ex. what is the location of charters shown on the invoice? do you know. . ? if th invoices are incorrect, does that give us any comfort in trying to defend an audit. . I saw three invoices only, and each had a different owner or address . . Date: Mon, May 18, 2015 at 8:17 AM Subject: agenda for tomorrrow To: Jeffrey Epstein , Melanie Spinella as a reflection on your voiced spirited concerns in the what have you done for me lately category ? )):: . in the beginning . there was eileen and tom. ( eve and adam,-- however it appears, she declined to eat the apple from the knowledge tree) . that was it. ada was at the bank but reviewing docs. carlyn was in the kitchen making mush ( abel and cain) books as they were mystersiously called was being kept soley by eileen, with little or no input ,correction or advice from tom. herarely if ever asked questions. expenses ie airplane was done in house apollo. (1031 exchange blown etc) at this time as I recall you got quite annoyed, and agressive and initiated the" talking out of the both sides of your mouth" tiddy, when i suggested that the level of their competence left much to be desired. ( ralph lerner's came later ) .response - eileen ran the desk, tom is a partner, ralph wrote the book etc re tax there was almost no oversight of income, estate, gift ,sales and use, transfer excise etc . IRS SEC GAMING NYS. real estate, valuations ( many )tax filings- disclosures, etc. re grats trusts defect trusts, Ilcs corps , trustees , partnerships. foreign corps. 100 bank accounts. gift taxes„ loans, notes. payables. expenses. . , insurance.( life, art, split dollar), cashflows, operating biz„ investments, contingent liabilitiites.( funds, HOUSE OVERSIGHT 023354 miami ) , commitments dividends, BRH TRA, shareholder agreements, bank loan agreements. wills, construction„ contracts planning permits etc. .employ rules. checking account reconciliations, crediti cards. jewelry, cost basis ,( art stock etc.) foundations regs , brokerage accts, old stock certificates. stock options,( environmental solutions still not done !). estate tax calcualtion firedrill, ( note ,basis etc ) low basis , step ups , however with no accounting system, no reveiw of boat expenses plane expenses etc. . many outside counsel with litle or no coordination. Paul Weisss , Mcdermit Will, Macfarlanes. Price Waterhouse , Reich, withers bergman, Empire„ akin gump, bbd seidman, Wendy , Apollo in house. lumber, knowledge universe, ennvironmental, solutions 12 mu i in stock, . on and on the priority list that you asked me to prepare for brad and you in dec , unfortunatlleyso far, little change ie no accounting system that ties, no, brokerage accounts though strongly suggested, jpm db, gs, april of 2014 . IT antiquated dagastino hired, no inut from me, julie, temps, paralegals miriam. etc. still need new accounting system - on line banking. staff hires. ( seprate from samantha two years out of school ). audit system, . ?? john murphy? joslin? dag? eva?. i strongly suggest workers at the highest level of competence. two senior accountants. not managers workers who will get into the weeds. partn expertise„ replace ava, get heather help. a new person legal , new IT,system and person, way way overdue, new receptionist, bill opener, ability to oeversee in house, boat plane review household ( 12million ) review, filings- partnerhip accounting,- familitarity with grats, trusts etc . audit system put in place. that should be the easy part. then strategy to deal with: As new facts on the ground develop, phaidon debra, children meeetings, ? stock sale sale of art„ apt( large gain ), 1031 trade in , plane depreciation, boat sale. construction, brad will oversee brokerage and investment, ?? pe. real es, . publishing, grats, tra, brh ( death). foundation , museum, tax proejctions cash flow projections, cooridnation with tax from apollo. etc Date: Tue, Jun 30, 2015 at 12:23 PM Subject: To: Melanie Spinella __________________________________ 1.I believe I have heard you , but i wanted to make certain that I have understood Though after much discussion ,- much! you were adamant that i receive my fee only at the very END of my work, oct 15 , this was a long discussion but you felt very strongly at the time . you now feel that as it was a very large sum of money . some of my time this year should be spent on your recent concept of "after care ". - and that after care should be for free. I have continued to pay others as well. I have asked and you have previously said you would lay out for me what you thought was encompassed by the concept. that was end of january Training brad?? who was your choice . not mine ,by a long shot. only brought on in january? ? hundreds of hours spent . eileen debrief? 2. boat. plane household ex[penses. personal review? , trying to create accurate ledgers of capital expenses . so to minimize future gain.? 3. phaidon - review from head to toe? though we agreed many times in the past this was not my responsbility, 4. overseeing the opening of trading accts. proposed and sent over first docs in april of 14. .5. art partnership.? we agreed though the draft was sent in sept14 . and still not done though little different from first draft. . 6 picasso contract? 7 art sale 1031 8 airplane review? 9. IT system implementation. ? tra brh sec gaming comm, foerign filing , tax, disclosure. fondation returns. ? planning for 16? not sure . 10. insurane review with josh? stock sale prep. ? filing ? I am available by phone. you mentioned my travel schedule ----last yea,r I canceled three European trips and two to seatle , none to my benefit. I have been consistant, I dont have any new proposal , do you ? though i am" complicated" , I have no intention of trying to convince you of value, its silly, 000000000000000000 i think if I have correctly deciphered your sophisticated code - should represent -drool Date: Tue, Mar 3, 2015 at 5:18 AM Subject: Fwd: HOUSE OVERSIGHT 023355 To: Melanie Spinella lets set a time to speak today if possible . 30 minutes or so. my schedule is tight From: jeffrey E. Date: Mon, Sep 21, 2015 at 6:36 PM Subject: agenda for today 5 pm? To: Melanie Spinella___________________________________>, Brad S Karp 1. put someone on asap to ascertain if she is still in london. 2. set up conference will uk criminal and uk counsel. a give them more facts. 3. choose method of message delivery, my choice. - two highly respected former ---- fill in the blank, immigration, scotland yard. sfo. . who may knock on her door and present the terms. 4 if not. an alternative method. 5. Is it possible to find out if she has gone to authorities? tabloid lawyer. 6. have the same types of individuals availble in new york if she decides to return as stated. . i prefer former fbi, or immigration one man one woman. . 7 from opening a DA investigation to arrest. how long? 8, can we open a file in either jurisdiction, and maintain confidentiality. Date: Mon, Sep 21, 2015 at 6:48 PM Subject: Re: agenda for today 5 pm? To: Melanie Spinella Cc: Brad S Karp I think that Melanie should set up a separate email account for this correspondence. she currently is on an apollo server. There is not even a good solution. all have substantial risks, we are dealing with a wholly unpredictable and bad minded person. I and Brad can only make suggestions/actions each less than stellar. - that being said we should do our best to have all the facts . options etc. and to distinguish fact from opionion As the consequences of any decision is likely to have some very bad parts , Leon needs to be cognizant of as much as the downside as we can adequately foresee. Date: Wed, Sep 23, 2015 at 12:07 AM Subject: Fwd: To: Melanie Spinella jan 2 of this year Date: Fri, Jan 2, 2015 at 2:55 PM Subject: To: Melanie Spinella_______________________________ Leon, I decided last week that there was little or no upside in disturbing your well earned holiday especiaily as you seemed so peaceful happy and smiley ,getting yourself in shape and truly enjoying your family time. etc. however the situation in your family office is unresolved. I am aware that brad starts monday howver, two last days of the year madness. timber.deal not complete no jpm,acct activity no partnership docs, old stock sales not complete , no bank doc redo. no phaidon note restructure, ., no boat expense review, airplane same ,topco midco.etc still not finished ( trustee ) , projections mixed with fiction. , legal exp out of control. no care for admin, silly ( audit). tom conversation with joslin. notes. debra, trustee notes. trustees hiring . bens audit. interest payable made hoopjumping last day of year. after weeks and months. of lectures , gifts to discuss- staff. -houseproject mgmt. . I will continue to try, I had offered ajoint call with eileen before you left. as i said before , joslin takes instructions from eileen. he said it was made clear to him that he doesn't work for me but works for you. . I tried. Date: Tue, Sep 29, 2015 at 8:39 PM Subject: To: Melanie Spinella jeffrey Brad Wechsler is asking if you could meet for a half hour with him and Rich Joslin to discuss Use Tax Refund. Below are available dates/times...below that is your schedule. OK for me to schedule in?: HOUSE OVERSIGHT 023356 NO sorry not until i hear from leon leon. to be fair, I had sent the first note to you one year ago . stating that my work would come to an end on oct 15. that day had meaning as everything would be closed, you asked that i continue to help brad. as of nov though he would officially start in jan. I said ok, but..... " you told me to continue as we would work something out" I told you my fee then was 40. feb you came with ben while kathy ruemmler was here. and said next week, debra got bad news. and I quickly prioritzed not adding stress to your situation. I wont regurgitate the interim, though millions of dollars were saved since. millions. . it is now one year later and you propose 10 mIllion , plus a contingent fee . I have said that i would work with you, and if contingent and a percentage of something. I strongly believe that is not in your interest. I continue to put our friendship first and dont want you to write a check for over 100million andthe i will have to listen to lewie for the next few years. but if you prefer over my objection a percentage deal then it should be of all savings not just phaidon. ( a random concept) . The idea that i am somehow even marginally responsible for neither you nor heather, ever telling me that there was an unresolved issue, though you said you had been pinged a number of times is emblematic . I can do a call with you and Karp. anytime you like today, but i can assure you 100 percent that there is no light between our positions. ZERO. and he is ready to do his best to try to explain it to you. Date: Thu, Oct 1, 2015 at 11:03 PM Subject: Fwd: To: Melanie Spinella to refresh your recollection, as 4 states. 40 a year for three years. as i said today. . the other was in addtion as you recall. Date: Thu, Apr 11, 2013 at 4:02 PM Subject: To: Melanie Spinella 1. 80 percent of contracted job is accomplished, now drafting ,signing and few critical decisions on your part still await , will fill in nec blanks, 1, how much of upside to kids. , 2, protections . 3 allocations. 4. charitiable, inventory, securities, 2 .to engage the second phase if you so choose , and considering there is only 8 more to be paid this year in oct, for the job now almost completed, total of 23. that was agreed only for history fix. 3. with the necessary proprietary protections , proposal is for first year only an additional 17 . making it 40 , but full year balance on signing, ie 25. takes care of 2013 4, moving forward, 40 per year ,( approx 1 percent ) for three years, to be credited against an agreed formula. Im open to suggestions total approx 120 for new workover 3 years , benefits to you over the next 20. 5 , can consider interests other than cash as payment. ? 6. need to speak re , bankers, valuations, mechanics and their continued importance. Date: Fri, Oct 16, 2015 at 4:38 AM Subject: To: Melanie Spinella_________________________________ Office, - ada goes. , hire heather a paralegal. Joslin goes or is closely managed by new cfo with tax experience. . castrucii goes asap.as he merely adds to mess.( too many people, ex 7 people or more to pay a bill ) eva goes. outsource as much as possible. . bookkeeping systems built from scratch, airplane restructure, boat. same, new grats. phaidon sale , decide on artspace survivability, regan,. do the kids really want these? , children accounting ie bens house.etc. re do estate for new facts. redo loans, trading accounts activity, . gaming -foreign- disclosures. . BRH TRA re thinks. household and construction architects. . redone. art partnership , choice of paintings. . re do structure of consultants. tax re family office. . decide if investments are a realistic option in the next three years.. insurance, operations. airplane, etc. . art foundation , private. max charity contributions, financial reports. still waiting. ? on line banking, . tax planning, family office deductions ( profit center ) . airplane certificate, redone jet aviation redo. . paper gigi ( E )trust to avoid gift tax.. today is Oct 15 HOUSE OVERSIGHT 023357 With your full knowledge I paid out 8 mil to my staff before june, . so i guess I can safely assume that after consideration of all the things I did for the entire past year separate and apart from your unique free "after care" concept. , what you thought was ultimately fair was the contribution of 5 million to a foundation and a total of 2 million dollars to me. Date: Fri, Oct 16, 2015 at 1:08 PM Subject: To: Melanie Spinella . I think you should consider the fact that your family office will be the most central component of what you leave to your children , wife heirs. it is the core of your assets. your art might be sold. your houses may lie empty, the apollo stock could be sold. you will pass on your office, . it will be the primary player in your estate tax. probate, transition. Brad has taken it from a D minus to a C minus, If I were you I would set the goal of an A. just like your paintings. . Like a house you could attempt to renovate it. it will take more time and money. or. in essence as I suggested in dec of 13, start from scratch. A financail head of office. - brad could move to being richards replacment as trustee. . barry cohen would be perfect but carries the trustee taint now. . take a tax partner from a major firm. to replace joslin, cost 1 + mil . keep heather and ssmantha. . bring in full time IT person. ASAP . your lighting contractor in your new townhouse has better IT than your multi billlion dollar antique opersation. data breaches are not your concern, precision is. . either re do the office layout. or get enterly new space. the proposals to focus on following on a monthly basis the values of all your current investments is an example of misplaced prioirties. . Your office is the heart of the familys financial life and temp future, it needs a heart operation Date: Mon, Oct 19, 2015 at 5:10 PM Subject: To: Melanie Spinella Radical but my preferred idea. . START from total scratch. there is absolutely nothing worth keeping in your family office except for heather, nothing at all . I remember when i bought my first house in order to renovate and jack robertson said forget it. knock it down start again, I could n't believe it. but he was right. Like your tax returns that were done in triplicate. TOM RICH ALAN. . tom and rich were not really useful in the end. Alan was the only smart one. you should in my opinion Start a brand new office. hire cfo. bring joe over, heather and samantha, run parallel for 6 months and close down the mess of elysium forever, leave your kids a functioning operation professionally constructed and managed. NOT BY ME!!! LAst nov i laid out priorities IT , being the first nothing as of today. in July I said focus on airplane as a test . to examine procedure and proficiency, so far mostly a waste of resources time people etc. Only last week told debra owns 49 percent of plane. no IT to speak of. bens house unaccounted for. tax returns very very sloppy, . boat still argued as third home. . pilots bonuses? , structure unkown by all. cash sitlling at the same time loans outstanding. Phaidon, looks like close to breakeven in a few years. others totally unknown. Query, do you really want this ? : I m not sure how you both want to have an investment office and have cash flow being eaten by publishing and loans amounts outstanding increased by art. --interest rates will be going up.- . your plane will cost 10 million to refinance - so will boat if sold next year-. art space and regan , both needs more cash. with little return, taxes , art purchases . Part of radical solutition is to sell publishing.altogether. (are the children really interested.) . restrucuture plane from scratch. layers unncessary. simplify crazy structure s bank accounts trading accounts accounts payble. credit cards. etc. The best way to wean yourself away from me is to have someone else do the whole thing from scratch. . move brad to be the replacement for Richard. . he is nice but this is not what he does. Him saying it is s0000 fucked up to me , was only an echo of me sayint it to you. Subj ect: To: Melanie Spinella as brad can attest, I spent time today with joslin, joe. etc. no question at all, a failed experiment. In the words of a banker that made a call on your office. what happened? leon seems to have replaced Eillenn with a HOUSE OVERSIGHT 023358 team of Shleppers. ? I know you care little for what they may think , but the legacy you leave your kids is just that. you only have 60 days of planning left for this year. numbers are all over the place. I recieved a nice call from Karp today, . He touted me as a great friend to you. I am happy to be just that. . He said it was important for me to tell you what others won't. Keep heather, fire EVERYONE else. Date: Mon, Oct 26, 2015 at 1:10 PM Subject: CONSTRUCTIVE? To: Brad Wechsler Melanie Spinella 1 cash flow projections for 16. . draft ok. i will be easy. i need rought projection. out now with who signs in sale of shares vs enitities. ? ie managing memebrs. . 2 . o , dynasty, ( does leon want to put in new restrictions per child ). - publishing interests. . 3 11c, for investments 4 names insured? guarnatees? art loans. outstanding. sales or use tax owed? 4, comparison of execu jet vs jet aviation. . 5. the bank loan on the jet is going to come due. does leon prefer to extend f they would ( he is a guarantor. ? ) or will he need to pay 10 million cash to renew, that wiill determine new structure of plane. getting rid of rance, wells fargo, john hannon, lisa gratizaino etc. . 5. boat restructure . 6 grats - if leon decie to have another. 7 accountning for children, . 2. phaidon chart laid 3 new trusts. Apo- Date: Mon, Oct 26, 2015 at 7:08 PM Subject: draft To: Melanie Spinella Brad Wechsler phaidon and art space. combined basis 96 million, ( reviewed with brad and joe.) . add ten for restructuring . basis 106. mi. subtract total sale price, for both, lets say approx $8 - 15m . leaving loss of between 90 and 98 million long term loss. . AMT rate 28 % obama. tax 3.8%. city and state 12% total aprox 43 %. tax rate. savings 38.7 - 44 m 0:51 PM (15 hours ago) to me, Richard, Karen DAli[Good afternoon Removal of headers in Cabana's 1 and 2 started today Dock Shelters proposed start date 16 Apr LSJ staff cottage and Sams kitchen and bath cabinets are due in this week. Have yet to schedule install. Will have estimate for GSJ Staff Cottage from EB by the end of the week Unable to contact Jimmy again regarding thIs project, Reached our Monday to schedule site meeting, got a - No Can Do - reply !!! Regards Brice Date: Mon, Oct 26, 2015 at 8:37 PM Subject: To: Brad Wechsler , Melanie Spinella gain at 20 % not 28. . so total, 35.8%. tax rate. same for boat. and plane each around 10 m so total 7 m savings if both sold Date: Fri, Jun 3, 2016 at 5:56 PM Subject: To: Heather Gray _____________________ heather leon seems to not recall the issue of finding an alternative to the eschange agents resale cerificate. he didnt remeebr you suggesting a gallery instead, you mentioned that he did not want to get another gallery involved. ? has any of the transactions been audited using this method , which even i find agressive. Date: Fri, Jun 3, 2016 at 3:02 PM HOUSE OVERSIGHT 023359 Subject: RE: To: "jeffrey E." Hi Jeffrey, As you will recall, we used this same exchange agent last year on the Calder 1031. At the time, we discussed the merits of using a gallery versus a commercial exchange agent and my recommendation to Leon was to use a gallery. I felt that there were advantages to using a commercial exchange agent instead of a gallery on the 1031 side (e.g., less likelihood of a breach of confidentiality, IRS familiarity with CDEC in the event of an audit, security of funds), but that a commercial exchange agent gave us less comfort on the sales tax side. Leon did not want to use a gallery because he was concerned about confidentiality and he did not want to have to ask a gallery that he did not do much business with to act as exchange agent. When Leon first discussed the exchange for the Cezannes with me a few weeks ago, I asked him if he wanted to use the same exchange agent as last year, or if he wanted to use a gallery. I said that a gallery carried little to no risk on the sales tax side, but I reminded him that he had not wanted to use a gallery last year for the Calder because of confidentiality reasons. He said to use the same exchange agent as before, which made sense to me because he was extremely concerned about confidentiality with the purchase of the Cezannes. I will find out about sales tax audits and will let you know. The exchange agent has had a New York resale certificate since 2014 and has been engaged in art transactions like this since then, but I do not believe they have been audited. I will check, though, and I will also ask the Herrick lawyer if any of his clients who have done similar deals have been audited. Best, Heather please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved HOUSE OVERSIGHT 023360