Epstein Secrets

be adjusted pursuant to Section 2.3. "Equivalent Heritage Points Deficit" means, with respect to a Principal Group, as of immediately prior to any Exchange, the excess (if any) of the number of 4 I ." CSI. 144-7-7441'9 1/octi: US1:107703119t 15 EFTA00808228 Equivalent Heritage Points of such Princ

Leon Black 760 Park Avenue New_York, NY 10021 with a copy to: Elysium Management LLC 445 Park Avenue Suite 1401 New York, NY 10022 Attention: Ada Clapp, Esq. Brad Wechsler, Esq. lf,_to_MR or any member of his Group: Marc Rowan 927 Fifth Avenue Apartment #6 New York, NY 10021 with a copy to: [

e taxable exchanges that trigger TRA payments. The transfer of BFP interests from Leon's estate to the CLATs would not be considered a nontaxable A Exchange because the CLATs themselves are not charities and no AOG units would be exchanged for public stock as part of the transfer. As exchanges are made

PRIVILEGED AND CONFIDENTIAL SULLIVAN & CROMWELL LLP July 12, 2017 Via E-mail MEMORANDUM TO: Ada Clapp Barry J. Cohen Bradley J. Wechsler (Elysium Management LLC) FROM: Charles T. Dowling Elizabeth A. Kubanik RE: Leon Black Estate Planning This

be adjusted pursuant to Section 2.3. "Equivalent Heritage Points Deficit" means, with respect to a Principal Group, as of immediately prior to any Exchange, the excess (if any) of the number of Equivalent Heritage Points of such Principal Group over the Pecuniary Interest in the Heritage Points of such

Leon Black 760 Park Avenue New York, NY 10021 with a copy to: Elysium Management LLC 445 Park Avenue Suite 1401 New York, NY 10022 Attention: Ada Clapp, Esq. Brad Wechsler, Esq. If, to MR or any member of his Group: Marc Rowan 927 Fifth Avenue Apartment #6 New York, NY 10021 with a copy to: [