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uld take advantage of the family office exception is for Leon to open the trading accounts and then enter into an investment advisory agreement with Elysium. Brad as CEO of Elysium could handle investments. Do you agree with this approach? Ada Clapp Chief Legal Officer Elysium Management LLC 445 Par
ad would no longer be a Managing Director of Elysium but would become an officer (CEO): Approach 1: Elysium's CEO would be given authority to invest Elysium's assets. Elysium's LLC agreement would be amended to provide that LDB can't remove the CEO without 65 days-notice. LDB (sole member/managing direc
59:59 +0000 To: Brad Wechsle Cc: Richard Joslin Subject: AP Investco Brad, I spoke this morning with Alan and Marco Masotti Head of Paul Weiss's Private Investment Funds group and Philip Heimowitz, counsel who specializes in 34 Act and 40 Act issues, including the family office exception. They propose the following
r that we fall outside the Apollo trading policy. The solution I outlined earlier today—using a relatively simple investment advisory agreement with Elysium — is designed to deal with both concerns. Please let me know how you wish to proceed. -Ada From: Jeffrey E. [mailto:[email protected] Sent: W
family office exception is for Leon to open the trading accounts and then enter into an investment advisory agreement with Elysium. Brad as CEO of Elysium could handle investments. Do you agree with this approach? Ada Clapp Chief Legal Officer Elysium Management LLC 445 Park Avenue Suite 1401 New
59 +0000 To: Brad Wechsler< Cc: Richard Joslin< Subject: AP Investco Brad, I spoke this morning with Alan and Marco Masotti Head of Paul Weiss's Private Investment Funds group and Philip Heimowitz, counsel who specializes in 34 Act and 40 Act issues, including the family office exception. They propose the following
uld take advantage of the family office exception is for Leon to open the trading accounts and then enter into an investment advisory agreement with Elysium. Brad as CEO of Elysium could handle investments. Do you agree with this approach? Ada Clapp Chief Legal Officer Elysium Management LLC 445 Par
ad would no longer be a Managing Director of Elysium but would become an officer (CEO): Approach 1: Elysium's CEO would be given authority to invest Elysium's assets. Elysium's LLC agreement would be amended to provide that LDB can't remove the CEO without 65 days-notice. LDB (sole member/managing direc
:59 +0000 To: Brad Wechsler Cc: Richard Joslin< Subject: AP Investco Brad, I spoke this morning with Alan and Marco Masotti Head of Paul Weiss's Private Investment Funds group and Philip Heimowitz, counsel who specializes in 34 Act and 40 Act issues, including the family office exception. They propose the following
uld take advantage of the family office exception is for Leon to open the trading accounts and then enter into an investment advisory agreement with Elysium. Brad as CEO of Elysium could handle investments. Do you agree with this approach? Ada Clapp Chief Legal Officer Elysium Management LLC 445 Par
ad would no longer be a Managing Director of Elysium but would become an officer (CEO): Approach 1: Elysium's CEO would be given authority to invest Elysium's assets. Elysium's LLC agreement would be amended to provide that LDB can't remove the CEO without 65 days-notice. LDB (sole member/managing direc
:59 +0000 To: Brad Wechsler Cc: Richard Joslin< Subject: AP Investco Brad, I spoke this morning with Alan and Marco Masotti Head of Paul Weiss's Private Investment Funds group and Philip Heimowitz, counsel who specializes in 34 Act and 40 Act issues, including the family office exception. They propose the following
ensure that Leon is not viewed as the beneficial owner of the securities being traded by Investco. They are concerned that this will be the case if Elysium could immediately remove a manager and in that way, control trading. The 65 days comes from practice in this area. Please let me know if you are co
ad would no longer be a Managing Director of Elysium but would become an officer (CEO): Approach 1: Elysium's CEO would be given authority to invest Elysium's assets. Elysium's LLC agreement would be amended to provide that LDB can't remove the CEO without 65 days-notice. LDB (sole member/managing direc
:59 +0000 To: Brad Wechsler Cc: Richard Joslin< Subject: AP Investco Brad, I spoke this morning with Alan and Marco Masotti Head of Paul Weiss's Private Investment Funds group and Philip Heimowitz, counsel who specializes in 34 Act and 40 Act issues, including the family office exception. They propose the following
00 I am not sure I understand your question. Let me confirm with PW but my understanding is that if you are doing the trading as a paid employee of Elysium (whether you are doing it under a POA or an investment agreement) —you may be viewed as being compensated for providing investment advice. In that c
59:59 +0000 To: Brad Wechsle Cc: Richard Joslin Subject: AP Investco Brad, I spoke this morning with Alan and Marco Masotti Head of Paul Weiss's Private Investment Funds group and Philip Heimowitz, counsel who specializes in 34 Act and 40 Act issues, including the family office exception. They propose the following
om> I am not sure I understand your question. Let me confirm with PW but my understanding is that if you are doing the trading as a paid employee of Elysium (whether you are doing it under a POA or an investment agreement) —you may be viewed as being compensated for providing investment advice. In that c
9 +0000 To: Brad Wechsler< Cc: Richard Joslitr< Subject: AP Investco Brad, I spoke this morning with Alan and Marco Masotti Head of Paul Weiss's Private Investment Funds group and Philip Heimowitz, counsel who specializes in 34 Act and 40 Act issues, including the family office exception. They propose the following
ensure that Leon is not viewed as the beneficial owner of the securities being traded by Investco. They are concerned that this will be the case if Elysium could immediately remove a manager and in that way, control trading. The 65 days comes from practice in this area. Please let me know if you are co
9 +0000 To: Brad Wechsler< Cc: Richard Joslin<1 Subject: AP Investco Brad, I spoke this morning with Alan and Marco Masotti Head of Paul Weiss's Private Investment Funds group and Philip Heimowitz, counsel who specializes in 34 Act and 40 Act issues, including the family office exception. They propose the following
ensure that Leon is not viewed as the beneficial owner of the securities being traded by Investco. They are concerned that this will be the case if Elysium could immediately remove a manager and in that way, control trading. The 65 days comes from practice in this area. Please let me know if you are co
59:59 +0000 To: Brad Wechsle Cc: Richard Joslin Subject: AP Investco Brad, I spoke this morning with Alan and Marco Masotti Head of Paul Weiss's Private Investment Funds group and Philip Heimowitz, counsel who specializes in 34 Act and 40 Act issues, including the family office exception. They propose the following
Entities connected to both Elysium and Private Investment Funds

Jeffrey Epstein
PERSON
Brad Wechsler
PERSON
Alan Dershowitz
PERSONVerizon Wireless
ORGANIZATIONAlan S. Halperin
PERSONAda Clapp
PERSONElysium Management LLC
ORGANIZATION
Melanie Spinella
PERSONMarco Masotti
PERSON
Paul, Weiss
ORGANIZATION
Richard Joslin
PERSONPhilip Heimowitz
PERSONEileen Alexanderson
PERSONIMAX Corporation
ORGANIZATIONI. Elysium Management LLC
ORGANIZATIONCindy Michel
PERSON