Epstein Secrets

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 memorandum summa

rustees. The trusts also would owe New York income tax on all of their income as long as any of the Trustees is a New York resident, the trusts hold New York situs property or have New York source income. It is likely the trusts will have New York source income as long as they hold interests in AOG. 10

or and the Noteholder have executed and delivered this Note as of the date hereof. LEON D. BLACK as Payor LDB 2011 LLC, as Noteholder By: Name: Barry J. Cohen Title: Manager 8 EFTA00585322

ns any day other than a Saturday, Sunday or other day on which commercial banks are authorized to close under the laws of, or are in fact closed in, New York (New York). "Event of Default" shall mean the occurrence of any of the following: (a) The Payor shall fail to perform or observe any covenant or

or and the Noteholder have executed and delivered this Note as of the date hereof. LEON D. BLACK as Payor LDB 2011 LLC, as Noteholder By: Name: Barry J. Cohen Title: Manager 8 EFTA00585769

ns any day other than a Saturday, Sunday or other day on which commercial banks are authorized to close under the laws of, or are in fact closed in, New York (New York). "Event of Default" shall mean the occurrence of any of the following: (a) The Payor shall fail to perform or observe any covenant or