From: "Barry J. Cohen" To: jeffrey E. <[email protected]>, Leon Black Subject: RE: Plane Straw Man PRIVILEGED AND CONFIDENTIAL Date: Mon, 21 Aug 2017 19:10:56 +0000 We value your opinion, so we prefer to send you everything. From: jeffrey E. [[email protected]] Sent: Monday, August 21, 2017 2:51 PM To: Barry J. Cohen <1 .>; Leon Black Subject: Re: Plane Straw Man PRIVILEGED AND CONFIDENTIAL Feel free to leave me out of this On Mon, Aug 21, 2017 at 2:28 PM Barry J. Cohen > wrote: Big picture: FET is peanuts. He flies 300 hours a year. At $17,500/hr, that's $400K per year of FET. Avoiding FET on half the flights would be $200K per year. Flying under Part 135 (and therefore incurring FET) better ensures full deductibility of the depreciation, which is big $. So for a small amount of FET, we solidify our position. But we will show example transactions with numbers as you suggest. From: jeffrey E. [mailto:[email protected]] Sent: Monday, August 21, 2017 2:23 PM To: Barry J. Cohen < > Subject: Re: Plane Straw Man PRIVILEGED AND CONFIDENTIAL Barry why don't you put dollars in your chart . Suggesting FETCeith no numbers is On Mon, Aug 21, 2017 at 2:03 PM Barry J. Cohen < wrote: We just had a call with EY, where they suggested improvements. New draft out shortly. From: Barry J. Cohen Sent: Monday, August 21, 2017 12:13 PM To: Jeffrey E. <[email protected]> Subject: FW: Plane Straw Man PRIVILEGED AND CONFIDENTIAL From: Barry J. Cohen Sent: Monda August 21, 2017 12:12 PM To: ; John Cook < Wimer, Ruth Cc: Joe Avantario , Bradle J. Wechsler Joseph Vinciguerra ; Richard Joslin Subject: FW: Plane Straw Man PRIVILEGED AND CONFIDENTIAL • John Castrucci EFTA00680654

Attached is a proposed straw man structure for owning and operating the plane. Slightly amended from what we sent out on Friday. There are still a couple of open questions on whether we can fully deduct depreciation and exactly who has want contractual relationship with Jet Aviation. Please let us know your comments. Barry J. Cohen I President and Special Counsel Elysium Management, LLC 445 Park Avenue Suite 1401 New York, NY 10022 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 [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 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 [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00680655