From: Richard Kahn Sent: Tuesday, September 9, 2014 2:28 PM To: jeffrey E. Subject: Fwd: First draft Attachments: MEMO JEE 1294.docx; Untitled attachment 00104.htm fyi Richard Kahn HBRK Associates =nc. Begin forwarded message: From: Erika Kellerhals Subject: =/b>FW: First draft =/b> Date: =/b>September 8, 2014 at =2:41:30 PM EDT To: = b>leanne Brennan =ichard Kahn I haven't =eard back from Alan yet but will finalize =his. Erika A. Kellerhals SIM EFTA_R1_02113763 EFTA02709030

Notice: This communication may contain =rivileged or other confidential information. If you are not the =ntended recipient, or believe that you have received this communication =n error, please do not print, copy, re- transmit, disseminate, or =therwise use this information. Also, please indicate to the =ender that you have received this e-mail in error, and delete the copy =ou received. Thank you. Circular 230: To ensure compliance with the =equirements imposed by the IRS, we inform you that any tax advice =ontained in our communication (including any attachments) was not =ntended or written to be used, and cannot be used, for the purpose of =i) avoiding any tax penalty or (ii) promoting, marketing or =ecommending to another party any transaction or matter addressed =erein. From: =rika Kellerhals Date: Friday, August 29, 2014 =0:47 AM To: "Dlugash, Alan" =It; =r>Subject: First draft =br> I have not =irculated this first draft to the entire group as I wanted to make sure =t covered what you needed. I will continue to refine while I wait for =our substantive =omments. 2 EFTA_R1_02113764 EFTA02709031