From: jeffrey E. <[email protected]> Sent: Wednesday, February 8, 2017 12:35 AM To: Grieve, Brian S Cc: Brad Wechsler; Okun, Brad R Subject: Re: Privileged and Confidential the numbers included on the delinquent filings were =irectly derived using the previously filed apollo numbers and =nly modified for the change in ownership percentage. ( o= something to that effect, ) On Tue, Feb 7, 2017 at 8:07 PM, Grieve, Brian = wrote: Brad as previously mentioned, we don't feel that statement is tech=ically accurate. The numbers on the forms filed by Apollo entities would b= different than the numbers on the forms filed by Leon because they own di=ferent percentages of the various underlying foreign entities. Also we know Apollo did not themselves file all required=forms, e.g. 5471s, for certain years so there would need to be a carveback=for that. I think the sentence I proposed earlier today is probably the be=t we can do on this particular point given the facts that exist. Or perhaps we can say "substantiall= similar to" rather than "essentially the same" if Apollo i= comfortable with that statement. Brian S. Grieve I Associate Paul, Weiss, Rifkind, Wharton & Garrison LLP From:=Brad Wechsle Sent: Tuesday, February 7, 2017 6:31:35 PM To: Grieve, Brian S; Jeffrey Epstein Cc: Okun, Brad R Subject: Privileged and Confidential Brian/jeffrey-cld both of you =ive with the following language at the end of the second paragraph of the =ackground Section: "Finally, the information in the International Information Returns pre=iously filed by the Apollo entities is essentially the same as the informa=ion included in the applicable International Information Returns being fil=d today by the Taxpayers." If the two of you sign-off I will run by Apollo legal and tax for final con=irmation. Sent from my Verizon Wireless BlackBerry EFTA_R1_01909744 EFTA02661461

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