and jeffrey to have a higher level conversation some time next week; either way you'll have access to everything, obviously. From: Barry J. Cohen [mal @iiiiTTT i’ Sent: Thursday, December 10, 2015 05:55 PM To: Brad Wechsler Subject: RE: Fw: sched I wouldn’t mind attending a meeting or portion of a meeting with JE. If he is the mastermind, and you want to move quickly, it might get a lot of questions resolved quickly. From: Brad Wechsler [mailto: Sent: Thursday, December 10, 2015 5:37 PM To: [email protected]' Ce: I io Spinella; Barry J. Cohen Subject: Fw: Fw: sched On different subject: general time frame is: docs (notes and purchase and sale agreement to you tomorrow end of biz); incorporate your comments monday and get docs to trust attorney tuesday; contemporaneously meet in person with you tuesday or wednesday and do a dry run. On these days ada will also take the trustees through outline of docs they will receive thursday. Docs to trustees, leon et al on thursday and signatures gathered by friday for first close 12/22. Tight but doable. Ada, alan agree? PS: ada, you shld begin to think abt where people are (jh, rr, bc, Idb) next week. From: Heather Gray [mailto Sent: Thursday, December 10, 2015 05:24 PM To: Brad Wechsler Cc: Jeffrey Epstein ([email protected]<mailto:[email protected]>) <[email protected]<mailto:[email protected]>> Subject: RE: Fw: No, I’m meeting with him at 9:30 am tomorrow. Date: Fri, Dec 11, 2015 at 9:49 AM Subject: fee To: Melanie Spinella elegant solution ;re fee. , 30 million paid now. with purchase of noel kalb, paid with funds from the drawdown. you should use and keep open the line for the full 30m and leave it outstanding until its expiration. in four months. legit biz reason, very nice , - the balance of the fee - paid in kind either low basis art . or interest in either milenium ,lone cascade ,or king street. Date: Tue, Apr 14, 2015 at 5:53 PM Subject: To: Melanie Spinella SY saved you 500k at the last minute, . brad has had the same chart since march 16th, its his job to review NOT MINE .appears he is one of those living in the dark leiwe. I found 8 million dollars today, missed deductions. . not yet in the numbers, .? Date: Wed, Apr 15, 2015 at 8:59 AM Subject: To: Melanie Spinella - HOUSE_OVERSIGHT_023220
1 did the paul weiss bill get paid ??? 2. Talk to me before signing anything today important 10m paid today to gratitude america, a 501 c 3, willl make last year complete. 20 million paid today ftc . 10 million july 15 5 million sept 30. , 5 million jan 1 for all of 16. tax savings paid at 37 percent . of net. savings. 50 million credit. net. so 150 million free. 600 savings 225 million owed. - 50 credit, 175 owed. Date: Mon, May 18, 2015 at 8:17 AM Subject: agenda for tomorrrow To: Jeffrey Epstein <[email protected]>, Melanie Spinella as areflection on your voiced spirited concerns in the what have you done for me lately category ? )):: in the beginning . there was eileen and tom. ( eve and adam,-- however it appears, she declined to eat the apple from the knowledge tree) that was it. ada was at the bank but reviewing docs. carlyn was in the kitchen making mush ( abel and cain) books as they were mystersiously called was being kept soley by eileen, with little or no input ,correction or advice from tom. herarely if ever asked questions. expenses ie airplane was done in house apollo. (1031 exchange blown etc) at this time as I recall you got quite annoyed, and agressive and initiated the" talking out of the both sides of your mouth " tiddy, when i suggested that the level of their competence left much to be desired. ( ralph lerner's came later ) .response - eileen ran the desk, tom is a partner, ralph wrote the book etc re tax there was almost no oversight of income, estate, gift ,sales and use, transfer excise etc . IRS SEC GAMING NYS. real estate, valuations ( many )tax filings- disclosures, etc. re grats trusts defect trusts, llcs corps , trustees , partnerships. foreign corps. 100 bank accounts. gift taxes, , loans, notes. payables. expenses. . , insurance.( life , art, split dollar), cashflows, operating biz, , investments, contingent liabilitiites.( funds , miami ) , commitments dividends, BRH TRA, shareholder agreements, bank loan agreements. wills, construction, , contracts planning permits etc..employ rules. checking account reconciliations, crediti cards. jewelry , cost basis ,( art stock etc.) foundations regs , brokerage accts, old stock certificates. stock options,( environmental solutions still not done !). estate tax calcualtion firedrill, ( note ,basis etc ) low basis , step ups , however withno accounting system, no reveiw of boat expenses plane expenses etc. . many outside counsel with litle or no coordination. Paul Weisss , Mcdermit Will, Macfarlanes. Price Waterhouse , Reich, withers bergman, Empire, , akin gump, bbd seidman, Wendy , Apollo in house . lumber, knowledge universe, ennvironmental, solutions 12 mii in stock, . on and on the priority list that you asked me to prepare for brad and you in dec , unfortunatlleyso far , little change ie no accounting system that ties, no, brokerage accounts though strongly suggested , jpm db, gs, april of 2014 . IT antiquated dagastino hired , no inut from me, julie, temps, paralegals miriam . etc. still need new accounting system - on line banking . staff hires. ( seprate from samantha two years out of school ). audit system, . ?? john murphy? joslin? dag? eva? . i strongly suggest workers at the highest level of competence. two senior accountants. not managers workers who will get into the weeds. partn expertise, , replace ava, get heather help. a new person legal , new IT,system and person, way way overdue, new receptionist, bill opener, ability to oeversee in house, boat plane review household ( 12million ) review, filings- partnerhip accounting,- familitarity with grats, trusts etc . audit system put in place. that should be the easy part. then strategy to deal with : As new facts on the ground develop , phaidon debra, children meeetings, ? stock sale sale of art, , apt( large gain ), 1031 trade in , plane depreciation, boat sale. construction , brad will oversee brokerage and HOUSE_OVERSIGHT_023221
investment, ?? pe. real es, . publishing, grats, tra, brh ( death). foundation , museum, tax proejctions cash flow projections, cooridnation with tax from apollo. etc Date: Thu, May 28, 2015 at 8:53 PM Subject: ulysses 2.0 To: Melanie Spinella Bea reenarmememt I realize it is only due to a lack of understanind of the job ahead. and not out of any sense of unwillingess to pay - as opposed to merely hiring people to set up a family office, someone will have to do _ the following- separate from the art partnership which is my responsiblity . there still needs to be a huge amount of work done for 2015,16. not to mention that brad at the moment is going to have train the incoming team?? your call strategic decisions re estate and other planning , sale of phaidon etc. . in addition setting up for the accounting for each strategy te.: income, estate, gift ,sales and use, transfer excise picasso, 1031 calder.. review and detailed oversite of IRS SEC GAMING NYS. real estate, entity valuations (many ) tax filings- disclosures, follow up of grats, trusts ,defective trusts, Ilcs corps , trustees , partnerships. foreign corps. 100 bank account need to be rationalized, not only having brad step in to children investments . gift taxes, trust , loans, notes. payables. expenses allocations . . , insurance.( life , art, split dollar), cashflows, operating biz, , investments, contingent liabilitiites.( funds , miami ) , commitments funds and charities , dividend treatment -important review of transcations relating to BRH ( amendments) TRA sale ( nuanced ) , shareholder agreements, bank loan agreements new bank relationships. ._ wills, construction accounting and oversite , contracts planning permits etc..employee rules, regs, . checking account reconciliations, crediti cards. jewelry , cost basis ,( art stock etc.) foundations regs , brokerage accts,. stock options,( ie environmental solutions still not done !). estate tax calcualtion firedrill, ( note ,basis etc ) review of boat expenses plane expenses, depreciation issues refunds etc. . rationalize all outside counsels and accounting firms Paul Weisss , Mcdermit Will, Macfarlanes. Price Waterhouse , Reich, withers bergman, Empire, , akin gump, bbd seidman, , Apollo in house counsel. set up and oversee brokerage accounts at JPM DB GS and thoughfullly trade .new IT system from top to bottom full time IT person new accounting system - on- line banking cooridnated with reports . fire drills as per caruci (he sounds good ) and. audit system,s . review of john murphy? joslin? dag? eva? . in house, review household ( 12million ) review, filings- partnerhip accounting,- familitarity with grats, trusts etc . audit system put in place. that should be the easy part. then strategy re: As new facts on the ground develop, phaidon debra, children meeetings, involvment , trustees adjusted, stock sale sale of art, , apt( large gain ), 1031 trade in , plane depreciation, boat sale. construction , brad will oversee brokerage and investment, ?? pe?. real estate?, . publishing, grats, tra, brh ( death). foundation , museum, tax proejctions cash flow projections, cooridnation with tax from apollo. etc you are sitting on over 100 m of cash???!! Date: Fri, Jan 2, 2015 at 2:55 PM Subject: To: Melanie Spinella - t—<‘i—isSOSOSCS Leon, I decided last week that there was little or no upside in disturbing your well earned holiday HOUSE_OVERSIGHT_023222
especiaily as you seemed so peaceful happy and smiley ,getting yourself in shape and truly enjoying your family time. etc. however the situation in your family office is unresolved. I am aware that brad starts monday howver, two last days of the year madness. timber.deal not complete no jpm,acct activity no partnership docs , old stock sales not complete , no bank doc redo. no phaidon note restructure, ., no boat expense review. airplane same ,topco midco.etc still not finished ( trustee ), projections mixed with fiction. , legal exp out of control. no care for admin, silly ( audit). tom conversation with joslin. notes. debra, trustee notes. trustees hiring . bens audit. interest payable made hoopjumping last day of year. after weeks and months. of lectures , gifts to discuss- staff. -houseproject mgmt. . I will continue to try , I had offered ajoint call with eileen before you left. asi said before , joslin takes instructions from eileen. he said it was made clear to him that he doesn't work for me but works for you. . I tried. Date: Tue, Dec 29, 2015 at 7:26 AM Subject: Fwd: leon DO NOT SEND, hand deliver. To: Jeffrey Epstein <[email protected]> Transaction complete ! . this - in spite of your collection of Elysium misfits. !!! With Brad out of the office and unable to run his usual interference , the level of his utter incompetence was brought front and center, he may be a step up from Eileen, but if he is , then it is not certainly not by much, . Though you and I have spent many many hours discussing the importance of details and mechanics. I was not shown one document re phaidon,- not one.. Brad wanted to keep it private between he and his so called" advisors" however as he was out of the office during the most important transaction of the year, I did get to spend time with joslin Joe and john, - the situation in your office is wholly ludicrous - to summarize - the list I provided to Brad last December - things I thought were a priority to get done after consulting with your office _ still remains virtually undone. IT, still desperately needed- reporting flawed cumbersome and inaccurate . all done by hand as one -off exercises , - airplane: re structure, (my only suggested priority in june ) is really ,no further ahead, consultants up the kazoo but nothing at all done.( the office was told that i cannot even see the proposals received without brads specific authorization ) - brad has no idea even as to what questions to ask. he knows little of finance, is run roughshod over by almost everyone in the office. he is a little man , using your power, to appear larger . Eileen was self aware enough to know she was over her head , that is a huge difference. bad info is rampant ie 3 million in deductions Im told are taken for art space but on closer examination it turns out they cannot be used at all. (ZERO benefit ) though you will be told yes they were deducted on the return they said that is the question they get asked ! " were they deducted "not -" is there a benefit" !!| I asked for the balance sheet and P and L for Regan arts , a basic first step in order to check your financials. "sorry we never got one?" though 9.8 million invested, no p&l, nothing , a construction project run amok , no budget, the coo fired after only 3 months. , no clue. I can add that artspace financials are also a total mess. As your friend and in order toturn the page. I will try to be constructive The following is a list of things I think would be in your interest to get done asap .but definitely not by me. isuggest you form new grats. , hire a high level tax partner. use your trading accounts as they remain the paramount requirement 16 months after i emailed to you their importance. , I suggest you consider having the 49percent of phaidon merged into artspance and have Richard buy artspace. re-do bank loans. no need to pay interest at higher rates on boat or plane. . as Richard is now no longer trustee. re- do will, make suydam executor , with Barry, and john as back up. pay | million a year for executor role. get rid of Judy Black trust, deal with gifts and their tax returns, . review amounts to kids at fixed ages. put more protections in for Alex and Victoria. , distribute some money to kids let them make decisions. , HOUSE_OVERSIGHT_023223
decide art division with children in attendance . have fire drill done on estate. fill out estate returns as if you and Debra died today, choose advisers - rick bronstein said the only 1040 he ever filled out was his own. ( this is brads chosen advisor??!) Halperin has a conflict that should be addressed., Debra should enter a tenants in common agreement with kids. you have airplane consultants tax consultants it consultants. plane operation consultant. . boat consultants. architects, lighting , art, legal, . foundation , deal with TRA , BRH, rationalize investments. cash flow. reporting, gaming disclosures. foreign, gift. . prepare tax projections for 15 and 16, . deal with neg basis ( tufts gain, debt financed. art partnership, pledges. sell stock , art, deal with phaidon debt. athene,? income , capital , foreign , exit, corporate, insurance regs, out and inbound issues, basis, appropriate discount rates. ? terminations. control. , qualified dividends. corporate tolls, inversion rules. , grat issues, short swing and other sec disclosures, Rothshcild bank, 150 b they have a distribution network with no products , private bank Rockefeller Rothschild. financial service. deal with UK visa issue sooner rather than later. we can talk about Rowen request re Athene , 2 billion in taxes on transaction. ?! the facts as i see them in June and then again Sept, we both agreed to a 50% of phaidon payout., then after weeks of thinking about the issue ( which I fully understand ) . the payout was unilaterally changed . 5m woudl be reserved for the future ? . and out of the remaining 15m ,? 1 would receive only 5. ( note : I'm confident that both the debt , and the artspace investment will also lead to a write off of another 30 m. plus ) In my dining room ,you were surprised when I said that i require most people to pay their advisory fee up front so that I am assured that I will be properly compensated for my work when strategies that I devise are implemented . you may recall that you appeared offended and said " are you suggesting that 1 would go back on my word" I said no , of course not ! you are my closest of friends ,but my experience is that when amounts get large, people tend to get unhappy when it actually comes time for them to pay ,. From day zero a 50 - 60 million price was attached as the fair price of the transaction just completed . though this amount was already substantially less thanour agreed and negotiated formula. - I was never told that this was out of range. in fact, alternative methods of payment. plane -in-kind etc, were discussed (ie keeping the 30m portion of fee outstanding till March ) ,I provided as requested a detailed step by step execution plan and reviewed all documents that i was given access to. ( Phaidon was not forthcoming ) in order to make my many corrections. I was then told that Alans involvement warranted a discount. Even in the best of light , though it is beyond question that not one-,not -one time in three years has he ever proposed a unique idea. (including the new tenant in common idea,) and lets say he made a contribution to the plan andeven that it was 50 %. though no one could posit such a large amount unless they were wearing a brightly colored clown suit. , the price of doing the deal was known . It had both sent in writing and spoken about on the phone numerous times ,_a detailed execution plan was provided . then and only then after all was laid out for the group I was told that after a number of conversations with brad karp that only 20m would be paid , (and even that was more than originally contemplated ) for both transactions . I feel It was remarkably unfair. Did brad even know of our prior agreement.? I called him and he said he was never told.?, I would ask that you I and Brad karp sit together if you think it would be helpful. . I would like to send him this email, with your consent of course. Ifthe transactions were never consummated , 1 would not be owed a dime, however , the price was known up front. , the detailed step by step plan was followed and overseen by me, the price that had been requested before the transaction was begun, and had Iready heavily discounted, out of friendship, from our agreement . I believe the decision re paying only 20 m has frankly left me felling quite uneasy. since you asked since last nov. ifound 11 million dollars in dormant accounts. 4 million dollars in eileens drawer. . went through cash flows for phaidon shwoing that john murphy is not an accountant. HOUSE_OVERSIGHT_023224
redid your gagosian contract ,. organized structure in case of divorce. set up gift trust. stopped ada from including multiple times things not in your interest. dealt with bad sales tax use tax income tax . created 8 millino in deductions ,500k in mistakes , found bank of scotland fbar problems, . . reorg bad art purchases , funds taken, , charibale decustions , helped with fincnacil sttment gamoing commions fling. . boat deductions, rescued stock from grats.. may 1 after months of brad not finding anyone i sent an email saying you would have to pay more. . on april 15. I sent an email detailing payments owed if i could figure out the basis issue, please see attached, . questions you might ask your team ask them to provide a balance sheet or p&1 for REgan arts. doesnt exist ask . either wechsler or haperin to tell you what brh is, or how the tra works. .. ? as bronstein to tell you why the proposed phaidon transaction DOES not work. . as them to give you a plan for the plane. ? ask them to show you the cash mgmt for over 100 million dollars. . ask them to show you the IT system progress after one year. . the approval process for payables. . the cash flow projections? assumptions? ask for a comparative review of investments. ask haperin to describle to you in any detail BRH , the major asset of his two biggest clients. tax basis, disposiotion in the estate. . etc. ask brad to show you the liquidation of the inteveing art space cos? . Last year you asked , for my help I told you I preferred not as we would be better off having no financial intereactions. the risk was not worth it. You told me that as my friend i had to do it Iagreed., here we are in what I find to be an awkward situation. the transactions that i decvised were used _, our agreement was ignored. and im not sure how to respond. since you asked since last nov. ifound 11 million dollars in dormant accounts. 4 million dollars in eileens drawer. . went through cash flows for phaidon shwoing that john murphy is not an accountant. redid your gagosian contract ,. organized structure in case of divorce. set up gift trust. stopped ada from including multiple times things not in your interest. dealt with bad sales tax use tax income tax . created 8 millino in deductions ,500k in mistakes , found bank of scotland fbar problems, . . reorg bad art purchases , funds taken, , charibale decustions , helped with fincnacil sttment gamoing commions fling. . boat deductions, rescued stock from grats.. may 1 after months of brad not finding anyone i sent an email saying you would have to pay more. . on april 15. I sent an email detailing payments owed if i could figure out the basis issue, please see attached, . questions you might ask your team ask them to provide a balance sheet or p&1 for REgan arts. doesnt exist ask . either wechsler or haperin to tell you what brh is, or how the tra works. .. ? as bronstein to tell you why the proposed phaidon transaction DOES not work. . as them to give you a plan for the plane. ? ask them to show you the cash mgmt for over 100 million dollars. . ask them to show you the IT system progress after one year. . the approval process for payables. . the cash flow projections? assumptions? ask for a comparative review of investments. ask haperin to describle to you in any detail BRH , the major asset of his two biggest clients. tax basis, disposiotion in the estate. . etc. ask brad to show you the liquidation of the inteveing art space cos? . n--------- Forwarded message ---------- From: jeffrey E. <[email protected]> Date: Tue, Apr 14, 2015 at 5:53 PM Subject: To: Melanie Spinella saved you 500k at the last minute, . brad has had the same chart since march 16th, its his job to review HOUSE_OVERSIGHT_023225














