From: "Grieve, Brian S" Date: Wed, 8 Feb 2017 15:22:10 +0000 To: Brad Wechsler ; Jeffrey Epstein<[email protected] <mailto:[email protected]» Cc: Okun, Brad R Subject: RE: Privileged and Confidential Of course, Brad. I can discuss today between 130-3 and then again at 5 or after. Let me know the best time. Thanks Brian S. Grieve I Associate Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York. NY 10019-6064 www.paulweiss.com <http://www.paulweiss.com> From: Brad Wechsler Sent: Wednesday, February 8, 2017 10:06:40 AM To: Jeffrey Epstein; Grieve, Brian S Cc: Okun, Brad R Subject: Re: Privileged and Confidential Brian/Jeffrey-it wld be great if you cld pick a mutually convenient time today to speak so we can wrap this up. I'm sure everyone agrees its time to shut down. Let me know and I'll try to join tho its really the two of you who are critical. Thx, b Sent from my Verizon Wireless BlackBerry From: "jeffrey E." <[email protected] <mailto:[email protected]» Date: Tue, 7 Feb 2017 20:35:15 -0400 To: Grieve, Brian S 6 EFTA_R1_01405922 EFTA02386235

Subject: Re: Privileged and Confidential the numbers included on the delinquent filings were directly derived using the previously filed apollo numbers and only modified for the change in ownership percentage. ( or something to that effect, ) On Tue, Feb 7, 2017 at 8:07 PM, Grieve, Brian S <[email protected] <mailto:[email protected]» wrote: Brad as previously mentioned, we don't feel that statement is technically accurate. The numbers on the forms filed by Apollo entities would be different than the numbers on the forms filed by Leon because they own different 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 best we can do on this particular point given the facts that exist. Or perhaps we can say "substantially similar to" rather than "essentially the same" if Apollo is comfortable with that statement. Brian S. Grieve I Associate Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York. NY 10019-6064 www.paulweiss.com <http://www.paulweiss.com> From: Brad Wechsler Sent: Tuesday, February 7, 2017 6:31:35 PM To: Grieve, Brian 5; Jeffrey Epstein Cc: Okun, Brad R Subject: Privileged and Confidential Brian/jeffrey-cld both of you live with the following language at the end of the second paragraph of the Background Section: "Finally, the information in the International Information Returns previously filed by the Apollo entities is essentially the same as the information included in the applicable International Information Returns being filed today by the Taxpayers." If the two of you sign-off I will run by Apollo legal and tax for final confirmation. Sent from my Verizon Wireless BlackBerry 7 EFTA_R1_01405923 EFTA02386236

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