From: Brian Gartner •,a Date: Thu, 5 Jun 2014 22:43:14 +0000 To: Richard Kahn Cc: " , Michael Liebeskind Subject: Private Placement Variable Annuity (PPVA) Investment Account Rich, It was nice speaking with you today. As promised, directly below is Michael's contact information. I have also attached his v-card for your convenience. Michael B. Liebeskind Winged Keel Group 1700 Broadway, 34th Floor New York, NY 10019 Email: Phone: 212-527-8020 Fax: 212-527-8098 Also, when we got off the call, Michael and I thought it may be helpful for you to have the Willkie Farr & Gallagher Tax Memorandum at your fingertips for when you meet with the Principal tomorrow (see "Willkie Farr & Gallagher LLP Memorandum," attached). We asked Willkie Farr & Gallagher to research EFTA01470866

the tax treatment of the charitable legacy application of a Private Placement Variable Annuity (PPVA) Investment Account. They were able to confirm the tax results we had anticipated, namely that all taxes on investment gains are eliminated to the extent that the PPVA Investment Account is bequeathed to a tax-exempt charity or private foundation. We hope you find this helpful for your conversation tomorrow. Please let us know if you have any questions prior to your discussion with the Principal or if any arise as a result of tomorrow's conversation. Brian From: Brian Gartner Sent: Thursday, June 05, 2014 4:47 PM To: Cc: Michael Liebeskind Subject: FW: Private Placement Variable Annuity (PPVA) Investment Account Paul and Rich, The third attachment to this email is the reporting example Michael was referring to. Here is a brief description of the document: PPVA Sample Statement: This is a redacted version of an actual client statement for the month ending December 31, 2013. The PPVA Investment Account has now shielded $6,537,565 of investment gains from current period taxation for an incremental fee of $407,101. This particular client had earmarked $20 million to bequeath to her private foundation, but she did not want to give up ownership and control of the assets during her lifetime. Needless to say, she is delighted with the results that have been achieved. EFTA01470867