From: Ada Clapp Cc: Eileen Alexanderson; Rich Joslin Date: January 9, 2014 Re: Art Held in Narrows. I. Organizational Structure/Purpose of Narrows. Narrows Holdings LLC ("Narrows") was formed November 22, 1996 as a New York Limited Liability Company by Rubin Baum Levin Constant & Friedman. Its

orma balance sheet appeared to be based on then appraised values, not cost basis. III. July 2012 Addition of Art to Narrows I do not know whether Narrows was originally intended to be an investment entity but in July of 2012, Ralph Lerner advised Leon to assign all of his art, other than the Edvard Mu

MEMORANDUM To: Jeffrey Epstein From: Ada Clapp Cc: Eileen Alexanderson; Rich Joslin Date: January 9, 2014 Re: Art Held in Narrows. I. Organizational Structure/Purpose of Narrows. Narrows Holdings LLC ("Narrows") was formed November 22, 1996 as a New York Limited Liability Co

, or family trusts including APO1 and APO2. Gagosian wants us to agree that, if Narrows/AP Narrows assigns the agreement to someone else, Narrows/AP Narrows "shall not be discharged from its liabilities under this Agreement and shall remain primarily liable to Seller." Larry is concerned that we might a

a, the kids, or family trusts including APO1 and APO2. Gagosian wants us to agree that, if Narrows/AP Narrows assigns the agreement to someone else, Narrows/AP Narrows "shall not be discharged from its liabilities under this Agreement and shall remain primarily liable to Seller." Larry is concerned that

possible to have the partners agree contractually to each continue to maintain insurance on the works that they are contributing to AP Narrows? AP Narrows would be added as a "Named Insured" on Leon's policy with respect to the art that Leon and Narrows are contributing to the partnership, and as a Nam

From: "jeffrey E." <[email protected]> To: Melanie Spinella Subject: Fwd: AP Narrows - art insurance Date: Wed, 20 May 2015 22:45:36 +0000 and you want to know why things seem complicated. . liket he original issue, these are ssimpl

Looking Forward to the Past sale. Leon bought the Calder from PaceWildenstein in 2009 for $3,758,125 (including NY sales tax) and transferred it to Narrows as part of the 2012 contribution of all art to Narrows that Ralph prepared. Christie's is giving Narrows a guarantee of $6.5 million, plus 80% of a

er from PaceWildenstein in 2009 for $3,758,125 (including NY sales tax) and transferred it to Narrows as part of the 2012 contribution of all art to Narrows that Ralph prepared. Christie's is giving Narrows a guarantee of $6.5 million, plus 80% of any overage (the amount of the hammer price above $6.5 mi

Number: Chase Bank 1003 Lexington Avenue, New York, NY 10021 Sublime Art LLC The Commission shall be due and payable to Sublime only if and when Narrows receives the Sale Price in full from the Buyer. Narrows and Sublime agree that neither of them will disclose the Sale Price, the Commission or the

n. 1930 Signed `Klee' (lower right); signed again, dated, numbered and titled '1930 AE. 9 "was fehlt ihn" Klee' (on the stretcher) (the "Klee"). Narrows agrees to pay to Sublime the sum of One Million Eight Hundred Thousand Dollars U.S. ($1,800,000.00) (the "Commission") as the Commission for arrangi

From: Richard Joslin <MIMIII > To: Jeffrey Epstein <[email protected]> Subject: Narrows Date: Tue, 04 Feb 2014 20:41:52 +0000 In prior discussion there was decision/ discussion not to register for sales tax nor issue an exemption cert

:52 +0000 In prior discussion there was decision/ discussion not to register for sales tax nor issue an exemption certificate to seller. In effect Narrows pays sales tax to dealer and then collects from purchaser. Please let me know if you disagree. EFTA00684757

bra, the kids or trusts for any of their benefit. I think we should have Narrows Holdings make the first payment, with the understanding that if AP Narrows is up and running before the next installment payment (on June 30, 2015) and Leon wants the Picasso in AP Narrows, we can assign the contract to AP

uestion Date: Mon, 11 May 2015 14:32:37 +0000 It's true that under the Bank of America loan/pledge documents, we are required to notify the bank if Narrows transfers/sells/assigns any of the art that it owns, so we would be required to notify the bank if we moved the Picasso out of Narrows and into AP

bra, the kids or trusts for any of their benefit. I think we should have Narrows Holdings make the first payment, with the understanding that if AP Narrows is up and running before the next installment payment (on June 30, 2015) and Leon wants the Picasso in AP Narrows, we can assign the contract to AP

with the understanding that if AP Narrows is up and running before the next installment payment (on June 30, 2015) and Leon wants the Picasso in AP Narrows, we can assign the contract to AP Narrows at that time and have it repay Narrows the $23 million. Do you agree that Narrows Holdings should make the

a, the kids, or family trusts including APOI and APO2. Gagosian wants us to agree that, if Narrows/AP Narrows assigns the agreement to someone else, Narrows/AP Narrows "shall not be discharged from its liabilities under this Agreement and shall remain primarily liable to Seller." Larry is concerned that

ent has no money. I think this is a valid concern and that we should agree to it. However, Ada just reminded me that it is possible that Narrows/AP Narrows (really, Leon's) agreeing to effectively guarantee payment by the assignee might be considered a gift to the assignee. In the discussions with Alan

ent has no money. I think this is a valid concern and that we should agree to it. However, Ada just reminded me that it is possible that Narrows/AP Narrows (really, Leon's) agreeing to effectively guarantee payment by the assignee might be considered a gift to the assignee. In the discussions with Alan

a, the kids, or family trusts including APOI and APO2. Gagosian wants us to agree that, if Narrows/AP Narrows assigns the agreement to someone else, Narrows/AP Narrows "shall not be discharged from its liabilities under this Agreement and shall remain primarily liable to Seller." Larry is concerned that

er from PaceWildenstein in 2009 for $3,758,125 (including NY sales tax) and transferred it to Narrows as part of the 2012 contribution of all art to Narrows that Ralph prepared. Christie's is giving Narrows a guarantee of $6.5 million, plus 80% of any overage (the amount of the hammer price above $6.5 m

Looking Forward to the Past sale. Leon bought the Calder from PaceWildenstein in 2009 for $3,758,125 (including NY sales tax) and transferred it to Narrows as part of the 2012 contribution of all art to Narrows that Ralph prepared. Christie's is giving Narrows a guarantee of $6.5 million, plus 80% of an

fore being sold. The Braque is owned by Narrows Holdings LLC (and is collateral on the Bank of America loan), so it would have to be distributed by Narrows to Leon and then contributed by Leon to the 2011 LLC in exchange for membership interests in the LLC. As indicated above, AP Narrows and the LDB 20

et sale price for the Giacometti is $30 million and the purchase price of the Cezanne figure study is also $30 million. The first columns on the AP Narrows spreadsheet show the basis in the Giacometti, the gain that would be deferred in an exchange and the NY sales tax that would be sheltered by operati

15:24:45 +0000 Attachments: Narrows_ Sublime_Commission_Agmnt.pdf Hi Jeffrey, I thought you might want to review the commission agreement between Narrows and Sublime before I send it to Anna. Please let me know if you have any questions or comments. Best, Heather Heather Gray Art Counsel Elysium

[email protected])" <[email protected]> Subject: Narrows - Sublime commission agreement Date: Wed, 20 Sep 2017 15:24:45 +0000 Attachments: Narrows_ Sublime_Commission_Agmnt.pdf Hi Jeffrey, I thought you might want to review the commission agreement between Narrows and Sublime before I send it

get sale price for the Giacometti is $30 million and the purchase price of the Cezanne figure study is also $30 million. The first columns on the AP Narrows spreadsheet show the basis in the Giacometti, the gain that would be deferred in an exchange and the NY sales tax that would be sheltered by operat

efore being sold. The Braque is owned by Narrows Holdings LLC (and is collateral on the Bank of America loan), so it would have to be distributed by Narrows to Leon and then contributed by Leon to the 2011 LLC in exchange for membership interests in the LLC. As indicated above, AP Narrows and the LDB 20

Cornell boxes in his own name, while he owns the remaining four works through Narrows. I know we had some discussions about moving everything into Narrows before the auctions, but I wasn't sure where we came out. The Comells are most likely to be losses, so Eileen and I thought it made sense to leave

[email protected]> Subject: RE: Sotheby's consignment agreements and valuation Date: Fri, 10 Oct 2014 16:28:24 +0000 Okay, I'll switch it all to Narrows. Thanks, Heather From: jeffrey E. [[email protected]] Sent: Friday, October 10, 2014 12:22 PM To: Heather Gray Subject: Re: Sotheby's

fore being sold. The Braque is owned by Narrows Holdings LLC (and is collateral on the Bank of America loan), so it would have to be distributed by Narrows to Leon and then contributed by Leon to the 2011 LLC in exchange for membership interests in the LLC. As indicated above, AP Narrows and the LDB 20

et sale price for the Giacometti is $30 million and the purchase price of the Cezanne figure study is also $30 million. The first columns on the AP Narrows spreadsheet show the basis in the Giacometti, the gain that would be deferred in an exchange and the NY sales tax that would be sheltered by operati

ent has no money. I think this is a valid concern and that we should agree to it. However, Ada just reminded me that it is possible that Narrows/AP Narrows (really, Leon's) agreeing to effectively guarantee payment by the assignee might be considered a gift to the assignee. In the discussions with Alan

a, the kids, or family trusts including APOI and APO2. Gagosian wants us to agree that, if Narrows/AP Narrows assigns the agreement to someone else, Narrows/AP Narrows "shall not be discharged from its liabilities under this Agreement and shall remain primarily liable to Seller." Larry is concerned that

with the understanding that if AP Narrows is up and running before the next installment payment (on June 30, 2015) and Leon wants the Picasso in AP Narrows, we can assign the contract to AP Narrows at that time and have it repay Narrows the $23 million. Do you agree that Narrows Holdings should make th

11, 2015 at 10:32 AM, Heather Gray < > wrote: It's true that under the Bank of America loan/pledge documents, we are required to notify the bank if Narrows transfers/sells/assigns any of the art that it owns, so we would be required to notify the bank if we moved the Picasso out of Narrows and into AP

ollateral) PICASSO. PABLO Femme nue (painting) (3YKD2) 11.000.000 30.000.000 19.000,000 19.000.000 0 EFTA00592228 ALL ART - 3/19/17 Owner Narrows (Collateral) Artist TURNER. JOSEPH WILLIAM MALLORD Title Goldau Basis 1,300.000 CHRISTIE'S 5/11/16 appraised value or purchase price +

and Octavia drawing [LDB owns 40% of this work. The appraised value shown is for the entire work.] 600.000 1,600.000 1.000,000 1,000.000 0 AP Narrows (Collateral) PICASSO, PABLO Paysage^ 2.500.000 3.500,000 1.000.000 1,000.000 0 Narrows (Collateral) PONTORMO (JACOPO CARUCCI) Study of a

prepare an expense estimate? 2. Will AP Narrows be a disregarded entity for income tax purposes? 3. Should Leon contribute high basis art to AP Narrows (preserve basis step-up at death)? 4. Which non-Apollo related investments currently held in BFP will be distributed to NAR Investments (all rough

LP. 4. Confirm who will be the Trustee of APO-B Trust. 5. Confirm that all art held in the APOI Trust and APO2 Trusts will be contributed to AP Narrows or alternatively, which works of art each trust will contribute. 6. Decide who will appraise the art contributed to AP Narrows? Christie's or Sothe