(23,338,800 $ 1,3158,749,653 Residue Passes to CLA7s 1 1,358,749,653 see page 5 see page 5 Marital Trust Residue Added U• • Debra's Death: CLATs are funded with Cash Black Famly Partners LP (80.28%1 An See 'Notes and Assumosons" Par. don 82 5,000.000 0.3680% 1,334,875,832 i82430% 18.8

&C basically thought the estate plan was fine. They highlighted some low likelihood governance issues at Apollo that could screw up the testamentary CLATs. They note that we have not maximized our GST. I'm sure Leon will be fine sending it to you and I hope to do so tomorrow. Sent from my iPhone On J

see no reason not to implement this planning now as flexibility can be maintained to take into account potential tax changes by providing that the CLATs will be funded only in the event there is an estate tax upon Leon's death. Funding the CLATs with interests in Black Family Partners, L.P. ("BFP")

lan around that. My goal is to be able to tell him "If you sell certain art you will achieve the following benefits." Not quite there yet. > On the CLATs, I hear you that no one has experience with art. But as you have pointed out, Leon's situation is unique. Unless we hear specific reasons why it doe

lan around that. My goal is to be able to tell him "If you sell certain art you will achieve the following benefits." Not quite there yet. > On the CLATs, I hear you that no one has experience with art. But as you have pointed out, Leon's situation is unique. Unless we hear specific reasons why it doe

lan around that. My goal is to be able to tell him "If you sell certain art you will achieve the following benefits." Not quite there yet. > On the CLATs, I hear you that no one has experience with art. But as you have pointed out, Leon's situation is unique. Unless we hear specific reasons why it doe

We are not aware of anyone on our team who has put art in OATS, but would note the following o There are 2 chapters in Ralph Lerner's book on art in CLATs, so it doesn't seem like an alien concept o In any event, we just aren't seeing the risk. We thought about valuation issues, but valuation seems kin

to tell him =quot;lf you sell certain art you will achieve the following benefits."= Not quite there yet. EFTA_R1_01432409 EFTA02398439 > On the CLATs, I hear you that no one has experience with art. But as y=u have pointed out, Leon's situation is unique. Unless we hear specific re=sons why it doe

ound that. My goal is to be able to tell him =quot;If you sell certain art you will achieve the following benefits."= Not quite there yet. > On the CLATs, I hear you that no one has experience with art. But as y=u have pointed out, Leon's situation is unique. Unless we hear specific re=sons why it doe

lan around that. My=goal is to be able to tell him "If you sell certain art you will achieve t=e following benefits." Not quite there yet. > On the CLATs, I hear you that no one has experience with art. But as you =ave pointed out, Leon's situation is unique. Unless we hear specific reaso=s why it doe

From: Barry J. Cohen Sent: Friday, September 22, 2017 5:17 PM To: jeffrey E. Subject: RE: Art in CLATs--PRIVILEGED AND CONFIDENTIAL Then I have misunderstood your past comments. I wrote this to address multiple issues I thought you specifically raise

From: jeffrey E. <[email protected]> Sent: Friday, September 22, 2017 5:18 PM To: Barry J. Cohen; Melanie Spinella Subject: Re: Art in CLATs--PRIVILEGED AND CONFIDENTIAL there is a reason i have not engaged on this subject:40=AD and have no intention of doing so. * one point. barry, as t

From: "Barry J. Cohen" To: Jeffrey E. <[email protected]> Subject: RE: Art in CLATs—PRIVILEGED AND CONFIDENTIAL Sent: Friday, September 22, 2017 5:31:47 PM I completely agree that we could use more clarity from Leon. I have though

&C basically thought =he estate plan was fine. They highlighted some low likelihood governance i=sues at Apollo that could screw up the testamentary CLATs. They note=that we have not maximized our GST. I'm sure Leon will be fine s=nding it to you and I hope to do so tomorrow. Sent from my iPhone On J