EFTA02520691.pdf

From: Jeffrey Epstein <jeevacation@gmail.com> Sent: Monday, May 20, 2013 1:22 PM To: Fenn, Patrick Subject: Re: FW: Early Termination Calculation can we distribute out amh? I want to end up owning t=e holder and the debt. in different pockets. On Mon, May 20, 2013 at 9:08 AM, =enn, Patrick <mailto:a wrote: Ok. Yes, thinking through possibilities. From: Jeffrey Epstein Imailto:jeevacation@gmail.com <mailto:jeevacat=on@gmail.com> ] Sent: Monday, May 20, 2013 08:19 AM To: Fenn, Patrick Subject: Re: FW: Early Termination Calculation could they run the calcuations at a 30 and 35 dollar price=for apo , thanks, also have you given tought to refreshing the=basis in amh.? new loan,? partnership, guaranteed either payments=or assignment of tra in whole? On Mon, May 20, 2013 at 7:46 AM, Fenn, Patrick <=pan dir="ltr"> <mailto wrote: Jeffrey, <=p> Calculation from Brian Kn=dson at E&Y. Note that this relates only to the unexchanged unit=, and does not include the existing TRA payments. <=p> Regards <=p> EFTA_R1_01657583 EFTA02520691  Hi Patrick, Attached is the calculation that we put together for Leon. As we=discussed, this only calculates the estimated early termination payment wi=h respect to the APP units held by Leon - it does not yet calculate the estimated early termination payment with respect to rema=ning TRA benefits related to the 2007 exchange. I have added an assumption= tab to the workbook outlining many of the items that we discussed. Thanks= Brian Brian Knudson=span style="font-size:10.0ptfont-family:"Arial","sans-se=if""> I Partner I National Tax - Partnership and Joint Ventures Ernst & Young LLP 200 South Sixth Street, Suit= 1400, Minneapolis, Minnesota 55402, United States of America Office: +1612 371 6387 <tel:%2B1%20612%20371%206387> I Mobile: +1 612 849 0339 <tel:%2B1%20612%20849%200339> I <mailto Website: www.ey.com=/span> <http://www.ey.com> Assistan :Lnr WI Ph = : <tel <mailto Thank you for considering th= environmental impact of printing emails. Any=U.S. tax advice contained in the body of this e-mail was not intended or w=itten to be used, and cannot be used, by the recipient for the purpose of =voiding penalties The information contained in this message may be privileged and confidentia= and protected from disclosure. If the reader of this message is not the i=tended recipient, or an employee or agent responsible for delivering this =essage to the intended recipient, you are hereby notified that any dissemination, distribution or copying of=this communication is strictly prohibited. If you have received this commu=ication in error, please notify us immediately by replying to the message =nd deleting it from your computer. Notice required by law: This e-mail may constitute an advertisement or soli=itation under U.S. law, if its primary purpose is to advertise or promote = commercial product or service. You may choose not to receive advertising =nd promotional messages from Ernst & Young LLP (except for Ernst & Young Online and the ey.com website, which track e-mail preferences throw h a separate proce=s) at this e-mail address by forwarding this message to <mailt If you do so, the sender of this message will be notified promptly. =ur principal postal address is 5 Times Square, New York, NY 10036. Thank y=u. Ernst & Young LLP IRS Circular 230 Notice Requirement: This communication is not given in the=form of a covered opinion, within the meaning of Circular 230 issued by th= United States Secretary of the Treasury. Thus, we are required to 2 EFTA_R1_01657584 EFTA02520692 inform =ou that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding Uni=ed States federal tax penalties. In addition, any tax advice contained in =his communication may not be used to promote, market or recommend a transa=tion to another party. The information contained in this e-mail message is intended only for the p=rsonal and confidential use of the recipient(s) named above. If you have r=ceived this communication in error, please notify us immediately by e- mail= and delete the original message. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com <mailto:jeevacation@gmail.com> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved IRS Circular 230 Notice Requirement: This communication is not given in the=form of a covered opinion, within the meaning of Circular 230 issued by th= United States Secretary of the Treasury. Thus, we are required to inform =ou that you cannot rely upon any tax advice contained in this communicatio= for the purpose of avoiding United States federal tax penalties. In addit=on, any tax advice contained in this communication may not be used to prom=te, market or recommend a transaction to another party. The information contained in this e-mail message is intended only for the p=rsonal and confidential use of the recipient(s) named above. If you have r=ceived this communication in error, please notify us immediately by e-mail= and delete the original message. =Ain ***** ***** ***************** **en The information contained in this c=mmunication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the a=dressee. It is the property of Jeffrey Epstein Unauthorized use, di=closure or copying of this communication or any part thereof is strictl= prohibited and may be unlawful. If you have received this communication in error, p=ease notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com, =nd destroy this communication and all copies thereof, including all attachm=nts. copyright -all rights reserved 3 EFTA_R1_01657585 EFTA02520693