EFTA02472875.pdf

From: jeffrey E. <jeevacation@gmail.com> Sent: Thursday, February 11, 2016 2:54 PM To: Brad Wechsler Subject: Re: no problem , the issue is simple, you have man= people in your office. no one is looking at the numbers received =A0 to check for the most basic of errors. fo=warding me, numbers that have not even been looked at seems a waste of eve=yones time, especially mine - not dissimilar to zero rec=iveables on art space. . I dont have the time to do the basic =eview that should have been being done. Sorry but i dont have the t=me this week to talk to rj, like my suggestion from day one, =C2 all needs to be redone, sorry, rich does not understand=how fuel cost per hour times number of hours , needs to be accurate.= leon and you told me that castrucii selling point was that he=said his fundamental view was that he needed accurate numbers or everythin= else was a waste of time. here we are On Thu, Feb 11, 2016 a= 9:44 AM, Brad Wechsler wrote:<=r> Jeffrey-some people here feel you are confusing certain items....which may =r may not be true. May I suggest you organize your questions and get on th= phone with rich j and then we can identify meaningful loose ends. Two thi=gs to remember: we don't control the form in which jet produces numbers and, I believe, most importantly yo= and I (and likely leon) agree that a simple restructure to part 91 is lik=ly the best path. In addition--and on a separate front-- we plan to scrutin=ze costs for potential savings. As you know we have not done this yet. Also, I'm a little unclear on w=at your ultimate goal is. B Sent from my Verizon Wireless BlackBerry From: jeffrey E. <jeevacation@gmail.com <mailto:jeevacation@gmail.com» Date: Thu, 11 Feb 2016 09:20:34 -0500 To: Brad Wechsler Cc: Richard J Bronstein Melanie Spinell= John Castrucci Joe Avantario >; Richard Joslin Subject: Re: it says charter revenue only 312 but letter says apo=lo hours were 42 at 18k each hour? On Tue, Feb 9, 2016 at 6:41 PM, Brad Wechsler wrote: MEMORANDUM ATTORNEY-CLIENT PRIVLEDGE</=> qspan> EFTA_R1_01585008 EFTA02472875  TO: =AO Rick Bronstein =AO =C2 =AO CC: =C2 John Castrucci =C2 Leon Black =AO =C2 =AO =C2 =AO Joe Avantario<=p> =C2 =AO =C2 =AO =C2 =AO =C2 Rich Jos=in FROM: Brad Wechsler =C2 =AO =C2 =AO =C2 Jeffrey Epstein DATE: February 9, 2016=/u> Leon, 1. =C2 Attached, please find the =anuary 26th memo on the airplane which was sent to you previously. It deal= with Part 91 vs. 135 and attendant costs and income tax benefits. The office feels that with respect to income tax, Par= 135 is more favorable, but not significantly so, i.e., between 0 and $400K depending on use. 2. =C2 Also included are detailed=operating costs. These were previously sent to Jeffrey but not previously =ot sent to you. 3. =C2 The final note details the=FET and sales tax consequences of moving from the current structure to a s=mplified structure. Were we to move to a very simple Part 91only structure you could likely save $200K/year but would h=ve to own and operate the plane in your personal name (your insurance is s=fficient, but there would be a certain lack of privacy). If you held the p=ane in a sole purpose LLC the aforementioned savings would disappear. If Jeffrey wants to take a deep dive, we have muc= detailed material and we would also suggest he speak to Rich J and our av=ation attorney. 4. =C2 Bottom-line, a lot of work=has been done and there is not a compelling answer, one way or another. Ta=ing into account income tax attributes, sales tax attributes and ease of use attributes it's almost a push, thou=h I would probably marginally favor Part 135. I believe Jeffrey favors Par= 91, which in my mind, is a sufficient reason to go that route. We should =iscuss. 2 EFTA_R1_01585009 EFTA02472876  Thanks please note 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 JEE 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 please =ote The information contained in this communication is confiden=ial, may be attorney-client privileged, may constitute inside informati=n, and is intended only for the use of the addressee. It is the propert= of JEE Unauthorized use, disclosure or copying of this communica=ion or any part thereof is strictly prohibited and may be unlawful. If =ou have received this communication in error, please notify us immediat=ly by return e-mail or by e-mail to jeevacation@gmail.com <mailto:jeevacation@gmail=com> , and destroy this comm=nication and all copies thereof, including all attachments. copyright -=11 rights reserved 3 EFTA_R1_01585010 EFTA02472877