<table><tr><th>From:</th><th>Heather Gray &lt;</th></tr><tr><td>Sent:</td><td>Thursday, April 30, 2015 7:01 PM</td></tr><tr><td>To:</td><td>jeffrey E.</td></tr><tr><td>Subject:</td><td>RE: Re:</td></tr></table>

Get an insurance figure meaning have Christie's give us an insurance value for it? I'd be very, very concerned about them keeping it confidential... Can we wait until Leon takes possession of it in February 2016? Until then, Larry is insuring it for the full purchase price.

From: jeffrey E. [mailto:jeevacation@gmail.comj
Sent: Thursday, April 30, 2015 2:59 PM
To: Heather Gray
Subject: Re: Re:

also would be nice to get an insurance figure on a 100 million dollar PLASTER

On Thu, Apr 30, 2015 at 2:55 PM, Heather Gray <mailto > > wrote:

Still waiting for the Christie's rental guy to call me back. I'll call again. Frankly, I think other collectors are just ignoring/aren't aware of the sales tax issue. But let's see what the Christie's guy has to say.

From: jeffrey E. [mailto:jeevacation@gmail.com <mailto:jeevacation@gmail.com> I
Sent: Thursday, April 30, 2015 2:49 PM
To: Heather Gray
Subject: Re:

any more info on rental rates , off the record. if we could get a 1percent per year or less. it might be worth it. if we can avoid sales tax

- Type: Email header + message snippet
- Date/time: Thu, Apr 30, 2015 at 2:40 PM
- Sender: Heather Gray (email address redacted)
- Recipient: Jeffrey (salutation: "Hi Jeffrey,")
- Message snippet: "any more info on rental rates, off the record. if we could get a 1percent per year or less. it might be worth it. if we can avoid sales tax"
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I'll find someone at Paul Weiss to discuss this with and will report back. For what it's worth, I think he should absolutely be able to do it under the trade-in credit rules (section 526.5(f) of the Sales and Use Tax Regulations). But I'll find out from the PW folks.

Best,

Heather

From: jeffrey E. [mailto:jeevacation@gmail.com <mailto:jeevacation@gmail.com>
Sent: Thursday, April 30, 2015 2:34 PM
To: Heather Gray
Subject:

heather, track down with someone at pw. whether as opposed to a 1031 leon coudl use other fully paid for art to avoid sales tax if traded in to gogosian

this would not shelter gain, only limit sales tax. to picasso minus trade

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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 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