<table><tr><th>From:</th><th>Fenn, Patrick &lt;</th></tr><tr><td>Sent:
To:</td><td>Monday, January 13, 2014 1:34 PM
'Jeffrey Epstein'; Richard Joslin</td></tr><tr><td>Subject:</td><td>RE:</td></tr></table>

Hi Jeffrey. Happy N=w Year. Will look at this. As you know, the right to rec=ive the TRA payments is triggered by a taxable exchange of AOG units. = To the extent a separate asset, likely a capital asset to the extent the addition=l payments are capital. Concern is that assignment of income d=ctrine might apply if the AOG Units also are not transferred. =lso have to look at contractual restrictions — payments under TRA are paid to exchanging party. Will get back to you.</=:p>

<=p>

From: Jeffrey =pstein (mailto:jeevacation@gmail.comj
Sent: Sunday, January 12, 2014 6:37 AM
To: Fenn, Patrick; Richard Joslin
Subject:

can leon sell assign or contribute =either the future tra payments or a portion thereof. . i= it a contract right? capital asset 1234 ,

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can we

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