<table><tr><th>From:</th><th>Richard Joslin</th><th></th></tr><tr><td>Sent:</td><td>Thursday, February 11, 2016 2:37 PM</td><td></td></tr><tr><td>To:</td><td>jeffrey E.; Brad Wechsler</td><td></td></tr><tr><td>Cc:</td><td>Richard J Bronstein; Melanie SpineIla
Avantario </td><td>John Castrucci; Joe</td></tr><tr><td>Subject:</td><td>RE: Re:</td><td></td></tr></table>

The 42 hours include both Part 91and Part 135 hours. Part 135 is the charter component and that gives rise to charter revenue.

From: jeffrey E. [mailto:jeevacation@gmail.com]
Sent: Thursday, February 11, 2016 9:21 AM
To: Brad Wechsler
Cc: Richard J Bronstein, Melanie Spinella, John Castrucci, Joe Avantario, Richard, Joslin
Subject: Re:

it says charter revenue only 312 but letter says apollo hours were 42 at 18k each hour?

On Tue, Feb 9, 2016 at 6:41 PM, Brad Wechsler > wrote:

## MEMORANDUM

ATTORNEY-CLIENT PRIVLEDGE

TO: Rick Bronstein CC: John Castrucci

Leon Black Joe Avantario

Rich Joslin

FROM: Brad Wechsler Jeffrey Epstein

## MEMORANDUM (cont.)

Leon,

1. Attached, please find the January 26th memo on the airplane which was sent to you previously. It deals with Part 91 vs. 135 and attendant costs and income tax benefits. The office feels that with respect to income tax, Part 135 is more favorable, but not significantly so, i.e., between 0 and $400K depending on use.

2. Also included are detailed operating costs. These were previously sent to Jeffrey but not previously not sent to you.

3. The final note details the FET and sales tax consequences of moving from the current structure to a simplified structure. Were we to move to a very simple Part 91 only structure you could likely save $200K/year but would have to own and operate the plane in your personal name (your insurance is sufficient, but there would be a certain lack of privacy). If you held the plane in a sole purpose LLC the aforementioned savings would disappear. If Jeffrey wants to take a deep dive, we have much detailed material and we would also suggest he speak to Rich J and our aviation attorney.

4. Bottom-line, a lot of work has been done and there is not a compelling answer, one way or another. Taking into account income tax attributes, sales tax attributes and ease of use attributes it's almost a push, though I would probably marginally favor Part 135. I believe Jeffrey favors Part 91, which in my mind, is a sufficient reason to go that route. We should discuss.

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,

## MEMORANDUM (cont.)

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