<table><tr><th>From: </th><th>jeffrey E. &lt;jeevacation@gmail.com&gt;</th></tr><tr><td>Sent: </td><td>Monday, May 2, 2016 4:00 PM</td></tr><tr><td>To: </td><td>Melanie Spinella</td></tr><tr><td>Subject: </td><td>Fwd: </td></tr></table>

brads going to present me his ideas on presentation. =? . re tra fire drill review. needs a =oal. . not merely see what categories things fall into . =amendments should be tailored for benefit. not just clarified.

<=iv>

Forwarded messa e
F=om: Brad Wechsler
=ate: Mon, May 2, 2016 at 11:53 AM
Subject: Re:
To: "jeevacation@gmail.com" <jeevacation@gmail.com>

Jeffrey-let me give you the top-line and others =an fill in as necessary on the issues noted below and progress.

1. 8RH k: key point is that both apo and pw have indicated that their read =s that no two principals can take an action that is prejudicial to the thi=ds estate. This is key but must be socialized with marc and josh (by john =) and then be clearly reflected.

A. Of lesser importance, wendy is trying to push thru the 754 election at a= professionals, make certain an estate has access to "information rig=ts", see if the three partners want mfn investment rights to continue=past death and fix some language "clarifications.

Wendy is quarterbacking this and timing is apo dependent which means likely=to be a process.

On some none "fire-drill" issues which are nonetheless quite impt= pls note:

2. People are comfortable with TRA transfer with respect to 2007 stock sale= and, I believe, are expressing "sufficient comfort" with respec= to a TRA transfer for future sales. There are definitely imbedded issues =ith respect to "completed gifts" and creating a separation from BRH without causing tax effects. Nonetheless, it appears=we'll come out ok.

3. TIC still appears somewhat problematic to alan or said differently: I do='t believe AH is comfortable with "nominal ownership and exclusiv= use".

4. We (and you) now know that a clat works and we can have an ultimate bene=iciary as the foundation, a clat or both. You, leon and alan have to decid= whether you want to "hard wire" the clat into the planning coda= (can do one that has some built in flexibility) or defer to a later date.

5. By later today or tomorrow I shld be able to show you "my take"= on how to simply present the grat back-up.

Obviously feel free to reach out to any on and all for more detail on the a=ove. B

From: Jeffrey E. [mailto:jeevacation@gmail.com <mailto:jeevacation@g=ail.com>
Sent: Monday, May 02, 2016 06:20 AM
To: 1 Brad Wechsler
Subject:

where are we with re do of fire drill docs

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please note

=he information contained in this communication is confidential, may be =ttorney-client privileged, may constitute inside information, and is in=ended only for the use of the addressee. It is the property of JEEUnauthorized use, disclosure or copying of this communication or any p=rt thereof is strictly prohibited and may be unlawful. If you have rece=ved this communication in error, please notify us immediately by ret=rn e-mail or by e-mail to jeevacation@gmail.com <mailto:jeevacation@gmail.com> , and destroy this communication an= all copies thereof, including all attachments. copyright -all rights r=served