EFTA01047438.txt

"Barry J. Cohen I Elysium Management, LLC"

"From: Thomas Turrin To: ... Jeffrey E. Date: Mon, 01 May 2017 16:17:29 +0000"

"From: Barry 3. Cohen [mailto: ... To: Brad Wechsler; Jeffrey E."

"Leon's ownership was deliberately structured through the family partnership for estate planning purposes."

"Deloitte (with help of Apollo tax group) has always prepared the tax returns of BRH Holdings, LP."

"Who are the owners of BRH on BRH's books and records? Unclear whether it is LDB or BFP. Black Family Partners, LP -since all K-1's have always been is"

"Apollo understands that the IRS's review focused on the manager entity of an old Apollo Credit fund (VIF). This entity rolls up into BRH."

"Leon's ownership was deliberately structured through the family partnership for estate planning purposes. Wendy Dulman... was involved in setting up t"