EFTA00815407.txt

"Hi Jeffrey, From: "Jeffrey E." <[email protected]> To: Melanie Spinella Subject: Fwd: 1031 exchanges ... please print for our 12 ock call"

"From: Heather Gray cti Date: Wed, Oct 12, 2016 at 4:31 PM Subject: RE: 1031 exchanges To: "jeffrey E.""

"Heather Gray Elysium Management LLC 445 Park Avenue"

"AP Narrows LP intends to exchange a Giacometti that it owns (Figure moyenne II)"

"The LDB 2011 LLC intends to exchange a Mondrian that it owns (Composition with Cola Planes and Grey Lines 1)"

"The Schiele ... is owned by the LDB 2011 LLC"

"The Picasso is owned by APO-01, so it would have to be distributed to the LDB 2011 LLC before being sold."

"distributed to the APO-01 trust (which owns 100% of the LDB 2011 LLC)"

"The Braque is owned by Narrows Holdings LLC (and is collateral on the Bank of America loan)"

"The Braque is owned by Narrows Holdings LLC (and is collateral on the Bank of America loan)"

"Larry Gagosian is working on selling the works."

"contributed by Leon to the 2011 LLC in exchange for membership interests in the LLC."

"Jeffrey (or Rich), what combined federal and NYS income tax rate should I use? ... you need to include taxes owed on transaction, if no 1031"