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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01454392: Mike Gallagher, Gallagher and Memorandum (DS10)

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Email from Willkie Farr & Gallagher LLP (1700 Broadway, 34th Floor, New York, NY 10019) providing a tax memorandum regarding the tax treatment of charitable legacy applications of a Private Placement Variable Annuity (PPVA) investment. The memorandum was prepared for a meeting with 'the Principal' and addresses tax research conducted by the law firm.

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Excerpt 1
1700 Broadway, 34th Floor New York, NY 10019 Also, when we got off the call, Michael and I thought it may be helpful for you to have the Willkie Farr & **Gallagher**
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Tax Memorandum at your fingertips for when you meet with the Principal tomorrow (see "Willkie Farr & **Gallagher** LLP Memorandum," attached).
Excerpt 3
We asked Willkie Farr & **Gallagher** to research the tax treatment of the charitable legacy application of a Private Placement Variable Annuity (PPVA) Investment

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