From: "Lerner, Ralph" < To: CC: " cleevaeationggmail.coin> Subject: FW: CONFIDENTIAL - possible sale of work of art Date: Sun, 08 Sep 2013 19:12:30 +0000 Attachments: ATT48942.PDF Dear Mort see attached general calculation 1. donation of art to a public museum, 2. donation of art to a private foundation vs.. 3. the sale of the art. My recommendation is that you immediately set up a Delaware private foundation, donate the Rothko to it and sell the Rothko at public auction. This will generate the maximum amount available to satisfy now various charitable pledges. I can create the foundation have it set up within 48 hours from the time you give me the name (MBZ Foundation ?maybe) , the IRS ruling which could take 90 days or more is retroactive to the date of incorporation. The time pressure is to negotiate the best deal for you so we can meet the publication and publicity deadlines.. Please review, I am currently in the office and always available on my cell at 917 331-2571. I look forward to working with you and, of course, visiting your apartment to see the art. I will wait to hear from you before doing anything. I need the catalogue raisonne number for the Rothko asap , and let me know if you are considering selling anything else. all the best ralph Ralph E. Lerner, Esq. Withers Bergman LLP 430 Park Avenue, 10th Floor New York, New York 10022 T: 212-848-9866 F: 212-848-9888 email: From: NYecopyXP, NYecopyXP Sent: Sunday, September 08, 2013 3:03 PM To: Lerner, Ralph Subject: Scanned document from NYecopyXP, NYecopyXP (NYecopyXP) Withers Bergman LLP 430 Park Avenue, 10th Floor New York, NY 10022-3505 T: +1 212 848 9800 F: +1 212 848 9888 www.withersworldwide.com New York, Greenwich, New Haven, London, Geneva, Zurich, Milan, Hong Kong, British Virgin Islands, Singapore, Padua IRS Required Statement: This document (and any attachments) was not intended or written to be used, and it cannot be used by the recipient, for the purpose of avoiding penalties that may be imposed on any taxpayer EFTA00970028 This email (and any attachments) is confidential and may also be legally privileged. If you are not the intended recipient please immediately notify the sender then delete it from your system. You should not copy it or use it for any purpose nor disclose its contents to any other person. EFTA00970029