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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA00691372: Harris, Beneficial Owner and Arrangement (DS9)

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This document discusses proposed modifications to an investment arrangement involving Leon and Investco to ensure Leon is not viewed as the beneficial owner of traded securities. The correspondence references Phil's proposal that Investco be a wholly owned subsidiary of a family office and questions whether Rowan's and Harris's offices have resolved the matter.

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Excerpt 1
This is to ensure that Leon is not viewed as the **beneficial** **owner** of the securities being traded by Investco.
Excerpt 2
They propose the following tweaks to the **arrangement** we discussed: 1.
Excerpt 3
Phil feels that Investco should be a wholly owned subsidiary of the family office in order to ensure that the **arrangement** falls within the FO exception

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