Russia-based real estate project shortly after the conclusion of the 2013 Miss 291 Universe pageant in Moscow. Donald J. Trump Jr. served as the primary negotiator on behalf of the Trump Organization; Emin Agalarov (son of Aras Agalarov) and Irakli “Ike” Kaveladze represented the Crocus Group during 292 293 negotiations, with the occasional assistance of Robert Goldstone. In December 2013, Kaveladze and Trump Jr. negotiated and signed 294 preliminary terms of an agreement for the Trump Tower Moscow project. On December 23, 2013, after discussions with Donald J. Trump, the Trump Organization agreed to accept an arrangement whereby the organization received 295 a flat 3.5% commission on all sales, with no licensing fees or incentives. The 296 parties negotiated a letter of intent during January and February 2014. From January 2014 through November 2014, the Trump Organization and Crocus Group discussed development plans for the Moscow project. Some time before January 24, 2014, the Crocus Group sent the Trump Organization a proposal for a 800-unit, 194-meter building to be constructed at an Agalarov- owned site in Moscow called “Crocus City,” which had also been the site of the 297 Miss Universe pageant. In February 2014, Ivanka Trump met with Emin 298 Agalarov and toured the Crocus City site during a visit to Moscow. From March 2014 through July 2014, the groups discussed “design standards” and 299 other architectural elements. For example, in July 2014, members of the Trump Organization sent Crocus Group counterparties questions about the “demographics of these prospective buyers” in the Crocus City area, the development of neighboring parcels in Crocus City, and concepts for redesigning 300 portions of the building. In August 2014, the Trump Organization requested specifications for a competing Marriott-branded tower being built in Crocus 301 City. Beginning in September 2014, the Trump Organization stopped responding 302 in a timely fashion to correspondence and proposals from the Crocus Group. Communications between the two groups continued through November 2014 with decreasing frequency; what appears to be the last communication is dated 303 November 24, 2014. The project appears not to have developed past the planning stage, and no construction occurred.

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