If he doesn’t have ASR couldn’t he use a differential from a 300CE with the M104.981? I think that is the same housing as the 400E. He would just need to swap the 3 arm yoke with the 4 arm. Maybe uses the same axles so the flanges would be a direct bolt up. The ratio in that is a 3:06. My 92 W140 400SE had the 2:82 ratio and that car ran really strong even with the additional weight.