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e DRB 2012 Family Trust Agreement and the anticipated tax consequences of certain of its provisions. I. The DRB 2012 Family Trust A. Trust Fund Debra will be the creator of the trust. It is anticipated that she will transfer assets valued at an amount equal to Debra's remaining gif tax credit to t
he assets remaining in the trust at the death of the survivor of you (including all appreciation on the original gift) should pass to the trusts for Debra's issue without federal or New York estate tax. D. Income Tax During Debra's lifetime, the primary trust will be a grantor trust. This means that
like us to prepare a formal tax opinion on which you may rely for penalty relief, please let us know, and we can discuss the cost of preparing one. Internal Revenue Service Circular 230 Notice: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in thi
bed below. B. Dispositive Provisions 1. Distributions The primary trust provides that the trustees must distribute as much of the trust fund to Debra and the settlor's issue' as the independent trustees determine for any reason. I For all purposes of the trust agreement, the settlor's issue inclu
like us to prepare a formal tax opinion on which you may rely for penalty relief, please let us know, and we can discuss the cost of preparing one. Internal Revenue Service Circular 230 Notice: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in thi
move the situs of administration and governing law of the Family Trust from New York to Delaware. It is intended that while at least one of you and Debra is alive and competent, the Family Trust will be a so-called "directed trust." This means that U.S. Trust Company of Delaware ("U.S. Trust"), which
like us to prepare a formal tax opinion on which you may rely for penalty relief, please let us know, and we can discuss the cost of preparing one. Internal Revenue Service Circular 230 Notice: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in thi
Entities connected to both Debra and Internal Revenue Service Circular

Jeffrey Epstein
PERSONLeon Black
PERSONEileen Alexanderson
PERSONElyse G. Kirschner
PERSONRichard Ressler
PERSON
the Internal Revenue Service
ORGANIZATIONFamily Trust
ORGANIZATIONMcDermott Will & Emery LLP
ORGANIZATIONDM US
ORGANIZATIONthe Primary Beneficiary's
ORGANIZATION
Joshua
PERSONliving,2
ORGANIZATION