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"Substitution Power"). The provision of the Trust Agreement creating the Substitution Power reads as follows: "Reacquisition of Trust Assets. The Settlor at any time or from time to time may acquire or reacquire any portion of the Trust Fund of any Trust by substituting therefor other property of an
es a bargain between parties that provides a motivating reason for each party to enter into the contract or engage in a transaction. See Richman v. Brookhaven, 80 Misc. 2d 563, N.Y.S.2d 731 (1975); Weiner v. McGraw-Hill, Inc. 57 N.Y.2d 458, 457 N.Y.S.2d 193, 443 N.E.2d 441 (2d Dep't 1982); In re Toscano,
Settlor") created an irrevocable trust (the "Trust") pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. The Settlor is deemed to own the Trust property for Federal and New York State income tax purposes, as provided in Sections 671 to 679 of the Internal Revenue
es a bargain between parties that provides a motivating reason for each party to enter into the contract or engage in a transaction. See Richman v. Brookhaven, 80 Misc. 2d 563, N.Y.S.2d 731 (1975); Weiner v. McGraw-Hill, Inc. 57 N.Y.2d 458, 457 N.Y.S.2d 193, 443 N.E.2d 441 (2d Dep't 1982); In re Toscana,
Settlor") created an irrevocable trust (the "Trust") pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. The Settlor is deemed to own the Trust property for Federal and New York State income tax purposes, as provided in Sections 671 to 679 of the Internal Revenue
es a bargain between parties that provides a motivating reason for each party to enter into the contract or engage in a transaction. See Richman v. Brookhaven, 80 Misc. 2d 563, N.Y.S.2d 731 (1975); Weiner v. McGraw-Hill, Inc. 57 N.Y.2d 458, 457 N.Y.S.2d 193, 443 N.E.2d 441 (2d Dep't 1982); In re Toscana,
ution Power"). The provision of the Trust Agreement eating thejSubstitution Power reads as follows: Cala _.e "Reacquisition of Trust Assets. The Settlor at any time or from time to time may acquire or reacquire any portion of the Trust Fund of any Trust by substituting therefor other property of an
es a bargain between parties that provides a motivating reason for each party to enter into the contract or engage in a transaction. See Richman v. Brookhaven, 80 Misc. 2d 563, N.Y.S.2d 731 (1975); Weiner v. McGraw-Hill, Inc. 57 N.Y.2d 458, 457 N.Y.S.2d 193, 443 N.E.2d 441 (2d Dep't 1982); In re Toscano,
ution Power"). The provision of the Trust Agreement eating thejSubstitution Power reads as follows: Cala _.e "Reacquisition of Trust Assets. The Settlor at any time or from time to time may acquire or reacquire any portion of the Trust Fund of any Trust by substituting therefor other property of an
es a bargain between parties that provides a motivating reason for each party to enter into the contract or engage in a transaction. See Richman v. Brookhaven, 80 Misc. 2d 563, N.Y.S.2d 731 (1975); Weiner v. McGraw-Hill, Inc. 57 N.Y.2d 458, 457 N.Y.S.2d 193, 443 N.E.2d 441 (2d Dep't 1982); In re Toscano,
Settlor") created an irrevocable trust (the "Trust") pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. The Settlor is deemed to own the Trust property for Federal and New York State income tax purposes, as provided in Sections 671 to 679 of the Internal Revenue
es a bargain between parties that provides a motivating reason for each party to enter into the contract or engage in a transaction. See Richman v. Brookhaven, 80 Misc. 2d 563, N.Y.S.2d 731 (1975); Weiner v. McGraw-Hill, Inc. 57 N.Y.2d 458, 457 N.Y.S.2d 193, 443 N.E.2d 441 (2d Dep't 1982); In re Toscana,
Settlor") created an irrevocable trust (the "Trust") pursuant to a trust agreement (the "Trust Agreement") between the Trustees and the Settlor. The Settlor is deemed to own the Trust property for Federal and New York State income tax purposes, as provided in Sections 671 to 679 of the Internal Revenue
es a bargain between parties that provides a motivating reason for each party to enter into the contract or engage in a transaction. See Richman v. Brookhaven, 80 Misc. 2d 563, N.Y.S.2d 731 (1975); Weiner v. McGraw-Hill, Inc. 57 N.Y.2d 458, 457 N.Y.S.2d 193, 443 N.E.2d 441 (2d Dep't 1982); In re Toscana,
Entities connected to both Settlor and Brookhaven

Samantha Power
PERSONthe Trust Fund of any Trust
ORGANIZATIONFederal and New York State
ORGANIZATIONthe "Substituted Property
ORGANIZATION
New York State
LOCATIONMartin Weinberg
PERSONN.Y.2d 458
ORGANIZATIONReacquisition of Trust Assets
ORGANIZATIONRichman
PERSONDepartment of Taxation and Finance
ORGANIZATIONSubstitution Power
ORGANIZATION
Jeffrey Epstein
PERSON
McGraw-Hill
ORGANIZATIONToscana
LOCATIONthe Settlor's Substitution Power
ORGANIZATIONthe Trust Property
ORGANIZATIONMcGraw-Hill, Inc.
ORGANIZATIONToscano
ORGANIZATION
Exchange
ORGANIZATIONExchan
LOCATION