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From: Ada Clapp Sent: Friday, September 27, 2013 1:52 PM To: Jeffrey Epstein Cc: Melanie Spinella; Eileen Alexanderson; Alan S. Halperin Subject: Re: Pour-over and GRATs Good =orning Jeffrey, I understand that you want to move =uickly (though perhaps not all the nuances for your ti
on in the =006 Trust (which will disappear), what gets decanted into the =eritage Trust is the art. Nice and clean --no need to do a =ubstitution in the Heritage Trust that might draw attention if we =ecide to move forward on someone else's =uling. 2. The substitution language cited =n the petition for the ruling
omments you may have on the topics discussed in this memorandum or any other aspect of Leon's estate planning. C.T.D. E.A.K. cc: Leon D. Black Alan S. Halperin (Paul, Weiss, Riflcind, Wharton & Garrison LLP) -14- EFTA00591806
the Black Family 1997 GST Exempt Trust holds GST tax- exempt assets. Because that trust does not include the more tailored governance provisions of the Heritage Trust, it may be desirable to consolidate the GST exempt assets in a single trust. 6 As of December 31, 2016. 7 In Part III.a. below, we recommend pou
: October 23, 2013 Re: Summary of the APOI Agreement Following is a summary of the APOI Agreement (the "Agreement") that was prepared for you by Alan Halperin of Paul, Weiss, Rifkind, Wharton & Garrison, LLP. You are the Grantor of the trusts created under the Agreement. It is intended that this trust wil
OI GRAT, as well as the assets of the Black 2006 Family Trust upon a decanting of such trust by its trustees. Once you have settled on the terms of the Heritage Trust, it will be the ultimate recipient of the assets held under this Agreement. I. Discretionary Trust. Until such time as the Trustees decide to crea
: October 23, 2013 Re: Summary of the APO2 Agreement Following is a summary of the APO2 Agreement (the "Agreement") that was prepared for you by Alan Halperin of Paul, Weiss, Riflcind, Wharton & Garrison, LLP. You are the Grantor of the trusts created under the Agreement. It is intended that this trust wi
ets of the Non-Exempt Trust under the Black Family 1997 Trust upon a decanting of such trust by its trustees. Once you have settled on the terms of the Heritage Trust, it will be the ultimate recipient of the assets held under this Agreement. I. Discretionary Trust. Until such time as the Trustees decide to crea
Entities connected to both Alan S. Halperin and the Heritage Trust

Jeffrey Epstein
PERSON
Alan Dershowitz
PERSONEileen Alexanderson
PERSONWeiss
PERSONLeon Black
PERSON
Marc Rich
PERSONAda Clapp
PERSONElysium Management LLC
ORGANIZATION
Melanie Spinella
PERSONDebra
PERSON
Barry Diller
PERSON
Michael Cohen
PERSON
NEW YORK NY
LOCATIONBlack Family Partners
ORGANIZATIONJohn Hannan
PERSONRichard Ressler
PERSONBarry Cohen
PERSONSeparate Trust
ORGANIZATIONUS Trust
ORGANIZATIONOverview
ORGANIZATION