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anagement LLC) FROM: Charles T. Dowling Elizabeth A. Kubanik RE: Leon Black Estate Planning This memorandum summarizes our high-level thoughts on Leon Black's estate planning based upon the information and documents that have been provided to us and our discussions with you. As a general matter, we have b
questions or comments 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
harles T. Dowling Elizabeth A. Kubanik RE: Leon Black Estate Planning This memorandum summarizes our h
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
ren Indyke requested whereby all Directors of the Leon Black Family Foundation acknowledge that you resigned
ndyke requested whereby all Directors of the Leon Black Family Foundation acknowledge that you resigned
documents Paul Weiss prepared to appoint new directors for the Leon Black Family Foundation. 6. Preparing a bullet point summary of Leon's Will and the Heritage Trust so you can speak with him about the changes he wishes to make to one or both documents 7. Prepare new illustrations for Estate Flow at $25 and $30/
CHECKLIST FOR LEON BLACK ESTATE PLANNING AND RESTRUCTURING As of January
CHECKLIST FOR LEON BLACK ESTATE PLANNING AND RESTRUCTURING As of January
ust Agreement. PW Complete but revisions likely 2. Leon to execute Trust Agreement. PW Complete 3. Determine which assets will be decanted to the Heritage Trust (2006 Trust, 1997 non-GST exempt trust, etc.) and the timing. • If 1997 Trust assets, wait until 2009 GRAT terminates? Or assign receivable? Tea
ial Inventory As of April 16, 2014 Assets Cash and Marketable Securities 12,298,000 Apollo Credit Opportunities 40,838,000 Note Receivable From Leon D. Black 1,694,738,000 Note Receivable From APO2 Declaration 86,436,000 Art 142,231,000 Total Assets $ 1,976,541,000 Includes assets held through LBF
ing Overview Presented to: Leon D. and Debra R. Black Overview of Estate Plan as of April 16, 2014 Ma
pal to Debra and Leon's descendants. strata to the sienna:on guidelines maned in tie Trust Agreement. After Leon's death. art andtoilet-Wes held in the Heritage Trust designaled for a particular child will be darned to such chiiSs Legacy Tnnl. Alter Debra's death. simitury designaled items in the Marital Trust wa
LEON D. BLACK: TERM SHEET FOR TESTAMENTARY DOCUMENTS Will I.
LEON D. BLACK: TERM SHEET FOR TESTAMENTARY DOCUMENTS Will I.
a will receive outright the Manhattan apartments; the remaining residences will be held in her marital trust. If Debra directs property to be sold, the Heritage Trust, followed by the children (or their Legacy Trusts) will have a right of first refusal. ii. If Debra predeceases, the Manhattan apartments will be s
DOCUMENT SUMMARY To: Leon D. Black From: Ada Clapp Date: October 23, 2013 Re: Summary of the APOI Agreement Following is a summary of the APOI Agreement (the "Agreement") that w
DOCUMENT SUMMARY To: Leon D. Black From: Ada Clapp Date: October 23, 2013 Re:
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
Black Family Partners Apollo Management 9 West 57th Street New York, New York 10019 Ada Cla Phone: Email: To: Leon D. Black From: Ada Clapp Date: October 23, 2013 Re: Summary of the APO2 Agreement Following is a summary of the APO2 Agreement (the "Agreement") that w
Black Family Partners Apollo Management 9 West 57th S
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
ugh it. EFTA00663454 Best regards, Ada Clapp Black Family Partners do Apollo Management 9 W 57th S
tly in effect. Items to highlight (noted with the last version): • The Overview illustrates the 1997 Trust and the 2006 Trust already decanted into the Heritage Trust. • BFP interests are discounted 30% to reflect the reality of the Note substitution. This deflates the value of Leon's estate (good for estate tax
ustee of the Marital Trust, if any)? Ada Clapp Black Family Partners IRS Circular 230 Disclosure: Pu
please confirm October funding as opposed to November (with lower rate). Also, the Trustees listed in the APO I and APO2 trusts are the same as in the Heritage Trust: that is, Barry Cohen, John Hannan and Richard Ressler. Just want to confirm that this is what Leon wants (and not Paul Weiss's assumption when dra
Entities connected to both Leon Black and the Heritage Trust

Jeffrey Epstein
PERSON
Marc Rich
PERSON
Melanie Spinella
PERSON
Alan Dershowitz
PERSON
Barry Diller
PERSON
Michael Cohen
PERSONEileen Alexanderson
PERSON
NEW YORK NY
LOCATIONBlack Family Partners
ORGANIZATIONAda Clapp
PERSONAlan S. Halperin
PERSONDebra
PERSONElysium Management LLC
ORGANIZATIONWeiss
PERSONBarry Cohen
PERSON
Bank of America
ORGANIZATIONRichard Ressler
PERSONJohn Hannan
PERSONUS Trust
ORGANIZATIONLeon D.
PERSON