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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
governance role they will take on after Leon's death. In addition, if the Heritage Trust is funded now Q.e., with assets from the existing trusts), the Legacy Trusts for the children could be funded It would not be appropriate for the assets of the 1992 and 1999 Insurance Trusts or the Black 2011 Family Trusts t
Ous0/40 10 Sulk* County Cantreolo Hod In New York County Cornrnsmon ewer. June 4. 2014 EFTA00601882 SCHEDULE A $10.00 LEON D. BLACK, Grantor LEON D. D. BLACK, Trustee Dated: • ST2013 DxN USI 8469098v1601S84600003 EFTA00601883
NT made this IS day of , 2013, between LEON D. BLACK of the State of New York (hereinafter called the
partments to any one or more of the Grantor's children, the Trustees of the Heritage Trust (as defined in Clause THIRTEENTH) and/or the Trustees of the Legacy Trusts, provided such sale is for Fair Market Value. (c) The Trustees shall pay any such expenses that they deem reasonable in connection with selling th
n walk him through it. Best regards, Ada Clapp Black Family Partners do Apollo Management EFTA_R1_02
million of art from his estate and $100 million from the Heritage Trust to be held in each child's Legacy Trust. Leon's selection of what passes to the Legacy Trusts will dramatically influence the estate tax calculation. The greater the amount of includible art that passes to the Legacy Trusts on Debra's death,
Entities connected to both Leon Black and the Legacy Trusts

Jeffrey Epstein
PERSON
Barry Diller
PERSON
Michael Cohen
PERSONEileen Alexanderson
PERSONBlack Family Partners
ORGANIZATIONAda Clapp
PERSONDebra
PERSONUS Trust
ORGANIZATIONthe Heritage Trust
ORGANIZATIONRevocable Trust
ORGANIZATIONthe Marital Trust
ORGANIZATIONLegacy Trust
ORGANIZATIONthe Black Family 1997 GST Exempt Trust
ORGANIZATIONOverview
ORGANIZATIONLegacy Trust Agreement
ORGANIZATIONthe Estate Overview
ORGANIZATIONDebra's Marital Trust
ORGANIZATION