mpt payment of assets to Legacy Trusts for the children. Instead, the Legacy Trusts should be funded with non-exempt assets. 5 We understand that 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

emption Amount (as defined in Clause THIRTEENTH) or otherwise, such portion of the Exemption Amount instead shall be distributed to the Trustees of the Black Family 1997 GST Exempt Trust (as defined in Clause THIRTEENTH), to be added to and disposed of as a part of the principal thereof. (B) In allocating cash or other property to

rtners to Black Family 1997 Trust as loan Promissory note issued $54mil transferred from Black Family 1997 Trust to PLB LLC $3mil Transferred from the Black Family 1997 GST Exempt Trust to PLB LLC $10mil transferred from JPMorgan Acct 220-42260 of LDB 2011 LLC to PLB LLC E FTA_R 1_02050349 EFTA02696499