From: Jeffrey Epstein <[email protected]> To: Ada Clapp Subject: Fwd: Estate Overview Date: Sat, 12 Apr 2014 11:09:17 +0000 Attachments: Black_EstatePlanningAnalysis_2013_(9.23.13).pdf the new one? when? Forwarded message From: Jeffrey Epstein <[email protected]> Date: Mon, Sep 23, 2013 at 6:30 PM Subject: Fwd: Estate Overview To: Melanie Spinella ???????? Forwarded message From: Ada Clapp <11 Date: Mon, Sep 23, 2013 at 6:07 PM Subject: Estate Overview To: Jeffrey Epstein <[email protected]>, Eileen Alexanderson Hi Jeffrey and Eileen, Attached is the revised Estate Planning Overview prepared by US Trust. As I mentioned, the prior Overview was inaccurate because their program was not updated and calculated the tax using the 35% rate in effect for 2012. The attached Overview reflects the 45% tax rate currently 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 but the children's inheritance appears smaller). As Leon monetizes AGM shares, the discounts will "disappear". Assuming no principal repayments, the note value will remain frozen at the discounted value. • The Overview assumes that Debra has transferred title to all residences to Leon. Leon's new Will and Revocable Trust are drafted as if Leon owns all residences individually. In fact, all but two parcels are owned jointly by Debra and Leon. Unless she transfer her title to Leon, the residences will pass to her outright on Leon's death rather than to the Marital Trust (and later the Heritage Trust) as Leon wants. Leon needs to be reminded of this. EFTA00987850