CHECKLIST FOR LEON BLACK ESTATE PLANNING AND RESTRUCTURING As of October 2, 2013 ACTION TO BE TAKEN Mig RESPONSIBLE PARTY TIMING/STATUS ESTABLISH CASH FLOW PLAN I. Substitution of Trust assets by Leon in exchange for a promissory note. Team Completed on August 15, 2013 2. Value BFP interests acquired by Leon. Empire Valuation/Team Empire is working on the valuation re . , a 3. Determine whether a gift tax return will be filed reporting the substitution. Team PW is leaning against doing so. 4. Explore financing options relating to the asset substitution and existing loans secured by art. Consider: • Using multiple banks (solicit information from BAC, JPM, Morgan Stanley and Deutsche Bank). • Using assets other than art as collateral. If done, remove bank as payee on art insurance policies. Family Office Preliminary meetings with Deutsche Bank taken. 5. Determine, as a financial matter, how Leon will make note payments and repay the loan prior to his death. Consider whether Trustees should (i) distribute funds to Debra to pay income tax or make loan repayments or (ii) reimburse Leon for his tax liability. Team 6. Jib Black will be the "second" attorney reviewing the cash flow plan. Consider the timing for getting him involved. Team Once valuation is received, update books and records to reflect change of ownership of BFP. Family Office 1 of 7 EFTA01071282