DOCUMENT SUMMARY To: Leon D. Black From: Ada Clapp Date: April 12, 2013 cc: Eileen Alexanderson, Jeffrey Epstein Re: Judah 2009 Investment Trust (2009 GRAT) Following is a summary of the Judah 2009 Investment Trust Agreement dated August 13, 2009 (the "Trust Agreement") creating the Judah 2009-A Investment Trust (the "2009 GRAT"). Carlyn McCaffrey and Elyse Kirschner of McDermott Will & Emery prepared the Trust Agreement for you. You are the Senior of the 2009 GRAT. I. GRAT Term. The 2009 GRAT will terminate on the 41k anniversary of the date of the Trust Agreement (August 13, 2013). II. Dispositive Provisions A. Annuity During GRAT Term. An annuity payment will be made to you (or if you die during the GRAT Term, to your estate) each year of the GRAT Term. 1. The annuity payment for the first year is equal to such percentage' of the initial fair market value of the property contributed to the 2009 GRAT that, when increased by 20% each subsequent year, results in your right to receive the annuity payments having a value equal to 99.99% of the initial fair market value of the GRAT property. 2. The annuity payment for each subsequent year of the GRAT Term will equal 120% of the prior year's annuity payment. B. Disposition at End of GRAT Term. At the end of the GRAT Term, any property remaining in the 2009 GRAT (after payment of the final annuity payment) will be distributed as follows: I. If you are then living, such property will be distributed to the trustees of the Black Family 1997 Trust (described in a separate memorandum). 2. If you are not then living, such property will be distributed as follows: I Based on the August 2009 Section 7520 rate. EFTA01082210