To: Jeffrey EpsteinDeeva i n mil. m Cc: Eileen Alexanderson From: Ada Clapp Sent Wed 4/30/2014 4:13:10 PM Subject: Estate Planning Overview Hi Jeffrey, The initial draft of the overview values all of Leon and Debra's assets other than the GRATs as of April 16, 2014 but models the GRATs differently. The GRATs are shown as if Leon survived each of the terms, received back all his annuity payments and paid a remainder to the Heritage Trust based on income and appreciation projections Eileen provided. This is a "quick and dirty" way of showing how the assets would pass if the GRATs are successful. It is not "technically accurate" from an estate tax standpoint. I discussed the approach with Alan and asked whether he thought this was a "meaningful" yet practical approach to take. Alan noted that it depended entirely on what you were using the Overview for—broad view of the flow of assets and liabilities on the death of Leon and Debra or an accurate picture of estate tax for liquidity planning purposes. He and I agreed that for the Overview to be a "more accurate" picture of Leon's estate tax, we will need to do a much more complex analysis that would require engaging Paul Weiss's fiduciary account (Carlos has apparently assisted another family office in a similar situation in this regard). Carlos would look at each GRAT on April 16, 2014 to determine whether the GRAT would be deemed to have failed (based on the April 7520 rate) and determine what portion of the GRAT corpus (likely all) would be included Leon's estate. Carlos would also do a more accurate projection of the GRAT remainders based on variables we give him, such as (i) the date and amount of each dividend payment, (ii) what portion of each payment was made with BFP stock, (iii) application of a discount to the amount of BFP stock used to pay the dividend—which would require projected values of the stock, and (iv) value of the TRA applicable to each GRAT after each annuity paymen