EPSTEIN
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Paul
Paul Barrett I Managing Director I Global Investment Opportunities Group I J.P. Morgan Securities LLC 1 1.P.
Morgan Private Bank I J.P. Morgan Chase Bank N.A.
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From:
Ada Clapp
Sent:
Wednesday, August 21, 2013 10:07 PM
To:
Jeffrey Epstein
Subject:
Further to our conversation
Hi
Thinking more about our discussion earlier of =aving the Heritage Trust be under Leon's revocable trust and creating a
=eparate trust for purposes of decanting the 06 and 97 Trusts. I =ecalled having had a similar discussion with Alan after
we moved to the =urrent structure. He just reminded me that the bulk of the assets =he kids will be inheriting are the
assets in the 06 and 97 Trust. What =s left in Leon's estate after both Leon and Debra die will be cut in =alf by estate
taxes. So, if we want those "heritage trust =rovisions" to apply to the bulk of the kids' inheritance, the =rovisions have
to be in an irrevocable trust to which we can decant the =6 and 97 Trusts.
If Leon decides he no =onger can live with those provisions, we can always decant Heritage =rust #1 into a new Heritage
Trust (#2) with provisions Leon likes--but = would not want to decant too often. The other alternative (which = don't
love but like better than serial decanting) is to give the =ndependent Trustees the power to amend certain trust
provisions. =nbsp;l think Alan would be comfortable with this but again, we would =ave to create space between
amendments and they could not come from =eon (only the independent trustee).
What do =ou think?
New York NY 10019
IRS Circular 230 =isclosure:
Pursuant to IRS =egulations, I inform you that any tax advice contained in this =ommunication (including attachments) is
not intended or written to be =sed, and cannot be used by any person or entity for the purpose of (i) =voiding tax
related penalties imposed by any governmental tax =uthority, or (ii) promoting, marketing or recommending to another
party =ny transaction or matter discussed herein. I advise you to consult with =n independent tax advisor on your