EFTA01116019

Proposed 2013 Will and Revocable Trust Paul Weiss draft dated July 19, 2013 Dispositive Provisions Upon Leon's death' Will Debra Survives Debra Predeceases ► Charitable Pledges Paid. ► Charitable Pledges Paid. ► To Revorahle Tnict ► To Revocable Trust, o Personal property o Personal property o Residences o Residences. o Art Entities. o Art Entities. o Collectibles. o Collectibles. o Balance of estate. o Balance of estate. Revocable Trust Debra Survives Debra Predeceases ► Outright to Debra ► Outright to Children o Personal property (excluding Art o Personal property (excluding Art Entities Entities and Collectibles2). and Collectibles) in equal shares to o Residences. surviving children. ► Cash Requests ► Cash Requests o $3 million to Melanie Spinella. o $3 million to Melanie Spinella. o Unused estate tax exemption amount to o 10 million to John Ressler. Black Family 1997 Trust. o Trustees to buy an annuity for Judy Black ► To Marital Trust to pay her annual income of $500,000 for life. o Art Entities. o Unused GST tax exemption amount to o Collectibles. Black Family 1997 GST exempt Trust o Balance of Trust Fund (less debts, ► To Heritage Trust expenses and taxes owing). o Proceeds from sale of art held in Art Marital Trust All income to Debra Entities and Collectibles not selected for a during her lifetime. Upon her death, Legacy Trust (sale is directed). remaining principal (less estate tax o Proceeds from sale of Manhattan owing) is disposed of as follows: apartments (760 Park Avenue and 750 Park Avenue). 1 Assumes the Revocable Trust is not funded during Leon's lifetime. 2 Collectibles are defined as art valued at $10,000 or more, the cane collection and first edition books. EFTA01116019 Revocable Trust (continued' Debra Survives Debra Predeceases • Each child selects items (not o Interests in Art Entities (if any after sale of exceeding $300 million in value) art). from art held in Art Entities and o Balance of Trust Fund (less debts, Collectibles for his or her Legacy expenses and taxes owing). Trust (see next column). Heritage Trust: Trustees may pay • Balance of Collectibles and art income and principal to descendants for held in Art Entities to be sold. any purpose and must pay: • $10 million to John Ressler. • $10 million to a child's Legacy Trust • Trustees to buy an annuity for when child attains age 30. Judy Black to pay her annual income of $500,000 for life. • $50 million to a child's Legacy Trust when child attains age 35. • Debra's GST exemption amount to Black Family 1997 Trust. • $100 million to a child's Legacy Trust when child attains age 40. • Balance of Marital Trust (including proceeds from sale of lb To a Child's Legacy Trust art and Collectibles) to the o Art and Collectibles not exceeding $300 Heritage Trust (see next million in value selected by the child. column). o $10 million at age 30. o $50 million at age 35. o $100 million at age 40. Legacy Trust: Trustees may pay income and principal to the child for any purpose. • Trustee is requested to give the child $10 million at age 30 to buy a residence. • Legacy Trust terminates upon the child's death and is distributed to Leon's descendants as child appoints or in default to child's descendants per stirpes subject to a Legacy Trust EFTA01116020