Proposed 2013 Will and Revocable Trust

Proposed 2013 Will and Revocable Trust Dispositive Provisions Upon Leon's death' Debra Survives Debra Predeceases ► Outright to Debra ► Outright to Children o Personal property (excluding Art Entities and Collectibles2). o Residences. ► Charitable Pledges Paid. o Personal property (excluding Art Entities and Collectibles) in equal shares to surviving children. ► Charitable Pledges Paid. ► To Revocable Tnict ► To Revocable Trust, o Art Entities. o Proceeds from sale of residences. o Collectibles. o Art Entities. o Balance of estate. o o Collectibles. Balance of estate. Revocable Trust Debra Survives ► Cash Bequests o $3 million to Melanie Spinella. o Unused estate tax exemption amount to Black Family 1997 Trust. ► To Marital Trust o Art Entities. o Collectibles. o Balance of Trust Fund (less debts, expenses and taxes owing). Marital Trust All income to Debra during her lifetime. Upon her death, remaining principal (less estate tax owing) is disposed of as follows: • Each child selects $X of art held in Art Entities and Collectibles for his or her Legacy Trust (see next column). Debra Predeceases ► Cash Bequests o $3 million to Melanie Spinella. o 10 million to John Ressler. o $25 million in trust for Judy Black On Judy's death, $1 million to her husband and balance to Heritage Trust. o Unused GST tax exemption amount to Black Family 1997 GST exempt Trust. ► Art and Collectibles not selected for a Legacy Trust to be sold. ► To Heritage Trust o Sale proceeds for art and Collectibles not selected for a Legacy Trust. o Interests in Art Entities (if any after sale of art). o Balance of Trust Fund (less debts, expenses and taxes owing). 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. EFTA01092079 Revocable Trust (continued) Debra Survives Debra Predeceases • • • • • Balance of Collectibles and art held in Art Entities to be sold. $10 million to John Ressler. $25 million in trust for Judy Black. On Judy's death, $1 million to her husband and balance to Heritage Trust Debra's GST exemption amount to Black Family 1997 Trust. Balance of Marital Trust (including sale proceeds of art and Collectibles) to the Heritage Trust (see next column). ► fleritage Trust: Trustees may pay income and principal to descendants for any purpose and must pay: • $10 million to a child's Legacy Trust when child attains age 30. • $50 million to a child's Legacy Trust when child attains age 35. • $100 million to a child's Legacy Trust when child attains age 40. To a Child's Legacy Tritst o $X of art and Collectibles selected by the child for his or her Legacy Trust 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 EFTA01092080