Case File
efta-efta01187365DOJ Data Set 9OtherFrom: "Kirschner, Elyse" <
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DOJ Data Set 9
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efta-efta01187365
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From: "Kirschner, Elyse" <
To: "McCaffrey, Carlyn"
>, Jeffrey Epstein <[email protected]>
Subject: RE: Re:
Date: Mon, 19 Nov 2012 14:11:32 +0000
Attachments:
New).DO
(NEW).DOC;
DOC
Attached is the memo regarding the proposed changes to LB's Will.
At the same time (in August), we prepared an amendment and restatement of each of LB's 1997 Family Trust Agreement
and 2006 Family Trust Agreement. Attached are copies of the memoranda summarizing the provisions of these
agreements.
Elyse G. Kirschner I Partner
McDermott Will & Emery LLP 1340 Madison Avenue, New York, NY 10173
www.mwe.com
From: McCaffrey, Carlyn
Sent: Monday, November 19, 2012 8:03 AM
To: Jeffrey Epstein
Cc: Kirschner, Elyse
Subject: RE: Re:
Dear Jeff,
We've revised the trust agreement that will create the trust to hold Debra's 2012 gift. By copy of this email, I'm asking
Elyse to send you a copy of the draft and the explanatory memo if she hasn't already done so. Elyse has also prepared a
prototype for the trusts that the 4 children will create. She send you a draft yesterday.
As to the will, by copy of this email, I'm asking Elyse to send you a copy of the most recent memo she has prepared
describing proposed changes to LB's will.
Best,
Carlyn
Carlyn S. McCaffrey I Partner
cDermott Will & Emer LLP J 340 Madison Avenue, New York, NY 10173
www.mwe.com
From: Jeffrey Epstein [mailto:jeevacSgmail.com
Sent: Monday, November 19, 2012 1:02 AM
To: McCaffrey, Carlyn
Subject: Re:
EFTA01187365
Gift trusts , will, ?
On Monday, November 19, 2012, McCaffrey, Carlyn wrote:
Dear Jeff,
Here's an outline of the plan you and I have been discussing. It's still in the preliminary stage and needs some
additional analysis including a section 2701 analysis
Step 1— You think it would be preferable to arrange for a set of trustees who have no relationship to LB.
Step 2- Reorganize BFP into two classes of partnership interests, Class A and Class B. The holders of Class A
would have the right to receive all BFP profits that are attributable to operating income from the original relevant
companies for a period of time to end at the death of LB.. The holders of Class B would have the right to all
other profits and to the existing capital accounts of BFP.
Step 3 — LB agrees to repay the 2006 Family Trust an amount equal to excess distributions he has received from
2006 Family Trust
Step 4 — The 2006 Family Trust decants its Class B interests in BFP and all other assets other than its Class A
BFP interests to a new 2012 Family Trust.
Step 5 - The 2006 Family Trust is amended to give LB the right to assign his interest in the trust.
Step 6 — LB assigns his interest in the 2006 Family Trust to a GRAT.
Best,
Carlyn
Carlyn S. McCaffrey I Partner
McDermott Will & Emery LLP I 340 Madison Avenue. New York, NY 10173
From: Jeffrey Epstein [mailto:[email protected]
Sent: Sunday, November 18, 2012 1:17 PM
To: McCaffrey, Carlyn
Subject:
it would be very helpful for you to write a here are the following steps memp/ trustees, chanve, set up new part
„ amend trust, decant trust, . repair faulty valutations document. . gift tax trusts debra and kids, new will.
etc. thanks, I would like it for tomorw nights meeting with halperin.. as you can see i don't type often
EFTA01187366
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to [email protected], and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
*******************************************************************************************************************
IRS Circular 230 Disclosure: To comply with requirements imposed by the IRS, we inform you that any
U.S. federal tax advice contained herein (including any attachments), unless specifically stated
otherwise, is not intended or written to be used, and cannot be used, for the purposes of (i) avoiding
penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another
party any transaction or matter herein.
This message is a PRIVILEGED AND CONFIDENTIAL communication. This message and all
attachments are a private communication sent by a law firm and may be confidential or protected by
privilege. If you are not the intended recipient, you are hereby notified that any disclosure, copying,
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Please notify the sender of the delivery error by replying to this message, and then delete it from your
system. Thank you.
*******************************************************************************************************************
Please visit http://www.mwe.com/ for more information about our Firm.
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to [email protected], and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
EFTA01187367
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