EFTA Document EFTA01804406

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 particular tax =ircumstances. This communication, =nd any attachment, is for the intended recipient(s) only and may =ontain information that is privileged, confidential and/or proprietary =nbsp;lf you are not the intended recipient, you are hereby notified =hat further dissemination of this communication and its attachments is =rohibited. Please delete all copies of this communication and its =nbsp;attachments and notify me immediately that you have received them =n error. 1 EFTA_R1_00149658 EFTA01804406