EFTA01187368.pdf

From: "Kirschner, Elyse" .T:1 To: "McCaffrey, Carlyn" >, Jeffrey Epstein <[email protected]> Subject: RE: Re: Date: Mon, 19 Nov 2012 15:22:41 +0000 Attachments: Benjamin_Eli_Black_2012_Trust_Agreement.DOC Jeff, Attached is a draft of a prototype for the trusts LB's 4 children will create. This one is for Benjamin. I left the trustee blank. I also gave Ben the power to remove and replace trustees of his trust, but I am not sure that this is what LB would want. LB and/or DB could have these powers instead. Carlyn hasn't had a chance to look at this yet. Elyse Elyse G. Kirschner I Partner Eme LLP 340 Madison Avenue, New York, NY 10173 I 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 McDermott Will & Emery LLP 1340 Madison Avenue, New York, NY 10173 I I www.mwe.com From: Jeffrey Epstein fmailto:jeevacatln Sent: Monday, November 19, 2012 1:02 AM To: McCaffrey, Carlyn Subject: Re: Gift trusts , will, ? On Monday, November 19, 2012, McCaffrey, Carlyn wrote: EFTA01187368 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 I www.mwe.com From: Jeffrey Epstein [mallto:[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 The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for EFTA01187369 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, distribution or use of the information contained in or attached to this message is strictly prohibited. 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 EFTA01187370