EFTA02563790.pdf

From: McCaffrey, Carlyn < Sent: Tuesday, December 18, 2012 1:29 PM To: Jeffrey Epstein Cc: Kirschner, Elyse; Eileen Alexanderson Subject: RE: Re: If the ot=er children are beneficiaries, we would have a reciprocal trust problem =p class=MsoNormal style=imargin-left:Sin'>Carlyn S. McCaffrey I Partner McDermott Will & Emery LLP I 340 Madiso= Avenue, New York, NY 10173 I www.mwe.com <http://www.mwe.com> Jeffrey Epstein [mailto:[email protected] Sent: =uesday, December 18, 2012 8:27 AM To: McCaffrey, Carlyn Su=ject: Re: <=o:p> I thought that=each child could have the other three as benef , not debra &nbs.; , can you send another co-vel letter I cannot locate t=e first either On Tue, Dec 18, 201= at 9:22 AM, McCaffrey, Carlyn < <mailto > wrote: =p class=MsoNormal style='mso-margin-top-alt:auto;mso-margin-bottom-alt=auto5I've asked Darren to send me a copy of the letter you already=signed so I can modify it. We can't seem to find it. We are worki=g on the children's trust agreements. &=bsp; The plan so far is to have distrib=tions made to the two younger children from their individual trusts. =They will use those funds to fund their new trusts. The two older on=s will use portions of the notes that were issued to them from their indiv=dual trusts. Because those notes would not make very good investment= for long term, multi-generational trusts, we expect that the notes will b= paid off when they are held by the trustees of the new trusts. We expec= that Leon and Debra will be trustees. Leon will be an independent trustee= EFTA_R1_01727146 EFTA02563790 <=pan style=lont-size:11.0ptfont-family:"Calibri","sans-serir;color:#1F=97D5Debra will also be a beneficiary so that each trust will have a curre=t beneficiary even before it settlor has any children. The trust agr=ement will make it clear, however, that the settlor's primary intention is=that the trust will be held for the benefit of his or her future descendan=s. <=pan style=lont-size:11.0ptfont-family:"Calibri","sans-serir;color:41F=97D'>The trusts will be grantor trusts treated as owned by their settlors.=/span> Any thoughts or comments? Carlyn S. McCaffrey I Partner McDermott Will & Emery LLP I 340 Madison Avenu=, New York, NY 10173 <tel www.mwe.com <http://www.mwe.com> From: J=ffrey Epstein Imailto:[email protected] <mailto:[email protected]> Sent: Tuesday, December 18, 20=2 8:14 AM To: Darren Indyke; McCaffrey, Carlyn Subject: status of co vel= letter, leons children signing etc. confidential, may be=attorney-client privileged, may constitute inside information, and is i=tended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communic=tion or any part thereof is strictly prohibited and may be unlawful. If=you have received this communication in error, please notify us immedia=ely by return e-mail or by e-mail to [email protected] <mailto:jeevacation@gmai=.com> , and destroy this com=unication and all copies thereof, including all attachments. copyright =all rights reserved IRS Circular 230 Disclosure: To comply with requiremen=s imposed by the IRS, we inform you that any U.S. federal tax advice conta=ned herein (including any attachments), unless specifically stated otherwi=e, is not intended or written to 2 EFTA_R1_01727147 EFTA02563791 be used, and cannot be used, for the purp=ses of (i) avoiding penalties under the Internal Revenue Code or (ii) prom=ting, marketing or recommending to another party any transaction or matter=herein. This message is a PRIVILEGED AND CONFIDENTIAL comm=nication. This message and all attachments are a private communication sen= by a law firm and may be confidential or protected by privilege. If you a=e not the intended recipient, you are hereby notified that any disclosure,=copying, distribution or use of the information contained in or attached t= this message is strictly prohibited. Please notify the sender of the deli=ery error by replying to this message, and then delete it from your system= Thank you. Please visi= http://www.mwe.com/=for more information about our Firm. =br> The info=mation contained in this communication is confidential, may be attorney=client privileged, may constitute inside information, and is intended o=Iy for the use of the addressee. It is the property of Jeffrey Epste=n Unauthorized use, disclosure or copying of this communication or =ny part thereof is strictly prohibited and may be unlawful. If you have=received this communication in error, please notify us immediately byreturn e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communicatio= and all copies thereof, including all attachments. copyright -all righ=s reserved 3 EFTA_R1_01727148 EFTA02563792