EFTA01187365.pdf

From: "Kirschner, Elyse" < To: "McCaffrey, Carlyn" >, Jeffrey Epstein <jeevacation@gmail.com> 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:jeevacation@gmail.com 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. 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If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA01187367