Proposed 2013 Will and Revocable Trust Paul Weiss draft dated July 19, 2013 Dispositive Provisions Upon Leon's death' Will Debra Survives Debra Predeceases ► Charitable Pledges Paid. ► Charitable Pledges Paid. ► To Revorahle Tnict ► To Revocable Trust, o Personal property o Personal property o Residences o Residences. o Art Entities. o Art Entities. o Collectibles. o Collectibles. o Balance of estate. o Balance of estate. Revocable Trust Debra Survives ► Outright to Debra o Personal property (excluding Art Entities and Collectibles2). o Residences. ► Cash Requests o $3 million to Melanie Spinella. o Unused estate tax exemption amount to Black Family 1997 Trust. ► To Marital Trust o Art Entities. o Collectibles. o Balance of Trust Fund (less debts, expenses and taxes owing). Marital Trust All income to Debra during her lifetime. Upon her death, remaining principal (less estate tax owing) is disposed of as follows: Debra Predeceases ► Outright to Children o Personal property (excluding Art Entities and Collectibles) in equal shares to surviving children. ► Cash Requests o $3 million to Melanie Spinella. o 10 million to John Ressler. o Trustees to buy an annuity for Judy Black to pay her annual income of $500,000 for life. o Unused GST tax exemption amount to Black Family 1997 GST exempt Trust ► To Heritage Trust o Proceeds from sale of art held in Art Entities and Collectibles not selected for a Legacy Trust (sale is directed). o Proceeds from sale of Manhattan apartments (760 Park Avenue and 750 Park Avenue). 1 Assumes the Revocable Trust is not funded during Leon's lifetime. 2 Collectibles are defined as art valued at $10,000 or more, the cane collection and first edition books. EFTA01116019 Revocable Trust (continued' Debra Survives Debra Predeceases • Each child selects items (not exceeding $300 million in value) from art held in Art Entities and Collectibles for his or her Legacy Trust (see next column). o Interests in Art Entities (if any after sale of art). o Balance of Trust Fund (less debts, expenses and taxes owing). • Balance of Collectibles and art held in Art Entities to be sold. Heritage Trust: Trustees may pay income and principal to descendants for any purpose and must pay: • $10 million to John Ressler. • Trustees to buy an annuity for Judy Black to pay her annual income of $500,000 for life. • $10 million to a child's Legacy Trust when child attains age 30. • $50 million to a child's Legacy Trust • Debra's GST exemption amount to Black Family 1997 Trust. when child attains age 35. • $100 million to a child's Legacy • Balance of Marital Trust Trust when child attains age 40. (including proceeds from sale of art and Collectibles) to the Heritage Trust (see next column). lb To a Child's Legacy Trust o Art and Collectibles not exceeding $300 million in value selected by the child. o $10 million at age 30. o $50 million at age 35. o $100 million at age 40. Legacy Trust: Trustees may pay income and principal to the child for any purpose. • Trustee is requested to give the child $10 million at age 30 to buy a residence. • Legacy Trust terminates upon the child's death and is distributed to Leon's descendants as child appoints or in default to child's descendants per stirpes subject to a Legacy Trust EFTA01116020