EFTA00586670.txt

"You are the Grantor of the GRAT. ... You are the sole Trustee."

"Alan Halperin of Paul, Weiss, Rifkind, Wharton & Garrison, LLP"

"provided that she is your surviving spouse"

"the GRAT remainder will pass to the Discretionary Trust for the benefit of Debra"

"you intend to fund the GRAT in October with your entire 80% limited partner interest in Black Family Partners, L.P. ... roughly, $2 billion"

"the trust agreement (the "Agreement") creating the APOI GRAT (the "GRAT"), which was prepared for you by Alan Halperin"