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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01122188: Memorandum and Paul Weiss (DS9)

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This document is a memorandum prepared by Alan Halperin of Paul, Weiss, Rifkind, Wharton & Garrison, LLP describing a GRAT (Grantor Retained Annuity Trust) trust structure. It explains how the GRAT remainder will pass to a Discretionary Trust for the benefit of Debra and her descendants under an APO1 Agreement.

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the GRAT remainder will pass to the Discretionary Trust for the benefit of Debra and your descendants under the APO1 Agreement (described in a separate **memorandum**
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GRAT Following is a summary of the trust agreement (the "Agreement") creating the APO1 GRAT (the "GRAT"), which was prepared for you by Alan Halperin of **Paul**
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, **Weiss**, Rifkind, Wharton & Garrison, LLP.

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