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reached, would be of assistance to them in deciding which of
their respective assets they wanted each of their children to
become actively involved in managing.
The parties in the litigation among the children engaged in
extensive discussions to settle that litigation and to resolve
the children’s concerns regarding Mr. Stone’s and Ms. Stone’s
assets so as to avoid any future litigation as to such concerns.
Those parties intended and agreed that any agreements that they
were able to reach were to be comprehensive and to cover every
possible issue that might arise among them as to those matters.
On June 3, 1994, the parties in the litigation among the children
and their respective attorneys executed a plan (1994 plan for
settlement) to settle that litigation and to resolve the various
issues relating to the children’s concerns regarding Mr. Stone’s
and Ms. Stone’s assets. Ms. Stone and Mr. Stone were not parties
to the 1994 plan for settlement, and neither of them signed that
document.
With respect to the issues relating to the trusts, the 1994
plan for settlement provided in part as follows:
I. TRUSTS
The existing trusts will remain as two
(2) trusts administered by three (3) inde-
pendent, qualified Trustees.
A. THREE TRUSTEES TO ADMINISTER EXISTING TRUSTS
There will be three independent, quali-
fied Trustees (“Trustees”) who shall adminis-
ter the two existing trusts (“Existing
Trusts”) in accordance with the terms of the
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