Estate of Anna Mirowski, Deceased, Ginat W. Mirowski and Ariella Rosengard, Personal Representatives - Page 6




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          not disclosed by the record, Ms. Mirowski developed hypertension.           
               On March 26, 1990, Dr. Mirowski died.  At the time of Dr.              
          Mirowski’s death, Ginat Mirowski was a student at Harvard Univer-           
          sity in Cambridge, Massachusetts, from which she eventually                 
          obtained dental and medical degrees; Ariella Rosengard was a                
          physician and a pathology resident at Johns Hopkins University              
          Hospital in Baltimore (John Hopkins Hospital), was married, and             
          had a daughter; and Doris Frydman was a medical student at Emory            
          University in Atlanta, Georgia.                                             
               Pursuant to Dr. Mirowski’s will, the ICD patents, his                  
          interest under the ICD patents license agreement, and the remain-           
          der of his assets, except for $600,000, passed to Ms. Mirowski.             
               Ms. Mirowski maintained a long and continuous history of               
          making gifts to family members and friends.  Throughout the ten-            
          year period preceding her death in 2001, Ms. Mirowski continued             
          to evaluate and make gifts to, or for the benefit of, her three             
          daughters, her grandchildren,6 and others.  Whenever Ms. Mirowski           
          made gifts to her daughters or to the respective trusts that she            
          created for them (discussed below), she always paid the related             
          gift tax.                                                                   
               On February 27, 1992, Ms. Mirowski created an irrevocable,             
          so-called spendthrift trust for each of her three daughters and             


               6At the time of Ms. Mirowski’s death, each of her daughters            
          had two children.                                                           





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