Estate of Anna Mirowski, Deceased, Ginat W. Mirowski and Ariella Rosengard, Personal Representatives - Page 7




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          their respective issue in order to provide for each daughter                
          during the daughter’s life and each daughter’s children after the           
          daughter died.  (We shall refer to the respective trusts that Ms.           
          Mirowski created for Ginat Mirowski, Ariella Rosengard, and Doris           
          Frydman and their respective issue as the Ginat Trust, the                  
          Ariella Trust, and the Doris Trust.  We shall refer collectively            
          to those trusts as the daughters’ trusts.)  Ms. Mirowski named              
          all three of her daughters as cotrustees of each of the daugh-              
          ters’ trusts.  She did so specifically because she wanted her               
          daughters to work together and have a close working relationship.           
               Under the terms of each of the daughters’ trusts, the                  
          trustees (1) had to pay income to the daughter for whom Ms.                 
          Mirowski created the trust and (2) had the discretion to pay                
          principal to that daughter for her health, maintenance, educa-              
          tion, and support.  Upon the death of a daughter, the corpus of             
          that daughter’s trust was to continue to be held in trust or to             
          be paid over to that daughter’s issue, depending on the age of              
          such issue.                                                                 
               On February 27, 1992, the same date on which Ms. Mirowski              
          created her daughters’ trusts, she funded the Ginat Trust and the           
          Ariella Trust by transferring to each of those trusts five                  
          percent of her interest under the ICD patents license agreement.            
          On the same date, Ms. Mirowski funded the Doris Trust by trans-             
          ferring to that trust ten percent of her interest under that                







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