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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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Last modified: March 27, 2008