Trump MTD

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK: COMMERCIAL DIVISION

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MARY L. TRUMP, Index # 654698/2020
Plaintiff,
NOTICE OF MOTION TO
DISMISS PURSUANT TO
CPLR§ 3211(a)(5) & (7)
-against-
DONALD J. TRUMP, in his personal capacity,

MARYANNE TRUMP BARRY, and SHAWN
HUGHES, the executor of the ESTATE OF
ROBERT S. TRUMP, in his capacity as executor,
Defendants
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S I R S:
Please take notice that upon the annexed affirmation of James D. Kiley, Esq. affirmed the
day of December, 2020, the Memorandum of Law dated December the day of
December 2020 and the supporting papers and exhibits herein, Defendants, DONALD J.
TRUMP and SHAWN HUGHES, as Executor of the ESTATE OF ROBERT S. TRUMP, will
move this Court at the Commercial Term to be held in and for the County of New York at the
courthouse located at 60 Centre Street, New York, New York 10007 on the day of ,
2020 at 9:30 o'clock in the forenoon of that day or as soon thereafter as counsel can be heard for
an Order pursuant to C.P.L.R. 3211(a)(5) & (7) dismissing the Complaint since: (a) the action is
untimely under the statute of limitations; and (b) Plaintiff previously executed General Releases
releasing Defendants from the claims now asserted; and (c) Dismissing Counts 5 and 6 of the
Complaint as Plaintiff fails to state a cause of action with regard to her conspiracy claims and for
such other and further relief as to this Court may be just and proper.
PLEASE TAKE FURTHER NOTICE, that you are required to serve answering affidavits
seven (7) days before the return date hereof.

PLEASE TAKE FURTHER NOTICE, that pursuant to a previous Stipulation and
Proposed Order you are required to serve answering affidavits and opposition papers by
February 26, 2021.
Dated: Great Neck, New York

December 22, 2020
YOUR C.
étine D. Kiley, Esq.

KIL Y, KILEY & KILEY, PLLC
Att rneys for Defendants
'
DO ALD J. TRUMP and SHAWN
H GHES, as Executor of the ESTATE OF
BERT S. TRUMP
3000 Marcus Avenue, Suite 3W07
Lake Success, New York 11042
(516) 466-7900
(516) 466-7903 Fax

JDKiley@KileyLawFirm.com
TO: KAPLAN HECKER & FINK LLP

350 Fifth Avenue, Suite 7110
New York, NY 10118
(212) 763-0883
(212) 564-0883 Fax

rkaplan kaplanhecker.com
iquinn@kaplanhecker.com
arodneyakaplanhecker.com
GREENFIELD, STEIN & SENIOR LLP

600 Third Avenue
New York, NY 10118
(212) 818-9336
212-818-1264 Fax
afriedman@ass-law.com
isbeetz ass-law.com
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Plaintiff,
AFFIRMATION
IN SUPPORT
-against- OF DEFENDANTS’
MOTION TO DISMISS
PURSUANT TO 3211(a)(5) & (7)
Defendants
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James D. Kiley, Esq., an attorney duly admitted to practice law in the Courts of the
State of New York, hereby affirms and states:
(1) I am a partner in the law firm of Kiley, Kiley & Kiley, PLLC, attorneys for the
Defendants, Donald J. Trump and Shawn Hughes, the executor of the Estate of Robert S. Trump,
and I am fully familiar with the facts and circumstances of this action. That my knowledge comes
from a review of the files from Plaintiff’s previous litigation with Defendants dating back to 2001
and of the corporate records of the various entities named in Plaintiff’s Complaint.
(2) I make this Affirmation in support of said Defendants’ motion to dismiss all actions
stated in the Complaint in their entirety pursuant to CPLR § 3211(a)(5) & (7).
(3) The plaintiff, Mary L. Trump, brought the instant action against her uncle, Donald
J. Trump, her aunt, the Honorable Maryanne Trump Barry and the estate of her uncle, Robert S.
Trump by filing a Summons and Complaint on or about September 24, 2020 alleging eight separate
causes of action for fraud, civil conspiracy and breach of fiduciary duty. (Exhibit “A”)
(4) Plaintiff’s Complaint should be dismissed in its entirety pursuant to CPLR
3211(a)(5) as: (a) Plaintiff’s claims are time barred under the statute of limitations; and (b) Plaintiff
previously litigated the same claims and settled them with Defendants in 2001, executing General
Releases which released Defendants from the claims she now asserts.
(5) To the extent that Plaintiff is attempting to assert claims for breach of fiduciary
duty and fraud, fraudulent concealment and negligent misrepresentation prior to the sale of her
Trump interests, Defendants seek dismissal pursuant to CPLR 3211(a) (7) on the ground that
Plaintiff lacks standing and she has failed to state a cause of action for each of her claims of fraud
and negligent misrepresentation.
(6) Plaintiff’s claims of civil conspiracy to commit fraudulent misrepresentation and
concealment and civil conspiracy to commit fraudulent inducement should be dismissed because
there is no cause of action for “civil conspiracy” independent of any underlying fraud allegations.
Your affirmant respectfully refers this honorable Court to the legal arguments made in the
Memorandum of Law filed herewith.
The Parties and their Shared Business Interests
(7) Plaintiff is the daughter of Fred C. Trump, Jr. (“Fred, Jr”), the brother of
Defendants, who died in 1981. Plaintiff is the granddaughter of Fred C. Trump, (“Fred”) a real
estate developer who built and acquired dozens of apartment buildings and other commercial
properties in Brooklyn, Queens and Staten Island predominantly from the 1940’s to the 1960’s.
Fred generally formed separate entities for each building or development project but he owned and
managed the entire portfolio of properties as a single enterprise (hereinafter the “Company”) from
his central office in Brooklyn, New York. In 1969 he formed a management entity called Trump
Management, Inc., which managed the portfolio. Fred was the sole owner of Trump Management,
Inc. At no time did Fred’s children have an ownership interest in this entity. (Exhibit “B”)
(8) In the 1960’s, Fred’s five children formed partnerships and other business entities
and acquired interests in several properties. These included Midland Associates, Park Briar
Associates, Highlander Hall, Inc. and Coronet Hall, Inc. In 1969, Plaintiff’s father, Fred Jr’s,
twenty percent (20%) share in these entities was placed in Trust (the “1969 Trust”) and the family
attorney, Matthew J. Tosti, Esq., was named as Trustee and served as Trustee of said Trust until
his death in 1977, at which time, his law partner, Irwin Duren, Esq replaced him as Trustee.
(9) After her father’s death, Plaintiff (along with her brother Fred C. Trump III who is
notably not a plaintiff in this lawsuit) inherited Fred Jr.’s share of the business entities owned with
her aunts and uncles. Her interests remained in the 1969 Trust with Irwin Durben, Esq. as Trustee
until 1995, at which time they were transferred out of the Trust and into her name individually.
These entities had owned buildings that were converted to Cooperative ownership in the 1980’s
and after the conversions the entities retained ownership in the shares of any unsold apartments.
At the time of Plaintiff’s original litigation against Defendants in 2000, these entities included: 1)
Midland Associates, LLC which owned the shares of 54 apartments in Sunnyside Towers; 2)
Coronet Hall, Inc., which owned the shares of 62 apartments in Coronet Hall and the shares of 40
apartments in Wedgewood Hall; 3) Highlander Hall, Inc. which owned the shares of 54 apartments
in Highlander Hall and 4) Park Briar Associates, LLC which owned the shares of 59 apartments
in Park Briar and 28 apartments in Saxony Hall. In addition, Coronet Hall, Inc., Highlander Hall,
Inc. and Park Briar Associates, LLC owned the shares to 57 apartments in a building known as
1
Lincoln Shore. In addition to these sponsor owned apartments, the entities owned wrap
mortgages on the converted Co-op buildings and sponsor financed loans from individual apartment
sales. The entities also owned a ground lease to a McDonald’s restaurant and an approximate
1.5% interest in Starrett City, a housing development in East New York. In the Trump family
these legal entities have been collectively referred to as “Midland Associates Group” and their
ownership interests as the ‘Midland Interests”.
(10) The Plaintiff mistakenly claims that all of her land interests were inherited through
her great grandmother’s will (Complaint ¶ 45). In fact, Plaintiff inherited from her father a ten
percent (10 %) interest in ground leases on properties that had been developed by her grandfather
called the Beach Haven Apartments Numbers # 1, 2, 3, 4, 5 & 6, which her grandfather had placed
in Trust for his five children in 1949. Plaintiff also inherited from her father a two and one-half
percent (2.5 %) interest in a ground lease for a property called Shore Haven Apartments No.1, Inc.
and a five percent (5%) interest in a ground lease for Shore Haven Apartments No.2, Inc. which
had been placed in Trust by her great grandmother, Elizabeth J. Trump in 1949 for her five
grandchildren. As Plaintiff was only sixteen years at the time of her father’s death in 1981, her
inherited interests continued to be held in Trust with Chase Manhattan Bank serving as Trustee
until 1988 at which time they were deeded to Irwin Durben, Esq. as Trustee under a Trust
established for Plaintiff in 1983 (the “1983 Trust”). These interests were held in Trust until 1995
when they were deeded outright to Plaintiff. (Exhibit “C”) Upon her grandfather’s death in 1999,
Plaintiff inherited a further two and one-half percent (2.5 %) interest in the ground lease for Shore
Haven Apartments No.1, Inc. (bringing her total interest to 5%) and a further five (5%) interest in
1
Midland Associates and Park Briar Associates were converted to LLCs in 1995.
the ground lease for Shore Haven Apartments No.3, Inc. through a testamentary trust that had been
established under the will of her great grandmother in 1967 and managed by Chase Manhattan
Bank as Trustee. Chase provided an accounting for the period 1968-2000 to Plaintiff who executed
a Receipt and Release in 2000 when she assumed title these land interests personally. (Exhibit
“D”) These land leases were for an initial term of 99 years but they gave the building owners an
automatic right of renewal for an additional 99 years for a total lease term of 198 years. (Exhibit
“E”) 2
(11) In 1976, prior to her father’s death, Plaintiff’s grandfather established a Trust for
her with a gift of $400,000.00, which Trust was managed by Defendants and Matthew Tosti, Esq.
and subsequently Irwin Durben, Esq. (the “1976 Trust”). A similar Trust had been established
for Plaintiff’s father in 1976 with a gift to him of $200,000.00. When Plaintiff’s father died in
1981, she inherited half the proceeds of his 1976 Trust and half the death benefit on his life
insurance policy. These assets continued in the 1976 Trust until it was terminated when Plaintiff
settled with Defendants in 2001.
Background of Prior Litigation
(12) After Fred’s death on June 25, 1999, a probate petition was filed in the Queens
County Surrogate’s Court by Defendants Donald J. Trump, Maryanne Trump Barry and the
decedent Defendant Robert S. Trump, who were the executors named in their father’s Will dated
September 18, 1991. Under his 1991 Will and Codicils dated September 18, 1991 and November
18, 1991, Fred made certain bequests to his four surviving children in equal shares. He did not
2
See Lease dated May 1, 1950, Article XX, Section 3 and Mortgage on Lease dated July 17, 1950 Page 1
bequeath an equal share to the children of his predeceased son, Fred, Jr. (Exhibit “F”) On October
21, 1999, Plaintiff appeared in the Queens County Surrogate’s Court through her retained counsel,
the law firm, Farrell Fritz, and entered into a Stipulation to conduct § 1404 examinations of the
attorney draftsman, witnesses to the Will as well as the nominated executors. Plaintiff served a
Notice for Discovery & Inspection on October 25, 1999 making sixty-one separate demands for
all previous wills and codicils, state and federal income tax returns, gift tax returns, personal
correspondence, calendars, deeds, mortgages, life insurance policies, banking records, financial
records, medical records and more. (Exhibit “G”) Defendants replied with a Partial Response to
First Notice of Discovery & Inspection on November 21, 1999, which exchanged documents and
also set a date of December 8, 1999 for Plaintiff to inspect and make copies all relevant records at
the Trump corporate offices in Brooklyn. (Exhibit “H”) Among the voluminous records
exchanged included yearly financial statements for the 1976 Trust dating back to 1990. (Exhibit
“I”)3 the management agreement between Apartment Management Associates, Inc and Fred C.
Trump. (Exhibit “J”) and a detailed report on the sale of almost forty sponsor and non-sponsor
owned apartments in 1999 and 2000. (See Exhibit “K”)
(13) As a witness to the execution of Fred C. Trump’s Will, attorney Vincent J. Tosti
testified at a § 1404 hearing on January 5, 2000. (Exhibit “L”) In addition to the facts and
circumstances surrounding the execution of the Will, Mr. Tosti, as an attorney of the Defendants
familiar with their businesses, was asked questions with regard to Midland Associates and was
specifically questioned about Promissory Notes given by Midland Associates to Fred C. Trump on
August 25, 1992 and October 25, 1992. (Exhibit “M”) The decedent Defendant Robert S. Trump
3
The corpus of 1976 Trust consisted of cash, bonds and mortgage receivables
testified at a §1404 hearing on February 24, 2000. (Exhibit “N”) Defendants’ cousin, John W.
Walter testified at a §1404 hearing on March 7, 2000. (Exhibit “O”)
(14) In April 2000, Plaintiff commenced a second lawsuit in Nassau County Supreme
Court, suing Defendants and seeking to provide health insurance coverage to herself, her nephew
William and other family members through the Company health plan, despite the fact that no one
in her immediate family was an employee of the Company. This action would run parallel to the
Surrogate’s Court proceeding throughout 2000 and into 2001. (Exhibit “P”)
(15) On or about March 22, 2000, Plaintiff and her brother filed Objections to the
Probate of Fred C. Trump’s Will (Exhibit “Q”) wherein they alleged, inter alia, that he did not
have testamentary capacity to make the Will and that the Will was procured by the fraud and undue
influence of Defendants.
(16) On August 7, 2000, Fred C. Trump’s wife, Mary A. Trump died.
(17) By letter dated October 2, 2000, Defendants counsel provided Plaintiff’s counsel
detailed records regarding the Midland Interests, including detailed reports on the co-op
apartments still owned and detailed records of the sales of approximately forty apartments that had
closed in 1999 and 2000 to that point. A second letter to Plaintiff’s counsel dated November 1,
2000 contained further records regarding the Midland Interests. (Exhibit “R”) Plaintiff and
defendants entered into a further Stipulation in Surrogate’s Court on January 8, 2001 which
scheduled plaintiff for a deposition on February 21, 2001. (Exhibit “S”) Plaintiff served a Verified
Bill of Particulars on January 12, 2001 wherein she amplified her claims of fraud against the
defendants. (Exhibit “T”)

(18) Defendants provided copies of appraisals for the Estate assets as well as GRATS
that had been created four years previously by Fred C. Trump and his wife for the benefit of
Defendants. These included appraisals from Grubb & Ellis, one of the nation’s leading
commercial real estate service firms, (Exhibit “U”) and Management Planning Inc., (“MPI”)
(Exhibit “V”).
(19) In the latter part of 2000, the parties engaged in significant settlement discussions
that would ultimately not only settle the claims made against the estate of Fred C. Trump but would
(1) also allow for the probate of his wife Mary A. Trump’s estate without objections; (2) provide
the terms for the liquidation of all of Plaintiff’s interests in all family partnerships and businesses;
and (3) provide for the distribution and termination of all existing trusts for Plaintiff’s benefit.
Toward those ends, detailed correspondence was exchanged between the parties’ attorneys from
November 2000 through February 21, 2001 as they inched their way toward a global settlement.
(Exhibit “W”)
(20) On April 9, 2001, Plaintiff executed General Releases specifically releasing
Defendants Donald J. Trump, Maryanne Trump Barry and Robert S. Trump individually and as
co-executors of the Estates of Fred C. Trump and Mary A. Trump. (Exhibit “X”) That same day
Defendants resigned as Trustees of Plaintiff’s 1976 Trust and Plaintiff executed a Receipt and
Release. (Exhibit “Y”) On April 10, 2001, Plaintiff and Defendants entered into a confidential,
comprehensive Agreement and Stipulation which: (i) settled the pending cases in the Queens
Surrogate’s Court and Nassau County Supreme Court; (ii) allowed for the probate of Mary A.
Trump’s estate without objection through the execution of waivers and consents; (iii) liquidated
and extinguished Plaintiff’s equitable interests in all family owned businesses and assets; and (iv)
terminated Plaintiffs 1976 Trust. The Agreement itemized the specific value and consideration
given for each. (Exhibit "Z") Checks were issued and delivered to Plaintiff for the consideration
stated in the Agreement and Stipulation. (Exhibit "AA'').
(21) On April 9, 2001, Plaintiff relinquished her land interests and deeded them to
Midland Associates, LLC. (Exhibit "BB") On April 10, 200 I she assigned her ten percent (I 0%)
membership interests in Midland Associates, LLC and Park Briar Associates, LLC back to both
LLCs and signed stock powers to transfer her shares back to Highlander Hall, Inc. and Coronet
Hall, Inc. (Exhibit "CC")
(21) For the reasons argued by your affirmant in the Memorandum of Law filed
herewith, Plaintiffs Complaint should be dismissed in its entirety.
WHEREFORE, your affirmant respectfully requests that the motion herein be
granted in all respects and that the Court issue an order pursuant to CPLR § 321l(a) (5) & (7)
dismissing Plaintiffs Complaint in its entirety and for such other and fmther relief as to this Comt
may be just and proper.
Affirmed: December 22,2010

Lake Success, NY
H GHES, as Executor of THE ESTATE

0 ROBERTS. TRUMP
3 0 Marcus Avenue, Suite 3W07
Lake Success, New York II 042
( 516) 466-7900
jdkilevrd·kilc\lawtirm.com
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Plaintiff,
Hon O. Peter Sherwood
-against-

Defendants
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MEMORANDUM OF LAW
IN SUPPORT OF DEFENDANTS DONALD J. TRUMP AND SHAWN HUGHES, as
Executor of the ESTATE OF ROBERT S. TRUMP'S MOTION TO DISMISS
PURSUANT TO CPLR §3211(a) (5) & (7)
KILEY, KILEY & KILEY, PLLC
Attorney for Defendants

DONALD J. TRUMP and SHAWN
HUIGHES, as Executor of THE ESTATE
OF ROBERT S. TRUMP
300 Marcus Avenue, Suite 3W07
(516) 466-7900
Counsel:
James D. Kiley, Esq.
TABLE OF CONTENTS
Page No.
TABLE OF AUTHORITIES ………………………………………………………………… ii
PRELIMINARY STATEMENT……………………………………………………………… 2
FACTS MADE KNOWN TO PLAINTIFF IN THE PRIOR LITIGATION….…………... 6
ARGUMENT……………………………………………………………………………………12
I. POINT I: PLAINTIFF’S CLAIMS ARE BARRED BY THE STATUTE OF

LIMITATIONS…………….............................................................................................12
A. Plaintiff’s Fraud Claims are Untimely………………………………………12
B. Plaintiff’s Claims for Breach of Fiduciary Duty and Aiding and

Abetting Breach of Fiduciary Duty Are Time-Barred………………………17
II. POINT II: PLAINTIFF’S CLAIMS ARE BARRED BY THE GENERAL

RELEASE SHE EXECUTED IN CONNECTON WITH THE SETTLEMENT
AGREEMEMENT………………………………………………………………………18
III. POINT III: PLAINTIFF LACKS STANDING TO ASSERT ANY

CLAIM TO RECOVER FOR DEFENDANTS’ ALLEGED BREACH OF
FIDUCIARY DUTY PRIOR TO THE APRIL 10, 2001 SETTLEMENT……………..20
IV. POINT IV: PLAINTIFF’S PRE-SETTLEMENT CLAIMS FOR FRAUD,

FRAUDULENT CONCEALMENT AND NEGLIGENT REPRESENTATION
MUST BE DISMISSED BECAUSE SHE HAS NOT PLEADED THAT
SHE JUSTIFIABLY RELIED ON DEFENDANTS’ ALLEGED
MISPREPRENTATION AND CONCEALMENT……………………………………..22
V. POINT V: PLAINITFF’S CONSPIRACY CAUSES OF ACTION MUST

BE DISMISSED………………………………………………………………………...23
CONCLUSION………………………………………………………………………………...24
i
TABLE OF AUTHORITIES
Page
Abrams v. Donati,
66 N.Y.2d 951, 498 N.Y.S.2d 782 (1985)……………………………………………………….21
Accord Elghanian v. Harvey,

249 A.D.2d 206, 671 N.Y.S.2d 266 (1st Dep’t 1998)……………………………………………22
Appel v. Ford Motor Co.,

111 A.D.2d 731, 490 N.Y.S.2d 228 (2d Dep’t 1985)……………………………………………18
Arfa v. Zamir,
17 N.Y.3d 737, 929 N.Y.S.2d 11 (2011)……………………………………………………….. 19
Armstrong v. Peat, Marwick, Mitchell & Co.,

150 A.D.2d 189, 540 N.Y.S.2d 799 (1st Dep’t 1989)………………………………………….. .12
Booth v. 3669 Delaware,

92 N.Y.2d 934, 680 N.Y.S.2d 899 (1998)……………………………………………………….18
Brawer v. Lepor,
188 A.D.3d 482 (1st Dep’t 2020)……………………………………………………………….. 23
Brock v. Brock,
229 A.D.2d 457, 645 N.Y.S.2d 536 (2d Dep’t 1996)………………………………………….. 14
Carbon Capital Management, LLC v. American Express Co.,

88 A.D.3d 933, 932 N.Y.S.2d 488 (2d Dep’t 2011)…………………………………………….13
Centro Empresarial Cempresa S.A. v. America Movil, S.A.B.,

17 N.Y.3d 269, 929 N.Y.S.2d 3 (2011)……………………………………………........18, 19, 20
Ciullo v. Orange and Rockland Util. Inc.,

271 A.D.2d 369, 706 N.Y.S.2d 428 (1st Dep’t 2000)……………………………………………22
D. Penguin Brothers Ltd. v. City National Bank,

158 A.D.3d 432, 70 N.Y.S.3d 192 (1st Dep’t 2018)…………………………………………….13
EVEmeta LLC v. Siemens Convergence Creators Corp.,

173 A.D.3d 551, 104 N.Y.S.3d 607 (1st Dep’t 2019)………………………………………….. 24
ii
Global Minerals and Metals Corp. v. Holme,
35 A.D.3d 93, 824 N.Y.S.2d 210 (1st Dep’t 2006), lv. denied, 8 N.Y.3d 804,
831 N.Y.S.2d 106 (2007)……………………………………………………………….13, 18, 19
Goldberg v. Manufacturers Life Ins. Co.,

242 A.D.2d 175, 672 N.Y.S.2d 39 (1st Dep’t) lv. dismissed in part and denied in part,
92 N.Y.2d 1000, 684 N.Y.S.2d 186 (1998)………………………………………………...13, 18
High Tides, LLC v. DeMichele,

88 A.D.3d 954, 931 N.Y.S.2d 377 (2d Dep’t 2011)……………………………………………23
Hillman v. City of New York,

263 A.D.2d 529, 693 N.Y.S.2d 224 (2d Dep’t 1999)…………………………………………..14
IDT Corp. v. Morgan Stanley Dean Witter & Co.,

12 N.Y.3d 132, 879 N.Y.S.2d 355 (2009)………………………………………………...........17
Jacobs v. Cartalemi,
156 A.D.3d 605, 67 N.Y.S.3d 63 (2d Dep’t 2007)……………………………………………. 22
Lefkowitz v. Appelbaum,
258 A.D.2d 563, 685 N.Y.S.2d 461…………………………………………………………12, 14
Leider v. Amalgamated Dwellings, Inc.,

2009 WL 2984839 (Sup. Ct. New York Co. Sept. 9, 2009)…………………………………... 16
Lucas-Plaza Housing Development Corp. v. Corey,

23 A.D.3d 217, 805 N.Y.S.2d 9 (1st Dep’t 2005)………………………………………………15
Mamoon v. Dot Net Inc.,

135 A.D.3d 656, 25 N.Y.S.3d 85 (1st Dep’t 2016)……………………………………………. 24
Matter of Cheng Ching Wang,

114 A.D.3d 939, 981 N.Y.S.2d 439, (2d Dep’t 2014)…………………………………….........18
Matter of Weinroth,
1993 WL 13715515 (Sur. Ct. New York Co. 1993)……………………………………………13
O’Neill v. Warburg, Pincus & Co.,

39 A.D.3d 281, 833 N.Y.S.2d 461 (1st Dep’t 2007)…………………………………………… 21
Pappas v. Tzolis,
20 N.Y.3d 228, 958 N.Y.S.2d 656 (2012)……………………………………………………....19
iii
Rite Aid Corp. v. Grass,
48 A.D.3d 363, 854 N.Y.S.2d 1 (1st Dep’t 2008)………………………………………………. 16
Salerno v. Pandick, Inc.,

144 A.D.2d 307, 534 N.Y.S.2d 179 (1st Dep’t 1988)……………………………………………24
Sargiss v. Magarelli,
12 N.Y.3d 527, 881 N.Y.S.2d 651 (2009)……………………………………………………….13
Siegel v. Dakota, Inc.,

173 A.D.3d 515, 104 N.Y.S.3d 604 (1st Dep’t 2019)…………………………………………....16
Spinale v. Tag’s Pride Produce Corp.,

44 A.D.3d 370, 844 N.Y.S.2d 255 (1st Dep’t 2007)……………………………………………..16
Squitieri v. Trapani,
2012 WL 8677707 (Sup. Ct. Westchester Co. 2012) aff’d, 107 A.D.3d 688,
966 N.Y.S.2d 204 (2d Dep’t), lv. denied, 22 N.Y.3d 852, 975 N.Y.S.2d 385 (2013)…………..13
Warner v. Heath,
2020 WL 2095654 (Sup. Ct. New York Co. 2020)…………………………………………….. 22
iv
PRELIMINARY STATEMENT
Plaintiff, brings the instant action against her uncle, the President of the United
States, Donald J. Trump in his personal capacity; her aunt, the Honorable Maryanne Trump
Barry, a retired federal judge who served sixteen years on the District Court and twenty years on
the 3rd Circuit Court of Appeals, and the estate of her uncle, Robert S. Trump. Plaintiff filed a
Summons and Complaint on or about September 24, 2020 (Exhibit “A”), alleging eight separate
causes of action for fraud, conspiracy and breach of fiduciary duty based on alleged conduct
dating back 40 years. Plaintiff’s Complaint should be dismissed in its entirety pursuant to CPLR
§ 3211(a)(5) as: (a) Plaintiff’s claims are time barred under the statute of limitations; and (b)
Plaintiff previously litigated and settled claims with Defendants in 2001, executing General
Releases which released Defendants from the claims she now asserts. To the extent that Plaintiff
is attempting to assert claims for breach of fiduciary duty and fraud, fraudulent concealment and
negligent misrepresentation prior to the sale of her Trump interests, Defendants seek dismissal
pursuant to CPLR § 3211(a) (7) because Plaintiff lacks standing and she has failed to state a
cause of action for each of her claims of fraud and negligent misrepresentation. Plaintiff’s
claims of civil conspiracy to commit fraudulent misrepresentation and concealment and civil
conspiracy to commit fraudulent inducement should be dismissed because there is no cause of
action for “civil conspiracy” independent of the underlying fraud allegations.
Plaintiff makes outlandish and incredulous accusations in her Complaint, which is
laden with conspiracy theories more befitting a Hollywood screenplay than a pleading in a legal
action. Plaintiff even uses the thematic structure of a play to contrive a decades-long sinister plot
in which she claims her aunt and uncles conspired with reputable lawyers, appraisers and other
2
professionals to defraud her. According to Plaintiff, the evil plan unfolded in three acts or parts
she dubs the “Grift”, the “Devaluing” and the “Squeeze Out”. Neatly packaging the conspiracy
as such, Plaintiff casts herself as the unknowing and unsophisticated victim. Quite the contrary,
from her very public appearances this past year, it is apparent that Plaintiff has orchestrated a
sophisticated plan to exact retribution for decades old, previously litigated family grievances to
further her own political agenda and cash in on her family name. To borrow Plaintiff’s own
thematic structure, her “First Act” commenced in December 2017 when, in blatant and willful
violation of the confidentiality and non-disclosure agreement she had entered into with
Defendants in 2001, she gave the New York Times nineteen boxes of her file from a protracted
lawsuit she brought against Defendants for fraud when she filed Objections in the Queens
County Surrogate’s Court to the probate of her grandfather, Fred C. Trump’s Will in 2000. 1
Plaintiff’s “Second Act” followed when she contracted with Simon & Schuster to publish her tell
all book in July this year. 2 A month later, in an act of astonishing duplicity, she released to the
press secretly recorded, private conversations she had with her aunt, Defendant Maryanne Trump
Barry.3 Now for her “Third Act”, Plaintiff has commenced this lawsuit with the aid of a law firm
that has all but admitted on its web site the true purpose and goal of this litigation- to weaken the
President’s political influence during his post- presidency by preoccupying him with the defense
of innumerable lawsuits. 4
Plaintiff herself articulates no direct or specific evidence to substantiate her claims of
fraud and conspiracy. Instead, she simply refers to a New York Times story published on October
1
Mary Trump Reveals How She Became a Top Source for The New York Times, CNN July 7, 2020,
https://www.cnn.com/2020/07/07/media/mary-trump-book-new-york-times/index.html
2
Mary L. Trump, Ph.D., Too Much and Never Enough: How My Family Created the World’s Most Dangerous Man,
New York, Simon & Schuster 2020 https://users.monash.edu.au/~kallan/papers/mtrump.pdf
3
Mary Trump’s Secret Recordings of Aunt Knocking POTUS Slammed a “Rotten”, “Disgusting”, Fox News
August 24, 2020 https://www.foxnews.com/media/mary-trump-blasted-for-secretly-recording-aunt-knocking-potus
4
See https://www.kaplanhecker.com/newsroom/post-presidency-con-man
3
2, 2018 which purported to demonstrate that Defendant, Donald J. Trump, inherited wealth from
his parents and was not totally self-made, a narrative the authors and, no doubt, the New York
Times itself were eager to push. 5 The Times article suggested that the estate planning techniques
employed by the Trumps were “suspect”, notwithstanding the fact that the planning was
performed under the advice, guidance and execution of experienced attorneys, accountants and
other professionals in the field and notwithstanding the fact that the estate and trust tax returns
survived an intense audit by the IRS. On its mission to prove that the President was not self-
made, the Times took full advantage of the libel protections afforded it to make unsubstantiated
claims that Defendants formed “sham” companies and engaged in fraud and a conspiracy to
transfer vast sums of monies to themselves from their father’s companies. Seizing the
opportunity to re-litigate her case and piggy back on a wave of political bias against Defendants,
Plaintiff now runs with this unsubstantiated narrative, albeit with an added self-serving twist-
that it was all done to defraud her. Unlike newspapers stories, claims made in lawsuits must be
substantiated by admissible evidence, not speculation and conjecture about double hearsay
statements from anonymous sources. Plaintiff proffers no direct evidence to support her claims
of fraud or conspiracy. She paints in broad strokes and just repeatedly characterizes alleged
conduct and transactions as fraudulent and conspiratorial, hoping the mantra will have a
transformative effect.
Plaintiff alleges that, starting almost forty years ago, Defendants engaged in three
fraudulent schemes to defraud her. First, that Defendants, through the formation and use of a
purchasing and contracting company called All County Building Supply & Maintenance Corp.
5
See David Barstow, Susan Craig & Russ Buettner, Trump Engaged in Suspect Tax Schemes as He Heaped Riches
From His Father N.Y.Times, Oct 2, 2018, https://www.nytimes.com/interactive/2018/10/02/us/poltics/donald-trump-
tax-schemes-fred-trump.html.
4
(“All County”) and a management company called Apartment Management Associates, Inc.,
(“AMA”), fraudulently siphoned value from Trump family entities in which she had a minority
interest to entities Defendants owned and controlled, while disguising those transfers as
legitimate business transactions (the so called “Grift”); second, that Defendants fraudulently
depressed the value of her interests and the net income they generated through fraudulent
appraisals and financial statements (the so called “Devaluing”); and third, that Defendants forced
Plaintiff to the negotiating table to settle her lawsuit against her will by threatening her. With
dramatic flair, Plaintiff alleges that when she got to the negotiating table, she was presented with
a stack of fraudulent valuations and financial statements and forced to sign a written agreement
against her interests (the so called “Squeeze Out”).
To get a second bite at the apple and toll the statute of limitations for fraud,
Plaintiff claims that she was kept “in the dark” about the alleged fraud until The New York Times
published its aforementioned article on October 2, 2018, despite the fact that the very documents
used by the Times to write the article were given to it by Plaintiff a year earlier. Indeed, all of
the information Plaintiff now claims forms the basis of fraud (which Defendants vehemently
deny) was made known to her twenty years ago after she filed Objections to the probate of her
grandfather’s Will in 2000. At that time, she retained an experienced and highly regarded trusts
and estate litigator named John Barnoski, Esq., a partner of the law firm, Farrel Fritz. Plaintiff
engaged in protracted litigation with two separate lawsuits in two courts, which involved
significant discovery, including the exchange of tax returns, financial statements, banking
statements, appraisals and other financial information regarding the testamentary and non-
testamentary assets of her grandfather as well as other Trump family assets in which she shared a
minority ownership interest with her aunts and uncles. Her attorney took SCPA § 1404
5
examinations of the attorney draftsman and witnesses to the will as well of
Defendants/Executors. Eighteen months into the litigation, Plaintiff made an informed decision
to settle her claims for a significant sum of money. Plaintiff admitted in her own book that she
should have investigated further when she settled in 2001 but made a conscious decision to do
nothing.6 She wasn’t dragged to a negotiating table and at the last minute presented with a stack
of fraudulent valuations and financial statements. On the advice of her very competent and
experienced attorney, she ultimately signed a carefully worded twenty page settlement
agreement, that had gone through several modifications and revisions between her attorney and
attorneys for the estate and memorialized and finalized global settlement negotiations that had
taken place over months, which included a termination of her Trust and a buyout of her interests
in the family businesses. At no time was Plaintiff forced to relinquish her interests in the family
businesses during this litigation. At any time, she could have simply withdrawn her Objections
to the probate of her grandfather’s Will and maintained the status quo.
FACTS MADE KNOWN TO PLAINTIFF IN THE PRIOR LITIGATION
The decedent Defendant Robert S. Trump testified at his §1404 hearing (See
Exhibit “N”) that he began working with his father in the fall of 1991, while his father (then in
his mid-eighties) was convalescing from hip replacement surgery. In view of the age of the
buildings in the portfolio, Robert helped begin a campaign to perform major capital
improvements which included the installation of new roofs, new boilers, elevator equipment,
windows, sidewalks et cetera. (Page 44:11-24) Robert also observed that his father had an
6
Mary L. Trump, Ph.D., Too Much and Never Enough: How My Family Created the World’s Most Dangerous Man,
New York, Simon & Schuster 2020 https://users.monash.edu.au/~kallan/papers/mtrump.pdf at page 187
6
antiquated and inefficient system (ripe for theft) where the building superintendents controlled
the purchase of supplies and equipment. Therefore, in 1992, Robert, along with his three
siblings and a cousin, on the advice and blessing of their lawyers and outside accountants,
formed All County to become the central purchasing agent and contractor for the Trump
properties. (Page 135:10-17; Page 137:6-11) Robert testified that All County was set up “to
acquire goods, services, sort of combining the purchasing power of the whole company. Rather
than the system of having each individual building order individually its particular building
needs, we started buying on a wholesale basis, and then--- from vendors, from suppliers, and
then selling that off to the entities.” (Page 135: 2-9) Robert freely admitted that All County was
a “for profit” venture. Plaintiff’s attorney had the following exchange with Robert:
Q. And so was one of the purposes of--- All County Building Supply in
addition to having the business purpose of centralized purchasing power,
if you will, could mark up and generate a profit on its own. ?
A. That’s correct.
Q. And that was one of the other purposes?
A. It was a purpose also, yes.
(Page 135:24-Page 136:8)
Robert testified that, in many cases, the mark-up charged by All County was offset by the
savings wholesale bulk purchasing afforded. (Page 143:5-13) Plaintiff’s attorney also observed
that the markup had the effect of decreasing Fred C. Trump’s estate, which Robert
acknowledged, while clarifying that the performance of major capital improvements allowed for
the lawful increase in rents under New York City law which ultimately increased the profitability
of his father’s companies. (Page 136:9-Page 137:7) Plaintiff’s attorney probed deeper into All
County, marking and identifying cash disbursements to All County for Beach Haven
Management in January and September, 1993 and entering the following exchange:
Q. “Would it be fair to say that once you established All County as the
purchasing agent, that the purchases or all of the entities would have been
7
through All County….? And I am going to find the same kind of entries
in all of those other entities to the extent they had purchasing
requirements?
A. “I believe so”
Q. And I’m going to find the same kind of entries in all of those other entities
to the extent that had purchasing requirements?
A. Right
(Page 145: 3-12)
Plaintiff requested and, upon information and belief, received records from Defendants regarding
All County, including its consulting contract with Fred Trump’s entity, Trump Management,
Inc., and letters from Fred Trump with regard to purchase orders. (Page 165: 19-166:2) Robert
further testified that in 1994, he and his siblings replaced their father’s company, Trump
Management Inc, with their own management company, AMA. The company had a management
agreement with Fred C. Trump and charged a management fee. (See Exhibit “J”) This was
made clear and obvious to plaintiff’s attorney, when he had the following exchange with Robert:
Q. What did that (Apartment Management Associates) do?

A. It created, I believe, later, but it’s in the business of managing the
individual developments. What Trump Management, Inc. had really done
we shifted the focus over to Apartment Management Associates.
Q. So, in effect, you took the money that was being paid from the entities to
Trump Management, which was owned by your father, and that money
went to a company controlled by people other than your father?
A. That’s correct.
(Page 139:17- 140:5)
Not only was Plaintiff’s attorney made keenly aware of All County and AMA and their business
purposes, he conceded that they made for “good estate planning” by getting money out of Fred
Trump’s estate. (Page 141: 2-8)
Defendant’s cousin, John W. Walter testified at his §1404 hearing (See Exhibit
“O”) that All County was formed in 1992 to have a central purchasing agent. Prior to All
8
County, there was an inefficient system where no one in the central office was responsible for
purchasing and where the supers would order supplies for the individual buildings. (Page 257: 2-
20) In questioning Mr. Walter, Plaintiff’s attorney again was advised that All County made a
profit through a mark-up, which he observed had the ancillary benefit of sending money
“downstream” and not subject to estate taxes...” (Page 262:18-21)
Plaintiff was provided voluminous financial records, which she admits in her
Complaint included years that pre-dated and postdated All County and AMA. (Complaint ¶ 92,
93) Plaintiff was given discovery with regard to loans taken by Midland Associates and elicited
deposition testimony from Mr. Tosti with regard to the loans. (See Exhibit “L”) In fact,
plaintiff had legal access to all of Midland’s financial records prior to settling her claim.
Plaintiff was provided the appraisals used for the Estate and Gift tax returns and was certainly
free to obtain her own valuations.
To feign ignorance and attempt to create an issue of fact, Plaintiff conjures up
conspiracy theories starting with her own attorney, John Barnosky, Esq. whom she alleges may
have left her in the dark due to “conflicting loyalties”. (Complaint ¶ Id) Plaintiff alleges that her
now deceased and silenced Trustee, Irwin Durben conspired to commit fraud with no substantive
facts to support the allegation. (Complaint ¶ 78, 91) Plaintiff also alleges that, Robert Von
Ancken, a licensed appraiser who worked for Grubb & Ellis, one of the nation’s leading
commercial real estate service firms, conspired with Defendants to produce fraudulent appraisals
to devalue her interests. (Complaint ¶ 80-84) Von Ancken’s company performed valuations for
the two GRATs that Fred C. Trump and his wife funded in 1995 as well as valuations of Fred’s
Estate as of 1999. Von Ancken’s work was certified by two other appraisers. (See Exhibit “U”)
In addition, a second valuation company, Management Planning Inc., (“MPI”) had been retained
9
by Defendants to value the Estate and GRAT assets. The reports generated were also certified
by two valuation experts. (See Exhibit “V”) To the extent that Plaintiff alleges a conspiracy to
obtain fraudulent appraisals, the conspiracy must include these three other people, which is
absurd.
Plaintiff alleges that Defendants ducked sales of Co-op apartments, selling only
three sponsor owned apartments in 1998 and 1999 which prevented evidence of sales price
information from being generated which, in turn, precluded her from adequately valuing her
interests. This is patently false. Defendants provided Plaintiff detailed information on the sales
of almost forty sponsor and non-sponsor owned apartments in the buildings in 1999 and 2000.
(See Exhibit “K”)
With respect to her Land Interests, Plaintiff claims they were misrepresented to
her simply as rights to cash streams from ground leases and that she wasn’t informed that, in
addition, she had a reversion interest in the buildings themselves not just the ground leases.
(Complaint ¶ 51-52) Plaintiff claims that the alleged fraudulent appraisals and alleged fraudulent
maintenance and management fees lowered the net income of the buildings that stood on the
land, which in turn devalued her reversion interest. Plaintiff claims that the ground leases in
question were created in 1948 and were for a duration of 99 years and that she would have an
ownership interest in the buildings when they reverted back to the lease owners in 2047.
(Complaint ¶ 50) This is demonstrably false. First the ground leases commenced in 1950. (See
Exhibit “E”) and were for an initial term of 99 years but they gave the building owners an
automatic right of renewal for an additional 99 years. So in fact, plaintiff can only claim a
minority ownership interest in the buildings in the year 2148, when she will be 183 years old.
Moreover, the reversion interest in a ground lease is an obvious fact. If Plaintiff was
10
misinformed or misadvised with regard to it, she would have a grievance with regard to the
quality of her legal representation, not a claim of fraudulent misrepresentation against
Defendants.
Plaintiff alleges that she was misinformed with regard to Midland’s interest in
Starrett City (through Park Briar Associates, LLC) claiming that, while Defendants reported the
value to her attorney as “nominal” (Complaint ¶ 123,124), it sold for $900 Million seventeen
years later in 2018. (Complaint ¶ 123,124) Plaintiff’s interest would have been 1/10th of 1.4583%
of the “net sale amount” after the mortgage was paid off, discounted to present value back in
2001. Of course, Defendants were not clairvoyant in 2001, and could not have predicted that a
buyer would come along nearly two decades later to overcome the regulatory hurdles and
7
community and political resistance that accompanied any attempt to sell the property.
Plaintiff’s complaints now don’t constitute fraud, they constitute ‘buyer’s remorse”. Moreover,
Plaintiff had a duty to make further inquiry in 2001 (see Point II, infra).
In April 2000, Plaintiff commenced a second lawsuit in Nassau Supreme Court,
suing Defendants to compel them to continue to pay her and her family’s health insurance
premiums. (See Exhibit “P”) While plaintiff was litigating the second action against Defendants
in Supreme Court, she had been made aware of the following facts: that Defendants, along with
their cousin, formed All County and used it as the exclusive purchasing agent and general
contractor for the Trump buildings as a means to take purchasing control away from the supers
and to use the power of bulk purchasing; that All County was a “for profit” venture that marked
up the goods and services it purchased in consideration for the legitimate business purposes it
served; that All County performed extensive major capital improvements for the Trump
7
See Oksana Miranova. The Lesson of Starrett City Feb 6, 2014 https://www.bklynr.com/the-lesson-of-starrett-city/
Discussing how a buyer’s market only developed in the Mid 2000’s
11
buildings throughout the 1990’s; that AMA was formed by Defendants as the managing agent for
the portfolio of real estate properties in 1994 and that it received a management fee which
amount was disclosed to Plaintiff. She was aware that Midland Associates had loans on the
books. She was aware of the GRATs that were created in 1995 as well as the values assigned to
them. She was aware of the appraised value of the estate. If all of this smelled of fraud to
Plaintiff, she could have added causes of action to her Supreme Court lawsuit in 2000.
ARGUMENT
POINT I
PLAINTIFF’S CLAIMS ARE BARRED BY THE STATUTE OF LIMITATIONS
A. Plaintiff’s Fraud Claims are Untimely
Under CPLR §213(8) the time within which an action alleging fraud must be
commenced “shall be the greater of six years from the date the cause of action accrued or two
years from the time the plaintiff … discovered the fraud, or could with reasonable diligence have
discovered it.” A fraud claim accrues upon the “commission of the fraud.” See, e.g., Armstrong
v. Peat, Marwick, Mitchell & Co., 150 A.D.2d 189, 191, 540 N.Y.S.2d 799, 802 (1st Dep’t 1989)
(“[A]n action based upon fraud must be commenced within six years from the commission of the
fraud or two years from its actual or imputed discovery”); Lefkowitz v. Appelbaum, 258 A.D.2d
563, 685 N.Y.S.2d 460, 461 (2d Dep’t 1999) (a “cause of action based upon actual fraud must be
commenced within six years of the commission of the fraud, or two years from the date the fraud
could reasonably have been discovered, whichever is later”).
Where, as here, a claim is made that a person was fraudulently induced to enter
into a contract, the time of the “commission of the fraud” is the time the person entered into the
12
agreement. Carbon Capital Management, LLC v. American Express Co., 88 A.D.3d 933, 939,
932 N.Y.S.2d 488, 495 (2d Dep’t 2011) (fraud claim accrued at time plaintiff entered into
contract with investment company in reliance on defendant’s alleged misrepresentations);
Squitieri v. Trapani, 2012 WL 8677707 (Sup. Ct. Westchester Co. 2012), aff’d, 107 A.D.3d 688,
966 N.Y.S.2d 204 (2d Dep’t), lv. denied, 22 N.Y.3d 852, 975 N.Y.S.2d 385 (2013) (claim that
plaintiff was fraudulently induced to enter into agreement to swap interests in properties with
defendant accrued on date of agreement); Goldberg v. Manufacturers Life Ins. Co., 242 A.D.2d
175, 672 N.Y.S.2d 39 (1st Dep’t), lv. dismissed in part and denied in part, 92 N.Y.2d 1000, 684
N.Y.S.2d 186 (1998) (claim that insurer misrepresented premium payment terms of insurance
policy accrued on date plaintiffs purchased policy).
The fraud is also held to have been committed when the plaintiff, or his decedent,
is alleged to have parted with his or her property as a result of the defendant’s
misrepresentations. See D. Penguin Brothers Ltd. v. City National Bank, 158 A.D.3d 432, 70
N.Y.S.3d 192 (1st Dep’t 2018) (fraud cause of action accrued when plaintiff was induced to
provide $1.5 million investment based on defendants’ misrepresentations); Matter of Weinroth,
1993 WL 13715515 (Sur. Ct. New York Co. 1993) (claims for return of decedent’s real property,
funds in Keogh plan and proceeds of sale of professional cooperative apartment, alleged to have
been procured by surviving spouse by fraud, coercion and undue influence, accrued at time of
transfer to surviving spouse).
The “inquiry as to whether a plaintiff could, with reasonable diligence, have
discovered the fraud turns on whether the plaintiff was ‘possessed of knowledge of facts from
which [the fraud] could be reasonably inferred’”. Sargiss v. Magarelli, 12 N.Y.3d 527, 532, 881
N.Y.S.2d 651, 654 (2009). If a plaintiff had “knowledge of the operative facts underlying [its]
13
fraud claim” more than two years before the commencement of its action, “at which time, with
due diligence, [it] could have discovered the alleged fraud,” her claim is time-barred. Brock v.
Brock, 229 A.D.2d 457, 458, 645 N.Y.S.2d 536, 537 (2d Dep’t 1996). The “burden of
establishing that the fraud could not have been discovered before the two-year period before the
commencement of the action rests on the plaintiff, who seeks the benefit of the exception.”
Hillman v. City of New York, 263 A.D.2d 529, 693 N.Y.S.2d 224, 225 (2d Dep’t 1999), lv.
denied, 94 N.Y.2d 759, 706 N.Y.S.2d 80 (2000); Lefkowitz v. Appelbaum, supra, 258 A.D.2d at
563, 685 N.Y.S.2d at 461.
Here, Plaintiff’s claim accrued, at the latest on April 10, 2001, the date on which
she entered into the Settlement Agreement. To the extent that she is attempting to assert fraud
claims based on the Defendants’ actions during the twenty-year period preceding her entry into
the Settlement Agreement, those claims are time-barred because they accrued earlier than April
10, 2001. Plaintiff cannot meet her burden of establishing that she was unaware of the alleged
fraud and could not, with reasonable diligence, have discovered it within two years of
commencing this action, which she filed on September 24, 2020.
On February 24, 2000, nearly a year before entering into the Settlement
Agreement, Plaintiff’s counsel, Mr. Barnosky, questioned Defendant-Decedent, Robert Trump
extensively concerning All County’s operations. Robert testified that All County was a central
purchasing company set up by him, his siblings and his cousin in 1992, to acquire goods and
services and combine the bulk purchasing power of the Company and to buy wholesale from
vendors and suppliers and then to sell those products and services to the Company, which would
also effectively take control away from the supers by removing them from the purchasing
process. (See “Exhibit N” Page 134:20- 135:17) Robert freely admitted that All County was a
14
“for profit” venture that made money by marking up prices for the valuable business purposes it
served. (Page 135:24-136:6) Robert testified that All County was formed in consultation with
the Company’s lawyers and outside auditors. (Page 145:21- 146:12)
Robert Trump also testified concerning AMA, testifying that “it’s in the business
of managing the individual developments” and indicating that it had taken over what Trump
Management had done (Page 139:15-22). Mr. Barnosky stated that he had seen “lots of checks
going out to Trump Management from the various [Trump family] entities (Page 132:22--133:2),
and that he had “records of all these entities for the three years [prior to Fred’s September 18,
1991 Will] (Page 133:16-20), and that “I can assure you there are checks during the two-year
period [September 1991 – September 1993] to All County Building Supply” (Page:134:20-23).
Mr. Barnosky also demanded production of “the documents on All County Management, its
shareholders’ agreement, and any contractual arrangements between entities in which [Fred] had
an interest” during the period from September 1988 through September 1993. Such questioning
put Plaintiff on notice of the alleged fraud she now claims. Lucas-Plaza Housing Development
Corp. v. Corey, 23 A.D.3d 217, 805 N.Y.S.2d 9 (1st Dep’t 2005) (suit alleging fraud in
connection with reissuance and defeasance of long-term tax- exempt bonds untimely where
plaintiff’s counsel had questioned defendants concerning the bonds’ defeasance over ten years
before bringing suit).
Plaintiff admits that, since signing the Settlement Agreement, she was in
possession of or had control over the 19 boxes containing these records from her file on which
the New York Times based its investigation. Those documents, which Plaintiff sat on for twenty
years, included the transcripts of Robert Trump and John Walter’s deposition testimonies which
disclosed the existence of All County and AMA, their ownership structure and their legitimate
15
business purposes. Defendants did not fraudulently conceal any of this information. To the
contrary, they admitted openly to it. Plaintiff was perfectly free to examine those records, or to
ask counsel to do so. Under similar circumstances, the courts have consistently held that the
discovery exception to the six-year fraud statute is unavailable. See, e.g., Siegel v. Dakota, Inc.,
173 A.D.3d 515, 104 N.Y.S.3d 604 (1st Dep’t 2019), lv. Denied 35 N.Y. 3d 902, 124 N.Y.S. 3d
309 (2020) (no basis to apply two-year discovery provision to plaintiff’s fraud claim against
former co-op board members where “plaintiff admits he discovered this alleged new evidence by
reviewing board minutes from more than a decade ago that were available to him at that time”);
Spinale v. Tag’s Pride Produce Corp., 44 A.D.3d 570, 844 N.Y.S.2d 255 (1st Dep’t 2007)
(summary judgment properly granted dismissing complaint alleging fraudulent inducement of
sale of stock where “any documents that might have been necessary for plaintiff to discover the
fraud alleged … were in his possession”); Leider v. Amalgamated Dwellings, Inc., 2009 WL
2984839 (Sup. Ct. New York Co. Sept. 9, 2009) (“it has been generally held that when the
documents necessary for a claimant to discover the alleged fraud were in his possession, the
discovery exception does not apply”); Rite Aid Corp. v. Grass, 48 A.D.3d 363, 364, 854
N.Y.S.2d 1 (1st Dep’t 2008) (corporation “had notice of operative facts that should have
prompted further inquiry as to the … transaction, where the “key proof – financial records and
internal company correspondence – had been in plaintiff’s possession” since before the
expiration of the two-year discovery period).
Plaintiff simply feigns ignorance of all the information that put her on notice for
the alleged fraud, claiming she wasn’t made aware of any of this information and that her very
qualified and experienced attorney was possibly duped. (Complaint ¶ 20) Plaintiff’s claim that
16
she was misinformed by counsel might form the basis for a legal malpractice claim but it doesn’t
toll the statute of limitations for fraud.
It is thus obvious that all of the information that Plaintiff claims was unknown to
her until 2018 and which forms the basis of her alleged fraud claims, was plainly made known to
her and her lawyer twenty years ago. Plaintiff’s counsel had all the information she needed to
pursue the present claims, or at the very least to pursue more intensive discovery in Plaintiff’s
probate contest concerning All County’s billing of the Trump operating entities and the
management and consulting fees, and salaries, or any loans to or from Midland which Plaintiff
now claims were fraudulent. Furthermore, to the extent that any discovery was limited in the
probate proceeding, Plaintiff could have pursued direct claims for fraud unrelated to the Estate
when she filed the second action against Defendants in Supreme Court.
B. Plaintiff’s Claims for Breach of Fiduciary Duty and Aiding and Abetting Breach of
Fiduciary Duty Are Time-Barred
Plaintiff’s claims for breach of fiduciary duty and aiding and abetting breach of
fiduciary duty are barred by CPLR 214(4)’s three-year Statute of Limitations, because Plaintiff
seeks money damages only, and because Plaintiff’s allegations of fraud are not essential for
those claims. IDT Corp. v. Morgan Stanley Dean Witter & Co., 12 N.Y.3d 132, 139, 879
N.Y.S.2d 355, 359 (2009). A review of Plaintiff’s allegations supporting her claim for breach of
fiduciary duty shows that they are premised on Defendants’ alleged siphoning and devaluing of
her interests (Complaint, ¶226), which as is argued in Point III, infra, are derivative claims8
8
If Plaintiff could assert these claims, they would be governed by CPLR 213(7), which applies to actions on behalf
of a corporation against an officer, director or shareholder to recover damages for waste or an injury to property. No
discovery period is provided for those claims.
17
which she has no standing to assert. Moreover, by the time the parties entered into the
Settlement Agreement, their fiduciary relationship had terminated (see Point II, infra).
Even if 213(8)’s six-year Statute of Limitations were applicable, Plaintiff’s breach
of fiduciary duty claim is time barred for the same the reasons her fraud claims are time barred.
POINT II
PLAINTIFF’S CLAIMS ARE BARRED BY THE

GENERAL RELEASES SHE EXECUTED IN CONNECTION
WITH THE SETTLEMENT AGREEMENT
It “is well established that a valid release constitutes a complete bar to an action
on a claim which is the subject of the release.” Global Minerals and Metals Corp. v. Holme, 35
A.D.3d 93, 98, 824 N.Y.S.2d 210, 214 (1st Dep’t 2006), lv. denied, 8 N.Y.3d 804, 831 N.Y.S.2d
106 (2007); accord, Matter of Cheng Ching Wang, 114 A.D.3d 939, 940, 981 N.Y.S.2d 439, 441
(2d Dep’t 2014). If “the language of a release is clear and unambiguous, the signing of a release
is a ‘jural act’ binding on the parties,” Centro Empresarial Cempresa S.A. v. America Movil,
S.A.B., 17 N.Y.3d 269, 276, 929 N.Y.S.2d 3, 8 (2011) (quoting Booth v. 3669 Delaware, 92
N.Y.2d 934, 935, 680 N.Y.S.2d 899 (1998)), which “will be enforced as a private agreement.”
Appel v. Ford Motor Co., 111 A.D.2d 731, 732, 490 N.Y.S.2d 228, 229 (2d Dep’t 1985).
That Defendants are alleged to have been co-partners with Plaintiff in Midland or
are otherwise alleged to have been acting as fiduciaries when entering into the Settlement
Agreement, does not affect the enforceability of the release. It is well-settled that where, as here,
“the fiduciary relationship is no longer one of unquestioning trust,” Centro Empresarial
Cempresa S.A., supra, 17 N.Y.3d at 278, 929 N.Y.S.2d at 9, a sophisticated principal or one
represented by sophisticated counsel, is able to release her fiduciary from all claims. Id.; accord
18
Arfa v. Zamir, 17 N.Y.3d 737, 738, 929 N.Y.S.2d 11, 12 (2011); Pappas v. Tzolis, 20 N.Y.3d
228, 233, 958 N.Y.S.2d 656, 659 (2012). When Plaintiff agreed to relinquish her interest in
Midland and her Land Interests, the parties were already in an adversarial relationship – she had
filed her objections contesting Fred’s Will and had brought her action against Defendants to
require them to reinstate insurance coverage for Fred III’s son, William, which she alleges was
discontinued out of spite by the Defendants. In addition, her complaint alleges that Robert
attempted to force her to sell her interests, by threatening that Defendants would put Midland
into bankruptcy and put her in a position where she would pay income taxes for the rest of her
life, without receiving any further income. The First Department in Arfa v. Zamir, supra, found
that a similar threat to damage a co-shareholder’s interest evidenced such an adversarial
relationship. 76 A.D.3d at 60, 905 N.Y.S.2d at 80.
Moreover, in the adversarial context, a “heightened degree of diligence [was]
required of [Plaintiff] and [she cannot] reasonably rely on [Defendants’] representations without
making additional inquiry to determine their accuracy” Arfa, 76 A.D.2d at 60, 905 N.Y.S.2d at
80 (quoting Global Mins. & Metals Corp. v. Holme, supra, 35 A.D.3d at 100, 824 N.Y.S.2d at
216 (1st Dep’t 2006), lv denied, 8 N.Y.3d 804, 831 N.Y.S.2d 106 (2007). Plaintiff did not
exercise such diligence, notwithstanding that she was plainly on notice, through her counsel’s
questioning of Robert Trump concerning the ‘fraud” of which she now complains. “There is no
prerequisite to the settlement of a fraud case that the (fiduciary) defendant must come forward
and confess to all his wrongful acts in connection with the subject matter.” Centro Empresarial
Cempresa S.A., supra, 17 N.Y.3d at 278, 929 N.Y.S.2d at 9.
The release is also enforceable under the well-settled rule that “a party that
releases a fraud claim may later challenge the release as fraudulently induced only if it can
19
identify a separate fraud from the subject of the release.” Centro Empresarial Cempresa S.A.,
supra, 17 N.Y.3d at 276, 929 N.Y.S.2d at 8. Plaintiff has not done so here. There can be no
dispute that the release executed by Plaintiff encompasses fraud claims, including any fraud
claims that were allegedly unknown at the time of the settlement. In Centro Empresarial
Cempresa S.A., where, like here, the Plaintiffs alleged that the defendants had fraudulently
induced them to sell their minority investment in a telecom company (which they owned through
a limited liability company), the Plaintiffs executed a release in connection with the sale
releasing the defendants from:
all manner of actions … whatsoever … whether past, present or

future, actual or contingent, arising under or in connection with the
Agreement Among Members and/or arising out of … the
ownership of membership interests in [TWE]….
17 N.Y.3d at 274, 929 N.Y.S.2d at 60. The Court of Appeals held that the phrase “all manner of
actions” in conjunction with the reference to “future” and “contingent” actions “indicates an
intent to release defendants from fraud claims, like this one, unknown at the time of the contact.”
Id.
The general releases Plaintiff signed are even broader, releasing Defendants from:
all actions … whatsoever, in law, admiralty or equity, which

against the RELEASEE … the RELEASOR ever had, now have or
hereafter can, shall or may, have for, upon, or by reason of any
matter, cause or thing whatsoever, from the beginning of the world
to the day of the date of this RELEASE.
All of Plaintiff’s current claims are within the terms of the Releases she executed in 2001.
POINT III
PLAINTIFF LACKS STANDING TO ASSERT ANY

CLAIM TO RECOVER FOR DEFENDANTS’ ALLEGED
BREACH OF FIDUCIARY DUTY PRIOR TO THE APRIL 10, 2001 SETTLEMENT
20
Plaintiff claims that, for some twenty years prior to relinquishing her Midland
Interests in the April 10, 2001 settlement, Defendants engaged in various schemes to diminish
the value of her investment, by siphoning profits from the two corporations and two limited
liability companies in which she held her interests.9 These include her allegations concerning the
markups taken by All County as a middleman, Defendants’ alleged charging of “exorbitant
management fees, consulting fees and salaries” to these entities through Trump Management and
AMA, and by causing these entities to make loans to other Trump entities they controlled, at
preferential rates or which did not require repayment.
All of these claims are classic derivative claims which do not accrue to a
shareholder individually. As the Court of Appeals held in the leading case of Abrams v. Donati,
66 N.Y.2d 951, 953, 498 N.Y.S.2d 782, 783 (1985):
[A]llegations of mismanagement or diversion of assets by officers

or directors to their own enrichment, without more, plead a wrong
to the corporation only, for which a shareholder may sue
derivatively but not individually.
This rule applies to claims that such diversion and self-dealing caused the “diminution of the
value of [a shareholder’s] stock holdings.” O’Neill v. Warburg, Pincus & Co., 39 A.D.3d 281,
281-282, 833 N.Y.S.2d 461, 462 (1st Dep’t 2007).
Because the heart of the alleged injury is the diminution of the

value of shares of QoS Networks Limited, a start-up company in
which plaintiffs were minority shareholders, the argument that
plaintiffs are entitled to bring a direct action against Warburg, the
majority shareholder, is unavailing under New York Law.
9
Highlander Hall, Inc. and Coronet Hall, Inc., and Midland Associates, LLC and Park Briar Associates, LLC
(Complaint ¶¶55).
21
Id. at 282, 833 N.Y.S.2d at 462. Accord Elghanian v. Harvey, 249 A.D.2d 206, 207, 671
N.Y.S.2d 266 (1st Dep’t 1998) (“The motion court correctly determined that plaintiff’s claim for
diminution of the value of his stock holdings in defendant Artra was a derivative cause of action
belonging to that corporation and not to plaintiff individually”). The same rules apply to claims
for self-dealing and diminution in value brought by members of a limited liability company.
See, e.g., Jacobs v. Cartalemi, 156 A.D.3d 605, 608, 67 N.Y.S.3d 63, 66-67 (2d Dep’t 2007);
Warner v. Heath, 2020 WL 2095654, at *13-14 (Sup. Ct. New York Co. 2020).
It is equally well settled that when a shareholder or member of a limited liability
company disposes of her shares or membership interest, she no longer has standing to sue
derivatively. See Ciullo v. Orange and Rockland Util. Inc., 271 A.D.2d 369, 706 N.Y.S.2d 428
(1st Dep’t 2000) (“Plaintiffs lack standing to challenge dismissal of their complaint since they are
no longer shareholders in defendant corporation, having tendered their shares for cash in the
merger of defendant corporation into another corporation”); Jacobs v. Cartalemi, supra.
Thus, as Plaintiff is not a shareholder or member of any of the Midland entities,
she has no standing to prosecute her claim for breach of fiduciary duty on behalf of any of those
entities.
POINT IV
PLAINTIFF’S PRE-SETTLEMENT CLAIMS FOR FRAUD, FRAUDULENT

CONCEALMENT AND NEGLIGENT MISREPRESENTATION MUST BE
DISMISSED BECAUSE SHE HAS NOT PLEADED THAT
SHE JUSTIFIABLY RELIED ON DEFENDANTS’ ALLEGED
MISREPRESENTATIONS AND CONCEALMENT
To plead claims for fraud and fraudulent concealment, Plaintiff must plead the
element of justifiable reliance. Similarly, Plaintiff must plead reasonable reliance to sustain her
22
claim for negligent misrepresentation. High Tides, LLC v. DeMichele, 88 A.D.3d 954, 959, 931
N.Y.S.2d 377, 383 (2d Dep’t 2011).
Although Plaintiff claims that Defendants misrepresented and concealed that they
were allegedly siphoning money from the Trump entities in which she was interested and
depressing the value of her interests for years prior to the April 2001 settlement, she does not
plead that she took any action in reliance on such alleged misrepresentation and concealment
before she tendered her shares in connection with the Settlement Agreement.
The First Department recently affirmed this Court’s dismissal of a similar claim
for fraudulent concealment in Brawer v. Lepor, 188 A.D.3d 482 (1st Dep’t 2020), holding that
the complaint failed to allege how plaintiff relied to his detriment on a limited liability
company’s president and vice president’s concealment of the company’s 43.5% member’s self-
dealing and their own self-dealing by causing the company to pay their personal expenses. The
plaintiff (the company’s other 43.5% member) did not allege that their concealment caused him
to retain his membership interest or to take any other action in reliance on such concealment.to
his damage.
Here, too, Plaintiff fails to allege that she took any action in reliance over the 20-
year period on Defendants’ alleged fraud and fraudulent concealment, or their alleged negligent
misrepresentations. Accordingly, her claims for fraud, fraudulent concealment and negligent
misrepresentation, to the extent that they rely on actions allegedly taken by the Defendants prior
to the April 10, 2001 settlement, should be dismissed.
POINT V
PLAINTIFF’S CONSPIRACY CAUSES OF ACTION MUST BE DISMISSED
23
Plainitffs claims of "civil conspiracy to commit fraudulent misrepresentation and
fraudulent concealment" (Count 5) and "civil conspiracy to commit fraudulent inducement"
(Count 6) must be dismissed, because "New York does not recognize an independent cause of
action in tort for conspiracy." EVEmeta LLC v. Siemens Convergence Creators Corp., 173
A.D.3d 551,553, 104 N.Y.S.3d 607,610 (1st Dep't 2019); accord Mamoon v. Dot Net Inc .. 135
A.D.3d 656, 658, 25 N.Y.S.3d 85, 88 (1' 1 Dep't 2016); Salerno v. Pandick. Inc., 144 A.D.2d 307,
308, 534 N.Y.S.2d 179, 180 (I 51 Dep't 1988). In any event because the underlying fraud claims
are time-barred, any such conspiracy claims are unsustainable.
CONCLUSION
For all of the foregoing reasons, Plaintiffs complaint should be dismissed as
against Defendants Donald J. Trump and Shawn Hughes, as Executor of the Estate of Robert S.
Trump pursuant to CPLR§ 3211(a)(5)& (7).
Dated: Lake Success, NY

December 22, 2002
By:
1-1 GHES, as Executor of THE ESTATE

0- ROBERTS. TRUMP
3 0 Marcus Avenue, Suite 3W07
ake Success. New York II 042
( 516) 466-7900
24
TO: KAPLAN HECKER & FINK LLP
New York, NY 10118
(212) 763-0883
(212) 564-0883 Fax
rkaplan@kaplanhecker.com
jquinn@kaplanhecker.com
arodney@kaplanhecker.com
GREENFIELD, STEIN & SENIOR LLP

600 Third Avenue
New York, NY 10118
(212) 818-9336
212-818-1264 Fax
gfriedman@gss-law.com
jsheetz@gss-law.com
25
EXHIBIT "A "
INDEX NO. 654698/2020
F.T.LE D NEW YORK COUNTY CLERK 09/ 2 4 /2 020 10 : 2 6 AMl
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/24/2020

COUNTY OF NEW YORK
MARY L. TRUMP,
Plaintiff
v. Index No.
Date Purchased: September 24, 2020
MARYANNE TRUMP BARRY, and JOHN or JANE
DOE, the executor of the ESTATE OF ROBERT S. SUMMONS

TRUMP, in his or her capacity as executor,
Defendants. .
TO THE ABOVE-NAMED DEFENDANTS, ER.
YOU ARE HEREBY SUMMONED to answer the Complaint e e a
copy of your answer on the Plaintiff's attomeys within 20 days after the service of this summons,
exclusive of the day of service (or within 30 days after the service is complete if this summons is
not personally delivered to you within the State of New York); and in case of your failure to appear
or answer, judgment will be taken against you by default for the relief demanded in the Complaint.
Pursuant to NY CPLR §§ 503(a) and 509, Plaintiff designates as the place of trial New
York County, the county of residence of Defendant Donald J. Trump and Defendant Maryanne
Trump Barry at the time this action was commenced.
Dated: September 24, 2020 KAPLAN HECKER & FINK LLP

New York, New York
'~~
I oberta A. Kaplan
John C. Quinn
Alexander J. Rodney
New York, New York 10118
Tel: (212) 763-0883
Fax: (212) 564-0883
jquinn@kaplanhecker.com
Attorneys for Plaintiff Mary L Trump
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COUNTY OF NEW YORK
MARY L. TRUMP,
v. Index No.

MARYANNE TRUMP BARRY, and JOHN or JANE
DOE, the executor of the ESTATE OF ROBERT S. COMPLAINT

TRUMP, in his or her capacity as executor,
Defendants.
Plaintiff Mary L. Trump ("Mary"), by and through her attorneys, alleges as follows:
INTRODUCTION
1. For Donald J. Trump, his sister Maryâññe, and their late brother Robert, fraud was
not just the family business-it was a way of life. Beginning in the 1980s, these siblings took
control of the New York City real estate empire that their father Fred Sr. had built, and exploited
it to enrich themselves at the expense of everyone around them. They concocted scheme after
scheme to cheat on their swindle their business and jack rents on their low-
taxes, partners, up
income tenants.
2. This case is brought by a victim closer to home--their niece Mary. Mary's father,
and their brother, Fred Trump Jr., died in 1981 when Mary was just sixteen years old. Upon his
death, Mary inherited valuable minority interests in the family business. Donald, Maryanne, and
Robert commined to watch over her interests as fiduciaries. They lied. Rather than protect Mary's
interests, they designed and carried out a complex scheme to siphon funds away from her interests,
conceal their grift, and deceive her about the true value of what she had inherited.
3. When Mary's grandfather Fred Sr. died in 1999, Donald, Maryanne, and Robert
moved to squeeze Mary out altogether. They threatened to bankrupt Mary's interests and
terminated the health insurance that was her ñcphew-an infant with cerebral palsy-
keeping
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alive. Then they presented her with a stack of fraudulent valuations and a so-called settlement
agreement, and forced her to sign. All told, they fleeced her of tens of millions of dollars or more.
4. The fraud perpetrated by Donald, Maryanne, and Robert only began to come to
1
light following publication of an investigative report by the New York Times in October 2018.
But it began decades earlier, in secret, unbeknownst to Mary.
5. In 1981, following the death of their father, teenage Mary and her brother Fred
Trump III ("Fred III," and together with Mary, the "Minority Stakeholders") each inherited various
minority interests in the Trump property empire. Neither Mary nor her brother had more than
cursory knowledge or understanding of the nature or value of those interests or the assets to which
they related. They had no involvement in how their interests were managed and did not pmticipate
in the underlying business in any way. Instead, the Minority Stakeholders' interests were
controlled by Defendants Donald J. Trump, Maryanne Trump Barry, and Robert Trump (together,
"Defendants") and those loyal to them, who also controlled, managed, and operated the overall
business empire, and had near-exclusive access to information.
6. More specifically, because Mary was a teenager at the time of her father's death,
Irwin Durben was appointed to act as a trustee on Mary's behalf. At the time, Durben was already
an old hand in Trumpworld. Durben had been Fred Sr.'s attorney since the 1950s; a fiduciary to
various Trump family trusts; a senior executive at various corporate entities associated with the
Trump property empire, which were managed and controlled by Defendants; and Donald's
personal attorney. In short, he was irredeemably conflicted. Led primarily by Donald, Defendants
conspired with Durben and interfered with his discharge of his duties to Mary. As a result, on
1 See David Barstow, Susanne Craig & Russ Buettner, Trump Engaged in Suspect Tax Schemes as He Reaped Riches
From His Father, N.Y. TIMES, Oct. 2, 2018, https://www.nytimes.com/interactive/2018/10/02/us/politics/donald-

trump-tax-schemes-fred-trump.html.
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information and belief, Durben deferred to Donald with respect to decision-making, favored
Defendants' interests over Mary's, and ultimately acquiesced in Defendants' campaign to squeeze
her out of the family business entirely. (Durben passed away in 2016 with no obituary or publicity.)
7. By the 1990s, Defendants were maneuvering to take control of Fred Sr.'s empire.
Fred Sr. was approaching his nineties. Gripped with Alzheimer's dementia, Fred Sr. was
increasingly prone to bouts of confusion and memory loss and progressively less able to participate
in the management of the Trump family business. His decline presented Defendants with an
opportunity to position themselves to profit from his impending death. And while at first they
competed with one another-with palace intrigue reminiscent of the HBO series Succession-
ultimately Defendants worked together to consolidate their power and advance their own interests
at the expense of everyone else, including Mary.
8. In 1991, Donald secretly approached Durben and enlisted him to draft a codicil to
Fred Sr.'s will that would have put Donald in complete control of Fred Sr.'s estate. Even though
he was chief counsel to Fred Sr., Durben agreed to do Donald's bidding. When the codicil was
presented to Fred Sr. for his signature, in a moment of lucidity, Fred Sr. became suspicious and
rejected the codicil. But Maryanne finished the job, procuring a revised will that named the three
Defendants the executors of Fred Sr.'s estate (the "1991 Will").
9. Four years later, in 1995, Robert procured from Fred Sr. a sweeping power of
attorney giving Robert the power to act in Fred Sr.'s "name, place and stead." While Robert already
exercised significant power in Fred Sr.'s empire, the power of attorney gave him explicit authority
over all aspects of Fred Sr.'s affairs and business, including "real estate transactions," "banking
transactions," "business operating transactions," "estate transactions," and "records, reports, and
statements."
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10. Having secured the loyalty of Mary's trustee and cemented control over Fred Sr.'s
business empire and forthcoming estate, Defendants conspired with each other and those loyal to
them to abuse their dominant position for their own benefit, breach the trust that had been placed
in them, and defraud Mary out of what was rightfully hers.
I1. More specifically, Defendants perpetrated three fraudulent schemes against Mary.
Each scheme was a fraud in itself, but they also built on one anoths. First, Defendants fraudulently
siphoned value from Mary's interests to entities Defendants owned and controlled, while
those transfers as legitimate business transactions (the "Grift"). Second, Defendants

disgüising
fraudulently depressed the value of Mary's interests, and the net income they generated, in part
th ough fraudulent appraisals and financial statements (the "Devaluing"). Third, following Fred
Sr 's death, Defendants forced Mary to the negotiating table by threatening to bankrupt Mary's
interests and by canceling the hea!thcare policy that was keeping Fred III's infant son alive, and
once at the table Defend ante presented with a stack of frandülent valuations and fhñd M
Mary
statements and a written agreement that itselfmemorialized their fraud, and obtained her signature
(the "Squeeze-Out"). Through each of these schemes, Defendants not only deliberately defrauded
Mary out of what was rightfully hers, they also kept her in the dark about it-until now.
12. Part 1: Grift. Defendants used various methods to siphon millions of dollars from
Mary's interests to their own, and to canceâI those transfers as legitimate business transactions.
Take for example All County Building Supply & Maintenance ("All County")-a sham
corporation Defendants set up in 1992. Put simply, All County inserted itself between Trump
companies that operated real estate interests like apartment buildings and the suppliers who
provided appliances and other items to apartñients in those buildings. All County purchased the
items at pre-negotiated prices, and then issued padded invoices marking those prices way up to the
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Trump operating companies. Defendants pocketed the difference. Transaction by transaction,
money was siphoned from the Trump operating companies, which had other stakeholders like
Defendants'
Mary, and into accounts. All County was just one scam among many. (In addition, as
the New York Times reported, the All County scam was one of the ways Defendants avoided
inheritance taxes, and the marked-up invoices also helped the Trumps justify rent hikes on their
low-income tenants.)
13. At the same time, Defendants paid themselves disguised cash distributions from
entities in which Mary had an interest in the form of exorbitant management fees, consulting fees,
and salaries. They used other management entities they operated, including Trump Management,
Inc. ("Trump Management") and Apartment Mãüâgement Associates Inc. ("Apartment
Máñagemcnt"), to levy the fees, lend them apparent legitimacy, and cover their tracks.
"loans"
14. Defendants also issued from companies in which Mary had an interest to
other entities that Defendants owned and controlled. In reality, those purported loans too were just
disguised cash distributions-unlike genuine loans, they included no terms of repayment, failed to
impose an obligation to pay interest, and/or charged preferential rates untethered from those that
would be negotiated in an arm's-length transaction. Defendants engaged in various other
undisclosed and concealed self-dealing to Mary's detriment.
15. Part 2: Devaluing. As Defendants siphoned millions of dollars from Mary's
interests, they also conspired to drive down the book value and net income of those interests. To
some extent this was inherent in the Grift-by siphoning value from Mary's interests while
disguising the transfers as legitimate transactions, Defendants were already concealing and
understating the true value of the Mary's interests. But that was not enough.
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16. Enter Robert Von Ancken. Von Ancken was a New York City real estate appraiser.
"friendly"
He had worked with Defendants for decades as what might charitably be called a
appraiser: Rather than valuing an interest according to professional standards, he would inflate or
Trumps'
deflate the valuations, manipulating his methodologies and inputs, in accordance with the
desires. Donald had first enlisted Von Ancken's services as early as 1981 to avoid having to pay
taxes on his piece of Mary's father's estate. After Von Ancken proved his worth in undervalüing
family assets then, Defendants continued to conspire with Von Ancken and to use his fraudulent
appraisals to grossly understate the value of the Mary's interests. Year after year, Mary was
provided, through Durben, with false and misleading financial Matements based on Von Ancken's
valuations. In so doing, Defendants fostered the impression that everything was okay, that they
were watching over her interests.
17. By the time Fred Sr. died on June 25, 1999, Defendants had already siphoned
millions of dollars from Mary's interests and further devalued her interests with false and
misleading valuations and financial statements. Because Mary's interests were enormously
valuable, however, significant value yet remained. Indeed, even as late as 1999, Mary's interests
included at least the following:
a. Over 1,729,250 square feet of prime real estate in Brooklyn, improved by

at least 58 apartment buildings. The land was divided between two
enormous developments: a forty-acre development known as Beach Haven,
in whose land Mary had a 10% interest, and a thirty-acre development
known as Shore Haven, in whose land Mary had a 5% interest (collectively,
the "Land Interests"). Mary's brother had equal minority interests in Beach
Haven and Shore Haven, and Defendantscollectively held the remainder.
Defendants also owned and controlled the entities that operated Beach
Haven and Shore Haven pursuant to long-term leases, but importantly,
Mary would receive a share in the valuable buildings on the land when they
reverted to her as a co-owner on the expiration of the leases.
b. A group of partnerships and entities known as the Midland Associates
Group (collectively, "Midland"), which the Trump family referred to as "the

mini-empire."
Midland held at least 357 unsold apartments units in
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cooperative buildings in Brooklyn and Queens, in addition to certain cash

reserves; 1.5% of a sprawling 153-acre complex of46 buildings and 5,881
apartments in Brooklyn; approximately $10 million in receivables; and half
of the land leased to a McDonald's franchise in Brooklyn. Mary had 10%
interest in Midland (the "Midland Interests"). Again Mary's brother had
equal minority interests in Midland, and Defendants collectively held the
remainder.
Mary also had a trust that had been set up for her by her grandfather in 1976, and was a beneficiary
of her grandfather's estate (collectively, the "Trust and Estate Interests," and, together with the
Land Interests and the Midland Interests, "Mary's Interests" or "Interests").
18. Part 3: The Squeeze Out. Fred Sr. died in June 1999. Although she had no
knowledge of Defendants' fraudulent schemes at the time, she was concerned that Fred Sr. had not
been of sound mind when the 1991 Will was finalized.
19. In a series of meetings between July and October 1999, Robert tried to force Mary
to consent to probate notwithstanding her concerns. At one meeting in October 1999, at the Drake
Hotel at 56th Street and Park Avenue in New York City, for example, Robert threatened that
Defendants would bankrupt Midland if Mary did not comply with their demands, stating that
Defendants would "leave you paying taxes on money you don't have for the rest of your lives."
20. At first, Mary refused to give in, and on March 23, 2000, Mary and Fred III filed
objections to probate. At the recommendation ofDurben, the Minority Stakeholders engaged John
Barnosky as their litigation counsel. At the time, Mary trusted Durben and had no idea that he was
colluding with Defendants in their campaign to squeeze her out. Throughout the litigation and
subsequent settlement discussions, whether because he had conflicted loyalties, or because he too
was duped by Defendants, Barnosky did not keep the Minority Stakeholders fully informed of
material information and ultimately pursued and facilitated a settlement without ensuring that his
client had complete and accurate information.
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21. After Mary filed objections to probate, Defendants ratcheted up the pressure. At
Maryanne's suggestion, Defendants cut off the Minority Stakeholders' health insurance. This was
an act of unfathomable cruelty. Fred III's third child, William, had been born just hours after Fred
Sr.'s funeral. The child would later be diagnosed with cerebral palsy. At just one day old, William
started having seizures, and he remained in the neonatal intensive care unit for months afterward.
Even after William left intensive care, he required round-the-clock nursing care. More than once,
a seizure put him in a state of cardiac arrest so severe that he would not have survived without
CPR. Mary felt an unbreakable bond to her nephew William, and felt compelled to ensure his
health and safety.
22. Everyone in the Trump family was provided medical insurance from birth by
Trump Management. Consistent with that longstanding family agreement and understanding,
when William had first fallen ill, Robert had promised Fred III that the family would take care of
everything. And Fred III depended on this insurance to pay for his newborn son's crushing medical
expenses. When Defendants canceled that insurance in retaliation for the Minority Stakeholders'
objections to probate, Mary and Fred III were forced to commence a separate action against
Defendants to reinstate young William's health insurance.
23. As the pressure increased, and as attorneys' fees mounted, Defendants exploited
the opportunity to squeeze Mary out of her Interests altogether. Defendants told her they would
not resolve any of their disputes unless she relinquished her Interests completely, including the
Midland Interests and the Land Interests, which had nothing to do with the litigation.
24. During the discussions that followed, Defendants doubled down on their prior
fraudulent misrepresentations. Defendants provided Mary with estate accounting, financial
statements, and valuations riddled with deliberate falsehoods about Mary's Interests. Defendants
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misrepresented the expenses and costs associated with Mary's Interests, the net income they
generated, as well as their underlying value. Meanwhile, Defendants continued to misrepresent the
value of Fred Sr.'s estate in general-stating that it was cumulatively worth no more than thirty
million dollars.
25. Of course, given their dominant ownership and management role, Defendants had
special knowledge with respect to the operation of the empire in which Mary had Interests, the
revenue it generated and its associated costs, and its underlying value. In other words, they knew
that all of their representations and omissions were materially false and misleading. That was the
whole point.
26. In reliance on the false and misleading representations Defendants had provided,
grossly understated values were imputed separately to each of Mary's Interests-both the Estate
Interests that were at issue in probate proceedings, and the Midland and Land Interests that
Defendants were separately demanding that Mary relinquish.
27. In reliance on the same misrepresentations, documents were drawn up that, among
other things, purported to deprive Mary of her Interests at grossly fraudulent valuations (the
"Purported Agreements"). In reality, Mary's Interests were worth tens of millions of dollars more
than what Defendants represented to her and what she received.
28. The Purported Agreements set Defendants' misrepresentations and omissions in
stone. They expressly referred to, and incorporated by reference, decades of representations made
by Defendants, which the Minority Stakeholders relied on in entering the Purported Agreements.
Those documents both concluded and encapsulated the fraud.
29. In the years that followed, Defendants continued to conceal their fraud and
misconduct, which began to come to light for the first time in October 2018.
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30. In short, Mary Trump was a teenager who inherited Interests of extraordinary value
upon the premature death of her father. Her aunt and uncles-who called Mary "honeybunch"-
promised to watch over her Interests for her benefit. Instead, they swindled her. They conspired
with her trustee, maneuvered to steal her money, and lied to her about it. And in the end, they
threatened her, put her infant nephew's life at risk, and used their position of power to con her into
signing her Interests away. Mary comes to this Court to right these wrongs. By this action, she
asserts the following claims:
Count One. Fraudulent misrepresentation;
Count Two. Fraudulent concealment;
Count Three. Fraudulent inducement;
Count Four. Negligent misrepresentation;
Count Five. Civil conspiracy to commit fraudulent misrepresentation and concealment;
Count Six. Civil conspiracy to commit fraudulent inducement;
Count Seven. Breach of fiduciary duty; and
Count Eight. Aiding and abetting a breach of fiduciary duty.
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THE PARTIES
3L Plaintiff Mary L. Trump is a clinical psychologist, businessperson, and author. She
is the granddaughtcr of Fred Sr., a property developer and landlord in New York's outer boroughs.
More specifically, she is the daughter of Fred Sr.'s eldest son, Fred Jr., who died in 1981 at the
age of 42, when Mary was 16 years old. Mary is a resident of the State of New York.
32. Defendant Donald J. Trump ("Donald") was Fred Sr.'s fourth child and second son.
He is Mary's uncle. He currently serves as the President of the United States, but he is sued here
only in his personal capacity arising from his acts and omissions between 1981 and 2001-15
years before he assumed that office. Together with his siblings Maryanne and Robert, Donald
served as co-executor of the Last Will and Testament of Fred C. Trump and ofthe Last Will and
Testament of Mary Anne Trump; trustee of the 1976 trust that Mary's grandfather established on
her behalf; shareholder, officer, and director of numerous Trump family corporations, including
Apartment Management; co-owner of All County; partner in Midland; and co-owner of certain
land interests and the ground leases over those interests, including those at Beach Haven and Shore
Haven. He is a resident ofthe State ofNew York.
33. Defendant Maryanne Trump Barry ("Maryanne") was Fred Sr.'s first-born child.
She is Mary's aunt. Together with her brothers Donald and Robert, Maryanne served as co-
executor of the Last Will and Testament of Fred C. Trump and of the Last Will and Testament of
Mary Anne Trump; trustee of the 1976 trust that Mary's grandfather established on her behalf;
shareholder, officer, and director of numerous Trump family corporations, including Apartment
Management; co-owner of All County; partner in Midland; and co-owner of certain land interests
and the ground leases over those interests, incInding those at Beach Haven and Shore Haven. From
1999 to 2019, Maryanne served as a judge on the U.S. Court of Appeals for the Third Circuit. She
retired in April 2019, following an investigation into whether she violated rules ofjudicial conduct
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2
by participating in various fraudulent schemes revealed by the New York Times in October 2018.
Maryanne is a resident of the State of New Yark.
34. The late Robert S. Trump ("Robert") was Fred Sr.'s fifth child and third son. He
was Mary's uncle. Robert was a New York businessperson and real estate developer who passed
away on August 15,2020. Robert dedicated much of his life to the family business. Between 1980
and 1991, Robert worked as a vice president of The Trump Organization, which Donald headed.
In 1991, he transferred to his father's business, Trump Management. Together with his siblings
Donald and Maryanne, Robert served as co-executor of the Last Will and Testament of Fred C.
Trump and of the Last Will and Testament of Mary Anne Trump; trustee of the 1976 trust that
Mary's grandfather established on her behalf; shareholder, officer, and director of numerous
Trump family corporations, including Apartment Management; co-owner and Chief Executive of
All County; partner in Midland; and co-owner of certain land interests and the ground leases over
those interests, including those at Beach Haven and Shore Haven. Robert was a resident of the
State ofNew York. Robert passed away on August 15, 2020. Accordingly, Mary's claims against
Robert herein are asserted against John or Jane Doe, the yet-to-be-named executor of his estate.
JURY DEMAND
35. Plaintiff Mary L. Trump hereby demands a trial by jury.
JURISDICTION & VENUE
36. This Court has jurisdiction pursuant to NY CPLR §§ 301 and 302.
37. Venue is proper in this county pursuant to NY CPLR §§ 503 and 509.
2
Russ Buettner & Susanne Craig, Retiring as Judge, Trump's Sister Ends Court Inquily into Her Role in Tax Dodges,
N.Y. TrMES, Apr. 10, 2019, https://www.nytimes.com/2019/04/10/us/maryanne-trump-bmTy-misconduct-
inquiry.html.
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FACTUAL ALLEGATIONS
I. MARY'S INTERESTS IN THE TRUMP EMPIRE
38. In 1927, Mary's great-grandmother, Elizabeth Trump ("Elizabeth"), and her son,
Mary's grandfather, Fred Sr., established E. Trump & Son, Inc. Together they constructed
hundreds of houses in Brooklyn and Queens.
39. Elizabeth passed away on June 6, 1966, leaving certain interests to Mary's father,
which later passed to Mary, including the Land Interests, as detailed further below.
40. Following the death of his mother, Fred Sr. expanded the property empire, building
and managing a number of major real estate developments in New York City, including prominent
developments and apartment buildings in Queens and Brooklyn. Over the course of the next three
decades, he amassed a vast fortune.
41. Fred Sr. had five children: Maryanne Trump Barry; Mary's late father Fred Trump
Jr.; Elizabeth Trump Grau; Donald J. Trump; and Robert Trump, who passed away in August
2020.
42. Mary's father, Fred Jr., died in 1981 at the age of 42, when she was 16 years old.
Mary inherited certain interests from her father, including the Midland Interests, which were held
in trust on her behalf by Defendants and their co-conspirator Durben following her father's death.
43. Mary's grandfather, Fred Sr., died on June 25, 1999. Mary was a beneficiary of his
estate and also the beneficiary of a trust he had established on her behalf. As a result, on his death,
she inherited and was due certain additional Estate and Trust Interests.
44. Accordingly, following Fred Sr.'s death, Mary was the beneficial owner of three
categories of interests in the Trump property empire: (1) the Land Interests from her great-
grandmother; (2) the Midland Interests from her father; and (3) the Estate and Trust Interests from
her grandfather. Each of these sets oflnterests was enormously valuable, as detailed below.
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A. The Land Interests: Beach Haven and Shore Haven
45. On June 8, 1960, Mary's great-grandmother Elizabeth executed a will providing
for the establishment of a trust in favor of her grandchildren, including Mary's father Fred Jr.
Among other things, the fee interests in the land underlying Beach Haven and Shore Haven were
placed in the trust for the grandchildren, with the income from those interests flowing to Fred Sr.
during his life. Elizabeth Trump further directed that her son, Fred Sr., would be the measuring
life of that trust, but provided that Fred Jr.'s interests in the trust should be distributed to Mary and
Fred III if their father died before Fred Sr.
46. Accordingly, pursuant to Elizabeth's trust, upon the death of Fred Jr., Mary and her
brother inherited equal shares of their father's fee interests in the land underlying Beach Haven
and Shore Haven. Mary's share was 10% of the land underlying Beach Haven and 5% of the land
underlying Shore Haven. Mary's brother had the same shares. And Defendants (together with their
sister Elizabeth Trump Grau) owned the remainder.
47. Together, these were the crown jewels in the Trump family's empire.
48. Beach Haven was a complex in Coney Island, Brooklyn spanning over forty acres
improved with at least twenty-six buildings, in addition to various parcels of vacant land.
49. Shore Haven was a complex in Bensonhurst, Brooklyn spanning more than thirty
acres improved by over thirty-two six-story buildings and a shopping center.
50. Back in 1948, Elizabeth and Fred Sr. leased the land to entities controlled, operated,
and ultimately owned by Defendants. The ground lease was for a period of 99 years.
51. A ground lease is an arrangement in which the lessee develops a piece of property
owned by the lessor, including by adding buildings and other improvements, during a lease period
(typically 99 years), after which all buildings and improvements revert to the lessor. Thus, the
lessor's interest in a ground lease includes not just the cash streams paid by the lessee under the
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terms of the lease, but also, significantly, a reversion interest in the appreciated land as well as the
improvements that will transfer to the lessor at the end of the lease period. Here, Defendants
extensively developed and improved the land with the 58 buildings alleged above.
52. As a minority owner of the land, Mary had an interest in the stream of payments to
be made by the lessees (at least following Fred Sr 's death). Importantly, however, she also had a
reversion interest in the appreciated land itself and all of the buildings and improvements that had
been developed upon it, which would be returned to her at the end of the lease period.
53. In the meantime, Defendants were on both sides of the lease-as majority lessors
of the land and as lessees, who operated the buildings. As alleged below, Defendants were
consistently, mmpañtly, dishonest with Mary about her interest and its extraordinary value.
"Mini-Empire"
B. The Midland Interests: the
54. Through her father Fred Jr 's estate, Mary also inherited a combiñêd 10% interest
in a group of partnerships and entities known as the Midland Associates G oup, which the Trump
mini-empire."
family referred to as "the Mary's interest in Midland was held in trust, with
Defendants'
co-conspirator Durben serving as trustee, and Mary knew very little about it.
55. Midland was made up of four entities: Midland Ass0ciates, LLC; Park Briar
Associates, LLC ("Park Briar"); Highlander Hall, Inc.; and Coronet Hall, Inc. Each ofthese entities
owned certain sponsor corporations that themselves held, among other interests, unsold
cooperative shares in various apartment buildings. Mary held a 10% interest in each of the four
Midland entities.
56. Among other valuable assets, Midland held interests relating to hundreds of
apartments in at least seven apartaiêñt buildings in Brooklyn and Queens that were converted by
Fred Sr. to cooperative ownership in the 1980s. Some of the apartments in these buildings were
sold to the cooperative, whereas others were unsold and rented out to tenants by Defendants.
/
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57. Thus, Midland generated revenue for Defendants and the Minority Stakeholders in
three principal ways: through the sales of sponsor apartments, through rentals of unsold units, and
through issuing loans. Mary's interest in Midland entitled her to portions of each of these revenue
streams.
58. In total, at the time of Fred Sr.'s death in 1999, Midland held at least the following
valuable entities and assets:
a. Lincoln Shore Apartments and Wedgewood Hall Property, each sponsors of
cooperative housing in Brooklyn, NY; holders of unsold shares relating to 60
apartment units and 40 apartment units, respectively; and lessors to various
tenants;
b. Highlander Hall, Park Briar Property, Sunnyside Towers, Coronet Hall, and
Saxony Hall Property, each sponsors of cooperative housing in Queens, NY;
holders of unsold shares relating to 54 apartment units, 59 apartment units,
54 apartment units, 62 apartment units, and 28 apartment units, respectively;
and lessors to various tenants;
c. A 1.4583% interest in Starrett City Associates, LP, which in turn held Spring
Creek Towers, a sprawling 153-acre complex of 46 buildings and 5,881
apartments in Brooklyn, NY. Starrett City was the largest federally subsidized
housing project in the nation and ultimately sold in 2018 for over $900 million;
d. A 50% interest in land leased to a McDonald's Franchise at 606 Neptune
Avenue, Brooklyn, NY 11224;
e. $7,187,200 and $2,743,000 in mortgage and notes receivable, respectively; and
f. Various service contracts.
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59. As alleged below, Defendants diluted the value of the Midland Interests through
grift and self-dealing, depressed its book value and the net income it generated, and lied to Mary
about its worth.
C. The Trust and Estate Interests
60. In 1976, Fred Sr. established irrevocable trusts then worth $400,000 for each of his
grandchildren, including Fred III and Mary.
61. The designated trustees of that trust were Defendants and attorney Matthew J. Tosti
Defendants'
(followed by co-conspirator Durben as successor to Tosti on Tosti's death).
62. Finally, Mary was herself a beneficiary of Fred Sr.'s estate.
DEFENDANTS'
IL FIDUCIARY DUTIES TO MARY
63. Defendants and Durben controlled, operated, and dominatad each of Mary's
Interests alleged above, and accordingly owed her fiduciary duties to protect her Interests.
64. First, Defendants were majority co-owners of Land Interests at Beach Haven and
Shore Haven, in which Mary had interests; majority partners, members, and owners in Midland,
in which Mary had an interest; trustees (together with Durben) of the irrevocable trust created by
Fred Sr., of which Mary was the beneficiary; and Co-Executors of the Last Will and Testament of
Fred Sr., of which Mary was a beneficiary. In each of these capacities, Defendants owed Mary a
fiduciary duty of undivided loyalty, including a duty to protect her Interests.
Defendants'
65. In addition, co-conspirator Durben, whom the Defendants co-opted
and controlled, was a trustee of Mary's Land Interests, Midland Interests, and her Trust Interests.
In each of these capacities, he too owed Mary a fiduciary duty of undivided loyalty.
66. and in each of Mary's Interests was part of the larger Trump-
Second, addition,
bucinace businecc
family Defendants controlled and dominated the operation of that by virtue of
their roles in the following entities, from which Mary was excluded:
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a. as shareholders, officers, and directors of Apartment Management;
b. as shareholders, officers, and directors of Trump Management;
c. as co-owners and managers of All County, of which Robert Trump was also the
CEO;
d. as majority owners and operators of Beach Haven and Shore Haven; and
e. as majority owners and operators of Midland.
67. Third, as alleged above, Maryanne prepared and procured Fred Sr.'s revised 1991
Will after Fred Sr. refused to sign a codicil drafted by Durben that would have put Donald in
control of Fred Sr.'s estate. Maryanne, along with Donald and Robert, appointed themselves co-
executors of the 1991 Will. In addition, as alleged above, Robert procured Fred Sr.'s power of
attorney in 1995, which enabled him to exercise powers over all aspects of Fred Sr.'s affairs and
businesses, including respecting Mary's Interests.
Ill. DEFENDANTS' FRAUDULENT SCHEME
A. TheGrift
68. Between 1981 and 2001, Defendants siphoned millions of dollars from Mary's
Interests into entities that Defendants controlled, while concealing those transfers as legitimate
business transactions.
69. One example was All County, a scam first reported by The New York Times in
October 2018. All County was a sham corporation that Defendants set up in 1992-it was a shell
without any corporate offices. It existed for the purpose of secretly extracting funds and assets
from Trump family-owned properties and entities that had other stakeholders, including Midland,
and transferring those funds and assets to Defendants and those loyal to them.
70. Before All County was established, Trump entities like Midland paid vendors
directly for maintenance, upkeep, and supplies on the Trump properties. Defendants set up All
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County and inserted it between the Trump entities and the vendors. All County paid vendors for
the same maintanance services and supplies, at the same rate. All County then issued padded
invoices to the Trump entities (including entities in which Mary had an interest) marking the
purchases way up. The owners of All County-Defendants and their cousin Walter-then
pocketed the differcñce.
71. Defendants then prepa ed financial statcmcats that disguised their grift as genuine
business expenses, and thereby hid them from Mary.
72. All County and other similar schemes siphoned significant funds away from Mary's
Midland Interests, as well as the Estate Interests.
73. All County and schemes like it were not the only tool that Defendants used to
benefit themselves at the expense of Mary's Interests. For example, as The New York Times
reported in October 2018, Defendants also used the managcmcñt entities Trump Management and
Apartmcñt Mañagement, which they owned and of which they were each officers and directors, to
siphon additional value from Mary's Interests, including Midland.
74. Before 1994, buildings controlled by Defendants paid millions of dollars in
püiported mañagcment fees, including consulting fees and salaries, via Trump Management-$6.8
million in 1993 alone. Beginning in January 1994, Apartment Management began charging and
collecting those fees.
75. The inañagement fees collected by Trump Management and later Apartment
Management were massively inflated and overstated. To a significant extent, therefore, the
"management" "mainteñañce"
and fees paid did not accurately reflect the provision of services of
value. Indeed, as with All County, Trump Managcmcñt and Apartment Management were just
another means by which Defendants carried out their grift and siphoñêd money from Mary's
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Interests into their own accounts. Defendants paid themselves fraudulent "consulting" and
"management" fees through other entities as well.
76. Defendants also issued "loans" to other entities that they controlled. These loans,
however, were simply another means by which Defendants diverted cash to benefit themselves:
unlike genuine loans, they included no repayment terms, they imposed no obligation to pay
interest, or they charged preferential rates far more favorable to the borrower than those that would
be negotiated at arms' -length. For example, in 1990, 1993, 1997, and 1998, Coronet Hall Property,
a division of Coronet Hall, Inc. (one ofthe Midland entities), was owed a total of$1,723,640 in
non-interest-bearing advances without definite terms as to repayment.
77. Defendants were aware, at the time that they were using these entities to redirect
funds into their own pockets and disguise those transfers, and indeed Defendants fully intended,
that their actions were in fact transfers of value from Mary's Interests to benefit themselves.
B. The Devaluing
78. For years, Defendants repeatedly provided Mary, through her so-called trustee
Durben, with numerous financial statements to create the false impression that Defendants were
protecting her Interests. In fact, the opposite was true. Rather than presenting Mary with a fair and
honest account of her Interests, Defendants knowingly and fraudulently understated their true
value, including their book value and net income. Through manipulation, they also further drove
down the actual value of those Interests.
1. Defendants Obtained Lowball Appraisals
79. Defendants also devalued Mary's Interests by negotiating and procuring fraudulent
appraisals from their co-conspirator Von Ancken.
80. As alleged above, Von Ancken was a purportedly independent but in fact "friendly"
appraiser who had performed favorable valuations for Defendants after Fred Jr.'s death. Pleased
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with the services that he had provided at that time, Defendants rehired Von Ancken to conduct
appraisals of Fred Sr 's real estate holdings, including those relating to Mary's Interests.
81. As The New York Times reported in October 2018, rather than performing objective
valuations of the Trump family's assets according to applicable professional standards, Von
Ancken inflated or deflated vahmrinns based on the purposes for which Defendants requested those
valuations.
Defendants'
82. Von Ancken's valuations fluctuated according to requested
specifications. For example, in 1992, when Fred Sr. decided to donate Patio Gardens, one of his
least profitable complexes, and take a charitable tax deduction, Von Ancken provided an inflated
assessment: $34 m minn, or $61.90 per square foot. providing such an inflated appraisal, Von
By
Ancken boosted the tax dedudion Fred Sr. claimed on his tax return.
83. In sharp contrast, in 1995, Von Ancken priced Beach Haven and Shore Haven, in
which Mary had reversion interests, and which were much more lucrative and boasted five times
as many apartments as Patio Gardens, at a mere $24 million, or $11.01 per square foot. As of 2020,
the current assessed value of Beach Haven and Shore Haven, which is typically far lower than
actual fair market value, was over ten times that amount.
84. Von Ancken's false valuations were themselves based on another set of
misctatements: false and misleading data and other management information that Defendants had
provided to Von Ancken for use in his valuations.
85. Recent court filings and public reporting have revealed that Donald in particular
knows full well how to improperly inflate or deflate the value of real estate assets to suit his
purposes. Indeed, in March 2019, the Office of New York State Attorney General opened a civil
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investigation to determine whether The Trump Organization and Donald improperly inflated the
benefits.3
value of Donald's assets to secure loans and obtain economic and tax
86. The New York Attorney General subpoeñâed documents from The Trump
Organization to investigate wildly inflated valuations of several properties, including Seven
Springs, a parcel of real property in Westchester County, New York. In 1995, Seven Springs LLC,
a company controlled by The Trump Organization, purchased Seven Springs for $7.5 million.
Between 1996 and 2014, Donald made various efforts to develop Seven Springs as a golf course,
or to subdivide it for residential development. When those efforts all failed, Donald granted a
conservation easement over 158 acres of Seven Springs in order to exploit an income tax deduction
based on the purported lost development value of the property on account of his granting the
easement.
87. In 2015, to maximize his claimed tax deduction, Donald obtained improperly
inflated valuations for his Seven Springs property. Even though Donald bought the property for
only $7.5 million and did not develop it, he claimed the property was suddenly worth $56.5 million
value"
as of December 1, 2015 and that the "appraised fair market of the conservation easement
was $21.1 million on tax forms submitted to the IRS.
88. Additionally, as the Washiñgton Post reported in 2019, Donald routinely sent
Condition"
lenders "Statements of Financial concerning his properties, debts, and alleged net
flawed" "overvalued"
worth that "were deeply because they assets, "omitted properties that carried
debts" wrong."4
big and included "key numbers [that] were For example, according to the Post,
Donald's 2011 financial statement claimed that he had 55 home lots to sell at a golf course in
3
New York v. The Trump Organization et al., Affirmation of Matthew Colangelo in Support of Motion to Compel
Compliance, No. 451685/2020 (N.Y. Sup. Ct., Aug. 24, 2020), 6-9.
4 David A. rahi-ciithold & L·-¤±== O'Connell, How Donald Trwnp inflated his net worth to lenders and investors,
WAsH. POST, Mar. 28, 2019, https://wapo.st/2DsxZyo.
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Southem California for at least $3 million each. According to city records, however, Donald in
fact had only 31 lots available to sell and claimed credit for 24 lots (and over $72 million in
expected revenue) that he did not actually have. Donald made similar misrepresentations about a
Virginia vineyard (overstating its size by 800 acres).
89. In 2019, Michael Cohen, Donald's former lawyer and "fixer"-who pleaded guilty
to various federal crimes in connection with his work for Donald, including tax evasion and making
false statements to a bank-named Donald and other Organization executives as knowing

Trump
participants in a scheme to evade campaign finance restrictions by mischaracterizing the payments
2017.5
as legal expenses on The Trump Organization's books in 2016 and Cohen also testified to
Congress that it was common for The Trump Organization to submit falsified f nancial records
loans.6
when the company applied for
90. After the New York Times investigation in 2018, the Washiñ,gton Post reported that
The Trump Organization had claimed, in 2012, that it had purchased certain outstanding debt
Chicago.7
relating to the Trump Intemational Hotel and Tower in The debt was listed on Trump
Organization books as a loan from one Trump Organization subsidiary to another. Despite
supposedly holding a multimillion-dollar loan, Donald listed the subsidiary that purchased the debt
worthless"
as being "practically on his financial statcmcñts. There is no indication that The Trump
Organization treated the forgiven debt as taxable income, as required under tax law.
5 See Dkt. 2, at 11-18 ¶¶ 24-42, United States v. Cohen, No. 18-cr-602

Info==tinn, (WHP) (S.D.N.Y. Aug. 21, 2018);
see also Rebecca Ballhaus & Joe Palazzolo, Michael Cohen Details Allegana;;s of Trwnp's Role in Hush-Money
Scheme, WALL ST. J., Feb. 27, 2019, https://on.wsj.com/3fp2jap.
6 to President Donald Trump: Hearing Before the H. Comrn. on
Hearing with Michael Cohen, Former Attorney
Oversight and Reform, 116th Cong. 1 (Feb. 27, 2019).
7 David A. FahraithGid & Jonathan O'Connell, After selling off his father's properties, Trump embraced unorthodox
strategies to expand his empire, WASH. POST, Oct. 8, 2018, https://wapo.st/35iWald.
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2. Defendants Cooked the Books
91. Beginning at least as early as the late 1980s or early 1990s, Defendants and those
loyal to them knowingly and fraudulently understated the value of Mary's Interests on various
financial statements, tax returns, and other documents. Defendants provided those documents to
Mary, through Durben, as purportedly authentic depictions of her Midland, Land, and Estate
Interests.
92. As alleged above, some of the fraudulent misstatements related to All County and
similar schemes. For example, the 1992 and I993 financial statements for Sunnyside Towers, a
division of one of the Midland entities, stated that Sunnyside "purchases equipment and supplies
from All County Building Supply & Maintenance, Co., Inc." According to the financial statements,
in 1993 (the first year of All County's existence), Sunnyside Towers claimed it purchased $7,992
of supplies from All County. On a sheet titled "Statements of Revenues and Expenses," the
financial statements then listed "Repairs & maintenance-schedule" as an expense. The financial
statements contained "Supporting Schedules" that broke out the "Total repairs and maintenance
expenses" into specific categories, such as "Painting-apartments," "Painting supplies," "Janitorial
supplies," "Repair materials," and "Plumbing repairs & supplies."
93. Like the 1992 and 1993 financial statements, the 1997 and. 1998 Sunnyside
financial statements again stated that Sunnyside "purchases equipment and supplies from All
County Building Supply & Maintenance, Co., Inc," and contained "Statements of Revenues and
Expenses" that listed certain amounts for "Repairs & maintenance."
94. Each ofthese references to "repairs," "maintenance," and "supplies" in the financial
statements was a fraudulent misrepresentation. In fact, significant sums paid to All County were
not spent on "repairs" and "maintenance," but were simply transfers to Defendants through padded
invoices issued by All County, in the manner alleged above.
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95. The financial st-tements for the other Midland properties-such as Coronet Hall
Property, Highlander Hall, Lincoln Shore Apartments, Park Briar Associates, L.L.C., Saxony Hall,
maintenance"
and Wedgewood--contained similar misstatements of "repair and expenses that, in
Defendants'
material part, were not spent on repair and maintenance, but were transfers to line
pockets.
96. DefenAnts also created and provided Mary with schedules of cash disbursements
that colitaliled numerous fraudulent transfers. The 1993 cash disbursemcats (the first year in which
All County was operational) listed various transfers to All County and specified the claimed
purposes for those transfers. For example, the 1993 Highlander Hall record of cash disbursements
REPA"
showed a $224.09 payment to All County for "DISHWASH, STOVE, REFR, PARTS &
and two $504.22 and $664.77 payments to All County for "PLUMBING & HEATING REP. &
SUP."
Those claimed purposes were similarly fraudulent and concealed what were in material part
simply transfers of cash to Defendants.
97. In addition, because the financial statements hid the transfers to Defendants and
"repairs," "maintenance," "expenses,"

fraudulently portrayed those transfers as or the financial
"expenses" income"
statements fraudulently overstated the and understated the "net on the
properties. This was because net income on the financial statements was calculated as revenues
less expenses. If Defendants had correctly identified those transfers on their financial statements,
"expenses,"
rather than fraudulently disguising them as then the net income on the properties
would have been much higher.
98. Those misstatements were material to Mary, as a suketantial comp0ñent ofthe value
ofthe properties was the net incese and cash flow from the prõperties. By fraudulently overstating
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the Midland properties' expenses and understating the Midland properties' net income, Defendants
fraudulently understated the value of the Midland properties.
99. Similarly, Defendants disguised their grift via Trump Management and Apartment
Management by labeling those transfers as "management," "maintenance," consulting fees, and
salaries, to make them appear to be genuine business transactions. Defendants' use of those labels
made the financials misleading and further reduced the net profit generated by and book value of
Mary's Interests.
100. As alleged above, Defendants also fraudulently labeled certain transfers from the
Trump properties, including the Midland properties in which Mary had an interest, as payments
for "consulting" and "management" fees and salaries, despite those fees and salaries paying for
services oflittle or no value.
101. For example, Donald was a salaried employee, property manager, landlord, banker,
and consultant to the Trump property empire. Donald was also responsible for selling certain
Starrett City shares, which resulted in today's equivalent of $1 million in "consulting fees." By
charging the Trump properties these fees, Defendants not only siphoned value from Mary's
Interests, but also overstated the expenses of these properties, including the Midland properties in
which Mary had an interest, and thereby understated their profitability and true value.
102. Similarly, as alleged above, Defendants disguised cash distributions as "loans." But
unlike genuine loans they were non-interest-bearing advances without definite terms as to
repayment. By failing to charge appropriate rates of interest on loans, and make sure they were
paid back, Defendants reduced the net income generated by Mary's Interests.
103. Defendants also provided to Mary numerous financial statements, general ledgers,
and tax returns for 1989, 1990, 1991, 1992, and 1993 for Beach Haven, Shore Haven, and various
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associated entities and divisions of those entities. Defendants provided these financial statements
to Mary as supposedly authentic depictions of the value of her Land Interests. On information and
belief, however, each of these financial statements and other financial documents contained similar
false representations of the value of Beach Haven and Shore Haven. In so doing, Defendants
thereby materially understated the value of the Mary's reversion interest as well-i.e., the value
of the appreciated land and improvements that would be returned to her at the conclusion of the
lease period.
3. Defendants Ducked Sales
104. Even beyond fraudulently understating the value of Mary's Interests, Defendants
also conspired to drive down the true value of those Interests. For example, Defendants depressed
Midland's book value by deliberately failing to sell certain cooperative units in which Midland
held shares.
I 05. The Midland entities generated revenue in part through the sale of cooperative
apartments that they held as the sponsor of the cooperative ("sponsor units"). Defendants
artificially devalued the Midland assets by refusing to sell the sponsor units with respect to which
Midland held shares. Indeed, in 1998 and 1999 combined, only three units were sold. In 2000, the
Midland entities collectively still held 357 unsold sponsor units.
106. Defendants' reason was straightforward enough. Defendants had ascribed an
artificially low value to Midland. Selling sponsor units to buyers in an open market would have
generated sales price information, and thus would have created evidence that Defendants had
undervalued Midland. By refusing to sell the sponsor units, Defendants avoided creating a paper
trail.
107. But by refusing to sell the sponsor units, Defendants also failed to generate
proceeds of sale in connection with the Midland units that they otherwise would have generated if
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the sponsor units had been sold. Those sales proceeds from apartment sales were part of the value
of the Midland assets and thus part of Mary's Midland Interests. While some portion of the unsold
sponsor units were rented, Defendants' siphoning efforts (alleged above) depleted the net income
generated for Mary by such rentals by artificially inflating the maintenance expenses charged to
them.
I 08. In other words, by refusing to sell apartments and opting instead to rent them with
inflated expenses, Defendants intentionally drove down the book value of Mary's Interests. And
by failing to generate transactional sales data, Defendants compounded their undervaluing of
Midland and carefully avoided putting Mary and others on notice that the Trump properties were
undervalued.
C. The Squeeze Out
109. Fred Sr. passed away in June 1999. When Fred Sr. died, Mary had some concerns
about the 1991 Will. Although Mary did not have knowledge ofDefendants' fraud at the time (and
had no reason to know it), she believed that Fred Sr. had not been of sound mind when the will
was finalized.
II 0. A few days after Fred Sr. died, Mary received a call from Robert. He had called to
convey a simple message on Defendants' behalf: It was time for Mary to relinquish her Interests.
Over the next month or so, he hectored Mary with daily calls reiterating the same message: "Cash
in your chips, Honeybunch."
Ill. When Mary held out, Robert demanded to meet in person. They had a series of
meetings between July and October 1999 in which Robert tried to procure Mary's consent to
probate and relinquish her Interests.
112. In their final meeting that October, in the bar of the Drake Hotel at 56th Street and
Park Avenue in New York City, Robert made his most concrete and explicit threat. If Mary did
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not comply with their demands, including consenting to probate, Defendants would bankrupt
Midland and "leave you paying taxes on money you don't have for the rest of your lives."
113. Nevertheless, Mary persisted. On March 23, 2000, Mary and Fred III filed
objections to probate, contesting the validity of the 1991 Will.
114. As alleged above, the Minority Stakeholders engaged John Barnosky as their
litigation counsel, at the recommendation ofDefendants' co-conspirator Durben. At the time, Mary
trusted Durben and had no idea that he and Defendants were conspiring to defraud her and squeeze
her out. Whether because of conflicted loyalties or because he was duped by Defendants as well,
throughout the litigation and settlement discussions, Bamosky did not keep the Minority
Stakeholders fully informed of material information and pursued a settlement without ensuring
that he and his client had complete and accurate information.
115. Defendants' response to the objections filed by Mary and her brother was swift and
vicious. As alleged above, Fred III's third child, William, had been born just hours after Fred Sr.'s
funeral. Forty-eight hours after baby William was born, he turned blue in his mother's arms, his
body stiffening and shaking uncontrollably. It was the first of many devastating seizures to come.
116. William spent months in neonatal intensive care, where the seizures and severe
illness continued. Brain scans, spinal taps, blood tests and visits to three hospitals followed. And
even after William left intensive care, he required round-the-clock nursing care. The experience
was harrowing, and the expenses were crushing.
117. Like every member of the Trump family, William had health insurance from birth
through Trump Management. But when the Minority Stakeholders filed their objections to probate,
Defendants, acting at Maryanne's suggestion, ripped that health insurance away and put the child's
life at risk. In December 2000, Donald acknowledged that Defendants had terminated the infant's
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medical coverage to retaliate against Mary and her brother, telling the New York Daily News:
"When [the Minority Stakeholders] sued us, we said: 'Why should we give him medical
coverage?'" When asked whether he thought cutting their coverage could appear cold-hearted in
8
light of the baby's medical condition, Donald dismissed the idea, remarking, "I can't help that."
118. Mary was devastated by this act of retaliation against a newborn. She became
increasingly desperate, telling the press that "William is my father's grandson. He is as much a
part of that family as anybody else. He desperately needs extra care." William's mother echoed
what the Minority Stakeholders were feeling: Defendants' retaliation was "so shocking, so
disappointing and so vindictive."
119. As alleged above, Mary and Fred III started another action against Defendants to
reinstate the health insurance and protect young William. Barnosky's fees piled up.
120. As the pressure mounted, Defendants exploited the opportunity to squeeze Mary
out of her Interests altogether: they told the Mary that they would only settle the litigation if she
agreed to be bought out of her Interests altogether, including the Midland Interests and the Land
Interests, which were not even at stake in the litigation.
121. In the discussions that followed, Defendants doubled down on their prior fraudulent
misrepresentations and compounded them.
1. Defendants Grossly Understated the Value of Mary's Midland

Interests
122. In a series of discussions concerning the value of Mary's Midland Interests,
Defendants repeatedly and fraudulently understated their fair market value.
8 Inside Trumps" Bitter Battle: Nephew"s Ailing Baby Caught in The Middle, N.Y. DAILY NEWS, Dec. 19, 2000,
https://www.nydailynews.com/archives/news/trumps-bitter-battle-nephew-ailing-baby-caught-middle-article-
1.888562.
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123. To take one example, Defendants fraudulently understated the value of Starrett
City, an enormous Brooklyn housing development that later sold for nearly a billion dollars.
Specifically, on December 8, 2000, Patricia C. Marcin, one of Mary's attorneys, requested certain
information from Stephen J. Schwartz, counsel for the Defendants, in connection with the probate
proceedings. Marcin asked Schwartz specifically for an appraisal of Fred Sr.'s "partnership interest
in [Starrett] City."
124. On December 8, 2000, Schwartz responded to Marcin, "Starrett City was valued at
a nominal amount based on information obtained from management." This "nominal" valuation,
which was based solely "on information obtained from management," was fraudulently
understated. Defendants, as "management," made this misrepresentation, together with the false
and misleading representations on which it was based, to Mary with the intent that she rely on it
for purposes of undervaluing her own interest in the property.
125. According to the New York Times investigation, Starrett City in reality had such a
high value that its subsequent sale led to a massive windfall for Defendants. Despite the "nominal"
valuation provided by Schwartz on December 8, 2000, Starrett City was sold in 2018 for $905
million, of which Donald personally received at least $16 million.
126. In addition, on December 21, 1999, Defendants provided Mary with various
financial statements, tax returns, and schedules of cash disbursements for 1989-1993 for the
Midland entities, which compounded the prior fraudulent misrepresentations and omissions
alleged above.
127. The Purported Agreements themselves memorialize myriad fraudulent
misrepresentations concerning the value of Mary's Midland Interests. For example, according to
the Purported Agreements, Mary and her brother, Fred Trump III, requested that Defendants
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'
provide her with information concerning their ownership interests in Midland. In response,
Defendants provided Mary with documents including income tax returns, financial statements,
partnership tax returns, lists of sold and unsold units, lists of mortgages and notes receivable, and
a list of cooperative apartment ownership interests for 1997-1999 for the Midland entities, all of
which were undervalued on account of all the schemes and misrepresentations outlined above. The
Purported Agreements incorporated by reference each of these documents containing fraudulent
misrepresentations of Midland's value.
128. With these fraudulent documents, Defendants deliberately deceived Mary into
believing that the fair market value of her I 0% interest in Midland was far less than its true value.
In reasonable reliance on Defendants' fraudulent undervaluations, Mary relinquished the Midland
Interests at a grossly understated value. If Defendants had provided accurate information
concerning her Midland Interests, Mary would not have accepted these terms.
2. Defendants Grossly Understated the Value of Mary's Land Interests
129. Defendants made similar misrepresentations about Mary's Land Interests.
130. To take one example, the Purported Agreements fundamentally misrepresented the
nature of the Land Interests by portraying those interests simply as rights to cash streams from
"ground leases." More specifically, an "Agreement and Stipulation made April I 0, 200 I" made
reference to Mary's "right, title and interest to the 'ground leases' affecting the real property," i.e.,
Beach Haven and Shore Haven. Yet, as alleged above, Mary's interest was far broader and more
valuable: she had an interest in the land underlying those developments, but she also had a
reversion interest in the buildings themselves, not just an interest in the ground leases. Defendants
thus took advantage of their domination and control over Mary's affairs to portray her Land
Interests as far less valuable than they in fact were.
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'
131. During their discussions, Defendants also provided Mary with numerous financial
statements, appraisals, and other valuation documents concerning her Land Interests. Many if not
all of them were fraudulent.
132. For example, on December 21, 1999, Defendants provided Mary with numerous
financial statements, general ledgers, and tax returns for 1989, 1990, 1991, 1992, and 1993 for
Beach Haven, Shore Haven, and various associated entities and divisions of those entities. Those
statements contained fraudulent undervaluations of the value of the Land Interests. They included
valuations from Von Ancken, who valued the Beach Haven and Shore Haven developments,
despite being "the crown jewels of Fred Trump's empire," at a mere $23 million, or $11.01 per
square foot-far lower than their true market value. Indeed, as of 2020, their current assessed
value, which is typically far lower than fair market value, was over ten times that amount.
133. In addition, Mary, through her lawyer Barnosky, was provided with a May 18, 2000
letter addressed from Von Ancken to Robert that provided Von Ancken's valuation of the
reversion interest in the Shore Haven Shopping Center at $1,330,000 and the reversion interest in
the Beach Haven Shopping Center at $2,530,000. Mary also was provided with at least two
accountings that provided the value of Shore Haven Apartments #1 and #3 as of June 25, 1999,
and March 31, 2000. These valuations were all grossly and fraudulently understated.
134. In addition to these sorts of false appraisals and accountings, Defendants also
provided Mary with gift and estate tax returns for the Fred Sr. estate that contained further
fraudulent undervaluations of Mary's Land Interests. For example, the 2000 Fred Sr. estate tax
returns included a schedule of real estate assets containing valuations of "50% interest in land-
Cropsey Avenue, Brooklyn, NY, subject to a ground lease to Shore Haven Apartments No. l, Inc."
as well as similar valuations of assets that were subject to ground leases to "Shore Haven
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Apartments No. 2, Inc.," and "Shore Haven Apartments No. 3, Inc." The values of each of these
real estate assets were fraudulently understated for at least two reasons.
135. First, as the tax returns stated, the valuations for each of these interests were
performed "based on present value of stream of payments." In other words, the valuations were
performed solely on the lease payments that were being paid and placed no value at all on Mary's
reversion interests (the appreciated land and improvements that would revert to Mary as lessor).
136. Second, the lease payments were excessively preferential to Defendants' entities as
lessees and far below market. These extremely low lease payments increased the flow of value to
Defendants as lessees to the detriment of Mary and other stakeholders as lessor. The valuation of
Mary's lessor interest was fraudulently calculated based solely on these low lease payments.
13 7. In reliance on these fraudulent misrepresentations, Mary relinquished her interest
in Shore Haven and Beach Haven at a grossly fraudulent undervaluation. If Defendants had
provided accurate numbers concerning her Land Interests, Mary would not have accepted these
terms.
3. Defendants Grossly Understated the Value of Mary's Trust and

Estate Interests
138. Finally, Defendants provided Mary with fraudulently understated valuations of her
Trust and Estate Interests.
139. Defendants procured several of these valuations from Von Ancken. Defendants
provided them to Mary in a May 18, 2000 letter fraudulently understating the value of 11 real
estate assets associated with the Fred Sr. estate, including Fontainebleau Apartments, Lawrence
Towers, Tysens Park Apartments, Shore Haven Shopping Center, and Beach Haven Shopping
Center.
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140. Defendants made similar fraudulent misrepresentations as to the value of certain
interests related to Fred Sr. and Mary Anne Trump's grantor-retained annuity trusts ("GRATs"),
as reflected in December 2000 statements; the value of Fred Sr.'s "Gross Estate," as reflected in a
federal tax summary; and (as alleged above) the value of the massive Starrett City development, a
percentage ofwhich was also part of the Fred Sr. estate, and which Defendants claimed was "a
nominal amount based on information obtained from management." Indeed, Defendants
represented to Mary that the total value of the properties in the Fred Sr. and Mary Anne Trumps'
GRATs, including 25 apartment complexes-was just $93.9 million. Just nine years later, banks
would put a valuation of nearly $900 million on many of the same assets.
141. Based on the fraudulently understated data that Defendants had provided, Mary's
attorneys calculated that "the amount that we would receive if we were totally victorious in this
regard is approximately $13,400,000." ![Defendants had provided accurate data, Mary would have
calculated a significantly higher fair market value for her interest in the Fred Sr. estate.
142. In each and every one of these ways, Defendants intentionally and fraudulently
induced Mary to enter into the Purported Agreements through their grossly fraudulent
undervaluations. Mary reasonably relied on these misstatements in relinquishing her claim to the
Estate Interests for an amount that grossly understated its true value. If Defendants had provided
accurate numbers concerning the Fred Sr. estate, Mary would not have accepted these terms.
IV. DEFENDANTS' CONTINUING CONCEALMENT
143. After Mary was squeezed out of her Interests on April 10, 2001, she no longer
received financial statements or other information (though her representatives or anyone else)
pertaining to the Trump empire and the Interests she had relinquished.
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144. Unbeknownst to Mary, however, Defendants continued to engage in fraud and
misconduct that harmed the taxpayers, their tenants, and anyone who did business with them.
Defendants also continued to deliberately conceal their fraud and cook the books.
145. Defendants' rampant fraud and misconduct-includ ing the schemes that harmed
Mary-only began to come to light with the publication of an investigative report by the New York
Times on October 2, 2018. Among other things, the reporting included extensive "interviews with
Fred Trump's former employees and advisers," as well as invoices and purchase orders obtained
from vendors, and other documents from both public and private sources.
146. That investigative report, and the documents and information it revealed, first put
Mary on notice of the schemes by which Defendants had defrauded her and squeezed her out of
her Interests in the Trump empire years earlier.
CAUSES OF ACTION
COUNTl
Fraudulent Misrepresentation
147. Mary incorporates by reference all preceding paragraphs and re-alleges them as if
fully set forth herein.
148. As alleged above, beginning in at least the early 1980s, Defendants intentionally
made material misrepresentations and omissions of fact to Mary regarding the true value ofMary's
Interests, including in connection with the Siphoning, Devaluing, and Squeeze-Out ofher Interests.
149. Defendants' fraud began in at least the early 1980s and culminated on April 10,
2001, when Defendants induced Mary into entering the Purported Agreements through which
Mary purported to settle her claims in the probate proceedings and health insurance 1itigation and
separately relinquish her Interests for far less than their true value.
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150. As alleged in greater detail above, for at least a decade prior to the Squeeze-Out,
Defendants used sham companies, lowball va hmtions, cash distributions disguised as notes,
padded invoices, and other kinds of concealed self-dealing to siphon value away from the entities
in which Mary held Interests, such as Midland, and into entities controlled and owned by
Defendants, such as All County, Trump Mâñagement, and Apartment Associates.
151. As a consequence of these siphoning efforts, additional undisclosed self-dealing,
and colluding to stall the sale of sponsor apartments held by the Midland entities, among other
gambits, Defendants drove down the book value of and net income generated by Mary's Interests.
Defendsts'
152. Throughout fraud, beginning at least in the early 1980s, Defendants
provided Mary with materially false and misleading financial statements and other financial
documents that grossly undervalued Mary's Interests, including with respect to their book value,
the net income they generated, and their purported fair market value (seesupra Sections IILA-B).
153. Defen±nk knew that the financial information provided to Mary was false or
they
provided the information recklessly without regard to its falsity.
154. Defendants provided this information intending that Mary would rely on it in
valuing her Interests and to deceive her into believing that her Interests were less valuable than
they actually were.
155. In the months leading up to the signing of the Purported Agreements in April 2001,
Defendants compoüñded their materially false and misleading representations and omissions
through additional statemcats concerning the value of Mary's Interests, as well as providing her,
through her attorney Barnosky and her trustee Durben, with similarly materially false and
misleading accounts, books and records, and valuations.
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156. In the Purported Agreements, Defendants expressly referred to the decades of
representations and omissions they made to Mary.
157. The Purported Agreements contained extensive warranties and representations as
to the truth and accuracy of that information. Defendants made at least the following material
misstatements and omissions:
a. Mary's Midland Interests. Between 1999 and 2001, Mary and her brother
requested that the Defendants provide her with information concerning their
ownership interests in Midland.
i. On or around December 21, 1999, Defendants provided Mary with
documents including income tax returns, financial statements,
partnership tax returns, lists of sold and unsold units, lists of mortgages
and notes receivable, and a list of cooperative apartment ownership
interests for 1997-1999 for the Midland entities. Separately, on
December 21, 1999, Defendants provided to Mary various financial
statements, tax returns, and schedules of cash disbursements for 1989-
1993 for the Midland entities, as well as additional tax returns. As
alleged in further detail in Section III.C above, the financial statements
contained numerous fraudulent misrepresentations, including
fraudulent overstatements of expenses for repairs and maintenance on
the Midland properties. In addition, as alleged in further detail in Section
III.C above, the schedules of cash disbursements contained numerous
similar fraudulent misrepresentations and transfers.
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ii. On December 8, 2000, Mary's counsel asked Defendants' counsel for
an appraisal for Fred Sr.'s partnership interest in Starrett City, which
Mary had an interest in through her 10% interest in Midland.
Defendants' counsel responded that Starrett City was valued at "a
nominal amount based on information obtained from management."
That "nominal" valuation was made by Defendants in their capacity as
"management." That valuation was fraudulently understated. According
to the New York Times investigation, Starrett City was sold in 2018 for
$905 million, of which Donald personally received at least $16 million.
iii. Ultimately, Defendants falsely represented to Mary that her interest in
Midland was worth no more than a specified amount that grossly
undervalued her interest.
b. Mary's Land Interests. Defendants also misrepresented to Mary the value of
her Land Interests in Beach Haven and Shore Haven. Defendants procured
fraudulent undervaluations of Beach Haven and Shore Haven from Von
Ancken. Von Ancken valued the Beach Haven and Shore Haven apartments at
$23 million, or $11.01 per square foot, which was far lower than their true
market value. Between 1999 and 2001, Defendants provided Mary with
numerous financial statements and other documents containing
misrepresentations of the value of the Beach Haven and Shore Haven ground
leases that were predicated on Von Ancken's undervaluations. Ultimately,
Defendants falsely represented to Mary that her Land Interests were worth no
more than a specified amount that grossly undervalued those interests.
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c. Mary's Trust and Estate Interests. Defendants misrepresented to Mary the
value of certain interests related to Fred Sr. and Mary Anne Trump's GRA Ts,
as reflected in December 2000 statements; the value of Fred Sr.'s "Gross
Estate," as reflected in a federal tax summary; and (as alleged above) the value
of the Starrett City development, a percentage of which was also part of the
Fred Sr. estate. Defendants falsely represented to Mary that Fred Sr.'s estate
was cumulatively worth no more than thirty million dollars and falsely
represented to Mary that her interest in the estate was worth no more than a
specified amount that grossly undervalued her interest. Defendants failed to
disclose, however, that they had fraudulently transferred valuable estate assets
to themselves in 1997. In fact, when most of the assets in the Trump real estate
empire were sold in December 2003, two years after the Squeeze-Out, they
were valued at "nearly one billion dollars."
158. Defendants' misrepresentations and omissions were material because the true value
of Mary's Interests was an essential consideration for her in deciding whether and the amount for
which to relinquish Interests.
159. Defendants knew that all of these statements and omissions relating to the value of
Mary's Interests were materially false and misleading, or acted with reckless disregard to their
falsity, in part because Defendants themselves had conspired to siphon millions of dollars from
Mary's Interests and conspired to drive down their value as alleged above, as well as because
Defendants dominated, operated, and controlled the overall business empire and had near
exclusive access to information about it.
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160. Defendants had intentionally made or provided the materially false and misleading
representations to Mary to deceive her into believing her Interests were far less valuable than they
actually were and ultimately to induce her into relinquishing her Interests for far less than their fair
market value.
161. Defendants intended that Mary would rely on their statements and omissions in
determining whether and at what amount to relinquish her Interests.
162. Defendants knew Von Ancken's valuations were false, that there was no reasonable
basis for them, and procured them for the purpose of misleading Mary, but presented them to Mary
as accurate assessments of the value of the assets in which she had Interests, in order to deceive
her.
163. Defendants intended to use and did use Von Ancken's valuations to further mislead
Mary as to the value of her Interests and to induce her reliance on their gross undervaluations of
her Interests.
Defendants'
164. Maryreasonably and justifiably relied on misrepresentations about the
value of her Interests in deciding to relinquish her claims to those Interests
165. Although Mary sought information about the value of her Interests, Mary could not
have discovered the true value of her Interests through the exercise of ordinary diligence or
intelligence because Defendents, in furtherance of their fraud and with near-exclusive access to
information, had siphoned value away from and misrepresented the value of her Interests for so
long.
Defendants'
166. As a direct and proximate result of relying on intentional
misrepresentations, Mary suffered injury by entering into the Purported Agreements predicated on
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these incorrect valuations and was conned by Defendants into giving up her Interests for
dramatically less than they were actually worth.
Defendants'
167. fraud against Mary was particularly egregious and morally culpable
because Defendants deliberately targeted her because they disliked her. For example, in a tweet,
"
Donald stated that Mary was "rightfully shunned, scorned and mocked her entire life In another
mess" stand."
tweet, he described her as "a who her grandfather "couldn't
Defendâñ‡s'
168. Due to fraud, Mary suffered damages in an amount to be proven at
trial.
169. Mary is also entitled to an award of punitive damages from Defendants because
Defendants'
their conduct toward her was malicious, wanton, and willful, and because schemes
Defendants'
also harmed the public by cyading applicable taxes and by improperly raising rents on
low-income tenants.
COUNT 2
Fraudulent Concealment
170. Mary ineerporates by reference all preceding paragraphs and re-alleges them as if
171. Defendants had a duty to disclose to Mary accurate information about the value of
her Interests before she entered the Purported Agreements because the true value of Mary's
facts"
Interests were "special known and knowable only to Defendants.
Defendants'
172. superior knowledge of such essential facts, coupled with their
knowledge that Mary was acting on the basis of incorrect information, made nondisclosure
inherently unfair.
173. By virtue of their dominant and controlling positions in the family business and
their fraudulent coñduct and conspiracy as detailed above, Defendants were aware of information,
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not readily available to Mary, demonstrating that the representations in the financial statements
and the valuations they provided to Mary dramatically understated the value of the entities in which
she had an interest
174, Although Mary sought information about the value of her Interests, she could not
have discovered their true value through the exercise of ordinary diligence or intelligence because
Defendants, in furtherance of their fraud, had so thoroughly siphoned value away from and
misrepresented the resulting value of the entities in which she had an interest for so long.
175. In short, Defendants had a duty to disclose essential facts to Mary bearing on the
true value of her Interests because those facts were peculiarly within their knowledge, and Mary
could not have discovered that information through the exercise of ordinary diligence or
intelligence,
176. But Defendants never disclosed those facts, Instead, between at least the early
1980s and 2001, they furthered their underlying fraud by deceiving Mary about the true value of
her Interests, as alleged above, through a combination of affirmative misrepresentations, active
concealment, and deliberate nondisclosure,
177. Indeed, year after year, Defendants provided Mary, through her trustee Durben,
with financial documents that were designed to dupe her into believing that her Interests were
being protected.
178. And Defendants expressly referred to the decades of representations and omissions
they made to Mary in the Purported Agreements.
179, Defendants knew that accurate information about the true value of her Interests was
material information that Mary needed,
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180. Defendants deliberately concealed these material, special facts to mislead Mary
about the value ofher Interests in the months leading up to the signing of the Purported Agreements
in order to induce her to relinquish her Interests in the Purported Agreements for significantly less
than they were worth.
181. As alleged above, Mary reasonably and justifiably relied on Defendants' omissions
in relinquishing her Interests and could not have found out the information they were concealing
from her through an exercise of ordinary diligence or intelligence.
182. As a direct and proximate result of Defendants' misleading omissions and their
failure to disclose the special facts peculiarly within their knowledge, Mary suffered injury by
relinquishing her Interests for far less than they were worth.
183. Due to Defendants' fraudulent concealment, Mary suffered damages in an amount
to be proved at trial.
184. For the reasons alleged above, Mary is also entitled to punitive damages because
Defendants' conduct was malicious, wanton, and willful.
COUNT3
Fraudulent Inducement
185. Mary incorporates by reference all preceding paragraphs andre-alleges them as if
186. As more fully set alleged above, Defendants fraudulently induced Mary to enter
into the Purported Agreements, and thereby to relinquish her Interests, by knowingly and falsely
representing the value of assets in which Mary held Interests, throughout their fraud and leading
up to and during settlement negotiations and in the Purported Agreements themselves.
187. Defendants' misrepresentations were materially false and misleading because they
dramatically understated the value of assets in which Mary held Interests.
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NYSCEF,DOC. NO. 2 RECEIVED NYSCEF: 09/24/2020
188. Defendants' omissions were materially false and misleading because they had the
purpose and effect of leaving Mary with amisimpression of the value of assets in which Mary held
Interests.
189. The Purported Agreements expressly referred to, and incorporated by reference,
decades of representations and omissions made by Defendants.
190. When Defendants made the representations regarding the assets in which Mary held
Interests, they knew the representations were false or made the representations with reckless
disregard to their falsity. Indeed, as alleged above, Defendants themselves directed the creation of
the fraudulently understated valuations on which these representations relied and directed the fraud
that led to these incorrect valuations.
191. Defendants intended that Mary would rely on their misrepresentations ofthe value
of the assets in which Mary had Interests and deliberately made the misrepresentations to induce
Mary to enter into the Purported Agreements.
192. Mary reasonably and justifiably relied on Defendants' falsely low representations
of the value of the assets in which she had Interests when she decided to enter into the Purported
Agreements.
193. As a direct and proximate result of relying on Defendants' false representations of
the values of her various Interests inducing her to sign the Purported Agreements, Mary
relinquished her Interests for an amount far lower than their actual worth and suffered damages in
an amount to be proven at trial.
Defendants' conduct was malicious, wanton, and willful
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COUNT4
Negligent Misrepresentation
196. As more fully alleged above, Defendants had a special relationship with Mary
regarding her Interests based on their fiduciary relationship and their status as executors of Fred
Sr.'s estate, majority partners and owners in Midland and her Land Interests, and trustees ofMary's
1976 trust.
197. Durben also had a special relationship with Mary as her trustee with respect to each
of these Interests. Defendants and Durben therefore had a duty to provide correct information
regarding the value of Mary's Interests during settlement negotiations.
198. Defendants and Durben knew or should have known that Mary would rely on their
representations regarding the value of her Interests, including but not limited to during the
negotiations following Fred Sr.'s death.
199. Defendants and Durben provided Mary with incorrect information regarding the
value of Mary's Interests.
200. Defendants and Durben failed to use reasonable care to ensure that their
representations were correct.
201. Mary's reliance on these representations when she decided to enter into the
Purported Agreements was reasonable because Defendants controlled, managed, and operated the
overall business empire and had near-exclusive access to information while Mary had no
involvement in how her Interests were managed and did not participate in the underlying business
in any way.
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ILED : NEW YORK COUNTY CLERK 09/24 / 2 620 10 : 2 6 W INDEX NO. 654698/2020
NYSCEFs DOC. NO. 2 RECEIVED NYSCEF: 09/24/2020
202. In addition, because Durben was her trustee, Mary reasonably relied on his
representations when she decided to enter into the Purported Agreements.
Defendants'
203. As a direct and proximate result of and Durben's false and misleading
representations, Mary has suffered damages in an amount to be proven at trial.
Defendants'
conduct was malicious, wanton, and willful.
COUNT 5
Civil Conspiracy to Commit Fraudulent Misrepresentation and Fraudulent Coaccalment
206. Together with Durben and Von Ancken (the "Co-Conspirators"), Defendants
agreed to misrepresent and conceal from Mary the true value of the entities that comprised her
Interests.
207. Over more than a with of their advisors and Co-

decade, Defendants, help
Conspirators, siphoñed minions of dollars from the entities in which Mary had an interest, drove
down their value, and provided Mary with fiñañcial statements and other documents and
statements they knew were predicated on misrepresentations, including false valuations, or
provided with reckless disregard to theirfalsity.
208. All the while, Defendants and their Co-Conspirators refused to disclose the true
value of Mary's Interests, despite having fiduciary duties and superior knowledge of the essential
facts that Mary could not readily ascertain.
209. Defêñdsets and their Co-Conspirators took these actions intentionally and in
Defendants' Co-Consphaiors'
furtherance of their agrccment. and their misrepresentations of the
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!FILED: NEW YORK COUNTY CLERK 09/24/2020 10:26 AM INDEX NO. 654698/2020
NYSCEF, DOC. NO. 2 RECEIVED NYSCEF: 09/24/2020
value ofMary's Interests and their refusal to disclose essential information were material to Mary's
relinquishment of her Interests.
210. Defendants and their Co-Conspirators intended that Mary would rely on their
misstatements and omissions.
211. Mary reasonably and justifiably relied on Defendants' and their Co-Conspirators'
misstatements and omissions and could not have discovered the truth through ordinary
intelligence-Defendants and their Co-Conspirators deliberately and effectively concealed their
collusive fraud from Mary, other members of the Trump family, and the general public.
212. As a direct and proximate result of Defendants' collusion and cooperation m
misrepresenting and concealing the value of her Interests, Mary relinquished her Interests for far
less than their fair market value, and was thereby injured.
COUNT6
Civil Conspiracy to Commit Fraudulent Inducement
215. Together with their Co-Conspirators, Defendants agreed to misrepresent the value
of Mary's Interests and failed to disclose essential facts to her in an effort to deceive her into
believing that the value of her Interests was substantially lower than it actually was.
216. Defendants and their Co-Conspirators provided Mary with misrepresentations and
concealed essential facts in the Purported Agreements with the purpose and intent of inducing her
reliance and making her believe that the entities that comprised her Interests were worth much less
than their fair market value.
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!FILED: NEW YORK COUNTY CLERK 09/24/2020 10:26 AM INDEX NO. 654698/2020
NYSCEF. DOC. NO. 2 RECEIVED NYSCEF: 09/24/2020
217. Defendants and their Co-Conspirators knew that the representations they provided
to Mary were false, or provided them with reckless disregard to their falsity.
218. Mary reasonably and justifiably relied on the misrepresentations Defendants and
their Co-Conspirators provided to her.
219. As a direct and proximate result of Defendants' and their Co-Conspirators'
collusion and cooperation in misrepresenting the value of her Interests, Mary was injured when
she relinquished her Interests for far less than their true value as set forth in the Purported
Agreements.
COUNT7
Breach of Fiduciary Duty
222. As described in further detail in Section II, Defendants owed Mary fiduciary duties
on account of their dominant ownership interest and higher level oftrust that had been placed in
them, their roles as her trustees, as executors, and as partners, as follows:
a. Defendants owed Mary fiduciary duties as co-members of Midland, a limited
liability company, and as partners in the associated entities, which they majority
owned, operated, and controlled;
b. Defendants owed Mary fiduciary duties as majority fee owners of the Beach
Haven and Shore Haven land interests, which they operated and controlled;
c. Defendants owed Mary fiduciary duties as executors of Fred Sr.'s estate, of
which Mary was a beneficiary. In their capacity as executors, Defendants owed
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INDEX NO. 654698/2020
Mary fiduciary duties beginning immediately on Fred Sr.'s death on June 25,
1999.
d. Defendants owed Mary fiduciary duties as trustees of certain trust interests of
which Mary was the beneficiary.
223. In addition, Defendants' co-conspirator Irwin Durben owed fiduciary duties to
Mary as the trustee of her Ground Lease Interests, Midland Interests, Estate Interests, and 1976
Trust, see supra Section II.
224. As such, Defendants had a fiduciary duty to speak and inform Mary of their scheme
to siphon away value from her, to devalue her Interests, to misrepresent their value in various
financial documents, and to squeeze her out of her Interests.
225. In addition, as fiduciaries, Defendants owed Mary duties of good faith, fair dealing,
and full disclosure, and were not permitted to engage in transactions that created conflicts of
interest.
226. Defendants breached their fiduciary duties to Mary beginning in the early 1980s
and throughout the 1990s by self-dealing, siphoning her Interests, devaluing them, misrepresenting
their value, and attempting to fraudulently squeeze her out of them, as alleged above.
227. As a direct result of Defendants' breach of these duties, Mary suffered damages
from the dramatic reduction in value of her Interests, including their book value and their net
income.
228. In so doing, Defendants showed wanton disregard for Mary. They willfully,
egregiously, and repeatedly abused their position of trust and deprived Mary of her Interests in
order to maximize their own profits.
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INDEX NO. 654698/2020
229. Mary sustained damages directly caused by Defendants' breach of their fiduciary
duties in an amount to be proven at trial.
COUNT8
Aiding and Abetting Breach of Fiduciary Dutv
232. As alleged above in Count 7, Defendants breached the fiduciary duties they owed
to Mary as co-executors of Fred Sr.'s estate, as co-trustees of the 1976 trust, as partners in and co-
members ofMidland, and as majority owners of the Beach Haven and Shore Haven land interests.
Irwin Durben also breached the fiduciary duties he owed to Mary as trustee of her Land Interests,
Midland Interests, and co-trustee of the 1976 trust.
233. Each Defendant was aware of the fraud. Each Defendant lent substantial assistance
to each other, and to Durben, in furtherance of the fraud and breach of fiduciary duty. And each
Defendant's refusal to disclose the fraud and breach of fiduciary duty to Mary helped conceal
Defendants' breach and enabled it to occur.
234. Defendants knew of each other's fiduciary duties and the duties owed by Durben
and, due to their participation, had actual knowledge of the pertinent breaches.
235. Due to each Defendants' substantial assistance in the breach of fiduciary duties,
Mary suffered damages in an amount to be proven at trial.
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INDEX NO. 654698/2020
IFILED: NEW YORK COUNTY CLERK 09/24/2020 10:26 Aij
PRAYER FOR RELIEF
WHEREFORE, judgment should be entered in favor of Plaintiff and against Defendants,
jointly and severally, as follows:
a. compensatory damages in excess of $500,000 and in an amount to be proven at

trial;
b. punitive damages in an amount to be proven at trial;
d. prejudgment and post-judgment interest;
e. attorneys' fees, litigation expenses, and costs; and
( such other relief as may be just and proper.
Dated: September 24, 2020

New York, New York
Roberta A. Kaplan
John C. Quinn
Alexander J. Rodney
KAPLAN HECKER & FINK LLP
Tel: (212) 763-0883
Fax: (212) 564-0883
jquinn@kaplanhecker .com
Counsel for Plaintiff Mary L. Trump
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EXHIBIT "B"
• WAIVER OF NOTICE OF ANNUAL MEETING
OF
STOCKHOLDERS
OF
TRUMP MANAGEMENT, INC.
The undersig ned, being the sole stockhol der of
TRUMP MANAGEMENT, INC., does hereby waive all notice of the
Annual Meeting of Stockho lders of said corpora tion, to be
held at the offices of the corporat ion, 200 Garden City Plaza,
Garden City, New York 11530, at 9 o'clock in the forenoon ,
•
for the purpose of electing director s for the corporat ion
for the ensuing year and such other business that may properly
come before the meeting,
Dated: January 4, 1993
tockhold er
•
,A 234,-·Cortlacateof Incorporation. copyrrour 1963or JULTUsBLUMBERG.INC., LAW BLANK PUBLtW FRS
BWrilleSSCorporation Law §4D2. So EXCHANGEPLACC AT BaoAoway, NEW YORK-
Gertificate at htrorporatintt of
TRUMP MD1AGEENT INC.
under Section 402 of the Business Corporation Law
IT IS HEREBY CERTIFIED THAT:
(1) The name of the proposed corporation is qgyyggs IGNAGEENT INC.
(2) The purpose or purposes for which this corporationisforined,are asfollows,towit:
To own, buy, sell, erect, construct, maintain, improve,

rebuild, enlarge, alter, manage and control directly or through
ownership of stock in any corporation, any and all kinds of
dwellings, apartment houses and other buildings, private or
public, and any and all other structures and erections which
may at any time be necessary, useful or advantageous in the
udgment of the Board of Directors and which can be lawfully
done under the Business Corporation Iaw.
The corporation, in furtherance of its corporate purposes above set forth, shall have all of the powers
enutnerated in Section 202 of the Business Corporation Law, subject to any limitations provided in the Business
Corporation Law or any other statute of the State of New York.
(3) The office of the corporation is to be located in the Cl'VV
(city) {town) {Incorporated vlll;t!;?)
of NEW YORK County of Queens} State of New York.
(4) The aggregate number of shares which the corporation shall have the authority to issue is
(200) without value.

(5) The Secretary of State is designated as agent of the corporation upon whom process against it may be
served. The post office address to which t e Secretary of State shall mail a copy of any process against
the corporation served upon him is O o Duroen & Toati, Esqe. ,
89-31 161st street,
Jamaica , New York, 11432.
The undersigned incorporator, or each of them if there are more than one, is of the age of twenty-one
years or over.
IN WI TNESS WHEREOE, this certiñcate has been subscribed this r day of .. 19,
by the undersigned who afBrm(s) that the statements made herein are Îr nder the penaÎlŸes Ÿ perjury.
Typenameof mcorporator Signature
.ÓÛ*31 1Ó18 ..Street.,.-..Jamal-ca,...NewJork,- n432

Address
Address
.......................................... . ... ......... .. ... ......................................... ..........,...,,.....,.......................... . . ..................................................
___.................................. .... ............................... .......................... .. . ... . . ...... ...... ..... ..... ...
Mdress
._............--
Gertificate of Incorporatiott
of
TRUMP MANAGEBENT INC.
under Section 402 of the Business Corporation Law
Filed By: DDLGBEB & TOSTI,
Office and Post Office Address
89-31 161st street

Jamalea New York 11432
RECEIPT ISSUED BY SECRETARY OF STATE
(ATTACHED HERETO)
STATE OF NEW YORK DEPARTMENT OF STATE
DIVISION OF CORPORATIONS AND STATE RECORDS

ALBANY
FIUNG RECElPT
TYPEOF CERTIFICATE
Incorporation (3nsiness)
CORPORATIONNAME DATE FILED
TEL?2TP FEAGBET2 12M. 4/22/89
DURATION& CO.CODE FitM NO.
NO. AND KIND OF SHARES

200 npy
LOCATIONOF PRIN.OFFICE COM/MNT
FORSERVICE
ADDRESS OF PROCESS
REGISTERED
AGENT,IF ANY
FILERAND ADDRESS
39-31 161ST ST
JAi@.ICA Ef 11432
G DOLLAR FEE TO COUNTY
FEES AND/OR TAX PAID AS FOLLOWS:
K CASH au
$ t O FILING
$ 10 TAX
$ CERTIFlED COPY
$ CERTlFICATE TOTAL $ 60
REFUND OF $ TO FOLLOW
JOHN P. LOMENZO .
SECRETARY
OF STATE
CO-518(REV.3/65)
2
EXHIBIT "C"
TH1BINDTRUMENT
iNSTRUMENT
YoURLA'.'"/CCenE$10%NGTHW
CofIBULT SHOULD LAWYERS
BEUSEDBY oNLY.
THIS INDENTURE,mndethe 2nd day of Mamn hundredimdeighty-eight

, :iinets·en
BETWEEN THE G ASEMAN1ta'IT AN BANK, a National a-hHon, successor by inerger to
the President and Directors of The Manhattan Ctxupany, as Trustee under the Inden-
ture of Trust made by Elizabeth Trump, as Grantor and dated August 2, 1949, and as
Trustee under the last Will and Itstament of El.izabeth Trump, Deceased, with offices
at 1211 Avenue of the Americas, New York, N1 10D36
.
panyof theflmt pun.nnd IRWIN DURBEN,as Trustee under an Indenture of Trust dated June
percent
20, 1983 for the benefit of W.ry Lea. Trump, as to an undivided five (5%)
interest in the paperty, and IRWIN DURBEN,as Trustee under an Indenture of Trust
dated November 25, 1981 for the benefit of Fred C, Trunp, III, as to an undivided
five (5%) interest in the property, with offices at 200 Garden City Plaza, Garden
City, N.Y. 11530
panyof thesecondpmt,
of
WITNESSETH,thatthe pmtyof thefirstpart,in considenulon
-------ten ($10.00)------ dollars,
lawfulmoneyof theUnitedStates, paid
UntDthepartyOfthesecondpan,theheirsor successon
pn, doesherchygrantandTelcD30.
bytheprty of thesecond
of thepunyof thescand panforever.
andassigns
PARCEGA
All that certain plot, piece or parcel of land, vilth the buildings and impmvenents
thereon erected, situate, lying and being in the Borough of Bmoklyn, County of Kings,
City and State of New York, bounded and described as follows:
BEGINNINGat a corner fonned by the intersection of the southerly side of Cropsey

Avenue and the westerly side of 21st Avenue; running thence southerly along the
thence
westerly side of 21st Avenue 386,88 feet to the center line of 21st Drive;
line of 21st
vesterly at right angles to 21st Avenue and partly along the center
Drive 476.67 feet; thence northerly at right angles to the preceding course and
side
partly along the center line of Bay 25th Street 417.63 feet to the southerly
of Cropsey Avenue; and thence easterly along the southerly side of Cropsey Avenue
477.67 feet to the corner, the point or place of BUINNING,
'ICGETER with all right , title and interest, if any, of the Grantor, of, in and
to land lying in the bed of Cropsey Avenue, Bay 25th Street, 21st Drive and 21st
Avenue in front of and adjoining the above described premises to the center lines
thereof respectively.
TOGETHER with the appurtenances and all the estate and rights of the party of the
first part in and to said pranises,
PARCELB
All that certain plot, piece or parcel of land, with the buildings and impmvenants
thereon erected, eituate, lying and being in the Borough of Brooklyn, Oxinty of Kings,
BEGINNINGat a point on the southeasterly side of 20th Avenue, distant 116.03 feet
southwesterly frcm the corner founed by the intersection of the southeasterly side
of 20th Avenue with the southwesterly side of Cropsey Avenue; running thence
southeasterly at right angles to 20th Avenue, 223.33 feet to the center line of
Bay 25th Street; thence southwesterly along the center line of Bay 25th Street
https://a836-acris.nyc.gov/DS/DocumentSearch/Document|mageView?doc_id=FT_3630001356963 1/4
a 2198a 280
und along a line in continuation thereof, 316 feet to its intersection with the
center line of 21st Drive or said center line of 21st Drive if extended north-
westerly; thence southeasterly along said center line of 21st Drive if extended,
and along said center line of 21st Drive, 266.67 feet to ita intersection with
the center line of 20th Lane, if extended northeasterly; thence southwesterly
along said center line of 20th Lane, if extended northeasterly and along the
center line of 20th Lane and along the said center line of 20th Lane if extended
southwesterly, 250 feet to its intersection with the center line of 20th Lane as
the same runs at right angles to 20th Avenue; thence northwesterly along said
center line of 20th Lane as the same runs at right angles to 20th Avenue; S30 .
feet to the intersection of said center line with the center line of 20th Avenue;
thence northeasterly along the center line of 20th Avenue, 367.03 feet more or
less to the fomer high water line of Gravesend Bay; thence southeasterly along
said former high water line of Gravesend Bay, 40,01 feet to the coutheasterly
side of 20th Avenue; and thence northeasterly along the southeasterly side of ,
20th Avenue, 109 feet nore or less to the point or place of BEGINNING.
TOGE11ER with all of the right, title and interest, if any, of the Grantor, of, in .
and to the beds of the streets, roads, avenues and lanes in front of and adjoi&-
ing the above described premises to the respective center lines thereof.
TOGE1HER with the appurtenances and all the estate and rights of the party of the
first part in and to said premises,
PARCELC
All that certain plot, piece or parcel of land, with the buildings and improvenente
thereon erected, situate, lying and being in the Borough of Brooklyn, 00unty of Kings,
BEGINNINGat a point on the northeasterly side of Shore Road htension where same
is intersected by the center line of 20th Avenue, as same are laid down on the
City Plan; running thence southeasterly along the northeasterly side of Shore
Road Extension, 440 feet to an angle in the northeasterly side of Shore Road Ex-
tension; thence in an oasterly direction still along the northeasterly side of
Shore Road htension, 258.31 feet to a point; thence in an easterly and north-
easterly direction along Shore Road Extension, along the arc of a circle having
a radius of 66.81 feet, a distance of 87.95 feet to a point on the northwesterly
side of 21st Avenue, the same is laid down on the City Plan; thence southeasterly
at right angles to the said north½usterly side of 21st Avenue, 40 feet to the
center line of said 21st Avenue; thence northeasterly along the center line of
said 21st Avenue, 340.36 feet to the interesection of the center line of said
21st Avenue with the line which is the continuation southeasterly of the center
line of 21st Drive, as same are laid down on the City Plan; thence northwesterly
along said line and the center line of said 21st Drive, 250 feet to the inter-
section with the line which is the continuation northeasterly of the center line
of 20th Lane as said 20th Lane runs in a northeasterly direction, and as laid
M down on the City Plan; thence southwesterly along said line and the center line
of said 20th Lane 250 feet to the intersection of the line which is the continua-
y: tion southeasterly of the center line of said 20th Lane, as said 20th Lane runs
in a southeasterly direction, and as laid down on the City Plan; thence north--
westerly along said line and the center line of said 20th Lane, 530 feet to the
center line of said 20th Avenue; thence southwesterly along the center line of
said 20th Avenue, 220 feet to the northeasterly side of Shore Road Extension,
at the point or place of BEGINNING.
10GE1HR with all the right, title and interest, if any, of the Grantor, of, in
and to the beds of the streets, roads, avenues and lanes in front of and adjoin-
ing the above described premises to the respective center lines thereof.
SUBJECfto covenants, restrictions, easenents and agreenents of records, if any,

to the extent that the same may affect eaid property; subject to leases of record;
and subject to taxes, water rates, sewer charges and assessnents, if any, affect-
ing said property.
TOGE1HER with the appurtenances and all the estate and rights of the party of the
first part in and to said premises.
https://a836-acris.nyo.gov/DS/DocumentSearch/DocumentimageView?doc_id=FT_3630001356963 2/4
TOGETHERwi1hull right,title and an 2198me 281
if nny,of diopunyofthefirst
Inletest.
the ubovedescdbed put Inandto anyametsandroada
pirmiscsto the centerthics shutting
thereof,
TOGETHERwith theappunenances
andall theestateandrights
TO NAVEAND TO HOLDthe of thepartyof thefirst partIn andto
premises saidpremiser,
hereingnateduntothe
assignsof thepanyof the panyof theaccondpa& theheirsuaüvw»me and
secondpan forever.
..sND the partyof 1hefirstpar:

covenants thatthepanyof thefirst parthas
thesaidpremises notdoneor suffered
havebeenincumbered in anyway whatever,exceptas onythingwhcmby
aforesaid.
AND the panyof thefirst
part,in compliance withSection13of theLien
panwill receivethe Law, covenants thatthepartyof the first
consideration for this conveyanceandwill holdtherightto mccive
fundto beappliedfirst for the such:=:2::±a asa trust
purpose of paying111c
costof theImprovement
mentof thecostof he andwill applythesamefast to pay-
improvement beforeusingany partof thetointof the
The word "paity" shallbe thesamefor any otherpurpose.
congmedas if h tend"panics"
IN WITNESS whenever thesenseof this indentureso
WHEREOF,thepanyof the fttstparthas
dutyaus deedthedayandy
m enszNes or
'Uis OIASE MANHATPAN

BANK, N,A
By
J.0HbiM. YALENSTEIN,
VICEPRES.
https://a836-acris.nyc.gov/DS/DocumeidGearch/De-
se V;ew?doc_id=FT_3630001356963 3/4
21h 282
STATE OF
COUNTY
OFNEWYORK, 4: STATE COUNTY
OFNEWYORK, OF as:
19 , hermyme On Ike day of 19 . befamnic
Onthe Jay of
enme
per.timulty personallyenme
to mekiwiwnto hethe individutd in undwlio to meknownm be theindivithmi

dexeribed described
in andwhn
executedthe foivgolngInstminent,nmi eeknowledged that executedthe foiegoing iminiment.and neknowledged that
the snntc.
execitled executedthesiune.
STATE OFNEWYORN, COUNTY F NE' YORK m 8TATEOFNEWYORK, Col]NTV OF as:
Onshe 2 ND da of JehlPeary- 19..88 , beforeme On the day of I9 , befamine

pemmnitycume h/ V4L N W# personnllycame
to meknown.who. gby gueduly sworn,diddepose andsay to nicknown,who, beingby medulysworn,did depose andf.ay
that berealdesut No.YMidd/e MY that heresidesatNo,
0ID CP CCM.vic,/4 ' cr /‰f&7'·
that neis the WW that heis the
of 7'fadAss HMhmweque, NA of
, thecorpomtion described , thecorporation described
AS TRoST'g [nstrumentuhat heknows
inandwhichexecuted thefo:egoInginstrument:thut heknow in andwhichexecuedthefaregolng
thescalofsuldcoiporationuhai thescalaffixedinsaidinsmimentthesculofanidcorpomliont thattheseal a ffixedinsaidinstrumem
is stichco at thath wassoafGxedby on)crvftheheanI is suchcorpomte r.cuhthat11wassnaffixedbyorderof the6cant
nfdirectors rpomiian, and11mt healgned his name or directors of saidcapomdon.andthat hesignedh name
themtoby I ,, cr. theretoby likeorder.
GEOSGE
WIL8ON
ed InNowYorkCounty
Parcel Parcel Parcel

A _ B C
[
. infJ ANTAGalNSI' ACTS
GRANTOR'8
64G7 6489
nun 6469
Kings
COUNTrappr8MN Kings Kings
BA1
'IllE CHASEMANHATrAN N.A. ,
w -5rit >oat ChM5Y A th'--
as Trustee
.C uf COMMONWEALTH
. t P.cituest
Recorded LAND
TO , SURANCECOMPANY
IRWIN DURBEN, Al NAP
as Tn.tstee
N™™" "*^"
(7)
sTwomomm40F
NEWyQAK
BOMD UNDERWMTER3
0FTITLE
Durben & 1bsti, Esqs.
, 200 Gat·denCity Plaza
° Garden City, New York
COMMONWEALTH1AND'
3
(DMPANY
TITl£INSURANCE 7.ipNu 11530
1958AIN -b A ID 34
. r suan u
https://a836-acris.nyc.gov/DS/DGcümei dGearch/Dec nt|-ageView?doc_id=FT_3630001356963 4/4

FORu
ma SandefN.YAT,U.Fonn5007 BugdnandSaleDecdithCownant
agalmt Acts- Individud
Gmnior's orCoqersikm
CONSULT
YOUR BEFOR£9IGNING
LAWYER - THIS
THIS1NETRUMENT INSTRUMENT
SHoDLD DYLAWYERS
BEUEED ONLY.
THIS INDENTURE,maderhe 18th dayof October , nineteenhundred

and ninety five
BETWEENIrwin Darben as Trustee under an indenture of Trust dated June 20, 1983
for benefit of Mary Isa Trtmp, with offices at 200 Garden City Plaza, Garden City,
New York 11580,
CD
partyohhe fina pan,and Mary Lea. Trump, residing at 78 Kensington Road, Garden y
Rew York 11530, an undivided flye (5%) percent interest in the property.
.. . .
partyof thesecond
part,
WITNESSETH,thatthepany of thefirst pan, in consideration
of ten and 00/100 ($10)
dollars,
lawful moneyof theUnitedStates, paid
by thepart ofthesecond
partÔdnes
herebygrantandrelease
untothepaÔy..oÓthe part,Iheheirs-.--
seennd
altdassigns
of the partyof thesecond
pan forever,
PARCELA .
. .
All that certain plot , piece or parcel of land, with the buildings and improvenents
erected, situate, lying and being in the Borough of Brooklyn, County of Kings,
y and State of New York, bounded and described as follows:
Et ct t th e C y
idaÈh$ ly
Westerly side of 21st Avenue 386.88 feet to the center line of 21st Drive; thence
westerly at right angles to 21st Avenue and partly along the center line of 21st
Drive 476.67 feet; thence northerly at right angles to the preceding course and
partly alog the center line of Bay 25th Street 417.63 feet to the southerly side
y Avenue; and thence easterly along the southerly side of Cmpsey Avenue
• feet to the corner, the point or place of BEGINNING
10GE11IERwith all right, title and interest, if any, of the Grantor, of, in and
O land lying the bed of Cropsey Avenue, Bay 25th 8treet, 21st Drive and 21st
Avenue in front of and adjoining the above described premises to the center lines
thereof respectively,
20GimER with the appurtenances and all the estate and rights of the party of the
first part in and to said precises.
PARCELB
All that certain plot, piece or parcel of land, with the buildings and fapmvenants
thereon erected, situate, lying and being in the Borough of Brooklyn, County of Kings,
City sad State of New Yorrk, bounded and described as follows:
IEGINNDU at a point on the southeasterly side of 20th Avenue, distant 116.03 feet
avuümmierly frcrn the corner fored by the intersection of the southeasterly side
of 20th Avenue with the southwesterly side of Cropsey Avenue; running thence
https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentimageView?doc_id=FT_3240004976224 1/5
of
southeasterly at right angles to 20th Avenue, 223.33 feet to the center line
Bay 25th Street; thence soutN==terly along the center line of Bay 25th Street
and a.1ong a line in continuation thereof, 316 feet to ite intersection with the
north-
center line of 21st Drive or said center line of 21st Drive if extended
westerly; thence southeasterly along said center line of 21st Drive if extended,
and along said center line of 21st Drive, 266.67 feet to its intersection with
the center line of 20th lane, if extended northeasterly; thence southwesterly co
along said center line of 20th Lane, if extended northeasterly and along the
center line of 20th Iane and along the said center line of 20th lane if extended
southwesterly, 250 feet to its intersection with the center line of 20th Iane as
the same runs at right angles to 20th Avenue; thence northwesterly along said o
center line of 20th Iane as the same runs at right angles to 20th Avenue; 530 e..3
feat to the intersection of said center line with the center line of 20th Avenue;
thence northeasterly along the center line of 20th Avenue, 367.03 feet more or
less to the former high water line of Gravesend Bay; thence southeasterly along
said fomer bigh water line of Gravesend Bay, 40.01 feet to the southeasterly
side of 20th Avenue; and thence northeasterly along the southeasterly side of
20th Avenue, 199 feet rwre or less to the point or place of BEGINNING .
703ETIEERwith all of the right, title and interest, if any, of the Grantor, of, in
and to the beds of the streets, roads, avenues and lanes in front of and adjoin-
ing the above described pranises to the respective center lines thereof.
70GBITERwith the appurtenances and all the estate and rights of the party of the
first part in and to said premises.
PARCELC
All that certain plot, piece or parcel of land, with the hzildings and inprovements
thereon erected, situate, lying and being in the Borough of Brooklyn, (bunty of Kings,
City and State of New York, bounded and described as fol1cws:
BEGINNINGat a point on the northeasterly side of Shore Road Extension where same
is intersected by the center line of 20th Avenue, as same are laid down on the
City Plan; running thence southeasterly along tho northeasterly side of Shore
Road Extension, 440 feet to an angle in the northeasterly side of Shore Road Ex-
tension; thence in an easterly direction still. along the northeasterly side of
Shore Road Extension, 258.31 feet to a point; thence in an easterly and north-
easterly direction along Shore Road Extension, along the arc of a circle baving
feet to a point on the northwesterly
I a radius of 66.81 feet, a distance of 87.95
side of 21st Avenue, the same is laid down on the City Plan; thence southeasterly
at right angles to the said northwesterly side of 21st Avenue, 40 feet to the
I center line of said 21st Avenue; thence northeasterly along the center line of
eaid 21st Avenue, 340,36 feet to the intersection of the center line of said
21st Avenue with the line which is the continuation southeasterly of the center
line of 21st Drive, as sarre nre laid dcon on the City Plan; thence northesterly
inter-
along said line and the center line of said 21st Drive, 250 feet to the
section with the line which is the continuation northeasterly of the center line
of 20th Iane as said 20th lane runs in a northeasterly direction, as as laid
down on the City Plan; thence southwesterly along said line and the center line
of said 20th Lane 250 feet to the intersection of the line wtiich is the continua-
tion southeasterly of the center line of said 20th lane, as said 20th Lane runs
in a southeasterly direction, and as laid down on the City Plan; thence nurth-
westerly along said line and the center line of said 20th Lane, 530 feet to the
center line of eaid 20th Avenue; thence southviesterly along the center line of
said 20th Avenue, 220 feet to the northeasterly side of Shore Road Extension,
at the point or place of BEGINNING.
with all the right,

'IOGETIHER title and interest, if any, of the Grantor, of, in . .
and to the beds of the streets, roads, avenues and lanes in frcot of and adjoin
ing the above described pranises to the respective center lines thereof.
SUBJECTto covenants, restrictions, easenents and agreenents of records, if any

to the extent that the ease say affect said property; subject to leases of acord; . ,
and subject to taxes, water rates, sewer ebarges and assesstents, if any, affect-
ing said prcperty. .,
)GElifERwith the appurtenances and all the estate and rights of the party of the
first part in and to said pranises.
BEING the sana prenises as that conveyed to the party of the first part by deed
dated March 2nd, 1988 and recorded on April 6, 1988 in Reel 2198, Page 279.
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TOGETHERwithall right,titleandinterest,If any,of thepartyof thefirstpartinandgoanystreets
androadsabutting
theabovedescribed
premises to thecenterlinesthereof,
TOGETHERwiththeappurtenances
andall theestateandrightsof thepanyof thefirstpanIn andtosaidprembes,
10 HAVEANDTO HOLDthepremises hereingramedumothepartyof thesecond paft,theheirsor successors
and
araignsof the partyof thesecond
partforever,
AND thepartyof thefirstpartcovenants

thatthepartyof thefirstpanhasnotdoneor suffemianythingwhereby
thesaidpremises
havebeenincumbered in anyway whatever,exceptasafomsaid.
ANDthepanyof thefirst pan,incompliance with Section13of theLien Law, covenants thatthepanyof thefirst
partwl!1receive
thecomideration for thisconveyance andwill holdtherightto receivesuchconsideration
asatrust
fundto beappliedfirst forthepurpose of payingthecostof theimprovementandwill applythesamefint tothepay-
mentof thecostof theimprovement
beforeusingany panof thetotalof thesamefor anyotherpurpose,
Theword"party" shallbeconstrued
asif it read"parties" whenever
thesenseof thisindenture
80Tequires.
INWITNESSWHEREOF,thepartyofthefint parthasdulyexecuted
thisdeedthedayandyearfirstabovewritten,
'CE
'Den T1¶5tee
ames
https://a836-acris.nye.gov/DS/DecumentSearch/Document|rnaseV;ew?doc_id=FT_3240004976224 3/5
r
STATE
OFNEWYORI4 OFNASSAU
COUNTY sa: STATE
OFNEWYQRK,COUN1Y
OF sa:
On the dayof October 19 95 . beforeme Onthe day of [9 , beforeme
personally Irwin Dilrben came
personally
to meknown10betheindividuc] described
in andwho to meknown tobetheindividual described
Inandwho
executedthe. foregninginstniment·arid
same.' -a 'that exeemedthe·fûri*going
acknowledgedl ackndviledged
''instrumenty-ahd that
executed . . escutedthesame
VIED .10 . - i. . ., .. - . us
PUBL lé Na York
iTfÃ'RY us
No. 09621175
Qualified Coun
InSulMk
Commission 31, 9-
ExplmsMay co
STATE 0F NEW YORK, COUNTYOF as: STATE OFNEWYORLCOUNTY OF sa

'^ -
On the day-o 19 , befOTe
me Onthe day of 19 . beforeme
personallycame came
undway'personally
to meknown,who,beingtiymedulysvorn,didafcifosh did depose'and
tomeknownwho,belig by me'duly.áwo/n. say
that he.tuidmkH Fo. .. +. . that>- heresides
at No
3 that he isthe I that heis the

of of . ,
. th6dopBrdflogi desdtibed , ttletorpeftBn 'd'esehed
inandwhichüccuted thefoñgoinginsitumentt -'
that heknows inandwMchexecuted lheforegonginstrument; that heknows
thesealofsaidcorpomtion; thatthesealaffixedtosaidinstrumentthesealof:::ik-i-=±r.: thathesealamxedtosaidinstrument
issuchcorporate scal;thatit wassoaffixedby orderof thebounj tssuchcorporate seal;thatit wassoaffixedhyonferoftheboard
andthat hesigned
ofdirectorsöftialdEòrporation, h name ofdirectors ofsaidcorporation.andthat hesignedh name
theretoby lik order. thereinby likeorder. .
Parcel Percel Parcel

A B C
WITHCOVENANT ACTS
GRANTOR'S
AGA)NST Sam0N
BLOCK 6460 6467 6489
Ti* No, -0 ' 1 12 1
coum enewEings Kings Kings O
AS U5JSTEE
pIN DDRBEN 20-34 to 20-78 Cropsey Avenue ()
of ChMMOWIEALTMLAND
at Request
Recorded
TITLEINSURANCE COMPANY
MARYLFA W MAIL
., REDTARSY TO:
MRICOEW
SMDMD OFTME
YO BOAND
amem DUBBEN& TOSTI, ES's.
200 GAHDENCITT PLAZA , .
GARDENCITY, NT 11530
TH 1.AW o
unEMMts:E COMMU
AbimerGouplhings ZipNo.
https://a836-acris.nyc.gov/DS/DacümâñtSearch/Doc thgeView?doc_id=FT_3240004976224 4/5

EXHIBIT "D"
In the Matter
of the
Settlement of the First Intermediate Account

RECEIPT, RELEASE, INDEMNIFICATION
of The Chase Manhattan Bank as Trustee under
Article Sixth of the Last Will and Testament AND REFONDING AGREEMENT
of ELIZABETH J. TRUMP, Deceased.
WHEREAS, ELIZABETH J. TRUMP, (the "Decedent") died on the sixth day of June 1966,
a resident of the City of New York, County of Queens, and State of New York, leaving
a Last Will and Testament dated June 8, 1960, (the "Will"), which was duly admitted
to probate by the Surrogate's Court of the County of Queens, on August l, 1966, a copy
of which is annexed hereto as Exhibit A; and
WEEREAS, by ARTICLE SIXTH of her Will, the Decedent directed that certain property,
to a 25% interest in the fee title to Shorehaven Apartments #1 and a 50% interest
wit;
in the fee title to Shorehaven Apartments #3, and "any and all life insurance policies
on the life of my son, FRED C. TRUMP, subject to any indebtedness to which such policies
death," if FRED
are sub,ject at the time of my be held in trust, her son, C. TROMP,
survived her; and
WHEREAS, the Decedent gave, devised and bequeathed said property to The Chase
Manhattan Bank (National Association) to hold and administer the same, to collect the
income and to apply the net income as needed for the purpose of paying life insurance
premiums on policies held by the Trustee on the life of her son, FRED C. TRUMP, and
to the payment of interest on any loans against such policies which may be outstanding
at her death or may be made thereafter in order to permit the payment of premiums out
(
of the funds that have been borrov.ed. "Any net income not requir ed for the payment of
my Truste es and added
such premiums or intere st as herein provid ed shall be retain ed by
C. TRUMP, the Deced ent
to the princ ipal of the Trust Fund," and upon the death of FRED
ition of the·T rust.
direct ed in pert1n ent part as follow s with respec t to the dispos
SECTION 2(b) Each share so set aside for a child of my son, FRED C. TRUMP,
FRED C. TRUMP,
\'ho shall have surviv ed me, but vmo shall have predec eased my son,
and distri buted
togeth er with any accum ulated income thereo n, shall be paid over
FRED C. TRUMP,
by my Truste es to the descen dants of each child surviv ing my son,
in equal shares , per stirpe s.
SECTION 2(c) Each share so set aside for a child of my son, FRED C. TRUMP,
thereo n,
v-ho shall have surviv ed h:ini, togeth er with any accum ulated income
ct trust for
shall be held and managed by my Truste es as a separa te and distin
es shall,
the benef it of the child for v-nom it has been set aside and my Truste
such Trust
during the life of such child, hold, manag e,· invest and reinve st
rom to
Fund, collec t .. the income theref ran and pay over the net income theref
the said child for v-hom such Trust Fund have been set apart; and
ied and
WHEREAS, The Chase Manha ttan Bank (Natio nal Assoc iation ), duly qualif
was issued Letter s of Truste eship under ARTICLE FOURI'EENTH

of the said Will and
there after acted as Truste e of the said Trust; and

The Chase
WHEREAS, The Chase Manha ttan l3iink is the succes sor in intere st to
ed to as "the
Manha ttan Bank (Natio nal Assoc iation ) s6rreti mes herein after referr
Truste e" ; and

nt of the City
WHEREAS, the said FRED C. TRUMP, died on June 25, 1999, a reside
of New York, County of Queen s, and State of New York; and
2.
('
/
WHEREAS, at the t:ime of his death, FRED C. TRUMP, was survived by his children
DONALD J. TRUMP, ROBEIIT S. TRUMP, MARYANNE TRUMP BARRY and ELIZABEI'H TRUMP GRAU, and
grandchildren FRED C. TRUMP, III and MARY LEA TRUMP, children of FRED C. TRUMP, JR.,
who died on September 26, 1981; and
WHEREAS, during the lifet:ime of FRED C. TRUMP, the trust assets wre held "in
solido" representative of the separate shares for each of the children of FRED C. TRUMP;
and
WHEREAS, in accordance with the above-quoted provisions of ARTICLE SIXTH of the
Will, one-fifth of the trust assets are now distributable to FRED C. TRUMP, III and
MARY LEA TRUMP, the surviving adult children of FRED C. TRUMP, JR., deceased; and
WHEREAS, in accordance with the above-quoted provisions of ARTICLE SIXTH
of the Will, four-fifths of the trust assets continue in trust for the benefit of each of
OONALD J. TRUMP, -JIDBEIIT S • TRUMP, MARYANNE TRliMP BARRY and ELIZABEI'H TRUMP GRAU; and
WHEREAS, OONALD J. TRUMP, ROBER!' S. TRUMP, MARYANNE TRUMP BARRY and ELIZABEI'H TRUMP
GRAU, have requested the Trustee to continue to hold their respective share of the assets
"in solido"; and
WHEREAS, annexed hereto as Exhibit B is a Chase statement reflecting transactions

pertaining to the principal and income of the respective shares of the Trust and
covering the period from June 25, 1999 through August 31, 2000 (said first intermediate
account of proced.ings and said statement somet:imes collectively referred to herein
as the "Account") ; and
WHEREAS, the undersigned are familiar with the provisions of the Will and with
all of the facts in connection with the administration of the Trust and have examined
the Account and are satisfied that the same is in all respects correct and that nothing
has been omitted therefrom to the prejudice of the undersigned; and
3.
WHEREAS, the Trustee has prepared a first intermediate account of its
proceedings covering the period from January 15, 1968,to March 31, 2000, a copy
of which is annexed hereto as Exhibit C; and
WHEREAS, the undersigned are desirous of avoiding the necessity of a judicial
settlement of the account, the legal proceedings incident thereto and the expenses
involved therein and have requested the Trustee to refrain from taking such legal
proceedings, and the Trustee has consented to refrain from taking such action,
unless it should at any time be necessary or advisable, in its opinion, to account to
.any person or persons other than the undersigned, upon the condition that an instrument
in the form hereof be duly executed and delivered by the undersigned.
NOW THEREFORE, in consideration of the premises, the undersigned do hereby
-covenant and agree to and with The Chase Manhattan Bank, individually and as Trustee
of the said Trust as follows:
FIRST: The undersigned, FRED C. TRG1P III and MARY LEA TRUMP represent to the
Trustee that he (she) is a person entitled to distribution of the Trust and he (she)
is under no legal disability.
SECOND: The undersigned DONALD J. TELWP, ROBERT S. TRUMP, MARYANNE TRUMP BARRY
and ELIZABETH TRUMP GRAU, the children of FRED C. TRUMP, jointly and severally represent
to the Trustee that they collectively constitute or represent the only persons with
a continuing interest in the Trust and that none of the undersigned is under a legal
disability.
THIRD: The undersigned hereby ratify, approve, and confinn the account
and the schedules .annexed thereto, as well as each and every one of the acts and
proceedings and, without limiting the generality of the foregoing, the sales, purchases,
retentions of investments and cash, changes of investments, allocations of receipts
and expenses between principal and income, and disbursements of the Trustee therein
4;
c
set forth, and expressly waive any right to enforce a judicial settlement of the
account, it being the purpose and intention of the undersigned that this instrument
and the releases herein contained shall be delivered to the Trustee as binding upon
the undersigned and in all respects as conclusive as though the account had been
'.
rendered in the course of a judicial proceeding or action and had thereupon been
allowed and settled by a decree of a court of.ccrnpetent jurisdiction. The undersigned

hereby waive the issuance and service of process in any judicial proceeding brought
for the settlement of the account, and consent to the entry of a decree judicially
settling the .same without further notice.
FOURI'H: The undersigned· hereby approve the computation of carmissions as set

forth in Schedule H of the Account and hereby authorize the Trustee to pay over to
itself the sum·of $7,186.33, representing the total principal commissions, due Chase
as Trustee upon this accounting as ccmputed and set forth in Schedule H of this
account.
FIFTH: The undersigned hereby consent to the payment by the Trustee of
the sum of $5,.000.00, the amount of its. counsel fees and disbursements in connection
·with the settlement of this account and authorize and direct the Trustee to pay the
said sum of $5,000.00 to Durben &Tosti, LLP; its attorneys, before the division
and delivery of any applicable assets.

The undersigned hereby consent to the payment by the Trustee of
the sum of $2,700.00, the fee for the preparation of this account and authorize
and direct the Trustee to pay the said sum of $2,700.00 to FSS Trust Service
before the division and delivery of any applicable assets.
SIXTH: FRED C. TRUMP, III and MARY LEA TBljMP (the "distributees"), hereby
acknowledge the receipt, transfer and conveyance of cash and securities shown as
attached Exhibit D including a 2.5% interest in the fee title of Shorehaven Apartments
5.
#1 and a 5% interest in the fee title of Shorehaven Apartments #3, in full satisfaction
of their right, title and interest in and to the principal and income of said Trust.
SEVENTH: The distributees covenant with and represent to the Trustee that,
to the date of this instrument they have not assigned, alienated, transferred or in
any way encumbered their respective.rights, titles and interests in and to the Trust
property distributed in accordance with the terms of this instrument, and further
covenant and agree that, to the extent of the property they have receipted for
hereunder they will indemnify and save harmless the Trustee of and from any,and all
loss, costs, damages, claims, and demands of whatever kind or nature that the
Trustee may suf fer by reason of having transferred and delivered to the undersigned
distributees the cash and property hereinabove acknowledged.
EIG1TH: The undersigned and the distributees hereby release, remove and
forever discharge The Chase Manhattan Bank individually and as Trustee of said Trust
of and from all action or actions, cause or causes of action, suits, sums of money,
damages and claims and demands whatsoever, whether at law or in equity, which
against the said The Chase Manhattan Bank the undersigned and the distributees ever ·
had, now have or hereafter can, shall or may have by reason of any act or omission,
cause or thing whatsoever recited, contained, appearing or set forth herein or in
the Account or reasonably to be inferred from anything herein or therein contained,
including with respect to the Partial Distribution and the Trust property distributed
hereunder, the receipt of which is hereinabove acknowledged.
The distributees hereby jointly and severally agree that if any
or all of the cash or other property distributed to them hereunder, the receipt of
which is hereinabove acknowledged, shall be required at any time hereafter to discharge
any debts, expenses, taxes or other obligations of the Trust, they will refund on
demand to the Trustee such portion or all of said property as may be necessary for
the payment of said obliga.tion.
6.
·NINTH: This instrument_may be executed in counterparts and such counterparts
taken together shall constitute a single instrument which shall be binding upon the
heirs, executors, administrators, anecessors and assigns of the undersigned.anti the
distributees and shall run to the benefit of the successors and assigns of the Trustee.
IN WITNESS WHEREOF, the undersigned has executed this instrument on the date
and year opposite his or her name.
, 2000
.. .
Fred C. Trump,
M ea Trump
7.
STATE OF NEW YORK)
) ss:
COMTf OF Af Ñ&5AU
On the day of in the year 2000, before me, the unde signed,
personally appeared FRED C. TRUMP, III, personally known to me or proved to -me on
the basis of satisfactory evidence to be the individual whose name is subscribed
to the within instrument and acknowledged to me that he executed the same in his
capacity and that by his signature on the instrument, the individual or the person
upon behalf of which the individual acted, executed the instrument.
Notary'Public
LYNNEA.VAZ
Notary
Public,StateofNewWrk
No. 01VA5020628
Qualified in Nassau County
Commission Expires November22, 20A2
STATE OF NEW YORK)
) ss:
COMTY OF V#Jg4u
)
On the G day of fWijid in the year 2000, before me, the undersigned
personally appeared MARY LEA TRUMP, .personally knowh to me or proved to me on
the basis of satisfactory evidence to be the individual whose name is subscribed
to the within instrument and acknowledged to me that she executed the same in her
capacity and that by her -signature on the instrument, the individual or the person
upon behalf of which the individual acted , executed the instrument.
j ANTHONY H. GESUALE
; Notary Public, State of NewYork
No. 01GE6043795
Qualified in Nassau Coun
Commission Expires June 28, 2002
..... ... ....,,.. - -.,,. ...-.....-.-. .,... ...-. --..
EXHIBIT "E"
F.H.A. No.
012-42055
WILLIAM WALTER AND PRESIDENT AND DIRECTORS OF

THE MANHATTAN COMPANY, AS TRUSTEES,
Landlords
TO
BEACH HAVEN APARTMENTS NO. 5 INC.
Tenant
Dated May 1, 1950
FARRELL & TOSTI

Attorneys for Landlord
89-31 161st Street
Jamaica 2, New York
This instrument has been executed in 8 counterparts, of which

the within is counterpart number
TABLE OF CONTENTS
.Article Page
No.
Parties and description of premises ............ ...... . 1
Rent, amount of, during initial term ............ ..... . 4
I Rent, covenant to pay ............ ............ ...... . 4
II Use of premises ............ ............ ........... . 5
III Payment of taxes, assessments, etc ............ ...... . 5
IV Insurance ............ ....... .. : . ............ ..... . 9
v Landlord's right to perform Tenant's covenants ...... . 13
VI Construction of buildings; repairs and maintenance ... . 14
VII Compliance with orders, ordinances, etc ............ .. . 17
VIII Changes, repairs, alterations and erection of new build-
ings by Tenant ............ ............ .......... . 18
IX Mechanic's liens ............ ............ .......... . 22
X Covenant against waste ............ ............ ... .. 23
XI Inspection of premises by Landlord ............ ..... . 23
XII .Assignment and subletting ........... : ............ .. 24
XIII Excavations on adjoining property ............ ..... . 25
XIV Public utility charges ............ ............ ...... . 26
XV Indemnification of Landlord ............ ............ . 26
XVI Damage or destruction.. .. .. .. .. . .. . .. . .. . . . . . .. .. . . 27
XVII Condemnation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
XVIII Vault space . . . . . . . . . . . . . . . . . . . • . . . . . . . . . . . . . . . . . . . . 36
XIX Conditional limitations; default provisions. . . . . . . . . . . . 36
XX Renewal privileges, rent during renewal terms. . . . . . . . . 48
XXI Invalidity of particular provisions. . . . . . . . . . . . . . . . . . . 49
XXII Notices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
XXIII Surrender of premises ............ ............ ..... . 51
XXIV Quiet enjoyment ............ ............ .......... . 51
XXV Limitation of Landlord's Liability ............ ....... . 51
XXVI Estoppel certificate by Tenant and Landlord ......... . 52
XX¥II Remedies cumulative no waiver, no oral change ... : ... . 53
XXVIII Definition of certain terms ............ ............ .. . 54
XXIX Covenants to bind benefit respective parties .......... . 55
XXX Reference to Counterparts ............ ............ .. . 55
The foregoing table of contents is inserted under the same cover as
the lease that follows for the purpose of convenience and reference only
and is not to be deemd or construed in any way as part of said lease
nor as supplemental thereto or amendatory thereof.
Tms INDENTURE, made as of the first day of May, 1950 by and
between WILLIAM WALTER, residing at 100-53 199th Street, Hollis,
New York, and President and Directors of the Manhattan Company,
a corporation organized and existing under the laws of the State of New
York, with offices at 40 Wall Street, New York, New York, as Trustees
under an Indenture of ·Trust made by FRED C. TRUMP, as Grantor, and
dated August 10, 1949, parties of the first part (hereinafter referred
to as the Landlord), and BEACH HAVEN APARTMENTS No.5 INc., a New
York corporation, having an office at 89-31 161st Street, Jamaica 2,
New York, party of the second part (hereinafter referred to as the
Tenant),
.WITNESSETH:
That the Landlord, for and in consideration of the rents, covenants
and agreements hereinafter reserved, mentioned and contained on the
part of the Tenant, its successors and assigns, to be paid, kept and per-
formed, has demised and leased, and by these presents does demise and
lease unto the Tenant, and the Tenant does hereby take and hire, upon
and subject to the conditions hereinafter expressed, the real property
together with the buildings and improvement s to be erected thereon,
together with all equipment, fixtures and machinery therein contained
and all furniture and furnishings, together with any and all additions
thereto and replacements thereof, bounded and described as follows:
ALL those certain lots, pieces or parcels of land, situate,
lying and being in the Borough of Brooklyn, County of Kings,
PARCEL 1
BEGINNING at the corner formed by the intersection of the
north side of Avenue Z with the west side of West 3rd Street;
running thence west along the north side of Avenue Z, 416.71
feet to the land of the Brooklyn City Raih·oad; running· thence
north along the land of the Brooklyn City Railroad, 225.96 feet
to the center line of Dank Court; running thence easterly along
the center line of Dank Court, 396 feet more or less, to the west
side of West 3rd Street and running thence southerly along the
west side of West 3rd Street, 225 feet to the corner, the point
or place of beginning.
PARCEL 2
BEGINNING at the corner formed by the intersection of the
south side of Avenue Z with the west side of West 3rd Street;
running thence West along the south side of Avenue Z 424.57
feet to the land of Brooklyn City Railroad; running thence
.south along the land of the Brooklyn City Railroad 230.97 feet
48
ARTICLE XX
RENEWAL PRIVILEGES-RENT DuRING RENEWAL TERMS
SECTION 1. The Tenant shall have the right, to be exercised as

hereinafter provided, to extend the term of this lease for a period of
99 years upon the following terms and conditions:
(1) That the Tenant is not in default in the performance of any
of the terms, covenants and conditions herein contained in
respect to a matter as to which notice of default has been
given hereunder and which has not been remedied or is not in
the process of being remedied promptly and with due diligence
within the time limited in this lease, at the time of the exercise
of such right;
(2) That the renewal term shall be upon the same terms, cove-
nants and conditions (including the amount of basic rent)
as in this lease provided, except that there shall be no further
privilege of renewal of this lease ;
(3) That all other payments upon the part of the Tenant to be made
as in this lease provided shall continue to be made during
such renewal term, including, but without limiting the gen-
erality of the foregoing, payment of taxes, assessments, water
charges, fire and other insurance premiums.
SECTION 2. Notwithstanding anything in this Article contained to

'I' the contrary, the Tenant shall not be entitled to any renewal term if at
'j
the time of the commencement of such renewal term the Tenant shall
be in default under any of the terms, covenants or conditions of this
lease in respect to a matter as to which notice of default has been given
hereunder and which has not been remedied within the time limited
in this lease or if this lease shall have terminated prior to the com-
mencement of such renewal term.
SECTION 3. The Tenant shall exercise its right to the renewal term
in the following manner: Not more than twenty-four (24) months and
49
at least eighteen (18) months prior to the expirat ion of the initial term
of this lease, the Tenant shall notify the Landlo rd in writing of its
election to exercise the right to renew the term of this lease for said
period of 99 years from the date of the expirat ion of the initial term.
Such notice of election shall be given in the manne r in this lease pro-
vided for the giving of notices.
SECTION 4. If any part of the princip al amoun t of any mortga ge

of the leasehold estate of the Tenant in the demised premises shall be
unpaid at the time that the Tenant has the right to the renewal term of
this lease, as provid ed for in this Article, then and in that event the
holder of such mortga ge andjor the Federa l Housin g Commissioner or
liis successors in office if such mortga ge is insured under the Nation al
Housin g Act, shall have the right to extend the term of this lease for
a period of ninety-nine (99) years upon the terms and conditions set
forth in this Article and to be exercised in the same manne r as hereinbe-
fore provid ed for the Tenant , either in its or his behalf, or in behalf of
th·e Tenant. And if such lease be renewed in behalf of the holder of such
mortga ge or the Federa l Housin g Commissioner or if any holder of
a mortgage on this leasehold estate, or the Federa l Housin g Commis-
sioner, has acquired this lease throug h foreclosure or otherwise, and
continues to be the holder thereof, such renewal shall be as to them
or either of them without person al liability beyond the period of their
occupancy. The Tenant does hereby empower the bolder of such mort-
gage and/or the Federa l Housin g Commissioner to exercise such right
in the name and behalf of the Tenant, if the holder of such mortga ge
and/or the Federa l Housin g Commissioner elects to exercise the right
to extend the term of this lease in behalf of the Tenant .
ARTIC LE XXI
INVALIDITY OF PARTICULAR PROVISIONS

If any term or provisi on of this lease or the applica tion thereof
to any person or circumstances, shall to any extent be invalid or unen-
forceable, the remain der of this Iease, or the applica tion of such term
I,
!
56
the President and Directors of the Manhat-

IN WITNESS WHEREOF,
tan Company and William Walter as Trustees under an Indenture of
Trust dated August 10, 1949 ma--WH¾*m··-W*4er as landlord, have
hereunto set their hands and seals, and Beach Haven Apartments No. 5
as tenant, and President and Directors of the Manhattan Company

Inc.,
have caused these presents to be signed by their duly authorized oilicers
and their corporate seals to be affixed hereto as of the day and year first
above written.
WILMAM WALTER (Landlord)
Di•
President and ctors of the
Manhatta om any ord)
.... ....... . ......... . ..., ..

y
Vice-President
As Trustees under an Indenture

Trust made by Fred C. Trump, as
Grantor, and dated August10,1949.
ATTEsT:
A4tent Trust OÁer
BEASH HAVEN TMENTS No. 5 INo.
... .. . . . . . . . ....... ..........

By
President (Tenant)
[
ATT T:
Secretary
57
STATE OF New Yonx, 1 _ .

COUNTY OF NEw YoBr, j
On the Êfday of 1950, before me came WHRAM

WALTER, 10 me known and known to me to be the individual described
in and who executed the instrument an e duly acknowl-
foregoing
edged to me that he executed the same.
. . . . . . - . . . +. . . . . . . . . . . . . . .
JoHN H. MEDLAR
Notary Publio. state of New York
No. 41-2646800
Qual. in Queens Co. Gert.
filed with Olerks of N. Y., Kings, Nassau,
SufEolk Counties and Register in Quesus;,
New York and Kings Countaes
Term Expires March 80, 1851
STATE of N£w Yoax,

COUNTY OF NEw Yonx,
On the/f day o , 1950, before me came

to me known, who, be b e duly sworn, did depose d say tha
he resides at
f ,-4(Afo d, 4 ; that he is a
Vice President of PRESIDENT AND l)IRBOTORS OF THE ANHATTAN COM-
PANY, the corporation described in and which executed the foregoing

instrument; that he knows the seal of said corporation; that the seal
affixed to said instrument is such corporate seal; that it was so affixed
by order of the board of directors of said corporation and that he signed

his name thereto by like order.
. .... ..................
JOSEPH W. CARU80
NOTARY PUBIJC.StatestNewYork.
Qualified in King Con:iti
No. 24-5636800
Certificates filed in:
Xings Co. Reg.-Richmond Co. Clk's
New York County Clerlis & Register
Queens County Clerk-s & Register
Bronx County Cler1fs & Register
Commission Expires March 30, 1958
58
SnTE OF NEw TORK,

COUNTY OF ÑEW YORK,
On the day of Jane, 1950 before me came FRED C. TauuP,

to me known, who being by me duly sworn, did depose and say that he
resides at 85-14 Midland Parkway, Jamaica, New York; that he is the
President of Beach Haven Apartments No. 5 Inc., the corporation
described in and which executed the foregoing instrument; that he
seal of corporation instrn-
knows the said ; that the seal a yed to said
ment is such corporate seal; that it was so a@xed b order of the Board
of directors of said corporation and that he si , d his name thereto
by like order.
JOHN H. MEDLAR
Notary Public. State of New York
No. 43-2646800
Qual In Queens Co. Cert.
filed with Clerks of N. Y., Xings, Nasm
Sufibik Counties and Register in Quee
. New York and Kings Counties
Term Expires March 30, 1951
STATE OF NEW YORK
F. H. A. Loan No. 01242055
MORTGAGE ON LEASE
(Under Section 608)
o00
BEACH HAVEN APARTMENTS NO. 5 INC.
Mortgagor
To
& PRESIDENT AN D DIRECTORS OF THE MANHATTA

COMPANY
Mortgagee
o00
FnazLL & TOSTI

Attorneys for Mortgagor
. 89-31161st Street
Jamaica, N. Y.
SUPREME PluXUNG CO., inc.. 41 Mmutu 5TREn, K Y., BARCLAr 7-0349

asp- 49
THIS MORTGAGE, made the / f day of , 1950 by and
between BEACH HAVEN APARTMENTs No. 5 INo., a New York corpora-
tion, having an office at 89-31161st Street, Jamaica 2, New York, Boom
705, the Mortgagor, and PRESIDENT AND DmECTORS OF THE MANHATTAN
COMPANY, a corporation Organized and existing under the laws of the

State of New York, having its principal place of business at 40 Wall
Street, New York, New York, the Mortgagee.
WHEREAs WILLIAM WALTER, residing at 100-53 199th Street, Hollis,

New York, and President and Directors of the Manhattan Company, a
corporation organized and existing under the Laws of the State of New
York, with offices at 40 Wall Street, New York, N. Y., as Trustees under
an Indenture of Trust made by Fred C. Trump, as Grantor, and dated
August 10, 1949, as Landlords, did, by a certain indenture of lease dated
as of the 1st day of May, 1950, and recorded or to be recorded in
the OHice of the Register of Kings County, demise and lease unto BEACH
HAVEN APARTMENTs No. 5 INC., as Tenant, and to its successors and
all and singular the premises hereinafter mentioned and de-
assigns,
seribed, TO HAVE AND TO HOLD the same unto the said BEAcH
HAVEN APARTMENTs No. 5 INo., the mortgagor its successors and assigns
for and and until.the full term of ninety-nine com-
during (99) years,
mencing on the 1st day of May, 1950 and ending at midnight on
the last day of April, 2049, upon the terms, covenants and conditions
therein set forth, and granting to the Tenant, at its option, the right
to renew the said lease (hereinafter sometimes referred to as the
''Ground Lease") for one additional term of ninety-nine (99) years
upon giving notice as therein required and upon the terms, covenants
and conditions therein set forth, and
WHEREAs the said Mortgagor is justly indebted to the Mortgagee

in the principal sum of Two Million, Eighty Two Thousand Dollars
($2,082,000.00) lawful money of the United States of America, which

sum or so much thereof as may from time to time be advanced, with
interest on the unpaid balance thereof at the rate of four per cent (4%)
per annum, is payable in accordance with the terms of a certain note
oi obligation bearing even date herewith, as follows:
Interest alone shall be payable on the first day of 950

and on the first po,f each month thereafter to and including
the first day of 1951.
W-
26
indenture of mortgage on lea·sehold the terms "owner of the Ground

Lease"
or "owner of the lease", or "owner of the leasehold estate",
or words of similar import appear, they shall be construed to mean
the Tenant or the owner of the Tenant's leasehold estate.
IN WrrNass Wana£or, this niortgage has been duly executed by

the Mortgagor.
BEACH HAVEN APARTMENTS No. 5 Inc.
President
Atte :
Secretary
STATE OF NEw ToBK,
COUNTY OF NEw YoBK, j
On the / day of , 1950 before me came FRED C. TRUMP,

to me known, who being by me duly sworn, did depose and say that he
resides at 85-14 Midland Parkway, Jamaica, New York; that he is the
President of BEACH HAVEN APARTMENTS No. 5 INo., the corporation de-
scribed in and which executed the foregoing instrument; that he knows

the seal of said corporation; that the seal affixed to said instrument is
such corporate seal; that it was so affixed by order of the board of
directors of said corporation and that he signed his name thereto by
like order.
"F"
EXHIBIT
5
FRED C. now residing in the County of
I, TRUMP,
State of New York, do make, publish and declare this

Queens,
to be Last Will and Testament, hereby revoking all wills

my
and codicils heretofore made by me.
FIRST: I direct my executors to pay from the
principal of my residuary estate, as an expense of
administration without apportionment, all estate,
succession, inheritance and transfer taxes, including any
interest and penalties thereon, imposed as a result of my
death by any state or federal laws with respect to any
property devised or bequeathed by this Will or any Codicil
hereto, but excluding (i) any generation-skipping transfer
tax imposed by Section 2601 of the U.S. Internal Revenue
Code and any comparable tax imposed by any other taxing
authority; and (ii) any additional estate tax which may be
imposed by Section 2032A of the Internal Revenue Code.
SECOND: I give and bequeath all of my tangible
personal property to my wife, Mary Anne Trump, or if she
does not survive me, I give and bequeath the said property
to my children who survive me, to be divided among them as
they may agree in as nearly equal shares as possible. All
expenses incurred by my executors in storing, packing,
shipping and insuring any of the said property shall be paid
from the principal of my residuary estate, as an expense of
administration.
THIRD: (a) I give, devise and bequeath all of my
real property, including any condominium apartment, that I
or my family shall be using at the time of my death as a
place of residence, whether permanent, temporary or
seasonal, together with all buildings and improvements
thereon and all insurance policies relating thereto, to my
wife, Mary Anne Trump, or if she does not survive me, to my
children who survive me in equal shares as tenants in
common.
lI•i (b) I give and beque ath all right, title and
j: inter est that I may own at my death in and to any
I' coope rative apartm ent that I or my family shall be using at
li the time of my death as a place of reside nce, includ ing the
I
propr ietary lease and the shares of stock or other intere st
. in the landlo rd corpo ration eviden cing such owner ship, to my
'
wife, Mary Anne Trump , or if she does not surviv e me, to my
childr en who surviv e me in equal shares as tenan ts in
common.
FOURTH: I give and beque ath the sum of TWENTY
MILLION DOLLARS ($20,0 00,000 ) to my childr en who surviv e me,
to be divide d among them in equal share s.
FIFTH: (a) I give and beque ath to my
grand childr en who surviv e me (other than the childr en of my
son, Fred c. Trump, Jr.), to be divide d among them in equal
share s, a pecun iary legacy equal to the amoun t of the unused
portio n (as define d in Sectio n 2632(b ) (2) of the U.S.
Intern al Revenu e Code) determ ined immed iately before my
death , if any, of my gener ation- skipp ing transf er tax
exemp tion provid ed by Sectio n 2631(a ) of the said Code.
(b) I give and beque ath to each child of my son,
Fred c. Trump , Jr., who surviv es me an amoun t equal to the
amoun t beque athed to each of my other grand childr en under
parag raph (a) of this Artic le FIFTH.
SIXTH: In recog nition of over forty years of
loyal and faithf ul servic e, I give FIFTY THOUSAND DOLLARS
($50,0 00) to Amy Luers sen, if she surviv es me, and I give
her an additi onal SEVENTY-FIVE THOUSAND DOLLARS ($75,0 00) on
each of the first and second anniv ersari es of my death on
which she is living .
SEVENTH: (a) I give, devise and beque ath my
residu ary estate , both real and perso nal, exclud ing any
prope rty over which I may have a power of appoin tment, to my
truste es, in trust, to pay the net income in quart erly or
more frequ ent instal lment s to my wife, Mary Anne Trump , as
long as she lives.
2
,.
,.'
I I authorize my trustees to distribute to my said
! wife, at any time and from time to time, such amounts from
the principal of the trust as the trustees deem advisable in
their discretion. The authority granted to my trustees by
this paragraph may be exercised for any reason they deem
sufficient and shall include the power to terminate the
trust.
If my executors elect to qualify only a portion of
the trust under this Article SEVENTH (a) for the marital
deduction under Section 2056(b)(7) of the U.S. Internal
Revenue Code, any distribution s of principal made pursuant
to the foregoing paragraph and any payments made to the
personal representativ es of my said wife's estate, or as
they may direct, pursuant to the following paragraph of this
Article shall reduce the portion of the trust with respect
to which such election is made before reducing the portion
with respect to which such election is not made.
Upon the death of my said wife, I direct my
trustees to pay to the personal representativ es of my said
wife's estate, or as they may direct, upon receipt of notice
in writing from them, the amount equal to the excess of the
total death taxes payable by my said wife's estate over the
total death taxes that would have been payable by her estate
if no portion of the value of this trust had been included
in her gross estate, and to dispose of the remaining
principal of the trust pursuant to the provisions. of Article
EIGHTH hereof.
(b) If my said wife does not survive me, I direct
that, upon my death, my said residuary estate be disposed of
pursuant to the provisions of Article EIGHTH hereof.
EIGHTH: All property directed to be disposed of
pursuant to the provisions of this Article shall, upon the
occurrence of the event which gives rise to such direction,
be divided into as many equal shares as may be necessary to
provide one such share for each child of mine who is living
on the date of such event and one such share for the issue
3
collectiv ely of each child of mine (other than my son, Fred
c. Trump, Jr.) who has died prior to such date leaving issue
who are living on such date.
( I direct my executors or my trustees, as the case
! may be, to dispose of any share provided for my son, Donald
J. Trump, pursuant to Article NINTH hereof and to dispose of
any shares provided for any other children of mine pursuant
to Article TENTH hereof, and to distribute one such share to
the issue who are living on such date, per stirpes, of each
then deceased child of mine (other than my son, Fred C.
Trump, Jr.).
NINTH: Any share of property directed to be
disposed of pursuant to this Article, and, anything to the
contrary herein notwithsta nding, any other assets of my
estate or any other share of the principal of any trust
created by this Will that shall be distributa ble to my son,
Donald J. Trump, shall, upon the occurrence of the event
which gives rise to such direction or distributi on, be held
by my trustees in a separate trust for the benefit of my
said son and his issue, or shall be added to any then
existing trust under this Article for the benefit of my said
son and his issue, to pay so much or all of the net income
of the trust to or among a group of permissib le
beneficia ries composed of my said son and his issue (of
whatever degree, whether or not per stirpes) living from
time to time, or to any one or more of such group to the
exclusion of the others, at such times and in such
proportio ns, all as the distributi on trustee (hereinaf ter
named) deems advisable in his discretion , and to accumulat e
the balance, if any, of such net income not so paid in any
year, or in the distributi on trustee's discretion , to
accumulat e the entire net· income in any year, and to add all
accumulat ed income to principal annually during the term of
the trust.
I authorize my trustees to distribute to any one
or more of the permissib le income beneficia ries, at any time
4
and from time to time, such amounts from the principal of
the trust, and in such proportions, as the distribution
trustee deems advisable in his discretion. The authority
granted to the distribution trustee by this paragraph may be
exercised for any reason he deems sufficient, including tax
planning for any of such beneficiaries or their families,
and shall include the power to terminate the trust.
Upon the death of my said son, I direct my
trustees to distribute the remaining principal of the trust,
if any, in accordance with a limited power of appointment
hereby granted to my said son, exercisable only by specific
reference to this power contained in his Will duly admitted

!
to probate, to or among my said son's wife and my issue
(other than the holder of the power but including the issue
of my son Fred C. Trump, Jr.), of whatever degree, whether
or not per stirpes, or to any one or more of them to the
exclusion of others, in such proportions and in such manner,
whether in trust for the benefit of one or more of them or
otherwise, as my said son may direct; provided, however, the
power to appoint to or for the benefit of my said son's wife
shall be limited to the power to appoint in further trust,
with an income interest only in my said son's wife and the
trust remainder, upon the death of his wife or such earlier
date as my said son may direct, passing to or among my issue
(other than the holder of the power but including the issue
of my son Fred C. Trump, Jr.), of whatever degree, whether
or not per stirpes, or to any one or more of them to the
exclusion of the others, in such portions and in such
manner, whether in trust for the benefit of one or more of
them or otherwise as my said son may direct. If my said son
fails to exercise such power effectively, in whole or in
Part, then to the extent of such failure, I direct my
trustees to distribute the said principal to the then living
issue, per stirpes, of my said son, or in default of such
issue, to my then living issue, per stirpes, other than the
issue of my son, Fred C. Trump, Jr., provided, however, that
5
if pursua nt to this sentenc e the whole or a part of the
princi pal would be distrib utable to a.child of mine for whom
a trust is then in existen ce under this Will, I direct that
such princi pal shall be added to the princip al of child' s
trust hereun der, for admini stratio n and distrib ution as a
part thereo f.
TENTH: Each share of proper ty directe d to be
dispos ed of pursua nt to this Articl e shall, upon the
occurr ence of the event which gives rise to such directi on,
be held by my trustee s upon a separa te trust, one such trust
for the benefi t of each child of mine other than my son,
Donald , for whom said share was provide d pursua nt to Articl e
EIGHTH, and as to each such trust to pay the net income to
such child in quarte rly or more freque nt install ments as
long as such child lives.
I author ize my trustee s to distrib ute to such
child of mine, at any time and from time to time, such
amount s from the princip al of such child's trust as the
distrib ution trustee of such trust (herein after named) ,
deems advisa ble in his or her discre tion. The author ity
grante d to the said distrib ution trustee by this paragra ph
may be exerci sed for any reason he or she deems suffic ient,
includ ing tax plannin g for such child and his or her family ,
and shall includ e the power to termin ate the trust.
Upon the death of a child for whom a trust is held
hereun der, I direct my trustee s to distrib ute the ·remain ing
princi pal of such child's trust, if any, in accorda nce with
a limite d power of appoint ment hereby granted to such child,
exerci sable only by specif ic referen ce to this power
contai ned in his or her Will duly admitte d to probat e, to or
among such child's spouse and my issue (other than the
holder of the holder of the power but includi ng the issue of
my son Fred C. Trump, Jr.), of whatev er degree , whethe r or
not per stirpe s, or to any one or more of them to the
exclus ion of others , in such propor tions and in such manner ,
whethe r in trust for the benefi t of one or more of them or
6
otherwi se, as such child may direct; provided , however, the
power to appoint to or for the benefit of such child's
spouse shall be limited to the power to appoint in further
trust, with an income interest only in such child's spouse
and the trust remaind er, upon the death of such spouse or
such earlier date as such child may direct, passing to or
among my issue (other than the holder of the power but
includin g the issue of my son Fred c. Trump, Jr.), of
whateve r degree, whether or not per stirpes, or to any one
or more of them to the exclusio n of the others, in such
iJ proport ions and in such manner, whether in trust for the
benefit of one or more of them or otherwi se as such child
may direct. If such child fails to exercise such power
p effectiv ely, in whole or in part, then to the extent of such
I failure ,
I
I direct my trustees to distribu te the said
I princip al to the then living issue, per stirpes, of such

child, or in default of such issue, to my then living issue,
per stirpes, other than the issue of my son, Fred c. Trump,
Jr., provided , however, that if pursuan t to this sentence
the whole or a part of the principa l would be distribu table
r to a child of mine for whom a trust is then in existenc e
,I under this Will, I direct that such princip al shall not be
distribu ted to such child but shall be added to the
princip al of such child's trust hereund er, for
adminis tration and distribu tion as a part thereof.
ELEVENTH: Any provisio n to the contrary herein
notwith standing , if, upon my death or the termina tion of any
trust created by this Will, includin g any trust created by
this Article , any assets of my estate or any share of the
princip al of such trust shall be distribu table to a
grandch ild or more remote descend ant of mine who has not
then attained the age of forty (40) years, I direct my
trustee s to hold such assets or share upon a separate trust
i for the benefit of such person, or to add such share of
princip al to any then existing trust under this Article for
I the benefit of such person, and as to each such trust to pay
I 7
II
'
;i
. .
the net income to such person in quarterly or more frequent
installments until such person attains the age of forty (40)
years, and thereupon to distribute the remaining principal
of the trust to such person.
I authorize my trustees to distribute to any
.. person. for whom. is. held. in. trus.t herewader,- a-t

property any
time and from time to time, such amounts from the principal
of such person's trust as my trustees deem advisable in
their discretion. The authority granted to my trustees by
this paragraph may be exercised for any reason they deem
sufficient, including tax planning for the benefit of such
person and his or her family, and shall include the power to
terminate the trust.
Upon the death of a person for whom a share is
held in trust before attaining the age of forty (40) years,
I direct my trustees to distribute the remaining principal
of such person's trust to the issue of such person who
survive such person, per stirpes, or such issue failing, to
the issue, per stirpes, who survive such person of such
person's nearest ancestor who was an issue of mine, or if
none, to my issue who survive such person, per stirpes,
other than the issue of my son, Fred C. Trump, Jr.
TWELFTH: Anything contained herein to the
contrary notwithstanding, if upon my death or the
termination of any trust created hereunder all or a part of
my estate or of the principal of such trust is directed to
be held in trust for the benefit of a person or persons for
whose benefit a trust is created or in existence at that
time under the Last Will and Testament of my wife, Mary Anne
Trump, which has identical dispositive provisions and no
conflicting administrative provisions, I authorize my
executors or my trustees, as the case may be, in their
discretion, to distribute any part or all of such property
to the trustees under my said wife's Will, to be added to
the trust thereunder for such person or persons and to be
administered and distributed as a part thereof.
8
THIRTEENTH: (a) Anythin g herein contain ed to the
contra ry notwit hstand ing, each trust under this Will shall
termin ate no later than the date twenty- one (21) years after
the death of the surviv or of the issue of my parent s and the
issue of my wife's parent s in being at my death. Any trust
in existen ce on such date shall thereup on termin ate and the
remain ing princi pal of such trust shall be distrib uted to
the then income benefi ciary of the trust.
(b) If, upon the termin ation of any trust created
by this Will pursua nt to paragra ph (a) above, a portion of
the princip al of such trust shall vest in absolu te owners hip
in a minor or minors , I author ize my trustee s, in their
discre tion, to hold all or any part of the proper ty so
vested in each such minor in a separat e fund for the benefi t
of such minor, and to pay the net income to such minor and
to distrib ute to such minor so much or all of the princip al
as my trustee s deem advisa ble in their discre tion. Upon
such minor' s attaini ng the age of majori ty, I direct my
trustee s to distrib ute the remaini ng princip al to him or to
her, and upon such minor' s death before attaini ng that age,
I direct my trustee s to distrib ute the said princip al to the
execut ors or admin istrato rs of the estate of such minor.
The author ity conferr ed upon my trustee s by this
subdiv ision shall be constru ed as a power only. My trustee s
as donees of such power: (a) shall have all the powers ,
rights , discre tions, exempt ions and immun ities granted to,
and the duties and obliga tions imposed upon, them by other
provis ions of this Will; (b) shall serve withou t bond or
other securi ty; and (c) shall be entitle d to the same
compen sation as if the proper ty subjec t to such power were
held in trust by them.
FOURTEENTH: If my wife, Mary Anne Trump, and I
should die simulta neousl y or in such circum stances that the
order of our deaths cannot be establi shed by proof, I direct
that my said wife shall be presume d to have survive d me only
for the purpos es of Articl e SEVENTH (a) of this Will.
9
If any other bene ficiar y and I shoul d die in such
circu mstan ces that the order of our death s canno t be
estab lishe d by proof , I direc t that such bene ficiar y shall
be presu med to have prede cease d me.
If a remai nderm an of any trust creat ed hereu nder
and the incom e bene ficiar y of such trust shoul d die in such
circu mstan ces that the order of their death s canno t be
estab lishe d by proof , I direc t that such remai nderm an shall
be deeme d to have prede cease d such incom e bene ficiar y.
FIFTEENTH: (a) Where ver my trust ees are direc ted
by any of the foreg oing provi sions of this Will to pay net
incom e to a perso n who has not yet attai ned the age of
twent y-one (21) years , I autho rize my trust ees, anyth ing
herei n conta ined to the contr ary notw ithsta nding , to
accum ulate any porti on or all of the net incom e other wise
payab le to such perso n as my trust ees deem advis able in
their discr etion until such perso n has attai ned said age and
to add such accum ulated incom e to the princ ipal from which
it is deriv ed at least annu ally.
(b) In makin g any payme nt of incom e or
discr etion ary distr ibuti on of princ ipal under any provi sions
of this Will to any perso n, I autho rize my trust ees, in
their discr etion , to apply such income or princ ipal or any
part there of for the suppo rt, educa tion, maint enanc e or
bene fit of such perso n, or to pay or distr ibute such incom e
or princ ipal, or any part there of, direc tly to such perso n
or to the legal ly appoi nted comm ittee, conse rvato r or
guard ian of such perso n; and, if such perso n is a minor , I
also autho rize my trust ees to pay or distr ibute such incom e
or princ ipal or any part there of, for such mino r's use, to
eithe r a paren t or to the legal ly appoi nted guard ian of the
perso n or prope rty of such minor or to a custo dian for such
mino r under an appli cable Unifo rm Gifts to Mino rs Act or any
comp arabl e statu te (and, if perm issibl e under appli cable
law, to autho rize any such custo dian to retai n any prope rty
so distr ibute d until such minor attain s the age of twent y-
10
one (21 ) yea rs) , or to any adu lt
wit h whom suc h min or
res ide s.
(c) In ma kin g any dis cre tio nar y pay me
nt or
acc um ula tio n of inc om e or dis tri
bu tio n of pri nci pal und er
any pro vis ion of thi s Wi ll, my tru
ste es may but nee d not
con sid er the oth er ass ets and sou
rce s of inc om e ava ila ble to
any ben efi cia ry, and may but nee
d not con sid er any pri or
une qua l pay me nts of income or dis
tri bu tio ns of pri nci pal
among the res pec tiv e ben efi cia rie
s.
SIXTEENTH: If upo n my dea th or the ter mi nat
ion
(wh eth er pa rti al or com ple te) of
any tru st cre ate d by thi s
Wi ll, any int ere st or int ere sts
in a fam ily bus ine ss (as
he rei na fte r def ine d) sha ll be dis
tri bu tab le to a ben efi cia ry
her eun der , suc h per son sha ll tak
e suc h pro per ty sub jec t to
the pro vis ion s of thi s Ar tic le.
If suc h per son (he rei naf ter ref err

ed to as the
"S ell er" ) sha ll at any tim e des
ire to se ll all or any
po rtio n of suc h pro per ty wh ile
any ch ild of min e is the n
liv ing , I dir ect tha t suc h pro per
ty sh all be off ere d fir st
to tho se of my chi ldr en who are
the n liv ing (ot her tha n the
Se lle r if he or she is a chi ld of
min e), in suc h pro por tio ns
as the Se lle r sha ll det erm ine .
Any suc h sal e sha ll be made
at the pri ce or pri ces and on the
ter ms and con dit ion s
agr eed upo n bet we en the Se lle r
and the buy er or buy ers . Any
suc h off er to my chi ldr en may be
wit hdr aw n if not acc ept ed
wi thi n thi rty {30) day s of suc h
off er, and if no chi ld of
min e acc ept s suc h off er, the Se
lle r may the rea fte r sel l suc h
pro per ty to ano the r or oth ers but
onl y for a pri ce not low er
tha n, and on ter ms and con dit ion
s not mo re fav ora ble tha n,
tho se off ere d by the Se lle r to
my sai d chi ldr en. Any ch ild
of min e acq uir ing pro per ty pur sua
nt to thi s Ar tic le sha ll
als o tak e suc h pro per ty sub jec t
to the pro vis ion s of thi s
Ar tic le.
For pur pos es of thi s Ar tic le, "fa

mi ly bus ine ss"
sh all mean a par tne rsh ip, cor por
ati on or any oth er en tity in
wh ich my spo use or ind ivi dua ls
who are my des cen dan ts or
11
trusts under which my spouse or my descendan ts are
interested own, directly or indirectly , in the aggregate,
fifty-perc ent (50%) or more of the equity or voting rights.
SEVENTEENTH: (a) I appoint my sons, Donald J.
Trump and Robert s. Trump, and my daughter, Maryanne T.
Barry, to be executors of and trustees under this Will.
Each of my sons, Donald and Robert, and my daughter,
Maryanne, shall be authorized at any time to designate an
individua l to be executor or trustee hereunder in his or her
own place and stead, to act in the event he or she should
fail to qualify or at any time should cease to act as
, executor or trustee for any reason. Any such designatio n
shall be made by a written instrumen t duly acknowledg ed and
may contain one or more successive alternate designatio ns in
listed order and may be revoked or changed by the individua l
having the power to make such designatio n by similar
instrumen t at any time before the designee takes office.
Any successor executor or successor trustee designated by my
said sons or daughter as aforesaid who qualifies hereunder
and every successor executor and successor trustee
designate d thereafte r who qualifies hereunder shall also
have the power to designate any individua l as successor
executor or successor trustee, as the case may be, in the
same manner specified in the immediate ly preceding sentence.
If at any time there are only two executors or two trustees
serving hereunder and no successor is designated pursuant to
the foregoing provision s, they shall designate an individua l
to be the third executor or third trustee, as the case may
be. Any such designatio n shall be made by a written
instrumen t duly acknowledg ed.
(b) I appoint Irwin Durben to be the distributi on
trustee of any trust under Article NINTH of this Will for
the benefit of my son Donald and his issue. If Irwin Durben
should fail to qualify or cease to act as distributi on
trustee, I appoint the first named of the following
individua ls who is willing and able to qualify to be
12
distributi on trustee: (i) Jack Mitnick; (ii) such
individua l as Irwin Durben shall have designated ; (iii) such
individua l as Jack Mitnick shall have designated .
I appoint my son, Robert, to be the distributi on
trustee of any trust under Article TENTH of this Will for
the benefit of my daughter Maryanne. If Robert should fail
to qualify or cease to act, I appoint the first named of the
following individua ls who is willing and able to qualify to
be distributi on trustee: (i) John Barry; (ii) such
individua l as Robert shall have designate d; (iii) such
individua l as John Barry shall have designate d.
I appoint Richard Levey to be the distributi on
trustee of any trust under Article TENTH of this Will for
the benefit of my son Robert. If Richard Levey shall fail
, to qualify or cease to act, I appoint the first named of the
II following individua ls who is willing and able to qualify to
I be distributi on trustee: (i) my daughter, Maryanne; (ii)
such individua l as Richard Levey shall have designated ;
(iii) such individua l as my daughter, Maryanne, shall have
designate d.
I appoint my daughter, Maryanne, to be the
distribut ion trustee of any trust under Article TENTH of
this Will for the benefit of my daughter, Elizabeth . If my
daughter Maryanne should fail to qualify or cease to act, I
appoint the first named of the following individua ls who is
willing and able to qualify to be distributi on trustee: (i)
my son, Robert; (ii) such individua l as my daughter,
Maryanne, shall have designate d; (iii) such individua l as my
son, Robert, shall have designated .
Any designatio n of a successor distributi on
trustee pursuant to this paragraph (b) shall be made by a
written instrumen t duly acknowledg ed and may contain one or
more successiv e alternate designatio ns in listed order and
may be revoked or changed by the individua l having the power
to make such designatio n by similar instrumen t at any time
before the designee takes office.
13
I direc t that at all times there shall be a
distri butio n truste e with respec t to each of the afores aid
trusts . If at any time there is no distri butio n truste e
acting with respec t to any of the afores aid trusts and no
succe ssor distri butio n truste e is design ated pursua nt to the
provi sions of this paragr aph (b) who shall qualif y to act,
the distri butio n truste e shall be such indivi dual as a
major ity of my then living childr en other than the child who
is a benef iciary of the trust shall design ate.
The distri butio n truste e of any trust hereun der
shall have sole and absolu te discre tion with respec t to any
distri butio n of income (unles s income is requir ed to be
distri buted ) and princ ipal with respe ct to the trust in
which he acts, but shall not otherw ise partic ipate in the
manag ement or admin istrati on of such trust.
The appoin tment of each distri butio n truste e named
in this paragr aph (b), or design ated in accord ance herew ith,
{othe r than a child of mine) is condi tioned on his or her
agreem ent in writin g to accep t as full compe nsatio n for his
or her servic es as distri butio n truste e in each year of the
trust the sum of TEN THOUSAND DOLLARS ($10,0 00.00) .
(c) If at any time there is no execu tor of this
Will or no truste e of any trust hereun der (other than a
distri butio n truste e), The Chase Manha ttan Bank, N.A., is
appoi nted to be execu tor or truste e, as the case may be.
(d) Any execu tor or truste e (inclu ding a
distri butio n truste e) may resign at any time witho ut the
permi ssion of any court or person .
(e) I direc t that no bond or other secur ity be
requi red of any fiduci ary named herein or appoin ted in
accord ance herew ith for the faithf ul perfor mance of his or
her dutie s in any capac ity in any jurisd iction or to secure
the return of any advan ce payme nt of comm issions .
(f) The terms "execu tors" and "trust ees" as used
in this Will are intend ed to includ e the execu tors or
execu tor and the truste es or truste e, respe ctivel y, acting
14
I·,I
as such from time to time with out regar d to the gend
er or
numb er of any prono un or othe r term used in this Will
, but
shal l not inclu de the distr ibut ion trust ee of any trus
t
actin g from time to time , whos e auth ority and powe r
shal l be
limi ted to the distr ibut ion powe r gran ted to him or
her
unde r parag raph (b) abov e.
(g) I hereb y dire ct that my sons , Dona ld and
Robe rt, and my daug hter, Mary anne, prio r to qual ifyin
g as
exec utors and/ or trus tees (incl udin g distr ibut ion trus
tee) ,
shal l each agree in writ ing to waive all statu tory
comm issio ns and fees for servi ng as an exec utor and/
or
trus tee with resp ect to the adm inist ratio n of my esta
te
andf or the trus ts crea ted hereu nder .
(h) Exce pt as other wise prov ided in parag raph (b)
of this Arti cle, the appo intm ent of every indiv idua l,
bank
or trus t company to be an exec utor of this Will or to
be a
trus tee of any trus t hereu nder , othe r than those name
d in
para grap h (g) above (but inclu ding The Chas e Manh attan
Bank ,
N.A. , if it is appo inted othe r than purs uant to parag
raph
(c) of this Artic le) is cond ition ed upon his, her or
its
agree ment to acce pt, in plac e of the comm ission s to
whic h
he, she or it would othe rwis e be entit led unde r New
York
law, such comp ensat ion as shal l be agree d upon in writi
ng
with the othe r exec utor or the othe r trust ee of such
trus t,
as the case may be, then in offic e, or if no othe r exec
utor
or othe r trust ee is then in offic e, as shal l be agree
d upon
in writ ing with the bene ficia ry or a majo rity of the
bene ficia ries, as the case may be, who· are adul t and
comp etent .
(i)Exce pt as othe rwis e spec ifica lly prov ided in

this Will or any Codi cil here to, in the even t of any
disp ute
aris ing betw een the exec utors of this Will or the trust
ees
of any trus t unde r this Will as to any actio n to be
taken by
them as such exec utors or trust ees (othe r than any auth
ority
gran ted unde r the prov ision s of this Will to a distr
ibut ion
trus tee) , such disp ute shal l be fina lly settl ed by vote
of a
15
I
'•
....majorit
----- -·- --- ---
. .•.
y of the executo rs or trustees in office at the time
of the dispute.
EIGHTEENTH: If ancillar y or separate
adminis tration of my property in any jurisdic tion becomes
necessa ry or desirab le, I authoriz e my executo rs to be, or
to designa te one or more individu als and/or a bank or trust
company (includi ng one or more of my executor s) to be,
ancilla ry executor s or executor or to occupy such other
fiduciar y position as may be appropr iate to accompl ish this
purpose under the law of such jurisdic tion and I appoint the
fiducia ries or fiduciar y so designat ed; provided , however ,
that none of my said executo rs shall be entitled to dual
commiss ions as domicil iary executor and as such fiduciar y
with respect to the same assets or the proceeds of sale
thereof . The fiducia ries or fiduciar y acting pursuan t to
this paragrap h shall have, with respect to the property
subject to such ancillar y or separate adminis tration, all of
the rights, powers, privileg es, discreti ons, exemptio ns and
immunit ies granted to, as well as the duties and liabilit ies
imposed upon, my executo rs by this Will.
I authoriz e my executor s to pay from the princip al
of my residuar y estate, as an expense of adminis tration, all
expense s of ancillar y adminis tration, includin g all such
expense s with regard to specific bequests and devises under
this Will.
NINETEENTH: In addition to the powers granted by
law or by other provisio ns of this Will and not in
limitati on thereof, I authoriz e my executo rs, with respect
to my estate, and my trustees , with respect to any trust, in
their discreti on:
(a) To retain, and to invest and reinves t in,
such common stocks, preferre d stocks, bonds, other
securit ies and other property , real or persona l, includin g
interes ts in investm ent trusts, mutual funds, securiti es of
any corpora te fiduciar y and common trust funds, as they deem
advisab le, whether or not any such property is diversif ied
16
or is qual ified by law for fidu ciary inves tmen t, and
whet her
or not any such prop erty may be deem ed to be spec ulati
ve or
is unpr oduc tive of incom e;
(b) To sell , exch ange or other wise dispo se of any
prop erty, real or pers onal , at such time s and upon such
term s as they deem advi sable , with out any duty to alloc
ate
any of the proce eds of unpr oduc tive or unde rprod uctiv
e
prop erty to incom e;
(c) To exer cise (by purc hase , subs cript ion,
conv ersio n or other wise ) or to sell or to waiv e any
optio ns,
righ ts, warr ants or othe r priv ilege s exer cisab le by
them ;
(d) To make distr ibut ion whol ly or part ly in cash
or in kind , and to caus e any shar e or legac y to be comp
osed
of cash , prop erty or undiv ided inte rests in prop erty
dif-
fere nt in kind or diffe rent in incom e tax basis from
any
othe r shar e or legac y, in satis fact ion of any of the
prov i-
sion s of this Will ;
(e) To vote in perso n or by proxy with resp ect to
any secu rity; to cons ent to or to diss ent from any plan
for
cons olida tion, merg er, reor gani zatio n, reca pital izati
on or
liqu idat ion, or othe r plan , with resp ect to any secu
rity;
(f) To regi ster, tran sfer or hold any stoc ks,
bond s or othe r secu ritie s in thei r name s or (to the
exte nt
perm itted by appl icab le law) in bear er form or in the
name
or name s of any othe r perso n or nomi nee chose n by them
, but
with full resp onsi bilit y in thei r fidu ciary capa city;
(g) To comp romis e claim s made by or agai nst them ;
(h) To empl oy or reta in such custo dian s,
acco unta nts, lega l coun sel, inves tmen t coun sel and othe
r
agen ts and advi sers as they deem advi sable and to dele
gate
auth ority there to; and to comp ensat e them , in adva nce
of the
settl eme nt of thei r acco unt and with out prio r cour t
appr oval , from prin cipa l or incom e, or part ly from prin
cipa l
and part ly from incom e;
(i) To borro w money from any perso n or

corp orati on (incl udin g any exec utor or trust ee here unde
r),
17
whet her or not upon the secu rity of any real or perso
nal
prop erty held hereu nder, for such purp oses and upon
such
term s as they deem advi sable ;
(j) To make such elec tions unde r the tax laws as
they deem advi sable , rega rdles s of the effe ct there of
on any
inte rest s unde r this Will , with out any requi reme nt to
make
an adju stme nt of such inter ests by reaso n of such elec
tion,
and to alloc ate any gene ratio n-sk ippin g tran sfer tax
exem ption to which I am entit led, unde r Sect ion 2631
of the
u.s. Inte rnal Reve nue Code, to any prop erty with resp ect to
whic h I am the trans fero r for the purp oses of said tax
(whe ther or not such prop erty is inclu ded in my prob ate
esta te), in any mann er they deem advi sable ;
(k) To elec t unde r Sect ion 6166 of the u.s.
Inte rnal Reve nue Code (or unde r a corre spon ding statu
te of
any state impo sing a death tax on my esta te), to defe
r the
paym ent of the fede ral esta te tax or state death tax
for
such perio d as my exec utors may in thei r sole disc retio
n
deter mine . In the even t such an elec tion is made, my
exec utors may in thei r sole disc retio n (i) charg e inte
rest
on the defe rred tax to incom e or prin cipa l in such mann
er as
they deter mine , notw ithst andin g any othe r prov ision s
of this
Will and (ii) elec t unde r secti on 6324A of said Code
(or a
corre spon ding prov ision of state law) to crea te a spec
ial
lien for the defe rred esta te or death tax (incl udin g
tax
attri buta ble to prop erty not pass ing unde r this Will)
and
subj ect prop erty belon ging to my esta te to such lien.
(1)To divid e any trus t crea ted hereu nder into
two or more sepa rate trus ts or to hold and admi niste
r any
two or more sepa rate trus ts in solid o and to make any
distr ibut ions from or addi tions to any one or more of
said
trus ts, in equa l or uneq ual prop ortio ns, all as my trust
ees
in thei r disc retio n deem advi sable , prov ided, howe ver,
that
such powe rs shal l be exer cised only in conf ormi ty with
the
inte rest s of the bene ficia ries crea ted unde r this Will
; and
18
(m) To aba ndo n any pro per ty, rea l or per
tha t I may own or in whi ch I may hav
son al, r-
e any int ere st at the
tim e of my dea th, inc lud ing any min
era l int ere sts , whi ch
the y deem wo rth les s or not of suf fic
ien t val ue to war ran t
ret ent ion or pre ser vat ion , and I rel
eas e my exe cut ors and my
tru ste es from any and all lia bil ity
wit h res pec t to any suc h
pro per ty aba ndo ned in good fai th.
TWENTIETH: My exe cut ors and tru ste es sha ll
all oca te to pri nci pal the ent ire amo
unt of all dis trib uti ons
of sto ck of the dis trib uti ng cor por
atio n (wh eth er of the
sam e typ e as or a dif fer ent typ e from
the sha res hel d by my
fid uci ari es) , all dis trib uti ons of
sto ck of a cor por atio n
oth er tha n the dis trib uti ng cor por
atio n, and the ent ire
amo unt of all liq uid ati ng div ide nds
, and sha ll allo cat e to
inc om e the ent ire amo unt of all cas
h div ide nds oth er tha n
liq uid ati ng div ide nds , inc lud ing div
ide nds pai d by cor -
por ati ons dev elo pin g nat ura l res our
ces (commonly known as
"w ast ing ass ets " cor por atio ns) , and
the ent ire amo unt of all
int ere st on bon ds and oth er fix ed
inco me sec uri tie s
(al tho ugh pur cha sed or hel d at a pre
miu m).
TWENTY-FIRST: Any thin g her ein con tain ed to the
con tra ry not wit hst and ing , no dis trib
uti on tru ste e at any
tim e act ing her eun der sha ll be ent
itle d to par tic ipa te in
any dis cre tio nar y det erm ina tion as
to the pay men t or
acc um ula tion of inc om e or the dis trib
uti on of pri nci pal for
his or her own ben efi t or for the
ben efi t of any per son to
whom he or she owe s a leg al obl iga
tio n of sup por t at the
tim e suc h det erm ina tio n is made, and
any suc h dis cre tio nar y
det erm ina tio n sha ll be made by the
oth er tru ste e or tru ste es
the n act ing her eun der .
TWENTY-SECOND: With res pec t to all rea l pro per ty

hel d for my est ate or the tru sts her
eun der , in add itio n to
the pow ers gra nte d by law and not
in lim ita tio n the reo f, I
aut hor ize my exe cut ors and my tru ste
es, as the y deem
adv isa ble in the ir dis cre tio n, wit
hou t cou rt ord er: to sel l
suc h pro per ty at pub lic or pri vat e
sal e, for cas h or on
19
mort gage , or to exch ange such prop erty for othe
r prop erty ; 1
to leas e such prop erty upon term s and for peri ods
that they
elec t notw ithst andi ng that such leas e may exte nd
beyo nd the
peri od of adm inist ratio n of my esta te or of any
trus t
here unde r or any othe r peri od appl icab le by stat
ute in the
abse nce of auth orit y here in; to agre e to the canc
ella tion of
any leas e for such prop erty ; to gran t opti ons for
the sale
or exch ange of such prop erty ; to hold and mana ge
such
prop erty ; to incu r, pay, exte nd or rene w.m ortg age
inde bted -
ness ; to make ordi nary and extr aord inar y repa irs
and alte ra-
tion s to any buil ding , to raze buil ding s, to erec
t buil ding s
and to make impr ovem ents, or to aban don any buil
ding s or
prop erty ; to insu re agai nst loss by fire or othe
r casu alty ;
and to make any agre emen t of part ition of such
prop erty and
to give or rece ive money or othe r prop erty for
equa lity of
such part itio n; and to join with co-o wner s in exer
cisin g any
of the fore goin g pow ers.
TWENTY-THIRD: I auth oriz e my exec utor s, with
resp ect to my esta te, and my trus tees , with resp
ect to any
trus t, in thei r disc retio n, to sell , reta in, deve
lop,
purc hase , oper ate and manage oil, gas and min eral
inte rest s,
whe reve r loca ted and whet her or not such inte rest
s are
spec ulat ive or unpr oduc tive of incom e, rega rdle
ss of the
natu re of the inve stme nt ther ein, and gene rally
to exer cise
all of the righ ts, powe rs and disc retio ns of an
abso lute
owne r (inc ludi ng the righ t to inve st addi tion al
fund s and to
dele gate auth orit y to othe rs and to act join tly
with othe rs)
with resp ect to such inte rest s; and to allo cate
the retu rns
from any such inte rest s to incom e or to prin cipa
l, or part ly
to inco me and part ly to prin cipa l, as they deem
advi sabl e.
I rele ase my exec utor s and my trus tees from any
and all
liab ility with resp ect to thei r acts or omis sion
s in
conn ectio n with such inte rest s, and spec ifica lly
auth oriz e
them to deal with any one or more of them selv es
indi vidu ally
or othe rwis e with resp ect to such inte rest s.
20
----- -- --·- ---- ,r-- ---- -- ----- --
TWENTY-FOURTH:I auth orize but do not dire ct my
exec utors and trust ees to conti nue, eithe r indep ende
ntly or
in partn ersh ip or asso ciati on with othe rs, any busin
ess in
the form of a sole prop rieto rship , partn ersh ip, corp
orati on
or other wise in whic h I may be engag ed at the time of
my
deat h for such perio d of time afte r my death as my
exec utors
or my trust ees cons ider to be in the best inte rest s
of my
esta te or of the trus ts hereu nder. I gran t to my exec
utors
and my trust ees, in addi tion to and not in limi tatio
n of the
powe rs gran ted by law and by the prece ding Arti cles
of this
Will , all as they deem advi sable in thei r disc retio n,
full
powe r and auth ority :
(a) To sell , exch ange , lease , pled ge, mortg age or

othe rwis e empl oy any asse ts in the cond uct of or for
the
bene fit of such busi ness ;
(b) To purc hase , rent or other wise obta in any

prop erty, real or pers onal , that they cons ider usef
ul in the
cond uct of such busi ness ;
(c)
To empl oy or retai n perso nnel and cons ultan ts
and to comp ensat e them in any mann er notw ithst andi ng
that
any empl oyee or cons ultan t may also be an exec utor
or
trus tee hereu nder ;
(d) To comm it prop erty held by my esta te or any
such trus t to the oper ation of such busin ess, whet her
or not
such prop erty was so comm itted prio r to my deat h;
(e) To dele gate auth ority with reaso nabl e care

with out liab ility ;
(f) To alte r the scope or natu re of the busin ess
in any mann er;
(g) To esta blish depr eciat ion and oper ating

rese rves ;
(h) To exten d cred it and to borro w for any
reaso nabl e purp ose;
(i) To sell any part or all of such busi ness ;
21
(j) To inve st and rein ves t surp lus fund s in othe
r -l
bus ines ses or in common stoc ks, pref erre d stoc
ks, bond s,
othe r secu ritie s and othe r prop erty ;
(k) To orga nize or to part icip ate in the orga
ni-
zati on of a corp orat ion or othe r enti ty for
the ope rati on or
own ersh ip of any such bus ines s or any par t
ther eof;
(1) To liqu idat e such busi ness in who le or in
par t at any time ;
(m) To exe rcis e gen eral ly all of the righ ts,
pow ers and priv ileg es of an own er in conn ecti
on with the
con tinu atio n of such bus ines s.
Ever y act done , pow er exer cise d or obli gati on
assu med by my exe cuto rs or my trus tees purs
uan t to this Wil l
in conn ecti on with carr ying on any such busi
ness sha ll be
held to be done , exe rcis ed or assu med , as the
case may be,
by them as exec utor s or trus tees and not indi
vidu ally , and
eve ry pers on or corp orat ion con trac ting or
othe rwis e dea ling
with my exec utor s or my trus tees sha ll look
only to the
pro pert y of my esta te or of the trus ts here
und er for the
sati sfac tion of any obli gati on aris ing from
the con tinu ance
of such busi ness ; and in no even t sha ll eith
er my exec utor s
or my trus tees be pers ona lly liab le ther efor
.
My exec utor s and my trus tees sha ll be full y
pro-
tect ed in reta inin g any inte rest in such bus
ines s or any
inte res t in any othe r busi ness or corp orat ion
tha t may have
been exch ange d ther efor in acco rdan ce with
the fore goin g
pro visi ons , and sha ll not be liab le for any
acti on or in-
acti on with resp ect to such inte rest s or for
any decr ease in
the valu e ther eof, or for any loss or damage
sust aine d by my
esta te or any trus t here und er or by any ben
efic iary here -
und er, by reas on of or aris ing out of the rete
ntio n of such
inte rest s. The judg men t of my exec utor s or
my trus tees , as
the case may be, as to the pro prie ty of reta
inin g such
inte res ts or inve stm ents or any par t ther eof
sha ll be
bind ing and con clus ive on all pers ons inte rest
ed in my
esta te or in any trus t here und er.
22
TWENTY-FIFTH: My executors and my trustees may
sell or lend to, or purchase or borrow from, or otherwise
deal with one or more of themselves individually or

any
otherwise, without reference to the fact that they or any of
them are acting in a fiduciary capacity, provided that all
such transactions are made in good faith and in accordance
with the other applicable provisions of this Will.
TWENTY-SIXTH: (a) Any reference to a provision
of the U.S. Internal Revenue Code in this Will shall refer
to a provision of the U.S. Internal Revenue Code of 1986, as
amended from time to time, or any corresponding provision of
any future Internal Revenue Law. Any reference to a
provision of any other statute, federal or state, in this
Will shall refer to that provision as amended from time to
time or any successor provision thereto.
(b) The minority or majority of any person
referred to in this Will shall be determined under the law
of such person's domicile at the time that each such
determination becomes necessary.
The terms "children" "issue"

(c) "child", and as
used in this Will shall include adopted persons and their
issue.
TWENTY-SEVENTH: No life income beneficiary or
remainderman of any trust hereunder shall have, during the
continuance of such trust, any power to assign or otherwise
to anticipate, alienate or encumber his or her interest in
the trust, nor shall such interest be subject in any way to
the indebtedness of any such beneficiary or, with respect to
such beneficiary, be subject to the legal process,
bankruptcy proceedings or the claims, interference or
control of creditors or others.
TWENTY-EIGHTH: If any beneficiary hereunder
contests the validity of this Will or attempts to prevent
the probate thereof or to invalidate any part thereof, such
beneficiary shall, for the purposes of this Will, be deemed
to have predeceased me without issue. This provision shall
23
on
or in ter pr eta tio n of th is
W ill .
TWENTY-NINTH: Th e de vis e and
be qu est made in
Ar tic le SEVENTH (a) of th is
W ill , to the ex ten t my ex ec
uto rs
so el ec t pu rsu an t to Se cti on
20 56 (b) (7) of the u. s. In ter
na l
Re ve nu e Co de, is int en de d
to qu ali fy fo r the ma rit al
de du cti on un de r the ap pli ca
ble pr ov isi on s of the sa id
Co de.
Th ere fo re, I di re ct (1) th
at any au tho riz ati on s or
di re cti on s or oth er pro vis
ion s co nta ine d in th is Wi ll
wh ich
wo uld ca us e the dis all ow an
ce of the sa id ma rit al de du
cti on
wi th res pe ct to the sa id de
vis e and be qu est sh all no t
ap ply
to th e sa id de vis e and be qu
est , and (2) th at any pro vis
ion
of th is Ar tic le wh ich ap pe
ars to be inc on sis ten t wi th
any
pr ov isi on of any oth er ar tic
le he reo f sh all su pe rse de
suc h
ot he r pr ov isi on . I req ue st
the co ur t ha vin g ju ris di cti
on of
my es ta te , or of the fed era
l es tat e tax pro ce ed ing wi
th
re sp ec t to my es tat e, to co
ns tru e th is W ill ac co rdi ng
ly,
up on an y sho wi ng of rea so na
ble do ub t as to the all ow an
ce of
th e sa id de du cti on , reg ard
les s of the fa ct th at suc h
co ns tru cti on may req uir e a
cha ng e in the or din ary me ani
ng of
an y pr ov isi on of th is W ill
.
I di re ct th at the inc om e fro
m the tru st cre ate d by
th e de vis e and be qu est un de
r sa id Ar tic le SEVENTH (a)
sh all
be pa ya ble in an nu al or mo
re fre qu en t ins tal lm en ts.
The
ter m "in co me " sh all inc lud
e al l of the inc om e th at ma
y be
re qu ire d to qu ali fy the sa
id de vis e and be qu est fo r the
sa id
ma rit al de du cti on . If any
un pro du cti ve pr op ert y sh all
at
an y tim e co ns tit ut e a pa rt
of the pr inc ipa l of the sa
id
tru st, I di re ct my tru ste es
, upo n the wr itt en req ue st
of my
24
.I
...-----....-... ................,,, ..,_.._,_,.,_,,_,
wife, Mary Anne Tsuinp, to convert'suen-1Weparty"·rnt.o ¬w¬m-- ,
productive property within a reasonable time.
IN WITNESS WHEREOF, I, FRED C. TRUMP, have
hereunto set a hand and seal this ÎÛ day of
, in the year One Thousand Nine Hundred
Ninety-one.
The foregoing instrument was on the day

of the date thereof subscribed, sealed,
published and declared
by the testator
therein named as for and his Last Will
and Testament, in our presence and in the
presence of each of us, who, at the same
time, at his request, in his presence and
in the presence of each other have here-
subscribed our names as witnesses.
. residing at n2c PArk fw‰h,n f.
corfa*
. residing at é.5potsw Jr
atf4 D$jL
residing
25
AFFIDAVIT OF ATTESTING WITNESSES .
STATE OF A/E
COUNTY OF )
Each of the undersigned, being severally duly
sworn, says:
1. We make this affidavit as subscribing
witnesses to the Last Will and Testament of FRED C. TRUMP.
2. We are acquainted with FRED C. TRUMP (the
"testator") and make this affidavit at his request.
3. The subscription of the name of the testator
to the foregoing original instrument bearing date
, 1991 was made by the testator at
the presence of each of us as the subscribing witnesses. At
the time of making such subscription, the testator declared
said instrument so subscribed by him to be his Last Will and
Testament; and we thereupon signed our names as witnesses at
the end of said instrument at the request of the testator in
the sight and presence of each other and in his sight and
presence.
4. The testator at the time of so executing said
instrument was over the age of 18 and in the respec-

years,
tive opinions of the undersigned, of sound mind, memory and
understanding, not under any restraint or in any respect
incompetent to make a will.
5. The testator, in the respective opinions of
the undersigned, could read, write and converse in the
English language and was suffering from no defect of sight,
hearing or speech, or from any other physical or mental
impairment which would affect his capacity to make a valid
will. The foregoing original instrument was executed as a
single, original instrument and was not executed in
counterparts.
the undersigned at the time this af fidavit was made, and was
examined by each of us as to the signature of the testator
and of each of the undersigned.
7. The foregoing original instrument was executed
by the testator and witnessed by each of the undersigned
affiants under the supervision of bbh/ an
attorney-at-law.
Sworn to before me this
day of 1991.
Notary Public
AUSTIN T. W1LK1E
State o' New York
Notary Pubtic, 31-403t423
SJo.
Oualified in Now Yo•k Cour.ty
Commission Expircs fZay 23, 19. .
C.
TRUMP FRED
EXHIBIT "G"
STATE OF NEW YORK
SURROGATE'S COURT : COUNTY OF QUEENS
______._____-_____ __ _ _ ___ _ _ -------X
In the Matter of the Probate of the
Last Will and Testament of FIRST NOTICE

OF DISCOVERY
AND INSPECTION
FRED C. TRUMP, TO PETITIONERS
Deceased. File No. 3949/99

_____ _ _ __ _ ___-------------------------X
PLEASE TAKE NOTICE that pursuant to Article 31 of the Civil Practice Law and Rules and the
Surrogate's Court Procedure Act, Mary Trump and Fred C. Trump, III, by their attorneys, Farrell Fritz,
P.C., hereby request that the Petitioners produce and permit inspection and copying of the documents
described and requested herein at the office of Farrell Fritz, P.C. on November 15, 1999 at 10:00 a.m.
DEFINITIONS
"Document"
A. is used herein in its customary broad sense, and includes without limitation
any
kind of printed, recorded, written, graphic or photographic matter (including tape recordiñgs), however
printed, produced, reproduced, coded or stored, of any kind or description, whether or not sent or
received, including reproductions, facsimiles, drafts and including without limitation, papers, books,
correspondence, reports, memoranda, tapes, handwritten or stenographic notes, e-mails, invoices,
computer printouts, disks, tapes, or data, telex messages, work prodüet, telephone logs, diaries, desk
calendars, minutes, corporate resolutions and things similar to any of the foregoing.
B. Each and every non-identical copy of a document whether different from the original becaüse
of stamps, indication ofreceipt, handwritten notes, marks or any other reason, is itself a document to be
produced.
C. "Commu nication" or "Communications" mean every manner of transmitting, and the
transmittal, or receiving, and the receipt offacts, information, opinions, thoughts, ideas or knowledge,
whether orally, in writing, or otherwise.
D. "Fred C. Trump" or "Decedent" refers to the Decedent, Fred C. Trump, or any person or
employee working for or acting on behalf of Fred C. Trump. As used herein, "you" and "Petitioners"
means Donald J. Trump, Robert S. Trump and/or Maryanne T. Barry, or any person or employee
working for, acting on behalf of Donald J. Trump, Robert S. Trump and/or Maryanne T. Barry,
including but not limited to accountants, attorneys and/or any other persons or entities subject to their
control.
E. "Concerning", ''referring'', "relating", ''concern'', ''refer" or "relate" means and includes:
with respect to, referring to, relating to, purporting, pertaining, involving, embodying, mentioning,
establishing, evidencing, comprising, connected with, commented on, responding to, prepared in
connection with, prepared as a result of, showing, discussing, describing, analyzing, reflecting,
presenting or constituting.
F. As used herein, "person" in the plural as well as in the singular means any natural person,
firm, corporation, unincorporated association, partnership or any other form of legal entity or
governmental body including its affiliates, agents and representatives.
G. As used herein, "and" as well as "or" shall be construed either disjunctively or conjunctively
as necessary to bring within the scope of the Notice all documents that might otherwise be construed to
be outside its scope. "Any" includes the word "all" and "all" includes the word "any".
H. The use of the singular form of any word includes the plural and vice versa.
2
INSTRUCTIONS
A. If not otherwise indicated, the time period covered by these requests is September 18, 1988
to September 18, 1993.
B. Each request shall be construed independently and no request limits the scope of any other
request.
C. The documents called for by this demand include all documents, wherever located, in your
possessiOn, custody or control or in the possession, custody or control of your representatives,
employees, family members, agents, partners, attorneys, accountants, consultants, auditors or
investigators or other persons.
D. To the extent you are uncertain about the meaning of any aspect of this demand, you or your
counsel are invited to contact the undersigned counsel.
E. If any document within the scope of this request has been destroyed, describe the
circumstances of such destruction and produce each document concerning such destruction, including,
without limitation, each document concerning any policy of document retention and destruction.
F. In the event that any document covered by this request has been transferred to a third party
over whom you lack control, identifY:
I. The document by date, authors, recipients, subject matter and contact;
2. The date and circumstances surrounding the transfer;
3. The reasons for transfer;
4. The persons or entities to whom transferred;
5. The present location of such documents;
3
6. Any request you have made for the return of either the original documents or a
copy thereof to your possession; and
7. The date and manner in which you can or may obtain the return of each such
document.
G. Pursuant to CPLR 3122(b ), if any documents are withheld under a claim of privilege or work
product doctrine, set forth the privilege, identifY each person having knowledge of the information for
which you claim the privilege, and identify each document containing the information for which you
claim the privilege, including:
I. The type of document,
2. A description of the subject matter with the document;
3. The date of the document,
4. The names and addresses of each person who viewed the document, and
5. A statement of the basis upon which the privilege is claimed.
REQUESTS
I. Documents containing, evidencing, referring to or memorializing any
instructions of Fred C. Trump, whether oral or in writing, regarding his intentions as to the disposition
of his property, whether relating to his Last Will and Testament dated September 18, 1991, or relating
to any prior Will or Codicil executed by him.
2. Wills and Codicils made prior to the Last Will and Testament dated
September 18, 1991.
4
3. Conformed, work copies or drafts of any Will or Codicil executed by
Deceden t and a copy of each and every Will and Codicil and draft thereof prepared for
execution by
Decedent and all documents referring to or relating to the preparation of such, including but
not limited
to notes, memoranda and estate tax analysis.
4. Documents created by, sent to or received from Decedent which
evidenced, referred to or memorialized any oral communications with him regarding any
part of the
content or proposed content of any Will of Decedent.
5. Documents created by, sent to or received from Decedent which
evidenced, referred to or memorialized any oral or written communication with Decedent

regarding the
disposition or proposed disposition, transfer or proposed transfer, of any property, real
or personal,
owned by Decedent in whole or in part.
6. Documents that concern, refer or relate to Fred C. Trump III and/or Mary
Trump.
7. Letters, correspondence, documents or other forms of communications,
whether handwritten, taped, or otherwise recorded, received by any of the Petitioners or anyone
on their
behalf from or on behalf of the Decedent.
8. Documents, including, but not limited to, appointment books, calendars,
diaries, journals, memoranda or other forms of transcription, whether typed, handwritten,

taped or
otherwise recorded, concerning the date, time, place and/or nature of appointments, meeting
s, visits,
or conversations held or to be held by Petitioners or anyone on their behalf with Deceden
t.
5
9. Documents, including, but not limited to, appointment books, calendars,
diaries, journals, memoranda or other forms of transcription, whether typed, handwritten, or otherwise
recorded, concerning the date, time, place and/or nature of appointments, meetings, visits and
conversations held, or to be held by Petitioners or anyone on their behalf, with individuals employed by
Decedent, whether as employees or independent contractors.
I 0. Documents, including, but not limited to, appointment books, calendars,
diaries, journals, memoranda or other forms of transcription, whether typed, handwritten, taped or
otherwise recorded, concerning the date, time, place and/or nature and substance of appointments,
meetings, visits and conversations held or to be held, by Petitioners or anyone on their behalf with
Robert W. Sheehan, Esq., and/or attorneys at the law firm of Chadbourne & Parke, LLP.
II. Photographs, voice and/or motion picture records of the Decedent and/or
you and the Decedent and/or Fred C. Trump III and/or Mary Trump and the Decedent..
12. Life insurance policies in the name of the Decedent and all life insurance
policies for which he was the insured, and all documents referring orrelating to the beneficiaries of those
life insurance policies including, but not limited to, documents referring or relating to any change or
request for change of a beneficiary of any such life insurance policies.
13. Deeds and/or mortgages to real property executed by or on behalf of
and/or in the name of Decedent, individually or jointly.
14. Records of safe deposit boxes used by Decedent.
15. Inventories of any safe deposit boxes in the name ofDecede nt individually
or jointly, or to which he had access, whether such inventory was made before Decedent's death, or by
anybody on his behalf, or after Decedent's death by any other person.
6
16. Bank records, including statements, passbooks, canceled checks, check
registers, check stubs, signature cards and deposit slips for all bank accounts, domest
ic and/or foreign,
of and/or Decedent, held individually and/or jointly with any other person, corpora
tion, or entity.
17. Records of any other type of account, including brokerage accounts,
held by or for Decedent, including but not limited to signature cards and all stateme
nts for any account
or accounts held at any brokerage firms by Decedent, individually, jointly, and/or
with any other person
or corporation.
18. Ledgers, lists of assets, income and expense calculations and any
other financial records made by or on behalf of Decedent.
19. Documents, including deeds, referring or relating to any actual
proposed gift, beneficiary designation, transfer or conveyance of real or person

al property made by
Decedent.
20. Individual, gift, federal and state income tax returns filed by or on
behalf of Decedent, individually or jointly.
21. Federal and state partnership tax returns filed by or on behalf of any
partnership in which Decedent had an interest.
22. Federal and state corporate income tax returns filed by or on behalfof each
corporation or LLC in which Decedent had an interest.
23. Federal and state fiduciary income tax returns for each trust in which the
Decedent had an interest either as a current beneficiary, remainderman or trustee.
24. Inventories of the contents of Decedent's residences, including
appraisals of any personal property belonging to him.
7
25. Address books, telephone books, diaries, desk calendars and
notebooks kept by or for Decedent.
26. Tape recordings or videotapes made of Decedent.
27. Photographs of Decedent.
28. Records of all purchases and/or sales of stocks, bonds, options,
business interests, by, for, or on behalf of Decedent.
29. Documents referring or relating to securities and/or bonds held by
Decedent.
30. Powers of attorney given by Decedent to any other person.
31. Documents referring or relating to any transaction performed by an
attorney in fact on behalf of Decedent.
32. Medical records, medical reports, and medical and/or hospital bills for
Decedent.
33. Records, including bills, of any prescription drugs or medications
purchased by, for, or on behalf of Decedent.
34. Documents containing any reference to the mental state or physical
condition of Decedent including, but not limited to any documents referring to any mental or
physical
impairment or aberrational behavior.
35. Documents referring or relating to the physical or mental condition of
Decedent including, but not limited to, his memory, testamentary capacity, knowled
ge and
understanding of the contents and meaning of any Will, Codicil, Trust Agreement, or other
legal
8
instrument, including real estate conveyances, or relating to his capaci
ty to manage his financial,
business and personal affairs.
36. Files relating to Decedent kept by or maintained by Petitioners.
37. Living Will or Health Care Proxies executed by Decedent or any
documents referring or relating thereto.
38. Documents evidencing any liens on property owned by Decedent.
39. Trusts or amendments thereto, or drafts thereof, executed by
Decedent, or by anyone on his behalf, or prepared for Decedent, and all

documents referring or relating
thereto.
40. Documents referring or relating to any life estates retained by
Decedent.
41. Medicaid, medicare or health insurance documents relating to
Decedents.
42. Beneficiary designations on any non-probate assets belonging to
Decedent, either individually or jointly.
43. Documents concerning loans or gifts to Petitioners from Decedent or any
trust or other entity in which Decedent had a financial or fiduciary interes

t.
44. Documents concerning gifts, in whatever form, from Decedent to
Petitioners.
45. Diaries, books, calendars, date books, appointment books, journals,
memoranda, telephone logs, recordings and/or computer disks maintained

by you or on ·your behalf that
concern, refer or relate to Decedent.
9
46. Documents concerning requests for money by Petitioners to Decedent
and/or all family trusts and other trusts in which Decedent had an interest.
47. All W-2 and 1099 forms issued to the decedent.
48. Records showing payment for insurance premiums.
49. Records, papers, memoranda or other documents pertaining to individuals
who provided domestic or other household services (including but not limited to painting,
repairs, and
construction) to Decedent..
50. Decedent's death certificate.
51. Records for any corporations, partnerships or other business entities in
which Petitioners are now shareholders, partners or have a financial or other interest, directly
or through
nominees, in which Decedent was a shareholder, a partner, or had a financial or other interest,
directly
or through nominees.
52. Corporate, partnership or other records of each entity in which Decedent
or his nominee(s) had an interest, including (but not limited to) certificates of incorporation,
by-laws and
amendments thereto, corporate resolutions, shareholders agreements and amendment
thereto,
management agreements and amendments thereto, partnership agreements, and amendments
thereto,
nominee agreements, sale, lease, mortgage and/or purchase agreements.
53. Inventories or records of assets now owned, co-owned or managed by
Petitioners that were at any time from 1988 to 1993 assets owned or co-owned by Deceden
t, or by
nominees on behalf of decedent, or held in trust for Decedent.
10
54. Stock certificates, partnership or ownership records of any corporation,
partnership or other entity that includes or included among its officers, owners or
partners, Decedent or
Petitioner.
55. Deeds and records reflecting ownership or co-ownership by Decedent, in
his name, through nominees, or in trust for him, of real estate properties or shares
or partnership interests
in holding corporations or companies of real estate properties.
56. Contracts, agreements, memos, notes or special understandings between
Decedent and Petitioners regarding disposition of decedent's assets or estate and

all matters relating
thereto.
57. Statements of financial condition, statements of assets, income statements
or other financial statement for Decedent and any business or investment in

which Decedent had a
financial or other interest.
58. Federal, state and city tax returns for Decedent and businesses in which
decedent had a financial or other interest and correspondence, memos or notes

relating thereto.
59. Contracts, agreements, documents, memos, notes or correspondence
concerning any direct or indirect investments by Decedent in any corporation, or

any partnership or other
venture, either in the U.S. or abroad.
60. Records ofreal estate properties or shares in real estate holding companies
or interests in partnerships or other assets acquired by, for, or on behalf of Decede

nt, in his name,
through, on behalf, or in trust in him, or were liquidated, sold, transferred, assigne
d or mortgaged by
Petitioners or persons, firms or corporation entities under their control.
11
61. Records of Decedent's known creditors or financial obligations, including
but not limited to any IRS tax assessments or liens. '

PLEASE TAKE FURTHER NOTICE that pursuant to CPLR 3!0l(h ), this request
shall be
deemed continuing so as to acquire prompt, further and supplemental produc
tion (without further
requests by the propounders ofthis request). If you locate or obtain possession,
custody or control or
knowledge of the location of additional responsive documents at any time prior
to trial herein.
Dated: Uniondale, New York
October 25, 1999
Yours, etc.,
FARRELL, FRITZ, P.C.

Attorneys for Mary Trump
and Fred C. Trump, III
EAB Plaza, West Tower, 14th Floor
Uniondale, New York 11556-0120
(516) 227-0700
TO: Stephen J. Schwartz, P.C.

Attorney for Petitioners
3000 Marcus Ave.
Lake Success, NY 11042
Jay Goldberg, P.C.

Attorney for Petitioners
250 Park Avenue - 20'h Floor
New York, NY 10177-0077
12
AFFIDAVIT OF SERVICE BY FEDERAL EXPRESS
STATE OF NEW YORK)
) ss.:
COUNTY OF NASSAU )
MAUREEN C. HEALY, being duly sworn, deposes and says:
1. That I am not a party to the action and am over 18 years
of age.
2. That I reside in Mineola, New York.
3. That on October 25, 1999, I served a copy of the within
within First Notice of Discovery & Inspection to Petitioners, a
true copy thereof enclosed in a wrapper addressed as shown below
into the custody of Federal Express for overnight delivery prior to
the latest time designated by that service for overnight delivery
to each of the following persons at the last known addresses set
forth after each name:
Stephen J. Schwartz, P.C. Jay Goldberg, P.C.
Attorney for Petitioners Attorney for Petitioners

3000 Marcus Avenue 250 Park Avenue - 20th Floor
Lake Success, NY 11042 New York, NY 10177-0077
MAUREEN C. HEALY
Notary Public JUUE GEHUCH

Public. State of New York
Notary
No. 01GE4636229
Commission Expires August 31, 20._
FFDOCS1 247482.1
EXHIBIT "H"
STATE OF NEW YORK
SURROGATE'S COURT: COUNTY OF QUEENS
----------------------------------------------------------------)(
In the Matter of the Probate of the Last Will Partial Response
and Testament of To First Notice of
Discovery and Inspection
FRED C. TRUMP, to Petitioners
Deceased. File No. 3949/99

----------------------------------------------------------------)(
PLEASE TAKE NOTICE that this is Partial Response to the First Notice of
Discovery and Inspection dated October 25, 1999- time eJCtended to reply by oral
agreement between the parties to November 29, 1999.
The Partial Response is to the following items set forth in the First Notice as follows:
Items 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 27, 30,31 (None), 34 (None), 35 (None), 37,38
(None), 45 (None), 50, 56 (None), documents will be listed below as they address the
aforementioned items.
Items 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 28, 29, 32, 39, 40, 41, 42,
43, 44, 46, 47, 48, 49, 51, 52, 53, 54, 55, 57, 58, 59, 60 and 61 will be addressed following
the eJCamination ofbooks, records, memorandum, taJC returns, etc. at the business offices of
the Trump Organization in Kings County on December 8, 1999, which date has been
agreed on between Petitioners and Respondents attorneys. Whatever records are eJCamined
for the period covered by the requests from September 18, 1988 to September 18, 1993 (In
accordance with the Uniform Rules) will be set aside by the staff, photocopied and
furnished to the attorneys of record.

In the event that an instrument or documents precedes or goes slightly beyond the
time set forth above, Petitioners do not waiver the provisions of the three (3)/two (2) rule set
forth in detail with the Uniform Rules Section 207.27 of22.N.Y.C.R.R.
The following documents are numbered, identified and furnished herewith:
Document#: Dated: Description: No. of Pages:

001 11/3/99 Time Sheets to12/31/91 5
002 10/19/99 Bill for Services, time sheet 5
003 4/26/93 Letter, copies of Power of Attorney, Health 6

Care Proxy, Memorandum
004 5/26/93 Office Memorandum (unbilled time) 1
005 5/25/93 Letter to J. Walter (bill) 1
006 12/9/91 Letter to F.C. Trump 1
007 12/9/91 Letter to M/M Trump 1
008 10/4/91 Letter to J. W. Walter to R. W. Sheehan 1
009 10/4/91 Letter to MIM Trump from J.W. Walter 3
010 10/18/91 Letter plus summary to MIM Trump 3
011 10/18/91 Letter to Judge Barry 1
012 10/18/91 Letter to I. Durben 1
013 10118/91 Letter to E. Grau 1
014 10/18/91 Letter to D. Trump 1
015 10/18/91 Letter to R. Trump 1
016 9/18/91 Letter to J. W. Walter 1

017 9/18/91 Duplicate of above item 1
018 9/18/91 Letter to MIM Trump 1
019 9/18/91 Letter to Judge Barry 1
020 9/18/91 Letter to D. Trump 1
021 9/12/91 Letter to L.T. Warble, Esq. 1
022 9/3/91 Letter to F. C. Trump 1
023 7/29/91 Letter to I. Durben 1
024 7/29/91 Letter to Mitnick 1
025 7/26/91 Letter to M/M Trump 1
026 7/23/91 Letter to MIM Trump (portion deleted) 1
027 Undated Handwritten notes and changes 19
028 Undated Cover Case Sheet #C11 061-002 1
029 9/11/91 Handwritten notes, including 7118/91 (two (2) 7

sheets identical)
030 Undated Cover Case Sheet (11061-002-0002-1) 1
031 Document Index Report (conformed copy of 30

LWT 9/18/91)
032 Undated Cover Case Sheet - Codicils 4/26/91 1
033 4/26/91 Second Codicil - conformed copy 8
034 Correspondence 4/30/91 to 6/12/91 6
035 5/13/91 Draft- Memorandum to Testator 7
036 Undated Memorandum to MIM Trump 6

037 Undated Sunnnary of Proposed Will -plus copy 27
038 Undated Cover Case Sheet - Miscellaneous 1
039 Undated Handwritten Sunnnary of 1984 Will and 8

Codicils
040 Undated Handwritten notes (portion deleted) 4
041 Undated Second Codicil 7
042 Undated Handwritten Notes 5
043 Undated Cover Case Sheet - Codicil 4/26/91 1
044 1/14/86 First Codicil - conformed copy 6
045 4/2/84 Copy ofLWT 4/2/84 33
046 Undated Cover Case Sheet - proofs & drafts 1
047 Undated Sunnnary & Draft of Will 27
048 Undated Marked Handwritten conformed copy of 28

9/18/91 Will
049 9/16/91 Facsimile Transmission to J. Walter 15
050 9/13/91 Draft 27
051 9/11191 Draft 27
052 9/11/91 Draft 27
053 9/11/91 Draft - markup 29
054 9/11/91 Fax Transmitted 36
055 9/11/91 Same as above 36
056 Undated Draft 27

057 7/23/91 "Highlighted" Draft 27
058 7/23/91 "Highlighted" Draft 27
062 7119/91 Draft 27
063 7/19/91 Draft 25
064 6125/99 Death Certificate 1
065 Photographs 1991 to 1994 6
PLEASE NOTE: All drafts or documents prepared for Mary Anne Trump are not
included because of the nature of the privileged documents.
Item 26 deletion pertains to Mary Anne Trump.
Item 37 deletion is a personal comment made by the Testator about his daughter
which has nothing to do with the issues of this case. However, the Proponents will reveal
same on instructions and a ruling from the Law Department or the Surrogate of Queens
Count when and if the issue is raised before the Court.
Dated: November 21, 1999

Garden City, New York
Laurino & Laurino

By: LOUIS D. LAURINO
Trial Counsel to Stephen J. Schwartz, P.C.
and Jay Goldberg, P.C.
..
TO: Farrell, Fritz, P.C.

EAB Plaza, West Tower,l41h Floor
Att: John J. Bamosky, Esq.
Stephen J. Schwartz, P.C.

3000 Marcus Avenue
Jay Goldberg, P.C.

250 Park Avenue, 20'h Floor
NewYork,NewYork 10177-0077
Curtis, Mallet-Prevost, Colt &

MosleLLP
101 Park Avenue
New York, New York 10178-0061
Attn: Robert W. Sheehan, Esq.
EXHIBIT "I"
·..,
•r"
MARY TRUMP TRUST

IRWIN DURBEN, MARYANNE BARRY,
DONALD J. TRUMP AND ROBERT TRU
MP,
TRUSTEES
U/A DECEMBER 16, 1976
FINANCIAL STATEMENTS
DECEMBER 31 , 1990
I
spahr, Lacher & Sperber
°""-
ACCOUNTANTS
Jack Mitnick, CPA 3000 Marcus Avenue

Leonard Koval, CPA Lake Success, NY 11042-1066
Stanley Kleinberg, CPA 516 488-1200 / 718 895-0940
Gerald Rosenblum, CPA 516 354-0050 / 718 348-2226
Stephen J. Schwartz, CPA . Telecopier 516 488-1238
Andrew M. Cohen, CPA
Michael L. Zivotovsky, CPA Members:
Jerome U. Schwortz, CPA . American Institute ofCPA's
Frank G. Percoco, CPA New York State Society of CPA's
Steven Gurien
Consultants:
Kenneth H. Sperber, CPA
Norman Litwack, CPA
To the Trustees of the
Mary Trump Trust:
We have compiled the accompanying statement of trust

assets and liabilities arising from cash transactions of the Mary Trump
Trust as of December 31 , 1 990, and the related statements of revenue
collected and disbursements made and accumulated income, and changes in
principal for the year then ended, in accordance with standards
established by the American Institute of Certified Public Accountants.
The financial statements have been prepared on the cash basis of
-accounting, which is a comprehensive basis of accounting other than
generally accepted accounting principles.
A compilation is limited to presenting in the form of

financial statements information that is the representation of the
Trustees. · We have not audited or reviewed the accompanying
financial statements and, accordingly, do not express an opinion
or any other form of assurance on them.
The Trustees have elected to omit substantially all of

the informative disclosures ordinarily included in financial
statements. If the omitted disclosures were included in the financial
statements, they might influence the user's conclusions about the
trust's assets, liabilities, principal, revenue and disbursements.
Accordingly, these financial statements are not designed for those who
are not informed about such matters.
Lake Success, New York
May 1, 1991
MARY TRUMP TRUST
IRWIN DURBEN, MARYANNE BARRY, DONALD
J. TRUMP
AND ROBERT TRUMP, TRUSTEES
STATEMENT OF TRUST ASSETS AND LIABIL
ITIES
DECEMBER 31, 1990
Pri nci pal Income

Tot al Ass ets Ass ets
Cash in ban k
$17 8,7 44 $14 6,8 02 $ 31; 942
$65 ,00 0 Nas sau Cou nty bon ds -
6% due Jun e 1, 1993
65, 162 65' 162
Mo rtga ge rec eiv abl e - Che lsea Ha ll
12% due Dec emb er 1, 1994 -
50, 000 35, 094 14 '906
Mo rtga ge rec eiv abl e - Na util us Ha
12% due Aug ust 31, 1993 ll -
55, 632 8,5 43 47, 089
Mo rtga ge rec eiv abl e - Win ston Hal l
15% due Aug ust 1, 1991 -
86, 333 86, 333
Mo rtga ge rec eiv abl e - Sho re Haven
Apa rtm ent s #2 - 12- 1/2% due
Oct obe r 1, 1995
290 ,98 3 81, 954 209 ,02 9
Tot al ass ets 726 ,85 4 423 ,88 8 302 ,96 6
Due to Fre d C. Trump
1,0 00 1,0 00 -0-
Net ass ets $72 5,8 54 $42 2,8 88 $30 2' 966
See acc oun tan ts' com pila tion rep ort
.
MARY TRUMP TRUST
IRWIN DURBEN, MARYANNE BARRY, DONALD J. TRUMP
STATEMENT OF REVENUE COLLECTED AND DISBURSEMENTS MADE
AND ACCUMULATED INCOME
YEAR ENDED DECEMBER 31, 1990
Revenue collected:
Interest income:
Certificates of deposit $ 5,301
Money market account 5,630
Nassau County bonds 3,833
Winston Hall mortgage 12,950
Shore Haven Apartments #2 mortgage 36,813
Nautilus Hall mortgage 6,676
Chelsea Hall mortgage 6,051
Total income receipts 77,254
Disbursements:
Distributions to beneficiary 43,834
Federal fiduciary tax 5,124
New York State and City fiduciary tax 2,234
Custodial fees 500
Total disbursements 51,692
Increase in accumulated income 25,562
Accumulated income - 1990 277,404

January 1,
Accumulated income - December 1990 $ 302,966

31,
See accountants' compilation report.

MARY TRUMP TRUST
IRWIN DURBEN, MARYANNE BARRY, DONALD J, TRUMP
STATEMENT OF CHANGES IN PRINCIPAL
Princ ipal balan ce- December 31, 1990 (no change ) $422,8 88
See accou ntants ' compi lation repor t.

.
'
MARY TRUMP TRUST

DONALD J. TRUMP AND ROBERT TRUMP,
TRUSTEES
DECEMBER 31, 1991
Spahr, Lacher & Sperber
°:"""
ACCOUNTANTS
Jack Mitnick, CPA 3000 Marcus Avenue

Leonard Koval, CPA Lake Success, NY 11042-1066
Stanley Kleinberg, CPA 516 488-1200 / 718 895-0940
Gerald Res=blum, CPA 516 354-0050 / 718 S43-2226
Stephen J. Schwartz, CPA Telecopier 516 488-1288
Andrew M. Cohen, CPA
Michael L. Zivotovsky, CPA Members:
Jerome U. Schwortz, CPA American Institute of CPA's
Frank G. Percoco, CPA New York State Society of CPRs
Steven Curien
Mary Trump Trust:
We . have compiled the

accompanying statement of trust
assets and liabilities arising from
cash transactions of the Mary Trump
Trust as of December 31, 1991, and the related statement of revenue
and expenses and changes in accumulated income for the year then ended,
in accordance with standards established by the American Institute of
Certified Public Accountants. The financial statements have been
prepared on the cash basis of accounting, which is a comprehensive
basis of accounting .other than generally accepted accounting
principles.

Trustees. We have not audited or reviewed the accompanying
or any other form of assurance on them,

statements, they might influence the user's conclusions about the

trust's assets, liabilities and principal at December 31, 1991, and its
revenue and expenses and changes in accumulated income for the year
then ended. Accordingly, these financial statements are not designed
for those who are not informed about such matters.

January 28, 1992
., MARY TRUMP TRUST
IRWIN DURBEN, MARYANNE BARRY, DONALD J.
TRUMP
STATEMENT OF TRUST ASSETS AND LIABILITIE
S
DECEMBER 31, 1991
Prin cip al Inco me

Cash in bank
$19 8,77 2 $13 9,64 4 $ 59,1 28
$65 ,000 Nas sau Cou nty bon ds -
6% due June 1 ' 1993
65,0 95 65,0 95
Mor tgag e rece ivab le - Che lsea Hal l -

12% due Dec emb er 1, 1994
50,0 00 35,0 94 14,9 06
Mor tgag e rece ivab le - Nau tilu s Hal l -
12% due Aug ust 31, 1993
55,6 32 8,54 3 47,0 89
Mor tgag e rece ivab le - Win ston Hal l -
15% due Aug ust 1 ' 1 991
86,3 33 86,3 33
Mor tgag e rece ivab le - Sho re Haven

Apa rtme nts /12 - 12-1/2% due
Oct obe r 1 ' 1995
283 !758 89! 179 194 !579
Tot al ass ets 739 ,590 423 ,888 315 ,702
Due to Fred C. Trump
1 !000 1! 000 -0-
Net ass ets $73 8!59 0 $42 2!88 8 $31 5!70 2
See acc oun tant s' com pila tion rep ort.
MARY TRUMP TRUST
STATEMENT OF REVENUE AND EXPENSES
AND CHANGES IN ACCUMULATED INCOME
Reve nue:
Inte rest inco me:
Money mark et acco unt
$ 8, 727
Nass au Coun ty bond s
3,83 3
Wins ton Hall mort gage
12,9 50
Shor e Haven Apar tmen ts #2 mort gage
35,9 68
Nau tilus Hall mort gage
6 ,676
Chel sea Hall mort gage
6,oo o
Tota l reve nue
74 154
Expe nses :
Fede ral fidu ciar y tax
8 '498
New York Stat e and City fidu ciar y tax
3,47 2
Cust odia l fees
500
Tota l expe nses
12,4 70
Exce ss of reve nue over expe nses
61 ,684
Accu mula ted inco me- Janu ary 1, 1991
302! 966
Less : Dist ribu tion s to bene ficia ry 364, 650
48 948
Accu mula ted inco me- December 31, 1991
$ 315, 702
See acco unta nts' com pilat ion repo rt.

MARY TRUMP TRUST
TRUSTEES
DECEMBER 31, 1992
Spahr, Lacher & Sperber CERTIFIED
PUBLIC
ACCOUNTANTS
Jack Mitnick, CPA
Leonard Koval, CPA 3000 Marcus Avenue
Stanley Kleinberg, CPA Lake Success, NY 11042-1066
Gerald Rosenblum, CPA 516 488-1200 I 718 895·0940
Stephen J. Schwartz, CPA 516 354·0050 I 718 343·2226
Andrew M. Cohen, CPA Teiecopier 516 488·1238
Michael L. Zivotovsky, CPA
Jerome U. Schwartz, CPA Members:
American Institute of CPA's
Steven Ourien New York State Society of CPA's
To the Truste es of the

Mary Trump Trust:
We have compile d the accomp anying statem ent of trust

assets and liabil ities arising from cash transa ctions of the Mary Trump
Trust as of Decemb er 31, 1992, and the related statem ent of revenue
and expens es and change s in accumu lated income for the year then ended,
in accorda nce with Statem ents on Standa rds for Accoun ting and Review
Servic es issued by the Americ an Institu te of Certifi ed Public
Accoun tants. The financ ial statem ents have been prepare d on" the cash
basis of accoun ting, which is a compre hensive basis of accoun ting other
than genera lly accepte d accoun ting princip les.
A compil ation is limited to presen ting in the form of

financ ial statem ents inform ation that is the represe ntation of the
Truste es. We have not audited or reviewe d the accomp anying
financ ial statem ents and, accord ingly, do not expres s an opinion
or any other form of assuran ce on them.
The Trustee s have elected to omit substa ntially all of

the inform ative disclos ures ordina rily include d in financ ial
statem ents. If the omitted disclos ures were include d in the financ ial
statem ents, they might influen ce the user's conclu sions about the
trust's assets , liabil ities and princip al at Decemb er 31, 1992, and its
revenue and expens es and change s in accumu lated income for the year
then ended. Accord ingly, these financ ial statem ents are not designe d
for those who are not informe d about such matter s.
Lake Succes s, New York

January 23, 1993
MARY TRUMP TRUST
STATEMENT OF TRUST ASSETS AND LIABILITIES
CASH BASIS
DECEMBER 31, 1992
ASSETS Princ ipal Income

Total Assets Assets
Cash in bank $234,2 02 $139,7 11 $ 94,491
$65,00 0 Nassau County bonds -

6% due June 1, 1993 65,028 65,028
Mortga ge receiv able - Chelse a Hall -

12% due Decem ber 1, 1994 50,000 35,094 ]4,906
Mortga ge receiv able - Nauti lus Hall -

12% due Augus t 31, 1993 55,632 8,543 47,089
Mortga ge receiv able - Winsto n Hall -

15% mature d Augus t 1, 1991 86,333 86,333
Mortga ge receiv able - Shore Haven

Apartm ents #2 - 12-1/2 % due
Octob er 1, 1995 275,57 7 89' 179 186,39 8
Total assets 766,77 2 423,88 8 342,88 4
LIABILITIES
Due to Fred C. Trump 1,000 1,000 -0-
Net assets $765,7 72 $422,8 88 $342,8 84
See accou ntant' s compi lation repor t.

MARY TRUMP TRUST
UIA DECEMBER 16, 1976
CASH BASIS
Revenu e:
Intere st income :
Money market accoun t $ 6 '615
Nassau County bonds
3 '833
Winsto n Hall mortga ge 12,950
Shore Haven Apartm ents #2 mortga ge 35,012
Nautilu s Hall mortga ge
6 '676
Chelse a Hall mortga ge 6 000
Total revenue 71 086
Expens es:
Federa l fiducia ry tax 4,825
New York State and City fiducia ry tax
1 '0 6 0
Custod ial fees 500
Total expens es 6 !385
Excess of revenue over expens es 64,701
Accumu lated income - January 1, 1992 315!702
380,403
Less: Distrib utions to benefi ciary 37!519
Accumu lated income - Decemb er 31, 1992 $ 342,884
See accoun tant's compil ation report.

MARY TRUMP TRUST
TRUSTEES
DECEMBER 31, 1993
Spahr, Lacher & Sperber CERTIFIED
PUBLIC
ACCOUNTANTS
Jack Mitnick, CPA, P.O.
Leonard Koval, CPA, P.O. 3000 Marcus Avenue
Staniey Kleinberg, CPA, P.C. Lske Success, NY 11042-1066
Gerald Rosenblum, CPA, P.O. 516 488-1200 I 718 895·0940
Stephen J. Schwartz, CPA, P.O. 516 354-0050 /718 343-2226
Andrew M. Cohen, CPA, P.O. Telecopier 516 488-1238
Michael L. Zivotovsky, CPA, P.C.
Jerome U. Schwartz, CPA, P.C. Members:
Steven Gurien New York State Society of CPA's
To the Truste es of the

Mary Trump Trust:
We have compi led the accom panyin g statem ent of trust

assets and liabi lities arisin g from cash transa ctions of the
Trust as of Decem ber 31, 1993, and the relate d statem ent Mary Trump
of
and expen ses and change s in accum ulated income for the year then revenu e
in accord ance with Statem ents on Stand ards for Accou nting ended,
and Review
Servic es issued by the Americ an Instit ute of Certif ied- Public
Accou ntants . The finan cial statem ents have been prepar ed on the cash
basis of accou nting, which is a compr ehensi ve basis of accou nting
than gener ally accep ted accou nting princ iples. other
A compi lation is limite d to presen ting in the

finan cial statem ents inform ation that is the repres entati on form of
Truste es. of the
We have not audite d or review ed the accom panyin g
finan cial statem ents and, accord ingly, do not expres s an
or any other form of assura nce on them. opinio n
The Truste es have electe d to omit subst antial ly all of

the inform ative disclo sures ordin arily includ ed in
statem ents. financ ial
If the omitte d disclo sures were includ ed in the financ ial
statem ents, they might influe nce the user's conclu sions
about the
trust 's assets , liabi lities and princ ipal at Decem ber 31, 1993,
revenu e and expen ses and change s in accum ulated income for and its
the year
then ended . Accor dingly , these finan cial ·statem ents are not
design ed
for those who are not inform ed about such matte rs.
Lake Succe ss, New York

Januar y 22, 1994
MARY TRUMP TRUST
IRWIN DURBEN, MARYANNE BARRY, DONALD J.
TRUMP
STATEMENT OF TRUST ASSETS AND LIABILITIE
S
CASH BASIS
DECEMBER 31, 1993
ASSETS
Prin cip al Inco me
Cash in bank
$ 21,1 84 $ 21,1 84
Mor tgag e rec eiv abl e - Che lsea Hal l -
12% due Dec emb er 1, 1994
50,0 00 35,0 94 $ 14,9 06
Mor tgag e rece ivab le - Nau tilu s Hal l -
9-1/ 2% due Aug ust 31, 1996
55,6 32 8,54 3 47,0 89
Mor tgag e rec eiv abl e - Win ston Hal l -
15% mat ured Aug ust 1, 1991
86,3 33 86,3 33
Apa rtme nts #2 - 12-1 /2% due
Oct obe r 1, 1995
266 ,312 89 ' 179 177 ' 133
Mor tgag e rece ivab le - Fon tain eble au
Apa rtme nts - 9-1/ 2% due
Oct obe r 1 , 1996
201 ,393 183 ,555 17,8 38
Apa rtme nts #6 - 9-1/ 2% due
Oct obe r 1, 1996
100 ,696 100 ,696
Tot al ass ets 781 ,550 423 ,888 357 ,662
LIA BIL ITIE S
Due to Fred C. Trump
1,00 0 1,00 0 -0-
Net ass ets $78 0,55 0 $42 2,88 8 $35 7,66 2
See acc oun tan t's com pila tion rep ort.
-2-
CASH BASIS
Revenue
Interest income
Money market account $ 5,169
Nassau County bonds 1,922
Fontainebleau Apartments mortgage 1,393
Shore Haven Apartments #6 mortgage 696
Winston Hall mortgage 12,950
Shore Haven Apartments #2 mortgage 33,928
Nautilus Hall mortgage 6,328
Chelsea Hall mortgage 6,000
Total revenue 68,386
Expenses
Federal fiduciary tax 9,621
New York State and City fiduciary tax 3,615
Custodial fees 250
Total expenses 13,486
Excess of revenue over expenses 54,900
Accumulated income - 1993 342,884

January 1,
397,784
Less: Distributions to beneficiary 40,122
Accumulated income - December 1993 $ 357,662

31,
See accountant's compilation report.

-3-
MARY TRUMP TRUST
TRUSTEES
DECEMBER 31, 1994
AJ}Jtilli
3
1JticIler & OperDer, L.L.t'. PUBLIC
ACCOUNTANTS
Jack Mitnick, CPA, PC 3000 Marcus Avenue

Leonard Koval, CPA, PC Lake Success, NY11042-1066
Gerald Rosenblum, CPA, PC 516 488-1200 /718 895-0940
Stephen J. Schwartz, CPA, PC 516 354-0050 /718 343-2226
Andrew M. Cohen, CPA PC Telecopier 516 488-1238
MichaelL.Zivotovsky, CPA PC
Jerome U. Schwortz, CPA, PC Members:
Michael W. Alderman, CPA AmericanInstitute of CPA's
EdwardP.Ichart, CPA NewYorkstate Society of CPA's
Steven Gurien

Mary Trump Trust:
We have compiled the accompanying statement of trust

assets and liabilities arising from cash transactions of the Mary Trump
Trust as of December 31, 1994, and the related statement of revenues
and changes in accumulated income for the year then ended, in
accordance with Statements on Standards for Accounting and Review
Services issued by the American Institute of Certified Public
Accountants. The financial statements have been prepared on the cash
basis of accounting, which is a comprehensive basis of accounting other
than generally accepted accounting principles.

Trustees. We have not audited or reviewed the accompanying
or any other form of assurance on them.

might influence the user ' s conclusions about the
statements, they
trust's assets, liabilities and principal at December 31, 1994, and its
revenues and changes in accumulated income for the year then ended.
Accordingly, these financial statements are not designed for those who
are not informed about such matters.

January 23, 1995
MARY TRUMP TRUST
U/ A DECEMBER 16, 1976
CASH BASIS
DECEMBER 31, 1994
Prin cipa l Income

Tota l Asse ts Asse' ts
Cash in bank $ 84,53 0 $ 21,18 4 $ 63,34 6
Mort gage rece ivab le - Naut ilus Hall -
9-1/2 % due Augu st 31, 1996 55,63 2 8,543 47,08 9
Mort gage rece ivab le - Wins ton Hall -
15% matu red Augu st 1, 1991 86,33 3 86,33 3 -0-
Mort gage rece ivab le - Shor e Haven
Apar tmen ts #2 - 12-1/ 2% due
Octo ber 1, 1995 255,8 21 89,17 9 '166 ,642
Mort gage rece ivab le - Chel sea Hall -
12% matu red Dece mber 1, 1994 50,00 0 35,09 4 14,90 6
Mort gage rece ivab le - Font aineb leau

Apar tmen ts - 9-1/2 % due
Octo ber 1, 1996 207,0 59 183,5 55 23,50 4
Mort gage rece ivab le - Shor e Haven
Apar tmen ts #6 - 9-1/2 % due
Octo ber 1 , 1996 103,5 26 -0- 103,5 26
Tota l asse ts 842,9 01 423,8 88 419,0 13
LIAB ILITI ES
Net asse ts $841 ,901 $422 ,888 $419 ,013
See acco unta nts' comp ilatio n repo rt.
-2-
MARY TRUMP TRUST
STATEMENT OF REVENUES AND CHANGES IN ACCUMULATED INCOME
CASH BASIS
Revenue s:
Interes t:
Money market $ 192
Mortgage receivab le - Fontaine bleau Apartme nts 25,816
Mortgage receivab le - Shore Haven Apartme nts tf6 12,907
Mortgage receivab le - Nautilus Hall 5,285
Mortgage receivab le - Winston Hall 12,950
Mortgage receivab le - Shore Haven Apartme nts tf2 32,701
Mortgage receivab le - Chelsea Hall 6,000
Amortiz ation of discoun t on mortgage s 8,496
Federal and New York tax refunds 8,458
Total revenues 112,805
Accumul ated income- January 1, 1994 357,662

470,467
Less: Distribu tions to benefic iary 51 '454
Accumul ated income- Decembe r 31, 1994 $419,013
See account ants' compila tion report.
-3-
.;\.
Mary Trump Trust

Irwin Durben, Maryanne Barry,
Donald J. Trump and Robert Trump,
Trustees
U/A December 16, 1976
Financial Statements
Year Ended December 31, 1995
Spahr, Lacher & Sperber, L.L.P. CERTIFIED
PUBLIC
ACCOUNTANTS
Jack Mitnick, CPA, PC
Leonard Koval, CPA, PC 3000 Marcus Avenue
Gerald Rosenblum, CPA, PC Lake Success, NY 11042-1066
Stephen J. Schwartz, CPA, PC 516 488-1200 I 718 895-0940
Andrew M. Cohen, CPA, PC 516 354-0050 I 718 343-2226
Michael L. Zivotovsky, CPA. PC Telecopier 516 488-1238
Jerome U. Schwartz, CPA, PC
Michael W. Alderman, CPA Members:
Edward P. !chart, CPA American Institute of CPA's
New York State Society of CPA's

Mary Trump Trust:
We have compiled the accompanying statement of trust assets and liabilities arising from
cash transactions of the Mary Trump Trust as of December 31, 1995, and the related stateme
nt
of revenues and expenses and chauges in accumulated income for the year then ended,
in
accordance with Statements on Standards for Accounting and Review Services issued by
the
American Institute of Certified Public Accountants. The financial statements have been prepare
d
on the cash basis of accounting, which is a comprehensive basis of accounting other
than
generally accepted accounting principles. "
A compilation is limited to presenting in the form of financial statements information that
is the representation of the Trustees. We have not audited or reviewed the accompanying
fmancial statements and, accordingly, do not express an opinion or any other form of assuran
ce
on them.
The Trustees have elected to omit substantially all of the infomiative disclosures
ordinarily included in fmancial statements. If the omitted disclosures were included in
the
financial statements, they might influence the user's conchisions about the trust's assets,
liabilities and principal at December 31, 1995, and its revenues, expenses and changes
in
accumulated income for the year then ended. Accordingly; these financial statements are
not
designed for those who are not informed about such matters.

January 25, 1996
' '
Mary Trump Trust
Irwin Durben, Maryanne Barry, Donald J. Trump
and Robert Trump, Trustees
Statement of Trust Assets and Liabilities
Cash Basis
December 31, 1995
Principal Income
Total Assets Assets
ASSETS
Cash in bank $ 68,620 $ 21,184 $ 47,436

Mortgage receivable - Nautilus Hall -
9-1/2% due August 31, 1996 55,632 8,543 47,089
Mortgage receivable - Winston Hall -
15% matured August 1, 1991 86,333 86,333 -0-
Mortgage receivable - Shore Haven
Apartments #2- 12-1/2% due
on demand 244,987 89,179 155,808
Mortgage receivable - Chelsea Hall -
12% due on demand 50,000 35,094 14,906
Mortgage receivable - Fontainebleau
Apartments- 9-1/2% due
October 1, 1996 212,885 183,555 29,330
Apartments #6 - 9-1/2% due
October 1, 1996 106.435 -0- 106.435
Total assets 824,892 423,888 401,004
LIABILITIE S
Due to Fred C. Trump 1 000 1 000 -0-
Net assets $ 823,892 $ 422.888 $ 401,004
See accountant's compilation repon. -2-

Mary Trump Trust
Statement of Revenue and Expenses and Changes in Accumulated Income
Cash Basis
Revenues:
Interest:
Money market . $ 678
Mortgage receivable - Fontainebleau Apartments 20,653
Mortgage receivable - Shore Haven Apartments #6 7,744
Mortgage receivable - N autilus Hall 5,285
Mortgage receivable - Winston Hall 12,950
Mortgage receivable - Shore Haven Apartments #2 . 28,760
Mortgage receivable - Chelsea Hall 6,000
Amortization of discount on mortgages 8 735
Expenses:
Bank charges 67
Excess of revenues over expenses 90,738
Accumulated income- January 1, 1995 419 013
509,751
Less: Distributions to beneficiary 108 747
Accumulated income - December 31, 1995 $ 401,004
See accountant's compilation report. -3-

l '
\•
-·
Mar y Trump Tru st

Irw in Durben, Maryanne Barry,
· · Trustees ·· ·
U!A December 16, 1976
Year Ended December 31, 199 6
%"""
Spahr, Lacher & Sperber, L.L.P.
- _ ACCOUNTANTS
Leonard Koval, CPA, PC 8000 Marcus Avenue

Gerald Rosenblum, CPA, PC Lake Success, NY 11042-1066
Stephen J. Schwartz, CPA, PC 516 488-1200 / 718 895.0940
Andrew M. Cohen, CPA, PC 516 854-0050 / 718 343-2226 .
Michael L. Zivotavdy, CPA, PC Telecppier 516 488-1238
Jerome U. Schwortz, CPA, PC
Michael W. Alderman, CPA Members:
Edward P. Ichart, CPA
Consultant
Jack Mitnick, CPA, PC
To the Trustees of the .
Mary Trump Trust:
cash transactions of the Mary Trump Trust as of December 31, 1996, and the related statement
of revenues and changes in accumulated income for the year then ended, in accordance with
Statements on Standards for Accounting and Review Services issued by the American Institute
of Certified Public Accountants. The financial statements have been prepared on the cash basis
of accounting, which is. a comprehensive basis of cowounting other than generally accepted
accounting principles.
A compilationis limited to presenting in the form of financial statements information that
financial statements aiid, accordingly, do not express an opinion or any other form of assurance
on them.
The Trustees have elected to omit substantially all of the informative disclosures
ordinarily included in financial statanents. If the omitted disclosures were included in the
financial statements, they might influence the user's conclusions about the trust's assets,
liabilities and principal at December 31, 1996, and its.revenues and changes in accumulated
income for the year then ended. Accordingly, these financial statements are not designed for
those who are not informed about such matters.
Lake Success, New York .
February 3, 1997
..
.. Mary Trump Trust
Cash Basis
December 31, 1996
Principal Income
Total Assets Assets
ASSETS
Cash in bank $ 43,584 $ 21,184 $ 22,400

9-1/2% due August 31, 1999 55,632 8,543 47,089

9% due August 31, 1999 86,333 86,333 -0-

Apartments #2- 12-1/2% due
August 31, 1999 244,987 89,179 155,808

12% due on demand 50,000 35,094 14,906

Apartments - 9-1/2% due
October 1, 1999 217,395 183,555 33,840

Apartments #6 - 9-112% due
October 1, 1999 108.688 -0- 108.688
Total assets 806,619 423,888 382,731
LIABILITIES

Due to Mary L. Trump 3.630 -0- 3.630
Total liabilities 4.630 1 000 3.630
Net assets $ 801.989 $ 422,888 $ 379.101

Mary Trump Trust
Statement of Revenues and. Changes in Accumulated Income
· Cash Basis
Revenues:
Interest:
Money market $ 944
Mortgage receivable - Nautilus Hall 5,285
Mortgage receivable - Chelsea Hall 6,000
Amortization of discount on mortgages 6 763
488,089
Less: Distributions to beneficiary 108.988
Accumulated income- December 31, 1996 $ 379,101

Mary Trump Trust
Trustees
UIA December 16, 1976
Year Ended December 31, ]997
Spahr, Lacher & Sperber, L.L.P. CERTIFIED
PUBLIC
ACCOUNTANTS
Leonar.d Koval, CPA, PC
Gerald Rosenblum, CPA, PC 3000 Marcus Avenue
Stephen J. Schwartz, CPA, PC Lake Success, !>IY 11042-1066
Andrew M. Cohen, CPA, PC 516 488-1200/718 895-0940
Michael Zivotovsky, CPA, PC 516 354-0050 /718 343-2226
Jerome U. Schwartz, CPA, PC Telecopier 516 488-1238
Michael W. Alderman, CPA
Edward P. !chart, CPA Members:
Mitchell R. Zachary, CPA American Institute of CPA's

Mary Trump Trust:
cash transactions of the Mary Trump Trust as of December 31, 1997, and the related statement
of revenues and changes in accumulated income for the year then ended, in accordance with
of accounting, which is a comprehensive basis of accounting other than generally accepted
A compilation is linlited to presenting in the form of financial statements information that

financial statements and, accordingly, do not express an opinion or any other form of assurance
on them.
The Trustees have elected to omit substantially all of the informative disclosures
ordinarily included in financial statements. If the omitted disclosures were included in the
financial statements, they might influence the user's conclusions about the trust's assets,
liabilities and principal at December 31, 1997, and its revenues and changes in accumulated
income for the year then ended.· Accordingly, these financial statements are not designed for
those who are not informed about such matters.

February 9, 1998
Mary Trump Trust
Cash Basis
December 31, 1997
Principal Income
Total Assets Assets
ASSETS
· Cash in bank $ 57,173 $ 21,184 $ 35,989

9-1/2% due August 31, 1999 55,632 8,543 47,089

9% due August 31, 1999 86,333 86,333 -0-

Apartments #2 - 12-1/2% due
August 31, 1999 ,.-, <"--·-·--· 244,987 89,179 155,808

12% due August 31, 1999 50,000 35,094 14,906

Apartments - 9-1/2% due
October 1, 1999 217,395 183,555 33,840

Apartments #6 - 9-112% due
October 1 , 1999 108.688 -0- 108.688
Total assets 820.208 423.888 396.320
LIABILITIES

Due to Mary L. Trump 3.630 -0- 3 630
Total liabilities 4.630 1.000 3 630
Net assets $ 815.578 $ 422.888 $ 392.690

Mary Trump Trust
Statement of Revenues and Changes in Accumulated Income
Cash Basis
Revenues:
Interest:
Money market $ 847
}.{ortgage receivable - Shore Haven Apartments #6 10,325
,, ,,-, __ Mortgage
,...... receivable
.. - Wiri.ston Hall 7,770
Mortgage receivable - Chelsea Hall 6.000
Accuml!lated income - January 1, 1997 379.101
460,604
Less: Distributions to beneficiary 67.914
Accumulated income- December 31, 1997 $ 392.690

..
Mary Trump Trust

Trustees
VIA December 16, 1976
Spahr, L a c
h e r & Sper
L eo n ar d Kov ber, L .
al, CPA, P C L.P. C E R T IF IE
G er al d Ros D
enblum, CP PUBLIC
S te p h en J. A,
Schwartz, C P C ACCOUNT
Andrew M. PA ANTS
Cchen, CPA , P C
Michael Ziv ,
otovsky, CP P C 3000 Marcu
Je ro m e U. A
Schwortz, C , P C Lake Succe
s Avenue
Edward P . !c PA, P C ss, NY 1104
Mitchell R. h ar t, C P A 516 488-12
00 /7 1 8 89
2-1066
Zachary, C 516 354-00 5-0940
PA 50 I 718 34
Telecopier 3-
5 1 6 488·12 2226
38
Members:
American In
stitute of CP
S ta te Socie A's
New York
ty of CPA's
To the Trus
tee
Mary Trump s o f the .
Trust:
We ha
cash transac ve compiled the accom
tio pan
o f revenues ns o f the Mary Trump ying statement o f trust
a Trust as o f assets and li
accordance nd expenses and chan De ab
with Statem ges in accu cember 31, 1998, and ilities arising from
American In ents on Sta mulated inc the related s
ome for th
sti
o n the cash tute o f Certified Public
ndards for
Accounting e year then tatement
b Ac and R ended, in
generally ac asis o f accounting, w countants. The fmanc eview Services issued
cepted acco h ia by the
unting princ ich is a comprehensiv l statements have been
iples. e basis ·Of prepared
A compilati accounting
o other than
is the repre n is limited
se to p rese
financial sta ntation o f the Trustee nting in the form o f fm
tements and s ancial statem
, according . We have not audit
o n them. ly, do not e ed o r revie ents information that
xpress an op w
inion or any ed the accompanying
other form o
The T f assurance
ordinarily in rustees have elected
clu to
fmancial sta ded in fmancial state omit substantially all
te me o
liabilities a ments, they might in nts. I f the omitted d f the informative dis
nd principa flu ence the u isclosures we closures
income for l a
the year the t December 31, 1998, ser's conclusions abo re included in the
those who a ne an ut
re not inform nded. Accordingly, th d its revenues and cha the trust's assets,
ese financia n
ed about su
ch matters. l statements ges in accumulated
are not desig
ned for
Lake Succe
ss, New Yo
February 1 rk
2, 1999
.,_ ·.
Mary
Irwin Trump Trust
Durben,
Maryanne
Barry, Donald
and J.
Robert Trurnp
Trump, Trustees
U/A
December
16, 1976
Statement of
Trust
Assets and
Liabilities
Cash Basis
December
31, 1998
Principal
ASSETS Total Income
Assets
Assets
Cash in bank
Mortgage $
receivable - 58,459 $
Nautilus - 21,184
9-1/2% due Hall $
August 37,275
31, 1999
Mortgage 55,632
receivable -
9% Winston - 8,543
due Hall
August 47,089
31, 1999
Mortgage 86,333
receivable -
Shore 86,333
Apartments Haven
#2 - -0-
12-1/2% due
August 31, 1999
Mortgage 244,987
receivable -
12% Chelsea - 89,179
due Hall
August 455,808
31, 1999
Mortgage 50,000
receivable -
35,094
- Fontainebleau
Apartments
9-1125-due
14,906 ----
Octõ1ier 1, 1999
Mortgage 217,395
receivable -
Shore 183,555
Apartments #6 - Haven
33,840
9-1/2% due
October 1, 1999
Total assets 108,688

-0-
108,688
LIABILITIES 821,494
423.888
397,606
Due to Fred C.
Due Trump
to
Mary L
Trump
1,000
1,000
Total 3.630 -0
liabilities -0-
3,630
Net assets 4.630
1,000
3,630
$
816.864
$
422,888
$
393,976
See
accountant's
compilation
report.
mary irump Irust

U/A December 16, 1976 .
Statement of Revenues and Expenses and Changes in Accumulated Income
Cash Basis
Revenues:
Interest:
Money market $ 732
Mortgage receivable - Winston Hall . 7,770
Mortgage receivable - Hall . . 6:000

Chelsea.
Expenses:
Bank charges 40
Excess of revenues over expenses 81,348
Acemm2lated income - 1998 392,690

January 1,
474,038
Less: Distributions to . 80,062

beneficiary
Accumulated income - December 1998 $ 393.976

31,

OFFICE
7186482637 pgqa
MARY TRUMP TRUST

IRWIN DURBEN, MARYANNE BARRY, ..
DONALD J.TRUMP AND
ROBERT TRUMP, TRUSTEES
!
k
go M.R.Weiser & Co.t,u>

eSI N Certified Public Accountants
and Consultants
3000 Marcus Avenue

Lake Success. NY 11042-1066
Tel S16-488-1200
Fax 516-488-1238
Write s direct number:
ACCOUNTANTS'
COMPILATION REPORT
Trustees of the
Mary Trump Tmst:
We have compiled the statement of trust assets and liabilities - cash basis of the
accompañÿing
Mary Trump Trust as of December31, 1999, and the related statement of revenues and changes
in accumulated income - cash basis for the year in accordanca with Stateinents on
then ended,
Standards for Accounting and Review Services issued by the American Instimte of Certified
Public. Accountants, The financial statements have been papared on the cash basis of
accotmting, which is a compreh6ñsive basis of accounting other than generally accepted
accountmg pnnciples.
A compilation is limited to presenting in the form of financial statements information that is the
reptasenktion of the Trustees. We have not audited or reviewed the aceodpeyin financial
statements and, accordingly, do not express an opinion or any other form of assurance on them.
The Tmstees have elected to omit substantially all of the disclosures ordinarily included in
f'mancial statements prepared on the cash basis of accounting. If the omitted disclesises were
included in the financial statements, they might influence the user's conclusions about the trust's
assets, liabilities, principal, revenues, and changes in accumulated income. Accordingly, these
financial statements are not designed for those who are not informed about such matters.
CERTIFIED PUBLIC ACCOUNTANTS
Lake Success, N.Y.
February 3, 2000
laWIN DURBEN, MARYANNE DARR , DONALD J. TRUMP
CASH BASIS
DECEMBER 31, 1999
Accountants'
(See Compilation Report)
Principal Income
Total Assets Agets
ASSETS
Cash in bank $ 54,052 $ 21,184 $ 32,868
Mortgage receivable - Nautilus Hall - .

9% due September 1, 2004 55,632 8,543 47,089
9% due September 1, 2004 86,333 86,333 -0-

Apartments #2 - 9% due
September 1, 2004 244,987 89,179 155,808
Moñgage receivable - Chelsea Hall -
9% due March 1, 2004 50,000 . 35,094 14,906
Mortgage receivable -
Fontainebleau
Apartments - 9% due
October 1, 2004 217,395 183,555 33,840
Mortgage receivable - Shore

Haven
Apartments #6 - 9% due -
October 1, 2004 -0- 108,688
108,688_
Total assets 817,087 423.888 393,199
LIABILITIES
Due to the Estate of Fred C. 1,000 1,000 -0-

Tnimp
Due to Mary L. -0
Trump 340. . 3,630
Total liabilities
_ 443Q_ I,000 3 630
Net assets
g gl2A52 $ 422,888 $ 389,569
TRUM1'
MA1n TRUST
IRWIN DURBEN, MARYA NNE BARRY, DONALD J. TRUMP
U/A DEC EMBER 16, 1976
STATEMENT OF REVENUES AND CHANGES IN ACCUMULATED INCOME
CAMH BASIS
(See Accountants Compilation Report)
Revenues: .
Intelest:
Money market $ 707
Iviortgage receivable - Fontainehleau Apartments 20,653
Mörtgage receivable - Nautilus Hall 5,215
Mortgage receivable - Chelsea Hall 4, 875
Accenulated income - 1999

January 1, 393,976
472,001
Less: 1)istributions to beneficiary Ó2,432
Accumulated income - December

31, 1999 S 389.569
.'
(' .
MARY TRUMP TRUST

ffiWIN DURBEN, MARYANNE B'ARRY,
DONALD J. TRUMP AND
ROBERT TRUMP, TRUSTEES
•
M.R.Weiser & Co.Lu
E Certified Public Accountants
and Consultants
3000 Marcus Avenue

Lake Success. NY 11042-1008
Tel 516-488-1200
Fax 516-488-1238
ACCOUNTANTS'
COMPILATION REPORT
Trustees of the .
Mary Trump Trust:
We have compiled the statement of trust assets and liabilities - cash basis of the
accompanying
Mary Trump Trust as of December 31, 2000, and the related statement of reveriues and
changes in accumulated income - cash basis for the year then in accordance with
ended,
of accounting, which is a comprehensive basis of accounting other than generally accepted
A compilation is limited to presenting in the form of financial statements information thaÒs the
. representation of the Trustees. . We have not audited or reviewed the accompanying financid
statements and, accordingly, do not express an opinion or any other form of assurance on
them.
The Trustees ha elected to omit snhetantially all of the disclosures ordinarily included in
financial statements prepared on the cash basis of accounting. If the omitted disclosures were
included in the financial statements, they might influence the user's conclusions about the
trust's assets, liabilities, principal, revenues, and chaliges in accumulated income.
Accordingly, these fiñãñciãl statements are not designed for those who are not informed about
such matters. . ...
CERTIFIED PUBLIC ACCOUNTANTS
Lake Success, N.Y.
January 30, 2001

MARY TRUMP TRUST
CASH BASIS
DECEMBER 31, 2000
Accountants'
(See Compilation Report)
Principal Income
. Total Assets Assets
ASSETS
Cash in bank $ 45,655 $ 21,184 $ 24,471
9% due September 1, 2004 55,632 8,543 47,089
9% due September -0-

1, 2004 86,333 86,333

September 1, 2004 244,987 89,179 155,808
Mortgage receivable -Chelsea Hall - . .

9% due March 1, 2004 50,000 35,094 14,906
Mortgage receivable-- Fontainebleau .

Apartments -- 9% due
October 1, 2004 217,395 183,555 33,840

October -0-
1, 2004 108,688 108.688
Total assets 808.690 423,888 384,802
™
LIABILITIES
Due to the Estate of Fred C. 1,000 1,000 -0-

Trump
Due to L. 3,630 -0- 3,630
Mary Trump
Total liabilities 4.630 1,000 ____3_,63_Q
Net assets $ 804,060 $ 422.888 $ 381,172

. ' .
MARY TRUMP TRUST
. AND ROBERT TRUMP, TRUSTEE S
VIA DECEMB ER 16, 1976
STATEME NT OF REVENUE S AND CHANGES IN ACCUMU LATED INCOME
CASH BASIS
YEAR ENDED DECEMB ER 31, 2000
(See Accountan ts' Compilatio n Report)
Revenues:
Interest:
Money market $ 954
Mortgage receivable - Shore Haven Aparttnents #6 9,782

,'.. .
\:i·: Mortgage receivable - Shore Haven Aparttnents #2 22,049
Mortgage receivable - Chelsea Hall 4500
459,197
Less: Distributions to beneficiary 78 025
Accumulated income- December 31, 2000 $ 381,172·

EXHIBIT ''J''
MANAGEMENT AGREEMENT
Agreement mad t is day of , 1994 between

Fred C. Trump, exford Hall, Inc., Shore Haven Apts. No. 1, Inc.,
Trump Village Construction Company, Beach Haven Apts. No. 1, Inc.,
Sussex Hall, Inc., Beach Haven Management Corp., and Fred C. Trump
and Mary A. Trump, a partnership, all having offices at 600 Avenue
Z, Brooklyn, New York 11223 hereinafter collectively designated as
"Owner" and Apartment Management an office
Associates, Inc., having
at 2611 West 2nd Street, Brooklyn, New York 11223 hereinafter
designated as "Agent".
WITNESSETH
In consideration of the mutual promises and covenants herein

contained, Owner and Agent agree as follows:
ARTICLE I
Owner hereby appoints Agent as the sole and exclusive

management agent of Owner's properties as set forth on Exhibit A,
hereinafter designated as the "Property".
ARTICLE II
(a) Agent shall use its best efforts in disposing of vacant

space, and in keeping the premises rented to desirable tenants, and
to this end is
hereby authorized (but is not required) on behalf of
the Owner, to enlist the services of other real estate brokers.
Owner agrees that, if permitted by law, Agent may charge new
residential tenants a brokerage commission not to exceed two months
rent. With respect to commercial tenants, Agent may charge a
brokerage commission, the amount to be agreed upon prior to
commencement of negotiations, for both new tenants and for renewal
of existing tenants. If for any reason a brokerage commission is
not charged to tenant, then Agent may charge the Owner and owner
shall pay a marketing fee not to exceed two months rent.
(b) At Owner's expense, Agent shall advertise the premises or
portions thereof, prepare and secure renting signs, renting plans,
circular matter and other forms of advertising.
(c) All inquiries received by Owner for any leases or
renewals or agreements for the rental or operation of the premises
or any part thereof shall be referred to the Agent, and all
negotiations connected therewith shall be conducted solely by or
under the direction of Agent.
(d) Agent shall use its best efforts in the management of the
units and due diligence in collecting the rents and other income
therefrom.
(e) Agent may, in the name of and at the expense of the
Owner, institute any and all legal actions or proceedings for the
collection of rent or other income from the property or the ousting
or dispossessing of tenants or other persons therefrom, and such
expense may include the engaging of counsel for any such matter as
set forth herein.
(f) Agent may, in the name of and at the expense of the '
owner, institute any and all legal actions or proceedings to
collect rent from tenants who have vacated their apartments prior
to the end of the lease term, and such expense may include the
engaging of a collection agency for any such matter as set forth
herein. Agent may retain fifty per cent (50%) of the net
collections derived from this section. This fee shall apply to all
monies collected subsequent to the date of the this agreement
whether or not the matter has already been referred to a collection
agent.
(g) Agent is authorized, in the name of and at the expense of
owner, to make or cause to be made such repairs and/or alterations
and maintenance to the premises and apartments therein as may be
advisable or necessary, and to purchase such supplies as may be
advisable or necessary. Agent may utilize its own staff in
effecting repairs, alterations and maintenance in which case Owner
shall pay Agent for the reasonable costs thereof.
(h) Agent is authorized, in the name of and at the expense of
owner, to make contracts for electricity, gas, steam, telephone,
window cleaning, vermin extermination, automobile leasing,
painting of vacant and occupied apartments, apartment renovation
and other services or such of them as Agent shall deem advisable.
To the extent that Agent utilizes its own staff with respect to the
foregoing, then Agent shall be entitled to charge for the
reasonable costs thereof.
( i) Agent agrees on behalf of owner to supervise the work of,
and to hire and discharge employees. Agent agrees to use
reasonable care in the hiring of such employees. It is expressly
understood and agreed, however, that all employees are in the
employ of Owner solely and not in the employ of Agent and that
agent is in no way liable to employees for their wages or
compensation, nor to Owner or others, for any act or omission on
the part of such employees.
(j) Agent shall render to owner a monthly statement of
receipts and disbursements. The disbursements shall include the
compensation of Agent on the basis hereinafter provided.
(k) owner shall reimburse Agent promptly for any monies which
Agent may elect to advance for the account of Owner. Nothing
contained herein, however, shall be construed to obligate Agent to
make any such advances.
(1) All monies received by Agent for, or on behalf of, Owner
(less any sums properly deducted by Agent pursuant to any of the
provisions of the Agreement) shall be deposited in a bank in a
special account maintained by Agent for the deposit of monies of
Owners and not mingled with the funds of Agent.
. (m) Except for certified mail, express mail and/or
"overnight" or special messenger service costs required for the
performance of Agent's duties described herein, as evidenced by
supporting receipts, the Agent will not charge the owner for any
office & administrative expenses incurred at the office of the
Agent, including but not limited to: all telephone, printing,
regular postage, computer, photocopy, office equipment, paper, etc.
Notwithstanding the foregoing, where any servicejuse is commingled
between Owner and Agent (telephone, photocopy, postage machine,
computer, etc.) such costs shall be reasonably prorated.
(n) If it becomes advisable or necessary to make
extraordinary repairs or engage in reconstruction or rehabilitation
of the premises or any part thereof, or if Agent is called upon to
perform any services not customarily a part of the usual services
performed by a managing agent, it is agreed by the parties hereto
that Agent shall receive an additional fee therefor in an amount
agreed upon between the parties.
ARTICLE III
(a) Owner agrees: (1) To hold and save Agent free and
harmless from damages or injuries to person or property by reason
of any cause whatsoever, either in or about the premises, or
elsewhere, when Agent is carrying out the provisions of this
contract or acting under the express or implied directions of
Owner; (2), To reimburse Agent upon demand for any monies which the
latter is required to pay out for any reason whatsoever, either in
connection with, or as an expense in defense of, any claim, civil
or criminal action, proceeding, charge or prosecution made,
instituted or maintained against Agent or Owner and Agent jointly
or severally, affecting or due to the condition or use of the
premises, or acts or omissions of Agent or employees of owner or
Agent, or arising out of or based upon any law, regulation,
requirement, contract or award relating to the hours of employment,
working conditions, wages, and or compensation of employees or
former employees of Owner, or otherwise; (3) To defend promptly
and diligently, at Owner's sole expense, any claim, action or
proceeding brought against Agent or Agent and Owner jointly or
severally arising out of or connected with any of the foregoing,
and to hold harmless and fully indemnify Agent from any judgement,
loss, or settlement on account thereof. It is expressly understood
and agreed that the foregoing provisions of this article shall
survive the termination of this Agreement, but this shall not be
construed to mean the owner's liability does not survive as to
other provisions of this Agreement. Nothing contained in this
article III shall relieve Agent from responsibility to Owner for
gross negligence.
(b) If Owner shall fail or refuse to comply with, or abide
by, any rule, order, determination, ordinance or law of any
Federal, State or Municipal Authority, Agent upon giving twenty-
four hours written notice mailed to Owner as its address first
hereinabove set forth, may terminate this Agreement.
· (c) Owner agrees to carry any and all such insurance as may
be necessary for the protection of the interests of Owner and
Agent. In each such policy of insurance Owner agrees to designate
Agent as.a party insured with owner; the carrier and the amount of
coverage in each policy shall be mutually agreed upon by Owner and
Agent. A certificate of each policy issued by the carrier shall be
delivered promptly to Agent by owner.
ARTICLE IV
''
Agent is clothed with such other general authority and powers

as may be necessary or advisable to carry out the spirit and intent
of this Agreement.
ARTICLE V
owner agrees to pay Agent monthly the following compensation

which has been negotiated between owner and Agent:
(a) For Management: 7% of the net collections received
(payable in equal monthly installments)
(b) It is understood that the foregoing shall be in addition
to fees,. costs or reimbursements to Agent for any services
performed pursuant to this agreement.
ARTICLE VI
(a) This agreement shall become effective on the 1st day of

April, 1994 and shall.continue in full force and effect until the
31st day of December 1999. Thereafter it shall continue in full
force and effect from month to month unless either party hereto
shall serve written notice of cancellation personally or. by
registered or certified mail sent to the address first hereinabove
set forth,· in which event this Agreement shall terminate sixty days
after the service of the notice.
(b) Anything in this article to the contrary notwithstanding,
in the event of a bona fide sale or demolition of a particular
development, Agent may terminate this Agreement, with regard to
that development, upon not less than sixty days notice served in
the manner hereinabove set forth; In this event, this agreement
with respect to the other developments covered will remain in full
force and effect.
(c) In the event a petition in a bankruptcy is filed by or
against the owner, or in the event that the owner shall make an
assignment for the benefit of creditors or take advantage of any
insolvency act, then Agent may forthwith terminate this Agreement
without notice.
(d) Either party may designate a different address for the
service of notices pursuant to this Agreement by serving written
notice to such effect upon the other by registered mail.
ADDITIONAL PROVISIONS
1) As part of the Agent's regular services for which he is

being compensated as provided in Article V (1) (a) hereof and in
conformity and in compliance with required governmental statue,
Agent shall: (a) consider, and when reasonable, attend to
complaints and inquires from tenants of the Owner, and if the Agent
shall deem any such complaint unreasonable, it shall advise the
owner· of the complaint and the reason for its opinion that the
complaint is unreasonable; (b) cause to be prepared and delivered
on or before the first of the each month during the term of the
Management Agreement, monthly statement of rent, additional rent
items and balance due statements to the Owner's tenants; (c)
prepare and send out all notices to tenants which are required or
necessary; (d) prepare all appropriate filings required by
government agencies of Owner and landlord in connection with rent
controlled andfor rent stabilized tenants; (e) prepare for
signature of Agent or Owner, applications to obtain rent increases,
if any; (f) prepare on behalf of owner appropriate responses to
complaints filed by or on behalf of tenants against Owner with
government agencies; (g) assist owner's counsel in proceedings to
collect rent and items of additional rent or to discontinue a
tenants occupancy or obtain possession of any space in the
building, including preparing dispossess and making demand for rent
preceding dispossesses proceedings; (h) give appropriate notice of
lease renewal and prepare renewal leases for rent stabilized
tenants, where appropriate; (i) maintain tenants security accounts
at banks in interest bearing accounts and arrange for the payment
by the banks annually of allowable interest to tenants; Agent shall
retain the amount permitted by law to be retained by the Owner
(presently 1% annually) as additional fee; (j) administer a fleet
of automobiles leased by owner or affiliated companies of Owner;
and (k) obtain, renew and maintain in effect all liqmses and
permits necessary and required for the operation of the premises.
The cost for such licenses and permits shall be paid by Owner.
(2) The Agent represents that it is duly licensed by the
Department of State of New York as a real estate broker in
connection with its services under the Management Agreement.
(3) This Management Agreement is personal to Agent and may

not be assigned by it without owner's prior written approval.
(4) Agent is authorized to engage the services of outside

professionals, at the owner's expense, in regards to investigating
questionable tenancies so as to create vacancies in the event of
illegal tenancies, with the owner's prior written approval.
OWNER: FRED C. TRUMP
BY:
WEXFORD HALL, INC. , SHORE HAVEN APTS.

NO. 1, INC. , TRUMP VILLAGE
CONTRUCTION CORP., BEACH HAVEN APTS.
NO. 1, INC. , SUSSEX HALL, INC., BEACH
HAVEN MANAGEMENT CORP.
BY: a
FRED C. TRUMP AND MARY. A. TRUMP,..A

PARTNERSHIP
BY: .
AGENT: APARTMENT MANAGEMENT ASSOCIATES, INC.
MAAGREE.1
Exhibit A (Fred C. Trump)
Chelsea Hall 8700 25th Ave

Brooklyn, NY 11214
Fontainbleau 8855 Bay Parkway

Brooklyn, NY 11214
Lawrence Towers 3280 & 3310 Nostrand Ave.

Brooklyn, NY 11235
Shore Haven Shopping Center Various Sites

Loc. at 2002-2024 Cropsey Ave.
Brooklyn, NY 11214
Wilshire Hall 182-30 Wexford Terrace

Jamaica, NY 11432
Beach Haven Apts. #3 ·Bldg. #13 - 2681 w. 2nd st., Brooklyn

Bldg. #14 - 2661 w. 2nd st., Brooklyn
Bldg. #15 - 2631 w. 2nd St., Brooklyn
Bldg. #16- 2611 w. 2nd st., Brooklyn
Bldg. #17 - 621 Ave. z • I Brooklyn
Ocean Terrace 2650 Ocean Parkway

Co-op Bldg. Brooklyn, NY 11235
Sea Isle Apts. 3901 Nostrand Ave.

Co-op Bldg. Brooklyn, NY 11235
Vacant Land 1607 Surf, Ave.

Bl. 7062, Lot 28
Surf Ave./West 17th St.

Bl. 7062, Lot 34
Bl. 7212, Lot 100
Bl. 7232, Lot 73
Bl. 7233, Lot 2
Bl. 7237, Lots 63, 64, 65
Exhibit A (Wexford Hall, Inc.)
Wexford Hall 86-75 Midland Parkway

Jamaica, NY 11432
Lawrence Gardens 3301-15-23 Nostrand Ave.
Brooklyn, NY 11229
.. _.........__
... ..............., ,......__.... . . . .... ._, . ,,. .
Exhibit A (Shore Haven Apts. No. 1, Inc.)
Shore Haven Apts. No. 1 Bldgs. #1 to 10

2034, 20361 2038, 2044, 2056, 2058,
2064, 2074, 2076, 2078 Cropsey Ave.
Land at Block #6469, Lot 1, Brooklyn
Shore Haven Apts. No. 2 Bldg. #H 8831 20th Ave.

Bldg. #12 8841 20th Ave.
Bldg. #13 8851 20th Ave.
Bldg. #14 8861 20th Ave.
Bldg. #15 8869 20th Ave.
Bldg. #16 8871 20th Ave.
Bldg. #17 8891 20th Ave.
Bldg. #18 2040 21st Dr.
Bldg. #19 2044 21st Dr.
Bldg. #20 2049 20th Lane
Bldg. #21 2050 21st Dr.
Shore Haven Apts. No. 3 Bldg. #22 1535 Shore Parkway

Bldg. #27 1493 Shore Parkway
Shore Haven Apts. #6(Fiesta) 8635 21st Ave.

Brooklyn, NY 11214
Nautilus Hall 1230 Avenue Y

Brooklyn, NY 11235
Southampton 1429-1445-1461 Shore Parkway

Brooklyn, NY 11214
/
Exhibit A (Trump Village Construction Company)
Briarwyck Apts. 86-25 Van Wyck Expressway

Briarwood, NY 11435
Shore Haven Apts. #5 8800 20th Ave.
(Falcon Apts.) Brooklyn, NY 11214
Trump Village 1 2940 Ocean Parkway
Brooklyn, NY 11235
Trump Village 2 3000 Ocean Parkway
Brooklyn, NY 11235
Trump Village Shopping ctr 486 to 530 Neptune Ave.
Brooklyn, NY 11224
Bore Office McDonald's (Queens)
•
McDonald's (Brooklyn)
Kentucky Fried Chicken
182-39 Hillside Ave.(Vacant)
Bl. 9950, Lot 70
Exhibit A (Beach Haven Apts. No. 1, Inc.)
Beach Haven No. 1 Bldg. #1 2775 Shore Parkway

#2 2795 Shore Parkway
#3 9 Nixon Court
#4 49 Nixon Court
#5 9 Murdock Court
#6 29 Murdock court
#7 49 Murdock Court
#8 675 Avenue z
Land at Block 7216, Lot 38
Block 7237, Lot 2
Block 7238, Lot 2
Block 7238, Lot 82
Argyle Hall 400 Argyle Road

Brooklyn, NY
Beach Haven No. 2 Bldg. #9 2612 West Street

#10 2634 West Street
Beach Haven No. 4 Bldg. #18 2612 West 2nd St.
#19 2632 West 2nd st.,
#20 2662 West 2nd St.
#21 2682 West·2nd St.
Belcrest Hall 162-15 Highland Ave.

Jamaica, NY 11432
Edgerton Hall 178-10 Wexford Terrace

Jamaica, NY 11432
Green Park Essex 143-09; 143-11; 143-23; 143-29

Barclay Ave.
Flushing, NY
Land at Block 6944, Lots 10,
290,458 Brooklyn
Green Park Sussex 143-06; 143-16 Barclay Ave.
Flushing, NY
Grymes Hill Apartments Various sites at Arlo Rd; Howard

Ave.; and Stratford Rd.
staten Island, NY
Kendall Hall 41-10 Bowne st.

Flushing, NY 11355
Westm inster Hall 405 Westm inster Rd.
Brook lyn, NY
Winsto n Hall 178-60 Wexfo rd Terrac e

Jamai ca, NY 11432
Park Tower s 370 Ocean Parkw ay

Co-op Bldg. Brook lyn, NY
Exhibit A (Sussex Hall, Inc.)
Sussex Hall 166-05 Highland Ave.

Jamaica, NY 11432
)
ersh ip)
Exhi bit A (Fred C. Trump and Mary A. Trum p, a partn
Beac h Have n Shop ping Cent er sites at 589 to 611 Ave. Z; 2568
to 2589 West 2nd St.
Exhibit A (Beach Haven Mgmt. Corp)
Land Beach Haven Jewish Center

Bl. 7238, Lot 30
EXHIBIT "K"
FRED C. TRUMP, III and MARYL. TRUMP
COOPERATIVE APARTMENT OWNERSHIP INTERESTS
Fred C. Trump, III and Mary L. Trump each own 10% interest of the
following entities:
1. Midland Associates, LLC consisting of:

Sunnyside Towers Apartments (54 coop apartments)
2. Coronet Hall, Inc. consisting of:
Coronet Hall Apartments (62 coop apartments)
W edgewood Hall Apartments (40 coop apartments)
25% Interest in Lincoln Shore Apartments (57 coop apartments)
3. Highlander Hall, Inc. consisting of:
Highlander Hall Apartments (54 coop apartments)
4. Park Briar Associates, LLC consisting of:
Park Briar Apartments (59 coop apartments)
Saxony Hall Apartments (28 coop apartments)
\
"\
MIDLAND ASSOCIATES ETAL
MORTGAGES AND NOTES RECEIVABLE
DECEMBER 31, 1998
CORONET HALL. INC.
CORONET HALL PROPERTY:
Mortgage Receivable (6%% due 8/1/08) 3,350,647

Underlying Mortgage (7V.% due 8/1/08) 2,938.217
Equity 412,430
WEDGEWOOD HALL PROPERTY:
Mortgage Receivable (8V.% due 7/1/06) 1,217,540

Underlying Mortgage (8% due 7/1/06) 778.380
Equity 439,160
HIGHLANDER HALL, INC.:
Mortgage Receivable (7% due 12/1/08) 3,795,932

Underlying Mortgage (7V.% due 12/1/08) 3.400.000
Equity 395,932
LINCOLN SHORE APARTMENTS PARTNERSHIP
Mortgage Receivable (7.265% due 9/1/28) 2,873,480

Underlying Mortgage (7.64% due 9/1/28) 2.759,081
Equity 114,399
MIDLAND ASSOCIATES, LLC
Total Mortgages Receivable (7% to 9Yz%) 7,200,001

Total Notes Receivable (various rates) 3.356,000
10,556,001
Less: Notes Payable (various rates) 6,956,000
Equity 3,600,001
-2-
PARK BRIAR ASSOCIATES LLC
PARK BRIAR PROPERTY:
Mortgage Receivable (6.94% due 8/1113) 4,569,129

Underlying Mortgage (7.17% due 8/1113) 4.286.245
Equity 282,884
SAXONY HALL PROPERTY:
Mortgage Receivable (7% due 1/1109) 1,977,980

Underlying Mortgage (7Y.% due 111/09) 1.646.839
Equity 331.141
TOTAL EQillTY IN MORTGAGES AND NOTES 5.575.947
FRED C. TRUMP III - 10% 557.595
midland.mor
FRED C. TRUMP III
MARY L. TRUMP
CO-OP APARTMENT INFORMATION
CORONET HALL
172-70 HIGHLAND AVENUE
JAMAICA ESTATES, NY 11432
CO-OP: CORONET HALL TENANTS CORP.

SPONSOR: CORONET HALL, INC.
TOTAL APTS.: 141
SPONSOR OWNED APTS.: 62
HIGHLANDER HALL
164-20 HIGHLAND AVENUE
CO-OP: HIGHLANDER HALL OWNERS, INC.

SPONSOR: IDGHLANDER HALL, INC.
TOTAL APTS.: 165
LINCOLN SHORE APARTMENTS

2727 OCEAN PARKWAY
BROOKLYN, NY 11235
CO-OP: LINCOLN SHORE OWNERS, INC.

SPONSOR: LINCOLN SHORE APARTMENTS PARTNERSHIP
TOTAL APTS.: 174
PARK BRIAR
110-45 QUEENS BOULEVARD
FOREST HILLS, NY 11375
CO-OP: PARK BRIAR OWNERS, INC.

SPONSOR: PARK BRIAR ASSOCIATES, LLC
TOTAL APTS.: 165
-2-
SAXONY HALL
87-15 165TH STREET
CO-OP: SAXONY HALL OWNERS, INC.

SPONSOR: PARK BRlAR ASSOCIATES, LLC
TOTAL APTS.: 85
SUNNYSIDE TOWERS
46-01 39TH A VENUE
SUNNYSIDE, NY 11104
CO-OP: SUNNYSIDE TOWERS OWNERS CORP.

SPONSOR: MIDLAND ASSOCIATES, LLC
TOTAL APTS.: 158
WEDGEWOOD HALL
2580 OCEAN PARKWAY
BROOKLYN, NY 11235
CO-OP: WEDGEWOOD HALL OWNERS, INC.

SPONSOR: CORONET HALL, INC.
TOTAL APTS.: 90
coopapts.fct
Building No. COR Page 1
CORONET HALL Report No. TYS
172-70 HIGHLAND AVE. Printed 09/25/00 (10:00)
JAMAICA ESTATES, NY 114322868 Station : 112
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
2A 2 1/2 440
3A 2 1/2 470
SA 2 1/2 490
7A 2 1/2 510
SA 2 1/2 520
2B 3 1/2 705
6B 3 1/2 765
3C 4 T 780
4C 4 T 790
8C 4 T 830
4D 4 1/2 T 880
5D 4 1/2 T 890
8D 4 1/2 T 920
3E 3 590
4E 3 600
SE 3 610
7E 3 630
BE 3 640
3F 2 1/2 470
SF 2 1/2 490
6F 2 1/2 500
9F 2 1/2 530
2G 2 1/2 440
3G 2 1/2 470
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
5G 2 1/2 490
6G 2 1/2 500
9G 2 1/2 530
5H 3 1/2 755
6H 3 1/2 765
9H 3 1/2 795
2J 5 B 900
8J 5 B 980
3K 5 1/2 TB 1,100
4K 5 1/2 TB 1,110
6K 5 1/2 TB 1,130
7K 5 1/2 TB 1,140
8K 5 1/2 TB 1,150
2L 3 1/2 665
4M 3 1/2 705
9M 3 1/2 755
4N 3 600
5N 3 610
8N 3 640
9N 3 650
3P 3 1/2 695
SP 3 1/2 715
2R 3 1/2 665
4R 3 1/2 705
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOME SHARES
__ - _ ___ _ ______--- ______
7R 3 1/2 735
9R 3 1/2 755
3S 4 1/2 T 870
5S 4 1/2 T 890
68 4 1/2 T 900
78 4 1/2 T 910
3T 3 1/2 735
4T 3 1/2 745
6T 3 1/2 765
7T 3 1/2 775
2U 3 560
4U 3 600
5U 3 610
6U 3 620
GA-R-5-1-
GAR52, *
GARS$ *
GNR99 *
GAR65 *
GAae4 *
GAR£& *
GAR3"E *
G *
=====
44,180
Building No. HIG Page 1
HIGHLANDER HALL Report No. TYS
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
SA 2 1/2 225
SA 2 1/2 245
1B 2 1/2 190
2B 2 1/2 210
3B 2 1/2 213
SB 2 1/2 245
2C 3 1/2 310
4C 3 1/2 320
5C 3 1/2 325
sc 3 1/2 345
9C 3 1/2 350
3D 3 1/2 333
6D 3 1/2 350
1E 3 1/2 310
7E 3 1/2 360
1F 3 1/2 290
6F 3 1/2 330
9F 3 1/2 350
3G 2 1/2 213
9G 2 1/2 250
3J 2 168
SK 2 1/2 245
4L 3 1/2 340
7L 3 1/2 360
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
SL 3 1/2 365
9L 3 1/2 370
2M 5 TB 480
4M 5 TB 490
7M 5 TB 510
9M 5 TB 520
2N 2 1/2 210
4N 2 1/2 220
6N 2 1/2 230
SN 2 1/2 245
9N 2 1/2 250
2P 2 1/2 210
6P 2 1/2 230
1R 2 1/2 190
3R 2 1/2 213
4R 2 1/2 220
9R 2 1/2 250
6S 2 1/2 230
9S 2 1/2 250
1T 4 1/2 420
2T 5 TB 480
4T 5 TB 490
7T 5 TB 510
6U 3 1/2 350
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SEARES
__ - __-- __________ _ __ _--
80 3 1/2 365
8V 2 1/2 245
9V 2 1/2 250
3W 2 168
8W 2 200
9T 5 TB 520
=====
16,558
Building No. LS Page 1
LINCOLN SHORE APTS. Report No. TYS
2727 OCEAN PARKWAY Printed 09/25/00 (10:00)
BROOKLYN, NY 112357837 Station : 112
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
------- ---------- ------
Al 3 1/2 390
Cl 3 1/2 406
Dl 3 1/2 414
Fl 3 1/2 430
B2 2 235
D2 2 245
F2 2 255
C3 4 453
F3 4 480
A4 3 1/2 365
C4 3 1/2 379
B5 3 321
C5 3 327
A7 3 300
C7 3 312
DB 5 l/2TB 603
ES 5 l/2TB 614
B9 3 1/2 377
E9 3 1/2 398
ClO 3 1/2 396
All 2 230
Ell 2 250
Al2 4 435
Bl2 4 444
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
C12 4 453
Dl2 4 462
Al4 3 1/2 365
B14 3 1/2 372
D14 3 1/2 386
El4 3 1/2 393
A15 3 315
C15 3 327
A16 2 230
E16 2 250
F16 2 255
E17 3 324
F17 3 330
AlB 5 l/2TB 570
C18 5 1/2TB 592
F19 3 1/2 405
E20 2 250
B21 4 459
B24 4 479
C24 4 488
C25 3 1/2 401
F26 5 1/2TB 645
B27 3 1/2 388
D27 3 1/2 404
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
_______ - ___--____ ______
E27 3 1/2 412
F27 3 1/2 420
A29 3 1/2 375
E29 3 1/2 407
F29 3 1/2 415
C30 2 240
D30 2 245
F30 2 255
=====
21,371
t .
BuildJ.ng No. PB Page 1
PARK BRIAR Report No. TYS
110-45 QUEENS BLVD. Printed 09/25/00 (10:00)
FOREST HILLS, NY 113755501 Station : 112
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
101 2 1/2 205
801 2 1/2 262
402 3 1/2 328
502 3 1/2 336
802 3 1/2 360
902 3 1/2 368
203 2 1/2 215
403 2 1/2 231
703 2 1/2 254
803 2 1/2 262
204 5 TB 500
304 5 TB 508
504 5 TB 524
604 5 TB 532
305 5 TB 508
805 5 TB 548
905 5 TB 555
307 2 1/2 198
507 2 1/2 213
607 2 1/2 221
208 3 1/2 290
308 3 1/2 298
508 3 1/2 313
608 3 1/2 321
Building No. PB Page 2
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
------- ---------- ------
808 3 1/2 337
209 3 1/2 290
309 3 1/2 298
409 3 1/2 306
210 3 1/2 290
410 3 1/2 306
311 4 1/2 B 428
511 4 1/2 B 444
611 4 1/2 B 452
811 4 1/2 B 468
911 4 1/2 B 475
212 3 1/2 290
412 3 1/2 306
512 3 1/2 313
712 3 1/2 329
912 3 1/2 345
314 4 1/2 418
414 4 1/2 426
514 4 1/2 434
714 4 1/2 450
814 4 1/2 458
914 4 1/2 465
515 4 1/2 434
915 4 1/2 465
Building No. PB Page 3
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
217 6 1/2 TB 620
617 6 1/2 TB 652
518 3 1/2 336
718 3 1/2 352
119 2 1/2 180
319 2 1/2 198
419 2 1/2 206
619 2 1/2 221
111 7 3BT D 800
609 7 B D 675
809 7 B D 690
=====
22,507
Building No. SAX Page 1
SAXONY HALL Report No. TYS
87-15 165th STREET Printed 09/25/00 (10:00)
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
------- ----- ---- - ------
6A 2 1/2 112
3B 2 1/2 103
SB 2 1/2 109
6B 2 1/2 112
7B 2 1/2 115
4C 2 1/2 116
2D 2 1/2 100
SD 2 1/2 109
4E 3 1/2 161
1F 3 1/2 130
2F 3 1/2 155
3F 3 1/2 158
SF 3 1/2 164
7F 3 1/2 170
SG 2 1/2 109
6G 2 1/2 112
7G 2 1/2 115
3H 2 1/2 103
6H 2 1/2 112
7H 2 1/2 115
7J 3 1/2 170
7L 2 1/2 115
5M 2 1/2 119
7M 2 1/2 125
Building No. SAX Page 2
SAXONY HALL Report No. TYS
87-15 165th STREET Printed 09/25/00 (10:00)
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
------- ---------- ------
2N 2 1/2 100
7N 2 1/2 115
5P 2 1/2 109
7P 2 1/2 115
=====
3,448
Building No. SUN Page 1
SUNNYSIDE TOWERS Report No. TYS
46-01 39TH AVE Printed 09/25/00 (10:00)
SUNNYSIDE, NY 111041455 Station : 112
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
L6 3 1/2 270
L7 2 160
LS 2 160
201 2 165
102 4 350
202 4 360
402 4 380
502 4 390
602 4 400
603 4 400
204 5 B 420
404 5 B 440
205 3 1/2 280
305 3 1/2 290
505 3 1/2 310
605 3 1/2 320
307 3 1/2 290
407 3 1/2 300
308 3 1/2 310
408 3 1/2 320
508 3 1/2 330
609 JR 3 185
312 3 1/2 310
512 3 1/2 330
46-01 39TH AVE Printed 09/25/00 (10:00)
SUNNYSIDE, NY 11104145 5 Station : 112
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
214 4 360
414 4 380
614 4 400
515 5 B 450
117 3 1/2 270
217 3 1/2 280
617 3 1/2 320
118 3 1/2 290
218 3 1/2 300
318 3 1/2 310
119 3 1/2 290
419 3 1/2 320
220 4 360
620 4 400
121 5 370
221 5 380
321 5 390
421 5 400
322 3 1/2 310
622 3 1/2 340
223 4 360
323 4 370
423 4 380
324 4 370
4

46-01 39TH AVE Printed 09/25/00 (10:00)
SUNNYSIDE, NY 111041455 Station : 112
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
_______ ________ -- ______
624 4 400
125 4 350
225 4 360
425 4 380
326 2 170
426 2 175
GART
GAR-a
GAR-4
GMt5
GE6
=====
17,705
Building No. WED Page 1
WEDGEWOOD HALL Report No. TYS
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
------- ---------- ------
L1C 3 95
L1H 3 95
L1J 3 95
3A 3 107
4A 3 109
2B 4 1/2 230
3B 4 1/2 233
5B 4 1/2 236
1C 6 TB 275
2C 6 TB 280
4C 6 TB 286
4D 3 1/2 169
SD 3 1/2 169
3E 4 1/2 253
4E 4 1/2 256
6E 4 1/2 256
2F 4 1/2 250
4F 4 1/2 256
SF 4 1/2 256
6F 4 1/2 256
5G 4 189
6G 4 189
4H 4 1/2 236
1J 4 1/2 245
Building No. WED Page 2
WEDGEWOOD HALL Report No. TYS
NO. OF SHARES
APT. NO. OF NO. OF

NO ROOMS SHARES
------- ---------- ------
3J 4 1/2 253
4K 4 1/2 256
6K 4 1/2 256
5L 6 TB 286
6L 6 TB 286
1M 4 1/2 245
3M 4 1/2 233
5M 4 1/2 236
6M 4 1/2 236
lN 3 1/2 165
3N 3 1/2 152
6N 3 1/2 154
lP 4 180
4P 4 189
5P 4 189
6P 4 189
=====
8,526
CORONET
Date A_pi Size Shares Price
9/29/99 8R 3½ 745 $25,000 /ff-rg
10/20/99 3L 3½ 695 32,000 A'51 &
3/15/00 7U 3 630 27,000 /2
3/14/00 9J 5B 990 85,000 //
4/6/00 9A 2½ 530 20,000 /2&5
4/27/00 4L 3½ 705 15,000 /22
7/19/00 3M 3½ 695 34,000 /
rent.15t
HIGHLANDER
E6gwr .JhéT
Date A_pt. Size Shares Price
1/21/00 5S 2½ 225 $20,000 /260 /
3/10/00 6C 3½ 330 30,000 /26T
3/29/00 4G 2½ 220 19,000 /2zG
3/30/00 7U 3½ 360 38,000 /2éürd
TCItt.1st
LINCOLN SHORE
48 65dT [#µ#
Date A_pt Size Shares Price
7/1/99 D19 3½ 391 $56,500 #g5 -cg
9/22/99 D21 4 477 50,000 6Tef
10/4/99 D17 3 318 60,000 / EThf
10/19/99 D18 5½TB 603 100,000 $ odsog)
2/25/00 E24 4 506 g;p (Sfodso A
3/24/00 F16 4 480 90,000 / Efef
3/28/00 A8 5½TB 570 110,000 FI# c F
5/12/00 A3 4 435 70,000 /2 2-fWE
5/23/00 D9 3½ 391 75,000 ETEF

5/10/00 E10 3½ 412 80,000 (SRo,wrgA)
7/12/00 B19 3½ 3 77 70,000 (S f or/So

A)
9/15/00 E28 3½ 379 62,000 U7Af

37'
floo 8't 9 oco (StoAru
3 98 Te
rent,lSt
PARK BRIAR
Date A_pi Size Shares Price
8/9/00 603 2½ 246 $58,000 /Ž&S t†CE
12/14/99 106 6TB 780 200,000 /f EJ#f-f
12/1/00 919 2½ 245 47,000 /2gf#6(
2/25/00 612 3½ 321 87,000 ES A6
3/8/00 216 6TB 600 245,000 /2gf
5/8/00 503 2½ 238 75,000 /2
6/7/00 908 3½ 345 120,000
7/20/00 710 7B 683 267,000
8/7/00 601 2½ 246 76,000
rent.1st
SAXONY
jl£ t:e,/V'r S/1[6;f
NONE
rcntlst
SUNNYSIDE TOWERS
/25/SN'i'
J/NE3
Date apt Size Shares Price
H.g'
9/99 410 2 175 $24,000 fEr
10/99 504 5B 485 99,000 f gf ;St
2/00 314 4 370 90,000 ft
5/00 415 5 440 110,000 c
TentlSt
WEDGEWOOD
/Ž57Er'r fRZed
Date Ap_t. Size Shares Price
5/4/00 2G 4 185 $85,000 4c7W4
5/19/00 1E 4½ 245 65,000 /ff-YP6
rent.lst
EXHIBIT "L"
1
ORIGINAL
SURROGATE'S COURT:
QUEENS COUNTY
---------------------------------x
PROBATE PROCEEDING,
WILL OF File No.
FRED C. TRUMP, 3949-99
Deceased.
---------------------------------x
Surrogate's Court, Queens County
88-11 Sutphin Boulevard
Jamaica, New York

January 5, 2000
9:30 a.m.
Examination of VINCENT J. TOSTI,

taken by respondent, held at the above-
noted time and place, pursuant to Section
1404, before Lisa Stein, a Shorthand
Reporter and Notary Public within and
for the State of New York.
TRISTAR COURT REPORTING SERVICE, INC.

(212) 922-9144
121
1 v. Tosti
2 produced.
3 MR. BARNOFSKY: So you're directing the
4 witness not to answer?
5 DI . MR. LAURINO: I am directing him not to
6 answer and not to waste my time any further.
7 I have another engagement to take care of.
8 MR. BARNOFSKY: I think I'm just about
9 done. Wait, hold it.
10 Let's mark as the next exhibit a
11 promissory note dated August 25, 1992
12 produced by Mr. Laurino and Bate stamped
13 000068. And since they're similar, as the
14 next exhibit, a similar promissory note, Bate
15 stamped 000069.
16 (Respondent's Exhibit 44, promissory
17 note dated August 25, 1992 produced by
18 Mr. Laurino, Bate stamped 000068, marked for
19 identification, as of this date.)
20 (Respondent's Exhibit 45, promissory
21 note Bate stamped 000069, marked for

22 identification, as of this date.)
23 Q. These two documents came from your file?
24 A. Yes, they did.

(212) 922-9144
122
1 v. Tosti
2 Q. What do they represent?
3 A. I think it's privileged what they
4 represent.
5 Q. Well, they were produced by counsel, so
6 presumably any privilege was lost by their
7 production. I don't know why they were produced,
8 but they were produced. I'm trying to find out
9 what they were.

10 MR. LAURINO: You wanted documents
11 executed between that period of time. I
12 asked Mr. Tosti and he produced these

13 documents.
14 Q. So what is it?
15 A. I'd like to have a ruling on this for an
16 authorizati on to release the information as to why
17 they were prepared.
18 Q. Let's get a little foundation. They've
19 been disseminate d. On its face it's a promissory

20 note from Midland Associates to Fred C. Trump;
21 right?
22 A. Yes.
23 Q. What is Midland Associates?
24 A. It's a copartnersh ip.

(212) 922-9144
123
1 V. Tosti
2 Q. And who are the owners?
3 A. The partners are Robert Trump, Donald
4 Trump, Mary Anne Trump-Barry, Elizabeth Trump,
5 Mary and Fred Trump.
6 Q. Mary and Fred Trump my clients?
7 A. Yes.
8 MR. LAURINO: Excuse me, just for your
9 own purposes, Mr. Robert Trump, who's one of
10 the copetitioners here, as well as the
11 corporate officer, has indicated that he has
12 no problem.
13 THE WITNESS: Robert, it's okay?
14 MR. R. TRUMP: Judge?
15 MR. LAURINO: Yes.
16 MR. R. TRUMP: It's fine with me.
17 Q. In any event, Midland Associates is a
18 partnership in which my clients have some
19 interest?
20 A. That's correct.
21 Q. What is this?
22 A. It's a promissory note.
23 Q. Is it issued in connection with a
24 particular transaction?

(212) 922-9144
124
1 v. Tosti
2 A. Yes.
3 Q. What was that transaction?
4 A. It was in connection with the removal of
5 Trump Village I and II from the Mitchell-lama
6 program. We had to buy out the mortgages.
7 Q. And who owned those mortgages?
8 A. Trump Village I and II were corporations
9 owned by Fred C. Trump.
10 Q. And Midland Associates acquired those
11 interests?
12 A. They acquired the mortgages.
13 Q. And they acquired the mortgages and paid
14 Mr. Trump individually for them?
15 A. Correct.
16 Q. So the mortgages were owned by whom
17 prior to the acquisition?
18 A. They were owned by Mitchell-lama.
19 Q. How did it come to pass that the money
20 went to Mr. Trump?
21 A. He loaned the partnership the money to
22 buy out the mortgages.
23 Q. So this in effect was a promissory note
24 evidencing a loan that Mr. Trump individually made

(212) 922-9144
125
B
1 V. Tosti
2 to Midland Associates?
3 A. Correct.
4 Q. Which was then used by Midland
D 5 Associates to acquire these mortgages owned by
6 some other entity?
7 A. Correct.
8 Q. And when you say we had to do this, what
9 was the compelling force that required this
10 closeout of the Mitchell-lama project?

9
11 A. Because they could generate substantial
12 increase in the rent-roll by getting out of the
13 Mitchell-lama program.
14 Q. This was a real estate transaction in
15 the normal course of business?
16 A. Yes.
17 Q. Did this have anything to do with estate
18 planning?
19 A. No.
20 Q. And I see there are two notes; one is
21 dated August 25th and another October 25, 1992.
22 A. Yes.
23 Q. Does that mean the totality was five-six
24 twice?

(212) 922-9144
126
1 V. Tosti
2 A. No. You could see the first note was

3 until --
4 Q. Until October 25th?
5 A. Yes. That was at a differen t interest
6 rate because that was the prevaili ng rate at the

7 time that I received from the accounta nt.
8 Q. The second note is a renewal of the
9 first note?
10 A. Correct, at a differen t rate.
11 Q. There must be dozens and dozens of real

12 estate transact ions that were handled by your
13 office for the Trump Organiza tion during this time
14 frame; right?
15 A. Yes.
16 Q. Is there any particul ar reason all of a
17 sudden I get these two pieces of paper?
18 A. As Judge Laurino indicate d, he asked me
19 for any transact ions within that time frame, loans
20 or anything , so that's when I checked my files and
21 I came up with these.
22 Q. These are the only two transact ions that
23 took place during that time frame?
24 A. I believe the five years in terms of the

(212) 922-9144
1 V. Tos ti
2 loan s or wha teve r I was aske d for.

3 MR. BARNOFSKY: I hav e no furt her
4 que stio ns.
5 Des pite the opp osit ion, I'm sure the
6 reco rd wil l refl ect , I rese rve my righ t to
7 con tinu e the exa min atio n of this witn ess

ente
8 eith er, A, upon the pro duc tion of the Val
9 file if I deem it app rop riat e tha t the re's

10 stu ff in ther e tha t is rele van t to this
11 witn ess; and, B, if perh aps thro ugh furt her
12 jud icia l pro cess the scop e of this
13 exa min atio n is open ed.
14 MR. LAURINO: Wel l, und er 1404 you have
y.
15 you r one bite of the app le and tha t's toda
to
16 If you wan t to exam ine him aga in, you have
I
17 mak e a mot ion and then I eith er wil l con sent
18 or I wil l opp ose it.
19 I have a few que stio ns to ask
20 Mr. Tos ti.

21 FURTHER EXAMINATION
22 BY MR. LAURINO:
23 Q. I not iced tha t Mr. Bar nofs ky did not ask

y.
24 you any que stio ns abo ut test ame ntar y cap acit
TRIS TAR COURT REPORTING SER VICE , INC .

(212 ) 922 -914 4
128
1 V. Tosti
2 On the day of the execution of this
3 document and having represented him before and
4 after, on the day of the execution of this
5 document, did Fred Trump, Fred C. Trump have
6 testamentary capacity to execute the document that
7 has been deemed marked in evidence?
8 A. Yes.
9 Q. And did you observe any abnormality in
10 the procedure followed by Robert Sheehan
11 differently than what you follow as an attorney
12 draftsman for the execution of wills?
13 A. No.
14 Q. He touched all the requirements of the
15 statute?
16 A. Yes.
17 Q. With respect to this Midland Associates,
18 did all of the partners benefit by the advancement
19 of this money?
20 A. Yes, I would assume so, sure. They
21 purchased the mortgage and they were going to get
22 interest under the mortgage at a substantially
23 higher rate than they were paying Fred.
24 Q. So that what he did is he advanced his

(212) 922-9144
129
1 V. Tosti
2 monies and they all benefited by it?
3 A. Correct.
4 MR. LAURINO: I have no other
5 questions.
6 (Time noted: 4:36p.m.)
7
8
9 VINCENT J. TOSTI
10
11 Subscribed and sworn to before me
12 this ______ day of ___________ ____ , 1999.
13
14
15 (Notary Public) My Commission Expires:
16
' 17
18
19
20
21
22
23
24
I

(212) 922-9144
130
C E R T I F I C A T E
STATE OF NEW YORK

ss.
COUNTY OF NEW YORK

I, LISA STEIN, a Shorthand Reporter and
a Notary Public within and for the State of New
York, do hereby certify that the foregoing
deposition of VINCENT J. TOSTI was taken before me
on the 5th day of January, 2000;
That the said witness was duly sworn
before the commencement of his testimony; that the
said testimony was taken stenographically by me
and then transcribed.
I further certify that I am not related
by blood or marriage to any of the parties to this
action nor interested directly or indirectly in
the matter in controversy; nor am I in the employ
of any of the counsel in this action.
IN WITNESS WHEREOF, I have hereunto set
my hand this 13th
LISA STEIN

(212) 922-9144
EXHIBIT "M"
PROMISSORY NOTE 000069
$5,600,000.00 OCTOBER 25, 1992
For value received, the undersigned promises to pay to Fred C. Trump

or order, at 600 Avenue Z, Brooklyn, New York 11223 the sun of Five Million Six
Hundred Thousand Dollars, in lawful noney of the United States as follows:
interest on the unpaid principal balance of the loan payable nonthly at the
rate of 3.79% per annum until August 25 , 1995, when the entire unpaid principal
balance of the loan together with all accrued interest therew shall be due and
payable.
I f any sum payable on any liability of the undersigned to the holder hereof
shall not be paid when due; or if the undersigned or any indorser or guarantor
hereof shal become insolvent (however such be evi-
die, insolvency may
denced), ccanit any act of bankruptcy, or make a general assignment for the
benefit of or if the transaction of the usual business of the under-
creditors;
signed shall be suspended or procedure or supple-
any proceeding, remedy
mentary to or in enforcenent of judgment shall be resorted to or connenced
or with respect to the undersigned or such in-
against, any property of, any
dorser or guarantor; or if a petition in bankruptcy or for any relief under any
law to the relief of readjustment of reorgani-
relating debtors, indebtedness,
zation, ccmposition or extension shall be filed, or any proceeding shall be
instituted under such the or in-
any law, by or against undersigned any such
dorser or guarantor; of if any governmental authority or any court at the
instance thereof shall take possession of any substantial part of the property
of, or assume control over the affairs or operations of , or a receiver shall
be appointed of , or of any substantial part of the property of , or a writ or
order of attachnent or garnishment shall be issued or made against any of the
the undersigned or such indorser or of if in-
property of, any guarantor; any
debtedness of the undersigned or any such indorser or guarantor for borrowed
noney shall become due and payable by acceleration of maturity thereof; or
if the undersigned (if a corporation) shall be dissolved or be a party to any
merger or consolidation without the written consent of the holder hereof, shall
file or authorize or permit to be filed in jurisdiction state-
any any financing
ment under the Uniform Ccanercial Code or like statement in which the
holder hereof is not named as the sole secured party; then this note and all
other present and future demnds of any and all kinds of the holder hereof
agrinst the undersigned, whether created directly or acquired by assignment,
whether absolute or contingent, shall, unless the holder hereof shall otherwise
elect , forthwith be due and payable. The undersigned, if more than one, shall be
jointly and severally liable hereunder, and if any of the undersigned is a

partnership the ma rs shall also be individually liable. The undersigned agrees
to pay all expenses of enforcement, including collection costs and reasonable
attorneys' This
fees, in case default is made in the payment of this note.
note shall be construed according to and governed by the laws of the State of
New York. This note may be in whole or in
prepaid, part, at any time without
penalty.
Midland Associates
by .
Robert S. Trump, Partner
DEFENDANT'S
EXHIBlT
& Yi
PROMISSORY NOTE
$5, 600,000.00 AUGUST 25, 1992
For value received , the undersigned promises to pay to Fred C. Trump

or order, at 600 Avenue Z, Brooklyn, New York 11223 the sum of Five Million Six
Hundred Thousand Dollars, in lawful money of the United States as follows:
interest on the unpaid principal balance of the loan payable monthly at the
rate of 4.41% per annun until October 25, 1992, when the entire unpaid principal
balance of the loan together with all accrued interest therecn shall be due and
payable.
If any sun payable on any liability of the undersigned to the holder hereof
shall not be paid when due; or if the undersigned or any indorser or guarantor
hereof shall become insolvent (however such be evi-
die, insolvency may
denced), ccnmit any act of bankruptcy, or make a general assignment for the
benefit of or if the transaction of the usual business of the under-
creditors;
signed shall be suspended or any procedure or supple-
proceeding, remedy
mentary to or in enforcement of judgment shall be resorted to or comnenced
or with respect to the undersigned or such in-
against, any property of, any
dorser or guarantor; or if a petition in bankruptcy or for any relief under any
law relating to the relief of debtors, readjustment of indebtedness, reorgani-
zation, composition or extension shall be filed, or any proceeding shall be

instituted under such or against the undersigned or such in-
any law, by any
dorser or guarantor; of if any governmental authority or any court at the
instance thereof shall take possession of any substantial part of the property
of, or assume control over the affairs or operations of, or a receiver shall
be appointed of , or of any substantial part of the property of , or a writ or
order of attachment or garnishment shall be issued or made against any of the
property of, the undersigned or such indorser or or if in-
any guarantor; any
debtedness of the undersigned or any such indorser or guarantor for borrowed
money shall beccme due and payable by acceleration of maturity thereof; or
if the undersigned (if a corporation) shall be dissolved or be a party to any
merger or consolidation without the written consent of the holder hereof; or
if the undersigned, without the written consent of the holder hereof, shall
file or authorize or permit to be filed in jurisdiction any state--
any financing
ment under the Uniform Ocumercial Code or like statement in which the
holder hereof is not named as the sole secured party; then this note and all
other present and future demands of any and all kinds of the holder hereof
agairmt the undersigned, whether created directly or acquired by assignment,
whether absolute or contingent, shall, unless the holder hereof shall otherwise
elect, forthwith be due and payable. The undersigned, if more than one, shall be
jointly and severally liable hereunder, and if any of the undersigned is a
partnership the manbers shall also be individually liable. The undersigned agrees
to pay all expenses of enforcement, including collection costs and reasonable
attorneys'
fees , in case default is made in the payment of this note. This
note shall be construed according to and governed by the laws of the State of
New York. This note may be prepaid, in whole or in part, at any time without
penalty.
Midland Associates
by 2).
Robert S. Trump, Partner
EXHIBIT ''N''
.1
ORIGINAL
SURROGATE'S COURT:
QUEENS COUNTY
---------------------------------X
PROBATE PROCEEDING,
WILL OF File No.
Deceased.
---------------------------------X
February 24, 2000
9:53 a.m.
Examination of ROBERT S. TRUMP, taken by
respondent, held at the offices of Stephen J.
Schwartz, P.C., 3000 Marcus Avenue, Lake
Success, New York, pursuant to Section 1404,
before Lisa Stein, a Shorthand Reporter and
Notary Public within and for the State of New
York.

(212) 922-9144
43
1 R. Trump
2 death?
3 A. You want to relate it to the five-yea r
4 period; yes?
5 Q. Yeah.
6 A. He owned it.
7 Q. He owned it, okay.
8 Did you ever come to get an ownershi p
9 position in any of the family -- his entities
10 during the three years after October 1991?
11 A. The only ownershi p I had was what we
12 called the Midland Group.
13 MR. LAURINO: Two years.
14 MR. BARNOSKY: Two years.
15 A. The Midland Group properti es, which I

16 had been a partner in for years with my brothers
17 and my sisters.
18 Q. So you
19 A. And during that period of time I had no
20 ownershi p in anything . I was merely an employee .
21 Q. And your ownershi p position at Midland

22 stayed the same?
24 Q. You said there were, I thought you said,
• TRISTAR COURT REPORTING SERVICE,

(212) 922-9144
INC.
44
1 R. Trump
2 a number of things that were tax driven that were
3 on the table. Was there anything else that was in
4 any way estate tax driven, that you recall, when
5 you came there?
6 A. Again, I don't think of it -- I'm not a
7 lawyer and I'm not an accountant. I don't think
8 of that as an estate tax per se. I think of that
9 as enhancing the value of the company, enhancing
10 the value of the underlying company.
11 And I mentioned the capital improvements
12 that were required to be done on those two
13 buildings, the Trump Village buildings, because it
14 was really typical of the rest of the portfolio.
15 Those buildings were sort of the approximate age
16 of many of the other buildings in the company's
17 portfolio. And a lot of those buildings did need
18 substantial amounts of capital improvement.
19 So it really became, if you will, the
20 next phase of, you know, moving the company, the
21 succession planning, if you will, of the company,
22 to upgrade the quality of the portfolio in terms
23 of physical planr; things like roofs, boilers,
24 sidewalks, elevator equipment.

(212) 922-9144
132
1 R. Trump
(
' 2 A. Yes, he owned Beach Haven and Shore
3 Haven.
4 Q. But you don't think Fred and Mary, my
5 Fred and Mary, had an interest in that?

6 A. I believe they're part I believe they
7 inherited from their father part of the ground

8 lease underlying those developmen ts along with my
9 brothers and sisters. And that's the ground lease
10 with the tenant being Beach Haven and Shore Haven.

11 Q. So the ground lease is not something
12 your father had an interest in?

c 14 Q. So you think it is a correct statement
15 that there were no entities in which your father

16 had an interest simultaneou sly with Fred and Mary
17 having an interest?
18 A. I believe that's correct.
19 Q. Are there any Trump family entities or
20 partnership s, corporation s that are payees of any

21 of the partnership s which we've seen the documents
22 on? In other words, you know what I'm saying, I
23 saw, for example, there are lots of checks going
24 out to Trump Management from the various entities,

(212) 922-9144
133
1 R. Trump
2 Trump Management obviously is the management
3 company, and that was owned by your father; right?
5 Q. So that's just going from one pocket to
6 the other?
7 A. Uh-huh.
8 Q. Is that right?
10 Q. There was something called Trump
11 payroll, same sort of thing, going from your
12 father's money to other pockets of your father's
c
13 money?
14 A. That was the payroll disbursement arm,
15 i f you will.
16 Q. But was there any monies, and I've got
17 records of all these entities for the three years,

18 are there any monies going from the entities in
19 which your father owned to other entities in which
20 other Trump family members have an interest?
21 A. I don't believe during the two-year
22 period. I don't believe during the first two-year

23 period.
24 Q. Do you know that for a fact?
c
(212) 922-9144
134
1 R. Trump
2 A. I don't know it for a fact.

3 Q. There are entitie s within -- that other
4 Trump family member s have an interes t that there
5 were checks coming from the various partne rship
6 interes ts?
7 A. Which I believe were created later after
8 the two-ye ar period.
9 Q. What are the names of those entitie s?
10 A. One is Apartm ent Manage ment Associ ates,
11 which manage s the apartm ent --
12 MR. LAURINO: Is this beyond the
13 two-ye ar period?
14 MR. BARNOSKY: He said he wasn't sure.
15 THE WITNESS: I believe it is.
16 Q. Well, if I can just get the names, I can

17 then check the checkbo oks. I won't pry. Just
18 give me the names.

19 A. The other is All County Buildin g Supply.
20 Q. Well, I can assure you there are checks
21 during the two-ye ar period to All County Buildin g

22 Supply . Tell me about All County Buildin g
23 Supply .
24 A. It's a purcha sing -- in essence , a
• TRISTAR COURT REPORTING SERVIC E, INC.

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1 R. Trump
2 purch asing compa ny set up to acqu ire goods ,

3 servi ces, sort of comb ining the purch asing powe r
4 of the whole compa ny. Rathe r than the syste m of
5 havin g each indiv idual build ing order indiv idual ly

6 its parti cular build ing needs , we start ed buyin g
7 on a whol esale basis , and then from vend ors,
8 from supp liers , and then selli ng that off to the

9 entit ies.
10 Q. And that' s a corpo ratio n, All Coun ty
11 Build ing -- it's actua lly All Coun ty Build ing

12 Supp ly and Main tenan ce?
13 A. I don't know if it's a corpo ratio n or a
14 partn ershi p. I'm not sure.
15 Q. Who owns that?
16 A. My two siste rs, my broth er, myse lf, and
17 my cousi n John Walte r.

18 Q. And did you have anyth ing to do with the
19 setti ng up of that corpo ratio n?

20 A. I was -- yes, I was invol ved.
21 Q. Were there attor neys invol ved?
22 A. Yeah, there likel y were, but I can't
23 tell you who it was. I woul dn't know who it was.
24 Q. And so was one of the purpo ses of -- All
TRIST AR COURT REPORTING SERV ICE, INC.

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•
1 R. Trump
2 County Building Supply in addition to having the
3 business purpose of centraliz ed purchasi ng power,

4 if you will, could mark up and generate a profit
5 on its own?
7 Q. And that was one of the other purposes ?
8 A. It was a purpose also, yes.
9 Q. So to the extent that that markup was
10 created at a level outside of your father's

11 entity, in effect it had the effect of decreasi ng
12 his estate; right?
13 A. Possibly to some extent offsettin g that
14 is the fact that by buying through a third-pa rty

15 vendor items of supply, plumbing fixtures , things
16 like kitchen cabinets , et cetera, my father's

17 company was able to increase the rents that he
18 charges for the apartmen t units under what they
19 call MCI, major capital improvem ent. And if you
20 do renovati ons through an outside third-pa rty

21 company, you can then increase the rent on a
22 particul ar unit one-fort ieth the cost of the
23 improvem ent; and then over the first 40 months you
24 could receive back the amount that was paid in the

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1 R. Trump
9 2 form of rent. After that 40-month period, the
3 rent stays at the same level, it doesn't get
4 rolled back, so really the estate at that point
5 ism2€ beneficiary of having done that transaction.
6 Q. Who initiated the idea of this All
7 County building?
8 A. I would say probably it was my idea.
9 Mine, I think, in consultation with our lawyers,
10 with our outside auditors. I know John Walter was
11 involved as well.
--
12 Q. We're going to go over I have a
13 statement for September of 193, and there were
9 14 payments being made then. The entity was
15 obviously then created prior to that.
16 Did Mr. Sheehan have anything to do with
17 this?
18 A. No, he didn't.
19 Q. Mr. Durben, to your knowledge?
20 A. I would say, yes, they were probably
21 involved. I don't know if it was Mr. Durben or
22 Mr. Tosti.
23 Q. Involved in the mechanics of the
24 creation?
•
(212) 922-9144
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1 R. Trump
2 A. The creation and also the discussion
3 leading up to the creation of that, of the entity.

4 Q. Are there any agreements that exist for
5 the shareholders of All County, any shareholder
6 agreements, to your knowledge?
7 A. There probably are. I don't know where
8 they would be.

9 Q. Are there contractual agreements between
10 All County and the Trump Organization, if you
11 will, as to being the exclusive purchasing agent
12 and the level of markups, that sort of thing?
13 A. There would be agreements back and

14 forth, but I don't recall what those agreements
15 contained.
16 Q. Was this done as part of the project
17 that you were talking about, one of the projects
18 were these capital improvements on many of the
19 buildings?
20 A. In part, it was done in part to do
21 that. And we found that by each individual
22 building buying its own supplies, its own
23 maintenance, there was no centralized control;
24 there was nobody telling the building

(212) 922-9144
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1 R. Trump
2 superintendent what he could order or could not
3 order. So we felt the large combined purchasing
4 power, which we were not taking advantage of, so
5 we decided to take advantage of it.
6 It also relates to some of the capital
7 improvements to the extent we could increase the
8 cost of items and then get higher rents within the
9 various entities.
10 Q. Is McFar -- did you ever hear of that,
11 M-e-f-a-r, is that another family-owned entity?
12 A. No, it's not.
13 Q. That's a third party?
14 A. A third-party contractor.
15 Q. The other name that you gave?
16 A. Apartment Management Associates.
17 Q. What did that do?
18 A. It created, I believe, later, but it's
19 in the business of managing the individual
20 developments. What Trump Management, Inc. had
21 really done we shifted the focus over to Apartment
22 Management Associates.
23 Q. So, in effect, you took the money that
24 was being paid from the entities to Trump

(212) 922-9144
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1 R. Trump
2 Management, which was owned by your father, and
3 that money went to a company controlled by people
4 other than your father?
6 Q. Are those the only two names you can
7 think of?
8 A. I believe so, yes.
9 Q. When was it that I'm sorry, that
10 other name was Apartment?
11 A. Management Associates.
12 Q. Did this All County Building also act as
13 the purchasing agent for Midland?
14 MR. LAURINO: Excuse me, we're going
15 back again to something that does not belong
16 in the estate. You know, I didn't object.
17 This is a probate proceeding, not an
18 accounting proceeding.
19 MR. BARNOSKY: I understand that.
20 MR. LAURINO: You may understand it, but
21 you keep diverting back to Midland and he's
22 not going to answer any questions about
23 Midland.
24 MR. BARNOSKY: You have estate assets,
• TRISTAR COURT REPORTING SERVICE, INC.

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1 R. Trump
2 what was at one point estate assets, being
3 diverted, if you will, to entities not
4 controlled by the decedent; and to that
5 extent, in effect, this is part of an overall
6 testamentary plan. I would submit, may be
7 good estate planning, but it got money out of
8 Fred Trump's estate and someplace else.
9 MR. LAURINO: And at the appropriate
10 time when you prevail at that time you can
11 start an action for a judicial accounting.
12 MR. BARNOSKY: I'm not looking for
13 numbers. I'm looking to find
14 MR. LAURINO: Or you can dissolve the
15 partnership.
16 MR. BARNOSKY: I think I'm allowed to
17 inquire as part of a pattern of what was
18 happening here. This is the pattern of the
19 planning; whose idea was it and who set it up
20 and everything.
21 DI MR. LAURINO: I'm going to object and
22 I'm going to direct that he not answer.
23 MR. BARNOSKY: Let's mark
24 MR. LAURINO: This is not a judicial
• TRISTAR COURT REPORTING SERVICE, INC.

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1 R. Trump
2 accounting.
3 MR. BARNOSKY: I told you I was aware of
4 that.
5 Let's mark -- and I apologize, I don't
6 have multiple copies of some of these because
7 I wasn't sure I was going to use them. This
8 is from the documents that were produced.
9 It's called cash disbursements for an entity
10 called Beach Haven Management for September
11 1993. Let's mark it, and I'm just going to
12 refer to it.
13 (Respondent's Exhibit 86, cash
14 disbursements for Beach Haven Management for
15 September 1993, marked for identification, as
16 of this date.)
17 Q. You'll see on the first page there are
18 three entities to that All County. That's the All
19 County we're talking about; right?
20 A. Yes.
21 Q. And those are payments made from -- I
22 just randomly picked one entity -- to All County?
24 Q. Prior to the establishment of All

(212) 922-9144
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143
1 R. Trump
2 County, those payments -- the purchasing was being
3 done directly to the vendors?

4 A. Yeah, albeit a higher price.
5 Q. Albeit a higher price, but here
6 presumably All County would buy what you say is a

7 lower price, then there would be a markup on its
8 charge to the various Trump entities; right?
9 A. Yes, but I'm not sure the Trump entities
10 wound up paying more. The purchasing power, as I
11 said, more than offset in many cases, if not all
12 cases, certainly many of the cases, offset the
13 markups that All County was receiving.

14 Q. I understand.
15 A. And, again, in some cases it was
16 beneficial; the higher the markup would be, the
17 higher the rent that might be charged on

18 particular apartments, or the greater the tax
19 reductions could be on the developmen t under the
20 City's J-51 plan.
21 Q. But All County could have been set up
22 with your father owning it and achieved the same

23 purpose?
24 A. Theoretica lly. No, it actually could

(212) 922-9144
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144
1 R. Trump
2 not because then you could not take advantage of
3 the rent increases nor could you take advantage of
4 the tax reductions. It had to be a third-party
5 entity doing the work.
6 Q. Do you know-- you said you didn't know
7 exactly when All County was created.
8 MR. BARNOSKY: I'm going to mark as the
9 next exhibit cash disbursements for the same
10 Beach Haven for January '93.
11 (Respondent's Exhibit 87, cash
12 disbursements for Beach Haven for January
13 '93, marked for identification, as of this
14 date.)
15 Q. This is January '93. You'll see again
16 on the first page some disbursements to All
17 County.
18 A. Okay.
19 Q. Suggesting that All County was in
20 existence at least as early as January of '93;
21 right?
22 A. That would be correct, yes.
23 Q. I'm going to -- I'm not going to burden
24 you with going through every document.

(212) 922-9144
INC.
145
1 R. Trump
2 A. Thank you.
3 Q. Would it be fair to say that once you

4 established All County as the purchasing agent,
5 that the purchases for all of the entities would

6 have been through All County just as we're now
7 seeing happened with Beach Haven?
8 A. I believe so.
9 Q. And I'm going to find the same kind of

10 entries in all of those other entities to the
11 extent they had purchasing requirements?
12 A. Right.
13 Q. Tell me about --and I'm going to go
14 through and see if we can find out exactly when

15 that started.
16 A. We can look it up for you, in all
17 fairness.
18 Q. I think I have it here. I just didn't
19 know that that was relevant when I was going

20 through it, so I have to find the earliest entry.
21 Did your father participate in the
22 discussions about the creation of this All County
23 mechanism?
24 A. Yes.

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1 R. Trump
2 relationship, to the extent it existed, between
3 himself and Fred and Mary's mother?

4 A. Not during this five-year period, no.
5 Q. Did your father provide, to your
6 knowledge, any financial benefits to my clients'
7 mother?
8 A. I believe he did, yes.
9 Q. Apartment?
10 A. There were a variety of benefits.
11 Q. Did he have any relationship with her,
12 to your knowledge?
13 A. He did not.
14 Q. Did your mother?
15 A. She did not.
16 MR. BARNOSKY: Why don't you just give
17 me five minutes.
18 (Recess taken.)
19 RQ Q. I'm through. I would just like to, on
20 the record, request the documents on All County
21 Management, its shareholders' agreement, and any
22 contractual arrangements between entities in which

23 your father had an interest, and to the extent
24 that they exist during the five-year period on

(212) 922-9144
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1 R. Trump
2 both of those corporations.
3 MR. LAURINO: We'll furnish you with the
4 dates. And I think one of them is in '94.
5 And that's essentially the reason why you
6 don't have any records on that one. And if
7 it's '94, we'll give you the date, but
8 nothing more than that.
9 MR. BARNOSKY: I understand.
10 MR. LAURINO: But if my records are
11 correct, you were going to furnish me with
12 copies of '85 through '89.
13 MR. BARNOSKY: Yeah, we can either do
14 that right now or send it to you.
15 MR. LAURINO: You can send it to me.
16 (Continued on the following page.)
17
18
19
20
21
22
23
24

(212) 922-9144
168
STATE OF NEW YORK
ss.
COUNTY OF NEW YORK
I, LISA STEIN, a Shorthand Reporter and
a Notary Public within and for the State of New
York, do hereby certify that the foregoing
deposition of ROBERT S. TRUMP was taken before me
on the 24th day of February, 2000;
before the commencement of his testimony; that the
said testimony was taken stenographically by me
and then transcribed.
I further certify that I am not related
by blood or marriage to any of the parties to this
action nor interested directly or indirectly in
the matter in controversy; nor am I in the employ
of any of the counsel in this action.
IN WITNESS WHEREOF, I have hereunto set
my hand this 6th
LISA STEIN

(212) 922-9144
INC.
EXHIBIT "0"
CoPY
SURROGATE'S COURT:
QUEENS COUNTY
---------------------------------x
PROBATE PROCEEDING,
WILL OF File No.
Deceased.
---------------------------------X
Surrogaters Court, Queens County
88-11 Sutphin Boulevard
Jamaica, New York
March 7, 2000
9:55 a.m.
Examination of JOHN W. WALTER, taken
by respondent, held at the above-noted
time and place, pursuant to Section 1404,
before Lisa Stein, a Shorthand Reporter
and Notary Public within and for the
State of New York.

(212) 922-9144
256
1 J. Walter
2 Q. A person named Sam Goldman at one
3 point?
4 A. Sam Goldman was a bookke eper who
5 worked for Bill Price.
6 Q. Did he leave?
7 A. He left at 78 or someth ing.
8 Q. At age 78?
9 A. Yes. I mean, he's well in his
10 sevent ies. Didn't look it, but.
11 You have to underst and that we're
12 mostly comput erized now and in the earlier years

13 everyth ing was hand-p osted in ledger papers and
14 that work subside d.
15 Q. Was there someone in charge of
16 purcha sing?
17 A. No, but during that time frame after
18 the will, not before, I guess 1992 probab ly,
19 Mr. Trump had, after I had come back, had said
20 that he wanted me to reiniti ate a purcha sing
21 system that I had done in the '60s and stopped

22 when I went with Telepro mpter, and so he had
23 liked that program but there was nobody to run

24 it while I was gone, so he said we should do
25 that again and take advanta ge of purcha sing.
TRISTAR COURT REPORTING SERVIC E, INC.

(212) 922-914 4
257
1 J. Walter
2 Q. Is that what led to the creation of

3 this All County Building?
4 A. Yes.
5 Q. And that was sometime in '92?
6 A. Yes. I started writing the computer
7 program for it in August of '92.
8 Q. That was your idea to do that?
9 A. It was his idea. And I said, well,
10 this time let's computerize it. Doing it by
11 hand is going to take forever.
12 Q. In '91 who was doing the purchasing?
13 A. In '91 it was the supers. The same
14 way as it always had been. The supers would
15 order supplies.
16 Q. There was no one in central office
17 whose responsibility was purchasing?
18 A. No. It was basically decen.tralized
19 for each building ordered their own and then Mr.
20 Trump would.
21 Q. Are the names you gave me pretty much
22 all of the people that are at the top of the
23 pecking order? Was there anyone that was in any
24 way viewed higher than any of the people you
25 named that you didn't mention?

(212) 922-9144
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1 J. Walter
2 A. I don't think there's anyone higher.
3 I think that's probably it, unless you have some
4 other names to refresh my memory.
5 Q. No, that's why I'm asking you.
6 So All County, that was a
7 corporation --
8 A. Yes.
9 Q. -- that was formed?
10 A. Yes.
11 Q. Were you instrumental in instructing
12 some lawyer to incorporate the business?
13 A. Yes.
14 Q. Who that was lawyer?
15 A. Durben probably or Tosti, one of the
16 two.
17 Q. It was set up to serve as a central
18 purchasing organization?
19 A. Correct.
20 Q. And it would do purchasing, and the
21 cost would then be allocated to the various
22 entities that owned various properties; right?
23 A. It would be allocated to the entity
24 that needed it specifically, yes.
25 Q. And who were the shareholders of All

(212) 922-9144
259
1 J. Walter
2 County?
3 A. Myself, Robert, Donald, Maryanne and
4 Elizabeth.
5 Q. In equal shares?
6 A. Yes.
7 Q. And that's a Sub-S Corporation?
8 A. Yes.
9 Q. And when did it start doing business,
10 do you know?
11 A. Well, I think we were incorporated in
12 August of '92. We probably started doing test
13 business, if you understand that, because I'm
14 designing a computer system as the company is
15 starting to function, so we did test purchases
16 just to get it through the system probably in
17 September or October. There was really no
18 significant business of consequence in 1992, and
19 as the computer system could carry it, we
20 started doing more business in '93.
21 Q. It was intended that this business
22 was going to do some markups so that it could
23 make a profit; right?
24 A. Well, what was intended was there
25 were a lot of reasons why All County made

(212) 922-9144
260
1 J. Walter
2 sense. First of all, Mr. Trump was very
3 concerned about the price of what we charged,
4 what we could use to establish a capital --
5 major capital improvement for rent increase
6 purposes.
7 Because of the rent stabilization
8 program, a landlord in New York City, New York
9 State, is allowed to increase the rent by a
10 specific percentage, which is set each year by
11 the Rent Stabilization Board. The only way a
12 landlord can increase the rent over and above
13 that amount is to make some significant capital
14 improvement to its property. The idea being,
15 the State will acknowledge if you improve your
16 property, will allow you to pass the cost of
17 that on to the tenant in an increased rent that
18 is one-fortieth the cost of the improvement.
19 So if Mr. Trump, in his expert
20 negotiation ability, gets a refrigerator from
21 P.C. Richard's for $200, that a normal person
22 could go and buy for $350, he then delivers that
23 refrigerator, has P.C. Richard deliver that
24 refrigerator for $200, or whatever, to the
25 building, has his staff, Mr. Trump's staff,

(212) 922-9144
261
1 J. Walter
2 carry it up to the building because there's no

3 -- the delivery charge will only be made to the
4 building, A, if a tenant did that, the cost
5 would be 350 plus 25 delivery, he's only getting
6 250 plus no delivery.
7 He said, that makes no sense. I
8 should be able to get the same benefit that it

9 would cost the tenants. So he said, devise a
10 method -- you have to understand the thinking
11 that went behind this.
12 Q. I understand.
13 A. So All County would then charge the
14 $25 and then, therefore, he could get credit for
15 it, and that was with a markup. You asked about
16 a markup.
17 Q. My question started, and so it was
18 intended that the corporation make a profit;
19 right?
20 A. It was intended that the family make
21 a profit.
22 Q. The corporation make a profit and
23 distribute it to its shareholders?
24 A. Okay.
25 Q. And, in fact, it did make a profit?

(212) 922-9144
262
1 J. Walter
2 A. It did.
3 Q. And that was a Sub-S Corporation and
4 that profit went out to the shareholders?
6 Q. And do you recall how much profit was
7 distributed to the shareholders in 1993?
8 A. To each shareholder, a few thousand
9 dollars.
10 Q. And Mr. Trump was not a shareholder?
11 A. That's correct, he didn't choose to
12 be one.
13 Q. And why was that?
14 A. He said it didn't make much sense.
15 Q. Why is that?
16 A. He said because he would have to pay
17 a death tax on it.
18 Q. So one of the ancillary benefits was
19 to the extent that the money went downstream, it
20 wasn't going to be subject to estate taxes?
21 A. Correct. He loved to save taxes.
22 Q. How did it come to pass that you were
23 one of the shareholders?
24 A. He asked me to do it and said I
25 should be a shareholder.

(212) 922-9144
287
STATE OF NEW YORK
ss.
COUNTY OF NEW YORK
I, LISA STEIN, a Shorthand Reporter
and a Notary Public within and for the State of
New York, do hereby certify that the foregoing
deposition of JOHN W. WALTER was taken before me
on the 7th day of March, 2000;
before the commencement of his testimony; that
the said testimony was taken stenographically by
me and then transcribed.
I further certify that I am not
related by blood or marriage to any of the
parties to this action nor interested directly
or indirectly in the matter in controversy; nor
am I in the employ of any of the counsel in this
action.
IN WITNESS WHEREOF, I have hereunto
set my hand this
LISA STEIN

(212) 922-9144
EXHIBIT "P"
[ é:un B104 - Summons without Nodce, Blank Court BhuterOFxcehior,R2Ushar,NYC10013
Mai¾ Personal or Substituted Service. 12 pt. type, 4-94
Index No. CD-Coø745

COUNTY OFNASSAU Date purchased 4fa t 00
.. .... ......
LINDA C. TRUMP, MARY TRUMP, LISA Plaintiff(s) designate(s)

TRUMP and FRED-C. NASSAU
TRUMP, III,
as· as the place of trial.
individually and parent andnatural guardian of County
WILLIAM TRUMP, an infant under the age of 18 years,
""
against . $11111ttt0115
DONALD TRUMP, J. ROBERT S. TRUMP
. . The basis of the venue is
and MARY ANNE TRUMP as Prelinunary Co-
BARRY, .
Plaintiffs' .
Executors of the 2state of FRED C. TROMP, deceas-ed,
Place of Residenc
and APARTMENT NANAGEMENT ASSOCIATES,INC.
efendan gs)
and.TRUMP MANAGEMENT, INC.,
at old Wes tbury, .

Plaintiff(s) reside(s)
County of Nassau
To the above named Defendant(s)
on are IJereby guntmsiEb to answer the complaint in this action, and to serve a copy of your
answer, or, if the complaint is not served with this se_mons, to serve a notice of appearance, on the Plaintiffs
Attorney(s) within 20 days after the service of this summons, exclusive of the days of service (or within
30 days after the service is complete if this summons is not personally delivered to you within the State of New
York); and in case of your failure to appear or answer, judgment will be taken against you by default for the
relief demanded in this complaint
FARRELL FRITZ, P.C.

Dated,April 27, 2000
Uniondale, New York
Defendant's address:
Donald J. Trump
7 21 Fifth Avenue
By : .
New York, NY
Jame M. icks, Esq.
Robert S. Trump
167 East 61st Street Att for Plaintiffs
y(s)
New York, NY
Maryanne Office and Post Office Address

Trump Barry
EAB Plaza - 14th West Tower
5 Is land Trail Floor,
NJ Uniondale, New York 11556
Sparta,
(516)227-0615
Apartment Management Associates
2611 Wes t 2nd Street
Brooklyn, NY 11223
Trump Management, Inc.

2 611 West 2nd Street
Brooklyn, NY 112 23
COUNTY OF NASSAU
----------------------------x
LINDA C. TRUMP, MARY TRUMP, LISA
TRUMP and FRED C. TRUMP, III, individually and VERIFIED COMPLAINT

as parent and natural guardian of WILLIAM
TRUMP, an infant under the age of 18 years,
Index No. OO-co(a95

Plaintiffs,
$4 @Ò
- against -
DONALD J. TRUMP, ROBERT S. TRUMP and

MARYANNE TRUMP as Preliminary Co-
BARRY,
Executors of the Estate of FRED C. TRUMP,
deceased, APARTMENT MANAGEMENT

ASSOCIATES, INC., and TRUMP
MANAGEMENT, INC.,
Defendants.
---------------------------- x
Plaintiffs Linda C. Trump, Mary Trump, Lisa Trump and Fred C. Trump, III, individually
and as parent and William Trump, an infant, by their attorneys Farrell Fritz, P.C., as and for their
verified complaint against defendants, respectfully allege:
Preliminary Statement
1. This is an action for damages and injunctive relief for the wrongful termination of
medical benefits and coverage by defendants Donald J. Trump, Robert S. Trump and Maryanne
Trump Barry, individually and as preliminary co-executors of the Estate of Fred C. Trump
(collectively "Trump Defendants"). After decades of providing medical coverage for the
children of deceased Fred C. Trump, Jr., the Trump Defendants breached this longstanding
agreement by unilaterally cancelling medical coverage for plaintiffs, including William, a
9-month old child suffering from a debilitating illness. The Trump Defendants stopped
providing medical coverage and reimbursement for medical expenses incurred in retaliation for
plaintiffs' having commenced a will contest challenging the
Last Will and Testament of Fred C.
Trump. This was done with malice and an awareness of moun
ting medical expenses for infant
William. Thus, defendants, who regularly tout themselves
in the media as great philanthropists,
are more than willing to turn the back on the tiniest member
of their family in an attempt to bully
his father into fading into the night.
The Parti es
2. Plaintiff Linda C. Trump ("Linda") is an individual residing

in the County of
Queens, State ofNe w York.
3. Plaintiff Mary Trump ("Mary") is an individual residing in

the County of Nassau,
State of New York.
4. Plaintiff Fred C. Trump, III ("Fred III") is an individual resid

ing in Greenwich,
Connecticut.
5. Plaintiff William Trump ("William"), a minor, is the son of

Fred III, residing in
Greenwich, Connecticut.
6. Defendant Donald J. Trump is an individual residing at 721

Fifth Avenue, New
York, New York, and is now acting as preliminary co-executo
r of the Estate of Fred C. Trump.
7. Defendant Robe rtS. Trump is an individual residing at 167
E. 61" Street, New
York, New York, and is now acting as preliminary co-executo
r of the Estate of Fred C. Trump.
8. Defendant Maryanne Trump Barry is an individual residing
at 5 Island Trail,
Sparta, New Jersey, and is now acting as preliminary co-ex
ecutor of the Estate of Fred C. Trump.
9. Upon information and belief, defendant Apartment Manageme
nt Associates, Inc.
("Apartment Management") is a domestic corporation organ
ized under the laws of the State of
New York with a place of business at 2611 West 2nd Stree
t, Brooklyn, New York.
2
10. Upon infonnation and belief, the defendants Donald J. Trump,
Robe rtS. Trump,
Maryanne Trump Bany and other family members own all of the
outstanding shares and are
members of the Board of Directors of Apartment Management.
11. Upon infonnation and belief, defendant, Trump Management, Inc.,

is a domestic
corporation organized under the laws of the State of New York
with a place of business at
Brooklyn, New York.
Back groun d
12. Fred, ill and Mary are the children of Fred C. Trump, Jr. ("Fred
Jr."), the
predeceased son of Fred C. Trump, Sr. ("Fred Sr.").
13. Fred Jr. and Linda Trump were divorced in 1970. Fred Jr. died
in 1981.
14. In or around early 1991, defendants consulted a lawyer regarding
the preparation
of a new will for their father, Fred Sr.
15. The will, which was eventually signed by Fred Sr. in September
1991, virtua lly
disinherited Fred ill and Mary.
16. Upon infonnation and belief, at the time the will was executed,
Fred Sr. was
suffering from senile dementia and had significant memory impai
rment.
17. Upon infonnation and belief, Fred Sr.'s will is the product of undue
influence and
coercion by defendants upon Fred Sr., who clearly lacked the requis
ite mental capacity to make a
will.
18. On or about March 23, 2000, Fred ill and Mary filed Verified Objec
tions to the
probate of the will with the Queens County Surrogate's Court,
in a proceeding entitled Probate
Proceeding, Will ofFred C. Trump, Deceased, Index No. 3949-
99 (Surr. Ct. Queens County)
("Probate Proceeding").
3
19. For all of their lives, plaintiffs were provided medical coverage and/or
reimb ursem ent for medical expenses through one or more of the family
owned entities. Fred Sr.
and defendants, over the years, agreed, promised, represented, confir
med and stated to plainti ffs
that medic al coverage and reimbursement for medical expenses would
be provid ed to plainti ffs
and their children for life.
20. This promise or agreement to pay and reimburse the medical expen ses
was made
and intended to benefi t plaintiffs and their children, and was confirmed
and ratified by
defend ants throug h words and condu ct from I 993 to on or about March
2000.
21. Upon information and belief, Fred Sr. initially provided medic al insura
nce
covera ge for plaintiffs and defendants through Trump Management,
Inc., and thereafter by and
throug h defend ant Apartm ent Management.
22. In or around June I 970, Linda and her then-husband, Fred C. Trump
, Jr.
C'Fred Jr.") entere d into a Separation Agreement.
23. The Separation Agreement provided for a division of assets betwe en

Linda and
Fred Jr., and obligations to be undertaken by Fred Jr.
24. Upon information and belief, Fred Sr. provided assistance and legal
servic es to
Fred Jr. to assist Fred Jr. in the preparation of the Separation Agreement,
to ensure that Linda
was kept separa te and apart from the Trump family businesses.
25. Amon g Fred Jr.'s obligations contained in the Separation Agree ment
included the
promi se to pay and reimburse all medical and dental expenses for Linda
's childre n for Fred Jr.'s
life.
26. This promi se to pay and reimburse all medical and dental expenses
was further
guaran teed by Fred Sr. by a Guaranty dated June 9, 1970.
4
27. This promise to pay medical and dental expenses was in consideration for Linda's
continued disassociation from the Trump family business, which directly benefitted Fred Sr. and
defendants.
28. On or about September 26, 1981 Fred Jr. died.
29. Subsequent to the death of Fred Jr., Fred Sr. agreed to and continued to pay and
reimburse Linda and her children, Mary and Fred ill for medical expenses through various
Trump family businesses.
30. From on or about 1993 until the present, upon information and belief, Apartment
Management has performed said agreement by including plaintiffs on its Health Benefit Plan
under which plaintiffs have received full medical insurance coverage.
31. On June 30, 1999, William, was born.
32. William is seriously ill and requires extensive medical treatment and around the
clock nursing care, of which defendants are aware.
33. Because of the longstanding agreement and promise to provide medical insurance
coverage and reimbursement, Fred did not insure William through his employer, but, rather,
William was covered under the Trump family policy.
34. Pursuant to this insurance coverage, the appropriate care and around the clock
nursing services have been covered and reimbursed by and through Apartment Management.
35. These nurses are critical since, just recently at age 8 months, William needed
cardiopulmonary resuscitation during the night, which, if a nurse not been with him, he would
not have survived.
5
AS AND FOR A FIRST CAUSE OF ACTION
42. Plaintiffs ·repeat and reallege paragraphs "I" through "41" as though fully set forth
herein.
43. As a result of the aforesaid agreement and promise made by Fred Sr. and
defendants, plaintiffs had a contractual right to medical insurance coverage and reimbursement
for medical costs for life.
44. Defendants Donald J. Trump, Robert S. Trump and Maryanne Trump Barry knew
or should have known of the existence of the aforesaid agreement or promise and the plaintiffs'
rights thereunder.
45. · Defendants partially performed their obligation under the agreement by paying
and reimbursing plaintiffs for medical expenses incurred.
46. In retaliation for plaintiffs' contesting the Will of Fred Sr., defendants Donald J.
Trump, Robert S. Trump and Maryanne Trump Barry have caused Apartment Management to
terminate plaintiffs' eligibility to participate in and receive benefits under the Health Benefit Plan
effective May 1, 2000, thus breaching the parties' agreement
47. Defendants Donald J. Trump, RobertS. Trump and Maryanne Trump Barry
wrongfully, knowingly, intentionally, maliciously and without justification, induced Apartment
Management to breach the aforesaid agreement and deprive the plaintiffs of their rights under the
aforesaid agreement.
48. By reason of the foregoing, the plaintiffs have been irreparably harmed, and
defendants should be permanently enjoined to pay and reimburse the medical expenses of
plaintiff.
7
AS AND FOR A SECON D CAUSE OF ACTIO N
49. Plaintiffs repeat and reallege paragraphs "I" through "48" as though fully set forth
herein.
50. In or around 1970, Fred Sr. promised plaintiffs that he would pay all medical costs
for his family members, including plaintiffs, for life.
51. From on or about when the promise was made until on or about June 25, 1999,
consistent with the aforesaid promise, Fred Sr. did provide plaintiffs with medica
l coverage.
52. From on or about 1993 until the present, defendants have ratified, assumed and
performed the aforesaid promise by providing plaintiffs with medical insurance

coverage and
otherwise paying or reimbursing plaintiffs for healthcare costs.
53. Defendants, by words and conduct, represented, stated and assured plaintiffs that
medical coverage would be provided to them for life and affirmatively advised
plaintiffs not to
procure independent medical insurance coverage.
54. Defendants knew or should have known that plaintiffs would rely on the aforesa
id
promise which defendants have assumed.
55. In reasonable reliance upon the aforesaid promise to plaintiffs, plaintiffs were
caused over many years to refrain from obtaining their own private medical insuran
ce to their
detriment, which insurance would now be prohibitively expensive to obtain indepen
dently, it if
could be obtained at all.
56. Plaintiffs relied upon these promises and representations made by Fred Sr. and
defendants by not independently obtaining medical insurance coverage.
57. On or about March 30, 2000, with no prior notice, defendants advised plaintiffs
that effective May I, 2000, they were no longer entitled to benefits under the Health
Benefit Plan.
8
58. In retaliation for plaintiffs contesting the Will of Fred Sr., the defenda nts have
caused Apartme nt Management to terminate plaintiff s' eligibility to participate in and

receive
benefits under the Health Benefit Plan effective May 1, 2000.
59. By reason of the foregoing, plaintiffs have been and will continue to be
irreparably harmed and should be permanently enjoined to pay and reimburse the medical
expense s of plaintiff.
AS AND FOR A THIRD CAUSE OF ACTIO N
60. Plaintiffs repeat and reallege paragraphs "1" through "59" as though fully set forth
herein.
61. As a result of the aforesaid agreeme nt between Fred Sr. and Apartm ent
Manage ment to include the plaintiffs in the Health Benefit Plan, plaintiffs had a contract
ual right
to medical insurance for life.
62. Defenda nts Donald J. Trump, RobertS . Trump and Maryan ne Trump Barry knew
or should have know of the existence of the aforesaid agreement and plaintiff s' rights
thereunder.
63. In retaliation for plaintiffs contesting the Will of Fred Sr., defendants Donald J.
Trump, RobertS . Trump and Maryanne Trump Barry wrongfully, knowingly, intention
ally,
maliciou sly and without excuse or justifica tion did cause Apartment Manage ment to terminat
e
plaintiff s' eligibility to participate in and receive benefits under the Health Care Plan effective
May 1, 2000.
64. Defendants Donald J. Trump, RobertS . Trump and Maryan ne Trump Barry did
deliberately cause Apartm ent Management to terminate plaintiffs' eligibility to particip

ate in and
receive benefits under the Health Care Plan effective May 1, 2000, with the sole intent
and
purpose of injuring plaintiffs in retaliation for plaintiffs contesting the Will of Fred Sr.
9
,_
65. By reason of the foregoing, plaintiffs have been damaged to date in the amoun t
not less than $100,000, which damages continue to accrue each day.
WHER EFOR E, plaintiffs demand judgment against defendants as follows:
a. On the First and Second Causes of Action, that defendants are
permanently enjoined to continue to pay and reimburse medical expenses of plaintif

fs;
b. On the Third Cause of Action, for damages in an amount not less than
$100,000 to be determined at trial;
c. Granting plaintiffs such other and further relief as the Court may deem just
and appropriate, together with the costs and disbursements of this action.

April2 7, 2000
FARRELL FRITZ, P.C .
By:
. lk).
West Tower, 14th Floor
Uniondale, New York 11556
(516) 227-0700
FFDOCS1\275771.1
10
'
'
VERIFICATION
STATE OF NEW YORK )

) ss
COUNTY OF NASSAU )
I, Mary Trump, being duly sworn, depose and say:
I am a Plaintiff in the above entitled action. I have read the foregoing and know the
contents thereof; that the same is true of my own knowledge except as to matters therein stated
on information and belief and as to those matters I believe to be true.

27'h day of April, 2000.
FFDOCS1\275771.1
JAMES <M. WICIQl

NaiBry il'ublic. State of"New York
No. 31-4961418
.Qualified In N'ew York County
Certlllcate Aled In Nassau County
Commisslon Exolres Feb. 5, ::2&1•1.
11
Year:
Index No.

COUNTY OF NASSAU
LINDA C. TRUMP, MARY TRUMP, LISA TRUMP and FRED C. TRUMP, III,
individually and as parent and natural guardian of WILLIAM TRUMP, an infant under
the age of 18 years,
Plaintiffs,
-against-
DONALD J. TRUMP, ROBERT S. TRUMP and MARY ANNE TRUMP BARRY,

as Preliminary Co-Executors of the Estate of FRED C. TRUMP, decêasêd, and
APARTMENT MANAGEMENT ASSOCIATES, INC., and TRUMP MANAGEMENT, INC.,
Defendants.
SUMMONS AND VERIFIED COMPLAINT
FARRELL FRITZ, P.C.

Anorneys for Plainnfs
EAB PLAZA
UNIONDALE, NY 11556-0120
(516) 227.0700
This certification, pursuant to 22 N.Y.C.R.R. Part 130-1.1-a,
applies to the following papers contained within this back:
(1) Summons and Verifi Complaint
Dated: April 27, 2000 Signature:
Print Signer's am : James M. Wicks
FFDOCS11278269.1
EXHIBIT "Q"
OF NEW YORK
GATE'S COURT : COUNTY OF QUEENS
---------------------------------x
te Proceeding, Last Will and . VERIFIED
ment of OBJECTIONS TO PROBATE
Fred C. TRUMP, File No. 3949/99
Deceased.
---------------------------------X
The answer of FRED C. TRUMP, III and MARY TRUMP, persons
ested in the above entitled estate, as and for their objections
e probate of the purported Last Will and Testament of FRED C.
, dated September 18, 1991, respectfully shows to this Court, on
nation and belief:
L. The alleged Will, dated September 18, 1991, was not duly
:ed by FRED C. TRUMP; he did not publish the same as his Will in
resence of the witnesses whose names are subscribed thereto; he
St request the said witnesses to be witnesses thereto; and the
tileged witnesses did not sign as witnesses in his presence or
3 presence of each other.
18ª said
?. On the day of September, 1991, the decedent,
:. TRUMP, did not know the nature, extent or value of his assets,
is not of sound mind or memory and was not mentally capable of
[ a Will.
:. On information and belief the instrument offered for
.e is not the Last Will of the above-named decedent, but the
as executed by the said decedent by mistake in that he did not
tand the contents of the instrument offered for probate herein.

4. The purpor ted Will was not freely or volunt arily made or
execute d by the said FRED C. TRUMP, as his Last Will and Testam ent;
the said paper writing purpor ting to be his Will was obtaine d and the
subscr iption and public ation thereo f, if in fact subscr ibed and
publish ed by him, was procure d by fraud and undue influen ce practic ed
upon the decede nt by Petitio ners and/or by some other person s whose
names are at the presen t time unknow n to the Object ants.
5. Object ants demand a trial by jury of all issues raised
herein .
WHEREFORE, Respon dents FRED C. TRUMP, III and MARY TRUMP
pray that this procee ding be dismiss ed with costs.
Respec tfully submit ted,
Farrel l Fritz, P.C.

Attorne ys for Fred C. Trump, III
and Mary Trump
EAB Plaza, 14th Floor, West Tower
Uniond ale, New York 11556-0 120
(516). 227-070 0
2
VERIFICATION
STATE OF CONNECTICUT)
.. COUNTY OF Éd-t( f )
I, FRED C. TRUMP, III, being sworn, say: I am the Objectant
in the within action; I have read the foregoing objections and know
the contents thereof; the same is true to my own knowledge, except as
to those matters therein stated to be alleged on information and
belief, and as to those matters I believe it to be true.
Fred C. Tr p, III
RWday of /Wreb, 2000.
Notary Public
ROBERTA P. ANDERSON
My Commission Expires
June 30, 2004
VERIFICATION
STATE OF NEW YORK )

) ss:
COUNTY OF NASSAU )
I, MARY TRUMP, being sworn, say: I am the Objectant in the
within action; I have read the foregoing objections and know the
contents thereof; the same is true to my own knowledge, except as to
those matters therein stated to be alleged on information and belief,
and as to those matters I believe it to be true.
Mard rump

It day of r , 2000.
Ûn t
N tary Public
WAYNE ULRICH
Notary Public, State of New York
No.9411880
Qualifiedin Nassau County
Commission Expires Mamh30, 20 0
(
FFDOCS1\272016.1
4
EXHIBIT "R"
516 248 4785
1B/B3/20 00 1B:01 515-248- 4785 LAURINO AND LAURINO PAGE 04
r
LAURI NO & LAURI NO

ATTORNE YS AT lAW
229 SEVENTH STREET
GARDEN CITY, New YORK 11530
LOUIS o. LAURINO
LOUIS M. LAURINO TELEPHONE: (516) 241-4771
FAX: (516) 248-4785
October 2, 2000
Via Facsimil e: 227-077 7

Farrell Fritz
EABPia za
Uniondale, New York I 1556-0120
Attn: John J. Barnosky , Esq.
Re: fistate qj'Fred C. frump
Dear Jack:
In accordance with our agreement at the conference held with Surrogate Robert L.
Nahman, I have in my possession the following documents pertaining to the interest of the
objectants in the various partnership and corporations listed below.
I. Schedule of Ownership Interests.
2. 1999 Tax Returns for:

Park Briar Associates, LLC
Coronet Hall, Inc.
Highlander Hall, Inc.
Midland Associates, LLP
Lincoln Shore Apartments Partnership
3. 1999/1998 Audited Financial Statements:
Mary Trump Trust (1999 only)

Fred C. Trump Ill Trust (1999 only)
Coronet Hall Property
Wedgewood Hall Property
Highlander Hall, Inc.
Saxony Hall Property
516 248 4785
10/03/2000 10:01 516-248-4785 LAURINO AND LAURINO PAGE 05
Sunnyside Towers Property

Lincoln Shore Apartments
Midland and Park Briar will be forwarded when completed. I expect that
completion will be in about a week.
4, Co-op Apartment Information
5. Co-op recent sales.
6. Midland Schedule of Mortgagen/Note Receivable and Not Payable.
All of these represent far more that we agreed to furnish.
I expect to receive a copy for your review of the Federal Estate Tax Return (706)
that was filed in this estate.
Although it was not part of our discussion, I believe that we would like to have a
commitment from your office as to when we will receive the information that was requested
on August 1, 2000 pertaining to our First Demand for Discovery and Inspection.
I would like to delivery the material men6oned along with the tax return with a clear
understanding as to when we will get the material from your office before the meeting on
October 31, 2000.
I believe in all fairness that when we made this request these di= ions of possible
settlement were not being considered, however, I certainly think it would be to our
advantage to have in hand the requested material.
Please advise as quickly as possible so that I can deliver the material to your office.
Very y yours
Louis D. Laurino
LDL:cb
cc: By Facsimile: 718-520-5048
Surrogate's Court, Queens County

Hon. Robert L. Nahman
NOV. L 2000 5: 36 PM NO. 9660 P. 2/7
abA«n . Selwadz, 908.

edfilotneys as Îaw
3000 Åa'aus Assus
,£aÊa duca±ss, e..Near ¶mA no42-1066
(E16) 488-1200
2Mecopien(618)488-1238
November 1, 2000
VIA FAX (516) 227-0777
Jack Barnosky, Esq.
Re: Estate of Fred C. Trump
Dear Jack:
With regard to the basis of Midland, et al., we submit the following:
1. Midland LLC and Park Briar LLC - please refer to

Associates, Associates,
ending capital accounts as reflected on the K-1s attached to the 1065
partnership tax returns previously submitted.
2. Coronet Inc. and Highlmi-r Inc. (owned Park Briar

Hall, Hall, by
Associates in 1981):
Schedule F of the 706 of the Estate of Fred C. Trump, Jr - refer to

(a)
Item F-1 - Park Briar Associates - value $1,474,926.
Report of Audit Changes with regard to Item F-) - increase of

(b)
$131,497 of value.
(c) IRC § 754 worksheets apportioning Park Briar step-up adjustinent

of $1,997,860:
Coronet Hall, Inc. $785,758

Highlander Hall, Inc. $775,170
NOV. 1. 2000 5: 37PM NO. 9660 P. 3/7
Page 2
November 1, 2000
(d) These values represent outside basis to which should be added

allocable share of Accumulated Adjustment Accounts. See Forms
1120S previously submitted to you.
Very truly yours,
STEPHEN J. SCHWARTZ, P.C.
Stephen J. Schwartz
SJS/de
Enclosures
cc: Hon. Louis D. Laurino

(w/Enclosures
Via Fax No. 516-248-4785)
w. leplWS I ,ADM TRUMP.FRE\Bamoskyviafax JI-1.002nc

EXHIBIT "S"
\TE OF NEW YORK (PLEASE PRESS HARD)
OGATE'S COURT, COUNTY OF QUEENS
File No.
In the Matter of the
fug PftoctFsovg
at
STIPULATION
$9 C . ‰/h P
A/M/4 fy&K 4 /JT

fA.Eo
DATE Of
Deceased.
It is hereby stipulated and agreed the parties hereto as

by follows:
VCgh m pÁ® 6 dar O Ã06/ /O 60 ft, 862

27
SURR. CT (12/95) Page of-

EXHIBIT "T"
STATE OF NEW YORK
SURRO GATE'S COURT : COUNTY OF QUEENS
----- ----- ----- ----- ----- ---X
In the Matter of the Probate of the Last Will and VERIFIED
Testament of BILL OF PARTI CULAR S
FRED C. TRUMP, File No. 3949/99
Deceased.
----- ----- ----- ----- ----- ---X
Objectants, Fred C. Trump ill and Mary L. Trump, as and for their Bill of Particulars,
respectfully allege as follows:
1. The act or acts and course of conduct constituting fraud and undue influence
consisted of the following: Petitioners retained attorneys to draft codicils and a Will for deceden
t
and gave instructions to said attorneys without consulting decedent and without his knowled
ge or
consent; isolated decedent from members of his family; told the decedent that the Objectants
did
not care for him or his wife; pressured decedent to do a new Will benefitting Petitioners and
arranged for preparation and execution at a time when decedent was mentally and physically
weak; pressured decedent to sign the Will when Petitioners knew his mental state was such
that
he was unable to comprehend or retain any information regardipg the instruments.
2. The persons who perpetrated the fraud and undue influence practiced upon the
decedent are Donald A. Trump, RobertS . Trump, and Maryann Trump Barry.
3. Such fraud and undue influence took place continually from January 1991 until
the decedent's death, at the decedent's residence, the decedent's place of business, the
Petitioners' residences and the Hospital for Special Surgery.
4. It is not claimed that such acts were accompanied by an act of physical violence or
mistreatment of the decedent.
5. It is not claimed that there is an alleged testamentary instrument oflater date than
the instrument offered for probate.

6. It is not claimed that the instrument offered for probate was revoked.
7. It is claimed that the instrument offered for probate was not exeented in
accordance with the prescribed statutory formalities.

12
January , 2001
Yours, etc.,
FARRELL FRITZ, P.C.
ohn J. B osky
Attorneys for Objectants
EAB Plaza
West Tower, 14th Floor .
.. Uniondale, New York 11556-0120
(516) 227-0700
To: Louis D. Laurino, Esq.

Laurino & Laurino
229 Seventh Avenue
Garden City, NY 11530
Stephen J. Schwartz, P.C.
3000 Marcus Avenue

2
VERIFICATION
STATE OF NEW YORK )

) ss
COUNTY OF NASSAU )
I, FRED C. TRUMP, III, declare:
I am an Objantant in the above entitled action. I have read the foregoing and
know the contents thereof; that the same is true of my own Imewledge except as to matters
therein stated on information and belief and as to those matters I believe to be true.
I declare under penalty of perjury under the laws of the State of New York that
the foregoing is true and cottect.
Fred C. FffÍmp, III
/Rtt..day of January, 2001
NOTARY PUBLIC, STATE OF NEW YORIC

NO.414972543
QUAltFIED IN QUEENS COUNTY
CERTlFICATE FILED IN NEW YORKCQUNTY
COMMISSIONEXPlRES OGE1.C
FFDOCS1\311117.1
EXHIBIT "U"
GrubbsEllis
Appraisal & Consulting
Robert Von Ancken, MAl, CRE
Executive Managing Director
May 10, 1996
Mr. Robert S. Trump
Apartment Management Associates, Inc.

2611 West 2nd Street
Brooklyn, New York 11223
Re: Various Properties
Brooklyn, Queens and Staten Island
New York
Dear Mr. Trump;
In accordance with your request, we have prepared a limited-form. summary appraisal of various
apartment buildings and shopping centers owned by Fred C. Trump and others.
The portfolio of properties consists of 22 separate apartment buildings plus four multi-building
housing projects (Beach Haven, Grymes Hill, Shore Haven and Tysens Park) which are all
located in Brooklyn, Queens and Staten Island. In addition to the apartment buildings, there are
3 strip shopping centers located in Brooklyn (Beach Haven, Shore Haven and Trump Village), 3
retail properties net leased to fast-food operators, and 3 parcels of vacant land.
Our appraisal is a limited-form, summary appraisal that indicates all the necessary ingredients of
an appraisal, but with less descriptive material and more on the actual valuation. Supporting
documentation is in our files and is available for your review. This appraisal is made in
accordance with the criteria established by the Appraisal Institute and the State of New York, and
under the guidelines of the Departure Provisions of the Uniform Standards of Professional
Appraisal Practice (Standard Rule 2-2(b)).
We have included a discussion of the apartment building market in the outer boroughs of New
York City. We have also included a brief description of the neighborhood surrounding each
property, zoning, assessed value, and highest and best use of each property, and a brief building
description. Each property was fully inspected by the appraisers.
Grubb & Elbs Appraisal & Consuinne

A Dwimon of Grubb & Elbs New York, Inc.
Delmomco Pla-a. is Eat 59th Streer. New York, NY 10022
(212) 759-9700 Fax (2 12) 126-4789
GrubhcrEllis
Mr. RobertS. Trump

May 10, 1996
Page 2
Our valuation is based entirely on the indications from the income capitalization approach, using
direct capitalization. For the valuation of Trump Village Section I and Section II, we used yield
capitalization. We reviewed historical income and expenses in order to project a stabilized
income and expense as of the valuation date. A present value deduction for major capital
expenditures was made to our capitalized value to keep the properties competitive. A present
value addition for any remaining J-51 tax abatements was made to our capitalized value.
Our selected overall capitalization rate considers rates of return for older rent stabilized
apartment buildings located in Brooklyn and Queens, and takes into consideration each
properties' location, physical condition and rent structure. Our rate also considers future tax
abatements under the J-51 program for work already completed as of the effective date of value,
as well as necessary work to be completed.
In support of the income capitalization approach, we used the sales comparison approach where
we analyzed numerous apartment building and shopping center sales in Brooklyn and Queens.
We utilized the price per apartment, price per room and gross income multiplier as the units of
compar1son.
Our valuation gauges the impact of lead paint on each of the apartment buildings as dictated by
current laws. We also consider the impact on value from asbestos which has not been removed
from certain apartment buildings and the shopping centers.
The interest being appraised is the fee simple estate, subject to rent stabilized apartment leases,
i.e., in other words a leased fee estate. For Beach Haven Apartments, Shore Haven Apartments
and Tysens Park Apartments, the interest being appraised is the fee simple estate subject to a
long-term ground lease or the leasehold interest. The effective date of appraisal is September 1,
1995.
Our valuations are subject to the basic assumptions and limiting conditions, certifications, and
definitions set forth in the attached limited-form, summary appraisal.
Based on the analyses contained in the attached limited-form, summary appraisal, and our
experience as real estate appraisers and consultants, it is our opinion that the market value of
various properties owned by Fred C. Trump and others, in cash or equivalent terms, as of the
effective date of value, September 1, 1995, is as follows:
Grubbc:rE
Appraisal
llis
Consulting
&
Mr. RobertS. Trump

May 10, 1996
Page 4
Our limited-form, summary appraisal stating our findings is attached.
Very truly yours,

NYS Certification No. 46000001797
Stephan J. Gianop1us, MAl

Senior Director
:\TRUMP95\repon. doc
GrubberEllis
CERTIFICATE OF APPRAISAL
Premises: Various Properties in Brooklyn,

Queens and Staten Island
I, Robert Von Ancken, certifY to the best of my knowledge and belief:
THAT the statements of fact contained in this report are true and correct;
THAT the reported analyses, opinions, and conclusions are limited only to the reported
assumptions and limiting conditions, and are my personal, unbiased professional analyses,
opinions, and conclusions;
THAT I have no present or prospective interest in the property that is the subject of his report, and I
have no personal interest or bias with respect to the parties involved:
THAT my compensation is not contingent on an action or event resulting from the analyses,
opinions, or conclusions in, or the use of, this report;
THAT the reported analyses, opinions, and conclusions were developed, and this report has been
prepared, in conformity with the requirements of the Code of Professional Ethics and the Standards
of Professional Appraisal Practice of the Appraisal Institute;
THAT the use of this report is subject to the requirements of the Appraisal Institute relating to
review by its duly authorized representatives;
THAT I have completed the requirements of the continuing education program of the Appraisal
Institute;
THAT as of the date of this report, I am currently certified under the voluntary continuing
education program of the Appraisal Institute;
THAT I have made a personal inspection of the property that is the subject of this report;
DATE: May 10, 1996

NYS Certification #4600000 1797
\sg Various Properties in Brooklyn, Queens & Staten Island, NY 93

GrubboEllis
Premises: Various Properties in Brooklyn,
Queens and Staten Island
I, Stephan J. Gianoplus, certify to the best of my knowledge and belief:
assumptions and limiting conditions, and are my personal, unbiased professional analyses,
opinions, and conclusions;
THAT I have no present or prospective interest in the property that is the subject of his report, and I
have no personal interest or bias with respect to the parties involved:
THAT my compensation is not contingent on an action or event resulting from the analyses,
opinions, or conclusions in, or the use of, this report;
prepared, in conformity with the requirements of the Code of Professional Ethics and the Standards
of Professional Appraisal Practice of the Appraisal Institute;
THAT I have completed the requirements of the continuing education program of the Appraisal
Institute;
DATE: May 10, 1996
Stephan J. Gianoplus, MAI

NYS Certification #46000008918
5 1sg Various Properties in Brooklyn, Queens & Staten Island, NY 94

I LANDAUER
I
REALTY GROUP , INC.
55 East 59th Street, 1Oth Floor A GRUBB & ELLIS COMPANY

Direct (212) 759-9700
FAX 12121 326-4865
I
I
I May 18,200 0
The Estate of Fred C. Trump

c/o Apartm ent Management Associates, Inc.
c/o Robert S. Trump
2611 West 2nd Street
I Brooklyn, New York 11223
Re: The Estate of Fred C. Trump
Dear Mr. Trump:
In accordance with your request, we have prepared a limited appraisal, present

ed in a summary
format, of 11 properties owned by the above noted Estate. The purpose of these
appraisals is to
I estimate the market value of the interest in each property held by Mr. Fred Trump
1999.
as of June 25,
l The properties consist of seven separate apartment complexes, two strip

shopping centers, a
parcel of a vacant land and a personal residence. The properties are located in
Brooklyn, Queens
and Staten Island, in the City and State of New York.
I Our appraisals are limited, presented in summary format that indicate
all the necessary
ingredients of a complete appraisal, but with less descriptive material and
more on the actual
valuation. Supporting documentation is kept in our files and is available for
your review upon
request. These appraisals were performed in accordance with the criteria
established by the
Appraisal Institute and the State of New York, and under the guidelines
of the Departure
Provisions of the Uniform Standards of Professional Appraisal Practice (Standa
rd Rule 2-2(b)).
Our valuations are subject to the basic assumptions and limiting conditions,
certifications, and
definitions set forth and attached to this repot.
We have included a discussion of the apartment building market in the outer

boroughs of New
York City. We have also included a brief description of the neighborhood
s surrounding each
property, zoning, assessed value, and highest and best use of each property,
and a brief building
description for each complex. We have also inspected all of the subject propert
ies.
I
I May 18,2000
c/o RobertS. Trump
I page- 2-
I Except for the land and personal residence, our valuation is based entirely on the indications
from the income capitalization approach, using the direct capitalization method. We reviewed
I historical income and expenses in order to project stabilized income and expenses as of the
valuation date. A present value deduction for major capital expenditures was made to our
capitalized value to keep the properties competitive. A present value addition for any remaining
I J-51 tax abatements was made to our capitalized values. The valuation of the vacant land and
personal residence relied on the sales comparison approach, which emulates purchasers' behavior
when buying these types of properties.
I Our selected overall capitalization rates consider rates of return for older rent stabilized
apartment buildings located in Brooklyn, Queens and Staten Island, and takes into consideration
each property's location, physical condition and rent structure. Our rate also considers future tax
abatements under the J-51 program for work to be completed.
In support of the income capitalization approach, we used the sales comparison approach where
we analyzed numerous apartment building and shopping center sales in Brooklyn and Queens.
I We utilized the price per apartment, price per room and gross income multiplier as the units of
comparison.
I Our valuation gauges the impact of lead paint on each of the apartment buildings as dictated by
current laws. We also consider the impact on value from asbestos containing materials (ACM),
which has not been removed from certain apartment buildings.
I The interest being appraised is the fee simple estate, subject to rent stabilized apartment leases or
commercial store leases, i.e., in other words a leased fee estate.
I Based on the analyses contained in the attached limited appraisals, and our experience as real
estate appraisers and consultants, it is our opinion that the market value of the subject properties,
in cash or equivalent terms, as of the effective date of value, June 25, 1999, is as follows:
May 18, 2000
c/o Robert S Trump
page - 2 -
PROPERTY VALUE PROPERTY VALUE

Chelsea Hall $3,490,000 Ocean Terrace Apartments $1,740,000
25th
8700 Avenue 2650 Ocean Parkway,
Brooklyn, New York Brooklyn, New York
Fontaine Bleau Apartments $5,960,000 Shore Haven Shopping Center $1,330,000
8855 Bay Parkway 2002-2024 Cropsey Avenue
Brooklyn, New York Brooklyn, New York
Lawrence Towers $6,990,000 Beach Haven Shopping Center $2,530,000

3280-3310 Nostrand Avenue 589-611 Avenue Z
Brooklyn, New York 2568-2574 West 2nd Street
Brooklyn, New York
Wilshire Hall $7,160,000 Personal Residence $830,000

182-30 Wexford Terrace 85-14 Midland Parkway
Jamaica, New York Jamaica Estates, New York
Tysens Park Apartments $8,040,000 Vacant Land $1,800,000
Tysens Lane, Mill Road and Surf Avenue and West 17
Ebbits Avenue Avenue
Staten Island, New York Brooklyn, New York
Sea Isle Apartments $2,110,000
3901-02 Nostrand Avenue
Brooklyn, New York
This appraisal report was prepared by Robert Von Ancken, MAI, CRE, New York State Certified
General Real Estate Appraiser #46000001797, and Ghassan E. Kachouh, New York State
Certified General Real Estate Appraiser #4600000717. Our limited summary appraisal stating
our findings is attached.
Respectfully submitted,
Robert Von Ancken, MAI, CRE

gk:\fred trump 2000.doc

LA ND AU ER
REAL TY GRO UP, INC.
A GRUBB & ELLIS COMPA NY
I, Robert Von Ancken, certify to the best of my knowledge and belief:

t;
THAT the statements of fact contained in this report are true and correc
only to the reported
THAT the reported analyses, opinions, and conclusions are limited unbiased professional
and
assumptions and limiting conditions, and are my personal, impartial
analyses, opinions, and conclusions;
the subject of his report,
THAT I have no present or prospective interest in the property that is is the subject of this
the proper ty that
and I have no personal interest or bias with respect to
report or the parties involved:
contingent upon 1) the
THAT my compensation for completing this assignment is not
that favors the cause of
development or reporting of a predetermined value or direction in value
ted result;, 4) or the
the client; 2) the amount of the value opinion; 3) the attainment of a stipula
this appraisal;
occurrence of a subsequent event directly related to the intended use of
and this report has been
THAT the reported analyses, opinions, and conclusions were developed,
of Profes sional Ethics and the
prepared, in conformity with the requirements of the Code
Standards of Professional Appraisal Practice of the Appraisal Institute;
isal Institute relating to
THAT the use of this report is subject to the requirements of the Appra
the voluntary continuing
THAT as of the date of this report, I am currently certified under
t of this report;
THAT I have made a personal inspection of the property that is the subjec
gathering of information,
THAT in the preparation of this appraisal report others assisted in the
than Ghassan Kachouh
comparable sales, inspection of the property, etc. However, no one other
ning the value of the
and the undersigned prepared the analyses, conclusions and opinions concer
real estate set forth in this appraisal report.
Date: May 18, 2000

NYS Certification# 46000001797
87
\gk Estate of Fred C. Trump
LANDAUER
R E A LTY G R O UP, IN C.
A GR UB B & ELLIS CO M P AN Y
Re: Fred C. Trump
I, Ghassan Kachonh, certify to the best of my knowledge and belief:
assumptions and limiting conditions, and are my personal, impartial and unbiased professional
analyses, opinions, and conclusions;
THAT I have no present or prospective interest in the property that is the subject of his report,
and I have no personal interest or bias with respect to the property that is the subject of this
report or the parties involved:
THAT my compensation for completing this assignment is not contingent upon 1) the
development or reporting of a predetermined value or direction in value that favors the cause of
the client; 2) the amount of the value opinion; 3) the attainment of a stipulated result;, 4) or the
occurrence of a subsequent event directly related to the intended use of this appraisal;
prepared, in conformity with the requirements of the Code of Professionni Ethics and the
Standards of Professional Appraisal Practice of the Appraisal Institute;
THAT in the preparation of this appraisal report others assisted in the gathering of information,
comparable sales, inspection of the property, etc. However, no one other than Robert Von
Ancken and the undersigned prepared the analyses, conclusions and opinions concerning the
value of the real estate set forth in this appraisal report,
Date: May 18, 2000
Ghassan Kachouh
Managing Director
NYS Certification # 4600000717
\gh Estate of Fred C. Trump

EXHIBIT ''V''
101 Poor Farm Road
P.O. Box 611
Princeton, NJ 08542
(609) 924-4200
M AN AG EME N T (609) 924-4573 FAX
PLANNING, INC. www.mpival.com
Celebrating 60 Years
of Valuation Results
November 18, 1999
Stephen J. Schwartz, CPA

M.R. Weiser & Co. LLP
3000 Marcus Avenue
Lake Success, New York 11042-1066
Dear Mr. Schwartz:
We are pleased to submit herewith our financial analysis and evaluation, as of November 22,
1995, of the equity interests in twelve real estate holding companies transferred by Fred C.
Trump. This evaluation was prepared for gift tax filing purposes.
We wish to express our appreciation to you for your cooperation in making available to us
fiñancial data and other pertinent information necessary to the preparation of this study.
Very respectfully yours,
MANAGEMENT PLANNING, INC.
By
Robert P. Oliver, ASA
President
By
Troy . ngham
Valuation Analyst
bf
101 Poor Farm Road
RO. Box 611
IMP Princeton, NJ 08542
(609) 924-4200
MAN AGEMENT (609) 924-4573 FAX
PLANNING, INC. www.mpival.com
Celebrating 60 Years
of Valuation Results
September 19, 2000
Stephen J. Schwartz, CPA

M.R. Weisen & Co. LLP
3000 Marcus Avenue
Lake Success, New York 11042-1066
Dear Mr. Schwartz:
We are pleased to submit herewith our financial analysis and evaluation of the equity interests
in nine real estate holding companies owned by the Estate of Fred C. Trump as of June 25,
1999. Our opinion is being expressed for estate tax purposes.
We wish to express our appreciation to you for your cooperation in making available to us
fin=rial data and other pertinent information to the preparation of this study.
secessary
Very respectfully yours,
MANAGEMENT PLANNING, INC.
By
Robert P. Oliver, AM
President
By
Troy . In am
Valuation Analyst
bf
Valuation Advisors Since 1939

EXHIBIT "W"
kow.sys ab Îaur
3000 cAllaraus divenus
_fafs c:Success, cNear ¶o,£ 1:o42-1o66
(516) 488-1200
%lecopier (516) 488-1238
December 7, 2000
VIA FAX (516) 227-0777
Jack Barnosky, Esq.
Dear Jack:
This will confirm the conference scheduled for December 18, 2000 at 9:30 a.m. at
the Supreme Court Building, Mineola, New York, with regard to the medical insurance
coverage matter. We trust that this conference will be concluded in the a.m. and that we
can then meet at my office in the p.m. to review the financial information which you will
be submitting to us.
This letter will also confirm receipt of your voice mail message with regard to
your associate Tricia calling me for information concerning the Estate Tax Retum, Form
706. I have not yet heard from her and would appreciate it if she could fax to me her
requests, because, as you are aware, I am presently unable to write. If she could possibly
furnish me with her requests by December 8, 2000, I will try to get back to her as soon as
possible so that you can submit to me your computations by the scheduled December
1lth date. I will then be able to review them before our meeting on the 18d'.
If you have any questions, please call me.
Very truly yours,
Stephen J. Schwartz
SJS/de

(Via Fax 516-248-4785)
W:\Legal\EST.ADM\TRUMP.FRE\Bamosky via fax 12.7,00.doc
. .
FARRELLFRIT2
PRoFESSIONAL CORPORAUCN
EAB PLAZA
(516) 227-0700
FACSIMU.E: (516) 227-0777
M.AAMENTAND TKo½MtAKELEEN JO)lND.CAliMMElelt
HD A B Mj[ogs WRrrER'S DIRECT DIAL NUMBER
JQIDIF.
CLEARY JDRN
R.MoRJCEN
ROBERTC.CRE1GHTON ROBEELT
E 5ANDr.EL
E"ob'EÏat.a. ^"°""caAntah'Toi (516) 227-0611
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JAMBS IGNATANI. *
-KAPEN L KEMPRANNON
M(CHAILL IIEALY
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EUWAGER
KENNETH AUERBACH WK1ErSL hEYER

ANDREW 1.COHEN JENNiFER
M.MONE
*^=atr·c= =uo=or December 8 2000
ANDREW L.CRABTREE DAWND.QU.JVlBRE
CHRISTOP112it
P.DALY ERIC
W.PENZER
SALLY M.·DONAHUE - BRUCEN.ROBERTE
GREGORY C.FORNASAR EAINER.SAMMON
10ENEfETH
S.HORWrit E VZU.,ANZ
1.viaC.MAER. MARIE
1WEG
INANBK
13157-100
BY FACSIMILE
(516) 488-1238
Stephen J. Schwartz, Esq.

3000 Marcus Avenue
Lake Success, NY 11042-1066
Dear Mr. Schwartz:
In accordance with your letter of December 7, I am writing with respect to the questions
we have in connection with the above-captioned estate. From a review of the 1995 Gift Tax
Returns, I noted that Mr. Trump had retained a 50% interest in the corporations which were the
subject of the 1995 gifts. However, I do not see ussex Hall, Inc., Wexford Hall, Inc., Trump
Village Construction Corp., Beech Haven Apartments No. 1, Inc., or Shore Haven Apartments
No. 1, Inc. reported on the Form 706. Also, I do not see a transfer of these assets on a gift tax
return subsequent to the 1995 gifts. Could you please let me know how these interests were
disposed of.
It would be helpful if you could provide me with a copy of the Greyston & Co. appraisals
of Sinclair Farms LLC, Ocean Air Investors LLC, and Oakdale Investors LLC, as well as the
appraisals of Mr. Trump's 27% partnership interest in 220 Prospect Street Company and his
9.72% partnership interest in Starret City. These appraisals were not attached to the 706 exhibits
which we received.
Finally, it would be most helpful if you could provide-me with a copy of the IRS
computation for the GRAT remainder after audit. Although we are in possession of the line
adjustments, we do not have the IRS remainder computation.

December 8, 2000
Page 2
Please let me know if you need any clarification with respect to my rag2ase. Thank you.
Sincerely,
Patricia C. Marcin
PCM/10
FFDOCS1U10086-1
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3000 e/Mazaas c4venus

la$s Euccess, cNew ¶o,£ 11o42-1o66
(516) 488-1200
1klecopier: (516) 488-1238
December 8, 2000
VIA FAX (516) 227-0777
Ms. Patricia C. Marcin

Farrell Fritz, P.C.
14th
EAB Plaza, F100r
Uniondale, NY 11556-0120
Dear Ms. Marcin:
In response to your letter of December 8, 2000 with regard to your questions in

connection with the above-captioned estate, we submit the following:
1. Immediately prior to Mr. Trump's funding of his Retained Annuity Trust #1

on November 22, 1995, he gifted to his wife, Mary Trump, a 50% interest in
each of the following corporations: Sussex Hall, Inc., Wexford Hall, Inc.,
Trump Village Construction Corp., Beech Haven Apartments No. 1, Inc. and
Share Haven Apartments No. 1, Inc. Mrs. Trump also established a Retained
Annuity Trust #1 and these interests were part of the principal of her trust. I
direct your attention to Mr. Trump's 1995 Form 709, Schedule A, Part 3, Line
4, with regard to the gift-splitting concerning Mrs. Trump's GRAT.
2. I am enclosing a letter of Greystone& Co. with regard to valuations of Ocean
Air, Oakdale and Sinclair.
3. 220 Prospect Street Company was valued at ten (10) times the average cash
distributions for the years 1996, 1997 and 1998.
4. Starrett City was valued at a nominal amount based on information obtained

from management.
5. I am enclosing a copy of the IRS computation for the GRAT gift after audit in
the amount of $18,239,794.16. This amount agrees with IRS worksheet 3 of
15 which was attached to Form 706.
Ms. Patricia C. Marcin
Page 2
December 8, 2000
If you have any further questions, please contact the undersigned.
Very truly yours,
Stephen J. chwartz
SJS/de
Encls.
cc w/Encls.: Hon. Louis D. Laurino

(via fax 516-248-4785)
W:\Legal\EST.ADM\TRUMP.FP1 Mamin.Patricia (viafax) 12.8.00.doc

foÂe r.Sueasaa e.New ¶od 11O4s-1o66
(516) 488-1200
2klecopier (516) 488-1238
December 12, 2000
VIA FAX (516) 227-0777
Jack Barnosky, Esq.
Dear Jack:
It is now 4:00 p.m. on December 12, 2000. By agreement reached before

Surrogate Nahman you were to forward to me certain supporting financial information by
18"'
December 11 so that I would be able to prepare for our meeting on the of this
month. I have not received said information having only received a faxed letter from
Patricia Marcin, Esq. of your office, dated December 8, which was responded to on that
date.
Would you please advise me when I can expect to receive the information so that
we can prepare for a productive meeting on the 18d'.
Very truly yours,
tephen J. Schwartz
SJS/de

(Via Fax 516-248-4785)
cc: Dennis Hasher

(Via Fax 718-891-3609)
via fax 12.12.00.doc

W: Legal\EST.ADM\TRUMP,FRE\Barnosky
. . . __.-- - . ._ -
FARRELLFRITZ
PROFESSIONALcORPORATION
BAB PLAZA
Uniondale, New York I1556-0120
(516) 227-0700
FACSDea (516) 227-0777
JOHN
M.ARMENrANO 1HOMASLlEL1Dr JOttND.CaEMMENiR
JOHNJ.BARNOsKY MUCN.FJUMER 1928-1982
TBDA,BERKOWHz F.hELORE
STBPHEN WRR'ER'SDIRECT DIAL NU)GER FRANKAFRTrl.JR.
JOHN
P.CL1iARY JOHNLMORICEN 1924-1982
ROBERTC'
CREIGHTON ROBERTE.SANDLER
PETERLCL¶LRY J.3D40NS
ANDREW COUNSEL
asonames -asrR^m (516) 227-0730 ass,-
ARTHURK. RILDMAN A.XATIERENtch0.INSON
jbamosk., n -
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JAMESF,DEVARSO
cotonssrRmant Louisviolos WOMASJ,DORAN
ROBERTV.00100 JAMESM WJCK$ ."wm,_Ayr. EZOR
ALCNY.RAFEN J.KEMPNANNON
MICRAELJ.HEALY
PA1RICIAC.MA1 N
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rmera^uEa=ACN waurssmEvER December 13, 2000

ANDREW LCOMEN JENNIFERM.MONE
PATRICK
T.COLMNE MARIANNENONROY
ANDREW L CRABTREE DAW142.01.LIVIER3tE
OlklSTOPHERP.DALY ER3C
W.PEN2ER
SAIJ.YhLDONAHUB ERUCEN.ROB11E15
GR1lGORYC.FORNASAA ELAINR)LSAILD€0N
AND)ONYS.GUARDDIO L15ARVACCARO OURFIIENOMBER
xemaras.uonowrrz wRuum.maa 13157-100
LYLEC.MAHI.$A MARE3WEG
DTANEK.MENDE
Stephen J. Schwattz, Esq.
3000 Marcus Avenue
Dear Steve:
I am enclosing our calculations herein. Sorry for the delay. I did not get your letter
responding to our request until Monday.
The calculations assume intestacy using the assets which Fred would have had on hand
without any transfers to Mary, but assuming an intestate s smg to Additionally, we
have assumed that our clients would have been incl in the GRAT.
We calculate that the amount that we would rec we were totally victorious in this
regard is approximately $13,400,000. Against that, we applied our estimate of probability of
success and, thus, the demand figures that we went over in Court.
I look forward to seeing you next Monday.
V yours,
J J. Barnosky
JJB:mch
Enc1.
cc: Louis Vlahos, Esq.
FFDOCS1\310866.1
DEC. 14. 2000 5i :
i 6 AM NO. 029 1 P. 2/2
3000 d‰uu.s coŸesau

..La$s suesses, cr‰ Q_asÂ 11042-1066
(81m 488-1200
2Mecopter.•(516)488-1238
December 14, 2000
VIA FAX (516) 227-0777
Jack Barnosky, Esq.
Dear Jack:
13"'
I received your letter of December and attached calculations. I have
questions with regard to your computations of the amount available for distribution to
issue and would like to discuss these further at our meeting on December 18'h. However,
I see no basis at all for adding back a 20% remainder value of the GRAT since, in your
letter, you state that the calculations are based on intestacy without any transfers. Thus,
there would be no GRAT.
In addition I see no computation for the valuation of Midland, et al. When might
I expect same?
Very truly yours,
Stephen J. S wartz
SJS/de

(Via Fax 516-248-4785)
cc: Dennis Hasher

(Via Fax 718-891-3609)
D EC. 2 2. 2000 5 : 23 PM NO. 0 4 65 P. 2
FARRELLFRTfZ
PROFESSIONALCORPORATION
EABPLAZA
( )niondale, New York 11556·-0120
(516) 227-0700
PAesbes: (516) 227-4777
m A mangoust srmapir, uneas WRITER'S DINicT DIAl. NOMBER remetA.rarrea

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December 22, 2000

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DieNtK MENDEE
BY FACSIMILE
(516) 488-1238
3000 Marcus Avenue

Re: Estate of Fal C. Trump
Dear Steve
I have revised the tax scenario in intestacy to reflect the reduction of the intestate estate
by the discounted values (as per the 706) of the IlC's purchased back from the GRAT with the
annuity payments, as you pointed out at our meeting on Mcñday. Please note that while the
distribution obstis based on the assets without discounts, the estate tax calculation should be
computed listing discounted values. For tax calculation pmposes, this results in a reduction of
the gross estate by $7,487,747, rather than $17 million. We are still coming up with $8.3 million
as*the 20% share to my clients under this scenario. I believe your calculations did not calculate
the tax on discounted values as to the assets on hand, which is unrealistic.
Please let me know if you agree with the enclosed.
Very yours,
J L Bamosky
JJB:mch
Encl.
cc: Pred C. Trump. Ill (w/enclosure)
Louis D. Laurino, Esq. (w/enclosure)
FFDOCS1912095.1 .
12/28/2000 14: 14 516-248-4785 LAURINO AND LAURINO PAGE 01
LAURINO & LAURINO

ATTORNEYS AT LAW
229 SEVENTH STREET
GARDEN CITY, NEW YORK 11530
LOUlS D. LAURINO TELE PHONE: (516) 248-4771
LOUIS M. LAURINO FAX: (S16) 248.4785
December 28, 2000
Via Facsimile: 516-227-0777

Farrell Fritz
EAB Plaza
Uniondale, NY I 1556
Attn: John Barnosky, Esq.
RE: The Estate of Fred C. Trump
Dear Jack:
In response to your letter of December 22, 2000, I have been asked to advise you
that we disagree with the cantentions of your letter and the enclosure.
We engaged in an exercise to arrive at a common meeting ground at the request

of Surrogate Nahman - we believe that we arrived at that compromise when we conferred
at the offices of Stephen J. Schwartz on Monday, December 18, 2000. We corrected your
"revised"
calculations and ran the numbers again after correcting erroneous positions and
duplications apparent in your "revision".
In consideration of intestacy, you insist on rûixing apples and oranges. This is not
the first time you have taken inconsistent positions, in fact, I would say illogical positions
for the sole purpose of arriving at higher numbers without merit.
We look forward to our scheduled conference on January 8, 2001 and putting

forth again one sound position which is still open - but not for much longer.
..-----..
Ve tÓly yours,
Louis D. Laurino
LDL:cb
cc: Via Facsimile:
Stephen J. Schwartz, Esq. 5 16-488-1238 (
Dennis Hasher, Esq. 1-718-891-3609

1- 2 9 - O 1 ; 3 : 4 4 PM ; F a r r e I I Fr It z ; 5 16 2 2 7 O7 7 7 # 2/ 2
FARRELLFRTfZ
PROPESSIONALCORPORATION
EAB PLAZA
Uniond ale, New York 11556-0120
(516) 227-0700
FACSIMILE: (516) 227-0777
JOHNM.ARMENrAND ALONY.KAPEN JOHND.CAEAGdERER
JOHNJ.BARNDSRY IOEEEN
'GIDMASJ. 1928-1982
TEDA.BERKOWTfZ ERICM.KRAMER WRITER'S DIRECT DIAL NUMBER FRANKA.FRFF2,
JR.
JOHNP.CLEARY rn!PHENF.MELORE 1924-1982
RDBliRTC.CRIDONTON JOHNLMDRKEN
PETERL CURRY ROBERTE.SANDLElk COUNSHL
SPECIAL
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ROBERT
V.GUIDO JAMES
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COUNSEL
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JAMER F.DEVARSO
SALLYM.DONAHUE
ANDREW 3.CDHEN JENNIFER
M.MONE 'JH0MASJ.DORAN
-r.Coane -uaNRoy January 26, 2001 R»aTHANtsoR
ANDREW L CRABTREE DAWN D.OLLlVIERRE ANTHONY fi.GUARD1NO
CHRISTOPHERP.DALY ERICW.PENZER MICHAEL J..HEALY
FIEVB4N.DAVI BRUCEN. RDBERTS PATRICIAC.MARCIN
OREQ0RY C.FORNASAR EAINER.EAMMON M3R1AME.VILLANF
KENNETH S.HOROWIIZ NEll.YS1UfLAND
SEGIW,KRAS1LOV5KY LISAM.VACCARO
LYLEC.MAHLER MARIE2WEIO OURPILENUMBER
"'""8 8 "I"E" 13157-100
BY FACSIMILE
(516) 488-1238

3000 Marcus Avenue
Dear Steve:
This letter will confinn last evening's telephone conversation concerning possible
settlement. I am authorized by my clients to settle the probate litigation for a sum of $2,000,000
total for my clients, plus a buy out of their partnership interests at the $3,400,000 level previously
disc=ssd, as well as collapse (or perhaps merely changing the Trustees) of their existing Trusts,
plus a distribution from the partnerships for year 2000 concomitant with case flow.
I will be back in the office next Thursday and would appreciate a respcase.
Very truly yours,
ohn J. Barnosky
JJB:jg
ce: Louis D. Laurino, Esq. (via facsimile)
2- 9-O1; 2:33PM;Farrel I Fritz ;5102270777 # 2/ 3
FARRELLFRITZ
PROFESSIONALCORPORATION
EAB PLAZA
(5I6) 227-0700
FACSIMRE: (516) 227-0777
20MM. ARNEPTTANO AMRIY.KREN JOHND.CAEMAGEu!R
JOHNJ.BARNOSKY THDMAS J.KILUEEN 1928-1982
TEDA.BERKOWTTZ ENC14KRAMER WRITER'S DIRECT DIALNUMBER BANKA.FRTT2pR.
. JOHNP.CLEARY STEPHEN F.MELORE 1924.1982
RDBERT C.CREIGHTON JOHN R>MORKEN
PEIERLCURRY ROBERT E.SANOLER SPECIAL
COUNSEL
oEoRaEJ.FARRELMR. CHARLES E SUNN (516) 227-0730 J.xEuPNANNON
ARTHUR K.FELDMAN A.KAELEENTDMlJNSON c_ rm_., ANDREWJ.SIMONS
noloAsSPREoaJCu touis vs.AnoS jbarnosky@-iTsuanz.com EuWAcER
ROBERTV.GUIDD JAMES K WICK5
couNseL
KENNERI AUERBACH
.....___.._ __ ILENES.COOPElt
JAMES F.DEVAlUIO
SALLYM. DONAHUE
ANDREW L COIEN JENNIFER
M.MDNE THOMAS J.DORAN
x-snocKT.cOLuNs
ANDREW L.CRABTREE
-uoNRm
DAWN D.OLL1VEERRE February 9, 2001 ou^m^NL
ANTHONY
=
5,GUARDIND
C:HRISTOPHER F.DALY ERICW.PENZER MICHAEL L HEALY
STEVEN N.DAVI BRUCEN.RDBERTS PATRICtA C.MARC1N
GREGORY C.FORNASAR ELAINER.
SAMMON M1RIAM P.VILLANI
KENNETH S.HOROW1TZ NELLYSIUTIAND
SETH W.ERASELOVSKY LtSAM.VACCARO
LYF.EC. MAHEJ!R MARIBZWEIO OUEFELE
NUMBER
*"·¹""S·M"E"
13157-100
VIA FACSIMILE
Louis D. Laurino, Esq.

Laurino & Laurino
229 Seventh St., Ste. 201

3000 Marcus Avenue
Re: Estate of Fred C. Tnunp
Dear Lou and Steve:
At Lou's request, I am putting in writing the status of our negotiations.
LOu commüñicated to me earlier this week that he had no additional money to put on the
table from our prior discussions and that he was authorized to pay to my clients by a combination
ofnewmoney andliquida+ion ofassets already owned bythem, atotal sumof$7,030,000, consistin.g

of the following:
1. A settlement of the contested probate proceeding $1,850,000
clients'
2. Liquidation of my interest in Midland and
related partnerships 3,400,000
2- 9-01; 2:33PM;Farrell FritZ ;5162270777 # 3/ 3
' ' >

February 9, 2001
Page2
3. Liquidation of 1976 Trust u/a Fred Trump II 1,580,000 1
4. Buy-out ofleasehold interest owned by my clients 200,000
I responded to you that I had authority to settle on the above terms, except for the amount
attributable to the probate for which my clients are still demanding $2,000,000. My clients also wish
to have a representation as to a maximum that would pass out on the year 2000 K-1 to the
partnership so there would be no surprises.
It appears we are now $150,000 apart. My clients have moved considerably in their demands
and in view of the fact that Judge Nahman had recommended a $2,000,000 settlement attributable
to the probate, my clients feel strongly that this is a minimum level at which they feel comfortable
in settling.
In view of the fact that we have substantial depositions and motion practice immediately
ahead of us, I would ask that your clients seriously consider closing the gap and putting this matter
behind us.
I have copies Judge Nahman on this letter thinking that given how close we are, he may
believe a further conference before moving ahead on depositions and motion practice is advisable.
osky
JJB:jg
cc: Hon. Robert L. Nahman
1
My clients have indicated they may prefer not to liquidate this Trust, but simply have
new Trustees, and you indicated that was acceptable.
FARRELLFRTfZ
PROFESSIONAL CORPORATION
EAB PLAZA
(516} 227-0700
FACSIMILE: (516) 227-0777
JOHN&LARMENTAND ALONY.KAPEN JOHND,CAEMMERER
JOHNJ.BARNOSKY THOMASA KR1EEN 1928-1982
WD A.BEl0tOWUZ EIUCM.KRAMER WRITER'S DIRECr DIAL NUMBER FRANKA.FRHZ,JR.
JOHNP.CLEARY SEP)iENF,MEt.ORE 1924-1982
P-OBERTC.CREIGHTON JOHNL MORKEN
PETERL CURRY
aEoRæ1m
ARTHRK.FELDMAN
R.
ROBEATS.SANDLER
CHARLEsu.STRAm
A.KAUfL2ENTOMIJNSON - (516) 227-0730 t--
SPECIAL
COUNSEL
1 5IMONS
ANDRBW
pot.ORESmiORICH LOUlsVLAHOS ••ÛÛ BUWAGER
ROBERT V.GUIDO JAMESM.WICKS
couNsa
KwNErnueRaAcH
ILiiNliS.COOPER
JAMES F.DEVARSD
SALLY M.DONAHUE
ANDREW L CONEN JENNIFER
M.MONE THOMAS 1 DORAN
PATRICKT.COLLINS MARIANNE MONROY 2001 >O×^m^w1.szon
ANDREW L CRABTAEE DAWND..OLLIVIIIRRE February 15, ANNIONY S.GUARDIND
CHRIETOPHERP.DALY ERICW.PENZER MICHAEL1 HEALY
STEVENN.DAV) BRUCEN.AOBERTs PATRICA C.MARCIN
GRECiORYC.FORNASAR ELATNER.SAMMON MIRIAM E.VILl.AN1
KENNETH S.HOROWITZ NELLYSTOTLAND
SETHW.KRASE1.OVSKY LLSAM.VACCARD
LYLEC.MAMI,ER MARIEZWEEG OUREILENCMBER
'"58·"EY"" 13157-100
BY FACSIMILE
(516) 488-1238

3000 Marcus Avenue
Dear Steve:
This letter will confirm our telephone conversation in which on behalf of my clients I
advise that they were agreeable to the settlement set forth in my letter of February 9, 2001, with
the exception that the amount attributable to settlement of the probate proceeding will be
increased by $75,000 to the sum of $1,925,000.
I wil.1 work on drafting the Settlement Agreement over the long weekend and will have a
copy in the hands of you and Lou by Wednesday.
Very yo s,
Jo , Barnosky
JJB:jg
cc: Louis D. Laurino, Esq. (via facsimile)
LAURINO & LAURINO

ATTORNEYS AT LAW
229 SEVENTH STREET
GARDEN CITY, NEW YORK 11530
LOUS D. LAURANO TELEPHONE: (518) 248-4771
LOUlS M. LAUR1NO FAX: (516) 248-4785
February 2 I, 2001
Via Facsimile 516-227-0777

Farrell Fritz
EAB Plaza

Attn: John L Barnosky, Esq.
RE: The Estaig of Fred C. Trump
Dear Jack:
On arriving at my office this morning, I received your facsimile dated February 20, 2001
with the proposed draft of the Settlement Agreement based upon our discussions.
supposedly
However, rather than submit my·draft to you at this time, which is still being prepared, I believe
I have to call your attentioñ to a few items before there is any misunderstanding.
With respect to paragraph three (3) the checks will be payable to the objectaüts as well as
Farrell Fritz. With respect to paragraph four (4) we have clearly indicated throughout our
discussions that we will not make any representations as you set forth in the last paragraph
pertaining to the K-1 forms for the year 2000. We have indicated to you orally that the amount
of the K-1s in all likelihood will be slightly higher than it was in the year of 1999. In addition
thereto, we have advised you that a number of the cooperative apartments have been sold and
therefore there will be a capital gains aspect of the annual statement.
With respect to paragraph five (5) and the ground leases, at no time have you ever
indicated a desire on your client's part to stay in rather than be bought out. Part of the "global
settlement"
was that all ties in relationships between the proponents to the objectants would be
completely terminated. This includes Midland Associates, the probate proceedings, the ground
leases and the trusts. In fact, I don't recall ever having heard you say or express any
disagreement that part of the global settlement was not to include the ground lease and I am a bit
surprised at this point that you are now raising this issue. This must be part of our understanding
or else we just don't have an agreement.
Furthermore, the title to the ground leases may be with the Chase Manhattan Bank so that
any payments made to your clients may have to be held in escrow until the appropriate
acceptance of the assignment of yoor client's rights, title and interest to those ground leases or
their rights, title and interest into the trust instruments will have to be assigned over to my
clients. Title to the ground leases are being examined and I will keep you advised as to our
findings.
Farrell Fritz
Febr.uary 21, 2001
l'age2
With respect to paragraph six (6), the only thing we have discussed is my clients'
withdrawal and resignation as trustees. We will not be-responsible to obtain Irwin's withdrawal
or resignation. I believe that your clients have an ongoing relationship with him. We would like
to know who you would want as a designee of my clients. We assume no responsibility in
attempting to negotiate with Irwin Durben or to request that be withdraw as a trustee.
With respect to paragraph seven (7) there are several items which I would like to discuss
with you as it pertains to the Stipulation of May 15, 2000 which was part of the Supreme Court
Order of July 31, 2000.
The first paragraph of said Stipulation required your client to release to AMA's
representatives any and all information including but not limited to medical insurance received
or available from his employer necessary to process any claim submitted to our plan
administrator. I have asked Mr. Wicks for that information and the authorization to be signed by
Fred C. Trump, III well over a month ago. I have never received that authorization and to this
date we do not b>!ve th<:: information from your client.
· With respect to the processing of claims I believe the Stipulation is rather clear.
However, 1 had indicated-to you that: my clients were anxious and desirous of being reimbursed
.for the amount that they advanced on behalf of Fred C. Trump, III's family. When, in fact, those
claims should have been processed through his carrier. Therefore we would expect him to
cooperate with us in attempting to.recover the payments that should have been paid by his carrier
rather than through AMA. . ·
In addition, Linda C. Trump .or Mary L. Trump need to relinquish any rights that may
exist for reimbursement for obtaining their own medical insurance.
. With respect to paragraph.nine (9) under the Unif01m Rules of the Court an appropriate
motion is going to have to be made to seal pa1tially or totally the records that we are going to be
requesting. I. intend to have a more extensive clause submitted to you as it pertains to the
confidentiality aspect but we also need your clients cooperation to consent to the sealing of
records. Not only in the Surrogate's Court but in the Supreme Court as welL
. ;;t;i"·
Louis D. Laurino
LDL:kr
cc: Dennis Hasher, Es·q.
Via facsimile (718) 891-3609
Stephen J. Schwartz,·Esq. · ·
Via facsimile 516-488-1238
FARRELL FRITZ
PROPE5.9tONAL CORPORATKN
EAB PLAZA
Uniondale, New York (1556-0120 !
. . (316) 227-0700
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13157-100
Louis D. Laurino, Esq. .

Laurino & Laurino
229 Seventh St, Ste. 201
Re: . Estate of Fred C. Trump
Dear Lou:
I received your fax and had about a half hour to review it before going into a series of
.
mee*ings. I thought I would dictge on the fly some of the things that Um sure we can agree to as
follows-
1 No problern with checks being payable to my client as well as Farmll Frits
2. With respect to K-1's, certainly ym1 have always said that your clients would not
makerepresentations, but when I spoke to Steve last week he thought that by thetirne
the stip was signed, there might.be enough infbrmation on the table to providc an
upside cap- Thus, the provision.
3. With regard to paragraph 6, I don't believe my clients have an engoing relationship

with Irwin but I will take the matter up with him directly. I will also let you know
who Fred would want as a designee.
4. I think I covered the Linda Trump/Mary Trump issue in my draft by having all
plaintiffs withdraw with prejtidice. but I have no mblem with the waiver 1âñguaga
you suggest. [
516-248-4785 LAURINO AND LAURINO PAGE 03
02/22/2001 09:27
Febmary 21, 2001

Page 2
5. I have no problem with sealing the record.
6. With respect to the ground leases, Ibad =an¾ed in JudgeNahman's chambers that
my clients might want to stay in but P1l take this up with them again.
The rest of the contents of your letter Pil take up with my clients tomorrow.
Very indy ypura,
John J. Barnosky
JJB:lac
FFDOCSn319703.1
!
EXHIBIT "X"
To all to whom these Presents shall come or may Concern, know
that
MARY L. TRUMP
residing at 52 Davison Place, Rockville Centre, New York as RELEASOR,
in consideration of the sum of -----------------Ten ($10.00)---------- - Dollars

($10.00)
and other valuable consideration,
received from DONALD L TRUMP, individüally and as Co-Executor
of the Estate of FRED C. TRUMP a/k/a FREDERICK CHRIST TRUMP

as well as the Estate of MARY ANNE TRUMP as RELEASEE,
receipt whereof is hereby ackü0wI6dged, releases and discharges
DONALD J. TRUMP, individually and as Co-Executor
of the Estate of FRED C. TRUMP a/k/a FREDERICK CHRIST TRUMP as well as the Estate of MARY ANNE
TRUMP, the RELEASEE, RELEASEE'S heirs, executors, administrators, successors and assigns from all actions,
causes of action, suits, debts, dues, sums of money, accounts, reckonings, bonds, bills, specialties, covenants,
contracts, controversies, agreements, promises, variances, trespasses, damages, judgments, extents, executions,
claims, and demands whatsoever, in law, admiralty or equity, which against the RELEASEE, the RELEASOR,
RELEASOR'
S heirs, executors, adminiztrators, successors and assigns ever had, now have or hereRs can, shall or
may, have for, upon, or by reason of any matter, cause or thing whatsoever from the hcgin-ing of the world to the
day of the date of this RELEASE, except for any obligations under a certain Agreement and
Stipulation signed simultaneously he.rewitlp
Thts RELEASE is being executed m accómañce with the terms and ccaditiûns set forth in detail
seMement"
within the Agreement and StipüIstian signed by the parties pertaining to the "global of all their
differences. .
"RELEASOR" "RELEASEE"
The words and include all releasors and all releases under this
RELEASE.
This RELEASE may not be changed orally.
In Witness Whereof, The RELEASOR has hereunto s t RELEASOR'S hand and seal on the
day of April, 2001.
In presence of
L.S.
M . TRUMP
Social Security Number

..
STATE OF NEW YORK, COUNTY OF NASSAU ss.:
On April Ÿ , 2001, before me persermily came MARY L. TRUMP, to me known, and known
foragain'
to me to be the individüu1(s) described in, and who executed the LEASE, and duly acknowiêdged to me
that she executed the same.
JOHN J. BARNOSKY
Public, State of New York
Notary
No. 02BA0167250 Pgbhc
Qualified in Suffolk County
Commission Expires February 28, 200
that
MARY L. TRUMP
in-consideration of the sum of -------------------Ten ($10.00)------------------------- Dollars

($10.00)
received from ROBERT S. TRUMP, individually and as Co-Executor

as well as the Estate of MARY ANNE TRUMP . as RELEASEE,
receipt whereof is hereby acknowledged, releases and discharges
ROBERT S. TRUMP, individually and as Co-Executor
of the Estate of FRED C. TRUMP a/k/a FREDERICK CHRIST TRUMP as well as the Estate of MARY ANNE
TRUMP, the RELEASEE, RELEASEE'S heirs, executors, administrators, successors and assigns from all actions,
causes of action, suits, debts, dues, sums of money, àâvunts, reckonings, bonds, bills, specialties, covenants,
contracts, controversies, agreements, promises, variances, trespasses, damages, judgments, extents, executions,
RELEASOR'
S heirs, executors, administrators, successors and assigns ever had, now have or hereafter can, shall or
may, have for, upon, or by reason of any matter, cause or thing whatsoever from the beginning of the world to the
day of the date of this RELEASE, except f or any obligations under a certain Agreement and
Stipulation signed herewith. -
simultaneously
Tlus RELEASE is being executed in accordance with the terms and-condidons set forth in detail
settlement"
within the Agreement and Stipulation signed by the parties pertaining to the "global of all their
differences.
RELEASE.
In Witness Whereof, The RELEASOR has hereunto set RELEASOR'S hand and seal on the
day of April, 2001.
In presence of
..... . . L.S.
MAfY . TRUMP
On April , 2001, before me personally came MARY L. TRUMP, to me known, and known
to me to be the individual(s) d'escribed in, and who execüted the foregoing RELEASE, and duly aclaivwledged to me
JOHN J.-BARNOSKY
Notary
No. 02BA0167250
that
MARY L. TRUMP
in consideration of the sum of -------------------------------Ten ($10.00)---------------------------------------- Dollars

($10.00)
received from MARYANNE TRUMP BARRY, individually and as Co-Executor

as well as the Estate of MARY ANNE TRUMP as RELEASEE,
MARYANNE TRUMP BARRY, individually and as Co-Executor
of the Estate of FRED C. TRUMP a/lda FREDERICK CHRIST TRUMP as well as the Estate of MARY ANNE
TRUMP, the RELEASEE, RELEASEE'S heirs, executors, adrainisitators, successors and assigns from all actions,
causes of action, suits, debts, dues, sums of money, accounts, reckonings, bonds, bills, specialties, covenants,
centracts, controversies, agreements, y1062iscs, variances, trespasses, damages, judgments, extents, executions,
RELEASOR'S heirs, executors, administrators, successors and assigns ever had, now have or hereafter can, shall or
may, have for, upon, or by reason of any matter, cause or thing whatsoever from the beginning of the world to the
day of the date of this RELEASE, except f or any obligations under a certain Agreement and
Stipulation signed simultaneously herewith.
This RELEASE is being executed in accordance with the terms and conditions set forth in detail
settlement"
differences.
RELEASE.
day of April, 2001.
In presence of
o - / .- L.S.
M TRUMP
On April , 2001, before me personally came MARY L. TRUMP, to me known, and known
to me to be the individüal(s) des ribed in, and who executed the foregoin LEASE, and duly aclGow1cdgcd to me
JOHN J. BARNOSKY
No. 02BA0167250 ' '
Pubhd
Cornmission Expires February 28, 2
that
MARY TRUMP a/k/a MARY L. TRUMP

as RELEASOR,
in consideration of the sum of-- --------------Ten ($10.00)---------------------------------- Dollars

($10.00)
received from DONALD J. TRUMP, ROBERT S. TRUMP and MARYANNE TRUMP BARRY, as Preliminary
Co-Executors of the Estate of FRED C. TRUMP, Deceased, as well as imlividùally and as Co-Executors of the
Estates of FRED C. TRUMP, Deceased, and officers and directors of APARTMENT MANAGEMENT
ASSOCIATES, INC. and TRUMP MANAGEMENT, INC. and as partners, officers and directors in the
MIDLAND ASSOCIATES GROUP. as RELEASEE,
DONALD J. TRUMP, ROBERT S. TRUMP and MARYANNE TRUMP BARRY, as Preliminary Co-Executors of
the Estate of FRED C. TRUMP, Deceased, as well as individually and as Co-Executors of the Estates of FRED C.
TRUMP, Deceased, and officers and directors of APARTMENT MANAGEMENT ASSOCIATES, INC. and
TRUMP MANAGEMENT, INC. and as partners, officers and directors in the MIDLAND ASSOCIATES GROUP,
the RELEASEE, RELEASEE'S heirs, executors, administrators, successors and assigns from all actions, causes of
action, suits, debts, dues, sums of money, accounts, reckonings, bonds, bills, speciâ1ties, covenants, contracts,
controversies, agreements, promises, variances, trespasses, damages, judgments, extents, executions, claims, and
demands whatsoever, in law, admiralty or equity, which against the RELEASEE, the RELEASOR, RELEASOR'S
heirs, executors, administrators, successors and assigns ever had, now have or hereafter can, shall or may, have for,
upon, or by reason of any matter, cause or thing whatsoever from the beginning of the world to-the day of the date of
this RELEASE, except f or obligations under a certa3.n Agreement and Stipulation
any
signed simultaneously herewith.
This RELEASE is being executed in accordance with the terms and ca-h set forth in detail
se*!ement"
differences.
RELEASE.
'
Ñ day of April, 2001.
In presence of
- / L.S.
MARY a/k/a MARY-L UMP
Social SecurÍty Number
On April , 2001, before me personally came MARY TRUMP a/k/a MARY L. TRUMP, to
me known, and known to me'to be the individüal(s) described in, and o executed the foregoing RELEASE, and
duly acknowledged to me that she executed the same.
JOHN
J. BARNOSKY
NotaryPublic, State of New York
No. 02BA0167 250
Qualified in Suffolk .
County
EXHIBIT "Y"
RECEIPT AND RELEASE AND WAIVER OF CITATION
WHEREAS, FRED C. TRUMP, on December 16, 1976, created a
Trust for the benefit of his granddaughter, MARY L. TRUMP, naming
as Trustees thereof, Mary Anne T. Desmond (now known as Mary Anne
Trump Barry, Donald J. Trump, Robert S. Trump and Matthew J.
Tos.ti, and
WHEREAS, via various resignations, deaths and successor
appointments, the current Trusteen of said Trust are Donald J.
Trump, Robert S. Trump, Mary Anne Trump Barry and Irwin Durben,
and
WHEREAS said Trustees have agreed to resign as Trustees
of said Trust and are desirous of having their account of
proceedings covering the period from inception through April 10,
2001 settled and allowed, and
WHEREAS, both the Trustees and the beneficiary, Mary L.
Trustees' account of
Trumpiare agreeable to the settlement of the
proceedings by this Receipt and Release and Waiver of Citation,
in order to avoid the delay and expense of a -judicial accounting,
NOW, THEREFORE, in consideration of the premises and of
the mutual agreement of the parties hereto to waive a judicial
settlement of said account of proceedings and other good and
valuable consideration, the receipt of which is hereby
acknowledged, it is hereby agreed as follows:

1. The Benefic iary does hereby represe nt that he has
examine d the annual Trustee s' stateme nts attache d hereto as
Exhibit A and is satisfi ed with same. The Trustee s represe nt

that said stateme nts are true and accurat e to the best of their
knowled ge.
2. The Benefic iary, for himself , his heirs, legal
represe ntative s, executo rs, admini strators , success ors and
assigns (herein after "succes sors") does' hereby remise, release
and forever dischar ge the Trustee s individ ually and as Trustee s
of said Trust, of and from any claims, demands , or liabili ties
whatso ever which the Benefic iary, has, or might have, or which
his success ors now have or might have by reason of the acts and
proceed ings of the Trustee s and as to all matters set forth in
the docume nts made availab le to them and agreed upon in this
instrum ent of Receipt and Release .
3. The Benefic iary does hereby waive the issuanc e and
service of any Citatio n or other nolice in any judicia l
proceed ing or action brought at any time tc settle the account of
the Trustee s, and consent s that an order or decree may be entered
in such proceed ing or action settlin g such account and releasi ng
the Tr·ustee s as to all matters embrace d therein , it being the
intenti on of the parties that this agreeme nt shall have the
effect of a judicia l settlem ent of the annexed account .
4. The Benefic iary does hereby represe nt that he has
not assigne d, transfe rred or encumb ranced any of his interes t in

the property herein accounted for, that he is entitled to the
property herein receipted for and that he is aware of no other
claim to any of the property accounted for.
5. This Agreement may be executed in any number of
counterparts each of which shall be deemed an original, but all
of which together shall constitute one and the same Agreement.
IN WITNESS WHEREOF, the parties hereto have executed this
Receipt and Release and Waiver of Citation of the day of
April, 2001.
DO . T MP
ROBERT S. TRUMP
MAR ANNE RUMP R Y
IRWIN DURBEN
MARY L. TRUMP
STATE OF NEW YORK )
COUNTY OF / ^} tif) )
On the day of April, in the year 2001 before me, the

undersigned personally appeared DONALD J. TRUMP, personally
known to me or proved to me on the basis of satisfactory evidence
to be the individual(s) whose name(s) is (are) subscribed to the
within instrument and acknowledged to me that he executed the
same in his capacity(ies), and that by his signature(s) an the
instrument, the individual(s), or the pers on be of which
the individual(s) acted, executed the ins rume t.
. . Notary Public
LOUISD.tAURINO
STATE-OF NEW YORK ) NotaryPublic,StalsofNewYork
)SS.: No.4995194
COUNTY OF ) .. wp
undersigned, personally appeared ROBERT S. TRUMP, personally
known to me or proved to me on the basis of satisfactory evidence
to be the individual(s) whose name(s) is (are) subscribed to the
within instrument and acknowledged to me that he executed the
same in his and that h4 signature on the
capacity(ies), by )
instrument, the individual(s), or the p rso upon ehalf of which
the individual(s) acted, executed the nstr ment.
Notary Public
LOUiSD.LAURINO
STATE.OF NEW YO K ) Notary9ublic,StateofNewYork
)ss.: No,4995194
COUNTY OF /
CommissionExpireeApril20 4G9"'>#ok
On the /, .day of April, in the year 2001 before me, the

undersigned, personally appeared MARY ANNE TRUMP BARRY,
personally known to me or proved to me on the basis of
satisfactory evidence to be the individual(s) whose name(s) is
(are) .subscribed ·to the within instrument and acknowledged to me

that she executed the same in her capacity(ies), and that by her
signature(s) on the instrument, the indi al(s), or the person
upon behalf of which the individual(s) cts , ex ut d the
instrument.
Notary Public
LOU|BD.lAURINO
Pubile,Statoo(NewYoik
No.4996194
QualilledinNassaucounty
CommissionExpiresApdiki95
STATE OF NEW YORK )
COUNTY OF-
)

undersigned, per sonally appeared IRNIN DURBEN, personally known
to me or proved to me on the basis of satisfactory evidence to be
the individual(s) whose name(s) is (are) subscribed to the within
instrument and acknowledged to me that he executed the same in
his capacity(ies), and that by his signat on the
instrtiment, the individual(s), or the pe son u on behal of ich
the individual(s) acted, executed the i strument.
Publict.OUlSD.tAURIN0
Notary
ágggyP¾9teed NewYork
No, mo5194
Conf
STATE OF NEW YORK )
QggAladinNMs
g)
y
)SS.:
COUNTY OF )

undersigned, personally appeared MARY L. TRUMP, personally known
to me or proved to me on the basis of satisfactory evidence to be
the individual(s) whose name(s) is (are) subscribed to the within
instrument and acknowledged to me that she executed the same in
her capacity(ies), and that by her signature(s) on the
instrument, the individual(s), or the person upon behalf of which
the_individual(s) acted, executed the instrument.
Notary Public
RECEIPT AND RELEASE AND WAIVER OF CITATION
WHEREAS, FRED C. TRUMP, on Decembe r 16, 1976, created a
Trust for the benefit of his grandda ughter, MARY L. TRUMP, naming
as Trustees thereof, Mary Anne T. Desmond (now known as Mary Anne
Trump Barry, Donald J. Trump, Robert S. Trump and Matthew J.
Tosti, and
WHEREAS, via various resignat ions, deaths and successo r
appointm ents, the current Trustees of said Trust are Donald J.
Trump, Robert S. Trump, Mary Anne Trump Barry and Irwin Durben,
and
WHEREAS said Trustees have agreed to resign as Trustees
of said Trust and are desirous of having their account of
proceed ings covering the period from inceptio n through April 10,
2001 settled and allowed, and
WHEREAS, both the Trustees and the benefic iary, Mary L.
Trump are agreeab le to the settleme nt of the Trustee s' account of
proceed ings by this Receipt and Release and Waiver of Citation ,
in order to avoid the delay and expense of a judicia l accounti ng,
NOW, THEREFORE, in conside ration of the premises and of
the mutual agreeme nt of the parties hereto to waive a judicial
settleme nt of said account of proceedi ngs and other good and
valuable conside ration, the receipt of which is hereby
acknowl edged, it is hereby agreed as follows:

1. The Beneficiary does hereby represent that he has
examined the annual Trustees' statements attached hereto as
Exhibit A and is satisfied with same. The Trustees represent
that said statements are true and accurate to the best of their
knowledge.
2. The Beneficiary, for himself, his heirs, legal
representatives, executors, administrators, successors and
assigns (hereinafter "successors") does hereby remise, release
and forever discharge the Trustees individually and as Trustees
of said Trust, of and from any claims, demands, or liabilities
whatsoever which the Beneficiary, has, or might have, or which
his successors now have or might have by reason of the acts and
proceedings of the Trustees and as to all matters set forth in
the documents made available to them and agreed upon in this
instrument of Receipt and Release.
3. The Beneficiary does hereby waive the issuance and
service of any Citation or other notice in any judicial
proceeding or action brought at any time to settle the account of
the Trustees, and consents that an order or decree may be entered
in such proceeding or action settling such account and releasing
the Trustees as to all matters embraced therein, it being the
intention of the parties that this agreement shall have the
effect of a judicial settlement of the annexed account.
4. The Beneficiary does hereby represent that he has
not assigned, transferred or encumbranced any of his interest in

the property herein accounted for, that he is entitled to the
property herein receipted for and that he is.aware of no other
claim to any of the property accounted for.
5. This Agreement may be executed in any number of
counterparts each of which shall be deemed an original, but all
of which together shall constitute one and the same Agreement.
IN WITNESS WHEREOF, the parties hereto have executed this
Receipt and Release and Waiver of Citation of the day of
April, 2001.
DONALD J. TRUMP
ROBERT S. TRUMP
MARY ANNE TRUMP BARRY
IRWIN DURBEN
pápY L. TRUMP
EXHIBIT "Z"
STATEOFNEWYORK
SURROGATE'S COURT, COUNTY OF QUEENS
-----------------------------------------------------------------)( AGREEMENT AND
Probate Proceeding, Will of
STIPULATION
FRED C. TRUMP
a/k/a FREDERICK CHRIST TRUMP, Fil\! No. 3949/1999
Deceased.
------------------------------------------------------------------)(
Probate Proceeding, Will of
MARY ANNE TRUMP, File No. _..........:/2001
Deceased.·
-------------------------------------------------------------------)[
COUNTY OF NASSAU
-------------------------------------------------------------------)(
LINDA C. TRUMP, MARY TRUMP, LISA and
FRED C. TRUMP, III, individually and as parent
and natural guardian of WILLIAM TRUMP, an infant
under the age of 18 years,
Plaintiffs,
-against- IndeJl No. 6795/2000
DONALD J. TRUMP, ROBERTS. TRUMP, and

MARY ANNE TRUMP BARRY, as Preliminary
Co-EJlecutors of the Estate of FRED C. TRUMP,
deceased, APARTMENT MANAGEMENT
ASSOCIATES, INC. and TRUMP MANAGEMENT,
INC. .
Defendants.
--------------------------------------------------------------------)[ ;,
THIS AGREEMENT AND STIPULATION made as of the /o- day of April,
TRUMP
2001, by and between DONALD J. TRUMP, ROBERTS. TRUMP and MARYANNE
dated
BARRY, (the ''Proponents"), individually and as Co-EJlecutors under a purported Will
of Queens
September 18, 1991, and offered for probate in the Surrogate's Courto fthe County
(File Number 3949/1999) as the Last Will and Testament of FRED C. TRUMP, a/k/a
FREDER ICK CHRIST TRUMP, deceased (the "Decedent") and FRED C. TRUMP Ill, residing
at 67 Richmon d Hill Road, Greenwich, Connecticut 06831, and MARY L. TRUMP, residing at
52 Davison Place, Rockville Centre, New York, ("Respondents/Objectants") to the Last Will and
Testamen t
A.N.l2
by and between DONALD J. TRUMP, ROBERT S. TRUMP and MARY ANNE
TRUMP BARRY, (the "Propone nts"), individually and as Co-Execu tors under a purported Will
dated Septembe r 18, 1991, and a purported First Codicil dated March 12, 1998, and a purported
Second Codicil dated Novembe r 18, 1999, and being offered for probate in the Surrogat e's Court
of the County of Queens (File No. /2001) as the Last Will and Testament of MARY
ANNE TRUMP, deceased (the "Deceden t") and FRED C. TRUMP III, residing at 67 Richmon d
Hill Road, Greenwich, Connecticut 06831, and Mary L. Trump, residing at 52 Davison Place,
Rockville Centre, New York, ("Respondents") to the Last Will and Testamen t and Codicils
A.N.l2
LINDA C. TRUMP, MARY TRUMP, LISA and FRED C. TRUMP, Ill,
individually and as parent and natural guardian of WILLIAM TRUMP, an infant under the age
of 18 years ("Plaintiffs") commenced an action against DONALD J. TRUMP, ROBERT S.
TRUMP and MARY ANNE TRUMP BARRY, as Preliminary Co-Execu tors of the Estate of
FRED C. TRUMP, deceased, APARTM ENT MANAGEMENT ASSOCIA TES, INC. and
TRUMP MANAG EMENT, INC. ("Defendants") as it pertained to the cancellation of medical
insurance coverage
2
APARTMENT MANAGEMENT ASSOCIATES, INC. and TRUMP
MANAGEMENT, INC. and DONALD TRUMP, MARY ANNE TRUMP BARRY and
ROBERTS. TRUMP, as shareholders and officers and directors of same, and as partners in
MIDLAND ASSOCIATES GROUP and as co-owners of certain ground leases described in
Paragraph 14 hereof
WITNE SSETH
WHEREAS, FRED C. TRUMP alk/a FREDERICK CHRIST TRUMP (the
"Decedent") died on the 25'" day of June, 1999, a resident of and domiciled in the County of
Queens and State ofNew York, and
WHEREAS, the said "Decedent" (FCT) left a paper writing purporting to be his
Last Will and Testament bearing date the 18"' of September, 1991, and
WHEREAS, the "Will" was duly filed in the Surrogate's Court ofthe County of
Queens along with the petition of DONALD J. TRUMP, ROBERTS. TRUMP and
MARYANNE TRUMP BARRY (the "Proponents") seeking probate thereof and the issuance of
Letters Testamentary thereon to them, and
WHEREAS, by Order of the Queens County Surrogate's Court dated September
24, 1999, the "Proponents" have been appointed Preliminary Executors of the Estate of FRED C.
TRUMP and have administered said estate in that capacity since appointment, and
WHEREAS, a Citation was issued on the aforesaid Probate Petition by the
Queens County Surrogate's Court and jurisdiction has been completed, and the following
persons have appeared in the proceeding by the law fin11S listed below:
Proponents: LOUIS D. LAURINO, ESQ.

Laurino & Laurino, Trial Counsel
3
'
229 Seventh Street, Suite 20 l
Garden City, New York 1!530
STEPHEN J. SCHWARTZ, ESQ.

Attorney for "Proponents"
3000 Marcus Avenue
Lake Success, New York II 042
Objectants: JOHN J. BARNOSKY, ESQ.

Farrell Fritz, PC
EAB J:"laza
Uniondale, New York 11556 and,
WHEREAS, Objectants on March 23, 2000, filed objections to probate
contending that the Will was the product of undue influence and fraud, that the decedent lacked
testamentary capacity or understanding to execute the instrument and that said Will was not duly
executed, and
WHEREAS, examinations pursuant to SCPA § 1404 have been conducted, and
WHEREAS, MARY ANNE TRUMP, (MAT) the surviving spouse of FRED C.
TRUMP, subsequently died on the 7"' day of August, 2000, leaving a purported Last Will and
Testament dated September 18, 1991 and a purported First Codicil dated March 12, 1998 and a
purported Second Codicil dated November 18, 1999, now being filed for probate by the
"Proponents" as Co-Executors in Queens County Sutrogate's Court, and FRED C. TRUMP, III
and MARY L. TRUMP are named distributees and "Respondents" in said probate proceeding,
and
WHEREAS, L!NDA C. TRUMP, MARY TRUMP, LISA and FRED C. TRUMP,
III, individually and as parent and natural guardian of WILLIAM TRUMP, an infant under the
age of 18 years, commenced an action against DONALD J. TRUMP, ROBERTS. TRUMP and
MARYANNE TRUMP BARRY, as Preliminary Co-Executors of the Estate of FRED C.
4
TRUMP, deceased, APARTME NT MANAGEMENT ASSOCIATES, INC. AND TRUMP
MANAGEMENT, INC. as it pertains to the cancellation of medical insurance coverage, :and
WHEREAS , subsequent to the filing of objections to the Last Will and Testament
of FRED C. TRUMP and the commencement of the Supreme Court action in Nassau County
pertaining to the enforcement of the rights of the Plaintiffs named therein to continue medical
insurance coverage, there have been numerous motions, cross-motions, contempt proceeding s,
and discovery schedules established, as well as a pending motion to quash a subpoena and a
cross-motion for a protective order, and
WHEREAS , all interested parties have been represented by counsel and none are
under disability, and
WHEREAS , the parties hereto wish to avoid the uncertainty, further expense and
delay incident to protracted litigation and believe it is in the best interest of all concerned that the
controversies raised by these proceedings be compromised and settled, on a "global basis" in
order to resolve all of their differences pertaining to the two (2) probate proceedings; the
insurance case; partnership and corporate interests; as well as their interests in two (2) inter
vivos trusts established by FRED C. TRUMP as the Settlor,
NOW, THEREFORE, in consideration of the mutual covenants set forth herein,
and subject to the fulfillment of the following, it is agreed and stipulated as follows:
CONFIDE NTIALITY & SEALING OF RECORDS

Uniform Rule 22NYCRR 216.l(a)
Sealing:
1. Each of the "Proponents" as well as the "Respondent/Objectants" as well as
each of the Plaintiffs and Defendants in the Supreme Court, Nassau County action (Index No.
6795/2000) have unanimous ly agreed that the public has no interest in the particular information
5
involved in the "global" resolution of their differences. Confidentiality is, in certain
circumstances, necessary in order to protect the litigants and encourage a fair resolution of the
matters in controversy. The interests herein favor confidentiality and confidentiality should be
provided, the "Objectants/ Respondents" and all Plaintiffs and Defendants in the Supreme Court,
Nassau County action will join in the motion to seal these records.
Confidentiality:
2. Without obtaining the consent of DONALD J. TRUMP, ROBERTS . TRUMP
and MARYAN NE TRUMP BARRY, individually and as Co-Executo rs of the Estate of FRED
C. TRUMP, deceased, and individually and as Co-Executors of the Estate of MARY ANNE
TRUMP, deceased, as well as officers and directors of APARTME NT MANAGE MENT
ASSOCIATES, INC. and TRUMP MANAGEMENT, INC. ("Proponents/Defendants") in
advance, FRED C. TRUMP, III and MARY L. TRUMP, LISA TRUMP and LINDA C. TRUMP
("Objectant/Plaintiffs") as well as Farrell Fritz, P.C. (their counsel) shall not disclose any of the
terms of this Agreement and Stipulation, and in addition shall not directly or indirectly publish
or cause to be published, any diary, memoir, letter, story, photograph, interview, article, essay,
account, or description or depiction of any kind whatsoever, whether fictionalized or not,
concerning their litigation or relationship with the "Proponents/Defendants" or their litigation
involving the Estate of FRED C. TRUMP and the Estate of MARY ANNE TRUMP, or assist or
provide information to others in connection therewith. As used in the preceding sentence, the
terms "publish" and "publication" shall be deemed to include the presentation or reproduction of
written, verbal or visual material in any communication medium, including, without limitation,
books, magazines, newspapers, theatrical productions of any kinds, movies, television, or radio,
or the use of the internet in any language and in any jurisdiction. Any violation of the terms of
6
this Paragraph 2 shall constitute a material breach of this agreement. In the event such breach
occurs, "Objectants!Plaintiffs", as well as their "counsel", hereby consent to the granting of a
temporary or permanent injunction against them (or against any agent acting in their behalf) by
any court of competent jurisdiction prohibiting them (or their agent) from violating the terms of
this Paragraph. In any proceeding for any injunction and upon any motion for a temporary or
permanent injunction, "Objectants!Plaintiffs" and their "counsel" agree that their ability to
answer in damages shall not be a bar or imposed as a defense to the granting of such temporary
or permanent injunction. "Objectants/Plaintiffs" and their "counsel" further agree that
"Proponents/Defendants" will not have an adequate remedy at law in the event of any breach by
"Objectants!Plaintiffs" hereunder and "Proponents/Defendants" will suffer irreparable damage
and injury in event of any such breach.
3. Without obtaining the written consent of FRED C. TRUMP, III and MARY
TRUMP, LISA TRUMP and LINDA C. TRUMP ("Objectants/Plaintiffs'') in advance,
DONALD J. TRUMP, ROBERTS. TRUMP and MARY ANNE TRUMP BARRY, individually
and as Co-Executors of the Estate of FRED C. TRUMP, deceased, and individually and as Co-
Executors of the Estate of MARY ANNE TRUMP, deceased, and as officers and directors of
APARTMEN T MANAGMENT ASSOCIATES, INC. and TRUMP MANAGEMENT, INC.
("Proponents/Defendants") as well as Stephen J. Schwartz, Esq. and Louis D. Laurino, Esq.
(their counsel) shall not disclose any of the terms of this Agreement and Stipulation and in
addition shall not disclose any of the terms of the Agreement and Stipulation, and in addition
shall not directly or indirectly publish or cause to be published, any diary, memoir, letter, story,
photograph, interview, article, essay, account, or description or depiction of any kind
whatsoever, whether fictionalized or not, concerning their litigation or relationship with the
7
"Proponents/Defendants", "Objectants/Plaintiffs" or their litigation involving the Estate of
FRED C. TRUMP and the Estate of MARY ANNE TRUMP, or assist or provide information to
others in connection therewith. As used in the preceding sentence, the terms "publish" and
"publication" shall be deemed to include the presentation or reproduction of written, verbal or
visual material in any communication medium, including, without limitation, books, magazines,
newspapers, theatrical productions of any kinds, movies, television, or radio or the use of the
internet in any language and in any jurisdiction. Any violation ofthe terms of this Paragraph 3
shall constitute a material breach of the Agreement. In the event such breach occurs,
"Proponents/Defendants", as well as their "counsel", hereby consent to the granting of a
temporary or permanent injunction against them (or against any agent acting in their behalf) by
any Court of competent jurisdiction prohibiting them (or their agent) from violating the terms of
this Paragraph. In any proceeding for any injunction and upon any motion for a temporary or
permanent injunction. "Proponents/Defendants" and their "counsel" agree that their ability to
answer in damages shall not be a bar or imposed as a defense to the granting of such temporary
or permanent injunction. "Proponents/Defendants" and their "counsel" further agree that
"Objectants/Plaintiffs" will not have an adequate remedy at law in the event of any breach by
"Proponents/Defendants" hereunder and "Objectants/Plaintiffs" will suffer irreparable damage
and injury in event of any such breach.
Paragraphs 1, 2 or 3 are not violated in the event any party hereto is compelled by
Court order to disclose any of the information deemed confidential pursuant to this Agreement;
provided however, that the party required to disclose, prior to disclosure, provides notice of such
requirement to the other parties so that any of such other parties may seek a protective order or
other appropriate remedy. In the event such protective order or other remedy is not obtained, the
8
party required to disclose shall disclose only that portion of the information that is legally
required and reasonable efforts will be made to obtain reasonable assurance that confidentia l
treatment will be afforded to the information. In addition, the parties hereto may disclose those
material and necessary matters covered in said paragraphs in any proceeding to enforce this
Agreement.
PROBATE PROCEED ING- ESTATE OF FRED C. TRUMP
4. FRED C. TRUMP, III and MARY L. TRUMP, the distributee "Objectant s"
herein, do hereby withdraw their objections, dated and verified March 22, 2000 and will execute
on the fulfillment of all terms and conditions of the Agreement and Stipulation, Waivers and
Consents, consenting .to the probate of the Last Will and Testament dated September 18, 1991
and that Letters Testamentary be issued to the Co-Executors, DONALD J. TRUMP, ROBERTS .
TRUMP and MARYANNE TRUMP BARRY, without bond or security.
5. On the execution of this Agreement, FRED C. TRUMP, Ill and MARY L.
TRUMP will have no further interest in this estate in any manner whatsoever as creditors,
legatees or distributees, and will not be in any position to interfere with the administration of this
estate and have no standing or interest whatsoever in the Estate of FRED C. TRUMP, deceased.
PROBATE PROCEED ING- ESTATE OF MARY ANNE TRUMP
6. FRED C. TRUMP, III and MARY L. TRUMP, the distributees/respondents
herein will execute, on the fulfillment of all terms and conditions of the Agreement and
Stipulation, Waivers and Consents consenting to the probate of the Last Will and Testament
dated September 18, 1991, the First Codicil dated March 12, 1998 and the Second Codicil dated
November 18, 1999 and that Letters Testamentary be issued to the Co-Executors DONALD J.
TRUMP, ROBERTS . TRUMP and MARYANNE TRUMP BARRY without bond or security.
9
7. On the execution of this Agreement, FRED C. TRUMP III and MARY L.
TRUMP will have no further interest in this estate in a11y manner whatsoever as creditors,
legatees or distributees and will not be in any position to interfere with the administrat ion of this
estate nor have standing or interest whatsoever in the estate of MARY ANNE TRUMP,
deceased.
SUPREME COURT. NASSAU COUNTY ACTION

Index No. 679512000
8. The Plaintiffs, LINDA C. TRUMP, MARY TRUMP, LISA and FRED C.
TRUMP, III, individually and as parent and natural guardian of WILLIAM TRUMP, an infant
under the age of 18 years, will discontinue, with prejudice, the cause of action commence d by
them (Amended Verified Complaints) and all prior proceedings against the Defendants,
DONALD J. TRUMP, ROBERTS . TRUMP and MARYANN E TRUMP BARRY, as
Preliminary Co-Executors of the Estate of FRED C. TRUMP, deceased, APARTME NT
MANAGEM ENT ASSOCIAT ES, INC. and TRUMP MANAGE MENT, INC., seeking to
permanently enjoin the Defendants from discontinuing medical benefits to Plaintiffs and money
damages.
9. The "Defendant s", DONALD J. TRUMP, ROBERTS . TRUMP and
MARYAN NE TRUMP BARRY, as Preliminary Co-Executors of the Estate of FRED C.
TRUMP, deceased, APARTME NT MANAGEMENT ASSOCIAT ES, INC. and TRUMP
MANAGEM ENT, INC., will discontinue, with prejudice, the cross-comp laints and affirmative
defenses raised in their Answer to Amended Verified Complaint and Counterclaim dated
January 15,2001, as well as all prior proceedings.
10. Separate and apart from the exchange of General Releases in the two (2)
10
aforementioned Probate Proceedings covered by paragraphs I to 7, inclusive, the Plaintiffs and
Defendants will exchange General Releases as individuals and well as in their representative
capacities, such as but not limited to, "Parent and natural guardians", "preliminary Co-
Executors", "Co-Executors" and officers and directors of APARTMENT MANAGEMENT
ASSOCIATES, INC. and TRUMP MANAGEMENT, INC. and as partners, officers and
directors in the Midland Associates Group.
11. After the filing of the first motion by the Plaintiffs and the Defendant's cross-
motion thereto, the Plaintiffs and the Defendants, by their attorneys, entered into a Stipulation
and Order dated May 15,2000 and "So Ordered" by the Hon. John W. Burke, Justice of
Supreme Court, State of New York on July 31, 2000. This Stipulation dated May 15, 2000, and
its terms and conditions shall also cease and "Defendants" are obligated no longer to provide any
coverage of medical insurance, after the date of this Agreement, to any of the Plaintiffs for
themselves individually, but also as the parents and natural guardians of the children of FRED C.
TRUMP, III and his wife, LISA TRUMP. All claims submitted up to the date of this Agreement
will be processed in accordance with the Stipulation of May 15, 2000 and Defendants remain
obligated to pay same in accordance with the terms of the Stipulation.
LINDA C. TRUMP and MARY L. TRUMP also hereby waive their right to
reimbursement for the cost of their medical insurance.
12. FRED C. TRUMP, III will cooperate with APARTMENT MANAGEMENT
ASSOCIATES, INC. (AMA) in its attempt to recover payments made by AMA from his current
carrier for medical coverage under his employer's health plan. Plaintiffs are not required to
otherwise reimburse or pay back Defendants for any sums paid or advanced hereto in accordance
with this Stipulation.
ll
In the event his current carrier for medical coverage reimburses FRED C.
TRUMP, IH and issues checks payable to him personally, he will endorse said check or checks
to APARTMENT MANAGEMENT ASSOCIATES, INC. on receiptofsaid reimbursement.
MIDLAND ASSOCIATES GROUP
13. During the pendency of the probate proceeding (Estate of FRED C. TRUMP)
and the Supreme Court, Nassau County action (Index No. 6795/2000) there have been ongoing
discussions pertaining to the interests of the "Objectants/Rcspondents" in Midland Associates
Group, which combined interest is a total sum 'of twenty percent (20%). At their request, their
ownership interest in certain partnerships and corporate entities commonly referred to as
"Midland Associates Group" necessitated that they be furnished the following information, but
not limited to, items enumerated herein:
(a) Copies of the most recent tax returns
(i) U.S. Income Tax Return for an S Corporation (Coronet Hall Inc.)
Form 1120S-1998-1999
(ii) Financial Statements 1997 & 1998, 1999 Coronet Hall Property,
Division of Coronet Hall, Inc.
(iii) U.S. Partnership Return - Form 1065

1998 & 1999 -Park Briar Associates, L.L.C.
(iv) Saxony Hall Property, Division of Park Briar Associates, L.L.C.

Financial Statements 1997, 1998 and 1999
(v) Midland Associates, L.L.C.- U.S. Partnership Return Form 1065-1998-1999
(vi) Sunnyside Towers Property, Division of Midland Associates, L.L.C.

Financial Statements 1997, 1998 and 1999
(vii) Highlander Hall, Inc.- U.S. Tax Return-S Corporation 1998 and 1999
(viii) Lincoln Shore Apartments (a Partnership)

Financial Statements- 1997, 1998 and 1999
12
(ix) List of units sold 1998, 1999 and unsold units 2/12/00 for Coronet Hall, Inc.,
Wedgewood Hall and 25% interest in Lincoln Shore Apartments as well as
Park Briar Associates, Saxony Hall Property, 25% interest in Lincoln Shore
Apartments and Starett City Associates, L.P., Midland Associates, L.L.C.,
inclusive of Sunnyside Towers Property; 50% interest in land leased to a
McDonald's franchise; Mortgage and Notes receivable
12/31!99; Notes payable 12/31/99 (list furnished separately).
Financial Statement 12/31/99; Highlander Hall, Inc., inclusive ofHigh1ander
Hall and 50% interest in Lincoln Shore Apartments
(x) Detailed list of cooperative apartment ownership interests - Midland, Coronet,

Highlander, Park Briar- yvith recent sales 1999 and 2000
(xi) Mortgage Receivable 9/29/00 and Notes Receivable 9/29/00
GROUND LEASES
14. In three (3) separate instruments dated March 12, 1948, FRED C. TRUMP
and ELIZABETH TRUMP (his mother), as fee owners, executed a lease to Shore Haven
Apartments No. I, Inc.; on March I, 1948, a lease to Shore Haven Apartments No.2, Inc.; and
on June I, 1948, a lease with Shore Haven Apartments No. 3, Inc.; each instrument recorded in
Register's Office, Kings County, (#!-conveyance liber 7274 pg. 198; #2-conveyance liber 7278
pg. 188; and #3-conveyance liber 7316 pg. 168).
Thereafter on August 20, 1980 Modification Agreements were executed between
The Chase Manhattan Bank as Trustee under Indenture Trust of FRED C. TRUMP dated August
2, 1949 and FRED C. TRUMP with the corporate tenants recited above establishing new rental
obligations.
Thereafter Durben & Tosti, LLP prepared separate deeds from Irwin Durben as
Trustee under an Indenture of Trust dated November 25, 1981 to FRED C. TRUMP, lii and
MARY LEA TRUMP, each for five percent (5%) interest in the property and a second separate
deed to FRED C. TRUMP, III and MARY LEA TRUMP, each for ten percent (10%) interest,
13
each of the deeds are dated October 18, 1995 and recorded in Reel3598, Pages 1996, 1997,
1998, 1999,2001, 2002,2003, 2004 for Shore Haven; on Pages 2006,2007,2008,2009,20 10,
2012,2013,2014,2015,201 6, 2017 for Beach Haven.
Shore Haven
The five percent (5%) interest to each of the grantees is recited in said deed as:
"Being the same premises as that conveyed to the party of the first by Deed dated
March 2, 1988 and recorded on Apri16, 1988 in Ree12198, Page 179"
Parcel A (Block 6469, Lot I); Parcel B (Block 6467, Lot 12) and Parcel C (Block 6489, Lot 1)
all in Kings County.
Beach Haven
The ten percent (I 0%) interest to each of the grantees is recited in said deed as:
"Being the same premises as that conveyed to the party of the first by
Deed dated March 2, 1988 and recorded on June 8, 1988 in Reel2198,
Page 279" Parcels in Block and lot as follows:
7216/38; 7238/2; 7237/2; 7238/82; 7235/1; 7234/100; 7234/150; 7234/1; 7232170; 7232173;
7233/2; 7233/210; 7233/225; 7237/63; 7327/64; 7237/65; 7212/100; 7214/39.
The "Objectants/Respondents" as grantors herein will execute the appropriate
deeds and transfer tax: forms to the "Proponents" or their designee, covering all of their right,
title and interest to the "ground leases" affecting the real property described in detail in each of
the aforesaid deeds (copies of said deeds have been furnished their "counsel"), so that on the
execution of this Agreement and the payment of the consideration provided for herein, they
("Objectants/Respondents") will no longer have any interest in said long-term ground leases,
properties or option extensions as provided for therein. The leases are due to expire in the year
2048 and have renewal options of another ninety-nine (99) years.
14
1976 TRUST AGREEMENTS
15. On the 16'h day of December, 1976, FRED C. TRUMP, as "Grantor", created
an iiTevocab1e trust for each of his grandchildren, namely FRED C. TRUMP, III and MARY L.
TRUMP, with a Schedule A amount of cash of $400,000.00 in each trust.
The designated "trustees" were MARY ANNE T. DESMOND, DONALD J.
TRUMP, ROBERTS. TRUMP and MATTHEW J. TOSTI (followed by Irwin Durben as
successor to Matthew J. Tosti).
The "Proponents" herein, as Tnistees have the authority " ... to pay out of the net
income or principal or both such amount or amounts ... [as] may in their sole discretion determine
to such one or more persons as the Trustees ... they may in their sole discretion select out of a
class composed of the Beneficiary and the descendants of the Beneficiary ... " (under Article
ONE).
The "Proponents" wisn to resign as Trustees and terminate the trust for MARY L.
TRUMP and deliver the total assets as set forth below, including undistributed income within
fifteen (15) days of her delivery to tne trustees a Receipt and Release, in the form annexed hereto
as Exhibit __, as well as a consent from FRED C. TRUMP, III to the delivery of said assets to
MARYL. TRUMP.
The "Proponents" further wish to resign as Trustees (under Article FOURTH) for
the trust for the benefit of FRED C. TRUMP, Ill and shall designate their successor and consent
to the appointment of a successor trustee or trustees designated by FRED C. TRUMP, III (under
Articles FIFTH and SIXTH) on his simultaneous execution and delivery of the Receipt and
Release.
15
The Successor Trustees shall be Fred C. Trump, Ill, residing at 67 Richmond Hill
Road, Greenwich, Connecticut 06831, and Mary L. Trump, residing at 52 Davison Place,
Rockville Centre, New York.
Proponents shall also furnish at the time of signing of this Agreement a
resignation of Irwin Durben as Trustee of both Trusts, and his consent to termination of the
MARY L. TRUMP TRUST and his consent to appointment of a Successor Trustee of the FRED
C. TRUMP,III TRUST as designated by FRED C. TRUMP, III.
The "Proponents" as Trustees are not required to submit any informal or formal
accounting due to the prior submissions and periodic accounts previously submitted.
CONS!DERA TION
16. The "Proponents" agree to pay the "Objectants/Respondents" the following
in consideration of a "global settlement" of all of their differences:
(a) Probate Proceeding- Estate of FRED C. TRUMP

(i) Fred C. Trump III $ 962,500.00
(ii) Mary L. Trump 962.500,00
Total $1.925,000.00
Payment to be made within ten (10) days of the entry of the Decree of
Probate in the Estate of FRED C. TRUMP, by certified check to the Objectants
and Farrell Fritz.
Said sum shall be free of any and all estate, generation skipping or income
taxes which, if imposed, "Proponents" on behalf of the Estate of FRED C.
TRUMP agree to assume.
(b) Probate Proceeding- Estate of MARY ANNE TRUMP

(i) Fred C. Trump III No Consideration
(ii) Mary L. Trump No Consideration
(c) Supreme Court. State of New York- Nassau County (Index No. 6795/00)
(i) Fred C. Trump Ill No Consideration
except as set forth in Paragraph 11
(ii) Mary L. Trump No Consideration
(iii) Linda C. Trump No Consideration
16
(iv) Lisa Trump No Consideration
FRED C. TRUMP, III and LISA TRUMP also appeared herein

"...as parent and natural guardian of WILLIAM TRUMP, an infant under
the age of 18 years".
(d) Midland Associates Group (Interests terminated as of December 31, 2000)

(i) Fred C. Trump III $1,700,000.00
(ii) Mary L. Trump 1.700.000.00

Total $3.400.000.00
The Total Purchase Price of $3,400,000.00 should be allocated as follows:

1. Highlander Hall, Inc. $ 850,000.00
2. Coronet Hall, Inc. 850,000.00
3. Park Briar Associates , LLC 850,000.00
4, Midland Associates, LLC 850,000,00
$3.400.000.00
(e) Ground Lease a
(i) Fred C. Trump III $ 100,000.00
(ii) Mary L. Trump $ 100.000.00

Total $ 200,000.00
(f) 1976 Trust Agreements

Fred C. Trump III- a Successor Trustee
(i) Designating
Transfer to Trustee (Net) $ 824,934.00
L. Trump - Trust terminated
(ii) Mary
Total Assets (Net) $ 778.254,00
Total $1,603,188.00
CONSIDERATION
17. The parties hereto agree that they shall each be responsible for their own
attorney's fees, as well as costs and disburseñ1eids.
"Objectaiits" "Proponents"
18. and agree to execute and exchange mutual general
releases upon the signing of this Agreement in the form annexed hereto as Exhibit ___ which
17
will be held in escrow by respective counsel pending full payment of all of the monetary
provisions set forth herein.
19. The parties hereto agree that the provisions hereof are binding upon them
individually and in their capacity as preliminary executors, trustees and as controlling partners of
the partnerships set forth herein as well as officers and directors of the named corporate
"Defendants".
20. The parties hereto agree to execute any and all instruments and to perform
any and all acts that may from time to time be· deemed necessary or proper to give full force and
effect to the terms of this Agreement and Stipulation and authorize their counsel to do so on their
behalf and at their own respective expense.
21. This Agreement shall be binding upon and insure to the benefit of the heirs,
successors, administrators, executors and assigns of the parties, partnership or corporate entities.
22. The parties agree that each has had sufficient opportunity to review this
Agreement and Stipulation with their attorney and each executes this instrument after due
consideration and of his or her own volition.
23. This instrument may be executed in one or more counterparts, each of which
will be deemed an original, but all of which together shall be deemed to constitute one and the
same instrument.
24. The execution ofthis Agreement and Stipulation is being completed on a
voluntary basis and each party represents that they were under no compulsion to execute this
agreement and they have been fully advised throughout the negotiations to resolve their
differences between the parties as to all negotiations and representations made to each other as
well as to the Court.
18
25. It is agreed that the Queens County Surrogate's Court shall retain jurisdiction
over all parties to this Agreement and Stipulation in order to implement and carry out any of the
terms of his Agreement and Stipulation.
26. Neither this Settlement Agreement, nor any provision hereof, shall be
amended or modified, except by an agreement in writing duly subscribed and acknowledged in
the form to entitle a deed to be recorded by each of the parties hereto with the same formality as
this settlement Agreement and Stipulation.
27. This Agreement and Stipulation shall be constmed in all respects by the Jaw
of the State of New York.
19
IN WITNESS WHEREOF, the unders ned have exec ed this A ement and
Stipulation as of the date and year first above written
J. TR P
ROBERT S. TRUMP
- .
MARYA E TRU P BA
FRED C. TRUMP, III
MARY L. TRUMP
LINDA C. TRUMP
LISA TRUMP
20
IN WITNESS WHEREOF, the undersigned have executed this Agreement and
Stipulation as of the date and year first above written.
DONALD J. TRUMP
ROBERTS. TRUMP
MARYANNE TRUMP BARRY
....
MARY L. TRUMP
LINDA C. TRUMP
LISA TRUMP
20
IN WITNESS WHEREOF, the undersigned have executed this Agreernent and
Stipulation as of the date and year first above written.
DONALD J. TRUMP
ROBERT S. TICUMP
MARYANNÈ TRUMP BARRY
FRED C 11
Mßft TRUM
LINDA C. TRUMP
LISA TRUMP
20
Escrowee: FARRELL FRITZ, P.C.
by/& fo :
LOUIS D. LAURINO, ESQ. ffN J. B USkŸ .
½TÉPHEN J. S ARTZ, ESQ.
DURBEN & TOSTI
ppf77 aWLf¬OF WWC/f 5 Wøf 77
by: I IN DURBEN, ESQ.
G B R , P,C.
21
STATE OF NEW YO )
)SS.:
COUNTY OF )
On the day of Ê / in the year 2001, before me, the undersigned, personally
appeared DONALD J. TRUMP, peasonally known to me or proved to me on the basis of
satisfactory evidence to be the individual whose name is subscribed to the within instrurnent and
acknowledged to me that he executed the same in his capacit , that by his s nature on the
instrument, the individual, or the person upon behalf of wh 1 the in ividual ted, ecuted the
instrument.
Notary Public
LOUls D.tAURMO
Noisy Pubb Stato of How
York
Na 4905194
_STATE OF NEW YORK Comm AW

) gr
)SS.:
COUNTY OF )
On the day of in the year 2001, before me, the undersigned, personally
appeared ROBERT S. TRUMP, personally known to me or proved to me on the basis of
satisfactory evidence to be the individual whose name is subscribed to the within instrument and
acknowledged to me that he executed the same in his capacity that by his gnal e on the
instrument, the individual, or the person upon behalf of whic the in ividual a ted, ex cuted the
instrument.
Pu
Notary 0. LAm
Nowy FabHe, State of New Yd
STATE OF NEW YORK

No. 4995194
QuaWied In Nassau County pV
) Comadssion Expires Apri 20,yW
)SS.:
COUNTY OF )
On the day of // L in the year 2001, before me, the undersigned, personally
appeared MARYANNE TRUMP BARRY, personally known to me or proved to me on the basis
of satisfactory evidence to be the individual whose name is subscribed to the within instrument
and aeleiowledged to me that she executed the same in her capacit and that by her signature on
the instrurnent, the individual, or the person upon behalf of w ch the ndividual , executed
the instrument.
Notary Public t.00tS D. LAURINO

Nowy Path State of New
Yd
No. 4995194
CommW E W..
22
STATE OF NEW YORK )
)SS.:
COUNTY OF 45$4 )
On the day of A rd in the year 2001, before me, the undersigned, personally
appeared RED C. TRU P, IH personally known to me or proved to me on the basis of
satisfactory evidence to be the individual whose name is subscribed to the within instrurnent and
acknowledged to me that he executed the same in his capacity, and that by his signature on the
instrument, the individual, or the person upon behalf of ht h the individual acted, executed the
instrument,
JOHN J. BARNOSKY
Public, State of NewYork
Notary
No. 02BA0167250 Y4 (ary Publ
Qualified in Suffolk County -
Commission Expires February 28, 20 2
STATE OF NEW YORK )

)SS.:
COUNTY OF |Ù ¾¾½)
On the day of rt | in the year 2001, before me, the undersigned, personally
appeared ARY L. TRUMP, personally known to me or proved to me on the basis of
satisfactory evidence to be the individual whose name is subscribed to the within instrument and
acknowledged to me that she executed the same in her capacity, and that by her signature on the
instrument, the individual, or the person upon behalf of ich the individual acted, executed the
instrument.
JOHN J. P.®!0FKV
Public. % .
Notary t wor 7 A
No. 023 P v. . / /(
ouaste . :
atý Publ
Commissior. ept c... ..3, 2
STATE OF
)SS.:
COUNTY OF DG / c
..
On the of April in the year before me, the undersigned,

day 2001, personally
appeared LINDA C. TRUMP, known to me or proved to me on the basis of
personally
evidence to be the individual whose narne is subscribed to the within instrument and
satisfactory
acknowledged to me that she executed the same in her capacity, and that by her signature on the
instrument, the individual, or the person upon behalf of which the individual acted, executed the
instrument, and th t such individual made such appearance b ore the undersigned
in the 41-ey of 120ctuvCE./oAV/V , State of .
assachtÅsey
Notary Publi
23
STATE OF CONNBCTICUT )
)SS.:
COUNTY OF FaittF, e/ )
On the day of April in the year 2001 before me, the undersigned, personally appeared LISA
TRUMP, personally known to me or proved to me on the basis of satisfactory evidence to be the
individual(s) whose name(s) is (are) aubscribed to the within instrument and acknowledged to me
that she executed the same in her capacity(ies), and that by her signature(s) on the instrurnent, the
individual(s), or the person upon behalf of which the individual(s) acted, executed the instrument,
and that such individual made such appearance b ore the undersigned in the City of
State of Connecticut.
Notary Public
COMMISSION OF DEEDS
SEAL
OFFICIAL
STATE OF CONN,
COUNTY OF FAIBFT
EXHIBIT "AA"
T -ESTATE ACCOUNT No'000153
-2/21o
11 WEST 2ND STREET cuscuoATE CHECK AMOUNT
ROOKLYN, NY 11223
BATCH CD-26238
. 04/26/01 $***962,500.00
NINE HUNDRED SIXTY TWO THOU IV f)OLLARS and 00/100
. o o?REOF FRED C I & L, FRITZ
PAVABLE AT:
CHASE NABNATTAN BANK

270 PARK AVENUB
NEN YORR., NY 10017
a r0004E1F i:02100002hi:2 1 ? . 5 le
CT -ESTATE ACCOUNT 2/21o

. . emana0UNT
. 611 9fEST 2ND STREET .. . .
ROOKLYN, ·NY 11223
CD¬26238 ***962,500 00
BATCH ji 04/26/01
and 00/100
FI
DOLLARS
HUNDRED SIXTY TWO THOU
NINE
F FRITZ
MARY L P
d o or
PAYABLE AT
· CHAss MANHATTANBANK - -
27o PAax avenus
HEN YORK, NY 10017
u:0210000211·...10 7
PODOL5he
No.
MIDLAN·SOC~TE,. ~ 002232 o'
'\_ ..:> 1-2/210
611 WEST 2ND STREET

j BROOKLYN, NY 11223
&!:I '-~)
ts-..;: 0\Q0
~
~
o
If')
... CHECK DATE CHECK AMOUNT
CD-26146 1::
~ ><~!l ' ' 04/09/01 $***425,000.00
)Av FOUR HUNDRED TWENTY FIVE ~D jLJ~d 00/100
:)AYABLE AT:
TO THE
ORDER OF
MARY tf"'~ ;aL

:1t~
8
THE CHASE MANHATTAN BANK, N.A.
161-10 JAMAICA AVENUE
JAMAICA, NY 11432 .. ;~A
:;, ; 1... ~ ..=o.~
1"02~ •:021o000021oi:'H0 2 75"',·~.:;1•
;: ·~.: ...: :
No. 002,385
l-2/210
'CHECK DATE CHECK AMOUNT
04/09/01 $***425,000.00
~AY FOUR, HUNDRED TWENTY and 00/100

TO THE
ORDER OF
PAYABLE AT:
CHASE MANHATTAN BANK

401 MADISON AVENUE
NEW YORK, NY 10017 ~-"'
11"00 2 ~8 511• •:O 21.0000 21o1:00b 0 ~ fJ:-:.· :.;~ ~·
·~ '"; - .-:-·· '·' .

•.··
•'-'
. • :_:·
' ... ::;:::-:··
• <•• .·.;
"
.·;:·
:.: ·.
' ::.:..·.;·[;·, ',
..·. ·:·;'
..'CORONET HALL No.
002411
~ I~sl ~ ·~
1-2/210
611 ' v<EST 2ND STREET CHECK DATE CHECK AMOUNT
~
BROOKLYN, NY'i1223
BATCH CD-26146
04/09/01 $***425,000.00
IQ"' = -g~.
rAY FOUR HUNDRED TWENTY FIVE TH~m ~L ~hd 00/100
TO THE
ORDER OF MARY L~p ·~
PAYABLE AT'
~It: I ~ ~i vJ~
§~8 ~
.~h
401 MADISON AVENUE
:llw .....tb
.. u
..
NEW YORK, NY 10017 ·--- _U'A,a•e
1..,
n•oo 2 .. ~ ~· 1:0 2 ~DO 2 ~: 25 ~ 0 ~;: ' '•. ·.·'~:c;1• ... :'

·~-.,_ •."-""" -.,~'"•=<7· >c• ·:r·-------.-. ·•-"~;:',
... £0 No. 002888

pj . . · .•
2NP. STREET · . ~.·
, NY 11223 · CCI
~
g ·
CHECK DATE·
1-2/210
CHECK AMOUNT
-26146 .~ 0 ·•
~
$***425,000.00
)AY I
FOUR. HUNDRED TWENTY FIVE THO;,
~f
TO THE
~
ORDER OF
'AYABLE AT:

=&
401 MADISON AVENUE
NEW YORK, NY 10017
:llw
_u ~-'J --- ..
--w~ .r~-
n•oo 2888n• •:O 2 ~DO 2 ~: 25 ~ 0 -u•

:•,
;,•
••• : \<>'
-:·
·..
... .;· ..,.
'• ··.•
..::·. ·'·,·i.:}'< ..::c:i

'
No.
VILLAGE 000838
1-2/210
"2ND. STREET CHECK DATE CHECK AMOUNT
J\ly 11223
26146'
..
94/09/01 $***762,035.10
)Av
SEVEN HUNDRED SIXTY TWO and 10/100
TO THE
ORDER OF
'AYABLE AT:
~h.
401 MADISON AVENUE
NEW YORK, NY 10017
·-.N:~
u•ooo8 :>811' •:o 2 1.oooo 2 1.•: 2 51. o 2 ·:,·,::::

•' '·'
· ·-:~mo<ti1;=lW!JU>'?r.,vshYP"C_ -_,.~·";' •·· ':-~ ~- ·--· .. ··---;-.....-::-:--····-· -----·-·----
No.
002233
1-2/210
2l'JD STREET CHECK AMOUNT
~<IlROKLYN, NY 11223
-2614.6
$***100,000.00
,AY
ONE HUNDRED THOUSAND
TO THE
0
ORDER OF MARY. L., et:::
'AYABLE AT: ""'
<C
<~ _-_ ~ ..;:>~- ~-

THE CHASE MANHATTAN BANK, N .A.
161-10 JAMAICA AVENUE
JAMAICA, NY 11432
u•oo 2 2:! :Ill' •:o 2 1.0000 2 ··= 9 1.0 2 7 5;-~:•\.tu ··' ' ,.
···------"'· -~ ...._, _______ ,______ .c--- .·; ...,.,. -,,.,------------· --
'/.
"·"
·,• .
..;;
"'
..-::
'.,/'.' <:,._,;:;(: .·.·
"BB"
EXHIBIT
- Individual
‰tancyDeedWithFullCovenants orCorporation
(SingleSheet)
CONSULT YOUR LAWY ER BEFORE SIGNING THIS INSTRUMENT-THIS INSTRUMENT SHOULD BE USED BY LAWYERS ONLY
THIS made the in the year two thoussnul and one

INDENTURE, day of April,
BETWEEN, MARY LEA TRUMP, residing at 52 Davison Place, Rockville Centre, New York I 1570, as to her
undivided ten oercent (10%) interest in the property,
party of the first part, and
2"d NefC
MIDLAND ASSOCIATES LLC, having its principal place of be en at 261 1 West Street, Brooklyn,
York U1
11223,
party of the second part,
WITNESSETH, that the party ofthe first part, in consideration of Ten Dollars and other valuable consideration paid >
by the party of the second part, does hereby grant and release unto the party of the second part, the heirs or
successors and assigns of the party of the second part forever,
co
AS TO AN UNDIVIDED TEN PERCENT (10%) INTEREST IN:
ALL that certain plot, piece or parcel of land, with the buildings and liiipr0voments thereon erected, situate, lying
and being in the
Block Lot
7216 38
SEE ATTACHED SCHEDULE A
7238 2
7237' '
2
7238' '
82
7235' 1 -
'
7234 100
7234 150
1'
7234 : BEING the same property eciiveyed to the party of the first part by Deed dated October 18, 1995 and recorded in
7232 70 the County Clerk's Office of the City Register in Liber 3598, Page 2006 of Deeds.
7232 -
Bl
7233'
21
TOGETHER with aII right, title and interest, if any, of the party of the first part in and to any streets and roads
2
abuMing the above described premises to the center lines thereof; TOGETHER with the appurtenances and all lhe
l- estate and rights ofthe party ofthe first part in and to said premises; TO HAVE AND TO HOLD the premises herein
7231 .
24 granted unto the party of the second part, the heirs or successors and assigns of the party of the second part forever
7233
7233 I15
7212'
. 104 AND the party of the first part, in compliance with Section 13 of the Lien Law, covenants that the party of the first
/'
7214 39 part will receive the ceiisideraticü for this cúiiveyâiice and will hold the right to receive such consideration as a trust
fund to be applied first for the purpose of paying the cost ofthe imprevement and will
apply the same to the payment
of the cost of the improvement before using any part of the total of the same for any other purpose.
"party" "parties"
The word shall be construed as if it read wheilever the sense of this indenture so requires.
IN WITNESS WHEREOF, the party of the first part has duly executed this deed the day and year first above
written.
IN PRESENCE OF
MARŸ TRUMP
York ) State of New York )
S5oR/) ss: County of ) ss:
of April, 2001, before me, the undersigned, On the day of , 2001, before me, the
appeared MARY LEA TRUMP, personally undersigned, personally appeared , personally
to me or proved to me on the basis of satisfactory known to me or proved to me on the basis of satisfactory
ce to be the individual whose name is subscribed to evidence to be the individual(s) whose name(s) is (are)
ithin instrument and acknowledged to me that he subscribed to the within instrument and acknowledged to
cuted the same in his capacity, and that by his signature me that he/she/they executed the same in his/her/their
ri the instrument, the individual or the person upon behalf capacity(ies), and that by his/her/their signature(s) on the
of which th individual acted, executed the instr ument. instrument, the individual(s), or the person upon behalf of
which the individual(s) acted, executed the instrument.
(Signatur a 1 offic individual taking (Signature and office of individual taking

acknowl dgment) acknowledgment)
JOHN
J. BARNOSKY
Notary
No. 02BA0167250
Oualified in Suffolk County
Commission -0
Expires February 28, 2002
C3
COUNTY KINGS
WARRANTY DEED BLOCK LOT BLOCK LOT

WITH FULL COVENANTS 7216 38 7232 El
7238 2 7233 21
7237 2 7233 210
Title No. 7238 82 7233 225
7235 1 7232.
MARY LEA TRUMP 7234 100 7233 211
7234 150 7233 // 5
TO 7234 1 7212 109
7232 70 7214 39
MIDLAND ASSOCIATES LLC
RETURN BY MAIL TO:
LAURINO & LAURINO, ESQS.

229 Seventh Street
O
SCHEDULE A
ALL that certain plot, piece or parcel of land, with the buildings and improvements thereon erected,
situate, lying and being in the Borough of Brooklyn, of Kings, and State of New
County City York,
and more particularly bounded and described as follows:
PARCEL 1
BEGINNING at the corner formed by the intersection of the northerly side of Avenue 7. and the
easterly side of West Street; running thence northerly along the easterly side of West Street, 160 feet;
running thence easterly parallel with Avenue Z, 100 feet; running thence southerly and parallel with
West Street, 40 feet; running thence easterly parallel with Avenue Z, 100 feet to the westerly side
of East First Street; running thence southerly along the westerly side of East First Street, 120 feet to
the northerly side of Avenue Z; and running thence westerly along the northerly side of Avenue Z,
200 feet to the corner, the point or place of BEGINNING.
PARCEL 2
BEGINNING at the corner formed by the intersection of the southerly side of Avenue 7-, and the
easterly side of West Street; running thence easterly along the southerly side of Avenue 7., 460 feet;
running thence southerly parallel with West Street, 200 feet to the northerly side ofMurdock Court;
running thence westerly along the northerly side of Murdock Court, 460 feet to the easterly side of
West Street; and running thence northerly along the easterly side of West Street, 200 feet to the
corner, the point or place of BEGINNING.
PARCEL 3
BEGINNING at the corner formed by the intersection of the southerly side of Murdock Court and
the easterly side of West Street; running thence easterly along the southerly side of Murdock Court
460 feet; running thence southerly parallel with West Street 200 feet to the northerly side of Nixon
Court; running thence westerly along the northerly side of Nixon Court 460 feet to the easterly side
of West Street; and running thence northerly along the easterly side of West Street 200 feet to the
PARCEL 4
BEGINNING at the corner formed by the intersection of the southerly side of Nixon Court and the
easterly side of West Street; running thence easterly along the southerly side of Nixon Court 460
feet; running thence southerly parallel with West Street 52.83 feet to the northerly side of Shore
Parkway; running thence southwesterly along the northerly side of Shore Parkway 494.78 feet to the
easterly side of West Street; and running thence northerly along the easterly side of West Street 235
feet to the corner, the point or place of BEGINNING.
PARCEL 5
BEGINNING at the corner formed by the intersection of the southerly side of Avenue Z with the
westerly side of West Street; running thence westerly along the southerly side of Avenue Z, 200 feet
to the easterly side of West First Street; running thence southerly along the east side of West First
Street 752.05 feet to the north side of Shore Parkway; running thence easterly along the north side
of Shore Parkway, 200.09 feet to the west side of West Street; running thence northerly along the
west side of West Street, 758.17 feet to the corner, the point or place of BEGINNING.
PARCEL 6
BEGINNING at the corner formed by the intersection of the south side of Avenue 7, with the west
side of West First Street; running thence west along the south side of Avenue Z, 200 feet to the east
side of West Second Street; running thence south along the east side of West Second Street, 767.27
feet to the north side of Shore Parkway; running thence east along the north side of Shore Parkway,
200.73 feet to the west side of West First Street; running thence north along the west side of West
First Street, 750.21 feet to the corner, the point or place of BEGINNING.
L ONO WO\a
ARCEL 7
BEGINNING at the corner formed by the intersection of the north side of Avenue Z with the west
side of West First Street; running thence west along the north side of Avenue Z, 200 feet to the east
side of West Second Street; running thence north along the east side of West Second Street, 100 feet;
running thence east parallel with Avenue Z, 200 feet to the west side of West First Street; and
running thence south along the west side of West First Street, 100 feet to the corner, the point or
place of BEGINNING.
PARCEL 8
BEGINNING at the corner formed by the intersection of the south side of Avenue Z with the west
side of West Second Street; running thence west along the south side of Avenue Z, 200 feet to the
east side of West Third Street; running thence south along the east side of West Third Street, 789.45
feet to the north side of Shore Parkway; running thence east along the north side of Shore Parkway,
200.73 feet to the west side of West Second Street; running thence north along the west side of West
Second Street, 772.39 feet to the corner, the point or place of BEGINNING.
PARCEL 9
BEGINNING at the corner formed by the intersection of the north side of Avenue 7 with the west
side of West Third Street; running thence west along the north side of Avenue Z, 416.71 feet to the
land of the Brooklyn City Railroad, running thence north along the land of the Brooklyn City
Railroad, 225.96 feet to the center line of Dank Court; running thence easterly along the center line
of Dank Court, 396 feet, more or less, to the west side of West Third Street; running thence southerly
along the west side of West Third Street, 225 feet to the corner, the point or place of BEGINNING.
PARCEL 10
BEGINNING at the corner formed by the intersection of the south side o f Avenue Z with the west
side of West Third Street; running thence west along the south side of Avenue Z, 424.57 feet to the
land of Brooklyn City Railroad; running thence south along the land of the Brooklyn City Railroad,
230.97 feet, more or less, to the center line of Atwater Court (proposed); running thence casterly
along the center line of Atwater Court (proposed) 447 feet; more or less, to the westerly side of West
Third Street; running thence northerly along the westerly side of West Third Street, 230 feet to the
PARCEL 11
BEGINNING at a point on the easterly side of Shell Road, 150 feet south of the corner formed by
the intersection of the easterly side of Shell Road and the southerly side of Avenue Z; running thence
easterly at right angles to Shell Road, 92.83 feet to land of Brooklyn City Railroad; running thence
southerly and along the land of Brooklyn City Railroad, 273.02 feet;running thence westerly and at
right angles to Shell Road 116.43 feet to the easterly side of Shell Road; running thence northerly
and along the easterly side of Shell Road, 272 feet to the point or place of BEGINNING.
PARCEL 12
BEGINNING at the point formed by the intersection of the west side of West Third Street with the
center Ene of Atwater Court (proposed); running thence westerly along the center line of Atwater
Court (proposed), 447 feet, more or less, to the land of the Brooklyn City Railroad; running thence
south along the land of the Brooklyn City Railroad, 610.58 feet, more or less, to the north side of
Shore Parkway; running thence east along the north side of Shore Parkway, 508.51 feet, more or less,
to the west side of West Third Street; running thence north along the west side of West Third Street,
564.56 feet to the center line of Atwater Court (proposed) to the point or place of BEGINNING.
PARCEL 13
BEGINNING at a point on the easterly side of Shell Road, distant 422 feet south of the corner
formed by the intersection of the easterly side of Shell Road with the southerly side of Avenue Z;
running thence easterly at right angles to Shell Road, I 16.43 feet to the land of the Brooklyn City
2
Wananty - indMdualorCorporation
DecdWithfull Covenants (Singlesheet)
CONSULT YOUR LAWYER BEFORE SIGNING THIS INSTRUMENT-THIS INSTRUMENT SHOULD BE USED BY LAWYERS ONLY
THIS INDENTURE, made the day of April, in the year two thousand and one
BETWEEN, MARY LEA TRUMP, residing at 52 Davison Place, Rockville Centre, New York 11570, as to her
undivided five percent (5%) interest in the property,
party of the first part, and
2d
MIDLAND ASSOCIATES LLC, having its principal place of business at 2611 West Street, Brooklyn, New
York 11223,
party of the second part,
WITNESSETH, that the party of the first part, in consideration of Ten Dollars and other valuatic consideration paid
the party of the second part, does hereby grant and release unto the party of the second part, the heirs or
by
successors and assigns of the party of the second part forever,
AS TO AN UNDIVIDED FIVE PERCENT (S%) INTESEST IN: O
ALL that certain plot, piece or parcel of land, with the buildings and improvements thereon erected, situate, lying
and being in the
Block Lot
6469 1
6467 12 SEE ATTACHED SCHEDULE A
6489 1
BEING the same property ccñveyed to the party of the first part by Deed dated October 18, 1995 and reccidcd in
the County Clerk's Office of the City Register in Liber 3598, Page 2001 of Deeds.
SAID PREMISES being known as 20-34 to 20-78 Cropsey Avenue, Brooklyn, New York.
TOGETHER with all right, title and interest, if any, of the party of the first part in and to any streets and roads
ahatting the above described premises to the center lines thereof; TOGETHER with the appanêñances and all the
estate and rights ofthe party ofthe first part in and to said premises; TO HAVE AND TO HOLD the premises herein
granted unto the party of the second part, the heirs or successers and assigns of the party of the second part forever
AND the party of the first part, in compliance with Section 13 of the Lien Law, covenants that the party of the first
part will receive the consideratica for this conveyañca and will hold the right to receive such consideration as a trust
fund to be applied first for the purpose of paying the cost of the improvement and will
apply the same to the payment
of the cost of the improvement before using any part of the total of the same for any other purpose.
"party" "parties"
The word shall be construed as if it read whenever the sense of this indenture so requires.
IN WITNESS WHEREOF, the party of the first part has duly executed this deed the day and year first above
written.
IN PRESENCE OF
MA1( TRUl P
State of New York ) . State of New York )
County of rge,s3.9 ) ss: County of ) ss:
On the 7 y of April, 2001, before me, the undersigned, On the day of , 2001, before me, the ,
personally appeared MARY LEA TRUMP, personally undersigned, personally appeared , personally
known to me or proved to me on the basis of satisfactory known to me or proved to me on the basis of satisfactory
evidence to be the individual whose name is subscribed to evidence to be the individual(s) whose name(s) is (are)
the within instrument and acknowledged to me that he subscribed to the within instrument and acknowledged to
executed the same in his capacity, and that by his signature me that he/she/they executed the same in his/her/their
on the instrument, the individual or the person upon behalf capacity(ies), and that by his/her/their signature(s) on the
of whic e individual acted, executed the instrument. instrument, the individüâl(s), or the person upon behalf of
which the individual(s) acted, executed the instrument.
(Si tdEe En off of ndiv i (Signature and office of individual taking

ac owledgment) acknowledgment)
JOHNJ. BARNOSKY
NotaryPublic, State of NewWrk
No. 02BA0167250
Commission Expires February 28,2002
Parcel Parcel Parcel

A B C
WARRANTY DEED
WITH FULL COVENANTS
BLOCK 6469 6467 6489
LOT 1 12 1
Title No.
COUNTY KINOS KINGS KINGS

MARY LEA TRUMP
20-34 to 20-78 Cropsey Avenue

TO
MIDLAND ASSOCIATES LLC
RETURN BY MAIL TO:
LAURINO & LAURIN0, ESQS.

229 Seventh Street
O
ailroad; running thence southerly and along the land of the Brooklyn City Railroad, 273.02 feet to
a point; running thence westerly again at right angles to Shell Road, 140.04 feet to the easterly side
of Shell Road; running thence northerly along the easterly side of Shell Road, 272 feet to the point
or place of BEGINNING.
TOGETHER with all the right, title and interest, if any, of the Grantor, of, in and to the beds of the
streets, roads, avenues and lanes in front of and adjoining the above described premises to the
respective center lines thereof.
SUBJECT to covenants, restrictions, easements and agreements or records, if any, to the extent that
the same may affect said property; subject to leases ofrecord; and subject to taxes, water rates, sewer
charges and assessments, if any, affecting said property.
TOGETHER with the appurtenances and all the estate and rights of the party of the first part in and
to said premises.
3
BEACII IIAVEN APTS. NO. I - PARCEL 1: BLOCK 7216: 1,0T 38:
675 Avenue Z
BEACII IIAVEN APTS. NO. 1 - PARCEL 2: BLOCK 7238: I OT 2:

9 Murdock Court
29 Murdock Court
49 Murdock Court
BEACH IIAVEN APTS. NO. 1 - PARCEL 3: BLOCK 7238: I,0T 82:

9 Nixon Court
49 Nixon Court
BEACII IIAVEN APTS. NO. I - PARCEL 4: BLOCK 7237: LOT 2:

2775 Shore Parkway
2795 Shore Parkway
HEACII IIAVEN APTS. NO. 2 - PARCEL 5: BLOCK 7235: 1,OT 1:

2612 West Street
2634 West Street
2662 West Street
2684 West Street
BEACII IlAVEN APTS. NO. 3- PARCEL 6: BLOCK 7234:

2"d 2'"'
Lot 100: 2611 West Street Lot 150: 2661 West Street
2"d 2'"'
2631 West Street 2681 West Street
BEACH HAVEN A PTS. NO. 3 - PARCEL 7: BLOCK 7214: LOT 39:

621-27 Avenue Z
BEACH IlAVEN APTS. NO. 4 - PARCEL 8: BLOCK 7234: LOT 1:

2"d
2612 West Street
2"d
2632 West StFCel
2"d
2662 West Street
2"d
2682 West Street
BEACH IIAVEN APTS. NO. 5 - PARCEL 9: BLOCK 7212: LOT 104:

557 Avenue Z
BEACH IIAVEN APTS. NO. 5 - PARCEL 10: BLOCK 7232: LOT 81:
556 Avenue Z
BEACH HAVEN APTS. NO. 5 - PARCEL 11:

BLOCK 7232: LOT 70:
Vacant Land
BI,OCK 7233: LOT 225:
Vacant Land
BEACH HAVEN APTS. NO. 6 - PARCEL 12:

BLOCK 7232: LOT 1:
49 Bokee Court
BLOCK 7233: LOT 21:
1670 Shore Parkway
BLOCK 7233: LOT I15:
2651 Shore Parkway
BLOCK 7233: 1,0T 24:
Vacant Land
BEAC11 ItAVEN APTS. NO. 6 - PARe :EL 13: Bl.OCK 7233: 1,0T 210:
Vacant Land
Note: All Addresses Arc Brooklyn, New York 1 I223

EXHIBIT "CC"
WSLEGAtaCONTRACnTRUMPFC\ParkBrinrAsigIL
MtfyldE,dñG
ASSIGNMENT AND REDEMPTION AGREEMENT, made the __ day of , 2001,
by and between MARY LEA TRUMP (hereinafter referred to as "ASSIGNOR") and PARK BRIAR
ASSOCIATES, LLC (hereinafter referred to as "ASSIGNEE"); and
WHEREAS, Assignor is a Member in a New York Limited Liability Company known as Park
Briar Associates, LLC (hereinafter referred to as the "Limited Liability Company"); and
WHEREAS, Assignor is authorized to assign to the Assignee, and the Assignee has agreed to
redeem from the Assignor, the Membership interest of the Assignor, so that from and after the date of
this Assignment the Assignee will have the Assignor's Membership interest as hereinafter indicated; and
NOW THEREFORE, IT IS AGREED AS FOLLOWS:
1. Assignor hereby assigns to Assignee, PARK BRIAR ASSOCIATES, LLC, all of
Assignor's Ten (10%) Percent Membership interest and all of Assignor's rights therein and with respect
thereto, subject to the Operating Agreement of the Limited Liability Company and all of the teirms,
covenants and conditions thereof, and Assignee, PARK BRIAR ASSOCIATES, LLC, agrees to accept
the same. .
2. The said Assignee, PARK BRIAR ASSOCIATES, LLC, accepts the said interests hereby
assigned and redeemed by it subject to all coveñahts, terms, and conditions of the Operating Agreement of
the Limited Liability Company.
3. It is agreed that it is the Assignor's intention that the Assignee redeem Assignor's
Membership Interest in the Limited Liability Company, and the Assignee agrees to redeem said
Membership Interest.
.
IN WITNESS WHEREOF, the parties hereto have duly executed this Assignment and Agreement.
ASSIGNOR: ASSIGNEE:
. PARK BRIAR ASSOCIATES, LLC

By: .
WALEGAtaCONTRACBTRUMPFCtParkBriarAsign.Maryf.cz.4ge
STATE OF NEW YORK )

: ss.
COUNTY OF NASSAU )
On the day of m) in the year 2001, before me, the undersigned personally appeared
MARY LEA TRUMP, personally known to me or proved to me on the basis of satisfactory evidence to
be the individual whose name is subscribed to the within instrument and acknowledged to me that she
executed the same in her capacity, that by her signature on the instrument, the individual, or the person
upon behalf of which the individual acted, executed the instrument, and that such individual made such
appearance before the undersigned.
JOHN
J. BARNOSKY
.
Notary
No. 02BA0167250
Qualified in Suffolk
County
Commlesion Expires
February %% Y PUB /)
STATE OF NEW YORK )

: ss.
COUNTY OF )
On the day of in the year 2001, before me, the undersigned personally appeared
, Member of Park Briar Associates, LLC., personally known to me or
proved to me on the basis of satisfactory evidence to be the individual whose name is subscribed to the
within instrument and acknowledged to me that he executed the same in his capacity, that by his signature
on the instrument, the individual, or the person upon behalf of which the individual acted, executed the
instrument, and that such individual made such appearance before the undersigned.
NOTARY PUBLIC
WALEGAL
CONTRACT\TRUMPFCtbidiriarAnhra.MaryLca.doc
ASSIGNMENT AND REDEMPTION AGREEMENT, made the___ day of , 2001,
by and between MARY LEA TRUMP (hereinafter referred to as "ASSIGNOR") and PARK BRIAR
WHEREAS, Assignor is a Member in a New York Limited Liability Company known as Park
Briar Associates, LLC (hereinafter referred to as the "Limited Liability Company"); and
WHEREAS, Assignor is authorized to assign to the Assignee, and the Assignee has agreed to
1. Assignor hereby assigns to Assignee, PARK BRIAR ASSOCIATES, LLC, all of

Assignor's Ten (10%) Percent Membership interest and all of Assignor's rights therein and with respect
thereto, subject to the Operating Agreement of the Limited Liability Compaùy and all of the terms,
covenants and conditions thereof, and Assignee, PARK BRIAR ASSOCIATES, LLC, agrees to accept
the same. .
2. The said Assignee, PARK BRIAR ASSOCIATES, LLC, accepts the said interests hereby
assigned and redeemed by it subject to all covenants, terms, and conditions of the Operating Agreement of
ASSIGNOR: ASSIGNEE:
PARK BRIAR ASSOCIATES, LLC

By: .
MARY LEA TRUMP

WuLEGAUCONTRACT\TRUHPFCiParkBriacA.tign.MaryLea.th:
STATE OF NEW YORK )

: ss.
COUNTY OF NASSAU )
upon behalf of which the indiÓdual acted, executed the instrument, and that such individual made such
NOTARY PUBLIC
STATE OF NEW YORK )

. ss.
COUNTY OF )
On the day of ) L in the year 2001, before me, the undersigned personally appeared
Î'bF229,T
S. Tl20 H , Member of Park Briar Associates, LLC., g aunally known to me or
within instrument and acknowledged to me that he exa ted the same in his capacity, that by his signatate
instrument, and that such individual made such appearance efore the undersigned.
NOTARY PUBLIC
. LOUIS D, (AURINO
Notmy Pubile, State of New Yet
No. 4995194
Commissbn EWes Agil20J1
E.ca,gina
WALEGALtCONTRACUTRUMPTCMWlart|,AssigmMary
ASSIGNMENT AND REDEMPTION AGREEMENT, made the_day of , 2001,
by and between MARY LEA TRUMP (hereinafter referred to as "ASSIGNOR") and MIDLAND
WHEREAS, Assignor is a Member in a New York Limited Liability Company known as Midland
Associates, LLC (hereinafter referred to as the "Limited Liability Company"); and
WHEREAS, Assignor is authorized to assign to the Assigilee, and the Assignee.has agreed to
1. Assignor hereby assigns to Assignee, MIDLAND ASSOCIATES, LLC, all of Assignor's
Ten (10%) Percent Membership interest and all of Assignor's rights therein and with respect thereto,
subject to the Operating Agreement of the Limited Liability Compañy and all.of the terms;covenants and
conditions thereof, and Assignee, MIDLAND ASSOCIATES, LLC, agrees to accept the same.
2. The said Assignee, MIDLAND ASSOCIATES, LLC, accepts the said interests hereby .
assigñêd and redeemed by it subject to all covenants, terms, and conditions of the Operating Agreemêñtof
Membership Interest in the Limited Liability Compañy, and the Assignee agrees to redeem said
IN WITNESS WHEREOF, the parties hereto have duly exeæted this Assignment and Agreement.
ASSIGNOR: ASSIGNEE:
. MIDLAND ASSOCIATES, LLC

By:
MAR EA TRÚMP
W;\LEGALACONTRACEiñ
ú-éFCddlailami,n.MaryLeadoc
STATE OF NEW YORK )

: ss.
COUNTY OF NASSAU )
On the of r in the year before the undersigned appeared

† day
df 2001, me, personally
MARY LEA TRUMP, personally known to me or proved to me on the basis of satisfãctory evidence to
exem2+ëd the same in her capacity, that by her signature on the instrument, the individual, or the person
upon behalf of which the individual acted, executed the instrument, and that such individual made such
JOHN J. BARNOSKY
No. 02BA0167250
on Expires February 28,
N ARY PU C
STATE OF NEW YORK )

: ss.
COUNTY OF )
On the .. day of in the year 2001, before me, the undersigned personally appeared
, Member of Midland Associates, LLC., persoilally known.to me or
proved to me on the basis of satiáfactory evidence to be the individual whose name is subscribed to the
within instrument and acknowledged to me that he executed the same in his capacity, that by his signature
instrument, and that such individual made such appearance before the undersigned.
NOTARY PUBLIC
W6LEGAUCONTRACT\TRumFFCriidimé.A,nign.MayI.uake
ASSIGNMENT AND REDEMPTION AGREEMENT, made theÎ__ y of 2001,

by and between MARY LEA TRUMP (hereinafter referred to as "ASSIGNOR") and MIDLAND
WHEREAS, Assignor is a Member in a New York Limited Liability Company known as Midland
Associates, LLC (hereinafter referred to as the "Limited Liability Company"); and
WHEREAS, Assignor is authorized to assign to the Assignee, and the Assignee.has agreed to
1. Assignor hereby assigns to Assignee, MIDLAND ASSOCIATES, LLC, all of Assignor's
Ten (10%) Percent Membership interest and all of Assignor's rights therein and with respect thereto,
subject to the Operating Agreement of the Limited Liability.Company and all.of the termstcovenants and
conditions thereof, and Assignee, MIDLAND ASSOCIATES, LLC, agrees to accept the same.
2. The said Assignee, MIDLAND ASSOCIATES, LLC, accepts the said interests hereby .
assigned and redeemed by it subject to all covenants, terms, and conditions of the Operating Agreement of
3. It is agreed 'that it is the Assignor's intention that the Assignee redeem Assignor's
ASSIGNOR: ASSIGNEE:
MIDLAND ASSOCIATES, LLC

By:
w:\LEGAL1CONTRACATRUMPFC1Midland.Assign.Mary1ra.duc
STATE OF NEW YORK )

: ss.
COUNTY OF NASSAU )
upon behalf of which the individual acted, executed the instrament, and that such individual made such
NOTARY PUBLIC
-
STATE OF NEW YORK )
: ss.
COUNTY OF )
EET O , Member of Midland Associates, LLC., personally known to me or
within instrument and ackno wiedged to me that he executed the same in his capacity, that by his signature
instrument, and that such individual made such appearanc ore the unders ed.
NOTARY PUBLIC LOU1S D. LAORINO

State of New YA
dary Public,
No. 4995194
Qualified in Nassau Coudy
Connission Expkes Apd 20
WILEGALICORPISTOCKPWRITrump.M·•™
La"!¡;*dreaderHalidoc
..
IRREVOCABLE STOCK POWER
FOR VALUE RECEIVED, the undersigned does hereby sell, assign and transfer to
HIGHLANDER HALL, INC. eighteen (18) shares of the Common stock of HIGHLANDER
HALL, INC. represented by Certificate No. 29, standing in the name of Mary Lea Trump on
the books of said Corporation, being her entire interest in HIGHLANDER HALL, INC.
The undersigned does hereby irrevocably constitute and appoint Durben & Tosti, LLP
attorneys to transfer the said stock on the books of said Corporation, with full power of
substitution in the premises.
Dated: , 2001
MA1( A TRUMP
W£EGADCORPLSlUCKPWR\Tnc.;''--J'
--£:-seLdoc
IRREVOCABLE STOCK POWER
FOR VALUE RECEIVED, the undersigned does hereby sell, assign and transfer to
CORONET HALL, INC. twelve (12) shares of the Common stock of CORONET HALL, INC.
represented by Certificate No. 37, standing in the name of Mary Lea Trump on the books of said
Corporation, being her entire interest in CORONET HALL, INC.
The undersigned does hereby irrevocably constitüte and appoint Durben & Tosti, LLP
attorneys to transfer the said stock on the books of said Corporation, with full power of
substitution in the premises.
Dafed: , 2001
MARY TRUMP

Trump MTD

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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK: COMMERCIAL DIVISION

DONALD J. TRUMP, in his personal capacity,

seven (7) days before the return date hereof.

February 26, 2021.

Dated: Great Neck, New York

étine D. Kiley, Esq.

(516) 466-7903 Fax

TO: KAPLAN HECKER & FINK LLP

(212) 564-0883 Fax

GREENFIELD, STEIN & SENIOR LLP

State of New York, hereby affirms and states:

and negligent misrepresentation.

(6) Plaintiff’s claims of civil conspiracy to commit fraudulent misrepresentation and

Memorandum of Law filed herewith.

The Parties and their Shared Business Interests

ownership interests as the ‘Midland Interests”.

settled with Defendants in 2001.

Background of Prior Litigation

owned apartments in 1999 and 2000. (See Exhibit “K”)

Walter testified at a §1404 hearing on March 7, 2000. (Exhibit “O”)

(16) On August 7, 2000, Fred C. Trump’s wife, Mary A. Trump died.

defendants. (Exhibit “T”)

(20) On April 9, 2001, Plaintiff executed General Releases specifically releasing

stated in the Agreement and Stipulation. (Exhibit "AA'').

Hall, Inc. (Exhibit "CC")

herewith, Plaintiffs Complaint should be dismissed in its entirety.

WHEREFORE, your affirmant respectfully requests that the motion herein be

may be just and proper.

Affirmed: December 22,2010

H GHES, as Executor of THE ESTATE

Hon O. Peter Sherwood

DONALD J. TRUMP, in his personal capacity,

KILEY, KILEY & KILEY, PLLC

Attorney for Defendants

TABLE OF AUTHORITIES ………………………………………………………………… ii

FACTS MADE KNOWN TO PLAINTIFF IN THE PRIOR LITIGATION….…………... 6

I. POINT I: PLAINTIFF’S CLAIMS ARE BARRED BY THE STATUTE OF

A. Plaintiff’s Fraud Claims are Untimely………………………………………12

B. Plaintiff’s Claims for Breach of Fiduciary Duty and Aiding and

II. POINT II: PLAINTIFF’S CLAIMS ARE BARRED BY THE GENERAL

III. POINT III: PLAINTIFF LACKS STANDING TO ASSERT ANY

IV. POINT IV: PLAINTIFF’S PRE-SETTLEMENT CLAIMS FOR FRAUD,

V. POINT V: PLAINITFF’S CONSPIRACY CAUSES OF ACTION MUST

Accord Elghanian v. Harvey,

Appel v. Ford Motor Co.,

Armstrong v. Peat, Marwick, Mitchell & Co.,

Booth v. 3669 Delaware,

Carbon Capital Management, LLC v. American Express Co.,

Centro Empresarial Cempresa S.A. v. America Movil, S.A.B.,

Ciullo v. Orange and Rockland Util. Inc.,

D. Penguin Brothers Ltd. v. City National Bank,

EVEmeta LLC v. Siemens Convergence Creators Corp.,

Goldberg v. Manufacturers Life Ins. Co.,

High Tides, LLC v. DeMichele,

Hillman v. City of New York,

IDT Corp. v. Morgan Stanley Dean Witter & Co.,

Leider v. Amalgamated Dwellings, Inc.,

Lucas-Plaza Housing Development Corp. v. Corey,

Mamoon v. Dot Net Inc.,