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RECORD 1: THE STERLING 1994 IRREVOCABLE DYNASTY TRUST (EXCERPT)
ORIGINAL GRANTOR: ELEANOR V. STERLING | TRUSTEE: HARBOR TRUST COMPANY N.A.
EXECUTION DATE: NOVEMBER 18, 1994 | GOVERNING LAW: STATE OF DELAWARE
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ARTICLE IV: DISCRETIONARY DISTRIBUTIONS OF INCOME AND PRINCIPAL

Section 4.1. Ascertainable Standard for Primary Beneficiaries
During the lifetime of the Grantor’s son, Julian Sterling ("Primary Beneficiary"), 
the Corporate Trustee shall distribute to or for the benefit of Julian and his lineal 
descendants so much of the net income and principal as is necessary for their health, 
education, maintenance, and support (HEMS) in reasonable comfort, taking into account 
other financial resources reasonably available to them known to the Corporate Trustee.

Section 4.2. Mandatory Income Distribution Standard
Notwithstanding Section 4.1, following Julian Sterling's attainment of age thirty-five 
(35), the Trustee shall pay to Julian all of the net accounting income of Trust Share A 
in convenient installments, not less frequently than quarter-annually.

Section 4.3. Special Power of Appointment
Julian Sterling shall have the testamentary special power to appoint the remaining 
principal of Trust Share A to or among any one or more of the Grantor’s lineal 
descendants, outright or in trust, provided that Julian shall have no power to appoint 
any part of the trust estate to himself, his estate, his creditors, or the creditors 
of his estate.

ARTICLE VII: TAX ELECTIONS AND GENERATION-SKIPPING TRANSFER (GST) EXEMPTION

Section 7.2. GST Tax Inclusion Ratio Covenant
The Grantor directs that the Trustee and Grantor's personal representative shall 
allocate available Generation-Skipping Transfer (GST) tax exemption under Section 2631 
of the Internal Revenue Code such that Trust Share A shall at all times maintain an 
Inclusion Ratio of exactly zero (0.000). If the available exemption is insufficient to 
achieve a zero inclusion ratio, the Trustee shall divide the trust into two separate 
trusts: one with an inclusion ratio of zero (0) and one with an inclusion ratio of one (1).