CALDERWOOD & HARKNESS LLP Counselors at Law
375 Park Avenue, 42nd Floor New York, NY 10152
Telephone: (212) 506-7200 Facsimile: (212) 506-7299 www.calderwoodharkness.com
March 10, 2023
Rachel F. Dunlap, Esq. Partner, Private Client Pemberton, Locke & Strauss LLP 405 Lexington Avenue, 26th Floor New York, NY 10174
Re: Estate Plan for Jonathan R. Caldwell — Independent Review Materials for Eleanor V. Caldwell C&H Matter No. 1034-00004
Dear Ms. Dunlap:
I write on behalf of Calderwood & Harkness LLP, and in my capacity as Responsible Partner on this engagement, in connection with the comprehensive generational estate plan that our firm is currently designing and implementing for our client, Jonathan Robert Caldwell. As you know, during the course of our planning discussions with Mr. Caldwell, we recommended that his spouse, Eleanor V. Caldwell (née Whitmore), retain independent legal counsel to review the proposed estate plan structures and, in particular, the spousal consent and acknowledgment documents that the plan requires Mrs. Caldwell to execute. We understand that Mrs. Caldwell has engaged your firm, Pemberton, Locke & Strauss LLP, for this purpose, and we are pleased that she will have the benefit of your guidance throughout this process.
The purpose of this letter is to transmit to you the relevant draft documents for your review on Mrs. Caldwell's behalf. We have endeavored to provide you with sufficient background and context regarding the overall estate plan so that you may evaluate the enclosed drafts in light of Mrs. Caldwell's interests and advise her accordingly. For reference, Mrs. Caldwell resides with Mr. Caldwell at 418 East 72nd Street, Apt. 14A, New York, NY 10021.
I. Background — Overview of the Estate Plan
To orient your review, the following is a summary of the principal facts and circumstances that inform the estate planning structures currently under development.
A. Client Profile
Jonathan R. Caldwell (date of birth: March 14, 1956; age 67) is the founder and former Managing Partner of Caldwell Ridgeline Capital LLC, a New York-based asset management firm with approximately $2.1 billion in assets under management. Mr. Caldwell retired from active management of the firm in 2019 but retains significant carried-interest positions and limited partnership stakes in certain funds managed by the firm. In addition, Mr. Caldwell holds substantial direct real estate investments through Stonecrest Realty Holdings LLC, a New York limited liability company through which he owns interests in a diversified portfolio of commercial and residential properties located primarily in the New York metropolitan area and the Northeast.
B. Estimated Gross Estate
Based on valuations and estimates compiled as of year-end 2022 and updated through February 2023, Mr. Caldwell's estimated gross estate is approximately $300,000,000, comprising the following principal asset categories:
These figures are subject to revision based on updated appraisals and market conditions as of the relevant funding dates for each planning structure.
C. Marital and Family Information
Mr. and Mrs. Caldwell have been married since 1985. We note that all property held by Mr. Caldwell is separate property under New York law. There is no pre-nuptial or post-nuptial agreement between the spouses.
Eleanor V. Caldwell (date of birth: September 22, 1958; age 64) is a former partner of Whitmore-Langdon Gallery, which she co-founded and operated until its sale in 2017. She is currently active as a philanthropist with particular interests in arts education, cultural preservation, and pediatric medical research. Mrs. Caldwell holds separate assets of approximately $18,000,000, which are not part of this estate planning engagement.
The Caldwells have three adult children and four grandchildren:
1. Thomas R. Caldwell (age 38) — eldest son. Father of Lucas T. Caldwell (age 3) and Nora E. Caldwell (age 1).
2. Katherine C. Hartfield (age 35) — married to William A. Hartfield. Mother of James W. Hartfield (age 8) and Charlotte M. Hartfield (age 5).
3. Olivia G. Caldwell (age 30) — unmarried; no children.
D. Estate Plan Structure
Calderwood & Harkness LLP is designing and implementing a comprehensive estate plan for Mr. Caldwell that includes the following principal components:
(a) Three Grantor Retained Annuity Trusts ("GRATs"), designated as GRAT A (securities), GRAT B (real estate), and GRAT C (carried interest/LP interests);
(b) A dynasty trust (the "Caldwell Family Dynasty Trust"), established in Delaware and designed to receive the remainder interests from the GRATs upon their termination;
(c) A private family foundation (the "Caldwell Family Foundation"), to be funded jointly by Mr. and Mrs. Caldwell;
(d) An irrevocable life insurance trust (the "Caldwell Family Insurance Trust" or "ILIT"), holding a second-to-die universal life insurance policy; and
(e) Amendments to Mr. Caldwell's existing revocable trust and the execution of a new pour-over will.
E. Engagement Team
The Calderwood & Harkness engagement team for this matter consists of the following professionals:
• Victoria Chambers — Responsible Partner
• Howard Quinn — Billing Partner
• Monica Reyes — Lead Associate
• Elliot Nguyen — Working Associate
• Sylvia Hartwell — Specialist Partner, Tax
Ms. Reyes serves as the day-to-day contact for document-related inquiries, and Ms. Hartwell is available to address any tax-related questions that may arise during your review.
II. Description of Transmitted Documents
Set forth below is a description of each of the seven draft documents enclosed with this letter. We have organized these descriptions to highlight the provisions and features that are of particular relevance to Mrs. Caldwell's interests.
1. Draft Spousal Consent and Acknowledgment
Enclosed as Enclosure 1 is a draft written consent and acknowledgment to be executed by Eleanor V. Caldwell. This document constitutes Mrs. Caldwell's formal consent to all of the estate plan structures described in this letter, including the three GRATs, the Caldwell Family Dynasty Trust, the Caldwell Family Insurance Trust, the amended and restated Caldwell Revocable Trust, the pour-over will, and the Caldwell Family Foundation.
The spousal consent document addresses, among other things, Mrs. Caldwell's understanding and acknowledgment that certain of the estate plan structures will redirect assets that might otherwise be available to her as surviving spouse — most significantly, assets that would otherwise remain in Mr. Caldwell's estate and flow into the residuary estate of the revocable trust, from which the marital QTIP trust would be funded at Mr. Caldwell's death. The consent also recites that Mrs. Caldwell has been advised to seek, and has in fact obtained, independent legal counsel to review the estate plan and the consent document itself.
The draft contemplates execution on or about April 1, 2023, to be coordinated with the signing of the dynasty trust agreement, the amended and restated revocable trust agreement, and the new pour-over will. We believe it is important that the consent be executed simultaneously with these instruments so that all documents reflect a consistent understanding of Mrs. Caldwell's acknowledgment and agreement.
We would ask that you review the spousal consent document with particular care and advise us of any provisions that you believe should be modified, clarified, or supplemented to protect Mrs. Caldwell's interests. We are open to reasonable revisions that do not alter the fundamental planning objectives.
2. Amended and Restated Caldwell Revocable Trust Agreement (Draft)
Enclosed as Enclosure 2 is the draft Amended and Restated Caldwell Revocable Trust Agreement. The Caldwell Revocable Trust was originally established on October 3, 2010. It is being amended and restated in its entirety, with an effective date of April 1, 2023 (the restatement was formally drafted and dated February 6, 2023, and has been undergoing revisions since that date).
The settlor of the revocable trust is Jonathan R. Caldwell. The following provisions of the restated trust agreement are of particular relevance to Mrs. Caldwell's interests:
• Credit Shelter Trust. At Mr. Caldwell's death, a credit shelter trust (also referred to as the "Family Trust" or "Bypass Trust" in the agreement) will be funded in an amount equal to the then-applicable federal estate tax exemption amount. Mrs. Caldwell is the primary income beneficiary of the credit shelter trust and may receive discretionary distributions of principal for her health, education, maintenance, and support.
• Marital QTIP Trust. The balance of the trust estate, after funding the credit shelter trust, will pass to a marital QTIP trust qualifying for the federal estate tax marital deduction under IRC § 2056(b)(7). Mrs. Caldwell is the sole income beneficiary of the marital QTIP trust for her lifetime, with mandatory distributions of all net income at least quarterly.
• General Power of Appointment. Mrs. Caldwell holds a general power of appointment over the marital QTIP trust, exercisable by her last will and testament. In default of exercise, the trust estate passes to the Caldwell children and their issue per stirpes.
We draw your attention to the fact that the restatement is designed to coordinate with the new GRAT, dynasty trust, and foundation structures. Specifically, the assets contributed to the GRATs and the $5,000,000 direct gift to the dynasty trust will be removed from Mr. Caldwell's estate during his lifetime (assuming the GRATs perform as designed) and will therefore not be available to fund the revocable trust's residuary estate at Mr. Caldwell's death. This has a direct and potentially significant impact on the corpus available to fund the marital QTIP trust, and we respectfully suggest that this interaction be a focal point of your discussion with Mrs. Caldwell.
The revocable trust is governed by the laws of the State of New York.
3. Last Will and Testament of Jonathan R. Caldwell — Pour-Over Will (Draft)
Enclosed as Enclosure 3 is the draft Last Will and Testament of Jonathan R. Caldwell, structured as a pour-over will. This new will is intended to be executed on April 1, 2023, and upon execution it will revoke in its entirety the prior will dated October 3, 2010.
The pour-over will directs all probate assets of Mr. Caldwell's estate to the Caldwell Revocable Trust, to be administered and distributed in accordance with the terms of that trust as amended and restated. The will does not itself create any separate testamentary trusts; rather, it serves as the vehicle to capture any assets not otherwise titled in the revocable trust or transferred by beneficiary designation, joint tenancy, or other non-probate transfer mechanism.
The pour-over will names Eleanor V. Caldwell as executor of the estate and Thomas R. Caldwell as successor executor. It also includes provisions for the guardianship of minor grandchildren in the event that guardianship becomes applicable — a contingency provision designed to address the possibility that one or more of the Caldwell children predecease Mr. Caldwell while their minor children survive.
The pour-over will is governed by the laws of the State of New York and is intended to be admitted to probate in Surrogate's Court, New York County.
4. Caldwell 2023 Securities GRAT — Trust Agreement (GRAT A) (Draft)
Enclosed as Enclosure 4 is the draft trust agreement for the Caldwell 2023 Securities GRAT, designated herein as "GRAT A."
The material terms of GRAT A are as follows:
• Funding Date: On or about April 15, 2023.
• Funded Amount: $60,000,000 in publicly traded securities.
• Term: Two (2) years.
• Annuity Amount: $32,195,122 per year, calculated to produce a zeroed-out gift under IRC § 2702 at the applicable § 7520 rate of 5.0% (March 2023).
• Grantor and Trustee (during annuity term): Jonathan R. Caldwell.
• Remainder Beneficiary: Caldwell Family Dynasty Trust.
The key concern for Mrs. Caldwell in connection with GRAT A is that the assets contributed to this trust — $60,000,000 in publicly traded securities — will be removed from Mr. Caldwell's estate (and hence from the revocable trust's residuary estate that would otherwise fund the marital QTIP trust) if the GRAT succeeds — that is, if Mr. Caldwell survives the two-year annuity term and the trust assets appreciate in excess of the § 7520 hurdle rate. If GRAT A succeeds, the remainder interest will pass to the Caldwell Family Dynasty Trust, of which Mrs. Caldwell is not a named beneficiary.
5. Caldwell 2023 Realty GRAT — Trust Agreement (GRAT B) (Draft)
Enclosed as Enclosure 5 is the draft trust agreement for the Caldwell 2023 Realty GRAT, designated herein as "GRAT B."
The material terms of GRAT B are as follows:
• Funding Date: On or about May 1, 2023.
• Funded Amount: $80,000,000 in Stonecrest Realty Holdings LLC membership interests, representing approximately 59.7% of the total equity interest in Stonecrest (total entity value: $134,000,000).
• Term: Three (3) years.
• Annuity Amount: $29,375,859 per year, calculated to produce a zeroed-out gift under IRC § 2702 at the applicable § 7520 rate of 5.0% (April 2023).
• Valuation discounts: A combined 25% lack-of-marketability and lack-of-control discount is applied for gift tax purposes, yielding a funded fair market value of $60,000,000 for transfer tax purposes.
• Grantor and Trustee (during annuity term): Jonathan R. Caldwell.
• Remainder Beneficiary: Caldwell Family Dynasty Trust.
As with GRAT A, we note that the membership interests contributed to GRAT B represent a substantial portion of Mr. Caldwell's overall estate. If the GRAT succeeds upon the expiration of its three-year term, the remainder interest — potentially including significant appreciation in the Stonecrest real estate portfolio — will pass to the dynasty trust and will no longer be available to fund the marital QTIP trust for Mrs. Caldwell's benefit.
6. Caldwell 2023 Carried Interest GRAT — Trust Agreement (GRAT C) (Draft)
Enclosed as Enclosure 6 is the draft trust agreement for the Caldwell 2023 Carried Interest GRAT, designated herein as "GRAT C."
The material terms of GRAT C are as follows:
• Funding Date: On or about June 1, 2023.
• Funded Amount: $38,000,000 in limited partnership interests and carried-interest positions in Caldwell Ridgeline Capital Fund IV ($12,000,000), Fund V ($14,000,000), and Fund VI carried interest ($12,000,000).
• Term: Three (3) years.
• Annuity Amount: $13,953,759 per year, calculated to produce a zeroed-out gift under IRC § 2702 at the applicable § 7520 rate of 5.0% (May 2023).
• Valuation discounts: A blended discount is applied, yielding a post-discount fair market value of $25,300,000 for transfer tax purposes. The blended discount reflects a 35% discount on the limited partnership interests and a 30% discount on the carried-interest positions, reflecting the illiquidity, transferability restrictions, and lack of control inherent in these asset classes.
• Grantor and Trustee (during annuity term): Jonathan R. Caldwell.
• Remainder Beneficiary: Caldwell Family Dynasty Trust.
The same observation regarding the impact on the marital QTIP trust applies to GRAT C. The carried-interest positions in Caldwell Ridgeline Capital are among the assets with the highest potential for appreciation over the three-year term, particularly the Fund VI carried interest, which relates to a fund in the early stages of its investment period. To the extent these assets appreciate materially, the benefit of that appreciation will inure to the dynasty trust rather than to the marital QTIP trust.
7. Caldwell Family Dynasty Trust — Trust Agreement (Draft)
Enclosed as Enclosure 7 is the draft trust agreement for the Caldwell Family Dynasty Trust.
The material terms of the dynasty trust are as follows:
• Execution Date: April 1, 2023.
• Situs: Delaware. The trust is established under Delaware law and will take advantage of Delaware's perpetual trust statute (25 Del. C. § 503(a)), which abolishes the common-law rule against perpetuities for trusts governed by Delaware law. In addition, the Delaware situs is selected in order to benefit from Delaware's absence of state income tax on undistributed trust income for beneficiaries who reside outside of Delaware.
• Grantor: Jonathan R. Caldwell.
• Initial Funding: $5,000,000 in cash, constituting a direct gift utilizing a portion of Mr. Caldwell's remaining lifetime gift tax exemption. After this gift, Mr. Caldwell's remaining applicable exclusion amount will be reduced from $6,170,000 to approximately $1,170,000.
• Expected Additional Funding: Remainder interests upon termination of GRATs A, B, and C. If all three GRATs succeed and the underlying assets appreciate as projected, the dynasty trust could receive substantial additional funding over the next two to three years.
The governance and administration of the dynasty trust are structured as follows:
• Co-Trustees: Thomas R. Caldwell (serving as family trustee) and Northgate Trust Company of Delaware (serving as institutional trustee). The designated contact at Northgate is Philip A. Rossiter, SVP, Trust Administration, located at 1201 North Market Street, Suite 1600, Wilmington, Delaware 19801.
• Distribution Committee: Thomas R. Caldwell, Katherine C. Hartfield, and Olivia G. Caldwell. The Distribution Committee must unanimously approve any discretionary distribution exceeding $100,000 per beneficiary per calendar year.
• Distribution Standard: Distributions may be made for the health, education, maintenance, and support ("HEMS") of beneficiaries. Broader discretionary distributions — including distributions for purposes beyond HEMS — may be made with the approval of the Distribution Committee.
• Trust Protector: Victoria Chambers (serving in a non-fiduciary capacity), with powers to modify administrative provisions, change the trust situs, and remove and appoint trustees.
The beneficiaries of the dynasty trust are Thomas R. Caldwell, Katherine C. Hartfield, Olivia G. Caldwell, and their respective issue per stirpes. Spouses of beneficiaries are eligible for HEMS distributions only.
We wish to draw particular attention to Mrs. Caldwell's status relative to the dynasty trust. As a spouse of a beneficiary's parent — rather than a child of the grantor — Mrs. Caldwell is not a direct beneficiary of the dynasty trust. She is not eligible for any distributions from the trust, including HEMS distributions. We believe it is important for Mrs. Caldwell to understand that the dynasty trust's terms, as currently drafted, do not provide for her in any capacity. Moreover, because the dynasty trust is expected to receive the remainder interests from all three GRATs, the cumulative effect of the estate plan is to redirect a potentially substantial portion of Mr. Caldwell's estate away from the marital QTIP trust (which does benefit Mrs. Caldwell) and into the dynasty trust (which does not). Mrs. Caldwell should review with you whether the dynasty trust's terms, in conjunction with the other estate plan structures, adequately protect her interests as surviving spouse.
III. Summary of Mrs. Caldwell's Roles and Interests Across Plan Structures
For ease of reference, we have compiled the following summary of Mrs. Caldwell's roles, rights, and interests across the various estate plan structures:
1. Amended and Restated Caldwell Revocable Trust. Mrs. Caldwell is the primary income beneficiary of both the credit shelter trust and the marital QTIP trust funded at Mr. Caldwell's death. She holds a general power of appointment over the marital QTIP trust, exercisable by her last will and testament. The credit shelter trust provides for discretionary distributions to Mrs. Caldwell under a HEMS standard.
2. Caldwell Family Foundation. Mrs. Caldwell is a co-grantor of the Foundation, with $5,000,000 of the $10,000,000 initial cash contribution attributable to her. She is to serve as Vice President on the Foundation's board of directors.
3. Caldwell Family Insurance Trust (ILIT). Mrs. Caldwell is an insured life under the second-to-die universal life insurance policy (Beacon Life Assurance Company, Policy No. BLA-2023-77419) held by the ILIT. The policy provides a $15,000,000 death benefit payable upon the death of the second to die of Mr. and Mrs. Caldwell. The death benefit is payable outside of the taxable estates of both spouses.
4. Caldwell Family Dynasty Trust. Mrs. Caldwell is not a named beneficiary of the dynasty trust. Spouses of the grantor's children are eligible only for HEMS distributions from the trust; however, Mrs. Caldwell, as the grantor's spouse (rather than a spouse of a beneficiary), does not fall within this category.
5. Separate Assets. Mrs. Caldwell's separate assets of approximately $18,000,000 are not part of this engagement and are not affected by any of the structures described herein.
IV. Note Regarding Foundation Documents
Separately, we wish to advise you that the Caldwell Family Foundation was incorporated on March 20, 2023, under the New York Not-for-Profit Corporation Law (New York Department of State Filing No. 230320-001847; Employer Identification Number 88-3021547). Although the foundation's organizational documents — including its certificate of incorporation, bylaws, and conflict-of-interest policy — are not enclosed with this transmittal, as they are currently being finalized by our team, we intend to arrange for Mrs. Caldwell's review of her role as co-grantor and Vice President of the Foundation board through a subsequent transmittal. Alternatively, we can provide these documents to you upon request at any time.
For your general information, the initial cash contribution to the Foundation will be $10,000,000, split equally between the spouses ($5,000,000 from Mr. Caldwell and $5,000,000 from Mrs. Caldwell). The charitable income tax deduction for the aggregate $10,000,000 cash contribution is subject to the 30%-of-AGI limitation applicable to contributions to private foundations under IRC § 170(b)(1)(B). Based on Mr. Caldwell's estimated 2022 adjusted gross income of approximately $22,500,000, the deductible amount in the current tax year is limited to $6,750,000, with a carryforward of $3,250,000 available over the succeeding five tax years under IRC § 170(d)(1). Mrs. Caldwell's deduction will be determined separately based on her own adjusted gross income, and we understand she will address this with her personal tax advisors.
V. Note Regarding the ILIT
The Caldwell Family Insurance Trust was established on March 15, 2023. The grantor of the ILIT is Jonathan R. Caldwell, and the trustee is Northgate Trust Company of Delaware. The trust holds a $15,000,000 second-to-die universal life insurance policy issued by Beacon Life Assurance Company (Policy No. BLA-2023-77419). The annual premium on the policy is $187,500. The Crummey withdrawal right beneficiaries under the ILIT are Thomas R. Caldwell, Katherine C. Hartfield, and Olivia G. Caldwell, each of whom holds a $5,000 annual withdrawal right per calendar year.
A copy of the ILIT trust agreement is available upon request but is not enclosed with this transmittal, as Mrs. Caldwell's consent is not required for the ILIT itself. We note, however, that the ILIT and the life insurance policy are referenced in the draft spousal consent document (Enclosure 1), and Mrs. Caldwell should be aware that the policy is a second-to-die policy on the joint lives of Mr. and Mrs. Caldwell. No death benefit will be payable until the death of the surviving spouse.
VI. Request for Review and Coordination
We respectfully request that you review all of the enclosed draft documents with Mrs. Caldwell and advise us of any concerns, requested modifications, or questions that arise from your review. We are committed to ensuring that Mrs. Caldwell has a thorough understanding of the estate plan structures, her rights and interests under each, and the cumulative effect of the plan on the assets available for her benefit as surviving spouse.
We note that the target execution date for the spousal consent, the dynasty trust agreement, the amended and restated revocable trust agreement, and the pour-over will is April 1, 2023. The three GRAT trust agreements will follow on their respective anticipated funding dates: GRAT A on or about April 15, 2023; GRAT B on or about May 1, 2023; and GRAT C on or about June 1, 2023. We ask that you endeavor to complete your review and provide any comments on the spousal consent and the April 1 documents in sufficient time to allow us to address any issues before the target execution date.
In furtherance of an efficient review process, we would be pleased to schedule a meeting or telephone conference among Victoria Chambers, Sylvia Hartwell, yourself, and Mrs. Caldwell to discuss any issues arising from your review. We believe a collaborative discussion would be productive and would allow us to resolve any open questions in advance of the execution date. Please let us know your availability, and we will coordinate scheduling accordingly.
Finally, we wish to offer to provide any additional documents or materials that would be helpful for your review, including but not limited to the estate planning strategy memorandum prepared for Mr. Caldwell, the detailed tax analysis and projected transfer tax savings, and the sensitivity analysis modeling various appreciation scenarios for the GRAT assets. These materials were prepared in connection with our engagement for Mr. Caldwell, and while they are subject to Mr. Caldwell's attorney-client privilege, Mr. Caldwell has authorized us to share them with you to the extent necessary for Mrs. Caldwell's independent review.
We appreciate your prompt attention to this matter and look forward to working with you to bring this process to a successful conclusion. I am available to discuss any aspect of the enclosed documents or the estate plan at your convenience. Please do not hesitate to reach out to me directly or to Monica Reyes, the lead associate on this engagement.
Victoria Chambers — Direct: (212) 506-7218
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Victoria Chambers Partner 375 Park Avenue, 42nd Floor New York, NY 10152
Enclosures:
Enclosure 1: Draft Spousal Consent and Acknowledgment
Enclosure 2: Draft Amended and Restated Caldwell Revocable Trust Agreement (effective April 1, 2023; original dated October 3, 2010)
Enclosure 3: Draft Last Will and Testament of Jonathan R. Caldwell (Pour-Over Will)
Enclosure 4: Draft Caldwell 2023 Securities GRAT Trust Agreement (GRAT A)
Enclosure 5: Draft Caldwell 2023 Realty GRAT Trust Agreement (GRAT B)
Enclosure 6: Draft Caldwell 2023 Carried Interest GRAT Trust Agreement (GRAT C)
Enclosure 7: Draft Caldwell Family Dynasty Trust Agreement
cc: Jonathan R. Caldwell (via email) Monica Reyes, Calderwood & Harkness LLP Sylvia Hartwell, Calderwood & Harkness LLP
CONFIDENTIALITY NOTICE: This letter and the enclosed documents are confidential communications protected by the attorney-client privilege and the work product doctrine. The enclosed documents are drafts subject to revision and do not constitute final legal instruments. This letter and its enclosures are transmitted to Pemberton, Locke & Strauss LLP solely for the purpose of Ms. Dunlap's independent legal review on behalf of Eleanor V. Caldwell and should be treated as confidential. They should not be disclosed to, shared with, or discussed with any person other than Mrs. Caldwell and those professionals within Pemberton, Locke & Strauss LLP working on this matter. If you have received this communication in error, please notify the sender immediately and destroy all copies. Thank you.
| Asset Category | Estimated Value |
| Liquid securities (publicly traded equities, fixed income, cash equivalents) | ~$112,000,000 |
| Real estate via Stonecrest Realty Holdings LLC | ~$134,000,000 |
| Carried interest and LP stakes in Caldwell Ridgeline Capital Funds IV, V, and VI | ~$38,000,000 |
| Art and collectibles | ~$9,000,000 |
| Other assets (cash, personal property, miscellaneous) | ~$7,000,000 |
| Total Estimated Gross Estate | ~$300,000,000 |