UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF OHIO

WESTERN DIVISION

UNITED STATES OF AMERICA,

vs.

WILLIAM PIERCE WASHINGTON, III,

WILLIAM PIERCE WASHINGTON, JR.

STEVEN E. RITTER,

EDUARD SARKISOV

Defendants.

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Case No. 1:17-cr-071

1:18-cr-19

1:18-cr-20

Judge Timothy S. Black

ORDER TO CREATE TRUST AND APPROVING TRUST FORM

The Court previously ordered the payment of restitution to Minor Victim A 

(“KB”) in the three above-referenced criminal cases. Specifically, KB was the victim of 

sex trafficking by the above-referenced Defendants. Defendants’ cases have all been 

adjudicated and as part of each of their cases, Defendants were ordered, jointly and 

severally, to pay restitution in the amount of $229,125.20 to be distributed as follows, in 

order of priority: (a) $194,528.00 to an irrevocable trust for the benefit of KB; and 

(b) $34,597.20 to Clermont County Job and Family Services (for Past Medical Services).

Payment of the restitution has commenced, and the Court finds that it would in the 

best interest of KB for those funds to be held in an irrevocable discretionary trust for 

KB’s benefit. Accordingly, the Court hereby ORDERS creation of such an irrevocable 

discretionary trust and, further, APPROVES the Trust Form attached to this Order. 

IT IS SO ORDERED.

Date: 12/2/2022

Timothy S. Black

United States District Judge

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KB IRREVOCABLE TRUST

Under Agreement Dated ________________

This irrevocable trust agreement is created, entered into and effective as of the 

____ day of __________________, 2022, pursuant to court order and by and between 

KRISTIN K. BOOTH as Grantor (hereinafter referred to as “Grantor”) and KRISTIN K. 

BOOTH as the Trustee (hereinafter referred to as “Trustee”). 

This trust agreement shall be known as the KB Irrevocable Trust (“Trust”) and is 

established to administer funds received by the court for the benefit of Minor Victim A as

entered in the United States District Court for the Southern District of Ohio Western 

Division under Case Numbers 1:17-CR-071(TSB), 1:18-CR-019 (TSB) and 1:18-CR020(TSB). This Trust is established for the benefit of Minor Victim A, also known as KB,

in the above-listed cases (hereinafter referred to as “Beneficiary”). Beneficiary’s name 

and identifying information will be filed under seal in the above-listed cases. 

In accordance with the provisions of this Trust agreement, the Trustee shall 

receive, hold, administer, invest and distribute all funds paid to the Trustee by the Clerk 

of the Court for the United States District Court Southern District of Ohio Western Division,

as well as any other such funds that are transferred to and received by the Trustee,

including all income earned on said funds (“Trust Estate”) as provided by the terms of this 

Trust agreement. 

ARTICLE 1

FUNDING THE TRUST

1.1. Initial Funding of the Trust. Upon receipt of a Court Order, the Clerk of Court for 

the United States District Court Southern District of Ohio Western Division shall 

fund this Trust with the assets on deposit in the Court’s repository that are being 

held on behalf of Minor Victim A as entered in the United States District Court for 

the Southern District of Ohio Western Division under Case Numbers 1:17-CR071(TSB), 1:18-CR-019 (TSB) and 1:18-CR-020(TSB). 

1.2. Additions to the Trust. The Trustee shall have the right, at any time, to add 

property acceptable to the Trustee to the Trust including income earned on the 

Trust estate. Such property when received and accepted by the Trustee, shall 

become part of the Trust estate. All property so transferred, in addition to the 

property initially funding the Trust, shall constitute the Trust estate. In no event 

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shall such additions be considered income for the purposes of determining 

Beneficiary’s eligibility for any governmental, charitable or community benefits. 

ARTICLE 2

PURPOSE OF THE TRUST

2.1 Administering assets for Beneficiary. Pursuant to the court’s order in the 

above-listed cases, the Trustee shall hold funds in this Trust on behalf of 

Beneficiary and shall administer this Trust as an irrevocable discretionary Trust for 

the benefit of Beneficiary. Further, in administering this Trust, the Trustee shall 

have complete and total discretion as to the distributions made to or on behalf of 

Beneficiary, but shall take into consideration the provisions as enumerated in 18 

U.S. Code Section 2259 which include:

a. Medical services relating to physical, psychiatric, or psychological care;

b. Physical and occupational therapy or rehabilitation;

c. Necessary transportation, temporary housing, and child care expenses;

d. Lost income;

e. Reasonable attorneys’ fees, as well as other costs incurred; and

f. Any other relevant losses incurred by the victim.

Trustee shall have complete discretion if Trustee does make any distribution 

pursuant to 18 U.S. Code Section 2259, but Trustee shall only distribute if there is 

no other pay source. 

2.2 Eligibility for governmental, charitable or community benefits. In 

administering this Trust as an irrevocable discretionary Trust for the benefit of

Beneficiary, Grantor and the Court intend that this Trust supplement, rather than 

supplant, replace, impair, or diminish Beneficiary’s governmental, charitable or 

community benefits. 

a. Definition of governmental, charitable or community benefits. The 

term “governmental, charitable or community benefits” shall refer to all 

programs enacted by federal, state, or local statutes, regulations, and/or 

administrative decisions in effect during the existence of this Trust as well 

as any community benefit programs whether public or private, including, but 

not limited to: Medicaid; Supplemental Security Income payments; Food 

Stamps/SNAP benefits; Subsidized Housing; State Supplement payments; 

Disability Assistance; Veteran’s Benefits; or, any other public, private, or 

charitable assistance which is or may be available to Beneficiary.

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ARTICLE 3

DISTRIBUTION OF INCOME AND PRINCIPAL

DURING BENEFICIARY’S LIFE

3.1 Distributions. The Trustee is authorized to expend such amounts of income and 

principal as the Trustee deems appropriate in Trustee’s sole, unfettered, and 

uncontrolled discretion for the benefit of Beneficiary. Any income not distributed 

in accordance with this paragraph shall be accumulated and added to the principal. 

It is Grantor’s intent that the power to compel distributions shall lie solely with the 

United States District Court for the Southern District of Ohio and further that this 

Trust not contain an ascertainable standard for distribution purposes. 

3.2 Spendthrift Provision. The interest of the Beneficiary in the Trust created 

hereunder shall not be subject to the claims of creditors and shall not be subject 

to attachment, execution or other legal process or lien brought by or in favor of a 

creditor or creditors of the Beneficiary, and no alienation or assignment of any 

interest in the subject matter of this Trust, whether principal or income, shall be 

binding upon the Trustee. The Beneficiary nor any person acting on Beneficiary’s

behalf or any other person except the Trustee alone, shall have any right, power 

or authority to liquidate the fund, in whole or in part, or to require payments from 

the fund for any purpose. 

a. No income or principal distributable or to become distributable with respect 

to this Trust shall be transferable, assignable or subject to being in any 

manner whatsoever anticipated, charged or encumbered by any person 

beneficially interested in such Trust, or subject to interference or control by 

any creditors of said person, or subject to any claim for maintenance, 

alimony or for the support of a spouse pursuant to a decree of separate 

maintenance or separation agreement, or to being take or reached by any 

legal or equitable process in satisfaction of any debt, liability or obligation of 

the Beneficiary prior to its receipt by the Beneficiary. 

ARTICLE 4

TERMINATION OF TRUST

4.1 Termination upon death. This Trust shall terminate upon Beneficiary’s death. 

The Trustee may, in the Trustee’s sole, absolute and uncontrolled discretion, pay 

the last illness and funeral expenses of the Beneficiary, attorneys’ fees, advisor 

fees, accountant or other professional advisor fees as well as any costs incurred 

in administering the Beneficiary’s estate and this Trust and any other such 

expenses related to the Beneficiary as the Trustee deems appropriate. The 

balance remaining in the Trust after payment of any such expenses shall be 

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distributed to the children of the Beneficiary, per stirpes. If the Beneficiary has no 

living children and no living descendants, any balance remaining in this Trust shall 

be distributed to the Estate of KB. 

4.2 Termination due to Trust being economically unfeasible and/or depletion of

Trust assets. Should the Trustee determine in the Trustee’s sole discretion that 

this Trust is so small as to be deemed economically unfeasible for management 

under this Trust agreement or if all assets of this Trust have been depleted, the 

Trustee may terminate such Trust and distribute all accrued and undistributed 

income and principal, free of Trust, to the Beneficiary or on behalf of the 

Beneficiary. Any such distribution made by the Trustee shall be final, binding and 

conclusive upon all persons whomsoever and shall be a full discharge and 

acquittance to the Trustee in its performance of the administration of this Trust

agreement. 

ARTICLE 5

DUTIES AND POWERS OF TRUSTEE

5.1 Trustee Powers. In addition to the authority the Trustee may have under the laws 

of any state, the Trustee shall have the following powers which the Trustee may 

exercise without court order:

a. To collect all income and to deduct, before distribution to any Beneficiary, 

such fees and expenses as may accrue or be payable.

b. To collect, pay, settle and compromise debts and claims in favor of or 

against the Trust estate.

c. To borrow money and to renew existing loans, with or without giving security 

therefor.

d. To buy and sell real property and personal property, publicly and privately 

for cash or for deferred payments, secured or unsecured; to give or take 

options to buy or sell real or personal property for any length of time; to 

lease real and personal property for any term irrespective of the duration of 

any Trust, with or without an option to purchase; to mortgage real property 

and pledge personal property; and to execute and deliver instruments to 

effectuate such powers without liability on the part of any purchaser, lessee, 

mortgagee or pledgee to see to the application of the purchase money, 

rents or funds; all without the necessity of notice, advertisement, 

appraisement, evaluation, court order or other legal formality, for such price 

as the Trustee, in the Trustee’s sole discretion, deems proper.

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e. To administer real estate in any manner including but not limited to the 

power to manage, repair, alter, sell, transfer, convey, subdivide, develop, 

protect, exchange or dedicate land to public use; make or obtain the 

vacation of a plat or adjust a boundary; adjust a difference in valuation on 

exchange or partition by giving or receiving consideration; grant or retain 

easements; dedicate an easement to public use with or without 

consideration; grant and convey with or without covenants of warranty, to 

lease for a term of years or perpetually with or without privilege of purchase, 

or otherwise deal in real property, or any interest in that real property, as 

the Trustee deems appropriate and without regard to the duration of those 

interests and to do and perform any and all proper acts as the owner of real 

estate and to execute all instruments to effectuate these powers. 

f. To invest or reinvest any funds of the Trust in any property (including but 

not limited to any real estate, stock, mutual fund or common Trust fund) and 

to hold cash uninvested for such periods as may be deemed advisable for 

the benefit of the Beneficiary. 

g. To exercise and not exercise, as the Trustee deems reasonable, rights of 

ownership incident to securities that the Trustee may hold, including rights 

to vote, give proxies and execute consents, effectuate a redemption and to 

make as many redemptions as the Trustee considers appropriate and to 

accept cash or property or notes in return therefor.

h. To hold property in the name of a nominee.

i. To consult with and/or employ legal counsel as an expense of the Trust, 

and the Trustee shall not be liable in respect to any action taken in good 

faith and in accordance with the opinion of legal counsel.

j. To employ, as an expense of the Trust, accountants, investment advisors, 

brokers, agents, custodians or other professional advisors as may be 

deemed necessary in administering the Trust and its assets.

k. To continue in full force any policies of life insurance which may at any time 

form a part of the Trust estate, on the life of any person whomsoever, or to 

purchase insurance on the life of any Beneficiary or other person in whom 

any such Beneficiary may have an insurable interest, naming as the 

Beneficiary of any such policy either the Trust or the Trust Beneficiary on 

whom or with respect to whom such policy was purchased; to exercise any 

and all rights granted under any such policy, including the right to borrow 

from the value accrued, to elect to convert to paid up insurance, or to 

surrender any such policy for the then full value; and the Trustee may pay 

premiums, assessments and other proper charges on any such policy, 

either from the income, or to the extent necessary, from the principal of the 

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Trust estate; and the Trustee may exercise all rights granted under any such 

policy, all as the Trustee may determine in the Trustee’s sole discretion.

l. To hold, retain and continue to operate any business interest received by 

the Trustee, whether organized as a sole proprietorship, partnership, LLC 

or corporation, for such time and in such manner as the Trustee may deem 

advisable, solely at the risk of the Trust estate, without liability on the part 

of the Trustee for any losses resulting therefrom; to dissolve, liquidate or 

sell such business interest at such time and upon such terms as the Trustee 

may deem advisable; to use the general assets of the Trust estate for the 

purposes of the business; to use the income from such business for 

business purposes, including, but not limited to, the establishing of 

additional reserve and depreciation accounts, the establishing of funds for 

future expansion and growth, and such other business purposes as the 

Trustee, in the Trustee’s sole judgment, may deem advisable; to borrow 

money for business purposes and pledge or encumber the assets of the 

business or other assets of the Trust estate to secure a loan; to employ 

such officers, managers, employees or agents as the Trustee may deem 

advisable in the management of such business, including electing any of 

the Trustees to take part in the management of such business as a Director, 

Officer, Partner or Employee, and as such, the said Trustee may receive 

compensation for services in addition to the fee which the Trustee may be 

entitled to for the Trustee’s services in the administration of the Trust estate; 

and to have such additional powers as may be necessary to enable the 

Trustee to continue or to dispose of such interest. Grantor and the Court

knowingly and specifically authorizes and empowers the Trustee hereunder 

to exercise all of the duties and powers under this instrument despite any 

duality of fiduciary obligation arising by reason of service as a Trustee 

appointed hereunder and as an Officer, Director, Partner or Employee of 

any sole proprietorship, corporation or partnership in which the Trust estate 

may have an interest.

m. In the exercise of the powers and duties hereunder, Trustee shall use the 

same judgment and care that a prudent individual would use if he or she 

were the owner of such Trust assets.

n. No person leasing or purchasing property from or lending money to or 

otherwise dealing with any Trustee, and no transfer agent requested to 

transfer corporate securities to or from any Trustee need inquire as to the 

purposes of the lease, sale, loan, transfer or assignment or to see to the 

application of the proceeds, and the receipt of the Trustee shall be a 

complete acquittance and discharge of such person for the amount paid.

o. The Trustee is authorized to distribute Trust assets in cash or in kind, or 

partly in each and in such manner as the Trustee shall determine. If it is 

necessary for the Trustee to value Trust assets for the purposes of division 

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and distribution to remainder beneficiaries, each such asset shall be valued 

at what the Trustee determines to be its fair market value on the date of 

such original division and distribution. The Trustee shall not be held 

accountable for any loss or depreciation of the assets after the original date 

of distribution or division.

p. If the Trustee has a reasonable doubt about the manner of allocating any 

credit or charge to principal or income under applicable law, the Trustee 

shall have the power, exercisable as a fiduciary in good faith: to determine 

whether assets received shall be treated as principal or income, provided 

that the distribution of capital gains by regulated investment companies, 

capital gains on the sale of assets and stock dividends in stock of the 

declaring corporation shall be allocated to principal; to charge or apportion 

expenses or losses to principal or income; to establish and maintain 

reasonable reserves for depreciation, depletion, amortization and 

obsolescence, and if any portion of the Trust estate consists of a wasting 

asset, to establish and maintain reasonable reserves for such asset; and to 

amortize or not to amortize both premiums and discounts on investments.

q. The Trustee assumes no responsibility as to the validity or enforceability of 

any policy of insurance made payable to the Trustee hereunder, nor with 

respect to the payment of any premiums or other amounts that may be due 

or may become due on any such policy, nor does the Trustee assume 

responsibility for doing anything else that may be required in order to keep 

such policy in force. As to any insurance policy of which the Trustee is the 

owner, the Trustee shall have the right to exercise all rights, elections, 

options, privileges and other powers, including powers to surrender any 

such policy for the cash surrender value thereof, and to convert any such 

policy in connection with a loan or loans to the Trustee. Any insurance 

company which has issued a policy of insurance payable to the Trustee 

hereunder need not inquire into or take notice of this agreement, nor see to 

the application of the proceeds of any such policy or any other amounts paid 

to the Trustee, and the receipt of the Trustee shall be a complete release 

and discharge of the insurance company for the amount so paid. If a dispute 

arises with respect to the collection by the Trustee of the proceeds of any 

such policy, the Trustee shall have the authority to compromise such 

dispute in any manner the Trustee deems to be in the best interests of the 

Trust, and the Trustee may enter into any agreement with respect to such 

compromise which the Trustee deems appropriate and may release any 

insurance company from liability under any such policy. The Trustee need 

not engage in litigation to collect the proceeds due under any such policy

r. If the Trustee is unable to act as Trustee with respect to any real property 

located outside of the State of Ohio, then such person or persons or 

corporation as may, from time to time, be appointed by the United States 

District Court for the Southern District of Ohio to serve as Trustee for such 

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real property. If approved by the United States District Court for the 

Southern District of Ohio to serve as Trustee with respect to any real 

property located outside of the State of Ohio, such appointed Trustee shall 

have all of the powers and discretion with respect to such property as are 

herein given to the original Trustee and shall be paid the reasonable value 

of services rendered. The United States District Court for the Southern 

District of Ohio shall also have sole authority to remove such person, 

persons, or corporation appointed as Trustee with respect to said out-ofstate real estate. Should any such real property located outside of the State 

of Ohio property be sold, exchanged or otherwise disposed of, the proceeds 

thereof shall be remitted to the original Trustee appointed hereunder. Such 

appointed Trustee may employ the original Trustee as agent in the 

administration of such property. No surety shall be required on the bond of 

any appointed Trustee or agent acting under the provisions of this 

paragraph. No periodic court accounting shall be required of such 

appointed Trustee for real property located outside of the State of Ohio, it 

being Grantor’s and the Court’s intention to exclude any statutory 

accounting which ordinarily may be required. 

s. Any insurance companies which may pay the proceeds of any policy or 

policies of insurance to the Trustee hereunder are hereby fully released and 

relieved from any and all responsibility to see to the application of any funds 

so paid to the Trustee. The receipt of the Trustee for any sums so paid by 

any insurance company shall fully release such insurance company from all 

further responsibility or accountability to any person or persons for the sum 

of said receipt so stated to have been received.

ARTICLE 6

TRUSTEES

6.1 Initial Trustee. The initial Trustee of this Trust is Kristin K. Booth. All Trust

provisions regarding “Trustee” shall include the initial Trustee and all successor 

Trustees.

6.2 Resignation and Removal of Trustee. Any Trustee shall have the right to resign 

from such capacity on sixty (60) days written notice delivered to the United States 

District Court for the Southern District of Ohio Western Division and the Trust

Beneficiary. A Trustee may be removed as Trustee of this Trust by order of the 

United States District Court for the Southern District of Ohio Western Division and 

written notice thereof delivered to said Trustee.

6.3 Appointment of Successor Trustee. Upon the death, incapacity, resignation or 

removal of any Trustee under this Trust agreement, the United States District Court 

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for the Southern District of Ohio Western Division shall appoint a successor 

Trustee to serve under this Trust agreement. The then-serving Trustee may 

recommend to the court a successor Trustee, but no successor Trustee shall be 

appointed without a court order from the United States District Court for the 

Southern District of Ohio Western Division. The court may appoint a qualified 

individual or bank or Trust company as the Trustee hereunder by written order and 

shall provide the name and contact information for the chosen successor Trustee

to the Beneficiary. In no event may Beneficiary serve as a successor Trustee 

hereunder. Each successor Trustee shall have the same powers, duties,

authorizations and immunities as herein provided for the initial Trustee. A Trustee 

may be considered unable or unwilling to serve for any reason, including but not 

limited to refusal, resignation, removal, incapacity, death or if the person’s 

whereabouts are unknown. 

6.4 Termination of Trustee Duties. Upon the payment and delivery to any successor 

Trustee of all the property and assets of the Trust estate, and after full settlement 

of accounts, the responsibilities and liabilities of the resigning or removed Trustee 

shall terminate and the Trustee shall be released and discharged from any and all 

claims, demands, duties and obligations arising out of this Trust agreement or its 

management of the Trust estate hereunder. No successor Trustee shall be 

required or obligated to investigate the acts of any predecessor Trustee, nor be 

responsible for any of the acts or omissions of any predecessor Trustee.

6.5 Compensation of Trustee. Upon semi-annual application to the Finance Office 

for the United States District Court for the Southern District of Ohio, any individual, 

corporate or professional Trustee shall receive such compensation for services as 

is provided for by law but in no event shall a Trustee charge more than two hundred 

dollars ($200) per hour for any Trustee services. 

6.6 Trust Expenses. The Trustee shall be reimbursed from assets of the Trust estate 

for such costs, charges, taxes, damages and expenses as the Trustee may have 

incurred in connection with acting as Trustee; however, the Trustee must seek 

approval from the United States District Court for the Southern District of Ohio prior 

to committing to any expenses if it is reasonably foreseeable that such expenses 

may exceed the lesser of $5,000 or 15% of the Trust assets. 

ARTICLE 7

GENERAL PROVISIONS CONCERNING TRUST

7.1 Modification of Trust. The Trustee may modify this Trust agreement in such 

manner that is necessary to effectuate the intent of this agreement by seeking a court 

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order for approval of the modification from the United States District Court for the 

Southern District of Ohio Western Division. The intent of this agreement is to 

benefit the Beneficiary without causing the Beneficiary to lose or otherwise be 

ineligible for any governmental or community benefits that may be available to said

Beneficiary. No modification and/or amendment hereunder shall be considered a 

termination of this Trust.

7.2 Trust Statements. The Trustee shall keep a true account of the affairs of the Trust. 

At least annually and on termination of the Trust or termination of a Trustee, the 

Trustee shall render a statement of account. A statement of account is a report by 

the Trustee of the Trust property, liabilities, receipts, and disbursements, including 

the source and amount of Trustee’s compensation, a listing of the Trust assets, 

and, if feasible, their respective market values. No particular format or formality is 

required for a report unless a court specifies its content and presentation. The 

statement shall be delivered to the Beneficiary as soon as practicable after the 

close of the accounting period or on termination of the Trust. Within 30 days after 

the end of each calendar year, an annual report must be filed in the three criminal 

cases identified on page 1 of this Trust agreement. 

7.3 Incapacity. For all purposes of this Trust agreement, an individual shall be 

considered incapacitated or incompetent if under age eighteen (18), or if so 

declared by a court having jurisdiction or if such person’s personal physician or 

any two physicians selected by the Trustee shall advise the Trustee of such 

incapacity or incompetency in writing. In the event that the potentially 

incapacitated person is also serving as the Trustee, then the immediate successor 

Trustee shall select the two physicians indicated in the preceding sentence. Any 

such incapacity or incompetency established in the first instance by declaration of 

court may be removed only by such court, or if established in the first instance by 

such person’s personal physician or any two physicians selected as above 

provided, may be removed by either the personal physician then serving such 

person or by any two physicians selected by the Trustee (who need not be the 

same two physicians who may have advised the Trustee of such person’s 

incapacity or incompetency).

7.4 Child and Descendants. The words “child” or “children,” when used in this Trust

agreement shall mean lineal descendants of the first degree only. The word 

“descendants” shall mean lineal descendants of any degree. The words “child” 

and “children” shall include persons adopted, as well as those of the blood, of the 

parents or ancestors mentioned, except those adopted after reaching age 21.

7.5 Spendthrift provision. A Beneficiary may not assign any portion of the beneficial 

interest in income or principal. No creditor of any Beneficiary may attach, interfere, 

take, or reach by any legal or equitable process any part of a Beneficiary’s interest 

in satisfaction of any debt or liability of the Beneficiary before actual receipt by the 

Beneficiary after payment from Trustee. Notwithstanding any other provision in this 

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Trust agreement, the Trustee may withhold distributions to any Beneficiary whose 

interest would or likely could become payable to anyone other than the Beneficiary. 

7.6 Retained share. Notwithstanding any other provision in this Trust agreement, the 

Trustee may, but only upon the approval of the United States District Court for the 

Southern District of Ohio, hold in further Trust all or any portion of a share of Trust

assets otherwise distributable to the Beneficiary if Trustee determines that there is 

a substantial possibility that the Beneficiary will be unable or unwilling to use the 

distributed Trust assets in the Beneficiary’s best interests due to personal 

circumstance. Circumstances warranting retention include but are not limited to 

mental or physical incapacity, difficulty in exercising judgment about or attending 

to financial and property affairs, alcoholism, drug abuse, gambling, incarceration, 

pending or threatened bankruptcy, marital disharmony or pending divorce, pending 

or threatened litigation, or residence in a jurisdiction or affiliation with a group or 

sect where all or a majority of the distribution may be confiscated or appropriated 

by the government or others. Trustee may, but only upon approval of the United 

States District Court for the Southern District of Ohio, hold the Beneficiary’s share 

of Trust assets as a completely discretionary spendthrift Trust in which the Trustee 

is authorized to distribute such amounts of income and principal in Trustee’s sole, 

unfettered and uncontrolled discretion. Trustee shall be fully exonerated in its 

decision under this section to hold, continue to hold, or decline to hold Trust assets 

in a wholly discretionary spendthrift Trust unless such decision is made in bad faith.

7.7 Construction. If any provision of this Trust agreement is deemed unenforceable, 

the remaining provisions shall nevertheless be carried into effect. The masculine 

gender shall include the feminine and the neuter and the feminine gender the 

masculine and the neuter, and the neuter gender the masculine and the feminine, 

unless the context otherwise requires. The singular form of a word shall include 

the plural and the plural form of a word shall include the singular unless the context 

otherwise requires. 

7.8 Governing law. The United States District Court for the Southern District of Ohio 

Western Division shall retain jurisdiction of this Trust agreement at all times and 

the Trust agreement shall be governed by the substantive law of the State of Ohio,

which shall be its principal place of administration. The Trustee may at any time 

request approval from the United States District Court for the Southern District of 

Ohio Western Division to change the situs of administration of the Trust from one 

jurisdiction to another U.S. jurisdiction if such change is in the best interest of the 

Beneficiary. 

7.9 Right of beneficiary to appeal. The Beneficiary shall have the unfettered right to 

appeal any decision by or action of the Trustee to the United States District Court 

for the Southern District of Ohio for a final determination. Any such appeal must 

be submitted in writing to the presiding District Judge assigned to the three criminal 

cases identified on page 1 of this Trust Agreement. In the event of an appeal by 

the Beneficiary, the Trustee shall defer the appealed decision or action until 

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otherwise ordered by the presiding District Judge before whom the Beneficiary’s 

appeal is pending. 

Date:___________________ ________________________________

Kristin K. Booth, Grantor

WITNESSES:

_________________________________ ______________________________

Printed Name:______________________ Printed Name:__________________

STATE OF OHIO, COUNTY OF HAMILTON )ss:

BE IT REMEMBERED, that on _______________________, before me, the 

subscriber, a Notary Public in and for said county and state, personally came Kristin K. 

Booth, and acknowledged the signing and execution of the foregoing Trust Agreement to 

be a free and voluntary act and deed and such individual appeared to be of sound mind 

and under no duress, fraud or undue influence. IN TESTIMONY WHEREOF, I have 

hereunto subscribed my name and affixed my notarial seal on the day and year last 

aforesaid.

__________________________________

Notary Public

Date:___________________ ______________________________

Kristin K. Booth, Trustee

WITNESSES:

_________________________________ ______________________________

Printed Name:______________________ Printed Name:__________________

STATE OF OHIO, COUNTY OF HAMILTON )ss:

BE IT REMEMBERED, that on _______________________, before me, the 

subscriber, a Notary Public in and for said county and state, personally came Kristin K. 

Booth as Trustee of the KB Irrevocable Trust and acknowledged the signing and 

execution of the foregoing Trust Agreement to be a free and voluntary act and deed and 

such individual appeared to be of sound mind and under no duress, fraud or undue 

influence. IN TESTIMONY WHEREOF, I have hereunto subscribed my name and affixed 

my notarial seal on the day and year last aforesaid.

__________________________________

Notary Public 

Case: 1:18-cr-00019-TSB Doc #: 40 Filed: 12/02/22 Page: 13 of 13 PAGEID #: 195