EMAIL DETAILS

FYI, not that it hugely matters but Naomi's Birthday is wrong in this.
December 21, 1993. Not December 4 (which is Kathleen's).

Eric D. Schwerin
eschwerin@rosemontseneca.com

Sent from my iPhone

On Apr 7, 2017, at 4:26 PM, SMancinelli <SMancinelli@ainbanklaw.com> wrote:

See below and let me know your thoughts. I will review the attached and
confirm it is good to go.


*From:* Rebekah J.H. Sullivan [mailto:RSullivan@ksfmlaw.com
<RSullivan@ksfmlaw.com>]
*Sent:* Friday, April 07, 2017 12:53 PM
*To:* SMancinelli
*Subject:* RE: Biden


Dear Sarah,


Thank you for your responses below. Several additional items:


-Attached is a draft FOFCOLJAD for your review and approval. I know a QDRO
is not needed to transfer Hunter’s IRA, but I thought it was better to
include the reservation of jurisdiction in case there are issues and we
need an order down the road.


-Kathleen sent a number of outstanding bills for Hunter that are his
responsibility under the MSA. She can continue to send those, but to whom
or to where should she forward them?


-Hunter agreed to Kathleen to pay $20,000 for her legal fees and $100,000
to her parents, but requested that it not be included in the MSA. He
promised it would be paid. Kathleen would like to know when that will
happen. Kathleen’s number one priority is the money owed to her parents.


-Finally, I asked Kathleen to bring the marriage license to the hearing if
she has it. Better safe than sorry. If for whatever reason Hunter has it,
would you mind bringing it to the hearing?


Thanks,


Rebekah J.H. Sullivan

Kuder, Smollar, Friedman & Mihalik, PC

1350 Connecticut Ave. NW

Suite 600

Washington, DC 20036


*www.KSFMLAW.com <http://www.ksfmlaw.com/>*

Tel: 202/331-7522

Fax: 202/331-0388


<image001.png>

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*above and may contain information that is privileged, attorney work
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*or exempt from disclosure under applicable law. If you have received this
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*message in error, or are not the named recipient(s), please immediately
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*Thank You.*


*From:* SMancinelli [mailto:SMancinelli@ainbanklaw.com
<SMancinelli@ainbanklaw.com>]
*Sent:* Friday, April 07, 2017 9:48 AM
*To:* Rebekah J.H. Sullivan
*Subject:* RE: Biden


Rebekah-


See my responses below.


*From:* Rebekah J.H. Sullivan [mailto:RSullivan@ksfmlaw.com
<RSullivan@ksfmlaw.com>]
*Sent:* Thursday, April 06, 2017 1:41 PM
*To:* SMancinelli
*Subject:* RE: Biden


Sarah,


We maintain that it is better for the privacy of both parties that no
statements be released, and we ask that the MSA be modified to reflect that
no statements will be released. Please understand that anything issued
only gives the press something new to report on. If Hunter insists on
releasing statements, we propose the following as his:


This has been a very difficult two years for my family, particularly with
the death of my brother and the conclusion of my marriage to Kathleen. We
are fortunate to have three amazing daughters together. We have resolved
our differences and entered into a settlement. We ask that everyone respect
our privacy and the privacy of our children.


I will discuss this with Hunter and let you know how he would like to
proceed.


There are several other matters related to moving forward that I want to
raise with you:


-I assume you will bring a Joint Waiver of Appeal, signed by Hunter, to the
uncontested divorce hearing. Please let us know whether Hunter will be
attending, and whether you have a signed Joint Waiver of Appeal.

I will bring a Joint Waiver signed by Hunter. Hunter will not attend the
hearing.


-Would you give me an update on the transfer of funds from Hunter’s IRA?
We would like to get this accomplished before the hearing if possible

Hunter has executed all the documents necessary to make the transfer. The
transfer itself, however, cannot be done until after entry of the Judgment
of Divorce. Once we have the executed Judgment, that is submitted along
with the paperwork and the transfer ill be completed.


-Would you also provide proof that Kathleen is the sole irrevocable
beneficiary of Hunter’s $3,000,000 life insurance policy? Again, we would
like this before the hearing.

Please see the attached.


-Please ask Hunter to remove Kathleen’s name from any credit cards that he
is able to. Relatedly, please have him move the debt from the American
Express card as soon as possible so Kathleen can use that card

This is being worked on.


-Does Hunter have any objection to Kathleen reaching out to Joan about
transferring bills to her name?

Please see the attached which I believe I have forwarded previously. Joan
is recovering from knee surgery and not presently in a position to help
with the transfers. What I suggest is that Kathleen log-in to each account
and change the bills to her name and address (which for most, if not all,
can be done online). If she has any trouble transferring any of them,
please then let me know and we can proceed as needed.


Thank you,


Rebekah J.H. Sullivan

Kuder, Smollar, Friedman & Mihalik, PC

1350 Connecticut Ave. NW

Suite 600

Washington, DC 20036


*www.KSFMLAW.com <http://www.ksfmlaw.com/>*

Tel: 202/331-7522

Fax: 202/331-0388


<image001.png>

*******NOTICE**********

*This e-mail message is confidential, intended only for the named
recipient(s) *

*above and may contain information that is privileged, attorney work
product *

*or exempt from disclosure under applicable law. If you have received this
*

*message in error, or are not the named recipient(s), please immediately
notify *

*the sender at (202) 331-7522 and delete this e-mail message from your
computer. *

*Thank You.*


*From:* SMancinelli [mailto:SMancinelli@ainbanklaw.com
<SMancinelli@ainbanklaw.com>]
*Sent:* Wednesday, April 05, 2017 11:42 AM
*To:* Rebekah J.H. Sullivan
*Subject:* Biden


Hi Rebekah-


Attached is Hunter’s press statement. Its identical to the one that Meg
prepared at mediation except that we changed “breakdown” to “conclusion”.
Please confirm the attached is agreeable to Kathleen.


Given the Court’s refusal to seal the file and the fact that TMZ has
already run a story about the Judge’s Order from yesterday, our thought is
that the parties should release these statements soon. Either before or in
conjunction with the hearing next Friday.


We welcome Kathleen’s input.


Thank you-
Sarah


Sarah E. Mancinelli, Esq.

Ain & Bank, P.C.

1900 M. Street, NW, Suite 600

Washington, D.C. 20036-3565

(202) 530-3355 (direct dial)

(202) 530-4411 (fax)

<FOFCOLJAD.docx