EMAIL DETAILS

Hunter and Eric-

Please see the email below.

If I am not mistaken, some of the specific expenditures they note below were for the girls, right? Can you PLEASE highlight which ones and tell me how you know that? That would be very, very helpful to me when I respond to this.

Please note that discovery needs to be submitted by January 31st. Hunter, you and I will need to do the interrogatory answers together. I will likely take an initial pass at them and then send to you to review/edit/comment.

Thank you, both.

Sarah

From: Rebekah J.H. Sullivan [mailto:RSullivan@ksfmlaw.com]
Sent: Tuesday, January 17, 2017 3:05 PM
To: SMancinelli
Subject: RE: Biden Matter

Dear Sarah,

Thank you for providing the information below.

We agree that Hunter will transfer to Kathleen $10,000 on or about January 20th, that Hunter will received $4,000, and that the rest will be used to pay autopays or family expenses directly from the office. Please note it is our understanding that the office, not Hunter, pays those expenses.

With respect to the Romania payment, we do not agree that Hunter should receive an additional $10,338 at that time. We have asked for $15,000 in a retainer (and will need a second retainer soon) and have asked for a retainer for Debbie May of $5,000. Your firm received a $15,000 retainer in August, so you must agree this is a reasonable request. Given that Hunter deposited $126,545 in the middle of November into the TD account in his sole name, and spent the funds on extravagances such as Georgetown Tobacco $236.81, Cardtronics $605.50, Ladybird Lingerie (not for Kathleen) $75.00, Hus Shoes $846, the Hot Tub Store $7,450.92, Sierra Mountain Outdoors $1,245.22, Toujours Lingerie (not for Kathleen) $456.75, and Kirna Zabete $1,202, I do not think it is fair to ask Kathleen to cut back on her expenses, so Hunter can continue blowing through the family funds. We propose that of the $34,000 from the Romania deal, Kathleen will receive $10,000, $18,500 will go to Kathleen’s retainers, and Lourdes will be paid, and Dr. Giannini’s bill will be paid.
We agree that a spreadsheet should be circulated every week showing how family funds are being spent.

With respect to the discovery responses, we agree to an extension but not until the day of our initial hearing. The responses will help us determine what we ask for at the initial hearing. Please provide discovery responses on a rolling basis, as we agreed, with complete discovery responses by Tuesday, January 31.

Sincerely,


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


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From: SMancinelli [mailto:SMancinelli@ainbanklaw.com]
Sent: Thursday, January 12, 2017 6:20 PM
To: Rebekah J.H. Sullivan
Subject: Biden Matter

Rebekah-
I met with Hunter last week. We spent the vast majority of that time doing our best to develop an interim support and bill paying arrangement. While it is not a sustainable scenario for a final settlement, Hunter wants to develop an interim arrangement in keeping with Kathleen’s desire for him to continue to be responsible for the payment of all of their recurring monthly expenses (which ranges between $22,000 and $25,000). Hunter recognizes the bill paying responsibility has never fallen on Kathleen’s shoulders and at this juncture, he appreciates that she would prefer that not to change so he will continue to pay all of the recurring expenses in the interim.

Our primary goal with the proposal below is to project for Kathleen the payments that Hunter expects to receive this month and how those funds will be allocated- including funds for retainer payments. I will say that for a long-term settlement, we will have to have a better understanding of Kathleen’s expenses. Given that all of her fundamental living expenses are paid for from the auto-pay account, we will need to more fully understand what her additional reasonable living expenses are so we can develop an appropriate support structure going forward. Therefore, this proposal is without prejudice to a final settlement.

1) On or about January 20th, Hunter will receive his salary payment of $70,000 from Owasco, PC representing his monthly fees from Burisma:

Salary: $70,000
Net pay: $39,000
Autopays (approx): $25,000
Remainder (approx.): $14,000

Hunter proposes paying Kathleen $10,000 on or about the 20th and he would retain the remaining $4,000.

2) Hunter believes a $60,000 “Romania” related payment may come in before the end of the January. Should that payment be received, Owasco, P.C. would pay out a bonus in the amount of $60,000 and there would be $34,000 remaining after taxes.

Bonus: $60,000
Net pay: $34,000

From that $34,000, Hunter proposes the following:

· Dr. Giannini’s bill is paid ($3,662)
· $10,000 for Kathleen’s retainers
· $10,000 to Kathleen
· $10,338 to Hunter

Therefore, of the possible $130,000 Hunter hopes to receive in January, Kathleen would receive $20,000 and Hunter would receive $14,338. And Kathleen’s retainer and the bill for Dr. Giannini would also be paid. In addition, Lourdes is owed $1,380 that Kathleen promised Lourdes to help with her taxes. If Kathleen could pay that out of her $20,000 that would go a long way to chipping away at some outstanding debts.

Should any additional money come in above and beyond that $130,000, we will alert you to that ASAP. I can say, however, that any additional cash that becomes available will likely need to first be applied to debt/tax payments before being distributed out to the parties for their discretionary use.

3) There is not yet certainty as to what the February numbers will be at this point. We hope to have a better idea of that figure soon and once we do we can better ascertain how to handle February. I would note however, that in February, Hunter and Kathleen will have to begin a payment plan to pay the IRS which will impact the amount available for discretionary spending. In addition, while Hunter is no longer paying rent and utilities for his apartment, the apartment was rented by Owasco, P.C. and Hunter will need to dedicate a portion of future discretionary spending to pay Owasco, P.C. back for those costs and/or dedicate a similar amount of money to his own living expenses.

With the goal of operating in a fully transparent manner, every week a spreadsheet will be circulated demonstrating how all of the parties funds are being spent.

I understand that the majority of Hunter’s belongings were removed from the garage at the marital home. Please confirm.

We trust this will be an agreeable way forward for the remainder of the month of January. We would like to turn our attention to developing a mutually agreed upon comprehensive settlement arrangement.

We look forward to Kathleen's response.

Sarah