EMAIL DETAILS

I am comfortable with the email as drafted below- I added language about this being without prejudice, etc.

If you approve, Hunter. I will send this out.

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.


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