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> On Jan 2, 2017, at 4:04 PM, Eric Schwerin <eschwerin@rosemontseneca.com> wrote:
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> <Biden Monthly Outflows.xlsx>
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> Eric D. Schwerin
> Rosemont Seneca Advisors, LLC
> 1010 Wisconsin Ave., NW
> Suite 705
> Washington, DC 20007
> (202) 333-1880
> eschwerin@rosemontseneca.com <x-msg://59/eschwerin@obblaw.com>
> P Consider the environment before printing this email.
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I cannot stress enough how much Ms. Biden wants to resolve this quietly, amicably, and fairly. We have asked for full financial disclosure and have not received it. It is the continuing lack of response from Mr. Biden that left us no choice but to file so that we would have the ability to obtain information independent from his stonewalling. I acknowledge the financial information forwarded by you from Mr. Biden’s office, and your email of Wednesday that your paralegal is preparing the TD Bank statements (though she has not yet sent them). That information, and the other information we have requested will help us to reach a comprehensive agreement.

We cannot make a full settlement proposal, however, without more disclosure from Mr. Biden. We do not know the current state of finances and we do not know how the parties got where they are. While acknowledging that Mr. Biden’s office has been helpful, in some ways, in getting us information, they are not a neutral party. It is clear that they act at Mr. Biden’s direction, as they were complicit in providing Mr. Biden at least the $120,000 in a way designed to circumvent the family. We are willing to provide certain proposed terms, but without full disclosure it is unreasonable to ask Ms. Biden for a comprehensive settlement proposal. With this understanding, Ms. Biden proposes the following partial terms:

Custody: Ms. Biden will have sole legal and sole physical custody of the parties’ minor children. Mr. Biden will have visitation as mutually agreed between he and the children.

Real Property: Ms. Biden will receive both the D.C. Home and the Indiana Lake House. She will have five years in which to attempt to refinance either or both of the homes. If she is unable to refinance either or both of the homes, the properties will be listed for sale and Ms. Biden will keep any proceeds as her sole and separate property.

Retirement Assets: Mr. Biden will transfer to Ms. Biden all his retirement assets. This contemplates Ms. Biden’s inability to accumulate future retirement assets of her own and recognizes Mr. Biden’s safety net through his family.

Bank Accounts: Mr. Biden will immediately transfer to Ms. Biden $103,000, representing the deposit in his TD Bank account, less the $17,000 previously transferred to Ms. Biden. Our understanding is that these funds have been dissipated by Mr. Biden pursuing interests separate from the family.

Debt: Mr. Biden will be solely responsible for all credit card debt in his name, Ms. Biden’s name, or the parties’ joint names. Mr. Biden will transfer all credit card debt into his sole name within 30 days. Mr. Biden will be solely responsible for his school loans. Mr. Biden will be solely responsible for all tax liability of the parties including 2016, 2015, and all other years in which the parties filed jointly.

KSFM • LAW
KUDER, SMOLLAR, FRIEDMAN & mihalik, PC

Sarah Mancinelli, Esquire

December 30, 2016 Page 3

Mr. Biden will be responsible for all UCC liens placed on any property owned by him or the parties jointly and any cost for resolving and removing the liens. Ms. Biden will be responsible for the $122,000 (original $112,000 plus $10,000 Ms. Biden had to borrow in November) debt to her parents.

Life Insurance: Mr. Biden will name Ms. Biden the sole beneficiary of his life insurance policy if she is not currently the sole beneficiary. Mr. Biden will maintain the current policy with Ms. Biden named as the sole beneficiary at least for so long as he has an alimony obligation to Ms. Biden.

Cars/Boats: Mr. Biden will keep the boat, the Audi, and the Chevrolet Silverado. Ms. Biden will keep the Chevrolet Suburban and the Mercedes Benz. Each party will keep the debt associated with the vehicles he or she is retaining.

Support: Until we receive full financial disclosure and are able to reach a comprehensive agreement, Mr. Biden will pay Ms. Biden $20,000 in spousal support and $20,000 in child support per month. In any month in which Mr. Biden receives more than $150,000 in gross income, he will pay Ms. Biden 50% of the income above $150,000. Mr. Biden’s office will continue to pay the expenses they have been paying, including tuition, mortgages, utilities, and car payments until we are able to agree on a final support amount after full financial disclosure.

Sincerely, Rebekah Sullivan


cc: Ms. Kathleen Biden 8508.01