EMAIL DETAILS

Great. Should I call you in the office then?

Eric D. Schwerin
eschwerin@rosemontseneca.com

Sent from my iPhone

On Aug 24, 2016, at 6:02 PM, Patrow, Paul D. <Paul.Patrow@faegrebd.com>
wrote:

Yes. That works for me.


Paul D. Patrow
*Partner*
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311 S. Wacker Drive | Suite 4300 | Chicago, IL 60606, USA

*From:* Eric Schwerin [mailto:eschwerin@rosemontseneca.com
<eschwerin@rosemontseneca.com>]
*Sent:* Wednesday, August 24, 2016 4:55 PM
*To:* Patrow, Paul D.
*Cc:* Mesires, George R.; Hunter Biden; Martin, George D.
*Subject:* Re: BHR


How’s tomorrow afternoon around 3pm EDT/2pm CDT?


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.*


On Aug 24, 2016, at 5:41 PM, Patrow, Paul D. <Paul.Patrow@FaegreBD.com
<Paul.Patrow@faegrebd.com>> wrote:


Eric,


I am generally open whenever works for you. I have lunch meetings
scheduled tomorrow and Friday (both should run about 12-1 Central time) but
otherwise I can discuss at your convenience.


I look forward to speaking with you.


Thank you,
Paul


Paul D. Patrow
*Partner*
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311 S. Wacker Drive | Suite 4300 | Chicago, IL 60606, USA


*From:* Eric Schwerin [mailto:eschwerin@rosemontseneca.com
<eschwerin@rosemontseneca.com>]
*Sent:* Wednesday, August 24, 2016 4:35 PM
*To:* Mesires, George R.
*Cc:* Hunter Biden; Patrow, Paul D.; Martin, George D.
*Subject:* Re: BHR


Paul-


Do you have time to talk to follow up on the tax issues George mentions
below?


Let me know what your schedule is like for a call.


Thanks,


Eric


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.*


On Aug 10, 2016, at 2:30 PM, Eric Schwerin <eschwerin@rosemontseneca.com>
wrote:


George-


All of the below is correct. RSB has agreed to transfer the 10% to
Skaneateles right now and has not asked for any money to change hands prior
to the transfer. I think it is worth confirming that with RSB/Devon (and
let’s discuss how to do so) as it is possible that Devon believes there is
a small portion of the $464K outstanding. I know we believe it has been
paid in full but it is something that needs to be confirmed to avoid
questions later. That said, I know Devon is comfortable moving forward
with the transfer now.


As you suggest, I will follow up with Paul on the tax issue.


Thanks,


Eric


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.*


On Aug 10, 2016, at 1:09 PM, Mesires, George R. <George.Mesires@FaegreBD.com
<George.Mesires@faegrebd.com>> wrote:


Eric and Hunter:


As we undertake the documentation of the transfer of 10% of the interest in
BHR from RSB àSkaneateles, we would like to confirm our understanding of
the transaction so that we can ideally achieve a tax-neutral transaction.
To recap:


RSB currently holds 20% interest in BHR, which we believe was acquired in
2014 for approximately USD $928,000. Thus, ½ of that interest (10% of the
interest in BHR) was valued at USD $464,000. We view RSB as acting as
Hunter’s agent in holding funds that RSB accumulated on Hunter’s behalf
from various third party payments to Hunter (e.g., Burisma). We further
understand that RSB has agreed that Hunter has accumulated US $464,000,
which is the sum necessary for Hunter to earn 10% of the interests in BHR
(ie., ½ of RSB’s interest). Thus, no money will change hands now. To
effectuate the equity transfer, Hunter is directing that RSB transfer its
10% interest in BHR to Skaneateles, which is owned indirectly by Hunter
(75%) and indirectly by Eric (25%).


Will Eric be receiving a 25% interest in the 10% BHR equity transferred by
RSB to Skaneateles in accordance with the current ownership structure of
Skaneateles? Will the basis for the equity grant be on account of exchange
for services Eric provided to Hunter or on some other basis? Paul can talk
through the potential US tax implications and other issues related to any
ownership in BHR that accrues to Eric, so please feel free to follow up
directly with Paul.


Thank you.


George


George R. Mesires
*Partner*
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