EMAIL DETAILS

For Settlement Purposes Only

Rebekah-

Attached please find a draft Consent Motion to Stay the Litigation. Hunter will authorize me to execute the attached if Kathleen will agree to the following:


- Hunter will immediately proceed with good faith settlement discussions if Kathleen will agree to negotiate with him directly (or through a family member(s) of her choosing). Obviously this does not limit either party's ability to discuss the negotiations with his or her counsel and counsel will have the opportunity to review any agreement reached by the parties prior to the parties executing a comprehensive agreement. As I understand it, it was initially the hope and expectation of the parties to resolve this matter without the need for extensive intervention from attorneys. Given the events of the past week, Hunter feels strongly that no one is in a better position to develop a mutually agreeable settlement resolution than he and Kathleen and that proceeding as a united front to develop a settlement is in the best interest of their girls. For settlement purposes, I have agreed to step aside and allow them to proceed in this fashion.


- If Kathleen is not agreeable to negotiating with him directly or through a family member, then we will continue with the litigation, file a response to the Motion to Enjoin, and proceed accordingly. That would not be Hunter's preferred path forward.


We truly hope this is an agreeable way forward for Kathleen. I look forward to hearing from 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