EMAIL DETAILS

They want more information on the diamond. I don't know what else to tell them. If you can craft a couple of sentences for me to send her, I would appreciate it.

From: Rebekah J.H. Sullivan [mailto:RSullivan@ksfmlaw.com]
Sent: Friday, February 17, 2017 7:43 PM
To: SMancinelli
Subject: RE: Biden

Sarah,

What documents in particular are you asserting would be subject to a confidentiality agreement? Can you send me all the ones that would not be affected. Since we have prior business tax information, I am not sure why would you want the confidentiality agreement now. In any event, I will look at it and get back to you, but it should not hold up most of the 2016 tax information.

Thank you for your other responses. The sooner the better on the draft agreement. It would be extremely helpful on my end to feel like we are moving forward.

We are going to need answers about the diamond in order to enter any settlement agreement (and avoid and immediate motion on the issue). If he is now asserting he does not have it, that is a problem on our end. I ask for a complete explanation, as soon as possible.

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


[cid:image002.png@01D2879A.7900E1E0]

******NOTICE*********
This e-mail message is confidential, intended only for the named recipient(s)
above and may contain information that is privileged, attorney work product
or exempt from disclosure under applicable law. If you have received this
message in error, or are not the named recipient(s), please immediately notify
the sender at (202) 331-7522 and delete this e-mail message from your computer.
Thank You.


From: SMancinelli [mailto:SMancinelli@ainbanklaw.com]
Sent: Friday, February 17, 2017 3:39 PM
To: Rebekah J.H. Sullivan
Subject: Biden

Hi Rebekah-

Our responses are below.

Dear Sarah,

A few things.

We met with Debbie on Monday and have a few requests related to the draft agreement you are working on
1. We ask that Hunter maintain his current life insurance through the duration of the policy, with Kathleen maintained as the sole beneficiary
This will be addressed as part of the overall comprehensive settlement. But I will leave in a placeholder in the agreement.
2. We ask that Hunter move the American Express credit card to his sole name, leaving the card in Kathleen's name with no outstanding balance.
Agreed.
3. We ask that Hunter transfer the entire value of his retirement account to Kathleen.
This will be addressed as part of the overall comprehensive settlement. But I will leave in a placeholder in the agreement.

4. We ask that Hunter commit to paying for college and a living stipend for Finnegan and Maisy.
Agreed.
5. We ask that Hunter be solely liable for outstanding tax debt and indemnify Kathleen
This will be addressed as part of the overall comprehensive settlement. But I will leave in a placeholder in the agreement.


I look forward to having a draft agreement to review by the end of the week. I think the more we are able to discuss prior to ADR the more useful that time will be.
I will get you a draft the beginning of next week- my apologies for the delay.

Can you let me know as soon as possible how much will be transferred to Kathleen this month and when? This continues to be a source of frustration
I am working on getting an answer to this ASAP. It is frustrating for everyone and is the result of not knowing, at this time, how much money will come in the next few days. I will keep you posted.

I reiterate my request that Hunter pay Debbie $5,000. This is all earned fees now, no retainer.
I am working on getting this paid in the next week.

Please also provide all of Hunter's tax documents for 2016 (W-2s, 1099s, etc.) and profit and loss statements for the businesses. This will be necessary to have a reasoned conversation about support going forward.
I have these and will forward to you. Can you please execute the confidentiality agreement I sent you previously?

In the past month, Hunter has withdrawn $4,200 in cash from the joint USAA account by transferring it into the account that was Kathleen's primary account during the marriage. I reiterate my request that he not withdraw funds from either USAA account, as we have been instructed that those accounts are earmarked for auto-pays. I also ask for an accounting of the cash that has been withdrawn.
We will work on this also.


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


[cid:image003.jpg@01D14DF8.A6C1C540]

******NOTICE*********
This e-mail message is confidential, intended only for the named recipient(s)
above and may contain information that is privileged, attorney work product
or exempt from disclosure under applicable law. If you have received this
message in error, or are not the named recipient(s), please immediately notify
the sender at (202) 331-7522 and delete this e-mail message from your computer.
Thank You.


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