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-----Original Message-----
From: Rebekah J.H. Sullivan [mailto:RSullivan@ksfmlaw.com]
Sent: Friday, March 03, 2017 1:43 PM
To: SMancinelli
Subject: RE: Biden

Sarah,

Obviously I am disappointed by the tenor of this email.

You, also, could have filed a Motion to Seal at any time after we filed our Complaint, but did not do so. Hunter or his parents could have refused to comment on the story about Hallie, which is what brought the attention to the divorce. I am not going to address the things that could have been done to avoid this litigation or avoid the need for the Motion to be filed. We tried.

In any event, if what you say below is true, the solution is a quick, quiet settlement. Your filing an Opposition to our Motion will only push the story. If we must have a hearing, it will result in testimony and evidence that will be specific, which is not in anyone's interest. I am sure you see that as well as we do.

We can make ourselves available Wednesday for mediation, if you and Hunter agree to this path forward. I, frankly, do not see any other way.


Rebekah J.H. Sullivan
Kuder, Smollar, Friedman & Mihalik, PC
1350 Connecticut Ave. NW
Suite 600
Washington, DC 20036

www.KSFMLAW.com
Tel: 202/331-7522
Fax: 202/331-0388


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-----Original Message-----
From: SMancinelli [mailto:SMancinelli@ainbanklaw.com]
Sent: Friday, March 03, 2017 1:33 PM
To: Rebekah J.H. Sullivan
Subject: Biden

Rebekah-

It was a difficult day for everyone- including Hunter.

Bottom line, it was reckless to file that Motion as part of a public court filing and the repercussions of this are and will continue to be widespread- and will negatively impact Hunter, Kathleen, and the girls. While no one could have predicted the exact timing of this story breaking in the press, that fact that it would break at some point was never a question. You could have moved to seal the file before filing that motion- especially since it was never even set for a hearing.

Hunter’s business has already been impacted and his income earning potential has been jeopardized if not already damaged. This is bad for everyone.

What Hunter was prepared to do last week at mediation, literally may no longer be possible. And candidly, his willingness to be as generous as he offered before, is now limited if not non-existent.

I am in trial next Monday and Tuesday and Hunter has a meeting he cannot reschedule on Thursday. I am going to talk with him about how to proceed from here but at this juncture, the path I saw to settlement on Tuesday is no longer achievable.

Furthermore, Hunter will now need to file an opposition to the motion instead of focusing on settlement as we had hoped. This is, again, all truly unfortunate.

I am not sure what, if anything, can be done at this point to salvage this. I assume you will brainstorm with Kathleen to that end.

Sarah