EMAIL DETAILS

My two cents - I think the email is great but I would add maybe that the motion was filed after there was an agreement to put a hold on litigation. And at this time, Hunter feels the need to respond to the motion and he will be doing so shortly. Until he can do that you can’t get back to them with any response to their latest draft. I think you want to make it clear you are not escalating things by filing a response but merely trying to get back to a more level playing field.

At the end of the day the response to the motion could be the best way for Hunter to respond without going on the record.


Eric D. Schwerin
Rosemont Seneca Advisors, LLC
2900 K Street, NW
Suite 507
Washington, DC 20007
(202) 333-1880
eschwerin@rosemontseneca.com <x-msg://59/eschwerin@obblaw.com>
P Consider the environment before printing this email.

WE’VE MOVED: PLEASE NOTE OUR NEW ADDRESS ABOVE

> On Mar 3, 2017, at 11:50 AM, SMancinelli <SMancinelli@ainbanklaw.com> wrote:
>
> Hunter and Eric-
>
> Please review my draft email to Rebekah. I want your approval before I send.
>
> 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.
>
> 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
>
> From: Rebekah J.H. Sullivan [mailto:RSullivan@ksfmlaw.com <mailto:RSullivan@ksfmlaw.com>]
> Sent: Thursday, March 02, 2017 9:43 PM
> To: SMancinelli
> Subject: Biden MSA
>
> Sarah,
>
> I understand from your assistant you were in mediation all day, so I am sorry to bother you on the heels of that.
>
> Today was obviously a very tough day for Kathleen and the girls. Hunter seems to think the Motion to Enjoin was filed yesterday. Please help him understand it was filed when he denied possession of the diamond, and after the secret deposits into his separate bank accounts. It was filed at a time when the case had been pending for some time with absolutely no media attention. We had no way of predicting the Halle – Hunter story would break yesterday, and as soon as we realized it we tried to get the case sealed. It just moved too quickly for us to do anything at that point. In any event, this is not fair to the girls, and Kathleen wants to quickly work to quiet everything down.
>
> I ask that you please work off of the most recent draft MSA I sent you and turn it around as soon as possible. Please let us know if Hunter can get close to what we are asking for so we can wrap this up and quiet everything down.
>
> 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
>
>
> <image001.png>
> ******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.