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Hunter, see attached draft from Sarah.

My thoughts whether you want something more definitive in this where Kathleen expresses regret for filing the motion. Perhaps adding in at the end of #4, “…..and regret that recent litigation made it difficult to do so.”

So the fourth point would say:
Both parties value and respect the contributions each made to their marriage and are committed to closing this chapter of their relationship in a dignified, respectful, and family-focused manner and regret that recent litigation made it difficult to do so.


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.

> Begin forwarded message:
>
> From: SMancinelli <SMancinelli@ainbanklaw.com>
> Subject: draft motion
> Date: March 3, 2017 at 7:31:21 PM EST
> To: "Hunter Biden (hbiden@rosemontseneca.com)" <hbiden@rosemontseneca.com>, "Eric Schwerin (eschwerin@rosemontseneca.com)" <eschwerin@rosemontseneca.com>
>
> Guys-
>
> See the attached. I am not sure what your thoughts are on this but I think it is something to consider. And I would suggest you discuss it with whomever you are talking to about these things (press people, etc.). It’s a first draft. I welcome edits.
>
> I think this would be a good way to change the story and get everyone to focus on resolution. And it can be lifted at any time.
>
> Give it thought.
>
> 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)