EMAIL DETAILS

See below. I don't know if they will actually file but if they do, better if I accept service than you having to be personally served. Let me know if I can tell her that I accept service for you.

Let me know on the draft proposal.

Begin forwarded message:

From: "Rebekah J.H. Sullivan" <RSullivan@ksfmlaw.com<mailto:RSullivan@ksfmlaw.com>>
Date: December 7, 2016 at 3:03:36 PM EST
To: 'SMancinelli' <smancinelli@ainbanklaw.com<mailto:smancinelli@ainbanklaw.com>>
Cc: "Theresa M. Mihalik" <TMihalik@ksfmlaw.com<mailto:TMihalik@ksfmlaw.com>>
Subject: RE: Biden Matter

Sarah,

Please let me know if you have any update, and if not, whether you are authorized to accept service. The housekeeper’s check bounced for a second time in a row, the BB&T loan was not paid, and the office let Kathleen know (you did not respond to my prior question about this) that the taxes were not paid and the parties owe over $200,000. Hunter needs to transfer money to Kathleen today.

Less urgently, but very important to Kathleen, Hunter needs to get his personal property out of the garage.

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: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
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Thank You.


From: Rebekah J.H. Sullivan
Sent: Tuesday, December 06, 2016 2:40 PM
To: SMancinelli
Cc: Theresa M. Mihalik
Subject: RE: Biden Matter

Thank you

From: SMancinelli [mailto:SMancinelli@ainbanklaw.com]
Sent: Tuesday, December 06, 2016 12:56 PM
To: Rebekah J.H. Sullivan
Cc: Theresa M. Mihalik
Subject: RE: Biden Matter

FYI- I am working diligently on this. If I don’t get something back to you today, I should be able to tomorrow. Just know, this is a priority for me.

From: Rebekah J.H. Sullivan [mailto:RSullivan@ksfmlaw.com]
Sent: Monday, December 05, 2016 3:59 PM
To: SMancinelli
Cc: Theresa M. Mihalik
Subject: RE: Biden Matter

Dear Sarah,

Thank you for the update, but we are concerned that it does not move us where we need to go.

Hunter’s office has made clear they do not have access to Hunter’s TD account statements or other information, so they would not be able to provide that to you to provide to us. The office does not have all the information we need, as evidenced in part by the fact that the budget they prepared falls far short of the $2.4 million that Hunter earned last year (per the tax returns). In short, they do not know where the rest of the money is or went.

Kathleen also found out from the office that payments on the Chase card have been late through the past few months, and that there is an America Express card, on which Kathleen is primary, with a balance of $16,000. This is not on your spreadsheet that I can tell, and is extremely concerning.

Kathleen has a right to know when money is coming to her and how much is coming. It is the holidays, and she does not know whether she has money for Christmas expenses. Although you and Hunter have both communicated that you want to do this process amicably and fairly, a bare minimum of good faith would involve immediately proposing an amount of money to be transferred regularly to Kathleen and letting her know when that will happen. Hunter continues not to make any such proposal.

In short, unless we receive the information we have requested immediately and are immediately able to reach an agreement on temporary support, we have no choice but to file. Please let me know if you are authorized to accept service, and if there is any way we can work this out immediately to avoid our filing.

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: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.


From: SMancinelli [mailto:SMancinelli@ainbanklaw.com]
Sent: Monday, December 05, 2016 10:14 AM
To: Rebekah J.H. Sullivan
Subject: Biden Matter

Hi Rebekah-

I have had a hard time connecting by phone with Hunter- primarily as a result of my crazy week last week. But I sent him a comprehensive email explaining where we are and the requests Kathleen has made for statements and retainers for you and Debbie May. Hunter confirmed he would have his office make available both the requested statements and money for the retainers. I asked him to take care of that ASAP. I will let you know as soon as I have that from him.

Just wanted to give you that update.

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)