EMAIL DETAILS

Thank you for taking care of the documents and the money. Let me know when I should expect all of that from you. I am going to let Kathleen’s lawyer know you are good to go with those requests.

And yes, we can make a proposal and avoid the need for mediation. I can make some tweaks to what I drafted previously. Will send to you to review.

From: Hunter Biden [mailto:hbiden@rosemontseneca.com]
Sent: Saturday, December 03, 2016 5:38 PM
To: SMancinelli
Subject: Re: Update

All sounds fine. I'm in CA and plan on being here for the next 10 days at least. Schedule a time for us and I'll be on call. I'll talke care of documents and $ and have Eric get to you. As for mediation / can't we just make an offer and be done with this.

Sent from my iPhone

On Dec 2, 2016, at 9:57 AM, SMancinelli <SMancinelli@ainbanklaw.com<mailto:SMancinelli@ainbanklaw.com>> wrote:
Hunter-

Since we have had a hard time connecting on the phone, I wanted to send you an email to let you know the current status.

First, Rebekah and I discussed and agreed that the fastest and most efficient way to reach an agreement will likely be by way of mediation. We will hire a third-party mediator (likely an experienced attorney), set aside a day, and try to hammer out an agreement. It’s not a technically complicated case so if we can all focus and try to put emotions to the side, we should be successful. I think that is a good path forward but we can discuss more when next we talk.

Second, Kathleen is requesting you pay a $15,000 retainer to her attorneys and a $5,000 retainer to her financial planner she is using in settlement. I would suggest you pay both of these. I would be comfortable sending just $15,000 and having her use that for both retainers. The bottom line is that she has good counsel and I want them to stay involved in the case and I don’t want her filing for divorce just to go to court and ask you to pay her attorneys’ fees.

Third, they have asked for the following documents:

· All statements for your Bank of America Account

· Past six months of statements from Washington First Bank

· 2015 joint tax return

· 2013-2015 business tax returns

On the requests for documents, bottom line- she is entitled to access to all of these documents. Obviously provide her with the tax returns. On the bank statements, I would like to give them as much as possible so we don’t find ourselves in a positon where they won’t discuss settlement because they are hung up on requesting documents from you. I want to get this case resolved as expeditiously as possible and if you stonewall on documentation too much- it won’t happen.

Should I reach out to Eric for any of these documents? Let me know.

We need to talk soon. Do you want to come into the office or meet somewhere to discuss all of this? I also want to go over your settlement options with you.

Let me know.
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)