EMAIL DETAILS

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> 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