Subject: Re: Burnham
From: "Eric Schwerin" <[email-masked]>
To: "George R. Mesires" <[email-masked]>
Cc: "Hunter Biden" <[email-masked]>, "Maschka, Jane E." <[email-masked]>
Date: Tue, 6 Sep 2016 20:06:48 -0400

Thanks, George.

A few comments.   In the third paragraph when we are detailing the breaches, I would reorder them so that they are (ii), (iii), and then (i).  For point (ii), I would end that sentence with “in the time period required by the agreement.” (or whatever legalese you want to get that point across.)

I also think misrepresenting Hunter’s role at Burnham is a key point - not sure how it holds up from a legal point of view - but would move that up with point (iii).

As for the $1m owed Hunter, depends when you want to calculate it.  He’s owed his $800K salary starting July 1, 2016.  If we are going until today’s date it is approaching $1m.  If we are going only to May of 2016 then it is less than $800K.  

Finally, I know in an earlier call you mentioned “fraudulent inducement” as another potential claim we could have on them.  Is that something to throw in here or do we have enough with everything you have in here now?

Thanks for the quick turnaround.

Best,

Eric

Eric D. Schwerin
Rosemont Seneca Advisors, LLC
1010 Wisconsin Ave., NW
Suite 705
Washington, DC 20007
(202) 333-1880
[email-masked] <x-msg://59/[email-masked]>
P Consider the environment before printing this email.

> On Sep 6, 2016, at 7:36 PM, Mesires, George R. <[email-masked]> wrote:
> 
> Hunter and Eric,
>  
> Please see the draft demand letter and let us know of any comments/concerns. The aim is for this to give Burnham the cover that it is acting prudently to accept the terms of Rosemont’s demand for termination of the Asset Assignment Agreement and the Employment Agreements.
>  
> Eric, please confirm the amounts unpaid to RHB.
>  
> George
>  
> George R. Mesires
> Partner
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> <Demand Letter - Sept 6 2016 - JEM revisions.docx>