Subject: RE: Biden
From: "SMancinelli" <[email-masked]>
To: "Rebekah J.H. Sullivan" <[email-masked]>
Cc: <[email-masked]>
Date: Thu, 15 Dec 2016 20:49:48 +0000

Rebekah-

I sent the consent motion to Hunter to review. I will get back to you.

Didn't you subpoena the TD statements? I am trying to get my hands on all you have asked for but I also recall you subpoena'd all of those- unless I am mistaken? What are you referring to when you say "all expenses since the end of the last statement"? I just want to make sure I know what you are asking for.

I will be back in touch on the consent motion. Thank you for preparing it.

Sarah

-----Original Message-----
From: Rebekah J.H. Sullivan [mailto:[email-masked]] 
Sent: Thursday, December 15, 2016 3:38 PM
To: SMancinelli
Cc: Theresa M. Mihalik
Subject: RE: Biden

Dear Sarah,

I sent you the draft Motion to Assign this morning.  Please let me know when you have had a chance to review.

On the disclosures, help me understand why it is taking so long to get this basic information.  Hunter's office confirmed to Kathleen a deposit of more than $120,000 into Hunter's TD account, as funds from the "Romania deal."  There is no reason to continue to delay providing us the TD account statements and all expenses since the end of the last statement.  If there is a reasonable explanation for why those funds are not being used to pay the family's pressing expenses that reason should be shared with us immediately.   Otherwise, please immediately provide Kathleen with half of this deposit.  

We agree with you that the parties are in a very precarious financial situation:  they owe $200,000 in taxes, they owe Kathleen's parents $100,000 (which has not been paid in two years), the credit cards are maxed out, Hunter maxed out a Bank of America cash advance, and their bills are not being paid.  And yet, Hunter has been enjoying time in California with Hallie?  It is more than fair to ask for Hunter immediately to provide Kathleen with half of the $120,000, and immediate disclosure with respect to his TD account.  

Rebekah J.H. Sullivan
Kuder, Smollar, Friedman & Mihalik, PC
1350 Connecticut Ave. NW
Suite 600
Washington, DC 20036

www.KSFMLAW.com
Tel: 202/331-7522
Fax: 202/331-0388

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-----Original Message-----
From: SMancinelli [mailto:[email-masked]] 
Sent: Wednesday, December 14, 2016 4:00 PM
To: Rebekah J.H. Sullivan
Subject: RE: Biden

Thank you for the extension.

I am agreeable to transferring to DR 1. Should we try to do that transfer now and then just do our initial conference on that calendar? If you prepare a consent motion to transfer, I will review.

I am working on the disclosures.

Thank you-
Sarah

-----Original Message-----
From: Rebekah J.H. Sullivan [mailto:[email-masked]]
Sent: Wednesday, December 14, 2016 3:26 PM
To: SMancinelli
Subject: RE: Biden

Dear Sarah,

Yes, we consent to your filing your Answer on or before January 6.

Yes, we will work with you to change the date of the initial hearing.  If possible, let's move the hearing date forward, as these matters are quite pressing.

We intend to move to transfer to DR-1.  Would you join us or consent to that request?

Are you still intending to provide the financial disclosure we have been requesting?  We continue to hope we can resolve this between the parties and counsel.

Sincerely,

Rebekah J.H. Sullivan
Kuder, Smollar, Friedman & Mihalik, PC
1350 Connecticut Ave. NW
Suite 600
Washington, DC 20036

www.KSFMLAW.com
Tel: 202/331-7522
Fax: 202/331-0388

******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.

-----Original Message-----
From: SMancinelli [mailto:[email-masked]]
Sent: Wednesday, December 14, 2016 8:36 AM
To: Rebekah J.H. Sullivan
Subject: Biden

Hi Rebekah-

In looking at due dates, I see our responsive pleadings are due the week after Christmas when I will be out of town for the holiday. Will you agree to an extension of time to a due date of January 6th?

Also, I am not available on January 23rd for the initial hearing. Can we contact chambers together and see what other dates are available? I can then confirm Hunters availability with what they have to offer. 

Let me know if this is agreeable to you and thanks very much in advance. 

Sarah 
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