Dear Jusge Schillari-Rich:

This firm represents the defendant, Bruce Tanis, in the above referenced matter.

We are in receipt of Your Honor’s order, entered on December 16, 2019.

This letter is to request that the court amend paragraph 4 of the order and exclude
the defendant’s line of credit against his stocks from the order and allow him to
pay his monthly bills utilizing the line of credit, pursuant to the status quo,
without having to request permission from the defendant in order to do so, which
will only create unnecessary chaos and force the parties to incur additional
counsel fees.

The Defendant’s nontraditional bill payment system requires some further

clarification with The Court, so that Your Honor could understand that
historically, since 2007, the defendant has always relied on a margin line of
credit against his premarital stock portfolio.

This line acts similarly to an overdraft line of credit but the rules fall under
Federal margin regulations. Federal Regulation T (Federal Reserve Board 12 CFR
§220 – Code of Federal Regulations, Title 12, Chapter II, Subchapter A, Part 220),
requires that active margin accounts must be actively maintained, and interest and
principal must be paid on a timely basis, or compounded interest accruals and/or
potentially adverse market movements could trigger a margin call and forced
liquidation of assets. Such a chain of events would cause a significant tax
liability and significant financial hardship to the Defendant.

All accounts referenced here are single name accounts, titled solely in Mr. Tanis’s
name, and always have been in single name since 2007.

Mr. Tanis’s stock account, line of credit and checking/debit/ATM account were all
opened in 2007, at which time they were funded 100% with premarital bonus money and
premarital stock shares in Citigroup, the company which at the time owned Smith
Barney.

The Citi shares were granted to him as part of his 2007 compensation contract,
negotiated with Smith Barney in January of 2007.

Under the acquisition of Smith Barney by Morgan Stanley occurring on January 13,
2009, Citi shares owned by Mr. Tanis were converted into Morgan Stanley shares as
of January 13, 2009, the acquisition date. This is how Mr. Tanis acquired those
shares and all liquid and equity assets in that account.

The overdraft credit line, also opened in 2007, has been in use in that account
against his stock for years since then, before the parties even met. There is a
checking account linked to the stocks, with a separate account number in Mr. Tanis
his sole name, also opened in 2007.

Defendant purposely and carefully set up joint checking accounts with Plaintiff
after the marriage, at Citibank and later at Morgan Stanley, separate from his
single, premarital assets, whereby part of his paycheck was split-direct-deposited
into the joint accounts, keeping assets separate so that they could pay jointly-
incurred expenses without commingling any premarital assets. My client was very
careful not to comingle these separate assets.

Mr. Tanis uses this overdraft line, his income, deposited into a checking account
linked to the overdraft line, and his stock dividends to pay all of his monthly
bills, which amount to approximately 15 bills per month. There are also rental
payments from his Florida house (purchased and titled in single name before the
marriage) and other items being direct -deposited monthly into this account. Total
number of transactions in and out of this account can exceed 20 per month.

The account is Mr. Tanis’s sole source of cash, transportation costs, gasoline,
auto repairs, business entertainment funds, medical deductibles, apartment and home
maintenance costs, parking, tolls, and other items, including counsel fees.

My client’s paychecks are direct-deposited to this checking account and the amount
of the paychecks is credited against the line of credit to reduce interest costs
and prevent unnecessary margin calls.

Having to request permission from Ms. Antonopoulou through counsel to pay every
single bill is burdensome, impractical, and forces both parties to incur counsel
fees.

Furthermore, given the history of this case thus far, and Plaintiff’s counsel’s
letter-writing campaigns and general intransigence, we anticipate every bill will
be questioned, which is unfair and prejudicial to my client, and will allow
plaintiff to micromanage defendants bill-paying mechanisms. This is against the
status quo. Plaintiff never paid any of Defendant’s bills nor did she make any
deposits to defendants premarital accounts or contribute to them in any way. None
of these accounts was ever commingled with any joint or marital assets.

It would be extremely burdensome, impractical and much more costly for Defendant to
request permission every time a bill needs to be paid. Many of the regular bills
are automatically paid from the linked checking account, and have been paid that
way since well before the marriage.

Based upon the foregoing, we are respectfully requesting that the court amend
paragraph four of the December 16, 2019 order. We have prepared an enclosed a
proposed Supplemental Order for Your Honor’s review and consideration.

Alternatively, we are respectfully requesting a telephonic conference call with

your honor regarding this issue to explain the matter in more detail. We think your
honor for your courtesies in this matter.

Respectfully requested,