i Feinberg Gary Freedman Wednesday, March 13, 2024 9:41 AM Heidi Feinberg Smith Follow Up Flag: Follow up Flag Status: Flagged (CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the contents sate Heidi, Belowis the response. Please confirm via return email you have received this email. | agree to the proposed division of Real property assets, automobiles, Joint Tenant Account 3905 (collateral for Justine's loan) and IRA‘s/401K's as presented. | do have a couple of changes/clarifications as follows: 1. Our "Remaining Escrow Funds" is nearly $40,000 not $27,000. As previously communicated, | was only able to pay the 2023 Town and County tax bills when | made a payment in December. As a result | would ask that these funds, as previously agreed, be used to pay the taxes due on 31 Main Street and 10018 Deer Park prior to the closing date of their respective sales. | would also propose these funds also pay the back taxes ( 2023 Village and School ONLY) for 2 & 4 Milton Street as well as the $4,500 of "Unpaid Bills". The balance remaining can be combined with 2185 Joint Tenant Account (now nearly $35,000) and the 2193 Joint Invesco Account ($975) to pay for the processing a payment of the 2022 Taxes. | will agree to split the balance remaining after all 2022 taxes are paid 60% Robbin & 40% Me. It’s not worth fighting over. 2. agree to paying the Credit Card and Gas Card balances. | would like to pay these as soon as possible 80 please have the most recent statements sent to me. Robbin will remain responsible to pay the $9100 Ameritrade balance. 3. Personal Property: a. | would ask for the John Deere Tractor, the Utility Trailer and Zero Turn tawn mower to be sold and the proceeds split 50/50. b. | request to have the Amold Palmer/Jack Nicklaus portrait, my family's gold trimmed dishes, my golf travel bag and 3 wheeled golf push cart. Robbin can have the rest. 4, Reservation of Rights:‘Again, the defendant continues to make baseless claims regarding misappropriation of our marital funds and continues to provide general documents as “proof”. This is an order from Art to Frames that was ordered via Robbinest2003@yahoo.com (defendants email address) and the purchased frames were delivered to our home. Also, the defendant has provided what appears to be the same Summary of Paypal purchases in THREE Different formats. The statements show “The Express Purchase" (negative balance) and the Credit Card deposit (positive balance). There is a matching charge on our Capital One credit card that was linked to Robin's paypal account which was under her email of Robbinest2003@Yahoo.com. In fact, the Paypal purchases were made via the defendant's email. The Plaintiff has never had, nor: does not have, a Paypal account. Lastly, the defendant has provided a nameless paypal invoice for an April 2023 (DOC is October 2022) purchase of Bitcoin. Being the nameless and address- less document contains an Order and Receipt number, | am sure the Forensic accountant can substantiate what this account is and who is the ‘owner of the account. The Plaintiff states that t is not the Plaintiff. ‘The Plaintiff has NO concerns with the "defendant reserving rights to rights to bring claims against Plaintiff in the future if she uncovers clear and convincing evidence that Plaintiff has diverted funds and secreted away assets and accounts from the marital estate". It must be agreed in writing, however,that any future claims are processed through legal channels and not through a barrage of emails from the defendant. The Plaintiff does not have Rights of Ownership for any securities, properties or assets other than what has been provided in the Statement of Net Worth. Bob Gary M. Freedman, Esq. 300 72nd Street Niagara Falls, New York 14304 716-512-2499 garyfreedman92@gmail.com CONFIDENTIALITY NOTICE: This email is protected by the Electronic Communications Privacy Act, 18 U.S.C. Section 2510- 2521. The information contained in this message Is privileged and/or confidential and is intended only for the individual or ‘entity to whom itis addressed. ithe reader of this message is not the intended recipient, you are hereby notified that any dissemination or copying of this message is strictly prohibited. If you have received this message in error, please notify the sender immediately by reply email to garyfreedman92@gmail.com and delete this message. Unintended transmission shall not constitute waiver of the attorney-client or any other privilege. CPLR 2103(b)(5) NOTICE: This law firm does not accept service of legal pleadings or interlocutory papers by any electronic ‘means including but not limited to e-mail or facsimile transmissions. IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with U.S. Treasury regulations we inform you that any U.S. tax advice contained in this communication (including any attachments or enclosures) is not intended or written to be used, for