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In Re: The Marriage of                                            Case Number:












The parties agreed to the following in open Court:


  1. Wife shall have temporary sole parental responsibility – The Husband shall submit himself to BARC for an alcohol evaluation. The Husband shall be solely responsible for all costs associated with his evaluation.   The Wife shall be provided with a copy of the evaluation once completed.  The Husband shall comply with any and all recommendations of BARC, if any.


  1. Marital Home – The marital home is upside down. The Wife agrees to continue to reside in the home until it’s sold and to list the marital home for sale in six (6) months.  The parties would equally (50/50) be responsible for any deficiency.
  2. Reunification Therapy -The Husband shall attend counseling and reunification therapy. The parties agree that the Mother shall select the low cost therapist.   The parties shall abide by the recommendation of the therapist.


  1. Wife’s 401(k) with Fidelity & Wife’s Primerica – The Husband shall receive his 50% share from the date of marriage to date of filing of Petition November 2015 of the Wife’s 401(k) with Fidelity and Primerica.  The parties shall equally share the cost of the QDRO and/or QDRO’s to effectuate the distribution.


  1. Husband’s 403(b) and Husband’s FRS Retirement – The Wife shall receive her 50% share from the date of marriage to date of filing of Petition November 2015 of the Husband’s 403(b) and FRS Retirement.  The parties shall equally share the cost of the QDRO and/or QDRO’s to effectuate the distribution.
  2. Orlando TimeshareThe Wife would receive the Orlando Timeshare titled in both parties names and be solely responsible for the payment, taxes, insurance and all costs associated with the Timeshare. The Husband would execute any and all documents to transfer the Timeshare to the Wife’s sole name.
  3. Automobiles– Both parties keep their automobiles and agree to execute any documents to transfer in their sole names, if needed.




  1. Student Loans – Both parties shall be solely responsible for their student loans.


  1. Loan with Allied Interstate– (Husband’s student loan) The Husband obtained this loan on his own. The Wife never received any monies and the Husband should be solely responsible for the payment of this loan.


  1. Credit Cards– Each party to be solely responsible for their own credit card debts, if any.
  2. Alimony:


Neither party shall receive alimony from the other.  Each party waives alimony now and forever.


Child Support:


  1. The Husband shall pay child support pursuant to the attached child support guidelines commencing XXXXX XX, 20__ by Income Withholding Order. The Wife waives retro-active child support.


  1. Parties agree to pay their guideline percentage of uncovered medical/dental, the tutoring, and extra-curricular activities.


  1. The Wife is providing health insurance for the children through her employment and shall continue to do so as long as it is reasonably available through her employment.


  1. .Prepaid College:


The parties shall continue to pay both children’s pre-paid college plan 50/50 each month until paid in full.


  1. Attorney Fees and Costs:


Each party shall pay their own attorneys fees and costs.



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This document is a sample pleading related to a specific set of facts and circumstances and should not be used or relied upon for any family law matter. This document is being provided for illustrative purposes only. We recommend and urge you to consult with an experienced divorce lawyer for professional advice as each case is unique.

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