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Re:  Crown v King, Case Number:


            This letter constitutes an offer to enter into settlement negotiations.  This correspondence, regardless of the terms below, is not a strict contract offer that can comprise a contract upon acceptance; rather, this is an offer to negotiate on the general terms set forth below but which can only be concluded and construed to be a binding agreement upon rendition of a specific independent written instrument signed by both of the parties.  This letter and any reference to it shall be inadmissible in any court proceedings as settlement negotiations except that same may be admissible with regard to the issue of attorney’s fees pursuant to Rosen, Diaz and


Dear Jack:


I am in receipt of your letter dated January 10, 2017 for settlement in the above case.  The Father agrees to paragraphs 1; 3; 4; 5; 6; 9; and 11 in your proposed settlement letter.


The Father is not in agreement with paragraph 2.  My client does not agree to designate a school for the child to attend middle school at this time.  The child still has (2) two years in grade school and no one can predict where either party will reside in (2) two years.   The Mother has moved at least (4) four times since 2009.  The Father has resided in the same residence since 2003.


The Father is not in agreement with paragraph 7.  The Father currently has a life insurance policy for the child in the amount of $40,000.00.  The Father would request that the Mother obtain a life insurance policy in the same amount through the child’s minority.  The Father agrees that each party should provide proof of life insurance once a year within 5 (five) days of written request.


The Father is in agreement with paragraph 8 with the following exceptions:


  1. The Father does not agree to designate Jesus People’s Ministry in Miami Gardens for camp for all future years. The Father agrees to exercise shared parental responsibility and both parties can make the choice of what camp the child will attend each year.


  1. The Father also would like to add the change to the current Parenting Plan “that the Mother is solely responsible for dropping off the child on Sunday mornings to the Father’s residence each week”.


The Father is not in agreement with paragraph 10.   The Mother owes the Father $24,428.83 as of January 1, 2017 in child support arrears.   The Father would agree to the following:


The Mother pays a lump sum payment in the amount of $2,500.00 to be paid in two (2) monthly payments on February 1, 2017 and March 1, 2017.  The remaining balance of child support arrears $21,928.83 shall be paid commencing April 1, 2017 in the amount of $300.00 per month until child support arrears are paid in full through and Order directing all payments through Central Depository.


The Father requests the Mother reimburse him for his attorney fees and costs for the having to file a Motion for Contempt and Enforcement for her failure to pay child support and court ordered attorney fee award in the amount of $1,500.00.  The Mother shall pay the Father the amount of $1,500.00 on or before June 1, 2017 paid through and Order directing payments through Central Depository.


I am enclosing my retainer agreement; billing statements; and child support arrears sheet for the upcoming hearing tomorrow.


Please advise if your client is in agreement with the above.


Very truly yours,



Larry D. Schott


Enclosures as noted



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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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