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Larry D. Schott, Esq.

Board Certified, Marital & Family

Law, The Florida Bar                                                     March XX, 20__








Re:      Doe v Doe, 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 its progeny.


Dear Mr. XXXXX:

In order to resolve some of the issues in the above case my client would offer the following:


  1. Wife shall have temporary sole parental responsibility – until the Husband successfully completes counseling and reunification therapy with the children with a therapist mutually selected by the parties. Additionally, Husband to complete an alcohol abuse evaluation.


  1. Assets:


  1. Marital Home – Marital home is upside down. The Wife agrees to continue to reside in the home until sale and to list the marital home for sale in six (6) months.  The parties would equally (50/50) be responsible for any deficiency.
  2. Wife’s 401(k) with Fidelity & Wife’s Primerica – The Husband would receive his 50% share from the date of marriage to date of filing of Petition November 2015.


  1. Husband’s Retirement AccountsThe Wife would receive her 50% share of any retirement accounts from the date of marriage to date of filing of Petition November 2015.


  1. 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.


  1. Automobiles– Both parties keep their automobiles and agree to execute any documents to transfer in their sole names, if needed.


  1. Husband’s 403(b) – The parties split 50/50 by QDRO as of date of filing.


  1. Husband’s FRS Retirement – The parties split 50/50 by QDRO as of date of filing.





  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.



Neither party shall receive alimony from the other.


  1. Child Support:


  1. The Husband shall pay child support pursuant to the guidelines commencing XXXX XX, 20__. The Wife waives retro-active child support.


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


  1. Wife is providing health insurance for the children.


  1. .Prepaid College:


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


  1. Attorney Fees and Costs:


Each party pay their own attorneys fees and costs.





Please immediately advise.


Very truly yours,




Do You Have a Question?

If you have a question about a family law case, please feel free to call us at 954-880-1302. We promise to get back to you promptly.

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.

To Learn About Larry Schott’s Qualifications as a Divorce Lawyer and Family Law Advocate, See His About Me Page.