IN THE CIRCUIT COURT OF THE

NINTH JUDICIAL CIRCUIT, IN AND

FOR ORANGE COUNTY, FLORIDA
CASE NO:
IN RE: THE MARRIAGE OF
,
Petitioner/Wife,
vs.
,
Respondent/Husband.
/
JOINT STIPULATION ON RESPONDENTS VERIFIED MOTION FOR
EMERGENCY TEMPORARY SOLE CUSTODY
Respondent, (RESPONDENT), and Petitioner, (PETITIONER), hereby file
this Joint Stipulation on Respondents Verified Motion for Emergency Temporary Sole
Custody and agree as follows:
1.

The parties are currently subject to a Final Judgment for Dissolution of

Marriage and Parenting Plan dated which was amended.

2.

The parties hereby agree that:

a) This Courts Order entered October 22, 2014 will remain in full force and
effect until the end of the current school year, or until June 4, 2015. The
Court will then schedule a hearing to revisit the Temporary Sole Custody
matter and Petitioners fitness as a parent for the parties shared children;
b) The Time Sharing Plan contained within the Parenting Plan is modified as
follows:
(i)

The parties will split time sharing equally, that is, 50/50 on a week
to week basis beginning Monday evening at 6:00 p.m. until the
following Monday evening at 6:00 p.m. where the time sharing
will switch to the other parent with the same schedule, Monday
evening beginning at 6:00 p.m. until the following Monday
evening at 6:00 p.m. Based upon the time-sharing schedule, the
Father has a total of 183 overnight stays per year, and the Mother
will have a total of 182 overnight stays per year.

(ii)

The Holiday schedule will remain the same, except that,

1. Easter, Father will get even years and Mother will get odd
years;
2. Halloween, Father will get even years and Mother will get odd
years;
3. Birthdays, Father will get odd years and Mother will get even
years;
4. Christmas Day 12:00 noon to 12:00 noon the following day,
Father will get odd years and Mother will get even years, the
current Christmas Eve schedule will remain as is.
(iii)

For school and school district purposes, the Fathers address shall
be designated.

(iv)

Child care Each parent may select appropriate child care

providers without the other parents approval. In the event a child
care provider is needed for longer than 12 hours the other parent
will be given the opportunity to care for the children.

(v)

Section XIV Other Provisions stipulations under the Parenting Plan

are hereby removed.

c. The Father will claim the parties minor daughter on his 2014 Federal
Income Tax Return, and every year thereafter if she remains in Fathers
custody. Father will maintain exclusive right to claim the parties minor
son on his Federal Income Tax Return.
d. The parties former marital home awarded Petitioner in the MSA located at
is currently in foreclosure proceedings in Orange County, Florida, Case
No.. Petitioner will quit claim deed the former marital home located at to
Respondent.
e. Respondent will no longer be required to maintain life insurance in the
face amount of TWO HUNDRED AND NINETY-FIVE THOUSAND
DOLLARS AND ZERO CENTS ($295,000).
Dated: November 18, 2014.
Respectfully Submitted,
RESPONDENT

PETITIONER