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i need to do a closing statement for a trial on timesharing, mother wants full custody 80/20 father is unempolyed but mother wants full custody

i need to do a closing statement for a trial on timesharing, mother wants full custody 80/20 father is unempolyed but mother wants full custody

fact mattern:

HUSBAND IS FILING FOR DIVORCE

Date of Marriage January 1, 2005, in Las Vegas, NV

Husband:

Michael Brady 52

Employed by United - pilot- $150k/yr. - for 8yrs

Leased 2018 Porche 911 in Husband's name@ $1,400/mo. - 7months remaining till lease expires

Wife:

Carol Brady 45

Employed by Bern's - bar manager- $75k/yr. - 20yrs

Owned 2018 Porche Cayan in Wife's name @ $700/mo. - 5yrs left till PIF

Owns business "Greater Chaos Marketing" - $50k/yr. - started 2 years ago

4 Kids:

Rodney & Diane (twins)12 - Northside Christian going into 7th grade ($7,500/year per child)

Steve & Marsha (twins) 6 - Northside Christian going into 1st grade ($7,500/year per child)

All children have Prepaid College plans - PIF by Grandparents

Address: 1234 Brittany St

Clearwater, FL 33755

House Worth: $1,250,000

Mortgage: $2,400/mo.

(House is in both their names and bought it 15yrs ago brand new.)

Owe: $300k balance

Toys & Hobbies:

1982 24' Grady White w/trailer (PIF in Husband's name - worth $8k)

2- 2015 Yamaha Waverunners (PIF in Husband's name - worth $25k)

Kayaks/Paddleboards gear (worth approx. $5k)

Pets:

Husky dog: "Balto" 3 years old

French bulldog: "Dexter" 3 years old

Tabby cat "Vincent" 3 years old

Calico cat "Bella" 5 years old

Liabilities:

Amex Husband - $6k balance owed

Visa Joint - $6k balance owed

Discover Wife - $650 balance owed

MasterCard Joint - $3k balance owed

Sak's 5th Credit Card Wife - $2k balance owed

ASSETS:

Retirement Accts:

Husband: 401k $750k

Wife: Roth IRA $300k

Checking Joint: $8k

Savings Joint: $100k

Wife's Engagement Ring: 3ct (VVS1 H) 18kt (valued $30k)

Husband's Rolex - birthday gift from Wife during marriage (valued $8.5k)

Wife inheritance of 10 acres in Ocala, Florida

Husband inheritance of baby grand piano (valued $45k)

Wedding gift of sterling silver flatware- originally owned by Husband's grandparents

Health Insurance (family plan): Paid through Husband's employment - $800/mo.

Life Insurance:

Husband - Term policy through his employment $500k - $50/mo.

Wife - Term private policy $500k - $150/mo.

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