You continue to work on the Mary Green divorce case for Attorney Anita Bryant. John is represented by Attorney Monty Stratton. With their attorneys' guidance and advice, the parties continue to negotiate to reach a complete Marital Settlement Agreement. They have reached an agreement on Child Custody and Physical Placement, as well as on health care expenses for the minor children. There are two proposals under consideration for Child Support and the tax exemptions for the children. John's gross income is $7,500.00 per month; Mary's gross income is $3,500.00 per month.

Prepare a Memorandum from yourself to Attorney Bryant, setting forth the draft agreements on Custody and Physical Placement, as well as on Health Care Expenses. Then add the two proposals on Child Support and the Tax Exemptions. Each section will bear the proper heading, identifying the provision. You may use templates from your state, from Lexis Advance or the template provided (parts I, III and VIII), but this is not a fill-in-the-blank form assignment. This will be submitted as a single Word document, with the proposals contained within the text of the memo.

Memo from: Attorney Anita Bryant

To: Paralegal Staff

RE: Our Client: Mary Green

I am providing you with an outline of the parties' agreement on Custody and Child Support. There are two proposals on child support for us to discuss with our client. The state is attempting to standardize child support awards, and so has come up with several formulas that must be used. I will give you a recap of those formulas. The straight percentage guidelines require the parent who does not have primary placement, who is John Green in this case, to pay child support in the amount of twenty five percent of his gross monthly income for two children. The shared placement guidelines have a five- step formula:

1. Determine each parent's monthly income.
2. Multiply each parent's monthly income by the appropriate percentage standard, in this case 25%.
3. Multiply the results from step 2 by 150%.
4. Multiply the result from step 3 by the percentage of time the children spend with the other parent.
5. Subtract the smaller amount from the larger. This is what that parent must pay monthly in child support.

Under those shared placement guidelines, John Green would also have to pay 30% of the variable costs, such as childcare, tuition, special needs, or other activity costs for the children. Mary Green will need to determine whether his contribution to those costs will offset any reduction in child support payments.

Here is an outline of their agreement:

The agreement on Child Custody is as follows:

• The parties will have joint legal custody.
• Mary will have primary physical placement.
• John will have periods of physical placement of the children consisting of alternate weekends from Friday at 6:00 pm to Sunday at 6:00 pm; overnight placement on alternate Thursdays opposite his weekend; and other reasonable times on reasonable notice.
• Both parents will have access to medical, dental, and school records.
• The parties agree to participate in mediation through the Family Court Mediation Service if there are future disputes.

The agreement on Health Care Expenses is as follows:

• John will provide medical insurance for the children.
• Mary will provide dental insurance for the children.
• The parties will divide equally any uninsured medical, dental, or other health care expenses for the children.

The first proposal on Child Support and the Tax Exemptions is as follows:

• John will pay child support based on the straight percentage Child Support Guidelines. You will need to calculate the monthly amount in dollars, so that Attorney Bryant may show Mrs. Davis the comparable monthly amounts. Show your calculation: $_____ dollars monthly income X _____% = $_____ dollars support.
• John will have the tax exemption for Susan.
• Mary will have the tax exemption for Timothy.

The second proposal on Child Support and Tax Exemptions is as follows:

• The parties agree that the shared time placement will result in the children spending 70% of their time with Mary and 30% of their time with John.
• John will pay child support based on the shared placement child support guidelines. You will need to calculate the monthly amount in dollars. Show your complete 5-step calculation.
• John will also pay 30% of the variable costs for the children.
• John will have both tax exemptions for the children.

Attorney Bryant