Without Prejudice Offer Help

Hi

I bought the Wikivorce Legal Advice on Financial Settlement pakage and got advice from solictor and written report previously.

I have read the wikivorce forum and looked at previous posts on Without Preduice Offer.

Please can someone look at my offer letter for upcoming FDR and tell me what they think?

Should i set out at the end of the offer letter bullett points and summerise why i made the offer in relation to Section 25 of Law. Housing needs, earning capacity, income needs..... Or should i keep this for the postion statement and not write anything at the end of my offer letter?

I am the applicant for Financial remedy (Husband).
I am Litagant in Person
Ex wife has solictor and barrister

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Applicant (me)
Without Prejudice Offer

Date of offers exchange between both parties xxxxxx

I the Applicant X would like to offer the following: I propose that the court dismiss all claims against each other and there be a Clean Break.

Sell matrimonial home (Address)
Sell Buy to Let Property (Address)

1. Responded (Wife name) x% of HUSBAND NON-PENSION ASSETS (net) figure (please see Updated Court spreadsheet ES2)
2. Responded (Wife name) pension sharing order x% of Husband Civil Service Pension (please see Updated Court spreadsheet ES2)) (pension share implementation fee to civil service pension of £X to be paid by responded)

3. Applicant (Husband name) x% of HUSBAND NON-PENSION ASSETS (net) figure (please see Updated Court spreadsheet ES2)
4. Applicant (Husband Name) x% of Applicant (X) Civil Service Pension (please see Updated Court spreadsheet ES2)

I would normally summarise the pot and the respective needs of the parties first.

We have X, Y and Z assets and a,B,c incomes.

The children spent most of their time with me. They need to remain close their school and community of friendship. I need to be near my well established support community. A suitable property in xxxx are would cost yyyy. I can raise a mortgage of zzz and will have costs to pay so need aaaa from the capital to provide a secure and stable home for the children.

This represents X% of the equity of the FMH.

XxX has the children every other weekend and does not need to live close to the school. His strict need is an X bed property. This would cost some Xxx. He can raise a mortgage of Yyyy.

Between us there are matrimonial savings of zzzz and pension funds amounting to YY.

Given the disparity in our incomes I believe there is a case for a departure from equality.

My without prejudice proposal is therefore:

Bullet point

Sell FMH and divide proceeds of sale, after costs, xx:YY in my favour.
Sell BTL and divide proceeds of sale after costs and CGT xx:YY in Xx's favour.

Savings in xx account are to be shared equally.

There is to be a pension share of xxxx pension in line with the actuary's recommendations (or other as appropriate). NB costs of pension sharing are normally divided equally.

There is to be a clean break.

I hope you/ your client will give this proposal due consideration. I look forward to receiving a response within X days. ( Always give a deadline)

Hadenoughnow

Thank you for reply. I have read you previous post on this forum and have also now added :

"The proposal to settle should set out a rationale in line with the section 25 factors ie needs and how they can be addressed. So housing needs, costs, mortgage capacity, deposit required, debt to be cleared etc. It should also set out income vs needs and how that could be maximised if it isn't atm. If there's an actuary's report, set out how pensions should be treated in line with the calculations. If possible work out what the overall division of assets works out at"