My wife has a TRO against me and she is at her parents home now. We have a court hearing next week.

My attorney has reached out to my wife’s attorney with the following offer of settlement for TRO.

  1. Plaintiff dismisses TRO;

  2. Defendant has filed a Complaint for Divorce which Plaintiff’s counsel in the TRO will accept service for, the Consent Order to be entered under the FM docket number;

  3. Parties remain in the marital residence PL, with the Plaintiff in the master bedroom upstairs and the Defendant in the bedroom or guest bedroom downstairs, conversations between the parties only about the child and with the parties co-parenting the child pending the divorce;

  4. In the alternative, if Plaintiff wishes to continue to reside at her parent’s residence PL, Defendant will continue to reside in the marital residence and the parties will share 50/50 custody of the child with pickup and drop off at either residence curbside and communications only about the child between the parties;

  5. Pendente Lite the parties will each deposit $3,000 per month in their joint account to pay all of the status quo marital bills listed below, which are automatically debited from the joint account.

My wife’s attorney reached out to my attorney that he is meeting with my wife tomorrow and will update us after that.

I’ll know what my wife has to say about this settlement tomorrow/weekend hopefully, but I am just curious what to expect in terms of negotiation? What she may and may not accept? What terms and conditions she may come back with? What I must not let go during negotiation? What is ok to let go if TRO gets dropped?

If anyone went through this and can share their experience, that’d be great!

Thank you!