Attorney says mediation is a fluid thing and not to go in with expectations but I don’t play like that. Here’s what I have in mind so far:

General:

Legal fees for defense from frivolous restraining order attempts paid by STBX

Legal fees for attempting to get kids’ SSNs, dog rights, addressing other violations of my parental rights paid by STBX

If there is a conflict and a party refuses to mediate, the refusing party will pay court/lawyer fees.

If an agreement needs to be enforced, the “guilty” party pays court/lawyer fees.

Right to family pets

Documents - SS#, Passport, Birth Cert. - stat with me. She has proven to be recalcitrant re: things I am entitled to.

Right to international travel.

House:

If house is to be sold - if she remains in the house, she will pay mortgage and all other house related expenses until it’s sold. (She’s in the House now and I’m paying the mortgage)

If one party buys out the other, the agreed upon price will be the 1/2 average of x# estimates.

If I buy her out the transfer will happen on x date and will include the following property. STBX will pay for necessary repairs to the house resulting from neglect or intentional damage during her time in the house since July 19 2019.

Think of anything else?

Edit: a lot of stuff has already been covered by our temporary agreement, especially regarding the kids and healthcare etc.

We are currently finishing up a custody evaluation that will probably have a big say in determining a lot of issues regarding the kids.

I’m sort of looking for other things that other people have found useful. For instance, the penalty for refusing to mediate was brought up to me by a friend.