Without Prejudice

Memorandum of Understanding

made between

Client 1 Client 2
Address 1 Address 1
Address 2 Address 2
Postcode Postcode

We, Client 1 and Client 2, have been in mediation with Mediator, mediator of Family
Mediation (Northern Ireland) in accordance with the professional requirements and
code of practice of the Family Mediators Association.

This Memorandum of Understanding summarises the outcome of our discussions in
mediation. It is written on a without prejudice basis and is legally privileged.

We have been advised to instruct separate solicitors and have acknowledged this on
signing our Agreement to Mediate. This Memorandum of Understanding is intended
to facilitate us each obtaining independent professional advice and is not, therefore,
a legally binding document unless and until we decide to enter into such a binding
agreement.

In the course of our mediation we have established various priorities and objectives.
These include being fair to each other, by our own agreed standards, working the
best interests of our children and balancing our respective interests and objectives
and consequently coming to an arrangement, which reflects our current and future
needs.

Background Information

Client 1 and Client 2 were married for 00 years, and separated in DATE. They have
three children, Child 1 aged 00 years, Child 2 aged 00 years and Child 3 aged 00
years. The children live with their mother Client 1 in the matrimonial home, with dad
having structured and regular contact with all three children.

1. Dates of Individual pre mediation appointments: 11 November 2011
17 November 2011

2. Dates of mediation appointments:
28 November 2011 Joint Mediation
06 December 2011 Joint mediation
13 December 2011 Review of MOU



The agreed agenda for mediation:

1. Contact arrangements for Child 1 Child 3 and Child 2
2. Sharing information with the children
3. Respecting the decisions of the children
4. Sharing information with each other
5. Sharing the parenting responsibility
6. Mutual agreement concerning discipline and rules
7. Entering each others property
8. Changes to Child 1s tutor time and location
9. Christmas 2011
10. Holiday arrangements
11. Review date

Principles applied to the discussion of these issues by Michael and Lizanne:

1. The best interests of Child 1, Child 2 and Child 3 to be considered
2. Truthful and honest communication within the process of mediation
3. To be reasonable and fair to the other person
4. Decisions in relation to this process remain with Michael and Lizanne

With our agreed principles in mind we reached the following understandings:

1. Contact arrangements for Child 1, Child 3 and Child 2
1) We both agree and support the meaningful contact between Michael and
Child 1, Child 3 and Child 2.
2) We agree that Child 1 spends Sunday, Monday and Thursday overnight at
his dads. Child 3 spends Thursday and Sunday night at his dads. Child 2
spends Thursday night at her dads and also a 3pm-7pm on a Sunday. It has
been discussed and agreed in mediation that if Child 2 wants to spend
overnight at her dads on the Sunday that she is free to do so, or in the
event that Lizanne has something planned for a Sunday night that Child 2
will stay with her dad at his house.

2. Sharing information with the children
1) We agree that we shall communicate any changes to plans or
arrangements with the children.
2) We agree that communication between us should always be respectful
and that we will not say negative things about the other parent in front of
Child 1, Child 3 and Child 2.
3) We recognise that this is necessary to foster a positive co-parenting future
and work together in the interests of Child 1, Child 3 and Child 2.

3. Respecting the decisions of the children
We agree that in the parenting of our children we will involve them in the
decision making processes and will respect their decisions, without making
them feel guilty or under pressure.


4. Sharing information with each other
We agree that we shall communicate any changes to plans or arrangements
made as soon as possible, this shall also take place before changes are
communicated to and confirmed with the children.

5. Sharing responsibility
We agree that if we need to ask for the other parent to do a pick up/drop off
or attend an event last minute that we will free to do so. We are in agreement
that we will do our best to accommodate the request of the other parent at
that time.

6. Mutual agreement concerning discipline and rules in both houses
We agree that we will adopt and carry out the same methods of discipline and
rules in both houses, and will support each other in the implementation of
these. The children will be informed of our decisions regarding rules etc that
apply in both homes.

7. Entering each others homes
We agree that we will not enter the others house unless we have the
permission to do so.

8. Christmas contact
We have agreed that Michael will collect Child 1, Child 2 and Child 3 on
Christmas morning after they have opened their presents and Child 1 and Child
3 will spend Christmas day and night at their dads house. Child 2 is free to
choose how long she would like to spend with her dad on Christmas day and is
welcome to stay the whole day and have dinner there.

9. Holiday arrangements
We agree that we shall discuss with each other any holidays we would like to
book with the children before we go ahead and do so.

10. Review date
We agree to return to Family Mediation NI on the 06 of March 2012 to review
the current arrangements.



Further action by FMNI: Client 1 and Client 2 to be contacted by FMNI to remind
them of review appointment or to be contacted by the clients for an earlier
appointment if necessary. It is further explicitly agreed between the parties that
neither mediator involved in this mediation will be asked to attend court or give
evidence about the content of this agreement.



Signed:


_______________________________________________
Client 1


_______________________________________________
Client 2


_______________________________________________
Mediator



Distribution of this Outcome Summary
Client 1
Client 2
Family Mediation file




Date of statement: 13 December 2011