IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR

MIAMI DADE COUNTY, FLORIDA

IN RE: THE MARRIAGE OF:

CASE NO: 2019-005770-FC-04

Petitioner/Husband, FAMILY LAW DIVISION
vs.

Respondent/Wife,
_______________________________/

MARITAL SETTLEMENT AGREEMENT

THIS MARRITAL SETTLEMNT AGREEMENT (hereinafter, “Agreement”), by and

between (hereinafter referred to as “Petitioner/Husband”) and
(hereinafter referred to as “Respondent/Wife”) made and entered into by both
parties on this ____ day of April 2019, is as follows:

WITNESSETH:

WHEREAS, the parties to this Agreement were lawfully married on March 27th, 2014 in
Miami, Florida.
WHEREAS, the parties to this Agreement have separated and now live apart from each
other and are residing in separate homes.
WHEREAS, Petitioner/Husband has filed a petition in the Circuit Court of Miami-Dade
County, Florida to dissolve the marriage. This Agreement is intended to be a full settlement of all
matters now pending in that action, and all claims or rights of any kind existing between the parties,
including a division of the marital assets, provisions for support of Respondent Wife, and any other
obligations growing out of their marriage relationship.
WHEREAS, each party hereby waives, releases, and relinquishes any actual or potential
right, claim, or cause of action against the other party, including but not limited to asserting a claim
against the estate of the other party or to act as a personal representative of that estate, except as
otherwise provided in this Agreement or arising hereunder.
WHEREAS, the terms and provisions of this Agreement are enforceable in contract, in
addition to any remedies for enforcement that may be available under any final judgment of
dissolution of marriage entered into between the parties.
NOW THEREFORE, in consideration of mutual promises and undertakings hereinafter
made, the parties do freely and voluntarily agree to the terms of this Agreement. The adequacy of
consideration for this Agreement is admitted and each party intends to be legally bound by it. The
terms are as follows:

1. SEPERATION: The parties shall continue to live separate and apart. Each party shall continue
to reside at a place of his or her choosing without interference from the other.
2. PERSONAL PROPERTY: The parties have agreed to the equitable distribution of their
property. The Petitioner/Husband shall have exclusive ownership of 2014 Nissan Pathfinder
automobile and the Respondent/Wife shall have exclusive ownership if 2014 Honda Civic
automobile. Petitioner/Husband shall assume all debts and liabilities associated with said
vehicle. Petitioner/Husband shall take all necessary steps to confirm his sole ownership and
release Respondent/Wife of any outstanding liability, this includes the removal of
Respondent/Wife as vehicle’s cosigner and transfer of registration and title to reflect only
Petitioner/Husbands name. The parties shall retain all other items presently in their possession
and each party waives and releases any and claim or interest that either may have in the
personal property of the other.
3. BANK ACCOUNTS: The parties agree to equal division of funds held in joint bank account
through Chase Bank. Each party is entitled to half of the funds reflected in joint bank account
on April 1, 2019, the date wherein initial pleadings were served upon Respondent/Wife’s
attorney. Each party waives and releases any and claim or interest that either may have in the
other’s banking/financial accounts.
4. JOINT ENTERPRISES: Respondent/Wife relinquishes any interest in Husband/Petitioner’s
corporation, Cool Air Sky Dive, Inc. Parties agree that Husband/Petitioner shall retain
exclusive and sole ownership of the company.
5. JOINT DEBTS: The parties hereby covenant and agree that they have either canceled or
surrendered all joint credit cards and specifically covenant and agree not to incur any further
joint charges as of the date of the execution of this Agreement for which the other party may
be liable. Each party shall be responsible for any and all other debts and/or credit card accounts
that are in their individual names.
6. ALIMONY: Respondent/Wife shall receive durational alimony in the sum of Two Thousand
and Five Hundred ($2,500.00) Dollars per month for a total of thirty(30) months, commencing
on May 1, 2019 and continuing until the alimony has been paid to Respondent/Wife in full,
through and including November 1, 2021.
7. FILING OF INCOME TAX RETURN: The parties have filed a joint federal income tax return
for the year 2018. The parties have agreed to share their federal income tax refund for the year
2018 in equal parts. The parties agree that they will each file their federal income tax separately
for the 2019 tax year and for all subsequent years thereafter. Each party shall bear their own
tax liability from their respective individual filings
8. FINANCIAL DISCLOSURES: The parties agree that they have fully and completely disclosed
their assets and liabilities to each other. The parties agree to waive further disclosure unless
either party fails to disclose or actively conceals any assets or liabilities.
9. ATTORNEYS FEES AND COSTS: Petitioner/Husband shall pay the sum of Three Thousand
Dollars ($3,000.00) to Cristina Bosmenier, Esq., Attorney for Respondent/Husband for legal
services rendered and for costs and necessary disbursements expended or to be expended. The
sum may be paid in three (3) equal installments of $1,000.00 on the first day of each month,
beginning with May 1, 2019. If Petitioner/Husband fails to pay any installment when due, the
delinquent payment bears interest at the rate of 12% per year until paid. If all or part of any
installment is in default for 60 days, the entire remaining balance shall become due and payable
immediately. Petitioner/Husband shall sign a promissory note for the above amount payable to
Cristina Bosmenier, Esq.
10. RELEASE OF ALL CLAIMS: Except as otherwise provided in this agreement, the Wife and
Husband mutually forever renounce and relinquish all claims whatsoever nature each may have
in or to any property or estate whatsoever kind, now or hereafter owned or possessed by the
other, it being the intention of the other parties hereto that this paragraph shall constitute a
complete, general and mutual release of all claims whatsoever including dower, curtesy,
inheritance, descent, the right to act as executor, administrator or personal representative of the
other party's estate, distribution or any other rights or claims arising out of the marital
relationship.
11. INDEMNIFICATION: To the extent not previously provided for herein, each party hereby
agrees to indemnify and hold the other party harmless at all times following the execution date
hereof against and with respect to any damages, actions, demands, losses, costs, expenses,
taxes, or liabilities incurred by the other party (including attorney's fees and court costs)
deriving from any claim or claims of any creditor or governmental entity of the other party,
without limitation.
12. BANKRUPTCY: The parties agree that all releases and hold harmless provisions contained in
this Agreement are in the nature of alimony and support and, as such, are not dischargeable in
any bankruptcy proceedings. If the court does not interpret the obligations contained in this
Agreement as nondischargeable in bankruptcy, all releases and hold harmless provisions
contained in this Agreement are null and void.
13. INDIVIDUAL ENTERPRISES: It shall be lawful for each of the said parties to conduct, carry
on and engage in any employment, business or trade, whichever she/he may deem fit, free from
control, restraint or interference directly or indirectly by the other in all respects, as if such
person were sole and unmarried.
14. NON-WAIVER PROVISION: The failure of either party to insist in any one or more instances
upon the strict performance of any of the terms or provisions of this Agreement shall not be
construed as a waiver or relinquishment of the future performance of any such provision and
same shall continue in full force and effect. No waiver or relinquishment shall be deemed to
have been made by either party unless in writing.
15. COVENANT TO INTRODUCE AGREEMENT INTO EVIDENCE-CONSENT: Each of the
parties hereto agrees that she or he, either as the petitioner or respondent, shall offer in evidence
this Agreement in their petition for dissolution of marriage of the parties hereto, and consents
and agrees that the Court having jurisdiction of such action shall and by these presents does
have the authority and power to incorporate in any interlocutory or final decree or judgment
entered in such cause, the provisions of this Agreement in their entirety and that this Agreement
4 and the provisions of this Agreement in their entirety shall be and become part of any such
interlocutory or final decree entered in such cause. The parties wish that this Agreement
survive the Judgment and be binding on the parties for all time
16. INDEPENDENT LEGAL ADVICE: The parties acknowledge that they each have been
afforded the opportunity to seek independent legal advice by an attorney of his or her choice
in the negotiation of this agreement.
17. INDEPENDENT INCOME TAX ADVICE: The parties acknowledge that they have not
received tax advice from their respective counsel concerning the tax consequences of this
Agreement. The parties further acknowledge that they have been advised to seek their own
independent tax advice by retaining a certified public accountant, accountant, tax attorney or
tax advisor. Each party has had an opportunity to consult with a tax specialist or accountant of
his or her own choosing.
18. GOVERNING LAW: Florida law shall govern the validity, construction, interpretation, and
effect of this agreement.
19. CHOICE OF LAW: In the event that disputes arise concerning this Agreement, the parties
mutually agree that either of them may petition the Circuit Court of the 11th Judicial Circuit,
in and for Miami-Dade County, Florida for the appropriate recourse and/or relief.
20. DEFAULT: In the event that either party defaults in his or her obligations as set forth in this
Agreement, the party in default shall be liable to the non-defaulting party for all reasonable
expenses incurred in curing the default, including attorney's fees, regardless of whether
litigation is filed, and if so filed, both at the trial court level and all appellate court levels in the
enforcement of obligations created by this Agreement.
21. FULL AGREEMENT: This Agreement constitutes a full and complete settlement of property
and financial rights and obligations of the parties, all terms and provisions herein being
interrelated and dependent covenants and as such constituting a complete marital settlement
agreement. No oral representation shall have any force or effect whatsoever. No addendum,
modification or waiver of any of the terms of this Agreement shall be effective unless ordered
by a Court of competent jurisdiction or in writing and signed by both of the parties.

[signatures on following page]

IN WITNESS WHEREOF, the parties have executed the foregoing for the purposes
herein expressed on the day and year first above written.

__________________________ ___________________________
Witness
Petitioner/Husband
________________________
Witness
STATE OF FLORIDA
COUNTY OF MIAMI-DADE
The foregoing instrument was sworn to and acknowledged before me this _____ day of
_______, 2019, by Patrik Cserpak, who personally appeared before me and who: [ ] is personally
known to me (or) [ ] has produced as identification. WITNESS my HAND and SEAL in the
County and State aforesaid this ____day of ______, 2019.

___________________________
Notary Public, State of Florida
= = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = == = = = = = = = = = =

__________________________ ___________________________
Witness
Respondent/Wife
________________________
Witness
STATE OF FLORIDA
COUNTY OF MIAMI-DADE
The foregoing instrument was sworn to and acknowledged before me this _____ day of
_______, 2019, by who personally appeared before me and who: [ ] is personally
known to me (or) [ ] has produced as identification. WITNESS my HAND and SEAL in the
County and State aforesaid this ____day of ______, 2019.

___________________________
Notary Public, State of Florida