A friend from mine in high school reached out to me very distraught. He married another girl from our high school a few years ago. We were all surprised because we honestly all though she was gay, but I was happy for him. He believes she is having an affair with a woman she works with (his neighbor caught them under the covers with no pants or underwear on, and she is constantly texting with this woman but deletes all the texts).

He has mentioned a few times over the years how lonely the marriage was....no intimacy, she won't even give him a hug or a kiss hello, no sex for 2 years. She finally "allowed him" to be intimate with her (his words) and she immediately got pregnant. The day she found out she was pregnant she told him "I got what I wanted, now I want a divorce". She moved out of their home (that he has been fixing up) and to her mother's. He has had their daughter a few days a week since then. He does not want to divorce and wants to go to marriage counseling but she refuses. So far, they have been pretty amicable. She wants them to sell the house and, if there is any profit, split it evenly. He makes very little money; he works in landscaping in very long, manual hours for little pay. State is Pennsylvania

Their daughter currently goes to daycare, which he pays for. His wife drops her off and picks her up, as it is 40 minutes away from his work and he is rarely off for the day before the center closes. For this reason, he is not sure 50/50 custody would work.

He can't afford a divorce lawyer and wants to go to mediation, but doesn't know where to start. I've been giving him some advice but I know all of you here are far wiser than me. Do you have any points to add to the below. Any pointers you have would be appreciated!

Here is what I have sent him so far:

-All future communications with her needs to be in writing and saved, either text or email. Reiterate in writing that you DO NOT want a divorce and want to go to marriage counseling and save her response.

-She is pregnant and the legal system will assume you are a deadbeat dad leaving his pregnant wife. You need to establish repeatedly in writing that is not the case

-(They do not have joint finances) Keep track of all spending, deposits, credit cards, etc. Keep receipts for anything you do on the house (he has spent at least $18k so far remodeling)

-In mediation, if she wants to keep the house, it must be reappraised and she has to buy you out of half the equity and reimburse you for half the renovations. She needs to refinance and have the mortgage and deed solely in her name. If she wants to sell it, you get 50% of the profits

-Establish that she has left the marital home. Save the texts where she has said "you can stay at the house, I can't stay there anymore,. I don't like the house, I don't want to live there"

-They have no debts aside from the house, so if she has any credit cards in her name that you don't know about, she is responsible for that debt.

On to the current daughter and the future child:

-What do you guys think is the best custody plan? Since he works crazy hours during the week, maybe visitation 2-3 weekends a month?

-Make sure there is definitive wording about holidays. For example, father has custody for Thanksgiving (from time school ends to night before school begins) on even years and has Christmas (from time school ends until December 29th evening on odd years).

-Spring break from school - parents alternate years

-Taxes - He files for his current daughter as a dependent, she files for the new baby. They are each claiming one child for the child tax credit

-Birthdays - If the child's birthday falls during mother's time, father can take child for 3 hours in the evening. Vice versa if on father's time

-Father's Day - If father's day falls on mother's time, father gets the child from 10am - 6pm Father;s day

-Mother's Day - If mother's day falls on father's time, mother gets the child from 10am - 6pm Mother's day

-Pick up and drop offs will be at a location to be agreed upon halfway between mother and father's house

-Neither parent can move more than 20 miles away from the other parent. No parent can move out of state without other parent's consent.

-Parent must get other parent's approval to take the child out of the country

-Parents make joint decisions on school. Child will attend public school unless agreed upon by both parents and cost split 50/50

-Mother will be responsible for carrying insurance (she works for the government and has great insurance for $40 a month). Father will be responsible for 50% of all deductibles, co-pays, and care costs. In-network providers must be used. If a parent takes a child out of network, that parent will be responsible for 100% of the costs for that visit

-Neither parent is mandated to pay for college. Each parent may save for college at their own choosing and contribute at their own choice and ability

-No alimony will be paid by father(I doubt this would fly, because she makes nearly double of what he makes)

-State calculation will be used for Child Support.

***Anything I'm missing? Anything you would add? Anything in your decree that you like? Anything you wish was in your decree?