Proposed Language for Separation Agreement  

When Get Has Not Yet Been Issued

No later than thirty (30) days after executing this Agreement, the parties shall appear before the Boston Beit Din, 665 Beacon Street, Boston, Massachusetts2 (“the Beit Din”) (Jewish rabbinical court), including but not limited to any agents it may designate for the purpose stated herein, for binding arbitration regarding the issuance, delivery, and acceptance of a Jewish divorce document, also known as a get. The parties shall share equally in the usual fees assessed by the Beit Din for such proceedings.

In the event that either party fails to appear before or cooperate with the proceedings and directives of the Beit Din, the non-compliant party shall be solely responsible for any and all additional costs and fees assessed by the Beit Din, as well as all reasonable attorneys’ fees and costs incurred by the other party in enforcing the decision or determination of the Beit Din or in subsequent litigation of this issue, including but not limited to specific enforcement of this provision.

The parties further agree that, in any event, any enforcement of this provision, including but not limited to civil and/or criminal contempt actions, shall not be deemed isu’i (compulsion) before the Beit Din or any other arbitrator, or any court in the Commonwealth of Massachusetts or any other jurisdiction. Each party hereby waives the right to appeal any contempt or other actions for enforcement of this provision taken against that party.