In divorce, that is safe working assumption. In some limited situations, courts may recognize oral agreements; but in general, courts do not recognize an oral or verbal agreement between divorcing spouses, particularly when there is no evidence of the agreement other than the testimony of one spouse.

At the least, when spouses negotiate with each other, any agreement should be put in writing and signed in the presence of a notary. Courts in some cases recognize oral agreements that have not yet been reduced to writing, as in the case when the parties reach accord but have not yet hammered out at written pact in the "give and take" of such writing.

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