Introduction: In this vibrant and fast-paced city of Shenzhen, the maintenance and breakdown of a twelve-year marriage often involves more complex emotional ties and asset disputes. Recently, Tang Yunhong, a marriage lawyer in Shenzhen, Guangdong, senior partner of Dao Hua Law Firm, and head of the Dao Hua Marriage and Family Law Team, successfully mediated a typical divorce case. The case involved not only a dispute over child support for an 11-year-old child and a loan dispute over the down payment for post-marriage housing from the parents of the husband, but also the division of two Shenzhen properties worth over 20 million yuan and luxury cars. Ultimately, under the professional intervention of Lawyer Tang Yunhong and the Dao Hua Marriage and Family Law Team, the parties reached a settlement and achieved a peaceful divorce. This case not only demonstrates the excellent legal professional skills of Lawyer Tang Yunhong but also highlights the outstanding strength of Dao Hua Law Firm and the Dao Hua Marriage and Family Law Team in the field of complex family disputes resolution, providing a high-quality model for high-end family mediation in Shenzhen and the Greater Bay Area.

Keywords：Shenzhen Marriage Mediation, Divorce Property Division of Ten Million RMB Real Estate, Child Support Dispute for an 11-Year-Old Child, Identification of Parents' Down Payment Nature, Lawyer Tang Yunhong (Guangdong Dao Hua Law Firm)

I. Case Summary

Ms. Li (pseudonym) and Mr. Wang (pseudonym, the client) were registered as married in Shenzhen in 2012. After marriage, they had a son, Xiao Chen (pseudonym), who is now 11 years old and is in the upper grades of elementary school, facing the critical educational transition from primary to junior high school. Over the twelve years of marriage, the couple accumulated a considerable property portfolio: one is a three-bedroom apartment located in the core area of Bao'an District, Shenzhen (hereinafter referred to as the "marriage property"), with a market value exceeding 10 million yuan according to the latest second-hand housing market in Shenzhen; the other is a two-bedroom apartment purchased by Mr. Wang before marriage in Bao'an District, Shenzhen (hereinafter referred to as the "pre-marriage property"), with a market value of nearly 10 million yuan. The total value of the two properties and other assets exceeds 20 million yuan. As their feelings gradually fade, their relationship has broken down, and they plan to divorce. However, they are at a stalemate on three major issues, and the contradictions are escalating.

After several fruitless negotiations, Mr. Wang, through a friend's introduction, learned about the Dahuahua Marriage and Family Law Team at the Guangdong Dahuahua Law Firm, which has an excellent reputation in Shenzhen for handling million-level property disputes, child rights protection, and family debt recognition. The team is particularly skilled in dealing with complex, large-scale property cases with multiple争议 points. Therefore, Mr. Wang sought out the head of the Dahuahua Marriage and Family Law Team, Lawyer Tang Yunhong, hoping to use professional legal strength to properly resolve issues related to child custody, property division, and debt disputes.

II. Three Key Dispute Points Behind the Stalemate in a Twelve-Year Marriage Divorce Case

1. Dispute Point One: Dispute over Child Support and Educational Planning for an 11-Year-Old Child

The 11-year-old child, Xiao Chen, is about to enter junior high school, and there is a significant increase in educational needs and living expenses. Ms. Li proposes that Xiao Chen is currently enrolled in a private primary school with an annual tuition and miscellaneous fee of nearly 70,000 yuan. To prepare for the transition from primary to junior high school, Xiao Chen has enrolled in extracurricular tutoring classes for mathematics competitions and English, with annual tutoring fees exceeding 40,000 yuan. Adding to this are daily living expenses and expenditures on interest development, with an average annual total expenditure of around 150,000 yuan. Considering that the educational investment for Xiao Chen's junior high school years may further increase, she argues that Mr. Wang should pay 10,000 yuan in child support per month until Xiao Chen turns 18, and also bear 50% of the large educational expenses such as the transition class for entering junior high school and the school selection fees for future junior high school education.

And Mr. Wang stated that in recent years, due to industry fluctuations, his monthly income has dropped from the previous 40,000 yuan to 20,000 yuan, and after marriage, he is still repaying the mortgage on the property, leaving a limited amount of disposable income after the mortgage is deducted. He believes that the amount of alimony claimed by Ms. Li is too high, and he can only afford 3,000 yuan per month, and large educational expenses should be negotiated based on actual receipts rather than pre-arranged proportions. The two parties have repeatedly argued over the amount of alimony and the distribution of educational expenses, but have been unable to reach an agreement.

2. Second Dispute Focus: The Dispute Over the Division of the 10 Million Pre-Marriage Property

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Mr. Wang, however, insists that the pre-marital property is his personal pre-marital property and, according to the law, should not be considered as joint marital property; the appreciation of 5.35 million yuan is a natural result of the overall appreciation of the Shenzhen real estate market and has nothing to do with Ms. Li's maintenance efforts. He only agrees to return the amount she invested in the renovation, and there is a huge gap between the two parties on the amount of compensation.

3. Third争议 Focus: Dispute over the loan for the down payment by the groom's parents for post-marital property

The background of purchasing property after marriage further exacerbated the complexity of the dispute. When the property was purchased in 2016, Mr. Wang's parents contributed 400,000 yuan as the down payment, and no IOU or written agreement was provided at the time. Now, during the divorce, Mr. Wang claims that the 400,000 yuan is a loan from his parents to both husband and wife, and should be considered as a joint debt, with each party responsible for repaying 200,000 yuan.

Ms. Li, on the other hand, believes that the funds are a gift from Mr. Wang's parents and not a loan, and should not be included in the joint debt division. Both parties are at odds over this issue, even leading to conflicts between their families.

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Three, Mediation Breakthrough: The Dao Hua Team Makes Multi-dimensional Efforts; Tang Yunhong Lawyer Analyzes Three Disputes in Detail

After taking over the case, Lawyer Tang Yunhong immediately organized a case seminar with the core members of the Dao Hua Marriage and Family Law Team. The team includes not only marriage law experts but also invites local senior real estate appraisers and family debt mediation specialists to participate. They comprehensively analyze the three major dispute focal points of the case by combining the real estate market situation in Shenzhen, judicial practice, and relevant legal provisions.

Subsequently, Lawyer Tang Yunhong led the team to formulate a three-step mediation strategy of "first resolve the emotional knot, then break the legal issue, and finally determine the details," which took one month to gradually resolve the contradictions between the two parties through three rounds of in-depth communication.

1. First consultation with the male party: clarify the scope of claims and evidence (1 hour)

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(1) Clarify the ability to pay child support. Verify Mr. Wang's income proof and mortgage repayment records, confirm the authenticity of his disposable income of 12,000 yuan, and point out the educational necessity of the 11-year-old child during the transition from primary to junior high school, guiding him to understand that child support needs to take into account the actual needs for the child's growth.

(2) Analyze the legal boundaries of pre-marital property. According to Article 1063 of the Civil Code and the judicial interpretations of the Marriage and Family Law, it is clarified that pre-marital property belongs to personal property, but in combination with the renovation payment records and mortgage repayment records provided by Mr. Wang, it is explained that the residual value of the renovation, the contribution to the increase in value, and the natural increase should be compensated.

（3）Sort out evidence of the nature of the down payment.Point out that Mr. Wang can only provide bank transfer records from his parents, without any evidence of borrowing, such as promissory notes or collection records. In conjunction with Article 29 of the Interpretation of the Marriage and Family Article of the Civil Code, it is suggested that "parental contributions after marriage without clear agreements are generally deemed as gifts."

This communication has given Mr. Wang a clear understanding of the legal provisions and the rationality of his own claims, and he has preliminarily agreed to make concessions on child support and property compensation.

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