I like your idea unbidden, what if I just went with:

W, I note that you have not responded to my repeated requests that we work out an amicable timesharing arrangement that allows us both to share time with our children equally. I will discuss the financial matters between us when we have a parenting agreement in place that provides for us to share time with the kids equally.


Me-40,W-37
D7, D5, S3
Separated Oct 3/2013
T 11 YRS
M 7 YRS