Given enough evidence and if he has been doing proper documentation and all, he could get 50/50 or better. Why would he ask her for that? That's what the lawyer is for. It would be a fight and he needs to be prepared for anything/everything from her, but he needs to protect himself. And his family.
There are moments in this life when you are so confident in the rightness of your actions, that not even for a second do you consider the option that you might be wrong.