I believe that your offer is more than fair, and follows the letter of the law.
I don't believe that any other Order would be appropriate?
Even if a NCP changes employers multiple times per year, the increases/decreases in income would be disclosed within the annual income tax returns, so the CP has nothing to disagree with!?
If your husbands income this year has been significantly lower than the previous years, she would probably choose the option that gives her the most money.
And IF you have a clause in your agreement that states that
any changes in income/employment have to be disclosed within X number of days, she could call that a 'material change' and drag you back to court anyways, (which seems to be her forte).
The good thing is, as long as your offer is:
1 - Reasonable;
2 - Close to the final Order;
she will likely be ordered to pay your costs (either full or partial indemnity, based on your previous request), up to the date the Offer was rejected.
So make sure you put a point on 'costs' in your settlement offer.
You can also put a time limit on your Offer; or let it cancel out on the date that the trial begins.
Good Luck
