You will need to explain to the court why the possession and use of this money in the way you have indicated is fair and equitable. For example, if both Petitioner and Respondent agree that Respondent should have possession and use of the money, the reason can be something like: Petitioner and Respondent agree that Respondent shall have possession and use of this money.
If Petitioner and Respondent do not agree, then you should carefully detail why possession and use of this money as you have indicated is fair and equitable. The following are some examples: