IN THE DISTRICT COURT OF THE
HONG KONG SPECIAL ADMINISTRATIVE REGION
MATRIMONIAL CAUSES NO.12808 OF 2017
WONG KEAN LI (黄安鵬)
(formerly known as 黃兆瑄 and formerly known as 黃建理)
and
GEMMA FANG (方嘉敏)
(formerly FANG YU WEN 方郁雯)
1" AFFIRMATION OF GEMMA FANG
(In opposition to the Defendant's Application for interim access)
(In opposition to the Defendant's Application for interim access)
I, GEMMA FANG of Room 201, Block 5, Rainbow Haoting, 4400 Bin Sheng Road, Binjiang District, Hangzhou City, Zhejiang Province, PRC (中國浙江省杭州市滨江区演盛路 4400 號彩虹豪庭5幢 201 室) do solemnly, sincerely and truly affirm and say as follows: -
-
I am the Respondent in these proceedings. I make this affirmation in opposition
to the Defendant's summons dated 13 December 2017 for the following orders granting: -
- interim access to the child of the family, namely FW Wong ((黄頭桐), a girl born on 27 October 2005;
- leave to remove FW out of the jurisdiction of Hangzhou to Kuala Lumpur, Malaysia for no less than 7 days during Chinese New Year holiday in 2018; and
- am to encourage and promote the Petitioner's access to FW.
- In this affirmation I would like to respond to the unsworn Petitioner's affirmation ifled in support of his summons on 13 December 2017 ("Petitioner's Affirmation"). Moreover, the Petitioner's address stated in the said Affirmation is a business address in Hong Kong, not a residential address. The facts deposed hereto are all within personal knowledge and information and are true to the best of my knowledge, information and belief unless otherwise stated. Where I deposed to matters on the basis of information received from third parties, I verily believe the same to be true because of my belief in the veracity of my informants.
- The Petitioner and I have been married for 16 years. We have one child of the family, namely FW Wong(黃頁桐), formerly known as 黄河形, a girl born on 27 October 2005 ("FW") she is now 12 years old. FW resides in Hangzhou, PRC with me. She attends the Hangzhou International School and various extra-curricular activities after school hours.
- I was born and raised in Taiwan. The Petitioner was born and raised in Malaysia. We met online when I was studying my Masters in Education at Harvard University, USA. We subsequently met a few times in Hong Kong and in USA. After I completed my masters in 2000, I moved to Hong Kong and started cohabitation with the Petitioner who was working as a solicitor in Clifford Chance's Hong Kong office. The Petitioner and I married in Hong Kong on 12 February 2001. FW was born a few years later on 27 October 2005. Since FW was born, I had been a housewife until I had to go out to work to support FW and myself when the Petitioner stopped supporting us some time after we moved to Hangzhou in November 2012. We moved there because the Petitioner said that he has a close friend there who would invest in him.
- In June 2014, the Petitioner started living apart from FW and me intennittently, Between June 2014 and 2016, he moved out around 7 times. He finally moved out for good in 2016.
- Before I explain why I oppose to the Petitioner's summons for interim access, the Court should be informed that the Petitioner and I have another court case in Hong Kong for a loan agreement under HCA 1755/2017. On 28 January 2002, we purchased in joint names a property known as Flat 33A, Casa Bella, 117 Caine Road, Mid-Levels, Hong Kong including rooftop ("Casa Bella"). Our family lived there until one day, the Petitioner wanted to sell Casa Bella. In fact, he arranged the sale and purchase of Casa Bella without me knowing about the whole thing. It was until I was informed by the solicitor handling the transaction that I realized the house was sold. The Petitioner intended to pocket the whole proceeds of sale to himself.
- On 30 July 2010, the sale of Casa Bella was completed. Prior to completion, the Petitioner and I signed a loan agreement in relation to the sale proceeds of Casa Bella ("Loan Agreement") on 20 July 2010. Pursuant to the Loan Agreement, the entire sale proceeds of Casa Bella would belong to me, but I had to lend the full amount to the Petitioner. The sale proceeds amounted to HK$27,000,000 ("Loan Amount"). The Petitioner agreed to repay the Loan Amount to me in full upon demand.
- The Petitioner never gave me any part of the sale proceeds to me. Every time I brought it up, he would say, "You can get it when we get a divorce, but I am telling you that you won't get FW's custody because you are not working, and the court wouldn't give the custody to someone who can't support herself and the kid." He knew my weakness was FW and that I would do anything to stay in the marriage, even if it meant I would never get my money back.
- We had a lot of arguments leading to the Petitioner started leaving FW and me in June 2014. I would explain in more detail below about what had happened. In June 2017, I instructed my solicitors, Messrs. Ho & Ip ("HI") to send the Petitioner a demand letter for repayment of the Loan Amount. Within the same month, the Petitioner attempted to initiate divorce proceedings in Hangzhou but the Hangzhou Court refused to hear the case for lack of jurisdiction.
- On 26 July 2017, I commenced the legal proceedings in Hong Kong by filing a Writ of Summons to claim the Loan Amount back under the Loan Agreement in HCA 1755 of 2017. The Petitioner applied to stay my proceedings and the hearing for the stay is fixed to be heard on 14 June 2018 at the Court of First Instance.
- On 29 September 2017, the Petitioner filed a Petition for Divorce based on 2 years' separation and unreasonable behaviour. He also filed on the same day an Inter- Partes Summons and his affirmation in support of a stay of the present proceedings pending the final determination of the parties' financial claims under the present divorce proceedings. The Inter-Parte Summons is fixed to be heard on 14 June 2018.
- It is true that the Petitioner has little time with FW since April 2017 as he claimed in paragraph 3 of the Petitioner's Affirmation. I deny that his limited access to FW is because I have stopped FW from seeing him. However, to be honest after having learnt from FW about the Petitioner's inappropriate conduct towards her, I do not want FW to be with him alone at all.
- Before I go on further from here, I would like to point out that up to the present day, I still have not received a copy of the Petitioner's Affirmation duly sworn. The Petitioner was a very experienced solicitor in Clifford Chance in Hong Kong. Surely, he knows very well the need to have his affirmation sworn. I would like to say that the Petitioner has twisted the facts to make me look very unreasonable. Therefore, I deny the Petitioner's allegations in the Petitioner's Affirmation unless I have admitted any fact stated herein.
- I categorically deny the Petitioner's claim that he is the primary carer of FW in Hangzhou as he claimed in paragraph 4 of the Petitioner's Affirmation. When I had to go out to work, the Petitioner had the advantage of spending a few hours' time with FW as he was also busy with his own works and business. Even for this arrangement, it happened for a short period of time when FW refused to see him.
- I was and am the primary carer of FW since her birth. I stopped working to care for FW while we were still in Hong Kong. FW and I have a very close relationship. It was only for a short period of time when I had to work long hours that I had no choice but spent less time with FW during which the Petitioner claimed he cared for her which is not true as I had my own mother, Madam Pauleen Li Hua H. Fang, to come to care for FW.
- In short, the Petitioner has planned every move of his since he wanted to divorce me. He spoke ill of me in front of FW to win her to him and spend time with him. I believe one of the reasons was to avoid paying maintenance to her and me. The worst of all, he flirted with my mother who came to look after FW while I was at work. He started a relationship with my mother and got my mother to be his spy on me and took benefit from my aged mother.
- Soon after we had moved to Hangzhou, the Petitioner started to say he would not give me any money for the maintenance of FW and me. I was shocked and do not know what to do as he was the one who controlled all of our family's expenses and was in possession of the money we got from selling Casa Bella. What made me even more upset was when he told me I should file for a divorce if I was not happy with the situation and he would be happy to oblige to the divorce.
- It really hurts me a lot of to hear a proposal for a divorce from the Petitioner. I come from a very traditional Chinese family and was determined not to let FW be part of an incomplete family, and thus I did not take any action on the Petitioner's proposal. Soon afterwards, the Petitioner stopped providing for FW and I, and in order to sustain FW's education and lifestyle, I started working.
- At first, I worked for XDF (新東方), one of the largest educational companies in China and was just about an hour away from where FW and I lived in Hangzhou. Still, by the time I arrived home from work, it would have been almost 1 1pm. This did not give me much time to spend with FW. It was definitely a very difficult time for FW and I as I used to be a home-maker and was able to take care of FW full-time. However, seeing as the Petitioner had cut-off all of our financial support for FW and I, it was no longer feasible for me to remain a full-time home-maker to care for FW. I had to work to give FW the best that I can provide for her, despite the Petitioner's reluctance to provide for us.
- When I was working at the beginning, I often found the Petitioner neglecting the basic needs of FW when she was under his care. The Petitioner would always let FW play computer games and be at home alone while he disappeared at around 5 or 6pm with no explanation as to where he was going. There were even times where FW had told me that the Petitioner did not give her any dinner, especially on days which the part-time local helper was not on duty. Seeing that FW could not be left in the care of the Petitioner, I started having my own education centre two years ago which would allow me to arrive home at about 9 pm on busy days. My mother (i.e., the grandma to FW) also helps me to look after FW when I am at work. My mother started living with us around November 2014 on the Petitioner's invitation. The Petitioner asked my mother to come from Taiwan with an offer to pay her a monthly payment of RMB 5,000. However, as soon as my mother arrived, the Petitioner said he could not pay my mother anything and said he could book her flight back to Taiwan. By then my mother had already terminated her rental contract and work contract in Taiwan.
- The Petitioner clearly does not have FW's best interest at heart as he unilaterally made the decision to withdraw FW from her international school, namely Hangzhou International School ("HIS"), without my knowledge or consent, and placed her in a local school in summer 2013. I was only notified that the Petitioner had transferred FW to a local school after all arrangements had been set. FW was devastated when she was suddenly told she would need to switch to a local school. It was not until September 2016 where I was able to re- place her back into HIS in which I had to fight hardly for. After transferring back to HIS, FW told me that she is much happier being back at HIS and felt more accustomed to the environment there. The Petitioner clearly did not consider the correct and right academic path for FW in order to ensure the best for her or give her the opportunity to excel and to grow into her full potential.
- The Petitioner not only neglects the genuine and proper care needed by FW, but he also encourages her to quit studying to become a child actress. I presume the Petitioner had been pushing FW to pursue a career in the entertainment industry at young age because FW is talented. Luckily, FW did not follow his proposal.
- FW's self-driven personality caused her to excel in her academics. However, the Petitioner would always disregard FW's protests and objections against being a child actress. He would often bring her to seedy movie sites to pay visits to those so-called producers and directors. FW had on various occasions told me that she did not like going there because these people were vulgar and would often be smoking and touching her which made her feel uncomfortable. When he overheard me telling FW that the entertainment industry is a dark place where women often have to pay high prices such as sleeping around to get roles, he screamed at me, shake me and told me to stop saying such "nonsense" to FW. The Petitioner was basically forcing FW, against her own will, to become an entertainment star and forego her academics after and upon knowing that FW had such a talent in performing. The Petitioner wishes to exploit FW's talents and skills to achieve his own ambitions without any regard to FW's thoughts and feelings.
- When FW was in the Petitioner's care he would return FW at around 5:00pm because he has to attend to his personal matters. I have previously suggested that he may see FW after she finishes her homework and extra- curricular activities, but he refused the proposal. Therefore, it is inaccurate and untrue that the Petitioner claims that I do not give him access, but rather that his requested access times are unreasonable and disturbing FW's academic growth and daily routine.
- It was during this time that I found FW changed a lot. She spent time in video games and watching movies. I got very anxious and worried that FW had at one time refused to come with me when I had the time. I tried to talk to FW that it was no good for her not to study and only watching movies with her father and playing video games. I had on several occasions tried to get FW to come to me and she did refuse to do so solely because playing and watching movies is certainly more attractive than to come with me who is getting her to study. I had argued with the Petitioner about FW, but it was all because I could see the Petitioner is not taking good care of FW and trying to distance her from me.
- The recording and photographs taken by the Petitioner were done during the most difficult time FW had with me and she had resistance to come with me when I could not convince her to come home with me. However, I wish to point out that the Petitioner has apparently edited what he had recorded and presented as if I was a very bad person. It was not happened in the ways as suggested by the Petitioner. I deny all the allegations he made in the Petitioner's Affirmation about me acting as if I was forcing myself against the will of FW. The true fact is I was trying to get FW back to a normal life for a child studying instead of being manipulated by the father and used by him.
- Therefore, in response to paragraph 5 of the Petitioner's Affirmation, I would say that I had started to be straight with FW and keeping her with me to be sure she is not being influenced by the Petitioner. Occasionally, the Petitioner still got to see FW but every time after seeing the Petitioner she was being affected by him who had told FW how bad I was. I am sure the Petitioner had said a lot of bad things about me which made FW does not want to stay with me at about this time.
- The Petitioner had told FW that the Loan Agreement between the Petitioner and I did not exist and had FW come home to question my sanity and that if it was possible that I had been hallucinating about the whole case. The Petitioner is deceptive towards FW to portray me as to have made up this whole loan agreement situation.
- In reply to paragraph 6 of the Petitioner's Affirmation, I accepted that there was an agreement signed by the Petitioner called Maintenance Expenses Agreement. Since the Petitioner had stopped paying me maintenance for FW and I, it has been bothering me a lot. I had demanded for maintenance from the Petitioner and he had been ignoring me for a long time. One of our arguments apart from how to raise FW, the other main issue between us is the Petitioner has stopped paying any maintenance as he used to do. But, I deny that the purpose of signing the agreement was a condition for the Petitioner to see FW. It had never been the case. The Petitioner had rightly pointed out that I had instructed a lawyer in PRC to demand for maintenance and it was until the demand from my lawyer that the Petitioner finally agreed to sign the agreement. The Petitioner voluntarily signed the ageement to pay RMB15,000 as maintenance for FW every month on 12 December 2016. The Petitioner is a lawyer and he knows what he is doing when he signed the agreement. As mentioned by him that he had amended the agreement and inserted a condition for him to see FW. At that material time, I had no issue for the Petitioner seeing FW except I strongly objected that the Petitioner did not take good care of her instead trying to push her to become a movie star. But I have to say that now I have an issue for the Petitioner to see her for the reason I would explain below. There is now produced and shown to me marked exhibit, "GF-1", a copy of the said Maintenance Expenses Agreement dated 12 December 2016.
- Regarding his payment of maintenance under the agreement, up until February 2017 he followed the agreement and paid me RMB 15,000 every month. Then he skipped March and started paying me RMB 5,000 only every month on 12 April 2017 without giving me any notice he would decrease the amount of maintenance. His last payment was made on 6 August 2017. Since then I have not received anything from him as interim maintenance. here is now produced and shown to me marked exhibit, "GF-2", copies of screenshots of the deposits I received from the Petitioner in February 2017 which shows he paid me RMB 15,000, in April when he started paying me RMB 5,000 and the last time he paid me RMB 5,000 was August 2017.
- In reply to paragraph 7 of the Petitioner's Affirmation, I am surprised to learn from the Petitioner in saying that he did not believe he had any obligation to pay the maintenance as he had paid the international school fees for 2016 -2017 and he had transferred the school fee for 2017 -2018 to my mother for safekeeping. This is not true. He did transfer money to my mother but not for the purpose of paying the school fees. He used my mother to keep money for him and he always made her withdraw from the bank to give him the money when he needed it. Therefore, no money was ever paid for the school fees whether or not it was through my mother.
- In regarding to paragraphs 8, 10 and 13 to 18 of the Petitioner's Affirmation, there were incidents occurred during this period. It was a time when both FW and my mother were misguided by the Petitioner but now they have realized what the Petitioner was doing. He has been fooling both of them, The Petitioner had approached my mother and started a relationship with her making my mother to go against me and at the same trying and persuading FW to stay with her father. It was a very difficult time for me and FW. My mother now realized that she has been fooled.
- The Petitioner has on multiple occasions recorded the telephone conversations between him and me or him and FW without our knowledge and consent. My greatest concern is not the act of having secretly recorded the conversations, but the Petitioner is very deceptive and intentionally misleading the Court. Since the Petitioner and my marriage has fallen apart, the Petitioner has developed a hobby of film and sound editing and has become very skilled at this. He would often edit sound clips during his free time and he has clearly done some form of editing with the recorded conversation so as to distort the truth. In fact, we have never had such a conversation in that way. It is true that I had requested FW to come home because she had a lot of work to complete, but what the Petitioner had provided was not the complete and true copy of the recording. The three audio and video recordings the Petitioner exhibited in his Affirmation in support of his application for interim access dated 13 December 2017 are examples of his editing.
- There was this incident in September 2017 when the Petitioner asked his mother (i.e., the paternal grandma) to come for a visit. I initially had no idea why he invited her to come but I found out soon enough. The Petitioner's mother was secretly recording me while I was telling FW off for not completing her homework or spending too much time playing on her computer. This is an example of how the Petitioner could use FW and my audio recordings to produce inaccurate proof.
- I had been told by my own mother that the Petitioner was responsible in creating her WeChat mobile account as well as setting the password for her. It was also often the case that the Petitioner would claim that he would need my mother's phone to do a few "configurations" for her and would take her phone to do what was "needed" for her.
- During the period when the Petitioner managed to trick my mother as if he is a lover of her, my mother was willing to do a lot of things for the Petitioner. There was an affair between him and my mother back in late 2016. On 21 December 2016, FW and I were shocked to witness the Petitioner and my mother hugging and kissing passionately. As far as I am aware, the Petitioner slept with my mother on a few occasions. I do not think the Petitioner was attracted to my mother, but that he was just using her against me.
- Later she has found out she was being used by the Petitioner. Now, my mother has told me that she has never written anything as such claimed by the Petitioner, nor has had such a conversation with him, which leads me to highly suspect that such conversation was created by the Petitioner himself with the motive to use my mother to testify against me before the Court. The Petitioner has not only misuse my mother's WeChat account, after much further discovery, my mother has set up a case with the local police in Hangzhou against the Petitioner for fraudulent use of her identifications for the purchase of a car and a subsequent "transfer of ownership" which was all completed without her knowledge. Such deceptive and misleading behaviour of the Petitioner is unacceptable and it is only getting worse as he continues to fabricate events and distort the truth, especially in front of FW. There is now produced and shown to me marked exhibit, "GF-3", a copy of my mother's statement on the Petitioner's deceptive behaviour notarized by a lawyer in Hangzhou and papers of her case in the local police office for the Petitioner's forgery of her signature and for stealing her travel documents to purchase a car.
- In reply to paragraphs 11 and 12 of the Petitioner's Affirmation, the Petitioner was trying to show his protection for both the grandma and FW. The Petitioner did not show any copy of the alleged proposed new agreement called "Family and Maintenance Expenses Agreement". I have never seen such an agreement and have no idea what the content was. I would say this is just another trick played by the Petitioner. Of course, I would not agree to sign such agreement to avoid falling into any trap set up by the Petitioner.
- It was until FW has stopped seeing the Petitioner about March 2017, it has come to light to me that the Petitioner has been molesting FW in the past. Around that time, while FW and I were watching a movie in which a character told another character that most sexual harassments come from a friend or close relative, she timidly told me that the Petitioner had touched her in places in which made her feel uncomfortable. Upon asking her to show me where she was touched, she pointed to her breast and her crotch. She said sometimes the Petitioner would pretend to adjust the front of her shirt and his hands would linger on her breast, she felt embarrassed and "not right," but she was not sure how to say it or whether it was even appropriate to say "no" to that. Other times while they were seating, he would put his hands up her inner thighs, very close to her crotch, and she would move away, but then it would start over again, until she made an excuse to distance herself away. She said she used to like to sit on Daddy, but ever since he started to get weird on her, I did ask her when exactly did it start, but she said she could not say the exact month, all she could remember was that it started while she was in the last year of her local school, which meant anytime between September 2015 and June of 2016. It was very shocking and painful for me to find out that the Petitioner was so twisted as to touch the private areas of his own daughter. I immediately told FW that she should not allow anyone to touch those areas, not even her father.
- There are occasions where I would notice certain marks on FW's body and have become very suspicious of these marks. I have seen the Petitioner attempting to choke FW by the neck a few times and was lucky enough to be able to stop him before anything unfortunate were to happen. The first time took place in early October 2014, around 1 to 7 October 2014. I was in the kitchen washing up dishes after lunch. Then I heard a loud crash sound coming from FW's bedroom. I rushed there and to my disbelief I saw the Petitioner's hands on FW's neck and her eyes look bulged and her tongue was sticking out. The crashing sound came from her struggling hands hitting the desktop lamp and sweeping it to the floor. I have never felt so scared in my life. As soon as the Petitioner turned around and saw me he let go of FW, slammed the door and left. I asked FW what happened and she said she did not know why daddy suddenly got angry. This behaviour of the Petitioner is absolutely unacceptable and it was a very horrific experience for FW and me. I had asked FW what had happened and she would say "I don't know why daddy got angry."
- In addition, the Petitioner has continually exhibited threatening behaviour towards FW which only leads me to fear for her safety if it is ordered that she was to travel or be alone with the Petitioner. There was one incident where the Petitioner had inappropriately touched FW. This was happened when he took her to the doctors for a constipation issue, where she was asked by the nurse to take off her pants and lie down. During the time in which the nurse had left the doctor's room to go and get the necessary medication, the Petitioner kept on touching her naked, bare hips to the point where she felt extremely uncomfortable and asked him to stop. The Petitioner did not stop until the nurse re-entered the room. The Petitioner often threatened FW not to tell anyone about his disgusting behaviour towards her. FW had expressed such incident to me with great unhappiness and disgust which pains my heart. The Petitioner is clearly not suitable, at this moment, to be left alone, let alone travel alone, with FW as his presence alone poses too much of a danger to FW without sufficient supervision.
- I wish to clarify that although the Petitioner said in his Affirmation that he has had difficult seeing FW since March 2017, he was still seeing FW then till July 2017. What the Petitioner was not happy with was FW's cautious attitude towards him. Since FW had told me about the incidents where the Petitioner had touched her, I told her the only safe way for her to see the Petitioner was to have me accompanying her. Whenever the Petitioner asked FW to go somewhere with him, she would say "Dad, Mum is free on [time], Mum and I will go out with you." The Petitioner would then say things like, "FW, you know how much I hate your mother" and "FW, you're not my daughter anymore."
- On the last occasion, around May 2017, the Petitioner took FW to McDonald's for one of his scheduled meetings. He directed her to the back corner of the restaurant with a more secluded seat and began to touch her inner things. FW had learnt by then that she should stop people from touching her if she felt uncomfortable and so she immediately told the Petitioner to stop, but he refused to listen to her request. FW then pleaded to the Petitioner to stop and to take her home immediately but was only met with the Petitioner's anger in which he reacted by throwing FW's iPad on the floor, cracking the screen and causing FW to cry. He immediately left the restaurant and FW, leaving her there alone to cry. That day, whilst I was teaching a large group class, I received an urgent call from FW, who was in tears and crying for my help. I immediately sent someone to pick up FW. After this incident, FW expressed to me that she never wants to see him again, even when the Petitioner had sent her several disturbing messages on her school email telling her how much he loves her wand whatever she thought he did was only meant as loving gestures. There is now produced and shown to me marked exhibit "GF-4", a copy of the e-mail sent from FW to the Petitioner expressing her opinion and feelings towards the Petitioner and that she does not feel safe in his presence. To hear my daughter tell me this pains me as she is a young child and should not have to go through such traumatic and inappropriate situations.
- There were other occasions where the Petitioner would claim or find reasons to brush his hand against FW's chest, deliberately resting his fingers on her breast for an unnecessary and inappropriately long time. FW told me that she was unaware that such touching was unnatural and had thought that such thoughts and feelings were her own unique feelings developed from the physical contact made by her father. As a result, FW did not tell me and this situation lasted for approximately 2 years (FW herself said it begun in the last school year of her fourth grade at local school which would been between September 2015 to June 2016) until sex education was taught at FW's school. At the class, she was told that no one should ever touch her as long as she felt uncomfortable about it, which was when she began to disclose bits and pieces of what the Petitioner had done to her. After getting the full story from FW, I was furious and shocked. How could a father do such a thing to his own daughter and not feel any remorse? Should it not be the Petitioner's duty as well to teach FW the importance of self-love, to protect her from any harm or damage and to teach her that she should be respected emotionally and physically? Upon confronting the Petitioner on what FW had told me about what he has done to her, his reply towards me was "What are you going to do about it'?" and immediately walked off. This confrontation took place around early October 2016. I cannot let my daughter interact alone with the Petitioner, knowing that this corrupt moral and standards of his would allow him to sexually harass and assault her. Therefore, starting from early 2016, FW would come to my education centre after school to do her homework so I can keep an eye on her instead of leaving her to the Petitioner.
- FW's discomfort towards the Petitioner was shown in her letter addressed to Judge Cai of the Hangzhou Binjiang People's Court when the Court has not decided it has no jurisdiction to hear the Petitioner and my divorce. The letter was undated but it should have been sent to the Judge between 30 July and 3 August 2017. There is now produced and shown to me marked exhibit, "GF-5", a copy of FW's letter to Judge Cai of the Hangzhou Binjiang People's Court.
- I wish to point out that it is highly suspicious that up to the time of writing this affirmation, the Petitioner still has not sworn on the Petitioner's Affirmation. As I mentioned before the Petitioner is a very experienced solicitor with Clifford Chance before, he should know what he should have done with his affirmation. I have great doubt with his evidence given in the Petitioner's Affirmation.
- In any event, in view of the Petitioner's neglectful, sexual, violent and deceptive behaviour mentioned above, I humbly pray the Court to dismiss the Petitioner's application on interim access and leave to remove FW out of jurisdiction as it is clear that the Petitioner is a prone-to-be violent and sexual parent who is not suited to be with FW on his own. I respectfully request the Court to dismiss the Petitioner's application with costs be awarded to me.
Background
RCA 1755 of 2017
My reply to the Petitioner's Affirmation
The Petitioner had Sexually Harassed and Assault FW
Conclusion