AFFIRMATION IN REPLY OF WONG KEAN LI
(In reply to the Respondent’s 1st Affirmation)

I, WONG KEAN LI 黃安鹏 (formerly黄兆璿and 黄建理) of 14D Hollywood Centre, 77-91 Queen’s Road West, Sheung Wan, Hong Kong do hereby solemnly sincerely and truly affirm and say as follows:-

• I am the Petitioner herein. I make this Affirmation in reply to the Respondent’s 1st Affirmation in opposition to my application for interim access, dated 1st February 2018. Unless stated otherwise, references to paragraph numbers below shall refer to the paragraphs in the Respondent’s 1st Affirmation (“Paragraghs”).


• I regret that this Affirmation has turned out to be much longer than I had originally expected. However, due to the countless lies and falsehoods made by the Respondent in her Affirmation in opposition, I’ve had no choice but to address each of them thoroughly to make the truth as clear as I can. I am therefore writing here a summary of some of the more important things I will be showing in this Affirmation.



Executive Summary

• Moving Out History – Before we finally lived in separate homes, I only moved out twice, not “around 7 times”, and even those two times did not make much of a practical difference to FW as I still put her to bed and woke her up for the most part (until or unless prevented by the Respondent).
  
  It is also false to imply that I left or abandoned the Respondent and FW at the end of 2016. It was actually the Respondent who moved out first and did not welcome me to the flat she had newly rented, causing me to find a place of my own.


• Evidence, Corroboration, and Truthfulness – The Respondent’s affirmation in general contains many statements that range from twisted beyond recognition to being completely fabricated. I challenge the Respondent to provide at least corroborating evidence instead of just making allegations. And if the Respondent wishes to deny what I say, I ask the Respondent to be specific, so that I can try to find specific evidence to back up what I said.
  
  To the extent that the Respondent claims that my audio and video recordings have been edited or doctored, or that my Wechat conversations are faked, I again ask the Respondent to be specific as to how they have been edited or faked (in comparison with what it ought to be). I also invite the Court, her lawyers and even audio/video professionals to examine the original records and source files directly and my mobile phone or computer to do the necessary verification.


• “The Petitioner stopped supporting us” – It is clear from evidence I show that it is completely false to say that I stopped supporting the Respondent, let alone stopped supporting the Respondent and FW. I was the one who paid for all basic expenses relating to the family (such as rent, utility bills, maid salary), FW’s essential expenses (including two and a half years of international schooling), and I even continued to pay the Respondent an allowance until at least mid-2014 despite the fact that the Respondent had started earning a high salary as early as February 2013.
  
  


• Reduction of Monthly Allowance to the Respondent – The Respondent seems to be using the fact that I had reduced her monthly allowance after arriving in Hangzhou and twisting it to suggest that I have financially abandoned her and FW. Yet she doesn’t acknowledge why her allowance had continually been decreased in the first place, which was the result of repeated and non-stop dishonest behaviour from the Respondent regarding money, such as stealing my credit cards (including company credit cards) and maxing them out on her personal purchases and overspending beyond what had been agreed.
  
  This behaviour had started since the beginning of our marriage, but was especially damaging at that time because we were very low on money (which was one key reason why we moved to Hangzhou in the first place). Yet not only does the Respondent not have any concept of “for rich or for poor”, she only seems to be aware of what she was not getting compared to what she used to get, and had never even considered contributing to the family in any significant way even after she started earning a high income herself. Instead, she would consider herself a victim, and constantly berate me as a “loser”.


• Primary Carer for FW – Hong Kong period – The Respondent claims to have been the primary caretaker since birth, but I consider that very debatable. She never “stopped working to care for FW… in Hong Kong” because she had stopped working long before FW was born, with the only two jobs she had lasting merely months before she was asked to leave. She whiled away most of her time before and after FW’s birth doing her own stuff and it ended up being the maid taking care of FW most of the time while I was at work.
  
  Conversely, I was so involved with FW’s upbringing, especially in educating her, that I used all I had learned from teaching in starting my first business not long after FW was born – BrillKids (see www.brillbaby.com and www.brillkids.com ).


• Primary Carer for FW – Hangzhou period – While it may be debatable as to whether she was the primary carer for FW while in Hong Kong as she wasn’t working, it is simply not possible for the Respondent to claim to be so after moving to Hangzhou. She started working about two months after arriving, and she would generally be teaching children every day during after-school hours until late at night and most of the weekend period, ie. when FW was not at school. She barely saw FW all that time, until August 2016 when she started isolating FW from me and having her be at her classroom when she was not in school.
  
  And while Grandma did help during certain short periods, the Respondent had chased Grandma out of the home twice during that period and so Grandma was not even living with us, nor even allowed to see FW for a lot of that time, so the Respondent can’t claim that Grandma was helping her much either. Just looking at the abundant evidence of my involvement with FW at school and at the extracurricular level, it is obvious that I was the primary caretaker after we moved to Hangzhou.


• Changes of School (International to Local School, and back to International) – FW was fully involved and in agreement with the decision to switch to a local school. I had seen the life-changing impact that my own father’s decision to send me to a Chinese primary school had on me, and FW was willing to try it. FW did remarkably well there, with her Chinese developing to a high level that everyone was proud of.
  
  When the Respondent started getting involved in her life in July/August 2016, she used some of FW’s minor grievances with some of her fellow students (who were also fellow band members) and fanned them into hate towards those involved. The Respondent was asked to stay away from the band activities, but she instead just ended up pulling FW out of the band, and then even the local school. She was even prepared to homeschool FW had I not agreed to come up with the money to put her back into International school.


• Neglect of FW, Being a Child Actor, etc. – The incidents described by the Respondent of me taking FW to film sets where she was then molested by others as I watched were completely fabricated. I also never encouraged FW to quit studying. I had merely tried to foster FW’s enormous talents and interest in singing, music and performing. I had only taken her once ever to a movie set, and that was only because we were following a friend who was an investor in a TV series and who was giving us a ride back to Hangzhou.


• Playing Games and Watching Movies – I did allow FW to play computer games, but mainly the game Minecraft, which I believe is much more than a game, and which allowed FW to express her creativity in ways never before possible. It also allowed us to bond a lot in a virtual world. In any event, playing games was only a small part of the time. She would be using the computer also for writing her stories and illustrating her self-created characters. Watching movies was also just one of the many activities we did together during her spare time.


• The Respondent’s Relationship with FW – Before July 2016, the Respondent was not very close to FW. Partly this was because she didn’t get to see her much as she was working for most of the time when FW was out of school, but also because the Respondent was never very interested in all the things that FW was interested in, like her singing/rock band, choir, character creations, Minecraft, etc. The Respondent also was not very interested in her school activities when she was in the Chinese local school.
  
  FW also would often rebel against how the Respondent treated her, which caused FW to run away from the Respondent many times (especially in early 2017).


• Maintenance Agreement / Stopping of Payments – The Respondent tries to paint the picture that I stopped paying her child support payments that were agreed upon under the Maintenance Agreement without any good reason. The truth was, the Respondent had been mistreating both FW as well as Grandma, and one day when she announced FW would from thereon live with me, I rightfully terminated it. I also told her that we could continue with it, but only after adding two more clauses, one to protect FW, and another to protect Grandma. I have now shown conversations and documents to prove this very clearly.
  
  It is quite clear that the Respondent stopped letting me see FW after this termination, and she refused to add the clauses to continue with the payments, but would rather sue me in Court.


• School Fees for 2017-2018 / Misappropriation of Funds – The Respondent denied that I paid for FW’s school fees, but I show clearly here that I did. Not only did I do so, but part of the money was misappropriated by the Respondent, and I ended up having to pay more again to cover the difference.


• Affair with the Respondent’s Mother – Not only is my supposed affair with the Respondent’s mother completely fabricated, but it is cruel to have made FW also tell that lie to others. When I asked FW why she would continue to peddle that lie to others, all she could say was, “because I’m screwed up.” The Respondent had long been trying to explain to others why even her own mother did not take her side and why the mother had reported the Respondent’s violent and abusive acts towards Grandma to the police, and it seems like the Respondent could not think of a better explanation other than that Grandma and I were lovers.


• Grandma’s Police Report Against Me – In the latter part of 2017, it seemed that the Respondent had somehow persuaded or coaxed Grandma into being back on her side, which was not completely unforeseeable given the huge amount of pressure she had been receiving from numerous quarters. The first thing that it seems Grandma was forced to do was to make a false police report about how I supposedly stole her identity documents to buy and sell a car under her name. I have easily shown using an abundance of evidence (previous chat records and phone call recordings) that her story was a complete lie, and I have also made a counter police report against her for giving false evidence. I shall update the Court with the results of the police investigation when done.


• Grandma’s Relationship with the Respondent and Me – I have generally had a good and respectful relationship with Grandma for all these years, but her relationship with the Respondent has almost always been bad since the time I met her. The relationship became the worst it had ever been last year. She would often complain to me about how the Respondent was treating her, and here is just one of her many quotes about the Respondent:
  
  “She is no longer a normal person. Whether she can control her words and actions, I have no expectation of that for her. The only way would be to send her for medical treatment, or if not then let the law take care of her.”


• Sexual Abuse and Physical Assault Towards FW – The Respondent’s allegations can easily be shown to be full of holes, inconsistencies and illogicalities. She contradicts herself in numerous places and obviously did not spend enough time ironing out her completely-fabricated story before making her affirmation. Of course, it can be also seen that the Respondent provides virtually no evidence of such abuse other than what she is claiming FW to have told her.


• Respondent’s Propensity To Lie and Manipulate Others to Lie – Even though her fabrications hit a new low when she accused me of having sexually abused FW, it was not totally unforeseen. The Respondent has a very long history of lying, and more than that, she also routinely forces people around her to lie for her. This has been shown so many times, and also pointed out by her own mother:
  
  “We all, husband, mother and brother, just can’t do anything about her frequently making up lies and fictional untrue stories.”



---

Unsworn affirmation?

• As already evident by the time of the hearing, my Affirmation was indeed sworn, and even though the three Appendices were not individually sworn (I didn’t realize I had to), I resubmitted sworn Appendices subsequently before the hearing. I believe the Respondent’s mistaken allegation (in Paragraph 2 and elsewhere) that what I submitted was unsworn probably stem from a clerical error in what was sent to her solicitors (and unsigned final draft), for which I apologize.



Moving Out History

• What the Respondent described in Paragraph 5 is incorrect in numerous places.


• Firstly, I first moved out of the house the first time in late 2013, not June 2014. I had moved out after the Respondent refused to stop having a fight (screaming and yelling) in front of FW, whereupon I said I would leave the house, and to which she said if I should leave then I should never come back and she would lock the doors and not let me back in. I therefore packed my bags and moved to the office. The Respondent will no doubt remember that FW’s head teacher (叶老师) successfully persuaded me to return home on Christmas day of 2013, after my staying in the office for probably less than a month.


• Secondly, I only moved out again once more, twice in total, and not “around 7 times” as the Respondent claims. That time, after a resumption of similar fights with the Respondent in front of FW, I moved out around March 2014. June 2014 was when I actually moved back to the house and started living in separate rooms. The Respondent’s statement that “Between June 2014 and 2016, he moved out around 7 times” is completely false and without basis. What evidence does she have that this happened? When I agreed to move back for the second time in June 2014, I did it on condition that we sign an “Agreement for Harmonious Marriage” to lay out important ground rules (for example we should never argue in front of FW), and I specifically stated that if the agreement is repeatedly violated by the Respondent and I leave the house again for the third time, I would never return again. I attach as “Exhibit R1” a copy of the signed Agreement for Harmonious Marriage. There is no date on the agreement but email records will show that it was signed in June 2014 before my moving back home.


• It is important to note that even for the two periods when I was living at my office (which was less than 5 minutes away), it made hardly any difference to FW, at least initially – I still put FW to bed at night, and when the Respondent returned home from work around 10pm, I would leave and sleep in my office, and then return first thing in the morning to wake FW up and take her to school. So practically speaking, it was no different for her. However, the Respondent then started to insist on her taking FW to school in the mornings, and that was when she began to prepare breakfast for her (either cooking or buying breakfast the night before). Even then, I still came back many mornings to help FW get ready for school, but did not sit with her and the Respondent at the dining table because it would just end up with the Respondent having some reason to yell at me again, typically by accusing me of being a hypocrite, pretending to still care about FW even though I have “abandoned” her. Nevertheless, I would still pick her up from school, have dinner with her, and be with her until her bed time (as described in my Form J).


• Lastly, the Respondent’s statement that I “finally moved out for good in 2016” is also, at best, a complete twisting of facts as far as it implies that I left the Respondent and FW. First of all, we ALL had to move out, because our landlord had sold the flat and the new owner would not renew our lease, which would expire on 31st December 2016.


• In anticipation of that, I had already begun searching for a new home for us in the same residence (Rainbow Luxury) in October 2016 and found suitable replacements which I then proposed to the Respondent. However, the Respondent turned them down and said she would be the one to rent the flat this time. She later then settled on one in November, but never consulted with me nor even told me the details. In fact, it was our maid who later informed me which flat they had rented – she had to supervise workers who were there to renovate the flat. Evidence of the above can be provided if the Respondent wishes to dispute it. (NOTE: Our relationship had already broken down starting from July/August 2016, and FW was already being kept away from me and turned against me by then.)


• The Respondent signed the lease for her new flat in November 2016, and the flat was exactly the same as our current flat, except in a different tower. The layout of these flats had 4 rooms – Master, Bedroom 1, Bedroom 2, and Study. From June 2014 up till then, I had slept and worked in Bedroom 1, the second largest room, while the Respondent slept with FW in the Master bedroom. After signing the lease, the Respondent said that since she’s now the one renting the flat, she gets to make all decisions, and I should sleep in the study, as she wanted to turn Bedroom 1 into a home cinema, and Bedroom 2 would be a princess room for FW. I told her if she did not give me Bedroom 1, I would simply not move in. FW begged the Respondent to reconsider, and she then offered me Bedroom 2. I told her it won’t work, because I can’t make my desk and the bed fit properly in it without obstructing the passageway to the balcony, and pointed out she was being unreasonable in not letting me remain in Bedroom 1. After some further pleading by FW, the Respondent said I can have Bedroom 1 but only on condition that I sign an agreement for her with certain conditions of stay, like never locking my door, always reporting my whereabouts, etc. I told her I would never sign anything for her again (due to what happened with the Loan Agreement).


• However, in an effort to compromise, I figured out how to make it work with Bedroom 2 – it would require me to dispose of the existing king-sized bed and buy a retractable bed instead, where I would fold the bed up against the wall each morning so as not to block the passageway to the balcony (so our maid could get to the washing machine etc.). I happily told this to the Respondent and FW thinking that we had overcome the impasse and we could therefore all continue to live together, but the Respondent still insisted I sign her agreement in order to let me stay. The above is evidenced from our Skype conversation on 29th November 2016, which I attach as “Exhibit R2”. Here is a short excerpt:
  
  
  


• It subsequently became clear to me that the Respondent had very little desire for letting me stay in anything other than the Study anyway. I noticed from the deliveries sent to our house that she already had the special wallpaper purchased for Bedroom 1 (Galaxy/night sky for home cinema) and for Bedroom 2 (opulent princess style), and our maid told me that workers had already started with the renovation work even at the time of the above Skype conversation. A simple viewing of her current home will show the above renovations.


• The Respondent and FW then moved out one day in early December without even telling me. Since it was clear I was not welcome to the new flat, I started looking for another flat after that. I found one within a week or so, and moved out myself on 23rd December 2016, weeks after the Respondent had already moved to the new flat without me.


• Given the circumstances above, how is it possible for the Respondent to truthfully say that I “finally moved out for good” in 2016, trying to imply that I left them? Yet this is what she tells everyone, and even FW seems to believe that I’m the one who abandoned them, despite all the provable facts to the contrary.



Loan Agreement / High Court Case

• There is actually a lot I would like to say regarding the High Court case concerning the Loan Agreement, but since I do not see how it is relevant to the current issue regarding supervised access, I will refer to my Affirmation in Reply made to the High Court dated 12th January 2018 (in particular, paragraphs 6 to 14 thereof) which I hereby attach as “Exhibit R3”, and which already addresses many of the false allegations and insinuations made by the Respondent in Paragraphs 6 to 11.


• In addition, I’d like to attach as “Exhibit R4” what I wrote in section 5.2 of my recent Form E submission, where I also talk about how the entire situation regarding the Loan Agreement shows the Respondent’s “all-take, no-give” mentality



Evidence, Corroboration, and Truthfulness

• Paragraph 12 onwards contains a very large number of inaccuracies, as well as statements that are exaggerated, twisted beyond recognition, simply untrue, and in some instances, completely fabricated. There are honestly too many to deal with them all, so I shall be focusing on what I consider to be the more important ones, and I hope it will be apparent that she has been outright lying in many instances.


• Before that, I would like to emphasize that everything I have said and will say is true (at least not knowingly false), and where the Respondent has denied or denies what I say, I CHALLENGE the Respondent to not just simply deny it, but to prove it using supporting evidence like what I have been doing and will continue to do as far as I can.


• Some of the evidence I have come from conversations that took place over digital channels such as email, Wechat, Skype, etc. To avoid any doubt whether the screenshots I take of such conversations are real and unmanipulated, I hereby welcome the Court to verify the conversation records directly on my devices, such as my phone for Wechat records, or computer for emails. If the Respondent wishes to state that any particular conversation was manipulated, I would also welcome her to tell me exactly how and where the alleged manipulation occurred, and then have her solicitors arrange a time with me so that they can verify the records directly. Of course, for items like email, Wechat or Skype conversations involving the Respondent, it should be easy to disprove as she would also have her own copy, but I am assuming that she would simply say (conveniently) that she does not have them anymore.


• The Respondent claims in Paragraphs 26 and 33 that the previous video and audio recordings I submitted have all been edited, and that “we have never had such a conversation in that way.” I would ask the Respondent to be specific as to which conversations or recordings she is referring to, and to be specific as to how they have been edited. Which parts have been edited? What is she claiming to be the original unedited version? What exactly is she saying she or FW said or didn’t say? And if she can’t be specific, as I fully expect to be the case, then why not?


• For videos, audio recordings and phone call conversations, I shall be providing the original files directly to the Respondent’s solicitors so they can not only verify the accuracy of the transcripts. I also welcome them (and the Court) to check my phone, as well as the apps which made the recordings – they can see that the original files are still there within the apps. They are also welcome to send them to professionals to see if they have been manipulated in any way. If they are proven to be, I hereby declare that I shall cover all professional costs incurred.


• Specifically regarding my Wechat conversation records with the Respondent’s mother (“Grandma”) which the Respondent alleges in Paragraph 37 to have been “created by [myself]”, it should be noted that Grandma’s voice messages are also found throughout the entire chat history, including many which contain very disparaging remarks towards the Respondent. Like with the other evidence mentioned above, the Court and the Respondent’s solicitors are welcomed to examine the Wechat records directly on my mobile device to see if there is anything suspicious.



“Petitioner stopped supporting us”

• In Paragraphs 4, 17, 18, 19, the Respondent alleges several times that I stopped supporting the Respondent as well as FW soon after moving to Hangzhou (end of 2012). Can the Respondent please let the Court know:
  
  
  • Who paid for rent of the flat in which the Respondent and FW stayed between December 2012 and December 2016, plus related management fees etc.?
  • Who paid all utility bills, groceries, household expenses and the maid’s salary during that same time?
  • Who paid the Respondent a monthly allowance at least until the end of December 2013, even though the Respondent already started having a good income since the beginning of that year?
  • Who continuously reimbursed the Respondent for almost every expense she spent on FW when alone with her, as well as other expenses like gasoline even though she was the one mainly driving the car?
  • Who repeatedly lent the Respondent money for her own personal expenses even though she would often not pay back as promised?
  • When the Respondent found a job with New Oriental (新东方) in early 2013 and complained that a lot her salary was wasted on taxi fares, who then bought a car (MG3) for her, and initially drove her to and from classes, including waiting for her for hours while she taught, and then letting her use the car almost exclusively after she had got her driving license? After the Respondent kept on complaining that the car was too small and cheap, who then upgraded the car to a brand new Mercedes SUV in June 2016?
  • Who paid for FW’s school tuition and expenses (for both international school and local school) for 2013-2016, as well as the recent two years of international school fees? (I know the fees for the current year are disputed, and that will be dealt with separately.)
  • Who paid for FW’s after-school child care (托班) fees, ukulele lesson fees (2014-2016), band fees (2015-2016), contest-related and performance-related fees and expenses (up to August 2016)?
  • Who paid for FW’s computers (desktop and laptop), phones, iPads, ukulele’s, guitars etc. up to December 2016


• The answer to all the above, of course, is me. Do none of the above qualify as ‘support’? Does the Respondent really deny the above? If so, firstly, I would ask the Respondent to please show evidence if possible, any evidence, that rebuts what I said. I’m quite certain that almost everything I wrote above can be substantiated and corroborated (if not proven beyond doubt) through our communication history and other records. So if the Respondent wishes to deny any of it, at least please be specific so I can go through all past records to find corroborative evidence of whatever she denies, including printing out bank statements and trawling through my entire Wechat and Gtalk history as well as emails etc. with the Respondent dating back to 2013. However, the email thread between me and the Respondent dated 1st October 2013 and titled “Money arrangements going forward” which I attach as “Exhibit R5” should already sufficiently corroborate most of the above.



Reduction of Monthly Allowance to the Respondent

• What I believe the Respondent probably meant is that I did not give her much monthly allowance anymore after moving to Hangzhou, which is absolutely true.


• Before moving to Hangzhou, I remember that I would give her a monthly allowance of around $20,000 a month, on top of letting her use a credit card and spend money on spas etc at the American Club. Because my business did not succeed (at least not yet) and we were living a lavish lifestyle (the reasons for living such a lifestyle I shall not get into here), we ran out of money, and we decided to move to Hangzhou.


• To make matters worse, the Respondent continued with dishonest behaviour regarding money and spending. Ever since the start of our marriage in 2001, we had many fights because of the Respondent’s spending habits and dishonest behavior, including:
  
  
  • stealing my credit cards or card details (including my company credit cards) and purchasing things (most often luxury items or services), especially online, completely without my authorization and in breach of her promises to me
  • stealing cash from my wallet or from my sometimes-unlocked safe (which I had bought to specifically guard against her and no one else)
  • other dishonest behaviour like breaking into my email account to gain access to my Paypal account (using the ‘lost password’ function) in order to make further unauthorized spendings.


• This was a continuous problem, and even when we had run out of money at the end of 2012 and in the middle of preparing to move to Hangzhou, she was still doing the same thing, with total disregard for the financial problems we had.


• Just before moving to Hangzhou, her monthly allowance was already reduced to $10,000 a month, and due to further episodes of ‘theft’ in November 2012, she offered to pay back the money by reducing her allowance to 2700 yuan a month until November 2013. It seems like I still gave her more though, but due to further such incidents that continued into January 2013, it was set to 1000 yuan a week (4000 yuan a month, which was still above the 2700 yuan she had proposed before). Later, that became 600 yuan a week. Apparently in March 2014 (according to the Respondent’s own words in a public forum), it eventually became zero. I haven’t looked through our correspondence records to try to determine the reason it was eventually reduced to zero, but it’s probably a combination of her further stealing or borrowing money and not paying back (therefore reducing the allowance in order to repay back the money), and because she was already earning a lot of money after she started her teaching career in January or February 2013.


• I am attaching as “Exhibit R6” certain emails, Gtalk chat history and related documents from November 2012 to November 2013 that show most of what I described above, including repeated and continuous dishonest or unauthorized spendings by the Respondent, and how and why her monthly allowance was reduced over time because of that. The Respondent’s dishonest actions is not in dispute – it is clear from the correspondence that she has acknowledged her actions. That, as well as words like:
  
  “You are a loser and a stay-home father…. I am literally getting paid less than Marisa so please don’t count me to be involved in [FW’s] parenting educating etc. etc.” (23rd Dec. 2012)
  
  “From now on, you should be even more guarded because you haven’t seen anything yet. You not want to wrong a Scorpio. Consider that a precaution.” (23rd Dec. 2012)
  
  “God would not let a man who abuses his wife succeeds.” (1st Oct. 2013)
  
  


• In light of the above and all the evidence I attached, let’s review the Respondent’s statements again:
  
  
  • “the Petitioner stopped supporting us some time after we moved to Hangzhou in November 2012”
  • “Soon after we moved to Hangzhou, the Petitioner started to say he would not give me any money for the maintenance of FW and me.”
  • “the Petitioner stopped providing for FW and I, and in order to sustain FW’s education and lifestyle, I started working.”
  • “seeing as the Petitioner had cut-off all of our financial support for FW and I… I had to work to give FW the best that I can provide for her…”


• How can the Respondent honestly make these claims in light of all the facts I’ve shown? It’s clear that I’m the one who continued to provide for virtually all the family expenses. I’ve even continued to give her a monthly allowance even though she earns an income higher than me. Yet, to her, my reduction of monthly allowance (due to her continued dishonest transgressions) is twisted by the Respondent as saying that I stopped supporting her.


• Not only that, but the Respondent twists it further to allege that I stopped supporting FW also – notice how she says “FW and me” and “us” when she crafts her false narrative of being victimized. And this is not just what she is alleging to the Court now, but something she has all along been saying to others (including in FW’s school parent’s QQ group chat on 17th April 2014), and sadly, she seems to have convinced FW to believe this completely twisted story too, along with many other twisted stories. And even if her saying my not supporting them “at all” is based on my reducing her monthly allowance to zero, that did not happen until March 2014, more than 15 months after we moved to Hangzhou.


• The Respondent is clearly aggrieved that she did not continue to get a very high monthly allowance like before, but this shows two things about her mentality. First, she completely ignores the reasons why it was reduced in the first place (ie. because of her own repeated dishonest transgressions which caused tremendous damage to our financial situation and during a time when my financial circumstances were already very poor).


• Further, even though she started earning an income since early 2013, and which eventually became much higher than my own income, did she ever once think about contributing to the family for a change? I don’t mean occasionially buying designer clothes for FW or opulent furniture for the house that’s totally unnecessary, but in ways that really mattered and would have helped relieve my burden, eg. helping pay the rent? Obviously not, because she still expected me to continue to give her an allowance and shoulder her own expenses like car petrol! She sure knows how to take, but does she know how to give? She sure knows how to complain about lack, but does she know how to appreciate what’s already been given? This type of ungrateful and “all-take no-give” mentality is exactly the same that we saw during the time the Loan Agreement was signed, as already mentioned in paragraph 15 above. Like I said in the email of 1st October 2013 (Exhibit R5):
  



Primary Carer for FW – Hong Kong period

• The Respondent claims that she has been the primary caretaker since birth (see Paragraph 15).


• For the period when we lived in Hong Kong, I do not claim to be FW’s primary caretaker, but I’m doubtful if that title should go to the Respondent either, even though she was not working and therefore ought to have been so.


• Firstly, it’s totally untrue that the Respondent “stopped working to care for FW while we were still in Hong Kong.” The Respondent only ever held two jobs in Hong Kong. Both were in local private kindergartens, took place around 2001 and/or 2002, and both lasted maybe 2-3 months (or maybe half a year for the second one) because she could not get on with the principals and was asked to leave. (Incidentally, a similar result happened when she worked part-time for another child care center in Hangzhou (called “KidsGlobal”) – it also only lasted a couple of months before trouble arose again and she parted ways with them acrimoniously. They can provide written testimony if required.)


• After the two failed jobs in Hong Kong, she no longer wanted to work for anyone, so she never looked for a job again, and spent a lot of her time online shopping and, I suspect, doing cosmetic surgery (which caused many of the financial problems mentioned above). In any case, she had not been working for several years before FW was born in October 2005, so it’s absolutely incorrect to say she “stopped working to care for FW while we were still in Hong Kong”. If the Respondent wishes to dispute this, then I can ask our friends during that period to attest to what I’m saying.


• Even though she was not working after FW was born, neither did she spend much time with FW as far as I was aware. Apart from certain brief periods like immediately after birth, of course, I honestly believe she never spent that much time with FW, and most of the time it was our maid (and Grandma during certain periods) who took care of FW while I was at work. That is why even though I was working, I would say that it’s quite possible (and even likely) that I actually spent more time (especially quality time) with her than the Respondent. One may ask, “what did the Respondent do then, if not spending time with FW?” Well, likely the same things she had been doing all the previous years before FW was born, whatever that was (Sleeping late, online shopping, doing spas, cosmetic surgeries, etc.?).


• The Respondent is not someone who likes playing with kids, especially during the baby/toddler stage, whereas I was the opposite. In fact, I was so into bringing up FW that my Brillkids early learning business (see www.brillbaby.com, www.brillkids.com and www.eeecf.org ) which I started in 2007 was the direct result of my having spent all that time teaching FW, resulting in her learning to read many words as early as 12 months old.


• These can be seen in several videos I took showing her reading between the ages 12 months and 2.5 years old, some of which can be found on the website I created for her: www.FWwong.com . On the website can also be seen all her photos which I meticulously took, edited (mainly file size and cropping) and posted to her website. I also have hundreds and hundreds more photos and videos not featured on the website, starting from birth all the way to when she was 11 (until end of 2016), and upon examination I believe most people would at least conclude that I have been a very involved father since birth. One would probably also notice that the Respondent doesn’t feature much in them. Please see “Exhibit R7” for more information regarding this.
  
  



Primary Carer for FW – Hangzhou period

• The Respondent denies that I had been the primary caretaker of FW since moving to Hangzhou (see Paragraph 14), and contends that she was, “since her birth” (Paragraph 15).


• Yet, she admits that she was first working with “XDF” (New Oriental 新东方) and that she would arrive home from work only at 11pm and therefore “this did not give [her] much time to spend with FW”. Let me add that she started working for New Oriental around February 2013, less than two months after moving Hangzhou (provable through email and chat records)


• She then says that she “started having [her] own education centre two years ago which would allow [her] to arrive home at about 9pm on busy days”. First, she got her dates very wrong, and left out some periods of time. She left New Oriental to privately tutor children probably around the end of 2013. She then worked part-time with a nursery/kindergarten called KidsGlobal towards the end of 2013 or early 2014, but stopped after falling out with the people there again after a few months (as already mentioned in paragraph 55 above). It was soon after that when she started renting a room at “Cotton Candy” education centre sometime in early 2014 to continue to privately tutor her students, and she continued teaching there till at least towards the end of 2017 (not sure about now).


• In any case, isn’t she already effectively admitting that she’s been teaching since February 2013 until now, and that she could only arrive home late at night? Given that FW is in school during the day during weekdays and the Respondent is teaching during after-school hours and most of the weekends and returning home only late at night, how can the Respondent claim to be the primary caretaker of FW? She basically got to see FW on weekdays every night just before FW was about to go to bed, plus Saturdays from 4-5pm onwards – that was their only real Mommy-Daughter time.


• The Respondent said that her mother (“Grandma”) started living with us around November 2014 upon my invitation, and that Grandma helped the Respondent look after FW when she was at work. First, her dates are again way off. Grandma came to live with us towards the end of 2013. She had been taking care of her son Wesley (the Respondent’s brother) who was unemployed and suffering from bi-polar disorder in Taiwan, but she was finding it difficult making ends meet. So I invited her to come stay with us, which she did, all the way until June 2014 when the Respondent essentially forced her to leave and stay in another place. During those months after Grandma had came to stay with us, they had ended up arguing incessantly and that was also when the first incidences of violence by the Respondent towards Grandma started to happen (mentioned in my Form J). This conflict between the Respondent and Grandma (including forcing her to leave) can be proven through numerous Wechat records and photos of Grandma’s physical injuries by the Respondent.


• The above time also corresponded with the time I had left home for the second time to stay in the office (March to June 2014) and during this time, Grandma’s presence did indeed help me a lot in taking care of FW. Perhaps during these few months, I would say that it was mainly Grandma and myself who took care of FW. After the Respondent forced Grandma to leave, the only times Grandma could see FW was when FW was at her child care/tutoring centre at Cotton Candy, where Grandma also worked as a teacher. After the Respondent and FW moved to the new flat in December 2016, the Respondent persuaded Grandma to live with them, but Grandma was forced to leave yet again in March 2017 after many incidents of conflict (including physical abuse by the Respondent towards Grandma and the Respondent locking Grandma out of the flat). Please see Police warning letter to the Respondent asking that she desist from physical violence towards Grandma dated 16th February 2017 attached as “Exhibit R8”. It also showed that the Respondent was locking Grandma out and preventing Grandma from seeing FW. To sum up, it can hardly be said that Grandma played any major role for any significant period in being Felicitiy’s caretaker.


• In short, I had been FW’s main caretaker since we moved to Hangzhou up until August 2016. It certainly wasn’t the Respondent given that she was teaching during the times FW was not at school, and it wasn’t Grandma either as explained above. This is especially apparent with regard to FW’s schooling and extra curricular activities during that time. Regarding schooling, I attach as “Exhibit R9” a letter by FW’s head teacher Mr. Zhang Hua at the local Chinese school where FW was for three years between 2013-2016. The letter was originally prepared by Mr. Zhang for the purposes of the original divorce proceedings in Hangzhou in 2017, and confirms that I was the one in charge of FW’s schooling, and was even given an “Outstanding Parent” (优秀家长) award.


• Apart from being very involved in her school life, I also spent virtually all my spare time outside work with FW and her extracurricular interests, especially from early 2014 until August 2016. I attach as “Exhibit R10” what I wrote in my recent Form J regarding FW’s extracurricular activities, and as ““Exhibit R11” video links and screenshots showing my involvement with FW’s extracurricular life. FW’s head teacher Zhang Hua also confirms that I was the one who nurtured FW’s musical and performance talents (Exhibit R9).



Changes of School (International to Local School, and back to International)

• Just a quick note regarding transferring FW from international school to a local Chinese school. I had always been keen on FW attending local schools, even in Hong Kong, despite the fact that I was more in agreement with Western-style education over the long term. The reason is because I wanted FW to be a well-rounded individual with a wide range of experiences, and someone who was multilingual, especially in Chinese. When we were in Hong Kong, going to anywhere other than Hong Kong International School had never been on the table given the Respondant’s attitude, so I never pushed the issue there in order not to have a pointless fight with the Respondent that would achieve nothing in the end.


• When in Hangzhou, I also agreed to have FW attend Hangzhou International School (HIS) when we first moved there, and she did so for the second semester of the year (first half of 2013). Just after the summer holidays started, however, I had a conversation with FW about my own education and life path. I told her that my father had put me and my siblings all into a Chinese primary school in Malaysia and I had hated it back then, and was constantly envious of all my cousins who were attending English-speaking international schools. I continued to tell her that after I was an adult, however, I actually thanked my father countless times for having put us into that Chinese school, because my consequent knowledge in Chinese (coupled with short working experiences in China during a gap year after graduation) totally changed my career path – from being a typical lawyer in Malaysia in a local firm, to being chased by both Clifford Chance and Freshfields to work for them in Hong Kong, which then led to more wonderful job opportunities in Hong Kong. I told FW that I thought it was an enormous pity that even though we were living in China, she didn’t have the opportunity to really learn Chinese properly, or to mix with local children and thereby get a better understanding of Chinese culture. I also said that learning Chinese would be best done during primary school, when school results weren’t as important compared to later years. I had first hand experience of that as my grades were terrible during my primary school years (often bottom of class), but yet I still managed to get into Cambridge University.


• To my greatest surprise, FW indicated that she was open to the idea. I warned her that schooling would be more difficult, as there would be longer school hours, a lot more homework and a lot of rote memorization. But I also told her that I had no expectations on her for her school results – she would just need to learn Chinese (as she would do naturally), and she could be at the bottom of class like Daddy was for all I cared. Even though she had her concerns with changing school, she agreed to take on the challenge. It’s therefore totally inaccurate for the Respondent to say that “FW was devasted when she was suddenly told she would need to switch to a local school” as alleged by the Respondent in Paragraph 21. Not only was FW involved all the way in the decision-making process, she herself was also afraid of breaking the news to the Respondent as we both knew she would go ballistic. So I made sure I could get FW a place in a good local school first, and after pulling a lot of connections, I got her accepted into the best local school in our district – one that had only just opened the year before (therefore everything was grand and new), and was one of the new progressive and experimental-style schools that had a high status in Hangzhou.


• After that place was confirmed, I brought FW to have a good look at the school and the facilities, and she was happy to proceed. We then together told the Respondent, and as expected, she went berserk and tried immediately to convince FW to change her mind. Thankfully, with my assistance, FW stood firm, and she proceeded to attend the local school. That was a tumultuous period I had with the Respondent, who continued to try to get me to change my mind and pay for HIS and have her continue there. Once, she even barged into my room in the middle of the night and started hitting me (including on the face) while I was still in bed. I would then often have to drag her out of my room and also lock the doors.


• Truth be told, I’m also thankful that this switch to the local school also helped save us about 140,000 yuan in international school fees a a year, which I probably would have had to borrow from my parents had FW continued at HIS. But to me, even if the local school were to cost the same, I still would have preferred to have paid for the local school instead of HIS – that’s how much I value the local school experience for FW at that point in her life.


• FW did very well at the local school. She was a fast learner, and was self-motivated, and the amount of homework was no where near as much as I had feared. She made incredible progress with her Chinese, which everyone was very proud of, even the Respondent though she would try to hide it. Soon, she was making many friends, and settled in well. She would often even place within the top five for some Chinese tests, which she was very proud of.


• Typically, after I picked her up from school at 4.15pm, we would spend about an hour in a coffee shop or bread shop where she would have a snack and talk about her day, and she would often confide in me about things, even about the boys she liked in class (Incidentally, that’s how she wrote the song “Puppy love”, after I had told her that what she was feeling was probably what’s-called puppy love.) Of course, as with most children, there would be things she would complain about, such as the food sometimes, or the teacher being strict with her, friend problems etc.


• During her Grade four (third year), her rock band (comprising five kids from her class, and where she was the lead singer) was doing very well and gaining a lot of attention, especially having won first place in a Zhejiang Province children’s rock band contest. Towards the end of that year, FW would often complain to me that she felt ‘bullied’ by some of the other band members (who were all boys) and even sometimes their parents. I tried my best to placate her concerns, like telling her that the boys probably secretly liked her and just wanted to get her attention, and I even recounted how I myself as an 11 year old was so fearful that others would know I liked a girl that I would do things to annoy that girl so people wouldn’t find out. I also tried to help her not form conclusions that certain acts by other parents were because they didn’t like her, and helped her try to see other possible explanations that weren’t as negative.


• However, it was around that time (July/August) when the Respondent started getting involved with FW’s life, and the Respondent used that opportunity to ‘confirm’ FW’s fears that she was being bullied by the other band members and mistreated by some parents. The Respondent positioned herself as someone who had FW’s back and who would protect her all from these ‘bad’ people around her, and help her seek justice for all the wrongdoings being done upon her by others. I was cast as the weak father who didn’t have her best interests at heart and someone who was unable to protect her.


• When the Respondent said that she also wanted to join the band contest along with the rest of parents and children in late July (which would have been the first time she attended any band event), I privately told FW that the Respondent being there was a terrible idea, because it probably would become a mess with her presence, and also because one of the mothers did not like the Respondent, which was what I honestly believed. FW then told the Respondent what I said, so the Respondent then confronted that parent, and when the parent denied that she disliked the Respondent, I was also branded as a big liar. That was the start of the process where FW would be turned against me, and when the Respondent slowly started to isolate FW from me.


• During the band contest event lasting several days which the Respondent joined, as expected, there were a lot of problems and acrimony created by the Respondent with the other parents, partly because of her antisocial and diva nature, but particularly because she was accusing the Band teacher of not appreciating FW enough, since he had appointed another band member as band leader, a position the Respondent badly wanted for FW in order to ‘boost her resume’. The band teacher insisted to me that the Respondent should never attend another band event again. Later, the Respondent had also wanted to not let FW attend another band performance that was coming up, but lied to the Band teacher by saying that it was the school’s head teacher who objected to FW missing school for that day. Unbeknownst to her, the Band teacher was good friends with the head teacher, and her lies were exposed. Embarrassed and angry, the Respondent then convinced FW to further hate the band members and Band teacher and had her quit the band. Because now the school’s head teacher was also involved, she also decided to withdraw FW from the local school altogether.


• Of course I was furious, but she announced this to the head teacher against my clear objections anyway. I told her I would not pay for her international school fees if she pulled her out, and even though she had no money (despite her high income) to pay for her school fees, she pulled her out anyway, saying that she would just homeschool FW in the morning and afternoon before her classes started.

NOTE: Some of the above events (like the Respondent’s conflicts with the band members and pulling her out of school) are alluded to in the head teacher (Mr. Zhang Hua)’s letter in Exhibit R9, but I would be happy to provide more evidence if the Respondent disputes what I said, including showing wechat conversations with the band teacher, or even having the band teacher write an affirmation describing what happened.


• Some time in August, seeing that FW’s place in the local school had already been given up to someone else (so she could no longer go back), and not wanting FW to be homeschooled by the Respondent, I decided to support the decision to send FW back to international school. Thankfully, I had some spare cash at that time which would be enough to pay for the fees. I told the Respondent that it would mean that we would have to live more frugally, as the school fees of around 160,000 yuan was completely unbudgeted and would require financial adjustments. She agreed and said she understood (though a few months later she would hire a lawyer to demand that I pay for FW’s ‘maintenance’, as shall be described in more detail further below.)


• After switching back to HIS, of course FW is happier, especially since she was already convinced to hate her fellow-students. Of course a child like FW, who’s mother-tongue is English, would enjoy an international school more. I myself would have been very happy too if my Mom had switched me to an international school away from the Chinese school during my primary years, where I could just speak English comfortably instead of having to learn Chinese. But then I would not have reaped (and continue to reap) the enormous advantages that my knowledge of Chinese has brought me in my career. In any event, my original plan was to have FW return to international school for Secondary school anyway, like what I did.



Neglect of FW, Being A Child Actor, etc.

• Most of the Respondent’s allegations in Paragraphs 20, 22, 23 are either inaccurate, twisted, or completely fabricated.


• It was very rare that I did anything that could be called ‘neglecting’ FW beyond what’s generally considered reasonable or appropriate. The only times I have left FW at home is when I would go for a game of badminton at FW’s school with other class parents, and even this would be at most once a week. FW would be absolutely aware of where I was, and could reach me at any time, which she would often do anyway. I tried to explain to her that people need exercise to have a healthy life, and this was basically my only opportunity to exercise. And yes, one of these badminton sessions happened during a day when FW had been sick since the morning or the night before. However, by that evening, FW had already recovered a lot, and was happily playing Minecraft on her computer and/or chatting or playing with her Malaysian cousin Wen-Li (online). I therefore felt comfortable enough to leave her alone at home like other times. Afterall, she could contact me easily, and I was just about 7 minutes away. But the Respondent chooses to take this one incident and say that I left her sick and alone at home many times and with no one knowing where I was. All untrue.


• I have never encouraged FW to quit studying. How could I? I have always hoped that she will one day attend a good University like Harvard or Cambridge, as I feel it would help her a lot in many different ways and be a source of pride for her entire life, just like it has certainly helped me and has been a source of pride for myself and the Respondent. However, I have always suggested to FW that she follows her heart and follows her dreams, whatever they might lead her. If she wanted to take up a singing career, then I would support that too, even though my advice to her would be to have all the fun and experience in singing and performing when she was still young, and then settle down and study hard and get into a good University. However, I had no fixed vision for her, unlike the Respondent who believes that FW must attend Harvard or at least a top University at any cost.


• Paragraph 23 is almost entirely made up. FW's main interest (and talent) has always been in singing and music, not acting. Look at all the events she has participated in – they are all either English or music related. The only thing that was purely acting that I exposed FW to was this: We were on our way back from Sochi (Russia) after the World Choir Games competition, and we were traveling with another parent of the choir and her son. Our flight back was via Shanghai, and that parent had offered us a ride back by car to Hangzhou from Shanghai. She was also an investor in a TV series that was being produced, so after reaching Shanghai, we took up her offer to accompany her to the film studio to get briefed by the producer, and take that opportunity to also watch how the filming was done. We had a quick lunch there with the producer and she took some pictures with the film stars there. We were there for two to three hours in total and then we left to go back to Hangzhou. That was the only time FW had been in a film set, and completely under not only my supervision, but also that of the other choir parent, who’s son was also there at the same time. I posted this event on my Wechat Moments, and ever since then it seems the Respondent believes I frequently take her to these places, which she has all along considered ‘seedy’ and dark.


• To be specific:
  
  
  • We only went to a movie set once, as described above
  • There was no ‘always going there because the people were vulgar and rude’
  • There was definitely no “touching her which made her feel uncomfortable”. It is, like many of the Respondent’s allegations, completely made up. By the way, the producer, and two main actresses who she took photos with, were all female.
  • Her imaginative description of me screaming at her and shaking her telling her to stop saying negative things about the movie industry never happened. At most we had disagreements sometimes over what the movie industry was like (or had to be like) or the type of experience that FW would have to go through if she ever chose to act.


• I therefore challenge the Respondent to show any corroborative evidence that I took her to film sets beyond what I described above, and that the ‘touching’ etc. happened to her.


• In Paragraph 23, the Respondent says that I was “basically forcing FW, against her own will, to become an entertainment star and forego her academics” and I “exploit FW’s talents and skills to achieve [my] own ambitions…” Firstly, what exactly are my ambitions, and how does FW becoming an entertainment star help me achieve it? Has my career at any point in time had anything to do with the entertainment industry? The answer is, no, nothing. Do I like singing and performing? Yes I do. Do I think FW has talent in this area? Yes, an abundance of talent. Do I wish to nurture that talent? Absolutely yes, since FW also loves music and performing, and I am able to help her a lot in this area like I already have done. Given FW’s talent in music and performing, as well as her interest in this area, I would be completely remiss as a parent if I didn’t nurture her talent and give her the opportunities to develop her talent, would I not?


• Besides, the Respondent herself obviously isn’t against FW pursuing her interests in music and performing. FW was recently chosen for the starring role in the Madagascar musical at her current International school because of her talent, and obviously the Respondent is supportive of that. Does the Respondent believe that FW’s getting that role has nothing to do with my nurturing and developing her talent since birth?


• In fact, if anything, I could more easily accuse the Respondent of “forcing FW, against her own will… to achieve [her] own ambitions.” The Respondent not only teaches English to kids, but also advises parents on getting their children to US schools and colleges. I believe one reason she is so keen on FW getting into Harvard and scoring well in her SSAT etc. is so that she could prove to her existing and potential clients (parents) that she is very qualified in helping their children achieve the same thing.



Playing Games and Watching Movies

• Yes, I did allow FW to play computer games, and we would often watch movies together. But that’s hardly all she did, even though the Respondent tries to paint the picture as such. First, I have always encouraged her to use the computer and bought her her own computer soon after moving to Hangzhou. She picked it up very quickly and started creating very advanced Powerpoint and Word documents as early as age 8, even dabbling with Excel from time to time. These tools enabled her to write out and illustrate the stories she was creating, as well as to create “homework” for me (she would make me memorize all the “Spintas’” (Pokemon-like creatures) she was creating, and would often create tests for me to do, using Word/Powerpoint. From about age 9 or 10, most of the stories she would write were already typed out by herself. She would also learn to use art programs to illustrate her creations, audio editors to edit the music or audio that she created, and even video editors to edit videos she would make (either of herself or screen recordings of her Minecraft sessions), which she would share on her Youtube channel with others like her Malaysian cousin Wen-Li.


• The main game she liked playing on the computer was Minecraft, which I fully encouraged, as I don’t view it as just a ‘game’. Just do a search on “why kids should play Minecraft” and read any of the many articles that will come up. To me, the main reason I encourage her to play is that it allows her to be extremely creative in building things and devices in a three dimensional virtual world, and she even learned things like building electric circuits to power devices, as well as computer coding to create more advanced Minecraft items. Minecraft also gave us a great bonding experience as we would often navigate new worlds together and create stuff together (see the last item of Exhibit R11, for example). The Respondent wouldn’t know any of this, because she never bothered to find out nor to enter FW’s world.
  
  
  (FW (left) and me (centre) after having built a Pokemon statue)


• In any event, I made sure FW did not just play games or watch Youtube videos. Her time on the computer was limited by the use of a program called “Computer Time”, which would lock the computer or lock internet access according to the time of day, or only allow usage by use of tokens, which I would grant FW on a limited basis each day or upon the completion of other activities I wanted to encourage.


• From time to time, we would also often watch movies together, which also gave us a great bonding experience, as well as a teaching opportunity for me depending on what issues the movies brought up. How can the Respondent complain about movie-watching when a far greater proportion of the time she used to spend with FW was in just watching movies. Not only that, she would often watch movies in the master bedroom with FW even though if would already be way past her bedtime after the Respondent returned home, or would watch anyway by herself while FW tried to sleep. Worse, the Respondent would even often watch with FW very inappropriate content such as Game of Thrones, which would be replete with violent and sexual content. And movie watching is so important to the Respondent she has even turned the second largest room in the flat (the one I used to stay in) into a movie theater room.



The Respondent’s Relationship with FW

• The Respondent alleges that FW would refuse to go to the Respondent because I was trying to distance FW away from her (Paragraph 25), and that I would often “say a lot of bad things about [her]” (Paragraph 27). Yes, FW indeed would often refuse to go the Respondent – that IS true. However, it’s completely wrong to say that the reason was because of my actions. The truth was, in fact, the opposite.


• As mentioned above, the Respondent did not show any interest in FW’s schooling during the time she was in the local school. The Respondent also never took much of an interest in all of FW’s other interests, including the stories she was writing. When FW would show her her creations, she would politely feign interest for a short while, but her attention would wander off to other things very soon, and she would almost never take the initiative to enquire more about FW’s interests. Same thing for FW’s singing and performances, her choir, her rock band (until July 2016 before getting involved and then pulling her out), and certainly her activities on the computer. Naturally, therefore, FW and I became very close, and FW felt more and more distant from the Respondent.


• The Respondent’s way of showing love to FW generally revolved around spending money, like buying her very expensive clothes and shoes, and taking her on holidays where they would fly business class, stay in 5 or 6 star hotels, and eat in expensive restaurants. This thinking can be seen in the Wechat conversation I had with the Respondent when FW got lost while they were in Universal Studios in Los Angeles (see “Exhibit R12” attached). The Respondent and FW had been fighting a lot before she got lost, and the Respondent was complaining to me that FW was ‘wayward’, ‘hopeless’ and ‘recalcitrant’, needed to be taught how to comply. She said, “Here you are doing the almost-no-budget stuff and indulge her with laissez faire attitude, on the other hand I am doing the high end stuff to be treated like sh*t.” I responded, “It’s never about how much you spend. When will you understand?” The Respondent then refused to take my advice to go look for her, and said that she’s not going to bother, and even saying that if FW were to be “permanently lost”, she would be “sad but definitely relieved.” Yes, that’s correct – the Respondent actually would have been relieved if FW got lost and never got found again! I then pointed out to her, “if she feels you never cared enough to find her, you expect there to be any chance for her to be close to you?” and “It’s what you do during times like this that’s important, and not how much you spend.”


• I believe that it’s very important for children to have a good relationship with both their parents, and I was mindful that the Respondent and FW were fighting more and more, and FW was increasingly ignoring her mother. This had been an issue that had always concerned me since FW was very young, as I had always been the one who was closer to her. Anyone who knew our family can attest to this, including FW’s God-parents. (The Respondent also acknowledges this herself even as late as 25th May 2016 in a QQ message to me: “If I were FW, I would prefer you over myself too, which child wouldn't prefer a parent who lets her be?”) So from young, I had been telling FW the importance that she get along with her mother, that she try her best not to argue with her, and to do as she says, even though it often was quite unreasonable. I pointed out that the Respondent does not have a good relationship with Grandma, and according to the Respondent, Grandma also did not have a good relationship with her own mother. So I had always encouraged FW to be the one to break this cycle and get along with her mother, and tried to give her the belief that she could and would do it. Whenever I was with FW when the Respondent would come home at night and FW just continued doing what she was doing, I would almost always remind FW to welcome the Respondent home and give her a welcome hug, even during the times when the Respondent and I were fighting. Why did I do this? Not because I loved the Respondent (though I did care for her wellbeing), but because I loved FW and wanted her to have a healthy mental and emotional state, which included getting along with her mother. Therefore, it is absolutely not true that I would deliberately do anything to make FW have a bad relationship with her mother, nor to speak badly of her. The only types of situation where I may be indirectly saying something negative about the Respondent would be where, for example, it would be in my own defence under false accusations by the Respondent and/or FW, where I would have to tell FW what really happened, and that would cast the Respondent in a bad light.


• Lastly, regarding the period of January to late March 2016 when I had weekly access to FW and when FW would often run to me or call me to go ‘save her’, the Respondent seems to believe that this happened because I was speaking badly of her and turning FW against her (Paragraph 27). The reality was that the Respondent was mistreating FW with unreasonable demands, threats, insults and violence. Even though FW would not say much to me why she was running away from the Respondent, it would become apparent later on from some of our conversations, and also from what Grandma had been telling me of what she was witnessing and what FW had told her (can be seen in Wechat conversations with Grandma).



Maintenance Agreement / Stopping of Payments

• In Paragraph 29, the Respondent acknowledges the Maintenance Expenses Agreement (“Maintenance Agreement”) I had mentioned in my first Affirmation of 13th December 2017, and admits that I was the one who added a clause to guarantee I would be able to see FW at least once a week. Yet she seems to imply that my agreeing to pay her the 15,000 yuan a month she demanded had nothing to do with her suddenly allowing FW to see me immediately after the agreement was signed. How then does she explain the fact that FW started seeing me immediately after the agreement was signed?


• She goes on to describe how my payment was reduced to 5,000 yuan in April 2017 and then stopped after August 2017, which were all true, yet does not address the reasons I gave previously as to why the payments were reduced – ie. because I had terminated the Maintenance Agreement on 6th March 2017. It’s not clear if the Respondent denies this termination, so I am attaching as “Exhibit R13” the Wechat conversation with the Respondent on 5th and 6th March 2017 to show how the agreement was terminated.


• In Paragraph 38, the Respondent denies that I had offered to her to sign an amended version of the agreement (entitled “Family and Maintenance Expenses Agreement”) in order to resume payment of the 15,000 yuan a month. She even says she has “no idea what the content was.” First, I attach as “Exhibit R14” a blacklined version of the agreement showing the amendments I made, especially with the inclusion of two new clauses – one for the protection of FW, and the other for the protection of Grandma. The clause for protecting FW was mutual and applied to both of us, and in any event, both clauses only contained reasonable requirements like not physically assaulting FW and Grandma. I am also attaching as “Exhibit R15” the Wechat conversation on the 7th and 8th of March 2017 with the Respondent showing that I offered her to sign this amended agreement, and even telling her the contents of the agreement. It separately also emailed to her (also attached in Exhibit R15), as mentioned in the chat. We can also see that she refused to sign it, and told me that I would be hearing from her lawyer. How can she therefore truthfully say that she had never seen this agreement or know the contents?


• After the Respondent refused to sign the amended agreement, I started paying her 5000 yuan each month, hoping that that would make her change her mind. She didn’t, and FW then stopped seeing me. I tried to speak to FW at the Respondent’s classroom two or three times in April, but FW would say she couldn’t see me anymore because I had stopped paying the maintenance payments, and I should be punished. (The last conversation I had with FW in April can be seen in Exhibit 25, which is referred to below.)


• I already expected that the Respondent would coax FW not to see me. For example, this is a screenshot of what she had told me over Wechat on 13th March 2017, where she specifically said she was “no longer bounded by the agreement to let [FW] see [me]”:
  
  
  
  In fact, the Respondent had already said the following in the Wechat conversation shown in Exhibit R15:
  
  “I believe FW made it clear in her voice message to you that she is not interested to see a “father” who willfully terminates his agreement to pay for her.”
  
  It was clear that the Respondent was already twisting what was happening in order to make FW hate me.


• Sometime around or before August 2017, after I continued to have no access to FW, I told the Respondent that I would only pay in the future by giving the cash directly to FW – ie. I must be able to see her again. (I can’t remember how this was communicated, but it was probably through Alipay, which unfortunately I no longer have chat records.) There was no reply or no agreement, so I promptly stopped paying after that.


• As clearly shown, the reduction and eventual stopping of payments was completely and easily avoidable by the Respondent. She only had to sign the amended agreement (essentially agreeing not to mistreat FW and Grandma) and the 15,000 yuan a month payment would have resumed, and she only had to let me see FW again and the 5,000 yuan a month would have resumed.


• Lastly, it should be noted that I considered the very basis of the Maintenance Agreement (that I was supposedly not contributing to FW and therefore should pay her maintenance) to be ridiculous, not to mention the demanded amount of 15,000 yuan was quite over the top and unnecessary. That was why in Clause 7 I had specifically declared that my signing of the agreement did not mean that I thought the requirement to make those payments was reasonable.


• I considered it ridiculous because I had already been paying all expenses for the family (see paragraphs 40 and 41 above and Exhibit R5 hereof). Most of all, I had already paid for FW’s HIS tuition fees for 2016-2017 (see paragraph 80 above), which is also implicitly acknowledged by the Respondent in Paragraph 31. What sort of mentality must she have for her to be claiming that I was not making any contribution towards FW and demanding maintenance payments from me as at December 2016, when I had just paid 160,000 yuan in school fees for the year just 3 months earlier?



School Fees for 2017-2018 / Misappropriation of Funds

• In Paragraph 31, the Respondent denies that I had also set aside FW’s 2017-2018 school fees with Grandma for her safekeeping, saying that it was not for school fees. I find it difficult to describe this as anything other than yet another big lie.


• Sometime in November or December 2016, I had told the Respondent that I had FW’s 2017-2018 fees prepared, and that I would give it to her to pay when the time comes (around June 2017). The Respondent wanted assurance, and since I didn’t trust the Respondent, we agreed to give the money to Grandma, who would open a special deposit account just for this. I transferred 160,000 yuan to Grandma on 10th December 2016, and an extra 15,000 yuan two days later. On 14th December 2016, Grandma put the 175,000 yuan into a special deposit account, and I helped her take a picture of the deposit slip, along with her note to say that the funds were for FW’s school fees, and was not to be unilaterally used by anyone. I have attached as “Exhibit R16” that picture, as well as various Wechat conversations I had with Grandma coordinating this transfer. It’s clear from the conversations that I paid 175,000 yuan to Grandma for safekeeping for FW’s school fees, and that the Respondent knew about it - Grandma described the Respondent as “annoying’ for constantly chasing her for it.


• Unfortunately, not only did the Respondent know about the deposit and what it was for, some time soon after that deposit was made, Grandma confessed to me that the Respondent had forced/persuaded her to transfer 50,000 yuan to the Respondent, completely in breach of what was agreed amongst us. Grandma felt very bad about having betrayed my trust, and said she would make sure that the Respondent returned the money before the school fees became due. Given what had happened, Grandma had originally agreed to transfer the remaining money back to me instead of continuing to be the stakeholder, but later persuaded me to leave it with her, because she feared that if she did so she would be chased out of the house. This conversation with Grandma between 9th to 12th January 2017 is attached as “Exhibit R17”.


• However, the missing 50,000 yuan was not returned. Sometime in March 2017 (before Grandma was forced out of the Respondent’s home), the Respondent took Grandma to the bank to withdraw the balance of the money to transfer to the school. Apparently, she had added in another 8,000 yuan, and transferred a total of 133,000 yuan to the school.


• In October 2017, I asked the school about the missing balance (which was 42,750 yuan) and paid it off – see email correspondence with the school between 4th May and 21st October 2017 also attached in Exhibit R17. I therefore ended up paying a total of 217,750 yuan for FW’s 2017-2018 school fees, even though only 175,750 yuan had been required.


• Again, it’s clear that the Respondent knew about all this (even the balance payment, as she was cc’d). How can she therefore still truthfully say that “no money was ever paid for the school fees whether or not it was through my mother”?



Affair with the Respondent’s Mother

• I first started hearing that the Respondent was accusing Grandma and me of “hugging passionately” from Grandma on 8th March 2017 (see “Exhibit R18”, attached). This then later became “kissing and hugging passionately”, and then a full-blown “affair” with Grandma shortly thereafter. At first, I laughed it off as yet another one of the Respondent’s ridiculous accusations that would have been blatantly obvious to anyone who knew us that it was an insane idea, but I started taking it very seriously when I heard from Grandma that FW had also started to tell other people the same thing.


• It was obvious to Grandma and me why the Respondent had to resort to such a ridiculous accusation – the Respondent had only recently been given a police letter ordering her to stop any physical violence and other abusive behaviour against Grandma, and she had to make people believe that Grandma was just making it all up, and she had done so at my behest. She also had to explain why was it that even her own mother took my side instead of hers, and would regularly complain to some mutual friends about how the Respondent was mistreating her. I suppose my having an affair with Grandma was the only thing she could think of to defend herself and make others believe that Grandma was lying about everything.


• In paragraph 10 of my original Affirmation, I had described the incident on 5th March 2017 when the Respondent had had chased FW out of the house and I picked her up to sleep at my place. Grandma had accompanied her out, but found herself locked out of the house (see the Wechat conversation in Exhibit R13, where the Respondent said, “I am going to sleep now and I am wearing ear plugs, so it’s took bad she can’t get in”). I picked her up later and she also slept at my place. FW was already sleeping on my bed by that time, so Grandma slept downstairs on the sofa bed. A few days later, the Respondent was apparently telling others that FW had told her that on that evening of 5th March, I had made FW sleep downstairs alone on the sofa bed while Grandma slept with me upstairs in my bedroom. It seemed that this then became the Respondent’s official ‘evidence’ that I was having an affair with Grandma.


• On the 12th of March 2017, FW was at my home and I taped recorded my asking her about what she was supposedly telling others regarding the sleeping arrangements that night. The transcript of this conversation is attached as “Exhibit R19”. When asked, FW refused to talk about it. I asked if she was going to continue insisting that that was what happened, and when she said yes, I asked, “why would you do that?” FW replied, “look, because I’m screwed up.”


• Firstly, it should be obvious from FW’s answer (or refusal to answer) that her accusation of my having slept with Grandma was false – if it had really happened the way she had described, she would have said something like, “What do you mean, Dad? That’s what happened!” and “Because it’s true!”, instead of “I don’t want to talk about it”, and “Because I’m screwed up.” Secondly, it is heartbreaking to see FW seemingly having no choice but to continue telling that made-up story, and feeling that she is “screwed-up” for doing so.


• If fabricating such a disgusting story was not bad enough, then forcing FW to also spread that lie to others is simply inexcusable. How sick does your mind have to be in order to do that?



Grandma’s Police Report Against Me

• It seems like Grandma is the latest person who has been forced to knowingly falsely accuse me. In Paragraph 37, the Respondent mentions that Grandma made a police report against me for “forgery or her signature and for stealing her travel documents to purchase a car” as well as “a subsequent “transfer of ownership” which was all completed without her knowledge”. Unfortunately for her and the Respondent, they probably never realized how completely and easily their above fabrications can be proven to be false.


• What happened was this. In November 2016, I had enough money to purchase a car for myself (since the one I had bought earlier was used by the Respondent almost exclusively), and found a second-hand car that I liked. However, to get a Hangzhou license plate, one would need to have a “quota permit”, which was very hard or expensive to get. The agent then suggested that they arrange for me to get a non-Hangzhou plate (specifically, a plate from Hefei, Anhui province) which would have some restrictions but which I considered to be fine. However, when they found out I was Malaysian, they said it would be difficult, and asked if I could use another ID like my wife’s. I said what about using my mother-in-law who had Taiwanese documents. After checking, they said that that would work, so I discussed this with Grandma, who promptly agreed.


• Since Grandma filed the false police report, I was called to the police station twice to help with their investigations, and on the second time, I showed them my entire Wechat conversation with Grandma, as well as phone recordings with her, which clearly proved that:
  
  
  • She knew about my buying and selling a car
  • She cooperated and fully assisted with it by sending me pictures of her identity documents as well as the required photo of herself, and later gave me the original documents
  • She knew that the purpose of my borrowing her identity documents was to purchase a car under her name
  
  
  Please see “Exhibit R20” where I have attached screenshots of relevant Wechat conversations with Grandma, a download link to phone recordings. I didn’t bother transcribing and translating them, but would be happy to do so if requested. In the meantime, the Court can easily download and listen to the call recordings. I have written more about the reasons why I think she filed this false police report against me in the following section.


• On that second visit to the police station, I also submitted my own police report against Grandma, accusing her of making a false police report and submitting false evidence, which I tendered to the police on 4th February 2018 (also attached to Exhibit R20). The police told me they will investigate the matter and give both Grandma and me a final outcome report once it’s been completed, and I look forward to sharing it with the Court when that happens by submitting “Exhibit 30” at a later date.


• If the Respondent still insists on continuing to peddle that false accusation as the truth, I fully welcome the Respondent to put Grandma in the witness box so we can discuss the facts in Court.



Grandma’s Relationship with the Respondent and Me

• Why did Grandma file a false police report against me? Wasn’t she supposed to be “on my side”? Prior to this, I have generally always had a very good relationship with Grandma, even though her relationship with the Respondent had most of the time been acrimonious, with me often playing the role of the peacemaker between them. I view Grandma as someone who is generally reasonable and kind, and who is not difficult to get on with. As my mother-in-law, I have always felt it was my duty to treat her kindly and with respect, and that’s why I always try to help her where I can, including giving/lending her (and her son Wesley) money, helping her move house (several times now), helping her with tech stuff like buying her phones and tablets (including her first smart phone and ipad back in 2008) when she needed them and helping her set up Wechat and Skype accounts etc. The above would be apparent to anyone who has a look through our entire Wechat conversation history, which dates all the way back to 2013 when I first helped her set it up (the Court, and even the Respondent’s lawyers, are welcome to have a look).


• Before this recent episode, Grandma had always prided herself as someone who would “help what’s right and not relatives” (帮理不帮亲), and that’s how she would always explain to others why she was often ‘on my side’. Unfortunately, this made matters worse with the Respondent, who expected Grandma to be on her side no matter what. This got even worse when Grandma was staying with the Respondent, because the Respondent then felt that Grandma (as she was staying for free) should do her every bidding, otherwise she would just be a “parasite”. Even though Grandma would often try her best to oblige, the Respondent’s requests would often be so unreasonable that Grandma would refuse, and then the Respondent would get extremely upset and often verbally (occasionally physically) abusive.


• For example, during the period when Grandma was persuaded again to stay with the Respondent and FW after they had moved to the new flat without me between December 2016 and March 2017, trouble first started again when the Respondent wanted to know where I lived (which I wouldn’t tell her) and demanded that Grandma follow me secretly until she found out. Another example is as mentioned in paragraphs 109 to 114 above, when Grandma felt she had to comply with the Respondent’s demand to let her misappropriate 50,000 yuan from the money that had been set aside for FW’s school fees. Attached as “Exhibit R21” is a Wechat conversation with messages from the Respondent forwarded to me by Grandma, showing how the Respondent pressured Grandma into demanding 50,000 yuan from me, insulting her along the way as a “parasite”. This was what led to the misappropriation of funds mentioned above, after she couldn’t get the 50,000 yuan from me directly.


• As the relationship between the Respondent and Grandma reached its lowest point ever during the first half of 2017 (amidst the violence, locking out, police reports etc.), Grandma was determined to help me fight for FW’s custody. Of course, one reason (I like to think the main reason) was that she truly felt that FW’s growing up with the Respondent would be detrimental to FW (see Wechat message from Grandma to me on 14th April 2017, attached as “Exhibit R22”). Here’s an excerpt (English translation):
  
  “She is no longer a normal person. Whether she can control her words and actions, I have no expectation of that for her. The only way would be to send her for medical treatment, or if not then let the law take care of her.”
  
  “Whatever you do please save FW.”
  
  “If FW is freed from her demonic grasp, then only you would be qualified, and have the ability.”


• However, I also believe that other reasons were probably that Grandma felt that it would only be possible for her to see FW (probably the dearest person to her) if it was me who had her custody, and also because it was more likely that I would take care of her compared to the Respondent.


• All along, however, some people around her would continually criticize and condemn her for siding with me and even being willing to take the stand as my witness in court. A lot of them were continually urged by the Respondent to persuade Grandma, if not to support the Respondent, at least don’t help me. Pressure also came from the Respondent’s Taiwanese relatives, especially her Fourth Uncle who is rich and influential. (Wechat conversations showing the above can be provided.)


• I had always told Grandma that she didn’t have to be my witness if she didn’t want to, but it had always been her who insisted she wanted to, in order to “save FW”. But over many months, under a lot of pressure, and (I’m guessing) probably financial and other enticements from Respondent, plus having the ability to live with and see FW again, I think Grandma gave in to the pressure and started cooperating with the Respondent. I’m guessing that Grandma also believes that the Respondent won’t dare do anything to her anymore (at least when these divorce proceedings are still ongoing), because the Respondent would not want Grandma to act as my witness.


• One day out of the blue on 26th October 2017, Grandma called me and started asking a series of questions about the car. She wanted to know how come she didn’t have to sign anything for the car to be put under her name, to which I replied that the agent who handled it didn’t require it. Then she was saying that if anything bad happened, she could get into trouble as it was under her name. I assured her she didn’t have to worry, and in any case, the car was already no longer under her name, but under my name. Unfortunately, there were two problems with what I said. First, the disposal of the car was a complicated story – I had sold the car and bought another one (effectively did a swap with a second hand dealer because of Hangzhou license plate restrictions preventing me from bringing the old car back into Hangzhou), but I just simplified it to say that the car was transferred back to my name already, so what I told her technically was not true (though in reality it made no difference to her). Second, I thought the car had been transferred out of her name by then already, but I later found out that at that time, the agent had still not found a buyer for the car yet, so it was still under her name. It looks like the Respondent went to check official records and found that what I said didn’t match the facts, so that probably gave Grandma a good reason to conclude I was a bad and devious liar just like what the Respondent had been saying all along. That night, it was obvious Grandma was being coached by someone else by the phone (presumably the Respondent), and I said I would go over and explain everything to her and that person. But she refused. I went over anyway, and found no one at her home. After that, I found that Grandma had blocked my calls, as well as Wechat. She remains uncontactable, and I have not spoken to her since that night. A fuller explanation of this incident can be seen in my email to FW on 15th January 2018 attached as part of Exhibit R24 mentioned further below. The call with Grandma described above can be heard from the link provided in Exhibit 20.


• Although it’s understandable why Grandma would think I lied, because technically I did (although it was out of convenience rather than malice), it is disappointing that she would suddenly cut off communications with me and not even let me explain the full story. But I’m not surprised at all, because this would definitely be one of the requirements that the Respondent would make of Grandma in whatever new agreement they have come to. Although disappointing even more, it’s also not too surprising that Grandma has apparently been forced to lodge a completely false police report against me (claiming I stole her identity documents and bought a car in her name without her knowledge). I know that the Respondent would be desperate to make me have a police case too, just like she does (for violence against Grandma), so that she can use it to continue to malign me, like she has already done in her last affirmation.


• However, the biggest takeaway to me from this event is this: If a fully mature and reasonably-minded adult like Grandma can be persuaded/coerced by the Respondent to believe in lies and twisted stories and even make false police reports, what chance does a young impressionable 12 year old like FW have, especially given her sweet and protective nature that compels her to protect those she believes are being unfairly treated?



Sexual Abuse and Physical Assault Towards FW

• In Paragraphs 39 to 45, the Respondent alleges that I have sexually harassed and physically assaulted FW. These completely fabricated allegations were not totally unexpected, but it does represent a new low for her, and confirms that there is really nothing the Respondent would not say or do (including forcing others to say or do) in order to get what she wants. It also shows her complete disregard towards her oath of truth she took when filing her Affirmation. I shall speak more about her propensity to lie further below, but I’ll first deal with her allegations.


• There are numerous problems with what the Respondent is saying. The first one is the glaring factual inconsistencies and contradictions inherent in her statements.
  
  A. Contradiction 1: When did I stop seeing FW?


• She acknowledges that “FW has stopped seeing the Petitioner about March 2017”, which was also what I had said in my Affirmation (“26th March 2017”) and is accurate if you don’t count the couple of times in early April when I tried to see her but could only talk to her outside the Respondent’s classroom for a few minutes. Yet in Paragraph 42, the Respondent seems to have forgotten what she had just acknowledged, and said that “he was still seeing FW then till July 2017.”


• And that’s not all. In Paragraph 43, the Respondent says that the “last occasion” was “around May 2017”, supposedly at a McDonald’s. So which is it:
  
  
  • “March 2017”
  • “July 2017” or
  • “May 2017”?
  
  
  B. Contradiction 2: When did the Respondent Find out about the Sexual Abuse?


• Another glaring inconsistency is that in Paragraph 44, the Respondent describes that FW was taught about inappropriate touching during local school sometime “between September 2015 to June 2016”, after which she told the Respondent about it, and therefore the Respondent confronted me about it “around early October 2016”. She goes on to say that therefore, “from early 2016” (which I take it is a typo and she really meant “from early 2017”) FW would go to her education centre to do her homework so she wouldn’t be left with me. The dates regarding FW being kept at her education centre wouldn’t be too far off the truth, except that it started around August 2016 as described in paragraph 5 of my first Affirmation.


• However, she has apparently again forgotten she had said in Paragraph 39 that “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”. In other words, she’s saying that she only knew about the sexual molestation after I had stopped seeing FW, which is one of March 2017, May 2017 or July 2017, depending on which version of her story one takes (see paragraphs 138 and 139 above), but in any of those three cases it is still wholly inconsistent with her saying that she found out about it and even confronted me in “early October 2016”.
  
  C. Illogicality and Inconsistency with Actions


• What she said also doesn’t make sense because it is wholly inconsistent with her actions. For example, what she says about what she did when she found out begs the following question:
  
  If the Respondent had already known about my sexual molestation and confronted me in “early October 2016”, and I had said, “What are you going to do about it?” (ie. I effectively admitted doing it), then:
  
  
  • Why did she wait until (according to her) “January [2017]” to keep FW at the education centre away from me?
  • Why was I still allowed to see her from late December 2016 to March 2017 after signing the Maintenance Agreement?
  • Why did she not write down any restrictions in that agreement, or make sure the access was supervised?
  • Why was I still (according to her) allowed to see FW “until July 2017”, including in May 2017 during my “scheduled meeting” with FW at McDonald’s?


• Let me also remind the Court what the Respondent was recorded as saying in the phone call on 26th March 2017 as shown in Appendix 3 of my first Affirmation. The Respondent was commanding FW to return home, but FW didn’t want to, and asked why she has to. The reason the Respondent gave for this was not, “because your father is sexually abusing you!”, but rather, “because you already violated a promise” (line 33), “you already signed it” (line 49), “so I’ll forgive you” (line 45), and “otherwise I will not even think about paying your tuition” (line 51).
  
  FW then wanted to use the opportunity to “resolve this once and for all”, ie. “why can’t you just let me see him every Sunday?” (line 78). Again, the Respondent’s answer was not, “because your father has been sexually abusing you!”, but rather, “I will not let him see you until I won the law suit against him”, even saying that “and he sign it that he will never renege on your monthly payment without me signing for anything, then go ahead and see him, otherwise NO!”


• Later in that recording, the Respondent then offers to let FW see me, but with her presence, saying “I need to be present because I don’t trust him, of the things he do to you.” When I challenge her, “exactly what am I doing to her?”, her first reply is again NOT about any sexual abuse, but “you tried to suffocate her even in my presence last time, OK? God knows!”. And then comes the key line, “Maybe you’re raping her, maybe you’re doing something sexual to her, who knows?” Why did she say “maybe” as a hypothetical situation? And “who knows”, when she supposedly has known about it already since October 2016? She also says, “FW, honestly, yeah, if he’s doing something sexual, no one would ever know besides you, and then one day you will have suppressed memories and guess what, one day when the memory comes out, God knows…”. Why does she even have to talk about ‘suppressed memories’ coming out if FW had already told her about it before? And notice FW’s reaction: when the Respondent mentions the possibility of my “sexually molesting her” and “sexually abusing her” again, FW then said, “That’s disgusting!” FW obviously knew what it meant, and found it a disgusting suggestion. Would that have been her reaction had I really been sexually abusing her in the past? In any event, my guess is that this on-the-spur thought about the possibility of sexual molestation by the Respondent was perhaps what laid the seeds for her later full-blown allegation in her last affirmation.


• Of course, the Respondent’s allegations of sexual abuse are also wholly inconsistent with her actions vis a vis these Divorce proceedings. In my divorce petition, I had listed as one of the grounds of unreasonable behaviour that “since April 2017, the Respondent has been completely preventing the Petitioner from having contact with their child”, and this statement was denied by the Respondent. At the First Appointment on 11th December 2017, the Respondent’s counsellor said that they wanted this line taken out, because the Respondent had not been denying access, but rather, it was just that FW did not wish to see me. This statement itself is already very inconsistent with what the the Respondent now alleges. If it’s true that I had been sexually molesting FW and the Respondent already knew about it back in 2016 (or even let’s say August 2017), then shouldn’t they be agreeing that the Respondent has indeed been completely preventing me from seeing FW, but simply adding that the reason is because of sexual abuse?


• Furthermore, as has already been noted during the summons hearing on 1st February 2018, why was this very serious allegation not brought up AT ALL at the first hearing? In fact, I remember that the Judge specifically asked the Respondent’s counsel, “Why doesn’t your client grant him access? It’s not as if there are allegations of abuse or anything.” The counsel didn’t say anything, or at least anything about sexual abuse. Why not? Did he not know about such allegations from the Respondent? And if that’s the case, why did the Respondent not have told the counsel about something so fundamental that affects the most important thing in contention in these divorce proceedings – ie. the custody of FW?


• Even after that hearing, I had taken the Judge’s suggestion that I can try communicating with the Respondent via her lawyers if she had been ignoring or blocking my communications, and sent her an email via her lawyers on 18th December 2017 formally asking her to let me see FW, and asking her to tell me the reasons why not if she wouldn’t let me, or why does FW not want to see me if she alleged it was FW who didn’t want to see me. I attach this email, as well as a follow-up chaser email, as “Exhibit R23”. I never got a reply on this from anyone – neither her nor her lawyers. Why not? Why not simply tell me that it’s because the Respondent has been made aware of my sexual abuse towards FW?
  
  D. Complete and Utter Lack of Evidence


• Not only do the Respondent’s actions not match her allegations, she has shown virtually zero evidence of what she is saying, and I know for a fact that she would be completely unable to show any evidence other than what she would be forcing FW to say.


• For example, the supposed May 2017 incident at McDonald’s was said to be during “one of [my] scheduled meetings” with FW. I challenge the Respondent to show the Court ANY shred of evidence that ANY such “scheduled meetings” occurred after March 2017. It doesn’t have to be evidence of that May meeting, but it can any meeting after March. Show the Court. Anything. Any small shred of corroborative evidence. I have already shown in paragraph 104 above using the Respondent’s own Wechat messages that she already didn’t want FW to see me from 13th March 2017 after I had terminated the Maintenance Agreement. She also started blocking me on Wechat on a long term basis latest from 27th March 2017 until now, and it was only unblocked (apparently by FW) a couple of times after that for a couple of hours at most each time when FW needed my help (eg. to send her pictures of her previous holidays for school work etc.), after which the block resumed. I can show this blocking using my Wechat history with the Respondent, but to rule out the possibility of my having deleted certain messages, I challenge the Respondent to contradict what I said using her own Wechat history, and would ask her to show communications between us after March 2017 (Wechat, Skype, email, QQ etc.), whether about resuming access or even about other matters. She would not be able to show anything, of course, because there simply was none.


• The Respondent also says she confronted me about it, supposedly “around early October 2016”. Again, I challenge the Respondent to show the Court ANY shred of evidence of such confrontation, whether or not in October 2016, or at any other time. It doesn’t even have to be a confrontation. Can she show the Court even any MENTION of my alleged sexual abuse in any discussions with me? I am declaring here that the first time I heard of this allegation (as a REAL allegation as opposed to a hypothetical possibility like what she said during the call on 26th March 2017) was the day before the summons hearing on 1st February 2018, when I received a copy of her Affirmation in Opposition. Can the Respondent show otherwise?


• Can the Respondent even show any mention of such allegations to anyone else, such as her mother or her other relatives, apart from that supposed letter by FW to the Hangzhou Court’s judge, which I will talk about further below. It’s not as if she keeps quiet about her issues with me and keeps our problems to herself. In fact, it’s the complete opposite – she has maligned me in public forums and places and to friends and relatives numerous times. For example:
  
  
  • Posting a long rant on FW’s class’ Parent/Teacher QQ group on 17th April 2014 about how I have supposedly abandoned the family and mistreating them;
  • Posting flyers about me with my picture and personal details all around our residential complex (Rainbow Luxury) as well as the neighboring residential complex (Rainbow City) on or about 20th November 2016, saying that I have abandoned the family to go dancing, and advising anyone who saw me to spit on me. (This is referenced by the Respondent in Appendix 1 of my last Affirmation – see line 87: “Anyway you’re famous in Rainbow City. You’re taped all over the place.”)
  • Posting on our residential complex (Rainbox Luxury)’s Resident’s Wechat group on 12th March 2017 after the incident described in Appendix 2 of my last Affirmation (where I had tried to pick up FW but she was dragged back crying into the flat by the Respondent), along with my picture, and saying that I had been harassing FW and taking her against her will, and everyone should know that I did not live there so should report me to the guards if they ever saw me there again.
  • Posting repeatedly (over ten times) on her Facebook page tagging numerous friends and relatives, and creating a private group comprising many friends and relatives, over a few days starting from 28th October 2017, ranting about how I have abandoned the family and cheated her out of money from the sale of the flat and including scans of a letter supposedly written by Grandma about how devious and bad I was, how I had been supposedly violent towards the Respondent’s brother during one occasion, etc. etc., and asking everyone to re-post her posts and try to get a reporter to report about me in the media.
  
  So why is it that, especially in her numerous Facebook postings, did she not mention my supposed sexual abuse in any of the above public defaming? Surely that would make it more likely for a reporter to report on it, which was what she wanted people to help her achieve.
  
  E. Evidence from FW


• The only piece of ‘evidence’ that the Respondent submitted to support her allegations that specifically mentiond sexual abuse was a letter supposedly written by FW to the Hangzhou court judge in July/August during my attempted divorce proceedings in Hangzhou in 2017. Firstly, it is unclear if this letter was ever sent to the Judge, because I had never received a copy, and the first time I saw it was as part of the Respondent’s affirmation. Even if it was sent to the Judge and the Judge never sent it to my Hangzhou lawyer, why was it not sent to me directly too? My Hangzhou lawyer is willing to attest that no such letter was ever received by us.


• Secondly, the letter consists of four pages. The first page is basically about how FW is busy with many important competitions, and asks the Judge to please delay the date of the court hearing as it conflicts with an important contest (which I believe is actually true). Then pages 2 and 3 are basically a long description of how bad I’ve been to her and the Respondent, similar to what the Respondent has been alleging in her last affirmation like how I’ve abandoned them and refused to support them etc., thereby trying to persuade the Judge not to give custody over her to me. Then it’s only in the last page when she starts talking about being molested by others on a film set, then in the last Paragraph she mentions that I have been sexually molesting her. Can the Respondent expect the Court to believe that something so fundamental and serious is left till the end, and added more like an afterthought?


• Thirdly, what FW supposedly said in that letter is not even consistent with the Respondent’s story in her affirmation. In that letter, it says (translation):
  
  
  “When Dad first started touching me on my breast and peeing area, I told myself it was an accident, because I felt that no father would touch his daughter on her breast and peeing area. But it later became more and more frequent, and the occasions became more and more. Once I built up the courage and said to him, “Dad, please don’t touch my breasts and down there.” Dad said, “You don’t like it? Dad touching you there means I love you.” I told him I didn’t like it…”
  
  In this version, FW knew that my touching her in those areas was a wrong thing, and she did not like it, right from the beginning. Yet the Respondent says in Paragraph 43 that “FW told me that she was unaware that such touching was unnatural…” and “this situation lasted for approximately 2 years…” and it was only after sex education classes at school that “she began to disclose bits and pieces of what [I] had done to her”.


• And that’s not the only inconsistency. It’s also inconsistent as to who confronted me, and what happened at McDonald’s that day. According to the letter, after FW told the Respondent about my behaviour, the Respondent merely told her that “even if it’s your father he cannot touch you in these two places!”, and after that it was FW who told me what the Respondent had said, while at McDonald’s, whereupon I supposedly got so angry with FW for telling the Respondent that I left her alone at McDonald’s, after which she called the Respondent who then picked her up. Note that there was no touching at McDonald’s in this version. In the Respondent’s story in Paragraph 44, however, it was the Respondent who confronts me (in October 2016), after which I supposedly said “What are you going to do about it?”. The McDonald’s incident was supposedly in May 2017, and according to the Respondent, I had continued to touch her in a secluded back corner, and FW asked me to stop, causing me to leave FW there alone, after which she called the Respondent who then picked her up.


• In Paragraph 43, the Respondent said that after that McDonald’s incident, I had “sent her several disturbing messages on her school email telling her how much [I love] her and whatever she thought [I] did was only meant as loving gestures.” Where are these supposedly disturbing emails and why haven’t they been reproduced as evidence? The Respondent is implying that I basically implicitly confessed to sexual molestation by saying that whatever FW thought I did (ie. touching her) was “only meant as loving gestures”. I challenge the Respondent to produce such email, because this is exactly the type of corroborative evidence that I have been begging her for in Section D (“Complete and Utter Lack of Evidence”) above. In the meantime, I am attaching as “Exhibit R24” a collection of ALL my email correspondence with FW ever since she started having a school email account in September/October 2017 that I could reach her with. It can be seen that there is nothing in those correspondences, whether by me or by FW, which indicate that I have sexually or physically abused her. In fact, you can see FW complaining about other things, such as my not paying for her, for talking to the school principal, for “being a liar about so many things”, etc. Why is there no mention at all of sexual harassment, or even a HINT about it, in any of the emails? I also challenge the Respondent to show me any significant email to or from FW that I have left out, let alone that ‘loving gestures’ email I allegedly wrote. If she doesn’t produce it, then why not?


• The Respondent attaches an email from FW to me dated 15th January 2018, saying that FW said she doesn’t “feel safe or comfortable with [me] or any backstabbing recording lunatic…”, and this is supposedly evidence of my sexual abuse towards her. It should be noted that FW’s complaints in that email was firstly about my not paying her child support (a topic which I discussed in paragraphs 100 to 108 above), and about my supposedly lying to her about the Loan Agreement (discussed in paragraphs 32 to 33 above). If sexual molestation had really happened, wouldn’t that have been the first thing she would have said in that email? I think I can guess what she is probably referring to when she refers to feeling “safe or comfortable”, and it’s to do with her mention of me being a “backstabbing recording lunatic”. When I had first read it, I misunderstood “recording lunatic” to refer to the song I had written and recorded for her for her 12th birthday, but it dawned upon me later that she was referring to the recordings I had made of our phone calls and conversations. I can fully understand why she would be angry about them, because I can fully imagine that she would have gotten into a lot of trouble from the Respondent since they form a very key part of my evidence and rebuts many things the Respondent has been alleging. So of course she would no longer feel safe or comfortable with me because she is afraid that what she said might get recorded again and used against the Respondent, and she would get into a lot of trouble for again.


• It’s unfortunate for me that I have had to show my correspondence with FW in order to disprove what the Respondent is saying. It is sad because FW will likely feel again that I’ve used her ‘stuff’ as evidence against her mother again, and therefore hate me even more.
  
  F. Contradictory Evidence


• Saying that FW’s not wanting to see me had anything to do with sexual or physical abuse can also be contradicted directly with evidence. Before the Court Order granting me interim supervised access on 1st February 2018, the last time I had seen FW and had any semblance of a conversation with her was on 23rd April 2017. This conversation was recorded and the details are attached as “Exhibit 25”. In this conversation, FW refused to come out with me anymore like our previous regular Sundays. She said she didn’t want to see me anymore, and the reasons she gave were all about financial issues between the Respondent and me, and nothing to do with FW herself, and certainly nothing to do with any alleged sexual or physical abuse. It was also obvious that FW had been fed many lies and distorted reasoning about what had happened in the past between the Respondent and me, and nothing I said could convince her otherwise, and she would rather believe that I was lying about everything I was saying.
  
  G. My Challenge To The Respondent


• In relation to the Respondent’s allegations of sexual abuse against FW, I would like to plead with the Respondent to report me to the Hangzhou police. If what she is saying is true, then I am a menace to society and not just to FW, and I should be locked up for a long time. When talking to the police during their investigations into Grandma’s police report against me regarding the purchase of the car, I also asked them if I could report myself given the Respondent’s allegations and have them investigate the matter, but they said that a suspect cannot report himself, and it must be done by the victim or the guardian of the victim (who was not himself/herself the suspect). Will the Respondent report me to the Hangzhou police? If not, then why not? She and the police will have my full cooperation.


• Lastly, I understand that the Court has no power to compel anyone to take a polygraph (lie detector) test, as mentioned by the Judge at the last hearing. However, these tests can be done by several professional companies, and there is no reason why the Respondent and I cannot do it voluntarily. I undertake that if we do it and it shows that I am lying about not having sexually or physically abused FW, or if it shows that the Respondent is not lying about her allegations, then I will pay for the entire costs of the tests for both of us. Will the Respondent take up my offer to do a polygraph test? If not, why not?



Physical Abuse / Strangling

• Most of the above has been focused on the Respondent’s allegations of my sexual abuse towards FW, but she also accuses me of physical abuse in Paragraph 40. The Respondent mentions seeing marks on FW’s body, but of course, never bothered to take any photos. She says that the first time supposedly took place “around 1 to 7 October 2014”. Will the Respondent please explain why she is so certain of those dates?


• Actually, I first heard her come up with this allegation during the first time I had moved out of the house some time in late 2013, and she said that FW had told her I had strangled her before in Hong Kong. I think it could have started off with a miscommunication by FW recounting an incident when I was punishing her by having her stand against a wall when she was around 6 years old, and when she moved, I forcibly grabbed her by the shoulders and put her back in position. I’m guessing FW might have misdescribed it to the Respondent, but either way, the Respondent then seized it and twisted it beyond recognition, as she so often does. When I managed to have an alone moment with FW one day, I asked her about it and recorded the conversation so as to have the truth on record. A transcript of this recording is attached as “Exhibit R26”. It’s clear that the Respondent started accusing me of “strangling” FW as early as 2013 and not as she described, and since then she has just added to the story, as now it’s become “many times”, and now even a completely made-up event (supposedly the first time I strangled FW) has been described in detail by her. Like with the completely fabricated sexual molestation accusations, I challenge the Respondent to show the Court corroborating evidence of the incident she described, for example like a mention to that specific incident in email or chats, whether to me or to others.



Respondent’s Propensity To Lie and Manipulate Others to Lie

• Over the years of our marriage, I have seen the Respondent frequently exaggerate events, twist facts, add on made-up details, and completely fabricate things out of thin air. It is nothing new for her, so much so that I already half-expect her to do so every time there is a dispute or there’s something important at stake.


• That the Respondent has no hesitation in making up outrageous lies without even a second thought can be seen in a series of videos I had recorded of her on 12th June 2016. She was upset at what I had said when we were discussing FW’s education and was pushing everything off my desk and creating a mess, so I started recording her, both in order to have evidence of the damage she was causing, and also to encourage her to stop her violent behaviour after knowing she was on video. When she noticed I was recording her, she then suddenly started to pretend like I had just hit her. “Why did you hit me?” she says immediately after seeing me with the phone video-recording her. She later also says that she never thrashed my room and I did it myself, even though that part was caught on video. Details and screenshots of these videos are attached as “Exhibit R27”. Grandma also recounted an incident to someone else on Wechat about a time when the Respondent had beaten and pushed Grandma to the floor and Grandma was lying there in agony in tears, only for the Respondent then to say, “Don’t pretend. You hit yourself, and fell all by yourself.” She also mentioned that if she were to die one day, the Respondent would be the murderer but would make it look like a suicide. (see Wechat conversation with Grandma on 20th February 2017 in “Exhibit R28”).


• Let’s not also forget all the obvious statements in her last Affirmation which (I believe) I have shown to be clearly untrue, such as:
  
  
  • I no longer paid for the Respondent and FW after arriving in Hangzhou;
  • We now live separately because I left them (moved out)
  • I signed the Maintenance Agreement and then stopped paying without good reason
  • She never saw the amended "Family and Maintenance Agreement" and had no idea what the content was.
  • The money I paid to Grandma was not for school fees


• I have also seen how she uses lies and deceit in a very convincing way to manipulate others (including myself in the past) to believe certain things. I described two of these incidents in my long email to FW recently, about how even my second brother was turned against me by the Respondent, and how my second brother, his wife and I were turned against our eldest sister-in-law by the Respondent, based on half-truths, distortions and lies (see Exhibit 24, email 6).


• Whenever the Respondent is in a position of authority or power, she would also use that to persuade, manipulate and/or coerce others to lie for her. We have already seen this in how she made FW lie to others about how I supposedly made her sleep on the sofa while I slept with Grandma (see paragraphs 115 to 120 above), and how she has apparently even convinced Grandma somehow to lodge a patently false police report against me (see paragraphs 121 to 125 above). I only just realized while writing this affirmation and going through Grandma’s Wechat conversations (a lot of which I never bothered reading carefully) that Grandma once mentioned that that the Respondent had made FW “sign a self-cursing poison oath” which is why FW is lying with abandon for her (highlighted in the next paragraph below). Is this what all the mentions by the Respondent to FW in the 26th March 2017 phone call recording that she has “signed it and therefore it’s valid” be referring to? (See Appendix 3 of my original affirmation.) I hereby request the Respondent to produce all documents that FW has signed for her, or at least give a detailed description of them, and at the very least describe the thing that the Respondent said was signed by FW in the 26th March 2017 phone recording.


• Of course, apart from me, no one knows the Respondent’s dishonest, manipulative and coercive nature more than the Respondent’s own mother (Grandma). Grandma would often describe to others how the Respondent is “full of lies”, and also how she forces FW to give false evidence. I have excerpted certain Wechat conversations with Grandma showing this in “Exhibit 29”. Here are some quotes:
  



Closing

• I apologize that this Affirmation had to become so long. I had not intended to go into detail on many of the issues mentioned above, but as they were brought up by the Respondent, and often in a completely twisted or fabricated manner, I was compelled to deal with them here rather than during the substantive trial.


• I hope it will be obvious to any bystander looking at the evidence that the real reason for the Respondent’s outrageous allegations against me is simply that she is petrified of letting me see FW, because she is petrified that all her brainwashing of FW will wear off in my presence and we would become close again like the last time (January to March 2017), and petrified that FW’s words and actions would completely contradict the false narrative she had been trying to build up and used against her in Court.


• This is apparent even in the Respondent’s behaviour after the Court Order granted pursuant to the 1st February 2018 hearing, where it was ordered that the Respondent grant me supervised access to FW every Saturday 5-9pm. I had initially agreed to the Respondent’s choice of supervisor, but then I later find out that:
  
  
  • The Respondent mandated that all visits be confined to her home, and the Supervisor would not be allowed to let me take FW out of the home, not even “for dinner”, something which the Judge had mentioned I would be able to do since access was 5-6pm;
  • The Supervisor would be paid fully by the Respondent and would report to the Respondent alone, and would not be allowed to talk to me at all;
  • The Supervisor was an English-speaker, and therefore would be able to understand what was said between FW and me, even though knowledge of English is clearly not necessary to make sure I am not sexually or physically abusing FW;
  • The Supervisor had to be very close to us, even though I had argued that the Supervisor need only have us both within sight
  
  Some of the above were changed after my protests, and I am still awaiting clarification on the biggest remaining issue from the Judge (which is that I’m still being confined to their home), but the actual circumstances of visit were even worse – FW and I were confined to a room, with the Respondent also at home in the dining room. We were forced to have takeaway dinner both times, on the floor (since there were no tables in the room).
  
  To me, this behaviour from the Respondent only goes to further show that her concerns have nothing to do with any sexual or physical abuse by me, but only to do with trying to prevent FW and me from being able to properly see, talk and spend time with each other.


• The stakes are very high for the Respondent, and the saddest thing is that she feels she must win this legal battle at all costs, regardless of what it would do to FW. If it requires the Respondent to make up stories about me to FW and poison her mind against me and have her hate her own father, and even lose him forever, then so be it. (And the same vis a vis her grandmother and other relatives.) If it requires the Respondent to force FW to perpetuate her lies to others and even allege something as disgusting as sexual molestation by her father, then that’s just the cost of winning the battle. And that’s because the Respondent has never put FW’s interests before her own. Before, it was “merely” arguing in front of FW from the time FW was an infant. Then when FW was old enough to understand things more, it progressed to getting FW involved and having her take sides. In the past year and a half, it’s been a combination of segregation, brainwashing, manipulation, threats and coercion in order to completely turn FW against me and anyone else who stood in her way (particularly Grandma and me).


• I just pray that this truth will ultimately become clear to everyone involved in these proceedings.