please edit the below affirmation to add new evidence into a trial where the judgement is not made as if a Barrister would with paragraph numbering:

Question

Adducing New Evidence into the Custody, Care, Control Hearings, and the HK Family Court record for all applications Varying Care and Control of Philip, Variation of Schooling Order, Consolidated Temporary and Permanent removal applications regarding children’s protection, well being, and best interests matters which is the HK Family Court’s overriding Paramount Concern as well as any responsible parents.

The Father has been forced to submit these applications to adduce TRUTHFUL evidence to the to the HK Family Court on children matters prior to any Judgements which may otherwise be reliant on FALSE sworn affirmations and testimony on material matters of fact, which I verily believe may qualify for PURJURY. Additional harm to the children will be caused if an incorrect Judgement is made if the TRUTHFUL evidence is restricted, and potentially relying on the prior documented exposed false and potential PURJUROUS testimony of the Mother.

The Father has been THREATED with COSTS for reporting obvious child abuse, child assault, exposing systemic and voluminous false ‘sworn’ testimony, and INVALID Psychology and Social Welfare reports that need to be updated as their opinions were based on exposed dishonesty. I should not be fearful to report the TRUTH to the HK Family Court and the Mother and her HKLA team appear confident that covering up and being exposed to cover up Child Abuses and Child Assaults and then submit cut evidence along ‘Sworn Testimony’ saying ‘nothing happened’ to willfully mislead the HK Family Court (this is a fact that has been brought to light and any costs orders should be to the Mother for these exposed actions);

The Father request the following evidence be included into the HK Family Court’s record and to be reviewed along side the already filed evidence to provide a TRUTHFUL account of the Mother’s conduct of harming her own children. The Father will request the TV Video Monitor to display the IRREFUTABLE evidence before the HK FAmily Court.

Exhbit XX – Unsworn and potentially ‘still cut’ SGD VX documenting the Mother initiated the Assault by physically grabbing her son’s phone, hysterical son crying for his Phone back, and flailing elbows of the Mother with a CRY “YOU ELBOWED ME’

Exhbit XX – REPLY Letter of the Father including additional evidenc of the child abuse and child assult

Philip’s whats ap document the Mother’s and Philip’s known deception and Cover up of the Child Abuse and Chile Assault “The video where you hit”...

Photo and time stamp of the clearly shown BRUISE on Leonidas face. YOU ELBOWED ME IN THE FACE – cries in the bathroom already in evidence and proof of the bruise on Leonidas face.



Exhibit XX - Add Philip’s recent FAILING Report Card and evidence that Local Schools are not suitable for Philip and will cause him Permanent EDUCATIONAL harm as Philip’s teachers have stated and they stated that Philip should be in a Private International School. The Mother has caused willful HARM to Philip and plans to enroll Philip in a local school next year that the mother did not report to the Father like Philip’s continued failing grades and worsening educational condition. For the avoidance of any doubts, the ‘local school’ Catholic Mission recommends Private International Schools as the FIRST choice for both Local and NCS (NON-CHINESE-SPEAKERS) alike above ‘local schools’.

Exhibit XX – Leonidas HIGH Ranking and IMPROVING Global Scores and Updated report cards documenting his Educational Success along with Leonidas Admission into a TOP Private International School on Scholarship.

Add the HK Police Video testimony of Leonidas which matches exactly with the new evidence and what Leonidas said the Psycholgist Ms Lam, and exposed that the Mother provided false testimony under OATH to Ms Lam creating an INVALID report that cannot be relied upon.

Provide leave so that the Psychology Report of Ms Lam be given to the HK Police conducting a criminal investigation as the Mother’s HKLA council, wrote a letter under submission to Deputy Judge Sasha Alison who verbally did not give leave. This matter should have been presented to H. H. T. Kwan for decisions. The Mother’s testimony to the HK Police may also be false and not match what she said to the HK Police.

The Father did not take the matter to the HK Police on February 26, 2024 then believe the HK Family Court would act to protect the children’s safety, well being and best interests, which I still believe will be the case today.

None of these exposed facts should provide any confidence to the HK Famiy Cour that the MOther

The Father’s objective is the protection, best interests, and well being of both children which is the Parmount Concern of the HK Family Court, who requires TRUTHFUL and not FALSE testimony to make the correct Judgements and findings of facts to safeguard children’s well being.

As these are children’s matters and a Judgment has not been made the HK Family Court Honorable Judge T. Kwan has the authority to adduce evidence prior to her Judgement.

The Mother herself has provided ‘unsworn’ evidence in essence ADMITTING her false testimony regarding Child Abuse and Child Assaults under oath and dishonest statements to the Officers of the Court to cause INVALID Psychology and Social Welfare reports.

There is no law allowing the perpetrator of child abuse and child assault to blame the child victim for ‘deserving to be assaulted and abused’ which the Mother believes she has leave to assault any child or adult for any reason and at any time by her own documented statements.

The Mother’s violence is frequent and the Mother’s dishonesty under oath is systemic as this is not an isolated incident but a repeated pattern of conduct for the Mother in these proceedings.

The Father’s proposed solutions to the children safety, protection and well being matters remains the ratification of the ‘Status Quo’ which is the 50/50 Custody, Care, and Control of both children for the last now some SIX Months by way of Mutual Consent Agreed Joint 50/50 custody, care and control as stipulated for both children namely Leonidas Age 14 on August 5, 2024, and Philip Age 12 on October 31, 2024.

None of the Father’s recommended solutions are punitive to the Mother and only call for ratification of 50/50 time for both parents for both children as the solution to these matters.

The Mother does not want to spend 50/50 time with her other son Leonidas (and the Father is OK to have more than 50/50 time with either or both children to support the Mother);

The Mother refuses to co-parent and work toward a normal amiable children’s well being first resolution outside the HK Family Court.

The Father has reached out again to the Mother to STAY all proceedings and come to a Mutual Consent Children’s Well Being first resolution based on the established Status Quo. The Mother up until this affirmation has refused after numerous approaches and is forced to move forward with these hearings to provide TRUTHFUL evidence to the HK Family Court prior to any Judgement.

Given the Mother’s refusal to co-parent, The Father is forced to apply for SOLE CUSTODY of both children to make the important decisions such as schooling, and steward both children's baptized Christian Faith, and the Father can be relied on to provide 50/50 Access to the Mother for both children.

Due process requires that the Mother must provide a ‘Sworn Affirmation’ and the Mother and her HKLA team had ample time to prepare the same instead of ‘Submissions’.

These are very serious matters as the HK Family Court and the Father are not in possession of any evidence, and the Father is entitled to REPLY to the ‘evidence’. For the avoidance of any doubts, The Father reports that what the Mother’s HKLA council stated ‘verbally from the barstool as instructed or not by his client’ at the last hearing (not under oath) was materially false, and if SWORN would be tantamount to additional willful PURJURY to mislead the HK Family Court. I demand that they Mother SWEAR to those statements made a the last hearing as the statements continue to be materially and willfully false. These again are very serious matters and submissions such as those cannot be relied on and only server to protect from additional potential perjury as they are ‘unsworn’);

The Mother stated she always had a FULL COPY but submitted only a CUT COPY (OVERTLY removing her child abuse and child assaults to mislead the HK Family Court and provide false testimony); The Mother or her HKLA team have admitted to the potential perjury themselves and its not clear WHO cut this child abuse and child assault but the ACT OF CUTTING THIS AND SUBMTTING TO THE HK FAMILY COURT IS THE ADMISSION OF GUILY OF ITSELF: (this is not an isolated incident but systemic)

As these are very serious children protection and well being matters which are not isolated nor is the Mother’s conduct

Answer 1

1. The Father has been forced to submit these applications to adduce TRUTHFUL evidence to the HK Family Court on children matters prior to any Judgements which may otherwise be reliant on FALSE sworn affirmations and testimony on material matters of fact, which I verily believe may qualify for PERJURY. Additional harm to the children will be caused if an incorrect Judgement is made if the TRUTHFUL evidence is restricted, and potentially relying on the prior documented exposed false and potentially PERJURIOUS testimony of the Mother.

2. The Father has been THREATENED with COSTS for reporting obvious child abuse, child assault, exposing systemic and voluminous false ‘sworn’ testimony, and INVALID Psychology and Social Welfare reports that need to be updated as their opinions were based on exposed dishonesty. I should not be fearful to report the TRUTH to the HK Family Court and the Mother and her HKLA team appear confident that covering up and being exposed to cover up Child Abuses and Child Assaults and then submit cut evidence along ‘Sworn Testimony’ saying ‘nothing happened’ to willfully mislead the HK Family Court (this is a fact that has been brought to light and any costs orders should be to the Mother for these exposed actions).

3. The Father requests the following evidence be included into the HK Family Court’s record and to be reviewed alongside the already filed evidence to provide a TRUTHFUL account of the Mother’s conduct of harming her own children. The Father will request the TV Video Monitor to display the IRREFUTABLE evidence before the HK Family Court.

4. Exhibit XX – Unsworn and potentially ‘still cut’ SGD VX documenting the Mother initiated the Assault by physically grabbing her son’s phone, hysterical son crying for his Phone back, and flailing elbows of the Mother with a CRY “YOU ELBOWED ME’.

5. Exhibit XX – REPLY Letter of the Father including additional evidence of the child abuse and child assault.

6. Philip’s WhatsApp document the Mother’s and Philip’s known deception and Cover up of the Child Abuse and Child Assault “The video where you hit”.

7. Photo and time stamp of the clearly shown BRUISE on Leonidas face. YOU ELBOWED ME IN THE FACE – cries in the bathroom already in evidence and proof of the bruise on Leonidas face.

8. Exhibit XX - Add Philip’s recent FAILING Report Card and evidence that Local Schools are not suitable for Philip and will cause him Permanent EDUCATIONAL harm as Philip’s teachers have stated and they stated that Philip should be in a Private International School.

9. Exhibit XX – Leonidas HIGH Ranking and IMPROVING Global Scores and Updated report cards documenting his Educational Success along with Leonidas Admission into a TOP Private International School on Scholarship.

10. Add the HK Police Video testimony of Leonidas which matches exactly with the new evidence and what Leonidas said to the Psychologist Ms Lam, and exposed that the Mother provided false testimony under OATH to Ms Lam creating an INVALID report that cannot be relied upon.

11. Provide leave so that the Psychology Report of Ms Lam be given to the HK Police conducting a criminal investigation as the Mother’s HKLA council, wrote a letter under submission to Deputy Judge Sasha Alison who verbally did not give leave.

12. The Father did not take the matter to the HK Police on February 26, 2024 then believe the HK Family Court would act to protect the children’s safety, well-being, and best interests, which I still believe will be the case today.

13. None of these exposed facts should provide any confidence to the HK Family Court that the Mother deserves...

14. The Father’s objective is the protection, best interests, and well-being of both children, which is the Paramount Concern of the HK Family Court, who requires TRUTHFUL and not FALSE testimony to make the correct Judgements and findings of facts to safeguard children’s well-being.

15. As these are children’s matters and a Judgment has not been made the HK Family Court Honorable Judge T. Kwan has the authority to adduce evidence before her Judgement.

16. The Mother herself has provided ‘unsworn’ evidence in essence ADMITTING her false testimony regarding Child Abuse and Child Assaults under oath and dishonest statements to the Officers of the Court.

17. There is no law allowing the perpetrator of child abuse and child assault to blame the child victim for ‘deserving to be assaulted and abused’, which the Mother believes she has the leave to assault any child or adult for any reason and at any time by her own documented statements.

18. The Mother’s violence is frequent and the Mother’s dishonesty under oath is systemic as this is not an isolated incident but a repeated pattern of conduct for the Mother in these proceedings.

19. The Father’s proposed solutions to the children's safety, protection, and well-being matters remain the ratification of the ‘Status Quo’ which is the 5...

20. None of the Father’s recommended solutions are punitive to the Mother and only call for ratification of 50/50 time for both parents for both children as the solution to these matters.

21. The Mother does not want to spend 50/50 time with her other son Leonidas (and the Father is OK to have more than 50/50 time with either or both children to support the Mother).

22. The Mother refuses to co-parent and work toward a normal amiable children’s well being resolution outside the HK Family Court.

23. The Father has reached out again to the Mother to STAY all proceedings and come to a Mutual Consent Children’s Well Being first resolution based on the established Status Quo. The Mother up until this affirmation has refused after numerous approaches...

24. Given the Mother’s refusal to co-parent, The Father is forced to apply for SOLE CUSTODY of both children to make the important decisions such as schooling, and steward both children's baptized Christian Faith, and provide 50/50 Access to the Mother for both children.

25. Due process requires that the Mother must provide a ‘Sworn Affirmation’ and the Mother and her HKLA team had ample time to prepare the same instead of ‘Submissions’.

26. These are very serious matters as the HK Family Court and the Father are not in possession of any evidence, and the Father is entitled to REPLY to the ‘evidence'.

27. The Mother stated she always had a FULL COPY but submitted only a CUT COPY (OVERTLY removing her child abuse and child assaults to mislead the HK Family Court and provide false testimony). The Mother or her HKLA team have admitted to the potential perjury themselves and it's not clear WHO cut this child abuse and child assault...