Dear Registrar,
Subject: Request for Urgent Directions Hearing for Consolidated Applications Regarding Child Safety
I write on behalf of the Father in relation to consolidated applications for temporary and permanent removal submitted to the Hong Kong Family Court on April 16, 2024. The Father is grateful for the accommodation made by the Court to move the originally scheduled hearing from July 5, 2024 to June 17, 2024.
The Father filed and served the consolidated applications on May 14, 2024 to the Mother and her legal team. Furthermore, copies of the original separate applications were provided to the Mother on May 3, 2024. It is important to note that the Mother and her legal team have been fully informed of the urgent situation at hand, as demonstrated by the Ex-Parte applications and Judgments filed by the Father on May 3, 2024.
The Father is concerned that the situation is rapidly escalating and is at serious risk of becoming extremely urgent if not promptly addressed. Despite receiving ample time to prepare their response since April 17, 2024, the Mother and her legal team have not taken appropriate action.
In light of the urgent nature of the situation and the need to protect the children from harm, I kindly request that the direction hearing be rescheduled to May 28, 2024 or any date prior to that if possible. If Her Honour T. Kwan is unavailable, I request that Her Honour C.K. Chan or a Deputy District Judge or Duty Judge be assigned to handle the expedited hearing.
Thank you for your attention to this matter.
Yours sincerely,
[Name]
Barrister
please edit the below letter as a barrister would requesting an earlier direction hearing date from a Hong Kong family court judge
Dear HK Family Court,
Subject: URGENT directions hearings for consolidated applications for 1. Temporary /2. Permanent removal to be moved up from June 17, 2024 to May 28, 2024 or earlier regarding the saftey and protection of children now in serious and accelerating risk of harm.
The Father is greatful for your accommodation to move the submitted to the HK Family Court on April 16, 2024 from July 5, 2024 delayed due to various matters.
The Father has filed and served these consolidated applications on May 14, 2025 to the Mother and her HKLA team.
Furthermore, The Father promptly provided copies and prior correspondences of the TWO separate applications (before consolidation) to the Mother on May 3, 2024 who has full knowledge of the contents of these applications.
The Mother and her HKLA team have been made fully aware of the URGENT situation, and the Ex-Parte appliction and Judgments by the Father on May 3, 2024. These were considered URGENT to the Father but not Extremely Urgent.
The Father does not want this situation if ignored to qualify as EXTREMELY Urgent.
This situation will shortly digress to being EXTREMELY Urgent if nothing is rapidly done.
More notably the Mother and her HKLA team were provided with TWO - WP Prejudice Offers on April XX, 2024 which mirror the same original separate applications originally filed which have now been consolidated. All children matters are open not WP given the Father is desperately trying to protect children from imminent harm with direct dialogue with the Mother, but the Mother is ignoring the severity of the situation.
The Mother and her HKLA team have had a considerable amount of time since April 17, 2024 and May 03, 2024 (serving of copies of two separate applications), May 14, 2024 serving of the consolidated application.
The Mother and her HKLA team will have ample time to prepare their REPLY Affirmation and present their argument against these consolidated applications if they oppose one or the other or both.
The Father is forced to seek the HK Family Court’s intervention to protect both children from further and worsening avoidable harm by expediting these applications.
Given the URGENT nature of the situation involving the protection of children.
Please reschedule the direction hearing for our current date of May 28, 2024 or any date prior to May 28, 2024 if at all possible.
I understand H.H. T. Kwan is busy and her schedule may not allow for this so I please request that if this is the case his H.H. CK Chan or a Deputy District Judge or Duty Judge is requested to handle the expedited Directions Hearing in place of H. H. T. Kwan if she is not available.
Thank you for you kind consideration
1 answer