I will attach the following documents to this update:
- Introduction
- Zakaria Zayed - 14A - Affidavit (Responding) - Respondent - Zayed - June 2, 2025
- Lubna Aldahleh - REPLY - Form 14A - REPLY Affidavit-Motion of Strike, Restrain, Recognizing_ APPLICANT - ALDAHLEH - 27-JUNE-2025
- Lubna Aldahleh - Form 14 - Notice of Motion _ APPLICANT - ALDAHLEH - 20 FEB 2025
- 5. Lubna Aldahleh - Form 14A - Affidavit _ APPLICANT - ALDAHLEH - 20 FEB 2025 - (TO BE CONTINUED) Douments will be attached in the next post due to the text-length limit.
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- Introduction:
It seems that my ex-husband and the Canadian officials helping him are completely twisting the real nature of our case (a family custody dispute over Muslim children, which has ended since 2021 at the appealing courts in Kuwait, with a final ruling giving the mother sole custody and protecting her and the children by preventing the father from making any decisions about them). In this update I’ll first share my ex-husband’s responding to my cross-motion— which I posted his two motions in the last update.
Here are my concerns to our honourable Canadian Government regarding the statements and evidence filed by the respondent father against the mother:
- What connection is there between the Freemasons and the ongoing conflict between Palestinian resistance fighters and Zionist occupiers in this “FAMILY CASE”?
- What does the mother’s religion—and her following the Prophet’s (peace be upon him) example and that of the righteous female companions—have to do with a family law case in Canada?
- Does what the father said in his response actually relate to the real issues in our custody case?
- Does Canada have the right to decide these matters in a family dispute between a mother and her Palestinian children (who are Canadian citizens living in Canada), when the father is not Canadian and lives in Kuwait and hiding his religion and original (Which is now coming clear as the sun in this case)?
- On what basis does the father has all these authority in Canada since 2022?
- What is his background and true religion—which he clearly seems ashamed of—so much so that he and his allies won’t admit it, and instead use their system’s plan (“Kill, Steal, Lie, Betray, and Cry”) in a family case to try to take the children away from their family for their own purposes?
If he really were a Muslim of Palestinian origin living in Kuwait with no money actually drowning in debt, as he claimed when he submitted his financial records—then how could he use some hidden power to forge documents in three countries (Jordan, Kuwait, and Canada) without anyone catching him? How could he fake his children’s passports in Jordan in such a strange way? How could he do forgeries in Kuwait, when even Kuwaiti citizens themselves don’t have that kind of authority? How could he afford to hire three women lawyers in Canada? And how did this case end up in the hands of Freemasons and people who hate Muslims—carefully arranged so that a fair judge in Canada, who follows the law without any bias, wouldn’t simply rule in the mother’s favor?
I feel deep sorrow for the father who cannot admit who he really is. He thought he was brave when he confessed his true nature to me, threatening that he would turn my children (grandchildren of the resistance Palestinians, REAL MEN) into soldiers for the Zionists. He went so far as to threatened that I give up my children by signing a paper, believing all the power was in his hands, saying “that it will happen”!. This is a vile conspiracy by the Freemasons, who have hidden themselves among Arabs, learned our language and memorize the Quran and Sunnah, claim they are poor people without any authority, and married Muslim women—especially Palestinian daughters and granddaughters of the fedayeen—THINKING THEY COULD WEAKEN US, BUT DEFINITLY IT IS THEIR FANTASY DREAM THAT WILL NEVER HAPPEN. No, by ALLAH ALMIGHTY, He will never let us be lost. Their scheme is only a reverse plot that, with ALLAH’s help, will turn against them. ALLAH is the best planner, the best witness, and the best disposer of affairs.
I will not lose my faith or God’s pleasure by accusing anyone of disbelief—that is forbidden in Islam—unless the person admits it himself, out of pure foolishness, thinking that a lone woman with no help would fear him and obey his demands. The father completely missed that all his cruelty over the years only is strength of her faith and her trust in a Lord who wrongs no one. In fact, ALLAH put this mother and her children through this trial for a good reason and wisdom that only He knows.
While the corrupt people (in the Canadian courts of justice) think they broke Canada’s laws and their own ethics—believing no one will expose them and that they can pick cases to serve their vile goals—they failed to realize that ALLAH deliberately chose them for this trial and fixed the plan in advance so it cannot fail. My case is a strong one, based on clear evidence from Kuwait that justified giving immediate protection to the Canadian mother and children from the very first hearing. Yet it has become a case that shows racism against Sunni Muslims in general, and manipulation and trickery by the Freemasons who control Canada with their corruption and lawbreaking, all to take children and turn them into mercenary soldiers for their Zionist entity. This is not only a threat to Muslim children, but to every child in Canada—regardless of their religion, best interests, age, or how much their parents care for them—as long as their case is in the hands of those who do not respect Canada’s clear laws and who tamper with files according to their preplanned schemes.
If I had revealed the father’s real background earlier, some might have dismissed it as guesswork. But the truth is that he admitted to the mother—by the end of 2020, after all the appeal courts had ruled in her favor—that he was not a Muslim from the start. He threatened her, claiming he had the power of the world, that he was a Zionist Freemason, and that he would take the children by any means. He figured that if he forced her to sign a paper giving up her kids, she could walk away without the Masonic powers turning on her—especially since she was alone in Kuwait with no family or man to defend her.
He was completely wrong to think that a Muslim woman’s strength comes from the men who protect her. No—our strength comes only from hearts that put their trust in ALLAH. We will never submit to anyone but Him. Our hearts will never allow anyone to force us to abandon the path of the Beloved Prophet Muhammad (peace be upon him). By ALLAH’s help, we will all be saved through the power of our faith, so that we may meet our beloved Prophet on the Day of Judgment and make him proud of us, because we never gave up or betrayed his trust in us, NEVER AT ALL.
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2. Zakaria Zayed - Respondent Father’s Form 14A: Affidavit (Responding) / Filed at the Superior Court of Justice, dated June 2, 2025
My name is (Full legal name) Zakaria A. M. Zayed
I live in (Municipality and province) Jabriya, Kuwait
PART 1: INTRODUCTION
1. I am the Respondent in this case and the father of the three children involved. This affidavit is my response to the Applicant’s amended Form 14A affidavit, dated May 12, 2025. Her affidavit was submitted in support of her Form 14 Notice of Motion dated February 20, 2025.
PART 2: BACKGROUND:
2. Before addressing the Applicant’s claims in detail, I wish to note that I have received numerous abusive and threatening messages from her over time. Despite this, I have consistently chosen not to respond in kind or be drawn into personal or irrelevant conflicts.( Exhibit 3 and below links)
3. In her Exhibit Tab A2, dated May 12, 2025, the Applicant confirms that as early as September 15, 2022, I asked to enroll our children in a bilingual school and extracurricular activities, and that I offered to pay all related costs. She ignored this request. Since that time, the Applicant has changed the children’s schools five times over the past three years, including a period of online learning. At one point, our youngest daughter, Mariam, was not enrolled in any school at all. In 2024, she finally agreed to enroll the children at Al-Taqwa Academy. I have paid all tuition and transportation fees, totaling CAD 22,860. However, the Applicant has not shared any plans regarding the children’s schooling for the upcoming academic year. Exhibit 5
4. I disagree with the claims and explanations made by the Applicant in her affidavit. In this response, I have organized my replies to directly address the documents she submitted—particularly those marked as Tab A and Tab B—to help the court understand the facts clearly and accurately.
5. The children’s and parents’ habitual residence is Kuwait. We are all Jordanian citizens, and none of us has close family in Canada. My youngest daughter holds only Jordanian citizenship. Baraa and Lujain became Canadian citizens only because they were born during a short 60-day visit to Canada. The Applicant recently acquired Canadian citizenship. I have lived in Kuwait since 1979, and the children lived there from birth until the Applicant relocated them to Canada in 2021—without my consent and without a final court order permitting their permanent move.
6. The Applicant was convicted in Kuwait for violating the children’s rights by unjustly cutting off their relationship with me. On February 13, 2022, the Kuwaiti court ordered her to maintain good conduct for one year. She appealed the decision, but on February 14, 2023, the Court of Appeal upheld the ruling and imposed a fine against her.
7. On March 31, 2023, the Amman Court in Jordan (Order No. 15421/2022) convicted the Applicant for acting against the best interests of the children.
8. The Applicant has been convicted in two separate criminal cases—one in Kuwait and one in Jordan—both directly related to her treatment of the children. These convictions are not, as she claims, about “abduction,” but concern serious violations of the children’s well-being.
9. Court Order No. 1528/2021, files on August 12, 2021—and upheld on two levels of appeal with the Applicant’s full participation—explicitly ordered the Applicant not to harass me in matters related to custody or the children’s transfer.
10. The Applicant is currently under investigation for forgery in Kuwait. She misled the Kuwaiti court to obtain a temporary travel permit to Jordan, but instead used it to permanently move the children to Canada. This occurred despite active parenting time orders and ongoing court proceedings.
11. In Canada, the Applicant opened a protection file with the Children’s Aid Society (CAS), but the file was closed early. The case didn’t move forward because there was no evidence of risk. I have always opposed CAS’s involvement in this matter. Despite the Applicant’s claims, CAS never contacted me for an investigation. I also objected to CAS participating in court. Although the judge directed that a CAS worker submit an affidavit, none was filed, and no CAS representative came to testify.
12. In the Jordanian custody case, the Applicant was properly and repeatedly notified through official channels. I personally sent her the court application by email, and the Jordanian Embassy in Canada delivered the legal documents to the address she gave. The Embassy also contacted her by phone. She also can access to court notifications through her mobile app. Despite clearly knowing about the case, the Applicant chose not to take part. Instead, she accessed and copied the court file without formal service, which raises serious concerns about her respect for legal procedures and the privacy of court records.
13. In the Jordanian criminal case, the Applicant also accessed the court file without being properly served. She was notified by the Jordanian Embassy in Canada and can access to updates through her mobile app. Still, she chose not to participate or appeal. To this day, she has taken no steps to challenge or respond to her criminal conviction.
14. Both the Kuwaiti and Jordanian courts removed custody from the Applicant and granted it to me. This was not because of any "abduction," as the Applicant wrongly claims, but because she permanently relocated the children without my consent or a final court order, refused to follow parenting time orders, blocked me from supporting the children, and cut them off from their extended family. These decisions were not based on my claims alone—both courts held full hearings where the Applicant had the opportunity to participate. On Kuwait appeal, the courts found her unfit and untrustworthy to have custody. These rulings are final, enforceable, and based on the best interests and well-being of the children.
PART 3: FACTS RELATED TO RESPONDENT’S SCHEDULE A EXHIBITS:
15. The Applicant submitted an email from the school principal that includes messages from Baraa and Lujain, claiming they do not want to meet with the Office of the Children's Lawyer (OCL). Based on the language and tone, I do not believe these messages were written independently by the children. They appear to have been written or influenced by an adult—most likely the Applicant.
16. I have submitted the full email thread in Exhibit 2, dated May 12, 2025. The Applicant shared only selected parts, leaving out important context. The full email includes phrases like: “Due to unforeseen circumstances”, “oppression and distress he has caused me”, “I don’t want to talk to any of my lawyers”, “I’m free to say what I want and what I feel comfortable in saying”
17. These expressions do not reflect the natural voice of children aged 12 and 14.
18. The language is formal and emotionally layered—far beyond what would be expected from children in an unsolicited email. And the emails were sent from a newly created and unfamiliar address: baraa487654@gmail.com, which raises further concerns about their authenticity.
19. Both emails were sent on the same day, used similar language, and expressed nearly identical points. It is highly unlikely that two children would independently write such coordinated and structured messages. The content and tone of these emails mirror the Applicant’s own language in court filings—particularly her complaints about me and the legal process—which suggests that the emails may have been scripted.
20. In the past, the Applicant used Baraa’s mobile phone in Kuwait to receive court-related messages, as shown in Exhibit 4.
21. The Applicant also involved Baraa in her public petition by attributing to him a quote that does not appear to be in his own words. She published personal photos of the children and court pleadings online, as shown in Exhibit 3 and below links, raising concerns about privacy, manipulation, and exposing the children to adult legal conflict.
22. If the court wishes to understand their actual feelings, I request that a neutral psychological assessment be arranged. It should occur in a private, safe setting without either parent present— to allow the children to speak freely and without influence.
23. The Applicant has blocked my access to the children's school, health, and psychological information. She contacted multiple schools—Victoria Public School, Eagle Heights Public School, Sir John A. Macdonald Public School, and Al-Taqwa Academy—and made misleading or hostile claims about me, which led to the restriction of my access. This is despite active court orders confirming my legal right to receive such information. I have included evidence of these school changes and Mariam’s non-attendance in my previous submitted exhibit list dated May 12, 2025
24. The Applicant continues to misinterpret the February 16, 2024 temporary order by Justice Tobin, which dealt only with jurisdiction. She wrongly claims it removed my access to children’s information. This misunderstanding has been explained to her multiple times, but she continues to use it to exclude me from the children’s lives.
25. Aschedule A – TAB 02: The Applicant submitted a private email I sent to the London Mosque on September 15, 2022. It was clearly marked “CONFIDENTIAL” and meant only for the Imam. I sent it to seek guidance about our children. At the time, I didn’t know the Applicant worked at the mosque. She somehow accessed this message and used it in court without my consent or the full context.
26. In that email, I respectfully asked the Imam to encourage the Applicant to enroll our children in a bilingual Islamic school, allow them to join religious activities, and help restore contact between me and the children. I also offered to cover all costs. These were sincere and respectful requests based on concern for the children’s well being.
27. Instead of responding constructively, the Applicant took parts of that email out of context and used it in her affidavit to misrepresent my intentions. She ignored my concerns, and I believe mosque staff mishandled the matter. That made things worse and harmed chances for cooperation in the children’s best interest.
28. The mosque replied confirming the email was understood to be private. Their message stated: “Thank you for sharing with us this private information (Will remain confidential).” This confirms my message was sent in good faith and not intended for public or legal use. The Applicant’s use of it in court is a serious breach of privacy and trust.
29. SCHEDULE A – TAB 03: I found this part of the Applicant’s affidavit confusing and misleading. She was the one who took our three children and relocated them to Canada permanently without my consent or a final court order. For a long time, I had no contact with them and was trying to confirm whether they were even in Canada. During that time, I contacted several agencies just to find out where my children were and whether they were safe. The Applicant is now misrepresenting these efforts.
30. The statements she highlighted in yellow are not opinions or threats, as she suggests. They are based on official final court orders and documents from both Kuwait and Jordan, not on emotions. These are facts supported by evidence decisions that were made by the courts after full hearings. I was simply trying to protect my children and follow the law.
31. SCHEDULE A – TAB 04: The first page of the Applicant’s submission appears to be from a different platform and not WhatsApp, despite how it was presented. She attached only part of a WhatsApp conversation from September 2021, including my question about the children and her hostile reply. She deliberately omitted the rest of the exchange, including my clear statement that I had no knowledge of the social media post she mentioned, and that I would never approve of anyone saying anything against the mother of my children. As shown in Exhibit 1 – WhatsApp Communications Between Parents, I responded respectfully and asked several times to speak with the children and confirm their school attendance. She ignored those requests and blocked communication.
32. The Applicant’s submission is incomplete and misleading. It removes her accusatory language and hides my calm responses. She used this message out of context, not to clarify facts, but to influence others against me. This conduct is not only unfair—it also shows how she manipulates communications to support her claims while ignoring the children’s best interests.
She sent:
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“Looks like you don’t understand Arabic. Seems like Hebrew is still stuck to you” (She is implying that I am not a Muslim, but rather Jewish). “I do not yield to threats.” “I’m the daughter of freedom fighters, martyrs, and righteous people… When someone challenges her, she never backs down, nor does she accept humiliation.” All the evil they plotted for you—from beginning to end—has turned back on your heads. But they’re still playing you, and you’re blindly following misguidance. So, you want to challenge me?
33. I responded:
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“Where are the kids?”, “This statement is not from me, and I know nothing about it. I do not approve of it being said about the mother of my children.”, “Threats and destruction have always been your approach, Lubna — not mine.”, “Did the kids go to school?”, “Lubna, I want to speak with the kids.”
34. She ignored all of these messages and submitted only her own aggressive reply, as if I had provoked her or said something wrong—which I had not. In addition, she did not include the original Arabic version of the conversation, even though the entire exchange was written in Arabic. Leaving out both the full text and the original language is highly misleading. She often attempted to provoke me with challenges and threats, seemingly to serve her own hidden agenda. However, I consistently chose not to engage, and her efforts to provoke a reaction from me were largely unsuccessful
35. Her words show hostility and emotional manipulation, while my messages show a consistent effort to maintain respectful communication and reconnect with our children. This is part of a larger pattern: the Applicant selectively shares parts of conversations, removes context, and uses her own replies to shift blame. My focus has always been on the children’s safety, well-being, and my right to be a part of their lives.
36. SCHEDULE A – TAB 05 and 06 (CAS Investigation Report): I strongly objected to the use of the CAS report as evidence in these proceedings. I also want to clarify that the CAS worker, Caroline Graham, did not call me as she claimed. I was the one who initiated the only ONE phone call. During that call, Ms. Graham ended the conversation quickly, saying she had to attend a meeting and would call me back with an interpreter. Despite having both my contact information and my former lawyer’s, she never followed up or tried to reach me again.
37. The court had also asked CAS to submit an affidavit and for Ms. Graham to attend as a witness. She did not comply with either request. This failure to follow up, communicate, or respond to the court’s direction seriously undermines the reliability of the CAS report.
38. Based on these facts, I respectfully ask the court to disregard the CAS report and any materials submitted by CAS. The report was not verified, lacks procedural fairness, and does not reflect an accurate or impartial investigation.
39. SCHEDULE A – TAB 07: This exhibit includes more WhatsApp messages between the Applicant and me. I continued to communicate respectfully and tried to cooperate. I used the example of Musaylimah—a historical figure who falsely claimed prophethood—as a metaphor to warn against deception, especially when children are involved. It was not a personal insult.
40. I never said the Applicant is "not Muslim," as she claims. On the contrary, she has accused me of being "not Muslim" and made worse comments against my faith, both publicly and in private. She also continues to tell the kids that great prophets and their fathers were not Muslim. MY EXHIBIT 3 (confirms)
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Lubna AIDahleh
16 Jan·
Patience is beautiful but beware the wrath of the forbearing. Indeed, the time when the cries of truth will shatter is near. Allah will unveil the cover of concealment from the hypocrites with Jewish-Masonic roots, who, having realized their weaknesses and losses, could only resort to barking like dogs. They realized that the deceit, lies, and schemes they concocted have been turned away by Allah, and soon they will face the consequences. The oppressors, liars, hypocrites, thieves, and traitors will face a severe punishment.
Yet, we suffice with small whispers to our loved ones before the truths are revealed. So, be patient, for Allah is true, and Allah does not waste the reward of those who do good. I have entrusted my affairs, my darkness, and my files to the planner of the affairs of the heavens and the earth and all that is between them. Allah is sufficient as a guardian, and Allah is sufficient as a helper.
So, be patient, my dear ones, as the prophets and the righteous were patient. Be patient like the steadfast Khansaa, like our mother Aisha, the truthful. Be patient like Joseph, peace be upon him. Be patient like those with firm resolve (with strength, not with betrayal). Take them as exam les, the com anion of truth never weakens or retreats. Ever."
Lubna AIDahleh
April 7 at 12:22 PM
Rest in peace. I swear that I will take revenge, and I will not deviate after being deprived from seeing you and bidding you farewell. I apologize for you, oh you have drawn the right path, steadfastness, and patience throughout your life with limitless giving, my Catastrophe when I heard about your suffering that you experienced during your last days in this transient life has preoccupied me from announcing the initial good news to soothe your soul that victory is our ally and near with the help of Allah. I'm sorry, my father.
Yes, I have been deprived of meeting you and bidding you farewell, smelling your scent, and kissing your hands and forehead. But what calms my soul is the confidence that you are in a better place than this world.
I only have to struggle in this life to prove the truth and end the injustice imposed on us by those who have tainted our lives. However, I will whisper phrases that may dwell in our souls.
Did the hypocrites not infiltrate themselves into the front lines of the Muslims? Why didn't they spread among the disbelievers? Their goal is the righteous ones!!!
Didn't they attack the honor and integrity of those who were promised paradise? Why didn't they spread their lies about those who actually committed them?
Weren't rumors being spread about the righteous!!!
Didn't they accuse my beloved, the most honorable creation of God, who was known as the truthful and trustworthy, Muhammad (peace be upon him), of being a liar, magician, and madman (far be it from him, I sacrifice him with my soul and everything I own)? Who are we to be immune from all these accusations?
Accusations, rumors, and slander do not spread about the scum of society, but they spread about the righteous to tarnish their reputation. However, no matter how long their schemes, we have the examples of the righteous to satisfy us and trust blindly that victory is from Allah alone: "If you support Allah, He will support you." So, those who walk the path of truth will never fall.
Sorry, my father, I know that you always asked me from the beginning of my shock at the beginning of my life that was built on lie, fraud, and Hypocrisy, to be patient and calm, to hold onto my roots, morals, and the way I was raised. The path I am walking may be different from what you recently drawn for me, but we will meet at the end because the principle, values, and beliefs are one. I inherited my principles, beliefs, and steadfastness from you, my dear parents, from my activist father, and from my honorable ancestors. Don't worry; Allah is with us.
The noble and honorable one who fell into a quagmire and was forced to endure must shake off the impurities to remain clean, noble, and honorable, as you raised her not to surrender submit to humiliation. My dignity and self-esteem will not accept what ancestors did not accept despite their torture and persecution.
If my children carry his name, they are from my blood and the pulse of my soul, and their hearts beat with mine. I have full confidence in their goodness and that they have inherited your principles, the goodness of your heart, and your righteousness. Our Prophet (peace be upon him) was so fond of his grandsons (Hasan and Hussein, the sons of his daughter). My children are the precious gems I found when I fell into the quagmire, and diamonds do not lose their value even if covered by external impurities. On the contrary, their value continues to increase and will never decrease.
I inform you, oh, I lost a piece of my soul when I heard of your death while being far away from you, that I will take revenge from those who tried to spread lies about you.
All the files have been submitted, and the fraud and manipulation using my name will be exposed. In Canada, (I am sorry my dad that the disbelievers seem to possess the morals of Muslims, and they hear and can know who the liar is and who is the truthful one, this is what happened, while I live in an Islamic country, but corruption, evil, and falsehood are spreading. However, Allah is greater than all of them, and He alone, may He be glorified and exalted, is capable of crushing them in the blink of an eye.
I assure you that I am still on your path, and I will fight for my principle, my approach, my cause, and my belief. Yes, finally, I opened my file to the Canadian government out of love for you and as a simple revenge for what happened to you. Let him and his Canadian partner in Kuwait, as well as his relatives in Canada, pay the price for their collusion and manipulation of documents and fraud using my name.
I promise you that I will pursue them even in their dreams so that they do not see the consequences of what they did by exploiting your name. We still have a lot in our arsenal, so patience is great.
Despite their evasion, deceit, and conspiracies with no boundaries by people who think that their influence and positions in Kuwait will save them and fulfill the evil they planned, they overlooked the saying of Allah (And they plan, and Allah plans, and Allah is the best of planners).
They overlooked that my trade with Allah has not and will not perish as long as I live. They overlooked that your righteousness and the goodness of your heart will save me from them thanks to your righteousness and prayers.
They overlooked that Allah, glorified and exalted is He, is able to turn their plots against them. Indeed, Allah has saved me from all that has happened, despite their cunning and the traps they set. Yes, my father, Allah has supported me so far, and I am confident that He, glorified and exalted is He, will save us from what is to come, with a victory greater than before. Did not Allah save the Companions of the Cave with the righteousness of their ancestors? So, how can I not trust Allah (and He will give you victory) Isn't Allah the one who honored me with your righteousness?
Until we meet on the Day of Judgment, my dearest, with victory in both worlds, 0 Lord of the worlds.
41. I tried to keep the conversation focused on the children’s well-being. I asked caring, respectful questions like: “Can I talk to them?”, “What do you want to return?”, “Do you want to visit Kuwait with the children?”, “Can we work something out together?”
42. I asked for cooperation, but she avoided giving clear answers and made vague or dismissive replies. She did not show any intent to resolve things or allow contact with the children.
43. This conversation, like others, shows that I remained respectful and focused on the children’s best interests. The Applicant continued to block communication, ignore questions, and reject efforts to co-parent. I ask the court to consider this as further evidence of my good faith and her unwillingness to cooperate.
44. SCHEDULE A – TAB 08: The conversation shows that the Applicant repeatedly tried to provoke conflict, while I remained calm and avoided escalation. I respectfully ask the court to refer to the original Arabic version of the call, as it better reflects the full tone and context. The Applicant has a pattern of provoking emotional reactions and later using selective excerpts to misrepresent events.
For clarity, I did not threaten her during this call.
PART 4: Public Campaign Misrepresentations and Impact on Children’s Welfare
45. The Applicant has used public websites to post threats, insults, and false accusations against anyone who disagrees with her. In paragraphs 7 and 8 of her May 12, 2025 affidavit, she refers to her www.changeit.org petition, which includes false and inflammatory claims against me, the OCL, judges, and other professionals. She also posted private court documents and photographs of our children without consent. These actions raise serious concerns about her disregard for privacy, court confidentiality, and the potential emotional harm to the children.
46. These statements raise serious concerns and also show that she is not only accusing me. Below are quotes from her petition that highlight how serious this issue is:
47. Attacks on Judges and the Justice System: The Applicant made repeated public accusations against judges and the Canadian legal system, including: “This injustice judge (Kiran Sah) was pointed recently by RECOMMENDATION from the Minister of Justice. It seems that another RECOMMENDATION was provided to close the complaint file against her oppression!” Source “It is clearly that she took the decision to return the children by forcing specific section in the law to be applicable. What is this justice?!” Source “Some racist judges, driven by prejudice against Sunni Muslims… They fail to recognize that it is they who have violated the law… defying the law itself and dishonoring its principles.” Source “Even the judge issued the endorsement with false claiming.” Source Accusations Against Institutions and Officers “Wouldn't it be easier to simply grant the children their right to express their own opinions in court and resolve this dispute fairly?” Source “What has happened to my children and me in Canada… is the responsibility of our esteemed government, which has ignored our case and did not 'listen' to our sounds until now.” Source “The hatred against Muslims confirmed by the Canadian Senate… must be addressed urgently by our esteemed government.” Source
48. Disparaging Named Professionals: The Applicant publicly attacked professionals by name,
stating: “The children’s deceitful lawyer… submitted three different statements… to mislead the court toward false conclusions.” Source “I have followed all official procedures to file complaints against the racist officials in Toronto and Ottawa… However, all my complaints were dismissed— not because discrimination or threats… do not exist, but because higher-ranking officials intervened to shut them down.” Source “The Lawyers are disasters.” Source
49. The tone and language used in these statements reflect strong hostility and a repeated pattern of public defamation. This type of exposure—especially involving the children—can have a serious negative impact on their emotional well-being, their perception of authority and family relationships, and their view of the Applicant’s parental capabilities. Please refer to the Kuwait final custody orders and their stated reasons.
50. I respectfully ask the Court to take judicial notice of the risks posed by this behavior. These statements go beyond protected opinion or advocacy; they include direct attacks on judicial integrity, accusations of racism and conspiracy, and demands for judges based on religion or perceived political views.
PART 5: Misuse of Process, Reputation Attacks, and Ongoing Interference with Parenting and Family Bonds
51. The Applicant appears to be trying to secure an uncontested trial to control the narrative, avoid full disclosure of facts, and limit the court’s ability to review the case properly. She has isolated the children and controlled their communications and views. This pattern also appears in her Change.org petition, where she shares only her version of events—without context or reference to the full legal history.
52. I confirm that I submitted my financial statement on time
53. With respect to the Applicant’s claims about reputation, I respectfully ask the court to review the petition she posted on www.change.org and the Facebook content attached in Exhibit 3. These materials reflect only the Applicant’s perspective and contain several misleading and one-sided claims. I believe any reasonable reader will recognize the imbalance and bias in how the facts are presented.
54. I have not responded to every point raised by the Applicant, particularly those that are irrelevant or unrelated to the parenting issues before the court. I chose to focus only on what truly matters—our children’s well-being and the need for clear and fair parenting arrangements—out of respect for the court’s time.
55. I will not respond to the Applicant’s comments about the reasons given in past trial judgments. Those reasons are not considered evidence.
56. In response to paragraph 32 of the Applicant’s affidavit: she never filed a complaint with the parenting centre or asked to move court-ordered parenting time to the center. Instead, she created unnecessary obstacles that disrupted my time with the children. Her actions made the exchanges hostile and chaotic, rather than peaceful and focused on the children. See my submitted exhibits before)
57. The Applicant’s false and very serious allegation is deeply upsetting. I am shocked that I even have to respond to such an offensive and baseless claim. This shows how far she is willing to go—even at the expense of the children’s emotional well-being to push her personal agenda. If she truly believed something like this had happened, she had a duty to report it to the proper authorities. Instead, she chose not to file any official complaint. Given how active she has been in making legal claims, her failure to report this raises serious doubts about her credibility and fitness as a custodial parent.
58. In response to paragraphs 33 and 35 of the Applicant’s affidavit: The Applicant is misusing her religious beliefs to justify removing the children without consent and cutting them off from their father. This misuse of faith is harmful and highlights the serious emotional and psychological damage being caused to the children.
59. The Applicant falsely claims that I am trying to deprive the children of a relationship with their mother. In reality, she is the one who has cut them off from their father, extended family, and their home and community in Kuwait. Since 2021, she has blocked all meaningful contact. Her accusations are based on incomplete and misleading messages, while ignoring her own actions.
60. The Applicant shared the children’s photos and documents without my consent. This violated their privacy and exposed them to emotional harm, especially since she used these materials to influence public opinion.
61. I am deeply concerned about how the children will feel when their classmates or school community see their personal information and family matters posted publicly and repeatedly by their mother.
62. The Applicant continues to block all three children from having any contact with their two siblings, their father, extended family, and close friends. This ongoing isolation has cut them off from vital emotional support and meaningful family connections.
PART 6: CONCERNS ABOUT THE APPLICANT’S AFFIDAVIT:
63. I respectfully raise concerns about how the Applicant presents her claims and whether her material is relevant to the parenting issues before the court.
64. Serious allegations without supporting evidence: The affidavit includes repeated claims that I am abusive or controlling, but these allegations are not supported by any court order, independent records, or objective facts. In contrast, I hold valid, final, active court orders from Kuwait, Jordan, and Canada.
65. Irrelevant or emotionally charged content: Much of the Applicant’s affidavit focuses on personal conflict between the parties rather than the children’s best interests. These sections shift attention away from the real parenting concerns in this case, including the children’s overall care, education, health, emotional stability, the rejection or disposal of items and gifts ordered for them, repeated changes in home and school environments, and their right to maintain meaningful relationships with both parents.
66. Selective and misleading use of evidence: The Applicant has referred to isolated portions of past communications while leaving out full exchanges and critical context. This presents a one-sided version of events that does not give the court an honest or complete picture.
67. Avoiding key parenting matters: The Applicant’s affidavit does not address the most important issues in this case—particularly, the complete denial of my parenting time, blocked communication with the children, rejection or disposal of items and gifts intended for them, and ongoing concerns about their psychological and emotional well-being. She also fails to acknowledge the harm caused by exposing the children to ongoing parental conflict, or to address signs of alienation and undue influence. In addition, the affidavit overlooks the children’s frequent and unexplained absences from school. These are serious concerns that directly affect the children’s development, stability, and best interests.
68. Misinterpretation and misuse of materials: Several parts of the affidavit appear to misrepresent or distort documents in an attempt to support her position. For example:
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She refers to an incomplete email forwarded from the school using a newly created email address in my son’s name.
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Incidents on May 14 and May 21, 2021, which she references, in fact support my position and document her refusal to comply with court-ordered parenting time, as confirmed by decisions issued by the Kuwaiti judiciary.
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Her paragraph 38, based on a translation that is inaccurate, distorts the meaning of a call that—when reviewed in full—demonstrates concerning behavior on her part.
69. Deeply inappropriate allegations: The affidavit includes a sexual allegation involving our young daughter that is not only baseless but also distressing. It is difficult to understand how a parent could make such a claim without any supporting evidence. I believe this demonstrates a lack of judgment and further underscores the emotional harm caused by her conduct.
70. For these reasons, I respectfully ask the court to give no weight to the portions of the Applicant’s affidavit that rely on personal opinions, emotionally charged narratives, partial or misleading information, or inadmissible content, including references to privileged case conference discussions. The affidavit fails to address core parenting concerns, misrepresents facts, and in some parts, includes deeply inappropriate and unsupported allegations. I ask the court to focus instead on the documented, verifiable facts before it—especially those related to court-ordered parenting time, the children's repeated absences from school, their emotional well-being, and their fundamental right to maintain a safe, stable, and meaningful relationship with both parents.
General Concern: Misuse of Religion and Breakdown of Parent-Child Relationship
71. In multiple parts of her affidavit, the Applicant has demonstrated—both implicitly and explicitly— a desire to sever the children’s relationship with me. In one section, she attempts to justify this by referencing her religious beliefs, suggesting that her actions are supported or encouraged by her interpretation of faith. I believe this is a misuse of religion to excuse harmful and unlawful behavior, and to justify isolating the children from their father.
72. It appears that both religion and the children are being used by the Applicant as tools to pursue her personal agenda, rather than acting in the children’s best interests.
73. I make this affidavit in support of my motion and for no improper purpose.
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THE BELOW EXHIBITS ARE THOSE REFERRED TO IN THE AFFIDAVIT
SWORN on the 2nd day of June 2025 By Zakaria Zayed
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3. Lubna Aldahleh - REPLY - Form 14A - REPLY Affidavit-Motion of Strike, Restrain, Recognizing_ APPLICANT - ALDAHLEH - 27-JUNE-2025
My name is (Full legal name) Lubna Yousef Abdel Rahman Aldahleh
I live in (municipality and province) London, Province of Ontario
and I swear/affirm that the following is true:
1. I am, Lubna Aldahleh, the applicant in this matter, swear this affidavit in support of my “REPLY” to the Respondent’s (his) affidavit dated June 02, 2025.
2. Pursuant to para. 5(e) of Judge Bezaire’s endorsement dated Feb26, 2025, which remains in force, my reply affidavit is capped at 5 pages. I’ve complied, but the limit prevents me from fully addressing the Respondent’s many misstatements and omissions. If the Court requires further particulars, I am ready to provide them.
3. In my reply, I enclose the accountable exhibit, marked Exhibit “A,” along with the unaccounted evidence, marked Brief Exhibit “B”. I further rely on the 16-day trial judgment in this case dated Feb 16, 2024— (Aldahleh v. Zayed, 2024 ONSC 547 (CanLII), <https://canlii.ca/t/k3bl0>) —will refer to its findings.
4. With respect to para 11, I submit Exhibit B-20 (the 155-page CAS record) and deny the Respondent’s CAS allegations; although the SCJ final order of 27 July 2023 required full disclosure and continuing CAS involvement, that record was withheld and the case-worker excluded through manoeuvres by certain judges and the OCL, distorting the proceedings, so I ask that the record be admitted and the case-worker compelled to testify. As for paras 5-10 and 12-14 of the Respondent’s 2 June 2025 affidavit, he is merely re-litigating issues conclusively resolved by the 16-day trial and final judgment; reopening them without an appeal is an abuse of process supporting my motion to strike under Family Law Rules r. 1(8.2). Despite the case’s complexity, the Court’s evidence limits, and the Respondent’s legal misuse, I still submit a thorough defence.
5. The Respondent (paras. 12–13) claims I was “properly and repeatedly” served in the Jordanian custody and criminal cases—by email, embassy calls and a mobile-app—yet he also accuses me of accessing the court file “without formal service” and admits I was never properly served in the criminal matter. These statements are inconsistent: if I had truly received full service through official channels, I would not have needed to obtain the file myself, nor could any alleged breach of court privacy have occurred, as he cited. Also, please review his credibility in the judgment of the trial from para(s) 28-42, at the above link of trial judgment.
6. I never had an opportunity to defend myself in Kuwait or Jordan, and I have held no local phone number or address since I left those countries. If the Respondent now says service was effected by mobile app or e-mail, he must file verifiable proofs and the entire package he claims was sent—virtual-hearing links, the final custody order, and the forgery investigation he cited. Proper service is his responsibility. He has produced no physical evidence to support the criminal allegations, e.g. in para. 7 “Jordanian criminal conviction on Mar 31, 2023”.
7. Attached Exhibit A-01 shows the Respondent filed three ex-parte enforcement requests—28 May 2023 and 14 June 2023 with the Directorate of Public Security, and 20 June 2023 with INTERPOL—without ever serving me or allowing me to respond. I learned of the INTERPOL notice only when the RCMP contacted me on 20 October 2023. Although this evidence was entered at trial, the judgment did not address it, which heightens my concern that anti-Muslim bias may have influenced the Superior Court’s decision.
8. Attached Ex. A-2: After I discharged previous counsel, I served him with a Form 20 Request for Documents on 17 Aug 2023, he withheld pleading and interim order from the Kuwaiti and Jordanian cases, giving me only a few final orders. Not until Nov 07, 2023—days before the London trial and after his failed RCMP arrest bid—did he send a single cover page from his Jordanian trial set to be heard on Nov 17, 2023, to enforce a Kuwaiti order. While I prepared for the abduction trial, he employed counsels in Canada, Kuwait, and Jordan, ran various actions in three jurisdictions. He has disclosed only the documents that serve his interests and continues to deny me access to the full records on which those foreign proceedings_founded on his fraudulent allegation_depend. He refused providing me any virtual-links—ASSUMING ONE EVEN EXISTED.
9. Ex(s). A-01&A-02 show he sent his e-mail only months after he had already triggered INTERPOL and, in it, ignored my request for a virtual-hearing link. Brief Exhibit B-01 also shows he gave the Jordanian court his own Jordanian address for serving me in Jordan, even though I have lived in Canada since July 2021 and have had no address in Jordan since 2009, when I moved permanently to Kuwait after our marriage.
10. In answer to his Exhibit 4, paragraph 20, where he claims I used our son Baraa’s phone number in court, please see my Brief Exhibit B-10 (Kuwaiti Court Order No. 543/21 dated 21 June 2021, permitting the children’s permanent travel from Kuwait). The first page lists the parties’ contact details to show my own Kuwaiti number—50989506—not 50556068, the number the Respondent cites in his 20 Dec 2022 print-out.
11. In response to his allegations about the children’s welfare and his claims of abuse and harassment (paras. 2, 3, 23-24, 56, 59, 61, 62, 69, 71, & 72), the children refuse to speak with him because of his own violent and harmful behaviour toward them and the mother—not because of anything I have done. He now says I sent abusive or threatening messages, yet the evidence shows the opposite: his abusive pattern was acknowledged in the final Kuwaiti orders, confirmed in Canada by the children’s therapists, Victim Services, and CAS, and documented in the 16-day trial judgment. Nevertheless, he continues to blame me and will not leave the children in peace. His persistence is driven not by concern for their welfare but by a desire to control them and disrupt their chance to live a normal life free from his harmful influence. The children’s resistance to the Respondent did not arise in Canada; it began in Kuwait, as confirmed in the trial judgment for ex: para(s). [135, 136, 142, and 271].
12. Brief Exhibits B-3 and B-4 show that, since 2022, Mariam’s file at IRCC has been flagged due to this litigation, putting her Canadian status at serious risk by October. As result, her (OHIP) renewal was refused.
13. In contrary of his statements of caring about the children, please review the judgment mentioned above, also review Ex. A-03 (police report) shows that at 11:50 p.m. on 11 March 2020, during Kuwait’s COVID-19 lockdown, the Respondent forced the children and me out of his apartment and refused to let us return, stating to police that he was barring me because he himself had previously lodged a theft complaint against me. Exhibit A-04 (our WhatsApp chat of 29 July 2020) confirms that four months later he ordered me back into the same apartment; when I asked, why would I return to my ex-husband’s house after being expelled? he replied that returning was “a duty imposed by ALLAH” and accused me of seeking “freedom.” He offered no alternative accommodation that night, underscoring how his actions—not mine placed the children at risk and belie his claim of concern for their welfare. Brief Ex. B 13 is a certificate from the Kuwaiti Criminal Court confirming that, in the theft charge the Respondent brought against me in 2019—a case where he retained two lawyers while I appeared self-represented—the court acquitted me on 14 June 2021. Since I sought a divorce, the Respondent has tried every means to portray me as a criminal aiming destroying my reputation. I filed this certificate, together with the complete pleadings and full judgment, with the trial court in London Ontario - SCJ, yet the trial reasons mention the theft allegation without noting my acquittal. These documents illustrate the Respondent’s ongoing pattern and attitude. Ex. A-11: is the Respondent’s handwritten note from a reconciliation session on 21 February 2017. Asked to list four positive qualities about me, he actually wrote eleven: (1. She is keen on the home and everybody, 2. Committed, 3. Pious to God, 4. Respectful & successful housewife, 5. Patient, 6. Educated, 7. Cooperative, 8. Good cook, 9. Appreciating respect, 10…., 11. …); those contrast to his current effort to brand me a criminal only after I refused to remain in a violent marriage; He has gone further, exploiting anti Muslim prejudice in Canada by insinuating—without any factual basis—that I present a terrorist risk, and even invoking between references to “Palestinian” against “Masonic-Zionist” involvement to my beloved ancestors. I will proudly address these defamatory allegations in greater detail in a forthcoming petition on Change.org (https://chng.it/7dV7zn2cDY) and Factum(s) ALLAH willing. He has deliberately chosen to raise this aspect in the present case aiming malicious intent, but this is the Lord’s plan, and certainly I am grateful to ALLAH that this topic is opened.
14. Attached Exhibit A-08: is a police incident certificate dated May 2021 confirming that, at the Respondent’s instigation, I was taken into custody in front of the children. The certificate states no lawful basis for my arrest; it merely records planned defamatory remarks, plainly intended to damage my reputation.
15. Ex. A-09: chat exchange dated Aug 20, 2022 that exemplifies the Respondent’s pattern of harassment. Since the start of our marriage, he has repeatedly not only blended physical abuse but also religious abuse with mental, verbal, and emotional abuse, telling me, for example: “You don’t understand life, laws, motherhood, or religion at alL” “But you are used to being rude and saying dirty words.”…”Be rotten in Canada and live like a founding.”.
16. In reply to paragraph# 69—and in support of the video record dated April 21, 2021 already before this Court—I tender Exhibit A-10, Some evidence concerning the sexual harassment of the young daughter in 2021.
17. Attached Ex.A-05: An example of the father’s attempts to force the mother to relinquish custody of the children solely to make him cease his personal harassment of her. Also, paragraph# 141 at the judgment in this case.
18. Exhibit A-06 is a court order dated November 2020 directing the father’s arrest and appearance as a debtor for failing to pay 3,413.500 Kuwaiti Dinars in child support, illustrating his ongoing financial abuse.
19. Exhibit A-07: is an official report dated 29 November 2020 from the Embassy of Jordan in Kuwait confirming that the Respondent fraudulently obtained and altered the children’s passports.
20. Also attached exhibits from B-05 to B-12 and B-14 to B-24 to support my evidence and motion dated Feb 20, 2025. Also, to refer to them as evidence in my arguments in the Factum(s),Videos. I argue them in the Factum(s).
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SWORN on June 27, 2025 By Lubna Aldahleh
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4. Lubna Aldahleh - Form 14 - Notice of Motion _ APPLICANT - ALDAHLEH - 20 FEB 2025
The person making this motion or the person’s lawyer must contact the clerk of the court by telephone or otherwise to choose a time and date when the court could hear this motion. TO THE PARTIES:
THE COURT WILL HEAR A MOTION on (date) February 26, 2025
at (time) 10:00 A.M , or as soon as possible after that time at: (place of hearing)
ZOOM LINK PROVIDED BY THE COURT
This motion will be made by (name of person making motion)
Applicant Mother, Lubna Aldahleh
who will be asking the court for an order for the item(s) listed on page 2 of this notice.
X - A copy of the affidavit(s) in support of this motion is/are served with this notice.
X - A notice of a case conference is served with this notice to change an order.
If this material is missing, you should talk to the court office immediately.
State the order or orders requested on this motion.
1. An Order, pursuant to Rule 3(5) of the Family Law Rules, abridging time for serving and filing of the within Motion, if necessary.
2. An Order, pursuant Rule 1(7.2) of the Family Law Rules, that the Applicant Mother’s affidavit and exhibits for this motion may exceed the page limits as set in the Province-wide Notice to the Profession, if necessary.
3. An Order, pursuant to Rule 1(7.2) of the Family Law Rules, setting a special appointment date for the hearing of this motion at the earliest possible date.
4. An Order, granting the Applicant Mother leave to submit the report cards of the school before the special appointment date of the three children to provide this Honourable Court of their good achievements in the school, due to the delay of providing them for administration’s reasons. And more evidence to determine the other claims in the respondent’s motion.
5. An Order, pursuant to Rule 1(8) of the Family Law Rules, to strike the Respondent Father’s pleadings for noncompliance in order to provide disclosure. He did not submit them by the due date on March 16, 2024.
6. An Order, pursuant to section 41 of the Children’s Law Reform Act, R.S.O. 1990, c. C.12, recognizing the Applicant Mother’s final orders, in the applicant’s amended application dated October 18, 2023, originally dated October 07, 2022, and in her reply by dated August 12, 2024, which granted in Kuwait at the final basis before moving to Canada.
7. An Order, pursuant to section 16.1(2) Divorce Act, alternatively section 28(1)(a) (i) CLRA, grant the mother sole decision-making responsibility to facilitate the immigration process for the little daughter, Mariam Zayed, due to the risk of her legal residency in Canada.
8. An Order, pursuant to section 35(1) CLRA to restrain the father from attending any location that the children and the mother is known to be if he comes to Canada.
9. An Order, pursuant to section 21.2(2) CLRA for CAS to disclose records that may be in their possession with respect to any investigation in relation to the children and the Parties.
10. The cost of the motions.
11. Such further and other relief as Applicant may advise and this Honourable Court deem just.
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5. Lubna Aldahleh - Form 14A - Affidavit _ APPLICANT - ALDAHLEH - 20 FEB 2025
My name is (Full legal name) Lubna Yousef Abdel Rahman Aldahleh
I live in (municipality and province) London, Province of Ontario
and I swear/affirm that the following is true:
"I do not agree with and strongly oppose all the allegations made by the respondent father, as they are false and misleading. His motion contains over 19 requests, some of which are repetitive. I will respond to his claims systematically and in the appropriate order based on my evidence and arguments."
RESPONDENT CREDIBILITY DURING THE TRIAL AT SUPERIOR COURT OF JUSTICE:
1. Please review the issues of credibility of the respondent father at Aldahleh v. Zayed, 2024 ONSC 547 (CanLII), <https://canlii.ca/t/k3bl0>, from paragraph [28] to [42].
RE: FAILURE TO COMPLY WITH COURT ORDERS:
APPLICANT MOTHER POSITION:
2. It is unclear what the respondent seeks to achieve by resurrecting the same arguments that were already litigated and resolved by the trial judgment over a year after his initial claims. The matter has been conclusively addressed, and revisiting these issues serves no legitimate purpose other than to create unnecessary litigation and obstruction.
3. The majority of the orders cited by the respondent were rendered moot upon the release of the final judgment dated February 16, 2024. Prior to the trial, I fully complied with all court orders. Furthermore, the respondent’s false allegations were thoroughly addressed during the trial. Please review the order issued by Justice Tobin dated Feb 16, 2024, addressed that “All interim orders made in this case are now at an end. This would include the order of Justice V. Mitrow dated November 29, 2023.” “Attached as TAB-01 in the applicant’s schedule of exhibits”.
4. With respect to Justice Victor’s order dated November 29, 2023, there was a miscarriage of justice. As a result, I took the appropriate legal steps by appealing the order before the Superior Court of Justice – Ontario - Divisional Court in Toronto. Some of the details are at Aldahleh v. Zayed, 2024 ONSC 2417 (CanLII), <https://canlii.ca/t/k4887>
5. Despite Justice Victor’s order stating that no motions were to be filed before the trial, the applicant mother was granted permission ......... ...TO BE CONTINUED DUE TO THE TEXT-LENGTH LIMIT