To continue the court material from the previous post, …

• CONTINUING OF 5. Lubna Aldahleh - Form 14A -  Affidavit _ APPLICANT - ALDAHLEH - 20 FEB 2025 

6. Lubna Aldahleh - Amended Form 14A -sworn-  Affidavit to Support Motion of Notice Dated 20-FEB-2025_ APPLICANT - ALDAHLEH - 12-MAY-2025  (TO BE CONTINUED)

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CONTINUING OF  5. Lubna Aldahleh - Form 14A -  Affidavit _ APPLICANT - ALDAHLEH - 20 FEB 2025 

5. Despite Justice Victor’s order stating that no motions were to be filed before the trial, the applicant mother was granted permission to file a motion to stay that order and to appeal it. This permission was explicitly granted by Justice Hassan in a written order issued in chambers on December 5, 2024. “In the event that permission is required for the Applicant’s Motion, then permission is granted and the Motion should be served and filed as per the Rules of Civil Procedure.” “Attached as TAB-02 in the applicant’s schedule of exhibits”.

6. Also, the applicant did her responsibility to respect the law of filling an urgent motion to stay the order in the same court that issued it, in London, Ontario. However, the trial judge confirmed that the matter would be addressed in the trial judgment, which was ultimately done through the endorsement order dated February 16, 2024, effectively terminating all temporary orders. So, any delay in releasing the urgent matter which explained the risk of the children’s interests on that orders, is between the wisdom of this honorable court.

7. I do not wish to waste the Court’s time by resubmitting evidence related to arguments that were already litigated before the trial. However, I am prepared to provide the Court with evidence on the crucial points necessary to reassure this Honorable Court of the applicant mother’s respect for and compliance with judicial orders.

1. Regarding the order of Justice Korpan dated March 30, 2023, I fully complied with all its provisions despite the risks involved. However, it was my previous lawyer’s responsibility to follow the proper procedures in updating this Honorable Court with our address and contact information, but it appears that he failed to do so. I became self-represented on August 9, 2023, and, on August 14 & 15, 2023, I properly served the other party with the correct information via email. Additionally, on August 24, 2023, I properly filed and served a 'Notice of Change in Residence' affidavit at the courthouse in London, Ontario. “Attached as TAB-03- the email of providing the information in the applicant’s schedule of exhibits”. / “Attached as TAB-04- the email of SERVING “Notice of Changing in Residency dated August 24, 2023, in the applicant’s schedule of exhibits”.
2. All information regarding the children's access was provided to the respondent father through my previous lawyer’s letter immediately in April 2023, and I confirmed this in my affidavits during 2023 & 2024. Additionally, I directly communicated this information to the father via 'Talking Parents' in 2023. If there are any future changes to this information, I will follow the proper legal procedures in accordance with the Canadian legal system.
3. Unfortunately, the respondent has continuously harassed and pressured me by sending hundreds of repetitive emails and messages through 'Talking Parents' on the same topic, despite my having already responded to his initial inquiries.

RESPONDENT FATHER POSITION:
On the other hand, the respondent father has failed to comply with multiple court orders, including but not limited to the following:

8. (Attached as TAB-05), The respondent father ignored the formal request for information, which was served and filed on August 17, 2023, and required him to provide the applicant mother with all the orders issued in Kuwait within 3 days, as ordered by Justice Tobin in his order dated August 11, 2023 (Attached as TAB-06). Despite this, the respondent withheld these documents for several months, even as the trial date approached, which was originally scheduled for July 30, 2023. Attached as TAB-07- the email of SERVING “Notice of Form 20_Request of Information dated August 17, 2023, in the applicant’s schedule of exhibits”.

Attached as TAB-08- “Form 20_Request of Information dated August 17, 2023, in the applicant’s schedule of exhibits” confirmed that the applicant request them by August 20, 2023.

In TAB-07, confirmation that the applicant re-sent another email to request the information on August 28, 2023. 

9. The respondent disobey the order by Justice Tobin, dated March 15, 2024, This court orders that the respondent pay forthwith to the applicant costs of the trial fixed in the amount of $9000.00. (Attached as TAB-09). After many arguments from his side, the respondent father finally paid the cost of the trial on June 3, 2024.

10. The respondent father has failed to comply with the judgment issued on February 16, 2024, which required him to file his amended answer within 30 days, by March 16, 2024. To date, he has not fulfilled this obligation. At Aldahleh v. Zayed, 2024 ONSC 547 (CanLII), at para 304, <https://canlii.ca/t/k3bl0#par304> https://canlii.ca/t/k3bl0#par304 “On a temporary basis: 3. The Respondent shall have 30 days from the date of the service of this order upon him to file his Answer in this proceeding.”

11. The applicant mother raised her concerns before the judge during the hearing on March 19, 2024, regarding the delay of this case for over two years. She requested an uncontested trial in order to finalize this matter as soon as possible, in the best interests of the children. Unfortunately, the judge ignored the applicant mother’s request for an uncontested trial and, instead, granted the respondent an extension of three more months to file his amended answer. This extension exceeds the legal timeframe for responding to the initial application regarding the residence outside Canada. (Attached as TAB-10) 

The Respondent is granted leave to file his Answer, 35.1, 35.1A affidavits and Financial Statement by June 28. 2024. 

12. Despite this, the respondent father did not comply with the order issued on March 19, 2024, and the mother did not receive the financial statement by the deadline specified in the order, which was June 28, 2024. (Attached as TAB-11). The Endorsement Order by Judge Sah dated July 09, 2024. “The Respondent has “not” filed a F.S. as ordered.”

RE: PARENTING TIME AND THE CHILDREN’S COMMUNICATION AND THEIR SITUATIONS:

13. The respondent father alleges that I have failed to comply with multiple court orders regarding parenting time. However, I have made reasonable efforts to facilitate the ordered parenting schedule during 2023, and all those schedules’ orders were ended by February 16, 2024.

14. (Attached as TAB-12), Talking Parents Communications Records of calling, which confirms that the children last time accepted to answer the father calling was on December 14, 2024. However, they refused to speak with him not only in Canada, but also from Kuwait. All the calls timed for seconds.

15. (Attached as TAB-13), The email dated August 15, 2023, by the OCL who had investigated the case and he confirmed the following: “During the court appearance of July 31, 2023, I indicated to counsel that the children do not wish to communicate with the father at all. Our position has not changed, and at this time, we will not meet with them to ask the same question.”. 

16. (Attached as TAB-14), Affidavit Ms. Lisa Heslop, a member of the Clinical Panel of the Office of the Children’s Lawyer (“OCL”), dated July 21, 2023, confirmed that:

• a. The violence from the respondent father toward the mother and the children in Kuwait.
• b. Confirmed in page 18 of the affidavit that the children had already full sessions with psychologist by Dr. Collin King for Baraa to heal from the trauma occurred in Kuwait because of the father. And the daughters (Lujain and Mariam) had sessions by Muslim Resource Centre (MRCSSI). In addition, the three children had sessions to deal with the trauma as well with Dr. Amjed AbuJedi referred by “Victim Services London”.
• c. To avoid more trauma of the children by long period of years of investigations, initially, those reported from the psychologist did not file properly in the court. The applicant Mother needs the permission order to file them and request the individuals mentioned above to be witnesses.

17.  (Attached as TAB-15), The reasons behind refusing the OCL in 2023 the child’s psychologist from the other parties confirmed that there is biased against the mother even before speaking with her or meeting the children and the mother.

Dear counsel, 

Subsequent to the two meetings with Ms. De Veto, the OCL felt compelled to express our concerns about the neutrality and appropriateness of Ms. De Veto and her potential involvement in this case. We will not agree to Ms. De Veto doing relationship counselling in this case and ask that the Family Court Clinic do the counselling. We can reach out accordingly. The OCL concerns based on our initial meetings with Ms. De Veto are as follows:

1. Credible and Serious Allegations: It is vital to emphasize that the children's statements to the OCL are credible and serious. We firmly believe that their safety and well-being should be our utmost priority.
2. Child Psychologist: Originally, the parties agreed upon Dr. Sas, a child psychologist skilled in handling such sensitive cases. Unfortunately, she cannot be involved in this case due to a conflict of interest. However, the OCL is concerned that Ms. DeVeto is a replacement who is not a child psychologies and who does not acknowledge the need to properly assess the children's situation or needs and seems keen on reunification therapy under the forensic work lens.
3. Lack of Neutrality: Reunification therapy, in this specific case, is contraindicated for children who have experienced abuse, including witnessing their mother being abused. There is substantial evidence in the literature supporting this. Additionally, the children have expressed fear of their father, and their behaviour is consistent with their feelings.
4. AFCC Guidelines: The guidelines set forth by AFCC prioritize children's safety above all else. We strongly believe that the current process, as outlined by Ms. De Veto, does not align with these essential guidelines.
5. Concerning Statements/comments by Ms. DeVeto: During the initial and second meetings, she made statements that raised serious doubts about her suitability and impartiality for this case. For example:

• a. Negative views on OCL: She referred to OCL as an anchor that hindered the process and expressed a dislike for our involvement.
• b. In the second meeting, she restated her feelings about OCL -and said that OCL had become an agency that "simply parrots" children's words.
• c. Discrediting specialized DV training: In the second meeting, she reiterated her negative views on OCL and questioned the credibility of anyone with specialized training in DV, including us. This casts doubt on our ethics and professionalism.
• d. She questioned our ethics and suggested we were acting "outside of our lane".
• e. She suggested that there is an obligation to make children participate and talk: She suggested that the mother should exercise her parental authority to make the children speak to their father, disregarding their fears. She said that the mother "can't hide behind the wishes of the children". She drew an inference that the mother is already at fault despite her insistence that everyone involved can't be positional. Frankly, in our view, she has been positional from the outset.

6. Misconceptions about child rejection: She claimed that children do not outright reject their abusive parents unless subjected to torture.
7. Questioning the children's credibility: She consistently questioned the credibility of the children's statements, even when citing examples, for example, the child's disclosure that when he last spoke to his father he was so afraid he "peed his pants."
In light of the above, the OCL firmly believes that the children need relationship counselling by qualified professionals to determine the best course of action for their well-being, including how to support them through this process and next therapeutic steps. 

For clarity purposes, Ms. Heslop and I will not meet again with Ms. De Veto, and or respond to her questions from today's meeting. 

If the above is unacceptable, the OCL's would ask the court that the matter be set for Trial. 

Kind Regards, 

Rasim (Sam) Misheal -----

18. (Attached as TAB-16), The investigations by CAS between 2021 to the end of 2023 confirmed the violence from the father. The closing letter dated July 31, 2023, was sent by the case worker to both parties to confirm that the children are safe with their mother, but not with the father.

Dear Mr. Zayed: 

Re: Baraa Zayed, Lujain Zayed and Miriam Zayed 

I am writing to inform you that the Children's Aid Society of London & Middlesex has concluded its recent investigation with your family During the course of our involvement, concerns regarding you and your children were confirmed. However, ongoing service from the Society is not warranted at this time. 

Thank you for your cooperation with me during my involvement with your family. 

If you have any questions, please do.....

19.  Also, at the same attached TAB#16, Provided disclosure for the investigation#12443448 of the details of the safety threats and the assessments of that investigation.

20. (Attached as TAB-17), The record videos of one of the communications between the respondent father with the children to confirm the risk of his violent behavior toward the children by leading him to be very angry from his behaviors and his violence.

21.  Aldahleh v. Zayed, 2024 ONSC 547 (CanLII), <https://canlii.ca/t/k3bl0> the evidence that the mother did not prevent the children from the communication with the father, but rather the father’s behaviours with them and his violence is the reason behind their trauma:

A. RISK OF PHYSICAL HARM:

i. https://canlii.ca/t/k3bl0#par268 [268]        B. described to Ms. Heslop that L. and he were subject to physical discipline by the father. He would hit them. L. described the father as quick to anger.

ii. https://canlii.ca/t/k3bl0#par269 [269]        The three children were exposed to family violence between the mother and the father. For the reasons set out above, I accept the mother’s evidence that she was the victim of family violence from the father, as described in her evidence.

iii. https://canlii.ca/t/k3bl0#par270 [270]        L. described to Ms. Heslop an incident where the mother tried to return to the family apartment but the father did not want her to enter. During this incident, L.’s leg was caught in the door when she opened it for the mother and the father intervened to prevent the mother from coming inside. As well, there were some audio and video recordings admitted in evidence. They purported to show the children being upset while in the care of their father because of his behaviour towards them. The weight given to these exhibits is slight, as context was not clear.

iv. https://canlii.ca/t/k3bl0#par271 [271]        I find that the potential serious risk to the children is the father’s propensity to anger, and B. and L.’s resistance to him.

B. SOME OF THE VIOLENCE FROM THE FATHER IN KUWAIT:

 i. Events of May 14, 2021

1. https://canlii.ca/t/k3bl0#par134 [134] The mother again attended at the Vision Centre with the children on May 14, 2021. It was Eid. B. was crying and refused to go with the father. Mr. Al Qalaf came outside of the Vision Centre and told the mother to wait with B. inside. M. and L. went with the father. After waiting inside for approximately 1.5 hours, Mr. Al Qalaf returned and told the mother to go to her car and leave B. at the Centre. The mother did as she was asked. Shortly thereafter, she saw L. and B. come out of the Centre, both crying and upset. The two children ran to the mother’s car and got inside. The mother then went into the Centre to ask “mercy for the children” from Mr. Al Qalaf. Based on his response to her, the mother was afraid that a false report would be prepared to the effect that she was a “neglectful mother”, so that she would lose custody. The mother took a video with her phone to show, if needed, that the father kept M. At 5:00 p.m., M. was returned.

2. https://canlii.ca/t/k3bl0#par135 [135] According to the father, on May 14, 2021, all three children were happy to go with him. Mr. Al Qalaf helped him take the children to his vehicle. It was the mother who intervened by claiming B. did not want to go. They all went inside the Centre, where the mother engaged in a verbal argument with centre staff and a security guard. She was asked to leave. The mother took L. and B. with her to her car. The mother then tried to take M. from the father. This resulted in a security guard trying to intervene. The father gave M. to the mother.

3. Court’s finding with respect to the events of May 14, 2021 https://canlii.ca/t/k3bl0#par136 [136] I find that the mother’s evidence regarding the events of May 14, 2021 to be more credible than the father’s. The mother provided significantly more detail regarding the events of that day than did the father. These details were consistent. The father’s observation that the children were happy to go with him is inconsistent with the uncontroverted evidence of what had happened previously. B. was reluctant to go with his father. The mother’s version of events is more consistent with all of the other evidence in relation to these children’s demeanour concerning parenting time. The evidence does not explain why the father needed the help of Mr. Al Qalaf to bring the children to his car if they were willing to go. I also take into account that there is a text message from the mother on May 14, 2021 that indicates she will receive M. at 5:00 p.m. That appears to be contemporaneously prepared evidence that the father did have M. with him, contrary to his assertion. I have also had regard to the father’s statement dated September 14, 2021, which is consistent with the mother’s version of events.[12]

ii. Events of May 21, 2021

1. https://canlii.ca/t/k3bl0#par137 [137] On May 21, 2021, the mother attended the Vision Centre with the three children for an access exchange. B. and L. refused to go with the father. M. did go with the father.

2. https://canlii.ca/t/k3bl0#par138 [138] Mr. Al Qalaf and the father, together with another employee of the Centre, were beside the mother’s car shouting at B. and L., who looked afraid. The mother called the Centre’s hotline to speak with its manager.

3. https://canlii.ca/t/k3bl0#par139 [139] The manager and the mother were able to convince L. to go with the father along with M.

4. https://canlii.ca/t/k3bl0#par140 [140] Some time later that day, the father called the mother and told her that L. wanted to return home early, at 2:00 p.m. As requested, the mother went to the Centre early. When she picked up the children, she took a photo to show she was there and exchanged the children. She suspected that the father would allege she did not come at 5:00 p.m. to pick up the children. Mr. Al Qalaf and another employee demanded the mother give over her phone. She refused. The police were called, came to the Centre and told her to go to the police station. They did not tell the mother what she had done wrong.

5. https://canlii.ca/t/k3bl0#par141 [141] The mother went home with the children. She was called by the police to attend at the police station. She went there with the three children. When she arrived, she saw the father laughing with Mr. Al Qalaf and the other employee. Mr. Al Qalaf verbally abused B., who was crying. The father did not intervene on B.’s behalf. The father asked the mother to sign a document giving him custody. He said that if she did, she could return home quietly. She refused. The mother was then arrested and held overnight.

6. https://canlii.ca/t/k3bl0#par142 [142] The evidence of B. and L., not denied by the father, was that when the father took the children from the police station that afternoon, he stopped along the way to purchase a cake. The children perceived this purchase as a celebration of what had happened to their mother.

7. https://canlii.ca/t/k3bl0#par143 [143] The next day, with the assistance of a lawyer, the mother was released. [13] The father, who had kept the children overnight, brought the three of them to the police station and they left with the mother.

8. https://canlii.ca/t/k3bl0#par144 [144] While the mother was in police custody, an employee of the Vision Centre sent a WhatsApp message to her phone. She did not receive it until the next day. The message stated that “your child visitation file has been permanently closed, so please don’t attend to the centre at all by order of counsellor/Saleh Al-Rafk.”

9. https://canlii.ca/t/k3bl0#par145 [145] After reviewing this message, the mother did not attend at the Vision Centre with the children. She understood that the services offered there ended.

10. https://canlii.ca/t/k3bl0#par146 [146] The father’s evidence is that the file was temporarily closed.

11. https://canlii.ca/t/k3bl0#par147 [147] I do not accept the father’s evidence. It is contradicted by the WhatsApp message from the Vision Centre to the mother.

12. The mother applies for permission to leave Kuwait

RE: CUSTODY, DECISION-MAKING, AND PASSPORT HOLDER OF THE THREE CHILDREN:

The Little Child’s Status, Mariam Zayed, In Canada Is in Risk:
22.  A letter from IRCC has requested the custody of the child, Mariam Zayed, to complete her application to grant her the “permanent residency” in Canada. (Attached as TAB-18),

Dear Mariam Zayed:

This is in reference to your application for permanent residence in Canada. In order for us to continue the

processing of your application, we require the following documents:

XXX - Mariam Zayed:

Client Information: Receipt of information from client Please provide the

following:

 - written parental agreement for Mariam Zayed

- custody agreement for Mariam Zayed

- Court order(s) for custody of Mariam Zayed This must be received at this office by: 2025/03/03

23.  The child’s passport, Jordanian Passport, and her visitor visa record will be expired October 11, 2025. The applicant mother will “not” be able to apply for renewing the child’s passport in Jordan based on issues from the Jordanian Embassy. (Attached as TAB-19).

24.  HOUNORABLE COURT, it is unfair for the mother to be treated as a criminal and to have the children's passports taken from her without any legal or logical justification, especially after she obtained all rulings from Kuwait in her favor, which removed all of the father's rights to guardianship or custody due to his abusive behavior towards the mother and children in Kuwait. Furthermore, the mother was proven innocent of the child abduction case before the Supreme Court of Justice in London, Ontario. Aldahleh v. Zayed, 2024 ONSC 547 (CanLII), <https://canlii.ca/t/k3bl0>

ALL THE FINAL ORDERS ISSUED IN KUWAIT BEFORE MOVING TO CANADA FOR THE MOTHER FAVOUR, SOLO CUSTODY AND SOLO GUARDIANSHIP:
25.  Please take a look at Aldahleh v. Zayed, 2024 ONSC 547 (CanLII), <https://canlii.ca/t/k3bl0> from paragraphs 17, 36, 83, 85, 99, 123-128 and 189 

[17] In her evidence, the mother was able to identify some positive aspects of the children’s relationship with the father. This is to be contrasted with the father’s evidence that she was not a good mother. He did not allow a positive view of the mother, even though he did not contest the Kuwaiti court order that originally granted her custody of the children.
[36] The father’s unwillingness to concede any positive attributes to the mother’s care of the children is of concern. This evidence supports a finding that his interest in the outcome of the case is greater than his willingness to be candid and truthful. As noted above, he did not contest the mother’s claim for custody when the original order was made in Kuwait.
[83] On November 25, 2019, the mother started a court case against the father seeking custody of the children.
[85] On February 11, 2020, the Hawalli Family Court granted the mother custody of the three children.
[99] As set out above, on February 11, 2020, the mother was granted custody of the children by the Kuwaiti court. The father did not appeal that order.
[123] In August 2020, the father wanted the children to attend a different school from the one they had been attending. The mother did not agree with this plan based upon the children’s wishes and her view that the school they attended was “an overall better school”.
[124] This prompted the mother to seek an order for guardianship of the children, which she filed on August 11, 2020.
[125] On September 1, 2020, the father filed a police report against the mother based upon her not taking the children for an interview at the proposed new school. In Kuwait, as their father, he had the automatic right to educational guardianship, that is, the right to make decisions regarding the children’s education.
[126] The mother was successful in her request. On September 22, 2020, the mother was granted guardianship (i.e., decision-making responsibility) regarding the children’s education. By order of the court in Kuwait on November 15, 2020, the mother was granted guardianship with respect to the children’s schooling, passports and identification documents, medical and health decisions, all “without referring to the father.”[10]
[127] On December 1, 2020, the father renewed the mother’s sponsorship to remain in Kuwait for one year. He did so on the basis that the mother was his wife.
[128] The very next day, December 2, 2020, the father obtained a divorce order as against the wife.[11]  This started a three-month waiting period during which the father had the opportunity to revoke the divorce. If not revoked, the divorce would “become official”.
[189] The mother did not abduct or wrongfully remove the children when she left Kuwait in July 2021. At that time, she had a number of court orders in her favour. She had a custody order. She had three guardianship orders including over the children’s documents, education, and health. She had permission from the Ministry of Education to change the children’s school to a school outside of Kuwait. She also had the permission of the court to travel outside of Kuwait.
RE: THE APPLICANT MOTHER DEMANDS IN THIS CROSS-MOTION:

26.  Please review the Applicant’s Notice of Motion dated February 20, 2025.

RE: THE MOTION BY THE FATHER DATED FEBRUARY 26, 2025:

27.  The Respondent Father argues the matters dealt in the trial judgment dated February 16, 2024.

28.  The respondent used false evidences from Kuwait provided by his friends in the Interior Ministry in Kuwait, without my knowledge or even reaching out to me. That also was ended in the trial by releasing the order dated February 16, 2024.

RE: THE MOTIONS DATED FEBRUARY 26, 2025:

The Applicant Mother is seeking 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, with permission to submit more evidence.

Put a line through any blank space on this page.

SWORN on Feb 20, 2025, By Lubna Aldahleh

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6. Lubna Aldahleh - Amended Form 14A -sworn-  Affidavit to Support Motion of Notice Dated 20-FEB-2025_ APPLICANT - ALDAHLEH - 12-MAY-2025 

1. I am, Lubna Aldahleh, the applicant/moving party in this matter, swear this affidavit in support of my Form 14 Notice of Motion dated 20 February 2025.

2. Based on 5(e) of Judge’s-J. Bezaire- order dated 25 February 2025, all filings must comply with the Provincial and Regional Practice Directions on page limits, font, and spacing, and my request for leave to exceed those limits was denied, the certified evidence will be divided into highly concise, page-numbered excerpts in Schedule A. The documents listed in Schedule B are submitted as evidence without being counted toward the statutory page limit.

A. HISTORY:

3. I am a Canadian citizen, living in Ontario since 2021 with my three children: Baraa Zayed (male, born 21 Oct 2010, Toronto) and Lujain Zayed (famale, born 6 Nov 2012, Toronto)—both first‑generation Canadians—and Mariam Zayed (famale, born 11 Oct 2018, Amman), who currently holds visitor‑visa status. Their father was born in Kuwait and now lives there on a temporary‑work residency with his second wife and their two children, as shown in his Superior Court filings.

4. After years of domestic violence, I initiated divorce proceedings in Kuwait in 2019—my final attempt to secure safety—seeking sole custody and decision‑making authority for the children to protect them from their father’s abuse and give them a brighter future. Following a serious assault by the respondent, I relocated with the children to Canada, their country of birth. By the time we left, the Kuwaiti appellate courts had issued final orders, over the father’s opposition, granting me sole custody, sole decision‑making responsibility, and guardianship of the children’s passports and other legal documents, as well as authority over their education, residence, and any future relocation. Hostility intensified after these orders: the respondent and his well‑connected associates in the Middle East continued to threaten us, and I was unable to convert my Kuwaiti residency from dependent‑spouse status to a work permit. Even after our move to Canada, the respondent has continued to threaten and attempt to harm me and the children. Aldahleh v. Zayed, 2024 ONSC 547 (CanLII), <https://canlii.ca/t/k3bl0>

5. Because my youngest daughter, Mariam, holds only visitor‑visa status in Canada, I have applied for permanent‑resident status on her behalf. The father is actively opposing the application, seeking to prevent her from settling here with her Canadian mother and siblings. He alleges—without ever serving me with the documents filed in Kuwait and Jordan without my knowledge while I am in Canada—that I committed fraud and that he has final custody because I “abducted” the children. Kuwait and Jordan do not provide virtual court hearings, so since our move to Canada in July 2021 “legally” I have been unable to appear and defend myself there, which the respondent has exploited to advance misleading claims and obstruct justice in the Middle East. Immigration, Refugees and Citizenship Canada (IRCC) has placed Mariam’s application on hold since 2022 (3 years ago) until the issues are resolved before the Superior Court of Justice. Unless her status changes, Mariam will lose her passport and visitor status in Canada next October. The father continues to oppose the immigration process to have her deported and separated from her family—ALLAH forbids.

6. On 7 October 2022, after repeated efforts to obtain a Legal Aid certificate, my previous former lawyer filed this application on my behalf. The respondent father “refused” to accept service by e‑mail and ignored all correspondence. I also tried repeatedly to reach him so that he could accept service and attend the first court date, set for 31 January 2023 in London, Ontario, but received “no response”. Several months later, a lawyer retained by the respondent in London eventually agreed to accept special service on his behalf.

B.  STRIKING PLEADINGS BACKGROUND:

7. On 26 January 2023, the Form 8 application was duly served in accordance with the Family Law Rules. The applicant received “no answer” from either the respondent father or his former lawyer within the required timelines—30 days for counsel served in Canada or even 60 days for a party residing outside Canada. Attached in Schedule B – Tab# 01.

8. Based on the family rules in Ontario and based on the application form 8 (THE RESPONDENT HAS ONLY 30 DAYS AFTER THIS APPLICATION IS SERVED ON THE RESPONDENT (60 DAYS IF IT IS SERVED ON THE RESPONDENT OUTSIDE CANADA OR THE UNITED STATES) TO SERVE AND FILE AN ANSWER. IF THE RESPONDENT DOES NOT DO SO, THE CASE WILL PROCEED WITHOUT THE RESPONDENT, AND THE COURT MAY MAKE AN ORDER AND ENFORCE IT AGAINST THE RESPONDENT.). That is exactly what occurred; however, the applicant’s pleas were ignored because the respondent father alleged—on multiple false grounds—that she was a danger to the children. Among other claims, he asserted that the applicant had “abducted” the children and had no legal authority to make decisions for them to move them from Kuwait.

9. On 22 March 2023—before the respondent had filed the required Answer and been properly added as a party—my former lawyer was served with an “urgent” motion and sworn affidavit from the respondent. The affidavit set out multiple false and misleading allegations. Under the Family Law Rules, the respondent was not entitled to bring any motion until he had responded to the application, and the issues raised did not satisfy the court’s urgency standard. I conveyed these objections to my lawyer, but the court does not permit a represented party to address the judge directly. Instead of striking the motion for procedural non‑compliance or lack of urgency, the court allowed it to proceed. A full hearing was eventually held, and on 16 February 2024 the trial judge dismissed all of the respondent’s claims and affirmed the applicant mother’s innocence. Aldahleh v. Zayed, 2024 ONSC 547 (CanLII), <https://canlii.ca/t/k3bl0>

10. At the motion hearing on 30 March 2023, the judge ordered the respondent to file his Answer but allowed the motion itself to proceed. The applicant was not permitted to address the court directly, and the judge declined to strike the motion despite the respondent’s failure to file his materials within the prescribed time—circumstances the applicant considers a miscarriage of justice. The applicant has already brought several motions to strike the respondent’s materials, but—appearing self‑represented—her submissions were not entertained. She nevertheless reserves, and is actively pursuing, her right on this motion to strike the respondent’s late‑filed materials.

11. About 1 August 2023, the applicant discovered that her former lawyer—without her knowledge or consent—had executed multiple consents permitting the respondent father to amend his Answer and rectify significant errors, without serving her with the related correspondence or consent forms. Further review revealed additional misleading and apparently fraudulent irregularities in the court file attributable to the same counsel.

12. A few days later, the applicant dismissed her lawyer and chose to proceed self‑represented, exercising her right under Ontario law to seek justice and protect her children and her own interests.

13. The applicant filed multiple motions to strike the respondent’s pleadings and requested an uncontested trial (Form 23C), but each application was summarily dismissed. She remains determined to vindicate her rights and rectify this miscarriage of justice.

14. On 16 February 2024, the Superior Court of Justice issued a judgment that cleared the applicant mother of all allegations at Aldahleh v. Zayed, 2024 ONSC 547 (CanLII), <https://canlii.ca/t/k3bl0> Despite the need—under Canadian law—for a prompt final order to protect her and the children from the respondent’s violence, the case was left open. The judgment required the father to file an amended Answer within 30 days at https://canlii.ca/t/k3bl0#par304 subtitle 3. “On a temporary basis:3. The Respondent shall have 30 days from the date of the service of this order upon him to file his Answer in this proceeding.”. But the respondent failed again to do so; instead, he dismissed both of his lawyers by the 15 March 2024 deadline, apparently to delay resolution and prolong his abuse.

15. On 19 March 2024, despite the applicant mother’s refusal to consent to a late filing, Justice Tobin ordered that “the respondent is granted leave to file his Answer, Forms 35.1 and 35.1A affidavits, and Financial Statement on or before 28 June 2024.” Attached in Schedule B – Tab# 02.

16. Nevertheless, the respondent again ignored the order and failed to file his Financial Statement by the 28 June 2024 deadline. Judge Sah confirmed this non‑compliance in the endorsement dated 9 July 2024, stating, “The respondent has not filed a Financial Statement as ordered.”. Attached in Schedule B – Tab# 03.

17. On 28 June 2024—four months after the trial judgment—the respondent filed an amended Answer that merely repeats issues already decided. He still asserts that the applicant abducted the children and seeks custody and their relocation to Kuwait, despite the court’s findings of his violence and the serious harm such a move would cause. The applicant, a Muslim woman who wears the niqab, is deeply concerned about the fairness of these proceedings and the prejudice she believes she has faced. She remains determined to expose what she regards as fraud and discrimination, including through her public petition at https://chng.it/7dV7zn2cDY

18. In addition, every affidavit sworn by the respondent contains untruths that ignore the solemnity of his oath, and the trial court’s judgment expressly found him lacking in credibility.

C. RESPONDENT CREDIBILITY DURING THE TRIAL AT SUPERIOR COURT OF JUSTICE:

19. 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]. “[42] For these reasons, where the evidence of the parties differ relating to the issues, I prefer the evidence of the mother unless otherwise stated.”.

20.  Although the trial judgment confirmed the father’s dishonesty—and recorded that the children had already refused to communicate with him before leaving Kuwait until this moment, a preference independently documented in the Office of the Children’s Lawyer affidavit filed in 2023—the applicant mother remains concerned that the continuing proceedings are wasting time and undermining justice. She and her children are entitled to settle in Canada without prejudice or needless delay, yet several judicial orders have, in her view, unjustly disregarded her legal rights. In addition, emails from the OCL confirm that the children do “not” wish to communicate with the respondent father. 

D. RESTRAINING ORDER:

 i. DEFAMATORY Statements Aimed at Destroying the Applicant’s Reputation:

21.  The respondent continues to contact various individuals—both known and unknown to me—in an effort to tarnish my reputation, drawing them into false and irrelevant allegations that they have no authority to resolve. I have received numerous e‑mails that document this ongoing pattern of defamation. Unfortunately, under paragraph 5(e) of Judge’s-J. Bezaire- order dated 25 February 2025, all filings must comply with the Provincial and Regional Practice Directions on page limits, font, and spacing, and my request for leave to exceed those limits was denied. Accordingly, only a representative sample of the respondent’s defamatory communications is appended to this affidavit; should this Honourable Court consider further documentation helpful, I am prepared to submit the balance upon receiving leave.

22. On 25 February 2025, I was copied (cc’d) on an e‑mail the respondent father sent to the principal of my children’s school, Al‑Taqwa Academy. The message read as follows, and a copy is attached as Schedule [A] Tab 01: 

Dear Ms. Kaloti,

1. Please keep in mind that I am always available to support my children—regardless of any parental disputes. I kindly ask you to focus on their development, interests, and activities, ensuring that their education and well-being remain the priority. It is important to ignore the unnecessary drama created by the Office of the Children’s Lawyer (OCL), which lacks the qualifications to properly assess or evaluate the situation. I have opposed and continue to oppose OCL’s involvement. Both OCL and Lubna have caused extreme harm to my children through their actions, prioritizing their own agendas over the children's well-being.

2. For the past three years, I have been the one pushing hard to enroll my children in an Islamic bilingual school to provide them with a proper education. Meanwhile, Lubna deliberately kept them in online schooling to maintain control over them and continue her efforts to manipulate and brainwash them. Her actions have been focused on isolation rather than their academic and personal growth.

3. This is the first time I am referring to parental disputes, and it is only due to the drama caused by Lubna and the OCL.

4. Below email was not written by my children. A 15-year-old and a 13-year-old would not naturally use such advanced language, structured arguments, and legal terminology without Lubna/adult influence. The wording, tone, and repeated emphasis on distress and discomfort suggest external coaching, likely from Lubna. Phrases such as "unforeseen circumstances," "oppression and distress," and references to "lawyers" and "not wanting to talk about personal matters" indicate an intentional effort to frame a legal argument.

5. This is not the first time—Lubna has previously manipulated the children, forcing Baraa to post messages on social media on her behalf and using Baraa’s mobile to receive and read court updates. This email is just another attempt to misrepresent their voices to be used in court later on.

6. Simply, in 2017, Lubna proposed moving to Canada solely to obtain Canadian citizenship and then returning to Kuwait. When I refused, she began planning and orchestrating the abduction. Her strategy involved alienating and brainwashing the children, falsely claiming abuse, and portraying herself as a victim in the Middle East. She has systematically exploited and manipulated the children to serve her personal goals.

7. As part of her plan, she deliberately cut off all communication between the children and me, as well as their siblings, friends, and extended family, to maintain control over them. She has filled their minds with falsehoods and fabrications while preventing them from learning the truth.

8. As per final court rulings in both Kuwait and Jordan—where Lubna was participated—I am the sole custodian, decision-maker, and legal guardian.

9. Till date, Lubna has actively prevented the children from receiving money, gifts, and other items that I have ordered and paid for.

10. She has worked persistently to involve the Office of the Children’s Lawyer (OCL), the Children’s Aid Society (CAS), psychologists, and various individuals and firms to fabricate false reports of abuse in an attempt to support her baseless claims. It is important to note that Lubna, not I, was the one who sought OCL’s involvement.

Best Regards,

Zakaria Zayed

23. On 15 September 2022, while I was employed at the London Muslim Mosque, I learned that my ex‑husband had contacted mosque officials and levelled false accusations intended to damage my reputation. In his message—attached as Schedule [A] Tab 02—he alleged that I was practising “taqeya” [sic] (a concept expressly forbidden in my Sunni Islamic tradition) and “brainwashing” the children. Although he claimed to be seeking help and advice, he explicitly asked that his correspondence be kept from me, confirming that his true aim was to harm my reputation. He has continued to spread similar slanders in other venues. The message read as follows:

From: Zakaria Zayed <XXgmail.com>
Sent: Thursday, September 15, 2022 4:26 PM
To: Secretary @ LMM <XXX@londonmosque.ca>
Subject: Advice

CONFIDENTIAL, please share it with EMAM only and do not participate any of the below with any one

Al Salamu Alaikum, 

With reference to our call conversation, I need the EMAM to advice my ex-wife to: 

1. Register our children in Bilingual school/London Islamic School and I will pay all fees.

2. Allow our children to participate in mrcssi, mosque, swimming, soccer ..…all useful activities to improve their personality and I will pay all fees.

3. Enable me and our children to communicate smoothly (she stopped all communications since she fled from Kuwait to Canada on July 2021)

4. Stop abusing and brainwash our kids and manipulate them against me. 

5. top “Taqeya” / fabricating stores and playing as a victim with some people and hero with others.

More details can be discussed over the phone.

If I can have a conference call with EMAM, it will be highly appreciated. 

Thanks in advance,

Zakaria

24. On multiple occasions in 2022, the respondent contacted the Children’s Aid Society and the MissingKids organization, falsely alleging that I had abducted the children. In these communications he repeated defamatory claims that I am an unfit mother, that I am using the children to obtain Canadian citizenship, and that I remain in Canada merely “to keep getting financial support” from the government. He also disparaged my religious faith—invoking my niqab to exploit anti‑Muslim sentiment—and wrote in one e‑mail dated July 13, 2022 (attached as Schedule [A] Tab 03) that the authorities should “rescue [the children] from their abusive, mentally disturbed mother, who believes she is descended from the holy bloodline of the Prophet Muhammad.” All of these allegations are entirely intended to damage my reputation.

25. Since the beginning of 2019, the father has systematically smeared the mother’s reputation through direct social-media communications with her friends, her first- and more distant-degree relatives (extending as far as Palestine), as well as with her acquaintances, family members, and her sisters’ husbands on a very wide scale. He even posted several defamatory messages about the mother at the University of Jordan, where her sister is a civil servant. In other words, the father disseminated insulting, reputation-damaging messages about the mother in Kuwait, Jordan, Palestine, and Canada. One of these messages is attached as evidence as Schedule [A] Tab 04) and named “Al-Muntaqim Al-Jabbar” (“The arrogant Avenger”). The message read as follows:

The woman whose name is Lubna, Umm al-Baraa, is an example of tyranny, rebellion, priests, and devils themselves cannot handle/control her, but Allah is watching over her..; she denies the husband and life whom the Messenger of Allah, peace be upon him, spoke about in the Prophet’s hadith: (Most of the people of Hell are women, because they disbelieve; It was said: Do they disbelieve in Allah? He said: They deny goodness of their husbands, and they deny kindness. If you were good to one of them all the time, and then she saw something bad from you; she said: I have never seen anything good from you.) The Messenger of Allah speaks the truth...

She is a person who is ungrateful to her husband and benevolence who has wronged herself, wronged her ex-husband, and wronged her children, claiming that she is oppressed and poor. She is the biggest oppressor on the face of the Earth and the biggest hypocrite who has spread discord in all homes and spread rumors, lies and stories. She cries in front of people to gain their sympathy and they believe her lies, and she writes films about her ex-husband so that they will side with her. She teaches her children to hate and grudge their father and does not allow them to communicate. She fled to Canada to achieve freedom and complete her tyranny, pride and injustice, to apply the laws of the infidels so that the laws of Islam and the Qur’an are not applied there. Do not believe her, for I swear to ALLAH Almighty that she is a liar and claims injustice and that she has the right. She has a sweet-speaking tongue to make her friends, relatives, family, and those around her believe her. She is making her children lost while they are still children.

26. What astonishes me is that he proclaims I am the worst woman in the world, and that my honeyed words are nothing but lies to deceive and mislead people. If this truly is the ‘truth’ he is broadcasting so widely around the globe, then why, on multiple occasions, has he compelled me to return as his wife?! I believe he needs psychological help, for he cannot accept the fact that he no longer has any authority or control over me. Praise be to Allah, I am now his EX-wife and no longer subject to his oppression and tyranny.

27. Nonetheless, I respectfully petition this honorable court to put an end to his persecution by ordering him to cease all contact with me and my children, and by suspending any judgments that allow him to access or share our personal information.

28. The most important point is his assertion that I fled to Canada to avoid the application of Islamic law here—which is completely contrary to everything I have pleaded since choosing to represent myself before this honorable court. It seems that the respondent takes advantages everywhere by spreading conflicts widely. I will never agree to the enforcement of any rule that conflicts with the law of my Lord. Unfortunately, I believe that my insistence on implementing my Lord’s Law is the very reason for the prejudice against me, but certainly I will never ever give up. Please give full consideration to the demands set forth in my petition at https://chng.it/7dV7zn2cDY

    i. Sexual Harassment Directed at the Child Mariam INCLUDING CAS Investigation Records:

29. On 27 July 2023, Justice Tobin of the Superior Court of Justice issued a final order directing that the Children’s Aid Society (CAS) records be disclosed to all parties. The endorsement is attached as Schedule B- Tab 05.

30. The investigations by CAS between 2021 to the end of 2023 confirmed the violence from the father. The closing letter dated July 31, 2023, was sent by the case worker to both parties to confirm that the children are safe with their mother, but not with the father. attached as Schedule A- Tab 05.

Dear Mr. Zayed: 

Re: Baraa Zayed, Lujain Zayed and Miriam Zayed 

I am writing to inform you that the Children's Aid Society of London & Middlesex has concluded its recent investigation with your family During the course of our involvement, concerns regarding you and your children were confirmed. However, ongoing service from the Society is not warranted at this time. 

Thank you for your cooperation with me during my involvement with your family. 

If you have any questions, please .... 

31.  The CAS disclosure for Investigation No. 12443448 consists of 42 pages. On page 3 of that disclosure (page 3 / 42 of the CAS record itself—it is attached as Schedule A- Tab 06), the “Eligibility Spectrum Coding” for Abusive Sexual Activity is recorded at the highest severity level, “Extremely,” and additional codes confirm other forms of violence attributed to the respondent father. This disclosure also verifies the ongoing risk he poses. Accordingly, the applicant requests that the complete CAS records for the period 2021 – 2023 be added to the court file in this matter.

32.  While still in Kuwait, the mother undertook several measures to protect the children from the father’s sexual and other violence but refrained from lodging a criminal court complaint because she did not want to put the children’s father in jail. Instead, she filed an internal complaint with the Parenting Centre, reporting the abuse to its counsellors and urgently requesting that visitation be transferred from his home to the Centre. Her efforts were thwarted by the father’s substantial influence—particularly his connections within the Ministry of the Interior—which impeded the normal protective process.

33. Beyond the respondent’s long record of violence, his sexual abuse of the children became the decisive factor in my relocating them to Canada for their safety. I had no supportive relatives in Kuwait, and each time I sought help I was told, “He is their father—he can do whatever he wants to them.” That attitude reflects a patriarchal culture, not our religion. To fulfil my moral duty before my Lord- ALLAH Almighty- I removed the children from that environment until they are old enough to protect themselves.

34. These concerns were first detailed in the applicant’s original Form 8 Application, dated 7 October 2022 and filed by her former lawyer, at paragraphs 32 to 34. She repeated them in her Amended Form 8, dated 18 October 2022, at paragraphs 38 to 40. Attached in Schedule B – Tab# 04.

35.   Unfortunately, Mariam is not the only child who has since disclosed further details of the respondent father’s sexual abuse. These concerns must not be ignored and should be fully considered by this Honourable Court.

ii. Harassment and Psychological Violence:

36. The respondent father continues to subject the mother and children to psychological abuse: he repeatedly claims she does not deserve to be a mother—or even to be considered human—and sends her messages accusing her of abducting the children, despite the judgment confirming her innocence and his violence. This pattern, which has persisted since 2008, prevents the family from leading a normal life. A restraining order is therefore required to halt his ongoing misconduct; video and written evidence documenting these incidents is available to the Court.

37. (This is an illustrative example—not an exhaustive list—intended to show the psychological persecution directed against the mother. The father sent a video of a woman in the United States who had been imprisoned, claiming that the criminal, Dalia Dippolito, is better than the mother, saying “She is still better than you. She does not talk and trade in religion, nor does she sell her children, her family, and her home for vile and cheap goals” and the proof is attached as Schedule A- Tab 07. In the subsequent message, the father comments on the mother’s profile picture—where she posted an image indicating that she follows the example of the Prophet’s wife, peace be upon him, Lady Aishah, may Allah be pleased with her—and he wrote “Are you not ashamed when you put this picture as a status? And distort religion and distort the name of Aisha, may ALLAH be pleased with her?”, then he sent: “Find a picture of Musaylimah and put it as your profile picture.”. “Just so you know, Musaylimah was a hypocrite who claimed to be Muslim. His story confirms that he hid his disbelief in order to mislead the Prophet (peace be upon him). ALLAH Almighty reassured our Prophet that Musaylimah was on the hill.”. But the point is who is the respondent father to issue like these statements against the mother! And what is the goal of focusing on her faith and believes even in his pleadings? “The complete certified translation, together with the original Arabic text, will be provided once the court permits exceeding the page limit.”.

 iii. Threats to Deprive the Applicant of Her Children—and the Children of Their Mother:

38. Over the years, the father has repeatedly threatened to take the children away from the mother and to bar her from seeing them should she petition for divorce. A certified translation of their dialogue attached as Schedule A- Tab 08; in it, the father threatens to deprive her of her children unless she leaves the State of Kuwait and returns to Jordan after filing her divorce petition in Kuwait. Meanwhile, he clandestinely imposed a travel ban on the children’s passports—placed without her knowledge—resulting in the mother’s detention at the airport when she attempted to travel. The full translation spans eleven pages, including the certificate of translation; however, due to page-limit restrictions it has been submitted separately. Should this honorable court permit the submission of all evidence, it will be provided forthwith.

Zakaria:…how do you leave your husband’s house without telling him you were going to the embassy?

Lubna: When there are lawsuits between us, I will surely protect myself. And when my husband signs and forges my signature, yes I will surely protect myself.

Zakaria: Ok, what do you want now? Do you want to take the children? Take them and travel with them.

Lubna: Really? I don’t want to travel

Zakaria:  Isn’t this what you want?

Lubna: I don’t want to travel, that’s none of your business.

Zakaria: Then ok stay here and hopefully – dear – dear – hopefully you won’t see them.

Lubna: Won’t see who?

Zakaria:  I hope you won’t see them

Lubna:  You mean my children?

Zakaria:  Take the children and leave -- and save what you still have of pride and dignity – take the children and take care of them, and keep the children and use them as protection for yourself. But if you want to disobey here in this country and make problems and [inaudible] talk, I will not let you here neither with children nor without them. I am not stupid. Don’t think I am not aware of what is going on. It is a shame, what you are doing is a shame.

Lubna: There is no way you can deprive me of my children

Zakaria:  Yes there is. There are a hundred ways. Depend on God.

Lubna:  You said --

Zakaria: I told you from day one, the custody is not going to affect me, but the acts you are doing [inaudible]

Lubna: You have always been threatening me about them [the children] – you have always been threatening me about them.

Zakaria: I don’t threaten, I don’t threaten, no, I don’t. I don’t threaten.

Lubna: I asked you a question, did you get new Canadian passports issued?

Zakaria: That’s none of your business, none of your business.

Lubna: None of my business?

Zakaria: No --

Lubna: So it is ok if I go file a lawsuit for forging my signature

Zakaria: Go do whatever you want, Lubna, ok?

Lubna:  Ok.

Zakaria: Go do whatever you want, Lubna.

Lubna: Ok.

Zakaria: Calm down and save what is left.

Lubna: Calm down?

Zakaria:  And save what is left

Lubna: The piece of spying, I didn’t file a spying lawsuit against you and it has been with me since the beginning of December. Calm down?

Zakaria: And I also have things --

RE: PARENTING TIME AND THE CHILDREN’S COMMUNICATION AND THEIR SITUATIONS:

39. attached as Schedule A- Tab 09), The email dated August 15, 2023, by the OCL who had investigated the case and he confirmed the following: “During the court appearance of July 31, 2023, I indicated to counsel that the children do not wish to communicate with the father at all. Our position has not changed, and at this time, we will not meet with them to ask the same question.”. 

40. (Attached VIDEO), The record video dated June 21, 2023, of one of the communications between the respondent father with the children to confirm the risk of his violent behavior toward the children by leading him to be very angry from his behaviors and his violence.

41. Aldahleh v. Zayed, 2024 ONSC 547 (CanLII), <https://canlii.ca/t/k3bl0> the evidence that the mother did not prevent the children from the communication with the father, but rather the father’s behaviours with them and his violence is the reason behind their trauma:

A. RISK OF PHYSICAL HARM:

42. https://canlii.ca/t/k3bl0#par268 [268] B. described to Ms. Heslop that L. and he were subject to physical discipline by the father. He would hit them. L. described the father as quick to anger.

43. https://canlii.ca/t/k3bl0#par269 [269] The three children were exposed to family violence between the mother and the father. For the reasons set out above, I accept the mother’s evidence that she was the victim of family violence from the father, as described in her evidence.

44. https://canlii.ca/t/k3bl0#par270 [270] L. described to Ms. Heslop an incident where the mother tried to return to the family apartment but the father did not want her to enter. During this incident, L.’s leg was caught in the door when she opened it for the mother and the father intervened to prevent the mother from coming inside. As well, there were some audio and video recordings admitted in evidence. They purported to show the children being upset while in the care of their father because of his behaviour towards them. The weight given to these exhibits is slight, as context was not clear.

45. https://canlii.ca/t/k3bl0#par271, [271] 

TO BE CONTINUED........