Meanwhile, the father—who is not Canadian but claims to be a Muslim of Palestinian origin, holds Jordanian citizenship, lives in Kuwait, has a U.S. Social Security number, and owns a Kuwaiti company that is a branch of a Toronto-based firm established in 2004 (a structure he uses to pursue Canadian citizenship without actually residing in Canada)—filed three lawsuits against the mother in February; all are set to be heard on 11 July 2025.
He argues that she should lose custody because she has ignored Canadian court orders, and—most seriously, in his view—comes from a “terrorist” family, since some of her relatives were Palestinian fighters. In reality, those fighters were defending their homeland, beliefs, and faith, refusing to surrender to the Zionists who occupied their land and expelled them for their devotion to their religion.
Yet the father himself has continued to break Canadian law—more and more since 2023—apparently without fear, thanks to his alleged Masonic supporters inside Canada. In my view, these supporters pose the real threat to Canada’s legal system. So far, no one has stopped them.
***********************
On 2 July 2025 at 2:35 p.m., the mother received an email from the father that read:
Dear All,
Please find attached the following documents, served in accordance with the Family Law Rules:
• Form 14A – Affidavit (Respondent - Zayed) dated 2 July 2025, with exhibits
• Form 14 – Notice of Motion (Respondent - Zayed) dated 2 July 2025.
Service of these materials violated paragraph 4 of Justice Bezaire’s 26 February 2025 order, which bars either party from bringing new motions until the outstanding special-appointment motions are heard.
***********************
At 4:47 p.m. the same day, the newly assigned lawyer for the Office of the Children’s Lawyer (OCL) replied to Mr Zayed:
Good afternoon Mr. Zayed:
I draw to your attention and remind you that the Honourable Justice Bezaire ordered (see para 4 of the attached endorsement) on February 26, 2025 that no further motions, aside from for the removal of the OCL, are permitted to be brought by the parties until the existing special appointment motions are dealt with.
The OCL will not take a substantive position on your new motion on July 11, but I will take the position that your new motion should either be ADJOURNED or dismissed pending the hearing of the already-filed motions.
If the OCL is not permitted to withdraw on the 11th, then it will be necessary for me to make renewed efforts to meet with the children alongside Ms. Heslop before I can confirm a position on your latest motion. I will therefore ask the court to adjourn your motion to a regular Wednesday motions date at least six weeks away if it is not being dismissed, and if the OCL is not being removed/allowed to withdraw on the 11th.
Yours truly,
***********************
Ooooooooooooooooooooh! As usual, all the professionals in this file are so cute, so kind, soooooooooooooo flexible about disobeying the Canadian Law by the Respondent Father (Zionist)!
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The father who claims that there is biased from the OCL to remove all of their previous material to REOPEN THE TRIAL after 2 years, reply:
Good afternoon Mr. Eric,
I thank you for your email. The motion is marked to be spoken to for the judge to address the matter.
Best Regards,
*****************************
Hahahahahaha. They play in the Canadian Law on their feet!
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On July 04, 2025, the mother served all the parties of cross-motion which is responding to the father's motion dated July 02, 2025. However, OCL's Lawyer replied immediately:
Good afternoon Ms. Zayed:
Please be advised that contempt motions must be served by special service, and cannot be served via e-mail, pursuant to Rule 31(2) of the Family Law Rules.
Motions are also required to be served at least six business days in advance.
The Office of the Children’s Lawyer does NOT consent to waive either of these requirements.
Yours truly
*******************
Ooooooooooooh! This is disappointing to hear that from a professional Lawyer who is licensed in Canada and should respect this esteemed government!
******************
The mother reply:
Hello Eric,
Please be advised that my name is Ms. Aldahleh, not Ms. Zayed. Second, please read carefully the subject of this email (RSPONDING MOTION) and the context of the material before judging or giving your opinion. Thank you for appointing that the respondent has not served the "contempt Order properly," as I was not served by special service at all.
Finally, please be advised that I, the Applicant Mother, do not consent to waive any of the requirements of following the rules of our esteemed government, either from your side or the respondent's side. I appreciate your email and your time in typing it.
The very truly,
*****************************
WHY?!
- Pursuant to Family Law Rules, O. Reg. 114-99, Rule (11), (11) A party making a motion with notice shall, (a) serve the documents mentioned in subrule (9) or (10) on all other parties, not later than six days before the motion date;...etc.
- Pursuant to Family Law Rules, O. Reg. 114-99, Rule (11.3), Response to notice of motion (11.3) A response by a person to a motion made using a notice of motion (Form 14) shall be served and filed not later than four days before the motion date. O. Reg. 298/18, s. 10 (2).
- The responding party must serve & file a response no later than 4 days before the motion date. IF THEY DID NOT, allows the moving party to ask that the motion be dealt with “without further notice,” and the judge may grant the orders requested on the material filed.
This proves how sneaky the new children’s lawyer is. He is trying to distract the mother with the new "illegal motion", hoping she will not reply to the father’s case—even though the father is openly breaking a judge’s order. He is also making things more complicated by filing several motions on the same issue in different ways to abuse the process in the court. They aim to stop anyone from filing a written objection in court, because a spoken objection will carry no weight—especially after the judge’s order of 26 February 2025 that bars it. In short, they are using every trick to secure orders that help themselves (not the children, as they pretend) and hurt the mother and the kids, relying on legal loopholes and the sway of influential people inside the court. Now, it is a long motion to discuss 5 cases at the same day, July 11, 2025.
******************************
On July 08, 2025, The mother received an email from the father to serve the OCL of the "contempt order motion" against the mother through "SPECIAL SERVE TO OCL not the mother" !!!!!!!!!! The service dated July 07, 2025. How ever, he serve her with "affidavit under the oath that they serve her through special service to deliver the document to her - handing service- which is NOT true!!!!!! It seems that the father realised that he need the OCL for another waste plan. Maybe he will try to withdraw his motion to remove the OCL?! "They need each other" :-)
I don't know if the mafia will be involved in this case as well!!!
********************
On July 09, 2025, the father again sent an email for all parties:
Good evening Mr. Eric,
Did you have a chance to thoroughly review all the emails and attachments I shared with the OCL since they were appointed in 2023? Best Regards,
*********************
WHAT IS THE FATHER'S MOTION REQUESTS?
Respondent's Form 14: Notice of Motion dated July 2, 2025
State the order or orders requested on this motion.
1. Abridging the time for service of this motion if necessary;
2. This motion be heard on an urgent base due to the Respondent having no parenting time with the children of the parties and the he resides in Kuwait.
3. Leave is granted for this motion to be spoken to at the July 11, 2025 special appointment hearing for motions by both parties specifically addressing parenting decision making and parenting time.
4. Appointing Ms. Lourdes Geraldo, MSW, RSW, AccFM, to conduct a section 30 assessment for parental decision-making-responsibility and parenting time for the children (Baraa Zakaria Zayed DoB October 21, 2010; Lujain Zakaria Zayed DoB November 6, 2012; Mariam Z. A. Zayed DoB October 11, 2018 with the parties.
5. Requiring both parties to immediately fully cooperate with the assessor that includes but is not limited to each of them completing intake documents, each party signing documents to retain the assessor, and each party attend appointments on time as scheduled, and the parties will support and ensure the children fully participate in the assessment according to the recommendations of the assessor.
6. The matter of the assessment shall return to court immediately in the event one or both parties and or one or all children do not follow the recommendations of the s.30 clinical assessor. In that instance, the clinical assessor may either provide the Court directly with a written update and/or appear personally with the parties to update the Court.
7. On a without prejudice basis to the Respondent, he shall be responsible to pay the professional fees of the assessor and the Court will re-apportion the professional fees paid for the assessment to both parties following the s.30 assessment being completed and filed with the court.
8. The Applicant shall pay the Respondent his costs for this motion on a full recovery basis.
9. Such further and other relief as the parties may advise and this Honourable Court may deem just.
************************************
Mmmmmmmmmmmm!
It seems that they not only closed the legal channels to expose their violation of the law, but also they are still trying to silence our voices by claiming mental health, or even created false reasons to take the children and silence our voices! They think that, but that will never happen!
*********************************
What is the mother's response-CROSS-MOTION?
Form 14: Notice of Motion _ APPLICANT CROSS-MOTION _ JULY 04, 2025
State the order or orders requested on this motion.
� ORDERS REGARDING RESPONDENT FATHER’S MOTION DATED JULY 02, 2025:
1. AN ORDER denying and restrict the Respondent’s request for any further parenting or psychological assessment—whether by the Office of the Children’s Lawyer, a section 30 assessor, or any other professional—on the grounds that:
(i) all parenting issues were conclusively resolved by the final Kuwaiti appellate orders and by the un-appealed judgment of the Superior Court of Justice dated 16 February 2024, rendered after a 16-day trial, which confirmed the Respondent’s history of violence in Kuwait and ordered that the children have no parenting time with him (a restriction that has remained in force from Kuwait to the present);
(ii) the Respondent has alleged no material change in circumstances;
(iii) any new assessment would be duplicative, disproportionate, and contrary to the child(ren)’s need for stability as articulated in section 24 of the Children’s Law Reform Act; and
(iv) pursuing such an assessment would constitute an abuse of this Court’s process.
2. AN ORDER, pursuant to sections 28, 35 and 36 of the Children’s Law Reform Act and rule 1(8) of the Family Law Rules, restraining the Respondent—who holds no decision-making responsibility—from representing to, contacting, or directing any third party (including schools, medical or dental providers, government agencies, extracurricular programs, and travel authorities) for the purpose of making, influencing, or arranging decisions about the child(ren), and directing such third parties to accept instructions only from the Applicant; any breach of this order to be enforceable forthwith, including by police assistance under s. 36. The respondent contacts the assessor mentioned in his current motion without any active decision-making responsibility order by the SJC or even active foreign order at the time of relocated the children to Canada, which is abusing the court processing and authority. The only current order to grant the decision-making responsibility over the children in this matter is the judgment order of 16-days trial dated Feb 16, 2024, which is active and enforced until this date.
3. AN ORDER declaring that the Respondent has abused the court’s process by swearing multiple affidavits containing materially false statements, and directing the Registrar to forward the Respondent’s sworn materials to the Attorney General of Ontario for investigation and possible prosecution for perjury (Criminal Code, s. 131) and obstruction of justice (s. 139); in particular, the Respondent averred under oath that his annual income is only $33,000, yet his own motion materials and exhibits show he is prepared to pay at least $20,000 for a private assessment—one of several pieces of evidence the Applicant will file to demonstrate that the Respondent’s affidavits are knowingly false and calculated to mislead the Court.
4. An order, pursuant to Rule 2.1.01(1) of the Rules of Civil Procedure R.R.O. 1990, Reg 194 of Courts of Justice Act, that the court may, on its own initiative, stay or dismiss a proceeding if the proceeding appears on its face to be frivolous or vexatious or otherwise an abuse of the process of the court. O. Reg. 43/14, s. 1.
a) In addition to the fact that, the respondent broke the court’s order dated Feb 26, 2025, that no one may file a new motion until the four motions set for the special-appointment hearing on 11 July 2025 are dealt with. Even so, he filed a new motion after the factum for that hearing had been submitted.
b) He also repeats in this new motion a request he first made on 17 February 2025; the court has not ruled on that earlier request yet, and it is already scheduled to be heard on 11 July 2025.
c) These actions show the court that he is abusing the court process to make the case more complicated, to harass the applicant mother, and to waste both the court’s time and the time the children could have with their mother—time she has devoted to defending against the father’s unfounded claims so that she can protect the children’s safety and stability in Canada and secure a fair, peaceful future for them.
5. An order, pursuant to Rule 2.1.02 (1) of the Rules of Civil Procedure O. Reg. 322_24, staying or dismissing a motion that appears on its face to be frivolous or vexatious or otherwise an abuse of the process of the court.
6. An order, pursuant to Rule 2.1.02 (3) of the Rules of Civil Procedure O. Reg. 322_24, restriction on further motions, the court may also make an order under rule 37.16 prohibiting the moving party from making further motions in the proceeding without leave.
7. An order, pursuant to Rule 1(8)-(b) of the Family Law Rules, dismissing the Respondent Father’s Motion dated July 02, 2025. Order dated February 26, 2025, by Justice Bezaire, at paragraph 4. “Pending the Special Appointment, no further Motions shall be brought, other than the one Motion.” This order remains in full force and effect. However, the respondent certainly broke this order in his unnecessary motion dated July 02, 2025.
8. An order, pursuant to Rule 1(8)-(c) of the Family Law Rules, striking out the Respondent’s notice of motion, affidavit, and or any other document filed and will be filed by the Respondent in this matter. Respondent Father failed to obey the SCJ’s order dated February 26, 2025 paragraph (4); he failed to obeying the order.
9. An order, pursuant to Rule 1(8.1) of the Family Law Rules, regarding the failure to follow rules by Respondent Father; If a person fails to follow these rules, the court may deal with the failure by making any order described in subrule (8), other than a contempt order under clause (8) (g). O. Reg. 322/13, s. 1.
10. An order, pursuant to Rule 1(8.2) of the Family Law Rules, strike out all or part of any document that may delay or make it difficult to have a fair trial or that is inflammatory, a waste of time, a nuisance or an abuse of the court process. O. Reg. 322/13, s. 1.
11. An order, supporting Notice of Contempt Notice, pursuant to Rule 1(8)-(g) of the Family Law Rules (contempt) a contempt order. O. Reg. 322/13, s. 1. The respondent father has continued to abuse the court process and to disobey orders issued by the Superior Court of Justice.
a) Order of Justice Bezaire dated 26 February 2025 paragraph 4. “Pending the Special Appointment, no further Motions shall be brought, other than the one Motion.” This order remains in full force and effect. Despite this direction, the respondent served the applicant mother with a new motion dated July 2, 2025, thereby breaching the order.
b) Order of Justice Bezaire dated 26 February 2025 paragraph 5-(e) All materials filed must fully comply with the Provincial and Regional Practice Direction including the required page limits, font, and line spacing. The party’s request for leave to exceed page limits is denied. This order remains in full force and effect. Despite the order:
c) the respondent filed materials for every motion set down for the special appointment on 11 July 2025, and each set exceeds the permitted page limits; and he failed to amend his original affidavit by the court-ordered deadline of 12 May 2025 so that it would comply with the same page-limit requirements.
12. An Order, pursuant to Rule 1(8)-(c) of the Family Law Rules, striking out the Respondent Father’s pleadings for noncompliance in order to provide disclosure; Including his answer dated April 11, 2023, his amended answer dated June 28, 2024, and his financial statement filed after March 16, 2023, or/and after June 28, 2024.
13. 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.
14. An Order, pursuant to section 35(1) of the Children’s Law Reform Act, to restrain the father from attending any location that the children and the mother is known to be if he comes to Canada.
15. An Order, pursuant to section 24 of the Children’s Law Reform Act, for consider the bast interests of the child; IT IS HEREBY ORDERED that every question of decision-making responsibility, parenting time, and contact raised by this motion shall be determined strictly in accordance with section 24 of the Children’s Law Reform Act (R.S.O. 1990, c. C.12), giving primary consideration to the child(ren)’s physical, emotional, and psychological safety, security, and well-being and considering all the factors listed in subsections 24(3)-(6); AND THE COURT NOTES that these parenting issues have already been conclusively resolved by (i) the final appellate orders of the Kuwaiti courts made before the family’s relocation to Canada and (ii) a 16-day trial of this Court that dismissed the father’s abduction allegations, so that no further reassessment is required.
16. An Order, pursuant to section 21.1 of the Children’s Law Reform Act, for Police records checks including RMPC to disclose records that may be in their possession with respect to any investigation in relation to the children and the Parties.
17. An Order, pursuant to section 21.2(2) of the Children’s Law Reform Act, for CAS to disclose records that may be in their possession with respect to any investigation in relation to the children and the Parties.
18. An Order, pursuant to section 21.3 of the Children’s Law Reform Act, for assessments of all the psychologists and therapists to disclose records that may be in their possession with respect to any investigation in relation to the children and the Parties.
19. An Order, pursuant to section 39.1 (3)&(4) of the Children’s Law Reform Act, that the notice requirements in subsections 39.1 (1) and (2) shall not apply to the Applicant’s proposed change of residence with the child(ren) [Baraa Zayed- B.O.D. October 21, 2010 / Lujain Zayed- D.O.B. November 06, 2012 / Mariam Zayed- D.O.B. October 11, 2018], and that the Applicant may relocate the child(ren) from [London, Ontario] on or after [July 11, 2025] without prior written notice to the Respondent, the Applicant’s new address and contact information to be filed under seal and withheld from the Respondent.
20. AN ORDER, pursuant to subsections 39.3 (3) and (4) of the Children’s Law Reform Act, that the 60-day relocation-notice requirements in subsections 39.3 (1) and (2) shall not apply to the Applicant’s proposed relocation, and that the Applicant may move the child(ren) [Baraa Zayed- B.O.D. October 21, 2010 / Lujain Zayed- D.O.B. November 06, 2012 / Mariam Zayed- D.O.B. October 11, 2018] from [London, Ontario] on or after [July 11, 2025] without prior written notice to the Respondent, the Applicant’s new address and contact details to be filed under seal.
21. AN ORDER, pursuant to sections 41, 44 and 45 of the Children’s Law Reform Act, for recognizing the Applicant Mother’s final orders, in the applicant’s amended application dated October 18, 2023, and in her reply by dated August 12, 2024, which granted in Kuwait at the final basis before moving to Canada; including the followings:
(i) recognizing and deeming to be orders of this Court all final Kuwaiti parenting, decision-making-responsibility, parenting-time and contact orders that were in full force and effect on 12 July 2021, the date the child(ren) relocated to Canada;
(ii) declaring those orders immediately enforceable in Ontario;
(iii) directing that the Court accept, without further proof, the attached certified true copies of each Kuwaiti order as evidence of their making and contents; and
(iv) providing that the Court take judicial notice of the applicable Kuwaiti law and tribunal decisions for the purpose of this recognition and enforcement.
22.
� ORDERS REGARDING OCL’S MOTION DATED JUNE 23, 2025:
23. An order, pursuant to Rule 2.1.01(1) of the Rules of Civil Procedure R.R.O. 1990, Reg 194 of Courts of Justice Act, that the court may, on its own initiative, stay or dismiss a proceeding if the proceeding appears on its face to be frivolous or vexatious or otherwise an abuse of the process of the court. O. Reg. 43/14, s. 1. There is purpose of involving the OCL based on the Courts of Justice Act, s. 112, which the OCL in this case failed to achieve it, this is current dispute before this honorable court in the motion set to be heard in a special appointment on July 11, 2025.
24. An order, pursuant to Rule 2.1.02 (1) of the Rules of Civil Procedure O. Reg. 322_24, staying or dismissing a motion that appears on its face to be frivolous or vexatious or otherwise an abuse of the process of the court.
25. An order, pursuant to Rule 1(8)-(b) of the Family Law Rules, dismissing the OCL’s Motion dated June 23, 2025. The (SCJ) Superior Court of Justice’s order dated February 26, 2025, by Justice Bezaire, at paragraph 5 (c), this order remains in full force and effect: “The Respondent party on each of the Motions shall serve and file their responding Motion materials for each of the Motions by no later then June 2, 2025. This includes any amendments to be made to the affidavit evidence previously filed.”. OCL failed to file anuy material by the deadline. In addition, OCL did not file any factum by the deadline determined at the same order mentioned in this paragraph by June 27, 2025.
26. An order, pursuant to Rule 1(8)-(c) of the Family Law Rules, striking out the OCL’s notice of motion, affidavit, and or any other document filed and will be filed by the OCL in this matter. OCL failed to obey the SCJ’s order dated February 26, 2025 by failure or filing the material by the deadlines.
27. An order, pursuant to Rule 1(8)-(d) of the Family Law Rules, that the materials of OCL which were required to be provided by June 02, 2025, but was not, may not be used in the case.
28. An order, pursuant to Rule 1(8.1) of the Family Law Rules, regarding the failure to follow rules by OCL; If a person fails to follow these rules, the court may deal with the failure by making any order described in subrule (8), other than a contempt order under clause (8) (g). O. Reg. 322/13, s. 1.
29. An order, pursuant to Rule 1(8.2) of the Family Law Rules, strike out all or part of any document that may delay or make it difficult to have a fair trial or that is inflammatory, a waste of time, a nuisance or an abuse of the court process. O. Reg. 322/13, s. 1.
30. Family Law Rules r. 1(8) and r. 1(8.1)– if a person “fails to obey an order” (or a mandatory rule) the court may make “any order it considers necessary,” including costs, striking documents or contempt. OCL did not comply with a mandatory rule 4(9) of the Family Law Rules, a party (including the Office of the Children’s Lawyer when it is “lawyer-of-record” for the child) must serve every other party and file a Form 4 if it changes lawyers or begins acting in person (Form 4 is mandatory). Serving Notice of Motion and Affidavit on June 23, 2025, is invalid because the lawyer is not on record. In addition, that they served the applicant mother in wrong address which is not in the record of the court. Also, OCL failed to provide this honourable court of full evidence regarding the psychologists’ reports who were involved with the children in this case, and the reports from Kuwait regarding this matter.
31. That the Court award costs of these motions to the Applicant, payable forthwith;
32. Such further and other relief as the Applicant Mother may advise and this Honourable Court deem just.
***********************************
Both of OCL and Respondent failed to serve and file confirmation of motion, so pursuant the Family Law Rules, O. Reg. 114-99 says:
Effect of failure to confirm
(11.1) Unless the court orders otherwise, a motion shall not be heard if confirmation of the motion is not given to the clerk in accordance with clause (11) (e). O. Reg. 298/18, s. 10 (2).
HOWEVER, when the original moving party fails to file Form 14C but the responding party has filed a cross-motion and its own Form 14C
The cross-motion turns me into the “moving party” for that motion.
r. 14(14) – a notice of cross-motion is simply another Form 14 issued by the respondent and is governed by the same deadlines (service ≥ 4 days before, confirmation by 2 p.m. three business days before).
WHICH I DID!
DOES THE SUPERIOR COURT OF JUSTICE WILL RESPECT THE LAW THIS TIME, OR THEY WILL CONTINUE TO ABUSE THE RULES BY THEIR AUTHORITIES?
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WHAT ID THE ORDERS FILED BY THE MOTHER IN THE CONFIRMATION? WILL THE COURT RESPECT THE RELIGION AS THE
Form 14C: Confirmation of Motion – Set on 11 JULY 2025 / APPLICANT MOTHER - DATED: JULY 08, 2025
What specific orders are you seeking on this motion? (List the specific orders below)
1. AN ORDER that Sunni Islamic law be applied to my children and their descendants in Canada for everything related to their family relationships— including financial matters arising from marriage, inheritance, rights between the spouses and their children, the lawful age of marriage under Sunni rules, wills, and guardianship……etc. — with all rulings and orders issued by qualified Sunni Muslim imams, without ever having to go to Canadian courts or be subject to them.
2. AN ORDER denying and restrict the Respondent’s request for any further parenting or psychological assessment—whether by the Office of the Children’s Lawyer, a section 30 assessor, or any other professional.
3. AN ORDER, pursuant to sections 28, 35 and 36 of the Children’s Law Reform Act and rule 1(8) of the Family Law Rules, restraining the Respondent—who holds no decision-making responsibility—from representing to, contacting, or directing any third party (including schools, medical or dental providers, government agencies, extracurricular programs, and travel authorities) for the purpose of making, influencing, or arranging decisions about the child(ren), and directing such third parties to accept instructions only from the Applicant; any breach of this order to be enforceable forthwith, including by police assistance under s. 36.
4. AN ORDER declaring that the Respondent has abused the court’s process by swearing multiple affidavits containing materially false statements, and directing the Registrar to forward the Respondent’s sworn materials to the Attorney General of Ontario for investigation and possible prosecution for perjury (Criminal Code, s. 131) and obstruction of justice (s. 139)
5. An order, pursuant to Rule 2.1.01(1) of the Rules of Civil Procedure R.R.O. 1990, Reg 194 of Courts of Justice Act, that the court may, on its own initiative, stay or dismiss a proceeding if the proceeding appears on its face to be frivolous or vexatious or otherwise an abuse of the process of the court. O. Reg. 43/14, s. 1.
6. An order, pursuant to Rule 2.1.02 (1) of the Rules of Civil Procedure O. Reg. 322_24, staying or dismissing a motion that appears on its face to be frivolous or vexatious or otherwise an abuse of the process of the court. An order, dismissing the OCL’s Motion dated June 23, 2025. And dismissing the Respondent’s Motions dated July 02, 2025, and dated February 17, 2025 and May 12, 2025.
7. An order, pursuant to Rule 2.1.02 (3) of the Rules of Civil Procedure O. Reg. 322_24, restriction on further motions, the court may also make an order under rule 37.16 prohibiting the moving party from making further motions in the proceeding without leave.
8. An order, pursuant to Rule 1(8)-(b) of the Family Law Rules, dismissing the Respondent Father’s Motion.
9. An order, pursuant to Rule 1(8)-(c) of the Family Law Rules, striking out the Respondent’s notice of motion, affidavit, and or any other document filed and will be filed by the Respondent in this matter.
10. An order, pursuant to Rule 1(8.2) of the Family Law Rules, strike out all or part of any document that may delay or make it difficult to have a fair trial or that is inflammatory, a waste of time, a nuisance or an abuse of the court process. O. Reg. 322/13, s. 1.
11. An Order, pursuant to Rule 1(8)-(c) of the Family Law Rules, striking out the Respondent Father’s pleadings for noncompliance in order to provide disclosure; Including his answer dated April 11, 2023, his amended answer dated June 28, 2024, and his financial statement filed after March 16, 2023, or/and after June 28, 2024.
12. 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.
13. An Order, pursuant to section 35(1) of the Children’s Law Reform Act, to restrain the father from attending any location that the children and the mother is known to be if he comes to Canada.
14. An Order, pursuant to section 21.1 of the Children’s Law Reform Act, for Police records checks including RMPC to disclose records that may be in their possession with respect to any investigation in relation to the children and the Parties.
15. An Order, pursuant to section 21.2(2) of the Children’s Law Reform Act, for CAS to disclose records that may be in their possession with respect to any investigation in relation to the children and the Parties.
16. An Order, pursuant to section 21.3 of the Children’s Law Reform Act, for assessments of all the psychologists and therapists to disclose records that may be in their possession with respect to any investigation in relation to the children and the Parties.
17. An Order, pursuant to section 39.1 (3)&(4) of the Children’s Law Reform Act, that the notice requirements in subsections 39.1 (1) and (2) shall not apply to the Applicant’s proposed change of residence with the child(ren) [Baraa Zayed- B.O.D. October 21, 2010 / Lujain Zayed- D.O.B. November 06, 2012 / Mariam Zayed- D.O.B. October 11, 2018], and that the Applicant may relocate the child(ren) from [London, Ontario] on or after [July 11, 2025] without prior written notice to the Respondent, the Applicant’s new address and contact information to be filed under seal and withheld from the Respondent.
18. AN ORDER, pursuant to subsections 39.3 (3) and (4) of the Children’s Law Reform Act, that the 60-day relocation-notice requirements in subsections 39.3 (1) and (2) shall not apply to the Applicant’s proposed relocation, and that the Applicant may move the child(ren) [Baraa Zayed- B.O.D. October 21, 2010 / Lujain Zayed- D.O.B. November 06, 2012 / Mariam Zayed- D.O.B. October 11, 2018] from [London, Ontario] on or after [July 11, 2025] without prior written notice to the Respondent, the Applicant’s new address and contact details to be filed under seal.
19. AN ORDER, pursuant to sections 41, 44 and 45 of the Children’s Law Reform Act, for recognizing the Applicant Mother’s final orders, in the applicant’s amended application dated October 18, 2023, and in her reply by dated August 12, 2024, which granted in Kuwait at the final basis before moving to Canada; including the followings:
a. recognizing and deeming to be orders of this Court all final Kuwaiti parenting, decision-making-responsibility, parenting-time and contact orders that were in full force and effect on 12 July 2021, the date the child(ren) relocated to Canada;
b. declaring those orders immediately enforceable in Ontario;
c. directing that the Court accept, without further proof, the attached certified true copies of each Kuwaiti order as evidence of their making and contents; and
d. providing that the Court take judicial notice of the applicable Kuwaiti law and tribunal decisions for the purpose of this recognition and enforcement.
20. An order, pursuant to Rule 2.1.01(1) of the Rules of Civil Procedure R.R.O. 1990, Reg 194 of Courts of Justice Act, that the court may, on its own initiative, stay or dismiss a proceeding if the proceeding appears on its face to be frivolous or vexatious or otherwise an abuse of the process of the court. O. Reg. 43/14, s.
21. An order, pursuant to Rule 1(8)-(c) of the Family Law Rules, striking out the OCL’s notice of motion, affidavit, and or any other document filed and will be filed by the OCL in this matter. OCL failed to obey the SCJ’s order dated February 26, 2025 by failure or filing the material by the deadlines.
22. An order, pursuant to Rule 1(8)-(d) of the Family Law Rules, that the materials of OCL which were required to be provided by June 02, 2025, but was not, may not be used in the special appointment.
23. An order, pursuant to Rule 1(8.1) of the Family Law Rules, regarding the failure to follow rules by OCL; If a person fails to follow these rules, the court may deal with the failure by making any order described in subrule (8), other than a contempt order under clause (8) (g). O. Reg. 322/13, s. 1.
24. An order, pursuant to Rule 1(8.2) of the Family Law Rules, strike out all or part of any document that may delay or make it difficult to have a fair trial or that is inflammatory, a waste of time, a nuisance or an abuse of the court process. O. Reg. 322/13, s. 1.
25. Family Law Rules r. 1(8) and r. 1(8.1)– if a person “fails to obey an order” (or a mandatory rule) the court may make “any order it considers necessary,” including costs, striking documents or contempt. OCL did not comply with a mandatory rule 4(9) of the Family Law Rules, a party (including the Office of the Children’s Lawyer when it is “lawyer-of-record” for the child) must serve every other party and file a Form 4 if it changes lawyers or begins acting in person (Form 4 is mandatory). Serving Notice of Motion and Affidavit on June 23, 2025, is invalid because the lawyer is not on record. In addition, that they served the applicant mother in wrong address which is not in the record of the court. Also, OCL failed to provide this honourable court of full evidence regarding the psychologists’ reports who were involved with the children in this case, and the reports from Kuwait regarding this matter.
26. Pursuant to Rules 1(8)(c) and (d) and 1(8.1) of the Family Law Rules, I ask that all pages in excess of the Practice-Direction caps be struck and that the respondent be prohibited from relying on them at the Special Appointment.
27. Pursuant to Courts of Justice Act, R.R.O. 1990, REGULATION 194 RULES OF CIVIL PROCEDURE RULE 2.1 FRIVOLOUS, VEXATIOUS OR ABUSIVE PROCEEDINGS / 2.1.01 (1) The court may make an order staying or dismissing a proceeding that appears on its face to be frivolous or vexatious or otherwise an abuse of the process of the court. O. Reg. 322/24, s. 1.
28. An order, pursuant to s. 89(3.1) & s. 112 Courts of Justice Act, to that all interim orders appointing or continuing the Office of the Children’s Lawyer (OCL)—namely Justice Tobin’s order of May 26 2023, Justice of the Peace Howard’s order of October 24 2024, Justice Tobin’s order of January 23 2025, Justice Bezair’s order of February 26 2025, and any other order addressing OCL involvement in this proceeding—are hereby set aside insofar as they relate to any future involvement of the OCL; that the OCL is discharged on a final basis, effective immediately; and that all reports, notes, affidavits, and other materials previously filed by the OCL shall remain part of the court record and may be relied upon by the parties and the Court.
29. 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, and he did not initially serve his answer of the original application “Form 08” filed on October 07, 2022, and served officially to the oppose party on January 26, 2023.
30. An Order, pursuant to section 21.2(2) CLRA for CAS and all psychological assessments to disclose records and reports that may be in their possession with respect to any investigation in relation to the children and the Parties, and any more witnesses if necessary for this matter.
31. Under the Family Law Rules (O. Reg. 114/99), the child. Rule 12(1) states: “In a proceeding under these rules, the court may interview a child in private if it considers the interview necessary to determine what order would be in the best interests of the child.”. The children must be heard before the court without adding more prejudice to this case.
32. That the Court award costs of all these motions (5 Motions) to the Applicant, payable forthwith;
33. Such further and other relief as the Applicant Mother may advise and this Honourable Court deem just.
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WHAT ID THE OCL'S MOTION DATED JUNE 23, 2025, FOR:
State the order or orders requested on this motion.
1. An order that the Order of the Honourable Mr. Justice Tobin dated May 26, 2023, requesting the involvement of the Office of the Children’s Lawyer in these proceedings shall be terminated.
2. An order removing the Office of the Children’s Lawyer, and Justice Kimberly Doucett who has now been appointed to the Ontario Court of Justice, and Eric Vallillee as counsel of record for the children, Lujain Zakaria Zayed, born 6 Nov 2012, Baraa, Zakaria Zayed, born 21 Oct 2010, and Mariam Zayed, born 11 October 2018.
3. An order that the motion of the Respondent, Zakaria Zayed, returnable July 11, 2025 with respect to the involvement of the Office of the Children’s Lawyer and with respect to the striking of materials filed by the Office of the Children’s Lawyer shall be dismissed.
4. An order for such other and further relief as may be requested by Eric Vallillee and the Office of the Children’s Lawyer, and as this Honourable Court may deem just.
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However, OCL serve me not in my official email (which is added in the court record)? Also, he addresses a different address than mine, which is increase the concerns that the official employees "meant" to abuse the proper process, to complicate the matter and add more delays against the children's interest. From where he brought my previous address which I did not use it in the court materials?
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The mother's Responding affidavit. Form 14A: Applicant’s RESPONDING Affidavit (General)- Support CROSS-Motion July 04, 2025
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 “RESPONDING” to the Respondent’s (Notice of Motion) and affidavit dated JULY 02, 2025, which I oppose it at all. In addition to the OCL’s Notice of Motion dated June 23, 2025, including a third party’s affidavit who is not involve in this case, Form 14A - Affidavit of S Scott - OCL - Zayed -20-JUNE-2025.
2. I attach two exhibits, one is Justice Bezaire’s Order dated 26 February 2025 and the second is my Reply Affidavit sworn 27 June 2025, together with all of its exhibits, in responding to the respondent father’s motion. I respectfully ask the Court to treat the father’s present requests as grounds for a finding of CONTEMPT and to stay or dismiss his motion as frivolous, vexatious, and an abuse of process. The issues he raises are already scheduled for the Special Appointment on 11 July 2025 under his motion dated 17 February 2025. His new filing, presented in a different form and various channel, therefore breaches earlier Court orders and needlessly complicates these proceedings. At paragraph 2 of Justice Bezaire’s Order dated 26 February 2025 order:
2. A Special Appointment has been set for July 11, 2025, at 10 a.m. (full day) to take place virtually. Four Motions shall be heard at the Special Appointment as follows:
a) Motion by the Applicant for ancillary relief (Motion Form dated February 20, 2025); b) Motion by the Respondent for a Contempt Order (Motion Form dated February 17, 2025); c) Motion by the Respondent for ancillary relief (Motion Form also dated February 17, 2025); and d) Motion to be brought by the Respondent got the sole relief of removing the Office of the Children’s Lawyer and excluding any evidence of the Office of the Children’s Lawyer.
3. Moreover, in paragraph 8 of his draft order he seeks “full-recovery” costs against me, even though paragraph 7 of the same notice states—without prejudice—that he will bear the assessor’s professional fees pending any later re-apportionment. A full-recovery award would force me to reimburse those assessment fees—estimated at no less than $20,000—despite there being no legal basis for a fresh assessment: the children were fully assessed in Kuwait and have completed the required steps in Canada, and the delay by the Office of the Children’s Lawyer (now far beyond its own 90- to 120-day service window since 26 May 2023) is not the fault of the children or of me. This contradictory request is a further attempt to exert financial pressure on the applicant and the children and should be dismissed.
4. I have attached, as exhibits to this affidavit, every prior order and expert report in this case, all of which confirm that the father was violent toward the family and that the children have steadfastly resisted contact with him for many years—findings the Canadian trial also upheld. His latest demand for yet another psychological assessment of the mother and children—an issue he has raised again and again since 2019—has no legal basis or supporting evidence and serves only to harass us and complicate these proceedings. The Court’s continued disregard of the clear evidence I have provided creates a genuine fear of racism and corruption in the justice system toward Canadian Muslims who practise their faith. Please review the judgment at Aldahleh v. Zayed, 2024 ONSC 547 (CanLII), <https://canlii.ca/t/k3bl0>
5. I have attached, as exhibits to this affidavit, (a) every prior order and expert report—each of which confirms the father’s violence toward the family and the children’s long-standing refusal to see him, findings upheld at the Canadian trial in February 2024; and (b) the children’s current report cards, which show they are thriving at school and clearly settled in Canada. Yet, even after the trial ended in February 2024, the case keeps dragging on and the Court has so far ignored the evidence that favours the children and me. This delay, combined with the father’s latest bid for another needless assessment, raises the same concerns about anti-Muslim bias in government institutions that were highlighted in the recent Canadian Senate report on systemic racism. It appears that the discrimination identified in that report is playing out here, blocking me from exercising my rights and from overturning unfair, discriminatory orders.
6. I swear this affidavit in support of (a) my Notice of Motion filed today, which seeks to oppose the respondent father’s motion dated 3 July 2025 and the Office of the Children’s Lawyer’s motion dated 23 June 2025, and (b) my related Notice of Motion for a contempt order, for the following reasons:
7. Pursuant to Rule 1(8)-(b) of the Family Law Rules, dismissing the Respondent Father’s Motion dated July 02, 2025. Order dated February 26, 2025, by Justice Bezaire, at paragraph 4. “Pending the Special Appointment, no further Motions shall be brought, other than the one Motion.” This order remains in full force and effect. However, the respondent certainly broke this order in his unnecessary motion dated July 02, 2025.
8. Pursuant to Rule 1(8)-(c) of the Family Law Rules, striking out the Respondent’s notice of motion, affidavit, and or any other document filed and will be filed by the Respondent in this matter. Respondent Father failed to obey the SCJ’s order dated February 26, 2025 paragraph (4); he failed to obeying the order.
9. Pursuant to Rule 1(8.1) of the Family Law Rules, regarding the failure to follow rules by Respondent Father; If a person fails to follow these rules, the court may deal with the failure by making any order described in subrule (8), other than a contempt order under clause (8) (g). O. Reg. 322/13, s. 1.
10. Pursuant to Rule 1(8)-(g) of the Family Law Rules (contempt) a contempt order. O. Reg. 322/13, s. 1. The respondent father has continued to abuse the court process and to disobey orders issued by the Superior Court of Justice.
a) Order of Justice Bezaire dated 26 February 2025 paragraph 4. “Pending the Special Appointment, no further Motions shall be brought, other than the one Motion.” This order remains in full force and effect. Despite this direction, the respondent served the applicant mother with a new motion dated July 2, 2025, thereby breaching the order. b) Order of Justice Bezaire dated 26 February 2025 paragraph 5-(e) All materials filed must fully comply with the Provincial and Regional Practice Direction including the required page limits, font, and line spacing. The party’s request for leave to exceed page limits is denied. This order remains in full force and effect. Despite the order: c) the respondent filed materials for every motion set down for the special appointment on 11 July 2025, and each set exceeds the permitted page limits; and he failed to amend his original affidavit by the court-ordered deadline of 12 May 2025 so that it would comply with the same page-limit requirements.
11. Declaring that the Respondent has abused the court’s process by swearing multiple affidavits containing materially false statements, and directing the Registrar to forward the Respondent’s sworn materials to the Attorney General of Ontario for investigation and possible prosecution for perjury (Criminal Code, s. 131) and obstruction of justice (s. 139); in particular, the Respondent averred under oath that his annual income is only $33,000, yet his own motion materials and exhibits show he is prepared to pay at least $20,000 for a private assessment—one of several pieces of evidence the Applicant will file to demonstrate that the Respondent’s affidavits are knowingly false and calculated to mislead the Court.
12. Pursuant to sections 28, 35 and 36 of the Children’s Law Reform Act and rule 1(8) of the Family Law Rules, restraining the Respondent—who holds no decision-making responsibility—from representing to, contacting, or directing any third party (including schools, medical or dental providers, government agencies, extracurricular programs, and travel authorities) for the purpose of making, influencing, or arranging decisions about the child(ren), and directing such third parties to accept instructions only from the Applicant; any breach of this order to be enforceable forthwith, including by police assistance under s. 36. The respondent contacts the assessor mentioned in his current motion without any active decision-making responsibility order by the SJC or even active foreign order at the time of relocated the children to Canada, which is abusing the court processing and authority. The only current order to grant the decision-making responsibility over the children in this matter is the judgment order of 16-days trial dated Feb 16, 2024, which is active and enforced until this date.
13. Denying and restrict the Respondent’s request for any further parenting or psychological assessment—whether by the Office of the Children’s Lawyer, a section 30 assessor, or any other professional—on the grounds that:
(i) all parenting issues were conclusively resolved by the final Kuwaiti appellate orders and by the un-appealed judgment of the Superior Court of Justice dated 16 February 2024, rendered after a 16-day trial, which confirmed the Respondent’s history of violence in Kuwait and ordered that the children have no parenting time with him (a restriction that has remained in force from Kuwait to the present); (ii) the Respondent has alleged no material change in circumstances; (iii) any new assessment would be duplicative, disproportionate, and contrary to the child(ren)’s need for stability as articulated in section 24 of the Children’s Law Reform Act; and (iv) pursuing such an assessment would constitute an abuse of this Court’s process.
14. Pursuant to Rule 2.1.01(1) of the Rules of Civil Procedure R.R.O. 1990, Reg 194 of Courts of Justice Act, that the court may, on its own initiative, stay or dismiss a proceeding if the proceeding appears on its face to be frivolous or vexatious or otherwise an abuse of the process of the court. O. Reg. 43/14, s. 1.
a) In addition to the fact that, the respondent broke the court’s order dated Feb 26, 2025, that no one may file a new motion until the four motions set for the special-appointment hearing on 11 July 2025 are dealt with. Even so, he filed a new motion after the factum for that hearing had been submitted. b) He also repeats in this new motion a request he first made on 17 February 2025; the court has not ruled on that earlier request yet, and it is already scheduled to be heard on 11 July 2025. c) These actions show the court that he is abusing the court process to make the case more complicated, to harass the applicant mother, and to waste both the court’s time and the time the children could have with their mother—time she has devoted to defending against the father’s unfounded claims so that she can protect the children’s safety and stability in Canada and secure a fair, peaceful future for them.
15. An order, pursuant to Rule 2.1.02 (1) of the Rules of Civil Procedure O. Reg. 322_24, staying or dismissing a motion that appears on its face to be frivolous or vexatious or otherwise an abuse of the process of the court.
16. An order, pursuant to Rule 2.1.02 (3) of the Rules of Civil Procedure O. Reg. 322_24, restriction on further motions, the court may also make an order under rule 37.16 prohibiting the moving party from making further motions in the proceeding without leave.
17. An Order, pursuant to Rule 1(8)-(c) of the Family Law Rules, striking out the Respondent Father’s pleadings for noncompliance in order to provide disclosure; Including his answer dated April 11, 2023, his amended answer dated June 28, 2024, and his financial statement filed after March 16, 2023, or/and after June 28, 2024.
18. 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.
19. An Order, pursuant to section 35(1) of the Children’s Law Reform Act, to restrain the father from attending any location that the children and the mother is known to be if he comes to Canada.
20. An Order, pursuant to section 24 of the Children’s Law Reform Act, for consider the bast interests of the child; IT IS HEREBY ORDERED that every question of decision-making responsibility, parenting time, and contact raised by this motion shall be determined strictly in accordance with section 24 of the Children’s Law Reform Act (R.S.O. 1990, c. C.12), giving primary consideration to the child(ren)’s physical, emotional, and psychological safety, security, and well-being and considering all the factors listed in subsections 24(3)-(6); AND THE COURT NOTES that these parenting issues have already been conclusively resolved by (i) the final appellate orders of the Kuwaiti courts made before the family’s relocation to Canada and (ii) a 16-day trial of this Court that dismissed the father’s abduction allegations, so that no further reassessment is required.
21. An Order, pursuant to section 21.1 of the Children’s Law Reform Act, for Police records checks including RMPC to disclose records that may be in their possession with respect to any investigation in relation to the children and the Parties.
22. An Order, pursuant to section 21.2(2) of the Children’s Law Reform Act, for CAS to disclose records that may be in their possession with respect to any investigation in relation to the children and the Parties.
23. An Order, pursuant to section 21.3 of the Children’s Law Reform Act, for assessments of all the psychologists and therapists to disclose records that may be in their possession with respect to any investigation in relation to the children and the Parties.
24. An Order, pursuant to section 39.1 (3)&(4) of the Children’s Law Reform Act, that the notice requirements in subsections 39.1 (1) and (2) shall not apply to the Applicant’s proposed change of residence with the child(ren) [Baraa Zayed- B.O.D. October 21, 2010 / Lujain Zayed- D.O.B. November 06, 2012 / Mariam Zayed- D.O.B. October 11, 2018], and that the Applicant may relocate the child(ren) from [London, Ontario] on or after [July 11, 2025] without prior written notice to the Respondent, the Applicant’s new address and contact information to be filed under seal and withheld from the Respondent.
25. AN ORDER, pursuant to subsections 39.3 (3) and (4) of the Children’s Law Reform Act, that the 60-day relocation-notice requirements in subsections 39.3 (1) and (2) shall not apply to the Applicant’s proposed relocation, and that the Applicant may move the child(ren) [Baraa Zayed- B.O.D. October 21, 2010 / Lujain Zayed- D.O.B. November 06, 2012 / Mariam Zayed- D.O.B. October 11, 2018] from [London, Ontario] on or after [July 11, 2025] without prior written notice to the Respondent, the Applicant’s new address and contact details to be filed under seal.
26. AN ORDER, pursuant to sections 41, 44 and 45 of the Children’s Law Reform Act, for recognizing the Applicant Mother’s final orders, in the applicant’s amended application dated October 18, 2023, and in her reply by dated August 12, 2024, which granted in Kuwait at the final basis before moving to Canada; including the followings:
(i) recognizing and deeming to be orders of this Court all final Kuwaiti parenting, decision-making-responsibility, parenting-time and contact orders that were in full force and effect on 12 July 2021, the date the child(ren) relocated to Canada;
(ii) declaring those orders immediately enforceable in Ontario;
(iii) directing that the Court accept, without further proof, the attached certified true copies of each Kuwaiti order as evidence of their making and contents; and
(iv) providing that the Court take judicial notice of the applicable Kuwaiti law and tribunal decisions for the purpose of this recognition and enforcement.
v ORDERS REGARDING OCL’S MOTION DATED JUNE 23, 2025:
27. An order, pursuant to Rule 2.1.01(1) of the Rules of Civil Procedure R.R.O. 1990, Reg 194 of Courts of Justice Act, that the court may, on its own initiative, stay or dismiss a proceeding if the proceeding appears on its face to be frivolous or vexatious or otherwise an abuse of the process of the court. O. Reg. 43/14, s. 1. There is purpose of involving the OCL based on the Courts of Justice Act, s. 112, which the OCL in this case failed to achieve it, this is current dispute before this honorable court in the motion set to be heard in a special appointment on July 11, 2025.
28. An order, pursuant to Rule 2.1.02 (1) of the Rules of Civil Procedure O. Reg. 322_24, staying or dismissing a motion that appears on its face to be frivolous or vexatious or otherwise an abuse of the process of the court.
29. An order, pursuant to Rule 1(8)-(b) of the Family Law Rules, dismissing the OCL’s Motion dated June 23, 2025. The (SCJ) Superior Court of Justice’s order dated February 26, 2025, by Justice Bezaire, at paragraph 5 (c), this order remains in full force and effect: “The Respondent party on each of the Motions shall serve and file their responding Motion materials for each of the Motions by no later then June 2, 2025. This includes any amendments to be made to the affidavit evidence previously filed.”. OCL failed to file anuy material by the deadline. In addition, OCL did not file any factum by the deadline determined at the same order mentioned in this paragraph by June 27, 2025.
30. An order, pursuant to Rule 1(8)-(c) of the Family Law Rules, striking out the OCL’s notice of motion, affidavit, and or any other document filed and will be filed by the OCL in this matter. OCL failed to obey the SCJ’s order dated February 26, 2025 by failure or filing the material by the deadlines.
31. An order, pursuant to Rule 1(8)-(d) of the Family Law Rules, that the materials of OCL which were required to be provided by June 02, 2025, but was not, may not be used in the case.
32. An order, pursuant to Rule 1(8.1) of the Family Law Rules, regarding the failure to follow rules by OCL; If a person fails to follow these rules, the court may deal with the failure by making any order described in subrule (8), other than a contempt order under clause (8) (g). O. Reg. 322/13, s. 1.
33. An order, pursuant to Rule 1(8.2) of the Family Law Rules, strike out all or part of any document that may delay or make it difficult to have a fair trial or that is inflammatory, a waste of time, a nuisance or an abuse of the court process. O. Reg. 322/13, s. 1.
34. Family Law Rules r. 1(8) and r. 1(8.1)– if a person “fails to obey an order” (or a mandatory rule) the court may make “any order it considers necessary,” including costs, striking documents or contempt. OCL did not comply with a mandatory rule 4(9) of the Family Law Rules, a party (including the Office of the Children’s Lawyer when it is “lawyer-of-record” for the child) must serve every other party and file a Form 4 if it changes lawyers or begins acting in person (Form 4 is mandatory). Serving Notice of Motion and Affidavit on June 23, 2025, is invalid because the lawyer is not on record. In addition, that they served the applicant mother in wrong address which is not in the record of the court. Also, OCL failed to provide this honourable court of full evidence regarding the psychologists’ reports who were involved with the children in this case, and the reports from Kuwait regarding this matter.
35. That the Court award costs of these motions to the Applicant, payable forthwith.
36. Such further and other relief as the Applicant Mother may advise and this Honourable Court deem just.
37. This submission is filed in support of the Applicant Mother’s Responding Affidavit sworn dated JULY 04, 2025 on support Notice of CROSS-Motion and Contempt Order Motion dated JULY 04, 2025.
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The affidavit from THIRD Party who is not involved in this case, filed by OCL:
Form 14A: Affidavit (General) dated June 20, 2025
My name is Sheena Scott
1. I am the Regional Supervisor in the Personal Rights department at the Office of the Children's Lawyer overseeing this file. As such I have knowledge of the information deposed to herein, except as otherwise explicitly stated below.
2. I have had the opportunity to review the affidavits of Lubna Aldahleh, sworn May 12, 2025 and June 1, 2025, and the amended affidavit of Lubna Aldahleh, sworn May 12, 2025, and the affidavits of Zakaria A M. Zayed, sworn May 12, 2025 and June 2, 2025, and except as stated herein I disagree with their contents as they relate to the Office of the Children's Lawyer.
3. An Order appointing the Office of the Children's Lawyer ("OCL") to represent the children, Lujain Zakaria Zayed, who is currently 12 years of age, Baraa Zakaria Zayed, who is currently 14 years of age, and Mariam Zayed, who is currently 6 years of age, was made on May 26, 2023, by the Honourable Mr. Justice Tobin.
4. The Office of the Children's Lawyer is seeking an order terminating Justice Tobin's order and removing the OCL, now-Justice Kimberly Doucett of the Ontario Court of Justice,