1. This Affirmation was made in reply to a directions letter I received during the Christian Holiday Season dated December 20, 2023 for matters which I believe serve very useful to further expose why all of these matters regarding ‘shares’ and ‘the Company’ should not be in the HK Family Court properly ventilated in the High Court where they already righteously belong for the last 3.5 years.
2. The Petitioner and her HKLA council are welcomed to take their hopeless litigations to the High Court, and I recommend all matters regarding Asia Interactive Services (HK) Limited are moved from the HK Family Court to the High Court given all of the finding of facts presented in this requested affirmation.
3. I want to make it clear that I only provided the Statement of Claims, Affirmations, Amended Replies, that I had on hand and did not attach the exhibits as this request was made during the Christian Holidays and our legal councils were not available for obvious reasons. There are some 800 pages of relevant documents exposing this frivolous ‘joiner’ application and to save time and costs the rest are in the ‘High Court’ discovery of some 12,000 pages and some 40 binders the HK Family Court would need to thoroughly review. The high risk of conflicting judgements on overlapping matters already being properly ventilated in the High Court for 3.5 years is a very obvious matter that the Petitioner cannot make the HK Famil Court o or HKLA paying for this willfully ignore any longer. A formal opinion in light of the evidence should also be put on record.
a. The matter of the Shapiro’s malicious infestation of the confidential HK Family Court via the Petitioner full cooperation is already exposed and on record. (A formal comment from the HK Family Court on what to do with these continued violations of privacy law)
b. The ADMITED acceptance of bribes by the Petitioner under OATH are also on record. (A formal comment from the HK Family Court on acceptance of bribes in exchange for overt collusion should be documented)
4. On December 20, 2023 I received a request by the Petitioner via to send over some 10,000 pages of discovery already with the High Court Cases, which would cost HKLA some $10,000 HKD or more in printing expenses alone for discovery already provided to the malicious Shapiro’s whom the Petitioner openly collaborates with violating many laws like sharing confidential HK Family Court information and collusion. Potentially the Petitioner and HKLA council should get these documents from the Shapiro’s given they are so openly colluding saving our time and costs over the Christian Holidays.
Pleadings History
5. Initially in their HCMP 1847 of 2020 Originating Summons started off trying to extort all my shares, and my family’s shares D1-D4 (take them all and keep all of their own, which was attempted but after D1-D4 defense the nefarious Shapiro’s OS was so poor and sloppy, they embarrassed themselves and lost this claim and their Originating Summons was deemed so improper Judge Manzoni ordered that the Shapiro’s sue the defendants in a less embarrassing manner and come back to sue us via Writ.
a. The Shapiro’s then changed their entire pleadings again and in May 2021 via their writ (again). They filed Statement of Claims
i. HCMP 1847 of 2020
1. Exhibit 3 – HCMP 1847 of 2020 Pleadings and Replies
ii. HCA 757 of 2021 – a new hopeless litigation regarding directors compensation.
1. Exhibit 4 – HCA 757 of 2021 Pleadings and Replies
2. The Shapiro’s made a failed ‘ Partial Summary Judgement’ for HCA 757 of 2021 that was so poor they vacated to a litigant in person and were ordered to pay costs. And this was the ‘strongest part’ of their incredibly weak case explaining why its 3+ years later and they do not want to take it to court….
3. Neither of these new litigations made claims on my personal shares. Just attacking my family’s ownership D2-D4. But not their own share ownership. Then recently the Shapiro’s changed their pleadings again saying the Step 1 and Step 4 shares they received were wrongful (but the Shapiro’s did not challenge ALL other of the many Step 1 share recipient parties shares – The Petitioner being one of the many receiving Step 1 shares with NO paperwork (I issued those shares to the Petitioner); Making her own claims and the Shapiro’s ever changing claims even more non-sense. The Shapiro’s should be suing all parties who received Step 1 shares (including the petitioner and themselves) Explaining why the Shapiro’s are now infesting the “HK family Court” on these matters having embarrassed themselves in the High Court.
iii. HCMP 1429 of 2022 – A discovery application
1. Exhibit – 5 I provide Statement of Claims, Affirmations and replies.
2. I note that the same requests in this failed discovery application were also repeated by the Petitioner, which is provides further evidence of her law breaking ‘collusion’ with the Shapiro’s for irrelevant items like ‘emails’ which have nothing to do with the matter at hand. “emails” are non sense and just the Shapiro’s trying to get contact information of potential business partners to threaten litigation against them and cause harm to the company, which is the only thing the Shapiro’s seem to be good at (as well as infesting these private HK family court proceedings with no penalties)
a. The Petitioner refuses to provide full and frank disclosure and DENY her Collusion with the Shapiro’s UNDER PERJURY with the Shapiro’s as this would mean another count of Perjury given we know she is colluding.
iv. HCA 1238 of 2023 (Exhibit 6) Statement of Claim– Removal of Howard Nathan Shapiro as a director, with a clear majority of some 60% (everyone except the nefarious Shapiro’s) wanting to remove them. An temporary Injunction order was granted sometime in August 2023, based a completely fabricated ‘Shareholder Agreement’.
1. Exhibit 6 - We just received the ‘Statement of Claim’ on December 21, 2023. We will reply in due course.
6. To save time and costs and in the hope’s “Common Sense” prevails on how HOPELESS the mother’s Joiner application is, I again submit that ALL of my shares are the property of Georgia Varvitsiotis as stipulated in the May 2017 formal agreement by deed where a cash investment was made of $45,000 USD into the company saving it from insolvency. (This deal followed the Supplemental deed some 12 hostile investors in March/April 2017 who put a lien on 10% of George Varvitsiotis and a draconian coupon payment by the Company – because of this prior deal Georgia refused any new investments without warrantied protections – the Supplemental Deeds are all in Discovery and submitted already). This agreement is well documented, and this agreement was upheld with THIRD parties namely publicly listed AAJ2 third party in May 2020, whereby Georgia enforced this agreement to allow a lien on her shares (only held in my name). These agreements were made more than THREE years before the Mother’s unannounced filed divorce filing, had a clear purpose, and sizeable $45,000 USD cash investments into the Company, was enforced with Publicly listed company, who also made a some $25,000 CAD investment relying on this same agreement and are well documented, completely independent of the Petitioner, and to have nothing at all to do with the Petitioner, and render her meritless claim where the burden of proof resides with the Petitioner hopeless. As this matter predates the divorce by over THREE years, the burden of proof is on the Petitioner who has not provided any save for what we have already provided to the High Court again reaffirming why this matter if the Petitioner wants to pursue it should happen in the High Court and not the HK Family Court if the Petitioner wants to pursue this meritless claim. To avoid repetition I attach an already filed detailed explanation Exhibit 1 and Exhibit 2 to put a end to this.
a. Exhibit 1 – Opposition to Improper Joiner with the May 2017 agreement, $45,000 USD Convertible Note with agreement, HSBC Bank wire of $45,000 USD investment, which end matters right there.
b. Exhibit 2 – I attach a formal agreement whereby Georgia Varvitsiotis authorizes a small fraction of the shares in my name that she owns with a publicly traded Third Party called AAJ2 to make a $25,000 CAD cash loan to the company using that small fraction of shares in my name that Georgia Varvitsiotis owns as collateral for that business loan. The emails are also attached and if needed to waste Rob Kan’s and Praveen Varshney’s time the Petitioner can bear the costs of harassing them as well in Canada about this well documented and known matter.
c. The Joiner application of the Mother is hopeless, HKLA should be made aware of this frivolous already disclosed waste of taxpayers funds, and this end right here..
7. In conclusion, I strongly believe that all matters regarding the shares and the company should be properly addressed in the High Court, where they have already been diligently discussed for the past 3.5 years. The HK Family Court should not waste any more time or resources on these matters that clearly belong in the High Court.
8. I did not attach the exhibits requested in the letter as it was during the Christian Holidays and our legal councils were unavailable. However, there are already hundreds of pages of relevant documents exposing the frivolous nature of the petitioner's claims, and the rest can be found in the discovery of the High Court.
9. The petitioner's collaboration with the Shapiro's, including their violation of privacy laws and acceptance of bribes, is already exposed and on record. I believe the HK Family Court should provide a formal comment on how to address these violations.
10. The petitioner's request for 10,000 pages of discovery that has already been provided to the High Court would incur significant costs for printing alone. It is suggested that the petitioner obtain these documents from the Shapiro's, given their open collusion, in order to save time and costs.
11. A brief history of the pleadings is provided, highlighting the petitioner's failed attempts to extort shares and their ever-changing claims. The petitioner's recent infestation of the HK Family Court with these matters, after their embarrassing failures in the High Court, is concerning.
12. It is reiterated that all of my shares are the property of Georgia Varvitsiotis, as stipulated in a formal agreement made in May 2017. This agreement, along with subsequent agreements with third parties, predates the divorce filing by over three years and renders the petitioner's claim meritless.
13. Exhibits 1 and 2 are attached to provide a detailed explanation and evidence of the May 2017 agreement and subsequent agreements with third parties. It is emphasized that the burden of proof lies with the petitioner, who has not provided any evidence to support their claim.
14. In conclusion, the petitioner's joiner application is deemed hopeless and a waste of taxpayer funds. HKLA should be made aware of this frivolous claim, and the matter should be put to rest.