write the below as if a barrister in HOng Kong wrote it with paragraph numbers
1. Leave for removal to visit CT/NYC for Chinese New Year’s to see immediate family (grandmother, Sister, extended family such as Aunts, Uncles, Cousins). I have recently discovered my 85 year old Mother in February 2024 is in much poorer health than I was told by my family before the Christmas Holiday.
2. Grandmother Georgia Varvitsiotes has a materially negative change in her health and wants to see BOTH her only grandchildren before she may passes away. I was told of her material negative change in health after the Christmas Leave application was rejected as they did not want to alarm me before hand considering all of the pressures myself and the children are under now.
a. This is a new update not included in the prior Christmas Leave application which was dismissed without the full facts;
b. I tried to urgently tell the Duty Judge so the children could see their loving and financially supportive Grandmother before she passes as “New information is that the Grandmother is 84 years old, in poor and failing health, and does not have a prognosis. The children being prevented for FOUR years now need to see their loving and financial supportive grandmother before she potentially passes.”
c. I did not have a doctors letter for the prior URGENT application, and I was not told about how poor her health has become. I have provided my Mother’s Cardiologist prognosis as attached confirming the poor current health of my Mother.
i. Exhibit 1 – a letter from my mother’s cardiologist stating the failing health of my Mother and need for her to see her grandchild and son.
3. Preventing the Father to take both children to see their Grandmother (and Grandfather) has caused a very large amount of emotional distress to the children, and severe emotional duress to the Father.
4. The Mother has ADMITTED to maliciously deny the children the right to see to see their grandparents to cause pain, suffering, and harm to the children, the Father, and the Father’s family. This is simply wrong to use the HK Family Court in this manner to alienate family members.
a. The Mother also denigrated the Father and his family to both children all while the Mother ADMITTED she will keep DENYING the children the right to see their grandparents “IN PERPETUITY” next Summer, and next Christmas. It has SIX years to block the Grandfather from seeing his own grandchildren and FOUR years to block the Grandmother from seeing her own grandchildren); this is simply wrong.
b. The above is not an allegation but a FACT. The reason for the Mother’s opposition to these applications is MALICE.
c. The Mother is welcomed to DENY the above UNDER PERJURY; I believe the Mother will not DENY the above TRUTHFUL statement Under Perjury.
5. The Mother most recently (but also on other occasions) on 28 December 2023 again abused her own children stating that if she does not receive the money’s the Mother wants she will continue to perpetually DENY access of the grandchildren using the children as ‘personal bargaining chips’ No past current or future Christmas, and No past current or future Summer holidays with their own grandparents and family. This is both ADMITTED, and Wrongful extortion of access to family members for children by the Mother. These applications should have been done via Mutual Consent and never even need to be made. The denial of children’s access to their grandparents and family members out of malice to knowingly cause the children, the Father, grandparents, and their family harm is wrong.
6. The HK Family Court should not knowingly be used an instrument of family alienation, malice, and extortion by the Mother. The HK Family Court is there to be fair and just and protect the well being and best interest of the children and not be used as tool of extortion and wrongdoing by the Mother.
a. The Mother went on to denigrate both the Father on this most recent and many other occasions which are on record.
b. The Father’s family provide material financial support to both of her children; notably more financial support than the mother herself, and yet the Mother denies the very same grandparents access to their own grandchildren. This is a Fact.
c. These are facts which have been occurring over the last now FOUR years whereby the Mother gloats over the pain she knowingly inflicts on the children, and the Father by wrongly denying access to the children to see their grandparents and immediate family members, and the Mother has been successfully using the HK Family Court as the instrument of this ADMITED form of abuse.
d. The children have a right to see their elderly grandparents and the grandparents also have a right to see their own grandchildren.
7. Its has now been some FOUR years since the children have seen their immediate family and SIX years to see their grandfather in Greece. The children have an inalienable right to see their immediate family and their own Grandmother. And this has been a reprehensible and inhumane cruelty imposed on children, and the Father by a clearly malicious mother overtly acting in this manner to cause harm and distress. The Father is not a flight risk and these prolonged divorce proceedings have lasted over FOUR years (this is not the first application).
8. There is NO flight risk and the concept of providing returnable ‘Bail Bond’ or ‘Security for Flight Risk’ IF needed so that the wrongful cruelty to children can end. A “Bail Bond” or “Security for Flight Risk” that is returnable immediately after I bring the children back to Hong Kong IF needed eliminates any potential allegation of me being a “Flight Risk”.
9. I am not and never was a flight risk but A bail bond or ‘security flight’ is also being offered by the Grandparents to hold as collateral to be returned when the Father brings back both children to Hong Kong.
a. Even accused criminals have the right to a ‘bail bond’ and if I am to be treated as such for a crime I could not have committed. I believe this can alleviate any concern of being a flight risk.
b. It is reasonable that a ‘Bail Bond’ concept be applied so the children can see their grandparents after FOUR years and SIX years respectively. IF needed.
c. I believe this is only more than fair and should provide the HK Family Court with the Peace of mind to grant the children the right to see their own grandparents and family after so many years being blocked by the Mother to do so.
10. The Father is NOT and Never was a flight risk and the below reasons document why:
A.The business Asia Interactive is run out of the immovable Registered office on 42 Macdonnell Road flat 2E (the converted company REGISTERED office). There can be no MISREPRESENTATION of FACT that the company needs a PHYSICAL office and all of IT network and IT server equipment which are ALL physically located physical office on 42 Macdonnell Road. The Business CANNOT be run remotely without this Physical office this was a FALSE statement and misrepresentation. This is a finding of FACT and NO further misrepresentations can be made on this finding of documented fact.
B. This business needs a physical location to hold its secure IT network and It development servers. That physical location is in HK / immovable office where the Father lives. The costs to move are prohibitive some $300,000 - $500,000 HKD – (this fact has been repeated in many sworn affirmations add emphasis) and a new physical location is needed to move the ‘office’ to. There are NO IT staff or capabilities to make this risky move and if this move is attempted – the entire business can SHUT down in seconds if any move is even attempted. This is the REPEATED finding of facts that NO further ‘misrepresentation’ or FRAUDULENT misrepresentations can be made in light of the repeated finding of facts. The business cannot be ‘run online’ or remotely without the physical office set up. The businesses physical office cannot be moved with material investments and HIGH RISK for closure causing threat of liability from investors if wrongly attempted. I will not bear this liability to leave 17 year OLD business in Hong Kong and be a ‘flight risk’ on 19 Hazelwood Lane, Stamford CT. 06905.
C. I am Yale University graduate with no criminal record at 51 years of age. A professional who is not a “flight risk”.
a. Both children attend schools in Hong Kong
i. American International School for Leonidas Varvitsiotis (age 13); needs to return to finish this school year or lose a grade
ii. Catholic Mission School for Philip Varvitsiotis (age 10); needs to return to finish this school year or lose a grade
iii. I believe my views on elite Private Education for both children and ‘Bright Futures’ is well documented.
iv. Leonidas Varvitsiotis is now being considered to attend the #1 and #3 Private High Schools in the World on full academic scholarship. These schools Admit some 80% into the IVY Leagues like Yale, Harvard, Standford, Duke, UPENN, etc
v. I would not jeopardize my children’s “Bright Educational futures” which came at great personal effort by me personally by being a ‘flight risk’. This is an embarrassing argument.
b. My entire LIFE in Hong Kong and am the CEO of a business in Hong Kong for the last 17 years’ and I am running many litigations concurrently here in HK simultaneously for which my presence here makes managing them very cost effectively. I intend to move out of Hong Kong, and will do so legally. My well documented applications are on record.
vi. If I did not LOVE both my children would I have self represented for FOUR years now so they could have a BRIGHT FUTURE with Quality Stable Housing and elite Private Schools? (what I am on record fighting for)
vii. I believe this argument makes NO sense at all and is meritless.
c. All our possessions and life has been in Hong Kong and we have to return. I do not have any track record of being irresponsible and just ‘running away’. I believe my actions have shown just the just the opposite.
d. The criminal ‘Bail Bond’ or ‘Security for Returning’ can be provided by the grandparents, if I am to be treated like a criminal for a CRIME I have NOT committed or under some for inditement for a ‘suspected crime’ I could not and have not committed yet. Even accused criminals get bail bonds to visit their families for crimes they are being accused of formally that the Police suspect they may have done. I have NOT committed any crimes and the children and myself are suffering as if we have based on the Mother’s malicious opposition for the basic rights of the children to see their own grandparents and family members for so long.
e. All of the above should address the pointless argument after now over FOUR years of the children being PREVENTED to see their own loving and financially supportive families due to the Mother’s ADMITTED Malice.
10. The Father’s family and grandparents have been providing the loans for the children’s needs, payments for private schools, health insurance for both children, and many essentials including loans for children’s food, clothes, and gifts to raise the spirits of the children in these now some “FOUR YEARS” of divorce proceedings from the same Mother now alienating both children out of ADMITTED malice. This is not an allegation but a FACT the Mother ADMITTED in her own words directly to BOTH Children.
a. I REPEAT the Mother is welcomed to DENY this fact UNDER PERJURY, and the HK Family Court must comment on this exposed finding of ADMITTED fact.
Paragraph 1: The applicant seeks leave for removal to visit CT/NYC for Chinese New Year's to see immediate family, including their grandmother, sister, and extended family members. The applicant recently discovered that their 85-year-old mother's health is much worse than they were informed by their family before the Christmas Holiday.
Paragraph 2: The grandmother's health has significantly deteriorated, and she wishes to see both her only grandchildren before her passing. The applicant was not informed about this change in health until after their Christmas Leave application was rejected. This new update was not included in the previous application, which was dismissed without all the facts. The applicant urgently informed the Duty Judge about this new information, emphasizing the need for the children to see their grandmother due to her failing health. The applicant did not have a doctor's letter for the prior application and was unaware of the poor health of their mother. However, they have now attached a letter from their mother's cardiologist confirming her poor health.
Paragraph 3: Preventing the father from taking both children to see their grandparents has caused significant emotional distress to the children and severe emotional duress to the father.
Paragraph 4: The mother has admitted to maliciously denying the children the right to see their grandparents, with the intention of causing pain and harm to the children, the father, and the father's family. This is an abuse of the HK Family Court to alienate family members. The mother has also denigrated the father and his family to the children and has admitted to denying the children access to their grandparents "in perpetuity" in future summer holidays and Christmases.
Paragraph 5: The mother has engaged in wrongful extortion by using the children as bargaining chips, stating that if she does not receive the desired amount of money, she will continue to deny access to the grandparents. This is both admitted and wrongful, as these applications should have been resolved through mutual consent instead of being made. Preventing the children from seeing their grandparents out of malice and to cause harm is wrong.
Paragraph 6: The HK Family Court should not be used as a tool of family alienation, malice, and extortion by the mother. The court should instead protect the well-being and best interests of the children and ensure fairness and justice. The mother has denigrated the father on multiple occasions, and despite financial support from the father's family, she denies access to the grandparents. These facts have been ongoing for four years, and the HK Family Court has been successfully used as an instrument of abuse.
Paragraph 7: It has been four years since the children have seen their immediate family and six years since they have seen their grandfather in Greece. The children have a right to see their immediate family and grandmother, and the mother's malicious actions have caused them significant harm and distress. The father is not a flight risk, and these prolonged divorce proceedings have been ongoing for over four years.
Paragraph 8: There is no flight risk, and the father suggests providing a returnable "Bail Bond" or "Security for Flight Risk" if required, to address any concerns. This would eliminate the potential allegation of the father being a flight risk.
Paragraph 9: The father reiterates that he is not and never was a flight risk. Both the father and the grandparents are willing to provide a bail bond or security for flight if needed. Even accused criminals are granted bail bonds, and the father's proposal should alleviate any concerns of flight risk. The HK Family Court should grant access to the grandparents and family members for the children after being blocked for so many years.
Paragraph 10: The father presents reasons why he is not a flight risk, including the immovable registered office of the business in HK that needs a physical location, his educational background, the children's schooling in Hong Kong, his presence in Hong Kong for the last 17 years, his intention to move legally, and the fact that all their possessions and life are in Hong Kong. The grandparents are also willing to provide a bail bond or security for return. The father emphasizes that his actions do not align with being a flight risk and the mother's opposition is based on her malicious intent.
Paragraph 11: The father's family and grandparents have been providing financial support, including loans for the children's needs and payments for private schools, health insurance, and other essentials. The mother has admitted to using the children as bargaining chips and has alienated them out of malice. The mother is welcomed to deny this fact under perjury.