write in numbered paragraphs as if a barrister in hong Kong to a court:
1. My prior application for leave for both children to see their own grandfather was not heard in the Summer of 2023. The Children have last seen their grandfather in person in the Summer of 2018 or some SIX Years (most of their childhoods) since then save for regular online calls, which is a severe cruelty harming the children’s well being to be so wrongly denied seeing their loving grandfather, grandmother and family. I have experienced severe personal duress not being able to have the children visit my parents as they used to so many times in the past. I make this application again to for the children to see their grandfather in the Summer of 2024 for 20 – 28 days.
2. The grandfather is in ailing health (almost dying last year hospitalized for around 1 Month in April 2023), and its has been now some SIX YEARS since both children have been able to see and hug their loving and financially supportive grandfather and see their family in Greece.
a. This application is made at the same time and is proposed to be heard together as the application to see the children’s Grandmother for Chinese New Years, who as reported has serious ill health. Not to repeat the very same basic children’s human rights the children need to see their own very ill Grandfather, Grandmother and family.
b. The ‘allegations of being a potential ‘flight risk’’ will be addressed by the Grandfather and Grandmother providing ‘A Grandchild Child Visitation BAIL BOND’ or ‘Security for being a Flight Risk’ which appears to be the only remaining excuse the Mother can make to continue this inhumane prevention of US Citizen children being stopped by the Mother from seeing their own family for now SIX years for the Grandfather, and FOUR years for the Grandmother.
3. I will also rely on the Chinese New years affirmation which documents in greater detail, why I am not a flight risk correcting material misrepresentations made by the Mother on this non-existent matter.
a. The Mother has ADMITTED on many occasions (most recently on December 28, 2023) that she is intentionally maliciously blocking both children from seeing their grandparents out of nothing more than pure malice, and to cause intentional harm and duress to her own children, the father, and the grandparents out of her ADMITTED malice. The Mother was also linking access to family for financial payments, which is similar extortion “payment” for access to “Philip” she has been exposed to have done in the past (“No Money – No Philip” just one year ago). The Mother has been using access to the children’s grandparents, as a similar weapon to cause harm due to her anger and this is a serious form of child abuse. The HK Family Court should be aware WHY the Mother is blocking her children to see their own grandparents in the past and now ADMITTING to block the children to see their grandparents ‘in perpetuity ‘going forward. This is simply wrong.
b. This is a FACT, and if the Mother wishes to refute this fact in her REPLY – then I invite the Mother to do so UNDER PERJURY.
i. I have requested the right to a REPLY to the Mother’s Affirmation.
c. The Father is not a flight risk, nor was the Father ever a flight risk, and as documented the prior affirmation(s) the office is fixed in the current converted Company Registered office where the Father lives in on 42 Macdonnel road, and the business cannot be run remotely without this office running all IT server and network equipment, this FACT was misrepresented by the Mother and the HK Family Court should be further mislead on a matter of fact.
d. The 17 year old business’s continuation is needed as its main source of the Father’s income to support the children. This along with all our possessions in the office should also be obvious that we will return among the below additional reasons to eliminate any potential new excuses for the inhumane restriction of children to see their loving grandparents by the Mother for SIX and FOUR years respectively (most of their known childhood).
e. The grandparents (grandfather and grandmother) are willing to put up a ‘Bail Bond’ or ‘Security for flight risk’ (that they will get back once I return both children to Hong Kong “Asia’s World City”). The grandparents offered to do this to see their own grandchildren.
f. The father is not a flight risk and with a ‘bail bond’ or ‘security for flight’ that the grandparents have volunteered IF NEEDED, eliminates this ‘excuse’ to block the children from seeing their loving and financially supportive grandparents and family.
g. I clearly done nothing save for wrongly being ‘accused’ of being a potential flight risk and the children are being wrongly punished and intentionally alienated from their own family by the Mother for SIX and FOUR years respectively and this ‘excuse’ of being a flight risk should have disappeared some TWO or THREE years ago after these numerous applications for the children’s basic human rights to see their own grandparents before they Pass Away.
h. I believe many accused criminals facing criminal charges for ‘alleged acts committed’ have more freedom of travel during their upcoming trials and are free on ‘bail bonds’ so I request the same courtesy from the HK Family Court, IF needed as My Parents want to see their ‘grandchildren’ before they DIE – This application is that simple.
i. As it has been FOUR years now to see the grandmother (being denied THREE times) and SIX years now to see the grandfather being denied TWO times (both of which are in very poor health the grandmother now in worse health that the grandfather) and this separation has caused the children much harm and duress, caused me the father much harm, emotional duress, and pain, and the caused the elderly grandparents much harm and duress and pain, and the children’s family members much distress learning of this situation in Hong Kong and of the children being blocked by the Mother for so long to see their own loving family members for such a long time.
j. To repeat the Mother has ADMITTED to her own children she is blocking them to see their loving and financially supportive grandparents to intentionally cause the children pain and harm, to cause the father pain and harm, and to cause the grandparents pain and harm out of her own malice. This is wrong and the HK family court has been used by the Mother in this manner as ‘instrument of harm’ to cause children harm. It is time to allow the children to see their own grandparents before they die and if the children do not see their grandparents before they die, IF they are blocked and either grandparent dies that will cause a lifetime of pain and suffering to the children and father (the grandparents being also hurt before they die being denied to see their own grandchildren). This is just wrong.
i. Please imagine if You were blocked to have your children see their elderly and now very sick grandparents for FOUR and SIX years based on nothing more than ‘allegations’ but in reality done just out of malice by an Ex-Spouse? How would you feel after SIX and FOUR years of this?
4. I plead to take my sons Leonidas (“Leo”) age 13, and Philip age 11 to see my 84 year old father (their Grandfather) in ailing health, and to stay in my father’s home (the children’s Grandfather) home in Sparta, Greece. Which the children have visited and stayed for a long period of time in the Summer of 2018.
5. The Mother last Summer in 2022 (still during COVID) successfully opposed both children to see there then in far better health grandfather. The Air Tickets and all expenses will be paid by the Grandfather.
6. My grandfather is in poor health and was recently hospitalized with pneumonia and other complications for almost one month in April 2023, which he almost did not survive. He is recovering now slowly but is in still poor and frail health.
7. As my father, the grandfather loves both of his grandchildren and was denied last year the opportunity to see them. My Father fears that he will not see them before his passing given his frail health wants to see both of his grandchildren this Summer 2023. My Father feared this last summer in 2022, and wanted to see his grandchildren and paid all AIR Ticket expense last year but was denied by the Mother to see his grandchildren, which was wrongful.
8. Both Children dearly love their beloved grandfather, and have kept in close touch via digital phones and even learned Greek. The Photos and Exhibits speak for themselves.
9. It is crucial for the children's well-being and emotional development to have a strong bond with their grandparents. Denying them the opportunity to see and spend time with their loving and supportive grandparents for such an extended period of time is a severe cruelty that has had a negative impact on their overall well-being.
10. The children have expressed their desire and longing to see their grandfather, as they have not had the chance to see him in person for six years. Regular online calls can never replace the personal connection and affectionate relationship that can be fostered through physical visitations.
11. Moreover, the grandfather's ailing health adds urgency to this application. He was hospitalized for almost a month last year and, considering his frailty, it is uncertain how much longer he will be able to spend quality time with his beloved grandchildren.
12. I request that this application be considered together with the earlier application to see the children's grandmother for Chinese New Year. Both visits are vital for the children's well-being and should not be mutually exclusive.
13. The mother's allegations of being a flight risk have been frivolously made and are unfounded. The grandparents are willing to provide a grandchild child visitation bail bond or any other form of security to alleviate any concerns regarding the children's return to Hong Kong.
14. Additionally, the mother's malicious intent is evident through her admission that she is intentionally blocking the children from seeing their grandparents out of pure malice. She has been using access to the grandparents as a weapon to cause harm and distress to the children, the father, and the grandparents. This manipulative and abusive behavior should not be condoned or tolerated.
15. I categorically state that the father is not a flight risk and has no intention of absconding with the children. The business that he operates requires his physical presence, as documented in prior affirmations. The mother's misrepresentation of this fact to mislead the court is deeply concerning.
16. The continuation of the father's seventeen-year-old business is essential for supporting the children financially. The office and its contents serve as a vital source of income that ensures the children's well-being and future. It is evident that the father has no intention of jeopardizing his livelihood and the children's security by fleeing the jurisdiction.
17. The grandparents' willingness to provide a bail bond or security for flight risk further proves that there is no legitimate reason to deny the children the opportunity to see their grandparents. The intention behind the mother's persistent efforts to block this visitation is nothing but a malicious and harmful attempt to control and harm the children, the father, and the grandparents.
18. The separation from their grandparents and extended family members for such a prolonged period has caused immense harm, distress, and duress to the children, the father, and the grandparents. This separation has caused significant emotional pain, not only to the immediate family but also to other concerned family members who have become aware of the situation.
19. It is essential to highlight once again that the mother has admitted her intention to block the children from seeing their loving and financially supportive grandparents purely out of malice. The court should not be complicit in allowing the mother to continue inflicting pain and suffering on the children and their grandparents.
20. In conclusion, I implore the court to grant this application and allow the children to see their ailing grandfather this summer. The children's emotional well-being, their right to a relationship with their grandparents, and the grandparents' right to spend quality time with their grandchildren should be prioritized and protected. Any further delay or denial of this visitation will perpetuate harm and suffering that cannot be undone.