please write the letter below to the Hong Kong Family Court Judge for a moving and relocation application like a barrister would using numbered paragraphs like in an affirmation.
Dear Honorable CK Chan / Honorable T. Kwan
I apologize for this letter, which I was told to refrain from writting letters.
But this is an urgent situation and I am happy to swear by way of Affirmation, or submit upon your request to another HK Government if I am mistakenly contacting the HK Family Court on this matter involving the protection of children from harm and more notably my concern for the protection, well being, and best interests of both children that is the HK Family Court’s paramount concern.
RE: Request URGENT directions Hearing for TWO applications to protect children from harm and for their well being and best interests:.
Temporary Removal of children for Private International Schooling (in the USA) and Quality, secure, stable housing.
Permanent Removal of children to the United States of America
For the avoidance of any doubts, the children will not have housing, private international schooling in Hong Kong which is available in the USA.
The Mother who is neither a local Chinese, is an NCS (non- Chinese Speaker), has no employment, no family or support in HK, has irresponsibly ignored all repeated attempts to protect the children from harm by way of mutual consent forcing the Father to desparately come to the HK Family Court to protect the children from harm.
The Father has provided the attached unmasked WP Settlement SHORT and LONG term solutions to the Mother providing the children with Private International Schooling, Private Health Insurance, Quality Housing for both the Mother / Children and Father and Children for FREE and other in the US as stipulated.
The children face homeless and increasing hardship in Hong Kong which shoudl be a concern to the HK Family Court in light ot the Mother’s refusal to consider the saftey, well being, and best interests of her own children.
I am also requesting an URGENT updated Social Welfare and Psychology Report be made as two prior Social Welfare Reports have already been made in 2021 and 2022 recommended Moving and Relocation to avoide this exact now URGENT situation which was laready predicted and well documented causing harm and now SERIOUS HARM to children if no action is taken.
I believe a THIRD updated Social Welfare and Psycholgy Report should provide the correct recommendation for the HK Family Court to protect children from harm
But more notably determine what is in the best interests and well being of both children which is the Paramount concern of the HK Family Court by mandate.
Dramata's of this URGENT situation I am requesting your HELP or any other HK Government body tasked to protect children from harm
The Father has secured employment in the USA and is leaving in July 2024 after both children’s current HK schools end and the Father has secured as part of his employment Private International Schooling for both children in the USA starting in the Summer 2024, secured Private Health Insurance for both children, Quality Housing for both parents and both children in the USA as in WP Short and Long Term solutions (attached) as later mirrored also in the TWO separate applications I have been forced to file with the HK Family Court.
I have submitted the above applications on April 16, 2024 almost one month ago.
There was a letter written by H.H.T.Kwan on April 17, 2024 (no phone call informing me was received on directions provided informing me about this most likely due to an error on the phone number). Then I learned that H.H. T. Kwan went on holiday for an unknown time.
On April 22, 2024, I went in person to the HK Family Court desk to pick up the letter and told that H.H. T. Kwan was on vacations until May 6, 2024.
Given the URGENCY of the situation involving the protection of children from harm, I was distraught and later kindly consoled by the by the desk that I could have directions Duty Judge set up an URGENT directions hearing in H. H. T. Kwan’s vacation absence.
On April 29, 2024 during the morning, I requested to file with the Duty Judge for urgent attention. I was called at around 4:30 pm that a hearing on these URGENT matters could be held on April 30, 2024 by the Duty Judge H.H. CK Chan in H.H.T. Kwan’s absence. These are my children and I consider their protection for upcoming HARM to be an extremely urgent matter to me.
On April 30, 2024, this matter was not resolved as this was considered URGENT but not Extremely URGENT. And no relif to protect both children from harm was provided. The same URGENT situation and problms that require solutions remain.
On May 3, 2024, I CC and provided copies of the correspondences, applications, and Ex-Parte Judgement to the Mother and her HKLA team with letters and urgent requests for a mutual consent agreement to protect the children from harm and avoide taking this matter to the HK Family Court.
For the avoidance of any doubt, The Mother and her HKLA team have both applications in their entirety since May 3, 2024.
The Mother and her HKLA team have time to put forward a REPLY Affirmation so that ‘due process’ can be fulfilled to oppose both of these separate applications.
I note that the Mother and her HKLA team have not been filing REPLY affirmations to my applications on these and many serious matters which circumvent due process on serious matters involving children which have been documented and evidence provided. Separate but very serious matters involving the protction of children from actual harm, which cannot be ignored.
On May 6, 2024, upon the return of H.H.T Kwan from vacation, I went in person to the HK Family Court to file the original applications made with her instructions provided. The letter attached requested the TWO separate applications one TEMPORARY Removal (as mirrored by the SHORT Term Solution attached) and one PERMANENT Removal (as mirrored by the LONG Term Solution attached) into one Summons this was vexations for the listing clerk.
I went on the same day May 6, 2024 to Legal Help Desk with the attached letter from H.H. T. Kwan who told me that Two Applications and Summons should just have the same summons date on both separate applications it was vexatious to them as well.
After further review, the legal help desk told me to just copy both summons on ONE summons with slight modification to articulate that they are two separate applications.
I later went to the filing desk, and swore again the contents, and resubmitted the same applications on May 6, 2024 to fulfil all of the requests on the letter and we resubmitted the TWO separate applications under ONE summons as requested.
On May 7, 2024, I went in person after none of my calls were answered or returned to follow up on the URGENT Summons Date.
On May 8, 2024, I went in person after none of my calls were answered or returned to follow up on the URGENT Summons Date.
On May 9, 2024, I went again in person after none of my calls were answered or returned to follow up on the URGENT Summons Date.
On May 7, 2024, I submit this letter asking for HELP from the HK Family Court to protect children from harm and more notably to act for and on behalf of both children’s clear best interests and well being.
PLEASE HELP: I understand that my children and their protection from harm and their well being and what I consider to be an EXTREMELY URGENT matter may not qualify as such right now. But without taking prompt action and the children are rendered homeless, on the streets, having their educational futures destroyed if NO ACTION is taken right now, only then may this qualify as EXTREMELY URGENT.
I am trying to responsibly act, and am forced to go to the HK Family Court for ‘common sense’ relief as a litigant in person with the only object to protect children from HARM. The HKLA funded Mother has refused all direct pleadings and offers for a mutaully agreed children well being first global resolution, as she believes some advantage over an unrepresented father in the HK Family Court (refusing all FDR’s, Settelments, and Global Mediation solution instead choosing litigation). I am forced to protect the chidren from HARM by going to the HK Family Court.
I understand that the HK Family Court Judges are busy, go over vacation, and have other matters and schedules to attend to.
I request that if this is the case, PLEASE HELP provide a qualified Expat Duty Judge that can hear these matters urgently.
I request the Mother’s HKLA team make REPLY Affirmations if the want to OPPOSE these applications (or if HKLA will not fund a hopeless opposition, the Mother herself draft her own REPLY Affirmations and be held to the same standards as the legally unrepresented father, which is only fair, just, and equitable);
To reiterate, I have attempted to file these URGENT children well being, best interests and more notably protection matters on April 16, 2024 for URGENT directions, and as above you can see how URGENT this situation truly is and all of the Father’s good faith efforts in between to protect children from harm.
It is now, May 9, 2024 almost one month later, and so far the Father does not have an URGENT Direction Hearing date. The Father’s new employment starts in July 2024 adn both children have Private International Schools (one on Scholarship) as well as stable and secure housing in the United States of America as stipuled in the attached.
I am desparate for directions and guidance on this matter to protect both childrne from harm.
I sincerely and greatfully look forward to help, guidance and assistance on this URGENT matter.
1. I am writing to urgently request directions from the Hong Kong Family Court for two separate applications aimed at protecting the children from harm and ensuring their well-being: one for the temporary removal of the children for private international schooling in the USA, and secure and stable housing; and the other for the permanent removal of the children to the United States of America.
2. The Mother, who is not a local Chinese, lacks employment, family support in Hong Kong, and has consistently ignored attempts to protect the children from harm, necessitating the Father's intervention through these applications to safeguard the children's best interests.
3. The Father has provided detailed proposals for the children's education, healthcare, and housing in the USA, which significantly exceed the opportunities available in Hong Kong, emphasizing the urgency of relocating the children to ensure their safety and well-being.
4. Despite repeated attempts to address these urgent concerns, the Mother and her legal team have failed to engage in meaningful dialogue or submit reply affirmations to the applications, compromising due process and delaying critical decisions affecting the children's welfare.
5. Given the imminent relocation of the Father for employment in July 2024 and the availability of private international schooling and quality housing arrangements in the USA, it is imperative that the Hong Kong Family Court expedites a resolution to prevent harm and disruption to the children's lives.
6. The Father has diligently pursued legal avenues for resolution, filing the applications on April 16, 2024, and subsequent attempts to secure an urgent directions hearing have been met with delays and administrative obstacles, hindering timely intervention to protect the children's interests.
7. In light of the gravity of the situation and the urgent need for court intervention, I respectfully request the Honorable CK Chan or another qualified Duty Judge to promptly schedule a directions hearing to address the pressing issues at hand and safeguard the children's well-being.
8. I implore the Hong Kong Family Court to prioritize the children's safety and best interests in determining the most suitable course of action, considering the documented risks and vulnerabilities they face in Hong Kong and the superior opportunities available to them in the USA.
9. Your urgent attention and assistance in expediting a directions hearing for these critical matters are crucial to ensuring the children's protection and well-being, and I trust that the Hong Kong Family Court will act swiftly and decisively in the children's best interests.
10. I express my sincere gratitude for your attention to this pressing matter and look forward to a swift resolution that prioritizes the children's welfare above all else.
Yours faithfully,
George Varvitsiotis
Barrister for the Father
HK Family Court File Number 12345678
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