fc_judgments: 69
Data source: lawnet.sg/lawnet/web/lawnet/free-resources
This data as json
| _id | _item_id | tags | date | court | case-number | title | citation | url | counsel | timestamp | coram | html | _commit |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 69 | 8a8473eb67738bad5f5a71cc38e0e19ff7ffc739 | [
"Family Law \u2013 Variation of consent order \u2013 Custody, care and control of child \u2013 Child maintenance"
] |
2024-08-20 | Family Court | Divorce No 1182 of 2022 | XBA v XBB | [2024] SGFC 62 | https://www.lawnet.sg:443/lawnet/web/lawnet/free-resources?p_p_id=freeresources_WAR_lawnet3baseportlet&p_p_lifecycle=1&p_p_state=normal&p_p_mode=view&_freeresources_WAR_lawnet3baseportlet_action=openContentPage&_freeresources_WAR_lawnet3baseportlet_docId=%2FJudgment%2F32019-SSP.xml | [
"Chew Wei En (Teoh & Co) for the Plaintiff",
"Defendant-in-Person"
] |
2024-08-24T16:00:00Z[GMT] | Shobha Nair | <root><head><title>XBA v XBB</title></head><content><div class="contentsOfFile"> <h2 align="center" class="title"><span class="caseTitle"> XBA <em>v</em> XBB </span><br><span class="Citation offhyperlink"><a class="pagecontent" href="javascript:viewPageContent('/Judgment/32019-SSP.xml')">[2024] SGFC 62</a></span></h2><table id="info-table"><tbody><tr class="info-row"><td class="txt-label" style="padding: 4px 0px; white-space: nowrap" valign="top">Case Number</td><td class="info-delim1" style="padding: 4px">:</td><td class="txt-body">Divorce No 1182 of 2022</td></tr><tr class="info-row"><td class="txt-label" style="padding: 4px 0px; white-space: nowrap" valign="top">Decision Date</td><td class="info-delim1" style="padding: 4px">:</td><td class="txt-body">20 August 2024</td></tr><tr class="info-row"><td class="txt-label" style="padding: 4px 0px; white-space: nowrap" valign="top">Tribunal/Court</td><td class="info-delim1" style="padding: 4px">:</td><td class="txt-body">Family Court</td></tr><tr class="info-row"><td class="txt-label" style="padding: 4px 0px; white-space: nowrap" valign="top">Coram</td><td class="info-delim1" style="padding: 4px">:</td><td class="txt-body"> Shobha Nair </td></tr><tr class="info-row"><td class="txt-label" style="padding: 4px 0px; white-space: nowrap" valign="top">Counsel Name(s)</td><td class="info-delim1" style="padding: 4px">:</td><td class="txt-body"> Chew Wei En (Teoh & Co) for the Plaintiff; Defendant-in-Person </td></tr><tr class="info-row"><td class="txt-label" style="padding: 4px 0px; white-space: nowrap" valign="top">Parties</td><td class="info-delim1" style="padding: 4px">:</td><td class="txt-body"> XBA — XBB </td></tr></tbody></table> <p class="txt-body"><span style="font-style:italic">Family Law</span> – <span style="font-style:italic">Variation of consent order</span> – <span style="font-style:italic">Custody, care and control of child</span> – <span style="font-style:italic">Child maintenance</span></p> <p></p><table border="0" cellpadding="0" cellspacing="0" width="100%"><tbody><tr><td width="80%"><p class="Judg-Hearing-Date">20 August 2024</p></td><td><p class="Judg-Date-Reserved"></p></td></tr></tbody></table><p></p> <p class="Judg-Author"> District Judge Shobha Nair:</p> <p class="Judg-Heading-1"> <u>Introduction</u> </p> <p class="Judg-1"><a id="p1_1"></a>1 Parties are divorced and all ancillary matters were resolved after mediation conducted at the Family Court, resulting in a consent order recorded in January 2023. In the matter before me, the ex-husband sought variation of the orders, largely related to the care of their 6-year-old son and the maintenance that was payable to support his expenses. More specifically, he asked that:</p> <p class="Judg-2"><a id="p1_1-p2_a"></a>(a) the joint custody order that was agreed to between parties be varied to allow him to unilaterally decide on the child’s education and medical concerns in the event parties could not agree on them. <em>I dismissed this request but added that given the immediate need for the child to be registered for primary school, the ex-wife shall make the decision in the event parties are unable to reach agreement on the choice of school.</em></p> <p class="Judg-2"><a id="p1_1-p2_b"></a>(b) the original order which allowed for shared care and control of the child be varied to reflect specific days and times every week for the ex-husband to provide care for his child. He also sought that the child be returned home by 9 p.m. should either party bring the child out of the home and that “no romantic third parties (be) present during each party’s care period”. <em>I allowed the request to the extent that the child could be with his father every Wednesday after kindergarten ends to 8 p.m. on Fridays.</em></p> <p class="Judg-2"><a id="p1_1-p2_c"></a>(c) the maintenance for the child be reduced to $500 per month from $2 000 per month with educational expenses being paid by the ex-husband solely and directly to the kindergarten/childcare centre. <em>This was dismissed save that I had ordered the ex-wife to produce proof of kindergarten, childcare, tuition fees and medical cost before payment is made.</em></p> <p class="Judg-2"><a id="p1_1-p2_d"></a>(d) the ability of the ex-wife to remain at the home be until such time she remarries. <em>By the time the matter came before the court however, the ex-wife had already left the home with the child making this request for her to move out redundant.</em> She had also confirmed that she had registered her marriage with her new partner in May 2024. A child from this union was due to be delivered when parties came for the hearing.</p> <p class="Judg-2"><a id="p1_1-p2_e"></a>(e) the child attend counselling. <em>I made no order on this as there was an absence of any indication of the nature of counselling that was sought, why it was sought for the child alone and where or who was to provide this. Instead, I directed the engagement of the court’s counselling and psychological services unit to provide more information to the parties.</em></p> <p class="Judg-2"><a id="p1_1-p2_f"></a>(f) the passport of the child be returned to the ex-husband by the ex-wife and that she is not to travel with the child without the ex-husband’ consent. <em>This was dismissed.</em></p> <p class="Judg-1"><a id="p1_2"></a>2 Against these orders, the ex-husband appeals. He also appeals on my order that each party was to bear his or her own costs for the matter.</p> <p class="Judg-Heading-1"> <u>Varying Consent Orders</u> </p> <p class="Judg-1"><a id="p1_3"></a>3 The courts have been slow to vary consent orders. In family matters, the need for members of a family to progress beyond the grief arising from the breakdown of a family is assisted by the process of mediation which if successful, allows parties to own and therefore be empowered by the agreements that they reach. To unravel this would be to revisit the grief that they are encouraged to move from. There is also the potential for abuse if requests are made soon after mediated settlements especially if it were for the simple reason that one party feels that he no longer wants to abide by its terms. When it involves care arrangements and financial support for children, patience must be exercised, and sufficient time must be taken by the parties to allow the agreement to work.</p> <p class="Judg-1"><a id="p1_4"></a>4 Section 128 of the Women’s Charter (1961) provides for the ability of a parent to seek variation of a custody and/or care and control order if there was any misrepresentation or mistake of fact or a material change in circumstances. In <b><em>DDN</em></b> v <b><em>DDO</em></b><span class="FootnoteRef"><a href="#Ftn_1" id="Ftn_1_1"><sup>[note: 1]</sup></a></span> the Appellate Division stated that while a court would take a holistic approach to assess what constitutes a material change in circumstances for issues relating to the welfare of a child, this should not encourage parties to pursue variation of orders at the earliest opportunity. The parents are to do their best in to successfully implement the ordered arrangements.</p> <p class="Judg-1"><a id="p1_5"></a>5 Similarly, an order for the maintenance of children made pursuant to s 127 of the Charter can be varied if there are material changes in circumstances or for any other good cause, the latter allowing a court a wide approach to variation.<span class="FootnoteRef"><a href="#Ftn_2" id="Ftn_2_1"><sup>[note: 2]</sup></a></span> When a paying party meets with a situation that significantly impacts his ability to pay, for example the loss of employment or a serious health concern, variation is typically allowed. Much too often however even the smallest of change in the expenses of a child sees a parent applying for variation in these courts. A child’s expenses will change, sometimes even within the month orders are made. Parents should pause and consider aspects such as the cost of living, the need to provide for ad hoc or unexpected expenses before applying for variation and understand that in certain months, not all of the maintenance is used up and in certain others, more is needed. The agreed amount should continue to be paid with such an awareness.</p> <p class="Judg-Heading-1"> <u>Joint custody of the child – should there be variation?</u> </p> <p class="Judg-1"><a id="p1_6"></a>6 The need to co-parent, sometimes even in the most volatile of relationships between former spouses has been extensively written on. The roots of co-parenting are respect for the needs of a child, a child who is born from the union of 2 people and who therefore deserves the involvement of each parent. Parenting does not end on the termination of a marriage. In fact, it should continue even stronger, freed from the tension and anxiety between parents caught in circumstances that they did not hope for at the inception of the marriage. Yet, continuing disagreement between parents even over the smallest of things make co-parenting appear theoretically sound but sometimes, a practical nightmare.</p> <p class="Judg-1"><a id="p1_7"></a>7 In the matter before me, the ex-husband did not seek a change to the joint custody arrangement that was agreed to but asked that he be given the sole decision-making ability when it came to the educational and medical needs of his son should the parties not be able to agree on issues arising in these areas. In cases where parties are not working well together, there is a real possibility that the interests of the child are compromised as a result. At the same time, allowing one parent to make all decisions relating to the education and health concerns of a child where parties cannot agree is often a licence given to that parent to point quickly to the slightest disagreement as basis for unilateral decision-making. I saw no need to change the order given that it was entered into only in January 2023 and parties have yet to begin to work together on these issues. There is certainly an issue with communication but in my view, the challenges were not being posed by the ex-wife alone.</p> <p class="Judg-1"><a id="p1_8"></a>8 The child is in his second and final year of kindergarten. The ex-husband was concerned that his child was developing slower than his peers and accused the mother of not taking steps to better prepare the child for primary school, especially for Mandarin. He also alleged that she failed to attend at an organisation that was recommended to them by the child’s school for assessment to be conducted in order to ascertain if there were any needs which requires medical intervention. He wanted the child to move to another childcare centre he believed would support his child’s needs better.<span class="FootnoteRef"><a href="#Ftn_3" id="Ftn_3_1"><sup>[note: 3]</sup></a></span> The ex-wife showed to the court another report from the school which presented a different and more positive picture. I could not place weight on that as it was unsigned.<span class="FootnoteRef"><a href="#Ftn_4" id="Ftn_4_1"><sup>[note: 4]</sup></a></span>The mother however had also taken the child for assessment at a local children’s hospital and the child was continuing with speech therapy at the hospital. She informed that the child was progressing well. She had also arranged for tuition classes so that he could be better prepared for primary school.<span class="FootnoteRef"><a href="#Ftn_5" id="Ftn_5_1"><sup>[note: 5]</sup></a></span> While these steps appear to be taken late in the day suggesting that she had wanted to advance her cause in these proceedings, there was no suggestion that she was negligent or that she would cease all assistance after proceedings. She spoke through an Interpreter during the hearing as she was in person. There was a genuine expression of concern for her son. What appears to be standing between parties is a different set of expectations on what a 6-year-old child should be exposed to as he prepares for primary school. She also claimed that she did not take up the suggestion to bring the child to the alternative assessment centre as she felt it would be better for the assessments at the hospital to be completed.<span class="FootnoteRef"><a href="#Ftn_6" id="Ftn_6_1"><sup>[note: 6]</sup></a></span>The local hospital is well known and regarded for its services in the development of infants and children and the ex-wife’s choice appears prudent.</p> <p class="Judg-1"><a id="p1_9"></a>9 I intervened on one specific issue and that was in relation to the choice of primary school. Again, it is hoped that parties will agree but given that the need to register the child for primary school was coming up in July and parties were still unable to agree, I allowed the ex-wife to make that decision. The ex-wife had moved out with the child, has remarried and has permanent accommodation in Yishun. Her choice of school was one that was proximate to her new home. Given the imminent need to make a decision on the choice of school, I allowed the mother to make the decision as she was the main caregiver of the child at this point in time.</p> <p class="Judg-Heading-1"> <u>Shared care and control – is further refinement necessary?</u> </p> <p class="Judg-1"><a id="p1_10"></a>10 When the consent order on ancillary matters was made, the parties were living together. At the time this application was taken for variation, they were still in the same home. What then was the basis for the variation that was sought? It was the ex-husband’s position that the ex-wife restricted his time with his child and that the child was alienated from him. He pointed to the presence of the ex-wife’s new partner as instrumental in this difficulty.<span class="FootnoteRef"><a href="#Ftn_7" id="Ftn_7_1"><sup>[note: 7]</sup></a></span>I found this hard to appreciate because the ex-wife was working and there were many times when the ex-husband was alone with his son. It was the ex-wife’s position that her former spouse never engaged with his son and that much of the interaction was with the domestic helper. She denied that access was prevented or restricted by her. They both attempted to show photographs and recordings to prove their point. I did not find any evidence of alienation. Indeed, it is difficult to make such a determination without a hearing which enables the evidence to be tested (<b><em>WQT</em></b> v <b><em>WQU</em></b>).<span class="FootnoteRef"><a href="#Ftn_8" id="Ftn_8_1"><sup>[note: 8]</sup></a></span> What is clear however is that a few supervised visitation sessions at a Divorce Support Specialist Agency (DSSA) were scheduled for the ex-husband to connect with the child. It was the ex-husband’s position that it had ceased because the counsellors were of the view that the father-son relationship was good and there was no need for the sessions to continue.<span class="FootnoteRef"><a href="#Ftn_9" id="Ftn_9_1"><sup>[note: 9]</sup></a></span> The ex-wife claimed that it was the ex-husband who wanted to terminate the access at the DSSA as seen in the messages from the DSSA<span class="FootnoteRef"><a href="#Ftn_10" id="Ftn_10_1"><sup>[note: 10]</sup></a></span> and that it showed how reluctant he was to participate or be truly involved in the child’s life.<span class="FootnoteRef"><a href="#Ftn_11" id="Ftn_11_1"><sup>[note: 11]</sup></a></span> If indeed as stated by the ex-husband, his interaction with his son was good at least during supervised access, any allegation that the ex-wife had successfully alienated the child is unlikely. It is more probable that the child is somewhat caught in the middle of parents who no longer get along. With the parents now living apart, creating a safe space and time for father and son will if the opportunity is taken up, be the beginning of a new and better relationship.</p> <p class="Judg-1"><a id="p1_11"></a>11 As the ex-wife and child had left the home they shared with the ex-husband by the time this matter came up for hearing, I felt it prudent to define the dates and times when the father should have the child with him and provide care for him. I defined the days to be Wednesdays to Fridays (till 8 p.m.) which in my view is long enough to enable good contact and the provision of relevant care in the larger context of little to no access in the recent past and the father’s own position that as recently as September 2023 the access to his child was positive and did not require external intervention. At the same time, it was short enough to prevent a situation where the child having just moved to a new home would need to make significant changes to his routine.</p> <p class="Judg-1"><a id="p1_12"></a>12 Although the dates and times that I had allowed the ex-husband to use to care for his son do effectively take the form of access rather than shared care and control, I chose not to define it as such as this application is in my view rather premature and would benefit from further assessment in the year ahead. The arrangement put in place is not ideal because the child will be in primary 1 next year yet it is necessary at this time given that the ex-husband needs to be engaged with the child immediately and consistently.</p> <p class="Judg-1"><a id="p1_13"></a>13 With formal schooling, the need for change to the orders is inevitable. An assessment taking into account where the child will be studying and living as well as the demands of school life would need to be made. I had given liberty to parties to vary this order at the appropriate time. At the time of the hearing, I was not entirely certain of important aspects which may determine the way forward for parties. There was suggestion for example that the ex-husband may remarry. A more permanent care arrangement would be contingent on aspects like the child’s residence, new family structures, the location of the child’s primary school, the school schedules, and whether he will be placed in a student care after school.</p> <p class="Judg-1"><a id="p1_14"></a>14 It was also the father’s request that if the child is brought out by the ex-wife, she would need to return him home by 9 p.m. and that no third party should be present during these outings. With the mother’s remarriage, the child’s family structure has changed even as his biological father should certainly continue with all the rights and responsibilities that come with a parent-child relationship. As for the child returning home by 9 p.m. everyday, I thought this too restrictive as there would be instances when the child may have to return a little later. There was nothing in the evidence other than the ex-husband suggesting that the ex-wife had been staying out late with her partner that warranted such an order. The circumstances of the ex-wife has materially changed as well which made such a request unnecessary. She has a new child with her husband and the need to care for the differing needs of an infant and her 6-year-old son would spell very few late nights, at least for the short to medium term.</p> <p class="Judg-Heading-1"> <u>Maintenance – who should payment be made to?</u> </p> <p class="Judg-1"><a id="p1_15"></a>15 Under the consent order, maintenance for the child was agreed at $ 2 000 per month. The ex-husband did not dispute the need for this amount nor his ability in providing it. He wanted to vary this amount to $500 per month and in addition, he wanted to pay for the child’s educational expenses directly to the schools/childcare centres. His position was that the ex-wife was not utilising the money for the child’s educational needs as she had failed to pay for his school fees.<span class="FootnoteRef"><a href="#Ftn_12" id="Ftn_12_1"><sup>[note: 12]</sup></a></span> The ex-wife responded that she had paid for it regularly but that her ex-husband had proceeded to pay it for the months of May and June without informing her. He then informed her that he would be shaving an amount off the monthly maintenance to reflect the payment he had made directly to the school.</p> <p class="Judg-1"><a id="p1_16"></a>16 There was no proof that the child only required $500 per month if and when the ex-husband provided for the child’s educational expenses separately and directly to the school. What parties accepted as expenses of the child when the matter was mediated is not known. Food, clothing, medical expenses, accommodation are basic expenses which maintenance seeks to help support. The arbitrary sum of $500 was not adequately supported by documentation. He also did not share what educational expenses he was willing to provide directly for. Would it include for example, the assessments and therapy? What if more therapy is required? The husband appears to want control of what he pays for and I did not find that the ex-wife had intentionally refused to cater for their son from the maintenance given to her. Having said that, and while there was no material change in circumstances nor any good reason to vary the maintenance payment agreed to, it is important to prevent any fear of child maintenance being misused especially because it is a long-term commitment by the paying party. In some cases, it would promote understanding between parties for the receiving party to account for the expenses of the child which may change quite dramatically for young children entering different phases in their education. The ex-wife for example said that she had engaged tutors for the child.<span class="FootnoteRef"><a href="#Ftn_13" id="Ftn_13_1"><sup>[note: 13]</sup></a></span> Additionally, she wanted to continue to have the child remain at the same childcare centre till the child enters primary 1 which the husband was not in agreement with. The ex-husband should be provided with documentation that these expenses continue to be relevant and I ordered that documentation for all school fees, childcare fees, tuition and medical expenses be notified to the ex-husband. The other expenses such as food, clothing and accommodation need not be accounted and was clearly within contemplation of the parties when the agreement for an amount of $2 000 per month was entered into.</p> <p class="Judg-Heading-1"> <u>Should counselling be ordered for the child?</u> </p> <p class="Judg-1"><a id="p1_17"></a>17 One of the cornerstones of therapeutic justice is counselling and psychological services which if appropriately applied, can have a tremendous positive long-term impact on the lives of families. It is important however not to seek counselling for a 6-year-old child without any reference to the nature of the difficulty the child is experiencing and the type of programme that is being sought. The ex-husband through his counsel had not explained why only the child needed counselling and what exactly needed to be addressed. It is important to be mindful that the court cannot assume the nature of intervention. Counsel forwarding such requests should be clear on what, why and who they wish to engage for the specified purpose. There are many programmes available, and it is the obligation of counsel and his client to inform of the concerns and challenges. If it is to address access issues, these would already have been done at the DSSA which has not terminated its services. If it is to address developmental concerns, counselling would not be appropriate. In any event, the ex-wife seems to have taken steps in this regard at the local children’s hospital. I had in my orders called on the counselling and psychological services within the family court to engage the parties on appropriate channels of assistance if they required support.</p> <p class="Judg-Heading-1"> <u>Who should hold the child’s passport?</u> </p> <p class="Judg-1"><a id="p1_18"></a>18 The ex-husband sought that the passport of the child be given to him. He expressed fear that the ex-wife would leave Singapore with the child. Although the wife is Thai, there is no indication that she would flee to Thailand to prevent any contact with the ex-husband. She is married with her new family in Singapore. The only time she went to Thailand in the recent past was in 2023 after the challenges of the pandemic restored travel fully. She claimed that she was prevented from travelling by the ex-husband prior to this and disagreed with any suggestion of an intention to run off with her child.<span class="FootnoteRef"><a href="#Ftn_14" id="Ftn_14_1"><sup>[note: 14]</sup></a></span>I found no need to have the passport retained by the ex-husband. If she wishes to take the child abroad, she should be free to do so.</p> <p class="Judg-Heading-1"> <u>Costs</u> </p> <p class="Judg-1"><a id="p1_19"></a>19 The ex-husband appeals against my order on costs. I had ordered that the parties were to bear his or her own costs for the matter. The ex-husband succeeded in part but was largely unsuccessful. I found his positions rooted in a sense of mistrust of the intentions of his ex-wife who has started a new life in Singapore rather than any real difficulty in engaging with his son. The issues were not complex, and the ex-husband had filed 2 affidavits for the matter. I did not believe that this was a case for an order of costs to be made against the ex-wife who appeared in person.</p> <p class="Judg-Heading-1"> <u>Conclusion</u> </p> <p class="Judg-1"><a id="p1_20"></a>20 Consent orders should not be varied with ease. In this case, the matter was mediated, and the parties agreed on all issues related to their child in 2023 only for the ex-husband to seek variation so quickly in 2024.</p> <p class="Judg-1"><a id="p1_21"></a>21 The need for the child to bond with his father is an imperative. The child’s step-father cannot replace the biological father-son relationship. The relationships can certainly co-exist meaningfully. Equally important is the need for the parents to start to speak civilly with each other to enhance the potential for a successful parenting journey. The consent order needs time to work. I have structured the time each parent has with the child to allow for the relationship to resume if disrupted, and to grow. The reality is that the child will commence formal schooling next year and his needs will change continuously, and an assessment would be prudent next year. It is not for the parents to dictate what they each want. It is always about what the child needs. The child’s changing circumstances will inevitably dictate the response that the parents need to adopt.</p> <hr align="left" size="1" width="33%"><p class="Footnote"><sup><a href="#Ftn_1_1" id="Ftn_1">[note: 1]</a></sup>[2024] SGHC(A) at paragraph 17.</p><p class="Footnote"><sup><a href="#Ftn_2_1" id="Ftn_2">[note: 2]</a></sup>Section 72 of the Women’s Charter.</p><p class="Footnote"><sup><a href="#Ftn_3_1" id="Ftn_3">[note: 3]</a></sup>Paragraph 19 of the ex-husband’s affidavit of 7 August 2023.</p><p class="Footnote"><sup><a href="#Ftn_4_1" id="Ftn_4">[note: 4]</a></sup>Tab B, page 15 of the ex-wife’s affidavit of 4 May 2024.</p><p class="Footnote"><sup><a href="#Ftn_5_1" id="Ftn_5">[note: 5]</a></sup>Ibid. at paragraphs 14-16.</p><p class="Footnote"><sup><a href="#Ftn_6_1" id="Ftn_6">[note: 6]</a></sup>Ibid.at paragraph 7.</p><p class="Footnote"><sup><a href="#Ftn_7_1" id="Ftn_7">[note: 7]</a></sup>Paragraph 25 of the affidavit of the ex-husband dated 7 August 2023.</p><p class="Footnote"><sup><a href="#Ftn_8_1" id="Ftn_8">[note: 8]</a></sup><a class="pagecontent" href="javascript:viewPageContent('/Judgment/24154-SSP.xml')">[2020] SGHCF 3</a></p><p class="Footnote"><sup><a href="#Ftn_9_1" id="Ftn_9">[note: 9]</a></sup>Affidavit of ex-husband dated 5 March 2024.</p><p class="Footnote"><sup><a href="#Ftn_10_1" id="Ftn_10">[note: 10]</a></sup>Tab A, page 13 of the ex-wife’s affidavit of 4 May 2024.</p><p class="Footnote"><sup><a href="#Ftn_11_1" id="Ftn_11">[note: 11]</a></sup>Ibid. at paragraph 5.</p><p class="Footnote"><sup><a href="#Ftn_12_1" id="Ftn_12">[note: 12]</a></sup>Paragraph 38 of the ex-husband’s affidavit of 7 August 2023.</p><p class="Footnote"><sup><a href="#Ftn_13_1" id="Ftn_13">[note: 13]</a></sup>Tab C, page 20 of the ex-wife’s affidavit of 4 May 2024.</p><p class="Footnote"><sup><a href="#Ftn_14_1" id="Ftn_14">[note: 14]</a></sup>Paragraph 7 of ex-wife’s affidavit of 4 May 2024.</p></div></content></root> | 1793 |
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