fc_judgments_version: 37
This data as json
| _id | _item | _version | _commit | tags | date | court | case-number | title | citation | url | counsel | timestamp | coram | html | _item_full_hash |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 37 | 29 | 1 | 1308 | [
"Civil Procedure \u2013 Discovery",
"Civil Procedure \u2013 Interrogatories"
] |
2024-05-09 | Family Court | Divorce No 3523 of 2022 (Summons No 632, 633, 682 and 684 of 2024) | WWS v WWT | [2024] SGFC 24 | 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%2F31488-SSP.xml | [
"Arul Suppiah Thevar (APL Law Corporation) for the Plaintiff",
"Chai Li Li Dorothy, Lai Mun Loon (DCMO Law Practice LLC) for the Defendant"
] |
2024-05-16T16:00:00Z[GMT] | Soh Kian Peng | <root><head><title>WWS v WWT</title></head><content><div class="contentsOfFile"> <h2 align="center" class="title"><span class="caseTitle"> WWS <em>v</em> WWT </span><br><span class="Citation offhyperlink"><a class="pagecontent" href="javascript:viewPageContent('/Judgment/31488-SSP.xml')">[2024] SGFC 24</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 3523 of 2022 (Summons No 632, 633, 682 and 684 of 2024)</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">09 May 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"> Soh Kian Peng </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"> Arul Suppiah Thevar (APL Law Corporation) for the Plaintiff; Chai Li Li Dorothy, Lai Mun Loon (DCMO Law Practice LLC) for the Defendant </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"> WWS — WWT </td></tr></tbody></table> <p class="txt-body"><span style="font-style:italic">Civil Procedure</span> – <span style="font-style:italic">Discovery</span></p> <p class="txt-body"><span style="font-style:italic">Civil Procedure</span> – <span style="font-style:italic">Interrogatories</span></p> <p></p><table border="0" cellpadding="0" cellspacing="0" width="100%"><tbody><tr><td width="80%"><p class="Judg-Hearing-Date">9 May 2024</p></td><td><p class="Judg-Date-Reserved">Judgment reserved</p></td></tr></tbody></table><p></p> <p class="Judg-Author"> Assistant Registrar Soh Kian Peng:</p> <p class="Judg-Heading-1">Introduction</p> <p class="Judg-1"><a id="p1_1"></a>1 Suspicion and distrust are two defining features marking the breakdown of a marriage. This often manifests itself when parties, anticipating divorce, attempt to dispose of, or conceal their assets: see <em>UZN v UZM</em> <a class="pagecontent" href="javascript:viewPageContent('/SLR/25771-SSP.xml')">[2021] 1 SLR 426</a> (“<em>UZN</em>”); <em>TIT v TIU and another appeal</em> <a class="pagecontent" href="javascript:viewPageContent('/SLR/19108-SSP.xml')">[2016] 3 SLR 1137</a> at [32]. Such attempts, if successful, would deplete the deferred community of property arising upon the termination of marriage.</p> <p class="Judg-1"><a id="p1_2"></a>2 There is, however, a mechanism by which such attempts may be stifled and brought to light. Parties can, if they suspect that matrimonial assets are being dissipated or concealed, apply for discovery and interrogatories. The respondent to such an application must comply with any order for disclosure. They cannot hide. If they do, the court hearing the ancillary matters can draw an adverse inference from the failure to make full and frank disclosure: <em>UZM</em> at [18] – [21] citing <em>BPC v BPB and another appeal</em> <a class="pagecontent" href="javascript:viewPageContent('/SLR/23037-SSP.xml')">[2019] 1 SLR 608</a> (see also <em>AFS v AFU</em> <a class="pagecontent" href="javascript:viewPageContent('/SLR/[2011] 3 SLR 0275.xml')">[2011] 3 SLR 275</a> at [40] – [45]).</p> <p class="Judg-1"><a id="p1_3"></a>3 The present case before me concerned a total of four applications taken out by both the Wife and the Husband for discovery and interrogatories. These applications appear to have been motivated by the fact that each party suspected the other of hiding or concealing their assets.</p> <p class="Judg-1"><a id="p1_4"></a>4 I heard oral arguments by counsel for both parties on 2 May 2024. This is my decision in respect of the four applications: SUM 632/2024 (“SUM 632”), SUM 633/2024 (“SUM 633”), SUM 682/2024 (“SUM 682”), SUM 684/2024 (“SUM 684”).</p> <p class="Judg-Heading-1">Background</p> <p class="Judg-1"><a id="p1_5"></a>5 The parties were married on 31 May 2007. They had a child shortly thereafter. In the years that followed, the family weathered the vicissitudes of life together. The Husband was imprisoned, and the responsibility of caring for the child fell to the Wife. Upon the Husband’s release, Company A was set up. Its’ business lay in the provision of courier services.</p> <p class="Judg-1"><a id="p1_6"></a>6 Relations between the couple, however, were strained, and deteriorated to the point where the Husband moved out of the matrimonial home in July 2021.<span class="FootnoteRef"><a href="#Ftn_1" id="Ftn_1_1"><sup>[note: 1]</sup></a></span> A few months later, the Husband cut off all contact with the Wife. This was, as far as the Wife was concerned, the straw that broke the camel’s back. She filed for divorce a few months later on 2 August 2022. Interim judgment was granted on 25 October 2022. In an attempt to find common ground on the ancillary matters, parties attended mediation. No resolution was forthcoming.</p> <p class="Judg-1"><a id="p1_7"></a>7 This set parties on the road to an ancillary matters hearing. Parties exchanged their Affidavit of Means (“AOMs”) on 30 October 2023, and were directed to exchange voluntary discovery and interrogatories in a Case Conference on 9 November 2023.<span class="FootnoteRef"><a href="#Ftn_2" id="Ftn_2_1"><sup>[note: 2]</sup></a></span></p> <p class="Judg-1"><a id="p1_8"></a>8 Dissatisfied with what information and documents they had received from this voluntary exchange, the Wife and Husband both took out summons for discovery and interrogatories.</p> <p class="Judg-Heading-1">Parties’ application for discovery and interrogatories </p> <p class="Judg-Heading-2">The Wife’s application in SUM 632 and SUM 633</p> <p class="Judg-1"><a id="p1_9"></a>9 The Wife’s application for interrogatories were grouped in the following order. First, questions relating to the Husband’s sources of income – specifically, whether he had any other sources of income outside of his job as director of Company A.<span class="FootnoteRef"><a href="#Ftn_3" id="Ftn_3_1"><sup>[note: 3]</sup></a></span> Second, questions relating to the Husband’s bank accounts – specifically, whether he had any other accounts apart from those disclosed in his AOM.<span class="FootnoteRef"><a href="#Ftn_4" id="Ftn_4_1"><sup>[note: 4]</sup></a></span></p> <p class="Judg-1"><a id="p1_10"></a>10 Third, questions relating to whether any other person or entity had held cash on behalf of the Husband.<span class="FootnoteRef"><a href="#Ftn_5" id="Ftn_5_1"><sup>[note: 5]</sup></a></span> Fourth, questions relating to insurance policies – specifically, whether the husband had held any other insurance policies from the date of marriage, apart from those disclosed in his AOM.<span class="FootnoteRef"><a href="#Ftn_6" id="Ftn_6_1"><sup>[note: 6]</sup></a></span></p> <p class="Judg-1"><a id="p1_11"></a>11 Fifth, questions relating to the details of any loans or gifts that the Husband had made to any person.<span class="FootnoteRef"><a href="#Ftn_7" id="Ftn_7_1"><sup>[note: 7]</sup></a></span> Sixth, questions relating to whether the Husband had disposed of any assets (<em>ie</em>, property, cash, cars) that were either owned by him individually or jointly.<span class="FootnoteRef"><a href="#Ftn_8" id="Ftn_8_1"><sup>[note: 8]</sup></a></span> The Wife also sought an explanation for various deposits and withdrawals from the Husband’s bank account.<span class="FootnoteRef"><a href="#Ftn_9" id="Ftn_9_1"><sup>[note: 9]</sup></a></span> Finally, the Wife also wanted answers as to the Husband’s current residential address, as well as whether he owned any credit cards, and if so, whether there were any supplementary cards, and an explanation as to what had happened to the $100,000 of cash that had been deposited into the safe box in the matrimonial flat.<span class="FootnoteRef"><a href="#Ftn_10" id="Ftn_10_1"><sup>[note: 10]</sup></a></span></p> <p class="Judg-1"><a id="p1_12"></a>12 The Wife takes the position that these interrogatories are relevant in determining whether the Defendant had made a full disclosure of his assets as well as his income. This would have a direct bearing on the division of matrimonial assets.</p> <p class="Judg-1"><a id="p1_13"></a>13 As for the Wife’s application for discovery, that fell into three broad categories. First, for documents pertaining to Company A – these included documents such as Company A’s articles of association and company memorandum and financial statements from 2022 – 2023.<span class="FootnoteRef"><a href="#Ftn_11" id="Ftn_11_1"><sup>[note: 11]</sup></a></span></p> <p class="Judg-1"><a id="p1_14"></a>14 The Wife explains that these documents are relevant because they establish her contributions towards the company, as well as the Husband’s earning capacity and/or means. The Wife has also pointed out that there is no reason why the Husband cannot produce these documents given that he is currently the sole director and shareholder of Company A, having removed her name without her consent.<span class="FootnoteRef"><a href="#Ftn_12" id="Ftn_12_1"><sup>[note: 12]</sup></a></span></p> <p class="Judg-1"><a id="p1_15"></a>15 Second, documents relating to the Husband’s personal finances – these include CPF transaction statements for the past 12 months, as well as receipts of household expenses.<span class="FootnoteRef"><a href="#Ftn_13" id="Ftn_13_1"><sup>[note: 13]</sup></a></span> Here, the Wife explains that these documents are relevant because they establish the Husband’s earning capacity and/or means, and are also necessary for the division of matrimonial assets.</p> <p class="Judg-1"><a id="p1_16"></a>16 Third, documents relating to two questions posed in her Request for Interrogatories. These questions concerned whether the Husband had any other sources of income or credit cards. In relation to the former, the Wife stated, in her affidavit, that the Husband had other businesses apart from Company A.<span class="FootnoteRef"><a href="#Ftn_14" id="Ftn_14_1"><sup>[note: 14]</sup></a></span> She therefore sought documents (<em>ie</em>, ACRA business profile, financial statements) relating to those businesses. As for the latter, the Wife had also stated that the Husband had other credit cards,<span class="FootnoteRef"><a href="#Ftn_15" id="Ftn_15_1"><sup>[note: 15]</sup></a></span> and sought statements for those credit cards for the past 12 months.</p> <p class="Judg-Heading-2">The Husband’s application in SUM 682 and SUM 684</p> <p class="Judg-1"><a id="p1_17"></a>17 The Husband’s application for interrogatories all related to the Wife’s finances. He sought information about her source of income,<span class="FootnoteRef"><a href="#Ftn_16" id="Ftn_16_1"><sup>[note: 16]</sup></a></span> details about her bank accounts (including inflows and outflows of funds),<span class="FootnoteRef"><a href="#Ftn_17" id="Ftn_17_1"><sup>[note: 17]</sup></a></span> and whether she had taken any loans from her insurance policy which was disclosed in her Affidavit of Means (“AOM”).<span class="FootnoteRef"><a href="#Ftn_18" id="Ftn_18_1"><sup>[note: 18]</sup></a></span></p> <p class="Judg-1"><a id="p1_18"></a>18 The Husband’s application for discovery mirrored his request for interrogatories.<span class="FootnoteRef"><a href="#Ftn_19" id="Ftn_19_1"><sup>[note: 19]</sup></a></span></p> <p class="Judg-1"><a id="p1_19"></a>19 The Husband justified his request for interrogatories and discovery on the basis that he had reason to believe that the Wife had worked for other companies, apart from those disclosed in her AOM, and been paid by these companies. The Husband also claimed, in his affidavit, that despite working and drawing a good income in addition to a lump sum of $122,000 that she had amassed, it was puzzling that she only had the sum of $339.30 left in her bank account.<span class="FootnoteRef"><a href="#Ftn_20" id="Ftn_20_1"><sup>[note: 20]</sup></a></span> In this vein, this made it necessary for him to get hold of her account statements with the banks and financial institutions.<span class="FootnoteRef"><a href="#Ftn_21" id="Ftn_21_1"><sup>[note: 21]</sup></a></span></p> <p class="Judg-1"><a id="p1_20"></a>20 As for the Wife’s insurance policies, the Husband’s position was that information and documents relating to those policies were necessary to confirm if those policies had been purchased prior to the marriage. This would allow the court to determine whether these policies should be considered a matrimonial asset.<span class="FootnoteRef"><a href="#Ftn_22" id="Ftn_22_1"><sup>[note: 22]</sup></a></span></p> <p class="Judg-Heading-1">My decision</p> <p class="Judg-Heading-2">The law on discovery and interrogatories in family proceedings </p> <p class="Judg-1"><a id="p1_21"></a>21 Discovery and interrogatories allow parties to a divorce proceeding to seek further information and documents from the other following the filing of the first AOM. The former concerns the disclosure of documents, whilst the latter allows for information to be sought in the form of answers to questions posed: <em>UJN v UJO</em> <a class="pagecontent" href="javascript:viewPageContent('/Judgment/21836-SSP.xml')">[2018] SGFC 47</a> (“<em>UJN</em>”) at [9].</p> <p class="Judg-1"><a id="p1_22"></a>22 Rules 63 – 77 of the Family Justice Rules 2014 (“FJR”) govern the process of discovery and interrogatories in ancillary matters proceedings. Parties seeking discovery and interrogatories must establish that their request for information or documents are not only relevant, but also necessary for the fair and efficient disposal of the matter: <em>UJN</em> at [10].</p> <p class="Judg-1"><a id="p1_23"></a>23 It has been stated that the test for what is relevant in family cases is very wide: <em>Tan Bin Yong Christopher v Ng Lay Mui (m.w.) and other cases</em> <a class="pagecontent" href="javascript:viewPageContent('/Judgment/25533-M.xml')">[2003] SGDC 306</a> (“<em>Tan Bin Yong Christopher</em>”) at [13]. The reason for this is to ensure that the issues are properly delineated, and that all the necessary evidence is made available by the time of the ancillary hearing.</p> <p class="Judg-1"><a id="p1_24"></a>24 This, however, does not mean that discovery or interrogatories will automatically be allowed once their relevance to the ancillary matters hearing can be shown. Necessity must also be established. In the context of discovery, this means that the court must “strike a balance between the importance and relevance of the documents sought and the hardship to the party seeking discovery which is likely to be caused by non-production, against any prejudice likely to be caused to the other party if an order to produce documents or provide information is made”: <em>VTQ v VTR</em> <a class="pagecontent" href="javascript:viewPageContent('/Judgment/26432-SSP.xml')">[2021] SGFC 85</a> (“<em>VTQ</em>”) at [26] citing <em>Tan Bin Yong Christopher</em> at [13].</p> <p class="Judg-1"><a id="p1_25"></a>25 Having sketched out the broad principles governing applications for discovery and interrogatories, I turn now to set out my reasons in respect of the applications filed by both the Wife and Husband.</p> <p class="Judg-Heading-2">SUM 633</p> <p class="Judg-1"><a id="p1_26"></a>26 I deal, first, with the Wife’s application for interrogatories. It was clear to me that the Wife was seeking these interrogatories because she did not believe the Husband’s answers. Indeed, she had said as much in her affidavit.<span class="FootnoteRef"><a href="#Ftn_23" id="Ftn_23_1"><sup>[note: 23]</sup></a></span> Her counsel had also gone to great lengths in the course of oral arguments, and referred me to various documents which allegedly showed that the Husband had lied in his responses given on 2 February 2024.</p> <p class="Judg-1"><a id="p1_27"></a>27 The Wife is perfectly entitled to disbelieve the Husband’s response, and to mount a vigorous argument that he had been dissipating assets, but the proper forum to ventilate this is at the hearing of ancillary matters. I am not concerned as to the <em>truth</em> of the Husband’s answers, but rather, the <em>sufficiency</em> of those answers: <em>UJN</em> at [12].</p> <p class="Judg-1"><a id="p1_28"></a>28 How then is one to assess the sufficiency of answers in response to interrogatories? It is perhaps useful to look at an example. In <em>Rasbotham v Shropshire Union Railways and Canal Company</em> [1882 R. 2434] 24 Ch D 110 (“<em>Rasbotham</em>”), the plaintiffs, who were owners of water mills and had the statutory right to draw water from the river, sued the defendants, alleging that they had, through their own acts of negligence, polluted the river from which water was drawn for their mill. The defendants sought interrogatories asking the plaintiffs to give a list of specified dates on which the operation of the water mills had allegedly been interfered with. The plaintiffs’ response was that they were unable to specify the particular days on which the interference had taken place.</p> <p class="Judg-1"><a id="p1_29"></a>29 North J dismissed the defendants’ objection that the answer given was insufficient. In reaching this conclusion, North J distinguished the earlier case of <em>Bolckow, Vaughan, & Co. v Fisher and others</em> [1882] 10 QBD 161 (“<em>Bolckow</em>”), which stood for the proposition that where a man is “interrogated as to what he did by his servants or agents, he is not entitled to say that he will not ask them about it" (<em>Rasbotham</em> at p 112). The interrogatory posed did not specifically query the plaintiffs as to what their agents or servants knew. There was also nothing in the present case to show that the “acts referred to [had] been done in the presence of the plaintiffs’ servants or agents”.</p> <p class="Judg-1"><a id="p1_30"></a>30 Short of stating the obvious, in assessing the sufficiency of the response, one must look closely at the wording of the interrogatory posed, as well as the response given. Exactly what is it that is being asked? Has it been answered?</p> <p class="Judg-1"><a id="p1_31"></a>31 Returning to the present application, having read the Husband’s responses, I was satisfied that his answers to 31 out of the 32 interrogatories (Items 1 – 31) posed were indeed sufficient. He had directly answered these 31 questions posed to him. Where the questions posed had sought details, the Husband had provided them.</p> <p class="Judg-1"><a id="p1_32"></a>32 In relation to queries about his other sources of income, he had stated that he had none. As for details of other accounts or investments he may have had with financial institutions or banks, he answered in the affirmative and disclosed the details sought. When queried about whether others had held cash on his behalf, he replied in the affirmative. He stated that the Wife held cash, to the tune of $122,000, on his behalf.</p> <p class="Judg-1"><a id="p1_33"></a>33 As for the interrogatories about other insurance policies he may have had, he stated that, as far as he could remember, he did not own any other insurance policies apart from those disclosed in his AOM.<span class="FootnoteRef"><a href="#Ftn_24" id="Ftn_24_1"><sup>[note: 24]</sup></a></span> As to whether he had made any loans or gifts, he stated that he had not made any loans to any person, but he had gifted a gold bangle to his mother.<span class="FootnoteRef"><a href="#Ftn_25" id="Ftn_25_1"><sup>[note: 25]</sup></a></span></p> <p class="Judg-1"><a id="p1_34"></a>34 The Wife had also asked whether he had disposed of any assets – to which the Husband had replied in the negative.</p> <p class="Judg-1"><a id="p1_35"></a>35 The next set of questions required the Husband to explain various withdrawals and deposits to his personal account. The Husband’s responses were sufficient – he not only set out the details sought (such as owner of the account to whom the monies had been transferred), but also explained the purpose of the transfer.</p> <p class="Judg-1"><a id="p1_36"></a>36 Finally, in relation to the set of miscellaneous interrogatories pertaining to the Husband’s current residence, as well as whether he had any other credit cards apart from those disclosed in his AOM, the Husband had, again, provided the details sought.</p> <p class="Judg-1"><a id="p1_37"></a>37 The one response which I did not find to be sufficient was that in respect of Item 32. This was the interrogatory posed:</p> <p class="Judg-Quote-1">What has happened to the cash amount more than $100,000.00 deposited earlier into the safe box in the matrimonial flat.</p> <p class="Judg-1"><a id="p1_38"></a>38 In stark contrast to his previous responses, all the Husband offered was: “no reply”. This is not a sufficient answer. The interrogatory seeks to know what has become of the cash. It is no answer to simply state “no reply”.</p> <p class="Judg-1"><a id="p1_39"></a>39 I therefore allow the Wife’s application in respect of Item 32. Her application in respect of Items 1 – 31 is disallowed, for the reasons that I have set out above.</p> <p class="Judg-Heading-2">SUM 632</p> <p class="Judg-1"><a id="p1_40"></a>40 I turn now to the Wife’s application for discovery. The first broad category of documents for which discovery was sought related to Company A (Items 1 – 10). The ACRA records disclosed in the Husband’s AOM showed that he was the sole director and shareholder of Company A.<span class="FootnoteRef"><a href="#Ftn_26" id="Ftn_26_1"><sup>[note: 26]</sup></a></span></p> <p class="Judg-1"><a id="p1_41"></a>41 The principles relating to discovery of documents belonging to a company of which the spouse was a director and shareholder, which was laid down in <em>ACW v ACX</em> <a class="pagecontent" href="javascript:viewPageContent('/Judgment/[2014] SGHC 0053.xml')">[2014] SGHC 53</a> (at [20] citing <em>B v B (Matrimonial Proceedings: Discovery</em> [1978] Fam 181 at 193 – 194), are thus relevant:</p> <p class="Judg-Quote-1">20 More directly, a helpful summary of the relevant principles relating to discovery of documents belonging to a company of which the husband was a director and shareholder can be found in <em>B v B</em> at 193–194:</p> <p class="Judg-QuoteList-2">(a) The documents of a company are in the legal possession of the company. If they are or have been in the actual physical possession of a director who is a party to litigation they must be disclosed by that director, if relevant to the litigation, even though he holds them as servant or agent of the company in his capacity as an officer of the company.</p> <p class="Judg-QuoteList-2">(b) If the director who is a party to the litigation does not have physical possession of the documents, the question of fact of whether the documents are within the power of the director arises. “Power” in this context means “the enforceable right to inspect or obtain possession or control of the document” in the personal capacity of the director. This is in contradistinction to the right to inspect vested in a director in his capacity as a director. Without the consent of the company, the director has no right to inspect the documents. Much will depend on the share structure of the company.</p> <p class="Judg-QuoteList-2">(c) If the company is the alter ego of such a director so that he has unfettered control of the company’s affairs, he must disclose and produce all relevant documents in the possession of the company. Where the company is not the alter ego of a director, the factors to be considered are:</p> <p class="Judg-Quote-3">(i) the extent of the shareholding of the husband;</p> <p class="Judg-Quote-3">(ii) whether it amounts to control of the company;</p> <p class="Judg-Quote-3">(iii) whether the minority shareholders are adverse to him;</p> <p class="Judg-Quote-3">(iv) how the board of directors is constituted; and</p> <p class="Judg-Quote-3">(v) whether there is any objection by the board to disclosure of any of the documents sought.</p> <p class="Judg-QuoteList-2">(d) A very wide range of issues are relevant in proceedings relating to ancillary matters. The court has to assess what the husband is shown to have, but also what could reasonably be made available to him. In many cases, audited accounts of companies of which the husband is a shareholder will be sufficient, together with full disclosure of all the husband’s personal financial records. But there are cases when the court will go behind company accounts and order discovery of company books and documents. It is not usual, however, for the court to take this course unless there is evidence before it from accountants or other experts that the published accounts of the company cannot be relied upon.</p> <p class="Judg-QuoteList-2">(e) Where relevant documents in the possession of a company are disclosed by a director as being in his custody or power, the court has a discretion whether or not to order production of them. In exercising the discretion, the court will have regard to all the circumstances and balance the relevance and importance of the documents and the hardship likely to be caused to the wife by non-production against any prejudice to the husband and third parties likely to be caused by production.</p> <p class="Judg-QuoteList-2">(f) It has not hitherto been the practice of the court to order production of company documents to which the board of directors objects on affidavit, provided that the court is satisfied that the objection is not contrived for the purpose of frustrating the powers of the court. The court will not in the exercise of its discretion order parties to do that which they have no power to do. The court will not order production unless it is satisfied that production is necessary either for disposing fairly of the issues between the parties or for saving costs.</p> <p class="Judg-QuoteList-2">(g) Where the wife cannot obtain documents on discovery, she may be able to apply for leave to issue a subpoena against the secretary or other officers of the company to produce relevant documents.</p> <p class="Judg-1"><a id="p1_42"></a>42 The Wife appeared to take the position that Company A was the Husband’s alter ego – this meant that the documents set out in Items 1 – 10 were indeed in his possession and thus ought to be disclosed.</p> <p class="Judg-1"><a id="p1_43"></a>43 I was satisfied that Company A was indeed the Husband’s alter ego. There was no other evidence to the contrary. To borrow the words of Lord Denning in <em>Lonrho Ltd and anor v Shell Petroleum and anor</em> <a class="pagecontent" href="javascript:viewPageContent('/English/67355-E-M.xml')">[1980] QB 358</a> at p 371, the Husband’s power over Company A was so complete such that he should be able to disclose the documents of the company that were sought in these proceedings.</p> <p class="Judg-1"><a id="p1_44"></a>44 I would, however, at this juncture, observe that the idea of a company being an alter ego in the context of a discovery application is subtly different from the context of piercing the corporate veil. The former inquiry is concerned with assessing whether the spouse’s control over the company is so domineering such that they would likely have, and be able to disclose, the company documents sought without requiring the consent of the company’s board. The latter, however, is concerned with questions of liability – if the company is carrying on the business of its controller and incurs liability as a result, the controller cannot take cover behind the company’s corporate form: see <em>Dialectic PR LLC v Brilliante Resources International Pte Ltd</em> <a class="pagecontent" href="javascript:viewPageContent('/Judgment/29343-SSP.xml')">[2023] SGHC 39</a> at [49] citing <em>Alwie Handoyo v Tjong Very Sumito and another and another appeal</em> <a class="pagecontent" href="javascript:viewPageContent('/SLR/15355-SSP-M.xml')">[2013] 4 SLR 308</a> (“<em>Alwie</em>”) at [96], citing <em>NEC Asia Pte Ltd v Picket & Rail Asia Pacific Pte Ltd</em> <a class="pagecontent" href="javascript:viewPageContent('/SLR/[2011] 2 SLR 0565.xml')">[2011] 2 SLR 565</a> at [31] and <em>Zim Integrated Shipping Services Ltd v Dafni Igal</em> <a class="pagecontent" href="javascript:viewPageContent('/SLR/[2010] 2 SLR 0426.xml')">[2010] 2 SLR 426</a> at [86]–[88].</p> <p class="Judg-1"><a id="p1_45"></a>45 As to which documents should be disclosed, I allow the Wife’s request in relation to Items 1 – 4, and Items 6 – 9. Item 1, which was the memorandum and articles of association of the company at the time it was incorporated, was relevant because the Wife had alleged that the Husband had removed her as a shareholder and intended to downplay her contributions to Company A.<span class="FootnoteRef"><a href="#Ftn_27" id="Ftn_27_1"><sup>[note: 27]</sup></a></span></p> <p class="Judg-1"><a id="p1_46"></a>46 As for items 2 – 4, and 6 – 9, I was of the view that they were relevant towards showing the value of Company A at the ancillary matters hearing. These items included, amongst other things, financial statements (which I understood to be a request for the <b><em>audited</em></b> financial statements) and the corporate income tax return form as well as bank statements. The Wife had also asked for the tenancy agreement and list of company vehicles (Items 4, 6, 7, and 8) – these were also relevant towards the valuation of Company A. These documents would show whether Company A’s assets had been dissipated, and also give a clearer picture of its expenses.</p> <p class="Judg-1"><a id="p1_47"></a>47 In light of the above, I will disallow the Wife’s request for a valuation report (Item 9).</p> <p class="Judg-1"><a id="p1_48"></a>48 As for the Wife’s request in relation to Item 5, that too, is disallowed. Item 5 was the CPF list of Company A’s employer submissions statement. Counsel for the Wife argued that it was relevant to showing the company’s value, as well as ascertaining who were Company A’s employees, and whether the Husband was an employee. I disagree. Item 5 was not relevant towards valuing the company – the company’s payroll would have been reflected in the financial statements, which the Wife had also asked for. There were also other documents that could be sought to show whether the Husband was indeed Company A’s employee. Finally, as counsel for the Husband quite rightly pointed out, Item 5 would contain CPF contributions of other employees that were, and should remain, confidential.</p> <p class="Judg-1"><a id="p1_49"></a>49 I turn now to deal with the next category of documents which related to the Husband’s personal finances.</p> <p class="Judg-1"><a id="p1_50"></a>50 Item 11 was a request for the Husband’s CPF statements for the past 12 months. Counsel for the Husband characterised this request as a fishing expedition. In response, counsel for the Wife argued that the CPF statements would be a more accurate reflection of the Husband’s salary, and also allow for the numbers to be tallied with the payslips that had been disclosed.</p> <p class="Judg-1"><a id="p1_51"></a>51 I will allow the request for Item 11. The CPF statements were clearly relevant towards demonstrating the Husband’s earning capacity and means.</p> <p class="Judg-1"><a id="p1_52"></a>52 As for Items 12 – 14, these were requests for receipts evidencing the Husband’s expenditure on, amongst other things, household expenses and property tax. I will disallow this request. As I had pointed out to counsel for the Wife during the hearing, if the Husband has not disclosed these receipts, that will only be to his detriment at the hearing of ancillary matters.</p> <p class="Judg-1"><a id="p1_53"></a>53 I come now to the last two items. Item 15 related to Item 1 of the Wife’s request for interrogatories. She wanted the Husband to produce documents, including the ACRA business profile, financial statement (which I, again, understood to be a request for the <b><em>audited</em></b> financial statements), corporate income tax form and valuation of the business.</p> <p class="Judg-1"><a id="p1_54"></a>54 This request is not well framed. The Wife’s real interest was in Company B, which had an almost similar name to Company A. She had disclosed ACRA records of Company B in her affidavit which showed the Husband being listed as a shareholder and director.<span class="FootnoteRef"><a href="#Ftn_28" id="Ftn_28_1"><sup>[note: 28]</sup></a></span> These ACRA records also showed that Company B had been incorporated on 30 May 2022.<span class="FootnoteRef"><a href="#Ftn_29" id="Ftn_29_1"><sup>[note: 29]</sup></a></span></p> <p class="Judg-1"><a id="p1_55"></a>55 In the circumstances, I will allow Item 15 only to the extent that the Husband is to disclose the bank statements of Company B from 30 May 2022 to date. The Husband is also to disclose, if available, the audited financial statements of Company B for the financial years 2022 and 2023.</p> <p class="Judg-1"><a id="p1_56"></a>56 Item 16 was a request related to Item 31 of the Wife’s request for interrogatories. As I have rejected the Wife’s request (above at [39]), I see no basis to order discovery for Item 16.</p> <p class="Judg-1"><a id="p1_57"></a>57 In summary, Items <b>1 – 4</b>, <b>6 – 9</b>, <b>11</b>, and Item <b>15</b> (only to the extent I have stated above), are allowed. Items 5, 10, 12 – 14 and 16 are disallowed.</p> <p class="Judg-Heading-2">SUM 682</p> <p class="Judg-1"><a id="p1_58"></a>58 I turn now to deal with the Husband’s application for interrogatories.</p> <p class="Judg-1"><a id="p1_59"></a>59 Item 8 required the Wife to disclose if she had any other sources of income. Items 9 – 12 required the Wife to, if she indeed had any other sources of income, to provide details – this included, amongst other things, the source and frequency of such income as well the banks or financial institutions within which she had deposited such income.</p> <p class="Judg-1"><a id="p1_60"></a>60 The Wife’s response to Item 8 was that “there was no such income”.<span class="FootnoteRef"><a href="#Ftn_30" id="Ftn_30_1"><sup>[note: 30]</sup></a></span> Counsel for the Husband justified the request on the basis that the Wife was not honest in her answer.</p> <p class="Judg-1"><a id="p1_61"></a>61 This, however, is not a valid justification on which to seek interrogatories. The rule is that answers to interrogatories should be sufficient. As I have already pointed out, any quarrel as to the <em>truth</em> of the answers given should be taken up at the ancillary matters hearing (see <em>UJN</em> at [12]). I thus disallow the Husband’s request in relation to Items 8 – 12.</p> <p class="Judg-1"><a id="p1_62"></a>62 I turn now to Items 13 and 14. Item 13 was a request for the Wife to state whether she had, in the preceding 3 years, maintained any account or investment in any type of financial institution in Singapore or abroad. Item 14 required the Wife to disclose the relevant details, if she indeed had such accounts.</p> <p class="Judg-1"><a id="p1_63"></a>63 The Wife’s answer to Items 13 was:</p> <p class="Judg-Quote-1">“It is in the POSB account under the Plaintiff’s name.”</p> <p class="Judg-1"><a id="p1_64"></a>64 This is an insufficient answer. The question posed was whether she had maintained any account or investment with any other financial institutions either in Singapore or abroad. The Wife had, in her response, entirely side-stepped this question. I will therefore allow the Husband’s request for Items 13 and 14.</p> <p class="Judg-1"><a id="p1_65"></a>65 I come now to the final two interrogatories sought: Items 28 and 29. These questions required the Wife to state whether she had taken any loans from her insurance policies as stated at paragraph 7 of her AOM, and if so, to state the quantum of the loan, when it was taken, and the reason for taking the loan.</p> <p class="Judg-1"><a id="p1_66"></a>66 The Wife’s response was “N.A.”. As her counsel explained, this response was provided because she had not taken any loans from those insurance policies. This was, obviously, not good enough for the Husband. As his counsel explained – if such loans had indeed taken, then the question should be answered in the affirmative.</p> <p class="Judg-1"><a id="p1_67"></a>67 I allow the Husband’s request in relation to items 28 and 29. The response was insufficient. I would add, however, that had her response to item 28 been that no such loans were taken out, then her answer of “N.A.” to item 29 would be perfectly acceptable. That is because the manner in which item 29 was framed clearly showed that it was a follow-up question to that posed in item 28.</p> <p class="Judg-1"><a id="p1_68"></a>68 To sum up, in respect of SUM 682, I allow the Husband’s request in respect of Items <b>13</b>, <b>14</b>, <b>28</b>, and <b>29</b>. The Husband’s request in respect of Items <b>8</b> – <b>12</b> is denied.</p> <p class="Judg-Heading-2">SUM 684</p> <p class="Judg-1"><a id="p1_69"></a>69 I come now to the Husband’s request for discovery.</p> <p class="Judg-1"><a id="p1_70"></a>70 The Husband sought documents pertaining to the Wife’s payslips and related bank account statements:</p> <p class="Judg-2"><a id="p1_70-p2_a"></a>(a) Item 2 was a request for the Wife to furnish payment advice statements if she had, in the preceding 3 years, some other sources of income apart from that declared in her AOM.</p> <p class="Judg-2"><a id="p1_70-p2_b"></a>(b) Item 3 was a related request for the Wife to provide bank statements, from January 2022 to date, for the accounts in which payments from her other sources of income had been deposited.</p> <p class="Judg-2"><a id="p1_70-p2_c"></a>(c) Item 8 required the Wife to produce, bank account statements for the past 3 years, for the accounts into which her monthly salary had been deposited.</p> <p class="Judg-1"><a id="p1_71"></a>71 Counsel for the Husband argued that while the Wife had disclosed that she was working for her father’s company (“Company X”), and other ride-hailing companies, she had only produced her payslips from Grab. In addition, it was highly suspicious that her personal bank account was depleted, despite her remaining gainfully employed. It was therefore necessary to obtain the Wife’s payslips, and relevant bank account statements, to get a fuller picture of her financial status, and to determine if she was truly attempting to conceal her sources of income.</p> <p class="Judg-1"><a id="p1_72"></a>72 In response, counsel for the Wife argued that this request was simply a tit-for-tat response by the Husband. In any event, the request, as framed, was not for payslips, and the Wife was not trying to evade her disclosure obligations.</p> <p class="Judg-1"><a id="p1_73"></a>73 There can be no quibble that the documents sought for are indeed relevant to the ancillary matters hearing. There is a point, however, as to whether these documents were indeed in the Wife’s possession, custody or power (<em>VTQ</em> at [26(b)]).</p> <p class="Judg-1"><a id="p1_74"></a>74 In this connection, there was evidence to show that the Wife had indeed been driving for other ride-hailing companies. For example, these were some of the payouts that the Wife had received in the months of August and September:</p> <p class="Judg-2"><a id="p1_74-p2_a"></a>(a) Tada cashout, $962.72 (14 August)<span class="FootnoteRef"><a href="#Ftn_31" id="Ftn_31_1"><sup>[note: 31]</sup></a></span></p> <p class="Judg-2"><a id="p1_74-p2_b"></a>(b) Gojek cashout, $248.37 (20 August)<span class="FootnoteRef"><a href="#Ftn_32" id="Ftn_32_1"><sup>[note: 32]</sup></a></span></p> <p class="Judg-2"><a id="p1_74-p2_c"></a>(c) Ryde cashout, $80 (20 August)<span class="FootnoteRef"><a href="#Ftn_33" id="Ftn_33_1"><sup>[note: 33]</sup></a></span></p> <p class="Judg-2"><a id="p1_74-p2_d"></a>(d) Tada cashout, $907.13 (21 August)<span class="FootnoteRef"><a href="#Ftn_34" id="Ftn_34_1"><sup>[note: 34]</sup></a></span></p> <p class="Judg-2"><a id="p1_74-p2_e"></a>(e) Gojek cashout, $70.45 (28 August)<span class="FootnoteRef"><a href="#Ftn_35" id="Ftn_35_1"><sup>[note: 35]</sup></a></span></p> <p class="Judg-2"><a id="p1_74-p2_f"></a>(f) Ryde cashout, $80.90 (28 August)<span class="FootnoteRef"><a href="#Ftn_36" id="Ftn_36_1"><sup>[note: 36]</sup></a></span></p> <p class="Judg-2"><a id="p1_74-p2_g"></a>(g) Tada cashout, $674.34 (28 August)<span class="FootnoteRef"><a href="#Ftn_37" id="Ftn_37_1"><sup>[note: 37]</sup></a></span></p> <p class="Judg-2"><a id="p1_74-p2_h"></a>(h) Tada cashout, $521.38 (4 September)<span class="FootnoteRef"><a href="#Ftn_38" id="Ftn_38_1"><sup>[note: 38]</sup></a></span></p> <p class="Judg-2"><a id="p1_74-p2_i"></a>(i) Gojek cashout, $65.45 (4 September)<span class="FootnoteRef"><a href="#Ftn_39" id="Ftn_39_1"><sup>[note: 39]</sup></a></span></p> <p class="Judg-1"><a id=""></a>It is also evident that both Company X, and Company A, had made CPF contributions to the Wife’s CPF accounts.<span class="FootnoteRef"><a href="#Ftn_40" id="Ftn_40_1"><sup>[note: 40]</sup></a></span></p> <p class="Judg-1"><a id="p1_75"></a>75 It thus stands to reason that the Wife, having received payment from other ride-hailing applications, as well as Company X and Company A, should be able to produce the relevant payslips and bank statements. If she does not have them in her possession, or cannot obtain copies, she must set out her explanation in an affidavit with the supporting documentation (if any): <em>VTQ</em> at [26(c)]. She cannot tiptoe around her obligation of disclosure in these proceedings with the bare assertion that she does not have the documents that were requested for.</p> <p class="Judg-1"><a id="p1_76"></a>76 I would note that the Wife had, in an earlier affidavit, to which her counsel referred me, stated that she had been banned by all the other ride-hailing companies, except Grab.<span class="FootnoteRef"><a href="#Ftn_41" id="Ftn_41_1"><sup>[note: 41]</sup></a></span> The point, which counsel appeared to allude to, was that because the Wife had been banned from these ride-hailing platforms, she would not have been able to obtain these payslips. If this is indeed the case, the Wife should, as I have highlighted above, explain the same in an affidavit and exhibit the relevant documents in support.</p> <p class="Judg-1"><a id="p1_77"></a>77 I therefore allow the Husband’s request for discovery in relation to Items 2, 3, and 8.</p> <p class="Judg-1"><a id="p1_78"></a>78 The next request, Item 5, was for the Wife to disclose the transaction history of her personal bank account with POSB, from January 2022 to May 2023 as well as from December 2023 to date. The Husband wanted these records because, as his counsel put it, it was inconceivable that she only had a few hundred dollars left in her personal bank account. Counsel for the Wife pointed out that she had already disclosed 6 months’ worth of statements and that administrative charges would likely have to be incurred to procure the records sought.</p> <p class="Judg-1"><a id="p1_79"></a>79 I allow the Husband’s request for Item 5. As far as I could tell, the marriage was on the rocks when the Husband left the matrimonial home in July 2021. It would therefore be useful, for the court hearing the ancillary matters, to have an idea of the Wife’s finances during the breakdown of the marriage and prior to the filing of divorce proceedings (see <em>Tan Bin Yong Christopher</em> at [19]).</p> <p class="Judg-1"><a id="p1_80"></a>80 Apart from the Wife’s personal bank account statements, the Husband also sought, in Item 6 of his request for discovery, the account statements of the joint bank account which the Wife held with their daughter. The Husband’s contention is that the Wife should be able to produce these documents but has refused to do so. In response, counsel for the Wife argued that there was no need to produce these documents because it was not a matrimonial asset.</p> <p class="Judg-1"><a id="p1_81"></a>81 I allow the Husband’s request for Item 6. It is the court that decides what constitutes a matrimonial asset. Parties must strictly observe their disclosure obligations and cannot “tailor the extent of their disclosure in accordance with their own views on what constitutes their matrimonial assets”: <em>UZN</em> at [17].</p> <p class="Judg-1"><a id="p1_82"></a>82 Item 7 was related to Items 8 – 12 of the Husband’s request for interrogatories. In short, if the Wife had accounts or investments with other financial institutions, apart from those disclosed in her AOM, she was to produce statements from these accounts.</p> <p class="Judg-1"><a id="p1_83"></a>83 While I had rejected Items 8 – 12 of the Husband’s request for Interrogatories, it did not follow that Item 7 of the Husband’s request for discovery should also be rejected. I cannot proceed on the basis that discovery of these documents should be disallowed because the Wife had no such accounts. To do so would be to implicitly accept that her answer to Items 8 – 12 of the Husband’s request for interrogatories were true. That, however, is an assessment that must be left to the court hearing the ancillary matters.</p> <p class="Judg-1"><a id="p1_84"></a>84 It was, however, clear to me that such documents, if they existed, were clearly relevant to the disposal of ancillary matters. I thus allow Item 7 of the Husband’s request for discovery.</p> <p class="Judg-1"><a id="p1_85"></a>85 I come now to the Husband’s request for documents relating to the Wife’s insurance policies as set out in Items 10 – 12. Counsel for the Husband argued that these documents were relevant in determining whether they formed part of the matrimonial pool of assets. Further, any loans taken out would have been a draw down on the matrimonial assets. Counsel for the Wife contended, in response, that these insurance policies had been acquired before marriage and so were not part of the matrimonial pool, and that in any event, no loans had been taken out.</p> <p class="Judg-1"><a id="p1_86"></a>86 I allow the Husband’s request in relation to Items 10 – 12. As I have noted above (at [81]), it is the court that decides whether a particular asset is indeed a matrimonial asset. These documents sought were clearly relevant towards determining whether they were matrimonial assets or not.</p> <p class="Judg-1"><a id="p1_87"></a>87 The final request, in Item 14, was for the Wife to furnish all documents supporting her replies to the Husband’s request for interrogatories. This request is denied. What the Husband has sought, in interrogatories, was similarly sought in his request for discovery. He basically wanted information as to the Wife’s sources of income, whether she had any other bank accounts apart from those disclosed in the AOM, details about the joint account she held with their daughter, and her insurance policies. Given my orders in respect of his request for discovery and interrogatories, I did not think it was necessary to grant his request in respect of Item 14.</p> <p class="Judg-1"><a id="p1_88"></a>88 To sum up, the Husband’s request in relation to Items <b>2</b>, <b>3</b>, <b>5</b>, <b>6</b>, <b>7</b>, <b>8</b>, <b>10</b> – <b>12</b> are allowed. The Husband’s request in relation to Item <b>14</b> is disallowed.</p> <p class="Judg-Heading-1">Summary of orders made</p> <p class="Judg-1"><a id="p1_89"></a>89 These are the orders that I make in respect of the four applications:</p> <p class="Judg-2"><a id=""></a> <b><u>SUM 633</u></b> </p> <p class="Judg-2"><a id="p1_89-p2_a"></a>(a) The Defendant shall answer the interrogatories as set out in Item 32 of the Request for Interrogatories annexed to this summons on affidavit, to the best of his knowledge, information and belief, pursuant to Rule 69 of the Family Justice Rules 2014.</p> <p class="Judg-2"><a id=""></a> <b><u>SUM 632</u></b> </p> <p class="Judg-2"><a id="p1_89-p2_b"></a>(b) The Defendant shall state on affidavit, pursuant to Rule 63 of the Family Justice Rules 2014, in respect of the following documents as set out in Items 1, 2, 3, 4, 6, 7, 8, and 9 of the Request for Discovery annexed to this summons, whether the same is in his possession, custody or power, and if not then in his possession, custody or power, when he parted with it and what has become of it.</p> <p class="Judg-2"><a id="p1_89-p2_c"></a>(c) The Defendant shall also state on affidavit, pursuant to Rule 63 of the Family Justice Rules 2014, in respect of:</p> <p class="Judg-3"><a id="p1_89-p2_c-p3_i"></a>(i) the bank statements of Company B from 30 May 2022 to date; and</p> <p class="Judg-3"><a id="p1_89-p2_c-p3_ii"></a>(ii) the audited financial statements of Company B for the financial years 2022 and 2023;</p> <p class="Judg-2"><a id=""></a>whether the same is in his possession, custody or power, and if not then in his possession, custody or power, when he parted with it and what has become of it.</p> <p class="Judg-2"><a id=""></a> <b><u>SUM 682</u></b> </p> <p class="Judg-2"><a id="p1_89-p2_d"></a>(d) The Plaintiff shall answer the following interrogatories set out in Items 13, 14, 28, and 29 in Schedule B annexed to this summons on affidavit, to the best of her knowledge, information and belief, pursuant to Rule 69 of the Family Justice Rules 2014.</p> <p class="Judg-2"><a id=""></a> <b><u>SUM 684</u></b> </p> <p class="Judg-2"><a id="p1_89-p2_e"></a>(e) The Plaintiff shall state on Affidavit, pursuant to Rule 63 of the Family Justice Rules 2014, in respect of each of the following documents as set out in Items 2, 3, 5, 6, 7, 8, 10, 11, and 12 of Schedule A annexed to this summons, whether the same is in her possession, custody or power, and if not in her possession, custody or power, when she parted with it and what has become of it.</p> <p class="Judg-1"><a id="p1_90"></a>90 In addition to the above orders, I also order that:</p> <p class="Judg-2"><a id="p1_90-p2_a"></a>(a) Compliance affidavits are to be filed and served by 14 June 2024, by 5pm.</p> <p class="Judg-2"><a id="p1_90-p2_b"></a>(b) Costs submissions in respect of SUM 633, 632, 682 and 684 are to be filed and served by way of letter by 16 May 2024 by 5pm, limited to 3 pages each.</p> <p class="Judg-Heading-1">Conclusion</p> <p class="Judg-1"><a id="p1_91"></a>91 I conclude with one brief observation. It was not lost on me that there was a great deal of acrimony between the parties. That is, perhaps, to be expected in a family dispute, but I must stress that the Family Court is not a place for parties to do battle.</p> <p class="Judg-1"><a id="p1_92"></a>92 It remains for me to thank counsel for their assistance.</p> <hr align="left" size="1" width="33%"><p class="Footnote"><sup><a href="#Ftn_1_1" id="Ftn_1">[note: 1]</a></sup>Statement of Particulars dated 2 August 2022 at 1(c)(vii).</p><p class="Footnote"><sup><a href="#Ftn_2_1" id="Ftn_2">[note: 2]</a></sup>Minute Sheet dated 9 November 2023.</p><p class="Footnote"><sup><a href="#Ftn_3_1" id="Ftn_3">[note: 3]</a></sup>SUM 633, Request for Interrogatories, Items 1 – 4.</p><p class="Footnote"><sup><a href="#Ftn_4_1" id="Ftn_4">[note: 4]</a></sup>SUM 633, Request for Interrogatories, Items 5 – 6.</p><p class="Footnote"><sup><a href="#Ftn_5_1" id="Ftn_5">[note: 5]</a></sup>SUM 633, Request for Interrogatories, Items 7 – 8.</p><p class="Footnote"><sup><a href="#Ftn_6_1" id="Ftn_6">[note: 6]</a></sup>SUM 633, Request for Interrogatories, Items 9 – 11.</p><p class="Footnote"><sup><a href="#Ftn_7_1" id="Ftn_7">[note: 7]</a></sup>SUM 633, Request for Interrogatories, Items 12 – 15.</p><p class="Footnote"><sup><a href="#Ftn_8_1" id="Ftn_8">[note: 8]</a></sup>SUM 633, Request for Interrogatories, Items 16 – 17.</p><p class="Footnote"><sup><a href="#Ftn_9_1" id="Ftn_9">[note: 9]</a></sup>SUM 633, Request for Interrogatories, Items 18 – 29.</p><p class="Footnote"><sup><a href="#Ftn_10_1" id="Ftn_10">[note: 10]</a></sup>SUM 633, Request for Interrogatories, Items 30 – 32.</p><p class="Footnote"><sup><a href="#Ftn_11_1" id="Ftn_11">[note: 11]</a></sup>SUM 632, Request for Discovery, Items 1 – 10.</p><p class="Footnote"><sup><a href="#Ftn_12_1" id="Ftn_12">[note: 12]</a></sup>Wife’s Affidavit filed in support of SUM 632 and SUM 633 dated 27 February 2024 at [12].</p><p class="Footnote"><sup><a href="#Ftn_13_1" id="Ftn_13">[note: 13]</a></sup>SUM 632, Request for Discovery, Items 11 – 14.</p><p class="Footnote"><sup><a href="#Ftn_14_1" id="Ftn_14">[note: 14]</a></sup>Wife’s Affidavit filed in support of SUM 632 and SUM 633 dated 27 February 2024 at [25].</p><p class="Footnote"><sup><a href="#Ftn_15_1" id="Ftn_15">[note: 15]</a></sup>Wife’s Affidavit filed in support of SUM 632 and SUM 633 dated 27 February 2024 at [31].</p><p class="Footnote"><sup><a href="#Ftn_16_1" id="Ftn_16">[note: 16]</a></sup>SUM 682, Schedule B, Items 8 – 12.</p><p class="Footnote"><sup><a href="#Ftn_17_1" id="Ftn_17">[note: 17]</a></sup>SUM 682, Schedule B, Items 13 – 14.</p><p class="Footnote"><sup><a href="#Ftn_18_1" id="Ftn_18">[note: 18]</a></sup>SUM 682, Schedule B, Items 28 – 29.</p><p class="Footnote"><sup><a href="#Ftn_19_1" id="Ftn_19">[note: 19]</a></sup>SUM 684, Schedule A, Items 2 – 3 (Sources of Income); Items 5 – 8 (bank account details); Items 10 – 12 (Insurance Policies).</p><p class="Footnote"><sup><a href="#Ftn_20_1" id="Ftn_20">[note: 20]</a></sup>Husband’s Affidavit filed in support of SUM 682 and SUM 684 dated 1 March 2024 at [34].</p><p class="Footnote"><sup><a href="#Ftn_21_1" id="Ftn_21">[note: 21]</a></sup>Husband’s Affidavit filed in support of SUM 682 and SUM 684 dated 1 March 2024 at [29].</p><p class="Footnote"><sup><a href="#Ftn_22_1" id="Ftn_22">[note: 22]</a></sup>Husband’s Affidavit filed in support of SUM 682 and SUM 684 dated 1 March 2024 at [41] – [43].</p><p class="Footnote"><sup><a href="#Ftn_23_1" id="Ftn_23">[note: 23]</a></sup>Wife’s Affidavit filed in support of SUM 632 and SUM 633 dated 27 February 2024 at [25] – [31].</p><p class="Footnote"><sup><a href="#Ftn_24_1" id="Ftn_24">[note: 24]</a></sup>Wife’s Affidavit filed in support of SUM 632 and SUM 633 dated 27 February 2024 at p 13.</p><p class="Footnote"><sup><a href="#Ftn_25_1" id="Ftn_25">[note: 25]</a></sup>Wife’s Affidavit filed in support of SUM 632 and SUM 633 dated 27 February 2024 at p 14.</p><p class="Footnote"><sup><a href="#Ftn_26_1" id="Ftn_26">[note: 26]</a></sup>Husband’s AOM at pp 30 – 33.</p><p class="Footnote"><sup><a href="#Ftn_27_1" id="Ftn_27">[note: 27]</a></sup>Wife’s Reply Affidavit filed 26 April 2024 at [5] – [7].</p><p class="Footnote"><sup><a href="#Ftn_28_1" id="Ftn_28">[note: 28]</a></sup>Wife’s Reply Affidavit filed 26 April 2024 at p 35.</p><p class="Footnote"><sup><a href="#Ftn_29_1" id="Ftn_29">[note: 29]</a></sup>Wife’s Reply Affidavit filed 26 April 2024 at p 33.</p><p class="Footnote"><sup><a href="#Ftn_30_1" id="Ftn_30">[note: 30]</a></sup>Husband’s Affidavit filed in support of SUM 682 and SUM 684 dated 1 March 2024.</p><p class="Footnote"><sup><a href="#Ftn_31_1" id="Ftn_31">[note: 31]</a></sup>Wife’s AOM at p 89.</p><p class="Footnote"><sup><a href="#Ftn_32_1" id="Ftn_32">[note: 32]</a></sup>Wife’s AOM at p 91.</p><p class="Footnote"><sup><a href="#Ftn_33_1" id="Ftn_33">[note: 33]</a></sup>Wife’s AOM at p 91.</p><p class="Footnote"><sup><a href="#Ftn_34_1" id="Ftn_34">[note: 34]</a></sup>Wife’s AOM at p 91.</p><p class="Footnote"><sup><a href="#Ftn_35_1" id="Ftn_35">[note: 35]</a></sup>Wife’s AOM at p 93.</p><p class="Footnote"><sup><a href="#Ftn_36_1" id="Ftn_36">[note: 36]</a></sup>Wife’s AOM at p 93.</p><p class="Footnote"><sup><a href="#Ftn_37_1" id="Ftn_37">[note: 37]</a></sup>Wife’s AOM at p 93.</p><p class="Footnote"><sup><a href="#Ftn_38_1" id="Ftn_38">[note: 38]</a></sup>Wife’s AOM at p 96.</p><p class="Footnote"><sup><a href="#Ftn_39_1" id="Ftn_39">[note: 39]</a></sup>Wife’s AOM at p 96.</p><p class="Footnote"><sup><a href="#Ftn_40_1" id="Ftn_40">[note: 40]</a></sup>Wife’s AOM at p 71.</p><p class="Footnote"><sup><a href="#Ftn_41_1" id="Ftn_41">[note: 41]</a></sup>Wife’s Affidavit dated 28 March 2024 at [30].</p></div></content></root> | 8755f14fe21d8c9968cb9911ebe7bb30546aec65 |
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