fc_judgments_version: 63
This data as json
| _id | _item | _version | _commit | tags | date | court | case-number | title | citation | url | counsel | timestamp | coram | html | _item_full_hash |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 63 | 55 | 1 | 1779 | [
"Family Law \u2013 Procedure \u2013 Discovery",
"Family Law \u2013 Procedure \u2013 Interrogatories",
"Family Law \u2013 Procedure \u2013 Interrogatories \u2013 Whether providing a document in response to an interrogatory is a sufficient answer"
] |
2024-07-15 | Family Court | Divorce No 5338 of 2022 (Summons No 1739 and 1684 of 2024) | WZH v WZI | [2024] SGFC 48 | 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%2F31841-SSP.xml | [
"Alain Abraham Johns and Emira Binte Abdul Razakjr (Alain A Johns Partnership) for the plaintiff",
"Muhammad Hasif Bin Abdul Aziz and Abdul Wahab Bin Saul Hamid (A.W. Law LLC) for the defendant"
] |
2024-08-01T16:00:00Z[GMT] | Soh Kian Peng | <root><head><title>WZH v WZI</title></head><content><div class="contentsOfFile"> <h2 align="center" class="title"><span class="caseTitle"> WZH <em>v</em> WZI </span><br><span class="Citation offhyperlink"><a class="pagecontent" href="javascript:viewPageContent('/Judgment/31841-SSP.xml')">[2024] SGFC 48</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 5338 of 2022 (Summons No 1739 and 1684 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">15 July 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"> Alain Abraham Johns and Emira Binte Abdul Razakjr (Alain A Johns Partnership) for the plaintiff; Muhammad Hasif Bin Abdul Aziz and Abdul Wahab Bin Saul Hamid (A.W. Law 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"> WZH — WZI </td></tr></tbody></table> <p class="txt-body"><span style="font-style:italic">Family Law</span> – <span style="font-style:italic">Procedure</span> – <span style="font-style:italic">Discovery</span></p> <p class="txt-body"><span style="font-style:italic">Family Law</span> – <span style="font-style:italic">Procedure</span> – <span style="font-style:italic">Interrogatories</span></p> <p class="txt-body"><span style="font-style:italic">Family Law</span> – <span style="font-style:italic">Procedure</span> – <span style="font-style:italic">Interrogatories</span> – <span style="font-style:italic">Whether providing a document in response to an interrogatory is a sufficient answer</span></p> <p></p><table border="0" cellpadding="0" cellspacing="0" width="100%"><tbody><tr><td width="80%"><p class="Judg-Hearing-Date">15 July 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 Parties were married on 5 January 2018. In the years that followed, they welcomed two sons into their family. During this time, however, cracks were forming in their relationship. Matters reached a point of no return where the Husband filed for divorce on 17 November 2022. Interim judgment was obtained on 14 December 2023, and parties set course for a hearing of the ancillary matters.</p> <p class="Judg-1"><a id="p1_2"></a>2 The Wife has now taken out an application for discovery and interrogatories in SUM 1739/2024 (“SUM 1739”) and SUM 1684/2024 (“SUM 1684”) respectively. I heard parties on 24 June 2024 and now give my decision in respect of both summons.</p> <p class="Judg-Heading-1">Wife’s Application for Discovery (SUM 1739)</p> <p class="Judg-1"><a id="p1_3"></a>3 The Wife sought disclosure of bank statements, specifically of the following bank accounts in the Husband’s name:</p> <p class="Judg-2"><a id="p1_3-p2_a"></a>(a) OCBC 360 account ending -XX1;</p> <p class="Judg-2"><a id="p1_3-p2_b"></a>(b) OCBC Easisave account ending -XX1;</p> <p class="Judg-2"><a id="p1_3-p2_c"></a>(c) POSB Passbook savings account ending -XX-5.</p> <p class="Judg-1"><a id="p1_4"></a>4 The period of disclosure sought was from September 2021 – September 2022 (<em>ie</em>, a year prior to the commence of divorce proceedings). The Wife argued, in written submissions, that disclosure was relevant and necessary to establishing whether the Husband had indeed been dissipating matrimonial assets.</p> <p class="Judg-1"><a id="p1_5"></a>5 During the course of oral hearings, counsel for the Wife, Mr Muhammad Hasif Bin Abdul Aziz (“Mr Hasif”), and counsel for the Husband, Mr Alain Abraham Johns (“Mr Johns”) crossed swords on whether the facts of <em>VTQ v VTR</em> <a class="pagecontent" href="javascript:viewPageContent('/Judgment/26432-SSP.xml')">[2021] SGFC 85</a> were similar to the present case such that discovery should be allowed.</p> <p class="Judg-1"><a id="p1_6"></a>6 I would observe that in the context of discovery applications, the decision whether to allow disclosure, while guided by the twin principles of relevance and necessity, is necessarily a decision that must turn on the facts of the case at hand, taking into account all relevant circumstances. To that end, precedent is useful only insofar as they lay down guiding principles and provide an illustration as to how those principles are applied. Attempts at analogising or distinguishing precedent by close reference to the facts are, therefore, of limited utility.</p> <p class="Judg-1"><a id="p1_7"></a>7 While I have said that close attention must be paid to the facts of the present case in deciding whether discovery should be ordered, one must also be careful not to stray into the realm of matters that can only be ventilated at the hearing of the ancillary matters. I make mention of this because at times, it appeared to me that both Mr Hasif, as well as Mr Johns, were trying to establish whether the Husband had indeed dissipated assets.</p> <p class="Judg-1"><a id="p1_8"></a>8 In my judgment, the documents which the Wife sought was indeed relevant and necessary to the determination of the ancillary matters. It is useful for the court, as well as the Wife, to have a picture of the Husband’s financial circumstances in the period shortly before the divorce was filed: <em>WXE v WXF</em> <a class="pagecontent" href="javascript:viewPageContent('/Judgment/31617-SSP.xml')">[2024] SGFC 29</a> at [25] citing <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> at [19].</p> <p class="Judg-1"><a id="p1_9"></a>9 Furthermore, having perused the various affidavits filed, it was clear to me that one issue in dispute was whether the Husband had dissipated assets which should rightfully be accounted for in the matrimonial pool of assets. The statements which the Wife sought would clearly show if there were any unusual transactions in the months leading up to the filing of the divorce. Without these statements, it would be difficult, if not impossible, to establish whether the Husband had indeed disposed of assets prior to his filing of the divorce.</p> <p class="Judg-1"><a id="p1_10"></a>10 As a final point, I add that I could not agree with the Husband’s argument that the Wife’s application for discovery should be dismissed for procedural irregularity because he was never served with a request for the documents in the form stipulated by the Family Court Practice Directions (see Rule 63(4) of the Family Justice Rules 2014).<span class="FootnoteRef"><a href="#Ftn_1" id="Ftn_1_1"><sup>[note: 1]</sup></a></span> This is because, in her first Request for Discovery dated 6 March 2024,<span class="FootnoteRef"><a href="#Ftn_2" id="Ftn_2_1"><sup>[note: 2]</sup></a></span> the Wife had indeed sought monthly bank statements for all bank accounts in the Husband’s name for December 2021 to November 2022. I do note, however, that the period of disclosure which the Wife seeks in SUM 1739 appears to be different from that set out in her first Request for Discovery. I will therefore only order that the Husband disclose the bank statements for the period December 2021 to November 2022.</p> <p class="Judg-1"><a id="p1_11"></a>11 Subject to this slight change in the period of disclosure which I have ordered, the Wife’s application for discovery in SUM 1739 is allowed for the reasons I have set out above.</p> <p class="Judg-Heading-1">Wife’s Application for Interrogatories (SUM 1684)</p> <p class="Judg-1"><a id="p1_12"></a>12 I turn now to consider the Wife’s request for interrogatories. Parties do not dispute that in deciding whether to order the Husband to answer the interrogatories posed, I must consider the relevance and necessity of the interrogatories. In addition, I must also consider whether the Husband had, in his Notice-in-Response to the Wife’s Request for Interrogatories, provided sufficient answers to the interrogatories (see <em>WWS v WWT</em> <a class="pagecontent" href="javascript:viewPageContent('/Judgment/31488-SSP.xml')">[2024] SGFC 24</a> at [28] – [30]). Indeed, parties had, during the hearing, summarised the crux of their dispute over whether the interrogatories should be ordered, as focussing on the sufficiency of the answers which the Husband had provided.</p> <p class="Judg-1"><a id="p1_13"></a>13 I start with Item 1. This was the interrogatory posed:</p> <p class="Judg-QuoteList-2">a. I aver that the Plaintiff had bought one Rolex watch sometime during parties’ trip to Switzerland on October 2018, which is during the marriage (the “Rolex Watch”).</p> <p class="Judg-QuoteList-2">b. The Plaintiff is to provide the value of the Rolex Watch?</p> <p class="Judg-1"><a id="p1_14"></a>14 This was the same interrogatory which the Wife had posed in her Further Request for Interrogatories dated 7 May 2024.<span class="FootnoteRef"><a href="#Ftn_3" id="Ftn_3_1"><sup>[note: 3]</sup></a></span> The Husband had provided a response in a letter dated 28 May 2024:<span class="FootnoteRef"><a href="#Ftn_4" id="Ftn_4_1"><sup>[note: 4]</sup></a></span></p> <p class="Judg-Quote-1">i. Yes. The trip was sometime in April 2018. The Plaintiff used pre-marriage assets to purchase the Rolex watch.</p> <p class="Judg-Quote-1">ii. The value of the Rolex Watch is about SGD18,000.</p> <p class="Judg-1"><a id="p1_15"></a>15 I am satisfied that this is a sufficient answer to the interrogatory that had been posed. It is clear that the Husband had answered the question. If the Wife has any quarrel with the <em>truth</em> of the Husband’s answers, she must take that up at the hearing of the ancillary matters.</p> <p class="Judg-1"><a id="p1_16"></a>16 I would go further to add that it was also clear to me that this interrogatory was not necessary for the disposal of the ancillary matters. I arrive at this conclusion having considered the interrogatories which the Wife had posed in her first Request for Interrogatories:<span class="FootnoteRef"><a href="#Ftn_5" id="Ftn_5_1"><sup>[note: 5]</sup></a></span></p> <p class="Judg-Quote-1">2a. Does the Plaintiff has a watch collection? If the answer is yes, what is the total value of the watch collection?</p> <p class="Judg-1"><a id="p1_17"></a>17 This was the Husband’s response in the letter from his lawyers dated 11 April 2024:<span class="FootnoteRef"><a href="#Ftn_6" id="Ftn_6_1"><sup>[note: 6]</sup></a></span></p> <p class="Judg-Quote-1">The Plaintiff owns 3 Rolex watches with a total value of about $40,000. These watches were purchased before the marriage and are pre-marriage assets.</p> <p class="Judg-1"><a id="p1_18"></a>18 In short, the Wife had already asked the Husband whether he did have a watch collection, and if so, the value of that collection. The Husband had given a sufficient answer. He disclosed that he owned three Rolex watches worth $40,000. Taking this into account, it was quite clear that Item 1 was not necessary to the hearing of the ancillary matters.</p> <p class="Judg-1"><a id="p1_19"></a>19 The Wife’s request in respect of Item 1 is disallowed.</p> <p class="Judg-1"><a id="p1_20"></a>20 I turn now to Item 2. This interrogatory related to certain insurance policies which the Husband had with [Y]. The Wife wanted the Husband to:</p> <p class="Judg-2"><a id="p1_20-p2_a"></a>(a) Explain why these policies were “no longer valid”;</p> <p class="Judg-2"><a id="p1_20-p2_b"></a>(b) Provide the amounts received when these policies were “no longer valid”; and</p> <p class="Judg-2"><a id="p1_20-p2_c"></a>(c) State the accounts to which these amounts had been disbursed to.</p> <p class="Judg-1"><a id="p1_21"></a>21 This was the Husband’s response:</p> <p class="Judg-Quote-1">i. The Plaintiff was unable to afford the high premiums of Policy No. XXXXX177 and the Plaintiff had surrendered Policy No. XXXXX944 as he required funds to pay for personal and business expenses. This was stated at S/No. 3 in the Plaintiff’s Notice in Response to Request for Discovery dated 11 April 2024.</p> <p class="Judg-Quote-1">ii. The screenshots from the Plaintiff’s [Y] Insurance Account show that Policy No. XXXXX177 and XXXXX944 are no longer valid, as they no longer appear. Please refer to Plaintiff’s Affidavit of Assets and Means filed on 16 February 2024 at pages 54 to 57.</p> <p class="Judg-Quote-1">iii. As stated at paragraph 2 e.iv. of NIRI, the amount received from the surrender of Policy No. XXXXX944 was $668,031.17. There was no surrender value for Policy No. XXXXX177 as the Plaintiff was unable to make payment of the high premiums and accordingly, the policy had lapsed.</p> <p class="Judg-Quote-1">iv. As stated at paragraph 2 e.iv. of NIRI, the amount was received into the Plaintiff’s POSB No. XXX-XXXXX-5.</p> <p class="Judg-1"><a id="p1_22"></a>22 I am satisfied that this is a sufficient answer. The Husband had clearly explained why he had to give up both policies. He had also stated the sums received from surrendering these policies, as well as the bank accounts into which the proceeds had been deposited. If the Wife believes that the Husband’s answer is untrue, the proper place to ventilate this is before the judge hearing the ancillary matters.</p> <p class="Judg-1"><a id="p1_23"></a>23 The Wife’s request in respect of Item 2 is disallowed.</p> <p class="Judg-1"><a id="p1_24"></a>24 I come now to Item 3. It was a rather lengthy interrogatory comprising several parts. In essence, the Wife wanted the Husband to explain and provide details of several transactions. The Wife also queried the Husband on his business expenses.</p> <p class="Judg-1"><a id="p1_25"></a>25 At the outset, I observe that the Wife had also asked, in her request for interrogatories, that the Husband produce various documents:</p> <p class="Judg-Quote-1">b. Based on the NIRI, the Plaintiff seems to allege that he paid $445,000.00 ($150,000.00 + $150,000.00 + $20,000.00 + $10,000.00 + $20,000.00 + $40,000.00 + $5,000.00 + $50,000.00) in legal fees. The Plaintiff is to provide the documents to show that the Plaintiff has paid $445,000.00 to his divorce lawyers.</p> <p class="Judg-Quote-1">c. With reference to paragraph 2.d.ii. of the NIRI,</p> <p class="Judg-QuoteList-2">i. The Plaintiff is to provide the full particulars and withdrawal documents for the investment.</p> <p class="Judg-QuoteList-2">ii. The Plaintiff is to provide the particulars of the payments for the new matrimonial home and renovations? The Plaintiff is to provide the documentary evidence for the same.</p> <p class="Judg-QuoteList-2">iii. The Plaintiff is to provide the details of what happened to the amounts that were not used for the payment to the new matrimonial home and / or renovations? The Plaintiff is to provide the documentary evidence for the same.</p> <p class="Judg-1"><a id="p1_26"></a>26 The Wife had also, in her written submissions, argued that documents should be disclosed as part of any orders made in relation to interrogatories:</p> <p class="Judg-Quote-1">10. Further and specifically to S/N 2 and 3 of the Interrogatories, the Wife highlights and reiterates (with reference to <em>VTQ v VTR</em>) that:</p> <p class="Judg-QuoteList-2">a. It would be in the Husband’s interest to provide full and frank disclosure of relevant documents as this would help dispel any notion or suspicion that he might have dissipated or concealed matrimonial assets.</p> <p class="Judg-1"><a id="p1_27"></a>27 Given this request for documents (see above at [25]), at the hearing, Mr Johns raised an objection on the grounds of legal privilege. He argued that the invoices might be “impacted by solicitor-client privilege” and the Husband should therefore not be ordered to disclose those invoices. Mr Johns, however, took the position that legal privilege was not a bar to ordering that the Husband answer the interrogatories in the event that his answer was found to be insufficient.</p> <p class="Judg-1"><a id="p1_28"></a>28 Leaving aside the question of legal privilege, I do not allow the Wife’s corresponding request for the disclosure of these documents simply because she had not asked for these documents in her application for discovery in SUM 1739. As the court in <em>UJN v UJO</em> <a class="pagecontent" href="javascript:viewPageContent('/Judgment/21836-SSP.xml')">[2018] SGFC 47</a> at [9] (see also <em>WWS v WWT</em> <a class="pagecontent" href="javascript:viewPageContent('/Judgment/31488-SSP.xml')">[2024] SGFC 24</a> at [21]) had made clear, there is a difference between discovery and interrogatories. A request for discovery cannot be smuggled in under the cover of an application for interrogatories.</p> <p class="Judg-1"><a id="p1_29"></a>29 As for the sufficiency of the Husband’s answers in response to Item 3, having read those, it was clear to me that he had replied to every part of the interrogatory which had been posed, and provided ample details. The Wife may well dispute the <em>truth</em> of these answers, but in my judgment, the Wife can have no quarrel with the <em>sufficiency</em> of these answers (see <em>WWS v WWT</em> <a class="pagecontent" href="javascript:viewPageContent('/Judgment/31488-SSP.xml')">[2024] SGFC 24</a> at [27] citing <em>UJN v UJO</em> <a class="pagecontent" href="javascript:viewPageContent('/Judgment/21836-SSP.xml')">[2018] SGFC 47</a> at [12]).</p> <p class="Judg-1"><a id="p1_30"></a>30 For completeness, I note that the Husband had, in response to the Wife’s interrogatory on his business expenses, disclosed a business agreement. That agreement set out the sums which the Husband claims to have incurred, and was, in my view, a sufficient answer to the interrogatory which had been posed. While I have noted above (at [28]) that a party may not, in their request for interrogatories, demand that the other party disclose documents, I would take the tentative view that a party who is responding to an interrogatory can disclose a document as their answer.</p> <p class="Judg-1"><a id="p1_31"></a>31 The Wife’s request in respect of Item 3 is disallowed.</p> <p class="Judg-1"><a id="p1_32"></a>32 I turn now to Item 4. This Item contained interrogatories pertaining to the Husband’s income. The Wife sought details as to the lump sum payments which the Husband had or would receive from his work in April and May 2024 (Item 4a), as well as whether he had won any awards (Item 4b).</p> <p class="Judg-1"><a id="p1_33"></a>33 In relation to the lump sum payments, this interrogatory had been posed in the Wife’s request dated 6 March 2024.<span class="FootnoteRef"><a href="#Ftn_7" id="Ftn_7_1"><sup>[note: 7]</sup></a></span> She had asked whether the Husband would be receiving a lump sum bonus to the tune of $80,000 to $100,000 for work done in April/May 2024. This was the Husband’s response:</p> <p class="Judg-Quote-1">iv. In relation to Interrogatory 6(d), the numbers should be accurately reflected in the income statements.</p> <p class="Judg-1"><a id="p1_34"></a>34 This was, in my judgment, not a sufficient answer. The Husband had not directly answered the question. He provided no confirmation as to whether he would indeed be receiving a lump sum bonus, or the quantum of such a bonus.</p> <p class="Judg-1"><a id="p1_35"></a>35 As for the interrogatory relating to whether the Husband had won any awards at work, he had not provided an answer. The Wife argued that this interrogatory was relevant and necessary to assessing the Husband’s financial capacity and income ability.<span class="FootnoteRef"><a href="#Ftn_8" id="Ftn_8_1"><sup>[note: 8]</sup></a></span></p> <p class="Judg-1"><a id="p1_36"></a>36 This interrogatory was, in my judgment, not necessary to the disposal of the ancillary matters. The Husband had already disclosed his IRAS statements for the years 2021 – 2023.<span class="FootnoteRef"><a href="#Ftn_9" id="Ftn_9_1"><sup>[note: 9]</sup></a></span> There was no need for the Wife to establish the Husband’s “financial capacity and income ability”, by this rather roundabout means.</p> <p class="Judg-1"><a id="p1_37"></a>37 I will therefore order that the Husband answer the interrogatory that had been framed in Item 4a. The Wife’s request in respect of Item 4b is disallowed.</p> <p class="Judg-Heading-1">Orders Made</p> <p class="Judg-1"><a id="p1_38"></a>38 It is therefore ordered that:</p> <p class="Judg-2"><a id="p1_38-p2_a"></a>(a) The Husband shall state on affidavit, pursuant to Rule 63 of the Family Justice Rules 2014, in respect of the following documents as set out at paragraph 8 of the Wife’s affidavit filed in support of SUM 1739 for the period December 2021 to November 2022, 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_38-p2_b"></a>(b) The Husband shall exhibit, in the affidavit, a copy of each of the documents that are in his possession, custody or power. If any of the documents are not in his custody, power or possession, he is to state the reasons why, together with supporting documentation for his explanation (if any).</p> <p class="Judg-2"><a id="p1_38-p2_c"></a>(c) The Husband shall answer, on affidavit, the following interrogatory to the best of his knowledge, information and belief, pursuant to Rule 69 of the Family Justice Rules 2014:</p> <p class="Judg-3"><a id="p1_38-p2_c-p3_i"></a>(i) With reference to paragraph 2.f.iv. of the NIRI, whether the Plaintiff has and / or will receive lump sum payments in April and May 2024.</p> <p class="Judg-1"><a id="p1_39"></a>39 The Husband’s compliance affidavits are to be filed by 2 August 2024. As for costs, parties are to write in with their submissions, which shall be no longer than 3 pages each, by way of letter. This is to be done no later than 22 July. The time limited for filing an appeal shall only begin to run once I have issued my decision on costs.</p> <p class="Judg-1"><a id="p1_40"></a>40 To avoid doubt, nothing I have said in this judgment shall bind the hands of the judge hearing the ancillary matters.</p> <p class="Judg-1"><a id="p1_41"></a>41 Finally, it remains for me to thank Mr Hasif and Mr Johns 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>The Wife did file a request, but the request was not set out in the form as dictated by the Practice Directions. That request came in by way of letter dated 7 May 2024, and the title of that header referred to FC/SUM 1827/2024 which was a reference to a separate application. See Wife’s Affidavit in support of SUM 1739 at p 131.</p><p class="Footnote"><sup><a href="#Ftn_2_1" id="Ftn_2">[note: 2]</a></sup>Wife’s Affidavit in support of SUM 1739 at p 9.</p><p class="Footnote"><sup><a href="#Ftn_3_1" id="Ftn_3">[note: 3]</a></sup>Wife’s Affidavit in support of SUM 1684 at p 140.</p><p class="Footnote"><sup><a href="#Ftn_4_1" id="Ftn_4">[note: 4]</a></sup>Husband’s Affidavit in Reply at p 7.</p><p class="Footnote"><sup><a href="#Ftn_5_1" id="Ftn_5">[note: 5]</a></sup>Wife’s Affidavit in support of SUM 1684 at p 11.</p><p class="Footnote"><sup><a href="#Ftn_6_1" id="Ftn_6">[note: 6]</a></sup>Wife’s Affidavit in support of SUM 1684 at p 20.</p><p class="Footnote"><sup><a href="#Ftn_7_1" id="Ftn_7">[note: 7]</a></sup>Wife’s Affidavit in support of SUM 1684 at p 17.</p><p class="Footnote"><sup><a href="#Ftn_8_1" id="Ftn_8">[note: 8]</a></sup>Wife’s Skeletal Arguments at para 9f.</p><p class="Footnote"><sup><a href="#Ftn_9_1" id="Ftn_9">[note: 9]</a></sup>Husband’s AOM at pp 38 – 40.</p></div></content></root> | 85fc416fd861be4fa59d9045f3903e0795b9fa11 |
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