Our legal standing

1. 39. Irum She was restrained from traveling

1.1. Look at court order sheet. in my second declaration Ex 25. True copy and translation of court order sheet. Lie.

1.2. The courts directly 1-4 not to remove minors from the custody of the court. She is not a minor.

2. 15a Abduallah alimony

2.1. Ilyas 55 -58 and conclusoin

2.2. Noman 2nd declaration 13 A

3. 15 b Abduallah property rights.

3.1. Noman 2nd declaration 13 B

3.2. Ilyas Zafar 56 - 58 and conclusion.

4. 15c Abduallah Child support

4.1. Noman 2nd declaration

4.2. Also it is on the judges desecration to decide.

4.3. We suggest an amount and then leave it to the judge to decide spousal support and child maintainence. Judicial Notice - Pg 5 Para 17. This case was filed on Feb 16, 2013. However Judgement of Nov 16, says we cannot submit child support as this is guardian petition. We filed a separate suit Junaid Qazi Second declaration Ex 27 using the same cause of action of Feb 16, 2013. However we have filed an appeal against the objection of allowing us to submit child support in the Hight Court of Pakistan. Therefore this judgement is not final What is final is that we are submitting child support in court and willing to give handsome amount as spousal support as well.

4.3.1. She will make big fuss of this.

4.4. Noman 2nd Declaration Para 13 C

5. 15 D Abduallah Child custody standard

5.1. Ilyas Zafar 53, 54 & 55.

5.2. Nomans second declaration 13 D

6. 13, 14 of Abduallah

6.1. Noman 2nd Declaration 12

6.2. Ilyas Zafar. 56, 58

7. 4. Amir Abdullah CAC statement

7.1. Noman Farooqui.

7.2. Ilyas Zafar. pt 32.

7.3. Ilyas Zafar pt 34

7.4. Ilyas Zafar pt 35. Basically if she wants to fight the validity of the CAC divorce, she can do so in Pakistani Civil Court system. She should first fight the validity of the divorce in Pakistan and get it null and void before coming to US and forum shopping.

7.5. Ilyas Zafar pt 37.

7.6. Please refer to the divorce being legal final and conclusive in the certificate issued by CAC . Noman 2nd Declaration Ex 2.

7.7. The proceedings of CAC can be initiated by people residing outside of Pakistan. So the final statement only refers to people who are residents outside of Pakistan.

8. Aleem vs Aleem

8.1. Distingusings facts.

8.2. Divorce proceedings in USA by wife were already pending.

8.3. Person travelled to Washington DC and divorced her during the pendency of that divorce in Pakistan Embassy. In the Embassy, he pronounced divorce.

8.4. Both husband and wife were residents of Maryland. They stayed in Maryland even after divorce.

8.5. It was offensive to public policy because in Talaq only the husband can give divorce. In my case, it was equal right to divorce which the woman used to divorce the man. Therefore it is not offensive to any law.

8.6. More relavent is Chaudhry vs Chaudhry because in Chaudhry vs Chaudhry, the divorce took place in Pakistan while both parties were in Pakistan.

8.7. Irum had the option to come to USA for two years. She choose to stay in Pakistan for this time frame.

8.8. In caes of our divorce, the property rights were cut out as in nil. (Not left blank) Therefore it means that she does not get property rights.

9. 6. Abdullah Separation and not divorce

9.1. She says that the defendant left for Pakistan before the divorce was finalized and retuned after it was finalized. Judicial Notice, Exhibit 12, Pg 6, First para last three lines.

9.2. She claims to be well educated. She could have come to US and filed for separation.

9.3. Contents Noman 2nd declaration. Item 7.

9.4. She is forum shopping. Judicial Notice Ex 12. Page 4 para 16. She states in her own declaration that the wards act favours the mother for custody of daughters. So she knows where to take advantage of the legal system. But for the issue of division of assets she wants to flee to US court.

9.5. Para 35 -37, 43, 44 of Ilyas zafar declaration.

10. 40. Threatened her of blood shed.

10.1. Did not threaten her.

10.2. If she did have bookings, She did not submit them in court.

10.3. Why is she now dragging me through US courts

11. 7-10 Opinion of Mr Abbasi

11.1. Para 9 & 10 of nomans second declaration.

11.2. Para 35 - 46 of ilyas zafar declaration.

12. 11. Not dual nationals

12.1. He is an ass hole. Ex 16 of Judicial Notice. Order clearly stated they are dual nationals. and ordinarily residing in Pakistan.

12.2. She had the chance to plead her case before the judge. She did that but the ground facts were very different. Exibit 23 of Judicial notice as well.

12.3. NADRA (National Database Registeration authority)

13. Not a prenop agreement

13.1. Noman 2nd declaration. pt 12.

13.2. Ilyas Zafar pt 54-58 talks about case laws in Pakistan where the articles in the property awarded to wife is very strongly implemented. Please read carefully to understand these case laws which prove that Pakistani law awards property very strongly if mentioned in Nikkah Nama.

13.3. Ilyas zafar Para 45 and 46 anteneptual agreement.

14. 41. The first time we moved to CA was in 2006.

14.1. So we possibly could not file for taxes for the last 11 years in CA. This is a blatant lie.

15. 3. Amir Abudullah CAC issues religious decree.

15.1. Noman 2nd Declaration. Pt 4. This is under muslim family law.

15.2. Declaration of Ilyas pt 25.

15.3. Declaration of Ilyas pt 27. Union council in Basic democracies order, 1959.

15.4. To get a religious decree, All she had to do was to pronounce divorce 3 times. The Divorce Deed is enough for religious decree. To register it in Union Council is to give it legal finality.

15.5. He has made a statement without any case law or proof.

15.6. CAC/ union council is recognised in UK law. Ilyas Zafar declaration 38-41. Recognised in USA 42 - 43. In Canada pt 47, 48