1. Issues of Fiannce
1.1. How am I getting paid
1.2. What happend with my pay
1.2.1. Money that came to Pakistan.
1.2.2. Some of it is residing in Pakistani Banks.
1.3. Should I move money from USA
1.3.1. I have a 401 K that had 98K in 401/ IRA Now there are 80 K left in it. There was a 32K in a stock program. 32 K was paid to my last attorney.
1.3.2. Should I pay Mr Waller through the IRA account.
1.4. Legal case situation in Pakistan.
1.5. Direction to take in USA
1.6. Expert witness
1.7. Letter from USA attorney general
1.8. She is trying to potray an image of Pakistan
1.9. Company ownership
1.9.1. I have been paid a divident of $1700 for 2012. K1.
1.9.2. Did not file taxes 2012.
1.9.3. I was getting paid through the whole account. So everyones pay was deposited in our account.
1.9.4. So then the question is should I show that all money was in my name and I rest was all expenses. Other option is that we show that this account was only cash and disbursement account and then my part was only $4500 and then show expenses from there.
2. Pakistan Case
2.1. Child custody
2.1.1. 476 - Perjury
2.1.2. Case progression
2.1.2.1. Pleadings
2.1.2.1.1. Junaid
2.1.2.1.2. Irum
2.1.2.1.3. Jurisdiction established
2.1.2.2. Child maintenance Application
2.1.2.3. Visitation order
2.1.2.4. Appeal in District Court
2.1.2.5. Application for interpretation of District court order
2.1.2.6. Writ before Islamabad High Court
2.2. Deposit of Maintenance Nov 28, 2013
2.3. 491 - Habeas Corpus - Illegal confinement of children
2.4. Jactatation of marriage
2.5. Declaratory Suit + injunction
2.6. Damages and perjury
3. Misc Items
4. Time line for our history
4.1. XL sheet for our time line
4.2. Married in 2001 June
4.2.1. Moved to USA in July 2001.
4.2.2. Have three daughters, 11, 6, 3 all born in USA.
4.2.3. Both become US citizens (Through myself) in Feb 2010
4.3. Divorce filed in Pakistan 2012 July
4.3.1. Moved back to Pakistan In Jan 2012.
4.3.2. Travel to Europe in June 2012.
4.3.3. Fights and goes to her family on 26 June 2012.
4.3.4. Files for divorce July 20, 2012.
4.3.5. Files for legal proceedings of Divorce in July 23, 2012.
4.3.6. Divorce finalised on Oct 21, 2012.
4.3.7. Divorce Certificate issued Oct 30, 2012
4.4. Social efforts to settle matters Child visitation, maintenance and support Nov 12- Feb 13
4.4.1. Emails to Plaintiff
4.4.2. Emails to her brother
4.4.3. Mutual friends as mediators.
4.4.4. Mediation document prepared and sent
4.5. Where are the parties
4.5.1. All Children and mother residing in Pakistan.
4.5.2. Court instructs Irum not to remove minors from jurisdiction of court in Feb 2013.
4.5.3. Children on Exit Control list since Nov 2013.
5. USA Case
5.1. Petition
5.2. Motion to Quash Declarations
5.3. Responsive Declarations by Irum
5.4. Rebuttal to Responsive Declaration
5.5. Interrogatories through admissions
6. Discoveries
6.1. Birth and life uptil travelling to USA
6.1.1. Were you born in Pakistan
6.1.2. Are you parents citizen of any other country other than Pakistan.
6.1.3. I agree that all my brothers are also only Pakistani Citizens.
6.1.4. Did you have a valid photo ID showing your citizenship of Pakistan till you reached the age of 18.
6.1.5. Did you attend OPF school for your education.
6.1.6. Did you ever travel to USA before your marriage.
6.1.7. Did you complete bachelors before your came to USA.
6.1.8. Is Maryam Duarana also attending OPF. school
6.1.9. Did you have an application for citizenship for USA before your marriage.
6.2. Medical issues
6.2.1. Agree that I had a medical condition called AV malformation before my marriage.
6.2.2. I had an episode where I had a haemorrhage in my head and I was operated on for that hamiorage before my marriage
6.2.3. I was discharged from Pakistan Institute of Medical Sciences PIMS hospital on January 16 1998.
6.2.4. I was later treated with Gamma Ray sugery in Cromwell hospital for my AV malformation.
6.2.5. I was taking anti seizure medication Valproic Acid before my marriage.
6.2.6. Valproic acid is considered a class D medication.
6.2.7. Maryam was conceived during the first month of marriage.
6.2.8. Saw doctor Dalton in MA during my pregnency.
6.2.9. Doctor dalton adjusted my medication (Valproic Acid) dose.
6.2.10. Maryam was born via C section on the advise of Dr Dalton or Dr Jacobson or Both.
6.2.11. The doctors moved me from Valproic Acid to Lamactal before the birth of my second daughter Fatima.
6.3. Educational activities, its duration employement if any etc.
6.3.1. I was attending Assumption College for my bachelors degree.
6.3.2. I was full time student in Assumption College.
6.3.3. We filed taxes taking advantage of my education advantage.
6.3.4. I was involved in getting clothes from Pakistan and selling them for money in USA.
6.3.5. For my Masters I joined John F Kennedy University SF Bay area.
6.3.6. I joined Santa Clara University within a year of starting course work in John F Kennedy University.
6.3.7. I joined San Jose University for my Masters program.
6.3.8. I agree that I was living in SF Bay area during my education in San Jose University.
6.3.9. I agree that Mr Junaid Qazi was living in San Diego while my studies continued in Jan Jose University.
6.3.10. I agree that Mr Junaid would make frequent visits to SF Bay area during my visit.
6.4. Maryams upbringing
6.4.1. Maryam was slow in her speech.
6.4.2. We had to seek professional help while living in Massachussets from early intervention center.
6.4.3. Kate Anderson was one of the staff from Early intervention that helped Maryam develop her speech capabilities.
6.5. Tax related issues.
6.5.1. I have never held an earning job.
6.5.2. I was a non paid intern with San Diego State University.
6.5.3. I would leave my daughter Fatima with daycare (name) while I would go for my internship.
6.6. Litigation history in USA.
6.6.1. In 2004/ 2005 I had you filed for rear end accident
6.6.2. Agree that in 2006/2007 you made a complaint that a jewish professor had discriminated/mistreated you.
6.6.3. Agree that in 2011 you filed a lawsuit against South West airline for discrimination against you.
6.6.4. Agree that you received six figure settlement in the response to that lawsuit.
6.7. Entire phase of moving back to Pakistan
6.7.1. You were not physically forced to move.
6.7.2. You were not tied or contained during your travel to Pakistan.
6.7.3. You moved with your own free will.
6.7.4. Helped sell the house hold item.
6.7.5. That you were aware that moving out of Country sale was held at your residence
6.7.6. Helped sell the car
6.7.7. That you sent a move out notice to the land lord via registered mail.
6.7.8. That you sent an email confirming that you had sent the move out notice to the landlord
6.7.9. You did not make a complaint to any lawenforcement agency that you were being moved against your will.
6.7.10. That you asked for more time to move because in your email you said that you were "moving for good"
6.7.11. That you helped pack all household items in boxes for your move.
6.7.12. That you vacated the house.
6.7.13. That you had listed the car to move.
6.7.14. more stuff from the declaration.
6.8. Phase from Jan 2012 till June 2012.
6.8.1. Agree that you told your friend Shireen (Amina ) Zia that you were --- > from her declaration.
6.8.2. Agree that you hosted Zia Syed and Owais Anjum at your parents home
6.8.3. Agree that you told them that you were happy with your moving plans.
6.8.4. Agree that you were never beaten while you were in Islamabad.
6.8.5. Agree that you were in contact with legal councils from the US via email between Jan 2012 till June 2012.
6.8.6. Agree that you were allowed to pick and drop the kids at the school and allowed to visit your home.
6.8.7. Agree that your family lives less than half a Kilometer from the respondents home.
6.8.8. Agree that you have four brothers between the ages of 25 to 40 years of age and your father is also alive and does not have any disability.
6.8.9. Agree that your father and family owns Regalia Hotel in Islamabad.
6.8.10. Agree you mentioned in your email to Respondent that you drive good cars. (Do research)
6.8.11. Agree that the childrens school is within half a kilometer of your own home as well.
6.8.12. Agree that you never filed any complaint with any law enforcement agency in Islamabad.
6.8.13. Agree that you traveled to Europe with the defendant.
6.8.14. Agree that you came across several law enforcement and immigration officers officers during your travel in Europe.
6.8.15. Agree that your children were never physically harmed by the defendent.
6.8.16. Agree that you moved money to Pakistan.
6.8.17. Agree that you purchased immoveable property in the month of June 2012 in Pakistan.
6.8.18. Agree that you closed your bank accounts in USA.
6.8.19. Agree that you renewed your driver license in September or October 2013.
6.8.20. Agree that you had possession of your and the childrens passports between June 26 2012 till date.
6.8.21. Agree that you never mentioned in any court proceedings till October 2013 that you had been forced to move to Pakistan. (use exact language)
6.8.22. Agree that in your pleadings of October 2013 you mentioned that the defendant had tricked you into coming to Pakistan. (Exact language)
6.8.23. Agree that you had filed a response mentioned that you had been held against your will.
6.9. Moving out and shifting with parents (7)
6.9.1. Agree that you moved out of the house of the defendant with your own free will.
6.9.2. Agree that you sent the defendant a divorce deed dated July 20, 2012.
6.9.3. Agree that you filed divorce proceedings with the Union Council on July 23, 2012.
6.9.4. Agree that you were represented by Barrister Usman Mughal in Union Council.
6.9.5. Agree that you received an email from the defendant dated ( ) where he made you an offer that you could live at your parents home and he could spend time with you over weekends or spend foreign travel together.
6.9.6. Agree that the defendent filed a response to the union Council asking that he wanted the marriage to be saved (Exact language)
6.9.7. Agree that your council filed an answer that you did not want reconciliation.
6.10. Proceedings of divorce (15)
6.10.1. Agree that you were given a certificate of Divorce on October 30 2012.
6.10.2. Agree that you did not ask for maintenance and child support in your divorce proceedings.
6.10.3. Agree that you have recieved all the provisions of the Nikkah Nama / Marriage contract.
6.10.4. Agree that you could have asked for any property in article 16 of the Nikkah Nama provided both the bride and groom agreed upon it.
6.10.5. Agree that you could have written any monitory caluse in article 16 of the Nikkah Nama.
6.10.6. Agree that the Nikkah Nama/Marriage contract was written by your own brother and registered in Pakistan by your own brother.
6.10.7. Agree that your marriage with Defendent was never registered anywhere in United States.
6.10.8. Agree that your Divorce Certificate was issued in Pakistan.
6.10.9. Agree that during the divorce proceedings you traveled out of the country.
6.10.10. Agree that you did not sell your property in Islamabad Sector G 14.
6.10.11. Agree that you have not challenged your divorce proceedings in Paksitan.
6.10.12. Agree that you only allowed the father to see his middle daughter Fatima twice, once in Ali Medical Center and the second time in Serena Hotel between June 2012 till November 2013.
6.10.13. Agree that you only allowed the father to see his youngest daughter Khadija once in Serena Hotel between June 2012 till November 2013.
6.10.14. Agree that you never allowed the father to see the oldest daughter to meet with the oldest daughter Maryam between June 2012 till November 2013.
6.10.15. Agree that in your knowledge the first time the father met Maryam since June 2012 was in january 2014.
6.11. Travel to Japan
6.11.1. Agree that you traveled to Japan (Exact Date)
6.12. Updating the Nicop (7)
6.12.1. Agree that you updated your National ID Card of Overseas Pakistanis in September or October 2012.
6.12.2. Agree that you updated your permanent address on your NICOP to Sehar Bagla, Paksitan.
6.12.3. Agree that you updated your Current Address to 56 A Margalla Road on your NICOP.
6.12.4. Agree that only Pakistani Nationals can get a NICOP.
6.12.5. Agree that you still have a valid National ID Card for Overseas Pakistanis.
6.12.6. Agree that the children Maryam Junaid, Fatima Junaid and Khadija Junaid have been in Pakistan since Jan 2012 and have not left Pakistan Since Jan 2012.
6.12.7. Agree that the children are admitted in school/s in Pakistan.
6.13. Settlement, money transfer, property purchase (3)
6.13.1. Agree that you moved money from USA to your bank account in Paksitan.
6.13.2. Agree that you purchased a plot of land in Sector G 14 of Islamabad.
6.13.3. Agree that you are still in possession of that plot of land and it is still in your name.
6.14. Guardian proceeding (4)
6.14.1. Agree that you were served notice for Guardian petition filed a response to Guardian petition.
6.14.2. Agree that in your pleadings of Guardian Petition you mention that " The Children are only US Nationals and they are not Pakistani Nationals"
6.14.3. Agree that in the order of June 6, 2012, the Court mentions that both children are dual nationals of Paksitani and American decent.
6.14.4. Agree that in your petition of date (Some date) you mention that the children are not Pakistani Citizens.
6.15. US petition and perjuries in US petition (24)
6.15.1. requirement of residency
6.15.1.1. Agree that you have never physically lived in Orange County between July 2001 till September 2013 for more than a week.
6.15.1.2. Agree that you have never paid Orange County property tax or rented an apartment in OC between July 2001 till September 2013.
6.15.1.3. Accept that I have not married or domestic partner of anyone currently residing in USA.
6.15.2. Concealment of pending and concluded cases in Pakistan. (17)
6.15.2.1. Accept that at the time of filing of the divorce paperwork in Orange County there were custody proceedings pending in Pakistan.
6.15.2.2. Accept that your council responded to the custody proceedings claiming that the courts in Pakistan did not have jurisdiction over the subject matter.
6.15.2.3. Accept that the court order of June 6,2013 states that "Exact wordings or jurisdiction"
6.15.2.4. Accept that I challenged that the childrens names not be put on ECL in the additional session court.
6.15.2.5. Accept that the court did not remove the names of the children from ECL.
6.15.2.6. Accept that you filed a lawsuit in Islamabad High Court and in the prayer you requested that the names of the children should be removed from ECL.
6.15.2.7. Accept that the Islamabad High Court did not remove the names of the children from the ECL.
6.15.2.8. Accept that you did not comply with the orders of the Islamabad High Court to submit the passports of the minors to the Court.
6.15.2.9. Accept that after the high court you filed another application with the family Judge to allow the children to leave Pakistan.
6.15.2.10. Accept that there are medical doctors and medical hospitals in Pakistan.
6.15.2.11. Accept that after the Arbitration Council of Islambad issued a valid Divorce certificate, the matter MFLO 288/2012 was concluded and finished.
6.15.2.12. Accept that I mention on my filing in CA court that MFLO 288/2012 is pending.
6.15.2.13. Accept that I did not disclose that there are custody proceedings pending in Islamabad Pakistan in my filing of dissolution of Marriage.
6.15.2.14. Accept that I did not mention that I had received a divorce certificate certificate issued in October 2012.
6.15.3. Forged documents (3)
6.15.3.1. Accept that I have received a certificate from the Union Council/Arbitration Council of Islamabad/Pakistan stating that the parties are advised to adjucate matters of divorce inside or outside of Pakistan.
6.15.3.2. Accept that you your self went to the Arbitration Council to receive that letter.
6.15.3.3. I accept that the arbitration council functions under article 6 of the Muslim Family law of Pakistan.
6.15.4. False accusations
6.15.4.1. Have to look at her declaration
6.16. Pakistan Guardian case.
6.16.1. November 16 till Jan 27 no access to kids
6.16.2. Withdrawl of writ petition.
6.17. Child support offer and refusal (5)
6.17.1. Accept that the defendent sent Mr Nasir Majeed with offer to settle matters and give him right to see the children between November 2012 till Jan 2013.
6.17.2. Accept that before my flying out to USA in September 2013, the defendant had filed an application with the family court that he be allowed to deposit maintenance in court.
6.17.3. Accept that you refused to give access to the children to the defendant.
6.17.4. Accept that your brother received two checks from the defendent via TCS (Courier service) in August 2012.
6.17.5. Accept that you had refused money orders sent by the defendant in March 2013.
6.18. Children registeration (5)
6.18.1. I accept that the children are registered in NADRA.
6.18.2. I accept that only Pakistani Nationals and citizens can be registered in NADRA
6.18.3. I accept that according to Pakistani law if the father is a Pakistani National then the children automatically are Pakistani Nationals.
6.18.4. I accept that the father of the children is Pakistani National and was only Pakistani National at the time of Marriage.
6.18.5. I accept that my husband's green card was sponsored by his employer Intel and I received my green card because of being a spouse of the defendant.
6.19. Wealthy family (6)
6.19.1. Accept that my father owns a hotel in Islamabad and we live in F 8 islamabad.
6.19.2. Accept that you mention in your email that the children are well taken care of in Islamabad.
6.19.3. Accept that the daughter Maryam you mention in your email performed well in her school.
6.19.4. Accept that Maryam has a tutor that comes to tutor her after school hours.
6.19.5. Accept that you have a maid to take care of Khadija
6.19.6. Agree that the children did not leave Pakistan since January 2012 till April 4, 2014.
6.20. Brothers pregnancy tourism
6.21. Vote in Pakistan (3)
6.21.1. Agree that you are a registered voter of Pakistan.
6.21.2. Agree that you cast your vote in the General Election of Pakistan held in May 2013.
6.21.3. Agree that only Pakistani Nationals are allowed to cast a vote in Pakistan.
6.22. Work in Paksitan (3)
6.22.1. Agree that you mention in your petition that you were teaching in Quaid Azam University and islamic University of April (Some date)
6.22.2. Agree that Non Pakistani Nationals/ citizens require a work permit to work in Pakistan.
6.22.3. Agree that I did not have a work permit till June 2013.