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Clare, Solicitor
Category: Law
Satisfied Customers: 33004
Experience:  I have been a solicitor in High Street Practice since 1985 with a wide general experience.
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Have a court order to attend a Family Court at Bromley on

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Hello All.
Have a court order to attend a Family Court at Bromley on 21st July. I am disputing some of the statements that my wife is making because of a divorce. Need to file sworn evidence to her, or her solicitors 48 hours prior to the hearing. She has already made a statement, and I haven@ I'm currently unemployed, hence asking you if you can't take my case. I do however have the means to have a solicitor in court if required but need to discuss this beforehand.
Would really appreciate your consideration of this given the emergency and have some one to call me.
You can contact me on ***********
Yours sincerely.
Paulo Azevedo
Submitted: 3 months ago.
Category: Law
Expert:  Clare replied 3 months ago.

Thank you for your question

My name is Clare

I shall do my best to help you but I need some further information first

What is she actually asking for?

Customer: replied 3 months ago.
Hi Clare,
My apologies for late reply. Been with my wife for 10 years, and supporting our family financially for the last 9 bar a few months since my wife was made redundant. My wife hasn't worked since January 2009, and we have never been on benefits. Circ**tsances changed in Feb 2013 when I was made redundant at State Street Bank & Trust after 13 years of continuous service. My role was outsourced to Cape Town. I was in a process of moving there, but then found that my wife, Hanna, was pregnant with our second child after months of trying including visits to hospitals considering IVF.
At this point I decided that it was not a good idea to move there. State Street offered me a job in Edinburgh which I declined. I decided to take the money and stay with my family in London. Things didn't quite worked the way as I expected as the financial industry went into a melt down after 2008. I then started drinking, which in future years I sought help. Hanna in the mean time, I assume now after reading her statement which I dispute, started a diary.
I'm attaching the court orders and her statement.
I need a one to one to discuss all this, her statement and everything else.
As you can see from the court order I need to file a sworn evidence to the court by the 19th so this is urgent.
Non - Molestation Order In the
Family Court at BROMLEY (Under section 42 of the
Family Law Act 1996) Case No. BR16F00229
Applicant Hanna Azevedo
To Paulo Azevedo Ref
of Flat 3
Beech House Respondent Paulo Azevedo, date of birth 09/04/1970
Ainsley Estate
Swan Road
SE16 7DQ
Amended pursuant to FPR 2010 rule 29.16 on 11th July 2016
Important Notice to the Respondent Paulo Azevedo, date of birth 09/08/1970
You must obey this order.You should read it carefully. If you do not understand
anything in this order you should go to a solicitor, Legal Advice Centre or Citizens
Advice Bureau.You have a right to apply to the court to change or cancel the order.
If, without reasonable excuse, you do anything which you are forbidden from doing by this order, you
will be committing a criminal offence and liable on conviction to a term of imprisonment not exceeding
five years or to a fine or to both.
Alternatively, if you do not obey this order, you will be guilty of contempt of court and may be sent to
On 7th July 2016, Deputy District Judge Mills,
sitting at the Family Court at Bromley, College Road, Bromley, Kent, BR1 3PX
considered an application and determined that it would make an order even though the Respondent had not
been given notice because it considered that there was a risk of significant harm to the Applicant or a relevant
child attributable to the Respondent if the order was not made immediately.
From and after the time when the Respondent is made aware of the terms of this order whether by personal
service or telephone or text message or otherwise the Respondent whether by himself or acting jointly with
any other person is forbidden to:
1) Use or threaten any violence towards the Applicant.
2) Threaten, intimidate, harass or verbally abuse the Applicant in any way.
3) Go to Upper Flat, 6, Carholme Road, London SE23 2HS or go into the road known as Carholme Road, or
go within 50 metres of 6, Carholme Road or go to any property at which he is aware that the applicant is living.
FL404A Non-Molestation Order
The Family Court at Bromley, College Road, Bromley, Kent, BR1 3PX. Please address all communications to the Court Manager and quote the case number.
Tel:(###) ###-####9620 Fax: 0870(###) ###-####Produced By: Miss D Collier Page: 1
4) Send any threatening or abusive letters, emails, text or voicemail messages to the Applicant.
5) Make any threatening or abusive telephone calls to the Applicant.
6) Communicate with the Applicant whether by letter, telephone, text message or other means of communication
except in connection with these proceedings and then by text, email or letter only.
7) Go to Dalmain Primary School, Brockley Rise, Lewisham SE23 1AS and Busy as Bee's on Brockley Rise,
Lewisham SE23 1AS or go into Brockley Rise between 8.00am and 10.00am and 12.00 noon to 1.30pm and
2.30pm-4.00pm during term time.
8) Make any reference to the applicant, the children or these proceedings on Facebook, Twitter or any other
Social Network Site.
9) Damage or attempt to damage or threaten to damage any of the contents of Upper Flat, 6, Carholme Road,
London SE23 2HS.
10) The Respondent is also forbidden to instruct or encourage any other person to do anything which he is
forbidden to do by the terms of this order.
This order shall remain in force until 4.00pm on the 7th July 2017 unless before then it is varied or discharged
by an order of the court.
Either the Applicant or their solicitors must arrange for its service on the Respondent.
Costs reserved.
The court will re consider the application and whether the order should continue at a further hearing
at the Family Court at Bromley, College Road, Bromley BR1 3PX
Customer: replied 3 months ago.
Hanna's statement that I am disputing and need to reply toNo. of Witness Statement
On behalf of:
No. of Exhibits:IN THE C1 COUNTY COURT
Applicant-and-R1 Paulo Azevedo
FIRST WITNESS STATEMENT OF A11. I, A1, a housewife, live at ADDRESS- Upper Flat,***** London, SE23 2HS.2. The Respondent, R1, and I are associated persons within Section 62(3) of the Family Law Act 1996 because we are married.3. I am making this Witness Statement in support of my application to this Honourable Court, made without notice to the Respondent for a non-molestation order and occupation order.4. I was born on 03/11/1975 and am 40 years of age.5. The Respondent, my husband, unemployed, was born on 09/04/1970, is 45 years of age and is currently living at address: Flat 3, Beech House, Ainsley Estate, Swan Road, London, SE16 7DQ.6. I have 2 children by the Respondent, named: Anabella Marie Azevedo (Born: 17/12/2009), Leon Alexandre Azevedo (Born: 08/01/2013). Who live at address: Upper Flat,***** London, SE23 2HS.7. I first met the Respondent in April 2006. We were in a relationship from April 2006. We married on 11/04/2008.8. The Respondent has lived with me at my home address between July 2007 and March 2016. My home is a 3-bedroom house which is privately owned. The mortgage is in joint names.
9. My relationship with the Respondent was in initially good. Our relationship began to change gradually as I was always concerned that he drank too much but when I tried to address it he claimed that ‘it was in my head’. It escalated to a more radical level in February 2013 when he was made redundant from his job and was also given 10 years to live by the dr based on his level of drinking. He promptly got another job through a former client but was dismissed within 2 weeks. He was completely unmotivated and spent most of his days sleeping and in a very negative mind-set. I hoped that it was just a phase that would pass but he was brought home in an ambulance on one occasion after he had been found unconscious on a pavement by a stranger (admitting that he was drinking 1 litre vodka per day). He also had 2 car accidents on 10th August 2013 and 1st January 2014 which resulted in claims from the other parties for whiplash (affecting my insurance).
10. In August 2013 I needed a break and went away with the children for a few days to give him space to think about his behaviour and the effect it was having on the family. On our return he agreed to engage in substance misuse services and went to see the dr. I also started going to a weekly friends and family group and educating myself about addiction.
11. On 2nd November 2013 I tried to leave to stay with my parents as it was my birthday weekend and I was very distressed about his behaviour but he physically pinned me down in front of the children resulting in me having a panic attack and took the car keys from me preventing me from leaving.
12. He was in services until the end of November 2013 when he disengaged saying that he no longer needed help.
13. In February 2014 he started a job at Citi Bank in Edinburgh and had that for 3 weeks after which he was dismissed for smelling of alcohol whilst working. We were due to go to a wedding in Belfast just after this incident and 7 plane tickets were wasted due to him double booking flights and missing flights due to intoxication (we never ended up going).
14. I again tried to get him back into engaging with services which he eventually did reluctantly in April 2014. He did a detox with CRI, Lewisham and aftercare with TTP, Deptford but as soon as he finished started drinking again saying that he would ‘never stop drinking’ but would remain in control of it. During this time his behaviour deteriorated and I often felt as though the children and I were walking on eggshells.
15. I was extremely concerned with his behaviour but continued to be supportive in the hope that things would improve. In September 2014 he was offered a 9 month contract with HSBC but for various reasons (relating to HSBC internal politics) he did not start until January 2015. Whilst he was waiting he took up some volunteer work for VSL (Voluntary Services Lewisham) which involved driving people to and from meetings/ clubs/ family gatherings. Despite this, I was still concerned that he was in a negative mind-set and did not seem to be mentally preparing himself for the job. He worked at HSBC for 5 months (during which I bought him a mindfulness and CBT course to help his mind-set but he never took any interest in it despite me asking whether he’d do it before purchasing it) but on the 29th May 2015 was dismissed for breach of contract (he was initially sent home but instead of going home, he tried to call his colleague from the reception and had to be removed from the premises by security
Expert:  Clare replied 3 months ago.

When did you separate?

Clare, Solicitor
Category: Law
Satisfied Customers: 33004
Experience: I have been a solicitor in High Street Practice since 1985 with a wide general experience.
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