Form 49 [Rule 13.19] - 8 COURT FILE NUMBER 4801 15085 CIerk?s Stamp COURT COURT OF BENCH OF ALBERTA JUDICIAL CENTRE CALGARY PLAINTIFF HASINA SHAH DEFENDANT OMID EBRAHIMI DOCUMENT AFFIDAVIT ADDRESS FOR SERVICE AND A. Paul Allyjan CONTACT INFORMATION OF Barrister Solicitor PARTY FILING THIS DOCUMENT Allyian Familythaw 205, 535 10 Avenue SW. Calgary. Alberta TZR 0A8 p. (403) 718?9891 f. (403) 538-3777 AFFIDAVIT OF OMID EBRAHIMI, THE DEFENDANT Sworn on May 24, 2016 l, Omid Ebrahimi, of Alberta. SWEAR AND SAY THAT: 1. I am the Defendant herein and as such I have a personal knowledge of the matters hereinafter deposed to except where based upon belief. and where so stated I verily believe the same to be true. 2. There is one child of the the name and birth date of each child of the marriage or relationship is as follows: Elnaz Ebrahimi. born February 2010 3. On or about May 2012 a Consent Order was granted by the Honourable Madam Justice S.L. Martin providing inter alia for primary care and control of our child to be with me. 4. My mother, Mansoreh Haidary (hereinafter the ?Grandmother"), lived with me and was often providing child care for me post-separation. Over the last 3 years. the Grandmother became increasingly involved in my daughter?s life. 5. Approximately 3 months ago, the Grandmother and I had an argument and I left the home. I left my daughter with her Grandmother. as they were very close and Elnaz was happy in her care. I was told that the Grandmother was considering taking a vacation to visit family in Germany, Sweden and Iran. Communication between the Grandmother and I became very strained to the point where communication more or less stopped. Unfortunately this argument has grown to the point where some of my family members and I no longer speak with each other. 6. I was told that in order for the Grandmother to pursue a child support application against the Plaintiff, as she was not paying any child support at the time that I would have to sign some paperwork. I did not understand the form that was signing at the time. but I have now been informed that the paperwork was a travel authorization. I do have some dif?culties with the English language. Attached hereto and marked as exhibit is a capy of the travel document. 7. On or about May 3rd. 2016 I am told and do verily believe that the Grandmother travelled with the child to Germany. I did not become aware of this travel until May 2016. I do not know how the Grandmother travelled without the Plaintiff?s consent. 8. con?rm that I did attend at the representative for the central authority in order to facilitate the Plaintiff?s Hague application, and all they told me they needed was a copy of the Order granted by the Honourable Madam Justice K.D. Nixon on or about May 2016. 9. have now become aware that the Grandmother has travelled from Germany to Iran for vacation purposes. I have attempted to contact my Brother in Germany, however he refuses to speak to me. Therefore I have had asked my sister. Farinush Ebrahimi, to try and speak to both my brother and the Grandmother. 10. My Sister has spoken to the Iranian embassy in Washington. D.C., USA in order to inquire as to getting a visa to visit Iraq in order to return the child to Canada. My Sister was told that applying for a visa with a Canadian Passport is a very long process. My sister therefore has inquired whether it will be easier to enter Iran under a Afghani Passport. as both she and I hold Afghani Citizenship. My Sister in speaking with the Afghan embassy has advised me that it will take approximately 3 weeks to receive an Afghanistan Passport and then another 3 weeks to get a visa to enter Iran. 11. I am told by my sister that in speaking with the Grandmother that she intends to return to Germany on or about June 2016. I would propose that I be allowed to travel to Germany to recover the child and accompany her back to Canada. Attached hereto and marked as exhibit is a copy of the Grandmother's tickets. 12. Further, can con?rm that my Sister has asked the Grandmother to return to Canada immediately in order to avoid any further complications and to ensure that my daughter is safe. My Mother. the Grandmother. is complaining that due to health reasons that it is dif?cult for her to travel right now, however she anticipates being able to travel in June. 2016. have asked that the Grandmother change her travel plans in order to return with the child to Canada as soon as possible. 13. I am certain that if this Honourable Court is willing to delay the proceedings until late June or early July, 2016 that Elnaz will be returned to this Jurisdiction. I would prefer not to have to have the German or Canadian Authorities involved as I am sure the same will be traumatic to my daughter. 14. make this af?davit in response to the Plaintiff?s application and for no improper purpose. SWORN BEFORE ME at ary, Alberta, this 24th day of May, 2016. ?1 . Ear?J?. ff X/{xf? a x? for a tie/in an eithe Province ofAlberta A. Paul Allyjan Barrister Solicitor o??im EBRAHIMI v1.1 5mm: Io mm 4 m-ywm, Hwn, Manor w: m: um m- me pun-m sow Wu 5911>>! my" me mam; x: min?" 51 mung macumcm I mummluwem'cmmnu Jar-991m" r44 my 0m me (his 13 mmlum nmuumumuuw I .mwuw um. WWNII) Mum-m and . ammo-nmnm a mm, .n a max 1m "mace D, . mm MGM 9a: Page 1 of4 Subject: TK TICKET: Confirmation for reservafion Ebrahimi, Calgary, 06 May. Date: Tue, 22 Mar 2016 13:32:12 43400 "Us is the ticket of my mother and elnaz. 1.81515 EXHIBIT 15 referred in in th: Affidavit of . . Confirmation for reserva on 33?; mm" 20 A YDU can review yourreservation inlormauan beiow . A Cami To see (he lalesl infurmatlon about your reservation, you can 90 In com and for "in Provin: {Albcna Your reservation Ball} 72:" Booklng monatinn number: sis'rsv We mcommand you make a "are ml 019 booking reservaiinn number nr pnril this mail Traveller inlormatlon Miss Elnaz Ehrahim Mansoureh Hanan e-licket numbers Oniy eriickel numbers we aispiayed when may are issued Dncumenl :Igary - CllgiryElnaz Ehrahlmi - c-ignryuisnsouveh Haida" your selection Airline numhari Airllnel Rrsaiv eaig-ryrouiunnaa IFlignH Friday. Mayae,2oiu cqnfimied Denamire: 12 in Calgary' Canada 7 caigary Imemaiicnal 7m Page 2 of 4 Arrival: 18:15 Montreal. Canada Pierre E. Trudeau International Airline Turkish Airlines TK 9103 Aircraft: Airbus Industrie A320 Operated by Air Canada Last check in: information not available Fare type: Economy Restricted Meal: information not available Change of plane requrred. Time between flights 4 50 I Flight 2 Friday, May 06, 2016 confirmed Departure: 23:05 Montreal. Canada - Pierre E. Trudeau International Arrival: 15:45 +1 day(s) Istanbul. Turkey - Ataturk, terminal Airline Turkish Airlines TK 036 Aircraft: Airbus Industrie A330-300 Last check in: information not available Fare type: Economy Restricted Meal: MEAL (NON SPECIFIC) Change of plane required. Time between ?ights: 4:25 Flight 3 Saturday. May 07. 2016 confirmed Departure: 20:10 Istanbul. Turkey - Ataturk. terminal I Arrival: 01:35 +1 day(s) Mashhad. Iran - Shahid Hashemi Nejad Airline Turkish Airlines TK 888 Aircraft: Boeing 737-800 (Winglets) Last check in: information not available Fare type: Economy Restricted Meal: MEAL (NON SPECIFIC) Mashhad to Hamburg Flight 1 Wednesday, June 29, 2016 confirmed Departure: 02:30 Mashhad. Iran - Shahid Hashemi Nejad Arrival: 05:30 Istanbul. Turkey - Ataturk. terminal I Airline Turkish Airlines TK 889 Aircraft: Boeing 737-800 (Winglets) Last check in: information not available Fare type: Economy Restricted Meal: MEAL (NON SPECIFIC) Change of plane required. Time between ?ights 1:05. Flight 2 Wednesday, June 29, 2016 con?rmed Departure: 06:35 Istanbul, Turkey - Ataturk. terminal I Arrival: 08:55 Hamburg. Germany - Hamburg, terminal 1 Airline Turkish Airlines TK 1661 Aircraft: 32B Last check in: information not available Fare type: Economy Restricted 2016-05-75 . Page 3 of 4 Meal: MEAL (NON SPECIFIC) Hamburg to Calgary Flight 1 Sunday, August 28, 2016 confirmed Departure: 07:20 Hamburg, Germany - Hamburg, terminal 1 Arrival: 11:30 Istanbul, Turkey - Ataturk. terminal I Airline Turkish Airlines TK 1668 Aircraft: Airbus lndustrie A321 Last check in: information not available Fare type: Economy Restricted Meal: MEAL (NON SPECIFIC) Change of plane required. Time between ?ights 2:35. Flight 2 Sunday, August 28, 2016 confirmed Departure: 14:05 Istanbul, Turkey - Ataturk, terminal I Arrival: 17:40 Montreal. Canada - Pierre E. Trudeau International Airline Turkish Airlines TK 035 Aircraft: Airbus lndustrie A330-300 Last check in: information not available Fare type: Economy Restricted Meal: MEAL (NON SPECIFIC) Change of plane required. Time between ?ights 3:25. Flight 3 Sunday, August 28, 2016 confirmed Departure: 21 :05 Montreal. Canada - Pierre E. Trudeau International Arrival: 23:45 Calgary, Canada Calgary International Airline Turkish Airlines TK 9102 Aircraft: Airbus lndustrie A319 Operated by Air Canada Last check in: information not available Fare type: Economy Restricted Meal: information not available Flight payment Air Fare not Available Flight Notes - Not all seat and meal options are offered on all ?ights. - Specific rules and restrictions may apply to this fare. - Taxes are included except where local airport taxes are collected at check-in time. Flight special requests Meal and seat request: Traveller Seat number Seat location Meal preference Calgary - Mashhad . Flight 1: Calgary - Montreal Elnaz Ebrahimi None speci?edNone Speci?edVegetarian vegan . Mansoureh HaidariNone speci?edNone speci?edVegetarian vegan Flight 2: Montreal - Istanbul Elnaz Ebrahimi 13A None speci?edVegetarian vegan Mansoureh Haidari13B No'ne speci?edVegetarian vegan 2016?05?75 er i? Page 4 of 4 Flight 3: Istanbul - MashhadEInaz Ebrahimi 5E None speci?edVegetarian vegan Mansoureh HaidariSF None speci?ed'v'egetarian vegan Mashhad - Hamburg Flight 1: Mashhad - IstanbulElnaz Ebrahimi 6E None speci?edVegetanan vegan Mansoureh HaidariSF None speci?edVegetarian vegan Flight 2: Istanbul HamburgElnaz Ebrahimi 6E None speci?edVegetarian vegan Mansoureh Haidari?F None speci?edVegetarian vegan Hamburg - Calgary Flight 1: Hamburg - IstanbulEInaz Ebrahimi None speci?edNone speci?edVegetarian vegan Mansoureh HaidariNone speci?edNone speci?edVegetarian vegan Flight 2: Istanbul - Montreal Etnaz Ebrahirni None speci?edNone speci?ed?v'egetarian vegan Mansoureh HaidariNona speei?edNone speci?edVegetarian vegan Flight 3: Montreal - Calgary Elnaz Ebrahimi None specifiedNone speci?edVegetarian vegan Mansoureh HaidariNone speci?edNone speci?edVegetarian vegan Other requests Traveller Speci?cations Meet and assist travellers with special naeds:E naz Ebrahirni None speci?ed I Mansoureh HaidariNone speci?ed Wheelchairs needed: Elnaz Ebrahimi Mansoureh HaidariD airline has your seat or meal requests. If It has not been con?rmed WltI?Iln 24 hours, you may want to contact the airline _direct _y general remarks TOTAL PAID $3225 AT TD BANK AT 22MAR16 PLEASE RECONFIRM YOUR TICKET 3DAYS BEFORE DEPARTURE VALID PAPSSPORT FOR 6 MONTHS AND APPLICABLE VISA IS MANDATORY PLEASE CHECK FOR MORE INFORMATION CHANGE AFTER DEP. SUBJECT TO AIRLINE DIFF. FARE CANCEL FEE B4 B4 DEP: $350 PLUS DIFF. FARE PLEASE CHECK IN AT LEAST THREE HOURS PRIOR TO DEPARTURE. TICKET IS NON-CHANGABLE THANKS FOR GIVING US THE OPPORTUNITY TO SERVE YOU WE WISH YOU A SAFE ENJOYABLE TRIP reservation office AFRA TRAVEL INC. #206 - 6120A YONGE STREET TORONTO ON M2M 3W7 CANADA Telz416 642-2372 Legal Information For customer support, please contact your travel agency. Thank you for choosing 2016?05-25