APPLICATION UNDER THE HAGUE CONVENTION ON THE CIVIL ASPECTS OF INTERNATIONAL CHILD ABDUCTION



From:
Jean Marc Louis
P.O. Box 110388
Kampala GPO
Kampala
UGANDA

Phone: +256706271008
E-mail: louis@rcdsociety.com


Date: 28 November 2023

To: WHOMEVER IT CONCERNS

Subject: REQUESTING THE CENTRAL AUTHORITY OF YOUR COUNTRY BY THIS
APPLICATION UNDER THE HAGUE CONVENTION ON THE CIVIL ASPECTS OF
INTERNATIONAL CHILD ABDUCTION

This is an application for the RETURN OF my child Dewi Lestari Louis
born 19th May 2018, who will attain 16th year on May 19, 2034.

I, Jean Marc Louis, am writing to submit an application under the
provisions of the Hague Convention on the Civil Aspects of
International Child Abduction on behalf of my child, Dewi Lestari
Louis.


CHILD'S INFORMATION:
--------------------

- First names: Dewi Lestari
- Family name: Louis
- Full Name: Dewi Lestari Louis
- Date of Birth: 28 May 2018
- Place of Birth: Kampala, Uganda
- Nationality: Ugandan

- Habitual residence before removal or retention: Kyebando Central,
  Kisalosalo road, close to El-Shaddai Kindergarten, Kampala, Uganda

- It is not known to me that Dewi Lestari Louis has passport

- She is as of today 5 years 6 months 9 days old girl, from European
  father and Ugandan mother, thus having longer curly hair, more
  straight than majority of Ugandan children, gentle, timid child;


IDENTITY OF MOTHER, WHO IS ACCUSED TO WRONGFULLY REMOVE CHILD:
--------------------------------------------------------------

- First names: Aling
- Family name: Margret
- Full name: Aling Margret
- Date of birth: 6 January 1991
- Place of birth: Kitgum, Uganda
- Nationality: Ugandan
- Habitual residence: previously known to be at Kyebando Central, Kampala, Uganda
- Occupation: mother
- Passport number: B1073302 issued on 4 November 2013, expires on 4 November 2023


IDENTITY OF FATHER, WHO IS APPLICANT:
-------------------------------------

- First names: Jean Marc
- Family name: Louis
- Full name: Jean Marc Louis
- Date of birth: 26 May 1973
- Place of birth: Banja Luka, Bosnia and Herzegovina
- Nationality: Bosnia and Herzegovina
- Habitual residence: Kyebando Central, Kampala, Uganda
- Occupation: Business Planner

Parents were living together from 2020 to 2023 despite being separated
2020 for reasons that mother refused to marry, parents were never
married.

Children Act of Uganda, Chapter 59, Legislation as at 2 June 2016,
provides parental rights to access to child and children rights to
live with parent, and for protection of children from exploitation,
child trafficking, and any other form of physical or emotional abuse.


CIRCUMSTANCES OF THE WRONGFUL REMOVAL OR RETENTION
--------------------------------------------------

Mother has wrongfully removed and retained the child Dewi Lestari
Louis. Aling Margret attempted to kill father begin of August 2023,
and shortly thereafter she abducted our child Dewi Lestari Louis, to
unknown direction. Additionally, child was abruptly taken away from
attending preschool El-Shaddai in Kyebando. No custody was given to
mother, both parents have the rights and responsibility to child.

Assault, domestic violence case was filed with police at Kira Road,
SD. REF. 93/03/07/2023, in Kampala, Uganda.

Because similar case of attempted killing was filed in 2022, and later
canceled by father, mother was aware that police would not be
arresting her, mother kept threatening to father to kill him and harm
him and his other 2 children in Uganda as to prevent reporting and
following up with the police case, and that is suspected reason to
remove and retain child, as she used the child to prevent the police
case being followed up.

DATE OF WRONGFUL REMOVAL OR RETENTION: End of June 2023, probably 30
June 2023.

PLACE OF WRONGFUL REMOVAL OR RETENTION: Kisalosalo road, close to
El-Shaddai kindergarten, Kyebando Central, Kampala, Uganda


FACTUAL AND LEGAL JUSTIFICATION FOR THE REQUEST
-----------------------------------------------

1. Involvement of the Mother in Police Cases:

   The mother, Aling Margret, has been involved in police cases and is
   currently on the run from authorities. This demonstrates a
   potential risk to the safety and well-being of our child. It is
   essential to prioritize the child's rights to a peaceful life,
   education, access to both parents, and siblings. The abduction was
   carried out to use the child for mother to avoid being detained by
   police, as on numerous occasions previously, mother claimed to want
   to run away and to abandon the daughter.

2. Rights of the Child and Parental Access:

   Under the Children Act of Uganda, Chapter 59, it is recognized that
   children have the right to live with their parents and parents have
   the right to access their children. By wrongfully removing the
   child from the habitual residence, the mother has violated the
   child's rights to live with both parents and denied the
   non-custodial parent's right to access the child.

3. Protection of Children from Exploitation and Abuse:

   The Children Act of Uganda also emphasizes the protection of
   children from exploitation, child trafficking, and any form of
   physical or emotional abuse. The abduction was carried out to due
   to the mother's involvement in police cases and her current status
   as a fugitive.

By requesting the assistance and intervention of the Central
Authority, we aim to ensure the prompt return of Dewi Lestari Louis to
her habitual residence and provide a safe and stable environment for
her well-being, education, and access to both parents and siblings.


PLACE WHERE CHILD IS THOUGHT TO BE:
-----------------------------------

By recent information from friend of Aling Margret and Dewi Lestari
Louis, mobile money agent from Kisalosalo, Kyebando, Getrude Mudondo,
+256700636020, mother Aling Margret has reported to her to be in
Nairobi, Kenya, that she called Getrude from the number: +254732843010
and that Getrude Mudondo also spoke to Dewi Lestari Louis, which means
that Dewi could be in Kenya.

Other place and person suspected to know where is child, is brother of
Aling Margret:

Bashir Umar, +256701035257, +256762934672

I know his place of work in Kampala, Uganda.

Child could be also taken to Kenya for reason to apply for visa to
other country, as boyfriend of Aling Margret could be, according to
information I have obtained in the area of Rhein in Germany
(Rheingebiet). However, Aling send indirectly deceptful information.

Child could be also taken to Canada, as other information tells me
that she wanted to go to Tanzania or Kenya to apply for visa to
Canada.


OTHER PERSONS WHO MIGHT BE ABLE TO SUPPLY ADDITIONAL INFORMATION
RELATING TO WHEREABOUTS OF THE CHILD ARE:
----------------------------------------------------------------

- mobile money agent of Aling Margret: Prossy Nakachwa, +256708692908,
  as Aling requested money from me to be sent to her directly, so that
  she can pick it up in cash; she is in Nateete, Kampala;

- friend of Aling Margret: Betty Arinaitwe, +256702989637, since Aling
  left from house, Betty started harassing my other 2 children, myself
  and my fiancee; and in case from 2022, she was guarantor for Aling
  Margret on the police bond;

- Friend of Aling Margret: Frances, +256756136790, who in year 2022
  was retaining my daughter Dewi Lestari Louis illegally in her home;

- friend of Aling Margret: Brenda, who lives and work together with
  Betty Arinaitwe;

- Brother of Aling Margret: Brian Soodo, +256703033128, +256785436465

- Sister of Aling Margret: Atim Scovia Kilama, +256790749545,
  +256779571133, +256752727959
  
- Mother of Aling Margret: Betty Acan, +256752727959, +256786995305

- Brother of Aling Margret: Peter Kassim, +256702579998

- Brother of Aling Margret: Abang Emmanuel, +256752222860,
  +256774612633, +256752222806


WHERE TO RETURN THE CHILD:
--------------------------

Child shall be returned to her previous habitual residence at
Kisalosalo Road, close to El-Shaddai Kindergarten, Kyebando Central,
Kampala, Uganda.


SUPPORTING DOCUMENTATION:
-------------------------

- Birth certificate of Dewi Lestari Louis
- Police case Kira Road, SD. REF. 93/03/07/2023, in Kampala, Uganda


Date: 28 November 2012
Place: Kampala, Uganda



__/jl/_______________________________
Signed (electronically) by Jean Louis, father of Dewi Lestari Louis