Salah Documents

Response [1] – I formally acknowledged service on 19 November 2024. The Acknowledgment of Service Identifies my name, Records that I am acting as a litigant in person, that “I intends to defend all of this claim and Carries Court event reference EVN-9379351124-3129.

Evidence Relied On – Acknowledgment of Service_253627.pdf

Acknowledgment of Service_253627

Response to Para 2 and  3 are noted only as statements of the materials on which the Claimants say they rely. The  existence of an exhibit, extract or earlier bundle is not an admission by the First Defendant of  its truth, completeness or the Claimants’ interpretation of it. The First Defendant requires the  Claimants to prove every disputed factual proposition drawn from those materials.

Response to Para 2 and  3 are noted only as statements of the materials on which the Claimants say they rely. The  existence of an exhibit, extract or earlier bundle is not an admission by the First Defendant of  its truth, completeness or the Claimants’ interpretation of it. The First Defendant requires the  Claimants to prove every disputed factual proposition drawn from those materials.

Res 1 – The First Defendant formally acknowledged service on 19 November 2024. The Acknowledgment of Service:

• Identifies Salah Masri as the Defendant.
• Records that he was acting as a litigant in person.
• States: “The Defendant intends to defend all of this claim.”
• Bears his name and signature.
• Carries Court event reference EVN-9379351124-3129.

Evidence Relied On – Acknowledgment of Service_253627.pdf

Acknowledgment of Service_253627

Response [1] – I deny any suggestion in paragraphs 4–8 that I ignored the Claimants or engaged only after the Dubai judgment. The Claimants’ own correspondence shows that their Pre-Action Notice was sent on 15 July 2024 and that I provided a substantive response on 17 July 2024, copying their legal representatives.

I referred to my earlier unanswered correspondence and legal notice, confirmed that the Dubai proceedings had already commenced, identified the hearing fixed for 22 July 2024 and supplied supporting documents. This was before both the DIFC Claim Form dated 23 September 2024 and the Dubai jurisdiction judgment dated 11 November 2024..

Evidence Relied On – Pre Action Emails with the Claimants’ legal attorney

Pre Action Notice emails

Response – SCT-352-2024 was a narrow employment claim arising because, after my resignation and the sale of the business, my expired employment visa had not been cancelled and my name remained associated with the Company’s licence.

Although my original claim included AED 30,000 in employment dues, I withdrew all monetary claims at the hearing and pursued only cancellation of my visa. The Claimants attempted to resist cancellation by raising DEWS penalties, the Share Purchase Agreement, alleged breaches of duty and CFI-066-2024.

H.E. Justice Nassir Al Nasser expressly found that the DEWS penalties and the SPA dispute were separate matters from the employment and visa-cancellation issue. The Court found that my employment had ended by resignation and ordered Hair Creators Salon Ltd to cancel my employment visa.

Accordingly, SCT-352-2024 did not determine any allegation of fraud, concealment, breach of the SPA or breach of directors’ duties. Nor did filing an employment claim amount to accepting that the SCT had jurisdiction over the separate share-sale dispute. The judgment determined only the employment-visa issue, in my favour.

Response – As per the Governing Law and Jurisdiction Clause of the Agreement, ” This Agreement shall be governed by and construed in accordance with the laws of the United Arab Emirates.” The First Defendant initiated a Contract Enforcement Case against the First Claimant following her refusal to honor her contractual obligations and make payments arose from the liabilities of the Second Claimant.

Response [1] – As per the Governing Law and Jurisdiction Clause of the Agreement, ” This Agreement shall be governed by and construed in accordance with the laws of the United Arab Emirates.” The First Defendant initiated a Contract Enforcement Case against the First Claimant following her refusal to honor her contractual obligations and make payments arose from the liabilities of the Second Claimant.

The Dubai Court’s jurisdictional decision did not determine the merits of the present allegations. It is denied that the timing of the First Defendant’s correspondence or commencement of other proceedings gives rise to any inference of  concealment, fraud or bad faith

Response [1] – Third Defendant acknowledged the claim form on 21 Nov 2024.

Response [2] – I sold my shares in the Second Claimant on 14 Feb and 20 March 2024 while the Third Defendant entered into Share Transfer Agreement buying the shares of the Second Defendant on 5 July 2024. at minimum a gap of 4 month in between, I am not identified as purchaser or shareholder in any document. the Commercial License of the Second Defendant identifies me only later, in October 2024, as an authorised signatory, while my employment contract records my employment from 14 November 2024 as a hairdresser. Those later positions do not establish that I founded, acquired or owned the company.

Response [3] – The Claimants did not prove and are still required to prove that the Third Defendant collected any client’s data, this is denied because no material evidence whatsoever.

Response [1] – No Cause of action pleaded.

Response [1] – The historical share transfers recorded between the First and Third Defendants pre date the transaction in dispute. They were lawful corporate acts and caused no pleaded loss to  the Claimants. Any allegation that a particular transfer was unlawful, fraudulent or caused  damage is denied and must be proved by identifying the legal wrong, the affected property or  right, causation and loss. no pleaded loss caused by the historical shareholdings.

Response [1] – The Claimants are required to identify a specific duty to disclose family arrangements matter, the sale in dispute and the relative contract between the parties did not obligate either First or Third Defendants to disclose private details. It is denied that I was under a contractual duty to disclose my personal relationship, that my marriage altered the assets, liabilities or terms of the business sold, or that any alleged non disclosure of my marriage caused loss.

Response [1] – The Claimants herein are the party who filed unsigned employment contract of the Third Defendant in SCT-400-2024 on 15 Oct 2024 as ANNEXURE A The allegations are denied as they suggest that the Third Defendant’s employment was concealed, that her remuneration was improper, or that withdrawing her salary claim amounted to an admission of wrongdoing.

First, the Order with reasons in SCT-400-2024 records that the Third Defendant and the Second Claimant entered into an employment agreement on 22 September 2021. Her employment was therefore a documented relationship, not a concealed arrangement.

Secondly, EX-CL-08 the Claimants’ own bank exhibit records 38 transfers expressly described as salary payments to Julia/Iuliia Valiullina between 6 February 2023 and 30 May 2024, totalling AED 160,100. These repeated salary descriptions are consistent with her employment. Her employment contract provided for a monthly salary of AED 10,000 and a 40% commission on hair-extension sales. The separate commission payment should therefore not be mischaracterised as an unexplained or improper transfer.

The assertions that the First Claimant was unaware of the Third Defendant’s employment is unsupported when the Claimants’ own banking evidence records repeated salary payments in her name. At minimum, EX-CL-08 contradicts any inference that the payments had no identifiable employment basis.

Thirdly, the Third Defendant submitted her resignation on 13 June 2024, stating an effective termination date of 28 June 2024. The SCT judge found that the employment relationship had ended by resignation and ordered the Second Claimant to cancel her employment visa under Article 57(3) of the DIFC Employment Law.

The Third Defendant withdrew her AED 30,000 monetary claim at the SCT hearing and proceeded only with the visa-cancellation relief. The order does not state that she withdrew because the Claimants proved misconduct, nor does it record any admission of fraud, conspiracy, competition or improper receipt of company funds. No determination was made against her concerning the withdrawn salary claim.

The judge also found that the DEWS notices relied upon by the Second Claimant did not refer to any system block preventing cancellation of the visa. The responsibility to cancel the visa remained with the employer after termination. Any separate dispute concerning the SPA or responsibility for the DEWS penalties was expressly left to be determined in CFI-066-2024.

Accordingly, SCT-400-2024 does not support the Claimants’ allegations of fraud or misconduct. It confirms a documented employment relationship, resignation, termination of employment and the Second Claimant’s obligation to cancel the Third Defendant’s visa.

Response [1] – The Claimants are to specifically detail the alleged fraud made by the Third Defendant including actions, spoken words, and provide material evidence as what exactly she had done that amount to Fraud, nothing in her employment contract is breached or her lawful purchase of shares in the second defendant amount to fraud. Under RDC 17.43, an allegation of fraud or dishonesty must be supported by full and specific particulars.

The pleading must identify the precise representation, omission or act relied upon; when, where and how it occurred; what made it false; the Defendant’s alleged knowledge or recklessness; the primary facts supporting that inference; the intention to induce; actual reliance; and causally connected loss.

Where concealment is alleged, the specific legal or contractual duty to disclose must also be identified. the blanket assertion of fraud in paragraphs 10 to 14 fail specify any breached contract or duty or agreement. Third Defendant did not start Space X enterprise with of the Claimants money, it a small size hair salon.

Response [1] – The Claimants allegation is untrue, the sale and purchase in dispute was during Feb and March 2024 while the Third Defendant entered in to contract with the previous share holder of the the Second Defendant on 5 July 2024, following the resignation of the First Defendant on Jun 2024, then the Third Defendant resignation on 13 June 2024, effective 28 June 2024.

Response [1] – The assertions about the grove salon media inactivity are irrelevant and do not prove the alleged fraud and denied, the First Defendant is not in charge of the that media maintenance. the assertions about the hair by salah media are denied as no cause of action is identified there in and the claimants are required to prove these allegations with material evidance

Response [1] – The assertions about the grove salon name is similar are inaccurate, the name is different.

Response [2] – The Claimants are required to prove any company phone number was taken.

Response [1] – The Claimants are required to prove any allegation of spying.

Response [1] – The Claimants did present the employees confirmation.

Response [1] – The Third Defendant resignation date was 13 June 2024, this is true, until September the Claimants herein refused to cancel her visa Claiming that they had no access to Difc Portal despite their admission in Paragraph 11 that they had access in July 2024.

Response [2] – The First Defendant submitted the visa claim on 6 Aug 2025, exactly 5 month since 20 March 2024 the Date of the Share Transfer Agreement was executed, the Claimants did not particularise the damage caused.

Response [1] – The Claimants herein are presenting their own personal opinion about the judgment.

Response [1] – there was a formal Lease Transfer not a sale and purchase contract.

Response [1] – The assertions that the Second Claimant is paying for the lease on Retail Unit 130 is not true, the Claimants are required to prove this assertions, official correspondence with DIFC Retail Leasing Management dated 14 January 2022, Regarding SR-24431 definitively establishes that rental cheque copies, dated 15 September 2021 till 15 June 2023, were drawn on Ms Rojin’s personal account and made payable directly to DIFC Investments Ltd. the Claimant are required to prove this allegation.

Response [1] – The assertions that the Second Claimant paid fitting and decoration cost of the Retail Unit 130 are wrong, the full Cost was paid by Ms Roshain the sole share holder of the Fourth Defendant to Falcon Decorations LLC by way of Cheques from her personal account.

Response [2] – The Notice to pay dated 9 Aug 2025 that the Claimants rely on is addressed to Retail Units 133, 135 and 137 only as clearly stated on the schedule that the total amount of 81,200 is divided over these 3 units exclusively. the First Defendant respectfully request the Court to validate the details of this Notice of Fine with DIFC Investment as the document may have been altered. and further require the Claimants to provide a proof the payment if any.

Response [1] – The Claimants had these account statements from 17 April 2024 the day the Authority approved the new shareholder as further evidenced in the there filing on the 3ed of Sep 2024 of their supporting documents in the SCT-352-2024 a document titled personal loan taken under corporate account .

Response [1] – The purported admission is denied, a gift for the wife does not prove any cost paid by the Second Claimant, the Claimants are required to prove any historical payments allegedly made by the company and any damage such payments has caused.

Response [1] – The purported false representations are denied. Response [2] – the removal of assets is denied.

Admission relied upon.

Response [1] – the First Defendant never had a partner in the Second Claimant. Claimants are required to prove this assertion.

[ADM] This Admission is incomplete, the real state Agent or the Claimants never referred or mentioned why the substantial price reduction was made, in particular it was as equivalent amount to the extent 1 million Dirham Company Financing loan and under the false promise made Mr. Cici that his principale will pay the monthly installments of the Loan.

Response [1] – the Claimants filed there Supporting Exhibit EXCL22 and in that statement of bank account these is record of 100,000 Dirham cash deposited into the Second Claimant ADIB account on 14 Feb 2024. but there is no term mondationg ths payment to be deposited exclusively into the company account.

Response [1] – Denied. The MOU expressly identifies the Second Claimant as the Seller and the First Claimant as the Buyer. It was drafted by Premium International, the First Claimant’s own agent. The First Defendant designated as owner of the company in reference to its shareholding not its land or premises, receipt of deposit do not prove a drafting mistake or alter the written parties. The AED 100,000 was a deposit toward the transaction, and no contractual term required it to be paid into the Second Claimant’s operating account.

Response [1] – The Salon rent payment for April 2024 was pre-paid  in advance by the First Defendant on 1 March 2024 via ADIB cheque no. 500158 for AED  110,458.00, cleared from ADIB account ending with 8723, beneficiary DIFC Investments LTD, for the  period of March and April 2024. Ms. Marsella paid AED 50,000 in cash, as reimbursement to cover the rent for the month of April when the salon was handed over.

Response [1] – The First Defendant initial request sent to the DIFC Authority for adding the First Claimant was on 19 March 2026 and before the execution of the STA with her Agent in Copy followed by the instructions of the Authority on the requirements for the registration of which is fully documented by the First Defendant.

Response [2] – it is denied that The First Defendant neglected seeking approval or that he failed to register her shares, it is after all subject to the Authority approvals and indeed the registration process is not an option that the First Defendant can enforce without these mandatory approvals .

Response [1] – The 50% Payment was a request made by the First Claimant on 20 March 2024 via her real estate Agent Premium International, this request is documented by the First Defendant and The AED 750,000 was the contractually agreed first instalment for 50% of the shares. Accepting it was performance of the Share Transfer Agreement, not deception. therefore it is denied that the First Defendant intended to mislead the Claimant by dividing payments as alleged.

Response [2] – the temporary partnership defined on the Share transfer agreement is contractually drafted with specific terms apply within the specified period to protect the interests of both parties rather than it is an actual partnership that the First Defendant thought to be committed to. I did not fail to begin the DIFC process. After receiving the First Claimant’s required documents, I submitted them to DIFC on 26 March 2024, with the First Claimant and her representative copied.

Response [1] – The First Claimant had beneficial control over the Company as the documented physical and actual handover of Salon was on 1 April 2024, this is requested, agreed and handled by the First Claimant’s representative Ms. Marsela.

Response [2] – The AED 750,000 was purchase consideration for the shares, not income belonging to the Second Claimant. Clause 1, Stage 1 of the STA expressly permitted payment either by bank transfer or in cash directly to myself as the then company manager. No contractual term required the share-sale proceeds to be deposited into the Second Claimant’s bank account or used for its benefit. the Claimants are required to identify the contract provision they rely on for this assertion.

Response [3] – The transition period terms and conditions at the 4th page term 2 is that the then Company Manager to remain with full management rights until the full purchase consideration of 1.5 million is paid in full. therefore this was a negotiated transitional term concerning the gradual payments of the sale price.

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Response [1] – The First Claimant was personally liable to pay the rent of the premises pursuant to Term #1 of the transitional period as it clearly stated thereon that the responsibility of paying the rent is on hers, the April 2024 Salon rent was prepaid on 1 of March 2025 by way of Company Cheque no. 500158 for value of AED 110,458.00, cleared from Second Claimant ADIB account ending with 8723, beneficiary DIFC Investments LTD, for the period of March and April 2024. The separate AED 50,000 payment was partial reimbursement for April rent.

Response [2] – The assertion that payment is personal is denied. Response [3] – The assertion that the Claimant is entitled to recover that amount is denied. Response [4] – the assertion that the payment was a misappropriation of funds is denied.

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Response [1] – The First Claimant was personally liable to pay the rent of the premises pursuant to Term #1 of the transitional period as it clearly stated thereon that the responsibility of paying the rent is on hers, the April 2024 Salon rent was prepaid on 1 of March 2025 by way of Company Cheque no. 500158 for value of AED 110,458.00, cleared from Second Claimant ADIB account ending with 8723, beneficiary DIFC Investments LTD, for the period of March and April 2024. The separate AED 50,000 payment was partial reimbursement for April rent.

Response [2] – The assertion that payment is personal is denied. Response [3] – The assertion that the Claimant is entitled to recover that amount is denied. Response [4] – the assertion that the payment was a misappropriation of funds is denied.

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Response [1] – I deny that the Failure is already established, Response [2] – I deny that I held Shares by Trust. and the reason is that the documented DIFC register of companies preliminary Approval was issued and received on 17 April 2024 falling exactly within the Probationary Period.

Response [3] – The First Claimant was bound by the contract transitional terms.

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Response [1] – I deny that the alleged breach as already established, I am not holding power to make the Claimant a legal. Response [2] – I deny that the April rent reimbursement was unlawful.

Response [3] – I deny the alleged damage had been and the claimants are required the particulars of such damage if any.

Response [1] – I deny that the alleged breach as already established, I am not holding power to make the Claimant a legal of the company before the Authority Approval. Response [2] – I deny that the April rent reimbursement was unlawful.

Response [3] – I deny the alleged no access to the DIFC Client Portal as the registered Emirates Id Cards of the Claimants’ employees in May 2024 has followed their Employment Visa issuance under the Second Claimant sponsorship which is a process done by formal submissions on the DIFC Client Portal precisely in March and May 2024 proving that the Claimants had access to the same at the relevant time.

Response [1] – I deny that the alleged no attempt alleged, the First Documented formal request to add shareholder was indeed submitted on 19 March 2024 with the Claimants real estate Agent fully informed about it resulting in the ROC approval on 17 April 2024, any latter delay in the formal share transfer was due to the further approvals required by the Authority and such matter is beyond my power, any opposing statement may the Claimants have is required to proved by verifiable documents.

Response [1] – Registration of the First Claimant as Shareholder

1. On 19 March 2024, my employee, Abeer Kurdi, contacted DIFC Mall Management, copying me, to request the procedure and documents required to add a shareholder.
2. On 20 March 2024, DIFC explained that the proposed change required:
   • Clearance of the company’s outstanding payments;
   • The reason for the change;
   • The proposed shareholder’s name, percentage and biography;
   • Six months of the proposed shareholder’s bank statements; and
   • DIFC Committee approval, followed by the formal process through the DIFC Client Portal and final ROC review.
3. I forwarded those requirements for the necessary documents and also requested a meeting with DIFC concerning the proposed new business partner.
4. On 26 March 2024, I submitted the proposed shareholder’s documents and requested approval to add the First Claimant initially as a 50% shareholder.
5. DIFC then requested confirmation that the company had cleared its outstanding payments. I clarified the requirement and supplied the company’s clearance confirmation on 27 March 2024.
6. I repeatedly followed up with DIFC on 29 March, 5 April and 15 April 2024 while the request was awaiting Committee consideration.
7. On 17 April 2024, DIFC Retail Leasing confirmed that the request had been approved by the DIFC Committee and instructed me to liaise with the Registrar of Companies Helpdesk to make the necessary corporate changes.
8. On 1 May 2024, I informed the ROC that the intended transfer had changed from 50% to 100% of the shares. I expressly confirmed that I had no objection to the full transfer and attached the transfer document, acceptance document and the First Claimant’s passport.
9. On 2 May 2024, the ROC instructed that the formal transfer request had to be submitted through the DIFC Client Portal using the “Update Company Shares” service and the “Transfer” option.

The First Claimant and Marsela Kollcaku were copied into the material correspondence. The emails therefore show that I openly initiated, pursued and obtained the necessary preliminary approval for the transfer; I did not conceal, obstruct or refuse the process.

Important distinction: The DIFC Committee’s approval on 17 April 2024 was preliminary approval, not the final legal registration of the shares. The correspondence ends with the ROC’s Client Portal instructions on 2 May 2024. The subsequent portal record, amended share register, share certificate or licence is required to prove the exact date on which the First Claimant became the legally registered shareholder.

Response [1] – I allegation herein is unclear, such Resolution was as standard company instrument to comply with the company’s Articles of Association. which itself require director approval, surrender of the existing share certificate. it was accepted by the ROC and caused no damage to the Claimants .

Response [1] – the allegation herein are denied, unspecified and do not identify a particular breach, the Claimant had received the entire the salon on 1set of April, the April income was managed by the First Claimant, likewise the April expenses were paid via the Company accounts, the DIFCA Approval was gained and the transition process resulted in completed share transfer, the Claimants are required to clarify the alleged Breach.

Response [2] – there is no contract term, agreement or any material evidence that the Sale consideration was mandated to be deposited into the Company account and used by the Company, the Claimants are required to prove such agreemnt.

Response [1] – the agreement doe not necacciate the DIFC Portal submission to be done by the First Defendant, the Former employee Ms Abier, submitted the Portal request on the mid May 2024 right after the First Claimant’s passport was attested by the Authority, a step than can not be skipped before the Portal Submission. the Claimants could have produced the portal submissions if allegations were true.

Response [1] – the continued sole control of the company is denied, every matter related to the operations and every decision in relation to the salon financial management during the transitional phase was negotiated with Marsela, this is documented by WhatsApp correspondence where as she made decisions suitable for them and I facilitated these decisions by the Manager or Authorised Signatory capacity on their behalf.

Response [2] – it is denied, that any liabilities were concealed, the bank accounts were fully accessed on 17 of April by the person nominated by Marsela and designated as Salon Manager Ms Rexhina Mema, the DIFC Portal was as well browsed and viewed by her during the transitional phase in order to review matters related to the employees.

Response [3] – the broad assertions of stolen assets without specifying the allegedly stolen items is denied, the Court is invited to order that the CCTV footage of the Gate Avenue mall be brought and reviewed if necessary, I have nothing to hide, the only Items removed are the listed personal items for removal in Subparagraph E on the Second Page of the STA and these are Cameras or photography lights and computers. the Claimants are required to prove their position regarding “theft assets”.

Response [1] – .

Response [1] – the Company Trade License is not a transferable right like Company shares, the change of the registered manager on the Trade License is a formal request to be submitted on the DIFC Portal and it requires no permission, approval or any other form of acceptance by myself. that request for a manager change can not proceed the ROC’s registration of the First Claimant as the new shareholder of the Company, therefore the First Claimant following the amendment of the Share Certificate held the required authority to replace the name of the Authorized Signatory on the Trade License with no further needed from myself to do that.

Response [2] – the Term 2 on the STA obligated me to transfer the company management as in general to the First Claimant but that term does not obligate me to change the registered Authorised Signatory on the trade license on behalf of the First Claimant, especially that following the formal submission of the Board Resolution on 1 May I had no more Authority to initiate any company related formal requests.

Response [3] – the access to the Second Claimant’s DIFC Portal was handed over during April as the VISA Permit approvals issued between end of April and early May 2024 are indeed submitted for the DIFC Authority via the Portal said to be inaccessible, the Super User Portal Admin Account was registered under Accountant@haircreators.net, it was originally operated by the former accountant, Shady Zaiat, who transferred access during the handover to the First Claimant’s appointed accountant, Lolita Tines, and manager, Rexhina Mema. DIFC confirmed on 25 June 2024 that Shady’s personal email access had been deactivated following a request submitted by the company’s Super User. This demonstrates that the Claimants’ management team was exercising portal administration before the licence update on 27 June 2024. Lolita’s subsequent use of Accountant@haircreators.net to retrieve and forward the historical DIFC notices further contradicts the allegation that the Claimants never had access to that account.

Response [4] – it is denied that the First Claimant never had access to that account.

Response [1] – it is denied that I hid any fines, when I received the Notice of Fine on 15 April 2024, I instructed the former assistant manager Ms Abeir to submit and objection and full the enrollment requirements, it is important to draw a clear understanding of the reasons of the fine notice, it that the DIFC required the Second Claimant to enroll in the DEWS and was not about any amount unpaid, SR 206759 was therefore submitted via the Portal by Ms Abier with new salon Manager clearly informed to follow up and that the new accountant to prepare and the submit the employees related documentation in order to avoid the fine, the resignation notice of Ms Aber and Ms Shadi was over by end of may, both left the company relying on the Claimants appointed employees to carry on the necessary remaining part of the process, the DIFC email on 27 May 2024 clearly indicated the SR raised and mentioned herein and extended the compliance deadline until 16 June 2024, which is the Claimants’ responsibility to deliver.

Response [2] – it is denied that any legal notices were sent by DIFC Authority to the Second Claimant or to me at any point of time, the Notice of fine is a notice to pay a potential fine it is not legal notice.

Response [1] – .

Response [1] – it is denied that I kept any spare keys with me, DIFC facilities are highly secured with CCTV camera in every corner in security guards standing in everywhere there is no way any person can access any facility without permission.

Response [1] – in order for any audit report to be accurate it requires the original receipts, statements of accounts, invoices, supplier accounts, payments receipts and many other material financial and operational records to be available, therefore this allegation inconsistent with the allegations that the I no access to digital assets was granted nor was there any handover of company related accounting and managerial records.

Response [1] – in order for any audit report to be accurate it requires the original receipts, statements of accounts, invoices, supplier accounts, payments receipts and many other material financial and operational records to be available, therefore this allegation inconsistent with the allegations that the I no access to digital assets was granted nor was there any handover of company related accounting and managerial records.

Response [2] – I do not recognize these terms to honest.

Response [1] – the reference on the STA dated 20 March 2024 is reference to the rental pay cheques issued from ADIB Account, it is not a reference to a single account itself with the intention of hiding another account, I rely of the 2ed April documented disclosure of all other bank accounts including bank name and individual account numbers. therefore I deny the reference on the STA to constitute an intentional conduct to conceal anything.

Response [2] – the Claimants produced and relied on their WhatsApp correspondence between myself and their identified representative Ms Marsela, she was tasked to handle all matters of handover during the Due Diligence therefore the details related to the comapny banking I provided to her on early April undermines the Claimants allegations that banking details were withheld.

Response [1] – it is denied that I had met the First Claimant at any date prior to 26 March 2024, I deny obstructing her from performing any investigations on the company documents before the two contracts are already executed on 26 March, I further submit that I was transparent with my obligations to disclose any matter before and after the contracts execution.

I require the Claimants to prove and or specify any act, omission, or conduct that I allegedly made, including date, words, person and or material that amount to deliberate obstruction.

Response [2] – it is denied that the loan is secured or guaranteed by the Second Claimant, the Loan is guaranteed by a personal cheque signed by myself.

Response [1] – it is denied that I failed to disclose the loan agreement, I rely on the very first contract executed, its Clause no. 5 and No. 7 both refers to the informations provided thereof, these referred to informations are the financial disclosure of the bank statements, audit reports and copy of the loan agreement, these were the materials relied on for drafting the contract, I rely on the price reduction admitted by the claimant in the equivalent amount to the loan of 1 million, which is exactly why the Claimants declared or contractually assumed all liabilities and obligations. the Claimants do not allege any altered or fake documents provided, they only ommit to admit the pre-contractul disclosure made to their identified real estate Agent.

Response [1] – it is denied that the banking access provided during the transitional phase was limited, the First Claimant being a self litigant filed a supporting document to the DIFC SCT Court on 3 Sep 2024 before the present proceedings was even registered, this document evidences that the First Claimant logged into the Rak Bank account and managed to screenshot the full details of the company loan including its terms, repayments proving that the login username and password were provided to her appointed employees during the transitional phase. Furthermore, the Claimants’ own appointed Accountant and Manager names are showing in the bank transactions statements, their additions of new beneficiaries, transactions for suppliers, payments made to the DIFC Investments establish a full unrestricted access was granted.

Response [2] – the First Claimant did not clarify how they managed to provide many screenshots and generate an online bank statements while not being the Authorised Signatory at Rak Bank, it technically impossible for a person to sign in bank account without having the required logging credentials. it is denied that the provided documents papers were limited, a 12 month account statements are not limited.

Response [1] – it is denied that the I failed to disclose leasing history of the company. By 26 Feb 2024, I transparently placed the Claimants’ real estate Agent on direct contact with the DIFC Leasing Management at a time the only payment made by the Claimant was 100K deposit and further on 2 April I introduced the First Claimant as my new business partner to the DIFC Leaning Management senior level officers in person whereas any informations related to company leasing history could then be clarified directly from the Authority.

Response [1] – I require the Claimants to provide at least 1 request for disclosure of such immaterial and personal matter that I refused to answer, there is contractually no duty to disclose such matter, nor was there a true reason for private relationships to be disclosed.

Response [1] – I was formally designated as a manager from before the sale in dispute, I remained as a manager until med May 2024, I request the Claimants to specify the contract term that obligated me to voluntarily prepare and submit informations that I was not asked to provide at first place.

Response [1] – it is denied that the Third Defendant had been obligated by any contract or term of agreement to disclose her private marriage details to any of the Claimants, I require the Claimants to specify the contract term that obligated my wife the Third Defendant to voluntarily prepare and submit informations that she was not asked nor obligated to provide at first place.

Response [1] – it is denied that the Fourth Defendant the transactions were or funds were received incorrectly.

Response [1] – the Claimants failed to explain how the historically transferred shares in 2022 caused the later bank access issues in 2024. Any banking access interrupted by historical and lawfull share transfer is denied, I rely on the documented reminder I sent on the 26 June 2024 for the First Claimant and requested her to perform her necessary KYC updates at the ADIB Bank.

Response [1] – the First Claimant filed several documents including statements of bank account, full loan details, repayments transactions and more in which it is clear the access was unlimited and unrestricted.

Response [2] – the Claimants are invited to explain how their supporting documents shows all the Digital banking details, transactions, balance and payments covering several months while I remain the Authorised Signatory till the date.

Response [1] – the assertion that First Claimant had seen the loan details briefly is denied, Mr Eshja via voice note sent confirmed that he agreed the terms of a partnership that was supposed to happen between myself and the first claimant, that day the Claimants’ appointed representative received a confirmation that the earlier security bank instrument guaranteeing the loan was cancelled, they were asking ms Abier what was the replacement of that Cheque.

Response [2] – I deny that I made any admission that the Loan was personal loan, Response [3] – I sent Mr Esha a copy of the replacement security cheque submitted during the loan Top-Up process which is signed by myself in a personal capacity not personal liability, I clearly mentioned Company Loan in my documented voice note. following that the First Claimant refused making repayments claiming that the loan is personal and been withheld.

Response [1] – it is denied, I made any promise to clear or pay the loan.

Response [1] – security cheque guaranteeing the earlier Loan Agreement No. 20649173 was canceled on 7 May 2024.

Response [2] – I was paying the installments of the loan throwout the transition phase, on 30 May I transferred 29000 to the Second Claimant Rak bank account using the personal account of former accountant therefore the deduction on 1 Jun had followed the deposit, after June the shares transfer process was completed and I pursuant to the contract the claimants are liable for the remaining installments.

Response [1] – any allegations of bad faith attempt is denied, Term# 10 “The First Claimant to be responsible for covering the POS machine fees, online line platforms charges and fees such as the company website, company email hosting fees, the DIFC Portal charges, employees work permit issuing and cancellation’s costs, business bank accounts charges and any other auto or manual payments linked to the company.”.

Response [1] – it is denied that Rak Bank account statements are only now provided, these were provided from 26 March 2025 before the execution of the STA and the Claimants produced and submitted several account statements proving their possession of the same prior to any disclosure with these proceedings.

Response [1] – .

Response [1] – if the Claimants’ statement here is true it establish that they had the required loan documents, interest rate, loan installment date, funds release date and other details are correct except that the loan is personal, it is denied the bank had contacted the First Claimant, despite being shareholder, within the bank records she has no recognizable authority to retrieve any information regarding the Rak Bank Accounts or the Company financing facility while she remained unregistered Authorised signatory without a court order, it is denied that the bank disclosed any information via a phone call to unregistered account administrator.

Response [1] – it is denied that loan agreements are drafted, the material provided to the First Claimant is the Digital form of the financing agreement, Response [2] – I deny stating the draft is similar and I require the Claimants to prove this allegation.

Response [1] – I deny that I was obligated to any further repayments after 17 May 2024 the date that the First Claimant became officially the new shareholder and as per the Foundational Term of the Contract and the term of the STA shw was obligated to repay her company Financing repayments.

Response [2] – I shared the cancellation email with Marsela during may and she was aware that the previous cheque is cancelled.

Response [1] – .

Response [1] – this is misstatement of fact and is denied, I rely on the Claimants’ 24 April 2024 email confirming their agreement about the partnership whereas I stay 10% share holder, this documented. the Claimants denied their knowledge of the company financing loan upon knowing that the security instrument held by the financing bank is enforceable against me not against the company itself.

Response [2] – it is denied that I admitted or acknowledged any failure to disclose, to the contrary, in the email I clearly mentioned the Loan in a company loan and that the Claimants as responsible for its payments from June 2024.

Response [1] – interpretation is denied, I by the exact words said that, sincs the partnership is no longer considered the parties should stick to the terms of the initial STA and its terms as executed by the parties. I require the claimants to prove their allegation to the contrary.

Response [1] – I rely on this admission that the First Claimant had access, I deny changing the username, it is not true the Claimants were unable to access Rak Bank accounts since july, the Claimants appointed accountant made transactions after July and her name is present on these transaction, it is the Claimants changed the password after transfering funds out of the account and shift the company sales back to ADIB account.

Response [1] – the First Claimant managed to have over 443 transactions following the handover, several cash withdrawals, paid salaries, transferred funds between company accounts, made generated several account statements and screen printed all the details about the Company Financing facility, such access was not limited.

Response [2] – the First Claimant failed to mention which accounts were these funds transferred and the dates of these transactions and crutilly failed to clarafy the inward transactions in the other company account, these transactions were withdrawn from Rak Bank and deposited in ADIB bank and used for the benefit of the Company.

Response [1] – The allegation is denied. I do not rely on the divorce certificate as creating a mandatory child-support obligation. My Defence states that the five transfers, totalling AED 80,000, represented salaries owed to me, which I directed to the Fourth Defendant to support my daughter, principally for her schooling expenses. The absence of a prescribed obligation from the divorce certificate does not remove the separate lawful basis for the payments.

My employment contract provided monthly remuneration of AED 40,000, and my Defence states that salary for February and March 2024 remained outstanding. Only AED 20,000 was transferred after the Share Transfer Agreement, followed by an AED 50,000 deposit into the Company’s account the next day. The American School of Creative Science records provide additional corroboration that: I was registered on the school’s parent platform by 17 October 2023, before the challenged transfers.

Raghad Salah Masri was enrolled at the school. The school communicated with both me and her mother, Roushin Basher Haj Ali. I relay on the school email correspondence and the later statement of account records substantial tuition and transport fees. These school records support the genuine and continuing schooling arrangement. However, because the financial statements are from 2026, I would not say that they directly trace the five transfers made in February and March 2024 to particular school invoices.

Response [1] – I accept that the Second Claimant has a separate legal personality under Article 9 of the DIFC Companies Law. I do not claim that my former shareholder or authorised-signatory status gave me personal ownership of the Company’s funds.

However, the allegation is denied because the payments were not the Company discharging a separate personal debt owed by me to my former wife. My case is that the payments represented remuneration already lawfully owed to me, including unpaid salary for February and March 2024, which I directed towards supporting my daughter, principally her schooling expenses.

My employment contract, EXCL33, provided monthly remuneration of AED 40,000. The five transfers totalled AED 80,000. Once remuneration was lawfully due to me, directing its payment to a third party did not, by itself, amount to misuse of Company funds or breach of fiduciary duty.

I do not rely on the divorce certificate as creating the Company’s liability or prescribing child support. The school records corroborate that my daughter was enrolled at the American School of Creative Science from at least October 2023 and that genuine and continuing tuition and transport expenses existed. The account statements received from that school are relied upon only as supportive material to the stated purpose.

The Claimants must still prove that the remuneration was not due, that the payments exceeded my entitlement, that they were made for an improper purpose or unauthorised benefit, and that the Company suffered an identifiable loss. Those matters are not established merely by citing Article 9 or the general duties of a manager or director.

Response [1] – The allegation that these lawfull salary payments amount to misappropriation of company funds is denied. I do not rely on the divorce certificate as creating a mandatory child-support obligation. My Defence states that the five transfers, totalling AED 80,000, represented salaries owed to me, which I directed to the Fourth Defendant to support my daughter, principally for her schooling expenses. The absence of a prescribed obligation from the divorce certificate does not remove the separate lawful basis for the payments.

My employment contract provided monthly remuneration of AED 40,000, and my Defence states that salary for February and March 2024 remained outstanding. Only AED 20,000 was transferred after the Share Transfer Agreement, followed by an AED 50,000 deposit into the Company’s account the next day. The American School of Creative Science records provide additional corroboration that: I was registered on the school’s parent platform by 17 October 2023, before the challenged transfers.

Raghad Salah Masri was enrolled at the school. The school communicated with both me and her mother, Roushin Basher Haj Ali. I relay on the school email correspondence and the later statement of account records substantial tuition and transport fees. These school records support the genuine and continuing schooling arrangement. However, because the financial statements are from 2026, I would not say that they directly trace the five transfers made in February and March 2024 to particular school invoices.

Response [1] – it is denied that the First Claimant herself paid any part of the 80,000 transfers.

Response [2] – it is denied that the First Claimant was entitled by any agreement, contract to have the business Financing funds preserved for her in the company account.

Response [1] – The allegation appears in APOC paragraph 18, “The employees of the Company were not aware of the new ownership of the Company…”.

Response [1] – it is denied that the Claimants paid the alleged fine or submitted evidence for its enforceability.

Response [1] – The Claimants are required to prove that under the ownership of the Third Defendant any company funds were used for personal matter, there is no evidence to such assertion.

Response [2] – The Claimants are required to prove that there representation made directly to the First Claimant at any point of time before she already signed the two contracts by relying on her real estate Agent.

Response [3] – The Claimants are required to prove that she paid any of the company liabilities to Rak Bank or provided a replacement of the security cheque or that was deceived into purchasing the salon and that she was not totally relying on her real estate Agent.

Response [1] – The group company assertion is incorrect, each of these companies has it own trade license and lease agreement. The allegation is denied. It improperly combines two separate matters: the challenged payments and the historical reference to Unit 130.

Response [2] – Unit 130 was not part of the Second Claimant’s leased premises at the relevant time. Although Unit 130 had historically operated under the Second Claimant’s licence, its lease was separately transferred and varied before the disputed sale, and the Fourth Defendant subsequently operated as an independent company with its own registration, trade licence, lease and funding.

Most importantly, the DIFC Investments late-payment notice dated 15 October 2024 was issued specifically concerning the Second Claimant. It identifies the Second Claimant’s lease dated 29 August 2020 and expressly defines its premises as: “Unit 133, 135 and 137, Gate Avenue, DIFC.” Unit 130 is not included. This directly contradicts the assertion that DIFC considered the Second Claimant responsible for all leased units, including Unit 130, at that time. The notice was issued after the handover. I replied on the same day, informed DIFC that I was no longer associated with the Second Claimant, copied the First Claimant and her appointed team, and requested that future correspondence be sent to them.

This is inconsistent with any allegation that I concealed either the new ownership or the Company’s leasing position. A historical reference to Unit 130 in RAKBANK or earlier administrative records does not establish that the Fourth Defendant was a group company, that the Second Claimant owned it, or that the Second Claimant remained responsible for its activities. The Claimants have identified no shareholding, control document, current lease or DIFC determination establishing such a group relationship.

Response [1] – The group company assertion is incorrect, each of these companies has it own trade license and lease agreement. The allegation is denied. It improperly combines two separate matters: the challenged payments and the historical reference to Unit 130.

Unit 130 was not part of the Second Claimant’s leased premises at the relevant time. Although Unit 130 had historically operated under the Second Claimant’s licence, its lease was separately transferred and varied before the disputed sale, and the Fourth Defendant subsequently operated as an independent company with its own registration, trade licence, lease and funding. Most importantly, the DIFC Investments late-payment notice dated 15 October 2024 was issued specifically concerning the Second Claimant. It identifies the Second Claimant’s lease dated 29 August 2020 and expressly defines its premises as: “Unit GA-SZ-G-133, 135 and 137, Gate Avenue, DIFC.” Unit 130 is not included. This directly contradicts the assertion that DIFC considered the Second Claimant responsible for all leased units, including Unit 130, at that time.

The notice was issued after the handover. I replied on the same day, informed DIFC that I was no longer associated with the Second Claimant, copied the First Claimant and her appointed team, and requested that future correspondence be sent to them. This is inconsistent with any allegation that I concealed either the new ownership or the Company’s leasing position.

A historical reference to Unit 130 in RAKBANK or earlier administrative records does not establish that the Fourth Defendant was a group company, that the Second Claimant owned it, or that the Second Claimant remained responsible for its activities. The Claimants have identified no shareholding, control document, current lease or DIFC determination establishing such a group relationship.

Response [1] – The allegation is denied. It assumes, without identifying any particular asset or evidence of ownership, that the Second Claimant owned Unit 130’s equipment, fittings and fixtures.

No deed of transfer exists because the Defendants’ case is that no assets owned by the Second Claimant were transferred to the Fourth Defendant. The lease variation is legally and factually different from a transfer of physical assets.

The contemporaneous evidence shows:

1. On 26 October 2021, DIFC confirmed that the Variation Agreement concerned Unit 130.
2. DIFC subsequently sent the Variation Agreement through DocuSign and requested rent cheques before execution.
3. Eight unique rent cheques were drawn from Ms Roushin Bashar Haj Ali’s personal Emirates Islamic account in favour of DIFC Investments between 15 September 2021 and 15 June 2023. They total AED 588,822. Duplicate copies within the PDF have been counted only once.
4. Personal Cheque No. 000075, dated 9 December 2021, was drawn from Ms Roushin’s account in favour of Falcon Interior Decoration LLC for AED 293,305.85 and bears an acknowledgement dated 10 December 2021. This corroborates personal funding of the principal fit-out.
5. The January 2022 correspondence records Hair Creators’ accountant telling DIFC that Ms Roushin had her own clients and revenue, held and paid the rent cheques and would continue funding her salon.
6. Falcon addressed its fit-out correspondence and quotations directly to Ms Rojin. She was treated as the client and controlled which additional works were approved, rejected or removed. The original additional-works quotation of AED 23,770 was revised to AED 14,270 following her instructions.
7. On 18 April 2022, Hair Creators’ accountant informed DIFC that Unit 130 was no longer under Hair Creators’ name and was under Hair by Rojin. On 20 May 2022, DIFC confirmed that the Variation Agreement bearing the revised name was under execution.

This contemporaneous evidence materially contradicts the suggestion that there was no documentation concerning the lease, funding or fit-out of Unit 130. It supports the Defendants’ case that the rent and fit-out were independently funded and managed for Hair by Rojin.

The Claimants must identify each particular asset allegedly owned by the Second Claimant, produce its purchase invoice and payment evidence, prove its alleged transfer to the Fourth Defendant, establish the legal basis for the alleged trust and prove the value and loss claimed. The mere absence of a deed does not prove ownership, transfer or the existence of a trust.

Response [1] – The wording of Clause 11 is admitted, but it is denied that the Claimants established that the condition was triggered. The MOU was dated 14 February 2024. The Defence’s position is that the one-month period expired on 14 March 2024 and was not indefinitely exercisable. The Claimants have not identified the required level of “satisfactory” turnover, the turnover actually achieved, or when and how they invoked the clause.

The subsequent Share Transfer Agreement dated 20 March 2024 clarified the requirement by setting a turnover benchmark of AED 180,000 within one month. The Company’s income exceeded that amount by 20 April 2024, as recorded in the RAK Bank statements.

The First Claimant also completed due diligence, paid the final purchase-price instalment and proceeded with the share registration. The alleged entitlement to a full refund or restitution of the Company is therefore denied..

Response [1] – The .

Response [2] – The assertion that the turnover failed to meet satisfactory level is denied, the STA was executed on 26 March, its Clause 6 set the minimum agreed amount as 180,000, the Claimants’ own EXCL08 shows that the sales between the 27 of March till 27 April was 208,000 exceeding the minimum level permits the First Claimant to Claim anything.

Response [3] – The allegation of misappropriation is denied, the Claimant failed to prove that.

Response [1] – The .

Response [1] – The assertion that from December 2023 I served as DEWS Authorised Signatory is denied and I require official documents from the DEWS.

Response [1] – it denied that the 15 April notice itself was an already imposed penalty rather it is was a formal Notice of intended fine from DEWS which occurred after the 2 contracts. And sent on 15 April to the registered email address of the Second Claimant to which Ms Rexhina the newly appointed salon Manager had access and I received a copy on my personal email as well, during the relevant time, Ms Abier Al Kourdy was serving her 2 weeks notice after the Handover dated 1 April and indeed responded by rising an objection to DEWS via the DIFC Portal under SR 206759 on the bases that the company did not receive prior direction to enroll its employees before 15 April, further she guided the new Manager on how to follow up with the process, Ms. Shamma from the DEWS team responded on 27 May by referring to the objection raised and encouraged the Second Claimant to complete the enrollment before 15 June 2024 to avoid the said by that time the new salon accountant was already hired and had access to the DIFC Portal as evidenced by her own visa issuance and access to the company email as evidenced by her replies received with the necessary employees salaries informations as evidanced by the timely salaries paid on 30 May 2024 including the salaries of Lolita and the Manager Rexhina as evidenced in bank statement of account.

Response [1] – it denied that the First Claimant was not aware, her appointed Salon Manager received and reviewed the DEWS email dated 15 April, her appointed accountant received the team related account records and the former business manager raised the objection to the DIFC, I instructed the former business manager to coordinate with the former accountant and the new accountant to submit the required documents and enroll the employees during april. by the term 10 of the STA the First Claimant was contractually responsible for the DIFC charges and any other payment linked to the company from 26 March 2024, therefore the non follow up and the absence of timely submission during May and before the 15 June deadline after extended time by the DIFC can not be considered a failure of my own failure.

Response [2] [3] – I deny the assertions intentions to cause harm, and deliberate concealment I am such conduct will only only damage and I no reason to willfully cause damage and latter be sued for it.

Response [1] – I accept that I received the preliminary DEWS notice on 15 April 2024. The same notice was separately delivered by DIFC to the Company’s registered accountant mailbox, accountant@haircreators.net. I did not conceal it. On the same day, I telephoned Abeer Kurdi and instructed her to submit an objection through the DIFC Portal and complete the necessary DEWS enrolment documents with the assistance of the Company’s former accountant, Mr Shadi Zayat. I then immediately forwarded the complete notice and attachment to Abeer. That same-day forwarding is proved by the contemporaneous email.

At that time, Abeer and Shadi were serving their two-week resignation notices. My evidence is that Abeer submitted the objection, demonstrated it to the incoming salon manager, Ms Rexhina, and instructed her to follow up with DIFC. This is independently corroborated in part by DIFC’s email of 27 May 2024, which expressly records an objection raised by Hair Creators Salon Ltd and gives the Company until 15 June 2024 to complete its DEWS enrolment and employee payments.

Shadi subsequently handed the Company’s accounting records to the newly appointed accountant, Ms Lolita Tines. Abeer and Shadi had left by May, and my earlier team had entirely left the Company by approximately mid-May. Responsibility for following up the objection, enrolment and regulatory correspondence therefore passed operationally to the incoming management.

The transition of portal control is also documented. On 25 June 2024, DIFC emailed Shadi at his personal address, shadyzaiat@gmail.com, confirming that his access to the Client Portal for Hair Creators Salon Ltd had been deactivated with effect that day following a request submitted by the entity’s Super User. The email copied Rojin Haj Ali and me. This objectively confirms the removal of the former accountant’s personal portal access. The email does not identify the individual who submitted the Super User request.

The subsequent documents further prove that the incoming management had notice and the means to act. A portal-user update was submitted on 29 June. On 1 July, DIFC requested re-upload of the signed authorisation, and Rojin forwarded that requirement to Abeer, the Company accountant mailbox and Ms Lolita. On 3 July, DIFC confirmed that Ms Lolita had been appointed Super User with extensive Company, employee, financial and other permissions.

The formal USD 19,000 Decision Notice was issued on 10 July—after the former accountant’s access had been removed and after Ms Lolita had become Super User. It was sent to the Company’s registered accountant mailbox and addressed directly to the First Claimant, Klesta Eshja. A reminder was sent on 17 July before the 25 July payment deadline, followed by another reminder on 9 August.

The correspondence shows that the incoming management used a mixture of personal email addresses and the Company’s registered accountant mailbox during the transition. Formal DIFC notices continued to be delivered to the registered Company mailbox, which Ms Lolita later accessed and used. Any failure to coordinate and monitor those accounts, complete the enrolment, replace the DEWS signatory or pay the fine by the deadline cannot properly be characterised as concealment by me or attributed exclusively to me.

I do not deny that a DEWS compliance issue existed. I deny that I concealed it or solely caused the final fine and alleged consequential loss. I promptly disclosed the preliminary notice and instructed the relevant employees to act. The documentary evidence establishes an objection, the removal of the former accountant’s portal access, a transition to the incoming team, Ms Lolita’s subsequent Super User appointment and repeated notices addressed to the Claimants. The Court should therefore distinguish any underlying contribution arrears from the post-handover failure to complete the regulatory process and mitigate the loss.

Response [2] [3] – I deny the assertions intentions to cause harm, and deliberate concealment I am such conduct will only only damage and I no reason to willfully cause damage and latter be sued for it.

Response [1] – I accept that I received the preliminary DEWS notice on 15 April 2024. The same notice was separately delivered by DIFC to the Company’s registered accountant mailbox, accountant@haircreators.net. I did not conceal it. On the same day, I telephoned Abeer Kurdi and instructed her to submit an objection through the DIFC Portal and complete the necessary DEWS enrolment documents with the assistance of the Company’s former accountant, Mr Shadi Zayat. I then immediately forwarded the complete notice and attachment to Abeer. That same-day forwarding is proved by the contemporaneous email.

At that time, Abeer and Shadi were serving their two-week resignation notices. My evidence is that Abeer submitted the objection, demonstrated it to the incoming salon manager, Ms Rexhina, and instructed her to follow up with DIFC. This is independently corroborated in part by DIFC’s email of 27 May 2024, which expressly records an objection raised by Hair Creators Salon Ltd and gives the Company until 15 June 2024 to complete its DEWS enrolment and employee payments.

Shadi subsequently handed the Company’s accounting records to the newly appointed accountant, Ms Lolita Tines. Abeer and Shadi had left by May, and my earlier team had entirely left the Company by approximately mid-May. Responsibility for following up the objection, enrolment and regulatory correspondence therefore passed operationally to the incoming management.

The transition of portal control is also documented. On 25 June 2024, DIFC emailed Shadi at his personal address, shadyzaiat@gmail.com, confirming that his access to the Client Portal for Hair Creators Salon Ltd had been deactivated with effect that day following a request submitted by the entity’s Super User. The email copied Rojin Haj Ali and me. This objectively confirms the removal of the former accountant’s personal portal access. The email does not identify the individual who submitted the Super User request.

The subsequent documents further prove that the incoming management had notice and the means to act. A portal-user update was submitted on 29 June. On 1 July, DIFC requested re-upload of the signed authorisation, and Rojin forwarded that requirement to Abeer, the Company accountant mailbox and Ms Lolita. On 3 July, DIFC confirmed that Ms Lolita had been appointed Super User with extensive Company, employee, financial and other permissions.

The formal USD 19,000 Decision Notice was issued on 10 July—after the former accountant’s access had been removed and after Ms Lolita had become Super User. It was sent to the Company’s registered accountant mailbox and addressed directly to the First Claimant, Klesta Eshja. A reminder was sent on 17 July before the 25 July payment deadline, followed by another reminder on 9 August.

The correspondence shows that the incoming management used a mixture of personal email addresses and the Company’s registered accountant mailbox during the transition. Formal DIFC notices continued to be delivered to the registered Company mailbox, which Ms Lolita later accessed and used. Any failure to coordinate and monitor those accounts, complete the enrolment, replace the DEWS signatory or pay the fine by the deadline cannot properly be characterised as concealment by me or attributed exclusively to me.

I do not deny that a DEWS compliance issue existed. I deny that I concealed it or solely caused the final fine and alleged consequential loss. I promptly disclosed the preliminary notice and instructed the relevant employees to act. The documentary evidence establishes an objection, the removal of the former accountant’s portal access, a transition to the incoming team, Ms Lolita’s subsequent Super User appointment and repeated notices addressed to the Claimants. The Court should therefore distinguish any underlying contribution arrears from the post-handover failure to complete the regulatory process and mitigate the loss.

Response [2] – I deny fraudulently misrepresenting the Company’s financial health. The Claimants have not identified the precise false financial statement allegedly made by me, when and to whom it was made, why it was false when made, how it induced the transaction, or what loss was caused by reliance upon it.

The independent ADIB Merchant Services confirmation dated 4 October 2023 records that Hair Creators Salon Ltd, under merchant ID 4001714, generated AED 3,656,361 in card transactions during the 12 months from October 2022 to September 2023, averaging AED 304,696.75 per month. It also certifies that there were no chargebacks during that period. The document bears the merchant-services signature and official stamp.

Those figures are independently corroborated by the ADIB account statement later produced and relied upon by the Claimants as EX‑CL‑08. For the eight overlapping months from February to September 2023, the merchant-services letter records AED 2,313,358 in gross card transactions, while EX‑CL‑08 records AED 2,256,118.54 in corresponding credits described as “Merchant Payment 4001714.” The difference is approximately 2.47%, which is consistent with merchant-processing deductions and settlement timing. The close monthly correspondence demonstrates that both records concern the same genuine business receipts.

EX‑CL‑08 was generated on 15 February 2024 and, according to my evidence, supplied to the Claimants’ representative before the Share Transfer Agreement. It displayed not only the Company’s merchant receipts, but also its expenditures, loan deductions and other liabilities. The Claimants therefore had the financial information from which they could assess both the Company’s income and its obligations before completing the acquisition. Their subsequent production and reliance upon that same statement is inconsistent with an allegation that the Company’s true financial activity was concealed from them.

The official assignment letter dated 29 January 2024 further records that all receivables under merchant ID 4001714 were assigned to the Company’s RAK Bank account ending 101002. That document explains why the same merchant-settlement income subsequently appeared as recurring credits in RAK Bank rather than ADIB. It demonstrates continuity of the Company’s business receipts and the corporate purpose of the RAK account.

I do not suggest that gross card turnover alone proves net profitability or the absence of liabilities. Turnover, profit, liabilities and overall financial health are different matters. My answer is that the independently certified turnover disproves any sweeping suggestion that the Company lacked genuine substantial operations, while the pre-contract ADIB statement disclosed the receipts, expenditure and liabilities necessary for the Claimants to assess its financial position.

The Claimants’ reliance on Mr Salem Dwela v Damac Park Towers Company Limited does not establish fraud. The Court of Appeal held only that an arguable misrepresentation claim could proceed to trial and expressly recorded that no fraudulent-misrepresentation claim had been pleaded. When the case later proceeded to trial, the misrepresentation claim was dismissed on the facts. The Claimants in this case must still prove a particular incorrect statement, inducement, actual reliance and resulting loss. The independent income confirmation and the pre-contract financial disclosure materially contradict those essential allegations..

Response [1] – I accept that the personal mobile number was on sometimes used for matters related to the second Claimant, I deny the assertions of exclusivity, the two contracts in dispute stated the term “Telephone” as an asset assigned for transfer the which is also presented on the Letterheads, invoices and other company materials, there is no term identifying my personal number or any contract. I rely on the Entire Agreement term.

Response [1] – I require the Claimants to Identify the contractual bases for this allegation or any material agreement that my Personal Mobile Number was included in for transfer, there is no term identifying my personal number or any contract. I rely on the Entire Agreement term and I deny that the Third Defendant had anything to do with my personal number.

Response [1] – I require the Claimants to Identify the contractual bases whereas the Third defendant and I had any obligations to transfer my personal number.

Response [2] – I deny the solicitation asserted without evidence to the contrary I rely on the earlier client messages wherein I provided clients contacted me personally with contact of the Second Claimant, this is documented in my correspondence with the Claimants’ representative.

Response [3] – there is many other salones with lawful licence in the DIFC and it can not be considered as unlawful competition, the Third Defendant is not a party to the contract these allegations are based on, her lawful work and hard earned income cannot be fully stopped because of the Share Transfer in dispute, the Claimants are required to specify the contract that give them Rights against the Third Defendant.

Response [1] – the agreement clause 1 is not related to my personal phone number, I deny any presentation of such a promise and I recall requesting a disclosure of documents that the Claimants’ real estate Agent relied on for drafting the contracts now allegedly breached.

Response [2] – there is no term in the entire agreement that Identify my personal mobile number as a company owned property no was there any presentation I made as a promise to transfer my 18 years old personal number.

Response [3] – Based on the Second Defendant’s documentation, regarding the purchase and registration dates of the shares:

• Purchase Agreement Effective Date: Jul 05, 2024. This is the date the Company Share Transfer Agreement was entered into between the transferor (Sukant Mishra) and the transferee (Iuliia Valiullina).
• Board Resolution Date: Jul 20, 2024. The Corporate Board Resolution to sell and accept the new shareholding structure was ratified to take effect from this date.
• Actual Registry Certification Date: Aug 13, 2024. The DIFC, Registrar of Companies certified the true copy of the share transfer document identifying Iuliia Valiullina as the registered proprietor on this date.

Response [1] – I deny any assertion of relocating and I further nedy the misstated facts in the witness Statement of the First Claimant’s real estate Agent, on 20 March 2024 I rejected that non-competition term in writing and refused to sign the second agreement that the Agent drafted during negotiations, I offered the Agent a refund of the deposit he paid, the Agent responded that he will delete that term from the drafted agreement, this is documented and the correspondence is still on my personal phone until the minute. I further deny that the real estate Agent introduced me to the First Claimant or facilitated any connection between us before the two contracts were already signed and executed on 26 March 2024.

Response [2] – if the Agent misrepresented the Company Share Transfer Agreement terms to his paid client the First Claimant or promised her that these terms she requested are binding me personally that is not a wrongdoing that I am liable for, I recall requesting that Agency to disclose material documents they referred to in Clause No. 5 and 7 of base contract dated 14 Feb 2024, the first contract, what are these documents and informations they referring to and what was the pre contract base they relied on, I deny that the contract was drafted by relying on verbal promises.

Response [3] – The Article 4 the Claimants rely on Company Share Transfer Agreement dated 20 march is non-existent term while Clause 11 is imposed on the Second Claimant in its company capacity not on me in personal capacity or name, the Term clearly stating the “the Company agree not to engage”

Response [1] – Paragraph 120 is denied. The judgment in SCT-352-2024 does not record that I said I had changed my mind about relocating to Syria, nor does it record any argument by me concerning a right to compete with the Second Claimant. SCT-352-2024 was a separate employment proceeding concerning cancellation of my employment visa. The Court recorded that I withdrew all claims except visa cancellation, treated the DEWS penalties and Sale and Purchase Agreement issues as separate matters, and ordered the Second Claimant to cancel my visa because the employment relationship had ended by resignation.

I also deny ever representing to Mr Sokol Cici or the First Claimant that I would relocate to Syria. My separate legal position is that the non-compete clause was addressed to “the Company” and did not impose a personal three-year restriction upon me. That contractual position is not an admission that I competed unlawfully, diverted clients, or breached any obligation.

If the Claimants rely upon words allegedly spoken during the SCT hearing, they must produce the official recording or transcript and identify the exact words and context. The judgment itself does not prove their assertion.

Response [1] – Paragraph 121 is denied as pleaded. The First and Third Defendants did not jointly establish, acquire or own Hair Crafters Company Ltd.

The documentary record shows that Hair Crafters was an existing, separately licensed business before the sale of Hair Creators. Its licence records the company trading as The Grove Salons from Unit CC4 by October 2022, and its separate tenancy commenced in November 2023.

The Third Defendant resigned from Hair Creators on 13 June 2024, effective 28 June 2024. She subsequently entered into a separate share-transfer agreement effective 5 July 2024. Payment of AED 350,000 was acknowledged on 21 July 2024, and the share certificate dated 12 August 2024 records the Third Defendant alone as proprietor of all 1,000 shares. No document records the First Defendant as a shareholder or joint owner.

The First Defendant was identified as an authorised signatory only later, in October 2024, and his employment contract dated 14 November 2024 appointed him as a Hair Dresser. These later roles do not prove that he established, acquired or owned the company.

The mere fact that the businesses provided similar services or were approximately two kilometres apart does not establish unlawful competition, solicitation, diversion of customers or resulting loss. Paragraph 121 also refers to “two specific actions” but does not identify either action, its date, the person responsible, the supporting document or any resulting loss.

Response [1] – Paragraph 122 is denied as it alleges that the Claimants first discovered these transfers through bank statements disclosed in August 2025. The five transfers were already displayed in the Claimants’ own EXCL08, which they relied upon in support to their original Particulars of Claim dated 7 January 2025. They therefore possessed these records months before the alleged August 2025 discovery.

The statement records the five outward transfers totalling AED 80,000. However, it also records an inward transfers of AED 4,700 from “HAIRBYROJIN SALON LTD” on 22 and on 28 March 2024, making the net outward movement AED 75,300 before bank charges.

The entries alone do not prove that the payments lacked a contractual or commercial basis, approval or supporting documentation. Nor do they prove that the payments came from the RAKBANK loan, were improperly retained or caused any loss. The first transfer, dated 3 February 2024, also predates the initial agreement of 14 February 2024.

Response [1] – Paragraph 123 is denied. It is incorrect to allege that I provided no justification for the transfers. My Amended Defence, paragraphs 7.13–7.17, explains that the five payments represented remuneration owed to me for February and March 2024, which I directed to the Fourth Defendant for the support of my daughter, principally her schooling expenses.

The Claimants’ own EXCL33 is my employment contract dated 1 July 2021. It records total remuneration of AED 40,000 per month, comprising AED 24,000 basic salary and AED 16,000 in allowances. The five transfers total exactly AED 80,000, corresponding to two months’ contractual remuneration.

The pleaded basis was therefore payment of an employment liability, not payment for goods or services supplied by the Fourth Defendant. Consequently, no commercial invoice or agreement from the Fourth Defendant would ordinarily be expected. If remuneration was lawfully owed to me, directing it to a third party for family support does not convert it into misappropriation; it discharges the Company’s liability to its employee.

The Claimants must prove that the February and March remuneration was not outstanding, that the transfers exceeded my contractual entitlement, or that the stated salary explanation is false. The mere fact that the funds were ultimately used for a personal or family purpose does not establish dishonest diversion..

Response [1] – it is denied that the second claimant paid any cost for the setup of the fourth defendant.

Response [2] – it is denied that the second claimant POS was linked, used or accessed by the fourth defendant no that the Business financing agreement no. is a personal, the Claimants are required to prove these allegation.

Response [1] – Paragraph 125 is denied as it alleges wrongdoing by me. I make no admission on behalf of the Fourth Defendant. The allegation incorrectly assumes that the five payments were misappropriated and then attempts to infer knowledge from personal relationships. The underlying misappropriation is denied. My Amended Defence explains that the AED 80,000 represented two months of accrued remuneration owed to me under EX‑CL‑33, which records monthly remuneration of AED 40,000. I directed those funds to the Fourth Defendant to support my daughter, principally her schooling expenses.

As to the matters relied upon:

(a) My former marital relationship with Ms Rojin does not establish knowledge of wrongdoing.

(b) Any historical or simultaneous employment does not establish that either person knew the payments were improper.

(c) The allegation of shared access to the Second Claimant’s financial systems is denied. The Claimants must identify the system, credentials, dates and activity allegedly undertaken by Ms Rojin or the Fourth Defendant.

(d) It is denied that the Fourth Defendant used assets or funding belonging to the Second Claimant. Unit 130 had a separate lease-transfer and variation history. Its rent and fit-out costs were paid from Ms Rojin’s personal account, including the cheque paid to Falcon Interior Decoration LLC.

(e) Any alleged reference to the Fourth Defendant as a “gift” must be read in context. It referred to my personal assistance and funding for Ms Rojin’s project. It was not an admission that I gifted the Second Claimant’s assets, equipment, fittings, fixtures or stock. The Claimants must identify each allegedly transferred asset and prove its ownership, transfer, recipient and value.

(f) No commercial invoice was required because the pleaded basis of the payments was satisfaction of my employment remuneration, not the purchase of services from the Fourth Defendant.

The listed personal and historical connections do not prove that the Fourth Defendant knew or ought to have known of any misappropriation. The Claimants must first prove that the payments were wrongful and then prove knowledge of that specific wrongdoing.

Response [2] – it is denied that the second claimant POS was linked, used or accessed by the fourth defendant no that the Business financing agreement no. is a personal, the Claimants are required to prove these allegation.

Response [1] – .

Response [1] – I deny that the alleged unauthorised diversion or any misused assets and money, the Claimants were unable to prove such allegations with any material evidence or even establish that the authority that was allegedly breached no the contract term given rights to claim matters predated the contract.

Response [1] – Paragraph 128 is denied. The July emails do not demonstrate that the First and Third Defendants jointly acquired the Second Defendant before the sale of the Second Claimant. They establish the opposite chronology.

On 9 July 2024, I expressly clarified that SR‑297386 concerned “another salon” at Liberty House CC4 called Hair Crafters Salon Ltd and that it had “nothing to do with other requests done to Hair Creators Salon.” This clarification was necessary because DIFC had confused the two companies.

The email identifies Iuliia Valiullina alone as the proposed purchaser. It states that the current shareholder had submitted a request for the shares to be transferred into her name and that the process remained at the passport-verification and initial-approval stage.

The subsequent correspondence confirms that no transfer had yet been completed. Between 10 and 17 July 2024, passport verification repeatedly failed, SR‑297386 could not be submitted and the parties requested manual verification followed by the “subsequent transfer of shares.” My use of the expression “has bought” referred to the purchase agreement, not a completed or registered transfer.

The documentary chronology is:

• Iuliia gave notice of resignation on 13 June 2024, effective 28 June 2024.
• She entered into the separate share-transfer agreement on 5 July 2024.
• The July emails record the incomplete verification and regulatory process.
• Payment of AED 350,000 was acknowledged on 21 July 2024.
• Her registered ownership was documented by the share certificate dated 12 August 2024.

The Claimants themselves allege that the First Claimant obtained control of the Second Claimant in late June 2024. Accordingly, the 5 July agreement and 9 July correspondence occurred after that date, not before it.

Nothing in the emails states that I acquired, paid for or beneficially owned any shares in the Second Defendant. My assistance with the DIFC verification process does not establish joint ownership, and the marital relationship does not convert Iuliia’s separate acquisition into my acquisition.

The emails therefore do not prove prior acquisition, joint ownership, concealment or breach. At most, they prove that, following Iuliia’s resignation, a separate acquisition process for an existing salon was being pursued and remained incomplete during July 2024..

Response [1] – the assertions that Third Defendant was obligated to disclose her own business or was in need for a permission to is denied, her employment contract does not impose any duty to disclose or request any approvals following her resignation from the Second Claimant, if her acquisition of the shares in the Second Defendant were unlawful, the DIFC itself would reject such transfer. we require the Claimants to identify the contractual terms monaditing alleged obligations.

Response [2] – the allegation about misappropriated funds require detailed specifications in terms of amount, date, transactions and proof of the same with all due respect the broad term as pleaded with no material evidence is denied.

Response [3] – bad financial records are easily proven by a sample audited report such concern is true and the very first financial material disclosed to the Claimants’ real estate Agent was a 12 month bank statements showing genuine income and deductions of loan in the name of the company, now the if First Claimant having read and understood these transactions and decided to buy the company such decision was a choice and if not then the misrepresentation was in fact by her real estate Agent not First and Third Defendants, it is denied that the company was in bad financial status and the Claimants are required to prove it.

Response [1] – I admit withdrawing the business finance funds but not obstruct the First Claimant, I did not know her in 2023. The business finance funds as credited by the bank is 1,012000 dirham as a total, I refer to the total cash deposits and inward transfers records of the relative time period totaling 1,050,000 AED which is more than the loan total funds having been deposited into the other Company’s ADIB account between Feb 2023 and 30 April 2024 prior to the formal share transfer, These transactions and their source statements derive directly from pre-contractually disclosed company bank statements the Claimants’ submitted as (EXCL08) and utilized through the Company’s operating account for the direct and exclusive benefit of the Second Claimant. therefore the allegations on withdrawals are denied because the loan money is used in for the company benefit. and if we mention the money I deposited after the Share Transfer the

Response [2] – the agree that the funs are indeed company related funds and I must say that this is inconsistent with the Claimant assertion that the Loan is personal Loan.

Response [3] – I deny having any withdrawals made after 1 April 2024 and I request the Claimant to prove it.

Response [4] – The four payments described as payments to “Liberty House” total AED 4,594.13. The supporting documents establish that they were paid to LIBERTY HOUSE PRINCIPAL BC GEN FUND, the body-corporate account used for utility and property charges.

The corresponding invoices and notices relate to my residential Apartment 2419 on the 24th floor of Liberty House. The residential leases identify me as the tenant, and the utility notices are addressed to me for Unit 24/2419. The payment amounts correspond to those residential charges.

These payments were not made to the Second Defendant, its seller or its business premises at Unit CC4. Apartment 2419 and Unit CC4 are separate premises. The fact that both are located in Liberty House does not establish any financial connection between them.

The payments were made between May 2023 and February 2024. The Third Defendant’s separate Share Transfer Agreement was effective only from 5 July 2024, and receipt of the AED 350,000 purchase price was acknowledged on 21 July 2024. There is no evidence tracing any of the AED 4,594.13 to that purchase price or to the Second Defendant’s operations.

Accordingly, the documents disprove the Claimants’ assumption that these Liberty House payments were used to acquire the Third Defendant’s shares or support the Second Defendant. A shared building name is not evidence of a shared tenancy, recipient or purpose.

Response [1] – the final installment against the share price was made on 1 May 2024, the day in which I submitted 100% share transfer request to the DIFC, for the First Claimant to become registered as Manager on the commercial license she had to complete the regularity procedure of attesting her passport, submitting the Portal application and get the ROC confirmation and the related Share Certificate before her registration as an Authorised Signatory on the commercial license of the Second Claimant, this process took at least 2 to 3 weeks, following the issuance of the new Share Certificate the First Claimant removed my name from the company commercial license at her first available opportunity without the need of any further approval from myself. contractually defined arrangement for managing the second claimant can not now be inter.

Response [2] – I deny that I operated the Second Claimant together with the Second Defendant at the same time, I rely on the Second Claimant Commercial License issued on 18 October 2024, in fact 4 month following the completion of the Share Transfer of the Second Claimant and following the SCT Court order to cancel my work visa issued from it.

Response [1] – The First Defendant’s direct evidence is that, from the website’s creation in 2019, the haircreators.net domain was acquired and administered through One.com, while the website’s content, design, galleries, images and other displays were created and published through Webflow. The domain service and the website publishing platform were therefore separate functions.

A website-development proposal dated 3 July 2023 was addressed to “Mr. Salah Masri, CEO – Haircreators.net” and expressly concerned the Hair Creators Salon business. The proposal states that Kent Tupas intended to use WordPress as the CMS. The First Defendant’s understanding is that Kent subsequently migrated or rebuilt the Webflow website content in WordPress and changed the design. However, the proposal proves the intended migration, not its completion; completion should be established by Kent’s evidence, technical records, WordPress records or contemporaneous communications.

The First Defendant’s evidence is that Mr Thomas, a full-time media manager employed by the Second Claimant, prepared fresh website content and communicated it to Kent for uploading and publication. This is consistent with Ms Lolita’s own witness statement identifying Thomas as involved with the website/accounts. It should be corroborated by Thomas’s employment record or job description, native Thomas–Kent communications, content files and platform collaborator or activity logs.

The supplied proposal is incomplete because bundle page 666 is absent. The pages produced contain no express maintenance or email-administration clause. The clause saying the resulting work would be the intellectual property of “Mr. Masri” is potentially ambiguous and must be explained by the fact that the proposal identifies him as CEO, concerns the Hair Creators business, and the Company paid the relevant service providers.

The Claimants’ bank material records recurring Webflow charges during 2023 and January 2024, a One.com charge of AED 920.67 on 9 November 2023, and payments of AED 400 to Kent Tupas on 13 February, 27 April, 4 May and 12 June 2024. The payments on 27 April, 4 May and 12 June occurred after the operational handover and support the existence of an ongoing web-designer relationship while the Claimants’ appointed management was operating the Company. The statements do not identify which individual initiated each transfer.

Webflow’s email of 12 September 2024 states that repeated attempts to charge the billing card failed, that the CMS hosting plan was cancelled, and that any connected custom domain was consequently unpublished. This supports an administrative non-payment explanation for the website going offline rather than deliberate deletion or obstruction. Because the notice was addressed to the First Defendant, it is still necessary to produce the earlier payment warnings, evidence that they were passed to the Claimants, and any request that the Claimants update the billing method.

On 15 October 2024, the Claimants’ accountant Ms Lolita Tines used accountant@haircreators.net to forward historical DIFC correspondence to the First Defendant, including messages from April, May, July and August 2024. This proves that the Claimants’ appointed accountant had access to the accountant mailbox and its historical contents by that date, contrary to an unqualified allegation of no past or present access.

Ms Lolita’s witness statement says that she did not witness any attempt by the First Defendant to restrict access to important business data. Her statement that Thomas and the First Defendant “apparently” controlled the accounts “as per the website guy” is not evidence from her own direct knowledge and does not identify any login, refusal, deletion or access event by the First Defendant. Her reference to Thomas nevertheless supports the Defence evidence that a Company employee was involved in the website workflow.

The One.com screenshot dated 31 August 2026 says only that haircreators.net is “with another provider.” It does not identify the current provider, prove who transferred the domain, state when any transfer occurred, or establish the status of the website or email hosting in 2024.

Accordingly, the presently available evidence does not establish that the First Defendant deliberately blocked access, refused a valid technical transfer, accessed confidential data after handover, or caused the alleged loss. The operational history instead identifies at least two other persons involved in website activity: Thomas, the Second Claimant’s employee responsible for content, and Kent, the external designer responsible for technical publishing. The Claimants should identify the particular credential requested, the date and recipient of each request, the alleged refusal, the service involved, the technical record proving the First Defendant’s control, and the loss caused. The strongest independent evidence would be the domain-transfer and DNS history, Webflow and WordPress account/activity records, One.com and email logs, the complete Kent Tupas contract, Thomas–Kent communications, and evidence from Kent and Thomas concerning the actual migration, administration and credential handover.

Documents and references

Ms Lolita Tines’ witness statement, particularly the passages concerning data restrictions and official email accounts..

WEB HOSTING DETAILS supporting file: Kent Tupas proposal, Webflow cancellation email and later One.com screenshot.

Website-development proposal dated 3 July 2023, supplied bundle pages 665, 667 and 668; bundle page 666 is absent.

Webflow CMS Hosting cancellation email dated 12 September 2024.

One.com domain-search screenshot dated 31 August 2026.

Claimants’ EX-CL-08 bank material: Webflow and One.com charges and AED 400 transfers to Kent Tupas, including PDF pages 124, 136, 139 and 202 of BinderEX CL08.

DEWS Hair Creators Ltd, Reference No. SR-206759 correspondence: emails forwarded by Ms Lolita from accountant@haircreators.net on 15 October 2024.

Response [2] – I deny that I operated the Second Claimant together with the Second Defendant at the same time, I rely on the Second Claimant Commercial License issued on 18 October 2024, in fact 4 month following the completion of the Share Transfer of the Second Claimant and following the SCT Court order to cancel my work visa issued from it.

Response [1] – I deny that the Second Claimant was operated under any different trade name, all of it documentations state its own name, the mere social media account Hair By Salah is my personal industrial identity, hair by salah was not a part of the share transfer contract not it is an asset owned by the Second Claimant, this was made known to the First Claimant and she was able to cancel the contract when I rejected the transfer of Hair By Salah after the misrepresentation her real estate Agent made regarding the ownership of it. any claim for additional assets from outside the scop of the contract is denied.

Response [2] – I deny blocking access or causing the alleged disruption. From the website’s creation in 2019, its administration was structurally divided: domain registration was handled via One.com, while design and hosting were managed through Webflow. I did not unilaterally control these functions. Operations were actively managed by the Second Claimant’s full-time media manager, Mr. Thomas, and an external web designer, Mr. Kent Tupas. Bank records confirm that the Claimants’ continued to pay Mr. Tupas between April and June 2024, proving an active, ongoing relationship with the webmaster well after the operational handover.

The website going offline was not an act of deliberate obstruction, but rather the result of administrative failure by the Claimants’ management. A September 12, 2024 notice from Webflow confirms that the CMS hosting plan and custom domain were unpublished strictly because repeated attempts to charge the billing card failed.

The Claimants’ unqualified allegation that they completely locked out of their accounts is factually incorrect. Evidence demonstrates that on October 15, 2024, the Claimants’ accountant, Ms. Lolita, actively used the accountant@haircreators.net address to forward historical correspondence. Furthermore, Ms. Lolita’s own witness statement admits she never witnessed the First Defendant restrict access to business data.

The Claimants web development proposal submitted itself stated that the webmaster intended to shift the site content to WordPress, and a latter search result in One.com stating the domain is “with another provider” failing to prove unauthorized transfer. To substantiate their claims, the Claimants must produce specific technical evidence, including DNS history, Webflow/WordPress activity logs, Thomas-Kent communications, and definitive proof of any specific credential request formally refused by the First Defendant..

Response [1] – I deny any misrepresentation and conclusions to be made directly or indirectly to the First Claimant. I expected long term Due Diligence from 14 Feb until 1 May 2024 in which the First Claimant and her appointed representatives exercised their rights to find out any company related information matter to them and I further rely on my documented written rejection to transfer Hair By Salah on the 2 of April by which time the First Claimant was able to terminate the Agreement but chose to proceed therefore any allegedly made representation is required to proven by words, the person said such words, the time and the Claimants’ reliance on such misrepresentation with evidence.

Response [1] – the STA Clause No.1 is about the transfer of shares, there is nothing in it about virtual or digital assets, the list of items included for transfer on the second page of the Agreement identify the Social Media Assets of the Second Claimant being { Hair Creators } in reference to its instagram account among other platforms, there is no reference identifying { Hair By Salah } as digital asset agreed for transfer therefore I deny any obligations to handover my personal social account to the claimants and I further request them to identify the contractual terms they rely on.

Response [1] – the STA Clause No.1 is about the transfer of shares, there is nothing in it about virtual or digital assets, the list of items included for transfer on the second page of the Agreement identify the Social Media Assets of the Second Claimant being { Hair Creators } in reference to its instagram account among other platforms, there is no reference identifying { Hair By Salah } as digital asset agreed for transfer therefore I deny any obligations to handover my personal social account to the claimants and I further request them to identify the contractual terms they rely on.

Response [2] – the purported tax invoice is fake and I require the Claimants to prove its authenticity by showing the actual correspondence including full attachments.

Response [3] – the bank account of the Third Defendant is denied, the Second Defendant had its own commercial Bank account from ADCB and full statement of that account is filed, the Claimant failed to specify the term given them right to allege matters relate to the personal account of the Defendant.

Response [1] – The allegations concerning unauthorized access to sensitive data are overly broad, unparticularized, and are accordingly denied in their entirety. Regarding the POS Merchant ID 4001714, this service has been provided to the Second Claimant since 2021, and its monthly reports have been routinely routed to my personal email since that time. The network provider continues to direct these reports to me solely as a consequence of the First Claimant’s own inaction. The First Claimant refused to register herself as the Authorized Signatory with RakBank thus she can not request an update to the POS registered email address.

Furthermore, This bank registration remains pending since the sale in dispute because the First Claimant refuses to sign the requisite financing security instrument, a deliberate omission made to avoid being forced to satisfy the associated monthly repayment obligations.

Response [2] – the assertions about integrated spying software discovery are denied and the Claimants are required to prove the that by device name, the technology used and how that is done by myself.

Response [3] – I deny the purported admission I did not admit to have key access, the fact that my emails was historically used to keep the monthly payments satisfied on the domain hosting provider doesn’t prove that I had willfully taken down the company email addresses, I never received an email request to maigret the site to another provider or provide any informations about it because the webdesigner Mr Kent was in charge of that and he in fact shifted the domain and its contents to another hosting provider called WordPress without any further requirements from me. I have no benefit deleting these emails and to the contrary if I have access to the same now I will be able to support my position further with material correspondences that undermine the present allegations.

Response [1] – The allegations concerning unauthorized access to sensitive data are overly broad, unparticularized, and are accordingly denied in their entirety. Regarding the POS Merchant ID 4001714, this service has been provided to the Second Claimant since 2021, and its monthly reports have been routinely routed to my personal email since that time. The network provider continues to direct these reports to me solely as a consequence of the First Claimant’s own inaction. The First Claimant refused to register herself as the Authorized Signatory with RakBank thus she can not request an update to the POS registered email address.

Furthermore, This bank registration remains pending since the sale in dispute because the First Claimant refuses to sign the requisite financing security instrument, a deliberate omission made to avoid being forced to satisfy the associated monthly repayment obligations.

Response [2] – the assertions about integrated spying software discovery are denied and the Claimants are required to prove the that by device name, the technology used and how that is done by myself.

Response [3] – the fact that my emails was historically used to keep the monthly payments satisfied on the domain hosting provider does not prove that I had willfully taken down the company email addresses, I never received an email request to maigret the site to another provider or provide any informations about it because the webdesigner Mr Kent was in charge of that and he in fact shifted the domain and its contents to another hosting provider called WordPress without any further requirements from me. I have no benefit deleting these emails and to the contrary if I have access to the same now I will be able to support my position further with material correspondences that undermine the present allegations.

Response [1] – the First Claimant herself is indeed the non-performing party to her written obligation on the first page of the two contract she signed to purchased the company and excepted all of its liabilities and all of its obligation in writing, on two contracts and refused to honour these obligations upon knowing about the personal guarantee of the company loan, the present mixed up allegations failing to present one material proof are designed to help her avoid paying her company loan and are denied.

Response [1] – I accept the statutory provisions only as they are accurately quoted. I deny breaching any duty of cooperation. I pursued the share-transfer process, assisted with the handover and provided operational access. The remaining RAKBANK resulted from the First Claimant refusal to provide the Bank a replacement of my security-cheque in order to be the authorised-signatory, not from any refusal by me to cooperate. The Claimants must identify the particular contractual obligation, the cooperation allegedly required, the request made to me and the act or omission said to constitute the breach. it is respectfully submitted the First Claimant herself is in breach of the core written understanding she signed upon in the Memorandum Of Understanding on 14 Feb 2024.

Response [1] – Paragraph 141 is denied in its entirety.

1. Share transfer

The allegation that 100% of the shares were not transferred is inconsistent with the Claimants’ own case. APOC paragraph 1 admits that the First Claimant ultimately became the sole shareholder of the Second Claimant.

The contemporaneous DIFC correspondence shows that I applied to add the First Claimant as a shareholder on 26 March 2024, after receiving her required identification and financial documents. Preliminary approval was issued on 17 April 2024. When the final AED750,000 instalment was paid on 1 May 2024, I requested the transfer of 100% of the shares. DIFC confirmed the further regulatory procedure on 2 May 2024. Regulatory processing by DIFC was not a refusal by me to transfer the shares.

2. Bank accounts

Operational access must be distinguished from being formally registered as a bank signatory. ADIB access was handed over, and operational control of the business was given to the Claimants’ appointed manager, Ms Rexhina Mena, on 1 April 2024.

I remained the RAKBANK authorised signatory because the Bank required the replacement of my security cheque, which the First Claimant declined to provide. My Defence states that the RAKBANK credentials were provided to Ms Rexhina on 17 April 2024.

The Claimants’ own EX-CL-08 contains an electronically generated RAKBANK statement issued on 14 June 2024. Their possession of that statement is inconsistent with their blanket allegation that no access or credentials were provided. However, the identity of the person who downloaded it can be conclusively established through RAKBANK’s audit records.

3. Website, email and social-media systems

I deny deliberately withholding any Company-owned digital asset. The domain registration, website hosting, content-management system and email hosting were separate technical functions. The website was administered through the external designer, Kent Tupas, with content handled by the Second Claimant’s media employee, Thomas.

Payments to Kent continued after the handover. The Webflow email dated 12 September 2024 records that the hosting plan was cancelled following failed subscription payments, not because I deleted or obstructed the website. Ms Lolita subsequently used accountant@haircreators.net to forward historical Company correspondence, proving that the Claimants’ appointed accountant had access to that Company mailbox.

The Claimants must identify the particular credential requested, the date of the request, the alleged refusal, the person who actually controlled the relevant service and the loss caused.

4. Telephone numbers and intellectual property

The two mobile numbers relied upon by the Claimants were registered in my personal name and were not expressly identified in the SPA as assets to be transferred. They must be distinguished from the Second Claimant’s business landline, Hair Creators branding, customer records and other Company-owned property. “Hair by Salah” was my personal professional identity. It was not transferred to or owned by the Second Claimant. I deny retaining or accessing confidential customer, POS or operational data after the handover.

5. Alleged continued control

My remaining registration as the RAKBANK authorised signatory did not itself establish that I continued exercising operational control. It resulted from the Bank’s security-cheque requirements. The Claimants must identify every post-sale transaction or instruction allegedly made by me, together with its date, purpose, authority and resulting loss.

6. Non-compete and the Second Defendant

I deny that the SPA imposed the alleged personal three-year restriction preventing me from working in my profession. The proposed personal restriction was rejected during negotiations. Clause 11 was expressed as an obligation of “the Company,” and its proper interpretation is a matter for the Court.

The APOC also incorrectly describes the Second Defendant as “Hair by Salah.” The Second Defendant is The Hair Crafters Company Ltd, trading as The Grove Salons. Annexure D27 shows that it was already an existing licensed business in October 2022. Annexures D35 and D29 identify Iuliia Valiullina as the purchaser and sole registered shareholder. Annexures D26 and D30 identify me only later as an authorised signatory and employee/hairdresser, not as purchaser or shareholder.

The fact that two salons were geographically close does not establish ownership, contractual breach or diversion. The Claimants have not identified any particular client or supplier diverted by me, the communication used, the resulting transaction or any corresponding loss.

Response [1] – Paragraph .

Response [1] – The First Claimant herself breached the fundamental term of the contract whereas she purchased the Company including all of its liabilities and other obligation related to it on 14 Feb and then on 20 March 2024, the two contracts included the same retained liabilities term and denied her obligation once she knew that the Company financing agreement is secured by a personal cheque which is not enforceable against her or her company, this calculated misconduct committed regardless the 1 million reduction in the purchase price that she herself admitted. the manufactured allegations in the present proceedings are designed to evade the loan repayment and prevent me from enforcing the contract terms the First Claimant herself signed. the unfounded allegations of fiduciary breach are denied.

Response [1] – I admit owing these duties to the Second Claimant at the time I established it from scratch and until under my management the Company was generating a minimum income of 300,000 dirhams a month which is exactly why the First Claimant purchased it with its liability to pay back its Financing Loan, I deny that I breached any of these duties or diverted any of its clients and the claimants are required to prove that.

Response [2] – I spent the funds of the financing facility exclusively for the benefit of the Second Claimant as recorded on its Banking statement of account from ADIB and I further supported it with extra amount from my own and the Court is invited to read the banking records save for the 3 million I spent on its setup and preparation at first place, misappropriation of its funds is denied.

Response [3] – the Third Defendant in not a contracting party to any agreements and following her resignation she was not obligated to seek permission of any of the Claimants regarding her business.

Response [1] -.

Response [1] -.

Response [1] – I deny the wrongful act as an authorised signatory and I relay on my email sent to the First Claimant personal email on 8 June 2024 requesting her to provide RakBank a copy of the new commercial license and all other company documents reflecting the ownership change and further provide the bank a replacement of the security cheque that I earlier signed.

Response [2] – I deny making any alleged unauthorised withdrawals and I relay to the contrary on the monthly deposits into the Rak Bank Account since the First Claimant dishonored her contractual obligation with documented account statements and cash deposit slips with total amount of 700,000 till.

Response [1] – I deny the broad withholding allegations and I require the Claimants to specify, data type, devices used, dates, software or system and present verifiable evidence.

Response [2] – the Second Defendant Name is Hair Crafters Company Ltd, Hair By Salah Is not a company or registered license and I deny the unparticularized allegation of diverted Clients with no evidence.

Response [3] – I forwarded the DEWS Notice of fine to the former business manager on the same day I received the proposed fine by Mon 15 april 2024, she in turn filed timely objection on the salon portal and advised the Claimants appointed manager to follow up and submit the team documentations, her resignation notice was over by end of May 2024 and left the company before any fine decision was formally imposed, this is documented.

Response [1] – such duty of avoiding conflict applied on me during my formal employment with the Second Claimant but after I left the company and especially the DIFC SCT Court ordered on 18 October 2024 that my work visa be cancelled, these alleged duties were no longer applicable on me and are denied to continue in effect.

Response [2] – the Non-Competition term is binding the Second Claimant itself it stating that “the Company Agree not to engage” and it does not bind me or my name, I rely on my written rejection to that term before the Agreement was executed and I rely on the written admission of the First Claimant’s Agent that he will delete that term and amend the agreement, if the Agent misrepresented that term to her or provided her untrue assurance regarding that term then that matter is between them to be sorted out, the Second Defendant was established years before the Second Claimant and the Third Defendant ownership of its shares does not make me the owner of it or prove that I established it.

Response [3] – I forwarded the DEWS Notice of fine to the former business manager on the same day I received the proposed fine by Mon 15 april 2024, she in turn filed timely objection on the salon portal and advised the Claimants appointed manager to follow up and submit the team documentations, her resignation notice was over by end of May 2024 and left the company before any fine decision was formally imposed, this is documented.

Response [1] – I deny permitting unauthorized withdrawals, I rely on the 1,269,890 AED were deposited in cash directly into the Second Claimant Bank Accounts between 1 March 2023 and 30 April 2024. these figures do not count any transfers between the 2 bank accounts of the company.

Response [2] – the supplier debt is paid in full for the reasons I explained earlier and the DIFC Fines incurred after the handover date.

Response [3] – I dnay the broad allegations of failure to handover.

Response [1] – no material records of financial damage have been pleaded nor there was a proof of direct financial damage arose from any alleged wrongdoing, to the Contrary I and the Third Defendant had incurred severe and documented financial loss with records exceeding 1.5 million seins the sale in dispute.

Response [2] – I deny the broad allegations of misappropriated company assets, and I require martial proof, detailed list of assets, and invoices .

Response [3] – I dnay that the 15 April notice itself was an already imposed penalty rather it is was a formal Notice of intended fine from DEWS which occurred after the 2 contracts. And sent on 15 April to the registered email address of the Second Claimant to which Ms Rexhina the newly appointed salon Manager had access and I received a copy on my personal email as well, during the relevant time, Ms Abier Al Kourdy was serving her 2 weeks notice after the Handover dated 1 April and indeed responded by rising an objection to DEWS via the DIFC Portal under SR 206759 on the bases that the company did not receive prior direction to enroll its employees before 15 April, further she guided the new Manager on how to follow up with the process, Ms. Shamma from the DEWS team responded on 27 May by referring to the objection raised and encouraged the Second Claimant to complete the enrollment before 15 June 2024 to avoid the said by that time the new salon accountant was already hired and had access to the DIFC Portal as evidenced by her own visa issuance and access to the company email as evidenced by her replies received with the necessary employees salaries informations as evidanced by the timely salaries paid on 30 May 2024 including the salaries of Lolita and the Manager Rexhina as evidenced in bank statement of account.

Response [1] – no material records of financial damage have been pleaded nor there was a proof of direct financial damage arose from any alleged wrongdoing, to the Contrary I and the Third Defendant had incurred severe and documented financial loss with records exceeding 1.5 million seins the sale in dispute.

Response [2] – I deny the broad allegations of misappropriated company assets, and I require martial proof, detailed list of assets, and invoices .

Response [3] – I dnay that the 15 April notice itself was an already imposed penalty rather it is was a formal Notice of intended fine from DEWS which occurred after the 2 contracts. And sent on 15 April to the registered email address of the Second Claimant to which Ms Rexhina the newly appointed salon Manager had access and I received a copy on my personal email as well, during the relevant time, Ms Abier Al Kourdy was serving her 2 weeks notice after the Handover dated 1 April and indeed responded by rising an objection to DEWS via the DIFC Portal under SR 206759 on the bases that the company did not receive prior direction to enroll its employees before 15 April, further she guided the new Manager on how to follow up with the process, Ms. Shamma from the DEWS team responded on 27 May by referring to the objection raised and encouraged the Second Claimant to complete the enrollment before 15 June 2024 to avoid the said by that time the new salon accountant was already hired and had access to the DIFC Portal as evidenced by her own visa issuance and access to the company email as evidenced by her replies received with the necessary employees salaries informations as evidanced by the timely salaries paid on 30 May 2024 including the salaries of Lolita and the Manager Rexhina as evidenced in bank statement of account.

Response to Para 153 – is denied. It is incorrect to allege that I provided no justification for the transfers. My Amended Defence, paragraphs 7.13–7.17, explains that the five payments represented remuneration owed to me for February and March 2024, which I directed to the Fourth Defendant for the support of my daughter, principally her schooling expenses.

The Claimants’ own EX‑CL‑33 is my employment contract dated 1 July 2021. It records total remuneration of AED 40,000 per month, comprising AED 24,000 basic salary and AED 16,000 in allowances. The five transfers total exactly AED 80,000, corresponding to two months’ contractual remuneration.

The pleaded basis was therefore payment of an employment liability, not payment for goods or services supplied by the Fourth Defendant. Consequently, no commercial invoice or agreement from the Fourth Defendant would ordinarily be expected. If remuneration was lawfully owed to me, directing it to a third party for family support does not convert it into misappropriation; it discharges the Company’s liability to its employee.

The Claimants must prove that the February and March remuneration was not outstanding, that the transfers exceeded my contractual entitlement, or that the stated salary explanation is false. The mere fact that the funds were ultimately used for a personal or family purpose does not establish dishonest diversion.

Response [1] – is denied that my salaries of Feb and March transfers to the Fourth Defendant amount to a breach of my Fiduciary duty at the time when my employment contract was still in effect, I further submit that there was no contractual provision requiring me to seek any approval from the First Claimant during the ownership transitional phase.

Response [1] – It is incorrect to assert that I provided no justification for the transfers. My Amended Defence, paragraphs 7.13–7.17, explains that the five payments represented remuneration owed to me for February and March 2024, which I directed to the Fourth Defendant for the support of my daughter, principally her schooling expenses.

Response [1] – is denied that my salaries of Feb and March transfers to the Fourth Defendant amount to a breach of my Fiduciary duty at the time when my employment contract was still in effect, I further submit that there was no contractual provision requiring me to seek any approval from the First Claimant during the ownership transitional phase.

Response [1] – It is incorrect to assert that I provided no justification for the transfers. My Amended Defence, paragraphs 7.13–7.17, explains that the five payments represented remuneration owed to me for February and March 2024, which I directed to the Fourth Defendant for the support of my daughter, principally her schooling expenses.

Response [1] – is denied that my salaries of Feb and March transfers to the Fourth Defendant amount to a breach of my Fiduciary duty at the time when my employment contract was still in effect, I further submit that there was no contractual provision requiring me to seek any approval from the First Claimant during the ownership transitional phase.

Response [1] – It is incorrect to assert that I provided no justification for the transfers. My Amended Defence, paragraphs 7.13–7.17, explains that the five payments represented remuneration owed to me for February and March 2024, which I directed to the Fourth Defendant for the support of my daughter, principally her schooling expenses.

Response [1] – I deny being assisted by any of the Defendants to breach any of my duties, at the time of the alleged breach, the Second Claimant was my company and I built its reputation and good being by my own hard efforts, therefore diverting its clients, staff or any other good away from it would be an act that I business leader would never do and cause loose to my own company income.

Response [2] – the allegations that Retail Unit 130 was the Second Claimants and used by the Fourth Defendant is a misstatment of fact, the time when unit 130 was leased by the Second Claimant, the Fourth Defendant was not excited yet, its sole shareholder Mr. Rojin was a salaried employee at the Second Claimant and her sales of good were credited into the Second Claimant bank account for its good and not diverted to any other person.

Response [1] – I deny the assertions that there was no lawfulf entitlement, My Monthly Salary is an obligation of the Second Claimant to pay me pursuant to my full time employment contract, when I exercised my right and transferred my salaries to the Fourth Defendant bank account, the Fourth Defendant UBO is Ms Rojin herself therefore there is no more needed permissions or contract to justify these transactions.

Response [2] – the allegations that concealed is a misstatement of fact, the First Claimant by way of her appointed representatives reviewed the Company accounts before the conclusion of the contract and the formale share transferred, had they made any single enquiries at any point of time before 1 May, the Claimants pleading does not allege that they paid the purchase price and completed the transaction without seeing a single Account Statement or reviewing the company income against its expenses and transactions, I rely on the Bank Statement that the Claimants filed and relied on showing their own names and transactions regardless being Authorised Signatory of the Account proving they logged into the Company Account during the transitional phase and failed to exercise there are termination right as a stated in the share transfer agreement now such transactions are unlawful.

Response [3] – the Claimants are challenged to prove that the Fourth Defendant was funded by the Second Claimant.

Response [1] – I deny the allegations in their pleaded form without an evidence establishes the alleged breach of fiduciary duty, the Claimants omitted to plead anything about the inward transactions back from the Fourth Defendant account and are recorded in the same exact Bank Statements the Claimants rely on, a party pleading dishonesty at least have to plead honest details of the facts they rely on.

The Claimants are challenged to prove that the Fourth Defendant was funded by the Second Claimant.

Response [1] – I deny the allegations in their pleaded form without an evidence establishes the alleged breach of fiduciary duty, the Claimants omitted to plead anything about the inward transactions back from the Fourth Defendant account and are recorded in the same exact Bank Statements the Claimants rely on, a party pleading dishonesty at least have to plead honest details of the facts they rely on.

The Claimants are challenged to prove that the Fourth Defendant was funded by the Second Claimant.

Response [1] – I deny the allegations in their pleaded form without an evidence establishes the alleged breach of fiduciary duty, the Claimants omitted to plead anything about the inward transactions back from the Fourth Defendant account and are recorded in the same exact Bank Statements the Claimants rely on, a party pleading dishonesty at least have to plead honest details of the facts they rely on.

The Claimants are challenged to prove that the Fourth Defendant was funded by the Second Claimant.

Response [1] – I deny the allegations in their pleaded form without an evidence establishes the alleged breach of fiduciary duty, the Claimants omitted to plead anything about the inward transactions back from the Fourth Defendant account and are recorded in the same exact Bank Statements the Claimants rely on, a party pleading dishonesty at least have to plead honest details of the facts they rely on.

The Claimants are challenged to prove that the Fourth Defendant was funded by the Second Claimant.

Response [1] – The five transfers, totalling AED 80,000, were not gratuitous payments or funds used to finance the Fourth Defendant. They were paid from remuneration accrued to me under my Employment Contract dated 1 July 2021, which provided a monthly salary of AED 40,000.

The transfers represented outstanding remuneration for February and March 2024 and were directed to Hair by Rojin for child-support and schooling expenses. All five transfers occurred before the operational handover on 1 April 2024 and before completion of the share transfer.

At the relevant time, I was the Company’s manager and registered bank signatory. The Defence therefore denies that the payments lacked a lawful basis, were unauthorised, or constituted any breach of fiduciary duty. The Claimants must prove the absence of salary entitlement, the alleged lack of authority, and any resulting loss..

The Claimants are challenged to prove that the Fourth Defendant was funded by the Second Claimant.

Response [1] – The five transfers, totalling AED 80,000, were not gratuitous payments or funds used to finance the Fourth Defendant. They were paid from remuneration accrued to me under my Employment Contract dated 1 July 2021, which provided a monthly salary of AED 40,000.

The transfers represented outstanding remuneration for February and March 2024 and were directed to Hair by Rojin for child-support and schooling expenses. All five transfers occurred before the operational handover on 1 April 2024 and before completion of the share transfer.

At the relevant time, I was the Company’s manager and registered bank signatory. The Defence therefore denies that the payments lacked a lawful basis, were unauthorised, or constituted any breach of fiduciary duty. The Claimants must prove the absence of salary entitlement, the alleged lack of authority, and any resulting loss..

The Claimants are challenged to prove that the Fourth Defendant was funded by the Second Claimant.

Response [1] – .

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Response [1] – Fourth Defendant was established in 2021 early 2022 as per the DIFC Records, the First Claimant signed her offer to buy the Second Claimant in 2024 so mixing the events happed 2 years apart is a calculated conduct to not a mistake and is denied.

Response [1] – Fourth Defendant was established in 2021 early 2022 as per the DIFC Records, the First Claimant signed her offer to buy the Second Claimant in 2024 so mixing the events happed 2 years apart is a calculated conduct to not a mistake and is denied.

Response [1] – it is denied, the Fourth Defendant was managed, operated and controlled by it sole shareholder or eals the name and trade license would not have been change.

Response [1] – it is denied, the Second Claimant itself was established and funded by myself and buy the principale Hair Creators Fz Llc located in Dubai Knowledge Park. now allegations that I made any wrongdoing to cause damage to my own company while under my own management is illusionary and denied.

Response [1] – it is denied, the Second Claimant itself was established and funded by myself and buy the principale Hair Creators Fz Llc located in Dubai Knowledge Park. now allegations that I made any wrongdoing to cause damage to my own company while under my own management is illusionary and denied.

Response [1] – the Claimants are first required to prove their allegations of misappropriation of assets and of cost allegedly incurred for the setup of the Fourth Defendant before.

Response [1] – the Claimants are first required to prove their allegations of misappropriation of assets and of cost allegedly incurred for the setup of the Fourth Defendant before.