Frosty nursery pay

Subject
Frozen incarceration lawsuit tunnel wage nursery

It is on / / / / 2020
Upon request first: - Mrs. / ........................ and resident ................. .......................- Cairo . He has chosen a place for him, the institution "Dar Al Qanoon Group for Advocacy, Arbitration and Training," represented by Professors / Rami Saeed Tawfiq and his fame (Rami Al Sejiny) - Tamer Adel Mahmoud Al Sharshaby (famously Tamer Al Sharshaby) - Hani Adel Mahmoud Al Sharshaby (known as Hani Al Sharshaby) - Mohamed Ali Hassan - Ibrahim Sayed Nair and his fame (Ibrahim Nair) - Mahmoud Ali Radwan and his fame (Mahmoud Al-Batouri) - Ibrahim Abdel Rahman Al-Fiqi - Diane Numan Mustafa - Muhammad Khaled Mahmoud - Mahmoud Abdel-Wahab Abdel Halim Al-Mahamoun, located in 3 A Hob El Din Street - Al Sefarat Neighborhood - Nasr City - Cairo.
.
I am a District Court record that has moved and announced: -
Mr. / ...................................... residing in ........ ......................................--
Addressed with /
I announced the following
The student was the wife of the one who was declared to him according to the valid legal marriage contract dated on ..... / ...... / ......... and he entered with her and married her with husbands and provided with her on the marital bed with the children (.... ... born in ... / ..... / .......), (......... born ...... / ...... ... / ......), (............... born ..... / ........ / ........ ..); On the date .... / ...... / ...... the student was divorced from the one who was declared to him with a mortal shot, as a result of marital disputes and the impossibility of ten between them.
 Whereas the student previously instituted case No. ....... for the year ............. Nasr City family in order to judge her with a house wage and a nursery fee for the young (........ - .. ........ - .........) and in a session .... / ..... / ....... (writing the verdict)
Whereas the verdict the above statement did not accept from both sides of the litigation, the plaintiff appealed it and her appeal was registered under the number ......... for the year ........ s High Cairo Appeal and the defendant appealed against the same judgment and his appeal is registered under No. ... ... for a year ...... s High Cairo Appeal; In a session ...... / ..... / ......... the Cairo High Court of Appeal ruled on the two appeals with its verdict and the judge pronounced it
(Writing the pronouncement of the appeal judgment).
Whereas, from the date of the judgment of the court of the first degree, passing through a judgment of the second degree, and until the filing of the current lawsuit, the defendant did not perform what the court ruled by the first degree and was confirmed by the Court of Appeal with regard to the consideration for the custody wage in the amount of ............... ................; Whereas, it has been frozen in the custody of the declared to the student under the aforementioned judgment, for the period from .... / .... / .......... until the current case is registered with a total amount of ....... C (eight thousand and three hundred Egyptian pounds only) as frozen custody wage for the period from ..... / .... / ..... which is the date of filing the lawsuit from the beginning until the filing of this case by ......... ... a month multiplied by ............ a sum other than what is prostrate from an alimony debt until the judgment is issued in the current lawsuit; Although the plaintiff tried repeatedly and alerted the defendant, he refused and abstained without an acceptable or legal justification.
The husband is obligated to pay the wife’s custody fee in return for keeping the children, raising them, and confining herself for that custody.
(Entourage of Ibn Abdeen - Part Three - Page 561)
Perhaps that wage is very similar to alimony, and then it is correct to count part of his small alimony and obligate his father if he does not have money, and if he has money then his father does not have to do anything from it except to donate
(Article 388 of the Book of Islamic Rulings by Qadi Pasha)
As for the due date of that wage, the principle is that it is not due except from the date of agreement on it or the judge’s judgment because it is like all the wage debts. However, the mother has been excluded from this original. She is entitled to the nursery fee from the actual date of custody without agreement or judging by the maturity of the breastfeeding wage from the actual date of breastfeeding. ; The reason for this exception lies in the fact that the mother's compassion for her young child pushes her to custody without waiting for an agreement or judiciary, and accordingly the opinion and jurisprudence have settled.
(Counselor Azmi Al-Bakri - Encyclopedia of Jurisprudence, Judiciary and Legislation in Personal Status - Part Three, Page 168)
Whereas, Article 76 bis of Law No. 1 of 2000 regulated personal status matters
If the convicted person refuses to implement the final judgment issued in the lawsuits for expenditures, wages and the like, the convicted person may refer the matter to the court that issued the judgment or in whose district the execution is to be carried out, and when it is proven to it that the convict is capable of performing what was ordered by his order to pay even if he did not comply Sentenced to imprison him for a period not exceeding thirty days.
If the convicted person performs the judgment or brings a guarantor who is accepted in his favor by the judgment, then he will be released, all without prejudice to the right of the convicted person to implement by normal means.
Whereas the student had repeatedly requested the advertiser amicably to him and urged him to pay, but he refused without a legal justification or legal basis, which led her to resort to the Nasr City Family Disputes Settlement Office and the application was registered with No. 3066 for the year 2020 settlements; This is what led the student to initiate that lawsuit to judge her with her requests.
Accordingly
I, the aforementioned reporter, moved and announced to him the advertiser of the origin of this petition and handed him a copy of it and assigned him to appear before the Nasr City family court, the circuit () whose headquarters are ........ - ............ -. ........... - and that is in its session that will be held on the corresponding day / / starting from eight o'clock in the morning and afterwards for pleading and to hear the ruling that he pays the student an amount ............... EGP (eight thousand and three hundred Egyptian pounds only) as frozen custody wage for the period from ..... / ...... / ......... which is the date of filing the lawsuit from the beginning until the filing of this case by .... ... a month multiplied by ......... 0 EGP with the latest alimony debt until the issuance of the judgment in the current lawsuit; with the defendant's imprisonment upon completion