LEGAL NOTICE
**DRAFT — FOR REVIEW, COMPLETION AND ISSUANCE BY LEGAL COUNSEL ONLY**
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**FROM:**
Mrs. Saira Rizwan
[Nationality], Emirates ID No. [●]
Sole Owner / Licensee of **Green Roots Nursery** (Trade License No. [●], issued by [DED / relevant authority], Dubai)
Residing at: Villa [●], Al Furjan, Dubai, United Arab Emirates
**Through her legal counsel:**
[Law Firm Name]
[Address, Dubai] — [Telephone] — [Email]
**TO:**
Mr. Rizwan Ajmal
[Nationality], Emirates ID No. [●]
Residing at: Villa [●], Al Furjan, Dubai, United Arab Emirates
**Date:** [●] June 2026
**Subject: Final Notice — Cessation of Unlawful Conduct; Vacation of Residence; Withdrawal of Unfounded Claims; Accounting of Company Funds; Employment Matters**
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Dear Mr. Rizwan Ajmal,
We act for and on behalf of Mrs. Saira Rizwan ("our Client"), to whom you are married and by whose company, Green Roots Nursery ("the Company"), you are employed in the position of Managing Director under an employment contract dated [●].
We are instructed to put you on formal notice as follows:
1. Cessation of Threats, Intimidation and Violence
Our Client has instructed us regarding repeated acts and threats directed at her, including physical aggression, verbal abuse, threats against her life, threats of divorce made as instruments of coercion, and threats concerning the residency status of the children. Such conduct constitutes offences under **Federal Decree-Law No. 31 of 2021 (Crimes and Penalties Law)** and falls squarely within the scope of **Federal Decree-Law No. 13 of 2024 on Protection Against Domestic Violence**, which encompasses physical, psychological and economic abuse.
**You are required to immediately and permanently cease** all such acts, threats, intimidation and coercion, in any form whatsoever.
2. Cessation of Threatening Communications to Our Client's Family
Our Client has further instructed us regarding threatening communications made by you, by telephone and electronic means, to members of her family in Pakistan. You are reminded that threats and harassment conveyed through electronic means constitute offences under **Federal Decree-Law No. 34 of 2021 on Combatting Rumours and Cybercrimes**.
**You are required to immediately cease all contact** of a threatening, abusive or harassing nature with our Client's family members.
3. Vacation of the Residence
In light of the conduct described above, our Client is no longer prepared to share a residence with you. **You are required to vacate the residence at Villa [●], Al Furjan, Dubai, and arrange alternative accommodation within fourteen (14) days** of the date of this notice.
Should you fail to do so, our Client reserves the right to seek a Protection Order from the Public Prosecution pursuant to Article 11 of Federal Decree-Law No. 13 of 2024, which empowers the Prosecution to order your removal from the shared residence with immediate effect.
4. The Children
You are formally put on notice that **any attempt to remove the children from the United Arab Emirates, to cancel, transfer or otherwise interfere with their residence visas, or to retain or remove their identity documents**, against the will of our Client, will be met with immediate legal action, including urgent precautionary applications before the competent courts and a criminal complaint. Pursuant to **Article 116 of Federal Decree-Law No. 41 of 2024 (Personal Status Law)**, no parent may travel with a child outside the State without the written consent of the other parent or the permission of the court.
5. Withdrawal of Unfounded Claims to the Company
Green Roots Nursery is solely owned and licensed in the name of our Client, as conclusively established by the Trade License and constitutive documents of the Company. Your relationship with the Company is exclusively that of a **salaried employee** under the **Federal Decree-Law No. 33 of 2021 (Labour Law)**. Your repeated demands for fifty percent (50%) ownership of the Company have no basis in law or in fact.
**You are required to immediately and permanently withdraw such demands.** Any continued assertion of such claims, or any act in furtherance thereof, will be treated as an attempt at unlawful coercion and dealt with accordingly.
6. Accounting of Company Funds
Our Client's instructions are that, over the course of your employment, you have caused sums to be withdrawn from the Company over and above your contractual salary, without authorisation, documentation or accounting.
**You are required, within fourteen (14) days** of the date of this notice, to provide a full written accounting of all sums received or withdrawn by you from the Company, in any form, beyond your contractual salary, together with supporting documentation. Our Client expressly reserves the Company's right to pursue civil recovery of all unaccounted sums, together with a precautionary attachment over assets, should such accounting not be provided or prove unsatisfactory.
7. Employment
You are advised that the Company will be addressing your employment status separately and formally, in accordance with the terms of your employment contract and the provisions of Federal Decree-Law No. 33 of 2021. Nothing in this notice shall be construed as a waiver of any of the Company's rights in that regard.
8. Reservation of Rights
This notice is issued without prejudice to any of our Client's rights, all of which are expressly and fully reserved, including without limitation the right to file criminal complaints, to seek protection orders, to commence proceedings before the Personal Status Courts (including for maintenance, custody and related relief), and to pursue civil claims for recovery of Company funds — **without any further notice to you**.
Should you fail to comply with the requirements of this notice within the periods stated, our Client will proceed with all available legal remedies forthwith.
Yours faithfully,
**[Name of Advocate]**
[Law Firm Name]
Advocates & Legal Consultants, Dubai, UAE
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⚠ PRIVATE NOTES FOR YOU AND YOUR LAWYER — REMOVE BEFORE SERVICE
1. **Do NOT serve this until the urgent travel ban on the children has been filed.** This notice warns him about everything. The ban must already be in the immigration system before he reads paragraph 4.
2. **Banking first:** remove him as Company bank signatory and revoke any Power of Attorney before service — same week, before he is served.
3. **The villa/mortgage question:** confirm with your lawyer whose name the villa title and mortgage are in. If the property or mortgage is in his name (or joint), paragraph 3 needs reframing — the demand to vacate then rests on the Protection Order route rather than property rights. If in your name, paragraph 3 can be strengthened.
4. **Paragraph 7 (employment):** your lawyer may prefer the Company to issue a separate termination letter on Company letterhead, since the Company is a distinct legal person from you. This notice deliberately only signals it.
5. **Evidence discipline:** this draft deliberately does not disclose what evidence you hold (messages, witnesses, records, audit). Never reveal your evidence in a notice — demand, don't show.
6. **Service method:** through notary public or registered means via the law firm — never hand it to him yourself, and ideally not while you are alone in the house with him.
7. All [●] placeholders to be completed by counsel from original documents.