SHEWE TH :

1.

THAT ALL THAT piece or parcel of ground situate lying

and being at Kowloon in the Colony of Hong Kong and registered in the Land

Office as KOWLOON INLAND LOT NO.9232 (formerly as SECTION B

OF SUBSECTION 1 OF KOWLOON INLAND LOT NO.447 ) Together

with the messuage or tenements erections and buildings thereon known as

No. 962 Canton Road (hereinafter called

vested in Yu Wo Lung (

the said property ") was originally

the lawful husband of your Petitioner

Subject to and with the benefit of the Conditions of Regrant registered in the

Land Office as Conditions of Regrant No. 8721.

2.

THAT prior to his death the said Yu Wo Lung deceased was

a Canadian resident residing permanently in Canada,

3.

4.

THAT prior to his death the said Yu Wo Lung deceased had

by a Power of Attorney dated the 2nd day of December, 1957 appointed your

Petitioner then of No. 36A, Pak Tai Street, 5th Floor, Kowloon in the said Colony of Hong Kong to be his attorney to manage or otherwise deal with

all his properties assets estates and interests in the Colony of Hong Kong.

THAT on the 23rd day of June 1964 your Petitioner in her

capacity as the lawful attorney of Yu Wo Lung surrendered the said Section B of Subsection 1 of Kowloon Inland Lot No. 447 to the Crown for obtaining

the Conditions of Regrant of the property to be known as Kowloon Inland

Lot No. 9232 subject to the payment of a premium of $149, 200.00 and

interest to Government by 20 instalments in the following manner :-

(a) 1st instalment of $16,825.00 to be paid within 28 days

of the date of signing of the said Conditions of Regrant.

(b)

2nd instalment of $15,825.00 to be paid on the 23rd day

of June 1965.

(c)

The remaining eighteen annual instalments of $15,825.00

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to be paid on the 23rd day of June in each succeeding year.

THAT your Petitioner had paid on behalf of the said Yu Wo

Lung the first instalment of the said premises to Government on the 17th

day of November 1964.

6.

THAT your Petitioner moved to a new address at No. 67,

Lai Chi Kok Road, 3rd Floor, Flat D, Kowloon aforesaid in early 1965

and had missed any demand note for the second instalment payment of

premium for the said property sent by Government,

7.

THAT your Petitioner emigrated to Canada to join her

husband the said Yu Wo Lung in early 1966 and had taken up residuence

in Canada since then.

8.

THAT before leaving for Canada your Petitioner entrusted

the management and the rental affairs of all the properties of her husband

in the Colony of Hong Kong to a certain YU HUNG HUP (

余雄洽

of Cheong Shing Investment, Loan & Exchange Co. Ltd. at Nos. 52-54,

Wing Lok Street, Victoria in the said Colony of Hong Kong and asked him

to keep her informed of the matter.

9.

THAT neither your Petitioner nor her husband has heard

anything from the said Yu Hung Hup.

10.

THAT both your Petitioner and her husband resided abroad

all the time and were never informed of any default in payment of the said

instalment premium.

11.

THAT most unfortunately your Petitioner's husband the said

Yu Wo Lung suffered from Bladder disease and was bed-ridden which

required the constant care and attention of your Petitioner. No particular

attention was paid to the said property and that your Petitioner and her

husband were under the impression that the rentals received in respect

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of the said property had been applied for payment of the instalments of

the said premium.

12.

THAT your Petitioner's husband the said Yu Wo Lung executed

his last Will and Testament in the Chinese Language dated the 1st day of

October 1970 at 1188, St. Urbain Street, Montreal 129 P. Q. Canada

whereby he appointed your Petitioner the sole executrix and beneficiary

thereof.

13.

THAT the said Yu Wo Lung died on the 11th day of December

1970 in the City of Montreal Canada without having altered or revoked his

said last Will. Your Petitioner was tied up with all the matters in Canada

after the death of her husband. It left her no time to look into every matter

in detail.

14.

THAT not until August 1973 your Petitioner was able to return

to Hong Kong for the purpose of applying for a grant of Probate in respect

of the estate of the said Yu Wo Lung deceased in Hong Kong and was

subsequently informed by his solicitors Messrs. Woo, Kwan, Lee & Lo

that the said property was re-entered by the Crown under a Notice of

Re-entry registered in the Land Office by Memorial No. 517618 dated

the 20th day of January 1966. Your Petitioner or her husband was never

aware of such re-entry.

15.

THAT your Petitioner is now in the process of applying

to the Supreme Court of Hong Kong for a grant of Probate in the estate

of the said Yu Wo Lung deceased through Messrs. Woo, Kwan, Lee & Lo.

The Estate Duty Commissioner has assessed the value of the property

in question as $190,000.00. Your Petitioner is ready willing and able

to pay the said estate duty.

16.

THAT your Petitioner being the sole beneficiary of the

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