{"id":602984,"date":"2026-04-19T09:01:32","date_gmt":"2026-04-19T07:01:32","guid":{"rendered":"https:\/\/kohenavocats.com\/jurisprudences\/wjb-v-hjm\/"},"modified":"2026-04-19T09:01:32","modified_gmt":"2026-04-19T07:01:32","slug":"wjb-v-hjm","status":"publish","type":"kji_decision","link":"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/wjb-v-hjm\/","title":{"rendered":"WJB v HJM"},"content":{"rendered":"
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1. THE DISTRICT JUDGE: This is an application by the applicant ex-wife (whom, for ease of reference I shall refer to as \u201cW\u201d) made within proceedings for an order for enforcement of\u00a0a\u00a0court order by such means as the court considers appropriate for what is known as\u00a0a\u00a0Hadkinson order, namely an order that prevents the respondent, her former husband (\u201cH\u201d) from making or taking further steps in\u00a0a\u00a0case pending compliance with\u00a0a\u00a0court order. 2. In dealing with the matter, I had access to\u00a0a\u00a0court bundle. I received\u00a0a\u00a0position statement from Ms\u00a0de Navarro, who represents the applicant, and she also referred me to two cases, the de Gafforj [2018] EWCA Civ 2070\u00a0decision of Jackson LJ and the case of Tattersall v Tattersall [2018] EWCA Civ 1978, which is\u00a0a\u00a0decision of Moylan LJ. 3. H has not attended this hearing. He has\u00a0a\u00a0history of non-attendance and indeed non-compliance with orders, which is what has led to the making of this application. 4. When the matter was before DJ Mulkis on 13\u00a0September, he made\u00a0a\u00a0specific direction that H must attend the next hearing in person, because this is substantively\u00a0a\u00a0D50K application relating to enforcement and the court required him to attend to enable him to be orally examined as to his means. The further hearing was listed before me on 13\u00a0October and H failed to attend that hearing. He did send an email to the court the day before saying that he lives in the USA and as such the notice he had been given to attend in person along with the cost of\u00a0a\u00a0short notice flight, makes it physically not possible at this time, but he did plan to attend the UK towards the end of the year although nothing had been booked and he would be happy to join the hearing remotely. 5. We did in fact send him an invitation to join the link to enable him to attend the hearing remotely but he did not accept it, although he did make reference to the fact that the hearing being at 10\u00a0am meant that it was 3\u00a0am in his time. 6. I made directions leading to the hearing today and I specifically made\u00a0a\u00a0direction that if he wanted this hearing to be remote, he must make an application and statement in support at least 14\u00a0days prior to this hearing so, by 1\u00a0February. I directed that this hearing was to be an in person hearing and he was to attend. 7. I am satisfied that H was served with that order on 31\u00a0October 2023\u00a0in accordance with the directions I had given in relation to service, namely by email and no such application has been made, my clerk having checked the emails that we have received and apparently none having been received from H after 12\u00a0October. 8. An email from the solicitors acting for the applicant, which was sent with the bundle and position statements confirmed that they had spoken to him and he had confirmed that he would not be attending today and that has been reaffirmed by Ms\u00a0de Navarro this morning. She tells me that there has been contact and I am told there are some without prejudice discussions ongoing, but nevertheless, he has chosen not to attend this hearing today. 9. The history of the matter is that on 29\u00a0November 2017\u00a0HHJ O'Dwyer made\u00a0a\u00a0final financial remedies order in proceedings between the parties. In his decision and the order he recorded that his findings were that there were insufficient funds to make provision to meet the applicant's needs which he put at \u00a36,000\u00a0per month. He made an order of periodical payments for \u00a33,500\u00a0per month and it is\u00a0a\u00a0joint lives order or until H\u2019s retirement at aged 67, together with CPI adjustment payments to be made on the 28th day of the month. 10. On 5\u00a0April 2023, W issued\u00a0a\u00a0D50K seeking enforcement by such means as the court considered appropriate and in particular\u00a0a\u00a0third party debt order against\u00a0a\u00a0company bank account with NatWest. At that time the arrears were \u00a335,282.64\u00a0and the payment, taking into account the CPI adjustment, had increased to \u00a33,851.93\u00a0from 28\u00a0April 2022. At that time H had paid \u00a33,670\u00a0in April 2022\u00a0and then made no payments thereafter. 11. On 2\u00a0May 2023\u00a0the court issued the standard order when receiving applications and listing them for hearing, that he should complete his ES1\u00a0and attend\u00a0a\u00a0hearing on 19\u00a0June 2023. That hearing took place before HHJ Evans-Gordon and he attended remotely. Her order reflects that he agreed to reinstate maintenance from 28\u00a0June 2023\u00a0until the conclusion of the proceedings. I understand that he informed the court that the reasons why payments had not been made was because of\u00a0a\u00a0judgment debt, but that that had now been resolved and he was able to make payments going forward. He also gave an assurance that \u00a343,000\u00a0remained in the NatWest account for the company and that that money would not be utilised pending further hearing. 12. The court adjourned the application to enforce on that basis, made\u00a0a\u00a0direction that he was to serve his Form E1\u00a0by 17\u00a0July 2023\u00a0and listed the matter for further hearing, including reserving costs. 13. On 17\u00a0July 2023, H made an application to vary paragraph 21\u00a0of the original order of 29\u00a0November 2017. That document is quite interesting. It is not in\u00a0a\u00a0Form A. He made it on\u00a0a\u00a0D11\u00a0and he set out the reasons why he was applying for the variation and there were two reasons given. Firstly was that the order had been made on the basis that W would be earning \u00a320,000\u00a0per annum and he thought that by now she ought to have been doing that, and secondly, that she is cohabiting. There is no reference in that D11\u00a0to the application being made because he cannot afford it. 14. On 6\u00a0September, W made her application for\u00a0a\u00a0Hadkinson order preventing him from proceeding with his application to vary unless he cleared the arrears, and for\u00a0a\u00a0penal notice to be endorsed on the directions to file an E1. 15. On 13\u00a0September 2023\u00a0DJ Mulkis heard this matter. He again reinforced the direction that H was to file an E1\u00a0as he had not done so, and that was to be done by 28\u00a0September 2023. He relisted the hearing before me on 13\u00a0October, again made\u00a0a\u00a0costs order in relation to the hearing in June and that hearing totalling \u00a313,687.20\u00a0and, as I have already said, directed that the next hearing was to attend in person. He also made\u00a0a\u00a0final third party debt order against the company bank account with NatWest plc for \u00a353,175.80. 16. As I have said, at the hearing on 13\u00a0October H did not attend. He had filed by then an E1\u00a0in compliance with the order of DJ Mulkis, but it was deficient and I made\u00a0a\u00a0further order that he was to file\u00a0a\u00a0fully completed E1\u00a0with all attendant documents by 27\u00a0October 2023. That order had\u00a0a\u00a0penal notice attached to it and, as far as I am aware, it has not been complied with. As I said, I am satisfied that that order was served on 31\u00a0October 2023. 17. He has apparently paid \u00a34,000\u00a0in November and December 2023\u00a0but he is substantially in breach and the arrears as of today's date, I understand, stand at \u00a361,901.62. 18. There is no doubt that the order that the court is being asked to make is\u00a0a\u00a0draconian one and this was enforced by Peter Jackson LJ who confirmed in de Gafforj v de Gafforj the description of such an order made by Sir Ernest Ryder in the case of Assoun v Assoun [2017] EWCA Civ 21, namely: "Such an order is draconian in its effect because it goes directly to\u00a0a\u00a0litigant's right of access to\u00a0a\u00a0court.\u00a0 It is not and should not be\u00a0a\u00a0commonplace.\u00a0 As developed in case law, it is\u00a0a\u00a0case management order of last resort in substantive proceedings (for example for\u00a0a\u00a0financial remedy order) where\u00a0a\u00a0litigant is in wilful contempt rather than\u00a0a\u00a0species of penalty or remedy in committal proceedings for contempt." 19. He also made clear that such an order is also not\u00a0a\u00a0species of what has been described as "enforcement by the back door". 20. In his judgment Jackson LJ set out the conditions that would be necessary before such an order could be made, namely that the respondent is in contempt; that the contempt is deliberate and continuing; as\u00a0a\u00a0result, there is an impediment to the court of justice; and there is no other realistic and effective remedy. The order has to be proportionate to the problem and go no further than necessary to remedy it. His decision also refers to the decision of Bodie J in Mubarak v Mubarik [2006] EWHC 1260\u00a0(Fam) in which he said that non-payment in breach of\u00a0a\u00a0maintenance order is in itself\u00a0a\u00a0contempt of court regardless of ability to pay and that questions of ability to pay come into play when the court decides whether and how to act on the contempt. Also, as to the third condition, namely whether there is an impediment to the course of justice, this is likely to include what was described by Sir Mark Potter in Laing v Laing [2005] EWHC (Fam) that it was "making it more difficult for the court to ascertain the truth or to enforce the orders that it makes." 21. There can be no doubt that H is in contempt of court. There are numerous examples in the history of these proceedings where he has failed to comply with court orders, not only the original ones, the payment of maintenance, but also the orders within these proceedings for disclosure and to attend for questioning. These failures to comply have put the applicant at significant cost because there have had to be more hearings than would otherwise have been necessary. This is the fourth hearing and the matter will not conclude today. 22. There can equally be no doubt that the contempt is deliberate and continuing and that is exampled by H\u2019s failure to attend today. He was given clear notice that he was required to attend in person. He was given sufficient time to make the necessary arrangements. He was served with the order giving the notice of hearing on 31\u00a0October. He was also given\u00a0a\u00a0means by which to apply to vary that direction if he wished to do so, but he failed to avail himself of that. That is in addition to his ongoing contempt in relation to failing to comply with the original order as to maintenance, despite having made sporadic payments. 23. Is there then an impediment to the course of justice? Ms\u00a0de Navarro says that there is. She refers me to the applicant's statement in support of this application, which is in fact attached to the application itself. She has exhausted her savings, not only paying for her income needs but also paying for legal costs and she is now having to rely on credit cards and borrowing. I am told that she is, and I can understand why, extremely stressed by these proceedings. Clearly there will be an impediment to justice in the event that she is unable to pursue matters with the assistance of legal representation, given the fact that the respondent, H, is in the United States of America, and his failure to comply with orders to date. 24. The decision in de Gafforj v de Gafforj related to two breaches. One was in relation to\u00a0a\u00a0legal services payments order, and one was in relation to non-payment of maintenance. Jackson LJ slightly differentiates between the two at paragraph 17\u00a0of his judgment when he says: "Does the order sought by the wife go further than necessary? Yes, but only to\u00a0a\u00a0marginal extent. I would differentiate between the unpaid costs and maintenance on the one hand and the unpaid legal services payments on the other. The latter impacts in the most direct way possible upon the course of justice; the position of the former is less clear. I am far from dismissing the wife's concerns about the effect upon her everyday life of the abrupt and arbitrary removal of her income stream, and the knock-on effect on her ability to participate in the proceedings, and I would not want to be understood as saying that there are no circumstances in which such\u00a0a\u00a0contempt could found an order of this kind; but in this case it does not compare to the strikingly direct impediment to the course of justice represented by the contempt in relation to the litigation services payment order \u2026" 25. Ms\u00a0de Navarro says that this case is differentiated from de Gafforj because in this case there is no legal services payments order. A pragmatic decision was taken not to pursue such an application because of the history and the costs and so, in effect, the maintenance is being used to fund the cost of legal proceedings which otherwise might have been the subject of\u00a0a\u00a0LSPO order, namely there is one pot of money and this wife is having to use it to fund living expenses and legal costs and therefore there clearly is an impediment to justice by H's failure to make the payments. I accept and I agree with her argument in that respect and I am satisfied that breach of this order, coupled with breaches of all the other directions orders that have been made, are such that there will be an impediment to justice if the order is not enforced and the order that is being sought made. 26. But I must also consider the effect of the impediment to justice on H if he is unable to gain access to the court in circumstances where he is applying to vary the order that is being sought to be enforced. In circumstances where somebody is told that they cannot pursue an application to vary because they cannot afford to pay the order unless they pay the arrears under the order, then it puts them in\u00a0a\u00a0difficult position. However, I am satisfied that is not the case here and I make specific reference to the D11 on which H has made his application to vary. He has not made this application on the basis that he says he cannot afford to pay it. He made the application on the basis that W would have \u00a320,000\u00a0per annum which should be offset against maintenance and also that she is cohabiting. 27. So far as the former is concerned, he is correct in his broad analysis, but on looking at the judgment of HHJ O'Dwyer, that is not what was said. In the judgment HHJ O'Dwyer made\u00a0a\u00a0finding that W\u2019s needs were \u00a36,000\u00a0per month and that they could not be met by H in full as there were insufficient funds at that time to meet such an order. He made the order he did knowing that there would be\u00a0a\u00a0shortfall. He then went on to say at paragraph 83\u00a0of his judgment that he was satisfied that within the next 12\u00a0months H would have an income of \u00a3100,000\u00a0per annum and that W would have an income of around \u00a320,000\u00a0per annum and so what he said was that there was no reduction in his order in 2018\u00a0when he considered that W could be in work because by that time he considered that H would have increased his income and that they each cancelled each other out. The income that W was going to receive filled the shortfall in what he assessed was the difference between her reasonable needs and what H could afford to pay. H\u2019s argument in that respect is wrong. 28. The court does not know about the position in relation to the allegation of cohabitation, but the application is not based on inability to pay and it is not for\u00a0a\u00a0party to take it upon himself to stop making payments of an order pending\u00a0a\u00a0determination by the court as to whether or not they should do so and whether the order should be suspended pending the application to vary. In this respect I am aware of the decision in Tattersall v Tattersall which makes it clear that applications to vary do not prevent enforcement but in any event H has not attended this hearing or put forward any argument that enforcement should be postponed pending the outcome of his application for variation. I am satisfied that this is not\u00a0a\u00a0case where there should be\u00a0a\u00a0stay pending enforcement, because of the reasons given as to why the application is made. 29. Although H says that\u00a0a\u00a0bankruptcy petition has been issued, Ms\u00a0de Navarro tells me that\u00a0a\u00a0search of the register has not disclosed one and he has provided no further information or detail. 30. So in conclusion whilst I accept that this is\u00a0a\u00a0draconian step to take and that there will be many cases where\u00a0a\u00a0court would not make the order that is being sought today in circumstances where there is an application to vary because of the risk of putting\u00a0a\u00a0respondent in an impossible position, in circumstances where the application to vary is not made on the basis of ability to pay and bearing in mind in mind the history of non-compliance with this matter, I am quite satisfied that there is an impediment to the course of justice to W if the court does not make the order sought. 31. Finally then is there any other realistic and effective remedy? The answer to that appears to be no. H is residing in the United States of America. He has very few, if any, assets here. I am satisfied that he deliberately misled the court as to the position in relation to the \u00a343,000\u00a0which he gave assurances in June 2023\u00a0was in the company's NatWest account as the bank accounts and statements for that account disclosed with his E1 clearly show that on the date in question he had approximately \u00a35,000\u00a0in the account. So, I am satisfied that there is no other realistic and effective remedy, that the order is proportionate to the problem and goes no further than necessary to remedy it. I make\u00a0a\u00a0Hadkinson order preventing H from pursuing his application to vary unless and until he makes\u00a0a\u00a0payment to W of \u00a361,901.62\u00a0in relation to the arrears and the sum of \u00a313,687.20\u00a0in relation to the costs that are outstanding as at today's date. I include the costs of \u00a37,252.80\u00a0as well. (After further submissions) JUDGMENT ON COSTS 32. I am now asked to make an order of the costs in relation to this hearing. An N260\u00a0has been served on 12\u00a0February and is also included in the bundle that was served on 13\u00a0February, so I am satisfied that H has notice of the costs that are being claimed. 33. Ordinarily, claims for costs are dealt with under the provisions of FPR 28\u00a0and that of course provides for the starting point to be no order for costs but for the court to be able to make\u00a0a\u00a0different order in the event that there has been, in effect, litigation conduct. That provision refers to and relates to financial remedies applications. A D50K is not included within the definition of the financial remedy applications and so the no order as to costs starting point does not apply. The rules to be applied are the Civil Procedure Rules, and in particular CPR 44.2\u00a0with the exception of 44.2(2), which is the rule that, if\u00a0a\u00a0court decides to make an order about costs, the general rule is that the unsuccessful party will be ordered to pay the costs of the successful party, but the court may make\u00a0a\u00a0different order. That presumption does not apply, but nevertheless the courts have made it clear in decisions, including that of Butler-Sloss LJ in Gojkovic v Gojkovic (No.2)[1991]2 FLR that you have to start somewhere and in her view this remained the correct starting point although it may be displaced more easily in family law cases. Obviously when applying what is known as the clean sheet, the court has to look at all the circumstances of the case. 34. CPR 44.2\u00a0(4) makes it clear that in deciding what order, if any, to make about costs, the court has to have regard to the conduct of the parties and whether\u00a0a\u00a0party has succeeded on part of its case, even if they have not been successful on the whole, and that conduct includes conduct before and during the proceedings. Also whether it was reasonable for\u00a0a\u00a0party to raise, pursue or contest\u00a0a\u00a0particular allegation or issue and the manner in which they have done so. 35. There can be no doubt that H's conduct is such that he should be responsible for W's costs of this hearing today for the reasons that I have already set out in my judgment, namely the ongoing breaches of the order and his failure to engage in the court process or to attend today, so I am satisfied that it is appropriate to make an order as to costs. 36. The N260\u00a0is for \u00a315,374. That was based on solicitor attending with counsel. Solicitors took the very sensible approach that, once they knew that H was not going to be attending, that they would not attend and so Ms\u00a0de Navarro has kindly recalculated the schedule to exclude their attendance costs and disbursements and the figure I am told is \u00a310,932.60. 37. I am satisfied that in view of the amount of work needed to be done, the importance of this decision and the fact that this was originally listed for three hours, that those costs are reasonable and proportionate, and so I make\u00a0a\u00a0summary assessment of costs of \u00a310,932.60\u00a0to be paid in 14\u00a0days and I add those to the sum that is due to be paid under the Hadkinson order. Epiq Europe Ltd hereby certify that the above is an accurate and complete record of the proceedings or part thereof. Lower Ground, 46\u00a0Chancery Lane, London WC2A 1JE Email: civil@epiqglobal.co.uk<\/p>\n<\/div>\n

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Sources officielles :<\/strong> consulter la page source<\/a><\/p>\n

Open Justice Licence (The National Archives).<\/em><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

1. THE DISTRICT JUDGE: This is an application by the applicant ex-wife (whom, for ease of reference I shall refer to as \u201cW\u201d) made within proceedings for an order for enforcement of a court order by such means as the court considers appropriate for what is known as a Hadkinson order, namely an order that prevents the respondent, her former…<\/p>\n","protected":false},"featured_media":0,"template":"","meta":{"_crdt_document":""},"kji_country":[7608],"kji_court":[8063],"kji_chamber":[],"kji_year":[8677],"kji_subject":[7638],"kji_keyword":[7919,15805,8052,7916,7707],"kji_language":[7611],"class_list":["post-602984","kji_decision","type-kji_decision","status-publish","hentry","kji_country-royaume-uni","kji_court-family-court-b-district-and-circuit-judges","kji_year-8677","kji_subject-famille","kji_keyword-application","kji_keyword-attend","kji_keyword-costs","kji_keyword-hearing","kji_keyword-order","kji_language-anglais"],"yoast_head":"\nWJB v HJM - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/wjb-v-hjm\/\" \/>\n<meta property=\"og:locale\" content=\"zh_CN\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"WJB v HJM\" \/>\n<meta property=\"og:description\" content=\"1. THE DISTRICT JUDGE: This is an application by the applicant ex-wife (whom, for ease of reference I shall refer to as \u201cW\u201d) made within proceedings for an order for enforcement of a court order by such means as the court considers appropriate for what is known as a Hadkinson order, namely an order that prevents the respondent, her former...\" \/>\n<meta property=\"og:url\" content=\"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/wjb-v-hjm\/\" \/>\n<meta property=\"og:site_name\" content=\"Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:label1\" content=\"\u9884\u8ba1\u9605\u8bfb\u65f6\u95f4\" \/>\n\t<meta name=\"twitter:data1\" content=\"18 \u5206\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\\\/\\\/schema.org\",\"@graph\":[{\"@type\":\"WebPage\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/wjb-v-hjm\\\/\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/wjb-v-hjm\\\/\",\"name\":\"WJB v HJM - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris\",\"isPartOf\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/#website\"},\"datePublished\":\"2026-04-19T07:01:32+00:00\",\"breadcrumb\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/wjb-v-hjm\\\/#breadcrumb\"},\"inLanguage\":\"zh-Hans\",\"potentialAction\":[{\"@type\":\"ReadAction\",\"target\":[\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/wjb-v-hjm\\\/\"]}]},{\"@type\":\"BreadcrumbList\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/wjb-v-hjm\\\/#breadcrumb\",\"itemListElement\":[{\"@type\":\"ListItem\",\"position\":1,\"name\":\"Home\",\"item\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/\"},{\"@type\":\"ListItem\",\"position\":2,\"name\":\"Jurisprudences\",\"item\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/\"},{\"@type\":\"ListItem\",\"position\":3,\"name\":\"WJB v HJM\"}]},{\"@type\":\"WebSite\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/#website\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/\",\"name\":\"Kohen Avocats\",\"description\":\"Ma\u00eetre Hassan Kohen, avocat p\u00e9naliste \u00e0 Paris, intervient exclusivement en droit p\u00e9nal pour la d\u00e9fense des particuliers, notamment en mati\u00e8re d\u2019accusations de viol. Il assure un accompagnement rigoureux d\u00e8s la garde \u00e0 vue jusqu\u2019\u00e0 la Cour d\u2019assises, veillant au strict respect des garanties proc\u00e9durales.\",\"publisher\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/#organization\"},\"potentialAction\":[{\"@type\":\"SearchAction\",\"target\":{\"@type\":\"EntryPoint\",\"urlTemplate\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/?s={search_term_string}\"},\"query-input\":{\"@type\":\"PropertyValueSpecification\",\"valueRequired\":true,\"valueName\":\"search_term_string\"}}],\"inLanguage\":\"zh-Hans\"},{\"@type\":\"Organization\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/#organization\",\"name\":\"Kohen Avocats\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/\",\"logo\":{\"@type\":\"ImageObject\",\"inLanguage\":\"zh-Hans\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/#\\\/schema\\\/logo\\\/image\\\/\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/wp-content\\\/uploads\\\/2026\\\/01\\\/Logo-2-1.webp\",\"contentUrl\":\"https:\\\/\\\/kohenavocats.com\\\/wp-content\\\/uploads\\\/2026\\\/01\\\/Logo-2-1.webp\",\"width\":2114,\"height\":1253,\"caption\":\"Kohen Avocats\"},\"image\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/#\\\/schema\\\/logo\\\/image\\\/\"}}]}<\/script>\n<!-- \/ Yoast SEO Premium plugin. -->","yoast_head_json":{"title":"WJB v HJM - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris","robots":{"index":"index","follow":"follow","max-snippet":"max-snippet:-1","max-image-preview":"max-image-preview:large","max-video-preview":"max-video-preview:-1"},"canonical":"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/wjb-v-hjm\/","og_locale":"zh_CN","og_type":"article","og_title":"WJB v HJM","og_description":"1. 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