Main Date: 28 Nov 2007 01:57:05 From: Sam Sloan Subject: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt Sam Sloan 1664 Davidson Ave., Apt. 1B Bronx NY 10453-7877 Tel. 917-507-7226 samsloan@samsloan.com ember 27, 2007 Referee Mildred Negron Queens County Family Court 151-20 Jamaica Avenue Jamaica NY 11432 Re: Sloan vs. Rankoth, V-11657-05 Rankoth vs. Sloan, O-18182-05 Dear Referee Negron, You may recall that the court ordered that I would have one visitation with my daughter Anusha, now aged 15, but then it was reported that although Anusha came to the scheduled visitation she refused to see me. However, I have since learned from other sources that Anusha did not come alone. She was accompanied by a representative of Dorschen Leidholdt’s office, although not by Dorschen Leidholdt herself. My appellate counsel, Pauline Braun, informs me that this was entirely improper. It was OK for Anusha to be accompanied by her mother, another close relative or even by the Guardian Ad Litem. However, Dorschen Leidholdt has been in an adversary relationship with me for 16 years since June 1991 and she had been manipulating and controlling my children and their mother for that entire time. Indeed, Dorschen Leidholdt tried to abortion my daughter Anusha, since Dayawathie was pregnant with Anusha when Dorchen first got involved with her in 1991. Dayawathie has often told me that the only thing that saved Anusha’s life was that Dorschen could not arrange the Medicaid in time to pay for the abortion and by the time the Medicaid was available the pregnancy was too far advanced for the abortion. However, Dorschen Liedholdt did abortion our next baby. Dayawathie became pregnant with our next baby in 1995 and Dorshen had that baby abortioned on July 7, 1995. The abortion of Sam Sloan's child took place on July 7, 1995. Almost immediately thereafter, Dayawathie became pregnant from a passing stranger whose name and identity is still unknown. That child, Geeta Kamal Rankoth, was born on June 9, 1996, just 11 months after Dayawathie's child by Sam Sloan had been aborted. By that time, the father of Geeta had long since disappeared. Geeta, incidentally, is a bright and delightful child. As to how Dorschen Leidholdt is able to control Dayawathie to the extent of moving her about, directing where she should live and even deciding whether she should have an abortion or not, it is a carrot and stick operation. Dayawathie has been under constant investigation by ACS since she first arrived in New York in June 1991. She was also being investigated by Childrens Services in Lynchburg Virginia before she got here. She has also been threatened with eviction proceedings. Dorschen Leidholdt appears and defends her in all these cases. I have some evidence that she actually helps brings these cases that she then defends her in. Dorschen Leidholdt had my two sons, Michael and George, kidnapped away from me in May 1995. We were living in San Francisco with the knowledge and consent of Dayawathie who was trying to keep this fact a secret from Dorschen Leidholdt. This story goes on and on. I could write a book about it and perhaps I will some day. What is especially disturbing about Dorschen Leidholdt is that she is an outspoken advocate of lesbianism. I am a strong believer that people have a right to adopt their own lifestyles and to fulfill their own dreams, whatever they may be. I have no objection, none what ever, to Dorschen Leidholdt being a lesbian. I do object, however, to her having any involvement in raising my daughter. If you will read her book, "The Sexual Liberals and the Attack on Feminism", by Dorschen Leidholdt, you will see her advocating lesbianism and claiming for example that one-quarter of all girls under age ten have been sexually molested usually by their own fathers. This is a sick statement for which she offers no proof. Dorschen Leidholdt has also been personally involved with infamous pornographers including Linda Lovelace and Larry Flynt. I want this woman kept away from my children and I have every right to insist on that. While this case was pending before Judge Modica, I made several motions to disqualify Dorschen Leidholdt and her representatives, including Jill Zuccardy and Alexander Karam, from appearing in this case. These motions were properly served and submitted in open court by handing them up to the judge. I went to the court last week to look at the file and found that there was no record of these motions. They were not in the file or on the docket. Apparently, Judge Modica must have trashed them. Apparently, needed to file them with Mr. Sternberg on the first floor. I did not know about that. I naturally assumed that handing them up to the judge in open court was an effective way to file these motions. I ask that you consider these motions now. Also, I ask that you reschedule my visitation with Anusha and direct Dorschen Leidholdt and her representative to stop interference with this case. Every time I bring up Dorschen Leidholdt I am told that she is not in this case. But, she is in this case. Dorschen Leidholdt is the 800 pound gorilla in the room. She controls Dayawathie Rankoth. She hires and fires Jill Zuccardy, Paul Weiss and the other attorneys who appear in this case, and every time I try to ask Dayawathie a question about Dorschen Leidholdt the attorneys object on the grounds of attorney-client privilege, yet the name of Dorschen Leidholdt has never appeared on any of these cases. I have never met or seen Dorschen Leidholdt. I have no idea what she looks like. I know her role in this case because Dayawathie talks about her and often complains about her all the time. This case will never be resolved and will go on forever as long as Dorschgen Leidholdt is allowed to hide behind a screen while controlling and manipulating everything. Accordingly, I am renewing my motions previously filed with Judge Modica to remove Dorschen Leidholdt from this case. I also object that every time that Jill Zuccardy announces her appearance in this case she states that she is representing Sanctuary for Families. Center for Battered Women’s Legal Services. This creates the misleading impression that Dayawathie Rankoth is a battered woman. However, there is no allegation, much less evidence that she has ever been battered by me. Also, the 990 Form for Sanctuary for Families shows that Dorschen Leidholdt pays herself a salary of $111,067 per year. She is just using my family as poster children so that she can obtain charitable contributions and this is highly objectionable. Then, she uses this as a pretext to get Paul, Weiss, Rifkind, Wharton & Garrison to represent Dayawathie Rankoth on the appellate level. On May 2, 2006 in an article in the New York Law Journal in response to criticism of the judges in the Queens Family Court, Dorschen Leidholdt was quoted as saying that most of the judges are bad, but there is one good judge and that is Judge Modica. I would like to draw your attention to that quote. Very Truly Yours, Samuel H. Sloan Copy to: Jill Zuccardy Vladimir Cadet Janet L. Brown Pauline Braun Paul, Weiss, Rifkind, Wharton & Garrison LLP P.S. While not relevant to this case, I think I should inform you that there has been a lot of media publicity recently about the fact that a person has been positively identified as having impersonated me in 2464 postings on the Internet. The lead article on this subject appeared in the New York Times on October 8, 2007 entitled: NY Times: "Chess Group Officials Accused of Using Internet to Hurt Rivals" AFFIDAVIT OF SERVICE Docket No. V-11567-05 STATE OF NEW YORK COUNTY OF QUEENS Kayo Kimura, being duly sworn says: I am not a party to this action, I am over 18 years of age and on ember 27, 2007 at 8:00 AM I served a true copy of the within motion by mailing a true copy of the same to: Jill Zuccardy Sanctuary for Families 67 Wall Street, Room 2211 New York NY 2006 Vladimir Cadet 89-31 161st Street, Suite 505 Jamaica NY 11432 Janet Lisa Brown 89-31 161st Street, Suite 301 Jamaica, NY 11432-6150 Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York, NY 10019-6064 __________________________ Sworn to Before me this 27th Day of ember, 2007 ______________________________ NOTARY PUBLIC   Date: 03 Jul 2008 17:54:18 From: Sam Sloan Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt Sam Sloan 1664 Davidson Ave., Apt. 1B Bronx NY 10453-7877 Tel. 917-507-7226 samhsloan@gmail.com June 30, 2008 Jackie Vasquez Appellate Division, Second Department Supreme Court of New York 45 Monroe Place Brooklyn, NY 11201 2008-02071 In the Matter of Dayawathie Rankoth, respondent, v Samuel Sloan, appellant. Dear Ms. Vasquez, With regard to our conversation earlier today, the scheduling order gives me until today, June 30, 2008 to file my brief. However, in this case, the transcripts are, according to my count, 516 pages long. There are hundreds of pages of exhibits and related documents. This case was filed on July 30, 2005 and litigated for more than two years over eight hearing dates involving live testimony of witnesses. Accordingly, it will not be possible for me to file my brief today. I am working very hard on it and I expect to be able to file my brief in two weeks. I hereby request an extension of time of 30 days to file my brief. Very Truly Yours, Sam Sloan Copy to: Jill Zuccardy Attorney for Sanctuary for Families 67 Wall Street, Suite 2211 New York NY 10006 Vladimir Cadet 89-31 161st Street, Suite 505 Jamaica NY 11432   Date: 19 May 2008 23:30:29 From: Sam Sloan Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt SUPREME COURT OF THE STATE OF NEW YORK APPELLATE DIVISION: SECOND DEPARTMENT -------------X No. 2008-02071 DAYAWATHIE RANKOTH, Docket No. O-18182-05 Petitioner - Respondent Queens County Family Court - against - MOTION TO DISQUALIFY SAMUEL SLOAN, Jill M. Zuccardy and Sanctuary for Families, Inc. , Respondent-Appellant. from appearing as counsel -------------X in this case AFFIDAVIT IN SUPPORT OF MOTION TO DISQUALIFY Jill M. Zuccardy and Sanctuary for Families, Inc. from appearing as counsel in this case: Samuel H. Sloan, being duly sworn, deposes and says: 1. I am the Respondent-Appellant in the above entitled case. I make this motion to disqualify Jill M. Zuccardy and Sanctuary for Families, Inc. from appearing as counsel in this case. 2. JILL M. ZUCCARDY begins her affirmation to dismiss my appeal with the following paragraph: “1. I am a pro bono attorney associated with Sanctuary for Families' Center for Battered Women's Legal Services.” 3. This statement alone is unfair and prejudicial. It implies that Dayawathie Rankoth, the Petitioner - Respondent herein, is a “battered woman”. In reality this is not the case. There is no allegation, much less evidence or proof, that Dayawathie Rankoth has ever been battered, abused or mistreated in any way. 4. In addition, these statements have the effect of threatening and intimidating the judges of this and other courts. If the judges decide a case contrary to the wishes of Dorchen Leidholdt, she will go to the newspapers and complain that the courts are failing to protect battered women and that the courts themselves are abusers of women. Dorchen Leidholdt often does exactly this. Search the newspapers and you will see Dorchen Leidholdt often complaining about judges and the courts. Dorchen Leidholdt is managing director, founder and CEO of Sanctuary for Families. She had to make a great personal sacrifice to do this, by giving up her career as a child pornography gadfly. 5. You heard that exactly right. Attached hereto is a feature article about Dorchen Leiodholdt as published in Hustler Magazine. Dorchen Leidholdt first became famous as a target of the Meese Commission on Child Pornography. 6. In an article published in May 2006 in the New York Law Journal, Dorschen Leidholdt was quoted as saying that all of the judges of the Queens Family Court are bad except that there is one good judge. His name was Judge Modica. Judge Modica happens to be the judge on this case. 7. Jill M. Zuccardy works for Dorchen Leidholdt. She should not be allowed to appear in this case. . .8. Sanctuary for Families is not a registered and licensed law firm. The last time this case was before this court, Dorchen Leidholdt had hired Paul, Weiss, Rifkind, Wharton & Garrisonto appear in this case. It is apparent that Paul Weiss has seen the light and does not want to appear any more. Probably this was pro bono work because they thought they were representing a “battered woman”. Having found out that there is no battered woman involved in this case, they have discharged their duties and no longer want to be involved. . 9. Attached hereto as an exhibit is the Form 990 for Sanctuary for Families proving that Dorchen Leidholdt is the managing director of Sanctuary for Families, Inc. Attached hereto as another exhibit is a non-pornographic feature article about Dorchen Leidholdt from Hustler Magazine. Attached hereto as a third exhibit is the cover of a book by Dorechen Leidholdt entitled “The Sexual Liberals and the Attack on Feminism”. . .10. Dorchen is a notorious lesbian activist. She should not be allowed to have contact with anybodies children, and especially not with my children. I can only wonder what the orientation of Jill Zuccardy is, since she works for Dorchen Leidholdt. My assigned counsel in the prior appeal to this court, Pauline Brandt, told me that she is quite familiar with Dorchen Leidholdt and Sanctuary for Families, having opposed them in many cases in the Family Court. She said that they are “crusaders”, in the words of Pauline Brandt. They are not concerned with the mother and her children in the case before the courts. They want to make a political or social point. For example, Dorschen Leidholdt campaigns against the “Mail Order Bride Industry”. That may explain her interest in this case as she is regarding Dayawathie Rankoth, who is from Sri Lanka, as some sort of mail order bride. 11. The duty of any attorney is to her client. However, the primary duty of Jill Zuccardy is to her boss, Dorchen Leidholdt. Therefore Jill Zuccardy should be disqualified from appearing in this case. . .12. This is not just a minor point. This is the whole case. Dorchen Leidholdt has been attacking me and my family for 17 years since June 1991. If Dorchen Leidholdt and her organization Sanctuary for Families Inc. and their employee Jill Zuccardy is disqualified from this case, this case will be over and I can get my children and their mother back. The mother, Dayawathie Rankoth, is mortally afraid of Dorchen Leidholdt and has told me all about this, which is the reason why I know so much about her. . .13, I make this affidavit in support of a motion to disqualify Jill Zuccardy, Dorchen Leidholdt and Sanctuary for Families from appearing as counsel in this case. This case in its various aspects has been going on for 17 years since 1991. I had first brought Dayawathie Rankoth to America in 1988 on a tourist visa because she was pregnant, in order that she give birth in America to confer American citizenship on our child. I entrusted her to Sister Bernadine Dominick, who ran a home for unwed mothers called the Casa Vincentia in Oakland, California. Dayawathie gave birth to Michael there on June 18, 1988. As Dayawathie was here on a tourist visa, it was necessary to take her back within the time allotted for her visa, so in July, 1988, I took her back to Abu Dhabi where we had been living. On February 10, 1989, after Dayawathie had been arrested by the police, she flew back to her home in Bowalawatta, Kandy, Sri Lanka, leaving Michael with me. I later made two trips to Sri Lanka to get her out. The first trip in August 1989 I could not get her out because the civil war had reached its peak and all government offices were closed. She became pregnant with out second child, George, on that trip. In ember 1989 I made another trip to Sri Lanka and this time I was able to get her out and I brought her to Fujairah, United Arab Emirates, where we were living. As she was pregnant again, I later obtained another tourist visa for her so that she could give birth to our next child in America too. 14. In 1991, we were living in my mother's house at 917 Old Trents Ferry Road in Lynchburg, Virginia when on or about June 19, 1991, I brought Dayawathie Rankoth who was four months pregnant and our children Michael and George by car to Jamaica Queens. I had business to take care of the following morning, so I arranged for them to stay one night in a hotel and then I planned to take them the following morning back to my mother's house in Lynchburg, Virginia where we had been staying up until this time. Unfortunately, as I had business to take care of, I was one hour late the following morning to come back to pick them up. Upon arrival I was told that they had been waiting outside for me and had just stepped back inside. I was told that they were just coming down the steps and to wait outside as they would be down in a minute. I waited in my car with the motor running because it was a no parking area and I did not want to get a ticket. 15. So I waited and waited and waited. I was told by another resident that Dayawathie and the children had been stopped on their way out the door taken into a office by a Miss Bivins, who had locked the door. The other residents were concerned about this because they did not know what was going on. 16. I continued to wait outside the building for more than 24 hours. I finally found a legal parking space on the same block and slept in my car. They never came out. Finally, the following afternoon, another resident called out the window that they had been taken out the back door and put in a closed van the previous evening and taken to an unknown location. 17. I spent the next four years looking for them, checking with every possible agency and even walking the streets of New York City trying to locate them. Shortly after their disappearance, I received a telegram from Sebastian Ike of the Child Welfare Agency in New York City who informed me that the CWA was investigating them and was considering starting removal proceedings to take the children away from the mother. However, the CWA had lost track of them too and were unable to find them just as I had been. 18. Just a day or two before their disappearance, I had started a proceeding in New York Family Court because I feared that something like this might happen. There had been prior court proceedings in Queens and in Lynchburg, Virginia which had been abandoned. There were several court hearings in New York Family Court over the next more than one year until October 1992. Each time the judge ordered the whereabouts of the children revealed to him. Each time the agency reported that they were unable to locate the children or that the “social worker” had refused to reveal their whereabouts. That “social worker” has since been revealed as Sister Theresa Courtney of Sanctuary for Families, who has never been, as far as I am aware, an official of the City of New York. 19. Since Dayawathie had been four months pregnant at the time of her disappearance, I knew the due date of the delivery of her child, Anusha, the same child who is the subject of the proceeding here. At the time of the due date, I started calling every hospital in New York City that delivers babies to see if this child had been born. Finally, I hit pay dirt because St. Vincent's Hospital informed me that the child had been born there. I have since been wondering why they chose St. Vincent's Hospital since I now know that Dayawathie never lived anywhere near that hospital. 20. I went to St. Vincent's Hospital on the pretext of wanting to pay the hospital bill for the birth of the baby. They gave me the bill which showed the address of the mother to be PO Box 413, Times Square Station, New York NY. I went to that post office and filed a Freedom of Information Request for the identity of the holder of that PO Box. This revealed that the holder of this PO Box was Sanctuary for Families. 21. I found out that Sanctuary for Families was located in a church on the SW corner of 46th Street and Eighth Avenue in New York City. I staked out the church for a while to see if I could see Dayawathie and the children going in or out of there. When that failed, I called the New York City Police and complained that my children and their mother had been kidnapped and were being held prisoner inside. The staff of Sanctuary for Families treated this as a joke. The police searched the place but of course could not find the children. 22. I attempted to file a writ of habeas corpus in New York Supreme Court but the judge refused to sign the writ because I could not provide an actual address for the children. Finally, in 1992 I filed a suit in Federal Court in Brooklyn against Sanctuary for Families alleging a conspiracy to kidnap all of my children. The case was Sloan vs. Pattison, 92 Civil 2388 (EDNY) (RJD). Sanctuary for Families appeared and answered through Lawrence Kamin, Esq. of the prestigious law firm of Willkie, Farr & Gallagher. They filed an answer which essentially denied any knowledge of the whereabouts of the children and their mother. The case was eventually dismissed http://www.anusha.com/judgego.htm . 23. Finally, in April, 1995, I retained Denise Grey, an investigator who specializes in finding children who have been given away for adoption. Amazingly, she found the children right away. They were living in the South Bronx, at 905 Tinton Avenue. 24. I went to that address and Dayawathie immediately invited me to come in to live with her. She introduced me to Anusha who had been born in the four years that I had been unable to locate the children. Anusha was now three and a half years old and had been told that her father was dead. 25. The children were very surprised to meet their father especially since they had been told that I was dead. George fainted. Dayawathie told me all about Sister Theresa Courtney, about how she had led her out the back door when I had been waiting out the front door. In the intervening four years, Dayawathie had been living in a variety of safe houses, especially one on Allerton Avenue in the North Bronx. 26. I had thought that after all the trouble they had gone to hide the mother and the children from both me and the Child Welfare Administration, that at least they were being kept in a good place. I was proven wrong. They were living in the most horrifying squalor imaginable. There were a million cockroaches on the walls, so many that you could not really see the walls. Their best friends were prostitutes and crack addicts named Julie, Jean and One-Legged Brenda (who had lost her leg due to drug addiction), who lived upstairs. They regularly did business with a loan shark named Panama. 27. The children told me all about Sister Theresa Courtney, who visited them regularly and whom they very much disliked. It was obvious that Sister Theresa Courtney knew the horrifying conditions under which the children were living and was doing nothing about it. 28. I spent two weeks cleaning up Dayawathie's apartment while living there. Then, I had to go back to California. Dayawathie asked me to take the two boys, Michael and George, with me because they were wild and out of control. She wanted to keep Anusha with her. Naturally, I agreed to take the boys with me. I gave Dayawathie five hundred dollars and she bought the boys new sets of clothing for their trip to California. However, Dayawathie said to me repeatedly “Don't tell Theresa”. She said that Theresa would be very angry if she found out that the kids were in California. Naturally, I promised not to tell Theresa. 29. We flew to California and I lived in San Francisco with my two sons Michael and George for one month. We lived at 2550 Webster Street, the Bourn Mansion, a famous building where I was helping the owner with her many court cases. Just as Dayawathie had said, the boys were far more difficult and unruly than I had imagined. They often fought with each other. The owner of the Bourn Mansion wanted to kick us out because they tore up her garden in her back yard. A bigger problem was that Michael refused to go to school. Finally, I took them over to Alameda where their half-sister Jessica was attending the Haight School. I enrolled them in the same school as Jessica was attending. 30. I was considering moving to the East Bay, where I had attended the University of California at Berkeley. We spent a few nights in Oakland. However, the owner of the Bourn Mansion, Arden Van Upp, called me back to help her with some of her legal work. Just when I got there, Dayawathie called to inform me that Theresa Courtney had found out that the children were in California. The way she had found out was that the Haight School, where I had enrolled the boys, had called the school in the Bronx which the boys had previously attended. However, that school instead of calling Dayawathie had called Theresa Courtney. Dayawathie was upset at this development and said that she was thinking of coming to California. 31. Just as we were talking on the telephone, there was a knock on the door. I answered the door and it was the police, who arrested me. I could not understand what had happened. I had spoken to Dayawathie on the phone every day since I had brought the boys to California. In fact I was talking on the phone to her at the very moment the police came knocking on the door. She was just explaining that the school in the Bronx where Dayawathie was living had informed Theresa that the two boys were in California and were attending school there. This had happened because the school in Alameda, California had contacted the school in the Bronx asking them for a transfer of the student records. The school in the Bronx had apparently breached student confidentially by telling Theresa Courtney that the boys were in California. Dayawathie of course knew that the boys were in California but had kept this information secret from Theresa. Now, Theresa had gone to her lawyer in Manhattan and had a judge in Manhattan issue a writ of habeas corpus to bring the boys back to New York. 32. The question was how a judge in Manhattan was able to do this when Dayawathie and the children were living in the Bronx. The answer is that they gave a FAKE ADDRESS. As Dayawathie explained it to me, the attorney for Sanctuary for Families was a personal friend with a judge in Manhattan. She had called the judge at home at night. The judge agreed to issue the order provided that the case was filed in Manhattan. Now, in order to get jurisdiction in Manhattan they created a fake address. The address was 410 West 40th Street, New York NY 10036. Dayawathie however lived at 905 Tinton Avenue, Bronx NY. She had never lived in Manhattan at that or any other address. I later went to 410 West 40th Street. You can see that address if you ever take a bus to New York City because the bus goes right in front of that address just before it enters Port Authority Bus Terminal. There is a soup kitchen there operated by a church. I went to the soup kitchen and showed the pastor a picture of Dayawathie and the children. He said that he had never seen them before in his life. He said that Sanctuary for Families had rented an apartment upstairs during the period in question, but nobody had ever lived there and he was completely certain that Dayawathie had never been there. 33. In California they have a law which does not exist in New York or in any other state as far as I am aware that a person can be arrested and held “pending investigation”, without any charges being brought. Bobby Fischer was notoriously held under that law and wrote a book about it. That is how they arrested me. I was never taken to court. I never saw a judge. They put me in jail in San Francisco and then transferred me to Santa Rita County Jail near Oakland. During this time, my two boys, Michael and George, were extradited to New York. 34. I was released in June with no charges ever being brought. As far as I am aware, there is no record of me even being in jail in California. After I got out, I flew back to New York. However, Dayawathie and the children had disappeared again. Sister Theresa Courtney had moved them out of 905 Tinton Avenue and taken them to parts unknown. 35. A writ of habeas corpus should not have been issued by the New York Family Court because of no jurisdiction. Dayawathie had never been awarded legal custody of the children by any court. The previous case in 1991 had been dismissed with no final order entered because Dayawathie had disappeared with the children when Sister Theresa Courtney had hidden them. Michael had been born in Oakland, California so in no way did New York have jurisdiction. Nevertheless, the boys were extradited to New York while I was still in jail. I was released from jail in California. No charge was ever brought against me. I was never even taken before a judge. However, by the time I got out the boys were gone. 36. During the two weeks that I had been living with Dayawathie at 905 Tinton Avenue, she had become pregnant with our fourth child. Upon finding out that Dayawathie was pregnant with our fourth child, Sister Theresa Courtney had arranged for Dayawathie to have an abortion. As Dayawathie later has explained it, Theresa said that since she was a nun in the Roman Catholic Church, she could not personally take Dayawathie to the abortion clinic. Therefore, she arranged for a co-worker to take Dayawathie to the abortion clinic. The abortion was performed on July 7, 1995. I know this date because I later saw documents, including an appointment letter and a bill providing this date, as the date of the abortion. 37. Thus, after I got out of jail after having been arrested by an illegal order, my sons had been extradited to New York and my unborn baby had been aborted. When I went to New York to try to locate Dayawathie again, Theresa had moved her out of the apartment at 905 Tinton Avenue and Dayawathie had disappeared to parts unknown. The case under which the writ of habeas corpus had been issued, No. V-4534/95, was dismissed. I tried to reopen it, without success. 38. Almost immediately after the abortion of July 7, 1995, Dayawathie became pregnant by a passing stranger. As a result, Geeta Rankoth, her fourth child, was born June 9, 1996. Dayawathie believes that the father was named Kamal and that he was from Bangladesh but I have asked around in the Bangladesh community and there is no such person from Bangladesh in New York. The result is that instead of having a child with me as the father, Dayawathie had a child by an unknown father. Geeta by the way is a wonderful child and I often refer to her as my step-daughter. 39. The problem Dorchen Leidholdt now has is that between 1991 and 1995 Dayawathie could not contact me because she did not know where I was and she could not yet speak English and I did not know where she was. However, now, Dayawathie knew where I was and soon she called me and gave me her new address, which was on Ft. Hamilton Parkway near Prospect Park. This was a facility operated by Sanctuary for Families. In July 1996, I went there with my other daughter Jessica, aged 7, and we met Dayawathie, Anusha and the newborn baby Geeta near the subway station and spent the day in Manhattan together. I then went with Jessica to play in the US Open Chess Championship in Alexandria, Virginia. When we got back in New York two weeks later, Dayawathie and the four children had been moved out of the Ft. Hamilton Parkway facility. Apparently, Sister Theresa Courtney had found out that we had met and had moved Dayawathie to another facility. 40. In February, 1997, Dayawathie called me again. She had just been given a new apartment on 1581 Park Avenue, New York NY This is in the Johnson Housing Project at 113th Street and Lexington.. She asked me to move in with her, which I did. We lived together there for several months. 41. Unfortunately, soon thereafter some of the denizens she had left behind in the Bronx named Jean, Julie and One-Legged Brenda found her. By then they had been evicted from their own apartments in the same building, 905 Tinton Avenue, and now they were staying with friends in the project across Lexington Avenue. Soon, they moved into Dayawathie's apartment. Before long, we had Jean, Julie, Jeans daughter, One-legged Brenda and new comers Brenda Morales and Jimmy all living with me, Dayawathie and the four children in the same two bedroom apartment. As Princess Diana later famously commented, “It was a bit crowded”. 42. I tried to convince Dayawathie to lock these people out, but she kept letting them in. They usually came home at about 2 AM. We later found out that Brenda Morales and Jimmy were HIV Positive. This is the reason they could not find any place else to live. Brenda Morales was a professional thief. She would take my children, Anusha and George, to stores and use them as decoys so that she could steal stuff. If she was caught, the police would be reluctant to arrest her because of the two children with her. Dayawathie knew about this but would do nothing to stop it. 43. Julie, Jean and One-Legged Brenda were five-dollar prostitutes, especially One-Legged Brenda. She lost her leg to drug addiction. They often smoked Crack. One-Legged Brenda gave birth to a baby and social services immediately took the baby away from the crack-addicted mother. A few days after One-Legged Brenda got back from delivering the baby, I went to sleep in the apartment with nobody but me, Dayawathie and the four children there. I was hoping to have a night of peace. However, I woke up in the middle of the night to find that One-Legged Brenda had crawled into bed with me. Some men would be happy to find a woman in bed with them but I certainly was not happy, especially since I knew that One- Legged Brenda was HIV Positive and a crack addict. Dayawathie had opened the door and let Jean, Julie, Jean's daughter and One-Legged Bredna into the apartment in the middle of the night. Jean, Julie and Jean's daughter had taken over the beds in which my children, Michael, George and Anusha were sleeping. They had pushed Michael, George and Anusha onto the floor and were sleeping in their beds while my children were now sleeping on the floor. 44. Finally, I had to act, so I secretly called 911. I reported that drug addicts and prostitutes had pushed their way into our apartment, which was true. The police arrived and I opened the door. They found Jean, Julie, Jean's daughter and One-Legged Brenda all asleep. They woke them up and searched the place but could not find any crack. All the crack vials had been thrown down the garbage chute. 45. This was about 5:00 AM. While the police were doing this, Dayawathie called Sister Theresa Courtney and woke her up. Dayawathie did not tell Sister Threresa Courtney anything about Jean, Julie, Jean's Daughter and One-Legged Brenda. Instead, she complained that I was in the apartment (not mentioning that by then I had been living there for four months). The end result was that the police took away my keys to the apartment and told me to leave, which I did. Jean, Julie, Jean's daughter and One-Legged Brenda were still allowed to stay there. (I believe that Jimmy and Brenda Morales were not present at the time of this incident.) 46. I was at that time working for a real estate holding company at 24 Sixth Avenue in Brooklyn. Twice, my other daughter, Jessica, and her mother, Renuka, flew from Alameda California to visit us and each time they stayed with Dayawathie and my other three children at 1581 Park Avenue in New York. Dorchen Leidholdt found out about this and approached Renuka and asked for her help in getting me arrested, but Renuka refused to cooperate and instead went back to California. 47. During this time, Dayawathie was calling me 20 times a day at work asking for stuff and this was disturbing my boss as work and made his wife angry. I lost that job and I went to live with my friend from Afghanistan, Sayed Durali Shah, who lives in Far Rockaway. Dayawathie called me many times asking me to come back there, but I refused to go. One night at about 7:00 PM Dayawathie called to say that Anusha was very sick and needed to be taken to the hospital. However, Dayawathie could not take her because she needed to take care of the other three children. Therefore, Dayawathie wanted me to come to her home and either take Anusha to the hospital or else stay with the kids while Dayawathie took Anusha to the hospital. 48. I was very tired. I had been working as a taxi driver for Towne Taxi in Lawrence Long Island. I wanted to go to sleep, but in view of the emergency I got out of bed and made the two hour trip by subway from Far Rockaway to Spanish Harlem where Dayawathie lived. 49. When I walked in the door to Dayawathie's apartment, I was surprised to find Michael, George and Anusha running around playing quite happily. Anusha did not look sick at all. Only one second later two police officers came out the bedroom and arrested me. It had all been a trap set by the police. The arresting officer was Carmen Bonilla. She had sat by Dayawathie coaching her on exactly what to say. This entire story about how Anusha was sick and needed to be taken to the hospital was a pure fabrication. Dorchen Leidholdt was involved in this, because as soon as she had arrested me Carmen Bonilla called Dorchen Leidholdt on the phone to tell her the good news. I was taken to jail. 50. They had made up a purely invented story that I had come to the apartment with my 16-year-old girlfriend and had forced our way into the apartment and had hit Dayawathie's head against the wall. Nothing like that had ever occurred. Yes, there was such a girl, but she was 17, not 16, and we had been palling around for months but she was never my girlfriend. Dayawathie had never met her. She had never been to that apartment. Her name was Irina ikova. She was from St. Petersberg, Russia and I was giving her lessons in shogi, or Japanese chess, of which I am a top player. She had converted to Hassidim and lived in the Machon Chana in Crown Heights, Brooklyn, but every Saturday she would sneak out to come to see me. Dayawathie had never met her but had heard about her and was jealous and thus had invented this entire story. 51. I called Irina ikova from the jail and asked her to come to court to testify in my defense. She said she would come, but did not show up. Soon thereafter she went back to Russia and I never saw her again until she returned to America four years later, 52. When the date came for the court hearing, Dorchen Leidholdt and Dayawathie did not show up. In that event, they were supposed to release me but instead they made a new bogus charge against me and put me back in. Another six days passed. I was brought from the jail to the courthouse. I sat all day in the waiting room behind the courtroom. At 5:00 PM my court appointed lawyer came back to see me and told me that Judge Ross had gone for the day. Therefore, there would be no court hearing and I would be released as the case was dismissed. By not allowing me to come before him in open court Judge Ross had cheated me out of my chance to complain that I had been held in jail for 12 days for no reason at all. I attach a copy of a letter from Dorchen Leidholdt saying that she was dropping the case because she could not prove it “by a preponderance of the evidence”. No mention of “beyond reasonable doubt”. The letter was dated June 20 and had been delivered by hand. Nevertheless, Judge Ross had kept me in jail until June 23 even though he knew that the case was being dismissed. 53. I went to the office of the District Attorney several times demanding that Dorchen Leidholdt be criminally prosecuted for bringing this false case. However, the ADA, Eileen Chiu, said that she could do nothing because again Dayawathie had disappeared. Dorchen Leidholdt wrote a letter saying that she no longer represented Dayawathie and did not know where she was. This was another lie. Dorchen had moved Dayawathie to a facility Dorchen operated in Queens. 54. Before long, Dayawathie started calling me again. She was living in a facility operated by Sister Theresa Courtney and Dorchen Leidholdt at 166th Street and Hillside Avenue in Queens. She wanted me to come there but I refused to go. She wanted me to buy presents for the kids. Finally, I agreed to meet her at the big shopping mall on 33rd Street and Herald Square on Sixth Avenue in Manhattan. We met many times there and I would treat the kids. There were no court orders or custody orders because everything had been dissolved every time she disappeared. Still, I was afraid to come to her residence. 55. In early 1998 she got a new apartment at 40-08 12th Street, Long Island City, Queens, New York in the Queensbridge Housing Project. She did not like the place, much preferring her old apartment in Manhattan. However, she finally asked me to come live there. The deal we made was that Sister Theresa Courtney and Dorchen Leidholdt only came to see her on Saturday or Sunday and only came during the daytime because they were afraid of the Black people at night. Therefore, I would never come at those times. I would maintain my own residence. If Dorchen Leidholdt or Theresa Courtney ever came at an unusual time when they were not expected, I would hide in a closet or in the stairwell on a higher floor and leave the building as soon as they entered the apartment. Dayawathie gave me keys to her apartment and to the building and I could pretty much come and go as I pleased as long as I followed those rules. 56. This was the deal for the past seven years, from 1998 to 2005. As long as Dorchen Leidholdt and Theresa Courtney did not know about it, I could even bring friends over. My other daughters, Shamema and Jessica, have visited there. Jessica even lived there for a while. I have married and my wife Kayo and our daughter Sandra have been frequent visitors in the home. Rusudan Goletiani, who is the US Womans Chess Champion, has visited me there, as has my friend Mario Sacripante for whom I worked when I was living in Japan in 1984. I have also made friends with some of the neighbors. Thus, I have lots of witnesses who could testify that I was freely coming and going in the home for the past seven years. There has been no problem, no arrests, no custody cases, for these seven years. 57. In 1999, my other daughter, Jessica, came from California to live with me. However, she strongly preferred to stay with her half-brothers and sisters, Michael, George and Anusha, so she lived in Dayawathie's apartment at 40-08 12th Street, Long Island City. I enrolled Jessica in school there, the same school that Michael and George were attending. However, Dorchen Leidholdt and Sister Theresa Courtney found out about this, went to the school and objected. As a result, Jessica was not allowed to attend school there. I complained to the Board of Education, to no avail. Finally I had to send Jessica back to California. 58. There has been a big problem with Surinder Singh a/k/a Kala. He was a homeless bum that Dayawathie had met while she was living in the homeless shelter at 166th Street and Hillside Avenue. He followed her to her new apartment at 40-08 12th Street. Dayawathie says that at first he was nice. However, later, he was drunk all the time. He would beat and abuse her. She would call 911. The police would come but he would run away. Sometimes he would hide on the roof of the building and come back down after the police left. Sometimes the police would even catch him in the apartment but would not arrest him even though he was obviously drunk and abusive. He was eventually arrested six times in her apartment but then the judge would let him out after just a few hours and he would come right back. Dayawathie got a dozen orders of protection against him but he just ignored them. 59. Finally, the New York City Housing Department started an eviction proceeding against Dayawathie for letting Surinder Singh into the apartment where he would cause a constant commotion. Dayawathie got Dorchen Leidholdt to defend her in this court case. Dorchen settled the case with an order in which Dayawathie agreed not to allow Surinder Singh OR Sam Sloan into her apartment, or otherwise she would forfeit the apartment. Dorchen Leidholdt added my name to the case, even though the New York City Housing Department had never heard of me. They did not even know my name because the police had never been called about me and there had never been any trouble about me. 60. This court order has made Dayawathie fearful of allowing me to stay in the apartment. I have never spent the night there since. My visits have been brief. Meanwhile, Kala has disappeared. I suspect that he was finally deported back to India after 9/11. 61. It is my absence that has allowed the two drug dealers from Tioga, Pennsylvania to move in. They moved in full time in about February, 2005. Before that, they were just coming and going from Tioga to New York. I know where they are from because one time Dayawathie went to visit them in Tioga. She had me take care of the children while she was gone and gave me the number there which she told me to call in case of emergency, but she insisted that I never reveal that I had the number. 61. From all of the above, it should be obvious that Jill Zuccardy, Dorchen Leidholdt and Sanctuary for Families are disqualified from appearing as counsel in this case. They have their own agenda which in in conflict with the best interests of the mother and the children. Rather than prove any case they might have against me, they repeatedly uproot the children and disappear with them. They have had me arrested three times but each time they have not come to court on the court date and instead have disappeared with the children again. In 1997, Dorchen Leidholdt wrote letters saying that she no longer represents Dayawathie Rankoth and does not know where she is, but Dayawathie says that there has never been even one day when Dorchen did not know where she lives because she has been living in a facility provided by Dorchen Leidholdt. Jill Zuccardy is a young lawyer who just graduated from law school in 2005 and this must be one of his first cases. He works for Sanctuary for Families and obviously does not know what he is getting into. 62. Finally, Jill Zuccardy, Dorchen Leidholdt and Sanctuary for Families tried to have me arrested again when this case was in court on October 6, 2005. This is their tactic. They cannot prove their case in court, so they want to win by having their opponent arrested and then disappearing with the children so that the father cannot find them again. This sort of behavior requires more than they be merely disqualified from this case. They should be disbarred from the practice of law. 63. Dorchen Leidholdt is a lesbian lunatic and a sick demented woman. She founded an organization called “Victims of Pornography”. While constantly railing in the press against pornography and organizing the street demonstrations one sees from time to time, her writings are actually pornographic. For example, her often cited statement that 25% of all female children are sexually molested by their own fathers is itself pornographic. For this reason, the statements by Dorchen Leidholdt are often published in pornographic literature such as Hustler Magazine. Hustler also publishes revealing pictures of Dorchen Leidholdt taken when she was younger. 64. However, I do need to tell you about this, because you can read it yourself. Attached hereto is a copy of an article Dorchen Leidholdt wrote entitled, “When Women Defend Pornography”, which is found in the book “The Sexual Liberals and the Attack on Feminism” by Dorchen Leidholdt and Janice G. Raymond. This book is filled with essays by militant lesbians, some of them quite famous. Anybody reading this essay will immediately realize that the author is seriously ill and emotionally disturbed. 65. Dorschen Leidholdt is the legal director for Sanctuary for Families, She is the boss of Jill Zuccardy who is a new hire having just graduated from Columbia University Law School in 2005. Dorchen has founded numerous groups, one of which is the “Coalition Against the International Trafficking of Women”. She uses my children and their mother as the poster children for her organization. This is obviously based on the fact that I brought the mother, Dayawathie Rankoth, from Sri Lanka to America twice to give birth to my children. 66. Dorchen Leidholdt uses my children to collect charitable contributions. She has established various 501(c)(3) corporations. In short, she uses my children to make money. Wealthy people can get tax deductions by donating to the various organizations which Dorchen Leidholdt has founded. Dayawathie Rankoth thinks that Dortchen Leidholdt is a nice lady her gives her money all the time but that is because she fails to realize that what is really going on is Dorchen Leidholdt is using her to make money. This is obviously a conflict of interest. 67. Dorchen Leidholdt has had me arrested three times. In May and June 1995, I was held in jail mostly in the Alameda County Jail in Santa Rita for 42 days on a charge of kidnapping. However, I was never brought before a judge in court. California allows a person to be held “Pending investigation”. Meanwhile Dorchen Leidholdt had my two sons, Michael and George, extradited to New York, which is why they are here now. 68. She had me arrested twice again in 1997. I was living in Far Rockaway Queens and driving a taxi for Towne Taxi in nearby Lawrence, Long Island. Dorchen Leidholdt had Dayawathie call me and tell me that Anusha was seriously ill and needed to be taken to the hospital and I needed to come to her house right away. What I did not realize was that Dorchen Leidholdt had taken out an order of protection against me which I had never been served with so I did not know about. When I appeared at the apartment to take Anusha to the hospital for this serious illness she was supposedly suffering from, two police officers were waiting to arrest me in a trap set by Dorchen Leidholdt. 69. Dorchen Liedholdt is doing the same thing here again. Here we have an order of protection prohibiting me from seeing any of my children including my eldest son Michael. However, Michael is not in the home. He has been arrested and is in mental hospital. His case worker is Nicole Valasko. She had called me and advises me that Michael should not be returned to the home of Dayawathie Rankoth. Michael should live with me, her father, she says. Two psychiatrists, Dr Arya and Dr. Attila Polonyi, have made the same recommendation. I am sure that, if asked, they would recommend that all three of my children be removed from that home, especially since Dayawathie has had two drug dealers living there. Yet, the court does not know about this, because of the misconduct by Dorchen Leidholdt and her subordinate Jill Zuccardy. I was not even allowed to send Christmas presents to my children. 70. From all this, there is obviously a major conflict of interest between Dorchen Leidholdt and her subordinate Jill Zuccardy and Dayawathie Rankoth and the three children. This struggle has been going on for 17 years since 1991. Dorchen Leidholdt and Jill Zuccardy have their own interests including an interest in not being arrested and charged with kidnapping for bringing my children from San Francisco, California where they were living to New York. It is not proper for them to be allowed to represent a party to this case. WHEREFORE, for all of the reasons set forth above, Jill Zuccardy, Dorchen Leidholdt and Sanctuary for Families from appearing as counsel in this case. ___________________________ Samuel H. Sloan 1664 Davidson Avenue, Apt. 1B Bronx NY 10453-7877 samhsloan@gmail.com 917-507-7226 347-869-2465 Sworn to before me this 20th Day of May, 2008 _______________________________ NOTARY PUBLIC VERIFICATION I, the undersigned, the petitioner named in the foregoing petition, being duly sworn, says: I have read the foregoing petition subscribed by me and know the contents thereof and the same is true of my own knowledge, except as to those matters herein stated to be alleged upon information and belief and as to those matters I believe it to be true. _________________________ Signature of Petitioner On the 20th Day of May, 2008 before me personally came Samuel Sloan to me known to be the person described herein and who executed the foregoing instrument. Such person duly swore to such instrument before me and duly acknowledged that he executed the same. _____________________________ NOTARY PUBLIC   Date: 19 May 2008 21:05:21 From: Sam Sloan Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt SUPREME COURT OF THE STATE OF NEW YORK APPELLATE DIVISION: SECOND DEPARTMENT -------------X No. 2008-02071 DAYAWATHIE RANKOTH, Docket No. O-18182-05 Petitioner - Respondent Queens County Family Court - against - MOTION TO DISQUALIFY SAMUEL SLOAN, Jill M. Zuccardy and Sanctuary for Families, Inc. , Respondent-Appellant. from appearing as counsel -------------X in this case AFFIDAVIT IN SUPPORT OF MOTION TO DISQUALIFY Jill M. Zuccardy and Sanctuary for Families, Inc. from appearing as counsel in this case: Samuel H. Sloan, being duly sworn, deposes and says: 1. I am the Respondent-Appellant in the above entitled case. I make this motion to disqualify Jill M. Zuccardy and Sanctuary for Families, Inc. from appearing as counsel in this case. 2. JILL M. ZUCCARDY begins her affirmation to dismiss my appeal with the following paragraph: "1. I am a pro bono attorney associated with Sanctuary for Families' Center for Battered Women's Legal Services." 3. This statement alone is unfair and prejudicial. It implies that Dayawathie Rankoth, the Petitioner - Respondent herein, is a "battered woman". In reality this is not the case. There is no allegation, much less evidence or proof, that Dayawathie Rankoth has ever been battered, abused or mistreated in any way. 4. In addition, these statements have the effect of threatening and intimidating the judges of this and other courts. If the judges decide a case contrary to the wishes of Dorchen Leidholdt, she will go to the newspapers and complain that the courts are failing to protect battered women and that the courts themselves are abusers of women. She often does exactly this. Dorchen Leidholdt is managing director, founder and CEO of Sanctuary for Families. She had to make a great personal sacrifice to do this, by giving up her career as a child pornography gadfly. 5. You heard that exactly right. Attached hereto is a feature article about Dorchen Leiodholdt as published in Hustler Magazine. Dorchen Leidholdt first became famous as a target of the Meese Commission on Child Pornography. 6. In an article published in May 2006 in the New York Law Journal, Dorschen Leidholdt was quoted as saying that all of the judges of the Queens Family Court are bad except that there is one good judge. His name was Judge Modica. Judge Modica happens to be the judge on this case. 7. Jill M. Zuccardy works for Dorchen Leidholdt. She should not be allowed to appear in this case. . .8. Sanctuary for Families is not a registered and licensed law firm. The last time this case was before this court, Dorchen Leidholdt had hired Paul, Weiss, Rifkind, Wharton & Garrisonto appear in this case. It is apparent that Paul Weiss has seen the light and does not want to appear any more. Probably this was pro bono work because they thought they were representing a "battered woman". Having found out that there is no battered woman involved in this case, they have discharged their duties and no longer want to be involved. . 9. Attached hereto as an exhibit is the Form 990 for Sanctuary for Families proving that Dorchen Leidholdt is the managing director of Sanctuary for Families, Inc. Attached hereto as another exhibit is a non-pornographic feature article about Dorchen Leidholdt from Hustler Magazine. Attached hereto as a third exhibit is the cover of a book by Dorechen Leidholdt entitled "The Sexual Liberals and the Attack on Feminism". . .10. Dorchen is a notorious lesbian activist. She should not be allowed to have contact with anybodies children, and especially not with my children. I can only wonder what the orientation of Jill Zuccardy is, since she works for Dorchen Leidholdt. My assigned counsel in the prior appeal to this court, Pauline Brandt, told me that she is quite familiar with Dorchen Leidholdt and Sanctuary for Families, having opposed them in many cases in the Family Court and they are "crusaders", in the words of Pasuline Brandt. They are not concerned with the mother and her children in the case before the courts. They want to make a political and social point. For example, Dorschen Leidholdt campaigns against the "Mail Order Bride Industry". That may explain her interest in this case as she is regarding Dayawathie Rankoth, who is from Sri Lanka, as some sort of mail order bride. 11. The duty of any attorney is to her client. However, the primary duty of Jill Zuccardy is to her boss, Dorschn Leidholdt. Therefore Jill Zuccardy should be disqualified from appearing in this case. . .12. This is not just a minor point. This is the whole case. Dorchen Leidholdt has been attacking me amd my family for 17 years since June 1991. If Dorchen Leidholdt and her organization Sanctuary for Families Inc. and their employee Jill Zuccardy is disqualified from this case, this case will be over and I can get my children and their mother back. The mother, Dayawathie Rankoth, is mortally afraid of Dorchen Leidholdt, which is the reason why I know so much about her. . .13, I make this affidavit in support of a motion to disqualify Jill Zuccardy, Dorchen Leidholdt and Sanctuary for Families from appearing as counsel in this case. This case in its various aspects has been going on for 17 years since 1991. I had first brought Dayawathie Rankoth to America in 1988 on a tourist visa because she was pregnant, in order that she give birth in America to confer American citizenship on our child. I entrusted her to Sister Bernadine Dominick, who ran a home for unwed mothers called the Casa Vincentia in Oakland, California. Dayawathie gave birth to Michael there on June 18, 1988. As Dayawathie was here on a tourist visa, it was necessary to take her back within the time allotted for her visa, so in July, 1988, I took her back to Abu Dhabi where we had been living. On February 10, 1989, after she had been arrested by the police, she flew back to her home in Bowalawatta, Kandy, Sri Lanka, leaving Michael with me. I later made two trips to Sri Lanka to get her out. The first trip in August 1989 I could not get her out because the civil war had reached its peak and all government offices were closed. She became pregnant with out second child, George, on that trip. In ember 1989 I made another trip to Sri Lanka and this time I was able to get her out and I brought her to Fujairah, United Arab Emirates, where we were living. As she was pregnant again, I later obtained another tourist visa for her so that she could give birth to our next child in America too. 14. In 1991, we were living in my mother's house at 917 Old Trents Ferry Road in Lynchburg, Virginia when on or about June 19, 1991, I brought Dayawathie Rankoth who was four months pregnant and our children Michael and George by car to Jamaica Queens. I had business to take care of the following morning, so I arranged for them to stay one night in a hotel and then I planned to take them the following morning back to my mother?fs house in Lynchburg, Virginia where we had been staying up until this time. Unfortunately, as I had business to take care of, I was one hour late the following morning to come back to pick them up. Upon arrival I was told that they had been waiting outside for me and had just stepped back inside. I was told that they were just coming down the steps and to wait outside as they would be down in a minute. 15. So I waited and waited and waited. I was told by another resident that Dayawathie and the children had been stopped on their way out the door taken into a office by a Miss Bivins, who had locked the door. The other residents were concerned about this because they did not know what was going on. 16. I continued to wait outside the building for more than 24 hours. I slept in my car. They never came out. Finally, the following afternoon, another resident called out the window that they had been taken out the back door and put in a closed van the previous evening and taken to an unknown location. 17. I spent the next four years looking for them, checking with every possible agency and even walking the streets of New York City trying to locate them. Shortly after their disappearance, I received a telegram from Sebastian Ike of the Child Welfare Agency in New York City who informed me that the CWA was investigating them and was considering starting removal proceedings to take the children away from the mother. However, the CWA had lost track of them too and were unable to find them just as I had been. 18. Just a day or two before their disappearance, I had started a proceeding in New York Family Court because I feared that something like this might happen. There had been prior proceedings in Queens and in Lynchburg, Virginia which had been abandoned. There were several court hearings in New York Family Court over more than one year until October 1992. Each time the judge ordered the whereabouts of the children revealed to him. Each time the agency reported that they were unable to locate the children or that the ?gsocial worker?h had refused to reveal their whereabouts. That ?gsocial worker?h has since been revealed as Sister Theresa Courtney of Sanctuary for Families, who has never been, as far as I am aware, an official of the City of New York. 19. Since Dayawathie had been four months pregnant at the time of her disappearance, I knew the due date of the delivery of her child, Anusha, the same child who is the subject of the proceeding here. At the time of the due date, I started calling every hospital in New York City that delivers babies to see if this child had been born. Finally, I hit pay dirt because St. Vincent?fs Hospital informed me that the child had been born there. I have since been wondering why they chose St. Vincent?fs Hospital since I now know that Dayawathie never lived anywhere near that hospital. 20. I went to St. Vincent's Hospital on the pretext of wanting to pay the hospital bill for the birth of the baby. They gave me the bill which showed the address of the mother to be PO Box 413, Times Square Station, New York NY. I went to that post office and filed a Freedom of Information Request for the identity of the holder of that PO Box. This revealed that the holder of this PO Box was Sanctuary for Families. 21. I found out that Sanctuary for Families was located in a church on the corner of 46th Street and Eighth Avenue in New York City. I staked out the church for a while to see if I could see Dayawathie and the children going in or out of there. When that failed, I called the New York City Police and complained that my children and their mother had been kidnapped and were being held prisoner inside. The staff of Sanctuary for Families treated this as a joke. The police searched the place but of course could not find the children. 22. I attempted to file a writ of habeas corpus in New York Supreme Court but the judge refused to sign the writ because I could not provide an actual address for the children. Finally, in 1992 I filed a suit in Federal Court in Brooklyn against Sanctuary for Families alleging a conspiracy to kidnap all of my children. The case was Sloan vs. Pattison, 92 Civil 2388 (EDNY) (RJD). Sanctuary for Families appeared and answered through Lawrence Kamin, Esq. of the prestigious law firm of Willkie, Farr & Gallagher. They filed an answer which essentially denied any knowledge of the whereabouts of the children and their mother. The case was eventually dismissed http://www.samsloan.com/judgego.htm . 23. Finally, in April, 1995, I retained Denise Grey, an investigator who specializes in finding children who have been given away for adoption. Amazingly, she found the children right away. They were living in the South Bronx, at 905 Tinton Avenue. 24. I went to that address and Dayawathie immediately invited me to come in to live with her. She introduced me to Anusha who had been born in the four years that I had been unable to locate the children. Anusha was now three and a half years old and had been told that her father was dead. 25. The children were very surprised to meet their father especially since they had been told that I was dead. George fainted. Dayawathie told me all about Sister Theresa Courtney, about how she had led her out the back door when I had been waiting out the front door. In the intervening four years, Dayawathie had been living in a variety of safe houses, especially one on Allerton Avenue in the North Bronx. 26. I had thought that after all the trouble they had gone to hide the mother and the children from both me and the Child Welfare Administration, that at least they were being kept in a good place. I was proven wrong. They were living in the most horrifying squalor imaginable. There were a million cockroaches on the walls, so many that you could not really see the walls. Their best friends were prostitutes and crack addicts named Julie, Jean and One-Legged Brenda, who lived upstairs. They regularly did business with a loan shark named Panama. 27. The children told me all about Sister Theresa Courtney, who visited them regularly and whom they very much disliked. It was obvious that Sister Theresa Courtney knew the horrifying conditions under which the children were living and was doing nothing about it. 28. I spent two weeks cleaning up Dayawathie's apartment while living there. Then, I had to go back to California. Dayawathie asked me to take the two boys, Michael and George, with me because they were wild and out of control. She wanted to keep Anusha with her. Naturally, I agreed to take the boys with me. I gave Dayawathie five hundred dollars and she bought the boys new sets of clothing for their trip to California. However, Dayawathie said to me repeatedly ?gDon?ft tell Theresa?h. She said that Theresa would be very angry if she found out that the kids were in California. Naturally, I promised not to tell Theresa. 29. We flew to California and I lived in San Francisco with my two sons Michael and George for one month. We lived at 2550 Webster Street, the Bourn Mansion, a famous building where I was helping the owner with her many court cases. Just as Dayawathie had said, the boys were far more difficult and unruly than I had imagined. They often fought with each other. The owner of the Bourn Mansion wanted to kick them out because they tore up her garden in her back yard. A bigger problem was that Michael refused to go to school. Finally, I took them over to Alameda where their half-sister Jessica was attending the Haight School. I enrolled them in the same school. 30. I was considering moving to the East Bay, where I had attended the University of California at Berkeley. We spent a few nights in Oakland. However, the owner of the Bourn Mansion, Arden Van Upp, called me back to help her with some of her legal work. Just when I got there, Dayawathie called to inform me that Theresa Courtney had found out that the children were in California. The way she had found out was that the Haight School, where I had enrolled the boys, had called the school in the Bronx which the boys had previously attended. However, that school instead of calling Dayawathie had called Theresa Courtney. Dayawathie was upset at this development and said that she was thinking of coming to California. 31. Just as we were talking on the telephone, there was a knock on the door. I answered the door and it was the police, who arrested me. I could not understand what had happened. I had spoken to Dayawathie on the phone every day since I had brought the boys to California. In fact I was talking on the phone to her at the very moment the police came knocking on the door. She was just explaining that the school in the Bronx where Dayawathie was living had informed Theresa that the two boys were in California and were attending school there. This had happened because the school in Alameda, California had contacted the school in the Bronx asking them for a transfer of the student records. The school in the Bronx had apparently breached student confidentially by telling Theresa Courtney that the boys were in California. Dayawathie of course knew that the boys were in California but had kept this information secret from Theresa. Now, Theresa had gone to her lawyer in Manhattan and had a judge in Manhattan issue a writ of habeas corpus to bring the boys back to New York. 32. The question was how a judge in Manhattan was able to do this when Dayawathie and the children were living in the Bronx. The answer is that they gave a FAKE ADDRESS. As Dayawathie explained it to me, the attorney for Sanctuary for Families was a personal friend with a judge in Manhattan. She had called the judge at home at night. The judge agreed to issue the order provided that the case was filed in Manhattan. Now, in order to get jurisdiction in Manhattan they created a fake address. The address was 410 West 40th Street, New York NY 10036. Dayawathie however lived at 905 Tinton Avenue, Bronx NY. She had never lived in Manhattan at that or any other address. I later went to 410 West 40th Street. There is a soup kitchen there operated by a church. I showed the pastor a picture of Dayawathie and the children. He said that he had never seen them before in his life. He said that Sanctuary for Families had rented an apartment upstairs during the period in question, but nobody had ever lived there and he was completely certain that Dayawathie had never been there. 33. In California they have a law which does not exist in New York or in any other state as far as I am aware that a person can be arrested and held ?gpending investigation?h, without any charges being brought. That is how they arrested me. I was never taken to court. I never saw a judge. They put me in jail in San Francisco and then transferred me to Santa Rita County Jail near Oakland. During this time, my two boys, Michael and George, were extradited to New York. 34. I was released in June with no charges ever being brought. As far as I am aware, there is no record of me even being in jail in California. After I got out, I flew back to New York. However, Dayawathie and the children had disappeared again. Sister Theresa Courtney had moved them out of 905 Tinton Avenue and taken them to parts unknown. 35. A writ of habeas corpus should not have been issued by the New York Family Court because of no jurisdiction. Dayawathie had never been awarded legal custody of the children by any court. The previous case in 1991 had been dismissed with no final order entered because Dayawathie had disappeared with the children when Sister Theresa Courtney had hidden them. Michael had been born in Oakland, California so in no way did New York have jurisdiction. Nevertheless, the boys were extradited to New York while I was still in jail. I was released from jail in California. No charge was ever brought against me. I was never even taken before a judge. However, by the time I got out the boys were gone. 36. During the two weeks that I had been living with Dayawathie at 905 Tinton Avenue, she had become pregnant with our fourth child. Upon finding out that Dayawathie was pregnant with our fourth child, Sister Theresa Courtney had arranged for Dayawathie to have an abortion. As Dayawathie later has explained it, Theresa said that since she was a nun in the Roman Catholic Church, she could not personally take Dayawathie to the abortion clinic. Therefore, she arranged for a co-worker to take Dayawathie to the abortion clinic. The abortion was performed on July 7, 1995. I know this date because I later saw documents, including an appointment letter and a bill providing this date, as the date of the abortion. 37. Thus, after I got out of jail after having been arrested by an illegal order, my sons had been extradited to New York and my unborn baby had been aborted. When I went to New York to try to locate Dayawathie again, Theresa had moved her out of the apartment at 905 Tinton Avenue and Dayawathie had disappeared to parts unknown. The case under which the writ of habeas corpus had been issued, No. V-4534/95, was dismissed. I tried to reopen it, without success. 38. Almost immediately after the abortion of July 7, 1995, Dayawathie became pregnant by a passing stranger. As a result, Geeta Rankoth, her fourth child, was born June 9, 1996. Dayawathie believes that the father was named Kamal and he was from Bangladesh but I have asked around in the Bangladesh community and there is no such person from Bangladesh in New York. The result is that instead of having a child with me as the father, Dayawathie had a child by an unknown father. Which is better? Geeta by the way is a wonderful child and I often refer to her as my step-daughter. 39. The problem Theresa now has is that between 1991 and 1995 Dayawathie could not contact me because she did not know where I was and I did not know where she was. However, now, Dayawathie knew where I was and soon she called me and gave me her new address, which was on Ft. Hamilton Parkway near Prospect Park. This was a facility operated by Sanctuary for Families. In July 1996, I went there with my other daughter Jessica, aged 7, and we met Dayawathie, Anusha and the newborn baby Geeta near the subway station and spent the day in Manhattan together. I then went with Jessica to play in the US Open Chess Championship in Alexandria, Virginia. When we got back in New York two weeks later, Dayawathie and the four children had been moved out of the Ft. Hamilton Parkway facility. Apparently, Sister Theresa Courtney had found out that we had met and had moved Dayawathie to another facility. 40. In February, 1997, Dayawathie called me again. She had just been given a new apartment on 1581 Park Avenue, New York NY This is in the Johnson Housing Project at 113th Street and Lexington.. She asked me to move in with her, which I did. We lived together there for several months. 41. Unfortunately, soon thereafter some of the denizens she had left behind in the Bronx found her. By then they had been evicted from their own apartments in the same building, 905 Tinton Avenue, and now they were staying with friends in the project across Lexington Avenue. Soon, they moved into Dayawathie?fs apartment. Before long, we had Jean, Julie, Jeans daughter, One-legged Brenda and new comers Brenda Morales and Jimmy all living with me, Dayawathie and the four children in the same two bedroom apartment. As Princess Diana later famously commented, ?gIt was a bit crowded?g. 42. I tried to convince Dayawathie to lock these people out, but she kept letting them in. They usually came home at about 2 AM. We later found out that Brenda Morales and Jimmy were HIV Positive. This is the reason they could not find any place else to live. Brenda Morales was a professional thief. She would take my children, Anusha and George, to stores and use them as decoys so that she could steal stuff. If she was caught, the police would be reluctant to arrest her because of the two children with her. Dayawathie knew about this but would do nothing to stop it. 43. Julie, Jean and One-Legged Brenda were five-dollar prostitutes, especially One-Legged Brenda. I suspect that she lost her leg to drug addiction. They often smoked Crack. One-Legged Brenda gave birth to a baby and social services immediately took the baby away from the mother. A few days after One-Legged Brenda got back from delivering the baby, I went to sleep in the apartment with nobody but me, Dayawathie and the four children there. I was hoping to have a night of peace. However, I woke up in the middle of the night to find that One-Legged Brenda had crawled into bed with me. Some men would be happy to find a woman in bed with them but I certainly was not happy, especially since I knew that One- Legged Brenda was HIV Positive and a crack addict. Dayawathie had opened the door and let Jean, Julie, Jean?fs daughter and One-Legged into the apartment in the middle of the night. Jean, Julie and Jean?fs daughter had taken over the beds in which my children, Michael, George and Anusha were sleeping. They had pushed Michael, George and Anusha onto the floor and were sleeping in their beds while my children were now sleeping on the floor. 44. Finally, I had to act, so I secretly called 911. I reported that drug addicts and prostitutes had pushed their way into our apartment, which was true. The police arrived and I opened the door. They found Jean, Julie, Jean?fs daughter and One-Legged Brenda all asleep. They woke them up and searched the place but could not find any crack. All the crack vials had been thrown down the garbage chute. 45. This was about 5:00 AM. While the police were doing this, Dayawathie called Sister Theresa Courtney and woke her up. Dayawathie did not tell Sister Threresa Courtney anything about Jean, Julie, Jean?fs Daughter and One-Legged Brenda. Instead, she complained that I was in the apartment (not mentioning that my then I had been living there for four months). The end result was that the police took away my keys to the apartment and told me to leave, which I did. Jean, Julie, Jean's daughter and One-Legged Brenda were still allowed to stay there. (I believe that Jimmy and Brenda Morales were not present at the time of this incident.) 46. I was at that time working for a real estate holding company at 24 Sixth Avenue in Brooklyn. Twice, my other daughter, Jessica, and her mother, Renuka, flew from Alameda California to visit us and each time they stayed with Dayawathie and my other three children at 1581 Park Avenue in New York. Dorchen Leidholdt found out about this and approached Renuka and asked for her help in getting me arrested, but Renuka refused to cooperate and instead went back to California. 47. During this time, Dayawathie was calling me 20 times a day at work asking for stuff and this was disturbing my boss as work and made his wife angry. I lost that job and I went to live with my friend from Afghanistan, Sayed Durali Shah, who lives in Far Rockaway. Dayawathie called me many times asking me to come back there, but I refused to go. One night at about 7:00 PM Dayawathie called to say that Anusha was very sick and needed to be taken to the hospital. However, Dayawathie could not take her because she needed to take care of the other three children. Therefore, Dayawathie wanted me to come to her home and either take Anusha to the hospital or else stay with the kids while Dayawathie took Anusha to the hospital. 48. I was very tired. I had been working as a taxi driver for Towne Taxi in Lawrence Long Island. I wanted to go to sleep, but in view of the emergency I got out of bed and made the two hour trip by subway from Far Rockaway to Spanish Harlem where Dayawathie lived. 49. When I walked in the door to Dayawathie?fs apartment, I was surprised to find Michael, George and Anusha running around playing quite happily. Anusha did not look sick at all. Only one second later two police officers came out the bedroom and arrested me. It had all been a trap set by the police. The arresting officer was Carmen Bonilla. She had sat by Dayawathie coaching her on exactly what to say. This entire story about how Anusha was sick and needed to be taken to the hospital was a pure fabrication. Dorchen Leidholdt was involved in this, because as soon as she had arrested me Carmen Bonilla called Dorchen Leidholdt on the phone to tell her the good news. I was taken to jail. 50. They had made up a purely invented story that I had come to the apartment with my 16-year-old girlfriend and had forced our way into the apartment and had hit Dayawathie?fs head against the wall. Nothing like that had ever occurred. Yes, there was such a girl, but she was 17, not 16, and we had been palling around for months but she was never my girlfriend. Dayawathie had never met her. She had never been to that apartment. Her name was Irina ikova. She was from St. Petersberg, Russia and I was giving her lessons in shogi, or Japanese chess, of which I am a top player. She had converted to Hassidim and lived in the Machon Chana in Crown Heights, Brooklyn, but every Saturday she would sneak out to come to see me. Dayawathie had never met her but had heard about her and was jealous and thus had invented this entire story. 51. I called Irina ikova from the jail and asked her to come to court to testify in my defense. She said she would come, but did not show up. Soon thereafter she went back to Russia and I never saw her again until she returned to America four years later, 52. When the date came for the court hearing, Dorchen Leidholdt and Dayawathie did not show up. In that event, they were supposed to release me but instead they made a new bogus charge against me and put me back in. Another six days passed. I was brought from the jail to the courthouse. I sat all day in the waiting room behind the courtroom. At 5:00 PM my court appointed lawyer came back to see me and told me that Judge Ross had gone for the day. Therefore, there would be no court hearing and I would be released as the case was dismissed. By not allowing me to come before him in open court Judge Ross had cheated me to my chance to complain that I had been held in jail for 12 days for no reason at all. I attach a copy of a letter from Dorchen Leidholdt saying that she was dropping the case because she could not prove it ?gby a preponderance of the evidence?h. No mention of ?gbeyond reasonable doubt?h. The letter was dated June 20 and had been delivered by hand. Nevertheless, Judge Ross had kept me in jail until June 23 even though he knew that the case was being dismissed. 53. I went to the office of the District Attorney several times demanding that Dorchen Leidholdt be criminally prosecuted for bringing this false case. However, the ADA, Eileen Chiu, said that she could do nothing because again Dayawathie had disappeared. Dorchen Leidholdt wrote a letter saying that she no longer represented Dayawathie and did not know where she was. This was another lie. Dorchen had moved Dayawathie to a facility Dorchen operated in Queens. 54. Before long, Dayawathie started calling me again. She was living in a facility operated by Sister Theresa Courtney and Dorchen Leidholdt at 166th Street and Hillside Avenue in Queens. She wanted me to come there but I refused to go. She wanted me to buy presents for the kids. Finally, I agreed to meet her at the big shopping mall on 33rd Street and Herald Square on Sixth Avenue in Manhattan. We met many times there and I would treat the kids. There were no court orders or custody orders because everything had been dissolved every time she disappeared. Still, I was afraid to come to her residence. 55. In early 1998 she got a new apartment at 40-08 12th Street, Long Island City, Queens, New York in the Queensbridge Housing Project. She did not like the place, much preferring her old apartment in Manhattan. However, she finally asked me to come live there. The deal we made was that Sister Theresa Courtney and Dorchen Leidholdt only came to see her on Saturday or Sunday and only came during the daytime because they were afraid of the black people at night. Therefore, I would never come at those times. I would maintain my own residence. If Dorchen Leidholdt or Theresa Courtney ever came at an unusual time when they were not expected, I would hide in a closet or in the stairwell on a higher floor and leave the building as soon as they entered the apartment. Dayawathie gave me keys to her apartment and to the building and I could pretty much come and go as I pleased as long as I followed those rules. 56. This has been the deal for the past seven years, from 1998 to 2005. As long as Dorchen Leidholdt and Theresa Courtney did not know about it, I could even bring friends over. My other daughters, Shamema and Jessica, have visited there. Jessica even lived there for a while. I have married and my wife Kayo and our daughter Sandra have been frequent visitors in the home. Rusudan Goletiani, who is the US Womans Chess Champion, has visited me there, as has my friend Mario Sacripante for whom I worked when I was living in Japan in 1984. I have also made friends with some of the neighbors. Thus, I have lots of witnesses who could testify that I was freely coming and going in the home for the past seven years. There has been no problem, no arrests, no custody cases, for these seven years. 57. In 1999, my other daughter, Jessica, came from California to live with me. However, she strongly preferred to stay with her half-brothers and sisters, Michael, George and Anusha, so she lived in Dayawathie?fs apartment at 40-08 12th Street, Long Island City. I enrolled Jessica in school there, the same school that Michael and George were attending. However, Dorchen Leidholdt and Sister Theresa Courtney found out about this, went to the school and objected. As a result, Jessica was not allowed to attend school there. I complained to the Board of Education, to no avail. Finally I had to send Jessica back to California. 58. There has been a big problem with Surinder Singh a/k/a Kala. He was a homeless bum that Dayawathie had met while she was living in the homeless shelter at 166th Street and Hillside Avenue. He followed her to her new apartment at 40-08 12th Street. Dayawathie says that at first he was nice. However, later, he was drunk all the time. He would beat and abuse her. She would call 911. The police would come but he would run away. Sometimes he would hide on the roof of the building and come back down after the police left. Sometimes the police would even catch him in the apartment but would not arrest him even though he was obviously drunk and abusive. He was eventually arrested six times in her apartment but then the judge would let him out after just a few hours and he would come right back. Dayawathie got a dozen orders of protection against him but he just ignored them. 59. Finally, the New York City Housing Department started an eviction proceeding against Dayawathie for letting Surinder Singh into the apartment where he would cause a constant commotion. Dayawathie got Dorchen Leidholdt to defend her in this court case. Dorchen settled the case with an order in which Dayawathie agreed not to allow Surinder Singh OR Sam Sloan into her apartment, or otherwise she would forfeit the apartment. Dorchen Leidholdt added my name to the case, even though the New York City Housing Department had never heard of me. They did not even know my name because the police had never been called about me and there had never been any trouble about me. 60. This court order has made Dayawathie fearful of allowing me to stay in the apartment. I have never spent the night there since. My visits have been brief. Meanwhile, Kala has disappeared. I suspect that he was finally deported back to India. 61. It is my absence that has allowed the two drug dealers from Tioga, Pennsylvania to move in. They moved in full time in about February, 2005. Before that, they were just coming and going from Tioga to New York. I know where they are from because one time Dayawathie went to visit them in Tioga. She had me take care of the children while she was gone and gave me the number there which she told me to call in case of emergency, but she insisted that I never reveal that I had the number. 61. From all of the above, it should be obvious that Jill Zuccardy, Dorchen Leidholdt and Sanctuary for Families are disqualified from appearing as counsel in this case. They have their own agenda which in in conflict with the best interests of the mother and the children. Rather than prove any case they might have against me, they repeatedly uproot the children and disappear with them. They have had me arrested three times but each time they have not come to court on the court date and instead have disappeared with the children again. In 1997, Dorchen Leidholdt wrote letters saying that she no longer represents Dayawathie Rankoth and does not know where she is, but Dayawathie says that there has never been even one day when Dorchen did not know where she lives because she has been living in a facility provided by Dorchen Leidholdt. Jill Zuccardy is a young lawyer who just graduated from law school in 2005 and this must be one of his first cases. He works for Sanctuary for Families and obviously does not know what he is getting into. 62. Finally, Jill Zuccardy, Dorchen Leidholdt and Sanctuary for Families tried to have me arrested again when this case was in court on October 6, 2005. This is their tactic. They cannot prove their case in court, so they want to win by having their opponent arrested and then disappearing with the children so that the father cannot find them again. This sort of behavior requires more than they be merely disqualified from this case. They should be disbarred from the practice of law. 63. Dorchen Leidholdt is a lesbian lunatic and a sick demented woman. She founded an organization called “Victims of Pornography”. While constantly railing in the press against pornography and organizing the street demonstrations one sees from time to time, her writings are actually pornographic. For example, her often cited statement that 25% of all female children are sexually molested by their own fathers is itself pornographic. For this reason, the statements by Dorchen Leidholdt are often published in pornographic literature such as Hustler Magazine. Hustler also publishes revealing pictures of Dorchen Leidholdt taken when she was younger. 64. However, I do need to tell you about this, because you can read it yourself. Attached hereto is a copy of an article Dorchen Leidholdt wrote entitled, “When Women Defend Pornography”, which is found in the book “The Sexual Liberals and the Attack on Feminism” by Dorchen Leidholdt and Janice G. Raymond. This book is filled with essays by militant lesbians, some of them quite famous. Anybody reading this essay will immediately realize that the author is seriously ill and emotionally disturbed. 65. Dorschen Leidholdt is the legal director for Sanctuary for Families, She is the boss of Jill Zuccardy who is a new hire having just graduated from Columbia University Law School in 2005. Dorchen has founded numerous groups, one of which is the “Coalition Against the International Trafficking of Women”. She uses my children and their mother as the poster children for her organization. This is obviously based on the fact that I brought the mother, Dayawathie Rankoth, from Sri Lanka to America twice to give birth to my children. 66. Dorchen Leidholdt uses my children to collect charitable contributions. She has established various 501(c)(3) corporations. In short, she uses my children to make money. Wealthy people can get tax deductions by donating to the various organizations which Dorchen Leidholdt has founded. Dayawathie Rankoth thinks that Dortchen Leidholdt is a nice lady her gives her money all the time but that is because she fails to realize that what is really going on is Dorchen Leidholdt is using her to make money. This is obviously a conflict of interest. 67. Dorchen Leidholdt has had me arrested three times. In May and June 1995, I was held in jail mostly in the Alameda County Jail in Santa Rita for 42 days on a charge of kidnapping. However, I was never brought before a judge in court. California allows a person to be held ?gPending investigation?h. Meanwhile Dorchen Leidholdt had my two sons, Michael and George, extradited to New York, which is why they are here now. 68. She had me arrested twice again in 1997. I was living in Far Rockaway Queens and driving a taxi for Towne Taxi in nearby Lawrence, Long Island. Dorchen Leidholdt had Dayawathie call me and tell me that Anusha was seriously ill and needed to be taken to the hospital and I needed to come to her house right away. What I did not realize was that Dorchen Leidholdt had taken out an order of protection against me which I had never been served with so I did not know about. When I appeared at the apartment to take Anusha to the hospital for this serious illness she was supposedly suffering from, two police officers were waiting to arrest me in a trap set by Dorchen Leidholdt. 69. Dorchen Liedholdt is doing the same thing here again. Here we have an order of protection prohibiting me from seeing any of my children including my eldest son Michael. However, Michael is not in the home. He has been arrested and is in mental hospital. His case worker is Nicole Valasko. She had called me and advises me that Michael should not be returned to the home of Dayawathie Rankoth. Michael should live with me, her father, she says. Two psychiatrists, Dr Arya and Dr. Attila Polonyi, have made the same recommendation. I am sure that, if asked, they would recommend that all three of my children be removed from that home, especially since Dayawathie has had two drug dealers living there. Yet, the court does not know about this, because of the misconduct by Dorchen Leidholdt and her subordinate Jill Zuccardy. I was not even allowed to sent Christmas presents to my children. 70. Jill Zuccardy, Dorchen Leidholdt and Sanctuary for Families tried to have me arrested again when this case was in court on October 6, 2005. This is their tactic. They cannot prove their case in court, so they want to win by having their opponent arrested and then disappearing with the children so that the father cannot find them again. This sort of behavior requires more than they be merely disqualified from this case. They should be disbarred from the practice of law. WHEREFORE, for all of the reasons set forth above, Jill Zuccardy, Dorchen Leidholdt and Sanctuary for Families should be disqualified from appearing as counsel in this case. ___________________________ Samuel H. Sloan 1664 Davidson Avenue, Apt. 1B Bronx NY 10453 samsloan@samsloan.com 917-507-7226 347-869-2465 Sworn to before me this 20th Day of May, 2008 _______________________________ NOTARY PUBLIC     Date: 07 Aug 2008 13:29:07 From: Sam Sloan Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt 80.I regret that I have not cited any cases an d this does not read like a proper legal brief. I wan t to make one further point I passed over previously. On ember 13, 1990 Dayawathie filed a child custody petition in the Family Court of Lynchburg, Virginia. Judge Dale Harris of that court conducted several hearings in that case until June, 1991. During this time Dayawathie was living with me in my mother's home in Lynchburg, Virginia. That is where she became pregnant with Anusha, who was born non ember 29, 1991. (By the way, I did not have five girls locked up in different rooms of my mothers house and I did not rape them every day.) Judge Dale Harris took jurisdiction over this case and has never transferred jurisdiction. That was when Dayawathie disappeared with the children. I brought Dayawathie to New York in my car on what was supposed to be a one-day trip because she was already under investigation by the Lynchburg Virginia Department of Social Services. Martha Tomlin was conducting that investigation. She still works there and she still remembers the case which was unusual, to say the least. It was for this reason that Appellant was afraid to leave Dayawathie alone with the children and therefore brought her to New York on that fateful day in June 1991, whereupon Sanctuary for Families and Dorchen Leidholdt grabbed her away and still has her to this day. 81.Therefore, I maintain that under the Uniform Child Custody Act, the courts of New York lack the jurisdiction to deprive me of the custody of my children. 82.Also, again, I assert that every time this cases is heard, Dorchen Leidholdt and her gay minions assert that they are from “Sanctuary for Families Center for Battered and Abused Women”. They are a private organization founded and headed by Dorchen Leidholdt and are not in any way a governmental organization. I believe that it is unfair and prejudicial for them to be allowed to announce themselves in court every time as from the “Sanctuary for Families Center for Battered and Abused Women”. For this reason alone, this case should be reversed and sent back down to the lower courts. WHEREFORE, for all of the reasons set forth above, the petition by Jill Zuccardy to dismiss this appeal on the grounds of res judicata and collateral estoppal should be denied, and the decisions by the court below should be vacated and reversed and remanded for new hearings before a different judge and Sanctuary for Families and their many attorneys should be disqualified from appearing in this case. ___________________________ Samuel H. Sloan 1664 Davidson Avenue, Apt. 1B Bronx NY 10453-7877 samhsloan@gmail.com 917-507-7226 347-869-2465 Sworn to before me this 7th Day of August, 2008 _______________________________ NOTARY PUBLIC VERIFICATION I, the undersigned, the petitioner named in the foregoing petition, being duly sworn, says: I have read the foregoing petition subscribed by me and know the contents thereof and the same is true of my own knowledge, except as to those matters herein stated to be alleged upon information and belief and as to those matters I believe it to be true. _________________________ Signature of Petitioner On the 7th Day of August, 2008 before me personally came Samuel Sloan to me known to be the person described herein and who executed the foregoing instrument. Such person duly swore to such instrument before me and duly acknowledged that he executed the same. _____________________________ NOTARY PUBLIC     Date: 07 Aug 2008 12:28:52 From: Sam Sloan Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt 75.The egregious misconduct of Judge Modica resulted in a near tragedy. Appellant had been bringing his three-year-old daughter Sandra to court with him because he could not afford a baby sitter. There is a mysterious order in the court file signed by Judge Modica directing ACS to investigate that Appellant had been bringing his three-year-old to court in a leash and harness. This order is mysterious because there was no hearing on that date. Apparently Sanctuary For Families again made an ex-party application without telling me about it. When I came to court on January 6, 2006, Judge Modica immediately had me locked up in the lunatic asylum. I am still receiving bills from the ambulance company charging me $700 for taking me to the hospital. I got out on January 11, 2006. Only two days later I was taking my daughter Sandra to school. Up until then, I had always put a harness and a leash on Sandra because she was, and still is, extremely active and accident prone. Nobody knows my daughter better than I do and this leash and harness was for Sandra's protection. However, Judge Modica had ordered ACS to investigate this and for that reason I could not put a leash and harness on Sandra any more. 76.On January 13, 2006, just two days after I had gotten out of the loony bin, I was walking Sandra to school holding her hand as tightly as I could. Across the street from her school, which was the Davidson Avenue School, there is a children's playground with slides and swings. Just as I was about ten yards from the school door, Sandra suddenly broke loose from my grip and ran across the street to the children's playground, right in front of a car that hit her and threw her ten feet into the air. 77.Sandra was taken by ambulance to St. Barnabas Hospital, where the emergency room crew did ten Cat scans. After about five hours, another ambulance took her and me to Columbia Presbyterian Hospital, where she remained for five days. 78.Fortunately, Sandra survived. It was a miracle. Has an adult been hit directly by a car going that fact we would not have survived. 79.THIS ACCIDENT WAS ENTIRELY CAUSED BY JUDGE MODICA. IT WAS JUDGE MODICA WHO FORCED ME TO TAKE THE LEASH AND HARNESS OFF OF MY FOUR-YEAR-OLD DAUGHTER SANDRA. IT WAS BECAUSE OF JUDGE MODICA THAT MY FOUR YEAR OLD DAUGHTER SANDRA RAN ACROSS THE STREET AND GOT HIT BY A CAR. THEREFORE, I AM CALLING FOR THE ARRESTS, CRIMINAL PROSECUTION AND LONG PRISON SENTENCE OF JUDGE SALDAVOR MODICA.     Date: 07 Aug 2008 12:04:28 From: Sam Sloan Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt 50.This is a new issue that just came up when Referee Negron decided that Appellant and Respondent are married NOW which means that Appellant is not married to his current legal wife. Other than her delusional testimony there is no evidence such as a marriage certificate showing that they are legally married. True, Appellant has sometimes referred to Petitioner as his common law wife in view of the fact that they have three children together, but New York Law does not recognize these common law arrangements. Just before the present case was heard, there was an Order of Filiation case heard by Magistrate Michael J. Fondacaro of the Queens Family Court on the same day, October 6, 2005. See the Order on Page 16 of the Appendix to this Appeal. This was necessary because Dayawathie has often been known to state that Appellant in not the father of Anusha and Anusha has no father at all!! A transcript of that proceeding has not been made because it did not come up until now, but a transcript or tape will show that Dayawathie testified that she has never been married to anybody and then, after receiving instructions from Alexander Karam, changing her testimony. Please note that Magistrate Fondacaro found, and his order states, that Appellant and Respondent had never been married and that Anusha was born "out of wedlock".At that hearing Alexander Karam brought with him a big red brief-appendix type document that appeared to be about 500 pages thick which turned out to be a legal document presented to the Division of Immigration and Naturalization, Department of Homeland Security for the purpose of obtaining a green card for Dayawathie Rankoth. Appellant was not allowed to see that document but it was handed up to the court who proceeded to examine it. There is now a specific provision of law that says that "Wives who are abused or battered by their U.S. citizen husbands may self-petition themselves to gain lawful permanent status (commonly called the green card). The Immigration and Nationality Act (INA) has a provision that allows abused immigrant wives to file on their own behalf without waiting for their U.S. citizen husband to file for them." The application petition is often called the “battered spouse petition” The form that must be filed is USCIS form I-360 http://www.philippinenews.com/article.php?id=2736     Date: 07 Aug 2008 11:48:38 From: Sam Sloan Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt 62.Please recall that Judge Wong had threatened to have Appellant arrested and locked up as soon as he walked in the door when this case started. Obviously this was not an idle threat. However, regarding Judge Modica's statement, “You have been convicted of a federal crime by a federal judge. You have been convicted of a federal crime by a federal judge”, this is demonstrable not true. Not only has Appellant never been convicted, he has never been arrested, charged, accused or even investigated for any federal crime. There is a website on the Internet called the Federal Prisoner Inmate Locator: http://www.bop.gov/iloc2/LocateInmate.jsp 63.Anybody who has ever been convicted of any federal crime in the last 30 years or so can be found on that website. The name of Appellant is not there. Thus, it is easily established that Appellant has never been convicted of any federal crime by any federal judge. 64.More than that, the fact that Judge Modica made a statement that can so easily be proven false demonstrates that it is actually Judge Modica who is crazy. He should be removed from the bench. 65.Throughout these proceedings going back to 1991 when they started 17 years ago when Dayawathie was pregnant with Anusha, Dorchen Leidholdt has made all kinds of allegations of sexual misconduct by Appellant. As a result, there are several court orders in this case directing various New York City agencies to investigate Appellant. The result of all this is the appropriate District Attorney's office submitted a report to the court stating that not only has Appellant never been charged with a crime in New York, but he is not under investigation for anything either. In short, Appellant has a clean record. That report is in the file of this case. Unfortunately, Appellant has not been allowed to copy that report and for that reason it is not included in the Appendix. 66.On the other hand, when this case started, it was the Respondent who was supposed to be investigated and a home study made. Appellant is not aware of any such home study ever being made. There is nothing about it in the case file to the extent that Appellant has been able to see it. However, this case was previously pending in Manhattan Family Court and Appellant submitted numerous documents from the case files there showing very negative findings regarding Petitioner by various social workers there. Although these documents were submitted to the courts and the judges said that they would study the files of the previous cases, there is no indication in their decisions that they actually did. 67.Much is made of the case of Shamema Honzagool Sloan, the daughter of Appellant. Appellant was charged with the “attempted abduction” of Shamema in Virginia. However, documents submitted to the court demonstrate that Appellant had legal custody on Shamema in New York State, where she was born. Shemema was born in Columbia Presbyterian Hospital in New York City on October 15, 1981. A few months later, Judge Anthony Mercorella of the Bronx Supreme Court awarded legal custody of Shamema to her mother, Honzagool, with visitation to the father, Appellant. When Shamema was only nine months old her mother abandoned her by returning to her native Pakistan and to this day has never returned. Shamema was left with her father, Appellant. The father subsequently obtained a modification of the existing order and was given full legal custody of Shamema. Copies of the two orders of the Bronx Supreme Court are included on Page 1266 and 1270 of the Appendix. Those orders have never been modified. No order was ever entered transferring this case to Virginia. 68.In September 1990, Charles and Shelby Roberts, fanatical followers of Shelby Roberts, hired professional kidnappers to kidnap Shamema who was then living with her father, the Appellant, in the United Arab Emirates. Shamema was kidnapped and brought to Virginia. This is well documented. Even the airline tickets that were used to bring the kidnapped eight-year-old child to America are included in the appendix. Charles Roberts even openly testified that he had paid $4,000 as a down payment towards the kidnapping of Shamema. The transcript is included. 69.The Amherst County Juvenile and Domestic Relations Court in Amherst County Virginia was well aware that Appellant had legal custody in New York having been presented with certified copies of the court orders, and they knew that Shamema had been kidnapped from the United Arab Emirates, but they proceeded to hear the petition by the Roberts for legal custody of Shamema, in clear and obvious VIOLATION OF THE UNIFORM CHILD CUSTODY ACT. All this is fully documented. 70.It is significant that Judge Michael Gamble had previously been the attorney for Charles and Shelby Roberts during the period in question up until the time he was appointed as a judge in March 1991 (after Shamema had been kidnapped and brought to Virginia). Also the two attorneys on the side of the Roberts, Linda Groome and Lisa Schenkel, were both instructors in Jerry Falwell's Liberty Christian Academy. Their whole case was that neither the Appellant, Sloan, nor the mother, Honzagool, should be allowed to have custody of Shamema, because they were both Muslims. Therefore, Charles and Shelby Roberts, non-relatives with no biological or legal connection to the child, should be allowed to have custody, because they were God fearing Christians and believers in Jerry Falwellism and “attended church regularly”. 71.If one wants read something truly pathetic, read the transcript of the so-called “trial” which is on pages 1287-1308 of the Appendix. Both witnesses, both of whom were attorneys, testified that they were not present in court on the dates of the incidents in question and in fact they knew nothing about the case. Based solely on their testimony and nothing else, Judge Gamble convicted Appellant. However, Judge Gamble convicted Appellant not on what he had been charged with, nor what the special prosecutor alleged, but for something that had not even come up during the so-called trial. (A Special Prosecutor had been appointed by Judge Gamble after the Amherst County Commonwealth Attorney had refused to prosecute the case, saying that it had no merit.) The reason Judge Gamble did all this is obvious, because, if Appellant was not guilty of something, then Judge Gamble was guilty of kidnapping because Judge Gamble's law firm had been involved in helping the Roberts kidnap the child and bring her to Virginia in the first place. 72.The case was partially appealed. The full case could not be appealed because simultaneously with convicting Appellant Judge Gamble had removed his counsel from the case. That is in the transcript. Appellant did not realize this and for that reason filed a notice of appeal one day late. 73.The part of the case that was appealed went to the Virginia Court of Appeals. That case was affirmed in a split 2-1 decision. Appellant then filed a Petition for Rehearing En Banc from his jail cell which was GRANTED. (Appendix page 1388) The case then went for a full EN Banc Hearing before the Virginia Court of Appeals. The result was a split 6-3 decision. A reading of the courts decision, which is included in the appendix but a better copy is available on Lexus Nexus, shows that all nine judges agreed that Appellant was NOT GUILTY of the charges. However, the majority of six ruled that the conviction must be upheld because Appellant's court-appointed attorney had failed to plead the right defense. The minority of three felt that Appellant was totally not guilty at all. (Appellant had been given a very weak court-appointed attorney after his paid attorney had been disqualified and removed from the case by Judge Gamble.) 74. The dissenting opinion of Judge Koontz, which is found on page 1384 of the Appendix makes it clear and obvious that Appellant was not remotely guilty and could never have been convicted by any proper court.     Date: 07 Aug 2008 10:19:21 From: Sam Sloan Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt 56.In short the entire report of Dr. Mark Rand was rubbish because instead of doing what he is supposed to do as a trained psychologist, which is to examine the patients before him, he instead was ordered by the court to go out and read a bunch of stuff on the Internet and base his findings on that. Because this vitally important part of this case was total garbage, this entire proceeding needs to be thrown out by this appellate court. 57.On ember 15, 2006, Referee Negron ordered Polgar and “her paramour Paul” who is Paul Truong in Case Number #: V-11575-06106A to stop abusing their children by forcing them to take hot sauce as punishment for playing bad moves at chess. This Vietnamese Hot Sauce Case has been widely debated over the Internet. Referee Mildred Negron, who was hearing both cases, could not possibly have known that the perpetrators in the Hot Sauce Case were the same people who had impersonated the Appellant here in this case over the Internet. Appellant tried to testify about this matter before Referee Negron but was not allowed to do so. 58.Another issue involved in this case concerns the behavior and conduct of Judge Salvador Modica. On January 6, 2006, it is true that Appellant came to court late. On the other hand on the previous court date, Judge Modica had come to work one and a half hours late. Judge Modica called the case without Appellant present and took testimony, although there was a waiting room filled with other litigants waiting for their cases to be heard. When the Appellant, Samuel Sloan, arrived in court Judge Modica started screaming at him that he had appealed a ruling by Judge Modica. Apparently Judge Miodica does not like to have his rulings appealed. Appellant had in fact filed an appeal but his appeal had been dismissed as an appeal from a non-appealable order. Judge Modica then started screaming “You have been convicted of a federal crime by a federal judge. You have been convicted of a federal crime by a federal judge.” Judge Modica screamed these words over and over again. Then Judge Modica ordered Appellant detained and taken to Elmhurst Hospital to be held there for five days for psychiatric examination and ordered the three-year-old daughter of Appellant who the Appellant had brought to court detained by ACS. Appellant was then locked up for five days. 59. Appellant requests and indeed demands that the judges of this court play the tape recording on the brief hearing before Judge Modica on January 6, 2006, which starts on page 1219 of the Appendix. This court will clearly hear Judge Modica yelling and screaming while at all times Appellant remained poli