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  • Motion to disqualify Alexander Karam, Dorchen Leidholdt and Sanctuary for Families fr

    FAMILY COURT OF THE STATE OF NEW YORK
    CITY OF NEW YORK - COUNTY OF QUEENS
    __________________________________________________ X
    In the Matters of:
    :
    SAMUEL SLOAN,
    :
    Petitioner
    : Docket
    # V-11657-05
    -against-
    :
    DAYAWATHIE RANKOTH,
    :
    Respondent
    __________________________________________________ _X
    :
    DAYAWATHIE RANKOTH,
    :
    Petitioner
    : Docket
    # O-18182-05
    -against-
    :
    SAMUEL SLOAN,
    :
    Respondent
    __________________________________________________ ____X
    NOTICE OF MOTION TO DISQUALIFY ALEXANDER KARAM,
    DORCHEN LEIDHOLDT AND SANCTUARY FOR
    FAMILIES FROM APPEARING AS COUNSEL IN THIS CASE
    __________________________________________________ ____X

    PLEASE TAKE NOTICE that upon the annexed affidavit of Samuel H. Sloan
    sworn to the 28th day of November, 2005, the Undersigned hereby moves
    this court for a order disqualifying disqualify Alexander Karam,
    Dorchen Leidholdt and Sanctuary for Families from appearing as counsel
    in this case.


    ___________________________
    Samuel H.
    Sloan
    1664 Davidson
    Avenue, Apt. 1B
    Bronx NY 10453


    [email protected]
    917-507-7226
    347-869-2465


    FAMILY COURT OF THE STATE OF NEW YORK
    CITY OF NEW YORK - COUNTY OF QUEENS
    __________________________________________________ X
    In the Matters of:
    :
    SAMUEL SLOAN,
    :
    Petitioner
    : Docket
    # V-11657-05

    -against-
    :
    DAYAWATHIE RANKOTH,
    :
    Respondent
    __________________________________________________ _X
    :
    DAYAWATHIE RANKOTH,
    :
    Petitioner
    : Docket
    # O-18182-05

    -against-
    :
    SAMUEL SLOAN,
    :
    Respondent
    __________________________________________________ _X

    MOTION TO DISQUALIFY ALEXANDER KARAM,
    DORCHEN LEIDHOLDT AND SANCTUARY FOR
    FAMILIES FROM APPEARING AS COUNSEL IN THIS CASE
    __________________________________________________ _X

    Samuel H. Sloan, being duly sworn, deposes and says:

    1. I make this affidavit in support of a motion to disqualify
    Alexander Karam, Dorchen Leidholdt and Sanctuary for Families from
    appearing as counsel in this case. This case in its various aspects
    has been going on for 14 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 November 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.

    2. 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.

    3. 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.

    4. 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.

    5. 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.

    6. 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 "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.

    7. 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.

    8. 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.

    9. 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.

    10. 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 .

    11. 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.

    12. 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.

    13. 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.

    14. 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 ****roaches 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.

    15. 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.

    16. 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.

    17. 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.

    18. 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.

    19. 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.

    20. 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.

    21. 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.
    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.

    22. 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.

    23. 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.

    24. 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.

    25. 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.

    26. 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.

    27. 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.

    28. 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.

    29. 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'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".

    30. 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.

    31. 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's daughter and One-Legged 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.

    32. 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.

    33. 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 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.)

    34. 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.

    35. 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.

    36. 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.

    37. 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.

    38. 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 Novikova. 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.

    39. I called Irina Novikova 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,

    40. 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 "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.

    41. 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.

    42. 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.

    43. 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.

    44. 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.

    45. 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.

    46. 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.

    47. 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.

    48. 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.

    49. 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.

    50. From all of the above, it should be obvious that Alexander Karam,
    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. Alexander Karam 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.

    51. Finally, Alexander Karam, 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, Alexander Karam,
    Dorchen Leidholdt and Sanctuary for Families from appearing as counsel
    in this case.



    ___________________________
    Samuel H.
    Sloan
    1664 Davidson
    Avenue, Apt. 1B
    Bronx NY 10453


    [email protected]
    917-507-7226
    347-869-2465
    Sworn to before me this 28th Day
    of November, 2005

    _______________________________
    NOTARY PUBLIC
    AFFIDAVIT OF SERVICE

    Docket #
    V-11657-05

    STATE OF NEW YORK, COUNTY OF QUEENS SS:

    Kayo Kimura, being sworn says: I am a party to this action and I am
    over 18 years of age.

    At 8:00 AM on November 28, 2005, I served a true copy of the attached
    affidavit, in the following manner:

    By mailing a true copy of the same to:

    Alexander Karam
    Attorney for Sanctuary for Families
    67 Wall Street, Suite 2211
    New York NY 10006

    www.sanctuaryforfamilies.com
    (212) 349-6006 ext. 320

    Vladimir Cadet
    89-31 161st Street, Suite 505
    Jamaica NY 11432
    718-297-0004



    ________________________


    Sworn to Before me this 28th
    Day of November 2005


    _________________________
    NOTARY PUBLIC



  • #2
    Motion to disqualify Alexander Karam, Dorchen Leidholdt and Sanctuary for Families fr

    On Mon, 28 Nov 2005 12:06:12 GMT, [email protected] (Sam Sloan)
    wrote:
    FAMILY COURT OF THE STATE OF NEW YORKCITY OF NEW YORK - COUNTY OF QUEENS
    Nobody cares about your personal life, Sam! Nobody cares!


    Phil
    ======
    visit the New York City Homebrewers Guild website:
    http://www.hbd.org/nychg

    Comment


    • #3
      Motion to disqualify Alexander Karam, Dorchen Leidholdt and Sanctuaryfor Families fro

      Sam Sloan wrote:
      FAMILY COURT OF THE STATE OF NEW YORK CITY OF NEW YORK - COUNTY OF QUEENS __________________________________________________ X
      It doesn't do a bit of good to post this crap on the
      internet. We don't care. We can't do anything about it. As
      it is, the "affidavit" looks like it was written by a
      juvenile who pretends to know legal language.


      --
      Blogging at http://HexagonalPeg.blogspot.com

      Comment


      • #4
        Motion to disqualify Alexander Karam, Dorchen Leidholdt and Sanctuary for Families fr

        Sam,

        This is extremely long and rambling. You supply huge amounts of pointless
        history and never explain why these folks should be removed as counsel.
        Sanctuary for Families is an organization not a lawyer and so will not
        appear in court as a counsel. You clearly do not like Leidholdt but do not
        offer valid reasons for her removal. All you say about Karam is that he is
        inexperienced, which is not a reason for removal.
        You should also address your standing in this matter to the court. These
        are not your lawyers so why should the court listen to you. It is unlikely
        that a court will require the other side to have counsel that meets with
        your approval.

        Good luck,
        Dave M.


        Comment


        • #5
          sam sam sam

          dude you need some councelling or something. you rumbled through and i fail to understand your primary objective. All i could gather was you are a disturbed bitter individual who might use some rehab,

          Comment

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