Complaint to Judge Little, Aiken County Probate Court

Samuel H. Sloan
920 Belmont Avenue
Brooklyn NY 11208

(718) 277-6957

January 12, 2004

Hon. Angela Little
Associate Probate Judge
Aiken County Probate Court
P. O. Box 1576
Aiken, South Carolina 29802-1576

Re: Helen M. Sloan Conservatorship,
Order certifying that Bank of America is the Conservator
This document, signed by Judge Little, shows that the Bank of America has been the conservator since April 12, 1991. Click to enlarge.

Dear Honorable Judge:

In the more than two months since the Aiken County Probate Court ruled in favor of Creighton and appointed him as his mother's personal representative, Creighton has done absolutely nothing to implement the court's decision. He has not taken any steps to post a bond as he was required to do, nor has he turned over the funds to his lawyer. In short, the situation is exactly the same as it was before the hearings in court. Creighton has stolen more that one million dollars of his mother's money and has possession of these funds in violation of numerous court orders and has shown no inclination to distribute the funds in his possession to the rightful heirs. Creighton has claimed that he has not been able to implement the court's decision, because he has been unable to take off time from work. However, I have found out that three weeks ago Creighton traveled to Las Vegas Nevada where he attended a party and engaged in gambling and other activities. I have found a picture of Creighton taken on December 20, 2003 at the New York New York Hotel in Las Vegas and posted on the Internet on December 21, 2003. That picture can be found at:

In this picture, Creighton's face appears directly above the head of the groom. It appears that Creighton was trying to hide his face and did not want his picture appearing. He is looking down at the ground. He probably did not see the camera pointed at him. Then, in another picture obviously taken only seconds later, Creighton has scampered away. That picture was posted at: It has since been removed.

This is the only picture of Creighton among the 50 posted photos of this wedding party. However, there are several clear pictures of his son, Cassel Sloan, from the same party, for example at:

Cassel is standing at the left facing away from the camera. Also, in the same group of pictures are several clear photos of Charles and Shelby Roberts. For example at:

These are the same religious fanatics who have repeatedly kidnapped or tried to kidnap my children. Charles Roberts also filed a claim in your court against my mother's estate. It is to be recalled that Creighton testified in court under oath that he had no involvement with the Roberts. Yet, here is the proof that they traveled from Virginia and South Carolina to Las Vegas to attend the same party together. It is obvious from Creighton's entire conduct during the 18 years that this litigation has been going on that he intends to keep all of the money for himself and never to distribute it.
First Citizens Bank statement
First Citizens Bank statement shows that Creighton wrote $20,000 worth of checks on his mother's account in May, 2002. Click to enlarge.

It can be readily established that the amount of money left by my mother is considerably greater than Creighton has revealed. He is obviously hiding money. In addition, he has opened two bank accounts in his motherfs name since 1994. One is at the Sun Trust in Lynchburg, Virginia. The other was at First Citizens Bank, Columbia SC. This was a violation of various court orders, as the Bank of America has been the conservator since April 12, 1991. Creighton also removed $200,000 from the Bank of America in Lynchburg some time after 1994, even though the Bank of America was the court-appointed conservator. Creighton cleaned out the bank account, even though the account had been frozen since 1986 by court order. The whereabouts of those funds is unknown.

I enclose letters to this court from Nations Bank dated 1992 stating that they are awaiting the transmittal of funds from the bank in Lynchburg, Virginia. In fact, however, the Nations Bank never received the money. Creighton took the money and ran. It is unbelievable that the banks involved, both of which merged into the Bank of America, could make mistakes like these, but they did and obviously they are liable for the money.

I enclose a bank statement I have obtained from First Citizens Bank, Columbia South Carolina. It shows that in April 2002, just the one month covered by the bank statement, Creighton wrote $20,420.80 in checks on the account. This was obviously a violation of orders of your court, as the Bank of America and not Creighton was the conservator, and Creighton had no authority to open and operate that account. This is a relatively recent account, opened by Creighton in the last few years and certainly more recently than the April, 1991 date when the Nations Bank, now Bank of America, was appointed as the conservator.

Similarly, I have a bank statement from SunTrust Bank in Lynchburg. Again, the account was opened relatively recently and has a substantial amount and Creighton has been operating the account. For example, on April 9, 2002, Creighton withdrew $3,463.46 from that account, again a violation of court orders because the Lynchburg funds were supposed to be frozen. My mother never had an account with SunTrust or with any predecessor bank.

I have recently found a curious letter in the files of the Aiken County Probate Court. A copy is enclosed. It is dated June 10, 1992 and was from the NationsBank, the court-appointed conservator. It states:

"Mrs. Sloanfs son, M. Ismail Sloan, has filed another suit on May 18, 1992 that is of course holding up proceedings again."

The bank mixed up the two brothers. It was Creighton who filed the suit in Lynchburg Circuit Court, not I. In that 1992 suit, Creighton claimed to have been appointed conservator by the South Carolina Probate Court, but that was not true. It was the NationsBank, and not Creighton, that had been appointed. The Bank of America is the successor to the NationsBank. In that 1992 suit, Creighton, by falsely claiming to be the conservator, obtained possession of his motherfs house, sold it and kept the money. The Virginia court clearly had no jurisdiction for that and for another reason, which was that the Virginia case had been removed to Federal Court and thus the Virginia State Court no longer had jurisdiction over the matter. I enclose documents proving this. This is the reason why I want to go back and recover possession of the house, which was obviously sold by Creighton illegally and without jurisdiction or legal authority.

I have found another letter in the files of the Aiken County Probate Court dated May 16, 1995 stating that the NationsBank did not open a conservator account until April, 1995, although the bank had been appointed the conservator on April 12, 1991, four years earlier. This means that for at least those four years Creighton was able to collect and keep his motherfs pension and social security checks amounting to $5,000 per month. This alone comes to at least $240,000 and Creighton has never accounted for those funds.

For all of these reasons, most especially the reason that after two more months Creighton has done nothing to implement the courtfs decision, and obviously has no intention of doing anything and no reason to do anything either as he has already stolen more than half of his motherfs money and has secreted it away, and meanwhile is gallivanting around Las Vegas spending the stolen funds freely, I demand that Creighton be removed as his motherfs personal representative and that I be appointed in his place. Creighton should be required to account for all of the funds in his possession since April, 1991.

Very Truly Yours,

Samuel H. Sloan

Copy to:

Catherine H. Kennedy
Attorney for Creighton Sloan
Nelson, Mullins, Riley & Scarborough, LLP
1330 Lady Street
PO Box 11070
Columbia, South Carolina 29201

Creighton W. Sloan
102 Indian Creek Trail
Aiken, South Carolina 29803

Patricia L. Harrison
611 Holly Street
Columbia, South Carolina 29205

William H. Tucker
Attorney for Creighton W. Sloan
111 Park Ave SW
Aiken SC 29802

Paige Weeks Johnson
Johnson, Johnson, Whittle & Snelgrove, P.A.
PO Box 2619
117 Pendleton St NW
Aiken, South Carolina 29802-2619

David C. Dickey
Attorney for Helen M. Sloan
20 Willow Lane
P.O. Box 218
Stanardsville, Virginia 22973-0218

Leighton S. Houck
Caskie & Frost
Attorney for Bank of America
2306 Atherholt Road
P.O. Box 6360
Lynchburg, Virginia 24505

Killis T. Howard
Attorney for Creighton W. Sloan
712 Court St.
Lynchburg, VA 24504-1406

Preston Sawyer
801 Court St.
Lynchburg, VA 24504-1534

Pamela Mitchell
Bank of America Trust Department
801 Main St.
Lynchburg, VA 24501-1537

Hank Moore
Roth Management Advisory Center, SunTrust Bank
919 East Main Street
Richmond VA 23219

Margaret K. Lippard, Account Administrator
SunTrust Bank
P.O. Box 678
1010 Main Street
Lynchburg VA 24501

Branch Manager
First Citizens Bank
1230 Main Street
P.O. Box 29
Columbia SC 29202

Massie Ware
The Pettyjohn Company
1925 Atherholt Road
Lynchburg VA 24505

Tom Cox
Administrator, Bank of America
1901 Main Street
Columbia SC 29201

James H. Massie III
150 Shrader Drive
Madison Heights, VA 24572

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