November 17, 1994
I am writing to request the removal of Judge Michael Gamble from all pending cases involving myself and my family on the grounds that by statute, he is prohibited from ruling on our cases under the Virginia Code of Judicial Conduct and the Virginia Conflict of Interest laws. I also understand that you have the power to order the removal of a circuit court judge from a pending cases under circumstances such as these pending here.
In approximately November, 1985, I consulted and, in my view, hired Judge Gamble to represent me in a then not yet filed cases involving the custody of my daughter, Shamema Honzagool Sloan. After an interview lasting approximately one hour, I paid Mr. Gamble, then of the law firm of Pendleton & Gamble, a check for $250 as a retainer fee. However,. a few days later, the check was returned in the mail, along with a note stating that he must decline to represent me, because he had found out that his secretary was a close friend and neighbor of Charles and Shelby Roberts, whom, according to his letter, might be interested in seeking the custody of my child.
Shortly thereafter I found out that the law firm of Pendleton & Gamble was actively representing a woman named Alma Coates Dawson, who has functioned for many years as the part time girlfriend and chauffeur for my father, Leroy B. Sloan, an auditor for the IRS and a lawyer and member of the Virginia State Bar. Alma Dawson had abruptly married Dick Friend, a close friend of my father, but, upon discovering that Mr. Friend had no money and also that she would lost her right to receive alimony from one of her previous husbands, Mr. Dawson, she wanted out of that marriage after only two or three weeks time. The law firm of Pendleton & Gamble arranged the annulment and the restoration of alimony. They had also represented Alma Dawson in various other civil suits as well.
On December 31, 1985, (New Years Eve), Alma Dawson contrived to marry my father in the emergency room of the Lynchburg General Hospital while my father was being treated for a brain seizure. My father, who was 75 at the time, died 189 days later, on January 19, 1986.
Three days after my father's death, I received a telephone call from Michael Garrett, a junior partner in the law firm of Pendleton & Gamble, who told me that he represented Alma Coates Dawson and that he was demanding information about the ownership of my mother's house at 917 Old Trent's Ferry Road, Lynchburg VA (which Mr. Garrett obviously believed had belonged to my father) and on a trust fund reputed to contain something like $50, 000,000 worth of General Motors stock which had been left by my father's father, Howard Creighton Sloan. I told Mr. Garrett that as far as I knew the trust fund was a myth which had been around for a long time and that, according to my mother, my grandfather had died indigent.
Immediately thereafter, possibly the next day, I received a letter from the law firm of Pendleton & Gamble demanding further information on the above two items, plus further information about my late father's bank accounts, gasoline credit cards, safe deposit box keys and mail box.
About one month after that, I received a document from the law firm of Pendleton & Gamble renouncing my father's will and declaring that Alma Coates Dawson would take her one-third "widow's share" of my father's estate. This document was filed by the law firm of Pendleton & Gamble in the Lynchburg Circuit. A file stamped copy of that document is enclosed.
My mother and I shortly thereafter retained Stave Martin, an Amherst, Virginia attorney, to file two actions. One to obtain an autopsy of my late father, who had died at the residence and in the presence of Alma Dawson. The other was for a declaration that the purported marriage between my father and Alma Coates Dawson was null and void.
Mr. Martin filed both suits. Alma Coates Dawson was represented by Pendleton & Gamble in both cases. We prevailed in the first case, when Judge Sweeny ordered an autopsy, over the objections of Alma Coates Dawson and her attorneys, Pendleton & Gamble. The second case was filed and remained pending for some years.
While the second case was pending, Steve Martin, my attorney, joined the law partnership of Pendleton & Gamble. Almost instantly, he stopped doing any active work on my cases, which included not only the Alma Dawson litigation but also the frivolous child custody case which had been brought by Charles and Shelby Roberts. Subsequently, the law firm of Pendleton & Gamble filed a new suit against me and my mother entitled Alma Sloan v. Samuel H. Sloan and Helen Marjorie Sloan. That case is still pending in the Lynchburg Circuit Court.
On October 7, 1990, Charles and Shelby Roberts succeeded in having my daughter, Shamema Honzagool Sloan, kidnapped in the United Arab Emirates and brought to America. My attorney, Steve Martin, promptly appeared in the case, but was then almost immediately removed by Judge Janow on the grounds of conflict of interest in that he was a partner in the law firm of Pendleton, Gamble & Martin, which was suing me.
Shortly thereafter, Judge Goad died and Judge Gamble was appointed as his successor. I think that you will find it astonishing that Judge Gamble then insisted that all pending cases involving me and my family be assigned to him.
This was clearly illegal and a violation of the cannons of judicial ethics. I am in California and have access to the California Code, which states in pertinent part:
(a) a judge shall be disqualified if any one or more of the following is true:
(2) The judge served as a lawyer in the proceeding or in any other proceeding involving the same issues he or she served as a lawyer for any party in the present proceeding or gave advise to any party in the present proceeding. . . .
Later, Section 170.3 (b) (2) states:
(2) There shall, be no waiver of disqualification where the basis therefore is either of the following:
(A) The judge has a personal bias or prejudice concerning a party.
(B) The judge served as an attorney in the matter in controversy or the judge has been a material witness concerning it.
I realize that I have just cited provisions of the California Code but, as far as I am aware, the Virginia code is substantially similar.
It also needs to be mentioned that Alma Coates Dawson is a close personal friend of Charles and Shelby Roberts. It is also to be recalled that Judge Gamble initially disqualified himself from representing me because his secretary, Linda Carroll, was also a close personal friend of Charles and Shelby Roberts.
Under these circumstances, is it clear that Judge Gamble is legally disqualified from hearing any of the cases invoicing me or my family. Nevertheless, he has insisted on being the judge in every such case, including the case by Charles and Shelby Roberts for the custody of my daughter, the criminal case for the attempted abduction of my daughter and contempt, and the case for the possession of my mother's house. Regarding the criminal cases, Judge Gamble continued to act as the judge on that case and to conduct hearings and issue orders on that case, even after he had signed an order disqualifying himself from that case.
At every possible opportunity, I have objected to the participation of Judge Gamble in these cases. When he refused to recuse himself, I then filed several lawsuits against Judge Gamble. I have complained against Judge Gamble to the Judicial Inquiry and Review Commission. I have filed mandamus petitions against Judge Gamble. After all this, Judge Gamble still refuses to disqualify himself from these cases.
The end result is that my mother's house has been confiscated, the custody of my kidnapped daughter has been taken away from me, and I have been falsely convicted and sentenced to five years and ten days in prison, all through the actions of Judge Gamble. Only recently, Judge Gamble entered yet another contempt citation against me.
It is clear that Judge Gamble is personally biased against me and that he has a personal and financial interest adverse to mine. I have recently been informed that you have the authority to remove Judge Gamble from these cases and from acting in any capacity in any case involving me or my family. I request that you do so.
I am enclosing copies of various documents which clearly demonstrate that Judge Gamble is now and has always been disqualified from appearing in any case involving me or my family.
Very Truly Yours,
Samuel H. Sloan a/k/a
M. Ismail Sloan