Dear Ms. Fletcher:

I wish to have disciplinary proceedings brought against a crooked lawyer named Frank G. Davidson III, a member of the Virginia State Bar, whose address is 916 Main Street, Lynchburg VA 24504.

I have several complaints against Mr. Davidson. I will try my best to break them down into parts, but this will be difficult, as it involves a continuing course of unethical and, indeed, illegal conduct over the past more than eight years.

I first met Frank G. Davidson III in his office on Main Street in Lynchburg in approximately September or October of 1985. A Mr. Charles Roberts had asked me to meet with him. As it turned out, Mr. Roberts, who was also present, wanted Mr. Davidson to ask me to give Mr. Roberts legal custody of my then four-year-old daughter, Shamema Honzagool Sloan. I told Mr. Davidson in no uncertain terms that I would never agree to such a preposterous request. I also told Mr. Davidson that, in any event, legal custody was not mine to give, because the matter was pending before the Bronx Supreme Court, which had previously awarded custody of my daughter to her mother, Honzagool, with visitation to me.

My mother, Dr. Helen Marjorie Sloan, was present with me at this meeting with Mr. Davidson and Mr. Roberts and was even more emphatic than I that giving custody of my daughter to Mr. Roberts was totally out of the question. The only other person present was my then girlfriend from the Philippines, Apolonaria Honculada. Mr. Roberts tried to hand my mother a copy of the Holy Bible and told her to read and study it. This deeply offended my mother. Mr. Roberts gave the Bible to Apolonaria instead.

Only one or two days later, I received a telephone call from Shelby Roberts, the wife of Charles Roberts, who told me that she did not agree with the actions of her husband and that she had no desire to seek the custody of my daughter. She said that her husband had acted without her knowledge or agreement.

However, on August 27, 1986, nearly one year later, Frank G. Davidson III filed a petition for the custody of my daughter on behalf of Charles and Shelby Roberts in the Amherst County Juvenile and Domestic Relations Court. A copy of this petition and the supporting affidavit by Mr. Davidson is annexed. Please note that the Roberts did not sign these documents. They were only signed by Mr. Davidson.

The affidavit of Mr. Davidson is false and fraudulent in numerous respects. It gives, for example, under places where the child has resided in the last five years as only: Route 3, Box 159, Madison Heights, Virginia 24572.

In reality, my daughter was not then residing at that address in Madison Heights, Virginia, nor indeed was she residing anywhere in Virginia. Rather, my daughter was residing with her father and her grandmother (my mother) in New York City, a fact well known to Mr. Davidson.

More than that, my daughter, who was born in New York City on October 15, 1981, had originally resided with her natural mother in Bronx, New York, within the last five years. This fact, also known to Mr. Davidson, was not disclosed in the affidavit. In late 1982, when my daughter was less than one year old, her natural mother had returned to her native Pakistan, without her daughter, and had never returned. This left my daughter in the natural custody of me, her father, and I had resided with my daughter in New York City, another fact not disclosed by Mr. Davidson.

More than that, in 1981, very shortly after the birth of my daughter, I had filed a custody suit in the Bronx Supreme Court, because her mother had stated that she intended to take our daughter with her back to her native Pakistan. A trial of six full days had resulted in March and April, 1982. This trial had generated national and international publicity. At the conclusion of the trial, the court had granted custody to the mother, "provided that she remains with the child in the State of New York". It was for this reason that when the mother returned subsequently to her native Pakistan, she did not take the child with her. The Bronx Supreme Court has since ruled that from the date of the mother's departure, I have had "de facto" custody of my daughter. The name of that case is Sloan v. Awadallah and Honzagool, Index No. 17815/1981, Bronx Supreme Court.

All of these facts were well known to Mr. Davidson at the time he signed and filed the annexed affidavit. Mr. Davidson knew that my daughter had resided at various addresses in New York City within the past five years. Accordingly, Mr. Davidson committed the crime of perjury, which is, of course, a grounds for disbarment.

Furthermore, Mr. Davidson knew that under the Uniform Child Custody Act, which Virginia has ratified, there was no legal basis for Virginia to claim jurisdiction over this matter. Indeed, on September 11, 1986, Mr. and Mrs. Charles Roberts applied for and obtained a writ of habeas corpus in the Supreme Court of New York County, alleging that my daughter was in New York City (which she was). The name of that case is Mr. and Mrs. Charles Roberts v. Ismail Sloan, Index No. 20991/1986, Supreme Court, New York County. Mr. Davidson has since indicated that his law firm retained the New York counsel, Weidman & Weidman, who filed that habeas corpus petition. Mr. Davidson therefore knew that his petition for custody in Virginia was frivolous, without legal basis and without jurisdiction.

But this was only the beginning. From that day until the present, Mr. Davidson has engaged in a monstrous course of harassment of myself, my mother and my entire family. In September, 1986, Mr. Davidson obtained an ex-party court order "awarding" the custody of my daughter to the Amherst County Department of Social Services, even though he knew that my daughter was not in the Commonwealth of Virginia at the time. The Amherst County Department of Social Services had not filed any sort of agency petition and was not even aware of the existence of my daughter.

The petition for the custody of my daughter was never served on me or my mother. Thus, the Virginia courts clearly never had jurisdiction over this matter. Indeed, it was only a few days ago that I first obtained a copy of the affidavit of Mr. Davidson dated August 27, 1986, a reason why I am complaining now.

Thereafter, Mr. Davidson contacted the Virginia State Police, the F.B.I., the State Department and Interpol, trying to have me and my mother arrested and my daughter detained and brought to Virginia. As result, numerous attempts were made thereafter to have my daughter kidnapped and brought to Virginia. My mother and I were forced to leave the United States of America altogether because of the persistence of these kidnapping efforts. I repeatedly complained about this to the F.B.I. More than four years later, on September 3, 1990, my daughter barely escaped from being kidnapped in Bangkok, Thailand. Finally, on October 7, 1990, my daughter was kidnapped in Fujairah, United Arab Emirates and brought to Madison Heights, Virginia.

Meanwhile, my mother, Dr. Helen Marjorie Sloan, a retired child psychiatrist, had in 1989 filed suit against Mr. Davidson, alleging that he was conspiring to kidnap her and her granddaughter, as well as conspiring to seize all of my mother's assets and to sell her house and to have my mother locked up in a nursing home. That suit was dismissed in July, 1990. On September 3, 1990, my mother was, in fact, kidnapped out of her hospital bed in Bangkok, Thailand and forcibly brought to America, just as she had predicted in her complaint that she would be. A copy of the complaint in my mother's lawsuit is annexed. Please note that Mr. Davidson is named as one of the defendants.

On September 10, 1990, seven days after she had been kidnapped and then brought to America, my mother was forced to sign statement asking that her appeal in her suit against Mr. Davidson and others be dismissed. A copy is enclosed. Note that my mother's signature is extremely weak and shaky, as compared with notarized affidavits she had signed several months earlier. My mother had been extremely ill in the Bangkok General Hospital with a life-threatening case of bronchitis, pneumonia and high fever. The defendants in her lawsuit had taken advantage of her illness and had arranged the payment of $27,000 plus expenses to a professional kidnapper named Boonchoo Yensabai to have my mother kidnapped and brought to America. This explains her difficulty in signing her name. Note that Mr. Davidson exploited this situation to his benefit, to have her appeal against him dismissed.

On October 19, 1990, less than two weeks after my daughter was kidnapped in the United Arab Emirates and brought to Virginia, the law firm of Davidson & Sakolsky, Mr. Davidson's law firm, filed a new suit against me for the custody of my daughter, even though Mr. Davidson well knew that my daughter had been in the United States for only ten days and then only as a result of having been kidnapped and brought here. My daughter had just turned nine years old at the time.

On November 7, 1990, I arrived in the United States with my remaining son, Michael Sloan, aged 2 years, five months. On December 17, 1990, I filed a lawsuit against Mr. Davidson in the United States District Court, Western District of Virginia, Lynchburg Division, alleging among other things his personal involvement in the conspiracy to kidnap my mother and my children. On December 19, 1990, only two days later, a hearing was held before United States District Judge James C. Turk. In the courtroom, while waiting for Judge Turk to arrive, I over heard Mr. Davidson state to W. Edward Meeks, the Amherst County Commonwealth Attorney: "I am going to kill him" (meaning me).

Mr. Meeks, an officer of the law, appeared shocked to hear this. After the hearing had started, I immediately reported this death threat to Judge Turk. Mr. Davidson responded by stating: " I didn't mean to kill him physically. I mean to kill him financially. I intend to drive him into bankruptcy, to take all of his money." These remarks were taken down by the court reporter and are part of the record of that proceeding.

My mother, a medical doctor who is retired after 41 years of service with the Commonwealth of Virginia, has (or at least then had) a net worth of about $300,000 (which is, of course, the factor which makes Mr. Davidson interested in pursuing this matter) plus she receives a pension check of more than $2500 from the Virginia Supplemental Retirement System plus a social security check in the amount of more than $1500 per month.

My brother, Creighton W. Sloan, who has been in active almost daily contact with Charles and Shelby Roberts since 1984 and who is the primary instigator of all of this litigation, thereafter filed several lawsuits to seize control of my mother's house, assets and other personal property. On November 8, 1990, the day after my arrival in America, my brother had my mother transferred from a nursing home in the area of Silver Spring, Maryland, where she had been confined subsequent to her being kidnapped, to his own residence in Aiken, South Carolina, in order forcibly to prevent my mother from running away and rejoining me and her three grandchildren.

On January 16, 1991, my brother filed an ex-party application in the Aiken County Probate Court to have himself appointed as the guardian and conservator of my mother, without notifying me. My brother failed to notify the court or even his own attorney in South Carolina that actually I had a power of attorney regarding my mother's affairs, and that my brother did not have any such power of attorney.

In April, 1991, the Aiken County Probate Court denied my brother's request for the appointment of himself as the conservator of my mother and instead appointed the N.C.N.B. Bank as the conservator. (The N.C.N.B. bank has since merged with NationsBank.) Almost immediately thereafter, my brother had my mother confined to a nursing home against her will in Aiken, South Carolina. My mother remains locked up in that nursing home to this day.

In November or December, 1991, My brother filed a suit in the Lynchburg Circuit Court seeking to sell my mother's house. The complaint in that action was amended in May, 1992. Thereafter, some time in or about September 1, 1992, Frank G. Davidson III requested to be appointed as my mother's guardian ad litem in that pending litigation. I have never yet seen a copy of any order appointing Mr. Davidson as my mother's guardian ad litem and I believe that, in fact, there is no such order. Since at least September, 1992, Mr. Davidson has identified himself and has signed papers as the guardian ad litem of my mother.

This is highly improper, as Mr. Davidson is clearly adverse to my mother, and has been so since at least 1985. Mr. Davidson was the legal instigator of all of this litigation against myself and my mother. My mother was clearly adverse to Mr. Davidson's frivolous suit on behalf of Charles and Shelby Roberts for the custody of my daughter (my mother's beloved granddaughter). My mother filed a suit against Mr. Davidson in 1989 alleging Mr. Davidson's involvement in a conspiracy to kidnap herself and her granddaughter, and to obtain her house, assets and property. I filed a federal suit against Mr. Davidson in December, 1990 and filed another one in May, 1992. (The latter is still pending on possible certiorari.) For Mr. Davidson to claim to act as the guardian ad litem of my mother is like the fox claiming to guard the henhouse.

On August 18, 1992, I was arrested in San Francisco on the frivolous charge of the "attempted abduction" of my own daughter (the same daughter who had actually been kidnapped from me) and was thereafter extradited to Virginia. In about November, 1992, I was brought to court from the Lynchburg City Jail for a hearing on my brother's civil suit to sell my mother's house. Mr. Davidson appeared as the "guardian ad litem" of my mother. Mr. Davidson supported the sale of the house, even though my mother has often stated that she will never agree to the sale of her house for so long as she is alive, and that she wants to live in that house until she dies.

I was convicted on January 13, 1993. (My conviction was affirmed by a 2-1 vote of the Virginia Court of Appeals on October 4, 1994 but, on November 14, 1994, the Virginia Court of Appeals granted my petition for a rehearing en banc. See Sloan v. Commonwealth, 0934-93-3). In February, 1993, a hearing was held on the proposal by Cecil W. Taylor, the attorney for my brother, to sell my mother's house to one Dorothy C. Taylor for a paultry $75,000. Mr. Davidson made no objection, even though the house was obviously worth at least $150,000.

The house was ultimately sold for gross proceeds of $75,000. From that was deducted attorney's fees in excess of $11,000, which was well above the statutory fee, part of which was paid to Frank G. Davidson, as the guardian ad litem for my mother. Also deducted from the $75,000 was more than $10,000 in moving and storage expenses plus $5,000 in real estate broker's fees. After all these deductions, only $47,000 was left. The same house is now being offered for sale on the market at the price of $167,500!!!

The only justification ever given for the sale of the house was the expense of annual property tax and insurance, amounting to about $900 per year. However, with the consent and agreement of Mr. Davidson, the furniture and other contents of the house were placed in a storage facility with Moody Moving & Storage Company of Concord, Virginia, which has since been charging $850 per month for storage over the past two years. Mr. Davidson recently agreed to the payment of the latest storage bill in the amount of $10,000, meaning that only $37,000 is now left from the sale of my mother's fully paid for house, a house now being offered on the market for $167,500.

In January, 1991, a civil suit was filed against me by the law firm of Davidson & Sakolsky, as attorneys for Charles and Shelby Roberts, seeking $200,000 in damages for their costs and expenses involved in the kidnapping of my daughter. In March, 1993, at a hearing in this civil suit by Charles and Shelby Roberts against me, Mr. Davidson testified that his objective in all of these proceedings has been to break me financially, and to force me into bankruptcy.

Mr. Davidson has now succeeded in his objective because, on September 8, 1994, I filed for Chapter 7 bankruptcy. Almost all of my liabilities were the result of these various suits involving Mr. Davidson and his law firm against me (with the exception of some 20-year-old debts to stockbrokers incurred primarily in 1973).
As you can see from this letter, in the course of the last eight years, Mr. Davidson has engaged in so many ethical violations that it is almost impossible to enumerate them. All of this started from his false and fraudulent affidavit dated August 27, 1986. More recently, my mother's assets have been squandered to the extent of $130,500, the current market value of my mother's house, minus the proceeds of the sale after Mr. Davidson's fees and other expenses.

Accordingly, I request that you institute disciplinary proceedings against Mr. Davidson, leading to his permanent disbarment from the practice of law.

Very Truly Yours,

Ismail Sloan a/k/a
Samuel H. Sloan