Follow-up Complaint to Virginia Judicial Inquiry and Review Commission

Sam Sloan
1320 Bushwick Avenue
Brooklyn NY 11207

(718) 602-2737

March 2, 1999

Donald H. Kent, Counsel
Virginia Judicial Inquiry and Review Commission
P. O. Box 367
Richmond, Virginia 23218-6636

Dear Mr. Kent,

Based on my conversations, you are apparently unsatisfied with the complaint I have filed thus far, although I feel that what I have submitted is more than sufficient to start and inquiry and indeed is conclusive to prove that Judge Gamble has committed serious violations of the Code of Judicial Conduct. In addition, some of the things you are demanding are quite impossible for me to provide, such as case numbers and file numbers, because Judge Janow has acted so far outside the law that there actually was no case when he issued many of his orders, especially the most Draconian orders.

For example, look at the order of Judge Janow dated August 25, 1986, a copy of which I enclosed. You will see that there is no case number. That is because the Roberts had not yet filed their case. They did not file a case until August 27, 1986, two days later, as can be seen from Judge Gamble's order dated November 18, 1991, a copy of which is also enclosed.

The order dated August 25, 1986 constituted egregious misconduct on the part of Judge Janow, for numerous reasons. A case had not yet been filed. The Roberts were not proper parties before the court. Their lawyer, Frank Davidson III, had simply called Judge Janow on the telephone and said an emergency existed because the Roberts wanted to enroll my daughter in their church, and I would not agree to this. The Roberts were not parents or relatives of any kind of my daughter. They certainly had no right to try to determine the religion of my daughter. I thought their request was ridiculous and that it was even more ridiculous that Judge Janow agreed to hear them. Later, I was flabbergasted to learn from my attorney that Judge Janow had granted their request, even without an actual court hearing involving the testimony of witnesses.

The pertinent part of the order was:

This 25th day of August 1986, appeared Ismail Sloan with Counsel, Stephen Martin; Mr. and Mrs. Charles Roberts with counsel, Frank G. Davidson, III; and J. Thompson Shrader, Esquire, Court appointed guardian ad litem for Shamema Honzagool Sloan with regard to the enrollment of Shamema Honzagool Sloan in school and based upon the fact of the child having attended Temple Baptist School in the past, and the final hearing is set for October 8, 1986, at 1:30 p.m. the court orders that this matter remain in status quo and allows the child, Shamema Honzagool Sloan to be enrolled in Temple Baptist School by Mr. and Mrs. Charles Roberts pending the outcome of the final hearing."

At the time of this order, Judge Janow must have believed that Charles and Shelby Roberts had my daughter, which was not true. This was one problem Judge Janow created by not conducting a hearing. Had he heard testimony on this matter, he would have learned that the Roberts did not have my daughter. I had my daughter. The Roberts were asking me to let them take my daughter on a trip to Virginia Beach that weekend, but I had no intention of agreeing to this.

On September 3, 1986, Judge Janow called Judge Kristin Booth Glen of the Supreme Court of New York and Judge Glen informed him that my daughter was in New York and Judge Glen had seen my daughter in her courtroom. The next day, on September 4, 1986, Judge Janow issued the following order:

"For purposes of interpretation and enforcement of this order, the court doth award legal custody of Shamema Honzagool Sloan to the Amherst County Department of Social Services.

"The Amherst County Department of Social Services shall have the authority to place said child with any appropriate individual or agency including Mr. and Mrs. Charles Roberts."

This order was illegal, just as the previous order had been, but for a different reason. By then, the Roberts had filed their case. I had not been served because I was in New York with my mother and daughter. Judge Janow wanted my daughter brought to Virginia, even though Virginia clearly had no jurisdiction in view of a prior custody order in New York State. Since he could not legally award custody to the Roberts, he decided to bring them in through the back door by having them appointed as foster parents. The problem was: The Amherst Department of Social Services had never petitioned for the custody of this child and did not even know that the child existed. Furthermore, Virginia had no jurisdiction because neither the child nor her parents were in Virginia.

Also, in his order, similar to the pervious order, Judge Janow implies that a hearing was held on September 3, 1986. This was not true. The court records indicate no hearing on that date and my lawyer Steve Martin at the time told me that there had been no hearing or court appearances. Judge Janow just did this completely on his own, without consulting anybody.

I never saw either of these orders until months later, in January, 1987, by which time I was in Abu Dhabi, United Arab Emirates. Had Judge Janow conducted himself in a legally proper way, this would never have happened. At the same time, had he done things legally, he could never have achieved the result he wanted, which was for the Roberts to obtain custody of my daughter.

However, the most important point is that in view of the order dated September 4, 1986, which was the last order signed by Judge Janow until February, 1991, Charles and Shelby Roberts did not have custody of my daughter. The Amherst County Department of Social Services had custody except for the fact that they did not have physical possession of my daughter. Thus, when Charles Roberts kidnapped my daughter in October 1990, he did not have custody, neither in the United Arab Emirates where the kidnapping took place, nor in Amherst County, Virginia where he brought my daughter. Charles Roberts should clearly have been arrested and prosecuted for kidnapping on the spot.

After the September 4, 1986 order, Judge Janow did not enter another order until February, 1991. He did not even issue an order in October, 1990 when my daughter was kidnapped, because he knew that any order he issued would be immediately appealed by me. Numerous laws of Virginia were violated or skirted. For example, pursuant to section 16.1-253.4 of the Code of Virginia, within 72 hours after the Department of Social Services takes custody of a child, there must be a hearing in court. In my case, there was no 72 hour hearing. In fact, I was never notified that my child was even in Virginia. They said that the reason there was no 72 hour hearing was the Department of Social Services had never petitioned for custody and did not want custody of this child. Judge Janow had forced them into this situation by issuing an order which the Department of Social Services had never requested.

After his order dated September 4, 1986, the next order by Judge Janow was dated February 19, 1991. I immediately appealed, but the Virginia Court of Appeals dismissed my appeal in May, 1991 in a non-published opinion saying that it was a non-final order. I filed a mandamus petition against Judge Janow. That was dismissed as well with the statement that this must wait until a final order was issued. However, in child custody cases, there is never really a completely final order. I have appealed about 14 times in these cases and have never been able to get an appeal heard on the merits.

In spite of the obvious illegality of what Judge Janow did, I was four years later arrested for violating the order of August 25, 1986. Prior to being arrested, I had called the Amherst County Sheriff's office and had been told by a deputy that there were no charges pending against me. When I was arrested on November 13, 1990, when I first arrived in Amherst County to try to recover my by then kidnapped daughter, I believed that I had been lied to by the Sheriff's Deputy who told me that no charges were pending against me. Later, however, when I was sitting in my prison cell at Dillwyn Correctional Center, I discovered that the deputy had not lied. The order for my arrest had been issued by Judge Janow dated November 13, 1990, the same date that I was arrested. Judge Janow had heard that I was in Amherst and had quickly ordered my arrest. He had called Sheriff Michael Cox and told him to go over to Amherst Social Services, where I was waiting after having been told that I could see my daughter there, and arrest me. This was also illegal. The statute of limitations for misdemeanor charges, which this was, is one year. It was clearly illegal to charge me with this for the first time, four years later. (Actually the Roberts had tried numerous times to have charges brought against me in Amherst, but the Amherst County Commonwealth Attorney, Ed Meeks, had nolle prossed their charges.)

Yet on December 16, 1991, more than five years after the incident in question, I was convicted of this charge by Judge Gamble and sentenced to jail.

Copy of the decision of Judge Gamble, which was entered December 30, 1991, is enclosed. There were several things illegal about this. Judge Gamble says that I failed to appear. However, he had previously written a letter to my lawyer, James H. Massie III, saying that he would not hear the case on that day and my appearance was not required. Even the Roberts did not appear on that day, as they surely would have had they known there would be a hearing on that date. Also, no evidence was presented on this issue. Judge Gamble himself was effectively the only witness, based on his knowledge of the case, gleaned while my legal adversary when he was the lawyer for Alma Coates Dawson. There was no actual sworn testimony of live witnesses on this issue. In addition, as I had never been served with the order, how could I be guilty of disobeying it? More importantly, if you will read carefully the order dated August 25, 1986, you will see that I was not ordered to do anything. The order said "the court orders that this matter remain in status quo and allows the child, Shamema Honzagool Sloan, to be enrolled in Temple Baptist School by Mr. and Mrs. Charles Roberts pending the outcome of the final hearing".

As you can see, my name is nowhere mentioned. I was ordered neither to do, nor to refrain from doing, anything. How could I be guilty of violating such an order?

Knowing Judge Gamble as I do, he probably never read the order he found me guilty of violating. Judge Gamble is slipshod. He does not read the papers or look up the case law. He just makes up his own law as he goes along. I find it amazing that he graduated from law school and passed the bar (although I understand that the Virginia bar was much easier back then.) I feel that somebody should check his law school grades and diploma.

Finally, in his decision dated December 30, 1991, Judge Gamble removed my attorney from this case, thereby effectively depriving me of my right to appeal. This was a violation of my constitutional rights under Penson v. Ohio, 488 U.S. 75 (1988) and was also a violation of Virginia law.

Even though I was only sentenced to ten days on that charge (the maximum), that was the linchpin to their case, because without that conviction, they could not have convicted me of the more serious charge of attempted abduction of my daughter, for which they were trying to give me 15 years, and they could not have retained custody of my daughter.

My complaints against Judge Gamble were recently mentioned in a news story in the Lynchburg News and Advance dated February 22, 1999 entitled "Local jurist re-elected by Assembly". Here is what the newspaper said:

"Local legislators said Sloan, who sent a threatening e-mail about Gamble to legislator's offices two years ago, was not credible.

" Del. Preston Bryant, R-Lynchburg, said Sloan 'threatened the judge via e-mail. She (Baskerville) obviously didn't dig into this deeply enough.'

"Sloan, who has a local criminal record and was involved in a bitter custody fight in the Amherst County courts for years, is no stranger to Central Virginia judges or prosecutors. Over the years, he's sued several of them.

'Judge Gamble is a fine judge,' Bryant said.

" Del. Lacey Putney, I-Bedford, agreed.

"Both Bryant and Putney said they'd received letters from Sloan about Gamble and disposed of them.

"'We get a letter from him every so often,' Bryant said. 'As I remember the last one was quite an epistle.'

Putney said he also received a five to 10 page, rambling letter from Sloan.

"'I threw it away without even reading it,' he said."

Regarding this, I would like to note that, in addition, State Senator Steve Newman of Lynchburg refused to receive my mail. My envelope to him was returned to me marked "refused". Senator Newman has also blocked me from sending him e-mail.

This is the problem I face: A whispering campaign is against me. No Virginia newspaper has ever reported the central underlying fact behind all of this, that my daughter, Shamema Honzagool Sloan, was kidnapped by Charles and Shelby Roberts, who had the assistance and support in their criminal acts of Judge Lawrence Janow and Michael Gamble along with several governmental officials.

As to the claim that I sent threatening letters to or about Judge Gamble, that is absolutely untrue. If it were true, I would not be writing you this letter from my home in Brooklyn New York. I would be in jail, instead. Two agents of the FBI and one United States Marshall came to my house not long ago and questioned me extensively about threats which they said Virginia judges claimed to have received from me. Although the FBI did not identify the judges, it was plainly apparent that they were talking about Judge Janow and Judge Gamble. I asked the FBI to show me the threatening letters, and they were unable to do so. In fact, there are none. I was not arrested.

The name of the principal FBI agent was Anthony Currie. I told him that the crime he should be investigating is the kidnapping of my daughter, a blatant and obvious criminal act. I also complained to him that FBI agent John P. Butler in Roanoke has assisted the Roberts in their kidnapping of my daughter and that officials of the Commonwealth of Virginia including the present Governor who was previously Assistant Attorney General was also involved in the commission of this crime, through his deputy, Barbara J. Gaden. Currie later told me that he had sent an inquiry to the FBI headquarters about this, but had never received any reply.

Similarly, in Virginia, Judge Janow sent the Virginia State Police to my home in Lynchburg in January, 1991, also claiming that I had threatened him. There were no such threats then, either unless you consider the letter I am presenting here to be a threatening letter, because it contains much the same statements as letters I have sent over the past 12 years. Judge Janow and Judge Gamble keep doing this over and over again, claiming that I have threatened them and trying to have me arrested, to cover up the fact that they are guilty of a crime, the crime of conspiring to kidnap my mother and daughter and to steal my mother's house and financial assets.

In spite of constantly complaining that they have received threats from me, they both refuse to disqualify themselves from my cases, obviously because they know that what they have done is illegal and no that other judge would ever do it.

Since you doubt my credibility, here is what Judge Gamble himself wrote about this situation. You will think that this is something that I wrote, but actually it was written my him:

"These circumstances are as follows:

"(1) M. Ismail Sloan consulted with J. Michael Gamble in 1985 about representing him in the matters involved in this case at a time when J. Michael Gamble was a practicing attorney. Although J. Michael Gamble did not take the case M. Ismail Sloan did talk with J. Michael Gamble about the facts of the case for about one hour. Also, J. Michael Gamble accepted a retainer fee which he returned by mail the same day.

"(2) Stephen C. Martin, a former law partner of J. Michael Gamble, represented M. Ismail Sloan in earlier proceedings in the matters in this case. Confidential or privileged information was provided to Stephen C. Martin as a result of such representation.

"(3) Donald G. Pendleton, a former law partner of J. Michael Gamble, represented a person claiming to have an adverse interest in M. Ismail Sloan in the estate of the father of M. Ismail Sloan. Possibly confidential or privileged information was given to Donald G. Pendleton, at the time he was the partner of J. Michael Gamble.

"(4) Lawrence Janow, Juvenile and Domestic Relations District Court Judge of Amherst County, who has heard many of the proceedings in this case, was a law partner of J. Michael Gamble from 1974-1979.

"(5) J. Michael Gamble has heard many discussions of this case by numerous sources.

"(6) Linda B. Carroll, the former legal secretary of J. Michael Gamble, is a close friend of Mr. and Mrs. Charles Roberts, a party to these proceedings."

Judge Gamble made these statements in connection with his request that I and the other parties waive his disqualification in two cases. As noted in my previous letter to you, Judge Gamble's request for a waiver was improper because he was involved these cases to such an extent that he was absolutely disqualified from being a judge. No waiver was possible under the Code of Judicial Conduct. Even more importantly, Judge Gamble only requested a waiver of disqualification in two cases. There were four other cases and Judge Gamble refused to be disqualified from any of those four cases.

One of those cases involved the sale of my mother's house and was filed in 1992, which is well after I had demanded that he disqualify himself from all of my cases. I enclose a copy of the amended complaint in that case. It is readily apparent that Judge Gamble was disqualified from hearing this case, because his law firm had filed a lawsuit against both me and my mother, the same defendants as are defendants in this case. The name of both cases is Sloan v. Sloan and that other case is still pending in Lynchburg Circuit Court.

The case for the sale of my mother's house was also without jurisdiction. The central allegation to the case is that my bother is the court appointed guardian of my mother. That is not true. My brother has never been so appointed, neither in Virginia nor anywhere else. Actually, I have the power of attorney with respect to my mother. Also, paragraph 5 of the amended complaint alleges that the "only" income my mother receives is $4000 per month and her expenses are $2000 per month, so she needs to sell the real estate.

My mother has often stated that she intends never to sell that house and she intends to remain in that house for as long as she lives. However, my brother hates his mother and has often stated that he wants to get revenge on her for neglecting him during his childhood. My brother says my mother should have quit her job as psychiatrist/director of various Virginia state mental health clinics and should have devoted her full time to raising him. In addition, my brother supports Charles and Shelby Roberts and instigated them against me and my mother in the first place.

Judge Gamble allowed Frank Davidson III, the attorney for Charles and Shelby Roberts, to appear as essentially self-appointed "guardian ad litem" for my mother. Davidson said he was not appearing generally, but "only to secure the sale of the house." The Roberts had an evil reason for wanting the house sold. I had been living in that house with my children. They wanted to be able to say that I had no place to live and therefore they were the more fit custodians for my daughter, whom they had kidnapped. Also, even though I was in prison and named as a defendant, Judge Gamble refused to appoint counsel to represent me, in spite of being required by the Code of Virginia to do so. Then, without a formal trial, a hearing or any medical testing or evidence of any kind, he ordered the house sold for the ridiculously low price of $75,000, when the house was easily worth $150,000, and then gave the entire proceeds to Cecil Taylor, my mother's legal adversary. He said that since Frank Davidson had agreed to the sale of the house, there was no need for a hearing. I enclose a copy of an application by Cecil Taylor to Judge Gamble for a legal fee of $11,206, far more than the statutory amount. However, that was not his last legal bill. Hearings continued until mid-1994 and each time I was brought from my prison cell to attend, without counsel. His total bill came to $18,000, plus there were moving and storage charges of $10,000, so only $47,000 remained. The money has since disappeared. Cecil Taylor is dead and his former law partner, Edgar Perrow, says that he does not know what happened to the money. Contrary to law, Judge Gamble did not appoint the Commissioner of Accounts to oversee the money.

Apparently, there is skepticism as to whether my daughter was really kidnapped. I feel that it is sufficient to show that my daughter, then 8 years old, disappeared from the front yard of my house in Fujairah, United Arab Emirates on the afternoon of October 7, 1990, and arrived in the house of Charles and Shelby Roberts on the early morning of October 9, 1990, without the consent or the permission of either the mother or father of my daughter, plus the clear evidence that the Roberts purchased and paid for the airplane tickets. Judge Gamble said in his order dated November 18, 1991, a copy of which is enclosed: "In October 1990, Mr. Sloan's wife, Renuka, along with her child by Mr. Sloan, Jessica, and Shamema came to Virginia by airplane with tickets purchased and sent to them by Mr. and Mrs. Roberts."

However, there is more, because Renuka testified that she did this because her life and the life of her daughter had been threatened by the professional kidnappers hired and paid by Charles Roberts. Here is the testimony of Renuka before Judge Janow on December 19, 1990 (pages from this transcript are enclosed):

Q Do you know anyone named Boonchoo or Sobell?
A Yes. I know them
Q How do you know them?
A I know them, because when I was -- It's a long story, you know. When I was right from Sri Lanka to U.A.E., then I get telephone call from Charles Roberts and he told me Boonchoo, they hire him, they hire the lawyer Boonchoo to the legal custody of Shamema. And they told me my daughter, Jessica and Michael, they have nothing to eat and they are in Thailand and they were looking for Jessica's mother.
They already know Dayawathie was in New York and they was looking for me. They told me, Charles Roberts, he told me, "If you want to get your daughter back, you call them and find out." Then I called the Boonchoo and they gave his number and I called the Boonchoo and he told me I better to come over there, that without him my daughter will be dead already, because he just leave my daughter in the hotel room, he just go away and they are running around in the outside, in the main road, nobody care about them, and that how I know Boonchoo.
Q How about somebody named Sobell.
MR. SLOAN Sobell, S-o-b-e-l-l, John Sobell.

BY THE COURT: (Continuing)
Q John Sobell
A I know him, he was American man and he was working for Boonchoo. Also he called me in the U.A.E. and he told me to come over there and take my daughter. That how I know him.
THE COURT: Any other questions?
MR. SLOAN: Yeah. I want to know, when she came back to the United Arab Emirates, did Boonchoo call her up on the phone and threaten to kill her or make any threats against her, that she should hand over Shamema and Jessica?

BY THE COURT: (continuing)
Q Were there any threats made to you by anyone with regard to any of these children?
A Boonchoo, when I was in United Emirates, he called me in the house and he tell me he want I to turn Shamema to his side, otherwise he's gong to kill me and he going to tell something, I stole from his -- something, something like that, he told me. Then I get really scared and then I call Charles and Shelby and I tell them, "What happened, he was telling me something like I stole stuff and I have to turn Shamema to their side, otherwise they're going to kill me." I don't really get this scared, because they was in another country and I was in another country, far away. That's all.

Also, in the same transcript, Charles Roberts testified that he paid Boonchoo ten thousand dollars for these services. Roberts testified:

BY THE COURT: (Continuing)
Q How much was paid for these services?
A Actually, I don't know if this was pertinent or not, but I don't have anything to hide. I paid him two installments of five thousand dollars.

Also, Roberts made it clear that he was aware that Renuka had been threatened. He testified: "I wasn't aware that he threatened to kill her. She called me by telephone and said he had scared her or upset her and I called John Sobell to find out just what was going on and he said it was just his way of trying to get her back on their side. Since apparently you had intimidated her back to your side, they wanted to try to scare her back to their side."

It should be obvious that Renuka was threatened, even without this testimony. She did not know Charles Roberts. Why would she go with a man she did not know and involve herself in a kidnapping which would in no way benefit her but would greatly benefit him (except that she got an airplane ticket to America out of this)? It is perfectly obvious that Renuka was in fear of her own life and the life of her daughter, Jessica, if she did not turn another woman's child, Shamema, over to Mr. Roberts. She had every reason to fear Mr. Roberts, especially since Boonchoo and his men had already chased us the whole length of Thailand and we had barely escaped across the border with the children into Malaysia.

All of this is well known to both Judge Janow and Judge Gamble. Indeed, they were participants in this as was Barbara J. Gaden, an assistant attorney general of Virginia. In fact, Judge Janow stated in open court that the Roberts were "justified in doing what they did." That is the reason there has been no prosecution for this crime of kidnapping, in spite of overwhelming evidence that this crime occurred.

In spite of my constant complaints to the law enforcement agencies, plus an Interpol warrant for the arrest of Charles Roberts for the kidnapping of my daughter, Shamema, this crime has never even been investigated by the federal, state or local authorities. If there were an investigation, one of the first people they would ask about it would be Renuka, and Renuka has never been contacted.

There are so many points that I cannot even touch them all. This is only the tip of the iceberg. For example, the decision of Judge Gamble dated November 18, 1991 says that in 1986 Judge Janow awarded custody to this Roberts. This is not really true. The order of Judge Janow contains the phrase "present custodians" but does not say who the present custodians are. Charles and Shelby Roberts were not named in the order. It could be the mother, Honzagool, who had legal custody in New York State, it could be me, it could be my mother, it could be the Department of Social Services. Nobody could imagine that a mere paid baby sitter, Shelby Roberts, who was paid handsomely for her services, was intended as the "present custodian". In this and several other ways, the orders of Judge Janow are vague and ambiguous. He wrote these orders in this way for two reasons (1) so that they could be interpreted in different ways depending which way the wind blew and (2) to make impossible any appeal I wanted to bring. Judge Janow openly stated in court "I will not allow any appeal in this case".

Also, Judge Gamble did at one point disqualify himself from one criminal case involving me, but not because of his personal involvement in the facts of the case. Rather, he disqualified himself because the sole witness against me in one of the cases was Lynchburg Commonwealth Attorney Bill Petty. A letter came from the Supreme Court of Virginia dated October 22, 1992, a copy of which is enclosed, indicating that both Judge Gamble and Bill Petty would have to disqualify themselves. Judge Gamble complied but Bill Petty refused to disqualify himself and thereby became both the witness and the prosecutor, which is a violation of the canons of ethics of the bar. Petty explained that he could not find any other prosecutor with the time to prosecute the case, but the real reason was that the case against me was frivolous.

Judge Gamble signed an order dated October 20, 1992 disqualifying himself from the criminal case dated, a copy of which is enclosed. Nevertheless, he disobeyed his own order because one week later he appeared in my case over my vehement objections and removed my defense counsel, James H. Massie, a second time. Remember that Judge Gamble had removed Massie as my counsel on December 16, 1991. However, this was another case and Massie had come back in. It is obvious that the reason Gamble removed Massie was that Massie knew the case and was doing a good job of defending me. Gamble appointed in Massie's place the weakest possible attorney, David B. Bice, who tried to get out of the case, to no avail.

I have mentioned several times Judge Gamble's order dated November 18, 1991 in which he awarded custody of my daughter to the Roberts. This order was actually written by counsel for the Roberts for the judge's signature and contains a distorted version of the true facts. For example, it implies that Shelby Roberts was not paid for her services. This is not true. She was paid in full and she even received a $5,000 bonus in August 1986. He makes no mention of the fact that my daughter was kidnapped by the Roberts. He states that I abandoned my daughter, which was a lie since my entire life has revolved around my daughter since the day she was born. He also states that I kidnapped my daughter in New York. This is not true and what transpired between my wife, Honzagool, and me in New York and in Pakistan in 1982 and 1983 is of no concern to Judge Gamble or to Charles and Shelby Roberts. They were not there and there was no testimony or evidence before the court on such matters.

You will note that Judge Gamble's order of November 18, 1991 is marked Exhibit 9. This is because it was used as an exhibit in the criminal trial against me. In fact, this is the only time I ever received a copy of Judge Gamble's order. I was already in jail. It was never served, either. Another outrageous fact is that the jury was given this decision to take to read with them in the jury room. This was clearly improper, because Judge Gamble's order directly states that I kidnapped my daughter twice. It was the same as having Judge Gamble testify as a witness against me but without the opportunity for my cross examination. Also note that I was charged with the attempted abduction of my daughter on September 5, 1991, but Judge Gamble's order was dated November 18, 1991, more than two months later. Thus, the order was irrelevant to the criminal case and served only to inflame the jury against me. One of the jurors was a client of David B. Bice and later told Mr. Bice that it was because of Judge Gamble's written order, which they read in the jury room, that I was convicted, because the testimony of the live witnesses was unconvincing.

I also have since found out that one of the jurors who convicted me was a co-worker of Charles Roberts who worked with him for 13 years at Limitorq Corporation and concealed this fact from the court.

In summary, I wish to emphasize that Judge Michael Gamble was initially disqualified from acting as a judge in this case for several reasons. One was that his law firm had filed a case against me and my mother which is still pending in Lynchburg Circuit Court: Sloan v. Sloan. In addition, I had consulted with him as my lawyer and had given him confidential information which he proceeded to pass to my legal adversaries. Had Judge Gamble not done this egregiously unethical act, probably none of these cases would have ever been filed. Furthermore, everything Judge Gamble has done in these cases has been illegal. There was no jurisdiction to award custody of my daughter to Charles and Shelby Roberts or even for the courts to entertain their custody suit. The orders for my arrest issued by Judge Gamble were illegal and without basis. His trial, conviction and sentence of me in absentia was illegal. His order for the sale of my mother's house was without jurisdiction.

Moreover, these are not merely historical events. Judge Gamble is still trying to have me attested again and to start this all over again. Two agents of the FBI came to my house not long ago. Judge Gamble insists on being the judge in all my cases, including any new cases which are filed. My daughter, now 17 years old, is still being held prisoner by the Jerry Falwell group and they will continue to hold her prisoner, with the full cooperation of the Lynchburg and Amherst law enforcement authorities, regardless of how old gets. Don't think that they are going to let her go just because she becomes of legal age. As long as Judge Gamble continues to sit as a judge, this case was just go on and on and will never end because Judge Gamble is determined personally to destroy me and my entire family.

Accordingly, I am asking that Judge Gamble be removed as a judge and that he be punished in accordance with law.

Attached you will find 48 pages of documentation, including numerous court orders by Judge Gamble, letters by Judge Gamble and the like. You will find that I have provided documentary evidence in support of every one of my claims against Judge Gamble. I believe that this documentation plus the previous documents and the two previous letters I wrote you constitute more than sufficient grounds to proceed against Judge Gamble. I also note that a law passed by the voters last November requires that a public record be made of complaints against judges. I made an ethical complaint against Judge Janow in early February, 1991, before he had conducted his first hearing in this case. Reno Harp, your predecessor, returned the original to me two days later by return mail and presumably did not even file it. On the morning before my first scheduled actual hearing before Judge Janow on February 19, 1991, I received back my complaint from Reno Harp along with a note saying that my complaint would not be entertained. Your office probably does not even have a record of that earlier ethical complaint.

Very Truly Yours,

Sam Sloan

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