PLEASE TAKE NOTICE that upon the annexed affidavit of Samuel H. Sloan sworn to the 6th day of January, 2006, 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
samsloan@samsloan.com
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
RENEWED 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 renewed motion to disqualify Alexander Karam, Dorchen Leidholdt and Sanctuary for Families and all persons associated with them from appearing as counsel in this case.
2. I have made this motion previously but apparently the court does not appreciate the full extend of the situation.
3. Dorchen Leidholdt is a lesbian lunatic and a sick demented woman. She founded an organization called gVictims of Pornographyh. While constantly railing in the press against pornography and organizing the street demonstrations one sees from time to time, her writings are actually pornographic. For example, her often cited statement that 25% of all female children are sexually molested by their own fathers is itself pornographic. For this reason, the statements by Dorchen Leidholdt are often published in pornographic literature such as Hustler Magazine. Hustler also publishes revealing pictures of Dorchen Leidholdt taken when she was younger.
4. However, I do need to tell you about this, because you can read it yourself. Attached hereto is a copy of an article Dorchen Leidholdt wrote entitled, gWhen Women Defend Pornographyh, which is found in the book gThe Sexual Liberals and the Attack on Feminismh by Dorchen Leidholdt and Janice G. Raymond. This book is filled with essays by militant lesbians, some of them quite famous. Anybody reading this essay will immediately realize that the author is seriously ill and emotionally disturbed.
5. Dorschen Leidholdt is the legal director for Sanctuary for Families, She is the boss of Alexander Karam who is a new hire having just graduated from Columbia University Law School in 2005. Dorchen has founded numerous groups, one of which is the gCoalition Against the International Trafficking of Womenh. She uses my children and their mother as the poster children for her organization. This is obviously based on the fact that I brought the mother, Dayawathie Rankoth, from Sri Lanka to America twice to give birth to my children.
6. Dorchen Leidholdt uses my children to collect charitable contributions. She has established various 501(c)(3) corporations. In short, she uses my children to make money. Wealthy people can get tax deductions by donating to the various organizations which Dorchen Leidholdt has founded. Dayawathie Rankoth thinks that Dortchen Leidholdt is a nice lady her gives her money all the time but that is because she fails to realize that what is really going on is Dorchen Leidholdt is using her to make money. This is obviously a conflict of interest.
7. Dorchen Leidholdt has had me arrested three times. In May and June 1995, I was held in jail mostly in the Alameda County Jail in Santa Rita for 42 days on a charge of kidnapping. However, I was never brought before a judge in court. California allows a person to be held gPending investigationh. Meanwhile Dorchen Leidholdt had my two sons, Michael and George, extradited to New York, which is why they are here now.
8. She had me arrested twice again in 1997. I was living in Far Rockaway Queens and driving a taxi for Towne Taxi in nearby Lawrence, Long Island. Dorchen Leidholdt had Dayawathie call me and tell me that Anusha was seriously ill and needed to be taken to the hospital and I needed to come to her house right away. What I did not realize was that Dorchen Leidholdt had taken out an order of protection against me which I had never been served with so I did not know about. When I appeared at the apartment to take Anusha to the hospital for this serious illness she was supposedly suffering from, two police officers were waiting to arrest me in a trap set by Dorchen Leidholdt.
9. Dorchen Liedholdt is doing the same thing here again. Here we have an order of protection prohibiting me from seeing any of my children including my eldest son Michael. However, Michael is not in the home. He has been arrested and is in mental hospital. His case worker is Nicole Valasko. She had called me and advises me that Michael should not be returned to the home of Dayawathie Rankoth. Michael should live with me, her father, she says. Two psychiatrists, Dr Arya and Dr. Attila Polonyi, have made the same recommendation. I am sure that, if asked, they would recommend that all three of my children be removed from that home, especially since Dayawathie has had two drug dealers living there. Yet, the court does not know about this, because of the misconduct by Dorchen Leidholdt and her subordinate Alexander Karam. I was not even allowed to sent Christmas presents to my children.
10. 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
samsloan@samsloan.com
917-507-7226
347-869-2465
Sworn to before me this 6th Day
of January, 2006
_______________________________
NOTARY PUBLIC